Florida Multifamily Liability: The Coverage Gaps Sitting Above the Primary Layer

Which lines actually turned?

As of mid August, national pricing across the Advocate placement network sat at $0.323 per $100 of coverage for commercial property, $1.245 for liability, and $0.973 for package. Direction matters more than level. Property has declined across the network for the past year. Liability has moved the other way, and not subtly. Package sits between the two, which is what a product containing both coverages should do when they are pulling in opposite directions.

One qualification belongs on the liability figure. Roughly two thirds of the liability movement is rate. The remainder is a shift in mix, more primary general liability in the book and less umbrella. It is mostly price, but it is not only price, which means any single headline percentage for liability is collapsing two different things into one number.

Where does Florida multifamily liability actually price?

The average rate on line for Florida multifamily liability across the network is $0.742 per $100 of coverage. That is $7,420 of premium per million dollars of coverage, or about $317 per door.

The average is the wrong number to anchor on. The middle half of the market runs from $0.109 to $0.948 on rate, or $1,090 to $9,480 per million, and from $71 to $322 per door. Two separate forces produce that width. A small number of large placements pull the mean toward the upper end of the middle half on both rate and premium per door. Underneath that, the segment blends two products that price on entirely different bases, primary and excess, which were never comparable in the first place.

For an owner of a 300 unit garden style asset in Broward County, the state average does not describe the building. Most Florida multifamily liability is written below it. The state average is among the most quoted numbers in this business and among the least useful.

Is the Florida premium in the primary layer or the excess layer?

Split the same market by layer, comparing each Florida layer against its own national counterpart.

Florida general liability averages $1.121 per $100 of coverage. Florida umbrella averages $0.258. Excess runs at roughly a quarter of the price of primary, which is the normal relationship in Florida and everywhere else. Primary is working layer coverage that responds to ordinary claims, so it absorbs frequency. Excess responds only once the underlying limit is exhausted, which is rare. First dollar limit is always the expensive limit. Nationally the same shape holds, at $1.05 for general liability against $0.20 flat for umbrella.

Against those national counterparts, Florida primary general liability runs about 1.06 times. Six percent.

Florida umbrella runs about 1.29 times the national figure. Twenty nine percent. The differential is concentrated above the primary layer.

The mechanism is easy to misread, because per million of limit the two gaps look similar: about $640 per million on primary and about $580 per million on umbrella. Almost the same dollars. But nobody buys the same amount of both. Take a structurally unremarkable Florida garden style program with $1 million of primary sitting under $10 million of umbrella. The Florida differential on the primary is about $640. On the excess it is about $5,800. Roughly nine tenths of what Florida costs over a comparable out of state account sits above the primary layer. Cheaper per dollar of limit, and still where the money goes, because owners buy so much more of it.

Why does the differential land in the excess layer?

The intuition runs the other way. If a state is a harder place to write liability, the harder pricing should show up in the working layer first.

It does not, because Florida's problem is severity rather than frequency. The issue is not more claims, it is bigger ones. A bigger claim does not change what the primary pays, because the primary caps out either way. It changes what pays above it. That is the umbrella carrier's exposure, and that is where it gets priced.

The practical consequence for brokers is direct. Primary general liability is what almost everyone benchmarks, because it is the cleanest number to obtain. It is also the one layer where Florida looks unremarkable. Primary is the layer that can be benchmarked easily and the layer that tells you the least.

What does the carrier board hide?

Average rate on line by carrier, for the carriers most active in this segment, ran from $2.027 at Admiral down to $0.105 at Midvale Indemnity. James River sat at $1.35, Century Surety at $1.289, Kinsale at $0.758, Atlantic Casualty at $0.578, ACE Property and Casualty at $0.507, Nautilus at $0.478, and Westchester Surplus at $0.455.

Read straight down, that board says Midvale writes Florida liability for about a twentieth of what Admiral charges. It does not.

ACE and Midvale both carry a zero percent general liability share. Those are umbrella books, and umbrella prices on a completely different basis from primary. A low rate on line there is not a cheaper carrier.

