Civil Remedy Notice of Insurer Violations
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Filing Number:     811230
Filing Accepted:  3/14/2025
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Complainant
Last/Business Name *  
HOLT   First Name   BRANNON AND AMY
Street Address * 20715 MARINA ROAD
City, State Zip * PERRY, FL 32348
Email Address * WITHHELD
Complainant Type: * Insured
Insured
Last/Business Name*   HOLT   First Name   BRANNON AND AMY
Policy # * P000696322 Claim #* 258332
Attorney
Attorney is Applicable
Last Name* REEVES First Name * NICHOLAS Initial
Street Address* 4000 HOLLYWOOD BLVD, STE 685-S
City, State Zip* HOLLYWOOD , FLORIDA 33021
Email Address * NREEVES@CASSEL.LAW
Violation
Insurer Type *   Authorized Insurer Unauthorized Insurer
 
Insurer Name*   SECURITY FIRST INSURANCE COMPANY
NAIC Company Code 10117
 
Name of individual responsible for violation (if any):* JOHN JOINER, MS. MOULTRY, INDEPENDENT FORENSICS GROUP, AND ALL OTHER ADJUSTERS, SUPERVISORS, MANAGEMENT AND INDIVIDUALS ASSOCIATED WITH OR RETAINED BY SECURITY FIRST INSURANCE COMPANY INVOLVED IN THIS CLAIM.
Type of Insurance * Residential Property & Casualty   
Reason for Notice *
Claim Denial
Claim Delay
Unfair Trade Practice
Other : Violation of Adjusters' Ethical Requirements
* 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.
626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information.
* Specific policy language that is relevant to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

The violations asserted herein regarding Security First Insurance Company's bad faith actions are based heavily on the facts and circumstances asserted in the below section designated for same as well as violations of the portions of Florida Insurance Code and Florida Administrative Code upon which the bad faith statutes contained within Sections 624.155 & 626.9541, Florida Statutes, are based. Despite requests for a complete copy of the policy, Security First Insurance Company has not provided same and, as such, the exact verbiage of the terms of the subject policy are “UNKNOWN.” With that said, the based on prior experiences with policies issued by Security First Insurance Company or its related companies, it is anticipated that the following policy language is relevant to Security First Insurance Company's statutory violations and bad faith conduct: SECTION I – CONDITIONS 10. Loss Payment. We will adjust all losses with you. We will pay you unless some other person is named in the policy or is legally entitled to receive payment. Loss will be paid upon the earliest of the following: a. 20 days after we receive your written proof of loss and reach a written executed agreement of settlement with you according to the terms of the written agreement; or b. 60 days after we receive your written proof of loss and: (1) There is an entry of a final judgment or, in the case of an appeal from such judgment, within 60 days from and after the affirmance of the same by the appellate court; or (2) There is a written executed mediation settlement agreement with you according to the terms of the written mediation settlement; or c. Within 90 days after we receive written notice of an initial claim, “reopened claim” or “supplemental claim” from you, we will pay or deny such claim or a portion of the claim unless the failure to pay such claim or portion of claim is caused by factors beyond our control which reasonably prevent such payment.
 
* Facts and circumstances giving rise to the violation.
Enter all words or phrases (one at a time) that should be used to filter.

