Connecticut · Insurance Adjuster SampleInteractive Mind Map
Connecticut Adjuster Regulations
A visual breakdown of the Connecticut rules an adjuster is tested on — including the four lines of authority, the twenty-four month fire policy suit clause, the conjunctive thirty-day payment trigger, and the comparative negligence rule that reverses outcomes.
Connecticut’s distinguishing habit is that it keeps its answers somewhere other than where the caption points. There is no single adjuster license: there are four credentials spread across three chapters, and the chapter captioned “Public Adjusters” — ch. 701b — licenses nobody at all. The licensing provision is § 38a-788, in a different chapter. The public adjuster’s 10% fee cap is not in the section captioned “Fees charged”; it is in a regulation. The state’s anti-steering rule is not in the unfair practices act; it is in an appraiser regulation. And fire adjusters and life adjusters need no Connecticut license at all — the exact reverse of what a national course teaches.
Then the claims law. Connecticut never adopted the NAIC claim-handling regulation, so there are no regulatory deadlines to find — and the regulation that governs an adjuster’s conduct, § 38a-792-4, points at implementing regulations that do not exist and fills the gap with a private trade association’s code of ethics. The property payment clock is real, but it is printed inside the standard fire policy the statute prescribes, and its trigger is conjunctive: thirty days after proof of loss and ascertainment of the amount. The 60- and 20-day numbers quoted in fifty-state charts are accident and health only.
Three more reversals decide real files. Comparative negligence measures the plaintiff against the COMBINED fault of all defendants, so a plaintiff who is 40% at fault against two defendants at 30% each recovers here and recovers nothing in a state that compares each defendant individually. Connecticut’s own standard fire policy carries a twenty-four month suit clause where the national form says twelve. And in workers’ compensation the employee selects the physician, with a 28-day accept-or-contest window whose default presumption is conclusive. Watch 1 October 2026: the guaranty fund’s $100 claimant deductible is abolished, unearned premium moves from half to full with the cap rising from $2,000 to $50,000, and new $1,000,000 property and $500,000 cyber limits arrive.
Connecticut does not have “an adjuster license.” It has four credentials in three chapters.
The casualty claims adjuster is § 38a-792. The motor vehicle physical damage appraiser is § 38a-790. The public adjuster is § 38a-788 — which is not in the chapter captioned “Public Adjusters.” And the catastrophe adjuster is a registration that does not exist until the Commissioner declares a storm. All three licenses share one gateway, § 38a-769, and one fee schedule, § 38a-11.
Credential
Created by
Where it lives
Casualty claims adjuster
§ 38a-792
ch. 702, Part VI
MVPD appraiser
§ 38a-790
ch. 702, Part V
Public adjuster
§ 38a-788
ch. 702, Part IV — NOT ch. 701b
Catastrophe adjuster
—
Registration only. No statute identified
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Chapter 701b is captioned “Public Adjusters” and licenses nobody
Chapter 701b contains exactly four operative sections — § 38a-723 (definition), § 38a-724 (employment contract), § 38a-725 (penalty) and § 38a-726 (fees charged) — and then §§ 38a-727 through 38a-730 are all “Reserved for future use.”
⚠ The licensing and examination requirements are in § 38a-788, in a different chapter entirely. This is a real trap rather than a technicality: a chapter named after the credential, containing that credential’s conduct rules, with no licensing provision anywhere in it. Any source answering “what does a Connecticut public adjuster need to get licensed?” out of chapter 701b is answering from a chapter that never addresses the question.
One license, FOUR lines of authority — and one excludes compConnecticut has no separate workers’ compensation adjuster license. It has one casualty adjuster license and four lines: All Lines · All Lines Except Workers’ Compensation · Workers’ Compensation Only · Auto Only. The Department’s own gloss is the tested part: All Lines “includes Workers’ Compensation,” and All Lines Except Workers’ Compensation “does not include Workers’ Compensation but does include Auto.”⚠ So “the casualty adjuster license covers comp” is true for two lines and false for a third — and the licensee holding that third line is fully licensed, not restricted. Say one license, four lines. Not “one exam,” and not “two licenses.”
✅ Five categories that REQUIRE the license — Reg. § 38a-792-1
Personal injury or death from automobile accidents
Liability arising out of premises and operations
Claims under the workers’ compensation law, or covering the master-servant relationship
Property damage, including automobile collision
Personal injury or death from common-law or statutory duty violations not otherwise covered
❌ Who needs NO license at all
⚠ FIRE insurance adjusters. Reg. § 38a-792-2 in full: “No fire insurance adjuster need be licensed. No life insurance adjuster need be licensed.”
LIFE insurance adjusters — same two-sentence regulation
Portable electronics claim staff — collecting or furnishing claim information and data entry, capped at 25 individuals supervised by a licensee
Members of the Connecticut bar in good standing in general practice
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The fire exemption inverts the national rule — and it has an unmarked boundary
In most states the fire and property adjuster is the paradigm case of who must be licensed. In Connecticut the credential is a casualty license, and the Department describes it as reaching claims “other than life, accident and health, and fire.”
⚠ Know the tension rather than memorizing past it. Reg. § 38a-792-2 exempts fire adjusters; its neighbor § 38a-792-1(4) requires a license for “property damage, including automobile collision.” Neither section marks where one ends and the other begins. On an exam, answer from the section the question quotes.
