Pruco Securities, Llc

Allegations: THE ILLINOIS DEPARTMENT OF INSURANCE (IL DOI) CONDUCTED A ROUTINE MARKET CONDUCT EXAMINATION OF PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA(PICA), PRUDENTIAL LIFE INSURANCE COMPANY (PLAZ) AND PRUDENTIAL ANNUITIES AND LIFE ASSURANCE COMPANY(PALAC - NOTE PALAC WAS ACQUIRED BY FORTITUDE GROUP HOLDINGS, LLC ON APRIL 1, 2022). THE EXAMINATION FOCUSED ON THE INDIVIDUAL LIFE AND INDIVIDUAL ANNUITY LINES OF BUSINESS WRITTEN BY THE COMPANIES IN ILLINOIS FROM SEPTEMBER 1, 2019 TO AUGUST 31, 2020. THE IL DOI MADE LIMITED FINDINGS OF PROCEDURAL AND NOTIFICATION DEFICIENCIES BASED ON THE EXAM. Status: Final Sanction Detail: PRUDENTIAL WAS FINED $50,000 WHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE OF 05/13/2022. Summary: THE COMPANIES ENTERED INTO TWO STIPULATIONS AND CONSENT ORDERS WITH IL DOI WITHOUT ADMISSION AND REQUIRED PAYMENT OF FINES TOTALING $50,000.

Allegations: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUP UNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WERE MORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAIN GROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICA SELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARY PENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONG WITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017. Status: Final Sanction Detail: UNDER A CONSENT ORDER, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA ("PICA") WAS ORDERED TO PAY A $2,500 FINE FOR VIOLATING SOUTH DAKOTA INSURANCE CODE §58-55-36 BY COLLECTING AS PREMIUMS OR CHARGES FOR INSURANCE ANY SUM IN EXCESS OF OR LESS THAN THE PREMIUMS OR CHARGES SPECIFIED IN THE POLICY IN ACCORDANCE WITH THE APPLICABLE CLASSIFICATIONS AND RATES AS FILED WITH AND APPROVED BY THE DIRECTOR OF THE INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION. Summary: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUP UNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WERE MORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAIN GROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICA SELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARY PENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONG WITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Allegations: ROUTINE MARKET CONDUCT EXAMINATION BY THE MARYLAND INSURANCE ADMINISTRATION NOTED ISOLATED VIOLATIONS OF MARYLAND INSURANCE LAWS AND REGULATIONS RELATED TO A FAILURE TO COMPLY WITH TIMING AND CONTENT REQUIREMENTS APPLICABLE TO ADVERSE BENEFIT TERMINATION NOTICES AND FAILURE TO INCLUDE THE REQUIRED FRAUD DISCLOSURE STATEMENT ON CLAIM FORMS THAT ARE NOT INDICATIVE OF A PATTERN OR PRACTICE IN ADMINISTERING CLAIMS. Status: Final Sanction Detail: ON JUNE 30, 2015, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID AN ADMINISTRATIVE PENALTY OF $3,500. Summary: BASED UPON THE FINDINGS OF THE MARYLAND INSURANCE ADMINISTRATION MARKET CONDUCT EXAM, THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FOUND TO HAVE VIOLATED PROVISIONS OF THE MARYLAND INSURANCE LAWS AND REGULATIONS AND PAID AN ADMINISTRATIVE PENALTY OF $3,500 WHICH WAS PAID ON JUNE 30, 2015.

Allegations: THE MONTANA COMMISSIONER OF SECURITIES AND INSURANCE NOTED THAT THE PRUDENTIAL INSURANCE COMPANY OF AMERICA HAD PROVIDED MARITAL RATHER THAN HOUSEHOLD OR PARTNER DISCOUNTS IN CERTAIN LONG TERM CARE INSURANCE FORMS AND RATES. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PAID A FINE OF $5,000 ON JULY 28, 2015. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AGREED TO SETTLE THE MONTANA COMMISSIONER OF SECURITIES AND INSURANCE'S INVESTIGATION AND ALLEGATIONS RELATING TO IMPROPER PROVISION OF LONG TERM CARE INSURANCE DISCOUNTS AND AGREED TO PAY A FINE OF $5,000 WHICH WAS PAID ON JULY 28, 2015.

