Litai Assets LLC v. Department of Financial Services
CourtDistrict Court of Appeal of Florida
Date FiledSeptember 30, 2026
Docket1D2025-0988
StatusPublished
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Full Opinion
FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________
No. 1D2025-0988
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LITAI ASSETS LLC,
Appellant,
v.
FLORIDA DEPARTMENT OF
FINANCIAL SERVICES,
Appellee.
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On appeal from the Circuit Court for Leon County.
John C. Cooper, Judge.
September 30, 2026
PER CURIAM.
Litai Assets LLC is in the insurance and viatical business. It
services viatical settlements—contracts through which parties sell
their life insurance benefits for an immediate cash payout. The
Department of Financial Services attempted to investigate Litai’s
activity and records via administrative subpoena, which Litai
challenged as unauthorized. The trial court ruled that the
Department had authority to investigate Litai’s business and issue
the administrative subpoena, and Litai appeals. We affirm.
Facts
The viatical industry allows a person with a life insurance
policy to sell that benefit, pre-death, for an immediate lump sum
payment. Often, but not always, the insured is terminally ill and
prefers to get money up front to pay medical or other expenses. The
new holder of the viaticated policy then takes over any premium
payments coming due, and recovers the death benefit upon the
viator’s death. The parties to this process include viatical
settlement providers, the purchasers; viators, the insureds; and
viatical brokers, who charge a fee to connect providers and viators.
See § 626.9911(11)–(16), Fla. Stat. (2023). Viatical licensees have
statutorily-imposed record-keeping requirements, including the
obligation to “keep and make available” or “maintain ... or have
readily accessible” such records to the Department or Office of
Insurance Regulation, as applicable, to ensure Code compliance.
See §§ 626.561(2), 626.748, Fla. Stat.
Until June of 2022, Litai held a Department-issued insurance
agency license. After that license lapsed, Litai’s website still
advertised that it had “a thirteen year long history [sic] of servicing
life insurance policies,” was “currently managing over 5,000 life
insurance policies and [] the largest servicer in the industry,” and
provided “pre-investment transaction advice.”
The Department began investigating Litai for possible
unlicensed practice in fall 2023. After Litai rebuffed Department
attempts to review Litai records, the Department issued an
investigative subpoena seeking four categories of documents:
(1) records “pertaining to insurance or the effectuating of
insurance transactions (including viaticals)” for the prior five
months, so the Department could “verify if your agency is
transacting insurance in violation of the Florida Statutes”; (2) a
list of active life settlement agreements for two trusts and life
insurance policies of two specific individuals in those trusts;
(3) Litai’s bank statements for the prior eight months from an
identified bank account; and (4) business e-mails from four named
Litai employees/managers for the prior three months, one of whom
held a Department-issued life insurance agent license.
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Litai responded that it was not transacting insurance, but
merely servicing viaticated policies, and therefore it had no records
responsive to the subpoena. Litai also asserted that the
Department lacked authority to investigate Litai because the
Department did not regulate viatical servicers. Litai challenged
the subpoena as overbroad.
The Department petitioned the circuit court to enforce the
subpoena. The court granted the petition. It directed Litai to
“comply with the subject subpoena” and “allow [the Department]
unencumbered access, by electronic or photographic means, to
books, papers, records, files, correspondence, documents, and
accounts so as to enable [the Department] to determine whether
any person has violated any provision of the [Insurance Code] in
accordance with [Bankers *].”
Standard of Review
We review questions of statutory interpretation and
jurisdiction de novo. See Dep’t of Revenue v. Graczyk, 206 So. 3d
157, 159 (Fla. 1st DCA 2016); see Fla. Dep’t of Revenue v. Verizon
Commc’ns, Inc., 380 So. 3d 541, 543–44 (Fla. 1st DCA 2024).
Analysis
Litai argues that the Department had no authority to issue
the subpoena because Litai is only a viatical servicer, and the
Department does not have authority to regulate, investigate, or
subpoena such servicers. We agree with the trial court and hold to
the contrary, that the Department did and does have such
authority, statutorily conferred. See generally Advance Am. v.
State, Off. of Att’y Gen., Dep’t of Legal Affs., 801 So. 2d 310, 310–
11 (Fla. 1st DCA 2001) (affirming AG’s authority to investigate
RICO claim that payday lender was charging usurious rates by
rollover or consecutive transactions, and issue subpoenas for that
purpose); Fla. Dep’t of Ins. & Treasurer v. Bankers Ins. Co., 694 So.
2d 70, 71 (Fla. 1st DCA 1997) (explaining an agency’s “legitimate
* Fla. Dep’t of Ins. & Treasurer v. Bankers Ins. Co., 694 So. 2d
70 (Fla. 1st DCA 1997).
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regulatory realm is no more and no less than what the Legislature
prescribes by law”).
