How to Challenge Insurance Company Comparable Vehicles (Comps)
How to Challenge Insurance Company Comparable Vehicles (Comps)
When your vehicle is totaled, the insurance company's valuation hinges on one critical element: comparable vehicles (comps). These are supposedly similar vehicles that recently sold in your area, and their average sale price becomes your settlement offer.
But here's the problem: Insurance comps are frequently wrong, outdated, or deliberately skewed to lower your payout. Most people don't know how to identify these flaws—or that they can challenge them.
This tactical guide will show you exactly how to spot invalid comparables, document their deficiencies, and force insurance companies to adjust your valuation using proper market data.
Table of Contents
- What Are Insurance Comparables and Why They Matter
- How Insurance Companies Source Comps
- The 7 Most Common Comparable Flaws
- How to Get Your Comparable Vehicle Report
- Analyzing Each Comp: What to Look For
- Building Your Challenge: Documentation That Works
- Presenting Your Challenge to the Adjuster
- When to Request a Larger Search Radius
- Understanding Why You Can't Cherry-Pick Comps
- Using MRR Review for Better Results
- FAQ
What Are Insurance Comparables and Why They Matter
Comparable vehicles (comps) are similar vehicles to yours that have recently sold in your geographic area. Insurance companies use the average of these comp sale prices to determine what your totaled vehicle is worth.
The Comp Formula
Your Settlement = (Average of Comp Prices) - Prior Damage - Deductible
If insurance uses:
- 3 comps at $15,000 each = $15,000 offer
- 3 comps at $14,000 and 6 at $16,000 = $15,330 offer
- 9 comps ranging $13,000-$17,000 = ~$15,000 offer
Small changes in comp selection = Big changes in your payout.
Why This Matters
One bad comp can reduce your settlement by $500-$1,500. Multiple flawed comps? You could be underpaid by $2,000-$5,000.
As one insurance claims expert noted:
"If you just happily exclude the ones that lower your value, no wonder you expect it to be more. That's not how this works and it's unreasonable to assume they will drop the low ones you don't like."
The key is challenging comps that are genuinely not comparable—wrong trim, rebuilt title, excessive mileage difference, outdated data.
How Insurance Companies Source Comps
Understanding the process reveals why so many errors occur.
The Vendor Chain
Insurance companies don't manually search for comps. They use a chain of third-party vendors:
Primary Insurer (Progressive, State Farm, etc.) ↓ Valuation Company (CCC, Mitchell, Autosource) ↓ Data Aggregator (Third-party service) ↓ Contract Workers (1099 workers paid per comp)
Each layer prioritizes speed over accuracy.
As one industry insider revealed:
"Insurers use a third-party company who uses AI to source and adjust the total loss. That company uses a third party company to provide the comps—who uses a third party company that pays bottom dollar to 1099 people to get photos and sale info. From what I've seen, they are focused on speed vs. accuracy."
What This Means for You
- Comps are often pulled automatically by AI
- Human verification is minimal
- Errors are common and expected
- The system assumes you won't check
- Challenging comps is built into the process
You're supposed to review and challenge. It's not adversarial—it's part of the system.
The 7 Most Common Comparable Flaws
1. Wrong Trim Level
Impact: $1,500-$3,500 depending on vehicle
Your vehicle: 2016 Honda CR-V EX-L (leather, sunroof, power seat) Their comp: 2016 Honda CR-V LX (base model, cloth seats, manual seat)
Trim packages add significant value:
- Honda CR-V: LX vs EX-L = $2,000-$2,500
- Toyota Camry: LE vs XLE = $2,500-$3,500
- Ford F-150: XL vs Lariat = $5,000-$8,000
How to spot it:
- Check the comp listing details for trim designation
- Verify packages (leather, technology, premium audio)
- Compare standard features to your vehicle
2. Significant Mileage Difference (15,000+ Miles)
Impact: $800-$1,500 per 15,000-mile gap
Your vehicle: 72,000 miles Their comp: 89,000 miles (17,000 mile difference)
Mileage value scale (approximate):
- Under 50,000 miles: Premium pricing
- 50,000-75,000: Standard market value
- 75,000-100,000: Moderate depreciation
- 100,000-125,000: Higher depreciation
- 125,000+: Significant discount
Threshold for challenge:
- 10,000-15,000 miles = questionable
- 15,000+ miles = definitely challenge
- 25,000+ miles = absolutely invalid
Insurance systems theoretically adjust for mileage, but starting with high-mileage comps artificially lowers the baseline.
