How the Person Who Decides Your Claim Is Paid

Short answer: The person who inspects your car is paid per file, not per hour. Every published pay arrangement we could find in this sector prices the assignment, and the regulator that supervises the claim measures the claim almost entirely by whether it closed and how fast. The only published fee schedule we located that moves with the size of the settlement moves upward, which cuts in the adjuster's favour.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-09-02 · How this was written, and what the machine may not do

How this page was produced: Researched, drafted and checked with AI assistance under human direction, and signed off by the named author. How this site is written

This piece is about the money and the measurement around the person who decides what your repair is worth. It is about the structure they work inside, read at source.

A note on typography. Several sources below print curly quotation marks, en dashes or em dashes. This page renders those as straight quotes and plain hyphens so the text stays ASCII. No word is changed, only the glyph, and every other departure from a source is flagged where it occurs.

The overtime exemption that lives outside the United States Code

Since 2014 there has been a federal overtime exemption for catastrophe claims adjusters. It is not in the Fair Labor Standards Act, and a lawyer reading 29 U.S.C. 207 or 29 U.S.C. 213 will not find it, because Congress never amended the Code. It puts the words somewhere else.

The current enactment is the Consolidated Appropriations Act, 2026, Public Law 119-75, approved 3 February 2026, Division B, Title I, Sec. 108, at 140 Stat. 253-254. We pulled the full text of the Act from govinfo.gov and searched it locally (read on 2026-09-02). The operative sentence, quoted verbatim, with the Statutes at Large paired quotation glyphs rendered as straight quotes and the printed editorial sidenotes omitted:

"Sec. 108. (a) Section 7 of the Fair Labor Standards Act of 1938 (29 U.S.C. 207) shall be applied as if the following text is part of such section:"

Read the construction. Section 7 "shall be applied as if" the text were part of it. A deeming provision in an appropriations act does not amend the Code, so the Code does not carry it.

The deemed text withdraws overtime protection for two years after a major disaster from an employee:

"(A) employed to adjust or evaluate claims resulting from or relating to such major disaster, by an employer not engaged, directly or through an affiliate, in underwriting, selling, or marketing property, casualty, or liability insurance policies or contracts; (B) who receives from such employer on average weekly compensation of not less than $591.00 per week or any minimum weekly amount established by the Secretary, whichever is greater..."

An insurance company cannot use this exemption. The firm it rents adjusters from can. Paragraph (A) excludes any employer engaged in underwriting, selling or marketing insurance. The exemption exists because the work is outsourced.

The figure has not moved in twelve years, across three enactments

We pulled three Acts in full and compared them (all read on 2026-09-02):

• the 2014 original, the Consolidated and Further Continuing Appropriations Act, 2015, Public Law 113-235, approved 16 December 2014, Division G, Title I, Sec. 111, at 128 Stat. 2465-2466;
• the Further Consolidated Appropriations Act, 2024, Public Law 118-47, approved 23 March 2024, Division D, Title I, Sec. 108, at 138 Stat. 644-645;
• and the 2026 Act above.

We extracted the rider from each, stripped the page markers and editorial sidenotes, normalised the whitespace and compared them character by character. All three are 2,647 characters and identical once the section number is masked: 111 in 2014, 108 in 2024 and again in 2026. The 2024 and 2026 riders are byte-identical to each other. The string "$591.00" appears exactly once in each Act.

The Department of Labor says the same thing about the sequence: the exemption "was first enacted in the Consolidated and Further Continuing Appropriations Act, 2015 (P.L. 113-235) and Congress has continued to enact it in subsequent appropriations acts" (Fact Sheet 72A, May 2026, read on 2026-09-02).

Against that, the Department states the ordinary salary threshold for the administrative exemption at "at a rate not less than $684 per week" (Fact Sheet 17L, revised September 2019, read on 2026-09-02). Our arithmetic, from those two figures: 591 dollars a week is 30,732 dollars over 52 weeks; 684 dollars is 35,568 dollars. The disaster floor is 93 dollars a week lower, about 86 per cent of the ordinary one, and Congress has left it at the same nominal number since 2014.

Two ways this cuts for the sector, not against it

Congress expressly preserved the ordinary analysis: "(2) The exemption in this subsection shall not affect the exemption provided by section 13(a)(1)." The rider adds a route; it takes nothing away. The Department of Labor puts it the same way: the two exemptions are "distinct", and "Each exemption stands alone and should be evaluated and applied independently based on the particular set of facts and circumstances."

