this regulatory settlement agreement (the … · medical insurance services, llc ... lead states...

REGULATORY SETTLEMENT AGREEMENT

This REGULATORY SETTLEMENT AGREEMENT (the "Agreement") is entered into this 19^!;day of December. 2017 by and among: (i) HCC Life Insurance Company ("HCC Life"); (ii) HCCMedical Insurance Services, LLC ("HCC MIS") ; (iii) HCC Insurance holdings, Inc.("Holdings") (HCC Life, HCC MIS and Holdings, together with their respective Affiliates, collectivelyreferred to herein as the "HCC Group"); (iii) the FLORIDA OFFICE OF INSURANCE REGULATION("FOIR"); (iv) the INDIANA DEPARTMENT OF INSURANCE ("IDOI"); (v) the KANSAS INSURANCEDepartment ("KID"); (vi) Utah Insurance Department ("UID") (FOIR, IDOI, KID and UIDcollectively referred to herein as the "Lead States"); and (vii) the insurance-related regulatory bodies ofsuch other jurisdictions .as choose to adopt, agree to and approve this Agreement (the "SubscribingStates") (Subscribing States and Lead States collectively referred to herein as the "Settling States") (theSettling States and HCC Life are collectively referred to herein as the "Parties").

RECITALS

WHEREAS, Holdings is the parent company of HCC Life and of HCC MIS;

WHEREAS, HCC MIS was established in Indianapolis, Indiana in 1998;

WHEREAS, during the Examination Period, HCC Life (NAIC #92711) marketed and sold short-term medical insurance products ("STM Products" as defined in Section 2 below) throughout the UnitedStates;

WHEREAS, the Settling States have regulatory jurisdiction over the business of insuranceconducted in their respective jurisdictions, including the authority to conduct market conductexaminations;

WHEREAS, the IDOI, as managing Lead State, advised HCC Life on May 13, 2016, that amultistate market conduct examination (the "Examination") had been called regarding HCC Life'swriting, form filing, marketing, soliciting and claims payment of STM Products during the periodMarch 23,2010 through April 30,2016 (the "Examination Period");

WHEREAS, there are presently forty-two (42) jurisdictions participating in the Examination, ofwhich STM Products were sold by HCC Life in thirty-nine (39) (the "Participating States") includingthe four (4) Lead States and thirty-eight (38) Participating States, a list of which may be found on ExhibitA, attached hereto and by reference incorporated herein;

WHEREAS, the Examination was conducted in conjunction with a separate multistateexamination of third parties. Health Insurance Innovations, Inc. (ORG # 118438), Health PlanIntermediaries, LLC, and their parent companies and Affiliates (collectively, "HIT). Through HIl'snetwork of agents and call centers, HII marketed, sold and collected premium for HCC Life's STMProduct (as defined in Section 2 below). The multistate examination of HII (the "HII Examination")continues;

WHEREAS, the Examiner-in-Charge has presented to HCC Life and the Lead States apreliminary statement based on information gathered to date;

WHEREAS, HCC Life denies any wrongdoing or activities that violate any applicable insurancelaws or regulations, and nothing contained herein, or the execution and performance of this Agreement

Regulatory Settlement Agreement NAIC No. 92711 Execution Copy33J2684 ]

shall be deemed or construed as evidence, or an admission or acknowledgment by HCC Life of anywrongdoing or liability whatsoever;

WHEREAS, based upon the review and analysis of the preliminary statement presented by theExaminer-in-Charge, HCC Life agrees to the conditions of this Agreement and the resolution of thosematters within the scope of the Examination as set forth in the April 26, 2016 Examination Warrant,which scope remains unchanged, (the "Examination Scope") all as more particularly provided herein;

WHEREAS, in view of the foregoing facts and circumstances, the Settling States find it to be in-the public interest and are willing to accept this Agreement to settle all insurance regulatory matterswithin the Examination Scope;

WHEREAS, effective June 1, 2017, HCC Life no longer markets or sells STM Products in theSettling States;

WHEREAS, HCC Life has cooperated with the Examiner-in-Charge in the course of theExamination by making its books and records available for examination, and its personnel and agentsavailable to assist as requested by the Examiner-in-Charge;

WHEREAS, HCC Life represents that at all times relevant to this Agreement, HCC Life and itsofficers, directors, employees, agents and representatives acted in good faith; and

WHEREAS, HCC Life and the Settling States execute this RSA knowingly and voluntarily, andthe Parties acknowledge that this Agreement is in the public interest and desire to end the Examination.

NOW, THEREFORE, in consideration of the Recitals, the mutual covenants and agreementsherein, and each act performed and to be performed hereunder, the Parties agree as follows:

]. Incorporation of Recitals. The above and foregoing Recitals, including, without limitation, allcapitalized terms defined therein, are hereby incorporated into and made a part of this Agreementas if more fully set forth in the body of this instrument.

2, Definitions. The terms listed below shall have either the meaning given in this section or thedefinition given elsewhere in the Agreement.

a. "Affiliate" shall mean a person that directly, or indirectly through one or more intermediaries,controls or is controlled by, or is under common control with, the person specified.

b. "Agreement" shall have the meaning set forth in the first paragraph of page 1.

c. "Agreement Date" shall be the date first written in the first paragraph of this Agreement.

d. "Audit Procedures" shall have the meaning set forth in Section 4e. of this Agreement.

e. "Business Practice Audit" shall have the meaning set forth in Section 4c. of this Agreement.

f. "Claims Audit" shall have the meaning set forth in Section 4b. of this Agreement.

g. "Conditional Effective Date" shall be the date on which this Agreement has been signed byHCC Life and adopted by each of the four (4) Lead States.

Regulatory Settlement Agreement NAIC No. 92711 Execution Copy3312684 1

h, "Examination" shall have the meaning set forth in the first paragraph of page 1.

i. "Examination Scope" shall have the meaning set forth in the tenth .clause of the Recitals.

j. "Examiner-in-Charge" shall mean Chad T. Walker of the law firm Bose McKinney &Evans LLP.

k. "Final Effective Date" shall have the meaning set forth in Section 10. [April 2, 2018]i 1

1. "FOIR" shall have the meaning set forth in the first paragraph of page 1.

m. "HCC" shall have the meaning set forth in the first paragraph of page 1.

n. "HCC Life" shall have the meaning set forth in the first paragraph of page 1.

o. "HCC MIS" shall have the meaning set forth in the first paragraph of page 1.

p. "HCC Third Party Audit" shall have the meaning set forth in Section 4d. of this Agreement.

q. "HCC Life STM Policies" shall mean any STM Products sold, marketed, underwritten orissued by HCC Life, either directly or indirectly through third parties, including, withoutlimitation, HIL

r. "HII" shall have the meaning set forth in the sixth clause of the Recitals.

s. "HII Exammation" shall have the meaning set forth in the sixth clause of the Recitals.

t. "Holdings" shall have the meaning set forth in the first paragraph of page 1.

u. "IDOI" shall have the meaning set forth in the first paragraph of page 1.

v. "KID" shall have the meaning set forth in the first paragraph of page 1.

w. "Lead States" shall have the meaning set forth in the first paragraph of page 1.

X. "Multistate Payment" shall have the meaning set forth in Section 5a. of this Agreement.

y. "Participating States" shall have the meaning set forth in the fifth clause of the Recitals.

z. "Parties" shall have the meaning set forth in the first paragraph of page 1.

aa. "Settling States" shall have the meaning set forth in the first paragraph of page 1.

bb. "STM Products" shall mean the approved short-term medical insurance policies as filed byHCC Life and sold to individuals, either directly or through a group, with limited coverageperiods as determined by applicable state laws and regulations.

cc. "Subscribing States" shall have the meaning set forth in the first paragraph of page 1.

dd. "UID" shall have the meaning set forth in the first paragraph of page 1.

Regulatory Settlement Agreement NAIC No. 92711 Execution Copy33I26S4 I

3. Short Term Medical Business. HCC Life represents to the Settling States that, effective June 1,2017, it ceased the sale, marketing and underwriting and premium collections' of all STMProducts directly or indirectly offered or underwritten by HCC Life, except as otherwise requiredin order to conduct the run-off of its STM business in accordance with applicable laws andregulations. HCC Life covenants and agrees that it shall not directly or indirectly enter into thesale of short-term medical insurance within any of the Settling States for a period of five (5) yearsfrom the Final Effective Date. In the event HCC Life commences the sale or marketing of STMProducts in any Settling State following such period, HCC Life shall file forms and rates asrequired by applicable laws and regulations.

4. Specific Business Practices and Reforms.

a. HCC Life shall administer and adjudicate any and all claims filed in relationship to HCCLife STM Policies in a timely fashion and in strict compliance with the terms andconditions of the policies and any and all applicable laws, rules, and regulations.

b. Within one hundred twenty (120) days of the Final Effective Date, the Examiner-in-Charge shall commence a preliminary audit (in accordance with the NAIC MarketRegulation Handbook) of HCC Life's claims handling practices for the STM Productsfor the period of June 1, 2017 through the date of the commencement of suchexamination (the "Claims Audit"). Upon completion of the Claims Audit, the Examiner-in-Charge shall present his preliminary findings to the Lead States. The Claims Auditcovers a period of time beyond the scope of the original Examination, and, therefore, theLead States reserve thfe ri^t to additional examinatiOn($) of HCC Life as a result of theClaims Audit together with the right to impose financial, regulatory, and performancesanctions with respect thereto. HCC Life shall be responsible for the full, complete, andprompt payment of all fees and expenses of the Examiner-in-Charge in conducting andreporting on the Claims Audit in compliance with the laws of the State of Indiana. Uponthe request of a Participating State, the Examiner-in-Charge shall provide any finalreports regarding the Claims Audit previously provided to Lead States to suchParticipating State.

c. Within ninety (90) days of the Final Effective Date, the Examiner-in-Charge shallcommence a preliminary audit (in accordance with the NAIC Market RegulationHandbook) of HCC Life's business practices for the STM Products to include, withoutlimitation, writing, form filing, marketing, soliciting, claims payment, licensing andappointments (the "Business Practice Audit"). Upon completion of the BusinessPractice Audit, the Examiner-in-Charge shall present his preliminary findings to the LeadStates, The Lead States reserve the right to additional examination(s) of HCC Life as aresult of the Business Practice Audit together with the right to impose financial,regulatory, and performance sanctions with respect thereto. HCC Life shall beresponsible for the full, complete, and prompt payment of all fees and expenses of theExaminer-in-Charge in conducting and reporting on the Business Practice Audit incompliance with the laws of the State of Indiana. Upon the request of a ParticipatingState, the Exarainer-in-Charge shall provide any final reports regarding the BusinessPractice Audit previously provided to Lead States to such Participating State.

' The Parties acknowledge that HCC Life continues to collect premiums on in-force business at the time ofwithdrawal from the applicable market.


d. HCC Life shall regularly audit the business practices of its producers, third partyadministrators, managing general agents, and contractors across all lines of its business,and make commercially reasonable efforts to ensure compliance with all applicable laws,rules and regulations and operate in a sound fashion (the "HCC Life Third PartyAudit").

e. Within 180 days of the Final Effective Date, HCC Life shall, to the . extent it deemsnecessaiy, establish, document, and provide to the Examiner-in-Charge standards and

1 procedures to conduct regular audits of its internal and third-party operations across alllines of business (the "Audit Procedures"). Such Audit Procedures shall include reviewof controls in place to ensure compliance with filed rating plans, form usage, licensing,appointments, marketing, claims handling, sales, and premiums are in compliance withapplicable laws, rules and regulations. Upon receipt of Audit Procedures, the Examiner-in-Charge shall provide the Audit Procedures to the Lead States, who in turn shall reviewand either approve or return to Company with directions for further revision.Alternatively, at the discretion of the Lead States, the Lead States may direct theExaminer-in-Charge to review the Audit Procedures and provide the Lead States with asummary of such Audit Procedures and the findings, if any, of the Examiner-in-Charge.Any review of such Audit Procedures by the Examiner-in-Charge shall be at the expenseof HCC Life.

5. Multistate Payment & Release.

a. HCC Life shall pay a total of $5,000,000 to the Settling States for the examination,administrative costs and compliance in connection with the Examination (the "MultistatePayment"). This payment shall be allocated among the Settling States as they agree.

b. Except as otherwise specifically provided herein, and provided HCC Life's full andcomplete compliance with this Agreement, the Multistate Payment shall be the soleamount charged, assessed or collected by the Settling States on HCC Life with respect tothe Examination Scope during the Examination Period.

c. Within ten (10) days of the Final Effective Date, the Examiner-in-Charge shall provideHCC Life a document reflecting how the Multistate Payment is to be allocated among theSettling States.

d. HCC Life acknowledges the validity and legitimacy of the Multistate Payment and shallpay the Multistate Payment within 30 days of the Final Effective Date. Once paid byHCC Life, the Multistate Payment is final and non-recoverable under any circumstances,including without limitation termination of this Agreement. However, HCC Life reservesall ,rights to pursue a private cause of action against third parties, and the Settling Statesagree that nothing in this Agreement precludes HCC Life from exercising any suchrights.

6. Cooperation with HIl Examination. HCC Life shall continue to fully and completely cooperatewith the Lead States and the Examiner-in-Charge with respect to the continuing HII Examination.HCC Life shall voluntarily (without service of subpoena) provide any and all unprivileged books,records, documents, instruments, writings, data or other tangible evidence available and requestedby the Examiner-in-Charge and shall make HCC Life personnel available as requested by theExaminer-in-Charge as such information and personnel relate to the HII Examination.


7. Regulatory Oversight. The Lead States shall maintain regulatory authority and oversight overHCC Life's compliance with the terms of this Agreement. With respect to such continuingoversight, HCC Life agrees as follows:

a. For a period of twenty-four (24) months following the Final Effective Date, HCC Life shallprovide to the Examiner-in-Charge semi-annual reports on the implementation and executionof the requirements of this Agreement. ■ Each report shall be delivered to the Examiner-in-Charge within 45 days following the end of the applicable reporting period (e.g.

11/16/18; 5/17/19; 11/16/19; 5/17/2pinsert due dates based on execution date]. Copies of these reports will be providedto the Lead States as well as to the Participating States' respective designated examiners,

, upon their request.

b. Twenty-Four (24) months following the Final Effective Date, the Lead States, through theExaminer-in-Charge, shall conduct a preliminary audit in accordance with the NAIC MarketRegulation Handbook) multistate examination on their own behalf and that of the SettlingStates of HCC Life's compliance with the requirements of this Agreement. The Lead Statesshall provide a report summarizing the results of that examination to HCC Life and theSettling States. HCC Life shall be responsible for the full, complete and prompt payment ofall fees and expenses of the additional audit(s) and of Examiner-in-Charge in conducting andreporting the additional audit(s) in compliance with the laws of the State of Indiana.

c. In addition to any payments otherwise provided in this Agreement, the costs of the SettlingStates related to the monitoring of HCC Life's compliance with the Agreement, includingcosts and expenses of conducting any reviews or examinations permitted herein, the costs andexpenses of the Examiner-in-Charge as it relates to his obligations hereunder, as well as-participating in any meetings, presentations or discussions with HCC Life and the costs ofany third-party examiner(s), shall be the full and sole responsibility of HCC Life as costs ofthe Examination.

