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Polsinelli - Third Party Administrator (TPA) Licensing and Compliance Services Polsinelli - Third Party Administrator (TPA) Licensing and Compliance Services

February 2018


Florida Regulatory Action a Reminder that TPAs Must Be Licensed Before Conducting Business






Third Party Administrator Licensing and Compliance Professionals:


Steven L. Imber

Insurance Group Chair


Email | Bio

Member of the Federation of Regulatory Counsel (FORC)


Justin T. Liby


Email | Bio


Jennifer Osborn Nix


Email | Bio



To learn more about our TPA Licensing and TPA Compliance Services, click here.



To learn more about our Insurance Business and Regulatory Law practice, click here.



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A recent regulatory action against a Delaware domiciled TPA ("Company") demonstrates the importance for companies to be properly licensed with state insurance regulators where they are conducting business.

In June 2017, the Florida Office of Insurance Regulation ("OIR") denied an application submitted by the Company's parent for licensure as a TPA based on the OIR's determination that all information required to process the application had not been provided. In June 2017, the denial was appealed with the Florida Division of Administrative Hearings to preserve all rights. On October 4, 2017, the OIR withdrew its prior denial of the TPA license application.

On February 14, 2018, the OIR entered into a Consent Order granting the Company a TPA license. However, in the Consent Order, the OIR determined the Company had previously administered business on behalf of authorized insurers with respect to Florida residents, in violation of Section 626.8805 Florida Statutes. The determination that the Company had been administering business in violation of Section 626.8805 Florida Statutes was based on the OIR's review of fourteen (14) administrative agreements under which the Company had been conducting business prior to submitting its TPA application to the OIR.

As a result of this finding, the Company was assessed a fine of $140,000, pursuant to Section 626.8805(l) Florida Statutes.

For More Information on our TPA Team

Polsinelli’s TPA team provides TPA licensing services, legislative monitoring services, drafting and negotiating of administrative services agreements, and a number of other TPA regulatory and compliance services. Our TPA team includes attorneys who were former in-house counsel for TPAs, as well as attorneys who were formerly insurance regulators.

By leveraging its extensive experience representing TPAs, the Polsinelli team helps clients avoid the learning curve and related cost implications that can be experienced by working with companies or attorneys less familiar with regulatory and compliance needs of TPAs.

For questions regarding this information, please contact one of the authors, a member of Polsinelli’s Third Party Administrators practice, or your Polsinelli attorney.











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