Ch 3 · Filing and Investigation
Module 3.4
Recorded Statement Prep
30-minute prep call before. PA present during. The questions to expect.
12 min read
What you'll learn
The 30-minute prep call before the recorded statement. Why PA presence matters. The questions to expect + the answers to give. The boundaries you set.
3.4.1 The PA's role in recorded statements
You can attend but cannot represent the insured legally.
Your role:
- Pre-statement preparation w/ client
- Attend the call (live or by phone)
- Take notes for the file
- Object to inappropriate questions (limited)
- Pause for client consultation if needed
Your role is NOT:
- Legal representation (that's an attorney)
- Answering questions on behalf of client
- Coaching during the statement (limits)
For high-stakes claims (ROR, EUO requested, large loss), attorney should be primary, with you supporting.
3.4.2 The 30-minute prep call
Hold this at least 24-48 hours before the actual recorded statement.
Cover
| Topic | Why |
|---|---|
| What a recorded statement is | Sworn-like testimony, will be referenced |
| What questions to expect | Loss event, cause, mitigation, value, prior claims |
| What NOT to say | Speculation, dollar estimates, maintenance admissions |
| The "I don't know" answer | Valid + protective |
| Listening fully before answering | Prevents misspoken answers |
| Pausing if needed | Silence is fine |
| Same words for same facts | Consistency |
| What gets used later | Lock-in of testimony |
3.4.3 The 7 questions every recorded statement covers
Your client should be ready for these:
1. "When did the loss occur?"
Right answer: Specific date if known. "On or about [date]" if approximate. Don't guess.
2. "How did you discover the damage?"
Right answer: Specific factual circumstances. "I came home and noticed..." Don't speculate.
3. "What's been done since?"
Right answer: List mitigation actions w/ dates. Have the list memorized.
4. "What's the cause of the damage?"
Right answer: State plumber/expert findings. Don't speculate beyond what you know.
5. "Have you had prior claims?"
Right answer: "I'd have to check my records — I'll provide them in writing." Don't memory-list.
6. "What's the value of the damage?"
Right answer: "I haven't completed full assessment. My contractor + I are still working on the scope."
7. "Have you done any of the work yourself?"
Right answer: Specific facts about any DIY mitigation. Saved receipts.
3.4.4 The 5 things to drill into your client
Drill 1 — Listen fully, pause, then answer
Common mistake: clients anticipate question + start answering before adjuster finishes. Wrong.
Drill: practice 5 minutes of "listen fully → 2-second pause → answer."
Drill 2 — Stick to what you know
Don't speculate. Don't guess. "I don't know" is a complete answer.
Drill: ask client 5 hard questions where the right answer is "I don't know." Practice saying it.
Drill 3 — Same words for same facts
Adjusters ask the same question multiple ways looking for inconsistency.
Drill: identify your client's key facts (date of loss, cause, when noticed). Use the same exact wording every time.
Drill 4 — No dollar estimates
Common mistake: "I think it's about $5,000 of damage." Wrong — locks the client into a low number.
Drill: "I haven't completed the full assessment" is the only acceptable answer.
Drill 5 — No speculation about cause
Common mistake: "It must've been from when the contractor worked on the pipes last year." Wrong.
Drill: stick to what experts have determined. Don't theorize.
3.4.5 What to do during the statement
You're on the call (in person or phone).
Listen actively
Take notes. Track:
- Carrier's questions asked
- Client's answers given
- Document references made
- Any objections you raised
Object when appropriate
Limited grounds for PA objection:
- Question is outside scope of claim
- Question is harassment / repetitive
- Question requests legal opinion from client (not PA's role to defer)
- Question requests medical history unrelated to property claim
You can suggest reframing, request break, or note for the record. Don't argue with the carrier's adjuster.
Request break
If client is struggling or saying things they shouldn't, request a break. "Can we take a 5-minute break? I want to confer with my client briefly."
Don't coach mid-statement
Florida law / industry norms limit PA coaching during a recorded statement. Use breaks for guidance.
3.4.6 After the statement
Get the recording / transcript
Request a copy. Save it.
Review for accuracy
If client said something incorrect or was misquoted → submit written correction within days.
Update the file
Add the recording / transcript to your claim file. Reference statements in subsequent communications.
Brief the attorney (if engaged)
Send transcript + your notes. Identify weak spots / areas to defend in future communications.
3.4.7 Common recorded statement disputes
Client said something unhelpful
Damage control:
- Submit written correction if factually wrong
- For matters of speculation, attorney crafts response
- Continue building the file w/ countering evidence
Client refused to answer something
Verify it was a legitimate refusal (out of scope, etc.). If not, the carrier may argue cooperation breach. Engage attorney.
Carrier weaponizes the statement later
Standard. Statement becomes part of carrier's denial / coverage analysis. Counter w/ evidence + supplements.
3.4.8 Action steps
- Schedule recorded statement minimum 48 hours out.
- Conduct 30-min prep call w/ client.
- Drill the 5 critical points.
- Attend the call in person or by phone.
- Object + request breaks when needed.
- Get transcript + review afterward.
- For ROR/EUO scenarios: attorney leads, you support.
Next: 3.5 Document Request Letter Responses.
Educational. Not legal advice. PA's role in recorded statements is limited; attorney representation appropriate for higher-stakes statements.