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T4 FANNIE_MAE High Confidence Guidance

Announcement SVC-2025-04 – Servicing Guide Update

GSE servicing guide maintenance including mortgage insurer consolidation, foreclosure timeframe updates, and BSA/AML compliance clarification

LOW
Impact Level
Top: Compliance (2)

Advisory Assessment

Impact. Your servicing operations must remove all references to Republic Mortgage Insurance Company from loan files and systems while adding UGI as an approved MI Claims Portal participant. The guide also revised foreclosure timing requirements and compensatory fee structures, directly affecting your loss mitigation workflows and fee calculations.

Risk. BSA/AML compliance procedures face the highest scrutiny since the October 2025 review deadline has passed without clear guidance on what specific updates were required. Fannie Mae examiners will expect documented evidence that your AML processes align with the updated servicing guide standards, and gaps here typically trigger broader compliance reviews.

Recommended Action. Have your compliance team immediately audit current BSA/AML servicing procedures against the updated guide requirements and document any remediation steps taken since the October deadline. Operations should simultaneously verify that Republic Mortgage Insurance references have been purged from all active systems and that UGI portal access is properly configured.

Watch. Monitor for any Fannie Mae enforcement actions or additional guidance clarifying the BSA/AML servicing requirements, as the retroactive nature of these changes suggests ongoing regulatory focus in this area.

Classification

Regulatory Program
GSE Servicing Standards
Doc Type
Guidance
Effective Date
2025-07-09
Days to Action
-372
Comment Deadline
Published
2025-07-09

Urgency Basis

Changes are effective as of July 9, 2025, which is 314 days before today's date (May 19, 2026). All compliance obligations are already past due.

Operational Context

Flags
Retroactive Provision
Affected Functions
Compliance Operations Legal
Institution Applicability
All

Impact by Category

Compliance
2
Operational
2
Data Governance
0
Model Risk
0
Reporting & Disclosure
1
Capital & Liquidity
0
Consumer Protection
1
Third-Party Risk
1

Key Requirements

- Remove references to Republic Mortgage Insurance Company from servicing systems and documentation - Update MI Claims Portal participant information to reflect UGI addition - Implement revised foreclosure timeframes and compensatory fee allowable delays - Review and update BSA/AML compliance procedures by October 2, 2025 - Update approved mortgage insurer lists and related system identifiers

Scoring Rationale

This is routine GSE servicing guide maintenance addressing administrative updates (mortgage insurer consolidation), operational adjustments (foreclosure timeframes), and compliance clarification (BSA/AML). The changes are incremental and primarily affect single business units with limited cross-functional impact. Effective dates are already past, indicating this is historical information rather than actionable guidance.

Scored: 2026-05-19T07:01:21.559Z Model: claude-sonnet-4-20250514 Confidence: High Aggregate Score: 1.4
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.