1025-00002 · QUORUM INSURANCE HOLDINGS · Correspondence

draft-letter-fl-oir-compliance-progress.docx DOCUMENT M&A / Corporate

6 / 12 ← → ✕

Contract analysis Extract to table

DRAFT — Prepared by Calderwood & Harkness LLP for Review and Signature by Client

QUORUM INSURANCE HOLDINGS CORP. 280 Asylum Street, Suite 1400 Hartford, CT 06103 Tel: (860) 555-7200

Fax: (860) 555-7201

www.quoruminsurance.com

[Date to be inserted]

VIA ELECTRONIC FILING AND CERTIFIED MAIL — RETURN RECEIPT REQUESTED

Commissioner Michael Yaworsky Florida Office of Insurance Regulation 200 East Gaines Street Tallahassee, FL 32399-0326

Re: Quorum Indemnity Insurance Company NAIC No. 41927 Corrective Action Plan Compliance Progress Report FL OIR Market-Conduct Examination Report (Issued May 12, 2025) Corrective Action Plan (Submitted July 1, 2025; Accepted with Modifications July 28, 2025)

Dear Commissioner Yaworsky:

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 Corp. ("QIH" or the "Company"), a Delaware corporation publicly traded on the Nasdaq Stock Market under the ticker symbol "QIHC" and headquartered at 280 Asylum Street, Suite 1400, Hartford, Connecticut 06103.

The purpose of this Progress Report is to apprise the Department of the substantial remediation progress that QIIC has achieved under the Corrective Action Plan (the "CAP") accepted by FL OIR on July 28, 2025, following the issuance of the final multi-state market-conduct examination report on May 12, 2025 (the "Examination Report"). As the Department is aware, the coordinated multi-state market-conduct examination was initiated by the Connecticut Department of Insurance ("CTDOI") in September 2023, with FL OIR serving as the lead examining state. The examination covered the period from January 1, 2021 through December 31, 2023 (the "Examination Period") and encompassed a comprehensive review of QIIC's claims-handling practices, advertising and marketing compliance, and complaint-handling procedures across multiple jurisdictions.

The Examination Report identified fourteen (14) formal findings organized into three categories: (i) six (6) findings related to claims-handling timeliness (Findings 1 through 6); (ii) five (5) findings related to advertising and marketing compliance (Findings 7 through 11); and (iii) three (3) findings related to complaint-handling procedures (Findings 12 through 14). QIIC submitted the CAP on July 1, 2025, and the Department accepted the CAP with certain modifications on July 28, 2025. The accepted CAP established December 31, 2025 as the deadline for full remediation and compliance certification.

QIIC remains firmly committed to achieving full remediation and compliance certification by the December 31, 2025 deadline. This Progress Report is submitted in accordance with Section IV.B of the accepted CAP, which requires QIIC to submit written progress reports to FL OIR at intervals of not less than sixty (60) days. As detailed below, QIIC has made significant and measurable progress across all three categories of examination findings, and the Company is on track to meet the December 31, 2025 compliance certification deadline.

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 transfer to the account designated by the Department. Confirmation of receipt was provided by the Department's Division of Financial Services on September 29, 2025. A copy of the wire transfer confirmation and the Department's acknowledgment of receipt are attached hereto by reference as Exhibit A.

For the Department's additional information, QIIC notes that the CTDOI separately assessed a civil penalty in the amount of Two Hundred Seventy-Five Thousand Dollars ($275,000.00) in connection with findings arising from the same coordinated multi-state examination. That penalty was paid in full on July 15, 2025, bringing the total penalties assessed and paid by QIIC across both jurisdictions to Four Hundred Fifty-Five Thousand Dollars ($455,000.00). QIIC is not aware of any additional monetary penalties that are outstanding in connection with the coordinated examination at this time, although QIIC acknowledges that additional proceedings are pending in other jurisdictions, as discussed in Section XI below.

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 Compliance Committee (the "A&C Committee") of the QIH Board of Directors, chaired by independent director Margaret Aldworth, convened a special meeting at which it directed management to retain new outside counsel to conduct a comprehensive market-conduct compliance refresh across all QIH carrier subsidiaries and affiliated distribution entities. The A&C Committee determined that fresh perspectives were required given the scope and severity of the examination findings, and that the remediation effort should be enterprise-wide in scope rather than limited to the specific findings identified in the FL OIR Examination Report.

Retention of Calderwood & Harkness LLP. Pursuant to the A&C Committee's directive, QIH retained Calderwood & Harkness LLP ("Calderwood & Harkness"), effective August 19, 2025, as lead outside counsel for the market-conduct compliance remediation program. Calderwood & Harkness replaced prior regulatory counsel Hargrove & Sattler LLP, whose engagement concluded in June 2025. Calderwood & Harkness's insurance regulatory practice group, under the direction of partner Marcus Delgado, brings significant experience in market-conduct examination defense, regulatory compliance program design, and CAP implementation across multiple jurisdictions.

Retention of Ridgeline Consulting Group, LLC. In addition to the engagement of new outside counsel, QIH retained Ridgeline Consulting Group, LLC ("Ridgeline"), a third-party market-conduct consulting firm based in McLean, Virginia, under the direction of Managing Director Sandra Whitfield. Ridgeline was retained to perform independent statistical claims-file sampling, complaint-ratio benchmarking against industry and NAIC standards, and validation testing of the remedial measures implemented under the CAP. Ridgeline's work product will serve as the foundation for the compliance certification to be submitted to the Department on or before December 31, 2025.

Continuation of Florida Local Regulatory Counsel. Cartwright & Eddings, P.A., based in Orlando, Florida, continues to serve as QIIC's Florida local regulatory counsel. Rosa Delacroix, Esq., a partner at Cartwright & Eddings specializing in Florida insurance regulatory matters, is the primary point of contact and has been coordinating directly with the Department on all matters related to the CAP and this Progress Report.

Four-Phase Work Plan. The engagement of Calderwood & Harkness and Ridgeline encompasses a structured four-phase work plan designed to ensure systematic and complete remediation of all identified deficiencies:

Phase 1 — Assessment & Gap Analysis (August 19 – October 3, 2025): Comprehensive assessment of QIIC's existing market-conduct compliance program, including identification of gaps between current practices and applicable statutory and regulatory requirements across all licensed jurisdictions, and benchmarking against industry best practices and NAIC Market Regulation Handbook standards.

Phase 2 — Remediation & Policy Drafting (October 6 – November 14, 2025): Development and finalization of revised standard operating procedures ("SOPs"), compliance policies, and internal controls to address all identified deficiencies, including preparation of a comprehensive revised Market-Conduct Compliance Manual.

Phase 3 — Training & Implementation (November 17 – December 5, 2025): Enterprise-wide training of all affected personnel on revised procedures and compliance standards, with knowledge-check assessments and certification sign-off requirements.

Phase 4 — Examination Preparation (December 8, 2025 – January 30, 2026): Preparation for anticipated follow-up examination by FL OIR and/or other examining states, including organization of examination files, preparation of examination responses, and validation testing of remedial measures through independent sampling conducted by Ridgeline.

The status of each phase is addressed in the relevant sections of this Progress Report below.

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 summarized below.

Scope of Assessment. The gap analysis covered QIIC's twenty-eight (28) licensed states, which are part of a total of seventy-nine (79) state licenses held across all three QIH carrier subsidiaries — Quorum Indemnity Insurance Company (QIIC), Quorum Specialty Underwriters, Inc. (QSU), and Quorum Life & Annuity Company (QLA) — representing thirty-eight (38) unique states after de-duplication of overlapping licenses. The assessment evaluated compliance with applicable statutes, regulations, and administrative orders governing claims-handling timeliness, advertising and marketing practices, and complaint-handling procedures in each of these jurisdictions, with particular emphasis on the states participating in the coordinated multi-state examination.

Cross-Reference with Internal Audit Findings. The Phase 1 assessment cross-referenced the fourteen (14) formal findings in the FL OIR Examination Report with Internal Audit Report No. IA-2025-017, issued on August 4, 2025, by QIH Director of Internal Audit Neil Granger. The Internal Audit Report, which was prepared independently of the examination and the CAP process, identified twenty-three (23) control deficiencies in QIIC's market-conduct compliance program and rated the overall program as "Needs Significant Improvement" — the second-lowest rating on the Company's five-level internal audit rating scale. Notably, all fourteen (14) of the FL OIR findings were corroborated by one or more of the twenty-three (23) Internal Audit Report control deficiencies, confirming the systemic nature of the compliance gaps identified by the Department.

