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)
- (a) State of Washington Office of Insurance Commissioner Consent Order No. 10-0041 regarding National General Insurance Company entered on March 17, 2010
- (b) Maryland Insurance Administration Order for Case no. MIA-2010-04-022 regarding National General Assurance Company
- (c) Texas Department of Insurance Order No. 10-0980 dated November 12, 2010 regarding National General Insurance Company
- (d) Maryland Insurance Administration Consent Order of May 2011 regarding National General Assurance Company
- (e) Missouri Division of Insurance Market Regulation forfeiture letter dated December 12, 2011, regarding National General Assurance Company, New South Insurance Company, and National General Insurance Company
- (f) New York State Department of Financial Services Stipulation No. 2013-0224-S regarding New South Insurance Company
- (g) State of Rhode Island and Providence Plantations Department of Business Regulation, Insurance Division, February 2014 Consent Agreement regarding National General Insurance Company
- (h) Delaware Insurance Commissioner Stipulation and Consent Order dated May 11, 2016 regarding National Health Insurance Company
- (i) State of Kansas Commissioner of Insurance Consent Agreement and Final Order Docket No. 4943-CO regarding National Health Insurance Company
- (j) State of Connecticut Insurance Department Docket MC 17-83 regarding Integon National Insurance Company
- (k) Official Order of the Texas Commissioner of Insurance regarding Integon Indemnity Corporation and Integon National Insurance Company
- (l) Louisiana Department of Insurance Regulatory Stipulation regarding Imperial Fire and Casualty Company effective December 4, 2017
- (m) State of California Insurance Commissioner Consent Agreement and Order File No. 2017-12 regarding Integon National Insurance Company dated October 18, 2017
- (n) Commonwealth of Virginia Bureau of Insurance forfeiture letter dated March 8, 2018
- (o) Official Order of the Texas Commissioner of Insurance regarding Integon Indemnity Corporation (TDI Enforcement File No. 15552)
- (p) State of Alabama Department of Insurance Consent Order Case no. C-2018-75FM regarding Century-National Insurance Company
- (q) Minnesota Commerce Department forfeiture letter File No. 52714 regarding MIC General Insurance Corporation dated June 6, 2018
- (r) Commonwealth of Virginia Bureau of Insurance forfeiture letter dated May 30, 2018, regarding Integon Casualty Insurance Company, Integon National insurance Company, and National General Insurance Company
- (s) Illinois Department of Insurance Market Conduct Executed Stipulation and Consent Order regarding Standard Property & Casualty Insurance Company
- (t) State of New York Department of Financial Services Stipulation No. 2013-0161-S regarding Integon National Insurance Company
- (u) New Jersey Department of Banking and Insurance Consent Order regarding New Jersey Skylands Insurance Association
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: