First Notice

The residential program market, before it hits the trades.

This Week in Programs: Landlord & Homeowners

Issue #11 · October 12, 2026 · covering October 5 to 12

Isaias arrived late, as the season's first hurricane, and hit the Florida Panhandle as a Category 2 on October 9, with brokers' early loss talk in the mid-single-digit billions. Also: Florida Citizens froze binding statewide for three days, and TWIA took up a 2027 budget that buys $230 million less reinsurance.

Update, October 2026: post-landfall estimates put Isaias insured losses at $1 billion to $4.5 billion (Verisk, Cotality, Karen Clark & Company, Moody's RMS). Artemis later reported Pillar Capital Management at about $4.3 billion of assets and TransRe exiting its stake.


Gallagher Re put insured losses from Hurricane Isaias in the mid-single-digit billions of dollars on October 9, hours before the storm made landfall near Destin, Florida as a Category 2 with 105 mph sustained winds. Isaias had become the first Atlantic hurricane of 2026 at 03:30 UTC on October 8, which was 11:30 p.m. Eastern on October 7, the latest first hurricane on record by AccuWeather's count, though NOAA-based reporting put it just short of the October 8, 1905 mark. Florida Citizens suspended binding across all 67 counties at 11:05 a.m. on October 7, and lifted it three days later. The Texas Windstorm Insurance Association took up a 2027 budget on October 8 that cuts its reinsurance limit to $2.05 billion from $2.28 billion and assumes no rate change, and three days earlier Washington announced a $35,000 fine against Unitrin Auto and Home over rating factors applied to 2,576 home policies.

Capacity & fronting

Isaias hits the Panhandle as a Category 2, and the brokers say mid-single-digit billions. Isaias became the first Atlantic hurricane of the 2026 season at 03:30 UTC on October 8, beating the 1905 record for the latest first Atlantic hurricane, according to AccuWeather. The National Hurricane Center declared it a major Category 3 with 120 mph sustained winds on October 9, and it made landfall close to Destin, Florida at 01:30 UTC on October 10, the evening of October 9 local time, as a Category 2 with 105 mph sustained winds. Gallagher Re said at 17:15 UTC on October 9 that losses "would be expected to settle in the mid-single-digit billions (USD)," BMS Group's Andrew Siffert said an hour earlier that "losses should be below $10B, with an expected range of $4B to $6B today," Marsh Re said "insured losses in the mid single digits of billions of USD," and Twelve Securis also put the most likely outcome in the mid-single-digit billions, saying a loss above $10 billion could not be ruled out if the storm strengthened more than expected. Gallagher Re said the event is unlikely to meaningfully affect January 1 reinsurance renewal discussions. More than 800,000 customers lost power across Florida, Alabama, Georgia and the Carolinas, and no catastrophe modeler had published a post-landfall industry loss estimate as of October 11. (AccuWeather, Artemis, Business Insurance, Insurance Business)

→ For reinsurers/ILS and fronting carriers: A mid-single-digit-billion landfall is a long way short of the $50 billion to $75 billion of second-half 2026 losses Gallagher Re says the market needs to earn its cost of equity, and Gallagher Re expects little effect on January 1 renewal talks.

Cotality tallies $241.6 billion of home wind reconstruction value in the storm's path; Moody's adds $40.2 billion of multi-family buildings. Cotality reported that approximately 777,000 homes across eight counties under a Hurricane Warning faced moderate or greater risk of wind damage, carrying wind reconstruction cost value of $241.6 billion, and that 342,000 homes across the Storm Surge Warning area faced moderate or greater surge risk at $101.5 billion of surge reconstruction value. In the four Florida counties of Escambia, Santa Rosa, Okaloosa and Walton the figures were 353,000 homes and $115.8 billion of wind value, with the Pensacola-Ferry Pass-Brent metro at 201,000 homes and $66.1 billion. Cotality's reconstruction values are exposure figures that assume total destruction of every at-risk home. Moody's reported on October 9 that 31,659 commercial properties in Alabama, Florida and Mississippi had a greater than 50% probability of winds of at least 50 mph, worth $71.8 billion, of which 14,945 were multi-family residential buildings valued at approximately $40.2 billion. Tampa-based Mangrove Property Insurance Company carries more than $1.5 billion of exposure on about 3,900 policies in the ten counties most exposed to the winds, per Florida Office of Insurance Regulation data. About 8% of residential property in Escambia County carried NFIP cover as of August, rising to 62% of residential structures inside the county's Special Flood Hazard Area. (Cotality, Insurance Business on Moody's, Insurance Journal)

→ For MGA operators and program administrators: Mangrove's more than $1.5 billion on about 3,900 Panhandle policies concentrates one carrier's wind exposure inside the landfall counties, and the 8% countywide Escambia NFIP take-up is where the uncovered water loss on those dwellings sits.

