A construction lender wants evidence of property insurance before a draw

ACORD 27 vs ACORD 28: evidence of property insurance

Both are short evidence of property insurance forms that tell a lender a building is insured and that the lender is named on the policy. ACORD 27, Evidence of Property Insurance, is the short form: one open grid for coverages, amounts and deductibles. ACORD 28, Evidence of Commercial Property Insurance, is the long form: separate yes-or-no lines for replacement cost, coinsurance, business income, flood, wind, ordinance or law and more. Which one you need is whatever your lender's written requirement names; some lenders' documents accept either, and Fannie Mae's multifamily guide lists ACORD 28, paired with ACORD 25, among its temporary forms.

Updated . Written by Andre Beukers, principal at Redoubt, a commercial insurance agency in Salt Lake City, not a government office.

What is evidence of property insurance?

Evidence of property insurance is a short summary an agent or carrier issues to a party with a financial interest in insured property, such as a mortgage lender, so that party can confirm the building is covered and that its interest is recorded on the policy. The ACORD versions call that party the "additional interest" rather than the certificate holder, and both forms open with the same disclaimer: the evidence "is issued as a matter of information only and confers no rights upon the additional interest named below."

That disclaimer is the most important line on the page. The lender's rights come from the policy, through a mortgagee clause or a lender's loss payable endorsement, not from the form. If the policy does not name the lender, checking the mortgagee box on an ACORD 27 or 28 does not fix it. Utah's certificate statute defines a "certificate of insurance" by what it does, not what it is called: a document issued to a non-policyholder as evidence of insurance, "regardless of how it is titled or described," and a certificate cannot alter the coverage it describes. The statute does not name ACORD 27 or 28; read on its terms, an evidence of property form issued to a lender fits that definition.

Sources: 1, 2, 10, 11

What is the difference between ACORD 27 and ACORD 28?

The two forms carry the same identity block (agency, insurer, named insured, loan number, policy number, effective and expiration dates, property location) and the same cancellation box, which promises only that notice "will be delivered in accordance with the policy provisions." They differ in how much of the coverage they force the agent to spell out.

ACORD 27 gives the coverage section one open grid headed "coverage / perils / forms," "amount of insurance" and "deductible," plus a remarks box. The agent writes in whatever applies. Its additional interest box offers mortgagee, lender's loss payable, loss payee and additional insured.

ACORD 28 is titled for commercial property and turns the coverage section into a checklist. Each line is answered yes, no or not applicable, with a limit and deductible where it applies. It also asks the agent to complete a separate form for each insurer when a policy is split among companies, and it adds a line for permission to waive subrogation in favor of the mortgage holder before a loss. Its additional interest box offers mortgagee, lender's loss payable and contract of sale, with a field for the lender's servicing agent.

  • Pick the form the lender's letter names; if it names none, ask which it wants before the agent issues
  • A lender that reviews flood, wind, coinsurance or replacement cost line by line will find those answers printed on ACORD 28
  • On either form, the mortgagee or loss payee box has to match the clause on the policy

Sources: 1, 3, 4, 5, 7

What does the ACORD 28 form show?

The edition hosted by New York City's Department of Design and Construction is ACORD 28 (2014/01). It runs two pages; the second is a remarks sheet used only when more space is needed. Beyond the identity block, it asks for the perils insured (basic, broad or special), the commercial property amount of insurance and deductible, and whether building, business personal property, or both are covered. Then come the yes-no lines: business income or rental value, blanket coverage and the value reported for this property, terrorism and any terrorism exclusion, limited fungus coverage, replacement cost, agreed value, coinsurance percentage, equipment breakdown, ordinance or law (undamaged portion, demolition, increased cost of construction), earth movement, flood, wind and hail, and named storm.

Above the coverage lines the form repeats a warning a lender should read literally: the insurance is "subject to all the terms, exclusions and conditions of such policies," and "limits shown may have been reduced by paid claims." An ACORD 28 reports what the policy says on the day it is issued. It does not guarantee that a flood or wind limit is still intact after a loss, and a box marked yes is only as good as the endorsement behind it.

Sources: 3, 6, 5

What does the ACORD 27 form show?

