Why this lands hardest on associations

Because in a Michigan condominium or site condominium, the association owns the roofs through the master policy. Aerial-imagery-driven nonrenewal of a master policy is not one owner's problem; it is the whole project's, and it arrives as a special assessment or as a scramble for surplus-lines coverage weeks before renewal.

Michigan roofs streak. Algae discolouration on asphalt shingles is close to universal on a north-facing slope in this climate, and it has nothing to do with the roof's remaining life. It is exactly the condition an aerial image flags and a physical inspection dismisses.

How a board uses the bulletin

Concretely, when a carrier signals nonrenewal on the basis of roof condition:

1. Ask what the adverse action is based on. If the answer is aerial imagery, ask for the images.
2. Ask whether the carrier's aerial-imagery underwriting rules have been filed with DIFS. The bulletin requires it. A carrier that cannot answer has a problem the association can raise.
3. Demand a physical inspection where the imagery is unclear or disputed. The bulletin says insurers should obtain one; a board asking for it is asking for what the regulator has already said should happen.
4. Get a roofing contractor's written assessment distinguishing cosmetic discolouration from damage. That document is what converts an argument into evidence.
5. Complain to DIFS if the carrier proceeds on cosmetic evidence alone. Unlike LARA, which has no authority over associations at all, DIFS regulates the carrier.

That last point is worth dwelling on. Michigan associations have almost no regulatory recourse against anyone. The insurance carrier is the exception.

Two more DIFS bulletins worth having on file

Bulletin 2024-02-INS (27 March 2024) reset the claim-count thresholds an insurer may use as an underwriting rule for nonrenewal of home insurance, under MCL 500.2117. As of 1 January 2024: three paid claims in the preceding three years totalling $5,000 or more excluding weather-related claims (up from $4,000), or $6,600 or more including them (up from $5,300). The Director resets these every sixth year, so they hold until roughly 2030.

For a board, that is a live consideration on small losses: routing a minor interior water claim through an owner's HO-6 rather than the master policy stacks toward the owner's three-claim trigger, and the trigger moved but did not move much.

Bulletin 2024-26-INS (8 November 2024) addresses the depreciation of labour in actual cash value settlements, which became considerably more important once Fannie Mae and Freddie Mac allowed roofs to be insured at ACV.

What DIFS has not done

Issued anything on condominium master policies, HOA insurance, per-unit deductibles or association property-insurance availability. A review of the complete bulletin index for 2024, 2025 and 2026 turns up nothing. Michigan's association insurance market is under real pressure and the regulator has not addressed it directly.

What to watch next

Whether DIFS extends the aerial-imagery principles to commercial lines. Association master policies are commercial policies, and the bulletin is addressed to personal lines homeowners and dwelling insurers. Its reasoning transfers cleanly; its formal scope does not.