More importantly, the definition at paragraph (3)(B) conditions the whole exemption on the employer maintaining workers compensation coverage, "if required by applicable law", and withholding "applicable Federal, State, and local income and payroll taxes from the wages, salaries and any benefits of such employees", and on the individual having "timely secured or secures a license required by applicable law". That is employment, and it is licensure. A firm that engages its catastrophe adjusters as 1099 contractors, withholding nothing, cannot use this exemption for them.

One large firm does use 1099 engagement for at least one programme, though the fit with the rider is loose enough to state carefully. Sedgwick's virtual inspector FAQ says: "Where allowed by law, you will receive a 1099 as a Sedgwick contractor and be paid on that pay cycle. Where this arrangement is not allowed, you will receive a W2 as an employee of eTeams or Workforce Logiq and be paid on that pay cycle." So the arrangement is 1099 by default and W2 where a state forbids that. Two cautions on using this against the rider. That programme is property rather than auto, and the same document says "you do not need an adjuster license to perform virtual inspections", so those inspectors would fail the rider's licensure condition regardless of how they are paid. It shows how the layer contracts. It does not by itself show a catastrophe adjuster losing the exemption.

The gap we did not close

Fiscal year 2025 ran on a full-year continuing resolution, the Full-Year Continuing Appropriations and Extensions Act, 2025, Public Law 119-4, approved 15 March 2025. Its section 1101(a) continues listed 2024 Acts "under the authority and conditions provided in applicable appropriations Acts for fiscal year 2024". Its entry (8) is the Labor, Health and Human Services and Education appropriations Act, "division D of Public Law 118-47", which is the very division carrying the adjusters rider at section 108. Entry (8) names four carve-outs: section 240 as modified, sections 241 and 310 excluded, and the amounts in sections 528 and 529 replaced. The adjusters rider, section 108, is not among them. The string "section 108" does not appear anywhere in that continuing resolution.

Whether a provision that operates on the Fair Labor Standards Act rather than on money is an "authority" or "condition" continued by that sentence is a question of statutory construction, and we located no court decision, agency opinion letter or Comptroller General decision answering it. We do not claim the exemption has been continuously in force since 2014, because we did not establish it. Nor does the agency: the Department of Labor tells employers that "Before applying the overtime exemption, employers should determine whether an appropriations law authorizing the exemption is in effect for the relevant time period." The regulator hands that question back to the employer.

A note on method, because it changed the answer. The rider wraps across lines in these fixed-width texts, so a plain line-by-line search for "Fair Labor Standards" returns nothing even in the 2026 Act, where the rider demonstrably sits in Division B. We therefore re-ran every search with whitespace normalised. On that corrected instrument the phrase appears once in Public Law 119-75, once in Public Law 118-47, once in Public Law 113-235, and zero times in the continuing resolution. The finding survives; the naive instrument would have produced it for the wrong reason.

What the regulator actually measures

The strongest evidence about what an auto claim is measured on is the data call the state insurance regulators run themselves.

The NAIC publishes seven ratios under the heading "Property & Casualty (Private Passenger Auto & Homeowner)" at pages 27 to 28 of its Market Conduct Annual Statement Ratios 2025, Version 2025.0.4 (read on 2026-09-02). Four of the seven concern claims:

"Ratio 1. The number of claims closed without payment compared to the total number of claims closed"

"Ratio 2. Percentage of claims unprocessed at the end of the period"

"Ratio 3. Percentage of claims paid beyond 60 days"

"Ratio 7. Suits opened during the period to claims closed without payment"

The other three count non-renewals and cancellations.

Read those four precisely, because the easy summary overstates them. Ratios 1, 2 and 3 count closure and elapsed time and nothing else. Ratio 7 is different: its numerator is the number of lawsuits opened, and only its denominator is claims closed without payment. So one of the seven does reach at an outcome, in the crude sense that a claimant who sues is a claimant who was not satisfied. What none of the seven measures is the amount. There is no ratio for severity, for supplement frequency, for parts type, or for whether the repair was right.

