REPORT OF EXAMINATION OF THE FIREMAN S FUND INSURANCE COMPANY AS OF DECEMBER 31, 2010

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1 REPORT OF EXAMINATION OF THE FIREMAN S FUND INSURANCE COMPANY AS OF DECEMBER 31, 2010 Filed: June 8, 2012

2 TABLE OF CONTENTS PAGE SCOPE OF EXAMINATION... 1 SUBSEQUENT EVENTS... 2 COMPANY HISTORY:... 4 Capitalization... 4 Dividends Paid to Parent... 6 MANAGEMENT AND CONTROL:... 7 Management Agreements... 9 Related Party Transactions TERRITORY AND PLAN OF OPERATION REINSURANCE: Intercompany Reinsurance Agreement Other Intercompany Reinsurance Assumed Crop Insurance Loss Portfolio Transfer Ceded ACCOUNTS AND RECORDS: Information Systems Controls FINANCIAL STATEMENTS: Statement of Financial Condition as of December 31, Underwriting and Investment Exhibit for the Year Ended December 31, Reconciliation of Surplus as Regards Policyholders from December 31, 2007 through December 31, COMMENTS ON FINANCIAL STATEMENT ITEMS: Losses and Loss Adjustment Expenses Taxes, Licenses and Fees SUMMARY OF COMMENTS AND RECOMMENDATIONS: Current Report of Examination Previous Report of Examination ACKNOWLEDGEMENT... 29

3 San Francisco, California May 16, 2012 Honorable Dave Jones Insurance Commissioner California Department of Insurance Sacramento, California Dear Commissioner: Pursuant to your instructions, an examination was made of the FIREMAN S FUND INSURANCE COMPANY (hereinafter also referred to as the Company) at its home office located at 777 San Marin Drive, Novato, California SCOPE OF EXAMINATION We have performed our multi-state examination of the Company. The previous multistate examination of the Company was made as of December 31, This examination covers the period from January 1, 2008 through December 31, The examination was conducted in accordance with the National Association of Insurance Commissioners Financial Condition Examiners Handbook. The Handbook requires the planning and performance of the examination to evaluate the Company s financial condition, to identify prospective risks, and to obtain information about the Company, including corporate governance, identification and assessment of inherent risks, and the evaluation of the system controls and procedures used to mitigate those risks. The examination also included an assessment of the principles used and the significant estimates made by management, as well as an evaluation of the overall financial statement presentation, and management s compliance with Statutory Accounting

4 Principles and Annual Statement instructions. All accounts and activities of the Company were considered in accordance with the risk-focused examination process. The examination was a coordinated examination and was conducted concurrently with other insurance entities in the holding company group and included participation from the following States: Illinois, Louisiana, Missouri, New Jersey, and Ohio. In addition to those items specifically commented upon in this report, other phases of the Company s operations were reviewed including the following areas that require no further comment: corporate records; fidelity bonds and other insurance; pensions, stock ownership and insurance plans; growth of company; statutory deposits; and sales and advertising. SUBSEQUENT EVENTS In 2011, the Fireman s Fund Group incurred a $232,069,621 operating loss. The operating loss was primarily due to current year catastrophe losses, and adverse development related to asbestos and environmental, and workers' compensation recorded during Total loss and allocated loss adjustment expense (ALE) adverse development amounted to $334,976,000, an increase of $60,053,000 from Pursuant to the Keep Well Commitment (Commitment) between its ultimate parent, Allianz SE and the Company, the Company will record a capital contribution and a receivable from parent whenever the loss and ALE adverse development on accident years 2003 and prior exceeds an annual retention of $150,000,000. In 2011, the Company recorded $341,269,000 of adverse development on accident year applicable to the Commitment triggering a contribution of $191,269,000 which will be recorded by the Company in the 2012 first quarter statement. The capital contribution would be 2

