state of connecticut · connecticut, having fully considered and reviewed the examination report...

STATE OF CONNECTICUT INSURANCE DEPARTMENT

ORDER ADOPTING REPORT OF EXAMINATION

I, Anne Melissa Dowling, Deputy Insurance Commissioner of the State of

Connecticut, having fully considered and reviewed the Examination Report (the

"Report") of Aetna Health Inc. (a Connecticut Corporation) (the "Company") as of

December 31, 2010, do hereby adopt the findings and recommendations contained

therein based on the following findings and conclusions:

TO WIT:

1. I, Anne Melissa Dowling, as the Deputy Insurance Commissioner of the State of Connecticut, and as such is charged with the duty of administering and enforcing the provisions of Title 38a of the Connecticut General Statutes ("CGS").

2. The Company is a domestic insurer authorized to transact the business of insurance in the State of Connecticut.

3. On February 27,2012, the verified Report of the Company was filed with the Connecticut Insurance Department (the "Department").

4. In accordance with CGS §38a-14(e)(3), the Company was afforded a period of thirty (30) days within which to submit to the Department a written submission or rebuttal with respect to any matters contained in the Report.

5. On March 27,2012, the Company notified the Department of certain responses and comments on certain items contained in the Report.

6. Following review of the Report, it was deemed necessary and appropriate to modify the Report. A copy of the Report is attached hereto and incorporated herein as Exhibit A.

WWW,ct.gov/cid P.O. Box 816 • Hartford,CT06142-0816

An Equal Opportunity Employer

NOW, THEREFORE, it is ordered as follows:

1. That the Report of the Company hereby is adopted as filed with the Department.

2. That the Company shall comply with all of the recommendations set forth in the Report, and that failure by the Company to so comply shall result in sanctions or administrative action as provided by Title 38a of the CGS.

Dated at Hartford, Connecticut, this 5th day of April, 2012.

k~~ Anne Melissa Dowling

Deputy Insurance Commissioner

Exhibit A

EXAMINATION REPORT

OF THE

AETNA HEALTH INC. (A CONNECTICUT CORPORATION)

AS OF

DECEMBER 31,2010

BY THE

CONNECTICUT INSURANCE DEPARTMENT

TABLE OF CONTENTS

Salutation

Scope of Examination 2

History 3

Organizational Chart 4

Management and Control 5

Related Party Transactions 6

Insurance Coverage 7

Territory and Plan of Operations 8

Reinsurance 8

Information Technology Controls 8

Accounts and Records 9

Financial Statements 9 Assets 9 Liabilities, Capital and Surplus 10 Statement of Revenue and Expenses 11 Capital and Surplus Account 11

Investments 12

Claims Unpaid 13 Unpaid Claims Adjustment Expenses 13

Common Capital Stock 13

Gross Paid in and Contributed Surplus 14

Aggregate Write-ins For Special Surplus Funds 14

Unassigned Funds (Surplus) 14

Subsequent Event 14

Conclusion 15

Signature 16

February 27, 2012

The Honorable Thomas B. Leonardi Insurance Commissioner State of Connecticut Insurance Department 153 Market Street, 6th Floor Hartford, CT 06103

Dear Commissioner:

In compliance with your instructions and pursuant to the requirements of Section 38a-14 of the Connecticut General Statutes (CGS), the undersigned has conducted a Financial Examination of the condition and affairs of the:

AETNA HEALTH INC. (a Connecticut corporation)

(hereinafter referred to as the Company or AHI), a capital stock corporation incorporated under the laws of the State of Connecticut and having its main administrative office located at 980 Jolly Road, Blue Bell, PA. The report of such examination is submitted herewith.

AETNA HEALTH INC. (a Connecticut Corporation)

SCOPE OF EXAMINATION

The previous examination of the Company was conducted as of December 31, 2005. The current examination, which covers the subsequent five year period through December 31, 2010, was conducted at the primary location of the books and records of the Company.

The examination was conducted on a full scope, comprehensive basis in accordance with the procedures outlined in the National Association ofInsurance Commissioners (NAIC) Financial Examiners Handbook (the Handbook). The'Handbook requires that we plan and perform the examination to evaluate the financial condition and identify prospective risks of the Company by obtaining information about the Company, including corporate governance, and inherent risks within the Company, and evaluating system controls and procedures used to mitigate those risks. An examination also includes assessing the principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation, and management compliance with Statutory Accounting Principles and the Annual Statement Instructions (Instructions). All accounts and activities of the Company were considered in accordance with the risk-focused surveillance examination process.

