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EXAMINATION REPORT OF PEOPLE’S TRUST INSURANCE COMPANY NAIC Company Code: 13125 DEERFIELD BEACH, FLORIDA as of December 31, 2015 BY THE FLORIDA OFFICE OF INSURANCE REGULATION

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EXAMINATION REPORT

OF

PEOPLE’S TRUST INSURANCE COMPANY

NAIC Company Code: 13125

DEERFIELD BEACH, FLORIDA

as of December 31, 2015

BY THE

FLORIDA OFFICE OF INSURANCE REGULATION

TABLE OF CONTENTS

LETTER OF TRANSMITTAL ........................................................................................................... -

SCOPE OF EXAMINATION ....................................................................................................... 1

SUMMARY OF SIGNIFICANT FINDINGS ................................................................................. 2

CURRENT EXAMINATION FINDINGS ............................................................................................ 2 PRIOR EXAMINATION FINDINGS ................................................................................................. 2

COMPANY HISTORY ................................................................................................................ 2

GENERAL ................................................................................................................................ 2 DIVIDENDS .............................................................................................................................. 3 CAPITAL STOCK AND CAPITAL CONTRIBUTIONS .......................................................................... 3 SURPLUS NOTES ..................................................................................................................... 3 ACQUISITIONS, MERGERS, DISPOSALS, DISSOLUTIONS AND PURCHASE OR SALES THROUGH

REINSURANCE ......................................................................................................................... 3

CORPORATE RECORDS ......................................................................................................... 4

CONFLICT OF INTEREST ............................................................................................................ 4

MANAGEMENT AND CONTROL .............................................................................................. 4

MANAGEMENT ......................................................................................................................... 4

DIRECTORS .............................................................................................................................. 5

SENIOR OFFICERS .................................................................................................................. 5

AFFILIATED COMPANIES ........................................................................................................... 6

SIMPLIFIED ORGANIZATIONAL CHART ................................................................................ 7

MANAGING GENERAL AGENCY CONTRACT ................................................................................. 8 MANAGEMENT SERVICES AGREEMENT ...................................................................................... 8 SERVICES AGREEMENT ............................................................................................................ 8 COST ALLOCATION AGREEMENT ............................................................................................... 9

TERRITORY AND PLAN OF OPERATIONS ............................................................................. 9

TREATMENT OF POLICYHOLDERS .............................................................................................. 9

REINSURANCE ......................................................................................................................... 9

REINSURANCE ASSUMED .......................................................................................................... 9 REINSURANCE CEDED .............................................................................................................10

ACCOUNTS AND RECORDS ..................................................................................................10

MANAGEMENT AGREEMENT .....................................................................................................10 COMMITMENT AGREEMENT ......................................................................................................11 DC ADVISORY CONSULTING SERVICES AGREEMENT .................................................................11 INSTITUTIONAL MASTER CUSTODY AGREEMENT........................................................................11 BROKER SERVICES AGREEMENT ..............................................................................................11 INDEPENDENT ADJUSTER/ESTIMATOR SERVICES AGREEMENT ...................................................11 MASTER SERVICES AGREEMENT ..............................................................................................12 CLAIMS ADMINISTRATION AGREEMENT .....................................................................................12

INFORMATION TECHNOLOGY REPORT ...............................................................................12

STATUTORY DEPOSITS .........................................................................................................13

FINANCIAL STATEMENTS ......................................................................................................14

ASSETS ...................................................................................................................................15

LIABILITIES, SURPLUS AND OTHER FUNDS .......................................................................16

STATEMENT OF INCOME AND CAPITAL AND SURPLUS ACCOUNT .................................17

RECONCILIATION OF CAPITAL AND SURPLUS...................................................................18

COMMENTS ON FINANCIAL STATEMENTS ..........................................................................19

LIABILITIES .............................................................................................................................19 CAPITAL AND SURPLUS ...........................................................................................................19

