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What Roofers Can and Cannot Say on Insurance Claims (UPPA Lines, Word for Word)

Emily Crawford, Home Maintenance Editor··32 min readRoofing Technical Authority
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A homeowner stands in their driveway after a hailstorm, points at their roof, and asks you the question every storm rep hears fifty times a season: "Can you get my insurance to pay for this?"

The honest answer is yes, you can help, and no, you cannot say it that way. The gap between those two facts is where roofing companies get fined, get their contracts voided, and in a handful of states get reported to the department of insurance by a competitor who recorded your pitch. The rules that govern this gap are unauthorized public adjusting statutes, usually shortened to UPPA, and almost nobody on a roofing crew has actually read one.

That is the problem. The penalties are real and the line is narrow, but the line is also knowable. You can run a profitable storm-restoration operation, document damage thoroughly, write an accurate repair estimate, and hand it to a homeowner without ever stepping over it. What you cannot do is improvise. The reps who get a company in trouble are not villains. They are good salespeople who said the natural, helpful, customer-pleasing thing instead of the legal thing, because nobody ever taught them the difference.

What follows is the difference, spelled out the way a sharp owner or compliance manager would teach it on a Monday morning: the actual statutory line, the phrases that cross it word for word, the phrases that stay safe and do the same selling work, the documentation that is yours by right, and the workflow that keeps an entire sales team inside the lines even when the homeowner is begging you to step outside them.

What a UPPA statute actually says

Strip away the legalese and a public adjusting statute does one thing: it reserves the act of representing a policyholder against their insurer to people who hold a public adjuster license. The license exists because someone negotiating a settlement on a homeowner's behalf is handling that homeowner's money and legal interests, and the state wants that person bonded, tested, and accountable.

The definition of public adjusting is remarkably consistent across states. Texas Insurance Code Chapter 4102 is the version most often litigated, and its language is typical: a public insurance adjuster is a person who, for compensation, "acts on behalf of an insured in negotiating for or effecting the settlement of a claim," or who advertises or solicits business as someone who adjusts claims. The compensation can be direct, indirect, or "any other" form. That breadth matters and we will come back to it.

Three verbs sit at the center of nearly every UPPA definition:

  • Negotiate a claim on behalf of the insured.
  • Adjust a claim, meaning evaluate coverage and arrive at the amount the carrier owes.
  • Settle or effect the settlement of a claim.

If you do any of those three things for the homeowner, for money, without a license, you are public adjusting. If you do none of them, you are a contractor doing contractor work, and the statute does not reach you. Everything in this discipline comes down to staying clearly on the contractor side of those three verbs.

The three roles, and why a roofer can only hold one

An insurance claim has three legitimate professional roles, and the entire body of UPPA law exists to keep them from blurring.

Role Who they work for What they do License required
Company adjuster / independent adjuster The insurer Inspects, scopes, and decides what the policy covers and pays Adjuster license
Public adjuster The policyholder Negotiates the claim against the insurer for a fee, usually a percentage Public adjuster license
Contractor Themselves Inspects their own scope, documents damage, writes a repair estimate, performs the work Contractor / roofing license per state

You are the third row. Your job is to repair a roof and to document, accurately, what repairing it correctly requires. The moment your activity starts to look like the second row, working the claim on the homeowner's behalf against the carrier, you have a problem regardless of how good your intentions were.

The legally clean version of a storm job looks like this: the homeowner owns the policy and the claim, the insurer decides coverage, and you supply an accurate, well-documented estimate of what the repair costs. You are a fact witness about the roof and a vendor for the repair. You are not the homeowner's representative in a dispute with their carrier.

The case every roofer should know: Stonewater

In 2024 the Supreme Court of Texas decided Texas Department of Insurance v. Stonewater Roofing, and it is the most important UPPA decision a roofing operator can read, because the roofer lost on facts that a lot of companies consider normal marketing.

Stonewater advertised itself in ways that positioned the company as an insurance-claim expert acting for homeowners, and it challenged the public adjuster statute on free speech grounds, arguing that talking to an insurer is just speech. The court disagreed. It held that the statute does not regulate speech at all; it regulates acting in a representative capacity on behalf of an insured to negotiate or effect settlement of a claim. Calling yourself an "insurance specialist" or holding yourself out as the person who handles the claim was treated as evidence of stepping into that representative role, not protected commercial speech.

