INSURANCE
BROKER ABUSE
What Is the Case
About?
Plaintiffs:
Santa Clara County
(through County Counsel
Ann Ravel),
San Francisco Unified
School District,
Tuolumne Joint Powers
Authority,
on behalf of themselves
and all other California
public entities who buy
insurance.
Defendants:
(three insurance
brokers)
1. Driver Alliant
Insurance Services Inc.
("Driver");
2. Keenan &
Associates ("Keenan");
3. Marsh & McLennan
Companies, Inc., and
Marsh USA, Inc.
("Marsh")
These are the primary
insurance brokers serving
California counties, schools,
and cities. The complaint
alleges that these brokers
have used their positions of
trust with their public sector
clients to obtain kick backs,
improper fees, and benefits
at the expense of their
clients.
What Remedies Does the
Lawsuit Seek?
1. To enjoin Defendants'
sales practices and order
commissions, payments,
kickbacks, and other
benefits restored to Plaintiffs
2. Temporary and
permanent injunctive relief
3. Restitution to the victims
4. Disgorgement of profits
from Defendants
5. Treble, double, punitive
and compensatory damages
6. Attorneys' fees, penalties
and cost of suit
For additional information
e-mail Scott Dickey or
Louise Renne or call (415)
678-3800
Complaint
County of Santa Clara vs.
Driver Alliant Insurance
Services, Inc., et al.
BROKER ABUSE
What Is the Case
About?
Plaintiffs:
Santa Clara County
(through County Counsel
Ann Ravel),
San Francisco Unified
School District,
Tuolumne Joint Powers
Authority,
on behalf of themselves
and all other California
public entities who buy
insurance.
Defendants:
(three insurance
brokers)
1. Driver Alliant
Insurance Services Inc.
("Driver");
2. Keenan &
Associates ("Keenan");
3. Marsh & McLennan
Companies, Inc., and
Marsh USA, Inc.
("Marsh")
These are the primary
insurance brokers serving
California counties, schools,
and cities. The complaint
alleges that these brokers
have used their positions of
trust with their public sector
clients to obtain kick backs,
improper fees, and benefits
at the expense of their
clients.
What Remedies Does the
Lawsuit Seek?
1. To enjoin Defendants'
sales practices and order
commissions, payments,
kickbacks, and other
benefits restored to Plaintiffs
2. Temporary and
permanent injunctive relief
3. Restitution to the victims
4. Disgorgement of profits
from Defendants
5. Treble, double, punitive
and compensatory damages
6. Attorneys' fees, penalties
and cost of suit
For additional information
e-mail Scott Dickey or
Louise Renne or call (415)
678-3800
Complaint
County of Santa Clara vs.
Driver Alliant Insurance
Services, Inc., et al.
Keenan & Associates
Keenan Solutions
Employee Benefits
Insurance brokerage
and consulting services
· Employee Benefits
Overview
· ConsumerAdvance
· Integrated Benefits
Keenan Financial
Services
Retirement Plan
Management and
Consulting Services
· Futuris
· SERP
· Elite Choice
· APPLE
· Envoy
Property & Casualty
Underwriting, technical,
administrative and
marketing services
· P&C Overview
· Super Pools
· Loss Control
Workers' Compensation
Providing self-insured,
fully-insured, and
excess insurance
services
· PRIME
· Claims Administration
· PRIME Advantage -
Schools
· PRIME Advantage -
Hospitals
· PRIME Plus MPN
Construction Services
Administrative Services
Maximize funds in
completing new
construction,
renovation or
modernization projects
· Labor Compliance
· SEWUP
Administrative Services
Providing expertise in
financial and
accounting reporting
for insurance activities
· SETECH
Employee Benefits
Insurance brokerage
and consulting services
· Employee Benefits
Overview
· ConsumerAdvance
· Integrated Benefits
Keenan Financial
Services
Retirement Plan
Management and
Consulting Services
· Futuris
· SERP
· Elite Choice
· APPLE
· Envoy
Property & Casualty
Underwriting, technical,
administrative and
marketing services
· P&C Overview
· Super Pools
· Loss Control
Workers' Compensation
Providing self-insured,
fully-insured, and
excess insurance
services
· PRIME
· Claims Administration
· PRIME Advantage -
Schools
· PRIME Advantage -
Hospitals
· PRIME Plus MPN
Construction Services
Administrative Services
Maximize funds in
completing new
construction,
renovation or
modernization projects
· Labor Compliance
· SEWUP
Administrative Services
Providing expertise in
financial and
accounting reporting
for insurance activities
· SETECH
Marsh & McLennan
sued in New York
(SDCOE)
sued in New York
(SDCOE)
"SIPIC, workman's
comp in Imperial
Valley, told lawyer to
get bids, he put in two
fake inflated bids and
one for Keenan, then
the two losers were
called and said they
didn't put in bids"
comp in Imperial
Valley, told lawyer to
get bids, he put in two
fake inflated bids and
one for Keenan, then
the two losers were
called and said they
didn't put in bids"
It appears that the Santa Clara v. Keenan & Associates lawsuit was settled.
