OFFICE OF INSURANCE REGULATION CONSENT ORDER. THIS CAUSE came on for consideration as the result of an investigation by the FLORIDA

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1 FILED AUG OFRC&OF "::::':::::":: INSURANCE ieguiation IIUl;lllMII by: SRB OFFICE OF INSURANCE REGULATION DAVID ALTMAIER COMMISSIONER IN THE MATTER OF: CASE NO.: CO AMERICAN GENERAL LIFE INSURANCE COMP ANY CONSENT ORDER THIS CAUSE came on for consideration as the result of an investigation by the FLORIDA OFFICE OF INSURANCE REGULATION ("OFFICE") of AMERICAN GENERAL LIFE INSURANCE COMP ANY ("AMERICAN GENERAL"). The OFFICE, having considered the record in this case and being otherwise fully advised in the premises, finds as follows:. The OFFICE has jurisdiction over AMERICAN GENERAL and the subject matter of this proceeding. 2. AMERICAN GENERAL holds a Certificate of Authority from the OFFICE issued pursuant to Chapter 624, Part III, Florida Statutes, as a life and health insurer in the state of Florida. I 3. Beginning in May 206, AMERICAN GENERAL closed its local offices, and transitioned to a "Home Office District System" ("HODs") billing system. Previously, HODs had been offered as an option to AMERICAN GENERAL policyholders. Because of system errors during this transition, AMERICAN GENERAL failed to send billing notices to some policy owners, did not properly post some premiums, and placed imp act e d policies into

2 lapsed, frozen, or a non-forfeiture status because of these errors. AMERICAN GENERAL also gave a reduced paid-up benefit or improperly denied claims in several instances based on these same errors. 4. The OFFICE was made aware of these issues and, on April, 207, opened an investigation of AMERICAN GENERAL. In January 208, AMERICAN GENERAL provided the following information to the OFFICE regarding the effects of its system errors: a. AMERICAN GENERAL failed to send billing notices for seven thousand, five hundred fifty-seven (7,557) Florida policies {"Total Impacted Policies," each an "Impacted Policy"). b. Of the Total Impacted Policies, five thousand, six hundred eighty-two (5,682) are Single Policy Groups, meaning there is one () policy per billing notice and only one () premium to apply. c. Two hundred seventy-five (275) policies within the Single Policy Groups are paid current or into the future. d. The remaining five thousand, four hundred seven (5,407) policies within the Single Policy Groups are not paid current or into the future ("Delinquent Single Policy Groups"), and are in one () of the following types of impacted status: () life insurance lapsed policies; (2) accident and health lapsed policies; (3) life insurance frozen policies; ( 4) accident and health frozen policies; (5) life insurance policies that entered non-forfeiture extended term status; or (6) life insurance policies that entered non forfeiture reduced paid-up status. e. Of the Total Impacted Policies, one thousand, seven hundred eighty-four (,784) are within six hundred and sixteen (66) Multi-Policy Billing Groups without any policies paid into the future, referred to by AMERICAN GENERAL as the "Delinquent Multi Policy Billing Groups." For each Delinquent Multi-Policy Billing Group, there is more than one 2

3 policy per billing notice and, correspondingly, more than one premium amount. f. Of the Total Impacted Policies, there are seventy-one (7) policies within twenty-nine (29) unique Multi-Policy Billing Groups where at least one of the policies are paid into the future, referred to by AMERICAN GENERAL as the "Advanced Paid Multi-Policy Billing Groups." g. Of the Total Impacted Policies, twenty (20) policies that were formerly in various Billing Groups are now bank draft or a direct bill method. Fourteen (4) of these policies are paid current or into the future. h. Six (6) of the policies falling into this latter category are not paid current or into the future ("Delinquent Direct Bill Policies Group"). 5. AMERICAN GENERAL has further represented that between May 206 and January 208, policy owners filed one hundred forty-two (42) claims on one hundred eleven () policies within the Total Impacted Policies ("Claims"). Prior to discovery of the system errors, AMERICAN GENERAL denied these Claims or gave a reduced paid-up benefit. AMERICAN GENERAL certifies that as of January 9, 208 it paid the full death benefit less a deduction for premiums owed on the policy plus interest consistent with Section , Florida Statutes on each of those Claims. 6. On or around May 206, AMERICAN GENERAL also failed to properly post received premiums on one thousand two hundred sixty-two (,262) policies. AMERICAN GENERAL certifies that as of April 207 it had posted all such premiums with the appropriate policies and corrected or rescinded any erroneously issued cancellation notices. 7. Section ( )(b), Florida Statutes, provide s that "[t]he office shall suspend or revoke an insurer's certificate of authority if it finds that the insurer... is using such methods and practices as to render its further transaction of insurance in this state hazardous or injurious 3

