The Wyoming sequence this creates

Freddie Mac says out loud why the rule changed: “We recognize that in certain areas, premiums and limited insurance availability are creating challenges for Borrowers and homeowners associations (HOAs).”

For a Wyoming association in a wildfire-exposed community, the chain runs like this, and each link is documented:

1. The admitted carrier non-renews. Wyoming Insurance Commissioner Jeff Rude, on the record: “(Insurance companies) can non-renew for whatever reason they want,” and “Our office has no authority over the rates.”³
2. Replacement goes to surplus lines. Wyoming operates no state residual property market — a full-text search of the Wyoming insurance code, Title 26, for “FAIR plan,” “FAIR access,” “insurer of last resort,” “windstorm pool” and “beach plan” returns nothing. The one residual-market facility named in the code, the Wyoming Assigned Risk Plan at W.S. § 26-45-104(b)(i), is the automobile facility.
3. A surplus-lines master policy carries a large per-unit deductible. That is how the non-admitted market prices catastrophe exposure.
4. If that deductible exceeds $50,000 per unit, the project fails the GSE insurance requirement — and the consequence is not confined to one unit. Every unit in the project becomes harder to finance, not only the one for sale.

The surplus-lines path just got narrower too

On January 22, 2026 Insurance Commissioner Jeffrey P. Rude issued Bulletin 01-2026, “Rescission of All Exemptions Due To Past Non-Competitive Insurance Markets”:

“At this time, Wyoming enjoys a robust insurance market and there are no longer any non-competitive insurance markets in Wyoming. Accordingly, all previously identified exemptions from provisions of the insurance code as a result of non-competitive insurance markets, including but not limited to exemptions from the provisions of W.S. 26-11-104(a)(ii), 26-11-104(a)(iii), 26-11-105, and 26-15-110(d)(iii), are hereby withdrawn, effective immediately.”⁴

A companion Omnibus Order, docket 26-04, vacated the underlying orders from 1985 and 1986. Restoring W.S. § 26-11-104(a)(ii) means the statutory diligent-effort search is back in force for the formerly exempt classes: “The surplus lines broker shall verify that a properly conducted diligent effort search was performed and documented as prescribed by the commissioner.”

One important limit. Every line the Order names is a professional-liability, errors-and-omissions or public-officials line — lawyers, school boards, real estate agents, insurance agents, directors and officers, judges, psychologists, counsellors, pollution and public officials liability. Property insurance, commercial property, habitational and condominium master policies are not among them. Both documents do use the phrase “including but not limited to,” and the Order vacates all orders resting on a non-competitive-market finding, so an unnamed property-related order would be swept in too — but the documents do not identify one.

The rest of the insurance package

Several other requirements moved on March 18, 2026, all effective immediately:

• The inflation guard endorsement requirement is retired in its entirety by both GSEs.
• Roofs no longer require replacement-cost coverage. Fannie: “The master property insurance policy must provide coverage on a replacement cost basis, with the exception of roofs. NOTE: Roofs must be insured, but do not have to be insured on a replacement cost basis.” In a hail state, that is a substantive relaxation.
• Guaranteed or extended replacement cost endorsements are now accepted as proof of 100% replacement cost value.
• Deductible buy-back policies are expressly allowed. Freddie: “PUDs, ground lease communities, condominium HOAs and Cooperative Corporations may purchase a deductible buy-back insurance policy to meet our deductible requirements…”
• General liability and fidelity insurance are not required for projects qualifying for a Waiver of Project Review.

What the Wyoming regulator has and has not published

The Wyoming Department of Insurance’s complete memoranda and bulletins index, running from 1997, contains no bulletin or memorandum on homeowners or condominium insurance availability, wildfire risk, hail or wind deductibles, or nonrenewal notice requirements. The two property-adjacent items that bear on an association roof claim are Bulletin 01-2017 on cosmetic damage exclusions and Memorandum 04.2-2023 on depreciation of labor, and both predate the current market.