The underlying data call says the same thing at the level of the individual file. The Private Passenger Auto Data Call and Definitions, Version 2026.0.0, covering 1 January 2026 through 31 December 2026 with a filing deadline of 30 April 2027, requires per coverage the number of claims closed with payment, the number closed without payment, "Median days to final payment", and six closing-time buckets for claims closed with payment and the same six again for claims closed without it. Collision and comprehensive are reported coverages. The attestation warns that those signing are aware a state insurance department "may initiate regulatory action as authorized by law in a specific jurisdiction if the data submitted in the MCAS is inaccurate, incomplete, or found to be materially false, misleading or omissive."

Speed and closure are the attested, annually filed, per-state measure of a collision claim.

Here is the limit of that. The MCAS is filed by the insurer. It is not filed by Crawford, Sedgwick, Alacrity, Eberl or Pilot, and no equivalent instrument we located reaches the adjusting firm. The measure lands on the carrier, and the carrier buys the work from a layer the measure does not reach.

What the firms say themselves

Two first-party documents, both fetched and read on 2026-09-02.

Crawford's catastrophe adjuster FAQ lists what a catastrophe adjuster does. Two consecutive items in that list are "Controls claims costs" and "Maintains expected case load". The same page notes that "Knowledge of Mitchell preferred for auto adjusters", which is the estimating platform on the collision side.

Sedgwick's virtual inspector FAQ is more specific, and it is a property programme rather than an auto one, which is a real limit on how far it carries. It states: "The range of pay can be anywhere from $45 - $192 per assignment based on task requirements. Mileage is not paid. The fee schedule will be provided at the time of assignment. By accepting virtual inspection assignments, you agree to the fees and terms of the program. The expectation is that you will complete all work assigned to you within the radius you have set." Elsewhere the same document sets the clock: initial contact within 2 hours of receiving the assignment, the appointment set within 48 hours, and the estimate uploaded within 24 hours of the on-site inspection.

Nothing in that fee formula moves with what the claim pays out. It is a per-task price with mileage excluded and the schedule disclosed only at assignment.

And here is the claim we are not making. We located no contract, pay plan, bonus schedule or litigation exhibit connecting a closing ratio, a cycle-time target or a file count to any individual adjuster's compensation. Caseload and elapsed time are in the regulator's data call and in these firms' own recruiting language. That is not the same thing as a pay plan, and we will not write it as though it were. We are not saying that any adjuster is paid more for closing a file without payment, or paid faster for closing it sooner. No document we read connects either to anybody's money.

The one fee schedule that moves with the settlement

It is federal, it is published, and it is flood rather than collision. FEMA Bulletin W-23013, dated 29 September 2023, signed by David I. Maurstad, Assistant Administrator, Federal Insurance Directorate, sets the NFIP adjuster fee schedule effective 1 October 2023 (read on 2026-09-02).

The schedule, reproduced as printed, except that the source prints en dashes in the ranges where this page shows hyphens:

Now read the definition, with the source's bullet markers omitted:

"Gross Loss Gross loss means the agreed cost to repair or replace before the following is applied: Depreciation (recoverable or non-recoverable) Policy deductible(s) Salvage buy-back"

Gross loss means the agreed cost to repair or replace. Above 50,000 dollars, the independent adjuster's fee is a published percentage of the number that adjuster writes on the estimate.

The arithmetic that follows is ours and appears in no FEMA document. A claim closed without payment pays 510 dollars. A 100,000 dollar gross loss falls in the 4.5 per cent band and pays 4,500 dollars, which is 8.82 times the closed-without-payment fee. A 1,000 dollar gross loss pays 680 dollars, or 1.33 times it. A one million dollar gross loss pays 3.2 per cent, which is 32,000 dollars.

Give the counterweight its weight

This schedule is the single strongest fact in the sector's favour, and it is a federal document.

It pays the adjuster more when the claim pays more. It is a straight function of the size of the loss, and the direction is upward across every band. Any argument that independent adjusters are paid to suppress claims has to get past this schedule first, and on this record nothing we located contradicts it.

FEMA also prices the boundary where a claim tips from paid to unpaid, in its own worked example: "Adjuster inspects and prepares an estimate of repair for $1,500. The eligible fee is $1,035. The policyholder withdraws the claim after the estimate is prepared. The claim is closed without payment and the adjuster is eligible to receive the $510 CWOP fee. The balance ($1,035 - $510) $525 is eligible for payment as a SALAE Type 2." Even the unpaid claim is not worth nothing to the adjuster who worked it.

