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2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 11 SOUTHERN DIVISION 12 Case Number: 8:17-ML-2797-AG-KES 13 IN RE WELLS FARGO COLLATERAL 14 PROTECTION INSURANCE DECLARATION OF CAMERON R. LITIGATION AZARI, ESQ. ON 15 IMPLEMENTATION OF SETTLEMENT NOTICE PLAN 16 17 Date: October 28, 2019 Time: 10:00 am 18 Courtroom: 10D

19 Hon. Andrew J. Guilford 20 21 22

23 24 25

26 27 28

76057444.1 Case No.: 8:17-ML-2797-AG-KES DECLARATION OF CAMERON R. AZARI, ESQ.

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1 I, Cameron Azari, declare as follows: 2 1. My name is Cameron R. Azari, Esq. I have personal knowledge of the matters 3 set forth herein, and I believe them to be true and correct. 4 2. I am a nationally recognized expert in the field of legal notice, and I have 5 served as an expert in dozens of federal and state cases involving class action notice plans. 6 3. I am the Director of Legal Notice for Hilsoft Notifications (“Hilsoft”), a firm 7 that specializes in designing, developing, analyzing and implementing, large-scale legal 8 notification plans. Hilsoft is a business unit of Epiq Class Action & Claims Solutions, Inc. 9 (“Epiq”). 10 4. This declaration details the implementation of the Settlement Notice Plan 11 (“Notice Plan” or “Plan”) for the Settlement in In Re Wells Fargo Collateral Protection 12 Insurance Litigation., Case No. 8:17-ML-2797-AG-KES, in the United States District Court 13 for the Central District of California. In the Declaration of Cameron R. Azari, Esq. on 14 Settlement Notice Plan, dated June 6, 2019, I detailed Hilsoft’s class action notice 15 experience and attached Hilsoft’s curriculum vitae. I also provided my educational and 16 professional experience relating to class actions and my ability to render opinions on the 17 overall adequacy of notice programs. The facts in this declaration are based on my personal 18 knowledge, as well as information provided to me by my colleagues in the ordinary course 19 of my business at Hilsoft and Epiq. 20 5. On August 5, 2019, the Court approved the Notice Plan as designed by Hilsoft 21 and appointed Epiq to serve as the third-party settlement administrator in the Amended 22 Order Preliminarily Approving Class Action Settlement and Class Notice (the “Order”). 23 In the Order, the Court certified the following definition of the Settlement Class, which 24 consists of: 25 Wells Fargo Dealer Services (“WFDS”) Customers who had a CPI Policy placed on their Account(s) that became effective at any time 26 between October 15, 2005 and September 30, 2016 and Wells Fargo 27 Auto Finance (“WFAF”) Customers who had a CPI Policy placed on their Account(s) that became effective at any time between February 2, 28 2006 and September 1, 2011.

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1 The Settlement Class excludes (a) customers who provided proof of Duplicative Insurance Coverage for the entire CPI Placement Period, 2 resulting in a cancellation of the policy in full before the scheduled CPI 3 Billing Date; (b) customers who provided proof of Duplicative Insurance Coverage for the entire CPI Placement Period, resulting in a cancellation 4 of the policy in full on or after the scheduled CPI Billing Date but before 5 the payment due date reflected on the customer’s first periodic statement reflecting any increased monthly payment amount due to the CPI 6 premium; and (c) other customers who provided proof of Duplicative 7 Insurance Coverage for the entire CPI Placement Period, resulting in a cancellation of the policy in full, and who did not pay a Duplicative CPI 8 Premium or Duplicative CPI Interest, who were not assessed Fees during 9 the CPI Impact Period that were not waived at the time, and who did not experience any negative credit reporting as a result of CPI as set forth in 10 Section III(G) of the Settlement Agreement. 11 6. After the Court’s preliminary approval of the Settlement, we began to 12 implement the Notice Program. This declaration will detail the notice activities undertaken 13 to date and explain how and why the Notice Plan is comprehensive and well-suited to the 14 Settlement Class. This declaration will also discuss the administration activity to date. The 15 facts in this declaration are based on what I personally know, as well as information 16 provided to me in the ordinary course of my business by my colleagues from Hilsoft and 17 Epiq, who worked with us to implement the notification effort. 18 NOTICE PLAN SUMMARY 19 7. Rule 23 of the Federal Rules of Civil Procedure directs that the best notice 20 practicable under the circumstances must include “individual notice to all members who can 21 be identified through reasonable effort.”1 The Notice Plan here satisfies this requirement by 22 mailing individual notices to all Settlement Class Members with identifiable mailing 23 addresses - which is virtually all Settlement Class Members. An extensive address updating 24 protocol was also implemented, in order to identify the best, current address for each 25 member of the Class. To supplement the comprehensive mailed notice effort, a targeted, 26 online media effort is currently being implemented. The combination of individual notice 27 28 1 FRCP 23(c)(2)(B). 2 Case No.: 8:17-ML-2797-AG-KES DECLARATION OF CAMERON R. AZARI, ESQ.

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1 and the measured portions of the paid media plan detailed below is estimated to reach at 2 least 90% of the Class (and perhaps higher). 3 4 CAFA NOTICE 5 8. As described in the attached “Declaration of Stephanie J. Fiereck, Esq. on 6 Implementation of CAFA Notice,” dated July 5, 2019 (“Fiereck Declaration”), Epiq sent a 7 CAFA notice packet (or “CAFA Notice”), on behalf of Wells Fargo & Company and Wells 8 Fargo Bank, N.A. d/b/a Wells Fargo Dealer Services, as required by the federal Class 9 Action Fairness Act of 2005 (CAFA), 28 U.S.C. § 1715, to 115 officials on June 14, 2019. 10 The CAFA Notice was mailed by certified mail to 112 officials, including the Attorneys 11 General of each of the 50 states, the District of Columbia and the United States Territories, 12 and State Insurance Commissioners. The Notice was also sent by United Parcel Service 13 (“UPS”) to three officials, including the Attorney General of the United States, the Office 14 of the Comptroller of the Currency, and the Consumer Financial Protection Bureau. The 15 Fiereck Declaration is included as Attachment 1. 16 17 NOTICE PLAN IMPLEMENTATION Class Data 18 19 9. Beginning on July 25, 2019, Epiq received 12 data files from Wells Fargo, which 20 represented data for virtually all Settlement Class Members. The files were organized by loan, 21 with up to four borrowers, two attorneys, and two trustees for each loan. Epiq split each of 22 these borrowers, attorneys, and trustees into a separate record. For the primary borrowers 23 (1,657,199 borrowers), Epiq referenced the mailing address from work conducted for Wells 24 Fargo’s original remediation program. 25 10. As part of Wells Fargo’s original remediation program, an extensive multi-layer 26 address hygiene process was undertaken and, therefore, the addresses in the database for these 27 Class Members were assumed to be very good. For the Class Members who were not involved 28 in the prior remediation effort, steps to update addresses were employed in anticipation of a

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1 future mailing. 2 11. For the mailing of the settlement notice here, if an address was less than 120 3 days old, Epiq used the address as-is. If the address was 120 days old or older, Epiq sent 4 the addresses to a third-party for address updates and checked against National Change of 5 Address (“NCOA”)2 database maintained by the United States Postal Service (“USPS”), 6 then mailed to updated addresses. For non-primary borrowers (593,343 borrowers who 7 were listed as the 2nd through 4th borrower on a loan), Epiq updated the addresses through a 8 third-party, then ran the addresses against the NCOA database. Trustee and attorney records 9 were also sent to a third-party for address updates. In addition, all addresses were certified 10 via the Coding Accuracy Support System (“CASS”) to ensure the quality of the zip code, 11 and verified through Delivery Point Validation (“DPV”) to verify the accuracy of the 12 addresses. This address updating process is standard for the industry and for the majority 13 of promotional mailings that occur today. 14 12. For 2,982 borrowers and one attorney, the initial data files did not contain enough 15 name or address information to attempt a mailing. Epiq and Wells Fargo collaborated to find 16 additional name and address information for these borrowers, and located addresses for 2,454 17 borrowers and one attorney. After additional research, Epiq and Wells Fargo were not able to 18 mail to 528 borrowers. 19 Individual Notice – Mailed Notice 20 13. This data is being used to send to all Settlement Class Members a custom 10- 21 image notice and 2-image cover letter, inserted into a custom window envelope (the “Notice 22 Packet”) that clearly and concisely summarizes the Settlement. The Notice Packet directs 23 the recipients to a case website dedicated to the Settlement where they can access additional 24 information. A copy of the Notice Packet is included as Attachment 2. 25 14. Mailing began on August 12, 2019, and will continue through September 5, 26 2 The NCOA database contains records of all permanent change of address submissions received by the 27 USPS for the last four years. The USPS makes this data available to mailing firms and lists submitted to it 28 are automatically updated with any reported move based on a comparison with the person’s name and known address. 4 Case No.: 8:17-ML-2797-AG-KES DECLARATION OF CAMERON R. AZARI, ESQ.