8. Release. Subject to HCC Life's full and complete performance of and compliance with the termsand conditions in this Agreement, each Participating State hereby releases the HCC Group fromany and all claims, demands, interest, penalties, actions or causes of action that each ParticipatingState may have or could have alleged by reason of any matter, cause or thing whatsoever,regarding or relating to the subject matter of the Examination within the Examination Period;provided, however, that nothing herein shall preclude the Lead States from conductingsubsequent examinations to assess HCC Life's compliance with this Agreement or such otherexaminations or audits as expressly provided herein,

9. Default.

a. HCC Life's failure to comply with any material provision of this Agreement shallconstitute a breach of the Agreement, a violation of an order of the Settling States and aviolation of HCC Life's Agreement with the Settling States, and shall subject HCC Lifeto such administrative and enforcement actions and penalties as each Participating Statedeems appropriate, consistent with each Participating State's respective laws.

b. Any agreement on the part of any party hereto to any extension or waiver shall be validonly if in writing signed by the party granting such waiver or extension and, unless itexpressly provides otherwise, shall be a one-time waiver or extension only, and any suchwaiver or extension or any other failure to insist on strict compliance with any duty or

Regulatory Settlement Agreement NAIC No. 92711 Execution Copy3312684 I

obligation herein shall not operate as a waiver or extension of, or estoppel with respect to,any continuing, subsequent, or other failure to comply with this Agreement.

c. If a Settling State believes that th& Company has breach a provision of this Agreement,that Settling State shall proyide written notice of the alleged breach to HCG Life ar^ willalso noti^ the Lead States that the allied breach has occurred. HGC Life shall have theopportunity, within thirty (30) days of receipt of such notice, to present evidence inwriting and through appearance before the complaining state insurance regulator in anattempt to rebut the allegation(s) or to seek an extension to address the alleged breach. ASettling State shall not pursue any orcement action as set forth in Section 9.a. againstHOC Life until the 30-day response period described above has expired.

10. Effectiveness.

a. This Agreement shall be finally effective on the date in which the Examiner-in-Chargeprovides HOC Life with a copy of this Agreement adopted, agreed to, and approved bythe first to occur of (I) twenty-five Settling States or; (ii) sixty percent (60%) of the grosspremium written during the Examination Period, as identified by the Examiner-in-Charge(the "Final Effective Date"). Except as provided in Subsection c of this Section 10, theFinal Effective Date shall be 90 days after the Conditional Effective Date.

b. The Examiner-in-Charge shall arrange to deliver this Agreement within seven (7)calendar days following the Conditional Effective Date to the Participating States.Participating States may adopt, agree to, or approve the Agreement by means of the■Subscribing State Adoption Form attached as Exhibit B and by reference hereinincorporated.

c. The Lead States and HCC Life may agree in writing to extend the initial Final EffectiveDate and each extended Final Effective Date thereafter in writing, in which case theExaminer-in-Charge shall notify the Participating States who may then choose whether toparticipate hereunder on or before the date of the extended Final Effective Date.

d. If the Final Effective Date does not occur by the initial Final Effective Date provided inSubsection a. of this Section 10, or such extended Final Effective Date thereafter asprovided in Subsection c. of this Section 10, this Agreement shall be deemed null andvoid and of no further force or effect.

11. Additional Terms.

a. No Admission. This Agreement represents a compromise of disputed matters between theParties. Neither this Agreement, nor any of the communications or negotiations leadingup to this Agreement, nor any actions taken or documents executed in connection withthis Agreement, is now or may be deemed in the future to be an_admission or evidence ofany liability or wrongdoing by the HCC Group or any of its current or former affiliates,subsidiaries, officers, directors, employees, agents or representatives with respect to thesubject matter of the Examination or the Examination Scope.

b. Third Party Reliance. This Agreement is an agreement solely between the named Partiesas defined above, and no other person or entity shall be deemed to obtain or possess anyenforceable rights against the HCC Group as a third party beneficiary or otherwise as aresult of this Agreement. The Parties agree that this Agreement is not intended to and


shall not confer any rights upon any otte perscai or entity and 11 ik^ be used fea" anypur|K)se. Nothing in this Agreement slmll be construed to provide a fH-ivate right

of action to any pers^ or entity not a patty to tlus Agreement. Nor shaU the Agrean^tbe d^med to create any intended or incidental third party beneficiaries, and the mattesherein al! remain within the sole and exclusive jurisdiction of the Settling States.

e. Hli Examimtion. Nothing in this Agreement shall prevent cw otherwise restrict aParticipating State or the Examinerrin-Charge from continuing the HII Examination orfrom otherwise examinirig the conduct of HII in any manner, including, withoutlimitation, HII's contractual relationship and dealings with the HCC Group. Additionally,nothir^ in this Agreement shall prevent or c^herwise restrict the HCC Group fromQtiberwise pursuing a fffivate ri^t of action against a third party for such third party'sfailure to comply with the terms and conditions of a contractual r^ment by andbetween HCC Life and such third party.

d. Exhibits. The following exhibits are attached hereto and incorporated herein:

Exhibit A Participating StatesExhibit B Subscribing State Adoption Form

e. Time of the Essence. The Parties hereby agree that time shall be of the essence withrespect to the performance of this Agreement.

f- Rights and Remedies. Except as otherwise provided in this Agreement, the rights, powers,remedies and privileges provided in this Agreement are cumulative and not exclusive ofany rights, powers, remedies and privileges provided by applicable law.

g. Settling State Authority, Each person signing on behalf of each of the Settling Statesgives his or her express assurance that under applicable state laws, regulations, andjudicial rulings, he or she has authority to enter into this Agreement.

h. HCC Life Authority. HCC Life expressly represents and warrants as of the date of itsexecution of this Agreement that: (i) it is duly organized, validly existing and in goodstanding under the laws of its jurisdiction of incorporation or organization and has theabsolute, unrestricted right, power, authority and capacity to execute and deliver thisAgreement and to perform its obligations arising hereunder, without any frirther consentor approval being required from any individual person, parent company or otherorganization or entity; (ii) it has obtained all necessary authorizations, approvals, orconsents of any governmental entity required in connection with the execution, delivery,or performance by it of this Agreement; (ill) it has conducted all investigations it deemsappropriate and necessary to determine whether to enter into this Agreement; and (iv) ithas read this Settlement Agreement, enters into it knowingly and voluntarily and has beenadvised by its legal counsel as to the legal effect of this Agreement.

j. Choice of Law. This Agreement and any disputes or conflicts which may arise inconnection with the interpretation or enforcement of this Agreement, .^d the rights andobligations of the Parties, shall be governed by the laws of the State of Indiana withoutregard or reference to choice or conflict of law luiles. The HCC Group and the SettlingStates consent to the exclusive jurisdiction of the United States District Court for theSouAem District , of Indiana or the Superior Court for Marion County, Indiana for thepurposes of Interpreting and enforcing this Agreement


j. Jofm Frepe^iim/TUs Agreen^t, exclusive of any statem^ts or fiadir^ preliminaryor c^erwise, of the Examiaer-'ia-Charge, shall be to have prepared Jointlyby the Parties berdo. Any ambiguity herein 11 not he interj^ted against any Par^hereto and shall be interpreted as if each of the Parties hereto had prepared thisAgreement,

k. IriterpretQtiqn, Titles and headings to sections herein are inserted for convenience ofreference only' and are not intended to be a part of or to affect the meaning orinterpretation of this Agreement. Whenever the context requires in this Agreement, thesingular shall include the plural, and vic^ versa.

I. Inyalidity. In the event that any portion of this Agreement is enjoined or held invalidunder the laws of a Participating State's jurisdiction, such enjoined or invalid portionshall be deemed to be severed only for the duration of the injunction, if applicable, andonly with respect to that Participating State and its jurisdiction, and all remainingprovisions of this Agreement shall be given full force and effect and shall not in any waybe affected thereby.

m. Entire Understanding; Modification. This Agreement represents the entire understandingbetween the Parties with respect to the subject matter hereof and supersedes any and allprior understandings, agreements, plans, and negotiations, whether written or oral, withrespect to the subject matter hereof. All modifications to this Agreement must be inwriting and signed by each of the Parties hereto.

n. Counterparts. This Agreement may be executed in one or more counterparts, any ofwhich shall be deemed an original and all of which taken together shall constitute oneand the same Agreement. Execution and delivery of this Agreement may be evidenced byfacsimile or electronic mail transmission.

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EXHIBIT A

PARTICIPATING STATES

1. Alabama

2. Alaska

3. Arizona

4. Arkansas

5. California

6. Golorado

7. -Connecticut

8. District of Columbia

9. Florida*

10. Georgia11. Idaho

12. Illinois

13. Indiana**

14. Iowa

15. Kansas*

16. Kentucky17. Louisiana

18. Maine

19. Maryland20. Michigan21. Mississippi22. Missouri

23. Nebraska

24. Nevada

25. New Jersey26. New York

27. North Dakota

28. Ohio

29. Oklahoma

30. Pennsylvania31. Rhode Island

32. South Carolina

33. South Dakota

34. Tennessee

35. Texas

36. Utah*

37. Vermont

38. Virginia39. Washington40. West Virginia41. Wisconsin

42. Wyoming

* - Lead State

** - Managing Lead State

Regulatory Settlement Agreement EXHIBIT ANAIC No. 92711 Participating States33J2684 1

EXHIBIT B

IVIultistnte Targeted Market Conduct Examinationof

HCC Life Insurance CompanyRegulatory Settlement Agreement

SUBSCRIBING STATE ADOPTION

On behalf of __]Jnsert Name ofInsurance Regulatory

Agency], I {Insert Name of Official Signing Below],

have received, reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement

Agreement executed by HCC Life Insurance Company on the day of , 2017.

[Print Name of Insurance Regulatory Agency]

By:

Printed:

Title:

Date:

Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life.

CONTACT NAME:

MAILING ADDRESS:

PAYMENT MADE TO:

IF APPLICABLE, PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY.

Upon completion, please return this form to:

Chad T. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199

Email: [email protected]

Regulatory Settlement Agreement EXHIBIT BNAlCNo. 927II Subscribing State Adoption3312684 1

Exhibit B

Multistate Targeted Market Conduct Examinationof



On behalf of the ALABAMA DEPARTMENT OF INSURANCE, I, Jim L. Ridling, as

Comniissioner of Insurance, have received, reviewed and to hereby adopt, agree to and approve

that certain Regulatory Settlement Agreement executed by HCC Life Insurance Company on

the 19th day of December, 2017.

ALABAMA DEPARTMENT OF INSURANCE

By:. Ridlingissioner of Insurance

Date; ^


CONTACT NAME: Richard L. Ford, Chief Examiner

MAILING ADDRESS: PO Box 303351, Montgomery, AL 36130-3351

PHONE NUMBER: ■ (334) 241-4155

EMAIL: [email protected] MADE TO: Commissioner of Insurance, State of Alabama


Chad T. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Email: cwaiker@boselaw,com

RyHTBTTB



STJBSCRTBTNC STATE ADOPTION

On behalf of the State of Alaska Division of Insurance, I, Director Lori Wing-Heier, have

received, reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement

Agreement executed by HCC Life Insurance Company on the 19th day of December 2017.

Alaska, Division of Insurance

Printed; yLori Wing-Heier

Title; Director

Date:


CONTACT NAME: Chin Wagoner

MAILING ADDRESS: Alaska Division of Insurance. PC Box 110805. Juneau. AK 99811

PAYMENT MADE TO: State of Alaska


Upon completion, please return this form to;

Chad T. Walker


Fax: 317.223.0199


EXHIBITB

Multistate Targeted Market Conduct Examination

HCC Life Inanraaee CompanyRegidatory Settlement Agreement

STfBSrRTBlWft STATE APOFTmN

On behalf of Arizona Debartmeni of Inanrance. I Leslie R. have received, reviewed and

do hereby adopt, i^ree to and approve that ceitain Regulatory Settlement Agreement executed by HCC

Life In surance Company on the day of December 29.2017.

AiHbEona Department of Insurance

By;

Printed: Leslie R. Hess

Title; Interim Director

Date: January (^.2018


CONTACT NAME: Marv Jordan

MAILING ADDRESS: 2910N. 44*^ Street.#210 Phoenix. AZ 85018

PAYMENT MADE TO: Arizona Department of Insurance

IF APPLICABLE. PLEASE PROVIDE WIRING INSTRUCTIONSSEPARATELY.


ChadT. WalkerBose MeKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


of

HCC Life tounmco Compa»ySottlcnient Agiêmeat


On behalf of \Insert Name ofInsurance Regulcôry

I [^^rt Name ofQfflcMSignmg Bel&w],


Agreênt executed by HGC Life Insurance Company on the day of 201?.

[Print Name ofInsurance Regulatory Agency]

Printed; ^//ee tr/^

Title:

Pate: ^hfir

Please provide the following information as to how your jurisdiction's allocation of the MultlstatePayment should be made fi-om HCC Life.

CONTACT NAME:

MAILING ADDRESS: tZ4>0 UitU AH 7U0i- /fff"/

PAYMENT MADE TO:

IF APPLICABLE, PLEASE PROVIDE WIRING INSTRUCnONS SEPARATELY.


Chad T.Walker


Fax; 317.223.0199


ffXHIRITB



simsrwiBiNC state AnoPTiON

On behalf of the Colorado Division of Insurance, I, Michael Conway, have received, reviewed

and do hereby adopt, agree to and approve that certain Regulatory Settlement Agreement executed by

HCC Life Insurance Company on the 4*^ day of January, 2018.

Colorado Division of Insuranc^^

Printed; Michael C

Title: Interim Commissioner of Insurance

Date: January 4. 20! 8


CONTACT NAME: Stephanie Clement: ATTN: Cash Management

MAILING ADDRESS: CO Division of Insurance 1560 Broadway Ste 850 Denver CO 80202

PAYMENT MADE TO: Colorado Division of Insurance



Chad T. Walker

Hose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


™miTB

of

H€C life Coosimoyi^leioemt A^emmt

sTyBfoiBTW^ STATE Awmm.

On behalf of the Conn^ticut Insurance Department» I Kafharine L. WadCj have received,

reviev\^ and do hereby adopt, agr^ to and approve that certain Regulate^ Settlement Agteepent

executed by HCC Life Insurance Company on the i9th day of December, 2017.

Connecticimlnsuranoe Rppartmeft

By: WTUAMAM

Printed: Katharine L. Wade

Title: Commissioner

'^.*'1 " I CDate:


CONTACT NAME: Kurt Swan, Director, Market Conduct Division

MAILING ADDRESS: P.O. Box 816, Hartford, CT 06142-0816

OVERNIGHT MAILING ADDRESS: 153 Market Street Hartford, CT 06103

PAYMENT MADE TO: Treasurer, State of Connecticut



Chad T. Walker

Bose McKinney Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199Fax: 317.223.0199Email: [email protected]

EXHTBTTB

Maltlstate Targeted Market Candact Examlaatioiiof

IICC life laBorance CompanyRegulatory Settlement Agreement


On bdiidf of the Relaware Ifepartment of Insurance, Trinidad Navarro, Delaware

InsurSince Commissioner, have received, reviewed and do hereby ado^t, agree to and approve that

certain Regulatory Settlement Agreonent executed by HCC Life Insurance Company on this 9® day

of January, 2018.

