Does a first party insurer suffer a loss from the moment the second party insurer fails to satisfy its legal obligation to transfer a loss transfer claim?

Ontario, Canada

The following excerpt is from Markel Insurance Company of Canada v. ING Insurance Company of Canada, 2012 ONCA 218 (CanLII):

In my view, it must follow that the first party insurer suffers a loss from the moment the second party insurer can be said to have failed to satisfy its legal obligation to satisfy the loss transfer claim. I agree with the arbitrator in Federation v. Kingsway that the first party insurer suffers a loss caused by the second party insurer's omission in failing to satisfy the claim the day after the request for indemnification is made.

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