USAA is back for more cat bond cover: $225 million, meteorite impact included. USAA is in the market with Residential Reinsurance 2026 Limited (Series 2026-2) seeking $225 million or more across three tranches, Artemis reported on October 8. The Class 2 notes are $50 million, attaching at $2.45 billion and exhausting at $3.45 billion, with an 8.24% attachment probability and 6.04% expected loss at price guidance of 8.5% to 9.25%. The Class 3 notes are $50 million attaching at $3.45 billion and exhausting at $4.6 billion, with a 4.4% attachment probability and 3.34% expected loss at guidance of 5% to 5.5%. The Class 5 notes are $125 million attaching at $5.6 billion and exhausting at $6.5 billion, with a 1.72% attachment probability and 1.43% expected loss at guidance of 2.5% to 3%, a midpoint multiple of 1.92 times expected loss. Covered perils include US tropical cyclone, earthquake with fire following, severe thunderstorm, winter storm, wildfire, volcanic eruption and meteorite impact, plus flood on automobile and renter policies. The notes settle in November with coverage running from December 1, 2026 to November 30, 2030, and follow USAA's $825 million Residential Re 2026-1 in April and the $400 million Residential Re 2025-2 a year ago. (Artemis)

→ For reinsurers/ILS and MGA operators: A remote homeowners layer is pricing at 1.92 times expected loss (USAA's Class 5, 2.5% to 3% guidance on a 1.43% expected loss), a ready yardstick for a residential program's own top layer at January 1.

Cat bond spreads sink to a 2018 low while expected loss sits at the top of Plenum's data. Plenum Investments data reported by Artemis on October 7 put the catastrophe bond market's insurance risk spread at 4.57% on September 25, down from 5.05% on August 28, a decline of 9.5% in the month and the lowest for that data point since around April 2018. The overall coupon yield fell to 8.74% from 8.87% as the collateral yield rose to 4.17% from 3.81%, its highest in more than a year. Yield above expected loss slipped to 6.24% from 6.37%, with expected loss standing at 2.50%, the highest in a record that begins in 2010. For reference, the 2016 trough saw risk spreads near 3.3% and total yield about 3.70%. (Artemis)

→ For reinsurers/ILS and MGA operators: Investors are taking a 2.50% expected loss for a 4.57% spread, the thinnest since April 2018, and a homeowners program sponsoring its first bond issues straight into that.

J.P. Morgan sees property cat rates falling 10% to 20% at January 2027, and reads that as stabilization. J.P. Morgan forecast property catastrophe reinsurance price declines of 10% to 20% at the January 2027 renewals in a note reported on October 9, and described the range as a slowing of declines that implies stabilization. At January 2026, global property catastrophe rates fell 12% to 15% on average, with reductions of up to 20% for non-loss-impacted programs in some regions. The same report cites Gallagher Re's estimate that the market would need $50 billion to $75 billion of second-half 2026 catastrophe losses to earn its cost of equity, and puts the figure close to $150 billion once accumulated excess capital is counted. (beinsure)

→ For fronting carriers and program administrators: A second year of double-digit cuts lowers a homeowners program's ceded cost again, and the same report says it would take close to $150 billion of second-half losses, counting excess capital, for the market to earn its cost of equity.

Market entries & movers

SageSure crosses to the capital side with a stake in Pillar, a $4 billion ILS manager. SageSure, the Jersey City catastrophe-focused managing general underwriter, made a strategic investment in Pillar Capital Management, a Bermuda insurance-linked securities fund manager with more than $4 billion in institutional assets under management, in a deal reported on October 11. Pillar management will keep a substantial ownership stake, financial terms were not disclosed, and SageSure funded the purchase by expanding its existing debt facility with Ares Management. SageSure carries more than $3.2 billion of in-force premium and more than 970,000 policyholders across 16 states, and completed its acquisition of Florida MGA Olympus MGA in January, adding about 130,000 policies and $700 million of gross written premium. (Insurance Business)

→ For MGA operators and PE-VC investors: A homeowners MGU with about $3.2 billion in force now owns part of an ILS manager with more than $4 billion of institutional capital, funded by debt from Ares Management.

