The Utah Labor Commission entered the penalty on September 15, 2023 and made it a court judgment in Salt Lake County on June 4, 2024. The state’s coverage index shows no Utah policy for BAM on the day of the penalty or through late March 2024, and a Hartford policy from spring 2024 on. As of October 28, 2026 the court docket shows no payment on the judgment. BAM’s disclosure documents, which require franchisees to carry workers’ compensation insurance and send BAM proof, say nothing about any of it.
PRIMARY SOURCEThe Labor Commission’s abstract of award in case 22-9-5023517, the Third District Court docket for case 246914299 in Salt Lake County, and the Commission’s public coverage index.
CONFIRMEDA $44,306.12 penalty for noncompliance under Utah Code section 34A-2-211, entered September 15, 2023 and docketed as a judgment on June 4, 2024. As of October 28, 2026 the docket shows no payment, no satisfaction and no collection step.
CONFIRMEDNo workers’ compensation policy on the state’s index for BAM Franchising in Utah on the day of the penalty or at any point through March 25, 2024. From spring 2024 on, a policy written by Trumbull Insurance Company, a Hartford company, for BAM Franchising LLC at the Provo office, still on the index in October 2026.
UNRESOLVEDHow long the gap in coverage ran and how many employees it covered, and whether BAM has paid the judgment without a satisfaction being filed.
Franchisees have to send BAM proof of workers’ compensation insurance. BAM’s own policy begins sometime in spring 2024, six to seven months after the state penalized it.
Conducting business without securing the payment of benefits.
IT IS THEREFORE ORDERED that pursuant to Utah Code Annotated Section §34A-2-211, Bam Franchising Inc, is ordered to pay $44,306.12, to the Uninsured Employers’ Fund as a penalty for noncompliance.
IT IS FURTHER ORDERED that pursuant to Utah Code Annotated Section §34A-2-211 & 212, that Plaintiff shall be entitled to recover from the Defendant, in addition to the amount of the uncollected penalty, reasonable attorney’s fees, cost of court and cost of collection.
Section 34A-2-211 is the penalty for an employer “conducting business without securing the payment of benefits,” the statute’s words for operating without workers’ compensation coverage. The penalty is the greater of $1,000 or “three times the amount of the premium the employer would have paid,” for up to 156 weeks without coverage, and the Division can waive or reduce it on conditions the statute lists. At three times the premium, $44,306.12 works out to about $14,800 of premium as the statute computes it. The abstract does not say whether the penalty was reduced, how long BAM’s gap ran or how many people it employed.
Carry it, and send BAM the proof.
Item 8 of BAM’s disclosure document lists, among the insurance a franchisee must carry, “workers’ compensation insurance as required by applicable law.” The franchise agreement requires “statutory workers’ compensation insurance with limits of greater than $100,000 or the minimum limits required by law.” Item 8 continues:
The insurance coverage must be maintained during the term of the Franchise Agreement, and you must provide evidence of insurance to us that insurance has been obtained from a responsible carrier or carriers acceptable to us.
The same words run through every edition since the penalty: March 31, 2024, March 31, 2025, April 8, 2026 and the September 2026 amendment. None of them mentions the Labor Commission, the Uninsured Employers’ Fund, the penalty or the judgment, and the Item 3 litigation section does not either (Item 3 across the editions).
Nothing through late March 2024. A Hartford policy from spring 2024 on.
The state keeps a public index of which insurer covers an employer on a given date. For BAM Franchising in Utah the index is blank from the day of the penalty through March 25, 2024, then carries one policy from spring 2024 on: six to seven months after the penalty, at least seven weeks before the judgment.
The Commission says the index is not a legal verification of coverage or of its absence, and the index itself says a blank result does not by itself mean an employer was uninsured. The name on the policy is BAM Franchising LLC; the franchisor in the disclosure documents is BAM Franchising, Inc., a Delaware corporation, at the same address.
Six to eleven thousand dollars a year, until 2025.
BAM’s audited statements carry one line for insurance: $5,829 in 2022, $10,912 in 2023, the year of the penalty, $10,585 in 2024, the year of the judgment, and $35,954 in 2025, while its compensation expenses grew from $1.6 million to $5.6 million. The statements do not say what the line holds.
| Fiscal year | Compensation expenses (audited) | Insurance (audited) |
|---|---|---|
| 2022 | $1,605,258 | $5,829 |
| 2023 | $2,334,942 | $10,912 |
| 2024 | $4,314,344 | $10,585 |
| 2025 | $5,607,803 | $35,954 |
BAM’s own ledger for January to May 2026 (October 26) books W-2 wages by department, $113,332.02 of payroll taxes, $195,629.24 of health insurance, an account called Insurance at $3,607.40 and one called Renters Insurance at $1,799.18. No account in it refers to workers’ compensation.
