[sheet: Cover & Summary]
Field | Value
Document Title | Corrective Action Plan Compliance Tracker — QIIC / FL OIR
Prepared By | Calderwood & Harkness LLP
C&H Matter Number | 1025-00002
C&H Office | 1177 Avenue of the Americas, 34th Floor, New York, NY 10036
Responsible Partner | Marcus Delgado
Lead Associate | Carlos Espinoza
Working Associate | Hannah Brinkley
Billing Partner | Catherine Bloom
Client Entity (Holding Co.) | Quorum Insurance Holdings Corp. (Nasdaq: QIHC)
Client HQ Address | 280 Asylum Street, Suite 1400, Hartford, CT 06103
Subsidiary Subject to CAP | Quorum Indemnity Insurance Company
NAIC Number | 41927
EIN | 06-2193847
Domicile | Connecticut Department of Insurance
Registered Address | 280 Asylum Street, Suite 1400, Hartford, CT 06103
Licensed States (QIIC) | 28
2024 DWP | $2,140,000,000
Examining Regulator (Lead) | Florida Office of Insurance Regulation (FL OIR)
Domestic Regulator | Connecticut Department of Insurance (CTDOI)
Examination Period | January 1, 2021 – December 31, 2023
Examination Initiated By | CTDOI (coordinated multi-state exam under NAIC Market Regulation protocols)
Date Examination Initiated | September 2023
Final Examination Report Date | May 12, 2025
Total Formal Findings | 14
CAP Submitted to FL OIR | July 1, 2025
CAP Accepted (with Modifications) | July 28, 2025
CAP Remediation & Certification Deadline | December 31, 2025
Internal Audit Report Reference | IA-2025-017 (issued August 4, 2025)
Internal Audit Rating | Needs Significant Improvement (2nd lowest on 5-tier scale)
Internal Audit Control Deficiencies Identified | 23
Board Action Date | August 12, 2025 — Audit & Compliance Committee (Chair: Margaret Aldworth) directed retention of new counsel
C&H Engagement Opened | August 19, 2025
Prior Regulatory Counsel | Hargrove & Sattler LLP (Mitchell Ostrander, Lead Partner) — engagement concluded June 2025
Florida Local Counsel | Cartwright & Eddings, P.A. (Rosa Delacroix) — 301 East Pine Street, Suite 750, Orlando, FL 32801
Third-Party Consultant | Ridgeline Consulting Group, LLC (Sandra Whitfield, Managing Director) — claims sampling & benchmarking
External / Statutory Auditor | Voss Kendrick & Associates, CPA, PLLC (Frank Castellano, Engagement Partner)
--- PENALTY STATUS ---
CTDOI Civil Penalty | $275,000
CTDOI Penalty Status | PAID — July 15, 2025
FL OIR Administrative Fine | $180,000
FL OIR Fine Status | DUE — September 30, 2025
Total Penalties (Paid + Assessed) | $455,000
--- ENGAGEMENT FINANCIAL SUMMARY ---
C&H Phase 1 (Assessment) — Hourly w/ Soft Cap | $185,000
C&H Phases 2–4 (Remediation, Drafting, Training, Exam Prep) — Fixed Fee | $410,000
C&H Total Engagement Budget | $595,000
Ridgeline Consulting Fees | $340,000
Internal FTE Reallocation Costs | $485,000
Technology / Systems Upgrades | $680,000
Total Estimated Remediation Cost | $2,100,000
--- OVERALL CAP PROGRESS ---
Total CAP Milestones | 42
Milestones Completed | 0
Milestones In Progress | 7
Milestones Not Started | 35
Milestones Overdue | 0
Overall Completion % | 0.0%
Days Remaining to Deadline | 128
--- KEY CLIENT CONTACTS ---
General Counsel & CCO | Derek Mallory — Quorum Insurance Holdings Corp.
VP, Regulatory Affairs | Priya Venkatesh — Quorum Insurance Holdings Corp.
SVP, Claims Operations | Thomas Raeburn — Quorum Insurance Holdings Corp.
Director, Market Conduct & Consumer Affairs | Lena Fujimoto — Quorum Insurance Holdings Corp.
CEO | Vivian Trask — Quorum Insurance Holdings Corp.
Director of Internal Audit | Neil Granger — Quorum Insurance Holdings Corp.
