MICHIGAN PENALTY INTEREST BEGINS WITH "SATISFACTORY PROOF OF LOSS."

Michigan provides for statutory "penalty interest" on delayed payment of claims.  However, the Michigan penalty-interest statute requires "satisfactory proof of loss," or penalty interest is not available.

    "This case cannot be resolved on summary judgment. Resolution of the case depends on when defendant received 'satisfactory proof of loss,' Mich. Comp. Laws § 500.2006(4), and this issue is disputed. Notably, the statute requires 'satisfactory proof,' not any proof, some proof, or partial proof."  Johnson Law, PLC v. Sentinel Ins. Co., No. 19-CV-11786, 2020 WL 6585540, at *2 (E.D. Mich. Nov. 10, 2020).

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