Florida Statutes
Fla. Stat. § 627.786 (2025)
Transaction of title insurance and any other kind of insurance prohibited.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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627.786 Transaction of title insurance and any other kind of insurance prohibited.—
(1) An insurer may not transact title insurance and any other kind of insurance in this state.
(2) Subsection (1) does not apply to any insurer actively transacting title insurance and any other kind of insurance in this state on January 1, 1965.
(3) Subsection (1) does not preclude a title insurer from providing instruments to any prospective insured, in the form and content approved by the office, under which the title insurer assumes liability for loss due to the fraud of, dishonesty of, misappropriation of funds by, or failure to comply with written closing instructions by, its contract agents, agencies, or approved attorneys in connection with a real property transaction for which the title insurer is to issue a title insurance policy.
History.—s. 12, ch. 65-359; s. 3, ch. 76-168; s. 1, ch. 77-457; ss. 1, 2, ch. 79-16; ss. 2, 3, ch. 81-318; ss. 584, 809(2nd), ch. 82-243; s. 79, ch. 82-386; ss. 104, 114, ch. 92-318; s. 19, ch. 99-286; s. 1208, ch. 2003-261.
Notes of Decisions
Cited in 12
cases (1 in the last 5 years), 1976–2023 · leading case: Nunez v. Geico Gen. Ins., 117 So. 3d 388 (Fla. 2013).
Nunez v. Geico Gen. Ins., 117 So. 3d 388 (Fla. 2013). “The PIP Statute Section 627.786, Florida Statutes (2008), is silent regarding EUOs — it does not authorize their use, much less denial of benefits for failure to attend one.”
Geico Gen. Ins. Co. v. Virtual Imaging Servs., Inc., 141 So. 3d 147 (Fla. 2013). “§ 627.786(5)(a)2., Fla. Stat. (2008) (emphasis supplied).”
FCOA LLC v. Foremost Title & Escrow Servs. LLC, 57 F.4th 939 (11th Cir. 2023). “Fla. Stat. § 627.786 . 3 Enter FT&E. In 2015, two partners of the law firm Stok Folk + Kon, Robert Stok and Joshua Kon, set up FT&E as a Florida- based limited liability company.”
Sommers v. Smith & Berman, PA, 637 So. 2d 60 (Fla. 4th DCA 1994). “Section 627.786(3), Florida Statutes (1987) authorizes the title insurance company to assume responsibility for losses arising out of a closing by "providing instruments to any prospective insured, in the form and content approved by the department [of insurance].”
Altamonte Springs Imaging, L.C. v. State Farm Mut. Auto. Ins., 12 So. 3d 850 (Fla. 3d DCA 2009). “CPI, MRI, PIP, and Commonality The legislature enacted section 627.786(5)(b)5 in 2001 to provide consumer price index (CPI) adjustments for magnetic resonance imaging (MRI) reimbursements in personal injury protection (PIP) claims.”
Allstate Fire & Cas. Ins. Co. v. Perez, 111 So. 3d 960 (Fla. 2d DCA 2013). “As in this case, the insurer would have to look beyond the CPT code to determine whether the services represented in the code are reimbursable under Medicare Part B. We understand that this complicates the reimbursement process under the PIP statute.”
State Farm Mut. Auto. Ins. Co. v. Delray Med. Ctr., Inc., 178 So. 3d 511 (Fla. 4th DCA 2015). “Section 627.786(5) provides, in pertinent part: (5) Charges for treatment of injured persons.”
State Farm Mut. Auto. Ins. v. Nicholson, 337 So. 2d 860 (Fla. 2d DCA 1976). “The relevant statute in the Act is F.S. § 627.786(4)(d)(l) which provides that benefits obtain for, “Accidental bodily injury sustained in this state by the owner while occupying a motor vehicle or while not an occupant of a motor vehicle or motorcycle if the injury is caused by…”
Fed. Deposit Ins. Corp. v. First Am. Title Ins. Co., 611 F. App'x 522 (11th Cir. 2015). “(Section 627.786, Florida Statutes, explicitly allows a title insurer to issue a closing protection letter.”
State Farm Mut. Auto. Ins. Co. v. Gonzalez, 178 So. 3d 448 (Fla. 3d DCA 2015). “Although section 627.786(4)(b) provides that PIP benefits “shall be overdue if not paid within.”
