# Insurance-contribution audit; September 20, 2026

**The existing dataset is incomplete. The checked direct transactions reconcile, but completeness and donor classification require separate judgments. No reliable carrier-versus-policyholder ratio is established by this audit.**

Scope: January 1, 2022–September 20, 2026; Florida state Senate candidate receipts and the same 15 senator-associated committees used in the original analysis. Direct comparisons retain the previous recipient roster; they are not a complete reconstruction of everyone who served during the period. Committee receipts are legally distinct from campaign receipts.

## What passed

All **355 previously included direct campaign transactions** match the 64,419-row official annual State Senator query population on normalized recipient, donor, date, signed amount and contribution type. This is a field-match test, not a check-image, amendment-chain, or independent affiliation audit. The state-query population includes unsuccessful candidates and does not itself establish who served.

The additional **70 statewide donor-name queries contain 6,883 source observations**. Every captured query's parsed count and signed sum reconcile to its displayed state total. These observations overlap and include unrelated donors and non-Senate recipients; they are not 6,883 unique insurance donations. Source observation IDs are snapshot-line references, not official transaction IDs.

## Review-ready coverage additions

The files identify **50 direct records totaling $49,000** within the previous recipient roster, plus **46 receipts totaling $240,500** at the previously reviewed committees. These are additions to the included coverage, including one FCCI receipt previously present but excluded. They are not a combined homeowners-carrier total. They remain a separate review-ready patch rather than silently changing the published ledger. Filing-level identity, amendments and duplicate reconciliation remain limitations.

| Donor family  | Direct: records / amount | Same 15 committees: records / amount |
| ------------- | -----------------------: | -----------------------------------: |
| Jerger MGA    |               2 / $1,000 |                               0 / $0 |
| Southern Oak  |                   0 / $0 |                           5 / $6,500 |
| FCCI          |             34 / $34,000 |                        29 / $188,000 |
| Assurant PAC  |               9 / $9,000 |                          7 / $24,500 |
| Travelers PAC |               4 / $4,000 |                          5 / $21,500 |
| FAIA PAC      |               1 / $1,000 |                               0 / $0 |

Every row in [the contribution table](review-ready-additions.csv) has a state source URL, a local snapshot citation and a separate affiliation source. [The JSON ledger](review-ready-additions.json) preserves reported addresses, legal-name truncation, category and review status. Links to specific source lines are clickable in [the audit viewer](index.html).

Only **$1,000 of the direct additions (two Jerger MGA payments)** and **$6,500 of the committee additions (five Southern Oak Management payments)** are placed in the residential-carrier-affiliate category. FCCI is commercial P&C; Assurant and Travelers entries are employee-funded PACs; FAIA is an agent PAC. Corporate affiliation does not demonstrate the donor's motivation for a particular contribution.

## Classification decisions and independent PAC research

- **Jerger MGA:** the [company's own description](https://jergermga.com/) identifies its relationship to American Traditions. Two $500 direct receipts are Doug Broxson, October 25, 2022, and Don Gaetz, November 2, 2023. Retain each reported spelling; normalize punctuation for lookup only.
- **Southern Oak Management:** the [OIR examination](https://floir.com/docs-sf/property-casualty-libraries/financial-examination-reports/2022/southern-oak-insurance-company-exam-report---to-publish.pdf?sfvrsn=4a471eb_4#page=8) identifies the MGA affiliation. The exam also documents homeowners business. This is an operating affiliate, not a PAC. Evidence is dated; ownership should not be assumed unchanged indefinitely.
- **FCCI:** [2025 consolidated financial statements, page 13](https://static.fcci-group.com/files/documents/2025-FCCI-Annual-Report-Financial-Statements.pdf#page=13) identify Group, Services, Agency and Insurance Group entities in the group. [FCCI's product description](https://www.fcci-group.com/content/fcci/en/commercial-insurance-coverages.html) supports commercial P&C classification. This is broader industry coverage, not proof of homeowners-specific giving. Legal-form variants not supported by the registry remain unresolved.
- **Assurant PAC:** [FEC C00185694](https://www.fec.gov/data/committee/C00185694/) identifies the connected committee; the [2023 SEC proxy](https://www.sec.gov/Archives/edgar/data/1267238/000126723823000020/aiz-20230323.htm) describes voluntary employee funding. Record the PAC as a separate legal donor; do not label these corporate treasury contributions or assume all donors work in homeowners insurance. Truncated state names require filing-level confirmation before final integration.
- **Travelers T-PAC:** [FEC C00376376](https://www.fec.gov/data/committee/C00376376/) and [Travelers' political-contribution policy](https://sustainability.travelers.com/drivers-of-sustained-value/public-policy/political-process-commitments-contributions) establish the connected employee-funded PAC. Corporate Travelers entities remain distinct. FEC evidence is used for PAC identity, not to add federal campaign spending to this Florida analysis.
- **FAIA PAC:** the [association's PAC description](https://www.faia.com/educationandadvocacy/advocacy-home/political-action) supports an insurance-agent category. The additional Tracie Davis receipt is $1,000. Agents are not automatically synonymous with insurance carriers.

