Guideline Brief · DU 12.1 September Update

DU changed on September 25.

On the evening of September 25, 2026, Fannie Mae pushed its September update to Desktop Underwriter. The red-flag section was rebuilt around occupancy, with a new message that reads external data and the borrower's rental history. Salaried borrowers with a year of total work history can now validate employment after three months in the current job instead of twelve. The close-by clock moved to business days. Three conditions now return an Ineligible. In the first week, almost nobody wrote it up. Here is every change, as it looks in the findings.

October 1, 2026 13 min read
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On the evening of Friday, September 25, 2026, Fannie Mae implemented its September update to Desktop Underwriter Version 12.1.1 Fannie's integration memo, in a preliminary count, put it at 11 new messages, 25 modified and 7 retired.2 The update rebuilt the Potential Red Flag section of the findings around occupancy, added a flag that reads external data and the borrower's rental history, let salaried borrowers with twelve months of total work history validate employment after three months in the current job instead of twelve, moved the employment close-by clock from calendar days to business days, and made three conditions return an Ineligible recommendation.1 As of October 1, the public coverage we could find was one short trade article that names none of those changes,5 a blog post derived from it, and two correspondent bulletins that restate or point to Fannie's notes without adding to them.3,4

This brief walks through every change the way it shows up in the findings — with the mock report, the employment timeline and the close-by calendar you would want in front of you before your next pipeline review. A word on method: every rule below is quoted from the release notes, the integration memo, Fannie Mae's Potential Red Flag matrix dated the same day, and the Selling Guide as published on October 1, 2026. Where Fannie Mae has not said something — what "business days" excludes, which external data feeds the new occupancy flag — the brief says so rather than guessing.

11
new DU messages in the September update, with 25 modified and 7 retired (integration memo, preliminary count)2
3 mo
of current employment, with 12 months of total history, now validates fixed base income (it was 12 current) — for casefiles created on or after Sept. 261
10
business days from a VOE report's date to close with employment validation intact, replacing ten calendar days1,18
Nov 30
the day the enhanced HTML and enhanced PDF findings reports retire1,2

What landed, and which loans it touches

DU releases moved from Saturday evenings to Friday evenings with the June update; Fannie Mae's stated reason was to give partners "additional time to review updates and prepare their systems before normal business hours resume."6 So the September update went live on a Friday night, and most lenders would first have seen it on Monday morning.

That matters because the release has two effective-date triggers, and they don't match. Most of it — the red-flag rebuild, the Collateral Underwriter eligibility messages, the new Ineligibles — applies to "DU V. 12.1 loan casefiles submitted or resubmitted on or after the evening of Sept. 25, 2026." The DU validation service changes — the three-month employment rule and the business-day close-by date — apply only to "loan casefiles created on or after Sept. 26, 2026."1 A file you opened in August and resubmit now gets the new red-flag list and the new Ineligibles, but keeps the old validation rules for as long as it lives. Of the lender bulletins we could find, only Truist's spelled that distinction out.3 Press Resubmit on each sample file below to see which rule set it picks up.

Four casefiles, resubmitted after the releaseResubmitted Oct 1, 2026 · which rules apply
CasefileCreatedLast submittedRed flags · CU · IneligiblesValidation service
Purchase, salaried borrowerFour months on the job · VOE report in file
CreatedAug 30
SubmittedSep 2
Old red-flag layout · reminders 12 months current · calendar days
Rate/term refi, principal residenceSubject address differs from current address
CreatedSep 18
SubmittedSep 24
Old red-flag layout · reminders 12 months current · calendar days
Purchase, hourly borrowerCreated Friday afternoon, before the release
CreatedSep 25
SubmittedSep 25
Old red-flag layout · reminders 12 months current · calendar days
Purchase, salaried borrowerNew casefile opened Monday
CreatedSep 28
SubmittedSep 28
New red-flag list · CU Ineligibles · rental-income Ineligible 3-month fixed-income rule · business-day close-by
Illustrative casefiles; the two triggers are quoted from the release notes.1 DU for Government Loans was updated the same weekend on its own schedule.35

A few smaller items round out the notes and get no section of their own below: a new Observation message on RefiNow transactions "specifying the loan number being refinanced with the transaction," an updated RefiNow project-review message, and a new Observation message "specifying the attachment type provided in the loan application data for cooperative properties and properties in a planned unit development". Fannie also says "various DU messages will be updated" for clarity and consistency with the Selling Guide, without listing them.1

The red-flag section, rebuilt

The Potential Red Flag section is not new, and the Selling Guide's description of it, last revised in 2022, still lists three message types: excessive resubmissions, a frozen credit report, and potential casefile ID reuse.8 The September update moves all three out — the excessive-submission and casefile-reuse messages to the Observation section, the frozen-credit messages to the Verification section — and refills the section with occupancy and collateral.1

Two existing occupancy verification messages move back in. One existing red flag stays, in a new format. One new occupancy message is added "based on a combination of loan application and external data." One new subject-property message is added based on Collateral Underwriter. Every red flag now renders inside a list message — one for occupancy (Msg 3969), one for the subject property (Msg 3971) — with a Message Identifier that, Fannie notes, "is specific to PRF messaging and is not a DU message ID." And "each instance of a message shown will be factored into the Red Flag counter displayed on the PDF version of the report."1 The identifiers are DOM-01, DOM-02, DOM-03, OCC-03 and DCM-01; Fannie's two-page matrix, re-issued with the same date, explains what causes each and what it recommends reviewing.7

Switch on the signals in a file and watch the section assemble. Flip the layout to see where the same signals surfaced before the update. Tap any identifier for Fannie's own cause and recommended review.

Signals in the file
DU Underwriting Findings Representative excerpt · DU 12.1
Potential Red Flags · list messages with Message Identifiers
No red flags. Switch on a signal to see how the section fills.

