Announcement SVC-2025-06 – Servicing Guide Update
Alignment with Bankruptcy Rule 3002.1 amendments and clarification of existing GSE servicing requirements
Advisory Assessment
Impact. This Fannie Mae servicing guide update revises bankruptcy procedures and fee structures, requiring updates to your allowable attorney fee schedules and renaming certain bankruptcy notice responses. The most substantial change establishes a voluntary repurchase requirement for recourse or indemnified loans before bankruptcy cramdowns take effect.
Risk. With effective dates already passed, your institution faces immediate examination exposure if bankruptcy servicing procedures and fee schedules remain outdated. Loan-level compliance gaps will surface during any GSE quality control reviews or regulatory examinations focused on bankruptcy servicing practices.
Recommended Action. Legal should immediately audit current bankruptcy attorney fee agreements against the updated Fannie Mae schedule and confirm all required procedure updates are in place. Operations needs to verify that bankruptcy servicing workflows reflect the cramdown policy clarifications and notice renaming requirements that took effect months ago.
Watch. Monitor upcoming GSE quality control sampling for any findings related to these bankruptcy procedure changes, as enforcement activity typically follows expired implementation deadlines. Track whether Freddie Mac issues parallel guidance that could require additional procedural alignment.
Classification
- Regulatory Program
- GSE Servicing Requirements
- Doc Type
- Guidance
- Effective Date
- 2025-12-01
- Days to Action
- -227
- Comment Deadline
- —
- Published
- 2025-11-12
Urgency Basis
Earliest effective date was December 1, 2025, which is over 180 days past the current date of May 19, 2026
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is a routine GSE servicing guide update with incremental changes to bankruptcy procedures and attorney fees. The compliance score reflects new obligations but limited scope. Operational impact is low, affecting primarily bankruptcy servicing workflows. The guidance nature and limited scope justify the low aggregate score, though the effective dates have already passed as of the current reference date.