Lender Letter LL-2025-01 Updates to the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit
FHFA direction to align Fannie Mae and Freddie Mac foreclosure timeframes across jurisdictions and update allowable delay categories for post-pandemic environment.
Advisory Assessment
Impact. Your servicing operations must update foreclosure processing systems to reflect new timeframes across 22 jurisdictions and implement tracking for revised allowable delay categories, including removal of unemployment forbearance delays. Third-party foreclosure counsel must also align with these updated jurisdictional requirements for loans entering foreclosure after July 1, 2025.
Risk. Operations teams face the highest exposure if system updates lag behind the effective date or if foreclosure counsel networks operate under outdated timeframes. Examination focus will likely center on whether your tracking systems properly distinguish between pre- and post-July 2025 loans and correctly apply the revised delay categories.
Recommended Action. Operations should immediately audit current foreclosure processing systems against the new exhibit requirements and coordinate with IT to implement necessary system changes. Simultaneously, notify all foreclosure counsel of the jurisdictional timeframe updates and establish compliance monitoring protocols for the revised delay tracking.
Watch. Monitor for any FHFA guidance clarifying transition procedures for loans already in foreclosure and track whether Freddie Mac issues corresponding updates to maintain GSE alignment. Additionally, watch for examination guidance from your primary regulator on how these changes affect safety and soundness reviews.
Classification
- Regulatory Program
- GSE Servicing Standards
- 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 over 180 days past today's reference date of May 26, 2026. This guidance has already taken effect and should be monitored for ongoing compliance.
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is a routine operational update to GSE servicing standards rather than new regulatory requirements. The changes are administrative adjustments to foreclosure timeframes directed by FHFA to align the GSEs. Impact is moderate on operations due to multi-jurisdictional updates and system changes needed, but low overall as this represents guidance refinement rather than substantive new obligations.