4 to its policyholders or to the public." 8. The OFFICE finds that the actions described in paragraphs three (3) through six (6) above were methods and practices of AMERICAN GENERAL in the conduct of its business. The OFFICE further finds that AMERICAN GENERAL's use of these methods and practices in the conduct of its business would render further transaction of insurance in this state injurious to its policyholders or the public. 9. AMERICAN GENERAL disputes the OFFICE's conclusion that AMERICAN GENERAL used such methods and practices in the conduct of its business as to render further transaction of insurance in this state injurious.to its policyholders or the public. 0. The OFFICE and AMERICAN GENERAL have conferred and agree that it is in their mutual best interests to enter into this Consent Order and avoid the expense, uncertainty, and delay oflitigation.. The OFFICE and AMERICAN GENERAL agree to a full and complete settlement of all issues raised herein on the terms set forth herein. 2. AMERICAN GENERAL shall undertake and complete the following corrective actions: a. Not later than ten (0) days after execution of this Consent Order, AMERICAN GENERAL shall provide to the OFFICE certification, under notarized signature of a company officer with authority to bind AMERICAN GENERAL, that all information submitted in Appendices A, B, C, D, E, F, and G to the letter dated January 26, 208, under signature of Charles Burger, as well as the representations in the letter, are true, accurate, and complete as of January 9, 208. b. Not later than thirty (30) days after execution of this Consent Order, AMERICAN GENERAL shall send letters to all persons owning Impacted Policies with delinquent 4

5 premilllll using the current policy status as of the mailing date for all above referenced billing groups. c. Except as provided ind. below, these letters shall be in the same form as those contained in Exhibit A to this Consent Order, with each individual letter corresponding to the specific impacted status of the subject policy. For Delinquent Single Policy Billing Groups and Delinquent Direct Bill Policies Group, AMERICAN GENERAL shall send a letter to the policy owner summarizing the billing status of the policy. For Delinquent Multi-Policy Billing Groups, AMERICAN GENERAL shall send a letter to the owner of each policy with a reference to the other policies within the same billing group. d. Not later than thirty (30) days after execution of this Consent Order, for Advanced Paid Multi-Policy Billing Groups, AMERICAN GENERAL shall send the letter on the form contained in Exhibit B to this Consent Order to the billing group payer, with a copy to each policy owner. e. AMERICAN GENERAL shall offer every person in the Delinquent Single Policy Groups, Delinquent Multi-Policy Billing Groups, Advanced Paid Multi-Policy Billing Groups and Delinquent Direct Bill Policies Groups who was provided the notice described in paragraphs 2(b)-(d) immediately above ("Recipient") no less than one-hundred eighty (80) days to submit all back premium due from the first date of non- payment through the current payment date. This period for payment shall commence on the date the letter is mailed to the Recipient. If a Recipient does not contact AMERICAN GENERAL or make a premium payment within thirty (30) days of the date the letter was mailed to that Recipient, AMERICAN GENERAL shall send the letter again by certified mail, return receipt requested. g. If AMERICAN GENERAL does not receive a return receipt for the 5

