STA1'E OF CONNECTICUT

Transcription

1 STA1'E OF CONNECTICUT INSURANCE DEPARTMENT ORDER ADOPTING REPORT OF EXAMINATION I, Katharine L. Wade, Insurance Commissioner of the State of Connecticut, having fully considered and reviewed the Examination Report (the "Report") of Cigna HealthCare of Connecticut, Inc. (the "Company") as of December 31, 2013, do hereby adopt the findings and recommendations contained therein based on the following findings and conclusions, TO WIT: 1. I, Katharine L. Wade, as the Insurance Commissioner ofthe State ofconnecticut, and as such is charged with the duty of administering and enforcing the provisions of Title 38a ofthe Connecticut Oeneral Statutes ("COS"). 2. The Company is a domestic insurer authorized to transact the business of insurance in the State of Connecticut. 3. On March 20, 2015, the verified Report of the Company was filed with the Connecticut Insurance Department ("Insurance Department"). 4. In accordance with Section 38a-14(e)(3) of the COS, the Company was afforded a period of thirty (30) days within which to submit to the Insurance Department a written submission or rebuttal with respect to any matters contained in the Report. 5. On April 27, 2015, the Company notified the Insurance Department of certain responses and comments on certain items contained in the Report. 6. Following review of the Report, it was deemed necessary and appropriate to modify the Report. A copy of the Report is attached hereto and incorporated herein as Exhibit A. P.O. Box 816 Hartford, CT An Equal Opportunity Employer

2 NOW, THEREFORE, it is ordered as follows: 1. That the Report of the Company hereby IS adopted as filed with the Insurance Department. 2. That the Company shall comply with all of the recommendations set forth in the Report, and that failure by the Company to so comply shall result in sanctions or administrative action as provided by Title 38a of the CGS. Dated at Hartford, Connecticut, this 29 th day ofapril, 2015 ~ L WoJc Katharine L. Wade Insurance Commissioner

3 STATE OF CONNECTICUT INSURANCE DEPARTMENT CERTIFIED COpy I, KATHARINE L. WADE, INSURANCE COMMISSIONER OF THE STATE OF CONNECTICUT, HAVE COMPARED THE ANNEXED COpy WITH THE ORIGINAL RECORD ON FILE WITH THE DEPARTMENT OF INSURANCE AND DO HEREBY CERTIFY THAT IT IS A WHOLE, TRUE AND CORRECT COpy OF THE ORIGINAL RECORD WITNESS MY HAND AND SEAL OF THE INSURANCE COMMISSIONER OF THE STATE OF CONNECTICUT THIS 29TH DAY OF APRIL 2015 ~~ JJ KATHARINE L. WADE INSURANCE COMMISSIONER P.O. Box 816 Hartford, CT An Equal Opportunity Employer

4 STATE OF CONNECTI CUT INSURANCE DEPARTMEN T IT IS HEREBY CERTIFIED THAT THE ANNEXED EXAMINATION REPORT OF ' CIGNA HEALTHCARE OF CONNECTICUT, INC. ASOF DECEMBER 31,2013 IS A WHOLE TRUE AND CORRECT COpy OF THE ORIGINAL DOCUMENT ON FILE WITH THE CONNECTICUT INSURANCE DEPARTMENT IN WITNESS WHEREOF, I hereunto, set my hand and affix the official seal of the Insurance Commissioner of the State of Connecticut This 29th day April, 2015 ~D E INSURANCE COMMISSIONER P.O. Box 816 Hartford, An Equal Opportunity Employer

5 Exhibit A EXAMINATION REPORT OF THE CIGNA HEALTHCARE OF CONNECTICUT, INC. AS OF DECEMBER 31, 2013 BY THE CONNECTICUT INSURANCE DEPARTMENT

6 TABLE OF CONTENTS Salutation Scope of Examination History Organizational Chart Management and Control Related Party Transactions Insurance Coverages Territory and Plan of Operation Reinsurance Information Technology Controls Accounts and Records Financial Statements Assets Liability, Capital and Surplus Statement ofrevenue and Expenses Capital and Surplus Account Claims Unpaid Unpaid Claims Adjustment Expenses Medial Loss Ratio Common Capital Stock Gross Paid-In and Contributed Surplus Unassigned Funds (Surplus) Subsequent Events 13 Conclusion Signature 13 14

7 March 20,2015 The Honorable Katharine L. Wade Insurance Commissioner State of Connecticut Insurance Department 153 Market Street, 6 th Floor Hartford, CT ( Dear Commissioner Wade: In compliance with your instructions and pursuant to the requirements of Section 38a-14 of the Connecticut General Statutes (CGS), the undersigned has conducted a financial examination of the condition and affairs of the: CIGNA HEALTHCARE OF CONNECTICUT, me. (hereinafter referred to as the Company or CHCCT), a capital stock corporation incorporated under the laws of the State of Connecticut and having its main administrative office located at 900 Cottage Grove Road, Bloomfield, CT. The report of such examination is submitted herewith.