📄 Public adjuster — the only one with prelicensing
§ 38a-788: forty hours, covering property insurance policies and forms, and the timing clause is the tested part — the course must be completed “before being admitted to such examination,” not before application. Pearson enforces it at the test center and applies it to retakes too.
⚠ NO BOND. And the proof is structural: § 38a-795 is captioned “Bond of applicant” in the same chapter — for surplus lines brokers. The legislature knew how and did it once, for someone else. Most states bond public adjusters. Connecticut does not.
⚠ The fee cap is NOT in the fee statute
§ 38a-726 is captioned “Fees charged” and contains no percentage. The 10% cap is in the regulation — Reg. § 38a-788-8: “No public adjuster shall receive compensation in excess of 10% of the actual or final settlement.”
Two opposite errors come out of this: a statute-only search concludes there is no cap, and a source pin-citing “10%” to § 38a-726 attaches a real number to the wrong instrument. Both come from assuming the cap lives in the section named after fees.
The public adjuster contract — and the weekend rule§ 38a-724 requires a written employment contract. Contracts signed after 1 July 2019 must carry a cancellation provision in 12-point boldface on the first page. The insured may cancel by certified mail RRR posted not later than midnight of the FOURTH CALENDAR DAY after signing — ⚠ except that a Friday, Saturday or Sunday signing runs to midnight of the immediately following THURSDAY. A contract omitting the provision is void from inception, and no solicitation between 8:00 p.m. and 8:00 a.m. — a contract from an off-hours solicitation is void. Candidates reliably remember “four days” and miss the weekend shift, which is always LONGER than four days.
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The catastrophe registration does not exist until the Commissioner declares
It is not a license, there is no fee, and the Department is explicit: the Commissioner “must first declare that the storm qualifies for the catastrophe licensing program.”There is no way to pre-register against a future event.
120 days per event, no renewal — the insurer “must register you for each storm separately.”⚠ Eligibility is DISJUNCTIVE: an active adjuster license in another state OR proof of two years’ work as an adjuster. Two years of experience is an independent alternative to holding any license anywhere, and most summaries state only the first branch.
Only an authorized insurer representative may register you — a third-party vendor cannot. Individuals only; public adjusters are excluded; photo ID worn while adjusting. Do not confuse it with the Insurance Claims Adjuster Permit, which is a disaster-area access placard for already-licensed adjusters after a declared disaster.
The appraiser is not a minor credentialIts exam, 12-CT-16, costs $120 — more than the $105 combined P&C producer exam and the most expensive insurance exam the state sells. Its penalty is $2,500 against the casualty adjuster’s $2,000, on otherwise identical wording. Its conduct regulations are the most detailed adjuster-side rules in Connecticut: Reg. §§ 38a-790-1 to -8 cover display of license, agreement on repair price, leaving the appraisal with the shop, competitive estimates and reinspection — and ⚠ § 38a-790-6 forbids requesting a SPECIFIED repair shop. Connecticut’s anti-steering rule is in an appraiser regulation, not in the unfair practices act.
There is no “Connecticut casualty adjuster exam.” There are four, and two of them run one hour.
The passing score is a raw 70% and Connecticut is unusually clean about saying so. Question counts are not published at all. Continuing education is zero hours, and that is provable from the statute rather than taken from an FAQ. And three different renewal conventions run at the same time.
Exam
Time
Fee
Questions
12-CT-09 All Lines Casualty Adjuster
2 hr
$70
Not published
12-CT-10 All Lines Except Workers’ Comp
2 hr
$70
Not published
12-CT-11 Workers’ Compensation Only
1 hr
$70
Not published
12-CT-12 Auto Only
1 hr
$70
Not published
12-CT-08 Public Adjuster
2 hr
$65
Not published
12-CT-16 MVPD Appraiser
1 hr
$120
Not published
✅ The score is answerable — and it is RAW
Pearson’s Connecticut handbook: “The passing score required on the Bail Bonds is 80%. The passing score required on all other examinations is 70%.”
The word “scaled” appears NOWHERE in the Connecticut handbook. Pretest questions are embedded and unidentified, and “responses to them do not affect a candidate’s score” — so the 70% is a straight percentage of the scored items.
When a source tells you a Connecticut adjuster score is “scaled,” it is importing another state’s convention.
⚠ The question count is NOT answerable
The candidate handbook does not state question counts, and Pearson’s published Connecticut content outline covers only the PRODUCER and CERTIFIED INSURANCE CONSULTANT exams — there is no adjuster, public adjuster or appraiser outline in it at all.
Figures on third-party sites are not traceable to Pearson. ⚠ And “100 questions, 2 hours” describes at most HALF this credential — two of the four casualty lines are one-hour exams.
Online delivery ended 1 August 2025Every Connecticut insurance examination is now administered in person at a test center, scheduled at least 24 hours in advance. Retakes require a 24-hour wait and cannot be booked at the center. A passing result is valid for one year to submit the application through NIPR. ⚠ Material written before August 2025 may still offer an online option — it is gone.
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The examination fees printed in § 38a-11 are NOT what you pay
§ 38a-11 sets examination fees of $15 (public adjuster), $20 (casualty) and $80 (appraiser). Every one is drafted the same way:
“an examination fee of [X] for each examination taken, except when a testing service is used, the testing service shall pay a fee of [X] to the commissioner for each examination taken by an applicant.”