SUBSEQUENT EVENTS ..........................................................................................................20

SUMMARY OF RECOMMENDATIONS ....................................................................................21

LETTER OF CREDIT .................................................................................................................21

CONCLUSION ..........................................................................................................................22

February 3, 2017 David Altmaier Commissioner Office of Insurance Regulation State of Florida Tallahassee, Florida 32399-0326 Dear Commissioner: Pursuant to your instructions, in compliance with Section 624.316, Florida Statutes, Rule 69O-

138.005, Florida Administrative Code, and in accordance with the practices and procedures

promulgated by the National Association of Insurance Commissioners (NAIC), we have conducted

an examination as of December 31, 2015, of the financial condition and corporate affairs of

People’s Trust Insurance Company 18 People’s Trust Way

Deerfield Beach, FL 33441 hereinafter referred to as the “Company.” Such report of examination is herewith respectfully

submitted.

1

SCOPE OF EXAMINATION

This examination covered the period of January 1, 2011 through December 31, 2015 and

commenced with planning at the Florida Office of Insurance Regulation (Office) on July 19, 2016

to July 21, 2016. The fieldwork started on July 25, 2016, and concluded as of February 3, 2017.

The Company was last examined on a limited-scope basis by representatives of the Office. The

last full-scope examination covered the period of January 1, 2010, through December 31, 2010.

The examination was a single state examination conducted in accordance with the NAIC Financial

Condition Examiners Handbook. The Handbook requires that the examination be planned and

performed to evaluate the financial condition, assess corporate governance, identify current and

prospective risks of the Company, and evaluate system controls and procedures used to mitigate

those risks. An examination also includes identifying and evaluating significant risks that could

cause an insurer’s surplus to be materially misstated both currently and prospectively.

All accounts and activities of the Company were considered in accordance with the risk-focused

examination process. This may include assessing significant estimates made by management

and evaluating management’s compliance with Statements of Statutory Accounting Principles

(SSAP).

This examination report includes significant findings of fact, as mentioned in Section 624.319,

Florida Statutes, and general information about the insurer and its financial condition. There may

be other items identified during the examination that, due to their nature (for example, subjective

conclusions or proprietary information), are not included within the examination report but

separately communicated to other regulators and/or the Company.

2

SUMMARY OF SIGNIFICANT FINDINGS

Current Examination Findings

The following is a summary of material adverse findings, significant non-compliance findings or

material changes in the financial statements.

Letter of Credit

The Company was not in compliance with Rule 69O-144.005 6(d)(2) and (e)(1), Florida

Administrative Code, as the Amlin Letter of Credit did not contain the Evergreen Clause requiring

no less than sixty (60) days notice prior to expiration date or nonrenewal, nor did it contain the

requirement that the agreement be governed by the laws of the State of Florida.

Prior Examination Findings

There were no findings, exceptions, or corrective action to be taken by the Company for the

examination as of December 31, 2010.

COMPANY HISTORY

General

The Company was incorporated in Florida on January 17, 2008, and commenced business on

March 6, 2008.

The Company was authorized to transact insurance in Florida on March 6, 2008,

and is currently authorized for the following coverage(s) as of December 31, 2015:

Homeowners Multiple Peril Fire Allied Lines Other Liability

3

Dividends

The Company did not declare or pay any dividends during the period of this examination.

Capital Stock and Capital Contributions

As of December 31, 2015, the Company’s capitalization was as follows:

Number of authorized common capital shares 1,000,000

Number of shares issued and outstanding 1,000,000

Total common capital stock $1,000,000

Par value per share $1.00

Control of the Company was maintained by its parent, People’s Trust Holdings, LLC (PTH), which

owned one hundred percent (100%) of the stock issued by the Company. PTH in turn was ninety-

nine percent (99%) owned by George W. Schaeffer as sole trustee of the George W. Schaeffer

Living Trust and one percent (1%) by GWS 2, Inc. PTH contributed $31.9 million in cash to the

Company as of December 31, 2015.

