OPINION
A. PAUL LOMMEN, Judge.
This appeal is from an order of the Commissioner of Commerce determining respondent had committed four separate violations of Minn.Stat. § 72A.20, subd. 12a and one violation of Minn.Stat. § 72A.20, subd. 12. Relator insurance company claims the Commissioner of Commerce erred because (1) there was no factual basis for finding a "general...
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