The broker's side of the COI: why requests pile up and how to answer deficiency notices

Where the load comes from

A contractor client with a dozen active jobs may answer to a dozen GCs, each with its own insurance exhibit, its own certificate holder name and its own idea of what proof looks like. Every new job, every renewal and every change in a GC's requirements produces another round of requests.

The requests come in three kinds:

1. Certificates for a new project or a new certificate holder.
2. Endorsements, because the GC has learned that a checked box isn't proof. See additional insured.
3. Deficiency notices, when the GC's review finds something that doesn't match.

The third kind is the expensive one. Each notice means reading the GC's requirement, comparing it with the policy, and either fixing the coverage, fixing the paper, or explaining why the requirement is already met.

The repeat deficiencies

Most notices fall into a few categories. Knowing them is most of the cure.

• Missing endorsement. The certificate shows a Y for additional insured or waiver of subrogation, and the GC asks for the form. Fix: send the endorsement with every certificate, by default.
• Missing completed operations. The client has an ongoing operations endorsement and nothing for completed operations. Fix: check whether the policy carries a completed operations form, ISO CG 20 37 or an automatic form like CG 20 39 or CG 20 40, or the carrier's equivalent. See completed operations.
• Limits below requirement. The GC's exhibit asks for more than the policy has, often on the umbrella. Fix: an umbrella increase, or a conversation with the GC about whether the limit is negotiable.
• Wording requirements. Primary and noncontributory, per project aggregate or a waiver on workers' comp that the policy doesn't carry. Fix: add the endorsement if the carrier will, or say plainly that it isn't available.
• Names and dates. A wrong certificate holder name, an insured name that doesn't match the subcontract, or a policy that has expired. Fix: a clean master record per client and per GC.

The limits wording change

The 2025/12 ACORD 25 adds language saying limits shown are inclusive of amounts requested by the certificate holder and may not reflect policy limits above those amounts, Big I New York reported. ACORD described the language as permissive, not mandatory, according to IIABA. Big I New York and the national Big I recommend continuing to show the limits in the policy declarations.

For a broker, the practical point is consistency. Pick an agency practice, follow it on every certificate, and be ready to explain it when a GC asks why a certificate shows a different number than last time.

Getting ahead of the notices

1. Keep a per-client endorsement library. Every endorsement on every policy, with form number and edition date, ready to attach.
2. Keep a per-GC requirements file. When a client works for the same GC again, you already know the exhibit.
3. Compare before you issue. Read the GC's exhibit against the policy before you send the certificate, and flag what won't pass to the client, not the GC.
4. Send the package, not the page. Certificate plus every endorsement the exhibit requires, in one send.
5. Answer deficiencies in the GC's terms. Quote the requirement, then show the form or the policy wording that meets it.

Our deficiency workflow describes the same loop from the GC's side.