# Fannie Mae post-closing QC requirements Updated September 26, 2026 Fannie Mae requires a random post-closing sample of at least 10% of monthly production, or a statistical sample at 95% confidence and 2% precision, plus discretionary selections on top. Every random-sample loan gets a full-file review with reverification, and the whole cycle must finish within 90 days from the month the loans disbursed. ## Key numbers - **10%** of monthly production at random, or a statistical sample at 95% confidence, 2% precision (D1-3-01) - **90 days** from the disbursement month to finish selection, review, rebuttal and reporting (D1-3-01) - **30 days** from the date of confirmation to self-report a loan ineligible as delivered (D1-1-01) ## Picking the sample You select at least monthly. For the random sample, D1-3-01 gives the lender two options. One is 10% of the loans you originate or acquire, chosen at random, and never fewer than one loan. The other is a statistical model built on, at a minimum, "a 95% confidence level with a 2% precision rate and a statistical statement of six months." The sample has to represent the whole book: every loan type, every branch, manually underwritten loans, and loans run through each automated underwriting system. Retail and third-party originations are sampled separately, stratified by channel. A lender with 100 or fewer third-party originations a year doesn't need a stratified third-party sample or separate reporting for it (D1-1-01). Discretionary selections come on top. They "supplement, but do not replace" the random sample, and they go after the areas you've identified as more likely to have errors and the loans at high risk of misrepresentation or fraud, including early payment defaults. The fraud section, A3-4-03, is blunter: sellers must "aggressively sample loans that have a high risk for fraud." There is no minimum discretionary count. You size it from your own risk assessment. Early payment defaults trip people up. The Guide names them as a discretionary target but doesn't define one, set a delinquency window, or set a minimum number to review. Those decisions belong in your QC plan and risk assessment. ## Reverifying the random sample For each loan in the random full-file sample, D1-3-03 requires you to reverify: - Income and employment, for every employer in the documentation period. A documented verbal reverification is acceptable. - Tax returns, when they supported income, through IRS transcripts (Form 4506-C or equivalent). Transcripts obtained before closing can be reused. - Assets: all funds used for the down payment, closing costs and reserves. - Credit: a new tri-merge report, or reverification of each nontraditional credit reference. - Property eligibility and value: a collateral risk assessment, or a desk or field review. - Occupancy: review the file documents, and dig further if there are red flags. Items validated by the DU validation service (when the enforcement-relief conditions are met) or verified directly through an approved Fannie Mae vendor are exempt. Document and track every failed reverification attempt. When a reverification contradicts what underwriting relied on, re-underwrite the loan. ## Rating defects Fannie doesn't hand you a severity scale. You define your own levels, with one fixed point: the top level is for loans not eligible as delivered to Fannie Mae. At a minimum, D1-1-01 requires a target defect rate for that level, set from the post-closing random sample and kept "as reasonably low as possible." Measure against it at least quarterly, report it to management, and review the target at least annually with the rationale documented. Keep defects of compliance with law separate from underwriting and eligibility defects in your post-closing reports. D1-1-03 requires the split. ## The 90-day clock Selection, review, rebuttal and reporting "must be completed within 90 days from the month of the disbursement date (loans they originate) or acquisition date (loans they acquire)." If you fall more than one 30-day cycle behind, give written notice to your Fannie Mae customer account team or QC Specialist (D1-3-01). ## Reporting inside the company Management reports are written and go out at least monthly. Under D1-1-03 each one carries its publication date, a description of each sample (criteria, number of loans reviewed, and percentage of eligible loans reviewed), summaries of random, discretionary and component reviews, third-party origination summaries, at least three months of defect trending, the highest-severity defect rate against its target at least quarterly, and, where applicable, the results of the 10% vendor review. Loan-level findings go to the business units responsible for fixing them. When the reviews show a trend, you need a written