Ppm Loan Management Company 2, Llc

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: 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: 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: 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.