What did take effect on August 3, 2026

Baseline funding is no longer permitted. From LL-2026-03:

“…they must verify the project’s budget includes the highest recommended reserve allocation amount in the reserve study to adequately cover the costs identified.”

“NOTE: Lenders are no longer permitted to use the baseline funding method which is the option that allows the reserve cash balance to approach but never fall below zero.”

Freddie Mac’s Bulletin 2026-C says the same, effective the same date. A reserve study written to a baseline goal — a very common form — no longer serves as the basis for a compliant budget, and where a study offers several funding scenarios the budget has to carry the highest recommended allocation in it.

Limited Review is retired.

“We are retiring the Limited Review process. Established projects previously eligible for Limited Review must now be reviewed using the Full Review process or, when applicable, the Waiver of Project Review process… Lenders may implement the retirement of Limited Review immediately but must do so for all loan applications dated on or after Aug. 3, 2026.”

Freddie retired Streamlined Review on the same date, leaving Established Condominium Projects reviewed under section 5701.5, Reciprocal Review under 5701.9, or delivered as “Exempt From Review.”

The consequence nobody announced

A Limited Review never touched Condo Project Manager. Now every established-project loan is either a Full Review or a Waiver, and both require a CPM check. Fannie’s Selling Guide B4-2.1-03, Ineligible Projects, updated August 5, 2026: “Loans secured by units in projects with a status of ‘Unavailable’ in Condo Project Manager (CPM)… are ineligible for purchase by Fannie Mae.”³

There is no published list of Unavailable projects; CPM is queried per project and returns standardised reason codes. A project that has quietly carried an Unavailable status finds out when the first post-August buyer’s loan does not close.

The escape hatch, and its Wyoming condition

The Waiver of Project Review was expanded, effective immediately in March 2026:

“We are expanding eligibility for a Waiver of Project Review to include new and established projects with ten or fewer units. For projects consisting of five- to ten-units, the project must not be part of a master association or larger development.”

“NOTE: As stated in Selling Guide B7-4-01… general liability and fidelity insurance are not required for condo projects that qualify for a Waiver of Project Review.”

Freddie’s equivalent extends “Exempt from Review” to projects of 2 to 10 units on the same master-association condition.

Wyoming condominium projects are small, so a large share of the state’s stock falls under ten units and lands inside the waiver. The exception bites hardest exactly where Wyoming’s condominium value is concentrated — Teton County and Jackson resort-adjacent development is commonly structured under a master association.

What a Full Review asks for

For a project that does not qualify for a waiver, the Full Review requires a lender-reviewed budget, a compliant reserve allocation, a reserve study that is not baseline-funded, documentation of critical repairs, and per-assessment detail on every special assessment — its purpose, approval date, original and remaining amounts and expected completion. A project is ineligible where a special assessment addresses an unresolved critical repair, or where repairs significantly affect safety, soundness, structural integrity or habitability.

That is a document set assembled by a managed association with a professional treasurer. Wyoming sits in the Foundation for Community Association Research’s lowest bracket — “Fewer than 1,000” associations statewide — and self-management is correspondingly common.

Two more items in the same package

• The 50% investor concentration limit is gone for established projects on investor loans, effective immediately from the March letter. The presale requirement is not: at least 50% of units must still have been conveyed or be under contract to principal residence or second home purchasers.
• Wyoming’s FHA alternative is one project. HUD’s condominium portal, queried September 19, 2026, returns a single approved Wyoming project — a four-unit building in Cheyenne whose approval expires October 18, 2026.