The Seal of the State of Florida, featuring a central shield with a sun rising over a body of water, surrounded by a circular border with the words "SEAL OF THE STATE OF FLORIDA" and "IN ODO WE TRUST".

Seal of the State of Florida

OFFICE OF INSURANCE REGULATION

MICHAEL YAWORSKY

COMMISSIONER

Index: OIR 2026-21

CASE NO.: 402580-26-CO

IN THE MATTER OF:

MANATEE INSURANCE EXCHANGE

_____/

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 23, 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)(q)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. 401992-25,

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

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.

1. MANATEE is a Florida-domiciled property and casualty reciprocal insurer authorized to transact insurance in the State of Florida.

2. On or about January 23, 2026, MANATEE submitted a proposal to assume selected policies from CITIZENS. The policies are expected to be assumed on or about June 16, August 18, and September 15, 2026, and the proposal provides for an assumption of up to 100,000 policies, consisting of 88,000 personal residential multi-peril policies and 12,000 personal residential wind-only policies from the CITIZENS' Account across all referenced assumption periods. MANATEE's preferred policy selections during any individual assumption period shall not exceed 50% of the total policies approved to be assumed across all assumption periods.

3. MANATEE understands that the selected policies to be assumed from CITIZENS on June 16, August 18, and September 15, 2026, or at a later date approved by the OFFICE and CITIZENS will not be subject to any incentive or bonus plan, whether statutory or otherwise.

4. 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, includes the same major covered perils at substantially similar levels of coverage as that 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.

5. Because of the potential harmful impact to Florida policyholders, MANATEE shall not make take-out offers to CITIZENS policyholders that are more than 40% higher than the

policyholder's estimated renewal premium with CITIZENS. MANATEE must use either rates that have 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.

1. 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.

2. 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.

3. 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 profiles were based upon MANATEE's current in-force book of property policies, MANATEE's projected voluntary market writings, and 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.

4. 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 five (5) above. Each additional assumption of CITIZENS policies by MANATEE shall be subject to advance written approval by the OFFICE.

5. 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.

6. MANATEE understands that it must send communications 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.

7. MANATEE agrees that any such policyholder communication related to the assumption of CITIZENS policies on June 16, August 18, and September 15, 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.

8. 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 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.

9. 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.

10. The parties agree that 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 that the signature of its representative as affixed to this Consent Order shall be under seal of a Notary Public.

11. 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 five (5), in accordance with any agreements between MANATEE and CITIZENS, and this Consent Order.

• (C) Regarding all reinsurance matters, MANATEE shall:
• (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 sixty 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 either at rates that have 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 policy 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

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 three (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 sixty days to cure its material non-compliance. In the event MANATEE fails to cure any such material non-compliance within the sixty-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 100,000 policies, consisting of 88,000 personal residential multi-peril policies and 12,000 personal residential wind-only policies from the CITIZENS' Account across all assumption periods occurring on or about June 16, August 18, and September 15, 2026, subject to the terms and conditions of this Consent Order, is hereby APPROVED.

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

DONE and ORDERED this 16 day of March, 2026.

The seal of the Office of Insurance Regulation, State of Florida. It is a circular emblem with a serrated outer edge. The words "OFFICE OF INSURANCE REGULATION" are written in a circular border at the top, and "STATE OF FLORIDA" at the bottom. In the center of the seal, there is a depiction of a figure, likely a deity or a personification of justice, holding a staff and a shield, surrounded by other symbols.

Seal of the Office of Insurance Regulation, State of Florida

Michael Yaworsky, Commissioner

Office of Insurance Regulation

By execution hereof, MANATEE RISK MANAGEMENT, LLC, as attorney-in-fact of MANATEE INSURANCE EXCHANGE, consents to entry of this Consent Order, agrees without reservation to all of the above terms and conditions, and shall be bound by all provisions therein. 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 FL

COUNTY OF Hillsborough

The foregoing instrument was acknowledged before me by means of physical presence

or online notarization, this 12 day of March 2026, by David Flitman

(name of person)

as President for Manatee Insurance Exchange

(type of authority; e.g., officer, trustee, attorney-in-fact) (company name)

(Signature of the Notary)

Nicole Pirolo

(Print, Type or Stamp Commissioned Name of Notary)

Personally Known V OR Produced Identification _____

Type of Identification Produced _____

My Commission Expires: 1/5/2027

Notary Public Seal for Nicole Pirolo, State of Florida, Commission Number HH 345955, Expires 1-5-2027

COPIES FURNISHED TO:

Judy Grunewald, Assistant Director

Depopulation & FMAP

Citizens Property Insurance Corporation

2101 Maryland Circle

Tallahassee, FL 32303

Judy.Grunewald@citizensfla.com

David Flitman, President

Manatee Risk Management, LLC

12640 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@flor.com

Bradley Trim, Director

P&C Financial Oversight

Office of Insurance Regulation

200 East Gaines Street

Tallahassee, FL 32399

Bradley.Trim@flor.com

Corey Hubbard, Chief Analyst

P&C Financial Oversight

Office of Insurance Regulation

200 East Gaines Street

Tallahassee, FL 32399

Corey.Hubbard@flor.com

Jeffrey Joseph

Assistant General Counsel

Office of Insurance Regulation

200 East Gaines Street

Tallahassee, FL 32399

Jeffrey.Joseph@flor.com