2026
The CARES Act, Crime Scores, and Affordable Housing Insurance Costs
Your renewal came back higher again. You didn’t file a claim. Your manager runs a tight property. So who decided your risk went up?
For a lot of affordable housing owners, part of the answer runs through a pandemic relief law from 2020 and a crime score you have probably never seen. This post lays out what is documented, what is not, and what it is costing your NOI.
What a crime score is, and who is using it
A crime score is a number a third-party data vendor assigns to a property address, based on reported crime in the surrounding area. Many carriers use it when they price multifamily general liability. A high score can mean a surcharge, reduced coverage, or a flat decline.
The National Apartment Association (NAA) told Congress that many carriers are declining to write general liability on affordable and subsidized communities, and that crime score methodology is one factor. Because affordable units are often in areas with higher scores, NAA says stakeholders worry the practice works as de facto discriminatory redlining of affordable housing.
Here is the part that should bother you. A 2020 report from the Stewards of Affordable Housing for the Future (SAHF), Scott Insurance, Virginia Community Capital and Virginia Tech’s Center for Real Estate Excellence found that scores are often estimated from larger census blocks and do not account for property-specific features like design or management practices. In interviews for the Counselors of Real Estate, brokers and operators said carriers will not change a score because of the crime-prevention work you do.
So you can fix the lighting, tighten screening, and keep the building spotless, and the number may not move.
Where the CARES Act comes in
The CARES Act of 2020 paused evictions for nonpayment in federally backed and federally assisted housing. It also required 30 days’ notice before filing for eviction in those properties once the pause ended. NAA says that notice was meant to be temporary, that the statute’s language is ambiguous, and that it still affects about 40% of U.S. rental housing, including Section 8 and Fannie Mae or Freddie Mac-backed properties. State notice periods average 6 days.
If you want the full breakdown of the CARES Act 30-day notice, we wrote it up separately. The short version: where courts enforce it, you wait 24 more days than state law would have you wait.
What does that cost you? NAA’s member survey puts the average eviction at $6,767, counting legal fees, court fees, lost rent, turnover and marketing.
Example, not a forecast: ten evictions at that average is $67,670 out of your cash flow.
Is it one chain or two squeezes? Be honest about it
It is tempting to draw one straight line from eviction delay to crime scores to your premium. We have not found published data that proves that line. Crime scores come from area data, and the CARES notice applies to nonpayment cases.
What the evidence does show is two pressures landing on the same owners:
The notice slows your cash flow when a resident stops paying.
The crime score can restrict or reprice your liability coverage, no matter how well you manage.
And a third pressure is working underneath both. A recent rate analysis from Advocate Technologies, reported by Insurance Journal, found that multifamily liability pricing is tracking lawsuits, not crime. That points back to the courtroom, which is where nuclear verdicts come from. A carrier can use a crime score and still be pricing mostly off the lawsuits.
Why affordable housing owners feel it most
You cannot push this through to residents. NAA and its coalition point out that Low-Income Housing Tax Credit (LIHTC) rent and income restrictions typically stop owners from passing insurance increases through in rent. So when multifamily insurance costs climb, it comes straight out of your NOI. In some markets coverage gets harder to find too, and some owners end up with portfolios no carrier wants.
What is happening in Washington
The Respect State Housing Laws Act (H.R. 1078 / S. 470) would strike the 30-day notice from the CARES Act and return eviction timelines to the states. As of late October 2026, H.R. 1078 has been reported out of the House Financial Services Committee and sits on the House calendar with 58 cosponsors. It has not had a floor vote. NAA is pushing to move it on a must-pass bill during the lame-duck session.
That would help your cash flow. It would not rewrite how a carrier scores your address.
What you can do today
Ask your broker three things:
What crime score vendor does my carrier use, and what is my score?
Does my carrier allow property-specific adjustments, and what proof do they accept?
How much of my rate change did the carrier attribute to the litigation market?
Then ask the bigger question: who keeps your money when claims come in low? Under a traditional policy, it is the carrier and its shareholders.
Insur3Tech works differently. A captive is an insurance company owned by the people it insures, and Insur3Tech brings that model to real estate owners. There is no minimum premium. There are no holdout periods. The entire program is reinsured, so you carry no downside risk. Your premium comes back to you. We are built for every portfolio size and asset type, and we insure 100,000+ doors.
Be straight with yourself about the limits. A captive does not change your crime score or how your carrier prices your address. Before you change any coverage your lender or investors require, talk to them first. For a primer on how loss ratio shapes who profits, start there.
Want to know what your own renewal is really made of? Book a free discovery call and we will walk through your current insurance spend with you.
