John Hancock Investment Management Llc

Allegations: THE MANUFACTURERS LIFE INSURANCE COMPANY DISTRIBUTED HOSPITAL INSURANCE POLICIES TO SEARS CUSTOMERS THROUGH PERSONS WHO WERE NOT LICENSED WITH THE AUTORITE DES MARCHES FINANCIERS FOR THIS PURPOSE, THUS CONTRAVENING SECTIONS 461,462,470 AND 491 OF THE ACT RESPECTING THE DISTRIBUTION OF FINANCIAL PRODUCTS AND SERVICES AS WELL AS SECTION 406.1 OF THE ACT RESPECTING INSURANCE. Status: Final Sanction Detail: THE AUTORITE DES MARCHES FINANCIERS ISSUED AN ADMINISTRATIVE PENALTY OF $350,000 CAD AGAINST THE MANUFACTURERS LIFE INSURANCE COMPANY. THE $350,000 CAD ADMINISTRATIVE PENALTY WAS PAID ON FEBRUARY 12, 2018. Summary: THE MANUFACTURERS LIFE INSURANCE COMPANY DISTRIBUTED HOSPITAL INSURANCE POLICIES TO SEARS CUSTOMERS THROUGH PERSONS WHO WERE NOT LICENSED WITH THE AUTORITE DES MARCHES FINANCIERS FOR THIS PURPOSE, THUS CONTRAVENING SECTIONS 461,462,470 AND 491 OF THE ACT RESPECTING THE DISTRIBUTION OF FINANCIAL PRODUCTS AND SERVICES AS WELL AS SECTION 406.1 OF THE ACT RESPECTING INSURANCE. THE MANUFACTURERS LIFE INSURANCE COMPANY AGREES TO PAY THE AUTORITE DES MARCHES, UPON EXECUTION OF THE AGREEMENT, THE AMOUNT OF $350,000 CAD AS ADMINISTRATIVE PENALTY FOR NOT HAVING FOLLOWED SOUND COMMERCIAL PRACTICES DURING THE COURSE OF THE DISTRIBUTION OF THE SEARS HOSPITAL PLAN.

Allegations: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) VIOLATED OSR 746.230(1)(A) ON 21 OCCASIONS WHEN IT MISREPRESENTED FACTS AND/OR POLICY PROVISIONS BY INCORRECTLY CALCULATING THE ELIMINATION PERIOD AND/OR WAIVER OF PREMIUM BENEFIT WHEN SETTLING CLAIMS. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) VIOLATED OAR 836-052-0770(2) ON 122 OCCASIONS BY FAILING TO RESPOND WITHIN 30 BUSINESS DAYS AFTER RECEIPT OF A CLAIM FOR LONG TERM CARE. Status: Final Sanction Detail: IN VIOLATION OF ORS 731.988(1), JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) TO PAY CIVIL PENALTY OF $71,500. THE COLLECTION OF $35,000 WAS SUSPENDED FOR THREE YEARS. THE $36,500 WAS PAID ON FEBRUARY 9, 2017. Summary: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) VIOLATED OSR 746.230(1)(A) ON 21 OCCASIONS WHEN IT MISREPRESENTED FACTS AND/OR POLICY PROVISIONS BY INCORRECTLY CALCULATING THE ELIMINATION PERIOD AND/OR WAIVER OF PREMIUM BENEFIT WHEN SETTLING CLAIMS. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) VIOLATED OAR 836-052-0770(2) ON 122 OCCASIONS BY FAILING TO RESPOND WITHIN 30 BUSINESS DAYS AFTER RECEIPT OF A CLAIM FOR LONG TERM CARE. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) TO PAY CIVIL PENALTY OF $71,500. THE COLLECTION OF $35,000 WAS SUSPENDED FOR THREE YEARS. THE $36,500 WAS PAID ON FEBRUARY 9, 2017.