8 CIGNA HEALTHCARE OF CONNECTICUT, mc. SCOPE OF EXAMINATION The previous examination of the Company was conducted as of December 31, The current examination, which covers the subsequent five year period through December 31, 2013, was conducted at the main administrative office of the Company. Concurrent examinations were conducted on Connecticut General Life Insurance Company (CGLIC), Cigna Health and Life Insurance Company (CHLIC), and Cigna Arbor Life Insurance Company (CALlC). The examination was conducted on a full scope, comprehensive basis, in accordance with the procedures outlined in the National Association of Insurance Commissioners (NAlC) Financial Examiners Handbook (the Handbook). The Handbook requires that we plan and perform the examination to evaluate the financial condition and identify prospective risks of the Company by obtaining information about the Company including corporate governance and inherent risks within the Company and evaluating system controls and procedures used to mitigate those risks. An examination also includes assessing the principles used and significant estimates made by management, as well as evaluating the overall fmancial statement presentation and management compliance with the Statement of Statutory Accounting Principles and the Annual Statement Instructions. All accounts and activities of the Company were considered in accordance with the risk-focused surveillance examination process. As a part of the examination planning procedures, the Financial Regulation Division of the Connecticut Insurance Department (the Department) reviewed the following documentation submitted by the Company for the period under examination: Annual Statements filed with the Department; Annual reports to shareholders; Statements of Actuarial Opinion; Documentation supporting Section 404 ofthe Sarbanes Oxley Act (SOX); Form 10-K reports filed with the Securities and Exchange Commission; and Minutes of the Board of Directors (Board), affiliate and custodial agreements and other documents related to significant transactions that require prior approval or requests for deviations from the NAlC Accounting Practices and Procedures Manual. A review of the 2009 through 2013 statutory basis audit reports prepared by PriceWaterhouseCoopers, LLC (pwc), the Company's independent certified public accountants, indicated no material concerns with respect to fmancial condition or regulatory compliance -issues. Work papers prepared by PwC, as of December 31, 2012 and 2013, in connection with their annual statutory audits were reviewed and relied upon to the extent deemed appropriate. A comprehensive review was also made of the fmancial analysis files and documents submitted to the Financial Analysis Unit of the Department, as well as Examination Jumpstart and Financial Analysis and Solvency Tracking System reports obtained from the NAlC database. Lewis and Ellis, Inc. (L&E) was engaged by the Department to assist in the review of the Company's actuarial risks as well as significant ceded reinsurance treaties. 2

9 CIGNA HEALTHCARE OF CONNECTICUT, INC. Noble Consulting, Inc. (Noble) was engaged by the Department to assist in the review of the Company 's information technology (IT) general controls to provide assurances regarding the Company's IT operating controls. Comments in this examination report are generally limited to exceptions noted or to items considered to be of a material nature. Failure of items in the report to add to totals or for totals to agree with captioned amounts is due to rounding. HISTORY The Company was incorporated on June 26, 1985, under Chapter 648a-part I of the CGS, licensed by the Insurance Commissioner of the State of Connecticut on January 27, 1986, and commenced business on May 1,1986. CHCCT was federally qualified as a Health Maintenance Organization (HMO) on December 24, On June 25, 1997, Cigna Corporation (Cigna) acquired all of Healthsource, Inc. (Healthsource) outstanding common stock. Healthsource was a New Hampshire based company that operated a large indemnity book of business and a number of HMO's licensed in various states. In connection with this acquisition, the Company assumed the role of a party to a coinsurance agreement with Provident Life and Casualty Company and Provident Life and Accident Insurance Company (collectively, Provident). The Company was also assigned contracts and assumed the business of administering self-funded employee benefit plans providing coverage for medical and dental care services from Healthsource Provident Administrators, Inc. A plan of merger between the Company and Healthsource, Inc. was filed with the Department on July 24, Effective April 1, 1999, the merger resulted in CRCCT as the surviving company. The Company is a wholly-owned subsidiary of Healthsource, which is a wholly-owned subsidiary of Cigna Health Corporation (CHC), which is an indirect, wholly-owned subsidiary of Cigna. 3

