It is common to receive the commercial umbrella policy proposal at the last
minute—in part because the commercial umbrella policy's pricing and terms
are usually contingent on the terms, conditions, and pricing of the underlying
insurance, which must first be established to finalize the umbrella proposal.
Unfortunately, this eleventh-hour transaction often results in the buyer paying
little or no attention to the actual coverage being purchased.
Too often, the only focus is on the umbrella limit. And, even then, the
limit may simply be expressed as "$25 million excess of primary,"
which overlooks how the aggregate limits within the umbrella may apply—an
important consideration.
Nonstandard Forms
While the Insurance Services Office, Inc. (ISO), has promulgated since late
2000 a commercial umbrella policy form (CU 00 01) as well as a commercial
excess policy form (CX 00 01),1 most insurers
offering commercial umbrella coverage still draft and use their own policy
forms—or at least draft and use their own endorsement forms. Therefore, unlike
many of the insurance policies that underlie it, most commercial umbrella or
excess policies are not written with a "standard form" policy. To
understand what you have purchased, it is necessary to read the policy.
Umbrella and Excess Liability
While commercial umbrella policies and excess liability policies
2 typically sit above more than one type of
underlying liability insurance (e.g., commercial general liability, business
auto liability, employers liability, etc.), umbrella policies have
traditionally been distinguished from excess liability coverage in that an
umbrella may be somewhat broader than the underlying coverage. For
example, an umbrella policy may include a worldwide coverage territory, which
is often a broader coverage territory than found in the underlying liability
policies. Excess liability policies are traditionally different from an
umbrella policy in that excess liability policies do not provide broader
coverage than the policies over which they are excess, and they generally
follow only the terms of the underlying policies.
However, this distinction between umbrella and excess liability policies is
fading and may even be misleading. Umbrella insurers do not generally
"drop down" and provide coverage over known uninsured liability
exposures.3 In addition, some insurers use an
umbrella policy form that may include the characteristics of both an umbrella
and excess liability policy—usually by using a bifurcated (divided) insuring
agreement. The first insuring agreement is the excess and follows the terms of
the underlying policy; the second insuring agreement is the umbrella and covers
liability exposures not covered by the underlying insurance.
Be aware that in many instances, both insuring agreements are subject to
numerous exclusions. And don't be overly influenced by the policy
title—some insurers will call their umbrella policies "excess commercial
liability," while other insurers will title their excess policies as
"commercial umbrella liability." The takeaway is that there is no
substitute for reviewing the actual terms and conditions of the policy itself,
including all endorsements.
Point One—All Umbrella Policies Do Not Follow Form
It is simply not true that all umbrella policies "follow form" and
thus provide the exact same coverage as the underlying insurance.
While many may insist this is the case, such conclusions are based on a
fundamental misunderstanding of commercial umbrella insurance.
Stand alone. Rather, umbrella policies may well be
"stand alone," which means such umbrella policies are subject to
their own insuring agreements, definitions, conditions, and exclusions, all of
which are independent of the underlying policies.
Excess. Even if an excess liability policy is purchased and
does expressly state it will follow the terms, conditions, exclusion,
limitations, and definitions of the underlying insurance, invariably, that
promise is qualified and usually includes important disclaimer wording.
For example, one excess liability insurer, after promising to "… follow
form the terms, conditions, definitions, and exclusions of the underlying
insurance," further states, "… except to the extent that the terms,
conditions, definitions and exclusions of this policy differ…. In the event of
any conflict, the terms conditions, definitions, and exclusions of this policy
shall control." In other words, we follow form unless we don't follow
form—necessitating a complete reading of the excess liability policy to
identify where it does not "follow form."
This is not trickery on the part of the insurer—instead, it is a usual and
customary practice of excess liability insurers. Buyers should be on notice of
this practice and, therefore, should never conclude, without reviewing the
complete excess liability policy, that even a policy that begins by promising
to "follow form" actually does so in all circumstances.
A Look at Primary and Noncontributory
An unfortunate result of the "every umbrella is follow form" adage
is that this erroneous belief inevitably leads to the mistaken notion that the
umbrella follows the other insurance condition of the underlying
policies. For example, if the other insurance condition of the CGL policy has
been amended to include coverage on a primary and contributory basis (e.g., CG
20 01 04 13), the incorrect conclusion is that the umbrella is also written on
a primary and noncontributory basis for an additional insured. I find this view
particularly puzzling—if the umbrella followed the CGL other insurance
condition, the umbrella might well be primary coverage, not excess
coverage.