5 payable entirely to the Company, with no intercompany balances due to the subsidiaries. The Company and the pooled subsidiaries entered into a Second Amended and Restated Intercompany Reinsurance Agreement (Amended Pooling Agreement), effective January 1, Under the Amended Pooling Agreement, each of the pooled subsidiaries will continue to cede 100% of its insurance business to the Company; however, the retroceded shares for all pooled subsidiaries is reduced to zero and the Company s share is increased to 100%. The new Amended Pooling Agreement was approved by the domiciliary Department of Insurance of each participating company. The Company provided its 30-day prior notice filing with the California Insurance Commissioner (Commissioner) in accordance with California Insurance Code (CIC) section (b)(3). On February 23, 2012, the California Department of Insurance (CDI) notified the Company that the CDI does not disapprove" the agreement. Effective January 1, 2012, the Company and the pooled subsidiaries entered into an Intercompany Service Agreement (Service Agreement) pursuant to which the Company is authorized to provide all services necessary to operate the pooled subsidiaries insurance business. The Company provided its 30-day prior notice filing with the Commissioner in accordance with CIC section (b)(4), and was notified in February 2012 that the agreement was not disapproved by the CDI. 3

6 COMPANY HISTORY Capitalization The Company is authorized to issue one million shares of Class A voting common stock with a par value of $15 per share. As of December 31, 2010, there were 280 thousand shares outstanding. In May 2003, Allianz SE, the ultimate parent, issued two Keep Well Commitments, in which Allianz SE agreed to contribute capital to the Company up to certain specified maximum amounts if the 2003 accident year combined loss ratio exceeds the planned combined ratio of 102%, and for any adverse development up to $1 billion for accident years 2002 and prior. The terms of the commitments commenced on January 1, 2003 and terminated on December 31, On January 6, 2005, Allianz SE issued a new Keep Well Commitment (Commitment) in favor of the Company. Beginning calendar year 2006, Allianz SE agreed to contribute up to $800,000,000 to the Company for accident years 2003 and prior adverse development in excess of $150,000,000 as reported at December 31, The initial term of the Commitment commenced on January 1, 2006, terminated on December 31, 2008 and is deemed automatically extended for successive one-year terms thereafter, unless Allianz SE provides at least 12 months prior notice of termination. Effective September 21, 2009, the Commitment was replaced with an Amended and Restated Keep Well Commitment (Restated Commitment). The Restated Commitment increases the maximum commitment from $800,000,000 to $932,960,000 for calendar years 2009 and later. It also established an annual aggregate retention of $150,000,000 for calendar year 2009 and later. As of December 31, 2007 and 2008, additional adverse development of $190,707,000 and $142,253,000, respectively, in excess of $150,000,000 occurred related to accident 4

7 years 2003 and prior, triggering a contribution due from Allianz SE to the Company in accordance with the terms of the Restated Commitment. Upon receiving approval from the California Department of Insurance (CDI) and with the proper collateral from Allianz SE in place, the additional development was recorded as a surplus contribution and an intercompany receivable in the following year. The Restated Commitment was not triggered in On December 21, 2009, the Company made a capital contribution in the form of cash in the amount of $30,000,000 to AGCS Marine Insurance Company (AMIC) as authorized by the Company s board of directors on December 10, The Company sold its 100% ownership interest in Vintage Insurance Company, a California insurance company, to SPARTA Insurance Company, a Connecticut insurance company, for $10,900,000 effective October 1, On this date, the Company received an extraordinary dividend from Vintage Insurance Company in the amount of $11,180,364. The dividend was approved by the CDI on February 23, 2010, and the sale was approved by the CDI on August 25, The Company made a capital contribution to its controlled entity, Fireman's Fund County Mutual Insurance Company (FFCM), in the amount of $300,000 on December 30, 2010 to meet FFCM s minimum surplus requirements. As of December 31, 2010, $141,102,000 in additional adverse development in excess of $150,000,000 occurred related to accident years 2003 and prior, triggering a contribution due from Allianz SE to the Company in accordance with the terms of the Commitment. Upon receiving approval from the CDI and with the proper collateral from Allianz SE in place, the additional development was recorded as a surplus contribution and an intercompany receivable in

8 From 2008 to 2010, the Company received cash and/or stock dividends from the following subsidiaries: Company American Automobile Insurance Company $16,000,000 $ 81,506,676 $ 0 The American Insurance Company 82,000,000 87,604, ,000,000 Associated Indemnity Corporation 8,000, Chicago Insurance Company 12,000, ,000,000 0 Interstate Fire & Casualty Company 15,000, ,745,643 0 National Surety Corporation 0 130,000,000 0 San Francisco Reinsurance Company 8,000,000 14,000,000 0 Vintage Insurance Company 11,180, Life Sales LLC 0 0 4,800,000 International Film Guarantors LLC ,369 Dividends Paid to Parent On December 8, 2008, the Company paid an extraordinary cash dividend to Allianz Global Risks US Insurance Company (AGR US) totaling $300,000,000. The CDI approved this transaction on November 20, On December 14, 2009, the Company paid an extraordinary cash dividend to AGR US totaling $475,000,000. The CDI approved this transaction on November 24, On January 1, 2010, as a result of the transfer of the marine business, AMIC ceased to be a subsidiary of the Company, and as of that date, the Company's equity ownership of AMIC stock was distributed up to its sole shareholder, AGR US. The dividend was valued at the sum of the statutory book value of AMIC and the cost basis of a noninsurance subsidiary that was contributed to AMIC totaling $158,094,849. The CDI approved this transaction in December On December 14, 2010, the Company paid an ordinary dividend in the amount of $425,000,000 to its sole shareholder AGR US. 6

