We granted leave to determine whether defendant General Accident Insurance Company of America (GAl), which insured defendant Process Design Associates, should be estopped from enforcing policy exclusions against plaintiffs during a garnishment action initiated by plaintiffs to satisfy a judgment rendered against Process Design. We hold that GAl is not estopped from enforcing the policy exclusions against plaintiffs. Gai satisfied its duty to notify its insured, Process Design, that it was defending the case under a reservation of rights. Under Michigan law, there is no additional duty that requires an insurer that is not a party to the lawsuit to notify a plaintiff about a potential lack of coverage. Moreover, GAI cannot be estopped from enforcing the policy *590exclusions against plaintiffs because of an answer given by Process Design to an interrogatory regarding insurance coverage.

i

Plaintiff Alden Kirschner was injured at his place of employment in September 1987, when a heated mixture of caustic soda erupted from a caul plate washing system, splashing his face, eyes, and upper body and causing chemical bum injuries. In September 1988, plaintiffs1 filed suit against several parties, including defendant Process Design. Process Design had allegedly designed, manufactured, and installed the equipment that caused the injury. Process Design was insured by defendant GAL

On April 29, 1989, the complaint was amended to add additional defendants. The amended complaint alleged eleven theories of liability. Process Design was served with the amended complaint, as well as plaintiffs’ first interrogatories and first request for production of documents on June 7, 1989. On June 23, 1989, Walt McVey, a claims representative for GAI, sent a letter to plaintiffs’ counsel that stated in pertinent part:

As I have indicated to you we have just begun the investigation into this matter and are attempting same under a reservation. Once we have resolved all coverage and liability issues I will advise accordingly. Should you have any questions, please feel free to contact me at the above captioned number.

*591On June 28, 1989, gai assigned the defense of its insured, Process Design, to counsel Eugene Hoiby. Hoiby was advised that gai was defending under a reservation of rights. On June 30, 1989, GAI sent the first of three reservation of rights letters to Process Design. Subsequent letters were sent on March 19, 1991, and August 31, 1992. Gai defended the action under a reservation of rights because some of plaintiffs’ allegations — specifically those alleging negligent design — were excluded from coverage under the applicable policy. It is undisputed that gai’s insured, Process Design, understood that gai would not indemnify Process Design if the jury reached a verdict based upon a finding of negligent design or engineering.

On December 13, 1989, Process Design answered plaintiffs’ first interrogatories. Interrogatory 7 asked, “Was there any policy of insurance covering the Defendant on the date of this incident against the type of claim involved in this matter?” Additionally, if there was a policy, the interrogatory requested: “(a) The name and address of the insurer, (b) The name and address of the insured, (c) Whether primary or secondary coverage, policy number, (d) Effective dates of the coverage, (e) Limits of liability, (f) Deductible or self-insured retention, if any.” Process Design responded to the interrogatory with the following answer: “General Accident Insurance Company, P.O. Box 16666, Columbus, Ohio, $1,000,000.00 coverage.” Plaintiffs’ counsel admits that he did not pursue production of the policy itself.

The case proceeded to trial against Process Design only. Plaintiffs’ theory throughout the trial was that Process Design had negligently designed the equip-*592merit that caused the injury, and plaintiffs ultimately received a jury verdict on that basis. Plaintiffs then brought a garnishment action against gai to satisfy the judgment. Gai moved for summary disposition, seeking to enforce the policy exclusion. The trial court concluded that the jury verdict fell within the policy exclusion and that gai had provided adequate notice to its insured, Process Design, of a reservation of rights. However, the trial court determined that GAI was estopped from asserting the exclusions against plaintiffs because GAI had failed to adequately notify plaintiffs about the potential lack of insurance coverage. Accordingly, the trial court granted summary disposition in favor of plaintiffs.

In a two-to-one decision, the Court of Appeals reversed the judgment of the trial court, concluding that Process Design’s answer to the interrogatory was not a basis to estop gai from enforcing the policy exclusions against plaintiffs.2 The Court of Appeals noted that the general rule is that an attorney representing an insurance company’s insured owes a duty to the client — the insured — and not to the insurance company. Slip op, p 2. The Court of Appeals also determined that the answer to the interrogatory was not false or misleading, as many of the eleven allegations raised in the complaint were covered by the policy because they were not based upon negligent design or engineering. Thus, Process Design did have coverage for the “type of claim” involved. Slip op, pp 2-3. Finally, the Court of Appeals held that while gai was required to notify its insured, Process Design, of *593a reservation of rights, it did not have a duty to notify plaintiffs. Because Process Design had received adequate notice, it was not proper for the trial court to consider prejudice to plaintiffs because plaintiffs had no greater rights than did Process Design. Consequently, the Court of Appeals concluded that summary disposition should have been granted in favor of GAI. Slip op, pp 3-4. This Court granted leave to appeal. 458 Mich 875 (1998).