Order of coverage. The first aim of the "primary and
noncontributory" requirement is that all of the liability insurance
provided to the additional insured should respond before any liability
insurance available to that additional insured (as a named insured) is called
on to respond. In other words, the coverage for the additional insured is
expected to respond in this order.
- The CGL policy of another on which the person or organization is an
additional insured is to respond first (primary basis)
- The umbrella policy of another on which the person or organization is an
additional insured is to respond next, or second
- The CGL policy of the additional insured on which the additional insured
is a named insured is to respond next, or third
- The umbrella policy of the additional insured on which the additional
insured is a named insured is to respond next, or fourth
In the context of an umbrella policy, this first aim might be better
described as the "order of coverage" or the "priority of
coverage" rather than "primary."
Noncontributory. The second aim of
"noncontributory" does not address the order or priority of coverage.
Noncontributory means only that the insurer providing coverage to the
additional insured has agreed not to seek contribution from any liability
insurance policy on which the additional insured is a named insured. It should
be noted that an umbrella policy that only agrees to be
"noncontributory" fails to meet the first aim—the order of coverage.
(See "Commercial Umbrellas and the Demand for Primary and
Noncontributory.")
Umbrella—typical other insurance condition. A typical
umbrella other insurance condition provides for an order of coverage that is
quite different from, and in conflict with, the order of coverage required by
"primary and noncontributory." Here is the other insurance condition
found in a typical umbrella policy (in pertinent part).
If other insurance applies to a "loss" that is also covered by
this policy, this policy will apply excess of such other insurance. However,
this provision will not apply if the other insurance is specifically written
to be excess of this policy.
The last sentence is referring to a second (or higher) layer excess
liability policy—not the CGL policy of an additional insured.
Not the required order of coverage. Without changing the
typical umbrella other insurance condition as illustrated above, the order of
coverage will typically be as follows.4
- The CGL policy of another on which the person or organization is an
additional insured is to respond first (primary basis)
- The CGL policy of the additional insured on which the additional insured
is a named insured will be called on to respond next, or second
- The umbrella policy of another on which the person or organization is an
addition insured will respond in conjunction with the umbrella
policy of the additional insured on which the additional insured is a named
insured—prorating the payment of remaining damages between the two umbrella
insurers
The above is decidedly not the order of coverage contemplated by
"primary and noncontributory."
Because the "primary and noncontributory" requirement is becoming
commonplace, many umbrella insurers have amended or are willing to amend the
umbrella's other insurance condition to provide the required order of
coverage.
For example, here is wording that an umbrella or excess liability insurer
may use that would be necessary to amend the other insurance condition to
provide the agreed upon order of coverage in the umbrella or excess liability
policy (in pertinent part).
However, if you specifically agree in a written contract or agreement that
the insurance provided to any person or organization that qualifies as an
insured under this insurance must apply … on a primary and non-contributory
basis.…
This insurance will apply before any "other insurance"
that is available to such additional insured which covers that person or
organization as a named insured, and we will not share with that
"other insurance".…5 [italics
added.]
Of course, there are other changes to the umbrella other insurance condition
that may be used in lieu of the above. The larger point is that the other
insurance condition of an umbrella or excess liability policy in most instances
must be amended to provide the order of coverage required by an
additional insured.
Sublimits
Liability policies often have sublimits. For example, the CGL policy
typically includes a sublimit for "damage to premises rented to you."
It is highly unlikely that the umbrella or excess liability insurer intends to
drop down and pay losses in excess of a $100,000 damage to premises rented to
you limit.
Some insurers exclude the exposure entirely by adding to the umbrella or
excess policy a "real and personal property care, custody and
control" exclusionary endorsement that excludes property damage to any
real property rented to or occupied by any insured. Other insurers exclude any
exposure that is subject to a sublimit—usually defined as a limit that is less
than the limits shown in the schedule of underlying insurance.
Recognition of the reduction of the aggregate. Either way,
it is critical for the umbrella insurer to recognize, by use of the appropriate
policy wording, the payment of a claim within the sublimit as a reduction in
the underlying policy aggregate limit. Failure of the insurer to do so will
likely result in a gap between the underlying policy and the umbrella.
