Category Archives: government relations

New Rhode Island Tenant Insurance Law

Rhode Island’s new tenant insurance law took effect on January 1, 2023. This new law allows Rhode Island self storage operators to sell tenant insurance without obtaining a license, given a set of requirements are followed, including:

  • Training of the employees involved with the sale of insurance by the facility’s insurer,
  • Employees cannot represent themselves as licensed insurance producers,
  • Separate itemization or clear communication to the tenant about the charges,
  • Insurance may be provided under a commercial, corporate, group, or master policy
  • In print or electronic writing, the operator must summarize the terms of the policy, including:
    • The identity of the insurer,
    • The identity of the supervising entity,
    • The amount of the deductible and how it can be paid,
    • Benefits of coverage,
    • Key terms and conditions of coverage,
    • The process for filing a claim, and
    • A statement that the tenant can cancel their insurance coverage at any time.

Of course, the facility must also disclose in writing that the insurance they are selling may already be provided in one of the customer’s existing policies (homeowner’s, renter’s, etc.), and that enrollment in the facility’s insurance program is not required in order to lease a space from their facility. If insurance is required to rent a unit at the facility, the customer must also be given notice that they can opt out of purchasing a policy through the facility if they can provide proof of other applicable insurance.

For more information about the new State of Rhode Island Self-Service Storage Insurance Act, you can read the full, final version of the Bill here. Of course, you can also always reach out to us for any questions!

Connecticut Lien Law Success

Effective July 1, 2022, the Connecticut State Statute regarding the lien process is updating for the better!

As of July 1st, Connecticut facilities can benefit from these updates in the following ways:

  • Default Notices can now be sent by Certified Mail, instead of Certified Mail Return Receipt Requested.
  • If you choose to advertise a sale, you may now do so in any print or online newspaper of substantial general circulation, or you can do so on any publicly accessible independent website that regularly conducts online auctions of personal property. You also only have to advertise one time not less than ten days before the date of sale.
  • Towing of motor vehicles and vessels is now allowed in lieu of selling them when the tenant is delinquent for at least sixty days.

Please note that the above changes have been summarized.

Of course, individual facilities will have to make changes to how they operate in order to benefit from these legislative updates, and NeSSA is here to assist.

Any active member who has maintained their membership and already purchased a standard indoor and/or outdoor vehicle/vessel lease agreement through NeSSA will receive an update of the lease(s) once we receive them from our attorney. If you are an active member and you have never purchased your state lease through NeSSA, you can easily do so online.

We are also updating our Connecticut online resource library to reflect these changes. Some of these resources include a basic lien sale outline, default notices, templates, etc.

Additionally, we are including dedicated educational time for this topic at the September 29th Fall Retreat. Joe Doherty, SSA’s Chief Legal & Legislative Officer, will present on these changes and what they mean for your facility operations.

Finally, if you ever have questions, you can always come to us and ask. NeSSA will find answers for our members in a timely manner.

We are grateful to the Self Storage Association’s Legal & Legislative Counsel for their diligence and work within our state. Amazingly, this whirlwind legislation took only about four months from when this opportunity first arose to when these changes officially went into effect. This allowed for a quick legislative victory, and NeSSA’s Board of Directors was happy to donate $10,000 towards this effort on behalf of our members.

We hope this news excites you as much as it did us! We are committed to providing better standards, practices, and protections in our local self storage communities. This is a great accomplishment for our Connecticut members and shows what can happen when we work together for the betterment of our industry.

You can read through the full revised statute here.

Is Your Business in Compliance with Overtime Regulations?

Is Your Business in Compliance with Overtime Regulations and Federal Employment Reporting Requirements?

First, the federal Department of Labor (DOL) recently proposed an increase to the minimum required salary for employees designated as exempt from overtime pay from $23,660 to $35,308. Although this change is likely about six months away from taking effect, it is advisable for SSA members to review their payroll structure now to plan for any changes that will be necessary when the change goes into effect. When the changes take effect, salaried employees who make less than $35,308 must either receive a salary increase or be converted to an overtime-eligible employee.

Moreover, the current and proposed federal overtime regulations allow for employees to be designated as exempt from overtime pay only if their job duties fall into one of the exemptions. Both small and large operators have been sued based on allegations that their employees were improperly designated as exempt from overtime pay.

Therefore, storage operators are strongly urged to review the OVERTIME MEMO to better understand the exemptions from overtime pay and to determine whether their employees are accurately designated as exempt from overtime pay. If the employee’s job duties do not fall into one of the exemptions, federal law requires that the employer pay the employee overtime for any hours worked in excess of 40 hours per workweek. The memo also discusses the proposed change to the minimum required salary and tips to prepare for the change.

Storage operators must keep in mind that federal law sets minimum requirements for employers. State and local employment laws often impose stricter requirements that employers must meet.

Second, the Equal Employment Opportunity Commission (EEOC) is requiring employers with 100 or more employees to provide additional compensation data by September 30, 2019.

The EEOC has for years required covered employers to submit information regarding employee sex, race, and ethnicity to assist with its enforcement efforts. During the Obama Administration, the EEOC determined that additional information was needed from employers to combat wage discrimination.

As a result, employers will now have to provide pay ranges for employees based on “box one” of W-2 forms and must report hours worked by employees. Information must be provided regarding ethnicity, gender, job category, and sex of each individual employee within the pay ranges.

To learn more, visit the SSA blog.

Daniel Bryant is the SSA’s Legal & Legislative Counsel. He advocates on behalf of the membership at the federal, state, and local level to protect and advance the interests of the industry. He received his law degree from American University, Washington College of Law and his undergraduate degree in political science from Virginia Tech. He is a member of the Virginia and the District of Columbia bars. Prior to joining the SSA, he was an associate attorney with a law firm in Washington, D.C. Daniel can be reached at or at (703) 575-8000 ext. 107.