Civil Remedy Notice of Insurer Violations
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Filing Number:     795641
Filing Accepted:  12/6/2024
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Complainant
Last/Business Name *  
CUTTLER, TRUSTEE   First Name   MICHAEL
Street Address * 822 SOUTH TAMIAMI TRAIL
City, State Zip * OSPREY, FL 34229
Email Address * DAVIDMHELLER@TAMPABAY.RR.COM
Complainant Type: * Insured
Insured
Last/Business Name*   CUTTLER, TRUSTEE   First Name   MICHAEL
Policy # * 1005114885 Claim #* 052312
Attorney
Attorney is Applicable
Last Name* PETTINATO First Name * DAVID Initial J
Street Address* 1000 W. CASS STREET
City, State Zip* TAMPA , FLORIDA 33606
Email Address * DPETTINATO@OLDERLUNDYLAW.COM, DJP-PARALEGALS@OLDER
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):* TONI CRAIG-TATE, AND ALL OTHER ADJUSTERS, SUPERVISORS, MANAGEMENT AND INDIVIDUALS ASSOCIATED WITH OR RETAINED BY FRONTLINE INSURANCE UNLIMITED COMPANY INVOLVED IN THE CLAIM.
Type of Insurance * Commercial Property & Casualty   
Reason for Notice *
Claim Delay
Unsatisfactory Settlement Offer
Unfair Trade Practice
Other : Failure to properly investigate claim and with due regard to Insured’s interest
Other : Failure to acknowledge and act promptly to communications regarding claim
* 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.
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)(c) Failing to acknowledge and act promptly upon communications with respect to claims.
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)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5).
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

ADD’L STATUTES VIOLATED §627.70131(1)(a) §627.70131(2) §627.70131(3)(a) §627.70131(3)(d) §627.70131(7)(a) POLICY LANGUAGE The Insured may not be in possession of a complete copy the applicable policy of insurance, however, the specific policy language relevant to the violations outlined below is contained within Frontline Insurance Unlimited Company’s Commercial policy, Policy No. 1005114885, issued to the Insured including, but is not limited to, the following: Coverage A- Building Coverage provisions (CP 00 10 06 07) Coverage B- Business Personal Property provisions (CP 00 10 06 07) Coverage C- Personal Property Of Others provisions (CP 00 10 06 07) Additional Coverages provisions (CP 00 10 06 07 / FIU REM 12 23) - Debris Removal - Reasonable Emergency Measures - Preservation of Property - Increased Cost of Construction - Limited “Fungus”, Wet Rot, Dry Rot, and Bacteria Cause of Loss – Windstorm or Hail Percentage Deductible (FIU W 08 14) Commercial Property Conditions coverage endorsement (CP 00 90 07 88) Common Policy Conditions coverage endorsement (IL 00 17 11 98) Additional Coverage – Reasonable Emergency Measures endorsement (FIU REM 12 23) Florida Changes-Windstorm or Hail endorsement (FIUW FLCH 01 15) The Declarations Page (FIU-FL-DEC (08/20)) Loss Payment or Loss Settlement provisions (CP 00 10 06 07) Duties in Event of Loss Policy provisions (CP 00 10 06 07) The insurance policy's definition sections (CP 00 10 06 07) The insurance policy's exclusion of coverage provisions (CP 00 10 06 07) Please advise if there are other applicable policy provisions that are not cited above but would provide coverage to the Insured for the June 29, 2024 to June 29, 2025, Hurricane Helene and/or hurricane force winds loss.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

In Florida, the work of adjusting insurance claims engages the Public Trust. FRONTLINE INSURANCE UNLIMITED COMPANY (“FRONTLINE”) has breached this duty by its failure or refusal to acknowledge its Insured’s claim of loss. FRONTLINE has failed to create and implement adequate guidelines for proper investigation to evaluate claims handling and for training and supervision of employees resulting in statutory violations as set forth above. FRONTLINE has failed and/or refused to thoroughly, accurately, and completely investigate and evaluate the Insured’s insurance claim for damages. To date, notwithstanding the Insured’s pleas, FRONTLINE has continued to refuse to acknowledge its obligation to acknowledge and pay the full amount of its Insured’s claim. This complaint is made on behalf of the Insured, Michael Cuttler, Trustee (“MR. CUTTLER”). Further, this complaint is a statement that notice is hereby given in order to perfect the right to pursue the civil remedy authorized and pursuant to Florida Statute §624.155. In consideration of the premium paid to it by MR. CUTTLER, FRONTLINE issued an Commercial policy, Policy No. 1005114885 (hereinafter referred to as “the Policy”), to MR. CUTTLER wherein the insurance policy provided coverage for all