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Vermont condominiums got their own flood-loss reporting line

Vermont · Regulation

Vermont condominiums got their own flood-loss reporting line

Vermont now holds a per-zip-code record of condominium flood losses that most states cannot produce, and it exists because the insurance regulator asked for it twice.

Insurance Bulletin No. 233, “Flood and Rain Events Claims Data Call”, was issued on December 18, 2024 by Commissioner Kevin J. Gaffney under 8 V.S.A. § 13, addressed to all licensed and surplus lines property and casualty insurance companies.1

What it required

Reporting of every claim tied to Vermont flooding and rain events with a date of loss between June 22, 2024 and September 1, 2024 — and explicitly not limited to FEMA-designated periods or counties. The first report was due January 31, 2025, cumulative as of December 31, 2024, with a second report reserved. Companies with nothing to report still had to file zeroes.

It followed a data call issued in October 2023 for the 2023 floods, and references the Governor's State of Emergency addendum of July 13, 2024.

The detail that makes it useful

The reporting lines break residential property out by sub-type of insurance, and Sub-TOI 4.0001 is “Condominiums” — reported separately from 4.0002 Mobile Homeowners, 4.0003 Owner Occupied Homeowners, 4.0004 Tenants and 4.0005 Other Homeowners, alongside Dwelling Fire, Commercial Property, Business Interruption, Farm Owners, Private Flood, Federal Flood, Excess Flood, Inland Marine and Crop.

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What is collected, per zip code and town

For each line and date of loss: claims reported, claims closed with payment, claims closed without payment, average days to close, paid loss, case incurred loss, number of total-loss claims, and open claims — plus policies in force as of June 1, 2024. Submission runs through the NAIC portal under the data call group “PAC”, identifier VT_2024_FLOOD.

What a data call changes

A data call does not change anyone's coverage. What it does is make an argument possible.

Vermont is now able to say, at the granularity of a town and a line of business, what condominium flood losses actually were across two catastrophic seasons. Any future Vermont debate about condominium insurability, availability or pricing — and there will be one — starts from a dataset rather than from anecdote. It also means a Vermont association's claims history in a flood-exposed town is visible to its regulator in a way that is unusual.

The gap in the state's own flood explainer

DFR's public education deck, “Homeowners and Flood Insurance Overview”, revised April 2026, is the Department's flagship flood explainer. It names the HO-6 unit-owners form as one of three homeowners policy types and walks through covered and excluded water damage, special flood hazard areas, and the National Flood Insurance Program's Standard Flood Insurance Policy Dwelling Form limits — building $250,000, contents $100,000, other $15,000, Increased Cost of Compliance $30,000, with a 30-day waiting period and “extremely limited” basement coverage.2

It covers only the Dwelling Form. It does not cover the Residential Condominium Building Association Policy — the NFIP master flood policy a condominium association actually buys — and says nothing about master-policy deductibles or HO-6 loss-assessment coverage.

For a Vermont condominium board, the state's best flood explainer skips the policy the board is responsible for.

What Vermont law requires of the master policy

27A V.S.A. § 3-113 is the insurance section, and it applies to communities created on or after January 1, 1999. It is not on either of the § 1-204 retroactive lists, so it does not reach pre-1999 Vermont condominiums — those fall under the Condominium Ownership Act at 27 V.S.A. ch. 15 and their own declarations.

Vermont carries the 1994 uniform text and did not adopt the 2008 uniform insurance revisions. Property coverage is required to the extent reasonably available, keyed to the building structure, and subject to reasonable deductibles — with no statutory ceiling on what “reasonable” means.

What to watch next

Two 2024 bulletins from the July 2024 flood response — #232 on storm-related damages and #231 authorising catastrophe adjusters and appraisers, both dated July 12, 2024 — governed how Vermont association flood claims were adjusted that summer and remain the reference points for how the Department handles the next one.

Related Vermont HOA Topics

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  1. Insurance Bulletin No. 233, Flood and Rain Events Claims Data Call (Dec. 18, 2024) — Vermont Department of Financial Regulation ↩
  2. Homeowners and Flood Insurance Overview, revised April 2026 — Vermont Department of Financial Regulation ↩

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