Two practical lessons come out of that ruling, and they should reshape how a storm company markets:

  1. The label matters. You do not have to negotiate a single claim to get in trouble. Advertising yourself as a claims specialist, an insurance expert, or the company that handles the insurance process can itself be the violation, because it is holding yourself out as a public adjuster. Words on your truck, your yard sign, and your website are evidence.
  2. "It's just speech" is not a defense. The activity the statute reaches, representing the insured in the claim, is conduct. Dressing it up as helpful conversation does not move it out of the statute's reach.

Texas is also unusual in that its code contains a provision, Section 4102.163, that addresses roofing contractors directly: a roofing contractor may not act as a public adjuster, and may not advertise to adjust claims, on any property where the contractor is providing or may provide roofing services, whether or not the contractor holds an adjuster license. In other words, in Texas you cannot solve the conflict by going and getting licensed. The roles are walled off from each other on the same job. Many states reach the same result through a general conflict-of-interest rule that bars a licensed public adjuster from also being the contractor on the claim they adjusted.

Texas is the sharpest example, not the only one. Roughly every state licenses public adjusters, and the contractor-cannot-adjust principle is close to universal even where the statute is less explicit. Treat the strict version as your house standard and you are compliant nearly everywhere you operate.

The do-not-say list

Here is the part reps actually need: the specific phrases that cross the line, why each one crosses it, and what to say instead that does the same selling work without the liability. Train these as muscle memory. The point is not to sound like a lawyer. The point is to make the safe version the natural version, the thing that comes out of a tired rep's mouth on the fourth door of a hot afternoon.

1. Anything that promises an outcome

Do not say: "I'll get your claim approved." "We'll get this covered." "Don't worry, they're going to pay for the whole roof."

Why it crosses: You are promising the result of a coverage decision that is the insurer's to make. You do not control it, you cannot guarantee it, and promising it positions you as the person working the claim to that outcome. It is also simply false, because you cannot know what an adjuster will decide.

Say instead: "What I can do is document everything I find and put it in an accurate estimate. Whether it's covered is your insurer's call, and they decide based on your policy and their inspection."

2. Anything about negotiating, fighting, or handling the claim

Do not say: "We'll handle the insurance for you." "We deal with the adjuster so you don't have to." "We fight the insurance company and win." "Leave the claim to us."

Why it crosses: Handling, dealing with, and fighting the carrier on the homeowner's behalf is the literal definition of public adjusting. This is the single most common violation in roofing sales, because it sounds like world-class customer service.

Say instead: "You file the claim and you stay in control of it. If your adjuster wants to walk the roof, I'm glad to be there to point out the damage I found and show my documentation, the same way any contractor would explain their scope."

Meeting the adjuster on the roof to point out damage you documented and to explain your own repair scope is contractor activity and it is fine. Speaking for the homeowner, arguing coverage, or treating the adjuster as your adversary in the homeowner's place is not.

3. Anything about the deductible disappearing

Do not say: "We'll waive your deductible." "We'll eat the deductible." "You won't pay anything out of pocket." "We'll work it so the deductible's covered."

Why it crosses: This is the one that turns a UPPA problem into a fraud problem. The deductible is the policyholder's contractual obligation to their insurer. Absorbing it, rebating it, or inflating the estimate to hide it is insurance fraud in most states and a specific criminal statute in many. It is not a gray area.

Say instead: "Your deductible is what you owe under your policy, and you'll pay it. I'll give you a clear, honest estimate so you know exactly what your number is." If a homeowner pushes, the firm answer is that a contractor who offers to make a deductible disappear is offering to commit fraud, and you do not do that.

4. "Free roof"

Do not say: "You could get a free roof out of this." "This storm means a new roof at no cost to you."

Why it crosses: It implies the deductible vanishes, it promises an outcome, and several states' attorneys general and insurance departments have explicitly warned that "free roof" advertising is deceptive. There is no version of an insured claim where the roof is free; the homeowner pays the deductible, and they paid premiums.

Say instead: "If your roof has covered storm damage, your policy may pay to repair or replace it, minus your deductible. That's the homeowner's benefit they've been paying premiums for."

5. Anything that interprets the policy or coverage

Do not say: "Your policy definitely covers this." "That's a covered peril, you're fine." "They have to pay because it's wind damage."

Why it crosses: Interpreting coverage and telling a homeowner what their policy obligates the insurer to do is adjusting. You are not the policy's interpreter. You also frequently do not have the policy in front of you, and coverage turns on endorsements, exclusions, and language you have not read.

