Manulife Investment Management (North America) Limited

Allegations: THE MANUFACTURERS LIFE INSURANCE COMPANY ALLOWED RESTRICTED AGENTS TO ACT WHILE NOT HOLDING A VALID CERTIFICATE OF AUTHORITY CONTRARY TO SECTION 452(5) OF THE INSURANCE ACT (ALBERTA) AND COMPENSATING AN UNLICENSED RESTRICTED INSURANCE AGENT CONTRARY TO THE PROVISIONS OF SECTION 499(1) OF THE INSURANCE ACT (ALBERTA). Status: Final Sanction Detail: THE ALBERTA TREASURY BOARD AND FINANCE ISSUED AN ADMINISTRATIVE PENALTY OF $5,000 CAD AGAINST THE MANUFACTURERS LIFE INSURANCE COMPANY. THE $5,000 CAD ADMINISTRATIVE PENALTY WAS PAID ON FEBRUARY 2, 2018. Summary: THE MANUFACTURERS LIFE INSURANCE COMPANY ALLOWED RESTRICTED AGENTS TO ACT WHILE NOT HOLDING A VALID CERTIFICATE OF AUTHORITY CONTRARY TO SECTION 452(5) OF THE INSURANCE ACT (ALBERTA) AND COMPENSATING AN UNLICENSED RESTRICTED INSURANCE AGENT CONTRARY TO THE PROVISIONS OF SECTION 499(1) OF THE INSURANCE ACT (ALBERTA). AS A RESULT OF THE NONCOMPLIANCE, THE MANUFACTURERS LIFE INSURANCE COMPANY HAS BEEN ISSUED AN ADMINISTRATIVE PENALTY OF $5,000 CAD BY ALBERTA TREASURY BOARD AND FINANCE.

Allegations: THE MANUFACTURERS LIFE INSURANCE COMPANY DISTRIBUTED HOSPITAL INSURANCE POLICIES TO SEARS CUSTOMERS THROUGH PERSONS WHO WERE NOT LICENSED WITH THE AUTORITE DES MARCHES FINANCIERS FOR THIS PURPOSE, THUS CONTRAVENING SECTIONS 461,462,470 AND 491 OF THE ACT RESPECTING THE DISTRIBUTION OF FINANCIAL PRODUCTS AND SERVICES AS WELL AS SECTION 406.1 OF THE ACT RESPECTING INSURANCE. Status: Final Sanction Detail: THE AUTORITE DES MARCHES FINANCIERS ISSUED AN ADMINISTRATIVE PENALTY OF $350,000 CAD AGAINST THE MANUFACTURERS LIFE INSURANCE COMPANY. THE $350,000 CAD ADMINISTRATIVE PENALTY WAS PAID ON FEBRUARY 12, 2018. Summary: THE MANUFACTURERS LIFE INSURANCE COMPANY DISTRIBUTED HOSPITAL INSURANCE POLICIES TO SEARS CUSTOMERS THROUGH PERSONS WHO WERE NOT LICENSED WITH THE AUTORITE DES MARCHES FINANCIERS FOR THIS PURPOSE, THUS CONTRAVENING SECTIONS 461,462,470 AND 491 OF THE ACT RESPECTING THE DISTRIBUTION OF FINANCIAL PRODUCTS AND SERVICES AS WELL AS SECTION 406.1 OF THE ACT RESPECTING INSURANCE. THE MANUFACTURERS LIFE INSURANCE COMPANY AGREES TO PAY THE AUTORITE DES MARCHES, UPON EXECUTION OF THE AGREEMENT, THE AMOUNT OF $350,000 CAD AS ADMINISTRATIVE PENALTY FOR NOT HAVING FOLLOWED SOUND COMMERCIAL PRACTICES DURING THE COURSE OF THE DISTRIBUTION OF THE SEARS HOSPITAL PLAN.

Allegations: PURSUANT TO A MARKET CONDUCT EXAMINATION, THE STATE OF CONNECTICUT INSURANCE DEPARTMENT ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH STATUTORY REQUIREMENTS RELATED TO PRODUCER APPOINTMENTS. Status: Final Sanction Detail: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000. Summary: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000.