losses, including Hurricane Helene and/or hurricane force winds, except those losses which were expressly excluded. The policy was in full force and effect at the time the damage occurred as a result of Hurricane Helene and/or hurricane force winds, and the ensuing damages as a direct result thereof, to the insured premises located at 822 South Tamiami Trail, Osprey, FL 34229, on or about June 29, 2024 to June 29, 2025. MR. CUTTLER’S insured property sustained damages to the interior and exterior of the property. On the exterior, MR. CUTTLER’S insured property sustained damages, including but not limited to, the roofing system, property exterior paint, and gutters. On the interior, MR. CUTTLER’S insured property sustained damages, including but not limited to, the drywall, paint, ceiling, crown molding, flooring including carpet, baseboards, etc. in the rooms, breakroom, bathroom, bath & storage area, front section, rear section, and side room. Following the claim, MR. CUTTLER had a tarp installed on the roof of his insured property, in an effort to prevent additional damage. MR. CUTTLER timely notified FRONTLINE of the damages and opened a claim pursuant to the terms and conditions of the Policy. In response, FRONTLINE assigned the claim to its representative to adjust and investigate the loss, as well as a field adjuster to inspect the damages. FRONTLINE’S representative visited the insured property and performed a cursory and inadequate investigation of the damaged property. To date, MR. CUTTLER has not received any claims determination letter from FRONTLINE, advising him of the decision made regarding his claim with his carrier. Concerned that FRONTLINE had no intention to fairly investigate and adjust his claim, MR. CUTTLER retained the services of an insurance claim professional, David M. Heller, to assist in submitting his claim to FRONTLINE which would adequately and fairly detail all the damages sustained as a result of the loss. MR. CUTTLER’S damage estimate from Paul Marchese, totaled $715,618.66 RCV in Dwelling damages (Coverage – A). This estimate was inclusive of the full extent of damages sustained to MR. CUTTLER’S insured property, as detailed above. On or about October 21, 2024, MR. CUTTLER submitted to FRONTLINE an executed Sworn Statement in Proof of Loss for $726,802.86 in Building damages (Coverage – A). During late November 2024, MR. CUTTLER received approximately $180,000 from FRONTLINE for Building damages (Coverage - A) and approximately $8,000 also from FRONTLINE, for the roof tarping invoice. With regards to MR. CUTTLER’S insurance claim, FRONTLINE’S claim determination process has misrepresented the large extent of damages sustained to the property, and has delayed MR. CUTTLER’S ability to restore his insured property to pre-loss condition. To date, MR. CUTTLER has not received any claims determination letter from FRONTLINE, advising him of the decision made regarding his claim with his carrier. To date, MR. CUTTLER has not received any reinspection requests from FRONTLINE. To date, MR. CUTTLER has not received any settlement offers from FRONTLINE. FRONTLINE has admitted that MR. CUTTLER sustained covered damages as a result of the Hurricane Helene and/or hurricane force winds loss that occurred on or about June 29, 2024 to June 29, 2025 but has denied tendering all owed insurance benefits to MR. CUTTLER. Pursuant to Florida Statute §626.9541(1)(i)(4), FRONTLINE is required to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 90 days after FRONTLINE received notice of the residential property insurance claim, determine the amounts of partial or full benefits, and agree to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5). As FRONTLINE has failed to do so, FRONTLINE has wrongfully denied coverage. Since the beginning of the claim, FRONTLINE has engaged in a pattern of delay, denial, and reckless disregard for MR. CUTTLER’S rights. The actions of FRONTLINE listed herein have been continuing in nature and given the totality of the circumstances, which includes FRONTLINE’S adjustment, actions and/or omissions post the filing of this CRN. MR. CUTTLER contends that given the past experience in this matter with FRONTLINE, it is reasonably foreseeable that FRONTLINE’S current actions will extend to its entire conduct in the handing of his claim, including the acts or omissions of FRONTLINE and/or its representatives, until the final resolution of his claim. As such, MR. CUTTLER contends adequate notice has been given should FRONTLINE’S actions and violations listed herein continue after the expiration of this notice. FRONTLINE has failed and/or refused to settle the claim when it could and should have done so had it