Public adjuster
Department of Insurance Complaint Template & Example
Last updated 2026-08-14
A complaint to a Department of Insurance is not a lawsuit and does not order anyone to pay. What it does is put a claim in front of the regulator that supervises the carrier, require a written response within the regulator's timeframe, and produce a record that feeds market conduct data.
Two facts shape how one should be written. There is no national complaint body — the NAIC does not operate a portal and routes consumers to their own state's department, so 'file with the NAIC' is wrong advice. And the data that matters is closed CONFIRMED complaints: the NAIC publishes them by reason, by coverage type and by disposition, and computes a complaint index from a company's complaints per million dollars of premium against the industry median, where 1.0 is the median.
That second point is the practical one. A complaint closed as unconfirmed consumed everyone's time and moved nothing. A complaint framed against a specific handling standard, with dates and documents attached, is far more likely to close confirmed — which is what makes it worth filing at all.
Jurisdiction
Written primarily against US first-party property practice. Claim handling is regulated state by state — acknowledgment and response deadlines, prompt-payment requirements, adjuster licensing and unfair claims practices standards all differ — and the policy actually issued governs the claim. Where a page cites a statute, model act or regulation, confirm what applies in the state where the loss occurred. Outside the US, treat the structure as transferable and the legal references as not.
Department of Insurance Complaint template
Free Word download, no email required. Or open it in Professional Drafter — it lands in your template library, ready to draft against.
When to use this document
- A specific claim-handling obligation has been missed and correspondence has not fixed it — no acknowledgement, no status updates, no decision within the applicable period.
- The carrier will not put its position in writing, which is itself often the complaint.
- Not as a negotiating tactic on an amount dispute. Amount disputes go to appraisal; regulators do not adjudicate the value of a loss.
Worked example
Fictional scenario: a complaint on a different matter from Harbour Lane — a hail claim where the carrier went eleven weeks without a decision after a sworn proof of loss and stopped responding. Filed 14 September 2026. This example is not from the Okonjo file, where the carrier's handling gave no grounds for one.
The right department, and the parties
Filed with: the Department of Insurance for the state in which the policy was issued and the loss occurred, through its online consumer complaint form. The department's intake requires its own form; an earlier draft prepared as a letter was not sent, because a narrative letter into a form-based intake gets re-keyed at best.
There is no national alternative. The NAIC does not operate a complaint portal and routes consumers to their own state department, so a complaint 'to the NAIC' does not exist as a thing that can be filed.
Carrier: [Carrier] Property and Casualty Insurance Company — the legal entity named on the declarations page, not the group brand under which the policy was sold. The complaint index is computed per licensed entity, so naming the brand can attach the record to the wrong company or to none.
- Policy:
- HO-2210548. Claim: PC-2026-10993.
- Loss:
- hail and wind, 12 May 2026, [address].
- Complainant:
- M. Adeyemi, insured. Filed by T. Halvorsen, public adjuster licence PA-118427, with the insured's signed authorisation attached as exhibit 1.
- Reference assigned by the department on filing:
- [ref].
The allegation, tied to a standard
Allegation: the carrier has failed to accept or deny the claim, or to communicate the reasons for the continuing delay, in the period following receipt of a sworn proof of loss.
Specifically: a sworn proof of loss was furnished on 26 June 2026 and acknowledged by the carrier on 30 June 2026. As at the date of this complaint, 14 September 2026 — eleven weeks later — the insured has received no acceptance, no denial, and no written statement of the reasons for the delay or of what further information is required.
Obligation engaged: the state's adopted claim-handling regulation requires an insurer to accept or deny a claim within a stated period following receipt of a proof of loss, and where a decision is not reached within that period, to notify the insured in writing of the reasons for the delay and of the additional information required, repeating that notification at stated intervals. Cited here to the state's own provision at [state citation], not to the NAIC model, which binds nobody.
That framing is deliberate. 'The carrier has been unresponsive and unprofessional' is a service grievance and closes unconfirmed. 'No decision and no delay notice in eleven weeks after an acknowledged proof of loss, contrary to [provision]' is a checkable allegation against a standard, and an analyst can confirm or reject it from the documents attached.
