SEC Comment Letter 0000000000-24-003120 to FEDERAL NATIONAL MORTGAGE ASSOCIATION FANNIE MAE (FNMA, FNMAG, FNMAH, FNMAI, FNMAJ, FNMAK, FNMAL, FNMAM, FNMAN, FNMAO, FNMAS, FNMAT, FNMFM, FNMFN) (CIK 0000310522) (FNMA)
FEDERAL NATIONAL MORTGAGE ASSOCIATION FANNIE MAE (FNMA, FNMAG, FNMAH, FNMAI, FNMAJ, FNMAK, FNMAL, FNMAM, FNMAN, FNMAO, FNMAS, FNMAT, FNMFM, FNMFN) (CIK 0000310522)
Date: March 21, 2024 · CIK: 0000310522 · Accession: 0000000000-24-003120
AI Filing Summary & Sentiment
File numbers found in text: 000-50231
Letter
United States securities and exchange commission logo March 21, 2024 Chryssa C. Halley Executive Vice President and Chief Financial Officer Federal National Mortgage Association 1100 15th St., NW Washington, DC 20005 Re:Federal National Mortgage Association Form 10-K for Fiscal Year Ended December 31, 2023 File No. 000-50231 Dear Chryssa C. Halley: We have conducted a limited review of your annual report and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2023 Notes to Consolidated Financial Statements 1. Summary of Significant Accounting Policies Restructured Loans, page F-13 1.We note that you elected to suspend TDR accounting for eligible modifications under Section 4013 of the CARES Act during the period beginning on March 1, 2020 and ending on January 1, 2022. We also note the disclosure of your COVID-19 nonaccrual policy on page 117. Please provide us with the following:
•An analysis explaining, in detail, your accounting treatment and policies regarding non-accrual loans and interest income recognition for eligible modifications under Section 4013 of the CARES Act. Cite any authoritative accounting literature or guidance considered and applied. In your response, explain how the interest rate was determined for purposes of any interest income recognition for these loans and discuss any differences in how the interest rate was calculated if it varied depending on the type or length of the modification.
FirstName LastNameChryssa C. Halley Comapany NameFederal National Mortgage Association March 21, 2024 Page 2 FirstName LastName Chryssa C. Halley Federal National Mortgage Association March 21, 2024 Page 2
•Quantification of the amount of the eligible modifications and the associated interest income recognized, and any interest income deferred, for loans not accounted for as TDRs due to your election under Section 4013 of the CARES Act for each period presented. To the extent there are different types of modifications, or material differences in the terms of the modification, please provide this information separately for each material type of modification.
•An analysis explaining, in detail, your accounting treatment and policies for these loans subsequent to the expiration of the relief provided by Section 4013 of the CARES Act. As part of your response, please consider providing an illustrative example of a loan that went through an eligible modification under Section 4013 of the CARES Act, outlining the typical process for determining the interest rate for recognizing interest income on the loan both during and after the expiration of the relief. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Kirk C Silva
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United States securities and exchange commission logo
March 21, 2024
Chryssa C. Halley
Executive Vice President and Chief Financial Officer
Federal National Mortgage Association
1100 15th St., NW
Washington, DC 20005
Re:Federal National Mortgage Association
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 000-50231
Dear Chryssa C. Halley:
We have conducted a limited review of your annual report and have the following
comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
1. Summary of Significant Accounting Policies
Restructured Loans, page F-13
1.We note that you elected to suspend TDR accounting for eligible modifications under
Section 4013 of the CARES Act during the period beginning on March 1, 2020 and
ending on January 1, 2022. We also note the disclosure of your COVID-19 nonaccrual
policy on page 117. Please provide us with the following:
•An analysis explaining, in detail, your accounting treatment and policies regarding
non-accrual loans and interest income recognition for eligible modifications under
Section 4013 of the CARES Act. Cite any authoritative accounting literature or
guidance considered and applied. In your response, explain how the interest rate was
determined for purposes of any interest income recognition for these loans and
discuss any differences in how the interest rate was calculated if it varied depending
on the type or length of the modification.
FirstName LastNameChryssa C. Halley
Comapany NameFederal National Mortgage Association
March 21, 2024 Page 2
FirstName LastName
Chryssa C. Halley
Federal National Mortgage Association
March 21, 2024
Page 2
•Quantification of the amount of the eligible modifications and the associated interest
income recognized, and any interest income deferred, for loans not accounted for as
TDRs due to your election under Section 4013 of the CARES Act for each period
presented. To the extent there are different types of modifications, or material
differences in the terms of the modification, please provide this information
separately for each material type of modification.
•An analysis explaining, in detail, your accounting treatment and policies for these
loans subsequent to the expiration of the relief provided by Section 4013 of the
CARES Act. As part of your response, please consider providing an illustrative
example of a loan that went through an eligible modification under Section 4013 of
the CARES Act, outlining the typical process for determining the interest rate for
recognizing interest income on the loan both during and after the expiration of the
relief.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Kirk C Silva