The trial court approved transfer of structured settlement payments to a factoring company and ordered the payor insurance company to send the funds directly to the factor, and the insurance company appealed. The Structured Settlement Protection Act [SSPA; Insurance Code section 10134 et seq.] was passed to protect structured settlement payees from exploitation by factoring companies. Pursuant to Insurance Code section 10139.5, an annuity issuer and settlement obligor may not be required to divide payments, and the insurance company argued on appeal that the trial court’s order increased its burdens and risks. The appellate court reversed because the order puts the insurance company in the position of having to rely on another entity to fulfill its contractual obligations to the annuity recipient and would expose the insurance company to litigation if, for example, the factoring company or its assignee sought bankruptcy protection. (RSL Funding, LLC v. Alford (State Farm Fire and Casualty Co.) (Cal. App. Fourth Dist. Div. 2; August 18, 2015) (As mod. September 10, 2015) 239 Cal.App.4th 741 [190 Cal.Rptr.3d 917].)
