The Signal / Policy / October 22, 2026
Fannie Mae’s “Super Intelligence” rule and the other GSE changes that matter to appraisers
Fannie Mae’s updated security supplement now calls artificial intelligence “Super Intelligence,” and Fannie says the new name changes nothing. In the same seven weeks the GSEs opened a UAD 3.6 exception with a price attached, Fannie moved its rental income deadline to December 1 and added appraisal checks to Desktop Underwriter, and Freddie widened desktop valuations. This is what changed, from the documents, as of October 22, 2026.
Seven weeks in four numbers
- GSE documents on the board
- 10
- Days between the two AI rules
- 321
- CU score, UAD 2.6, from Mar. 1, 2027
- 999
- Days to the UAD 3.6 mandate
- 11
Ten documents in seven weeks
Fannie Mae and Freddie Mac changed AI governance, UAD 3.6 timing, rental income and appraisal screening this fall
Between September 2 and October 21, Fannie Mae, Freddie Mac or both issued the ten documents below that touch appraisal, valuation or the lenders and AMCs who order appraisals. We found no FHFA directive or advisory bulletin on appraisal or AI dated in the window; the September 30 UAD 3.6 exception was the one joint action. Each row links to the chapter that explains it.
| Date | Issuer | Document | Status |
|---|---|---|---|
| Sept. 2 (upd. Sept. 23) | Fannie Mae | SEL-2026-08: rental income, STR income, HBU | Mandatory Dec. 1 |
| Sept. 2 | Freddie Mac | Bulletin 2026-12: income docs, relocated manufactured homes | Issued |
| Sept. 25 | Fannie Mae | DU 12.1: overvaluation flag, No Longer Accepted, C6 | Live |
| Sept. 30 | Both GSEs | UAD 3.6 policy exception (LL-2026-08) | Requests open |
| Oct. 1 | Fannie Mae | VantageScore 4.0 in DU (LL-2026-06) | Live |
| Oct. 7 | Fannie Mae | SEL-2026-09: verbal VOE, K-1, attorney opinion letters | Mandatory Dec. 2 |
| Oct. 7 | Freddie Mac | Bulletin 2026-13: ACE for investment refinances | Issued |
| Oct. 14 | Freddie Mac | Bulletin 2026-14: servicing updates | Issued |
| Oct. 14 (upd. Oct. 21) | Fannie Mae | DU updates scheduled Nov. 13, Nov. 30, Dec. 11 | Scheduled |
| Oct. 20 or 21 | Fannie Mae | Security Supplement: "Super Intelligence (SI)" | Mandatory Jan. 18, 2027 |
A new name for the same rules
Fannie Mae’s security supplement now calls AI “Super Intelligence,” and says the rename changes nothing
Fannie Mae published a new edition of its Information Security and Business Resiliency Supplement on Oct. 20 or 21, 2026; its own page metadata says October 20, and the superseded notice on Lender Letter LL-2026-04 says October 21. Supplement Bulletin 26-01 sets the effective date at January 18, 2027, “90 Days from publication.” The edition adds a Section 4 titled “4. Super Intelligence (SI)” and defines the term as tools “able to perform tasks normally requiring human intelligence,” the ordinary definition of AI.
Fannie explains the name in a footnote and repeats it in the supplement’s FAQ.
“The term ‘Super Intelligence’ is used in place of ‘Artificial Intelligence’ to align with evolving industry terminology. This terminology update is not intended to alter the scope, meaning, or applicability of the requirements.”Information Security and Business Resiliency Supplement, footnote 1, p. 6
Section 4 replaces Lender Letter LL-2026-04, Fannie’s April 8, 2026 AI and machine learning governance letter. LL-2026-04 now carries the notice “This Lender Letter has been superseded by the Fannie Mae Information Security and Business Resiliency Supplement, published on October 21, 2026.” Fannie issued a parallel multifamily letter, LL-2026-05, on July 7, 2026. Read side by side, the old letter and the new section carry the same duties, with “AI/ML” swapped for “SI,” “subcontractor and vendor” swapped for “third party,” and one new clause on security risks.