10 CIGNA HEALTHCARE OFCONNECTICUT, INC. ORG~ATIONALCHART A partial organizational chart of the insurance holding company system at the end of the examination period is as follows: Cigna Corporation (DE) ~ Cigna Holdings, Inc. I Connecticut General Corporation Cigna Cigna Arbor Connecticut General Health Life Insurance Life Insurance Corporation Company Company (CT) (CT) I Healthsource, Inc. I Cigna Healthcare of Connecticut, Inc. (CT) Cigna Health and Life Insurance Company (CT) I I MANAGEMENT AND CONTROL The Company is a member of an insurance holding company system as defined in Sections 38a to 38a-138.1b of the Connecticut Insurance Regulations and Section 38a-135 ofthe CGS. The bylaws of the Company require all meetings of the shareholders to be held at any location as the directors may determine. The annual meeting of the shareholders is held on any date and place that the directors may designate, and if so designated, notices thereof need not be given. The annual meeting of the stockholders shall include the election of directors and for the transaction of any other business that may come before the meeting. Special meetings may be called at any time by the chairman, the president or the Board upon written request of the holders of not less than ten percent of all the shares entitled to vote at the meeting. 4

11 CIGNA HEALTHCARE OF CONNECTICUT, INC. The bylaws provide that the property, business and affairs of the Company be managed by its Board. The number of directors shall be not less than one nor more than nine as the Board shall from time to time determine. Where the issued and outstanding shares are owned beneficially and of record by three or more shareholders, the number of directorship shall not be less than three. Where the issued and outstanding shares are owned by less than three shareholders, the number may not be less than the number of shareholders. A majority of the directors shall constitute a quorum at all meetings of the Board. Directors serving the Company at December 31,2013, were as follows: Name Donald M. Curry David Goldberg Peter W. McCauley, M.D Title and Principal Business Affiliation General Manager, CGLlC Accounting Director, CGLIC Medical Senior Director, CGLIC Committees Pursuant to the corporate bylaws, the Company's business operations may be monitored through advisory committees approved by the Board. As of December 31, 2013, there was no Board appointed committees. Officers At December 31, 2013, the officers of the Company were as follows : Name Donald M. Curry Scott R. Lambert David Goldberg Anna Krishtul Glenn M. Gerhard Kathleen R. McCabe Robert P. Hockmuth, M.D Aslam M. Khan, M.D., M.M. Barry R. McHale Robert D. Picinich David M. Porcello Maureen H. Ryan Tim S. Sheridan Irene Sosnowski Edward V. Stacey, If. Title President and Treasurer Secretary 5

12 CIGNA HEALTHCJ\RE OF CONNECTICUT, INC. RELATED PJ\RTY TRANSACTIONS The Company is a party to numerous related party transaction agreements. agreements are as follows: The material Inve stment Man~ement Agreements: Effective February 19,2010, the Company entered into an agreement with Cigna Investments, Inc. (Cll) to provide investment mai?-agement and advisory services. The Company, crr and other affiliates.entered into an investment pooling agreement dated October 1, 2004, and amended effective April 1, 2011, which is an investment trust arrangement that is designed to maximize earnings on funds available for short-term investment. cn was designated as the trust administrator and investment manager with JP Morgan Bank as the trustee. Cost and Tax Allocation Agreements: The Company and other affiliates entered into cost allocation agreements whereby a fair and reasonable share of corporate expenses are allocated in accordance with customary insurance accounting practices. The Company is also a party to the Amended and Restated Consolidated Federal Income Tax Sharing Agreement, originally adopted effective April 1, 1982, and amended effective January 1, 1997, between Cigna and each affiliated company included in the consolidated federal income tax return. In general, the agreement requires the federal income tax liability of each affiliate to be computed on a separate company basis and settled periodically with Cigna. Provider Network and Administrative Services Agreements: Cigna Health Management, Inc. (CHM:) formerly known as International Rehabilitation Services, Inc. (d/b/a Intracorp), provides utilization management, case management, demand management, disease management, care management, and other services. The intercompany service agreement, effective November 5, 2013, is by and between CHM, CGLIC and the Company on behalfoftheir respective healthp1an subsidiaries and affiliates. The. Company entered into a Management Services Agreement as amended effective January 1, 2012, with CHC and its affiliates to provide management services for group health benefit plans insured or administered by the Company. The Company also entered into agreements with Cigna Behavioral Health, Inc. (CBH) to receive utili zation review and other administrative services from CBH in connection with group coverage for mental health and substance abuse. CBH also develops provider networks and acts as the preferred or exclusive provider organization and administers fully insured contracts with employer groups under a third party administrative agreement. The Dental Care Agreement, effective April 30, 2003, by and between the Company, CGLIC and Cigna Dental Health, Inc. (CDH:), whereby CDH provides certain administrative services for participating dental plans. 6

