Maryland Total Loss Valuation Disputes


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Maryland uses a 75% Total Loss Threshold under Md. Code § 13-506. A "salvage vehicle" is one whose repair cost (parts and labor) exceeds 75% of the fair market value of the vehicle immediately before the damage (Total Loss Appraisals – Maryland).

Detailed adjustment rules under COMAR 31.15.12. Maryland's claim-handling regulations at COMAR 31.15.12 are unusually specific (ATAS Law – How to Determine the Total Loss Value of a Vehicle):


  • 10-day offer rule. An offer on a total loss must be made within 10 days of the insurer accepting liability (COMAR 31.15.12.02).
  • Minimum offer methods. COMAR 31.15.12.04 requires the insurer's minimum offer to be calculated by one of four NAIC-model-style methods, with documentation.
  • Deduction discipline. Any deductions (betterment, prior damage) must be measurable, discernible, itemized, and specified as to dollar amount.

MIA Bulletin 24-8 extends to UM/UIM. The Maryland Insurance Administration's Bulletin 24-8 (April 12, 2024) confirmed that statutorily required UM/UIM property damage coverage extends to value damages including diminished value, which "cannot be contractually removed or limited." The bulletin's reasoning is relevant in total-loss disputes where UM/UIM is the recovery path.

Framework summary

Element Maryland rule
Test TLT (75% of FMV)
Statutory authority Md. Code § 13-506; COMAR 31.15.12
Offer deadline 10 days from acceptance of liability
Statute of limitations (property damage) 3 years
Required documentation Itemized betterment; documented deviation from NAIC methods

Practical Implications

  • A Maryland insurer that produces an undocumented CCC ONE valuation may be in technical breach of COMAR 31.15.12 regardless of the dollar amount.



  • The 10-day offer rule is a powerful tool — late offers can be the foundation for a complaint to the Maryland Insurance Administration.


  • Maryland's UM/UIM coverage now responds to value damages post-Bulletin 24-8, making first-party paths viable.
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Maryland Total Loss Valuation Disputes