DELAWARE DEPARTMENT OF INSURANCE

By;

Printed: Trinidad Navarro

Title: Insurance Commissioner

Date: January 9,2018


CONTACT NAME: Jenifer Vaughn, Controller

MAILING ADDRESS: Delaware Department of Insurance, 841 Silver Lake Blvd., Dover, DE

19904

PAYMENT MADE TO: State of Delaware


Upon completiQn, please return this form to:

Chad T.Walker

Bose MciCiimey & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone; 317.684.5199

Fax: 317.223.0199

^nail: cwalker^oselaw.oom

yxmnTTR

Muldstate Targeted Market ConductExamination of


STTftSCRTBTNC STATE AROPTTON

On behalf of the District of Columbia, Department of Insurance, Securities and Banking, I

Stephen C. Tavlor. have received, reviewed and do hereby adopt, agree to and approve that certain

Regulatory Settlement Agreement executed by HCC Life Insurance Company on day

of February ^2018.

District of Col) it fi Insurance, Securities and Banking

By: ^ Printed: Stephen C.,

Title: Commissioner

Date:

Please provide the following information as to how your jurisdiction's allocation of the MultistatePaymrat should be made from HCC Life.

CONTACT NAME: Philip Barlow. Associate Commissioner of Insurance

MAILING ADDRESS:1050 Firat Street. NE. Washington. DC 20002

PAYMENT MADE TO; D.C. Treasurer



Chad T.Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite2700

Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


Maltbtate Targeted Market Conduct Examinationof

HOC Life Insurance CompanyRegulatory Settlement Agreement


On behaljf of 0^ Ncane of Insw^cB RegulotoiyAgency], I /l/'hoaio^ {Insert Nme of Official Signing JJe/ow'],have received, reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement

Agreement executed by HOC Life Insurance Company on day of 2017.


Bv:J jXukiPnnted: Aliwi»ior

Title: Qo^tn'bS^art*^Date:

Please provide the following information as to how your jurisdiction's allocation of the MuttistatePayment should be made irom HOC Life.

CONTACT NAME;

MAILING ADDRESS: ;:iDO P , FtPAYMENT MADE TO: Sfef^U;.5


Upon completion, please return this fbrm to:

Chad T.Walker

Bose McKlnney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199

Email: cwa!kef@boselawxom

Regulatory Settlement Agreement EXHIBIT BNAIC No. 92711 SubKribiug State Adoptiou3312684 1

EXHIBIT B

Multistafe Targeted Market Conduct Examinationof

HCC Life Insurance CompanyRegulatoi7 Settlement Agreement

SUBgCRmNC? STATE APOPTIQN

On behalf of THE Georgia Insurance Department. 1, Ralph T. Hupgens.

Commissioner of insurance have received, reviewed and; do hereby adopt, agree to and approve

that certain Regulatory Settlement Agreement executed by HCC Life Insurance Company on the day

of December 19, 2017,

The Georgia Insurance Department

Printed: RALPH T, HUDGENS

Title: Commissioner of Insurance

Date:

Please provide tlie following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life.

CONTACT NAME: SaraliU. Crittenden. Esq.

MAILING ADDRESS:. Georgia Insurance Department. Legal Division

P.O. Box 935 138

Atlanta, Georgia 31193-5138

PHONENUMBER; (404) 463-4458

EMAIL: [email protected]. gov

PAYMENT MADE TO: The Georgia Insurance Department


Chad T. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700


Fax: 317.223.0199


BXHIBELB

of

BCC IMe losuraêe

Rûlatpry S^lem^t Agreemeat

state apqftiqn

On behalf ofHie Idaho Departm^t of Insurance, I Dean U Cameron, have received, reviewed

and do hereby adopt, aêe to and approve that certain Regulatory Settlement Agreement executed by

HCC Life Insurance Company on ihe day of November 22 ^ 2017.

Idaho Department of Insurance

[Prmt Name ofAiswance Regtdatmy Agency]

C

Printed: Dean L. Cameron

Title: Director

Date: L757Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life.

CONTACT NAME: October Nickel

MAILING ADDRESS: 700 W. State Street Boise. Idaho 83702

PAYMENT MADE TO: Idaho Department of Insurance



ChadT. Walker


Fax: 317.223.0199


EXHIBIT B

of

HCC Life Insui^nco Com|iaityRegiilatory Seftlem^l AgreemcRt


On bel^alf pf The Illinois Departn^ent of Insm-ance, I Jack Eiigle, have recdved. review ciohereby adopt, agr^ to and approve that cealain Regolattwry Settlenjoit Agre^^t executed by HCCLife Insurance Com|any on the 19th day of Etecemher, 2017,

Illinois Department of Insurance

Printed; Jack Bngle

Title: Assistant Deputy Director/CollaborativeAction Degignee

Date: February 22,2018

Please provide the following infonnation as to how your jurisdiction's allocation of the MultistatePayment should be made from HOC Life.

CONTACT NAh^: Jack Engle

MAIUNO ADDRESS: 320 West Washington St - 5th Floor, SpringHeld, IL 62767

PAYMENT MADE TO: Director - Illinois Department of Insurance


Upon completion, please return this foim to:

ChadT. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 270DIndianapolis, Indiana 46204Flme: 317.684.5199

Fax:317.223-0199

Bnail: cwalker#boselaw.eom

EXHIBITS




On behalf of tPfiUYTXYV^^ X)(3p^nsert Name of Insurance RegulatoryAgency], 1 {Insert Name ofOfficial Sigriing BeloW],


Agreement executed by HCC Life Insurance Company on the j^l-day of NlOVCrfibClT, 2017.

iUmnfi^JX^H-rncnf-' Udry Agency]

.Printed:

wjijilnPlease provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life

CONTACT NAME:- -

MAILING ADDRESS:,

PAYMENT MADE TO: KcolS^S £kf%,(HTV\eft4-IF APPLICABLE, PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY.


Chad T, Walker


Fax: 317.223.0199


Regulatory Settlement Agreement EXHIBIT BNAIC No. 92711 Subscribing State Adoption33I2684_l

EXHlBfTB

C onduct Esemaliiatloii

HCC life la^raBce Cpiap^yRt^tatoiy i^lêai AgrîneBt

SlIBSCRTBINC STATE ADOPTION

On behalf of Kentucky fPepartmt nt uf In tnrancel. I Russ Hamblen have received, reviewed and

<kj to y a^ree to apjarove that certain Regijlatory S^tlement AgreeaMt exûted by HCC

Life Insurance Company on the day of December 19.2017.

Kerrtucky Department of Insurance

By: i J

Printed: Russ Hamblen

Title: Chief Market Conduct Examiner

Pate: February 26.2018

Please provide the following information as to how your jurisdiction's allocation of the MjiltistatePayment should be made from HCC Life.

CONTACT NAME: Russ Hamblen - -----

MAILING ADDRESS: 215 West Main Street. Frankfort. KY 40601

PAYMENT MADE TO: Kentucky State Treasurer



ChadT. Walker

Hose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone; 317.684.5199

Fax: 317.223.0199


of

mifi APQPTWW

On behalf ofthe Louisiana Department of lnsuraffi:e, I James J. P^Kielop . received,

reviewed and do hereby adopt, s^ee to and approve that certain Regulatofy SettNnent Agreement

executed by HCC Life Ihauran^e Company on the 19th day of December, 2017.

LOUISIANA department OF INSURANCE

z

rinted: >3ames J.'SkMWon

Tille: Commissioner of Insurance

Please provide the following information as to how your junsdictlon'S aliocatlon of the MultistatcPayment should be made from HCC Life,

contact NAME: Jeffrey Zewe ,

MAILING ADDRESS: 1702 N. Third Street. Baton Rouae. LA 70802

PAYMENT MADE TO: Louisiana penartment of insurance

IF APPLICABLE, PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY,


Chad T.Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317,684.5199Fax: 317.223.0199


afHOD Ltfe teu wee Donâny

Regiflatoisr Settiemeirt 4gteera«rtt

MA!R1fLAM> gmTMABQPTlD^Pf

•CSn befealf l^n.cl.Iytsur<>.rTc^/)ê^j*i Nrnje'S^Jk^vmnCBi P^-.. 3^. Sec 11 'g^ , [/ww! Mum3 of Sirring; JSe/owJi

and'ejspriive dmtoertdti Itepfatoiy- Settlefflent-;i5av^ y^fasived rfevl^wod latd do:

^5ieeated by IC^G 'Dlfe insuranee-Company oft the: I .of Hô^roK^

Tbo M-

Mowe

At

pe c€ §'5^3) of the Regulate?ty .Sdttlemfeflt fa amended, as

dlsoretioTL of tho Maiyland Insuram CDitimfa^looer, and tnylandJa^, th&Maiyleud Insuwce Admin:btmtiQa

ahail consider not-prntjinfjgrr enfbroemem: action as set;Mih; in SOoiiion:HOC iUfe until the 3fl!-day refipQUse period described a;boye

/i^fifL^lo.y>clXV\.sora.v\c,e. /^4rnini s-fyajf'ovv. With regards to the above amendment to theKegttlatoiy •Settlement Asreranent":

mnee CompanyByr.

Mtit6dv_EvlS o— T". 6 o-i ie^title: AsSQctaj~e_ Cow>mi-SSloy\er

Bate: l'^^ tSL-Oi^

■Date: Mfg

HCCItl^tt^lnsruranee.SeiTto H^C

Dat&S: Miimfkr. 8^

Date;-

tContinned on 'ollowlngâie]

the; Mlowln# bfermatton a$ to how yotff Jiirisîotloa'-^ sUooatroa ,df flw Mwlfstetelament; shoiU4 ho tnade li^b.

COWACTNAME: H:r(ea.Or. 6icî\e^MAiLlHSAM)RBSSi,,ôr> 54. Pci;U\ Pu-jLc^g ,IPAYMBNT MADBTOt: fV^ m..V I ni ynd yir-a- /Ifl.uvi l n\ S'tTirt4-r/^

IP APftBSABlÊ. PLEASB EHd\rtt3E wmmd BlSTJBi;CtK>l« SEPAMTELY.

Ujiohcaraplbtion^please return Ihbib^^ i

Ch&ir, Wker i

1-1J McmumootQWes'Shite'^7'90

mrnrnmsmm/'^mzmnMwEinaii? alker^taekWiOom

KXHTBTTl

of

E€C life It^nroiic^ ComityRegulatory Settlement Agreement

state apopton

' On beiialf of the Michigan E)epartmeat of fosuranee and Financial Servfe^^ L Patric|c M.

MoPharlin. have reeeivedi levlewed and do h^areby adopt, agw to and prove that certain

Regulatoiy Settlement Agreranent executed by HCC Life Insurance Company on the 19th day of

December 2017,

tt-Nmie.^lnsurafice Reguhtory Agency]

Frinted: Patrick M. McPharlin

Title: Director

Date;


COTSITACTNAME: Randall S. Gregg. General Counsel

MAILING ADDItESS: Department of Insurance and Financial ServicesPersonal and Confidential: Randall S. GreggOffice of General Counsel

Mason Building, 8* Floor530 W. Ailegan St.

Lansing, MI 48933

PAYMENT MADE TO: Michigan Insurance Bureau Fund

IF APPLICABLE. PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY.


Chad T.Walker

Bose McKinney & Evans LLP111 Mmiument Circle, Suhe 2700Indianapolis, Indiana 46204Phone: 317.684.5199Fax; 317.223.0199Email: [email protected]

E?iiHIPTTB



STTBSCRrBTNC STATE ADOPTTON

On behalf of Mississippi Insurance Department 1 Mai'k Haire. have received, reviewed and do

hereby adopt, agi-ee to and approve that certain Regulatory Settlement Agreement executed by HOC

Life Insui-ance Company on the day of ST. 201^

Mississippi Insurance Department

By

Printed; Mark Haire

Title: Deputy Commissioner

DM.: /C


CONTACT NAME: Nancv Stuait

MAILING ADDRESS: P.O. Box 79 Jackson. MS 39205

PAYMENT MADE TO: Mississippi Insurance Department



Chad T. Walker


Fax: 317.223.0199


mun

of HCG Life lasnrance CompanyRegulatory Settlement Agreem^t


Oa belief of Ntissmiri DepiMent of Finandal Institutions and Pipfe^oi^Re^stratkin^ Undley-Myens, luLve received, reviowed do hereby adojpt, agree to

Company on the 19*** day of Dewanber 2017 adopt, agree and approve this Agreement.

Missouri Qjppartment of In^^nce, Finag^^titutions and Prof^sional Registration

By:

Chtora Undley-My^

Title; Director

Date

Please provide the following information as to how your jurisdiction's allocation of tiie Multi-

CONTACT NAME: Stewart Freilich

MAILING ADDRESS; 301 West High Street, Room 530, Jefferson City, MO 65101Phone:573 526-1527

E-Mail: Stewart.FreiIich@insurance,m0.govPAYMENT MADE TO: State of Missouri

Please return this form to:

Chad T.Walker

Bose McKitmey & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317-684-5199Fax:317-223-0199

Email; [email protected]

EXHIBIT B

Multistatc Targeted Market Conduct Examinationof



On behalf of Nebraska Department of Insurance Name ofltmirance Rcgnhuoty

Agency], I Bruce R. Ramge [Insert Name of Official Signing Behw]^

have received^ reviewed and do hereby adopt, agree to and approve that certain Regulatoiy Settlement

Agreement executed by HCC Life Insurance Company on the /^dav of 201^1

Nebraska Department of Insurance[Print Name of Insurance Regulatory Agency!]

By:

Printed: Bruce R. Ramge

•pitie: Director

Date: /-tO- :H>/S

Please provide the following infonnation as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life.

CONTACT NAME: Randall Willey

MAILING ADDRESS: 941 O Street, Suite 400, Lincoln, NE 68508

PAYMENT MADE TO: Nebraska D^>aftment insurance



Chad T. Walker

Bose McKinney & Evans LLPII I Monument Circle, Suite2700

Indianapolis, Indiana 46204Hionc: 317.684.5199

Fax: 317.223.0199


EXHrorr b

Multistite Targeted Market Conduct Examiimtionof

HCC Life Insurance CompanyRe^latory Settlement Agreement


On behalf of State of Nevada^ Dft)artment of Business and Industry, Division of Insurance. I,

Barbara D. Richardson. Commissiotter of Insurance, have received^ reviewed and do hereby adopt, agree

to and approve that certain Regulatory Settlement Agreement executed by HCC Life Insurance Company

on the 19'*' day of December, 2017.

NEVADA DIVISION OF INSURANCE

By:BARBARA D. RICHARDSON

Printed:

Title: State of Nevada. Commissioner of Insurance

Date: _

Please provide the following information as to how your jurisdiction's allocation of the Multistatepayment should be made from HCC Life.

CONTACT NAME: Amy L. Parks, Esq.MAILING ADDRESS: Nevada Division of Insurance

1818 East College Parkway, Suite 103Carson City, Nevada 89706

PHONE NUMBER: 775-687-0710

EMAIL: a][email protected]

PAYMENT MADE TO: Nevada Division of Insurance

IF APPUCABLE, PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY.


