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Insurance for Community Associations Articles

Property & Casualty Articles

  • What is a Covered “Collapse” for Insurance Purposes? July 13, 2012 Recently, the Fifth District Court of Appeal issued the opinion of Kings Ridge Community Association v. Sagamore Insurance Company, clarifying what constitutes a covered “collapse” under an All Risk Business Owner’s policy. On February 24, 2010, the association’s clubhouse began to shake, which was apparently caused by a failure of the roof trusses, which had deflected downward by approximately twelve inches. As a result, the drop ceiling and soffits deflected downward, and there was a substantial depression in the flat roof. Read ...
  • HOA Insurance Victimization June 20, 2012 An oft repeated scenario in common wall communities is water damage which originates from a neighboring unit. Whether a broken pipe or washing machine hose, surf’s up! and usually between midnight and 4 am (disasters are funny that way).  Read More……

Property & Casualty Article Archives


Directors & Officers Insurance Articles

  • Condominiums and Conflicts of Interest: How to interpret the rebuttable presumption (FL) October 9, 2017 The legislature recently amended Chapter 718 of the Florida Statues, relating to condominiums, to create a rebuttable presumption that a conflict of interest exist in certain situations. A conflict of interest is a real or seeming incompatibility between one’s private interests and one’s public or fiduciary duties. Black’s Law Dictionary (10th ed. 2014). For example, if a board member owns a landscaping company that provides services to an association, the board member’s private interest in obtaining a profit may be ...
  • Problem Boards: What to Do When Your Board Breaks the Rules October 5, 2017 A condominium, cooperative, or homeowners’ association elects a board for a specific purpose: to manage the community’s day-to-day business, oversee special projects, and draft and uphold the rules and regulations that keep life orderly and harmonious. In fact, the board has an inflexible fiduciary duty to act in the best interests of the community as a whole.  This means that boards have an obligation to stay consistently on the side of good, advocating for residents and promoting neighborly well-being – ...
  • A Guide To HOA Board Responsibilities October 3, 2017 Serving on the board of a homeowner association is a high calling. Well meaning volunteers are elected to roles that are critical to the well being of the HOA. But what exactly is a board member supposed to do to fulfill this charge? Here’s a handy guide:    Read the article………………
  • FAQs on HOA Board Member Roles and Responsibilities October 1, 2017 The president leads the Board and is responsible for overseeing and handling many of its procedural duties. In order to succeed in this role, the Board president must be knowledgeable about the community’s CC&Rs and governing documents and understand how to run an effective meeting. He or she serves as the authority on all association rules and governing documents, and appoints committees if dictated by the bylaws. The president also leads community and association meetings, handling such responsibilities as calling ...

Directors & Officers Insurance  Article Archives

Condominium Insurance Law

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  • Tue, 26 Sep 2017 11:00:38 +0000: Property Managers Fees and Property Insurance Claims - Condominium Insurance Law

    Property managers often include extra fees in their management agreements when having to help an association through an insurance claim and reconstruction. My experience has been these fees have risen significantly from extra hourly costs to as much as ten percent. While some may argue that a property manager is neither trained nor licensed to adjust claims and that property management firms may be practicing law or public adjusting without a license, the issue for recovery of these fees is important.

    In Capitol Property Management Corporation v. Nationwide Property & Casualty Insurance Company,1 a federal trial court held that a condominium association’s property insurance did not provide coverage for its manager’s fees for processing insurance claims and managing construction following a fire. There, the Association had a fire and the management company filed a claim with the association's insurance company. The insurer paid the construction costs except for the property managers extra fees associated with the claim and the construction oversight.

    The property management contract provided the property manager with a 10% fee for processing the insurance claims and another 5% for acting as the association's construction manager. While the property manager argued that the claims fees were similar to an extra expense and that the oversight of the construction was a construction expense related to supervision, the court held that neither fee was a direct result of physical damage.

    The total 15% fee seems ridiculously high and may have entered into the court's view of the matter. After a loss occurs, property managers usually have overtime and extra work duties not a result of normal operations, but specifically work directly caused by the physical damage. Had the bill to the association and the case been presented with overtime charges rather than a percentage, the result may have been different.

    Boards should be careful to look at all the costs which property managers place into their contracts. The percentage payment of an insurance recovery to the property manager—agreed to in advance—may not be allowed in the by-laws. Generally, only licensed public adjusters and attorneys at law may negotiate an insurance claim for a policyholder.