1. The following red flags related to occupancy have been identified.Msg 3969

Message IdentifierMessage Text
The occupancy on a previous submission was modified from investor to primary. Confirm the accuracy of the occupancy for this transaction.
The subject property address does not match the borrower's current address. Because this loan casefile was submitted as a principal residence refinance transaction, obtain documentation to confirm the accuracy of this information and, if appropriate, make necessary corrections and resubmit the loan casefile to DU.
The data submitted indicates the borrower(s) intent to occupy this property as a principal residence. However, according to our records, we have recently purchased at least one loan belonging to the borrower(s) that was recently originated and secured by a property that was identified as their principal residence. Obtain documentation that confirms the borrower(s) intent to occupy this property.
Based on external data, information on the loan application, and the borrower's history of managing rental properties, this loan has an elevated risk of an inaccurate occupancy type. The lender should document its review of occupancy information and any supporting information used to confirm the occupancy designation. If the primary occupancy was not confirmed, update the occupancy to investment and resubmit the loan casefile to DU.

2. The following red flags related to the subject property have been identified.Msg 3971

Message IdentifierMessage Text
Collateral Underwriter has indicated a heightened risk of overvaluation on the appraisal. The lender should carefully review the appraisal for this transaction to ensure the value is supported.
Potential Red Flags · individual messages, no identifiers
Excessive resubmissions · Frozen credit report · Potential casefile ID reuse — the three message types the Selling Guide lists for this section; now moved to the Observation and Verification sections.8,1
Occupancy message (since July 2024): a reminder "to confirm the accuracy of the occupancy on the loan casefile" when the loan was submitted as an investment property and later changed to a primary residence.9
Verification Messages / Approval Conditions
Nothing from these signals. Switch on the address or Fannie's-records signal.
The subject property address does not match the borrower's current address. Because this loan casefile was submitted as a principal residence refinance transaction, obtain documentation to confirm the accuracy of this information…
The data submitted indicates the borrower(s) intent to occupy this property as a principal residence. However, according to our records, we have recently purchased at least one loan belonging to the borrower(s)… Obtain documentation that confirms the borrower(s) intent to occupy this property.
Not in the findings before Sept. 25
No message. OCC-03 is new with this release.
No red flag. DCM-01 is new with this release.
Reconstructed. The release notes say two existing occupancy Verification messages moved into the Potential Red Flag section without naming them; DOM-02 and DOM-03 are shown under Verification Messages above by elimination (the notes' example marks them "existing"), in their current wording.1 The three older message types are from the Selling Guide's description of the Potential Red Flag section.8
What causes DU to return DOM-01

"When the occupancy is changed on a resubmission from investor to primary."

Fannie Mae recommends reviewing

"This data change could indicate incorrect occupancy for the subject transaction. Confirm that either the previous occupancy listed in DU was stated in error or obtain a detailed explanation regarding the change in expected occupancy for the subject transaction. Otherwise, correct the occupancy to investment and resubmit the loan casefile to DU."7

What causes DU to return DOM-02

"When the subject address and the borrower's current address do not match on a principal residence refinance transaction."

Fannie Mae recommends reviewing

"This data discrepancy could indicate incorrect occupancy for the subject transaction. Obtain a detailed explanation from the borrower regarding the data discrepancy. Otherwise, correct the occupancy and resubmit the loan casefile to DU."7

What causes DU to return DOM-03

"When Fannie Mae has recently purchased a loan secured by the borrower's principal residence and the borrower is purchasing or refinancing a principal residence for a different property."

Fannie Mae recommends reviewing

"This could indicate incorrect occupancy for the subject transaction. Obtain a detailed explanation from the borrower regarding the recent purchase of a different principal residence. Otherwise, correct the occupancy and resubmit the loan casefile to DU."7

What causes DU to return OCC-03

"Based on external data and a combination of borrower and property-related information on the loan application, including the borrower's history of managing rental properties."

Fannie Mae recommends reviewing

"The combination of borrower and property-related data elements may indicate characteristics commonly associated with investment property transactions. The lender should document its review of occupancy information and any supporting information used to confirm the occupancy designation for the transaction. If the occupancy as a principal residence was not confirmed, update the occupancy to investment and resubmit the loan casefile to DU."7

What causes DU to return DCM-01

"Based on comparable sales data, market trends, public records, and other property data, Collateral Underwriter has determined that the appraisal has a heightened risk of overvaluation and provides an overvaluation message to support the strongest statistical correlation to the risk."

Fannie Mae recommends reviewing

"The lender should evaluate the overvaluation reason message and review the appraisal to confirm that the reason for the overvaluation message has been adequately addressed and that the value is supported in accordance with Selling Guide B4-1.3."7

A representative Potential Red Flag section built from the release notes' example and Fannie Mae's matrix; message text is verbatim from the notes' example.1,7 "The appearance of these messages does not affect the underwriting recommendation from DU," the matrix says.7 The counter's placement on the PDF report is not shown in any Fannie Mae sample.

DOM-01 dates to 2024

The "investor to primary" message arrived with the DU 11.1 July 2024 update, which described it as "reminding lenders to confirm the accuracy of the occupancy" when a loan is submitted as an investment property and later changed to a primary residence.9 What is new in 2026 is that occupancy leads the section, each flag carries an identifier and counts toward a Red Flag counter, and one message draws on external data.