Say instead: "I can tell you what I see on the roof and what an accurate repair costs. What your specific policy covers is between you and your carrier, and your declarations page and policy language control that."

6. Holding yourself out as a claims expert

Do not say (on trucks, signs, websites, business cards): "Insurance claim specialists." "We're your claims experts." "Storm claim professionals who get you paid."

Why it crosses: This is the exact issue in Stonewater. Advertising yourself as the person who handles claims for homeowners is holding yourself out as a public adjuster, full stop, before you ever touch a single claim.

Say instead: "Storm damage roofing specialists." "Hail and wind roof repair." "We document storm damage and write accurate repair estimates." Sell your roofing expertise and your documentation, not your supposed power over the carrier.

The list, at a glance

Don't say Why Say instead
"We'll get your claim approved." Promises a coverage outcome you don't control "I document everything; coverage is your insurer's decision."
"We handle / fight / deal with the adjuster." Representing the insured = public adjusting "You stay in control; I'll show my documentation if your adjuster walks the roof."
"We'll waive / eat your deductible." Deductible fraud in most states "Your deductible is what you owe; here's your exact number."
"Free roof." Implies waived deductible + deceptive advertising "Your policy may pay to repair covered damage, minus your deductible."
"Your policy covers this." Interpreting coverage = adjusting "I'll tell you what's on the roof; coverage is between you and your carrier."
"Insurance claim specialists" (on marketing) Holding out as a public adjuster "Storm damage roofing specialists."

Print this. Laminate it. Put it in the truck.

What you absolutely CAN do

Reading a do-not-say list makes new reps timid, and timid reps lose storm jobs to companies that are not timid and not compliant. So be just as clear about everything you are fully entitled to do, because it is most of the job.

You can:

  • Inspect the roof and the property and find storm damage. You are a roofing expert. Climbing the roof and identifying hail bruising, wind creasing, mat exposure, and granule loss is the core of your trade.
  • Document damage exhaustively. Photograph every slope, every test square, every soft metal hit on vents and flashing, every collateral hit on gutters, screens, AC fins, and outdoor surfaces. This documentation is yours to create and yours to share.
  • Write an accurate repair estimate, ideally in the same estimating platform the carriers use, aligned to local pricing. Telling a homeowner what it costs to repair their roof correctly is contractor work in its purest form.
  • Explain your own scope to anyone, including the homeowner and the adjuster: what you found, what you would repair, why a particular flashing detail or code item is part of a correct repair, and what it costs.
  • Be present when the adjuster inspects and point out the damage you found, the way any tradesperson explains their work. You are giving the adjuster information about the roof; you are not arguing the homeowner's coverage.
  • State facts about your scope and local building code. If your jurisdiction requires drip edge, ice-and-water shield to a certain point, or a specific number of fasteners, you can include and explain those code-required items because they are facts about how the roof must legally be built.
  • Hand the homeowner your estimate and your documentation so they can file and substantiate their own claim. The homeowner files. The homeowner is the policyholder. You gave them the facts.
  • Recommend that the homeowner involve a licensed professional for the claim itself: a licensed public adjuster if they want representation, or their own attorney. You can point them to the right help without becoming the wrong help.

That is a powerful, complete storm operation, and none of it requires a public adjuster license, because none of it represents the homeowner against the insurer. The difference between this and public adjusting is not how hard you work. It is who you are acting for and what you are claiming to control.

The mental test for any sentence

Before a rep says anything claim-adjacent, two questions settle it:

  1. Am I stating a fact about the roof, the repair, or the cost? If yes, you are almost certainly fine.
  2. Am I promising, interpreting, negotiating, or representing? If yes, stop.

"There's hail damage on all four slopes and the repair runs to a full replacement at this cost" is a fact about the roof and the cost. Safe. "They'll approve a full replacement" is a promise about a coverage decision. Not safe. Same roof, same job, one sentence keeps you compliant and the other ends careers.

The compliant storm workflow, end to end

Here is the sequence a clean storm job follows, written so a sales manager can drop it straight into onboarding. Each step names what you do and the line you stay behind.

Step 1 — Identify likely candidates. Find roofs that are both old enough to be due and were under the storm. This is a targeting decision, not a claim activity, and it is where most wasted effort happens because reps knock indiscriminately. A roof that is three years old and took pea-sized hail is not a job; a roof that is sixteen years old and sat under a confirmed two-inch hail swath is. Filtering for both age and exposure before anyone leaves the truck is the difference between a productive day and a demoralizing one.

