Bulletin: SLS2025006

Dear Associates:

This bulletin advises you of the Federal National Mortgage Association’s (Fannie Mae’s) Chain of Title Schedule requirements and knowledge notification requirements for multifamily mortgage loans pursuant to Form 4650 “Title and Closing Requirements for Multifamily Mortgage Loans” dated May 2025. These requirements affect the information that lenders participating in the program will require you to provide.

Chain of Title Schedule

For every Fannie Mae multifamily mortgage loan (including any acquisition, refinance, transfer/assumption, and supplemental mortgage loan), the lender will require a Chain of Title Schedule issued to the proposed Insured to be attached to the title commitment or separately provided to the lender.

A Chain of Title Schedule is defined in Form 4650 as:

"An informational (i.e., information only) schedule attached to the title commitment … (or a separate title report or equivalent document) that identifies and attaches any of the following documents recorded in the [Public Records] during the 3 years prior to the date of the title commitment (and which are not otherwise identified on the title commitment):

• instruments evidencing any property or ownership interest transfers, including:
  • deeds,
  • tax affidavits, and/or
  • other similar lien instruments;
• deeds of trust, mortgages, or similar lien instruments securing debt; and
• releases of deeds of trust, mortgages, or other lien instruments."

Contact the lender if there is a question regarding whether a document should be included in the Chain of Title Schedule. We suggest that you should err on the side of inclusion. For example, the definition does not specifically state “satisfactions,” “reconveyances” or “assignments,” but we suggest that these should be included in the Chain of Title Schedule unless the lender indicates otherwise. 

Required Knowledge Notification

In addition to the Chain of Title Schedule, Fannie Mae requires that the lender’s Closing Instruction Letter for multifamily mortgage loans include the following (or substantially similar) language addressed to both the Funding Agent and Escrow Agent (if different):

"Title Insurance Underwriter and Title Agent (if applicable) must alert the Lender immediately if anyone working on this transaction on behalf of the Title Insurance Underwriter or the Title Agent (if applicable) is aware or becomes aware of any transaction with respect to a transfer of the subject property via deed or a transfer of ownership interests (via assignment of interests or otherwise) that (i) has occurred within the last 36 months and which is not reflected on the title commitment or Chain of Title Schedule delivered to Lender, or (ii) is expected to occur prior to the closing of the Mortgage Loan."

Please be mindful of the above requirements when reviewing the lender’s instructions for Fannie Mae multifamily transactions.

The above requirements are in addition to existing practices and requirements identifying transfers of title within a preceding period, e.g., 24 months, and flip transactions.

A sample form of Chain of Title Schedule is available here.

The full text of Form 4650 is available here.

For reference, Fannie Mae’s Multifamily web page is https://multifamily.fanniemae.com/.

If you have any questions relating to this or other bulletins, please contact a Stewart Title Guaranty Company underwriter.

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