Why occupancy, why now

Fannie Mae's own post-purchase reviews suggest why. In the Quality Insider editions covering April–September 2024, Q1 2025 and Q3–Q4 2025, the top-listed initial significant defect in the random sample was the same each time: misrepresentation of primary occupancy.11,12,10 In the mid-2024 period, "approximately 25% of the initial significant defects cited … related to income misrepresentation or primary occupancy misrepresentation," and "a common document found in many of these loan files is a fabricated lease agreement."11 In 2025, "the leading driver of PALs across all samples was occupancy - specifically loans delivered as primary residences that were actually investment properties."10 (A PAL, or price-adjusted loan, has a defect but would still have been deliverable with the correct data and price adjustment.) A significant defect "makes the loan ineligible for delivery to Fannie Mae and requires a remediation. A potential repurchase is possible."11

The incentive is structural. As Fannie puts it, lower-risk transactions "often allow for higher loan-to-value ratios and lower interest rates for the borrower. This cost differential could potentially incentivize the borrower to misrepresent an investment property as a primary residence or second home so they can borrow more at a lower cost."13 And the new OCC-03 has an obvious precedent in Fannie's October 2025 red-flag table for owner-occupied files, which lists "Borrower has other rental properties" alongside the insurance policy, the Schedule E and the commute distance.13 The June 2026 best practice reads like the message's specification: review "tax returns, bank statements for evidence of rental income, credit history for multiple mortgages, and the homeowner's insurance declaration page for language that suggests the property may be a rental."10

One caution keeps this honest: application-level alerts and post-purchase findings are different measurements. Cotality's occupancy-fraud risk index fell 5.8% year over year in its 2026 annual report, which says "Cotality's data suggests occupancy fraud risk has plateaued."14 Its Q2 2026 index still found indications of fraud of some kind in roughly one investment-property application in 44, against one in 119 overall.15 The performance evidence is older than any of it: a 2023 Philadelphia Fed study of loans originated from 2005 to 2017 found borrowers who misrepresented occupancy defaulted at a 75% higher rate than declared investors and made up about one-third of the effective investor population.16

OCC-03 is a Fannie Mae flag. We read Freddie Mac's July through October LPA release notes looking for a counterpart; the nearest is a "Primary Residence Review" message that fires when occupancy changes between LPA submissions — closer to DOM-01 than to an external-data flag.17 Open each document below for what Fannie says to look for in it.

Where the signals already liveOne open at a time · Fannie Mae's own red-flag language
1003 applicationDOM-02 · OCC-03

Declared occupancy, current address, and the real-estate-owned schedule. Fannie's red flags for an owner-occupied file: Borrower has other rental properties; Borrower is downgrading to a notably smaller or less expensive home; Significant or unrealistic commuting distance.13

DOM-02 fires when the subject address and the current address don't match on a principal-residence refinance.7

Schedule EOCC-03

Schedule E of the borrower's tax return or transcript reflects the subject property as a rental property.13 For an underwriter, Schedule E is the plainest record in the file of the "history of managing rental properties" in the OCC-03 text;7 the matrix places that history among the information "on the loan application."

Insurance declarationsOccupancy defect

Property insurance policy is inconsistent with occupancy type.13 Fannie's defect definition cites policy language such as "rent loss coverage" as indicative of a rental property.10

Credit reportDOM-03

Fannie's June 2026 best practice has underwriters check credit history for multiple mortgages.10 DOM-03 fires when Fannie Mae recently purchased another loan secured by the borrower's principal residence.7 In the Philadelphia Fed sample, 17% of declared owner-occupants carried multiple first liens four quarters after origination, versus 42% of declared investors.16

AppraisalDCM-01

Occupant field on appraisal reflects tenant or vacant.13 DCM-01 is the collateral flag: Collateral Underwriter has indicated a heightened risk of overvaluation on the appraisal.7

Bank statementsOccupancy defect

Fannie's June 2026 best practice has underwriters check bank statements for evidence of rental income.10 Rental deposits on a declared primary residence are a cross-document contradiction before they are a red flag.

Where the signals behind the new red flags already sit in a loan file. Quotes are from Fannie Mae's occupancy red-flag table13 and the June 2026 Quality Insider.10

Three months, not twelve

The validation-service change is the one brokers will feel first. Before the update, "DU requires that a borrower have at least 12 months of current employment to validate employment income." Now, for casefiles created on or after Sept. 26, DU requires two things to validate fixed base income: "At least 3 months of current employment" and "At least 12 months of total employment history (current and prior employment combined)." Variable base income, "including borrowers who are paid an hourly or daily wage," still needs 12 months of current employment.1

Two clarifications the notes don't make. First, the twelve-month rule was never Selling Guide policy. Fannie's own FAQ says so: "The 12-month minimum requirement is specific to the validation service – not a change in overall Selling Guide policy."18 For a salary documented the standard way rather than validated, the Guide says "a minimum history is not required for inclusion as qualifying income"; for variable base income, "a minimum 12-month history of receiving variable income is required."19 So the change narrows a gap between DU's validation threshold and the Guide rather than loosening the Guide. Second, "fixed" has a definition: "a set salary or fixed hourly rate with guaranteed minimum hours"; variable is "a fixed hourly rate with fluctuating hours, or an hourly rate that varies."19 Whether DU's validation logic sorts every hourly-paid borrower into the variable group is not stated. Lenders must still judge whether the work history "reflects a reliable pattern of employment over the most recent two years," with shorter histories acceptable when "positive factors … reasonably offset" them.20

Who this reaches: the Bureau of Labor Statistics' tenure survey, released the day before the DU update, found 20.6% of wage and salary workers had been with their employer a year or less, and 25.5% of 25-to-34-year-olds had 12 months or less.21 Those are all workers, not applicants, but they are the population the old threshold excluded from validation. We found no published rationale for the three-month figure; the release notes state it without one.1 Drag the two histories below and switch the income type.

Casefiles created before Sept. 26 · any income type
Does not validate
DU required 12 months of current employment to validate; 4 months is 8 months short.
Casefiles created on or after Sept. 26
Validates
4 months current (≥ 3) and 12 months total (≥ 12) — DU can validate.

Without validation, for comparison: the Guide sets no minimum history for fixed base income and a 12-month history (not necessarily with one employer) for variable base income.19

DU validation-service thresholds before and after Sept. 26, 2026, per the release notes;1 income definitions per Selling Guide B3-3.3-01.19 Whether DU treats every hourly-paid borrower as variable for validation purposes is not stated, and neither is how it treats a gap between jobs or more than one prior employer.

"The 12-month minimum requirement is specific to the validation service – not a change in overall Selling Guide policy."

