Jackson National Asset Management, Llc

Allegations: THIS EXAMINATION FOCUSED ON CLAIMS PROCESSING ACROSS ALL PRODUCT TYPES. THE REPORT STATES THAT IN TWO INSTANCES, THE COMPANY MISREPRESENTED TO CLAIMANTS' PERTINENT FACTS OR INSURANCE POLICY PROVISIONS RELATING TO ANY COVERAGES AT ISSUE. THE COMPANY GAVE THE BENEFICIARIES INCORRECT INTEREST RATE INFORMATION IN LETTERS DATED AUGUST 23, 2018 AND MAY 24, 2019. THE DEPARTMENT ALLEGES THESE ACTS ARE IN VIOLATION OF CIC §790.03(H)(1). Status: Final Sanction Detail: THE LETTERS PROVIDED TO BENEFICIARIES INCLUDED LANGUAGE NOT APPLICABLE TO CALIFORNIA STATUTORY INTEREST LAW. THESE WERE ISOLATED INSTANCES WHEREIN ANOTHER STATE'S INTEREST REQUIREMENT WAS INADVERTENTLY INCLUDED IN THE BENEFICIARY LETTERS. THE ADJUSTER WAS COUNSELED TO ENSURE FUTURE COMPLIANCE. Summary: THE LETTERS PROVIDED TO BENEFICIARIES INCLUDED LANGUAGE NOT APPLICABLE TO CALIFORNIA STATUTORY INTEREST LAW. THESE WERE ISOLATED INSTANCES WHEREIN ANOTHER STATE'S INTEREST REQUIREMENT WAS INADVERTENTLY INCLUDED IN THE BENEFICIARY LETTERS. THE ADJUSTER WAS COUNSELED TO ENSURE FUTURE COMPLIANCE.

Allegations: THE COMPANY VIOLATED CERTAIN PROVISIONS OF THE LOUISIANA INSURANCE CODE, TITLE 22, LA. R.S. 11:1 ET SEQ. SPECIFICALLY, THE VIOLATION RELATES TO MISREPRESENTING THE BENEFITS OF THE POLICY AND PAYING OUT THE LUMP SUM TO A BENEFICIARY WHEN A PRE-SELECTED DEATH BENEFIT OPTION HAD BEEN SELECTED BY THE CONTRACT OWNER. Status: Final Sanction Detail: THE COMPANY REMITED THE FINE OF $1,000 TO THE LOUISIANA DEPARTMENT OF INSURANCE. Summary: THE COMPANY REMITED THE FINE OF $1,000 TO THE LOUISIANA DEPARTMENT OF INSURANCE.

Allegations: NC MARKET CONDUCT EXAM FOCUSED ON CLAIMS SETTLEMENTS, COMPLAINT HANDLING AND THE SUITABILITY REVIEW OF FIXED ANNUITIES. ONE MATERIAL ITEM WAS IDENTIFIED; VIOLATIONS CONCERNING INCORRECT INTEREST ON PROCEEDS PAID ON SOME CLAIMS. THE EXAMINER ADVISED THE COMPANY IT WILL NOT RECOMMEND A FINE BUT ASKED THE COMPANY TO REVIEW THE ENTIRE EXAM POPULATION AND REMEDIATE ANY ADDITIONAL CLAIMS. ON 29 JULY 2019 THE COMPANY RECEIVED DIRECTIVES TO COMPLETE A SELF-CRITICAL ANALYSIS FOR A TWO-YEAR TIME PERIOD AND PROVIDE REPORTS TO NC ON A SEMI-ANNUAL BASIS. Status: Final Sanction Detail: THE COMPANY AGREED TO REVIEW AND AMEND EXISTING PROCEDURES AND PAY AGGREGATE REMEDIATION TO POLICYHOLDERS IN THE AMOUNT OF $45,334. THE FINAL REPORT WAS RECEIVED AND PURSUANT TO NC STATUTORY REQUIREMENTS IT WAS REVIEWED BY THE JACKSON BOARD. Summary: THE COMPANY AGREED TO REVIEW AND AMEND EXISTING PROCEDURES AND PAY AGGREGATE REMEDIATION TO POLICYHOLDERS IN THE AMOUNT OF $45,334. THE FINAL REPORT WAS RECEIVED AND PURSUANT TO NC STATUTORY REQUIREMENTS IT WAS REVIEWED BY THE JACKSON BOARD.