Chad T. Walker

Bose McKinncy & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199Email: [email protected]

EXHIBIT B

Multistate Targeted Market Conduct Examiiiationof


STJBSrRIBTNC STATF. AnOPTION

On behalf of the New Hampshire Insurance Department. I, Roger A Sevigny, have received,

reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement AgreementI {

executed by HCC Life Insurance Company on the 21 st day of February, 2018.

New Hampshire Insurance Department

Printed: Roger A. Sevienv

Title: Commissioner

Date: J ! - J F"


CONTACTNAME; Theodore Perkins. Jr

MAILING ADDRESS: 21 South Fruit St, Suite 14, Concord NH 03301

PAYMENT MADE TO; State of New Hampshire Insurance Department


I


Chad T- Walker

Bose McICinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204PlK>ne: 317.684.5199

Fax: 317.223.0199


of

HCC

On behdfofThe North Carolina D^artment of Insurance .1 TracvM.Bidin have

received, reviewed and do adopt, afree to and ro\« that certain R^latoq? Segment

Agreement executed by HCC Life Insurance Company on the 19th day of December. 2017.

Hie North Carolina Department of Insurance

By:

Printed; Tracv M. Biehn

Title: Senior Regulatory Compliance Analyst

Date: January 8.2018

Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life,

CONTACT NAME; Tracy M. Biehn

MAILING ADDRESS: 1201 Mail Service Center. Raleigh. NC 276994201

PAYMENT MADE TO; The North Carolina Department of Insurance

IF APPLICABLE PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY,


Chad T.Walker

Bose McXinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


KXHIBTTR



state apofttqn

On behalf of the North Dakota Insurance Department, I, Jon Godfread, have received, reviewed

and do hereby adopt, agree to and approve that,certain Regulatory Settlement Agreement executed by

HCC Life Insurance Company on the day of^^3^wQs . t2018.

North Dakota Insurance Departr

Printed: Jonpodfread

sjitle: Noftn Dakota Insurance Commissioner

Date: <3. J2^ l.Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life.

CONTACT NAME: Johnny Palsgraaf

MAILING ADDRESS: 600 East Boulevard Ave, Bismarck, ND 58505

PAYMENT MADE TO: North Dakota Insurance Department



Chad T. Walker

Hose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


EXHTBITR



SimSCRFBTNCT STATE ADfiPirON

On behalf of Ohio, I, Jiliian Froment, as Director, have received, reviewed and do hereby adopt, agree to

and approve that certain Regulatory Settlement Agreement executed by HOC Life Insurance Company on

the 19th day of December, 2017.

Ohio Department oflnsurance

Printed:

Title: Director

Date: ^h,^/j

Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made irom HCC Life.

CONTACT NAME: Angela Dingus. Chief Market Conduct Division

MAILING ADDRESS: 50 West Town StreeL Suite 300. Columbus. Ohio 43215

PAYMENT MADE TO: Treasurer. State of Ohio



Chad T. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204

, Phone: 317,684.5199

Fax: 317.223.0199


wmmM

HCC Llf« I^cfraaec CompanyRegulatory Sc^lement Agreement

SnBSCRTRmr; STATE AnORTTON

Qii l^ajf of the Qklaho*»e Insurance Department, I Joel L. Sande^^yhave received, reviewed and

do hereby adopt, agree to aiKi approve that certain Reguiatoiy Settlmr^nt Agreeincmt executed by

HCC Life Insurance Company on the cky of Fehruai-y 27.2018.

Oklahoma Insurance DepartraM

By

inted-^Printed: joel L. Sander

Title: Deputy Commissioner

Date: February 27.2018


CONTACT NAME: Sherrv Marczewski .

MAILING ADDRESS; 3625 NW 56'" Street Ste. 100 Oklahoma Citv. Ok 73112

PAYMENT MADE TO: Oklahoma Insurance Department



Chad T, Walker

Hose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 4^204Phone: 317.684.5199

Fax: 317.223.0199


KXHTBTTB



SUBSCRTBTNCi STATE AftOPTfOIS

On behalf of the^Pennsylvania Insurance Department, 1 Christopher fC Monahan, have received,

reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement Agreement

executed by HCC Life Insurance Company on the day of January 5,2018.

Pennsylvani^^nsu^cdDepartment

Printed: Christopher R. Monahan

Title: Deputv Insurance Commissioner

Date: January-5.2018


CONTACT NAME: Constance Arnold

MAILING ADDRESS: 1321 Strawberry Square. Harrisburg. PA 17120

PAYMENT MADE TO: Commonwealth of Pennsylvania



Chad T. Walker


Fax: 317.223.0199


EXHIBIT B



SIJBSrRIBINr, STATE AnOPTION

On behalf The Soutl| Carolina Department of Insurance, I, Raymond G. Farmer [, have received,

reviewed and do hereby adopt, agree to and approve that certain Regulatory Settlement Agreement

executed by HCC Life Insurance Company on the day of March 1,2018.

South Carolina Department of Insurance


1Printed: Raymond G. Farmer

Title; Director ■

Date:


CONTACT NAME: Michael Bailes

MAILING ADDRESS: 1201 Main Street. Suite 1000. Columbia SC 29201

PAYMENT MADE TO; South Carolina Department of Insurance



ChadT. Walker


Fax: 317.223.0199


KXHmiTP

Multlstate Targeted Market Condtict Kxamlaatkm

of

HCC Life Insuraoce CompanyRegulatory Settlement Agreement

statp apoptfon

On behalf of the Tennessee Department of Commerce and Insurance. 1, Julie Mix MoPeak. have

received, reviewed and do hereby adopt, agree to and approve the Regulatory Settlement Agreement

executed by HCC Life Insurance Company on the day of February, 2018.

Tennessee Department of Commerce and insurance

By: jlAi fcPrintel: Julie Mix McPeak

Title: Coininissioner

Date: dssJlS'Please provide the following informalion as to how your jurisdiction's allocation of the Mullistate Payment

should be made from HCC Life.

CONTACT NAME: Lorrie Brouse, Deputy Commissioner & General Counsel

MAILING ADDRESS: 500 Jap^c^ Robertson ParkwayNashville, TN 37243

PAYMENT MADE TO: Tennessee Department of Commerce and Insurance.

Insurance Education Fynd - Account C1779


Upon completion, please return this fonn to;

Chad T. Walker

Bose McKinney & Evans LLP 111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317,223.0199


^ 2018- 5440No,

OFFICIAL ORDER

of the

TEXAS COMMISSIONER OF INSURANCE

Subject Considered:

HOC LIFE INSURANCE COMPANY

HCC MEDICAL INSURANCE SERVICES, LLC

HCG INSURANCE HOLDINGS, INC.225 Towii Park, Drive, Suite 350

Kennesaw, Georgia 30144

CONSENT ORDER

TDI ENFORCEMENT FILE NO. 15422

The subject of this order is the Regulatory Settlement Agreement (RSA) entered into by HCC LifeInsurance Company, HCC Medical Insurance Services, LLC, and HCC Insurance Holdings, Inc.(Companies). The RSA is the result of an ongoing multistate targeted market conduct examinationregarding HCC Life's writing, form filing, marketing, soliciting, and claims payment of short-termmedical insurance plans.

WAIVER

The Companies acknowledge that the Texas Insurance Code and other applicable laws providecertain rights relating to the subject matter of any disciplinary proceeding and how it is conducted.The Companies waive those rights with respect to the entry of this consent order.

Pursuajit to Tex. Ins. Code § 82.055(b), the Companies agree to this consent order with the expressreservation that they do not admit to a violation of any provision of the Insurance Code or rule orregulation of the department and the Companies maintain the existence of any violation is indispute.

FINDINGS OF FACT

L The Companies have conducted the business of insurance in Texas.

2. On December 19,2017, the Companies signed the RSA, which is attached and incorporatedfor all purposes as Exhibit 1. Pursuant to the RSA, the Companies agree to pay $5,000,000to he distributed to the signatory states that are parties to die RSA.

2018- 5440COMMESSIONER'S ORDER

HCC Life Insurance CompanyHCC Medical Insurance Services, LLCHCC Insurance Holdings, Inc.Page 2 of 4

3. Texas is expected to receive a payment allocation as determined by the.RSA. The sumowed to Texas under the RSA constitutes an administrative penalty. Jurisdictions mustsign the RSA by March 1, 2018, to participate in the payment allocation.

4. In entering into this consent order, TDI and the Companies agree that numbered item 9.c(Breach/Default) of the RSA is not applicable in Texas. In the event TDI alleges that abreach of the RSA has occurred, TDI ill comply with the Texas Insurance Code, theTexas Administrative Code, and the Texas Administrative Procedures Act.

5. In entering into this consent order, TDI and the companies agree that numbered item 11.1(Choice of Law) of the RSA is not applicable in Texas.

6. TDI and the Companies agree that this consent order disposes of all issues, claims,demands, interest, penalties, actions, or causes of action regarding the Companies' writing,form filing, marketing, soliciting, and claims payment of short-term medical insuranceplans as described in the RSA. This order and the amount ordered payable to TDI does notextinguish any obligations otherwise owed to the State of Texas.

7. By this consent order, the Companies waive their rights with respect to all issues, claims,demands, interest, penalties, actions, or causes of action covered by the RSA: (1) to file amotion for determination; (2) to file any further claim for any issues occurring with respectto the matters covered by the RSA, or to otherwise further dispute any issues involved inthe matters covered by the RSA; and (3) to file any petition in district court contestingissues disposed of in the RSA, or which could have been raised and disposed of concerningthe period covered by the RSA, except those rights provided for in the RSA.

8. This consent order and RSA is between TDI and the Companies and does not incorporateany other pending agreements other than those referenced in the RSA.

CONCLUSIONS OF LAW

1. The commissioner has jurisdiction over this matter pursuant to Tex. Ins. Code §§ 82.052and 84.001-84.051; and TEX. Gov'tCODE§§ 2001.051-2001.178.

2. The commissioner has the authority to dispose of this case informally pursuant to TEX.Gov'tCode § 2001.056; Tex. Ins. Code §§ 36.104 and 82,055; and 28 Tex. Admin, Code

§ 1.47.

TDI adopts, agrees to, and approves the RSA and will enforce the RSA consistent with applicablelaw in effect in Texas and as referenced in the RSA and this consent order.

2018- 5440COMMISSIONER'S ORDER

HOC Life Insurance Company

HCC Medical Insurance Services, LLCHCC Insurance Holdings. Inc.Page 3 of4

It is ordered that Companies pay the penalty amount allocated to TDI in accordance with themethod described in the RSA within 10 days after the later of the effective date or receipt of theallocation from the Lead Depaitments as set forth in the attached RSA. The amount must be paidby check or money order made payable to the "State of Texas" and sent to the Texas Departmentof Insurance, Alln: Enforcement Section, Division 60851, MC 9999, P.O. Box 149104, Austin^Texas 78714-9104.

Kent C. Sullivan

Commissioner of Insurance

APPROVED AS TO FORM AND CONTENT:

Beverly RosendahlDirector, Enforcement SectionTexas Department of Insurance

2018- 5440COMMISSIONER'S ORDER

HOC Life Insurance CompanyHOC Medical Insurance Services, LLC

HCC Insurance Holdings, Inc.Page 4 of 4

AGREED, ACCEPTED, AND EXECUTED BY:

HCC Life Insurance CompanyHCC Medical Insurance Services, LLC HCC Insurance Holdings, Inc.

By: By:

Name: Randv Rinicella Name: Randv RinicelTaTitle: Vice President & Associate Secretary Title: Sr. Vice President. General Counsels

& Secretary

AFFIDAVIT

STATE OF "T ' §§

COUNTY OF Hr §

Before me, the undersigned authority, personally appeared the affiant, who being by me duly sworn,deposed as follows:

"My name is of sound mind, capable of making this statement, andhave personal knowledge of these facts which are true and correct.

I am an authorized representative of HCC Life Insurance Company, HCC Medical Insurance Services,LLC, and HCC insurance Holdings, Inc. Within HCC Life and HCC MedicalInsurance Services, LLC, I hold the office of Vice President Secretary. Within HCCInsurance Holdings, Inc., I hold the office of Senior Vice President General Counsel. & Seci-etarv. I amduly authorized by HCC Life Insurance Company, HCC Medical Insurance Services, LLC, and HCCInsurance Holdings, Inc. to sign this consent order and make the following statement:

HCC Life Insurance Company, HCC Medical Insurance Services, LLC, and HCC Insurance Holdings,Inc. knowingly and voluntarily enters into this consent order. HCC Life Insurance Company, HCCMedical Insurance Services, LLC, and HCC Insurance Holdings. Inc. agrees with and consents to theissuanc^Land service of the consent order by the Texas Commissioner of insurance."

3AfTianf^'

SWORN TO AND SUBSCRIBED before me on 2018.

3N fIS062 IExpires I

'Zj

SHERRt GIBSON

Notary !D 112401806JMy Commission Expires { "^Tgnatufc ofNotaW PubllcDecemb«ri7.2021

imJjkst"

2018- 5440


This REGULATORY SETTLEMENT AGREEMENT (the "Agreement") is entered into this i2!l!day of December. 2017 by and among: (i) HCC Life INSURANCE COMPANY ("HCC Life"); (ii) HCCMedical Insurance Services. LLC ("HCC MIS") ; (iii) HCC Insurance Holdings, Inc.("Holdings") (HCC Life. HCC MIS and Holdings, together with their respective Affiliates, collectivelyreferred to herein as the "HCC Group"); (iii) the FLORIDA OFFICE OF INSURANCE REGULATION("FOIR"); (iv) :the Indiana Department of Insurance ("IDOI"); (v) the Kansas InsuranceDepartment ("KID"); (vi) Utah insurance Department ("UID") (FOIR. IDOI, KID and UIDcollectively referred to herein as the "Lead States"); and (vii) the insurance-related regulatory bodies ofsuch other jurisdictions as choose to adopt, agree to and approve this Agreement (the "SubscribingStates") (Subscribing States and Lead States collectively referred to herein as the "Settling States") (theSettling States and HCC Life are collectively referred to herein as the "Parties").

