24220/JB

STATE OF MINNESOTA
DEPARTMENT OF COMMERCE

CEASE AND DESIST ORDER
AND NOTICE OF RIGHT TO HEARING

In the Matter of Mutual Assurance
a/k/a Embassy of Heaven Church and Kingdom of Heaven,
and Paul DeRevoire,
a/k/a Paul Revere, individually

TO:

Mutual Assurance
a/k/a Embassy of Heaven Church and Kingdom of Heaven
Paul DeRevoire a/k/a Paul Revere
P.O. Box 337
Stayton, OR 97383-0337

CEASE AND DESIST ORDER

INTRODUCTION

The commissioner of the Department of Commerce ("Commissioner") may issue a Cease and Desist Order whenever it appears that a person has engaged in, or is about to engage in, an act or practice constituting a violation of any law, rule, or order related to the duties and responsibilities entrusted to the Commissioner. Minn. Stat. § 45.027, subd. 5a(a) (2010).

Minnesota State law prohibits any person from soliciting or making, or aiding in soliciting or making, any contract of insurance not authorized by the laws of this the State. Minn. Stat. § 60A.08, subd. 4 (2010). Further, no insurance company may transact business in this State without a license or certificate of authority issued by the Commissioner, unless it is exempt from such requirements. Minn. Stat. § 60A.07, subd. 4 (2010). Finally, no person may act as a self-insurer in Minnesota without the approval of the Commissioner. Minn. Stat. § 65B.48, subd. 3 (2010).

Pursuant to the above-referenced statutes, the commissioner has determined as follows:

STATEMENT OF CHARGES

1. Mutual Assurance a/k/a Embassy of Heaven Church and Kingdom of Heaven ("Mutual Assurance") is not licensed in any capacity by the Minnesota Department of Commerce ("Department"). Likewise, Mutual Assurance does not have approval to self-insure in the State of Minnesota.
2. Paul DeRevoire a/k/a Paul Revere ("DeRevoire") is not licensed in any capacity by the Department.
3. The U.S. Department of Justice describes "Embassy of Heaven" as follows:
   A religious/antigovernment group in Oregon headed by "Paul Revere," the alias of a former computer analyst named Paul DeRevoire. DeRevoire started the Embassy of Heaven Church in 1987; it peaches a total reparation from "earthly" government. Embassy members continue to make and sell bogus license plates and other paraphernalia.
4. On June 12, 2012, the Renville County Attorney's Office contacted the Department about Mutual Assurance's licensing status. This inquiry followed a criminal citation issued to a Minnesotan for driving without automobile insurance. In defense of that citation, the owner of the vehicle produced a "Certificate of Self-Insurance" issued by Mutual Assurance.
5. The "Certificate of Self-Insurance" indicated that the Minnesotan was "a member (number MA328354566) of Mutual Assurance, which is a pool of self-insured ministries." In addition, the certificate purported to be valid from January 5, 2012, until January 5, 2013, and listed the identifying features of the Minnesotan's vehicle.
6. The Department contacted the Minnesotan, who reported that she did not pay any premium for the certificate, but believed she secured "church based insurance" through a group membership with Mutual Assurance. The Minnesotan indicated that she printed off her certificate from Mutual Assurance's website.
7. Mutual Assurance's website includes a document entitled "claim form" that may be filled out and electronically submitted to Mutual Assurance. The form includes fields for "Policy Holder Information," "Accident Information," and "Damage Information." In addition, the form provides as follows: "The foregoing is a true statement of the cause and estimated amount of this loss. If approved by the Company, I/we agree to accept this amount in settlement."
8. On information and belief, and in addition to acting as the entity's founder and leader, DeRevoire is listed as the registrant for Mutual Assurance's website.
9. This Order is in the public interest.

VIOLATIONS

Count I

Mutual Assurance a/k/a Embassy of Heaven Church and Kingdom of Heaven ("Mutual Assurance") and Paul DeRevoire a/k/a Paul Revere ("DeRevoire") engaged in false and misleading advertising and other misrepresentations with regard to the solicitation of certificates of self-insurance. Minn. Stat. §§ 72A.19, and 72A.20, subds 1, 2, and 18(b) (2010), and Minn.R. 2790.0500 (2010).

