RCBAP Explained: How Condo Association Flood Insurance Pays After a King Tide

Short answer

What the RCBAP covers and how much it pays

The RCBAP insures the residential condominium building, including all units and the improvements within them, against direct physical loss by flood, up to the lesser of the building's replacement cost or $250,000 times the number of units. Building losses are paid at replacement cost, but only if the association carries insurance equal to at least 80 percent of the building's replacement cost or the NFIP maximum, whichever is less. Carry less and every building claim is reduced by the same proportion as the shortfall. Below-grade garages and enclosures are covered only for a listed set of equipment and building elements, including electrical panels, elevators, pumps, and water heaters. Seawalls, docks, pool decks, and pools are not covered. The association must send a signed and sworn proof of loss within 60 days of the loss.

Who buys the RCBAP

The RCBAP is the NFIP policy form for a residential condominium building owned by a condominium association in a Regular Program community. The association is the named insured. The policy covers the whole building, including the units, which is why it is sometimes called a master flood policy. Unit owners cannot buy an RCBAP. They buy an individual NFIP Dwelling Form policy on their unit, or a private flood policy, which sits in excess of the RCBAP for building items and covers their own contents.

Florida's condominium statute, section 718.111(11)(a), requires every association to carry adequate property insurance based on the replacement cost of the property, determined by an independent appraisal at least once every 3 years. Flood is handled separately. Section 718.111(11)(e) says the association may also obtain and maintain flood insurance for common elements, association property, and units. The word is may. Many associations carry it because a lender, a declaration, or the building's flood zone demands it. The duty to carry it is a board decision documented in the minutes, not a statutory command.

What the building coverage includes

Coverage A under the RCBAP insures the residential condominium building, including all units within the building and the improvements within the units. Improvements means fixtures, alterations, installations, or additions, including improvements in the units. The form then lists fixtures, machinery, and equipment insured under building coverage only: awnings, blinds, permanently installed carpet over unfinished flooring, central air conditioners, elevator equipment, fire extinguishing apparatus and sprinkler systems, walk-in freezers, furnaces, light fixtures, outdoor antennas fastened to the building, permanently installed cupboards, bookcases, paneling and wallpaper, pumps and their machinery, ventilating equipment, permanently installed wall mirrors, and, inside the units, built-in dishwashers and microwaves, garbage disposals, water heaters, kitchen cabinets, plumbing fixtures, radiators, ranges, refrigerators, and stoves.

Read that against Florida's master property policy rule. Section 718.111(11)(f) makes the association's property policy exclude floor, wall, and ceiling coverings, electrical fixtures, appliances, water heaters, built-in cabinets and countertops, and personal property inside the units, which are the unit owner's responsibility. The RCBAP does not follow that split. It covers the units' kitchen cabinets, water heaters, and built-in appliances as part of the building. So after a king tide, the ground-floor unit's cabinets and water heater are an association flood claim even though they would be the owner's problem on a wind or fire loss. Boards and managers should scope the units, not just the common areas.

Limits: $250,000 per unit, or replacement cost, whichever is less

FEMA's regulation at 44 CFR 61.6 sets the maximum RCBAP building limit at $250,000 times the number of units in the building. The most the policy will actually pay is the lesser of that figure or the building's replacement cost. A 40-unit building can carry up to $10 million. A 10-unit building can carry up to $2.5 million. If the building's replacement cost is below that cap, replacement cost is the ceiling. Contents coverage for association-owned property is a separate limit, up to $100,000.

Two practical points. First, the limit is per building, and a multi-building community needs a policy on each building. Second, lenders financing units in a Special Flood Hazard Area commonly require the association to carry 100 percent of replacement cost or the per-unit maximum, not just the 80 percent coinsurance threshold. A board that buys to the 80 percent line can find its unit owners unable to close or refinance.

The 80 percent coinsurance penalty, with the numbers

Section VII of the RCBAP applies to building coverage only. The carrier will impose a penalty on any loss payment unless the amount of insurance on the damaged building is at least 80 percent of its replacement cost or the maximum available under the NFIP, whichever is less. If the building is underinsured, payment is calculated in three steps: divide the insurance carried by the insurance required, multiply the loss before deductible by that fraction, then subtract the deductible.

The policy's own example. A building with a $250,000 replacement cost needs $200,000 of coverage, which is 80 percent. The association carries $180,000. A $150,000 flood loss with a $500 deductible pays like this: $180,000 divided by $200,000 is 0.90. $150,000 times 0.90 is $135,000. Less the $500 deductible, the carrier pays $134,500. The $15,000 shortfall is the coinsurance penalty, and it becomes a common expense of the association.

Scale that to a real coastal building. A 20-unit tower with an $8 million replacement cost needs $5 million of coverage (80 percent of $8 million is $6.4 million, but the NFIP maximum for 20 units is $5 million, and the required amount is the lesser). If the board bought $3 million to save premium, the ratio is 0.60. A $1 million garage and switchgear loss pays $600,000 less the deductible. The other $400,000 is assessed to the owners. Coinsurance applies only to the building. It never applies to contents. And building coverage that unit owners carry on their own dwelling policies cannot be added to the association's limit to escape the penalty.

