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Arbitration Forums News
E-Subro Hub Users
May 13, 2026
E-Subro Hub: A Quick Guide to the My Team Option
The My Team option in E-Subro Hub can be used to view a group of users, which may be helpful for those managing a team.
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E-Subro Hub Users
May 13, 2026
Member Companies Join E-Subro Hub
On March 30, 2026, two member companies were added to E-Subro Hub.
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E-Subro Hub Users
March 19, 2026
Enhancements Coming Soon to E-Subro Hub
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TRS® Frequently Asked Questions
Add your damages as you normally would so the damages are considered when the case is heard. Use the Liability Arguments to explain your position so the arbitrator understands your position.
GAP insurance is not recoverable because it is not for damages incurred in the loss. GAP coverage is payment due to an excess amount owed on a loan between the loaner and loanee. Even though GAP insurance is paid when a vehicle is a Total Loss, it is not damages that would be owed by a negligent tortfeasor who is only obligated to reimburse for the value of the vehicle.
Yes, please see the discussion of Rule 2-4 in the Reference Guide to Arbitration Forums, Inc.'s Agreements and Rules.
Yes, our system will not block a filing, as there are instances where the late filing may be permissible. For example, under Rule 1-2, if a matter is in litigation and it is determined that all parties are represented by signatory companies, arbitration must be filed even if the statute of limitations has expired. It must be noted, though, that arbitration must be filed within 60 days of dismissal, or the Responding Party will be free to assert the delay as a jurisdictional exclusion.
Yes, AF encourages adding any additional responding companies when completing your response.
No, the arbitration agreements administered by AF are available only to insurers, self-insureds, or commercial insureds with large retentions/deductibles, not individuals–even if they should wish to participate. Their participation is excluded under the individual agreements.
A video file may be uploaded and attached to a filing.
If a party wishes to have video evidence viewed by the arbitrator, it must declare the tape, DVD, etc. as evidence. The member must also request a personal appearance. AF will contact the member representative to schedule a videoconference for the arbitrator to view the declared evidence.
In the event a member is unable to participate or share evidence via videoconferencing, AF will make arrangements with the member to provide the evidence to be viewed by an arbitrator, or the member may present the video evidence in person and must arrange for equipment to be available to present the evidence to the arbitrator.
In the case of audio evidence (such as recorded statements), AF requires the written transcript of the recording to be declared and provided as evidence for the arbitrator to view.
If a party wishes to have video evidence viewed by the arbitrator, it must declare the tape, DVD, etc. as evidence. The member must also request a personal appearance. AF will contact the member representative to schedule a videoconference for the arbitrator to view the declared evidence.
In the event a member is unable to participate or share evidence via videoconferencing, AF will make arrangements with the member to provide the evidence to be viewed by an arbitrator, or the member may present the video evidence in person and must arrange for equipment to be available to present the evidence to the arbitrator.
In the case of audio evidence (such as recorded statements), AF requires the written transcript of the recording to be declared and provided as evidence for the arbitrator to view.
Yes, video evidence such as dash cam or security videos can be submitted in the TRS platform.
- The file size cannot exceed 40MB.
- Acceptable file types are .mov, .wmv, .avi, .mp4, and .vob.
- All submitted video file types are converted to .mp4 format to eliminate any compatibility issues for the arbitrator.
- Bookmarking may be used on lengthy videos to indicate points of interest to the arbitrator.
- Examples of appropriate video evidence include: dash cam video of accident, security video showing accident, and video of scene.
- Links to external websites like YouTube as evidence are not permitted. AF and our member companies whose arbitrators hear cases remotely, prohibit access to external links as part of its IT security policy to prevent the spread of viruses, malware, etc.
There are two coverage questions for the responding company to answer: "A liability policy was in effect at the time of loss" and "has coverage been denied for this claim."
