We granted leave to appeal in this declaratory relief action to decide whether Luding-ton Savings Bank’s proposed business plan to purchase and operate an existing insurance agency through its wholly owned subsidiary, Ludington Service Corporation, would violate the Insurance Code. Specifically, we must decide whether the Commissioner of Insurance erred in concluding that the bank’s proposed business plan would violate MCL 500.1207(3); MSA 24.11207(3), MCL 500.2077(2); MSA 24.12077(2), MCL 500.1207(5); MSA 24.11207(5), and MCL 500.1242(3); MSA 24.11242(3). We hold that the commissioner’s findings with respect to §§ 1207(3), 2077(2), and 1207(5) are not supported by competent, material, and substantial evidence. We also hold that the commissioner improperly based his ruling on § 1242(3). Accordingly, we affirm the result reached by the *484Court of Appeals, albeit on somewhat different grounds.
i
Ludington Savings Bank sought to acquire ownership of an existing insurance agency through its wholly owned subsidiary, Ludington Service Corporation (plaintiff).1 Plaintiff proposed to offer life, accident, health, annuities, personal and commercial property, and casualty insurance. Both the insurance and banking operations were to take place in the bank buildings. After preparing a business plan2 that attempted to separate the *485bank’s lending activities from plaintiff’s insurance activities, plaintiff submitted the plan to the office of the Commissioner of Insurance and engaged in informal discussions with agency personnel. Subsequently, however, plaintiff learned that John R. Schoonmaker, the agency’s director of legal resources, had sent a letter to Robert G. Howell, Executive Vice-President of the Michigan League of Savings Institutions, indicating that plaintiff’s business plan could be in violation of the Insurance Code.3
*486Plaintiff promptly filed suit in Ingham Circuit Court, seeking a declaratory judgment and requesting approval to operate the insurance agency in accordance with its proposed business plan.4 Judge Thomas L. Brown dismissed the suit on the ground that plaintiff had not exhausted all its administrative remedies, noting that plaintiff either could seek a declaratory ruling from the commissioner or purchase the agency and contest the revocation proceedings if the commissioner sought to revoke the license.5
Following the court’s dismissal, plaintiff sought a declaratory ruling by the commissioner with regard to whether he would oppose the acquisition or later seek to revoke the license.6 At some point, plaintiff apparently concluded that the commissioner was improperly delaying his decision,7 *487thereby provoking plaintiff to again file suit in Ingham Circuit Court.
Thereafter, on September 15, 1989, the commissioner issued his declaratory ruling in conjunction with his answer to plaintiff’s complaint and filed both with the circuit court. In the declaratory ruling, the commissioner found that plaintiff’s business plan would violate several sections of the Insurance Code.8 Consequently, the commissioner moved for summary disposition on the basis of his findings. After rejecting several constitutional and procedural arguments,9 Judge Brown affirmed the commissioner’s declaratory ruling. Plaintiff appealed Judge Brown’s ruling in the Court of Appeals.
In three separate opinions, the Court of Appeals *488panel reversed both the commissioner’s ruling and the circuit court’s opinion. 194 Mich App 255; 486 NW2d 120 (1992). In the lead opinion, Judge Sawyer stated that he was not convinced that "plaintiff would necessarily violate the code if the agency is operated according to the business plan.” Id. at 258. Judge Shepherd concurred in the result reached by Judge Sawyer, but on the ground that the commissioner’s ruling lacked competent, material, and substantial supporting evidence. Id. at 268. Finally, Judge Connor dissented, asserting that the commissioner’s decisions are entitled to substantial deference, and therefore, found competent, material, and substantial evidence to support the commissioner’s ruling. Id. at 268-270.
