XML 110 R30.htm IDEA: XBRL DOCUMENT v3.25.0.1
Cybersecurity Risk Management and Strategy Disclosure
12 Months Ended
Dec. 31, 2024
Cybersecurity Risk Management, Strategy, and Governance [Line Items]  
Cybersecurity Risk Management Processes for Assessing, Identifying, and Managing Threats [Text Block] Overview
Cybersecurity risk is a key operational risk that we face; therefore, managing cybersecurity risk is an inherent part of our
business activities. We describe the material cybersecurity risks we face in “Risk FactorsOperational and Model Risk.”
Cybersecurity Risk Management Program
We have developed and continue to enhance our cybersecurity risk management program as we seek to protect the
security of our information systems, software, networks and other technology assets against unauthorized attempts to
access confidential information and data or to disrupt or degrade business operations. Our cybersecurity risk
management program has evolved, and continues to evolve, based on the changing needs of our business, the
evolving threat environment and FHFA regulatory guidance.
We design and assess our cybersecurity risk management program based on the National Institute of Standards and
Technology Framework for Improving Critical Infrastructure Cybersecurity (the “NIST Cybersecurity Framework”). While
we generally consult the NIST Cybersecurity Framework when designing and assessing our cybersecurity risk
management program, we have not implemented and do not plan to implement all categories and subcategories
included in the framework. We use the framework as a guide to help us identify, assess and manage cybersecurity risks
relevant to our business based on our current understanding of the cybersecurity threat environment.
Integration into Enterprise Risk Management Framework
Our cybersecurity risk management program is integrated into our overall Enterprise Risk Management framework,
which is described in “MD&A—Risk Management—Overview.” Our Enterprise Response Framework establishes the
reporting structure and escalation process for managing all enterprise incidents, including cybersecurity-related
incidents. The framework defines the relationship and notification steps among the various crisis management
stakeholders, including the Board of Directors, the Management Committee, the President and CEO, other members of
the executive leadership team, the crisis manager and crisis management coordinators. See “Cybersecurity
Governance—Management Role” for a description of the oversight role of the Corporate Risk & Compliance division,
Internal Audit and the management-level Technology Risk Committee and Enterprise Risk Committee relating to
cybersecurity risk management.
Cybersecurity Risk Management Strategy
Overview and Goal. Fannie Mae has a multilayered cybersecurity defense strategy. We take a risk-based approach that
prioritizes the highest impact events. Our cybersecurity threat operations operate with the goal of identifying, preventing,
and mitigating cybersecurity threats and responding to cybersecurity incidents in accordance with incident response and
recovery plans.
Tools and Safeguards. As part of our cybersecurity defense strategy, we employ tools and systems safeguards intended
to help secure our networks, applications, data and infrastructure, and to manage cybersecurity vulnerabilities. These
safeguards include network and perimeter defense, infrastructure security, cloud security, endpoint protection, data
protection, identity management and network segmentation. We work to evaluate and improve on these tools and
safeguards through periodic cybersecurity assessments and the integration of cybersecurity threat intelligence.
Backup Data Storage. We have both internal and external third-party backup data storage to help protect our data from
cybersecurity incidents. We test our backup restoration process on a regular basis.
Response Plans and Procedures. We maintain cybersecurity incident response procedures that identify the activities
and escalation processes to be implemented upon detection of a cybersecurity incident, and we routinely practice these
activities and processes. We also have business and technology continuity plans and a crisis management plan, which
we test on a regular basis.
Training. We provide mandatory cybersecurity training to employees and contractors on an annual basis. We test our
employees’ response to simulated phishing scenarios on a regular basis. We also conduct enhanced training for certain
groups of employees that may pose higher risk.
Assessments. We examine the effectiveness of our cyber defenses through various means, including internal audits,
targeted testing, vulnerability testing, maturity assessments, incident response exercises and industry benchmarking.
Insurance Coverage. We maintain insurance coverage relating to cybersecurity risks. As described in “Risk Factors
Operational and Model Risk,” our insurance may not be sufficient to provide adequate loss coverage.