3. Rebuilt or Salvage Titles
Impact: 20-40% lower value (absolutely unacceptable comp)
Your vehicle: Clean title Their comp: Rebuilt title or Salvage title
This is never acceptable. Clean title vehicles should only be compared to clean title comps. The value gap is enormous:
- $18,000 clean title vehicle
- $11,000-$14,000 rebuilt title equivalent
One poster shared their frustration:
"The only sales listings that low are rebuilt titles. The going price for my vehicle seems to be $16-20k, but they gave it a $15,130 value."
How to spot it:
- Request full comp report with title status
- Search VIN on Carfax/AutoCheck if provided
- Look for phrases like "rebuilt," "salvage," "branded title"
If they used salvage comps: Automatic challenge.
4. Outdated Sales Data (3+ Months Old)
Impact: $500-$2,000 depending on market changes
Markets shift. Comps should reflect current conditions, not last season's market.
Age guidelines:
- Under 30 days: Excellent
- 30-60 days: Acceptable
- 60-90 days: Questionable
- 90+ days: Challenge if market has shifted
Seasonal factors matter:
- SUVs/trucks worth more in fall/winter
- Convertibles worth more in spring/summer
- Market inventory changes affect pricing
One commenter noted the deliberate timing:
"Let me guess—the dates on all of the comps are 1-3 months prior and the listings have been removed from online searches."
Challenge outdated comps in shifting markets.
5. Geographic Mismatch (Wrong Market)
Impact: $1,000-$4,000 depending on markets
Your vehicle: St. Louis, Missouri Their comp: Rural Missouri, 250 miles away
Markets have different pricing:
- Urban vs rural: 10-20% difference
- High-demand vs low-demand areas: Significant variation
- Different states: Sales tax, registration, market conditions
Distance thresholds:
- Under 50 miles: Generally appropriate
- 50-150 miles: Acceptable if same market type
- 150-300 miles: Question if crossing market types
- 300+ miles: Likely inappropriate unless rare vehicle
When to challenge:
- Rural comps for urban vehicle
- Different state with significantly different market
- Low-demand area comps for high-demand area vehicle
6. Dealer vs Private Party Mix
Impact: $1,000-$2,500 (dealer listings worth more)
Insurance should use consistent comp sources:
- All dealer sales, or
- All private party sales, or
- Disclosed mix with appropriate adjustments
Dealer pricing includes:
- Warranty/guarantee
- Reconditioning
- Overhead
- Dealer reputation value
Private party pricing is lower for the same vehicle.
Mixing without adjustment skews valuation low if they use private party sales to reduce dealer-heavy averages.
7. Incorrect Options/Equipment
Impact: $300-$2,000 depending on options
Their comp list may show your vehicle is missing:
- Navigation system (you have it)
- Leather seats (you have it)
- Sunroof (you have it)
- Premium wheels (you have them)
This is actually a valuation error (covered in another guide), but also affects comp matching. Insurance might use base model comps for your loaded vehicle.
How to Get Your Comparable Vehicle Report
Step 1: Request the full valuation report
Call or email your adjuster:
"I'd like to review the complete valuation report including all comparable vehicles used, with the following details for each comp: year, make, model, trim level, mileage, sale price, sale date, location, title status, and source."
Step 2: Request digital access if available
Many insurers have online portals where you can access:
- CCC report
- Mitchell valuation
- Autosource report
Step 3: Verify you receive ALL comps
Insurers must show you what they're using. If they refuse:
- File complaint with insurance commissioner
- Mention this violates fair claims practices
- Request supervisor review
Analyzing Each Comp: What to Look For
Create a spreadsheet to systematically review each comp:
Comp Analysis Worksheet
| Comp # | Year | Make/Model | Trim | Mileage | Price | Date | Distance | Title | Issues |
|---|---|---|---|---|---|---|---|---|---|
| 1 | 2016 | Sienna LE | Base | 89k | $15,000 | 8/15 | 45 mi | Clean | +17k miles, base trim |
| 2 | 2016 | Sienna XLE | XLE | 71k | $17,200 | 9/2 | 38 mi | Clean | Good match |
| 3 | 2016 | Sienna | ? | 94k | $13,900 | 7/20 | 180 mi | Rebuilt | REBUILT + old + miles |
Red Flags to Mark
- ⚠️ Mileage difference over 15,000
- ⚠️ Wrong trim level
- 🛑 Rebuilt/salvage title (automatic disqualification)
- ⚠️ Sale date over 90 days old
- ⚠️ Distance over 200 miles
- ⚠️ Missing key options your vehicle has
Building Your Challenge: Documentation That Works
Format Your Challenge Document
Part 1: Professional opening
Subject: Valuation Review Request - Claim #[CLAIM_NUMBER]
Dear [Adjuster Name],
I have reviewed the comparable vehicle report for my 2016 Toyota Sienna
XLE (72,000 miles, clean title). I respectfully request review and
adjustment based on the following discrepancies in the comparables used.