Allegations: THE EXAM BY THE DELAWARE DEPARTMENT OF INSURANCE ("DE" OR THE "DEPARTMENT") WAS A COMPREHENSIVE, MARKET CONDUCT EXAMINATION THAT COVERED ALL ASPECTS OF JACKSON'S CORE ANNUITY BUSINESS AS WELL AS CLOSED BLOCKS OF LIFE AND ANNUITY BUSINESS. THE EXAMINATION FOCUSED ON ADVERTISING, CLAIMS, COMPLAINTS, POLICYHOLDER SERVICES, PRODUCER LICENSING, POLICY FORMS, AND UNDERWRITING AND RATING. TWENTY AREAS WERE TESTED AND OVER 1,081 RECORDS WERE REVIEWED, FROM A TOTAL POPULATION OF APPROXIMATELY 17,287 RECORDS THAT WERE PROVIDED TO THE DEPARTMENT. Status: Final Sanction Detail: IN ITS FINAL REPORT, DELAWARE NOTED 9 FINDINGS WITH 46 EXCEPTIONS. THE DEPARTMENT ORIGINALLY ASSESSED A FINE OF $46,000, BUT THE REGULATORY AFFAIRS TEAM WAS ABLE TO NEGOTIATE AND REDUCE THE NUMBER OF EXCEPTIONS NOTED ON THE CONSENT ORDER. AS A RESULT, THE FINE AMOUNT WAS LOWERED TO $35,000. THE FINAL REPORT WAS ISSUED ON OCTOBER 26, 2021, AND A CONSENT ORDER WAS EXECUTED ON NOVEMBER 30, 2021. Summary: IN ITS FINAL REPORT, DELAWARE NOTED 9 FINDINGS WITH 46 EXCEPTIONS. THE DEPARTMENT ORIGINALLY ASSESSED A FINE OF $46,000, BUT THE REGULATORY AFFAIRS TEAM WAS ABLE TO NEGOTIATE AND REDUCE THE NUMBER OF EXCEPTIONS NOTED ON THE CONSENT ORDER. AS A RESULT, THE FINE AMOUNT WAS LOWERED TO $35,000. THE FINAL REPORT WAS ISSUED ON OCTOBER 26, 2021, AND A CONSENT ORDER WAS EXECUTED ON NOVEMBER 30, 2021.

Allegations: ON JUNE 10, 2013, JACKSON RECEIVED A NOTIFICATION FROM THE KANSAS INSURANCE DEPARTMENT ANNOUNCING A TARGETED DESK EXAMINATION FOCUSING ON COMPLAINT HANDLING. Status: Final Sanction Detail: JACKSON ENTERED INTO A SUMMARY ORDER WITH THE DEPARTMENT AND PAID A FINE OF $500. Summary: ON JUNE 10, 2013, JACKSON RECEIVED A NOTIFICATION FROM THE KANSAS INSURANCE DEPARTMENT ANNOUNCING A TARGETED DESK EXAMINATION FOCUSING ON COMPLAINT HANDLING. JACKSON RECEIVED THE FINAL EXAMINATION REPORT CONTAINING A MINOR VIOLATION CONCERNING THE ACCURACY OF JACKSON'S COMPLAINT LOG. JACKSON ENTERED INTO A SUMMARY ORDER WITH THE DEPARTMENT AND PAID A FINE OF $500.

Allegations: ON JANUARY 24, 2014, JACKSON RECEIVED A NOTICE FROM THE PENNSYLVANIA INSURANCE DEPARTMENT ANNOUNCING THAT A MARKET CONDUCT RE-EXAMINATION WOULD COMMENCE WITHIN THE NEXT 90 DAYS. THE FOCUS OF THE EXAMINATION IS TO DETERMINE JACKSON'S IMPLEMENTATION OF A CORRECTIVE ACTION PLAN AND COMPLIANCE WITH THE AUGUST 2, 2012 EXAM REPORT. THE 2012 EXAM REPORT INCLUDED 6 RECOMMENDATIONS RELATED TO UNDERWRITING FORMS AND PRODUCER LICENSING AND CARRIED A FINE OF $150,000. JACKSON RECEIVED THE FINAL EXAM REPORT, WHICH CONTAINED VIOLATIONS CONCERNING POLICY ILLUSTRATIONS, PRODUCER APPOINTMENTS AND THE DISCLOSURE OF LIFE INSURANCE POLICY LOAN INTEREST RATES. Status: Final Sanction Detail: JACKSON ENTERED INTO A CONSENT ORDER AND PAID A $35,000 FINE IN CONNECTION WITH THE VIOLATIONS. Summary: ON JANUARY 24, 2014, JACKSON RECEIVED A NOTICE FROM THE PENNSYLVANIA INSURANCE DEPARTMENT ANNOUNCING THAT A MARKET CONDUCT RE-EXAMINATION WOULD COMMENCE WITHIN THE NEXT 90 DAYS. THE FOCUS OF THE EXAMINATION IS TO DETERMINE JACKSON'S IMPLEMENTATION OF A CORRECTIVE ACTION PLAN AND COMPLIANCE WITH THE AUGUST 2, 2012 EXAM REPORT. THE 2012 EXAM REPORT INCLUDED 6 RECOMMENDATIONS RELATED TO UNDERWRITING FORMS AND PRODUCER LICENSING AND CARRIED A FINE OF $150,000. JACKSON RECEIVED THE FINAL EXAM REPORT, WHICH CONTAINED VIOLATIONS CONCERNING POLICY ILLUSTRATIONS, PRODUCER APPOINTMENTS AND THE DISCLOSURE OF LIFE INSURANCE POLICY LOAN INTEREST RATES. JACKSON ENTERED INTO A CONSENT ORDER AND PAID A $35,000 FINE IN CONNECTION WITH THE VIOLATIONS.