Allegations: THE MANUFACTURERS LIFE INSURANCE COMPANY ALLOWED RESTRICTED AGENTS TO ACT WHILE NOT HOLDING A VALID CERTIFICATE OF AUTHORITY CONTRARY TO SECTION 452(5) OF THE INSURANCE ACT (ALBERTA) AND COMPENSATING AN UNLICENSED RESTRICTED INSURANCE AGENT CONTRARY TO THE PROVISIONS OF SECTION 499(1) OF THE INSURANCE ACT (ALBERTA). Status: Final Sanction Detail: THE ALBERTA TREASURY BOARD AND FINANCE ISSUED AN ADMINISTRATIVE PENALTY OF $5,000 CAD AGAINST THE MANUFACTURERS LIFE INSURANCE COMPANY. THE $5,000 CAD ADMINISTRATIVE PENALTY WAS PAID ON FEBRUARY 2, 2018. Summary: THE MANUFACTURERS LIFE INSURANCE COMPANY ALLOWED RESTRICTED AGENTS TO ACT WHILE NOT HOLDING A VALID CERTIFICATE OF AUTHORITY CONTRARY TO SECTION 452(5) OF THE INSURANCE ACT (ALBERTA) AND COMPENSATING AN UNLICENSED RESTRICTED INSURANCE AGENT CONTRARY TO THE PROVISIONS OF SECTION 499(1) OF THE INSURANCE ACT (ALBERTA). AS A RESULT OF THE NONCOMPLIANCE, THE MANUFACTURERS LIFE INSURANCE COMPANY HAS BEEN ISSUED AN ADMINISTRATIVE PENALTY OF $5,000 CAD BY ALBERTA TREASURY BOARD AND FINANCE.

Allegations: THE OREGON DIVISION OF FINANCIAL REGULATION HAS COMPLETED AN INVESTIGATION INTO JOHN HANCOCK'S HANDLING OF ADULT FOSTER HOME CLAIMS IN OREGON. THE DIVISION'S INVESTIGATION REVEALED THAT JOHN HANCOCK VIOLATED ORS 743.656 (1)(B)(D) ON SEVEN OCCASIONS WHEN IT INCORRECTLY DENIED COVERED SERVICES. THE CONSENT ORDER ADDRESSES THE SEVEN VIOLATIONS AND ALSO IMPOSES THE SUSPENDED CIVIL PENALTY FROM PRIOR ADMINISTRATIVE ACTION INS-16-0262. Status: Final Sanction Detail: STATE OF OREGON DEPARTMENT OF CONSUMER & BUSINESS SERVICES DIVISION OF FINANCIAL REGULATION ISSUED AN ADMINISTRATIVE PENALTY OF $49,000 AGAINST JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.). THE $49,000 ADMINISTRATIVE PENALTY WAS PAID ON JANUARY 18, 2018. Summary: THE OREGON DIVISION OF FINANCIAL REGULATION HAS COMPLETED AN INVESTIGATION INTO JOHN HANCOCK'S HANDLING OF ADULT FOSTER HOME CLAIMS IN OREGON. THE DIVISION'S INVESTIGATION REVEALED THAT JOHN HANCOCK VIOLATED ORS 743.656 (1)(B)(D) ON SEVEN OCCASIONS WHEN IT INCORRECTLY DENIED COVERED SERVICES. A CIVIL PENALTY OF $2,000 PER OCCURRENCE FOR SEVEN VIOLATIONS OF ORS 743.656 (1)(B)(D) FOR A TOTAL OF $14,000. A CIVIL PENALTY OF $35,000 FOR NOT COMPLYING WITH ALL REQUIREMENTS OF THE OREGON INSURANCE CODE, THE SUSPENDED CIVIL PENALTY FROM PRIOR ADMINISTRATIVE ACTION INS-16-0262.

Allegations: PURSUANT TO A MARKET CONDUCT EXAMINATION, THE STATE OF CONNECTICUT INSURANCE DEPARTMENT ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH STATUTORY REQUIREMENTS RELATED TO PRODUCER APPOINTMENTS. Status: Final Sanction Detail: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000. Summary: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000.

Allegations: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) FAILED TO ELECRONICALLY FILE ITS RELACEMENT AND LAPSE REPORT, ITS CLAIMS DENIAL REPORT, ITS RECESSION REPORT, AND ITS SUITABILITY REPORT ON OR BEFORE JUNE 30TH, OF EACH YEAR, AS REQUIRED, UNDER UTAH ADMINISTRATIVE CODE RULE R590-148-25. Status: Final Sanction Detail: THE FINE WAS PAID BY THE DUE DATE OF NOVEMBER 18, 2016 Summary: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) FAILED TO ELECTRONICALLY FILE ITS REPLACEMENT AND LAPSE REPORT, ITS CLAIMS DENIAL REPORT, ITS RECESSION REPORT, AND ITS SUITABILITY REPORT ON OR BEFORE JUNE 30TH, OF EACH YEAR, AS REQUIRED, UNDER UTAH ADMINISTRATIVE CODE RULE R590-148-25. THE UTAH INSURANCE DEPARTMENT ORDERED JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) TO PAY A $750 MONETARY PENALTY.

