1. Lock the review population
Start from a complete list of the loans in scope for the cycle. Reconcile the count and key totals to the system of record before selecting loans. Keep the original import, the import timestamp, the source, and any exclusions with their documented reasons.
- Define the production month and channels in scope.
- Reconcile funded, acquired, sold, cancelled, and excluded loans.
- Retain stable loan identifiers without exposing unnecessary borrower data.
- Freeze the population version used for selection.
2. Document the sample before review begins
A sample is defensible when another qualified person can recreate it. Record the method, population, channel strata, parameters, random seed when applicable, selected membership, and selection timestamp. Keep discretionary and targeted selections identifiable so they do not silently distort the random sample’s defect rate.
For Fannie Mae, the guide permits either a ten-percent random sample or a statistically valid sample at a 95% confidence level with a 2% precision rate, subject to the guide’s conditions. The current guide also requires separate treatment of retail and third-party originations. Read the current section before setting your method.
3. Inventory the file evidence
Record what was received, what is missing, and which document version is controlling. Prefer structured sources such as MISMO and UCD for data ingestion, then preserve the actual source document and page used for each material conclusion.
- Application and underwriting documentation
- Income, employment, asset, credit, and occupancy evidence
- Appraisal or collateral documentation
- Loan Estimate and Closing Disclosure versions
- Note, security instrument, riders, and closing package
- Delivery, insurance, and program-specific evidence
4. Reperform the material checks
Do not reduce the review to document presence. Recompute important outcomes from stored inputs and identify the rule version used. Typical work includes eligibility and underwriting consistency, material data reconciliation, disclosure timing and tolerance, fee comparison, closing document consistency, and investor-specific requirements.
5. Track reverification as a stateful process
A generated request is not a completed reverification. Record the provider, request date, delivery channel, response date, returned evidence, result, exception, follow-up, and any approved waiver separately. Preserve the response itself where your policy permits.
6. Give every finding an accountable disposition
Each finding should state the condition, source evidence, applicable requirement, severity, owner, response, and final disposition. Material findings should not be cleared without a rationale. If facts change, retain both the original observation and the correction trail.
7. Close the cycle with analysis and corrective action
A loan report closes one file; a cycle report explains the portfolio. Reconcile selected, reviewed, incomplete, and excluded counts. Separate random and discretionary defect rates, identify severity and trends, record management review, and assign corrective action with owners and due dates.
Compact handoff checklist
| Control | Evidence to retain | Owner |
|---|---|---|
| Population | Source, reconciliation, exclusions, frozen version | QC administrator |
| Selection | Method, strata, seed, parameters, membership | QC administrator |
| File review | Documents, facts, calculations, citations | Reviewer |
| Reverification | Request, response, result, exception | Reviewer |
| Disposition | Severity, response, rationale, approval | Reviewer / manager |
| Cycle close | Counts, defect analysis, trends, action plan | QC manager |
For the underlying operating model, read the complete post-closing quality control guide.
Frequently asked questions
What belongs in a post-closing QC checklist?+
At minimum: population reconciliation, documented sampling, required file evidence, data and eligibility checks, compliance timing, third-party reverifications, finding severity and disposition, corrective action, trend reporting, and evidence that the cycle was completed on schedule.
Is a checklist the same as a QC plan?+
No. A QC plan defines governance, scope, methods, responsibilities, timelines, escalation, reporting, and corrective action. A checklist operationalizes part of that plan for a specific review and should point back to the controlled plan and current agency requirements.
Can the checklist be fully automated?+
Some steps can be calculated or validated automatically, but final dispositions, materiality, third-party verification outcomes, and corrective action normally require accountable human review.
Primary sources
Requirements change. Confirm the current guide and your approved QC plan before changing a production process.