Civil Remedy Notice of Insurer Violations
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Filing Number:     784971
Filing Accepted:  9/30/2024
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Complainant
Last/Business Name *  
POINTE SOUTH OF FT. MYERS BEACH CONDOMINIUM ASSOCIATION’S   First Name  
Street Address * 5000 ESTERO BLVD
City, State Zip * FT. MYERS, FL 33931
Email Address * INSURED@MCDONALDBARNHILL.COM
Complainant Type: * Insured
Insured
Last/Business Name*   POINTE SOUTH OF FT. MYERS BEACH CONDOMINIUM ASSOCIATION’S   First Name  
Policy # * 5817565876 Claim #* 05000001179
Attorney
Attorney is Applicable
Last Name* GONTRUM First Name * RYAN Initial L
Street Address* 505 S. MAGNOLIA AVENUE
City, State Zip* TAMPA , FL 33606
Email Address * TAL@MCDONALDBARNHILL.COM
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   FRONTLINE INSURANCE UNLIMITED COMPANY
NAIC Company Code 10074
 
Name of individual responsible for violation (if any):* MARY HAMILTON, STEPHEN FITTS AND PETRINA MOTEN
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
* Statutory provision(s) which the insurer allegedly violated.
 
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.
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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

***ADDITIONAL STATUTORY PROVISIONS ALLEGED TO HAVE BEEN VIOLATED AS FOLLOWS:*** §624.155 (5) No punitive damages shall be awarded under this section unless the acts giving rise to the violation occur with such frequency as to indicate a general business practice and these acts are: (a) Willful, wanton, and malicious; (b) In reckless disregard for the rights of any insured; or (c) In reckless disregard for the rights of a beneficiary under a life insurance contract; (8) The damages recoverable pursuant to this section shall include those damages which are a reasonably foreseeable result of a specified violation of this section by the authorized insurer and may include an award or judgment in an amount that exceeds the policy limits. §627.70131 Insurer’s duty to acknowledge communications regarding claims; investigation (1)(a) Upon an insurer’s receiving a communication with respect to a claim, the insurer shall, within 14 calendar days, review and acknowledge receipt of such communication unless payment is made within that period of time or unless the failure to acknowledge is caused by factors beyond the control of the insurer which reasonably prevent such acknowledgement. If the acknowledgement is not in writing, a notification indicating acknowledgement shall be made in the insurer’s claim file and dated. A communication made to or by an agent of an insurer with respect to a claim shall constitute communication to or by the insurer. (b) As used in this subsection, the term “agent” means any person to whom an insurer has granted authority or responsibility to receive or make such communications with respect to claims on behalf of the insurer. (c) This subsection shall not apply to claimants represented by counsel beyond those communications necessary to provide forms and instructions. (2) Such acknowledgement shall be responsive to the communication. If the communication constitutes a notification of a claim, unless the acknowledgement reasonably advises the claimant that the claim appears not to be covered by the insurer, the acknowledgement shall provide necessary claim forms, and instructions, including an appropriate telephone number. (3) Unless otherwise provided by the policy of insurance or by law, within 10 working days after an insurer receives proof of loss statements, the insurer shall begin such investigation as is reasonably necessary unless the failure to begin such investigation is caused by factors beyond the control of the insurer which reasonably prevent the commencement of such investigation. (4) For purposes of this section, the term “insurer” means any residential property insurer. (5) Within 90 days after an insurer receives notice of a property insurance claim from a policyholder, the insurer shall pay or deny such claim unless the failure to pay such claim is caused by factors beyond the control of the insurer which reasonably prevent such payment. Failure to comply with this subsection constitutes a violation of this code. ***Specific policy language that is relevant to the violation*** Frontline Insurance Unlimited Company (Frontline) failed to adequately adjust and pay the claim covered under the subject insurance policy. Specifically, but not limited to, Frontline failed to properly apply the Loss Settlement and Loss Payment provisions of the policy. In addition to the policy sections specifically cited herein, any endorsements or changes to said sections are relevant to the Insured’s claim for civil remedy. There may be additional policy language relevant to this violation that may be discovered.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Pointe South of Ft. Myers Beach Condominium Association’s (Pointe South) claim results from wind and water damage from Hurricane Ian which occurred on or about September 28, 2022, to the property located at 5000 Estero Blvd. Ft. Myers, FL 33931. This property was insured under policy number 5817565876. The wind from the hurricane ripped off large sections of roof from the main six story condominium building, also ripping off sections of balcony, damaging windows and doors, and otherwise battering the exterior of the property. In turn, this damage resulted in rain pouring down throughout the building. The claim was reported to Frontline Insurance Unlimited Company, D.B.A. Frontline Insurance (Frontline). Frontline assigned the claim number 05000001179. After its initial inspection, Frontline issued payments of only $688,920.51 for the main building, which failed to include any interior damage, and $61,445.16 for building 2. Frontline issued the initial payments in November of 2022, but did not issue any supplemental payments until July of 2023. Following the loss, Frontline also sent HAAG Engineering to evaluate