The Ultimate Guide to ACORD 28 Evidence of Commercial Property in 2026

The ACORD 28 - Evidence of Commercial Property Insurance - is the form that lenders, mortgagees, and loss payees require to confirm that a commercial property has adequate property insurance coverage. It is not a certificate-of-insurance (ACORD 25, which covers liability). It is not a binder (ACORD 75, which creates temporary coverage). The ACORD 28 is a specific evidence-of-insurance document that shows the property insurance terms a lender needs to protect its security interest.

Getting ACORD 28 wrong costs time and sometimes transactions. A commercial mortgage closing held up because the ACORD 28 shows the wrong mortgagee language, the wrong coverage type, or missing ISAOA/ATIMA designation is a common and preventable failure.

Key Takeaways

• ACORD 28 is for commercial property insurance evidence. Use ACORD 27 for residential/personal property and ACORD 25 for liability coverage evidence.
• ISAOA/ATIMA language ("Its Successors and/or Assigns as Their Interests May Appear") is required by most commercial lenders and CMBS requirements to protect against loan transfers and securitization.
• Fannie Mae and Freddie Mac multifamily loan programs have specific property insurance requirements that determine minimum coverage amounts, coinsurance clauses, and acceptable carriers.
• CMBS loans require evidence that the property insurance carrier has an AM Best Financial Strength Rating of A- or better, Class VI or higher.
• The ACORD 28 does not modify the policy - it only evidences what the policy contains. Overstating coverage on the ACORD 28 is misrepresentation.
• The most common ACORD 28 errors: wrong coverage type checked, missing mortgagee, wrong ISAOA language, and missing deductible information.

What ACORD 28 Is and How It Differs from ACORD 25 and ACORD 27

Three ACORD forms cover property-related insurance evidence. The distinctions matter because using the wrong form triggers lender rejections and can delay closings.

ACORD 25 vs. ACORD 28. The ACORD 25 is a liability evidence form. It shows general liability, auto liability, workers compensation, umbrella/excess liability, and similar coverages. It has no mechanism for showing property coverage details - building value, coinsurance, deductibles, or mortgagee information. Lenders requesting commercial property evidence who receive an ACORD 25 will reject it because it does not contain the coverage information they need.

ACORD 27 vs. ACORD 28. Both are property evidence forms, but they serve different risk types. ACORD 27 covers personal/residential property - homeowner policies, dwelling policies, and similar personal lines. ACORD 28 covers commercial property - business owners policies (BOP), commercial property policies, and commercial package policies. A commercial lender will typically reject an ACORD 27 for a commercial property because the underlying coverage standards (minimum amounts, coinsurance requirements, carrier ratings) differ significantly.

The information gain that search results typically miss: Many commercial properties carry both a commercial property policy and a commercial general liability policy. The ACORD 28 evidences the property coverage only. The lender may also require an ACORD 25 for the liability coverage - particularly when the loan documents include a liability insurance requirement. Submit both when the loan requires both.

Every Field on the ACORD 28 Explained

Header Section

Date. The date the form is issued. Lenders frequently specify that the ACORD 28 must be current within 30 days of the closing date. An ACORD 28 issued months before closing may be rejected even if the underlying coverage has not changed.

Producer Information. The producing agency's name, address, phone, and fax. The producer is the contact for coverage verification. Lenders commonly call the producer directly to verify terms shown on the ACORD 28.

Company/Insurer Section

Insurer Name. The full legal name of the property insurance carrier. For commercial property, this must be the specific underwriting entity, not the holding company or trade name. "Travelers" is a trade name; "Travelers Property Casualty Company of America" is the underwriting entity. The distinction matters for carrier credit ratings and CMBS eligibility.

NAIC Code. The 5-digit NAIC company code. Lenders and CMBS servicers use the NAIC code to verify carrier licensing status and financial ratings. Including the NAIC code eliminates carrier identity ambiguity on loans that transfer or are securitized.

AM Best Rating. Most commercial lenders specify minimum AM Best Financial Strength Ratings (FSR). Standard commercial mortgage lenders typically require A- or better. CMBS loans require A- or better with a Financial Size Category of Class VI or higher. CMBS requirements reflect the need for the carrier to remain financially sound across the life of a 10-year commercial loan.

Insured and Property Section

Named Insured. The exact legal name of the property owner as it appears on the policy declarations page. For LLCs, LPs, and corporations, this must match the entity's legal name as filed. A mismatch between the ACORD 28 named insured and the borrower entity name on the loan documents creates a title issue that underwriters flag.

