In Security First Insurance Company v. State of Florida, Office of Insurance Regulation, 40 FLW D1449a (Fa. 1st DCA June 22, 2015), Security First sought to amend its insurance policy form to prohibit post-loss assignment of benefits without the insurer’s prior approval.  Security First submitted its proposed policy form change to the Florida Office of Insurance Regulation.  The OIR rejected the change because it would
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In Progressive Express Insurance Company v. Hartley, ____ So.3d ____ (Fla. 5th DCA October 30, 2009), Progressive provided Hartley with PIP insurance.  Hartley was injured in an accident and sought treatment from Michael C. Durant, D.C.  Upon seeking treatment from Dr. Durant, Hartley executed an assignment of benefits to "Atlantic Coast Chiropractic Clinic." 

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In Gables Insurance Recovery, Inc. v. Seminole Casualty Insurance Company, 34 FLW D672 (Fla. 3rd DCA April 1, 2009), the PIP insured received medical care from Atlantic Medical Specialty, Inc. and executed a document titled "ASSIGNMENT OF BENEFITS/POLICY RIGHTS."  This document purported to assign the insured’s rights and benefits under her PIP policy to Atlantic although