Fannie Mae, DU Validation Service FAQs18

Validation is relief, not approval

When DU validates employment, "the validation satisfies the requirement for verbal verification of employment," and the loan may be eligible for relief from enforcement of representations and warranties on that component — provided, among other requirements, that it closes by the close-by date and the lender resolves "any conflicting or contradictory information."23 In ACES's Q1 2026 benchmark of post-closing reviews run in its software, income and employment still accounted for one in five critical defects.22

The close-by clock

When DU validates employment, the findings carry a close-by date: the loan must close by it "to retain relief from representations and warranties on employment verification."1 For validations based on a verification-of-employment or verification-of-income-and-employment report, that date is now, for casefiles created on or after Sept. 26, "ten business days from the Report Date of the report" — "using business days instead of calendar days."1 The calendar-day rule it replaces was still on Fannie's FAQ page on October 1, 2026: "the loan must close within ten calendar days of the report date" for an income or employment verification report.18 Asset-report-based validation is untouched: 15 calendar days from the asset report's date or the next expected deposit date, whichever is later.18

The change makes DU's clock rhyme with the Selling Guide's own verbal-VOE window, which is in business days: "within 10 business days prior to the note date for employment income."24 Before the update, DU's validation window was the shorter of the two. Pick a report date to see both clocks; if the report date is day zero, the business-day version lands four calendar days later for any weekday report date, and later again when a federal holiday falls in the window and DU skips it. Fannie Mae hasn't said either.

Report dateCounted business dayWeekend / holidayOld close-by (10 calendar days)New close-by (10 business days)
—
Old close-by date
ten calendar days18
—
New close-by date
ten business days1
—
Extra calendar days to close with relief intact
Both windows counted from the report date, per the release notes1 and the FAQ.18 Assumptions, because Fannie Mae has not published them: business days are Monday to Friday, the holiday switch is ours, and the report date is day zero. The close-by date printed in your DU findings governs.

Three new Ineligibles

Three situations that used to produce a reminder, or a problem at delivery, now produce an Ineligible recommendation at submission — and one Ineligible became a keystroke. Two more messages are easy to misread as eligibility hits and aren't. Run each file to see DU's response, then open the cure.

Selling Guide alignment

Rental income on a one-unit primary

Purchase, one-unit principal residence. The 1003 includes $1,800 a month of rental income from the subject property.

IneligibleBefore: reminder, eligibility unaffected
The rule, and the cure

The rule didn't change — rental income from a one-unit principal residence or a second home "cannot be used to qualify the borrower."25 DU's response did: a reminder became an Ineligible.1 Remove the subject rental income and resubmit.

On a second home the loan stays eligible "as long as the income is not used for qualifying purposes, and all other requirements for second homes are met".26 The exception is accessory dwelling unit (ADU) income on a one-unit primary: purchase or limited cash-out only, one ADU, capped at 30% of total qualifying income.25,33

Collateral Underwriter eligibility

C6 condition rating

The appraisal rates the dwelling C6: deficiencies that affect safety, soundness or structural integrity.

IneligibleBefore: no DU message
The rule, and the cure

"Loans secured by properties with a condition rating of C6 are not eligible for sale to Fannie Mae"; deficiencies "must be repaired with a resulting minimum condition rating of C5," with the appraisal completed "subject to" the repairs.27 DU now says so at submission.1

The notes don't describe how the Ineligible clears once a C5 appraisal is in the file.

Collateral Underwriter eligibility

Appraiser on the No Longer Accepted list

The appraiser — or the supervisory appraiser — on the report is on the No Longer Accepted list.

Ineligible · new appraisalBefore: UCDP message, delivery stop
The rule, and the cure

The notes call it only the "No Longer Accepted list" and don't say where it is kept. The likely candidate is Fannie's Appraiser Quality Monitoring list, which "includes appraisers whose work is subject to 100% post-acquisition review or is no longer accepted by Fannie Mae," and is updated monthly; under it, the stop until this update was a message in the Uniform Collateral Data Portal (UCDP) and a delivery prohibition.28

Now DU issues an Ineligible "and a message will be issued specifying that a new appraisal would need to be obtained to proceed with the loan" — and the check covers the supervisory appraiser too.1

Not an Ineligible

Lava Zone 1 or 2 ZIP code

Subject property on the island of Hawaii, in a ZIP code that includes Lava Zone 1 or 2 land.

Confirm the zoneBefore: no DU message
The rule, and the cure

The Guide rule is parcel-level: "Properties in lava zones 1 and 2 are not eligible due to the increased risk of property destruction from lava flows within these areas."29 DU's trigger is the ZIP code — lenders "will need to confirm the accuracy of the lava zone designation or postal code" — so a Zone 3 parcel sharing a ZIP with Zone 1 land should expect the message.1 Document the zone and move on.

An Ineligible became a keystroke

Principal residence exception

Parents buy a home for an adult child with a disability who can't qualify alone. No borrower will occupy.

No occupancy Ineligible · confirm the exceptionBefore: Ineligible — no borrower occupying
The rule, and the cure

The Guide treats a home bought by parents for a "handicapped or disabled adult child," or by children for a parent, as a principal residence when that person "is unable to work or does not have sufficient income to qualify for a mortgage on their own."26 Until this update DU returned Ineligible when no borrower occupied.

Now enter "PrincipalResidenceException" in the DU Policy Feature Description field in Section 5, Declarations, and DU issues a verification message to confirm the exception applies instead.1 Your LOS has to send that enumeration — it was added in DU Spec 1.9.3.2

Not an Ineligible

CU overvaluation flag

Collateral Underwriter scores the appraisal high and flags overvaluation risk.

Red flag DCM-01Before: flag lived in CU only
The rule, and the cure

CU scores appraisals from 1.0 to 5.0 and flags overvaluation risk; a score of 2.5 or lower can earn rep-and-warrant relief on value for eligible appraisals.30 A red flag "does not affect the underwriting recommendation from DU."7

But among loans with appraisal-related significant defects, the median CU score was 4.6 and about 95% carried an overvaluation flag.31 Treat DCM-01 as the QC finding arriving early.