⚠ Pearson VUE IS the testing service. Those are vendor-to-department remittances, not candidate charges. The candidate pays Pearson $65, $70 or $120. A source reporting a “$15 Connecticut public adjuster exam fee” read the first half of the sentence and stopped before the exception.
Credential
Initial
Renewal
The arithmetic
Casualty adjuster
$130
$80
$80 license § 38a-11(a)(14)(B) + $50 filing
MVPD appraiser
$130
$80
$80 license § 38a-11(a)(15)(B) + $50 filing
Public adjuster
$300
$250
$250 license § 38a-11(a)(13)(B) + $50 filing
The $50 is § 38a-11(a)(10), and it explains the whole fee table“a filing fee of fifty dollars for each initial application for a license made pursuant to section 38a-769.”$80 + $50 = $130. $250 + $50 = $300. The arithmetic closes exactly against the Department’s published figures — and because the $50 attaches only to an initial application, renewals come in at the bare statutory license fee. ⚠ So the $50 is not an add-on beyond $130; it IS the difference between $80 and $130.
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THREE renewal conventions run at once — and the free codifications carry the old one
Public Act 24-138 substituted “initial license issued to an adjuster of casualty claims shall expire two years after the date of the licensee’s birthday that preceded the date the license was issued” for “such license shall be in force until June thirtieth in each odd-numbered year” — and made the identical change to § 38a-790.
• Individual casualty adjuster and appraiser — BIRTH MONTH, every other year. The Department states it as two years after the last day of the birth month preceding issuance. Applies to licenses issued on or after 1 October 2024; older ones ran to 30 June 2025. • ⚠ PUBLIC ADJUSTER — APRIL 30 of each EVEN year. P.A. 24-138 did not touch § 38a-788, which still reads “in force only until the first day of May in each even-numbered year.” • ⚠ BUSINESS ENTITIES — JUNE 30 of each ODD year. The old convention survives for entities. So in one agency file, “June 30, odd years” is right for the entity and wrong for the individual adjuster who works there.
No grace period. Miss it and you apply for a new license at $130. Renewal notices go out ~90 days ahead. A military waiver waives the fee for an active-duty year.
Continuing education is ZERO — and it is provable, not merely statedA department FAQ is a lead, never authority, so chase it to the delegation. § 38a-782a:“The commissioner may adopt regulations … relating to the establishment of continuing education requirements for persons licensed as insurance producers…”The power reaches producers only. Three supports: (1) placement — § 38a-782a sits in ch. 702 Part II, Insurance Producers, while public adjusters are Part IV, appraisers Part V, casualty adjusters Part VI; (2) enumeration — the adjuster regulation series is exactly five sections, §§ 38a-792-1 through -5, and none concerns education; (3) contrast — producers do have CE, 24 hours with 3 in laws and ethics, and the Department’s CE handbook is captioned for producers. ⚠ Do not import a neighboring state’s adjuster CE requirement. The Commissioner was never given the power to impose one.
Exam waivers — and the clock runs backward from application§ 38a-792(a)(2), mirrored in §§ 38a-790 and 38a-788: the Commissioner may waive the examination for an applicant that (A) is a nonresident or has its principal place of business in another state and holds an equivalent license from any other state, or (B)“at any time within two years next preceding the date of application has been licensed in this state under a license of the same type.”⚠ A lapsed licensee counting two years from the date the license lapsed is measuring from the wrong end of the period. Note the knock-on for public adjusters: the waiver reaches the examination, and the 40-hour course is conditioned on admission to that examination — the Department’s process refers to a “pre-licensing waiver letter.”
Connecticut never adopted a claim-handling regulation — and the regulation that governs your conduct points at rules that do not exist.
There is no private right of action under CUIPA, settled by the Supreme Court in 2022. CUTPA is the only private route, and it imports CUIPA’s elements whole. The result is a closed loop in which a single mishandled claim supports neither.
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The absence IS the rule — there is no subtitle 816
Connecticut never adopted the NAIC Unfair Claims Settlement Practices model regulation. This can be shown rather than assumed: the state agency regulations under Title 38a run to roughly eighty subtitles, and there is no subtitle 816. The nearest by caption is 819 — Advertisements of Accident and Sickness Insurance, which is not claim handling. The Department’s own regulations, §§ 38a-8-1 to 38a-8-126, are organization, contested-case procedure, hearings, privacy and information security, with zero substantive claim-handling timeframes.
⚠ Most states put the numbers in the regulation. A candidate trained on that pattern will hunt for Connecticut’s regulation and never find it, because there is none to find.
And the conduct regulation delegates to a private trade associationReg. § 38a-792-4, captioned “National standards”: casualty adjusters “shall be guided by the Connecticut Unfair Insurance Practices Act, Section 38a-816(6) of the General Statutes, the regulations implementing its provisions, and the Code of Ethics as established by the National Association of Independent Insurance Adjusters, as amended from time to time.”⚠ There ARE no regulations implementing its provisions. So the operative standard for a Connecticut casualty adjuster is § 38a-816(6) plus a private association’s ethics code, incorporated by reference, whose content can change without any action by the State of Connecticut.
⚠ The frequency element covers subdivision (6) ONLY
§ 38a-816 has twenty-six subdivisions, and “committing or performing with such frequency as to indicate a general business practice” appears in exactly one of them — the chapeau of (6).
