Pacific Private Fund Advisors Llc

Allegations: PACIFIC LIFE INSURANCE COMPANY CITED BY MARYLAND INSURANCE ADMINISTRATION FOR ALLEGEDLY NOT BEINGIN COMPLIANCE WITH CERTAIN SECTIONS OF THE MARYLAND INSURANCE STATUTES AND ADMINISTRATIVE CODE. Status: Final Sanction Detail: CORRECTION OF CITED VIOLATIONS AND TAKE MEASURES TO ENSURE THE SAME DO NOT OCCUR IN THEFUTURE. Summary: PACIFIC LIFE PAID THE $9,000 PENALTY ON DECEMBER 4, 2017 AND AGREED TO CORRECT CITED VIOLATIONS WITHIN90 DAYS OF THE DATE OF THE ORDER AND TAKE SUCH MEASURES TO ENSURE THE SAME DO NOT OCCUR IN THEFUTURE.

Allegations: PACIFIC LIFE & ANNUITY COMPANY WAS NOT IN COMPLIANCE WITH CERTAIN SECTIONS OF THE NEW YORK REGULATIONSON DISCLOSURE AND SUITABILITY REQUIREMENTS REGARDING THE REPLACEMENT OF DEFERRED ANNUITY CONTRACTSWITH IMMEDIATE ANNUITY CONTRACTS. Status: Final Sanction Detail: PACIFIC LIFE & ANNUITY COMPLETED PAYMENT OF THE FINE AND RESTITUTION AS OF APRIL 15, 2020. Summary: PACIFIC LIFE & ANNUITY COMPLETED PAYMENT OF THE FINE AND RESTITUTION AS OF MARCH 10, 2020.

Allegations: ON NOVEMBER 13, 2023, PACIFIC LIFE INSURANCE COMPANY ("PLIC") RECEIVED AN ORDER OF CIVILPENALTY AND THE ADOPTION OF A CORRECTIVE ACTION PLAN RELATED TO ITS BUSINESS OF INSURANCEFROM THE MINNESOTA DEPARTMENT OF COMMERCE ("MDC") FOR ALLEGED VIOLATIONS OF MINNESOTAINSURANCE STATUTES. THE ORDER ALLEGED THAT PLIC, EITHER DIRECTLY OR THROUGH ITS INSURANCEPRODUCERS, DID NOT HAVE REASONABLE GROUNDS FOR BELIEVING, IN SOME INSTANCES, THATRECOMMENDATIONS MADE TO APPLICANTS FOR LIFE INSURANCE, LONG-TERM CARE INSURANCE, ANDANNUITY CONTRACTS WERE SUITABLE, INCLUDING FOLLOWING SUITABLE GUIDELINES, TAKINGAPPROPRIATE ACTION FOR NONCOMPLIANCE BY SOME INSURANCE PRODUCERS, ENSURING THE POLICYAND ANY RIDERS MET THE CONSUMER'S FINANCIAL GOALS, AND CONSIDERING RIDER FEES AND THELOSS OF OTHER BENEFITS WHEN RECOMMENDING THE REPLACEMENT OF AN EXISTING POLICY. THEORDER ALSO ALLEGED THAT PLIC DID NOT ADEQUATELY MAINTAIN A SYSTEM OF SUPERVISION TOENSURE THAT THERE WERE REASONABLE GROUNDS FOR BELIEVING THAT RECOMMENDATIONS MADE TOAPPLICANTS FOR LIFE INSURANCE, LONG-TERM CARE INSURANCE, AND ANNUITY CONTRACTS WERESUITABLE, AND THAT PLIC ALLEGEDLY DID NOT HAVE ADEQUATE POLICIES AND PROCEDURES FOR THEEFFECTIVE SUPERVISION AND MONITORING OF ITS INSURANCE PRODUCERS THAT AS A RESULT, PLIC MAYHAVE ISSUED SOME UNSUITABLE LIFE INSURANCE, LONG-TERM CARE INSURANCE, AND ANNUITYCONTRACTS. Status: Final Sanction Detail: IN ADDITION TO THE MONETARY FINE OF $250,000, PLIC AGREED TO IMPLEMENT A CORRECTIVEACTION PLAN ("CAP") DESIGNED TO IMPROVE PLIC'S BUSINESS PRACTICES AND UPDATE POLICIESAND PROCEDURES IN A MANNER SATISFACTORY TO MDC AND TO ENSURE COMPLIANCE WITHCONTRACTUAL DUTIES AND MINNESOTA INSURANCE STATUTES. THE CAP REQUIRES PLIC TOUPDATE THE MDC ON IMPLEMENTATION OF THE CAP WHICH INCLUDES ENSURING BROKER/DEALERSHAVE SUITABILITY SUPERVISION, AND THAT PLIC WILL PERFORM QUARTERLY AUDITS, CONDUCTTRAINING OF ITS INSURANCE PRODUCERS AND SALES PERSONNEL AND WILL MAINTAINAPPROPRIATE BOOKS AND RECORDS. THE MDC AND PLIC AGREE THAT THE MDC WILL MONITORPLIC'S IMPLEMENTATION OF THE CAP UNTIL DECEMBER 25, 2024. Summary: MONETARY FINE: $250,000. THE NOVEMBER 13, 2023 CONSENT AGREEMENT AND CONCURRENTLYEXECUTED CORRECTIVE ACTION PLAN RESOLVES THE ALLEGATIONS AGAINST PLIC AND WAS ENTEREDINTO WITHOUT ADJUDICATION OF ANY ISSUE, LAW OR FACT.