- Governance programA documented, formal SI governance programp. 19
- InventoryAn inventory of SI use cases, their purpose and scopep. 19
- Risk assessmentProcesses to identify risks, errors or negative impactsp. 19
- Data governanceRetention, classification and quality standardsp. 20
- Model lifecycleDesign, training, testing and validationp. 20
- Monitoring and retirementPost-deployment monitoring and retirementp. 20
- Security risksIncluding prompt injection and model inversionp. 20
- Third partiesGovernance of third-party SI use, no less protectivep. 20
- Disclosure on requestTypes, purpose and safeguards, when Fannie asksp. 20
The same edition changes other security terms. It adds a requirement to “maintain an insurance policy appropriate to the Company’s assessment of its risk of loss associated with a cybersecurity incident,” names NIST 800-53 as an example standard, replaces “vendor” with “third party,” and moves the annual security assessment from a “qualified independent auditor” to an “independent third-party security professional.” We found no trade press or law firm commentary on this edition as of October 22; it was one or two days old.
Sources: Supplement PDF ↗ Fannie Mae Supplement page and FAQ ↗ Bulletin 26-01 ↗ LL-2026-04 ↗ LL-2026-05 ↗
Named, and not named
The rule binds lenders by name and reaches AMCs and valuation vendors through their contracts
The supplement applies to a “Company,” which it defines as the entity named in its agreements with Fannie, “including SF Lenders, MF Lenders, document custodians and integrators (also referred to as third-party solution providers).” Appraisers and AMCs are not on that list, and Section 4 does not mention them.
Fannie Mae
Writes the supplement and can ask any Company to disclose its SI use.
Companies
Lenders, document custodians and integrators that sign agreements with Fannie.
Named in the definition
Third parties
AMCs, valuation and AVM vendors, review tools: anyone working on a Company’s Fannie business.
Covered by Section 3.14, not named
Appraisers
Reached through client contracts, and separately bound by USPAP, including Advisory Opinion 41 on technology.
Separate rulebook: USPAP
The flow-down clause
Section 3.14 makes each Company answer for its third parties.
“Company shall cause its third parties involved with Company’s activities under the applicable Underlying Agreements to comply with the Supplement including the implementation of information security, Super Intelligence and resiliency controls that meet or exceed those set forth in this Supplement. Company is responsible for all failures by such a third party to comply with this Supplement to the same extent as if such failure were committed by the Company.”Supplement, Section 3.14, p. 18
A lender that uses an AMC or an AI-enabled valuation tool on Fannie loans will need that vendor’s AI use to meet Section 4. Expect vendor questionnaires, audit rights and AI-use disclosure terms in lender contracts with AMCs and valuation vendors before January 18, 2027. That follows from Section 3.14; the supplement does not say it in those words.
Appraisers already have their own rule on tools. Advisory Opinion 41, which the Appraisal Standards Board adopted on April 23, 2026, addresses the use of technology in appraisal and appraisal review. Its exposure draft stated that if an appraiser relies on a tool’s output without their own analysis, “the work does not comply with USPAP.” Our Jevons Paradox feature covers how cheaper analysis tools are changing appraisal demand.
Freddie Mac went first
Freddie Mac’s AI rule has applied since March 3, 2026, and Fannie Mae’s applies from January 18, 2027
Freddie Mac added AI and machine learning governance to Guide Sections 1302.2 and 1302.8 in Bulletin 2025-16, issued Dec. 3, 2025, effective March 3, 2026. The bulletin describes “a comprehensive governance framework for the responsible development, deployment and oversight of artificial intelligence (AI) and machine learning (ML) systems.” Freddie made no change to it in the window. Lenders that sell to both GSEs have been under Freddie’s rule for 233 days and will add Fannie’s on January 18.
2026
Freddie MacSection 1302.8
321days between the two effective dates
2027
Fannie MaeSupplement Section 4
The mandate stands, with a paid detour
Lenders can keep filing UAD 2.6 reports into 2027, and from March 1 those reports lose their value relief
On September 30, Fannie Mae and Freddie Mac announced a one-time policy exception to the UAD 3.6 mandate, which still takes effect for new submissions on November 2, 2026. Approved sellers who request it can submit new UAD 2.6 reports through May 19, 2027, and resubmit earlier ones through June 27, 2027. The announcement calls it “a one-time policy exception that will not be extended.” Only sellers that deliver to the GSEs request it; lenders that don’t sell directly “must align with their investors on their implementation plans.”
