ARTICLE
8 July 2025

FHFA Orders Fannie Mae And Freddie Mac To Consider Cryptocurrency Reserves In Mortgage Risk Assessments

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Sheppard Mullin Richter & Hampton

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Sheppard Mullin is a full service Global 100 firm with over 1,000 attorneys in 16 offices located in the United States, Europe and Asia. Since 1927, companies have turned to Sheppard Mullin to handle corporate and technology matters, high stakes litigation and complex financial transactions. In the US, the firm’s clients include more than half of the Fortune 100.
On June 25, the Federal Housing Finance Agency (FHFA) issued a directive ordering Fannie Mae and Freddie Mac to prepare proposals for treating cryptocurrency held on U.S.-regulated...
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On June 25, the Federal Housing Finance Agency (FHFA) issued a directive ordering Fannie Mae and Freddie Mac to prepare proposals for treating cryptocurrency held on U.S.-regulated exchanges as assets for reserves in single-family mortgage loan risk assessments without requiring conversion to U.S. dollars.

Director William J. Pulte of the FHFA, which oversees Fannie Mae and Freddie Mac (the "GSEs"), emphasized that the move may enhance access to sustainable homeownership by recognizing a broader spectrum of borrower assets. The directive marks the first formal step toward integrating digital assets into GSE's underwriting frameworks.

As outlined in the order, each GSE must address the following requirements in its proposal:

  • Crypto reserves may be included without conversion into U.S. dollars. The Enterprises must evaluate how verified crypto holdings could factor into borrower reserves, even if not converted to U.S. dollars.
  • Only regulated exchange holdings qualify. Eligible crypto assets must be evidenced and stored on a U.S.-regulated centralized exchange subject to all applicable laws.
  • Risk-based adjustments are required. The GSEs must consider additional risk mitigation to account for market volatility and limit the portion of reserves composed of cryptocurrency.

Putting It Into Practice: By directing Fannie Mae and Freddie Mac—who guarantee over half of U.S. mortgages—to consider verified crypto reserves in underwriting, FHFA could expand mortgage access for crypto-holding borrowers. This FHFA directive is the latest in a series of initiatives by federal and state regulators advancing a crypto-based agenda in financial services (previously discussed here, here, and here).

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