Why Fleet Risk Assessment Matters

Insurance is the second-largest operating expense for most trucking companies, behind only fuel. Yet most fleet operators treat insurance as a fixed cost they cannot control. The truth is that your risk profile directly determines your premium — and your risk profile is something you can measure, manage, and improve. Understanding your exposures is the first step toward controlling your insurance costs and protecting your business from catastrophic loss.

A single trucking accident can bankrupt a small fleet. The average cost of a non-fatal trucking accident is $91,000 when you factor in vehicle damage, cargo loss, medical expenses, legal costs, and lost revenue from downtime. A fatal accident averages $3.6 million — and nuclear verdicts (jury awards exceeding $10 million) are increasingly common, with some exceeding $100 million in recent years. Proper risk assessment is not optional.

Identifying Exposures by Vehicle Type

Different vehicle configurations carry fundamentally different risk profiles. Understanding yours helps you communicate with underwriters and target your safety investments:

• Tractor-trailers (Class 8) — highest frequency of severe accidents due to size, weight (up to 80,000 lbs GVWR), and stopping distance. Jackknife and rollover risks are unique to articulated vehicles. Underwriters focus on driver experience and route profiles.
• Straight trucks (Class 6-7) — often used for local delivery with frequent stops, backing maneuvers, and urban congestion. Higher frequency of backing accidents and pedestrian incidents. Lower severity per incident but higher claim frequency.
• Tankers — liquid surge dynamics make rollovers more likely, especially in curves and during partial loads. Hazmat tankers carry the highest insurance premiums in trucking due to catastrophic spill liability. Even non-hazmat tankers (milk, water) are rated higher than dry van.
• Flatbeds — cargo securement is the dominant risk. Improperly secured loads cause road debris accidents and cargo loss claims. Tarping injuries are a significant workers' comp exposure. Wind resistance issues affect handling.
• Reefers (refrigerated trailers) — all tractor-trailer risks plus cargo spoilage claims from mechanical failure. Temperature-sensitive cargo (pharmaceuticals, produce) can generate large cargo claims from a single unit malfunction.

Route Risk Analysis

Where your trucks operate matters as much as what they haul. Underwriters evaluate route profiles when pricing your policy:

• Urban corridors — higher accident frequency due to congestion, pedestrians, cyclists, and frequent lane changes. New York, Los Angeles, Chicago, and Houston are the highest-rated urban zones. Last-mile delivery in urban areas has 3-5x the claim frequency of long-haul interstate.
• Rural highways — lower frequency but higher severity. Head-on collisions on two-lane roads, animal strikes, and limited emergency response increase severity per incident. Fatigue-related incidents peak on rural stretches.
• Mountain passes — grade-related brake failures, runaway truck incidents, and winter weather closures. I-70 in Colorado, I-80 through the Sierra Nevada, and I-90 through Montana are high-severity corridors. Chains-required zones add compliance exposure.
• Weather corridors — Gulf Coast (hurricanes), Tornado Alley (wind events), and northern routes (ice/snow) all carry seasonal risk spikes. Carriers operating in these corridors need contingency plans that insurers want to see documented.

Commodity Risk Factors

What you haul shapes both your liability exposure and your cargo insurance needs:

• General freight / dry van — baseline risk. Cargo claims are typically moderate. The main risk is auto liability, not cargo.
• Hazardous materials — FMCSA requires $1M-$5M in liability depending on material class. Environmental cleanup liability can exceed policy limits. A single hazmat spill can generate cleanup costs exceeding $10 million. Specialized training, placarding, and routing requirements add compliance risk.
• High-value goods — electronics, pharmaceuticals, and alcohol attract cargo theft. Theft claims averaged $260,000 per incident in 2024. Underwriters require specific security protocols: king pin locks, GPS tracking, vetted parking, and team drivers for high-value loads.
• Oversized/overweight — permit requirements, escort vehicles, and route restrictions create compliance exposure. Accidents involving oversized loads have higher severity due to reduced maneuverability.

