... objections to the 2002 special purpose apportionment (SPA) pursuant to N.J.S.A. 17:1C-20. This is a final agency decision appealable to this court ... was calculated in an improper manner. We agree and reverse. N.J.S.A. 17:1C-20 permits the Commissioner to apportion DOBI's expenses among every ... total of all such net premiums received by all companies." N.J.S.A. 17:1C-20. The term "net premiums received" is defined as "gross premiums ... the 2002 SPA, arguing that the apportionment is contrary to N.J.S.A. 17:1C-20 because the "deposit-type" funds paid by annuity holders are ... the SPA was not calculated in a manner consistent with N.J.S.A. 17:1C-20. We agree. From our review, we conclude that the 2002 SPA contravenes N.J.S.A. 17:1C-20 because it is based in part on amounts that ...