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 | TOWER HILL SIGNATURE INSURANCE COMPANY (NAIC #12538) |
|---|---|
| Who filed it | The policyholder |
| Attorney of record | Grant Krapf |
| Where the property is | Davenport, Florida |
| When it was accepted by the state | April 4, 2023 |
| When the 60-day cure window closed | June 3, 2023 |
| Why, in the state’s own categories | Claim Delay, Unfair Trade Practice |
| Type of insurance | Residential Property & Casualty |
| Policy language at issue | Reference to specific policy language: The violations alleged are statutorily based and do not rely on any specific policy language. |
| Did the insurer respond | Yes, on May 5, 2023 |
Tower Hill Signature Insurance Company ("Insurer") has committed the following violations in handling the claim of its insured, [name redacted] ("Insured" or "Claimant"): 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Insurer before that of the policy holders and claimants; 3) looking for ways to deny benefit payments and otherwise "low ball" or "stone wall" claims; 4) not attempting in good faith to settle claims; 5) looking for ways to delay benefit payments; 6) misrepresenting policy provisions to Claimant; and 7) conducting inadequate investigations. The Claimant timely submitted a claim to the Insurer for Hurricane Ian damage sustained to the insured property, which occurred on or about September 28, 2022. The Insurer responded with an initial coverage determination accepting coverage for minimal interior work and the capped screen enclosure, but denying coverage for the roofing system despite widespread damage. Payments were issued in the net amount of $33,455.18. A revised coverage determination was rendered on or about March 7, 2023, wherein the Insurer provided a bottom-dollar quote from a roofer totaling $14,195.00 for roof replacement, without confirming whether the roofer would actually do the work. A supplemental payment was issued in the net amount of $940.96. Notably, in the March 7, 2023 revised payment letter, the letter does not cite any policy language in support of the revised payment. Given the clear scope and nature of the damage, the Claimant retained a public adjuster. On or about March 9, 2023, that adjuster produced a report detailing the damage to the property in the amount of $53,691.80, which was due to the Claimant under the contract of insurance. The initial investigation by the Insurer was inadequate. 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 Claimant's property. The Insurer's estimate of the insured property's loss simply would not restore the property to its pre-loss condition, which is the Insurer's duty under its own contract of insurance. The Insurer and its adjuster have colluded to misrepresent the true scope of damages to the insured property and the true replacement cost of the damages. This is an underhanded attempt to place the financial interest of the Insurer over those of the Claimant, to delay the Claimant's claim, and to delay the Claimant's ability to restore the property to its pre-loss condition. In short, the Insurer is not acting with due regard for the Claimant's interests. In Florida, the work of adjusting insurance claims engages the public trust. The Insurer has breached this duty. The Insurer has taken advantage of the knowledge imbalance between it and the Claimant to misrepresent policy provisions in an attempt to retain funds it knows should go to the Claimant to restore the property to its pre-loss condition. The Insurer's actions amount to but are not limited to the following:
1. Claim delay;
2. Not treating the policyholder with good faith claims conduct;
3. Looking for ways to reduce recovery to the Claimant;
4. Looking for ways to deny recovery to the Claimant;
5. Failing to implement proper standards for the adjustment and investigation of claims; and
6. Misrepresenting the Claimant's rights pursuant to the Insurance Policy issued by the Insurer. Therefore, to cure the defects outlined in this Civil Remedy Notice, the Insurer must:
1. Create and implement adequate guidelines for proper investigation and evaluation as to claims handling and for the training and supervision of employees, which will avoid future statutory violations as set forth above, and to avoid this from occurring in the future.
2. Act fairly and honestly towards the Claimant with due regard for their best interests in attempting to settle the claim.
3. Admit full coverage for the Claimant's loss.
4. Tender full benefits owed to the Claimant under the insurance contract, in the amount of $53,691.80 less the prior payment and applicable deductible. 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 Electronic Mail: Tower Hill Signature Insurance Company [address redacted] Gainesville, FL 32614 [email redacted]
1. Create and implement adequate guidelines for proper investigation and evaluation as to claims handling and for the training and supervision of employees, which will avoid future statutory violations as set forth above, and to avoid this from occurring in the future. 2. Act fairly and honestly towards the Claimant with due regard for their best interests in attempting to settle the claim. 3. Admit full coverage for the Claimant's loss. 4. Tender full benefits owed to the Claimant under the insurance contract, in the amount of $53,691.80 less the prior payment and applicable deductible.
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)(b) | Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. |
| 626.9541(1)(i)(3)(f) | Failing to promptly provide a reasonable explanation in writing to the insured of the basis in the insurance policy, in relation to the facts or applicable law, for denial of a claim or for the offer of a compromise settlement. |
Filed with the state on May 5, 2023. 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 686494. 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.
The split denial: accept the small stuff, deny the expensive stuff. Tower Hill’s first letter on this Ian claim covered minimal interior damage and a screen enclosure while denying the roof system itself. Months later a revised coverage-determination letter moved the number to $33,455.18.
The revision is the story. The same carrier, the same roof, and a different answer once the policyholder pushed, which is why a first denial letter is a position and not a verdict. The whole sequence, both letters described and dated, sits in a public DFS Civil Remedy filing.
Fla. DFS Civil Remedy Notice, Filing No. 686494 (Wallace v. Tower Hill Signature) · 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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