The edition hosted by the same New York City office is ACORD 27 (2016/03). It carries the identity block, a property location and description, the perils insured (basic, broad or special), and the open coverage grid with an amount and deductible per line. Everything the lender cares about beyond that, such as replacement cost, a flood sublimit, or a builder's risk form number, goes in the coverage grid or the remarks box in the agent's own words.

Lender documents reflect that flexibility. One bank's internal staff guide, Capital City Bank's builder's risk guide (found as a copy on a knowledge-base sandbox), says coverage details are listed in the "(ACORD) 27 or 28," and the Wisconsin Housing and Economic Development Authority lists ACORD 27 among the forms it accepts as temporary evidence at a construction closing. Each names its own contents. The bank's guide asks for the property address, amount of coverage, contractor's name, the bank as mortgagee, and the policy and expiration dates. WHEDA asks for the dates of coverage, dollar amount, property covered, insurer, policy number, the agent who placed the insurance, and the lender as an additional insured.

Sources: 1, 18, 15, 17

What is the difference between ACORD 25 and ACORD 28?

ACORD 25 is the Certificate of Liability Insurance. Its coverage lines are commercial general liability, automobile liability, umbrella or excess liability, and workers' compensation and employers' liability. It names a certificate holder and warns that additional insured status and a waiver of subrogation come from the policy, not from the certificate. It has no field for a building's amount of insurance, its perils, its deductible, or a mortgagee.

ACORD 28 is the property counterpart. A commercial lender can ask for both, because the loan is secured by the building (ACORD 28 or 27) and the lender also wants the borrower's liability on file (ACORD 25). Fannie Mae's multifamily guide lists that pairing as one of its acceptable temporary forms at closing, "ACORD 28 Evidence of Commercial Property Insurance ... combined with ACORD 25 Certificate of Liability Insurance," alongside an ACORD 75 binder, a joint letter from the borrower and its broker, and flood insurance items.

One bank's internal staff guide, Capital City Bank's, shows "an example of an ACORD 25 documenting proof of Liability Insurance, Worker's Comp Insurance and Builder's Risk Insurance." That is one bank's practice, not a rule. If the lender's letter asks for evidence of property insurance, send a 27 or 28.

Sources: 8, 9, 12, 22

How do I give a construction lender proof of builder's risk insurance?

Bind the builder's risk policy with the lender already named on it, then have the agent issue the evidence form the lender asked for. The order matters. Construction lenders check dates as well as names. Capital City Bank's internal staff guide has its loan administrators confirm that "the effective date of the policy precedes the date of the commencement and funding," and Mercantile Bank's residential construction loan guide tells home borrowers builder's risk "must be in place before the first draw."

The lender's role on the policy is the other half. The same staff guide calls for the bank to be named as mortgagee and explains why: a mortgagee gets rights a loss payee does not, including "the right to advance notice of any cancellation or non-renewal" and "the right to pay the premium and prevent a lapse in coverage." Its own list of what the evidence must show is short: the property address, amount of coverage, contractor's name, the bank as mortgagee, and the policy and expiration dates.

Some lenders treat the evidence form as a stopgap. WHEDA accepts ACORD 27 as temporary evidence at a construction closing and asks for a copy of the policy each year until construction is complete, and Capital City Bank's guide has staff review the builder's risk coverage form alongside the ACORD. Fannie Mae's multifamily guide, written for loans sold to Fannie rather than for construction loans, wants permanent evidence within 90 days after Mortgage Loan Delivery and does not accept certificates of insurance or binders as permanent evidence. Ask the lender whether it wants the policy itself, and request the policy forms list when you bind.

  • The lender's exact mortgagee clause, copied from its letter, including any ISAOA/ATIMA wording and the servicing address
  • The property address as it appears on the loan, and the amount of insurance the lender requires
  • Who buys the policy, owner or builder, as the construction contract states, and who is named insured
  • The closing date or first-draw date, so the policy's effective date is on or before it

Sources: 20, 23, 21, 19, 15, 16, 13, 14

Frequently asked questions

Is an ACORD 28 the same as a binder?

No. A binder (ACORD 75 in the ACORD series) is temporary coverage before the policy issues. An ACORD 28 reports a policy. Fannie Mae's multifamily guide lists both among its temporary evidence forms at closing, and says binders and certificates of insurance are not acceptable permanent evidence.

Does the lender need to be an additional insured on the property policy?

