March 23, Mr. Speaker:

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2 March 23, 2012 The Honourable Dale Graham Speaker of the Legislative Assembly of New Brunswick Legislative Assembly Building P.O. Box 6000 Fredericton, N.B. E3B 5H1 Mr. Speaker: Pursuant to subsection 10(1) of the Consumer Advocate for Insurance Act, I am pleased to submit the annual report on the activities of the Office of the Consumer Advocate for Insurance for the 2011 calendar year. It also contains a summary regarding the total amount assessed against insurers for the fiscal year that ended March 31, 2011 under section 11 and the amount paid by each insurer. Respectfully, Ronald Godin Consumer Advocate for Insurance for New Brunswick 270, av. Douglas Ave., Pièce/Suite 406 Bathurst, N.B. E2A 1M9 (506) (506) télécopieur/facsimile nb@cai-dma.ca

3 TABLE OF CONTENTS 1. INTRODUCTION RESPONSIBILITIES OF THE CONSUMER ADVOCATE OFFICE OF THE CONSUMER ADVOCATE ACTIVITIES OF THE CONSUMER ADVOCATE MEETINGS PRESENTATIONS CONFERENCES HEARINGS APPEARANCES OTHER ACTIVITIES WEBSITE REPORT FILES HANDLED BY THE OFFICE OF THE ADVOCATE NUMBER OF FILES BREAKDOWN BY TYPE OF INSURANCE NATURE OF REQUESTS ORIGIN OF REQUESTS BREAKDOWN BY COUNTY HIGHLIGHTS FOR MINOR INJURY CAP REVIEW MINISTER S ROUND TABLE ON HOME INSURANCE REVIEW OF LEGISLATIVE OFFICERS ASSESSMENT OF OFFICE EXPENDITURES ISSUES CREDIT SCORING LEGISLATION MINOR INJURY LEGISLATION RECOMMENDATIONS ON THE OFFICE OF THE CONSUMER ADVOCATE CONCLUSION...22 APPENDIX A: STATEMENT OF ASSESSMENTS...23

4 1. INTRODUCTION Subsection 10(1) of the Consumer Advocate for Insurance Act reads as follows: 10(1) The Consumer Advocate shall report annually to the Legislative Assembly concerning: (a) the activities of the Office of the Consumer Advocate in the preceding year; and b) the total amount assessed against licensed insurers in the preceding year under section 11 and the amount paid by each insurer. The Consumer Advocate for Insurance has been in office since January 1, Annual reports have been submitted for the years 2005, 2006, 2007, 2008, 2009 and The time has come to present the annual report for the year The 7 th year was one of continued stability and even a slight decrease in rates in the auto insurance market. The upward trend in premiums for house insurance continued in Credit scoring and the cap regarding compensation for minor injuries remained as issues yet to be resolved at the end of the year in question. 2

5 2. RESPONSIBILITIES OF THE CONSUMER ADVOCATE The Consumer Advocate for Insurance Act, chapter C-17.5 of the New Brunswick Acts, was assented to on June 30, 2004 on the recommendation of the Legislative Assembly. The Consumer Advocate for Insurance was appointed on December 21, 2004 for a 10-year term, commencing January 1, Subsection 7(1) of the Consumer Advocate for Insurance Act stipulates that the responsibilities of the Consumer Advocate are as follows: 7(1) The Consumer Advocate shall (a) examine the underwriting practices and guidelines of insurers, brokers, and agents, and report the use of any prohibited underwriting practices to the Superintendent; (b) conduct investigations in relation to insurers, brokers and agents concerning (i) (ii) the premiums charged for contracts of insurance, and the availability of contracts of insurance; (c) respond to requests for information with respect to insurance; (d) develop and conduct educational programmes with respect to insurance for the purpose of educating consumers; and (e) carry out tasks or investigations in relation to insurance matters or the insurance industry as directed by the Legislative Assembly. Subsection 7(2) provides that the Consumer Advocate may appear before the New Brunswick Insurance Board established under the Insurance Act to represent the interests of consumers ( ). 3