Outcomes per the release notes;1 rules per the Fannie Mae sources cited in each card. Scenarios and cures are illustrative.

November 30, and the rest of the DU calendar

The findings report many brokers still print is on a clock. With the new PDF findings introduced June 26, Fannie said it would retire the enhanced HTML and enhanced PDF versions "later this year"; the September notes set the date: November 30, 2026.32,1 The integration memo is blunter: file types 16 and 17 "will be retired on November 30, 2026. Any requests for these Return File Types will result in no response."2 The classic HTML version isn't scheduled; the new PDF and the JSON findings are the forward path; the RES, TEXT and XML formats retire October 27, 2028.2,32

days until the enhanced HTML and enhanced PDF findings retire

On Nov. 30, 2026 the enhanced HTML and enhanced PDF versions of the DU Underwriting Findings report retire.1 If your LOS requests return file type 16 or 17, it gets "no response."2

What stays: the new PDF findings (file type 19, introduced June 26 and opt-in through your LOS), the JSON findings (type 18), and the classic HTML version.32,2

Enhanced HTML · 16 — Nov. 30, 2026Enhanced PDF · 17 — Nov. 30, 2026New PDF · 19JSON · 18RES · TEXT · XML — Oct. 27, 2028
Live countdown to Nov. 30, 2026; file types per the integration memo and the May 27 findings-report notes.2,32

September's update sits inside a busy year for DU 12.1. Scroll the calendar.

DU 12.1 in 2026
Mar 21, 2026
DU 12.1 goes live

ADU rental income allowed on a one-unit principal residence, capped at 30% of qualifying income; HomeStyle Refresh; DU 11.1 retired.33

Jun 26, 2026
First Friday release

The June update modified DU's minimum credit risk standards, anticipating "a moderate reduction in the number of loan casefiles that receive an Approve/Eligible recommendation" for casefiles created on or after June 27; the new PDF findings option arrives.6,32

Sep 9, 2026
VantageScore 4.0 for every lender

DU accepts VantageScore 4.0 on all 12.1 casefiles; Lender Letter LL-2026-06 opens it to all lenders, one score model per loan, SFC 067 at delivery.34

Sep 25, 2026
The September update

Red-flag section rebuilt; CU eligibility messages; rental-income Ineligible; PrincipalResidenceException; 11 new, 25 modified, 7 retired messages in the memo's preliminary count.1,2

Sep 26, 2026
Validation rules for new casefiles

Three-month rule and business-day close-by date for casefiles created on or after this date. DU for government loans updated: FHA ARMs use the lender-entered qualifying rate when one is provided.1,35

Nov 2, 2026
UAD 3.6 mandate

Lenders "must transition to Uniform Appraisal Dataset (UAD) 3.6 no later than Nov. 2, 2026"; DU has reminded since June.6

Nov 30, 2026
Enhanced findings retire

Enhanced HTML (file type 16) and enhanced PDF (17) stop returning; new PDF, JSON and classic HTML continue.1,2

Oct 27, 2028
RES, TEXT and XML retire

Fannie Mae asks integrated partners to plan the move to JSON "as part of their 2026/2027 roadmap."32

Dates from Fannie Mae's 2026 release notes and memos.33,6,34,1,32

What a broker should do now

DU, Sept. 25 vs. LPA, July–October 2026Nearest Freddie Mac analog, from the LPA release notes17
DU changeClosest LPA itemDifference
OCC-03 external-data occupancy flag"Primary Residence Review" messages (effective Jul 26 and Aug 23)LPA's message fires when occupancy changes between submissions — a DOM-01 analog, not an external-data flag.
DCM-01 CU overvaluation red flagLoan Collateral Advisor risk-score message (July)LPA surfaces the score; no overvaluation red flag tied to it.
3 months current + 12 total to validate fixed base incomeWritten VOE accepted for automated income assessment (Bulletin 2026-12; in LPA Oct. 4)Freddie widened document types for relief; Fannie lowered the tenure threshold. No tenure change found in Freddie's automated income assessment.
C6, No-Longer-Accepted appraiser, subject rental income → IneligibleNone found—
Based on Freddie Mac's July–October 2026 LPA release notes (July's items as recapped in the August notes); Freddie Mac bulletin text was not accessible to us directly.17

What DU is doing now is cross-document reconciliation

Does the declared occupancy agree with the address history, the rental history, the appraisal and the valuation model? That is the same check an underwriter runs by reading the whole file — and the reason we built Power Underwriter to run it on intake, with every finding cited to the page it came from.

Frequently asked questions

Fannie Mae's DU 12.1 September Update rebuilt the Potential Red Flag section (occupancy and subject-property list messages with identifiers DOM-01, DOM-02, DOM-03, OCC-03 and DCM-01, plus a Red Flag counter on the PDF report); added Collateral Underwriter eligibility messages (a lava-zone ZIP confirmation, and Ineligibles for an appraiser on the No Longer Accepted list and for a C6 condition rating); changed the validation service so fixed base income validates with three months of current employment and twelve months total history, with a ten-business-day close-by date for validations based on a verification-of-employment report; added the PrincipalResidenceException policy feature; made subject rental income on a one-unit principal residence or second home an Ineligible; and set November 30 as the retirement date for the enhanced HTML and PDF findings.1 The integration memo's preliminary count is 11 new, 25 modified and 7 retired messages.2
No. The validation-service changes apply to "loan casefiles created on or after Sept. 26, 2026." Under the notes' wording, a casefile created earlier stays on the twelve-month current-employment requirement even when resubmitted. The rest of the release applies to any DU 12.1 casefile "submitted or resubmitted on or after the evening of Sept. 25, 2026."1 Truist's correspondent bulletin is the one we found that restated both triggers.3
A new occupancy message in the Potential Red Flag section: "Based on external data, information on the loan application, and the borrower's history of managing rental properties, this loan has an elevated risk of an inaccurate occupancy type."1 Fannie Mae's matrix gives the cause as "Based on external data and a combination of borrower and property-related information on the loan application, including the borrower's history of managing rental properties," and asks the lender to document its occupancy review — or update the occupancy to investment and resubmit.7 Like every red flag it does not change the recommendation, and Fannie Mae has not described which external data feeds it.
The Guide rule did not change: rental income from a one-unit principal residence or a second home "cannot be used to qualify the borrower."25 DU's response did — a reminder that left eligibility untouched became an Ineligible recommendation.1 Remove the subject rental income and resubmit. ADU income on a one-unit primary is the exception: purchase or limited cash-out only, one ADU, capped at 30% of total qualifying income.25
The enhanced HTML and enhanced PDF findings retire on Nov. 30, 2026;1 requests for return file types 16 and 17 then "result in no response."2 The new PDF (type 19), the JSON findings (type 18) and the classic HTML version continue; RES, TEXT and XML retire Oct. 27, 2028.32,2

Sources

Every rule in this brief is quoted from Fannie Mae's release notes, integration memo, Potential Red Flag matrix and Selling Guide as published on October 1, 2026. Some Fannie Mae pages still describe the pre-September rules (ten calendar days; twelve months of current employment) and are cited as such. The sample casefiles, dates and signals in the interactives are illustrative; the message in your own DU findings governs. Where Fannie Mae has not published a detail — what "business days" excludes, which external data feeds OCC-03, the Collateral Underwriter threshold behind DCM-01 — the brief says so. Vendor figures (Cotality, ACES) are labeled as such. Statements about press coverage are as of October 1, 2026.

  1. Fannie Mae — Desktop Underwriter/Desktop Originator Release Notes: DU Version 12.1 September Update (July 29, 2026; updated Aug. 31, 2026)Implementation "during the evening of Sept. 25, 2026"; changes apply to casefiles "submitted or resubmitted on or after the evening of Sept. 25, 2026," validation-service changes to casefiles "created on or after Sept. 26, 2026"; Potential Red Flag restructure, example section with DOM-01/02/03, OCC-03, DCM-01, Msg 3969 and 3971, Red Flag counter; CU eligibility messages (lava zones, No Longer Accepted list, C6); fixed base income 3 months current + 12 months total, variable 12 months current; close-by date ten business days from the Report Date; PrincipalResidenceException; subject rental income Ineligible with ADU exception; RefiNow and attachment-type messages; enhanced HTML/PDF findings retired Nov. 30, 2026; brokers "should contact their DO sponsoring wholesale lender."
  2. Fannie Mae — DU Version 12.1 Integration Impact Memo: September Update (July 29, 2026)"New Messages 11 | Modified Messages 25 | Retired Messages 7" (the memo calls its table "a preliminary assessment of the anticipated message changes"); DU Spec 1.9.3 adds "PrincipalResidenceException" to DUPolicyFeatureDescription; new JSON container FNMPotentialRedFlagMessageCodes; return file types 16 (enhanced HTML) and 17 (PDF) "will be retired on November 30, 2026. Any requests for these Return File Types will result in no response"; RES/TEXT/XML retiring Oct. 27, 2028; JSON = type 18, new PDF = type 19; vendors must support changes "no later than 120 days after the date the related specifications are made available."
  3. Truist Bank Correspondent — Product Release Bulletin COR26-053: DU Version 12.1 Updates (Sept. 25, 2026)Restates the release headings and the two effective-date triggers: "submitted or resubmitted … on or after the evening of September 25, 2026, with the following exception: The DU Validation Service related updates will apply to DU Version 12.1 loan casefiles created on or after September 26, 2026."
  4. NewRez Correspondent — Announcement 2026-073: Fannie Mae DU Version 12.1 (Sept. 9, 2026)Summarizes the release headings and points lenders to Fannie Mae's release notes.
  5. WRE News — Fannie Mae Updates Desktop Underwriter to Flag Loan Issues Earlier (John G. Stevens, Sept. 25, 2026)The only trade article on the release we found; describes the update in general terms without naming a specific change. Cited as evidence of coverage, not for any rule. An undated Note Servicing Center post, "Fannie Mae updates Desktop Underwriter to flag loan issues sooner," cites this article as its source and adds no detail from the release notes.
  6. Fannie Mae — DU Version 12.1 June Update Release Notes (April 29, 2026; updated June 17, 2026)"Going forward, DU updates will move from Saturday evenings to Friday evenings … allows our partners additional time to review updates and prepare their systems before normal business hours resume"; risk and eligibility assessment modification anticipating "a moderate reduction in the number of loan casefiles that receive an Approve/Eligible recommendation" for casefiles created on or after June 27, 2026; UAD 3.6 transition "no later than Nov. 2, 2026."
  7. Fannie Mae — Desktop Underwriter Potential Red Flag Messages (9.25.26)Two-page matrix: identifier, message text, "What Causes DU to Return This Message?" and "We Recommend Review of the Following" for DOM-01, DOM-02, DOM-03, OCC-03 and DCM-01; "The appearance of these messages does not affect the underwriting recommendation from DU."
  8. Fannie Mae Selling Guide — B3-2-11, DU Underwriting Findings Report (09/07/2022)Describes the report's sections; lists "Excessive resubmissions," "Frozen credit report" and "Potential casefile ID reuse" as the potential red flag messages; "The appearance of these messages does not affect the underwriting recommendation from DU."
  9. Fannie Mae — DU Version 11.1 July Update Release Notes (May 29, 2024)"Potential Red Flag Occupancy Message — A new message will be issued reminding lenders to confirm the accuracy of the occupancy on the loan casefile. This message will be issued when the loan is submitted as an investment property and later changed to a primary residence." Effective the weekend of July 20, 2024.
  10. Fannie Mae — Quality Insider: Understand Top Defects to Help Strengthen Loan Quality (June 29, 2026)Top 10 initial significant defects, Q3–Q4 2025 random sample, led by "Misrepresentation of primary occupancy"; "In 2025, the leading driver of PALs across all samples was occupancy"; defect definition citing "rent loss coverage"; holistic-review best practice (tax returns, bank statements, credit history for multiple mortgages, insurance declaration page); "Appraisal-related issues made up four of the top ten findings"; definition of a price-adjusted loan (PAL).
  11. Fannie Mae — Quality Insider: Understand Top Defects to Help Strengthen Loan Quality (January 2025)Random sample of loans acquired April–September 2024 led by "Misrepresentation of Primary Occupancy"; "Approximately 25% of the initial significant defects cited … related to income misrepresentation or primary occupancy misrepresentation"; "A common document found in many of these loan files is a fabricated lease agreement"; "Significant Defect: A loan manufacturing error that makes the loan ineligible for delivery to Fannie Mae and requires a remediation. A potential repurchase is possible."
