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T4 FANNIE_MAE High Confidence Guidance

Lender Letter LL-2025-01 Updates to the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit

GSE alignment with FHFA direction to standardize foreclosure timeframes across government-sponsored enterprises

LOW
Impact Level
Top: Compliance (2)

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 date of June 2, 2026, indicating this change has already taken effect and no immediate action is required for implementation

Operational Context

Affected Functions
Compliance Operations Legal
Institution Applicability
All

Impact by Category

Compliance
2
Operational
2
Data Governance
1
Model Risk
0
Reporting & Disclosure
2
Capital & Liquidity
0
Consumer Protection
1
Third-Party Risk
1

Key Requirements

- Update foreclosure timeline tracking systems to reflect new state-specific maximum allowable days - Apply new timeframes to all loans with foreclosure sale dates on or after July 1, 2025 - Add COVID-19 Foreclosure Moratorium and Forbearance as allowable delay categories - Remove Unemployment Forbearance from allowable delay calculations - Continue using current exhibit for loans with foreclosure sale dates prior to July 1, 2025

Scoring Rationale

This is a Fannie Mae operational guidance update that modifies existing foreclosure timeline requirements rather than creating new regulatory obligations. Impact scores are low to minimal as this represents incremental changes to established GSE servicing standards. The change affects multiple jurisdictions but is primarily operational in nature, requiring system updates and process modifications rather than fundamental compliance restructuring.

Scored: 2026-06-02T13:01:41.555Z Model: claude-sonnet-4-20250514 Confidence: High Aggregate Score: 1.5
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.