Jefferies Credit Management LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MASSACHUSETTS MUTUAL
LIFEINSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("DFS")
2.
Principal Sanction:
Other
Other Sanctions: 
RESTITUTION AND REMEDIATION
3.
Date Initiated (MM/DD/YYYY): 
01/01/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020-0129-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
6.
Principal Product Type:
Other
Other Product Types: 
REPLACEMENT OF DEFERRED ANNUITY CONTRACTS WITH IMMEDIATE INCOME ANNUITY CONTRACTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("DFS") COMMENCED AN INVESTIGATION FOR THE PERIOD OF 1/1/2012-5/31/2018.
DURING ITSINVESTIGATION, DFS IDENTIFIED A PRACTICE ARISING FROM THE REPLACEMENT OF DEFERRED ANNUITY CONTRACTS WITH IMMEDIATE
INCOME ANNUITYCONTRACTS IN VIOLATION OF THE DISCLOSURE AND SUITABILITY REQUIREMENTS OF NEW YORK REGULATIONS 60 AND 187. IT WAS
ALLEGED THATMASSMUTUAL SOLD OR ISSUED 692 REPLACEMENT CONTRACTS TO CONSUMERS WITHOUT REASONABLE BASES TO BELIEVE THE
ANNUITIES AT ISSUE WERESUITABLE IN SOME INSTANCES, AND WITHOUT PROVIDING CONSUMERS WITH THE REQUIRED ANNUITIZATION

INFORMATION FOR REPLACED DEFERREDANNUITIES. IT WAS ALSO ALLEGED THAT MASSMUTUAL DID NOT ESTABLISH A SUPERVISORY SYSTEM
DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 187 INCONNECTION WITH THE DEFERRED -TO-IMMEDIATE REPLACEMENTS AT ISSUE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
04/09/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 692,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PAY THE MONETARY PENALTY IN THE AMOUNT OF $692,000 WITHIN 10 DAYS OF THE EFFECTIVE DATE OF THE CONSENT. WITHIN 30 DAYS,
PROVIDE ALLAFFECTED CONTRACT HOLDERS OR BENEFICIARIES NOTICES OR CHECKS OR OTHER PAYMENT MEANS APPROVED BY DFS THE
REQUIRED AMOUNTS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MASSMUTUAL AND DFS AGREED UPON RESTITUTION AND REMEDIATION FOR THE AFFECTED CONTRACT HOLDERS OF THE REPLACEMENT
CONTRACTS,AND WITHIN 30 DAYS, ALL AFFECTED CONTRACT HOLDERS OR BENEFICIARIES WILL BE PROVIDED WITH NOTICES AND CHECKS OR
OTHER PAYMENTMEANS APPROVED BY THE DES IN THE REQUIRED AMOUNTS. MASSMUTUAL WILL PROVIDE THE DES QUARTERLY REPORTS
DETAILING THE NUMBER OFCHECKS MAILED, TOTAL AMOUNT OR INDIVIDUAL CHECKS AND THE NUMBER OF CHECKS DEPOSITED, UNDELIVERED
AND OR NOT DEPOSITED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
MASSMUTUAL AGREED TO PAY A CIVIL MONETARY FINE IN THE AMOUNT OF $692,000. MASSMUTUAL AND DFS AGREED UPON RESTITUTION
ANDREMEDIATION FOR THE AFFECTED CONTRACT HOLDERS OF THE REPLACEMENT CONTRACTS. WITHIN 30 DAYS, ALL AFFECTED CONTRACT HOLDERS
ORBENEFICIARIES WILL BE PROVIDED WITH NOTICES AND CHECKS OR OTHER PAYMENT MEANS APPROVED BY THE DES IN THE REQUIRED
AMOUNTS.MASSMUTUAL WILL PROVIDE DES QUARTERLY REPORTS DETAILING THE NUMBER OF CHECKS MAILED, TOTAL AMOUNT OR INDIVIDUAL
CHECKS, AND THENUMBER OF CHECKS DEPOSITED, UNDELIVERED, AND/OR NOT DEPOSITED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MASSACHUSETTS MUTUAL
LIFEINSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ("HUD")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
THE HUD'S MORTGAGE REVIEW BOARD ISSUED A NOTICE OF ADMINISTRATIVE ACTION WITHDRAWING MASSMUTUAL'S FHA APPROVAL. MASSMUTUAL
HASSINCE SUBMITTED THE REQUIRED DOCUMENTATION AND PAID A $7,500 CIVIL MONETARY PENALTY. THE MORTGAGE REVIEW BOARD HAS
RESCINDED THENOTICE OF ADMINISTRATIVE ACTION AND REINSTATED MASSMUTUAL AS AN APPROVED TITLE II MORTGAGEE.