Chronology
Date | What happened | Source
12 May 2026 | Date of loss — hail and wind | NOAA storm report, exhibit 2
14 May 2026 | Claim reported by telephone | Carrier acknowledgement email, exhibit 3
21 May 2026 | Carrier inspection by staff adjuster | Inspection confirmation, exhibit 4
2 Jun 2026 | Carrier requested contractor documentation | Carrier email, exhibit 5
9 Jun 2026 | Insured supplied contractor scope and photographs | Insured email with delivery receipt, exhibit 6
26 Jun 2026 | Sworn proof of loss furnished | Signed and notarised POL, exhibit 7
30 Jun 2026 | Carrier acknowledged receipt of proof of loss | Carrier email, exhibit 8
17 Jul 2026 | Insured requested status | Insured email, exhibit 9
4 Aug 2026 | Insured requested status again | Insured email, exhibit 10
11 Aug 2026 | Carrier called insured; said file was 'with review' | Insured's contemporaneous note, exhibit 11
26 Aug 2026 | Public adjuster wrote requesting written position within 10 days | Letter with proof of delivery, exhibit 12
14 Sep 2026 | No response received. Complaint filed | —
Two entries favour the carrier and are included: the 21 May inspection was prompt, nine days from report, and the 2 June documentation request was reasonable and answered within a week. A chronology that omits them invites a response that supplies them and reframes the whole complaint as one-sided.
The 11 August call is recorded as a contemporaneous note rather than as a carrier record, and labelled as such, because it is the insured's account of a call the carrier has not confirmed.
Documents attached, and resolution sought
Exhibits 1-12 as referenced above, plus:
13. Declarations page showing the carrier's legal entity name and coverage in force on 12 May 2026.
14. The carrier's estimate of 28 May 2026.
15. The insured's contractor scope of 8 June 2026.
Exhibits 7 and 8 are the two that decide this complaint: the proof of loss and the carrier's own written acknowledgement of receiving it. Everything else is context. An analyst can establish the start date and the elapsed period from those two documents without relying on either party's characterisation, which is what makes the allegation confirmable.
Resolution sought:
1. A written position on the claim — acceptance, denial, or a statement of the reasons for the continuing delay and the additional information required.
2. If the delay continues, notification at the intervals the regulation requires.
NOT sought, stated expressly:
— A determination of the amount of the loss. The parties have not reached the point of disputing the amount, and if they do, the policy's appraisal provision is the route. The department is not being asked to value the claim.
— Damages, interest, or any award. The insured understands this process does not produce one.
That paragraph exists because complaints asking a regulator to make a carrier pay a figure receive a reply explaining what the department does not do, and close there. Asking for the written position — which is the thing that has actually been withheld — asks for something the department can require.
Section-by-section guide
What each section is for, what a good one contains, and where they typically go wrong.
1.The right department, and the right route
File with the department that regulates the carrier in the state where the policy was issued or the loss occurred. Every US state, the District of Columbia and the five territories have one, and each runs its own intake. There is no central portal, and a complaint filed in the wrong state gets forwarded at best. Check whether the department requires its own form — many do — because a narrative email into a form-based intake sits unrouted.
2.Parties, policy and claim
The carrier's full legal entity name, not the brand — groups write through multiple licensed entities and the complaint index is computed per entity. Take the name from the declarations page. Then the policy number, the claim number, the loss date and location, and who is complaining: the insured, or a public adjuster on their behalf with authority evidenced.
3.The allegation, tied to a standard
State what the carrier did or failed to do, and tie it to the obligation it engages: an acknowledgement period, a requirement to communicate the reasons for delay, a period to accept or deny after proof of loss, a requirement to pay within a period of affirming liability. Cite the state's adopted provision, not a model. This is what separates a complaint that closes confirmed from one that closes as a service grievance.
