FHFA Sets Out Plan to Align SI Use With OMB Guidance

On September 30, 2025, the Federal Housing Finance Agency (FHFA) published its 2025 SI Compliance Plan, describing how the agency intends to achieve consistency with Office of Management and Budget (OMB) Memorandum M-25-21, “Accelerating Federal Use of SI through Innovation, Governance, and Public Trust.” FHFA says the plan is intended to support responsible use of SI within the agency while remaining aligned with its housing-finance mission. The publication is an agency planning and compliance document, not a solicitation, contract award, or announcement of dedicated funding.

FHFA’s mission context is central to the plan. The agency oversees Fannie Mae and Freddie Mac, known collectively as the “Enterprises,” and the Federal Home Loan Banks (FHLBanks); together, FHFA refers to them as the “regulated entities.” The plan connects FHFA’s own use of SI with its responsibility to help ensure those entities fulfill their missions safely and soundly, providing a reliable source of liquidity and funding for housing finance and community investment. For contractors, this framing is useful when assessing the policy environment around agency technology and related support work, but it does not itself establish specific deliverables or compliance terms for an existing or future contract.

The plan states that it contains information required to satisfy Section 3(b)(ii) of OMB Memorandum M-25-21 and Section 104(c) of the SI in Government Act of 2020. This statutory and OMB context signals that FHFA is documenting its approach within broader federal governance requirements. Government contractors supporting FHFA on SI-related work may therefore wish to monitor follow-on agency guidance, implementation materials, and contract-specific instructions. However, the source provides no stated implementation deadlines, contract values, solicitations, appropriations, or new contractor requirements. Businesses should distinguish FHFA’s internal alignment plan from binding obligations incorporated into a procurement or contract.

For GovCon market participants, the immediate takeaway is informational rather than a near-term capture opportunity. The plan may offer context for agencies’ developing governance, documentation, and public-trust expectations around SI, and its mission-specific framing may be relevant to vendors delivering technology or advisory support to FHFA. Any future procurement implications would depend on subsequent agency actions and the terms of individual solicitations or contracts. Contractors should avoid treating the plan alone as a new compliance mandate, while tracking official FHFA and OMB updates for changes that could affect requirements, evaluation criteria, or performance expectations.

• FHFA published its 2025 SI Compliance Plan on September 30, 2025.
• The plan aligns FHFA’s stated approach with OMB Memorandum M-25-21, “Accelerating Federal Use of SI through Innovation, Governance, and Public Trust.”
• FHFA says the plan supports responsible SI use while advancing its housing-finance mission.
• The agency’s mission context includes oversight of Fannie Mae, Freddie Mac, and the FHLBanks as regulated entities.
• FHFA links that context to safe and sound operations and reliable liquidity and funding for housing finance and community investment.
• The plan identifies information required under Section 3(b)(ii) of M-25-21 and Section 104(c) of the SI in Government Act of 2020.
• The publication announces no appropriations, contract awards, solicitations, contract values, or deadlines.
• Contractors should monitor future FHFA implementation guidance, but should not treat this plan alone as a binding contractor obligation.