[sheet: CAP Milestone Tracker]
Milestone ID | Exam Finding Ref | Finding Category | Finding Summary | Specific Corrective Measure | Responsible Quorum Personnel | Responsible Dept / Function | Status | Target Completion Date | Actual Completion Date | Supporting Documentation | Documentation Received? | C&H Verification Notes | C&H Reviewer | Linked IA-2025-017 Deficiency | Priority | Regulatory Cross-Reference
CAP-01 | Finding 1 | Claims-Handling Timeliness | Failure to acknowledge personal auto claims within 10 business days as required by FL statute; QIIC average acknowledgment time was 18.7 business days across examination period (Jan 2021 – Dec 2023) | Implement system-level auto-acknowledgment workflow in claims management platform; configure 10-business-day hard deadline with escalation alerts at Day 5 and Day 8 | Thomas Raeburn | Claims Operations | In Progress | 2025-10-31 | System configuration documentation; sample auto-acknowledgment letters; IT change-management log | No | Awaiting IT deployment confirmation; Ridgeline Consulting to validate sample file testing | Carlos Espinoza | IA-2025-017, Deficiency #3 | High | CT, NY (Reg 64), CA, IL, OH — all require ≤15 business days; FL, NY require ≤10
CAP-02 | Finding 1 | Claims-Handling Timeliness | Failure to acknowledge personal auto claims within 10 business days as required by FL statute; QIIC average acknowledgment time was 18.7 business days across examination period (Jan 2021 – Dec 2023) | Retrain all claims adjusters (~420 FTEs) on revised acknowledgment timeline and escalation protocol | Thomas Raeburn | Claims Operations | Not Started | 2025-12-05 | Training attendance records; completion certifications; knowledge-check assessment results | No | Training materials under development in Phase 3 (Nov 17 – Dec 5, 2025); coordinate with Lena Fujimoto on scheduling | Hannah Brinkley | IA-2025-017, Deficiency #4 | High | Applicable to all 28 QIIC licensed states
CAP-03 | Finding 1 | Claims-Handling Timeliness | Failure to acknowledge personal auto claims within 10 business days; related prompt-pay monitoring gaps | Develop post-implementation monitoring report to verify acknowledgment times are within 10-business-day threshold for 3 consecutive months | Thomas Raeburn | Claims Operations | Not Started | 2025-12-31 | Monthly acknowledgment time reports; trend analysis; management sign-off | No | Report template to be developed in Phase 2; Ridgeline to assist with benchmarking methodology | Carlos Espinoza | IA-2025-017, Deficiency #3 | High | FL, NY, CT
CAP-04 | Finding 2 | Claims-Handling Timeliness | Failure to pay or deny claims within prompt-pay statutory windows; QIIC timely payment rate was 74.2% vs. 95% internal target | Revise prompt-pay compliance monitoring dashboard; implement daily exception reporting for claims approaching statutory deadlines | Thomas Raeburn | Claims Operations | In Progress | 2025-11-14 | Dashboard screenshots; exception report samples; revised Claims-Handling Timeliness SOP | Partial | Draft SOP under C&H review; dashboard specifications received from QIH IT on 9/22/2025 | Carlos Espinoza | IA-2025-017, Deficiency #5 | High | NYDFS Regulation 64; FL prompt-pay statutes
CAP-05 | Finding 2 | Claims-Handling Timeliness | Failure to pay or deny claims within prompt-pay statutory windows; QIIC timely payment rate was 74.2% vs. 95% internal target | Establish supervisory review trigger for all claims open > 20 days without payment or denial determination | Thomas Raeburn | Claims Operations | Not Started | 2025-11-14 | Supervisory review protocol; workflow configuration documentation | No | To be incorporated into revised Claims-Handling Timeliness Remediation Protocol SOP | Hannah Brinkley | IA-2025-017, Deficiency #6 | High
CAP-06 | Finding 2 | Claims-Handling Timeliness | Failure to pay or deny claims within prompt-pay statutory windows; QIIC timely payment rate was 74.2% vs. 95% internal target | Implement weekly prompt-pay compliance scorecard with branch-level reporting and management accountability | Thomas Raeburn | Claims Operations | Not Started | 2025-11-30 | Scorecard template; sample weekly reports; management distribution list | No | Scorecard to track payment timeliness by state, line of business, and branch | Carlos Espinoza | IA-2025-017, Deficiency #5 | Medium | All 28 QIIC licensed states
CAP-07 | Finding 3 | Claims-Handling Timeliness | Failure to provide timely claim denial explanations with statutory citations | Draft standardized denial letter templates with state-specific statutory references for all 28 QIIC licensed states | Thomas Raeburn | Claims Operations | In Progress | 2025-11-14 | Denial letter templates (by state); legal review sign-off | Partial | Templates for FL, CT, NY, CA drafted; remaining 24 states in progress | Hannah Brinkley | IA-2025-017, Deficiency #7 | Medium | All 28 QIIC licensed states
CAP-08 | Finding 3 | Claims-Handling Timeliness | Failure to provide timely claim denial explanations with statutory citations | Configure claims management system to auto-populate denial letter templates with applicable statutory citations based on state of loss | Thomas Raeburn | Claims Operations / IT | Not Started | 2025-11-30 | System configuration documentation; test output samples; IT change log | No | Dependent on completion of denial letter templates (CAP-07); IT resource allocation pending | Carlos Espinoza | IA-2025-017, Deficiency #7 | Medium | All 28 QIIC licensed states
CAP-09 | Finding 3 | Claims-Handling Timeliness | Failure to provide timely claim denial explanations with statutory citations | Conduct QA review of denial letters issued post-remediation to verify compliance with template and statutory citation requirements (minimum 5% sample) | Thomas Raeburn | Claims Operations | Not Started | 2025-12-15 | QA review results; sample reviewed denial letters; deficiency log | No | Post-implementation validation; coordinate with Ridgeline Consulting | Hannah Brinkley | IA-2025-017, Deficiency #8 | Medium
CAP-10 | Finding 4 | Claims-Handling Timeliness | Inadequate documentation of claims investigation activities in claims files | Implement mandatory claims-file documentation checklist and quality-assurance review for random sample of closed files (minimum 5% monthly) | Thomas Raeburn | Claims Operations | Not Started | 2025-11-30 | QA review protocol; sample completed checklists; monthly QA reports | No | Ridgeline Consulting (Sandra Whitfield) to assist with statistical sampling methodology; examiner sample was 625 of 12,400 files (5.04% rate) with 11.8% error rate (74 deficient files) | Carlos Espinoza | IA-2025-017, Deficiency #9 | High
CAP-11 | Finding 4 | Claims-Handling Timeliness | Inadequate documentation of claims investigation activities in claims files | Revise claims investigation documentation standards and issue updated Claims Investigation Procedures SOP | Thomas Raeburn | Claims Operations | Not Started | 2025-11-14 | Revised Claims Investigation Procedures SOP; management approval record | No | SOP to address all documentation gaps identified in examination; C&H to review draft | Hannah Brinkley | IA-2025-017, Deficiency #10 | High
CAP-12 | Finding 5 | Claims-Handling Timeliness | Failure to properly apply policy deductibles and coverage limits in claims adjudication | Implement automated deductible and coverage-limit validation rules in claims management system | Thomas Raeburn | Claims Operations / IT | Not Started | 2025-11-30 | System validation rule documentation; test results; IT change log | No | IT development to begin in Phase 2; actuarial review of validation logic required | Carlos Espinoza | IA-2025-017, Deficiency #11 | High
CAP-13 | Finding 5 | Claims-Handling Timeliness | Failure to properly apply policy deductibles and coverage limits in claims adjudication | Conduct targeted training for claims adjusters on deductible application and coverage-limit calculations | Thomas Raeburn | Claims Operations | Not Started | 2025-12-05 | Training materials; attendance records; knowledge-check results | No | Phase 3 deliverable; to be included in 420-FTE claims adjuster training program | Hannah Brinkley | IA-2025-017, Deficiency #11 | Medium
CAP-14 | Finding 6 | Claims-Handling Timeliness | Insufficient supervisory oversight of claims handling; lack of documented supervisory reviews in claims files | Establish formal supervisory review protocol requiring documented review of 10% of each adjuster's closed files monthly | Thomas Raeburn | Claims Operations | Not Started | 2025-11-14 | Supervisory review protocol; sample review forms; monthly review summary reports | No | Protocol to be incorporated into revised Claims-Handling Timeliness Remediation Protocol SOP | Carlos Espinoza | IA-2025-017, Deficiency #10 | High
CAP-15 | Finding 7 | Advertising & Marketing | 43 unique non-filed/unapproved digital ad creatives identified across Severin Industries, Meta, and programmatic display channels in FL, CA, IL, OH; 31 of 43 (72.1%) placed by Pinnacle Bridge MGA without routing through QIIC advertising compliance review; non-compliant period: March 2022 – November 2024 (~32 months) | Establish centralized advertising review and filing workflow requiring all Pinnacle Bridge MGA marketing materials to be submitted to QIIC compliance function (Lena Fujimoto) prior to publication | Priya Venkatesh | Regulatory Affairs / Advertising Compliance | In Progress | 2025-11-14 | Draft Advertising Review & Filing SOP; Pinnacle Bridge workflow addendum; compliance review submission logs | Partial | Draft SOP under C&H review (Phase 2 deliverable); Pinnacle Bridge workflow gap was primary root cause of advertising findings | Carlos Espinoza | IA-2025-017, Deficiency #12 | High | FL (prior approval), CA (file and use), IL, OH
CAP-16 | Finding 7 | Advertising & Marketing | 43 unique non-filed/unapproved digital ad creatives identified across Severin Industries, Meta, and programmatic display channels in FL, CA, IL, OH; 31 of 43 (72.1%) placed by Pinnacle Bridge MGA without routing through QIIC advertising compliance review | Remove or revise all 43 non-compliant ad creatives from active digital channels; file revised versions with applicable state DOIs where required | Priya Venkatesh | Regulatory Affairs / Advertising Compliance | In Progress | 2025-10-15 | Ad takedown confirmations from Severin Industries, Meta, programmatic platforms; revised ad filing receipts from FL OIR, CDI, IL DOI, OH DOI | Partial | 38 of 43 ads confirmed removed as of last update; 5 programmatic display ads pending platform confirmation; CDI Order to Show Cause hearing re: CA advertising violations scheduled October 14, 2025 | Hannah Brinkley | IA-2025-017, Deficiency #13 | High | CDI hearing October 14, 2025 — coordinate with Derek Mallory on strategy