the damage. HAAG Engineering is well known in the industry for creating biased reports which cater to insurers by using exclusionary policy language. Insurers then use these reports to deny or underpay claims. This instance was no different, and HAAG concluded that none of the windows required complete replacement, instead proposing they be cleaned, and some reglazed with hardware repairs. HAAG also concluded that there was no wind related damage to the elevator, despite the storm surge only affecting the bottom levels of the elevator. Months after its initial payment, Frontline desk adjuster Mary Hamilton sent a supplemental payment letter attached to a new estimate prepared by Stephen Fitts and approved by Petrina Moten. This new estimate made few improvements to the exterior scope of the first estimate, with the majority of the additions being for the interior, where Mr. Fitts included mostly just drywall and insulation repairs. This estimate also reflected simply cleaning most of the windows rather than replacing them. Pursuant to this estimate, Frontline issued supplemental payments of just $44,965.79 for the main building, $638.45 for building 2 and $120,950 for mitigation, which supposedly covered all interior wind damages. Pointe South retained Serv Pro to conduct water mitigation services which totaled $963,932.40. Frontline sent Keystone Experts + Engineers (Keystone) to evaluate the mitigation services. Keystone, for its part, evaluated Serv Pro’s documentation and concluded that payment for their services should be $952,446.23, a difference of $11,486.17. Accordingly, Frontline failed to pay the full amount invoiced by Serv Pro. Pointe South hired MAF, Inc. d/b/a Ironclaim (“Ironclaim”) to represent its interests in the claim. Ironclaim inspected the property and assisted with the preparation of a proof of loss totaling $2,827,590.25. By this time, a different desk adjuster, Kristin Fitch had been assigned by Frontline. Ms. Fitch advised that Frontline disagreed with the proof of loss, but also indicated that she would have to review Ironclaim’s estimate to identify the dispute, demonstrating that Frontline disputed the proof of loss without even knowing what was included. After requesting a reinspection and coordinating the date and time, Ms. Fitch indicated that she did not have approval for reinspection after all, and Frontline never wound up reinspecting. After this, Ms. Fitch was taken off the claim and a new desk adjuster, Kim Gateb was assigned. Ironclaim reached out to Ms. Gateb about a reinspection, but after agreeing to look over the file, Ms. Gateb never responded. Several weeks later, yet another adjuster, James Carpenter, was assigned to the claim. Mr. Carpenter issued correspondence asserting that the proof of loss was improper, but included no details about what was in dispute, and incorrectly referred to the property as a five-story building. After Ironclaim followed up with Mr. Carpenter several times to no avail, yet another desk adjuster was assigned, Carol Crump. Ms. Crump indicated they would send Mike Rega to provide a supplemental evaluation. Ironclaim and Mr. Rega began working together to discuss the claim and damage, and Mr. Rega indicated that his report would soon be completed, but that he needed guidance from Ms. Crump. With Mr. Rega’s report seemingly on the way, Ms. Crump then reassigned the claim to a different consultant, wasting all of the time and effort spent working on the claim with Mr. Rega. Instead, Frontline had RMC Group begin reevaluating the loss. Even though Ironclaim and RMC group had concurred that the supplemental estimate would total more than $1 million, the RMC estimate produced by Frontline included only 11-line items and totaled just $761,519.07. This estimate did not include the full scope of the loss, addressing just the exterior and the elevator. The RMC estimate yielded a supplemental payment of only $265,663.10, the last payment issued by Frontline on this claim. It did not include any interest, and did not address any of the deficiencies of the interior damage estimate besides the elevator. Unfortunately, there is no proof the carrier ever actually considered the information sent by Ironclaim or did anything further to adjust the loss. In fact, it is evident that Frontline has “pulled the rug out” on the insured, Ironclaim, and even its own consultants on this claim on multiple occasions whether through malice or recklessness. In Florida, the work of adjusting insurance claims engages the public trust. Frontline has breached this duty in the adjustment of this loss by refusing to provide proper indemnity, failing to make payments it is aware are owed, unnecessarily delaying resolution of the claim, and failing to take into consideration documentation provided to them which would support further compensation. Frontline has failed to create and implement adequate guidelines for proper investigation of claims handling and for training and supervision of employees and representatives which have resulted in some of the statutory violations set forth above. Frontline charged Pointe South a substantial premium for these coverages but has refused to tender proper payment when under all circumstances it could have and should have done so had it acted fairly and honestly. Additionally, it appears this is done companywide. The Insured has been forced to consider legal counsel to protect his interests. Therefore, to cure the defects outlined in this Civil Remedy Notice, Frontline must: 1. Immediately tender all insurance monies due to the Insureds for the loss; 2. Act fairly and honestly towards the Insureds and with due regard for their interests in attempting to settle the claim; 3. Pay statutory interest on the amount of unpaid contractual damages from the date the claim was reported; 4. Cease and desist all present and future bad faith actions with regard to the Insureds’ claim; Failure to cure all defects during the 60-day safe harbor period may result in additional extra-contractual damages.