acted fairly and honestly towards MR. CUTTLER, and has failed to take into account the information and evidence provided that contradict its decisions. Even upon receipt of additional and supporting evidence to the contrary, FRONTLINE has continued to stand by its claim denials. As such, MR. CUTTLER does not anticipate FRONTLINE will rescind its denial of his claim. FRONTLINE’S conduct has been reckless and unfair to MR. CUTTLER, and has caused and continues to cause additional damages throughout the property. This is evidenced by the delay in paying the claim and the failure of FRONTLINE to evaluate the claim in total. To date, FRONTLINE has failed and/or refused to provide MR. CUTTLER with all the insurance benefits due and owing and has not tendered the full amount needed to repair the Property despite knowing that MR. CUTTLER has sustained covered damages to his insured property. As FRONTLINE must admit, it is implied within every insurance policy a duty of good faith and fair dealings. In an insurance contract, each party is prevented from interfering with the other’s right to benefit from the contract. The obligations of good faith and fair dealings encompass qualities of decency and humanity inherent in its responsibilities as a fiduciary. FRONTLINE is bound to conduct itself with the utmost good faith for the benefit of MR. CUTTLER. However, FRONTLINE has failed to comply with the obligations in connection with this claim and has never looked at the claim or the contract for insurance with good faith and fair dealing. Instead, FRONTLINE has looked for ways not to pay the claim in full, or at all, and these actions have been to the detriment of MR. CUTTLER. The adjusters assigned to this claim have a duty to adjust and treat all claims equally. Since the beginning of this claim the representatives on behalf of FRONTLINE have approached this investigation in a manner prejudicial to MR. CUTTLER. FRONTLINE is using either untrained or improperly trained adjusters in connection with this claim. FRONTLINE should have been adjusting the loss with MR. CUTTLER but instead, it was looking for ways not to pay the claim at all, or pay the claim in full. If FRONTLINE handles all the claims in the manner in which MR. CUTTLER’S claim was adjusted, then it is improperly handling all claims. FRONTLINE has refused and/or failed to comply with The Policy’s cooperation and/or “Loss Payment” provision. Under The Policy, FRONTLINE was to timely tender undisputed insurance benefits to MR. CUTTLER. FRONTLINE has failed and/or refused to timely tender owed insurance benefits, undisputed or otherwise. This is a breach of The Policy. FRONTLINE has refused and/or failed to cooperate and/or “Adjust the Loss” by cooperating with MR. CUTTLER during the claims adjustment process in compliance with The Policy’s “Loss Payment” provision. This is a breach of The Policy. The concept of insurance is that insurance is the insurer’s granting of timely and prompt indemnity or security against a contingent loss. Florida Statute §624.02 defines “insurance” as a contract whereby one undertakes to indemnify another or pay or allow specified amount or a determinable benefit upon determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that MR. CUTTLER may mitigate his damages and to put him back into the position he was in prior to the loss as quickly as possible. FRONTLINE has breached this duty. FRONTLINE has refused and/or failed to tender all insurance proceeds to MR. CUTTLER upon demand. FRONTLINE’S refusal and/or failure to settle the insurance claim when under all circumstances it could have and should have done so had it acted fairly and honestly towards MR. CUTTLER is wrongful conduct. Furthermore, MR. CUTTLER contends that FRONTLINE’S adjusters and/or representatives financially benefit by such wrongful conduct. It is clear that FRONTLINE’S adjusters have also failed to adhere to insurance industry rules and guidelines when adjusting a first party claim. It is also evident that FRONTLINE violated the Florida unfair claims practices, the adjuster’s ethical code of conduct, and acted irresponsibly in the handling of its insured’s claims. In this case, MR. CUTTLER paid a hefty premium for a service, the service is called claims adjusting (I encourage you to read the book titled, “The Claims Environment” written by James J. Markham, Kevin M. Quinley, and Layne S. Thompson-this book is taught in every first year AIC course). The claim professional must dispense his or her knowledge and skill for the benefit of society. The general public expects claims representatives to pay all legitimate claims promptly and fairly. The claim professional must harness all of his or her