It seems Santa Clara didn't want to clean up the system, it just wanted a
bigger portion of the gains.
It seems Santa Clara didn't want to clean up the system, it just wanted a
bigger portion of the gains.
Did San Francisco Schools and their fellow plaintiffs want to clean up the
school insurance industry?
school insurance industry?
Minutes
JPAs, insurance brokers, lawyers: who is profiting from school
litigation? Santa Clara v. Keenan & Associates
litigation? Santa Clara v. Keenan & Associates
Who is profiting from inflated insurance premiums in schools? Perhaps just
about everyone involved in school liability insurance.
Sometimes my commenters know more than I do about school insurance. A recent
comment caused me to do some research.
I found this:
(See clipping about public entities suing insurance
companies.)
County pushing suit alleging misdeeds in insurance industry
By Julie O'Shea
San Jose Recorder
Following New York's lead, Santa Clara County is suing several top insurance
brokerage firms, claiming they have duped customers out of millions through secret
"kickbacks" and other "lucrative" service deals.
"It's almost cartel-like," said the county's outside counsel, Louise Renne, a for-mer
San Francisco city attorney who wasbrought on board because of her extensive
experience with this type of litigation. "We believe that every public agency in the
state of California has been affected."
In a complaint filed in Alameda County Superior Court in November, Santa Clara is
alleging that industry giants Marsh & McLennan Cos., Driver Alliant Insurance Service
and Keenan & Associates are "steering" clients toward insurers that are offering
brokers undisclosed commissions, funded through insurance premiums.
"In the end," the complaint alleges,"clients paid more for less insurance, with
defendants siphoning off the difference to pad their bottom line..."
Here is part of what my commenter wrote:
"...Three insurance brokers namely Driver Alliant, Keenan and Associates and Marsh
& McLennan manage these super pools. These insurance brokers are being sued in
Alameda County where the allegations are for unlawful business practices, in violation
of California Business and Profession Code section 17200 et. seq. false and
misleading advertisement where they cream millions of dollars in public funds in
violation of Business and Profession Government Code Section 17500 et. seq.,
breach of fiduciary duty, illegal and secret kickbacks, steering premium dollars and
getting public agencies to purchase services at high rates.
"...Keenan and Associates has a “HYBRID SELF-INSURANCE and REINSURANCE”
[SDCOE has SELF-JPA where Keenan is also a member of this “Super Pool”] pooling
program for nearly 400 schools and community colleges.
"Keenan advertised for its Super Pool’s conference at Lake Tahoe as, “The Pudding
is in the Pooling,” in their invitations. Yes, the pudding is good, they are raking in
Millions of PUBLIC FUNDS through their billable hours...
"Keenan and Marsh and McLennan as the agents of California’s public entities have
a fiduciary duty to recommend the best coverage at the best price for its clients. They
are to provide independent, objective advice, and to put ‘their clients best interests’
ahead of their own. Keenan and Driver and Marsh and McLennan are hired to act as
consulting, billing/premium administration, and claims administration. Their duty is to
provide full disclosure, candor, and loyalty. Disclose the amounts of income;
Contingent Commissions Agreements and remuneration they receive form all
transactions to the public agencies they represent. Keenan has a policy where every
employee, associate and partner has to belong to several churches, golf clubs, non-
profit organizations and civic groups. This is how they create friendships with judges,
political figures, churches and organizations who look the other way...
