Where Oregon condominiums start from an advantage

The recency test is the easy part here, and Oregon law is why.

Fannie requires a reserve study “completed within three years of the date on which the lender approves the project,” prepared by an independent third party with reserve-study credentials. ORS 100.175(3) requires more:

“The board of directors of the association shall annually determine the reserve account requirements by conducting a reserve study or reviewing and updating an existing study.”⁴

ORS 94.595(3)(a) imposes the same annual duty on planned communities. A compliant Oregon condominium already satisfies the federal recency test with two years to spare.

And the federal rule expressly pulls Oregon law into itself. Fannie's guidance carries this note: “Individual states may have various statutes concerning the use and content of reserve studies. Fannie Mae requires that a reserve study used by the lender in its analysis meet or exceed requirements set forth in relevant state statutes.”

Where the real Oregon exposure is

Two places, and the second is the one boards do not see coming.

Baseline funding. A great many Oregon reserve studies are written to a baseline funding goal, because that is what the statutes require the board to determine and what the market has produced. From August 3, 2026, such a study does not waive the percentage requirement — which means the association falls back to the flat allocation, rising to 15 percent in January.

The statutory right not to fund. ORS 100.175 and ORS 94.595(8)(b) both permit the board, with the approval of all owners, to elect not to fund the reserve account for the following year. That is Oregon law, and it is an entirely lawful choice.

An association that exercises it will fail the Full Review. And when a condominium fails, every unit in the building becomes unfinanceable by Fannie Mae and Freddie Mac — and by USDA, which does not run its own condominium standards and accepts projects “approved or accepted by HUD/FHA, VA, Fannie Mae or Freddie Mac.”⁵ In much of rural Oregon, USDA Guaranteed lending is a meaningful share of first-time-buyer financing, and it disappears on the same day.

That is a direct, citable conflict between a right Oregon statute grants an association and the underwriting standard that determines whether its units can be sold.

What a board faces before January

Run the division. Take the annual budgeted replacement reserve allocation, divide by annual budgeted assessment income excluding utility income, reserve-allocated income and special assessments, and see what comes out. If it is between 10 and 15 percent, the FY2027 budget is the one that has to move.

Then read the reserve study for the words “baseline funding.” If they appear, the study will not do the work it used to do, and the choice is to refund the study on a different basis or to budget the percentage.

Then check the delinquency figures against the thresholds, which are unchanged: “No more than 15% of the total units in a project are 60 days or more past due on common expense assessments,” and separately no more than 15 percent 60 days or more past due “in the payment of each special assessment.” Our Oregon reserve studies and Oregon collections pages cover both.

The one relief valve

FHA has not moved. Its condominium project approval rules remain those of the 2019 final rule and Handbook 4000.1, with a reserve allocation minimum of 10 percent of the gross budget — and Fannie's own review-method table accepts FHA project approval through the HUD review and approval process as an alternative to a Full Review for attached units in established projects. From January 2027, FHA is the looser standard on reserves, and that is a real workaround for an Oregon condominium that cannot get to 15 percent in one budget cycle.

What to watch next

Whether Oregon studies get rewritten. The baseline-funding ban takes effect five months before the percentage rises, which gives the reserve-study profession a window to move the market to threshold or full funding. Boards commissioning a study this autumn should be specifying the funding goal in the engagement, not discovering it in the report.