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CHRISTOPHER S. PORRINOATTORNEY GENERAL OF NEW JERSEYRichard J. Hughes Justice Complex25 Market StreetP.O. Box 117Trenton, New Jersey 08625Attorney for Petitioner,Commissioner of the Departmentof Banking and InsuranceB y: " . r a Q17William B. Puskas, Jr.Deputy Attorney General( 609) 6Attorney ID:9SUPERIOR COURT OF NEW JERSEYCHANCERY DIVISION-MERCER COUNTYDOCKET NO. MER-CRICHARD J. BADOLATO,COMMISSIONER OF THEDEPARTMENT OF BANKING ANDINSURANCE OF NEW JERSEY,))))Plaintiff,)Civil Actionv.)I FA INSURANCE COMPANY,)CERTIFICATION OF STEVENP. KERNER, JR.)Defendant.STEVENP.KERNER,JR.,of fullage,herebycertifiesa nd says:1.Iam theAssistant Commissioner inthe Office ofSolvency Regulation for the New Jersey Department of Banking andI nsurance('theDepartment")Myresponsibilitiesinclude

ionentities transacting business in NewallofJersey.I makethis certification in support of the Commissioner's applicationto place IFA Insurance Company ( IFA") into liquidation.2.IFA is a New Jersey property and casualty insurerlicensed to transact insurance business in New ichmaintains its officeat the samealsoauthorizedautomobileisFinancial Agents,insurancewholly-ownedaInc.,andauthorizedIFA wasbusinesssubsidiarylocation as usinessin,privatePennsylvania,Maryland and 5.TheDepartment andIFA enteredinto aMemorandumof Understanding ("MOU") on September 4, 2014, based on tionofIFA.These concerns included IFA's failure to maintain adequate lossand loss adjustment expense reserves; IFA's financial condition;and IFA's ability to meet its policyholder obligations.- 2 -The MOU

lleviate the Department's concerns.6.The Department and IFA subsequently entered into aConsent Order No. C15-101, dated July 10, 2015, under which theDepartment approved IFA's withdrawal from the New Jersey privatepassengerprovidedautomobilethatIFAinsurance market.ceasewritingnewTheConsent Order alsobusinessinNewJersey,transfer certain business to another insurer, and non-renew anyexisting business not accepted by the insurer.7.byDespite these efforts and the continued inancialIFA2016.conditionfailedtocontinuedmeet itstobenchmarkrequirements for several financial analysis ratios and sufferedsignificant declines in net income and rderly run-off of IFA and its insurance business, on strative17:51A-1 to ndN.J.S.A.A true copy of the Confidential Consent Orderof Administrative Supervision ("Administrative Supervision .lThe1 The Commissioner has determined that it is in the best interestof the public to make the administrative supervision order- 3 -

monitoringb y the Department; maintaining an Risk-Based Capital ratio at fraintoinitstheas foranalysis;anynewSupervisionliquidationrun-off ofifitandbusiness.IFACO,failedtomaintain sufficient reserves and capital in IFA to keep its RBCat or above 1.000 during the run-off.9.Despite the active administrative supervision andmonitoring by the Department and as discussed more fully below,IFA reported to the Department in February 2017 that it was notgoing to be able to maintain sufficient reserves and capital inIFA tokeep its RBC at solventthat additionalrun-offwerehighlyFurthermore, IFA advised that its cash position as ofFebruary 15,hadtoabove 1000 RBC, and2017,cashonhaddeteriorated such that the company onlyhandof 254,830,offor 323,985atotalandoftotalpotential 578,815incashavailableassets.public pursuant to N.J.S.A. 17:51A-4d, and IFA has consented tomaking public the MOU, the Administrative Supervision CO, and anAmended Consent Order of Administrative Supervision No. A17-106in the Amended Consent Order, a true copy of which is attachedhereto as "Exhibit C".- 4 -

