The residential program market, and what each move means.
Issue #6 · September 7, 2026 · covering August 31 to September 7
Thirteen items from August 31 to September 7, across capacity, market entries, rate and regulatory action, and litigation. Allstate files to reopen California homeowners new business after nearly four years, Texas declares price optimization illegal by bulletin, California's Legislature adjourns without voting on its wildfire liability bill, Florida Citizens sends 45,000 non-renewal notices, Aon Securities counts a record $23 billion of sidecar capital, and Los Angeles County sues State Farm. No residential product launch cleared the bar.
Allstate filed with the California Department of Insurance in September to write new homeowners business in the state for the first time since November 2022, asking for a 1.4% overall rate change and committing to write at least 2,064 new policies by July 2029. The capacity behind filings like it got cheaper in the same week. Aon said on September 3 that global reinsurer capital reached $800 billion at June 30 and that property reinsurance should come down roughly 10% at January 1, 2027, while Aon Securities put the sidecar market at a record $23 billion. Regulators worked the opposite side. Texas issued Commissioner's Bulletin B-0007-26 on September 2 declaring price optimization unfairly discriminatory, California's Legislature adjourned September 1 without voting on SB 492, and Florida Citizens sent 45,000 non-renewal notices to take its book to roughly 270,000 policies.
Aon expects roughly 10% off property reinsurance at January 1 against $800 billion of reinsurer capital. In an interview published September 3 ahead of the Monte Carlo Rendez-Vous, the September meeting where January reinsurance renewals begin, Aon put global reinsurer capital at $800 billion at June 30, 2026, an increase of $15 billion over six months. Amanda Lyons, Aon's Bermuda chief executive and global product leader for reinsurance, said property reinsurance rate declines at the January 1, 2027 renewal would be smaller than those at January 1, 2026 while still landing "likely in that 10% off range." Property reinsurance pricing currently sits roughly 30% above the index level reached at the height of the last soft market. Aon counted about $75 billion of catastrophe losses year to date against a five-year annual average of $114 billion. (Artemis)
→ For MGA operators and program administrators: A 10% property decline at January 1, 2027 on pricing still 30% above the last soft market sets the ceiling on how much of a 2027 quota share saving a residential program can pass through, and it arrives with $75 billion of 2026 catastrophe losses already booked against Aon's $114 billion five-year average.
Aon Securities put the reinsurance sidecar market at a record $23 billion. Aon Securities estimated the sidecar market, reinsurance vehicles funded by outside investors that take a share of an insurer's business, at $23 billion at the end of June 2026, up from $19.6 billion at September 30, 2025, $17 billion at June 30, 2025, and about $10 billion at mid-2024, growth of 50% since the end of 2024. At September 30, 2025 the split was $17.9 billion property and $1.7 billion casualty. Aon attributed the growth to earnings inside existing sidecars and to new vehicles running asset-driven strategies, writing that asset managers "seeking scalable private credit investment opportunities have increasingly recognized sidecars as a meaningful foundation for insurance asset management." (Artemis)
→ For reinsurers/ILS and MGA operators: $17.9 billion of that market sits in property, the same structure Bamboo used for the $150 million of California admitted homeowners and dwelling fire capacity it placed through Greenshoots Re in July, so a residential program with defensible modeling is now competing for capital priced against private credit returns.
Verisk raised the global insured catastrophe average annual loss to $171 billion, with $117 billion in the United States. Verisk published its 2026 global modeled catastrophe loss report on September 1, putting the global insured average annual loss at $171 billion, up $19 billion year over year. The United States accounts for $117 billion, or 68%, of that figure. Severe thunderstorm is the largest peril at 40%, ahead of tropical cyclone at 27%, earthquake at 10%, winter storm at 9%, flood at 7% and wildfire at 6%. Verisk put the 100-year return period loss, the level expected once a century, at $477 billion and the 250-year at $606 billion, against actual 2025 insured losses of $107 billion to $129 billion. United States residential reconstruction costs have risen about 5% a year since 2021. Rob Newbold is president of Verisk Catastrophe and Risk Solutions. (Verisk)
→ For fronting carriers and state entrants: Severe thunderstorm at 40% of a $171 billion global average annual loss is the peril driving the inland excess and surplus homeowners growth in Texas and Colorado, and Verisk's 5% annual United States residential reconstruction inflation is what an Allstate filing asking for 1.4% has to absorb.
