Florida’s Department of Financial Services is in the early stages of a far-reaching investigation into the activities of Palm Coast Travel and its affiliated companies, according to documents released this week under the state’s Public Records Act.

The documents also raise new questions about the relationship between Access America, the largest travel insurance company in the world, and Palm Coast Travel, which also does business online as Smartcruiser.com.

In a prepared statement, Access America yesterday suggested its current and future relationship with Palm Coast, which is accused of selling unlicensed insurance, is an internal matter.

“Thus far we have been contacted by both customers identified in the Florida investigation and we are working to resolve each matter appropriately,” a spokesman said. “Access America will continue to take steps consistent with providing ongoing care for its customers.”

(Palm Coast Travel is suing one of its customers and me in an apparent attempt to stop us from writing about the company.)

The records, which were released under Section 119.07(2)(a) of the Florida Statutes, indicate Palm Coast Travel told customers they were Access America policyholders, when, in fact, they were probably not.

One email sent to customer Nancy Swinney from a Smartcruiser agent confirms her insurance policy as “AccessAmerica Insurance.” However, in new charges filed earlier this month against Palm Coast Travel by Florida regulators, the state charges that, “subsequent to [her] scheduled trip, her travel insurance was transferred from AccessAmerica to Prime Travel Protection, Inc.”

Prime Travel Protection closed last year amid charges it was offering unlicensed insurance products.

Another email, sent to customer Peter Lay, confirms his policy as “insurance provided by Access America.” The state alleges that “subsequent to the rescheduling of [his] trip, his travel insurance was transferred from AccessAmerica to Smart Travel Insurance and/or Prime Travel Protection, Inc.” (Lay is being sued by Palm Coast Travel.)

If Florida’s allegations are true — if consumers were told that they had an Access America policy when they did not — then Palm Coast Travel’s actions would be considered false advertising and misrepresentation under Section 626.951(1)(a), (b) and (e) of the Florida Statutes.

The corresponding penalty would be in accordance with Section 626.9521 of the Florida Statutes, which could include a $5,000 fine for each count of non-willful misrepresentation with a cap of $20,000 and a fine of up to $40,000 for willful conduct with a cap of $200,000, along with a revocation or suspension of its license.

As I mentioned in an earlier post, Florida’s actions are the least of Palm Coast Travel’s worries, for now. You really don’t want to get on the wrong side of Access America, the largest travel insurance provider in the world.

Access America wouldn’t comment on the record about its current or future relationship with Palm Coast Travel and Smartcruiser. It would not say on the record whether it will continue to do business with the agency.

It doesn’t have to. Under Florida law, an insurance company must give a 60-day termination notice. So check Smartcruiser.com in 60 days to see if it’s still selling Access America products.

(Photo of a beautiful origami, which may or may not be made out of Prime Travel Protection policies, by DougitDesign.com / Doug Aghassi)