ALJDEC - Licensing

25A-062-INS-RES · Department of Insurance and Financial Institutions - Insurance · 2025-11-17

IN THE OFFICE OF ADMINISTRATIVE HEARINGS

In the Matter of:

Percy Bland

(National Producer Number 18476505),

Respondent.

No. 25A-062-INS-RES

ADMINISTRATIVE LAW JUDGE DECISION

HEARING: September 29, 2025

APPEARANCES: Percy Bland represented himself. Assistant Attorney General Heather McCoy represented the Arizona Department of Insurance and Financial Institutions.

ADMINISTRATIVE LAW JUDGE: Kay A. Abramsohn

EXHIBITS ADMITTED INTO EVIDENCE: Department Exhibits 1 through 19.

_____________________________________________________________________

FINDINGS OF FACT

Percy Bland (“Respondent”) has been licensed in the State of Arizona as a non-resident Insurance Producer, National Producer License Number 18476505, with lines of authority in Accident & Health or Sickness and Life.

The Arizona Department of Insurance and Financial Institutions (“Department”) first issued Respondent’s non-resident insurance producer’s license on July 17, 2017; the most recent license was issued on April 1, 2021. Respondent’s license was set to expire on March 31, 2025.

Respondent’s business address with Department was on “Cowboys Way” in Frisco, Texas, and his residence and mailing address was on “Rhett Lane” in Carrollton, Texas. Respondent maintained only one email address: [email redacted].

In April 2024, Banner Life Insurance Company (“Banner”), notified the Department that Banner had terminated Respondent’s agency status. Banner was advising that it had determined that life insurance applications were being submitted with “fabricated” applicant information that did not match public records.

The subject life insurance applications provided by Banner to the Department were, by all appearances, from Arizona residents and were, in each case, submitted for coverage through an INSZU Insurance Agent with Agent #QUW1361.

On June 25, 2024, the Department sent an email to Respondent requesting a response to the allegations. The Department emailed Respondent at the email address of record at that time: [email redacted]. The Department did not receive a response.

On November 26, 2024, the Department emailed and issued Subpoenas to Respondent for an interview on December 20, 2024 and to produce documents by December 18, 2024 to Investigator Rachel Smith. The Subpoenae were mailed to each of Respondent’s addresses; each mailed subpoena resulted in returned postal mail as unable to forward.

On June 11, 2025, the Department issued its Notice of Hearing and Complaint (“Notice”) setting an administrative hearing regarding whether grounds existed to revoke Respondent’s Arizona non-resident insurance producer license. The Department mailed the Notice to the Rhett address and email to the email address of record: [email redacted].

On July 2, 2025, the Department emailed a copy of the Notice to Respondent at the following email address: [email redacted].

Further email communications ensued: on July 14, 2025, the Department emailed a final request to Respondent to respond by July 25, 2025, copying him on the Subpoena. The Department also requested responses to the following questions:

1. Have you transacted insurance business with/for Arizona consumers in any capacity since January 2025? If so, specify what lines of insurance and types of transactions (e.g. sales, enrollments, billing, risk assessments, policy service, financial advising, etc.).

2. Do you plan to continue work in the insurance industry on a forward basis?

On July 29, 2025, Respondent replied:

My apologies for the delayed response. Your email was in my spam folder in which I just noticed now. Please see my responses below:

1. I have only conducted annuity business in Arizona in 2025.

2. I do plan to continue to work in the insurance industry moving forward with my main focus being on advance retirement income planning.

On August 14, 2025, the Department requested more specific responses to the Subpoena and additional questions regarding Respondent’s insurance activities.

On August 20, 2025, Respondent replied, supplying his current mailing address and providing the following answers:

I categorically deny falsifying any client information to enroll customers with Legal & General Insurance without their consent. At the time, I was contracted with a marketer who used a third-party e-application and quoting platform called Navigator. This tool facilitated pre-underwriting and quoting for multiple carriers. The agency I was working with, Inszu LLC, had multiple outbound representatives who pre-qualified customers before applications were submitted.

If any information was entered incorrectly, it was not done by me, nor at my direction. I am actively working to gather evidence to demonstrate this. One possible point of error may relate to a dialer named Regina, located in the Philippines, who had been referred to us through Family First Life. At that time, we were unaware of any ethical concerns regarding that organization. It is possible she may have bypassed certain prompts in the quoting tool to speed up the quoting process. However, the customers associated with these applications were real individuals who wanted insurance and proceeded with their applications.

At no point did Legal & General contact me or my business partner to address or resolve these matters directly before this escalation occurred. I was terminated without such an opportunity. After reviewing the subpoena, I have made contact with Alexander Valer, and attached are screenshots of text messages sent to him today by my former business partner to assist in addressing these allegations.

Due to the passage of time, my access to client records is limited, but I am committed to continuing to collect supporting evidence. This situation appears to be a misunderstanding. If any data errors occurred on the named applications, they were not caused by me. My record in financial services and insurance reflects years of ethical, compliant conduct without prior customer complaints.

I have learned from this experience to be more cautious with third-party systems and automation tools, as they can introduce errors that require post-sale audits. In these specific cases, I can affirm that I did not knowingly mishandle client data or submit illegitimate policies.

Thank you for your consideration. I will continue compiling documentation in preparation for the legal conference.

ANNUITY BUSINESS: The only acts that I have transacted regarding annuity business in Arizona is helping my former client with surrendering his policy that was done on February 28, 2025. Since March 31, 2025, I have transacted any annuity business in Arizona.

At hearing, Investigator Smith testified in support of her investigation and the information collected.