Key Quantitative Findings. The Phase 1 assessment confirmed and, in several instances, expanded upon the quantitative findings in the Examination Report. The principal quantitative findings are as follows:

(a) Claims Acknowledgment Timeliness. QIIC's average claims acknowledgment time, measured on a calendar-year 2024 basis, was 18.7 business days — significantly exceeding statutory maximums of ten (10) to fifteen (15) business days, depending on the jurisdiction. In the most restrictive states (including Florida, under Fla. Stat. § 626.9541(1)(i)3.a.), where the applicable standard is fourteen (14) calendar days, QIIC's average acknowledgment time exceeded the statutory deadline in approximately 38% of claims files reviewed.

(b) Timely Claims Payment Rate. QIIC's timely claims payment rate for calendar year 2024 — defined as the percentage of claims paid within applicable statutory prompt-pay windows — was 74.2%, well below the Company's internal target of 95% and materially below industry benchmarks. The Phase 1 assessment confirmed that this deficiency was pervasive across jurisdictions and lines of business, with the most pronounced shortfalls observed in property claims and casualty first-party claims.

(c) Complaint Ratio. QIIC's complaint ratio for calendar year 2024 was 1.47 complaints per 1,000 policies in force, which is 79.3% above the NAIC median complaint ratio of 0.82 complaints per 1,000 policies in force. This elevated complaint ratio was among the primary factors cited in the Examination Report as evidence of systemic deficiencies in QIIC's claims and consumer-service practices.

(d) Claims File Error Rate. The claims file error rate in the examined sample was 11.8%, representing seventy-four (74) files with one or more identified deficiencies out of a total of six hundred twenty-five (625) files sampled from a universe of approximately 12,400 claims files during the Examination Period. This represents a 5.04% sample rate. Deficiencies included missing documentation, untimely acknowledgment letters, failure to document claim investigation activities, and incorrect application of policy provisions.

(e) Non-Compliant Digital Advertising. Forty-three (43) non-compliant digital ad creatives were identified across four states — Florida, California, Illinois, and Ohio — spanning the period from March 2022 through November 2024. The non-compliant creatives included unapproved or non-filed rate comparisons, misleading savings claims, and advertisements that failed to include required disclosures regarding underwriting company identity and licensing status.

The Phase 1 assessment provided the foundation for the remediation work conducted in Phase 2, the results of which are described in Sections V through VIII below.

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 (Finding 1); (ii) failed to commence investigation of claims within the time frames required by Fla. Stat. § 626.9541(1)(i)3 (Finding 2); (iii) failed to affirm or deny coverage within the time frames required by applicable law (Finding 3); (iv) failed to make prompt payment of settled claims as required by Fla. Stat. § 626.9541(1)(i)3.c. (Finding 4); (v) failed to maintain adequate claims-handling documentation sufficient to demonstrate compliance with statutory timeliness requirements (Finding 5); and (vi) failed to establish and enforce internal controls and supervisory review mechanisms sufficient to ensure compliance with statutory claims-handling deadlines (Finding 6).

B. Remediation Actions Taken

In response to Findings 1 through 6, QIIC has developed, approved, and commenced implementation of a comprehensive Revised Claims-Handling Timeliness Remediation Protocol (the "Claims Remediation Protocol"), which is attached hereto by reference as Exhibit B. The Claims Remediation Protocol constitutes a detailed standard operating procedure governing all aspects of claims acknowledgment, investigation, coverage determination, and payment timeliness. The principal components of the Claims Remediation Protocol are as follows:

Uniform Claims Acknowledgment Standard. QIIC has established a uniform ten (10) business-day claims acknowledgment standard applicable across all twenty-eight (28) of QIIC's licensed states. This uniform standard was adopted to match the most stringent state statutory requirement and replaces the prior inconsistent practice under which claims acknowledgment deadlines varied by jurisdiction and were not consistently tracked or enforced, resulting in the 18.7-business-day average identified during the Phase 1 assessment. Under the revised standard, upon receipt of a claim or notification of a loss, QIIC's claims department is required to issue a written acknowledgment to the claimant or insured within ten (10) business days of receipt, regardless of the jurisdiction in which the claim was filed.

System-Alert Configurations and Escalation Protocols. QIIC's claims management system ("CMS") — the Severin Solutions platform — has been configured with automated system alerts and escalation protocols designed to prevent claims from approaching or exceeding statutory deadlines without appropriate supervisory attention. Specifically, the CMS now generates: (i) an initial alert to the assigned claims adjuster at the five (5) business-day mark following claim receipt if no acknowledgment has been issued; (ii) a secondary escalation alert to the adjuster's direct supervisor at the seven (7) business-day mark; and (iii) a tertiary escalation alert to the regional claims manager at the nine (9) business-day mark. Similar alert cascades have been configured for coverage determination deadlines and prompt-pay deadlines. Failure to resolve an escalation alert prior to the statutory deadline triggers an automatic referral to the Claims Quality Assurance unit for root-cause review.

Supervisory Review Triggers. In addition to the automated system alerts described above, QIIC has implemented mandatory supervisory review triggers at defined intervals throughout the claims lifecycle. All claims with an incurred value exceeding $25,000 are subject to supervisory review within fifteen (15) business days of initial receipt and at subsequent thirty (30) day intervals until the claim is closed. Claims involving coverage disputes, reservation-of-rights letters, or extracontractual exposure are subject to enhanced supervisory review protocols, including mandatory involvement of claims counsel.

Responsible Executive. Thomas Raeburn, Senior Vice President of Claims Operations, has been designated as the responsible executive for claims-handling timeliness remediation. Mr. Raeburn reports directly to QIH Chief Operating Officer Daniel Ashby and provides monthly remediation status updates to the A&C Committee. Mr. Raeburn has direct authority over claims-handling staffing, workflow design, and CMS configuration, and is accountable for achievement of the remediation targets set forth in the CAP.

C. Current Performance Metrics

QIIC is pleased to report that the remediation actions described above are producing measurable improvements in claims-handling timeliness. Preliminary data compiled by the Claims Quality Assurance unit indicates an improving trajectory across all key performance indicators. As of the date of this Progress Report, the Company's current performance metrics reflect the following:

• Average claims acknowledgment time has been reduced from 18.7 business days (2024 full-year average) to approximately [] business days (month-to-date as of the date of this letter), reflecting a []% improvement.

• The timely claims payment rate has improved from 74.2% (2024 full-year average) to approximately []% (month-to-date as of the date of this letter), representing an increase of approximately [] percentage points.

QIIC's target is to achieve a timely claims payment rate of at least 95% by December 31, 2025, consistent with the Company's internal benchmark and the remediation timeline established in the accepted CAP. Ridgeline Consulting Group will conduct independent validation testing of claims-handling timeliness metrics in connection with the preparation of the compliance certification.

D. NYDFS Regulation 64 Compliance

QIIC notes for the Department's information that the claims-handling timeliness remediation workstream is also being designed to address concurrent compliance obligations under the New York Department of Financial Services ("NYDFS") Insurance Regulation 64 (11 NYCRR Part 216), which imposes detailed prompt-pay requirements on insurers doing business in New York. Because QIIC holds a New York certificate of authority and writes a material volume of business in New York, the Company is ensuring that its revised Claims Remediation Protocol meets or exceeds the requirements of Regulation 64, in addition to the requirements of the Florida Insurance Code and the statutes and regulations of all other licensed jurisdictions.

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 Department found that QIIC: (i) disseminated digital advertisements containing rate-comparison claims that had not been filed with or approved by the applicable state insurance department (Finding 7); (ii) disseminated digital advertisements containing misleading or unsubstantiated savings claims (Finding 8); (iii) failed to maintain copies of all advertisements and a record of when and where advertisements were used, as required by applicable law (Finding 9); (iv) failed to establish and enforce an internal advertising review and approval process sufficient to ensure pre-publication compliance review of all marketing materials (Finding 10); and (v) failed to adequately supervise the advertising activities of its managing general agent, Pinnacle Bridge MGA, LLC (Finding 11).

B. Root Cause Analysis

The Phase 1 assessment identified a significant root cause underlying the advertising compliance deficiencies. Of the forty-three (43) non-compliant digital ad creatives identified during the examination, thirty-one (31) — representing 72.1% of the total — were placed by Pinnacle Bridge MGA, LLC ("Pinnacle Bridge"), QIH's fintech distribution platform. Pinnacle Bridge is a Delaware limited liability company and a wholly owned subsidiary of QIH that operates as a managing general agent under delegated authority agreements with the three QIH carrier subsidiaries. The non-compliant creatives placed by Pinnacle Bridge were developed and deployed by Pinnacle Bridge's in-house digital marketing team without being routed through QIIC's advertising compliance review process. The root cause of this gap was the absence of a mandatory pre-publication compliance review requirement in the Pinnacle Bridge delegated authority agreement and the lack of a centralized advertising review workflow that encompassed affiliated distribution entities.

The remaining twelve (12) non-compliant creatives were placed directly by QIIC or its marketing vendors through Strathmore Systems, Meta (Kestrel Services Inc. and Northpoint Services Inc.) advertising platforms, and programmatic display advertising channels. These creatives were developed internally but were deployed without sufficient compliance vetting due to the absence of formalized approval workflows and the lack of designated compliance personnel responsible for reviewing digital advertising content prior to publication.

C. Corrective Actions Taken

QIIC has implemented the following corrective actions to address Findings 7 through 11:

Centralized Advertising Review Workflow. A centralized advertising review workflow has been established requiring that all marketing materials — including but not limited to digital advertisements across all channels (search, social media, display, email, and programmatic), print advertisements, direct mail, website content, and agent-facing promotional materials — be submitted to QIIC's advertising compliance function prior to publication or dissemination. The advertising compliance function is overseen by Lena Fujimoto, Director of Market Conduct and Consumer Affairs, who reports to Derek Mallory, General Counsel and Chief Compliance Officer. All advertising submissions are reviewed for compliance with applicable state advertising statutes and regulations, including but not limited to the Florida Unfair Insurance Trade Practices Act (Fla. Stat. § 626.9541), the Florida Insurance Code's advertising filing requirements, and the NAIC Advertisements of Insurance Model Regulation.

Pinnacle Bridge MGA Procedures. Specific procedures have been drafted and adopted to close the workflow gap between Pinnacle Bridge and QIIC's advertising compliance function. Effective upon implementation, Pinnacle Bridge is required to route all ad creatives — including digital advertisements, landing page content, social media posts, and paid search copy — through the centralized advertising compliance review process prior to deployment. The Pinnacle Bridge delegated authority agreement has been amended to include an express provision requiring pre-publication compliance review of all marketing materials and providing QIIC with audit rights over Pinnacle Bridge's marketing activities. Pinnacle Bridge's Vice President of Digital Marketing, who oversees the in-house marketing team, has been notified of the new requirements and has acknowledged the amended procedures in writing.

State-by-State Filing Requirements Catalogue. Calderwood & Harkness, in coordination with QIIC's advertising compliance function, has prepared a comprehensive catalogue of state-by-state advertising filing requirements across all thirty-eight (38) unique states in which the QIH enterprise holds insurance licenses. The catalogue classifies each jurisdiction according to its advertising filing regime — prior-approval, file-and-use, or use-and-file — and specifies applicable filing deadlines, required forms, and any state-specific content requirements or prohibitions. Particular attention has been given to Florida's advertising filing requirements under the Florida Administrative Code and the Department's published guidance on digital advertising compliance.

Withdrawal of Non-Compliant Creatives. All forty-three (43) identified non-compliant digital ad creatives have been withdrawn from circulation. As of the date of this Progress Report, QIIC confirms that none of the identified non-compliant creatives remain active on any advertising platform, website, or digital channel. Where applicable, removal confirmations have been obtained from the relevant advertising platforms.

Revised Advertising Review & Filing Procedures SOP. A comprehensive Revised Advertising Review & Filing Procedures SOP has been completed and approved by the A&C Committee. The SOP establishes detailed procedures for advertising submission, review, approval, filing, record retention, and periodic compliance monitoring. The SOP is attached hereto by reference as Exhibit C.

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 (Finding 12); (ii) failed to acknowledge consumer complaints within the time frames required by applicable law (Finding 13); and (iii) failed to provide substantive responses to consumer complaints within the time frames required by applicable law, including the time frames established by the Florida Department of Financial Services for responses to complaints forwarded through the state complaint portal (Finding 14).

B. Context: Complaint Volume and Ratios

The complaint-handling deficiencies identified in the Examination Report must be understood in the context of the elevated complaint volume experienced by QIIC and the QIH enterprise during the relevant period. The total number of consumer complaints filed against all QIH subsidiaries in calendar year 2024 was 2,847. QIIC's complaint ratio for the same period — 1.47 complaints per 1,000 policies in force — was 79.3% above the NAIC median complaint ratio of 0.82 complaints per 1,000 policies in force. This disproportionate complaint volume strained QIIC's existing complaint-handling infrastructure, which was not adequately staffed, resourced, or systematized to manage the volume of incoming complaints in a manner consistent with applicable regulatory requirements. The Phase 1 assessment identified the elevated complaint ratio as both a symptom of underlying claims-handling and service deficiencies and an independent area requiring targeted remediation.

C. Corrective Actions Taken

QIIC has implemented the following corrective actions to address Findings 12 through 14:

Updated Consumer Complaint Response Procedures SOP. A comprehensive Updated Consumer Complaint Response Procedures SOP has been drafted, approved, and implemented. The SOP establishes uniform, enterprise-wide procedures for the receipt, logging, acknowledgment, investigation, and resolution of consumer complaints. The SOP is designed to ensure that QIIC meets or exceeds the most restrictive applicable state statutory deadline for each stage of the complaint-handling process. The SOP is attached hereto by reference as Exhibit D.

Uniform Complaint Logging Standard. Under the revised procedures, all consumer complaints — whether received directly from consumers, forwarded by state insurance departments through complaint portals, received via the NAIC's Consumer Information Source database, or received through any other channel — are required to be logged in QIIC's complaint management system within twenty-four (24) hours of receipt. The complaint management system has been configured to time-stamp all entries and to generate alerts if a complaint remains unlogged beyond the twenty-four (24) hour threshold.

Acknowledgment Standard. Written acknowledgment of each consumer complaint is required to be issued to the complainant within three (3) business days of receipt. The acknowledgment must identify the assigned complaint handler, provide contact information for the complaint handler, and inform the complainant of the anticipated timeline for investigation and response.

Substantive Response Standard. A substantive written response to each consumer complaint is required to be issued within the most restrictive applicable state statutory deadline. Where the complaint is forwarded by a state insurance department, the response must comply with the specific deadline and format requirements established by that department. In all cases, the substantive response must address each issue raised in the complaint, explain the basis for QIIC's position, and inform the complainant of any applicable appeal or review rights.

Complaint Program Owner. Lena Fujimoto, Director of Market Conduct and Consumer Affairs, has been designated as the complaint program owner with direct reporting responsibility to Derek Mallory, General Counsel and Chief Compliance Officer. Ms. Fujimoto is responsible for the day-to-day management and oversight of the complaint-handling function, including staffing, training, quality assurance, and regulatory reporting. Ms. Fujimoto provides a weekly complaint status report to Mr. Mallory and a monthly complaint metrics report to the A&C Committee.

Enhanced Complaint Tracking and Reporting. QIIC has implemented enhanced complaint tracking and reporting mechanisms, including: (i) a centralized complaint dashboard providing real-time visibility into complaint volume, aging, and resolution status; (ii) automated escalation alerts for complaints approaching or exceeding applicable response deadlines; (iii) monthly complaint-ratio tracking and trending analysis, benchmarked against NAIC medians; and (iv) quarterly root-cause analysis of complaint trends to identify systemic issues requiring corrective action. These enhanced tracking and reporting mechanisms are designed to provide QIIC management, the A&C Committee, and the Department with reliable and timely information regarding the effectiveness of the complaint-handling remediation program.

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 governance document for the market-conduct compliance program across the entire QIH enterprise.

Enterprise-Wide Scope. The Manual covers all three Quorum carrier subsidiaries — Quorum Indemnity Insurance Company (QIIC), Quorum Specialty Underwriters, Inc. (QSU), and Quorum Life & Annuity Company (QLA) — as well as Pinnacle Bridge MGA, LLC, QIH's managing general agent. The decision to adopt an enterprise-wide scope was made at the direction of the A&C Committee to ensure consistency and eliminate the inter-company compliance gaps that contributed to the deficiencies identified in the Examination Report.

State-Specific Requirements. The Manual incorporates state-specific requirements for all thirty-eight (38) unique licensed states across the QIH enterprise. For each regulated function — claims handling, advertising, complaint handling, and related areas — the Manual identifies the applicable statutory and regulatory requirements on a state-by-state basis and specifies the procedures required to ensure compliance in each jurisdiction. Where requirements vary among states, the Manual establishes uniform baseline standards that meet or exceed the most stringent applicable requirement, supplemented by state-specific addenda addressing jurisdictions with unique or heightened requirements.

