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 INSURANCE EXCHANGE (NAIC #17179) |
|---|---|
| Who filed it | The policyholder |
| Attorney of record | Kaci Line |
| Where the property is | Clermont, Florida |
| When it was accepted by the state | December 2, 2024 |
| When the 60-day cure window closed | January 31, 2025 |
| Why, in the state’s own categories | Claim Delay, Claim Denial, Unsatisfactory Settlement Offer, Unfair Trade Practice |
| Type of insurance | Residential Property & Casualty |
| Policy language at issue | The complainant will abbreviate the full policy language for purposes of brevity while clearly identifying the significant portions so the Respondent may identify the full language... THIS VIOLATION REFERENCES THE DEFINITIONS CONTAINED WITHIN THE POLICY AND ITS AMENDMENTS AND ENDORSEMENTS THAT PERTAIN TO COVERAGES FOR ROOF AND WATER DAMAGES (INDIVIDUALLY AND COLLECTIVELY) TO THE PROPERTY OF [name redacted] AND [name redacted] . THIS VIOLATION ALSO REFERENCES COVERAGES - COVERAGE A - DWELLING AND ALL APPLICABLE PORTIONS OF THE POLICY, INCLUDING BUT NOT LIMITED TO AMENDMENTS AND ENDORSEMENTS. THIS VIOLATION ALSO REFERENCES THE COVERAGE B - OTHER STRUCTURES PORTION OF THE POLICY, INCLUDING BUT NOT LIMITED TO AMENDMENTS AND ENDORSEMENTS. THIS VIOLATION ALSO REFERENCES PERILS INSURED AGAINST COVERAGE A - DWELLING AND COVERAGE B OTHER STRUCTURES, ITS APPLICABLE PORTIONS OF THE POLICY, INCLUDING BUT NOT LIMITED TO AMENDMENTS AND ENDORSEMENTS. THIS VIOLATION ALSO REFERENCES THE ORDINANCE AND LAW PORTION OF THE POLICY THAT WAS PURCHASED WITH PREMIUM DOLLARS PAID TO TOWER HILL INSURANCE . THIS VIOLATION ALSO REFERENCES SECTION I - CONDITIONS - SUBSECTION 3 LOSS SETTLEMENT AND ITS APPLICABLE PORTIONS OF THE POLICY, INCLUDING BUT NOT LIMITED TO AMENDMENTS AND ENDORSEMENTS. THIS VIOLATION ALSO REFERENCES FUNGI, WET OR DRY ROT OR BACTERIAL COVERAGE ENDORSEMENT. |
| Did the insurer respond | Yes, on January 8, 2025 |
On out about, October 10, 2024, during the coverage period while the policy was in full force and effect, the subject property sustained a sudden and accidental covered loss as a result of a hurricane event, Hurricane Milton, causing extensive damage to the property. TOWER HILL INSURANCE ("TOWER HILL") received timely notice of the claim and assigned claim no. [redacted]. TOWER HILL performed a cursory inspection of the property that failed to retain the experts necessary to identify the repairs necessary to restore the property to its pre-loss condition. TOWER HILL continued the intentional path of claim delay and underpayment by failing to implement policies and procedures for payment of clearly covered claims. TOWER HILL time and time again, relies upon "cookie-cutter" reports that less than ironically state the cause of the damage to be identical to those exclusions found inside of TOWER HILL's policy of insurance. TOWER HILL continues to fail to promptly settle the claim when its obligation to settle has, under all the circumstances, become reasonably clear. There is no question the roof of the Insured's home was stuck by hurricane winds so severe that caused damage and requiring a full roof replacement, solar pool heater, and pool enclosure. Despite this, TOWER HILL denied coverage for the clearly covered loss. TOWER HILL continues to rely upon more restrictive definitions of damage that is not contained within the policy and appears to only look for damage that would not be covered while intentionally not photographing or documenting the extensive covered damage. Furthermore, TOWER HILL intentionally did not photograph multiple damaged area of the Insured's property and did not use clearly damaged property areas while determining the covered loss. TOWER HILL relies upon the report and estimate of its adjuster which bears little to no relationship to the actual, visible damage to the roof and its necessary repair/replacement. It is clear that TOWER HILL has put its own interest over that of its insured and has made this case about protecting its bottom line as opposed to living up to the contract of insurance it was paid premium dollars for. The insurer's conduct in this case occurs with such frequency as to constitute a general business practice. TOWER HILL knows it has failed to issue proper payment for the clearly covered loss to include damages and repairs covered by the policy and Florida law. Moreover, TOWER HILL has failed to comply with its loss settlement provision. Rather than issuing the proper payment or attempting to reach an agreement with its insured, TOWER HILL is delaying and denying the claim. Upon information and belief, TOWER HILL performs the subject actions as a business practice, including delaying and denying the claim and issuing "low ball" payments in an attempt to dissuade its insureds from pursuing the claim to the detriment of its insureds to increase financial profits. TOWER HILL INSURANCE can cure the violations contained herein by issuing a payment for all contractual damages owed, per estimates of $49,189.61plus interest, costs, and attorney's fees. This willful and wanton business practice in reckless disregard for the right of insurer's insureds and is a violation of Florida Statute 624.155(1)(B)(1) which states it is an unfair claims settlement practice in "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 interest." This willful and wanton business practice of insurer, in reckless disregard for the rights of its insureds, is in violation of Florida Statute 624.155(1)(B)(3), which defines unfair claims settlement practices to include "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." This willful and wanton business practice of insurer, in reckless disregard for the rights of its insureds, is in violation of Florida Statute 626.9542(1)(I)(3)(a), which defines unfair claims settlement practices to include "failing to adopt and implement standards for the proper investigation of claims."
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)(2) | Making claims payments to insureds or beneficiaries not accompanied by a statement setting forth the coverage under which payments are being made. |
| 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)(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)(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. |
| 626.9541(1)(i)(3)(e) | Failing to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or failing to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed. |
| 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. |
| 626.9541(1)(i)(3)(g) | Failing to promptly notify the insured of any additional information necessary for the processing of a claim. |
| 626.9541(1)(i)(3)(h) | Failing to clearly explain the nature of the requested information and the reasons why such information is necessary. |
Filed with the state on January 8, 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 794795. 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 filing says the quiet part in one sentence: the inspection reports behind the denials keep finding causes that match the policy’s exclusion list, word for word. That is the cookie-cutter allegation, made on the public record in a Milton claim out of Clermont, and it names the structural problem with template denials: the conclusion appears to precede the inspection.
Whether that allegation holds in any single claim is what discovery and the claim file decide, which is why the first response to an exclusion-matching denial is a written demand for the complete report behind it: the inspector’s name and license, the photos, the field notes, and every draft. Reports that echo exclusion language without site-specific findings are exactly what Florida’s reasonable-investigation requirement, Fla. Stat. 626.9541(1)(i)3.d, exists to test.
Tower Hill appears three times in this library: this Milton denial, a second Milton roof refusal from Leesburg, and the Ian split denial that a revised letter later repriced by $33,455. The pattern is the point of an archive.
Fla. DFS Civil Remedy Notice, Filing No. 794795 (Cervino v. Tower Hill Insurance Exchange), Clermont, FL · 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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