For the first question, the respondent will check "Yes" if the listed Insured, as identified by the recovering company, is an insured under a liability policy or is self-insured for liability. Check "No" if the listed insured is not insured under a liability policy, the policy expired, the insured has collision coverage only (no liability coverage), or the listed self-insured has liability coverage with a carrier. If the responding company answers "No" to the first question (i.e., no liability policy in effect or policy expired prior to loss), the responding company will be placed out of jurisdiction. If this is the only responding company, the filing will be closed/withdrawn.
If the respondent answers "Yes" to the first question, it must then answer the second. If it answers “Yes” that coverage has been denied to the company seeking coverage for the loss in dispute, it must submit a copy of the denial letter to that party as evidence. If submitted, the party will be placed out of jurisdiction (per Article Second (e)). If a denial letter is not submitted, the case will proceed to hearing wherein the coverage defense will be considered by the arbitrator(s).
For the first question, the respondent will check "Yes" if the listed Insured, as identified by the recovering company, is an insured under a liability policy or is self-insured for liability. Check "No" if the listed insured is not insured under a liability policy, the policy expired, the insured has collision coverage only (no liability coverage), or the listed self-insured has liability coverage with a carrier. If the responding company answers "No" to the first question (i.e., no liability policy in effect or policy expired prior to loss), the responding company will be placed out of jurisdiction. If this is the only responding company, the filing will be closed/withdrawn.
If the respondent answers "Yes" to the first question, it must then answer the second. If it answers “Yes” that coverage has been denied to the company seeking coverage for the loss in dispute, it must submit a copy of the denial letter to that party as evidence. If submitted, the party will be placed out of jurisdiction (per Article Second (e)). If a denial letter is not submitted, the case will proceed to hearing wherein the coverage defense will be considered by the arbitrator(s).
The Feature Damage workflow step must be used to dispute the amount of damages sought by the filing company. Please refer to the discussion of Rule 2-5 in the Reference Guide to Arbitration Forums, Inc.'s Agreements and Rules.
If the unnamed party is a signatory, you will add them as a responding company. You will present your liability position in your liability arguments.
If the unnamed party is not a signatory, you can secure its consent to participate in the arbitration and then add it as a responding company. You may need to contact AF to have a non-signatory company code created. Alternatively, you may simply present your liability position in your liability arguments and argue the unnamed party’s negligence. In this scenario, the recovering company may withdraw its filing if it wishes to pursue all parties outside arbitration. If the filing is not withdrawn, the arbitrator(s) will apportion liability and award damages, if applicable, against the named responding company. The filing company is barred from pursuing further recovery.
If the unnamed party is not a signatory, you can secure its consent to participate in the arbitration and then add it as a responding company. You may need to contact AF to have a non-signatory company code created. Alternatively, you may simply present your liability position in your liability arguments and argue the unnamed party’s negligence. In this scenario, the recovering company may withdraw its filing if it wishes to pursue all parties outside arbitration. If the filing is not withdrawn, the arbitrator(s) will apportion liability and award damages, if applicable, against the named responding company. The filing company is barred from pursuing further recovery.
If the recovering company asserts and supports that Joint and Several Liability applies to the filing, the arbitrator must follow local law and apply it in the arbitration. Local law controls the decisions, and the parties neither gain nor lose any rights in arbitration that they have in litigation.
In situations where one of parties is non-signatory and has not granted AF consent to hear the arbitration, AF does not have jurisdiction over the non-signatory company or the claim, pursuant to Article Second. In such cases, the signatory company should raise a Jurisdictional Exclusion for Subrogation Prohibited, as AF is unable to resolve the liability or primary and excess coverage issue.
In situations where one of parties is non-signatory and has not granted AF consent to hear the arbitration, AF does not have jurisdiction over the non-signatory company or the claim, pursuant to Article Second. In such cases, the signatory company should raise a Jurisdictional Exclusion for Subrogation Prohibited, as AF is unable to resolve the liability or primary and excess coverage issue.