Chapter Organization. The Manual is organized into the following chapters:

Chapter 1: Governance and Oversight Chapter 2: Claims Handling — Standards and Procedures Chapter 3: Advertising and Marketing — Review, Approval, and Filing Chapter 4: Consumer Complaint Handling — Intake, Response, and Reporting Chapter 5: Examination Preparedness and Cooperation Chapter 6: Training and Continuing Education Chapter 7: Record Retention and Document Management Chapter 8: Internal Monitoring, Testing, and Reporting

Alignment with Examination Findings and Internal Audit Deficiencies. The Manual has been designed to respond comprehensively to all fourteen (14) FL OIR examination findings and all twenty-three (23) control deficiencies identified in Internal Audit Report No. IA-2025-017. A detailed crosswalk mapping each examination finding and internal audit deficiency to the specific Manual chapter, section, and procedure addressing that finding or deficiency has been prepared and will be included as an appendix to the compliance certification to be submitted to the Department.

A copy of the Draft Revised Market-Conduct Compliance Manual, including the Table of Contents and selected chapters, is attached hereto by reference as Exhibit E. QIIC expects to finalize the Manual upon completion of the Phase 3 training program and will provide a final version to the Department upon request.

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 compliance team. The training program is designed to ensure that all personnel with responsibilities relevant to the areas identified in the Examination Report receive comprehensive, role-specific training on the revised procedures, SOPs, and compliance standards adopted during Phase 2.

B. Training Tracks

Three distinct training tracks have been developed to address the specific roles and responsibilities of different employee populations:

Track 1 — Claims Adjusters (approximately 420 FTEs). This track covers the revised Claims-Handling Timeliness Remediation Protocol, including the uniform ten (10) business-day claims acknowledgment standard, the CMS system-alert and escalation protocol configurations, supervisory review triggers, documentation requirements, and prompt-pay compliance. Training content includes jurisdiction-specific modules addressing the claims-handling requirements of QIIC's highest-volume states, including Florida, New York, California, Texas, and Illinois.

Track 2 — Marketing Personnel (approximately 85 FTEs). This track covers the revised Advertising Review & Filing Procedures SOP, including the centralized advertising review workflow, state-by-state filing requirements, prohibited advertising practices, and record-retention obligations. A Pinnacle Bridge-specific module has been developed to address the unique compliance requirements applicable to marketing activities conducted through the MGA distribution platform, including the amended delegated authority agreement provisions governing pre-publication compliance review.

Track 3 — Customer Service Representatives (approximately 310 FTEs). This track covers the revised Consumer Complaint Response Procedures SOP, including complaint intake procedures, the twenty-four (24) hour logging requirement, the three (3) business-day acknowledgment standard, substantive response requirements, the complaint management system, escalation procedures, and regulatory complaint-forwarding processes.

C. Training Audience and Delivery

The total training audience encompasses approximately eight hundred fifteen (815) employees across all QIH subsidiaries and Pinnacle Bridge MGA. Training is being delivered through a blended format consisting of live webinar sessions conducted by Calderwood & Harkness attorneys and QIIC compliance personnel, supplemented by recorded on-demand training modules available through the Company's learning management system. Each training track concludes with a knowledge-check assessment that employees must pass with a score of 80% or higher to receive certification credit. All employees subject to training are required to complete a certification sign-off acknowledging their understanding of and commitment to the revised procedures and compliance standards.

D. Training Records and Compliance Certification

All training completion records, including attendance logs, assessment scores, and certification sign-offs, will be maintained in the Company's learning management system and in hardcopy files for a minimum of five (5) years for regulatory examination purposes and compliance certification documentation. Training completion data will be included in the compliance certification to be submitted to the Department on or before December 31, 2025.

E. Current Training Status

As of the date of this Progress Report, Phase 3 training is [underway/scheduled to begin on November 17, 2025]. [Completion percentages to be inserted if Phase 3 is underway or completed at time of letter.] QIIC anticipates that all training tracks will be completed on or before December 5, 2025, consistent with the Phase 3 timeline.

A copy of the Training Program Outline and Materials Summary is attached hereto by reference as Exhibit F.

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 certification to the Department that demonstrates material and sustainable compliance with all applicable statutory and regulatory requirements.

The summary timeline for the remediation program is as follows:

QIIC intends to submit a compliance certification to FL OIR on or before December 31, 2025, in the form and manner specified by the Department. The compliance certification will be supported by the documentation and validation testing described in this Progress Report, including independent claims-file sampling and complaint-ratio benchmarking performed by Ridgeline Consulting Group.

Additionally, QIIC is prepared for any anticipated follow-up examination by FL OIR, whether conducted in the fourth quarter of 2025 or the first quarter of 2026. The Company will cooperate fully and promptly with any such examination and will make all requested personnel, documents, and systems available to the Department's examination team.

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 compliance violations identified in connection with the coordinated multi-state examination. The Order to Show Cause alleged violations of Cal. Ins. Code §§ 780 et seq. in connection with certain of the non-compliant digital ad creatives identified during the examination. A hearing before an Administrative Law Judge was scheduled for October 14, 2025. QIIC has been cooperating fully with the CDI in connection with this matter and is addressing the CDI's findings through the same advertising compliance remediation workstream described in Section VI of this Progress Report. [Additional status update to be inserted as appropriate at time of letter.]

NYDFS Regulation 64 Compliance. As noted in Section V.D above, QIIC is concurrently addressing compliance with NYDFS Insurance Regulation 64 (11 NYCRR Part 216) through the same claims-handling timeliness remediation workstream. QIIC has not received a separate enforcement action from NYDFS at this time but is proactively ensuring that the revised Claims Remediation Protocol meets or exceeds Regulation 64 requirements in anticipation of any future regulatory inquiry.

General Cooperation. QIIC is prepared to cooperate fully with any additional regulatory inquiries from FL OIR, CTDOI, or any other state insurance regulatory authority arising from the coordinated multi-state examination or related matters. QIIC will promptly notify the Department of any material developments in the proceedings described above or any new regulatory proceedings that may arise.

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: Revised Consumer Complaint Response Procedures (Draft SOP)

Exhibit E: Draft Revised Market-Conduct Compliance Manual (Table of Contents and selected chapters)

Exhibit F: Training Program Outline & Materials Summary

Exhibit G: FL OIR CAP Compliance Tracker (milestone status summary, current as of the date of this letter)

Copies of the foregoing exhibits will be provided under separate cover concurrent with the submission of this Progress Report. QIIC will provide complete or updated versions of any exhibit upon the Department's request.

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 and appreciates the Department's constructive engagement throughout the CAP process.

Should the Department require any additional information, documentation, or clarification regarding any matter addressed in this Progress Report or the attached exhibits, QIIC will respond promptly and fully. Priya Venkatesh, Vice President of Regulatory Affairs, is available at the contact information set forth below to address any questions. Additionally, QIIC's counsel — Marcus Delgado of Calderwood & Harkness LLP and Rosa Delacroix of Cartwright & Eddings, P.A. — are available to coordinate with the Department's staff as needed.

We thank the Department for its consideration of this Progress Report and look forward to continuing to work with FL OIR toward successful completion of the CAP and compliance certification.

Respectfully submitted on behalf of Quorum Indemnity Insurance Company,

QUORUM INSURANCE HOLDINGS CORP., on behalf of Quorum Indemnity Insurance Company (NAIC No. 41927)

By: ________

Name: Priya Venkatesh

Title: Vice President, Regulatory Affairs

Date: ________

280 Asylum Street, Suite 1400 Hartford, CT 06103 Direct Phone: (860) 555-7244

Email: p.venkatesh@quoruminsurance.com

cc:

Derek Mallory, General Counsel & Chief Compliance Officer, Quorum Insurance Holdings Corp., 280 Asylum Street, Suite 1400, Hartford, CT 06103

Rosa Delacroix, Esq., Cartwright & Eddings, P.A., 301 East Pine Street, Suite 750, Orlando, FL 32801

Marcus Delgado, Esq., Calderwood & Harkness LLP, 1177 Avenue of the Americas, 34th Floor, New York, NY 10036

Phase	Description	Dates	Status
Phase 1	Assessment & Gap Analysis	August 19 – October 3, 2025	Completed
Phase 2	Remediation & Policy Drafting	October 6 – November 14, 2025	Completed
Phase 3	Training & Implementation	November 17 – December 5, 2025	[In Progress / Scheduled]
Phase 4	Examination Preparation	December 8, 2025 – January 30, 2026	Scheduled

