Lender Letter LL-2025-01 Updates to the Foreclosure Time Frames and Compensatory Fee Allowable Delays Exhibit
GSE servicing alignment and FHFA direction to standardize foreclosure timeframes with Freddie Mac
Advisory Assessment
Impact. This guidance requires servicers to apply updated foreclosure timeframes across 22 jurisdictions and revise compensatory fee calculations to include COVID-19 related delays while removing unemployment forbearance provisions. The changes affect both system configurations for timeline tracking and fee calculation methodologies that determine servicer compensation from Fannie Mae.
Risk. Operations teams face the highest exposure from potential system misconfigurations that could apply incorrect timeframes to active foreclosure cases or miscalculate compensatory fees. The dual-track requirement to maintain legacy exhibit rules for pre-July 2025 sales while implementing new frameworks creates complexity that examination teams will scrutinize for accuracy.
Recommended Action. Operations should immediately audit current foreclosure timeline configurations and compensatory fee calculations to confirm full implementation of the July 2025 changes. Work with legal to validate that the correct exhibit version applies to each active case based on foreclosure sale timing.
Watch. Monitor for any Fannie Mae servicer letters addressing implementation questions or calculation disputes that emerged during the initial rollout period. Track examination findings from other servicers regarding timeline or fee calculation errors related to this exhibit transition.
Classification
- Regulatory Program
- GSE Servicing Requirements
- 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 was over 300 days ago from today's date of May 19, 2026. This is historical guidance that has already taken effect.
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is a routine GSE servicing update affecting operational processes and compliance calculations for Fannie Mae servicers. The changes are administrative in nature, updating timeframes and allowable delay categories. Since the effective date has already passed (July 1, 2025 vs. today's date of May 19, 2026), this represents historical guidance. Impact scores reflect the operational adjustments required but not enterprise-level changes.