American Coastal opens a $30 million surplus lines carrier for Florida, Texas and South Carolina property. American Coastal Insurance Corporation launched ACES Specialty Insurance Company with a $30 million cash contribution after receiving its certificate of authority from the Arizona Department of Insurance and Financial Institutions, in an announcement reported on October 9. ACES will write catastrophe-exposed commercial excess and surplus property in Florida, Texas and South Carolina through American Coastal's in-house MGA Skyway Underwriters, its exclusive production and underwriting arm, with writing expected to begin on or about December 1, 2026. Earlier in 2026, American Coastal took a 6% quota share of AmRisc's nationwide excess and surplus commercial property portfolio, from which it projects about $75 million of gross written premium; AmRisc remains the exclusive distribution partner for American Coastal's admitted Florida commercial residential book, restructured in September 2026 to one-year terms with 48 months of termination notice. American Coastal reported Q2 2026 net income of $21.9 million on gross premiums written of $216.3 million, down 5.3% year over year, against maintained full-year earnings guidance of $85 million to $100 million. Until ACES obtains a rating agency designation, some lender-required placements, particularly in habitational segments, may be out of reach. (Insurance Business)

→ For wholesalers and program administrators: ACES starts writing on or about December 1, but some lender-required habitational placements may stay out of reach until it carries a rating.

Rate & regulatory

Florida Citizens froze binding in all 67 counties for three days. Citizens Property Insurance Corporation issued a binding bulletin effective 11:05 a.m. on October 7 suspending new homeowners applications and any change that would increase coverage across all 67 Florida counties ahead of Isaias, including applications carrying later requested effective dates and regardless of distance from the track. Existing policies were not canceled and policies bound before the suspension were handled separately. Citizens lifted the suspension at 5:00 a.m. on October 10. Citizens had 266,231 policies in force at the end of August. Neither Citizens nor state regulators published a count of affected applications or delayed transactions, and private carriers set their own restrictions outside the Citizens action. (Citizens binding bulletin, Citizens lifting bulletin, WINK News, Citizens policies in force)

→ For state entrants and program administrators: Citizens freezing binding in all 67 counties for a Panhandle landfall left every new Florida applicant without Citizens as a fallback for three days.

TWIA's 2027 budget buys $230 million less reinsurance and assumes no rate change. The Texas Windstorm Insurance Association board met on October 8 in Austin and by web conference and took up a 2027 budget projecting direct written premium of $770.6 million, down 4.5% from the $807.0 million forecast for 2026, with policies in force of 286,201 at December 31, 2027 against 288,898 forecast for the end of 2026, a decline of 0.9%. Budgeted direct liability in force rises to about $131.4 billion from about $129.7 billion. The 2027 minimum required funding level is $4.4 billion, the 1-in-50 probable maximum loss, against $4.305 billion for 2026, and the association budgets a reinsurance limit of $2.05 billion, down from the roughly $2.28 billion secured for 2026, at a $173 million risk transfer placeholder against almost $210 million. The Catastrophe Reserve Trust Fund is budgeted at $350.5 million at December 31, 2027 against $59.2 million forecast for the end of 2026. Non-hurricane losses are budgeted at $100 million, net income at $378.8 million and the direct loss and loss adjustment expense ratio at 12.7%. The budget assumes no 2027 rate change, and the board did not consider rates. (TWIA budget materials, TWIA)

→ For reinsurers/ILS and state entrants: TWIA plans a smaller reinsurance check for 2027, a $173 million placeholder against almost $210 million, while its liability in force grows to about $131.4 billion.

TWIA asks Texas lawmakers to let surplus lines carriers take policies off its hands. The board voted on October 8 to adopt the legislative recommendations its Legislative and External Affairs Committee advanced on September 1, for TWIA's 2026 Biennial Report to the Legislature. The depopulation recommendation would add a per-risk take-out bonus to participating carriers subject to multi-year renewal and Texas Department of Insurance approval, a premium-compatibility rule requiring insureds to accept takeout offers, stronger agent protections and expanded participation for approved surplus lines insurers. The others would eliminate or make optional the appointed-judge requirement for multidistrict litigation under Texas Insurance Code section 2210.575(e), support wind mitigation and FORTIFIED funding, refine HB 3689 with additional administrative time before surcharge collection and an alternative funding method where excess losses are minimal, and seek tort reform similar to measures passed by the Florida Legislature covering one-way attorney fees, assignment of benefits and bad-faith standards. Any change in law would require enactment by the Texas Legislature. (TWIA board recap)

→ For MGA operators and wholesalers: A slice of TWIA's 286,201 budgeted policies would come within reach of non-admitted paper if the Legislature agrees, with a per-risk take-out bonus as the sweetener.