It is also bounded and policed in three ways we should state, because a counterweight reported without its limits is worth less than none.

The percentage does not run away, because the same guidance provides that "The gross loss shall not exceed the following policy limitations", listing the declarations page limits, programme limits, special limits and policy exclusions. The fee tracks a capped number.

It refuses to pay for the adjuster's own mistakes: "The NFIP will not consider supplemental billings for inadequate or incorrect scope of repairs or avoidable estimating errors. The NFIP will consider supplemental billing for unknown or progressive flood related damage as appropriate." A supplement caused by damage nobody could have seen is billable. A supplement caused by the adjuster having missed damage is not.

And it makes timeliness a ground for cutting the fee, which is the one place where this schedule does reach back toward speed. Under the heading IMPORTANT, the NFIP "reserves the right to withhold compensation and to reduce the amount of compensation, on adjustment work deemed: a. Not to comply with NFIP standards. b. Improperly prepared, requiring the claim to be substantially readjusted. c. Not timely adjusted, requiring reassignment."

Why a flood schedule belongs in a collision piece. It is the only published price list we located in this sector for the person standing at the loss. Crawford's own catastrophe material treats flood certification as part of the same deployed workforce that writes vehicle estimates on Mitchell. We located no fee schedule for independent automobile appraisal work, from any firm, in any public document we read, and we are not going to pretend the flood schedule is one.

What the courts have held, including the parts that go the other way

We read six appellate decisions in full for this piece. That is a statement about six decisions, not a survey of the circuits, and we make no claim about whether a circuit split exists. We are not claiming these six are representative of how the federal courts treat claims adjusters. Six opinions read in full is the whole of the reading behind this section.

The auto damage case, and the district court that came out the other way

Robinson-Smith v. Government Employees Insurance Company, D.C. Circuit, Nos. 08-7146 and 08-7147, 590 F.3d 886, decided 5 January 2010, before Circuit Judges Ginsburg and Henderson and Senior Circuit Judge Williams, opinion by Judge Henderson (read on 2026-09-02). The employees are GEICO auto damage adjusters. The court described the work:

"He then inspects the damaged vehicle and enters a description of the damage into the computer, which gives him information like the cheapest generic parts available or standard refinish times and material prices."

"He is empowered to negotiate with claimants and body shops and settles claims up to $10,000 or $15,000-all actions that bind GEICO financially."

(The source sets a dash before "all"; this page renders it as a hyphen.)

The district court had held for the adjusters, satisfied that the discretion they exercised was not sufficient because "the vast majority of the adjusters' work consists of using their training and skills to assess the value of the damage to the vehicle in accordance with the standards laid out by GEICO", and the D.C. Circuit reversed that ruling in the same decision quoted above: "For the foregoing reasons, we reverse the orders of the district court, remand and direct the court to enter judgment for GEICO on the FLSA claims and to conduct further proceedings regarding the Lindsay plaintiffs' state claims consistent with this opinion."

So: a federal appellate court recorded that the computer tells the auto damage adjuster the cheapest generic parts available, and held that the adjuster who works from that screen and negotiates with the body shop exercises enough discretion to be owed no overtime. The court also recorded that "The average auto damage adjuster handles more than 1,000 claims per year, totaling over $2.5 million."

How often that discretion is actually exercised is the number to read carefully, because the opinion states two and they are not the same. The low-end sample, extrapolated, gives "potential negotiations, which amount to between 20 and 30 per year when extrapolated from the 1,000 yearly claims handled by the average GEICO adjuster, involved deviations ranging from $100 to $2,875." The court's own bottom line is wider: "Thus, the record indicates that the typical number of customer negotiations regarding total loss vehicles is between 20 and 60 per year." The caveat the court then attaches belongs to that wider range, not to the narrower one: "Because this range includes only deviations of $100 or more from the computer-estimated vehicle value in total loss situations, it fails to capture negotiations involving partial loss claims or situations where an adjuster 'holds firm' in declining to alter GEICO's initial offer." Anyone quoting 20 to 30 as the court's finding is quoting the sample rather than the finding, and anyone attaching the caveat to it is attaching it to the wrong number. On the court's own figures, between 20 and 60 negotiations out of more than 1,000 claims a year is our arithmetic of 2 to 6 per cent, and the court said that understates the negotiating.

