Ast Investment Services, Inc.

Allegations: VIRGINIA BUREAU OF INSURANCE INVESTIGATION RELATING TO AN ALLEGED FAILURE TO PROPERLY INVESTIGATE A CLAIM PRIOR TO ACCEPTANCE OR DENIAL. Status: Final Sanction Detail: ON JULY 14, 2014, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID A SETTLEMENT AMOUNT OF $5,000 TO THE COMMONWEALTH OF VIRGINIA. Summary: ON JULY 14, 2014, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA SETTLED AN INVESTIGATION BY THE VIRGINIA BUREAU OF INSURANCE RELATING TO AN ALLEGED FAILURE TO PROPERLY INVESTIGATE A CLAIM PRIOR TO ACCEPTANCE OR DENIAL AND AGREED TO PAY A SETTLEMENT AMOUNT OF $5,000 TO THE COMMONWEALTH OF VIRGINIA.

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED. PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED.PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED. PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500.

Allegations: DEPARTMENT'S EXAMINATION WAS CONDUCTED TO EVALUATE THE COMPANY'S COMPLIANCE WITH VARIOUS STATUTES AND REGULATIONS, PARTICULARLY RELATING TO GUARANTEED GROUP ANNUITY CONTRACTS. THE EXAMINATION REVEALED CERTAIN INSTANCES IN WHICH THE COMPANY'S PRACTICES MAY NOT HAVE ACCORDED WITH THE COMPANY'S PROCESSES AND PROCEDURES AND DID NOT COMPLY WITH PROVISIONS OF APPLICABLE STATUTES Status: Final Sanction Detail: PICA PAID THE ADMINISTRATIVE FINE ON 04/27/21 Summary: AS A RESULT OF THE DEPARTMENT'S EXAMINATION, PICA WILL TAKE MEASURES THAT ADDRESS CONCERNS RAISED BYTHE DEPARTMENT. ALSO, PICA WAIVED ITS RIGHT TO A HEARING AND CONSENTED TO AN ADMINISTRATIVE FINE OF ONE MILLION AND TWO HUNDRED THOUSAND DOLLARS ($1,200,000) IN ORDER TO FULLY AND COMPLETELY RESOLVE ALLISSUES ARISING FROM THE EXAMINATION.

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AND THE OREGON DIVISION OF FINANCIAL REGULATION HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH CERTAIN NON-PRUDENTIAL INDIVIDUAL LIFE INSURANCE CUSTOMERS IN OREGON DID NOT RECEIVE IN A TIMELY MANNER ANNUAL STATEMENTS, WHICH WERE TO BESENT BY A THIRD-PARTY ADMINISTRATOR. THIS OCCURRED IN 60 INSTANCES OVER A THREE-YEAR PERIOD FROM 2015 TO 2017. THE OREGON CUSTOMERS AT ISSUE HAVE LIFE INSURANCE POLICIES THAT ARE REINSURED AND ADMINISTERED BY PRUDENTIAL. PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDED THAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1). Status: Final Sanction Detail: PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDEDTHAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1). THE CIVIL PENALTY WAS RECEIVED BY THE OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES DIVISION OF FINANCIAL REGULATION ON 2/12/20. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AND THE OREGON DIVISION OF FINANCIAL REGULATION HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH CERTAIN NON-PRUDENTIAL INDIVIDUAL LIFE INSURANCE CUSTOMERS IN OREGON DID NOT RECEIVE IN A TIMELY MANNER ANNUAL STATEMENTS, WHICH WERE TO BE SENT BY A THIRD-PARTY ADMINISTRATOR. THIS OCCURRED IN 60 INSTANCES OVER A THREE-YEAR PERIOD FROM 2015 TO 2017. THE OREGON CUSTOMERS AT ISSUE HAVE LIFE INSURANCE POLICIES THAT ARE REINSURED AND ADMINISTERED BY PRUDENTIAL. PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDED THAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1).

