Contract analysis

I. Introduction and Purpose On behalf of Quorum Indemnity Insurance Company ("QIIC"), NAIC No. 41927, EIN 06-2193847, a Connecticut-domiciled stock insurance company, we respectfully submit this formal Corrective Action Plan Compliance Progress Report (the "Progress Report") to the Florida Office of Insurance Regulation ("FL OIR" or the "Department"). QIIC is a wholly owned subsidiary of Quorum Insurance Holdings Cor

II. Administrative Fine Payment QIIC confirms that the administrative fine in the amount of One Hundred Eighty Thousand Dollars ($180,000.00) assessed by FL OIR in connection with the Examination Report has been paid in full. Pursuant to the terms of the accepted CAP, payment of the administrative fine was due on or before September 30, 2025. QIIC remitted payment in the full amount on September 26, 2025, by wire tra

III. Engagement of Outside Counsel and Consultants Recognizing the seriousness of the examination findings and the imperative need for a comprehensive and sustainable remediation program, QIIC and QIH have committed substantial resources to the engagement of experienced outside counsel and specialized consultants to guide and execute the remediation effort. Board-Level Oversight. On August 12, 2025, the Audit and Com

IV. Summary of Phase 1 Assessment Findings Phase 1 of the four-phase work plan — the Assessment and Gap Analysis — was completed on or about October 3, 2025. The Phase 1 assessment was conducted by Calderwood & Harkness in coordination with Ridgeline and encompassed a thorough and wide-ranging review of QIIC's market-conduct compliance program across all relevant dimensions. The results of the Phase 1 assessment are

V. Remediation Progress — Claims-Handling Timeliness (Findings 1–6) A. Summary of Examination Findings Findings 1 through 6 of the Examination Report identified pervasive deficiencies in QIIC's claims-handling timeliness practices. Specifically, the Department found that QIIC: (i) failed to acknowledge receipt of claims within the time frames required by applicable Florida statutes and the Florida Insurance Code (Fin

VI. Remediation Progress — Advertising and Marketing Compliance (Findings 7–11) A. Summary of Examination Findings Findings 7 through 11 of the Examination Report identified five (5) categories of advertising and marketing compliance deficiencies. The findings related to unapproved or non-filed rate comparisons in digital advertisements disseminated across Florida, California, Illinois, and Ohio. Specifically, the De

VII. Remediation Progress — Complaint-Handling Procedures (Findings 12–14) A. Summary of Examination Findings Findings 12 through 14 of the Examination Report identified three (3) categories of complaint-handling deficiencies. Specifically, the Department found that QIIC: (i) failed to log consumer complaints within the time frames required by applicable statutes and regulations in three states, including Florida (Fi

VIII. Revised Market-Conduct Compliance Manual As part of the Phase 2 remediation effort, QIIC has prepared a comprehensive revised Market-Conduct Compliance Manual (the "Manual") designed to supersede the prior compliance manual that was in effect during the Examination Period. The Manual represents a ground-up redevelopment of QIIC's market-conduct compliance framework and is intended to serve as the authoritative

IX. Training Program — Phase 3 Implementation A. Training Program Overview Phase 3 of the four-phase work plan — Training and Implementation — is scheduled for the period of November 17, 2025 through December 5, 2025. The training program has been developed by Calderwood & Harkness in coordination with QIIC's Market Conduct and Consumer Affairs department, Claims Operations leadership, and the Pinnacle Bridge complia

X. Timeline to Full Remediation and Compliance Certification QIIC reiterates its commitment to achieving full remediation and compliance certification by December 31, 2025, as required by Section IV.A of the accepted CAP. The Company believes that the remediation actions described in this Progress Report, together with the remaining work to be completed in Phases 3 and 4, will position QIIC to submit a compliance cer

XI. Other Regulatory Proceedings For the Department's awareness, and without creating any waiver of privilege, confidentiality, or other applicable protections, QIIC provides the following updates regarding other regulatory proceedings related to the subject matter of the Examination Report: California Department of Insurance (CDI). The CDI issued an Order to Show Cause on June 18, 2025, relating to advertising compl

XII. List of Exhibits The following exhibits are attached hereto by reference and are incorporated into this Progress Report: Exhibit A: Proof of Payment of $180,000 Administrative Fine (wire transfer confirmation and Department acknowledgment of receipt) Exhibit B: Revised Claims-Handling Timeliness Remediation Protocol (Draft SOP) Exhibit C: Revised Advertising Review & Filing Procedures (Draft SOP) Exhibit D: Revi

XIII. Closing Quorum Indemnity Insurance Company remains committed to achieving and maintaining full compliance with the requirements of the Florida Insurance Code, the rules and regulations of the Florida Office of Insurance Regulation, and the applicable statutes and regulations of all jurisdictions in which it is licensed to transact insurance business. QIIC values its cooperative relationship with the Department