The fix is cheap compared with the penalty: a current replacement cost appraisal, which section 718.111(11)(a) already requires every 3 years for the property policy, and an RCBAP limit set to the lesser of full replacement cost or the per-unit maximum.

Below-grade garages, elevators, and switchgear

The RCBAP defines a basement as any area of the building with its floor below ground level on all sides. In a basement, and in an enclosure below the lowest elevated floor of an elevated post-FIRM building in a zone beginning with A or V, coverage is limited to a specific list of items installed in their functioning locations: central air conditioners, cisterns, unfinished drywall in a basement, electrical junction and circuit breaker boxes, electrical outlets and switches, elevators, dumbwaiters and related equipment (except related equipment installed below the base flood elevation after September 30, 1987), fuel tanks and fuel, furnaces and water heaters, heat pumps, nonflammable insulation in a basement, solar system pumps and tanks, stairways attached to the building, sump pumps, water softeners and filters, well tanks and pumps, required utility connections for those items, and footings, foundations, posts, pilings, piers, and other foundation elements. Cleanup is also covered.

For a coastal condo after a king tide, that list is the claim: the main electrical switchgear and panels in the garage, the elevator machine room and pit equipment, the domestic water booster pumps, the fire pump, the garage drainage pumps, and the water heaters. The finished garage walls, the storage cages and their contents, the gym equipment, and the lobby furniture in a below-grade level are not covered. Note the elevator limitation. Controllers, drives, and other related equipment installed below base flood elevation after September 30, 1987 are excluded, which affects any building that modernized its elevators and left the equipment in the pit or a below-grade machine room. Get the elevator contractor to identify what is original and what was installed later, and when.

What the RCBAP does not cover

• Seawalls, bulkheads, retaining walls, fences, wharves, piers, bridges, and docks.
• Swimming pools, hot tubs and spas that are not bathroom fixtures, and their heaters, filters, pumps, and pipes, wherever located.
• Walks, walkways, decks, driveways, patios, and other surfaces outside the perimeter exterior walls of the building, roofed or not. Pool decks fall here.
• Land, land values, lawns, trees, shrubs, and plants. Landscaping losses are a common expense, not a flood claim.
• Underground structures and equipment, including wells, septic tanks, and septic systems.
• Vehicles, with a narrow exception for unlicensed vehicles used mainly to service the property while inside the building.
• Currency, deeds, securities, and valuable papers.
• Loss of revenue, loss of use, additional living expenses, and any other economic loss. Lost rental income on association-owned units and the cost of relocating residents during elevator outages are not covered.
• Mold and mildew that result from a condition within the association's control, including failure to inspect and maintain the property after a flood recedes. Dry the building fast and document it.

Contents: the association's, not the owners'

Coverage B under the RCBAP applies to personal property inside the fully enclosed insured building that is owned by the unit owners in common or owned solely by the association and used in its business. Lobby furniture, fitness equipment, office computers, maintenance tools, and pool furniture stored inside qualify, subject to the basement limitation. Contents are paid at actual cash value. Unit owners' personal property is never covered by the RCBAP. Each owner needs their own flood policy with contents coverage for that.

Unit owners: HO-6 excludes flood, and loss assessment coverage has a flood catch

A standard HO-6 unit owner policy excludes flood, including tidal water and storm surge. Florida's section 627.714 requires every unit owner policy to include at least $2,000 of loss assessment coverage, with a deductible of no more than $250, but only for assessments resulting from the same direct loss of the type of loss covered by the unit owner's residential property insurance policy. Because the HO-6 does not cover flood, its loss assessment coverage generally does not respond to a flood assessment.

The unit owner's NFIP Dwelling Form policy does. Section III.C.3 of that form pays, up to the owner's building limit, the owner's share of a loss assessment charged by the association because of direct physical flood loss to the unit or the common elements of the NFIP-insured building. It will not pay an assessment that results from the association's flood deductible, from a loss to contents, or from a governmental charge, and combined payments on a unit under the RCBAP and the owner's dwelling policy cannot exceed the single-family maximum. Whether an assessment caused by the association's coinsurance shortfall is paid is a question to put to the owner's flood carrier in writing. Boards should tell owners now, before the November and December tides, that a flood assessment is a real possibility and that only a flood policy on the unit is likely to help with it.

Board duties, documentation, and minutes

Section 718.111(11)(j) makes insurance deductibles and damages in excess of coverage a common expense, with limited exceptions for damage caused by an owner's negligence. That means every dollar the RCBAP does not pay, whether because of the deductible, the coinsurance penalty, an excluded item, or a missed deadline, lands on the owners. The board's exposure is in the file. Document the decision to buy or not buy flood coverage, the limit chosen and why, and the replacement cost appraisal relied on. After a loss, document the date and time water entered, the areas affected, the emergency vendors called, the decisions made and when, and every communication with the carrier.