On10.21,February2017,theDepartmentissuedaletter to IFA finding by the Commissioner that it is in N.J.A.C.take11:2-Attached hereto as "Exhibit B" is a true and exact copyof this achedhereto as "Exhibit C" is a true and exact copy of this nisbreach of the Administrative Supervision CO by not maintaining rsuant to N.J.A.C. 11:2-39.7, IFA's RBC places the company vent,thusrequiringtheactions necessary to cause the insurer tobe placed under regulatory control pursuant to N.J.S.A. etseq.Moreover, IFA consented to its placement into liquidation.12.providesthatBecause of its cash position, the Amended CO alsoIFAshallnotmake- 5 -anyexpendituresoffunds-

includingclaimspayments-withoutthepriorapprovalof theDepartment.13.theForall of theseCommissionerfindsdeteriorated, suchIFAwouldbecreditorsthatreasonsIFA'sthat any ,theCommissionerBasedtoonhashasof business byitsthisthat yholders,findingdeterminedbythattheitisnecessary to place IFA into liquidation.IFA IS ovidedtotheliabilities, required reserves and capital stock.15.Department ancialofinformationFebruary 1,481,293;of tedliabilitiesandcapital stock of 2, 494, 035.16.stockexceedinsolventasIFA's liabilities,itsassetsdefinedbybyrequired reserves, and capital 4,568,676.statuteanddeclaration of insolvency.- 6 -theAccordingly,courtshouldIFAenterisa

IFA IS IN A HAZARDOUS FINANCIAL CONDITION17.entitledprovisions LCommissionerinsurerisinahazardous financial sthatshall be considered either singly or in a combination of two financial condition."19.inaA finding by thehazardousfinancialCommissionerconditionthat an insurer isconstitutesgroundsforliquidation under N.J.S.A. 17:30C-8 and N.J.S.A. ommissioner may consider an adverse finding by the onstituteandahazardous financial condition.21.theBased on financial condition reports submitted rand30,surplus2016,wasasregards 661,764,butdecreased to (2,074, 641) as of February 15, er as to IFA's negative surplus, the Commissioner has- 7 -

determined that IFA is in a hazardous financial condition underN. J.A. C.11:2-27.3(a) 1 nprovidesinsurertobethatinathehazardousfinancial condition upon a finding by the Commissioner that tomeet its outstanding obligations as they mature"24.thehandBased on financial condition reports submitted toDepartment, as of February 15, 2017, IFA had total cash onofand 323,985 254,830,forUnderwriting ial eceivableswereassets.expectedtobeoftobe 192,783.Based on IFA's history of under-reserving, it is estimated thatIFA will be out of cash between the end of February 2017 and sinadequate to meet its outstanding obligations as they arding IFA' s asset portfolio, the Commissioner has nderN.J.A.C.11:2-27.3(a) 4.26.N.J.A.C. 11:2-27.3(a)7 permits the Commissioner todetermine an insurer is in a hazardous financial condition upon- g -

a finding by the Commissioner that the insurer's operating lossin the last twelve-month period or any shorter period of time,excluding net capital gains, is greater than 20 percent of sinexcessof the minimum required.Based on financial condition reports submitted to27.theDepartment, as of September 30, 2016, IFA had negative netincome of (l, 957, 036) for the first nine months of 2016 afterreduction for realized capital gains of 601,712.thecapital us, ders of 661,764 as of September 30, g IFA's operating loss, excluding net capital gains, theCommissioner has determined that IFA is in a hazardous financial11:2-27.3(a)7.condition under ssionerhazardousCommissioner- 9 -thethatfinancialtheinsurer

recash flow or liquidity ignificantly deteriorated such that it is expected to run outof cashto easureandfuture.istonowIn dingclaimsbytheapplicable state guaranty funds.32.Based on these findings by the Commissioner as toIFA's cash flow, the Commissioner has determined that IFA is ina hazardous financial condition under financialtheinsurerdoes not possess the minimum capital and surplus required to bemaintained by tominimum capital of 1,400,000 and a minimum surplusof 1, 200,000, for a total of 2, 600,000.35.theBased on financial condition reports submitted toDepartment,asofSeptember30,2016,IFAhadcapitalof 2, 494, 035 and surplus of (1, 832, 271), for a total of 661,764.- 10 -

