Borrowers with Local and State Benchmarking Requirements or Building Performance Standards
Depending on the size and location of your multifamily property, you may be required to benchmark by law or meet certain energy or carbon emissions performance standards. Both benchmarking and building performance standards (BPS) are requirements set by your city or state, but they differ in the following ways:
| Local and State Benchmarking | Building Performance Standards |
| Benchmarking entails submitting your energy and water consumption and cost data to your city or state. | Building performance standards build upon the benchmarking requirements, and require that buildings make efficiency upgrades to meet the local energy or carbon emissions standards. You may be fined if your building exceeds the jurisdiction’s energy or emissions cap. |
Many Fannie Mae Borrowers may be in jurisdictions with one or both requirements. Below is an overview of how these requirements can impact Fannie Mae Borrowers. To learn more, refer to the How to Submit Energy Performance Metrics Guide and the Building Performance Standards Overview for Lenders and Servicers.
Non-Green Mortgage Loans with Local and State Energy Benchmarking Requirements
If your property is in a city or state that requires energy benchmarking and the property has a Fannie Mae Mortgage Loan, you are required to submit 2024 Energy Performance Metrics (EPMs) to Fannie Mae in 2025.
In 2025, properties in these jurisdictions are required to:
• Comply with local energy benchmarking laws by submitting their 2024 energy cost and consumption data to cities.
• Submit their 2024 energy consumption and cost data to Fannie Mae.
Instructions are now available for How to Submit 2024 Energy Performance Metrics in 2025.
Borrowers that may have properties in jurisdictions with benchmarking requirements should benefit from this comprehensive training session. The webinar objectives include fundamental information about energy benchmarking requirements for Non-Green Fannie Mae Multifamily Mortgage Loans, the Covered Buildings List (CBL) and other resources for properties that may be required to benchmark and the steps Borrowers must take to fulfill these requirements.
Each city, town, or state below is linked to their benchmarking law’s website with compliance instructions.
Benchmarking Laws and Requirements for Properties Required to Submit EPMs in 2024 | |||
| Ann Arbor, MI | 20,000+ SF | Kansas City, MO | 50,000+ SF |
| Aspen, CO | 20,000+ SF | Lexington, MA | 25,000 + SF |
| Atlanta, GA | 25,000+ SF | Los Angeles, CA | 20,000+ SF |
| Berkeley, CA | 15,000 + SF | Miami, FL | 50,000+ SF |
| Bloomington, MN | 75,000+ SF | Minneapolis, MN | 50,000+ SF |
| Boston, MA | 15+ units or 20,000+ SF | Montgomery County, MD | 25,000+ SF |
| Boulder, CO | 20,000 + SF | New Jersey | 25,000+ SF |
| Brisbane, CA | 10,000 + SF | New York, NY | 25,000+ SF |
| California | 50,000+ SF | Oak Park, IL | 10,000 + SF |
| Cambridge, MA | 50+ units | Orlando, FL | 50,000+ SF |
| Chelsea, MA | 20+ units or 20,000+ SF | Philadelphia, PA | 50,000+ SF |
| Chicago, IL | 50,000+ SF | Portland, ME | 20,000+ SF (single-tenant buildings) |
| Chula Vista, CA | 20,000+ SF | Reno, NV | 30,000+ SF |
| Colorado | 50,000+ SF | San Diego, CA | 17+ Residential accounts and 50,000+ SF |
| Columbus, OH | 50,000+ SF | San Francisco, CA | 50,000+ SF |
| Denver, CO | 25,000 + SF | San Jose, CA | 20,000+ SF |
| Des Moines, IA | 25,000 + SF | Seattle, WA | 20,000+ SF |
| Detroit, MI | 100,000 + SF | South Portland, ME | 20,000+ SF |
| Edina, MN | 25,000 + SF | St. Louis, MO | 50,000+ SF |
| Evanston, IL | 20,000+ SF | St. Louis Park, MN | 25,000+ SF |
| Honolulu, HI | 50,000+ SF | St. Paul, MN | 50,000+ SF |
| Indianapolis & Marion County | 50,000+ SF | Washington, DC | 25,000+ SF |
| Fort Collins, CO | 5,000+ SF | ||
Please note that Green Mortgage Loan Borrowers are also required to submit their data to Fannie Mae each year and to local jurisdictions, if applicable. Bright Power completes the Fannie Mae reporting requirement through the Green Measurement and Verification Service on behalf of Green Mortgage Loan Borrowers only. Green Mortgage Loans are excluded from the Fannie Mae energy benchmarking requirements described above, but must still report to the jurisdiction per local benchmarking laws. Please refer questions regarding Fannie Mae Green Mortgage Loans to [email protected].
Non-Green Mortgage Loans subject to Local Building Performance Standards
Jurisdictions around the country are adopting Building Performance Standards (BPS) laws, which require buildings to meet certain energy or carbon emissions performance standards. Borrowers with properties in jurisdictions that are adopting BPS may be required to make efficiency upgrades to meet the standards. When a building’s energy consumption or emissions are over the jurisdiction’s cap, the owner may be subject to fines.
Currently, 13 jurisdictions have adopted various BPS policies. Four of the jurisdictions have state-wide requirements, and these are in addition to more localized requirements:
1. Boston, MA
2. Cambridge, MA (non-residential only)
3. Chula Vista, CA
4. Denver, CO
5. New York City, NY
6. Seattle, WA
7. St. Louis, MO
8. Washington, D.C
9. Montgomery County, MD
10. Colorado
11. Maryland
12. Oregon
13. Washington
Please refer to the Building Performance Standards Overview for Lenders and Servicers to learn more about how BPS may impact Borrowers, Servicers and Fannie Mae.
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Karyn Sper