Role of External Consultants, Vendors and Other Third Parties
We regularly use external consultants and vendors to assist in our assessment and management of cybersecurity risks,
including employing third parties to evaluate the security of our networks and our approach to cybersecurity risk
management, such as external vendors that conduct penetration testing against our network on at least an annual basis
and an external vendor that reviews and tests our cybersecurity incident response plan on at least an annual basis. We
also have external vendors on retainer to assist with cybersecurity incident response activities if requested.
We are also focused on building and maintaining relationships with the appropriate government and law enforcement
agencies and with other businesses, industry groups and cybersecurity services to better understand the cybersecurity
risks in our environment, enhance our defenses and improve our resiliency against cybersecurity threats.
Third-Party Cybersecurity Risk Oversight
Our cybersecurity risk management program extends to oversight of third parties that pose a cybersecurity risk to us,
including lenders that use our systems and third-party service providers. In alignment with the NIST Cybersecurity
Framework and FHFA regulatory guidance, we have established a risk-based framework for managing third-party risk
that defines specified triggers for assessing and reporting cyber-related third-party risks and events. Pursuant to this
framework, we have implemented both preventive and detective controls to mitigate cybersecurity risks posed by third
parties.
We have identified certain third parties that we believe pose a higher cybersecurity risk to us because they have
significant access to our systems or data. For these higher-risk third parties, we have implemented additional
requirements, including:
We assess these higher-risk third parties’ cybersecurity controls through a cybersecurity questionnaire and a
review of their cybersecurity controls, either through independent audits or by direct review of their
cybersecurity policies and practices.
We use third-party cybersecurity monitoring and alert services to monitor these higher-risk third parties.
We conduct periodic monitoring reviews of these higher-risk third parties’ cybersecurity policies and practices.
The Information
Security organization monitors information systems to detect anomalies, including attempted cyber attacks, as well as
user activity for access controls and risks of insider threat. The Information Security organization also monitors and
investigates cybersecurity incidents through detection tools, reports from end users, and other cybersecurity threat and
vulnerability intelligence. The Information Security organization also shares and obtains information on cybersecurity
threats through participation in the Financial Services Information Sharing and Analysis Center, referred to as FS-ISAC,
a member-driven organization that advances cybersecurity and resilience in the global financial system.
As appropriate, multidisciplinary teams are deployed to address cybersecurity threats and to respond to cybersecurity
incidents in accordance with the company’s incident response processes.
Cybersecurity Risk Management Processes Integrated [Flag] true
Cybersecurity Risk Management Processes Integrated [Text Block] Our cybersecurity risk management program is integrated into our overall Enterprise Risk Management framework,
which is described in “MD&A—Risk Management—Overview.” Our Enterprise Response Framework establishes the
reporting structure and escalation process for managing all enterprise incidents, including cybersecurity-related
incidents. The framework defines the relationship and notification steps among the various crisis management
stakeholders, including the Board of Directors, the Management Committee, the President and CEO, other members of
the executive leadership team, the crisis manager and crisis management coordinators. See “Cybersecurity
Governance—Management Role” for a description of the oversight role of the Corporate Risk & Compliance division,
Internal Audit and the management-level Technology Risk Committee and Enterprise Risk Committee relating to
cybersecurity risk management.
Cybersecurity Risk Management Third Party Engaged [Flag] true
Cybersecurity Risk Third Party Oversight and Identification Processes [Flag] true
Cybersecurity Risk Materially Affected or Reasonably Likely to Materially Affect Registrant [Flag] false
Cybersecurity Risk Board of Directors Oversight [Text Block] Board Oversight
The full Board of Directors oversees the company’s cybersecurity risk management, assisted by the Risk Policy and
Capital Committee of the Board. The Board has delegated management-level risk oversight, including for cybersecurity
risk matters, to the Enterprise Risk Committee, as described under “Management Role” below.
