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STATE OF NEW YORK INSURANCE DEPARTMENT
REPORT ON EXAMINATION
OF
THE UNION LABOR LIFE INSURANCE COMPANY
AS OF
SEPTEMBER 30, 2000
DATE OF REPORT: MARCH 16, 2001
EXAMINER:
BRIAN E. GLAAB

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TABLE OF CONTENTS
ITEM
PAGE
NO.
1.
Executive summary
2
2.
Scope of examination
3
3.
Description of Company
4
A. History
4
B. Holding company
5
C. Management
9
D. Territory and plan of operation
13
4.
Allocation of net investment income
15
5. Policy
forms
16
6.
Third party administrators
17
7.
Summary and conclusions
18

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http://www.ins.state.ny.us
STATE OF NEW YORK
INSURANCE DEPARTMENT
25 BEAVER STREET
NEW YORK, NEW YORK 10004
March 16, 2001
Honorable Gregory V. Serio
Superintendent of Insurance
Albany, New York 12257
Sir:
In accordance with instructions contained in Appointment No. 21651, dated
November 15, 2000 and annexed hereto, an examination has been made into the condition and
affairs of The Union Labor Life Insurance Company, hereinafter referred to as "the Company,"
at its home office located at 111 Massachusetts Avenue, NW, Washington, DC 20001.
Wherever "Department" appears in this report, it refers to the State of New York
Insurance Department.
The report indicating the results of this examination is respectfully submitted.

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2
1. EXECUTIVE SUMMARY
The Company has been deemed a domestic insurer pursuant to Section 1501(d) of the
New York Insurance Law. (See item 3D of this report)
The Company violated Section 1505(d) of the New York Insurance Law by failing to
provide notification to the superintendent of its intention to enter into a number of transactions
with members of the holding company system prior to entering into such transactions. (See item
3B of this report)
The Company violated Section 308(a) of the New York Insurance Law and failed to
comply with Department Circular Letter No. 33 (1979) by not notifying the Department of the
amended tax allocation agreement.
The Company violated Section 4228(d) of the New York Insurance Law by paying
agents and general agents commissions in excess of the first year limitations. (See item 3D of
this report)
The Company violated Section 4228(f)(1) of the New York Insurance Law by not filing
its agent compensation plan with the Department. (See item 3D of this report)
The Company violated Section 91.5(b) of Department Regulation No. 33 by adopting a
method of distributing net investment income to major annual statement lines of business, which
deviates from the rules prescribed in Section 91.5(a) of Department Regulation No. 33, without
obtaining the superintendent's prior approval. (See item 4 of this report)
The Company violated Section 3201(b)(1) of the New York Insurance Law by delivering
policy forms in New York State that were not filed with and approved by the superintendent, and
using forms that contain language not approved by the superintendent. (See item 5 of this report)
The Company violated Section 2108(a)(3) of the New York Insurance Law by allowing
third party administrators to act on behalf of the Company without being licensed as independent
adjusters. (See item 6 of this report)

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3
2. SCOPE OF EXAMINATION
The examination covers the period from January 1, 1998 through September 30, 2000.
As necessary, the examiner reviewed transactions occurring subsequent to September 30, 2000
but prior to the date of this report (i.e., the completion date of the examination).
The examination comprised a review of holding company transactions, policy forms,
agent compensation filings, independent adjuster licensing, and replacements. The examiner
utilized the National Association of Insurance Commissioners' Examiners Handbook or such
other examination procedures, as deemed appropriate, in such review and in the review or audit
of the aforementioned matters.
This report on examination is confined to comments on matters which involve departure
from laws, regulations, or rules or which require explanation or description.

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4
3. DESCRIPTION OF COMPANY
A. History
The Company was incorporated as a stock life insurance company under the laws of
Maryland on October 26, 1925 and commenced business on May 1, 1927. The Company was
granted a license by the Department to conduct business in the state of New York on May 31,
1927.
On December 31, 1926, the Company was authorized to issue 40,000 shares of common
stock. In 1987, the authorization was increased to 360,000 shares of common stock.
As of December 31, 1926, the Company's capital and surplus of $635,950, consisting of
common capital stock of $317,975 and paid in and contributed surplus of $317,975, were
provided through the sale of 12,719 shares of common stock (with a par value of $25 each) for
$50 per share. As of December 31, 1997, capital and paid in and contributed surplus were
$3,578,700 and $84,000,000 respectively. In December 1999, the parent, ULLICO Inc., made a
cash contribution to the Company in the amount of $15,000,000. (See item 3B of this report) As
of September 30, 2000, capital and paid in and contributed surplus were $3,578,700 and
$99,000,000 respectively.
The Company was founded in 1925 by the American Federation of Labor to provide
insurance protection at the lowest possible cost to union members. During 1987, ULLICO Inc.,
a holding company, was formed and all of the stockholders' shares in the Company were
transferred to ULLICO Inc. in exchange for an equal number of shares of ULLICO Inc. This
exchange resulted in the Company becoming a wholly owned subsidiary of ULLICO Inc.
Ownership of ULLICO Inc. shares is limited to labor organizations and their members.
ULLICO Inc.'s by-laws prohibit stockholders from selling their shares of ULLICO Inc. stock
without first offering them to ULLICO Inc. at $25 per share. It is ULLICO Inc.'s practice to
repurchase these shares and resell them to labor unions and their members.

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B. Holding Company
The Company is a wholly owned subsidiary of ULLICO Inc., a Maryland privately
owned holding company established in 1987.
An organization chart reflecting the relationship between the Company and significant
entities in its holding company system as of December 31, 1999 follows:
Zenith
Administrators,
Inc.
Union Standard
of America Life
Insurance
Company
ULLICO
Life
Insurance
Company
ULLICARE,
Ltd.
(99%)
The Union Labor
Life Insurance
Company
UNIONCARE
of Texas,
Inc.
UNIONCARE,
Inc.
Ulico Indemnity
Company
USAAC
Property
Ulico Standard
of America
Casualty
Company
Ulico
Casualty
Company
Tri Star
Managers
Insurance
Servicers, Inc.
Five-Star
Managers
LLC
Tri-City
Brokerage,
Inc.
Tri-City
Brokerage
of Illinois, Inc.
Tri-City
Insurance
Brokers, Inc.
Ulico
Insurance
Group,
Inc.
AMI
Capital, Inc.
Thornapple
Holdings,
Inc.
UlicoCawil
Partnership,
L.P.
Ulico Villa
Piedra
Partnership,
L.P.
Ulico
Fairpark
Partnership,
L.P.
Genpar,
Inc.
ULLICO
Mortgage
Corporation
HomeFirst,
Inc.
FFSFC
Residual, Inc.
Financial
Freedom
Senior Funding
Corp.
Securitas
Financial
Services, Inc.
MRCo,
Inc.
Trust Fund
Advisors
Inc.
ULLICARE,
Ltd.
(1%)
ULLICARE,
Inc.
ULLICO
Management
Company
ULLICO
Inc.