DRAFT — Prepared by Calderwood & Harkness LLP for Review and Signature by Client
QUORUM INSURANCE HOLDINGS CORP. 280 Asylum Street, Suite 1400 Hartford, CT 06103 Tel: (860) 555-7200
Fax: (860) 555-7201
www.quoruminsurance.com
[Date to be inserted]
VIA ELECTRONIC FILING AND CERTIFIED MAIL — RETURN RECEIPT REQUESTED
Commissioner Michael Yaworsky Florida Office of Insurance Regulation 200 East Gaines Street Tallahassee, FL 32399-0326
Re: Quorum Indemnity Insurance Company NAIC No. 41927 Corrective Action Plan Compliance Progress Report FL OIR Market-Conduct Examination Report (Issued May 12, 2025) Corrective Action Plan (Submitted July 1, 2025; Accepted with Modifications July 28, 2025)
Dear Commissioner Yaworsky:
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 Corp. ("QIH" or the "Company"), a Delaware corporation publicly traded on the Nasdaq Stock Market under the ticker symbol "QIHC" and headquartered at 280 Asylum Street, Suite 1400, Hartford, Connecticut 06103.
The purpose of this Progress Report is to apprise the Department of the substantial remediation progress that QIIC has achieved under the Corrective Action Plan (the "CAP") accepted by FL OIR on July 28, 2025, following the issuance of the final multi-state market-conduct examination report on May 12, 2025 (the "Examination Report"). As the Department is aware, the coordinated multi-state market-conduct examination was initiated by the Connecticut Department of Insurance ("CTDOI") in September 2023, with FL OIR serving as the lead examining state. The examination covered the period from January 1, 2021 through December 31, 2023 (the "Examination Period") and encompassed a comprehensive review of QIIC's claims-handling practices, advertising and marketing compliance, and complaint-handling procedures across multiple jurisdictions.
The Examination Report identified fourteen (14) formal findings organized into three categories: (i) six (6) findings related to claims-handling timeliness (Findings 1 through 6); (ii) five (5) findings related to advertising and marketing compliance (Findings 7 through 11); and (iii) three (3) findings related to complaint-handling procedures (Findings 12 through 14). QIIC submitted the CAP on July 1, 2025, and the Department accepted the CAP with certain modifications on July 28, 2025. The accepted CAP established December 31, 2025 as the deadline for full remediation and compliance certification.
QIIC remains firmly committed to achieving full remediation and compliance certification by the December 31, 2025 deadline. This Progress Report is submitted in accordance with Section IV.B of the accepted CAP, which requires QIIC to submit written progress reports to FL OIR at intervals of not less than sixty (60) days. As detailed below, QIIC has made significant and measurable progress across all three categories of examination findings, and the Company is on track to meet the December 31, 2025 compliance certification deadline.
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 transfer to the account designated by the Department. Confirmation of receipt was provided by the Department's Division of Financial Services on September 29, 2025. A copy of the wire transfer confirmation and the Department's acknowledgment of receipt are attached hereto by reference as Exhibit A.
For the Department's additional information, QIIC notes that the CTDOI separately assessed a civil penalty in the amount of Two Hundred Seventy-Five Thousand Dollars ($275,000.00) in connection with findings arising from the same coordinated multi-state examination. That penalty was paid in full on July 15, 2025, bringing the total penalties assessed and paid by QIIC across both jurisdictions to Four Hundred Fifty-Five Thousand Dollars ($455,000.00). QIIC is not aware of any additional monetary penalties that are outstanding in connection with the coordinated examination at this time, although QIIC acknowledges that additional proceedings are pending in other jurisdictions, as discussed in Section XI below.
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 Compliance Committee (the "A&C Committee") of the QIH Board of Directors, chaired by independent director Margaret Aldworth, convened a special meeting at which it directed management to retain new outside counsel to conduct a comprehensive market-conduct compliance refresh across all QIH carrier subsidiaries and affiliated distribution entities. The A&C Committee determined that fresh perspectives were required given the scope and severity of the examination findings, and that the remediation effort should be enterprise-wide in scope rather than limited to the specific findings identified in the FL OIR Examination Report.
Retention of Calderwood & Harkness LLP. Pursuant to the A&C Committee's directive, QIH retained Calderwood & Harkness LLP ("Calderwood & Harkness"), effective August 19, 2025, as lead outside counsel for the market-conduct compliance remediation program. Calderwood & Harkness replaced prior regulatory counsel Hargrove & Sattler LLP, whose engagement concluded in June 2025. Calderwood & Harkness's insurance regulatory practice group, under the direction of partner Marcus Delgado, brings significant experience in market-conduct examination defense, regulatory compliance program design, and CAP implementation across multiple jurisdictions.
Retention of Ridgeline Consulting Group, LLC. In addition to the engagement of new outside counsel, QIH retained Ridgeline Consulting Group, LLC ("Ridgeline"), a third-party market-conduct consulting firm based in McLean, Virginia, under the direction of Managing Director Sandra Whitfield. Ridgeline was retained to perform independent statistical claims-file sampling, complaint-ratio benchmarking against industry and NAIC standards, and validation testing of the remedial measures implemented under the CAP. Ridgeline's work product will serve as the foundation for the compliance certification to be submitted to the Department on or before December 31, 2025.
Continuation of Florida Local Regulatory Counsel. Cartwright & Eddings, P.A., based in Orlando, Florida, continues to serve as QIIC's Florida local regulatory counsel. Rosa Delacroix, Esq., a partner at Cartwright & Eddings specializing in Florida insurance regulatory matters, is the primary point of contact and has been coordinating directly with the Department on all matters related to the CAP and this Progress Report.
Four-Phase Work Plan. The engagement of Calderwood & Harkness and Ridgeline encompasses a structured four-phase work plan designed to ensure systematic and complete remediation of all identified deficiencies:
Phase 1 — Assessment & Gap Analysis (August 19 – October 3, 2025): Comprehensive assessment of QIIC's existing market-conduct compliance program, including identification of gaps between current practices and applicable statutory and regulatory requirements across all licensed jurisdictions, and benchmarking against industry best practices and NAIC Market Regulation Handbook standards.
Phase 2 — Remediation & Policy Drafting (October 6 – November 14, 2025): Development and finalization of revised standard operating procedures ("SOPs"), compliance policies, and internal controls to address all identified deficiencies, including preparation of a comprehensive revised Market-Conduct Compliance Manual.
Phase 3 — Training & Implementation (November 17 – December 5, 2025): Enterprise-wide training of all affected personnel on revised procedures and compliance standards, with knowledge-check assessments and certification sign-off requirements.
Phase 4 — Examination Preparation (December 8, 2025 – January 30, 2026): Preparation for anticipated follow-up examination by FL OIR and/or other examining states, including organization of examination files, preparation of examination responses, and validation testing of remedial measures through independent sampling conducted by Ridgeline.
The status of each phase is addressed in the relevant sections of this Progress Report below.
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 summarized below.
Scope of Assessment. The gap analysis covered QIIC's twenty-eight (28) licensed states, which are part of a total of seventy-nine (79) state licenses held across all three QIH carrier subsidiaries — Quorum Indemnity Insurance Company (QIIC), Quorum Specialty Underwriters, Inc. (QSU), and Quorum Life & Annuity Company (QLA) — representing thirty-eight (38) unique states after de-duplication of overlapping licenses. The assessment evaluated compliance with applicable statutes, regulations, and administrative orders governing claims-handling timeliness, advertising and marketing practices, and complaint-handling procedures in each of these jurisdictions, with particular emphasis on the states participating in the coordinated multi-state examination.
Cross-Reference with Internal Audit Findings. The Phase 1 assessment cross-referenced the fourteen (14) formal findings in the FL OIR Examination Report with Internal Audit Report No. IA-2025-017, issued on August 4, 2025, by QIH Director of Internal Audit Neil Granger. The Internal Audit Report, which was prepared independently of the examination and the CAP process, identified twenty-three (23) control deficiencies in QIIC's market-conduct compliance program and rated the overall program as "Needs Significant Improvement" — the second-lowest rating on the Company's five-level internal audit rating scale. Notably, all fourteen (14) of the FL OIR findings were corroborated by one or more of the twenty-three (23) Internal Audit Report control deficiencies, confirming the systemic nature of the compliance gaps identified by the Department.
Key Quantitative Findings. The Phase 1 assessment confirmed and, in several instances, expanded upon the quantitative findings in the Examination Report. The principal quantitative findings are as follows:
(a) Claims Acknowledgment Timeliness. QIIC's average claims acknowledgment time, measured on a calendar-year 2024 basis, was 18.7 business days — significantly exceeding statutory maximums of ten (10) to fifteen (15) business days, depending on the jurisdiction. In the most restrictive states (including Florida, under Fla. Stat. § 626.9541(1)(i)3.a.), where the applicable standard is fourteen (14) calendar days, QIIC's average acknowledgment time exceeded the statutory deadline in approximately 38% of claims files reviewed.