Thus,IFA' s capital andsurplus is (1, 938, 236) less than theminimum required by law.36. Based on these findings by the Commissioner as toIFA's failure to maintain the minimum capital and surplus, theCommissioner has determined that IFA is in a hazardous financialcondition under N.J.A.C.One37.of11:2-27.3(a)20.theusedtoolsby 'theinDepartmentmonitoring the solvency of insurers is analysis of an insurer'sRisk-Based Capital ("RBC") pursuant to N.J.A.C. 11:2-39.1 to 39.14.tobeRBC analysis can result in various event level osolvency regulation.Based on financial condition reports submitted to38.the Department, the Department has projected IFA's RBC ratio k-Based Capital ratio is a mandatory control level event .7(b)2,theCommissioner is required to take such actions as are .J.S.A.to17:30C-1 et seq.IFA HAS CONSENTED TO BE PLACED INTO LIQUIDATION39. rencedSeptemberin19,20168aboveParagraphwas the requirement that FIFA shall maintain a level of not less- 11 -

than 1.000 ("1000") at all times on or subsequent to [September19,2016].shallAny downward breach of this required level of mpany into liquidation upon such a breach." (Exhibit A, p. 3,9I2 - emphasis added.)40.ratiolessofAs discussed in Paragraph 38 above, IFA has a RBC(730.257)0,thantheas1.000ofFebruary 15,( tain under the September 19, 2016 consensual administrativesupervisionorder.By failingtomaintainaRBCratioof atleast 1.000 ( 1000") and through its entry into the Amended Exhibits B and C hereto.41.itsultimateAdditionally, the Boards of Directors of IFA , Inc., have consented to IFA's liquidation by resolution.Attached hereto as "Exhibits D and E" are true and exact copiesof these resolutions.THE NEED TO PLACE IFA INTO FAinto liquidation pursuant to N.J.S.A. 17:30C-1 et seq. in orderto protect its policyholders, creditors and the public at large.- 12 -

43. Accordingl.yrthe Commissioner has determined t:: tIFA must be placed into liquidation as soon as possible in - rt limit the duration of any claims payment interruptions due toZFA'ssignificantlydeterioratedcashcorporate existence be dissolvedposition,andthatitspursuant to N.J.S.A. 17:30C-9b(1 .certify that t .e forego n sta me:tts made by me aretrue. am aware that if any of the f reg ing stea}ement made byrc:e ire willf ll r fa:.s , I m subje, . to p :waish::ent./ .,., STEVEN P. KER xER, JR.x M Ass s ant C rnmissionerOffice of Solvency ion.,1r ,h rr C7 i.tier . .,.,,1,.,A M yl- Cn i.'4iirw n .yfL v c.


Order No. C'1 G-1 t)iSTATE F NEW JERSEYDEPARTMENT OF BANKING AND INSURANCEIII THE MATTER. C)F THEADMINISTRATIVE SUPERVISIONOF I 'A INSURANCE COMPANY})}CONFIDE 1TiALCONSENT QRDEROF ADMINISTRATIVE SUPERVISIQNThis matter is opened by the Commissioner ("Commissioner") of Banking and Insuranceof the New Jersey Department of Banking and Insurance ("Department"} pursuant to the e ;, 7:4 B-1 et ,s e ,;, and I7:SlA-1 tauthority c mtained in N.J.S. . 17:17-5, 1?:23-23-1 t ,s c,„stec ., and all powers expressed or implied therein.tT APPEARING that 1FA Insurance Company ("IFA" or the "Company"), is a NewJersey domiciled insurer licensed to transact properly and casualty insurance since Qctaber 30,1972; andIT F[. RTHER APPEARING that N.J.S.A. 17:51A-1 t s c , the AdministrativeSupervision Act {the "Act") sets Earth the authority of the Commissioner to subject aI) domesticinsurers Eo administrative supervision; andIT FURTHER APPEARII 1G that the Act overnin administrative supervision applies toIFA since the Company is a New Jersey-domiciled dornest c insurer authorized to txansact thebusiness of property and casualty insurance in New Jersey pursuant to Title 17 of the RevisedStatutes; andIT FURTHER APPEARING that IAA entered into a iV emorandum of Understanding("MOU"} with the Department on September 4, 2014, setting forth various candstions and termsIFA was required to meet or otherwise he subject to administrative supervision; and