Allegations: ILLINOIS DEPARTMENT OF INSURANCE ALLEGES PRUDENTIAL INSURANCE COMPANY OF AMERICA. NAIC 68241 AND PRUCO LIFE INSURANCE COMPANY, NAIC 79227 ("THE COMPANY") WAS NOT IN COMPLIANCE WITH THE ILLINOIS INSURANCE CODE (215 ILCS 5/1 ET SEQ.) AND DEPARTMENT REGULATIONS (50 III. ADM. CODE 101 CI SEQ.) IN VARIOUS AREAS. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FINED $44,055.00 WHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE OF 05/13/2022. Summary: THE COMPANY ENTERED INTO A STIPULATION AND CONSENT ORDER WITH IL DOI WITHOUT ADMISSION AND WAS REQUIRED TO PAY A FINE TOTALING $44,055.

Allegations: ON SEPTEMBER 24, 2019, A CONSENT ORDER BETWEEN THE NY DEPARTMENT OF FINANCIAL SERVICES AND PICA WAS EXECUTED. THE MATTER RELATED TO THE INADEQUATE DISCLOSURES FOR DEFERRED-TO-IMMEDIATE ANNUITY REPLACEMENTS. A FINE WAS ASSESSED IN THE AMOUNT OF $35,000; RESTITUTION IS ESTIMATED TO BE $14,020. Status: Final Sanction Detail: MONETARY/FINE AMOUNT: $35,000.00 DISGORGEMENT/RESTITUTION: $14,020.00 Summary: ON JULY 02, 2019, A CONSENT ORDER BETWEEN THE NY DEPARTMENT OF FINANCIAL SERVICES AND PICA WAS EXECUTED. A FINE WAS ASSESSED IN THE AMOUNT OF $35,000; RESTITUTION IS ESTIMATED TO BE $14,020.

Allegations: THE COMPANY DID NOT PROVIDE A TIMELY SUBMISSION OF AN ANNUAL REPORT TO THE NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY, DIVISION OF INSURANCE AS REQUIRED BY NRS 683A.08528(1). Status: Final Sanction Detail: $500 FINE PAID 7/10/2019. Summary: THE COMPANY DID NOT PROVIDE A TIMELY SUBMISSION OF AN ANNUAL REPORT TO THE NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY, DIVISION OF INSURANCE AS REQUIRED BY NRS 683A.08528(1).

Allegations: THE MONTANA COMMISSIONER OF SECURITIES AND INSURANCE NOTED THAT THE PRUDENTIAL INSURANCE COMPANY OF AMERICA HAD PROVIDED MARITAL RATHER THAN HOUSEHOLD OR PARTNER DISCOUNTS IN CERTAIN LONG TERM CARE INSURANCE FORMS AND RATES. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID A FINE OF $5,000 ON JULY 28, 2015 Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AGREED TO SETTLE THE MONTANA COMMISSIONER OF SECURITIES AND INSURANCE'S INVESTIGATION AND ALLEGATIONS RELATING TO IMPROPER PROVISION OF LONG TERM CARE INSURANCE DISCOUNTS AND AGREED TO PAY A FINE OF $5,000 WHICH WAS PAID ON JULY 28, 2015.

Allegations: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUP UNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WERE MORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAIN GROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICA SELF-REPORTED THIS MATTER TO ITS REGULATORS THE INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARY PENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONG WITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017. Status: Final Sanction Detail: ON SEPTEMBER 27, 2017 THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID A FINE OF $2,500. Summary: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUP UNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WERE MORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAIN GROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICA SELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARY PENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONG WITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Allegations: ALLEGATION THAT RESPONDENT TERMINATED THE LONG-TERM DISABILITY BENEFITS OF A CLAIMANT WITHOUT A REASONABLE BASIS, IN VIOLATION OF MINN. STAT. §72A.201, SUBD. B(2)(2014). Status: Final Sanction Detail: A CIVIL PENALTY IN THE AMOUNT OF $5,000 WAS PAID TO THE STATE OF MINNESOTA ON 12/22/2015. PRUDENTIAL WAS ORDERED TO CEASE AND DESIST ANY FURTHER VIOLATION OF MINN. STAT. §72A.201, SUBD. B(2) (2014). Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA CONSENTED TO INFORMAL DISPOSITION OF A MATTER BASED ON AN ALLEGATION THAT PRUDENTIAL TERMINATED THE LONG-TERM DISABILITY BENEFITS OF A CLAIMANT WITHOUT A REASONABLE BASIS. BASED ON ITS FINDINGS, THE MINNESOTA DEPT. OF COMMERCE ENTERED AN ORDER FORPRUDENTIAL TO PAY A $5,000 CIVIL PENALTY AND CEASE AND DESIST FROM VIOLATIONS OF MINN. STAT. §72A.201,SUBD. B(2) (2014). THE PENALTY WAS PAID ON DECEMBER 22, 2015.