Allegations: ON MARCH 13, 2014, JACKSON RECEIVED A NOTICE FROM THE MARYLAND INSURANCE ADMINISTRATION STATING THAT THEY HAD COMMENCED A TARGETED MARKET CONDUCT EXAM FOCUSING ON THE ANNUITY SUITABILITY REQUIREMENTS. THE PERIOD OF THE EXAM IS JANUARY 1, 2012, THROUGH DECEMBER 31, 2013. JACKSON RECEIVED THE FINAL EXAM REPORT AND CONSENT ORDER IDENTIFYING VIOLATIONS CONCERNING FORM FILING COMPLIANCE, AND REPLACEMENT NOTIFICATION REQUIREMENTS. IN A LETTER ACCOMPANYING THE REPORT, THE STATE ADDRESSED THE ISSUE OF CONTRACT SITUS DETERMINATION AND HAS DIRECTED JACKSON TO ESTABLISH PROCEDURES TO ENSURE COMPLIANCE WITH MARYLAND INSURANCE LAWS. Status: Final Sanction Detail: JACKSON AGREED TO THE STIPULATION AND CONSENT AND PAID THE ADMINISTRATIVE PENALTY OF $8,200. Summary: ON MARCH 13, 2014, JACKSON RECEIVED A NOTICE FROM THE MARYLAND INSURANCE ADMINISTRATION STATING THAT THEY HAD COMMENCED A TARGETED MARKET CONDUCT EXAM FOCUSING ON THE ANNUITY SUITABILITY REQUIREMENTS. THE PERIOD OF THE EXAM IS JANUARY 1, 2012, THROUGH DECEMBER 31, 2013. JACKSON RECEIVED THE FINAL EXAM REPORT AND CONSENT ORDER IDENTIFYING VIOLATIONS CONCERNING FORM FILING COMPLIANCE, AND REPLACEMENT NOTIFICATION REQUIREMENTS. IN A LETTER ACCOMPANYING THE REPORT, THE STATE ADDRESSED THE ISSUE OF CONTRACT SITUS DETERMINATION AND HAS DIRECTED JACKSON TO ESTABLISH PROCEDURES TO ENSURE COMPLIANCE WITH MARYLAND INSURANCE LAWS. JACKSON AGREED TO THE STIPULATION AND CONSENT AND PAID THE ADMINISTRATIVE PENALTY OF $8,200.

Allegations: JACKSON WAS NOT IN COMPLIANCE WITH ONE AREA OF THE ILLINOIS INSURANCE CODE AND/OR DEPARTMENT REGULATIONS IN THAT CHECKS PROCESSED ON FRIDAY NIGHTS AND MAILED THE NEXT BUSINESS DAY DID NOT INCLUDE THE APPROPRIATE AMOUNT OF INTEREST FOR THE ADDITIONAL DAYS. Status: Final Sanction Detail: NONE Summary: INSTITUTE AND MAINTAIN PROCEDURES TO COMPLY WITH ILLINOIS INSURANCE CODE BY ENSURING THAT CHECKS PROCESSED ON FRIDAY NIGHTS AND MAILED THE NEXT BUSINESS DAY SHALL INCLUDE THE APPROPRIATE AMOUNT OF INTEREST FOR THE ADDITIONAL DAYS. SUBMIT TO THE DIRECTOR OF THE ILLINOIS DEPARTMENT OF INSURANCE PROOF OF COMPLIANCE WITH THE ORDER WITHIN FIFTEEN (15) DAYS OF THE EXECUTION OF THE ORDER.

Allegations: THE FIRM MODIFIED SOME APPLICATION FORMS BY TYPED INTERLINEATIONS OF CERTAIN PROVISIONS OF THE APPLICATIONS WHICH REFERRED TO BENEFITS NO LONGER OFFERED BY THE FIRM. IN ADDITION, THE FIRM FAILED TO NOTIFY AN EXISTING INSURER OF THE PROPOSED REPLACEMENT WITHIN FIVE (5) BUSINESS DAYS AFTER RECEIPT OF A COMPLETED APPLICATION. Status: Final Sanction Detail: N/A Summary: THE FIRM SHALL CORRECT THE VIOLATIONS AS NOTED IN THE REPORT WITHIN NINETY (90) DAYS OF THE EXECUTED ORDER AND SHALL SET FORTH IN A LETTER TO THE COMMISSIONER THAT THE VIOLATIONS HAVE BEEN CORRECTED AND MEASURES HAVE BEEN TAKEN TO ENSURE THAT SUCH VIOLATIONS DO NOT OCCUR IN THE FUTURE. THE LETTER SHALL BE ACCOMPANIED BY A CERTIFICATION SIGNED BY AN OFFICER OF THE FIRM, CERTIFYING THAT THE INFORMATION IS TRUE AND ACCURATE.

