Civil Remedy Notice of Insurer Violations
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Filing Number:     804515
Filing Accepted:  1/31/2025
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Complainant
Last/Business Name *  
DAVIS   First Name   HARVEY
Street Address * 857 WOOD SORREL LANE
City, State Zip * VENICE, FL 34293
Email Address * HDC1993@VERIZON.NET
Complainant Type: * Insured
Insured
Last/Business Name*   DAVIS   First Name   HARVEY
Policy # * FFH3-000037010 Claim #* 01000069153
Attorney
Attorney is Applicable
Last Name* KRAPF First Name * GRANT Initial W
Street Address* 2790 SUNSET POINT RD
City, State Zip* CLEARWATER , FL 33759
Email Address * GRANT@KRAPFLEGAL.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):* DEVIN MAPP, BRIAN MORRIS, NINA LAFOND, MSICHANA THOMPSON, DONALD PHILLIPS, P.E., AND ANY OTHER INDIVIDUAL FROM, OR AGENT OF, FIRST PROTECTIVE INSURANCE COMPANY D/B/A FRONTLINE INSURANCE WHO WAS INVOLVED IN THE CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Delay
Unfair Trade Practice
Other : Not treating the Insured with good faith claims conduct.
Other : Looking for ways to delay and deny full recovery to the Insured.
Other : Not training, supervising, or managing adjusters properly so that prompt and full payments are made
* 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.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

627.70131 - upon the Insurer 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. As used in this subsection, "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. This subsection shall not apply to Claimants represented by counsel beyond those communications necessary to provide forms and instructions. 627.70131 failing to make any payment of an initial or supplemental claim or portion of such claim within 90 days after the Insurer receives notice of the claim, or made more than 15 days after there are no longer factors beyond the control of the insurer which reasonably prevented such payment, whichever is later, bears interest. Reference to specific policy language: The violations alleged are statutorily based and do not rely on any specific policy language.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

First Protective Insurance Company d/b/a Frontline Insurance and their agents (the "Insurer") has committed the following in handling the Insured's claim: 1) failure to act in due diligence and good faith to resolve claims; 2) placing the financial interest of Insurer before that of the Insured; 3) not adjusting the claims promptly and fairly; 4) shifting the burden of investigating the loss onto the Insured; 5) conducting inadequate investigations; 6) making material misrepresentations of the coverages afforded under the insurance policy; 7) failing to respond to communications made to the Insurer or their agent within 14 days; and 8) failing to pay interest on a payment made over 90 days after the Insurer received notice of the claim. The Insured timely submitted a claim to the Insurer for hurricane damage sustained to the above-referenced Insured property that occurred on or about September 28, 2022, including any ensuing damage therefrom. Due to the scope and nature of the damage, the Insured retained a public adjuster who, in an estimate dated October 24, 2022, revealed covered damages of $212,040.21 to the dwelling and $12,000 to the screen enclosure. The Insurer initially responded with a coverage letter, dated December 22, 2022, wrongfully stating that the gross loss was $33,431.09 from which the Insurer withheld $7,424.64 as "recoverable depreciation" and issued three checks totaling $16,400.55. A supplemental coverage letter arrived, dated April 23, 2023, after a second inspection, showing a gross loss of $47,395.79 and a payment of $8,821.64. Another inspection occurred on May 1, 2023, for which the coverage determination letter asserted the gross loss was now $56,454.60 and a payment of $3,965.22 was issued based on that letter. This amounts to over six months of delay by the Insurer which is well documented and includes repeated re-assignments of this claim to different desk adjusters with the Insurer including Brian Morris, Msichana Thompson and Devin Mapp. While the Insurer's totals kept increasing, however, they are still not nearly enough to make their Insured whole in this case and indeed are not even complete for example, the Insured's agents communicated to the Insurer regarding the covered expenses to tarp the damage on November 13, 2022 and March 2, 2023 and these expenses were simply ignored in the Insurer's totals. Further, the Insurer failed to respond within 14 days to Claimant, and his agents' requests. Upon an Insurer's receiving a communication with respect to a claim, the Insurer is required, within fourteen (14) calendar days, to 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 prevents such acknowledgement. There has been no response within the fourteen (14) calendar days of receipt of the Insureds' communication and the Insurer has not alleged any factors beyond their control that would make such communication impossible. Insurers have a duty to settle claims in good faith when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its Insureds and with due regard for her interests. The Insurer has failed or refused to promptly acknowledge the Claimants' communications in an attempt to frustrate and delay the resolution of Claimants' claim. The Insurer upon the Insured's loss had the duty to provide the full benefits under the policy. This includes providing the Insured with a proper investigation and the funds necessary to return their home to its pre-loss condition. Despite the obvious covered damage under this policy, the Insurer here placed its financial interest over the health and safety of the Insured. The investigations by the Insurer's field adjuster were inadequate. As a result of the inadequate investigation and surrounding circumstances, it is apparent that the Insurer significantly repeatedly underestimated the scope of the loss to the Insured'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 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 Insured, to delay the Insured's claim, and to delay the Insured's ability to restore the property to its pre-loss condition. The Insurer's total estimate of the insured property's loss resembles that of a classic "low-ball" offer and would not restore the property to its pre-loss condition which is Insurer's duty under the contract of insurance issued by it. Insurer and its adjuster have colluded to misrepresent the true scope of damages to the insured property and the true replacement costs of the damages. This is an underhanded attempt to place the financial interest of the Insurer over those of the Insured, to delay the Insured's claim, and to delay the Insured in restoring the property to its pre-loss condition. Moreover, Insurer shifted the burden and cost of investigating and insuring the loss onto the Insured. The Insurer upon the Insured's loss had the duty to provide the full benefits under the policy. This includes providing the Insured with the proper investigation and the funds necessary to return their home to its pre-loss condition. The Insurer is placing its financial interest over the health and safety of the Insured. Although there was interior moisture damage, the adjuster did not use a moisture meter or inspect for mold. A moisture meter can be purchased online from Amazon for around $44 before tax. The Insurer could purchase a moisture meter and assess thousands of properties with one meter. The Insurer's adjuster should have a full tool belt to thoroughly investigate claims. Instead, the Insurer's adjuster has no need for a tool belt because they don't have the necessary tools to fill it. It is clear the Insurer would rather place its financial interests over those of the Insured by failing to provide the adjuster with the necessary tools to correctly inspect the loss. 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 Insureds property. Moreover, the Insurer unreasonably inflated the amount of recoverable depreciation in this case, thereby artificially lowering the Claimant's recoverable value, to the detriment of the Claimant. The Insurer withheld an exorbitant amount of the net claim determined by the Insurer as recoverable depreciation. The Insurer has attempted to gain an unreasonable financial benefit by inflating the recoverable depreciation because it knows that it is unlikely, or at least less likely, that the Claimant can actually complete the repairs which is a condition precedent to the recovery of the depreciation withheld under the claim. In other words, the Insurer pays an unreasonable amount less on the front end of a claim, which makes it more difficult for the Claimant to restore the property to its pre-loss condition and recover the withheld depreciation from the Insurer. Only after Insured pays to restore the property out of pocket, if he can, will the Insurer fully pay its Insured under the policy. Withholding an inflated amount of depreciation is a creative, sneaky, and deceptive practice that is employed as to limit the amount the Insurer will ever have to pay out on a claim and essentially make the homeowner a self-insured. The Insurer is hoping that the Claimant is unaware of her right to recover the recoverable depreciation so that it can pay Claimant less than it is obligated. The Insurer is shifting the cost and the burden of investigating the loss onto the Claimant. The Insurer has the duty to inspect the loss and provide the Claimant with the full benefits under the policy. The Insurer has breached that duty by not providing the Claimant with the full value of the loss and caused the Claimant to take on the burden of