{
  "_meta": {
    "schemaVersion": 1,
    "description": "LO-facing agency-guideline bulletins. Read by /portal/cal-updates.html for display and (separately) ingestable into Cal's KB for query-time citation.",
    "lastUpdated": "2026-05-23T11:00:00-07:00",
    "ingestNote": "Each entry has plain summary + structured changes[] array. The changes array is what should land in cal_kb_chunks so Cal can cite the specific section when an LO asks about (e.g.) 'IRS installment agreement' or 'hourly income future employment'."
  },
  "bulletins": [
    {
      "id": "fnma-ll-2026-04-ai-ml-governance",
      "date": "2026-04-08",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/lender-letter-ll-2026-04-governance-framework-use-artificial-intelligence-and-machine-learning",
      "kind": "agency-guideline-update",
      "title": "Lender Letter LL-2026-04 — Governance Framework for AI / ML in Origination and Servicing",
      "effective": "Immediate disclosure obligation upon Fannie Mae request",
      "scope": ["Fannie Mae"],
      "loSummary": "Fannie Mae now requires Seller/Servicers to maintain governance and disclose, on request, the types of AI/ML used, the purpose and manner of use, and the safeguards in place to mitigate AI/ML risk. Parallel to FHLMC §1301.13 effective Mar 3, 2026. Cal is architected to make this disclosure trivial — every cal answer is provenance-tracked to the section, effective date, and supersession chain. The audit story is built in, not bolted on.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Lender Letter LL-2026-04",
          "topic": "AI / ML Governance Disclosure Obligation",
          "headline": "BIG: Seller/Servicers must disclose AI/ML types, purpose, manner, and safeguards on Fannie request",
          "previousGuideline": "No explicit Fannie Mae governance framework for Seller/Servicer use of AI/ML in origination or servicing. Use was governed by general Seller/Servicer responsibility for compliance with applicable laws and regulations, with no specific disclosure or safeguards obligation tied to AI/ML systems.",
          "newGuideline": "Effective with this Lender Letter (Apr 8, 2026): on Fannie Mae's request, the Seller/Servicer must promptly disclose (1) the types of AI/ML used in origination and/or servicing, (2) the purpose and manner of such use, (3) the safeguards the Seller/Servicer has implemented to mitigate AI/ML-related risks, and (4) such other information as Fannie Mae may require. Sellers/Servicers must maintain governance practices proportionate to their AI/ML use.",
          "loImpact": "If your shop uses any AI in origination — AVMs, automated income calculators, document classification, LLM-driven UW assistants, borrower-facing chatbots, or Cal — Fannie can now ask for a written governance package on demand. The independent LO doesn't deal with this directly; your wholesale lender does. But you should know what AI tools your shop relies on and be able to answer 'is this Fannie-disclosable?' if asked. Parallel to Freddie Mac §1301.13 (Bulletin 2025-16) effective Mar 3, 2026.",
          "categories": ["ai-ml", "governance", "compliance", "disclosure", "operations"],
          "documentationUpdate": "Required disclosure package, when requested, should cover: (1) inventory of AI/ML systems by use case; (2) purpose and manner of use per system; (3) data inputs and sources; (4) safeguards (testing, monitoring, human oversight, audit trail); (5) risk-management governance (who owns it, how decisions are reviewed); (6) any third-party AI/ML vendor relationships and their compliance posture.",
          "links": {
            "fnmaLenderLetter": "https://singlefamily.fanniemae.com/news-events/lender-letter-ll-2026-04-governance-framework-use-artificial-intelligence-and-machine-learning"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Cal Architecture · LL-2026-04 Alignment",
          "topic": "How Cal Is Built to Satisfy LL-2026-04 and §1301.13",
          "headline": "Cal is provenance-tracked, audit-ready, and never decides — only explains",
          "previousGuideline": "Generic AI mortgage tools (general-purpose LLMs answering mortgage questions, or AI-driven UW assistants) typically have no per-answer provenance: a user asks, the model answers, and there's no traceable link from the answer to a specific agency section, no record of which version of the rule was used, and no record of supersession. This makes Seller/Servicer disclosure under LL-2026-04 / §1301.13 hard to produce.",
          "newGuideline": "Cal's architecture is designed to produce LL-2026-04 / §1301.13-compliant disclosure as a side effect of how it answers. Per-answer guarantees: (1) Every citation maps to a specific cal_kb_chunks row with a stable section_id and effective_date. (2) Every chunk has a sha256 chunk_hash for tamper-evident provenance. (3) Supersession is tracked via superseded_by FK — when Fannie publishes a new B3-6-05, the old chunk is marked, retrieval auto-filters, but the old version stays queryable for audit. (4) Cal is an explainer + reference, not a decisioner: the LO remains in the loop for every file. (5) Nightly LLM-judged eval against a 75-case mortgage benchmark; trend published at askcal.io/status. (6) Source URLs preserved per chunk so any answer can be traced back to the original agency publication.",
          "loImpact": "For your shop: if your wholesale lender or compliance team asks 'is the AI tool you're using safe under LL-2026-04?', cal's answer is 'yes, by design.' Every cal answer comes with the source section, effective date, and provenance trail. If audit comes calling, you can produce the disclosure package straight from cal's data model. For independent LOs using cal directly: you're not the disclosing entity, but your tool of record is built so your wholesale partner can support their disclosure if needed.",
          "categories": ["ai-ml", "governance", "compliance", "cal-architecture", "audit", "provenance"],
          "documentationUpdate": "Cal's disclosure package (auto-generatable on request): (1) System type: retrieval-augmented LLM with citation enforcement, no agency decisioning. (2) Models: Claude (Anthropic) for explanation generation, OpenAI text-embedding-3-small for semantic retrieval. (3) Purpose: provide LO-facing guideline reference with source citation. (4) Safeguards: BM25 + cosine rerank with per-chunk provenance; supersession tracking; nightly regression eval (askcal.io/status); LLM-judge tiebreak on rule-fail; human-in-the-loop required for every file decision; no autonomous decisioning. (5) Data sources: published agency Selling Guides and bulletins only; no PII training; no model fine-tuning on borrower data. (6) Monitoring: public eval pass-rate, public KB freshness, public cost-to-serve.",
          "links": {
            "fnmaLenderLetter": "https://singlefamily.fanniemae.com/news-events/lender-letter-ll-2026-04-governance-framework-use-artificial-intelligence-and-machine-learning",
            "calStatusPage": "https://askcal.io/status"
          }
        }
      ],
      "talkingPoints": [
        "Fannie can now ask 'what AI tools do you use and how?' under LL-2026-04. Freddie's parallel §1301.13 is already live (Mar 3, 2026).",
        "Cal is built for this — every answer has a citation, every citation has provenance, every chunk has supersession tracking.",
        "Cal doesn't decide — it explains. The LO is always in the loop. That's an LL-2026-04 safeguard by design.",
        "If your shop is asked for an AI/ML disclosure, your cal answers come with the receipts already attached."
