Fannie Mae DUS | 2026-11-03

Fannie Mae Final Policies Need a Recording-Date Bridge

Form 4650 links funding-date coverage, simultaneous recordation where required, later-dating through the assignment, and a 60-day final-policy delivery clock.

Fannie Mae's current Title and Closing Requirements for Multifamily Mortgage Loans, Form 4650, requires the lender to attach a marked title commitment or pro forma title policy to the closing instruction letter. That attachment must comply with the form and evidence the title underwriter's commitment to issue the policy with an effective date as of mortgage-loan funding.

The coverage must be in effect when the lender funds the mortgage loan. If the property is in a jurisdiction where the policy does not become effective until the insured instrument is recorded, Form 4650 requires the title company to record the insured instruments and issue the lender's policy simultaneously with the mortgage-loan closing. The recording sequence and policy-effective-date mechanics therefore need to be settled before the funding window.

When issued, the policy must be later-dated to cover the recording date of the Assignment of Security Instrument. It must also include the document title, parties, effective date, recording date, recording reference, and recording office for the Security Instrument, its assignment, and other required recorded documents. Those fields create a direct reconciliation point between the recorder's data and the final policy.

The lender must deliver Fannie Mae a final title policy complete with recording information for all insured instruments within 60 days after closing, subject to local recording practices. A post-closing tracker should identify the funding date, document order, recording status, assignment recording date, later-date request, policy drafter, recording references, reviewer, and delivery deadline, with an exception path for local recorder delay. This note is informational only and is not legal advice for any specific transaction.