Driver Risk Profiling

Your drivers are your single largest variable in fleet risk. Underwriters evaluate your driver pool carefully:

• Experience — drivers with less than 2 years of CDL experience have accident rates 2-3 times higher than experienced drivers. Most insurers require minimum 2 years CDL experience; some require 3 years for hazmat or tanker operations.
• MVR (Motor Vehicle Record) history — moving violations in the past 3 years are weighted by severity. A single DUI/DWI can make a driver uninsurable. Two or more at-fault accidents in 3 years is a common disqualifier.
• CSA scores — your company's CSA BASIC scores directly affect underwriter appetite. High Unsafe Driving or HOS Compliance scores signal systemic risk. Insurers pull SMS data during the underwriting process.
• Age — drivers under 25 and over 70 are rated higher by most underwriters. The safest statistical cohort is 35-55 with 10+ years of experience.

Reading Your Declarations Page

The declarations page (dec page) is the front page of your insurance policy and summarizes what is actually covered. Most fleet operators never read past the premium amount — which is a costly mistake. The dec page lists: named insured, policy period, scheduled vehicles, covered drivers, coverage types with limits, deductibles, premium breakdown by coverage, and any endorsements or exclusions.

Pay close attention to who is the named insured. If your business operates under multiple entities (common in trucking — an operating company and a leasing company, for example), all entities must be named or covered by endorsement. An accident involving a vehicle owned by an unlisted entity can result in a coverage denial.

Primary Auto Liability

FMCSA requires minimum $750,000 in liability for non-hazmat property carriers, but this minimum is dangerously low in today's legal environment. Most brokers and shippers require $1,000,000 combined single limit (CSL) as a contractual minimum. Many large shippers now require $2,000,000 or more.

The trend in trucking verdicts makes this critical: the median nuclear verdict in trucking exceeded $20 million in 2023. A $750,000 policy leaves your business assets exposed to judgments that routinely exceed seven figures. Most experienced insurance producers recommend a minimum of $1,000,000 primary liability with an umbrella or excess policy layered on top.

General Liability vs. Auto Liability vs. Umbrella/Excess

These three coverages serve different purposes and many fleet operators confuse them:

• Commercial Auto Liability — covers bodily injury and property damage arising from the operation of your scheduled vehicles. This is your primary trucking policy and includes the MCS-90 endorsement required by FMCSA.
• General Liability (GL) — covers bodily injury and property damage from your business operations that are NOT related to vehicle operation. Slip-and-fall at your terminal, damage during loading/unloading at a customer's dock (after the vehicle is parked), advertising injury. GL does NOT cover auto accidents.
• Umbrella / Excess Liability — provides additional limits above your primary auto and general liability policies. If your primary auto is $1M and you have a $4M umbrella, your total available limit is $5M. Umbrella policies are the most cost-effective way to increase your total protection. A $5M umbrella typically costs 40-60% less than increasing your primary auto limit to $5M.

Cargo Insurance: Coverage vs. Carmack Liability

Under the Carmack Amendment, motor carriers are strictly liable for cargo loss or damage from the moment of pickup to delivery — regardless of fault. Your only defenses are: act of God, act of public enemy, act of the shipper, inherent vice of the cargo, or act of public authority. This means you are legally liable even without cargo insurance.

Cargo insurance protects you, not the shipper. It reimburses your company for cargo claims you are obligated to pay under Carmack. Most policies cover $100,000 per occurrence with a $250,000 aggregate, but high-value freight carriers may need $250,000-$500,000 per occurrence. Key exclusions to watch: reefer breakdown (often excluded or sub-limited), theft from unattended vehicles, and mysterious disappearance.

Physical Damage: Valuation Methods

Physical damage coverage pays for damage to your own vehicles (not liability to others). Three valuation methods determine how much you receive:

• Actual Cash Value (ACV) — replacement cost minus depreciation. The most common method. On older equipment, ACV can be shockingly low. A 10-year-old tractor worth $40,000 on the market might receive only $25,000 under ACV after the insurer's depreciation calculation.
• Agreed Value — you and the insurer agree on a stated value at policy inception. In a total loss, you receive the agreed amount with no depreciation argument. More expensive than ACV but eliminates disputes. Best for well-maintained, lower-mileage equipment.
• Stated Amount — you state the value, but the insurer pays the LESSER of the stated amount, ACV, or repair cost. This is NOT the same as agreed value. Many operators confuse the two and discover the difference after a total loss. Avoid stated amount when possible.