6 Subsection 7(3) stipulates that the Consumer Advocate may appear before the Board of Commissioners of Public Utilities to represent the interests of consumers at hearings the Board of Commissioners is authorized to hold under the Insurance Act ( ). 4

7 3. OFFICE OF THE CONSUMER ADVOCATE The Office of the Consumer Advocate for Insurance began operating officially on March 7, The office has a staff of four. In addition to the Consumer Advocate, the other employees are: Pauline Lafortune: Sandra Godin: Solange Godin: Administrative Assistant Assistant Advocate Administrative Assistant One other person acts as an assistant advocate on a contract basis: Brian Teed: Assistant Advocate The office is located at 270 Douglas Avenue, Suite 406, Keystone Place in Bathurst, New Brunswick. 5

8 4. ACTIVITIES OF THE CONSUMER ADVOCATE 4.1 Meetings The Consumer Advocate participated in the following meetings: - Meeting with Honourable Marie Claude Blais Minister of Justice and Consumer Affaires and Attorney General January 11, 2011 Fredericton, NB - Meeting with Mr. Bill Adams Vice President, Atlantic Insurance Bureau of Canada March 16, 2011 Fredericton, NB - Meeting with Brian D. MacLean, Laura P. Kennedy and Luigi Beltempo RBC Insurance May 26, 2010 Moncton, NB - Meeting with Ms Catherine A. Decarie and Mr. Brian M. Sypher TD Insurance Saint-John, NB June 8, Meeting with Board Members New Brunswick Insurance Board Saint-John, NB June 28, 2011 St-John, NB - Meeting with Shelley Ridgewell Insurance Learning Systems October 26, 2011 Fredericton, NB 6

9 4.2 Presentations The Consumer Advocate gave presentations regarding insurance matters to the following groups, associations, organizations and committees: - Insurance & Risk Management Volunteer and Non-Profit Organizations Saint-John, NB January 25, Insurance & Risk Management New Brunswick Association for Supported Services and Employment (NBASSE) Fredericton, NB March 16, Insurance and the Consumer Advocate Université de Moncton Insurance Law Class Moncton, NB March 22, Insurance & Risk Management New Brunswick Association of Residential Agencies Fredericton, NB May 19, Insurance 101 YMCA Settlement Services Saint-John, NB June 8, Round Table on Insurance Law Université de Moncton Moncton, NB November 9, Insurance Issues and Concerns Insurance Community Action Network (ICAN) Fredericton, NB November 10,

10 4.3 Conferences The Consumer Advocate attended the following conferences: Compliance and Consumer Complaints Canadian Life and Health Insurance Association Inc St. John s, Newfoundland May 4-6, Hearings The Consumer Advocate participated in the following hearings: - New Brunswick Insurance Board The Portage La Prairie Mutual Insurance Company Rate Revision Application Saint-John, NB March 15, New Brunswick Insurance Board The Cumis General Insurance Company Rate Revision Application Saint-John, NB March 17, New Brunswick Insurance Board The Dominion of Canada General Insurance Company Rate Revision Application Saint-John, NB April 11, New Brunswick Insurance Board Facility Association Rate Revision Application Saint-John, NB June 7, New Brunswick Insurance Board Pembridge Insurance Company of Canada Rate Revision Application Saint-John, NB June 9, New Brunswick Insurance Board Unifund Assurance Company Rate Revision Application Saint-John, NB June 14,

11 4.5 Appearances - Standing Committee on Legislative Officers (LAC) Year under review: 2010 Fredericton, NB June 28, Other Activities - Attend Open-Line Talk Show Radio Beauséjour Inc. Shédiac, NB March 30, Annual Report 2010 File annual report followed by press conference April 4, Attend Open-Line Talk Show CKRO Péninsule Acadienne, NB April 8, Attend Open-Line Talk Show CKRO Péninsule Acadienne, NB November 4, newspaper interviews - 28 radio interviews - 5 television interviews 9

12 4.7 Website Report Web Site: came into operation on March 7 th, It has proven to be a great tool for communicating information regarding insurance matters and also as an effective means for consumers to reach us for questions, comments or on-line complaints. Below is a usage statistics summary for It will provide you with an indication as to the popularity of our Web Site. Average number of visits per day: Average number of pages visited per day: Average number of visits per month: Average number of pages visited per month: Number of visits for 12 month period: Number of pages visited for 12 month period:

13 Summary by Month Month Visits Pages Files Hits Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Totals

14 5. FILES HANDLED BY THE OFFICE OF THE ADVOCATE 5.1 Number of Files We handled many files during 2011, and the following table shows that we responded to concerns, complaints, requests for information and assistance as follow: Number (%) # of files completed % 5.2 Breakdown by Type of Insurance The following table presents a breakdown of the files by type of insurance. Number (%) Property and Casualty % Auto % Home % Other % Total % Life and Health % Non insurance related % Property and Casualty 4% 27% Auto Home 54% Other 12

15 5.3 Nature of Requests The following table illustrates the main areas of concerns from consumers in regards to insurance. Number (%) Claims % Premiums % Information % Other % 5.4 Origin of Requests We received requests for information from several categories of individuals. The following table reflects the interest of the general public as consumers with regard to our office. Number (%) Public % Insurers % Adjusters % Brokers % Lawyers % Agents % Government % Corporations % Media % Other % 13

16 5.5 Breakdown by County We compiled a list of all the files by county, as shown in the following table. # (%) Gloucester % Westmorland % Saint John % York % Madawaska % Restigouche % Kings % Kent % Carleton % Northumberland % Charlotte % Albert % Sunbury % Victoria % Queens % Other (outside province) % 14

17 6. HIGHLIGHTS FOR Minor Injury Cap Review In January 2011, the New Brunswick government appointed an Auto Insurance Working Group to review two important elements of the Injury Regulation. - The definition of «minor personal injury»; and - The amount of the cap on minor personal injuries which was set at $2,500. The Consumer Advocate attended before the Working Group and made a presentation on April 6, 2011 in Moncton, NB. The Consumer Advocate also attended the following Auto Insurance Working Group Public Consultations: - Edmundston: June 15, Belledune: June 16, Tracadie-Sheila: June 21, Miramichi: June 22, Dieppe: June 23, Saint-John: June 28, Fredericton: June 29, 2011 In November 2011, the Working Group released its report with the following two major recommendations: - The current definition of «minor personal injury» should be discarded and replaced with the following definition: A minor personal injury is a sprain or strain or whiplash-associated disorder, or a combination thereof, which results in minor consequences to a person s life. Minor consequences means that neither the impairments nor the limitations resulting from the injury last more than six months and a person substantially retains his or her pre-accident bodily functions, level of activities and participation in life. 15

18 The cap amount should be increased to between $4,000 and $6,000. There should be annual indexing to CPI. There has been no response yet from the government as to these proposed changes; the report being under review at this moment. 6.2 Minister s Round Table on Home Insurance As a result of concerns expressed in the Consumer Advocate s Annual Report for 2010 regarding rising premiums for home insurance and the increasing threats convened by weather related damages, the Honourable Minister Marie Claude Blais convened a round table to examine these issues. Round table meetings were held by the Honourable Minister and attended by the Consumer Advocate as follows: - On April 13, 2011 with representatives from some insurers doing business in this Province, government officials, advisers to the Minister, elected members of government and the Insurance Bureau of Canada. - On September 21, 2011 with representatives from various organizations, associations, other public interveners and government officials and advisers to the Minister - On October 25, 2011 with advisors to the Minister. 16

19 6.3 Review of Legislative Officers In May of 2011 the Speaker of the Legislative Assembly asked the former Ombudsman and Child and Youth Advocate, Bernard Richard, to carry out a review of the legislative officers in New Brunswick and to report back with recommendations as to ways to enhance the efficiency, effectiveness and accountability of New Brunswick s Legislative officers without impairing their independence. The Consumer Advocate participated in this review process as follows: - June 29, 2011: Individual meeting with the review team of Mr. Richard. - August 8, 2011: Group meeting of Legislative Officers with the review team of Mr. Richard. - September 15, 2011: Forum at the Legislative Assembly involving NB Legislative Officers, Key Stakeholders and subject matter experts. In December 2011 Mr. Bernard Richard submitted his report with the following recommendations pertaining to the Consumer Advocate and the Office of the Consumer Advocate: «it is recommended that the responsibilities of the Consumer Advocate for Insurance be assigned to the Ombudsman effective January 1, 2015 and that the resources of the office of the CAI be relocated to the office of the ombudsman at that time.» The government has not yet responded to the report; the matter being under review at this moment. 17

