Comment from Cataldo, Dennis

Comment on the Consumer Impact of AI-Generated Photo Estimates AI-generated photo estimates have the potential to create unintended consequences that extend beyond the repair process and directly affect a consumer's insurance rights and benefits. Because these estimates are based solely on visible damage, they often cannot account for hidden structural, mechanical, electronic, or safety-related damage that is only discovered after a comprehensive inspection and vehicle disassembly. As a result, an AI-generated estimate may significantly understate the true cost of restoring a vehicle to its pre-loss condition. This can influence important decisions made by both consumers and insurers. A consumer who receives an estimate that appears to be below, or only marginally above, their deductible may reasonably conclude that filing a claim is not worthwhile. After a proper repair inspection, however, the actual cost of repairs may be substantially higher, meaning the consumer may have unknowingly declined insurance benefits that would have been available under their policy. Similarly, if an insurer relies heavily on a preliminary AI-generated estimate, the understated repair cost could influence claim handling decisions, coverage evaluations, or other policy-related determinations. Regardless of whether these outcomes are intentional, consumers should not lose access to benefits, experience delays, or be placed at a disadvantage because an automated visual assessment failed to identify the full extent of collision damage. Consumers generally assume that an estimate provided through their insurer represents a reasonably complete assessment of the damage. If an AI-generated estimate is merely a preliminary visual assessment, that fact should be clearly and conspicuously disclosed. It should not be represented as a final repair estimate or used as the basis for claim settlement, repair decisions, or coverage determinations before a qualified collision repair professional has performed a physical inspection, researched applicable OEM repair procedures, and completed the necessary repair planning process. As artificial intelligence becomes more prevalent in the claims process, regulatory safeguards should ensure that these tools are used to improve efficiency without compromising consumer protections. AI should assist the claims process—not determine the scope of repairs, influence coverage decisions, or inadvertently deprive policyholders of benefits to which they may be entitled after a complete and proper vehicle inspection.