CAP-17 | Finding 7 | Advertising & Marketing | 43 unique non-filed/unapproved digital ad creatives; Pinnacle Bridge MGA oversight gap | Amend Managing General Agent Agreement with Pinnacle Bridge MGA to include mandatory advertising pre-approval clause and compliance audit rights | Derek Mallory | Legal | In Progress | 2025-10-31 | Amended MGA Agreement; redline showing new advertising compliance provisions; executed amendment | Partial | Draft amendment under C&H review; Pinnacle Bridge general counsel (Richard Alvarez) engaged in negotiations | Carlos Espinoza | IA-2025-017, Deficiency #14 | High | Applicable across all Pinnacle Bridge operating states
CAP-18 | Finding 8 | Advertising & Marketing | Failure to include required disclaimers and disclosures in digital advertising materials | Develop standardized disclaimer and disclosure library for digital advertising by state and product line | Priya Venkatesh | Regulatory Affairs / Advertising Compliance | Not Started | 2025-11-14 | Disclaimer/disclosure library document; legal review sign-off by state | No | Library to cover FL, CA, IL, OH at minimum; expand to all 28 states as best practice | Hannah Brinkley | IA-2025-017, Deficiency #14 | Medium | FL, CA, IL, OH
CAP-19 | Finding 8 | Advertising & Marketing | Failure to include required disclaimers and disclosures in digital advertising materials | Implement automated disclaimer insertion tool for digital ad creation workflow | Priya Venkatesh | Regulatory Affairs / IT | Not Started | 2025-11-30 | Tool specifications; test output samples; IT deployment log | No | IT development dependent on completion of disclaimer library (CAP-18) | Carlos Espinoza | IA-2025-017, Deficiency #14 | Medium
CAP-20 | Finding 9 | Advertising & Marketing | Use of unapproved rate comparisons in digital advertising without actuarial substantiation | Implement rate-comparison advertising review checklist requiring actuarial sign-off prior to publication | Priya Venkatesh | Regulatory Affairs / Advertising Compliance | Not Started | 2025-11-14 | Rate-comparison review checklist; actuarial certification template | No | Coordinate with QIH actuarial department; checklist to be included in revised Advertising Review & Filing SOP | Hannah Brinkley | IA-2025-017, Deficiency #15 | Medium | CA, FL, IL, OH
CAP-21 | Finding 9 | Advertising & Marketing | Use of unapproved rate comparisons in digital advertising without actuarial substantiation | Conduct retrospective review of all active rate-comparison advertisements and obtain actuarial certification or remove from circulation | Priya Venkatesh | Regulatory Affairs / Actuarial | Not Started | 2025-10-31 | Inventory of rate-comparison ads; actuarial review memoranda; removal confirmations for non-substantiated ads | No | Coordinate with chief actuary; identify all active rate-comparison ads across digital channels | Carlos Espinoza | IA-2025-017, Deficiency #15 | High | FL, CA, IL, OH
CAP-22 | Finding 10 | Advertising & Marketing | Pinnacle Bridge MGA marketing team training deficiency — no formal advertising compliance training program existed | Develop and deliver advertising compliance training module for ~85 marketing personnel (including Pinnacle Bridge MGA staff) | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-12-05 | Training materials; attendance logs; knowledge-check results; certification sign-offs | No | Phase 3 deliverable (Nov 17 – Dec 5, 2025); part of 815-FTE training program | Hannah Brinkley | IA-2025-017, Deficiency #16 | High
CAP-23 | Finding 10 | Advertising & Marketing | Pinnacle Bridge MGA marketing team training deficiency | Establish annual advertising compliance certification requirement for all marketing personnel | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-12-15 | Annual certification policy; certification tracking log template | No | Policy to require annual recertification; first cycle to coincide with Phase 3 training | Hannah Brinkley | IA-2025-017, Deficiency #16 | Medium
CAP-24 | Finding 11 | Advertising & Marketing | Inadequate recordkeeping of advertising materials filed with state DOIs; inability to produce filing history upon examiner request | Implement centralized advertising filing and recordkeeping database with state-by-state filing status tracking | Priya Venkatesh | Regulatory Affairs / IT | Not Started | 2025-11-30 | Database specifications; sample filing records; user guide | No | IT to develop or procure advertising filing tracking system; evaluate vendor solutions | Carlos Espinoza | IA-2025-017, Deficiency #17 | Medium | All 28 QIIC licensed states
CAP-25 | Finding 11 | Advertising & Marketing | Inadequate recordkeeping of advertising materials filed with state DOIs | Conduct retrospective inventory of all advertising materials filed (or required to be filed) during examination period and reconcile with state DOI records | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-11-14 | Advertising filing inventory; reconciliation report; gap analysis | No | Coordinate with Lena Fujimoto for historical filing records | Hannah Brinkley | IA-2025-017, Deficiency #17 | Medium | FL, CA, IL, OH
CAP-26 | Finding 11 | Advertising & Marketing | Inadequate recordkeeping of advertising materials filed with state DOIs | Develop advertising record retention policy in compliance with state-specific retention requirements (minimum 5 years) | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-11-14 | Advertising Record Retention Policy; legal review sign-off | No | C&H to draft policy for client review; align with existing enterprise record retention schedule | Hannah Brinkley | IA-2025-017, Deficiency #17 | Low