20 7. ASSESSMENT OF OFFICE EXPENDITURES Subsection 11(1) of the Consumer Advocate for Insurance Act states that: The Consumer Advocate shall annually, as soon as practicable after the close of each fiscal year, by reference to the Public Accounts and by such further inquiries or investigations as he or she may deem necessary, ascertain and clarify the total amount of the expenditure incurred by the Province for or in connection with the administration of this Act during the last preceding fiscal year and the amount of the expenditure so ascertained and certified by the Consumer Advocate is final and conclusive for all purposes of this section. Subsection 11(3) states that: The total amount of the expenditure incurred by the Province for or in connection with the administration of this Act ascertained and certified under the provisions of subsection (1) shall be assessed against licensed insurers ( ). Subsection 11(3) (a) allows the Consumer Advocate to apportion the expenditure against any particular class of insurance. It states as follows: Where any portion, as the Consumer Advocate determines, of the total amount of the expenditure incurred by the Province for or in connection with the administration of this Act was expended directly or indirectly with that class shall be assessed such amount of that portion as his or her net receipts with respect to that class of insurance are of the total net receipts with respect to that class of insurance of all licensed insurers providing insurance of that class: Thus, the Consumer Advocate determined that the total amount of the expenditures for the fiscal year ending March 31, 2011 was to be apportioned as follows, for assessment purposes: 80% as against Property and Casualty insurers 20% as against Life and Health insurers 18

21 The total amount of expenditures incurred for the fiscal year ending March 31, 2011 was $493, This amount has been assessed against every licensed insurer in New- Brunswick, by means of a notice of assessment submitted to each company. Attached hereto as Appendix A is the breakdown of the total amount submitted to all the licensed insurers for the previous year, as well as the amount paid by each. 19

22 8. ISSUES 8.1 Credit Scoring Legislation Although legislation was drafted in late 2010; which would practically ban the use of credit scores for insurance underwriting purposes, the legislation in question has yet to come into force. 8.2 Minor Injury Legislation We await with great anticipation the government s response to the Auto Insurance Working Group report submitted in November Any decision will likely have an impact on consumers, accident victims and the industry in general, depending very much on the changes, if any, to the definition of «minor injury» more than any changes to the amount of the cap itself. 8.3 Recommendations on the office of the Consumer Advocate The office of the Consumer Advocate was established not only as one of the reforms to deal with the auto insurance crisis prevailing at that time but more fundamentally as a means of giving a voice and a tool to the consumers of this Province who felt powerless and defenseless against a mighty and powerful insurance industry. The office has been successful in providing some relief to the consumers in regards to their predicament. Implementing a recommendation that would substantially alter the nature of the office would likely lead to a reoccurrence of the feeling of imbalance and inequity that existed at the time. To reassign the responsibilities of the Consumer Advocate, along with the resources of the office, to the Ombudsman upon the expiration of the present term, is unwarranted. The office provides a service that is useful and appreciated by the consumers of this Province and at absolutely no cost to the taxpayers. There is no purpose to change something that already works in an efficient and effective manner. 20

23 The Province is a leader in this particular area of consumer protection. The office of the Consumer Advocate is considered as being unique and highly regarded due to the Consumer Advocate s status as a legislative officer, with all the independence and authority involved. It s a positive asset and a valuable service which should remain in its present form. 21

24 9. CONCLUSION 2011 has been another year of continuing stability in the auto insurance market. Affordability and availability of insurance continued to improve for the benefit of consumers and the industry in general. There is great concern as to the impact on the office of the Consumer Advocate if the recommendations in the Richard Report are adopted as submitted. It would substantially alter the nature and the quality of the services of the office of the Consumer Advocate and it would also negatively impact on the perception of independence and authority that are held by the public and the insurance industry towards the Consumer Advocate and his office. 22

