An unlicensed entity in Los Angeles is selling 'auto protection certificates' that function as physical-damage insurance. Under Ins. Code § 12921.8, what immediate enforcement tool may the Commissioner deploy?

Why this is the answer

Ins. Code § 12921.8 gives the California Insurance Commissioner a powerful administrative tool: a cease-and-desist order against any person transacting insurance without a Certificate of Authority (admitted insurer) or appropriate license (producer/broker). The order may be issued upon a determination of probable violation; the respondent then receives notice and an opportunity for a hearing. After hearing, the Commissioner may make the order permanent and impose civil penalties of up to $5,000 per violation (or $10,000 if willful). The statute lets CDI move quickly against fraudulent 'protection plans' that are functionally insurance. See Ins. Code § 12921.8.