The collision appraiser case

Roe-Midgett v. CC Services, Incorporated, Seventh Circuit, No. 06-3195, 512 F.3d 865, decided 4 January 2008, opinion by Judge Sykes (read on 2026-09-02). The appraisers "negotiate with mechanics and body shops and draft final repair estimates" and "settle claims up to the limit of their $12,000 settlement authority". The court held: "Summary judgment was properly entered for CCS on all four classes of employees."

A useful absence, tested on the flattened full text of the opinion with case folded: the strings "number of claims", "per day", "quota", "cycle time" and "closing" do not appear. The same instrument found the three quoted strings above and six other control terms, which is what a working instrument looks like. The most on-point collision authority in this sector decided that these appraisers exercised discretion without discussing caseload, throughput or closing rates at all.

Volume was tried as a legal test and abandoned by consent

In re Farmers Insurance Exchange, Claims Representatives' Overtime Pay Litigation, Ninth Circuit, Nos. 05-35080 and five others, 481 F.3d 1119, filed 26 October 2006 and amended 30 March 2007, opinion by Circuit Judge Silverman (read on 2026-09-02). The court opened: "For more than 50 years, the Department of Labor has considered claims adjusters exempt from the Fair Labor Standard Act's overtime requirement." (The missing "s" in "Standard Act" is the court's own.)

It held that "all of the adjusters in this case are exempt", and its disposition was mixed: it affirmed as to the adjusters the district court had ruled exempt, reversed as to the rest with instructions to enter judgment for the employer, and separately reversed and remanded the claims under Colorado, Illinois, Minnesota, New Mexico, Oregon and Washington law, closing "AFFIRMED IN PART, REVERSED IN PART AND REMANDED." Every part of the federal ruling went the employer's way; six states' claims went back for further proceedings and were not resolved here.

The passage that matters most concerns throughput. "In doing so, the district court promulgated a '$3,000 in claims paid per month' rule, a rule that all parties to this appeal agree is neither workable nor supported by the evidence." (The source sets that inner phrase in double quotes; they are rendered single here inside our own quotation.) A trial court tried to draw the exemption line by dollar volume, and every party on appeal agreed it did not work. Anyone arguing that throughput settles whether an adjuster is a professional has a federal appellate opinion recording that the litigants themselves abandoned the idea.

The court recorded the workload as "On average, each adjuster pays approximately $1 million in claims per year, ranging from $2,800 to $8,000 per claim". That is a multi-line adjuster population and is not comparable to GEICO's auto damage figure. We have not put them in one table.

One number from this case cannot be published, and the reason is worth stating exactly. The opinion says the district court made an award to "the 1,039 former and current adjusters who filed the necessary claims paperwork". The dollar amount immediately before that count renders in the served text as "nearly .5 million", with the digits missing. The figure is not readable at this source, so we do not give it, and we did not guess at it. This is a defect in the served text, not a disagreement between retrievals.

The largest adjuster win, and what the California Supreme Court did to it

Bell v. Farmers Insurance Exchange, California Court of Appeal, First District, Division One, Nos. A096721, A097810 and A098799, decided 9 February 2004 (read on 2026-09-02). The court held that "the undisputed evidence places the work of the claims representatives squarely on the production side of the administrative/production worker dichotomy" and recorded a jury's special verdict of $88,798,871.12 in unpaid time-and-a-half and $1,210,337 in unpaid double-time, but reversed part of that judgment in the same breath: "We reverse the portion of the judgment for unpaid double-time hours worked, and remand the order re plan of distribution. In all other respects the judgment and postjudgment orders are affirmed."

The two verdict components sum exactly to the judgment total of $90,009,208.12 that the opinion states in its opening paragraph. Adjusters have won, and the number was very large.

And then the state's supreme court cut the reasoning back. In Harris v. Superior Court, Supreme Court of California, No. S156555, filed 29 December 2011, brought by claims adjusters employed by Liberty Mutual Insurance Company and Golden Eagle Insurance Corporation, the court reversed the Court of Appeal and held only this: "We merely hold that the Court of Appeal improperly applied the administrative/production worker dichotomy as a dispositive test", disposing of the case with "We reverse the judgment of the Court of Appeal and remand with directions that it review the trial court's denial of the summary adjudication motion, applying the appropriate legal standard set out herein." (Read on 2026-09-02; the source renders some apostrophes as curly glyphs, rendered straight here.)