Since the unnamed alleged tortfeasor is a phantom, arbitration would retain jurisdiction as the dispute is between two members. The named responding company will need to argue their respective liability position. The arbitrator(s) will apportion liability and award the recovering company what it is owed by the named responding company.
The damages being sought determine which forum is compulsory. If you are seeking recovery of auto damages, you must file in Auto; if you are seeking recovery of property damage, you must file in Property. The respondent's liability coverage is irrelevant to the coverage under which the filing is submitted. A responding company can be an auto liability, homeowner's liability, general liability, products liability carrier, etc., as long as the responding company is signatory to the forum in which the dispute is filed.
Yes, assuming the damages were paid under the auto coverage. The car seats would be listed under the “Personal Property” damage type.
If the responding company does not properly assert and support its policy limit coverage defense, or it fails to assert it at all, an amount in excess of the limits may be awarded. Rule 3-9 affords a responding company time after the decision publication to raise limits. If the policy limits are not raised/supported in the response or within the time frame allowed under Rule 3-9, then the excess award would be binding.
No. The deferment fee is assessed at the case level not the feature level, so only one fee is incurred.
There is nothing in the arbitration agreements or rules that compels a signatory to pay an adverse insured's claim. The Intercompany Arbitration Agreements bind the signatory companies to arbitrate disputes among themselves. The insured is not a party to the agreement. Article Third of the various agreements specifically states that an arbitration decision is "neither res judicata nor collateral estoppel to any other claim or suit arising out of the same accident, occurrence, or event" and "conclusive only of the issues in the matter submitted to the panel and only as to the parties to the arbitration." That said, the adverse company’s insured’s claim can be voluntarily paid.
A responding company may assert denial of coverage for this reason. Per Rule 2-4, if they submit a denial of coverage letter to the appropriate party advising them that coverage is being denied due to noncooperation or no notice, etc., the responding company will be placed out of jurisdiction. If no such letter is submitted, the case will proceed to a hearing. The arbitrator will consider the coverage defense, and any evidence submitted to support it. The arbitrator will either uphold or deny the defense. It should be noted that each state may have different "requirements" that a carrier must comply with to uphold such a defense.
Below are the states where intercompany arbitration is mandatory per state statute, and AF is specifically named as the administrator. The source is also provided; however, this is subject to change, and AF does not guarantee accuracy. For other states that mandate arbitration for disputes between insurers but do not specifically designate AF as the provider, arbitration would be compulsory if all parties are signatories to the Personal Injury Protection (PIP) arbitration agreement for the loss state; arbitration may also be filed with consent.
| State | Source | Forum |
| DC | § 31-2405 (i) | Auto Arbitration |
| DE | 21 Del. C. § 2118(g)(3) | Auto, PIP, Property, and Special (when claim involves DE registered motor vehicle) |
| KY | KRS 304.39-070 | PIP (Authority for PIP arbitration is given to KIAA, whose rules reflect that either the KIAA or AF may be selected for arbitration) |
| MD | Insurance Code 19-514 | Auto Arbitration |
| MN | § 65B.53 | PIP Arbitration |
| NY | § 65-4.11 of Regulation 68 | PIP Arbitration (Loss Transfer/Priority of Payment) |
| VA | § 38.2-2231 | Auto Arbitration |
An affirmative defense bears only the authority of an arbitrator on behalf of Arbitration Forums, Inc. to decide the dispute in arbitration. It has no bearing on the right of recovery in any other venue and is NOT a finding of no liability. It means only that Arbitration Forums has no authority over, or may not decide, the dispute.
Decisions may not be shared with insureds.Insureds do not understand the intercompany arbitration process that the membership has agreed to use to resolve their subrogation disputes. Further, the insured is not a party to the arbitration; only the interests of the signatory companies are involved. Signatories are free to handle their insured's claims as they deem appropriate, i.e., refund deductible, assess no liability, regardless of the arbitration decision.