Comments
User Id Date Added Comment
jwank@kelleykronenberg.com 11-26-2024 Please accept this correspondence as Frontline Insurance Unlimited’s (“Frontline”) response to Civil Remedy Notice (“CRN”) Filing Number 784971 filed by you, on behalf of Pointe South of Ft. Myers Beach Condominium Association’s (“Insured”), dated September 30, 2024. At the outset, Frontline denies that any of its actions taken with regard to the Insureds’ claim has resulted in a violation of Florida’s bad faith laws as alleged in the CRN. Rather, Frontline acted at all times in good faith in its investigation and handling of the above-claim and with regards to the best interest of our Insureds. While Frontline welcomes the opportunity to respond to this CRN and specifically denies each and every allegation contained in the CRN referenced above, Frontline requests the CRN be rejected as it fails to comply with several of the requirements of the Civil Remedy Notice of Insurer Violation document provisions as set forth in Florida Statutes § 624.155 and Florida case law. The CRN omits required information and should be rejected. In large part, while the CRN does contain alleged specific facts, the cited provisions appear to be nothing more than boilerplate and conclusory language that have no application to the governing facts or law of this claim. The presently drafted CRN concludes bad faith while omitting essential and material facts in an effort to incorrectly support a narrative. THE CRN ALLEGATIONS The CRN asserts the following reasons for the notice: • Claim Denial • Claim Delay • Unsatisfactory Settlement Offer • Unfair Trade Practice In the CRN, the Complainants allege that Frontline violated the following statutes and applicable language (as taken from the Notice of Insurer Violations): • § 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 and his interests. Frontline strictly denies any violation of any section of Florida Statute § 624.155(1) (b) (1). • § 626.9541(1)(i)(3)(a): Failing to adopt and implement standards for the proper investigation of claims. Frontline strictly denies any violation of Florida Statute § 626.9541(1)(i)(3)(a). • § 626.9541(1)(i)(3)(b): Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue. Frontline strictly denies any violation of Florida Statute § 626.9541(1)(i)(3)(b). • § 626.9541(1)(i)(3)(c): Failing to acknowledge and act promptly upon communications with respect to claims. Frontline strictly denies any violation of Florida Statute § 626.9541(1)(i)(3)(c). As cited under “Additional Statutory Provisions Alleged to Have Been Violated as Follows: • § 624.155 (5): Frontline strictly denies any violation of Florida Statute § 624.155 (5)). • § 627.70131 Frontline strictly denies any violation of Florida Statute §627.70131 DISCUSSION Notwithstanding the numerous alleged references to violations of Fla. Stat. §§ 626.155, 626.9541 and 626.70131 and their progeny, nothing in Complainants’ petition states the factual circumstances giving rise to any purported violation. Rather, Complainants’ petition merely recites a dispute over a properly investigated and covered claim. Frontline believes the CRN should be rejected as insufficient because Complainants have failed to comply with Fla. Stat. §624.155(3)(b), which requires that a Civil Remedy Notice “state with specificity” the statutory provision allegedly violated, the facts and circumstances giving rise to the violation and the specific policy language relevant to any violation. Complainants’ provide an exhaustive list of statutory provisions supposedly violated, yet they fail to provide any specific factual or circumstantial support of the allegations. In addition, the Civil Remedy Notice does not contain specific information, as required strictly by statute, and is therefore insufficient due specifically to an incorrect address for the Insured by having the incorrect city, and an incorrect name for the Insured by referencing a plural of the Association despite only one Association being Insured under this Policy. By including both an incorrect address and name for the Insured, the CRN should be rejected as it does not comply with Florida Statute or caselaw. The CRN also includes an incorrect name of the Insurer. Complainants also fail to properly reference specific policy language relevant to the alleged violation, which also renders the notice deficient. Instead, Complainants state “Frontline failed to adequately adjust and pay the claim covered under the subject insurance policy. Specifically, but not limited to, Frontline failed to properly apply the loss settlement and loss payment provisions of the policy.” The particular reference to policy sections headings is not only vague, but does not include any specific language that alleges what the carrier violated. Accordingly, the notice does not comply with Florida law as it fails to fulfill the legislative purpose of