## Policyholder-side correction and false-positive protections

A $500 direct Ben Albritton receipt on October 17, 2022 uses **PUBLIC ADUSTERS FOR THE INSURING PUBLIC**. The PAC's expenditure export reports $500 to BEN ALBRITTON CAMPAIGN on October 10, 2022. Name, address and payee/amount support a probable spelling correction, but the seven-day date difference remains explicit. See [the recipient row](sources/senate-2022.html#L18573), [the sender row](sources/public-adjusters-expenditures.html#L494), and [the review record](policyholder-spelling-review.json). Do not count the two sides of the transfer twice. This remains an identity-reconciliation item, not an unconditional final-ledger change.

“Florida Family Medicine” must not match Florida Family Insurance; “CES Nationwide” must not match Nationwide Insurance. A donor with “insurance” in a political committee's name is not necessarily carrier-funded. Florida Justice Reform must not be confused with Florida Justice PAC. Keyword searches are discovery tools, never sufficient classification evidence. These are hazards found during screening, not proof that those false positives were published in the old included ledger.

Public-adjuster organizations represent a policyholder-service business interest; plaintiff-lawyer PACs can cover many issues besides homeowners insurance. Individual attorneys and firms need their own evidence. The Southern Oak exam also illustrates overlapping affiliations: named attorney directors are associated with Pajcic & Pajcic. Neither a legal occupation nor a firm name proves an exclusively opposing side.

## Rules for an accurate comparison

1. Preserve the transaction as reported, with recipient entity, date, amount, type, refund sign and source. Never overwrite source spelling with an inferred identity.
2. Resolve legal donor identity independently: committee IDs, corporate parent/affiliate documents, address and effective dates. A shared treasurer, address or lobbying firm alone is insufficient.
3. Store separate fields for sector, donor entity type, funding source, confidence, supporting evidence and unresolved conflicts. Use mixed/unassigned when needed.
4. Do not assume all money in a mixed-funded PAC originates with carriers or policyholders. Report funding composition separately; allocation formulas are estimates, not traceable dollars.
5. Keep incoming PAC funding and outgoing contributions in separate layers. Never add both to the same donation total. Keep candidate receipts, associated-committee receipts, party transfers and independent expenditures separate.
6. Use identical dates, recipient universe, contribution types, refund treatment and evidence thresholds on both sides. Unreviewed means unknown, not zero.
7. Do not deduplicate solely on donor/date/amount. Identical payments may be legitimate; amended filings require report/sequence identifiers and version history.

## Remaining limitations and severity

**High; completeness:** seventy targeted donor queries do not enumerate every subsidiary, executive, lobbyist, insurer-sponsored entity or transfer path. The 15-committee footprint remains selected. Other Senate candidates in the raw results require service-date review before inclusion. No claim of statewide completeness is justified.

**High; classification:** the inherited donor registry retains prior classifications; this pass independently researched the newly identified families above, not every historical PAC dossier. A carrier-only or policyholder-only aggregate must exclude mixed and unresolved cases. Broader attorney money cannot automatically stand in for homeowners-policyholder money.

**High; filing reconciliation:** query-level totals pass, but report sequence IDs, amendment histories and original check images were not fully reconciled. Potential unmatched old-family committee entries may be truncated-name matches or duplicate observations. They are in a separate unresolved queue and excluded from the addition totals.

**Medium; temporal comparability:** the cutoff is the capture date. Later or amended filings can change earlier totals. Corporate and PAC identity evidence has specific document dates; the full ownership/control timeline has not been reconstructed.

The next integration gate is filing-level reconciliation of the patch and unresolved queue, followed by the same donor-identity standard on both sides and a complete committee/service-date universe. Until then the correct site wording is “documented contributions in the reviewed records,” with coverage and category filters;not “all donations.”

## Reproducibility

[Prior transaction check](prior-direct-record-audit.json); [query manifest](manifest.json); [raw observations](records.json); [donor registry](donor-registry.json); [remaining review queue](unresolved-potential-additions.json); [notebook](audit.ipynb). Raw text snapshots and line-numbered HTML are in sources/. SHA256SUMS.json records file hashes. The live site and existing main ledger were not altered.