It is now clear that the commissioner of the Department of Banking and Insurance (DOBI) can bring an administrative action for violating state laws and insurance practices against "non-admitted foreign insurance companies," carriers that are not licensed in New Jersey, and licensed affiliates in New Jersey. According to the Appellate Division's April 27 opinion in Applied Underwriters Captive Risk Assuance Co. v. Department of Banking and Insurance, a Superior Court action by the attorney general is not the only enforcement mechanism.