October 6, 2015 TO: Citizens Property Insurance Corporation 2312 Killearn Center Blvd Tallahassee, Florida 32309-3524 United Services Automobile Association 9800 Fredericksburg Road San Antonio, Texas 78288 Universal Property & Casualty Insurance Company 1110 West Commercial Blvd Fort Lauderdale, Florida 33309 United Property & Casualty Insurance Company 360 Central Avenue, Suite 900 St. Petersburg, Florida 33701 State Farm Florida Insurance Company 7401 Cypress Gardens Blvd Winter Haven, Florida 33888 St. Johns Insurance Company, Inc. 6675 Westwood Blvd, Suite 360 Orlando, Florida 32821 Homeowners Choice Property & Casualty Insurance Company, Inc. 5300 West Cypress Street, Suite 100 Tampa, Florida 33607 Florida Peninsula Insurance Company 903 NW 65th Street, Suite 200 Boca Raton, Florida 33487 RE: Federated National Insurance Company 14050 NW 14th Street, Suite 180 Sunrise, Florida 33323 People’s Trust Insurance Company 18 People’s Trust Way Deerfield Beach, Florida 334416720 Security First Insurance Company d/b/a Security First Florida 140 South Atlantic Avenue Suite 200 Ormond Beach, Florida 32176 Tower Hill Prime Insurance Company 7201 NW 11th Place Gainesville, Florida 32605 Federal Insurance Company 15 Mountain View Road Warren, New Jersey 07059 USAA Casualty Insurance Company 9800 Fredericksburg Road San Antonio, Texas 78288 American Integrity Insurance Company of Florida 5426 Bay Center Drive, Suite 650 Tampa, Florida 33609 Request for Information, Florida Claims Data As Florida’s Insurance Consumer Advocate, I am committed to finding solutions to insurance issues impacting Florida’s families and seek to thoughtfully pursue those issues on behalf of the consumers of Florida. Accordingly, I am requesting your assistance in an effort to conduct a targeted analysis of Florida claims data related to the topic of assignment of benefits and gain a clear understanding of the impact this issue presents to the Florida consumer. Although assignment of benefits is used in a variety of insurance related transactions, the purpose of this request is to aid my office in examining non-weather related water damage claims involving an assignment of benefits to a third party contractor for services. Based on a restricted timeline, I am requesting that you provide this information to my office via email at ICA@myfloridacfo.com no later than 5:00 PM ET, Friday, November 6, 2015. This request for information is a call to each highest-writing property and casualty insurance company in Florida to present an assessment of the company’s aggregate claims experience for the years 2010 to 2015, FLORIDA DEPARTMENT OF FINANCIAL SERVICES Sha`Ron James Insurance Consumer Advocate Office of the Insurance Consumer Advocate 200 East Gaines Street Tallahassee, Florida 32399 Tel. 850-413-2868 Fax 850-487-0453 Email ShaRon.James@myfloridacfo.com AFFIRMATIVE ACTION EQUAL OPPORTUNITY EMPLOYER October 6, 2015 Page 2 of 2 organized in the attached data template for review. For convenience, the template and instructions will be made available for download on the Insurance Consumer Advocate’s website at http://www.myfloridacfo.com/division/ICA/. The survey questions in the template relate specifically to homeowner claims filed in Florida on properties located in Florida. For clarification purposes, this request does not require that each company present individual claims data; rather, the response should represent the company’s aggregate claims data over the time period indicated. In addition to providing a response via the data template, I am requesting that each individual insurer provide to my office a representative copy of the HO3 policy issued to consumers for coverage from the years 2010 to 2015. I have included the attached Certification Statement to be signed by a company officer stating that the information contained in the data template is accurate and truthful. Please provide an executed copy of the Certification Statement with your submission. If additional information not specifically requested in this letter is deemed important by you to the overall submission, please include same in your executed response materials. As industry stakeholders directly impacted by this issue, I strongly encourage your support and cooperation in this effort. Simultaneous with the issuance of this request, I pledge to continue to meet with members of the industry, consumer groups and other associations impacted by the assignment of benefits issue in an effort to work collaboratively to develop a policy position that will benefit Florida consumers. If you have any questions regarding the format or scope of the request, please do not hesitate to contact my office via email at ICA@myfloridacfo.com. Sincerely, C. Sha’Ron James Insurance Consumer Advocate cc: The Honorable Jeff Atwater, Chief Financial Officer Belinda Miller, Chief of Staff, Office of Insurance Regulation David Altmaier, Deputy Insurance Commissioner, Office of Insurance Regulation Sandra Starnes, Director of P&C Product Review, Office of Insurance Regulation