(b) Timely Claims Payment Rate. QIIC's timely claims payment rate for calendar year 2024 — defined as the percentage of claims paid within applicable statutory prompt-pay windows — was 74.2%, well below the Company's internal target of 95% and materially below industry benchmarks. The Phase 1 assessment confirmed that this deficiency was pervasive across jurisdictions and lines of business, with the most pronounced shortfalls observed in property claims and casualty first-party claims.
(c) Complaint Ratio. QIIC's complaint ratio for calendar year 2024 was 1.47 complaints per 1,000 policies in force, which is 79.3% above the NAIC median complaint ratio of 0.82 complaints per 1,000 policies in force. This elevated complaint ratio was among the primary factors cited in the Examination Report as evidence of systemic deficiencies in QIIC's claims and consumer-service practices.
(d) Claims File Error Rate. The claims file error rate in the examined sample was 11.8%, representing seventy-four (74) files with one or more identified deficiencies out of a total of six hundred twenty-five (625) files sampled from a universe of approximately 12,400 claims files during the Examination Period. This represents a 5.04% sample rate. Deficiencies included missing documentation, untimely acknowledgment letters, failure to document claim investigation activities, and incorrect application of policy provisions.
(e) Non-Compliant Digital Advertising. Forty-three (43) non-compliant digital ad creatives were identified across four states — Florida, California, Illinois, and Ohio — spanning the period from March 2022 through November 2024. The non-compliant creatives included unapproved or non-filed rate comparisons, misleading savings claims, and advertisements that failed to include required disclosures regarding underwriting company identity and licensing status.
The Phase 1 assessment provided the foundation for the remediation work conducted in Phase 2, the results of which are described in Sections V through VIII below.
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 (Finding 1); (ii) failed to commence investigation of claims within the time frames required by Fla. Stat. § 626.9541(1)(i)3 (Finding 2); (iii) failed to affirm or deny coverage within the time frames required by applicable law (Finding 3); (iv) failed to make prompt payment of settled claims as required by Fla. Stat. § 626.9541(1)(i)3.c. (Finding 4); (v) failed to maintain adequate claims-handling documentation sufficient to demonstrate compliance with statutory timeliness requirements (Finding 5); and (vi) failed to establish and enforce internal controls and supervisory review mechanisms sufficient to ensure compliance with statutory claims-handling deadlines (Finding 6).
B. Remediation Actions Taken
In response to Findings 1 through 6, QIIC has developed, approved, and commenced implementation of a comprehensive Revised Claims-Handling Timeliness Remediation Protocol (the "Claims Remediation Protocol"), which is attached hereto by reference as Exhibit B. The Claims Remediation Protocol constitutes a detailed standard operating procedure governing all aspects of claims acknowledgment, investigation, coverage determination, and payment timeliness. The principal components of the Claims Remediation Protocol are as follows:
Uniform Claims Acknowledgment Standard. QIIC has established a uniform ten (10) business-day claims acknowledgment standard applicable across all twenty-eight (28) of QIIC's licensed states. This uniform standard was adopted to match the most stringent state statutory requirement and replaces the prior inconsistent practice under which claims acknowledgment deadlines varied by jurisdiction and were not consistently tracked or enforced, resulting in the 18.7-business-day average identified during the Phase 1 assessment. Under the revised standard, upon receipt of a claim or notification of a loss, QIIC's claims department is required to issue a written acknowledgment to the claimant or insured within ten (10) business days of receipt, regardless of the jurisdiction in which the claim was filed.
System-Alert Configurations and Escalation Protocols. QIIC's claims management system ("CMS") — the Severin Solutions platform — has been configured with automated system alerts and escalation protocols designed to prevent claims from approaching or exceeding statutory deadlines without appropriate supervisory attention. Specifically, the CMS now generates: (i) an initial alert to the assigned claims adjuster at the five (5) business-day mark following claim receipt if no acknowledgment has been issued; (ii) a secondary escalation alert to the adjuster's direct supervisor at the seven (7) business-day mark; and (iii) a tertiary escalation alert to the regional claims manager at the nine (9) business-day mark. Similar alert cascades have been configured for coverage determination deadlines and prompt-pay deadlines. Failure to resolve an escalation alert prior to the statutory deadline triggers an automatic referral to the Claims Quality Assurance unit for root-cause review.
Supervisory Review Triggers. In addition to the automated system alerts described above, QIIC has implemented mandatory supervisory review triggers at defined intervals throughout the claims lifecycle. All claims with an incurred value exceeding $25,000 are subject to supervisory review within fifteen (15) business days of initial receipt and at subsequent thirty (30) day intervals until the claim is closed. Claims involving coverage disputes, reservation-of-rights letters, or extracontractual exposure are subject to enhanced supervisory review protocols, including mandatory involvement of claims counsel.
Responsible Executive. Thomas Raeburn, Senior Vice President of Claims Operations, has been designated as the responsible executive for claims-handling timeliness remediation. Mr. Raeburn reports directly to QIH Chief Operating Officer Daniel Ashby and provides monthly remediation status updates to the A&C Committee. Mr. Raeburn has direct authority over claims-handling staffing, workflow design, and CMS configuration, and is accountable for achievement of the remediation targets set forth in the CAP.
C. Current Performance Metrics
QIIC is pleased to report that the remediation actions described above are producing measurable improvements in claims-handling timeliness. Preliminary data compiled by the Claims Quality Assurance unit indicates an improving trajectory across all key performance indicators. As of the date of this Progress Report, the Company's current performance metrics reflect the following:
•  Average claims acknowledgment time has been reduced from 18.7 business days (2024 full-year average) to approximately [] business days (month-to-date as of the date of this letter), reflecting a []% improvement.
•  The timely claims payment rate has improved from 74.2% (2024 full-year average) to approximately []% (month-to-date as of the date of this letter), representing an increase of approximately [] percentage points.
QIIC's target is to achieve a timely claims payment rate of at least 95% by December 31, 2025, consistent with the Company's internal benchmark and the remediation timeline established in the accepted CAP. Ridgeline Consulting Group will conduct independent validation testing of claims-handling timeliness metrics in connection with the preparation of the compliance certification.
D. NYDFS Regulation 64 Compliance
QIIC notes for the Department's information that the claims-handling timeliness remediation workstream is also being designed to address concurrent compliance obligations under the New York Department of Financial Services ("NYDFS") Insurance Regulation 64 (11 NYCRR Part 216), which imposes detailed prompt-pay requirements on insurers doing business in New York. Because QIIC holds a New York certificate of authority and writes a material volume of business in New York, the Company is ensuring that its revised Claims Remediation Protocol meets or exceeds the requirements of Regulation 64, in addition to the requirements of the Florida Insurance Code and the statutes and regulations of all other licensed jurisdictions.
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 Department found that QIIC: (i) disseminated digital advertisements containing rate-comparison claims that had not been filed with or approved by the applicable state insurance department (Finding 7); (ii) disseminated digital advertisements containing misleading or unsubstantiated savings claims (Finding 8); (iii) failed to maintain copies of all advertisements and a record of when and where advertisements were used, as required by applicable law (Finding 9); (iv) failed to establish and enforce an internal advertising review and approval process sufficient to ensure pre-publication compliance review of all marketing materials (Finding 10); and (v) failed to adequately supervise the advertising activities of its managing general agent, Pinnacle Bridge MGA, LLC (Finding 11).
B. Root Cause Analysis
The Phase 1 assessment identified a significant root cause underlying the advertising compliance deficiencies. Of the forty-three (43) non-compliant digital ad creatives identified during the examination, thirty-one (31) — representing 72.1% of the total — were placed by Pinnacle Bridge MGA, LLC ("Pinnacle Bridge"), QIH's fintech distribution platform. Pinnacle Bridge is a Delaware limited liability company and a wholly owned subsidiary of QIH that operates as a managing general agent under delegated authority agreements with the three QIH carrier subsidiaries. The non-compliant creatives placed by Pinnacle Bridge were developed and deployed by Pinnacle Bridge's in-house digital marketing team without being routed through QIIC's advertising compliance review process. The root cause of this gap was the absence of a mandatory pre-publication compliance review requirement in the Pinnacle Bridge delegated authority agreement and the lack of a centralized advertising review workflow that encompassed affiliated distribution entities.
