Why a filing requirement is the interesting instrument

Underwriting standards are where a carrier decides what it will not insure. They are ordinarily proprietary and not filed — unlike rates, which are.

Requiring them to be filed does not prohibit anything. It makes the regulator's picture complete: the Commissioner would know, prospectively, which carriers decline business by distance to coast, roof age, claim history or building age, and would see a change before it took effect rather than after complaints arrived.

The Attorney General thought it mattered enough to intervene. The Office of the Attorney General's People's Insurance Counsel Division filed a comment letter on 24 November 2025, signed by People's Insurance Counsel Dorianne A. Meloy, supporting the draft.³ The letter is expressly advocacy rather than the Attorney General's statutory legality review.

That division also gained a related tool this year: Bulletin 25-14, issued 16 September 2025, notified all property and casualty insurers writing homeowners policies that the People's Insurance Counsel Division now has regulator-level SERFF access to their rate filings, under a memorandum of understanding with the Insurance Administration.⁴

What the regulator already knows about the coast

The draft rule did not come from nowhere. The Insurance Administration's own Market Hardening Survey Report on the Maryland homeowners market, published November 2024, covered condominium (HO-6) policies alongside other residential types and found:⁵

• Twenty-three of twenty-nine surveyed carriers restrict new business or renewals based on distance to coast or water in some way. Six do not — and one of those six had stopped writing that line entirely.
• Generally, those carriers “will not insure a home that is within 500 feet and up to 5 miles of a coastline.”
• “Worcester County is the county that is most frequently cited by name in carriers' underwriting guidelines,” and “in many cases, the restrictions for Worcester County are far more stringent than for the surrounding counties on the Eastern Shore.” Worcester County is Ocean City.
• Company-initiated non-renewals statewide rose from 6,499 to 8,663 in a single year — 33.30 percent — and rose in every county in Maryland between 2021 and 2023.
• Worcester County non-renewals went 57 to 78 to 98 across 2021–2023; policies in force there fell 15.3 percent then a further 0.9 percent.
• Fifteen carriers have mandatory wind or hurricane deductibles of 1 to 5 percent; fourteen have none. Some cover wind or hail losses only at actual cash value regardless of policy type.
• Islands including Hoopers, Smith, Taylor and Tilghman are listed as unacceptable risks by many carriers.

That is the most reliable coastal-insurance evidence Maryland has published — and its data period is 2021 to 2024. We searched for a 2025 or 2026 successor report and found none.

The honest gap

There is no published 2026 figure for Maryland condominium master-policy premiums. The hard local numbers are three years old: Ocean City property managers reported average multi-peril increases of 40 percent with individual renewals up to 150 percent, and four insurers ceasing to write Ocean City buildings — reporting that dates from late October 2023, not from this year.⁶

The only 2026 signal points the other way, and it comes from a vendor: a regional association-insurance broker reports well-maintained, low-claim condominium buildings renewing at just 2 to 5 percent, against a historical baseline above 10 percent, while umbrella and excess liability is still up 10 to 30 percent.⁷ That is one firm's book of business, published on its own marketing blog, with its data sources named but not linked.

So: anyone stating that Maryland condominium insurance rose or fell by a particular percentage in 2026 is not working from published evidence. That is precisely the vacuum a filed-underwriting-standards rule would start to fill.

What the Administration did do in the period

There is no 2025 or 2026 condominium-specific MIA bulletin. We enumerated every property and casualty bulletin for both years; the newest condominium ones remain 24-22 of September 2024 and 23-15 of September 2023.⁸

Two general bulletins do reach association master policies and unit-owner policies alike:

Bulletin 25-10, 17 June 2025, on cancellations, non-renewals and claim denials based on satellite and aerial imagery. An insurer may use such imagery as a basis for cancellation, non-renewal or denial “only if the image provides a clear, accurate, and current view of the property.” Images that are “low-resolution, out-of-focus, blurry, or dated … cannot justify a cancellation or nonrenewal based on the condition of the property without further investigation,” and roof “streaking or discoloration may not be sufficient to independently support cancellation or nonrenewal.” A protesting insured is entitled to review the images the insurer relied on, and under § 27-501(g) the insurer bears the burden of persuasion.⁹

Bulletin 26-8, 3 April 2026, requiring all property and casualty insurers to update cancellation and non-renewal notices with the Maryland Joint Insurance Association's new address and phone number from 10 April 2026 — 3290 North Ridge Road, Suite 185, Ellicott City, MD 21043, (410) 539-6808. The JIA is the residual market a non-renewed association or unit owner is pointed to.¹⁰

One rule was abandoned: the Administration decided not to pursue its proposed COMAR 31.15.11.06 on the use of credit history in underwriting, after comments closed on 26 July 2025.²

What to watch next

The Maryland Register. A formal proposal of Chapter 31.08.19 would open a fresh comment period with a new compliance date. Nothing has been published.

17 September 2026. An Insurance Administration item sits on the General Assembly's meetings calendar for that date with no published agenda. It is the only live interim thread on Maryland insurance touching this beat, and its subject is unknown. There is otherwise no MIA study, workgroup or legislative recommendation on condominium master-policy costs or deductible allocation — a verified absence.

1 October 2027. Chapter 717 of 2026 makes unit-owner coverage mandatory and raises the owner's deductible exposure to $25,000. A statutory minimum for loss-assessment coverage only works if carriers file forms offering it, which routes straight back through the filings this draft rule is about.