T4 FANNIE_MAE High Confidence Guidance

Announcement SVC-2025-06 – Servicing Guide Update

Alignment with Bankruptcy Rule 3002.1 amendments and clarification of existing GSE servicing requirements

LOW

Impact Level

Top: Compliance (2)

Classification

Regulatory Program: GSE Servicing
Doc Type: Guidance
Effective Date: 2025-12-01
Days to Action: -227
Comment Deadline: —
Published: 2025-11-12

Urgency Basis

Earliest effective date was December 1, 2025, which is over 180 days past reference date of June 9, 2026

Operational Context

Affected Functions

Compliance Operations Legal

Institution Applicability

All

Impact by Category

Compliance

Operational

Data Governance

Model Risk

Reporting & Disclosure

Capital & Liquidity

Consumer Protection

Third-Party Risk

Key Requirements

- Update allowable bankruptcy attorney fee structures to include Response to Motion to Determine Status fee by December 1, 2025 - Rename Response to Final Cure Payment Notice to Response to Trustee's Notice of Disbursements Made - Implement voluntary repurchase requirement before proceeding with court-ordered bankruptcy cramdowns on recourse or indemnified loans by February 1, 2026 - Review and update bankruptcy servicing procedures to align with clarified cramdown requirements

Scoring Rationale

This is a routine GSE servicing guide update with limited operational impact. The bankruptcy attorney fee updates are administrative changes aligning with federal rule amendments. The cramdown clarification provides helpful guidance but represents existing policy interpretation rather than new requirements. Impacts are concentrated in servicing operations and legal functions with minimal cross-functional coordination needed.

Scored: 2026-06-09T04:01:20.614Z 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.