source:
  type: regulation
  id: fnma-sel-b3-4-1-04
  authority: FNMA Selling Guide B3-4.1-04 — Virtual Currency
  description: 'FNMA Selling Guide B3-4.1-04 governs the use of virtual currency (cryptocurrency) as part of the asset-assessment process: virtual currency exchanged into U.S. dollars is acceptable for down payment, closing costs, and reserves only with documented USD exchange, custody in a U.S./state-regulated financial institution, and USD verification before closing; large deposits from virtual currency require documentation tracing funds to the borrower account; virtual currency may not be used for earnest money. Companion to B3-3.1-01 (crypto income excluded).'
obligations:
- id: fnma-sel-b3-4-1-04-virtual-currency-funds-conditions
  canonical_id: fnma-sel-b3-4-1-04-virtual-currency-funds-conditions
  section: FNMA Selling Guide B3-4.1-04 — Virtual currency usable for down payment/costs/reserves only after USD conversion + documentation
  description: Virtual currency that has been exchanged into U.S. dollars is acceptable for the down payment, closing costs, and financial reserves ONLY if there is documented evidence it was exchanged into U.S. dollars, it is held in a U.S. or state regulated financial institution, and the funds are verified in U.S. dollars prior to loan closing.
  type: do
  audit_question: For every loan where crypto-sourced funds are used for down payment, closing costs, or reserves, can [LENDER] evidence (a) the virtual currency was exchanged into U.S. dollars, (b) it is held in a U.S. or state regulated financial institution, and (c) the funds were verified in U.S. dollars prior to closing?
  workflow_phase: loan_origination
  owner_role: underwriting_manager
  secondary_owner_role: loan_processor
  cadence: per-loan-with-crypto-funds
  consequence: Counting crypto-sourced funds without the B3-4.1-04 conditions is a Selling Guide breach + R&W exposure.
  tags:
  - crypto
  - fnma
  - selling-guide
  - virtual-currency
  - asset-assessment
  - source-of-funds
  - promoted
  primary_source:
    tier: 1
    authority: FNMA Selling Guide B3-4.1-04 — Virtual Currency
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: there is documented evidence that the virtual currency has been exchanged into U.S. dollars and is held in a U.S. or state regulated ﬁnancial institution, and the funds are veriﬁed in U.S. dollars prior to the loan closing.
    drafter_attestation: Copied verbatim from snapshot 5f7b8b79da595d76. B3-4.1-04 funds-eligibility conditions (USD exchange + regulated-FI custody + USD verification before closing).
  program_review: Do the P&Ps ensure virtual currency counts toward down payment, closing costs, or reserves only after it is exchanged into U.S. dollars, documented as exchanged, held in a U.S. or state regulated financial institution, and verified in U.S. dollars before closing?
  file_review: On files with crypto-sourced funds, confirm the USD-exchange evidence, regulated-FI custody, and USD verification before closing.
  judgment: false
- id: fnma-sel-b3-4-1-04-large-deposit-virtual-currency-documentation
  canonical_id: fnma-sel-b3-4-1-04-large-deposit-virtual-currency-documentation
  section: 'FNMA Selling Guide B3-4.1-04 — Large deposit from virtual currency: document funds originated from borrower virtual currency account'
  description: When a large deposit may be from virtual currency that was exchanged into U.S. dollars, [LENDER] (lender) must obtain sufficient documentation to verify the funds originated from the borrower's virtual currency account.
  type: do
  audit_question: For every large deposit that may be from virtual currency exchanged into U.S. dollars, can [LENDER] produce sufficient documentation verifying the funds originated from the borrower's virtual currency account?
  workflow_phase: loan_origination
  owner_role: underwriting_manager
  secondary_owner_role: loan_processor
  cadence: per-loan-with-crypto-funds
  consequence: Counting crypto-sourced funds without the B3-4.1-04 conditions is a Selling Guide breach + R&W exposure.
  tags:
  - crypto
  - fnma
  - selling-guide
  - virtual-currency
  - large-deposit
  - source-of-funds
  - promoted
  primary_source:
    tier: 1
    authority: FNMA Selling Guide B3-4.1-04 — Virtual Currency
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: A large deposit may be from virtual currency that was exchanged into U.S. dollars. The lender must obtain suﬃcient documentation to verify the funds originated from the borrower's virtual currency account.
    drafter_attestation: Copied verbatim from snapshot 5f7b8b79da595d76. B3-4.1-04 large-deposit virtual-currency documentation requirement.
  program_review: Does the program ensure that when a large deposit may be from virtual currency exchanged to USD, the lender obtains sufficient documentation tracing the funds to the borrower's virtual currency account?
  file_review: For large deposits flagged as possibly crypto-sourced, confirm documentation tracing the funds to the borrower's virtual currency account; the compliance person judges whether it sufficiently establishes origin.
  judgment: true
- id: fnma-sel-b3-4-1-04-no-virtual-currency-earnest-money
  canonical_id: fnma-sel-b3-4-1-04-no-virtual-currency-earnest-money
  section: FNMA Selling Guide B3-4.1-04 — Virtual currency may not be used for earnest-money deposit
  description: Virtual currency may not be used for the deposit on the sales contract (earnest money) for the purchase of the subject property.
  type: refrain
  audit_question: For every purchase transaction, can [LENDER] evidence that the earnest-money deposit on the sales contract was not funded with virtual currency?
  workflow_phase: loan_origination
  owner_role: underwriting_manager
  secondary_owner_role: loan_processor
  cadence: per-purchase-loan
  consequence: Counting crypto-sourced funds without the B3-4.1-04 conditions is a Selling Guide breach + R&W exposure.
  tags:
  - crypto
  - fnma
  - selling-guide
  - virtual-currency
  - earnest-money
  - source-of-funds
  - promoted
  primary_source:
    tier: 1
    authority: FNMA Selling Guide B3-4.1-04 — Virtual Currency
    source_class: fnma-guide
    source_url: https://singlefamily.fanniemae.com/media/document/pdf/selling-guide
    snapshot_id: 5f7b8b79da595d76
    fetched_at: '2026-05-25T14:09:57Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: Virtual currency may not be used for the deposit on the sales contract (earnest money) for the purchase of the subject property.
    drafter_attestation: Copied verbatim from snapshot 5f7b8b79da595d76. B3-4.1-04 earnest-money prohibition.
  program_review: Does the program prevent virtual currency from being used for the earnest-money deposit on the sales contract?
  file_review: Confirm the earnest-money deposit was not funded directly from virtual currency.
  judgment: false
_promotion_history:
- promoted_at: '2026-06-08T00:00:00+00:00'
  candidate_path: direct-from-snapshot
  candidates_promoted: 3
  candidates_skipped_existing: 0
