A $50,000 per-unit deductible ceiling arrives for Rhode Island condo master policies
A $50,000 per-unit deductible ceiling arrives for Rhode Island condo master policies
2026-09-15 · Rhode Island · Regulation
A Rhode Island condominium association that has been managing its master-policy premium by raising the per-unit deductible now has a hard number to stay under, and every unit owner in the building has a new policy to buy.
Freddie Mac Guide Bulletin 2026-C, issued March 18, 2026, announced condominium project review and property insurance changes made “in consultation with FHFA and in alignment with Fannie Mae”. Fannie Mae issued its parallel Lender Letter the same day.1
The deductible cap
Effective for mortgages with application received dates on or after July 1, 2026, “but Sellers are encouraged to implement immediately”:
“The maximum deductible requirement of 5% per unit, associated calculation examples and limitation to use the HO-6 coverage cure only when the per unit deductible peril is specific to a geographic area is being retired. If the master property insurance policy includes a per unit deductible, the deductible now may not exceed $50,000 per unit.”
A percentage test has been replaced by a dollar ceiling. For a modest Rhode Island unit that is a loosening; for a high-value waterfront unit it is a tightening, because five percent of a large insured value could previously exceed $50,000 and now cannot.
The per-occurrence rule is separate and unchanged in form: “The deductible(s) for all perils required by Section 4703.2(a) may not exceed 5% of the limit maintained for dwelling coverage.”
Named storms are now a required peril
“Named storms designated by the U.S. National Weather Service or the National Oceanic and Atmospheric Administration by a name or number are a required component of windstorm coverage.”
In a coastal state this is the sentence to read twice. A master policy whose windstorm coverage excludes named storms — or carves them into a separate, uncapped named-storm deductible — is now a project-eligibility problem, not merely an underinsurance problem.
And every owner in a building with a per-unit deductible needs an HO-6
Also effective for applications on or after July 1, 2026: a lender must document that the borrower has an HO-6 unit owner's policy where the master policy “[d]oes not cover all or any portion of the interior of the unit or the improvements to the unit; or…[i]ncludes a per unit deductible”.
Previously the HO-6 requirement functioned as a cure available in limited circumstances. Now the existence of a per-unit deductible triggers it outright.
Two more insurance changes in the same bulletin, both loosenings
Roofs come off replacement cost. “The requirement to ensure roofs on a replacement cost basis has been retired. The master property insurance policy must now provide for coverage on a replacement cost basis, excluding roofs. (Roofs must be insured but do not have to be covered on a replacement cost basis.)” For a Rhode Island association that has been priced out of replacement-cost roof coverage, that is genuine relief on eligibility — and a genuine reduction in what the policy will actually pay after a hail or wind loss.
Inflation guard is gone. “The inflation guard requirement has been retired in its entirety.” The practical effect is to move the job of keeping insured values current from an endorsement onto the board. Nothing now automatically escalates the limit.
Why this collides with Rhode Island law in a specific way
Three Rhode Island facts have to be read together with the bulletin, and together they land the cost on the unit owner.
Rhode Island already moved the master-policy deductible onto owners. P.L. 2025, chs. 177 and 178 (H 5585 and S 0507, both enacted June 24, 2025) added § 34-36.1-3.13(k), requiring unit owners, where the association insures the units, to maintain “[i]nsurance for any amount of loss covered by the association property insurance policy but not payable under the association property insurance policy because of the application of the deductible” — and providing that “[t]here shall be no obligation on an association to apply common expenses related to a unit after a unit loss if the unit owner fails to comply with this section.”2
So Rhode Island statute says the owner carries the deductible gap, and the secondary market now says the owner must document an HO-6 wherever a per-unit deductible exists. Those two requirements point at the same policy. Our Rhode Island insurance requirements page covers what the association must carry.
Rhode Island's hurricane-deductible cap does not reach the master policy. The 5% ceiling on hurricane deductibles in 230-RICR-20-05-13 applies, by its own § 13.2, to “residential property insurance policies insuring dwelling houses”, and “this Part is not applicable to commercial insurance policies.” A condominium master policy is a commercial line. The one Rhode Island regulation capping a hurricane deductible does not constrain the policy on which the biggest hurricane deductibles sit.
And the notice rule runs the wrong way. The same 2025 act requires the association to notify owners of the deductible amount “at least thirty (30) days after notice to the association by the insurance carrier of any change in the association property insurance deductible”, with a statement asserting “the unit owner's legal obligation to notify its mortgagee of the change in any deductible.” Read literally, that is a floor on delay rather than advance warning to owners — and it is worth knowing that several accounts of the 2025 law describe it as a thirty-day advance notice requirement, which is not what the enacted words say.
A Rhode Island board's options, in order
Find out whether your master policy has a per-unit deductible at all. Many do not. If it does not, the $50,000 cap and the HO-6 trigger do not apply to your project, and this is a two-minute answer from your agent.
If it does, get the number and compare it to $50,000. Over the cap means units in the project become ineligible for conforming financing on applications from July 1, 2026. That shows up as a failed sale, not as a letter from anyone.
Check whether windstorm coverage includes named storms by name. Not whether it includes “wind”. The bulletin's requirement is specific to storms designated by name or number.
Tell owners about the HO-6 in writing, and tell them what limit. The statutory duty under § 34-36.1-3.13(k) and the lender documentation requirement now overlap. An owner without deductible-gap coverage is exposed twice: by the statute, after a loss, and at refinance.
Put insured-value review on the annual calendar. With inflation guard retired, nothing escalates the limit automatically. Section 34-36.1-3.13(a)(1) still requires the total amount of insurance after deductibles to be “not less than eighty percent (80%) of the actual cash value of the insured property at the time the insurance is purchased and at each renewal date”.
Remember the thirty-day cancellation floor you already have. Section 34-36.1-3.13(g): an insurer “may not cancel or refuse to renew it until thirty (30) days after notice of the proposed cancellation or nonrenewal has been mailed to the association, each unit owner, and each mortgagee”. That is a statutory protection independent of any regulation.
What to watch next
The 2026 Rhode Island bill that would have clarified deductible allocation further — H 7852 and S 2896 — passed the Senate 37-0 on May 19, 2026 and died in House Corporations. If it returns in January 2027 it will be landing into a market where the per-unit deductible question has already been answered by Freddie Mac and Fannie Mae, which changes what the legislation would be for.
Related Rhode Island HOA Topics
- Freddie Mac Guide Bulletin 2026-C, March 18, 2026 — condominium project and property insurance updates (bulletin text) ↩
- P.L. 2025, ch. 178 (S 0507), enacted June 24, 2025 — amending R.I. Gen. Laws § 34-36.1-3.13 to add subsection (k) ↩
- 230-RICR-20-05-13, Property Insurance and Weather Related Claims — the 5% hurricane deductible cap and its commercial-lines exclusion ↩
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