25 Appendix A: Statement of Assessments Company Amount of Assessement Amount paid Industrial-Alliance Pacific General Insurance Corporation $ $ Industrielle Alliance Assurance et services financiers inc. $3, $3, Novex Insurance Company $ $ Hartford Life Insurance Company $0.00 Household Life Insurance Company $93.35 $93.35 Industrial Alliance Pacific Insurance and Financial Services Inc. $ $ Intact Insurance Company $18, $18, Jewelers Mutual Insurance Company $18.97 $18.97 Markel Insurance Company of Canada $4, $4, Knights of Columbus $ $ La Compagnie d'assurance Belair inc. $0.00 The Guarantee Company of North America $2, $2, Lawyers' Professional Indemnity Company $11.91 $11.91 Legacy General Insurance Company $ $ Liberty Life Assurance Company of Boston $0.00 Liberty Mutual Insurance Company $1, $1, La Capitale assurances et gestion du patrimoine inc. $ $ La Compagnie d'assurances Jevco $ $ La Survivance compagnie mutuelle d'assurance-vie $ $ Fidelity National Title Insurance Company $0.00 L'Excellence Compagnie d'assurance-vie $66.75 $66.75 Life Insurance Company of North America $0.00 Lloyd's Underwriters $9, $9, Lombard Insurance Company $29.55 $29.55 London Life Insurance Company $5, $5, Lumbermen's Underwriting Alliance $ $ L'Union-Vie, compagnie mutuelle d'assurance $53.84 $53.84 L'Internationale compagnie d'assurance-vie $0.00 Lombard General Insurance Company of Canada $5, $5, L'Union Canadienne Compagnie d'assurances $0.00 Manulife Canada Ltd. $ $ Massachusetts Mutual Life Insurance Company $0.00 MD Life Insurance Company $0.00 MetLife Canada / MetVie Canada $0.00 Mitsui Sumitomo Insurance Company Limited $50.73 $50.73 New York Life Insurance Company $48.24 $48.24 Old Republic Insurance Company of Canada $ $ Medavie Inc. $8, $8, Metropolitan Life Insurance Company $0.00 Motors Insurance Corporation $ $

26 Company Amount of Assessement Amount paid National Liability & Fire Insurance Company $84.69 $84.69 Omega General Insurance Company $74.11 $74.11 Optimum Société d'assurance inc. $0.00 Pembridge Insurance Company $6, $6, Primerica Life Insurance Company of Canada $ $ Promutuel Gaspésie - les Îles, Société mutuelle d'assurance générale $2, $2, Promutuel Vie Inc. $0.26 $0.26 Pafco Insurance Company $ $ Penncorp Life Insurance Company $56.32 $56.32 Perth Insurance Company $33.08 $33.08 Primmum Insurance Company $4, $4, Promutuel des Riverains, société mutuelle d'assurance générale $2, $2, Protective Insurance Company $4.85 $4.85 Quebec Assurance Company $0.00 RBC General Insurance Company $4, $4, RBC Insurance Company of Canada $1, $1, Scotia General Insurance Company $0.00 Scottish & York Insurance Co. Limited $ $ Security National Insurance Company $13, $13, Sompo Japan Insurance Inc. $0.44 $0.44 RBC Life Insurance Company $3, $3, Reliable Life Insurance Company $ $ Royal & Sun Alliance Insurance Company of Canada $13, $13, Scotia Life Insurance Company $ $ Western Financial Insurance Company $ $ Sentry Insurance a Mutual Company $4.85 $4.85 SouthEastern Mutual Insurance Company $2, $2, St. Paul Fire and Marine Insurance Company $1, Stanley Mutual Insurance Company $2, $2, Stewart Title Guaranty Company $ $ Sun Life Assurance Company of Canada $13, $13, T.H.E. Insurance Company $0.88 $0.88 SSQ, Société d'assurance-vie inc. $ $ Travelers Guarantee Company of Canada $1, State Farm Fire and Casualty Company $7, $7, State Farm Mutual Automobile Insurance Company $13, $13, Sunderland Marine Mutual Insurance Company Limited $2, $2, TD Direct Insurance Inc. $0.00 TD General Insurance Company $0.00 TD Life Insurance Company $46.41 $46.41 ACA Assurance $48.08 $48.08 The Canada Life Insurance Company of Canada $0.00 The British Aviation Insurance Company Limited $0.00 The Dominion of Canada General Insurance Company $9, $9,