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA (PICA) HELD A SWEEPSTAKES IN SEPTEMBER 2022 WHERE THE PRIZE WAS A FULLY PAID $25,000 WHOLE LIFE INSURANCE POLICY, WHICH WAS OPEN TO WASHINGTON CONSUMERS, AND WITHOUT ANY REQUIREMENT TO PURCHASE/RENEW OR RECEIVE SOLICITATION FROM PICA OR ANY AFFILIATE. THE WASHINGTON OFFICE OF THE INSURANCE Status: Final Sanction Detail: THE WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER ISSUED A FINAL CONSENT ORDER ON MARCH 5, 2024, STATING THIS ACTION VIOLATED STATE LAW AND IMPOSED A MONETARY PENALTY OF $45,000. THE PENALTY WAS PAID ON MARCH 20, 2024. Summary: ***DUPLICATE ENTRY***THIS IAR WAS ALREADY ENTERED IN WEBCRD ON THE SAME DATE ON MARCH 5, 2024, A CONSENT ORDER BETWEEN WA OIC AND PICA WAS EXECUTED. A MONETARY PENALTY OF $45,000 WAS ASSESSED AND PAID BY PICA ON MARCH 20, 2024.

Allegations: PENNSYLVANIA INSURANCE DEPARTMENT ALLEGES VIOLATIONS OF: 40 P.S. § 323.3(A) WITH RESPECT TO MAINTAINING CERTAIN RECORDS; 40 P.S. §§ 1171.5(A), 1171.5(A)(1)(I), AND 1171.5(A)(7)(II) WITH RESPECT TO AN ERROR AND OMISSION REGARDING AND RESPONSE TIMES TO, CERTAIN CUSTOMER COMPLAINTS CONSTITUTING AN "UNFAIR METHOD OF COMPETITION" OR "UNFAIR OR DECEPTIVE ACT OR PRACTICE"; AND 31 PA. CODE § 146.5(A) CONSTITUTING FAILURES TO ACKNOWLEDGE CERTAIN CLAIMS WITHIN 10 WORKING DAYS. Status: Final Sanction Detail: UNDER A CONSENT ORDER, "THE PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA" [SIC] (PICA) WAS ORDERED TO PAY A $45,000 FINE AND CEASE AND DESIST FURTHER VIOLATIONS OF 40 P.S. § 323.3(A); 40 P.S. §§ 1171.5(A), 1171.5(A)(1)(I), AND 1171.5(A)(7)(II); AND 31 PA. CODE § 146.5(A). AS PART OF THE CONSENT ORDER, PICA IS TO UNDERTAKE TO COMPLY WITH PENNSYLVANIA INSURANCE DEPT RECOMMENDATIONS PROVIDED IN A REPORT ACCOMPANYING THE CONSENT ORDER AND PROVIDE SUCH REPORT AND ACCOMPANYING ORDERS TO EACH DIRECTOR. THE $45,000 PAYMENT AND AFFIDAVIT STATING THAT PICA WILL PROVIDE THE REPORT AND ACCOMPANYING ORDERS TO ITS DIRECTORS MUST BE PROVIDED TO THE INSURANCE DEPT. WITHIN 30 DAYS OF THE DATE OF THE CONSENT ORDER. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PICA CONSENTED TO AN ORDER BASED ON ALLEGATIONS THAT IT VIOLATED 40 P.S. § 323.3(A) WITH RESPECT TO MAINTAINING CERTAIN RECORDS; 40 P.S. §§ 1171.5(A), 1171.5(A)(1)(I), AND 1171.5(A)(7)(II) WITH RESPECT TO AN ERROR AND OMISSION REGARDING, AND RESPONSE TIMES TO, CERTAIN CUSTOMER COMPLAINTS CONSTITUTING AN "UNFAIR METHOD OF COMPETITION" OR "UNFAIR OR DECEPTIVE ACT OR PRACTICE"; AND 31 PA. CODE § 146.5(A) CONSTITUTING FAILURES TO ACKNOWLEDGE CERTAIN CLAIMS WITHIN 10 WORKING DAYS. PICA WAS ORDERED TO CEASE AND DESIST FURTHER VIOLATIONS, PAY A FINE OF $45,000, AND UNDERTAKE TO COMPLY WITH INSURANCE DEPARTMENT RECOMMENDATIONS PROVIDED IN A REPORT ACCOMPANYING THE CONSENT ORDER AND PROVIDE SUCH REPORT AND ACCOMPANYING ORDERS TO EACH DIRECTOR. THE $45,000 PAYMENT AND AFFIDAVIT STATING THAT PICA WILL PROVIDE THE REPORT AND ACCOMPANYING ORDERS TO ITS DIRECTORS MUST BE PROVIDED TO THE INSURANCE DEPT. WITHIN 30 DAYS OF THE DATE OF THE CONSENT ORDER.