Subdivisions (1)–(5) and (7)–(26) carry no frequency requirement at all. A single act violates CUIPA under, e.g., (8) false statements in an application, or (16) the total-loss sales tax rule.
“CUIPA always requires a general business practice” is wrong as to 25 of the 26 subdivisions.
📜 Within (6), one claim is not enough
Lees v. Middlesex Ins. Co., 229 Conn. 842, 849 (1994) — the legislature meant to “exempt from coverage under CUIPA isolated instances of insurer misconduct,” and misconduct on a single claim “without any evidence of misconduct … in the processing of any other claim” does not satisfy the statute.
Administrative penalties: $5,000 per violation / $50,000 aggregate, rising to $25,000 / $250,000 per six months for knowing violations. Hearing notice not less than 30 days.
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The closed loop — no CUIPA action, and CUTPA does not get you around it
1. No private right of action under CUIPA.Dorfman v. Smith, 342 Conn. 582 (2022): CUIPA “does not authorize a private right of action but, instead, empowers the commissioner to enforce its provisions through administrative action.” Before 2022 the Superior Courts genuinely split, and much secondary material still describes the split.
2. CUTPA is the only private route — and it inherits CUIPA.Mead v. Burns, 199 Conn. 651 (1986): the failure of the CUIPA claim is fatal to the CUTPA claim. State v. Acordia, 310 Conn. 1 (2013): insurance-related conduct “can violate CUTPA only if it violates CUIPA”.
3. So for claim settlement, the plaintiff must still prove a general business practice.
⚠ RESULT: a single mishandled claim supports NEITHER a CUIPA claim nor a CUTPA claim. What survives is common-law bad faith — and the routine Connecticut outcome is exactly that: CUIPA and CUTPA counts struck, bad faith count goes forward.
An official source on the legislature’s own server is flatly wrongA 2004 Office of Legislative Research report — still live at a cga.ct.gov address — states that CUIPA “provides a private right of action.” It is twenty-two years old and does not survive Dorfman. ⚠ A state-government domain is not evidence that a document is current. Legislatures and agencies host superseded material indefinitely. Check the date printed on the document, not the address it sits at.
CUTPA mechanics — and two things not to import§ 42-110g(a) requires an ascertainable loss and permits punitive damages in the court’s discretion. § 42-110g(d) allows costs and fees. § 42-110g(f) — THREE YEARS from the OCCURRENCE of the violation, not from discovery. ⚠ An adjuster cross-trained on the Massachusetts statute will expect a 30-day pre-suit demand letter and double or treble damages. Connecticut CUTPA has NEITHER. Punitive damages under § 42-110g(a) are discretionary and unmultiplied.
⚠ Punitive damages are a real inversion
Connecticut’s common-law punitive award is limited to the plaintiff’s litigation expenses, including attorney’s fees, less taxable costs — Berry v. Loiseau, 223 Conn. 786 (1992). Trigger: “reckless indifference to the rights of others or an intentional and wanton violation.”
That is closer to fee-shifting than to punish-and-deter. It survives Bifolck (2016), which held only that the common-law measure does not govern a statutory scheme.
💡 Which explains the whole litigation structure
Punitives under CUTPA § 42-110g(a) are NOT subject to the common-law ceiling. So the uncapped exposure runs through the statute — and the statute requires a CUIPA violation, which for claim settlement means a general business practice.
Everything turns on that one element, which is why insurers litigate it so hard.
And a coverage win carries no fees: ACMAT Corp., 282 Conn. 576 (2007) declined the fee-shifting rule absent bad faith conduct before or during litigation.
Can YOU be sued personally?Negligence — no duty to the insured.Danielsen v. USAA Cas. Ins. Co. (D. Conn. 2015): independent adjusters owe no duty of care to policyholders, because “the law of agency requires a duty of absolute loyalty of the adjuster to its employer, the insurer.”⚠ But note where the exposure goes instead: the same reasoning routes the remedy to a bad faith claim against the carrier with the adjuster’s conduct imputed to the insurer. YOUR FILE IS THE CARRIER’S BAD FAITH EXPOSURE — that is the sentence to remember. CUIPA/CUTPA is the live theory and not foreclosed: § 38a-815 says “No PERSON,” not “no insurer,” and Reg. § 38a-792-4 puts adjusters inside § 38a-816(6). But the plaintiff must still clear Acordia and prove a general business practice attributable to that individual. No Connecticut decision squarely resolves it. The certain exposure is regulatory: the Licensee Investigations Unit — administrative sanctions only, no law enforcement authority.
Ask where the rule lives before you ask what it says.
Connecticut’s property payment clock is not in CUIPA and not in a regulation — it is printed inside the fire policy the statute prescribes. The 60/20-day numbers everyone quotes are accident and health only. And everything else is a bare reasonableness standard, because there is no regulation to put numbers in.
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The property payment clock is inside the POLICY FORM — and the trigger is CONJUNCTIVE
§ 38a-307, standard fire policy, under “When loss payable”:
“The amount of loss for which this Company may be liable shall be payable thirty days after proof of loss … is received by this Company AND ascertainment of the loss is made either by agreement between the insured and this Company expressed in writing or by the filing of an award as herein provided.”
