# Freddie Mac vs Fannie Mae QC requirements

Updated September 26, 2026

Both agencies require a written QC program, prefunding and post-closing reviews, a 10% random sample and self-reporting of ineligible loans within 30 days. The differences are in the base and the clocks: Fannie measures the 10% monthly, Freddie annually, and only Freddie defines a monthly early-payment-default sample.

## Key numbers

- **10%** random sample: of monthly production at Fannie, of annual production at Freddie (D1-3-01; 3402.2(a)(i))
- **30 days** to self-report an ineligible loan at both agencies, counted from different dates (D1-1-01; 3402.3(b)(ii))
- **60+ days** past due in the first six months after the Note Date: Freddie's monthly targeted sample (3402.2(a)(ii))

## Requirements at a glance

| Requirement | Fannie Mae | Freddie Mac |
|---|---|---|
| Prefunding / preclosing | Written prefunding plan, monthly selection, each production channel. The lender sets the size (D1-2-01) | Required on "a sampling" of loans. No size set (3402.1(a), 3402.2(e)) |
| Random sample base | At least 10% of monthly production (minimum one loan) (D1-3-01) | At least 10% of annual total, secondary-market or Freddie Mac production (3402.2(a)(i)) |
| Statistical option | Any lender: 95% confidence, 2% precision, six-month statistical statement (D1-3-01) | Only sellers above 5,000 loans a year: 95% confidence, margin of error of 2% or less, annual basis (3402.2(a)(i)) |
| Selection timing | At least monthly (D1-3-01) | Every loan has a chance of selection within 90 days of the Note Date (3402.2(a)(i)) |
| Early payment defaults | Named as a high-risk target for discretionary selection. No definition (D1-3-01) | Monthly targeted sample of loans 60+ days past due in the first six months after the Note Date (3402.2(a)(ii)) |
| Completion deadline | Whole cycle within 90 days from the month of disbursement or acquisition (D1-3-01) | Results reported in writing to senior management within 90 days of selection (3402.3(b)(i)) |
| Self-reporting | Within 30 days of the date of confirmation, through Loan Quality Connect (D1-1-01) | Within 30 days of reporting to senior management. Named categories go through the Tip Referral Tool (3402.3(b)(ii)) |
| QC vendor oversight | Lender re-reviews at least 10% of the vendor's post-closing sample monthly (D1-1-02) | Lender monitors and evaluates the vendor "on a regular basis". No percentage (3402.1(b)) |
| Record retention | At least three years (D1-1-01) | At least three years from the date of review (3402.3(c)) |

## Sampling: same 10%, different base

Fannie's 10% is of monthly production and is reviewed as full files. Retail and third-party originations are sampled separately, unless you have 100 or fewer third-party loans a year (D1-3-01).

Freddie's 10% is of one of three annual populations you choose: total home mortgage production, total secondary-market production, or total Freddie Mac production. Any loan you leave out of selection is not eligible for sale to Freddie Mac. A statistical sample, available only above 5,000 loans a year, has to be based on the defect rates of loans your QC recently reviewed. You also warrant that over each 12-month period your samples represent every product line, state, branch and third-party originator, plus high-risk loans such as high-LTV, ARM and cash-out refinance loans (3402.2(a)(i)).

Freddie then requires two more samples (3402.2(a)(ii)–(iii)). The targeted sample is a monthly "appropriate risk-based sample" of Freddie loans 60 or more days past due in the first six months after the Note Date, each evaluated for fraud or other deficiencies. Discretionary samples must be pulled when fraud is suspected and should cover new branches, employees, third-party originators and products. Fannie's discretionary selections "supplement, but do not replace" the random sample and target early payment defaults among other high-risk loans, but with no size and no definition.

On timing, one thing the table leaves out: a Fannie lender more than one 30-day cycle behind must give Fannie written notice (D1-3-01).