Allegations: ROUTINE MARKET CONDUCT EXAMINATION BY THE MARYLAND INSURANCE ADMINISTRATION NOTED ISOLATED VIOLATIONS OF MARYLAND INSURANCE LAWS AND REGULATIONS RELATED TO A FAILURE TO COMPLY WITH TIMING AND CONTENT REQUIREMENTS APPLICABLE TO ADVERSE BENEFIT TERMINATION NOTICES AND FAILURE TO INCLUDE THE REQUIRED FRAUD DISCLOSURE STATEMENT ON CLAIM FORMS THAT ARE NOT INDICATIVE OF A PATTERN OR PRACTICE IN ADMINISTERING CLAIMS. Status: Final Sanction Detail: ON AUGUST 18, 2015, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID AN ADMINISTRATIVE PENALTY OF$3,500. Summary: BASED UPON THE FINDINGS OF THE MARYLAND INSURANCE ADMINISTRATION MARKET CONDUCT EXAM, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FOUND TO HAVE VIOLATED PROVISIONS OF THE MARYLAND INSURANCE LAWS AND REGULATIONS AND PAID AN ADMINISTRATIVE PENALTY OF $3,500 WHICH WAS PAID ON AUGUST 18, 2015.

Allegations: THE COMPANY DID NOT PROVIDE A TIMELY AND COMPLETE RESPONSE TO AN INQUIRY FROM THE DIVISION OF INSURANCE. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FINED $500 AND A SANCTION OF $75. THIS WAS PAID ON 10/31/2018. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA DID NOT PROVIDE A TIMELY AND COMPLETE RESPONSE TO AN INQUIRY FROM THE COLORADO DIVISION OF INSURANCE.

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA (PICA) HELD A SWEEPSTAKES IN SEPTEMBER 2022 WHERE THE PRIZE WAS A FULLY PAID $25,000 WHOLE LIFE INSURANCE POLICY, WHICH WAS OPEN TO WASHINGTON CONSUMERS, AND WITHOUT ANY REQUIREMENT TO PURCHASE/RENEW OR RECEIVE SOLICITATION FROM PICA OR ANY AFFILIATE. THE WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER ISSUED A FINAL CONSENT ORDER ON MARCH 5, 2024, STATING THIS ACTION VIOLATED STATE LAW AND IMPOSING A MONETARY PENALTY OF $45,000. Status: Final Sanction Detail: THE WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER ISSUED A FINAL CONSENT ORDER ON MARCH 5, 2024, STATING THIS ACTION VIOLATED STATE LAW AND IMPOSED A MONETARY PENALTY OF $45,000. THE PENALTY WAS PAID ON MARCH 20, 2024. Summary: ON MARCH 5, 2024, A CONSENT ORDER BETWEEN WA OIC AND PICA WAS EXECUTED. A MONETARY PENALTY OF $45,000 WAS ASSESSED AND PAID BY PICA ON MARCH 20, 2024.

Allegations: THE NEBRASKA DEPARTMENT OF INSURANCE NOTED VIOLATIONS OF NEB. REV. STAT. SECTIONS 44-1539 (1), (3) AND(13), AND 210 NEB. ADMIN. CODE SECTION 61-006.03, AS A RESULT OF INACCURATE AND UNTIMELY INFORMATION ON CLAIM APPEAL PROCEDURES FOR LONG TERM DISABILITY BENEFITS BEING PROVIDED TO AN INSURED. Status: Final Sanction Detail: ON NOVEMBER 5, 2014, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID A FINE OF $1,000 Summary: BASED UPON FINDINGS OF THE NEBRASKA DEPARTMENT OF INSURANCE, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FOUND TO HAVE FAILED TO PROVIDE ACCURATE AND TIMELY INFORMATION ON CLAIM APPEAL PROCEDURES FOR LONG TERM DISABILITY BENEFITS TO AN INSURED AND WAS FINED $1,000 WHICH WAS PAID ON NOVEMBER 5, 2014.

