T4
FANNIE_MAE
High Confidence
Guidance
Lender Letter LL-2025-01 Updates to the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit
FHFA directive to align Fannie Mae and Freddie Mac foreclosure timeframe requirements across jurisdictions
LOW
Impact Level
Top: Operational (3)
Classification
- Regulatory Program
- GSE Servicing Requirements
- Doc Type
- Guidance
- Effective Date
- 2025-07-01
- Days to Action
- -380
- Comment Deadline
- —
- Published
- 2025-04-09
Urgency Basis
Effective date of July 1, 2025 is more than 180 days from today's date of June 9, 2026, making this a historical change with no current urgency
Operational Context
Flags
Systems Change Required
Affected Functions
Compliance
Operations
Legal
Institution Applicability
All
Impact by Category
Compliance
2
Operational
3
Data Governance
1
Model Risk
0
Reporting & Disclosure
2
Capital & Liquidity
0
Consumer Protection
1
Third-Party Risk
2
Key Requirements
- Update foreclosure processing systems to reflect modified timeframes for 22 jurisdictions effective July 1, 2025
- Apply increased timeframes for California, Colorado, Connecticut, Georgia, Illinois, Indiana, Kansas, Kentucky, Maryland, Minnesota, Mississippi, North Carolina, Ohio, Oklahoma, Pennsylvania, Texas and West Virginia
- Apply decreased timeframes for Florida, Massachusetts, New Jersey, Nevada and Oregon
- Add COVID-19 Foreclosure Moratorium as allowable delay category with up to 670 days credit
- Remove Unemployment Forbearance from allowable delay categories
- Maintain dual timeframe tracking for loans with foreclosure sale dates before and after July 1, 2025
Scoring Rationale
This is operational guidance affecting mortgage servicers' foreclosure processing timelines. The changes require workflow updates and system modifications but represent incremental adjustments to existing requirements rather than new obligations. The FHFA coordination aspect and multi-jurisdiction scope elevate operational complexity. Historical effective date (July 2025) means no current urgency despite operational impact.
AI Analysis Disclosure — This record, including its scores, impact assessments, and Advisory
Assessment (impact, risk, and recommended actions), was generated by an AI model and may contain errors or
omissions. The Advisory Assessment is a starting point for analysis, not a substitute for professional judgment.
Effective dates, applicability determinations, impact assessments, and any recommended actions should be
independently verified against primary regulatory source documents and reviewed by qualified compliance or legal
personnel before taking compliance action. This output does not constitute legal or compliance advice.