6 second letter, then, if a Recipient does not contact AMERICAN GENERAL or make a premium payment within thirty (30) days of the date the second letter was mailed to that Recipient, AMERICAN GENERAL shall attempt to contact that Recipient using any telephone numbers for that Recipient in AMERICAN GENERAL's records. AMERICAN GENERAL shall keep a log of all attempts to contact Recipients by telephone, listing the date and time of call, phone number called, and name of the AMERICAN GENERAL representative placing the call. h. If a Recipient does not contact AMERICAN GENERAL within the one- hundred eighty (80) days, the policy will remain in its current status consistent with the policy terms.. If all back premiums are paid within the one-hundred eighty (80) days, AMERICAN GENERAL shall reinstate the policy without evidence of insurability. J. If a Recipient contacts AMERICAN GENERAL within the one- hundred eighty (80) day period and indicates he or she wishes to keep the policy or policies but cannot pay all back premiums within that period, AMERICAN GENERAL shall make good faith efforts to arrange a longer period for repayment, up to and including twenty-four (24) months. k. Unless an arrangement for a longer period of repayment has been made, if a Recipient has made only partial payment of back premiums at the conclusion of the onehundred eighty ( 80) days, the policy will be placed into a status consistent with its terms. I. AMERICAN GENERAL shall pay any claim on a policy within the Total Impacted Policies received after May 5, 208, through one-hundred eighty (80) days after the letter regarding that policy has been sent pursuant to Paragraph 2(b) above at full value plus applicable statutory interest, less a deduction for premiums owed on the policy. m. Not later than thirty (30) days after execution of this Consent Order, AMERICAN GENERAL shall pay a fine of $200,000 and administrative costs of $0,000. AMERICAN GENERAL shall send its payment to the address reflected on the invoice (attached 6.

7 as Exhibit C). AMERICAN GENERAL agrees that failure to make this payment in full within the specified time period, in accordance with the terms of the attached invoice hereby incorporated by reference, may result in further administrative action. 3. AMERICAN GENERAL affirms that all representations made herein are true and that all requirements set forth herein are material to the issuance ofthis Consent Order. 4. The deadlines set forth in this Consent Order may be extended by writtenapproval of the OFFICE. Additionally, the various reporting requirements and any other provision or requirement set forth in this Consent Order may be altered or terminated by written approval of the OFFICE. Approval of any deadline extension is subject to statutory or administrative regulation limitations. 5. AMERICAN GENERAL agrees that, upon execution of this Consent Order, failure to adhere to one or more of the terms and conditions contained herein may result in the OFFICE suspending, revoking or taking other administrative action as it deems appropriate upon AMERICAN GENERAL's Certificate of Authority in this state in according with Sections (2)(n) and 20.60(6), Florida Statutes. 6. AMERICAN GENERAL additionally agrees that, upon execution of this Consent Order, failure to adhere to one or more of the terms and conditions contained herein may be considered willful and subject AMERICAN GENERAL to the appropriate penalties and fines. 7. AMERICAN GENERAL additionally agrees that, upon execution of this Consent Order, future failure of HODS to properly bill policyholders and correctly apply premium may be deemed willful and will subject AMERICAN GENERAL to penalties as the OFFICE deems appropriate. 8. AMERICAN GENERAL expressly waives a hearing in this matter, the making of :findings of fact and conclusions of law by the OFFICE, and all further and other proceedings to 7

8 which it may be entitled, either by law or by rules of the OFFICE. AMERICAN GENERAL hereby knowingly and voluntarily waives all rights to challenge or to contest this Consent Order in any forum now available to it, including the right to any administrative proceeding, state or federal court action, or any appeal. attorney's fees. 9. Except as noted above, each party to this action shall bear its own costs and 20. The parties agree that this Consent Order shall be deemed to be executed when the OFFICE has signed and docketed a copy of this Consent Order bearing the signature of the authorized representative of AMERICAN GENERAL, notwithstanding the fact that the copy may have been transmitted to the OFFICE electronically. Further, AMERICAN GENERAL agrees that the signature of its authorized representative as affixed to this Consent Order shall be under the seal of a Notary Public. WHEREFORE, the agreement between AMERICAN GENERAL and the FLORIDA OFFICE OF INSURANCE REGULATION, the terms and conditions of which are set forth above, is APPROVED. FURTHER, all terms and conditions contained herein are hereby ORDERED. DONE and ORDERED this 'J~ day of /)v~vs l lwnd~ avid Altmaier, Commissioner Office of Insurance Regulation 8