⚠ TWO conditions must BOTH be met: proof of loss received, AND the amount ascertained by written agreement or appraisal award.
Two opposite errors come out of this one sentence. An adjuster who diaries 30 days from proof of loss alone treats files as late when the amount was never agreed or appraised. A course that says Connecticut has no property payment deadline — reasoning from the missing regulation — teaches that only reasonableness applies. Carry both halves: thirty days, running from the LATER of proof of loss and ascertainment.
Two companion provisions in the same formCompany’s options: the insurer may elect to repair, rebuild or replace rather than pay, but must give notice of that intention within thirty days after receipt of the proof of loss. Advance payment: the parties may agree in writing to a partial advance payment credited against the total — and “An advance payment shall not affect the requirement of this Company to pay the total amount of loss not later than thirty days after proof of loss.”Proof of loss itself is due within sixty days.
Accident & health — § 38a-816(15)(B)
Pay within
Deficiency notice
Pay after info
PAPER claim
60 days
30 days
30 days
ELECTRONIC claim
20 days
10 days
10 days
⚠ ALL CALENDAR DAYS — the subdivision uses the bare formula “not later than sixty days after receipt” with no business-day qualifier anywhere, and the drafters used the word “calendar” elsewhere in the same subdivision when they meant it. Late payment costs the claim amount plus interest at 15% per annum.
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Those 60/20 numbers are ACCIDENT AND HEALTH ONLY — and published compendia get this wrong
Subdivision (15) is expressly limited to “accident and health claims, including … claims for payment or reimbursement to health care providers.”
⚠ Applying the sixty-day or twenty-day rule to a homeowners or automobile file is an error — and it appears in more than one published fifty-state survey, which quote the numbers as though they were Connecticut’s general claim-payment deadlines. They are not. For property and casualty, go back to the policy form.
Everything else is a bare reasonableness standardFor P&C claim handling outside the fire policy form, § 38a-816(6) is entirely qualitative: reasonable promptness · prompt investigation · within a reasonable time after proof of loss statements have been completed · prompt, fair and equitable settlement where liability is reasonably clear · a reasonable explanation of the basis in the policy for denial. There are no numbers, because there is no implementing regulation to put numbers in.⚠ So the only numeric P&C claim deadlines in Connecticut are POLICY TERMS enforced as contract, not regulatory deadlines enforced by the Department.
📜 Bad faith — the standard is demanding
Breach of the implied covenant of good faith and fair dealing — Verrastro, 207 Conn. 179, 190 (1988). De La Concha, 269 Conn. 424, 433 (2004): “Bad faith means more than mere negligence; it involves a dishonest purpose.”
A legitimate coverage dispute is not bad faith.Third-party claimants cannot bring it — Carford, 94 Conn. App. 41, 46 (2006): no claim lies for conduct “outside of a contractual relationship.” A judgment creditor has a separate route under § 38a-321.
⚠ Two questions Connecticut has NOT answered
Whether Connecticut recognizes a first-party bad faith TORT distinct from the contract claim is unsettled. A 2025 Appellate decision is often cited for it and does NOT hold that — see below.
And no Connecticut appellate decision fixes the limitations period for common-law bad faith. Three-year tort or six-year contract; the question is live precisely because the claim is framed as contractual. Do not state a number.
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The litigation privilege — and exactly where it stops
Dorfman v. Smith, 342 Conn. 582 (2022) — the absolute litigation privilege BARS bad faith and CUTPA/CUIPA claims premised on the insurer’s false pleadings and false discovery responses during the coverage litigation, even where the carrier allegedly concealed evidence and pleaded a knowingly false special defense. The remedy is sanctions, not a bad faith count.
Bouazza v. Geico Gen. Ins. Co., 230 Conn. App. 87, argued 15 October 2024, officially released 21 January 2025 — the trial court improperly dismissed a bad faith claim, because allegations about conduct outside the judicial proceeding and prior to the commencement of the underlying litigation had “no connection or logical relation to any ongoing judicial proceeding” and were not covered by the privilege.
⚠ THE WORKING LINE: conduct at the CLAIM DESK is exposed; conduct in LITIGATION FILINGS is privileged.
⚠ AND A CORRECTION:Bouazza is sometimes described as recognizing an independent tort of insurer bad faith. It does not. It is a litigation-privilege and subject-matter-jurisdiction ruling; the court’s own syllabus calls it simply “the count of her complaint alleging bad faith,” and the word CUIPA appears nowhere in the opinion.
Three reversals of the national rule, and one date that changes the guaranty fund.
Comparative negligence measures the plaintiff against the combined fault of all defendants. The fire policy suit clause is twenty-four months, not twelve. The employee picks the doctor. And on 1 October 2026 the guaranty numbers move substantially.
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Comparative negligence is measured against the COMBINED fault — work the arithmetic
§ 52-572h(b): contributory negligence does not bar recovery “if the negligence was not greater than the combined negligence of the person or persons against whom recovery is sought.” Modified comparative, 51% bar — at exactly 50% the plaintiff recovers.
Plaintiff 40% · Defendant A 30% · Defendant B 30%: • Connecticut: 40% against the defendants’ combined 60%. 40 is not greater than 60. The plaintiff RECOVERS, reduced by 40%. • A state comparing the plaintiff to EACH defendant: 40% exceeds each defendant’s 30%. The plaintiff recovers NOTHING.