RECITALS

WHEREAS, Holdings is the parent company of HCC Life and-of HCC MIS;


WHEREAS, during the Examination Period, HCC Life (NAIC #92711) marketed and sold short-term medical insurance products ("STM Products" as defined in Section 2 below) throughout the UnitedStates;

WHEREAS, the Settling States have regulatory jurisdiction over the business of insuranceconducted in their respective Jurisdictions, including the authority to conduct market conductexaminations;

WHEREAS, the IDOI, as managing Lead State, advised HCC Life on May 13, 2016, that amuitistate market conduct examination ((he "Examination") had been called regarding HCC Life'swriting, form filing, marketing, soliciting and claims payment of STM Products during the periodMarch 23, 2010 through April 30, 2016 (the "Exiiminatioti Period");

WHEREAS, there are presently forty-two (42) jurisdictions participating in the Examination, ofwhich STM Products were sold by HCC Life in thirty-nine (39) (the "Participating States") includingthe four (4) Lead States and thirty-eight (38) Participating States, a list of which may be found on ExhibitA, attached hereto and by reference incorporated herein;

WHEREAS, the Examination was conducted in conjunction with a separate muitistateexamination of third parties. Health Insurance Innovations, Inc. (ORG # 1 18438). Health PlanIntermediaries, LLC, and their parent companies and Affiliates (collectively. "HH"). Through Hll'snetwork of agents and call centers. Hi! marketed, sold and collected premium for HCC Life's STMProduct (as defined in Section 2 below). The muitistate examination of HII (the "HIl Examination")continues;

WHEREAS, the Examiner-in-Charge has presented to HCC Life and the Lead Slates apreliminary statement based on information gathered to date;

WHEREAS. HCC Life denies any wrongdoing or activities that violate any applicable insurancelaws or regulations, and nothing contained herein, or the execution and performance of this Agreement

Regulatory Settlement Agreement Page 1NAIC No. 92711 I KAWiSI I | Execution Copy.i3i2oj54_.i ijf yf

2018- 5440

shall be deemed or construed as evidence, or an admission or acknowledgment by HCC Life of anywrongdoing or liability whatsoever;

WHEREAS, based upon the review and analysis of the preliminary stalement presented by theExaminer-in-Charge, HCC Life agrees to the conditions of this Agreement and the resolution of thosematters within the scope of the Examination as set forth in the April 26, 2016 Examination Warrant,which scope remains unchanged, (the "Examination Scope") all as more particularly provided herein;

WHEREAS, in view of the foregoing facts and circumstances, the Settling Stales find it to be inthe f)ublic interest and are willing to accept this Agreement to settle ^11 insurance regulatory matterswithin the Examination Scope;


WHEREAS, HCC Life has cooperated with the Examiner-in-Charge in the course of theExamination by making its books and records available for examination, and its personnel and agentsavailable to assist as requested by the Examiner-in-Charge;

WHEREAS, HCC Life represents that at all times relevant to this Agreement, HCC Life and itsofftcere, directors, employees, agents and representatives acted in good faith; arid

WHEREAS, HCC Life and the Settling Slates execute this RSA knowingly and voluntarily, andthe Parties acknowledge that this Agreement is in the public interest and desire to end the Examination.

NOW, THEREFORE, in consideration of the Recitals, the mutual covenants and agreementsherein, and each act performed and to be performed hereunder, the Parties agree as follows:

1. Incorporation of Recitals. The above and foregoing Recitals, including, without limitation, allcapitalized terms defined therein, are hereby incorporated into and made a part of this Agreementas if more fully set forth in the body of this instrument.

2. Definitions. The terms listed below shall have either the meaning given in this section or thedefinition given elsewhere in the Agreement.

a. "Affiliate" shall mean a person that directly, or indirectly through one or more intermediaries,controls or is controlled by, or is under common control with, the person specified.

b. "Agreement" shall have the meaning set forth in the first paragraph of page I.




f. "Claims Audit" shall have the meaning set forth in Section 4b. of this Agreement.


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h. "Examination" shall have the meaning set forth in the first paragraph of page 1.

i. "Examination Scope" shall have the meaning set forth in the tenth clause of the Recitals.

j. "Examiner-in-Charge" shall mean Chad T. Walker of the law firm Bose McKinney &Evans LLP.^

k. "Final Effective Date" shall have the meaning set forth in Section 10.

I. "FOIR" shall have the meaning set forth in the first paragraph of page I.



0. "HCC MIS" shall have the meaning set forth in the first paragraph of page 1,

p. "HCC Third Party Audit" shall have the meaning set forth in Section 4d. of this Agreement.

q. "HCC Life STM Policies" shall mean any STM Products sold, marketed, underwritten orissued by HCC Life, either directly or Indirectly through third parties, including, withoutlimitation, HII.

r. "HII" shall have the meaning set forth in the sixth clause of the Recitals.

5. "HII Examination" shall have the meaning set forth in the sixth clause of the Recitals.

t. "Holdings" shall have the meaning set forth In the first paragraph of page 1.

Li. "IDOI" shall have the meaning set forth in the first paragraph of page I.

V. "KID" shall have the meaning set forth in the first paragraph of page I.

w. "Lead States" shall have the meaning set forth in the first paragraph of page I.

X. "Multistate Payment" shall have the meaning set forth in Section 5a. of this Agreement.

y. "Participating States" shall have the meaning set forth in the fifth clause of the Recitals.

z. "Parties" shall have the meaning set forth in the first paragraph of page I.

aa. "Settling States" shall have the meaning set forth in the first paragraph of page I.

bb. "STM Products" shall mean Ihe approved short-term medical insurance policies as filed byHCC Life and sold to individuals, either directly or through a group, with limited coverageperiods as determined by applicable state laws and regulations.

cc. "Subscribing States" shall have the meaning set forth in the first paragraph of page 1.

dd. "UID" shall have the meaning set forth in the first paragraph of page 1.

Regulatory Settlement AgreementNAIC No. 9271133I26W 1


2018- 5440

3. Short Tenii Medical Business. HCC Life represents to the Settling States that, effective June I,2017, it ceased the sale, marketing and underwriting and premium collections' of all STMProducts directly or indirectly offered or underwritten by HCC Life, except as otherwise requiredin order to conduct the run-off of its STM business in accordance with applicable laws andregulations. HCC Life covenants and agrees that it shall not directly or indirectly enter into thesale of short-term medical insurance within any of the Settling States for a period of five (5) yearsfrom the Final Effective Date. In the event HCC Life commences the sale or marketing of STMProducts in any Settling State following such period, HCC Life shall file forms and rates asrequired by applicable laws and regulations.


a. HCC Life shall administer and adjudicate any and all claims filed in relationship to HCCLife STM Policies in a timely fashion and in strict compliance with the terms andconditions of the policies and any and all applicable laws, rules, and regulations.

b. Within one hundred twenty (120) days of the Final Effective Date, the Examiner-in-Charge shall commence a preliminary audit (in accordance with the NAIC MarketRegulation Handbook) of HCC Life's claims handling practices for the STM Productsfor the period of June 1, 2017 through the date of the commencement of suchexamination (the "Claims Audit"). Upon completion of the Claims Audit, the Examiner-in-Charge shall present his preliminary findings to the Lead States. The Claims Auditcovers a period of time beyond the scope of the original Examination, and, therefore, theLead States reserve the ri^t to additional examination(s) of HCC Life as a result of theClaims Audit together with the right to impose financial, regulatory, and performancesanctions with respect thereto. HCC Life shall be responsible for the full, complete, andprompt payment of all fees and expenses of the Examiner-in-Charge in conducting andreporting on the Claims Audit in compliance with the laws of the State of Indiana. Uponthe request of a Participating State, the Examiner-ln-Charge shall provide any finalreports regarding the Claims Audit previously provided to Lead States to suchParticipating State.

c. Within ninety (90) days of the Final Effective Date, the Examiner-in-Charge shallcommence a preliminary audit (in accordance with the NAIC Market RegulationHandbook) of HCC Life's business practices for the STM Products to include, withoutlimitation, writing, form filing, marketing, soliciting, claims payment, licensing andappointments (the "Business Practice Audit"), Upon completion of the BusinessPractice Audit, the Examiner-in-Charge shall present his preliminary findings to the LeadStates. The Lead Stales reserve the right to additional e.xamination(s) of HCC Life as aresult of the Business Practice Audit together with the right to impose financial,regulatory, and performance sanctions with respect thereto. HCC Life shall beresponsible for the full, complete, and prompt payment of all fees and expenses of theExaminer-in-Charge in conducting and reporting on the Business Practice Audit incompliance with the laws of the State of Indiana. Upon the request of a ParticipatingState, the Examiner-in-Charge shall provide any final reports regarding the BusinessPractice Audit previously provided to Lead States to such Participating State.

' The Parties acknowledge that HCC Life continues to collect premiums on in-force business at the lime ofwithdrawal from the applicable market. ,

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d. HCC Life shall regularly audit the business practices of its producers, third partyadministrators, managing general agents, and contractors across all lines of its business,and make commercially reasonable efforts to ensure compliance with all applicable laws,rules and regulations and operate in a sound fashion (the "HCC Life Third PartyAudit").

e. Within 180 days of the Final Effective Dale, HCC Life shall, to the extent it deemsnecessary, establish, document, and provide to the Examiner-in-Charge standards andprocedures to conduct regular audits of its internal and third-party operations across alllines of business (the "Audit Procedures"). Such Audit Procedures shall include reviewof controls in place to ensure compliance with filed rating plans, form usage, licensing,appointments, marketing, claims handling, sales, and premiums are In compliance withapplicable laws, rules and regulations. Upon receipt of Audit Procedures, the Examiner-in-Charge shall provide the Audit Procedures to the Lead States, who in turn shall reviewand either approve or return to Company with directions for further revision.Alternatively, at the discretion of the Lead States, the Lead States may direct theExaminer-in-Charge to review the Audit Procedures and provide the Lead States with asummary of such Audit Procedures and the findings, if any, of the Examiner-in-Charge.Any review of such Audit Procedures by the Examiner-in-Charge shall be at the expenseof HCC Life.


a. HCC Life shall pay a total of $5,000,000 to the Settling States for the examination,administrative costs and compliance in connection with the Examination (the "MultistatePayment"). This payment shall be allocated among the Settling States as they agree.

b. Except as otherwise specifically provided herein, and provided HCC Life's full andcomplete compliance with this Agreement, the Multistate Payment shall be the soleamount charged, assessed or collected by the Settling States on HCC Life with respect tothe Examination Scope during the Examination Period.

c. Within ten (10) days of the Final Effective Date, the Examiner-in-Charge shall provideHCC Life a document reflecting how the Multistate Payment is to be allocated among theSettling Slates.

d. HCC Life acknowledges the validity and legitimacy of the Multistate Payment and shallpay the Multistate Payment within 30 days of the Final Effective Date. Once paid byHCC Life, the Multistate Payment is final and non-recoverable under any circumstances,including without limitation termination of this Agreement. However, HCC Life reservesail rights to pursue a private cause of action against third parties, and the Settling Statesagree that nothing in this Agreement precludes HCC Life from exercising any suchrights.

6. Cooperation with HI! Examination. HCC Life shall continue to fully and completely cooperatewith the Lead States and the Examiner-in-Charge with respect to the continuing Hi! Examination.HCC Life shall voluntarily (without service of subpoena) provide any and all unprivileged books,records, documents, instruments, writings, data or other tangible evidence available and requestedby the Examiner-in-Charge and shall make HCC Life personnel available as requested by theExaminer-in-Charge as such information and personnel relate to the HII Examination.

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7. Regulatory Oversight. The Lead States shall maintain regulatory authority and oversight overHCC Life's compliance with the terms of this Agreement. With respect to such continuingoversight, HCC Life agrees as follows:

a. For a period of twenty-four (24) months following the Final Effective Date, HCC Life shallprovide to the Examiner-in-Charge semi-annual reports on the Implementation and executionof the requirements of this Agreement. Each" report shall be delivered to the Examiner-in-Charge within' 45 days following the end of the applicable reporting period (e.g.

^[insert due dates based on execution date]. Copies of these reports will be providedto the Lead States as well as to the Participating States' respective designated examiners,upon their request.

b. Twenty-Four (24) months following the Final Effective Date, the Lead States, through theExaminer-in-Charge, shall conduct a preliminary audit in accordance with the NAIC MarketRegulation Handbook) multistate examination on their own behalf and that of the SettlingStates of HCC Life's compliance with the requirements of this Agreement. The Lead Statesshall provide a report summarizing the results of that examination to HCC Life and theSettling States. HCC Life shall be responsible for the full, complete and prompt payment ofall fees and expenses of the additional audit(s) and of Examiner-in-Charge in conducting andreporting the additional audit(s) in compliance with the laws of the State of Indiana.

c. In addition to any payments otherwise provided in this Agreement, the costs of the SettlingStates related to the monitoring of HCC Life's compliance with the Agreement, includingcosts and expenses of conducting any reviews or examinations permitted herein, the costs andexpenses of the Examiner-in-Charge as it relates to his obligations hereunder, as well asparticipating in any meetings, presentations or discussions with HCC Life and the costs ofany third-party examiner(s), shall be the full and sole responsibility of HCC Life as costs ofthe Examination.

8. Release. Subject to HCC Life's full and complete performance of and compliance with the termsand conditions in this Agreement, each Participating State hereby releases the HCC Group fromany and all claims, demands, interest, penalties, actions or causes of action that each ParticipatingState may have or could have alleged by reason of any matter, cause or thing whatsoever,regarding or relating to the subject matter of the Examination within the Examination Period;provided, however, that nothing herein shall preclude the Lead States from conductingsubsequent examinations to assess HCC Life's compliance with this Agreement or such otherexaminations or audits as expressly provided herein.

9. Default.

a. HCC Life's failure to comply with any material provision of this Agreement shallconstitute a breach of the Agreement, a violation of an order of the Settling States and aviolation of HCC Life's Agreement with the Settling States, and shall subject HCC Lifeto such administrative and enforcement actions and penalties as each Participating Statedeems appropriate, consistent with each Participating State's respective laws.

b. Any agreement on the part of any party hereto to any extension or waiver shall be validonly if in writing signed by the party granting such waiver or extension and, unless Ite.\pressly provides otherwise, shall be a one-time waiver or extension only, and any suchwaiver or extension or any other failure to insist on strict compliance with any duty or

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c. If a Settling State believes that the Company has breached a provision of this Agreement,that Settling State shall provide written notice of the alleged breach to HOC Life and willalso notify the Lead States that the alleged breach has occurred. HOC Life shall have theopportunity, within thirty (30) days of receipt of such notice, to present evidence inwriting and through appearance before the complaining state insurance regulator in anattempt to rebut the allegation(s) or to seek an extension to address the alleged breach. ASettling State shall not pursue any enforcement action as set forth in Section 9.a. againstHOC Life until the 30-day response period described above has expired.

10. Effectiveness.

a. This Agreement shall be finally effective on the date in which the Examiner-in-Chargeprovides HCC Life with a copy of this Agreement adopted, agreed to, and approved bythe first to occur of (i) twenty-five Settling States or; (ii) sixty percent (60%) of the grosspremium written during the Examination Period, as identified by the Examiner-in-Charge(the "Final Effective Date"). Except as provided in Subsection c of this Section 10, theFinal Effective Date shall be 90 days after the Conditional Effective Date.

b. The Examiner-in-Charge shall arrange to deliver this Agreement within seven (7)calendar days following the Conditional Effective Date to the Participating States.Participating States may adopt, agree to, or approve the Agreement by means of theSubscribing State Adoption Form attached as Exhibit B and by reference hereinincorporated.

c. The Lead States and HCC Life may agree in writing to extend the initial Final EffectiveDate and each extended Final Effective Date thereafter in writing, in which case theExaminer-in-Charge shall notify the Participating States who may then choose whether toparticipate hereunder on or before the date of the extended Final Effective Date.

d. If the Final Effective Dale does not occur by the initial Final Effective Date provided inSubsection a. of this Section 10, or such extended Final Effective Date thereafter asprovided in Subsection c. of this Section 10, this Agreement shall be deemed null andvoid and of no further force or effect.

