A working guide to the most useful free dataset in American insurance, with the numbers to prove it

Every state regulator collects consumer complaints. The NAIC normalizes them by market share. What comes out is a public, quantified, regulator-published ranking of which carriers annoy their own customers most, broken out by line and by the specific thing that went wrong. Access costs nothing. The industry that spent $7.9 billion on advertising in 2024 asserting how well it treats people has, for the most part, never opened it.

1. What is the complaint index, in one sentence?

A company’s share of complaints divided by its share of premium. That is the whole thing.

1. An index of 1.00 means the carrier draws exactly as many complaints as its size predicts. 2.00 means twice as many. 0.50 means half.

2. It is computed per line of business, per state, per calendar year. Kansas prints the formula on page two of its annual report: complaints divided by market share.

3. The NAIC publishes it through the Consumer Information Source at content.naic.org, searchable by company code, with reports by state, by complaint code, and by disposition.

4. Most states also publish their own version. California ranks carriers by justified complaints per 100,000 policies across three years, so you get the trend rather than a snapshot.

2. Why does the normalization matter so much?

Because raw complaint counts only tell you who is big. Normalizing turns a popularity contest into a quality ranking, and the results invert constantly.

1. In Kansas private auto in 2024, State Farm Mutual Automobile drew 111 complaints, more than any other carrier in the state, and posted an index of 0.62. It writes 18% of the market.

2. First Chicago Insurance drew 54 complaints on 0.5% market share. Index: 11.75, following 11.82 the year before. Two straight years at roughly twelve times expected describes a business model.

3. One state, one line, one year, and a 25-fold spread between the best and worst carriers on the list.

3. What are people actually complaining about?

Claims. Overwhelmingly, boringly, consistently claims. Two independent samples, one national and one from a single midwestern state, land in almost the same place.

1. Inside claim handling, delays are 22.2% of all closed complaints and unsatisfactory settlement offers are 12.2%. Those two codes outweigh every underwriting and sales grievance combined.

2. Kansas, working from a completely separate file of 3,093 in-jurisdiction complaints, lands within two points on every category: 67% claims handling, 18% policyholder service, 10% underwriting, 5% marketing and sales.

3. That is the part worth sitting with. The complaint file is a claims operations file wearing a customer service label.

4. Which lines are generating the anger, and which way is it moving?

1. Accident and health took 36.6% of 2024 complaints, auto 35.3%, homeowners 18.0%. Auto complaints rose 31.6% between 2021 and 2024.

2. The growth rates are where the market intelligence lives, because a complaint code growing at triple digits is a coverage gap becoming a coverage fight.

Coverage type	2021	2024	Change
Homeowners: hazard	3	149	+4,866.7%
Accident & health: self-funded / ERISA	188	520	+176.6%
Auto: physical damage	375	990	+164.0%
Miscellaneous: pet insurance	27	77	+185.2%
Accident & health: ACA exchange plans	1,028	1,781	+73.2%
Homeowners: replacement cost	72	174	+141.7%
Liability (the only category that fell)	686	473	-31.0%

Source: ValuePenguin analysis of NAIC closed-complaint data, 2021 to 2024.

5. Do complaints go anywhere, or is this just yelling into a form?

They go somewhere, and the direction surprises most people.

1. In 2024 the company’s position was overturned in 26.2% of closed complaints and upheld in only 4.1%. Another 26.1% ended in a compromise settlement and 18.7% in a settled claim.

2. Referrals for disciplinary action grew from 2,368 in 2021 to 4,249 in 2024, up 79.4%.

3. The money is real and it is itemized. Kansas recovered $12,491,218.32 for its consumers in 2024. Colorado recovered $21,523,066 in one fiscal year, including a single Marshall Fire complaint that produced $513,154 in additional coverage. New York’s DFS returned $228 million to consumers and providers in 2024.

6. What is a market conduct examination, and why should I read one?

The long-form version of the index. A regulator pulls a claim sample, audits it line by line, and publishes the findings. They read like audits because they are audits, and outside compliance departments almost no one has opened one.

1. California’s May 2026 action against State Farm General is the current textbook case. Examiners sampled 220 wildfire claims and found 398 violations of state law across 114 of them, more than half the sample.

2. The findings are specific enough to build a product around: no investigation within 15 days, no accept or deny within 40 days, no payment or explanation within 30 days, repeated adjuster reassignment survivors called “adjuster roulette,” and smoke damage denials that made up nearly half of all consumer complaints in the file.

3. Scale: State Farm handled about 11,300 of the 38,835 residential claims filed after the fires. Penalties run to $5,000 per violation, or $10,000 where willful. The department had already clawed back $280 million through direct intervention against a total industry payout of $23.7 billion.

4. It is not one rogue state. North Carolina fined two Auto Club Group subsidiaries $113,000 and forced $2.6 million in refunds. Louisiana proposed close to $1 million across five hurricane exams. North Dakota fined Farmers $750,000. Florida fined 55 insurers in 2024 alone. American Coastal disclosed a $400,000 Hurricane Ian consent order in its own annual report, so this material surfaces in SEC filings too.

7. What is the insurtech play?

A target list, published by the government, refreshed annually, with the pain points labeled.

1. Find a line where incumbents cluster above 1.00 on claim-handling codes and you have a market announcing in public where the dissatisfaction sits and what it is about. Kansas health in 2024 is a case study in itself.