Surplus Notes

The Company issued surplus notes to PTH in the amounts of $12.0 million on September 20,

2012, $2.0 million on August 17, 2013, $15.0 million on February 28, 2014, and $10.0 million and

$15.0 million on February 18, 2015. All surplus notes earn interest at six percent (6%) per annum

with no stated maturity. As of December 31, 2015, the Company did not request nor did the Office

approve interest payments on principal surplus notes, and no payments were accrued or paid.

Acquisitions, Mergers, Disposals, Dissolutions and Purchase or Sales through

Reinsurance

The Company had no acquisitions, mergers, disposals, dissolutions and purchase or sales

through reinsurance during the period of this examination.

4

CORPORATE RECORDS

The recorded minutes of the Shareholder(s), Board of Directors (Board) and certain internal

committees were reviewed for the period under examination. The recorded minutes of the Board

documented its meetings and approval of Company transactions and events, in compliance with

the NAIC Financial Condition Examiners Handbook adopted by Rule 69O-138.001, Florida

Administrative Code, including the authorization of investments, as required by Section 625.304,

Florida Statutes.

Conflict of Interest

The Company adopted a policy statement requiring periodic disclosure of conflicts of interest in

accordance with the NAIC Financial Condition Examiners Handbook adopted by Rule 69O-

138.001, Florida Administrative Code.

MANAGEMENT AND CONTROL

Management

The annual shareholder meeting for the election of directors was held in accordance with Section

628.231, Florida Statutes. Directors serving as of December 31, 2015, are shown on the following

page.

5

Directors

Name City, State Principal Occupation

George William Schaeffer Boca Raton, Florida President and Chief

Executive Officer, People’s

Trust Insurance Company

Adam Lawrence Frankel Delray Beach, Florida Director, People’s Trust

Insurance Company

Stephen Alphonso Giliotti West Palm Beach, Florida Director, People’s Trust

Insurance Company

Mitchell Frederick Politzer (a) West Palm Beach, Florida Director, People’s Trust

Insurance Company

Gerald Arnold Levy (b) Boca Raton, Florida Director, People’s Trust

Insurance Company

(a) Resigned on December 31, 2016 as Director, and was replaced by Charles Thomas “Tom”

Gallagher III, appointed by the holding company as Director and Chief Operating Officer on February 1, 2017.

(b) Resigned on December 31, 2016, and was replaced by Adam Hasner on January 1, 2017.

In accordance with the Company’s bylaws, the Board appointed the following senior officers:

Senior Officers

Name City, State Title

Mitchell Frederick Politzer (c) West Palm Beach, Florida President

George William Schaeffer Boca Raton, Florida Chief Executive Officer

Steven Charles Martindale (d) Westerville, Ohio Chief Financial Officer

Brett Ross Frankel Delray Beach, Florida Vice President, Secretary,

and General Counsel

(c) Resigned as President on December 31, 2015, and George William Schaeffer was appointed

President. (d) Resigned on May 13, 2016, and was replaced by George Robert De Heer, immediately

thereafter.

6

The Company’s Board appointed several internal committees. Following were the principal

internal board committees and their members as of December 31, 2015:

Investment Committee

Name City, State Title

George William Schaeffer (1) Boca Raton, Florida Chief Executive Officer

Mitchell Frederick Politzer West Palm Beach, Florida President

1 Chairman

The Company maintained an audit committee, as required by Section 624.424(8) (c), Florida

Statutes.

Audit Committee

Name City, State Title

Gerald Arnold Levy (1) Boca Raton, Florida Director, People’s Trust Insurance Company

Steven Alphonso Giliotti West Palm Beach, Florida Director, People’s Trust Insurance Company

Adam Lawrence Frankel Delray Beach, Florida Director, People’s Trust Insurance Company

1 Chairman

Affiliated Companies

The most recent holding company registration statement was filed with the Office on March 31,

2016, as required by Section 628.801, Florida Statutes, and Rule 69O-143.046, Florida

Administrative Code.

