The letter I submitted to my Insurance carrier raising concerns about the quality of the CCC market analysis.

Subj: CCC Market Value Report Errors

During a phone call with T.H. on November 15, 2012 I raised a concern about an adjustment that was made to each of the three comparable vehicles involving Privacy Glass. This adjustment caused each of the comparable vehicles to have their value reduced by $70, which would then reflect as a reduction in the valuation of the loss vehicle.

My concern was how the determination had been made that each of these vehicles has Privacy Glass installed. None of the listings for the comparable vehicles provided by CCC makes mention of the vehicles being equipped with Privacy Glass.

When Rebecca from CCC was contacted to help address the concern she stated that CCC looked at the pictures provided with the listings. I asked how they could be sure Privacy Glass was installed on the vehicles when some of the listings did not provide images sufficient to evaluate the window tinting. At that point Rebecca became indignant and stated that if I was concerned about a $70 item they would adjust the valuation upward.

Because Rebecca had done nothing but exacerbate my concern about the care being given to my claim, and because of the inappropriate manner in which she was addressing me, I requested T. remove Rebecca from the conference call.

I reiterated my concerns to T. and pointed to comparable 3 from the CCC Valuescope report as an example. The Listing Description for comparable 3 makes no mention of Privacy Glass or even Tinted Windows. In the Vehicle Modification sidebar of the advertisement Tinted Windows is listed. The listing provides a single photo of the automobile, shown below.

It is quite obvious from looking at the listing photograph of comparable 3 that determining that the vehicle is equipped with Privacy Glass from that image is not possible. If anything, the view through the vehicle and out the back window suggests that if there is tinting on the rear window it is light, as the objects behind the vehicle can easily be seen through the window.

When I pointed these facts out to T. and explained my concern I was assured that CCC’s report was accurate. Being told a report is correct when all evidence suggests contrary is not something that builds my confidence in USAA. When I asked what would be done if it was determined that the vehicle did not have Privacy Glass I was told that speculating about that situation would not be done.

I then contacted the seller of comparable 3 and inquired about the type of Window Tinting on the car, if it was dark and would be considered Privacy Glass. The response from the seller of comparable 3 is shown below. (In the letter I provided a screen shot of the conversation I had with the vehicle seller)

The response from the seller is: “Its 30-35%. Not too dark.” There should be no question that comparable 3 does not have Privacy Glass, contrary to what the CCC Valuescope report states.

My primary concern about the Loss Unit Value being presented to me is the manner in which the value has been arrived at, and specifically about errors that exist in the report. A growing concern is the attitude being taken by USAA employees toward me about my concerns. I have a sense that USAA is more concerned with quickly settling the claim rather than providing a correct value for the loss vehicle.

As I have shown above, the facts make valid my concern about errors in the report. I will provide USAA with a summary of the errors and discrepancies I have found in the CCC report for review.

Next: Step Away

By this stage of the process my Insurance company was not exactly prompt in responding to my correspondence, in fact I doubt I would have received a response at all to the concerns I raised.  I called a couple of days later to ask pointed questions about the market valuation, such as how they could determine the condition of a vehicle they had never seen, how they could be sure the aftermarket components were on a car they’d never seen, and why some of the valuations were so far out of whack.

The answers from the Insurance representative were always the same, that CCC was in the business of doing vehicle valuations and knew what they were doing.  This pass the buck mentality combined with the absolute belief that CCC could do no wrong was infuriating in the face of the evidence I had provided.  One of the most egregious challenges to common sense was the value that CCC gave to the comparables for having “privacy glass”, a heavy tint that was considered more valuable than the regular tining that my car had.  I wanted to know how they had determined that the comparables were equipped with privacy glass when all they had to go off of was an Internet advertisement that made no mention of the vehicles having privacy glass.  I was told that they looked at the pictures posted with the ads and made the determination from those pictures.

This answer was absurd since the pictures in the advertisements did not show the car in a way that would enable a person to make this determination.  The insuarnce person told me that they would get someone from CCC on the call to answer my questions.  When they did come on the line and I asked about the window tinting, and they gave the same answer, I pointed out that in the case of one car there was a single photo included with the advertisment and it was from ground level in front of the car, making it impossible to determine that the car had window tinting.  The CCC representative became defensive and indignant claiming that if I was so concerned about an item that impacted the valuation by only $70 that they would revise the report.  Having learned all that I needed to know about CCC Valuescope, that their process for determining market value was sloppy, shoddy, and cursory, I told the Insurance representative to remove the CCC person from the call.

I tried making a point to the Insurance rep about how poor the quality of the market value report was, but incredibly they still stuck by CCC. (This is one reason you should not believe your Insurance carrier, they’re in bed with CCC and will say nothing bad about them even in the face of evidence.)  I was getting nowhere with the Insurance rep so I told them I would submit another letter with my most recent concerns.

Next: Documenting Incompetence

The second, higher offer, from my Insurance carrier had been the result of a second appraisal, consideration of the aftermarket parts on the car, as well as another market valuation.  My experience with the first market valuation report prompted me to immediately request a copy of the second valuation report that CCC had produced.

Once more I found significant cause for concern about the way CCC was determining the market value of my car.  For the second valuation three cars had been used for comparables, each supposedly having some degree of modification through aftermarket parts.  Unfortunately this crop of modified cars had a just smattering of exhaust, ECU, and wheel upgrades; I wrote another letter to my insurance carrier detailing my concerns.

For the sake of brevity I am going skip including the 6 pages I wrote detailing all of the problems and present the highlights:

Concern 1:

In the original CCC Market Valuation Report (Reference Number 48245400) the loss vehicle’s condition, as assessed by the appraiser who inspected the car, was described as Very Good in all areas except the condition of the tires, which were evaluated as Good, and the interior Headliner which was rated Fair. The loss vehicle received a positive $919 condition adjustment.

