Language patterns suggesting bad faith
- Generic boilerplate without fact specificity
- Contradicts carrier's own prior communications
- Uses exclusions inconsistently (pattern evidence)
- Omits material facts favoring coverage
- Cites wrong policy (wrong policy year, wrong endorsement)
Procedural failures suggesting bad faith
- Missed 627.70131 deadlines
- Documents requested but carrier already had them
- Multiple RFI cycles on already-provided documentation
- Lengthy reassignments without communication

Factual pretext indicators
- Damage characterized differently from prior communications
- Cause-of-loss changed without new evidence
- Scope position contradicts field-adjuster's initial findings
- Expert report contradicts other experts' findings
Pattern evidence
- Similar denials across multiple insureds
- Consistent pretextual language
- Engineer report shopping documented
- Carrier's prior regulatory findings

Using indicators in escalation
CRN filing
- Specific indicators cited as statutory violations
- Fla. Stat. 626.9541 categories
- 60-day cure window
Bad-faith litigation
- After CRN cure period
- With first-party counsel
- Statutory and common-law theories
DFS complaint
- Pattern documentation
- Regulatory inquiry trigger

