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This is because overall memory usage of the process hosting the Windows Update Agent process is extremely high.
The result is that there is either not enough memory available to satisfy the request or there is not a large enough contiguous block of free memory to satisfy the request.
This is different from a typical scan performed by the Windows Update agent which requires a smaller subset of criteria.
If an update is on WSUS and in a non-declined state, the Configuration Manager scan criteria will cause the Windows Update agent to try to evaluate it.
The update will change how the update metadata is loaded into memory.