9 MANAGEMENT AND CONTROL The Company is a member of an insurance holding company system. Allianz SE, formerly Allianz Aktiengesellschaft, is a European Company incorporated in the Federal Republic of Germany and the European Union. Allianz SE is the ultimate controlling entity of the Company. The following abridged chart depicts the interrelationship of the Company and its California subsidiaries within the holding company system (all ownership is 100%): Allianz SE (Germany) Allianz of America, Inc. (Delaware) Allianz Global Risks US Insurance Company (California) Fireman s Fund Insurance Company (California) San Francisco Reinsurance Company (California) Associated Indemnity Corporation (California) 7

10 Members of the board of directors, who are elected annually, oversee management of the business and affairs of the Company. Following are members of the board and principal officers of the Company serving at December 31, 2010: Directors Name and Residence Michael E. LaRocco (a) Sonoma, California Dale E. Lauer Woodinville, Washington Jill E. Paterson (b) Tiburon, California Dr. Helmut Perlet (c) Paehl/Aidenried, Germany Jay S. Ralph (d) Starnberg, Germany Michael P. Sullivan Edina, Minnesota Principal Business Affiliation President and Chief Executive Officer Fireman s Fund Insurance Company Retired Executive Vice President, Chief Financial Officer, and Treasurer Fireman s Fund Insurance Company Member of the Board of Management Allianz SE Chairman of the Board and Member of the Board of Management Allianz SE Attorney Gray Plant Mooty Mooty & Bennett 8

11 Principal Officers Name Michael E. LaRocco (a) Jill E. Paterson (b) Sally B. Narey Jeffery F. Johnson Title President and Chief Executive Officer Executive Vice President, Chief Financial Officer, and Treasurer Senior Vice President, General Counsel, and Secretary Vice President and Controller The following changes in management occurred subsequent to the examination date: (a) Effective July 4, 2011, Lori D. Fouché, formerly President of Commercial Insurance replaced Michael LaRocco as the Company s President and Chief Executive Officer. (b) Effective September 19, 2011, Kevin E. Walker became the Company s Senior Vice President, Chief Financial Officer, and Treasurer, replacing Jill E. Paterson. (c) Effective March 1, 2012, Marna Cupp Whittington was elected to the Board, replacing Dr. Helmut Perlet. (d) Effective February 15, 2012, Gary C. Bhojwani was elected as Chairman of the Board, replacing Jay S. Ralph. Management Agreements Tax Reimbursement Agreement: Effective December 17, 1999, the Company entered into a Tax Reimbursement Agreement for the purpose of clarifying an agreement that was in effect since The Tax Reimbursement Agreement was between Allianz of America, Inc. (AZOA), the Company, and its subsidiaries. Under the terms of this agreement, the tax liability of the Company and its subsidiaries would be computed as if each member filed a separate stand-alone return. AZOA is the party primarily responsible for filing and making all tax payments on behalf of the Company and its 9

