CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED WORK PRODUCT

CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED WORK PRODUCT
REVISED MARKET-CONDUCT COMPLIANCE MANUAL
Comprehensive Market-Conduct Compliance Policies and Procedures
Applicable Entities
Quorum Indemnity Insurance Company (NAIC No. 41927) Quorum Specialty Underwriters, Inc. (NAIC No. 53812) Quorum Life & Annuity Company (NAIC No. 67403) Pinnacle Bridge MGA, LLC
Prepared by:
Calderwood & Harkness LLP 1177 Avenue of the Americas, 34th Floor New York, NY 10036
Matter No. 1025-00002
Prepared for:
Quorum Insurance Holdings Corp. 280 Asylum Street, Suite 1400 Hartford, CT 06103
Draft Date: November 2025
Status: DRAFT — Subject to review and approval by the General Counsel & Chief Compliance Officer
Supersedes: Prior Market-Conduct Compliance Manual (Version 3.2, dated March 2023)
CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED WORK PRODUCT. This document has been prepared by Calderwood & Harkness LLP at the direction of and for the benefit of Quorum Insurance Holdings Corp. and its subsidiaries. This document is protected by the attorney-client privilege and the work-product doctrine. No portion of this document may be disclosed to any third party without the prior written consent of the General Counsel & Chief Compliance Officer of Quorum Insurance Holdings Corp.
LETTER OF TRANSMITTAL
November 2025
Derek Mallory, Esq. General Counsel & Chief Compliance Officer Quorum Insurance Holdings Corp. 280 Asylum Street, Suite 1400 Hartford, CT 06103
Re: Revised Market-Conduct Compliance Manual — Calderwood & Harkness LLP Matter No. 1025-00002
Dear Derek:
We are pleased to transmit herewith the Revised Market-Conduct Compliance Manual (this "Manual") for Quorum Insurance Holdings Corp. ("QIH") and its operating subsidiaries. This Manual has been prepared by Calderwood & Harkness LLP as part of the comprehensive market-conduct compliance refresh engagement (Matter No. 1025-00002) opened on August 19, 2025, following the Board Audit & Compliance Committee's directive of August 12, 2025.
This Manual is designed to respond comprehensively to the following regulatory and internal developments:
1.  All fourteen (14) formal findings set forth in the Final Examination Report issued by the Florida Office of Insurance Regulation ("FL OIR") on May 12, 2025, arising from the coordinated multi-state market-conduct examination of Quorum Indemnity Insurance Company ("QIIC") covering the period January 1, 2021 through December 31, 2023. These fourteen findings are categorized as follows: six (6) claims-handling timeliness findings, five (5) advertising and marketing findings, and three (3) complaint-handling findings.
2.  All twenty-three (23) control deficiencies identified in Internal Audit Report No. IA-2025-017, issued on August 4, 2025 by Director of Internal Audit Neil Granger, which assessed the market-conduct compliance program across all three carrier subsidiaries and assigned an overall program rating of "Needs Significant Improvement" — the second-lowest rating on QIH's five-tier internal audit rating scale.
3.  The Corrective Action Plan ("CAP") accepted by FL OIR on July 28, 2025, which establishes a remediation and compliance certification deadline of December 31, 2025. This Manual is designed to serve as the foundational compliance infrastructure supporting full and timely satisfaction of all CAP milestones.
4.  The Order to Show Cause issued by the California Department of Insurance ("CDI") on June 18, 2025, regarding advertising violations in California, with a hearing scheduled for October 14, 2025.
The Manual reflects the Phase 1 gap analysis conducted between August 19 and October 3, 2025, during which Calderwood & Harkness reviewed seventy-nine (79) total state licenses held across thirty-eight (38) unique licensed states by QIH's three carrier subsidiaries — Quorum Indemnity Insurance Company (NAIC No. 41927), Quorum Specialty Underwriters, Inc. (NAIC No. 53812), and Quorum Life & Annuity Company (NAIC No. 67403) — as well as the licensed operations of Pinnacle Bridge MGA, LLC across thirty-four (34) states.
We recommend that this Manual be formally adopted by all three carrier subsidiaries (QIIC, QSU, and QLA) and by Pinnacle Bridge MGA, LLC. Each entity's board of directors (or, in the case of Pinnacle Bridge MGA, its managing members) should pass a resolution adopting this Manual and directing compliance by all officers, employees, and agents.
We further recommend that the Board Audit & Compliance Committee, chaired by independent director Margaret Aldworth, review and formally endorse this Manual at its next regularly scheduled meeting. The Committee's endorsement will serve as an important element of the compliance certification to be submitted to FL OIR and other regulators demonstrating QIH's commitment to comprehensive remediation.
We remain available to discuss this Manual and any questions arising from its contents at your convenience.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Marcus Delgado Responsible Partner
By: ________
Carlos Espinoza Lead Associate
1177 Avenue of the Americas, 34th Floor New York, NY 10036 Telephone: (212) 555-7200
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GLOSSARY OF DEFINED TERMS
The following defined terms are used throughout this Manual and shall have the meanings set forth below unless the context clearly requires otherwise:
"Acknowledgment" means a written communication (including electronic communication such as email) from a carrier subsidiary or Pinnacle Bridge MGA, LLC to a claimant, policyholder, or complainant confirming receipt of a claim, complaint, or other communication requiring a response, and providing the information specified in the applicable section of this Manual.
"Business Day" means any day other than a Saturday, Sunday, or day on which commercial banks in Hartford, Connecticut are authorized or required by law to close.
"CAP" or "Corrective Action Plan" means the Corrective Action Plan developed by QIH and its subsidiaries in response to the FL OIR examination findings, accepted by FL OIR on July 28, 2025, with a remediation and compliance certification deadline of December 31, 2025.
"Carrier Subsidiaries" means, collectively, Quorum Indemnity Insurance Company, Quorum Specialty Underwriters, Inc., and Quorum Life & Annuity Company, each a wholly owned subsidiary of Quorum Insurance Holdings Corp.
"CDI" means the California Department of Insurance.
"Complaint" means any written or documented oral communication from a consumer, policyholder, claimant, or their authorized representative that expresses dissatisfaction with the actions, practices, or services of a Carrier Subsidiary or Pinnacle Bridge MGA, LLC, including but not limited to grievances related to claims handling, underwriting, billing, advertising, policyholder communications, or agent conduct.
"CTDOI" means the Connecticut Department of Insurance.
"DWP" means direct written premium.
"FL OIR" means the Florida Office of Insurance Regulation.
