DFR seeks input on rules to distribute roughly $2.5 million for insurance premium assistance to affordable housing and shelters

Brian Peltime, a senior policy staffer with the Division of Financial Regulation at the Oregon Department of Consumer and Business Services (DFR), opened the rulemaking advisory committee meeting by outlining the portion of Senate Bill 829 that creates a premium-assistance program to help affordable housing providers, shelter locations, project turnkey sites and navigators.

“We received, one-time funding of just under $2,500,000, and this funding is intended for recipients that are in the affordable housing, shelter space, or a project turnkey site, or navigators,” Peltime said, describing the DFR draft as framework language meant to guide discussion rather than final rule text. He said the program is designed to function as a rebate: applicants must have already paid their insurance premiums and would receive a reimbursement if approved.

The session focused on several practical design questions. DFR staff proposed an initial 60-day application window and a scored ranking system so that awards would not be made on a first-come, first-served basis. Natalie Thornton of the Housing Development Center warned that application timing could exclude providers whose policy renewal cycles do not align with the window: “I agree that the fund is very likely to be oversubscribed, and I think this approach of having an application window and then reviewing all applications simultaneously is the best way to mitigate that,” she said, and suggested either allowing prior-year premiums to qualify or running multiple rounds.

Participants repeatedly highlighted verification and prioritization challenges. Thornton and others noted it is easier to verify regulated affordable housing and project-turnkey sites (for example, by deed restrictions or recorded regulatory agreements) than it is to verify navigation centers or day‑center models that lack single‑asset, site-level financial statements. DFR staff said they were seeking documentation that most applicants could reasonably provide; possible items discussed included declarations, insurance binders, and at least one year of prior insurance information to allow comparisons.

On payment mechanics, industry representatives and DFR staff agreed reimbursement directly to eligible entities is administratively simpler than paying insurers or brokers, though some participants raised the potential complexity of ensuring funds serve their intended purpose. “There’s been some discussion about whether the payment should be made simply in the form of partial reimbursements to the eligible entities, as opposed to payments directly to the insurers,” said Ed Davis of the Independent Insurance Agents and Brokers of Oregon.

A recurring concern was whether proposed caps would be large enough to make a difference for properties at risk. Thornton offered a numerical example of a 75‑unit property with a $100,000 annual insurance premium and large accounts payable; she warned that a 5% share or a $20,000 cap would likely be insufficient to save such a property from foreclosure. Participants discussed alternatives — higher percentage shares, per‑unit caps, or a benchmarked dollar cap — and raised the prospect of spot reviews for applicants whose costs exceed market benchmarks.

DFR stressed the need to avoid creating perverse incentives or rewarding risky behavior; staff said they want enough application information to reasonably compare costs and risk-management practices while keeping the process accessible, especially for smaller providers without extensive financial reporting.

The committee also discussed data limitations. Thornton noted the state lacks comprehensive, statewide data on preservation need for affordable housing; Oregon Housing and Community Services (OHCS) has been tasked with a related study under a separate bill, but not all shelters or navigation centers are OHCS‑funded, complicating prioritization by need.

Staff reiterated statutory constraints and next steps: the bill sets a sunset date for the program of Dec. 31, 2028, and DFR must report annually to the legislature on program performance. DFR opened an initial written-comment window through Oct. 3 and said it will file proposed rulemaking with the Secretary of State, after which a 30‑day public comment period will follow. DFR staff said another RAC meeting would be scheduled only if the volume of comments makes it necessary.

The meeting produced no formal vote or final rule language; the discussion centered on what documentation the agency should require, how to prioritize limited funds, whether caps should be percentage or per‑unit, and how to ensure the program preserves housing stock most at risk.

DFR encouraged written comments on the draft language and will circulate any revised draft rule text to stakeholders. The RAC adjourned after directing interested parties to the Oct. 3 written-comment deadline and to the subsequent Secretary of State comment period.