    1Capitol Property Management Corporation v. Nationwide Prop. & Cas. Ins. Co., No. 1:16-cv-00664 (E.D. Va. Jun. 5, 2017).
  • Mon, 21 Aug 2017 11:00:43 +0000: Assessments Following Catastrophe Losses in Texas - Condominium Insurance Law

    Does an HOA have power to levy assessments following catastrophe losses? In Texas, the answer will likely be, yes. This much was also found true when a homeowner’s association for Leawood Condominiums sued a unit owner for failure to pay assessments in Akhtar v. Leawood HOA.1

    In this case, Hurricane Ike had damaged common elements such as the roofs, gutters, and siding on multiple buildings of the Leawood Condominiums. With a $500,000 deductible, no reserve, and insufficient insurance proceeds, Leawood Association turned to the unit owners to collect the funds necessary to commence repairs. Although 99% of the owners paid the assessments, Akhtar, the owner of 6 units, refused to pay the assessment claiming the HOA required a two-thirds homeowner’s vote to approve any assessment. The Association filed suit to collect the assessment and the court found for the Association.

    On November 12, 2012, Leawood sent a letter to all unit owners in the development explaining that a “Special Assessment for each unit Homeowner[] due to Hurricane Ike damage must be assessed.”2 Shortly after, on February 6, 2013, Leawood sent a second letter clarifying that, according to the declaration, the assessment was not simply a ‘special assessment,’ rather a pro rata assessment based on the size of each unit to recover the insurance deductible. The precise issue before the appellate court became whether the HOA had power to levy an assessment to collect the insurance deductible.

    Typically, provisions giving authority for an HOA to levy assessments are included in the governing documents of the association. Here, the unambiguous language of the declaration provides that in the event of any conflict between the declaration and by-laws, the declaration prevails. Notably, defaulting to the language of a declaration is consistent with the Tex. Prop. Code §82.053(c) (“If there is a conflict between the provisions of the declaration and the bylaws, the declaration prevails except to the extent the declaration is inconsistent with this chapter.”) The court reviewed the declaration in accordance with the relevant provisions of the Tex. Prop. Code.

    Specifically, Section 6.1(b)(2) of the Declaration imposes a duty on Leawood to repair the common elements of the development after a disaster damages or destroys less than sixty-six and two-thirds percent of all common elements. Since the actual damage caused by Hurricane Ike amounted to $600,000 or 2.2% of the insures value of the property, the court determined Section 6.1(b)(2) of the declaration governs Leawood’s conduct following the hurricane.3 Section 6.1(b)(2) also imposes a duty to recover any deficiency in insurance proceeds after a disaster by means of an assessment against “all of the Owners and Condominium Units.” The same section requires that such a “deficiency assessment shall be a special assessment made pro rata according to each Owner’s proportionate interest in and to the Common Elements,” and “Leawood shall have the authority to cause the repair or reconstruction of the improvements using all of the insurance proceeds for such purpose notwithstanding the failure of an Owner to pay the assessment.”4 Likewise, Section 6.1 of the declaration mirrors the Texas statutes. For example, Tex. Property Code 81.206(a) provides that “if a building in a condominium regime is damaged by a casualty against which it is insured, the proceeds of the insurance policy shall be used to reconstruct the building.” Continuing to Tex. Property Code 81.207(a), which reads:

    If under Section 81.206 a damaged building in a condominium regime must be reconstructed but insurance proceeds are insufficient to pay for the cost of reconstruction, the apartment owners directly affected by the damage shall pay the difference between the cost of reconstruction and the insurance proceeds … Each affected [unit] owner shall contribute an amount for reconstruction that is proportionate to the interest of the apartment owner in the condominium regime.5 (emphasis added)

    Considering the statutes and language in the declaration, the appellate court found “Leawood had no discretion regarding whether to repair the common elements, nor did it have any discretion as to how to pay for such repairs.”6

    You’ve probably picked up on the fact that Texas laws operate similar, if not identical, to the declaration in Akhtar v. Leawood. In fact, in Texas, the association provisions governing assessments need not exist, as the Texas Property Code grants associations the authority to impose interest and late charges for payments of assessments and even grants HOAs the right to amend any rules regulating delinquent assessments.7 Even more so, the Tex. Property Code also gives authority to “suspend the voting privileges of or the use of certain general common elements by an owner delinquent for more than 30 days in the payment of assessments.”8