The Board and the Risk Policy and Capital Committee generally engage in discussions throughout the year with
management on cybersecurity risk matters. The Chief Security Officer and other members of the management team
provide reports to the Board and the Risk Policy and Capital Committee on cybersecurity risk matters on a regular
basis, including updates on our cybersecurity risk management program, as well as external cybersecurity
developments, threats and risks. Management also discusses cybersecurity developments with the Chair of the Risk
Policy and Capital Committee and other Board members between Board and committee meetings, as appropriate. The
company has procedures to escalate information regarding certain cybersecurity incidents to the Board Chair. At least
annually, the Board reviews and approves the company’s Cybersecurity Risk Policy and Operational Risk Policy.
Cybersecurity Risk Board Committee or Subcommittee Responsible for Oversight [Text Block] The full Board of Directors oversees the company’s cybersecurity risk management, assisted by the Risk Policy and
Capital Committee of the Board. The Board has delegated management-level risk oversight, including for cybersecurity
risk matters, to the Enterprise Risk Committee, as described under “Management Role” below.
As appropriate, multidisciplinary teams are deployed to address cybersecurity threats and to respond to cybersecurity
incidents in accordance with the company’s incident response processes. The Information Security organization and
Corporate Risk & Compliance division are informed about and monitor the prevention, detection and mitigation of
cybersecurity incidents through risk and control assessments, targeted reviews, scenario analysis, and monitoring of
risk metrics. The company’s performance in managing cybersecurity risk is reported to the Technology Risk Committee,
the Enterprise Risk Committee and the Board of Directors.
As noted above, the Board has delegated oversight responsibility at the management level for risk-related matters to the
Enterprise Risk Committee, members of which include senior leaders throughout the company. The Enterprise Risk
Committee has delegated primary responsibility for management-level oversight of cybersecurity risk management to
the Technology Risk Committee. The Technology Risk Committee receives reports on cybersecurity risk matters on a
regular basis from the company’s Chief Security Officer. The Technology Risk Committee reviews and approves the
company’s management-level cybersecurity risk policies and standards. The Technology Risk Committee also reviews
and monitors metrics relating to cybersecurity risk. The Technology Risk Committee escalates matters to the Enterprise
Risk Committee as appropriate.
The company’s Corporate Risk & Compliance division provides risk-based independent oversight of cybersecurity risk
management performed by the Information Security organization. Members of the Corporate Risk & Compliance
division chair the Technology Risk Committee and the Enterprise Risk Committee.
The company’s Internal Audit organization audits the Corporate Risk & Compliance division’s oversight of cybersecurity
risk management and also independently tests the effectiveness of the company’s cybersecurity risk management and
governance. Members of the Internal Audit organization participate as non-voting members of both the Technology Risk
Committee and the Enterprise Risk Committee.
Cybersecurity Risk Process for Informing Board Committee or Subcommittee Responsible for Oversight [Text Block] The Board and the Risk Policy and Capital Committee generally engage in discussions throughout the year with
management on cybersecurity risk matters. The Chief Security Officer and other members of the management team
provide reports to the Board and the Risk Policy and Capital Committee on cybersecurity risk matters on a regular
basis, including updates on our cybersecurity risk management program, as well as external cybersecurity
developments, threats and risks. Management also discusses cybersecurity developments with the Chair of the Risk
Policy and Capital Committee and other Board members between Board and committee meetings, as appropriate. The
company has procedures to escalate information regarding certain cybersecurity incidents to the Board Chair. At least
annually, the Board reviews and approves the company’s Cybersecurity Risk Policy and Operational Risk Policy.
As appropriate, multidisciplinary teams are deployed to address cybersecurity threats and to respond to cybersecurity
incidents in accordance with the company’s incident response processes. The Information Security organization and
Corporate Risk & Compliance division are informed about and monitor the prevention, detection and mitigation of
cybersecurity incidents through risk and control assessments, targeted reviews, scenario analysis, and monitoring of
risk metrics. The company’s performance in managing cybersecurity risk is reported to the Technology Risk Committee,
the Enterprise Risk Committee and the Board of Directors.