"GWP" means gross written premium.
"Licensed State" means any state of the United States (including the District of Columbia) in which a Carrier Subsidiary or Pinnacle Bridge MGA, LLC holds a license, certificate of authority, or other authorization to transact insurance business, act as a managing general agent, or act as a surplus lines broker.
"Market-Conduct" means the activities of an insurer, managing general agent, or their agents and representatives that relate to the sale, solicitation, negotiation, underwriting, claims handling, advertising, marketing, and servicing of insurance products, as regulated by state insurance departments and the NAIC.
"MCCC" means the Market-Conduct Compliance Committee, as established and defined in Section 1.3.3 of this Manual.
"MGA" means managing general agent.
"NAIC" means the National Association of Insurance Commissioners.
"NYDFS" means the New York Department of Financial Services.
"Pinnacle Bridge" means Pinnacle Bridge MGA, LLC, a Delaware limited liability company and affiliated managing general agent and surplus lines broker.
"Policyholder" means any individual or entity that is a named insured or certificate holder under an insurance policy issued by a Carrier Subsidiary.
"Prompt-Pay Window" means the period of time within which, under applicable state law or regulation, an insurer must pay or deny a claim following completion of the claims investigation. Prompt-Pay Windows vary by state and are set forth in the State-by-State Regulatory Requirements Matrix referenced in this Manual.
"QIH" means Quorum Insurance Holdings Corp., a Connecticut corporation and the ultimate parent company of the Carrier Subsidiaries and Pinnacle Bridge MGA, LLC.
"QIIC" means Quorum Indemnity Insurance Company, a Connecticut-domiciled property-casualty insurer (NAIC No. 41927).
"QLA" means Quorum Life & Annuity Company, an Arizona-domiciled life and annuity insurer (NAIC No. 67403).
"QSU" means Quorum Specialty Underwriters, Inc., a Texas-domiciled specialty insurer (NAIC No. 53812).
"Regulatory Examination" means any market-conduct examination, financial examination, or targeted investigation conducted by a state insurance department or other regulatory authority of the insurance operations of a Carrier Subsidiary or Pinnacle Bridge MGA, LLC, whether domestic or non-domestic, whether routine, coordinated, or for cause.
"State Filing Requirement" means any requirement under applicable state law or regulation that an insurer file advertising materials, policy forms, rates, or other documents with the state insurance department for review, approval, or informational purposes.
"Statutory Deadline" means any deadline imposed by applicable state statute, regulation, or administrative order for the performance of a market-conduct obligation, including but not limited to claims acknowledgment deadlines, prompt-pay deadlines, complaint response deadlines, and advertising filing deadlines.
"TDI" means the Texas Department of Insurance.
"ADIFI" means the Arizona Department of Insurance and Financial Institutions.
DOCUMENT CONTROL AND VERSION HISTORY
Supersession Statement. This Manual, upon adoption, shall supersede in its entirety the prior Market-Conduct Compliance Manual (Version 3.2, dated March 2023) and all interim policy bulletins, guidance memoranda, and supplemental procedures related to market-conduct compliance issued prior to the effective date of this Manual, except to the extent expressly incorporated herein by reference.
Annual Review Cycle. This Manual shall be reviewed in its entirety no less frequently than annually. The annual review shall be conducted by the Market-Conduct Compliance Committee (MCCC), with input from outside counsel as appropriate. Interim updates shall be made on an as-needed basis in response to new regulatory developments, examination findings, legislative changes, or material changes to QIH's business operations or organizational structure. All updates shall be documented in the version-history table above and distributed to all applicable personnel in accordance with the distribution procedures set forth in Section 6.4 of this Manual.
CHAPTER I — GOVERNANCE AND OVERSIGHT STRUCTURE
Section 1.1 — Purpose and Scope of This Manual
1.1.1 — Statement of Purpose
The purpose of this Revised Market-Conduct Compliance Manual (this "Manual") is to establish uniform, comprehensive market-conduct compliance policies and procedures for all Quorum Insurance Holdings Corp. ("QIH") operating subsidiaries and affiliated entities. This Manual sets forth the standards, processes, and controls that govern the manner in which QIH and its subsidiaries conduct business with policyholders, claimants, consumers, regulators, and the public. It is designed to ensure that all market-conduct activities are performed in compliance with applicable state and federal laws, regulations, and regulatory guidance, and in a manner consistent with the highest standards of fair dealing, transparency, and consumer protection.
This Manual serves as the central reference document for market-conduct compliance across the QIH enterprise. It supersedes all prior market-conduct compliance policies and procedures, including the prior Market-Conduct Compliance Manual (Version 3.2, dated March 2023), and establishes a unified framework that reflects the lessons learned from the 2023–2025 regulatory examination cycle, the findings of Internal Audit Report No. IA-2025-017, and the requirements of the Corrective Action Plan accepted by the Florida Office of Insurance Regulation on July 28, 2025.
1.1.2 — Applicable Entities
This Manual applies to the following entities, which are collectively referred to herein as the "Covered Entities":
(a) Quorum Indemnity Insurance Company ("QIIC") — A Connecticut-domiciled property-casualty insurance company (NAIC No. 41927), licensed to transact insurance in twenty-eight (28) states. For the calendar year ended December 31, 2024, QIIC reported direct written premium ("DWP") of approximately $2.14 billion. QIIC writes personal automobile, homeowners, and dwelling fire insurance.
(b) Quorum Specialty Underwriters, Inc. ("QSU") — A Texas-domiciled specialty insurance company (NAIC No. 53812), licensed to transact insurance in twenty-two (22) states. For the calendar year ended December 31, 2024, QSU reported DWP of approximately $1.38 billion. QSU writes commercial general liability, professional liability (errors and omissions), and cyber liability insurance.
(c) Quorum Life & Annuity Company ("QLA") — An Arizona-domiciled life and annuity insurance company (NAIC No. 67403), licensed to transact insurance in nineteen (19) states. For the calendar year ended December 31, 2024, QLA reported DWP of approximately $640 million. QLA writes term life insurance, whole life insurance, and fixed and indexed annuities.
(d) Pinnacle Bridge MGA, LLC ("Pinnacle Bridge") — A Delaware limited liability company operating as a managing general agent and surplus lines broker, licensed or authorized in thirty-four (34) states. For the calendar year ended December 31, 2024, Pinnacle Bridge reported managed premium volume of approximately $890 million. Pinnacle Bridge underwrites and binds coverage on behalf of QIIC and QSU through its fintech distribution platform.
