TOI: 24.0 Surety SERFF Status: Closed-Filed State Tr Num: Sub-TOI: Surety Co Tr Num: AAIC-SURETY-11 State Status:

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1 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Project Name/Number: Aspen Commercial Surety Non-Construction Rating Plan Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Filing at a Glance Company: Aspen American Insurance Company Product Name: Aspen Commercial Surety Non- SERFF Tr Num: REGU State: Wisconsin Construction Rating Plan TOI: 24.0 Surety SERFF Status: Closed-Filed State Tr Num: Sub-TOI: Surety Co Tr Num: AAIC-SURETY-11 State Status: Filing Type: Rate/Rule Reviewer(s): Stephanie Cook Author: Jeremy Battles Disposition Date: 05/23/2011 Date Submitted: 05/20/2011 Disposition Status: Filed Effective Date Requested (New): 05/20/2011 Effective Date (New): Effective Date Requested (Renewal): 05/20/2011 Effective Date (Renewal): General Information Project Name: Aspen Commercial Surety Non-Construction Rating Plan Status of Filing in Domicile: Pending Project Number: AAIC-SURETY-11 Domicile Status Comments: Reference Organization: N/A Reference Number: N/A Reference Title: N/A Advisory Org. Circular: N/A Filing Status Changed: 05/23/2011 State Status Changed: Deemer Date: Created By: Jeremy Battles Submitted By: Jeremy Battles Corresponding Filing Tracking Number: Filing Description: Aspen American Insurance Company (AAIC) is submitting its new Commercial Surety Non-Construction Rating Plan. The attached Plan will be used to develop end rates for surety bonds that recognize the relative credit quality of each prospective or existing account through the application of a series of financial and risk factors to base rates. We ask that this filing become effective May 20, Company and Contact Filing Contact Information Jeremy Battles, Senior Analyst jeremybattles@ircllc.com 50 Broad Street [Phone] PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

2 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Suite 501 New York, NY Filing Company Information (This filing was made by a third party - insuranceregulatoryconsultantsllc) Aspen American Insurance Company CoCode: State of Domicile: Texas 590 Madison Ave Group Code: 4698 Company Type: 7th Floor, Group Name: Aspen Ins. Holdings State ID Number: Ltd New York, NY FEIN Number: (646) ext. [Phone] Filing Fees Fee Required? Retaliatory? Fee Explanation: Per Company: No No No COMPANY AMOUNT DATE PROCESSED TRANSACTION # Aspen American Insurance Company $0.00 PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

3 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Correspondence Summary Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Dispositions Status Created By Created On Date Submitted Filed Shasta Hoffhein 05/23/ /23/2011 PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

4 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Project Name/Number: Disposition Aspen Commercial Surety Non-Construction Rating Plan Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Disposition Date: 05/23/2011 Effective Date (New): Effective Date (Renewal): Status: Filed Comment: Filed is used with rates, rules and advertisements. Rate data does NOT apply to filing. PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

5 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Schedule Schedule Item Schedule Item Status Public Access Supporting Document Rate Filed Yes Supporting Document Rule Filed Yes Supporting Document Filing Authorization Letter Filed Yes Rate Commercial Surety Non-Construction Rating Plan Filed Yes PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

6 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Rate Information Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Rate data does NOT apply to filing. PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

7 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Rate/Rule Schedule Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Schedule Item Exhibit Name: Rule # or Page Rate Action Previous State Filing Attachments Status: #: Number: Filed 05/23/2011 Commercial Surety Non-Construction Rating Plan Pages 1-9 New Commercial Surety Rating Plan - Pgs 1-9.pdf PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