A simplified organizational chart as of December 31, 2015, reflecting the holding company

system, is shown on the following page. Schedule Y of the Company’s 2015 annual statement

provided a list of all related companies of the holding company group.

7

People’s Trust Insurance Company

Simplified Organizational Chart

December 31, 2015

PEOPLE’S TRUST HOLDINGS,

LLC

(FL)

PEOPLE’S TRUST MGA, LLC

(FL)

100%

PEOPLE'S TRUST INSURANCE COMPANY

(FL)

100%

8

The following agreements were in effect between the Company and its affiliates:

Managing General Agency Contract

The Company entered into a Managing General Agency (MGA) Contract (Agreement) with its

affiliate, People's Trust MGA, LLC (PTMGA), effective February 1, 2008. Per the Agreement,

PTMGA provided sales, marketing, inspection, policy administration and claims administration

services for the Company. Per Exhibit B to the Agreement, inspection services were added

effective January 1, 2012. As compensation for the services provided, PTMGA retained a fee of

thirty percent (30%) of direct written premium. The Company paid $72,299,937 to PTMGA for

contractual services during 2015, which includes $15.2 million of PTMGA commission

forgiveness.

Management Services Agreement

The Company entered into a Management Services Agreement (Agreement) with its parent,

People's Trust Holdings (PTH), effective January 1, 2008. Per the Agreement, PTH provided

certain administrative services to the subsidiary, such as corporate organization and management

services, tax services, human resources, benefit plan management, insurance, and group

infrastructure and services. PTH receives a sum equal to one percent (1%) of the Company’s

direct written premiums. The Company paid PTH $2,782,335 for contractual services during

2015.

Services Agreement

The Company entered into a Services Agreement (Agreement) with Rapid Response Team, LLC

(RRT), effective September 14, 2009. Per the Agreement, the Company may issue assignments

to RRT for property loss assessment/mitigation, remediation and repair. RRT is owned by GS

TWO, LLC, which is owned by the same members of PTH. For the year ended December 31,

2015, the Company paid RRT $28,319,034 for services rendered.

9

Cost Allocation Agreement

The Company has a Cost Allocation Agreement with PTMGA, PTH and RRT, effective July 27,

2011, covering allocable expenses incurred by one or more companies conferring a direct benefit

on another company, a portion of which expense is properly allocable to the company receiving

the benefit. Any such balances or reimbursements shall be settled within ninety (90) days. The

Company reported a receivable of $12,130,424 from PTMGA consisting of fees offset by

expenses paid on behalf of PTMGA per the Cost Allocation Agreement by the Company.

TERRITORY AND PLAN OF OPERATIONS

The Company was authorized to transact insurance only in the State of Florida.

Treatment of Policyholders

The Company established procedures for handling written complaints in accordance with Section

626.9541(1)(i) 3.a., Florida Statutes. The Company maintained a claims procedure manual that

included detailed procedures for handling each type of claim in accordance with Section

626.9541(1)(j), Florida Statutes.

REINSURANCE

The reinsurance agreements reviewed complied with NAIC standards with respect to the standard

insolvency clause, arbitration clause, intermediary clause, transfer of risk, reporting and

settlement information deadlines.

Reinsurance Assumed

The Company did not assume any reinsurance during the period of this examination.

10

Reinsurance Ceded

The Company entered into ceded reinsurance agreements with several reinsurers, including DE

Re, Ltd., an affiliate company, to provide protection from losses due to concentration of risk, to

manage its operating leverage ratios and to limit the exposure to losses arising from catastrophic

events. The Company uses both quota share and excess of loss arrangements that require

reinsurers to share risks proportionally or to indemnify the Company on specified parts of certain

types of losses in excess of amounts arising from any one occurrence or event.