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1 2019. As of August 30th, we have mailed 1,687,557 Notice Packets and by September 5th, 2 an estimated 2,251,956 Notice Packets will have been sent via USPS first class mail. 3 15. Additionally, a Long Form Notice is being mailed via USPS first class mail 4 to all persons who request one via the toll-free phone number. The Long Form Notice is 5 available in both English and Spanish. As of August 27, 2019, a total of 26 Long Form 6 Notices have been mailed as a result of requests via the toll-free phone number or by mail. 7 The Long Form Notice is also available for download or printing at the website. 8 16. The return address on the Notice Packets is a post office box maintained by 9 Epiq. Notice Packets returned as undeliverable are re-mailed to any new address available 10 through postal service information, for example, to the address provided by the postal 11 service on returned pieces for which the automatic forwarding order has expired. If there 12 is no address available through postal service information, Epiq manually searches for a 13 better address using a third party lookup service (“CLEAR” maintained by Thomson 14 Reuters). Upon successfully locating better addresses, Notice Packets are promptly re- 15 mailed. 16 Individual Notice – Emailed Notice 17 17. Between August 21, 2019 and August 30, 2019, Epiq sent 1,019,408 email 18 notices to Settlement Class Members with a valid email address. The Summary Email 19 Notice was created using an embedded html text format with an embedded link to the case 20 website. This format provides easy to read text without graphics, tables, images and other 21 elements that would increase the likelihood that the message could be blocked by Internet 22 Service Providers (ISPs) and/or SPAM filters. Each Summary Email Notice was 23 transmitted with a unique message identifier. If the receiving e-mail server cannot deliver 24 the message, a “bounce code” is returned along with the unique message identifier. For 25 any Summary Email Notice for which a bounce code is received indicating that the 26 message is undeliverable, at least two additional attempts will be made to deliver the Notice 27 by email. A copy of the Email Notice is included as Attachment 3. 28

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1 Media Notice - Internet Banner Notices 2 18. Internet advertising has become a standard component in legal notice 3 programs. The internet has proven to be an efficient and cost-effective method to target 4 and provide measurable reach of persons covered by a settlement. According to GfK MRI 5 syndicated research, over 86% of adults are online. Banner Notices are currently running 6 on select websites that Class Members may visit regularly, and we are utilizing networks 7 based on cost efficiency, timing, and their contribution to the overall reach of the target 8 campaign. The Banner Notices are image-based graphic displays available on desktops 9 and mobile devices. The text of the banner advertisements allow users to identify 10 themselves as potential Settlement Class Members and directly link them to the case 11 website for more information. 12 19. Banner Notices measuring 728 x 90, 300 x 600, and 250 x 300 pixels began 13 running on August 12, 2019 across both the Verizon Media (Yahoo) Audience Network and 14 the Google Display Network. The Google Display Network covers 90% of the U.S. 15 population that is online and encompasses over two million individual websites. 16 20. Banner notices measuring 254 x 133 and 1080 x 1080 pixels also began 17 running on August 12, 2019 on Facebook and Instagram. Facebook is the most widely 18 used social networking service in the world while Instagram is the leading social network 19 among users 18-28 in the United States. When a user logs into their Facebook account they 20 are presented with their homepage, also known as the “newsfeed.” Banners appear in the 21 right hand column next to the newsfeed, while notices on Instagram appear directly within 22 a user’s newsfeed. 23 21. In addition to the more broadly targeted notices outlined above, the banner 24 notice effort that began on August 12, 2019 also includes more specifically targeted 25 placements on Google, Verizon, Facebook, Instagram, and the Conversant Ad Network. 26 Specifically: 27  Banners targeted via a Google Custom Affinity Audience ad buy which 28 focuses only on websites related to topics such as “Car Loans,” Auto

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1 Financing,” and/or “Credit and Lending.” 2  A custom sitelist was purchased via the Verizon Media (Yahoo) Audience 3 Network targeting the “Automotive” category. 4  Banner notices on both Facebook and Instagram targeting individuals who 5 have expressed an interest, based on their online preferences, in “Car 6 Finance.” 7  Banner notices targeted using a “list activation” strategy through the 8 Conversant Ad Network. This is accomplished by matching the actual 9 names, and physical/email addresses of known Settlement Class Members 10 with current consumer profiles. This strategy ensures that specific 11 individuals receiving direct notice are also provided reminder messaging 12 online via banner ads. 13 22. Details of the online notice program are outlined in the table below. 14 Projected A18+ 15 Network/Property Banner Size Impressions 16 300x250; 728x90; Conversant - List Activation 320x480; 480x320 n/a 17 300x600 300x250; 728x90; 18 Google Display Network 80,000,000 300x600 19 Google Display Network: Custom 300x250; 728x90; 35,000,000 20 Affinity Audience 300x600 Facebook 254x133 60,000,000 21 Facebook: Interests include "Car 254x133 1,000,000 22 Finance" 23 Instagram 1080x1080 4,000,000 Instagram: Interests include "Car 1080x1080 1,000,000 24 Finance" Verizon (Yahoo!) Ad Network 300x250; 728x90; 25 32,000,000 300x600 26 Verizon (Yahoo!) Ad Network: 300x250; 728x90; 16,000,000 27 Automotive Sitelist 300x600 TOTAL 229,000,000 28

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1 23. Combined, approximately 229 million adult impressions will be generated by 2 the Banner Notices, which are scheduled to run through September 5, 2019. A copy of the 3 Banner Notice is included as Attachment 4. 4 Internet Sponsored Search Listings 5 24. To facilitate locating the case website, sponsored search listings are being 6 acquired on the three most highly-visited internet search engines: Google, Yahoo, and 7 Bing. When search-engine visitors search on common keyword combinations to identify 8 the Settlement, the sponsored search listing generally are displayed at the top of the page 9 prior to the search results or in the upper right-hand column of the web-browser screen. 10 25. As of August 30, 2019, the sponsored listings have been displayed 7,735 11 times, resulting in 1,586 clicks that displayed the case website. A complete list of the 12 sponsored search keyword combinations is included as Attachment 5. Examples of the 13 sponsored search listing as displayed on each search engine are included as Attachment 6. 14 Informational Release 15 26. To build additional reach and extend exposures, a party-neutral Informational 16 Release was issued on August 12, 2019, to approximately 5,000 general media (print and 17 broadcast) outlets across the United States and 4,500 online databases and websites 18 (including websites for large news outlets, local affiliate news stations, business journals 19 and trade organizations). The Informational Release served a valuable role by providing 20 additional notice exposures beyond those already provided by the paid media. A copy of 21 the Information Release is included as Attachment 7. 22 Case Website, Toll-free Telephone Number, and Postal Mailing Address 23 27. On August 12, 2019, a dedicated website was established for the Settlement 24 with an easy-to-remember domain name (www.WellsFargoCPISettlement.com). 25 Settlement Class Members can obtain detailed information about the case and review key 26 documents, including the Settlement Notices, Settlement Agreement, Complaint, and 27 Amended Preliminary Approval Order, as well as answers to frequently asked questions 28 (“FAQs”). The case website address is displayed prominently on all notice documents.

