
Borrowers with Local and State Benchmarking Requirements
How to Submit 2022 Energy Performance Metrics in 2023
Depending on the size and location of your multifamily property, you may be required to benchmark by law. Benchmarking entails submitting your energy and water consumption and cost data to your city or state. If your property is in a city or state that requires benchmarking and the property has a Fannie Mae Loan, you are required to submit 2022 Energy Performance Metrics (EPMs) to Fannie Mae in 2023.
In 2023, properties in the following jurisdictions are required to:
- Benchmark by law by submitting their 2022 energy and water cost and consumption data to cities
- Submit their 2022 energy and water consumption and cost data to Fannie Mae
- Green Mortgage Loans report to Fannie Mae through the Green Measurement and Verification Service and are not required to follow these requirements
Instructions are now available for How to Submit 2022 Energy Performance Metrics in 2023
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 2022
100,000+ SF |
20,000+ SF |
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25,000+ SF |
50,000+ SF |
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25,000 + SF |
200,000+ SF |
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100,000+ SF |
25,000+ SF |
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35+ units or 35,000+ SF |
50,000+ SF |
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10,000 + SF |
50,000+ SF |
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50,000+ SF with 17+ units |
50+ units |
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50+ units |
50,000+ SF |
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50,000+ SF |
San Diego, CA | 50,000+ SF | |
50,000+ SF |
San Francisco, CA | 50,000+ SF | |
50,000+ SF |
20,000+ SF |
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100,000+ SF |
20,000+ SF |
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25,000 + SF |
10+ units in specified areas |
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25,000 + SF |
50,000+ SF |
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25,000 + SF |
St. Louis Park, MN | 25,000+ SF | |
20,000+ SF |
St. Paul, MN | 50,000+ SF | |
5,000+ SF |
50,000+ SF |
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50,000+ SF |
Please note that the guidance does not apply to Fannie Mae Green Mortgage Loan Borrowers with properties in benchmarking jurisdictions, as they report through the Green Measurement and Verification Service. Please refer questions regarding Fannie Mae Green Mortgage Loans to [email protected].

Karyn Sper
Director, Green and Healthy Housing Financing
Contact Karyn Sper:
800-232-6643|
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