CAP-27 | Finding 12 | Complaint-Handling | Failure to log consumer complaints within statutory deadlines in 3 states; QIIC complaint ratio of 1.47 per 1,000 policies (79.3% above NAIC median of 0.82); 2,847 total complaints across all subsidiaries in 2024 | Implement centralized complaint logging system with 24-hour intake logging requirement and 3-business-day acknowledgment standard | Lena Fujimoto | Market Conduct & Consumer Affairs | In Progress | 2025-11-14 | Complaint logging system specifications; revised Consumer Complaint Response Procedures SOP; sample complaint log reports | Partial | Draft Complaint Response Procedures SOP under C&H review; system configuration in progress | Carlos Espinoza | IA-2025-017, Deficiency #18 | High | Applicable across all 28 QIIC licensed states; QSU ratio 0.93, QLA ratio 1.12 also above NAIC median
CAP-28 | Finding 12 | Complaint-Handling | Failure to log consumer complaints within statutory deadlines in 3 states; QIIC complaint ratio 1.47 per 1,000 policies | Develop complaint trending and root-cause analysis reporting to identify systemic issues driving elevated complaint ratio | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-30 | Root-cause analysis report template; sample trending reports; quarterly management presentation | No | Target: reduce QIIC complaint ratio to below 1.0 per 1,000 policies within 12 months | Carlos Espinoza | IA-2025-017, Deficiency #18 | Medium
CAP-29 | Finding 12 | Complaint-Handling | Failure to log consumer complaints within statutory deadlines in 3 states | Implement complaint intake quality assurance process with daily supervisory review of all new complaint entries | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-14 | QA process documentation; sample daily review logs | No | Daily review to verify completeness and timeliness of complaint logging | Hannah Brinkley | IA-2025-017, Deficiency #18 | Medium
CAP-30 | Finding 13 | Complaint-Handling | Failure to respond to consumer complaints within statutory deadlines in 3 states | Establish complaint-response escalation protocol with supervisory alerts at 50% and 75% of applicable state deadline | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-14 | Escalation protocol documentation; system alert configuration records | No | To be incorporated into revised Consumer Complaint Response Procedures SOP | Hannah Brinkley | IA-2025-017, Deficiency #19 | Medium
CAP-31 | Finding 13 | Complaint-Handling | Failure to respond to consumer complaints within statutory deadlines in 3 states | Configure complaint management system to generate automated status reports showing complaints approaching response deadlines | Lena Fujimoto | Market Conduct & Consumer Affairs / IT | Not Started | 2025-11-30 | System configuration documentation; sample automated reports; IT change log | No | IT development to begin in Phase 2; coordinate with complaint logging system implementation (CAP-27) | Carlos Espinoza | IA-2025-017, Deficiency #19 | Medium
CAP-32 | Finding 13 | Complaint-Handling | Failure to respond to consumer complaints within statutory deadlines in 3 states | Develop state-specific complaint response timeline reference guide for CSR and complaint-handling staff | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-14 | State-specific timeline reference guide; legal review sign-off | No | Guide to cover all 28 QIIC licensed states with statutory response deadlines | Hannah Brinkley | IA-2025-017, Deficiency #20 | Medium | All 28 QIIC licensed states
CAP-33 | Finding 14 | Complaint-Handling | Inadequate complaint-response record retention and DOI reporting; failure to maintain complete complaint files and submit required reports to state DOIs | Revise complaint record retention policy to comply with all applicable state retention requirements (minimum 5 years) | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-14 | Revised Complaint Record Retention Policy; legal review sign-off | No | Align with enterprise record retention schedule and advertising record retention policy (CAP-26) | Hannah Brinkley | IA-2025-017, Deficiency #21 | Medium
CAP-34 | Finding 14 | Complaint-Handling | Inadequate complaint-response record retention and DOI reporting | Implement automated DOI complaint reporting module to generate and submit required reports to state regulators on applicable schedules | Lena Fujimoto | Market Conduct & Consumer Affairs / IT | Not Started | 2025-11-30 | DOI reporting module specifications; sample generated reports; state filing confirmations | No | IT development in Phase 2; coordinate with complaint logging system (CAP-27) | Carlos Espinoza | IA-2025-017, Deficiency #22 | High | FL, CT, NY — all require periodic complaint reporting
CAP-35 | Finding 14 | Complaint-Handling | Inadequate complaint-response record retention and DOI reporting | Train ~310 customer service representatives on revised complaint intake, logging, and response procedures | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-12-05 | Training attendance records; certification sign-offs; knowledge-check results | No | Phase 3 deliverable (Nov 17 – Dec 5, 2025); part of 815-FTE training program | Carlos Espinoza | IA-2025-017, Deficiency #21 | High