Allstate filed to reopen California homeowners new business for the first time since November 2022. Allstate submitted a September rate filing to the California Department of Insurance to resume writing new homeowners policies in the state, having stopped accepting new California homeowners business in November 2022. The filing requests a 1.4% overall rate change across new and existing customers and commits Allstate to write a minimum of 2,064 new home policies by July 2029, directed into ZIP codes the department has flagged as distressed. Roughly two thirds of current policyholders would see premiums fall, close to 30% would see increases of up to 55%, and fewer than 4% would see increases between 55% and 185%. The filing uses the two levers Insurance Commissioner Ricardo Lara's Sustainable Insurance Strategy opened, catastrophe modeling for future wildfire losses and the net cost of reinsurance in rates. No approval has issued, and no filing number has been published in SERFF, the states' rate-filing system. (Insurance Business, reporting the San Francisco Chronicle)
→ For California entrants and HNW incumbents: 2,064 new policies by July 2029 is the price Allstate agreed to pay for catastrophe modeling and net reinsurance cost in its rates, and that commitment is what the department will quote to the next carrier asking to reopen.
Aon agreed to buy USI from KKR for $17 billion, citing MGA and MGU access. Aon announced on August 31 an agreement to acquire USI Insurance Services from KKR, the private equity firm, for $17 billion, adding roughly $3 billion of annual revenue, about 200 United States offices and 10,500 employees. Aon expects approximately $395 million of annual run-rate net adjusted EBITDA synergies and a fourth-quarter 2026 close, funded with new debt. Aon's stated rationale includes expanded direct access to the excess and surplus market through managing general agents and underwriters (MGAs and MGUs) with USI's wholesale capabilities. Mike Sicard, USI chairman and chief executive, becomes president of Aon plc and global chief executive of Middle Market at close. No residential property lines are named in the announcement. (Insurance Journal)
→ For wholesalers and program administrators: Aon closing USI in the fourth quarter and standing up Totalis Specialty Group with 46 programs and $5.5 billion of premium on January 1, 2027 puts a $3 billion wholesale business and a program platform under one owner inside a single quarter, which is the carrier-access position an independent residential program administrator now has to match.
Florida Citizens handed its commercial depopulation clearinghouse to Brown & Brown's wholesale arm. Citizens Property Insurance, Florida's state-backed insurer of last resort, awarded management of its new commercial clearinghouse, the marketplace that offers Citizens policies to private carriers willing to take them out, to Bridge Specialty Wholesale, a Brown & Brown division in Daytona Beach, at a September 2 board meeting. Risk Market Infrastructure, a Ryan Specialty subsidiary, ranked second and is named as the fallback if no contract is reached or the contract is terminated. Citizens held 4,562 commercial policies covering 10,678 buildings and $14 billion of total insured value at June 30. The dollar amount of the winning bid is undisclosed, with a Citizens communications director saying details are still being negotiated. A second contract, for a non-surplus commercial clearinghouse, remains unawarded after Citizens received less than two responsive replies. The clearinghouse is authorized by Senate Bill 1028, sponsored by Senator Joe Gruters and signed by Governor Ron DeSantis in June 2026. The award covers commercial policies, and no residential or condominium association line is named. (Insurance Journal)
→ For wholesalers and program administrators: Brown & Brown running the surplus lines match on $14 billion of Citizens commercial insured value puts one wholesaler in front of every takeout submission, and the second Citizens contract is still open after fewer than two firms bid for it.
Texas told insurers price optimization is illegal and promised enforcement. The Texas Department of Insurance (TDI) issued Commissioner's Bulletin B-0007-26 on September 2, stating that price optimization is unfairly discriminatory under the Texas Insurance Code and that the department will pursue enforcement action against companies that fail to comply. TDI described the practice as setting premium on factors unrelated to a customer's risk or the company's expenses, such as how likely a customer is to shop or how large an increase a customer will tolerate. Governor Greg Abbott, whose August 24 letter to Commissioner Amanda Crawford directed the bulletin, said "Price optimization drives up costs for loyal customers. Insurance companies must base rates on risk, not on how much extra money they think a customer will pay." Abbott cited a 79% rise in the average annual Texas homeowners premium over six years. This is the first of the five Abbott directives to land, with TDI recommendations on the remainder due September 14. The TDI bulletin page was unreachable at press time, so the language above is taken from September 2 coverage. (San Angelo LIVE, WTAW)
→ For MGA operators and program administrators in Texas: Enforcement under B-0007-26 reaches any Texas homeowners or dwelling fire program whose renewal rating carries retention or elasticity variables, and the four remaining Abbott directives, including a ban on declining or non-renewing on roof age, come back from TDI on September 14.