12 subsidiaries. Under the Tax Reimbursement Agreement, the Company paid AZOA $27,516,000 in 2010, $87,000,000 in 2009, and $137,306,000 in 2008 on a consolidated basis. Service Agreement: Effective January 1, 2008, a First Amended and Restated Service Agreement was executed among AZOA, Allianz of America Corporation, the Company, Allianz Global Risks US Insurance Company, Allianz Life and Annuity Company, Allianz Life Insurance Company of North America and Allianz Private Equity Partners, Inc. (each a "Group Member") which supersedes and replaces the prior Service Agreement, effective March 6, 2006, between AZOA, Allianz of America Corporation, the Company, Allianz Global Risks US Insurance Company and Allianz Life Insurance Company of North America. The First Amended and Restated Service Agreement added two additional parties, Allianz Private Equity Partners, Inc. and Allianz Life and Annuity Company, updated the schedule of authorized intercompany services, added an offset provision per statutory accounting principles and authorized each Group Member to provide ad hoc consultation and support services for another group member on an intermittent basis of limited duration. Each Group Member agrees to provide services for any requesting Group Member necessary for that Group Member's continuing operation. Any Group Member can decline to provide requested services if it would interfere with Group Member's ability to meet its obligations to its policyholders or would otherwise adversely affect the performing Group Member. Each Group Member must reimburse other Group Members for direct and directly allocable expenses attributable to recipient Group Member, plus a reasonable charge for overhead. The Company provided its 30-day prior notice filing with the California Department of Insurance (CDI) in accordance with California Insurance Code (CIC) Section (b)(4). On August 26, 2008, the CDI notified the Company that the CDI does not disapprove" the agreement. 10

13 Cost Sharing Agreement: Effective June 6, 2007, the Company entered into a cost sharing agreement with Allianz SE and affiliates of Allianz SE. Pursuant to this agreement, the Company is allocated a portion of expenses relating to the marketing of the Allianz group brand. The Company paid the following amounts relating to this agreement: 2008 $1,391, : : $1,671,274 In the third quarter of 2008, the Company suspended payments to Allianz SE after discovering that the agreement was not filed with the CDI. The Company subsequently filed this agreement with the CDI on January 13, On July 16, 2010, the CDI notified the Company that the CDI does not disapprove the agreement. The Company then resumed payments to Allianz SE. The Company did not notify the CDI at least 30 days prior to entering into this agreement, as required by CIC Section (b)(4). It is recommended that the Company implement procedures and controls to ensure compliance with CIC Section (b)(4). Cost Reimbursement Agreement: Effective August 6, 2010, a Cost Reimbursement Agreement was executed between Allianz SE Reinsurance Division (Allianz Re) and the Company. Under the terms of this agreement, the Company will reimburse Allianz Re for its share of the costs under the Software License and Services Agreement entered into on August 13, 2009, and amended October 12, 2009, between Risk Management Solutions, Inc. (RMS), Allianz Re and various affiliates of Allianz Re. In 2010, the Company paid $2,031,499 related to the Cost Reimbursement Agreement. The Company provided its 30-day prior notice filing with the CDI in accordance with CIC Section (b)(4). On July 16, 2010, the CDI notified the Company that the CDI does not disapprove the agreement. 11

14 The Company has other management and service agreements with its affiliated companies at December 31, The principal agreements were reviewed and found to be materially compliant with the CIC and were filed with the CDI as required. Related Party Transactions 1) Allianz SE issued a written commitment for the nominal amount of the Company s investment in 10% fixed-to-floating rate junior subordinated notes (Notes) of The Hartford Financial Services Group, Inc. ( Issuer ). If at any time during the fixed rate period of the Notes (ending October 15, 2018), the rating attributed by Standard & Poor's (S&P) or Moody s falls below investment grade, or the Issuer is subject to an event of default with its obligations under the Notes, the Company has the right to sell the Notes to Allianz SE. The consideration to be delivered by Allianz SE will be equal to the nominal amount of the Notes. At the option of Allianz SE, such consideration will either be paid in cash or senior notes of Allianz SE or one of its financial subsidiaries. At December 31, 2010, the fair value of this investment as reported on Schedule D was $124,051,800. 2) Effective August 1, 2009, the Company entered into an agreement with an affiliate, World Access Service Corporation dba Mondial Assistance (Mondial). Pursuant to the agreement, Mondial agrees to handle telephone intake and web entry services for first notice of loss. The Company subsequently filed this agreement with the CDI on January 13, On March 29, 2010, the CDI notified the Company that the CDI does not disapprove" the agreement. The Company did not notify the CDI at least 30 days prior to entering into this agreement, as required by CIC Section (b)(4). It is recommended that the Company implement procedures and controls to ensure compliance with CIC Section (b)(4). 12