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1 28. As of August 30, 2019, there have been 182,372 visits, represented by unique 2 users to the case website and over 231,145 website pages presented. 3 29. On August 12, 2019, a toll-free telephone number (1-877-641-8815) was 4 established to allow Settlement Class Members to call for additional information, listen to 5 answers to FAQs, request that a Notice be mailed to them and choose to speak to a live 6 operator during normal business hours. The toll-free telephone number is prominently 7 displayed in the Notice documents as well. This automated phone system is available 24 8 hours per day, 7 days per week. As of August 30, 2019, the toll-free number has handled 9 19,362 calls representing 133,761 minutes of use and live operators have handled 7,692 10 incoming calls representing 49,047 minutes of use. Live operators have also made 134 11 outbound calls representing 263 minutes of use. 12 30. A post office box for correspondence about the Settlement was established 13 and maintained, to allow Settlement Class Members to contact Epiq by mail with any 14 specific requests or questions. 15 CONCLUSION 16 31. In class action notice planning, execution, and analysis, we are guided by due 17 process considerations under the United States Constitution, by state and local rules and 18 statutes, and by case law pertaining to the recognized notice standards under Rule 23. This 19 framework directs that the notice plan be optimized to reach the class and, in a settlement 20 class action notice situation such as this, that the notice or notice plan itself not limit 21 knowledge of the availability of benefits—nor the ability to exercise other options—to 22 class members in any way. All of these requirements will be met in this case. 23 32. The Notice Plan includes individual notice to all Class Members who can be 24 identified with reasonable effort. Because of the extensive address updating protocols that 25 were implemented, we reasonably expect to deliver individual notice to well over 90% of 26 the identified Class. Even if the mailed notice is only ultimately delivered to 85% of the 27 identified Class, the combination of the individual notice effort and the Internet Banner 28 Notices will reach at least 90% of the Class (and likely higher). The Sponsored Search

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Attachment 1 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 13 of 65 Page ID #:5201

IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

) IN RE WELLS FARGO COLLATERAL ) PROTECTION INSURANCE ) Case Number: 8:17-ML-2797-AG-KES LITIGATION ) ) ) ______)

DECLARATION OF STEPHANIE J. FIERECK, ESQ. ON IMPLEMENTATION OF CAFA NOTICE

I, STEPHANIE J. FIERECK, ESQ., hereby declare and state as follows:

1. My name is Stephanie J. Fiereck, Esq. I am over the age of 21 and I have

personal knowledge of the matters set forth herein, and I believe them to be true and correct.

2. I am the Legal Notice Manager for Epiq Class Action & Claims Solutions, Inc.

(“Epiq”), a firm that specializes in designing, developing, analyzing and implementing large-scale,

un-biased, legal notification plans.

3. Epiq is a firm with more than 20 years of experience in claims processing and

settlement administration. Epiq’s class action case administration services include coordination

of all notice requirements, design of direct-mail notices, establishment of fulfillment services,

receipt and processing of opt-outs, coordination with the United States Postal Service, claims

database management, claim adjudication, funds management and distribution services.

4. The facts in this Declaration are based on what I personally know, as well as

information provided to me in the ordinary course of my business by my colleagues at Epiq.

CAFA NOTICE IMPLEMENTATION

5. At the direction of counsel for Defendants Wells Fargo & Company and Wells

Fargo Bank, N.A. d/b/a Wells Fargo Dealer Services (“Wells Fargo”), 115 officials, which

DECLARATION OF STEPHANIE J. FIERECK, ESQ. ON IMPLEMENTATION OF CAFA NOTICE

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included the Attorney General of the United States and the Attorneys General of each of the 50

states, the District of Columbia and the United States Territories, State Insurance

Commissioners, the Office of the Comptroller of the Currency, and the Consumer Financial

Protection Bureau were identified to receive the CAFA notice.

6. Epiq prepared a list of these state and federal officials with contact information

for the purpose of providing CAFA notice. Prior to mailing, the names and addresses from

Epiq’s list were verified, then run through the Coding Accuracy Support System (“CASS”)

maintained by the United States Postal Service (“USPS”).1

7. On June 14, 2019, Epiq sent 115 CAFA Notice Packages (“Notice”). The Notice

was mailed by certified mail to 112 officials, including the Attorneys General of each of the 50

states, the District of Columbia and the United States Territories, and State Insurance

Commissioners. The Notice was also sent by United Parcel Service (“UPS”) to three officials,

including the Attorney General of the United States, the Office of the Comptroller of the

Currency, and the Consumer Financial Protection Bureau. The CAFA Notice Service List

(USPS Certified Mail and UPS) is included hereto as Attachment 1.

8. The materials sent to the federal and state officials included a cover letter, which

provided notice of the proposed settlement of the above-captioned case. The cover letter is

included hereto as Attachment 2.

9. The cover letter was accompanied by a CD, which included the following:

a. Consolidated Class Action Complaint, Amended Consolidated Class

Action Complaint, and Second Amended Consolidated Class Action Complaint;

1 CASS improves the accuracy of carrier route, 5-digit ZIP®, ZIP + 4® and delivery point codes that appear on mail pieces. The USPS makes this system available to mailing firms who want to improve the accuracy of postal codes, i.e., 5-digit ZIP®, ZIP + 4®, delivery point (DPCs), and carrier route codes that appear on mail pieces.

DECLARATION OF STEPHANIE J. FIERECK, ESQ. ON IMPLEMENTATION OF CAFA NOTICE 2

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Attachment 1 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 17 of 65 Page ID CAFA Notice Service List #:5205UPS