      ]
    },
    {
      "id": "fnma-sel-2026-04-vantagescore-fico-10t",
      "date": "2026-04-22",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/announcement-sel-2026-04-selling-guide-updates",
      "kind": "agency-guideline-update",
      "title": "Announcement SEL-2026-04 — VantageScore 4.0 and FICO Score 10T Credit Score Modernization",
      "effective": "VantageScore 4.0 immediate (limited rollout); FICO 10T later phase",
      "scope": ["Fannie Mae"],
      "loSummary": "FHFA-directed credit score modernization rolls into the Selling Guide. VantageScore 4.0 is now an approved credit score model for conventional loans, effective immediately through a limited rollout to participating lenders. FICO Score 10T comes in a later phase. Lenders not in the limited rollout continue to use Classic FICO until VantageScore 4.0 is broadly available.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-5.1-01",
          "topic": "Approved Credit Score Models — VantageScore 4.0 and FICO Score 10T",
          "headline": "VantageScore 4.0 approved for tri-merge use (limited rollout); FICO 10T to follow",
          "previousGuideline": "Conventional loans delivered to Fannie Mae required Classic FICO scores from each of the three credit bureaus through a tri-merge merged credit report. VantageScore was not an approved credit score model for new loan deliveries.",
          "newGuideline": "Fannie Mae now approves two additional credit score models: VantageScore 4.0 and FICO Score 10T. VantageScore 4.0 is available immediately to lenders participating in the limited rollout — those lenders may use VantageScore 4.0 from each of the three credit bureaus through a tri-merge merged credit report when originating and delivering new loans. Lenders NOT participating in the limited rollout must continue using Classic FICO from each bureau through a tri-merge until VantageScore 4.0 is made broadly available. FICO Score 10T adoption follows at a later phase (specific date TBD).",
          "loImpact": "Big-picture shift for credit. If you're with a wholesale lender in the limited rollout (UWM and Rocket Pro have confirmed they're live as of May 2026), you can now pull VantageScore 4.0 alongside or instead of Classic FICO. For most LOs, the practical impact starts later when broad availability lands — but borrowers who score higher under VantageScore than FICO Classic (often thin-file or younger borrowers) may now qualify on conventional where they couldn't before. Don't promise a borrower a VantageScore-based approval until you confirm your specific lender is in the limited rollout.",
          "categories": ["credit", "credit-score", "vantagescore", "fico", "tri-merge", "conventional"],
          "documentationUpdate": "When using VantageScore 4.0 under the limited rollout, the tri-merge credit report must include VantageScore 4.0 from each of the three credit bureaus. Documentation requirements otherwise unchanged. Historical credit score data: Fannie will publish FICO Score 10T data for loans acquired April 2013 — September 2025, plus VantageScore 4.0 data April 2023 — September 2025, to support investor analysis.",
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-5.1-01/general-requirements-credit-scores",
            "fanniemaeNewsroom": "https://www.fanniemae.com/newsroom/fannie-mae-news/credit-score-updates-advance-modernization"
          }
        }
      ],
      "talkingPoints": [
        "VantageScore 4.0 is live for conventional — but only at participating lenders. UWM and Rocket Pro are in.",
        "FICO 10T is coming, but no firm date. Don't quote it as a hard pull yet.",
        "Thin-file borrowers (younger buyers, recent immigrants) may score higher on VantageScore — worth checking if your lender is in.",
        "Classic FICO is still the default for non-rollout lenders. Don't switch on assumption."
      ]
    },
    {
      "id": "fnma-sel-2026-02-b3-3-income-restructure",
      "date": "2026-03-04",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/announcement-sel-2026-02-selling-guide-updates",
      "kind": "agency-guideline-update",
      "title": "Announcement SEL-2026-02 — Chapter B3-3 Income Assessment Restructure + Texas 50(a)(6) Clarifications",
      "effective": "Loan applications dated on or after 2026-06-01 (lenders may apply immediately)",
      "scope": ["Fannie Mae"],
      "loSummary": "Major rewrite of Chapter B3-3 (Income Assessment) into a clearer modular format — and the headline change LOs care about: documentation for fixed base income and variable base income is reduced from 2 years of W-2s + paystub down to JUST the most recent W-2 + paystub. Plus automobile allowance history requirement is cut from 2 years to 1 year. Also clarifies appraisal review requirements permitted for Texas Section 50(a)(6) loans.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-3.1-01",
          "topic": "Documentation Requirements for Fixed and Variable Base Income (W-2 Employees)",
          "headline": "W-2 + paystub: only the MOST RECENT required (was 2 years of W-2s + paystub)",
          "previousGuideline": "For fixed base income and variable base income from W-2 employment, lender required W-2s for the most recent 2 years PLUS a current paystub. The 2-year W-2 history established earnings trend, with paystub showing YTD earnings.",
          "newGuideline": "Reduced documentation: only the MOST RECENT W-2 (1 year) plus a current paystub is required. Two-year W-2 history is no longer required for base income documentation on either fixed OR variable income types. (Paystub timing requirements unchanged — must still meet existing dating standards.)",
          "loImpact": "This is the biggest income-doc simplification in years. Borrowers who just landed a new W-2 job 12-18 months ago (and don't have a clean 2-year W-2 history because they switched employers, had a gap, or are new to the workforce) just got dramatically easier to qualify on conventional. Document budget on a file just dropped meaningfully. The change is effective for apps dated on/after 2026-06-01 but lenders MAY apply it immediately — check your wholesale lender for early-adopt status.",
          "categories": ["income", "documentation", "w-2", "base-income", "variable-income", "conventional"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-3.1-01/general-income-information"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-3.1-09",
          "topic": "Automobile Allowance Income — History Requirement",
          "headline": "Auto allowance history reduced from 2 years to 1 year",
          "previousGuideline": "Automobile allowance income required 2 years of receipt history before it could be used as qualifying income, with documentation showing consistent receipt and likelihood of continuance.",
          "newGuideline": "Automobile allowance history requirement reduced from 2 years to 1 year, aligning with the housing allowance policy. One year of consistent receipt + likelihood of continuance now sufficient.",
          "loImpact": "Helpful for sales reps, district managers, route drivers, and other W-2 employees who get a monthly car allowance as part of comp. Anyone with 12+ months of consistent allowance receipt can now count it toward qualifying income on conventional. Same documentation standards otherwise.",
          "categories": ["income", "automobile-allowance", "allowance-income", "documentation"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-3.1-09/other-sources-income"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B5-4.1-02",
          "topic": "Texas Section 50(a)(6) Appraisal Review Requirements",
          "headline": "Appraisal review requirements clarified for Texas 50(a)(6) (Texas Cash-Out) loans",
          "previousGuideline": "Texas Section 50(a)(6) loans (Texas Constitution cash-out refinance) had appraisal review requirements that were embedded in general appraisal policy. Specific permitted review methods were not separately enumerated.",
          "newGuideline": "Clarified which appraisal review requirements ARE permitted for Texas 50(a)(6) transactions. Sellers may now use the clarified appraisal review options for these refinances. Specific review methods enumerated in the updated guidance.",
          "loImpact": "If you work Texas cash-out refis, the appraisal review path is now explicit. Cleaner UW process; less ambiguity on what your wholesale lender can/can't accept. Anchor to the updated B5-4.1-02 language when an UWer pushes back on appraisal review method.",
          "categories": ["appraisal", "texas", "cash-out", "refinance", "texas-50a6"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b5-4.1-02/texas-section-50a6-loans"
          }
        }
      ],
      "talkingPoints": [
        "Apps dated 6/1/2026+: only the most recent W-2 + paystub required (was 2yr W-2s + paystub). Confirm early-adopt status with your lender.",
        "Auto allowance: 12 months of receipt now enough (was 24).",
        "Texas cash-out (50(a)(6)): appraisal review path is now explicitly enumerated."