13 CIGNA HEALTHCARE OF CONNECTICUT, INC. INSURANCE COVERAGES The Company and its affiliates are insured by a primary fidelity bond policy providing $20 million liability coverage. Excess fidelity bond coverage is provided by four earners for $85 million in coverage. The aggregate limit of liability provides fidelity coverage above the prescribed minimum set forth by the Handbook's schedule of suggested minimum amounts. The Company, as a named insured on a series of master policies with Cigna and its affiliates, maintains insurance coverage that includes: general liability; business automobile liability; workers' compensation; employers liability; fiduciary and pension trust liability; commercial umbrella; directors and officers liability; errors and omissions liability; computer crime; group travel; and commercial property. Premiums for insurance coverages are generally allocated to the insured subsidiaries in conjunction with the cost allocation arrangements for the companies being covered. TERRITORY AND PLAN OF OPERATION Licensing Information The Company is a federally qualified HMO corporation licensed to write managed care products and services in the state of Connecticut. Plan of Operations The Certificate of Incorporation filed in the state of Connecticut with the Secretary of State and approved by the Commissioner of the Connecticut Insurance Department, authorizes the Company to market, enroll and administer an HMO and to engage in any other lawful act or activity which corporations may be formed under the Stock Corporation Act of the state of Connecticut. The Company provides medical and dental HMO products to participating employees and dependents of employer groups and other sponsors of health benefit plans. The Company enters into contracts with primary and specialty care physicians and hospitals for the delivery of health care benefits to its members at negotiated rates of reimbursement with its providers. Marketing The Company's group sales representatives distribute managed health care products and services through a diversified distribution network of independent agents, insurance brokers and registered representatives of the Company. REINSURANCE Effective January 1, 2013, the 1994 reinsurance agreement with CGLIC was amended to change the reinsurer to CHLIC for claims incurred January 1, 2013, and after. The reinsurance.agreement provides a quota share coverage on claims $150,000 and greater, on a basis of 20% to the Company and 80% to CHLIC. 7

14 CIGNA HEALTHCARE OF CONNECTICUT, lnc. INFORMATION TECHNOLOGY CONTROLS Noble conducted a risk-focused assessment and review of the Company's IT general controls. The assessment and review was performed in accordance with the guidelines and procedures set forth in the Handbook, Exhibit C, Evaluation of Controls in Information Technology. Noble's objectives were to determine if IT resources aligned with the Company's objectives and to ensure that significant risks (strategic, operational, reporting, and compliance) arising out of its IT environment were appropriately mitigated by strategies and controls as outlined in the Handbook's Exhibit C Part Two - Evaluation Of Controls in Information Technology Work Program. The above objectives were achieved through an independent assessment of the Company's IT controls based upon a combination of inquiry, observation and examination of documentation. There were no material findings which affected the Department's overall reliance on the Company's IT controls. ACCOUNTS AND RECORDS The Company utilizes the Oracle general ledger (GL) of which access is restricted through Cigna's Role-Based Access (RBAC) process. User RBAC roles are semi-annually reviewed and approved by managers, and Oracle GL users' access reviews are conducted quarterly, whereby all Oracle users' access is reviewed and signed off by the users' managers. General ledger account balances were reconciled and traced to the amounts reported in the annual statement for 2012 and Further detailed analyses were performed on individual accounts throughout the examination. 8

