Contract analysis

1. Complainant Information: Full name, mailing address, telephone number, and email address of the complainant (to the extent available).

2. Policy/Claim Identification: Policy number, claim number, or other identifying information linking the complaint to a specific insurance transaction (if applicable and available).

3. Subsidiary Identification: The subsidiary involved in the complaint (QIIC, QSU, or QLA) and whether Pinnacle Bridge MGA, LLC was the distribution channel through which the underlying policy was sold or serviced.

4. Date and Time of Receipt: The date and time at which the complaint was received, recorded in the local time zone of the receiving office.

5. Channel of Receipt: The channel through which the complaint was received (U.S. mail, email, fax, telephone, website portal, mobile application, social media, or DOI-forwarded).

6. Nature of Complaint — Category Code: The complaint must be assigned one of the following category codes: • CH — Claims Handling • BP — Billing / Premium • UW — Underwriting • CN — Cancellation / Non-Renewal • AM — Advertising / Marketing • AC — Agent Conduct • OT — Other

7. Complaint Summary: A verbatim summary of the complaint or, in the case of a written complaint, attachment of the original written complaint to the intake record. For telephonic complaints, the CSR must prepare a contemporaneous written summary of the complaint, capturing the substance of the consumer's dissatisfaction and any specific relief requested.

8. DOI Origin: An indication of whether the complaint was received directly from the consumer or forwarded by a state department of insurance. If the complaint was forwarded by a DOI, the name of the forwarding DOI and the DOI's reference or case number must be recorded.

9. Complaint Tracking Number: A unique complaint tracking number will be auto-generated by the complaint management system upon entry. This tracking number must be referenced in all subsequent correspondence and documentation related to the complaint. DOI Complaint Priority Routing. Complaints received from or forwarded by a state department of insurance must be immediately flagged as "DOI Complaint" in the complaint

1. Unique Complaint Tracking Number: Auto-generated by the system upon entry; serves as the primary identifier for all subsequent activity on the complaint.

2. Complainant Identifying Information: Full name, mailing address, telephone number, and email address of the complainant (to the extent available).

3. Policy Number: The policy number associated with the complaint, if applicable.

4. Claim Number: The claim number associated with the complaint, if applicable.

5. Product Line: The line of business associated with the complaint (e.g., personal auto, homeowners, dwelling fire, commercial general liability, professional liability, cyber liability, term life, whole life, fixed annuity, indexed annuity).

6. Subsidiary: The carrier subsidiary involved (QIIC, QSU, or QLA).

7. Pinnacle Bridge Indicator: Whether the underlying policy was distributed through the Pinnacle Bridge MGA platform (Yes/No).

8. Date and Time of Complaint Receipt: As recorded during intake.

9. Date and Time of Logging: The date and time the complaint was entered into the Complaint Log.

10. Channel of Receipt: The channel through which the complaint was received (as specified in Section 3.1).

11. Complaint Category Code: The category code assigned to the complaint (as specified in Section 3.3).

12. State of Complaint Origin: The state in which the complainant resides or in which the policy was issued, as applicable, for purposes of determining the applicable response deadline.

13. DOI Indicator: Whether the complaint was forwarded by a state department of insurance (Yes/No). If Yes, the name of the forwarding DOI and the DOI reference number.

14. Assigned Complaint Handler: The name and title of the complaint handler assigned to investigate and respond to the complaint.

15. Status: The current status of the complaint, updated as the complaint progresses through the handling process: • Open • Under Investigation • Pending Response • Closed — Resolved • Closed — Denied • Closed — Withdrawn

16. Correspondence Dates: The dates on which each item of correspondence was sent or received, including: • Date acknowledgment sent to complainant • Date acknowledgment sent to DOI (for DOI Complaints) • Date substantive response sent to complainant • Date substantive response sent to DOI (for DOI Complaints) • Dates of any follow-up communications

17. Resolution Outcome: A description of the resolution, including whether the complaint was upheld, denied, compromised, or withdrawn, and a summary of any corrective action taken.

18. Resolution Date: The date on which the complaint was closed.

19. Escalation History: A record of all escalation actions taken, including the date of escalation, the reason for escalation, the escalation level, the name of the person escalating, and the name of the person receiving the escalation.

20. Elapsed Time Metrics: The system must automatically calculate and record: • Days elapsed from receipt to acknowledgment • Days elapsed from receipt to substantive response • Days elapsed from receipt to closure 4.3 System Requirements The Complaint Log must be maintained in an electronic complaint management system with the following minimum capabilities: Audit Trail Functionality. The system must track all entri

1. Complaint Reference: A reference to the specific complaint, including the assigned complaint tracking number.

2. Receipt Confirmation: A clear statement confirming that the complaint has been received and is under review.

3. Assigned Complaint Handler: The name and direct contact information (telephone number and email address) of the complaint handler assigned to investigate and respond to the complaint. The complainant should have a single, identified point of contact for the duration of the complaint-handling process.

4. Expected Timeline: A statement of the expected timeline for a substantive response, including the applicable statutory deadline. For example: "We expect to provide you with a detailed response within [15 business days / 20 calendar days] of the date we received your complaint."

5. Right to Contact DOI: A statement informing the complainant that they may contact the relevant state department of insurance if they are unsatisfied with the complaint-handling process, along with the contact information for the applicable DOI. This information must be provided in every acknowledgment letter, regardless of the nature of the complaint. Template acknowledgment letters will be developed for each subs

1. Complaint Reference: A reference to the complaint, including the assigned complaint tracking number.

2. Complaint Summary: A summary of the complaint as understood by the subsidiary, demonstrating that the complaint was received, reviewed, and understood. This summary allows the complainant to confirm that the subsidiary correctly identified the issue and ensures that the response addresses the correct concerns.

3. Investigation Description: A description of the investigation conducted, including the documents reviewed, the policy provisions analyzed, and the factual findings made. The level of detail should be sufficient to demonstrate that the investigation was thorough and conducted in good faith.

4. Subsidiary's Position and Determination: A clear statement of the subsidiary's position on the complaint and the basis for its determination. The response must cite applicable policy provisions, statutes, regulations, or other authorities as appropriate. Vague or conclusory statements are insufficient; the response must provide a specific, reasoned explanation.

5. If the Complaint Is Upheld: A description of the corrective action taken, including any payment made, policy change implemented, or other relief provided. The complainant should be informed of the specific steps taken to address the issue.

6. If the Complaint Is Denied: A clear and specific explanation of the reasons for denial, including citation to the applicable policy provision, statute, or regulation that supports the denial. The explanation must be written in plain language accessible to a consumer.

7. Appeal and DOI Contact Information: Information regarding the complainant's right to appeal internally (if an internal appeal process is available) and the compla