Illinois DOI Bulletin 2026-02: Third-Party Public Adjuster Lead Generators (What Contractors & Homeowners Need to Know)
On January 26, 2026, the Illinois Department of Insurance (DOI) issued Company Bulletin 2026-02 to address a growing practice: public adjusters using third parties to generate leads—including roofers, restoration contractors, and standalone lead-gen companies. cb2026-02-public-adjuster-lead-…
The bulletin is direct: this practice can violate Illinois law unless the third-party lead generator is properly licensed as an Illinois public adjuster. cb2026-02-public-adjuster-lead-…
Below is a practical breakdown of what the bulletin says, why it matters, and how to protect your business (and consumers) from avoidable legal and regulatory problems.
What the Illinois DOI says is happening
The DOI says it has “primarily seen” this lead-generation arrangement in situations where a roofing or home repair company makes the initial contact with a potential client and then shares the client’s information with a public adjuster—who then solicits the client for public adjuster services. cb2026-02-public-adjuster-lead-…
That initial contact can be:
- Door knocking
- Cold calling
- Or even a homeowner who contacts the contractor first cb2026-02-public-adjuster-lead-…
The key legal trigger: “anything of value”
Illinois DOI points to the Public Adjuster Law’s definition of “public adjuster,” which includes anyone who, for compensation or anything of value, directly or indirectly solicits business for another person engaged in adjusting losses under an insurance policy. cb2026-02-public-adjuster-lead-…
Even if the third party:
- Isn’t adjusting claims,
- Doesn’t intend to adjust claims,
- And is “only” passing contact information,
…the DOI states that licensing is still required if they (or their employer) receive anything of value in return. cb2026-02-public-adjuster-lead-…
And “anything of value” is not limited to cash. DOI gives examples such as:
- Direct payment for leads
- Common ownership
- Shared expenses
- The contractor benefiting from higher claim payments if the insured uses a public adjuster cb2026-02-public-adjuster-lead-…
Why this bulletin is a big deal for public adjusters
1) License discipline risk
The DOI cites authority to suspend or revoke a public adjuster license for permitting unlicensed representatives to conduct business requiring a PA license, or knowingly accepting business from someone who should be licensed. cb2026-02-public-adjuster-lead-…
2) “Void and invalid” public adjuster contracts
The DOI warns that if a PA contract was even partially solicited by an unlicensed person (including through lead generation), the contract can be “void and invalid.” cb2026-02-public-adjuster-lead-…
A void contract can mean the PA may have no enforceable right to collect fees for services provided. cb2026-02-public-adjuster-lead-…
3) Criminal liability exposure (as described by DOI)
The bulletin also warns that accepting claim payments under a void PA contract can expose the public adjuster to possible criminal liability, describing a Class 4 felony risk in the context of misappropriating/converting monies collected as a public adjuster. cb2026-02-public-adjuster-lead-…
What this means for roofers and restoration contractors in Illinois
While the bulletin is addressed to public adjusters, it directly discusses contractor-driven lead generation. cb2026-02-public-adjuster-lead-…
From a practical risk standpoint, contractors should assume DOI (and carriers) will treat the following as red flags:
- “We’ll connect you with our public adjuster.”
- “We work with a PA who will handle your claim.”
- Door-to-door scripts that pitch claim outcomes tied to PA involvement
- Any lead-sharing arrangement where the contractor receives value—directly or indirectly cb2026-02-public-adjuster-lead-…
Bottom line: If your marketing or intake process looks like soliciting PA business, you can become the “third-party lead generator” described in the bulletin.
Best practices to reduce risk (contractor-friendly, consumer-friendly)
Safer approach for contractors
- Focus on your lane: inspection, documentation, repair planning, code compliance, estimating for repair, and construction services.
- If asked about a public adjuster, provide a neutral list (multiple options) with a written statement that:
- The homeowner chooses,
- You receive no compensation,
- You do not solicit PA contracts.
For public adjusters (and anyone who wants leads)
The DOI urges public adjusters to cease third-party lead generator arrangements unless and until they confirm the third party and its representatives are properly licensed as Illinois public adjusters. cb2026-02-public-adjuster-lead-…
Recordkeeping and complaint scrutiny is increasing
The DOI is asking licensed public adjusters to keep names and license numbers of any third parties involved in solicitation/lead generation in the transaction file. cb2026-02-public-adjuster-lead-…
And DOI says it will start asking consumers and PAs how the PA contract was solicited during the complaint process. cb2026-02-public-adjuster-lead-…
If you’re a contractor, that means: if a complaint happens, the solicitation story will be examined closely.
FAQ
Does this apply only to roofers?
No. DOI says it applies to roofers/contractors and non-contractors whose business is lead generation. cb2026-02-public-adjuster-lead-…
What counts as “anything of value”?
DOI explicitly includes indirect value such as shared ownership/expenses or the contractor benefiting from higher claim payments when a PA is involved. cb2026-02-public-adjuster-lead-…
Who can I contact at the Illinois DOI with questions?
The bulletin lists Kathryn Williams, Assistant General Counsel, 312-814-8212. cb2026-02-public-adjuster-lead-…
Need help with Storm damage restoration?
- Phone: 800-792-0212
- Email: info@alliedemergencyservices.com
Disclaimer: This article is informational and not legal advice. For legal guidance on licensing, solicitation, or referral arrangements, consult a qualified Illinois attorney.