15 CIGNA HEALTHCARE OF CONNECTICUT, INC. FINANCIAL STATEMENTS The following statements represent the Company's financial position, as filed by the Company as of December 31,2013. No adjustments were made to surplus as a result of the examination. ASSETS Account Description Assets Nonadmitted Assets Net Admitted Assets Bonds Cash, cash equivalents and short-term investments Investment income due and accrued Premiums and considerations: Uncollected premiums and agents' balances in the course of collection Current federal and foreign income tax recoverable Net deferred tax asset Receivable from parent, subsidiaries and affiliates $20,207,114 9,791, , , ,541 39, ,242 $5,568 $20,207,114 9,791, , , ,541 39, ,242 Total assets excluding Separate Accounts, segregated accounts and protected cell accounts 31,575,589 5,568 31,570,021 From Separate Accounts, segregated accounts and protected cell accounts 0 0 Total $31 5'L),5.82 $ llt5io,021 LIABILITIES, CAPITAL AND SURPLUS Claims unpaid Unpaid claims adjustment expenses Aggregate health policy reserves Premiums paid in advance General expenses due or accrued Ceded reinsurance premiums payable Amounts withheld or retained for the account of others Amounts due to parent, subsidiaries and affiliates Aggregate write-ins for other liabilities $429,541 7, , , ,616 66, ,555 Total liabilities 983,845 Cornmon capital stock Gross paid in and contributed surplus Unassigned funds (surplus) 1,000 34,010,000 (3,424,824) Total capital and surplus - 30,586,176 Total liabilities, capital and surplus $31,570,021 9

16 CIGNA HEAlTHCARE OF CONNECTICUT, INC. STATEMENT OF REVENUE AND EXPENSES Net premium income Total revenues $10,986,151 10,986,151 Hospital and Medical: Hospital/medical benefits 730,268 Other professional services 6,399,154 Outside referrals 38,534 Emergency room and out-of-area 37,967 Prescription drugs 150,189 Incentive pool, withhold adjustments, and bonus amounts 275 Subtotal 7,356,387 Less: Claims adjustment expenses 22,717 'General administrative expenses 1,502,324 Increase in reserves for life and accident and health contracts (434,330) Total underwriting deductions 8,447,098 Net underwriting gain or (loss) 2,539,053 Net investment income earned Net realized capital gains (losses) 613,105 9 Net investment gains (losses) 613,114 Net gain or (loss) from agents' or premium balances charged off 10,923 Net income or (loss) after capital gains tax and before all other federal income taxes 3,163,090 Federal and foreign income taxes incurred 705,823 Net income $2.457,267 CAPITAL AND SURPLUS ACCOUNT Capital and surplus prior reporting year $28,258,316 Net income 2,457,267 Change in deferred income tax (221,522) Change in nonadmitted assets 92,800 Aggregate write-ins for gains or (losses) in surplus (685) Net change in capital and surplus 2,327,860 Capital and surplus end of reporting period $30 ~86.J76 10

17 CIGNA HEALTHCARE OF CONNECTICUT, INC. CLAJl\.1S UNPAID $429,541 UNP AID CLAJl\.1S ADmSTMBNT EXPENSES $7,342 L&E conducted an assessment of the Company's reserving, pncmg and underwriting, and liquidity risks. Consistent with the risk focused surveillance approach to the examination, L&E relied upon analyses and tests documented by the Company and in the work papers of the Company's independent auditors. Reviews of the Company's primary lines of business were conducted to determine whether the Company's reserves were established in accordance with minimum standards for the valuation of liabilities specified in the Connecticut Standard Valuation Law, Actuarial Guidelines and applicable Actuarial Standards of Practice. In performing the reserve review and analysis, L&E conducted the following: Reviewed and analyzed statutory Annual Statements for 2012 and 2013, and inquired into other years covered under the examination period; Met with Company management to understand the business of the Company, its procedures governing actuarial calculations, its approach to risk management, and its likely areas of financial and business risk; Reviewed tests performed by the Company's actuaries and its independent auditors and performed independent supplemental reserve calculations; Reviewed experience study information compiled and provided by the Company in support of the major assumptions used in the asset adequacy analysis; and Reviewed and analyzed the Company's Statement of Actuarial Opinion, including the 2012 and 2013 Actuarial Memorandum and inquired into other years covered under the examination period. Assessment of Reserve Risk L&E was engaged to assist the Department in reaching a conclusion regarding the risk that actual losses or other contractual payments reflected in the corresponding reserves would be greater than the carried liabilities. For some products or exposures, this risk included a consideration that reserves plus future revenue, less expenses, would be insufficient to pay future benefits. L&E reviewed SOX controls regarding the claim liability and reserving processes. Independent testing was performed where SOX controls were not in place. Various tests were performed to verify the appropriateness of the processes and the actual calculations for the policy reserves, claim reserves and the contract claims liabilities. It was concluded that the reported reserves and liabilities were consistent with those calculated by the Company's actuaries, and the results of their analysis show that the reported liability was sufficient to cover the expected future claims. 11