Not always. Both ACORD forms offer mortgagee and lender's loss payable boxes, and Capital City Bank's staff guide calls for the standard mortgagee clause naming the bank. WHEDA, by contrast, asks for the lender as an additional insured. Copy the role from the lender's written requirement.

Can one ACORD 28 cover two insurers?

No. The form says that if multiple companies share the risk, a separate form is completed for each.

Sources

Where these answers come from

Each entry carries the exact words of the source so you can check it yourself. Forms and statutes change; read the current version before acting.

  1. 1. ACORD 27 (2016/03), Evidence of Property Insurance, blank form hosted by NYC Department of Design and Construction
    “THIS EVIDENCE OF PROPERTY INSURANCE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE ADDITIONAL INTEREST NAMED BELOW.”
    nyc.gov, accessed October 3, 2026. Edition printed on the form: ACORD 27 (2016/03). Field names on this page (coverage / perils / forms grid; mortgagee, lender's loss payable, loss payee, additional insured boxes) are from the same PDF.
  2. 2. ACORD 27 (2016/03), header disclaimer, second part
    “THIS EVIDENCE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE ADDITIONAL INTEREST.”
    nyc.gov, accessed October 3, 2026
  3. 3. ACORD 28 (2014/01), Evidence of Commercial Property Insurance, blank form hosted by NYC Department of Design and Construction
    “THIS EVIDENCE OF COMMERCIAL PROPERTY INSURANCE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE ADDITIONAL INTEREST NAMED BELOW.”
    nyc.gov, accessed October 3, 2026. Edition printed on the form: ACORD 28 (2014/01). The yes-no coverage lines listed on this page are from this edition; a later edition may differ.
  4. 4. ACORD 28 (2014/01), insurer block
    “IF MULTIPLE COMPANIES, COMPLETE SEPARATE FORM FOR EACH”
    nyc.gov, accessed October 3, 2026
  5. 5. ACORD 28 (2014/01), coverage information lines
    “PERMISSION TO WAIVE SUBROGATION IN FAVOR OF MORTGAGE HOLDER PRIOR TO LOSS”
    nyc.gov, accessed October 3, 2026
  6. 6. ACORD 28 (2014/01), statement above the coverage section
    “THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.”
    nyc.gov, accessed October 3, 2026
  7. 7. ACORD 28 (2014/01), cancellation box (ACORD 27 prints the same text)
    “SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.”
    nyc.gov, accessed October 3, 2026
  8. 8. ACORD 25 (2016/03), Certificate of Liability Insurance, blank form hosted by the New York Department of Financial Services
    “THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER.”
    dfs.ny.gov, accessed October 3, 2026. Coverage lines on the form: commercial general liability, automobile liability, umbrella liability, workers compensation and employers' liability, plus one blank row.
  9. 9. ACORD 25 (2016/03), the additional insured and waiver notice
    “IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.”
    dfs.ny.gov, accessed October 3, 2026
  10. 10. Utah Code 31A-22-1702, Definitions (Property and Casualty Certificate of Insurance Act)
    “"Certificate of insurance" means a document that is prepared for or issued to a person who is not a policyholder as evidence of insurance, regardless of how it is titled or described.”
    le.utah.gov, accessed October 3, 2026
  11. 11. Utah Code 31A-22-1704, Scope of certificate of insurance
    “A certificate of insurance is not an insurance policy and does not affirmatively or negatively amend, extend, or alter the coverage afforded by an insurance policy to which a certificate of insurance refers.”
    le.utah.gov, accessed October 3, 2026
  12. 12. Fannie Mae Multifamily Selling and Servicing Guide, 501.01H Evidence of Insurance (effective 2026-09-28), acceptable temporary evidence
    “ACORD 28 Evidence of Commercial Property Insurance (most recent version or, if applicable, the state-approved form), combined with ACORD 25 Certificate of Liability Insurance.”
    mfguide.fanniemae.com, accessed October 3, 2026. The same list includes ACORD 75 Insurance Binder. ACORD 27 is not named in this section.
  13. 13. Fannie Mae Multifamily Selling and Servicing Guide, 501.01H Evidence of Insurance, requirements
    “temporary or permanent evidence of insurance when the Mortgage Loan closes; and permanent evidence of insurance within 90 days after Mortgage Loan Delivery.”
    mfguide.fanniemae.com, accessed October 3, 2026
  14. 14. Fannie Mae Multifamily Selling and Servicing Guide, 501.01H Evidence of Insurance, permanent evidence
