January 31, 2022

The Hon. Ross Romano, MPP
Minister of Government & Consumer Services
777 Bay St, College Park
5th Floor, Toronto, ON M7A 2J3

Dear Minister Romano:

The Association of Condominium Managers of Ontario (ACMO) is pleased to participate in the MGCS’s consultation regarding condominium insurance which is a critical issue currently facing the industry.  In recent years, ACMO members have reported significant increases in insurance premiums and deductibles for the condominiums they manage, and difficulties in finding companies willing to insure their condominium.

We have provided detailed commentary and suggestions in the Condominium Insurance Feedback Form submitted through the Ontario Regulatory Registry, but for convenience some of our key points are summarized below: 

• The industry needs legislation that mandates that condominium owners and tenants must maintain insurance and provide proof of same on an annual basis. 
• Set a minimum coverage standard for condominium insurance (e.g. minimum $5,000,000 liability and $5,000,000 Directors and Officers insurance) 
• We strongly disagree with the suggestion to proclaim the replacement of section 105 of the Condo Act given it is almost impossible to change the condominium declaration. Instead we suggest mandating that all owners be responsible for the deductibles and by-laws be put in its place to remove the onus from the owners.
• We support the unproclaimed changes to sections 93/95 that would expand the purposes for which reserve funds can be used with the caveat that Condo Corporations be required to budget a claims allowance within their reserve fund.
• The condominium corporation should NOT be required to maintain insurance coverage for damage to improvements to a unit. Doing so is unreasonable as it effectively makes all owners responsible for the changes to one unit which could drive up condominium fees and make them unaffordable for some owners.
• We should not try and regulate a standard unit definition under the Condo Act. Instead simply allow the condominium to pass a standard unit by-law with a lower voting threshold to gain approval, similar to current electronic voting practice. 
• The Ontario Building Code should be modified to specify that leak detection systems be installed in condos with automatic shutoffs to mitigate water damage.
• The CMRAO licensing education for managers should include education related to understanding the condo insurance policy, obtaining quotations for insurance, understanding co-insurance, use of a trustee, and general practice on how to make a claim, etc.

We would be glad to discuss this further with you. Thank your efforts to improve the regulations and for considering this additional submission.

Best Regards,

Paul MacDonald
Executive Director of ACMO

Katherine Gow
President of ACMO