VTCDO by Hawksroost  ·  Episode 4 Reference Document

The Two-Deadline Exposure Map

Three-page reference document

Two binding AI obligations took effect in the same week. This document separates what each one actually requires from what the Digital Omnibus moved, and gives executives a structured way to determine whether either clock is running on their organization or portfolio.

• Page 1 EU AI Act Article 50 transparency obligations now in force (August 2, 2026), mapped by legal role: provider and deployer duties, Digital Omnibus timeline, Annex III deferral to December 2027, and the December 2026 grace period for systems already on market.
• Page 2 Fannie Mae Lender Letter LL-2026-04 effective August 6, 2026: five governance requirements for AI/ML use in single-family mortgage origination and servicing, with correct scoping of the 36-hour notification obligation.
• Page 3 Does This Apply to You? Three scope questions with YES and NO/UNSURE paths for Fannie Mae coverage, EU AI Act territorial reach under Article 2, and PE portfolio exposure.