No. Each forum includes a monetary limit for compulsory disputes. If the claim exceeds this amount, the matter is outside arbitration's jurisdiction. Arbitration might still be filed with written consent, or the recovering company may file arbitration for the compulsory limit and waive pursuit of the balance of the claim.
The distinction between proof of payment and proof of damages is important. Proof of payment is a must only when a recovering company, through its answer, asserts the Jurisdictional Exclusion of Subrogation Prohibited arguing the lack of a subrogatable claim. If not challenged, the presumption is the recovering insurer has made payment to its insured and a subrogation claim exists. A challenge should not simply be raised because the recovering party did not list proof of payment in its evidence listing. We don’t want to require the submission of unnecessary documentation. While it is not a requirement to submit proof of payment to prove damages, we recommend it be included in the evidence. Many arbitrators find it useful to verify if the recovering company has listed its damage claim correctly (e.g., not included its deductible twice, deducted its salvage return). It is also of particular benefit when there are prior partial payments.
NOTE: The above does not apply to self-insured members that own and repair their vehicles, as there would be no payment to a repair facility.
NOTE: The above does not apply to self-insured members that own and repair their vehicles, as there would be no payment to a repair facility.
KRS 304.39-070 gives insurers two options for resolving disputes: (1) joining as a party in an action that may be commenced by the person suffering the injury, or (2) filing intercompany arbitration. If an insurer opts (1), Rule 1-2 cannot be enforced; the statute takes precedence. This applies specifically to Kentucky PIP claims.
Kentucky statutory authority for PIP arbitration is given to KIAA whose rules reflect that either the KIAA or AF may be selected for arbitration.
No, but it is strongly recommended to ensure optimal recovery. This is especially true when a responding company has policy limits, and there are multiple exposures. Recovering companies should be aware that by allowing the filing to be heard, they are agreeing to accept any award against a responding company and waive their right to pursue the balance directly from any unnamed party.
When you file, list your correct company code. The company code listed is used for billing purposes (i.e., filing fee, reschedule fee). When you are the responding company, correct your company when responding, if the recovering company has listed the incorrect subsidiary. Indicating the correct company when filing and responding eliminates any billing errors.
Yes, since you are seeking recovery for auto damages. The Auto forum is compulsory if the car wash’s liability insurer is a signatory. The type of damages sought determines which forum is compulsory, not the type of coverage afforded by the responding company. A responding company can be an auto liability, homeowner's liability, general liability, products liability carrier, etc. So, if the carrier is a signatory to Auto, arbitration is compulsory.
Yes, especially when liability is accepted, and the only disputed issue is damages. The responding company is the party that determines the issue(s) to be decided by the arbitrator. By entering a percentage of liability in the "I admit ____% liability" field, the responding company is advising the arbitrator that it concedes this amount of liability. The arbitrator can find the responding company more liable than it admitted but not less.
To document a denial of coverage, a denial letter must be directly addressed to the entity for whom coverage is denied (or the party seeking coverage) informing them of the denial (not always the named insured). A letter to another entity (i.e., any third party with a liability claim/action) regarding the denial is not sufficient for purposes of Rule 2-4. This includes correspondence that "copies" the entity for whom coverage is denied.
- Rule 4-2 allows AF to amend or void a decision if a clerical or jurisdictional error was made by the arbitrator or AF.
- Rule 3-9 allows AF to amend or void a decision for certain coverage defenses (no liability policy in effect on loss date, coverage denied, policy limits, etc.).
- Rule 2-12 allows a party to appeal a decision (Property and Special forums only).
The Filing Party has a choice to arbitrate against only the signatory party or file an action for recovery in a court against all negligent parties. If the Recovering Party chooses to arbitrate the dispute, it may NOT later file another action in court against the non-signatory. By choosing to pursue recovery via arbitration, the Recovering Party waives any right to pursue other parties separately outside of arbitration's jurisdiction.