Allegations: ON DECEMBER 23, 2020, PRUCO SECURITIES, LLC ("PRUCO") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") RESULTING IN THE SEC ISSUING AN ADMINISTRATIVE ORDER (THE "ORDER"). PRUCO CONSENTED TO THE ENTRY OF THE ORDER, WHICH FOUND THAT PRUCO VIOLATED SECTIONS 206(2) AND 206(4), AND RULE 206(4)-7 THEREUNDER, OF THE ADVISERS ACT IN CONNECTION WITH PRUCO'S WRAP FEE PROGRAMS, IN WHICH CLIENTS PAY AN ALL-INCLUSIVE FEE FOR ASSET MANAGEMENT AND TRADE EXECUTION. THE ORDER FOUND THAT, BEGINNING IN JANUARY 2014, PRUCO AT VARIOUS TIMES BREACHED ITS FIDUCIARY DUTY TO ITS CLIENTS BY: (A) FAILING TO CONDUCT STATED MONITORING OF CLIENT ACCOUNTS TO DETERMINE WHETHER THE WRAP FEE PROGRAMS CONTINUED TO BE SUITABLE FOR CLIENTS; (B) CHARGING CERTAIN FEES ON SOME CLIENTS CONTRARY TO ITS DISCLOSURES; (C) RECOMMENDING THAT CLIENTS PURCHASE AND HOLD CERTAIN MUTUAL FUNDS AND MUTUAL FUND SHARE CLASSES THAT PAID PRUCO FEES PURSUANT TO RULE 12B-1 OF UNDER THE INVESTMENT COMPANY ACT OF 1940; (D) FAILING TO DISCLOSE THAT IT RECEIVED REVENUE SHARING PAYMENTS ON CLIENT INVESTMENTS PURSUANT TO AN AGREEMENT WITH ITS CLEARING FIRM, WHICH ALSO ALLOWED PRUCO TO AVOID PAYING CERTAIN TRANSACTION FEES FOR ITS CLIENTS' PURCHASES OF MUTUAL FUNDS; (E) RECOMMENDING BANK SWEEP VEHICLES FOR WHICH ITS CLEARING FIRM PAID PRUCO REVENUE SHARING; AND (F) VIOLATING ITS DUTY TO SEEK BEST EXECUTION FOR CERTAIN TRANSACTIONS BY SELECTING OR RECOMMENDING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO THE CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE OR BETTER PERFORMANCE. Status: Final Sanction Detail: THE ORDER CENSURED PRUCO AND DIRECTED PRUCO TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. ADDITIONALLY, THE ORDER REQUIRED PRUCO TO PAY DISGORGEMENT OF $12,690,585, PREJUDGMENT INTEREST OF $3,061,786, AND A CIVIL PENALTY IN THE AMOUNT OF $2,500,000, WHICH WERE PAID ON JANUARY 4, 2021. Summary: SOLELY FOR THE PURPOSE OF SETTLING THIS PROCEEDING, PRUCO CONSENTED TO THE ORDER, WITHOUT ADMITTING OR DENYING THE FINDINGS SET FORTH IN THE ORDER. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Allegations: ON APRIL 20, 2017, PRUCO SECURITIES, LLC ENTERED INTO A STIPULATION AND CONSENT ORDER WITH THE ILLINOIS SECURITIES DEPARTMENT. THE DEPARTMENT ALLEGED THAT PRUCO FAILED TO REASONABLY SUPERVISE AND ENFORCE ITS SUPERVISORY SYSTEMS IN CONNECTION WITH CERTAIN SALES OF VARIABLE ANNUITIES IN ILLINOIS FROM 2013-2016, AND FAILED TO SUPERVISE IN CONNECTION WITH RESPONDING TO THE DEPARTMENT'S REGULATORY REQUESTS. PRUCO HAS AGREED TO A FINE OF $750,000, PLUS COSTS AND RESTITUTION TO IMPACTED CUSTOMERS. PRUCO SECURITIES PAID THE FINE ON APRIL 26, 2017. Status: Final Sanction Detail: PRUCO HAS AGREED TO A FINE OF $750,000, PLUS COSTS AND RESTITUTION TO IMPACTED CUSTOMERS. PRUCO SECURITIES PAID THE FINE ON APRIL 26, 2017.

