M.C.L. § 445.903(1) makes any "[u]nfair, unconscionable, or deceptive methods, acts, or practices in the conduct of trade or commerce…unlawful." However, the statute states that "[t]his act does not apply to or create a cause of action for an unfair, unconscionable, or deceptive method, act, or practice that is made unlawful by chapter 20 of the insurance code of 1956 [the Uniform Trade Practices Act, M.C.L. § 500.2001 et seq.]." M.C.L. § 445.904(3). Indeed, the purpose of the UTPA is "to regulate trade practices in the business of insurance. . . ." See M.C.L. § 500.2002.

101 et. seq., and under the Michigan Uniform Trade Practices Act, MCL 500.2001, et. seq. (Id.