T1 FANNIE_MAE High Confidence Guidance

Lender Letter LL-2025-03 Impact of Federal Government Shutdown

Federal government shutdown operational contingency planning and business continuity requirements

MODERATE

Impact Level

Top: operational (4)

Advisory Assessment

Impact. This guidance triggers immediate activation of your government shutdown contingency procedures, requiring coordinated response across operations, servicing, and vendor management functions. Your institution must now execute pre-existing business continuity plans while monitoring potential delays in government-dependent loan processing activities.

Risk. Operations teams face the highest exposure if contingency plans prove outdated or inadequately tested, particularly around vendor coordination and government-dependent workflow management. Examination focus will center on whether your institution maintained adequate service levels and consumer protection standards during the shutdown period.

Recommended Action. Operations should immediately convene a cross-functional response team including Risk Management, Treasury, and Vendor Management to execute your shutdown contingency checklist and establish daily monitoring protocols. Confirm communication pathways with Fannie Mae remain functional and document all operational adjustments for examination readiness.

Watch. Monitor the duration and scope of the government shutdown for escalating impacts on loan processing timelines, and track any supplemental guidance from Fannie Mae regarding modified operational expectations or reporting requirements during the shutdown period.

Classification

Regulatory Program: GSE Operations
Doc Type: Guidance
Effective Date: 2025-11-03
Days to Action: 1
Comment Deadline: —
Published: 2025-10-01

Urgency Basis

Federal government shutdown guidance requires immediate operational response and contingency planning activation

Operational Context

Flags

Examination Focus Systems Change Required Board Reporting Required

Affected Functions

Operations Risk Management Treasury Loan Origination Loan Servicing Vendor Management

Institution Applicability

Fannie Mae Approved Lenders Mortgage Originators Mortgage Servicers

Impact by Category

Compliance

Operational

Data Governance

Model Risk

Reporting & Disclosure

Capital & Liquidity

Consumer Protection

Third-Party Risk

Key Requirements

- Activate government shutdown contingency procedures immediately - Review and update business continuity plans for shutdown scenario - Coordinate with affected third-party vendors and service providers - Monitor impact on loan processing and servicing operations - Maintain communication channels with Fannie Mae during shutdown - Prepare for potential delays in government-dependent processes

Scoring Rationale

This is operational guidance requiring immediate action due to government shutdown timing. While not creating new regulatory requirements, it necessitates activation of existing contingency plans and coordination across multiple business functions. The impact is moderate but urgent given the immediate nature of government shutdown effects.

Scored: 2026-05-16T06:02:50.053Z Model: claude-sonnet-4-20250514 Confidence: High Aggregate Score: 2.4

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.