15 3) On December 21, 2010, the Company issued a promissory note to its wholly owned subsidiary, Standard General Agency, Inc. (SGA) in the amount of $300,000. These funds were subsequently deposited by SGA into trust accounts on behalf of American Standard Lloyd s Insurance Company (ASL) to meet ASL s minimum surplus requirement. 4) On December 29, 2009, pursuant to a Contribution Agreement between the Company and AGCS Marine Insurance Company (AMIC), the Company executed an Instrument of Transfer in favor of AMIC to transfer certain non-admitted assets required to operate the Company s former Specialty Marine Business. AMIC assumed certain liabilities related to the operation of such business from the Company under the Contribution Agreement. The statutory value of the liabilities transferred under the Contribution Agreement was $19,181,347. 5) On December 29, 2009, pursuant to the Contribution Agreement, the Company contributed its 100% ownership interests to AMIC of the common stock of Wm. H. McGee & Co., Inc., a New York corporation (McGee), which in turns owns all of the outstanding equity interests in Wm. H. McGee & Company of Puerto Rico, Inc., Wm. H. McGee & Company (Bermuda) LTD and Fireman s Fund Insurance Company Bermuda (SAC) Limited, valued at McGee s policyholder's surplus in the amount of $1,791,674. 6) On December 21, 2009, the Company purchased U.S Treasury Bonds with a Statement value of $76,782,044 from its wholly owned subsidiaries, American Automobile Insurance Company, Chicago Insurance Company, National Surety Corporation, Associated Indemnity Corporation, Interstate Fire & Casualty, and The American Insurance Company. The Company paid $76,782,044, including accrued interest of $799,920, for these securities with a fair market value of $75,982,

16 7) In accordance with the requirements of the State of Connecticut, the Company authorized a guarantee for San Francisco Reinsurance Company (SFRe) to maintain its combined capital and surplus at or above $4,000,000, as long as the Company controls SFRe. TERRITORY AND PLAN OF OPERATION The Company s operations are conducted jointly with its subsidiaries at its home office in Novato, California. As of December 31, 2010, the underwriting operations of the Company s group of insurance companies (Group) were conducted through its three business units: Commercial Business, Personal Insurance, and Agribusiness. Businesses that were deemed not profitable or non strategic were isolated into a discontinued operations unit. While operations are conducted nationally, consolidation has taken place to maximize synergies among the business units. The Group operates throughout the United States and Puerto Rico utilizing approximately 2,875 agent and broker locations. Approximately 21% of the Group s direct written premiums were generated in the State of California in 2010 and 20% in In August 2008, the Group underwent significant restructuring. Specialty marine business was combined with Allianz Global Corporate & Specialty s (AGCS) global marine business into a new Allianz unit. Agribusiness, a major contributor to Group s profitability in the last few years, is now operated as a dedicated unit. The other portions of specialty insurance were combined with commercial business to form a new commercial and specialty risks organization. As part of the corporate re alignment, the Allianz Group transferred the Company s marine business as well as employees and assets directly related to the marine business to Allianz Global Risks U.S. Insurance Company (AGR US) effective January 14

17 1, This was accomplished through the transfer of ownership of one of the Company s subsidiary Interstate Indemnity Company (which subsequently changed its corporate name to AGCS Marine Insurance Company, a member of the Company s pool in 2008, and was de pooled in 2009). REINSURANCE Intercompany Reinsurance Agreement The Company is the lead insurer in an intercompany reinsurance pooling agreement with seven of its affiliates (hereinafter also referred to as the participants). Under the terms of this agreement dated January 1, 1999 and subsequent amendments, the participants cede and the Company assumes 100% of the participants business generated from underwriting operations. The cessions from the participants are combined with the Company s business, resulting in the pooled balance to be allocated to each company in the pool. The following table illustrates each participant s pooled share as of December 31, 2010: Company State of Domicile Pooling Share Fireman s Fund Insurance Company CA 75.8% The American Insurance Company OH 11.5% National Surety Corporation IL 4.0% Interstate Fire & Casualty Company IL 3.5% American Automobile Insurance MO 2.5% Company Chicago Insurance Company IL 1.5% Associated Indemnity Corporation CA 1.0% Fireman s Fund Insurance Company of Ohio OH 0.2% Pool Total %