    “The following are not acceptable forms of permanent evidence: insurance policy declarations pages (except for an NFIP policy); single policy endorsement; insurance binders; and certificates of insurance.”
    mfguide.fanniemae.com, accessed October 3, 2026
  15. 15. WHEDA, Insurance Specifications for Developments in the Course of Construction, General Requirements 1
    “ACCORD 27, 25S or 75S are acceptable forms of temporary evidence for property/liability insurance.”
    wheda.com, accessed October 3, 2026. "ACCORD" is WHEDA's spelling.
  16. 16. WHEDA, Insurance Specifications for Developments in the Course of Construction, General Requirements 1 (annual policy copy)
    “Borrower will provide Lender with such evidence and a copy of the policy on an annual basis for as long as Lender has a construction mortgage on the Borrower’s property and the construction has not been completed.”
    wheda.com, accessed October 3, 2026
  17. 17. WHEDA, Insurance Specifications for Developments in the Course of Construction, what the evidence must include
    “The Certificate of Liability Insurance and Evidence of Property Insurance shall include the dates of coverage, dollar amount, property(s) covered, name of the issuing insurance company, policy number, name of the agent who procured the insurance for the mortgagor and Lender as an additional insured.”
    wheda.com, accessed October 3, 2026
  18. 18. Capital City Bank, Lender's Guide to Builder's Risk Insurance (staff how-to, helpjuice knowledge base)
    “Details of the coverages are listed in the Association for Cooperative Operations Research & Development (ACORD) 27 or 28 (Schedule A) which is a document issued by an insurance company or broker to provide proof of property insurance coverage.”
    sandbox-ccbg.helpjuice.com, accessed October 3, 2026. One bank's internal staff procedure, found on a Helpjuice sandbox tenant (sandbox-ccbg) not linked from ccbg.com; it cannot be shown to be the bank's current published policy. Cited only as one bank's internal guide.
  19. 19. Capital City Bank, Lender's Guide to Builder's Risk Insurance, what the ACORD must include
    “The ACORD must include: The property address Amount of coverage Contractors name Capital City Bank (CCB) listed as mortgagee Policy date Expiration date”
    sandbox-ccbg.helpjuice.com, accessed October 3, 2026. A bulleted list on the page; quoted as its text extracts, without list punctuation.
  20. 20. Capital City Bank, Lender's Guide to Builder's Risk Insurance, construction loan administration review
    “reviews both the insurance ACORD and the detailed builder's risk coverage form to confirm that adequate insurance coverage has been obtained and the effective date of the policy precedes the date of the commencement and funding for any improvements.”
    sandbox-ccbg.helpjuice.com, accessed October 3, 2026
  21. 21. Capital City Bank, Lender's Guide to Builder's Risk Insurance, mortgagee versus loss payee
    “There are valuable rights afforded to the mortgagee that are not available to a loss payee, including: The right to advance notice of any cancellation or non-renewal The right to pay the premium and prevent a lapse in coverage”
    sandbox-ccbg.helpjuice.com, accessed October 3, 2026. A bulleted list on the page; quoted as its text extracts.
  22. 22. Capital City Bank, Lender's Guide to Builder's Risk Insurance, ACORD examples
    “Below is an example of an ACORD 25 documenting proof of Liability Insurance, Worker's Comp Insurance and Builder's Risk Insurance Schedule A.”
    sandbox-ccbg.helpjuice.com, accessed October 3, 2026
  23. 23. Mercantile Bank, residential construction loan guide for home borrowers, FAQ on builder's risk insurance
    “Protects your project during construction against risks like fire, theft, or vandalism. Must be in place before the first draw.”
    mercbank.com, accessed October 3, 2026. A consumer guide for home construction loans; it does not mention ACORD forms or commercial loans.
The same moment

A construction lender wants evidence of property insurance before a draw

ACORD 27 and 28, builder's risk, and the loss payee and mortgagee wording lenders check.

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Text or email Redoubt the lender's insurance requirement, the mortgagee clause and the closing or first-draw date. We will tell you which evidence form it calls for and what the policy has to carry before the form can be issued.

This is general insurance information, not legal advice or a coverage determination. The policy forms, the endorsements the carrier issues, and the holder’s written requirement control.

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