27 Company Amount of Assessement Amount paid The Equitable Life Insurance Company of Canada $ $ TD Home and Auto Insurance Company $ $ Temple Insurance Company $1, $1, The Boiler Inspection and Insurance Company of Canada $ $ The Canada Life Assurance Company $8, $8, The Empire Life Insurance Company $ $ The Grand Orange Lodge of British America Benefit Fund $10.17 $10.17 The Great-West Life Assurance Company $8, $8, The Insurance Company of Prince Edward Island $3, $3, The Missisquoi Insurance Company $0.88 $0.88 The North Waterloo Farmers Mutual Insurance Company $0.00 The Personal Insurance Company $6, $6, The Manufacturers Life Insurance Company $14, $14, The Independent Order of Foresters $7.30 $7.30 The Mortgage Insurance Company of Canada $0.00 The Nordic Insurance Company of Canada / La Nordique compagnie d'assurance du Canada The Order of United Commercial Travelers of America $8.08 $8.08 The Portage la Prairie Mutual Insurance Company $5, $5, The Sovereign General Insurance Company $2, $2, $0.00 The Standard Life Assurance Company 2006 $0.00 The Wawanesa Life Insurance Company $ $ TIG Insurance Company $0.00 Traders General Insurance Company $6, $6, Trans Global Insurance Company $ $ Transamerica Life Canada $ $ The Standard Life Assurance Company of Canada $ $ The Wawanesa Mutual Insurance Company $44, $44, Tokio Marine & Nichido Fire Insurance Co. Ltd. $11.47 $11.47 Trafalgar Insurance Company of Canada $ $ Trans Global Life Insurance Company $31.81 $31.81 Unifund Assurance Company $10, $10, United American Insurance Company $1.17 $1.17 Unity Life of Canada $ $ Virginia Surety Company Inc. $0.00 Western Assurance Company $0.00 Western Surety Company $ $ UAP-NewRotterdam Insurance Company N.V. $0.00 United General Insurance Corporation $2, $2, Utica Mutual Insurance Company $0.00 Waterloo Insurance Company $ $ Western Life Assurance Company $ $ Woman's Life Insurance Society $0.00 Security Insurance Company of Hartford $0.00 XL Reinsurance America Inc. $ $

28 Company Amount of Assessement Amount paid Zurich Insurance Company Ltd $5, $5, XL Insurance Company Limited $1, $1, Zenith Insurance Company $1, $1, Standard Life Assurance Limited $0.00 State Farm International Life Insurance Company Ltd. $ $ Sun Life Insurance (Canada) Limited $0.00 Atradius Credit Insurance N.V. $0.00 Electric Insurance Company $19.85 $19.85 L'Unique assurances générales inc. $ $ Trisura Guarantee Insurance Company $ $ Canada Guaranty Mortgage Insurance Company $56.02 $56.02 Berkley Insurance Company $31.32 $31.32 PMI Mortgage Insurance Company Canada $0.88 AXA General Insurance $0.00 Fenchurch General Insurance Company $ $ Associated Electric & Gas Insurance Services Limited $ $ Safety National Casualty Corporation $0.00 Triton Insurance Company $ $ AXIS Reinsurance Company (Canadian Branch) $41.46 $41.46 Healthcare Insurance Reciprocal of Canada $7.94 $7.94 Global Reinsurance Company $0.00 Union du Canada Assurance-Vie $17.73 $17.73 Poultry Insurance Exchange Reciprocal of Canada $0.00 FaithLife Financial $0.78 $0.78 International Insurance Company of Hannover Ltd $0.00 The Shipowners' Mutual Protection and Indemnity $0.00 DAS Legal Protection Insuance Company Limited $0.00 Darwin National Assurance Company $0.00 ACA Assurance $0.00 ACE INA Insurance $3, $3, ACTRA Fraternal Benefit Society $1.83 $1.83 Affiliated FM Insurance Company $ $ BMO Life Assurance Company $ $ Allstate Insurance Company $0.00 Acadie Vie $2, $2, ACE INA Life Insurance $ $ Aetna Life Insurance Company $0.00 Allianz Global Risks US Insurance Company $2, $2, Allianz Life Insurance Company of North America $2.74 $2.74 Allstate Insurance Company of Canada $13, $13, American Bankers Insurance Company of Florida $3, $3, American Health and Life Insurance Company $70.01 $70.01 American Income Life Insurance Company $ $ Amex Assurance Company $