Allegations: THE FIRMED FAILED TO PROPERLY NOTIFY THE DEPARTMENT OF TERMINATION OF APPOINTMENTS FOR PRODUCERS, ACCEPTED BUSINESS BY A PRODUCER NOT PROPERLY APPOINTED, ACCEPTED APPLICATIONS WITHOUT REQUIRED PRODUCER RESPONSE TO THE REPLACEMENT QUESTION, ACCEPTED REPLACEMENT FORMS DATED AFTER APPLICATION DATE, AND FAILED TO PROVIDE WRITTEN NOTIFICATION OF REPLACEMENT OF POLICIES TO THE EXISTING INSURER. Status: Final Sanction Detail: N/A Summary: THE FIRM ACCEPTS THE FINAL EXAMINATION REPORT AND AGREES THAT THE DEPARTMENT MAY FILE THE FINAL EXAMINATION REPORT WITHOUT ANY FURTHER MODIFICATIONS. UPON EXECUTION OF THE STIPULATION AND CONSENT ORDER, THE FIRM AGREES TO THE PAYMENT OF AN ADMINISTRATIVE PENALTY OF $3,800.

Allegations: JACKSON NATIONAL LIFE INSURANCE COMPANY WAS NOT IN COMPLIANCE WITH CERTAIN SECTIONS OF THE STATE INSURANCE LAWS, I.E. RECORDKEEPING, PRODUCER APPOINTMENT REQUIREMENTS, CERTAIN NOTIFICATION AND ILLUSTRATION REQUIREMENTS AND DELIVERY RECEIPT REQUIREMENTS. Status: Final Sanction Detail: $35,000 CIVIL PENALTY PAID OCTOBER 10, 2014 Summary: WITHIN THIRTY (30) DAYS OF THE ORDER SUBMIT TO THE PENNSYLVANIA INSURANCE DEPARTMENT AN AFFIDAVIT STATING UNDER OATH THAT IT WILL PROVIDE EACH OF THE DIRECTORS OF JACKSON NATIONAL LIFE INSURANCE COMPANY ("JACKSON") A COPY OF THE ADOPTED REPORT AND RELATED ORDER. JACKSON SHALL COMPLY WITH ALL RECOMMENDATIONS IN THE EXAMINATION REPORT.

Allegations: ON MARCH 13, 2014, JACKSON RECEIVED A NOTICE FROM THE MARYLAND INSURANCE ADMINISTRATION STATING THAT THEY HAD COMMENCED A TARGETED MARKET CONDUCT EXAM FOCUSING ON THE ANNUITY SUITABILITY REQUIREMENTS. THE PERIOD OF THE EXAM IS JANUARY 1, 2012, THROUGH DECEMBER 31, 2013. JACKSON RECEIVED THE FINAL EXAM REPORT AND CONSENT ORDER IDENTIFYING VIOLATIONS CONCERNING FORM FILING COMPLIANCE, AND REPLACEMENT NOTIFICATION REQUIREMENTS. IN A LETTER ACCOMPANYING THE REPORT, THE STATE ADDRESSED THE ISSUE OF CONTRACT SITUS DETERMINATION AND HAS DIRECTED JACKSON TO ESTABLISH PROCEDURES TO ENSURE COMPLIANCE WITH MARYLAND INSURANCE LAWS. Status: Final Sanction Detail: JACKSON TO ESTABLISH PROCEDURES TO ENSURE COMPLIANCE WITH MARYLAND INSURANCE LAWS. Summary: ON MARCH 13, 2014, JACKSON RECEIVED A NOTICE FROM THE MARYLAND INSURANCE ADMINISTRATION STATING THAT THEY HAD COMMENCED A TARGETED MARKET CONDUCT EXAM FOCUSING ON THE ANNUITY SUITABILITY REQUIREMENTS. THE PERIOD OF THE EXAM IS JANUARY 1, 2012, THROUGH DECEMBER 31, 2013. JACKSON RECEIVED THE FINAL EXAM REPORT AND CONSENT ORDER IDENTIFYING VIOLATIONS CONCERNING FORM FILING COMPLIANCE, AND REPLACEMENT NOTIFICATION REQUIREMENTS. IN A LETTER ACCOMPANYING THE REPORT, THE STATE ADDRESSED THE ISSUE OF CONTRACT SITUS DETERMINATION AND HAS DIRECTED JACKSON TO ESTABLISH PROCEDURES TO ENSURE COMPLIANCE WITH MARYLAND INSURANCE LAWS. THE STATE ASSESSED AN ADMINISTRATIVE FINE OF $8,200. (1/15/15) THE COMPANY AGREED TO THE STIPULATION AND CONSENT AND PAID THE ADMINISTRATIVE PENALTY. WE ARE WORKING ON THE NECESSARY STEPS TO COMPLY WITH THE REQUIREMENTS OF THE STIPULATION AND CONSENT.

Allegations: JACKSON PERMITTED TEN (10) PRODUCERS TO ACT AS AGENTS OF THE COMPANY WITHOUT THE REQUIRED APPOINTMENT IN VIOLATION OF 38A-702M OF THE CONNECTICUT GENERAL STATUTES. Status: Final Sanction Detail: $15,000 FINE PAID DECEMBER 12, 2013 Summary: JACKSON AGREES TO UNDERTAKE A COMPLETE REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUTES IN THE AREA OF CONCERN AND AGREES TO COMPLY WITH THE RECOMMENDATIONS IN THE MARKET CONDUCT REPORT WITHIN NINETY (90) DAYS OF THE STIPULATION AND CONSENT ORDER.

