Jefferies Credit Management Llc

Allegations: HUD'S MORTGAGE REVIEW BOARD ISSUED A NOTICE OF VIOLATION AND A NOTICE OF INTENT TO SEEK CIVIL MONEY PENALTIES INFORMING MASSMUTUALOF HUD'S INTENT TO TAKE AN ADMINISTRATIVE ACTION OR IMPOSE CIVIL MONEY PENALTIES PURSUANT TO 12 U.S.C. § 1708 AND 1735F-14, AND 24 C.F.R.PARTS 25 AND 30, ON THE BASIS OF MASSMUTUAL'S FAILURE TO COMPLY WITH HUD-FHA'S ANNUAL CERTIFICATION REQUIREMENTS WITH RESPECT TOFISCAL YEAR ENDING DECEMBER 2012. Status: Final Sanction Detail: MASSMUTUAL HAS SINCE SUBMITTED THE REQUIRED DOCUMENTATION AND PAID A $7,500 CIVIL MONETARY PENALTY. THE MORTGAGE REVIEW BOARDHAS RESCINDED THE NOTICE OF ADMINISTRATIVE ACTION AND REINSTATED MASSMUTUAL AS AN APPROVED TITLE II MORTGAGEE. Summary: MASSMUTUAL HAS SINCE SUBMITTED THE REQUIRED DOCUMENTATION AND PAID A $7,500 CIVIL MONETARY PENALTY. THE MORTGAGE REVIEW BOARD HASRESCINDED THE NOTICE OF ADMINISTRATIVE ACTION AND REINSTATED MASSMUTUAL AS AN APPROVED TITLE II MORTGAGEE. ON NOVEMBER 17, 2014, ANADMINISTRATIVE LAW JUDGE WITH HUD'S OFFICE OF HEARINGS AND APPEALS DISMISSED THE MATTER, WITH PREJUDICE.

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("DFS") COMMENCED AN INVESTIGATION FOR THE PERIOD OF 1/1/2012-5/31/2018. DURING ITSINVESTIGATION, DFS IDENTIFIED A PRACTICE ARISING FROM THE REPLACEMENT OF DEFERRED ANNUITY CONTRACTS WITH IMMEDIATE INCOME ANNUITYCONTRACTS IN VIOLATION OF THE DISCLOSURE AND SUITABILITY REQUIREMENTS OF NEW YORK REGULATIONS 60 AND 187. IT WAS ALLEGED THATMASSMUTUAL SOLD OR ISSUED 692 REPLACEMENT CONTRACTS TO CONSUMERS WITHOUT REASONABLE BASES TO BELIEVE THE ANNUITIES AT ISSUE WERESUITABLE IN SOME INSTANCES, AND WITHOUT PROVIDING CONSUMERS WITH THE REQUIRED ANNUITIZATION INFORMATION FOR REPLACED DEFERREDANNUITIES. IT WAS ALSO ALLEGED THAT MASSMUTUAL DID NOT ESTABLISH A SUPERVISORY SYSTEM DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 187 INCONNECTION WITH THE DEFERRED -TO-IMMEDIATE REPLACEMENTS AT ISSUE. Status: Final Sanction Detail: MASSMUTUAL AND DFS AGREED UPON RESTITUTION AND REMEDIATION FOR THE AFFECTED CONTRACT HOLDERS OF THE REPLACEMENT CONTRACTS,AND WITHIN 30 DAYS, ALL AFFECTED CONTRACT HOLDERS OR BENEFICIARIES WILL BE PROVIDED WITH NOTICES AND CHECKS OR OTHER PAYMENTMEANS APPROVED BY THE DES IN THE REQUIRED AMOUNTS. MASSMUTUAL WILL PROVIDE THE DES QUARTERLY REPORTS DETAILING THE NUMBER OFCHECKS MAILED, TOTAL AMOUNT OR INDIVIDUAL CHECKS AND THE NUMBER OF CHECKS DEPOSITED, UNDELIVERED AND OR NOT DEPOSITED. Summary: MASSMUTUAL AGREED TO PAY A CIVIL MONETARY FINE IN THE AMOUNT OF $692,000. MASSMUTUAL AND DFS AGREED UPON RESTITUTION ANDREMEDIATION FOR THE AFFECTED CONTRACT HOLDERS OF THE REPLACEMENT CONTRACTS. WITHIN 30 DAYS, ALL AFFECTED CONTRACT HOLDERS ORBENEFICIARIES WILL BE PROVIDED WITH NOTICES AND CHECKS OR OTHER PAYMENT MEANS APPROVED BY THE DES IN THE REQUIRED AMOUNTS.MASSMUTUAL WILL PROVIDE DES QUARTERLY REPORTS DETAILING THE NUMBER OF CHECKS MAILED, TOTAL AMOUNT OR INDIVIDUAL CHECKS, AND THENUMBER OF CHECKS DEPOSITED, UNDELIVERED, AND/OR NOT DEPOSITED.