Part 2: Comp-by-comp challenges
COMPARABLE #3 - REQUEST REMOVAL
Vehicle: 2016 Toyota Sienna LE
Sale Price: $13,900
Issues:
1. WRONG TRIM: Base LE model vs my XLE trim
- My vehicle has: leather, power liftgate, navigation, premium audio
- Comp has: cloth seats, manual liftgate, no navigation
- Typical XLE premium: $2,500-$3,000
2. MILEAGE DIFFERENCE: Comp has 94,000 miles vs my 72,000 miles
- 22,000 mile difference
- Value impact: ~$1,200
3. TITLE STATUS: Comp shows rebuilt title (confirmed via Carfax)
- My vehicle: clean title
- Rebuilt titles worth 25-35% less
- This comp is fundamentally not comparable
Request: Remove Comparable #3 from valuation
Part 3: Supporting evidence
Attach:
- Screenshots of comparable vehicles you found
- Dealer quotes for similar vehicles
- CarFax showing title status if applicable
- Photos proving equipment exists
Part 4: Professional close
I've attached documentation showing current market data for vehicles
truly comparable to mine. I request review by the Material Damage
Representative (MRR) and adjustment to reflect accurate market value.
Thank you for your attention to this matter.
Example: Before and After
Before (ineffective):
"Your comps are terrible. I can't find any Siennas for $15k. You're trying to rip me off."
After (effective):
"Comparables #1, #3, and #5 are base LE trim models with cloth seats and no navigation. My vehicle is XLE trim with leather, navigation, and premium audio—representing a $2,500-$3,000 value difference. I request these comps be replaced with XLE trim comparables or appropriate upward adjustment applied."
Presenting Your Challenge to the Adjuster
Timing Matters
Best practice:
- Submit challenge within 7-10 days of receiving valuation
- Follow up in 5 business days if no response
- Escalate after 10 business days of no response
Who to Contact
Level 1: Desk Adjuster
- Initial contact
- Can make small adjustments
Level 2: MRR (Material Damage Representative)
- Vehicle valuation specialist
- More authority and expertise
- Request this level explicitly
As one insider advised:
"Put that in a neat file for your adjuster to give the MRR (the actual vehicle adjuster not the desk one) and ask them to review it."
Level 3: Supervisor
- When lower levels won't budge
- Can authorize larger adjustments
What to Expect
Likely outcomes:
- Minor adjustments ($200-$500): Common
- Moderate adjustments ($500-$1,500): With good evidence
- Major adjustments ($1,500+): Typically requires appraisal
Timeline:
- Initial response: 3-5 business days
- Revised valuation: 1-2 weeks
- MRR review: 1-2 weeks additional
When to Request a Larger Search Radius
Insurance typically searches within 50-150 miles. Sometimes you need a wider search—other times you need a narrower one.
Request Smaller Radius When:
- You're in a major metropolitan area
- Plenty of local inventory exists
- Comps from 200+ miles away don't reflect your market
- Urban vs rural pricing differs significantly
Request Larger Radius When:
- Rare or uncommon vehicle
- Limited local inventory
- Rural area with few sales
- Specialty vehicle (diesel, hybrid, performance model)
Example request:
"My area (Chicago metro) has substantial inventory of 2016 CR-Vs. The comparables from 250+ miles away in rural areas don't reflect the Chicago market where replacement vehicles cost 15-20% more. Please limit the search to 75 miles to reflect my actual replacement market."
Understanding Why You Can't Cherry-Pick Comps
Important reality check: You can't just throw out all low comps because you don't like them.
