2026-09-12 · Maryland · Regulation · Pending — not yet law

What happened. The Maryland Insurance Administration has a draft regulation that would require every homeowners insurer in the state to file its complete underwriting standards with the Commissioner, and to file again before changing them. The definition of residential property in the draft expressly includes a condominium unit, so unit-owner policies are inside its scope.¹

It has not been adopted. The draft is dated 23 October 2025, the comment period closed 24 November 2025, and as of today COMAR Subtitle 31.08 still ends at Chapter 18 — the proposed Chapter 19 does not exist.²

The draft's own compliance date has already gone by. It required filings “on or before July 1, 2026” — ten weeks ago. Whatever is eventually proposed in the Maryland Register will have to be re-dated.

What it would require

From the draft text:¹

• Insurers “shall file … current underwriting standards for homeowner's insurance … on or before July 1, 2026,” and from that date may not use an amendment unless it has been filed first.
• Filings go through the NAIC's SERFF system under the filing type “Underwriting Guidelines,” with no filing fee.
• An attestation must be signed by an executive employee responsible for underwriting.
• “Residential property” includes … a condominium unit.”
• A parallel obligation for private passenger automobile insurance carries a 1 July 2027 date.

A companion amendment to COMAR 31.08.13.04B would change the notice rule for withdrawing a percentage hurricane deductible from “within 10 days of” implementing the withdrawal to “prior to” it. Authority for both comes from Insurance Article § 27-501(h) and §§ 2-109, 19-209 and 19-209.1.

1. Maryland Insurance Administration, draft COMAR 31.08.19 (Filing of Underwriting Standards) and amendment to 31.08.13.04B, draft dated 23 October 2025 — the 1 July 2026 filing date, SERFF submission with no fee, the executive attestation, and "residential property" including a condominium unit ↩
2. Maryland Insurance Administration, Regulatory Activity — the draft's comment period closing 24 November 2025, and the decision not to pursue proposed COMAR 31.15.11.06 on credit history in underwriting ↩
3. Office of the Attorney General, People's Insurance Counsel Division — comment letter supporting draft COMAR 31.08.19, signed by People's Insurance Counsel Dorianne A. Meloy, 24 November 2025 ↩
4. Maryland Insurance Administration Bulletin 25-14, 16 September 2025 — People's Insurance Counsel Division access to homeowners rate filings via SERFF ↩
5. Maryland Insurance Administration, Market Analysis Unit, Market Hardening Survey Report — Homeowners Insurance Market in Maryland, November 2024 (data period 2021-2024): coastal underwriting restrictions, the Worcester County findings, and the 33.30 percent single-year rise in company-initiated non-renewals ↩
6. Hunter Hine, Ocean City Today — Insurance costs jump 40-150 percent for some OC condos, property managers say (syndicated copy; the syndicated page carries no explicit date, and the article's own content places it in late October 2023) ↩
7. Andrew Schlaffer, ACO Insurance, 26 August 2026 — vendor blog reporting 2 to 5 percent renewals for well-maintained DMV-region condominium buildings and 10 to 30 percent increases on umbrella and excess liability (one broker's book of business, sources named but not linked) ↩
8. Maryland Insurance Administration, Property and Casualty Bulletins index — no 2025 or 2026 condominium-specific bulletin; the most recent are 24-22 (September 2024) and 23-15 (September 2023) ↩
9. Maryland Insurance Administration Bulletin 25-10, 17 June 2025 — Cancellations, Nonrenewals, and Claim Denials Based on Satellite and Aerial Imagery ↩
10. Maryland Insurance Administration Bulletin 26-8, 3 April 2026 — Joint Insurance Association address change and notice requirements, effective 10 April 2026 ↩