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For which of the following reasons can a bondsman surrender a defendant without returning the premium?

  1. If they fail to notify the surety about a change of address

  2. If the defendant makes a valid court appearance

  3. If the defendant pays the premium in cash

  4. If they have no prior criminal record

The correct answer is: If they fail to notify the surety about a change of address

A bondsman can surrender a defendant without returning the premium if the defendant fails to notify the surety about a change of address. This is significant because maintaining current contact information is a critical responsibility of the defendant under the terms of the bail agreement. Failing to update the surety about a change of address can hinder the bondsman's ability to locate and manage the defendant's case, thus justifying the bondsman's action to surrender the defendant without a refund of the premium. The other options do not support the premise of the bondsman being entitled to keep the premium. A valid court appearance indicates compliance with the conditions of bail, which typically would warrant the return of the premium. Paying the premium in cash is a transactional detail and does not influence the bondsman's rights regarding surrender. Similarly, having no prior criminal record does not provide sufficient grounds for the bondsman to withhold the premium upon surrendering the defendant. Each of these scenarios doesn't involve a breach of the bail agreement that would normally justify the retention of the premium by the bondsman.