Count II

Mutual Assurance and DeRevoire acted and operated as insurers or self-insurers in Minnesota without the certification or approval of the Commissioner, and without evidence that appropriate provisions exist to ensure compliance with the Minnesota No-Fault Automobile Insurance Act. Minn. Stat. §§ 45.027, subd. 7(a)(2), 60A.08, subd. 4, 60A.07, subd. 4, and 65B.48, subd. 3 (2010); see also Minn. Stat. §§ 65B.41-.71 (2010).

ORDER

NOW, THEREFORE, IT IS HEREBY ORDERED, pursuant to Minn. Stat. § 45.027, subd. 5a (2010), Mutual Assurance a/k/a Embassy of Heaven Church and Kingdom of Heaven, and Paul DeRevoire a/k/a Paul Revere (collectively "Respondents") shall cease and desist from any further deceptive or misleading advertisements or other misrepresentations in connection with or relating to the business of insurance in the State of Minnesota, including without limitation issuing certificates of self-insurance to any Minnesotan.

IT IS FURTHER ORDERED THAT, pursuant to Minn. Stat. §§ 45.027, subd. 5a (2010), Respondents shall cease and desist from acting and operating as insurers or self-insurers in Minnesota without the certification or approval of the Commissioner.

NOTICE OF RIGHT TO HEARING

IT IS FURTHER ORDERED, pursuant to Minn. Stat. § 45.027, subd. 5a (2010), that Respondents may request a hearing in this matter. Such request shall be made in writing and served on the Commissioner, whereupon the Commissioner shall set a date for hearing within ten (10) days after receipt of the request unless Respondents and the Department agree to waive the 10-day time period. If no hearing is requested by Respondents within thirty (30) days of service of this Order and none is ordered by the Commissioner, this Order will become permanent and will remain in effect until modified or vacated by the Commissioner.

IT IS FURTHER ORDERED, that if a hearing is requested, this Order will remain in effect until modified or vacated or made permanent by further order of the Commissioner under Minn. Stat. § 45.027, subd. 5a (2010). The administrative proceeding provided by Minn. Stat. § 45.027, subd. 5a (2010), and subsequent appellate judicial review of that administrative proceeding, constitutes the exclusive remedy for determining whether the Commissioner properly issued this Order and whether this Order should be made permanent.

IT IS FURTHER ORDERED, that, notwithstanding Minn. Stat. § 45.027, subds. 5 or 5a (2010), if Respondents request a hearing under Minn. Stat. § 45.027, subd. 5a (2010), Respondents may, within 15 days after service of this Order, bring an action in Ramsey County District Court for an injunction to suspend enforcement of this Order pending a final decision by the Commissioner under Minn. Stat. §45.027, subd. 5a (2010) to vacate or make permanent this Order. The court shall determine whether to issue such an injunction based on traditional principles of temporary relief.

IT IS FURTHER ORDERED, that in the event a hearing is requested in this matter, it will be held before an Administrative Law Judge to be appointed by the Chief Administrative Law Judge for the State of Minnesota, Office of Administrative Hearings, 600 North Robert Street, St. Paul, Minnesota 55146, Telephone: (651) 361-7900. All parties have the right to represent themselves or be represented through the proceedings herein by legal counsel or a person of their choice if not otherwise prohibited as the unauthorized practice of law. The hearing will be conducted under the contested case procedures in Minn. Stat. §§ 14.57-14.69 (2010), and the Rules of the Office of Administrative Hearings, Minn. R. 1400.5100-1400.8401 (2011). Failure to attend a hearing in this matter may result in the allegations of this Order being taken as true. Any questions concerning the issues which were raised in this Order, or if you wish to discuss an informal disposition of this proceeding, may be directed to Assistant Attorney General Christopher M. Kaisershot at (651) 757-1264. Mr. Kaisershot's address is the Minnesota Attorney General's Office, 1800 Bremer Tower, 445 Minnesota Street, St. Paul, Minnesota 55101-2134.

Mike Rothman
Commissioner

Dated: October 1, 2012

/s/ Steven E. Carlson

STEVEN E. CARLSON
Deputy Commissioner

Minnesota Department of Commerce
85 Seventh Place East, Suite 500
St. Paul, MN 55101

AG: #3063187-v1