1 1. Additional Terms.

a. No Admission. This Agreement represents a compromise of disputed matters between theParties. Neither this Agreement, nor any of the communications or negotiations leadingup to this Agreement, nor any actions taken or documents executed in connection withthis Agreement, is now or may be deemed in the future to be an admission or evidence ofany liability or wrongdoing by the HCC Group or any of its current or former affiliates,subsidiaries, officers, directors, employees, agents or representatives with respect to thesubject matter of the Examination or the Examination Scope.

b. Third Party Reliance. This Agreement is an agreement solely between the named Parliesas defined above, and no other person or entity shall be deemed to obtain or possess anyenforceable rights against the HCC Group as a third party beneficiary or otherwise as aresult of this Agreement. The Parties agree that this Agreement is not intended to and

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shall not confer any rights upon any other person or entity and shall not be used for anyother purpose. Nothing in this Agreement shall be construed to provide for a private rightof action to any person or entity not a party to this Agreement, Nor shall the Agreementbe deemed to create any intended or incidental third party beneficiaries, and the mattersherein shall remain within the sole and exclusive jurisdiction of the Settling States.

c. HII Examination. Nothing in this Agreement shall prevent or otherwise restrict aParticipating State or the Examiner-in-Charge from continuing the HII Examination orfrom otherwise examining the conduct of HI! In any manner, including, withoutlimitation, Hli's contractual relationship and dealings with the HCC Group. Additionally,nothing in this Agreement shall prevent or otherwise restrict the HCC Group fromotherwise pursuing a private right of action against a third party for such third party'sfailure to comply with the terms and conditions of a contractual agreement by andbetween HCC Life and such third party.


Exhibit A Participating StatesExhibit B Subscribing State Adoption Fonn


f. Rights and Remedies. Except as otherwise provided in this Agreement, the rights, powers,remedies and privileges provided in this Agreement are cumulative and not exclusive ofany rights, powers, remedies and privileges provided by applicable law.

g. Settling State Authority. Each person signing on behalf of each of the Settling Statesgives his or her express assurance that under applicable state laws, regulations, andJudicial rulings, he or she has authority to enter into this Agreement.

h. HCC Life Authority. HCC Life expressly represents and warrants as of the date of itsexecution of this Agreement that; (i) it is duly organized, validly existing and in goodstanding under the laws of its jurisdiction of incorporation or organization and has theabsolute, unrestricted right, power, authority and capacity to execute and deliver thisAgreement and to perform its obligations arising hereunder, without any further consentor approval being required from any individual person, parent company or otherorganization or entity: (ii) it has obtained all necessary authorizations, approvals, orconsents of any govemmentai entity required in connection with the execution, delivery,or performance by it of this Agreement; (ill) it has conducted ail Investigations it deemsappropriate and necessary to determine whether to enter into this Agreement; and (iv) ithas read this Settlement Agreement, enters into it knowingly and voluntarily and has beenadvised by its legal counsel as to the legal effect of this Agreement.

i. Choice q/'imr. This Agreement and any disputes or conflicts which may arise inconnection with the interpretation or enforcement of this Agreement, and the rights andobligations of the Parties, shall be governed by the laws of the State of Indiana withoutregard or reference to choice or conflict of law rules. The HCC Group and the SettlingStates consent to the exclusive jurisdiction of the' United States District Court for theSouthern District of Indiana or the Superior Court for Marion County, Indiana for thepurposes of interpreting and enforcing this Agreement.

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j. Joint Preparation. This Agreement, exclusive of any statements or findings, preliminaryor otherwise, of the Examiner-in-Charge, shall be deemed to have been prepared jointlyby the Parties hereto. Any ambiguity herein shall not be interpreted against any Partyhereto and shall be interpreted as if each of the Parties hereto had prepared thisAgreement.

k. Interpretation. Titles and headings to sections herein are inserted for convenience ofreference only and are not intended to be a part of or to affect the meaning orinterpretation of this Agreement. Whenever the context requires in this Agreement, thesingular shall include the plural, and vice versa.

1. Invalidity. In the event that any portion of this Agreement is enjoined or held invalidunder the laws of a Participating State's jurisdiction, such enjoined or invalid portionshall be deemed to be severed only for the duration of the injunction, if applicable, andonly with respect to that Participating State and its jurisdiction, and all remainingprovisions of this Agreement shall be given full force and effect and shall not in any waybe affected thereby.

m. Entire Understanding; Modification. This Agreement represents the entire understandingbetween the Parties with respect to the subject matter hereof and supersedes any and ailprior understandings, agreements, plans, and negotiations, whether written or oral, withrespect to the subject matter hereof. AH modifications to this Agreement must be inwriting and signed by each of the Parties hereto.



Regulatory Settlement Agreement Page 9NAIC No. 92711 Execution Copy1312684 I

2018- 5440

SIGNATURE PAGE TO REGULATORY SETTLEMKNT AGREEMgNT

"lEAJO STATES"

FLORIDA OFFICB OF INSURANCERegulation

By; I ./ l/L 1

David AltmaicfConunissioner

Date: llh')//'

INDIANA DEPARTMENT OF INSURANCE


Date:

KANSAS INSURANCE DEPARTMENT

By;Ken Seizer

Commisstcmer

Date:


By:Todd E. Kiser

Comniissioner

Date:

"UCCUFE"

HCC Life insurance Comjw;

T • UXamc:

Title:

Date:

HCC MEDICAL INSURANCE SMVICE;

Name: 3 .

Title: ^^jeuLtxhiiA' Vtce*

Date:

HCC Insurance HQu)iNG5i,iNC.

Title:

Date;

Re^latory ScttiemeBt AerccmentNAIC No. 92711u:2&t4 I

Page 10

Execution Copy

2018- 5440

SIGNATURR PAGE TO REGULATORY SETTLEMENT AGREEMI£NT

"IBAnSTATES'*

FLosiuA OPFicie <iF InsuranceRjegulation

By;Pavid AltmaierCommissioner

Oat©:

IF rNIi;

'mCCUFB"

ncc upe Insurance coMj

By:.„

jamc:£l^g*j

Daje:

iHCC MKUflt.'AL INSURANCE S^VlCiSSjJX

' Title: l^v^ALvkfiU.Viee^

Kansas Insurance dbf artment

By:_Kon Seliter

Commissioner

Date:

Todd C. Kiser

Cpmmissioner

Date;

IICC Insurance Uou)iNGSi

By;

UTAH INSURANCE DEPARTMENT

By:„

Name:

Date:

Regulatory Scitleraeaf AgreementNAIC No. 92711J12U6S4 i

Fage 10Execniion Copy

2018- 5440

SIGNATURE PAGE TO REGULATORY SETTLEIvrENT AGREEMENT

"LEAD STATES"

FLORlbA OFFICE OF INSURANCE

Regulation

By;_^David Altmaier

Commissioner

Date;

Indiana department of insurance


Date:

Kans, ARTMENT

in Selzer

Commissioner


By;Todd E. Kiser

Commissionei-

"HCCirFE"

HOC LIFE Insurance Comj

Title:

Date:^

HOC Medical Insurance Services

Nflme; j; S . Cjj

Title:

Date:

HCC INSURANCE HQy>INGSjl

By:,

Naine.<C^At^pW" T:6^(JTitle;

Date;

Date:

Regulatoi*y Settlement AgreementNAIC No. 92711131266'! I


2 0 1 8 - 54 4 0

SIGNATURE PAGE TO REGULATORY SETTLEMENT AGREEMENT

"LEAD STATES"

■ ■ i

Florida Office of InsuranceRegulation >

oy:David Altmaier

Commissioner

Date:

INDIANA Department OF Insurance

By;Stephen \V, RobertsonCommissioner

Dale:

Kansas Insurance Department

By:

Ken Sclzer

Commissioner

Date:

UTAH In E EUEPARTMENT

T<wd E. Kiser

Commissioner

Date: • '7

"HCCLIFE'

HCC LIFE Insurance Company.

By:

>

Title: \

Date:

HCC Medical Insurance Serjuces, LLC

Name: .T- B. 0^^

Title:

Date:^

HCC insurancehqldings, Inc.

By^

Name: B.

Title:

Date:

Regulatory Settlement AgreementNAIC No. 92711


2018- 5440

EXHIBIT A


1. Alabama

2. Alaska

3. Arizona

4. Arkansas5. California

6. Colorado7. Connecticut


9. Florida*10. Georgia11. Idaho

12. Illinois

13. Indiana**

14. Iowa

15. Kansas*


18. Maine


23. Nebraska

24. Nevada

25. New Jersey26. New York ■

27. North Dakota

28. Ohio

29. Oklahoma

30. Pennsylvania31. Rhode Island

32. South Carolina

33. South Dakota

34. Tennessee

35. Texas

36. Utah*

37. Vermont

38. Virginia39. Washington40. West Virginia41. Wisconsin

42. Wyoming

* - Lead Slate ^** - Managing Lead State

Regulatory Settlement AgreementNAlC No. 92711.1312684 1

EXHIBIT A

Participating States

2018- 5440

EXHIBIT B

Muhistate Tai^eted MaHcet Conduct Exam mationof

HCC Life Insurance CompanyKegulatory Settlement Agreement


On behal f of [Insert Name of Insurance Regulatory

Agency]^ I [Insert Name of Offlcial Signing Below],

have received, reviewed and do hereby adopt, agree to and approve that ceilain Regulatory Seltlement

Agreement executed by HCC Life Insurance Company on the day of , 2017.


By;

Printed;

Title; _

Date:


CONTACT NAME:

MAILING ADDRESS:.

PAYMENT MADE TO:



Chad T. Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700

Indianapolis. Indiana 46204Phone: 317.684.5199

Fax; 317.223.0199

Email: cwalker@boselaw,com

Regulatory vSettlemcnt Agreement EXHIBIT BNAIC No. 92711 Subscribing State Adoption3312ft84 I

2018- 5440

Exhibit A

MLLTISTATE TARGETED MARKET CONDUCT EXAMINATIONOF

HCC LIFE INSURANCE COMPANY



f On behalf of the Texas Department of Insurance (TDI), I, Kent C. Sullivan, hereby adopt,agree to, and approve the Regulatory Settlement Agreement, as amended in the Texas consentorder.

Texas Department of Insurance

By:

Title:

Date:

Commissioner of Insurance

Please provide the following information as to how your jurisdiction's allocation of the Multi StateAdministrative Payment should be sent from Nationwide Mutual Insurance Company.

CONTACT NAME:

MAILING ADDRESS:

Catherine Bell

Texas DeparUnent of InsuranceAttn: Enforcement Section

Division 60851, MC 9999P.O. Box 149104

Austin, Texas 78714-9104

PHONE NUMBER: 512-676-6327

EMAIL:

PAYMENT MADE TO;

Please return this foiTn to:

[email protected]

Texas Department of Insurance

Chad T. Walker

Bose McKinney & Evans, LLP111 Monument Circle, Suite 2700


Fax: 317.223.0199


ExhM B

Multistage Targeted Market Conduct Examinationof

KCC Life Insumce CompanyRegulatory Settlement Agreement


On behalf of Utah Insurance Department, I, TODD E. KISER, have received, reviewed and do

hereby adopt, agree to and approve that certain Regulatory Settlement Agreement executed by HCC

Life Insurance Company on the day of ^ 2017.

UTAH INSURANCE M^TMEOT

By: ,

Printed;

Title; Commissioner, Utah Insurance Department

Date; //> ^"7

Please provide the following information as to how your jurisdiction's allocation of the MuJtistatePayment should be made from HCC Life.

CONTACT NAME: Patrick LeeMAILING ADDRESS: STATE OFFICE BUILDING, ROOM 3110, 350 N. State Street,

Salt Lake City, UT 84114PAYMENT MADE TO: Utah Insurance Department

Upon completion, please return this form to;

Chad T. Walker

Bose McKlnney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317 684-^5199Fax: 317223-0199

Email; cwaycer^boselaw.com

COMMONWEALTH OF VIRGINIA

180230272STATE CORPORATION COMMISSION w w

AT RICHMOND, FEBRUARY 27,2018

HCC LIFE INSURANCE COMPANY

HOC MEDICAL INSURANCE SERVICES LLC

HCC INSURANCE HOLDINGS, INC.

CASE NO. INS-2018-00029

Ex Porte: In the matter of Approval of aMulti-State Regulatoiy S ettlement Agreementbetween HCC Life Insurance Company, HCC Medical

C5o

Insurance Services LLC, HCC Insurance Holdings,'Inc., S 'and the State of Indiana Department of Insurance, ^ S AState of Florida Office of Insurance Regulation, ^ gSState ofKansas Insurance Department, and State of cr 5=Ûtah Insurance Department for and on behalf of the — gSVirginia Bureau of Insurance ^5

I t 3cmcr m

ORDER APPROVING SETTLEMENT AGREEMENT ^

ON THIS DAY came the Bureau of Insurance ("Bureau"), by counsel, and requested:

(i) State Corporation Commission ("Commission") approval and acceptance of a multi-state

Regulatory Settlement Aêement ("Agreement"), dated December 19,2017, a copy of which is

attached hereto and made a part hereof, by and between the commissioners of insurance for the

States of Indiana, Florida, Kansas, and Utah, and HCC Life Insurance Company,^ an Indiana

company licensed to transact the business of insurance in the Commonwealth of Virginia, and

(ii) authority to execute any documents attendant to the Agreement necessary to evidence the

Commission's acceptance of the Agreement.

NOW THE COMMISSION, having considered the terms of the Agreement together with

the recommendation of the Bureau that the Commission approve and accept the Agreement, is of

the opinion, finds, and ORDERS that: (i) the Agreement hêby is APPROVED AND

^ The Agreement also includes HCC Medical Insurance Services LLC and HCC Insurance Holdings, Inc. HCCMedical Insurance Services LLC, and HCC Insurance Holdings, Inc., are not licensed to transact the business ofinsurance in Virginia; therefore, tiiis order does not include these companies.

ACCEPTED and (ii) the Commissioner of Insurance hereby is authorized to execute any

attendant documenis necessary to evidence the Commission's approval and acceptance of the

Agreement.

AN ATTESTED COPY hereof shall be sent by the Clerk of the Commission to: T. Ark

Monroe, III, Esquire, and Rick Campbell, Esquire, Mitchell Williams, Selig, Gates &Woodyard,

P.LX.C, 425 W. Capitol Avenue, Suite 1800, Litde Rock, Arkansas 72201; and a copy shall be

delivered to the Commission's Office of General Counsel and the Bureau of Insurance in care of

Deputy Commissioner Julie S. Blauvelt.

"C"Clerk of the

State Corporatton Commission

Commonwealth of VirginiaSTATE CORPORATION COMMISSION

IN THE MATTER OF:

HCC Life Insurance CompanyHOC Medical Insurance Services LLC, andHCC Insurance Holdings, Inc.

CASE NO. INS-2018-00029

PARTICIPATING REGULATOR ADOPTION

ON THIS DAY this matter came before the Virginia Bureau of Insurance, State CorporationCommission ("Bureau") for consideration, and, upon consideration thereof, the Commissioner ofInsurance finds:

1. HCC Life Insurance Company is licensed to transact the business of insurance in theCommonwealth of Virginia.^ As affecting the Commonwealth of Virginia, the Bureauhas jurisdiction over the subject matter of this proceeding and the Company;

2. On May 13, 2016, regulators from the Florida Office of Insurance Regulation, the IndianaDepartment of Insurance, the Kansas Insurance Department, and the Utah InsuranceDepartment (collectively, "Lead Regulators"), called a multi-state market conductexamination of HCC Life Insurance Company, HOC Medical Insurance Services LLC,and HCC Insurance Holdings, Inc. (collectively, the "Companies"). The review focusedon the Companies' writing, form filing, marketing, soliciting and claims payment of(short-term) medical insurance plans in the Participating States during the period ofMarch 23, 2010 through April 30, 2016, as well as a review of HCC Life InsuranceCompany's contractual relationship with Health Insurance Innovations, among otherthings;

3. A settlement has been presented to the Bureau, the terms of which are set forth in aRegulatory Settlement Agreement ("Agreement") which has been signed by theCompanies and the Lead Regulators. The Companies understand that they have a right toa hearing in this matter, and have agreed to waive such rights, in accordance with theAgreement.