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6
The Company has three subsidiaries. Two are wholly owned life insurance companies:
Union Standard of America Life Insurance Company, a Maryland company, and ULLICO Life
Insurance Company, a Texas company. The other company, ULLICARE, Ltd. is a 99% owned
preferred provider organization. The holding company system consists of three other insurance
companies: Ulico Casualty Company, a Delaware company, Ulico Indemnity Company, an
Arkansas company, and Ulico Standard of America Casualty Company, a California company.
The Company had nine service agreements with its' parent and affiliates in effect as of
September 30, 2000. ULLICO Inc. has a consolidated services agreement incorporating all of its
affiliated companies, including the Company. Under this agreement, services provided include,
but are not limited to, accounting, tax and auditing, legal, actuarial, financial management,
underwriting, claims management, risk management, employee benefit plans and personnel
administration, sales, electronic data processing, communication, and investment services.
ULLICO Inc. has a consolidated income tax allocation agreement incorporating all of its
affiliated companies.
The Company has two reinsurance treaties with an affiliate, Ulico Casualty Company.
The first agreement, effective December 8, 1993, covers all excess and stop loss business written
on or after December 1, 1992 and assumed by the Company. The second agreement, effective
December 2, 1999 covers all accident and health business written by Ulico Casualty Company
and assumed by the Company.
The Company has five investment advisory agreements in effect with Trust Fund
Advisors ("TFA"), whereby TFA was appointed investment manager for five of the Company's
separate accounts.
The Company has a sub-advisory agreement with TFA, whereby the Company is named
sub-advisor pertaining to real estate assets with respect to certain employee benefit plans.

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Section 1505(d) of the New York Insurance Law states, in part:
"The following transactions between a domestic controlled insurer and any person
in its holding company system may not be entered into unless the insurer has
notified the superintendent in writing of its intention to enter into any such
transaction at least thirty days prior thereto, or such shorter period as he may
permit, and he has not disapproved it within such period:
(1) sales, purchases, exchanges, loans or extension of credit, or investments,
involving more than one-half of one percent but less than five percent of the
insurer's admitted assets at last year-end;
(2) reinsurance treaties or agreements;
(3) rendering of services on a regular or systematic basis . . . "
The following transactions were in violation of Section 1505(d)(1) of the New York
Insurance Law:
1. In December 1999, the parent, ULLICO Inc., made a surplus contribution to the Company in
the amount of $15,000,000. The amount of this transaction was approximately 0.56% of the
Company's 1998 admitted assets. The Company failed to provide notice to the superintendent
of this transaction.
2. In December 1999, the Company transferred its interest in certain limited partnerships,
amounting to $19,328,447, to MRCo, Inc., an affiliate, in exchange for a three-year
promissory note dated December 30, 1999. This transaction amounted to approximately
0.72% of the Company's 1998 admitted assets. The Company did not notify the
superintendent prior to entering into this transaction.
The Company violated Section 1505(d)(1) of the New York Insurance Law by failing to
provide the superintendent notice prior to entering into the aforementioned transactions with
members of its holding company system which exceeded one-half of one percent of its prior
year's admitted assets.
The Company failed to notify the superintendent prior to entering into two reinsurance
treaties with Ulico Casualty Company, an affiliate. The Company violated Section 1505(d)(2) of
the New York Insurance Law by failing to notify the superintendent prior to entering into
reinsurance treaties with an affiliate.
The examiner notified the Company that it was required to submit the above two
transactions and the two reinsurance agreements to the superintendent pursuant to Section
1505(d) of the New York Insurance Law. The Company submitted the two transactions and the

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8
reinsurance agreement for accident and health insurance to the superintendent on February 20,
2001.
The following transactions were in violation of Section 1505(d)(3) of the New York
Insurance Law as follows:
1. The Company participates in a consolidated services agreement with other members of the
holding company. The Company submitted a consolidated services agreement, dated May 1,
1994, to the superintendent with a cover letter dated September 21, 1998. This agreement was
disapproved by the Department on October 20, 1998, however the Company continued to
participate in the agreement after disapproval.
2. The Company entered into an investment management agreement with TFA to manage the
Company's separate account "R". The agreement was entered into on October 1, 1996 and
was not submitted to the superintendent.
3. The Company entered into a sub-advisory agreement, pertaining to the management of real
estate, with TFA on October 1, 1994 and amended it as of January 1, 1995. The Company did
not notify the superintendent of either the agreement or the amendment.
The Company violated Section 1505(d)(3) of the New York Insurance Law by failing to
notify the superintendent of a consolidated services agreement, an investment management
agreement and a sub-advisory agreement, including an amendment, thirty days prior to entering
into such agreements or amendment.
The Company submitted its consolidated services agreement and the sub-advisory
management agreement to the superintendent on March 16, 2001.
The Company entered into four additional investment management agreements with TFA
to manage four of the Company's separate accounts. Each agreement was entered into prior to
the examination period. Amendments were made to Separate Accounts "A" and "I" effective
January 1, 1992. The Company submitted the investment management agreements, and
amendments, for these separate accounts to the superintendent on April 26, 1999.
The examiner recommends that, in the future, the Company file its inter-company
agreements with the superintendent thirty days prior to entering into such agreement in
compliance with Section 1505(d)(3) of the New York Insurance Law.