giving the insurer notice of the contractual amounts due or provide a bonafide opportunity to cure the alleged wrongdoing. In addition, the CRN fails to provide a specific or accurate cure of what the Insured is seeking, especially due to the Insured submitting a supplemental claim for damages after filing of the CRN, as outlined below. Without knowing the policy provision Complainants believe Frontline violated, including relevant facts in support of same, Frontline cannot meaningfully evaluate any potential cure. Nonetheless, setting forth the factual background, on October 5, 2022, the Insured initially reported a claim as it relates to Hurricane Ian on September 28, 2022. The claim was promptly acknowledged and an initial inspection by an adjuster on behalf of Frontline was scheduled to take place on October 19, 2022. At the inspection, there were damages found to both the roofs and interior of the building that was believed to be related to the subject claim. An initial estimate was drafted by the Adjuster for an RCV of damages of $907,489.35 for the main building and $73,090.49 for the management building. As a result, on November 29, 2022, Frontline issued a coverage letter enclosing an initial payment of $750,365.67. Of note, ServPro, a mitigation company, performed mitigation on behalf of the Insured for both the flood and wind portions of the loss. ServPro generated an estimate totaling $1,243,971.14 for their mitigation performed to this property. After a review of the estimate by a building consultant on behalf of Frontline, the carrier and ServPro agreed on an amount of $963,923.40 on October 2, 2023, which has been paid in full to the Insured. Shortly after the initial coverage determination, a new adjuster on behalf of Frontline was assigned to the claim as the Insured was pursuing a supplemental claim of additional damages. As part of the additional investigation, Frontline retained Brandon Bealmear, P.E., of HAAG to inspect the property. These inspections occurred on December 6, 2022, March 22, 2023, and March 23, 2023. Mr. Bealmear provided a report which was submitted to the Insured’s representative. Ultimately, Mr. Bealmear determined the roofing systems needed to be replaced. In addition, the Insured was seeking replacement of the elevator systems and therefore Frontline retained Elevators CSI who inspected the property on May 5, 2023, on behalf of Frontline, who determined the damages to the elevator system were due to flood, which is not covered under the Policy. After multiple communications in June and July of 2023 with the Insured and their representatives, a supplemental payment letter was sent on July 17, 2023, providing an additional payment of $165,916.12 for Building 1 and $4,678.07 for Building 2 based on an additional estimate of damages generated. The corresponding letter outlined the coverage extended as well as excluded. An additional payment as made to the Insured in October of 2023 for $831,495.50 based on an agreement with ServPro as referenced above. On October 23, 2023, a letter of representation was received from Shaun Greene of Iron Claims Adjusting. A Reservation of Rights and Request for Information was sent on November 16, 2023 for documents related to the claim and Association. It is important to note that several Requests for Information were sent to the Insured throughout the investigation of this claim including October 3, 2022, July 17, 2023, October 16, 2023, March 12, 2024 and July 31, 2024. In December of 2023, there were correspondence indicating the Insured’s estimate of damages was pending. On January 16, 2024, the Insured’s Public Adjuster submitted an estimate and Sworn Proof of Loss. The estimate from Iron Claims totaled $2,827,590.25. Frontline responded to the Sworn Proof of Loss on January 24, 2024. On May 13, 2024, the Public Adjuster submitted a revised Sworn Proof of Loss for $2,888,670.44, which was responded to. After receipt of such, Frontline requested an additional inspection by Building Consultant Nelson Conde of RMC Group, LLC. As a result, a supplemental payment was issued to the Insured on August 30, 2024, for $265,663.10 for Location 1 and no additional payment for Location 2. The estimate itself was provided to the Insured and their representative with the coverage letter provided. Plaintiff’s allegation of there being another supplemental estimate is not supported and payment was correctly issued based on the Net Claim Total of $1,951,995.63 for Location 1 and $73,523.51 for Location 2. On September 30, 2024, the Insured submitted the subject Civil Remedy Notice. On October 10, 2024, ten days after the Civil Remedy Notice was filed and over two years after the loss, the Insured submitted a supplemental claim for damages through their representative including a new estimate of damages from the Public Adjuster totaling $3,526,813.12 to include additional