investigating the loss. In addition, the Insurer further delayed and frustrated Claimant's ability to have this supplemental claim adjusted promptly to begin restoring the home by waiting more than ninety (90) days after receiving notice of the Insured's claim to issue a payment. Pursuant to Florida Statute 627.70131, "any payment of an initial or supplemental claim or portion of such claim made 90 days after the Insurer receives notice of the claim, or made more than 15 days after there are no longer factors beyond the control of the insurer which reasonably prevented such payment, whichever is later, bears interest." The Insurer has failed to pay any interest on this claim. The purpose of this section of the Florida Statutes was to set a time limit in which to resolve policyholder's claims. Upon information and belief, the Insurer has failed to do this. Because the Insurer has delayed the Claimant's resolution of the above-referenced claim, it is obligated to pay the interest on the claim, in addition to the money it owes the Claimant to restore the property to its pre-loss condition. In short, Insurer is not acting with due regard for the Insured's interests or safety. In Florida the work of adjusting insurance claims engages the public trust. Insurers have a duty to treat all Insured equally and the Insurer has breached this duty. The Insurer has conducted poor and inadequate investigations and has significantly underestimated the replacement costs of Insured's property to further frustrate and delay the Insured's claim. The Insurer is placing their financial interests over those of the Insured and the Insured's safety. The foregoing has only delayed the Insured's ability to begin restoring their home to its pre-loss condition. The Insurer's actions amount to but are not limited to the following: 1. Not treating the policyholder with good faith claims conduct. 2. Looking for ways to reduce recovery to the Insured. 3. Not adjusting claims and evaluating loss properly, promptly and fairly to provide full and prompt indemnity to the Insured. 4. Not training, supervising or managing adjusters properly so that prompt and full payments are made, but rather placing the company's interests before the policyholder's interests. 5. Placing the financial interest of the Insurer over that of the Insured. 6. Shifting the burden of investigating the loss onto the Insured. 7. Conducting inadequate investigations. 8. Making material misrepresentations of the coverages afforded under the insurance policy. Therefore, to cure the defects outlined in this Civil Remedy Notice, the Insurer must: (1) Admit full coverage for the Insured's loss. (2) Tender full benefits owed to the Insured under the insurance contract. 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 badfaith@krapflegal.com. Via Electronic Mail: First Protective Insurance Company d/b/a Frontline Insurance P.O. Box 958405 Lake Mary, FL 32795-8405 info@flhi.com
Comments
User Id Date Added Comment
ailene.rogers@petersonbernard.com 03-24-2025 March 24, 2025 VIA ELECTRONIC FILING Florida Department of Financial Services Bureau of Consumer Assistance Civil Remedy Section Larson Building 200 East Gaines Street Tallahassee, FL 3399-0322 RE: Insurer: FIRST PROTECTIVE INSURANCE COMPANY Claimant: Harvey Davis CRN filing: 804515 Accepted date: 1/31/25 Claim No.: 01000069153 Date of Loss: 9/28/22 Dear Madam or Sir: We represent First Protective Insurance Company d/b/a Frontline Homeowners Insurance (“FRONTLINE”) in connection with a claim submitted by Harvey Davis and Christine Davis. We are in receipt of Civil Remedy Notice of Insurer Violation (CRN) submitted by Harvey Davis and accepted by the Florida Department of Financial Services (DFS) on January 31, 2025, with filing number 804515. Please allow this correspondence to serve as FRONTLINE’s response to the CRN. While this CRN is filed only on behalf of Harvey Davis, the Policy lists both Christine Davis and Harvey Davis as Insureds. FRONTLINE denies each and every allegation set forth in the CRN and denies any wrongdoing in the handling of this matter. At the outset, FRONTLINE notes that this is the third CRN the Insureds have filed, and that FRONTLINE has timely responded to the Insureds’ two prior CRNS. The first CRN (“CRN 1”) was filed on May 31, 2023, and assigned filing number 697313. This CRN was filed in “rough draft” form and included requests from what appears to be the person reviewing the CRN to the person drafting the CRN concerning revisions that needed to be made before the CRN was finalized. For example, CRN 1 states: • There is information on the timeline discussing items missed (tarping etc) – please include- need to include information in the Azeel note from the PA too • Lack of communication – see timeline & how many DAs were involved • Moisture Meter • Didn’t pay statutory interest on post 90-day supplement. The second