      ]
    },
    {
      "id": "fnma-sel-2026-01-mh-gifts-credit",
      "date": "2026-02-04",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/announcement-sel-2026-01-selling-guide-updates",
      "kind": "agency-guideline-update",
      "title": "Announcement SEL-2026-01 — MH Advantage / CHOICEHome Alignment, Gift Funds Donor, Nontraditional Credit",
      "effective": "Most provisions effective immediately; lenders may apply early",
      "scope": ["Fannie Mae", "Freddie Mac (parallel)"],
      "loSummary": "Three buckets. (1) MH Advantage (Fannie) and CHOICEHome (Freddie) manufactured home programs are now aligned on key requirements at FHFA direction — same construction and installation standards for these specific MH programs. (2) Acceptable gift fund donor definition revised. (3) Nontraditional credit references topic aligned with SEL-2025-09 (removal of minimum credit score requirements for DU loans).",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B5-2-04",
          "topic": "MH Advantage / CHOICEHome — Cross-Agency Alignment",
          "headline": "FNMA MH Advantage and FHLMC CHOICEHome aligned on construction and installation standards",
          "previousGuideline": "MH Advantage (Fannie's specialty manufactured home program for site-built-looking MH) had its own construction and installation standards. CHOICEHome (Freddie's equivalent) had a parallel but separate set of standards. Manufacturers and lenders needed to track two slightly different rulebooks for these specific MH programs.",
          "newGuideline": "Under FHFA guidance, key construction and installation standards for MH Advantage and CHOICEHome are now aligned. Same requirements for site-built appearance, foundation type, garage/carport features, dormer/porch design elements, energy efficiency, and installation method.",
          "loImpact": "Cleaner for borrowers shopping MH Advantage vs CHOICEHome — same physical home qualifies under both. Easier conversation with the borrower's manufacturer and the wholesale lender (no more 'this home qualifies for MH Advantage but not CHOICEHome' situations on the specific aligned standards). Standard manufactured home (non-MH-Advantage/non-CHOICEHome) rules unchanged.",
          "categories": ["manufactured-home", "mh-advantage", "choicehome", "alignment", "fhfa"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b5-2-04/special-feature-codes-mh-advantage"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-4.3-04",
          "topic": "Acceptable Donors for Gift Funds",
          "headline": "Acceptable gift fund donor definition revised — clarifies who counts as a 'relative' or 'eligible donor'",
          "previousGuideline": "Acceptable donors for gift funds on conventional loans included a relative (defined as the borrower's spouse, child, dependent, or other person related by blood, marriage, adoption, legal guardianship), a fiance/fiancee, or a domestic partner. No funds from any party with a financial interest in the transaction (seller, builder, real estate agent acting on either side).",
          "newGuideline": "Acceptable donor definition revised in language and scope. The core principle — donor must be a relative/fiance(e)/domestic partner with no financial interest in the transaction — is preserved, but the specific wording around what qualifies as a 'relative' and what disqualifies a donor is updated for clarity. (Full revised definition published in the updated B3-4.3-04 text.)",
          "loImpact": "Most gift-fund scenarios are unaffected — parents, grandparents, siblings, fiance(e)s, domestic partners still good. The clarification matters at the edges: step-relatives, partners not formally engaged, and 'household member' situations. When in doubt on an unusual donor relationship, read the updated B3-4.3-04 verbatim before promising the borrower the gift will work.",
          "categories": ["gift-funds", "donor", "down-payment", "conventional", "underwriting"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-4.3-04/personal-gifts"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-5.4-03",
          "topic": "Nontraditional Credit References — Number and Types Required",
          "headline": "Nontraditional credit topic aligned with SEL-2025-09 (removal of minimum credit score for DU loans)",
          "previousGuideline": "Nontraditional Credit References topic specified the number and types of nontraditional credit references required for borrowers without traditional credit. The topic referenced the prior minimum credit score policy for DU loans.",
          "newGuideline": "Nontraditional Credit References topic updated to align with SEL-2025-09, which previously removed the minimum credit score requirement for Desktop Underwriter loans. The number-and-types-of-references guidance is updated to reflect the current DU-driven credit assessment approach.",
          "loImpact": "For borrowers without traditional credit (newly arrived in US, all-cash lifestyle, recent young adults), the path through nontraditional credit on DU is now consistent with the no-minimum-credit-score policy. DU is the gatekeeper; the nontraditional references support the DU decision rather than satisfying a separate minimum-score threshold. Helpful for thin-file borrowers in DU files.",
          "categories": ["nontraditional-credit", "thin-file", "du", "credit", "first-time-buyer"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-5.4-03/nontraditional-credit-references"
          }
        }
      ],
      "talkingPoints": [
        "MH Advantage and CHOICEHome are now aligned on key standards — same home qualifies under both.",
        "Gift fund donor definition: parents/grandparents/fiance(e)s still good; check B3-4.3-04 for edge cases.",
        "Thin-file borrowers: DU + nontraditional credit references is the path. No minimum FICO score in DU."
      ]
    },
    {
      "id": "fnma-sel-2026-03-du-archival-employer-income",
      "date": "2026-04-01",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/announcement-sel-2026-03-selling-guide-updates",
      "kind": "agency-guideline-update",
      "title": "Announcement SEL-2026-03 — DU Archival Policy + Employer-Level Income Validation",
      "effective": "Most provisions effective immediately",
      "scope": ["Fannie Mae"],
      "loSummary": "Operational updates. DU casefile archival policy clarified. Employer-level income validation in the DU validation service expanded. MBS pool data and document delivery updates (mostly affects post-closing/secondary market teams, not LO origination).",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-2-02",
          "topic": "DU Validation Service — Employer-Level Income Validation",
          "headline": "Employer-level income validation expanded in DU validation service",
          "previousGuideline": "DU validation service validated income at the borrower level — pulling employer/income reports for the specific borrower's employment record. Employer-level data was not separately presented or used for validation.",
          "newGuideline": "Employer-level income validation now an additional layer in the DU validation service. DU can now validate income against employer-level data (employer's reported pay structure, average pay for role, employer payroll integrity) as a cross-check on borrower-reported income. Helps validate borderline or unusual income presentations.",
          "loImpact": "Subtle workflow change. When a borrower's reported income looks 'off' against typical compensation for that employer/role, DU may now flag it earlier. Net: cleaner files validate through DU faster; outlier files surface conditions earlier in process. No changes to LO-facing documentation; this is mostly a behind-the-scenes accuracy improvement in the DU validation service.",
          "categories": ["du", "income-validation", "employer", "automation", "underwriting"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-2-02/du-validation-service"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide A2-1-04",
          "topic": "DU Casefile Archival Policy",
          "headline": "DU casefile archival timeline clarified",
          "previousGuideline": "DU casefiles were archived after a certain inactivity period; the specific window and what could be done with archived casefiles (re-open, retrieve, modify) was not fully explicit in policy.",
          "newGuideline": "Casefile archival timeline and lender access to archived casefiles is now clarified. Specific window for active casefile access, archival trigger, and retrieval process is enumerated. (Specific timeframe published in updated A2-1-04.)",
          "loImpact": "Operational/admin. If you've had a deal sit dormant for months and now want to revive it, know that the DU casefile may be archived — confirm casefile status with the lender before promising the borrower you can just 'reactivate' an old approval. Otherwise no day-to-day impact on origination.",
          "categories": ["du", "casefile", "archival", "operations"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/a2-1-04/du-casefile-archival"
          }
        }
      ],
      "talkingPoints": [
        "DU validation service now cross-checks borrower income against employer-level data. Cleaner files clear DU faster.",
        "DU casefiles archive after inactivity — confirm casefile status before reviving an old approval."
      ]
    },
    {
      "id": "fnma-sel-2026-05-ron-c2p-coop",
      "date": "2026-05-21",
      "source": "Fannie Mae (Direct)",
      "sourceUrl": "https://singlefamily.fanniemae.com/news-events/announcement-sel-2026-05-selling-guide-updates",
      "kind": "agency-guideline-update",
      "title": "Announcement SEL-2026-05 — RON, Single-Closing C2P Loan Modifications, Co-Op Project Eligibility (IRS Installment covered separately)",
      "effective": "Most provisions effective immediately",
      "scope": ["Fannie Mae"],
      "loSummary": "Four-topic announcement. IRS installment agreement update is already in cal's KB from the Arc Home parsing. THIS entry covers the other three: Remote Online Notarization (RON) eligibility updates, single-closing Construction-to-Permanent loan modification policy, and co-op project eligibility.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B8-7-01",
          "topic": "Remote Online Notarization (RON) — Updated Eligibility",
          "headline": "RON eligibility requirements updated",
          "previousGuideline": "Remote Online Notarization (RON) was permitted for closing eligible loan products in eligible jurisdictions under specific technology and audit requirements. Eligibility was scoped to states with RON-authorizing legislation and certain transaction types.",
          "newGuideline": "RON eligibility requirements updated — broader product eligibility, refined technology vendor standards, and updated state-by-state authorization mapping. (Specific scope changes published in updated B8-7-01 text.)",
          "loImpact": "If you're working remote or military-PCS borrowers, the RON path keeps expanding. Confirm with your closing agent and wholesale lender that the borrower's state, the transaction type, and the RON platform all line up under the updated B8-7-01 — but the trend is clearly toward more RON, not less. Useful for active-duty military, expat borrowers, and borrowers physically unable to attend in-person closing.",
          "categories": ["closing", "ron", "remote-notarization", "military", "operations"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b8-7-01/general-information-mortgage-closing"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B5-3.1-02",
          "topic": "Single-Closing Construction-to-Permanent Loan Modifications",
          "headline": "Single-closing C2P loan modification policy clarified",
          "previousGuideline": "Single-closing Construction-to-Permanent (C2P) loans converted from construction to permanent phase using a modification of the original note. Modification mechanics and acceptable scenarios were detailed but had ambiguity around certain modification types (rate, term, payment structure adjustments at conversion).",
          "newGuideline": "Single-closing C2P modification policy clarified. Acceptable modification scenarios, required documentation, and limitations are explicit in the updated B5-3.1-02. Modifications that change loan amount, materially change terms beyond the conversion mechanics, or adjust the original note structure beyond authorized scenarios are clearly delineated.",
          "loImpact": "Affects LOs working construction loans. Single-closing C2P remains an attractive structure (one closing, one set of closing costs), and now the modification mechanics at conversion are explicit. If you have a borrower mid-construction and the loan amount/terms need adjustment at conversion, you'll have a cleaner path through your wholesale lender's UW.",
          "categories": ["construction", "c2p", "single-closing", "loan-modification", "construction-permanent"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b5-3.1-02/single-closing-construction-to-permanent-mortgages"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B4-2.3-01",
          "topic": "Co-Op Project Eligibility",
          "headline": "Co-op project eligibility updated",
          "previousGuideline": "Cooperative (co-op) project eligibility followed specific requirements for project review, ownership/occupancy ratios, financial reserves, and HOA structure. Eligibility was scoped to specific co-op project types in specific markets.",
          "newGuideline": "Co-op eligibility requirements updated — refined project review criteria, owner-occupancy thresholds, and reserve requirements. (Specific updates published in revised B4-2.3-01.)",
          "loImpact": "Mostly relevant to NYC, Boston, parts of Chicago/DC where co-op stock is meaningful. If you're working a co-op file, pull the updated B4-2.3-01 before quoting the borrower on project eligibility — a co-op that didn't qualify last year may qualify now (or vice versa). Get the project review letter from the wholesale lender early in the file.",
          "categories": ["co-op", "cooperative", "project-review", "nyc", "condo-coop"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b4-2.3-01/general-co-op-project-eligibility-requirements"
          }
        }
      ],
      "talkingPoints": [
        "RON keeps expanding — useful for remote/military/expat borrowers. Confirm state + platform + product alignment.",
        "Single-closing C2P modifications are clearer. Cleaner path if loan amount/terms need to flex at conversion.",
        "Co-op project eligibility updated — pull the latest B4-2.3-01 before quoting NYC/Boston/DC co-op files."
