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FHA did not follow Fannie and Freddie, and that now matters in Michigan

FHA did not follow Fannie and Freddie, and that now matters in Michigan
Michigan · Regulation

FHA did not follow Fannie and Freddie, and that now matters in Michigan

What happened. Nothing at FHA — which, this year, is the finding. While Fannie Mae and Freddie Mac overhauled condominium project standards in March 2026, the Federal Housing Administration left its own framework untouched.

A review of the Mortgagee Letters issued in 2024, 2025 and 2026 turns up no revision to condominium project approval. The 2026 letters are elsewhere: ML 2026-02 (22 January, sale of beneficial interest and declarations of trust), ML 2026-03 (29 January, foreclosure bidding and CWCOT), and ML 2026-09 and 2026-10 (23 June, mortgagee approval and quality control).

What still governs

The 2019 condominium rule and Handbook 4000.1 — project approval at II.A.8.p.iii, single-unit approval at II.C — with Form HUD-9992 as the project questionnaire.1

The standing thresholds are unchanged: 50% owner-occupancy (35% in limited low-risk cases with added oversight), a 50% cap on FHA-insured concentration, a three-year approval term requiring recertification, and commercial or non-residential space generally capped at 35% of floor area, up to 49% with documentation.

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Where the two regimes now part company

As of 2026 a Michigan condominium project can be:

  • Ineligible for conventional financing because its reserve allocation is below 15% of budgeted assessment income from 4 January 2027, or because its master-policy per-unit deductible exceeds $50,000, or because it lost its light-touch review path on 3 August 2026 — and still FHA-approvable, because none of those standards exists in Handbook 4000.1.
  • Or the reverse: eligible conventionally but not FHA-approvable, because owner-occupancy has fallen below 50% — a threshold Fannie Mae has now abandoned entirely, having eliminated its 50% investment-property concentration limit.

Those are genuinely different failure modes, and until this year they broadly moved together.

Why the divergence favours Michigan

Michigan's condominium stock skews old, small, suburban and inexpensive — the profile that struggles most with a 15% reserve floor and a capped deductible, and the profile that FHA buyers actually buy.

For a Michigan association with an underfunded reserve and an ageing roof, FHA approval is now the more forgiving path, and for many projects it will be the path that keeps a functioning resale market. That is a genuine reversal: FHA approval has historically been treated as the harder, fussier option that small boards skipped.

What a board can do about it

  1. Find out whether the project is currently FHA-approved, and if so when the three-year term expires. Recertification lapses quietly and nobody tells the board.
  2. Check owner-occupancy against the 50% line. This is the threshold Michigan projects with heavy investor ownership fail, and it is now the FHA-specific risk rather than a shared one.
  3. Consider single-unit approval. Where the project as a whole cannot be approved, FHA's single-unit approval route at Handbook 4000.1 II.C can keep individual sales alive.
  4. Do not treat FHA as a substitute for fixing reserves. It buys time. The GSE standards still determine what most buyers can borrow, and a project that leans on FHA indefinitely is a project whose owners are selling into a narrower market at lower prices.

The wider point about who regulates Michigan associations

Michigan has no agency with authority over association conduct, no reserve mandate, no milestone-inspection statute, and no insurance rules for master policies. What Michigan associations actually answer to, in financial terms, is the secondary mortgage market — and that market is now speaking with two voices.

A board's compliance posture therefore has to be plural. There is no single standard to meet.

What to watch next

Whether HUD issues a condominium Mortgagee Letter aligning FHA with the GSEs. There is no announced rulemaking. If FHA does eventually follow, Michigan's older projects lose their remaining soft landing, and the run-up to that would be the moment reserve funding stops being optional in practice as well as in theory.

Related Michigan HOA Topics

← All Michigan HOA Topics

  1. FHA condominium project approval — required documents (HUD)
  2. Form HUD-9992, FHA Condominium Project Approval Questionnaire
  3. Freddie Mac Guide Bulletin 2026-C, 18 March 2026 — the GSE standards FHA has not matched

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