18 CIGNA HEALTHCARE OF CONNECTICUT, INC. Assessment of Pricing and Underwriting Risk L&E assisted the Department in reaching a conclusion regarding the risk that pricing and/or underwriting practices are inappropriate for the risks assumed. The review noted that the Company pricing area sets medical trends encompassing both unit cost changes and utilization changes and works directly with the Underwriting Department on methodology clarifications or updates to ensure the pricing and strategies are appropriate. It was concluded that the Company's rating process and pricing methodology is reasonable and is consistent with Company procedures. Assessment ofliquidity Risk L&E assisted the Department in reaching a conclusion regarding the ability of the Company to meet contractual obligations as they become due because of an inability to liquidate assets or obtain adequate funding without incurring unacceptable losses. This may arise with the occurrence of an event such that the insurer will not have enough cash resources or liquid assets to meet its cash obligations. Based on a review of the Actuarial Memorandum, it was concluded that there were no material concerns related to liquidity risk. Medical Loss Ratio Within the "aggregate health policy reserve" liability, the Company reported $0 for its medical loss ratio (MLR) rebate liability. The Affordable Care Act (ACA) requires insurers to spend a minimum percentage of premium dollars on medical services and activities designed to improve health care quality. The Department reviewed and tested the Company's processes and controls designed to mitigate specific risks associated with the determination of its MLR rebate liability. No significant exceptions were identified. COMMON CAPITAL STOCK $1,000 Common capital stock of the Company consisted of 1,000 shares authorized, issued and outstanding with a par value of $1 per share. All shares are owned by Healthsource. GROSS PAID IN AND CONTRIBUTED SURPLUS $34,010,000 The following exhibit reflects the balance of this account during the period under review: 2012 $34,0 10, $34,010, $33,010, $ 7,010,000 The Company received a net capital contribution of $26 million from Healthsource for the year ended December 31,

19 CIGNA HEALTHCARB OF CONNECTICUT, INC. UNASSIGNED FUNDS (SURPLUS) ($3,424,824) The following exhibit reflects the balance of this account during the period under review: 2012 ($5,752,684) 2011 ($9,009,939) 2010 ($11,021,469) 2009 ($4,020,417) Decrease in mainly attributab le to net underwriting loss. The Company paid no dividends to its parent during the examination period. SUBSEQUENT EVENTS Effective January 1, 2014, the Company will be subject to an annual fee under section 9010 of the ACA. The Company's share of this annual fee will be allocated based on the ratio of the amount of their net premiums written during the preceding calendar year to the amount of health insurance for any U.S. health risk that is written during the preceding calendar year. A health insurance entity's portion of the annual fee becomes payable once the entity provides health insurance for any U.S. health risk for each calendar year beginning on or after January 1, of the year that the fee is due. Effective January 1, 2014, the Company is also subject to the risk-sharing provisions of the ACA, commonly referred to as the 3R's- risk adjustment, risk corridors and reinsurance. CONCLUSION The results of this examination disclosed that, as of December 31, 2013, the Company had admitted assets of $31,570,021, liabilities of $983,845, and surplus of $30,586,176. During the period under examination, admitted assets increased $6,298,135, liabilities decreased $10,275,205, and surplus as regards policyholders increased $16,573,

20 CIGNA HEALTHCARE OF CONNECTICUT, INC. SIGNATURE In addition to the undersigned, the following members of the Department participated in the examination: William Arfanis, CFE; Cecilia Arnold, CFE; Ronald Jankoski, CFE; Chiffon King, APE; Keith Kleindienst, APE; Kent Krajick, CFE; Daniel Levine, APE, CPA; Andrew Rarus, ASA, MAAA; Kenneth Roulier, APE, AES, CISA and; Michael Shanahan, CPA, CFE. Also participating were the consulting firms of Noble and L&E. I, Thomas H. Corrigan, CFE, solemnly swear that the foregoing report on examination is hereby represented to be a full and true statement of the condition and affairs of the subject insurer as of December 31, 2013, to the best ofmy information, knowledge and belief. * Respectfully mitted, Tholfjl. Corrigan, CFE Exarpi er-in-charge. Stat~ f Connecticut Insur ce Department State of Connecticut ss. Hartford County of Hartford Subscribed and sworn to before me, Pn + r-tc... Y:, 6!..A.-+-( f r Notary Public on this.?d.l... day of fuv...-lc 6,,2015. Notary Public My Commission Expires ~:- [9+-<" jc0. be.,- 3() l d U t & 14