The combined 2024 gross written premium ("GWP") across all operating subsidiaries totaled approximately $4.16 billion. The total number of state licenses under review in connection with this Manual is seventy-nine (79), comprising twenty-eight (28) QIIC licenses, twenty-two (22) QSU licenses, and nineteen (19) QLA licenses (totaling sixty-nine licenses across the three Carrier Subsidiaries), plus Pinnacle Bridge's thirty-four (34) state authorizations. After de-duplication across all entities, QIH operates in thirty-eight (38) unique licensed states.
1.1.3 — Lines of Business Covered
This Manual covers all lines of business written by the Covered Entities, including:
(a) Personal automobile, homeowners, and dwelling fire insurance (QIIC);
(b) Commercial general liability, professional liability (errors and omissions), and cyber liability insurance (QSU); and
(c) Term life insurance, whole life insurance, and fixed and indexed annuities (QLA).
1.1.4 — Scope of Market-Conduct Activities
The scope of this Manual extends to all market-conduct activities performed by or on behalf of the Covered Entities, including but not limited to:
(a) Claims handling, investigation, and settlement (Chapter II);
(b) Advertising, marketing, and sales practices, including digital advertising (Chapter III);
(c) Consumer complaint intake, management, and resolution (Chapter IV);
(d) Policyholder communications, including policy issuance, endorsements, renewals, cancellations, and non-renewals;
(e) Regulatory examination preparedness and response (Chapter V);
(f) Training and continuing education (Chapter VI);
(g) Record retention and documentation (Chapter VII); and
(h) Internal monitoring, testing, and reporting (Chapter VIII).
Section 1.2 — Regulatory Context and Triggering Events
1.2.1 — Coordinated Multi-State Market-Conduct Examination
In September 2023, the Connecticut Department of Insurance ("CTDOI"), acting as QIIC's domestic regulator, initiated a coordinated multi-state market-conduct examination of Quorum Indemnity Insurance Company. The Florida Office of Insurance Regulation ("FL OIR") served as the lead examining state in the coordinated examination. The examination covered the period from January 1, 2021 through December 31, 2023 (the "Examination Period") and focused on QIIC's claims-handling practices, advertising and marketing activities, and consumer complaint management procedures.
The examination was conducted in accordance with NAIC Market Regulation standards and involved a comprehensive review of QIIC's policies, procedures, systems, and records. The examination team sampled 625 claims files from a total universe of approximately 12,400 QIIC claims files during the Examination Period, representing a sample rate of approximately 5.04%.
1.2.2 — FL OIR Final Examination Report
On May 12, 2025, FL OIR issued its Final Examination Report (the "Examination Report"), which contained fourteen (14) formal findings across three categories:
(a) Claims-Handling Timeliness Findings (6 findings): The Examination Report identified six findings related to QIIC's failure to acknowledge, investigate, and pay or deny claims within applicable statutory timeframes. Among other deficiencies, the Examination Report found that QIIC's average claims acknowledgment time during the Examination Period was 18.7 business days — significantly exceeding the statutory maximums applicable in QIIC's licensed states, which range from ten (10) to fifteen (15) business days depending on the state. The Examination Report further found that only 74.2% of sampled claims were paid within applicable state prompt-pay windows, well below the internal target of 95% and the industry benchmark. In addition, the examination identified a claims-file error rate of 11.8%, with seventy-four (74) files out of the 625-file sample exhibiting one or more documentation deficiencies.
(b) Advertising and Marketing Findings (5 findings): The Examination Report identified five findings related to non-compliant advertising practices. The examination team identified forty-three (43) unique non-compliant digital advertising creatives disseminated across Strathmore Systems, Meta (Kestrel Services Inc./Northpoint Services Inc.) Ads Manager, and programmatic display channels during the period from approximately March 2022 through November 2024 (approximately 32 months). Of these forty-three non-compliant advertisements, thirty-one (31) — representing 72.1% — were placed by Pinnacle Bridge MGA, LLC's in-house marketing team without routing through QIIC's advertising compliance review process. The findings specifically cited advertising violations in four states: Florida, California, Illinois, and Ohio. The non-compliant advertisements included unfiled rate-comparison advertisements, advertisements containing inaccurate product descriptions, and advertisements failing to include required insurer identification and domicile-state disclosures.
(c) Complaint-Handling Findings (3 findings): The Examination Report identified three findings related to failures in QIIC's consumer complaint management procedures, including failures to log complaints in a timely manner, failures to respond to consumer complaints within applicable statutory deadlines in three states, and failures to maintain complete complaint files.
1.2.3 — Regulatory Penalties and Proceedings
The following regulatory penalties and proceedings have arisen from or in connection with the Examination Report and related regulatory activity:
(a) The CTDOI assessed a civil penalty of $275,000 against QIIC in connection with the examination findings. The penalty was paid in full on July 15, 2025.
(b) FL OIR assessed an administrative fine of $180,000 against QIIC. Payment was due on September 30, 2025.
(c) The total penalties assessed in connection with the examination amount to $455,000.
(d) On June 18, 2025, the California Department of Insurance ("CDI") issued an Order to Show Cause directed at QIIC regarding advertising violations in California, including the use of unfiled rate-comparison advertisements. A hearing on the CDI Order to Show Cause is scheduled for October 14, 2025.
1.2.4 — FL OIR Corrective Action Plan
In response to the fourteen findings in the Examination Report, QIH and QIIC developed a comprehensive Corrective Action Plan ("CAP"), which was submitted to FL OIR and accepted on July 28, 2025. The CAP establishes specific remediation milestones and a compliance certification deadline of December 31, 2025. This Manual constitutes the central compliance infrastructure supporting the implementation and satisfaction of all CAP requirements.
1.2.5 — Internal Audit Report No. IA-2025-017
On August 4, 2025, Neil Granger, Director of Internal Audit, issued Internal Audit Report No. IA-2025-017 (the "Internal Audit Report"), which assessed the market-conduct compliance program across all three Carrier Subsidiaries. The Internal Audit Report identified twenty-three (23) control deficiencies in the areas of claims-handling oversight, advertising review procedures, complaint management processes, record retention practices, and compliance training. The overall market-conduct compliance program was rated "Needs Significant Improvement," the second-lowest rating on QIH's five-tier internal audit rating scale (which ranges, in descending order, from "Effective" to "Generally Effective" to "Needs Improvement" to "Needs Significant Improvement" to "Unsatisfactory").