4. The Bureau expressly adopts, agrees and approves this Agreement as a fair and properdisposition of the matters addressed herein.

^ The Agreement also includes HCC Medical Insurance Services LLC, and HCC Insurance Holdings, Inc. HCCMedical Insurance Services LLC, and HCC Insurance Holdings, Inc. are not licensed to transact the business ofinsurance in Virginia; therefore, this order does not include these companies.

THEREFORE, IT IS DIRECTED that the Agreement dated, December 19, 2017, andattached hereto as "Exhibit A" be, and is hereby, approved, adopted, and fully incorporatedherein by reference. The Company shall initiate compliance with all terms and conditions of theAgreemCTrt; as incorporated herein, including payment ofa multi-state payment of $5,O(K1,O0O, ofwhich $118,592.14 is aOocable to the Commonwealth of■Virginia. All terms and condifions ofthe Agreement be, and they are hereby, further directed.

A COPY hereof shall be filed with the Clerk of the Commission and thereby placed in CaseNo. INS-2018-00029.

]

Scott A. White, DateCommissioner of InsuranceBureau of InsuranceState Corporation CommissionCommonwealth of Virginia

MQIO^TORY SBTTTtEMOT AGI^

IteRBGUlATOY is catered ito irfsl^gf Pecembar. 2017 by md dxatmgi (i) HCC Um iNSUItAHCE CWPANY ("HCC 00 HCC

iNsiiituscE smmm, ixc fHCC mis«) ; ® holdin(s, iwa(^^db^s'^XCHCC l4fe, HCQ MIS aad Hcddijigs, with fteirrespîve Affiliates, colteeti^yxef^d to herein as the "HCG Gnnip"); (lli) the fWM>A CÎCE OB ItOSimAHCS lÔTEAIIONfFOIR"); (iv) the INDIAKA DEPARTMENT OF iNSURAira flDOF); (v) the KANSAS msmAmnDEPARTMENT ("KID"); (vi) UTAH INSURANCE Dhpartm^ ("tJID") OIR, IDOL KID and UED.collectively referred to hîn 89 the "Dead Stat^"); and (vii) the miânce-related regulatory bodies ofsuch other judsdictions as choose to adopt, agree to and approve this Agreement (the "SubscribingStates") (Shbscdbii^ St^ and Lead State® cr^leotively to feein as tj^ "5 ettbng Stetes") (tl^Sîng es and HC^ life coUet^vdy reteed to herein

RECITALS

WHEREAS, Holdmgs is the parent company of HOG Life and of HCC MIS;


WHEREAS, during the Examination Period, HCC Life (NAIC #92711) marketed and sold short-term medical insurance produ^ ("STM Products" as defined in'Sedlcm 2 below) throughout the UnitedStates; .

WHEREAS, the Settling States have regulatory jurisdiction over the business of insinanceconducted in their respective jurisdictions, including tiie authority to conduct market conductexaminations;

WHEREAS, the JDOI, as managing Lead State, advised HCC Life on May 13, 2016, that amultistate market conduct escamination (the "Examination") had been called regarding HCC Life'swriting, form filing, marketii^, soliciting and claims payment pf STM Products during the periodMarch 23,2010 through April 30, 2016 (the "Examination Period");

whereas, thwe are presently forty-two (42) jurisdictions participating in the Examination, ofwhich STM Products were sold by HCC Life in tl^-nine (39) (the "Participating States") includingthe four (4) Lead States and thirty-eight (38) Participating S^tes, a list of which may be found on ExhibitA, attached hereto and by reference incorporated herein;

WHEREAS, file Bxamfnation was conducted in coi^'unption with a separate multis^te;examination: of thdrd parties, Health hisurance Innovationsj Ihc, , (ORG'# 118438)^ Health PlanIntermediaries, LLC, and their parent companies and Aviates (collectively, "HH"). Throu^ HO'snetwork of agents and <®11 centers, HII m^keted, sold and cotlected premium for HCC Life's STMProduct (as defined in Section 2 below). The multistate examination of HII (the "HE Examination")continues;

WHEREAS, the Examiner-in-Charge has presented to HCC Life and the Lead States adate;

WHEREAS, HCC Life denies any wrongdoing or activities that violate any applicable insurancelaws or regulations, and notung contained herck, or to exûtibn and perfonnan!^ of this Agreement

Ajgreemmit FagelNAIC No, 92711 Execution Copy3312684 1

shall be deemed or constnied as evidence, or an admission or acknowledgment by HCC Life of anywrongdoing or liability whatsoever;

WHEREAS, based upon the review and analysis of the preliminaiy statement presented by theExaminer-in-Char^, HCC Life agrees to the conditions of this Agreement and the resolution of thosematters within the scope of the Examination as set forth in the April 26, 2016 Examination Warrant,which scope remains unchanged, (the "Examination Scope") all as more particularly provided herem;

WHEREAS, in view of the foregoing facts and circumstances, the Settling States find it to be inthe public interest and are willing to accept this Agreement to'settle all insurance regulatory matterswithin the Examination Scope;


WHEREAS, HCC Life has cooperated with the Examiner-ln-Charge in the course of theExamination by making its books and records available for examination, and its personnel and agentsavailable to assist as requested by the Examiner-iix-Charge;

WHEREAS, HCC Life represents that at all times relevant to this Agreement, HCC Life and itsofficers, directors, employees, agents and representatives acted in good faith; and

WHEREAS, HCC Life and the Settling States execute this RSA knowingly and voluntarily, aridthe Parties acknowledge that this Agreement is in the public interest and desire to end the Examinatioa

NOW, THEREFORE, in consideration of the Recitals, the mutual covenants and agreementsherein, and each act performed and to be performed hereunder, the Parties agree as follows;

1. Tncnrporation ofRedtals. The above and foregoing Recitals, including, without limitation, allcapitalized terms defined therein, are hereby incorporated into" and made a part of this Agreementas if more fully set forth in the body of this instrument.

2. Definitions. The terms listed below shall have either the meaning given in this section or thedefinition given elsewhere in the Agreement.

a. "Affiliate" shall mean a person that directly, or indirectly through one or more intermediaries,controls or is controlled by, or is under common control with, the person ecified.

b. "Agreement" shall have the meaning set forth in the first paragraph ofpage 1,




f. " Claims Audit" shall have the meaning set forth in Section 4b. of this Agreement.


Regulatory Settlement Agreement Page 2NAIC No. 92711 Execution Copy3312684 1

h. "Examination" shall have the meaning set forth in the first paragraph of page I.

i. "Examination Scope" shall have the meaning set forth in the tenth clause of the Recitals.

j. "Examiner-in-Charge" shall mean Chad T. Walker of the law firm Bose McKinney &Evans LLP.

k. "Final Effective Date" shall have the meaning set forth in Section 10.

I. "FOIR" shall have the meaning set forth in the first paragraph of page 1.



o. "HCC MIS" shall have the meaning set forth in the first paragraph ofpage 1.

p. "HCC Third Party Audit" shall have the meaning set forth in Section 4d. of this Agreement

q. "HCC Life STM Policies" shall mean any STM Products sold, marketed, underwritten orissued by HCC Life, either directly or indirectly through third parties, including, withoutlimitation, HII.

, r. " Hir' shall have the meaning set forth in the sixth clause of the Recitals.

s. "HH Examination" shall have the meaning set forth in the sixth clause of the Recitals.

t. "Holdings" shall have the meaning set forth in the first paragraph of page 1,

u. 'TOOT' shall have the meaning set forth in the fir^ paragraph of page 1.

V, "KID" shall have the meaning set forth in the fust paragraph of page 1.

w. "Lead States" shall have the meaning set forth in the first paragraph of page 1.

X. "Multistate Payment" shall have the meaning set forth in Section 5a, ofthis Agreement.

y. "Participating States" shall have the meaning set forth in the fifth clause ofthe Recitals.

z. "Parties" shall have the meaning set forth in the first paragraph of page 1.

aa. "Settling States" shall have the meaning set forth in the first paragraph of page 1.

bb. "STM Products" shall mean the approved short-term medical insurance policies as filed byHCC Life and sold to individuals, either directly or through a group, wi& limited coverageperiods as determined by applicable state laws and regulations.

cc. "Subscribing States" shall have the meaning set forth in the first paragraph of page I.

dd. "UTO" shall have the meaning set forth in the first paragraph of page 1.

Regulatory Settlement Agreement Page 3NAIC No. 92711 Execution Copy3312684 1 .

3. Short Tenn Medical Business. HCC Life represents to the Settling States that, effective June 1,2017, it ce^ed the sale, marketing and underwriting and premium collections* of all STMProducts directly or indirectly offered or underwritten by HGC Life, except as otherwise requiredin order to conduct the run-off of its STM business in accordance with applicable laws andregulations. HCC Life covenants and agrees that it shall not directly or indirectly enter into thesale of short-term medical insurance witiiia any of the Settling States for a period of five (5) yearsfrom the Final Effective Date. In the event HCC Life commences the sale or marketing of STMProducts in any Settling State following such period, HCC Life shall file forms and rates asrequired by applicable laws and regulations.


a. HCC Life shall administer and adjudicate any and all claims filed in relationriiip to HCCLife STM Policies in a timely fashion and in strict compliance with the terms andconditions of the policies and any and all applicable laws, rules, and regulations.

b. Within one htmdred twenty (120) days of the Final Effective Date, the Examiner-in-Charge shall commence a preliminary audit (in accordance with tiie NAIC MarketRegtdation Handbook) of HCC Life's claims handling practices for the STM Productsfor the period of June 1, 2017 through the date of the commencement of suchexamination (the "Claims Audit"). Upon completion of the Claims Audit, the Examiner-in-Charge shall present his preliminaiy- findings to the Lead States. The Claims Auditcovers a period of time beyond the scope of the original Examination, and, therefore, theLead States reserve the ri t to additional examination(s) of HCC Life as a result of theClaims Audit together with' the right to impose financial, regulatoiy, and performancesanctions with respect thereto. HCC Life shall be responsible for the full, complete, andprompt payment of all fees and expenses of the Examiner-in-Charge in conducting andreporting on the Claims Audit in compliance with the laws of the State of Indiana. Uponthe request of a Participating State, the Exaxniner-in-Charge shall provide any finalreports regarding the Claims Audit previously provided to Lead States to suchParticipating State.

c. Within ninety (90) days of the Final Effective Date, the Examiner-in-Charge shallcommence a prelimmary audit (in accordance with the NAIC Market RegulationHandbook) of HCC Life's business practices for the STM Products to include, withoutlimitation, writing, form filing, marketing, soliciting, claims payment, licensing andappointments (the' "Business Practice Audit"). Upon completion of the BusinessPractice Audit, the Examiner-in-Charge shall present his preliminaiy findings to the LeadStates. The Lead States reserve the right to additional examination(s) of HCC Life as aresult of the Business Practice Audit together with the right to impose financial,regulatory, and performance sanctions with respect thereto, HCC Life shall beresponsible for the fitil, complete, and prompt payment of all fees and expenses of theBxaminer-in-Chargie in conducting and reporting on the Business Practice Audit incompliance with the laws of the State of Indiana. Upon the request of a Participa^State, the Examiner-in-Charge shall provide any fM reports regarding the BusinessPractice Audit prewously provided to Lead States to such Participating State.

' The Parties acknowledge that HCC Life continues to collect premiums on in-force business at the time ofwithdrawal from the applicable market.

Regulatory Settlement Agreement PagedNAIC No, 92711 Execution Copy3312684 1

d HCC Life shall regularly audit the business practices of its producers, third partyadministrators, managing general agents, and contractors across all lines of its business,and make commercially reasonable efforts to ensure compliance with all applicable laws,rules and regulations and operate in a sound fashion (the "HCC Life Third PartyAudit").

e. Within 180 days of the Final Effective Date, HCC Life shall, to the extent it deemsnecessary, establish, document, and provide to the Examiner-in-Charge standards andprocedures to conduct regular audits of its internal and third-party operations across alllines of business (the "Audit Procedures"). Such Audit Procedures shall include reviewof controls in place to ensure compliance with filed rating plans, foim usage, licensing,appointments, marketing, claims handling, sales, and premiums are in compliance withapplicable laws, rules - and regulations. Upon receipt of Audit Procedures, the Examiner-in-Charge shall provide the Audit Procedures to the Lead States, who in turn shall reviewand either approve or return to Company with directions for further revision.Alternatively, at the- discretion of the Lead States, the Lead States may direct theExaminer-in-Charge to review the Audit Procedures and provide the Lead States with asummary of such Audit Procedures and the findings, if any, of the Examiner-in-Charge.Any review of such Audit Procedures by the Examiner-in-Charge shall be at the expenseof HCC Life.


a. HCC Life shall pay a total of $5,000,000 to 'the Settling States for the examination,administrative costs and compliance in connection with the Examination (the "MultistatePayment"). This payment shall be allocated among the Settling States as they agree.

b. Except as otherwise, specifically provided herein, and provided'HCC Life's full and■ complete compliance with this Agreement, the Multistate Payment shall be the soleamount charged, assessed or collected by the Settling States on HOC Life with respect tothe Examination Scope during the Examination Period.

c. Within ten (10) days of the Final Effective Date, the Bxaminer-in-Charge shall provideHCC Life a document reflecting how the Multistate Payment is to be allocated among theSettling States.

d. HCC Life acknowledges the validity and legitimacy of the Multistate Payment and shallpay the Multistate Payment within 30 days of the Final Effective Date. Once paid byHCC Life, the Multistate Payment is final and non-recoverable under any circumstances,including without limitation termination of this Agreement. However, HCC Life reservesall rights to pursue a private cause of action against third parties, and the Settling Statesagree that nothing in this Agreement precludes HCC Life from exercising any suchrights.

6. Cooperation with HH Examination. HCC Life shall continue to fiilly and completely cooperatewith the Lead States and the Examiner-in-Charge with respect to the continuing HH Examination.HCC Life shall voluntarily (without service of subpoena) provide any and all unprivileged books,records, documents, instruments, writings, data or other tangible evidence available and requestedby the Examiner-in-Charge and shall make HCC Life personnel available as requested by theExaminer-in-Charge as such information and personnel relate to the HH Examination.