knowledge and expertise to accomplish the objectives of the claim function. He or she must also adhere to the highest degree of ethical conduct. In addition to interacting with other insurance personnel and service providers in a professional manner, the claims professional must deal with public’s and regulator’s expectations. Insurance Companies provide such a vital and necessary service to society that the selling and servicing of insurance is imbued with a public trust. James J. Markham, Kevin M. Quinley, Layne S. Thompson, “The Claims Environment”, Insurance Institute of America, 1st ed., 1993. Accordingly, FRONTLINE has a contractual and statutory obligation to investigate all possible bases which might support MR. CUTTLER’S claim and cannot deny a claim without thoroughly investigating the foundation for its denial or basis for withholding insurance benefits. FRONTLINE violated its obligations here. - FRONTLINE has a contractual and statutory obligation to make a perfunctory investigation, not ignoring evidence that would support MR. CUTTLER’S claim. FRONTLINE violated its obligations here. - FRONTLINE has a contractual and statutory obligation not to look the other way when confronted with facts revealing the possibility of coverage and resisting reasonable interpretations of its policy. FRONTLINE violated its obligations here. - FRONTLINE has a contractual and statutory obligation not to deny the claim based on standards known to be impermissible or on an interpretation contrary to established law. FRONTLINE violated its obligations here. These actions and violations were either done intentionally or as the result of FRONTLINE’S failure to adopt and implement the proper standards of the investigation and adjustment of claims. Overall, FRONTLINE’S investigation of the claim was inadequate and contrary to its obligations under the insurance policy and Florida law. MR. CUTTLER has done everything legally requested by FRONTLINE to date. To cure the violations set forth in this Civil Remedy Notice, FRONTLINE must now agree to acknowledge its duties and obligations under the law in adjusting its insured’s claim, and tender rightfully owed insurance benefits to return MR. CUTTLER to his pre-loss condition. Further, to cure the violations set forth in this Civil Remedy Notice, MR. CUTTLER hereby requests that FRONTLINE tender at this time, or prior to the expiration of the statutory cure period, the amount of MR. CUTTLER’S damage estimate and demand which accurately reflects the true nature and extent of MR. CUTTLER’S damages. Therefore, FRONTLINE should tender $715,618.66 (less any prior payments, depreciation, excess policy limits, and/or deductible) in ,insurance benefits at this time. Although MR. CUTTLER has made a demand for payment in the amount of $715,618.66 (less any prior payments, depreciation, excess policy limits, and/or deductible) and has provided FRONTLINE with all the necessary documentation in support thereof, he is still willing to consider and to potentially accept any reasonable counter-offer made by FRONTLINE. Therefore, if FRONTLINE is not in agreement with MR. CUTTLER’S reasonable demand for payment of his rightfully owed insurance benefits being submitted at this time, MR. CUTTLER hereby requests that FRONTLINE now make a reasonable counter-offer before the expiration of the cure period. MR. CUTTLER still hopes that his claim can be resolved amicably. The concept of insurance is that insurance is the insurer’s granting of timely and prompt indemnity or security against a contingent loss. Florida Statute §624.02 defines “insurance” as a contract whereby one undertakes to indemnify another or pay or allow specified amount or a determinable benefit upon determinable contingencies. Inherent is the fact that payment must be made timely and promptly so that MR. CUTTLER may mitigate his damages and to put him back into the position he was in prior to loss as quickly as possible. FRONTLINE breached this duty. This notice is given in order to perfect the right to pursue the civil remedy authorized and pursuant to Florida Statute §624.155, including any and all bad faith/extra contractual, should FRONTLINE fail to cure the violations set forth in this Civil Remedy Notice within the given cure period. While no specific “cure amount” is required for this Civil Remedy Notice to be valid, MR. CUTTLER will consider the allegations contained herein “cured” if FRONTLINE, without any requirement for a release: (1) Immediately tenders the amount of MR. CUTTLER damage estimate in the amount of $715,618.66 (less any prior payments, depreciation, excess policy limits, and/or deductible), which accurately reflects the true nature and