Maryland Property Study Guide

A national claims course teaches unfair claim settlement practices as a list of day counts, and it teaches you to count those days on a calendar. Maryland’s property claim chapter counts on a different instrument. COMAR 31.15.07 writes its core deadlines in working days — and then never tells you what a working day is.

That is not an oversight you can reason your way past. The chapter opens with a definitions regulation, COMAR 31.15.07.02, which defines twelve terms. Neither “day” nor “working day” is among them.

So the exam-relevant skill here is not conversion. It is restraint: read the unit the regulation prints, answer in that unit, and do not translate.

Four separate duties, all on the same fifteen

The number is easy. What candidates lose marks on is how many places it appears.

COMAR 31.15.07.03B gives a property insurer 15 working days to do four different things: to acknowledge a claim — subsection (10), unless the insurer simply pays within that period; to respond to an inquiry from the Maryland Insurance Administration — (11), or within the longer period the Administration itself specifies, whichever is greater; to affirm or deny coverage after receiving properly completed claim forms or other proofs of loss — (12), unless Regulation .04B applies or the policy sets its own time limit; and to reply appropriately to written communications from a claimant — (15). One clock, four duties, and an item can be built on any of them — including on which paragraph carries which duty, since (11) and (12) are the two most easily transposed.

Two refinements ride on top. First, .03C treats the acknowledgment limb as satisfied when the insurer furnishes claim forms, instructions and reasonable assistance — it need not be a separate letter. Second, the same 15 working days reappear inside a defined term: COMAR 31.15.07.02B(12) defines “unreasonable delay” as failure to pay amounts properly due within 15 working days of a properly completed claim form or other proof of loss. That definition bites only where there is “no significant dispute as to coverage, liability, and amount of damages,” and it expressly excludes personal injury protection claims. A genuinely contested property loss is not an unreasonable delay.

And the one computation rule the chapter does supply, COMAR 31.15.07.07, is not a definition at all — it is a tolling rule. Days between the insurer’s request for additional information and the claimant’s response are not counted. It tells you which days to skip; it never tells you how long a day is.

The 45-day notice that keeps coming back

Now switch units deliberately, because the very next regulation does.

Where an insurer has not completed its investigation of a first-party claim, COMAR 31.15.07.04B requires a written notice of the actual reason more time is needed — and requires that notice to be repeated after each additional 45-day period until coverage and damages are affirmed or denied. The regulation says plain “days” here, not working days.

Read that as a rolling obligation, not a one-time courtesy letter and not a deadline to finish investigating. As long as the file stays open, the insurer keeps writing, and each letter must give the actual reason — a form paragraph saying the claim remains under review is what the regulation is aimed at.

A written warning that the clock may run out

The second first-party duty in .04 has no national analogue you will have studied. Under COMAR 31.15.07.04C, on receiving a written claim from an unrepresented first-party claimant, the insurer must warn that claimant in writing that there may be an applicable statute of limitations that could bar their rights.

Every element narrows it. The claimant must be first-party — a third-party claimant is outside the regulation. The claimant must be unrepresented — the moment counsel appears, the duty is gone. And the trigger is a written claim. Relief from the duty exists at .04E, and it is narrow: a reasonable basis supported by specific information showing the claimant fraudulently caused or contributed to the loss.

An offer duty, not a coverage mandate

Finally, one rule that is easy to over-read. Md. Code, Ins. § 19-202(a) requires an insurer issuing, selling or delivering a homeowner’s policy to offer in writing coverage for loss caused by water that backs up through sewers or drains and is not caused by the negligence of the insured — at the time of application and at each renewal.

Maryland is not mandating the coverage. It is mandating the offer, and mandating that the offer recur. Two delivery rules follow: on a telephone transaction the offer goes out by a first-class mail tracking method within 7 calendar days (§ 19-202(b)); on an internet transaction it must be provided before the application or renewal is submitted (§ 19-202(c)).