From March 1, 2027, every UAD 2.6 report draws a collateral risk score of 999 in Fannie’s Collateral Underwriter and 99 in Freddie’s Loan Collateral Advisor, and the loan loses representation and warranty relief on value. Fannie’s letter says such loans “will not be eligible for enforcement relief for breaches of certain representations and warranties related to the appraisal and value of the subject property.” Drag the slider to see what happens to a UAD 2.6 report on a given day.
UAD 2.6 under the policy exception
Four phases, Nov. 2, 2026 to June 28, 2027
- Exception, normal processingNov. 2, 2026 to Feb. 28, 2027
New UAD 2.6 reports accepted
- Reduced Functionality PeriodMar. 1 to May 19, 2027
New UAD 2.6 reports accepted
- Resubmissions onlyMay 20 to June 27, 2027
Only resubmissions of earlier UAD 2.6 reports; new ones get fatal edits
- UAD 2.6 retiredFrom June 28, 2027
No UAD 2.6 reports processed
In a CSS survey of 863 appraisers in August, reported by NAR on September 29, 49.7% said they were ready to go and 25.3% said they were in progress. At an October 7 webinar with Fannie Mae, Clear Capital reported early numbers from its own orders.
- NAR, CSS survey75%of appraisers ready or in progress
- Vendor data+$65average fee per UAD 3.6 report, in markets with enough volume
- Vendor data28%faster report completion as appraisers learn the format
- Vendor data99%of Clear Capital’s active panel eligible for UAD 3.6
- Vendor data3%of UAD 3.6 orders converted back to UAD 2.6
The exception gives lenders and appraisers “additional time to prepare for this significant change.”Bob Broeksmit, MBA, via HousingWire, Sept. 30, 2026
NAR’s Washington Report “announced an effective delay to the November 2 mandate.”NAR Washington Report, Sept. 30, 2026
Sources: Joint GSE announcement ↗ LL-2026-08 ↗ HousingWire ↗ NAR Washington Report ↗ NAR on the CSS survey ↗ National Mortgage Professional on the webinar ↗ ABA Banking Journal ↗. Our exception window explainer covers lender timing in more detail.
From November 2, a report on a new GSE loan uses UAD 3.6 unless the lender holds an exception.
AI-generated illustration.
One month later
Fannie Mae moved its new rental income rules to applications dated December 1
Mandatory date, rental income topicsReissued Sept. 23, 2026. Applications dated on and after Dec. 1, 2026.
Fannie reissued Selling Guide Announcement SEL-2026-08 on September 23 “to revise the required implementation date for rental income policy changes from Nov. 1, 2026 to Dec. 1, 2026.” Lenders may adopt the changes now. The announcement splits rental income into six topics, including a new short-term rental topic and a new topic for investment properties bought within 45 days of the subject.
- B3-3.8-01General Rental Income Information
- B3-3.8-02Rental Income from the Subject Property
- B3-3.8-03Subject Property: Short-Term Rental
- B3-3.8-04Rental Income from Non-Subject Property
- B3-3.8-05Non-Subject Property: Departing Residence
- B3-3.8-06Investment Properties Purchased within 45 Days of the Subject Property (new)
The short-term rental topic counts 50% of gross rent and lets a positive result offset only the property’s own payment; our STR valuation feature covers it and what it asks of appraisers. The same announcement changed highest and best use reporting for UAD 3.6 reports, effective immediately, which our highest and best use explainer covers. It also lets lenders under Fannie’s Native American lending initiative order appraisals “based solely on the cost approach when insufficient market data exists to develop a reliable opinion of value using the sales comparison approach.”
A second announcement, SEL-2026-09 on October 7, changed verbal employment verification and attorney opinion letters. Its Schedule K-1 verbal verification change applies to applications dated on or after December 2, 2026. None of it changes appraisal requirements.
