Adrian Choulagh Insurance License Revoked for Exam Fraud

STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES Before the Director of the Department of Insurance and Financial Services

In the matter of:

Adrian Choulagh Enforcement Case No. 25-18849

System ID No. 0958067 Respondent.

_______________________/ Issued and entered on April 20, 2026 by Joseph Garcia Senior Deputy Director, and General Counsel ORDER ACCEPTING STIPULATION

Based upon the Stipulation to Entry of Order and the files and records of the Department of Insurance and Financial Services (DIFS) in this matter, the Senior Deputy Director finds and concludes that:

1. The Senior Deputy Director has jurisdiction and authority to adopt and issue this Order Accepting Stipulation in this proceeding pursuant to the Michigan Administrative Procedures Act of 1969 (APA), as amended, MCL 24.201 et seq., and the Michigan Insurance Code of 1956 (Code), MCL 500.100

et seq.

1. All required notices have been issued in this case, and the notices and service thereof were
   appropriate and lawful in all respects.

2. Acceptance of the Stipulation to Entry of Order is reasonable and in the public interest.

3. All applicable provisions of the APA have been either satisfied or waived by all Parties.

4. On or about December 22, 2025, DIFS served a Notice of Opportunity to Show Compliance (NOSC)
   on Respondent. In the NOSC, DIFS asserted that Respondent provided justification for sanctions pursuant to Sections 1239(1)(a) and 1239(1)(g) of the Code, MCL 500.1239(1)(a) and MCL 500.1239(1)(g).

5. Respondent admits that sanctions are warranted under Section 1239(1)(a) of the Code, MCL
   500.1239(1)(a), because Respondent attempted to and did obtain a license through misrepresentation or fraud.

6. Respondent admits that sanctions are warranted under Section 1239(1)(g) of the Code, MCL
   500.1239(1)(g), because Respondent used fraudulent or dishonest practices and demonstrated untrustworthiness in the conduct of business.

Order Accepting Stipulation Enforcement Case No. 25-18849 Page 2 of 2

1. The Director is authorized to take disciplinary action against Respondent's insurance license in addition to the imposition of monetary penalties for the above-described statutory violations pursuant to Sections 1239 and 1244 of the Code, MCL 500.1239 and MCL 500.1244. Now therefore, based upon the Stipulation to Entry of Order and the facts surrounding this case, IT IS

ORDERED THAT:

1. All agreements contained in the Stipulation to Entry of Order are accepted and adopted in their
   entirety.

2. Respondent shall comply with all terms agreed to in the Stipulation to Entry of Order. A failure to
   comply with a term in the Stipulation shall be deemed a violation of this Order.

3. Respondent's license is hereby REVOKED, effective immediately.

4. Respondent shall not reapply for a license administered by the Michigan Department of Insurance
   and Financial Services. Any attempt to do so will constitute a violation of this Order and will result in the commencement of additional proceedings.

5. The Senior Deputy Director retains jurisdiction over the matters contained herein and has the
   authority to issue such further order(s) as shall be deemed just, necessary, and appropriate in accordance with the Michigan Insurance Code. Failure to abide by the terms and provisions of the Stipulation to Entry of Order and this Order may result in the commencement of additional proceedings.

____________________________________ Dated: April 20, 2026 Joseph A. Garcia Senior Deputy Director, and General Counsel

STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES Before the Director of the Department of Insurance and Financial Services

In the matter of:

Adrian Choulagh Enforcement Case No. 25-18849

System ID No. 0958067 Respondent.

_______________________/ STIPULATION TO ENTRY OF ORDER

Adrian Choulagh (Respondent) stipulates to the following:

1. Respondent had the opportunity to have this Order Accepting Stipulation and Stipulation to Entry of Order (collectively "Consent Order") reviewed by legal counsel.
2. Respondent has read and understands this Consent Order.

3. Respondent understands that Respondent has a right to a hearing before an administrative law
   judge, at which DIFS would be required to prove the charges set forth by presentation of evidence and legal authority and at which Respondent would be entitled to appear, to cross-examine all witnesses presented by DIFS, and to present such testimony or other evidence or legal authority deemed appropriate as a defense to said charges. Respondent understands and intends that by agreeing to the Consent Order, Respondent is knowingly and voluntarily waiving Respondent's right, pursuant to the Michigan Insurance Code of 1956 (Code), MCL 500.100 et seq., the rules promulgated thereto, and the Administrative Procedures Act (APA), MCL 24.201 et seq., to a hearing before an Administrative Law Judge.

4. Respondent agrees that all parties have complied with the procedural requirements of the APA and
   the Code.

5. The Senior Deputy Director retains jurisdiction over the matters contained herein.

6. On or about December 22, 2025, the Department of Insurance and Financial Services (DIFS) served
   Respondent with a Notice of Opportunity to Show Compliance (NOSC) alleging that Respondent committed conduct warranting disciplinary action against Respondent's license and monetary penalties pursuant to Sections 1239 and 1244 of the Code, MCL 500.1239 and MCL 500.1244.

7. Respondent admits to hiring and employing Alicia Jackson to take and pass an online proctored licensing exam on Respondent's behalf, justifying sanctions under Sections 1239(1)(a), 1239(1)(g),
   and 1244 of the Code.

8. Respondent agrees that, in lieu of further disciplinary action, Respondent's license shall be revoked,
   effective immediately upon entry of the Consent Order.

4/14/2026