Step 2 — Inspect and document. On the roof, run test squares on each slope, mark and photograph hits, photograph soft-metal collateral, and record date, address, and slope on every image. Your goal is a documentation package so complete that the facts speak without you having to argue anything.

Step 3 — Write the estimate. Produce an accurate, itemized repair estimate aligned to local pricing and including code-required items. This is your professional opinion of what the correct repair costs. It is not a demand on the carrier; it is a contractor's number.

Step 4 — Hand it to the homeowner. Give them the documentation and the estimate. Walk them through what you found, in facts. Make clear that they file the claim, they own it, and the insurer decides coverage. This is the compliance hinge of the whole job, and it should be explicit, not implied.

Step 5 — Support the inspection, as a contractor. When the adjuster comes out, be there to show the damage you found and explain your scope. You are a fact witness about the roof. You are not the homeowner's advocate in a negotiation.

Step 6 — If scope is missing, document it, don't argue it. If the adjuster's scope leaves out a code-required item or a clearly damaged component, the compliant move is to document the gap with evidence and pricing and give that supplemental documentation to the homeowner. The homeowner submits it. You supplied facts about the repair; you did not negotiate the claim. This is the heart of legitimate supplementing, and it is worth its own section.

Supplements without crossing the line

Supplementing is where good companies leave money on the table out of fear, and where reckless ones get in trouble. The compliant version is straightforward once you see the structure.

A supplement, done right, is additional contractor documentation showing that a correct repair requires more scope than the original estimate captured. The three legitimate reasons a roof needs more scope:

  1. Missing damage the original inspection did not capture (a slope skipped, collateral damage to a vent or skylight not scoped).
  2. Code-required items the law mandates for a correct, permitted repair that the estimate omitted (drip edge, ice-and-water coverage, ventilation, fastener counts that meet code).
  3. Conditions revealed during the work (decking rot found at tear-off, layers that change the scope).

For each, the compliant supplement is the same shape: identify the item, anchor it to evidence (a photo, a code citation, a manufacturer specification), price it at local rates, and put it in a clean package the homeowner can submit to their carrier. You are documenting what a correct repair requires. You are not telling the carrier what they owe.

The line is in the verbs again. "Here is photo evidence and the code citation showing this repair requires drip edge that wasn't in the estimate; this is its cost" is documentation. "You owe my client for drip edge and I expect you to pay it" is negotiating a claim on the insured's behalf. The first is your job. The second needs a license.

A quick discipline that keeps supplement managers safe: every line in a supplement should be defensible with evidence about the roof or the code, never with an argument about the policy. If a supplement item's only justification is "the policy should cover this," cut it or reframe it as a documented fact about the repair, because the policy argument is the carrier's and the homeowner's territory, not yours.

A worked supplement, line by line

Abstractions are easy to nod along to and hard to apply, so here is a concrete one. A carrier's initial estimate on a 28-square architectural-shingle roof comes back at, say, a number that scopes the field shingles, underlayment, and basic accessories but stops there. Your tear-off and your code knowledge tell you three things are missing. Watch how each becomes a compliant supplement line and how each could have become a violation.

Missing item The compliant documentation line The version that crosses
Drip edge on 180 linear feet of eave and rake "Code requires drip edge at eaves and rakes per IRC R905.2.8.5. Original estimate omits it. Photo and code citation attached; priced at local rate per linear foot." "You owe my customer for drip edge and the policy requires you to pay it."
Damaged ridge vent, 40 linear feet "Hail-damaged ridge vent documented in photos R-12 through R-15; replacement required to restore the assembly. Priced at local rate." "This is obviously covered, the adjuster missed it, get it approved."
Decking replacement, 4 sheets found rotted at tear-off "Concealed decking rot discovered at tear-off, photos D-1 through D-4 dated and addressed. Replacement of 4 sheets required to install per manufacturer specification. Priced at local rate." "We always find rot, just add it and they'll pay."

Every line in the left column is a fact about the roof, the code, or the manufacturer specification, anchored to a dated photo and priced at the going local rate, packaged for the homeowner to submit. Nobody told the carrier what they owe. Nobody promised an approval. The homeowner files the supplement; the carrier decides; you supplied the documentation. Do this on every job and your supplements get paid more often precisely because they are evidence, not arguments, and an adjuster has a much harder time waving off a photo and a code citation than a roofer's opinion.

One more discipline that separates pros from amateurs: price at the local rate, not an inflated one. Padding a supplement to recover a deductible or pad margin is the fastest way to turn a clean documentation package into a fraud exhibit. The credibility of the whole package depends on every number being defensible.