CRN (“CRN 2”) was filed on August 9, 2023, and assigned filing number 709900. Incredibly, CRN2 is identical to CRN 1 and was also filed in “rough draft” form with the same reviewer’s notes to the drafter. Finally, on January 31, 2025, the third, instant CRN (“CRN 3”) was filed. This CRN differs from CRN 1 and CRN 2 only insofar as it appears to be a final draft, and the information reported to be missing from CRN 1 and CRN 2 has been added. FRONTLINE hereby denies any and all allegations of bad faith by the Complainant, and states that it has at all material times handled and adjusted the Complainants’ claim with the utmost good faith. FRONTLINE will address the new allegations immediately below and reserve the remainder of this CRN to respond, yet again, to the false, unsupported, and spurious allegations that have twice already been addressed. The Insureds’ new allegation that FRONTLINE failed to pay for a tarp is patently false. This matter was settled in appraisal . The umpire agreed with the Insureds’ appraiser’s amount of the loss and included the tarp services complained about in the award. Additionally, on March 2, 2023, during the pendency of the claim investigation, FRONTLINE informed the Insureds that payment was issued to MRC Services for tarp installation services. The remaining three new allegations do not set forth any additional amount that is owed, as the amount of the loss was addressed in the appraisal process and agreed to by the Insureds’ own appraiser and the umpire. To suggest otherwise is erroneous. Further, there is no support to the Insureds’ allegations that interest is owed. There are no allegations set forth in the CRN, nor do any facts exist that support the Claimants’ allegation that any portion of the claim was not paid within 15 days after there were factors beyond FRONTLINE’s control, thereby requiring FRONTLINE to pay any interest Below, FRONTLINE will, yet again, include a detailed factual history of the claim handling and actions by FRONTLINE as to the remainder of the allegations set forth in the instant CRN which clearly demonstrates that FRONTLINE acted properly in responding to the claim and complied with both its contractual and legal obligations. As with the prior two CRNS, the Complainants’ CRN is defective because it fails to comply with the strict governing requirements contained within Florida Statute §624.155. Namely, the statute requires that a CRN shall “state with specificity [t]he facts and circumstances giving rise to the violation.” Fla. Stat. §624.155(3)(b)2. Under Florida law, a civil remedy notice must state the facts and circumstances that give rise to an alleged violation with such specificity sufficient to allow an insurer to cure an alleged violation within the sixty (60) day statutory period. See Lane v Westfield Ins. Company 862 So 2d 774 (Fla 5th DCA 2003). The Fourth District Court of Appeal confirmed dismissal of an action for bad faith based upon a lack of specifity in a CRN similar to the one that has been filed on behalf of the Complainant in this case. Julien v. FIRST PROTECTIVE Property & Casualty Insurance Company, 4D19-2763 (Fla. 4th DCA Sept. 23, 2020). Therein, the Court highlighted that the “plain language of section 624.155(3)(b) instructs the policyholder to ‘state with specificity’ information in the notice; to specify ‘language of the statute, which the authorized insurer allegedly violated;’ and to ‘[r]eference specific policy language that is relevant to the violation, if any.’” The Fourth District Court of Appeal further found that casual reference to a multitude of statutes or listing whole sections of the insurance Policy did not satisfy the specificity requirements of a CRN. Id. The Complainants’ CRN is deficient as the limited facts and circumstances set forth therein are false, incomplete, and misleading, as well as insufficient to establish a violation of any statute or Policy provision. Additionally, the CRN includes multiple statutory provisions alleged to have been violated. The referenced statutes, however, do not appear to be pertinent to the subject claim, and the CRN fails to specify each statutes’ relative applicability to same. Furthermore, the CRN does not contain specific facts addressing and supporting each alleged statutory violation against FRONTLINE, but rather sets forth only stock, conclusory allegations of purported bad faith. For these reasons alone, the CRN is defective on its face. In light of the incomplete, misleading, and false allegations set forth in the CRN, FRONTLINE hereby provides the Florida Department of Financial Services with the following facts of the claim that, in and of themselves, disprove all of the allegations brought forth in the CRN. Frontline hereby asserts that all actions taken in the handling of this claim were done so in good faith for the purpose of fair and timely disposition of this