Allegations: UNAUTHORIZED AGENTS IN THE PROVINCE OF ALBERTA Status: Final Sanction Detail: PENALTY OF $5000.00 (CAD) AFTER REACHING A DETERMINATION THAT MLI CONTRAVENED SECTIONS 452(5) (INSURANCE AGENTS CERTIFICATE) (DEALING WITH UNAUTHORIZED INSURANCE AGENTS) OF THE PROVINCE OF ALBERTA INSURANCE ACT. Summary: MLI PAID THE PENALTY AND HAS PUT CONTROLS IN PLACE TO PREVENT FURTHER INCIDENTS.

Allegations: JOHN HANCOCK LIFE AND HEALTH INSURANCE COMPANY IS FINALIZING A CONSENT ORDER WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) REGARDING A SYSTEM ERROR IT SELF-DISCLOSED IN 2019 AND THAT CAUSED THE PREMATURE EXHAUSTION OF 155 LONG TERM CARE POLICIES THAT WERE PART OF THE NEW YORK STATE PARTNERSHIP FOR LONG-TERM CARE PROGRAM (THE "PROGRAM"). THE PROGRAM COMBINES LONG TERM CARE INSURANCE OFFERED BY PRIVATE INSURANCE COMPANIES AND MEDICAID. THE COMPANY HAS PROPOSED A REMEDIATION PLAN WHICH IT IS REVIEWING WITH THE NYDFS AND THE NY DEPARTMENT OF HEALTH. Status: Final Sanction Detail: NEW YORK'S OFFICE OF THE MEDICAID INSPECTOR GENERAL (OMIG) PROVIDED THE COMPANY WITH A STIPULATION OF SETTLEMENT ON JULY 8, 2022, IN WHICH THE COMPANY WOULD AGREE TO A SETTLEMENT AMOUNT OF "$2,228,031.39 WHICH INCLUDES ALL AMOUNTS DUE AND OWED". THE COMPANY HAS SIGNED OMIG'S STIPULATION. PAYMENT OF $2,228,031.39 IS EXPECTED TO BE MADE WITHIN 30 DAYS FROM OMIG'S COUNTERSIGNATURE. THE AMOUNT OF $2,228,031.39 REPRESENTS THE TOTAL THAT MEDICAID REIMBURSED THAT OTHERWISE WOULD HAVE BEEN COVERED BY THE JOHN HANCOCK POLICIES HAD THEY NOT BEEN PREMATURELY TERMINATED DUE TO OUR ERROR. THE NYDFS CONSENT ORDER WAS SIGNED BY JH ON AUGUST 3, 2022 AND WE ARE AWAITING COUNTERSIGNATURE BY NYDFS, AT WHICH TIME JH WILL PAY THE $2.5M FINE AND BEGIN REMEDIATING POLICYHOLDERS. Summary: NEW YORK'S OFFICE OF THE MEDICAID INSPECTOR GENERAL (OMIG) PROVIDED THE COMPANY WITH A STIPULATION OF SETTLEMENT ON JULY 8, 2022, IN WHICH THE COMPANY WOULD AGREE TO A SETTLEMENT AMOUNT OF "$2,228,031.39 WHICH INCLUDES ALL AMOUNTS DUE AND OWED". THE COMPANY HAS SIGNED OMIG'S STIPULATION. PAYMENT OF $2,228,031.39 IS EXPECTED TO BE MADE WITHIN 30 DAYS FROM OMIG'S COUNTERSIGNATURE. THE AMOUNT OF $2,228,031.39 REPRESENTS THE TOTAL THAT MEDICAID REIMBURSED THAT OTHERWISE WOULD HAVE BEEN COVERED BY THE JOHN HANCOCK POLICIES HAD THEY NOT BEEN PREMATURELY TERMINATED DUE TO OUR ERROR. THE NYDFS CONSENT ORDER WAS SIGNED BY JH ON AUGUST 3, 2022 AND WE ARE AWAITING COUNTERSIGNATURE BY NYDFS, AT WHICH TIME JH WILL PAY THE $2.5M FINE AND BEGIN REMEDIATING POLICYHOLDERS.