Concurrent examinations were also conducted on Aetna Life Insurance Company (ALlC), Aetna Health and Life Insurance Company (AHLlC), Aetna Insurance Company of Connecticut (AICC), and Aetna Better Health Inc. (a Connecticut Corporation) (ABH), which are members of the Aetna Group of companies (the Group).

As part of the examination planning procedures, the Financial Regulation Division of the Connecticut Insurance Department (the Division) reviewed the following materials submitted by the Company:

• Annual Statements filed with the Division; • The 2009 and 2010 audit reports by the Company's independent certified public

accountants, KPMG, LLP (KPMG); • The 2009 and 2010 statutory audit opinions which indicated no material concerns

with respect to financial condition or regulatory compliance issues; • Statements of actuarial opinion; • Annual reports to shareholders; • Form 10-K reports filed with the Securities and Exchange Commission; • Reports of the Company's Internal Audit Department; and • Minutes of the Board of Directors (Board), affiliate and custodial agreements, and

other documents related to significant transactions that require prior approval, or requests for deviations from the NAIC Accounting Practices and Procedures Manual (Manual).

2

AE1NA HEALTH INC. (a Connecticut Corporation)

A comprehensive review was made of the fmancial analysis files and documents submitted to the Financial Analysis Unit of the Division, as well as Examination Jumpstart, and Financial Analysis and Solvency Tracking System reports obtained from the NAIC database.

Work papers prepared by KPMG, the Company's independent public accountants, as of December 31, 2010, in connection with their annual statutory audits, were reviewed and relied upon to the extent deemed appropriate.

Lewis & Ellis, Inc. (L&E) was engaged by the Division to assist in the review of the Company's actuarial computed loss reserves and significant ceded reinsurance treaties.

CCR, LLP (CCR) was engaged by the Division to assist in the review of the Company's loss and benefit accounts.

RSM McGladrey, Inc. (McGladrey) was engaged by the Division to assist in the review of the Company's information technology (IT) general controls.

Comments in this report are generally limited to exceptions noted or to items considered to be of a material nature.

Failure of items in this report to add to totals or for totals to agree with captioned amounts is due to rounding.

HISTORY

The Company was incorporated on January 5, 1987, under Chapter 593a of the CGS, as U.S. Healthcare, Inc. The Company was licensed by the Insurance Commissioner of the State of Connecticut on January 5, 1987, and commenced business on June 1, 1987. The Company is organized as a stock for profit individual practice association (IPA) model health maintenance organization (HMO). The Company is one of several wholly-owned subsidiaries of Aetna Health Holdings, LLC (AHH), a Delaware HMO holding company, wholly owned by Aetna Inc., a Pennsylvania company (Aetna).

On July 15, 1998, Aetna acquired NYL Care Health Plans, the health care business of New York Life Insurance Company, for $1.05 billion.

On August 6, 1999, Aetna acquired the Prudential Health Care business (PHC) from The Prudential Insurance Company of America (Prudential) for approximately $1 billion. Included in the acquisition were PHC's risk HMO, Point-of-Service (POS), Preferred Provider Organization (PPO), indemnity health lines, and dental risk business. The transaction was fmanced by issuing $500 million of three-year senior notes to Prudential, and by using funds made available from the issuance of commercial paper.

3


On December 13,2000, Aetna sold its financial services and international businesses to ING Group N.V., and completed the simultaneous spin-off to shareholders of its health care business. Concurrent with the spin-off, Aetna became the ultimate parent of the Company.

Effective September 28, 2001, Prudential Health Care Plan of Connecticut, Inc. merged with and into Aetna U.S. Healthcare Inc. (a Connecticut corporation). The transaction was accounted for as a statutory merger. AHI was the surviving company.

On June 30, 2003, Aetna contributed all of the outstanding capital stock of the Company to AHB. The Company is a wholly-owned subsidiary of AHH, whose ultimate parent is Aetna.

ORGANIZADONAL CHART

A partial organizational chart of the insurance holding company system as ofDecember 31, 2010, is as follows:

Aetna, Inc. (Pennsylvania)

I

Aetna Life Insurance Company

(Connecticut)

Aetna Health and Life

Insurance Company

(Connecticut)

Aetna Health Holdings, LLC

(Delaware)

I

AHP Holdings, Inc. (Connecticut)

Aetna Health Inc.