Identifying Common Coverage Gaps

Most fleet insurance programs have at least one of these gaps that operators don't discover until they have a claim:

• Deadhead / empty miles — some cargo policies only cover when a load is on the trailer. Damage during deadhead positioning moves may not be covered.
• Bobtail / non-trucking liability — owner-operators leased to a carrier are covered by the carrier's policy while under dispatch, but NOT during personal use or between loads. Non-trucking liability (NTL) or bobtail insurance fills this gap. The owner-operator — not the carrier — is responsible for this coverage.
• Hired and non-owned auto (HNOA) — if you hire independent contractors or rent vehicles, your primary policy may not cover those units. HNOA coverage extends your liability to vehicles you don't own but use in your business.
• Trailer interchange — if you pull trailers owned by others (common in intermodal and drayage), your physical damage policy doesn't cover their trailer. Trailer interchange coverage is needed.
• Loading and unloading — some auto policies exclude loading/unloading incidents. Others include them. Verify where this falls in your policy vs. your GL coverage.

Understanding FMCSA Safety Ratings

FMCSA assigns safety ratings to motor carriers based on compliance reviews (CR) and safety audits. The three ratings directly affect your insurability and your ability to haul certain freight:

• Satisfactory — the carrier has adequate safety management controls in place. This is the baseline expectation. Most broker and shipper onboarding processes require a Satisfactory rating or "unrated" (which is treated as acceptable for carriers that haven't been audited yet).
• Conditional — the carrier has deficiencies in safety management. You can still operate, but many brokers and shippers will not contract with a Conditional carrier. Your insurance renewal will be significantly more expensive, and some insurers will non-renew.
• Unsatisfactory — the carrier's safety management is inadequate. You have 45 days (or 60 for certain passenger carriers) to take corrective action before FMCSA issues an operations out-of-service order. An Unsatisfactory rating effectively ends your ability to get insurance at any reasonable price.

CSA BASIC Scores and Insurance Pricing

The CSA (Compliance, Safety, Accountability) program evaluates carriers across 7 BASIC categories. Each category has an intervention threshold — once your percentile rank exceeds the threshold, FMCSA may intervene. But insurers look at your CSA data long before FMCSA does:

• Unsafe Driving (threshold: 65%) — speeding, texting, improper lane changes, failure to use seatbelt. The #1 BASIC that drives premium increases.
• HOS Compliance (threshold: 65%) — log falsification, driving past limits, insufficient off-duty time. Signals fatigue risk, which insurers weigh heavily.
• Driver Fitness (threshold: 80%) — expired CDL, no medical certificate, inadequate DQ files.
• Controlled Substances/Alcohol (threshold: 80%) — drug and alcohol violations. Even a single violation here can spike your premium 30%+.
• Vehicle Maintenance (threshold: 80%) — brake, tire, and lighting violations. Mechanical failures cause accidents that are 100% preventable.
• Hazmat Compliance (threshold: 80%) — placarding, shipping papers, containment violations. Only applies to hazmat carriers.
• Crash Indicator (threshold: 65%) — DOT-reportable crashes regardless of fault.

Carriers with CSA scores below intervention thresholds across all BASICs pay 20-40% less in insurance premiums compared to carriers at or above thresholds. Some underwriters offer specific premium credits for demonstrably low Unsafe Driving and HOS scores.

Building a Safety Program That Lowers Premiums

Insurance underwriters evaluate your safety program during the submission and renewal process. A documented, active safety program signals lower risk. The essentials:

• Hiring standards — written minimum requirements for CDL experience (2+ years), clean MVR (no DUIs, no more than 2 moving violations in 3 years), and Clearinghouse verification. Document that you enforce these standards by tracking rejection rates.
• Onboarding training — road test, orientation covering your specific equipment and routes, Smith System or similar defensive driving training. Document hours of training per new hire.
• Ongoing training — quarterly safety meetings, annual refresher on key topics (backing, intersections, adverse weather). Carriers with documented monthly safety programs get premium credits from many underwriters.
• Monitoring technology — ELD data review, forward-facing and driver-facing cameras, GPS speed monitoring, and hard-braking event alerts. Dash cams alone can reduce your premium 5-10% and dramatically improve your claims defense.

