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name: insurance-certificate-compliance language: en description: > Produces requirement-by-requirement CRE insurance certificate compliance reviews by analyzing ACORD 25 certificates and endorsements against Access Agreement terms. Use when the user mentions COI review, insurance compliance, ACORD 25 analysis, Additional Insured verification, primary/non-contributory status, waiver of subrogation, vendor insurance audit, CGL compliance, umbrella follow-form, broker-ready deficiency instructions, certificate holder vs. additional insured, AI endorsements (CG 20 10, CG 20 37), or carrier rating checks.

CRE Insurance Certificate Compliance Review

Analyzes ACORD 25 certificates and endorsement copies against Access Agreement insurance requirements. Produces a compliance determination with broker-ready corrective instructions.

Cardinal rule: A COI is an informational snapshot only — it does not amend, extend, or alter coverage.

Intake

Gather before drafting (unless user says "use defaults" or "just draft"):

1. Executed Access Agreement — all exhibits, insurance schedules, riders
2. Certificates of insurance — ACORD 25; separate forms for auto, WC, umbrella, professional, pollution
3. Endorsement copies — AI (CG 20 10, CG 20 37), primary/non-contributory, waiver of subrogation
4. Broker contact details
5. Project description — scope, dates, locations, hazard level

Defaults if no response: Review against standard CGL/auto/WC/umbrella; flag missing endorsements as non-compliant; produce deficiency instructions for all gaps.

If endorsements are missing, request them. If user insists on proceeding, label the review as preliminary with all conclusions conditional.

Step 1: Build Verification Matrix

Extract the Agreement's insurance clause into testable requirements:

Category	What to extract
Coverage lines	CGL, auto, WC/EL, umbrella/excess, professional, pollution, cyber
Limits	Per-occurrence, general aggregate, products/completed-ops aggregate, CSL, EL
Aggregate structure	Per-project, per-location, or policy-level
Additional Insured entities	Exact legal names with entity suffixes (owner, manager, lender, affiliates)
AI scope	Ongoing only vs. ongoing + completed operations
Required endorsement forms	Specific ISO form numbers or "or equivalent"
Primary & non-contributory	Required on which lines
Waiver of subrogation	Required on which lines
Carrier rating	AM Best minimum (typically A- VII)
Cancellation notice	Days' notice, to whom
Deductible/SIR caps	Maximum amounts
Occurrence vs. claims-made	Which lines must be occurrence form

Pitfalls: Missing completed-operations AI requirement; entity name mismatches (e.g., "ABC Management" vs. "ABC Management, LLC"); assuming umbrella follows form without proof.

Step 2: Review ACORD 25

Field	Verify
Named Insured	Matches Recipient entity exactly (legal name + suffix)
Policy dates	Spans entire access period
CGL form type	"Occurrence" if contract requires it
CGL limits	Per-occurrence, general aggregate, products/completed-ops
Aggregate applies per	Project/location if required (not just "Policy")
Auto	"Any Auto" or required symbols; CSL meets minimum
WC/EL	Statutory WC; EL limits; no excluded officers performing work
Umbrella/Excess	Limits stack to contract total; follows form to required lines
Certificate Holder	Being listed as Certificate Holder does NOT grant AI status

Step 3: Verify Additional Insured Status

1. Confirm exact AI entities required (including affiliates language)
2. Determine endorsement type:
   • Blanket ("when required by written contract") — needs executed contract + endorsement copy
   • Scheduled (named entities) — confirm schedule lists correct names
3. Verify scope:
   • Ongoing only (CG 20 10) vs. ongoing + completed (CG 20 10 + CG 20 37)
   • "Caused in whole or in part" vs. vicarious liability only — varies by edition
4. No endorsement copies = non-compliant — issue deficiency notice requesting AI endorsements for entities listed in the Agreement

Step 4: Verify Remaining Requirements

Primary & Non-Contributory:

• Separate from AI status — AI does not automatically mean primary
• COI narrative alone insufficient; require endorsement or policy provision
• Confirm not overridden by umbrella "other insurance" clause

Requirement	Verification
Waiver of subrogation	Endorsement on each required line — COI checkbox insufficient
Umbrella AI	Confirm umbrella recognizes AI status; request declarations + endorsement
Carrier rating	AM Best confirmation or broker attestation
Cancellation notice	ACORD 25 standard language confers no notice rights; require endorsement
Deductible/SIR	Request declarations or broker letter; flag credit risk for large SIRs
Description of Operations	Check for exclusionary language (geographic limits, activity exclusions)

Step 5: Produce Compliance Determination

INSURANCE COMPLIANCE REVIEW
[Privileged and Confidential — Attorney-Client Communication]

Project: [Name/Address]
Recipient: [Entity]
Agreement Date: [Date]
Review Date: [Date]
Assumptions Used: [list]
Open Items / Needed Inputs: [list]

DETERMINATION: [Compliant / Non-Compliant / Conditionally Compliant]

REQUIREMENT-BY-REQUIREMENT ANALYSIS:
| # | Requirement | Contract Ref | Status | Evidence | Deficiency |
|---|---|---|---|---|---|
| 1 | CGL $1M occ / $2M agg | §[X] | Compliant | COI shows matching limits | — |
| 2 | AI - ongoing + completed ops | §[X] | Non-Compliant | No endorsement provided | Provide CG 20 10 + CG 20 37 |

BROKER INSTRUCTIONS:
[Numbered corrective actions with exact document requests]

ESCALATION ITEMS:
[Issues requiring attorney or coverage counsel review]

Drafting rules: Use "unable to verify" not "coverage will be denied." Distinguish: "confirmed" / "indicated but not verified" / "not shown — non-compliant."

Jurisdiction Flags

Jurisdiction	Issue	Action
New York	Labor Law §§240/241 strict liability (gravity injuries)	Check for "Labor Law"/"Heights"/"Action Over" exclusions; escalate to coverage counsel
Texas	Anti-Indemnity Act (Ins. Code Ch. 151)	Flag if access involves construction/alteration/repair
California	Civil Code §2782 limits risk-shifting (active negligence)	Confirm indemnity + AI requirements are consistent
Florida	Fla. Stat. §627.4137 claimant rights	Note if potential claim identified

Flag state-law issues for local counsel. Do not assert universal rules about certificate legal effect.

Post-Draft Checklist

After delivering the review, ask:

1. Does the determination match your understanding of coverage posture?
2. Additional entities to verify as AI?
3. Any deficiencies to escalate to coverage counsel instead of broker?
4. Follow-up check needed after broker cures?

Quality Audit

Before finalizing:

• Every Agreement requirement mapped to a testable check
• Requirement table complete with status for each coverage line
• Entity names compared character-by-character (LLC, Inc., LP suffixes)
• No compliance finding based solely on COI without endorsement verification
• Broker instructions are specific (not generic "provide adequate coverage")
• Jurisdiction flags included where applicable
• Assumptions and open items listed prominently
• Every assertion traceable to a document or labeled as assumption
• Disclaimer: not a coverage opinion; requires licensed attorney review

Guardrails

• COI ≠ coverage: Never approve compliance based solely on a certificate
• Entity names must match exactly — mismatches defeat AI coverage at claim time
• No coverage opinions: Compare contract requirements to documentary evidence only
• Privilege: Confirm with supervising attorney; third-party sharing may waive privilege
• Anti-hallucination: Do not invent policy terms or coverage conclusions; use [VERIFY] for unconfirmed details
• Attorney review required: Every deliverable must disclaim that it requires licensed attorney review before reliance