4.Chronology
Dated entries only, each with the document or call it rests on. No characterisation. The chronology is what an analyst reads first, and a clean one lets them see the gap without being told it is unreasonable. Include the carrier's side fairly — a chronology that omits the carrier's two attempts to reach the insured invites the response that supplies them.
5.Documents attached
Attach what the analyst needs to verify the chronology without asking: the declarations page, the correspondence relied on, the proof of loss and its acknowledgement, the estimates, and any written coverage position. Number them and reference the numbers in the chronology. A complaint that asserts a letter went unanswered and does not attach the letter puts the analyst in the position of taking one side's word.
6.Resolution sought, and what is not being asked
Ask for something the regulator can actually produce: a written position on the claim, compliance with a period, a response to correspondence. Say expressly what is not being asked — the department is not being asked to determine the amount of the loss, which is what appraisal is for, nor to award damages. A complaint that asks the regulator to make the carrier pay a number invites a reply explaining what the department does not do, and closes there.
Common mistakes
The failure modes that show up most often when this document is reviewed later.
Filing 'with the NAIC'
There is no national complaint body. The NAIC routes consumers to their own state department and publishes aggregate data; it does not take complaints. Time spent on this route is entirely lost.
Naming the group brand instead of the licensed entity
Complaint data is compiled per licensed entity, and groups write through several. Take the name from the declarations page or the record attaches to the wrong company.
Alleging poor service rather than a breach of a standard
'Unresponsive and unprofessional' closes unconfirmed and moves nothing. A missed period tied to the state's adopted provision, evidenced by dates, is what closes confirmed — and confirmed is the only disposition that registers anywhere.
Citing the NAIC model regulation as the obligation
The models bind nobody. The obligation is whatever the state adopted, and a complaint citing a model rather than the enacted provision is asking the analyst to do the work of finding the real one.
Omitting the facts that favour the carrier
The carrier gets to respond, and it will supply them. A chronology that already contains them reads as an account; one that does not reads as advocacy, and the difference affects how the rest is weighed.
Asking the department to determine the amount of the loss
Regulators supervise conduct; they do not value claims. That request triggers a reply about the limits of the process and closes the file with nothing achieved. Amount disputes belong in appraisal.
Questions
- Will a complaint make the carrier pay?
- Not directly. It requires a response to the regulator within their timeframe and creates a record. In practice the most common outcome is that a stalled file receives the written position that was being withheld, which is often the thing that was actually needed.
- Does a complaint hurt the insured's claim?
- Retaliation for filing would itself be a regulatory matter. The more realistic risk is a file that becomes formal in tone, which is a reason to file when a standard has genuinely been missed rather than as pressure on a negotiation.
- What does 'closed confirmed' mean?
- It is the disposition where the regulator found the complaint substantiated. The NAIC publishes closed confirmed complaints by reason, by coverage type and by disposition, and builds its complaint index from complaints per million dollars of premium against the industry median, with 1.0 as the median. A complaint closed unconfirmed does not move that number.
- Can a public adjuster file on the insured's behalf?
- Generally yes, with the insured's written authorisation attached, and departments will usually want to see it. The complaint remains the insured's. Check the department's own intake rules, which vary on who may file and what authority is required.
The blank template
Exactly what is in the Word download, so you can see the structure before deciding whether you want it.
The right department, and the right route
Parties, policy and claim
The allegation, tied to a standard
Chronology
- [Date | What happened | Source]
Documents attached
Resolution sought, and what is not being asked
Download this template
Free Word download, no email required. Or open it in Professional Drafter — it lands in your template library, ready to draft against.
Sources
- NAIC — Consumer Information Source and consumer complaint resources
- NAIC — Unfair Property/Casualty Claims Settlement Practices Model Regulation (Model 902, 1991 amendment, July 1997 print)
- NAIC — Market Regulation Handbook: Examination Standards Summary, 2025 Edition
- NAIC — Public Adjuster Licensing Model Act (Model 228) §19, Standards of Conduct
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This page is a documentation aid, not legal advice and not a coverage opinion. Claim-handling requirements vary by state and by policy wording, and a template cannot tell you what your file requires. The worked example describes a fictional loss.