A Civil Remedy Notice is a formal complaint filed against an insurance company with Florida's Department of Financial Services. Filing one is the step Florida law requires before a policyholder can sue an insurer for bad faith. It is a public record, and the insurer gets 60 days to fix the problem before that right opens up.
So this is the policyholder's side of a dispute, written by their side, and it is an allegation rather than a finding. The insurer answered it, and its answer is published below alongside the complaint. Read both. Names, addresses, and policy and claim numbers have been removed here; everything else is quoted from the filing.
| Who the filing is against | FRONTLINE INSURANCE UNLIMITED COMPANY (NAIC #10074) |
|---|---|
| Who filed it | The policyholder |
| Attorney of record | Grant Krapf |
| Where the property is | Jacksonville, Florida |
| When it was accepted by the state | February 12, 2025 |
| When the 60-day cure window closed | April 13, 2025 |
| Why, in the state’s own categories | Claim Delay, Unfair Trade Practice |
| Type of insurance | Residential Property & Casualty |
| Policy language at issue | 627.70131(7)(a)Within 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer. The insurer shall provide a reasonable explanation in writing to the policyholder of the basis in the insurance policy, in relation to the facts or applicable law, for the payment, denial, or partial denial of a claim. If the insurer's claim payment is less than specified in any insurer's detailed estimate of the amount of the loss, the insurer must provide a reasonable explanation in writing of the difference to the policyholder. Any payment of an initial or supplemental claim or portion of such claim made 60 days after the insurer receives notice of the claim, or made after the expiration of any additional timeframe provided to pay or deny a claim or a portion of a claim made pursuant to an order of the office finding factors beyond the control of the insurer, whichever is later, bears interest at the rate set forth in s. 55.03. Interest begins to accrue from the date the insurer receives notice of the claim. The provisions of this subsection may not be waived, voided, or nullified by the terms of the insurance policy. If there is a right to prejudgment interest, the insured must select whether to receive prejudgment interest or interest under this subsection. Interest is payable when the claim or portion of the claim is paid. Failure to comply with this subsection constitutes a violation of this code. However, failure to comply with this subsection does not form the sole basis for a private cause of action. 627.444(2)(a) Notwithstanding any other law, an insurer shall provide to an insured within 15 calendar days after an individual or entity designated by the insurer receives the insured's written request, either: A loss run statement; Reference to specific policy language: The violations alleged are statutorily based and do not rely on any specific policy language. "It is an accepted principle of law that when parties contract upon a matter which is the subject of statutory regulation, the parties are presumed to have entered into their agreement with reference to such statute, which becomes a part of the contract, unless the contract discloses a contrary intention." Westside EKG Assocs. v. Found. Health, 932 So. 2d 214, 216 (Fla. 4th DCA 2005), aff'd, 944 So. 2d 188 (Fla. 2006). |
| Did the insurer respond | Yes, on September 26, 2025 |
First Protective Insurance Company d/b/a Frontline Insurance (the "Insurer") has committed the following in handling the Insured's claim: 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Insurer before that of the policyholder and the Insured; 3) looking for ways to deny benefit payments and otherwise "low ball" or "stone wall" claims; 4) not adjusting the claims promptly and fairly; 5) not attempting in good faith to settle claims; 6) conducting inadequate investigations; 7) failing to employ policies and procedures to conduct adequate investigations; 8) shifting the burden of investigating the loss onto the Insured; 9) failing to render a claims determination within sixty (60) days; 10) requesting a re-inspection only after the Insured retained a public adjuster; 11) failing to acknowledge and act promptly upon communications with respect to claims; 12) failing to provide a loss run statement; and 13) misrepresenting the terms of the insurance policy. On or about September 18, 2024, while the subject policy was in full force and effect, the Insured's suffered a loss caused by wind. The areas impacted include but are not limited to the roofing system, exterior surfaces, bonus room closet, and bathroom. The Insured timely submitted a claim on September 26, 2024, to the Insurer for wind damage and the ensuing damage therefrom. Thereafter, the Insurer assigned claim no. [redacted] to the loss and sent a field adjuster to inspect the property on October 7, 2024. Given the scope and nature of the damage, the Insured retained a public adjuster. After assessing the damage and the true scope of repairs, the public adjuster prepared an estimate identifying $82,258.38 in covered damage to the dwelling. The foregoing estimate, photographs, and a letter of representation from the public adjuster were sent to the Insurer who subsequently re-inspected the property. The reinspection clearly demonstrates that the Insurer's initial inspection was inadequate and was only meant to provide a "low-ball" estimate to wait and see if that amount would be accepted. Furthermore, this shows that the Insurer has implemented policies and procedures that once a public adjuster has been