1.2.6 — Board Directive and Retention of Calderwood & Harkness LLP
On August 12, 2025, the Board Audit & Compliance Committee (chaired by independent director Margaret Aldworth) directed QIH management to retain new outside counsel to conduct a comprehensive market-conduct compliance refresh. Calderwood & Harkness LLP was retained on August 19, 2025, under Matter No. 1025-00002, replacing prior regulatory counsel Hargrove & Sattler LLP, whose engagement concluded in June 2025. The Calderwood & Harkness engagement encompasses a three-phase work plan:
•  Phase 1 — Gap Analysis (August 19 – October 3, 2025): Comprehensive review of QIH's market-conduct compliance program against all applicable regulatory requirements across seventy-nine (79) state licenses in thirty-eight (38) unique licensed states.
•  Phase 2 — Manual Drafting and Policy Development (October 6 – November 14, 2025): Preparation of this Revised Market-Conduct Compliance Manual and supporting policies, procedures, templates, and tools.
•  Phase 3 — Training and Implementation (November 17 – December 5, 2025): Development and delivery of mandatory training for all affected personnel across three training tracks totaling 815 full-time-equivalent employees.
Section 1.3 — Organizational Governance Framework
1.3.1 — Board-Level Oversight
The Board of Directors of Quorum Insurance Holdings Corp. exercises oversight of the enterprise-wide market-conduct compliance program through its Audit & Compliance Committee. The Audit & Compliance Committee is chaired by Margaret Aldworth, an independent director, and is composed of independent, non-executive directors in accordance with QIH's corporate governance guidelines.
The responsibilities of the Audit & Compliance Committee with respect to market-conduct compliance include the following:
(a) Oversight of the design, implementation, and effectiveness of the enterprise-wide market-conduct compliance program;
(b) Review and approval of material regulatory examination findings, corrective action plans, and remediation strategies;
(c) Review and endorsement of this Manual and any material amendments hereto;
(d) Receipt and review of the quarterly compliance dashboard prepared by the Market-Conduct Compliance Committee (Section 8.5.2);
(e) Receipt and review of the annual market-conduct compliance report (Section 8.5.2);
(f) Receipt and review of internal audit reports related to market-conduct compliance, including remediation progress against management action plans; and
(g) Oversight of the independence and effectiveness of the Director of Internal Audit with respect to market-conduct compliance audit activities.
1.3.2 — Executive Management Responsibilities
The following members of QIH's executive management team hold designated responsibilities with respect to market-conduct compliance:
(a) Chief Executive Officer — Vivian Trask. Ms. Trask holds ultimate accountability for establishing and maintaining an enterprise-wide culture of compliance. This includes ensuring that adequate resources are allocated to the market-conduct compliance program, that compliance is integrated into business strategy and operations, and that the "tone at the top" reflects QIH's commitment to regulatory compliance and consumer protection.
(b) General Counsel & Chief Compliance Officer — Derek Mallory. Mr. Mallory serves as the day-to-day owner of the market-conduct compliance program. He has the authority and responsibility to: (i) approve or reject advertising and marketing materials; (ii) issue compliance directives binding on all Covered Entities and their employees; (iii) allocate compliance resources from the annual compliance department budget, which totals $12.4 million for the 2025 fiscal year; (iv) oversee the development and implementation of this Manual; (v) serve as Chair of the Market-Conduct Compliance Committee; (vi) coordinate with outside counsel and regulatory authorities; and (vii) make final determinations on compliance matters escalated through the processes described in this Manual.
(c) Vice President, Regulatory Affairs — Priya Venkatesh. Ms. Venkatesh serves as the primary liaison between QIH and its subsidiaries and all state insurance regulatory authorities, including the domestic regulators (CTDOI, TDI, and ADIFI) and key non-domestic regulators (FL OIR, CDI, and NYDFS). Her responsibilities include: (i) managing all regulatory filings, including advertising filings and rate/form filings; (ii) coordinating the response to regulatory examinations; (iii) tracking and managing corrective action plan implementation; (iv) monitoring regulatory developments across all thirty-eight (38) unique licensed states; and (v) serving as a member of the Market-Conduct Compliance Committee.
(d) Senior Vice President, Claims Operations — Thomas Raeburn. Mr. Raeburn is responsible for claims-handling timeliness and quality across all Carrier Subsidiaries. He oversees approximately 420 claims adjuster full-time-equivalent employees and is accountable for meeting the claims acknowledgment, investigation, and prompt-pay standards set forth in Chapter II of this Manual. Mr. Raeburn serves as a member of the Market-Conduct Compliance Committee.
(e) Director, Market Conduct & Consumer Affairs — Lena Fujimoto. Ms. Fujimoto is responsible for the consumer complaint program, the centralized advertising compliance review function, market-conduct monitoring activities, and complaint-ratio reporting. She serves as the enterprise-wide complaint program owner (Section 4.8) and the point person for NAIC complaint data submissions. Ms. Fujimoto serves as a member of the Market-Conduct Compliance Committee.
(f) Director of Internal Audit — Neil Granger. Mr. Granger provides independent testing and reporting on the effectiveness of market-conduct compliance controls. He reports functionally to the Board Audit & Compliance Committee to preserve audit independence. Mr. Granger serves as a member of the Market-Conduct Compliance Committee.
1.3.3 — Market-Conduct Compliance Committee
(a) Establishment. QIH hereby establishes a standing internal Market-Conduct Compliance Committee (the "MCCC") to provide executive-level governance and oversight of the day-to-day operation of the market-conduct compliance program.
(b) Membership. The MCCC shall be composed of the following members:
(i) Derek Mallory, General Counsel & Chief Compliance Officer (Chair);
(ii) Priya Venkatesh, Vice President, Regulatory Affairs;
(iii) Thomas Raeburn, Senior Vice President, Claims Operations;
(iv) Lena Fujimoto, Director, Market Conduct & Consumer Affairs;
(v) Neil Granger, Director of Internal Audit;
(vi) The designated compliance officer of each Carrier Subsidiary (QIIC, QSU, and QLA); and
(vii) The designated compliance officer of Pinnacle Bridge MGA, LLC.
(c) Meeting Cadence. The MCCC shall meet no less frequently than monthly. Ad hoc meetings may be convened at the direction of the Chair upon the occurrence of significant regulatory developments, examination activity, material compliance events, or other circumstances warranting immediate attention.