As noted above, the Board has delegated oversight responsibility at the management level for risk-related matters to the
Enterprise Risk Committee, members of which include senior leaders throughout the company. The Enterprise Risk
Committee has delegated primary responsibility for management-level oversight of cybersecurity risk management to
the Technology Risk Committee. The Technology Risk Committee receives reports on cybersecurity risk matters on a
regular basis from the company’s Chief Security Officer. The Technology Risk Committee reviews and approves the
company’s management-level cybersecurity risk policies and standards. The Technology Risk Committee also reviews
and monitors metrics relating to cybersecurity risk. The Technology Risk Committee escalates matters to the Enterprise
Risk Committee as appropriate.
The company’s Corporate Risk & Compliance division provides risk-based independent oversight of cybersecurity risk
management performed by the Information Security organization. Members of the Corporate Risk & Compliance
division chair the Technology Risk Committee and the Enterprise Risk Committee.
The company’s Internal Audit organization audits the Corporate Risk & Compliance division’s oversight of cybersecurity
risk management and also independently tests the effectiveness of the company’s cybersecurity risk management and
governance. Members of the Internal Audit organization participate as non-voting members of both the Technology Risk
Committee and the Enterprise Risk Committee.
Cybersecurity Risk Role of Management [Text Block] Our Chief Security Officer leads our Information Security organization, which has primary responsibility for assessing
and managing our cybersecurity risks. Our Chief Security Officer has principal management responsibility for
overseeing the company’s cybersecurity risk management program. Our Chief Security Officer reports to our Chief
Operating Officer.
The Information Security organization works collaboratively across the company to help protect the company’s
information systems from cybersecurity threats and to respond to cybersecurity threats and incidents. The Information
Security organization monitors information systems to detect anomalies, including attempted cyber attacks, as well as
user activity for access controls and risks of insider threat. The Information Security organization also monitors and
investigates cybersecurity incidents through detection tools, reports from end users, and other cybersecurity threat and
vulnerability intelligence. The Information Security organization also shares and obtains information on cybersecurity
threats through participation in the Financial Services Information Sharing and Analysis Center, referred to as FS-ISAC,
a member-driven organization that advances cybersecurity and resilience in the global financial system.
As appropriate, multidisciplinary teams are deployed to address cybersecurity threats and to respond to cybersecurity
incidents in accordance with the company’s incident response processes. The Information Security organization and
Corporate Risk & Compliance division are informed about and monitor the prevention, detection and mitigation of
cybersecurity incidents through risk and control assessments, targeted reviews, scenario analysis, and monitoring of
risk metrics. The company’s performance in managing cybersecurity risk is reported to the Technology Risk Committee,
the Enterprise Risk Committee and the Board of Directors.
As noted above, the Board has delegated oversight responsibility at the management level for risk-related matters to the
Enterprise Risk Committee, members of which include senior leaders throughout the company. The Enterprise Risk
Committee has delegated primary responsibility for management-level oversight of cybersecurity risk management to
the Technology Risk Committee. The Technology Risk Committee receives reports on cybersecurity risk matters on a
regular basis from the company’s Chief Security Officer. The Technology Risk Committee reviews and approves the
company’s management-level cybersecurity risk policies and standards. The Technology Risk Committee also reviews
and monitors metrics relating to cybersecurity risk. The Technology Risk Committee escalates matters to the Enterprise
Risk Committee as appropriate.
The company’s Corporate Risk & Compliance division provides risk-based independent oversight of cybersecurity risk
management performed by the Information Security organization. Members of the Corporate Risk & Compliance
division chair the Technology Risk Committee and the Enterprise Risk Committee.
The company’s Internal Audit organization audits the Corporate Risk & Compliance division’s oversight of cybersecurity
risk management and also independently tests the effectiveness of the company’s cybersecurity risk management and
governance. Members of the Internal Audit organization participate as non-voting members of both the Technology Risk
Committee and the Enterprise Risk Committee.