9 By execution hereof AMERICAN GENERAL LIFE INSURANCE COMPANY consents to entry of this Consent Order, agrees without reservation to all of the above tenns and conditions, and shall be bound by all p~o\lisions herein. The undersigned represents that he or she has the authority to bind AMERICAN GENERAL LIFE INSURANCE COMPANY to the tenns and conditions of this Consent Order. STATEOF Corporate Si:al \.lew \lov'k.. AMERICAN GENERAL LIFE INSURANCE COMPANY ~ By: ~ {).b.- Title: ~ ViY\ ~GW'\ Print or Type Name t;v-f,i. leq- L.\fe. ~.ftr-e~+ Date: :!yiog I t, 20 \ 8' COUNTYOP -.:.ak~i~0~~5=-~~~ The foregoing instrument was acknowledged before me this~day of TuV"l ~Vit,i ~"00 ~t>~o~~~,-~~~~ ~,!!45~ (Name of person)...,ias 208. by E\/P.& CEO Uk,t ge-ti~ (type of authority... e.g. officer. trostee attorney in fact) for ~ \6, \ V\C. (company name) cs;,.,..,..~--- t>ov)v\ta 'IWL (Print. Type or Stamp Commissioned Name ofnotmy) Personally Known. / or Produced Identification. Type of Identification Produced. My Commission Expires._ l...:.. \.._ J '?>.;;;;..0;;;..:=2 ;;..:. 0...:. lq ;. DONNA YUE N6f Aft\' f'ublic STATE Of NEW YG>RI NO. 0YU (!\:\LlfllEO IN KINGS COUNtv t,l\l t6mm\ssion EXPIRES

10 COPIES FURNISHED TO: Kevin Hogan, CEO & President American General Life Insurance Company P.O. Box 59 Houston, TX Mallary Reznik, General Counsel American General Life Insurance Company P.O. Box 59 Houston, TX Scott Woods, Director Life & Health Market Regulation Florida Office of Insurance Regulation 200 East Gaines Street Tallahassee, FL scott. Shaw Stiller, Chief Assistant General Counsel Florida Office of Insurance Regulation 200 East Gaines Street Tallahassee, FL Telephone: (850)

11 EXHIBIT A Al A2 A3 A4 AS A6 Accident and health insurance policies: lapsed. Accident and health insurance policies: frozen. Life insurance policies: non-forfeiture extended term. Life insurance policies: frozen. Life insurance policies: non-forfeiture reduced paid up. Life insurance policies: lapsed.

12 Exhibit Al Accident and health insurance policies: lapsed. American General Life Insurance Company A member of American International Group, Inc. {AIG) P O Box Nashville, TN Month DD, YYYY FNAMELNAME ADDRESS LINE ADDRESS LINE 2 CITY, ST ZIP RE: Policy Number :XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that the above referenced Policy terminated as a result of non-payment. Upon further review, we discovered that this Company did not deliver premium notices notifying you that payment was due between { insert timeframe}. We appreciate your business and are sending this letter to confirm whether you want to continue your insurance coverage at this time. If you wish to keep your policy in full force and effect, please complete the form below and return it along with a payment of$ by (MMIDDIYYYY) using the enclosed postage paid envelope. Please note that if you choose to reinstate the policy, going forward your premium amount will be [INSERT AMOUNT], and you will be responsible for making timely payments consistent with your previously selected [INSERT SELECTED] billing schedule. If we do not receive your payment by (MMIDDIYYYY), your policy will remain terminated (lapsed) without value. Our records indicate the following policies are part of your billing group: Policy Number Tw Status Due pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium $2.36 $5.96 $0.32 $80.00 We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at (800) Additionally, if you are unable to repay the entire amount due by the date specified, please contact our Customer Service Center to discuss if any other options may be available to you. If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Services, Division of Consumer Services, Toll Free at

13 Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME MAIL CODE 004 AGL P O BOX NASHVILLE, TN Date [ ] I wish to reinstate my policy. Signature