3.
Date Initiated (MM/DD/YYYY): 
10/17/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
14-1726-MRT
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
6.
Principal Product Type:
Debt - Asset Backed
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

HUD'S MORTGAGE REVIEW BOARD ISSUED A NOTICE OF VIOLATION AND A NOTICE OF INTENT TO SEEK CIVIL MONEY PENALTIES INFORMING
MASSMUTUALOF HUD'S INTENT TO TAKE AN ADMINISTRATIVE ACTION OR IMPOSE CIVIL MONEY PENALTIES PURSUANT TO 12 U.S.C. § 1708 AND 1735F­
14, AND 24 C.F.R.PARTS 25 AND 30, ON THE BASIS OF MASSMUTUAL'S FAILURE TO COMPLY WITH HUD-FHA'S ANNUAL CERTIFICATION REQUIREMENTS
WITH RESPECT TOFISCAL YEAR ENDING DECEMBER 2012.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Dismissed
11. Resolution Date (MM/DD/YYYY):
11/17/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 7,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MASSMUTUAL HAS SINCE SUBMITTED THE REQUIRED DOCUMENTATION AND PAID A $7,500 CIVIL MONETARY PENALTY. THE MORTGAGE REVIEW
BOARDHAS RESCINDED THE NOTICE OF ADMINISTRATIVE ACTION AND REINSTATED MASSMUTUAL AS AN APPROVED TITLE II MORTGAGEE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
MASSMUTUAL HAS SINCE SUBMITTED THE REQUIRED DOCUMENTATION AND PAID A $7,500 CIVIL MONETARY PENALTY. THE MORTGAGE REVIEW BOARD
HASRESCINDED THE NOTICE OF ADMINISTRATIVE ACTION AND REINSTATED MASSMUTUAL AS AN APPROVED TITLE II MORTGAGEE. ON NOVEMBER 17,
2014, ANADMINISTRATIVE LAW JUDGE WITH HUD'S OFFICE OF HEARINGS AND APPEALS DISMISSED THE MATTER, WITH PREJUDICE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
2682
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MASSACHUSETTS MUTUAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF CONNECTICUT, INSURANCE DEPARTMENT
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/03/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MC 18-87
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF CONNECTICUT, INSURANCE DEPARTMENT ALLEGED THAT MASSMUTUAL VIOLATED SUBSECTIONS 38A-15 AND 38A-702M OF THE
CONNECTICUTGENERAL STATUTES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
04/26/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 61,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MASSMUTUAL AGREED TO PROVIDE THE DEPARTMENT WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN
THEMARKET CONDUCT REPORT WITHIN 90 DAYS AND MASSMUTUAL AGREED TO PAY A FINE IN THE AMOUNT OF $61,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
MASSMUTUAL AGREED TO PROVIDE THE DEPARTMENT WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN THE
MARKETCONDUCT REPORT WITHIN 90 DAYS AND MASSMUTUAL AGREED TO PAY A FINE IN THE AMOUNT OF $61,000.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
MASSACHUSETTS MUTUAL
LIFEINSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF NEW HAMPSHIRE INSURANCE DEPARTMENT
2.
Principal Sanction:
Restitution
Other Sanctions: 
THE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD OF JANUARY 1, 2007 THROUGH NOVEMBER 30, 2009, FINDING
THATMASSMUTUAL, C.M. LIFE, AND MML BAY STATE VIOLATED REGULATIONS RSA 408:29; RSA 409-A:5, INS 401.12, AND RSA 417:4I(H) CONCERNING
CONTRACTANNUITIZATION AT MATURITY PROCEDURESAND PROCESS. MASSMUTUAL, C.M. LIFE, AND MML BAY STATE WERE ORDERED TO SUBMIT A
PROPOSEDCORRECTIVE PLAN OF ACTION WITH RESPECT TO POLICIES AND PROCEDURES FOR FORECED ANNUITIZATION AT MATURITY AND A
PROPOSED RES
3.
Date Initiated (MM/DD/YYYY): 
03/06/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
INS NO. 13-004-MC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
6.
