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Background: In August 2025, we issued a bulletin summarizing recent changes to Fannie Mae’s Multifamily Title and Closing Requirements contained in: Guide Update 25‑10 (effective May 8, 2025) and Notification 25‑13 (effective July 30, 2025) which clarified Fannie Mae’s expectations regarding: funding controls, escrow functions, and certain title documentation requirements. Mostly notably the update provided that:
· “Funding Functions” must be performed by an Approved Title Insurance Underwriter (except where limited by law, in which case the underwriter is required to review and approve funding functions); and
· Agents could continue to perform escrow functions consistent with Fannie Mae guidance.
For reference, see the prior bulletin here.
Recent Update: In December 2025, Fannie Mae issued Notification 25-25, further updating Form 4650 & Form 4650A as follows:
· Allows a Title Agent, that is a wholly-owned subsidiary of either an Approved Title Insurance Underwriter, or the parent company of any Approved Title Insurance Underwriter to perform Funding Functions;
· Clarifies that Title Agents are authorized to issue the Lender’s Title Policy on behalf of the Title Insurance Underwriter, and
· Includes on the list of Approved Title Insurance Underwriters, all Approved Wholly – Owned Title Agents.
What this means for you:
For Fannie Mae Multifamily transactions:
· CATIC & CATIC Title are Approved Title Insurance Underwriters
· We are authorized to perform Funding Functions in accordance with the most recent guidelines
· You, as our Title Agents, may issue Lender’s policies on our behalf in accordance with Fannie Mae guidelines
CATIC Commercial, working in support of our branch offices, has a dedicated and experienced team to perform the funding function and assist with any of your Fannie Mae Multifamily transactions.
For questions or assistance navigating these requirements, please reach out to your local CATIC or CATIC Title underwriter.
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