We granted leave to appeal, as well as various motions for leave to file briefs amici curiae.10
ii
This case comes to the Court in an interesting procedural posture because, instead of waiting for the commissioner to act upon actual Insurance Code violations, plaintiff exercised its right to a declaratory ruling for advance instruction with respect to whether its proposed business plan would violate the Insurance Code. Essentially, plaintiff sought guidance and approval that would bind the commissioner before making a substantial investment in its proposed business venture. Section 63 of the Administrative Procedures Act specifically permits plaintiff to seek such relief.11 *489Although this is a permissible remedy, we recognize the difficulty in isolating anticipatory violations of the Insurance Code solely on the basis of a proposed business plan.12
Nonetheless, in reviewing the commissioner’s findings, both the Michigan Constitution13 and the *490applicable statute14 direct this Court to examine the commissioner’s authority to issue such a ruling as well as the entire record to determine whether the anticipated violations are supported by competent, material, and substantial evidence. Metropolitan Council No 23 AFSCME v Oakland Co Prosecutor, 409 Mich 299, 330; 294 NW2d 578 (1980), quoting Detroit v General Foods Corp, 39 Mich App 180, 190; 197 NW2d 315 (1972). This Court must uphold the commissioner’s decision " 'if it is supported by such evidence as a reasonable mind would accept as adequate to support the *491decision.’ ” Kieffer v Dep’t of Licensing & Regulation, 169 Mich App 312, 315; 425 NW2d 539 (1988).
Moreover, we recognize that the office of Commissioner of Insurance is an administrative agency "charged with the execution of the laws in relation to insurance . . . and to perform such other duties as may be required by law . . . .” MCL 500.200; MSA 24.1200. Accordingly, this Court, in reviewing the record, will accord the commissioner’s factual findings great deference. Breuhan v Plymouth-Canton Community Schools, 425 Mich 278, 282-283; 389 NW2d 85 (1986), citing Magreta v Ambassador Steel Co, 380 Mich 513, 519; 158 NW2d 473 (1968). Similarly, this Court will accord deference to the " 'construction placed upon statutory provisions by any particular department of government for a long period of time . . . .’” Southfield Police Officers Ass’n v Southfield, 433 Mich 168, 177; 445 NW2d 98 (1989).
A
Against this backdrop, we review first the commissioner’s holding that the bank’s plan would violate § 1207(3) of the Insurance Code, which provides:
Except as provided in section 1212 and subsection (4), an agent shall not reward or remunerate any person for procuring or inducing business in this state, furnishing leads or prospects, or acting in any other manner as an agent.
The commissioner reasoned that the bank’s plan would "amount to procuring or inducing business or furnishing leads or prospects for the Agency,” *492with profits inuring to the benefit of the bank via dividend payments.15 Declaratory ruling at 5.
In addressing THM, Ltd v Comm’r of Ins, 176 Mich App 772; 440 NW2d 85 (1989), the commissioner stated that the same analysis is applicable in the instant case.16 He also suggested that this case could result in an even greater violation of § 1207(3) than in THM. The commissioner reasoned that the business plan’s proposal to permit the bank to control and distribute the mailings, while allowing both companies to inform their customers of their affiliation, would violate § 1207(3)’s prohibition against producing leads or prospects, as well as the prohibition against procuring and inducing business. Declaratory ruling at 6.
*493The Court of Appeals majority held that the commissioner erred in the application of this section. In his lead opinion, Judge Sawyer held that § 1207(3) was limited to a quid pro quo relationship where dividends are distributed in direct proportion to the amount of business referred. Ludington Service, supra at 259-260, citing Lawyers Title Ins Corp v Chicago Title Ins Co, 161 Mich App 183, 193-194; 409 NW2d 774 (1987). Judge Sawyer went so far as to hold that THM was wrongly decided, concluding that § 1207(3) "is not violated where an agency pays a dividend to a shareholder based upon the profits earned by the agency and the shareholder engages in promotion of the insurance agency.” Id. at 261.
On the other hand, Judge Shepherd’s concurrence advocated a more moderate approach. He rejected overruling THM, and instead rested his decision to reverse on the lack of competent, material, and substantial evidence.17 In his opinion, the bank’s business plan adequately addressed the concerns raised in THM. Id. at 268.