  12. Fannie Mae — Quality Insider: Understand Top Defects to Help Strengthen Loan Quality (September 2025)Q1 2025 random sample led by "Misrepresentation of primary occupancy."
  13. Fannie Mae — Quality Insider: Getting It Right – Reverification of Occupancy (October 2025)Cost-differential incentive language; red-flag tables for owner-occupied, second-home and investment files, including "Borrower has other rental properties," "Property insurance policy is inconsistent with occupancy type," "Schedule E … reflects the subject property as a rental property," "Occupant field on appraisal reflects tenant or vacant," "Significant or unrealistic commuting distance."
  14. Cotality — 2026 Annual Fraud Report (Sept. 15, 2026; vendor-modeled alert index)"Occupancy risk decreased 5.8% compared to a year ago"; "Cotality's data suggests occupancy fraud risk has plateaued"; "The most common occupancy fraud is that of an investor claiming primary occupancy on a subject property."
  15. Cotality — Q2 2026 Mortgage Application Fraud Risk Index (Aug. 4, 2026; vendor-modeled)Index 132, up 9.1% from Q1 and down 4.6% year over year; "1 in 119 mortgage applications had indications of fraud"; "1 in 44 investment applications"; "1 in 27 multi-family applications."
  16. Federal Reserve Bank of Philadelphia — Working Paper 23-01, Owner-Occupancy Fraud and Mortgage Performance (Elul, Payne, Tilson; January 2023)Fraudulent borrowers "defaulting at a 75 percent higher rate" than declared investors and "one-third of the effective investor population"; "17 percent of declared owner-occupants have multiple first liens in their credit bureau files four quarters following mortgage origination, compared with 42 percent of declared investors"; 584,499 loans, 2005–2017.
  17. Freddie Mac — Loan Product Advisor Release Notes, October 2026 (posted Sept. 16, 2026) and August 2026 (posted July 15, 2026)August notes: "Primary Residence Review Message Updates — Effective August 23, 2026 — We're revising a message to help you identify if there has been a change in the borrower's primary residence information" (new message effective July 26). October notes: "Written Verification of Employment (VOE) Enhancement — Effective October 4, 2026 — Guide Bulletin 2026-12 announced that written VOE has been added as eligible documentation for an automated income assessment"; no external-data occupancy flag, C6 Ineligible or employment-tenure change. August notes: sf.freddiemac.com/docs/pdf/lpa-august-2026-release-notes.pdf.
  18. Fannie Mae — DU Validation Service: Frequently Asked Questions (FAQs updated November 2025; as published Oct. 1, 2026)Pre-September rules, still posted: "When employment is validated, the loan must close within ten calendar days of the report date for an income or employment verification report or within 15 calendar days using a 12-month asset verification report"; asset-report close-by "15-days from the asset verification report date, or up to the next expected deposit date … (whichever is greater)"; "DU requires at least 12 months of income for the validation service to run. The 12-month minimum requirement is specific to the validation service – not a change in overall Selling Guide policy."
  19. Fannie Mae Selling Guide — B3-3.3-01, Base Income (03/04/2026)"Fixed base income refers to a set salary or fixed hourly rate with guaranteed minimum hours"; "Variable base income refers to a fixed hourly rate with fluctuating hours, or an hourly rate that varies"; fixed base income: "A minimum history is not required for inclusion as qualifying income"; variable base income: "A minimum 12-month history of receiving variable income is required." (The income chapter was restructured by SEL-2026-02, which created the section defining fixed and variable base income.)
  20. Fannie Mae Selling Guide — B3-3.2-02, Standards for Employment-Related Income (03/04/2026)"Lenders must evaluate the borrower's work history to determine whether it reflects a reliable pattern of employment over the most recent two years. A shorter employment history may be considered eligible for qualifying purposes if the borrower's employment profile includes positive factors that reasonably offset the shorter employment history."
  21. U.S. Bureau of Labor Statistics — Employee Tenure in 2026 (USDL-26-1532, Sept. 24, 2026)Median tenure 4.1 years in January 2026; "the share of wage and salary workers with a year or less of tenure with their current employer was 20.6 percent"; ages 25 to 34 median 3.0 years; Table 3: 25.5% of workers aged 25–34 with 12 months or less of tenure (bls.gov/news.release/tenure.t03.htm). Covers all wage and salary workers, not mortgage applicants.
  22. ACES Quality Management — Q1 2026 Mortgage QC Industry Trends Report (vendor QC benchmarking)Critical defect rate 1.71%; income/employment 20.07% of critical defects; borrower/mortgage eligibility 7.43%; appraisal 3.35%.
  23. Fannie Mae Selling Guide — B3-2-02, DU Validation Service (02/05/2025)"When employment is validated by DU, the validation satisfies the requirement for verbal verification of employment … Lenders must comply with all DU messages, including ensuring the loan closes by the 'Close by Date' stated in the DU employment validation message"; lender must "investigate and resolve any conflicting or contradictory information"; relief from representations and warranties on validated components.
  24. Fannie Mae Selling Guide — B3-3.1-04, Verbal Verification of Employment (03/04/2026)"The verbal VOE must be obtained within 10 business days prior to the note date for employment income, and within 120 calendar days prior to the note date for self-employment income"; "When employment is validated by DU … The DU message will include a date by which the loan must close."