⚠ Same facts, opposite result, and the difference is one word in one subsection. An adjuster who has worked an each-defendant state will evaluate multi-defendant Connecticut files wrongly and consistently.
Not a no-fault state — and has not been since 1994§§ 38a-365 to 38a-369 were repealed by P.A. 93-297, effective 1 January 1994. Connecticut is a pure tort state: no PIP mandate, medical payments optional. ⚠ Connecticut WAS a no-fault state for about two decades, which is why the error persists in older material and in the memory of adjusters who worked the state in the 1980s. Minimums are 25/50/25 under § 14-112(a), raised by P.A. 17-114 effective 1 January 2018 from 20/40/10 — note the property damage figure went $10,000 to $25,000, a 150% jump.
⚠ Standard CT UIM REDUCES — it is not excess
Reg. § 38a-334-6 permits the policy to provide “for the reduction of limits to the extent that damages have been paid by or on behalf of any person responsible for the injury, paid or are payable under any workers’ compensation law, or paid under the policy in settlement of a liability claim.”
An adjuster trained in an excess-UIM state will over-reserve and overpay Connecticut files in a predictable direction. Note the reduction reaches workers’ compensation payments too, which is easy to miss.
§ 38a-336a is an optional buy-up that converts reducing coverage into non-reducing coverage: “in no event shall the underinsured motorist coverage be reduced on account of any payment by or on behalf of the tortfeasor or by any third party.” An anti-duplication guard survives.
⚠ “Is this a conversion file?” should be one of the first three questions on any CT UIM claim. Same accident, same limits, same tortfeasor payment — materially different exposure.
Stacking is prohibited by statute, and the statute reversed the case law§ 38a-336(d):“in no event shall the limit of liability for uninsured and underinsured motorist coverage applicable to two or more motor vehicles … be added together.” The same subsection makes the occupied non-owned vehicle’s coverage primary and the insured’s own secondary. ⚠ Connecticut case law of the late 1980s and early 1990s PERMITTED inter-policy and intra-policy stacking. P.A. 93-297 superseded that line for policies issued or renewed on or after 1 January 1994. Those decisions are good law only for pre-1994 policies — which in practice means historical interest only. Material citing them as current Connecticut stacking law is teaching a rule the legislature abolished.
The UM/UIM clock runs from the DATE OF ACCIDENT§ 38a-336(g)(1) forbids limiting the time to sue or demand arbitration to “a period of less than three years from the date of accident.” Where the tortfeasor’s insurer is insolvent or denies coverage, § 38a-336(g)(2) gives not less than one year from the insured’s receipt of written notice. ⚠ Two things to understand. First, the clock runs from the accident — not from denial, breach or exhaustion — so a UIM claim can expire while the underlying liability claim is still being litigated. Second, this is a FLOOR on what the policy may impose, not a statute of limitations; the policy creates the period and may be more generous.
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Total loss is a FORMULA — and the “15% threshold” belongs to theft
§ 38a-353, as amended by P.A. 26-69 § 8, effective from passage (already live): “constructive total loss means the cost to repair or salvage such property, or the cost to both repair and salvage such property, equals or exceeds the total value of the property at the time of loss.”Connecticut has no percentage threshold. Valuation: at least the AVERAGE of the retail values from the J.D. Power guide — the act struck “National Automobile Dealers Association” — or any other Commissioner-approved public source, plus one other approved source. ⚠ Material naming NADA is now out of date.
⚠ THE 15% TRAP. § 14-16c(f) DOES contain fifteen percent. Read the trigger: a vehicle “declared a total loss in settlement of a claim for THEFT, having no damage to a major component part or having damage not exceeding (1) fifteen per cent of the retail value … or (2) one thousand dollars … shall not be required to have its certificate of title stamped.”
That is a title-BRANDING EXEMPTION for recovered theft vehicles on a disjunctive test — not a total loss threshold at all. The figure is authentic and correctly pin-cited by the sources that quote it. It simply answers a different question.
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Connecticut’s OWN fire policy — and THREE wrong answers on the suit clause
§ 38a-307 prescribes Connecticut’s own standard fire policy. It is NOT the national 165-line form, and it is not line-numbered.
“No suit or action on this policy … unless commenced within TWENTY-FOUR MONTHS next after inception of the loss.”
• National 165-line form — 12 months — never Connecticut’s rule • Pre-2014 Connecticut sources — 18 months — correct only 1/1/2012 to 9/30/2014 • Current law — 24 months — P.A. 14-175, effective 1 October 2014, and the act shows the change literally, replacing “eighteen” with “twenty-four”
⚠ A candidate working from a national reference gets twelve. One working from a 2012–2014 Connecticut source gets eighteen. Both look authoritative. Appraisal is in the same form: 20 days to name appraisers, 15 days to agree on an umpire, then a judge appoints.
Matching is a STATUTE, and it is an appraisal question§ 38a-316e: where a covered loss requires replacement and the replacement items “do not match adjacent items in quality, color or size, the insurer shall replace all such items with material of like kind and quality so as to conform to a reasonably uniform appearance… This provision shall apply to interior and exterior covered losses.”Connecticut is in the minority that legislates this — fifty-state matching charts built from code searches routinely miss it, and many rules elsewhere reach only exterior siding and roofing. No cap in the operative text. ⚠ And Klass v. Liberty Mutual, 341 Conn. 735 (2022) held that where the insurer CONCEDES a covered peril, matching is an “amount of loss” question FOR THE APPRAISERS. But the court expressly did NOT decide whether causation is a coverage question — so appraiser authority over causation remains open in Connecticut.