• Board minutes or a written emergency action by the president authorizing the claim, the emergency contractors, and the engagement of any public adjuster or counsel.
• The property manager's incident log with timestamps, resident notices, and photos of the waterline in every affected space.
• Electrician, elevator contractor, and fire pump vendor reports stating what failed, when it was installed, and whether it is repairable.
• FPL correspondence about disconnection and reconnection and the inspection the utility required.
• The current replacement cost appraisal and the RCBAP declarations page, to confirm the coinsurance position before the proof of loss is signed.
• Invoices for pumping, drying, debris removal, generator rental, and temporary power.
• Tide gauge data and news coverage for the date of loss, saved as PDFs, to establish a general and temporary flood condition.

The proof of loss clock runs on the association too

The RCBAP requires the association to send a signed and sworn proof of loss within 60 days after the loss. For an October 27 loss that is December 26, 2026. For October 28 it is December 27. The carrier's adjuster will usually present a proof of loss matching the carrier's estimate. On a condo garage loss the first estimate is often incomplete because the electrical and elevator damage has not been fully diagnosed. The board can sign for the undisputed amount and submit its own proof of loss for the rest, supported by vendor estimates, as long as everything is in before day 60. Only FEMA can extend that deadline, and as of November 2 it has not for the October tides. Appraisal, a FEMA appeal within 60 days of any written denial, and a federal suit within one year of the first written denial are the dispute options, and the association has no bad faith claim against an NFIP carrier.

A Florida licensed public adjuster can represent the association on the RCBAP claim: inspecting the building, scoping the covered below-grade equipment against the policy list, coordinating the electrician and elevator reports, separating any rain or wind damage that belongs on the master property policy, preparing the proof of loss, and running the deadlines. The NFIP does not pay that fee, and a public adjuster does not give legal advice. James Coyne adjusted claims for carriers before he represented policyholders. On an association loss, the value is a complete file before the deadline, so the board is not explaining a shortfall to the owners later.

Boards should also know the cancellation right in section 626.854(7), Florida Statutes. An association may cancel a public adjuster contract for any reason, without penalty, within 10 days after signing. For a claim arising from an event under a Governor's state of emergency declaration, the window is 30 days after the date of loss or 10 days after signing, whichever is longer. As of November 2, 2026, Executive Order 26-227 covers the October 31 to November 2 rain in Brevard, Indian River, St. Lucie, Martin, Highlands, Hardee, and DeSoto counties. No emergency order has been issued for the October king tides, so the 10-day window applies to those contracts. A state order is also not a Presidential disaster declaration, so it does not open FEMA Individual Assistance.

Commonly Asked Questions

Related

• King tide flood claim checklist for condo boards →
• NFIP proof of loss: the 60-day deadline →
• How to file an NFIP flood claim, step by step →
• NFIP claim denied or underpaid: appeal, appraisal, or lawsuit →
• King tide flood claims in South Florida →
• Condo association hurricane claims in Florida →
• Board insurance obligations under 718.111(11) →
• Your home or building flooded in Florida: what to do →
• For condo and HOA boards →
• For property managers →

About the Author

James Coyne

Florida Licensed Public Adjuster, License W482618. Founder of Coyne Commercial Group, Firm License G350978, Sanford, Florida. Represents commercial property owners, condominium and HOA associations, and homeowners on insurance claims statewide.

Sources

• NFIP Residential Condominium Building Association Policy, 44 CFR Part 61 Appendix A(3): Coverage A and improvements, basement items III.A.8, property not covered IV, exclusions V, coinsurance VII with examples, proof of loss, appraisal, suit, loss settlement
• 44 CFR 61.6 Maximum amounts of coverage available: residential condominium building $250,000 times the number of units; contents $100,000
• NFIP Dwelling Form, 44 CFR Part 61 Appendix A(1), III.C.3 Condominium Loss Assessments
• Fla. Stat. 718.111(11) (2026): adequate property insurance, replacement cost appraisal at least every 3 years, (e) association may obtain flood insurance, (f) unit owner items, (j) deductibles and excess damages as common expense
• Fla. Stat. 627.714 (2026): unit owner policies must include at least $2,000 loss assessment coverage for losses of a type the policy covers
• Big I Virtual University: RCBAP and Insurance to Value (coinsurance worked example; lender 100 percent requirement; per-unit maximum)
• FEMA NFIP Claims Manual (March 2025 edition): proof of loss extensions require FEMA waiver; supplemental proof of loss
• 44 CFR 62.20 claims appeals: 60 days from written denial; one-year suit period not extended
• FloodSmart Write Your Own bulletins index (checked November 2, 2026; no proof of loss extension for the October 2026 king tides)
• ClickOrlando: Port Canaveral gauge record during the October 2026 king tides
• South Florida Water Management District and county king tide calendars: November 22 to 29 and December 22 to 27, 2026 windows
• Fla. Stat. 626.854(7) (2026): public adjuster contract cancellation, 10 days, or 30 days after the loss under a declared state of emergency
• WFTV: Executive Order 26-227 state of emergency for seven counties (November 2, 2026)

This page is for general information, not legal advice or a coverage determination. Confirm any deadline or obligation against your policy, your association’s governing documents, and current Florida law.