Principal Product Type:
Annuity(ies) - Fixed
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD OF JANUARY 1, 2007 THROUGH NOVEMBER 30, 2009, FINDING
THATMASSMUTUAL, C.M. LIFE, AND MML BAY STATE VIOLATED REGULATIONS RSA 408:29; RSA 409-A:5, INS 401.12, AND RSA 417:4I(H) CONCERNING
CONTRACTANNUITIZATION AT MATURITY PROCEDURES AND PROCESS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):
03/06/2013
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MASSMUTUAL WAS ORDERED TO SUBMIT A PROPOSED CORRECTIVE PLAN OF ACTION WITH RESPECT TO POLICIES AND PROCEDURES FOR
FORECEDANNUITIZATION AT MATURITY AND A PROPOSED RESTITUTION PLAN FOR ANY LOSSES SUSTAINED BY CONSUMERS RELATED TO THE
FINDINGS OF THEMARKET CONDUCT EXAMINATION REPORT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD OF JANUARY 1, 2007 THROUGH NOVEMBER 30, 2009, FINDING
THATMASSMUTUAL, C.M. LIFE, AND MML BAY STATE VIOLATED REGULATIONS RSA 408:29; RSA 409-A:5, INS 401.12, AND RSA 417:4I(H) CONCERNING
CONTRACTANNUITIZATION AT MATURITY PROCEDURESAND PROCESS. MASSMUTUAL, C.M. LIFE, AND MML BAY STATE WERE ORDERED TO SUBMIT A
PROPOSEDCORRECTIVE PLAN OF ACTION WITH RESPECT TO POLICIES AND PROCEDURES FOR FORECED ANNUITIZATION AT MATURITY AND A
PROPOSED RESTITUTIONPLAN FOR ANY LOSSES SUSTAINED BY CONSUMERS RELATED TO THE FINDINGS OF THE MARKET CONDUCT EXAMINATION
REPORT.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
2682
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MASSACHUSETTS MUTUAL LIFE

INSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE OFFICE OF INSURANCE COMMISSIONER OF PUERTO RICO
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ADMINISTRATIVE FINE OF $3,000. RESCIND THE DISPUTED POLICY AND RETURN TO THE COMPLAINANT THE AMOUNT OF $65,000. MASSACHUSETTS
MUTUALLIFE INSURANCE COMPANY WAS ORDERED TO CEASE AND DESIST FROM THE PRACTICES DESCRIBED IN THE ORDER.
3.
Date Initiated (MM/DD/YYYY): 
03/27/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CM-2022-17
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 17, 2022, THE COMMISSIONER OF PUERTO RICO ISSUED AN ORDER AGAINST MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY STATING
THATTHE FIRM HAD VIOLATED ARTICLES 11.230 AND 27.160 OF THE PUERTO INSURANCE CODE, 26 LPRA SECTIONS 1123 AND 2716 FOR WHICH
ANADMINISTRATIVE FINE OF $3,000 WAS IMPOSED. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY WAS ORDERED TO RESCIND THE POLICY IN
DISPUTEAND RETURN TO THE APPLICANT (COMPLAINANT) THE AMOUNT OF $65,000, CORRESPONDING TO THE UNDULY COLLECTED PREMIUM.
MASSACHUSETTSMUTUAL LIFE INSURANCE COMPANY WAS ORDERED TO CEASE AND DESIST FROM THE PRACTICES DESCRIBED IN THE ORDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):

06/27/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
AN ADMINISTRATIVE FINE OF $3,000 WAS INITIALLY IMPOSED AND THE COMMISSIONER OF INSURANCE OF PUERTO RICO MODIFIED
THEADMINISTRATIVE FINE TO $1,500. AN ORDER TO RESCIND THE POLICY IN DISPUTE AND RETURN TO THE COMPLAINANT THE AMOUNT OF
$65,000CORRESPONDING TO THE UNDULY COLLECTED PREMIUM. AN ORDER TO CEASE AND DESIST FROM THE PRACTICES DESCRIBED IN THE
ORDER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
GIVEN THE ACCEPTANCE AND COMMITMENT OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY TO TAKE THE NECESSARY MEASURES TO
AVOIDSIMILAR MATTERS IN THE FUTURE, THE COMMISSIONER OF INSURANCE OF PUERTO RICO AGREED TO MODIFY THE ADMINISTRATIVE FINE
TO $1,500.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY DID NOT INTEND TO FAIL TO COMPLY WITH THE PROVISIONS OF ARTICLES 11,230 AND 27, 160
OF THEPUERTO RICO INSURANCE CODE, SUPRA, AND THE FACTS INDICATED IN THE ORDER AROSE AS AN EXCEPTIONAL SITUATION THAT DOES NOT