No valued policy law, and no statutory ACV definitionConnecticut is not a valued policy state — no such section in ch. 700, and the prescribed form settles on actual cash value. ⚠ Two neighboring states DO have valued policy laws, which is how the error travels into regional training material. And there is a specific trap on ACV: Public Act 11-196 (2011) is titled “An Act Concerning the Actual Cash Value of a Building” and is regularly cited for a statutory ACV formula. The enrolled act is a SINGLE SECTION that amends the fire policy form and enacts no definition at all.An act’s title is a description of intent, not operative text. Connecticut also has no authority in either direction on depreciating labor.
Hurricane deductibles need 74 mph IN Connecticut§ 38a-316a(b) permits a hurricane deductible only “if such hurricane results in a maximum sustained surface wind of seventy-four miles per hour or more for any part of this state.” The window opens with the National Hurricane Center’s hurricane warning for any part of Connecticut and closes 24 hours after the last warning is terminated or 24 hours after the last downgrade from hurricane status — whichever is EARLIER. ⚠ A major coastal storm downgraded below hurricane status before reaching the state wrote this rule: enormous damage, no hurricane deductibles, ordinary AOP deductibles instead. The test is not what the media called it — it is whether a warning was in effect and whether sustained winds hit 74 mph for part of Connecticut.
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The guaranty numbers change on 1 October 2026 — and one trigger date precedes the act
Now, through 30 September 2026 — § 38a-841(a)(1): claims in excess of $100 and less than $500,000 (final liquidation order on or after 1/10/2015). Legacy tiers $400,000 and $300,000. Unearned premium: one-half, max $2,000. Workers’ comp claims PAID IN FULL, no cap. Filing bar 2 years, except comp timely filed under § 31-294c.
⚠ $300,000 is the LEGACY tier, not the current cap — it is the figure most often quoted and has been superseded for over a decade.
P.A. 26-69 § 20, effective 1 October 2026: • The $100 claimant deductible is ABOLISHED — deleted outright • The one-half rule on unearned premium is DELETED — the full amount is refundable • Unearned premium cap $2,000 → $50,000 • NEW $1,000,000 for first-party real property claims from a single occurrence • NEW $500,000 aggregate for cybersecurity coverage per single insured event, regardless of the number of claims or claimants
⚠ NOTE THE DATE ASYMMETRY: the act is effective 1 October 2026, but the new $1,000,000 limit attaches to insurers “determined to be insolvent ON OR AFTER 1 JUNE 2026” — a trigger date that PRECEDES the act’s own effective date.
Workers’ compensation — two indices, and a conclusive presumptionFor 1 Oct 2025 to 30 Sept 2026: total incapacity max $1,716.00 / min $343.20; PPD max $1,220.00 / min $50.00. ⚠ The benefit is 75% of the AFTER-TAX wage, not two-thirds of gross. ⚠ And Connecticut uses TWO different wage indices in one schedule — total incapacity on the all-employee average, PPD on the manufacturing production-worker average. Most states run everything off one. Rates reset every 1 October; do not extrapolate.⚠ 28 DAYS to accept or contest under § 31-294c — miss it and the employer is “CONCLUSIVELY PRESUMED to have accepted the compensability.” Conclusive, not rebuttable.⚠ The EMPLOYEE selects the physician from an approved list (§ 31-294d) — the exact inversion of the employer-directs norm. And § 31-293 reduces the employer’s lien by ONE-THIRD when the EMPLOYEE brought the action — a mechanical substitute for a made-whole rule, not a version of one.
Fraud — no warning statement, and a duty that dies 1 October 2026⚠ Connecticut does NOT require a fraud warning statement on claim forms. The NAIC fraud-law chart records Connecticut as “no provision.”This is a trap precisely because you WILL see the warning on Connecticut forms — national carriers standardize forms across states and the language rides along. Having seen it is not evidence it is required. Mandatory reporting exists for HEALTH insurance fraud only — § 53-445(a), “shall provide notice” to the Commissioner, no deadline stated, immunity under (d) absent malice or wilful intent to injure. ⚠ The annual MOTOR VEHICLE fraud report — § 38a-356(c), due each 31 March — is REPEALED by P.A. 26-69 § 9 effective 1 October 2026. Information-sharing duties survive. Insurance fraud is a class D felony (§ 53a-215), and comp fraud sits with the Chief State’s Attorney (§ 31-290d), not the Department.
Ten fact patterns drawn from the places Connecticut departs from the national rule — or from what a confident secondary source will tell you.
Each one is a claim you could be handed on a Monday morning. Read the fact pattern before the options, and work the trigger clause before you answer. Several questions carry a plausible wrong answer that is simply the rule of a different state.
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Top Exam Tips — Connecticut Adjuster Regulations
1. FOUR CREDENTIALS, THREE CHAPTERS. Casualty adjuster § 38a-792, appraiser § 38a-790, public adjuster § 38a-788 — NOT ch. 701b, plus a catastrophe registration.
2. ONE LICENSE, FOUR LINES. “All Lines Except Workers’ Compensation” is a real line, and the licensee holding it is fully licensed.
