ASTM E2018 PCA vs Fannie Mae Form 4099 vs HUD PCNA: Which Report the Lender Actually Wants
The three formats a commercial PCR can take, what Fannie Mae 4099 and the HUD PCNA add to the ASTM baseline, who requires which, and why ASTM comes first.
By Nicolas Reimer, Founder, Baseline PCR · Published September 18, 2026
Three documents get called "the property condition report" in commercial real estate, and they are not interchangeable. Which one a firm writes depends on who is lending, not on what the building is.
The short version
| ASTM E2018-24 PCR | Fannie Mae Form 4099 PCA | HUD PCNA (CNA e-Tool) | |
|---|---|---|---|
| Who requires it | Buyers, owners, banks and private lenders | Fannie Mae DUS lenders on multifamily loans | HUD/FHA multifamily insured loans |
| Property types | Any commercial or multifamily | Multifamily and its variants (student, seniors, manufactured, co-op) | Multifamily insured under HUD programs |
| Governing document | ASTM guide, ~21 pages | Fannie Mae instructions plus exhibits 4099.A through 4099.G | HUD MAP guidance and the CNA e-Tool software |
| Report structure | Not prescribed; industry order from the 2008 guide's sample | Seven fixed sections | Structured data entered into the e-Tool, plus narrative |
| Condition rating | Good, fair, poor (defined) | 1 to 5 per component, criteria in 4099.D | Component-level needs in the tool |
| Cost tables | Table 1 immediate and short-term; Table 2 long-term if requested | Immediate repairs schedule plus replacement of capital items over loan term plus two years at 3 percent | Immediate and long-term needs schedules generated by the tool |
| Useful-life source | Consultant's choice; HUD table common | Form 4099.F table | e-Tool table |
| Extra requirements | None beyond the guide | Unit sampling by property size, 4099.G problematic materials, 4099.E data supplement, consultant qualifications | Accessibility and energy modules, HUD reviewer sign-off |
| Who signs | Field observer and PCR reviewer; PE if the client requires | Qualified consultant meeting Fannie's experience rules | Needs assessor accepted by HUD |
ASTM E2018: the baseline everyone starts from
E2018 is a guide, not a form. It defines the three components of the assessment (walk-through, document review and interviews, opinions of cost), the vocabulary (physical deficiency, immediate, short-term, long-term, EUL, RUL), the reporting threshold and the required contents of the report. It does not prescribe a page layout. Nearly every private-lender and buyer PCR in the country is an E2018 report in the shape the 2008 edition's sample table of contents established. See how to write one.
Fannie Mae Form 4099: ASTM plus a second rule system
Fannie Mae's instructions require an E2018 assessment and then add their own layer. The report has seven fixed sections. Every component receives a 1 to 5 rating against the criteria in Form 4099.D, which weigh life safety, deferred maintenance, routine maintenance and remaining life. Two cost schedules replace Table 1 and Table 2: immediate repairs, and replacement of capital items over the loan term plus two years, inflated at 3 percent. A property useful-life table drives the second schedule using Form 4099.F's EUL values, effective age, RUL and the RUL-to-EUL ratio.
Beyond the report, Fannie prescribes unit sampling by property size, a pre-site questionnaire (4099.B), a structural risk questionnaire (4099.C), an Excel data supplement delivered alongside the PDF (4099.E), a problematic-materials checklist (4099.G) that requires certain conditions such as aluminum branch wiring or specific panel brands to be identified and photographed, and consultant qualifications (engineering or architecture degree, years of experience, a minimum number of recent multifamily PCAs) attached as an exhibit. The instructions are revised by Fannie's guide updates and apply to reports in progress when they change.
Freddie Mac has its own version (Form 1105, with a different repair taxonomy) for its multifamily program; the two agencies do not share a form.
HUD PCNA: the same assessment, entered into a tool
For FHA-insured multifamily loans HUD requires a Project Capital Needs Assessment, delivered through the CNA e-Tool, a federal spreadsheet-and-web application. The assessor enters components, conditions, useful lives and costs into the tool, which generates the needs schedules and checks them; the narrative accompanies it. The e-Tool's useful-life table is public domain and organised by the E2018 outline, which is why it is also the common EUL source for ordinary ASTM work.
Why the ASTM structured report is the on-ramp
The agency forms are supersets of the ASTM tables. Fannie's useful-life table needs exactly the columns a good Table 2 already has (EUL, effective age, RUL, quantity, unit cost, year due); the 1 to 5 rating is derived from condition and RUL; the 4099.G checklist is a set of questions over the electrical and envelope sections; the HUD tool wants the same components with the same lives. A firm whose E2018 report is built from structured fields, rather than from prose in a template, can produce the agency versions as different views of the same data. A firm whose report is a Word document cannot.
Which one to write
- A buyer's due diligence, a bank refinance, an owner's capital plan: ASTM E2018, with Table 2 if the client wants a reserve view.
- A Fannie Mae DUS loan on an apartment property: Form 4099, by a consultant who meets Fannie's qualification rules.
- A Freddie Mac multifamily loan: Form 1105.
- An FHA-insured multifamily loan: HUD PCNA through the CNA e-Tool.
Where Baseline PCR stands
Baseline PCR produces the ASTM E2018-24 report from structured fields: all ten systems (roofing as its own section), source-tagged observations, Table 1 and Table 2 computed from the firm's cost library and the HUD useful-life table with Fannie 4099.F carried alongside. The agency formats are the planned next output from the same data; they are not produced today, and a firm doing agency work should say so in its scoping. The sample report is the ASTM form.
Sources
- ASTM E2018-24, Standard Guide for Property Condition Assessments (ASTM International)
- Fannie Mae, Form 4099 Instructions for Performing a Multifamily Property Condition Assessment
- Fannie Mae, Form 4099.D Property Condition Rating Definitions
- EBI Consulting, Fannie Mae and Freddie Mac Multifamily PCA Requirements
- Partner Engineering and Science, How Recent Fannie Mae Updates Could Impact Your Deal
- HUD, Estimated Useful Life Table for the CNA e-Tool
ASTM E2018-24 is copyrighted by ASTM International and is paraphrased here, never reproduced; buy the guide from ASTM to read the text. This page is general information for practitioners, not engineering, legal or lending advice.