Insurance includes a range of comps (high and low) to ensure proper market averaging. As one adjuster bluntly explained:
"You don't get to pick and choose comparables. They have to include many to make sure the rate is proper. If you just happily exclude the ones that lower your value, no wonder you expect it to be more."
What You CAN Do
✅ Challenge comps that are objectively not comparable:
- Wrong trim level
- Rebuilt title vs clean title
- Excessive mileage difference
- Outdated sales data
❌ What you CAN'T do:
- Exclude comps just because they're low
- Demand they only use your hand-picked comps
- Insist on only dealer prices vs actual sales
The Strength of Numbers
When insurance has 9 comparables supporting their number, your challenge needs to be specific and evidence-based.
"With 9 comps, Progressive will likely not consider anything you provide. I highly suggest contacting your own appraiser for a quote and consult on the offer."
Strategy with extensive comps:
- Focus on the worst offenders (rebuilt title, wrong trim)
- Request MRR review
- Consider appraisal clause
- Get independent appraiser consultation
Using MRR Review for Better Results
The Material Damage Representative (MRR) is the actual vehicle valuation specialist, not the desk adjuster who might have called you.
Why MRR Matters
- Vehicle valuation expertise (not just general claims)
- More authority to adjust valuations
- Access to additional comps and market data
- Can override automated system results
How to Request MRR Review
In your challenge letter:
"I request review by the Material Damage Representative (MRR) who specializes in vehicle valuations. Please forward my documentation and comparable evidence to the MRR for evaluation."
Or when speaking to adjuster:
"I'd like to have the MRR review my evidence and provide a professional assessment of whether these comparables accurately reflect my vehicle."
What to Prepare for MRR
- Organized documentation (spreadsheet of comp analysis)
- Specific challenges (not vague complaints)
- Supporting evidence (dealer quotes, clean title proof, photos)
- Professional tone (you're requesting expert review)
MRR reviews typically take 1-2 weeks but produce better results than desk adjuster back-and-forth.
FAQ
How many comparables should insurance use?
Typically 3-9 comparables. Some states mandate minimums (often 3). More comps generally favor insurance because it dilutes the impact of any single comp—but also makes obvious outliers more apparent.
Can I request insurance use specific comparables I found?
You can provide them as evidence, but insurance will verify they're actual sales (not just listings) and meet their data requirements. Listing prices aren't the same as sale prices.
What if all the comps are genuinely bad?
Request a larger geographic radius, invoke your appraisal clause, or hire an independent appraiser. If the local market truly has no comparable vehicles, insurance must adjust their methodology.
Does challenging comps affect my claim timeline?
Yes, expect 1-3 additional weeks. However, getting an extra $2,000-$4,000 is usually worth the delay. Most people can get rental car coverage extended during valuation disputes.
Can insurance use private party sales for comps?
Yes, but they should be consistent. Mixing dealer and private party sales without adjustment can skew values. Ask what type of sales they're using.
What if I can't find the original comp listings online?
This is common—listings disappear after sales. Ask insurance for screenshots or documentation of the original listings. They should have archived data.
Are dealer sales comps worth more than private party?
Yes. Dealer sales include warranty, reconditioning, and overhead. If insurance uses dealer comps, you should get dealer-equivalent value. If using private party, value should reflect that market.
Conclusion
Challenging insurance comparables isn't about being difficult—it's about ensuring accuracy. Automated systems make mistakes. Third-party vendors prioritize speed. Comps often have significant flaws.
Your systematic approach:
- Request full comparable report with all details
- Analyze each comp for trim, mileage, title status, age, location
- Document specific issues (not vague complaints)
- Build professional challenge with evidence
- Request MRR review for expert evaluation
- Follow up within 5 business days
- Escalate to appraisal if warranted
Most importantly: Challenge the right things. Focus on comps that are genuinely not comparable—wrong trim, rebuilt titles, excessive mileage gaps, outdated data. Don't try to cherry-pick only high comps you like.
Insurance adjusters expect some pushback on comps. It's built into the process. Organized, specific challenges get results. Vague complaints don't.
The difference between accepting flawed comps and challenging them systematically: $1,500-$4,000 on average. That's your money.
This guide is based on analysis of real insurance valuation disputes and industry practices. Consult your specific policy and state regulations for applicable procedures.