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9
Section 308(a) of the New York Insurance Law states, in part:
"The superintendent may also address to any . . . authorized insurer or its officers
any inquiry in relation to its transactions or condition or any matter connected
therewith. Every corporation or person so addressed shall reply in writing to such
inquiry promptly . . . "
Department Circular Letter No. 33 (1979) provides guidelines to assure that tax
allocation agreements are fair and equitable and give appropriate recognition to the separate
operating identity of the domestic insurer consistent with various sections of the Insurance Law.
Department Circular Letter No. 33 (1979) advises that:
"Any domestic insurer . . . shall file a copy of its tax allocation agreement with
this Department within 30 days of electing to do so. Furthermore, notification to
this Department should be given within 30 days of any amendment . . . "
The Company participates in a consolidated income tax allocation agreement, dated
December 31, 1987, with other members of the holding company. The agreement was amended
as of May 1, 2000. The Company failed to file the amended agreement with the superintendent.
The Company violated Section 308(a) of the New York Insurance Law and failed to
comply with Department Circular Letter No. 33 (1979) by not notifying the Department of the
amended agreement.
The Company submitted its tax allocation agreement to the superintendent on March 16,
2001.
C. Management
The Company's by-laws provide that the board of directors shall be comprised of not less
than 15 and not more than 32 directors. Directors are divided into three classes and are elected
for a period of three years at the annual meeting of the stockholders held in April. As of
September 30, 2000, the board of directors consisted of 29 members. Meetings of the board are
held annually.

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The 29 board members and their principal business affiliation, as of September 30, 2000,
were as follows:
Name and Residence
Principal Business Affiliation
Year First
Elected
Morton Bahr *
Washington, DC
President
Communications Workers of America
1996
John J. Barry *
Chevy Chase, MD
President Emeritus
International Brotherhood of Electrical Workers
1987
William G. Bernard *
Potomac, MD
President
International Association of Heat and Frost
Insulators and Asbestos Workers
1996
Morris Biller *
Arlington, VA
President
American Postal Workers Union
1987
Marvin J. Boede *
Potomac, MD
Retired President
United Association of Journeymen and
Apprentices of the Plumbing and Pipefitting
Industry of the United States and Canada
1983
Kenneth J. Brown *
Charlottesville, VA
Retired President
The Graphic Communications International
Union
1973
Bill Casstevens *
Oklahoma City, OK
Retired Secretary ? Treasurer
United Automobile, Aerospace and Agricultural
Implement Workers of America International
Union
1994
Arthur A. Coia *
Barrington, RI
President Emeritus
Laborers' International Union of North America
1993
John E. Cullerton *
Chicago, IL
Consultant
Hotel Employees & Restaurant Employees
International Union
1995
John F. Gentleman
Fort Meyers, FL
Retired President
The Union Labor Life Insurance Company
1992
Robert A. Georgine
Silver Spring, MD
Chairman, President and Chief Executive Officer
The Union Labor Life Insurance Company
1981