14 Exhibit A2 Accident and health insurance policies: frozen. American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY FNAMELNAME ADDRESS LINE ADDRESS LINE 2 CITY, ST ZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that we have not received premium to maintain the above referenced Policy in force since [MM/DD!YYYY]. Upon further review, we discovered that this Company did not deliver premium notices notifying you that payment was due between { insert timeframe}. We appreciate your business and are sending this letter to confirm whether you want to continue your insurance coverage at this time. If you wish to keep your policy in full force and effect, please complete the form below and return it along with your payment using the enclosed postage paid envelope. Please note that if you choose to keep your coverage, going forward your premium amount will be $xx.xx, and you will be responsible for making timely payments consistent with your previously selected [INSERT SELECTED] billing schedule. If we do not receive your payment by (MMIDDIYYYY), your policy will terminate (lapse) without value. Our records indicate the following policies are part of your billing group: Policy Number ~ Status Due pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium $2.36 $5.96 $0.32 $80.00 We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at 800} Additionally, if you are unable to repay the entire amount due by the date specified, please contact our Customer Service Center to discuss if any other options may be available to you. If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the

15 Florida Department of Financial Services, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME MAIL CODE 004 AGL PO BOX NASHVILLE, TN Date [ ] I wish to reinstate my policy. Signature

16 American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY Exhibit A3 Life insurance policies: non-forfeiture extended term. MC006 FNAME LNAME ADDRESS LINE ADDRESS LINE 2 CITY, STZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that, as a result of non-payment, your Policy has been placed in nonforfeiture status, meaning your benefits will expire earlier than expected under the original term. Upon further review, we discovered that this Company did not deliver premium notices notifying you that payment was due between (MONTH YEAR) and (MONTH YEAR). We appreciate your business, and are sending this letter to confirm whether you want to restore your coverage to the pre non-forfeiture term at this time. If you wish to reinstate your policy, please complete the form below and return it along with your payment using the enclosed postage paid envelope. We have included a set of payment options you may choose from. For example, if you choose to pay by (MM/DD/YYYY), remit the amount indicated below by this date. This amount reflects the total premium that has not been paid on the policy since [MM/DD/YYYY]. Please note that if you choose to reinstate the policy to pre non-forfeiture term, you will be responsible for making timely payments consistent with your previously selected (Insert Selected) billing schedule. Reinstatement requests received after (MM/DD/YYYY) may require you to provide evidence of insurability. Our records indicate the following policies are part of yqur billing group: Policy Number ~ Status pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium Due $2.36 $5.96 $0.32 $80.00 Note that your Policy benefit(s) will remain at the pre non-forfeiture term and amount until ' [MM/DD/YYYY]. If we do not receive your payment by [MM/DD/YYYY], the coverage will continue inforce for the non-forfeiture term and amount as provided for in your Policy. Additionally, if you do not have sufficient funds to repay the entire amount by [MM/DD/YYYY], but wish to reinstate, please contact our Customer Service Center at (BOO) to discuss if any other options may be available to you. We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at (BOO}

17 If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Service, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: Payment Amount: MM/DD/VY $ x,xxx.xx MM/DD/VY $ x,xxx.xx *MM/DD/VY $ x,xxx.xx MM/DD/VY $ x,xxx.xx MM/DD/VY $ X,XXX.XX *A premium change occurred during this window MAIL CODE 004 AGL P O BOX NASHVILLE, TN [ ] I wish to reinstate my policy. Signature Date

18 Exhibit A4 Life insurance policies: frozen. American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY FNAMELNAME ADDRESS LINE ADDRESS LINE 2 CITY, ST ZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that we have not received premium to maintain the above referenced Policy in force since [MM/DDIYYYY]. Upon further review, we discovered that this Company did not deliver premium notices notifying you that payment was due between { insert timeframe}. We appreciate your business and are sending this letter to confirm whether you want to continue your insurance coverage at this time. If you wish to keep your policy in full force and effect, please complete the form below and return it along with your payment using the enclosed postage paid envelope. We have included a set of payment options you may choose from. For example, if you choose to pay by (MM/DDIYYYY), remit the amount indicated below by this date. This amount reflects the total premium that has not been paid on the policy since [MM/DDIYYYYJ. Please note that if you choose to keep your coverage, going forward your premium amount will be $xx.xx, and you will be responsible for making timely payments consistent with your previously selected [INSERT SELECTED] billing schedule. If we do not receive your payment by (MMIDDIYYYY), your policy will terminate (lapse) without value except as to any non-forfeiture options provided for by your policy (such as the right to surrender value or a paid-up policy). Our records indicate the following policies are part of your billing group: Policy Number '.IYill2 Status Due pol type - pol status pol type - pol status pol type -pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium $2.36 $5.96 $0.32 $80.00