Form DFS-10-363, Rev. 10/14/2008, contains a field for the insureds to include their email addresses. Prior to filing the CRN, said form contains an instruction that, in the event the insureds do not with for certain information to become part of the public record, the insureds must simply include the term “WITHHELD” to satisfy the filing requirement. This is further established through the following statement with appears on Civil Remedy Notices which have been filed: Warning! Information submitted as part of this civil remedy notice is a public record. Data entered into this form will be displayed on the DFS website for public review. Please DO NOT enter Social Security Numbers, personal medical information, personal financial information or any other information you do not want available for public review. As any information contained herein becomes part of the public record, the insureds have withheld their email addresses so as not to make same available for public review and indicated same accordingly. Furthermore, as the insureds are represented by counsel, it would be improper for any representative of Security First Insurance Company to contact the insureds directly for any reason utilizing their email addresses and, as such, the information is neither material to Security First Insurance Company’s ability to correct the violations contained herein nor required by the Department of Financial Services. Security First Insurance Company should direct all follow-up correspondences to the attorney listed above. Furthermore, as the above section requesting people with knowledge as to the allegations in the instant CRN often gets cut off, the following are those responsible for the violations alleged herein: John Joiner, Ms. Moultry, Independent Forensics Group, and all other adjusters, supervisors, management and individuals associated with or retained by Security First Insurance Company involved in this claim. The facts and circumstances giving rise to the insurer's violation as the insureds understand them at this time: Brannon Holt and Amy Holt (hereinafter the “insureds”) purchased an all-risk property insurance policy, policy number P000696322 (hereinafter the “Subject Policy”) from Security First Insurance Company (hereinafter “Security First”) which, at all times material hereto, provided property insurance for the property located at 20715 Marina Road, Perry, FL 32348 (hereinafter the “Subject Property”). On or about September 26, 2024, Hurricane Helene caused direct physical loss and resultant/ensuing damages to the Subject Property (hereinafter the "Loss"). The insureds timely notified Security First of the loss. Security First assigned claim number 258332 to the loss (hereinafter the "claim") and assigned adjustment of the claim to Ms. Moultry who, in turn, enlisted the assistance of a field adjuster employed by Security First, to perform an inspection of the Subject Property. The carrier also retained Independent Forensics Group, a biased engineering firm routinely used to confirm the carrier’s coverage decisions, to perform an inspection On October 2, 2024, Independent Forensics Group performed an inspection of the Subject Property. On October 5, 2024, the assigned field adjuster inspected the Subject Property. On November 2, 2024, Security First sent a letter to the insureds indicating that the assigned field adjuster observed a total loss of the dwelling due to flood and storm surge from Hurricane Helene. Not surprisingly, the letter further stated that Independent Forensics Group agreed and also observed that the proximate cause of damage to the property, including all major structural and cladding components, was the result of rising water due to the storm surge. The letter concluded that there was no coverage for the claim. On November 6, 2024, in shock and extreme disappointment at Security First’s cursory investigation and summary denial, the insureds retained Coastal Claim Consultants (“Coastal”) for assistance with the claim. On November 7, 2024, Coastal sent a letter to Security First notifying the carrier of their retention, providing a letter of representation and making a formal request for documentation. On or about January 8, 2025, Coastal prepared a repair estimate to return the Subject Property to its pre-loss condition as a result of the destruction caused by the winds associated with Hurricane Helene, including the damaged contents and fair rental value, which totaled $594,180.05. On January 9, 2025, the insureds executed a sworn proof of loss which was supported by the estimate prepared by Coastal. On January 10, 2025, Coastal sent correspondence to the carrier including a payment request letter, the repair estimate, damaged contents list, competing engineering report, loss damage photographs, the sworn proof of loss, and a property held for rent confirmation. The