Allegations: PENNSYLVANIA INSURANCE DEPARTMENT ALLEGES VIOLATIONS OF :40 P.S. § 323.3(A) WITH RESPECT TO MAINTAININGCERTAIN RECORDS; 40. P.S. §§ 1171.5(A), 1171.5(A)(1)(I), AND 1171.5(A)(7)(II) WITH RESPECT TO AN ERROR ANDOMISSION REGARDING AND RESPONSE TIMES TO, CERTAIN CUSTOMER COMPLAINTS CONSTITUTING AN "UNFAIRMETHOD OF COMPETITION" OR "UNFAIR OR DECEPTIVE ACT OR PRACTICE"; AND 31 PA. CODE §146 5(A) CONSTITUTINGFAILURES TO ACKNOWLEDGE CERTAIN CLAIMS WITHIN 10 WORKING DAYS. Status: Final Sanction Detail: UNDER A CONSENT ORDER, "THE PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA" (SIC) (PICA) WAS ORDERED TO PAY A $45,000 FINE AND CEASE AND DESIST FURTHER VIOLATIONS OF 40 P.S. § 323.3(A); 40. P.S. §§1171.5(A), 1171.5(A)(1)(I), AND 1171.5(A)(7)(II); AND 31 PA. CODE §146.5(A). AS PART OF THE CONSENT ORDER, PICA IS TO UNDERTAKE TO COMPLY WITH PENNSYLVANIA INSURANCE DEPT RECOMMENDATIONS PROVIDED IN AREPORT ACCOMPANYING THE CONSENT ORDER AND PROVIDE SUCH REPORT AND ACCOMPANYING ORDERS TOEACH DIRECTOR. THE $45,000 PAYMENT AND AFFIDAVIT STATING THAT PICA WILL PROVIDE THE REPORT ANDACCOMPANYING ORDERS TO ITS DIRECTORS MUST BE PROVIDED TO THE INSURANCE DEPT. WITHIN 30 DAYS OFTHE DATE OF THE CONSENT ORDER. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PICA CONSENTED TO AN ORDER BASED ON ALLEGATIONS THAT ITVIOLATED 40 P.S. § 323.3(A) WITH RESPECT TO MAINTAINING CERTAIN RECORDS; 40 P.S. §§ 1171.5(A); 1171.5(A)(I),AND 1171.5(A)(7)(II) WITH RESPECT TO AN ERROR AND OMISSION REGARDING, AND RESPONSE TIMES TO, CERTAINCUSTOMER COMPLAINTS CONSTITUTING AN "UNFAIR METHOD OF COMPETITION" OR UNFAIR OR DECEPTIVE ACT ORPRACTICE"; AND 31 PA. CODE §146.5(A) CONSTITUTING FAILURES TO ACKNOWLEDGE CERTAIN CLAIMS WITHIN 10WORKING DAYS. PICA WAS ORDERED TO CEASE AND DESIST FURTHER VIOLATIONS, PAY A FINE OF $45,000, ANDUNDERTAKE TO COMPLY WITH INSURANCE DEPARTMENT RECOMMENDATIONS PROVIDED IN A REPORT ACCOMPANYINGTHE CONSENT ORDER AND PROVIDE SUCH REPORT AND ACCOMPANYING ORDERS TO EACH DIRECTOR. THE $45,000PAYMENT AND AFFIDAVIT STATING THAT PICA WILL PROVIDE THE REPORT AND ACCOMPANYING ORDERS TO ITSDIRECTORS MUST BE PROVIDED TO THE INSURANCE DEPT. WITHIN 30 DAYS OF THE DATE OF THE CONSENT ORDER.

