SFA Updates the Seasoned Mortgage Scope of Review

On June 2, the Structured Finance Association (SFA) published the Seasoned Mortgage Loan Scope of Review (the “Scope”). From 2023-2025, members of the ATR/QM Scope of Review Task Force and SFA developed the Scope as a uniform compliance standard to review seasoned ATR mortgage loans with 36+ months of clean pay history. The Scope aims to standardize the method by which diligence firms review seasoned loan files, which will benefit rating agencies, investors, and other secondary market securitization participants who rely on diligence findings.

The Scope was updated in November 2025 and published in January 2026, adding 7 additional FAQs pertaining to pay history considerations.

SFA’s Seasoned Mortgage Scope of Review document contains the following: 

1. Introduction, Background and Overview– detailing the development of the Scope.
2. SFA Seasoned Loan Scope of Review – detailing the Scope, the eligibility parameters, loan designations, and other considerations when using the Scope.
3. Frequently Asked Questions – detailing FAQs and answers that arose among Task Force members during the development of the Scope – expanded in January 2026.

Please direct questions and comments to Dallin Merrill or Jeanne Valk.