Company FullName Address1 Address2 City State Zip US Department of Justice William Barr 950 Pennsylvania Ave NW Washington DC 20530 Office of the Comptroller of the Currency Gregory F. Taylor Litigation Division 400 7th St. SW Suite 3E-218 Washington DC 20219 Consumer Financial Protection Bureau Stephen Van Meter Deputy General Counsel 1700 G St. NW Washington DC 20552 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 18 of 65 Page ID CAFA #:5206Notice Service List State Insurance Commissioners USPS Certified Mail Company FullName Address1 Address2 City State Zip Alabama Department of Insurance JIM L. RIDLING PO Box 303351 Montgomery AL 36130 Alaska Dept Commerce Comm. & Econ. Dev. LORI K. WING-HEIER Division of Insurance 550 West 7th Avenue Suite 1560 Anchorage AK 99501 Arizona Department of Insurance KEITH SCHRAAD 100 N 15th Ave Suite 102 Phoenix AZ 85007 Arkansas Insurance Department ALLEN W. KERR 1200 West Third Street Little Rock AR 72201 California Department of Insurance RICARDO LARA 300 Capitol Mall Suite 1700 Sacramento CA 95814 Colorado Dept of Regulatory Agencies MICHAEL CONWAY Division of Insurance 1560 Broadway Suite 850 Denver CO 80202 Connecticut Insurance Department ANDREW N. MAIS PO Box 816 Hartford CT 06142 Delaware Department of Insurance TRINIDAD NAVARRO 841 Silver Lake Boulevard Dover DE 19904 Government of the District of Columbia STEPHEN C. TAYLOR Department of Insurance Securities & Banking 1050 First Street NE Suite 801 Washington DC 20002 Office of Insurance Regulation DAVID ALTMAIER The Larson Building 200 E. Gaines Street Rm 101A Tallahassee FL 32399 Office of Ins. & Safety Fire Commissioner JIM BECK Two Martin Luther King Jr. Dr. West Tower Suite 704 Atlanta GA 30334 Dept of Commerce & Consumer Affairs COLIN M. HAYASHIDA Insurance Division PO Box 3614 Honolulu HI 96811 Idaho Department of Insurance DEAN CAMERON PO Box 83720 Boise ID 83720 Illinois Department of Insurance ROBERT H. MURIEL 320 W Washington Street Springfield IL 62767 Indiana Department of Insurance STEPHEN W. ROBERTSON 311 W Washington Street Suite 103 Indianapolis IN 46204 Iowa Insurance Division DOUG OMMEN Two Ruan Center 601 Locust 4th Floor Des Moines IA 50309 Kansas Insurance Department VICKI SCHMIDT 420 SW 9th Street Topeka KS 66612 Kentucky Department of Insurance NANCY G. ATKINS PO Box 517 Frankfort KY 40602 Louisiana Department of Insurance JAMES J. DONELON PO Box 94214 Baton Rouge LA 70804 Department of Professional & Financial Reg. ERIC A. CIOPPA Maine Bureau of Insurance 34 State House Station Augusta ME 04333 Maryland Insurance Administration AL REDMER JR. 200 St Paul Place Suite 2700 Baltimore MD 21202 Office of Consumer Affairs & Business Reg. GARY ANDERSON Massachusetts Division of Insurance 1000 Washington Street 8th Floor Boston MA 02118 Dept. of Insurance & Financial Services ANITA G. FOX PO Box 30220 Lansing MI 48909 Minnesota Department of Commerce STEVE KELLEY 85 7th Place East Suite 500 St Paul MN 55101 Mississippi Insurance Department MIKE CHANEY PO Box 79 Jackson MS 39205 Missouri Dept Ins. Fin. Institutions & Prof. Reg. CHLORA LINDLEY-MYERS PO Box 690 Jefferson City MO 65102 Montana Office Commissioner Securities & Ins. MATTHEW ROSENDALE Montana State Auditor 840 Helena Avenue Helena MT 59601 Nebraska Department of Insurance BRUCE R. RAMGE PO Box 82089 Lincoln NE 68501 Nevada Dept. of Business & Industry BARBARA RICHARDSON Division of Insurance 1818 East College Pkwy Suite 103 Carson City NV 89706 New Hampshire Insurance Department JOHN ELIAS 21 South Fruit Street Suite 14 Concord NH 03301 New Jersey Department of Banking & Ins. MARLENE CARIDE 20 West State Street PO Box 325 Trenton NJ 08625 Office of Superintendent of Insurance JOHN G. FRANCHINI PO Box 1689 Santa Fe NM 87504 New York State Dept. of Financial Services LINDA A. LACEWELL One State Street New York NY 10004 North Carolina Department of Insurance MIKE CAUSEY 1201 Mail Service Center Raleigh NC 27699 North Dakota Insurance Department JON GODFREAD State Capitol Fifth Floor 600 E. Boulevard Avenue Bismarck ND 58505 Ohio Department of Insurance JILLIAN FROMENT 50 West Town Street Third Floor Suite 300 Columbus OH 43215 Oklahoma Insurance Department GLEN MULREADY Five Corporate Plaza 3625 NW 56th Street Suite 100 Oklahoma City OK 73112 Oregon Dept. of Consumer & Bus Srvcs ANDREW STOLFI Division of Financial Regulation PO Box 14480 Salem OR 97309 Pennsylvania Insurance Department JESSICA ALTMAN 1326 Strawberry Square Harrisburg PA 17120 State of Rhode Island Dept of Business Reg. ELIZABETH KELLEHER DWYER Division of Insurance 1511 Pontiac Avenue Building 69-2 Cranston RI 02920 South Carolina Department of Insurance RAYMOND G. FARMER PO Box 100105 Columbia SC 29202 South Dakota Dept of Labor & Reg. Div. of Ins. LARRY DEITER South Dakota Division of Insurance 124 South Euclid Avenue 2nd Floor Pierre SD 57501 Tennessee Department of Commerce & Ins. JULIE MIX MCPEAK Davy Crockett Tower Twelfth Floor 500 James Robertson Parkway Nashville TN 37243 Texas Department of Insurance KENT SULLIVAN PO Box 149104 Austin TX 78714 Utah Insurance Department TODD E. KISER 3110 State Office Building Salt Lake City UT 84114 Department of Financial Regulation MICHAEL S. PIECIAK 89 Main Street Montpelier VT 05620 Virginia State Corporation Commission SCOTT A. WHITE Bureau of Insurance PO Box 1157 Richmond VA 23218 Washington State Office of the Ins. Comm. MIKE KREIDLER PO Box 40256 Olympia WA 98504 West Virginia Offices of the Insurance Comm. JAMES A. DODRILL PO Box 50540 Charleston WV 25305 State of Wisconsin Office of the Comm. of Ins. MARK AFABLE PO Box 7873 Madison WI 53707 Wyoming Insurance Department TOM GLAUSE 106 East 6th Avenue Cheyenne WY 82002 Office of the Governor PETER FUIMAONO American Samoa Government A P Lutali Executive Office Building Pago Pago AS 96799 Department of Revenue & Taxation DAFNE M. SHIMIZU Regulatory Division PO Box 23607 GMF Barrigada GU 96921 Commonwealth N Mariana Islands Dept Comm. MARK O. RABAULIMAN Office of the Insurance Commissioner Caller Box 10007 CK Saipan MP 96950 Office of the Commissioner of Insurance JAVIER RIVERA RIOS B5 Calle Tabonuco Suite 216 PMB356 Guaynabo PR 00968 Office of the Lieutenant Governor TREGENZA A. ROACH Division of Banking & Insurance 1131 King Street 3rd Floor Suite 101 Christiansted St. Croix VI 00820 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 19 of 65 Page ID CAFA Notice#:5207 Service List USPS Certified Mail

Company FullName Address1 Address2 City State Zip Office of the Attorney General Kevin G Clarkson PO Box 110300 Juneau AK 99811 Office of the Attorney General Steve Marshall 501 Washington Ave Montgomery AL 36104 Office of the Attorney General Leslie Carol Rutledge 323 Center St Suite 200 Little Rock AR 72201 Office of the Attorney General Mark Brnovich 2005 N Central Ave Phoenix AZ 85004 Office of the Attorney General CAFA Coordinator Consumer Law Section 455 Golden Gate Ave Ste 11000 San Francisco CA 94102 Office of the Attorney General Phil Weiser Ralph L Carr Colorado Judicial Center 1300 Broadway 10th Fl Denver CO 80203 Office of the Attorney General William Tong 55 Elm St Hartford CT 06106 Office of the Attorney General Karl A. Racine 441 4th St NW Washington DC 20001 Office of the Attorney General Kathy Jennings Carvel State Office Bldg 820 N French St Wilmington DE 19801 Office of the Attorney General Ashley Moody State of Florida The Capitol PL-01 Tallahassee FL 32399 Office of the Attorney General Chris Carr 40 Capitol Square SW Atlanta GA 30334 Department of the Attorney General Clare E. Connors 425 Queen St Honolulu HI 96813 Iowa Attorney General Thomas J Miller 1305 E Walnut St Des Moines IA 50319 Office of the Attorney General Lawrence G Wasden 700 W Jefferson St Ste 210 PO Box 83720 Boise ID 83720 Office of the Attorney General Kwame Raoul 100 W Randolph St Chicago IL 60601 Indiana Attorney General's Office Curtis T Hill Jr Indiana Government Center South 302 W Washington St 5th Fl Indianapolis IN 46204 Office of the Attorney General Derek Schmidt 120 SW 10th Ave 2nd Fl Topeka KS 66612 Office of the Attorney General Andy Beshear Capitol Ste 118 700 Capitol Ave Frankfort KY 40601 Office of the Attorney General Jeff Landry 1885 N Third St Baton Rouge LA 70802 Office of the Attorney General Maura Healey 1 Ashburton Pl Boston MA 02108 Office of the Attorney General Brian E. Frosh 200 St Paul Pl Baltimore MD 21202 Office of the Attorney General Aaron Frey 6 State House Sta Augusta ME 04333 Department of Attorney General Dana Nessel PO Box 30212 Lansing MI 48909 Office of the Attorney General Keith Ellison 445 Minnesota St Suite 1400 St Paul MN 55101 Missouri Attorney General's Office Eric Schmitt PO Box 899 Jefferson City MO 65102 MS Attorney General's Office Jim Hood Walter Sillers Bldg 550 High St Ste 1200 Jackson MS 39201 Office of the Attorney General Tim Fox Department of Justice PO Box 201401 Helena MT 59620 Attorney General's Office Josh Stein 9001 Mail Service Ctr Raleigh NC 27699 Office of the Attorney General Wayne Stenehjem State Capitol 600 E Boulevard Ave Dept 125 Bismarck ND 58505 Nebraska Attorney General Doug Peterson 2115 State Capitol Lincoln NE 68509 Office of the Attorney General Gordon MacDonald NH Department of Justice 33 Capitol St Concord NH 03301 Office of the Attorney General Gurbir S Grewal 8th Fl West Wing 25 Market St Trenton NJ 08625 Office of the Attorney General Hector Balderas 408 Galisteo St Villagra Bldg Santa Fe NM 87501 Office of the Attorney General Aaron Ford 100 N Carson St Carson City NV 89701 Office of the Attorney General Letitia James The Capitol Albany NY 12224 Office of the Attorney General Dave Yost 30 E Broad St 14th Fl Columbus OH 43215 Office of the Attorney General Mike Hunter 313 NE 21st St Oklahoma City OK 73105 Office of the Attorney General Ellen F Rosenblum Oregon Department of Justice 1162 Court St NE Salem OR 97301 Office of the Attorney General Josh Shapiro 16th Fl Strawberry Square Harrisburg PA 17120 Office of the Attorney General Peter F Neronha 150 S Main St Providence RI 02903 Office of the Attorney General Alan Wilson Rembert Dennis Office Bldg 1000 Assembly St Rm 519 Columbia SC 29201 Office of the Attorney General Jason Ravnsborg 1302 E Hwy 14 Ste 1 Pierre SD 57501 Office of the Attorney General Herbert H. Slatery III PO Box 20207 Nashville TN 37202 Office of the Attorney General Ken Paxton 300 W 15th St Austin TX 78701 Office of the Attorney General Sean D. Reyes Utah State Capitol Complex 350 North State St Ste 230 Salt Lake City UT 84114 Office of the Attorney General Mark R. Herring 202 North Ninth Street Richmond VA 23219 Office of the Attorney General TJ Donovan 109 State St Montpelier VT 05609 Office of the Attorney General Bob Ferguson 800 Fifth Avenue Suite 2000 Seattle WA 98104 Office of the Attorney General Josh Kaul PO Box 7857 Madison WI 53707 Office of the Attorney General Patrick Morrisey State Capitol Complex Bldg 1 Room E 26 Charleston WV 25305 Office of the Attorney General Bridget Hill 2320 Capitol Avenue Cheyenne WY 82002 Department of Legal Affairs Talauega Eleasalo V. Ale Executive Office Building 3rd Floor Pago Pago AS 96799 Attorney General Office of Guam Leevin T Camacho Administration Division 590 S Marine Corps Dr Ste 901 Tamuning GU 96913 Office of the Attorney General Edward Manibusan Administration Bldg PO Box 10007 Saipan MP 96950 PR Department of Justice Wanda Vazquez Garced Apartado 9020192 San Juan PR 00902 Department of Justice Denise N. George 34-38 Kronprindsens Gade GERS Bldg 2nd Fl St Thomas VI 00802 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 20 of 65 Page ID #:5208

