Roof certification for insurance, and why it is not a WPI-8

The word certification is doing too much work on the coast. It is used for a professional opinion about the condition of a roof, and it is used for the department's certificate of compliance for the work that put the roof there. An agent asked for a roof certification for insurance, and a title file being assembled, can each end up holding the wrong one.

The roof certification: an opinion about condition

A roof certification is a professional's written opinion about a roof as it stands: its condition, and often its remaining service life, for somebody who has to rely on it. When it is an engineer's, it carries a seal under section 1001.401 of the Occupations Code, and rule 137.33 makes the engineer fully responsible for what it states. What such an opinion properly rests on is set out on the roof inspections page.

No statute makes a roof certification a condition of association coverage. Its requirements are set by whoever asked for it, whether a lender, a buyer, or a carrier's own underwriting, and it answers their question and nobody else's.

The WPI-8: the department's certificate for the work

A certificate of compliance is issued by the Texas Department of Insurance under section 2210.2515 of the Insurance Code for an improvement, which that section defines to include repair and alteration. A re-roof inside the catastrophe area is that kind of improvement. Section 2210.251(g) says the certificate is evidence of insurability of the structure by the association, section 2210.258(b) bars the association from insuring covered work until it has issued, and section 2210.2515(k) says the department may not rescind it once issued.

It says the work complied when it was inspected. It says nothing about how that roof looks now, fifteen years and several storms later.

Why neither substitutes for the other

A roof in excellent condition with no certificate for its installation is still work the association's statute says it may not insure without one, subject to that section's exceptions. A roof with a valid certificate from years ago may be in poor condition today, and the certificate is not a statement about that.

One asks whether the work was inspected and found compliant. The other asks what state the roof is in. A coastal transaction usually needs to know both.

At binding

For association coverage the question to settle first is the certificate, because the statute makes it the gate. Whether a certificate has issued for the roof's installation, or whether one of the exceptions in section 2210.258 applies, is covered on the TWIA eligibility requirements page. A condition report, however favorable, does not open that gate.

At sale

On a sale, the windstorm record for the structure is searchable, and the useful check is whether the certificates on file account for the roof actually on the house. A roof visibly newer than the house with nothing on file behind it is the classic finding, and the coastal closing page sets out how to look.

On the Coastal Bend there is a wrinkle tied to dates. Hurricane Harvey came ashore near Rockport in 2017, and the department's completed construction page says the Texas Windstorm Insurance Association issued completed construction certificates, the WPI-8C, between January 1, 2017 and May 31, 2020. Those came from the association, not the department. A search of department records alone will not show one, and its absence there is not proof the roof was never certified.