Sources: SEL-2026-08, updated Sept. 23, 2026 ↗ SEL-2026-09 ↗
Automated review
Desktop Underwriter now flags overvaluation and rejects loans over the appraiser list and C6 ratings
Fannie’s DU Version 12.1 notes, published July 29 and updated August 31, scheduled appraisal checks that took effect the evening of September 25. Two of them return an Ineligible recommendation outright. The panel below lists the four, paraphrased; it illustrates the messages and does not reproduce DU output.
Findings, illustrative
- DCM-01Collateral Underwriter has indicated a heightened risk of overvaluation on the appraisal.
- IneligibleAppraiser or supervisory appraiser is on the No Longer Accepted list; a new appraisal is needed.
- IneligibleThe appraisal reports a C6 condition rating.
- ConfirmSubject zip code is in Lava Zone 1 or 2; confirm the designation or postal code.
An October 14 integration memo, updated October 21, schedules more DU 12.1 updates for the evenings of November 13, November 30 and December 11. Fannie made VantageScore 4.0 available in DU on October 1 under LL-2026-06.
- DU update Nov. 13, 2026
- DU update Nov. 30, 2026
- DU update Dec. 11, 2026
Sources: DU Version 12.1 release notes ↗ DU integration memo, Nov. and Dec. 2026 ↗ LL-2026-06 ↗
Where the GSEs part ways
Freddie Mac opened desktop valuations to investment refinances and has not matched Fannie’s rental income rules
Freddie issued three Guide bulletins in the window. The one with the most appraisal effect is Bulletin 2026-13, dated October 7, which makes refinances of investment properties eligible for ACE, its automated collateral evaluation, and ACE+ PDR, which pairs ACE with a property data report. The bulletin sets maximums of 75% loan-to-value for no cash-out refinances and 60% for cash-out refinances. More investment property refinances can now close without a full appraisal.
Bulletin 2026-12 · Sept. 2
Selling updates
- Income documentation changes
- Manufactured homes moved from another site become eligible, with an engineer’s inspection
Bulletin 2026-13 · Oct. 7
Selling updates
- ACE and ACE+ PDR for investment refinances
- GreenCHOICE retired into CHOICEReno eXPress
- Multi-wide manufactured homes allowed for community land trusts
- Condo flood coverage when commercial space exceeds 25%
Bulletin 2026-14 · Oct. 14
Servicing updates
- Servicing side of the GreenCHOICE retirement
- The same condo flood insurance provision
| Topic | Fannie Mae | Freddie Mac |
|---|---|---|
| AI governance | Supplement Section 4, mandatory Jan. 18, 2027 | Section 1302.8, in force since Mar. 3, 2026 |
| Short-term rental income | B3-3.8-03, mandatory Dec. 1, 2026 | No matching change found |
| UAD 3.6 exception | Joint terms; CU score 999 from Mar. 1, 2027 | Joint terms; LCA score 99 from Mar. 1, 2027 |
| Desktop valuations | No change found in the window | ACE and ACE+ PDR open to investment refinances |
Sources: Freddie Mac Guide Bulletins 2026-12 ↗ 2026-13 ↗ 2026-14 ↗ 2025-16 ↗ (copies hosted by Tenaco; Freddie’s Guide site requires a login).
By role
What appraisers, AMCs and lenders can do before each date
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- 11days to Nov. 2, 2026
UAD 3.6 mandate
- 40days to Dec. 1, 2026
Rental income rules mandatory
- 88days to Jan. 18, 2027
Supplement, including SI
- 130days to Mar. 1, 2027
UAD 2.6 reduced functionality
- 209days to May 19, 2027
Last new UAD 2.6 reports
AI-generated illustration.
This article draws on Fannie Mae and Freddie Mac guide documents, lender letters, bulletins and release notes, checked October 22, 2026, plus trade press and NAR reporting. Implications for AMCs and appraisers in chapter 03 are our reading of Section 3.14, labeled as such. Clear Capital figures are vendor data. Images and video are AI-generated and show no real company, document or property. This article is general information, not legal or compliance advice.
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