January 10, 2025, payment request letter advised that the insureds hired their own forensic engineer, The Harris Solution, to inspect the property for the total loss caused by Hurricane Helene. The insureds’ engineer concluded that the damage to the subject structure was due solely to Hurricane Helene with the wind from the hurricane as the proximate cause of total destruction to the home. The engineering report indicated that Hurricane Helene had 89 mph sustained winds and 121 mph gusts that lasted a total of five hours. The insureds’ engineer conclusively determined that wind caused the total destruction of the home. As such, the letter respectfully requested that Security First reverse their initial denial of the claim and extend full coverage and payment for the loss according to the limits of the policy: $211,000.00 under Coverage A; $30,000.00 under Coverage C; and $21,100.00 under Coverage D. On January 16, 2025, John Joiner from Security First, responded to Coastal advising that he had been re-assigned to the insureds’ re-opened claim. Mr. Joiner acknowledged receipt of the numerous documents and information submitted by Coastal and also inquired whether the insureds had a flood policy and made a flood claim. Also on January 16, 2025, Coastal responded immediately advising that the insureds had no other insurance policies on the property and requested a phone call upon review of the documentation submitted by Coastal in support of the claim. On January 27, 2025, Coastal called Mr. Joiner and left a voicemail. Coastal also sent a follow up email requesting a status on the review of the claim and requesting that Mr. Joiner advise if any further information was needed to assist with the review process. On January 28, 2025, Mr. Joiner sent correspondence to Coastal advising that the insureds’ engineering report had been sent to the carrier’s engineer, Independent Forensics Group for review. On January 29, 2025, Costal responded to Mr. Joiner inquiring as to the potential timeframe in which Mr. Joiner expected to hear back from Independent Forensics Group regarding the review. On February 20, 2025, 41 days after Costal submitted the supporting documentation to the carrier, Mr. Joiner sent a letter to Coastal indicating that Security First had reviewed the documentation provided by Coastal, but that it did not alter the prior coverage determination based on the carrier’s initial investigation. Despite the overwhelming amount of information and documentation submitted to Security First by Coastal on behalf of the insureds, it is clear that the carrier made no real effort to continue its evaluation of the claim, choosing instead to rely wholly on its initially cursory investigation the conclusory opinions of its biased engineering firm. Security First denied the insureds’ claim through their actions also in violation of Florida’s Valued Policy Law (hereinafter "VPL"). Florida’s VPL, which has been in existence since 1899, provides, in pertinent part: In the event of the total loss of any building… located in this state and insured by any insurer as to a covered peril, in the absence of any change increasing the risk without the insurer’s consent and in the absence of fraudulent or criminal fault on the part of the insured or one acting in her or his behalf, the insurer’s liability under the policy for such total loss, if caused by a covered peril, shall be in the amount of money for which such property was so insured as specified in the policy and for which a premium has been charged and paid. Fla. Stat. § 627.702(1)(a) (2022). Furthermore, “if the covered perils alone would have caused the total loss,” coverage shall be afforded in the amount of the applicable policy limits. Id. at (b). The VPL requires an insurance company to set its maximum liability, for which it sets an appropriate premium, in order to eliminate any dispute over the amount of loss payable where the insured loss is total. The Valued Policy Law... sets the amount payable when there is a total loss. ‘Its principle object and purpose is to fix the measure of damages in case of loss total, or partial; and, to this end, it requires the insurer to ascertain the insurable value at the time of writing the policy, and to write it therein.’