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T4 FANNIE_MAE High Confidence Guidance

Lender Letter LL-2026-01 Updates to retention workout options and disaster-related foreclosure proceedings policy

Updates to GSE servicing requirements for disaster-related borrower assistance and foreclosure proceedings

MODERATE
Impact Level
Top: Compliance (3)

Classification

Regulatory Program
GSE Servicing
Doc Type
Guidance
Effective Date
2026-05-01
Days to Action
-76
Comment Deadline
Published
2026-02-11

Urgency Basis

Effective date was May 1, 2026, which is 39 days before today's date of June 9, 2026. This is already in effect but represents operational guidance changes.

Operational Context

Flags
Consumer Harm Risk
Affected Functions
Compliance Operations Customer Facing
Institution Applicability
All

Impact by Category

Compliance
3
Operational
3
Data Governance
2
Model Risk
0
Reporting & Disclosure
2
Capital & Liquidity
0
Consumer Protection
2
Third-Party Risk
0

Key Requirements

- Structure forbearance plans in three-month increments not exceeding 12 months cumulative - Submit Forbearance Exception Request Template for plans exceeding Guide thresholds - Obtain Fannie Mae written approval before foreclosure referral on disaster-impacted properties - Submit detailed foreclosure recommendations within five days of prereferral review completion - Include disaster impact assessment data in all foreclosure referral submissions

Scoring Rationale

This Fannie Mae Lender Letter updates existing servicing requirements rather than creating entirely new obligations. The compliance score of 3 reflects moderate changes to mandatory servicing practices. Operational impact is also moderate due to workflow changes for forbearance structuring and foreclosure referrals. The effective date has already passed, making this T4 for monitoring compliance with implemented changes.

Scored: 2026-06-09T01:01:22.932Z 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.