Harris did not hold that claims adjusters are exempt, and anyone reporting it that way is misreporting it. The court said so itself in the sentence before the one quoted above: it did not hold that the dichotomy was misapplied to the earlier Bell plaintiffs, or that the dichotomy can never be used as an analytical tool. What it held is narrower and harder: courts must apply the statutes and wage orders to the facts in front of them rather than reach for a shortcut. The Bell jury verdict was never overturned; the test its language fed was told it cannot be used as a mechanical rule.

The same court, both sides of the estimate, 297 days apart

Yi v. Sterling Collision Centers, Inc., Seventh Circuit, No. 06-2645, 480 F.3d 505, decided 13 March 2007, Posner J. (read on 2026-09-02). Sterling paid the mechanics in its collision shops by booked hour. Judge Posner held that this is a commission, and therefore that they are owed no overtime, reasoning: "The faster the team works, the more it earns per number of hours, since its commission is based not on the total number of hours it puts in on a job but on the number of booked hours times each team member's booked-hour rate. That is how commissions work; they are decoupled from actual time worked." The disposition was one word: "AFFIRMED."

Two hundred and ninety-seven days later, the same circuit decided Roe-Midgett, and held that the appraiser who writes the estimate the technician works to is an exempt administrative employee.

The Seventh Circuit removed overtime protection from the person who writes the collision estimate and from the person who does the work that estimate describes, inside ten months, and the document connecting the two decisions is the estimate. In each case the feature the worker complained about is the feature that defeated the claim: for the mechanic, that speed pays; for the appraiser, that the negotiation is real judgment.

The pay structures rhyme in a way worth naming. A third party's number sets the worker's income in both cases. Both are paid per unit of output rather than per hour of work, so the variance in how long the unit actually takes lands on the worker. Neither the shop nor the adjusting firm publishes its pay plan.

What the claimant is never told

Every insurer filing an MCAS must answer, per state, "Does the company use Third Party Administrators (TPAs)?" and, if yes, "list the names of the TPAs." Two rows later it must answer "Does the company use digital claim settlement?" and, if yes, "list the names of the vendors providing third-party data and algorithms used in the digital claim settlement process."

The regulator is told, by name, every year, under attestation. The claimant is not a recipient of any of it.

The same data call now defines a claim with no human being in it. A "Digital Claim" is one where "the entire claim was handled without human intervention on the part of the insurance company", and, in the source's own words including its missing space, "No human inspection or appraisal of the damaged property isconducted by the insurance company, independent adjuster, or other person relied upon by the insurance company during the life cycle of the claim." From the 2026 reporting year, collision, comprehensive, property damage and uninsured motorist property damage claims are each broken out by whether they were digital, hybrid or non-digital. The category is being counted. The consumer is not told which category their claim is in.

Florida shows what a disclosure duty looks like when a legislature wants one

Florida Statutes section 626.854 governs public adjusters, the adjusters who work for the claimant (2025 statutes, read on 2026-09-02). It requires a written contract with the named insured; a cancellation notice whose words the statute dictates, in minimum 18-point bold type, opening "You, the insured, may cancel this contract for any reason without penalty or obligation to you within 10 days after the date of this contract"; an advertisement disclaimer in capitals reading "THIS IS A SOLICITATION FOR BUSINESS. IF YOU HAVE HAD A CLAIM FOR AN INSURED PROPERTY LOSS OR DAMAGE AND YOU ARE SATISFIED WITH THE PAYMENT BY YOUR INSURER, YOU MAY DISREGARD THIS ADVERTISEMENT."; compensation caps of ten and twenty per cent depending on whether the loss arises from a declared emergency; and a duty to provide "a written estimate of the loss ... within 60 days after the date of the contract" that must include "an itemized, per-unit estimate of the repairs, including itemized information on equipment, materials, labor, and supplies, in accordance with accepted industry standards."

That is a legislature that knows exactly how to write a consumer disclosure obligation onto an adjuster, down to the type size.