Texas proposes that a home's age, roof included, can't be a reason to decline it. The October 9, 2026 issue of the Texas Register, Volume 51, Number 41, pages 6983 to 7090, carries the Texas Department of Insurance's proposed amendment to 28 TAC section 21.1006, which the department announced on September 29. Proposed subsection (b) provides that an insurer may not decline to write residential property insurance based on the age of the property or of "any of the property's individual components or materials, including wiring, heating, air conditioning, plumbing, siding, and roofing," while new subsection (d)(1) preserves the right to decline based on documented physical condition. TDI characterizes the change as clarity and consistency edits that restructure the rule without expanding or changing its existing prohibition, and the existing section already bars declination based on the age or value of the property. The Docket 2874 hearing is set for 2:00 p.m. Central on November 3, 2026, remotely and at the Barbara Jordan State Office Building, Room 2.034, with comments due by 5:00 p.m. Central on November 9. (Texas Register)

→ For MGA operators: TDI reads declining a Texas home on roof age as already barred under section 21.1006, and the proposal just says so in more words, with a November 3 hearing and comments due 5:00 p.m. on November 9.

Texas homeowners filings since July average a 4.3% cut. The commissioner calls it relief. The Texas Department of Insurance said that homeowners filings made since the start of July average a 4.3% decrease, in data reported on October 9. ASI Lloyds, a Progressive company, filed a 6% decrease affecting 71,000 policyholders, and Texas Farm Bureau Mutual Insurance Company filed a 5.2% decrease affecting 133,000 policyholders. On automobile, Auto Club County Mutual Insurance Company filed a 3% decrease affecting 235,000 policyholders and Loya Insurance Company a 10.3% decrease affecting 39,000. About 160 companies sell automobile and homeowners insurance in Texas. Every figure here is a filed rate change awaiting department action. Commissioner Amanda Crawford said the department is "pleased to see some relief beginning to reach the market." (Insurance Journal)

→ For state entrants and MGA operators: ASI Lloyds (6% off, 71,000 policies) and Texas Farm Bureau Mutual (5.2% off, 133,000) are filed cuts still awaiting department action, and if approved they reset the admitted price a Texas landlord or dwelling program quotes against.

Washington's $495,200 in fines includes $35,000 against Unitrin over incorrect rating factors on 2,576 home policies. Commissioner Patty Kuderer announced on October 5 fines totaling $495,200 against insurers, agencies and producers, issued between April and August 2026. Unitrin Auto and Home Insurance Company was fined $35,000 under order 26-0109 for using incorrect rating factors on 2,576 home policies between 2019 and 2023, affecting 1,844 homeowners. Praetorian Insurance Company was fined $5,000 under order 26-0044 for incorrect rating factors on 49 renters policies traced to wrong construction-year assignments and building-unit counts. Arch Insurance Company was fined $5,000 under order 26-0039 over construction types, rate types and protection classes, and Stillwater Insurance Company $3,500 under order 26-0103 over sprinkler credits and construction type. The same announcement carries the $90,000 order against Allstate Vehicle and Property Insurance Company for claim handling. (Washington OIC)

→ For program administrators: Four of the orders Kuderer listed are rating-factor and construction-classification errors, so the rating engine behind a Washington program is the exposure, and order 26-0109 shows that a regulator will reach back to 2019 and name 1,844 affected homeowners.

Oklahoma's noncompetitive-market case has no hearing date and a pending motion to stay. In Oklahoma Insurance Department docket 26-0820-TRN, on whether Oklahoma's homeowners insurance market is noncompetitive under 36 O.S. section 984, Attorney General Gentner Drummond and insurance commissioner candidate Bob Sullivan filed a joint motion to stay proceedings and a joint request for production of the record on October 5. The National Association of Mutual Insurance Companies and the American Property Casualty Insurance Association filed an objection to the stay on October 7. No ruling on the motion is docketed. A noncompetitive finding would extend the rate waiting period under House Bill 3781, effective July 1, 2027, from 30 days to 60 days. The October 26 merits hearing was struck when independent hearing examiner John D. Miller stayed the case in September and has not been reset. (Oklahoma Insurance Department, Oklahoma Politics Today)

→ For state entrants and MGA operators: A noncompetitive finding would double Oklahoma's rate waiting period to 60 days from July 1, 2027, and the case now has no date for getting there.

