Missouri covered condo master policies after the storms, then excluded the HO-6
Missouri covered condo master policies after the storms, then excluded the HO-6
2026-09-12 · Missouri · Regulation
What happened. On 4 November 2025 the Missouri Department of Commerce and Insurance extended its post-storm cancellation moratorium to condominium master policies, after complaints that condominium complexes across the state were being nonrenewed while their claims were still open. In the same document it drew an explicit line: individual unit owners' HO-6 policies were not covered.1
The document is Insurance Bulletin 25-11, “Addendum: Post Storm Cancellations and Non-Renewals,” issued by Director Angela L. Nelson. It is the only Missouri agency action in the last twelve months whose operative text is addressed to community associations as such.
Who it was written to
The bulletin's own “To” line:
“All property and casualty insurers writing homeowners and dwelling insurance covering residential properties and property and casualty insurers writing Condominium Master Policies”
And its subject line:
“Addendum: Post Storm Policy Non-Renewals and Cancellations for homeowners and dwelling policies covering residential properties and master policies issued to condominium owners/associations”
Why it existed
The Department's predecessor bulletin, 25-10 of 13 October 2025, had covered “homeowners and dwelling insurance covering residential properties” — the policy an individual owner buys. That left association master policies outside. Three weeks later the Department explained the gap in its own words:
“The Department has received multiple complaints indicating that condominium complexes throughout the State of Missouri have received non-renewal or cancellation notices. These are for master policies issued to the condominium owner/association and not policies issued to individual condominium unit owners.”
“The Department understands these condominiums are still in the process of negotiating their damage claims with their insurance companies or are in the process of completing repairs.”
The extension itself:
“…the provisions of Bulletin 25-10 are hereby extended to apply to master policies issued to condominiums located within the State of Missouri…”
The line boards got wrong
“This extension does not, in any way, apply to Condominium Homeowners policies (commonly referred to as an HO-6 or its equivalent).”
And the scope confirmation:
“…with the issuance of Bulletin 25-11, that scope also includes master policies issued to condominium owners/associations, as further detailed in this Bulletin. No other insurance policies covering other properties or risks are included within the scope at this time.”
What it said about reinstating coverage already cancelled
This is the provision most likely to matter retrospectively to a board:
“The Department has also received questions about how far back insurers are expected to reinstate coverage. The Department reminds insurers of the intent behind both Bulletins, which is to ensure that property owners who have been unable to complete repairs (for any multitude of reasons) have insurance coverage and that they are not forced to secure coverage for a home that still has unrepaired damage.”
The Department said it “expects insurers to consider the individual facts and circumstances and use their best judgment in extending or otherwise reinstating coverage,” and that insurers “will be asked to provide an explanation for why coverage was not extended or reinstated” where they did not.
What the protection actually was, and for how long
The underlying directive, from Bulletin 25-10:
“Effective immediately, insurers in this State shall not issue a cancellation or non-renewal of a policy covering a residential property that was damaged by a storm until otherwise notified by the Department or this Bulletin is rescinded.”
“This directive applies to a residential property located anywhere within the State of Missouri for any storm or weather losses occurring after March 1, 2025, and is specific to those underwriting actions taken on the basis of claims activity and/or the condition of the property.”
“To the extent such actions have been processed and/or notices mailed, insurers are directed to take all necessary actions to ensure coverage remains in force and to notify impacted policyholders.”
The exceptions, also verbatim: “This moratorium does not apply to properties not damaged by this years' storms; it does not apply to cancellations due to non-payment of premium and should not be interpreted as a permanent moratorium.”
Condominium master policies were inside it from 4 November 2025 until 31 May 2026 — 209 days. Individual homeowners and dwelling policies were inside it from 13 October 2025, for 231 days. Both were rescinded effective 1 June 2026.
The four things this document still tells a board even though it is rescinded
- There is a retrospective claim in here. An association whose master policy was nonrenewed or cancelled on the basis of claims activity or property condition between roughly March 2025 and 31 May 2026 was, on the Department's own stated expectation, entitled to have that action reversed and coverage kept in force or reinstated. Insurers were told they “will be asked to provide an explanation” where they did not. That expectation existed at the time the decision was made, and rescission of the bulletin going forward does not change what was expected then.
- The complaint channel is named in the document. The Market Regulation Division, [email protected]. A board with a nonrenewal inside the window has a specific document, a specific date range and a specific division to write to.
- Non-payment was never covered, and that is the exclusion that applies first. A cancellation for non-payment of premium was outside the moratorium from the start. An association whose master policy lapsed during a cash crunch has no argument here.
- Tell unit owners the truth about their own policies. The HO-6 was expressly excluded. A board that reassured owners in the winter that “the state has stopped cancellations” should correct that if it has not already: the association's master policy was protected, each owner's own policy was not.
The mechanism, and why it was always going to end abruptly
The bulletin tied its own expected lifespan to the Governor's emergency declaration, and said so:
“…refers to Executive Order 31, issued by Governor Mike Kehoe on October 29, 2025. This Executive Order extends the State of Emergency within the State, due to 'ongoing conditions of distress and hazard to the safety, welfare and property of the Citizens of Missouri.'”
“…but in terms of guidance, the Department anticipates Bulletin 25-10 and Bulletin 25-11 will remain for at least as long as a State of Emergency exists within the State. Executive Order 31 is currently set to expire on December 31, 2025, unless otherwise extended.”
It was extended, repeatedly, and the bulletins outlived that December date by five months. Then the chain stopped and the protection stopped with it.
A distinction that will mislead anyone reading the news
Do not conclude that Missouri's state of emergency ended. Several were active in June and July 2026 — the Governor declared new emergencies for severe storm systems on 19 May, 10 June and 10 July 2026, among others. What ended on 31 May 2026 was the specific March 2025 storm-recovery emergency chain, and the Department had tied the insurance moratorium to that chain rather than to whichever emergency happens to be live.
So the accurate statement is narrow: the moratorium was rescinded because the emergency it was anchored to was allowed to lapse, not because Missouri stopped having storms or stopped declaring emergencies about them.
What this tells you about Missouri's regulatory landscape for associations
We searched every state agency that could plausibly touch a community association — the Department of Commerce and Insurance, the Attorney General's formal opinions, the Real Estate Commission, the Division of Professional Registration, the Secretary of State's Missouri Register, the Department of Natural Resources, the Public Service Commission, the Housing Development Commission. Twelve months of output produced exactly one document whose operative text is addressed to community associations: this one.
It was guidance rather than a rule. It disclaimed the force of law on its own face under section 374.015, RSMo. It lasted 209 days. And it has been rescinded.
What to watch next
Whether a future Missouri storm emergency produces a new bulletin, and whether it names condominium master policies again from the start rather than three weeks late. The Department needed complaints from Missouri condominium associations to discover that its first bulletin had left them out; a board that finds itself in that position again should complain early rather than wait for someone else to.
Related Missouri HOA Topics
- Missouri DCI Insurance Bulletin 25-11, “Addendum: Post Storm Cancellations and Non-Renewals” (Nov. 4, 2025) ↩
- Missouri DCI Insurance Bulletin 25-10, “Policy Non-Renewals and Cancellations” (Oct. 13, 2025) ↩
- Missouri Executive Order 25-31 (Oct. 29, 2025) — the emergency extension the bulletin cites by name ↩
- Missouri DCI press release (Oct. 13, 2025) accompanying Bulletin 25-10 ↩
Stay on top of Missouri HOA law
Every week: new Missouri legislation, court rulings, and regulatory developments affecting condos, planned communities, and property managers. Free.
No spam. Unsubscribe anytime.