n

Generally, once an insurance company has denied coverage to an insured and stated its defenses, the insurance company has waived or is estopped from raising new defenses. Michigan Twp Participating Plan v Federal Ins Co, 233 Mich App 422, 435-436; 592 NW2d 760 (1999); Smit v State Farm Mut Automobile Ins Co, 207 Mich App 674, 679-680; 525 NW2d 528 (1994); see also Johnson v Yorkshire Ins Co, 224 Mich 493, 496-497; 195 NW 45 (1923). Further, when an insurance company undertakes the defense of its insured, it has a duty to give reasonable notice to the insured that it is proceeding under a reservation of rights, or the insurance company will be estopped from denying its liability. Meirthew v Last, 376 Mich 33, 39; 135 NW2d 353 (1965) (emphasis added).3 The *594application of waiver and estoppel is limited, and, usually, the doctrines will not be applied to broaden the coverage of a policy to protect the insured against risks that were not included in the policy or that were expressly excluded from the policy. Ruddock v Detroit Life Ins Co, 209 Mich 638, 654; 177 NW 242 (1920); Lee v Evergreen Regency Cooperative, 151 Mich App 281, 285; 390 NW2d 183 (1986). This is because an insurance company should not be required to pay for a loss for which it has charged no premium. Id. As this Court has explained, applying the doctrine of waiver and estoppel to broaden the coverage of a policy would make a contract of insurance

cover a loss it never covered by its terms, to create a liability not created by the contract and never assumed by the defendant under the terms of the policy. In other words, by invoking the doctrine of estoppel and waiver it is sought to bring into existence a contract not made by the parties, to create a liability contrary to the express provisions of the contract the parties did make. [Ruddock, supra at 654.]

Despite the limited applications of waiver and estoppel, in some instances, courts have applied the doctrines to bring within coverage risks not covered by the policy. Smit, supra at 679-683; Lee, supra at 286-287. For example, in situations in which the insurance company has misrepresented the terms of the policy to the insured or defended the insured without reserving the right to deny coverage, courts have *595extended coverage beyond the terms of the policy when the inequity to the insurer as a result of the broadened coverage is outweighed by the inequity suffered by the insured. Smit, supra at 682-683; Lee, supra at 287. However, we have never held that waiver or estoppel can be applied to extend coverage beyond the terms of the policy when an insurer, who is not a party to the underlying litigation, fails to notify a plaintiff, who is not the insured, of a reservation of rights.4

*596A

In the present case, it is undisputed that GAI provided its insured, Process Design, with reasonable notice of its reservation of rights. The first reservation of rights letter was sent within one month of Process Design’s receipt of plaintiffs’ amended complaint.5 Two subsequent reservations of rights letters were also sent. Thus, it is apparent that Process Design was not prejudiced by a lack of notice that GAI was defending under a reservation of rights.6 Therefore, in this case, plaintiffs, as judgment creditors, stand in no better position than that of the principal defendant, Process Design Associates, and they are entitled to recover against GAI only to the extent that Process Design could recover against GAI. Kidd v Minnesota Atlantic Transit Co, 261 Mich 31, 34; 245 NW 561 (1932); Smit, supra at 683. Because Process Design cannot apply the doctrine of waiver or estoppel to extend coverage beyond the terms of the policy, neither can the plaintiffs. Gai aptly identified why plaintiffs’ claim fails when it observed that plaintiffs did not simply want to stand in Process Design’s shoes, but rather wanted new shoes.

*597B

Despite the fact that GAI satisfied its duty to notify Process Design of its reservation of rights, plaintiffs argue that GAI should be estopped from denying coverage because of Process Design’s answer to an interrogatory regarding insurance coverage. Process Design offered the following answer in response to plaintiffs’ interrogatory asking whether there was “any policy of insurance covering the Defendant on the date of this incident against the type of claim involved in this matter”:

General Accident Insurance Company RO. Box 16666, Columbus, Ohio $1,000,000.00 coverage.

Plaintiffs contend that this answer was misleading because GAI was proceeding under a reservation of rights and that the answer should estop GAI from asserting the policy exclusions.