Mailing Address. The insured's mailing address, which may differ from the insured property address.

Description of Premises. The physical location of the insured property. For commercial property, include the full street address, city, state, and ZIP code. For multi-building properties, identify each building or location covered. A description that says "Insured's premises" without a specific address does not satisfy most lender requirements.

Coverage Section

Type of Coverage. The ACORD 28 provides fields for multiple commercial property coverage types:

• Building. The covered value of the building structure itself.
• Business Personal Property. Coverage for furniture, fixtures, equipment, and inventory owned by the insured.
• Business Income / Rental Value. Coverage for lost income or rental income if the property becomes uninhabitable due to a covered loss. Lenders on income-producing properties (apartment buildings, retail, office) typically require this coverage.
• Equipment Breakdown. Coverage for mechanical or electrical breakdown of equipment, separate from property damage.
• Other. Flood, earthquake, and other specialty coverages appear here when applicable.

Check only the coverages that actually exist under the policy. Checking uncovered lines is misrepresentation.

Causes of Loss - Policy Form. The ACORD 28 includes a section for noting the cause-of-loss form:

• Basic Form - covers fire, lightning, explosion, windstorm/hail, smoke, aircraft, vehicles, riot, vandalism, sprinkler leakage, sinkhole collapse, volcanic action
• Broad Form - adds collapse, weight of ice/snow/sleet, water damage
• Special Form - covers all risks of physical loss except those specifically excluded

Most commercial lenders require Special Form (or equivalent "All Risk" or "Open Perils") coverage. Basic Form and Broad Form coverage typically do not satisfy lender requirements for commercial mortgages.

Coverage Amount. The insured value of the building and each covered category. For lender requirements, the coverage amount typically must equal the replacement cost value (RCV) of the building - not the market value or the loan amount. Replacement cost value and market value often differ significantly, particularly for older commercial buildings.

Coinsurance Percentage. If the policy contains a coinsurance clause, the percentage must be shown. Standard commercial property coinsurance clauses are 80%, 90%, or 100% of replacement cost. A coinsurance clause means the insured must carry insurance equal to at least that percentage of the building's replacement cost value or face a proportional reduction in claim payments.

Deductible. The per-occurrence deductible for property damage claims. Most lenders accept standard deductibles up to $25,000 per occurrence. CMBS loans and some large-bank lenders require borrower approval for deductibles above $50,000. Wind, hail, and named storm deductibles (often expressed as a percentage of insured value rather than a flat dollar amount) must be shown separately.

Valuation Basis. Whether claims are paid on a replacement cost (RC) or actual cash value (ACV) basis. Most commercial lenders require replacement cost coverage. Actual cash value coverage (which deducts depreciation from claim payments) typically does not satisfy lender minimum standards.

Additional Interests Section - The ISAOA/ATIMA Field

The Additional Interests section is where lenders, mortgagees, and loss payees are identified. This section is the most consequential on the ACORD 28 for lender purposes.

Mortgagee. The lender with a security interest in the property. The mortgagee has the right to receive claim payments directly (up to the amount of the outstanding loan balance) in the event of a total or partial loss.

Loss Payee. A party with an insurable interest in specific property - often equipment lenders or lessors. Loss payees have the right to claim payment for their specific property interest, not the entire claim.

Additional Insured. A party granted coverage under the policy. For commercial property, additional insured status is less common than mortgagee status, but may appear when a ground lessor requires coverage under the tenant's property policy.

What ISAOA/ATIMA Means and Why Lenders Require It

ISAOA/ATIMA stands for "Its Successors and/or Assigns as Their Interests May Appear." It appears as a suffix after the mortgagee or loss payee name on the ACORD 28 and on the policy declarations page.

The ISAOA designation accomplishes two things:

Successor protection. Commercial loans are bought, sold, and transferred between lenders. A loan originated by Wells Fargo Commercial Real Estate may be serviced by a different entity within months. The ISAOA language means the mortgagee protections follow the loan - the successor servicer or purchaser automatically steps into the same position as the original mortgagee, without requiring a policy endorsement change.

Securitization protection. CMBS (Commercial Mortgage-Backed Securities) loans pool multiple commercial mortgages and sell interests to investors. The loan servicer may change, the loan may be transferred to a special servicer, and interests in the loan may be held by multiple investors. ISAOA/ATIMA verifies the mortgagee clause protections survive all these transfers.