The craft of documentation that holds up

The quality of your storm operation is the quality of your photos and your scope notes, full stop. A thin file gives an adjuster every reason to scope conservatively; a thick, organized, fact-anchored file gives them very little to push back on. Here is what a documentation package built to hold up actually contains.

Per-slope test squares. Mark a 10-by-10 test area on each slope, count and circle the hits, and photograph the marked square with something for scale. This is the single most persuasive piece of hail documentation because it is repeatable and countable.

Soft-metal collateral. Hail leaves dents in soft metal that are hard to dispute: turbine and box vents, valley and step flashing, gutters, gutter aprons, downspouts, AC condenser fins, window screens, and metal fascia. Photograph these because they corroborate the date and severity of the event in a way shingle bruising alone does not.

Directionality. Photograph hits by slope orientation. Hail comes in on a vector, so damage concentrated on the north and west slopes that matches the storm's reported direction is consistent, documentable evidence the event caused it. This is a fact about the roof and the storm, squarely in your lane.

Date, address, and slope on every image. A photo with no metadata is an argument waiting to be lost. Every image should carry the property address, the date, and the slope it depicts. Loose, unlabeled photos are nearly worthless when scope is questioned weeks later.

A scope narrative in facts. A short written narrative that walks the reader from the storm event through the slope-by-slope findings to the required repair, citing the photos and code sections by number, turns a pile of images into a case. Keep every sentence a fact about the roof, the repair, or the code. The narrative is contractor documentation; it never argues coverage.

The payoff is twofold. First, a complete package gets supplements paid because it is hard to dispute. Second, a fact-only package keeps you compliant by construction, because if every line is an observation about the roof there is no room for a sentence that negotiates the claim.

State-by-state: the principle is universal, the specifics are not

Stonewater makes Texas the loudest example, but the contractor-cannot-adjust principle runs nationwide. Nearly every state licenses public adjusters, and the activity reserved to them, representing the insured to negotiate or settle a claim for compensation, is defined in close to the same words everywhere. Where states differ is in three details worth checking before you build a process.

  1. Explicit roofer provisions. A handful of states, Texas among them, write the roofing-contractor-cannot-adjust rule directly into the code. Most states reach the same outcome through a general conflict-of-interest rule that bars a licensed public adjuster from also being the contractor on the claim they adjusted. The result is the same; the citation differs.
  2. Assignment-of-benefits rules. Several states restrict or bar AOB specifically to stop contractors from using an assignment as a side door into claim handling. If any part of your process leans on AOB, confirm your state's current rule first, because what is routine in one state is prohibited in the next.
  3. Advertising and contract requirements. Some states regulate storm-restoration contracts directly: mandatory cancellation windows after an insurer's coverage decision, required disclosures, and bans on advertising to pay or absorb a deductible. These are easy to miss because they live in consumer-protection or contractor-licensing statutes rather than the insurance code.

The practical move is to adopt the strict version as your house standard everywhere, then layer your specific state's contract, advertising, and AOB rules on top. A roofer who can lawfully operate under the Texas reading can operate almost anywhere; a roofer who only knows the loose version of their home state is exposed the moment they cross a line into a stricter one or a competitor decides to make an example of them.

How RoofPredict keeps the documentation airtight and on the right side of the line

Everything compliant about a storm job is documentation: which roofs are genuinely candidates, what damage exists, what a correct repair costs, and where scope is missing. That happens to be exactly what RoofPredict is built to produce, and it is built so the output stays on the contractor-documentation side of the UPPA line rather than the claim-handling side.

Targeting, before anyone knocks. RoofPredict scores every home in a service area by roof-age band, from recent through mid-life to due and overdue, layers in per-roof storm exposure from hail and wind history, and produces a ranked target audience house by house, with a "why this home" evidence chain. For storm work that means you can filter to roofs that are both old enough to be real candidates and were actually under a confirmed storm swath, before a single rep leaves the truck. A sixteen-year-old roof under two-inch hail surfaces; the three-year-old roof under pea hail does not. Roof age is reported as a band, not an exact birthdate, and storm exposure is the odds a roof was hit, not proof of damage. That honesty is the point: you are targeting likelihood, then your inspection establishes the facts. The targeting is a marketing decision, fully on the contractor side of the line.