retained, the Insurer will request a reinspection despite no changes occurring at the property, and that the Insurer treats represented Insureds differently than those who are unrepresented. It was not until January 14, 2025, one-hundred ten (110) days after the Insured reported their loss that the Insurer issued its coverage determination letter in which it notified the Insured that it was extending partial coverage for the loss. However, the Insurer wrongfully determined that it would only require $1,458.86 to restore the insured property to its pre-loss condition, which resulted in no payment being issued to the Insured as the amount of covered damage allegedly fell below the policy deductible. The Insurer's lowball estimate is that of a classic under scope and under value of the claim. The Insurer has placed obstacles to the Insured's ability to have the claim adjusted promptly to begin restoring the home by waiting more than sixty (60) days after receiving notice of the loss to make a claims determination. Under Fla. Stat. 627.70131(7)(a), "[w]ithin 60 days after an insurer receives notice of an initial, reopened, or supplemental property insurance claim from a policyholder, the insurer shall pay or deny such claim or a portion of the claim unless the failure to pay is caused by factors beyond the control of the insurer which reasonably prevent such payment." There were and are currently no factors outside of the Insurer's control. As the Insurer has failed to make a timely determination, it has violated this code. As such, in addition to the below requirements to cure this CRN, any payment made to the Insured must contain interest for the damage as a result of the loss from the date the Insurer received first notice of the loss. The Insurer misrepresented the loss and issued a wrongful partial denial. The Insurer denied coverage for damage sustained to the roofing system based on the rationale that the damage sustained was a result of " wear and tear, deterioration, faulty, inadequate, or defective: workmanship, repair, construction, materials used in repair or construction, and maintenance." Although the Insurer and Insured are in dispute about how the roof was damaged, the Insurer knows or should know that when independent perils converge and no single cause can be considered the sole or proximate cause, it is appropriate to apply the concurring cause doctrine. Sebo v. Am. Home Assurance Co., 208 So. 3d 694, 697 (Fla. 2016). The concurring cause doctrine states that coverage may exist where an insured risk constitutes a concurrent cause of the loss even when it is not the prime or efficient cause. Id. at 698. A covered peril that meets with an uncovered peril may still provide for coverage under a policy when the covered peril triggered the events that eventually led to the loss. Id. at 697. The claims determination letter failed to comply with Fla. Stat. 626.9541(1)(i)(3)(f) as it did not include a reasonable explanation of the basis in the insurance policy, in relation to the facts, for the denial. The letter simply copies several policy exclusions with no explanation. Upon receiving notice of the loss, the Insurer had the duty to provide the full benefits under the policy. This includes providing the Insured with a proper investigation and the funds necessary to return the home to its pre-loss condition. There may be further wrongful conduct which has not been made known to the Insured at this moment. Certain conduct or actions may be discovered throughout discovery or cannot be verified without a review of the Insurer's claim file and standards and procedures for the adjustment and investigation of claims. The Insurer also failed to allocate and pay for overhead and profit, pursuant to Florida Statute 627.7011(3)(a). Where the Insureds are reasonably likely to need a general contractor for the repairs, Florida Statute 626.7011(3) does not permit an Insurer to withhold overhead and profit pending the actual repair, unless absent a showing by the Insureds that it was likely to need a general contractor for the repairs. Trinidad v. Fla. Peninsula ins. Co., 121 So. 3d 433, 435 (Fla. 2013). The Insurer has implemented policies and procedures that are designed to wrongfully withhold costs associated with restoring the insured property to its pre-loss condition. This is an underhanded attempt by the Insurer to place its financial interest above those of the Insured. Additionally, Insurer shifted the burden and cost of investigating and insuring the loss onto the Insured. During their investigation, the insurer's adjuster did not use a moisture meter, despite the presence of interior water damage. A moisture meter can be purchased online from Amazon for around $40 before tax. The Insurer could purchase a moisture meter and assess thousands of properties with one meter. Instead, the Insurer would rather place its financial interests over those of the Insured by failing to provide the adjuster with the necessary tools to correctly inspect the loss. As a result of the inadequate investigation and surrounding circumstances it is apparent that the Insurer significantly underestimated the scope of the loss to the Insured's property. The Insurer and its adjuster have colluded to misrepresent the true scope of damages to the insured property and the true replacement costs of the damages. Furthermore, the Insurer and its agents failed to comply with Fla. Stat. 627.444 by not providing the Insured and the Insured's representatives with a loss run statement. On January 27, 2025, the Insured's legal counsel provided the Insurer with a letter of representation. Within the letter, legal counsel requested a copy of a loss