"The agreements that the PUBLIC AGENCIES get pressured into signing with the JPA’
s have different names like: “Contingent Income Agreements” “Production Service
Agreements” “Volume Based Commission Agreements” “Profit-Sharing Commission
Agreements” “Commission Override Agreements” Premium Value Contingent
Commission Agreements” “Preferred Agency Agreements” and “Platinum Profit
Sharing Agreements.”
"These commissions create a blatant CONFLICT of INTEREST and a direct financial
interest for these brokers, JPA’s and preferred law firms. These commission and
preferred agreements cause CONFLICT of INTEREST, along with premium prices in
many cases with lower benefits. The insurance companies recoup the kickbacks paid
to marsh & Marsh and McLennan, Keenan and Driver by higher insurance prices
passed on to the public agencies. Whereby, suppressing competition in the market of
insurance.
"This is the reason why the PUBLIC AGENCIES in San Diego cannot get insurance
apart from the JPA’s. No insurance company can do business in California without
belonging to one of the three “insurance brokers.” The insurance brokers have
contractual agreements with certain JPA’s; like SDCOE SELF...
(End of quote of commenter to San Diego Education Report blog.)
It turns out that insurance companies were doing a lot of harm long before they
helped bring down the US economy in 2008 with their credit default derivatives. The
derivatives were too complicated and clever by half, a scheme to get rich quick while
promising that there would be no consequences. The government failed to regulate
these scams, pretending they weren't really insurance policies. Institutions began to
fail once it was discovered that the institutions didn't have any protection against
defaults because they were unknowingly insuring themselves.
Many local school districts belong to the San Diego County Office of Education-JPA.
Diane Crosier is the Executive Director of the SDCOE-JPA, and she works under the
direction of SDCOE Superintendent Randolph Ward and Asst. Supt. Lora Duzyk.
Crosier represents the SDCOE-JPA at a bigger JPA called SELF.
Diane Crosier then goes on to represent SELF when the other JPAs come together to
form what it is called a “super pool,” then she reports back (delivers instructions) to
SELF and SDCOE-JPA (which she herself directs).
This complete circle leaves me wondering who is in charge, the people at the bottom
or the people at the top?
Here is more from the comments:
This is how ALL insurance BROKERS operate and primarily why they are being sued
in Santa Clara. The SDCOE SELF-JPA is pretty much the same only it is operated by
insurance BROKER Marsh and McLennan with Diane Crosier being the
representative of SDCOE in the SELF SUPER POOL where Keenan is a member of
the self “SUPER POOL” as well.
Let’s look at the average amount of settlements? Just think of how much school
districts have to pay for the deductibles and in the end the VICTIMS get SCREWED.
now lets consider the hundreds of claims (about 95%) and lawsuits where the
VICTIMS get NO COMPENSATION.
SO IS THIS LEGAL? NOT ACCORDING TO THE LAWSUIT IN SANTA CLARA
http://www.socalrelief.org/minutes/2008/0115cccm.pdf
page 4
VIII. CLAIMS PAID REPORT
The following claims were paid and closed between September 01, 2007 through
November 31, 2007 and were presented to the Committee for final disposition:
CLAIM # DISTRICT NAME NAME AMOUNT PAID TYPE
5001-05-00014-01-02 N. Orange County SIA Cowley, Michael $ 30,301.00 Liability
5003-05-00012-01-06 SIRMA Lopez, Alejandra $ 70,000.00 Liability
5021-06-00007-01-02 Saddleback Valley USD Suarez, Elias $ 12,336.00 Liability
5022-06-00005-01-21 Vista USD Vista USD $ 13,866.00 Property
5022-06-00006-01-12 Vista USD Keav, Mandy $ 1,420.00 Liability
5022-06-00006-02-12 Vista USD 21st Century Ins. $ 5,774.00 Liability
5024-06-00005-01-12 Oceanside USD Dale, Rob $ 18,992.00 Liability
5024-06-00005-03-12 Oceanside USD Dale, Maria $ 12,000.00 Liability
5024-06-00005-07-13 Oceanside USD Oceanside USD $ 930.00 Liability
5029-06-00002-01-06 Perris UHSD Offerdahl, Suzanne $ 20,000.00 Liability
5002-07-00012-01-23 Beaumont USD Beaumont USD $ 13,227.00 Property
5002-07-00021-01-23 Val Verde USD Val Verde USD $ 22,828.00 Property
5002-07-00028-01-23 Riverside COE Riverside COE $ 18,371.00 Property
5002-07-00041-01-13 Hemet USD Hemet USD $ 24.00 Liability
5021-07-00007-01-21 Saddleback Valley Saddleback Valley $ 29,953.00 Property
5032-07-00002-01-23 Rialto USD Rialto USD $ 12,874.00 Property
5032-07-00003-01-23 Rialto USD Rialto USD $ 2,135.00 Property
5037-07-00003-01-27 William S. Hart USD William S. Hart USD $ 4,635.00 Property
COMMITTEE CONSIDERATION: Motion was made by Rick Majors, seconded by
Michael Bazan, and unanimously carried to ratify the final disposition of the above
stated claims.
