OFFICE OF INSURANCE REGULATION

FILED

JAN 15 2026

INSURANCE REGULATION
Document Services

MICHAEL YAWORSKY
COMMISSIONER

IN THE MATTER OF:

MANATEE INSURANCE EXCHANGE

Index: OIR 26-2
CASE NO.: 402408-26-CO

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CONSENT ORDER

THIS CAUSE came for consideration as a result of MANATEE INSURANCE EXCHANGE’S (“MANATEE”) proposal to assume selected personal lines policies from CITIZENS PROPERTY INSURANCE CORPORATION (“CITIZENS”), which was submitted to the FLORIDA OFFICE OF INSURANCE REGULATION (“OFFICE”) for its review on or about January 6, 2026. Following a complete review of the entire record and upon consideration thereof, and otherwise being fully advised in the premises, the OFFICE hereby finds as follows:

1. The OFFICE has jurisdiction over the subject matter and the parties herein.
2. CITIZENS has been established in accordance with the provisions of section 627.351(6), Florida Statutes (2025)¹, as amended, to provide insurance for residential and commercial property qualified risks under circumstances specified in the statute.
3. The Florida Legislature enacted sections 627.351(6)(j)3.a. and 627.351(6)(ii)3., to encourage and provide a means for the depopulation of CITIZENS. Pursuant to this legislation, CITIZENS submitted a depopulation plan titled “Citizens Property Insurance Corporation Depopulation Plan” (“Plan”), which the OFFICE approved and adopted by Order No. 40199-25.

[^1]: All statutory citations contained herein refer to Florida Statutes (2025), unless otherwise noted.

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on October 21, 2025. MANATEE shall abide by the terms and conditions of the Plan and section 627.351(6)(ii)3., as a condition for the issuance of this Consent Order.
4. MANATEE is a Florida-domiciled property and casualty reciprocal insurer authorized to transact insurance in the State of Florida.
5. On November 20, 2025, the OFFICE approved MANATEE to assume selected policies from CITIZENS for an assumption scheduled to occur on or about February 17, 2026. On or about January 6, 2026, MANATEE submitted a subsequent proposal to the OFFICE to assume selected policies from CITIZENS on or about April 21, 2026. This subsequent proposal provides for an assumption of up to 65,000 personal residential policies, consisting of 60,000 personal residential multi-peril policies and 5,000 personal residential wind-only policies from the CITIZENS’ Account across all of the above assumption periods. Therefore, MANATEE’s total policies to be assumed across the assumption periods occurring on or about February 17, 2026, and April 21, 2026, are not to exceed 65,000.
6. MANATEE understands that the selected policies to be assumed from CITIZENS on or about February 17, 2026, and April 21, 2026, or at a later date approved by the OFFICE and CITIZENS, will not be subject to any incentive or bonus plan, statutory or otherwise.
7. Coverage offered by MANATEE must be “comparable coverage” as required by section 627.351(6). MANATEE cannot establish comparable coverage through the offer of optional endorsements. Comparable coverage means, at a minimum, that the offer of coverage, without endorsements, include the same major covered peril levels of coverage that as already provided by CITIZENS. The premium calculation used to determine the 20% eligibility threshold detailed in section 627.351(6) must be calculated using offers of coverage that are comparable without the need to offer additional terms or endorsements.

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1. Because of the potential harmful impact to Florida policyholders, MANATEE shall not make takeout offers to CITIZENS policyholders that are more than 40% higher than the policyholder’s estimated renewal premium with CITIZENS. MANATEE must use rates that have either been approved by the OFFICE or rates that have been filed with the OFFICE as “use and file” prior to the date by which MANATEE must provide to CITIZENS its preferred policy selections and estimated renewal premiums for the subject assumption period as specified in the 2026 Assumption Calendar published by CITIZENS. The estimated premium offered by MANATEE must reflect the cost of an offer of comparable coverage.
2. MANATEE is responsible for ensuring that it has entered or will enter into appropriate agreements with CITIZENS to effectuate the assumption of policies as authorized by this Consent Order. By entering into this Consent Order, MANATEE represents that it will comply with any such agreements between it and CITIZENS.
3. MANATEE must timely provide to CITIZENS all information required by the 2026 Assumption Calendar published by CITIZENS. MANATEE acknowledges that neither approval by CITIZENS nor entry into this Consent Order by the OFFICE constitutes a guarantee that the above-referenced policies will ultimately be available to MANATEE for assumption from CITIZENS, as the availability of policies for assumption may vary over time.
4. MANATEE shall limit its actual assumption of policies from CITIZENS to the number and type of policies authorized by the OFFICE in this Consent Order. The OFFICE based its review on MANATEE’s current and projected reinsurance programs, catastrophe modeling, and financial statement projections, as well as the impact on policyholders. Such reinsurance program, catastrophe modeling, and financial statement projections were based upon MANATEE’s current in-force book of property policies, MANATEE’s projected voluntary market writings, and

