Is the 6 months in reserve for a multi unit property a hard must?

I know a few things vary by lender when using the VA

Home loan. When shopping for a multi-unit property, it is said that you can use 75% of the rental income from the other units as qualifying income towards a mortgage.

With that though, you must have 6 months of reserves to do this. Internet is telling me that this isn't a hard must, and it varies by lender. Looking to see if anyone else has ran into this and if they were able to do it without the reserves (it being a smart idea or not is another topic). If so, what lender did you use?