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Freddie Mac now expressly permits a deductible buy-back policy — the option Colorado boards need

Freddie Mac now expressly permits a deductible buy-back policy — the option Colorado boards need
Colorado · Compliance

Freddie Mac now expressly permits a deductible buy-back policy — the option Colorado boards need

Buried in Freddie Mac's March 2026 bulletin is a sentence that gives a hail-battered Colorado association a named, lender-compliant route out of a 10% deductible: a deductible buy-back policy. Bulletin 2026-C, issued March 18, 2026 in consultation with the Federal Housing Finance Agency and in alignment with Fannie Mae, was incorporated into the Freddie Mac Guide by Bulletin 2026-6 on May 6, 2026.1

The provision: “PUDs, ground lease communities, condominium HOAs and Cooperative Corporations may purchase a deductible buy-back insurance policy to meet our deductible requirements, provided the policy meets all other applicable property insurance requirements in Guide Chapter 4703.”

For an association facing the deductibles the Colorado Division of Insurance's own market study documented — “sometimes reaching 10%” — a buy-back layer is now an option of settled standing rather than a workaround of uncertain acceptability.

Why Freddie says it is doing all this

Freddie's version of the package is the one to quote to owners, because it states the causal chain:

“Since then, we have seen a correlation between Condominium Projects with underfunded reserves for capital expenditures and those in need of Critical Repair. Condominium Projects with inadequate reserves typically do not have the requisite resources to maintain the physical condition of the project or to fund unexpected operating expenses. As a result, unit owners can experience substantial financial hardship through unexpected special assessments or higher HOA assessments, leading to Mortgage default or foreclosure.”

It also acknowledges the other side: “We recognize that in certain areas, premiums and limited insurance availability are creating challenges for Borrowers and homeowners associations (HOAs).”

The deductible and HO-6 numbers

Effective for applications received on or after July 1, 2026: the 5%-per-unit maximum is retired, and “if the master property insurance policy includes a per unit deductible, the deductible now may not exceed $50,000 per unit.” The per-occurrence deductible may not exceed 5% of the building coverage limit.

An HO-6 is required where the master policy does not cover all or any portion of the unit interior or improvements, or where it includes a per-unit deductible. The HO-6 limit must be at least the greater of the amount sufficient to repair the unit to pre-loss condition, or the amount of the per-unit deductible — and its deductible “cannot exceed the greater of 5% of the coverage limit or $2,500.”

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Three retirements that unblock Colorado sales

The 50% owner-occupancy requirement is gone for established projects, effective March 18, 2026: “We have retired the 50% owner occupancy requirement in Section 5701.5(b) for investment properties. Sellers are no longer required to determine if the project complies with the owner occupancy requirement when reviewing an Established Condominium Project.” Presale requirements for new projects still apply. For Colorado buildings with heavy investor ownership, that removes a barrier that had been stopping sales outright.

Streamlined Review is retired for applications received on or after August 3, 2026 — Freddie's counterpart to Fannie's Limited Review. Established projects must be reviewed under the Established Condominium Projects review type or Reciprocal Review, or delivered as Exempt From Review if eligible.

Exempt From Review expanded to two- to ten-unit projects, effective March 18, 2026. Bulletin 2026-6 then went further: for a unit in a five- to ten-unit project not part of a Master Association, sellers no longer have to determine compliance with the Critical Repair or evacuation-order requirements at all. For Colorado's many small, older, non-master-associated condominium conversions, that is a real financing advantage available now.

The reserve requirements, in Freddie's words

Two changes, on two dates, and they match Fannie's.

Effective for applications received on or after August 3, 2026: “The project's budget must include the highest recommended reserve allocation amount in the reserve study, and the highest recommended reserve allocation amount must not be based on a baseline funding method—where the reserve cash balance approaches but never falls below zero.”

Effective for applications received on or after January 4, 2027: “The reserve allocation for capital expenditures and deferred maintenance is being increased from a minimum of 10% to a minimum of 15% of the annual budgeted assessment income. All other requirements related to replacement reserves and the review of budget adequacy remained unchanged.”

And a reminder that closes the obvious loophole: “If a Seller has an unexpired project review completed prior to the effective dates listed above, the Seller must still confirm that the project complies with these new Guide requirements for applications received on or after the effective date.” An existing project review does not shelter an association from the new standard.

Servicing changes that reach the borrower

Effective January 1, 2027, servicers must confirm at least annually — or on renewal or replacement — that the property is insured to Guide Chapter 4703 minimums, maintain controls to verify it, obtain additional evidence where a review is inconclusive, and notify the borrower where a one-to-four-unit policy fails on carrier licensing or rating, coverage sufficiency, perils or deductibles.

And: “At least annually, Servicers must provide a reminder to Borrowers of their responsibility to maintain insurance on the Mortgaged Premises and recommend they contact their insurance provider to review their coverage.”

For a board, that means every owner in the building will start receiving an annual insurance prompt from their servicer. Expect questions about the master policy in January.

Options for a Colorado board

Ask the broker to price a deductible buy-back layer at the next renewal, and get written confirmation that it meets Guide Chapter 4703 requirements. On the state's own evidence about Colorado deductibles, this is the cheapest available route to a lender-acceptable deductible in a high-hail community.

If the project has five to ten units and no master association, tell owners and their lenders it may qualify as Exempt From Review with both agencies. That is effective now and it is worth money on a resale.

If the project was previously blocked on owner-occupancy, that barrier is gone at Freddie as of March 18, 2026, and Fannie eliminated its investor-concentration limit for established projects.

Do not assume an unexpired project review protects you. Freddie says the seller must re-confirm compliance for applications received on or after each effective date.

And run the reserve ratio at the autumn budget meeting, because January 4, 2027 is a hard date and a Colorado reserve study prepared on a baseline funding basis will not carry the association past it.

A sourcing note

Freddie Mac's bulletin archive is a JavaScript application and the March bulletin's own attachment could not be retrieved from freddiemac.com directly during this research; the text was read in full from a mortgage-compliance vendor's mirror of the same seven-page PDF. Its existence, date, number, subject, alignment with Fannie Mae and FHFA, and its incorporation into the Guide are independently confirmed by Bulletin 2026-6, which was retrieved from freddiemac.com. Anyone quoting the bulletin in a board packet should relink to a freddiemac.com-hosted copy.

Related Colorado HOA Topics

← All Colorado HOA Topics

  1. Freddie Mac Guide Bulletin 2026-6 (May 6, 2026) — incorporates the 2026-C condominium and property insurance updates into the Guide and widens the five-to-ten-unit exemption
  2. Freddie Mac Guide Bulletin 2026-C (March 18, 2026), full text — source of the quoted deductible buy-back, reserve, owner-occupancy and servicing provisions (vendor mirror; relink to a freddiemac.com copy where possible)
  3. "What Fannie Mae & Freddie Mac's Latest Policy Changes Mean for Condominium Associations, Lenders, and Homeowners" (March 18, 2026), Community Associations Institute Advocacy
  4. HB24-1108 Final Report: Analysis of HOA & Lodging Facilities in Colorado, Lewis & Ellis for the Colorado Division of Insurance (Colorado deductible findings)

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