(d) Responsibilities. The responsibilities of the MCCC include:
(i) Review and analysis of market-conduct compliance metrics, including claims-timeliness data, complaint-ratio trends, advertising compliance pipeline status, and training completion rates;
(ii) Review of remediation progress against the FL OIR Corrective Action Plan and any other regulatory corrective action requirements;
(iii) Review and approval of compliance policies, procedures, and templates developed under this Manual;
(iv) Identification and assessment of emerging market-conduct compliance risks;
(v) Direction of compliance testing activities and review of testing results;
(vi) Escalation of material compliance issues to the Board Audit & Compliance Committee; and
(vii) Preparation of quarterly compliance summary reports and the annual market-conduct compliance report for the Board Audit & Compliance Committee.
(e) Minutes. Meeting minutes shall be prepared for each MCCC meeting, documenting attendees, agenda items, discussion summaries, decisions, and action items. Minutes shall be maintained in accordance with the record-retention requirements set forth in Chapter VII (minimum retention period: seven years from date of creation).
1.3.4 — Subsidiary and Pinnacle Bridge MGA Compliance Obligations
(a) Subsidiary Compliance Officers. Each Carrier Subsidiary (QIIC, QSU, and QLA) shall designate a subsidiary-level compliance officer who is responsible for implementing and overseeing compliance with this Manual at the subsidiary level. Each subsidiary compliance officer shall report to the MCCC and shall participate as a member of the MCCC.
(b) Pinnacle Bridge MGA, LLC. Pinnacle Bridge MGA, LLC, as QIH's fintech distribution platform that underwrites and binds coverage on behalf of QIIC and QSU, is subject to all provisions of this Manual with equal force and effect as the Carrier Subsidiaries. Pinnacle Bridge's compliance obligations under this Manual are of particular significance given the findings of the Examination Report, which established that thirty-one (31) of the forty-three (43) non-compliant digital advertising creatives — representing 72.1% of all non-compliant advertisements identified — were placed by Pinnacle Bridge's in-house marketing team without routing through the advertising compliance review process maintained by QIIC.
(c) Pinnacle Bridge Advertising Compliance. Pinnacle Bridge's in-house marketing team must comply with the centralized advertising review workflow set forth in Chapter III of this Manual without exception. No advertising or marketing material may be published, distributed, or placed in any medium by or on behalf of Pinnacle Bridge without documented compliance approval from Lena Fujimoto's advertising compliance team. This requirement is a direct remediation measure addressing the systemic gap in advertising compliance controls identified in the Examination Report and the Internal Audit Report.
(d) MGA Agreement Amendments. The existing managing general agent agreements between QIIC and Pinnacle Bridge, and between QSU and Pinnacle Bridge, shall be amended to incorporate this Manual by reference and to require Pinnacle Bridge's compliance with all provisions hereof as a contractual obligation. Such amendments shall be completed no later than the CAP remediation deadline of December 31, 2025.
Section 1.4 — Domestic Regulator and NAIC Coordination
1.4.1 — Domestic Regulators
The domestic regulators of the Carrier Subsidiaries are as follows:
(a) QIIC: Connecticut Department of Insurance (CTDOI);
(b) QSU: Texas Department of Insurance (TDI); and
(c) QLA: Arizona Department of Insurance and Financial Institutions (ADIFI).
1.4.2 — NAIC Coordination
QIH and its Carrier Subsidiaries participate in the NAIC Market Regulation ("D") Committee framework and are committed to compliance with NAIC market-conduct standards, including the Market Regulation Handbook, the Market Conduct Annual Statement (MCAS), and applicable NAIC model laws and regulations. This Manual has been developed with reference to the NAIC's standards for market-conduct compliance programs.
1.4.3 — Lead Examining State
FL OIR served as the lead examining state for the 2023–2025 coordinated multi-state market-conduct examination of QIIC. QIH recognizes FL OIR's continued interest in QIIC's compliance remediation and anticipates a follow-up examination by FL OIR in the fourth quarter of 2025 or the first quarter of 2026.
1.4.4 — Non-Domestic Regulators
In addition to the domestic regulators and FL OIR, QIH and its subsidiaries maintain regulatory relationships with insurance departments in all thirty-eight (38) unique licensed states. QIH recognizes the particular significance of the following non-domestic regulators in the current regulatory environment:
(a) CDI — In light of the CDI Order to Show Cause issued June 18, 2025, and the hearing scheduled for October 14, 2025;
(b) NYDFS — In light of the applicability of NYDFS Regulation 64 (prompt-pay requirements) and NYDFS advertising and consumer-protection standards to QIH's New York-licensed operations; and
(c) Regulators in all other licensed states, with whom QIH maintains ongoing compliance obligations and from whom QIH may receive examination notices, data calls, or other regulatory inquiries.
Section 1.5 — Third-Party Advisors and Service Providers
QIH has engaged the following third-party advisors and service providers in connection with its market-conduct compliance program:
(a) Calderwood & Harkness LLP (Responsible Partner: Marcus Delgado; Lead Associate: Carlos Espinoza; 1177 Avenue of the Americas, 34th Floor, New York, NY 10036). Calderwood & Harkness serves as outside counsel for the comprehensive market-conduct compliance refresh engagement (Matter No. 1025-00002). The engagement commenced August 19, 2025, and extends through January 30, 2026, with the option to extend by mutual agreement.
(b) Ridgeline Consulting Group, LLC (Managing Director: Sandra Whitfield). Ridgeline is a third-party market-conduct consulting firm retained by QIH for independent statistical claims-file sampling, complaint-ratio benchmarking, and related analytical services. The engagement value is approximately $340,000. Ridgeline's work product supports the compliance testing program described in Chapter VIII and provides independent verification of QIH's compliance metrics for regulatory reporting purposes.
(c) Cartwright & Eddings, P.A. (Lead Attorney: Rosa Delacroix). Cartwright & Eddings serves as local counsel in Florida, assisting QIH and QIIC with the FL OIR market-conduct examination response, including the development and implementation of the Corrective Action Plan and preparation for any follow-up examination activity.
(d) Voss Kendrick & Associates, CPA, PLLC (Engagement Partner: Frank Castellano). Voss Kendrick serves as the external auditor performing annual statutory audits for QIIC, QSU, and QLA. While the statutory audit function is distinct from market-conduct compliance, Voss Kendrick's familiarity with QIH's financial reporting and internal controls provides valuable context for the compliance program.
(e) Ashford Mutual Insurance Group — QIH maintains directors' and officers' ("D&O") liability insurance coverage through Ashford Mutual Insurance Group, with policy limits of $25 million per occurrence and $50 million in the aggregate, subject to a $1 million retention. This coverage is relevant to the personal liability exposure of QIH's directors and officers in connection with regulatory enforcement actions and compliance failures.
