Contents Claims

Contents Inventory Template: Six Fields That Release the Holdback

The carrier's inventory aid collects the inputs to the deduction. Six more columns collect the inputs to recovery.

By Andy Rouhafzai, Founder9 min read

Photo: FEMA / Andrea Booher

In short

The carrier's contents inventory columns for quantity, age and condition supply the inputs to the depreciation calculation and none of the inputs to recovery. Six per-item fields do that work: replacement source, comparable price, date priced, RCV, holdback in dollars, and a recovery deadline from the correct clock start. In LaVigne v. State Farm (Minn. Ct. App. June 22, 2026), a panel set ACV at $28,889 and RCV at $48,733, and $19,844 was forfeited when the two-year repair condition failed.

An appraisal panel valued Mark LaVigne's May 11, 2022 hail loss at $28,889 actual cash value and $48,733 replacement cost in August 2024. State Farm paid the actual cash value and refused the difference, because the policy required the insured to "complete the actual repair or replacement of the damaged part of the property within two years after the date of loss, and notify [State Farm] within 30 days after the work has been completed." 1 Appraisal had been demanded on May 3, 2024, roughly a week before that anniversary, and the award landed after it passed. On June 22, 2026 the Minnesota Court of Appeals affirmed summary judgment for the carrier in No. A25-1837, a nonprecedential opinion treating the two-year clause as an unambiguous condition precedent, requiring no showing of prejudice, and holding that an appraisal award reciting a replacement-cost figure does not obligate the insurer to pay it, because appraisers fix the amount of loss under Quade v. Secura Ins., 814 N.W.2d 703 (Minn. 2012), and not what is owed. 1 LaVigne's counsel put the unpaid balance at $19,844 in a December 2024 email.

What the appraisal panel found, and what got paid
$28,889
Appraised actual cash value
Paid
$48,733
Appraised replacement cost
Stated in the award
$19,844
Recoverable depreciation forfeited
Two-year repair condition unmet
LaVigne v. State Farm Fire & Cas. Co., No. A25-1837 (Minn. Ct. App. June 22, 2026), nonprecedential; figures taken from the slip opinion.

Nothing in that record turns on valuation. The panel agreed on the numbers, and the carrier never fought them. What went missing was a date, tracked per item, against the clock the policy actually ran, and the document that would have surfaced it is the contents inventory.

Three columns, and all three feed the deduction

State Farm's Contents Inventory Aid asks the insured for quantity, age, condition, and a free-text notes field. Its published instructional video says condition matters "when determining the amount of depreciation applied to an item," and asks the insured to grade each entry as "average, above average, or below average condition compared to what is normally expected for the age of the item." 8 Quantity, age and condition are precisely the inputs a depreciation calculation consumes. Fill them in carefully and you have handed the desk adjuster a tidy worksheet for computing the withhold.

Look at what the form leaves out. No column for where a like-kind-and-quality replacement can actually be bought, no column for what it costs, no column for the date the price was pulled, no per-item replacement cost value, no per-item holdback in dollars, and no per-item deadline.

ISO's Personal Property Replacement Cost endorsement, HO-290 (Ed. 4-84), lists property that settles at actual cash value no matter how fast the insured replaces it: antiques, fine arts, paintings and similar articles of rarity or antiquity which cannot be replaced; memorabilia, souvenirs, collectors items and similar articles whose age or history contribute to their value; "articles not maintained in good or workable condition"; and "articles that are outdated or obsolete and are stored or not being used." 6 Two of those four carve-outs turn on condition and age, the same two fields the carrier's form collects as structured, sortable data. A "below average" grade beside a fourteen-year-old elliptical sitting unused in a basement becomes a coverage argument against your own client, entered in your client's handwriting.

HO-290 also set the machinery the industry copied. Once replacement cost for the entire loss exceeds $500, the endorsement provides that "we will pay no more than the actual cash value for the loss or damage until the actual repair or replacement is complete," and gives the insured 180 days after the loss to make the supplemental claim. 6 Paragraph 2.a caps the eventual payment at the least of five amounts, one of which is 400% of the actual cash value at the time of loss. 6 On a heavily depreciated item the ceiling binds before the true like-kind-and-quality price does, and you only see it coming from an inventory line carrying the allowed ACV and a real comparable price side by side.