IT FURTHER APPEARING that IFA is also subject to the terms of a Consent Order No.C15-10I under which the Department approved its withdrawal from the New Jersey market andthe transfer of certain business to Palisades Safety a.nd Insurance Association and PalisadesInsurance Company ("Palisades"), and required, among other things, that IFA cease writing newbusiness and provided foc the norvenewal of any existing New Hersey business that was notaccepted by Palisades; andIT FURTHER APPEARING that IFA is in breach of the terms of the MOU andotherwise in a financial condition that is hazardous to its policyholders, creditors andlor thepublic, some ofthose breaches and conditions being:(i)As of December 31, 2015, CFA reflected an RBC ratio of0.771;(ii)As of Decerc ber 3I, 20I5, IFA's suxplus of 2.9 million had decreased 826,UQ0,or 22.1% from previous year end; IFA's surplus decreased another 921,000 to 2.0 million at the end of the first quarter of 2016 due to a decline in its NetIncome - 90b,00(}, a change in its Net Unrealized Capital (Losses) of - 18,000,offset by a change in non admitted assets of 3,000. lll IFA's 2015 IRIS ratios reflected unusual and unacceptable values for S of I3ratios, including 2reserve-related ratios;(iv)IFA's ZO I S Leverage Ratios Reserves/Surplus and NPW/Surplus realized valuesacre in excess of their respective benchmarks and this is a Material AdverseFinding;(v)IFA's first quarter 2016 Reserves/Surplus ratio exceeded its respective benchmarkand is a Materiat Adverse Finding;(vi)IFA's RBC ratio at May 31, 20Ib, was 0.399 and at June 30, 2U16, was O.S49,both below Mandatory Control Level RBC which required a capital infusion.

IT FURTHER APFEARING that the Department and IFA wish to facilitate an orderlyrun-offofIFA and its business; andIT FURTHER APPEA,R NG that pursuant to N.J.S.A, I7:S1A-3a(5}, an insurer may besubject tv administrative supervision by the Commissioner if the insurer consents to being placedunder administrative supervision; andIT FiJRTHER APPEARING that, for the reasons set forth above, IFA consents to beplaced under the cvnftdential Administrative Supervision ofthe Commissioner; andIT FURTHER APPEARING that, for the reasons set forth above, the Commissioner is,pursuant to N.J.S.A. 17:S1A-1 et se .placing IFA under administrative superv ion; andIT FURTHER APPEARING that the Act sets forth the authority of the Commissionerregarding domestic insurers to provide appropriate regulatory oversight consistent with hisresponsibilities as regulator in order to protect the interests of IFA, its policyholders,beneficiaries, creditors and/or the public; andIT FURTHER APPEARING that it is appropriate and consistent with the Act to set forthin additional detail the framework for the regulatory oversight ofIFA by the Department;NOVA THEREFORE,upon the consent of the parties,It is on thisay ofSeptember, 2dlb,ORDERED AND AGREED as follows:l. Effective this date, IFA shall be placed under Administrative Supervision pursuant toN.J.S.A. 17:51 A-5,in order to facilitate the orderly run-off ofIFA and its business.2. IFA shall maintain a RBC teve of not less than 1.000 at all times vn or subsequent tothe date of this Consent Order. Any downward breach of this required level of RBCshall constitute immediate grounds to initiate Liquids#ion proceedings pursuant toN.J.S.A. 7:3UC-1 et se ., and IAA hereby consents to placement ofthe company into3

liquidation upon such a breach. The Commissioner, without waiving any rights tocommence Liquidation proceedings, may in his sole discretion permit IFA areasonable period of time, the length of which shall also be in the Commissioner'ssole discretion, in which IFA may seek to remedy its RBC level so as to come intocompliance with this Consent Order.3. IFA shall have semi-annual reserve analyses performed by its opining actuary asindicated in the 11 QU.4. IFA shall continue to refrain from writing any new business.S. Pursuant to N.J.S.A. 17:S1A-5, the Commissioner shall serve as the AdministrativeSupervisor of IFA, until such time as he determines to appoint an AdministrativeSupervisor to facilitate the orderly run-off of the Company. If an AdministrativeSupervisor is appointed by the Commissioner for IFA,such appointed AdministrativeSupervisor shall be compensated by IFA, as determined and approved by theCommissioner. Any such appointed Supervisor shall, among other things, performaudits of the Company's respective operations, ensure compliance with the terms ofthis Consent Order and perform such other acts as the Commissioner deems necessaryto protect the interests of IFA, its policyholders, beneficiaries, creditors and/or #.hepublic. The appointment of an Administrative Supervisor shall not preclude theCommissioner from performing examinations in accordance with the provisions ofN.J.S.A. 17:2320 et sew.and N.J.S.A. 17:27A-5.6. Effective immediately, all payments by CFA, including, but not limited to, checks andwire transfers, shall be reviewed and approved by an officer off'IFA.7. IFA shall be exempt from assessments by the New Jersey Property LiabilityInsurance Guaranty Association pursuant to N.J.S.A. 17:30A-8.