Attachment 2 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 21 of 65 Page ID McGuireWoods LLP #:5209 Two Embarcadero Center Suite 1300 San Francisco, CA 94111-3821 Phone: 415.844.9944 Fax: 415.844.9922 www.mcguirewoods.com

David C. Powell [email protected] Direct: 415.844.1970 Fax: 415.844.1912

June 14, 2019

VIA UPS OR USPS CERTIFIED MAIL

All Addressees Listed in Attachment A.

Class Action Fairness Act – Notice to Federal and State Officials

Re: In re: Wells Fargo Collateral Protection Insurance Litigation, Case No. 8:17-ml-02797- AG-KESx, United States District Court for the Central District of California

Dear Sir or Madam:

We represent Defendants Wells Fargo & Company and Wells Fargo Bank, N.A. d/b/a Wells Fargo Dealer Services (“Wells Fargo”) in the above-captioned multi-district litigation (the “CPI MDL”). On behalf of Wells Fargo and co-Defendants National General Holdings Corp. and National General Insurance Company (“National General”), this notice is to inform you of a proposed settlement of the CPI MDL pursuant to 28 U.S.C. § 1715.

In accordance with 28 U.S.C. § 1715(b), Wells Fargo and National General state as follows:

1) Court-filed, redacted copies of the original, First Amended, and Second Amended Complaints in the CPI MDL are included in the accompanying CD. In addition, these complaints and all other pleadings and records filed in the CPI MDL are available on the Internet through the federal government’s Pacer service at https://ecf.cacd.uscourts.gov/cgi-bin/login.pl. Additional information about the Pacer service may be found at https://pacer.gov.

2) On June 6, 2019, Plaintiffs filed a Motion for Preliminary Approval of Class Settlement and Approval of Class Notice. Exhibit 1 to the Joint Declaration of Plaintiffs’ Co-Lead Counsel in Support of Plaintiffs’ Motion for Preliminary Approval includes the parties’ Settlement Agreement and Exhibits, which contain proposed forms of notice to class members of the proposed settlement and each class member’s right to request exclusion from the class action. In addition, the parties separately entered into a confidential attorney repayment agreement that was not filed with the Court. The Motion for Preliminary Approval, the Joint Declaration and Exhibit 1, and the confidential attorney repayment agreement are included in the accompanying CD.

Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 22 of 65 Page ID #:5210 June 14, 2019 Page 2

3) The hearing on the motion seeking preliminary approval is currently scheduled for July 29,2019 at 10:00 a.m. in Courtroom 1OD of the United States Courthouse located at 411 West Fourth Street, Santa Ana, California 92701, and a final approval hearing is not yet scheduled.

4) No final judgment or notice of dismissal has yet been entered in the CPI MDL.

5) It is not feasible at this time to provide the name and state of residence for each class member covered by the proposed settlement. At this time, the Defendants are able to provide an estimate of the number of class members, by state, that fall withm the class, along with an estimate of the proportionate share of relief being distributed in each state. The proportionate share of each individual class member will be dependent upon a number of factors that will not be known until after the final approval hearing (including, for example, the number and identity of class members that request exclusion).

6) No written judicial opinions have been issued relating to the proposed settlement as of this date.

It you have questions about this notice, the settlement, or the enclosed materials or if you do not receive any of the above-listed materials, please contact us. Thank you for your attention to this matter.

Sincerely,

/Wt€,GUIREWpapS LLP QUINN EMANUEL URQUHART & SULLIVAN, LLP

David Powell Core^Worcester Jason Evans Carolee Hoover Attorneys for Alicia Baiardo Defendants National General Insurance Aaron Marienthal Company and National General Holdings Corporation Counsel for Wells Fargo & Company and Wells Fargo Bank, N.A. d/b/a Wells Fargo Dealer Services

Attachment and Enclosure Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 23 of 65 Page ID Attachment A CAFA #:5211 Notice Service List