Cybersecurity Risk Management Positions or Committees Responsible [Flag] true
Cybersecurity Risk Management Positions or Committees Responsible [Text Block] Our Chief Security Officer leads our Information Security organization, which has primary responsibility for assessing
and managing our cybersecurity risks. Our Chief Security Officer has principal management responsibility for
overseeing the company’s cybersecurity risk management program
Cybersecurity Risk Management Expertise of Management Responsible [Text Block] Chief Security Officer
Our Chief Security Officer has over 20 years of professional experience in information security, including over 8 years as
Fannie Mae’s Chief Information Security Officer (2016-2024) and over 1 year as Fannie Mae’s Deputy Chief Information
Security Officer. Our Chief Security Officer holds a graduate degree in information technology management.
Technology Risk Committee
Members of the Technology Risk Committee include officers with expertise in cybersecurity risk oversight, such as the
Chief Security Officer described above and the head of our Technology Risk Oversight department. As of December
2024, several members of the Technology Risk Committee had prior work experience in cybersecurity and several had
a relevant degree or certification, or other knowledge, skills or background in cybersecurity.
Cybersecurity Risk Process for Informing Management or Committees Responsible [Text Block] Our Chief Security Officer leads our Information Security organization, which has primary responsibility for assessing
and managing our cybersecurity risks. Our Chief Security Officer has principal management responsibility for
overseeing the company’s cybersecurity risk management program. Our Chief Security Officer reports to our Chief
Operating Officer.
The Information Security organization works collaboratively across the company to help protect the company’s
information systems from cybersecurity threats and to respond to cybersecurity threats and incidents. The Information
Security organization monitors information systems to detect anomalies, including attempted cyber attacks, as well as
user activity for access controls and risks of insider threat. The Information Security organization also monitors and
investigates cybersecurity incidents through detection tools, reports from end users, and other cybersecurity threat and
vulnerability intelligence. The Information Security organization also shares and obtains information on cybersecurity
threats through participation in the Financial Services Information Sharing and Analysis Center, referred to as FS-ISAC,
a member-driven organization that advances cybersecurity and resilience in the global financial system.
As appropriate, multidisciplinary teams are deployed to address cybersecurity threats and to respond to cybersecurity
incidents in accordance with the company’s incident response processes. The Information Security organization and
Corporate Risk & Compliance division are informed about and monitor the prevention, detection and mitigation of
cybersecurity incidents through risk and control assessments, targeted reviews, scenario analysis, and monitoring of
risk metrics. The company’s performance in managing cybersecurity risk is reported to the Technology Risk Committee,
the Enterprise Risk Committee and the Board of Directors.
As noted above, the Board has delegated oversight responsibility at the management level for risk-related matters to the
Enterprise Risk Committee, members of which include senior leaders throughout the company. The Enterprise Risk
Committee has delegated primary responsibility for management-level oversight of cybersecurity risk management to
the Technology Risk Committee. The Technology Risk Committee receives reports on cybersecurity risk matters on a
regular basis from the company’s Chief Security Officer. The Technology Risk Committee reviews and approves the
company’s management-level cybersecurity risk policies and standards. The Technology Risk Committee also reviews
and monitors metrics relating to cybersecurity risk. The Technology Risk Committee escalates matters to the Enterprise
Risk Committee as appropriate.
The company’s Corporate Risk & Compliance division provides risk-based independent oversight of cybersecurity risk
management performed by the Information Security organization. Members of the Corporate Risk & Compliance
division chair the Technology Risk Committee and the Enterprise Risk Committee.
The company’s Internal Audit organization audits the Corporate Risk & Compliance division’s oversight of cybersecurity
risk management and also independently tests the effectiveness of the company’s cybersecurity risk management and
governance. Members of the Internal Audit organization participate as non-voting members of both the Technology Risk
Committee and the Enterprise Risk Committee.
Cybersecurity Risk Management Positions or Committees Responsible Report to Board [Flag] true