We agree with Judge Shepherd that the bank’s business plan satisfied the concerns raised in *494THM. Additionally, we agree that the record is devoid of any other competent, material, and substantial evidence necessary to support a violation of § 1207(3).18 Finally, we are persuaded that the instant case is distinguishable from Lawyers Title and THM.
In Lawyers Title, the Court of Appeals considered a scheme whereby real estate brokers incorporated various title companies in which they were shareholders. The brokers then referred their clients exclusively to these title companies. The brokers/shareholders received dividends based upon the title companies’ profits. In some instances, the dividends were proportionate to the amount of referral business expected to be generated by each broker. The Court of Appeals held that this constituted direct remuneration in violation of § 1207(3). Id. at 193-194.
In THM, the Court of Appeals reached a similar conclusion. The plaintiff was a wholly owned subsidiary of a bank that wanted to set up an insurance agency to handle insurance needs incident to the bank’s mortgage operations. The Court held that Lawyers Title was not limited to direct kickbacks, but held that the "more business [the subsidiary] has, the more profit [the bank] would make regardless of whether any dividends are ever paid.” THM, supra at 785.
In the instant case, we are satisfied that the business plan avoids the direct kickback problem addressed in Lawyers Title. Similarly, we are satis*495fied that the business plan avoids the kickback problem addressed in THM. In THM, it was apparent that virtually all of the subsidiary’s business would come directly from the bank’s referrals pursuant to its lending activities. In the case at hand, however, the commissioner has yet to determine how much business will ensue directly or indirectly from bank referrals and accordingly constitute dividends inuring to the bank.19 Nor has the commissioner pointed to any other evidence of remuneration between plaintiff and the bank. Absent such evidence, we cannot say that a "kickback” scheme as contemplated by § 1207(3) was in place.
Furthermore, because the bank seeks to acquire an existing insurance agency, at least some portion of the business will already be in existence, i.e., business unconnected to the bank’s lending activities. Accordingly, we conclude that the bank has properly shielded its lending activities from its subsidiary’s insurance activities.
B
Next, the commissioner ruled that the business plan would violate § 2077(2), which provides:
If an instrument requires that a purchaser, *496mortgagor or borrower furnish insurance of any kind on real property being conveyed or which is collateral security to a loan, the vendor, mortgagee or lender shall refrain from using or disclosing any such information to his own advantage or to the detriment of the purchaser, mortgagor, borrower, insurance company or agency complying with such requirement.[20]
The commissioner essentially held that the bank’s informational mailings would violate §2077(2) because it would be received by some customers who are required to obtain insurance as a condition of a mortgage. In short, the commissioner reasoned that the bank would use mortgage information improperly to its own advantage, and for the advantage of plaintiif.21
We disagree and hold that the record fails to demonstrate the necessary competent, material, and substantial evidence supporting a violation of *497§ 2077(2). We are persuaded that the bank’s business plan adequately addressed the concerns raised in THM.
In THM, the Court found that the commissioner was concerned with direct targeting of mortgage customers according to expiration dates of their customers’ insurance policies. The Court stated:
The commissioner found that insurance agents accordingly want access to information about expiration dates and that d&n could supply that specific information. The commissioner also cited [the insurance agency’s] proposed marketing strategy for the solicitation of d&n customers which relied heavily upon exploitation of information about expiration dates of policies held by d&n customers. The marketing strategy included direct mail solicitation, telephone solicitation, mailing pieces in d&n outgoing mail and establishing an expiration-date system. [Id. at 778.]
Thus, in THM, there was substantial evidence supporting the commissioner’s decision.