The cleaner illustration is the pair sitting ten cents apart in the middle of the board. Nautilus at $0.478 carries a 24 percent general liability share. Atlantic Casualty at $0.578 carries 86 percent. Ten cents of separation, two entirely different businesses. A predominantly umbrella book will always show a lower rate on line without being cheaper on comparable risk, which is why layer mix belongs next to the rate rather than behind it.

How wide is the property and casualty divergence in Florida?

Florida multifamily property has come down every single year, from $1.042 per $100 of coverage in 2023 to $0.542 through May of this year. Over the same period Florida multifamily general liability rose every single year, from $0.786 to $1.517.

In 2023, property cost more than general liability on the same asset in the same state. Today general liability costs nearly three times what property costs.

A crossover is a slow thing to notice. Property renewals keep arriving better than expected, so attention follows them, while the line that stopped being a concern years ago quietly becomes the largest number on the page. Four consecutive years of movement on both lines is about as clean a pattern as placement data produces. Most of the other findings here are snapshots. This one has held its direction every year in the visible window.

An independent read lines up with it. The Council of Insurance Agents and Brokers first quarter 2026 survey put commercial property and casualty premiums down 1.2 percent across all account sizes, the first overall decrease since the third quarter of 2017 and the end of that 33 quarter run. Large accounts fell hardest at 2.7 percent, while the smallest accounts still rose. Nine lines showed decreases, including commercial property, business interruption, cyber, directors and officers, and workers compensation. The liability lines went the other way: general liability up 2.6 percent, umbrella up 4.8 percent, and commercial auto up 5.8 percent. The shape is what matters. The survey has umbrella rising at nearly twice the pace of general liability nationally, and the Florida placement data puts that same pattern on the map.

What does 43 percent non-admitted mean for a Florida program?

Florida is the most surplus lines dependent state in the Advocate network for this segment. Roughly 43 percent of Florida multifamily liability placements are written on non-admitted paper. Nationally the figure is about 26 percent. Texas is the next closest at 37 percent, and New York sits near 16 percent.

Precision matters more than alarm here, because the term gets used loosely. Non-admitted means rates are not filed with the state, the form carries more latitude, and there is no state guaranty fund behind the policy. The latitude cuts both ways: more flexibility going in, and more room for exclusions that surface later. Non-admitted does not mean unrated. Surplus lines carriers are rated, and the channel has regulatory status.

The structural defense is strong, and it is the same defense that applied to the FAIR Plan in the previous episode. Florida is a catastrophe exposed habitational market with a litigation environment carriers have spent a decade trying to price. Non-admitted paper can price to the model without filing for permission first. A large surplus lines share is the system doing what it was built to do, which is find capital for risk the filed market will not take at the filed rate. The capital is available. It is sitting on the other side of the wall.

What is harder to settle is the scale. At 43 percent, this is not a handful of buildings. A channel carrying close to half of a market is not an alternative market. It is the market, and the admitted system becomes the exception. None of that is visible from a quote. Whether a given layer of a tower is admitted or non-admitted is a structural fact about the program, and it does not appear on a quote summary or a renewal comparison. The odds are close to a coin flip on any individual layer, and it is entirely possible that no one has ever said so out loud. That makes it a distribution problem more than a policy problem.

What should owners and brokers do before the next renewal?

Ask for the program priced by layer rather than in total. The primary is very likely sitting at the national market price. The excess is where the money is going, and that is the layer to shop.

Ask which layers are non-admitted, and get the financial strength rating for each. Not because non-admitted is bad, but because that is worth knowing in August rather than in the middle of a claim.

For lenders and servicers, treat the 43 percent as portfolio level. That share of the Florida habitational market carries no filed rates and no guaranty fund behind it. It is a fact about the book, not a footnote on a deal.

Anyone can say Florida liability is expensive. What placement data adds is the ability to pull the primary apart from the excess, carrier by carrier, and find that only one of them is the problem.