In the most recent valuation report the loss vehicle condition is rated as Average and each comparable vehicle is rated as being of Average condition. There is also no positive condition adjustment for the loss vehicle.

When I inquired with USAA if an appraiser was dispatched to inspect each of the comparable vehicles, each of which is being sold by a private party, I was told that there was no in-person inspection of the comparable vehicles. These comparable vehicles were all rated to be of equivalent condition to the loss vehicle. This determination is impossible to make without performing an in-person inspection. The loss vehicle should have an Above Average condition rating as supported by the appraiser’s report.

(When I asked the insurance representative about this they stated that because the three comparable cars were considered specialty vehicles, a product of having aftermarket parts, they were automatically assumed to be in Above Average condition since people who installed aftermarket parts were assumed to take better car of their cars – the condition of the comparables was never evaluated as was done with my car.)

Concern 2:

The CCC valuescope valuation report states that for comparable units “The Comparable Units are compared to the Loss Unit to determine the Adjusted Value. The Adjusted Value represents the price of the Comparable Unit configured to exactly match the Loss Unit.”

I have previously supplied documentation detailing the custom components installed on the loss vehicle along with the purchase price and current retail cost of those components.

The comparable vehicles all have configurations substantially less extensive than that found on the loss vehicle. The adjustments made to bring the comparable vehicles into a configuration exactly matching the loss unit have errors.

The valuation report assigns the custom components to general categories, the categories shown in the report are:

1. Performance Engine Equipment
2. Upgraded Drivetrain
3. Custom Wheels+Tires
4. Performance Exhaust
5. Upgraded Suspension

Absent is a category for Performance Brakes, which the loss vehicle is equipped with and which I have previously supplied documentation for showing the Loss Vehicle does have a performance braking system.

The comparable vehicles and loss vehicle match up in these general categories as follows. For each category I have reviewed the comparable listing supplied by USAA and in some cases contacted the sellers to get clarification about the custom equipment they have installed on the comparable vehicles.

Performance Engine Equipment

There are two significant errors to the Performance Engine Adjustment category.

1. The claimed cost to make the comparable vehicles configured to exactly match the loss vehicle is far below the actual cost required to accomplish this. Simply looking at the components that would need to be purchased and the associated costs makes this clear. To purchase just the turbochargers would be $1800, nearly the entire adjustment the CCC report gives comparables 1 and 2, leaving eight other components unaccounted for.

2. Note that the Loss Vehicle also has an upgraded Engine Computer though I do not have a receipt from the vendor for this upgrade.

3. Comparable 3 required a $4194 adjustment to make it comparable to the loss vehicle despite having only a single custom component that costs $316. At a minimum, to at least be consistent with the adjustments made, comparables 1 and 2 need the adjusted value increased by $2000.

Upgraded Drivetrain

1. To point out the obvious, none of the comparable vehicles have any upgrades to their drivetrains. Comparable 2’s listing states it has a sport clutch but that is what the vehicle was equipped with from the manufacturer.

2. Comparable 2 which also has no upgrades to the drivetrain would require $299 less to be exactly configured as the loss vehicle? At the very least comparable 2 should have a $299 adjustment to be consistent with comparables 1 and 3.

Custom Wheels+Tires

1. The listings provided insufficient information about the wheels to determine exactly what size and model were equipped on comparable 1 and 2.

2. The wheels installed on comparable 3 cost less than half that of the loss vehicle yet no adjustment is made.

Performance Exhaust

1. The amount quoted in the CCC report to make the three comparable vehicles configured exactly the same as the loss vehicle is unrealistic. Over three thousand dollars in custom equipment cannot be purchased for $292.

2. Comparable vehicle 1 which has no exhaust components has the same adjustment value as comparable 2 that has a custom exhaust.

3. Comparable vehicle 3 has no cost adjustment despite being configured nearly identically to comparable 2. Comparable 3 should have at least a $292 adjustment.

Upgraded Suspension

1. The amount quoted in the CCC report to make the comparable vehicles configured exactly the same as the loss vehicle is impossibly low. The components found on the loss vehicle cannot be purchased for one-tenth of the retail price.

2. No adjustment was made to any of the comparables, even comparable 1 that has no upgraded suspension components at all.

Performance Braking System

This category was omitted from the CCC valuescope report despite the Loss Vehicle being equipped with an upgraded braking system.

An adjustment of $452 was made to the Loss Vehicle Actual cash value to account for the $2195 braking system that none of the comparable vehicles were equipped with.

It is not possible to make the comparable vehicles configured exactly as the loss vehicle by allocating $452 for a braking system that retails for $2195.

Other discrepancies:

The valuation report provides a positive $702 adjustment to the comparable vehicle for having a Navigation System. The vehicle listing states that the car is equipped with the factory Audi Navigation System GPS. This vehicle is from the 2001 model year, which was made available for sale in 2000. The factory navigation system on this comparable is at least 12 years old. The state of the art in GPS navigation technology in the year 2000 consisted of a stack of eleven map CD’s that needed to be loaded into the vehicle CD player, preventing the play of music CD’s, so that pertinent maps of the region being driven through could be accessed. The Audi Navigation System in 2000 did not have a map display, it utilized the small red LED status display on the instrument panel to provide direction indications. The maps supplied with this navigation system are out of date, Audi of America no longer supports the system, and the company that supplied the map discs no longer has any mention of the product. The 2000 Audi Navigation System GPS is a relic from the earliest days of automotive GPS navigation systems and it is preposterous to believe a person interested in acquiring a GPS navigation system would be will to pay $700 for this technological dinosaur. A value of $100 would be generous.

Next: Insurance Phone Call