Allegations: STARTING IN 2019, PACIFIC LIFE INSURANCE COMPANY (PLIC) HAS BEEN THE SUBJECT OF AN INVESTIGATION BY THE NEW YORK DEPARTMENT OF FINANCIAL SERVICES (NYDFS) RELATED TO CONDUCTING PENSION RISK-TRANSFER (PRT) BUSINESS WITHIN THE STATE. THE NYDFS CONSIDERS IN-PERSON MEETINGS IN NEW YORK AND ANY COMMUNICATION (INCLUDING EMAIL AND PHONE CALLS) FROM A NEW YORK LOCATION OR TO ANYONE IN NEW YORK, AS DOING BUSINESS IN THE STATE. PACIFIC LIFE & ANNUITY, AND NOT PLIC, IS LICENSED TO DO INSURANCE BUSINESS IN THE STATE OF NEW YORK. IT WAS CONCLUDED DURING THE INVESTIGATION THAT PLIC HAD CONDUCTED PRT BUSINESS IN BREACH OF NYDFS COMMUNICATIONS GUIDELINES. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN 2020, PLIC BEGAN USING A TWO-GROUP ANNUITY CONTRACT (GAC) STRUCTURE WHERE PACIFIC LIFE & ANNUITY COMPANY (PL&A) WOULD ISSUE A GAC FOR ANY NEW YORK RESIDENTS, AND ALL EMPLOYEES WHO ARE SELLING OR SOLICITING PRT GACS IN NEW YORK HAVE BEEN LICENSED AND APPOINTED AS AGENTS BY PL&A. THE COMPANY IS EXECUTING A PLAN, APPROVED BY THE NYDFS, TO TRANSITION NEW YORK RESIDENTS WITH PLIC CERTIFICATES TO PL&A CONTRACTS. THE COMPANY WILL SUBMIT ANNUAL AFFIDAVITS OF COMPLIANCE WITH THE TERMS OF THE CONSENT ORDER FOR A PERIOD OF THREE YEARS.

Allegations: PACIFIC LIFE INSURANCE COMPANY WAS CITED BY THE CALIFORNIA DEPARTMENT OF INSURANCE FOR ALLEGEDLYNOT BEING IN COMPLIANCE WITH CERTAIN SECTIONS OF THE CALIFORNIA INSURANCE CODE AND CODE OFREGULATIONS Status: Final Sanction Detail: PACIFIC LIFE MUST IMPLEMENT AND COMPLY WITH THE CORRECTIVE ACTION AND COMPLIANCE PLAN ASPROVIDED BY PACIFIC LIFE THAT RESOLVES ALL MATTERS CITED BY THE CALIFORNIA DEPARTMENT OFINSURANCE IN THEIR NOTICE OF NONCOMPLIANCE. Summary: PACIFIC LIFE PAID THE $10,000 PENALTY ON AUGUST 30, 2019 AND AGREED TO IMPLEMENT THE CORRECTIVE ACTION AND COMPLIANCE PLAN AS PROVIDED.