A regulator asked about coverage in Minnesota. BAM said it had no employees there.
Minnesota’s Department of Commerce asked BAM about compliance with its workers’ compensation requirements. On April 30, 2026 Ammon McNeff answered in a one-page letter, which cites Minnesota Statutes section 176.182 and which BAM filed as its proof of workers’ compensation insurance:
BAM had no employees in Minnesota in 2025; and
No workers’ compensation policy was in place for Minnesota, as no coverage was required under the circumstances.
The letter says nothing about Utah, where BAM is based, and nothing about the judgment in Salt Lake County.
A lien on property BAM does not own there, and no collection step on the docket.
Under section 34A-2-212, once the award is docketed it is a lien for eight years on the employer’s real property in that county and can be enforced like any judgment of the district court. The county is Salt Lake. BAM’s office is in Provo, in Utah County, in a building another company owns (the one office), and the Salt Lake County assessor’s owner index lists no parcel in the name of BAM Franchising, BAM IP Holdings or Bricks & Minifigs. As of October 28, 2026, the docket shows no writ of execution and no garnishment.
BAM’s audited statements for 2024 and 2025 carry one note titled Litigation, which calls the company’s liability in its pending cases “not presently determinable” and says management expects no “adverse effect on the financial statements.” Neither year mentions the judgment. The total on the judgment docket is $44,306.12.
The fair reading, and its limit. A noncompliance penalty follows a gap in coverage, which can come from a lapsed policy, a late renewal or a dispute over who counts as an employee, not only from a decision to go without insurance; the abstract does not say how long the gap was or how many employees it covered. A judgment can be paid without a satisfaction being filed, and the state’s index depends on what carriers report, so a blank result is not proof that no policy existed. An insurance line in audited statements can leave out premiums paid through a payroll provider, and its size does not show whether a policy is in it. A company with no employees in Minnesota has no Minnesota coverage to show. The right of reply is open to BAM.
The abstract of award, certified January 2, 2024. The Third District judgment docket for case 246914299, as of October 28, 2026. The April 30, 2026 letter to Minnesota. Utah Code section 34A-2-211. Utah Code section 34A-2-212. The Labor Commission’s coverage verification page and the coverage index itself. The Hartford’s list of subsidiaries, with Trumbull Insurance Company. Item 8 and Item 21 across the editions, on this site’s guide to the disclosure document. BAM’s Minnesota registration file, 9006. The one office: BAM’s Provo address and its landlord.
Sources. Utah Labor Commission, Industrial Accidents Division v. BAM Franchising Inc, case 22-9-5023517: Abstract of Award certified January 2, 2024, one page, quoted verbatim. Third Judicial District Court, Salt Lake County, case 246914299, Abstract of Judgment: the docket as of October 28, 2026, one page. Utah Code sections 34A-2-211 and 34A-2-212 as published by the Utah Legislature, quoted verbatim. Workers Compensation Coverage Verification, the Utah Labor Commission’s coverage index operated by NCCI, for BAM Franchising in Utah, September 2023 through October 2026. The Hartford Financial Services Group, Inc., Form 10-K for 2022, Exhibit 21.01, listing Trumbull Insurance Company among its subsidiaries. Salt Lake County Assessor’s owner-name index, October 2026. BAM Franchising, Inc., franchise disclosure documents issued March 31, 2024, March 31, 2025 and April 8, 2026 and the September 2026 amendment (Minnesota file 9006): Item 8 and the franchise agreement’s insurance section, quoted verbatim, and Item 3 and Item 7 note 4, neither of which mentions the penalty; the audited consolidated statements of operations for the years ended December 31, 2025, 2024, 2023 and 2022 (the Compensation expenses and Insurance lines) and Note 10 (quoted verbatim); and the Management Report for the period ended May 31, 2026, Exhibit H to the September 2026 amendment (Minnesota document 37254-202609-02), accounts 6060, 6330, 6380, 6390 and 6440. Letter of Ammon McNeff to the Minnesota Department of Commerce, April 30, 2026, filed as Proof of Workers’ Compensation Insurance (Minnesota file 9006, document 36508-202605-02), quoted verbatim. Everyone named here is presumed to have acted lawfully.