So, while a buyer should not usually expect the umbrella or excess liability
policy to drop down and pay for damages in excess of the underlying
policies' sublimits, a buyer should expect that damages paid or payable
under any policy sublimit are recognized as a reduction in the applicable
aggregate limit—for that same event or subsequent events that result in bodily
injury, property damage, or personal or advertising injury during the policy
period.
Point Two—Umbrella Policy's Defense Obligation
While usually the underlying insurers have a duty to defend an insured with
the cost of defense paid by the underlying insurance in addition to the policy
limit, there are numerous instances in which it may be critical for the
umbrella or excess liability insurer to defend an insured. In other words,
whether an umbrella insurer has a duty to defend, and when that duty is imposed
on the insurer, is often overlooked, but it is a very important umbrella
coverage matter.
For example, the insured's CGL policy has just paid in settlements the
full amount of its product liability aggregate limit due to a series of product
claims involving bodily injury that took place during the policy year. A
subsequent products claim—also involving bodily injury during the same CGL
policy year—arrives in the form of a complaint against the insured.
Because the CGL insurer has used up the aggregate limit in the payment of
the settlements, the CGL insurer has no duty to defend or pay damages for this
new products claim. When the umbrella insurer drops down over the exhausted CGL
policy's product liability aggregate limit, will the umbrella insurer be
obligated to defend this new products claim? That depends on the
defense provision of the umbrella policy that will drop down.
No Duty To Defend
A few umbrella insurers unequivocally state that they have no duty to be
involved in any defense of any claim, suit, or proceeding. In the example
above, the insured, and not the umbrella insurer, will be required to defend
the new products liability claim, with all defense costs paid by the
insured.
No Duty To Defend but the Right To Associate in the Defense
Some umbrella insurers stipulate that they have no duty to defend but will
reserve the right—but not the duty—to associate in the defense of any
claim or suit that may involve their insurance. While it might make strategic
sense for the insurer to become involved in and defend the new product claim
noted above, the insurer is not obligated by the umbrella defense
wording to do so. Stated differently, the insurer's right to associate in
the defense of a claim is for the protection of the insurer and not the
insured, and it is not the equivalent of the insurer's duty to
defend the insured for the new products liability claim.
This is a very meaningful difference—the duty to defend is a very
broad obligation and is usually triggered if any of the allegations in the
complaint are potentially covered by the liability policy (in this case, the
umbrella policy). The right to associate in the defense means the
insured's protection is available only at the insurer's
option—even if the allegations are potentially covered by the umbrella
policy, the insurer owes the insured no duty to defend. The insurer has merely
reserved its right to protect its own interests. While the insurer may decide
to defend the new product claim, the policy does not obligate the
insurer to provide a defense to any insured.
This situation may be particularly exacerbated if the umbrella insurer sees
no exposure to its policy because the insurer believes that the new products
claim is not covered. Thus, the insurer is fully within its rights to decline
to defend the insured—as the insurer concludes it is not in the
insurer's interest to defend the suit. The takeaway is the insured
might very well end up paying for the all of the defense of the new product
claim.
No Duty To Defend but the Right To Assume Charge of the Defense
The right of an umbrella insurer to assume charge of the defense is not
mutually exclusive with the right to associate in a defense—both rights of the
insurer may be within the same policy. But for the same reasons, the right to
assume charge of the defense without the duty to defend is problematic. Again,
this provision is intended to protect the insurer's interest, but in a
different way—if the insurer believes the underlying claim may reach the
umbrella but is not being handled properly, the right to assume charge of the
defense usually gives the umbrella insurer the right to take over the defense
of the claim, including "… the right to select or dismiss defense counsel
for the purpose of continuing the defense…." It is worth repeating that
the right to assume charge of a defense is not the same as the duty to defend
its insured.
Duty To Defend—Limited Circumstances
From the insured's viewpoint, the most favorable defense provision in an
umbrella is the insurer's express duty to defend the insured, albeit in
limited circumstances, such as (a) when the underlying insurance has been
exhausted, or (b) when the underlying insurance does not provide coverage. In
most instances, even if the duty to defend does not arise, the umbrella insurer
will also maintain its right to associate in any defense and may even assert
its right to assume charge of a defense of a claim or suit that may reach its
umbrella policy.