8 Aspen American Insurance Company Commercial Surety Non-Construction Rating Plan I. PURPOSE OF COMMERCIAL SURETY NON-CONSTRUCTION RATING PLAN The purpose of the ASPEN AMERICAN INSURANCE COMPANY (AAIC) Commercial Surety Non-Construction Rating Plan (Plan) is to develop end rates for surety bonds that recognize the relative credit quality of each prospective or existing account through the application of a series of financial and risk factors to base rates. The rates contemplate the overall credit risk presented by the account, the risk of loss under the various classes of bonds needed and the expense of underwriting and handling the account s bond needs, including commission. II. PLAN ELIGIBILITY A. The plan applies to bonds that meet all of the criteria outlined below. Bonds that meet these eligibility requirements cannot be written outside of this plan, and bonds that do not meet these eligibility requirement cannot be written in this plan. The required criteria are: 1. Miscellaneous and commercial contract surety bonds, 2. Issued or procured by AAIC 3. Issued for commercial surety (non-construction) accounts or individuals, 4. In accordance with all applicable state and federal laws, 5. With obligees domiciled in the United States of America B. The Plan does not apply to the following types of bonds: -- Probate for individual estates and Fiduciary Bonds generating less than $1000 in annual premium. C. Bonds are defined in accordance with the Manual of Rules, Procedures and Classifications for Surety Bonds published by the Surety & Fidelity Association of America. III. COMMON GENERAL RULES A. ACCOUNT RATE(S) AND PREMIUM ADJUSTMENTS AT TERMINATION 1. Account rate(s) are determined at the initial rating of the account. Upon receipt of periodic financial statements or other notification of change in the account, the statements/changes will be analyzed in relation to the account s bonded activity to determine the current financial strength of the account. If it is determined that the current rating structure continues to reflect the financial condition and the bonded activity of the account, the current account rate will be maintained. Should the account analysis reveal conditions not contemplated at the initial rating, new account rate(s) can be established. 2. The first year and renewal premiums for all surety bonds, except as set forth in A.3 below or when a term premium is applicable, shall be adjusted pro-rata upon termination. Term premiums are fully earned. 3. The first year premium for a Court Bond is fully earned, unless otherwise negotiated. Annual premium for the second and subsequent years for the same bond will be returned on a pro-rata basis upon cancellation. B. MINIMUM PREMIUM The minimum premium for each surety bond is $ and shall be fully earned. There is no minimum premium for Lost Securities Bonds that are issued as part of a blanket lost securities bond program. Page 1 of 9

9 Aspen American Insurance Company C. ADVANCE PAYMENT OF PREMIUMS 1. When annual premiums for a surety bond, other than one classified as a Contract Surety Bond, are paid in advance for two years or more, a prepaid discount factor of 15% may be applied to the sum of premiums for the second and subsequent years. 2. If a bond is cancelled after one year, but before expiration of the period for which advance premium was paid, re-compute the premium for the period the bond remained in force, allowing a discount where length of term warrants it, and refund the balance. D. ACCOUNT RATE RULE The final account rate(s) shall be rounded to the nearest $.05. E. WHOLE DOLLAR PREMIUM RULE The premium for each surety bond shall be rounded to the nearest whole dollar. A premium involving $0.50 or over shall be rounded to the next higher whole dollar. F. RENEWAL PREMIUMS FOR NON-CANCELABLE SURETY BONDS Renewal premiums for all bonds that cannot be unilaterally cancelled by the principal may be adjusted during the term of the bond, subject to the rates and rules of the Plan. G. MAXIMUM AMOUNT OF COVERAGE The maximum amount of coverage for the Minimum Premium shall be given whenever permitted. H. UNLISTED BONDS Where a bond does not clearly fall within the scope of any listed Manual classification, contact Aspen Surety senior management for class code classification. I. INDIVIDUALLY RATED BONDS The surety reserves the right to individually rate any bond or obligation that was not anticipated at the time the account rate was established. J. RATING In the calculation of end rates, all factors are combined on a multiplicative basis. K. SURETY S RIGHT OF SUBROGATION The guarantee covered by the bond is the primary obligation of the principal obligor and if the principal obligor fails to fulfill its obligation and the surety makes good the principal s default, the surety is subrogated to the rights of the obligee against the principal obligor. Page 2 of 9

