Florida’s financial services regulatory environment is technical and not easy to navigate from the outside. Capital City Consulting brings firsthand experience within that structure, including a former staffer at the Department of Insurance–now the Office of Insurance Regulation–and a former member of the Department of Financial Services’ leadership team.
Capital City Consulting represents banks, credit unions, consumer finance companies, and insurers before the Florida Legislature, the Department of Financial Services, and the Offices of Insurance and Financial Regulation. The team includes former DFS leadership and has led on a number of issues, including consumer finance regulatory complexities, ensuring public deposits can be accepted by credit unions, and niche specialty work for various warranty products.
- Advocated for market-based broker fees, removing governmental fee structures
Florida’s surplus lines insurance market services large, exotic, and emerging risks. Previously, the government regulated broker fees, which decreased appetite to compete for smaller premiums risks. In its representation of the surplus lines industry, CCC was able to remove this government restriction, allowing free and fair competition on not just premium, but also broker services and fees. This has increased competitive quoting activity for risks, and ensured that the nonadmitted market can support all risks that are declined or unable to be supported by authorized carriers.
- Created new licensure pathways for warranties
Consumers often buy motor vehicle financial products to protect their investment. These include debt waivers, depreciation benefits, and trade-in credits. Prior to CCC’s engagement, guaranteed asset protection products were the only permissible offering, which is not necessarily well-suited for all consumers. Accordingly, a bill was crafted, and passed, which authorized both vehicle value protection agreements and excess wear & use waivers, affording consumers afforded additional investment protection options. Additionally, this legislation codified important consumer disclosures, a free-look period for each new product, and regulatory penalties for unauthorized sales or regulatory noncompliance.
- Modernized laws related to lender place/collateral protection insurance
Collateral protection insurance—also known as lender-placed insurance—is regulated at the state and federal levels. Importantly, this product provides property insurance coverage for those whose coverage may have lapsed, protecting both a homeowner’s investment, as well as a lender’s security interest. CCC led the effort to adopt a NAIC Model Law, which included restrictions on the sharing of commissions, the promotion of dual coverage policies, the implementation of a standard rate review process, and clarity around when coverage terminates after a homeowner regains primary coverage. These consumer protections improve accountability in this marketplace, while also increasing regulatory clarity for insurers offering this necessary product.