Allegations: IN CONNECTION WITH AN ACQUISITION, JACKSON NATIONAL LIFE INSURANCE COMPANY ("JACKSON") DID NOT TIMELY FILE A NAME CHANGE ENDORSEMENT WITH THE STATE OF WASHINGTON INSURANCE COMMISSIONER AND SENT VARIOUS CORRESPONDENCE WITH AN INCORRECT LEGAL NAME TO WASHINGTON CONSUMERS. JACKSON ALSO USED A NON-COMPLIANT FRAUD WARNING ON ITS FORMS. Status: Final Sanction Detail: $8,000 FINE PAID ON 3/18/2016 Summary: JACKSON SHALL PAY A FINE IN THE AMOUNT OF $8,000 BY MARCH 24, 2016. JACKSON SHALL FULLY COMPLY WITH THE STATUTES AND/OR REGULATIONS OF THE STATE OF WASHINGTON WHICH ARE THE SUBJECT OF THIS ORDER. IN ADDITION JACKSON WILL FULLY CARRY OUT ITS OBLIGATIONS UNDER THE COMPLIANCE PLAN AND WITHIN 30 DAYS OF THE ORDER PROVIDE A CORRECTIVE ACTION PLAN.

Allegations: IN CONNECTION WITH THE SALE OF A VARIABLE ANNUITY, JACKSON NATIONAL LIFE INSURANCE COMPANY ("JACKSON") DID NOT COMPLY WITH THE STATE SUITABILITY REQUIREMENTS AND UTILIZED AN APPLICATION FORM NOT APPROVED FOR USE IN THE STATE OF WASHINGTON. Status: Final Sanction Detail: $20000 FINE PAID MARCH 18, 2016 Summary: JACKSON SHALL PAY A FINE IN THE AMOUNT OF $20,000 BY MARCH 25, 2016. IN ADDITION, JACKSON WILL REFUND THE PREMIUM AND ANY OTHER PAYMENTS ALONG WITH 8% INTEREST TO THE INSURED BY MARCH 25, 2016 AND PROVIDE A CONFIRMATION LETTER TO THE INSURANCE COMMISSIONER THAT SUCH PAYMENTS HAVE BEEN MADE.

Allegations: JACKSON SHALL COMPLY WITH RECOMMENDATIONS IN THE REPORT OF EXAMINATION THAT PERTAIN TO PRODUCER LICENSING AND RECORDS, INCLUDING AGENT APPLICATIONS FOR APPOINTMENTS AND NOTICE OF TERMINATIONS; AND NOT ACCEPTING BUSINESS PRIOR TO AGENT APPOINTMENTS. Status: Final Sanction Detail: NONE Summary: RESPOND TO OFFICE OF THE COMMISSIONER OF INSURANCE WITHIN 90 DAYS STATING HOW JACKSON HAS COMPLIED WITH EACH RECOMMENDATION.

Allegations: FAILURE TO MAINTAIN COMPLAINT HANDLING PROCEDURES IN ACCORDANCE WITH KANSAS INSURANCE STATUTE 40-2404(10). TEN (10) OF THE COMPLAINTS HAD AN INCORRECT DATE ON THE LOG. Status: Final Sanction Detail: $500 PENALTY PAID AUGUST 14, 2014 Summary: JACKSON SHALL ENSURE ALL COMPLAINTS ARE RECORDED IN THE REQUIRED FORMAT ON THE FIRM'S COMPLAINT REGISTER.

Allegations: JACKSON DID NOT COMPLY WITH A RECOMMENDATION IN A PREVIOUS COMPLIANCE ORDER TO ENSURE SUBMISSION OF AGENT APPOINTMENT APPLICATIONS WITHIN 15 DAYS AFTER THE EARLIER OF THE DATE THE AGENT CONTRACT IS EXECUTED OR AGENT SUBMITS FIRST APPLICATION AND DID NOT MAINTAIN AGENT APPOINTMENT AND TERMINATION RECORDS AS REQUIRED BY THE WISCONSIN STATUTE AND ADMINISTRATIVE CODE. Status: Final Sanction Detail: $1,000 PAID 07/08/2013 Summary: PAY A FORFEITURE OF $1,000 AND COMPLY WITH THE COMPLIANCE ORDERS.

Allegations: JACKSON RECEIVED AN INQUIRY FROM THE WASHINGTON OFFICE OF THE COMMISSIONER OF INSURANCE (OIC) RELATED TO PRODUCER CHARLES FACKRELL. THE REQUEST TARGETS THE COMPANY'S SUITABILITY PROCESS, SPECIFICALLY IN RELATION TO A SPECIFIC CUSTOMER. Status: Final Sanction Detail: $20,000 FINE Summary: THE EXECUTED CONSENT ORDER AND PAYMENT WERE FILED WITH THE OIC ON 3/23/2016.