October 24, 2008 12:53 PM
Anonymous said...
...The biggest suckers are Vista and Poway Unified School Districts, both Vista and
Poway have their school district representatives sitting on the Board of Directors for
Keenan.
Both Vista and Poway are the biggest moneymakers for Keenan. Some of their
policies have a $ 250,000.000 dollar deductible per incident. This means that every
lawsuit and tort has a $ 250,000.000 deductible. While in most cases the school
district can settle a claim for much less like$ 15,000.000 or $20K 50K and so forth.
Instead Daniel Shinoff comes in and demands that the school districts DENY EVERY
CLAIM. Why?
Yes because in ALL cases Keenan/ Shinoff make money on the deductible.
While say 95% of the lawsuits get dismissed the ones that proceed end up loosing
anyways. Very few lawsuits ever get an award to the victims. Most lawyers suing
public agencies get discouraged and drop their clients once they see the inner
connections in the courts.
So Keenan makes big $$$$$$$ with the deductibles 100 percent secure that they will
not have to pay any claims (at least they don’t count on paying any damages,)
because they have secured victories through their associations with politicians,
churches, non-profits and courts etc…
Yes they make a bundle in the deductibles but how about the premiums? Wow VUSD
and PUSD have the highest premiums! They pay something like .19 cents per student
daily attendance. In school districts like VUSD, PUSD, OUSD, EUSD, SMUSD, where
they can have up to 25, 000.000 students the premiums add up to a whole lot of
DOUGH!!!
Lets not forget about the smaller districts, all in all it all adds up to a whole lot of
$$$$$$$$$
October 24, 2008
about everyone involved in school liability insurance.
Sometimes my commenters know more than I do about school insurance. A recent
comment caused me to do some research.
I found this:
(See clipping about public entities suing insurance
companies.)
County pushing suit alleging misdeeds in insurance industry
By Julie O'Shea
San Jose Recorder
Following New York's lead, Santa Clara County is suing several top insurance
brokerage firms, claiming they have duped customers out of millions through secret
"kickbacks" and other "lucrative" service deals.
"It's almost cartel-like," said the county's outside counsel, Louise Renne, a for-mer
San Francisco city attorney who wasbrought on board because of her extensive
experience with this type of litigation. "We believe that every public agency in the
state of California has been affected."
In a complaint filed in Alameda County Superior Court in November, Santa Clara is
alleging that industry giants Marsh & McLennan Cos., Driver Alliant Insurance Service
and Keenan & Associates are "steering" clients toward insurers that are offering
brokers undisclosed commissions, funded through insurance premiums.
"In the end," the complaint alleges,"clients paid more for less insurance, with
defendants siphoning off the difference to pad their bottom line..."
Here is part of what my commenter wrote:
"...Three insurance brokers namely Driver Alliant, Keenan and Associates and Marsh
& McLennan manage these super pools. These insurance brokers are being sued in
Alameda County where the allegations are for unlawful business practices, in violation
of California Business and Profession Code section 17200 et. seq. false and
misleading advertisement where they cream millions of dollars in public funds in
violation of Business and Profession Government Code Section 17500 et. seq.,
breach of fiduciary duty, illegal and secret kickbacks, steering premium dollars and
getting public agencies to purchase services at high rates.
"...Keenan and Associates has a “HYBRID SELF-INSURANCE and REINSURANCE”
[SDCOE has SELF-JPA where Keenan is also a member of this “Super Pool”] pooling
program for nearly 400 schools and community colleges.
"Keenan advertised for its Super Pool’s conference at Lake Tahoe as, “The Pudding
is in the Pooling,” in their invitations. Yes, the pudding is good, they are raking in
Millions of PUBLIC FUNDS through their billable hours...