(Connecticut)

I

Aetna Better Health Inc.

(Connecticut)

I Aetna

Insurance Company of Connecticut

(Connecticut)

4


MANAGEMENT AND CONTROL

The Company is a member of an insurance holding company system as defined in Sections 38a-138.1 to 38a-138.1 b of the Connecticut Insurance Regulations and Section 38a-135 of the CGS.

The bylaws of the Company state that the annual meeting of shareholders for the election of the directors, and for the transaction of such other business as properly may come before such meeting, shall be held each year, on such date and at such time, within or without the State of Connecticut, as may be determined by the Board.

Special meetings of the shareholders may be called at any time by the Board, the president, any vice president, or the secretary, and shall be called by the president or the secretary at the written request of any shareholder or shareholders owning at least ten percent of the outstanding shares entitled to vote thereat, or as otherwise required by law.

The Company bylaws provide that the number of directors, which shall constitute the entire Board, shall be fixed from time to time by resolution of either the Board or the shareholders, with such number being subject to any later resolutions of either of them. The directors are elected at the annual meeting of the shareholders, with each director to hold office until the annual meeting of the shareholders next succeeding his election and until his successor is elected and qualified, or until his earlier death, resignation, or removal. Any vacancy resulting from an increase in the number of directors, or the death, resignation, disqualification, removal or inability to act of any director, shall be filled for the unexpired portion of the term by an individual receiving a majority vote of the remaining directors at any regular meeting or special meeting of the Board called for that purpose.

At all meetings of the Board, the presence of a majority of the entire Board shall be necessary to constitute a quorum for the transaction of business.

5


Directors serving the Company at December 31, 20 10, were as follows:

Name Title and Principal Business Affiliation Martha R. Temple President, AHI Joseph V. Agostini Director, AHI Michael E. Morris Director, AHI David B. Morse Director, AHI

Committees Pursuant to the corporate bylaws, the Company's business operations may be monitored through various advisory committees approved by the Board. AHH, which is the controlling entity of AHI, has established an audit committee. AHH has elected its audit committee to be the audit committee of AHI, permitted by Section 38a-54-3(d) of the COS.

Officers The officers serving the Company at December 31, 2010, were as follows:

Name Title Martha R. Temple President Elaine R. Cofrancesco Treasurer Edward Chung-I Lee Vice President and Secretary Gregory S. Martino Vice President Jennifer A. Palma Principal Financial Officer and Controller Kevin 1. Casey Senior Investment Officer David W. Braun Assistant Controller

RELATED PARTY TRANSACTIONS

The Company is party to numerous related party transaction agreements. The agreements that are material in nature are as follows:

Administrative Services Agreement Effective September 1, 2008, an amendment to the Amended and Restated Administrative Services Agreement (Agreement), dated January 1,2004, was made by and between the Company and Aetna Health Management, LLC (AHM), indirectly a wholly-owned subsidiary of Aetna. Under the Agreement, AHM provided certain administrative services, including accounting, and the processing of premiums and claims. The Company remits a percentage of its earned commercial, Medicaid and Medicare premium revenue, as applicable, to AHM as a fee, subject to an annual true-up mechanism that is due to be settled with the affiliate by April 15th of the following contract year.

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The Agreement also provides for interest on all intercompany balances, and enables the Company to receive manufacturers' pharmacy rebates form ARM, under which the Company remits 10% of its earned pharmaceutical rebates to ARM as a fee. The terms of settlement for the interest and pharmaceutical rebates require that these amounts be settled within 45 days after the end of the calendar quarter.

The 2008 amendment was made to comply with certain requirements set forth by Medicare laws, rules, and regulations that apply solely to AHM's performance of Medicare services.

Consolidated Tax Allocation Agreement Effective January 1,2006, the Company entered into a tax sharing agreement and a supplemental tax sharing agreement with Aetna for the filing of consolidated federal income tax returns. The income tax obligation of the Company is apportioned in accordance with the result of its tax returns, applied on an individual basis. Aetna renders payment to the appropriate tax authority on behalf of itself and each subsidiary member of the affiliated group that is included in the consolidated income tax return. If the Company generates a separate tax loss, a tax benefit is allocated to the Company to the extent the loss is utilized against Aetna's consolidated taxable income.