units, replacement of the windows and doors at the property and various pricing increases. In response, On October 17, 2024, Frontline submitted an additional Reservation of Rights and Request for Information as it relates to the supplemental claim for damages. The correspondence included a timeline of events and specific information as to the documents requested and reason for such. In addition, Frontline requested a re-inspection by a fenestration expert as it relates to the supplemental claim for windows and doors. Due to not receiving a response for the Association documents, repair records and flood claim information, Frontline sent two additional Reservation of Rights and Request for Information. As of the date of this filing, a re-inspection was coordinated, after multiple attempts, for November 25 and 26, 2024. However, the Insured has still yet to comply with the documentation request pursuant to the Policy and the supplemental claim remains ongoing. The CRN alleges Frontline has breached their duty in adjusting claims by rejecting appropriately produced documentation, failing to make payments, delaying resolution and refusing to properly indemnify the insureds. These broad and generalized allegations are wholly improper and simply unfounded. As it relates to the initial adjustment of the claim, Frontline considered any and all documentation submitted by the Insureds in its evaluation of the claim, but disagreed with the same based on its inspection and findings. Finally, Frontline did not “refuse” to properly indemnify the Insureds as the CRN would suggest, but rather extended coverage for the covered items. As to the supplemental claim submitting after the filing of this CRN, the investigation remains ongoing due to the Insured’s own actions. Frontline further rejects the notion that it somehow engaged in any sort of failure to implement proper procedures for adjusting losses or properly train and supervise its employees and representatives. Rather, Frontline has appropriately and professionally handled this matter at all times. Any claims to the contrary are meritless and without any supporting factual basis. Finally, the Notice fails with respect to its requirement to specify how Frontline may “cure” the alleged violations. The purpose of a Civil Remedy Notice is to provide a carrier with one last opportunity to “cure” the alleged violations. In this instance, there is no indication at all what action Frontline needs to take to cure the alleged violations. Assuming, arguendo, that the real “cure,” sought by the insureds, is payment of all insurance proceeds demanded by the insureds, notwithstanding Frontline’s right to investigate and adjust the loss. The method for curing the violations alleged in a civil remedy notice are not determined by the Insureds. Section 624.155 does not impose on an insurer the obligation to pay whatever the insured demands. Section 624.155(2)(d) would have no effect or purpose under such an interpretation. In Talat Enterprises, Inc. v. Aetna Casualty and Surety Co., 753 So.2d 1278 (Fla. 2000), the Florida Supreme Court accepted and quoted the reasoning of the court below in its opinion which stated in relevant part, as follows: Section 624.155 does not impose on an insurer the obligation to pay whatever the insured demands. . . . Section 624.155(2)(d) would have no effect or purpose under such an interpretation. The law does not support such an expansive and illogical reading of Fla. Stat. Ann. §624.155(2)(d). Talat, 753 So2d at 1282 citing Talat Enterprises Inc. v. Aetna Cas. & Sur. Co., 952 F.Supp. 773, 777-778 (M.D. Fla. 1996). Thus, the CRN is purposefully drafted in a manner which does not allow Frontline proper notice of the allegations or any meaningful opportunity to respond and/or evaluate the claims being asserted. Based upon the foregoing, the CRN is insufficient on its face and should be rejected. Talat Enterprises Inc. vs. Aetna Cas. & Sur. Co., 753 So. 2d 1278 (Fla. 2000); Lane v. Westfield Ins. Company, 862 So. 2d 744 (Fla. 5th DCA 2003). This is further supported by the Insured submitting a supplemental claim during the cure period and delay on allowing an investigation into such. Accordingly, Frontline denies the alleged violations in their entirety and states that it has acted properly and reasonably in its investigation of this claim. Moreover, Frontline’s position is that the Notice is statutorily deficient in that it cites various statutory violations and does not provide the requisite specificity as to how they were violated. In large part, the cited provisions appear to be nothing more than boilerplate and conclusory language that have no application to the governing facts or law of this claim. The CRN also contains incorrect information as stated above. The CRN requires the Complainant to “reference to specific policy language that is relevant to the violations, if