What the inventory aid collects against what releases the holdback
On the carrier's inventory aidNeeded to release the holdback
Quantity
Age
Condition (above / average / below for age)
Free-text notes
Replacement source (retailer or URL)
Like-kind-and-quality comparable price
Date the comparable was priced
Per-item RCV
Per-item holdback in dollars
Per-item recovery deadline
Left column reflects the fields documented on the State Farm Contents Inventory Aid. Right column is derived from the operative tests: 10 CCR § 2695.9(f) (itemized, dollar-specified depreciation), C.R.S. § 10-4-110.8(11)(b) (methodology on demand), 11 NYCRR 216.6(b) (substantially identical item), and LaVigne (deadline as condition precedent).

Where the replacement clock actually starts

The windows differ by jurisdiction, and so do the events that start them.

California forbids a limit shorter than 12 months from the date the first actual-cash-value payment is made, rising to 36 months where the loss relates to a declared state of emergency, with additional six-month extensions the insurer must grant for good cause. 2 Colorado runs off a different event: at least 365 days after additional living expense expires to replace the property and collect recoverable depreciation, plus a separate 365 days after a total-loss claim just to submit the inventory. 3 In a governor-declared wildfire disaster, the greater of those post-ALE days or 36 months after the first payment. 3 HO-290 runs 180 days from the date of loss. 6 LaVigne's policy ran two years from the date of loss, plus notice within 30 days of completion. 1

Minimum contents replacement window, by jurisdiction
ISO HO-290 (Ed. 4-84) endorsement180 days from the date of loss
6 months
California, ordinary lossFrom the first ACV payment
12 months
Colorado, any total loss365 days after ALE expires
12 months
LaVigne policy (State Farm, Minnesota)From the date of loss, plus 30-day completion notice
24 months
California, declared state of emergencyFrom the first ACV payment
36 months
Colorado, governor-declared wildfire disasterGreater of 36 months from first ACV payment or 365 days after ALE
36 months
The clocks do not start at the same event: HO-290 and the LaVigne policy run from the date of loss, Cal. Ins. Code § 2051.5 runs from the first actual-cash-value payment, and C.R.S. § 10-4-110.8(11)(c)(II) runs from the expiration of additional living expense. Every bar is a statutory or contractual floor rather than a cap; Cal. Ins. Code § 2051.5(b)(1)(C) and C.R.S. § 10-4-110.8(13)(b)(II) both permit an insurer to allow more time. Texas, New York and Florida are handled in the text rather than plotted: none of the three sets a statutory contents deadline, so there is no number to chart.

Which event starts the clock decides whether an early payment helps your client or hurts them. In California the first check, however small, is the trigger. In Colorado the run holds off until additional living expense is exhausted, which on a long rebuild lands a year or more past the loss, and the rest of that stacking sits in Colorado's layered contents deadlines. In LaVigne the clock ran from the date of loss, so it was already running when the claim was reported on July 8, 2022, and still running when the $435.48 first payment went out on July 24, 2022 with a written reminder attached. 1

Texas and New York set no contents replacement deadline by statute

Tex. Ins. Code § 862.053 is a valued-policy provision reaching total loss of real property by fire, and TDI Commissioner's Bulletin B-0045-98 says in terms that it "is not intended to, and does not, express any opinion of the Department as to the calculation of actual cash value in other contexts, such as personal property." 9 New York's 11 NYCRR 216.6(b) defines actual cash value as the lesser of repair cost or replacement "with an item substantially identical to the item damaged," adds that "such amount shall include all monies paid or payable as sales taxes," and fixes no replacement window. 10 The "180 days to two years" ranges circulating on law-firm and adjuster blogs as Texas or New York law are policy-form terms borrowed from endorsements like HO-290. Pull the form.

New York hands you a per-item lever of a different kind: 11 NYCRR 216.6(e) requires payment of undisputed elements notwithstanding disputes on other elements, 10 which only works if the inventory is itemized finely enough to show which lines are undisputed, and it sits alongside the state's other claim-handling clocks. Florida runs the other way. Under Fla. Stat. § 627.7011(3)(b)1 the insurer must offer coverage obligating it to pay replacement cost "without reservation or holdback for any depreciation in value, whether or not the insured replaces the property," and the alternative form under (3)(b)2 pays in rolling receipt-driven installments and "may not require the policyholder to advance payment for the replaced property." 4 On a compliant Florida form there is no clock, because there is no holdback to chase.

