However, the Association of California Insurance Companies in Sacramento disputed the figures used by the insurance department, saying the complaint rate cited in the report is erroneous.

According to the insurance department's figures, of the 2,734 "total-loss" claims filed with insurers following the fires, 22 percent?or 676 cases?generated complaints over the handling of the claims by the insurer. Typically, California's insurance department receives complaints from about 1 percent of all claims in most lines of insurance.

Sam Sorich, president of ACIC, responding to the report said that of the 676 complaint cases mentioned in the study, many were actually not from "total-loss" claims.

"Our reaction to that is that when you really look at the numbers, the level of complaints was not extraordinarily high," Mr. Sorich said. He argued that the complaint level for "total-loss" claims is really only about 3.5 percent, not the 22 percent cited in the study. The insurance department spokesman was not immediately available for comment.

The report was completed after a survey of the top 76 insurers in the state, representing 95 percent of the homeowners' insurance market in Southern California, the insurance department said.

Commenting on the report, Mr. Garamendi acknowledged that some disparity between the wildfire-complaint numbers and normal claims may be attributable to the high-profile nature of the wildfires?but he added that the findings nonetheless indicate that the system is not working as effectively as it could.

"This disturbing report, at the very least, demonstrates a systemic problem of underinsurance that is happening throughout the industry," Commissioner Garamendi said. "At worst, it indicates that insurers in many cases have not held up their end of the bargain with fire survivors who are looking to rebuild their lives."

The report shows that 316 of the 676 complaints filed involved underinsurance?cases where the coverage for a home does not fully cover the amount it will take to rebuild.

Of the 316 underinsurance complaints, the California insurance department was able to get reformation and payment over policy limits on about 50 cases?with several other cases still pending. In all of the 676 claims cases with complaints, the department has helped collect more than $10 million on behalf of consumers.

"Consumers all over this nation are finding that the policies they bought for their homes do not adequately provide coverage to rebuild in the case of a total loss," Mr. Garamendi said.

He commented that "insurers already have models that they say provide an accurate estimation of the rebuilding cost. If that's so, why are so many people now facing financial hardship because they are being forced to pay much of the rebuilding cost from their own pockets?"

The report also shows that a rebuilding process in the region has been hampered by numerous problems, including the slow pace of building-permit issuances.

Of the 2,691 homes destroyed in San Diego County, only 655 have received permits to rebuild so far, and only 150 have been rebuilt and approved for occupancy. Commissioner Garamendi said that the problems responsible for this slow pace vary, but insurers' handling of claims is one of the factors.

The October 2003 wildfires resulted in an estimated 3,631 primary structures destroyed, 24 deaths and 739,597 acres destroyed, mostly in San Diego and San Bernardino counties.