Allegations: THE STATE OF WASHINGTON INSURANCE OFFICE OF THE INSURANCE COMMISSIONER IDENTIFIED A VIOLATION OF RCW 48.23A.080(8) IN WHICH JOHN HANCOCK LIFE INSURANCE COMPANY (USA) FAILED TO PROMPTLY NOTIFY THE COMMISSIONER UPON CHANGES TO THE ILLUSTRATION ACTUARY. Status: Final Sanction Detail: THE STATE OF WASHINGTON INSURANCE OFFICE OF THE INSURANCE COMMISSIONER IDENTIFIED A VIOLATION OF RCW 48.23A.080(8) IN WHICH JOHN HANCOCK LIFE INSURANCE COMPANY (USA) FAILED TO PROMPTLY NOTIFY THE COMMISSIONER UPON CHANGES TO THE ILLUSTRATION ACTUARY. A CONSENT ORDER WAS EXECUTED ON JULY 7 2022, WHICH INCLUDED A FINE OF $1,000. Summary: A CONSENT ORDER WAS EXECUTED ON JULY 7 2022, WHICH INCLUDED A FINE OF $1,000.

Allegations: PURSUANT TO A TARGETED MARKET CONDUCT EXAMINATION, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION INSURANCE DIVISION ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) FAILED TO COMPLY WITH RHODE ISLAND LAWS AND REGULATIONS RELATED TO THE OVERSIGHT OF REPLACEMENT TRANSACTIONS. Status: Final Sanction Detail: ON MAY 17, 2023, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY PROVIDING CORRECTIVE ACTION PLANS, WITHIN 120 DAYS (SEPTEMBER 14, 2023) AND 180 DAYS (NOVEMBER 13, 2023). THE COMPANY ALSO AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $95,000 WITHIN 30 DAYS TO RESOLVE THE ITEMS IDENTIFIED IN THE FINAL EXAM. Summary: ON MAY 17, 2023, THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY PROVIDING CORRECTIVE ACTION PLANS, WITHIN 120 DAYS (SEPTEMBER 14, 2023) AND 180 DAYS (NOVEMBER 13, 2023). THE COMPANY ALSO AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $95,000 WITHIN 30 DAYS TO RESOLVE THE ITEMS IDENTIFIED IN THE FINAL EXAM.

Allegations: A MARKET CONDUCT EXAM FOUND THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) VIOLATED REQUIREMENTS RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES FROM JANUARY 1, 2021, THROUGH DECEMBER 31, 2022. Status: Final Sanction Detail: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY IMPLEMENTING CORRECTIVE ACTION PLANS WITHIN 30 DAYS AND PAY AN ADMINISTRATIVE PENALTY OF $53,000. THE COMPANY PAID THE PENALTY ON MAY 10TH, 2024. Summary: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) AND ISSUED A FINE FOR $53,000 FOR VIOLATING PRACTICES RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES. THE EXAM RESULTED IN 78 EXCEPTIONS WITHIN THE CATEGORIES OF: PRODUCER TERMINATIONS, DELIVERY OF ILLUSTRATIONS, PRODUCER APPOINTMENTS, PRODUCER LICENSING AND PRODUCER KNOWLEDGE OR REPLACEMENTS.

Allegations: THE VIRGINIA BUREAU OF INSURANCE ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) IN CERTAIN INSTANCES VIOLATED THE CODE OF VIRGINIA, AND THE VIRGINIA ADMINISTRATIVE CODE, RELATING TO THE CONDITIONS OF A RATE INCREASE FOR A LONG-TERM CARE RATE INSURANCE POLICY BY FAILING TO FILE A NOTICE WITH THE STATE CORPORATION COMMISSION ON THE LONG-TERM CARE RATE INCREASE PRIOR TO USE. Status: Final Sanction Detail: SUBMITTED PAYMENT ON NOV 22, 2023 Summary: ON NOVEMBER 6, 2023, THE VIRGINIA BUREAU OF INSURANCE PROVIDED THE COMPANY WITH A SETTLEMENT OFFER, WHERE JHUSA WAS TO COMPLY WITH ACTION PLANS WITHIN 60 DAYS AND PAY A FINE OF $8,800. JHUSA SIGNED THE CONSENT ORDER AND SUBMITTED THE PAYMENT ON NOVEMBER 22, 2023.

Allegations: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. Status: Final Sanction Detail: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) SHALL PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON DECEMBER 6, 2019. Summary: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) WAS ORDERED TO PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON DECEMBER 6, 2019.