The Company was not in compliance with Rule 69O-144.005 6(d)(2) and (e)(1), Florida

Administrative Code, as the Amlin Letter of Credit did not contain the Evergreen Clause requiring

no less than sixty (60) days notice prior to expiration date or nonrenewal, nor did it contain the

requirement that the agreement be governed by the laws of the State of Florida.

ACCOUNTS AND RECORDS

The Company maintained its principal operational offices in Deerfield Beach, Florida. The

Company’s books and records were maintained by electronic processing equipment.

The Company and non-affiliates had the following agreements:

Management Agreement

The Company entered into a Management Agreement with Guggenheim Partners Investment

Management, LLC effective January 13, 2015, to receive investment advisory, management and

related services in accordance with certain Company investment guidelines. Under the terms of

the agreement the Company pays a quarterly management fee based on certain basis points of

the net asset value of the account as provided in the fee schedule.

11

Commitment Agreement

The Company entered into a Commitment Agreement with Guggenheim Private Debt Fund Note

Issuer 2.0, LLC (Issuer), effective September 24, 2015. The Company elected to commit $5.0

million in Limited Liability Company Interests in the Issuer to be allocated by mutual agreement

of the managing member and the investor. The fund was formed as a private investment vehicle

to invest in private debt investments, syndicated bank loans and other non-standard investments.

DC Advisory Consulting Services Agreement

The Company entered into DC Advisory Consulting Services Agreement with UBS Financial

Services Inc. effective January 20, 2015, to receive investment consulting services for the

Company’s 401k/Profit Sharing Plan. The Company pays an asset based fee of zero & five tenths

percent (0.5%) of assets on a quarterly basis.

Institutional Master Custody Agreement

The Company entered into an Institutional Master Custody Agreement with SunTrust Bank,

effective January 5, 2015, to maintain custody of the Company's cash, assets and securities. The

agreement was in compliance with Rule 69O-143.042, Florida Administrative Code.

Broker Services Agreement

The Company entered into a Broker Services Agreement with Guy Carpenter & Company, LLC,

effective January 13, 2015, to serve as a reinsurance intermediary for reinsurance brokering

services and the placement of the Company's reinsurance contracts.

Independent Adjuster/Estimator Services Agreement

The Company and PTMGA entered into an Independent Adjuster/Estimator Services Agreement

for Catastrophe Claims handling services with CNC Catastrophe & National Claims, Inc. (CNC),

effective May 27, 2015. CNC provided oversight and management of the Company's catastrophe-

12

related events and for year-round development, maintenance, coordination, and implementation

of catastrophe response efforts with the People's Trust Catastrophe Management Team.

Master Services Agreement

The Company entered into a Master Services Agreement with ISO Claims Partners (ISO),

effective August 7, 2015. ISO was compensated for fees and expenses annually at the beginning

of each year.

Claims Administration Agreement

The PTMGA entered into a Claims Administration Agreement with Burton Claims Service, Inc.

(Burton), effective April 6, 2015, for the adjusting and administration of the Company's claims.

Burton was compensated $750 per claim for services rendered, of which $500 was payable

through monthly billing and the remaining $250 was payable upon closing the claim.

INFORMATION TECHNOLOGY REPORT

Tracy Gates, CFE, CISA of Highland Clark, LLC, performed an evaluation of the information

technology and computer systems of the Company. Results of the evaluation were noted in the

Information Technology Report provided to the Company.