10 Aspen American Insurance Company IV. Description of the Plan A. The Plan consists of two pricing components. The first part of the Plan is objective and used to develop end rates from base rates and the Account Risk Premium Modification (ARPM) is a subjective plan that modifies base end rates reflecting characteristics of the account which are not fully reflected in the development of an account s base end rates. B. The Plan separates bonds into three categories; Miscellaneous, Commercial Contract, and Fiduciary / Lost Securities Bonds (LSB). The Miscellaneous and Commercial Contract categories are further broken down into 6 classes for which rates can be calculated within the Plan, four miscellaneous (two financial and two compliance classes) and two commercial contract. The Fiduciary / Lost Securities Bond rate class may be used for accounts with LSB program business or for individuals needing Fiduciary Bonds. Rates are calculated only for those classes of bonds needed by the account. 1. Miscellaneous Surety Bond Class Definitions: Financial High bonds - Self-insurer s workers compensation, appeal, large deductible, paid loss retro and other more hazardous bonds that are primarily financial in nature. A bond is considered being financial in nature when its core obligation is to guarantee the principal will make one or more payments such as paying a court judgment, etc. Compliance High bonds - Reclamation, plugging and abandonment, closure/post closure and other more hazardous bonds that are primarily compliance in nature. A bond is considered being compliance in nature when its core obligation is to guarantee the principal will perform obligations relating to the conduct of its business such as reclaiming coal mines or plugging oil wells, etc. Financial Low bonds - Tax, utility, plaintiffs attachment, plaintiffs injunction, plaintiffs replevin, customs, depository, and other less hazardous bonds that are primarily financial in nature. Compliance Low bonds - Cable, license & permit and other less hazardous bonds that are primarily compliance in nature. 2. Commercial Contract Surety Bond Class Definitions: Contract High bonds - Bonds covering hazardous, advance payment, completion, subdivision, and other miscellaneous contracts that tend to be fixed price and more hazardous and/or complex in nature. Contract Low bonds - Bonds covering service contracts, supply & install, supply, and maintenance that are generally less hazardous in nature. 3. Fiduciary Bonds for Individuals and Lost Securities Bond Programs Trustee in Bankruptcy Bonds, Probate Bonds, Lost Securities Bonds, etc. are generally written for professionals with high levels of experience, management and controls which lower the risk and justify a discounted rate from other Miscellaneous Low Bonds. This rate may be used separate from other Miscellaneous Low Bonds. See Section VIII for premium calculation details. Page 3 of 9

11 Aspen American Insurance Company C. The Plan starts with six Base Rates for Miscellaneous and Commercial Contract Surety Bonds, one for each class defined in IV.B.1 and IV.B.2 above, Base Rates are defined as follows: Bond Class Base Rate Financial High $12.00 Compliance High $12.00 Financial Low $8.00 Compliance Low $5.00 Contract High $7.00 Contract Low $7.00 D. Composite Rates for Miscellaneous High bonds, Miscellaneous Low bonds, and Commercial Contract bonds may be produced for an eligible surety account. The composite rate is a weighted average of the rates for miscellaneous high, low and contract. V. MISCELLANEOUS SURETY RATE CALCULATION A. Base Rate (As defined for Financial High & Low and Compliance High & Low) B. Account Credit Risk Factor Is a quantitative assessment modifier which considers the account s credit metrics taking into consideration an account s balance sheet characteristics (i.e. net worth, market capitalization to net worth, and goodwill to net worth); debt (i.e. long term debt to worth, total debt to worth, and simple cash flow to debt); profitability (i.e. ROE, net income trend and sales growth), liquidity (i.e., working capital, simple cash flow to investment, and times interest earned), and public and/or private debt rating from S&P, Moodys, Fitch or equivalent. One overall numeric ranking is produced for each account. Account is defined as the entity that is the basis of the underwriting decision. Range of Modifier = 0.30 to A modifier of 1.25 will be used for individuals that need miscellaneous surety bonds, and for accounts that are not rated by either S&P or Moody s and do not provide a financial statement but provide full collateral. C. Liability to Net Worth Defined as current or projected Miscellaneous Surety liability divided by as given net worth. To the extent a financial statement for an account has not been provided, but full collateral is provided, the collateral amount will be applied in lieu of the Net Worth in calculating this factor. One overall factor (Liability to Net Worth) is produced for each account. Liability to Net Worth Ratio Factor 0-10% % % % % 1.10 >100% 1.25 D. Collateral Discount - When an account deposits collateral with AAIC to support their bond program, modifiers are applied to discount the rates. Collateral Percentage Factor 1-24% % % % 0.45 Page 4 of 9