CHAPTER II — CLAIMS-HANDLING PROCEDURES AND TIMELINESS STANDARDS
Section 2.1 — Purpose and Applicability
This Chapter establishes uniform claims-handling procedures and timeliness standards applicable to all Carrier Subsidiaries (QIIC, QSU, and QLA) across all lines of business and all thirty-eight (38) unique licensed states. The procedures and standards set forth in this Chapter are designed to achieve the following objectives:
(a) Remediate the six (6) claims-handling timeliness findings identified in the FL OIR Examination Report dated May 12, 2025;
(b) Establish uniform, enterprise-wide claims-handling standards that meet or exceed the most stringent applicable state statutory requirements;
(c) Implement robust escalation protocols to prevent the recurrence of claims-handling timeliness deficiencies;
(d) Improve claims-file documentation quality and reduce the claims-file error rate; and
(e) Support the timely satisfaction of the FL OIR Corrective Action Plan remediation milestones.
These procedures apply to all claims personnel, including the approximately 420 claims adjuster full-time-equivalent employees supervised by Thomas Raeburn, Senior Vice President, Claims Operations, as well as any third-party adjusters, independent adjusters, or other claims service providers acting on behalf of a Carrier Subsidiary. The procedures also apply to Pinnacle Bridge MGA, LLC to the extent that Pinnacle Bridge performs claims intake, first-notice-of-loss processing, or other claims-related functions on behalf of QIIC or QSU (Section 2.8).
Section 2.2 — Claims Acknowledgment Standards
2.2.1 — Uniform 10-Business-Day Acknowledgment Standard
All claims received by a Carrier Subsidiary or by Pinnacle Bridge MGA, LLC on behalf of a Carrier Subsidiary must be acknowledged in writing (including by electronic communication) to the claimant or policyholder within ten (10) Business Days of receipt. For purposes of this Section, "receipt" means the date on which the claim is first received by the Carrier Subsidiary or Pinnacle Bridge, whether by telephone, mail, email, website portal, mobile application, or any other intake channel.
This ten (10)-Business-Day standard has been established as the enterprise-wide uniform acknowledgment standard because it matches the most stringent state statutory requirement among QIH's thirty-eight (38) unique licensed states. By adopting the most restrictive standard as the enterprise-wide baseline, QIH ensures compliance with all applicable state acknowledgment deadlines without requiring claims personnel to determine the applicable state-specific deadline for each individual claim.
This standard directly addresses the FL OIR examination finding that QIIC's average claims acknowledgment time during the Examination Period was 18.7 Business Days — a period that significantly exceeded statutory maximums ranging from ten (10) to fifteen (15) Business Days depending on the applicable state. The adoption of the ten (10)-Business-Day standard is intended to bring QIIC's claims acknowledgment practices into compliance with all applicable state requirements and to prevent future examination findings in this area.
Where a specific state statute, regulation, or regulatory order requires acknowledgment in fewer than ten (10) Business Days, the more restrictive state requirement shall control. Claims personnel should consult the State-by-State Regulatory Requirements Matrix (Appendix B) for state-specific acknowledgment deadlines. In the event of any conflict between the uniform ten (10)-Business-Day standard and a more restrictive state requirement, the more restrictive state requirement shall prevail.
2.2.2 — Acknowledgment Content Requirements
Each claims acknowledgment communication must include the following elements:
(a) The assigned claim number;
(b) The date of loss as reported by the claimant or policyholder;
(c) A description of the coverage under which the claim is being processed, including identification of the applicable policy and policy number;
(d) The name of the claims adjuster assigned to the claim;
(e) Direct contact information for the assigned adjuster, including telephone number, email address, and mailing address;
(f) A summary of the next steps in the claims investigation process, including any information or documentation the claimant or policyholder is requested to provide;
(g) All state-specific consumer-rights disclosures required by the applicable Licensed State, including but not limited to the right to file a complaint with the state insurance department and the applicable department's contact information; and
(h) Any additional information required by the applicable state's claims-handling statutes or regulations.
State-specific acknowledgment letter templates are maintained in Appendix D. These templates incorporate the state-specific disclosure requirements for each of QIH's thirty-eight unique licensed states and are updated periodically to reflect changes in state law or regulatory guidance. Claims personnel are required to use the applicable state-specific template for all acknowledgment communications.
2.2.3 — System-Alert Configuration
The claims management system shall be configured to generate the following automated alerts to support compliance with the ten (10)-Business-Day acknowledgment standard:
(a) Day 5 Warning Alert. On the fifth (5th) Business Day following claim receipt, the claims management system shall generate an automated warning alert to the assigned claims adjuster, reminding the adjuster that the ten (10)-Business-Day acknowledgment deadline is approaching and that acknowledgment must be completed no later than the tenth (10th) Business Day.
(b) Day 8 Escalation Alert. On the eighth (8th) Business Day following claim receipt, if no acknowledgment has been recorded in the system, the claims management system shall generate an automated escalation alert to the assigned adjuster's direct supervisor. The escalation alert shall require the supervisor to review the claim, determine the reason for the delay, document the explanation in the claims file, and take immediate action to ensure acknowledgment is completed before the tenth (10th) Business Day deadline.
The system-alert configuration shall be tested upon implementation and no less frequently than annually thereafter to verify proper functionality. Any system failures or malfunctions affecting alert delivery shall be reported to the MCCC and remediated promptly.
Section 2.3 — Claims Investigation Standards
Upon acknowledgment of a claim, the assigned claims adjuster shall commence the claims investigation within five (5) Business Days of the date of acknowledgment. The investigation shall be conducted diligently, thoroughly, and in good faith, with the objective of determining coverage, liability, and damages in a manner that is fair to the claimant or policyholder.
2.3.1 — Investigation Timelines
The following investigation timelines apply:
(a) Standard Claims. For standard claims that do not involve complex factual, legal, or coverage issues, the investigation shall be completed within thirty (30) calendar days from the date of claim receipt.
(b) Complex Claims. For claims involving complex factual, legal, or coverage issues — including but not limited to claims requiring independent medical examinations, engineering reports, subrogation analysis, or multi-party liability determinations — the investigation period may be extended to forty-five (45) calendar days from the date of claim receipt, provided that the extension is documented in the claims file with a written justification describing the specific complexity factors requiring additional time.