Allegations: JACKSON THAT THE STATE OF WASHINGTON WAS CONDUCTING A MARKET CONDUCT CONTINUUM ACTION (PRE-EXAM). INITIAL REQUESTS INCLUDED LEGAL NAME CONCERNS AND CLAIM & COMPLAINT PROCEDURES. JACKSON RECEIVED A REQUEST FOR 105 CLAIM AND DISBURSEMENT FILES. ALL FILES WERE PROVIDED ON AUGUST 4, 2014. ON JANUARY 26, 2015, JACKSON RECEIVED FILE REVIEW FINDINGS REQUESTING ADDITIONAL INFORMATION. JACKSON RESPONDED ON MARCH 3, 2015. JACKSON RECEIVED NOTICE ON NOVEMBER 20, 2015, THAT THE OIC HAD COMPLETED THE CONTINUUM ACTION AND REFERRED THE MATTER TO THEIR LEGAL DEPARTMENT FOR FURTHER REVIEW AND POSSIBLE ENFORCEMENT ACTION. Status: Final Sanction Detail: JACKSON WAS FINED $8,000.00 AND WAS REQUIRED TO SUBMIT A COMPLIANCE PLAN. THE EXECUTED CONSENT ORDER AND PAYMENT WERE FILED WITH THE OIC. THE COMPLIANCE PLAN HAD TO BE FILED 30 DAYS AFTER THE ENTRY OF THE CONSENT ORDER. Summary: JACKSON WAS FINED $8,000.00 AND WAS REQUIRED TO SUBMIT A COMPLIANCE PLAN. THE EXECUTED CONSENT ORDER AND PAYMENT WERE FILED WITH THE OIC. THE COMPLIANCE PLAN HAD TO BE FILED 30 DAYS AFTER THE ENTRY OF THE CONSENT ORDER.

Allegations: THE EXAM BY THE ILLINOIS DEPARTMENT OF INSURANCE ("IL" OR THE "DEPARTMENT") WAS A COMPREHENSIVE, MARKET CONDUCT EXAMINATION THAT COVERED ALL ASPECTS OF JACKSON'S CORE ANNUITY BUSINESS AS WELL AS CLOSED BLOCKS OF LIFE AND ANNUITY BUSINESS. THE EXAMINATION FOCUSED ON CLAIMS, COMPLAINTS, POLICYHOLDER SERVICES, PRODUCER LICENSING, POLICY FORMS, AND ADVERTISING. TWENTY-ONE AREAS WERE TESTED AND OVER 2,700 RECORDS WERE REVIEWED, FROM A TOTAL POPULATION OF APPROXIMATELY 10,200. FROM THE 2,700 RECORDS, 17 VIOLATIONS WERE NOTED. Status: Final Sanction Detail: UPON COMPLETION OF THE EXAMINATION, ILLINOIS NOTED 14 INITIAL FINDINGS. JACKSON WAS ABLE TO NEGOTIATE THE REMOVAL OF THREE FINDINGS RELATED TO CONSUMER COMPLAINTS AND SUITABILITY, REDUCE THE NUMBER OF EXCEPTIONS (WITHIN PAID LONG-TERM CARE, DENIED LONG TERM CARE, ANNUITY NEW BUSINESS, AND REPLACEMENTS), AND WAS SUCCESSFUL IN REDUCING THE FINE FROM $11,500 TO $2,500. THE FINAL REPORT WAS ISSUED ON MAY 11, 2021, AND A CONSENT ORDER WAS EXECUTED ON JUNE 11, 2021, WHICH REQUIRES REMEDIATION WITHIN THIRTY (30) DAYS. Summary: UPON COMPLETION OF THE EXAMINATION, ILLINOIS NOTED 14 INITIAL FINDINGS. JACKSON WAS ABLE TO NEGOTIATE THE REMOVAL OF THREE FINDINGS RELATED TO CONSUMER COMPLAINTS AND SUITABILITY, REDUCE THE NUMBER OF EXCEPTIONS (WITHIN PAID LONG-TERM CARE, DENIED LONG TERM CARE, ANNUITY NEW BUSINESS, AND REPLACEMENTS), AND WAS SUCCESSFUL IN REDUCING THE FINE FROM $11,500 TO $2,500. THE FINAL REPORT WAS ISSUED ON MAY 11, 2021, AND A CONSENT ORDER WAS EXECUTED ON JUNE 11, 2021, WHICH REQUIRES REMEDIATION WITHIN THIRTY (30) DAYS.