Driver Scorecards

Converting telematics data into individual driver scorecards is one of the most effective loss control strategies. Track and rank drivers on:

• Speeding events — instances over posted speed limit or over company policy speed (typically 65 mph on interstate). Weight by severity (5 over vs. 15 over).
• Hard braking events — sudden deceleration events signal following too closely or inattentive driving. Track frequency per 10,000 miles to normalize across drivers.
• HOS compliance — violations, close-to-limit driving, and log edit frequency. Drivers consistently driving 10.5-11.0 hours are a fatigue risk.
• Idle time and fuel efficiency — while not directly a safety metric, excessive idle time correlates with poor driving habits overall.

Share scorecards monthly. Tie safety bonuses to scorecard performance. Carriers that use driver scorecards report 25-35% fewer accidents within 12 months of implementation.

Accident Response Protocols

How you respond to an accident in the first 24 hours determines both the cost of the claim and your future insurability. Every driver should carry an accident kit with a camera, witness statement forms, and step-by-step instructions:

• Secure the scene — set reflective triangles, check for injuries, call 911 if needed. Never admit fault at the scene.
• Document everything — photographs of all vehicles from multiple angles, the roadway, traffic signs, weather conditions, and any visible injuries. Get contact information for all parties and witnesses.
• Report immediately — notify your dispatcher and your insurance company within hours, not days. Late reporting is one of the top reasons insurers non-renew trucking accounts.
• Drug and alcohol testing — post-accident DOT testing is required within 8 hours (alcohol) and 32 hours (drugs) for qualifying accidents. Failure to test is treated the same as a positive result.
• Preserve evidence — download dash cam footage, ELD data, and any in-cab sensor data immediately. This evidence disappears or gets overwritten if not preserved within 24-48 hours.

The Insurance Producer's Role

In commercial trucking insurance, you work with a producer — either a broker or an agent. Understanding the difference matters:

• Insurance broker — represents YOU (the buyer). A broker shops your account across multiple insurance carriers to find the best combination of coverage and price. Most mid-to-large fleets use brokers. The broker's compensation comes from commissions paid by the insurer (typically 10-15% of premium).
• Insurance agent — represents the INSURER. A captive agent sells for one company only (like a State Farm agent). An independent agent represents multiple insurers but has appointment agreements that can limit which markets they access. Agents are more common for small fleets (1-5 trucks).

For trucking specifically, you want a producer who specializes in commercial transportation. A generalist who also writes home and auto insurance will not have the market access, loss control resources, or underwriter relationships to properly place a trucking account. Ask how many trucking accounts they handle, which markets they access, and whether they have a dedicated transportation practice group.

What Underwriters Look For in a Submission

When your producer submits your account to an insurance carrier, the underwriter evaluates a specific set of data points. The stronger your submission, the more competitive your pricing:

• Loss runs — your claims history for the past 3-5 years (obtained from current and prior insurers). Loss runs show every claim filed, amounts paid, and amounts reserved. This is the #1 factor in pricing. Request your loss runs 90 days before renewal.
• CSA/SMS data — underwriters pull your FMCSA Safety Measurement System data. High BASICs narrow the field of willing underwriters.
• Driver roster with MVRs — a complete list of drivers with CDL numbers, hire dates, and motor vehicle records. One bad driver can sink an otherwise good account.
• Vehicle schedule — year, make, model, VIN, value, and radius of operation for every unit. Older equipment and long-haul operations are rated higher.
• Commodities hauled — the type of freight determines both liability and cargo exposure. Hazmat, high-value, and temperature-sensitive commodities are rated higher.
• Radius of operation — local (under 100 miles), intermediate (100-500 miles), or long-haul (500+ miles). Long-haul is more expensive due to higher severity.
• Safety program documentation — hiring standards, training materials, drug testing protocols, accident response procedures, and dash cam policies.

Insurance Carrier Selection: Admitted vs. E&S Markets

Not all insurance carriers operate the same way. Understanding the market structure helps you evaluate your options:

• Admitted (standard) carriers — licensed in the state, file their rates with the state DOI, and are backed by the state guaranty fund if they become insolvent. More stable pricing, slower underwriting, and stricter eligibility. Best for clean accounts with good loss history. Examples: Progressive Commercial, National Indemnity, Sentry.
• Excess & Surplus (E&S) carriers — not licensed in the state but authorized to write business that admitted carriers decline. More flexible underwriting, can write harder-to-place risks, but no state guaranty fund protection. Pricing can be higher and more volatile. Common for new ventures, poor loss history, or high-hazard operations. Examples: Canal Insurance, Great American (E&S division), James River.