Kansas 2024 outliers	Line	Market share	2024 index	2023 index
Aetna Health & Life	Health	0.2%	14.96	n/a
Golden Rule	Health	0.1%	7.23	n/a
Humana Insurance Co.	Health	0.3%	7.10	1.73
UnitedHealthcare	Health	7%	2.87	1.73
Prudential	Individual life	0.5%	14.65	11.35
Metropolitan Life	Individual life	0.4%	13.88	n/a
Northwestern Mutual	Individual life	10%	0.00	0.04
USAA General Indemnity	Homeowners	1%	0.22	0.37

Source: Kansas Insurance Department, Complaint Index 2024 Report. Kansas lists any carrier with 10 or more closed complaints plus the top 20 premium writers per line.

2. Pair it with the NAIC’s Market Conduct Annual Statement, collecting claims and underwriting data since 2002 across 13 lines of business, including days to close and claims closed without payment. Pet insurance was added for 2024, which tells you where regulators expect the next fight.

8. What if I am the carrier and my number is already good?

Then you own a third-party, regulator-published, uncontestable quality claim, and you are almost certainly not using it.

1. USAA’s three Kansas homeowners entities posted indexes of 0.32, 0.54 and 0.22 in 2024. Northwestern Mutual posted 0.00 in individual life two years running. Try buying that credibility from an agency.

2. The reason it goes unused is structural. Marketing does not know the number exists, and compliance has no reason to bring it up. The number lives in a building where no one is paid to sell.

3. Meanwhile the four largest personal lines carriers spent roughly $7.9 billion on advertising in 2024: Progressive $3.50 billion, Allstate $1.87 billion (up 187.6%), Berkshire’s GEICO $1.40 billion (up 67%), State Farm $1.11 billion. The complaint index costs $0 and is auditable.

9. What about the Karen problem?

This is the question that separates a credible outside analyst from a person waving a spreadsheet. The index measures how many people escalated, which is narrower than how badly a carrier behaved.

1. Start with the funnel. The most cited figure in service research is that roughly 4% of dissatisfied customers ever complain to the company at all. Lee Resources put it a second way: for every complaint filed, about 26 unhappy customers say nothing. A formal written complaint to a state insurance department sits several rungs above that.

2. So the index counts the tip of an iceberg whose height varies by book. A carrier writing retired homeowners in a wealthy suburb has customers with time, confidence, stationery, and a settled belief that the manager should be summoned. A carrier writing nonstandard auto to hourly workers does not. Same misconduct, very different filing rate.

3. Language and channel skew it too. In California’s statewide health complaint data, 82.2% of filers were English speakers and 4.2% Spanish, in a state where about a quarter of residents speak Spanish at home. Group plans route grievances through HR before a regulator hears anything.

4. Enforcement climate matters. Well-staffed departments in California, New York, Florida and Texas generate higher counts partly because they are easier to reach.

5. The framing that survives a hostile boardroom question: the index measures grievance that got escalated. Narrower than misconduct, far more useful than a brand tracker. Say it out loud and you become the most credible person in the room.

10. What are the other caveats, stated plainly?

1. Small samples swing violently, so read three years rather than one. Bremen Farmers Mutual posted a 2.34 on 11 complaints. Aetna Health Insurance moved 0.28 to 2.23 in a single year and US Health & Life moved 20.90 to 6.19. None of those swings is a story on its own.

2. Watch the legal entity. State Farm Fire & Casualty scored 2.84 on Kansas auto and 1.33 on Kansas homeowners in the same year. Group-level claims about “State Farm” are not supportable.

3. Do not mix definitions. NAIC complaint code reports count confirmed complaints, where the department found a violation or error. State indexes usually use all closed complaints. Different denominators, different stories.

11. Where does this sit alongside the other free filings?

Third in a trilogy. Each is an afternoon of work, and each has effectively no competition.

Dataset	Where it lives	What it tells you
Rate filings	SERFF and state DOI portals	What competitors charge and what they believe about risk
Risk factors	SEC 10-K, Item 1A	What public carriers are afraid of, in their own words
Complaint index and market conduct exams	NAIC CIS and state DOI sites	Who their customers are angry with, and about which part of the claim

The bottom line

Insurance is the most heavily disclosed industry in America and among the least read. Everything a marketer would pay a research firm six figures to approximate has already been filed, normalized and published by people whose job was to protect consumers rather than to help you. That is precisely why almost no one thought to look. The box score has been printed every year for decades. Go read it first.

Sources

1. NAIC Consumer Information Source: content.naic.org/cis_consumer_information.htm

2. NAIC Market Conduct Annual Statement: content.naic.org/insurance-topics/market-conduct-annual-statement

3. Kansas Insurance Department, Complaint Index 2024 Report: insurance.ks.gov (Publications)

4. California Dept. of Insurance, Consumer Complaint Study: insurance.ca.gov/01-consumers/120-company/03-concmplt/

5. California Dept. of Insurance, State Farm wildfire enforcement release, May 4, 2026: insurance.ca.gov

6. ValuePenguin analysis of NAIC closed-complaint data, 2021 to 2024: valuepenguin.com/most-common-insurance-complaints

7. California CDII, Annual Complaint Data Report, MY 2022 data tables: cdii.ca.gov

8. Colorado Division of Insurance, Annual Complaint and Recoveries Report: doi.colorado.gov

9. Office of the Governor of New York, $245.3 million recovered for New Yorkers, March 3, 2025: governor.ny.gov

10. Repairer Driven News, North Carolina market conduct refunds, May 6, 2025: repairerdrivennews.com

11. Property Insurance Coverage Law Blog, “The Case of the Missing Market Conduct Exams” (Louisiana, North Dakota)

12. Florida Office of Insurance Regulation, Insurer Compliance Report, January 31, 2025: floir.gov

13. S&P Global Market Intelligence, insurer advertising expense analyses for 2023 and 2024

14. Ruby Newell-Legner, Understanding Customers; Lee Resources International, complaint funnel ratios