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Maryland requires a reserve study every five years. Fannie Mae will want one every three

Maryland requires a reserve study every five years. Fannie Mae will want one every three
Maryland · Compliance

Maryland requires a reserve study every five years. Fannie Mae will want one every three

What happened. Fannie Mae and Freddie Mac rewrote their condominium project standards in Lender Letter LL-2026-03, issued 18 March 2026, and one of the changes creates a mismatch with Maryland law that boards have not had to think about before.

From 4 January 2027, the agencies' reserve requirement for a Full Review rises from a minimum of 10 percent to 15 percent of annual budgeted assessment income — unless the association has a reserve study completed or updated within the last three years and is funding at the highest recommended level.1

Maryland requires an updated reserve study at least every five years.2 An association on a strictly five-year cycle is in full compliance with state law and, for two years out of every five, outside the exception that avoids the 15 percent budget line.

The sourcing caveat, stated up front

Fannie Mae's servers refuse automated retrieval of the lender letter itself. We could not read the primary document. The $50,000 per-unit master-policy deductible cap is verified from Fannie Mae's own Selling Guide B7-3-03, which states that “the maximum allowable per unit deductible for all required property insurance perils covered by a master property insurance policy is $50,000 per unit,” as is the expanded waiver of project review for projects of ten or fewer units.3

The 10-to-15 percent reserve change, the 4 January 2027 date and the elimination of Limited Review are reported consistently by three independent readings — CAI's advocacy arm, a Maryland law firm's client alert, and a working Ocean City broker — but not read at source here.145 Anyone acting on the percentages should pull the letter directly.

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The dates, in order

The changes phase in across roughly nine months:14

  • 18 March 2026, immediately: the 50 percent investor-concentration cap dropped for Full Reviews; the Florida-specific review for new attached construction retired; waiver of project review expanded to projects of ten or fewer units (standalone only — a 5-to-10-unit project must not be part of a master association or larger development), with liability and fidelity insurance not required for projects qualifying for the waiver.
  • 1 July 2026: master-policy insurance changes — the $50,000 per-unit deductible cap, removal of the inflation-guard requirement, elimination of strict replacement-cost documentation, and removal of the roof full-replacement-cost mandate.
  • 3 August 2026: Limited Review eliminated for established projects over ten units. CAI reports Limited Review historically accounted for roughly 40 percent of project reviews.
  • 1 January 2027: new servicer duties — annual insurance verification, monitoring for coverage reductions, annual borrower reminders.
  • 4 January 2027: the reserve minimum rises to 15 percent.

Two of those dates have already passed. The Limited Review change took effect five weeks ago.

Why the three-versus-five mismatch actually bites

Maryland's reserve regime has a staggered history, and it puts different counties at different points in the cycle.

House Bill 107 of 2022 — Chapter 664, effective 1 October 2022 — took statewide a regime that had begun locally, and set initial-study deadlines of 1 October 2021 for Prince George's County, 1 October 2022 for Montgomery County, and 1 October 2023 for everywhere else. Updates are then required at least every five years.2

Run the arithmetic against a three-year GSE window:

  • A Prince George's County association that complied at the 2021 deadline is due for its first statutory update now, in 2026 — and its 2021 study is already well outside three years.
  • A Montgomery County association that complied in 2022 is due statutorily in 2027, and is outside the three-year window today.
  • An association elsewhere in Maryland that complied at the 2023 deadline is statutorily fine until roughly 2028 — and falls outside the GSE three-year window in 2026.

So on 4 January 2027 a large share of Maryland condominiums that are entirely compliant with Maryland law will not qualify for the exception, and will need 15 percent of budgeted assessment income going to reserves for their units to be financeable on a Full Review.

There is a second trap in the exception's wording. It requires funding at the highest recommended level — and the baseline funding method, which permits reserve balances to approach zero, does not qualify.5 Maryland's own statute permits a funding plan using a recognised method, baseline included. An association can therefore satisfy state law with a baseline plan and still fail the GSE test on two counts at once.