extent of the damages to the Dwelling / Other Structures; (2) Agrees to reimburse MR. CUTTLER for his expenses incurred by having to retain a public adjuster to present his claim; and (3) Immediately tenders the amount of statutory interest due and owing to MR. CUTTLER pursuant to Florida Statute §627.70131(5)(a). (4) Immediately provides MR. CUTTLER with the documentation FRONTLINE has used and/or continues to contend, supports the claim determination made by FRONTLINE in the adjustment of MR. CUTTLER’S claim. Specifically, FRONTLINE must provide MR. CUTTLER with its claim estimate(s), supporting photographs and/or videos, as well as any and all reports of any expert(s) or other individuals retained on behalf of FRONTLINE upon which FRONTLINE has relied on in reaching and/or further supporting its coverage determination in MR. CUTTLER’S claim. MR. CUTTLER continues to remain open to a fair and reasonable settlement offer from FRONTLINE in an effort to avoid additional delay, costs and expenses, and hereby request the same prior to the expiration of the statutory “cure” period. MR. CUTTLER has provided FRONTLINE with all necessary estimates, documentation, etc. in support of the claim. FRONTLINE must act fairly and honestly in its response to MR. CUTTLER’S request for a prompt, fair and reasonable settlement offer and resolution of the claim.
Comments
User Id Date Added Comment
lberns@bressler.com 02-03-2025 Please accept this response on behalf of Frontline Insurance Unlimited d/b/a Frontline Insurance (“Frontline”) to the Civil Remedy Notice No. 795641, filed on behalf of Michael Cuttler, Trustee, (“Complainant” and/or “Insured”), and accepted by the Florida Department of Financial Services on December 6, 2024. The Civil Remedy Notice (“CRN”) alleges that Frontline violated the following statutes: 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 coverage, 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)(c) Failing to acknowledge and act promptly upon communications with respect to claims. 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 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 the offer of a compromise settlement. 626.9541(1)(i)(4) Failing to pay undisputed amounts of partial or full benefits owed under first-party property insurance policies within 60 days after an insurer receives notice of a residential property insurance claim, determines the amounts of partial or full benefits, and agrees to coverage, unless payment of the undisputed benefits is prevented by factors beyond the control of the insurer as defined in s. 627.70131(5) As a preliminary matter, Frontline hereby rejects any allegation of bad faith, improper investigation or claims handling, claim delay, underpayment, failure to provide notification of additional information necessary to process the claim, or any other violation of any of the statutory or administrative code sections cited and referenced in the CRN. Simply put, Frontline outright denies any act or omission that could be construed or found to be deemed bad faith and/or a violation of the above cited statutes. As this response will show, Frontline promptly investigated the claim and issued its coverage determination based upon the terms and conditions of the policy. Further, Frontline issued an advance on the subject claim to assist with the rebuild and mitigation for the subject claim. Frontline was at all times responsive to the Insured and any and all request from its representatives regarding the adjustment of the claim. Frontline maintains that it is the Insured who has failed to act promptly upon communications regarding the claim. Beyond Frontline’s adamant belief that it acted with the utmost good faith, the CRN is deficient and fails to preserve any and all claims for statutory bad faith under Florida Law. Florida Statute § 624.155 requires a complainant to file with the Department of Financial Services a Civil Remedy Notice which shall be “on a form provided by the [Department] and shall state with specificity…such other information as the Department may require.” The Department created a CRN form: Form DFS-10-363 which lays out 15 requirements, including in part, the Complainants E-mail address, Complainant Type, Attorney’s Name, Attorney’s Address, Attorney’s Email Address, Type of Insurer, Address of Insurer, Type of Insurance, Reason for Notice. As these requirements are required by the Department, according to § 624.155, they must be stated with specificity. The instant CRN fails to provide the Email Address of the Insured, but rather states the email address for the former public adjuster for the subject claim. Due to the improper completion of the mandated information, the