Stated otherwise, "the insurer's offer of UIM coverage must be ‘meaningful.’ " Cohen v. Progressive N. Ins. Co., 402 S.C. 66, 737 S.E.2d 869, 872 (2013) (quoting Atkins v. Horace Mann Ins. Co., 376 S.C. 625, 658 S.E.2d 106, 109 (2008) ). The distinction between UM and UIM coverage in this context "relate[s]to the existence of a state-law mandate that motorists carry a minimum amount of [UM] coverage and the absence of any such requirement for [UIM] coverage."
; Cohen v. Progressive Northern Ins. Co., 402 S.C. 66, 76, 737 S.E.2d 869, 874 (Ct. App. 2013) ("[A]n insurer's noncompliance with subsection 38-77-350(B) does not render the use of the subsection 38-77-350(A) form a 'noncomplying offer.'").
Such an offer must be meaningful. Cohen v. ProgressiveN. Ins. Co., 737 S.E.2d 869, 872 (S.C. Ct. App. 2013). If the insurer fails to make a meaningful offer of UIM coverage, a court will reform the policy to include that coverage up to the insured's limits of liability coverage.