OFFICE OF INSURANCE REGULATION

FILED
JAN 28 2026

INSURANCE REGULATION
Dated by:

MICHAEL YAWORSKY
COMMISSIONER

IN THE MATTER OF:

ARIZONA PREMIUM FINANCE CO., INC.

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CEASE AND DESIST COMPLAINT

TO:
ARIZONA PREMIUM
FINANCE CO., INC.
c/o Sharon Rosenblum
1885 Loma Vista Drive
Beverly Hills, CA 90210

ARIZONA PREMIUM
FINANCE CO., INC.
c/o Allan Rosenblum, Statutory Agent
12406 N 32nd Street #110
Phoenix, AZ 85032

Pursuant to the Florida Insurance Code, including but not limited to sections 624.307,
624.310, 624.317, and 627.828, Florida Statutes,¹ the FLORIDA OFFICE OF INSURANCE
REGULATION ("the OFFICE") investigated the activities of ARIZONA PREMIUM FINANCE
CO., INC. ("APFC") with respect to premium finance business activities. Accordingly, the
OFFICE issues this Complaint alleging that since 2017 APFC knowingly funded hundreds of
premium finance agreements in Florida without a requisite Certificate of Authority. § 624.310(3),
627.828, 627.848, Fla. Stat. As grounds therefore, the OFFICE alleges that:

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

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Jurisdiction

1. Section 20.121(3)(a)1. provides, in part, that the OFFICE shall be responsible for
   all activities concerning insurers and other risk bearing entities, including licensing, rates, policy
   forms, market conduct, and claims.

2. Section 624.01 provides that chapters 624-632, 634, 635, 636, 641, 642, 648, and
   651 constitute the "Florida Insurance Code."

3. The OFFICE has jurisdiction over the subject matter hereof and parties herein
   pursuant to sections 20.121(3)(a)1., 624.307, 624.310, 624.401, and 627.828.

Findings of Fact

1. APFC's principal place of business is located at 12406 N. 32nd Street, #110,
   Phoenix, Arizona 85032.

2. APFC is a domestic for-profit business incorporated in Arizona. Allan Rosenblum
   is the statutory agent of APFC. Sharon Rosenblum is a Director, Officer, and Shareholder of
   APFC.

3. APFC is not currently a registered corporation in Florida.

4. APFC is not licensed as a premium finance company in Florida.

5. APFC is not an authorized insurer in Florida.

6. On October 29, 2024, County Hall Insurance Company ("County Hall") submitted
   a complaint to the OFFICE. The Complaint alleged APFC sought to cancel seven commercial auto
   policies that were insured by County Hall. Based on this information, the OFFICE initiated an
   investigation against APFC.

7. On November 5, 2024, County Hall provided the OFFICE with a list of 352 Florida
   policies financed by APFC with effective inception dates ranging from July 11, 2017, through
   December 22, 2023. The 352 Florida policies amass a total of $8,404,008.00 in written premiums.

8. On November 5, 2024, County Hall informed the OFFICE that APFC bound nine
   Florida policies after September 2024. County Hall further advised that APFC declined to fund
   the policy premiums until County Hall cancelled certain Florida policies.

Conclusions of Law

1. Section 624.04 defines "person," as used in the Florida Insurance Code, to include
   "an individual, insurer, company, association, organization, Lloyd's, society, reciprocal insurer or
   interinsurance exchange, partnership, syndicate, business trust, corporation, agent, general agent,
   broker, service representative, adjuster, and every legal entity."

2. Section 627.826 defines "insurance premium finance company" to include persons
   engaged "in the business of entering into premium finance agreements with insureds" or "in the
   business of acquiring premium finance agreements from other premium finance companies."
   Section 627.827 defines a "premium finance agreement" to include "a promissory note or other
   written agreement by which an insured promises or agrees to pay to, or to the order of, a premium
   finance company the amount advanced or to be advanced under the agreement to an insurer or to
   an insurance agent, in payment of premiums on an insurance contract, together with a service
   charge as authorized and limited by law."

3. Section 627.828(1) states that "no person shall engage in the business of a premium
   finance company unless licensed by the office."

4. APFC violated section 627.828(1) by engaging in the business of a premium
   finance company without a license or certificate of authority issued by the OFFICE.

5. APFC's activities do not fall within the exceptions, exclusions or exemptions
   provided in sections 627.901 and 627.902 or any other provision of the Florida Statutes or federal
   law.

6. APFC is an unlicensed person subject to the jurisdiction of the OFFICE pursuant
   to sections 624.04, 627.828, and 20.121(3)(a)1.

7. Section 624.310(3) authorizes the OFFICE to serve a complaint upon any
   unlicensed person whenever the OFFICE has reasonable cause to believe that the party is engaging
   or has engaged in conduct that is:
   a. An act that demonstrates a lack of fitness or trustworthiness to engage
   in the business of insurance, is hazardous to the insurance buying public,
   or constitutes business operations that are a detriment to policyholders,
   stockholders, investors, creditors, or the public;
   b. A violation of any provision of the Florida Insurance Code;
   c. A violation of any rule of the department or commission;
   d. A violation of any order of the department or office; or
   e. A breach of any written agreement with the department or office.

8. In addition to licensees and affiliated party's, section 624.310 applies to unlicensed
   persons subject to the regulatory jurisdiction of the OFFICE. See 624.310(2)(a), Fla. Stat.
   (emphasis added).

Notice of Statutory Penalties

1. The OFFICE will enter a Cease and Desist Final Order in this matter.

2. Pursuant to section 624.310(3), the OFFICE may order APFC to
   cease and desist acting as a premium finance company in Florida without a license or certificate
   of authority.