INSURANCE COVERAGE

The Company is insured with affiliates on a $60 million forgery or alteration, single loss limit of liability, financial institution bond issued by Travelers Casualty & Surety Company of America. The Company maintains a single loss deductible of $1 0 million on this coverage. The aggregate limit of liability provides fidelity coverage above the prescribed minimum set forth by the Handbook's schedule of suggested minimum amounts.

In addition to fidelity bond insurance coverage, the Company maintains primary and excess coverages for the following lines, with the respective insurance companies:

Company Coveraee Twin City Fire Insurance Company Commercial general liability Hartford Fire Insurance Company Commercial automobile liability The Factory Mutual Insurance Company Commercial property and boiler &

machinery Underwriters at Lloyds Directors & officers liability Aetna Insurance Company of Connecticut Managed care professional liability Hartford Fire Insurance Companies Workers compensation and employers

liability

7


TERRITORY AND PLAN OF OPERATIONS

The Company commenced operations as a HMO in 1987. The Company's lines of business include Commercial, Medicare and Federal Employees Health Benefits Program (FEHBA). AHI generally compensates primary care physicians through prospective compensation arrangements. AHI has contracts that provide for all-inclusive per diem and per case hospitalization rates, and fixed rates for ambulatory surgery, emergency room services, and specialist services. All premium writings are in Connecticut.

REINSURANCE

The Company does not assume or cede any reinsurance business.

INFORMATION TECHNOLOGY CONTROLS

McGladrey performed an evaluation ofthe IT controls in accordance with the guidelines and procedures set forth in Exhibit C Evaluation of Controls in Information Technology (Exhibit C) of the Handbook.

McGladrey's objectives were to determine whether IT resources align with the Company's strategies and objectives and to ensure that significant risk associated with its IT environment was appropriately mitigated by strategies and controls as outlined in Exhibit C.

The objectives of this review was achieved through a combination of reviewing the Company's policies and procedures, testing in key areas related to Exhibit C, interviewing the Company's IT senior management, reviewing IT risk assessment processes, and leveraging the risk assessment procedures performed by KPMG.

The scope of the review for the Companies under examination (Companies) included the following administrative systems:

System Description

Aetna Administration System (AAS) Policy administration and premium processing system

AES Billing System (AES) Premium billing system.

Claim Reporting System (CRS) Death, disability and accident and health loss and benefit processing system

QNXT ABH administrative system HMO Claims AHI claim processing system

The internal control structure of the Company and selected accounting procedures were reviewed and discussed with management through questionnaires, observation, and attribute testing. The reconciliation of accounts and the internal control review concluded that the operating environment is conducive to producing reliable accounting information, and the review did not disclose any material data integrity issues.

8


ACCOUNTS AND RECORDS

The Company uses the Integrated Financial System (IFS), the Group's general ledger system, resident on the Oracle network system to process and maintain its financial accounting records.

The Company uses The Complete Package (TCP) software to prepare its annual statement. There is no direct feed from the general ledger to the annual statement reporting software. Reports are generated from the general ledger in the annual statement format and then manually input into TCP.

General ledger account balances were reconciled and traced to appropriate asset, liability, and income statement lines of the Annual Statement. Adjusting entries are posted on a monthly basis.

FINANCIAL STATEMENTS

The following statements as filed by the Company, and as detennined by the examination, rdlect the assets, liabilities, surplus and other funds, and summary of operations of the Company, as of December 31, 2010:

ASSETS

Account Description Assets Nonadmitted Assets

Net Admitted Assets

Bonds Cash, cash equivalents and short-term investments Securities lending reinvested collateral assets Investment income due and accrued Premiums and considerations:

Uncollected premiums and agents' balances in course of collection

Current federal and foreign income tax recoverable and interest thereon

Net deferred tax asset Health care and other amounts receivable Aggregate write-ins for other than invested assets

$53,594,265 3,252,207

88,220 486,338

2,887,792

1,293,525 1,766,910 7,324,941

188,133

$498,812

2,321

$53,594,265 3,252,207

88,220 486,338

2,388,980

1,293,525 1,764,589 7,324,941

188,133 Total assets excluding Separate Accounts,

Segregated Accounts and Protected Cell Accounts 70,882,331 501,133 70,381,198

Totals $70,882,331 $501.133 $70,381,198

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LIABILITIES, CAPITAL AND SURPLUS

