March 3, 2021

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Functional Replacement Cost – When Will You Encounter It and What To Be On the Lookout For

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In unique situations, actual cash value (“ACV”) or replacement cost (“RC”) coverage may not be the best match to meet a property owner’s needs, or even be available. Policies that provide functional replacement cost (“FRC”) valuation, or endorsements that do so, offer an alternative. This valuation method is most commonly used to insure older structures built with obsolete materials and by outdated or custom methods; structures where the RC often exceeds the market value. One ISO endorsement defines FRC as:

‘Functional replacement cost’ means the amount which it would cost to repair or replace the damaged building with less costly common construction materials and methods which are functionally equivalent to obsolete, antique or custom construction materials and methods used in the original construction of the building.1

Common examples of “obsolete, antique or custom construction materials” that are replaced with functional equivalents include (1) plaster with drywall; (2) clay roofing tiles with shingles; and (3) the elimination of custom woodwork and masonry.

Although premium payments under an FRC endorsed policy may be more affordable compared to an RC policy, prudent policyholders who select this option will fully understand its implications – following a covered loss, a policyholder will usually be entitled to less insurance proceeds than under an RC policy, and potentially less than under an ACV policy.

Sample Xactimate® pricing is demonstrative:

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For a damaged structure that had plaster walls, a policy that pays out under FRC may only entitle the insured to $2.38/sqft to replace those same walls with ½” drywall. Under an RC or ACV policy, plaster walls are written to be replaced by a modern-day equivalent, such as acoustic plaster over ½” gypsum core blueboard at $8.47/sqft (unsurprisingly, it would be hard to find new horsehair plaster today!). Even if the plaster equivalent is depreciated by 70 percent under an RC or ACV policy, the insured is still entitled to the actual cash value of $2.54/sqft; more than is owed under the FRC valuation (with recoverable funds still available under an RC policy).

Alternatively, and ideally, FRC may properly address a gap between RC and ACV coverage:

It addresses situations when replacement cost valuation would be unnecessary in the event of a total loss, but an actual cash value settlement would not meet the insured’s needs in the event of a partial loss.2

Forms and Endorsements

The ISO HO 00 08 – Modified Coverage Form — has FRC as a default for homeowners’ real property valuation. FRC can also be added to a homeowners policy by endorsement. The ISO Functional Replacement Cost Loss Settlement endorsement, HO 05 30, is:

[O]ne of two endorsements designed to insure an older home whose architectural style has become obsolete or simply unnecessary to the insured’s current use of the house.3

This endorsement replaces the homeowners loss settlement provisions that apply to the primary dwelling and other structures and states:

a. If, at the time of loss, the amount of insurance in this policy on the damaged building is 80% or more of the “functional replacement cost” of the building immediately before the loss4 and you contract for repair or replacement of the damaged building for the same use, within 180 days of the damage unless we and you otherwise agree, we will pay the lesser of the following amounts:5

1. The limit of liability under this policy that applies to the building; or

2. The necessary amount actually spent to repair or replace the damaged building on a “functional replacement cost” basis.

b. If you do not [contract for repair within 180 days] we will pay the least of the following amounts:

1. The limit of liability under this policy that applies to the building;

2. The actual cash value of the damaged part of the building; or

3. The amount which it would cost to repair or replace the damaged building on a “functional replacement cost” basis.

The commercial property equivalent is ISO’s Functional Building Valuation endorsement, CP 04 38. Unlike the homeowners FRC endorsement, the commercial FRC endorsement includes a schedule. The FRC of the property is determined in advance, including anticipated costs to abide by applicable ordinance and law, and eliminates the need for a coinsurance clause.

In the event of a partial loss, the endorsement provides for:

The cost to repair or replace the damaged portion of the building with less costly material, if available, in the architectural style that existed before the loss or damage occurred[.]6

Determining what constitutes a “functional” replacement is not always an easy task. Be aware that there are many non-ISO FRC forms that deviate from the provisions cited in this blog, especially in commercial lines. Be sure to read your policy and speak with an insurance professional if you are unsure about how an FRC provision will be applied.
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1 ISO HO 05 30 05 11
2ISO Commercial Property Forms and Endorsements: Functional Building Valuation (CP 04 38). IRMI. Available at
https://www.irmi.com/online/cpi/ch006/1l06f000/al006710.aspx (subscription required).
3Functional Replacement Cost Loss Settlement HO 05 30. IRMI. Available at https://www.irmi.com/online/prmi/ch013/1l13f000/al003730.aspx (subscription required).
4 This acts as a coinsurance clause equivalent with a proportional payout.
5 ISO HO 05 31 grants ACV payment if FRC is less than the ACV.
6 ISO CP 04 38 09 17

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