29 Company Amount of Assessement Amount paid Ascentus Insurance Ltd. $46.32 $46.32 Assomption Compagnie Mutuelle d'assurance-vie $5, $5, Assurant Life of Canada $ $ American Bankers Life Assurance Company of Florida $ $ Munich Reinsurance America, Inc $0.00 Arch Insurance Company $ $ Aspen Insurance UK Limited $60.43 Assurance-Vie Banque Nationale Compagnie d'assurance-vie $ $ CompCorp Life Insurance Company $0.00 $0.00 Aviva Insurance Company of Canada $26, $26, AXA Insurance (Canada) $21, Blue Cross Life Insurance Company of Canada $2, $2, CAA Insurance Company (Ontario) $1, $1, Canadian Lawyers Insurance Association (CLIA) $ $ Canadian Premier Life Insurance Company $ $ AXA Assurances Inc. $ $ AXA Equitable Life Insurance Company $0.00 AXA Pacific Insurance Company $ $ BMO Life Insurance Company $ $ Canadian Farm Insurance Corp. $28.23 $28.23 Canadian Northern Shield Insurance Company $ $ Canadian Universities Reciprocal Insurance Exchange $ $ Canassurance compagnie d'assurance $ $ Chicago Title Insurance Company $ $ CIBC Life Insurance Company Limited / Compagnie d'assurancevie CIBC Limitée $ $ Coachman Insurance Company $1.76 $1.76 Chartis Insurance Company of Canada $9, $9, Carleton Mutual Insurance Company $ $ Aviva International Insurance Limited $0.00 Chubb Insurance Company of Canada $1, $1, CIGNA Life Insurance Company of Canada $0.00 Combined Insurance Company of America $1, $1, Commonwealth Insurance Company $ $ Compagnie Française d'assurance pour le Commerce Extérieur $ $ Co-operators General Insurance Company $22, $22, COSECO Insurance Company $ $ CUMIS General Insurance Company $1, $1, CUNA Mutual Insurance Society $0.13 $0.13 Desjardins Sécurité financière compagnie d'assurance vie $3, $3, Ecclesiastical Insurance Office Public Limited Company $1, $1, Continental Casualty Company $ $ Co-operators Life Insurance Company $1, $1, CT Financial Assurance Company $10.69 $10.69 CUMIS Life Insurance Company $ $

30 Company Amount of Assessement Amount paid CorePointe Insurance Company $6.18 $6.18 Echelon General Insurance Company $ $ Economical Mutual Insurance Company $12, $12, Employers Insurance Company of Wausau $0.00 Euler Hermes American Credit Indemnity Company $ $ Factory Mutual Insurance Company $4, $4, FCT Insurance Company Ltd. $1, $1, Federated Insurance Company of Canada $ $ Elite Insurance Company $6, $6, Westport Insurance Corporation $ $ Everest Insurance Company of Canada $0.00 Farm Mutual Reinsurance Plan Inc. $0.00 Federal Insurance Company $2.65 $2.65 Federation Insurance Company of Canada $12, $12, First American Title Insurance Company $ $ First Canadian Insurance Corporation $1, $1, Fundy Mutual Insurance Company $1, $1, Gerber Life Insurance Company $14.08 $14.08 Grain Insurance and Guarantee Company $ $ Great American Insurance Company of New York $0.00 First North American Insurance Company $15.88 $15.88 GCAN Insurance Company $1, $1, Genworth Financial Mortgage Insurance Company Canada $3, $3, Gore Mutual Insurance Company $28.23 $28.23 Great American Insurance Company $ $ Green Shield Canada $ $ Hartford Fire Insurance Company $22.94 $22.94 $493, $468,