  25. Fannie Mae Selling Guide — B3-3.8-01, General Rental Income Information, and B3-3.8-02, Rental Income from the Subject Property (09/02/2026)"Generally, rental income from the borrower's principal residence (a one-unit principal residence or the unit the borrower occupies in a two- to four-unit property) or a second home cannot be used to qualify the borrower. However, Fannie Mae does allow certain exceptions … for boarder income and rental income on principal residence properties with accessory units"; ADU limitations: one existing ADU, purchase or limited cash-out refinance only, "limited to 30% of the total qualifying income" (B3-3.8-02). Formerly B3-3.1-08.
  26. Fannie Mae Selling Guide — B2-1.1-01, Occupancy Types (10/05/2022)Principal-residence exceptions for "Parents or legal guardian wanting to provide housing for their handicapped or disabled adult child" and "Children wanting to provide housing for parents" ("If the parent is unable to work or does not have sufficient income to qualify for a mortgage on their own, the child is considered the owner/occupant"); second-home footnote: rental income permitted "as long as the income is not used for qualifying purposes."
  27. Fannie Mae Selling Guide — B4-1.3-06, Property Condition and Quality of Construction of the Improvements (06/04/2025)"Loans secured by properties with a condition rating of C6 are not eligible for sale to Fannie Mae. Any deficiencies impacting the safety, soundness, or structural integrity of the property must be repaired with a resulting minimum condition rating of C5 prior to sale of the loan"; C6 appraisals "must be completed 'subject to' completion of the deficient item(s)."
  28. Fannie Mae Selling Guide — B4-1.3-12, Appraisal Quality Matters (09/03/2025), and Appraiser Quality Monitoring FAQs (March 2025)"Fannie Mae may notify a lender that appraisals prepared by a given appraiser are no longer accepted … the lender is prohibited from delivering mortgages to Fannie Mae secured by properties appraised by that individual"; AQM FAQs: the list "includes appraisers whose work is subject to 100% post-acquisition review or is no longer accepted by Fannie Mae," updated monthly, enforced via a UCDP message (singlefamily.fanniemae.com/media/16536/display).
  29. Fannie Mae Selling Guide — B2-3-04, Special Property Eligibility Considerations (10/08/2025)"Fannie Mae will only purchase or securitize mortgage loans secured by properties that are located within lava zones 3 through 9 on the island of Hawaii. Properties in lava zones 1 and 2 are not eligible due to the increased risk of property destruction from lava flows within these areas."
  30. Fannie Mae — Collateral Underwriter: Risk Score and Risk Flags Overview (job aid) and Collateral Underwriter product page"Each appraisal receives a score on a scale of 1.0 to 5.0, with 1 indicating the lowest risk and 5 indicating the highest risk"; "Overvaluation - Statistical modeling is used to identify appraisals with higher probability of material overvaluation"; "a high-risk score does not necessarily mean the appraisal is bad"; product page: relief on property value "with CU risk scores of 2.5 or lower as part of Day 1 Certainty" (singlefamily.fanniemae.com/applications-technology/collateral-underwriter).
  31. Fannie Mae — Quality Insider: Understand Top Defects to Help Strengthen Loan Quality (May 2024)"Loans with appraisal related significant defects presented the following high-risk flags: Had a median CU score of 4.6; ~95% had an Overvaluation Flag (OVF)."
  32. Fannie Mae — New DU Underwriting Findings Report Options Release Notes (May 27, 2026; updated June 15, 2026)New PDF findings "on the evening of June 26, 2026," optional and requested through the LOS; "We plan to retire the enhanced HTML and enhanced PDF versions later this year"; "We will retire the RES, TEXT, and XML formats on October 27, 2028 … as part of their 2026/2027 roadmap."
  33. Fannie Mae — DU Version 12.1 Release Notes (Jan. 28, 2026; updated Feb. 18, 2026; effective the weekend of March 21, 2026)DU 12.1 implementation; ADU rental income "on one-unit, principal residence, purchase and limited cash-out refinance transactions," with the 30%-of-qualifying-income test; HomeStyle Refresh; DU 11.1 retirement.
  34. Fannie Mae — Lender Letter LL-2026-06, VantageScore 4.0 Broad Lender Availability (Sept. 9, 2026; updated Sept. 30, 2026), and DU Version 12.1 VantageScore 4.0 Update Release Notes (Sept. 9, 2026)VantageScore 4.0 expanded "to all Fannie Mae-approved lenders, without prior written approval"; "the same credit score model must be used for all borrowers on a single loan"; Special Feature Code 067; DU release notes: "DU has been updated to permit credit reports containing VantageScore® 4.0 for all loan casefiles underwritten through Desktop Underwriter® (DU®) Version 12.1" (release notes).
  35. Fannie Mae — DU for Government Loans Release Notes: September 2026 Release (Aug. 26, 2026)Updated "during the weekend of Sept. 26, 2026": FHA message updates and "DU will now use the lender-provided qualifying rate on all ARMs."
  36. Fannie Mae — Desktop Underwriter & Desktop Originator (product page)"Sponsored mortgage brokers have access to DU through Desktop Originator (DO)."
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We build the AI underwriting assistant that reads complete loan files, calculates income and assets, reviews conditions, and generates structured reports — without leaving your loan origination system. This brief quotes Fannie Mae's release notes, integration memo, Potential Red Flag matrix and Selling Guide as published on October 1, 2026, with Freddie Mac, Cotality, BLS, ACES and Federal Reserve research for context; every figure is traceable to the numbered sources above.