Company FullName Address1 Address2 City State Zip US Department of Justice William Barr 950 Pennsylvania Ave NW Washington DC 20530 Office of the Comptroller of the Currency Gregory F. Taylor Litigation Division 400 7th St. SW Suite 3E-218 Washington DC 20219 Consumer Financial Protection Bureau Stephen Van Meter Deputy General Counsel 1700 G St. NW Washington DC 20552 Office of the Attorney General Kevin G Clarkson PO Box 110300 Juneau AK 99811 Office of the Attorney General Steve Marshall 501 Washington Ave Montgomery AL 36104 Office of the Attorney General Leslie Carol Rutledge 323 Center St Suite 200 Little Rock AR 72201 Office of the Attorney General Mark Brnovich 2005 N Central Ave Phoenix AZ 85004 Office of the Attorney General CAFA Coordinator Consumer Law Section 455 Golden Gate Ave Ste 11000 San Francisco CA 94102 Office of the Attorney General Phil Weiser Ralph L Carr Colorado Judicial Center 1300 Broadway 10th Fl Denver CO 80203 Office of the Attorney General William Tong 55 Elm St Hartford CT 06106 Office of the Attorney General Karl A. Racine 441 4th St NW Washington DC 20001 Office of the Attorney General Kathy Jennings Carvel State Office Bldg 820 N French St Wilmington DE 19801 Office of the Attorney General Ashley Moody State of Florida The Capitol PL-01 Tallahassee FL 32399 Office of the Attorney General Chris Carr 40 Capitol Square SW Atlanta GA 30334 Department of the Attorney General Clare E. Connors 425 Queen St Honolulu HI 96813 Iowa Attorney General Thomas J Miller 1305 E Walnut St Des Moines IA 50319 Office of the Attorney General Lawrence G Wasden 700 W Jefferson St Ste 210 PO Box 83720 Boise ID 83720 Office of the Attorney General Kwame Raoul 100 W Randolph St Chicago IL 60601 Indiana Attorney General's Office Curtis T Hill Jr Indiana Government Center South 302 W Washington St 5th Fl Indianapolis IN 46204 Office of the Attorney General Derek Schmidt 120 SW 10th Ave 2nd Fl Topeka KS 66612 Office of the Attorney General Andy Beshear Capitol Ste 118 700 Capitol Ave Frankfort KY 40601 Office of the Attorney General Jeff Landry 1885 N Third St Baton Rouge LA 70802 Office of the Attorney General Maura Healey 1 Ashburton Pl Boston MA 02108 Office of the Attorney General Brian E. Frosh 200 St Paul Pl Baltimore MD 21202 Office of the Attorney General Aaron Frey 6 State House Sta Augusta ME 04333 Department of Attorney General Dana Nessel PO Box 30212 Lansing MI 48909 Office of the Attorney General Keith Ellison 445 Minnesota St Suite 1400 St Paul MN 55101 Missouri Attorney General's Office Eric Schmitt PO Box 899 Jefferson City MO 65102 MS Attorney General's Office Jim Hood Walter Sillers Bldg 550 High St Ste 1200 Jackson MS 39201 Office of the Attorney General Tim Fox Department of Justice PO Box 201401 Helena MT 59620 Attorney General's Office Josh Stein 9001 Mail Service Ctr Raleigh NC 27699 Office of the Attorney General Wayne Stenehjem State Capitol 600 E Boulevard Ave Dept 125 Bismarck ND 58505 Nebraska Attorney General Doug Peterson 2115 State Capitol Lincoln NE 68509 Office of the Attorney General Gordon MacDonald NH Department of Justice 33 Capitol St Concord NH 03301 Office of the Attorney General Gurbir S Grewal 8th Fl West Wing 25 Market St Trenton NJ 08625 Office of the Attorney General Hector Balderas 408 Galisteo St Villagra Bldg Santa Fe NM 87501 Office of the Attorney General Aaron Ford 100 N Carson St Carson City NV 89701 Office of the Attorney General Letitia James The Capitol Albany NY 12224 Office of the Attorney General Dave Yost 30 E Broad St 14th Fl Columbus OH 43215 Office of the Attorney General Mike Hunter 313 NE 21st St Oklahoma City OK 73105 Office of the Attorney General Ellen F Rosenblum Oregon Department of Justice 1162 Court St NE Salem OR 97301 Office of the Attorney General Josh Shapiro 16th Fl Strawberry Square Harrisburg PA 17120 Office of the Attorney General Peter F Neronha 150 S Main St Providence RI 02903 Office of the Attorney General Alan Wilson Rembert Dennis Office Bldg 1000 Assembly St Rm 519 Columbia SC 29201 Office of the Attorney General Jason Ravnsborg 1302 E Hwy 14 Ste 1 Pierre SD 57501 Office of the Attorney General Herbert H. Slatery III PO Box 20207 Nashville TN 37202 Office of the Attorney General Ken Paxton 300 W 15th St Austin TX 78701 Office of the Attorney General Sean D. Reyes Utah State Capitol Complex 350 North State St Ste 230 Salt Lake City UT 84114 Office of the Attorney General Mark R. Herring 202 North Ninth Street Richmond VA 23219 Office of the Attorney General TJ Donovan 109 State St Montpelier VT 05609 Office of the Attorney General Bob Ferguson 800 Fifth Avenue Suite 2000 Seattle WA 98104 Office of the Attorney General Josh Kaul PO Box 7857 Madison WI 53707 Office of the Attorney General Patrick Morrisey State Capitol Complex Bldg 1 Room E 26 Charleston WV 25305 Office of the Attorney General Bridget Hill 2320 Capitol Avenue Cheyenne WY 82002 Department of Legal Affairs Talauega Eleasalo V. Ale Executive Office Building 3rd Floor Pago Pago AS 96799 Attorney General Office of Guam Leevin T Camacho Administration Division 590 S Marine Corps Dr Ste 901 Tamuning GU 96913 Office of the Attorney General Edward Manibusan Administration Bldg PO Box 10007 Saipan MP 96950 PR Department of Justice Wanda Vazquez Garced Apartado 9020192 San Juan PR 00902 Department of Justice Denise N. George 34-38 Kronprindsens Gade GERS Bldg 2nd Fl St Thomas VI 00802 Alabama Department of Insurance JIM L. RIDLING PO Box 303351 Montgomery AL 36130 Alaska Dept Commerce Comm. & Econ. Dev. LORI K. WING-HEIER Division of Insurance 550 West 7th Avenue Suite 1560 Anchorage AK 99501 Arizona Department of Insurance KEITH SCHRAAD 100 N 15th Ave Suite 102 Phoenix AZ 85007

1 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 24 of 65 Page ID Attachment A CAFA #:5212 Notice Service List

Arkansas Insurance Department ALLEN W. KERR 1200 West Third Street Little Rock AR 72201 California Department of Insurance RICARDO LARA 300 Capitol Mall Suite 1700 Sacramento CA 95814 Colorado Dept of Regulatory Agencies MICHAEL CONWAY Division of Insurance 1560 Broadway Suite 850 Denver CO 80202 Connecticut Insurance Department ANDREW N. MAIS PO Box 816 Hartford CT 06142 Delaware Department of Insurance TRINIDAD NAVARRO 841 Silver Lake Boulevard Dover DE 19904 Government of the District of Columbia STEPHEN C. TAYLOR Department of Insurance Securities & Banki1050 First Street NE Suite 801 Washington DC 20002 Office of Insurance Regulation DAVID ALTMAIER The Larson Building 200 E. Gaines Street Rm 101A Tallahassee FL 32399 Office of Ins. & Safety Fire Commissioner JIM BECK Two Martin Luther King Jr. Dr. West Tower Suite 704 Atlanta GA 30334 Dept of Commerce & Consumer Affairs COLIN M. HAYASHIDA Insurance Division PO Box 3614 Honolulu HI 96811 Idaho Department of Insurance DEAN CAMERON PO Box 83720 Boise ID 83720 Illinois Department of Insurance ROBERT H. MURIEL 320 W Washington Street Springfield IL 62767 Indiana Department of Insurance STEPHEN W. ROBERTSON 311 W Washington Street Suite 103 Indianapolis IN 46204 Iowa Insurance Division DOUG OMMEN Two Ruan Center 601 Locust 4th Floor Des Moines IA 50309 Kansas Insurance Department VICKI SCHMIDT 420 SW 9th Street Topeka KS 66612 Kentucky Department of Insurance NANCY G. ATKINS PO Box 517 Frankfort KY 40602 Louisiana Department of Insurance JAMES J. DONELON PO Box 94214 Baton Rouge LA 70804 Department of Professional & Financial Reg. ERIC A. CIOPPA Maine Bureau of Insurance 34 State House Station Augusta ME 04333 Maryland Insurance Administration AL REDMER JR. 200 St Paul Place Suite 2700 Baltimore MD 21202 Office of Consumer Affairs & Business Reg. GARY ANDERSON Massachusetts Division of Insurance 1000 Washington Street 8th Floor Boston MA 02118 Dept. of Insurance & Financial Services ANITA G. FOX PO Box 30220 Lansing MI 48909 Minnesota Department of Commerce STEVE KELLEY 85 7th Place East Suite 500 St Paul MN 55101 Mississippi Insurance Department MIKE CHANEY PO Box 79 Jackson MS 39205 Missouri Dept Ins. Fin. Institutions & Prof. Reg. CHLORA LINDLEY-MYERS PO Box 690 Jefferson City MO 65102 Montana Office Commissioner Securities & Ins. MATTHEW ROSENDALE Montana State Auditor 840 Helena Avenue Helena MT 59601 Nebraska Department of Insurance BRUCE R. RAMGE PO Box 82089 Lincoln NE 68501 Nevada Dept. of Business & Industry BARBARA RICHARDSON Division of Insurance 1818 East College Pkwy Suite 103 Carson City NV 89706 New Hampshire Insurance Department JOHN ELIAS 21 South Fruit Street Suite 14 Concord NH 03301 New Jersey Department of Banking & Ins. MARLENE CARIDE 20 West State Street PO Box 325 Trenton NJ 08625 Office of Superintendent of Insurance JOHN G. FRANCHINI PO Box 1689 Santa Fe NM 87504 New York State Dept. of Financial Services LINDA A. LACEWELL One State Street New York NY 10004 North Carolina Department of Insurance MIKE CAUSEY 1201 Mail Service Center Raleigh NC 27699 North Dakota Insurance Department JON GODFREAD State Capitol Fifth Floor 600 E. Boulevard Avenue Bismarck ND 58505 Ohio Department of Insurance JILLIAN FROMENT 50 West Town Street Third Floor Suite 300 Columbus OH 43215 Oklahoma Insurance Department GLEN MULREADY Five Corporate Plaza 3625 NW 56th Street Suite 100 Oklahoma City OK 73112 Oregon Dept. of Consumer & Bus Srvcs ANDREW STOLFI Division of Financial Regulation PO Box 14480 Salem OR 97309 Pennsylvania Insurance Department JESSICA ALTMAN 1326 Strawberry Square Harrisburg PA 17120 State of Rhode Island Dept of Business Reg. ELIZABETH KELLEHER DWYER Division of Insurance 1511 Pontiac Avenue Building 69-2 Cranston RI 02920 South Carolina Department of Insurance RAYMOND G. FARMER PO Box 100105 Columbia SC 29202 South Dakota Dept of Labor & Reg. Div. of Ins. LARRY DEITER South Dakota Division of Insurance 124 South Euclid Avenue 2nd Floor Pierre SD 57501 Tennessee Department of Commerce & Ins. JULIE MIX MCPEAK Davy Crockett Tower Twelfth Floor 500 James Robertson Parkway Nashville TN 37243 Texas Department of Insurance KENT SULLIVAN PO Box 149104 Austin TX 78714 Utah Insurance Department TODD E. KISER 3110 State Office Building Salt Lake City UT 84114 Department of Financial Regulation MICHAEL S. PIECIAK 89 Main Street Montpelier VT 05620 Virginia State Corporation Commission SCOTT A. WHITE Bureau of Insurance PO Box 1157 Richmond VA 23218 Washington State Office of the Ins. Comm. MIKE KREIDLER PO Box 40256 Olympia WA 98504 West Virginia Offices of the Insurance Comm. JAMES A. DODRILL PO Box 50540 Charleston WV 25305 State of Wisconsin Office of the Comm. of Ins. MARK AFABLE PO Box 7873 Madison WI 53707 Wyoming Insurance Department TOM GLAUSE 106 East 6th Avenue Cheyenne WY 82002 Office of the Governor PETER FUIMAONO American Samoa Government A P Lutali Executive Office Building Pago Pago AS 96799 Department of Revenue & Taxation DAFNE M. SHIMIZU Regulatory Division PO Box 23607 GMF Barrigada GU 96921 Commonwealth N Mariana Islands Dept Comm.MARK O. RABAULIMAN Office of the Insurance Commissioner Caller Box 10007 CK Saipan MP 96950 Office of the Commissioner of Insurance JAVIER RIVERA RIOS B5 Calle Tabonuco Suite 216 PMB356 Guaynabo PR 00968 Office of the Lieutenant Governor TREGENZA A. ROACH Division of Banking & Insurance 1131 King Street 3rd Floor Suite 101 Christiansted St. VI 00820