Why this is a price story, not a paperwork story

The mechanism runs: reserve shortfall → project review failure → units not financeable on conventional terms → a smaller buyer pool → lower prices. None of it requires a Maryland statute to change.

The market is already slower where Maryland's condominium stock concentrates. In Worcester County — Ocean City and the coast — the median time to sell in July 2026 was 51 days against 39 a year earlier, with 4.7 months of inventory, while the statewide figures were 14 days and 3.0 months.6 Those are all-property-type figures; Maryland REALTORS does not break out condominiums. But the direction is consistent with what brokers on the coast describe.

A working Ocean City broker's summary of the new rules is the plainest statement of the practical effect: from August 2026, essentially every condo loan in a building over ten units requires a full review of the association's finances, and “the financial strength and documentation of the condominium association” is now decisive, with buyers needing to start financing earlier.5

The one piece of good news on insurance

The $50,000 per-unit deductible cap cuts the other way for many associations, because it legitimises a deductible level the market has been pushing toward anyway. An Eastern Shore broker advising Maryland associations has described current market deductibles as “at least $25,000, if not higher” where claim history or building age makes it a renewal condition.7

That intersects with Maryland's own new law. Chapter 717 of 2026 raises a unit owner's responsibility for the association's deductible to the lowest of actual cost, the deductible, or $25,000, and mandates unit-owner coverage — from 1 October 2027. So the GSE cap permits a $50,000 association deductible while Maryland caps the owner's share of it at $25,000, leaving the balance with the association. Boards setting deductibles in the 2027 budget cycle are choosing where that line falls.

What to watch next

The 1 December 2026 report. Maryland's housing department must tell the General Assembly, building by building, the difference between what each older condominium's reserve fund holds and what it is required to hold. It arrives one month before the 15 percent floor takes effect, and it is the first official measure of how many Maryland associations are on the wrong side of both tests at once.

Also worth watching: whether anyone proposes aligning Maryland's five-year update cycle with the GSE three-year window. It would be a one-line amendment, no state cost, and it is the sort of technical fix Maryland has repeatedly declined to pass — four reserve bills died this session and the 2025 election law's cleanup died in both chambers.

Related Maryland HOA Topics

← All Maryland HOA Topics

  1. Dawn Bauman, CAI Advocacy, 18 March 2026 — Fannie Mae Lender Letter LL-2026-03 and the Freddie Mac bulletin: the 10-to-15 percent reserve change effective 4 January 2027, the three-year reserve study exception at the highest recommended funding level, and Limited Review elimination on 3 August 2026
  2. Maryland Code, Real Property § 11-109.4 — the reserve study requirement and the at-least-every-five-years update cycle, with the staggered initial deadlines established by Chapter 664 of 2022
  3. Fannie Mae Selling Guide B7-3-03, Master Property Insurance Requirements for Project Developments — the $50,000 per-unit maximum allowable deductible, as published
  4. Claudia Lopez-Knapp, Whiteford Taylor Preston, 4 May 2026 — client alert on the Fannie Mae project standards and property insurance changes, noting the standards contain no Maryland-specific provisions
  5. Lauren Bunting, OC Today-Dispatch, 13 August 2026 — the practical effect on the Ocean City market, including the disqualification of the baseline funding method and the requirement to fund at the highest recommended amount
  6. Maryland REALTORS, Housing Statistics July 2026 (data from Bright MLS, current as of 6 August 2026) — Worcester County median days on market 51 versus 39, 4.7 months of inventory, against statewide 14 days and 3.0 months; all property types, not condominium-only
  7. Melissa Esham, Deeley Insurance Group, 26 December 2025 — Eastern Shore broker's account of current Maryland association master-policy deductible levels and the deductible history from $5,000 to $10,000 in 2020

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