Pursuant to MCR 2.309(B)(1):

Each interrogatory must be answered separately and fully in writing under oath. The answers must include such information as is available to the party served or that the party could obtain from his or her employees, agents, representatives, sureties, or indemnitors. If the answering party objects to an interrogatory, the reasons for the objection must be stated in lieu of an answer. [Emphasis added.]

Pursuant to MCR 2.114(E), the court may sanction a party’s attorney or the represented party for providing a false or misleading answer to an interrogatory. Despite the fact that Process Design is the answering party in this case and that Process Design, as well as *598its attorney, could be sanctioned for a misleading answer, plaintiffs’ argument implies that the insurer, gai, should be held responsible for the answer of its insured, Process Design, to the interrogatory. We disagree.

The general rule is that “[n]o attorney-client relationship exists between an insurance company and the attorney representing the insurance company’s insured. The attorney’s sole loyalty and duty is owed to the client, not to the insurer.” Michigan Millers Mut Ins Co v Bronson Plating Co, 197 Mich App 482, 492; 496 NW2d 373 (1992), aff’d 445 Mich 558; 519 NW2d 864 (1994).7 Even if one could characterize the answer to the interrogatory as misleading,8 we decline to hold that gai should be estopped from enforcing the policy exclusions. The answer to the interrogatory is not chargeable to gai but to Process Design. It is Process Design and its attorney who should be held accountable for the answer. Therefore, we hold that Process Design’s answer to the interrogatory does not *599provide a basis for estopping gai from enforcing the policy exclusions.

m

In summary, we hold that GAI is not estopped from enforcing the policy exclusions against plaintiffs. Gai satisfied its duty to notify its insured, Process Design, that it was defending the case under a reservation of rights. Under Michigan law, there is no additional duty that requires an insurer that is not a party to the lawsuit to notify a plaintiff about a potential lack of coverage. Moreover, gai cannot be estopped from enforcing the policy exclusions against plaintiffs because of an answer given by Process Design to an interrogatory regarding insurance coverage. The answer to the interrogatory is not chargeable to GAI but to its insured, Process Design Associates.

Affirmed.

I concur in the result reached by the majority. However I write separately to express my view concerning future actions. I would hold that, in future cases where an insurer defends under a reservation of rights, it must promptly notify both the court and the other parties of its intention. Also, I would favor the imposition of a court rule to that effect, in accordance with the procedures outlined in MCR 1.201.

The rationale behind the requirement is twofold: First, notification to the court is a simple courtesy and would promote efficient use of judicial resources and more fully inform the court of issues possibly emerging at trial. Having knowledge that an insurer is defending under a reservation of rights, the trial court *600may better assess the likelihood of pretrial settlement and plan accordingly. This Court should adopt a rule of notification in the interest of docket management.

Second, although the adjudication of the underlying claim is of consequence to a plaintiff, the practical effects of an insurer’s reservation of rights are also significant. With the rising cost of litigation, a major factor in a plaintiff’s decision to pursue a claim is the actual ability to recover for injury. It would seem in the interests of all parties, then, to fully disclose an insurer’s potential liability in the eventuality that a jury finds for the plaintiff.

Failure to timely disclose a disclaimer of liability should subject an insurer to possible estoppel. I note that other jurisdictions have held that prejudice resulting to a plaintiff is a relevant consideration in deciding whether an insurer is estopped from disclaiming coverage. Appell v Liberty Mut Ins Co, 22 AD2d 906; 255 NYS2d 545 (1964); Mundry v Great American Ins Co, 369 F2d 678, 681 (CA 2, 1966).1 As *601aptly stated in Fellows v Mauser:2

[T]he court should determine to what extent the plaintiff will be prejudiced in deciding whether to give effect to a reservation of rights. The prejudice referred to in Mundry relates to the fact that an insurance company by defending a suit “(holds) itself out to the injured party as willing to pay the judgment.” Shelby Mut Cos Co v Richmond, 185 F2d 803, 806 (CA 2, 1950). Thus, if a plaintiff brings suit against a judgment proof motor vehicle operator and goes to trial on that suit relying on the fact that an insurance company has taken over the defense, the plaintiff would be severely prejudiced if he learned after trial that there was a reservation of rights and the insurer will not pay the judgment. [302 F Supp 937.]

I would adopt this reasoning.

As Michigan law historically has not required notification of a reservation of rights, I agree with the majority that defendant should not be estopped from asserting its defense here. However, a different rule should adhere in future cases. In addition to notifying its insured that it is acting under a reservation of rights, I would require the insurer to timely notify the court and the other parties. A court should be empowered to refuse to give effect to a reservation of rights when it determines that the insured’s failure to give timely notice prejudiced the plaintiff.