8. Pwsuant to the Commissioner's powers in N.J.S.A. 17:51 A-S(n} and N.J.A.C. 11:227.4 (a)(13), IFA shall also be exempt from paying the following assessments:(a) Automobile Insurance Plan Service Office Assessment;{b) UnsaEisfied Claim and Judgment Fund Assessment;(c) New Jersey Fraud Assessment;(d} New Jersey Expense Motor Vehicle Assessment;(e) New Jersey Special Purpose Assessment(also known as the OverheadAssessment);( New Jersey Personal Automobile Insurance Plan Assessment9. Senior management of IFA shall continue to update the Commissioner or lusrepresentatives monthly, or as frequently as subsequently directed by theCommissioner or representatives (e,g., weekly, bi-weekly, quarterly), with areport containing alb available information concerning the run-off of the existingbusiness of IFA,including, but not limited to:a. Monthly statutory Balance Sheet, Income Statement and Cash Flvw Statementsubmitted on or before the 2U t'day after the end of the month;b. Monthly RBC Report on or before the 20 ' day of the month after the end of themonth;c. Monthly claim and reserve reports by the end of the subsequent month, in a formto be determined by the Commissioner or his representatives;d. Monthly reports with a detail of administrative expenses, including, but nvtlimited to staffing, salaries, benefits, taxes, operational costs, vendor costs, legalcosts, rental casts, supplies and the like;

e. Monthly reinsurance reports with recoverable information, e.g., pending and/orclaims to be made; andf. Quarterly reports of remaining policyholders by state reflecting dates of nonrenewal.10.IFA shall provide, for review and prior approval by the 17epartrnent, a listing of anycontemplated payments in excess of 5,000 at [east one week prior to disbursement, withthe exception of payroll payments, which may be paid an four(4} days prior notice to theDepartment.1 1.All documents and records in the possession of IFA, its agents andlor representativesshall not be moved, removed, transferred modified, amended, disposed of or alteredwithout the approval of the Commissioner, except that documents and records maycontinue to be sent to archives and/or may be modified in a manner consistent with IFA'susual and customary business practices.12.IFA sha11 provide to the Commissioner or his represents#fives access, on demand andwithout advance notice, to arty and all materials, records, documents or information oftheCompany and shall fully and Completely cooperate with alI requests ofthe Commissioneror his representatives for such materials, records or documents or inforntation, includingmeeting any reasonable timeframes established by the Commissioner or hisrepresentatives far the provision of any requested materials, records, documents orinformation. For the purposes of this Consent Order, materials, records, documents orinformation shall include, but not be limited to, those recorded or stored in paper orelectronic form, wherever they may be located.13.IFA shall, within 10 days from the date of this Order, provide the Commrssivner yr hisrepresentatives with the Iocation and description of, and access to, alI assets of any kind

held by, or on behalf of, IFA. For purposes of this order, assets shall inctude #hose itemsowned or leased.14.In accordance with its provisions, IFA shall not, without prior approval of theCommissioner or his representatives, take any action specified in N.J.S.A. 17;51 A-5.15.Upon the si,grung of this Order by ail parties, IFA shall provide a copy of this ConsentOrder to all directors and officers of the Company within 24 hours of its receipt of thefully executed Consent order.16.IFA shall immediately comply with all terms of this Consent Order unless otherwisedirected.17.Pursuant to N.J.S.A. 17:51 A-4d, the Commissioner deems that it is in the best interest ofthe public, the Company,its insureds and creditors that this order shall be confidential.18.If any provision of this Consent Order or the application thereofis for any reasons held tobe invalid, the remainder of this Consent Order and the application thereof to otherpersons or circumstances shall not be affected thereby.l9.The Commissioner may modify this Consent Order, from time to time, upon writtennotification to IFA, to address matters necessary for the benefit of IFA, its policyholders,beneficiaries, creditors and/or the public. Nothing in this Consent Order shalt prevent theCommissioner from taking any action deemed necessary by the Commissioner withrespect to IFA pursuant to this Consent Qrder, or with respect to any a.f iliate ofIFA as tomatters over which the Commissioner has regulatory jurisdiction. IFA consent to thisConsent Order shalt not be construed as its advanced consent to any modifcations ofthisConsent Order made by the Commissioner pursuant to this paragraph.20.The Commissioner reserves the right to, at any time subsequent to the date of thisConsent Order, issue additional orders and/or make applications for additional and

