ATLANTA - An excess insurer can be penalized for a primary insurer's failure to file the correct forms with the Florida Department of Insurance, pursuant to Florida's surplus lines law, the 11th Circuit U.S. Court of Appeals said Aug.18 in remanding a coverage dispute to determine if an excess insurer is liable for reimbursing an insured for attorney fees paid as part of an underlying settlement (CNL Hotels & Resorts Inc., v. Twin City Fire Insurance Co., Houston Casualty Co. and Landmark American Insurance Co., No. 07-12706, 11th Cir.; 2008 U.S. App. LEXIS 17686). From Mealey's Emerging Insurance Disputes