The ATIMA component - "as their interests may appear" - limits each party's claim to their actual insurable interest. A lender with a $2 million mortgage on a $4 million building has a $2 million interest. ATIMA means the lender can claim only up to $2 million, not the full $4 million claim that the property owner might pursue.

Practical consequence of missing ISAOA language: When a CMBS or agency loan is sold and the new servicer discovers the mortgagee clause lacks ISAOA, they typically require the insurance carrier to issue a policy endorsement adding ISAOA language and a new ACORD 28. This creates delays and occasionally generates claims against the originating broker's E&O policy.

Lender-Specific Requirements for Commercial Mortgages

Commercial mortgage lenders - particularly government-sponsored enterprises and CMBS lenders - impose specific insurance requirements that go beyond what the ACORD 28 form itself requires. Agencies issuing ACORD 28 forms for commercial loan closings should know these requirements.

Fannie Mae Multifamily Loan Requirements

Fannie Mae's Multifamily Selling and Servicing Guide (Form 4660) requires:

• Property coverage in an amount not less than the replacement cost of improvements (100% RCV)
• Special Form (all-risk) or its equivalent
• AM Best FSR of A-/VIII or better, or equivalent S&P/Moody's rating
• No coinsurance clause, or a agreed value clause that eliminates the coinsurance penalty
• Named insured must match the borrower entity exactly
• Flood insurance required for properties in FEMA Special Flood Hazard Areas (SFHA)

The no-coinsurance requirement is significant. Most standard commercial property policies include an 80% coinsurance clause. Fannie Mae requires that the coinsurance clause be eliminated - typically by adding an Agreed Value endorsement (ISO CP 04 02) to the policy. The ACORD 28 must note the Agreed Value endorsement in the Special Conditions field.

Freddie Mac Multifamily Loan Requirements

Freddie Mac's Multifamily Seller/Servicer Guide (Chapter 8) has similar requirements:

• 100% replacement cost coverage
• Special Form or equivalent
• AM Best FSR of A-/VI or better
• Replacement cost endorsement (no ACV settlement clauses)
• Flood insurance in SFHAs

Freddie Mac also requires that the insurer be licensed in the state where the property is located and not be on the California DOI's "non-admitted" list for California properties.

CMBS Loan Requirements

CMBS loan requirements are set by the rating agencies (Moody's, S&P, Fitch) and the CMBS trust documents rather than by a single servicing guide. Typical CMBS property insurance requirements:

• AM Best A-/VI or better (stricter than agency loans in some cases)
• ISAOA/ATIMA language on all mortgagee designations
• Replacement cost coverage with agreed value endorsement (no coinsurance)
• Business income / rental value coverage equal to 12 months' gross revenue
• Terrorism coverage required for properties above specific loan amount thresholds (post-TRIA)
• Annual insurance certification from the borrower and the insurance carrier

The terrorism coverage requirement under the Terrorism Risk Insurance Act (TRIA) applies to CMBS loans above $50 million in many trust documents. The ACORD 28 should note TRIA coverage or its exclusion in the Special Conditions field.

Common ACORD 28 Errors

Wrong Coverage Type Checked

The most common error: checking the "Building" coverage box when the insured holds a tenant position with no building coverage (only Business Personal Property coverage). Or checking "All Risk" under Causes of Loss when the policy is a Basic Form policy. Each checked box is a representation about the policy - an inaccurate checked box is a misrepresentation.

Missing or Incorrect Mortgagee Information

Mortgagee information must match the loan servicer's requirements exactly. "Bank of America, N.A." and "Bank of America Mortgage, LLC" are different entities. The mortgagee name must match the entity identified in the loan documents. For CMBS loans, the mortgagee is often a trust or servicer entity with a specific legal name.

Wrong ISAOA Language

Some agencies abbreviate or modify ISAOA/ATIMA language. "ISAOA" alone (without "ATIMA") does not carry the "as their interests may appear" limitation. Some lenders accept ISAOA alone, but CMBS servicers commonly require the full ISAOA/ATIMA designation. Use the complete standard language.

Missing Wind/Hail or Named Storm Deductible

Standard property deductibles are often different from wind, hail, and named storm deductibles. A commercial property in Florida may carry a $5,000 per-occurrence deductible for most perils but a 2% of insured value wind/hail deductible. If the ACORD 28 shows only "$5,000" in the deductible field without noting the wind/hail deductible separately, the lender does not have accurate information. CMBS servicers commonly flag this discrepancy.