matter. CLAIM FACTS FRONTLINE’s first notice of this claim was on October 1, 2022. It was reported that the property was damaged as a result of Hurricane Ian which made landfall on September 29, 2022. FRONTLINE immediately acknowledged the claim, advised the Insureds of their post loss duties, provided the Homeowner’s Bill of Rights, and began its investigation of the claim. FRONTLINE requested that the Insureds complete a Sworn Proof of Loss within 60 days of October 1, 2022, and provided a blank form for their convenience. After multiple unsuccessful attempts, FRONTLINE was finally able to make contact with the Insured on October 12, 2022. On October 14, 2022, FRONTLINE received a Letter of Representation from Coastal Claims Service. This Letter of Representation was acknowledged by FRONTLINE on November 7, 2022. On October 19, 2022, FRONTLINE’s Field Adjuster conducted an initial inspection of the property with the Insured, Christine Davis. At the time of the inspection, photographs were taken documenting the condition of the home. The Field Adjuster reviewed the scope of damages with the Insured, explained the claims process and the Insured’s roles and responsibilities. On November 7, 2022, FRONTLINE spoke with both Insureds after unsuccessfully trying to reach the public adjuster. FRONTLINE’S claim investigation and adjusting process was explained to both Insureds. Following the initial inspection, on December 22, 2022, FRONTLINE issued a coverage payment to the Insureds based on actual cash value, less recoverable depreciation. Along with payment, a copy of the estimate was provided. FRONTLINE advised that the claim remained open, and in addition to the carrier’s investigation, requested the Insureds’ cooperation in reaching an agreement on the covered loss. If the Insureds disagreed with the amount of the estimate actual cash value payment, they were requested to notify FRONTLINE of the specific reasons. FRONTLINE also requested additional documents, including an accurate record of repair expenses, any contract or estimates, unpaid invoices, photos prior to the property damage, and an updated and sworn proof of loss. On January 31, 2023, FRONTLINE acknowledged receipt of a Sworn Proof of Loss (“SPOL”) from the Insureds. The SPOL was executed on January 17, 2023, 112 days after Frontlines’ October 1, 2022, request date. FRONTLINE advised that it could neither accept nor reject the Sworn Proof of Loss as the claim investigation was still in progress. On March 2, 2023, FRONTLINE informed the Insureds that payment was issued to MRC Services for tarp installation services. On the same day, FRONTLINE contacted the public adjuster and advised that an engineer would be sent out to conduct an inspection due to a difference in scope between the Insureds and FRONTLINE. On March 9, 2023, FRONTLINE spoke with the public adjuster advising that once the inspections were completed and reports were received, a supplemental review would be conducted. On March 30, 2023, the engineer performed an additional inspection of the subject property. Present for the inspection was Matt Morrison from Coastal Claims Services. Both Insureds were present as well. The engineer reviewed the permit history of the property, historical pictography, information relating to Hurricane Ian from the National Weather Service, National Hurricane Center, and NOAA, documents from MRC Services who installed the tarp, and photos from the Insureds. Also on March 30, 2023, FRONTLINE’s Field Adjuster conducted a second inspection of the property and documented their findings. Based on the reinspection and engineer’s report, additional coverage allowances were made to the claim. On April 23, 2023, an additional coverage payment was issued to the Insureds, and the FRONTLINE estimate on which it was based was provided as well. Again, FRONTLINE advised that the claim remained open, and in addition to the carrier’s investigation, requested the Insureds’ cooperation in reaching an agreement on the covered loss. If the Insureds disagreed with the amount of the estimate/ actual cash value payment, they were requested to notify FRONTLINE of the specific reasons. FRONTLINE also requested additional documents, including an accurate record of repair expenses, any contract or estimates, unpaid invoices, photos taken prior to the property damage, and an updated and sworn proof of loss. On April 24, 2023, FRONTLINE spoke with the public adjuster to discuss the supplement review and payment details. The public adjuster responded that he would review FRONTLINE’S estimate and follow up with the carrier. On May 1, 2023, a third payment was made to the Insureds, and with it, the FRONTLINE estimate upon which it was based. Again, for the third time, FRONTLINE advised that the claim remained open, and in addition to the carrier’s investigation, requested the Insureds’ cooperation in reaching an