Allegations: ON APRIL 22, 2014 THE ALBERTA SUPERINTENDENT OF INSURANCE ISSUES A FINE OF $5000.00 AFTER REACHING A DETERMINATION THAT MANULIFE CONTRAVENED SECTIONS 452(5) (INSURANCE AGENT'S CERTIFICATE) AND 499(1) (DEALING WITH UNAUTHORIZED INSURANCE AGENTS) OF THE ALBERTA INSURANCE ACT BY ALLOWING AN ADVISOR, CONTRACTED THROUGH IG INSURANCE SERVICES INC, TO ACT AS AN INSURANCE AGENT AND PAYING COMMISSIONS FOR A PERIOD BETWEEN FEBRUARY 16, 2009 AND SEPTEMBER 12, 2011 WHEN HE WAS NOT AUTHORIZED TO CONDUCT INSURANCE BUSINESS UNDER THE ACT (LICENSE LAPSED). Status: Final Sanction Detail: PENALTY OF CAD$5000.00 AFTER REACHING A DETERMINATION THAT MLI CONTRAVENED SECTIONS 452(5) AND 499(1) OF THE ALBERTA INSURANCE ACT. Summary: A RESPONSE WAS SENT TO THE SUPERINTENDENT OF INSURANCE ON JUNE 23, 2014 EXPLAINING THE VALIDATION PROCEDURES PUT IN PLACE TO AVOID FUTURE VIOLATIONS INCLUDING (1) WORKING WITH OUR MANAGING GENERAL AGENCIES (MGA) AND NATIONAL ACCOUNT CHANNELS (DISTRIBUTORS) WHO ARE LICENSED ENTITIES HOLDING DISTRIBUTION AGREEMENTS WITH MLI TO CONFIRM THEIR ADHERENCE TO THE AGENT SCREENING AND ONGOING MONITORING DUTIES WHICH THEY ARE CONTRACTUALLY OBLIGATED TO CARRY OUT ON OUR BEHALF (2) CONTINUING TO COMPLETE LICENSE REVIEWS FOLLOWING THE RENEWAL PERIOD IN ALBERTA USING THE SPREADSHEETS ON THE ALBERTA INSURANCE COUNCIL WEBSITE AND (3) CONTINUING TO INCLUDE THE REQUIREMENT FOR AGENTS TO CERTIFY THEY ARE LICENSED AND IN GOOD STANDING ON ALL INSURANCE APPLICATION FORMS.

Allegations: A MARKET CONDUCT EXAMINATION FOUND JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) VIOLATED REQUIREMENTS RELATING TO THE REGULATIONS OF LONG-TERM CARE INSURANCE. Status: Final Sanction Detail: THE PENNSYLVANIA INSURANCE DEPARTMENT ORDERED JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) TO PAY A $50,000 FINE. THE FINE WAS PAID ON AUGUST 30, 2016. Summary: THE PENNSYLVANIA INSURANCE DEPARTMENT ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) AND ISSUED A FINE OF $50,000 FOR VIOLATING REQUIREMENTS RELATING TO THE REGULATIONS OF LONG-TERM CARE INSURANCE.

Allegations: A MARKET CONDUCT REPORT DATED JANUARY 12, 2016 STATED THAT A MARKET CONDUCT EXAMINATION REVEALED CONCERNS WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A)'S PROCEDURES AND PRACTICES IN UNDERWRITING AND CLAIMS. Status: Final Sanction Detail: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) WAS DIRECTED TO TAKE IMMEDIATE CORRECTIVE ACTION TO DEMONSTRATE ITS ABILITY AND INTENTION TO CONDUCT BUSINESS IN NORTH CAROLINA ACCORDING TO ITS INSURANCE LAWS AND REGULATIONS. Summary: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) WAS DIRECTED TO TAKE IMMEDIATE CORRECTIVE ACTION TO DEMONSTRATE ITS ABILITY AND INTENTION TO CONDUCT BUSINESS IN NORTH CAROLINA ACCORDING TO ITS INSURANCE LAWS AND REGULATIONS.