Regulatory Settlement Agreement Page 5NAIC No. 92711 Execution Copy33126S4 1

7. Regulatory Oversight, The Lead States shall maintain regulatoiy authority and oversight overHCC Life's compliance with the terms of this Agreement. With respect to such continuingoversight, HCC Life agrees as follows:

a. For a period of twenty-four (24) months following the Final Effective Date, HCC Life shallprovide to the Examiner-in-Charge semi-annual reports on the implementation and executionof the requirements of this Agreement. Each report shall be delivered to the Examiner-in-Charge within 45 days following the end of the applicable reporting period (e.g.

i rinsert due dates based on execution date]. Copies ofthese reports will be providedto the Le^ States as well as to the Participating States' respective designated examiners,upon their request.

b. Twenty-Four (24) months following the Final Effective Date, the Lead States, through theExaminer-m-Charge, shall conduct a preliminaiy audit in accordance with the NAIC MarketRegulation Handbook) multistate examination on their own behalf and that of the SettlingStates of HCC Life's compliance with the requirements of this Agreement. The Lead Statesshall provide a report summarizing the-results of that examination to HCC Life and theSettling States. HCC Life shall be responsible for the full, complete and prompt payment ofall fees and expenses of the additional audit(s) and of Examiner-m-Charge in conducting andreporting the additional audit(s) in compliance with tiie laws of the State of Indiana.

c. In addition to any payments otherwise provided in this Agreement, the costs of the SettlingStates related to the monitoring of HCC Life's compliance with the Agreement, includingcosts and expenses of conducting any reviews or examinations permitted herein, the costs andexpenses of the Examiner-in-Charge as it relates to his obligations hereunder, as well asparticipating in any meetings, presentations or discussions, with HCC Life and the costs ofany third-party examiner(s), shall be the full and sole responsibility of HCC Life as costs ofthe Examination..

8. Release. Subject to HCC Life's full and complete performance of and compliance with the termsand conditions in this Agreanent, each Participating State hereby releases the HCC Group fromany and all claims, demands, interest, penalties, actions or causes of action that each ParticipatmgState may have or could have alleged by reason of any matter, cause or thing whatsoever,regarding or relating to the subject matter of the Examination within the Examination Period;provided, however, that nothing herein shall preclude the Lead States from conductingsubsequent examinations to assess HCC Life's compliance with this Agreement or such otherexaminations or audits as expressly provided herein.

9. Default.

a. HCC Life's feilure to comply with any material provision of this Agreement shallconstitute a breach of the Agreement, a violation of an order of the Settling States and aviolation of HCC Life's Agreement with the Settling States, and shall subject HCC Lifeto such administrative and enforcement actions and penalties as each Participating Statedeems appropriate, consistent with each Participating State's respective laws.

b. Any agreement on the part of any party hereto to any extension or waiver shall be validonly if in writing signed by the party granting such waiver or extension and, unless itexpressly provides otherwise, shall be a one-time waiver or extension only, and any suchwaiver or extension or any other failure to insist on strict compliance with any duty or

Regulatory Settlement Agreement Page 6NAIC No. 92711 Execution Copy33126S4 1


c. If a Settling State believes that the Company has breached a provision of this Agreement,that Settling State shall provide written notice of the alleged breach to HOC Life and willalso notify the Lead States that the alleged breach has occurred. HOC Life shall have theopportunity, within thirty (30) days of receipt of such notice, to present evidence inwriting and through appearance before the complmiung state insurance regulator in anattempt to rebut the allegatioh(?) or to seek an extension to address the alleged breach. ASettling State shall not pursue any enforcement action as set forth in Section 9.a. againstHOC Life until the 30-day response period described above has expired.

10. Effectiveness.

a. This Agreement shall be finally effective on the date in which the Examiner-in-Chargeprovides HCC Life with a copy of this Agreement adopted, agreed to, and approved bythe first to occur of (i) twenty-five Settling States or; (ii) sixty percent (60%) of the grosspremium written during the Examination Period, as identified by the Bxaminer-in-Charge(the "Final Effective Date"). Except as provided in Subsection c of this Section 10, theFinal Effective Date shall be 90 days after the Conditional Effective Date.

b. The Examiner-in-Charge shall arrange to deliver this Agreement within seven (7)calendar days following the Conditional Effective Date to the Participating States.Participating States may adopt, agree to, or approve the Agreement by means of theSubscribing State Adoption Form attached as Exhibit B and by reference hereinincorporated.

c. The Lead States and HCC Life may agree in writing to extend the initial Final EffectiveDate and each extended Final Effective Date thereafter in writing, in which case theExaminer-in-Charge shall notify the Participating .States who may then choose whether toparticipate hereunder on or before the date of the extended Final Effective Date.

d. If the Final Effective Date does not occur by the initial Final Effective Date provided inSubsection a. of this Section 10, or such extended Final Effective Date thereafter asprovided in Subsection c. of this Section 10, this Agreement shall be deemed null andvoid and of no further force or effect.

11. Additional Terms.

a. No Admission. This Agreement represents a compromise of disputed matters between theParties. Neither this Agreement, nor any of the communications or negotiations leadingup to this Agreement, nor any actions taken or docximents executed in connection withthis Agreement, is now or may be deemed in the future to be an admission or evidence ofany liability or wrongdoing by the HCC Group or any of its ci^nt or former affiliates,subsidiaries, officers, directors, employees, agents or representatives with respect to thesubj ect matter of the Examination or the Examination Scope.

b. Third Party Reliance. This Agreement is m agreement solely between the named Partiesas defined above, and no other person or entity shall be deemed to obtain or possess anyenforceable rights against the HCC Group as a third party beneficiaiy or otherwise as aresult of this Agreement. The Parties agree that this Agreement is not intended to and

Regulatory Settlement Agreement Page 7NAIC No. 92711 Execution Copy3312684 J

shall not confer any rights upon any other person or entity and shall not be used for anyother purpose. Nothing in this Agreement shall be construed to provide for a private rightof action to any person or entity not a party to this Agreement. Nor shall the Agreementbe deemed to create any intended or incidental third party beneficiaries, and the mattersherein shall remain within the sole and exclusive jurisdiction of the Settling States.

c. HII Examination. Nothing in this Agreement shall prevent or otherwise restrict aParticipating State or the Examiner-in-Charge fi-om continuing the HU Examination orfrom otherwise examining the conduct of HII in any manner, including, withoutlimitation, HITs contractual relationship and dealings with the HCC Group. Additionally,nothing in this Agreement shall prevent or otherwise restrict the HCC Group fiomotherwise pursuing a private ri t of action against a third party for such third party'sfailure to comply witii the terms and conditions of a contractual agreement by andbetween HCC Life and such tiiird party.


Exhibit A Participating StatesExhibit B Subscribing State Adoption Form


f Rights and Remedies. Except as otherwise provided in this Agreement, the rights, powers,remedies and privileges provided in this Agreement are cumulative and not exclusive ofany rights, powers, reme^es and privileges provided by applicable law.

g. Settling State Authority. Each person signing on behalf of each of the Settling Statesgives his or her express assurance that under applicable state laws, regulations, andjudicial rulings, he or she has authority to enter into this Agreement

h. HCC Life Authority. HCC Life expressly represents and warrants as of the date of itsexecution of this Agreement that: (i) it is duly organized, validly existing and in goodstanding under the laws of its juris^ction of incorporation or organization and has theabsolute, unrestricted ri t power, authority and capacity to execute and deliver thisAgreement and to perform its obligations arising hereunder, without any fiulher consentor approval being required fiom any individual person, parent company or otherorganization or entity; (ii) it has obt^ed all necessary authorizations, approvals, orconsents of any governmental entity required in connection with the execution, delivery,or performance by it of this Agreement; (iii) it has conducted all investigations it deemsappropriate and necessary to determine whether to enter into this Agreement; and (iv) ithas read this Settiement Agreement, enters into it knowingly and voluntarily and has beenadvised by its legal counsel as to the legal effect of tMs Agreement.

L Choice of Law. This Agreement and any disputes or conflicts which may arise inconnection with the interpretation or enforcement of this Agreement, and the rights andobligations of the Parties, shall be governed by the^laws of the State of Indiana withoutregard or reference to choice or conflict of law rules. The HCC Group and the SettlingStates consent to the exclusive jurisdiction of the United States District Court for theSouthern District of Indiana or the Superior Court 'for Marion County, Indiana for thepurposes of interpreting and enforcing this Agreement.

Regulatory Settlement Agreement Page 8NAIC No. 92711 Execution Copy3312684 J

j. Joint Preparation. This Agreement, exclusive of any statements or findings, preliminaiyor otherwise, of the Examiner-in-Charge, shall be deemed to have been prepared jointlyby the Parties hereto. Any ambiguity herein shall not be interpreted agaiiit any Partyhereto and shall be interpreted as if each of the Parties hereto had prepared thisAgreement.

k. Interpretation. Titles and headings to sections herein are inserted for convenience ofreference only and are not intended to be a part of or to affect the meaning orinterpretation of this Agreement. Whenever the context requires in this Agreement, thesingular shall include the plural, and vice versa.

I. Invalidity. In the event that any portion of this Agreement is enjoined or held invalidunder the laws of a Participating State's jurisdiction, such enjoined or invalid portionshall be deemed to be severed only for the duration of the injunction, if applicable, andonly with respect to that Participating State and its jurisdiction, and all remainingprovisions of this Agreement shall be given full force and effect and shall not in any waybe affected thereby.

m. Entire Understanding; Modification. This Agreement represents the entire understandingbetween the Parties with respect to the subject matter hereof and supersedes any and allprior understandings, agreements, plans, and negotiations, whether written or oral, withrespect to the subject matter hereof. All modifications to this Agreement must be inwriting and signed by each of the Parties hesreto.



Regulatory Settlement Agreement Page 9NAIC No. 92711 Execution Copy33I26S4 1

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Commissioner

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Page 10JExeeuthn dopy

EXHIBTT A


1. Alabama

2. Alaska

3. Arizona

4. Arkansas

5. Califonua

6. Colorado

7. Connecticut


9. Florida*

10. Georgia11. Idaho

12. niinois

13. Indiana**

14. Iowa

15. Kansas*


18. Maine


23. Nebraska

24. Nevada

25. New Jersey26. New York ■

27. North Dakota

28. Ohio

29. Oklahpina30. Pennsylvania31. Rhode Island

32. South Carolina

33. South Dakota

34. Tennessee

35. Texas

36. Utah*

37. Vermont

38. Vir^nia39; Washington40. West Virginia41. Wisconsin

42. Wyoming

* -LeadState**.

SpOBlTANAIC No. 92711 Partlctimtiiig States3312^4 I

ECTTBITB



STJBSCRTBTNC STATE AnQ-PTTON

On behalf of Virginia. I, Scott A. "White, have received, reviewed and do hereby adopt, agree to

and approve that certain Regulatory Settlement Agreement executed by HOC Life Insurance

Company on the 14 day of February, 2018.

State Corporation ComTm'ssion Bureau of Insurance{Print Name of Insurance Regulatory Agency] •

By:

Printed: Scott A. White

Title; Commissioner of Insurance

Date: February 14.2018

Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made firom HCC Life.

CONTACT NAME: Marie Cox

MAILING ADDRESS: 1300 East Main Street P O. Box 1197 Richmond. VA 23219

PAYMENT MADE TO: Treasurer of Virginia



Chad T.Walker

Bose McKiimey & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199


Regulatory Settlement Agreement EXBIBIT BNAIC No, 92711 Subscribing State Adoption33126B4 1

ICXTTTBTTB

Multistate Taz^eted Market Conduct Examination ' 'of . '

HOC Life lusuraitce CompanyRegulatory Settlement Agreement

SrmSCRTBTNfi STATC AftO?TTON

On behalf of Washington State Office of Insurance Commisaiouer, I, Mike tCreidler as Insui-ance

Commissionei', have raceived, reviewed and do hereby adopt, agree to and approve that certain

Regulatory Seltletiient Agi'eement executed by HOC Life Insurance Company on the 19"' day of

December, 2017.

Washington State Office of Insiu-ance Commiasioner

By:Mike Kreidl^

Titje: Insurance Commissioner, Washington State

Date: Pmetary / 2018

Please provide the following information as to how your jurisdiction's allocation of the Multi-State Payment should be made from HOC Life.

CONTACT NAME: John Hawoitli, Mmket Conduct Oversight Manager

CONTACT PHONE: (360) 725-7223

MAILING DDRESS: PC Box 40255, Olympia, WA 98504-0255

PAYMENT MADE TO: Oftloe of Insurance Commissioner


Upon completion, pleas© mturn tliis form to:

Chad T.Walker


Pax: 317.223.0199


EXHIBIT R

Miiltistate Targêd Marlcet Conduct JExaininaBonof

HOC Life insurance CompanyRegulatory Settlement Agreement

?fTATR APOPTTQIN

On behalf of West Virginia OfTices of the Insurance Commissioner. 1 Allan L. McVcv. have

repeived, reviewed and do hereby adopt, agree to and approve that certain Reguiatory Settlement

Agreement executed by HCC Life Insurance Company on the 19th day of December 2017.

State of West VirginiaOfUces of the insurance Commissioner

By:

Printed: Allan L. McVev


Date: /•—/jZ - ^ /S'

Please provide the following information as to how your jurisdiction's allocation of the MuUistatePayment should be riiade from HCC Life.

CONTACT NAME: Mark A. Hooker

[email protected]

MAHÎNG ADDRESS; P.O. Box 50540

Charleslon. WV 25305-0540

PAYMENT MADE TO: WV Offices of tlie Insurance Commissioner

IF APPLICABLE. PLEASE PROVIDE WIRING INSTRUCTIONS SEPARATELY.:

; , '

Upon completion, please return tliis form to:

Chad T: Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Pkme: 317.684.5199

Fax: 3I7J223.0I^

Emaii: cwalte^lMâw.com

mrmTTB

Multistate Targeted IVlarket Conduct Examinationof

HCC Life Insurance CompanyR^nlatory Settlement Agreement

STTRSCRTBTNG STATE AROPTTON

On behalf of the Wisconsin Office of the Commissioner of Insurance, I Theodore K. Nickel, have

received, reviewed and do hereby adopt, agree to and approve that certain Regulatoiy Settlement

Agreement executed by HCC Life Insurance Company on the 19th day ofDecember, 2017.

Wisconsin Ofilce of the Commissioner of Insurance

Printed:

Title:

Date:.

Please provide the following information as to how your jurisdiction's allocation of the MultistatePayment should be made fi*om HCC Life.

CONTACT NAME: Richard B. Wicka

MAILING ADDRESS: 125 S. Webster St.. P.O. Box 7873. Madison. WI 53707

PAYMENT MADE TO: Wisconsin Office of the Commissioner of Insurance



Chad T.Walker

Bose McKinney & Evans LLP111 Monument Circle, Suite 2700Indian^lis, Indiana 46204Phone; 317.684.5199

Fax: 317.223.0199


MultistateTarg^^ Market Coaduct Examiaatkpef

SlIBSrRTBfNfi yTATF ^ROPTION

On

cto hereby edppt, agree to and at^rove ttmt certain Regulatpy Settlement Agreement executed by HCC

Life Insurance Company on the day of 2017,

Wyoming Department of Insurance

By:

Printed: Tom Glause


Date:

Please provide the foltovyring information as to how your jurisdiction's allocation of the MultistatePayment should be made from HCC Life,

CONTACT NAME: Beckv McFarland

MAiLrNG ADDRESS: 106 E. Avenue. Chevenne. WY 82QQ1

PAYMENT MADE TO: Wyoming State Treasurer



Chad T.WalkerBose McKinney & Evans LLP111 Monument Circle, Suite 2700Indianapolis, Indiana 46204Phone: 317.684.5199

Fax: 317.223.0199Email; [email protected]

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