AF recently facilitated its latest filer/responder workshops on September 22 and 24, with 175 member company representatives in attendance. The purpose of these workshops is to drive decision quality by:   

• Sharing information to improve filing and responding effectiveness.   
• Answering questions attendees have regarding filing and responding workflows and procedures.   

The following are key takeaways from the September workshop:   

Itemizing Damages

• There is no AF rule requiring that the recovering company correctly itemize its damages.
• Even without a rule, itemizing damages correctly helps the arbitrator.
• If your damages filing needs explanation, it may be done during the filing process in the Damages Justification/Dispute Rebuttal in the Feature Damages section, or upon revisit.
• Properly itemizing damages ensures the case is heard by the most qualified arbitrator based on the damage type.

Policy Limits and Additional Exposures

• When there are additional exposures of unknown amounts and policy limits may be at risk, a responding company should request a deferment.
• In the case of an additional exposure of unknown amounts, an arbitrator will not normally speculate on tens of thousands of dollars.
• A deferment may be requested at any point during the response. 
• A deferment may be requested by either party after the case is submitted, but before it is assigned to hearing.
• Deferments may be withdrawn at any time by the company that requested it.
• The arbitrator cannot see anything other than the deferment justifications and evidence attached to the deferment section at a deferment hearing.

• When responding to an arbitration, review the recovering party’s damage evidence.
• Evidence may have been submitted that was not submitted during the subrogation process. 

• Rule 2-1 requirement for shared evidence only applies to damage evidence in the Auto Forum. 
• When evidence is attached to the Feature Damages section, it is automatically shared with the other parties in the Auto Filing.

• Please be mindful when submitting graphic evidence. 
• Kindly include an advisory statement in your liability arguments and include a disclaimer cover sheet as the first item of any graphic evidence to alert the arbitrator to the nature of the content.