DOI Complaint Response Timeline Claims Services 2015 This timeline is applicable to DOI Inquiries/Complaints for all states where we do business. The dates on the timeline begin on the day that the DOI letter is received by the Company. Intra-Company DOI response timelines require approved responses be mailed by the 15 th day from the date of receipt, unless state- specific response requirements dictate a shorter time frame. Response from DOI may include: Notices of findings, non-compliance or justified complaints* Request for additional information/status requests Possible fines or other penalties (These notifications are received by P & S who will coordinate next steps with Operations and legal department). *Please see next page for contesting of DOI findings process & procedures: Analyst receives DOI complaint. Identify impacted Manager and Supervisor. Send notice to impacted claims Manager and Supervisor with appropriate response timelines. Analyst will log all DOI complaints for archiving purposes. Upon receipt of the Manager’s approved response , Analyst will record resolve date and document any identified compliance issues. Supervisor will review complaint, identify all contentions associated with complaint. Include any issues found within attached documents, not just the cover letter. Supervisor will prepare proposed response letter and send to Manager for review and approval. Include any compliance or claims handling concerns in to Manager. Supervisor will meet with Manager to review complaint as needed. Supervisor will provide any necessary coaching to adjuster to ensure future compliance, or provide positive feedback on compliance and claims handling if warranted. Manager will review proposed response letter from Supervisor and make any necessary changes. Meet with Supervisor as necessary to discuss any claims handling or compliance issues identified. By Day 15 Manager will approved letters to Supervisor with CC to P&S Analyst. contents to include any identified compliance issues with regulations listed if applicable. Supervisor will address mail out and include all requested documentation. Note claim file, DOI response sent. Upload proof of mailing to file. If P&S does not receive e- mail with a copy of the approved letters from Manager, Analyst will escalate to claims center Executive. Supervisor & Manager are accountable for ensuring DOI response letters with all supporting documentation requested by DOI are mailed timely. Tracking documentation to be uploaded to claim file. Complainant response can be sent via regular mail or certified at management’s discretion. DOI response must go signature-required and by best postal method available to ensure its timely delivery. Note claim file of mailing and upload proof of delivery to claim file. All DOI Response Letters reviewed and approved by Claims Manager for mail out to DOI by Operations. Day 1Day 1- 8Days 9-15Day 15Outcome I nsurance P & S rev

The CSAA IE intra-company standard for responding to all DOI related inquiries, for all states, is within 15 days from the date of receipt, unless the DOI specifies a shorter response time requirement. If a shorter time is specified we adhere to that time frame and the Policy & Standards Analyst will advise local management of the time line adjustment. P & S rev Receipt of Notice Non-Compliance or Notice of Justified Complaint Upon receipt of notice of Non-Compliance or Justified Complaint finding, the P&S Analyst will vet the notice and to the applicable Manager, Supervisor and claims center Executive. Business Unit Manager will review the notice of Non-Compliance or Justified Complaint and recommendations to their Executive (with CC to the Policy & Standards Analyst) advising if they have elected to either contest or not contest the finding. This action should be completed and ed within 7 days of receipt of the notice. Contesting a finding: Operations will corporate Regulatory counsel via Request to contest should include management’s detailed rationale for contesting. Regulatory counsel will be assigned and will respond to Operations directly to determine timeline for counsel’s preparation of the contesting response. Counsel will prepare response to go out under counsel’s signature on behalf of the company. Counsel will keep Operations informed. There are no state-specified time constraints for contesting a negative finding; therefore, response timelines from Regulatory counsel are flexible to counsel’s availability. Once Regulatory counsel has concluded their review, and if they agree the issue is contestable, they will prepare and send the response, and send a copy of the contesting letter to Operations for upload to the claim file. If Operations elects to leverage outside counsel to contest the finding, this is within their authority; however, they will be responsible for any associated cost.