She added, "Policyholders and clients have a right to expect their broker or agent to handle accounts honestly and fulfill their commitments, and we will not accept industry practices that fall short of that expectation."

DCBS said the overcharges involved the receipt of commissions from insurers in addition to the payment of a fee for services agreed to by the public entities. Marsh failed to inform the public entities of the additional commissions.

Last fall, Marsh voluntarily returned $1.2 million in over billed commissions to six Oregon school districts and a community college, the department said. A subsequent investigation by DCBS found an additional $260,000 in overcharges involving other public entity clients.

Marsh has since either returned the money or issued credit to the other affected public operations, the department said.

Three people who were involved in the scheme, Robert Lilly, a senior vice president of Marsh, Debora Leopold Hutchins and Patsy G. Hanson, were terminated by Marsh, officials said.

The insurance department is moving to revoke Mr. Lilly's insurance broker license. Ms. Hutchins and Ms. Hanson are under investigation by the department.

Steve Corson, a spokesman for the DCBS, said by e-mail that a review of other brokers has "found no cause to investigate further at this time."

The fine and reimbursements are not connected to the reimbursement settlement agreement Marsh & McLennan, Marsh's parent company, entered into with New York's Attorney General Eliot Spitzer involving contingent commissions, he said.

MMC entered into the agreement in New York to settle charges it rigged bids and accepted insurers' hidden commissions in exchange for steering clients their way.

According to Mr. Corson, the Oregon action does not affect any of the department's own inquiries that may be underway concerning contingent commissions.

The department expects to take no further action against Marsh, he added.

Barbara Perlmutter, senior vice president of public affairs for MMC said, "We brought this matter to the attention of the Oregon Insurance Division last year and have worked, cooperatively, to correct these problems.

"We paid full restitution to the 22 public entities. The Oregon Insurance Division also concluded that there was no improper conduct involving Marsh's private sector accounts.

"We are also pleased to note that earlier today, the Oregon Insurance Division, like 23 other insurance commissioners across the country signed the agreement that MCC reached with the National Association of Insurance Commissioners on Sept. 21, 2005."