any.” The CRN does not contain any specific policy language in which Frontline allegedly failed to comply. Rather, and as indicated, the Insureds list “Loss Settlement and Loss Payment” with no description of any language violated. Other than this blanket statement, there are no facts or circumstances provided in which this section was violated or misinterpreted. It is this failure to identify any specific policy provision allegedly relevant to each alleged statutory violations that prevents Frontline from addressing any issues regarding the policy and is further reason for the CRN to be rejected. The CRN should be rejected as it does not cite specific policy language relevant to the alleged violations, and more importantly, it includes conflicting violations contrary to the facts of the claim. Without referencing the specific policy language or providing further details, Frontline cannot address the alleged violations or properly respond. Additionally, the CRN is insufficient on its face and should be rejected since, contrary to the requirements of Section §624.155, the CRN does not specifically describe the facts or circumstances giving rise to each specific violation alleged against Frontline. Instead, the CRN makes broad and general allegations. As seen from the facts of this claim, these allegations are baseless and wholly without merit. Thus, the CRN is purposefully drafted in a manner which does not allow Frontline proper notice of the allegations or any meaningful opportunity to respond and/or evaluate the claims being asserted. Based upon the foregoing, the CRN is insufficient on its face and should be rejected. Talat Enterprises Inc. vs. Aetna Cas. & Sur. Co., 753 So. 2d 1278 (Fla. 2000); Lane v. Westfield Ins. Company, 862 So. 2d 744 (Fla. 5th DCA 2003). In response to each statutory violation alleged, Frontline states: Frontline conducted a complete, thorough, and timely investigation of the loss, utilizing an independent adjuster, engineer, Elevator consultant and building consultant to inspect the property and determine the scope of damages. Based on the inspections and overall investigation, the initial claim was covered and payment issued. The investigation into the supplemental claim remains ongoing. Therefore, no violations of § 624.155(1)(b)(1) have occurred. Frontline has adopted all proper and best practices and standard operating procedures for claims-handling with regard to § 626.9541(1)(i)(3)(a). Frontline conducted a complete, thorough, and timely investigation of the loss, utilizing an independent adjuster, engineer, Elevator consultant and building consultant to inspect the property and determine the scope of damages. Further, Frontline promptly arranged for an inspection after the loss was first reported to Frontline. Accordingly, Frontline denies any violations of § 626.9541(1)(i)(3)(a). There is no evidence or any allegations to suggest a violation of § 626.9541(1)(i)(3)(b) in the slightest. At no point has Frontline misrepresented pertinent facts or insurance policy provisions relating to coverages at issue. To include this section as a violation is evidence that the Complainants used boilerplate and form language. Accordingly, Frontline denies any violations of § 626.9541(1)(i)(3)(b). Frontline acknowledged and acted promptly with the Insureds and their representatives through the claims process. Therefore, Frontline denies violating § 626.9541(1)(i)(3)(c). Frontline further denies violating §624.155(5) and §627.70131. Frontline’s actions in handling the Insureds’ claim were prompt, thorough, conducted in accordance with the insurance policy and Florida law, and most importantly, in good faith. Furthermore, Frontline complied with all obligations under the insurance policy and the Florida Statutes. Frontline promptly investigated the loss and timely made its coverage decision based on its findings and as information was received. Therefore, Frontline denies each and every allegation contained in the Notice. Frontline requests that the CRN be rejected for its failure to comply with Florida Statute §624.155, §626.9541 and Florida case law. Regardless of the rejection, as demonstrated above, Frontline has, at all times, acted in good faith, with due diligence, and in accordance with the terms of its insurance policy and Florida Statutes with respect to the requests made by its Insureds and their representatives. Frontline respectfully disagrees with all of the assertions made and expressly denies all allegations contained in the CRN. We trust this response adequately addresses the allegations of violation alleged in the CRN.
Acknowledgement
* The submitter hereby states that this notice is given in order to perfect the rights of the person(s) damaged to pursue civil remedies authorized by Section 624.155, Florida Statutes.

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DFS-10-363
Rev. 10/14/2008