ROOFCLAIM, the documentation engine. This is the part that maps to the supplement workflow. RoofCLAIM takes the claim documents tied to a home, carrier and contractor estimates, photos, denial letters, invoices, and auto-classifies and OCRs them. Its opportunity detection compares the estimate's line items against a roofing knowledge base and flags missing scope, code-required items, and missed supplements, each with an evidence anchor and a local price. That is precisely the compliant supplement structure described above, item plus evidence plus cost, generated for you instead of assembled by hand. The recoverable-depreciation autopilot tracks the completion evidence and final-invoice checklist a homeowner needs to release depreciation. Deductible tracking keeps the homeowner's obligation visible and correct, never hidden or absorbed. Supplement aging and packet-completeness scoring tell you which documentation packages are ready to hand off and which are missing a photo or a code citation.

The design decision that matters for compliance: every template RoofCLAIM produces, supplement packets, depreciation-release letters, deductible invoices, missing-docs letters, audit reports, is locked and UPPA-gated and written as contractor documentation. It produces facts about the roof, the repair, and the code, anchored to evidence, for the homeowner to submit. It does not draft a negotiation, promise an approval, interpret coverage, or touch the deductible as anything other than the homeowner's stated obligation. The product is opinionated about the line on purpose, because the line is where roofers get hurt.

What a supplement manager actually does with it: upload the carrier estimate and the field photos, let the system flag that the estimate omitted code-required drip edge and a damaged ridge vent, review the flagged items and their evidence anchors, and export a clean supplemental documentation package, priced, that the homeowner submits to their carrier. The manager reviewed facts about the roof and the code. Nobody negotiated anything.

Turning compliant documentation into tracked, sold jobs

Documentation that sits in a folder does not close. The same platform carries a storm candidate from a ranked list to a won job without ever leaving the contractor side of the line.

The ranked due-and-storm-hit list becomes a tracked direct-mail campaign: personalized mail proofs with brand, copy, and address checks, vendor release, per-piece delivery and return tracking, and a cost quote up front, so a storm push is a measured campaign instead of a guess. Every targeted home gets a personalized report, roof profile, storm history, and the cost of waiting, as a PDF and a public microsite with a lead-capture form, plus per-home and lookup QR codes for the mail piece and the door hanger. The microsite sells your documentation and your roofing expertise, framed in facts, exactly the language the do-not-say list permits.

Field teams build door-knock routes from the same list, assign canvassers, and run a mobile app with next-stop routing, outcome forms, voice notes, leave-behind QR codes, and live route progress, so a storm sweep is organized instead of random knocking. Leads flow into a pipeline, new through contacting, appointment, inspected, and won or lost, with an immutable first-touch source, and sync two-way to thirteen CRMs including ServiceTitan, AccuLynx, JobNimbus, HubSpot, and Roofr, so the storm desk and the CRM never drift apart. The results funnel then shows delivered to views to form to calls to leads to wins, with cost per lead, cost per win, and actual versus estimate against an industry benchmark, so you know which storm campaigns actually paid.

None of that markets you as a claims handler. All of it markets you as the roofer with the best documentation in the market, which is precisely the position UPPA law leaves wide open.

Edge cases pros get wrong

"The homeowner asked me to talk to their adjuster for them." A homeowner inviting you to speak for them does not license you to do it. The statute is about the act, not about consent; you can be present and explain your own scope, but you cannot become their negotiator just because they asked. If they want a representative, the right answer is a licensed public adjuster or their attorney, and you can say so.

"I'm only helping, I'm not charging for the claim part." UPPA definitions reach direct, indirect, or any other compensation. The roofing job is your compensation. Arguing that the claim help was "free" does not work when the entire reason you are in the conversation is to land the paid repair. Indirect compensation is still compensation.

"I assigned the claim to myself, so now I'm the policyholder's interest." Assignment of benefits is heavily restricted or barred in many states precisely to stop contractors from using it as a back door into claim handling. Where AOB is restricted, taking an assignment and then negotiating the claim is the same violation wearing a different hat. Know your state's AOB rules before you build any process around it.

"I'll just get a public adjuster license too." In Texas and states with the same conflict rule, you cannot be the public adjuster and the contractor on the same property; the license does not open the dual role, it forecloses it. A licensed public adjuster who also does the repair has a statutory conflict of interest. The license is a wall between the roles, not a bridge.

"My website says we handle insurance, but I never actually negotiate." Stonewater is the answer: holding yourself out can be the violation by itself. Audit your trucks, signs, cards, and site for any language that positions you as the homeowner's claims handler, and replace it with storm-roofing-and-documentation language. The marketing is where enforcement often starts because it is public and recorded.