"Keenan and Marsh and McLennan as the agents of California’s public entities have
a fiduciary duty to recommend the best coverage at the best price for its clients. They
are to provide independent, objective advice, and to put ‘their clients best interests’
ahead of their own. Keenan and Driver and Marsh and McLennan are hired to act as
consulting, billing/premium administration, and claims administration. Their duty is to
provide full disclosure, candor, and loyalty. Disclose the amounts of income;
Contingent Commissions Agreements and remuneration they receive form all
transactions to the public agencies they represent. Keenan has a policy where every
employee, associate and partner has to belong to several churches, golf clubs, non-
profit organizations and civic groups. This is how they create friendships with judges,
political figures, churches and organizations who look the other way...
"The agreements that the PUBLIC AGENCIES get pressured into signing with the JPA’
s have different names like: “Contingent Income Agreements” “Production Service
Agreements” “Volume Based Commission Agreements” “Profit-Sharing Commission
Agreements” “Commission Override Agreements” Premium Value Contingent
Commission Agreements” “Preferred Agency Agreements” and “Platinum Profit
Sharing Agreements.”
"These commissions create a blatant CONFLICT of INTEREST and a direct financial
interest for these brokers, JPA’s and preferred law firms. These commission and
preferred agreements cause CONFLICT of INTEREST, along with premium prices in
many cases with lower benefits. The insurance companies recoup the kickbacks paid
to marsh & Marsh and McLennan, Keenan and Driver by higher insurance prices
passed on to the public agencies. Whereby, suppressing competition in the market of
insurance.
"This is the reason why the PUBLIC AGENCIES in San Diego cannot get insurance
apart from the JPA’s. No insurance company can do business in California without
belonging to one of the three “insurance brokers.” The insurance brokers have
contractual agreements with certain JPA’s; like SDCOE SELF...
(End of quote of commenter to San Diego Education Report blog.)
It turns out that insurance companies were doing a lot of harm long before they
helped bring down the US economy in 2008 with their credit default derivatives. The
derivatives were too complicated and clever by half, a scheme to get rich quick while
promising that there would be no consequences. The government failed to regulate
these scams, pretending they weren't really insurance policies. Institutions began to
fail once it was discovered that the institutions didn't have any protection against
defaults because they were unknowingly insuring themselves.
Many local school districts belong to the San Diego County Office of Education-JPA.
Diane Crosier is the Executive Director of the SDCOE-JPA, and she works under the
direction of SDCOE Superintendent Randolph Ward and Asst. Supt. Lora Duzyk.
Crosier represents the SDCOE-JPA at a bigger JPA called SELF.
Diane Crosier then goes on to represent SELF when the other JPAs come together to
form what it is called a “super pool,” then she reports back (delivers instructions) to
SELF and SDCOE-JPA (which she herself directs).
This complete circle leaves me wondering who is in charge, the people at the bottom
or the people at the top?
Here is more from the comments:
This is how ALL insurance BROKERS operate and primarily why they are being sued
in Santa Clara. The SDCOE SELF-JPA is pretty much the same only it is operated by
insurance BROKER Marsh and McLennan with Diane Crosier being the
representative of SDCOE in the SELF SUPER POOL where Keenan is a member of
the self “SUPER POOL” as well.
Let’s look at the average amount of settlements? Just think of how much school
districts have to pay for the deductibles and in the end the VICTIMS get SCREWED.
now lets consider the hundreds of claims (about 95%) and lawsuits where the
VICTIMS get NO COMPENSATION.