However, in the instant case, the commissioner lacked the necessary direct evidence to find that there would be an improper use of information. As stated in THM, § "2077(2) is clear in that a lender is not to benefit from its knowledge that a borrower must have insurance on the real property which is collateral for the loan.” Id. at 779. We agree that the plain meaning22 of § 2077(2) only proscribes a lender from using insurance requirement information to its own advantage or to the *498mortgagor’s detriment.23 Accordingly, we conclude that the bank’s business plan clearly addressed § 2077(2) by proscribing the use of this information to the detriment of mortgagors and for the benefit either of the bank or plaintiff.24 A generalized and untargeted informational mailing to all customers25 does not exploit the bank’s knowledge that a specific borrower must have insurance as a condition of a loan. Absent direct targeting via mailings, the business plan cannot be said to violate § 2077(2).
c
Additionally, the commissioner relied on MCL 500.1207(5); MSA 24.11207(5) to support his theory that operations in accordance with this proposed business scheme would result in threats and intimidation of bank customers to purchase insurance through plaintiff.26 Section 1207(5) states:_
*499A person may not sell or attempt to sell insurance by means of intimidation or threats, whether express or implied. Except as provided in section 2077(4) a person may not induce the purchase of insurance through a particular agent or from a particular insurer by means of a promise to sell goods, to lend money, to provide services, or by a threat to refuse to sell goods, to refuse to lend money, or to refuse to provide services.
The Court of Appeals majority was not in accord in its treatment of § 1207(5). Judge Sawyer held that the business plan does not threaten to refuse to lend money. Accordingly, he reasoned that the commissioner lacked substantial evidence to support his findings. He contended that § 1207(5) focuses on the actions of the insurance agents rather than the subjective beliefs of customers. Applying this analysis, he held that the business plan, as presently formulated, failed to demonstrate any intended use of threats or intimidation. Id. at 262-265.
Judge Shepherd agreed that the commissioner lacked specific evidence to support his findings, but argued that reasonable subjective beliefs of customers regarding specific acts either of the plain*500tiff or the bank could be considered when evaluating whether threats or intimidation occurred. However, he held that the record failed to demonstrate substantial evidence with regard to specific acts, thereby failing to provide the necessary justification for the commissioner’s ruling. Id. at 268.
In reviewing § 1207(5), we note that the question of threats or intimidation centers only on the commissioner’s fear that the bank will promise or threaten to refuse to lend money. On this issue, we agree with Judge Shepherd that the record lacks the necessary competent, material, and substantial evidence to support a violation of § 1207(5). We need not go so far as the Court of Appeals, however, in deciding whether § 1207(5) focuses only upon the insurance agent’s actions or also considers a customer’s reasonable subjective beliefs. We simply note that the commissioner is afforded great deference in this area. Nonetheless, under either view, the commissioner failed to point to any specific acts27 on the part of the bank or plaintiff.
Furthermore, we disagree with the commissioner’s contention that the bank’s proposed safeguards "promise more than they deliver.” He contends that the safeguards only prevent abuses by loan personnel taking mortgage applications, but not other types of loans. The commissioner also argues that nothing in the plan prohibits bank employees from soliciting business for the plaintiff before a formal loan application is submitted. Declaratory ruling at 12.
Although the proposed business plan may not be *501the most precisely drafted document, we conclude that it clearly does implement safeguards for all loan applications, not just mortgage applications. Under its "Communications” section in its business plan, the bank states:
2. The Savings Bank may advise the general public and its savings and mortgage customers that insurance services are available from the Service Corporation Agency and advise how to obtain more information about the insurance service, except that:
a. such information shall not be occasioned by submission of any loan application, nor any inquiry about the availability, terms, and conditions of any loan. [Business Plan at 5.]
Clearly, therefore, the plan proscribes conduct with regard to all loan activities by addressing both formal submissions of loan applications as well as inquiries.
Similarly, we are not persuaded by the commissioner’s fear that "even assuming the actual practice is in steadfast conformity with the business plan, an employee of \plaintiif\ could approach any loan customer right in the Bank at any point in a loan transaction and personally attempt to sell required insurance.”
This abuse may occur in the future, but at this point the commissioner’s concern is mere speculation, unsupported by substantial evidence. While the language of the business plan specifically addresses only what the bank would or would not do, the business plan and the announced intent of both the bank and plaintiff indicate that plaintiff would not and probably could not engage in such activities. With regard to the actual transfer of *502lending information, the business plan prohibits the bank from transferring it to plaintiff. Therefore, the likelihood of the plaintiff obtaining this information is minimal.