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Name and Residence
Principal Business Affiliation
Year First
Elected
Frank Hanley *
Kensington, MD
President
International Unions of Operating Engineers
1990
Frank D. Hurt *
Columbus, OH
International President
Bakery, Confectionery and Tobacco Workers
International Union
1995
John T. Joyce *
Washington, DC
Retired President
International Union of Bricklayers and Allied
Craftworkers
1981
Earl J. Kruse *
Palos Park, IL
President
United Union of Roofers, Waterproofers and
Allied Workers
1999
James La Sala *
Silver Spring, MD
President
Amalgamated Transit Union
1985
Martin J. Maddaloni *
Philadelphia, PA
General President
United Association of Journeymen and
Apprentices of the Plumbing and Pipe Fitting
Industry of the United States and Canada
1998
Joseph F. Maloney *
Rockville, MD
Retired Secretary ? Treasurer
Building and Construction Trades Department,
AFL-CIO
1995
Douglas J. McCarron *
Agoura Hills, CA
General President
United Brotherhood of Carpenters and Joiners of
America
1996
James F. McNulty
Great Falls, VA
General Counsel
The Union Labor Life Insurance Company
1968
Lenore Miller *
Little Silver, NJ
Retired President
Retail, Wholesale and Department Store Union
1987
Terence M. O'Sullivan *
Clifton, VA
General President
Laborers International Union of North America
2000
Vincent R. Sombrotto *
Port Washington, NY
President
National Association of Letter Carriers
1995

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Name and Residence
Principal Business Affiliation
Year First
Elected
John J. Sweeney *
Bethesda, MD
President
AFL-CIO
1985
Eugene Upshaw *
Great Falls, VA
President
Federation of Professional Athletes
1987
Jacob F. West *
Washington, DC
General President Emeritus
International Association of Bridge, Structural
and Ornamental Iron Workers
1990
John W. Wilhelm *
Santa Barbara, CA
General President
Hotel Employees & Restaurant Employees
International Union
2000
William H. Wynn *
Bonita Springs, FL
President Emeritus
United Food and Commercial Workers
International Union
1987
Roy Wyse *
Richmond, MO
Retired Secretary ? Treasurer
United Automobile, Aerospace and Agricultural
Implement Workers of America International
Union
1997
* Not affiliated with the Company or any other company in the holding company system
The following is a listing of the principal officers of the Company as of September 30,
2000:
Name
Title
Robert A. Georgine
Chairman, President and Chief Executive Officer
James W. Luce
Executive Vice President
John Kenneth Grelle
Senior Vice President and Chief Financial Officer
James F. McNulty
General Counsel
Grover L. McKean
Senior Vice President Investments
Joseph A. Carabillo*
Chief Legal Counsel
*Designated consumer services officer per Section 216.4(c) of Department Regulation No. 64

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D. Territory and Plan of Operation
The Company is authorized to write life insurance, annuities and accident and health
insurance as defined in paragraphs 1, 2 and 3 of Section 1113(a) of the New York Insurance
Law.
The Company is licensed to transact business in all 50 states and the District of
Columbia. In 1999, 25.36% of the Company's total premiums were received from New York.
The Company is a domestic insurer pursuant to Section 1501(d) of the New York Insurance Law.
Policies are written on a participating basis.
The following tables show the percentage of direct premiums received by state and by
major lines of business for the year 1999:
Accident
and
Health
Life Insurance Premiums Insurance Premiums
New York
20.4%
New York
27.2%
California
11.2
California
18.6
Subtotal 31.6%
Subtotal 45.8%
All others
68.4
All others
54.2
Total 100.0%
Total
100.0%
The Company's principal lines of business are group life and group accident and health,
which are primarily marketed to union workers. The Company's accident and health product
line consists mainly of indemnity medical, insured Participating Provider Organization, stop-
loss, and accidental death and dismemberment coverages. The Company has changed its focus
from indemnity medical plans to insured and self-funded managed care plans. The Company is
focusing on increasing its presence in the Taft/Hartley market. The passage of the Act allowed
unions to provide certain benefits to members. The majority of the group life and accident and
health business is solicited by full time salaried sales staff working with brokers, while a lesser
amount is solicited through mass marketing.
The Company's individual life and accident and health businesses are solicited on a
general agency basis and through direct marketing.