Allegations: MAINE OFFICE OF SECURITIES ALLEGED THAT THE FIRM FAILED TO CONDUCT AN ON-SITE BRANCH OFFICE INSPECTION OF ITS MAINE BRANCH OFFICES IN 2022, IN VIOLATION OF MAINE ORDER 2021-12 AND RULE CHAPTER 504 (7)(4)(B). Status: Final Sanction Detail: N/A Summary: THE FIRM WAS FINED $2,500 WHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE OF 8/22/23. FIRM STATEMENT: THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING THE CONCLUSION OF LAW, TO THE FINDING THAT IT HAD FAILED TO CONDUCT AN ON-SITE BRANCH INSPECTION OF ITS REGISTERED BRANCHES IN MAINE IN 2022.

Allegations: ON SEPTEMBER 24, 2019, A CONSENT ORDER BETWEEN THE NY DEPARTMENT OF FINANCIAL SERVICES AND PICA WAS EXECUTED. THE MATTER RELATED TO THE INADEQUATE DISCLOSURES FOR DEFERRED-TO-IMMEDIATE ANNUITY REPLACEMENTS. A FINE WAS ASSESSED IN THE AMOUNT OF $35,000; RESTITUTION IS ESTIMATED TO BE $14,020. Status: Final Sanction Detail: N/A Summary: ON SEPTEMBER 24, 2019, A CONSENT ORDER BETWEEN THE NY DEPARTMENT OF FINANCIAL SERVICES AND PICA WAS EXECUTED. A FINE WAS ASSESSED IN THE AMOUNT OF $35,000; RESTITUTION IS ESTIMATED TO BE $14,020.

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AND THE OREGON DIVISION OF FINANCIAL REGULATION HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH CERTAIN NON-PRUDENTIAL INDIVIDUAL LIFE INSURANCE CUSTOMERS IN OREGON DID NOT RECEIVE IN A TIMELY MANNER ANNUAL STATEMENTS, WHICH WERE TO BE SENT BY A THIRD-PARTY ADMINISTRATOR. THIS OCCURRED IN 60 INSTANCES OVER A THREE-YEAR PERIOD FROM 2015 TO 2017. THE OREGON CUSTOMERS AT ISSUE HAVE LIFE INSURANCE POLICIES THAT ARE REINSURED AND ADMINISTERED BY PRUDENTIAL. PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDED THAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1). Status: Final Sanction Detail: PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDED THAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1). THE CIVIL PENALTY WAS RECEIVED BY THE OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES DIVISION OF FINANCIAL REGULATION ON 2/12/20. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AND THE OREGON DIVISION OF FINANCIAL REGULATION HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH CERTAIN NON-PRUDENTIAL INDIVIDUAL LIFE INSURANCE CUSTOMERS IN OREGON DID NOT RECEIVE IN A TIMELY MANNER ANNUAL STATEMENTS, WHICH WERE TO BE SENT BY A THIRD-PARTY ADMINISTRATOR. THIS OCCURRED IN 60 INSTANCES OVER A THREE-YEAR PERIOD FROM 2015 TO 2017. THE OREGON CUSTOMERS AT ISSUE HAVE LIFE INSURANCE POLICIES THAT ARE REINSURED AND ADMINISTERED BY PRUDENTIAL. PRUDENTIAL WAS ORDERED TO PAY A CIVIL PENALTY OF $30,000 ($5K OF WHICH WILL BE SUSPENDED PROVIDED THAT PRUDENTIAL MEETS THE CONDITIONS SPECIFIED IN THE ORDER) AND CEASE AND DESIST FROM VIOLATING OAR 836-051-0580(1).

Allegations: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED. PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED. PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PRUDENTIAL ANNUITIES LIFE ASSURANCE CORPORATION AND PRUCO LIFE INSURANCE COMPANY (COLLECTIVELY, "PRUDENTIAL") AND THE SOUTH DAKOTA DIVISION OF INSURANCE HAVE ENTERED INTO AN AGREEMENT TO RESOLVE A MATTER IN WHICH POSITIVE ACCOUNT VALUES WERE PROVIDED ON FIFTEEN (15) SOUTH DAKOTA ANNUITY CONTRACTS THAT WERE PREVIOUSLY CLOSED. PRUDENTIAL AGREED TO PAY A MONETARY PENALTY OF $2,500.

Allegations: DEPARTMENT'S EXAMINATION WAS CONDUCTED TO EVALUATE THE COMPANY'S COMPLIANCE WITH VARIOUS STATUTES AND REGULATIONS, PARTICULARLY RELATING TO GUARANTEED GROUP ANNUITY CONTRACTS. THE EXAMINATION REVEALED CERTAIN INSTANCES IN WHICH THE COMPANY'S PRACTICES MAY NOT HAVE ACCORDED WITH THE COMPANY'S PROCESSES AND PROCEDURES AND DID NOT COMPLY WITH PROVISIONS OF APPLICABLE STATUTES Status: Final Sanction Detail: PICA PAID THE ADMINISTRATIVE FINE ON 04/27/21 Summary: AS A RESULT OF THE DEPARTMENT'S EXAMINATION, PICA WILL TAKE MEASURES THAT ADDRESS CONCERNS RAISED BY THE DEPARTMENT. ALSO, PICA WAIVED ITS RIGHT TO A HEARING AND CONSENTED TO AN ADMINISTRATIVE FINE OF ONE MILLION AND TWO HUNDRED THOUSAND DOLLARS ($1,200,000) IN ORDER TO FULLY AND COMPLETELY RESOLVE ALL ISSUES ARISING FROM THE EXAMINATION;

Allegations: ALLEGATION THAT RESPONDENT TERMINATED THE LONG-TERM DISABILITY BENEFITS OF A CLAIMANT WITHOUT A REASONABLE BASIS, IN VIOLATION ON MINN. STAT. 72A.201, SUBD 8(2)(2014). Status: Final Sanction Detail: A CIVIL PENALTY IN THE AMOUNT OF $5,000 WAS PAID TO THE STATE OF MINNESOTA ON 12/22/2015. PRUDENTIAL WAS ORDERED TO CEASE AND DESIST ANY FURTHER VIOLATIONS OF MINN. STAT. 72A.201 (2014). Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA CONSENTED TO INFORMAL DISPOSITION OF A MATTER BASED ON AN ALLEGATION THAT PRUDENTIAL TERMINATED THE LONG-TERM DISABILITY BENEFITS OF A CLAIMANT WITHOUT A REASONABLE BASIS. BASED ON ITS FINDONGS, THE MINNESOTA DEPT. OF COMMERCE ENTERED AN ORDER FOR PRUDENTIAL TO PAY A $5,000 CIVIL PENALTY AND CEASE AND DESIST FROM VIOLATIONS OF MINN. STAT. 72A.201 (2014). THE PENALTY WAS PAID ON DECEMBER 22, 2015.