However, were the plaintiff to conduct surveillance of loan applicants and thereafter solicit them to buy their insurance by means of a promise or threat of refusal to lend money via the bank, the commissioner would have adequate grounds to revoke the license under § 1207(5).28 Until this occurs, the commissioner lacks sufficient facts to support a violation.
Finally, we disagree with the commissioner’s conclusion that no adequate regulatory controls are possible to prevent the inherent pressure and intimidation that customers would endure where a subsidiary of a financial institution sells insurance to the financial institution’s borrowers. Declaratory ruling at 9-10, citing THM, supra at 780.29 We *503find that regulatory controls are possible and that the record supports the bank’s intention to implement adequate safeguards in order to address § 1207(5). These intentions are illustrated by not requiring borrowers to purchase insurance from plaintiff, shielding all lending activities from insurance activities, conspicuously marking the separate areas and not displaying any insurance materials in loan application areas, not initiating discussions concerning insurance during the loan application process, and providing written disclosures if inquiries are made. Therefore, at this point, the commissioner lacks specific evidence supporting his claim that the plan permits inducement to purchase insurance by means of a promise or threat of refusal to lend money.
hi
Finally, while this Court affords deference to an agency’s findings of fact, we can always review an agency’s legal findings. Both the Michigan Constitution30 and the applicable statute31 permit this Court to set aside the commissioner’s findings if they are "[i]n violation of the constitution or a statute,” or "[a]ffected by other substantial and material error of law.” Southfield Police, supra at *504175, citing MCL 24.306(l)(a), (f); MSA 3.560(206)(l)(a), (f).
Our reading of § 1242(3) persuades us that the commissioner improperly based his decision32 on this section because it only empowers the commissioner to review the granting and renewing of a license. It does not apply to the acquisition of an existing insurance agency. Section 1242(3) provides:
After notice and opportunity for a hearing, the commissioner may refuse to grant or renew a license to act as an agent, solicitor, adjuster or insurance counselor if he determines by a preponderance of the evidence, that it is probable that the business or primary occupation of the applicant will give rise to coercion, indirect rebating of commissions or other practices in the sale of insurance which are prohibited by law.
While the commissioner acknowledged that plaintiff was only seeking to acquire a licensed insurance agency and limited his ruling to this issue,33 he failed to indicate how and why § 1242(3) applies to a proposal to purchase a licensed insurance agency.34 Therefore, we find that § 1242(3) is *505not implicated by this declaratory relief action.
Moreover, although this Court affords an agency some statutory deference,35 the agency’s interpretation is not binding on this Court, and "cannot be used to overcome the statute’s plain meaning . . . .” Grand Rapids Ed Ass’n v Grand Rapids Bd of Ed, 170 Mich App 644, 651; 428 NW2d 731 (1988) (emphasis added). See also Buttleman v State Employees’ Retirement System, 178 Mich App 688, 690; 444 NW2d 538 (1989), and Allstate Ins Co v Dep’t of Ins, 195 Mich App 538, 545; 491 NW2d 616 (1992).
We conclude that the plain meaning of § 1242(3) clearly limits the commissioner’s powers to the granting or renewing36 of a license. It does not contemplate the acquisition by means of a sale of *506an existing license or the revocation of an existing license.37 The commissioner therefore erred as a matter of law in basing part of his declaratory ruling on § 1242(3).38
*507IV
We conclude that the commissioner lacked the necessary competent, material, and substantial evidence to support his findings of violations of §§1207(3), 2077(2), and 1207(5). Additionally, we find that the commissioner erred as a matter of law in applying § 1242(3) to the instant case. Section 1242(3) is limited to the granting or renewing of a license, as opposed to the acquisition of a licensed insurance agency. Accordingly, we affirm the decision of the Court of Appeals.
Cavanagh, C.J., and Levin, Brickley, Boyle, Griffin, and Mallett, JJ., concurred with Riley, J.