Insurance Producer License Revoked for Consent Violations

STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES Before the Director of the Department of Insurance and Financial Services In the matter of: Samuel Christmas Enforcement Case No. 25-18214 System ID No. 0082669 Respondent. ____________________/ Issued and entered On April __, 2026 By Joseph A. 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), MCL 24.201 et seq., and the Michigan Insurance Code of 1956 (Code), MCL 500.100 et seq.

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

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

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

5. On or about April 16, 2025, DIFS served a Notice of Opportunity to Show Compliance (NOSC) on
   Respondent. In the NOSC, DIFS asserts that Respondent violated Section 2003(1) of the Code, MCL 500.2003(1), by engaging in practices that constitute an unfair method of competition and/or deceptive acts or practices in the business of insurance as defined by MCL 500.2018, by submitting enrollment and/or change in enrollment documents without the knowledge or consent of the insured. The NOSC further alleged that Respondent provided justification for sanctions pursuant to Section 1239(1)(f), (1)(g), (1)(h), and Section 1239(2)(e) of the Code, MCL 500.1239(1)(f), (1)(g), (1)(h), and (2)(e).

6. Respondent admits to the allegations contained in the NOSC and agrees to the revocation of his
   insurance producer license as the sole regulatory penalty for said violations.

Order Accepting Stipulation Enforcement Case No. 25-18214 Samuel Christmas Page 2 of 2

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 insurance producer license is hereby REVOKED, effective immediately.

4. 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.

_______________________________________ 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: Samuel Christmas Enforcement Case No. 25-18214 System ID No. 0082669 Respondent. _______________________/ STIPULATION TO ENTRY OF ORDER Samuel Christmas (Respondent) stipulates to the following:

1. Respondent has 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 reviewed and voluntarily consented to the entry of the Order Accepting Stipulation
   that will be entered in this enforcement case and understands and agrees that the findings contained in this Order may be taken as true in this or any other DIFS proceeding.

3. This enforcement proceeding is currently before Administrative Law Judge David B. Marmon in
   Docket No. 25-029208. An evidentiary hearing was scheduled for February 9, 2026. Respondent has elected to waive his right to hearing and resolve this enforcement proceeding through this Consent Order.

4. Respondent understands that Respondent had 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 Administrative Law Judge David B. Marmon.

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

6. On or about April 16, 2025, DIFS served a Notice of Opportunity to Show Compliance (NOSC) on
   Respondent. In the NOSC, DIFS asserts that Respondent violated Section 2003(1) of the Code, MCL 500.2003(1), by engaging in practices that constitute an unfair method of competition and/or deceptive acts or practices in the business of insurance as defined by MCL 500.2018, by submitting

Stipulation to Entry of Order Enforcement Case No. 25-18214 Samuel Christmas Page 2 of 2

enrollment and/or change in enrollment documents without the knowledge or consent of the insured. The NOSC further alleged that Respondent provided justification for sanctions pursuant to Section 1239(1)(f), (1)(g), (1)(h), and Section 1239(2)(e) of the Code, MCL 500.1239(1)(f), (1)(g), (1)(h), and (2)(e).

1. Respondent admits to the violations alleged in the NOSC. Respondent agrees to the terms of this
   Stipulation and the revocation of his insurance producer license in order to avoid potential civil fines and the added cost of litigation.

2. Respondent agrees that DIFS will revoke his insurance producer license immediately upon the
   execution of the Order Accepting Stipulation. Respondent agrees to cease and desist from all activity that would require an insurance producer license.

3. Respondent understands that this Stipulation to Entry of Order will be presented to the Senior Deputy
   Director for approval and that the Senior Deputy Director may or may not approve and adopt it.

4. Respondent further agrees that the Senior Deputy Director has jurisdiction and authority to approve
   and adopt this Stipulation to Entry of Order.

5. Respondent waives any objection to the Director deciding the case following a Michigan Office of
   Administrative Hearings and Rules hearing in the event that the Stipulation to Entry of Order is not approved.

__________________________________ _____________________ Samuel Christmas Date Respondent

DIFS Staff approve this Stipulation and recommend that the Senior Deputy Director accept it and issue an Order Accepting Stipulation.

__________________________________ _____________________ Diego R. Avila (P72657) Date DIFS Staff Attorney

4-7-20264-6-2026Samuel Christmas w/permission granted 4-6-2026