Thank you so much for the response Nathan - yes that's how I interpreted the law, but since I am out of state , I will be hiring a prop mgmt company or an eviction lawyer for next steps.

Looks like they’re still operating at a loss if I’m interpreting correctly.  

You alluded to the "bad" interpretation, as this would be pointing to an oversupply situation pushing rents down.

I think they are just an extremely conservative bank and that is their interpretation of Fannie's guidelines.I have already gotten approved from some other banks (credit unions), so I'm not worried, but I am curious if anyone else has run into a bank telling them they need at least a 20% down payment on 3-4 units, regardless of it being FHA or not.

I know that in written communication, concepts can sometimes be interpreted differently than originally intended.

Now, if you have an alternative interpretation of the Regs, please share. 

The painting should be completed within three months of the move-in date, and the Lessor will inspect the work to confirm it meets these standards.”This implies that the LL gets to determine that the paint job meets his quality expectation.”Per the mutual agreement between the Lessor and the Tenant, the Lessor has agreed to reduce the monthly rent from $3,200 to $3,100, allowing the Tenant to repaint portions of the house at their own expense.”this is not as clear as it could be, but could be interpreted that the rent is $3200 if the tenant does not paint the areas that the LL specifies to the quality that meets the LL quality expectations. 

Shalom Luis,Jonathon is right in his interpretation of the law in Texas.

In some cases, Fannie Mae may approve a PMI removal even earlier than the 2-year seasoning period if you can prove the substantial increase in the property’s value.Speak with Your Lender: Given the complexity here, consider having a direct conversation with your lender and asking for a specific review of your PMI removal request based on the current LTV and any potential reappraisal opportunities.In summary, while it’s generally required to wait for the two-year seasoning period for PMI removal on HomeStyle loans, there could be flexibility depending on the lender’s interpretation of Fannie Mae's guidelines and your property’s new appraised value.

@Josh LemonsThey have a regulation A offering which is open to accredited and non accredited investorsThe great thing is they have to submit their offering circular and have it qualified by SEC as well as submit financial information etc.All this means is the information is readily available and if you do not understand it then I recommend engaging an attorney who can interpret it.