***Undoubtedly an important object of the statute is also to simplify and facilitate prompt settlement of insurance claims when a total loss occurs… Thus vexatious contest on this [value of the property] issue would persist when the best interests of all demanded prompt settlement and relief from the loss. A solution to this is found in the statute which in effect requires the parties to ascertain and agree in advance what the value is and in the case of total loss by the insured peril this amount shall be paid as liquidated damages. This is not an unfair scheme, as the insured is stating the limits of his recovery and at the same time the insurer is basing his premium charges on his maximum exposure. When the total loss occurs neither can contend the value of the destroyed property is any different from what they had previously specified. Springfield Fire and Marine Ins. Co. v. Boswell, 167 So.2d 780, 783-84 (1st DCA 1964); see also Ceballo v. Citizens Prop. Ins. Corp., 967 So.2d 811, 813 (2007)(“Florida’s VPL was originally enacted in 1899 to promote clarity and predictability for property insurers and insureds alike by predetermining the value of insured real property and having that value set out in the policy of insurance.”); Citizens Prop. Ins. Corp. v. Hamilton, 43 So.3d 746, 756 (1st DCA 2010)(“Once the jury found a total loss caused by wind, damages were fixed by statute.”). With Hurricane Helene, wind and wind-driven debris occurred first. This wind damage would have caused a total loss on its own, and as such, Florida’s VPL is triggered and policy limits are owed. This is further supported by the Informational Memorandum Notification to Authorized Residential Property Insurers, including Security First, issued by the Florida Office of Insurance Regulation (hereinafter “FOIR”) on February 20, 2025: https://content.govdelivery.com/accounts/FLOIR/bulletins/3d319a7. In the bulletin, the FOIR instructs that it “expects insurers, before denying a total loss claim for wind damage when flood or storm surge damage may have also damages the building . . . to be mindful of and apply the language contained in” the Florida Valued Policy Law statute. The FOIR further warns that “[i]nsurers failing to comply with Florida law and inappropriately denying coverage due to concurrent causation will be subject to additional regulatory action.” The actions of Security First with regard to the instant claim violate the very issues warned about by the FOIR’s bulletin. Should Security First fail to rectify this in response to the instant Notice, the FOIR will be notified regarding same, especially considering the pattern of conduct evident through counsel’s other files with Security First. The insureds have been left with no choice but to hire an attorney in order to file a notice of intent to initiate litigation subject to Fla. Stat. § 627.70152. Based on the documentation previously submitted, Security First could have reversed its coverage position and afforded coverage in line with the terms and conditions of the Subject Policy and governing Florida law or, at a minimum, requested a further inspection in order to attempt to find coverage by viewing the circumstances in the light most favorable to the insureds; instead, Security First chose to sit back and wait before Security First ever thought to act in a manner inconsistent with their own self-interest, forcing the insureds into hiring an attorney, thereby coming further out of pocket and leaving less of the outstanding due and owing insurance proceeds for actual repairs. This delay in claims adjustment constitutes a pattern of de facto bad faith conduct. Through its actions/inactions, subject to the facts and circumstances understood at this time as outlined herein, Security First has violated the following sections of Florida Statutes: §624.155(1)(b)(1) Not attempting in good faith to settle claims when, under all circumstances, it could have and should have done so, had it acted fairly and honestly toward its Insured and with due regard. §626.9541(1)(i)(3)(a) Failing to adopt and implement standards for the proper investigation of claims; §626.9541(1)(i)(3)(b) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue; §626.9541(1)(i)(3)(c) Failing to acknowledge and act promptly upon communications with respect to claims; §626.9541(1)(i)(3)(d) Denying claims without conducting reasonable investigations based upon available information; Additionally, through its actions/inactions, subject to the facts and circumstances understood at this time as outlined herein, Security First has failed to comply with the following sections of Florida Administrative Code: 69B-220.201(3)(b) An adjuster shall treat all claimants equally. 69B-220.201(3)(b)(2) An adjuster shall adjust all claims strictly in accordance with the insurance contract. 69B-220.201(3)(c) An adjuster shall not approach investigations, adjustments, and settlements in a manner prejudicial to the insured. 69B-220.201(3)(d) An adjuster shall make truthful and unbiased reports of the facts after making a complete investigation. 69B-220.201(3)(f) An adjuster, upon undertaking the handling of a claim, shall act with dispatch and due diligence in achieving a proper disposition of the claim. 