As two of the largest participants in the lending market, Fannie Mae and Freddie Mac (the "GSEs") are busy preparing for the transition away from LIBOR. Both GSEs have established milestones for beginning acquisition and issuance of SOFR-indexed products and ceasing LIBOR-indexed products. Below are reminders of important deadlines:

Single-Family ("SF") ARMs and Securities:

August 3, 2020 Fannie Mae began accepting delivery of SOFR-indexed ARMs.
September 30, 2020 LIBOR applications end. All LIBOR loans must have Application Received Date on or before this date.
November 16, 2020 Freddie Mac will begin accepting delivery of SOFR-indexed ARMs.
December 1, 2020 This the last MBS/Guarantor PC issue date for LIBOR-indexed ARM pools.
December 31, 2020 This is the last date for cash/whole loan purchase of LIBOR-indexed ARMs.

Single-Family Credit Risk Transfer ("SF CRT") transactions:

Q4 2020 Freddie Mac will be operationally prepared to begin issuing SOFR-indexed SF CRT transactions, with actual execution based on market readiness.
By the end of Q4 2020 Both GSEs will discontinue issuance of LIBOR-indexed SF CRT deals.
Q1 2021 Fannie Mae will be operationally prepared to begin issuing SOFR-indexed SF CRT transactions, with actual execution based on market readiness.

Collateralized Mortgage Obligations ("CMOs"):

July 2020 GSEs started offering SOFR-indexed CMOs for settlement.
October 2020 Freddie Mac and Fannie Mae will cease offering new LIBOR-indexed CMOs for issuance. The GSEs will continue to issue new resecuritizations of LIBOR-indexed CMOs (also known as "ReREMICs"), provided that such resecuritizations do not increase the total unpaid principal balance of the LIBOR- indexed CMOs outstanding.

Fannie Mae Multifamily ARMs and MBS:

By Q4 2020

Fannie Mae Multifamily will release a SOFR-indexed capped ARM product and begin offering SOFR-indexed Structured ARMs, 7/6 ARMs and Hybrid ARMs.

System capabilities will be in place for lenders to deliver SOFR-indexed ARMs with an embedded cap and SOFR- indexed uncapped ARMs.

Investors will be able to invest in Fannie Mae issued MBS based on a capped SOFR-indexed ARM.
October 1, 2020 Applications for LIBOR-indexed ARMs will no longer be accepted.
January 1, 2021 Fannie Mae Multifamily will no longer purchase LIBOR-indexed ARMs (i.e., must be purchased on or before December 31, 2020 as a Cash Mortgage Loan or MBS Mortgage Loan with an Issue Date on or before December 1, 2020)
2021 Legacy LIBOR-indexed ARM products will be converted to an alternative reference rate at Fannie Mae Multifamily's discretion upon LIBOR no longer being available.

Freddie Mac Multifamily ("MF") Floating Rate Loans and Securities

September 1, 2020 Freddie Mac will no longer issue quotes for LIBOR-indexed loans; all new floating-rate quotes will be for SOFR-indexed loans. For SBL, Optigo® lenders will no longer issue applications for SBL hybrid loans with a floating-rate period indexed to LIBOR; all new hybrid loan applications issued will be SOFR-based.
September 30, 2020 This is the last day for LIBOR-indexed floating-rate and hybrid loans to go under application.
November 9, 2020 This is the last day for submission of underwriting package for LIBOR-indexed floating-rate and hybrid loans to Freddie Mac.
December 11, 2020 This is the last day for submission of final delivery package for LIBOR-indexed floating-rate and hybrid loans to Freddie Mac.
December 31, 2020 This is the last day for Freddie Mac to purchase LIBOR-indexed floating-rate and hybrid loans, regardless of the loan application or the date of the note.

Fannie Mae Multifamily Credit Risk Transfer ("MF CRT") transactions

By end of Q4 2020 Issuance of LIBOR-indexed MF CRTs will be discontinued.
Q1 2021 Fannie Mae will be operationally prepared to begin issuing SOFR-indexed MF CRT transactions, with actual execution based on market readiness.

Freddie Mac MF CRT transactions

Q4 2020 Freddie Mac will be operationally prepared to begin issuing SOFR-indexed MF CRT transactions, with actual execution based on market readiness.

Duane Morris' LIBOR Transition Team: Roger S. Chari, Chair, Joel N. Ephross, Amelia (Amy) H. Huskins, Phuong (Michelle) Ngo, and Han Wang.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.