This is an appeal by the Superintendent of Insurance from an order of the Appellate Division, annulling his determination, by which he levied $13,000 in civil penalties upon respondent for its willful violations of sections 154 (subd. 7) and 204 (subd. 1, par. [c]) of the Insurance Law. The violations charged were the issuance of 13 policies of group credit life insurance without appellant's approval...
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