"It feels like you're having your wisdom teeth pulled out." That is how South Florida-based mortgage executive Melissa Cohn described arranging condo loans in the weeks after Aug. 3, 2026, in an interview with The Real Deal. She said the deals are still closing, but "the question is the pricing."
For anyone buying a Brickell condo resale with a conventional mortgage this fall, the main change is that the lender now looks hard at the building as well as the buyer. Your credit score, income and down payment still count. The association's budget, reserves, assessments and engineering reports now count about as much. A tower's completion date does not show how those records read.
What retired on Aug. 3, and what replaced it
On March 18, 2026, Fannie Mae announced in Lender Letter LL-2026-03 that it was retiring its Limited Review process for established condo projects. Those projects must now go through Full Review, or a Waiver of Project Review when one applies. Lenders had to make the switch for all loan applications dated on or after Aug. 3, 2026. Freddie Mac retired its version, called Streamlined Review, on the same timeline under Bulletin 2026-C. Established projects there now go through Freddie's Established Condominium Projects review or Reciprocal Review, or are delivered as Exempt From Review if they qualify.
The shortcut was widely used. According to The Real Deal, 40% of condos nationwide went through the limited review process last year. The same report said Florida has the country's highest concentration of condos, many of them without professional management.
Under Fannie Mae's Full Review requirements and its condo project FAQ, the lender's file on a building covers:
- Budget and reserves. The lender reviews whether the project's budget and reserves are adequate. If the lender relies on a reserve study, the budget has to use the study's highest recommended reserve allocation. Baseline funding, which lets the reserve cash balance approach zero, is no longer allowed for applications dated on or after Aug. 3, 2026.
- Delinquencies. No more than 15% of units can be 60 or more days behind on common assessments, or on any individual special assessment.
- Critical repairs. A loan is not eligible for Fannie Mae purchase if the lender cannot determine that the project is not in need of critical repairs. HOA minutes, financial statements and engineer reports are among the records that can answer that question.
- Inspection reports. Lenders must review any structural or mechanical inspection completed within the last three years, though Fannie Mae does not require one to be ordered if none exists. A project that fails a mandatory state, county or other inspection addressing structural safety, soundness or habitability is ineligible.
The standard condo questionnaire is optional, according to Fannie Mae's FAQ. When a questionnaire leaves gaps, the lender still has to get enough information some other way. For the transaction, that means the timeline depends partly on how quickly an association can produce documents. Cohn told The Real Deal that loans take longer because brokers wait on associations for the right paperwork. Once the paperwork arrives, she said, more buildings are failing to meet Fannie Mae or Freddie Mac thresholds, which sends some buyers to non-QM lenders that usually charge higher rates.
A 2008 tower shows why age is a poor shortcut
The two 1060 Brickell towers were completed in 2008. When the association's board at the time proposed a $21 million special assessment in 2024, many owners pointed out that the buildings were only 16 years old, well short of the 30-year trigger for structural recertification. The Real Deal reported in July 2025 that the assessment averaged more than $35,000 per unit. It included $7.7 million for façade restoration on Tower II, $3.5 million for garage and basement work, $2.5 million for general conditions and $1.7 million for rotunda repairs. Court filings described in The Real Deal's October 2026 coverage say the association based the assessment on its engineer's structural integrity reserve study.
Owners then filed arbitration petitions with the state and organized a recall, voting twice to replace the former board. A Miami-Dade judge ordered the former board to hand over control and records in the fall of 2025. A separate owner lawsuit challenging the assessment settled privately after the turnover. As of early October 2026, the current association president told The Real Deal that the assessment is still in place with about two or three installments left. The same report says the association has sued its repair contractor in Miami-Dade Circuit Court over construction liens.
A buyer looking at a unit in a building like this needs facts that a listing photo or a construction date won't show: how much of a special assessment is still outstanding, how many owners are current on it, and what engineering reports exist. Under Full Review, those are the facts that lead to a lending decision.
The same March rules loosened limits that hit Brickell hard
Lender Letter LL-2026-03 also removed several restrictions that had weighed on Florida and on investor-heavy towers.
- Florida's geographic restrictions. Fannie Mae said retiring Limited Review "effectively retires the remaining geographic restrictions that apply to the state of Florida." Freddie Mac separately retired its Florida LTV limits for established projects with a "Certified by Lender" status.