Allegations: THE COMPANY DID NOT PROVIDE A TIMELY AND COMPLETE RESPONSE TO AN INQUIRY FROM THE DIVISION OF INSURANCE. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA WAS FINED $500 AND A SANCTION OF $75. THIS WAS PAID ON 10/31/2018. Summary: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA DID NOT PROVIDE A TIMELY AND COMPLETE RESPONSE TO AN INQUIRY FROM THE COLORADO DIVISION OF INSURANCE.

Allegations: THE COMPANY DID NOT PROVIDE A TIMELY SUBMISSION OF AN ANNUAL REPORT TO THE NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY, DIVISION OF INSURANCE AS REQUIRED BY NRS 683A.08528(1) Status: Final Sanction Detail: $500 FINE PAID 7/10/2019 Summary: THE COMPANY DID NOT PROVIDE A TIMELY SUBMISSION OF AN ANNUAL REPORT TO THE NEVADA DEPARTMENT OF BUSINESS AND INDUSTRY, DIVISION OF INSURANCE AS REQUIRED BY NRS 683A.08528(1)

Allegations: THE CALIFORNIA DEPARTMENT OF INSURANCE DEPARTMENT CONDUCTED AN EXAMINATION OF PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA (PICA). THE EXAMINATION FOCUSED ON CLAIMS PROCESSING DURING THE PERIOD OF 07/01/2019 TO 06/30/2020. THE EXAMINATION REVEALED CERTAIN INSTANCES IN WHICH THE COMPANY'S PRACTICES MAY NOT HAVE ACCORDED WITH CALIFORNIA'S INTERPRETATIONS AND PROVISIONS OF APPLICABLE STATUTES. Status: Final Sanction Detail: THE PRUDENTIAL INSURANCE COMPANY OF AMERCIA WAS FINED $500,000 WHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE OF 11/27/2024 Summary: AS A RESULT OF THE DEPARTMENT'S EXAMINATION, PICA IMPLEMENTED MEASURES TO ADDRESS CONCERNS RAISED BY THE DEPARTMENT. ALSO,WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PICA WAIVED ITS RIGHT TO A HEARING AND CONSENTED TO AN MONETARY PENALITY OF FIVE HUNDRED THOUSAND DOLLARS ($500,000) IN ORDER TO FULLY AND COMPLETELY RESOLVE ALL ISSUES ARISING FROM THE EXAMINATION.

Allegations: THE PENNSYLVANIA INSURANCE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION OF PRUDENTIAL LIFE INSURANCE COMPANY OF AMERICA (PICA). THE EXAMINATION FOCUSED ON THE GROUP INSURANCE DISABILITY AND OTHER HEALTH LINES OF BUSINESS WRITTEN BY THE COMPANY IN PENNSYLVANIA FROM 01/01/2019 THROUGH 06/01/2022. THE EXAMINATION REVEALED CERTAIN INSTANCES IN WHICH THE COMPANY'S PRACTICES MAY NOT HAVE ACCORDED WITH PENNSYLVANIA'S INTERPRETATIONS AND PROVISIONS OF APPLICABLE STATUTES. Status: Final Sanction Detail: N/A Summary: AS A RESULT OF THE DEPARTMENT'S EXAMINATION, PICA WILL TAKE MEASURES THAT ADDRESS CONCERNS RAISED BY THE DEPARTMENT. ALSO,PICA WAIVED ITS RIGHT TO A HEARING AND CONSENTED TO AN ADMINISTRATIVE FINE OF TWENTY FIVE THOUSAND DOLLARS($25,000) IN ORDER TO FULLY AND COMPLETELY RESOLVE ALL ISSUES ARISING FROM THE EXAMINATION.