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the actual number of policies available in CITIZENS prior to the anticipated assumption date identified by MANATEE as satisfying its filed and approved underwriting guidelines.
12. MANATEE submitted the reinsurance documentation and financial projections for the assumption of up to the number and types of CITIZENS’ policies as set forth in paragraph 5 above. Each additional assumption of CITIZENS policies by MANATEE shall be subject to advance written approval by the OFFICE.
13. MANATEE’s acquisition of adequate reinsurance and maintenance of executed reinsurance agreements are material to the OFFICE’s review and analysis of MANATEE’s proposal to assume selected policies from CITIZENS and to the OFFICE’s approval of assumptions in the proposal.
14. MANATEE understands that it must send communication to selected CITIZENS policyholders that, at minimum, describes the purpose and function of a reciprocal and how a reciprocal differs from a property and casualty insurer, explains that the estimated renewal premium includes a 10% surplus contribution, and defines the surplus contribution and under what circumstances a subscriber would or would not receive a return of the surplus contribution.
15. MANATEE agrees that any policyholder communication related to the assumption of CITIZENS policies on February 17, 2026, and April 21, 2026, must be submitted to and receive approval by the OFFICE prior to being sent to selected CITIZENS policyholders, unless such policyholder communication has previously been approved by the OFFICE.
16. MANATEE expressly waives its right to any hearing in this matter, the making of findings of fact and conclusions of law by the OFFICE, and all other and further proceedings herein to which it may be entitled by law or by rules of the OFFICE. MANATEE agrees not to

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appeal or otherwise contest this Consent Order in any forum now or in the future available to it, including its right to any administrative proceeding, state or federal court action, or any appeal.
17. MANATEE represents that all explanations and documents made or submitted to the OFFICE as part of its proposal to assume selected policies from CITIZENS, including all attachments and supplements thereto, fully describe all transactions, agreements, and understandings relating to the assumption of policies from CITIZENS by MANATEE. However, all draft documents and non-executed agreements relating to MANATEE’s plan shall not be deemed approved by this Consent Order until such time as executed agreements or final documents are submitted to and approved by the OFFICE.
18. The parties agree this Consent Order will be deemed executed when the OFFICE has signed a copy of this Consent Order bearing the signature of the authorized representative of MANATEE, notwithstanding the fact that the copy was transmitted to the OFFICE electronically. MANATEE agrees the signature of its representative as affixed to this Consent Order shall be under seal of a Notary Public.
19. Each party to this action shall bear its own costs and attorney fees.

IT IS THEREFORE ORDERED that:

(A) Upon consideration of the proposal to assume selected policies from CITIZENS, including its attachments, the OFFICE approves the assumption of selected policies from CITIZENS, subject to adherence to the terms and conditions of this Consent Order by MANATEE.
(B) The OFFICE approves the assumption of CITIZENS’ policies up to the amounts set forth above in paragraph 5, in accordance with any agreements between MANATEE and CITIZENS, and this Consent Order.
(C) Regarding all reinsurance matters, MANATEE shall:

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(i) Secure and maintain catastrophe reinsurance at such levels that are acceptable to the OFFICE but in no event less than that evidenced to the OFFICE in the proposal to assume selected policies from CITIZENS;
(ii) Notify the OFFICE of any termination of any of its reinsurance agreements. The notification shall be made to the OFFICE in writing 60 days prior to the effective date of any such termination; and
(iii) Comply with the requirements of section 624.610 with regard to all of its reinsurance arrangements.
(D) MANATEE shall participate annually in any examination of MANATEE’s reinsurance program as requested by the OFFICE. Based upon the OFFICE’s review of the models and plans, MANATEE may be required at the OFFICE’s sole discretion to take corrective action to cure any overexposure identified by the OFFICE. Such action may include obtaining additional amounts of reinsurance coverage as directed by the OFFICE or suspending writing of any additional business, including the CITIZENS policies.
(E) Upon the expiration of the assumed CITIZENS policies, MANATEE shall provide coverage substantially equivalent to that afforded by CITIZENS at rates that have either been approved by the OFFICE or rates that have been filed with the OFFICE as “use and file,” unless such policies are cancelled or nonrenewed by MANATEE for a lawful reason.
(F) At the time MANATEE assumes any policy of insurance from CITIZENS, MANATEE shall either obtain a new policyholder application from each affected policyholder or maintain in its files a copy of the policyholder’s application on file with CITIZENS. If MANATEE chooses the former option, MANATEE may not initiate any retroactive increase in rates or