California's wildfire liability bill died without a vote, leaving insurer subrogation intact. The California Legislature adjourned on September 1 without bringing SB 492 to an Assembly vote, so insurers keep their subrogation rights against utilities by default. The bill as negotiated would have preserved those rights while barring private equity firms from buying insurers' claims against electric companies, and it set no limits on fire survivors' compensation or contingency fees. Insurance Business reported on August 31 that the negotiated text dropped Newsom's push to eliminate insurer subrogation. Governor Gavin Newsom said the reforms, "while important, did not address the underlying structural problems driving this crisis." Assembly Speaker Robert Rivas said "the proposal before us does not yet deliver the relief, accountability or meaningful reform that Californians deserve." PG&E and Edison lost about $20 billion of combined market value between Thursday, August 27 and the final day, a move that partly reversed when the bill failed. Assembly leaders committed to fall hearings and Newsom said he is "here until January." (CalMatters, KQED, Insurance Business)
→ For reinsurers/ILS and HNW incumbents: California wildfire models that assume subrogation recovery from PG&E and Southern California Edison hold through the fall hearings Assembly leaders promised, and the $20 billion swing in those two utilities' market value in the week to September 1 is the pressure that brings a bill back before January.
Florida Citizens sent 45,000 non-renewal notices, taking its book to roughly 270,000 policies. Citizens Property Insurance issued 45,000 non-renewal notices statewide, cutting its policy count to approximately 270,000 from a peak near 1.4 million in September 2023. Displaced policyholders have about a year to find replacement coverage, and Florida's takeout rule requires a Citizens insured to accept a private offer priced within 20% of the Citizens premium. Michael Peltier, a Citizens spokesperson, said "I think this is the latest indication that the market is getting healthier. There's more competition out there." The statewide average homeowners premium including wind coverage was $3,815 on April 2026 data, and 21 carriers have entered Florida since the 2022 and 2023 legislative reforms. (Insurance Business)
→ For state entrants and MGA operators: 45,000 Citizens policies moving to private paper inside twelve months at a $3,815 statewide average is the largest block of pre-underwritten Florida homeowners premium available to the 21 carriers that entered since the reforms, and the 20% rule sets the most any of them can charge and still force the move.
Triple-I put California's average rate filing approval at 336 days and counted 662 distressed ZIP codes. The Insurance Information Institute published its Insurance Affordability Index on September 3, putting homeowners insurance at 2.4% of median household income in 2025, up 24% since 2020. In California the index counts 662 distressed ZIP codes, 668,609 FAIR Plan homeowner and commercial policies as of December 2025, an average rate filing approval time of 336 days, and more than 300,000 surplus lines homeowners policies written in 2025. Florida Citizens fell from 819,027 policies on May 28, 2025 to 266,093 on August 28, 2026. Sean Kevelighan is chief executive of Triple-I and Pat Schmid is its chief insurance officer. (Insurance Business)
→ For California entrants and program administrators: A 336-day average approval is the carry cost sitting on Allstate's September filing and on every California homeowners program queued behind it, and the 662 distressed ZIP codes are the map the department uses to set reopening commitments like Allstate's 2,064 policies.
An APCIA-commissioned report put Florida homeowners rate change below 1% for 2025. The American Property Casualty Insurance Association published an actuarial report on September 3 finding that Florida policyholders paid almost $3 billion less in combined homeowners and auto premium in 2025 than in 2024. Homeowners rates rose less than 1% in 2025 and auto rates fell 4.1%. The homeowners defense cost ratio, a measure of legal defense spending, fell from 2.4% in 2021 to 2% in 2025, and litigation notices of pending action, the pre-suit notices Florida requires before a policyholder can sue, dropped from more than 8,500 in late 2021 to about 2,500 by early 2026. The report was written by Dave Moore, president of Moore Actuarial Consulting, and James Lynch, owner of James Lynch Casualty Actuary and former chief actuary of the Insurance Information Institute. APCIA is the trade association for the insurers whose reform benefits the report measures. (Insurance Journal)
→ For state entrants and PE-VC investors: A 2% defense cost ratio and roughly 2,500 litigation notices are the two inputs a Florida homeowners program feeds into 2027 pricing, and both come from a study APCIA published about its own members' reforms.