run statement. The Insurer and its agents have not acknowledged the request for a loss run statement nor has a loss run statement been provided. Upon receiving a written request for a loss run statement, the Insurer is required, within fifteen (15) calendar days, to provide either a loss run statement or information on how to obtain a loss run statement at no charge through a consumer reporting agency. There has been no response within fifteen (15) calendar days of the Insured's written request and the Insurer has not provided information on how to obtain a loss run statement at no charge through a consumer reporting agency. This Insurer has breached its duty to settle claims in good faith when, under all the circumstances, it could and should have done so. The Insurer and its agents have not acted fairly and honestly toward the Insured and the Insured's representative and have moreover failed or refused to promptly acknowledge the Insured's communications in an attempt to frustrate and delay the resolution of the Insured's claim. In short, the Insurer is not acting with due regard for the Insured's interests or safety. In Florida the work of adjusting insurance claims engages the public trust. The Insurer has breached this trust and its duty to the Insured. The Insurer and its agents conducted cursory and inadequate investigations and wrongfully determined that it would only require $1,458.86 to restore the insured property to its pre-loss condition. Moreover, the Insurer has engaged in bad faith practices designed to delay claims and prevent the Insured from recovering what is rightfully owed under the subject policy of insurance. The Insurer's actions and inactions have continued to frustrate and delay the resolution of the Insured claim. The Insurer's actions amount to but are not limited to the following:
1. Claim delay
2. Not treating the Insured with good faith claims conduct
3. Looking for way to reduce recovery to the Insured
4. Looking for ways to deny recovery to the Insured
5. Not adjusting claims and evaluating loss properly, promptly and fairly to provide full and prompt indemnity to the Insured
6. Not training, supervising or managing adjusters properly so that prompt and full payments are made, but rather placing the company's interests before the Insured's interests
7. Placing the financial interest of the Insurer over that of the health and safety of the Insured
8. Shifting the burden of investigating onto the Insured
9. Conducting inadequate investigations 10. Failing to render a written claims determination to the Insured within [address redacted]atute 627.70131 11. Requesting a re-inspection despite no changes to the above-referenced insured property 12. Treat represented and unrepresented Insured differently 13. Failing to provide a loss run statement 14. Making material misrepresentations Therefore, to cure the defects outlined in this civil remedy notice, the Insurer must: (1). Admit full coverage for the Insured's loss. (2). Tender full benefits owed to the Insured under the insurance contract. A copy of this form submitted to the FDFS has been sent via e-mail to the following parties providing them notice of the filing of the civil remedy notice. Please e-mail any response to this civil remedy notice to [email redacted]. Via E-mail: First Protective Insurance Company d/b/a Frontline Insurance [address redacted] [name redacted] FL 32795 [email redacted]
(1). Admit full coverage for the Insured's loss. (2). Tender full benefits owed to the Insured under the insurance contract.
These are the statutes named on the form. The wording under each is the statute's own, as the state prints it on the notice.
| 624.155(1)(b)(1) | Not attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests. |
|---|---|
| 624.155(1)(b)(3) | Except as to liability coverages, failing to promptly settle claims, when the obligation to settle a claim has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage. |
| 626.9541(1)(i)(2) | A material misrepresentation made to an insured or any other person having an interest in the proceeds payable under such contract or policy, for the purpose and with the intent of effecting settlement of such claims, loss, or damage under such contract or policy on less favorable terms than those provided in, and contemplated by, such contract or policy. |
| 626.9541(1)(i)(3)(a) | Failing to adopt and implement standards for the proper investigation of claims. |
| 626.9541(1)(i)(3)(c) | Failing to acknowledge and act promptly upon communications with respect to claims. |
| 626.9541(1)(i)(3)(d) | Denying claims without conducting reasonable investigations based upon available information. |
Filed with the state on September 26, 2025. This is the insurer's own written response to the complaint above, quoted from the same public record.
Florida DFS Civil Remedy Notice, filing number 806581. Read the filing on the state's site ↗
A Civil Remedy Notice records an allegation, not a finding. Nothing here has been decided by a court or by the Department. Not legal advice; consult an attorney about your specific claim.
Selected from the Civil Remedy Notices read for the archive as a documented example of a claim blamed on workmanship. The pattern page shows how often that argument appears and which carriers the filings name.
Fla. DFS Civil Remedy Notice, Filing No. 806581 (Jacksonville), accepted 2/12/2025 · public record ↗
Quotes are verbatim from the cited public record. Case status and statute summaries drafted August 2026; verify against the current docket and statute. Not legal advice; consult an attorney about your specific claim.
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