The same section does reach the other side, once. Subsection (14) requires a "company employee adjuster, independent adjuster, attorney, investigator, or other persons acting on behalf of an insurer" to give at least 48 hours notice before scheduling a meeting with the claimant or an onsite inspection. But subsection (19) limits subsections (5) through (18) to residential property insurance policies and condominium unit owner policies. None of it reaches an automobile collision claim.

The rule the last pass could not read

Florida Administrative Code Rule 69B-220.201, "Ethical Requirements for All Adjusters and Public Adjuster Apprentices", is the single most likely home in Florida law for a duty to identify oneself to a claimant. An earlier pass could not read it, because flrules.org serves it only as a Word binary.

We read it this time. The file is served at flrules.org with HTTP 200 as application/msword, 29,696 bytes (read on 2026-09-02). No converter available to us would render it, so we requested the raw bytes and decoded the document locally at its own host, using no archive and no mirror. That decode has since been repeated by a second, independently shaped retrieval of the same file, and the two decodes agree. The history note ends "4-21-25", matching the effective date on the rule's own metadata page, which is how we know we decoded the right document.

The rule binds all classes of adjuster expressly: "Adjuster," it says, "includes all types and classes of insurance adjusters, (company employee, independent, and public)". It sets a code of ethics requiring that "An adjuster shall put the duty for fair and honest treatment of the claimant above the adjuster's own interests in every instance." It forbids steering: an adjuster "shall not directly or indirectly refer or steer any claimant needing repairs or other services in connection with a loss to any person with whom the adjuster has an undisclosed financial interest, or who will or is reasonably anticipated to provide the adjuster any direct or indirect compensation for the referral", which is the closest thing in this record to a rule written for the collision-repair relationship. It also imposes detailed obligations about electronic estimating programs and about documenting any variation from the market prices those programs produce, but that paragraph closes "This paragraph only applies to residential coverage described in s. 627.4025(1), F.S."

What it does not contain is any requirement that a company employee adjuster or an independent adjuster tell the claimant which company employs them. On the flattened full text, the words "identify", "identification", "employer", "disclosure", "introduction" and "credential" do not appear at all, and the single occurrence of "disclos" is the "undisclosed financial interest" in the anti-steering paragraph. The same instrument found nine control strings we expected to be there.

Putting those together: we located no provision, in any instrument we read, requiring the person appraising your car to tell you whether they work for your insurer or for a contractor. The scope of that negative is exactly the Florida statute and administrative rule described above and a national data call. It is an absence of a located requirement, not a finding of absence, and it must never be published as one.

Sedgwick's own answer to the question is instructive and is not nothing. Asked "How do I identify myself to the policyholder once on-site?", its virtual inspector FAQ answers: "On arrival at an assigned loss location, you will be required to provide an introduction and proof of identification (state issued DL)." A driver's licence identifies the person. It does not identify the employer.

What we could not verify, and the walls

Recorded with dates, not worked around.

Cut as unreadable at source. The dollar amount the district court awarded in the Farmers litigation. The served text renders it with the digits missing, at every retrieval.

Not established. Whether the overtime rider was in force during fiscal year 2025. Whether it is permanent or annual in legal effect: the enacted text carries no sunset clause, the Department of Labor declines to answer it and refers employers to the appropriations law for the period, and we found no decision on the question. Whether FEMA has revised the adjuster fee schedule since 29 September 2023: the bulletin index we read lists twelve later bulletins, none of whose titles mentions a fee schedule revision, but we did not page the index and searched no archive.

Not established, and it is the discipline that holds the rest of this piece up. No document ties any individual adjuster's pay to a closing ratio, a cycle-time target or a file count. That would be the sharpest claim available here. We do not make it.

Walls and limits, tested 2026-09-02. All outbound direct fetching from our own shell is refused by an egress gateway in this environment, which answers 403 to the CONNECT for every host; every document here therefore came through hosted fetchers, and that is a tool limit, not a site behaviour. caselaw.findlaw.com returned no content on repeated attempts and is recorded as a hard wall on this pass; Robinson-Smith, Roe-Midgett and Bell were read instead at openjurist.org, and Yi at law.resource.org. A guessed law.resource.org path for Roe-Midgett returned 404, and a guessed openjurist path built on a wrong reporter citation for Robinson-Smith also returned 404; those are bad guesses, not walls. We did not establish whether Robinson-Smith has subsequent history; openjurist's own citator reports no negative treatment, which is a secondary signal and not a holding. courtlistener.com is a recorded robots wall and was not fetched; leagle.com and vlex are recorded paywalls and were not attempted.