12 Aspen American Insurance Company E. Bond Form, Contract & Statute Risk This rate factor is to be utilized only when the bond form, contract and/or underlying statute impose additional or unusual risk on the surety. Additional risk could include things like cumulative liability, successive recovery, selection against the surety, forfeiture, direct access to the Surety, and/or waiver of the Surety s rights. Manuscript, open penalty and non-cancelable forms may also impose extraordinary risk on the Surety. In general, bonds will be categorized as Average risk. One overall factor (Bond Form, Contract & Statute Risk) is produced for each group of bonds. Form, Contract & Statute Risk Factor High 1.2 Low 1 Average 0.8 F. Duration Risk Duration Risk relates to the time that a bond will remain in force. In general the bonds rated in the Plan will have a duration of 1 to 2 years. One factor (Duration Risk) will be used for each group of bonds. Duration Factor > 2 years years 1.0 < 1 year 0.8 G. Underwriting and Account Management Factor Certain accounts are more underwriting intensive and/or have less agency involvement which increases the expense of handling the program. This could be due to the need for continuous account analysis, complex bond underwriting, or low agency participation (i.e. bond execution by surety). At the same time the expenses could be lower due to less than average underwriting or high agency involvement. Account Management Expense Factor High 1.25 Average 1.0 Low 0.75 H. Account Risk Premium Modification (ARPM) See section IX I. Commission Commission is applied per the agency agreement. VI. COMMERCIAL CONTRACT SURETY RATE CALCULATION A. Base Rate (As defined for Commercial Contract High & Low) B. Account Credit Risk Factor This is the same as outlined in the miscellaneous surety rate Section V.B. C. Liability to Net Worth Defined as current or projected Commercial Contract Surety liability divided by as given net worth. One overall factor (Liability to Net Worth) is produced for each account. Liability to Net Worth Ratio Factor 0-5% % % % % % 1.15 >100% 1.25 Page 5 of 9

13 Aspen American Insurance Company D. Contract Risk In addition to commercial contract bonds being separated into high & low risk classes, each class contains different contract types which present different risks. The tables below separate the classes into different types and applicable risk factors to be applied. The predominant contract type in each class will be used to develop one rate for commercial contract high & low. Contract High Types Factor Hazardous Contracts 1.5 Advance Payment 1.3 Completion 1.3 Subdivision 1.1 Misc. Contracts 1.1 Contract Low Types Factor Service Contracts Complex 1.0 Service Contracts Other 0.75 Supply & Install Contracts 0.7 Supply Contracts 0.6 Maintenance Contracts 0.5 E. Collateral This is the same as outlined in the miscellaneous surety rate Section V.D. F. Duration Risk Determine the average bond duration for each class of commercial contract business. One factor is used for each class. Contract Duration Factor > 5 years years years years 1.0 < 1 year 0.75 Commercial contract bonds are billed for the term of the contract and there will be no charge for excess time on individual bonds other than what was contemplated in Duration Risk. G. Bond Form and Contract Form Risk This risk is based on terms and conditions found in the contract and/or bond form being used which increases or decreases the risk compared to the average risk in a contract type. If the contract(s) are generally classified to have more or less risk than average for the class we will apply the below factor. One factor is used for each class. Contract / Bond Form Factor Hazardous 1.5 Moderate 1.25 Regular 1.0 Low 0.75 H. Underwriting and Account Management Factor This is the same as outlined in the miscellaneous surety rate section. I. Account Risk Premium Modification (ARPM) See section IX J. Commission Commission is applied per the agency agreement. VII. NON-CONSTRUCTION GENERAL PREMIUM RULES A. Percentage Bonds All Contract Bonds for Non-Construction Accounts where the bond penalty is 50% or less of the contract price apply a 1.5 modification factor to the applicable contract surety account rate and bill annually. Apply the account rate to the bond limit. This rule applies to any type of contract bond. B. Annual Bonds Where an annual bond form is used, regardless of the overall contract duration in the underlying contract, assume a one (1) year duration for any contract bonds where an annual bond is used when calculating the average duration factor, in accordance with Section VI.F. An annual premium charge applies. If using an annual bond form on a percentage bond, the Percentage Bond rule applies. Page 6 of 9