2 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 25 of 65 Page ID #:5213

Attachment 2 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 26 of 65 Page ID #:5214 Notice Administrator for U.S. District Court P.O. Box 4990 Portland, OR 972084990

000 0000001 00000000 0001 0012 00002 INS:

CPI Class Action Settlement Tracking Number

If you were charged for collateral protection insurance on a Wells Fargo auto loan, you could receive a cash payment from a class action settlement.

Questions? Call 1-877-641-8815 or email [email protected].

Y4321 v.02 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 27 of 65 Page ID #:5215

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Questions? Call 1-877-641-8815 or email [email protected].

Y4322 v.02 Case 8:17-ml-02797-AG-KESDocument294-4Filed08/30/19Page28of65ID #:5216

000 0000002 00000000 0002 0012 00002 INS: Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 29 of 65 Page ID #:5217 Case 8:17-ml-02797-AG-KESDocument294-4Filed08/30/19Page30of65ID #:5218

000 0000003 00000000 0003 0012 00002 INS: Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 31 of 65 Page ID #:5219 Case 8:17-ml-02797-AG-KESDocument294-4Filed08/30/19Page32of65ID #:5220

000 0000004 00000000 0004 0012 00002 INS: Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 33 of 65 Page ID #:5221 Case 8:17-ml-02797-AG-KESDocument294-4Filed08/30/19Page34of65ID #:5222

000 0000005 00000000 0005 0012 00002 INS: Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 35 of 65 Page ID #:5223 Case 8:17-ml-02797-AG-KESDocument294-4Filed08/30/19Page36of65ID #:5224

000 0000006 00000000 0006 0012 00002 INS: Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 37 of 65 Page ID #:5225 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 38 of 65 Page ID #:5226

Attachment 3 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 39 of 65 Page ID #:5227

Komraus, Kathleen

From: Komraus, Kathleen Sent: Friday, August 30, 2019 9:57 AM To: Komraus, Kathleen Subject: FW: HTML Sample -- Legal Notice about $393.5 million class action settlement for Wells Fargo auto loan customers

From: [email protected] On Behalf Of Notice Administrator for U.S. District Court Sent: Tuesday, August 27, 2019 5:03 AM To: Subject: HTML Sample ‐‐ Legal Notice about $393.5 million class action settlement for Wells Fargo auto loan customers

CAUTION: This email originated from outside of Epiq. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Para obtener una notificación en español, póngase en contacto con nosotros o visite nuestra sitio www.WellsFargoCPISettlement.com.

Legal Notice of Proposed Settlement of Class Action

In re Wells Fargo Collateral Protection Insurance Litigation, Case No. 8:17-ML-2797-AG-KES

If you were charged for collateral protection insurance (“CPI”) on a Wells Fargo auto loan, you could receive a cash payment from a class action settlement.

The United States District Court for the Central District of California (“Court”) authorized this Notice of Proposed Settlement of Class Action (“Notice”). It is not a solicitation from a lawyer. Your legal rights may be affected whether you act or not. Please read this Notice carefully. This Notice is a summary of the proposed settlement. Please visit www.WellsFargoCPISettlement.com to view the Long Form Notice and Settlement Agreement dated June 6, 2019 (the “Settlement”), which have more information.

All capitalized terms used in this Notice, have the same meaning as the terms defined in the Settlement Agreement.

What is this case about? Defendants Wells Fargo (including Wells Fargo Bank, N.A. and Wells Fargo & Co.) and National General (including National General Holdings Corp. and National General Insurance Company) have agreed to settle claims alleging that between October 15, 2005 and September 30, 2016, they unlawfully placed CPI policies on Settlement Class Members’ automobile loan accounts. Under the proposed Settlement, Defendants will distribute at least $393.5 million to Settlement Class Members.

CPI is a type of insurance that Wells Fargo purchased from National General to cover potential damage to vehicles that served as collateral to Wells Fargo auto loans. The lawsuit alleges that the CPI Policies that Defendants placed on Settlement Class Members’ accounts were duplicative, unnecessary, and overpriced. Wells Fargo and National General deny these allegations.

Who is included? Wells Fargo’s records indicate you likely are a Settlement Class Member. The

1 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 40 of 65 Page ID #:5228 Settlement Class is defined as Wells Fargo Dealer Services (“WFDS”) Customers who had a CPI Policy placed on their Account(s) that became effective at any time between October 15, 2005 and September 30, 2016 and Wells Fargo Auto Finance (“WFAF”) Customers who had a CPI Policy placed on their Account(s) that became effective at any time between February 2, 2006 and September 1, 2011. Non-Compensable Flat Cancels, as that term is defined in Exhibit A to the Settlement Agreement, are excluded from the Settlement.

What does the Settlement provide? This Settlement: (1) legally obligates Wells Fargo to compensate Settlement Class Members who had a CPI Policy on their automobile loan Account(s) that became effective between October 15, 2005 and September 30, 2016 in accordance with the Settlement Allocation Plan, (2) requires Defendants to make additional payments to Settlement Class Members in accordance with the Settlement Distribution Plan, and (3) gives the Court jurisdiction to enforce the terms of the Settlement. Additionally, the Settlement Class may be eligible for non-cash compensation under the Settlement, including credit bureau adjustments.