    On the flip side, Chapter 82 of the Tex. Prop. Code, entitled the ‘Texas Uniform Condominium Act,’ establishes the parameters for unit owners regarding assessments, including the unit owner’s duty to “pay assessments, interest, and other charges properly levied by the association against the owner or the owner’s unit, and shall pay periodic assessments without demand by association.”9

    If you are in the market for a condominium unit, potential buyers should be aware of an Association’s ability to levy assessments—independent of the already established periodic assessments—following a catastrophic loss in Texas.

    1Akhtar v. Leawood HOA, Inc., 508 S.W. 3d 758 (Tex. App. 2016).
    2Id. at 761 and 762.
    3Id. at 764.
    4Id. at 764 and 765.
    5 Tex. Property Code 81.207(a) (emphasis added).
    6Id. at 765 (emphasis added).
    7 Tex. Property Code 82.102(12)- (15).
    8 Tex. Property Code 82.102(18) (emphasis added).
    9 Tex. Property Code § 82.117(1) (emphasis added).
  • Mon, 14 Aug 2017 11:30:49 +0000: Dealing with Insurance Agents as a Property Manager and Association Board Member - Condominium Insurance Law

    Insurance agent relationships between property managers and association boards are important. Insurance agents are required to obtain the best coverage at the best price. The problem is when different insurance agents, competing for business, start telling property managers and association boards different things about the insurance in place and comparing insurance coverages.

    Here are some basic rules when it comes to dealing with insurance agents when purchasing Association insurance:

    1. Make certain the agent is given all your bylaws. In writing, ask the agent to review the by-laws and obtain quotes for the coverages and properties required in the bylaws and state statutes.

    Merlin Law Group attorney Corey Harris' mother is a director at Edgewater Condominium in Destin, Florida. She has a form letter she requires any agent providing proposals to confirm in writing they have obtained the coverages required in the by-laws and as required by state law. She asks that all the Association property required to be insured not be excluded property but insured, even if by endorsement.

    Often, many association policies fail to cover all association property. The policies have a section for "property not covered." If the by-laws or state law requires that property be covered, endorsements need to be added to cover things like fences, pools and whatever is required to be covered.

    Exclusions and limitations of coverage can lead to a better price. It is fine to purchase "cheap" insurance if it is your own property, but Association Boards and property managers have to purchase the mandated coverage in the by-laws or required by state law and can only avoid that obligation through waivers in a manner allowed in the by-laws which usually requires notice and votes by all the association members.

    2. Ask the agents to confirm in writing your understanding of what they are saying so you get away from oral promises and oral "misunderstandings." If you have a question, put it in writing. If they have an answer, it should be confirmed in writing for the benefit of all.

    If you are contemplating changing agents, make certain that they have agreed to abide by the instructions as stated in point one above. Then, if they are making comparisons, ask that those only be made in writing so all board members can view them and the property manager can safely rely on written acknowledgements of coverage rather than oral promises which can be misunderstood or not complete.

    Agents who will not agree to deal in writing should not be association agents. As pointed out in Homeowner Association Managers, Agents and Officers Beware - Check Insurance Requirements to Avoid Lawsuits From Individual Members!!, board members and property managers can be liable for not obtaining the proper coverage. What is often not told is that many Board and property manager errors and omission policies exclude coverage for this omission. You can be personally liable for not following by-laws. So, only deal with agents that understand your concern and your significant legal responsibility.

  • Wed, 12 Oct 2016 11:52:30 +0000: Property Managers' and Condominium Association Leaders' Hurricane Matthew Dilemma - Financing the Repair Before the Insurance Company Pays - Condominium Insurance Law

    Property managers and condominium leaders will face an issue after Hurricane Matthew becoming all too recurrent following catastrophes—slow and underpaying property insurance carriers. While partial payments for small percentage amounts of easily agreed to damages are often made, full payment made within 90 to 120 days is almost non-existent with significant losses. Who can wait for that long to start substantial repairs?

