Cases from cite.case.law:

STATE DEPARTMENT OF FINANCIAL SERVICES v. BRANCH BANKING AND TRUST COMPANY, v., 40 So. 3d 829 (Fla. Dist. Ct. App. 2010)

. . . holding that Branch Banking and Trust Company (“the bank”) was entitled to offsets pursuant to section 631.281 . . . erred in both cases by granting offsets where there was no mutuality of debts, as required by section 631.281 . . . requested enforcement of its rights as a secured creditor and, alternatively, offsets pursuant to section 631.281 . . . The offset claim was based on section 631.281, which provides, in pertinent part, as follows: (1) In . . . As the statute indicates, an offset can be granted only where there is mutuality. § 631.281. . . .

IMAGINE INSURANCE CO. LTD. v. STATE DEPARTMENT OF FINANCIAL SERVICES a, 999 So. 2d 693 (Fla. Dist. Ct. App. 2008)

. . . Section 631.281, Florida Statutes (2004), addresses offsets and provides: (1) In all cases of mutual . . .

FLORIDA INDEPENDENT AUTOMOBILE DEALERS ASSOCIATION HEALTH AND WELFARE BENEFIT PLAN, REINECKE AGENCY, INC. v. FIDELITY SECURITY LIFE INS. CO., 636 So. 2d 37 (Fla. Dist. Ct. App. 1994)

. . . specifically prohibited set off or offset of any debt owing to FIADA except offsets as provided in section 631.281 . . .

NOVA INSURANCE GROUP, INC. v. FLORIDA DEPARTMENT OF INSURANCE,, 606 So. 2d 429 (Fla. Dist. Ct. App. 1992)

. . . right to retain the funds pursuant to s. 631.155, s. 631.191, s. 631.261, s. 631.262, s. 631.263, or s. 631.281 . . . Section 631.154(l)’s reference to the offset provisions of section 631.281 provides an example of just . . . Dept. of Ins., 507 So.2d 142 (Fla. 1st DCA 1987), construing section 631.281. . . .

SUNSET COMMERCIAL BANK, v. FLORIDA DEPARTMENT OF INSURANCE,, 509 So. 2d 366 (Fla. Dist. Ct. App. 1987)

. . . We find that Sunset Commercial Bank’s offset claim under section 631.281, Florida Statutes, should have . . . this order upon the contention that it has a self-executing right to offset by application of section 631.281 . . . While the act contains a statutory offset provision for mutual debts or credits, see section 631.281, . . . Florida Statutes, neither this enactment nor section 631.281 contains any exemption from filing requirements . . . The application of section 631.281 in this manner was recently approved by this court in Barnett Bank . . .

BARNETT BANK OF JACKSONVILLE, N. A. v. STATE DEPARTMENT OF INSURANCE,, 507 So. 2d 142 (Fla. Dist. Ct. App. 1987)

. . . Insurance Company (Midland), an insolvent insurer, seeking court approval of a setoff under section 631.281 . . . demonstrated the mutuality of obligation necessary to establish the right to an offset under section 631.281 . . . Section 631.281(1) provides that “[i]n all cases of mutual debts or mutual credits between the insurer . . . Thus, Barnett has demonstrated the mutuality required under section 631.281. . . . The offset permitted by 631.281 is, by its very nature, a specie of preference. . . .