Comment from Anonymous

I previously worked in the insurance industry and was directly involved in the development and implementation of a “smart estimate” AI tool created by CCC and deployed by The General Insurance. During the tool’s assessment and rollout, I reviewed its performance, provided data to leadership, and raised concerns that its estimates were inaccurate and could result in customers receiving payments that were lower than what they were entitled to under their policies. I also warned that continued reliance on the tool could expose the company to regulatory action or litigation. My concerns were not meaningfully investigated. Instead, I was reprimanded for raising them, and my opportunities for advancement effectively ended. This creatively avoided email or written correspondence as usual. Over the following months, I observed the tool being used extensively on claims involving customers who elected to receive cash payments rather than complete repairs through a shop. This was particularly concerning because The General serves a non-standard insurance market, where a comparatively high percentage of customers may accept a cash settlement without challenging the amount or understanding whether the estimate fully accounted for the covered damage. Without validating improved accuracy or any concern pertaining to our fiduciary responsbility this program was constant being pushed to represent a higher percentage of claims and being rolled out to higher volume states because of the money saved, without any concern for accuracy. Towards the end upwards of 5% of total claims volume was handled by AI. In my experience, many of these customers accepted payments that were substantially lower than the reasonable cost of repair. I believe the company knew, or should have known, that the estimating process was producing inaccurate or incomplete claim valuations. For a significant period, the company did not routinely audit these files in a manner that would have identified the full extent of the underpayments. Based on what I witnessed internally, this lack of auditing was not accidental. The reduced claim payments were treated as a financial and operational success, and projected costs and staffing levels were adjusted based on those results. Auditing of some files was introduced later, but only after the tool had already been used for an extended period. The tool’s reported financial performance was also presented as a success story by CCC and by leadership at The General. Certain leaders received substantial bonuses and career advancement connected to the program’s results, while I experienced retaliation and professional harm after raising concerns about its accuracy and potential impact on customers. I am submitting this information because I believe the FTC should investigate whether CCC and The General knowingly developed, promoted, or used an automated estimating system that systematically undervalued insurance claims, particularly for financially vulnerable customers who were less likely to dispute a cash settlement. I also believe the FTC should review the companies’ internal testing, audit practices, executive communications, incentive structures, customer complaint data, and any analysis comparing the tool’s estimates with actual repair costs.