As a member of the California Insurance Guarantee Association (“CIGA”), Virginia Surety Company had paid all CIGA premium assessments billed until 2007. In July 2006, Virginia Surety had notified the California Insurance Commissioner that it was not renewing any non-warranty coverages in California, including workers’ compensation. As a result of Virginia Surety’s ceasing its workers compensation placements and renewals,adjustment of prior assessments by CIGA demonstrated overpayments in those prior payments and resulted in a credit due to Virginia Surety’s account. Virginia Surety sought a refund of that credit from CIGA. On November 15, 2007, CIGA adopted rules regarding assessment credits and rejected Virginia Surety’s request for a refund. Virginia Surety appealed to the Commissioner.