Los Angeles County sued State Farm over Palisades and Eaton claim handling. Los Angeles County filed suit on August 31 in Los Angeles County Superior Court against State Farm General Insurance Company and State Farm Mutual Automobile Insurance Company, alleging delayed claims, wrongful denials and underpayments on property damage from the Palisades and Eaton wildfires of January 2025. Those fires killed 31 people, destroyed more than 16,000 structures and produced roughly $40 billion of insured losses. State Farm says it has processed 13,700 fire-related claims and paid $6.2 billion, including $1 billion for smoke damage, with 78% of claims closed. State Farm holds more than 2.8 million residential and commercial policies in California and has an approved average rate increase of 17%. The county also alleges State Farm refused to produce subpoenaed documents in an investigation it opened last November. Supervisor Lindsey Horvath said "We tried this the nice way." Spokesperson Bob Devereux said State Farm General "strongly disagrees with Los Angeles County's characterization." No case number has been published. (Insurance Journal)
→ For fronting carriers and program administrators: A county government suing its largest homeowners carrier on August 31 puts State Farm's 78% closed-claim rate and $6.2 billion paid into discovery, and whatever survives that scrutiny becomes the benchmark a California wildfire program's third-party claims administrator will be measured against.
A Florida judge cleared Lighthouse's former chief executive of concealing Hurricane Ida losses from investors. Orange County Circuit Judge Chad Alvaro granted summary judgment on August 31 for Patrick White, former chief executive of Lighthouse Property Insurance Corporation, and his father Lawrence White, ending a fraud suit brought by Fortinbras Enterprises, HT Investments and two Silver Rock funds. The funds alleged the Whites concealed Hurricane Ida losses while raising capital and that Lawrence White had an undisclosed insider relationship with One Florida bank over repayment of a $19 million loan. Alvaro held that the plaintiffs "had released any claims they might otherwise have had, and are therefore barred from bringing Counts I through III" under a 2021 note purchase agreement. Lighthouse wrote 13,800 Florida policies plus business in Louisiana and other states, went into rehabilitation in 2021 and was declared insolvent in April 2022. A related New York suit against TigerRisk Partners, now Howden Tiger Capital, was partly dismissed in 2025 and settled in spring 2026. No docket number is public. (Insurance Journal)
→ For PE-VC investors and MGA operators: Alvaro's August 31 ruling turned on release language in a 2021 note purchase agreement rather than on any finding about Hurricane Ida reserves, which is where an investor in a coastal residential program's next raise should spend its lawyer hours.
The take
Property reinsurance is getting cheaper and regulators are taking away the levers programs use to keep the difference. Aon's Amanda Lyons put January 1, 2027 property reinsurance in the 10% off range on September 3 against $800 billion of reinsurer capital, and Aon Securities counted a record $23 billion of sidecar capital at June 30, with $17.9 billion of it in property. In the same seven days Texas issued Bulletin B-0007-26 declaring price optimization unfairly discriminatory with enforcement promised, California's Legislature adjourned September 1 with SB 492 unvoted, and Triple-I put California's average rate filing approval at 336 days across 662 distressed ZIP codes. Allstate's answer was a 1.4% filing paired with a commitment to write 2,064 new California policies by July 2029 in ZIP codes the department selects. Florida runs the other way, with Citizens sending 45,000 non-renewal notices into a market 21 new carriers have entered since the reforms. If you front programs, price your 2027 quota share off Aon's 10% guidance and hold the difference against Verisk's 5% annual United States residential reconstruction inflation, because a Texas filing stripped of elasticity variables gives you nowhere else to recover it. If you run an MGA, audit your renewal rating for retention and shopping-propensity variables before TDI's September 14 recommendations land, and price what a Lara-style new-business commitment would cost your California program at 336 days of carry. If you allocate capital, the Florida trade is 45,000 Citizens non-renewals at a $3,815 average premium and the California trade is a 336-day approval queue behind a 2,064-policy obligation; decide which one your holding period survives.
First Notice tracks the U.S. P&C 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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First Notice · independent research on the residential program market