Respondent properly determined that petitioners had violated 11 NYCRR part 73 (or Regulation 121) by using an excess line broker to procure claims-made liquor liability policies from an unlicensed insurer and placing these policies with their New York State clients. Substantial evidence supports respondent's determination that petitioners placed 1,497 claims-made liquor liability policies, including renewals, from 1987 through 1991. However, we find, as did respondent's own...
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