Wrong Valuation Basis

Showing "Replacement Cost" when the policy settles on an Actual Cash Value basis is a misrepresentation. Check the policy's valuation basis - specifically the loss settlement condition in the commercial property coverage form (ISO CP 00 10 or equivalent) - before completing the valuation field.

Stale Form

Most lenders require that the ACORD 28 be issued within 30-60 days of the closing or loan anniversary date. An ACORD 28 showing a policy renewal from 9 months ago may still accurately reflect current coverage but will be rejected by a lender's closing desk. Issue a fresh ACORD 28 at each renewal and for each closing.

How BrokerageAudit Supports ACORD 28 Accuracy

BrokerageAudit's ACORD Form Library stores the current ACORD 28 form and links it to client policy data, so the coverage fields populate from the policy record rather than from manual entry. Manual entry is where most ACORD 28 errors originate - the wrong deductible amount transcribed, the wrong carrier name, the wrong mortgagee entity.

For related commercial property documentation, see our guides on commercial property evidence workflows and lender insurance requirements for commercial loans.

Frequently Asked Questions

What is the ACORD 28 used for?

The ACORD 28 is the Evidence of Commercial Property Insurance form. Lenders, mortgagees, and loss payees on commercial properties request it to confirm that the property has adequate property insurance coverage. It shows the insurer, policy number, coverage types and limits, deductibles, valuation basis, and the mortgagee or loss payee information the lender needs to protect its security interest. It is not a certificate of liability insurance (ACORD 25) and not an insurance binder (ACORD 75).

What is the difference between ACORD 27 and ACORD 28?

ACORD 27 is the Evidence of Property Insurance form for personal/residential property - homeowner policies, dwelling policies, and personal auto physical damage. ACORD 28 is the Evidence of Commercial Property Insurance form for commercial property policies. Commercial mortgage lenders, CMBS servicers, and commercial real estate lenders require ACORD 28. Residential lenders require ACORD 27. Using the wrong form for the property type typically results in rejection by the lender's closing department.

What does ISAOA/ATIMA mean on an ACORD 28?

ISAOA/ATIMA stands for "Its Successors and/or Assigns as Their Interests May Appear." ISAOA verifies that the mortgagee protections transfer automatically when a loan is sold, transferred, or securitized - without requiring a policy endorsement change each time. ATIMA limits each party's claim to their actual insurable interest in the property. CMBS loans require ISAOA/ATIMA language on all mortgagee designations because commercial loans are routinely securitized and transferred between servicers.

What carrier rating does a lender require on an ACORD 28?

Requirements vary by lender type. Fannie Mae multifamily loans require AM Best FSR of A-/VIII or better. Freddie Mac multifamily loans require A-/VI or better. CMBS loans typically require A-/VI or better, though some CMBS trust documents specify stricter standards. Standard commercial bank lenders typically require A- or better without a specified financial size category. The AM Best rating should be noted on the ACORD 28 in the Special Conditions field or the carrier information section.

What coverage types must be checked on an ACORD 28 for a commercial mortgage closing?

Most commercial mortgage lenders require: Building coverage (100% replacement cost), Special Form causes of loss, an Agreed Value or equivalent endorsement eliminating the coinsurance clause, and Business Income/Rental Value coverage equal to 12 months' operating income for income-producing properties. Flood coverage is required for properties in FEMA Special Flood Hazard Areas. Terrorism coverage under TRIA is required for some loan types above specified thresholds. Check only coverages that actually exist under the policy.

What are the most common ACORD 28 errors that delay closings?

The five most common closing-delay errors: (1) missing or incorrect mortgagee entity name - the ACORD 28 mortgagee must match the loan servicer's entity name exactly; (2) wrong ISAOA language - CMBS loans require "ISAOA/ATIMA," not just "ISAOA"; (3) missing wind or named storm deductible - percentage-based wind deductibles must be shown separately from the standard per-occurrence deductible; (4) wrong valuation basis - actual cash value coverage shown as replacement cost; (5) stale form - most lenders require an ACORD 28 issued within 30-60 days of closing.

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Written by Javier Sanz, Founder of BrokerageAudit. Last updated April 2026.

Issue accurate ACORD 28 forms directly from policy data. BrokerageAudit's ACORD Form Library populates coverage fields from the policy record, eliminating the transcription errors that delay commercial closings and create lender rejection loops. Explore ACORD Form Library