The litigation layer

Los Angeles County opened a civil investigation into the California FAIR Plan. The County of Los Angeles opened a civil investigation on October 7 into the California FAIR Plan Association's handling of claims from the January 2025 Palisades and Eaton fires for possible violations of California's Unfair Competition Law, and County Counsel Dawyn R. Harrison notified the FAIR Plan that it must immediately stop any unlawful or unfair practices and comply with state law. County Counsel may seek restitution, civil penalties and injunctive relief. No penalties have been imposed. The FAIR Plan says it handled about 5,400 claims from the two fires, paid nearly $3.5 billion and is reviewing the county's letter. A July 2026 Department of Angels survey found 67% of FAIR Plan customers dissatisfied, the highest share of any insurer, and more than half of respondents had been assigned multiple adjusters. The FAIR Plan already faces a July 2025 state order to show cause over smoke-damage claims citing at least 418 violations. The county opened a State Farm General investigation in November 2025 and sued on August 31, 2026, and opened a Farmers investigation on September 9, 2026. (Santa Monica Daily Press, Westside Current)

→ For state entrants and fronting carriers: With the FAIR Plan, Los Angeles County has now opened investigations into three insurers over the 2025 fire claims, and it has already gone from investigation to lawsuit once, with State Farm General.

A Chubb subsidiary was sued over smoke testing at a Palisades home. Austin Beutner and his wife sued Bankers Standard Insurance Company, a Chubb subsidiary, along with two environmental consulting firms the insurer hired, in Los Angeles County Superior Court, in a complaint the Daily Journal and MyNewsLA reported was filed Monday, which was October 5. The suit alleges the insurer relied on inadequate testing to minimize coverage for contamination at the family's Pacific Palisades home after the January 2025 Palisades Fire. It says the remediation offer was less than 25% of the family's contractor cost estimate and would cover only about half the rooms though all tested positive for toxic metals. Testing commissioned by the family reported lead in a wall cavity at 9,574 micrograms per square foot against a California residential floor threshold of 10. Chubb did not respond to requests for comment. The two-year deadline to sue over the fires falls in January 2027. No docket number is public. (MyNewsLA, NBC Los Angeles)

→ For HNW incumbents and MGA operators: A high-value homeowners carrier is being sued over the testing protocol and the consultants behind a smoke claim, and the January 2027 deadline pushes the remaining Palisades and Eaton smoke claims into settlement or suit inside the next quarter.

The take

The first US hurricane landfall since 2024 came in small enough to leave the January 2027 softening intact. Gallagher Re put Isaias in the mid-single-digit billions on October 9 and said the event is unlikely to meaningfully affect January 1 renewal discussions, and J.P. Morgan published a 10% to 20% property catastrophe decline forecast the same day. SageSure, with more than $3.2 billion of in-force premium and more than 970,000 policyholders, took a stake in Pillar Capital Management and its $4 billion of institutional assets on October 11 using an expanded Ares Management debt facility, and American Coastal put $30 million into ACES Specialty Insurance Company on October 9. Regulators and public bodies moved on homeowners pricing and claims conduct in four states in the same seven days. The Texas Register published TDI's proposed amendment to 28 TAC section 21.1006 on October 9, with a November 3 hearing and comments due November 9. Oklahoma's docket 26-0820-TRN, which would double the state's rate waiting period to 60 days from July 1, 2027, stalled on an October 5 motion to stay that NAMIC and APCIA opposed two days later. Washington announced a $35,000 fine against Unitrin Auto and Home for rating factors applied to 2,576 home policies between 2019 and 2023. Los Angeles County put the California FAIR Plan, with about 5,400 fire claims and nearly $3.5 billion paid, under the same Unfair Competition Law investigation already aimed at State Farm General and Farmers.

If you front programs, set your January 1 ceded-cost assumption at the shallow end of J.P. Morgan's 10% to 20% range until a post-landfall Isaias estimate lands. If you run an MGA, file comments on 28 TAC section 21.1006 by 5:00 p.m. on November 9 and audit your Texas declination rules against documented physical condition now, since TDI reads the age prohibition as already in force. If you allocate capital, price SageSure's stake in Pillar Capital Management as the fee and carry an MGU can add to a $3.2 billion book, and assume January 1 cat bond and treaty spreads start from the 4.57% risk spread, the lowest since April 2018.


First Notice tracks the U.S. residential property program market: new MGA licenses, program launches, rate and form filings, fronting partnerships, and insurance litigation, from public regulatory and news sources. On the web: firstnoticeresearch.com

Why "First Notice"? In claims, first notice of loss is the first report that something has happened. This letter aims to be that report for the program market.

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