On August 3, 2020, Fannie Mae updated its COVID-19 servicing FAQs to add an FAQ regarding a COVID-19 forbearance plan with a period of less than 180 days. The FAQ says:

Q: If a servicer provides a COVID-19 related forbearance plan with an incremental period shorter than 180 days, and the servicer is unable to achieve QRPC prior to the expiration of such incremental period, can the servicer automatically extend the forbearance period?

A: Servicers are responsible for complying with the requirements of Lender Letter LL-2020-02, Impact of COVID-19 on Servicing and applicable law, including the CARES Act, when providing borrowers with an initial or extended forbearance plan.

Fannie Mae updated Lender Letter 2020-02 on July 15, 2020.