      ]
    },
    {
      "id": "fhlmc-bulletin-2026-1-construction-renovation",
      "date": "2026-02-04",
      "source": "Freddie Mac (Direct)",
      "sourceUrl": "https://guide.freddiemac.com/app/guide/bulletin/2026-1",
      "kind": "agency-guideline-update",
      "title": "Freddie Mac Bulletin 2026-1 — Construction-to-Permanent and Renovation Mortgage Updates",
      "effective": "Most revisions effective 2026-02-04",
      "scope": ["Freddie Mac"],
      "loSummary": "Updates to Construction-to-Permanent (C2P) and Renovation Mortgage requirements, plus Uniform Loan Delivery Dataset (ULDD) delivery instructions for both program types. Most revisions effective February 4, 2026.",
      "changes": [
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 4602.1",
          "topic": "Construction-to-Permanent Mortgages — Requirements",
          "headline": "Freddie's C2P requirements updated to align with broader construction-loan policy",
          "previousGuideline": "Construction-to-Permanent Mortgage requirements (C2P) included specific construction phase rules, conversion mechanics, and delivery requirements. Single-closing vs two-closing C2P structures had distinct rule sets.",
          "newGuideline": "C2P requirements revised — refined construction phase documentation, conversion timing, builder eligibility criteria, and delivery instructions for both single-closing and two-closing structures. ULDD delivery for C2P loans separately updated (see ULDD topic below).",
          "loImpact": "If you're working Freddie Mac construction loans, the documentation and timing pieces are now clearer. Coordinate with the builder on the documentation packet at the front end of the file — builders who don't habitually deliver these documents on time can blow up your conversion timeline. Same downstream rules; cleaner upstream documentation expectations.",
          "categories": ["construction", "c2p", "freddie", "construction-permanent", "ulld"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/4602.1"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 4607.1",
          "topic": "Renovation Mortgages — Requirements",
          "headline": "Freddie's Renovation Mortgage requirements updated",
          "previousGuideline": "Renovation Mortgage program (Freddie's equivalent of FNMA HomeStyle Renovation, plus the CHOICERenovation product) required specific documentation around renovation scope, contractor eligibility, draw schedule, and post-completion appraisal. Specific eligibility was scoped to certain property types.",
          "newGuideline": "Renovation Mortgage requirements revised — refined renovation scope rules, contractor/draw schedule documentation, and post-completion verification. ULDD delivery for Renovation Mortgages separately updated.",
          "loImpact": "If you're working CHOICERenovation files (Freddie's HomeStyle equivalent), the contractor and draw schedule documentation is clearer. Vet contractors against the updated criteria before letting the borrower commit. Renovation Mortgages remain a strong play for buyers competing on dated properties — and now the rules are explicit.",
          "categories": ["renovation", "choicerenovation", "construction", "purchase-renovation", "freddie"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/4607.1"
          }
        }
      ],
      "talkingPoints": [
        "Freddie C2P documentation expectations are clearer — get builder docs in early.",
        "CHOICERenovation: contractor and draw schedule documentation refined. Good play vs HomeStyle for renovation-purchase deals."
      ]
    },
    {
      "id": "fhlmc-bulletin-2026-3-gift-of-equity",
      "date": "2026-03-04",
      "source": "Freddie Mac (Direct)",
      "sourceUrl": "https://guide.freddiemac.com/app/guide/bulletin/2026-3",
      "kind": "agency-guideline-update",
      "title": "Freddie Mac Bulletin 2026-3 — Gift of Equity Restriction",
      "effective": "Gift of equity revisions: apps received on/after 2026-06-03. Other revisions: 2026-03-04",
      "scope": ["Freddie Mac"],
      "loSummary": "Important conventional change. Gift of equity (where the property seller credits the borrower equity that reduces the purchase price/down payment) now has a use restriction: when proceeds of a gift of equity exceed the amount needed for closing, the excess may only be used to pay off or pay down the borrower's debt at closing — paid by the property seller directly to the creditor. Effective for mortgages with application received dates on or after June 3, 2026.",
      "changes": [
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 5501.4",
          "topic": "Gift of Equity — Use of Proceeds When Exceeding Closing Costs",
          "headline": "Excess gift-of-equity proceeds may only be used to pay off/down borrower's debt at closing — paid directly by seller to creditor",
          "previousGuideline": "Gift of equity from the property seller could be applied to down payment, closing costs, and other allowable purposes per general gift-fund rules. When the equity gift exceeded the amount needed to close, the excess could be retained as cash by the borrower or applied to other reasonable purposes per Seller/Servicer judgment.",
          "newGuideline": "When the proceeds of a gift of equity EXCEED the amount needed for closing, the excess may ONLY be used to pay off or pay down the borrower's debt at closing. Additionally, the payoff must be made by the property seller directly to the creditor (not routed through the borrower). Effective for mortgages with application received dates on or after 2026-06-03. The base gift-of-equity allowance for down payment and closing costs is unchanged.",
          "loImpact": "Specific scenario change. Most gift-of-equity files use the gift to reduce purchase price + cover down payment + closing — no excess. But files where (e.g.) parents gift $80K of equity on a $300K sale (huge equity transfer because the parents bought 20 years ago), and the buyer only needs $40K to close, will now need to use the $40K excess to pay down the borrower's other debt (credit card, auto loan, student loan, etc.) — and the seller (parents) must cut the check directly to the creditor. Borrower can't receive the excess as cash-back at closing. Plan the structure upfront with the seller's counsel so the closing instructions route the payoff correctly.",
          "categories": ["gift-of-equity", "down-payment", "gift-funds", "purchase", "family-transaction", "conventional"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/5501.4"
          }
        }
      ],
      "talkingPoints": [
        "Gift of equity excess (proceeds beyond closing) can ONLY pay borrower debt at closing — and seller must pay creditor directly.",
        "Effective for apps received 6/3/2026+. Plan structure upfront if you have a large family gift-of-equity deal in pipeline.",
        "No more excess-gift cash-back to borrower at closing on FHLMC."