New motor carriers (under 2-3 years of operating history) typically start in the E&S market because admitted carriers want to see at least 2 years of clean loss runs before offering terms.

The Renewal Process

Trucking insurance renewals should begin 90-120 days before expiration. Most fleet operators start too late and end up accepting whatever their current insurer offers. A proper renewal timeline:

• 120 days out — request loss runs from all insurers (current and prior). Review your CSA scores and address any deteriorating BASICs.
• 90 days out — meet with your producer to review the past year: claims activity, fleet changes, new routes, driver turnover. Discuss whether to market the account (shop it to other carriers) or negotiate with incumbent.
• 60 days out — submissions go out to target markets. Your producer should be marketing to at least 3-5 carriers for competitive quotes.
• 30 days out — quotes come back. Compare not just premium but coverage terms, deductibles, and excluded drivers. Negotiate final terms.
• 7 days out — bind coverage. Issue new certificates of insurance to all parties that require them (brokers, shippers, lessors). Update your FMCSA filing (BMC-91).

Negotiating Terms: Deductibles, SIRs, and Retrospective Rating

Premium is not the only lever in your insurance program. Structuring your deductible and retention can save significant money:

• Per-claim deductible — you pay the first $X of each claim. Increasing from $1,000 to $5,000 can reduce your premium 10-15%, but you take on more per-claim exposure.
• Self-Insured Retention (SIR) — similar to a deductible but you handle the claim directly up to the SIR amount. The insurer only gets involved above the SIR. More common for larger fleets (50+ trucks). Requires internal claims management capability.
• Retrospective rating — your premium adjusts after the policy year based on actual losses. If you have few claims, you pay less; more claims, you pay more. Only suitable for fleets large enough to have statistically credible loss data (typically 100+ trucks).
• Large deductible program — a hybrid where you take a $25,000-$100,000 deductible. Dramatically lowers premium but requires strong cash reserves and claims management.

Red Flags in Your Policy

Review your policy annually for these common problems:

• Excluded drivers — drivers specifically excluded from coverage. If an excluded driver operates a vehicle and has an accident, there is NO coverage. Ensure your roster matches your policy.
• Radius restrictions — some policies limit coverage to a stated radius (e.g., 500 miles). Exceeding the radius voids coverage for that trip.
• Named driver only — coverage only applies to specifically listed drivers, not any authorized driver. If you hire a new driver and forget to add them, they're uninsured.
• Commodity exclusions — your policy may exclude certain cargo types (hazmat, livestock, autos). Hauling an excluded commodity voids your cargo coverage.

Filing a Claim: The First 24 Hours

The first 24 hours after an incident determine the trajectory of the entire claim. Insurers consistently report that late-reported claims cost 30-45% more than claims reported within 24 hours. The reason is simple: evidence disappears, witnesses forget details, and injured parties hire attorneys when they don't hear from the carrier promptly.

Your claims reporting protocol should be drilled into every driver and dispatcher:

• Immediate (scene) — secure the scene, check for injuries, call 911 if warranted. Do NOT admit fault, do NOT discuss the accident with anyone other than law enforcement. Take photos of everything: vehicle damage, road conditions, traffic controls, debris field, weather, and all involved vehicles from multiple angles.
• Within 1 hour — notify your dispatcher/safety manager. Provide a verbal summary and transmit photos. Begin witness information collection if not already done.
• Within 4 hours — notify your insurance company's claims hotline. Most trucking policies require notification "as soon as practicable." Provide: date/time/location, description of incident, parties involved, injuries known, and photos. Early reporting triggers early investigation, which controls costs.
• Within 8 hours — complete post-accident DOT alcohol testing for qualifying accidents (any accident involving a fatality, or where the CMV driver receives a citation and there is bodily injury requiring medical treatment away from the scene or a towed vehicle).
• Within 32 hours — complete post-accident DOT drug testing.
• Within 24-48 hours — preserve all electronic evidence: dash cam footage, ELD data, GPS records, in-cab sensor data. Most systems overwrite data within 72 hours if not locked.