CRN fails to comply with the form requirements set forth in Florida Statute § 624.155, fails to comply with 624.155(3)(b)(3), and is facially deficient. See Bay v. United Servs. Auto. Ass’n, No. 4D19-3332, 2020 WL 6154256 (Fla. 4th DCA Oct. 21, 2020). The CRN fails to provide any claim-specific description relating to any specific acts or circumstances which give rise to the alleged statutory violations and administrative code violations, thus, prejudicing Frontline from providing any meaningful or complete response. The CRN is hardly more than a recitation of the language of a number of Florida statutory provisions. The CRN is devoid of any reference to specific dates, documents, or any correspondence between the parties regarding the subject claim. A CRN must state the facts and circumstances that give rise to an alleged violation with specificity sufficient to allow an insurer to cure the alleged violation within the sixty-day statutory period. Lane v. Westfield Insurance Company, 862 So. 2d 774 (Fla. 5th DCA 2003). Moreover, the CRN fails to apprise Frontline of any actions that rise to the level of a statutory violation and the facts contained therein are disingenuous, misleading, and incomplete. The CRN does not provide the contemplated and mandated notice of alleged bad faith that is required as a condition precedent to any civil claim for bad faith pursuant to Fla. Stat. §624.155. For these reasons alone, the CRN fails at its inception. Further, the CRN sets forth an insufficient cure demand, stating that Frontline must: (1) Immediately tenders the amount of MR. CUTTLER damage estimate in the amount of $715,618.66 (less any prior payments, depreciation, excess policy limits, and/or deductible), which accurately reflects the true nature and extent of the damages to the Dwelling / Other Structures; (2) Agrees to reimburse MR. CUTTLER for his expenses incurred by having to retain a public adjuster to present his claim; and (3) Immediately tenders the amount of statutory interest due and owing to MR. CUTTLER pursuant to Florida Statute §627.70131(5)(a). (4) Immediately provides MR. CUTTLER with the documentation FRONTLINE has used and/or continues to contend, supports the claim determination made by FRONTLINE in the adjustment of MR. CUTTLER’S claim. Specifically, FRONTLINE must provide MR. CUTTLER with its claim estimate(s), supporting photographs and/or videos, as well as any and all reports of any expert(s) or other individuals retained on behalf of FRONTLINE upon which FRONTLINE has relied on in reaching and/or further supporting its coverage determination in MR. CUTTLER’S claim. It is important to note that there is varying case law regarding whether and what type of cure is required. In Hunt v. State Farm Fla. Ins. Co., 112 So. 3d 547, 548 (Fla. 2d DCA 2013), the appellate court found that the trial court erred in ruling that the CRN in that case under § 624.155, Fla. Stat. (2006), was invalid for failure to include a definite cure amount and terms. Specifically, the Cure requests “expenses incurred by having to retain a public adjuster to present his claim,” this which his of course an amount unknown by Frontline. The appellate court noted that Section 624.155(3)(b) did not require a CRN to allege a specific cure amount. That being said, if it is absolutely impossible for the carrier to ascertain a demand, an argument can be made that the CRN fails to provide a true and feasible cure method. Thus, it is Frontline’s position that the failure to provide a clear ascertainable cure amount renders Frontline’s ability to cure all allegations an impossibility and invalidates the CRN on its face. Accordingly, the CRN does not provide the contemplated and mandated notice of alleged bad faith that is required as a condition precedent to any civil claim for bad faith pursuant to Fla. Stat. § 624.155. The CRN does not refer to any specific policy language pertinent to the allegations of bad faith. Rather, the CRN lists various sections of the policy and does not state any specific policy provisions which would support the allegations contained within the CRN. For example the CRN states, “Coverage A-Building Coverage provisions (CP 00 10 06 07).” Nowhere within the four corners of the CRN does it state the actual policy language of the provisions pertinent to allegations of bad faith. Courts have found that listing whole sections of the insurance policy constitutes insufficient specificity.” See Fox v. Starr Indem. & Liab. Co., No. 8:16-CV-3254-T-23MAP, 2017 U.S. Dist. LEXIS 65123, 2017 WL 1541294 at *2; see also Julien v. Frontline Property & Casualty Ins. Co., 311 So. 3d 875, 879 (Fla. 4th DCA 2021) (“Here, Julien did not substantially