19 We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at (800) Additionally, if you are unable to repay the entire amount due by the date specified, please contact our Customer Service Center to discuss if any other options may be available to you. If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Services, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: MM/DD NY Payment Amount: MM/DDNY MM/DDNY *MM/DDNY MM/DDNY $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX * A premium change occurred during this window MAIL CODE 004 AGL P O BOX NASHVILLE, TN Date [ ] I wish to reinstate my policy. Signature

20 American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY Exhibit AS Life insurance policies: non-forfeiture reduced paid up. FNAME LNAME ADDRESS LINE ADDRESS LINE 2 CITY, STZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that, as a result of non-payment, your Policy has lapsed and now provides reduced coverage under your non-forfeiture option. Upon further review, we discovered that the Company did not deliver premium notices notifying you that payment was due between {insert timeframe}. We appreciate your business, and are sending this letter to confirm whether you want to restore your coverage to the pre non-forfeiture value at this time. If you wish to reinstate your policy, please complete the form below and return it along with your payment using the enclosed postage paid envelope. We have included a set of payment options you may choose from. For example, if you choose to pay by (MM/DD/YYYY), remit the amount indicated below by this date. This amount reflects the total premium that has not been paid on the policy since [MM/DD/YYYY]. Please note that if you choose to reinstate the policy to pre non-forfeiture value, you will be responsible for making timely payments consistent with your previously selected (Insert Selected) billing schedule. Reinstatement requests received after (MM/DD/YYYY) may require you to provide evidence of insurability. Our records indicate the following policies are part of your billing group: Policy Number ~ Status pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium Due $2.36 $5.96 $0.32 $80.00

21 Note that your Policy benefit(s) will remain at the pre non-forfeiture term and amount until [MM/DD/YYYY]. If we do not receive your payment by [MM/DD/YYYY], the coverage will continue inforce for the non-forfeiture term and amount as provided for in your Policy. Additionally, if you do not have sufficient funds to repay the entire amount by [MM/DD/YYYY], but wish to reinstate, please contact our Customer Service Center at (800) to discuss if any other options may be available to you. We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at (800) If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Service, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: Payment Amount: MM/DD/VY $ x,xxx.xx MM/DD/YY $ x,xxx.xx *MM/DD/VY $ X,XXX.XX MM/DD/YY $ X,XXX.XX MM/DD/YY $ x,xxx.xx *A premium change occurred during this window MAIL CODE 004 AGL P O BOX NASHVILLE, TN [ ] I wish to reinstate my policy. S~n~ure Da~

22 Exhibit A6 Life insurance policies: lapsed. American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY FNAMELNAME ADDRESS LINE ADDRESS LINE 2 CITY, ST ZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Owner, It has come to our attention that the above referenced Policy terminated as a result of non-payment. Upon further review, we discovered that this Company did not deliver premium notices notifying you that payment was due between { insert timeframe}. We appreciate your business and are sending this letter to confirm whether you want to continue your insurance coverage at this time. If you wish to keep your policy in full force and effect, please complete the form below and return it along with your payment using the enclosed postage paid envelope. We have included a set of payment options you may choose from. For example, if you choose to pay by (MM/DDIYYYY), remit the amount indicated below by this date. This amount reflects the total premium that has not been paid on the policy since [MM/DDIYYYY]. Please note that if you choose to reinstate the policy, going forward your premium amount will be [INSERT AMOUNT], and you will be responsible for making timely payments consistent with your previously selected [INSERT SELECTED] billing schedule. If we do not receive your payment by (MM/DDIYYYY), your policy will remain terminated (lapsed) without value except as to any non-forfeiture options provided for by your policy (such as the right to surrender value or a paid-up policy). Our records indicate the following policies are part of your billing group: Policv Number ~ Status Due pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due 5 Total Premium $2.36 $5.96 $0.32 $80.00 We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement

23 purposes, please call our Customer Service Contact Center at (800) Additionally, if you are unable to repay the entire amount due by the date specified, please contact our Customer Service Center to discuss if any other options may be available to you. If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Services, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: MM/DD NY Payment Amount: MM/DDNY MMIDDNY *MMIDDNY MMIDDNY $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,X:XX.XX * A premium change occurred during this window MAIL CODE 004 AGL P O BOX NASHVILLE, TN Date [ ] I wish to reinstate my policy. Signature