2.3.2 — Investigation Documentation
All investigation activities must be documented in the claims file, including but not limited to:
(a) Adjuster investigation notes, dated and initialed, describing each investigation activity performed;
(b) All supporting evidence obtained during the investigation, including photographs, police reports, medical records, repair estimates, expert reports, and witness statements;
(c) A complete communications log documenting all communications with the claimant, policyholder, witnesses, attorneys, medical providers, and other parties;
(d) Coverage analysis memoranda, including identification of applicable policy provisions, exclusions, and endorsements;
(e) Damage or loss calculations, including the basis for each element of the calculation; and
(f) Supervisor review notes, where applicable.
2.3.3 — Prohibition on Unreasonable Delay
No Carrier Subsidiary or claims personnel shall engage in unreasonable delay tactics or make requests for information or documentation that is not material to the determination of coverage, liability, or damages. Requests for information must be reasonably related to the claim and must be made promptly. Follow-up requests should be consolidated where practicable to avoid repeated, piecemeal requests that unnecessarily prolong the investigation.
Section 2.4 — Prompt-Pay Standards and Timelines
2.4.1 — Statutory Prompt-Pay Windows
Upon completion of the claims investigation, all claims for which coverage has been confirmed and liability and damages determined shall be paid within the applicable state Prompt-Pay Window. Prompt-Pay Windows vary by state and are set forth in the State-by-State Regulatory Requirements Matrix (Appendix B).
QIH has established an internal target of paying ninety-five percent (95%) of all claims within applicable statutory Prompt-Pay Windows. This target directly addresses the current performance deficiency identified in the Examination Report, which found that only 74.2% of sampled claims during the Examination Period were paid within applicable Prompt-Pay Windows. Closing the gap between the current 74.2% timely payment rate and the 95% target is a critical remediation objective and a key metric for the FL OIR Corrective Action Plan.
For QIIC's operations in New York, claims personnel must comply with the prompt-pay requirements of NYDFS Regulation 64 (11 NYCRR Part 216), which imposes specific timeframes and procedural requirements for the payment of claims. New York-specific training on Regulation 64 is included in the claims adjuster training track (Chapter VI, Section 6.2.1).
2.4.2 — Payment Processing Procedures
Claims payments shall be processed in accordance with the following procedures:
(a) Payment Methods. Claims payments may be made by check, electronic funds transfer (EFT/ACH), or other approved payment methods. The Carrier Subsidiary shall accommodate the claimant's or policyholder's reasonable preference for payment method where practicable.
(b) Partial and Advance Payments. Where the full amount of a covered claim cannot be determined immediately but a portion of the claim is undisputed, the Carrier Subsidiary shall make a partial or advance payment of the undisputed amount promptly, without waiting for completion of the investigation of the disputed portion.
(c) Payment Documentation. All claims payments must be accompanied by documentation in the claims file that sets forth the calculation of the payment amount, the policy provisions supporting coverage, and the factual basis for the payment determination. Payment registers and disbursement records shall be maintained in accordance with Chapter VII.
2.4.3 — Denial and Adverse Determination Procedures
Where a claims investigation results in a denial of the claim or an adverse determination (including partial denial or payment of less than the claimed amount), the Carrier Subsidiary shall issue a written denial letter to the claimant or policyholder. Each denial letter must include the following elements:
(a) The specific policy provisions relied upon as the basis for the denial, including the full text or an accurate summary of the relevant provisions;
(b) A clear and complete factual basis for the denial, explaining how the facts of the claim relate to the cited policy provisions;
(c) A complete explanation of the claimant's or policyholder's right to appeal the denial, including the process for requesting reconsideration and any applicable deadlines;
(d) Contact information for the applicable state Department of Insurance, including a statement that the claimant or policyholder has the right to file a complaint with the state insurance department; and
(e) Any additional information or disclosures required by the applicable state's claims-handling statutes or regulations.
State-specific denial letter templates are maintained in Appendix F. These templates incorporate the state-specific requirements for each of QIH's thirty-eight unique licensed states. Claims personnel are required to use the applicable state-specific template for all denial communications.
Section 2.5 — Escalation Protocols for Claims Approaching Statutory Deadlines
To prevent any claim from exceeding applicable statutory deadlines, the following tiered escalation framework is hereby established:
Level 1 — Day 5 Post-Receipt (Warning). On the fifth (5th) Business Day following claim receipt, the claims management system shall generate an automated alert to the assigned claims adjuster, notifying the adjuster that the acknowledgment deadline is approaching. The adjuster is responsible for reviewing the claim status and taking appropriate action to ensure timely acknowledgment. No formal documentation beyond the system-generated alert is required at this level.
Level 2 — Day 8 Post-Receipt (Supervisor Notification). On the eighth (8th) Business Day following claim receipt, if acknowledgment has not been completed, the claims management system shall generate an escalation alert to the assigned adjuster's direct supervisor. The supervisor shall conduct a mandatory status review of the claim within one (1) Business Day, document the review in the claims file, and take all necessary steps to ensure acknowledgment is completed before the tenth (10th) Business Day deadline. The supervisor must record a written explanation of the reason for the delay.
Level 3 — Day 9 Post-Receipt (Unit Manager Escalation). On the ninth (9th) Business Day following claim receipt, if acknowledgment has still not been completed, the matter shall be escalated to the applicable claims unit manager. The unit manager shall develop and implement a mandatory remediation plan to ensure immediate acknowledgment. The remediation plan and the circumstances of the delay must be documented in the claims file.
Level 4 — Approaching Prompt-Pay Deadline (Director-Level Review). Five (5) Business Days prior to the expiration of the applicable state Prompt-Pay Window for any claim, the claims management system shall generate an alert to Thomas Raeburn (SVP, Claims Operations) or his designee. Mr. Raeburn or his designee shall conduct a director-level review of the claim, assess the status of the investigation and payment determination, and direct all necessary actions to ensure payment or denial is completed within the Prompt-Pay Window.
Documentation of escalation activities at each level shall be maintained in the claims file. Any claim that exceeds a statutory deadline — whether for acknowledgment, investigation, or payment — shall be subjected to a root-cause analysis. The root-cause analysis shall be documented and submitted to the MCCC as part of the monthly compliance dashboard. Patterns of statutory-deadline exceedances shall trigger a systemic remediation review by the MCCC.
