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stated hereinafter.

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The Director FINDS that:

FINDINGS OF FACT

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1.

Robert Warren Spruill, a resident ofthe State of Washington, is an

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insurance producer licensed to conduct insurance business in the State of Oregon

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(License # 145167). Spruill is authorized to sell health, property, casualty and life

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insurance products in Oregon. He does business under a number of assumed

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business names, including Brooke Auto Insurance Services and Brooke Agency

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Services Company, LLC (hereinafter "Brooke Auto"). Brooke Auto has offices located

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at 1513 NE 181st Avenue, Portland, Oregon 97230.

2.

The Oregon Consumer Identity Theft Protection Act requires persons

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who own, maintain or otherwise possess data that includes a consumer's personal

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information that is used in the course of the person's business, vocation, occupation

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or volunteer activities to develop, implement and maintain reasonable safeguards to

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protect the security, confidentiality and integrity of the personal information,

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including disposal of the data.

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3.

A person that is subject to and complies with regulations promulgated

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pursuant to Title V of the Financial Services Modernization Act of 1999, otherwise

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known as the Gramm-Leach-Bliley Act, 15 USC § 6801, et seq., is deemed to be in

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compliance with provisions of the Oregon Consumer Identity Theft Protection Act.

4.

The Gramm-Leach-Bliley Act requires the primary regulator of financial

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services providers, which for insurance producers would be the Oregon Insurance

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Division, to establish appropriate standards to respect the privacy of insurance customers and to protect the security and confidentiality of those customers'

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nonpublic information. In furtherance ofthis federal requirement, the Director,

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pursuant to the Oregon Insurance Code, ORS Chapter 731, et seq., has adopted OAR

Page 2-CEASE AND DESIST ORDER - Robert Warren Spruill (ID-09-0027)

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