24 EXHIBITB

25 American General Life Insurance Company A member of American International Group, Inc. (AIG) P O Box Nashville, TN Month DD, YYYY MC006 FNAMELNAME ADDRESS LINE ADDRESS LINE 2 CITY, ST ZIP RE: Policy Number XX-XXXXXXXXXX Dear XYZ Payer, It has come to our attention that premiums are paid in advance on the above referenced policy. This policy was part of a billing group, which contained two or more policies. According to our records, you are also the Payer on other policies which are not paid in advance. For the policies which are not paid in advance, you may have received lapse notices or an offer to reinstate. If the premiums paid in advance were intended for other policies paid by you and you would like to move the advance payments to those policies, please call our Customer Service Contact Center at (800) Based on Company records, the following policy(ies) are part of your billing group: Policy Number ~ Status Due pol type - pol status pol type - pol status pol type - pol status pol type - pol status Whole Life Lapsed Number of Premiums Due Paid in Advance 3 months 5 Total Premium $2.36 -$45.63 $5.96 $0.32 $80.00 Available funds from advanced paid contracts will vary based upon timing of decision by the payer and additional funds remitted on contracts within the group. For policies where payer and owner are not the same, please have the owner sign the form below so the policy may be reinstated. We regret any inconvenience this circumstance may have caused you. If you have questions regarding the status of your policy or would like to make a payment by phone for reinstatement purposes, please call our Customer Service Contact Center at <SQO} Additionally, if you are unable to repay the entire amount due by the date specified, please contact our Customer Service Center to discuss if any other options may be available to you.

26 If you feel you were unable to resolve your concerns with our Customer Service Center or have any additional questions or concerns that our staff was unable to address, you may contact the Florida Department of Financial Services, Division of Consumer Services, Toll Free at Sincerely, Customer Service Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: MM/DDNY Payment Amount: MM/DDNY MM/DDNY MM/DDNY MM/DDNY $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.:XX MAIL CODE 004 AGL PO BOX [ ] I wish to reinstate my policy. NASHVILLE, TN Date Signature Policy Number: XX-XXXXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: MM/DD NY Payment Amount: MM/DDNY MM/DDNY MM/DDNY MM/DDNY $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,X:XX.XX

27 MAIL CODE 004 AGL P O BOX NASHVILLE, TN Date [ ] I wish to reinstate my policy. Signature Policy Number: XX-XX:XXXXXXXX Insured: FNAME LNAME Owner: FNAME LNAME Payment Schedule Options Remit By Date: MM/DD NY Payment Amount: MM/DDNY MM/DDNY MMIDDNY MM/DDNY $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX $ X,XXX.XX MAIL CODE 004 AGL P O BOX [ ] I wish to reinstate my policy. NASHVILLE, TN Date Signature

28 EXHIBIT C

29 FINANCIAL SERVICES COMMISSION RICK SCOTT GOVERNOR OFFICE OF INSURANCE REGULATION JIMMY PATRONIS CHIEF FINANCIAL OFFICER DAVID ALTMAIER COMMISSIONER PAM BONDI ATIORNEY GENERAL ADAM PUTNAM COMMISSIONER OF AGRICULTURE INVOICE In order to ensure that your payment is received and properly credited, please make your check payable to the Florida Department of Financial Services and return this invoice with your payment to: Department of Financial Services Revenue Processing Section P.O. Box 600 Tallahassee, Florida INVOICE NO: REFERENCE NAME: ADDRESS: CITY, STATE, ZIP: FEID: NAIC COCODE: EXAM YR END: CASE#: ATTORNEY: SOURCE: American General Life Insurance Company 2727-A Allen Parkway, 3-Dl Houston, Texas CO Shaw Stiller Market Investigations Fine Due: Costs Due: Total Amount Due: $ 200, $ 0, $20, Amount Remitted: OFFICIAL USE ONLY - PLEASE DO NOT MARK BELOW THIS LINE Bff TIC Fff AMOUNT C 05 - MARKET CONDUCT J C 249- Attorney's fees J