Who completes it, and is the association required to

Who completes it, in practice

An authorized representative of the association. In a professionally managed community that is the community association manager, working from the association's records. In a self-managed community it is usually a board officer, most often the treasurer or the president.

The form asks the preparer for a name, a title, a company, a telephone number, an email address and a date, and that block is not decoration. An unsigned or undated form comes back. So does one signed by somebody whose authority to answer for the association is not apparent.

One rule of thumb is worth stating plainly because it is the quiet cause of a certain kind of return: nobody with an interest in the transaction should be the one completing it. A seller, a buyer, a listing agent or a loan officer filling in the association's answers produces a document the reviewer cannot rely on, whatever the answers say.

Is the association required to answer?

There is no federal rule requiring a community association to complete a lender questionnaire. The Fannie Mae and Freddie Mac requirements bind the lender, not the association. The lender must establish that the project is eligible, and the questionnaire is how it usually goes about that, but the obligation sits on the lender's side of the transaction.

Several association-side law firms publish exactly this, and they are right about it. Anyone telling a board it is legally obliged to complete one, without pointing at the source of the obligation, is overstating the position.

What may create an obligation is something other than the agency requirements: an association's own governing documents, a management agreement, or a state statute that requires the association to furnish information on request. Those vary, and which of them applies to a particular association is a question for that association's counsel rather than for a form.

Why most associations answer anyway

Because the consequence of an unreviewable project does not land on the association as a notice. It lands on the owners as sales that do not close and as a narrower pool of buyers, and it lands on the whole project rather than on the one transaction that prompted the question.

That pressure grew this year. Limited Review and Streamlined Review were retired for applications dated on or after August 3, 2026, so conventional condo loans in buildings of eleven or more units now go through Full Review, and Full Review means the complete questionnaire on every file. A community that saw a handful of these a year is seeing them on every conventional sale.

The practical question for most boards has therefore moved. It is rarely whether to answer. It is how to answer accurately, at that volume, without the answers becoming a source of argument later.

What careful answering looks like

Answer from records, not from memory

Almost every answer that matters has a document behind it: the budget, the aged delinquency report, the reserve study, the ownership roster, the evidence of insurance, the last inspection report, the minutes. An answer given from recollection is the one that gets disputed.

Report, do not conclude

The association is answering questions of fact about itself. Whether the project is eligible is the lender's determination, made in the agencies' own systems. Answers that reach for a conclusion invite a reader to test it.

Show the arithmetic

Where a question produces a ratio, give the numerator and the denominator. Delinquency counted in units 60 or more days past due against total units, reserves as the replacement reserve allocation against annual assessment income. A bare percentage cannot be checked and frequently is not believed.

Let the attorney speak on litigation

The form takes a yes or a no and the substance sits in the attachment. The attorney's status letter is what classifies a matter, and a collection action against a delinquent owner reads exactly like a construction claim until somebody says which it is.

Treat unknown as an answer

On the building safety addendum in particular, unknown is read rather than skipped. Where an inspection exists, answer from it. Where repairs exist, state scope, funding and completion status.

Keep a copy of what was sent, and when

The same community is usually asked again within the year, because lenders apply freshness windows shorter than the agency limit. A file of what was answered last time turns the second request into a check rather than a repeat.

The answers that most often cause a return, and what settles each of them, are set out separately. What each section of the form is asking for is here.

Can somebody else prepare it?

The answers can be assembled by somebody else. The association stays the preparer and signer of record either way, and that is not a technicality: the signature is what makes the document worth anything to the reader.

That is the arrangement this desk runs on. Averbrook assembles the package from the association's own documents, shows the arithmetic, carries the source behind each material answer, and flags what the records do not support. The management company reviews it, signs it and delivers it under its own brand. Nothing goes from us to a lender, a buyer, an owner or a public record.

What that does not do is take a judgment away from the association. Where a question calls for one, the package says so rather than answering it.

Common questions

Short answers to what managers and boards ask most often about completing these.

Does an HOA have to fill out a lender questionnaire?

There is no federal rule requiring it. Fannie Mae and Freddie Mac requirements bind the lender rather than the association. An obligation can arise from an association's own governing documents, from a management agreement, or from a state statute requiring information to be furnished on request, and which of those applies is a question for the association's counsel. Most associations answer, because a project that cannot be reviewed is harder for buyers to finance.

Who is supposed to fill out the condo questionnaire?

An authorized representative of the association, usually the community association manager, or a board officer in a self-managed community. The form asks the preparer for name, title, company and date, and an unsigned or undated form is returned.

Can the buyer, seller or loan officer complete it instead?

No. Someone with an interest in the transaction completing the association's answers produces a document the reviewer cannot rely on, whatever the answers say. It is a common and avoidable cause of a returned form.

Can an association charge for completing a questionnaire?

In practice most management companies do, and the transaction generally bears it. Unlike a resale certificate or an estoppel certificate in states that cap those, a lender questionnaire is not a statutory document, so there is no statutory ceiling on what may be charged for one. What is charged is a matter for the management agreement.

What if the association does not have an answer to a question?

Say so, and say what the records do show. An answer that overstates what the records support is the one that causes trouble later, and leaving a field blank without explanation reads as an unanswered question rather than as a neutral.

Should the association's attorney review the questionnaire?

That is the association's own call, and boards differ on it. The place where an attorney's input is routinely useful is the litigation question, because the classification of a matter is made in the attached documentation rather than in the form's yes or no.