Proposed Acquisition of National Farmers Union Property and Casualty Company

Last Updated: July 25, 2019

Proposed Acquisition of Control of National Farmers Union Property and Casualty Company by Integon National Insurance Company, National General Holdings Corp., and Leah Karfunkel, individually, and as Trustee of the Michael Karfunkel Family 2005 Trust and the Leah Karfunkel 2016-NG GRAT

Integon National Insurance Company filed a Form A filing for the acquisition of control of National Farmers Union Property and Casualty Company dated December 5, 2018, which was received on December 7, 2018. The proposed buyer intends that the products and markets in which National Farmers Union Property and Casualty Company operates will remain substantially unchanged following the acquisition, except for integration over time into the National General Group's shared services environment. National Farmers Union Property and Casualty Company offers auto, homeowners, renters, farm, small commercial, health, and online business insurance, including insurance for rural residents and rural telephone and cable companies. The only line of business that would be discontinued in the event of the closing of the proposed acquisition is multi-peril crop insurance. The company is licensed in the District of Columbia and all U.S. states, except Florida.


Notations on Accessing Information

Financial information concerning individual insurance companies, including key annual statement pages, may be accessed on the Consumers Information Source section of the National Association of Insurance Commissioner' website at www.naic.org/cis.


Form A and List of Exhibits to the Form A

Cover letter to the Form A

Form A dated December 5, 2018

Correspondence:

Email to William J. Toman, Quarles & Brady LLP, from Michael Mancusi-Ungaro, OCI, dated April 12, 2019, with attached list of inquiries

Email to Michael Mancusi-Ungaro, OCI, from Susan Eylward, National General Vice President and Corporate Counsel, providing an advance electronic copy of the letter to Michael Mancusi-Ungaro, OCI, from Jeffrey Weissmann, General Counsel and Secretary, dated April 17, 2019, responding to the OCI's list of April 12, 2019 inquiries

Letter to Michael Mancusi-Ungaro, OCI, from Jeffrey Weissmann, General Counsel and Secretary, dated April 17, 2019, responding to the OCI's list of April 12, 2019 inquiries

Attachment 1 to April 17, 2019 letter: Karfunkel 2005 Family Trust Statements of Financial Condition as of December 31, 2016, December 31, 2017; and December 31, 2018 [CONFIDENTIAL]

Attachment 2 to April 17, 2019 letter: Leah Karfunkel 2016 – NG GRAT Balance Sheets as of December 31, 2016, December 31, 2017; and December 31, 2018 [CONFIDENTIAL]

Attachment 3 to April 17, 2019 letter: Michael and Leah Karfunkel Statement of Financial Condition as of December 31, 2014; Michael and Leah Karfunkel Statement of Financial Condition as of December 31, 2015; Leah Karfunkel Statement of Financial Condition as of December 31, 2016; Leah Karfunkel Statement of Financial Condition as of December 31, 2017; and Leah Karfunkel Statement of Financial Condition as of December 31, 2018 [CONFIDENTIAL]

Attachment 4 to April 17, 2019 letter: Consent decrees, stipulations and orders, or agreements relevant to the cases disclosed in responses to Biographical Affidavit Question 15 (c)

Attachment 5 to April 17, 2019 letter: The last four examination reports issued by the North Carolina Department of Insurance on Integon National Insurance Company

Attachment 6 to April 17, 2019 letter: Form F Enterprise Risk Reports by National General Holdings Corp. for 2015, 2016, 2017, and 2018 [CONFIDENTIAL]

Attachment 7 to April 17, 2019 letter: National General Holding Corp.'s Information Security Risk Management Policy [CONFIDENTIAL]

Letter to the Michael Karfunkel 2005 Family Trust c/o Am Trust Financial Services, Inc., Attn. Barry Zyskind, from Dave Jones, California Insurance Commissioner, dated September 20, 2016

Hearing Documents: