Fannie Mae RSU continuance now starts at application for one-time awards
The October update changes which date anchors three years of expected vesting for a time-based, one-time award.
What changed
Under the updated section, a one-time time-based award needs documented vesting expected to continue at least three years from the application date. The prior version measured that period from the note date. Recurring time-based awards and performance-based awards need their own continuance analysis.
An example
If application is September 1 and the note is September 30, the two methods can produce required vesting-through dates nearly a month apart. Run the same award under the review date applicable to the loan file and keep both actual dates.
What stays separate
Vesting into the future supports continuance. It does not add shares to historical income. Use qualifying distributions already vested and received, the pretax amount, and the documented 200-day moving average for shares. Check award eligibility and history separately.