13

STATUTORY DEPOSITS

The following securities were deposited with the State of Florida as required by Section 624.411,

Florida Statutes:

State Description Par Value Market Value

FL Cash 800,000$ 800,000$

800,000$ 800,000$

-$ -$

-$ -$

800,000$ 800,000$

TOTAL FLORIDA DEPOSITS

TOTAL OTHER DEPOSITS

TOTAL SPECIAL DEPOSITS

14

FINANCIAL STATEMENTS

The examination does not attest to the fair presentation of the financial statements included

herein. If an adjustment is identified during the examination, the impact of such adjustment will

be documented separately following the Company’s financial statements. Financial statements,

as reported and filed by the Company with the Florida Office of Insurance Regulation, are reflected

on the following pages:

15

People’s Trust Insurance Company

Assets

December 31, 2015

Per Company Examination Per Examination

Adjustments

Bonds $161,503,489 $161,503,489

Stocks:

Preferred 1,617,067 1,617,067

Common 19,897,948 19,897,948

Cash and Short-Term Investments 9,445,595 9,445,595

Other investmented assets 7,417,094 7,417,094

Investment income due & accrued 1,495,335 1,495,335

Agents' Balances:

Uncollected premium 3,594,120 3,594,120

Deferred premium 17,593,153 17,593,153

Amounts recoverable from reinsurers 3,141,615 3,141,615

Other amounts receivable under reinsurance contracts 10,540,743 10,540,743

Current federal and foreign income income tax recoverable and interest 2,131,665 2,131,665

Net deferred tax asset 5,582,773 5,582,773

Receivable from parents, subsidiariesand affiliates 12,306,282 12,306,282

Aggregate write-in for other than invested assets 432,639 432,639

Totals $256,699,518 $256,699,518

16

People’s Trust Insurance Company

Liabilities, Surplus and Other Funds

December 31, 2015

Per Company Examination Per Examination

Adjustments

Losses $61,796,645 $61,796,645

Loss adjustment expenses 12,032,146 12,032,146

Other expenses 1,308,567 1,308,567

Taxes, licenses and fees 1,039,978 1,039,978

Unearned premium 66,926,287 66,926,287

Ceded reinsurance premiums payable 25,228,661 25,228,661

Payable to parent, subsidiaries and affiliates 451,229 451,229

Total Liabilities $168,783,513 $168,783,513

Common capital stock $1,000,000 $1,000,000

Surplus notes $54,000,000 $54,000,000

Gross paid in and contributed surplus 31,900,000 31,900,000

Unassigned funds (surplus) 1,016,005 1,016,005

Surplus as regards policyholders $87,916,005 $87,916,005

Total liabilities, surplus and other funds $256,699,518 $256,699,518

17

Peoples Trust Insurance Company

Statement of Income and Capital and Surplus Account

December 31, 2015

Underwriting Income

Premiums earned $139,053,634Deductions:

Losses incurred $85,008,768Loss expenses incurred 17,333,999Other underwriting expenses incurred 41,801,221Aggregate write-ins for underwriting deductions 0Total underwriting deductions $144,143,988

Net underwriting gain or (loss) ($5,090,354)

Investment Income

Net investment income earned $5,481,227Net realized capital gains or (losses) 1,468,030Net investment gain or (loss) $6,949,257

Other Income

Net gain or (loss) from agents' or premium balances charged off $0Finance and service charges not included in premiums 0Aggregate write-ins for miscellaneous income 0

Total other income $0

Net income before dividends to policyholders and before federal & foreign income taxes $1,858,903Dividends to policyholders 0Net Income, after dividends to policyholders, but before federal & foreign income taxes $1,858,903Federal & foreign income taxes (70,169)

Net Income $1,929,072

Capital and Surplus Account

Surplus as regards policyholders, December 31 prior year $89,337,086

Net Income $1,929,072Net unrealized capital gains or losses (1,639,533)Change in net deferred income tax (1,848,518)Change in non-admitted assets (50,000)Aggregate write-ins for gains and losses in surplus 187,897Change in surplus as regards policyholders for the year ($1,421,082)

Surplus as regards policyholders, December 31 current year $87,916,005

18

Peoples Trust Insurance Company

Reconciliation of Capital and Surplus

December 31, 2015

No adjustments were made to surplus as regards policyholders as a result of this examination.