SO IS THIS LEGAL? NOT ACCORDING TO THE LAWSUIT IN SANTA CLARA
http://www.socalrelief.org/minutes/2008/0115cccm.pdf
page 4
VIII. CLAIMS PAID REPORT
The following claims were paid and closed between September 01, 2007 through
November 31, 2007 and were presented to the Committee for final disposition:
CLAIM # DISTRICT NAME NAME AMOUNT PAID TYPE
5001-05-00014-01-02 N. Orange County SIA Cowley, Michael $ 30,301.00 Liability
5003-05-00012-01-06 SIRMA Lopez, Alejandra $ 70,000.00 Liability
5021-06-00007-01-02 Saddleback Valley USD Suarez, Elias $ 12,336.00 Liability
5022-06-00005-01-21 Vista USD Vista USD $ 13,866.00 Property
5022-06-00006-01-12 Vista USD Keav, Mandy $ 1,420.00 Liability
5022-06-00006-02-12 Vista USD 21st Century Ins. $ 5,774.00 Liability
5024-06-00005-01-12 Oceanside USD Dale, Rob $ 18,992.00 Liability
5024-06-00005-03-12 Oceanside USD Dale, Maria $ 12,000.00 Liability
5024-06-00005-07-13 Oceanside USD Oceanside USD $ 930.00 Liability
5029-06-00002-01-06 Perris UHSD Offerdahl, Suzanne $ 20,000.00 Liability
5002-07-00012-01-23 Beaumont USD Beaumont USD $ 13,227.00 Property
5002-07-00021-01-23 Val Verde USD Val Verde USD $ 22,828.00 Property
5002-07-00028-01-23 Riverside COE Riverside COE $ 18,371.00 Property
5002-07-00041-01-13 Hemet USD Hemet USD $ 24.00 Liability
5021-07-00007-01-21 Saddleback Valley Saddleback Valley $ 29,953.00 Property
5032-07-00002-01-23 Rialto USD Rialto USD $ 12,874.00 Property
5032-07-00003-01-23 Rialto USD Rialto USD $ 2,135.00 Property
5037-07-00003-01-27 William S. Hart USD William S. Hart USD $ 4,635.00 Property
COMMITTEE CONSIDERATION: Motion was made by Rick Majors, seconded by
Michael Bazan, and unanimously carried to ratify the final disposition of the above
stated claims.
October 24, 2008 12:53 PM
Anonymous said...
...The biggest suckers are Vista and Poway Unified School Districts, both Vista and
Poway have their school district representatives sitting on the Board of Directors for
Keenan.
Both Vista and Poway are the biggest moneymakers for Keenan. Some of their
policies have a $ 250,000.000 dollar deductible per incident. This means that every
lawsuit and tort has a $ 250,000.000 deductible. While in most cases the school
district can settle a claim for much less like$ 15,000.000 or $20K 50K and so forth.
Instead Daniel Shinoff comes in and demands that the school districts DENY EVERY
CLAIM. Why?
Yes because in ALL cases Keenan/ Shinoff make money on the deductible.
While say 95% of the lawsuits get dismissed the ones that proceed end up loosing
anyways. Very few lawsuits ever get an award to the victims. Most lawyers suing
public agencies get discouraged and drop their clients once they see the inner
connections in the courts.
So Keenan makes big $$$$$$$ with the deductibles 100 percent secure that they will
not have to pay any claims (at least they don’t count on paying any damages,)
because they have secured victories through their associations with politicians,
churches, non-profits and courts etc…
Yes they make a bundle in the deductibles but how about the premiums? Wow VUSD
and PUSD have the highest premiums! They pay something like .19 cents per student
daily attendance. In school districts like VUSD, PUSD, OUSD, EUSD, SMUSD, where
they can have up to 25, 000.000 students the premiums add up to a whole lot of
DOUGH!!!
Lets not forget about the smaller districts, all in all it all adds up to a whole lot of
$$$$$$$$$
October 24, 2008
| San Diego Education Report |
| SDER |
San Diego
Education Report
Education Report
| SDER |
| SDER |
| SDER |
Are San Diego JPAs
being investigated?
"...Several publicly owned
insurance companies
have since reported
receiving subpoenas from
San Diego investigators..."
--San Diego Union Tribune
June 25, 2008
San Diego Union
Tribune's Jonathan
Sidener reports that the
US Attorney has fined an
insurance company for
paying a San Diego
insurance broker
"millions of dollars in
kickbacks disguised as
items such as requests for
proposals, communications
and enrollment fees. Those
fees were passed along to
policyholders."
being investigated?
"...Several publicly owned
insurance companies
have since reported
receiving subpoenas from
San Diego investigators..."
--San Diego Union Tribune
June 25, 2008
San Diego Union
Tribune's Jonathan
Sidener reports that the
US Attorney has fined an
insurance company for
paying a San Diego
insurance broker
"millions of dollars in
kickbacks disguised as
items such as requests for
proposals, communications
and enrollment fees. Those
fees were passed along to
policyholders."