comply with the specificity standard, and this was more than a mere technical defect.”). The failure to provide a specific reference to specific policy language is direct and clear noncompliance with the requirements of Fla. Stat. § 624.155. The CRN requires that Frontline speculate as to the policy provisions at issue, which is the opposite of putting Frontline on notice. Therefore, failure to include specific policy language renders the CRN deficient in form and substance. For these reasons, the CRN fails on its face. Failure to provide specific reference to any relevant policy language is direct and clear noncompliance with the requirements of Fla. Stat. § 624.155, and therefore renders the CRN deficient on its face, as to form and substance. For these reasons alone, the CRN fails at its inception. With respect to the factual background of the claim, on or about September 27, 2024, Frontline first received notice of a loss alleged to have occurred at the subject property on September 28, 2022, as a result of Hurricane Helene. Immediately upon receipt of the claim, Frontline commenced an investigation, including assignment of Claim Number 05000002312 and issued a Claim Notice Letter on September 29, 2024. Within that correspondence Frontline issued a Reservation of Rights letter regarding the subject claim as well. Frontline further assigned an independent field adjuster to perform a physical inspection of the property. An initial inspection of the property took place on October 1, 2022, days after reporting of the claim. On October 23, 2024, Frontline timely responded to the Insured’s Sworn Statement in Proof Loss in the amount of $726,802.86, which was submitted to Frontline on October 20, 2024. The letter reaffirmed that the claim was being investigated under a Reservation of Rights. Frontline advised that it was not agreement with the amount of the loss as the investigation was still pending. On November 15, 2024, Frontline issued an advance payment in the amount of $72,000 for Coverage A for damages to the property before a final coverage determination was rendered. On November 26, 2024, an engineer from SDII inspected the subject property to confirm the cause and origin of the alleged damage and as well as to be able to confirm the damage to the property attributed to Hurricane Helene versus Hurricane Milton. Additionally, on November 27, 2024, Frontline issued an additional payment of $8,000 for the claim in relation the Tornado Construction of Florida Invoice submitted by the Insured. In total $80,000 of advance payment was issued to the Insured for the subject claim prior to a final coverage determination. In order to continue to assess the extent of the damage alleged, Frontline sent M6, a Building Consultant, to inspect the property and the damage being claimed. M6’s inspection took place on October 16, 2024. On January 3, 2025, Frontline issued a coverage determination letter advising that there was coverage for he roof in the amount of $52,260.89 in relation to Hurricane Helene. The letter was also detailed in that it outlined the coinsurance penalty applied in the amount of $26,130.44 pursuant to the terms and conditions of the policy. Given the RCV scope of damages less the co-insurance penalty and less the $30,690.00 Hurricane Deductible, less prior payment of $80,000 no additional payment was tendered. The M6 estimate was enclosed within the coverage determination letter. Despite the allegations contained within the CRN, Frontline kept the Insured informed of the investigation of the claim throughout the entire adjustment process. The multiple correspondences the Insured and its representative evidence constant communication, timely adjustment and transparency in the adjustment process which defies any allegations of bad faith. To the extent that this response does not address each and every allegation of bad faith conduct made by the Insured, Frontline hereby expressly and vehemently denies any and all allegations of bad faith conduct or omission set forth in the CRN, and/or any alleged violation of Fla. Stat. § 624.155 or any other statutory sections set forth therein. Again, Frontline insists that it has acted, at all times, in utmost good faith. Should you need any additional information from Frontline regarding the foregoing, please feel free to contact the undersigned. In short, and contrary to the unsupported statements contained in the CRN, the facts of this case are that Frontline performed its duties and has further complied with applicable Florida law and did not at any time whatsoever act in bad faith towards the Insured in the handling of the subject claim.
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