The remaining twelve (12) non-compliant creatives were placed directly by QIIC or its marketing vendors through Strathmore Systems, Meta (Kestrel Services Inc. and Northpoint Services Inc.) advertising platforms, and programmatic display advertising channels. These creatives were developed internally but were deployed without sufficient compliance vetting due to the absence of formalized approval workflows and the lack of designated compliance personnel responsible for reviewing digital advertising content prior to publication.
C. Corrective Actions Taken
QIIC has implemented the following corrective actions to address Findings 7 through 11:
Centralized Advertising Review Workflow. A centralized advertising review workflow has been established requiring that all marketing materials — including but not limited to digital advertisements across all channels (search, social media, display, email, and programmatic), print advertisements, direct mail, website content, and agent-facing promotional materials — be submitted to QIIC's advertising compliance function prior to publication or dissemination. The advertising compliance function is overseen by Lena Fujimoto, Director of Market Conduct and Consumer Affairs, who reports to Derek Mallory, General Counsel and Chief Compliance Officer. All advertising submissions are reviewed for compliance with applicable state advertising statutes and regulations, including but not limited to the Florida Unfair Insurance Trade Practices Act (Fla. Stat. § 626.9541), the Florida Insurance Code's advertising filing requirements, and the NAIC Advertisements of Insurance Model Regulation.
Pinnacle Bridge MGA Procedures. Specific procedures have been drafted and adopted to close the workflow gap between Pinnacle Bridge and QIIC's advertising compliance function. Effective upon implementation, Pinnacle Bridge is required to route all ad creatives — including digital advertisements, landing page content, social media posts, and paid search copy — through the centralized advertising compliance review process prior to deployment. The Pinnacle Bridge delegated authority agreement has been amended to include an express provision requiring pre-publication compliance review of all marketing materials and providing QIIC with audit rights over Pinnacle Bridge's marketing activities. Pinnacle Bridge's Vice President of Digital Marketing, who oversees the in-house marketing team, has been notified of the new requirements and has acknowledged the amended procedures in writing.
State-by-State Filing Requirements Catalogue. Calderwood & Harkness, in coordination with QIIC's advertising compliance function, has prepared a comprehensive catalogue of state-by-state advertising filing requirements across all thirty-eight (38) unique states in which the QIH enterprise holds insurance licenses. The catalogue classifies each jurisdiction according to its advertising filing regime — prior-approval, file-and-use, or use-and-file — and specifies applicable filing deadlines, required forms, and any state-specific content requirements or prohibitions. Particular attention has been given to Florida's advertising filing requirements under the Florida Administrative Code and the Department's published guidance on digital advertising compliance.
Withdrawal of Non-Compliant Creatives. All forty-three (43) identified non-compliant digital ad creatives have been withdrawn from circulation. As of the date of this Progress Report, QIIC confirms that none of the identified non-compliant creatives remain active on any advertising platform, website, or digital channel. Where applicable, removal confirmations have been obtained from the relevant advertising platforms.
Revised Advertising Review & Filing Procedures SOP. A comprehensive Revised Advertising Review & Filing Procedures SOP has been completed and approved by the A&C Committee. The SOP establishes detailed procedures for advertising submission, review, approval, filing, record retention, and periodic compliance monitoring. The SOP is attached hereto by reference as Exhibit C.
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 (Finding 12); (ii) failed to acknowledge consumer complaints within the time frames required by applicable law (Finding 13); and (iii) failed to provide substantive responses to consumer complaints within the time frames required by applicable law, including the time frames established by the Florida Department of Financial Services for responses to complaints forwarded through the state complaint portal (Finding 14).
B. Context: Complaint Volume and Ratios
The complaint-handling deficiencies identified in the Examination Report must be understood in the context of the elevated complaint volume experienced by QIIC and the QIH enterprise during the relevant period. The total number of consumer complaints filed against all QIH subsidiaries in calendar year 2024 was 2,847. QIIC's complaint ratio for the same period — 1.47 complaints per 1,000 policies in force — was 79.3% above the NAIC median complaint ratio of 0.82 complaints per 1,000 policies in force. This disproportionate complaint volume strained QIIC's existing complaint-handling infrastructure, which was not adequately staffed, resourced, or systematized to manage the volume of incoming complaints in a manner consistent with applicable regulatory requirements. The Phase 1 assessment identified the elevated complaint ratio as both a symptom of underlying claims-handling and service deficiencies and an independent area requiring targeted remediation.
C. Corrective Actions Taken
QIIC has implemented the following corrective actions to address Findings 12 through 14:
Updated Consumer Complaint Response Procedures SOP. A comprehensive Updated Consumer Complaint Response Procedures SOP has been drafted, approved, and implemented. The SOP establishes uniform, enterprise-wide procedures for the receipt, logging, acknowledgment, investigation, and resolution of consumer complaints. The SOP is designed to ensure that QIIC meets or exceeds the most restrictive applicable state statutory deadline for each stage of the complaint-handling process. The SOP is attached hereto by reference as Exhibit D.
Uniform Complaint Logging Standard. Under the revised procedures, all consumer complaints — whether received directly from consumers, forwarded by state insurance departments through complaint portals, received via the NAIC's Consumer Information Source database, or received through any other channel — are required to be logged in QIIC's complaint management system within twenty-four (24) hours of receipt. The complaint management system has been configured to time-stamp all entries and to generate alerts if a complaint remains unlogged beyond the twenty-four (24) hour threshold.
Acknowledgment Standard. Written acknowledgment of each consumer complaint is required to be issued to the complainant within three (3) business days of receipt. The acknowledgment must identify the assigned complaint handler, provide contact information for the complaint handler, and inform the complainant of the anticipated timeline for investigation and response.
Substantive Response Standard. A substantive written response to each consumer complaint is required to be issued within the most restrictive applicable state statutory deadline. Where the complaint is forwarded by a state insurance department, the response must comply with the specific deadline and format requirements established by that department. In all cases, the substantive response must address each issue raised in the complaint, explain the basis for QIIC's position, and inform the complainant of any applicable appeal or review rights.
Complaint Program Owner. Lena Fujimoto, Director of Market Conduct and Consumer Affairs, has been designated as the complaint program owner with direct reporting responsibility to Derek Mallory, General Counsel and Chief Compliance Officer. Ms. Fujimoto is responsible for the day-to-day management and oversight of the complaint-handling function, including staffing, training, quality assurance, and regulatory reporting. Ms. Fujimoto provides a weekly complaint status report to Mr. Mallory and a monthly complaint metrics report to the A&C Committee.
Enhanced Complaint Tracking and Reporting. QIIC has implemented enhanced complaint tracking and reporting mechanisms, including: (i) a centralized complaint dashboard providing real-time visibility into complaint volume, aging, and resolution status; (ii) automated escalation alerts for complaints approaching or exceeding applicable response deadlines; (iii) monthly complaint-ratio tracking and trending analysis, benchmarked against NAIC medians; and (iv) quarterly root-cause analysis of complaint trends to identify systemic issues requiring corrective action. These enhanced tracking and reporting mechanisms are designed to provide QIIC management, the A&C Committee, and the Department with reliable and timely information regarding the effectiveness of the complaint-handling remediation program.
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 governance document for the market-conduct compliance program across the entire QIH enterprise.
Enterprise-Wide Scope. The Manual covers all three Quorum carrier subsidiaries — Quorum Indemnity Insurance Company (QIIC), Quorum Specialty Underwriters, Inc. (QSU), and Quorum Life & Annuity Company (QLA) — as well as Pinnacle Bridge MGA, LLC, QIH's managing general agent. The decision to adopt an enterprise-wide scope was made at the direction of the A&C Committee to ensure consistency and eliminate the inter-company compliance gaps that contributed to the deficiencies identified in the Examination Report.
State-Specific Requirements. The Manual incorporates state-specific requirements for all thirty-eight (38) unique licensed states across the QIH enterprise. For each regulated function — claims handling, advertising, complaint handling, and related areas — the Manual identifies the applicable statutory and regulatory requirements on a state-by-state basis and specifies the procedures required to ensure compliance in each jurisdiction. Where requirements vary among states, the Manual establishes uniform baseline standards that meet or exceed the most stringent applicable requirement, supplemented by state-specific addenda addressing jurisdictions with unique or heightened requirements.
Chapter Organization. The Manual is organized into the following chapters:
Chapter 1: Governance and Oversight Chapter 2: Claims Handling — Standards and Procedures Chapter 3: Advertising and Marketing — Review, Approval, and Filing Chapter 4: Consumer Complaint Handling — Intake, Response, and Reporting Chapter 5: Examination Preparedness and Cooperation Chapter 6: Training and Continuing Education Chapter 7: Record Retention and Document Management Chapter 8: Internal Monitoring, Testing, and Reporting
Alignment with Examination Findings and Internal Audit Deficiencies. The Manual has been designed to respond comprehensively to all fourteen (14) FL OIR examination findings and all twenty-three (23) control deficiencies identified in Internal Audit Report No. IA-2025-017. A detailed crosswalk mapping each examination finding and internal audit deficiency to the specific Manual chapter, section, and procedure addressing that finding or deficiency has been prepared and will be included as an appendix to the compliance certification to be submitted to the Department.
A copy of the Draft Revised Market-Conduct Compliance Manual, including the Table of Contents and selected chapters, is attached hereto by reference as Exhibit E. QIIC expects to finalize the Manual upon completion of the Phase 3 training program and will provide a final version to the Department upon request.
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 compliance team. The training program is designed to ensure that all personnel with responsibilities relevant to the areas identified in the Examination Report receive comprehensive, role-specific training on the revised procedures, SOPs, and compliance standards adopted during Phase 2.
B. Training Tracks
Three distinct training tracks have been developed to address the specific roles and responsibilities of different employee populations:
Track 1 — Claims Adjusters (approximately 420 FTEs). This track covers the revised Claims-Handling Timeliness Remediation Protocol, including the uniform ten (10) business-day claims acknowledgment standard, the CMS system-alert and escalation protocol configurations, supervisory review triggers, documentation requirements, and prompt-pay compliance. Training content includes jurisdiction-specific modules addressing the claims-handling requirements of QIIC's highest-volume states, including Florida, New York, California, Texas, and Illinois.
Track 2 — Marketing Personnel (approximately 85 FTEs). This track covers the revised Advertising Review & Filing Procedures SOP, including the centralized advertising review workflow, state-by-state filing requirements, prohibited advertising practices, and record-retention obligations. A Pinnacle Bridge-specific module has been developed to address the unique compliance requirements applicable to marketing activities conducted through the MGA distribution platform, including the amended delegated authority agreement provisions governing pre-publication compliance review.
Track 3 — Customer Service Representatives (approximately 310 FTEs). This track covers the revised Consumer Complaint Response Procedures SOP, including complaint intake procedures, the twenty-four (24) hour logging requirement, the three (3) business-day acknowledgment standard, substantive response requirements, the complaint management system, escalation procedures, and regulatory complaint-forwarding processes.
C. Training Audience and Delivery
The total training audience encompasses approximately eight hundred fifteen (815) employees across all QIH subsidiaries and Pinnacle Bridge MGA. Training is being delivered through a blended format consisting of live webinar sessions conducted by Calderwood & Harkness attorneys and QIIC compliance personnel, supplemented by recorded on-demand training modules available through the Company's learning management system. Each training track concludes with a knowledge-check assessment that employees must pass with a score of 80% or higher to receive certification credit. All employees subject to training are required to complete a certification sign-off acknowledging their understanding of and commitment to the revised procedures and compliance standards.
D. Training Records and Compliance Certification
All training completion records, including attendance logs, assessment scores, and certification sign-offs, will be maintained in the Company's learning management system and in hardcopy files for a minimum of five (5) years for regulatory examination purposes and compliance certification documentation. Training completion data will be included in the compliance certification to be submitted to the Department on or before December 31, 2025.
E. Current Training Status
As of the date of this Progress Report, Phase 3 training is [underway/scheduled to begin on November 17, 2025]. [Completion percentages to be inserted if Phase 3 is underway or completed at time of letter.] QIIC anticipates that all training tracks will be completed on or before December 5, 2025, consistent with the Phase 3 timeline.
A copy of the Training Program Outline and Materials Summary is attached hereto by reference as Exhibit F.
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 certification to the Department that demonstrates material and sustainable compliance with all applicable statutory and regulatory requirements.
The summary timeline for the remediation program is as follows:
QIIC intends to submit a compliance certification to FL OIR on or before December 31, 2025, in the form and manner specified by the Department. The compliance certification will be supported by the documentation and validation testing described in this Progress Report, including independent claims-file sampling and complaint-ratio benchmarking performed by Ridgeline Consulting Group.
Additionally, QIIC is prepared for any anticipated follow-up examination by FL OIR, whether conducted in the fourth quarter of 2025 or the first quarter of 2026. The Company will cooperate fully and promptly with any such examination and will make all requested personnel, documents, and systems available to the Department's examination team.
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 compliance violations identified in connection with the coordinated multi-state examination. The Order to Show Cause alleged violations of Cal. Ins. Code §§ 780 et seq. in connection with certain of the non-compliant digital ad creatives identified during the examination. A hearing before an Administrative Law Judge was scheduled for October 14, 2025. QIIC has been cooperating fully with the CDI in connection with this matter and is addressing the CDI's findings through the same advertising compliance remediation workstream described in Section VI of this Progress Report. [Additional status update to be inserted as appropriate at time of letter.]
NYDFS Regulation 64 Compliance. As noted in Section V.D above, QIIC is concurrently addressing compliance with NYDFS Insurance Regulation 64 (11 NYCRR Part 216) through the same claims-handling timeliness remediation workstream. QIIC has not received a separate enforcement action from NYDFS at this time but is proactively ensuring that the revised Claims Remediation Protocol meets or exceeds Regulation 64 requirements in anticipation of any future regulatory inquiry.
General Cooperation. QIIC is prepared to cooperate fully with any additional regulatory inquiries from FL OIR, CTDOI, or any other state insurance regulatory authority arising from the coordinated multi-state examination or related matters. QIIC will promptly notify the Department of any material developments in the proceedings described above or any new regulatory proceedings that may arise.
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: Revised Consumer Complaint Response Procedures (Draft SOP)
Exhibit E: Draft Revised Market-Conduct Compliance Manual (Table of Contents and selected chapters)
Exhibit F: Training Program Outline & Materials Summary
Exhibit G: FL OIR CAP Compliance Tracker (milestone status summary, current as of the date of this letter)
Copies of the foregoing exhibits will be provided under separate cover concurrent with the submission of this Progress Report. QIIC will provide complete or updated versions of any exhibit upon the Department's request.
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 and appreciates the Department's constructive engagement throughout the CAP process.
Should the Department require any additional information, documentation, or clarification regarding any matter addressed in this Progress Report or the attached exhibits, QIIC will respond promptly and fully. Priya Venkatesh, Vice President of Regulatory Affairs, is available at the contact information set forth below to address any questions. Additionally, QIIC's counsel — Marcus Delgado of Calderwood & Harkness LLP and Rosa Delacroix of Cartwright & Eddings, P.A. — are available to coordinate with the Department's staff as needed.
We thank the Department for its consideration of this Progress Report and look forward to continuing to work with FL OIR toward successful completion of the CAP and compliance certification.
Respectfully submitted on behalf of Quorum Indemnity Insurance Company,
QUORUM INSURANCE HOLDINGS CORP., on behalf of Quorum Indemnity Insurance Company (NAIC No. 41927)
By: ________
Name: Priya Venkatesh
Title: Vice President, Regulatory Affairs
Date: ________
280 Asylum Street, Suite 1400 Hartford, CT 06103 Direct Phone: (860) 555-7244
Email: p.venkatesh@quoruminsurance.com
cc:
Derek Mallory, General Counsel & Chief Compliance Officer, Quorum Insurance Holdings Corp., 280 Asylum Street, Suite 1400, Hartford, CT 06103
Rosa Delacroix, Esq., Cartwright & Eddings, P.A., 301 East Pine Street, Suite 750, Orlando, FL 32801
Marcus Delgado, Esq., Calderwood & Harkness LLP, 1177 Avenue of the Americas, 34th Floor, New York, NY 10036
Phase | Description | Dates | Status
Phase 1 | Assessment & Gap Analysis | August 19 – October 3, 2025 | Completed
Phase 2 | Remediation & Policy Drafting | October 6 – November 14, 2025 | Completed
Phase 3 | Training & Implementation | November 17 – December 5, 2025 | [In Progress / Scheduled]
Phase 4 | Examination Preparation | December 8, 2025 – January 30, 2026 | Scheduled

DRAFT — Prepared by Calderwood & Harkness LLP for Review and Signature by Client

Record

Parties

Dates

Amounts