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p0524 REVIEW DENIED If the essence of the action against an insurance broker was that s/he failed to obtain the coverage requested, it is subject to the statute of limitations on actions for professional negligence, no matter how the claim is styled; although the statute of limitations in an action against an insurer based on its denial of a claim may be tolled until it formally denies the claim in writing, this rule does not apply to an action against the broker.CitationHYDROMILL v HAYWARD (Undercoverage) 115 Cal.App.4th 1145 [See: CCP 339, 338, 343, 340.9; Saunders v Cariss 224 CA3 905; Smyth v USAA 5 Cal.App.4th 1470]
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