3. FIRE AND LIFE ADJUSTERS NEED NO LICENSE. Reg. § 38a-792-2, two sentences, the reverse of the national rule.
4. 40 HOURS FOR PUBLIC ADJUSTERS — BEFORE THE EXAM, not before application. And no bond, proved by § 38a-795 requiring one of surplus lines brokers instead.
5. ZERO CE. § 38a-782a’s delegation reaches producers only.
6. RAW 70% — the handbook never says “scaled.” Question counts are not published. Two of the four casualty exams run one hour.
7. THREE RENEWAL CONVENTIONS. Individuals birth month; public adjusters 30 April, even years; entities 30 June, odd years.
8. NO CLAIM-HANDLING REGULATION EXISTS. There is no subtitle 816, and Reg. § 38a-792-4 points at regulations that were never written — leaving the NAIIA Code of Ethics as the operative standard.
9. THE PROPERTY CLOCK IS IN THE POLICY FORM AND IS CONJUNCTIVE — 30 days after proof of loss AND ascertainment by written agreement or appraisal award.
10. 60/20 DAYS IS ACCIDENT AND HEALTH ONLY. Do not apply it to a homeowners or auto file.
11. NO PRIVATE CUIPA ACTION (Dorfman 2022), and CUTPA imports CUIPA whole (Mead, Acordia). A single mishandled claim supports neither; bad faith survives.
12. THE FREQUENCY ELEMENT IS IN SUBDIVISION (6) ONLY — 25 of 26 subdivisions need no pattern.
13. PUNITIVES = LITIGATION EXPENSES at common law (Berry). Uncapped only through CUTPA.
14. COMBINED FAULT, 51% BAR. Plaintiff 40% against defendants 30/30 recovers in Connecticut.
15. 24-MONTH SUIT CLAUSE in Connecticut’s own fire policy. Twelve is the national form; eighteen is pre-2014.
16. THE 15% FIGURE IS A THEFT BRANDING EXEMPTION, not a total loss threshold. Total loss is a formula.
17. UIM REDUCES unless conversion coverage was bought; stacking is barred by § 38a-336(d); the clock runs from the accident.
18. 28 DAYS to accept or contest a comp claim — the presumption is CONCLUSIVE. And the employee picks the doctor.
19. 1 OCTOBER 2026: the guaranty $100 deductible is abolished, unearned premium goes to full / $50,000, and new $1,000,000 property and $500,000 cyber limits arrive.
20. NO FRAUD WARNING STATEMENT IS REQUIRED — even though you will see one on every Connecticut claim form.
§ 38a-788
The public adjuster licensing section — and it is in chapter 702, not in chapter 701b. Carries the 40-hour prelicensing requirement and the April 30 even-year expiration.
§ 38a-792-2
Two sentences in full: “No fire insurance adjuster need be licensed. No life insurance adjuster need be licensed.”The reverse of the national rule.
All Lines Except Workers’ Compensation
A full line of authority that includes auto and excludes comp. The licensee is fully licensed, not restricted — which is why “does my license cover comp?” has three answers.
Ascertainment of loss
The second half of § 38a-307’s conjunctive trigger. The 30-day payment clock needs proof of loss AND the amount fixed by written agreement or appraisal award.
§ 38a-11(a)(10)
The $50 filing fee on initial applications only. It is the difference between the $80 statutory license fee and the Department’s $130 figure — not an add-on beyond it.
P.A. 24-138
Moved casualty adjusters and appraisers from June 30 odd-year expiration to birth month. Did not touch § 38a-788, and entities kept the old rule — hence three conventions at once.
Subdivision (6)
The only subdivision of § 38a-816 carrying the general business practice element. The other twenty-five need no pattern at all.
NAIIA Code of Ethics
A private trade association’s ethics code, incorporated into Connecticut law by Reg. § 38a-792-4 “as amended from time to time” — because the implementing regulations it also names do not exist.
The closed loop
No private CUIPA action (Dorfman) → CUTPA only if the conduct violates CUIPA (Acordia) → claim settlement needs a general business practice. One bad claim supports neither.
Conversion coverage
§ 38a-336a — the optional buy-up making UIM non-reducing, so it is not cut down by the tortfeasor’s payment. Ask whether the file has it before setting a reserve.
Combined negligence
§ 52-572h(b) compares the plaintiff to the combined fault of all defendants, 51% bar. A 40% plaintiff against 30/30 defendants recovers.
Twenty-four months
The suit clause in Connecticut’s own standard fire policy, § 38a-307, since P.A. 14-175. Twelve is the national form; eighteen was the rule from 2012 to 2014.
§ 14-16c(f)
The source of the “15% Connecticut total loss threshold.” It is a title-branding exemption for recovered THEFT vehicles, on a disjunctive test. Authentic number, wrong question.
Constructive total loss
Defined by § 38a-353 as of 2026 — repair or salvage cost, or both, equals or exceeds the total value. A formula, not a percentage. Valuation now averages J.D. Power plus one other approved source.
Conclusive presumption
The § 31-294c consequence of blowing the 28-day accept-or-contest window. It cannot be rebutted — harsher than the rebuttable presumption most states apply.
Void from inception
A public adjuster contract omitting the 12-point boldface cancellation provision, or resulting from a solicitation between 8:00 p.m. and 8:00 a.m.
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