The vendor clause, which is the sharpest line in the bulletin

“Lastly, the Department reminds insurers that this bulletin applies to not only their direct use of aerial imagery, but also the use of any third-party roof scores or similar mechanism that leverage aerial imagery to generate the information provided to the insurer.”

That closes the obvious route around the rule. An insurer that does not look at an image, but buys a roof score derived from one, is inside the bulletin.

Claims, not just underwriting

The same standards apply to settlement, under a different statute:

“If aerial or satellite imagery is used in the settlement of a claim, those images must provide a clear, accurate, and current view of the property. Images of insured property that are low-resolution, out-of-focus, blurry, or not current do not provide an accurate and clear representation of the property, and thus cannot alone be used to determine a claim settlement or denial. Failure to follow these standards may constitute a violation of R.I. Gen Laws Chapter 9.1 Unfair Claims Settlement Practices Act.”

What the bulletin only encourages

Four practices are framed as best practice rather than requirement, and the difference matters to a homeowner. Where an insurer uses aerial imagery as a basis for non-renewal, beyond complying with statutory notification requirements, it is “best practice” to notify the homeowner before initiating the action, to provide the images used, and to allow the homeowner to provide updated information or dispute the imagery's accuracy. Insurers are “encouraged” to issue loss-control recommendations and to allow reasonable time for repairs before non-renewing.

So the right to see the photograph that cost you your policy is a recommendation in Rhode Island, not an entitlement. Asking for it is still the first thing to do.

The limit that matters to a condominium board

The bulletin is addressed to “homeowners insurance” and “homeowners insurers”. The words “condominium” and “association” do not appear in it.

A unit owner's HO-6 policy is a homeowners policy and is comfortably within the bulletin's subject matter. A condominium association's master policy is a commercial line, and whether the bulletin reaches it is not answered by its text. That is a genuinely open question and the obvious one to put to the Insurance Division.

What does protect the master policy is elsewhere, and it is worth knowing precisely because it is stronger than most boards realise:

The Condominium Act's own notice floor. 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 or beneficiary under a deed of trust to whom a certificate or memorandum of insurance has been issued.” Not just the association — every unit owner. Our Rhode Island insurance requirements page covers the section.

The commercial-lines regulation. 230-RICR-20-20-1 reaches commercial property policies and requires a non-renewal notice “at least sixty (60) days before the expiration date”, with coverage continuing sixty days past notice if it is late. Cancellation after sixty days in force requires an enumerated ground, which includes “[a]ctivities or omissions on the part of the named insured which increase any hazard insured against, including a failure to comply with loss control recommendations” and “[c]hange in the risk which increases the risk of loss.”

With one gap worth naming. That regulation does not apply to surplus lines policies. Coastal Rhode Island master policies that land in surplus lines get no notice protection from it — though § 34-36.1-3.13(g) still applies, because it binds the insurer by statute rather than by regulation.

What this means for a board and an owner

Boards: read the loss-control letter, and answer it. “Failure to comply with loss control recommendations” is an enumerated cancellation ground on a commercial policy. A recommendation ignored is a ground created.

Boards: photograph your own roofs. Dated, clear, ground-level and drone imagery in the association's file is the cheapest available answer to a stale aerial image. The bulletin's fifteen-month standard cuts both ways — it tells you what the insurer's evidence has to be, and it tells you what yours should look like.

Owners: ask for the image. On an HO-6 non-renewal citing roof condition, the bulletin gives you the standards to test it against — currency, resolution, and whether what is visible is cosmetic streaking or material degradation.

Both: remember what is not in the bulletin. It regulates how imagery may be used. It does not require any insurer to write any policy, and it does not cap a premium.

What to watch next

Rhode Island issued only two insurance bulletins touching property owners in 2025 — this one and Bulletin 2025-4 on legislative changes, issued October 16, 2025 — and none at all in 2026 on homeowners or condominium insurance. Whether the Division extends the aerial-imagery standards to commercial residential policies, by bulletin or by regulation, is the single change that would most help a Rhode Island association. It has not happened yet.