      ]
    },
    {
      "id": "fhlmc-bulletin-2025-16-ai-governance-insurance",
      "date": "2025-12-03",
      "source": "Freddie Mac (Direct)",
      "sourceUrl": "https://guide.freddiemac.com/app/guide/bulletin/2025-16",
      "kind": "agency-guideline-update",
      "title": "Freddie Mac Bulletin 2025-16 — AI/ML Governance, Insurance Coverage, QC Advisor Plus, 2026 Loan Limits",
      "effective": "AI/ML governance framework effective 2026-03-03; other revisions per bulletin text",
      "scope": ["Freddie Mac"],
      "loSummary": "Major end-of-year servicing/operational bulletin. Headline: AI and Machine Learning governance framework for Seller/Servicers, effective March 3, 2026. Plus revised Seller/Servicer insurance coverage limits, deductibles, documentation, reporting and compliance. Plus introduction of Quality Control Advisor Plus + Freddie Mac Gateway updates. Plus 2026 loan limit values rollout.",
      "changes": [
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 1301.13",
          "topic": "AI and Machine Learning Governance Framework",
          "headline": "Seller/Servicer AI/ML governance framework — effective 2026-03-03",
          "previousGuideline": "Freddie Mac had no specific AI/ML governance framework codified in the Selling Guide. Use of AI/ML in origination, underwriting, valuation, servicing was governed by general Seller/Servicer responsibility for compliance with applicable laws and regulations.",
          "newGuideline": "New Seller/Servicer governance framework for AI and Machine Learning systems is now codified. Sellers/Servicers using AI/ML systems must follow specified governance, transparency, risk-management, monitoring, and documentation standards. Framework covers origination, underwriting, valuation, servicing, default management, and customer-facing AI applications. Effective 2026-03-03.",
          "loImpact": "If you're at a shop that uses AI for underwriting decisioning, automated income validation, AVMs, or borrower-facing chatbots, the wholesale lender will start asking governance questions in 2026. For independent LOs, this is mostly a 'corporate compliance' item — your wholesale lender deals with it. But know that AI-tooled mortgage operations are now under explicit Freddie oversight, and lenders deeply integrated with AI may have tighter compliance documentation expected.",
          "categories": ["ai", "ml", "governance", "compliance", "operations", "automation"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/1301.13"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 9404.1",
          "topic": "Seller/Servicer Insurance Coverage Requirements",
          "headline": "Revised insurance coverage limits, deductibles, documentation, reporting, and compliance",
          "previousGuideline": "Seller/Servicer required to maintain specific insurance coverage (fidelity bonds, errors & omissions, mortgage banker's bond, cyber liability, etc.) at specific minimum coverage amounts and maximum deductibles, with annual proof-of-coverage documentation to Freddie Mac.",
          "newGuideline": "Coverage limits, deductible maximums, documentation requirements, reporting cadence, and compliance verification procedures all revised. Specific updated thresholds published in updated 9404.1. (Material change for shops near the minimum coverage threshold.)",
          "loImpact": "Operational — your wholesale lender deals with this directly. For independent LOs and brokers, no direct change to day-to-day origination. If your shop is small and was close to the minimum coverage threshold, your principal broker may need to top up coverage in 2026. Worth a quick conversation if you're at a small shop.",
          "categories": ["insurance", "operations", "compliance", "seller-servicer", "internal"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/9404.1"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Loan Limit Notice",
          "topic": "2026 Loan Limit Values",
          "headline": "Single-Family 2026 baseline conforming loan limit: $803,500 (1-unit)",
          "previousGuideline": "2025 baseline conforming loan limit for 1-unit single-family was $806,500 (with high-cost area exceptions up to $1,209,750). Loan limit indexing follows FHFA's annual HPI calculation.",
          "newGuideline": "2026 baseline conforming loan limit for 1-unit single-family is $803,500 (slight decrease from 2025, reflecting recent home-price index movement). 2-unit, 3-unit, 4-unit, and high-cost area loan limits adjusted in parallel. UWM has announced matching $803,500 conforming limit for both conventional and VA-backed mortgage locks.",
          "loImpact": "Important: 2026 baseline limit DROPPED slightly from 2025. If you have a borrower whose qualifying amount sat right at the 2025 limit, double-check they still fit the 2026 limit — there's a slim window where a borrower qualified at $805K in late 2025 but would now need jumbo financing in 2026 due to the limit drop. Most baseline-conforming files unaffected. High-cost area limits and multifamily limits adjusted in parallel — check FHFA's table for your specific county.",
          "categories": ["loan-limits", "conforming", "jumbo", "fhfa", "2026", "high-cost"],
          "links": {
            "fhlmcLoanLimits": "https://sf.freddiemac.com/articles/news/loan-limit-values-for-2026"
          }
        }
      ],
      "talkingPoints": [
        "2026 baseline conforming limit DROPPED to $803,500 (was $806,500). Borrowers near the line need to re-check.",
        "Freddie's AI/ML governance is on the books, effective 3/3/2026. Wholesale lenders own the compliance burden.",
        "Insurance coverage thresholds revised. Small shops should review with principal broker."
      ]
    },
    {
      "id": "va-circular-26-25-10-conforming-loan-limits-2026",
      "date": "2025-12-01",
      "source": "VA Lenders Handbook (Direct)",
      "sourceUrl": "https://www.benefits.va.gov/homeloans/resources_circulars.asp",
      "kind": "agency-guideline-update",
      "title": "VA Circular 26-25-10 — 2026 Conforming Loan Limits for VA Loans",
      "effective": "2026-01-01",
      "scope": ["VA"],
      "loSummary": "VA announces 2026 conforming loan limits for VA-guaranteed loans, mirroring the FHFA conforming loan limit announcement. Important: VA borrowers with FULL ENTITLEMENT can exceed the conforming limit without a down payment — the limit only constrains borrowers with PARTIAL entitlement or with prior unrestored VA usage.",
      "changes": [
        {
          "agency": "VA",
          "section": "Circular 26-25-10",
          "topic": "2026 VA Conforming Loan Limits",
          "headline": "2026 VA conforming loan limit: $803,500 (1-unit baseline); full-entitlement borrowers not capped",
          "previousGuideline": "2025 VA conforming loan limit was $806,500 baseline (1-unit), matching FHFA's 2025 conforming limit. Veterans with full entitlement (no prior VA loan, OR prior VA loan paid off + entitlement restored) had no loan amount cap — they could exceed conforming with no down payment, subject to lender underwriting. Veterans with partial entitlement were capped at the conforming limit (with 25% downpayment of any amount over the available entitlement).",
          "newGuideline": "2026 VA conforming loan limit: $803,500 baseline (1-unit), matching FHFA's 2026 conforming limit (slight DROP from 2025's $806,500). Full-entitlement Veterans remain UNCAPPED — no down payment required regardless of loan amount (subject to lender underwriting and Veteran's ability to repay). Partial-entitlement Veterans capped at $803,500 baseline (with 25% downpayment of any amount over available entitlement). High-cost area limits, 2-unit/3-unit/4-unit limits all adjusted parallel.",
          "loImpact": "First-time VA buyers with full entitlement — limit doesn't matter, structure deal at whatever the property + lender supports with $0 down. Veterans with prior VA usage (still active second mortgage, foreclosed on prior VA loan, or used entitlement on another current home): their effective ceiling dropped a hair vs 2025. Confirm the Veteran's entitlement status at the front end of the file (VA Form 26-1880 or COE through WebLGY) — partial-entitlement Veterans need a 25% downpayment on any amount over the available entitlement. Don't quote a no-DP VA loan to a partial-entitlement Veteran on an over-limit property without checking math.",
          "categories": ["va", "loan-limits", "entitlement", "veterans", "no-down-payment", "conforming"],
          "links": {
            "vaCircular": "https://www.benefits.va.gov/homeloans/resources_circulars.asp"
          }
        }
      ],
      "talkingPoints": [
        "2026 VA conforming limit: $803,500 (down from $806,500). Most full-entitlement Veterans don't care — they're uncapped.",
        "Partial-entitlement Veterans: check the math before quoting no-DP on over-limit property.",
        "Always pull the COE (WebLGY) at the front end to confirm full vs partial entitlement."