The Department argued that Respondent had not shown an explanation for failing to update his business and personal contact information as is required by statute. Further that Respondent had failed to respond to the Subpoena to appear and produce records as well as failed to respond to the written request for explanation, which is a violation of A.R.S. § 20-295(A)(2). Further, that the subject applications, which were in the names of three Arizona residents, contained inaccurate personal information regarding those residents, which is a violation of A.R.S. § 20-295(A)(8). The Department’s position is that these violations demonstrate grounds to revoke Respondent’s Arizona non-resident insurance producer’s license.

At hearing, Respondent was forthright in acknowledging he had not updated his business and personal contact information; however, he indicated that he had tried to call the Department about updating but had not received a call back. Respondent stated that he did not realize he had needed to update the contact information and indicated that he had also not updated it with other states.

Respondent indicated he stopped doing business at Cowboys Way during COVID. Respondent indicated that he moved from Rhett Lane to a new home in November 2021. Respondent indicated that he had not had any access to the “wilbridgefinancial” email address since 2022 or 2023.

As to the Arizona license, Respondent acknowledged that he had renewed the license in April 2021, but believed he had simply gone through the renewal process by paying the fees. Respondent indicated that he knew the license was expiring in March of 2025 and he did not renew it due to “getting out of” the life insurance business.

Regarding the applications, while he acknowledged that the applications contained his Agent number, Respondent categorically denied having created the three applications or having submitted the three applications to Banner. Respondent discussed the role that the Navigator had played in obtaining leads and gathering information for INSZU. Respondent stated that his involvement with INSZU had been for the purpose of growing an annuity business line to use in the retirement planning business and noted that he had disassociated with that business partner about 8 months prior to the hearing.

On July 1, 2025, the Department reviewed The National Association Insurance Commissioners (NAIC), State Licensing Report, for Respondent.

Regarding Respondent’s “Demographics” under the Texas summary, the report showed a Rhett Lane address as of May 3, 2020 and a last update on licensure on May 11, 2023. The NAIC report states Respondent’s Texas licensure is active; however, the licensure expiration date is noted to be March 31, 2025.

Regarding Respondent’s “Demographics” under the Arizona summary, the report showed a Rhett Lane address as of June 12, 2023 and noted the inactive licensure status as of April 1, 2025.

Regarding Respondent’s “Demographics” under the Florida summary, the report showed a Rhett Lane address as of September 17, 2020 and noted the voluntary cancellation licensure status as of February 4, 2020.

While Banner notified the Department in April 2024 that Banner had terminated Respondent’s agency status (as to Texas licensure), the NAIC report as to Texas shows that the Banner termination on April 16, 2024 was “Not for Cause.”

Based on the Demographics in the NAIC report, Respondent’s address at the time of his April 2021 Arizona license renewal was the Rhett Lane address.

CONCLUSIONS OF LAW

This matter is a disciplinary proceeding wherein the Department must prove by a preponderance of the evidence that Respondent violated the State’s Insurance Laws.

Ariz. Rev. Stat. § 20-295 provides, in pertinent part, as follows:

A. The director may deny, suspend for not more than twelve months, revoke or refuse to renew an insurance producer's license or may impose a civil penalty in accordance with subsection F of this section or any combination of actions for any one or more of the following causes: ...

2. Violating any provision of this title or any rule, subpoena or order of the director. . . .

8. Using fraudulent, coercive or dishonest practices, or demonstrating incompetence, untrustworthiness or financial irresponsibility in the conduct of business in this state or elsewhere.

The circumstances in this case demonstrate the need for requirements for licensees to update licensures in any state in which a person is actively licensed. A licensee should not presume that a regulator will not need to reach out to a licensee if the licensee is no longer using the license even when the license is neither voluntarily cancelled nor expired. The hearing record demonstrated that, once noticed for an administrative hearing, Respondent did respond to the Department’s subpoena and requests. The Administrative Law Judge concludes that the Department’s investigation was not substantially hampered by the time-lag in its inability to contact Respondent in November and December of 2024. The Administrative Law Judge concludes, based on the particular circumstances in this matter, the Department has not demonstrated Respondent was in violation of Ariz. Rev. Stat. § 20-295(A)(2) for purposes of disciplinary action.

Based on the credible testimony that Respondent was not responsible for the creation or submission of the three subject applications containing inaccurate applicant information, the Administrative Law Judge concludes the Department has not demonstrated Respondent was in violation, within the meaning of Ariz. Rev. Stat. § 20-295(A)(8), regarding any fraudulent or dishonest practices. Had such a violation been demonstrated, the Administrative Law Judge would have concluded that revocation of Respondent’s non-resident insurance producer licensure would have been appropriate for that reason alone.

RECOMMENDED ORDER

IT IS ORDERED Respondent’s Arizona non-resident insurance producer License Number 18476505 shall be considered to be expired as of April 1, 2025 on the effective date of the final Order entered in this matter.

Pursuant to A.R.S. § 41-1092.08(I), the licensee may accept the Administrative Law Judge Decision by advising the Office of Administrative Hearings in writing not more than ten (10) days after receiving the Administrative Law Judge Decision. If the licensee accepts the Administrative Law Judge Decision, the Administrative Law Judge Decision shall be certified as the final decision by the Office of Administrative Hearings.

In the event of certification of the Administrative Law Judge Decision by the Director of the Office of Administrative Hearings, the effective date of the Order will be forty (40) days from the date of that certification.

Done this day, November 17, 2025.

/s/ Kay A. Abramsohn

Administrative Law Judge

Transmitted electronically to:

Maria Ailor, Interim Director

Department of Insurance and Financial Institutions - Insurance

Heather McCoy

Office of the Attorney General

[email redacted]

Percy Bland

[email redacted]

By: OAH Staff