- New attached projects in Florida. Fannie Mae no longer requires these to go through its Project Eligibility Review Service. They can now be approved through lender-delegated Full Review. Freddie Mac dropped its requirement that such projects carry an "Approved by Fannie Mae" designation.
- Investor concentration. Fannie Mae retired the 50% limit on investment-property concentration in established projects reviewed under Full Review on investor loans. For new and newly converted projects, the presale requirement for principal residence and second home buyers still applies.
For investors financing a Brickell unit in an established tower, that investor-concentration change removes one test a building could fail. The policy took away one shortcut and several old Florida restrictions at the same time. The building's financial record decides which change matters more for a given building. Cohn summed it up for The Real Deal: the rules "will put a premium on the value of the buildings that are compliant."
The calendar for a contract signed this fall
Two deadlines fall within a normal contract-to-closing window for an offer written in November.
| Date | What applies | Source |
|---|---|---|
| Aug. 3, 2026 | Limited Review and Streamlined Review retired; no baseline reserve funding for Fannie Mae applications dated on or after this date | Fannie Mae LL-2026-03 |
| Dec. 31, 2026 | Deadline for a SIRS completed together with a milestone inspection due on or before this date | Florida DBPR |
| Jan. 4, 2027 | Fannie Mae's minimum reserve allocation under Full Review rises from 10% to 15% of the annual budgeted assessment income, for applications dated on or after this date | Fannie Mae LL-2026-03 |
The January change applies based on the loan application date. A buyer who goes under contract in late November but applies for the loan after the holidays could be underwritten against the 15% standard. "A lot of these buildings don't have the financial capacity to increase their reserves to 15 percent," Cohn told The Real Deal.
On the state side, Florida's Department of Business and Professional Regulation says associations must follow the funding schedule in their SIRS. If a study shows reserves fall short, an association may need to levy assessments or take out a loan or line of credit. Associations whose budgets were adopted on or after Jan. 1, 2025, cannot waive SIRS reserves.
What the county numbers say about pace
Market activity has not stalled. In September 2026, according to the MIAMI REALTORS® Miami-Dade townhouse and condo report, the county had 11,706 active listings, 7.2% fewer than a year earlier, and 12.3 months of supply compared with 14.0. The median sale price was $417,090, down 0.7% year over year. The median time to sale shortened from 115 days to 102.
Those are countywide medians, and they include every building that clears underwriting without trouble. The constraint shows up in which buildings can be financed. MIAMI REALTORS® reported in October 2026 that only 21 of the 2,397 condo buildings in Miami-Dade, Broward and Palm Beach counties are approved for FHA loans, or 0.9%. With FHA closed off in nearly every building, conventional financing carries most of the load for buyers who aren't paying cash. That's why the Full Review outcome on a given tower can matter more to a buyer than the county median.
For sellers, the association's records go with the listing
A Brickell seller's buyer pool now depends partly on records the seller doesn't control but can ask about early: the current budget, the reserve study and how the budget funds it, any special assessment and how many installments remain, recent engineer reports, and board minutes. Fannie Mae's FAQ names those kinds of documents as evidence lenders can use. When a seller knows early how quickly the association produces them, the time between contract and appraisal is easier to predict. For investors who own a unit and plan to sell in 2027, the Jan. 4 reserve change is a good reason to ask the board how its budget compares with the 15% figure.
Quick answers
Does every condo loan now require Full Review? No. Fannie Mae offers a Waiver of Project Review in some cases, including projects of 10 or fewer units, with other requirements still applying. Freddie Mac has Reciprocal Review and Exempt From Review options.
Does a building have to be 30 years old to face major structural costs? 1060 Brickell's $21 million assessment came when the towers were 16 years old, according to The Real Deal.
Is a cash purchase affected? These are lender eligibility rules for conventional loans sold to Fannie Mae and Freddie Mac. The state SIRS funding requirements apply to the association no matter how a unit is bought.
This post is general information, not legal, financial or lending advice. Please confirm how these rules apply to your purchase or sale with your lender, a Florida real estate attorney and your association.
If you're weighing a Brickell condo offer or planning to sell one in the next few months, Sandra Valenzuela and her team can help you collect the association documents early and plan your contract around the January reserve change, in English or Spanish. Contact us to start with the building, then the unit.