"The adjuster lowballed the scope and the homeowner is furious." Your move is documentation, not advocacy. Produce evidence and pricing for the missing scope and hand it to the homeowner to submit. If they want to escalate, that is a conversation for them, a licensed public adjuster, or their attorney to have with the carrier. You stay the fact witness.

Building this into a team that never slips

Individual reps will not stay compliant on willpower. Build the line into the system so the safe behavior is the default behavior.

  1. Script the first ninety seconds. Most violations happen in the opening pitch, when a rep is improvising rapport. Write and drill the compliant opener so the natural thing to say is also the legal thing. The reps who get a company in trouble are usually winging the part that should have been scripted.
  2. Audit your marketing once a quarter. Run trucks, signs, cards, social, and website against the do-not-say list. "Claims specialist" language has a way of creeping back in because it tests well in ads. Kill it every time.
  3. Make the deductible non-negotiable in writing. Your contract should state the homeowner pays their deductible, in plain language, and reps should never imply otherwise. This single discipline keeps a UPPA issue from ever becoming a fraud issue.
  4. Template the documentation so reps cannot freelance. When the supplement package, the estimate, and the homeowner handoff letter are all locked, evidence-anchored templates, an individual rep cannot accidentally draft a negotiation. The system stays on the contractor side because it was built to.
  5. Train the handoff line explicitly. Every rep should be able to say, cleanly, "You file the claim, you own it, your insurer decides coverage, and I give you the facts." If that sentence is automatic, most of the danger is gone.
  6. Know your state, not only the famous case. Stonewater is Texas. Pull your own state's public adjuster statute and any contractor-specific provision, and check your AOB rules. The principles are near-universal but the specifics, penalties, and advertising rules vary, and the strict version is the safe house standard.

The payoff for building it in: your team can be aggressive on storm work, knock the right doors, document better than anyone in the market, and close, while staying so cleanly on the contractor side of the line that a competitor recording your pitch finds nothing to report. Compliance done right is not a brake on a storm operation. It is the thing that lets you run flat out without fear.

The bottom line

UPPA statutes do not ban roofers from storm work, from documenting damage, from writing accurate estimates, or from being in the room when the adjuster inspects. They ban one specific thing: acting as the homeowner's representative to negotiate, adjust, or settle the claim against their insurer for compensation, or advertising that you do. Every safe sentence states a fact about the roof, the repair, or the code. Every dangerous sentence promises an outcome, interprets a policy, erases a deductible, or claims to handle the claim.

Learn the line word for word, build it into your scripts, your marketing, your contract, and your documentation, and you get the best of both: a storm operation that out-documents and out-sells the competition, and a legal position so clean it is boring. The roofers who get in trouble are not the ones who help homeowners. They are the ones who never learned the difference between helping and representing. Now you have.

If you want the documentation engine that produces evidence-anchored, UPPA-gated supplement packets, depreciation-release letters, and deductible-tracked invoices, plus the ranked due-and-storm-hit targeting that fills the top of the funnel, that is what RoofPredict is built to do. See it at https://roofpredict.com.

FAQ

What does UPPA actually stand for and what does it ban?

UPPA is shorthand for unauthorized (or unlicensed) public adjusting, a violation of the public adjuster licensing statutes that nearly every state has. It bans an unlicensed person from acting on a policyholder's behalf, for compensation, to negotiate, adjust, or settle an insurance claim, or from advertising that they do. It does not ban a contractor from inspecting a roof, documenting damage, writing a repair estimate, or being present when the adjuster inspects. The violation is representing the homeowner against the insurer, not doing roofing work.

Can a roofer talk to the insurance adjuster at all?

Yes, as a contractor. You can be present at the inspection, point out the storm damage you documented, and explain your own repair scope and why specific items, including code-required items, are part of a correct repair. That is a tradesperson explaining their work. What you cannot do is speak for the homeowner, argue coverage, or negotiate the settlement on their behalf, because that is the representative role reserved for licensed public adjusters. Stay a fact witness about the roof and you are fine.

Why can't a roofer just say they'll get the claim approved?

Because coverage is the insurer's decision, not yours. Promising an approval positions you as the person working the claim to a guaranteed outcome, which looks like public adjusting, and it is also false because you do not control the decision. The compliant version is to say you will document everything and provide an accurate estimate, and that whether it is covered is the carrier's call based on the policy and their inspection.

Is offering to waive or cover the homeowner's deductible illegal?

