Freddie Mac Optigo | 2026-08-13

Freddie Mac Liquidity Verification Belongs in the First Request List

Freddie Mac's June 2026 Guide Bulletin makes principal-level liquidity documentation an early closing-control item.

Freddie Mac's June 23, 2026 Multifamily Seller/Servicer Guide Bulletin announced several Guide changes, including updates to liquidity verification for applicable Key Borrower Principals, certain forward commitment requirements, insurance requirements, Structured Transaction Seller/Servicer designations, and information security and business continuity requirements.

On liquidity verification, the bulletin states that Seller/Servicers must verify the lesser of the liquidity reported in each applicable Key Borrower Principal's certified financial statement or two times the minimum liquidity required in the quote or for an assumption, as applicable. It also clarifies that each applicable Key Borrower Principal must independently satisfy the requirement, that verified liquidity is supported by bank or brokerage statements, and that a Liquidity Verification Worksheet must be submitted with the underwriting package.

For borrower-side closing counsel, the practical point is document control. The first request list should identify each applicable principal, current financial statements, bank or brokerage statement support, acquisition funds-to-close questions, and who will respond if the lender needs a liquidity explanation or supplemental evidence.

Liquidity verification should stay in its proper lane, but it should not be invisible to the legal closing calendar. If the verification work creates an open issue, the checklist should show the owner, requested document, lender response status, and any effect on authority, certificates, execution timing, or closing conditions. This note is informational only and is not legal advice for any specific transaction.