Claims Investigation Checklist
Steps a claims adjuster runs from FNOL through coverage decision on a first-party property or liability claim. Covers intake, evidence gathering, fraud screening, and documented decision rationale.
FNOL Intake and Assignment
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Log the FNOL in the claims system
Open the claim in ClaimCenter (or your PAS), assign a claim number, and capture loss date, loss location, reported-by party, and reported cause of loss. The reported cause drives the coverage path — get it from the reporter's words, not the adjuster's interpretation.
Collects text Collects date Collects list -
Send the statutory acknowledgment letter
Acknowledgment windows vary by state. Texas Insurance Code Chapter 542 requires acknowledgment within 15 business days of FNOL on a first-party claim; missing it triggers 18% statutory interest plus attorney's fees. Use the state-specific letter template from the compliance library.
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Verify policy is in force on the loss date
Pull the dec page for the policy period covering the loss date. Watch for mid-term cancellations, lapses for non-payment, and reinstatements with gaps. For claims-made policies, verify the retroactive date precedes the alleged act.
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Run OFAC screening on claimant and payees
Screen claimant, named insured, and any known assignees (body shops, contractors, medical providers) against the OFAC SDN list. Re-screen at payment — parties can be added mid-claim. Document the screening result in the file.
Coverage Analysis
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Read the policy form against the reported facts
Read the insuring agreement, exclusions, and endorsements as filed — do not rely on AMS-summarized coverage. Note any anti-concurrent-causation language for property claims and any prior-acts or retro-date conditions for claims-made forms.
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Identify coverage issues requiring an ROR
Flag exclusions, late-notice issues, prior-knowledge concerns, or coverage trigger ambiguity. A reservation of rights protects the carrier's ability to deny later while it investigates, and most states require it be specific to the issue — boilerplate ROR language has been rejected by courts.
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Issue the reservation of rights letter
Cite the specific policy provisions in question and the facts under investigation. Send via tracked delivery and calendar a follow-up within 30 days to either lift the ROR or proceed to a coverage position letter.
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Set the initial reserve
Set indemnity and ALAE reserves based on reported severity and the carrier's reserving philosophy. Calendar the next reserve review per the carrier's cadence (commonly 30/60/90 days). Placeholder reserves left unrevised are a market-conduct exam finding.
Collects number Collects number
Investigation and Evidence
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Take the recorded statement
Disclose recording at the start — some states are two-party consent, and undisclosed recording makes the statement inadmissible and supports a bad-faith allegation. Cover loss chronology, prior similar losses, and any third parties involved.
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Order police, fire, or incident reports
Request the official report from the responding agency. Many jurisdictions take 7-21 days to release; calendar a follow-up. The narrative section often contradicts FNOL details and reframes the investigation.
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Collect scene photos and damage estimatesCollects file Collects number
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Pull the CLUE and prior loss history
Run a LexisNexis CLUE report on the insured and, for auto, the involved drivers and vehicles. Frequency patterns (multiple soft-tissue claims, repeat water damage at the same dwelling) are leading SIU referral indicators.
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Assess SIU referral indicators
Score the file against the carrier's fraud-indicator checklist: late reporting, recent policy inception, prior similar losses, claimant pressure for fast settlement, missing documentation. Two or more indicators typically trigger SIU referral under the carrier's anti-fraud plan.
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Open the SIU referral
Submit the referral packet with indicator scoring, recorded statement, CLUE, and any inconsistent documentation. SIU may request an EUO; coordinate scheduling and counsel through the SIU lead, not the line adjuster.
Decision and Communication
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Reconcile evidence against coverage
Build the coverage analysis memo: facts, applicable provisions, exclusions considered, and how the evidence maps to each. This memo is the file's defense in any later bad-faith or market-conduct review.
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Evaluate subrogation potential
If a third party caused or contributed to the loss, put them on notice within the state's statutory window — often 6 months. Missing the notice waives recovery and shows up as a finding at the next market-conduct exam.
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Document the claim decision
Record the decision, settlement amount or denial basis, reviewer notes, and approval signature in the file. For Texas first-party claims, decision must be communicated within 15 business days of receipt of all requested information per Chapter 542.
Collects list Collects paragraph Collects signature -
Notify excess carriers if reserve crosses 50%
Most excess policies require notice of any matter reasonably likely to involve the excess layer; carriers commonly use 50% of the primary as the practical trigger. Late notice is a coverage-condition violation that excess markets do enforce.
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Send the coverage position letter to the insured
For denials and partial denials, cite the specific policy language and include the state-required appeal-rights notice. Use tracked delivery. For payments, attach the release form and confirm payee matches the OFAC re-screen.
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