69B-220.201(3)(k) An adjuster shall not undertake the adjustment of any claim concerning which the adjuster is not currently competent and knowledgeable as to the terms and conditions of the insurance coverage, or which otherwise exceeds the adjuster’s current expertise. As a direct result of Security First's actions, the insureds have sustained irreparable harm. Upon information and belief, the aforementioned actions complained of herein, among others, are effectuated by Security First so often as to constitute a general business practice evidencing a motive to enhance Security First's profits and cause a detrimental effect to its policyholders. Security First clearly failed to adopt and implement standards for the proper investigations of claims. As a direct and proximate result of Security First's handling of the claim, the insureds sustained extra-contractual damages, including, but not limited to, a public adjuster's fee and attorneys’ fees and costs. Security First's implemented claims programs and practices that were improper which directly resulted in additional losses to its insureds. Security First, as part of its routine business pattern and practices, employs outcome-oriented adjusters/vendors/experts who purposely looked for ways to minimize coverage instead of affording coverage to its policyholders. In contrast to the legislative intent which motivated the enumeration of an insurance adjuster’s responsibilities outlined in the Florida Administrative Code, the insureds were not afforded the professional duties entrusted and imposed on Security First by the Public Trust. The outcome-oriented claim adjustment practices undertaken by Security First led to Security First's failure to adequately adjust the Claim. This notice is given in order to perfect the right to pursue the civil remedy authorized by Section 624.155, Florida Statutes, should Security First fail to cure the violations set forth in this Civil Remedy Notice within the given cure period. In order to cure the defects outlined in this Civil Remedy Notice, Security First must act as follows: immediately deliver payment of all insurance proceeds due and owing to the insureds which would reasonably place the Subject Property back in its pre-loss condition or, alternatively, if appraisal is or has been requested, complete the appraisal process and deliver payment of the executed award; deliver payment for lost rental income; and keep the claim open for the adjustment of any supplemental claim and payment of any as of yet unincurred costs. If Security First disagrees with the extent of the cure requested or asserts that the payment of any of the above cure categories may not be required, Security First should cure to the extent it believes it must under the Subject Policy and governing laws to correct the allegations of bad faith contained herein. While it is not being requested as a cure for the bad faith alleged herein, the insureds remain willing to entertain any reasonable counteroffer of settlement.
Comments
User Id Date Added Comment
jjoiner@securityfirstflorida.com 04-16-2025 04/16/2025 Via Electronic Filing: Florida Department of Financial Services Bureau of Consumer Assistance c/o: Civil Remedy Section Larson Building 200 East Gaines Street Tallahassee, Florida 32399-0322 Via Email: NICHOLAS REEVES 4000 HOLLYWOOD BLVD, STE 685-S HOLLYWOOD, FLORIDA 33021 nreeves@cassel.law Re: CIVIL REMEDY NOTICE OF INSURER VIOLATION Filing No.: 811230 Insured: BRANNON AND AMY HOLT Complainant: BRANNON AND AMY HOLT Complainant Type: Insured Insurer: Security First Insurance Company Claim No.: 258332 Policy No.: P000696322 Date of Loss: 09/26/2024 Dear Sir or Madam: This correspondence represents the official response of Security First Insurance Company, (“Security First”) in the above referenced Civil Remedy Notice of Insurer Violations (hereinafter referred to as the “CRN”) that was filed by NICHOLAS REEVES on behalf of BRANNON AND AMY HOLT (hereinafter referred to as “Complainant”). The Florida Department of Financial Services (hereinafter referred to as “Department”) assigned this CRN an acceptance date of 3/14/2025 and DFS File No.: 811230. This matter concerns a property damage claim made by its Insured pursuant to a homeowners’ insurance policy provided by Security First Policy No. P000696322 and assigned Claim No: 258332. First, the civil remedy notice is overly broad in scope. The Civil Remedy Notice asserts in the “Reasons for Notice” section violations such as Claim Denial, Claim Delay, Unfair Trade Practice, Violation of Adjusters' Ethical Requirements, along with the following statutory violations: 624.155(1)(b)(1), 626.9541(1)(i)(3)(a), 626.9541(1)(i)(3)(b), 626.9541(1)(i)(3)(c), and 626.9541(1)(i)(3)(d). Security First welcomes this opportunity to respond to the CRN and denies each and every allegation contained therein. Security First does not consider there to have been any manner of violation and questions the validity of the Civil Remedy Notice, as it fails to adhere to the express requirements set forth under section 624.155, Florida