CAP-36 | Finding 14 | Complaint-Handling | Inadequate complaint-response record retention and DOI reporting | Conduct retrospective reconciliation of DOI complaint reports submitted during examination period (2021–2023) to identify and cure any reporting gaps | Lena Fujimoto | Market Conduct & Consumer Affairs | Not Started | 2025-11-14 | Reconciliation report; gap analysis; supplemental filings to state DOIs | No | Coordinate with Priya Venkatesh on supplemental filing procedures | Hannah Brinkley | IA-2025-017, Deficiency #22 | Medium | FL, CT, NY
CAP-37 | All Findings | Cross-Cutting | Enterprise-wide compliance monitoring and reporting framework | Develop and implement quarterly compliance monitoring report to Board Audit & Compliance Committee covering all CAP remediation areas | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-11-30 | Quarterly compliance monitoring report template; first report draft | No | Report to cover claims timeliness metrics, advertising compliance status, and complaint-handling KPIs | Carlos Espinoza | Medium
CAP-38 | All Findings | Cross-Cutting | Enterprise-wide policy and procedure updates | Compile and finalize all revised SOPs into comprehensive Compliance Policy Manual; obtain management sign-off | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-12-15 | Comprehensive Compliance Policy Manual; management sign-off records | No | Manual to consolidate all revised SOPs from Claims, Advertising, and Complaint-Handling workstreams | Hannah Brinkley | Medium
CAP-39 | All Findings | Cross-Cutting | Internal audit validation | Coordinate with Internal Audit (Neil Granger) to conduct targeted follow-up audit of all CAP remediation measures; target report issuance before compliance certification | Priya Venkatesh | Regulatory Affairs / Internal Audit | Not Started | 2025-12-20 | Follow-up internal audit report; remediation validation results | No | Follow-up audit to verify closure of all 23 IA-2025-017 deficiencies related to CAP findings | Carlos Espinoza | All 23 deficiencies | High
CAP-40 | All Findings | Cross-Cutting | Full remediation compliance certification to FL OIR | Prepare and submit compliance certification letter to FL OIR confirming full remediation of all 14 findings; attach supporting documentation package | Priya Venkatesh | Regulatory Affairs | Not Started | 2025-12-31 | Draft compliance certification letter (C&H to prepare); supporting documentation binder; C&H verification memorandum | No | Target: submit by December 31, 2025 (CAP deadline); C&H to draft letter for Priya Venkatesh signature on behalf of QIIC (NAIC No. 41927) | Marcus Delgado | High | Coordinate with Cartwright & Eddings, P.A. (Rosa Delacroix) for FL-specific procedural requirements
CAP-41 | N/A — Penalty | Administrative | FL OIR administrative fine of $180,000 | Remit $180,000 payment to FL OIR | Derek Mallory | Legal / Finance | Not Started | 2025-09-30 | Wire transfer confirmation; FL OIR receipt / acknowledgment | No | Payment due September 30, 2025; CTDOI civil penalty of $275,000 already paid July 15, 2025; total penalties = $455,000 | Carlos Espinoza | High
CAP-42 | N/A — Exam Prep | Examination Preparation | Anticipated FL OIR follow-up examination in Q4 2025 / Q1 2026 | Conduct mock-examination exercise and prepare regulatory correspondence; organize documentation for examiner review | Priya Venkatesh | Regulatory Affairs | Not Started | 2026-01-30 | Mock-exam results; examiner document request list; organized document repository | No | Phase 4 deliverable (Dec 8, 2025 – Jan 30, 2026); also preparing for anticipated CDI exam (Q1 2026) and NYDFS exam (Q1 2026) | Carlos Espinoza | Medium | CDI, NYDFS also anticipated
[sheet: Finding Summary]
Finding Number | Finding Category | Finding Description | Severity | States Affected | Related CAP Milestone IDs | Related IA-2025-017 Deficiency Numbers | Key Metric / Data Point | Remediation Owner | Target Resolution Date
1 | Claims-Handling Timeliness | Untimely acknowledgment of personal auto claims; average 18.7 business days vs. 10-day statutory maximum | Critical | FL, CT, NY, CA, IL, OH | CAP-01, CAP-02, CAP-03 | Deficiency #3, #4 | 18.7 business days avg. acknowledgment (target: 10 days) | Thomas Raeburn (SVP, Claims Operations) | 2025-12-05
2 | Claims-Handling Timeliness | Failure to pay or deny claims within prompt-pay statutory windows; 74.2% timely payment rate vs. 95% target | Critical | FL, NY (Reg 64), CT | CAP-04, CAP-05, CAP-06 | Deficiency #5, #6 | 74.2% timely payment rate | Thomas Raeburn (SVP, Claims Operations) | 2025-11-30
3 | Claims-Handling Timeliness | Failure to provide timely claim denial explanations with statutory citations in denial letters | Major | FL, CT, NY, CA, IL, OH (all 28 licensed states) | CAP-07, CAP-08, CAP-09 | Deficiency #7, #8 | Denial letters missing statutory citations in 62% of sampled denials | Thomas Raeburn (SVP, Claims Operations) | 2025-12-15
4 | Claims-Handling Timeliness | Inadequate documentation of claims investigation activities in claims files; 11.8% error rate in examiner sample | Critical | FL, CT, NY, CA | CAP-10, CAP-11 | Deficiency #9, #10 | 74 deficient files out of 625 sampled (11.8% error rate) | Thomas Raeburn (SVP, Claims Operations) | 2025-11-30
5 | Claims-Handling Timeliness | Failure to properly apply policy deductibles and coverage limits in claims adjudication | Major | FL, CT, NY | CAP-12, CAP-13 | Deficiency #11 | Deductible/coverage-limit errors identified in 8.3% of sampled files | Thomas Raeburn (SVP, Claims Operations) | 2025-12-05
6 | Claims-Handling Timeliness | Insufficient supervisory oversight of claims handling; lack of documented supervisory reviews in claims files | Major | FL, CT, NY, CA | CAP-14 | Deficiency #10 | Supervisory review documentation absent in 41% of sampled files | Thomas Raeburn (SVP, Claims Operations) | 2025-11-14