What are my options? As described in more detail in the Long Form Notice, Settlement Class Members have the following rights and options in this settlement:

 Do nothing and join the Settlement. If you are a member of the Settlement Class and do not take any action, you will join the Settlement, receive the benefits you are entitled to, and release your claims against Wells Fargo and National General related to any CPI policies described above.

 Exclude yourself. If you ask to be excluded from the Settlement, you will retain any rights you may have to sue Defendants, and can pursue your own legal claims against Defendants at your own expense. You will not be included in the Settlement Class. To request exclusion, you must timely file a letter with the Court on or before October 7, 2019. The Long Form Notice explains how to submit a request for exclusion.

 Object. Remain in the lawsuit, but write to the Court if you do not approve of any part of the Settlement. To object, you must timely file a letter with the Court and submit a copy to the claims administrator by October 7, 2019. The Long Form Notice explains how to submit an objection to the settlement.

On October 28, 2019, the Court will hold a hearing on whether to approve the Settlement, Class Counsel’s request for attorneys’ fees and expenses, and service awards for Class Representatives. The application for an award of attorneys’ fees and costs will be posted to the case website at www.WellsFargoCPISettlement.com. You may appear at the hearing, but you are not required to attend. You may hire your own attorney, at your own expense, to appear or speak for you at the hearing.

More details regarding the terms of the Settlement can be found in the Long Form Notice and Settlement Agreement posted at www.WellsFargoCPISettlement.com.

If you have questions, you may also contact the Settlement Administrator:

 Phone: 1-877-641-8815  Email: [email protected]  Postal Mail: Wells Fargo CPI Settlement, P.O. Box 4990, Portland, OR 97208-4990

2 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 41 of 65 Page ID #:5229

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3 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 42 of 65 Page ID #:5230

Attachment 4 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 43 of 65 Page ID #:5231 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 44 of 65 Page ID #:5232 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 45 of 65 Page ID #:5233 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 46 of 65 Page ID #:5234 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 47 of 65 Page ID #:5235 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 48 of 65 Page ID #:5236 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 49 of 65 Page ID #:5237 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 50 of 65 Page ID #:5238 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 51 of 65 Page ID #:5239 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 52 of 65 Page ID #:5240 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 53 of 65 Page ID #:5241 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 54 of 65 Page ID #:5242 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 55 of 65 Page ID #:5243 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 56 of 65 Page ID #:5244 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 57 of 65 Page ID #:5245

Attachment 5 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 58 of 65 Page ID #:5246

Wells Fargo CPI ‐ Sponsored Search Keywords Wells Fargo CPI Settlement Forced Placed Insurance Settlement Wells Fargo Settlement Wells Fargo Insurance Settlement Wells Fargo Auto Settlement Wells Fargo Auto Loan Settlement Auto Loan Settlement Auto Loan Insurance Settlement CPI Settlement Wells Fargo CPI Class Action Forced Placed Insurance Class Action Wells Fargo Class Action Wells Fargo Insurance Class Action Wells Fargo Auto Class Action Wells Fargo Auto Loan Class Action Auto Loan Class Action Auto Loan Insurance Class Action CPI Class Action Wells Fargo CPI Class Action Settlement Forced Placed Insurance Class Action Settlement Wells Fargo Class Action Settlement Wells Fargo Insurance Class Action Settlement Wells Fargo Auto Class Action Settlement Wells Fargo Auto Loan Class Action Settlement Auto Loan Class Action Settlement Auto Loan Insurance Class Action Settlement CPI Class Action Settlement Wells Fargo CPI Lawsuit Forced Placed Insurance Lawsuit Wells Fargo Lawsuit Wells Fargo Insurance Lawsuit Wells Fargo Auto Lawsuit Wells Fargo Auto Loan Lawsuit Auto Loan Lawsuit Auto Loan Insurance Lawsuit CPI Lawsuit Wells Fargo CPI Litigation Forced Placed Insurance Litigation Wells Fargo Litigation Wells Fargo Insurance Litigation Wells Fargo Auto Litigation Wells Fargo Auto Loan Litigation Auto Loan Litigation Auto Loan Insurance Litigation CPI Litigation Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 59 of 65 Page ID #:5247

Attachment 6 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 60 of 65 Page ID #:5248 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 61 of 65 Page ID #:5249 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 62 of 65 Page ID #:5250 Case 8:17-ml-02797-AG-KES Document 294-4 Filed 08/30/19 Page 63 of 65 Page ID #:5251

Attachment 7 8/12/2019 Case 8:17-ml-02797-AG-KESCourt To Notify Wells Fargo Document Auto Loan Customers 294-4 About Filed A Class 08/30/19 Action Settlement Page Related 64 Toof Insurance 65 Page Charges ID #:5252

Court To Notify Wells Fargo Auto Loan Customers About A Class Action Settlement Related To Insurance Charges

NEWS PROVIDED BY The United States District Court for the Central District of California  Aug 12, 2019, 16:00 ET

SANTA ANA, Calif., Aug. 12, 2019 /PRNewswire/ -- A noti. cation program began today, as ordered by the United States District Court for the Central District of California (the "Court"), to alert consumers about a proposed class action settlement in a lawsuit known as In re Wells Fargo Collateral Protection Insurance Litigation, Case No. 8:17-ML-2797-AG-KES, which is currently pending against Wells Fargo Bank, N.A. ("Wells Fargo") and National General Insurance Company ("National General") (collectively "Defendants").

The proposed settlement resolves a lawsuit originally led on July 30, 2017, which alleges that between October 15, 2005 and September 30, 2016, Defendants unlawfully placed collateral protection insurance ("CPI") policies on automobile loan accounts. CPI is a type of insurance that Wells Fargo purchased from National General to cover potential damage to vehicles that served as collateral for Wells Fargo auto loans. The lawsuit alleges, among other things, that the CPI policies that Defendants placed on Settlement Class Members' accounts were duplicative, unnecessary, and overpriced.

Under the Settlement, Defendants will distribute at least $393.5 million to Settlement Class Members pursuant to an agreed-upon "Settlement Allocation Plan" and "Settlement Distribution Plan."

The Settlement Class is dened as Wells Fargo Dealer Services ("WFDS") Customers who had a CPI Policy placed on their Account(s) that became effective at any time between October 15, 2005 and September 30, 2016 and Wells Fargo Auto Finance ("WFAF") Customers who had a CPI Policy placed on their Account(s) that became effective at any time between February 2, 2006 and September 1, 2011. The denition of "Class" and "Settlement Class" excludes Non-Compensable Flat Cancels, as dened in Exhibit A to the Settlement Agreement, which is available at www.WellsFargoCPISettlement.com.

Notices will be sent to Settlement Class Members and are scheduled to appear in a national online notice campaign leading up to a hearing on October 28, 2019, when the Court will consider whether to grant nal approval to the settlement.

The Court has appointed the following law rms to represent the Settlement Class: Baron & Budd, P.C. in Encino, California; Robins Kaplan LLP in Los Angeles, California; Casey Gerry Schenk Francavilla Blatt & Peneld, LLP in San Diego, California; Gibbs Law Group LLP in Oakland California; Levin Sedran & Berman in Philadelphia, Pennsylvania; and, Weitz & Luxenberg, P.C. in Detroit, Michigan.

Those affected by this Settlement can ask to be excluded from, or object to, the Settlement and its terms. The deadline for exclusions and objections is October 7, 2019.

https://www.prnewswire.com/news-releases/court-to-notify-wells-fargo-auto-loan-customers-about-a-class-action-settlement-related-to-insurance-char… 1/2 A8/12/2019 toll-freeCase number, 8:17-ml-02797-AG-KES 1-877-641-8815,Court To Notify has Wells been Fargo established, Document Auto Loan Customers along 294-4 with About aFiled Awebsite, Class 08/30/19 Action www.WellsFargoCPISettlement.com, Settlement Page Related 65 Toof Insurance 65 Page Charges ID where important case documents may be obtained. Those affected #:5253 may also write to Wells Fargo CPI Class Action Settlement, P.O. Box 4990, Portland, OR 97208-4990 or send an email to [email protected].

SOURCE The United States District Court for the Central District of California

Related Links http://www.WellsFargoCPISettlement.com

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