What is the test for a plaintiff to sue an insurer for failure to provide proper cause for a loss under a policy of good faith and fair dealing?

In "first party cases" involving an insured's claim against an insurer, the implied covenant of good faith and fair dealing "obligates the insurer to make a thorough investigation of the insured's claim for benefits, and not to unreasonably delay or withhold payment of benefits." (Major v. Western Home Ins. Co., supra, 169 Cal.App.4th at pp. 1209-1210.) If the insurer "without proper cause" refuses to compensate the insured for a loss covered by the policy or unreasonably delays payments

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due under the policy, its conduct is actionable. (Waters v. United Services Auto. Assn. (1996) 41 Cal.App.4th 1063, 1070.)