In most states, yes, and it is usually a fraud problem on top of any UPPA issue. The deductible is the policyholder's contractual obligation to their insurer. Waiving it, rebating it, or inflating the estimate to hide it is insurance fraud and is specifically criminalized in many states. Tell homeowners plainly that they pay their deductible and give them an honest estimate so they know their exact number. A contractor who offers to make the deductible disappear is offering to commit fraud.

What was the Stonewater case and why does it matter to roofers?

Texas Department of Insurance v. Stonewater Roofing, decided by the Supreme Court of Texas in 2024, held that the public adjuster statute regulates the act of representing an insured in a claim, not speech, and that holding yourself out as a claims or insurance specialist can itself violate the licensing law. The lesson for roofers everywhere is that you do not have to negotiate a single claim to be in trouble; advertising yourself as the company that handles insurance claims can be the violation by itself. Audit your trucks, signs, and website for that language.

Can a roofer get a public adjuster license to do both jobs?

Generally no, at least not on the same property. Texas Insurance Code Section 4102.163 bars a roofing contractor from acting as a public adjuster on any property where the contractor provides or may provide roofing services, whether or not they hold a license. Most states reach the same result through a conflict-of-interest rule that prohibits a licensed public adjuster from also being the contractor on the claim they adjusted. The license is a wall between the two roles, not a bridge that lets one person hold both.

How can a roofer supplement a claim without violating UPPA?

A compliant supplement is additional contractor documentation showing that a correct repair requires more scope than the original estimate captured, for one of three reasons: missing damage, code-required items, or conditions revealed during the work. For each item, identify it, anchor it to evidence such as a photo or a code citation, price it at local rates, and put it in a package the homeowner submits to their carrier. You are documenting what the repair requires. You are not telling the carrier what they owe or negotiating on the homeowner's behalf.

What can a roofer legally say on their website and trucks about insurance?

Sell your roofing expertise and your documentation, not power over the carrier. Safe language includes storm damage roofing specialists, hail and wind roof repair, and statements that you document storm damage and write accurate repair estimates. Avoid insurance claim specialists, claims experts, we handle the insurance process, or anything that positions you as the homeowner's claims representative, because under the Stonewater reasoning that advertising can be the violation.

Does it matter that I am not charging separately for the claim help?

No. Public adjusting statutes reach direct, indirect, or any other compensation. The roofing job itself is your compensation, so arguing that the claim assistance was free does not move you outside the statute when the entire reason you are in the conversation is to land the paid repair. Indirect compensation still counts, which is why the safe approach is to stay strictly on the documentation and estimating side regardless of how you are paid.

How does RoofPredict help a roofer stay on the right side of the line?

RoofPredict produces the documentation that compliant storm work is made of, and it is built to stay on the contractor side of the line. Its targeting ranks roofs by age band and storm exposure so you knock real candidates. RoofCLAIM auto-classifies and OCRs claim documents, then flags missing scope, code-required items, and missed supplements with evidence anchors and local pricing, and outputs supplement packets, depreciation-release letters, and deductible-tracked invoices on locked, UPPA-gated, contractor-documentation templates. It generates facts about the roof and the repair for the homeowner to submit; it does not negotiate, interpret coverage, promise approval, or erase a deductible.

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Sources

  1. Texas Department of Insurance v. Stonewater Roofing, Ltd. Co. (2024)law.justia.com
  2. Texas Insurance Code Chapter 4102, Public Insurance Adjustersstatutes.capitol.texas.gov
  3. TDI Bulletin B-0014-14: Roofing Contractors and Public Insurance Adjustingtdi.texas.gov
  4. TDI Frequently Asked Questions: Unlicensed Public Adjustingtdi.texas.gov
  5. National Association of Insurance Commissioners: Public Adjusterscontent.naic.org
  6. FTC: Avoiding Scams After a Disasterconsumer.ftc.gov
  7. IBHS: Hail Resources and Roof Performanceibhs.org
  8. NOAA Storm Prediction Center: Storm Reportsspc.noaa.gov
  9. National Weather Service: Hail Information and Severe Weatherweather.gov
  10. NRCA: Roofing Industry Resources and Standardsnrca.net
  11. ICC International Residential Code, Chapter 9 Roof Assembliescodes.iccsafe.org
  12. OSHA: Fall Protection in Residential Constructionosha.gov
  13. National Association of Public Insurance Adjusters: What Is a Public Adjusternapia.com
  14. RoofPredictroofpredict.com

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