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premium or any retroactive decrease in coverage provided under the assumed CITIZENS policy (if applicable) as a result of the information obtained from or through the new policy application.
(G) For a period of 3 years immediately following the date of entry of this Consent Order, MANATEE shall abide by the proposal to assume selected policies from CITIZENS in all material respects. Further, MANATEE shall abide by all terms of this Consent Order and all provisions of any agreements entered into with CITIZENS.
(H) Should the OFFICE determine MANATEE has failed to materially comply with the terms of this Consent Order, the proposal to assume selected policies from CITIZENS, including its attachments and amendments thereto as submitted to the OFFICE, or terms of any agreements with CITIZENS, MANATEE shall, upon receipt of notice of such material non-compliance, have 60 days to cure its material non-compliance. In the event MANATEE fails to cure any such material non-compliance within the 60-day period, MANATEE expressly agrees the OFFICE may enter an order directing it to immediately cease writing personal lines or other lines of insurance within the State of Florida, imposing such other sanctions authorized by statute or rule, or imposing other restrictions as may be deemed appropriate by the OFFICE.

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WHEREFORE, the assumption of up to 65,000 policies, consisting of 60,000 personal residential multi-peril policies and 5,000 personal residential wind-only policies from the CITIZENS’ Account across all assumption periods occurring on or about February 17, 2026, and April 21, 2026, subject to the terms and conditions of this Consent Order, are hereby APPROVED.

FURTHER, all terms and conditions contained herein are hereby ORDERED.

DONE and ORDERED this 15 day of January, 2026.

[SEAL OF THE OFFICE OF INSURANCE REGULATION]

Michael Yaworsky, Commissioner
Office of Insurance Regulation

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By execution hereof, MANATEE RISK MANAGEMENT, LLC, as attorney-in-fact of MANATEE INSURANCE EXCHANGE, consents to entry of this Consent Order, agree without reservation to all of the above terms and conditions, and shall be bound by all provisions herein. The undersigned represents that they have the authority to bind MANATEE INSURANCE EXCHANGE to the terms and conditions of this Consent Order.

MANATEE RISK MANAGEMENT, LLC
Attorney-in-Fact

[Corporate Seal]

David Flitman, President
Manatee Risk Management, LLC

STATE OF FLORIDA
COUNTY OF Hillsborough

The foregoing instrument was acknowledged before me by means of physical presence
or online notarization, this 14th day of January, 2026, by David Flitman
(name of person)
as President (type of authority; e.g., officer, trustee, attorney-in-fact) for Manatee Risk Management, LLC
(company name)

Chelsea Harrelson
(Signature of the Notary)

Chelsea Harrelson
(Print, Type or Stamp Commissioned Name of Notary)

Personally Known X OR Produced Identification
Type of Identification Produced
My Commission Expires: 1-3-27

[NOTARY SEAL]

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COPIES FURNISHED TO:

Judy Grunewald, Assistant Director
Depopulation & FMAP
Citizens Property Insurance Corporation
2101 E. Maryland Circle
Tallahassee, FL 32303
Judy.Grunewald@citizensfla.com

David Flitman, President
Manatee Risk Management, LLC
1640 Telecom Drive
Temple Terrace, FL 33673
dflitman@safepointins.com

Jane Nelson, Deputy Commissioner
Property & Casualty
Office of Insurance Regulation
200 East Gaines Street
Tallahassee, FL 32399
Jane.Nelson@floir.com

Bradley Trim, Director
P&C Financial Oversight
Office of Insurance Regulation
200 East Gaines Street
Tallahassee, FL 32399
Bradley.Trim@floir.com

Corey Hubbard, Chief Analyst
P&C Financial Oversight
Office of Insurance Regulation
200 East Gaines Street
Tallahassee, FL 32399
Corey.Hubbard@floir.com

Stephanie Roman Caban
Assistant General Counsel
Office of Insurance Regulation
200 East Gaines Street
Tallahassee, FL 32399
Stephanie.RomanCaban@floir.com

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