In the example above, the insured would have a defense provided by the
umbrella insurer for the new product claim because of the duty to defend
provision, as this claim clearly falls within (a) above—the underlying
insurance has been exhausted. And, despite the belief the umbrella insurer may
have that the new product claim may not be covered by the umbrella, if the
allegations are potentially covered by the umbrella, the insurer is still
obligated to defend that claim—the benefit to the insured of the "duty to
defend" obligation.
Limited duty to defend. While the umbrella insurer is
obligated to defend the insured when the underlying insurance does not provide
coverage, as stated in (b) above, this duty is limited.
First, the umbrella insurer has no obligation to defend an insured against a
suit for which there is no potential coverage under the umbrella
policy, even if the underlying insurer does not provide coverage.
Second, the duty to defend the insured when no underlying insurance provides
coverage can be viewed as providing the insured a "backup" for its
defense when the underlying insurer has improperly denied its
obligation to defend. While the caselaw is mixed on the purpose of this
provision, the general intent is to protect the insured from being left without
any defense. Umbrella insurers who undertake to provide the insured this
"backup" defense of a claim that was wrongly denied by the underlying
insurer may have a right of contribution to recover its defense expenses from
the underlying insurer that wrongly denied the insured its right to be
defended.
No underlying insurance provided. Of course, what exactly
is meant by "an underlying insurer not providing coverage" is the
subject of some dispute. A few courts have found that wrongfully denying the
insured a defense does not mean that the underlying insurance does
not provide coverage. These courts have found that whether the policy
provides coverage is based on the policy wording and not based on the
insurer's failure to discharge its duty to defend. In other words, if the
policy obligates the underlying insurer to defend, then the underlying
insurance provides coverage—regardless of whether the insurer has
actually failed to provide the defense owed. In such circumstances, the
"backup" defense would not be provided to the insured under (b) as
the underlying insurance would be found to provide coverage to the insured.
In addition to the limit. Regardless of how the umbrella
policy addresses defense, the umbrella should explicitly state that such costs
incurred by the insurer are paid in addition to the policy limits.6
Point Three—Claims That May Not Reduce the Underlying Aggregate Limits
Whether found within the insuring agreement, the limits section, or the
maintenance of underlying insurance section, some umbrella insurers recognize
the exhaustion of an underlying aggregate limit only if the claim paid
by the underlying insurance is also covered by the umbrella policy. Here is
wording that typically includes such restrictions (Maintenance of Schedule of
Underlying Insurance in pertinent part).
You agreed that during the Policy Period:
3. The total applicable limits of Scheduled Underlying Insurance shall not
decrease, except for any reduction or exhaustion of aggregate limits by
payment of Loss to which this policy applies; [Emphasis added.]
As noted above in the "Sublimits" section, if the umbrella insurer
totally excludes any property damage to property occupied or rented to the
insured, any claim paid by the CGL policy within the damage to premises rented
to you limit would not be recognized as reducing the CGL policy general
aggregate limit. For example, if the CGL insurer paid its limit of $100,000 for
fire damage to a warehouse rented to an insured, this reduction in the CGL
policy general aggregate limit of the CGL would leave a gap of $100,000 between
the actual CGL general aggregate limit and the general aggregate limit
as required by the umbrella insurer.
While this is just one example of this issue, it is far preferable for the
umbrella insurer to recognize the reduction or exhaustion of the underlying
insurance by payment of claims that are covered by the underlying
insurance, regardless of whether or not the umbrella covers that claim.
Here is wording that is more favorable (Maintenance of Underlying Insurance in
pertinent part).
During the "policy period", you agree:
2. That the Limits of Liability of the policies listed in the Schedule of
Underlying Insurance as shown in Item 5. of the Declarations will be
maintained except for any reduction or exhaustion of aggregate limits by
payment of loss in claims or suits covered by the Underlying
Insurance. [Italics added.]
Point Four—Loss Payable
When the umbrella insurer is obligated to "attach" and pay some or
the entire limit in damages is of vital importance, yet umbrella policies are
often silent or vague on this point, other than to generally state the loss
must exceed the underlying insurance limits.
A fairly common loss payable clause (CU 00 01 04 13) states the
following.
Liability under this Coverage Part does not apply to a given claim unless
and until the following.
a. The insured or insured's "underlying insurer" has become
obligated to pay the "retained limit"; and
b. The obligation of the insured to pay the "ultimate net loss"
in excess of the "retained limit" has been determined by a final
settlement or judgment or written agreement among the insured, claimant and
us.