Account Description Covered Uncovered Total Claims unpaid Unpaid claims adjustment expenses Aggregate health policy reserves Aggregate health claim reserves Premiums received in advance General expenses due or accrued Amounts due to parent, subsidiaries and

affiliates Payable for securities lending Aggregate write-ins for other liabilities

$19,722,971 347,965

67,525 193,592

17,196 1,108,485

5,139,650 88,220

226,807

$535,610 $20,258,581 347,965

67,525 193,592

17,196 1,108,485

5,139,650 88',220

226,807 Total liabilities 26,912,411 535,610 27,448,021 Aggregate write-ins for special surplus funds 174,966 Common capital stock 12 Gross paid in and contributed surplus 32,291,506 Unassigned funds (surplus) 10,466,693 Total capital and surplus 42,933,177

Total liabilities, capital and surplus $70,381.198

10


STATEMENT OF REVENUE AND EXPENSES

Account Description Uncovered Total Net premiums income Change in unearned premium reserves and reserve for rate

credits

$252,831,150

(6,973) Total revenues 252,824,177 Hospital/medical benefits Other professional services Outside referrals Emergency room and out-of-area Prescription drugs

$1,889,534

3,002,701 260,262

160,639,428 52,136

3,002,701 8,675,403

26,411,407 Subtotal 5,152,497 198,781,075 Total hospital and medical Claim adjustment expenses General administrative expenses Increase in reserve for life and accident and health contracts

5,152,497 198,781,075 5,488,785

32,253,691 (1,113,465)

Total undeIWriting deductions 5,152,497 235,410,086 Net underwriting gain or (loss) 17,414,091 Net investment income earned Net realized capital gains or (losses)

2,308,742 448,550

Net investment gains or (losses) 2,757,292 Net income or (loss) after capital gains tax and before all other

federal income taxes Federal and foreign income taxes incurred

20,171,383 6,085,224

Net income $14.086.159

CAPnAL AND SURPLUS ACCOUNT

Capital and surplus prior reporting period Net income Change in net unrealized capital gains and (losses) Change in net deferred income tax Change in nonadmitted assets Aggregate write-ins for gains or (losses) in surplus

$27,650,806 14,086,159

5,977 (447,597)

1,590,624 47,208

Net change in capital and surplus 15,282,371

Capital and surplus end of reporting period $42.933.177

11


INVESTMENTS

The Division examined the Companies investment and general risk management practices. The scope of the review included the following:

• Gain an understanding of the investment strategy and portfolio composition to assess the investment strategy and initiatives compared to the business objectives;

• Assess the investment risk management function and practices to identify, measure, manage, and monitor/report risks;

• Assess the valuation and price verification process; and • Review the watch list and impairment processes.

The focus of the review and analysis included the following risk areas:

• Asset pricing and fair value determination; • Other-than-temporary impairment (OTT!) determinations; • Commercial mortgage backed securities (CMBS) and other securitized assets; and • Liquidity and funding risks.

The Division's approach to conducting the risk review included the following:

• Reviewed investment policy and guideline documentation; • Reviewed investment strategy documentation for a sample of product lines; • Reviewed audited statutory financial statements as of December 31, 20 I0; • Interviewed key senior staff; • Reviewed operating plan and key priorities; • Reviewed investment management monthly operating reports; • Analyzed investment portfolio by asset class, bond type, credit ratings, and other

similar characteristics; • Reviewed problem asset and impairment review meeting materials, including

underwater securities report and problem bond report; • Reviewed accounting policy on OTT!; and • Reviewed documentation of valuation policies and methodology for each asset

class.

The Company's investment strategy appears to be fundamentally sound and portfolio strategies exist at the product level, which recognize the product liability and liquidity needs. The Company employs numerous reports used to manage investment risk and performance and analyzes investment performance relative to plan. Internal committees and senior management review committees focus on risk management and provide for a disciplined impairment review process.

12


CLAIMS UNPAID $20,258.581 UNPAID CLAIMS ADJUSTMENT EXPENSES $347,965

The Division retained L&E to assist in reviewing the accuracy and theoretical correctness of reserve calculations and analysis perfonned by the Company's appointed actuary as of December 31, 2010. Consistent with the risk focused surveillance approach to the examination, L&E relied upon analyses andtests documented by the Company and in the working papers of the Company's independent auditors.