Allegations: PACIFIC LIFE INSURANCE COMPANY PAID A $14,000 ADMINISTRATIVE PENALTY TO THE ILLINOIS DEPARTMENT OF INSURANCE AND AGREED TO CORRECT PROCESSES TO RESOLVE ALLEGED VIOLATIONS OF CERTAIN SECTIONS OF THE ILLINOIS INSURANCE CODE AND DEPARTMENT REGULATIONS REGARDING A FAILURE TO PROVIDE INSUREDS WITH A "NOTICE OF AVAILABILITY OF THE DEPARTMENT OF INSURANCE" ON DENIED CLAIMS, AND FOR USING A POLICY FORM THAT DOES NOT MEET THE 24 MONTH DEFINITION OF TERMINAL ILLNESS. Status: Final Sanction Detail: IN ADDITION TO AN ADMINISTRATIVE PENALTY OF $14,000, PACIFIC LIFE WAS ORDERED TO INSTITUTE AND MAINTAIN PROCEDURES TO COMPLY WITH PROVIDING "NOTICE OF AVAILABILITY OF THE DEPARTMENT OF INSURANCE" ON DENIED CLAIMS, AND TO DISCONTINUE A POLICY FORM THAT DOES NOT MEET THE 24 MONTH DEFINITION OF TERMINAL ILLNESS. Summary: PACIFIC LIFE INSURANCE COMPANY PAID THE $14,000 ON JUNE 8, 2013 AND PACIFIC LIFE INSURANCE COMPANY PROVIDED PROOF OF COMPLIANCE WITH THE ORDER WITHIN 30 DAYS OF THE DATE OF THE ORDER.

Allegations: PACIFIC LIFE INSURANCE COMPANY PAID A $7,500 ADMINISTRATIVE PENALTY PLUS $3,000 IN ADMINISTRATIVE COSTS TO THE FLORIDA OFFICE OF INSURANCE REGULATION TO RESOLVE ALLEGED VIOLATIONS OF CERTAIN SECTIONS OF THE FLORIDA INSURANCE CODE REGARDING A REFUSAL OF LIFE INSURANCE BASED SOLELY ON THE INDIVIDUAL'S PAST OR FUTURE LAWFUL FOREIGN TRAVEL PLANS. Status: Final Sanction Detail: IN ADDITION TO AN ADMINISTRATIVE PENALTY AND FEES OF $10,500, PACIFIC LIFE WAS ORDERED TO PROVIDE A SIGNED OFFICER CERTIFICATION THAT CORRECTIVE ACTION HAS BEEN COMPLETED AND THAT IT HAS REVIEWED ITS INTERNAL POLICIES TO AVOID FUTURE VIOLATIONS OF THE STATUTE. Summary: PACIFIC LIFE INSURANCE COMPANY PAID THE $10,500 ON JULY 12, 2012 AND SUBMITTED THE REQUESTED CERTIFICATION WITHIN 30 DAYS OF THE DATE OF THE ORDER.

Allegations: PACIFIC LIFE INSURANCE COMPANY ("PLIC") WAS CITED BY THE ILLINOIS DEPARTMENT OF INSURANCE FOR ALLEGEDLY NOT BEING IN COMPLIANCE WITH CERTAIN SECTIONS OF THE ILLINOIS INSURANCE CODE AND DEPARTMENT REGULATIONS ON DISCLOSURE, WHICH RESULTED IN THE NEED TO UPDATE POLICIES AND PROCEDURES ASSOCIATED WITH THE ISSUING OF NEW AND AMENDED LIFE INSURANCE POLICIES, SPECIFICALLY PERTAINING TO CONSUMER DISCLOSURES, REPLACEMENT INFORMATION, NOTICES AND TIMING THEREOF. THE PROOF OF COMPLIANCE WAS SUBMITTED TO THE ILLINOIS DEPARTMENT OF INSURANCE ON MAY 27, 2022 AND WAS APPROVED ON JUNE 1, 2022. Status: Final Sanction Detail: AN ADMINISTRATIVE FEE OF $37,000 PAID ON MAY 4, 2022 Summary: PLIC PAID THE $37,000 ON MAY 4, 2022 AND AGREED TO IMPLEMENT THE CORRECTIVE ACTIONS. PROOF OF COMPLIANCE WITH THE ORDER WAS SUBMITTED WITHIN 30 DAYS OF THE DATE OF THE ORDER AS REQUIRED.