7 | Advertising & Marketing | 43 non-filed/unapproved digital ad creatives across Severin Industries, Meta, and programmatic display; 31 of 43 (72.1%) placed by Pinnacle Bridge MGA without compliance review; period: March 2022 – November 2024 | Critical | FL, CA, IL, OH | CAP-15, CAP-16, CAP-17 | Deficiency #12, #13, #14 | 43 non-compliant ads; 31 by Pinnacle Bridge (72.1%); 32-month duration | Priya Venkatesh (VP, Regulatory Affairs) | 2025-11-14
8 | Advertising & Marketing | Failure to include required disclaimers and disclosures in digital advertising materials across multiple states | Major | FL, CA, IL, OH | CAP-18, CAP-19 | Deficiency #14 | Disclaimer/disclosure deficiencies in 28 of 43 identified ad creatives (65.1%) | Priya Venkatesh (VP, Regulatory Affairs) | 2025-11-30
9 | Advertising & Marketing | Use of unapproved rate comparisons in digital advertising without actuarial substantiation | Major | FL, CA, IL, OH | CAP-20, CAP-21 | Deficiency #15 | 7 rate-comparison ads published without actuarial support | Priya Venkatesh (VP, Regulatory Affairs) | 2025-11-14
10 | Advertising & Marketing | No formal advertising compliance training program for marketing personnel including Pinnacle Bridge MGA staff; ~85 marketing FTEs untrained | Major | All QIIC licensed states | CAP-22, CAP-23 | Deficiency #16 | 0 of 85 marketing personnel had completed advertising compliance training | Lena Fujimoto (Director, Market Conduct) | 2025-12-15
11 | Advertising & Marketing | Inadequate recordkeeping of advertising materials filed with state DOIs; inability to produce complete filing history upon examiner request | Minor | FL, CA, IL, OH | CAP-24, CAP-25, CAP-26 | Deficiency #17 | Filing records incomplete for 67% of advertising materials reviewed by examiners | Priya Venkatesh (VP, Regulatory Affairs) | 2025-11-30
12 | Complaint-Handling | Failure to log consumer complaints within statutory deadlines in 3 states; QIIC complaint ratio 1.47/1,000 policies (79.3% above NAIC median of 0.82) | Major | FL, CT, NY | CAP-27, CAP-28, CAP-29 | Deficiency #18 | 1.47 complaints per 1,000 policies; 2,847 total complaints (all subsidiaries, 2024) | Lena Fujimoto (Director, Market Conduct) | 2025-11-30
13 | Complaint-Handling | Failure to respond to consumer complaints within statutory deadlines in 3 states; untimely responses in 23.4% of sampled complaints | Major | FL, CT, NY | CAP-30, CAP-31, CAP-32 | Deficiency #19, #20 | 23.4% untimely response rate in examiner sample | Lena Fujimoto (Director, Market Conduct) | 2025-11-30
14 | Complaint-Handling | Inadequate complaint-response record retention and DOI reporting; incomplete complaint files and missed periodic reporting submissions | Major | FL, CT, NY | CAP-33, CAP-34, CAP-35, CAP-36 | Deficiency #21, #22 | DOI complaint reports missing or late for 3 of 6 reporting periods reviewed | Lena Fujimoto (Director, Market Conduct) | 2025-12-05
[sheet: Examination Data Reference]
Data Element | Value | Source / Notes
Examination Period | January 1, 2021 – December 31, 2023 | FL OIR exam report dated May 12, 2025
Lead Examining State | Florida Office of Insurance Regulation (FL OIR) | Coordinated multi-state exam initiated by CTDOI, September 2023
Participating States | CT (domestic), FL (lead), NY, CA, IL, OH | Under NAIC Market Regulation protocols
Total Claims Files in Exam Universe | 12,400 | QIIC only; personal auto and homeowners lines
Examiner Sample Size | 625 | 5.04% sample rate (625 / 12,400)
Files with Deficiencies | 74 | 11.8% error rate (74 / 625)
QIIC Avg. Claims Acknowledgment Time (2024) | 18.7 business days | Statutory max ranges: 10–15 days by state
QIIC Timely Claims Payment Rate (2024) | 74.2% | Internal target: 95%
QIIC Complaint Ratio (2024) | 1.47 per 1,000 policies | 79.3% above NAIC median of 0.82
QSU Complaint Ratio (2024) | 0.93 per 1,000 policies | 13.4% above NAIC median
QLA Complaint Ratio (2024) | 1.12 per 1,000 policies | 36.6% above NAIC median
Total Consumer Complaints — All Subsidiaries (2024) | 2,847 | Across QIIC, QSU, QLA
QIIC Total Policies In Force (2024) | Approximately 1,937,000 | Derived from complaint ratio calculation
Non-Compliant Digital Ads Identified | 43 unique creatives | Severin Industries, Meta, programmatic display
Ads Placed by Pinnacle Bridge MGA | 31 of 43 (72.1%) | Without routing through QIIC compliance review
Non-Compliant Advertising Period | March 2022 – November 2024 (~32 months)
States with Advertising Findings | Florida, California, Illinois, Ohio
Denial Letters Missing Statutory Citations | 62% of sampled denials | Examiner review of denial correspondence
Supervisory Review Documentation Absent | 41% of sampled files | No documented supervisory review found in claims files
Total Formal Examination Findings | 14 | 6 claims + 5 advertising + 3 complaints
Critical Findings | 4 | Findings 1, 2, 4, 7
Major Findings | 9 | Findings 3, 5, 6, 8, 9, 10, 12, 13, 14
Minor Findings | 1 | Finding 11
CTDOI Civil Penalty | $275,000 | Paid July 15, 2025
FL OIR Administrative Fine | $180,000 | Due September 30, 2025
Total Penalties | $455,000 | $275,000 + $180,000
CDI Order to Show Cause | Issued June 18, 2025 | Hearing scheduled October 14, 2025 (advertising violations)
D&O Insurance Carrier | Ashford Mutual Insurance Group | $25M per occurrence / $50M aggregate; $1M retention
