Roofing Insurance Laws in Maryland

Authority

No controlling authority. Proposed MIA Bulletin 25-XX, Depreciation of Labor for Claims Settled on an ACV Basis (comment deadline May 30, 2025), takes the position that depreciating labor as a general business practice is an unfair claim settlement practice under Md. Code Ann., Ins. Sec. 27-304(6). The bulletin remains in proposed status and is non-binding. SB 52 (2026 Reg. Sess.) would have amended Ins. Secs. 19-118, 19-217, 27-303, and 27-304 to fix the ACV calculation method. It was not enacted. Schreiber v. Pacific Coast Fire Ins. Co., 75 A.2d 108 (Md. 1950), adopts the broad-evidence rule for ACV but does not reach labor depreciation.

MIA Proposed Bulletin 25-XX, Depreciation of Labor for Claims Settled on an ACV Basis (draft, comments due May 30, 2025) · MIA Proposed Bulletins and Comments page (bulletin still in proposed status) · Maryland General Assembly - SB0052 (2026) bill status and details

Authority

MIA Bulletin No. 97-1, Aluminum Siding Claims (Aug. 4, 1997), interprets former Md. Code Ann., Art. 48A Sec. 230A, recodified as Md. Code Ann., Ins. Sec. 27-303. Insurers whose practices fail to take into account major differences in color shades, textures, or siding dimensions may face regulatory action. The bulletin expressly declines to read a replacement cost policy as requiring replacement of all siding in every instance. Two qualifications for roofing. The guidance is siding-specific; Maryland has no roof-specific matching statute, regulation, or bulletin, so applying it to undamaged roof slopes rests on analogy to the same unfair-claims statute. And even where the rule applies, a diminution-in-value payment can satisfy it, so full-slope replacement is not automatically compelled. COMAR 31.15.07.03, the parallel unfair claim settlement practices regulation, contains no matching provision.

MIA Bulletin No. 97-1 — Aluminum Siding Claims (Maryland Insurance Administration, official .gov PDF; verified text and quotes) · Md. Code Ann., Insurance Sec. 27-303 — Unfair Claim Settlement Practices (official Maryland General Assembly statute text; successor to former Art. 48A Sec. 230A)

Authority

Md. Code Ann., Ins. Sec. 27-407.2 (Compensation for deductible) makes it a fraudulent insurance act for a contractor offering home repair or remodeling services for damage to a private residence to directly or indirectly pay, compensate, or offer or promise to pay an insured for any part of the deductible, with intent to defraud the insurer, where payment for the services will come from policy proceeds. Penalties run through Md. Code Ann., Ins. Sec. 27-408. Two qualifications. Section 27-407.2 carries an intent-to-defraud element and applies where the repair is paid from policy proceeds. It does not itself prohibit advertising the offer, and Maryland has no deductible-specific advertising ban; a "we'll pay your deductible" pitch is instead reachable under the Home Improvement Law's prohibited-inducement rules at Md. Code Ann., Bus. Reg. Sec. 8-503 and general deceptive trade practices law.

Md. Code, Insurance § 27-407.2 (Maryland General Assembly official statute text, .gov)

Authority

Md. Code Ann., Ins. Sec. 10-401(g)(1) defines a public adjuster to include a person who, for compensation, acts or aids on behalf of the insured in negotiating for or effecting the settlement of a first-party property claim, or who solicits employment as or holds out as a public adjuster. Section 10-403(a) requires a license before acting as a public adjuster in the State; Sec. 10-403(b) provides that marketing on behalf of a licensed public adjuster does not itself require a license. Section 10-402 lists seven exemptions and none covers contractors; item (5) reaches only a person employed to obtain facts surrounding a loss or furnish technical assistance to a public adjuster, such as a photographer or estimator. Acting without a license is also a fraudulent insurance act under Sec. 27-405(a)(1), and investigating or adjusting claims on another's behalf implicates Sec. 4-205(b)-(c)(6)(vii), (ix), with civil penalties of $100 to $50,000 per violation under Sec. 4-212. The permitted and prohibited acts above come from the MIA Insurance Advisory for Home Improvement Contractors and Salesmen, which states that contractors may prepare an estimate of the loss, discuss it with their customer, and answer the insurance company's questions about the estimates, and may not prepare the claim, investigate or adjust it, negotiate it with the carrier, advise on coverage, or advertise that they can do so. In the Matter of Taylor Made Custom Contracting, Inc. & Kevin K. Taylor, Case Nos. MIA-2023-08-017/018 (Aug. 17, 2023), an MHIC-licensed contractor used an Insurance Claim Authorization and Declaration of Contractor of Choice authorizing him to estimate the damage, negotiate the claim amount, and receive all payments. The MIA found violations of Secs. 27-405(a)(1), 10-403(a), and 4-205(b)-(c), ordered him to cease public adjusting, and imposed a $2,000 administrative penalty. The order does not fault him for preparing or sending his own repair estimate to the carrier; the violation was assuming authority to negotiate the settlement for the insured.

Md. Code Ann., Ins. § 10-401 (definitions, incl. "public adjuster" at (g)(1)) — Maryland General Assembly official statute text · Md. Code Ann., Ins. § 10-402 (scope/exemptions — no contractor carve-out) · Md. Code Ann., Ins. § 10-403 (public adjuster license required; (c) misdemeanor, $500 and/or 6 months per violation) · Md. Code Ann., Ins. § 27-405 (fraudulent insurance act — acting as an unlicensed public adjuster) · Md. Code Ann., Ins. § 27-408 (criminal penalties; (c) administrative penalty up to $25,000 per act) · Md. Code Ann., Ins. § 4-205 (unauthorized transaction of insurance business; (c)(6)(vii) investigating or adjusting claims) · Md. Code Ann., Ins. § 4-212 (civil penalty $100–$50,000 per violation) · Maryland Insurance Administration — Insurance Advisory for Home Improvement Contractors and Salesmen (may prepare an estimate of the loss and answer the insurer's questions about it; may not negotiate the claim) · MIA Order, In the Matter of Taylor Made Custom Contracting, Inc. & Kevin K. Taylor, Case Nos. MIA-2023-08-017 / 018 (Aug. 17, 2023) · Maryland Insurance Administration — Public Adjuster consumer page