"Retained limit" means the available limits of "underlying
insurance" scheduled in the Declarations or the "self-insured
retention",7 whichever applies.
Provided either the insured or the underlying insurer has become
obligated to pay the "retained limit" listed in the schedule in the
declarations, the umbrella insurer must pay in excess of the "retained
limit." Of course, that obligation must be by final settlement or
judgment, as described above. However, consider the following actual
example.
Per-Claim Deductible
A policyholder had a $10,000 per claim deductible as part of the
CGL policy that included a $1 million each-occurrence limit. An explosion
occurred that resulted in numerous claims for bodily injury and property
damage. The claim settled for $1,785,986. However, because most of the claims
were within the deductible, the CGL insurer paid only $497,999 in damages, with
the insured paying $1,287,987 as deductible payments.
The policyholder made claim under the umbrella policy, which included loss
payable wording similar to the above.8 The umbrella
insurer took the position that as the underlying CGL insurer had not paid $1
million, the umbrella insurer owed no payment of damages. Of course, the
insured took a different position. Because the insured is obligated to pay
$1,785,986, the insured has satisfied the umbrella insurer's loss payable
condition, and any amounts paid by the insured policyholder in excess of $1
million should be paid by the umbrella insurer.
The tenth circuit court (applying Oklahoma law) decided that the wording was
ambiguous9 and that the loss payable provision of
the umbrella could mean either the insured is obligated to pay in excess of $1
million or the CGL insurer was obligated to pay in excess of $1 million. The
court remanded the matter to a lower court to determine how the loss payable
condition should be interpreted.10
Noncash Settlement
In another actual example11
based on similar loss payable wording in the umbrella
policy,12 the loss involved bodily injury because
of the death of a young woman who fell from a portable rock climbing wall. Due
to an exclusion for amusement devices13 included
on each policy, both the underlying CGL insurer and umbrella insurer denied
defense and indemnity to the insured. The insured entered an agreement limiting
the collection of any judgment to amounts payable by the insurance policies.
The owner was found liable, with an entry of judgment that included damages
awarded to the parents of the deceased woman of over $4.5 million.
The parents then pursued the insurers, and, in exchange for a settlement
payment of $700,000, the parents released the CGL insurer to the full extent of
the policy limit of $1 million. The umbrella insurer denied coverage for any
additional payments, contending that as the CGL insurer did not pay its full $1
million, the loss payable condition was not triggered.
Upon appeal, the Missouri Supreme Court disagreed with the umbrella insurer,
concluding that the underlying CGL limit requirement of $1 million was met. The
court went on to explain that the loss payable condition was not dependent on
the underlying limit being "fully exhausted by cash payment" before
the umbrella insurer was obligated to pay, and "the policy recognized that
the underlying limits of insurance may be fulfilled by something other than
insurance. Here, the underlying limits of insurance were met by a settlement
that consisted of a settlement of a $700,000 payment and a $300,000 release,
totaling $1 million."
In sum, the wording in the loss payable condition needs to be carefully
reviewed and understood by the buyer, particularly when viewed through the lens
of claims in which the underlying insurer may not have paid its full limits,
but which the insured is obligated to pay damages in amounts that exceed the
underlying limits.
Point Five—What about Those Aggies?
Of course, this reference is to the aggregate limit or limits shown on the
umbrella declarations page and also found within the limits section of the
umbrella policy.
For example, an umbrella policy that lists on its declarations page that the
policy limit is $25 million each occurrence and $25 million annual aggregate
should raise questions. Is the insurer providing aggregate limits that are
different from the underlying policies? Is the intent to impose an aggregate
limit for policies that do not include an aggregate in the underlying
insurance, such as the business auto liability coverage? Does one annual
aggregate limit actually mean it is the most the umbrella insurer will pay in
total for the policy year, despite the fact that an underlying policy includes
multiple aggregate limits, such as the CGL (a general aggregate limit and a
separate products-completed operations aggregate limit)? Or does it mean that
separate aggregate limits may apply to each underlying policy, such as the
employers liability policy limit for disease or the liquor liability aggregate
limits?
Most Favorable
The following wording is offered and may be the most favorable to an
insured.