Section 2.6 — Claims File Documentation and Quality Standards
2.6.1 — Required File Elements
Every claims file maintained by a Carrier Subsidiary shall contain, at a minimum, the following elements:
(a) The initial claim report, including the date and method of receipt, the reported facts and circumstances of the loss, and the identity of the reporting party;
(b) A copy of the acknowledgment communication sent to the claimant or policyholder;
(c) Complete investigation notes, dated and initialed, documenting all investigation activities;
(d) Coverage analysis memoranda;
(e) All payment and/or denial documentation, including payment calculations, denial letters, and supporting records;
(f) Copies of all correspondence with the claimant, policyholder, attorneys, and other parties;
(g) Records of all supervisor and management reviews; and
(h) Documentation of any escalation activities conducted pursuant to Section 2.5.
2.6.2 — Quality Assurance Review
The FL OIR Examination Report identified a claims-file error rate of 11.8% during the Examination Period, with seventy-four (74) files out of 625 sampled files exhibiting one or more documentation deficiencies, from a total universe of approximately 12,400 QIIC claims files. To address this deficiency and to achieve the target error rate of three percent (3%) or below, the following quality assurance review program is hereby established:
(a) Claims unit managers shall conduct random sampling of closed claims files on a monthly basis. The minimum sample rate shall be two percent (2%) of all files closed during the month.
(b) Each sampled file shall be reviewed against the documentation checklist set forth in Section 2.6.1 and against applicable state-specific requirements.
(c) Identified deficiencies shall be documented, and the responsible adjuster shall be notified and required to remediate the deficiency.
(d) Aggregate quality assurance results — including the monthly error rate, the types and frequency of deficiencies identified, and remediation actions taken — shall be reported to the MCCC through the monthly compliance dashboard.
(e) Any adjuster exhibiting a pattern of documentation deficiencies (defined as three or more deficient files within a rolling six-month period) shall be referred to Thomas Raeburn for additional training, coaching, or other appropriate corrective action.
Section 2.7 — Subsidiary-Specific Claims Procedures
2.7.1 — QIIC (Personal Auto, Homeowners, Dwelling Fire)
In addition to the enterprise-wide procedures set forth in this Chapter, QIIC claims operations shall comply with the following line-specific and state-specific procedures:
(a) Personal automobile claims shall be handled in compliance with the applicable state's motor vehicle insurance claims-handling statutes and regulations, including state-specific requirements for vehicle damage appraisals, total-loss determinations, rental car reimbursement, and diminished-value claims.
(b) Homeowners and dwelling fire claims shall be handled in compliance with state-specific requirements for property damage assessments, scope-of-loss determinations, contractor referral disclosures, and building-code upgrade coverage.
(c) Special attention shall be given to the claims-handling requirements of the following states, which represent QIIC's largest premium volumes and most active regulatory environments: Florida, California, New York, Connecticut, Illinois, and Ohio. State-specific procedures for these states are set forth in the State-by-State Regulatory Requirements Matrix (Appendix B).
2.7.2 — QSU (Commercial General Liability, Professional Liability, Cyber Liability)
In addition to the enterprise-wide procedures set forth in this Chapter, QSU claims operations shall comply with the following line-specific considerations:
(a) Commercial general liability claims shall be handled in compliance with applicable state requirements for commercial-lines claims, including notice-of-claim acknowledgment, reservation-of-rights procedures, and duty-to-defend determinations.
(b) Professional liability (errors and omissions) claims require specialized investigation procedures due to the complexity of professional standards-of-care analysis. Investigation timelines for E&O claims shall be governed by the complex-claims timeline (forty-five calendar days from receipt) in all cases, and may be extended beyond forty-five days with documented justification and director-level approval.
(c) Cyber liability claims involve unique investigation requirements, including coordination with forensic investigators, breach-notification counsel, and privacy regulators. QSU shall maintain a specialized cyber claims investigation protocol and a pre-approved panel of forensic investigation and breach-response vendors.
(d) State-specific considerations for QSU's twenty-two (22) licensed states are set forth in the State-by-State Regulatory Requirements Matrix (Appendix B).
2.7.3 — QLA (Term Life, Whole Life, Fixed and Indexed Annuities)
In addition to the enterprise-wide procedures set forth in this Chapter, QLA claims operations shall comply with the following line-specific considerations:
(a) Life insurance death-benefit claims shall be handled in compliance with applicable state statutes governing the payment of life insurance proceeds, including beneficiary verification procedures, contestability-period review, and interest-on-proceeds requirements.
(b) Annuity surrender and withdrawal requests shall be processed in compliance with applicable state requirements, including surrender-charge disclosures and tax-reporting obligations.
(c) QLA shall maintain compliance with unclaimed property and escheatment requirements in all nineteen (19) licensed states, including compliance with the Social Security Administration Death Master File cross-referencing requirements adopted by a growing number of states. QLA shall conduct Death Master File comparisons at least semi-annually and shall initiate proactive beneficiary outreach upon identification of unreported deaths.
(d) State-specific considerations for QLA's nineteen (19) licensed states are set forth in the State-by-State Regulatory Requirements Matrix (Appendix B).
Section 2.8 — Pinnacle Bridge MGA Claims Involvement
2.8.1 — Scope of Pinnacle Bridge Claims Functions
Pinnacle Bridge MGA, LLC performs certain claims-related functions on behalf of QIIC and QSU through its fintech distribution platform, including claims intake and first-notice-of-loss ("FNOL") processing. The following procedures govern Pinnacle Bridge's involvement in the claims process:
(a) Pinnacle Bridge may receive and process first-notice-of-loss reports through its digital platform. Upon receipt of a FNOL, Pinnacle Bridge shall transmit the FNOL to the applicable Carrier Subsidiary's claims operations unit within one (1) Business Day.
(b) Pinnacle Bridge shall not exercise independent claims settlement authority beyond delegated authority thresholds established in the applicable MGA agreement. As of the date of this Manual, the delegated claims settlement authority for Pinnacle Bridge is $25,000 per claim for QIIC personal-lines claims and $50,000 per claim for QSU commercial-lines claims. Any claim with a potential exposure exceeding the applicable threshold must be referred to the Carrier Subsidiary's claims operations unit for handling.
(c) Pinnacle Bridge shall not deny any claim or issue any adverse determination without the prior approval of the applicable Carrier Subsidiary's claims operations unit.
2.8.2 — Reporting Obligations
Pinnacle Bridge shall provide the following reports to QIIC and QSU claims operations:
(a) Daily FNOL transmittal logs documenting all claims intake activity;
(b) Weekly claims activity reports for claims handled within Pinnacle Bridge's delegated authority;
(c) Monthly claims performance metrics, including acknowledgment timeliness, payment timeliness, a