Because Illinois has no statutory reserve-study requirement — only the open-ended “reasonable reserves” standard at 765 ILCS 605/9(c)(2). The bills that would have created one died at spring adjournment.

So the sequence is: the legislature declined to require reserve studies in June, and from August a budget that does not reflect a study's highest recommended reserve allocation puts the building's units at risk of becoming unwarrantable.

Unwarrantable is not an abstraction. It means conventional financing becomes unavailable for units in the building — which hits resale value and refinancing for every owner, not only the ones causing the problem. A board that underfunds reserves is now making a decision about its neighbours' equity.

The four failure points for an Illinois association

1. No reserve study, or a stale one. With Limited Review retired, far more Illinois projects go to Full Review, where the study is examined. A building that has never commissioned one is starting from zero.

2. A budget that ignores the study's top recommendation. This is the common case and it is the one boards find hardest, because the study's highest recommendation is usually the number the board rejected as politically impossible.

3. A master-policy deductible above $50,000 per unit. Deductible-raising is the standard response to a hard market and to renewals the state's new rate-review authority most likely does not reach. It now has a ceiling set by the mortgage market.

4. Delinquencies above 15%. Which makes the new written collection policy requirement load-bearing in a way its drafters may not have intended: from January 1, 2027 an Illinois association cannot lawfully take legal action on unpaid assessments without an adopted, followed collection policy — and a board that cannot collect is a board whose building fails project review.

The advocacy fight, and where it stands

CAI opposes the reserve-funding changes, arguing they raise borrower costs and shrink financing availability, and listed a one-year delay of the Fannie Mae and Freddie Mac questionnaire updates among its 2026 federal priorities published August 6, 2026 ahead of its September 24 Congressional Advocacy Summit.³

Note the position that produces: the same organisation drafted and carried Illinois's reserve-study mandate in Springfield and is lobbying to delay the reserve requirements arriving through the mortgage market. Both positions are coherent — a statutory five-year study is a different instrument from a lender-imposed funding percentage — and the delay campaign, if it succeeds, buys time rather than removing the requirement.

What a board can do this quarter

Find out whether the association has a current reserve study and what its highest recommended allocation is. Compare that to the adopted budget. Check the master policy's per-unit deductible against $50,000, and the delinquency rate against 15%.

Four numbers. Any board can get them in a week, and they now determine whether owners can sell.

What to watch next

Whether FHFA or Congress grants the requested one-year delay, and the January 2027 step from 10% to 15%.