What this gives a board, and what it does not

It gives leverage at renewal: a named statute, a stated regulator posture, and a live complaint channel. That is more than most associations facing a wildfire-driven nonrenewal have had.

What it does not give is coverage. CSI has no rate approval authority here, the memorandum compels no insurer to write any particular risk, and it says on its own face that it is informational and does not enlarge or limit applicable law. It is enforcement guidance, not a rule.

One limit to be precise about: nothing in the memorandum mentions condominiums or association master policies. It speaks to “property and casualty insurance” and “insurance consumers” generally. That a master policy is property insurance within § 33-18-210(7) is a reading of the statute's text, not something the memorandum states — and it is the reading a board would be advancing, not one the regulator has confirmed.

The fact pattern the memorandum is aimed at

Read the emphasis carefully, because it defines where the argument is strongest. CSI is concerned about refusals in places not actually exposed — developed municipalities, in-town property, communities whose only connection to a fire was its presence in the same county. An association inside city limits whose master policy was nonrenewed after a regional fire is close to the centre of what the memorandum describes. An association in the wildland-urban interface with genuine exposure is not, and the “degree the property involved is actually threatened” standard cuts against it.

The statutory hook underneath it

Separately from the memorandum, Montana requires written notice before cancellation or nonrenewal of home policies under § 33-23-401, MCA. That is the first provision to look at when a notice arrives, and it is independent of anything the memorandum says.

It is also worth knowing what did not pass. Senate Bill 530, “Generally revise insurance laws relating to nonrenewals and cancellation of certain insurance policies,” died in process on May 23, 2025. So there is no new statutory protection against nonrenewal — which is precisely the exposure the Legislature's HJ 61 interim study is now examining.

Where the market is, per the regulator's own statements

The same office published a consumer piece on May 24, 2025 on rising costs and wildfire risk, and a news item on September 9, 2026 in which the State Auditor urges homeowners to review flood and wildfire coverage — noting that flood insurance does not take effect immediately, so planning ahead matters, and that wildfire protection “is becoming less common in standard homeowners' insurance policies and increasingly expensive.”²

Commissioner Brown has also said that nearly 70 percent of all wildfires recorded in Montana have occurred since 2000, that about half of Montana properties face catastrophic wildfire-damage risk, and that Montana ranks second nationally for the share of homes at risk.

Two practical notes, and one disclosure about our sourcing

• Cite it by title and date. The memorandum carries no bulletin or memo number, and it is not listed on CSI's own advisory-memos index page, whose visible listing stops at 2022. It lives at a 2025 upload path. Do not invent a number for it.
• Complaints are individual. The Consumer Services Bureau channel is how the office learns about a pattern. An association that quietly accepts a nonrenewal it believes was geography-based leaves the regulator with no record of it.

On sourcing: the memorandum PDF is an image-only scan. We read it page by page as rendered images; every quotation above is transcribed from that reading. CSI's index page does not list it, which is why we give the file path itself as the citation.³