Cheryl L. Davis, AMCM, ACS, AIRC Associate Vice President, Corporate Compliance

October 30, 2020

Mr. Mark Duffy Principal Examiner, Market Conduct Division State of Connecticut Insurance Department P.O. Box 816 Hartford, Connecticut 06142

RE: Market Conduct Examination Survey of Crestbrook Insurance Company Docket MC 20-60

Mr. Duffy,

Please find the required Corrective Action Plan associated with the above-named matter.

If you have any questions or need additional assistance related to the information being provided, please feel free to contact me by email at [email protected] or via telephone at (614) 249-4580.

Sincerely,

Cheryl L. Davis Associate Vice President, Corporate Compliance

One Nationwide Plaza, 1-35-206 Tel: (614) 249-4580 Columbus, OH 43215 Email: [email protected]

Confidential, Proprietary and Trade Secret Crestbrook Insurance Company Docket MC 20-60, Corrective Action Response Oct 30, 2020 The executed Stipulation and Consent Order in the above-named matter called for a Company filed Corrective Action Plan by Nov 30, 2020. Below, please find the action taken associated with each statutory requirement.

a) Individual producers acting as agents of Respondent without required appointment b) Entity producers acting as agents of Respondent without required appointment

Company Response Regarding the above-referenced licensing-related issues: 1. A review of Connecticut appointments was completed to ensure all agents with access to the state and licensed product have a licensed and appointed producer in their agency. We could not associate a total of seven agencies with a producer. We have confirmed no Connecticut business was issued for these agencies and have turned off their access to the state/products. 2. A review of our practices and procedures has led to the removal of the User Management role from 1,200 of our Agency Partners. This role allowed agents to create user IDs / grant access to our policy administration session on behalf of their staff. Without this role, all parties requesting access to the system must submit new user applications to Nationwide Private Client. Nationwide associates are responsible for reviewing the applications and issuing user IDs appropriately, based on our Standard Operating Procedures. These procedures were provided in our original response. 3. We have modified access for 87 users, who were not licensed, to remove their authority to bind and/or issue policies. Their new role only allows them to service an existing account. 4. To further close any gaps, we completed a review of all 7,532 active users in our policy administration system to identify any users that may not have the proper authority. Any users who have bind / issue authority, and do not show as licensed, will be contacted and asked to complete a new user application to provide their credentials. If they do not return the application within 2 weeks of initial contact, or we find they are not licensed, their user access will be modified to service only, thus removing their binding authority. Our goal is to complete this process no later than 01/31/2021.

c) Individuals adjusting casualty claims without required license

Company Response Regarding the above-referenced licensing-related issues, we have undertaken safeguards to adhere to Connecticut licensing requirements which include:

Confidential, Proprietary and Trade Secret 1. Crestbrook leaders completed the Crestbrook license review in July 2020 and any needed Connecticut licenses were obtained by associates. 2. Claims Dispatchers were provided a list of licenses held by associate for proper assignments with the state they are licensed in. 3. A reminder will be communicated to leaders by January 31, 2021 to review the license dashboard for associate license status. 4. A review of the licensing dashboard will take place by March 31, 2021 to validate the license status for Crestbrook associates handling claims in Connecticut and will be completed annually by the end of the first quarter each year.

Confidential, Proprietary and Trade Secret