Limited Review is gone, and Oregon condos now face the full file
Limited Review is gone, and Oregon condos now face the full file
2026-09-15 · Oregon · Compliance
The quiet path to a conventional loan on an Oregon condominium unit has been closed. Limited Review, the abbreviated project assessment that let a lender skip most of the association's financial file on a low-loan-to-value purchase, was retired for applications received on or after August 3, 2026.1
Freddie Mac's Bulletin 2026-C put it plainly: “The Streamlined Review project review type is being retired. Established Condominium Projects must be reviewed using the Established Condominium Projects project review type in Section 5701.5 or Reciprocal Review in Section 5701.9.”2
Fannie Mae's retirement is visible in its own guide. The Limited Review page has been removed, and the Project Review Methods table in B4-2.1-01 now offers attached units in established projects only “Full Review (with CPM), FHA Project Approval (HUD Review and Approval Process only), or Fannie Mae Review through the streamlined PERS process.”3
What the board now has to produce
A Full Review reaches the association's budget, reserve funding, insurance, delinquency rates, litigation, special assessments and inspection reports. In practice it arrives as a questionnaire the board secretary signs.
The Condominium Project Questionnaire Addendum — Fannie Form 1076A, Freddie Form 476A — “must be completed by an authorized representative of the Homeowners' Association (HOA)/Cooperative Corporation” and asks, among other things: the date of the last inspection by a licensed architect, engineer or building inspector; whether it produced findings on “safety, soundness, structural integrity, or habitability” and whether repairs are complete, with a copy of the inspection and the board meeting minutes; whether the association is aware of any deficiencies; whether there are outstanding violations of jurisdictional requirements; whether there is a funding plan and a schedule for deferred maintenance; whether a reserve study was done within the past three years; the current reserve account balance; current special assessments with amount, terms and purpose; planned special assessments with the same detail; and any association loans with the amount borrowed and repayment terms.4
Two answers that can end a sale
Planned special assessments. Question 11 reaches assessments the owners have approved but the association has not yet billed. An Oregon board that has voted a repair assessment and not started collecting still has to disclose it. And if the assessment funds a critical repair that has not been done, the project is ineligible — Fannie's rule is explicit: “If the special assessment is associated with a critical repair and the issue is not remediated, the project is ineligible.”
Critical repairs. The definition includes “any unfunded repairs costing more than $10,000 per unit that should be undertaken within the next 12 months (does not include repairs made by the unit owner or repairs funded through a special assessment).” A project under an evacuation order for an unsafe condition is ineligible until remediated and deemed safe for occupancy. And “If a structural and/or mechanical inspection was completed within 3 years of the lender's project review date, the lender must obtain and review the inspection report.”5
That last one deserves attention in Oregon, because House Bill 3746 created a mandatory moisture-intrusion inspection at year two and year six for condominiums whose declarations were first recorded from January 1, 2026. Those inspections are exactly the documents a lender must now obtain and review. A new Oregon condominium will be handing its statutory moisture report to every buyer's lender.
The status that stops everything
Fannie's ineligible-projects rule carries a note aimed squarely at boards:
“Loans secured by units in projects with a status of 'Unavailable' in Condo Project Manager (CPM) or on the DU Underwriting Findings report are ineligible for purchase by Fannie Mae.”
A lender may request an exception, and lenders are separately obliged to report information that could change a project's status — “such as, significant deferred maintenance or major litigation.” Nothing notifies the association when its status changes. A board typically finds out because a sale falls through.
What got easier
Not everything tightened. Three changes went the other way, and they reach Oregon boards too.
Owner occupancy. Freddie: “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.” Fannie's live Full Review text likewise contains no owner-occupancy or investor-concentration requirement. For an Oregon condominium with a high rental share — a common pattern in Bend, on the coast and near the universities — that removes a long-standing obstacle.
Small projects. The waiver of project review now covers detached condominium units, two-to-four unit projects, and five-to-ten unit projects “that is not part of a larger development or master association.” The caveat matters: “Attached units in a five- to ten-unit condo project that is part of a larger development or master association must be reviewed using the Full Review method.” Many small Oregon condominium buildings sit under a master association, and those are not waived.
Insurance. The requirement to insure roofs on a replacement cost basis was retired, and the inflation guard requirement was retired in its entirety. Guaranteed and extended replacement cost endorsements are now acceptable evidence of 100 percent replacement cost value.
The trap in the transition
Freddie flags it directly: “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 of such requirements.”
An existing project approval does not carry a board past the new rules. Our Oregon resale and disclosure page covers what an Oregon association owes a buyer alongside all of this.
What to watch next
January 4, 2027, when the reserve minimum rises from 10 percent to 15 percent of annual budgeted assessment income. A board that has just been through its first Full Review under the August rules will already have the numbers in front of it.
Related Oregon HOA Topics
- B4-2.1-02, Waiver of Project Review, Fannie Mae Selling Guide ↩
- Bulletin 2026-C, Freddie Mac Single-Family Seller/Servicer Guide, March 18, 2026 ↩
- B4-2.1-01, General Information on Project Standards, Fannie Mae Selling Guide ↩
- Form 476A, Condominium Project Questionnaire Addendum, Freddie Mac ↩
- B4-2.1-03, Ineligible Projects, Fannie Mae Selling Guide ↩
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