Surplus as regards policyholders

December 31, 2010 per Examination $16,557,550

Gain in Surplus

Loss in Surplus

Net Income (loss) $13,617,008

Change in net unrealized capital gain (loss) ($678,159)

Change in net deferred income tax $4,373,994

Change in non-admitted assets $61,241

Change in surplus notes $54,000,000

Aggregate write-ins for gains and losses in surplus ($15,631)

Rounding $2

Total Gains and Losses $72,052,245 ($693,790)

Net Increase/(Decrease) in surplus as regards policyholders $71,358,455

Surplus as regards policyholders

December 31, 2015 per Examination $87,916,005

19

COMMENTS ON FINANCIAL STATEMENTS

Liabilities

Losses and Loss Adjustment Expenses

Derek P. Chapman, FCAS, MAAA, Merlinos & Associates, Inc., appointed by the Board, rendered

an opinion that the amounts carried in the balance sheet as of December 31, 2015, made a

reasonable provision for all unpaid loss and loss expense obligations of the Company under the

terms of its policies and agreements.

The Office’s consulting actuary, Michael Solomon, FCAS, MAAA, CERA, of The Actuarial

Advantage, Inc., reviewed the loss and loss adjustment expense work papers provided by the

Company, and he was in concurrence with this opinion.

Capital and Surplus

As of December 31, 2015, the amount of capital and surplus reported by the Company of

$87,916,005, exceeded the minimum of $14,075,508 as required by Section 624.408, Florida

Statutes.

20

SUBSEQUENT EVENTS

The Company experienced the following subsequent events after the examination date:

Mitch Politzer retired from the Company effective December 31, 2015. He later resigned as

Director effective December 31, 2016.

George Schaeffer was appointed as President upon Mitch Politzer's departure.

Steve Martindale resigned as Chief Financial Officer and was replaced by George De Heer

effective May 13, 2016. Mr. De Heer was also appointed as Treasurer.

Adam Hasner was appointed to the Board of Directors effective January 1, 2017. He resigned as

Chief Marketing Officer effective March 31, 2016.

Mark Bowsher changed positions from Vice President of Underwriting to Chief Field Operations

Officer.

Kathy Semanate resigned as Chief of Staff effective January 27, 2017. Tom Gallagher III, Chief

Operating Officer, will assume her responsibilities.

21

SUMMARY OF RECOMMENDATIONS

Letter of Credit

We recommend that the Company amend the Amlin Letter of Credit to comply with the provisions

of Rule 69O-144.005 6(d)(2) and (e)(1), Florida Administrative Code, to contain the Evergreen

Clause requiring no less than sixty (60) days notice prior to expiration date or nonrenewal and be

governed by the laws of the State of Florida.

22

CONCLUSION

The insurance examination practices and procedures as promulgated by the NAIC have been

followed in ascertaining the financial condition of People’s Trust Insurance Company as of

December 31, 2015, consistent with the insurance laws of the State of Florida.

Per examination annual financial statements, the Company’s surplus as regards policyholders

was $87,916,005, which exceeded the minimum of $14,075,508 required by Section 624.408,

Florida Statutes.

In addition to the undersigned, Mark Jaster, CFE, Examiner-In-Charge, Travis Harrison, CPA, and

Sam Hebert, Participating Examiners, of Highland Clark, LLC, also participated in the

examination. Members of the Office who participated in the examination include Jeffrey Rockwell,

MBA, Financial Examiner/Analyst Supervisor, Examination Manager, and Kyra Brown, APIR,

Financial Examiner/Analyst Supervisor, Participating Examiner. Additionally, Michael Solomon,

FCAS, MAAA, CERA, of The Actuarial Advantage, Inc., and Tracy Gates, CFE, CISA, IT

Specialist of Highland Clark, LLC, are recognized for participation in the examination.

Respectfully submitted,

Brian Sewell, CFE, MCM Chief Examiner Florida Office of Insurance Regulation