Allegations: THE STATE OF WASHINGTON INSURANCE OFFICE OF THE INSURANCE COMMISSIONER IDENTIFIED A VIOLATION OF RCW 48.23A.080(8) IN WHICH JOHN HANCOCK LIFE INSURANCE COMPANY (USA) FAILED TO PROMPTLY NOTIFY THE COMMISSIONER UPON CHANGES TO THE ILLUSTRATION ACTUARY. Status: Final Sanction Detail: ON JUNE 14, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (USA) WAS ISSUED A DRAFT CONSENT ORDER FROM THE INSURANCE COMMISSIONER IN THE STATE OF WASHINGTON RELATED TO AN ALLEGED VIOLATION OF RCW 48.23A.080(8) - FAILURE TO PROMPTLY NOTIFY THE COMMISSIONER UPON CHANGES TO THE ILLUSTRATION ACTUARY. THE CONSENT ORDER WAS EXECUTED ON JULY 7 2022, WHICH INCLUDED A FINE OF $1,000. Summary: ON JUNE 14, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (USA) WAS ISSUED A DRAFT CONSENT ORDER FROM THE INSURANCE COMMISSIONER IN THE STATE OF WASHINGTON RELATED TO AN ALLEGED VIOLATION OF RCW 48.23A.080(8) - FAILURE TO PROMPTLY NOTIFY THE COMMISSIONER UPON CHANGES TO THE ILLUSTRATION ACTUARY. THE CONSENT ORDER WAS EXECUTED ON JULY 7 2022, WHICH INCLUDED A FINE OF $1,000.

Allegations: A MARKET CONDUCT EXAM FOUND THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) VIOLATED REQUIREMENTS RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES FROM JANUARY 1, 2021, THROUGH DECEMBER 31, 2022. Status: Final Sanction Detail: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY IMPLEMENTING CORRECTIVE ACTION PLANS WITHIN 30 DAYS AND PAY AN ADMINISTRATIVE PENALTY OF $53,000. THE COMPANY PAID THE PENALTY ON MAY 10TH, 2024. Summary: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) AND ISSUED A FINE FOR $53,000 FOR VIOLATING PRACTICES RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES. THE EXAM RESULTED IN 78 EXCEPTIONS WITHIN THE CATEGORIES OF: PRODUCER TERMINATIONS, DELIVERY OF ILLUSTRATIONS, PRODUCER APPOINTMENTS, PRODUCER LICENSING AND PRODUCER KNOWLEDGE OR REPLACEMENTS.

Allegations: THE VIRGINIA BUREAU OF INSURANCE ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) IN CERTAIN INSTANCES VIOLATED THE CODE OF VIRGINIA, AND THE VIRGINIA ADMINISTRATIVE CODE, RELATING TO THE CONDITIONS OF A RATE INCREASE FOR A LONG-TERM CARE RATE INSURANCE POLICY BY FAILING TO FILE A NOTICE WITH THE STATE CORPORATION COMMISSION ON THE LONG-TERM CARE RATE INCREASE PRIOR TO USE. Status: Final Sanction Detail: SUBMITTED PAYMENT ON NOV 22, 2023 Summary: ON NOVEMBER 6, 2023, THE VIRGINIA BUREAU OF INSURANCE PROVIDED THE COMPANY WITH A SETTLEMENT OFFER, WHERE JHUSA WAS TO COMPLY WITH ACTION PLANS WITHIN 60 DAYS AND PAY A FINE OF $8,800. JHUSA SIGNED THE CONSENT ORDER AND SUBMITTED THE PAYMENT ON NOVEMBER 22, 2023.

Allegations: PURSUANT TO A TARGETED MARKET CONDUCT EXAMINATION, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION INSURANCE DIVISION ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) FAILED TO COMPLY WITH RHODE ISLAND LAWS AND REGULATIONS RELATED TO THE OVERSIGHT OF REPLACEMENT TRANSACTIONS. Status: Final Sanction Detail: ON MAY 17, 2023, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY PROVIDING CORRECTIVE ACTION PLANS, WITHIN 120 DAYS (SEPTEMBER 14, 2023) AND 180 DAYS (NOVEMBER 13, 2023). THE COMPANY ALSO AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $95,000 WITHIN 30 DAYS TO RESOLVE THE ITEMS IDENTIFIED IN THE FINAL EXAM. Summary: ON MAY 17, 2023, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY PROVIDING CORRECTIVE ACTION PLANS, WITHIN 120 DAYS (SEPTEMBER 14, 2023) AND 180 DAYS (NOVEMBER 13, 2023). THE COMPANY ALSO AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $95,000 WITHIN 30 DAYS TO RESOLVE THE ITEMS IDENTIFIED IN THE FINAL EXAM.

Allegations: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. Status: Final Sanction Detail: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) SHALL PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON DECEMBER 6, 2019. Summary: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) WAS ORDERED TO PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON DECEMBER 6, 2019.