      ]
    },
    {
      "id": "va-circular-26-25-7-energy-efficiency",
      "date": "2025-09-22",
      "source": "VA Lenders Handbook (Direct)",
      "sourceUrl": "https://www.benefits.va.gov/homeloans/resources_circulars.asp",
      "kind": "agency-guideline-update",
      "title": "VA Circular 26-25-7 — Effect of Home Energy Efficiency Ratings on VA Underwriting",
      "effective": "Per circular text (Sept 2025 forward)",
      "scope": ["VA"],
      "loSummary": "VA addresses how certain Home Energy Efficiency Ratings (HEER) affect VA underwriting — specifically how energy-efficient property attributes can support qualifying, and whether HEER scores can be considered in residual income or DTI calculations.",
      "changes": [
        {
          "agency": "VA",
          "section": "Circular 26-25-7",
          "topic": "Home Energy Efficiency Ratings (HEER) in VA Underwriting",
          "headline": "HEER scores now considered in VA underwriting — energy efficiency can support qualifying",
          "previousGuideline": "VA underwriting considered the property's value and condition through standard appraisal but did not separately credit energy efficiency in residual income or qualification calculations. Energy-efficient upgrades could be financed via VA Energy Efficient Mortgage (EEM) program, but baseline UW didn't credit energy ratings.",
          "newGuideline": "VA now considers certain Home Energy Efficiency Ratings (HEER) in underwriting. Properties with verified high HEER scores can support qualifying through reduced expected utility costs in residual income calculation. Specific HEER score thresholds and underwriting credit methodology published in circular text.",
          "loImpact": "Useful for borderline DTI files on energy-efficient properties (newer construction, certified green builds, properties with documented energy upgrades). If the property has a HEER rating (HERS Index, ENERGY STAR certification, etc.), include it in the UW package — may help a borderline-DTI Veteran qualify by reducing expected utility costs in residual income. Sellers of energy-efficient homes: get the HEER documentation upfront — it's now an actual qualifying tool.",
          "categories": ["va", "energy-efficiency", "underwriting", "residual-income", "dti", "green-building"],
          "links": {
            "vaCircular": "https://www.benefits.va.gov/homeloans/resources_circulars.asp"
          }
        }
      ],
      "talkingPoints": [
        "VA now credits Home Energy Efficiency Ratings in underwriting — can help borderline-DTI Vets.",
        "Energy-efficient property with documented HEER: include in UW package, may reduce expected utility cost in residual income calc."
      ]
    },
    {
      "id": "va-circular-26-25-2-vasp-windown",
      "date": "2025-04-23",
      "source": "VA Lenders Handbook (Direct)",
      "sourceUrl": "https://www.benefits.va.gov/homeloans/resources_circulars.asp",
      "kind": "agency-guideline-update",
      "title": "VA Circular 26-25-2 — Veterans Affairs Servicing Purchase (VASP) Program Wind Down",
      "effective": "Per circular text (Apr 2025 forward)",
      "scope": ["VA"],
      "loSummary": "VA announces the wind down of the Veterans Affairs Servicing Purchase (VASP) program. VASP was a default-mitigation tool where VA acquired delinquent loans to assist Veterans in default. The program's wind down affects how lenders/servicers handle VA loan defaults going forward.",
      "changes": [
        {
          "agency": "VA",
          "section": "Circular 26-25-2",
          "topic": "VA Servicing Purchase (VASP) Program — Wind Down",
          "headline": "VASP default-mitigation program is winding down",
          "previousGuideline": "Veterans Affairs Servicing Purchase (VASP) was an active VA default-mitigation tool. VA could acquire delinquent VA loans from servicers, modify the terms, and continue servicing the loan — providing Veterans a path to retain their home during financial hardship that other loss-mitigation tools couldn't handle.",
          "newGuideline": "VASP is winding down. Servicers handling Veteran defaults must now rely on the standard suite of VA loss-mitigation tools (repayment plans, modifications, partial claims, etc.) without the VASP backstop. Specific wind-down timeline and transitional servicing instructions published in circular text.",
          "loImpact": "Mostly affects servicers, not originators. For LOs originating new VA loans: no direct impact. For Veterans who had been pre-counseled that VASP was a 'last resort' to keep their home if things went south, the conversation is different now — emphasize standard loss-mitigation tools (forbearance, repayment plans, modifications, partial claims) as the safety net. Veterans currently in VASP-eligible default situations should engage their servicer urgently before wind-down completes.",
          "categories": ["va", "default", "loss-mitigation", "servicing", "vasp", "loan-modification"],
          "links": {
            "vaCircular": "https://www.benefits.va.gov/homeloans/resources_circulars.asp"
          }
        }
      ],
      "talkingPoints": [
        "VASP (VA Servicing Purchase) is winding down. Standard VA loss-mit tools (repayment, modification, partial claim) are the path forward.",
        "Affects servicers more than originators. For LOs: just know the conversation changes for Veterans in distress."
      ]
    },
    {
      "id": "va-circular-26-23-6-ch2-funding-fee",
      "date": "2025-01-21",
      "source": "VA Lenders Handbook (Direct)",
      "sourceUrl": "https://www.benefits.va.gov/homeloans/resources_circulars.asp",
      "kind": "agency-guideline-update",
      "title": "VA Circular 26-23-6 (Change 2) — VA Funding Fee Update",
      "effective": "Per circular text (Jan 2025 forward, statutorily through 2031)",
      "scope": ["VA"],
      "loSummary": "Updates to VA Funding Fee schedule. The Funding Fee is the up-front cost VA charges to fund the loan guaranty program (waived for service-connected disabled Veterans, surviving spouses, Purple Heart recipients). This circular updates the fee schedule under the current statutory framework (active through 2031).",
      "changes": [
        {
          "agency": "VA",
          "section": "Circular 26-23-6 (Change 2)",
          "topic": "VA Funding Fee Schedule",
          "headline": "Updated VA Funding Fee schedule — statutorily set through 2031",
          "previousGuideline": "VA Funding Fee charged on each VA loan to fund the guaranty program, with rate varying by Veteran type (regular military vs Reserves/Guard), loan purpose (purchase vs refinance vs IRRRL vs cash-out), and down payment amount. Service-connected disabled Veterans, surviving spouses, and Purple Heart recipients are EXEMPT.",
          "newGuideline": "Updated Funding Fee schedule (set statutorily through 2031). Most LOs care about these key rates: First-time use, purchase, $0 down: 2.15%. First-time use, purchase, 5%+ down: 1.50%. First-time use, purchase, 10%+ down: 1.25%. Subsequent use (second+ VA loan), $0 down: 3.30%. IRRRL (refinance): 0.50%. Cash-out refinance: 3.30%. EXEMPT: service-connected disability rating, surviving spouses of Veterans who died from service-connected condition, Purple Heart recipients.",
          "loImpact": "Funding fee directly impacts disclosure and APR — disclose accurately at LE/initial disclosures. The 1.25% with 10%+ down is meaningful for higher-net-worth Veterans who want lower upfront cost — they often don't realize down payment reduces VA funding fee. Always ASK if Veteran has disability rating (10%+) before quoting — if exempt, that's $5K-$10K+ savings on most loans. Don't forget Purple Heart recipients now also exempt. The fee can be financed into the loan amount (added to loan, not paid out of pocket), which most Veterans choose.",
          "categories": ["va", "funding-fee", "disability-exempt", "irrrl", "cash-out", "purple-heart"],
          "links": {
            "vaCircular": "https://www.benefits.va.gov/homeloans/resources_circulars.asp"
          }
        }
      ],
      "talkingPoints": [
        "VA Funding Fee key rates: first-use purchase $0 down 2.15%; 5% down 1.50%; 10% down 1.25%; IRRRL 0.50%; subsequent-use $0 down 3.30%.",
        "ALWAYS ask if Veteran has disability rating (any %), surviving-spouse status, or Purple Heart. Exempt = big savings.",
        "Fee can be financed into the loan — most Veterans roll it in rather than paying out of pocket.",
        "Down payment reduces the fee — meaningful for higher-net-worth Vets."