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Section 4228(d) of the New York Insurance Law states, in part:
"A company may pay its agents as it sees fit for the sale and service of policies
and contracts. However:
(1) No company shall pay or permit to be paid to an agent a commission in excess
of the sum of (A) fifty-five percent of any qualifying first year premium and (B)
seven percent of any excess premium; or to a general agent with respect to
business not personally produced by such general agent, a commission in excess
of the sum of (C) sixty three percent of any qualifying first year premium and (D)
eight percent of any excess premium. . . . "
The Company's commission schedule for agents at the levels of Agent and Agent I
indicate that the commission rate for the Company's MA Senior Life product is in excess of the
first year premium limitation. Also, the commission rates for five levels of general agents for the
Company's MA Senior Life product are in excess of the first year premium limitation. The
Company acknowledged that commissions paid for the sale of 152 MA Senior Life policies
during the examination period exceeded the first year commission limitation.
The Company violated Section 4228(d) of the New York Insurance Law by paying
agents and general agents commissions in excess of the first year limitations.
Section 4228(f)(1) of the New York Insurance Law states, in part:
"Filing requirements for agent compensation plans are as follows:
(A) A company shall make annual information filings with respect to any newly-
introduced plans or changes under which the company makes payments to agents
if such plans are commission plans for which the commission percentages are, in
all policy or contract years, no greater than the commission percentages set forth
in paragraphs one, two, three and four of subsection (d) of this section . . . "
The Company did not file its compensation plan with the Department and therefore
violated Section 4228(f)(1) of the New York Insurance Law.

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4. ALLOCATION OF NET INVESTMENT INCOME
The Company uses the investment year method to allocate net investment income to the
major annual statement lines of business, excluding GIC's and individual annuities that have
segmented asset portfolios. The Department treats this method as a variant of the net investment
year method and requires approval prior to being adopted.
Section 91.5(b) of Department Regulation No. 33 states, in part:
" . . . If the company's method includes deviations from the foregoing rules, or
contemplates the use of a method other than the investment year method for assets
not listed in paragraph (a)(1), such deviations or use require the approval of the
superintendent as being equitable and as being necessary for reasons of feasibility
before the method can be adopted."
The Company filed its method of allocating net investment income on January 31, 1968,
and there have been no amendments filed since that time. The Company's method of allocating
net investment income during the examination period deviates from the method previously
submitted to the Department by including "Other" in its current method of allocating net
investment income. The Company failed to submit the amended method to the superintendent
for approval prior to adopting this method.
The Company violated Section 91.5(b) of Department Regulation No. 33 by adopting a
method of distributing net investment income to major annual statement lines of business which
deviates from the rules prescribed in Section 91.5(a) of Department Regulation No. 33, without
obtaining the superintendent's prior approval.

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5. POLICY FORMS
Section 3201(b)(1) of the New York Insurance Law states, in part:
"No policy form shall be delivered or issued for delivery in this state unless it has
been filed with and approved by the superintendent as conforming to the
requirements of this chapter and not inconsistent with law. . . . "
The Company delivered medicare supplement forms 8331, 615400C and 8338 in New
York State that were not filed with and approved by the superintendent. The Company indicated
that a total of 269 such medicare supplement forms were issued in New York.
The Company uses policy form Ind. A.H. 1408.18.NY to convert group health policies to
individual policies. The conversion form that the Company uses deviates from the form filed
and approved by the superintendent. The examiner determined that 41 health policies were
converted using policy form Ind. A.H. 1408.18.NY during the examination period.
The Company issued 13 group life contracts using policy form GP-9100.NY, which
contained language that varied from what was approved by the superintendent. The Company
also issued one group accidental death and dismemberment contract using policy form GP-
9200.NY, which contained language that varied from the form approved by the superintendent.
In addition, the Company issued four group excess loss policies using policy form 300NY, which
contained language that varied from the form approved by the superintendent.
The Company violated Section 3201(b)(1) of the New York Insurance Law by delivering
policy forms in New York State that were not filed with and approved by the superintendent and
also using forms that contained language not approved by the superintendent.