The Department and the Office of Insurance Regulation share
authority over the Florida Insurance Code, and the Code directs
that each “shall enforce the provisions of [the Code]” within its
respective realm. § 624.307(1)–(2), Fla. Stat. Each may investigate
“as it may deem proper to determine whether any person has
violated any provision of this code within its respective regulatory
jurisdiction.” § 624.307(3), Fla. Stat. Each may investigate
unlicensed activity under the Code—again, within its respective
regulatory jurisdiction. § 624.310(2)(a), Fla. Stat.
The Department has authority over “insurance agents,
insurance agencies, managing general agents, insurance
adjusters, reinsurance intermediaries, viatical settlement brokers,
customer representatives, service representatives, and agencies.”
§ 626.016(1), Fla. Stat. It licenses them. See § 626.172(1), Fla. Stat.
It is illegal to act as, or advertise or hold yourself out as, an
insurance agent, adjuster, or agency or to “transact[] insurance or
otherwise engage[] in insurance activities” without a license. See
§ 626.112(1)–(10), Fla. Stat. A Department-issued license is
required to “engage in the solicitation of insurance,” which
includes offering or attempting to negotiate on another’s behalf a
viatical settlement contract. See § 626.112(1)(b)(6), Fla. Stat.
As to viaticals, the Department controls viatical settlement
brokers, and a life agent can be a viatical settlement broker. See
§§ 626.785(1), 626.7845(1), 626.9916(1)–(2), Fla. Stat. The Office
licenses and controls viatical settlement providers. § 626.9912(1),
Fla. Stat.; see Coventry First, LLC v. State, Off. of Ins. Regul., 38
So. 3d 200, 202 (Fla. 1st DCA 2010) (discussing the Office and
viatical providers). Both the Department and the Office, within
their delineated roles, have the authority “to regulate viatical
settlement providers, viatical settlement brokers, viatical
settlement contracts, and viatical settlement transactions.”
§ 626.99285, Fla. Stat.
In addition to its regulatory authority, the Department has
statutory authority to investigate “accounts, records, documents,
and transactions pertaining to or affecting the insurance affairs of
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any agent, adjuster, insurance agency, customer representative,
service representative, or other person subject to its jurisdiction.”
§ 624.317(1), Fla. Stat.; see also § 626.9561, Fla Stat. (granting the
Department and Office, within their respective realms, power to
investigate “the affairs of every person involved in the business of
insurance in this state in order to determine” unfair competition
or deceptive acts or practices). During the investigation, the
person(s) “shall make freely available . . . the accounts, records,
documents, files, information, assets, and matters in their
possession or control relating to the subject of the examination or
investigation”; and subpoenas may be issued to require production
of “books, papers, records, files, correspondence, documents, or
other evidence which is relevant to the inquiry.” §§ 624.318(2),
624.321(1)(b), Fla. Stat.; see also § 626.601(2), Fla. Stat.
The Department regulates and licenses insurance agents and
agencies, and viatical brokers. A Department license is required to
solicit insurance—i.e., offer or attempt to negotiate on behalf of
another a viatical settlement contract. The Department
investigates its licensees and any unlawful unlicensed activity—
including not just advertising or holding out as an insurance agent,
adjuster, or agency, but also transacting insurance or otherwise
engaging in insurance activities.
Litai asserts it is not a viatical provider (under the Office’s
auspices) or a viatical broker (under the Department’s auspices).
It claims it merely services viatical agreements and has done
nothing wrong. But this is self-serving and conclusory, and does
not confront or resolve the real issue of the Department’s statutory
authority. A mere denial of impropriety does not thwart the
Department’s authority to investigate activity within its
jurisdiction.
The Department has clear and express statutory authority to
investigate whether Litai is brokering viaticals without a
Department-issued license. So too, the Department has the
authority to investigate Litai and ensure it is not operating as an
insurance agency (including offering or attempting to negotiate
viatical settlement contracts on behalf of another person). A
factual basis exists. Litai held a Department insurance license for
years; one of its owners/managers holds an active Department
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license; and its website discussed its history and prowess within
the life insurance industry, to include viaticals and “pre-
investment transaction advice.” On the record presented, we also
reject Litai’s arguments that the subpoena was overbroad, a
general warrant, and not supported by sufficient suspicion of a
violation.
Accordingly, the final judgment enforcing the Department’s
subpoena is AFFIRMED.
LEWIS, BILBREY, and KELSEY, JJ., concur.
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Not final until disposition of any timely and
authorized motion under Fla. R. App. P. 9.330 or
9.331.
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Oral Beason, General Counsel, Litai Assets LLC, Pompano Beach;
Jesse Michael Panuccio, Evan Matthew Ezray, and Andrea
Guzman of Boies Schiller Flexner LLP, Fort Lauderdale; Ben Allen
Andrews, John Lawrence Brennan, III, and Stephanie Loren Clark
of Pennington, P.A., Tallahassee, for Appellant.
Francis Albert Carbone II, General Counsel, Michael Thomas Ruff,
and Marshawn Michael Griffin, Florida Department of Financial
Services, Tallahassee, for Appellee.
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