Allegations: THE SURVEY BY THE WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER ("WA" OR "WASHINGTON") WAS A TARGETED SURVEY ASSESSING WHETHER JACKSON VERIFIED THAT FINANCIAL PROFESSIONALS HAD COMPLETED REQUIRED ANNUITY TRAINING BEFORE THEY SOLICITED ANNUITY BUSINESS. THE OFFICE REVIEWED THE ENTIRE POPULATION OF 513 FINANCIAL PROFESSIONALS THAT SUBMITTED ANNUITY BUSINES DURING THE PERIOD. OF THE 513 FINANCIAL PROFESSIONALS, JACKSON ACCEPTED APPLICATIONS FROM 5 FINANCIAL PROFESSIONALS WHO HAD NOT COMPLETED THE REQUIRED ANNUITY SUITABILITY TRAINING. IT IS UNUSUAL THAT AN ERROR RATE OF LESS THAN 1% OF THE POPULATION WOULD RESULT IN A FINE. HOWEVER, WASHINGTON HAS A UNIQUE POLICY ON THIS ISSUE. THE POLICY REQUIRED THAT IF THERE FIVE OR MORE PRODUCERS THAT FAILED TO MEET THE LICENSING REQUIREMENTS, THAT THE MATTER WAS ESCALATED WITHIN THE DEPARTMENT FOR FURTHER REVIEW. WHEN THAT OCCURS A FINE LIKELY RESULTS. THIS WAS BORNE OUT IN OTHER EXAM RESULTS FROM THE SAME SURVEY. NATIONWIDE, BRIGHTHOUSE, AND LINCOLN ALL HAD SIMILAR FINES FOR SIMILAR VIOLATIONS (6, 9, AND 15 FINANCIAL PROFESSIONALS RESPECTIVELY). IT IS UNCLEAR IF ERROR RATES ARE TREATED DIFFERENTLY IN TARGETED SURVEYS THAN EXAMINATIONS. Status: Final Sanction Detail: IN ITS FINAL CONSENT ORDER, WASHINGTON NOTED ONE FINDING WITH FIVE TOTAL EXCEPTIONS AND ASSESSED A FINE OF $10,000, BASED ON THE EXCEPTIONS AND THE 87 ANNUITY CONTRACTS JACKSON ACCEPTED FROM THE FINANCIAL PROFESSIONALS. Summary: IN ITS FINAL CONSENT ORDER, WASHINGTON NOTED ONE FINDING WITH FIVE TOTAL EXCEPTIONS AND ASSESSED A FINE OF $10,000, BASED ON THE EXCEPTIONS AND THE 87 ANNUITY CONTRACTS JACKSON ACCEPTED FROM THE FINANCIAL PROFESSIONALS.

Allegations: POLICY HAD AN UNCLAIMED PROPERTY FILING AMOUNT OF $56,957.32. FILINGS ARE DONE ONCE A YEAR. THE FILING SHOULD HAVE BEEN COMPLETED IN APRIL 2019 BUT WAS INSTEAD FILED IN APRIL 2021. JACKSON WAS NOTIFIED ON 5/12/21 VIA EMAIL THAT THE LATE FILING WOULD RESULT IN A PENALTY. NV INITIALLY CHARGED A PENALTY OF $5,000 (MAX AMOUNT) + $20,279.93 WORTH OF INTEREST (18% ON $56,957.32 FOR 722 DAYS - 4/30/2019 TO 4/22/2021). NV HAS MOVED THE PENALTY DOWN TO $2,500 AND KEPT THE INTEREST THE SAME AT $20,279.93 FOR A REVISED TOTAL OF $22,779.93. Status: Final Sanction Detail: JACKSON IS REQUIRED TO REPORT UNCLAIMED PROPERTY ON AN ANNUAL BASIS WITH THE STATE OF NEVADA. JACKSON FAILED TO TIMELY REPORT A PIECE OF UNCLAIMED PROPERTY, WHICH RESULTED IN A $22,779.93 PENALTY. Summary: JACKSON IS REQUIRED TO REPORT UNCLAIMED PROPERTY ON AN ANNUAL BASIS WITH THE STATE OF NEVADA. JACKSON FAILED TO TIMELY REPORT A PIECE OF UNCLAIMED PROPERTY, WHICH RESULTED IN A $22,779.93 PENALTY.

Allegations: THE EXAMINATION REPORT STATES THAT THE COMPANY FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH STATUTORY REQUIREMENTS, RESULTING IN THE INSTANCE OF: A.ONE (1) PRODUCER ACTING AS AGENT OF RESPONDENT WITHOUT REQUIRED APPOINTMENT. Status: Final Sanction Detail: JACKSON AGREED TO PAY A $1,500 FINE FOR THE VIOLATIONS NOTED. THE PROCESS FOR UPDATING PRODUCER APPOINTMENTS IS MANUAL. OPERATIONS IS CURRENTLY WORKING TO AUTOMATE THE PROCESS WITH SOFTWARE UPDATES. A TENTATIVE IMPLEMENTATION IS SLATED FOR 4TH QUARTER 2021. PREVIOUSLY A FULL STATE REVIEW OF ALL APPOINTMENTS WAS COMPLETED ON AN ANNUAL BASIS TO CONFIRM ACCURACY. THE REVIEW SCHEDULE HAS BEEN AMENDED TO OCCUR QUARTERLY UNTIL THE AUTOMATION PROCESS IS COMPLETE. Summary: JACKSON AGREED TO PAY A $1,500 FINE FOR THE VIOLATIONS NOTED. THE PROCESS FOR UPDATING PRODUCER APPOINTMENTS IS MANUAL. OPERATIONS IS CURRENTLY WORKING TO AUTOMATE THE PROCESS WITH SOFTWARE UPDATES. A TENTATIVE IMPLEMENTATION IS SLATED FOR 4TH QUARTER 2021. PREVIOUSLY A FULL STATE REVIEW OF ALL APPOINTMENTS WAS COMPLETED ON AN ANNUAL BASIS TO CONFIRM ACCURACY. THE REVIEW SCHEDULE HAS BEEN AMENDED TO OCCUR QUARTERLY UNTIL THE AUTOMATION PROCESS IS COMPLETE.