Allegations: ON SEPTEMBER 16, 2019, AST INVESTMENTS SERVICES, INC. AND AN AFFILIATE (TOGETHER "AST INVESTMENTS") ENTERED INTO AN AGREEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") TO SETTLE CHARGES RELATING TO CERTAIN SECURITIES LENDING AND FOREIGN TAX RECLAIM PRACTICES THAT AST INVESTMENTS PREVIOUSLY SELF-REPORTED (THE "ORDER"). THE SEC ALLEGED THAT FROM APPROXIMATELY JULY 2005 TO NOVEMBER 2015, AST INVESTMENTS RECALLED SECURITIES ON LOAN FROM FUNDS IN ADVANCE OF THE SECURITIES' DIVIDEND RECORD DATE TO INCREASE FEDERAL TAX BENEFITS FOR PRUDENTIAL FINANCIAL, INC. ("PRUDENTIAL") AST INVESTMENTS' ULTIMATE PARENT. THE ORDER FOUND THAT IN SOME CASES, THIS RECALL PRACTICE FAILED TO MAXIMIZE SECURITIES LENDING INCOME FOR CERTAIN SEPARATE ACCOUNT INVESTMENTS AND FUNDS. THE SEC ALSO FOUND THAT IN 2006, CERTAIN FUNDS MANAGED BY AST INVESTMENTS WERE REORGANIZED FROM REGISTERED INVESTMENT COMPANIES TO PARTNERSHIPS WHICH HAD THE EFFECT OF PROVIDING CERTAIN FEDERAL INCOME TAX BENEFITS TO PRUDENTIAL (THE "REORGANIZATION"). THE ORDER FURTHER FOUND THAT AS A RESULT OF THE REORGANIZATION, THE FUNDS WERE SUBJECT TO HIGHER TAXES IN CERTAIN FOREIGN JURISDICTIONS AS WELL AS DELAYS IN RECEIVING FUNDS WHEN TAXES WERE REFUNDABLE. THE SEC FOUND, AND AST INVESTMENTS NEITHER ADMITTED OR DENIED, THAT AST INVESTMENTS VIOLATED SECTION 206(2) OF THE ADVISERS ACT OF 1940 ("ADVISERS ACT"), SECTION 206(4) OF THE ADVISERS ACT AND RULES 206(4)-8 AND 206(4)-7 THEREUNDER. Status: Final Sanction Detail: PURSUANT TO THE SETTLEMENT, THE SEC ORDERED DISGORGEMENT OF $27.6 MILLION, AND A CIVIL MONETARY PENALTY OF $5 MILLION. THE DISGORGEMENT AND PENALTY WERE PAID WITHIN 14 DAYS OF THE ENTRY OF THE ORDER. NO PORTION OF THE PENALTY WAS WAIVED. Summary: ON SEPTEMBER 16, 2019, AST INVESTMENT SERVICES, INC. AND AN AFFILIATE (TOGETHER "AST INVESTMENTS") ENTERED INTO AN AGREEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") TO SETTLE CHARGES RELATING TO CERTAIN SECURITIES LENDING AND FOREIGN TAX RECLAIM PRACTICES THAT AST INVESTMENTS PREVIOUSLY SELF-REPORTED. THE SEC ADMINISTRATIVE ORDER IS FINAL. PURSUANT TO THE SETTLEMENT, THE SEC ORDERED DISGORGEMENT OF $27.6 MILLION, AND A CIVIL MONETARY PENALTY OF $5 MILLION. THE DISGORGEMENT AND PENALTY WERE PAID WITHIN 14 DAYS OF THE ENTRY OF THE ORDER.

Allegations: THE PENNSYLVANIA INSURANCE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION OF PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA (PICA). THE EXAMINATION FOCUSED ON THE GROUP INSURANCE DISABILITY AND OTHER HEALTH LINES OF BUSINESS WRITTEN BY THE COMPANY IN PENNSYLVANIA FROM 01/01/2019 THROUGH 06/01/2022. THE EXAMINATION REVEALED CERTAIN INSTANCES IN WHICH THE COMPANY'S PRACTICES MAY NOT HAVE ACCORDED WITH PENNSYLVANIA'S INTERPRETATIONS AND PROVISIONS OF APPLICABLE STATUTES. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERCIA WAS FINED $25,000 WHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE OF 06/12/2024 Summary: AS A RESULT OF THE DEPARTMENT'S EXAMINATION, PICA WILL TAKE MEASURES THAT ADDRESS CONCERNS RAISED BY THE DEPARTMENT. ALSO,PICA WAIVED ITS RIGHT TO A HEARING AND CONSENTED TO AN ADMINISTRATIVE FINE OF TWENTY FIVE THOUSAND DOLLARS($25,000) IN ORDER TO FULLY AND COMPLETELY RESOLVE ALL ISSUES ARISING FROM THE EXAMINATION.