14 Aspen American Insurance Company C. Subdivision Bonds To determine the annual premium charge, assume a one (1) year duration when calculating the average duration factor, in accordance with Section VI.F, and charge premium annually. D. Contract Extras/Change Orders Where the actual contract price as determined by final settlement exceeds the original estimate, additional premium is computed by calculating the bond premium on the final contract price and subtracting the bond premium based on the initial contract price. The rates utilized on the initial bond premium calculation will be used on the final contract premium calculation. E. Original Premium Earned The initial annual and term premium on a Contract Bond is fully earned, unless otherwise negotiated; however, renewal premiums on annual installment billings will be adjusted pro rata for short term. F. Bid or Proposal Bonds The premium charge for a bid bond is $100 per bid bond. AAIC retains the right to waive premiums for bid bonds. 1. Where at or before the receipt of opening of proposals sureties or their agents consent by letter or otherwise to become surety upon the contract if same is awarded, such consent or letter constitutes a bid or proposal bond on which surety company premium for bid bonds may be collected. 2. Letters or consents to become sureties are classified as bid bonds for premium calculation, even when the proposal is accompanied by certified check. 3. Surety company premium may be charged for each successive bid bond notwithstanding it may be for the same project on which bids have been received and previously rejected. 4. If contract is awarded, the bid bond premium may be credited to the performance bond premium. 5. All bid bond premium is fully earned whether the contractor is successful or not in obtaining the contract. 6. Where owner requires a bid bond, and an award is made to the company s contractor without requiring a final bond, the contractor may be charged a premium based on the account rate applied to the penalty of the bid bond or based on 10% of the contract price where a consent letter was issued. G. Bid Bond Servicing Facility where an account requires many bid bonds a year and it is expected that final bonds will not be required, a servicing fee may be applied. The premium per bond is the greater of the $100 minimum premium or the premium calculated using the account rate. Bid bond premiums charged under a BBSF will not be credited when a final bond is needed. H. Payment Bonds 1. When a Payment Bond is written with a Performance Bond for the same contract, there is no premium charge in addition to the Performance Bond premium. 2. When a Payment Bond is written for a contract, but a Performance Bond is not required, premium for the Payment Bond is developed in accordance with Section VI. Commercial Contract Surety Rate Calculation. Page 7 of 9

