One thing we could not confirm, and will not paper over

The 1.10 divisor appears in Citizens' commercial rate notice effective January 1, 2025. It does not appear in the commercial notices effective November 1, 2024 or November 1, 2025.

Whether the relief continues to be applied to commercial policies effective on or after November 1, 2025 by some mechanism outside the rate notice is not established. What is clear is that the statute plainly runs to December 31, 2027. Do not conclude the waiver was withdrawn — conclude that the document trail stops, and ask Citizens or the producer of record to confirm how it is being applied to a particular renewal.

The reporting mechanism that could end it early

SB 113 also enacted R.S. 22:2303(D)(6), a self-destruct clause with an annual trigger:

“(6)(a) Prior to February first of each year, the commissioner shall report to the House Committee on Insurance and the Senate Committee on Insurance the percentage of residential property insurance business in each of the sixty-four parish markets in this state. If the corporation is writing less than twenty percent of the residential property insurance in any given parish market, the commissioner may recommend to the committees that the provisions of this Subsection be legislatively terminated and the provisions of Subsection A of this Section be reinstated as to that parish market.
(b) The provisions of this Paragraph shall terminate on January 1, 2028.”

Two observations for a board. The trigger is measured on residential market share by parish, so the metric that could end the relief has nothing to do with the commercial book that carries association business. And the recommendation is parish-by-parish, so relief could in principle end in one parish and continue in another.

The snap-back date, and why it belongs in a reserve plan

Absent further legislation, the ten-percent loading returns for policies rated after December 31, 2027. For an association whose master policy sits with Citizens, that is a known, dated, non-discretionary cost increase — and there are very few of those in Louisiana insurance.

It also has a procedural consequence. R.S. 9:1141.34(A)(1) requires a planned-community association's budget summary to include “any reserves, and a statement of the basis on which any reserves are calculated and funded,” and to go to the owners within thirty days of adoption, with a ratification meeting between ten and sixty days later. A board that knows about a 2028 step-up and does not disclose the basis on which it is providing for it is disclosing less than the statute contemplates.

Two other Citizens carve-outs from the same 2024 act

SB 113 also narrowed what a policyholder can recover from Citizens, and the language reached both of Louisiana's claims-penalty statutes. The amendment to R.S. 22:1892(H), with additions shown:

“The Louisiana Insurance Guaranty Association, as provided in R.S. 22:2051 et seq., and the Louisiana Citizens Property Insurance Corporation, as provided in R.S. 22:2291 et seq., shall not be subject to the provisions of Code of Civil Procedure Article 591 et seq., or any other provision allowing a class action, for any damages including any penalties awarded pursuant to the provisions of this Section. … The Louisiana Citizens Property Insurance Corporation, as provided in R.S. 22:2291 et seq., shall not be liable for general damages, special damages, or penalties in excess of the policy's limit; however, this Subsection does not limit the Louisiana Citizens Property Insurance Corporation from paying legal interest due from breach or reasonable attorney fees and costs when otherwise provided by this Section.”

A materially identical amendment was made to R.S. 22:1892.2(F), the catastrophic-loss claims provision. So: no class action against Citizens, and no extracontractual exposure above the policy limit, save interest and fees.

Separately, Louisiana repealed one of its two bad-faith statutes outright. R.S. 22:1973 now reads, in full: “§1973. Repealed by Acts 2024, No. 3, §2, eff. July 1, 2024.” Any Louisiana insurance-remedies discussion still citing R.S. 22:1973 as live law is two years out of date; R.S. 22:1892 and R.S. 22:1892.2 are what remain.³

What a board can do

• Ask, in writing, whether the 1.10 divisor is being applied to your renewal. The statute says the relief runs to the end of 2027; the notice trail does not say how it is being administered now.
• Put January 1, 2028 in the reserve plan. A ten-percent statutory loading returning is a budgetable event.
• Do not plan a claim strategy around penalties. Against Citizens, the class-action route is closed and extracontractual damages are capped at the policy limit.
• Update any document citing R.S. 22:1973. It is repealed.

What to watch next

The Commissioner's report to the House and Senate insurance committees before February 1 each year, and whether any parish-level recommendation to terminate the relief is made. And the rate notices Citizens publishes for policies effective in late 2027, which are where the snap-back will first be visible.