Allegations: THERE WERE 5 FINDINGS AS PART OF THIS INVESTIGATION: FINDING 1 - FAILURE TO TIMELY CHANGE THE POLICY OWNERSHIP ACCORDING TO THE AGE OF MAJORITY (AOM) PROVISION OF THE POLICY. FINDING 2 - INDIVIDUALS OTHER THAN THE POLICY OWNERS WERE ALLOWED TO TAKE ACTION AGAINST THE POLICY SUCH AS CEASE PREMIUM PAYMENTS, WITHDRAW CASH VALUE, AND/OR SURRENDER THE CONTRACT WITHOUT NOTIFICATION TO THE POLICY OWNER PROVIDED FOR IN THE POLICY. FINDING 3: FAILURE TO PROVIDE ANNUAL STATEMENTS OR NOTICES FOR WHOLE LIFE POLICIES WHERE THE POLICY WAS IN A GRACE PERIOD, OR WHEN THE POLICY HAD CONVERTED TO REDUCED PAID-UP INSURANCE DUE TO UNPAID PREMIUMS OR POLICY LOANS. FINDING 4: FAILURE TO MAINTAIN RECORDS IN A MANNER THAT FACILITATES ADMINISTRATION OF ITS POLICIES IN ACCORDANCE WITH THE POLICY TERMS. FINDING 5: FAILURE TO SEND TIMELY GRACE PERIOD NOTICE AND LAPSE NOTICE. Status: Final Sanction Detail: MONETARY/FINE - $44,000.00 - PAID 4TH QUARTER 2022 Summary: THE INVESTIGATION OF THE JACKSON CONTRACTS REVIEWED RESULTED IN FIVE FINDINGS AND 10 REMEDIAL ACTIONS.

Allegations: VALLEY FORGE LIFE INSURANCE COMPANY (VFL) WAS ABLE TO COMPLETE THIS EXAM WITHOUT ANY FINES ISSUED AGAINST IT, BUT THE CAYMAN ISLANDS MONETARY AUTHORITY ("CIMA") DID ISSUE EXTENSIVE FINDINGS AGAINST JACKSON. THESE FINDINGS CAN ESSENTIALLY BE BROKEN DOWN INTO THREE CATEGORIES: (1) DEFICIENCIES IN VFL'S CORPORATE GOVERNANCE, (2) DEFICIENCIES RELATED TO VFL'S ANTI-MONEY LAUNDERING POLICIES AND PROCEDURES, AND (3) DEFICIENCIES RELATED TO THE INFORMATION THAT CIMA REQUIRES VFL TO COLLECT ON ITS CUSTOMERS ON AN ONGOING BASIS. Status: Final Sanction Detail: N/A Summary: THE FINDINGS THAT WERE MADE ESSENTIALLY FALL INTO THREE CATEGORIES: (1) DEFICIENCIES WITHIN VFL'S CORPORATE GOVERNANCE, (2) DEFICIENCIES WITHIN VFL'S AML POLICIES AND PROCEDURES, AND (3) DEFICIENCIES WITHIN VFL'S ONGOING CUSTOMER DUE DILIGENCE.

Allegations: THE INVESTIGATION OF THE JACKSON CONTRACTS REVIEWED RESULTED IN THREE FINDINGS AND FIVE REMEDIAL ACTIONS. A MONETARY PENALTY OF $1,500 WAS ALSO ASSESSED. JACKSON MUST FILE DOCUMENTATION WITH THE DIVISION WITHIN 90 DAYS OF THE ENTRY OF AN ORDER OF ANY REMEDIAL ACTION TAKEN OR TO DOCUMENT THE PAYMENT OF RESTITUTION REQUIRED BY THE STIPULATION. Status: Final Sanction Detail: MONETARY/FINE - $1,500.00 - PAID 4TH QUARTER 2022 Summary: JACKSON MUST FILE DOCUMENTATION WITH THE DIVISION WITHIN 90 DAYS OF THE ENTRY OF AN ORDER OF ANY REMEDIAL ACTION TAKEN OR TO DOCUMENT THE PAYMENT OF RESTITUTION REQUIRED BY THE STIPULATION.

Allegations: THE FINDINGS AGAINST JACKSON WERE DISTRIBUTED ACROSS THREE CATEGORIES: (1) THE REQUIREMENT TO MAIL DELAWARE PRODUCERS NOTIFICATION OF TERMINATION OF THEIR APPOINTMENT, (2) COLLECTING SIGNED PAPERWORK IN REPLACEMENT TRANSACTIONS, AND (3) TIMELY RESPONDING TO LIFE INSURANCE CLAIMS. Status: Final Sanction Detail: MONETARY/FINE - $35,000.00 - PAID 4TH QUARTER 2022 Summary: A NUMBER OF ITEMS WERE TESTED DURING THIS COMPREHENSIVE EXAM AND THE MAJORITY OF THE TESTING DETECTED NO REGULATORY VIOLATIONS. EXCEPTIONS THAT WERE NOTED WERE LIMITED IN SCOPE AND VOLUME. AND GENERALLY RELATED TO TERMINATION NOTIFICATIONS, CLAIMS HANDLING AND APPLICATION GOOD ORDER REQUIREMENTS. BECAUSE THE FINDINGS WERE RELATIVELY LIMITED, REMEDIATION FOR MANY OF THE FINDINGS IS UNDERWAY.