Announcement SVC-2025-06 – Servicing Guide Update
Alignment with Bankruptcy Rule 3002.1 amendments and clarification of existing GSE servicing policies for bankruptcy cramdowns
Advisory Assessment
Impact. This Fannie Mae servicing update modifies bankruptcy-related procedures in two key areas: updated attorney fee schedules that take effect December 1, 2025, and new cramdown policies requiring voluntary loan repurchases before court-ordered modifications by February 1, 2026. Your servicing operations will need revised workflows for bankruptcy fee processing and enhanced coordination between legal and asset recovery functions when cramdowns threaten.
Risk. Legal and servicing functions face the highest exposure, particularly around cramdown timing and the voluntary repurchase requirement. Examiners will scrutinize whether your institution properly identifies cramdown scenarios early enough to execute voluntary repurchases, and whether bankruptcy attorney fee schedules reflect the updated categories and naming conventions.
Recommended Action. Have your legal team review current bankruptcy servicing procedures against the new cramdown repurchase requirement and coordinate with operations to map workflow changes. Update your bankruptcy attorney fee processing systems to incorporate the revised fee categories before the December 1 deadline.
Watch. Monitor for additional GSE guidance on cramdown identification criteria and repurchase timing, as implementation questions typically surface as servicers work through the new procedures in live bankruptcy cases.
Classification
- Regulatory Program
- GSE Servicing
- Doc Type
- Guidance
- Effective Date
- 2026-02-01
- Days to Action
- -165
- Comment Deadline
- —
- Published
- 2025-11-12
Urgency Basis
Final implementation deadline is February 1, 2026, which is over 180 days from today (May 26, 2026). However, the bankruptcy attorney fee changes are already effective as of December 1, 2025.
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is a limited-scope update to GSE servicing requirements affecting bankruptcy procedures. While it creates new compliance obligations, the changes are incremental and affect a narrow subset of servicing activities. The bankruptcy attorney fee updates are largely administrative, while the cramdown clarification affects policy implementation but not fundamental operations. Impact is concentrated in legal and servicing functions with minimal cross-enterprise effects.