Statutes, and Florida law, thus failing to perfect the Claimant’s rights to pursue civil remedies under the Florida Statutes. Furthermore, Complainant provided no factual basis for the alleged statutory violations other than a generalized, bald and conclusory allegations regarding its disagreement with Security First’s claim assessment. Security First has acted responsibly, in good faith and in accordance with the terms and provisions of the applicable policy of insurance. Moreover, Security First has and will always continue to act fairly and honestly toward BRANNON AND AMY HOLT with due regard for their interests. Security First has followed all proper procedures and is bound by the subject insurance policy, contracted for by BRANNON AND AMY HOLT with Security First. Among other sections, the Complainant alleges that Security First has not complied with Florida Statute 624.155(1)(b)(1). Said statute states, “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 towards its insured and with due regard to her or his interests.” It is a longstanding principle of Florida law that a claim for bad faith pursuant to section 624.155(1)(b)(1) is founded upon the obligation of the insurer to pay when all conditions under the policy would require an insurer exercising good faith and fair dealing toward its insured to pay. See Vest v. Travelers Insurance Company, 753 So.2d 1270 (Fla. 2000). Denial of payment does not mean an insurer is guilty of bad faith as a matter of law. The insurer has a right to deny claims that it in good faith believes are not owed on a policy. See id at 1275. Here, based on the good faith investigation of this claim, Security First concluded that coverage does not apply to the subject loss claimed by BRANNON AND AMY HOLT that were clearly excluded by the contract (insurance policy). Security First is not required to indemnify an insured for damages that are clearly and unambiguously excluded by the insurance contract, i.e. Security First’s obligation to settle this claim has not been triggered. Security First first received notice of the subject loss on September 29, 2024 with a reported date of loss of September 26, 2024. Security First’s investigation immediately ensued. As part of Security First’s investigation, a licensed professional engineer, Ryan Gissal inspected the subject property on October 2, 2024 and a licensed field adjuster, Carla Davis, inspected the subject property on October 5, 2024. Based upon the information gathered during the claims investigation, and the policy in question, coverage was not afforded and a coverage determination letter was sent on or about November 2, 2024. Said letter stated in pertinent part that: “We are writing to inform you that we have concluded our investigation into your claim, and it is our determination that this loss is not covered by your Dwelling Property 3 Special Form policy. In that regard, here is how we made our decision regarding your policy’s coverage of this loss: The investigation of your claim began on September 29, 2024, when you reported wind damage to your dwelling with a date of loss of September 26, 2024. As part of the initial investigation, SFI assigned a Field Adjuster to inspect your property. 1. SFI’s field adjuster performed their inspection of the exterior and interior on October 5, 2024. During their inspection, the field adjuster observed the following: a. The inspection total loss of the dwelling due to flood and storm surge from Hurricane Helene. 2. Independent Forensics Group performed an inspection on October 2, 2024. During their inspection, the Engineer observed the following: a. The inspection revealed there was high-water level at approximately 8 feet or more above grade. b. The proximate cause of damage to the property, including all major structural and cladding components, is the result of rising water due to the storm surge. We then carefully reviewed all the facts and information we gathered during our investigation. We also reviewed the language in your insurance policy to determine whether it covers the situation based on the facts we uncovered. Based on the investigation, we have determined that your policy does not provide coverage for your loss. In particular, we found no signs of wind or hail damage to the roof or exterior, nor any openings caused by storms that allowed water to enter and cause subsequent damage to the interior. Additionally, your policy excludes coverage for damages solely caused by flooding, storm surge, water overflow from any body of water, or similar forms of water intrusion from the surface or ground. This includes instances where water enters directly into a building, backs up through sewers or drains, and any resulting damage from materials carried by the water. The inspection(s) of your property determined that your damages were solely due to such water intrusion rather than hurricane-force winds or any other covered event. Therefore, we regret to inform you that there is no coverage for this claim. Please see the following sections in the Dwelling Property 3 Special Form, SFI FL DF3D 12 20, endorsed by Special Provisions – Florida, SFI FL DF3 SP 07 21, which states in part: GENERAL EXCLUSIONS 1. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. … c. Water Damage, meaning: (1) Flood, surface water, waves, tidal waves, tsunami, tides, tidal water, storm surge, overflow of any body of water, or spray from any of these, whether or not driven by wind, including storm surge; (2) Water, water-borne material, sewage or any other substance which backs up through sewers or drains; (3) Water, water-borne material, sewage or any other substance that overflows from a sump pump, sump pump well or other system designed for the removal of subsurface water which is drained from a foundation area of a structure; (4) Water, water-borne material, sewage or any other substance on or below the surface of the ground, regardless of its source. This includes water or any other substance which exerts pressure on or flows, seeps or leaks through a building, sidewalk, driveway, foundation, swimming pool or other structure; (5) Water-borne material, sewage or any other substance, carried or otherwise moved by any of the water referred to in c.(1) through c.(4) of this exclusion; (6) Escape, overflow or discharge, for any reason, of water, water-borne material, sewage, or any other substance from a dam, levee, seawall or other boundary or containment system. However, direct loss by fire, explosion or theft resulting from water damage is covered. Exclusion 1.c.(2), 1.c.(3) and 1.c.(5) do not apply to the extent coverage is provided in Additional Coverages, 13. Water Back Up and Sump Overflow. Based on the aforementioned, Security First continues to stand firm on the coverage determination of the subject claim that there was no coverage pursuant to the conditions, limitations, exclusions of the subject insurance policy. Security First denies that any of its actions have resulted in any violation of Florida law, including any provisions of Florida Statute Sections 624.155 or 626.9541, as alleged in the CRN, or any other Florida statute or law. Contrary to the allegations in the CRN, Security First has not engaged in unfair trade practices, indeed properly investigated the claim prior to its decision. Security First issued a coverage decision pursuant to the terms and conditions of the subject policy. Security First did not come to a coverage decision without first conducting a reasonable investigation. Additionally, the Civil Remedy Notice of Insurer Violations fails to adequately or sufficiently describe the alleged violations and fails to provide any facts supporting the alleged violations of the Florida Statutes, regarding Claim Denial, Claim Delay, Unfair Trade Practice, Violation of Adjusters' Ethical Requirements, other than bald and conclusory allegations. The Civil Remedy Notice of Insurer Violations also fails to identify any specific policy language with which Security First has failed to comply, and merely cites general headings and titles as previously mentioned. Although this is important because Security First is unable to discern a cure to remedy the allegations. The CRN fails to establish a basis for coverage and specific acts during the investigation as unreasonable in relation to applicable policy provisions providing indemnification. Further, the Civil Remedy Notice of Insurer Violations fails to provide sufficient information to allow Security First to resolve the alleged violation. Overall, the CRN fails to provide a discernable cure as a result of the alleged violation considering the vague conclusory statement, lack of specific policy language, failure to assert facts regarding extra contractual damages and how any one individual, purportedly the “unqualified” individual that is “unknown” contributed to the alleged violations. Section 624.155, Florida Statues, is intended to allow an Insurer one last opportunity to remedy an alleged violation prior to the filing of any bad-faith lawsuit. This is known as the discernable cure requirement. Specific facts and recitation of specific policy language allows an Insurer to identify a cure demanded, and there is no requirement that the Complainant provide a specific demand. At all times, Security First has acted in good faith in its handling of the claim and it has acted fairly, honestly, and with due regard for the Complainant’s interest and in determining obligations to Complainant. Sincerely, _______________________ John Joiner W166594 Security First Insurance Company P.O. Box 105649 Atlanta, GA 30348-5649 jjoiner@securityfirstflorida.com Telephone Number: 386-868-1221
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