## Reverification: where one file won't satisfy both

Both agencies reverify income and employment, assets, credit, property value and occupancy, and exempt data verified through their own validation tools. The mechanics differ:

- Tax transcripts. Fannie requires IRS transcripts when tax returns supported income, and pre-closing transcripts may be reused (D1-3-03). Freddie requires a Form 4506-C (or equivalent) request on each selected loan, covering all income used in qualifying, unless IRS information was received during origination or all qualifying income came from a Freddie-designated verification source (3402.2(b)(i)(B)).
- Credit. Fannie requires a new tri-merge report. Freddie requires no new report for Loan Product Advisor Accept loans, only a check that the borrower identity data was accurate. For other loans, one in ten needs a new RMCR or three-repository merged report and the rest a new in-file report (3402.2(b)(iii)).
- Social Security number. Freddie requires validation on post-closing loans, with limited exceptions (3402.2(b)(ii)).
- Appraisal. Fannie requires a collateral risk assessment. Freddie requires a desk review, escalating to a field review on Form 1032 or 1072 when the desk review is insufficient (3402.2(b)(v)).

## Severity and self-reporting

Fannie makes you define severity levels. The top one must be "not eligible as delivered," with a target defect rate measured at least quarterly and reviewed at least annually (D1-1-01). Chapter 3402 of the Freddie Guide sets no severity levels or target defect rate. It requires you to document discrepancies that affect eligibility, report results to senior management in writing, and start corrective action.

Both self-reporting windows are 30 days, counted from different dates. Fannie's "date of confirmation" is the date the monthly post-closing report that includes the loan is published to management. Freddie's clock starts when results are reported in writing to senior management, for findings that affect eligibility or relate to fraud. Findings in its listed categories, such as misrepresentation, borrower eligibility, property and appraisal, and loan terms, go through the Tip Referral Tool in Freddie Mac Gateway (3402.3(b)(ii)).

One wrinkle: Freddie's property valuation subsection separately refers to reporting "within 90 days or within 60 days of the finding if fraud or possible fraud is involved, consistent with Section 3402.3(b)." Where that and the 30-day rule give different dates, confirm the deadline with Freddie Mac.

## Independence and vendors

Fannie requires QC staff independent of production, underwriting and closing, or a plan that explains the offsetting controls (D1-1-02). Freddie requires independent post-closing QC but lets sellers producing fewer than 5,000 loans a year house it with origination and underwriting. It also has the seller act on a vendor's findings as if its own staff had made them.

The QC plan, the sampling and the reporting to each agency stay with the lender.

## A lender selling to both

The numbers here are illustrative. A lender closes 500 loans a month (6,000 a year) and uses the 10% method for both. For Fannie, that is 50 random loans a month, split between retail and third-party channels, and March closings finish their cycle within 90 days from March. For Freddie, it is at least 600 loans over the year, scheduled so every loan could be selected within 90 days of its Note Date. At 6,000 loans a year, the lender could adopt a statistical sample for Freddie instead. Each month it also pulls a risk-based sample of Freddie loans that went 60+ days past due within six months of the Note Date. If a vendor reviews the 50 Fannie random loans, the lender re-reviews at least 5 of them itself.

## FAQ

**Is the 10% random sample the same for Fannie Mae and Freddie Mac?**
No. Fannie's 10% applies to monthly production. Freddie's applies to annual production, measured against the population the seller chooses.

**Does Freddie Mac require early payment default reviews?**
Yes. Each month, a targeted sample of loans 60 or more days past due in the first six months after the Note Date.

**Does Freddie Mac require a fixed vendor re-review percentage?**
No. Freddie requires regular monitoring and evaluation of the vendor. Fannie requires the lender to re-review at least 10% of the vendor's post-closing sample each month.

## 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
- D1-3-03, 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
- Freddie Mac Single-Family Seller/Servicer Guide, Section 3402.1, Quality control program structure (effective 05/06/2026): https://guide.freddiemac.com/app/guide/section/3402.1
- Freddie Mac Single-Family Seller/Servicer Guide, Section 3402.2, Quality control processes (effective 09/02/2026): https://guide.freddiemac.com/app/guide/section/3402.2
- Freddie Mac Single-Family Seller/Servicer Guide, Section 3402.3, Documenting and reporting (effective 05/06/2026): https://guide.freddiemac.com/app/guide/section/3402.3

This guide summarizes agency requirements as of the date above. It is not legal advice.