action plan with the expected resolution and a timeline. ## Self-reporting to Fannie Mae A loan found ineligible as delivered must be self-reported within 30 days of the "date of confirmation." That is the date the monthly post-closing report that includes the loan is published to management. File it through Loan Quality Connect with a summary and supporting documents (D1-1-01). Suspected misrepresentation or fraud runs on its own track: report it within 30 days once a reasonable basis exists (A3-4-03). ## Using a QC vendor You can outsource, but Fannie holds the lender "fully accountable," and a vendor contract "is not a substitute for the lender establishing and maintaining its own QC plan" (D1-1-02). The vendor works to your plan. Each month you re-review at least 10% of the vendor's post-closing sample yourself, including loans with defects and loans without, and that review "may not be contracted out." Report the results monthly, within 30 days of publication of the final QC management report, showing concurrence rates and discrepancies. QC staff also have to be independent of production, underwriting and closing, or the plan must explain the offsetting controls. The QC plan, the sampling and the reporting to Fannie Mae stay with the lender. ## What the written plan must cover D1-1-01 sets the minimum: quality standards, objectives, the risks being measured and how independence is ensured; operating procedures; the prefunding and post-closing file review processes; sample selection across all channels, products and underwriting methods; monthly reporting; corrective action; review of QC vendors; record retention for at least three years; and an independent audit of the QC process. ## One month, worked through The numbers here are illustrative. A lender closes 400 loans in March: 300 retail and 100 acquired from third-party originators. On the 10% method, the random sample is 30 retail and 10 third-party loans, so 40 full-file reviews with reverification. The discretionary sample is the lender's call, for example early payment defaults and high-risk loans flagged by its fraud tools. The Guide sets no number. If a vendor reviews all 40 random loans, the lender re-reviews at least 4 of them itself, some with defects and some without. Say the March post-closing report is published to management on June 15 and shows one loan ineligible as delivered. The self-report through Loan Quality Connect is due by July 15. ## FAQ **What is Fannie Mae's minimum post-closing QC sample?** At least 10% of monthly production chosen at random, or a statistical sample at 95% confidence and 2% precision. Discretionary selections are required in addition. **When does the 30-day self-reporting clock start?** On the date of confirmation, which is when the monthly post-closing report that includes the ineligible loan is published to management. **Does Fannie Mae define an early payment default for QC?** No. It names early payment defaults as a discretionary target but leaves the definition, the delinquency window and the review count to the lender's QC plan. ## Sources - Fannie Mae Selling Guide (published September 2, 2026): https://selling-guide.fanniemae.com/ - D1-1-01, Lender Quality Control Programs, Plans, and Processes (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-1-01/lender-quality-control-programs-plans-and-processes - D1-1-02, Lender Quality Control Staffing and Outsourcing of the Quality Control Process (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-1-02/lender-quality-control-staffing-and-outsourcing-quality-control-process - D1-1-03, Lender Quality Control Reporting (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-1-03/lender-quality-control-reporting - D1-2-01, Lender Prefunding Quality Control Review Process (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-2-01/lender-prefunding-quality-control-review-process - D1-3-01, Lender Post-Closing Quality Control Review Process (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-3-01/lender-post-closing-quality-control-review-process - D1-3-02, Lender Post-Closing Quality Control Review of Approval Conditions, Underwriting Decisions, Data, and Documentation (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-3-02/lender-post-closing-quality-control-review-approval-conditions-underwriting-decisions-and - D1-3-03, Lender Post-Closing Quality Control Reverifications (04/01/2026): https://selling-guide.fanniemae.com/sel/d1-3-03/lender-post-closing-quality-control-review-data-integrity - A3-4-03, Preventing, Detecting, and Reporting Mortgage Fraud (12/10/2025): https://selling-guide.fanniemae.com/sel/a3-4-03/preventing-detecting-and-reporting-mortgage-fraud This guide summarizes agency requirements as of the date above. It is not legal advice.