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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.
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,
FirstName LastNameChryssa C. Halley
Division of
Corporation Finance
Comapany NameFederal National Mortgage Association
Office of Finance
March 21, 2024 Page 2
cc: Kirk C Silva
FirstName LastName