Flood-damaged household belongings piled in the front yard of a home in Big Lake, Missouri, in June 2007, waiting to be hauled away
Photo: FEMA / Marvin Nauman

Two states let the insured collect without submitting any written inventory, and each figure is a floor the insurer must offer rather than a ceiling. Colorado requires at least 30% of the declarations-page contents limit after a total loss of a furnished owner-occupied primary residence, and 65% in a governor-declared wildfire disaster. 3 California, for a total loss in a declared emergency, requires an offer of no less than 60% of the personal-property limit, capped at $350,000, with no itemized claim required; the amended Cal. Ins. Code § 10103.7(b)(1) took effect January 1, 2026, and every form issued or renewed on or after July 1, 2026 has to comply. 7 Most states set no such floor, so the insured itemizes or the insured does not get paid.

Six fields to add before your next inventory goes out

Take the carrier's four columns and extend the sheet to the right. Replacement source comes first: the retailer, model, or URL where a like-kind-and-quality replacement can be bought today, which is the standard New York's regulation already articulates as an item "substantially identical to the item damaged." Comparable price is what that specific replacement costs, at that source. Date priced stamps the pull, because an undated comparable is arguable eighteen months later once the carrier's vendor pricing has drifted.

Per-item RCV is quantity times comparable price. It yields the same kind of line the LaVigne panel was able to state and unable to make anyone pay, which is why it belongs in your file rather than only in an award. 1 Per-item holdback in dollars is that RCV minus the actual cash value the carrier allowed, and it maps onto the figure Cal. Code Regs. tit. 10, § 2695.9(f) requires the carrier's own adjustment to be "specified as to dollar amount." 5 Colorado gives the insured a statutory right to demand the methodology behind it. 3 Recovery deadline is the calendar date the holdback expires for that line, computed from the correct clock start for that policy and jurisdiction, and carried on the item rather than on the claim, because a phased replacement generates different deadlines for different lines the moment a supplement moves the trigger.

Then there is the condition column, which cuts the other way.

Grade it against the item's age rather than against new. HO-290's carve-outs for articles "not maintained in good or workable condition" and articles "outdated or obsolete and are stored or not being used" run on that same column, so a careless entry pushes a line out of replacement-cost settlement before any deadline becomes relevant. 6 The 400%-of-ACV cap in paragraph 2.a is the second reason the comparable price and the allowed ACV belong on one row: where the comparable exceeds four times ACV, the cap governs what the carrier pays. 6

When the carrier won't show its depreciation math

California is the one state that tells the carrier, by regulation, how much of its arithmetic it has to surrender. Depreciation adjustments must be "discernable, measurable, itemized, and specified as to dollar amount," must "reflect a measurable difference in market value attributable to the condition and age of the property," and must apply "only to property normally subject to repair and replacement during the useful life of the property." 5

Item by item, in dollars.

All justification "shall be contained in the claim file," and "the basis for any adjustment shall be fully explained to the claimant in writing." 5 Subsection (f)(1) adds the rule contents estimates still violate: apart from intrinsic labor costs included in manufactured materials or goods, "the expense of labor necessary to repair, rebuild or replace covered property is not a component of physical depreciation and shall not be subject to depreciation or betterment." 5 The trades fight the same regulatory instinct in overhead and profit disputes.

Leyrn Miller inspecting her wedding gown after it was submerged in floodwater at her home in Spring, Texas, during the April 2016 severe storms
Photo: FEMA / Jann Tracey

Colorado gets there by a different route. If the policyholder receives the depreciated value of contents, the insurer "must make available to the insured the methodology used for determining the depreciated value of the insured contents," and in a governor-declared wildfire disaster the insurer has to affirmatively notify the policyholder of that duty. 3 Where a submitted inventory exceeds the no-inventory advance, the insurer must request any additional information within 30 days of receiving the inventory and pay covered, undisputed items within 30 days. 3 Both duties reward a line-itemized submission, since an aggregate number has no undisputed portion to sever.

Outside those two states you are arguing against a figure with no public benchmark.

No US state insurance department was found publishing a personal-property depreciation or useful-life table for claims purposes, and the state-published tables that do exist are property-tax assessment schedules, never insurance ACV instruments. No carrier schedule is public either. A widely used industry reference, the Claims Pages Depreciation Guide (Personal Property, 2024 edition), is "compiled using data from manufacturers, repairers, builders, home inspector associations, and insurers" and is described as "utilized by hundreds of insurance companies annually." 11 It also sits behind a sign-in wall; a direct download on August 18, 2026 returned the login page instead of the PDF. Its one publicly readable numeric rule is that items "still functional for their intended purpose should not be depreciated beyond 90% of their original value." 11 A per-item comparable carrying a source, a price and a date is the only number in the file that did not come out of a schedule you are not allowed to read.