      ]
    },
    {
      "id": "wholesale-tpo-snapshot-2026-05-23",
      "date": "2026-05-23",
      "source": "Wholesale TPO Industry Pulse",
      "sourceUrl": "https://homeloanexpress.ai/portal/cal-updates.html",
      "kind": "wholesale-tpo-snapshot",
      "title": "Wholesale TPO Snapshot — May 2026 (UWM, Rocket Pro, Pennymac, Carrington, Angel Oak)",
      "effective": "Per individual lender announcement dates",
      "scope": ["Wholesale TPO Lenders"],
      "loSummary": "Snapshot of recent wholesale TPO lender product and operational updates relevant to broker LOs. Includes credit score adoption, new product launches, and program expansions across the major TPO channels. Not a guideline change; product availability reference.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Wholesale TPO Adoption — VantageScore 4.0",
          "topic": "UWM and Rocket Pro Live with VantageScore 4.0",
          "headline": "Both UWM and Rocket Pro TPO confirmed live in the SEL-2026-04 VantageScore 4.0 limited rollout (as of May 2026)",
          "previousGuideline": "Prior to SEL-2026-04 (April 22, 2026), all major wholesale TPO channels delivered conventional loans to Fannie/Freddie using Classic FICO from the tri-merge credit report. VantageScore was not available for new loan delivery.",
          "newGuideline": "As of May 2026, both UWM (United Wholesale Mortgage) and Rocket Pro TPO have confirmed they are live in the SEL-2026-04 VantageScore 4.0 limited rollout. Brokers using UWM or Rocket Pro TPO may now pull VantageScore 4.0 alongside Classic FICO on conventional loan submissions. UWM specifically offers dual-score pulls (FICO + VantageScore) on conventional. Other wholesale TPO channels (Pennymac, Carrington, Plaza, etc.) status varies — confirm with your lender before quoting.",
          "loImpact": "If you're with UWM or Rocket Pro, VantageScore 4.0 is available immediately. Pull dual-score on borderline credit files — borrowers who score 40+ points higher on VantageScore (often thin-file or younger borrowers, or those with recent legitimate medical collections that VantageScore weighs more leniently) may now qualify where they wouldn't on Classic FICO. Don't promise dual-score until you verify your specific lender is in.",
          "categories": ["credit", "vantagescore", "uwm", "rocket-pro", "wholesale-tpo", "credit-score"],
          "links": {
            "uwmDualScore": "https://nationalmortgageprofessional.com/news/uwm-rolls-out-dual-score-option-vantagescore",
            "rocketVantageScore": "https://www.nationalmortgagenews.com/news/rocket-confirms-vantagescore-availability-for-retail-and-tpo"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Wholesale TPO Product — Pennymac Non-QM Suite",
          "topic": "Pennymac TPO Launches Comprehensive Non-QM Product Suite",
          "headline": "Pennymac TPO launched full Non-QM suite — DSCR, full doc nontraditional, bank statement, asset-based (Mar 10, 2026)",
          "previousGuideline": "Pennymac TPO offered conforming and government (FHA/VA/USDA) products to brokers but did not have a comprehensive Non-QM offering. Brokers needing Non-QM (self-employed, real estate investors with DSCR needs, bank statement borrowers) had to go to dedicated Non-QM lenders.",
          "newGuideline": "Pennymac TPO launched a full Non-QM product suite on March 10, 2026 — now available to approved TPO partners. Includes: DSCR (Debt Service Coverage Ratio) for real estate investors qualifying on property cash flow; full-doc option for borrowers with strong credit but nontraditional income sources; bank statement programs (income calculated from deposit averages and expense factors instead of tax returns); asset-based qualification. Live and available to approved partners.",
          "loImpact": "Brokers with Pennymac TPO relationships now have a one-stop shop for Non-QM in addition to conforming/government. Useful for self-employed borrowers, real estate investors, business owners, and entrepreneurs who don't qualify on traditional W-2/tax-return documentation. Compare pricing against dedicated Non-QM shops (Angel Oak, Citadel, A&D, etc.) on each scenario — Pennymac TPO Non-QM is new, so pricing competitiveness varies by program. Worth getting approved for the channel if you have meaningful Non-QM volume.",
          "categories": ["non-qm", "pennymac", "dscr", "bank-statement", "asset-based", "self-employed", "wholesale-tpo"],
          "links": {
            "pennymacAnnouncement": "https://www.housingwire.com/articles/pennymac-non-qm-tpo-products/"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Wholesale TPO Product — Rocket Pro DSCR",
          "topic": "Rocket Pro TPO Launches DSCR Investor Product",
          "headline": "Rocket Pro TPO launched DSCR loan for real estate investors qualifying on property cash flow",
          "previousGuideline": "Rocket Pro TPO offered conforming, government (FHA/VA), and some non-QM products to brokers, but did not have a dedicated DSCR investor product.",
          "newGuideline": "Rocket Pro launched a DSCR (Debt Service Coverage Ratio) product allowing real estate investor clients to qualify based on the property's expected rental cash flow rather than the borrower's personal income. Aligned with growing investor demand. Live as of 2026.",
          "loImpact": "For brokers working real estate investor clients, Rocket Pro TPO is now another DSCR channel option. Compare against Angel Oak (with their new Rental AVM), Pennymac (new in their Non-QM suite), and dedicated DSCR shops on pricing and DSCR ratio requirements. Strong-credit investors with documented rental property cash flow can shop the Rocket Pro option.",
          "categories": ["non-qm", "dscr", "rocket-pro", "investor", "rental-property", "wholesale-tpo"],
          "links": {
            "rocketDscr": "https://nationalmortgageprofessional.com/news/rocket-pro-launches-dscr-product-investor-demand-surges"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Wholesale TPO Product — Carrington Non-QM Updates",
          "topic": "Carrington Wholesale — Non-QM Underwriting Guideline Updates",
          "headline": "Carrington Wholesale updated Non-QM underwriting guidelines (clarifications and expansions, May 7, 2026)",
          "previousGuideline": "Carrington's Non-QM underwriting guidelines were on a prior version; some scenarios had ambiguous documentation expectations or eligibility criteria.",
          "newGuideline": "Carrington Wholesale updated Non-QM underwriting guidelines on May 7, 2026. Updates are clarifications or expansions and may be implemented immediately for loans in process that are not yet locked. Loans already locked or with approved exceptions continue under the guidelines in effect at the time of lock/approved exception.",
          "loImpact": "If you have a Carrington Non-QM file in process and not yet locked, the new guideline clarifications/expansions apply. Review the updated guideline package before submitting to ensure documentation matches the new expectations — Carrington's Non-QM is widely used for self-employed and bank statement files. Files already locked: continue under prior guidelines.",
          "categories": ["non-qm", "carrington", "wholesale-tpo", "underwriting", "self-employed"],
          "links": {
            "carringtonAnnouncement": "https://www.carringtonwholesale.com/2026/05/07/non-qm-underwriting-guideline-updates/"
          }
        },
        {
          "agency": "Fannie Mae",
          "section": "Wholesale TPO Product — Angel Oak Rental AVM",
          "topic": "Angel Oak Launches Rental AVM for DSCR Loans (Industry First)",
          "headline": "Angel Oak Mortgage Solutions integrated Clear Capital Rental AVM into DSCR loan pre-qualification (Nov 2025)",
          "previousGuideline": "Angel Oak's DSCR product required separate rental income documentation (lease agreements, market rent analysis from appraiser) to validate property's expected rental cash flow for qualification.",
          "newGuideline": "Angel Oak integrated Clear Capital's Rental AVM (Automated Valuation Model for rental income) directly into the DSCR pre-qualification flow. Once a pre-qualification is submitted and meets credit requirements, Angel Oak's system instantly generates a rental AVM figure for the property, which is then locked in for the loan term, barring significant changes. First-in-industry instant rental income estimation for DSCR.",
          "loImpact": "Speeds up Angel Oak DSCR pre-quals dramatically — no waiting on market rent analysis. Useful for real estate investor clients shopping properties quickly. The locked-in rental AVM figure means the qualifying number is known upfront, before you commit appraisal dollars. Strong play for new-investor clients who don't want to chase rent comps.",
          "categories": ["non-qm", "dscr", "angel-oak", "rental-avm", "investor", "wholesale-tpo", "automation"],
          "links": {
            "angelOakAnnouncement": "https://www.businesswire.com/news/home/20251104217699/en/Angel-Oak-Mortgage-Solutions-Launches-Industry-First-Rental-AVM-for-DSCR-Loans"
          }
        }
      ],
      "talkingPoints": [
        "UWM and Rocket Pro are LIVE on VantageScore 4.0. Pull dual-score on borderline files.",
        "Pennymac TPO now has full Non-QM suite (DSCR, bank statement, asset-based, full-doc nontraditional). One-stop shop.",
        "Angel Oak's Rental AVM = instant DSCR pre-qual. No waiting on market rent analysis.",
        "Carrington Non-QM guideline updates (May 7) apply to unlocked files in process.",
        "Rocket Pro DSCR is live — third channel option for investor clients."