Reviews of the Company's primary lines of business were conducted to detennine whether the Company's reserves were established in accordance with minimum standards for the valuation of liabilities specified in the Connecticut Standard Valuation Law, Actuarial Guidelines, and applicable Actuarial Standards of Practice. In perfonning the reserve review and analysis, L&E conducted the following tests:

• Reviewed and analyzed statutory Annual Statements for 2009 and 2010, and inquired into other recent years covered under the examination period;

• Met with Company management to understand the business of the Company, its procedures governing actuarial calculations, its approach to risk management, and its likely areas of financial and business risk;

• Reviewed tests perfonned by the Company's actuaries and its independent auditors, and perfonned independent supplemental reserve calculation tests;

• Reviewed experience study infonnation compiled and provided by the Company in support of the major assumptions used in the asset adequacy analysis; and

• Reviewed and analyzed the Company's Statement of Actuarial Opinion, including the 2010 Actuarial Memorandum, and inquired into other recent years covered under the examination period.

It was detennined that the Company's cited reserve base and methods make adequate provision for Connecticut minimum statutory reserves, and are consistent with actuarial guidelines.

COMMON CAPITAL STOCK

At December 31, 2010, the Company reported 10,000 shares of conunon stock authorized, with 1,200 shares issued and outstanding, having a par value of $.01 per share. All issued shares are owned by AHH, with the ultimate parent being Aetna.

On May 30, 2008 and November 24,2008, the Company paid $4.2 million and $5.6 million, respectively, as extraordinary dividends to its parent, all of which constituted returns of capital. The Division approved the dividends paid to its parent.

13


GROSS PAID IN AND CONTRIBUTED SURPLUS $32.291.506

The following exhibit reflects the balance of this account during the period under review:

2009 $32,291,506 2008 $26,291,506 2007 $36,091,506 2006 $36,091,506

AGGREGATE WRITE-INS FOR SPECIAL SURPLUS FUNDS $174,966


2009 $127,758 2008 $0 2007 $0 2006 $0

UNASSIGNED FUNDS (SURPLUS) $10.466,693


2009 $(4,768,470) 2008 $(4,500,008) 2007 $(10,691,248) 2006 $(15,831,611)

SUBSEQUENT EVENT

Medicare Drug Benefits: Aetna was sanctioned by the Centers for Medicare and Medicaid Services (CMS) as a result of improper handling of Medicare drug benefits. Effective April 21, 2010, the Company was temporarily unable to enroll or market Aetna Medicare Advantage and Standalone Prescription Drug Plan Contracts to new Medicare beneficiaries; however, this did not affect existing enrollees. The sanction was lifted in 2011 by CMS, as it was satisfied that the deficiencies, upon which the determination was based, had been corrected and would not likely reoccur.

14


CONCLUSION

The results of this examination disclosed that, as of December 31, 2010, the Company had admitted assets of$70,381,198, liabilities of$27,448,021, and surplus of $42,933,177. During the period under examination, admitted assets increased $36,246,027, liabilities increased $10,172,995, and surplus as regards policyholders increased $26,073,032.

It was determined that the Company's assets were fairly stated in accordance with guidance outlined in the Manual. Assets were acceptable under Section 38a-102 of the CGS. The liabilities established were adequate to cover the Company's obligations to policyholders.

15


SIGNATURE

In addition to the undersigned, the follov'I'ing members of the State of Connecticut Insurance Department participated in the examination: William Arfanis, CFE; Kevin Beaudoin, CFE; Edna Bosley; James Jakielo, FSA, MAAA; Daniel Levine, CPA; Robert Linnell, CFE; Richard Marcks, FCAS, MAAA; Kenneth Roulier, APE, AES, CISA; William Tacy, CFE, CISA; the CPA finn ofCCR; the consulting firm of McGladrey; and the actuarial consulting finn of L&E.

I, Thomas H. Corrigan, CFE, solemnly swear that the foregoing report on examination is hereby represented to be a full and true statement of the condition and affairs of the subject insurer as of December 31, 2010, to the best of my infonnation, knowledge and belief.

RespectfullY?brnitted,

State f Connecticut Insurance Department

State of Connecticut ss. Hartford

County of Hartford

Subscribed and sworn to before me, ,;t '7 LJ1lNotary Public on this

.~

d-a--':yI-'0:d...f:~~:~=~~~~:::~~:~,-2-0-1-2-. -

I

,'~ s H. Corrigan, CFE Ex .' er-In-Charge

16

state of connecticut · connecticut, having fully considered and reviewed the examination report...

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