3. Pursuant to section 624.310(3)(c), the Cease and Desist Final Order may require
   APFC to take corrective action to remedy the effects of past improper conduct and assure future
   compliance. Such corrective action may include requirements that APFC comply with all

requirements of the Florida Insurance Code, including that APFC obtain an appropriate license or
certificate of authority to act as a premium finance company.

1. Pursuant to sections 624.310(5) and 624.4211, the OFFICE may impose an administrative fine against APFC. For each non-willful violation, the OFFICE may impose an administrative fine of twelve thousand five hundred dollars, up to an aggregate amount of $50,000 for all other non-willful violations arising out of the same action. For each willful violation, the OFFICE may impose an administrative fine of one thousand thousand dollars, up to an aggregate amount of $500,000 for all other knowing and willful violations arising out of the same action. Additionally, the OFFICE may order APFC to provide restitution to all persons affected by APFC's violations of the Florida Insurance Code.

Proposed Agency Action

WHEREFORE, because APFC has violated the Florida Insurance Code by operating as a
premium finance company in Florida in violation of section 627.828(1), the OFFICE intends to
issue a Cease and Desist Final Order requiring the following:

A. APFC is ordered, pursuant to sections 624.310(2), (3) and 627.828(1) to cease and desist
from engaging in the business of a premium finance company in Florida without a license.

B. APFC shall honor all current and future obligations and liabilities arising from its
operations in Florida and will pay all obligations and liabilities that have arisen or may arise from
its operations in Florida. If any court or administrative action, arbitration, mediation, or other
judicial or quasi-judicial action listing APFC as a party is filed in Florida, APFC shall provide
written notice to the OFFICE within thirty days of the filing of such action.

C. APFC shall provide the OFFICE with monthly reports of all Florida premium finance
agreements remaining in-force until all premium finance agreements have lapsed, expired, or been

cancelled. Each report shall contain the parties to the premium finance agreement. The first report
will be due thirty days following the issuance of the Cease and Desist Final Order. Thereafter,
APFC will provide monthly reports.

D. APFC is responsible for administering and servicing existing premium finance
agreements in Florida.

E. APFC may be subject to additional administrative fines, corrective action, and
restitution based on the OFFICE's findings.

DONE and ORDERED this 28 day of January, 2026.

MICHAEL YAWORSKY
Commissioner
Office of Insurance Regulation

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NOTICE OF RIGHTS

Pursuant to sections 120.569 and 120.57 and Rule chapter 28-106, Florida Administrative Code
(F.A.C.), you may have a right to request a proceeding to contest this action by the Office of
Insurance Regulation (hereinafter the "Office"). Pursuant to Rule 28-106.106, F.A.C., only
qualified representatives or counsel licensed by the Florida Bar may represent a party in an agency
proceeding. If you intend to participate in the proceeding as a qualified representative, you must
file the appropriate request pursuant to Rule 28-106.106(2)(a), F.A.C. You may request a
proceeding by filing a Petition. Your Petition for a proceeding must be in writing and must be
filed with the General Counsel acting as the Agency Clerk, Office of Insurance Regulation. If
served by U.S. Mail the Petition should be addressed to the Florida Office of Insurance Regulation
at 612 Larson Building, Tallahassee, Florida 32399-0300. If Express Mail or hand delivery is
utilized, the Petition should be delivered to 612 Larson Building, 200 East Gaines Street,
Tallahassee, Florida 32399-0300. The written Petition must be received by and filed with the
Office no later than 5:00 p.m. on the twenty-first (21) day after your receipt of this notice. Unless
your Petition challenging this action is received by the Office within twenty-one (21) days from
the date of the receipt of this notice, the right to a proceeding shall be deemed waived. Mailing the
response on the twenty-first day will not preserve your right to a hearing.

If a proceeding is requested and there is no dispute of material fact, the provisions of section
120.57(2) may apply. In this regard you may submit oral or written evidence in opposition to the
action taken by this agency or a written statement challenging the grounds upon which the agency
has relied. While a hearing is normally not required in the absence of a dispute of fact, if you feel
that a hearing is necessary, one may be conducted in Tallahassee, Florida or by telephonic
conference call, upon your request.

If you dispute material facts which are the basis for this agency's action, you may request a formal
adversarial proceeding pursuant to sections 120.569 and 120.57(1). If you request this type of
proceeding, the request must comply with all of the requirements of Rule 28-106.2015, F.A.C.,
including but not limited to:

a) A statement requesting an administrative hearing identifying those material facts
that are in dispute. If there are none, the petition must so state; and

b) A statement of when the respondent received notice of the agency's action.

These proceedings are held before a State Administrative Law Judge of the Division of
Administrative Hearings. Unless the majority of witnesses are located elsewhere, the Office will
request that the hearing be conducted in Tallahassee.

In some instances, you may have additional statutory rights than the ones described herein.

Failure to follow the procedure outlined with regard to your response to this notice may result in
the request being denied. Any request for administrative proceeding received prior to the date of
this notice shall be deemed abandoned unless timely renewed in compliance with the guidelines
as set out above.

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Cease and Desist
Complaint has been sent by U.S. Certified Mail this 28th day of January, 2026, to:

ARIZONA PREMIUM
FINANCE CO., INC.
c/o Sharon Rosenblum
1885 Loma Vista Drive
Beverly Hills, CA 90210

ARIZONA PREMIUM
FINANCE CO., INC.
c/o Allan Rosenblum, Statutory Agent
12406 N 32nd Street #110
Phoenix, AZ 85032

/s/ Justin P. Ravelo
JUSTIN P. RAVELO
Florida Bar No. 1022417
Office of Insurance Regulation
200 East Gaines Street
Tallahassee, Florida 32399-4206
Email: Justin.Ravelo@floir.com
Telephone: (850) 413-5147