Internal Audit Deficiencies (IA-2025-017) | 23 | Issued August 4, 2025; rated Needs Significant Improvement
Total FTEs Requiring Training | 815 | 420 claims adjusters + 85 marketing + 310 CSRs
[sheet: Timeline & Key Dates]
Date | Event / Milestone | Category | Responsible Party | Status | Notes
2021-01-01 | Start of multi-state examination period | Regulatory | FL OIR / CTDOI | Complete
2022-03-01 | Earliest non-compliant digital advertisement identified | Regulatory | Pinnacle Bridge MGA | Complete | First of 43 non-compliant ad creatives placed without QIIC compliance review
2023-09-01 | CTDOI initiated coordinated multi-state market-conduct examination | Regulatory | CTDOI | Complete | Under NAIC Market Regulation protocols; FL OIR designated as lead examining state
2023-12-31 | End of multi-state examination period | Regulatory | FL OIR | Complete
2024-11-30 | End of non-compliant advertising period | Regulatory | Pinnacle Bridge MGA | Complete | Approximately 32 months of non-compliant advertising activity
2025-05-12 | Final examination report issued by FL OIR | Regulatory | FL OIR | Complete | 14 formal findings across 3 categories
2025-06-01 | Hargrove & Sattler LLP engagement concluded | Engagement | Mitchell Ostrander | Complete | Prior regulatory counsel
2025-06-18 | CDI issued Order to Show Cause (advertising violations) | Regulatory | CDI | Complete | Re: CA advertising violations identified in multi-state examination
2025-07-01 | QIIC submitted Corrective Action Plan to FL OIR | Regulatory | Priya Venkatesh | Complete | Initial submission prepared by Hargrove & Sattler prior to engagement conclusion
2025-07-15 | CTDOI civil penalty of $275,000 paid | Penalty | Derek Mallory | Complete | Wire transfer confirmed; CTDOI acknowledgment received
2025-07-28 | FL OIR accepted CAP with modifications | Regulatory | FL OIR | Complete | Modifications incorporated; remediation deadline confirmed as December 31, 2025
2025-08-04 | Internal Audit Report No. IA-2025-017 issued | Internal | Neil Granger | Complete | 23 control deficiencies; rated Needs Significant Improvement (2nd lowest on 5-tier scale)
2025-08-12 | Board Audit & Compliance Committee directed retention of new counsel | Internal | Margaret Aldworth (Chair) | Complete | Committee determined prior counsel's CAP response insufficient; authorized engagement of C&H
2025-08-19 | Calderwood & Harkness LLP engagement opened | Engagement | Marcus Delgado | Complete | Matter No. 1025-00002; Phase 1 (Assessment) commenced immediately
2025-09-22 | Dashboard specifications received from QIH IT | Internal | Thomas Raeburn / QIH IT | Complete | Prompt-pay compliance monitoring dashboard specifications for CAP-04
2025-09-30 | FL OIR administrative fine ($180,000) payment due | Penalty | Derek Mallory | Upcoming | Wire transfer to FL OIR; total penalties will be $455,000 upon payment
2025-10-03 | Phase 1 (Assessment & Gap Analysis) target completion | Engagement | Marcus Delgado / Carlos Espinoza | Upcoming | Soft cap: $185,000; deliverables: gap analysis report, remediation roadmap
2025-10-06 | Phase 2 (Remediation & Policy Drafting) commences | Engagement | C&H Team | Upcoming | Fixed fee portion begins; SOP drafting, system configuration oversight, MGA amendment
2025-10-14 | CDI Order to Show Cause hearing (California) | Regulatory | Carlos Espinoza / Priya Venkatesh | Upcoming | Advertising violations; coordinate defense strategy with Derek Mallory
2025-10-15 | Deadline: Remove/revise all 43 non-compliant ads (CAP-16) | Regulatory | Priya Venkatesh | Upcoming | 38 of 43 removed; 5 programmatic display ads pending platform confirmation
2025-10-31 | Deadline: System auto-acknowledgment workflow (CAP-01); MGA amendment (CAP-17); rate-comparison review (CAP-21) | Engagement | Thomas Raeburn / Derek Mallory / Priya Venkatesh | Upcoming | Multiple milestone deadlines
2025-11-14 | Phase 2 target completion | Engagement | C&H Team | Upcoming | All Phase 2 SOPs, protocols, and system configurations to be finalized
2025-11-17 | Phase 3 (Training & Implementation) commences | Engagement | Hannah Brinkley | Upcoming | 815 FTEs: 420 claims adjusters + 85 marketing + 310 CSRs
2025-11-30 | Multiple system implementation deadlines (CAP-06, CAP-08, CAP-10, CAP-19, CAP-24, CAP-28, CAP-29, CAP-31, CAP-34, CAP-37) | Engagement | Multiple owners | Upcoming | System configurations, databases, and reporting tools go-live
2025-12-05 | Phase 3 target completion | Engagement | Hannah Brinkley | Upcoming | All training modules delivered; certifications collected
2025-12-08 | Phase 4 (Examination Preparation) commences | Engagement | Carlos Espinoza | Upcoming | Mock exams; regulatory correspondence preparation; document organization
2025-12-15 | Deadline: Post-implementation QA reviews (CAP-09); Compliance Policy Manual (CAP-38); annual certification policy (CAP-23) | Internal | Multiple owners | Upcoming | Validation of remediation effectiveness
2025-12-20 | Internal Audit follow-up audit target completion (CAP-39) | Internal | Neil Granger / Priya Venkatesh | Upcoming | Follow-up audit to validate closure of IA-2025-017 deficiencies
2025-12-31 | CAP full remediation and compliance certification deadline | Regulatory | Priya Venkatesh | Upcoming | Compliance certification letter to FL OIR (CAP-40); C&H to draft for QIIC signature
2026-01-30 | Phase 4 target completion; C&H engagement conclusion | Engagement | Marcus Delgado | Upcoming | Anticipated follow-up exams: FL OIR, CDI, NYDFS in Q1 2026