agreement on the covered loss. If the Insureds disagreed with the amount of the estimate actual cash value payment, they were requested to notify FRONTLINE of the specific reasons. FRONTLINE also requested additional documents, including an accurate record of repair expenses, any contract or estimates, unpaid invoices, photos prior to the property damage, and an updated and sworn proof of loss. On May 2, 2023, a letter was issued to the Insureds providing a timeline of the claim investigation and conclusions from the engineer’s report. While some minor damage was attributed to wind, other reported damages were related to long term deterioration of a roof 24-years in age, deficient installation of ridge tiles, deficient mortar mix under ridge tiles, and thermal movement, in addition to improper installation of windows, lintel corrosion jacking to the stucco that pre-dated the hurricane, and separated interior room molding due to uneven geometry of the room. The Policy does not afford coverage for age related wear and tear, deterioration, and improper installation or cracking as a result of expansion and contraction. The letter cited the pertinent Policy language. FRONTLINE advised that evaluation of the claim was continuing and if the Insureds had concerns or additional information to provide, to contact FRONTLINE. A call was placed the same day to the public adjuster to discuss supplement review and payment details. On May 10, 2023, FRONTLINE spoke with the public adjuster to discuss repair of the roof. Matching roof tiles were located, and a repair of the roof could be completed. The public adjuster asked if FRONTLINE would be sending a roofer to complete the repair. FRONTLINE advised that it was the responsibility of the Insureds to effectuate the repairs. On May 17, 2023, a Letter of Representation was received from Krapf Legal on behalf of the Insureds. On the same day, a Notice of Intent to Litigation was filed with the Department of Financial Services. FRONTLINE responded to the Notice on May 30, 2023. On May 31, 2023, CRN Filing Number 697313, CRN 1, was filed on behalf of Insured, Harvey Davis, and on July 28, 2023, FRONTLINE filed its response to CRN 1. Thereafter, on May 30, 2023, FRONTLINE invoked appraisal responsive to the NOI. On August 9, 2023, CRN Filing Number 709900 , CRN 2, was filed on behalf of Insured Christine Davis. On September 15, 2024, FRONTLINE filed its response to CRN 2. As demonstrated above, FRONTLINE conducted a timely, thorough, and good faith evaluation of this claim. FRONTLINE has at all times fully complied with all obligations imposed by the subject Policy and Florida law. FRONTLINE specifically denies each and every allegation made in the CRN which is further addressed below. ALLEGED REASONS FOR NOTICE Claim Delay Unfair Trade Practice Not treating the Insured with good faith claims conduct Looking for ways to delay and deny full recovery to the Insured Not training, supervising, or managing adjusters properly so that prompt and full payments are made There is no basis for these allegations; and they are denied. The Complainants have failed to submit any facts or circumstances whatsoever to support these allegations. It is clear from the facts outlined herein that the handling and administration of this claim occurred with adherence to the statutory and contractual requirements imposed upon FRONTLINE. At no time did FRONTLINE, its agents, or its employees act improperly in the handling, administration, or disposition of this claim. The facts show that FRONTLINE promptly acknowledged the claim and timely initiated its investigation. As such, FRONTLINE acted in accordance with its duties and obligations pursuant to the Policy. ALLEGED STATUTORY VIOLATIONS The Complainant alleges statutory violations in the CRN; however, no specific facts or circumstances are provided to support any of these allegations. The CRN is simply a recitation of general, stock allegations of bad faith conduct, along with a list of statutory violations that are not specifically alleged or described. Notwithstanding, FRONTLINE denies each and every allegation of statutory violation individually as set forth below. 624.155(1)(b)(1): Denied. FRONTLINE has not failed to attempt to settle this claim in good faith and has always acted fairly and honestly towards the Complainant. As shown in the above factual summary, FRONTLINE inspected the property on three occasions and issued payment after further review of the claim and property conditions. Moreover, the Complainant has not submitted facts or circumstances to support this allegation. FRONTLINE asserts its full and strict compliance with the statutory requirements imposed upon it and all duties and obligation set forth in the subject insurance policy. 