ACORD 28 is the evidence of commercial property insurance form, issued by an agent or broker to document property coverage on commercial real estate or business personal property for a lender or other party with a financial interest in it. It exists because commercial lenders need detail a liability certificate cannot supply, including the building limit on their specific collateral, the valuation basis, the deductible, and their own status as mortgagee or lender's loss payable. When a commercial mortgage closes or a loan servicer runs its annual insurance review, this is the form their checklist names.
If you have been asked for "an ACORD 28" and sent back "an ACORD 25," you have discovered the difference the hard way. For personal lines and smaller commercial placements, the shorter ACORD 27 plays the same role. This page explains what the form documents, why lenders insist on it, and how the mortgagee and loss payee interests behind it actually work.
What does ACORD 28 do?
ACORD 28 documents, for one commercial property interest holder, the property insurance in force on described real or personal property. The agent completes it with the named insured, carrier, policy number and term, the location of the collateral, the coverage amount, the perils basis, the deductible, and coverage features the loan documents care about, such as whether business income coverage applies.
It then records the requesting party's interest, most often mortgagee for a lender secured by the building or lender's loss payable for a lender secured by business personal property.
Loan servicers keep the current evidence in the loan file and request a fresh one at each policy renewal, a process large servicers automate through insurance tracking vendors. The form is the standardized answer to a standardized demand, which is exactly why lenders specify it by number in their closing instructions.
Why do lenders demand ACORD 28 instead of ACORD 25?
Because ACORD 25 answers a different question. The 25 is a certificate of liability insurance, it summarizes casualty coverages and states on its face that it is informational only and confers no rights on the holder.
A construction lender vetting a contractor cares about that liability summary. A mortgage lender does not, because its exposure is the building burning down, not the borrower being sued. The lender needs to see property coverage on its specific collateral, in an amount that protects the loan, with itself named in a policy provision that pays it directly after a loss. The comparison is stark when set side by side:
| Question the lender asks | ACORD 25 | ACORD 28 |
|---|---|---|
| Is my collateral property insured, and for how much? | Not addressed | Core content |
| Am I named as mortgagee or lender's loss payable? | No interest detail | Interest section |
| What is the deductible and valuation basis on the building? | Not shown | Shown |
| Does the document relate to a described location? | Program-wide summary | Location-specific |
There is also a rights dimension. Certificates disclaim everything. An evidence form corresponds to the mortgageholders provision in the commercial property policy, a provision that pays the lender on covered building losses and preserves the lender's recovery even when the named insured's own claim fails for reasons like concealment or a vacancy breach. The lender's lawyers wrote the loan covenants around that provision. The ACORD 28 is how the agent evidences compliance with those covenants.
What is the difference between a mortgagee and a loss payee?
The labels describe different policy mechanics, and lenders are particular about which one appears. A mortgagee is a lender secured by real property, and the standard commercial property policy's mortgageholders provision gives it strong independent rights, including payment on covered building losses, notice before the insurer cancels, and continued protection despite certain acts of the named insured.
A loss payee is simply added to loss payments on described personal property, and in the plain version its recovery rises and falls with the insured's. Lender's loss payable is the middle path for lenders secured by business personal property, granting the secured creditor protections closer to a mortgagee's.
Brokers pull the exact required wording from the loan agreement rather than guessing, because a servicer that finds "loss payee" where its covenant says "lender's loss payable" will kick the evidence back. The form also carries the lender's precise name and address, down to the "its successors and assigns" tail loan documents specify, since claim checks and cancellation notices follow that exact wording.
Where can you see the actual form?
Menlo does not reproduce ACORD forms because they are copyrighted by ACORD Corporation. Licensed agencies and carriers access current editions through acord.org and issue completed evidence forms from their agency management systems. Lenders and servicers receive completed forms from the borrower's agent or broker, and the underlying mortgageholders or loss payable wording can be verified by requesting the relevant policy provisions through that same representative.
Frequently asked questions
What is the difference between ACORD 27 and ACORD 28?
Both evidence property insurance for an interest holder. ACORD 27 is the shorter form used for personal lines and small commercial placements, while ACORD 28 is built for commercial property and carries the coverage detail institutional lenders require. Commercial loan documents almost always name the 28.
Can a lender rely on an ACORD 28 as proof of coverage?
It is reliable evidence that the described coverage was in force when issued, but it is not the source of the lender's rights. Careful servicers confirm the mortgageholders or lender's loss payable provision actually names them on the policy and request updated evidence at every renewal.
Why did my lender reject an ACORD 25 certificate?
Because the 25 covers liability insurance and confers no rights on the holder. It says nothing about the building limit, the deductible, or the lender's mortgagee interest, which are the things a property-secured lender must verify. Ask your broker for an ACORD 28 naming the lender exactly as the loan documents require.
Who fills out the ACORD 28?
The insured's agent or broker completes and signs it, using policy data from the agency management system. Borrowers do not prepare their own evidence forms, and lenders will not accept one that lacks a producer's authorization.
This guide is for educational purposes and describes standard evidence of insurance practice in Menlo's own words. Form numbers and titles are cited for identification only, and Menlo Insurance Services is not affiliated with ACORD Corporation. Your policy's specific terms, conditions, and endorsements control. Talk to a licensed broker about your actual exposures.