Granada Ins. Co. v. Mark A. Cereceda, D.C., P.A., 997 So. 2d 1243 (Fla. 3d DCA 2008). “In so doing, Judge Canady wrote the “plain and unambiguous terms [of] section 627.786(7)(a) do[] not address situations in which one charge for treatment has been denied by the insurer.”
State Farm Mut. Auto. Ins. v. Jenkins, 767 So. 2d 622 (Fla. 4th DCA 2000). “By the time State Farm requested an examination *623 ■under oath on June 4, the claim filed on April 29 was already overdue under the thirty day provision of section 627.786(4)(b), Florida Statutes (1999).”
— 627.786(3) — 1 case
Sommers v. Smith & Berman, PA, 637 So. 2d 60 (Fla. 4th DCA 1994). “Section 627.786(3), Florida Statutes (1987) authorizes the title insurance company to assume responsibility for losses arising out of a closing by "providing instruments to any prospective insured, in the form and content approved by the department [of insurance].”
— 627.786(4)(b) — 2 cases
State Farm Mut. Auto. Ins. Co. v. Gonzalez, 178 So. 3d 448 (Fla. 3d DCA 2015). “Although section 627.786(4)(b) provides that PIP benefits “shall be overdue if not paid within.”
State Farm Mut. Auto. Ins. v. Jenkins, 767 So. 2d 622 (Fla. 4th DCA 2000). “By the time State Farm requested an examination *623 ■under oath on June 4, the claim filed on April 29 was already overdue under the thirty day provision of section 627.786(4)(b), Florida Statutes (1999).”
— 627.786(4)(d)(l) — 1 case
State Farm Mut. Auto. Ins. v. Nicholson, 337 So. 2d 860 (Fla. 2d DCA 1976). “The relevant statute in the Act is F.S. § 627.786(4)(d)(l) which provides that benefits obtain for, “Accidental bodily injury sustained in this state by the owner while occupying a motor vehicle or while not an occupant of a motor vehicle or motorcycle if the injury is caused by…”
— 627.786(5) — 1 case
State Farm Mut. Auto. Ins. Co. v. Delray Med. Ctr., Inc., 178 So. 3d 511 (Fla. 4th DCA 2015). “Section 627.786(5) provides, in pertinent part: (5) Charges for treatment of injured persons.”
— 627.786(5)(a) — 1 case
Geico Gen. Ins. Co. v. Virtual Imaging Servs., Inc., 141 So. 3d 147 (Fla. 2013). “§ 627.786(5)(a)2., Fla. Stat. (2008) (emphasis supplied).”
— 627.786(5)(a)(2)(f) — 1 case
Allstate Fire & Cas. Ins. Co. v. Perez, 111 So. 3d 960 (Fla. 2d DCA 2013). “As in this case, the insurer would have to look beyond the CPT code to determine whether the services represented in the code are reimbursable under Medicare Part B. We understand that this complicates the reimbursement process under the PIP statute.”
— 627.786(5)(b) — 1 case
Altamonte Springs Imaging, L.C. v. State Farm Mut. Auto. Ins., 12 So. 3d 850 (Fla. 3d DCA 2009). “CPI, MRI, PIP, and Commonality The legislature enacted section 627.786(5)(b)5 in 2001 to provide consumer price index (CPI) adjustments for magnetic resonance imaging (MRI) reimbursements in personal injury protection (PIP) claims.”
— 627.786(5)(d) — 1 case
State Farm Mut. Auto. Ins. Co. v. Gonzalez, 178 So. 3d 448 (Fla. 3d DCA 2015). “Although section 627.786(4)(b) provides that PIP benefits “shall be overdue if not paid within.”
— 627.786(6)(b) — 1 case
State Farm Mut. Auto. Ins. Co. v. Delray Med. Ctr., Inc., 178 So. 3d 511 (Fla. 4th DCA 2015). “Section 627.786(5) provides, in pertinent part: (5) Charges for treatment of injured persons.”
— 627.786(7)(a) — 1 case
Granada Ins. Co. v. Mark A. Cereceda, D.C., P.A., 997 So. 2d 1243 (Fla. 3d DCA 2008). “In so doing, Judge Canady wrote the “plain and unambiguous terms [of] section 627.786(7)(a) do[] not address situations in which one charge for treatment has been denied by the insurer.”
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