624.155(1)(b)(3): Denied. It is clearly evident that FRONTLINE has not violated this Statute as coverage payments were made for the damaged portions of the house where coverage was found. This is set forth in FRONTLINE’S letter dated May 2, 2023. 626.9541(1)(i)(2): Denied. FRONTLINE has not made any material misrepresentations to the Insureds, or any other person having an interest in a coverage payment. The carrier has been forthright and transparent in all of its communications to the Insureds. The Complainant has not presented one fact to support this allegation. 626.9541(1)(i)(3)(a): Denied. There is no showing by the Complainant to support the allegations made. FRONTLINE has adopted and implemented standards for the proper investigation of claims at all times. More specifically, here, after the initial Field Adjuster inspection was performed, a second inspection was performed as well, and an engineer inspection too. The aforementioned facts demonstrate that FRONTLINE employed proper and customary claims practices in the investigation and adjustment of this claim, and in strict compliance with the statutory requirements imposed upon it. 626.9541(1)(i)(3)(b): Denied. FRONTLINE has not misrepresented any pertinent facts or insurance policy provisions. The provisions on which FRONTLINE has relied are set forth FRONTLINE’S letter dated May 2, 2023. Furthermore, the Complainant has not provided any facts to prove this allegation, just conclusory statements with no support whatsoever. 627.70131: Denied. There are no allegations set forth in the CRN, nor do any facts exist that support the Claimants’ allegation that any portion of the claim was not paid within 15 days after there were factors beyond FRONTLINE’s control, thereby requiring FRONTLINE to owe any interest. ALLEGED VIOLATIONS OF THE INSURANCE POLICY Frontline asserts that the Complainants have failed to reference any specific Policy language in conjunction with any facts or circumstances of the underlying claim, and the failure to provide such specific reference to Policy language is direct and clear noncompliance with the requirements of Fla. Stat. § 624.155, rendering the CRN deficient on its face as to form and substance. Notwithstanding, FRONTLINE denies violating any provision or duties set forth in the Policy and further asserts compliance with the Policy and all of its provisions and endorsements. FRONTLINE handled the Complainants’ claim with diligence and at all times acted fairly in the administration of this claim and treated the Complainant with honesty and due regard for their interests. All actions by FRONTLINE were done in compliance with the Policy. FRONTLINE DENIES ALL ALLEGATIONS IN THE CRN FRONTLINE hereby denies any and all allegations of bad faith by the Complainants, and states that it has, at all material times handled and adjusted the Complainants’ claim with the utmost good faith. Any and all allegations of bad faith contained within the CRN are expressly rejected by FRONTLINE. As stated above, the CRN is simply a recitation of general, stock allegations of bad faith conduct, and conjecture, along with purported statutory violations that are not specifically alleged or described. The CRN is therefore noncompliant with Florida Statute §624.155(3), which requires that a CRN “state with specificity,” inter alia, the facts and circumstances giving rise to the violation and the “specific” language of the subject Policy that is relevant to any alleged violation(s). Moreover, there is not a single reference in the CRN to any specific Policy language that the Complainants allege as relevant to the allegations of bad faith. Failure to provide such specific reference to Policy language is direct and clear noncompliance with the requirements of Fla. Stat. §624.155 and renders the CRN deficient on its face as to form and substance. 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. For these reasons, the CRN is denied and rejected. Additionally, as described in detail above, the facts alleged in the CRN are contrary to the actual facts underlying the subject claim. FRONTLINE further denies any and all other allegations not specifically addressed in this response related to the above-referenced CRN. By responding to the Civil Remedy Notice filed by the Complainants, FRONTLINE neither waives nor abandons but expressly reserves any and all rights, claims and defenses it has or may have under the terms and conditions of the Policy and applicable Florida law. Herein, FRONTLINE has attempted to fully and adequately respond to the allegations alleged in the CRN. Should the Florida Department of Financial Services have any questions or further inquiry with respect to this matter, please contact the undersigned. Sincerely, /s/ Ailene Rogers Ailene Rogers For the Firm cc: Grant W. Krapf, Esquire (Via Certified Mail/Return Receipt; and email to: grant@krapflegal.com) Krapf Legal, P.A., 2790 Sunset Point Road, Clearwater, FL 33759
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