With no explanation, chose the best option from "A", "B", "C" or "D". for “it is well settled that attorney’s fees and penalty attach if the insured is required to file suit, even though judgment is confessed before trial” (quoting Federal Life & Cas. Co. v. Weyer, 239 Ark. 663, 666, 391 S.W.2d 22, 23 (1965)). Allowance of the statutory penalty and attorney’s fees is penal in nature and is to be strictly construed. Shepherd v. State Auto Property & Cas. Ins. Co., 312 Ark. 502, 850 S.W.2d 324 (1993). The statute is directed against unwarranted delaying tactics of insurers. Id. The insurer’s good faith in contesting coverage is not a defense. See Home Mut. Fire Ins. Co. v. Jones, 63 Ark. App. 221, 977 S.W.2d 12 (1998) (finding the penalty was appropriate despite the insurer’s purported good faith in contesting claim). But cf. Silvey Co. v. Riley, supra (<HOLDING>); Miller’s Mut. Ins. Co. v. Keith Smith Co.,

A: holding that after a reasonable investigation an insurer must promptly settle a claim for the value or within the range assigned to the claim as a result of its investigation
B: holding that an insurer has a duty to conduct an investigation reasonably appropriate under the circumstances
C: holding that when the insurer takes the position that the policy does not cover the complaint the insurer must 1 defend the suit under a reservation of rights or 2 seek a declaratory judgment that there is no coverage if the insurer fails to take either of these actions it will be estopped from later raising policy defenses to coverage
D: holding that the insurer is allowed to continue its investigation beyond the time that payment is due under the policy if reasonably necessary
D.