SECTION III—LIMITS OF INSURANCE
1. The Limit of Insurance shown in the Declarations as EACH OCCURRENCE is
the most we will pay for damages arising out of any one occurrence or
offense.
2. The Limit of Insurance shown in the Declarations as AGGREGATE WHERE
APPLICABLE shall apply in the same manner as the aggregate limits shown in
the SCHEDULE OF UNDERLYING INSURANCE.
In the above wording, the umbrella declarations will list the aggregate
limit as applying "where applicable" in lieu of "annual
aggregate," and, thus, the umbrella will apply its aggregate limits in the
same manner as the aggregate limits are shown in the schedule of underlying
insurance.14 No aggregate would apply to the
business auto liability coverage; the aggregate limit in the umbrella would
apply in the same manner as the CGL (separately to general aggregate limit and
to the products-completed operations limit). If liquor liability is listed with
an aggregate limit, then the umbrella will apply its aggregate limit separately
for liquor claims, and so on.
Per-project or per-location general aggregate limit. If the
underlying CGL policy is written with a per-project or per-location general
aggregate limit, the above wording would also require the umbrella aggregate to
apply per-location or per-project basis—as this would be "in the same
manner" as the aggregate limits of the underlying insurance as shown in
the declarations. A word of warning—an umbrella insurer may endorse the
umbrella policy to restrict the umbrella aggregate limit to a maximum annual
amount, regardless of the number of locations or projects—which change will
only be revealed by review of the entire umbrella policy, including all
endorsements.
Less Favorable
A less desirable but common umbrella aggregate limit arrangement is to
include one general aggregate limit that applies to all underlying insurance
except business auto claims or products-completed operations claims. A separate
aggregate limit will apply and be shown on the umbrella policy for the
products-completed operations hazard. Such an arrangement would be provided by
the following wording (in pertinent part).
B. The General Aggregate limit stated in Item 3 of the Declarations is the
most we will pay for all damages under this policy, except for:
- Damages included within the Products-Completed Operations Hazard;
and
- Damages because of Bodily Injury or Property Damage to which this
policy applies, caused by an Occurrence and resulting from the ownership,
maintenance or use of an Auto covered under the Schedule of Underlying
Insurance.
C. The Products-Completed Operations Aggregate limit stated in 3C of the
Declarations is the most we will pay for damages included in the
Products-Completed Operations Hazard.
This "one general aggregate" approach does not apply in
the same manner as the underlying policies' aggregate limit. For example,
the umbrella general aggregate would be exhausted by payment of any
claims (except auto and products-completed operations hazard) including
employers liability or liquor liability claims. Further, the umbrella general
aggregate would not apply per project or per location, even if the underlying
CGL is written with a per-project or per-location general aggregate limit.
Least Favorable
The least desirable arrangement of the umbrella limit arrangements is to
apply one annual aggregate limit to all umbrella claims, regardless of whether
the underlying policy included an aggregate limit, if the underlying policies
included multiple aggregate limits or more than one underlying policies
included an aggregate limit.
A more common "middle ground," which is less favorable than
applying the aggregate limits of the umbrella in the same manner as the
underlying policies, is to apply one annual aggregate limit to all but auto
claims, meaning that a separate aggregate limit does not apply to the
products-completed operations hazard. Wording that is typical of this approach
is as follows (in pertinent part).
The Aggregate Limit is the most we will pay for the sum of all
"ultimate net loss" under:
- Coverage A, except "ultimate net loss" because of
"bodily injury" or "property damage" arising out of the
ownership, maintenance or use of a "covered auto"; and
- Coverage B.15
In sum, there exists a wide variation in how umbrella insurance arranges
aggregate limits—the implication being that a buyer should not be content with
only "$25 million excess of primary," as there may be substantial
differences among umbrella policies that have not been considered.
Conclusion
There is a certain irony to giving short shrift to a liability policy that
is only important when damages from a liability claim may be in the range of
tens of millions of dollars. In other words, it is not advisable to review your
umbrella policy or policies for the first time only after being faced with a
complaint that alleges liability for damages in the millions of dollars.
The purpose of this article is to point out some critical issues to look for
in your commercial umbrella policy. In other words, while this article is not
intended as an exhaustive review of all of the issues that you may need to
understand a commercial umbrella policy, this may be regarded as a starting
point. Looking for something specific often makes the task a little less
daunting and maybe even a little less tedious.