    A further problem facing most coastal apartments, condominiums, and homeowner associations is the large windstorm deductible which will likely apply. A five percent deductible does not seem large, but when applied to a large building with millions of dollars as the policy limit, the deductible amounts can wind up in the hundreds of thousands of dollars. Insurance agents should always obtain quotes for "deductible buydown coverage." Many insurance agents fail to do this (which is clearly malpractice by insurance agents) and some in management decline the coverage after considering the quoted premium cost.

    Faced with non-payment of insurance funds and large deductibles, the issue arises regarding how to pay for repairs which need to be completed immediately. The answers are not perfect, but I will try to highlight some considerations.

    The insurance restoration industry and contractors will push that the answer can easily be found by using an assignment of benefits clause in a construction contract. Simply sign a construction contract for all repairs less the deductible and assign the benefits of the policy claim to the restoration contractor. Assignment of benefit clauses are allegedly giving rise to and supporting fraudulent practices, "gaming" the insurance adjustment process, being overly broad and often civilly or criminally illegal. Richard "Dick" Tutwiler wrote a guest blog on the topic from the standpoint of public adjusters in The Unlicensed Practice of Public Adjusting - The Insurance Claims Keep Rolling In.

    I have warned that such contracts are now under attack and giving rise to class action lawsuits by disgruntled policyholders. Any contractor using one of these contracts should read my post, Unauthorized Practice of Public Adjusting and the Lon Smith Roofing Case Should Scare Contractors and Roofers with Contingent Contracts.

    Managers and association leaders should be concerned about the scope of repairs promised to be accomplished. It is critical that they thoroughly check the references of any such contractor and interview multiple contractors if they choose to accept this route of repair. Merlin Law Group attorney Nicole Vinson wrote an analysis of this in Policyholders Should Be Aware of Assignment Provisions.

    Associations could consider using reserves. For example, if the association has half of a roof replacement already reserved, why shouldn't it be able to tap into those reserves to finance the repair or replacement of association property? This is a complicated area and I suggest that property managers and association boards consult with an experienced condominium attorney. I called Donna DiMaggio Berger of the well-respected condominium law firm, Becker Poliakoff, for her opinion.

    Berger stated that, in Florida, the emergency powers of the Association President and Board are very broad following a catastrophe and during an emergency situation so long as the Governor has stated that an emergency exists. During such times, they may authorize, without prior association member vote, using reserve funds for emergency repairs. The warning is there needs to be an emergency and an Order in place at the time. Otherwise, using reserve funds usually requires member approval through a vote pursuant to association by-laws. My advice is to get a condominium lawyer like Donna Berger to guide you through the process because she warned that "mistakes" can lead to fines and personal liability.

    Alternatively, I have suggested to many of my past commercial property owner and association clients they obtain a credit line for emergency construction. Donna Berger agreed this is an excellent avenue for most Associations, but that the credit line should be obtained in advance to speed up the process.

    Finally, special assessments can be made on association members to cover the shortfall of deductibles. These assessments can also provide interim funding of repairs caused by non-paying and slow paying insurance companies. This may be covered under loss assessment coverage, as noted in Florida Law Requires Loss Assessment Coverage for Condominium Unit Owner Policies. Loss assessment coverage usually pays up to a limited amount for the special assessments required as a result of the Association not purchasing or not having enough coverage under the master policy. However, some recent individual policies exclude coverage for assessments made to cover the shortfall of deductibles, and members purchasing this cheap form of condominium insurance will suffer out-of-pocket losses.

    There is no easy answer on which is the best alternative for quickly obtaining funds to pay for the repair, but there are alternatives to just doing nothing. It is my experience that getting repairs underway and finished right away is far better for association morale and welfare. Getting repairs completed, even when insurance companies do not pay, helps put rental income into the pockets of apartment and commercial building owners and prevents many tenants from cancelling leases resulting in lost revenues once the repairs are completed.

    Positive Thought of the Day

    If your actions inspire others to dream more, learn more, do more and become more, you are a leader.
                 —John Quincy Adams

  • Fri, 23 Sep 2016 10:30:14 +0000: Court Decision on "Your Work" Exclusion in a CGL Policy is a Head Scratcher - Condominium Insurance Law

    In Essex Insurance Co. v. DiMucci Development Corp. of Ponce Inlet Inc., U.S. District Judge Roy B. Dalton Jr. recently held that Evanston Insurance Company has no duty to defend a builder in a lawsuit alleging construction defects at one of its Florida condominium complexes based on an exclusion in the policy for damage to the developer’s own work.1

    The lawsuit arose when DiMucci Development Corp. of Ponce Inlet Inc. (“DiMucci”) was sued by the homeowners' association at the Towers Grande high-rise in Daytona Beach Shores, Florida, for various construction defect related issues.