Documentation Requirements

Thorough documentation protects you during the claims process and in litigation. For every incident, your file should contain:

• Photos — minimum 20-30 photos per incident. All vehicle damage (close-up and full vehicle), road surface, weather conditions, traffic signs, skid marks, final rest positions, and any visible injuries.
• Police report — obtain a copy as soon as it's available (typically 5-10 business days). Note the report number at the scene.
• Driver statement — a written statement from your driver within 24 hours while memory is fresh. Include: what the driver was doing before the incident, what they saw, what they did to avoid the collision, and the sequence of events.
• Witness statements — names, phone numbers, and written or recorded statements from any witnesses. Witnesses who seem favorable at the scene may change their story later — recording them early locks in favorable testimony.
• ELD and telematics data — speed at time of incident, hours driven that day, braking events, and route history. This data can either prove your driver was operating safely or undermine your defense.
• Maintenance records — the vehicle's most recent DVIR, annual inspection, and PM records. If the accident involved a mechanical failure, maintenance records are the first thing plaintiff attorneys subpoena.

Cargo Claims Under Carmack

Cargo claims under the Carmack Amendment follow a specific burden-of-proof framework. The shipper must prove three elements: (1) the cargo was in good condition when tendered to the carrier, (2) the cargo arrived damaged or did not arrive, and (3) the amount of damages. Once the shipper proves these elements, the burden shifts to the carrier to prove one of the five defenses.

Shipper obligations that protect you: the shipper must properly package and load the cargo (unless the carrier contractually assumed loading responsibility). If the shipper loaded a trailer improperly and the cargo shifted in transit, the "act of the shipper" defense applies. Document the condition of the load at pickup — take photos of how the shipper loaded it and note any concerns on the bill of lading.

Carrier defenses under Carmack:

• Act of God — natural disasters, extreme weather events beyond reasonable anticipation
• Act of public enemy — acts of war, terrorism (rarely invoked)
• Act of the shipper — improper packaging, loading, or labeling by the shipper
• Inherent vice — the cargo's own nature caused the damage (e.g., produce spoiling due to its perishable nature, not refrigeration failure)
• Act of public authority — government seizure, quarantine, or embargo

Subrogation: Recovering Costs

Subrogation is the process of recovering claim costs from the at-fault party. When another driver causes an accident with your truck, your insurer pays your claim and then pursues the at-fault driver's insurer for reimbursement. Successful subrogation recoveries reduce your incurred losses — which directly improves your loss ratio and future premiums.

To maximize subrogation recovery:

• Document the other party's fault thoroughly at the scene (photos, witness statements, police report).
• Preserve dash cam footage showing the other party's actions.
• Obtain the other party's insurance information at the scene.
• Cooperate with your insurer's subrogation unit — respond to their requests promptly.

Subrogation typically recovers 50-70% of paid claims where the other party is clearly at fault. Even partial recovery improves your loss ratio.

Managing Your Loss Ratio

Your loss ratio is the single most important number in your insurance program. It's calculated as: total incurred losses (paid claims + reserves) divided by total earned premium. For example, if you pay $200,000 in annual premium and have $120,000 in incurred losses, your loss ratio is 60%.

• Target: under 60% — at this level, you're profitable for the insurer and will receive favorable renewal terms. Carriers with loss ratios consistently under 50% can negotiate significant premium reductions.
• 60-75% — marginal. The insurer is likely breaking even on your account after expenses. Expect flat renewal or modest increases.
• 75-100% — unprofitable. Expect significant premium increases (15-30%) or non-renewal. The insurer is losing money on your account.
• Over 100% — the insurer is paying out more in claims than they collect in premium. Non-renewal is likely. You may need to move to the E&S market.

Claims-free discounts range from 5-15% of premium for carriers with no claims in the prior policy year. Over a 3-year claims-free period, cumulative discounts of 15-25% are common. This is the most powerful argument for investing in safety: the premium savings from avoided claims compound year over year.

Claims Reserves and Their Hidden Impact

When a claim is filed, the insurer sets a reserve — an estimated amount for the total cost of the claim. Even if no money has been paid yet, the reserve counts as an incurred loss on your loss runs. This means: an open claim with a $500,000 reserve impacts your next renewal as if $500,000 had already been paid.

Actively managing claim reserves is critical. Work with your producer and insurer to ensure reserves are appropriate — not inflated. Push for prompt resolution of open claims so reserves can be closed. A 3-year-old open claim with an outsized reserve is a silent killer on your loss runs.