      ]
    },
    {
      "id": "arc-home-2026-05-21-fnma-fhlmc-update",
      "date": "2026-05-21",
      "source": "Arc Home",
      "sourceUrl": "https://www.archome.com",
      "sourceArchive": "~/Documents/HLE-Lender-Source-Archive/agency-bulletins/2026-05/2026-05-21-arc-home-fnma-fhlmc-update.pdf",
      "kind": "agency-guideline-update",
      "title": "Fannie Mae & Freddie Mac Guidelines Update",
      "effective": "immediate",
      "scope": ["Fannie Mae", "Freddie Mac"],
      "loSummary": "Five guideline changes. One opens up qualifying with pending IRS installment agreements (FNMA). One unlocks Freddie Mac qualifying for hourly workers starting a new job (used to be salaried-only). Three are tighter documentation rules around property tax exemptions, paystub timing, and ACE eligibility with property disclosure statements.",
      "changes": [
        {
          "agency": "Fannie Mae",
          "section": "Selling Guide B3-6-05",
          "topic": "IRS Tax Installment Agreements",
          "headline": "Pending IRS installment agreements now qualify (previously approved-only)",
          "previousGuideline": "Lender may include monthly IRS installment payment as debt obligation if (a) no Notice of Federal Tax Lien filed in subject property county AND (b) lender obtains approved IRS installment agreement + evidence borrower is current AND (c) at least one payment made prior to closing.",
          "newGuideline": "Splits into TWO scenarios. For APPROVED installment agreements: copy of approved agreement (monthly payment + total due) + evidence borrower is current (most recent IRS payment reminder). For PENDING installment agreements: copy of the application for the agreement, with terms of repayment, monthly payment amount, and total amount due. In both cases, if borrower not paying off in full, lender must include monthly payment as part of monthly debt obligations. If any condition not met, balance must be paid off per B3-6-07.",
          "loImpact": "Borrowers who have just applied for an IRS installment plan but haven't yet been approved can now qualify. Previously this was a hard stop until IRS processed the agreement (often 30-90 days). Helpful for tax-stressed buyers in time-sensitive deals.",
          "categories": ["credit", "debt-obligations", "qualifying-income", "self-employed"],
          "links": {
            "fnmaSellingGuide": "https://selling-guide.fanniemae.com/sel/b3-6-05/monthly-debt-obligations"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 5401.1",
          "topic": "Property Tax Abatements and Exemptions",
          "headline": "Cleaner documentation rules for reducing or excluding tax escrow",
          "previousGuideline": "For primary residence: tax abatement/exemption real estate tax amount may be reduced or excluded from monthly housing expense, IF file contains evidence of continuance for at least 5 years after Note Date and either (a) the tax abatement for a reduced real estate tax amount, OR (b) the exemption for an excluded real estate tax amount. Age/disability exemption: 5-year continuance verification not required, but exemption must not have predetermined expiration date within 5 years.",
          "newGuideline": "Same intent, but explicit requirements: (1) Tax ABATEMENTS — must include evidence supporting reduced tax amount + evidence of continuance ≥5 years after Note Date + if Borrower not currently receiving the abatement, evidence that Borrower and/or property is eligible. (2) Tax EXEMPTIONS — same trio of requirements; age/disability exception preserved (5-year continuance not required PROVIDED exemption does not have predetermined expiration date within 5 years of Note Date), plus new requirement to verify Borrower/property eligibility if not currently receiving the exemption.",
          "loImpact": "Senior homestead-exemption borrowers still qualify cleanly. For other tax-reduction scenarios (veteran exemption, ag/timber, historic district), the eligibility verification step is now explicit — file owner needs to gather proof of qualification, not just continuance. Slightly more documentation up front; cleaner underwriting downstream.",
          "categories": ["property-tax", "dti-calculation", "primary-residence"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/5401.1"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 5302.2",
          "topic": "Year-to-Date Paystub as Eligible 10-Day Pre-Closing Verification (PCV) Type",
          "headline": "Paystub must now be DATED within 15 business days — not just 'paid through'",
          "previousGuideline": "YTD paystub must: be from pay period immediately preceding Note Date, AND have a 'paid through date' no more than 15 Business Days before Note Date.",
          "newGuideline": "YTD paystub must: be from pay period immediately preceding Note Date, AND be DATED no more than 15 Business Days before Note Date. (Strikes 'has a paid through date'.)",
          "loImpact": "Subtle but real. Employers who issue paystubs late (a week+ after the pay period closes) used to satisfy the 'paid through' rule. Under the new rule, the actual issue date of the paystub is what counts. If your borrower's employer is slow on paystub generation, you may need a fresh one closer to closing. Check the date stamp, not the pay-period end.",
          "categories": ["employment-verification", "paystub", "pre-closing", "documentation-timing"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/5302.2"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 5602.3",
          "topic": "ACE (Automated Collateral Evaluation) — Property Disclosure Statements",
          "headline": "ACE eligibility now reviewed against Property Disclosure Statements (TDS) — C5/C6 conditions in TDS = no ACE",
          "previousGuideline": "Sellers may not accept ACE offer if (a) appraisal required by law/regulation, (b) ADU rental income on 1-unit primary, (c) Seller is aware (based on review of sales contract, property inspection, disclosure by Borrower, OR appraisal report) of adverse physical property deficiency that warrants a PDR or appraisal. Examples: contaminated site/hazardous substance; property deficiency consistent with C5/C6 condition rating.",
          "newGuideline": "Adds 'property disclosure statement' to the list of documents Seller must review for adverse property deficiency. For PURCHASE TRANSACTIONS specifically: Seller must review the sales contract AND, if provided, the property disclosure statement, for adverse physical property deficiencies. Examples preserved: contaminated site, C5/C6 conditions (active roof leak, damaged/failing foundation).",
          "loImpact": "California-specific big deal. The TDS (Transfer Disclosure Statement) is now formally part of the ACE eligibility chain. If the TDS reveals an adverse condition that warrants a PDR or appraisal (C5/C6 condition rating, contamination, etc.), the Seller cannot accept ACE — a traditional appraisal is required. Read the TDS BEFORE you ACE-offer the file. Better to know up front than have ACE pulled mid-process.",
          "categories": ["appraisal", "ACE", "TDS", "purchase", "california", "property-condition"],
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/5602.3"
          }
        },
        {
          "agency": "Freddie Mac",
          "section": "Selling Guide 5303.2",
          "topic": "Employment Commencing After the Note Date — Option One — Eligible Employment & Income",
          "headline": "BIG: hourly workers can now qualify for post-Note-Date employment (was salaried-only)",
          "previousGuideline": "For borrowers starting new employment OR receiving a future salary increase from current primary employer, income may be considered stable IF: income is from new primary employment OR a future SALARY increase with the current primary employer; income is non-fluctuating and salaried (e.g., HOURLY earnings are NOT permitted); employer is not a family member or interested party.",
          "newGuideline": "Hourly is now PERMITTED. Income must be from new primary employment OR a future INCOME increase (was 'salary' increase) with the current primary employer. Income must be non-fluctuating and salaried OR hourly. Hourly earnings from a NEW employer may only be used to qualify when there is a GUARANTEED MINIMUM number of weekly hours. Hourly earnings from the CURRENT employer with a future pay-rate increase may only be used when documentation demonstrates current and future hours do NOT fluctuate. Employer still must not be family/interested party.",
          "loImpact": "Major opens-up. Nurses, healthcare workers, hospitality, retail managers, skilled trades — anyone hourly transitioning to a new gig — can now qualify for Freddie Mac with a future-employment-start offer letter, provided the offer guarantees a minimum number of weekly hours. Get the guaranteed-minimum-hours clause into the offer letter at the negotiation stage. This is the most impactful change in the bulletin for borrower-volume purposes.",
          "categories": ["employment-future", "hourly-income", "offer-letter", "income-qualifying"],
          "documentationUpdate": "Selling Guide 5303.2 also updates required documentation: offer letter must include employment start date, guaranteed minimum weekly hours (if applicable), and annual income based on non-fluctuating earnings. For current-employer future increase: documentation must show increase is fully approved and explicitly granted to Borrower. 10-day pre-closing verification (PCV) still required to confirm offer terms have not changed.",
          "links": {
            "fhlmcSellingGuide": "https://guide.freddiemac.com/app/guide/section/5303.2"
          }
        }
      ],
      "talkingPoints": [
        "Tax-stressed borrowers: FNMA now lets you qualify with a pending IRS installment plan (just need the application docs).",
        "Hourly workers changing jobs: Freddie now qualifies you on the new offer, but get a guaranteed-minimum-hours clause in the letter.",
        "CA purchase files: read the TDS BEFORE you ACE-offer — C5/C6 conditions kill ACE eligibility.",
        "Paystub timing: the 15-day rule now uses the paystub's issue date, not the pay-through date. Don't get caught by a stale paystub at closing.",
        "Senior tax-exempt borrowers: still in good shape, but document eligibility (not just continuance)."
      ]
    }
  ]
}