Allegations: THE STATE OF CONNECTICUT, INSURANCE DEPARTMENT ALLEGED THAT MASSMUTUAL VIOLATED SUBSECTIONS 38A-15 AND 38A-702M OF THE CONNECTICUTGENERAL STATUTES. Status: Final Sanction Detail: MASSMUTUAL AGREED TO PROVIDE THE DEPARTMENT WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN THEMARKET CONDUCT REPORT WITHIN 90 DAYS AND MASSMUTUAL AGREED TO PAY A FINE IN THE AMOUNT OF $61,000. Summary: MASSMUTUAL AGREED TO PROVIDE THE DEPARTMENT WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN THE MARKETCONDUCT REPORT WITHIN 90 DAYS AND MASSMUTUAL AGREED TO PAY A FINE IN THE AMOUNT OF $61,000.

Allegations: THE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD OF JANUARY 1, 2007 THROUGH NOVEMBER 30, 2009, FINDING THATMASSMUTUAL, C.M. LIFE, AND MML BAY STATE VIOLATED REGULATIONS RSA 408:29; RSA 409-A:5, INS 401.12, AND RSA 417:4I(H) CONCERNING CONTRACTANNUITIZATION AT MATURITY PROCEDURES AND PROCESS. Status: Final Sanction Detail: MASSMUTUAL WAS ORDERED TO SUBMIT A PROPOSED CORRECTIVE PLAN OF ACTION WITH RESPECT TO POLICIES AND PROCEDURES FOR FORECEDANNUITIZATION AT MATURITY AND A PROPOSED RESTITUTION PLAN FOR ANY LOSSES SUSTAINED BY CONSUMERS RELATED TO THE FINDINGS OF THEMARKET CONDUCT EXAMINATION REPORT. Summary: THE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD OF JANUARY 1, 2007 THROUGH NOVEMBER 30, 2009, FINDING THATMASSMUTUAL, C.M. LIFE, AND MML BAY STATE VIOLATED REGULATIONS RSA 408:29; RSA 409-A:5, INS 401.12, AND RSA 417:4I(H) CONCERNING CONTRACTANNUITIZATION AT MATURITY PROCEDURESAND PROCESS. MASSMUTUAL, C.M. LIFE, AND MML BAY STATE WERE ORDERED TO SUBMIT A PROPOSEDCORRECTIVE PLAN OF ACTION WITH RESPECT TO POLICIES AND PROCEDURES FOR FORECED ANNUITIZATION AT MATURITY AND A PROPOSED RESTITUTIONPLAN FOR ANY LOSSES SUSTAINED BY CONSUMERS RELATED TO THE FINDINGS OF THE MARKET CONDUCT EXAMINATION REPORT.

Allegations: ON MARCH 17, 2022, THE COMMISSIONER OF PUERTO RICO ISSUED AN ORDER AGAINST MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY STATING THATTHE FIRM HAD VIOLATED ARTICLES 11.230 AND 27.160 OF THE PUERTO INSURANCE CODE, 26 LPRA SECTIONS 1123 AND 2716 FOR WHICH ANADMINISTRATIVE FINE OF $3,000 WAS IMPOSED. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY WAS ORDERED TO RESCIND THE POLICY IN DISPUTEAND RETURN TO THE APPLICANT (COMPLAINANT) THE AMOUNT OF $65,000, CORRESPONDING TO THE UNDULY COLLECTED PREMIUM. MASSACHUSETTSMUTUAL LIFE INSURANCE COMPANY WAS ORDERED TO CEASE AND DESIST FROM THE PRACTICES DESCRIBED IN THE ORDER. Status: Final Sanction Detail: GIVEN THE ACCEPTANCE AND COMMITMENT OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY TO TAKE THE NECESSARY MEASURES TO AVOIDSIMILAR MATTERS IN THE FUTURE, THE COMMISSIONER OF INSURANCE OF PUERTO RICO AGREED TO MODIFY THE ADMINISTRATIVE FINE TO $1,500. Summary: MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY DID NOT INTEND TO FAIL TO COMPLY WITH THE PROVISIONS OF ARTICLES 11,230 AND 27, 160 OF THEPUERTO RICO INSURANCE CODE, SUPRA, AND THE FACTS INDICATED IN THE ORDER AROSE AS AN EXCEPTIONAL SITUATION THAT DOES NOT CONSTITUTETHE NORMAL OR INTERNAL POLICY OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY'S INSURANCE BUSINESS. MASSACHUSETTS MUTUAL LIFEINSURANCE COMPANY ALLEGED THAT THE FACTS OF THE ORDER WERE THE RESULT OF ACTIONS AND/OR OMISSIONS OF PARTIES INVOLVED IN THE ORDERWHICH ENDED IN A MISUNDERSTANDING. GIVEN THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY ACCEPTED AND COMMITTED TO TAKE THENECESSARY MEASURES TO AVOID SIMILAR SITUATIONS IN THE FUTURE, THE COMMISSIONER OF INSURANCE OF PUERTO RICO AGREED TO MODIFY THEADMINISTRATIVE FINE TO $1,500. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY PROCEEDED TO RESCIND THE POLICY THAT WAS SUBJECT OF THECONTROVERSY AND TO REIMBURSE THE APPLICANT (COMPLAINANT) THE SUM OF $65,000, AS PROVIDED IN THE ORDER.