Freddie Mac vs Fannie Mae PCA Requirements: Form 1105 and Form 4099 Compared
The two agency multifamily PCA formats differ in form, repair taxonomy, reserve horizon and consultant rules. What each requires on top of ASTM E2018 and.
By Nicolas Reimer, Founder, Baseline PCR · Published September 18, 2026
Both agencies buy multifamily loans and both require a property condition assessment built on ASTM E2018, but they do not share a form. A consultant who works for lenders in both programs maintains two templates, two vocabularies and two exhibit sets. Here is where they diverge; the current agency documents govern, and both are revised through the agencies' guide updates.
Forms
Fannie Mae: Form 4099, Instructions for Performing a Multifamily Property Condition Assessment, with exhibits 4099.A through 4099.G (questionnaires, rating definitions, the data supplement, the useful-life table, problematic materials). See Fannie Mae Form 4099.
Freddie Mac: its multifamily seller/servicer guide chapter on property condition assessments and Form 1105, the Property Condition Assessment report form, with its own attachments.
Repair taxonomy
Fannie's report presents an immediate repairs schedule and a replacement of capital items schedule, with each component rated 1 to 5. Freddie's uses its own repair categories, commonly described as critical repairs, priority repairs and repairs to be completed within a stated period after closing, with its own reserve schedule. The E2018 concepts of immediate, short-term and long-term map onto both but the labels, and the escrow consequences, differ by program.
Reserve horizon and inflation
Fannie: the loan term plus two years, inflated at 3 percent per year. Freddie: the loan term with the agency's own inflation convention. Both expect per-unit reserve figures normalised for the underwriter.
Sampling and exhibits
Both prescribe how many units to inspect by property size, both require a pre-site questionnaire and a problematic-materials review, and both require consultant qualifications. The counts, thresholds and exhibit names differ; a report prepared to one program's sampling rule does not automatically satisfy the other's.
Consultant qualifications
Both set experience minimums for the consultant and the field observer and require professional liability insurance; Fannie's are spelled out in Form 4099 and Freddie's in its guide. Neither accepts a plain E2018 report.
Producing both from one dataset
The data both programs need is the same: components with condition, installed year, useful life, remaining life, quantity, unit cost and category, plus the questionnaire, sampling record and problematic-materials answers. A firm whose E2018 report is built from structured fields can map to either form; a firm whose report is prose in a template rebuilds each time. See ASTM vs Fannie vs HUD.
Baseline PCR produces the ASTM E2018-24 report today; the agency forms are the planned next outputs from the same data and are not produced yet.
Sources
- EBI Consulting, Fannie Mae and Freddie Mac Multifamily PCA Requirements
- Fannie Mae, Form 4099 Instructions for Performing a Multifamily Property Condition Assessment
- Fannie Mae, Form 4099.D Property Condition Rating Definitions
- ASTM E2018-24, Standard Guide for Property Condition Assessments: Baseline Property Condition Assessment Process (ASTM International)
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.