T4 FANNIE_MAE High Confidence Guidance

Lender Letter LL-2026-02 Impact of Federal Government Shutdown

Temporary operational accommodation for federal government shutdown impact on employment verification

LOW

Impact Level

Top: Compliance (2)

Classification

Regulatory Program: GSE Lending Standards
Doc Type: Guidance
Effective Date: 2026-02-14
Days to Action: -152
Comment Deadline: —
Published: 2026-03-03

Urgency Basis

Temporary guidance for shutdown that already ended - government resumed full operations before today's date of 2026-06-09

Operational Context

Affected Functions

Compliance Operations

Institution Applicability

All

Impact by Category

Compliance

Operational

Data Governance

Model Risk

Reporting & Disclosure

Capital & Liquidity

Consumer Protection

Third-Party Risk

Key Requirements

- Document loan files with written statement of VOE attempts when waived due to shutdown - Continue attempting verbal VOE through automated systems or third-party providers - Warrant borrower employment at loan delivery when VOE waived - Maintain compliance with DU validation service requirements and close-by dates - Implement two-month minimum reserves for applications after March 16, 2026 if shutdown continues - Evaluate impacted borrowers for forbearance plans per existing servicing guidelines

Scoring Rationale

This is temporary guidance providing limited waivers and alternative procedures during a government shutdown. The guidance was effective during the shutdown period (Feb 14, 2026) but automatically expired when government resumed operations. Since today is June 9, 2026, this guidance is no longer active. Impact scores reflect the limited operational changes required - primarily documentation requirements and alternative employment verification procedures. The guidance did not create new substantive obligations but rather provided flexibility in existing requirements.

Scored: 2026-06-09T00:01:24.676Z 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.