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Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company Market Conduct Report Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company July 17,2019 Connecticut Insurance Department TABLE OF CONTENTS Page I. Introduction 1 A. Statutory Authority 1 B. Scope of Examination 1 C. Company Profile 1 D. Market Conduct Reports 2 E. Privacy of Consumer Financial Information 2 11. Items Examined 3 A. Operations and Management 3 B. Complaint Handling 5 C. Marketing and Sales 5 D. Producer Licensing 6 E. Policyholder Service 6 F. Underwriting and Rating 7 G. Claims 13 III. Summarv of Recommendations 19 IV. Acknowled gment 22 Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company I. INTRODUCTION A. Statutory Authority By authority granted under Section 38a-15 of the Connecticut General Statutes, this examination was conducted by Market Conduct examiners of the State of Connecticut Insurance Department at the companies' office located in Windsor, Connecticut. B. Scope of Examination From September 11, 2017 to on or about December 4, 2018, the Market Conduct Diyision of the Connecticut Insurance Department examined the market conduct practices of the companies using a sample period of January 1, 2016 through December 31, 2016. The examination was limited to Connecticut business. C. Company Profile Commenced State of Company Business Domicile Trumbull Insurance Company Noyember 6, 1986 CT Sentinel Insurance Company March 6, 1999 CT Hartford Accident & Indemnity August 12, 2013 CT Property Casualty Insurance May 4, 1989 IN Company of Hartford Hartford Casualty December 1, 1929 IN Insurance Company Direct premiums written as of December 31, 2017 are as follows: Connecticut Total Trumbull Insurance Company 97,902,873 1,215,010,402 Sentinel Insurance Company 67,603,150 1,522,044,375 Hartford Accident & Indemnity 24,124,772 744,427,802 Property Casualty Insurance Company of Hartford 24,682,615 839,595,317 Hartford Casualty Insurance Company 42,400,737 1,105,433,558 Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company D. Market Conduct Reports The examiners generated a listing of market conduct examination reports using National Association of Insurance Commissioners' I-Site. This information was used to request market conduct examination reports from the companies. The examiners obtained copies of all relevant market conduct examination reports which had been issued to the companies during the three (3) years preceding the examination. The reports were reviewed to identify any recommendations that had been made by the respective Insurance Departments and to determine whether the companies had taken appropriate corrective action in response to those recommendations. E. Privacy of Consumer Financial Information Standard 1: The companies have adequate procedures in place for the protection of consumer financial information. The companies appear to be in compliance. Standard 2: The companies provide each consumer with an initial privacy notice in accordance with statutes, rules and regulations. The companies appear to be in compliance. Standard 3: The companies provide each consumer with an annual privacy notice in accordance with statutes, rules and regulations but at a minimum annually. The companies appear to be in compliance. Standard 4: The companies provide each consumer with an opt out notice in accordance with statutes, rules and regulations. The companies appear to be in compliance. Standard 5: The companies provide each consumer with a revised privacy notice in accordance with statutes, rules and regulations. The companies appear to be in compliance. Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company Standard 6: All notices are provided in the required timeframe so as to minimize any improper intrusion into the privacy of consumers. The companies appear to be in compliance. Standard 7: The companies comply with all requirements for the disclosure of nonpublic personal financial information to nonaffiliated third parties so as to minimize any improper intrusion into the privacy of consumei^. The companies appear to be in compliance. Standard 8: The companies comply with all requirements for the disclosure and redisclosure of nonpublic personal financial information so as to minimize any improper intrusion into the privacy of consumers. The companies appear to be in compliance. Standard 9: The companies have procedures for the sharing of consumer account numbers so as to minimize any improper intrusion into the privacy of consumers. The companies appear to be in compliance. 11. ITEMS EXAMINED A. Operations and Management Standard 1: The companies have an up-to-date, valid internal or external audit program. The examiners reviewed the Hartford internal audit policy manual. Various types of audits are performed: full audits, limited scope, advisory, compliance and special project audits. Standard 2: The companies have appropriate controls, safeguards and procedures for protecting the integrity of computer information. The Hartford's Information Protection Plan has a comprehensive set of security policies and standards based on (ISO)27001-2013 which specifies the requirements for establishing, implementing, maintaining and continually improving information security management and complies with federal and state data security regulations and to protect information. The Hartford implements many levels and forms of encryption to ensure confidentiality, integrity and availability of sensitive information. Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company Standard 3: The companies have an antifraud plan in place. The examiners reviewed the Hartford Financial Services Group Fraud Plan. The SIU unit began in 1979 and has grown substantially since to its current staff of sixty (60) investigators. The main goal of the unit is prevention of both premium and claim fraud. During the sample period, a total of 251 Automobile and GL cases and 133 Property cases were referred to the S.I.U. The documentation included a note that they do not track the number of prosecutions and convictions. It is the Hartford's policy, however, when appropriate, to report fraud and theft to law enforcement authorities and prosecute. Standard 4: The companies have a valid disaster recovery plan. The Hartford's Business Resilience Program was reviewed. The goals and objectives of the program are extensive and involve recovery from many different scenarios. Detailed plans are in place should a disaster of many types occur. The companies appear to have adequate plans in place. Standard 5: The companies adequately monitor the activities of the managing general agents. The companies do not have managing general agents. Standard 6: The companies' contract with managing general agents comply with applicable statutes, rules and regulations. See above. Standard 7: Records are adequate, accessible, consistent and orderly, and comply with State record retention requirements. The companies appear to be in compliance. Standard 8: The companies are licensed for the lines of business that are being written. The companies appear to be in compliance. Standard 9: The companies cooperate on a timely basis with examiners performing the examination. The companies appear to be in compliance. 4 Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company B. Complaint Handling Standard 1: All complaints are recorded in the required format on the companies' complaint register. The examiners reviewed the companies' complaint register. All DOI complaints were recorded and the register format was in compliance with Connecticut Regulations. Standard 2: The companies have adequate complaint handling procedures in place and communicate such procedures to policyholders. The companies appear to be in compliance. Standard 3: The companies take adequate steps to finalize and dispose of the complaint in accordance with applicable statutes, rules and regulations, and contract language. The companies appear to be in compliance. Standard 4: The time frame within which the companies respond is in accordance with applicable statutes, rules and regulations. The companies appear to be in compliance. C. Marketing and Sales Standard 1: All advertising and sales materials are in compliance with applicable statutes, rules and regulations. The companies appear to be in compliance. Standard 2: The companies' internal producer training materials are in compliance with applicable statutes, rules and regulations. The companies appear to be in compliance. Standard 3: The companies' communications to producers are in compliance with applicable statutes, rules and regulations. The companies appear to be in compliance. 5 Trumbull Insurance Company Sentinel Insurance Company Hartford Accident and Indemnity Company Property Casualty Insurance Company of Hartford Hartford Casualty Insurance Company Standard 4: The companies' mass marketing of property and casualty
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