Sources

All read on 2026-09-02.

• Consolidated Appropriations Act, 2026, Public Law 119-75, Div. B, Tit. I, Sec. 108, 140 Stat. 253-254. https://www.govinfo.gov/content/pkg/PLAW-119publ75/html/PLAW-119publ75.htm
• Further Consolidated Appropriations Act, 2024, Public Law 118-47, Div. D, Tit. I, Sec. 108, 138 Stat. 644-645. https://www.govinfo.gov/content/pkg/PLAW-118publ47/html/PLAW-118publ47.htm
• Consolidated and Further Continuing Appropriations Act, 2015, Public Law 113-235, Div. G, Tit. I, Sec. 111, 128 Stat. 2465-2466. https://www.govinfo.gov/content/pkg/PLAW-113publ235/html/PLAW-113publ235.htm
• Full-Year Continuing Appropriations and Extensions Act, 2025, Public Law 119-4, Div. A, Tit. I, Sec. 1101(a)(8). https://www.govinfo.gov/content/pkg/PLAW-119publ4/html/PLAW-119publ4.htm
• US Department of Labor, Fact Sheet 72A, Major Disaster Claims Adjusters Under the Fair Labor Standards Act, May 2026. https://www.dol.gov/agencies/whd/fact-sheets/72a-flsa-major-disaster-claims-adjusters
• US Department of Labor, Fact Sheet 17L, revised September 2019. https://www.dol.gov/agencies/whd/fact-sheets/17l-overtime-claims-adjusters
• NAIC, Market Conduct Annual Statement Ratios 2025, Version 2025.0.4, pages 27 to 28. https://content.naic.org/sites/default/files/inline-files/MCAS%20Annual%20Statement%20Ratios%202025.0.4.pdf
• NAIC, P&C MCAS Private Passenger Auto Data Call and Definitions, Version 2026.0.0. https://content.naic.org/sites/default/files/inline-files/MCAS%20Instructions%20PPA%202026.0.0%20%20APPROVED%20DRAFT.pdf
• FEMA Bulletin W-23013, NFIP Adjuster Fee Schedules, FY2024 Revision, 29 September 2023. https://agents.floodsmart.gov/sites/default/files/bulletins/W-23013/w-23013.pdf
• Robinson-Smith v. Government Employees Ins. Co., D.C. Cir., Nos. 08-7146 and 08-7147, 590 F.3d 886, 5 January 2010. https://openjurist.org/590/f3d/886
• Roe-Midgett v. CC Services, Inc., 7th Cir., No. 06-3195, 512 F.3d 865, 4 January 2008. https://openjurist.org/512/f3d/865
• In re Farmers Ins. Exch. Claims Representatives' Overtime Pay Litig., 9th Cir., 481 F.3d 1119, filed 26 October 2006, amended 30 March 2007. https://law.justia.com/cases/federal/appellate-courts/F3/481/1119/544288/
• Bell v. Farmers Ins. Exchange, Cal. Ct. App. 1st Dist. Div. 1, Nos. A096721, A097810, A098799, 9 February 2004. https://caselaw.findlaw.com/court/ca-court-of-appeal/1445739.html
• Harris v. Superior Court, Supreme Court of California, No. S156555, 29 December 2011. https://scocal.stanford.edu/opinion/harris-v-super-ct-34045
• Yi v. Sterling Collision Centers, Inc., 7th Cir., No. 06-2645, 480 F.3d 505, 13 March 2007. https://law.resource.org/pub/us/case/reporter/F3/480/480.F3d.505.06-2645.html
• Fla. Stat. 626.854 (2025), public adjusters. https://law.justia.com/codes/florida/title-xxxvii/chapter-626/part-vi/section-626-854/
• Fla. Admin. Code R. 69B-220.201, served as a Word binary and decoded locally. https://www.flrules.org/gateway/ruleNo.asp?id=69B-220.201
• Crawford, catastrophe adjuster FAQ. https://www.crawco.com/cat/faq
• Sedgwick, virtual inspector FAQs. https://www.sedgwick.com/wp-content/uploads/2024/01/Virtual-inspector-FAQ.pdf

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