Can a COI List Lower Limits than the Umbrella?

An insured has a $5-million limit on their umbrella policy but wants to show only a $2-million limit on the certificate of insurance.

Q: Is it permissible for us, as the agent, to list lower limits on the COI than what the policy actually provides?

Response 1: My advice is to show the correct limits or don’t show them at all.

Response 2: No, it is not permissible. COIs are required to be accurate and true to the actual coverage.

Response 3: Don't do it.

Response 4: No—that’s a misrepresentation of coverage. Either don’t show the excess on the COI, or show the excess with the actual policy limit.

Response 5: According to New York Insurance Law Section 502(c), “A certificate of insurance shall not amend, extend, or alter the coverage provided by the insurance policy to which the certificate of insurance makes reference.”

At the very least, someone could argue that showing a limit on a COI that is not on the policy declaration page is “amending” or “altering” the coverage, even if the policy actually provides more coverage than is listed. That’s a regulatory hassle you don’t need as an agent.

Response 6: The COI should certify the limits shown on the dec page.

Response 7: I recommend extreme caution in placing any information on a COI that is inconsistent with the provisions and details of the policies it refers to. Explain to the insured that in the event of a claim, the true limits will be revealed, anyway.

Response 8: The COI must show the limits that are on the policy. Altering the limits from what the policy shows, or changing any other information between the policy and the COI, is illegal in most states.

Response 9: This sounds misleading to me. What do you call a statement made with the knowledge that it isn't true? If you can get your insurance company to sign off on it, I suppose it's OK, but I find it ethically troubling.

Response 10: According to ACORD, you should show the limits on the dec page.

Response 11: The standard is you show the policy limit—not what the client wants you to show.

Response 12: If you list the umbrella on the COI, you must show the accurate limit. Issuing a COI and showing an inaccurate limit is a violation of your ACORD licensing agreement. Consult the ACORD website for instructions on handling these situations.

This question was originally submitted by an agent through the VU’s Ask an Expert Service, with responses curated from multiple VU faculty members. Answers to other coverage questions are available on the VU website. If you need help accessing the website, request login information.