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6. THIRD PARTY ADMINISTRATORS
The Company has agreements with three third party administrators whereby the third
party administrators provide claim payment services for the Company.
Section 2101(g)(1) of the New York Insurance Law states, in part:
"The term "independent adjuster" means any person, firm, association or
corporation who, or which, for money, commission or any other thing of value,
acts in this state on behalf of an insurer in the work of investigating and adjusting
claims arising under insurance contracts issued by such insurer and who performs
such duties required by such insurer as are incidental to such claims . . . "
Section 2108(a)(3) of the New York Insurance Law states, in part:
"No adjuster shall act on behalf of an insurer unless licensed as an independent
adjuster . . . "
During the examination period each of the third party administrators acted as an
independent adjuster on behalf of the Company by investigating and adjusting health claims
arising under insurance contracts issued by the Company, without being licensed as an
independent adjuster.
The Company violated Section 2108(a)(3) of the New York Insurance Law by allowing
third party administrators to act on behalf of the Company without being licensed as independent
adjusters.
The Company's agreement with one of the administrators terminated as of January 1,
2001.

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7. SUMMARY AND CONCLUSIONS
Following are the violations, recommendations and comments contained in this report:
Item Description Page
No(s).
A
The Company violated Section 1505(d)(1) of the New York Insurance
Law by failing to provide the superintendent notice thirty days prior to
entering into transactions with members of its holding company system
which exceeded one-half of one percent of its prior year's admitted
assets.
7
B
The Company violated Section 1505(d)(2) of the New York Insurance
Law by failing to notify the superintendent thirty days prior to entering
into two reinsurance treaties with an affiliate.
7
C
The Company violated Section 1505(d)(3) of the New York Insurance
Law by failing to notify the superintendent thirty days prior to entering
into; a consolidated services agreement, an investment management
agreement and a sub-advisory agreement (including an amendment).
8
D
The examiner recommends that, in the future, the Company file its inter-
company agreements with the superintendent thirty days prior to
entering into such agreements in compliance with Section 1505(d)(3) of
the New York Insurance Law.
8
E
The Company violated Section 308(a) of the New York Insurance Law
and failed to comply with Department Circular Letter No. 33 (1979) by
not notifying the Department of the amended tax allocation agreement.
9
F
The Company violated Section 4228(d) of the New York Insurance Law
by paying agents and general agents commissions in excess of the first
year limitations.
14
G
The Company violated Section 4228(f)(1) of the New York Insurance
Law by not filing its agent compensation plan with the Department.
14
H
The Company violated Section 91.5(b) of Department Regulation No.
33 by adopting a method of distributing net investment income to major
annual statement lines of business, which deviates from the rules
prescribed in Section 91.5(a) of Department Regulation No. 33, without
obtaining the superintendent's prior approval.
15

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19
Item Description
Page
No(s).
I
The Company violated Section 3201(b)(1) of the New York Insurance
Law by delivering policy forms in New York State that were not filed
with and approved by the superintendent and also using forms that
contained language not approved by the superintendent.
16
J
The Company violated Section 2108(a)(3) of the New York Insurance
Law by allowing third party administrators to act on behalf of the
Company without being licensed as independent adjusters.
17

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Respectfully
submitted,
Brian E. Glaab
Senior Insurance Examiner
STATE OF NEW YORK )
)SS:
COUNTY OF NEW YORK )
BRIAN E. GLAAB, being duly sworn, deposes and says that the foregoing report,
subscribed by him, is true to the best of his knowledge and belief.
Brian E. Glaab
Subscribed and sworn to before me
this
day of
2001.

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