A deferment is a one-year postponement of a hearing due to the existence of a companion claim or suit that may impact the arbitration. A deferment is not to be requested simply to get more time to prepare/submit a response. When considering whether to uphold a deferment request, the arbitrator will look at what effect the arbitration hearing will have on the companion claim/suit and vice versa. Since the arbitration decision is neither res judicata nor collateral estoppel, it, in itself, should have no effect on the companion claim/suit. Some reasons a deferment may be warranted include policy limits (including combined single-limit policy), discovery still in progress (results of which will be used in arbitration as well as litigation), and active fraud investigations. In closing, if you request a one-year deferment, you must effectively justify and support the request (deferment justification section), so the arbitrator understands why the companion claim/suit must be resolved first.
An arbitrator's decision must always be based solely on the evidence that is submitted. In cases where conflicting versions of an accident/loss are presented (i.e., conflicting insured versions of a motor vehicle accident), and no other evidence corroborates either insured's version, determining liability will most likely be impossible. An exception would be where the Recovering Party is an innocent party (i.e., parked or legally stopped vehicle) seeking recovery from multiple Responding Parties whose accident caused their damages. In these cases, while the specific liability percentage of the respective Responding Parties may not be determined, the Recovering Party has proven that its damages were the result of the accident, and an award may be apportioned equally amongst the Responding Parties.
- Create a Word document titled “Video Evidence.”
- While you complete the filing or response, select the “Video Evidence” evidence type and attach the Word document.
- Select the “Personal Appearance” option.
- AF will schedule a personal appearance hearing, so you can share the video with the arbitrator.
Use the “Add Deferment” option in the Case Actions drop-down menu. We recommend this action be taken before submitting the filing or response. The deferment will be automatically granted. An adverse company may challenge the deferment if it believes the delay is not warranted. If challenged, the deferment will be ruled on by an arbitrator. If the request is upheld, the case will be deferred for one year from the date of filing. If the request is denied, the parties will be prompted to complete their filing or response.
Rule 5-2 provides the process to follow to secure payment of an award. The rule also contains language that permits the filing company to seek reimbursement for any legal expenses, costs, etc., incurred should litigation have to be filed to enforce payment.
The entry in the "I admit ____% liability" field takes precedence over any liability arguments made in the responding company's contentions in most cases. For example, in cases involving a single impact, if the responding company enters "100%" in this field but also makes liability arguments in its contentions, the arbitrator's liability decision will be controlled by the 100 percent liability admission. (If "0%" is entered in this field but no liability arguments are made, the arbitrator is free to deem that liability is not at issue and resolve any damages disputed.) In cases involving multiple impacts where the responding company may be admitting 100 percent liability for the recovering company’s rear damages only, the arbitrator will have the discretion to rule on the disputed front damages.
There is a specific jurisdictional exclusion listed in the Jurisdictional Exclusion drop-down menu.
No, the date of the loss is not controlling. What controls compulsory jurisdiction is the status of the claim on the signatory effective date. If a pending claim meets the provisions of Article First, it is subject to compulsory arbitration, regardless of the accident date. The keyword is "pending." Pending is synonymous, from the viewpoint of arbitration, with active claims. Closed claims are excluded, as are claims that have been abandoned prior to a company's decision to participate in arbitration.
Legal fees may be recovered for one of two reasons. A party may be entitled to recover attorney fees if a case is removed from arbitration because of an objection to jurisdiction (affirmative defense) raised by the responding company, it is discovered that it was properly placed in arbitration, and the filing company refiles the case (Rule 2-8). Legal fees may also be recovered in Special Arbitration. For more details, please refer to the discussion of Rule 2-3: Legal Fees in AF's Reference Guide.
Cases are administered in adherence to the rules in effect on the date of filing.
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At Arbitration Forums, we are committed to helping you achieve your recovery goals. One way we do this is by offering training at no cost to you. All of our training workshops focus on practical application of the rules, regulations, and procedures of each arbitration program.
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