different relief related to this Consent (order or the Company if the Commissionerdetermines that any such order or relief is necessary in accordance with Title 17 of theRevised Statutes, including, but not limited to, the imposition of fines for failing tocomply with the terms of any subpoena issued by the Department.21.This Consent Order of Administrative Supervision may be executed in twa or morecounterparts, each of which shah be deemed an original, but all of which together shallconstitute one and the same Consent Order. The individuals signing the Consent Orderof Supervision on the respective behalf ofIFA warrants and represents that he/she has theauthority to bind that entity to this Order by their signature.Ne Je ey Departof Banking and InsuranceDate:Y 'cd . BadotT I,CommissionerConsented to by the parties as to form and entry.IFA Insurance CompanyDate:By:(Print clearly or type name an title)0/ J


yOF SHE ' ,QAy4jF , sP Fr ta te of , .e 'er epDEPARTMENT OF BANKING AND INSURANCEDIVISION OF INSURANCEPO Box 325TRENTON,NJ 08625-0325CHRIS CHRISTIEGovernorKIM GUADAGNORICHARD J. BADOLATOTE[.(609)292-0844FAx(609)292-3144Lt. GovernorCommissionerPETER L. HARTTDirectorCONFIDENTIAL &PROPRIETARYFebruary 21, 2017Via,E-Mail & Re lar MailDavid WalshPresidentIFA Insurance Company14 Walnut AvenueClark, NJ 07066Re:IFA Financial ConditionDear Mr. Walsh:Pursuant to our conversation this afternoon, the Commissioner hereby finds IFA inbreach of the requirements of Confidential Consent Order of Administrative Supervision No.C 16-101, dated September 19, 2016 ("Consent Order"). In that Consent Order, IFA agreed tomaintain a Risk Based Capital ("RBC") level of not less than 1.000 at all times to facilitate theorderly run-off of its business. Based upon the most recent financial information, as of February15, 2017, provided by IFA to the Department, IFA's RBC has fallen significantly below 1.000,and has breached. the level of RBC as required by the aforementioned Consent Order. In light ofthis, the Commissioner will petition the Superior Court in the near future for the placement ofIFA into liquidation because it is deemed to be insolvent, is in a hazardous financial condition,and it is likely that regulatory control of the company is mandated under law.The Consent Order provides that the Commissioner may in his sole discretion permit IFAtime to cure the breach. As discussed, the Commissioner declines to exercise his discretion andwill not allow any cure period because there appears to be no reasonable prospect of a viablecapital infusion to permanently remediate IFA's insolvency. Furthermore, under Paragraph 2 ofthe Consent Order, please be reminded that IFA has consented to the placement of the companyinto liquidation upon such a breach of the RBC requirement —whether or not a discretionary cureperiod has been provided.Visit tcs on the Web at dobi.nj.govPrinted on Recycled Paper and RecyclableNew jersey is an Egzcal Opportzcnit Employer

We will keep you apprised as we prepare to file the Petition for Liquidation, and wethank you for your cooperation during this difficult time.Very truly yours,.d,,Ffi Steven P. Kerner, Jr.Assistant Commissionerc:Peter L. Hartt, Director of InsuranceKristine A. Maurer, Assistant Director of InsuranceRichard D. Schlesinger, Chief Insurance ExaminerJohn Sirovetz, Assistant Chief Insurance ExaminerChristopher Brennan, Legal Specialist

EXI'll 1t

private passenger automobile insurance business as of December 4, 1973. IFA is a wholly-owned subsidiary of Independent Financial Agents, Inc., which maintains its office at the same location as IFA. 3. IFA is also authorized to transact private passenger automobile insurance

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