18 The agreement authorizes and empowers the Company to: (1) collect and receive all premiums; (2) adjust and pay all losses; (3) reinsure or cancel any and all policies and contracts of insurance; and (4) act as though the policies and contracts of insurance and reinsurance were issued by the Company. It further provides for the complete sharing of all income and expenses of the pooled business with the exception of the investment operations, liabilities for federal income tax or other items not relating to the underwriting operations of the parties. Accounts are required to be settled quarterly. Other companies within the Fireman s Fund Group, referred to as Specialty Companies, cede 100% to the Company. These companies receive a commission from the Company, and also pay the Company a management fee, resulting in minimal income. Two companies in the pool, Interstate Fire & Casualty Company and Chicago Insurance Company, submit business to the pool net of external reinsurance arrangements with third parties. The Company and its pooled subsidiaries entered into a Second Amended and Restated Intercompany Reinsurance Agreement (Amended Pooling Agreement) effective January 1, Under the Amended Pooling Agreement, each of the pooled subsidiaries will continue to cede 100% of its insurance business to the Company; however, the retroceded shares for all pooled subsidiaries is reduced to zero and the Company s share is increased to 100%. (See Subsequent Events ). Other Intercompany Reinsurance Prior to the pooling of business among the participating companies, certain other business is assumed and/or ceded between the Company and other affiliated companies. These companies do not participate in the pool. Instead, these affiliates 16

19 receive a 3.25% commission fee and reimbursement of expenses. The Company assumes all business written by the following subsidiaries: Fireman s Fund Indemnity Corporation Fireman's Fund Insurance Company of Hawaii, Inc. Fireman's Fund Insurance Company of Louisiana In addition, the Company has a variety of reinsurance arrangements other than pooling with the following affiliates: Allianz Global Risks US Insurance Company San Francisco Reinsurance Company AGCS Marine Insurance Company The Company also provides reinsurance facilities to American Standard Lloyd s Insurance Company, acting by and through its Attorney-in-Fact, Standard General Agency, Inc. All business underwritten or assumed by American Standard Lloyd s Insurance Company is ceded 100% to Associated Indemnity Corporation and then to the intercompany pool. Assumed In addition to intercompany agreements, the Company assumes business from pools and associations and from various companies under several reinsurance agreements. Crop Insurance The Company entered into various reinsurance agreements with Rural Community Insurance Company (RCIC) regarding federally insured Multi Peril Crop Insurance 17

20 (MPCI) and other crop peril coverages, which were effective July 1, 2009 to June 30, 2012 for MPCI and December 31, 2012 for the other peril coverages. Under the fronting agreements, the Company provides a fronting company for the policies issued in states where RCIC is not licensed. These policies are 100% ceded to RCIC. RCIC serves as the lead insurer, ceding approximately 24% of the premiums to the Federal Government, as dictated by the Standard Reinsurance Agreement with the Federal Government. Fireman s Fund, as lead reinsurer, assumes from RCIC 50% of the premium not ceded to the Federal Government. Loss Portfolio Transfer On September 30, 2002, the Company entered into a loss portfolio transfer agreement with Allianz Aktiengessellschaft (now Allianz SE) in which Allianz SE agreed to assume losses associated with asbestos and environmental claims for accident years 1987 and prior for a maximum of $2.159 billion. In lieu of having the Company pay the full premium of $1.276 billion, Allianz SE dismissed $1.1 billion of premium payment through the assignment of premiums. Allianz SE assigned the $1.1 billion premium payment to Allianz of America, Inc. (AZOA), which in turn, assigned the payment to Allianz Global Risks US Insurance Company (AGR US). AGR US then assigned the payment back to the Company as a capital contribution. Therefore, no cash was actually exchanged for the $1.1 billion premium payment. A trust account was established and the Company placed the remaining $176 million in securities in a trust account. 18

21 The prospective treatment of the contract was approved by the CDI as it met the requirements for a prospective agreement defined under Statement of Statutory Accounting Principles (SSAP) No. 62, paragraph 30(d). During 2007, the maximum limit of $2.159 billion was reached. The Company is now establishing reserves for all losses in excess of that amount. Ceded Other than intercompany agreements, reinsurance is placed through the Company for the Fireman's Fund Group. All members of the Group, either individually or collectively, may utilize the reinsurance of the various contracts that are in effect. The major principal treaties, coverages, retentions and limits in effect during the examination period are listed as follows: The Company utilizes the facultative market, as needed, to increase its capacity. Senior management provides a list of acceptable facultative markets to the field underwriting staff. Line of Business and Type of Contract Reinsurer s Name Company s Retention Reinsurer s Limit Casualty: Per Risk Excess of Loss First Layer 7 domestic, foreign and alien companies $15 million each and every occurrence, each and every risk, plus 10% of $10 million excess of $15 million 90% of $10 million excess $15 million, each and every occurrence, each and every risk, not to exceed $10 million each and every occurrence, each and every risk. Acts of Terrorism only $60 million aggregate 19

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