If youâre a mortgage lender or servicer, the phrase ‘bulletin’ usually means more paperwork or a shift in underwriting guidelines. But Freddie Mac Bulletin 2025-13 is a different beast entirely. As of January 1, 2026, the grace period for ‘getting around to it’ has officially ended.
The regulatory hammer has dropped, and itâs not just about having a firewall or some antivirus software anymore. Freddie Mac is now mandating annual independent penetration testing.
Why the Heat? Authority and Risk Contagion
As a Government-Sponsored Enterprise (GSE), Freddie Mac holds the keys to the kingdom. If you canât sell your loans to them, your business model likely collapses. By setting a hard deadline of January 1, 2026, they are asserting regulatory authority to force an industry-wide security lift.
In 2024 and 2025, we saw a massive spike in supply-chain attacks. Cybercriminals realized that if they canât break into the GSEs directly, they can break into the thousands of smaller brokers and lenders connected to them. To Freddie Mac, your weak password is their security breach.
Penetration Testing: The 2026 Requirement
The core of Bulletin 2025-13 update focuses on ensuring that any system that stores, processes, or transmits ‘Confidential Information’ or ‘Protected Information’ (NPI) is battle-tested.
What Actually Counts as a “Pentest” Under the New Rules?
A common mistake we see is a firm thinking their monthly ‘vulnerability scan’ fulfills the requirement. It doesnât.
- Vulnerability Scanning (Automation Only): This is like a security guard walking around your building and checking if any doors are unlocked. Itâs a good start, but it misses sophisticated entry points.
- Penetration Testing (Ethical Hacking): This is like hiring a professional locksmith to see if they can pick the lock. It involves human intelligenceâexperts who actively try to bypass your defenses, exploit misconfigurations, and pivot through your network.
Freddie Mac Bulletin 2025-13 specifically requires the latter. And it must be independent. This means your internal IT guy or your standard “helpdesk-only” MSP cannot be the one to grade their own homework.
What the Audit Expects to See
When the auditors come knocking, they aren’t just looking for a “pass” certificate. They want to see:
- A Detailed Executive Summary: A high-level view of what was tested and what was found.
- A Clear Scope: Confirmation that all systems handling Freddie Mac data or connecting to Freddie Mac systems were included.
- Remediation Tracking: Proof that you didn’t just find holesâyou plugged them. If a pentest finds a ‘Critical’ or ‘High’ risk vulnerability, you need a documented path to resolution.
Incident Response: Can You Prove It?
The 2026 requirements also emphasize incident response testing. Freddie Mac wants to know:
- Do you have a written Incident Response Plan (IRP)?
- Have you tested it in the last 12 months? (e.g., via a Tabletop Exercise).
- Can you prove your staff knows what to do if they see a suspicious wire transfer request?
The Ninja Advantage: Audit-Ready Security
At US Tech Ninja, we don’t just “run a tool.” We provide the comprehensive, independent oversight that Freddie Mac requires. We understand the specific tech stack of the mortgage industryâfrom LOS integrations to secure email workflows.
Don’t wait for a ‘Notice of Finding’ or a failed audit to realize your security isn’t up to 2026 standards.
Three Steps to Compliance:
- Perform a Gap Analysis: See where you stand against Bulletin 2025-13 today.
- Schedule Your Independent Pentest: Get your 2026 certificate and executive summary ready for review.
- Run a Tabletop Exercise: Test your Incident Response Plan with our team to ensure you’re battle-ready.
We aren’t just another faceless helpdesk. We are a boutique firm that specializes in the high-stakes world of mortgage and real estate security.
Book a Freddie Mac Compliance Consultation or Penetration Test with US Tech Ninja today.
