DATE: August 27, 2002

TO: Dealers, General Managers, and F&I Managers

FROM: Mark S. Krejci

RE: Hartford GAP - Florida Department of Insurance (FDOI) Compliance

This memo is to confirm that Continental-National's IAS/Hartford GAP is in compliance with all legislation in the state of Florida. A recent information memorandum (02-059M) issued by the FDOI clarified their position that two-party GAP is not insurance.

At present, the IAS/Hartford GAP product is a two-party transaction between the Dealer who, by law, is the Lender/Lessor at the time of the sale or lease. The product is a contract by the Dealer (Creditor) to waive the GAP (deficiency) to the Customer (Borrower).

Per the information memorandum, "As long as the party who made the loan is the one who is agreeing to waive the difference, the product is not insurance."

If you have any questions, please feel free to contact me at the office at 813.223.0085, ext. 25. As always, thank you for allowing us the opportunity to serve you.

Back to Top