    The construction defect lawsuit alleged that DiMucci ‘s work was defective on a portion of the high rise condominium complex and that the defective work caused property damage to other portions of the building that DiMucci also had constructed. More specifically, the Towers Grande Condominium Association alleged that DiMucci ‘s defective work resulted in damage to the roof and HVAC systems, as well as multiple water intrusion issues purportedly tied to poor waterproofing.

    DiMucci had held three consecutive CGL policies with Evanston predecessor Essex Insurance Company between 2003 and 2005. During that time, DiMucci constructed Towers Grande, a 132-unit condominium building, with subcontractor Wayne's Roofing and Sheet Metal handling the roofing work.

    After DiMucci tendered a claim for defense and indemnity to its general liability insurance company (Evanston), Evanston filed suit in Florida federal court in September 2014, seeking a ruling that its policy excluded coverage and therefore it had no obligation to defend or indemnify DiMucci.

    After the parties filed cross motions for summary judgment, the trial court ruled that the so-called "your work" exclusion in DiMucci's CGL policy with Evanston precluded coverage because the underlying construction defect complaint only alleged damage to the builder's own work. The court found that the Your Work exclusion barred coverage, and that Evanston had no duty to defend or indemnify DiMucci.

    This decision is notable because it takes the interesting position that because DiMucci constructed the entire high-rise—even though the defective construction caused damage to other parts of the high-rise—the exclusion applied not only to the portions of the high-rise where the defective work appeared, but even to the consequential damage to other parts of the high-rise caused by the defective construction work.

    This decision is at odds with the law of numerous jurisdictions including (1) California (see Blackfield v. Underwriters at Lloyd's, London, 245 Cal. App. 2d 271, 273, 276 (1st Dist. 1966) - where defective construction is at issue, the “your work” exclusion only applies to the defective work itself, not the consequential damage caused by the defective work. [insured builder of tract home constructed home with defective fill/foundation; this caused the remainder of the house to suffer cracking, slanting, windows and doors could not be opened. Coverage for damages to the “other parts” of the house covered, i.e., not excluded]) (2) New Jersey (see Cypress Point Condominium Assoc. Inc. v. Adria Towers, 226 N.J. 403 (N.J. August 4, 2016), and even (3) Florida (United States Fire Insurance Co. v. J.S.U.B., Inc., 979 So.2d 871 (Fla.2007), and Auto–Owners Insurance Co. v. Pozzi Window Co., 984 So.2d 1241 (Fla.2008) both hold that faulty workmanship or defective work that has damaged the otherwise non defective completed project has caused ‘physical injury to tangible property’ within the plain meaning of the definition in the policy)) to name a few.

    Policyholder advocates need to be aware of the authority interpreting and applying the so called “work product” exclusions as well as the fact that numerous jurisdictions permit coverage for consequential damage caused by defective workmanship even when coverage for the defective workmanship itself might otherwise be excluded.

    1  Essex Insurance Co. v. DiMucci Development Corp. of Ponce Inlet Inc., No. 6:15-cv-00486 (M.D. Fla. Sept. 13, 2016).

Condominium Insurance Law Archives

General Liability Insurance Articles

  • Fiduciary Duties 101 – Limiting the Liability of the Board November 15, 2017 A fiduciary duty creates an obligation to act for another’s benefit. A board of director’s fiduciary duty is to the association and its members. So what are the core duties of an association director? Individual loyalty, good faith and fair dealing in conducting the association’s business, care, and obedience to follow and enforce the association’s documents.     Read the article……………
  • Conflicts of Interest (IL) September 6, 2017 The Illinois Condominium Property Act (the “Condominium Act”) does not provide complete guidance on when a board decision may be invalidated due to a conflict of interest. Therefore, a court, when deciding if a decision should be set aside due to a conflict, looks to the General Not for Profit Corporation Act of 1986 (the “Not For Profit Act”).    Read the article……………..
  • East Bay Panel Update – Director Liability August 31, 2017 Two weeks ago, I met with a great group of ECHO members at our East Bay Resource Panel. We were gathered to talk about the recent Parth case and how it affects the personal liability of HOA directors. Ann Marquis-Fisher, chair of the Panel and president of her HOA, invited attorney Mark Wleklinski to speak about the case, and David Stompe (link is external) to discuss the insurance implications.     Read the article………….
  • Community Association Liability For Dog Bites – Woof, Woof, Woof August 29, 2017 Can a Florida condominium, homeowners’, and cooperative association have liability for its members’ dog bites? Apparently, the answer is yes, it surely can.  In 1996, the Fourth District Court of Appeal of Florida in Barrwood Homeowners Association, Inc. v. Maser, held that an association could be found liable where there was sufficient evidence from which a jury could determine that it was aware of a dog’s vicious propensities. In this case, there was a dog attack and bite to a ...

