The Iowa Commissioner of Insurance (the “Commissioner”) filed a petition, on January 29, 2015, seeking to liquidate CoOpportunity Health, Inc. (“CoOpportunity”), a Consumer Operated and Oriented Plan (“CO-OP”) established under the Affordable Care Act (“ACA”) that has sold health insurance on the Iowa and Nebraska Exchanges.

In a much anticipated decision, the Florida Supreme Court closed a statutory loophole that permitted debtors to use a wholly owned limited liability company (LLC) to put their assets beyond the reach of their judgment creditors. In Olmstead v. FTC, Case No. SC08-1009 (Fla. June 24, 2010), the Florida Supreme Court ruled that a court may order a judgment debtor to surrender all right, title, and interest in the debtor's single-member Florida limited liability company to satisfy an outstanding judgment.