15 Aspen American Insurance Company I. Maintenance and Warranty Bonds/Extended Warranty Periods 1. Performance Bond Provided With No Separate Maintenance Bond Where the maintenance term is more than 12 months, factor the maintenance period into the average duration factor when developing the account rate in Section VI.F. No separate premium charge applies. 2. Where a Separate Maintenance Bond is Required in Addition to a Performance Bond a. For terms of 12 months or less after completion, there is no additional charge over the performance bond premium. b. For terms greater than 12 months, develop the account rate in accordance with Section VI. Commercial Contract Surety Rate Calculation. Apply the account rate to the maintenance bond limit. VIII. Fiduciary and Lost Securities Bond Rate Calculation A. Base Rate $4.50 B. Experience and Qualifications of the fiduciary, LSB principal or third party administrator. Experience Level of Principal Factor High 0.5 Above Average 0.75 Average 1.0 Low 1.25 C. Risk Management Level of transactional oversight, internal controls and overall risk management of the account(s). Risk Management Factor High 0.75 Average 1.0 Low 1.25 D. Account Management Expense As defined in Section V.G. Account Management Expense Factor High 1.25 Average 1.0 Low 0.75 E. Account Risk Premium Modification (ARPM) See section IX F. Commission Commission is applied per the agency agreement. IX. ACCOUNT RISK PREMIUM MODIFICATION PLAN (ARPM) A. Eligibility The ARPM Plan applies to all accounts rated under the Plan. Page 8 of 9

16 Aspen American Insurance Company B. ARPM Plan Procedure The ARPM may be applied to recognize special risk characteristics which were not reflected in the Plan. If the basic premium calculated by the Plan does not take into account material risk characteristics the ARPM Plan may be used. Premium modifications will be reviewed in accordance with account rate reviews. The premium modifications are separated into the five groups below, total debits or credits will not exceed state maximums and documentation supporting the reasoning for the adjustment will be included in the account file. 1. Industry Assessment (0-25%) Industry prospects/future Industry specific hazards Competitive and regulatory climate Industry consolidation trends Market share/expansion issues 2. Management (0-25%) Longevity of present management Reputation of management Stability of staff and key people Perpetuation plans Internal controls 3. Off Balance Sheet Issues (0-25%) Litigation Financial trends Review of analyst reports Accounting issues Special or one time charges 4. Risk Analysis (0-25%) Parent or affiliate indemnity impact Quality of information Spread of risk in bond/work program Bank relationship Personal indemnity 5. Expenses (0-15%) Modification based on variance in company expenses from that contemplated in the base premium relating to underwriting, commission, or bond processing and issuance. C. Modification Limitations by State (%) -15 / / / / / / / +50 N/A NY AL NJ TX AK SC GA AR MN HI AZ ND ME VT CA NV CO OH MD DE NM CT OK MS GU NC DC OR MT ID RI FL PA NE IL TN IA PR NH IN VA KS SD WV KY VI LA UT MA WI MO WA MI WY Page 9 of 9

17 SERFF Tracking Number: REGU State: Wisconsin Filing Company: Aspen American Insurance Company State Tracking Number: Company Tracking Number: AAIC-SURETY-11 TOI: 24.0 Surety Sub-TOI: Surety Product Name: Aspen Commercial Surety Non-Construction Rating Plan Project Name/Number: Aspen Commercial Surety Non-Construction Rating Plan/AAIC-SURETY-11 Supporting Document Schedules Item Status: Status Date: Bypassed - Item: Rate Filed 05/23/2011 Bypass Reason: N/A - this filing does not involve the adoption of loss costs, any LCM and is not a Consent to Rate filing. Comments: Item Status: Status Date: Bypassed - Item: Rule Filed 05/23/2011 Bypass Reason: N/A - new rates/rules Comments: Item Status: Status Date: Satisfied - Item: Filing Authorization Letter Filed 05/23/2011 Comments: Attachment: 1 - IRC Filing Authorization Letter.pdf PDF Pipeline for SERFF Tracking Number REGU Generated 05/24/ :32 AM

18 LETTER OF FILING AUTHORIZATION This letter will certify that Insurance Regulatory Consultants, LLC (IRC) has been given full authorization to submit filings on behalf of Aspen American Insurance Company. This authorization extends to all correspondence regarding the filings. Andrew Noga April 11, 2011 Name Date EVP, US General Counsel Title Aspen American Insurance Company Company Name Signature Telephone Number Re: Aspen American Insurance Company NAIC #: ; FEIN#: Commercial Surety Non-Construction Rating Plan Filing