General Liability Insurance Articles Archives


Insurance – General Articles

  • No flood insurance for the condo? It’s potentially negligent to go uncovered (FL) November 18, 2017 Q: We own a unit in a small condominium. Until recently, we have had flood insurance although we are not in a flood zone. Now a new owner is pushing for it, and the board is caving in. Are they legally required to have flood insurance if most owners do not want to pay the extra expense through our dues?      Read the Q&A…………..
  • No flood insurance for the condo? It’s potentially negligent to go uncovered (FL) November 16, 2017 Q: We own a unit in a small condominium. Until recently, we have had flood insurance although we are not in a flood zone. Now a new owner is pushing for it, and the board is caving in. Are they legally required to have flood insurance if most owners do not want to pay the extra expense through our dues?    Read the Q&A…………..
  • Hurricane Insurance, Part 2: 4 Tips for Ensuring Comprehensive Hurricane Insurance Coverage November 14, 2017 When hurricanes roll in, violent weather in the form of extreme rain and high-speed winds results in loss of life and property alike. We saw the devastating results near the end of this year’s hurricane season during Tropical Storm Lidia, Hurricane Irma and Hurricane Harvey, and people who were affected are still rebuilding their homes and their lives.  Before another wave of storms makes landfall next hurricane season, take time now to review your current insurance policies relevant to hurricane ...
  • Hurricane Insurance: 6 Tips for a Successful Claims Process November 14, 2017 In the wake of Hurricane Harvey, Hurricane Irma and Tropical Storm Lidia, many board members and homeowners are now left dealing with the destruction these storms left in their wake – it’s estimated that Hurricane Irma alone caused more than $62.87 billion in damages, and these storms combined killed hundreds of people. Even though these extreme weather events struck in late August and early September, the damage will take months to restore at the very least, and working with insurance ...

Insurance – General Articles Archives


Owners Insurance Articles

  • Some owners looking to blame others after Hurricane Irma (FL) November 4, 2017 Many Southwest Florida condominium and homeowners’ association owners suffered damage to their unit, home, cars or other possessions as a result of Irma’s wrath.  While most understand that hurricanes are considered no-fault “acts of God” that caused their damage, there have been a few who what to try to have someone else cover their costs of repairs by trying to find fault with their governing association or their neighbor.     Read the article………………..
  • With Insurance Claims, Time Is of the Essence October 17, 2017 In our upcoming special November issue, “Governing Powers Through a Legal Lens,” several prominent lawyers advise boards and the residents of co-ops and condos on the vagaries of establishing liability for leaks, fires, and other unwelcome mishaps. Their advice, though varied, contains a thread: when filing an insurance claim, time is of the essence.    Read the article……………….
  • Loss Assessment Insurance October 6, 2017 You live in a condominium association and happily (ok, probably not “happily”) pay your dues each month. Your board has diligent members and your association is well insured. What could go wrong? Well, lots can go wrong, unfortunately. Life is full of unexpected twists and turns. A slip and fall accident might find the association on the wrong side of a lawsuit. Or, the association might discover hidden property damage that must be repaired. There is a myriad of unforeseen ...
  • 5 Ways Hawaii Condo Dwellers Can Protect Themselves September 19, 2017 When I accompanied our daughter in her search to buy a condominium in Honolulu a few years ago, we didn’t even think to ask the real estate agent if the unit we liked had a fire sprinkler system or how much fire insurance the building association had purchased or if there were regularly scheduled fire drills.    Read the article…………….

Owners Insurance Article Archives


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