Questions adjusters ask about contents holdbacks

Does an appraisal award that states a replacement cost value obligate the carrier to pay it?

No. LaVigne v. State Farm Fire & Cas. Co., No. A25-1837 (Minn. Ct. App. June 22, 2026), held that appraisers fix the amount of loss but do not decide whether the insurer should pay, citing Quade v. Secura Ins., 814 N.W.2d 703 (Minn. 2012). The panel stated an RCV of $48,733 and the insured still collected only the $28,889 ACV, because the policy's two-year repair-and-notify requirement was an unfulfilled condition precedent.

Does a carrier have to prove prejudice before enforcing a replacement deadline?

It depends on the jurisdiction, and in LaVigne the answer was no. The Minnesota Court of Appeals treated the two-year completion-and-notice clause as an unambiguous condition precedent and required no showing of prejudice by State Farm before enforcing it.

Do Texas and New York set a statutory deadline to replace contents and collect recoverable depreciation?

No. Tex. Ins. Code § 862.053 is a valued-policy provision covering total loss of real property by fire, and TDI Commissioner's Bulletin B-0045-98 expressly declines to opine on actual cash value for personal property. No New York statutory replacement deadline was located; 11 NYCRR 216.6(b) defines ACV, including sales taxes, without setting a window. The policy form governs in both states, so the 180-day and two-year figures circulating online are endorsement terms rather than state law.

Can an insured in Colorado or California collect contents money without submitting a written inventory?

Yes, up to a statutory floor. Colorado requires an offer of at least 30% of the declarations-page contents limit after a qualifying total loss, and 65% in a governor-declared wildfire disaster. California requires an offer of at least 60% of the personal-property limit, capped at $350,000, for a total loss in a declared emergency under Cal. Ins. Code § 10103.7 as amended effective January 1, 2026. In both states the insured may still itemize to recover above the advance.

Is there a published table showing how much depreciation carriers withhold on contents?

No. No state insurance department was found publishing a personal-property depreciation or useful-life table for claims purposes, and no carrier schedule is public. The Claims Pages Depreciation Guide (Personal Property, 2024 ed.) sits behind a sign-in wall; its publicly readable rule is that items still functional for their intended purpose should not be depreciated beyond 90% of their original value. Colorado is the only state located that gives the insured an affirmative right to obtain the insurer's methodology.

Can a carrier depreciate labor on a contents claim in California?

No. Cal. Code Regs. tit. 10, § 2695.9(f)(1) provides that, except for intrinsic labor costs included in the cost of manufactured materials or goods, the expense of labor necessary to repair, rebuild or replace covered property is not a component of physical depreciation and is not subject to depreciation or betterment.

Sources cited

  1. LaVigne v. State Farm Fire & Cas. Co., No. A25-1837 (Minn. Ct. App. June 22, 2026)Minnesota Court of Appeals (via CourtListener)
  2. Cal. Ins. Code § 2051.5 — replacement cost time limitsCalifornia Legislative Information
  3. C.R.S. § 10-4-110.8 — contents inventory deadlines and depreciation-methodology disclosureJustia US Law
  4. Fla. Stat. § 627.7011(3)(b) — personal property replacement cost without holdbackThe Florida Senate
  5. Cal. Code Regs. tit. 10, § 2695.9(f) — depreciation must be itemized and explained in writingCornell Legal Information Institute
  6. ISO HO-290 (Ed. 4-84) Personal Property Replacement Cost endorsementInsurance Services Office (ISO), via Bankers Fidelity
  7. Cal. Ins. Code § 10103.7 — contents advance without an itemized claim after a declared emergency (as amended by SB 495, Stats. 2025, Ch. 542)California Legislative Information
  8. State Farm Contents Inventory Aid — homeowner claim forms and personal property inventory toolsState Farm
  9. Commissioner's Bulletin B-0045-98 — actual cash value under replacement cost policiesTexas Department of Insurance
  10. 11 NYCRR 216.6 — standards for prompt, fair and equitable settlementsCornell Legal Information Institute
  11. Depreciation Guide (Personal Property), 2024 editionClaims Pages

Stop rebuilding the same documents.

Letters, notices, and sworn documents in claimOS start from the claim facts already on file: names, dates, policy numbers, and the statutory citations that match the state.