CONSTITUTETHE NORMAL OR INTERNAL POLICY OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY'S INSURANCE BUSINESS. MASSACHUSETTS
MUTUAL LIFEINSURANCE COMPANY ALLEGED THAT THE FACTS OF THE ORDER WERE THE RESULT OF ACTIONS AND/OR OMISSIONS OF PARTIES
INVOLVED IN THE ORDERWHICH ENDED IN A MISUNDERSTANDING. GIVEN THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY ACCEPTED AND
COMMITTED TO TAKE THENECESSARY MEASURES TO AVOID SIMILAR SITUATIONS IN THE FUTURE, THE COMMISSIONER OF INSURANCE OF PUERTO RICO
AGREED TO MODIFY THEADMINISTRATIVE FINE TO $1,500. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY PROCEEDED TO RESCIND THE POLICY
THAT WAS SUBJECT OF THECONTROVERSY AND TO REIMBURSE THE APPLICANT (COMPLAINANT) THE SUM OF $65,000, AS PROVIDED IN THE ORDER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

CRD
Number:
2682
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MASSACHUSETTS MUTUAL LIFE
INSURANCE COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/26/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 23-0147
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/08/2023
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE INSURANCE COMMISSIONER CONSENTED TO SETTLE THE MATTER IN CONSIDERATION OF THE COMPANY'S PAYMENT OF A FINE AND UPON
SUCH TERMS AND CONDITIONS, INCLUDING (1) THE COMPANY ACKNOWLEDGES THE DUTY TO COMPLY FULLY WITH THE APPLICABLE LAWS OF
THE STATE OF WASHINGTON; AND (2) THE COMPANY CONSENTED TO THE ENTRY OF THE ORDER, WAIVED ANY AND ALL HEARING OR OTHER
PROCEDURAL RIGHTS AND FURTHER ADMINISTRATIVE OR JUDICIAL CHALLENGES TO THE ORDER. BY AGREEMENT, THE INSURANCE
COMMISSIONER IMPOSED A FINE IN THE AMOUNT OF $10,000 TO BE PAID WITHIN 30 DAYS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY MUST CERTIFY ANNUALLY TO THE OFFICE OF THE INSURANCE COMMISSIONER ("OIC") THE
INSURANCE PRODUCERS THAT ARE SELLING, SOLICITING, OR NEGOTIATING THE COMPANY'S LONG TERM CARE ("LTC") INSURANCE PRODUCTS HAVE
COMPLETED LTC EDUCATION REQUIREMENTS. THE CERTIFICATION IS REQUIRED TO BE SUBMITTED ANNUALLY TO THE OIC ON OR BEFORE MARCH
31ST. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY WAS GRANTED AN EXTENSION TO FILE ITS 2021 ANNUAL CERTIFICATION REPORT BY MAY
31, 2022.THE STATE OF WASHINGTON OIC ALLEGED THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY FAILED TO VERIFY THAT TWO
INSURANCE PRODUCERS HAD RECEIVED THE REQUIRED LTC TRAINING BEFORE THEY WERE PERMITTED TO SELL, SOLICIT, OR OTHERWISE NEGOTIATE
THE SALE OF THE COMPANY'S LTC INSURANCE PRODUCTS. BY FAILING TO VERIFY THE TRAINING, IT WAS ALLEGED THAT THE COMPANY VIOLATED RCW
48.83.130(4), JUSTIFYING THE IMPOSITION OF A FINE UNDER RCW 48.83.160. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY MUST CERTIFY
ANNUALLY TO THE OFFICE OF THE NSURANCE COMMISSIONER ("OIC") INSURANCE PRODUCERS SELLING, SOLICITING, OR NEGOTIATING THE
COMPANY'S LONG TERM CARE ("LTC") INSURANCE PRODUCTS HAVE COMPLETED LTC EDUCATION REQUIREMENTS. THE CERTIFICATION IS REQUIRED
TO BE SUBMITTED ANNUALLY TO THE OIC ON OR BEFORE MARCH 31ST. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY WAS GRANTED AN
EXTENSION TO FILE ITS 2021 ANNUAL CERTIFICATION REPORT BY MAY 31, 2022. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY SUBMITTED THE
CERTIFICATION ON MAY 26, 2022, WHICH REVEALED THAT IT SELF-DISCLOSED THAT TWO PRODUCERS SOLD THREE LTC POLICIES TO WASHINGTON
CONSUMERS ON BEHALF OF THE COMPANY AND THE PRODUCERS WERE NOT IN COMPLIANCE WITH THE LTC EDUCATION REQUIREMENTS AT THE TIME
OF THE SALES. RCW 48.83.130(4) REQUIRES ISSUERS TO OBTAIN VERIFICATION THAT A PRODUCER RECEIVES TRAINING BEFORE THE PRODUCER IS
PERMITTED TO SELL, SOLICIT, OR NEGOTIATE THE ISSUER'S LTC NSURANCE PRODUCTS. WAC 284-17-262(1) PROVIDES THAT EACH INSURER THAT HAS
LTC POLICIES APPROVED FOR SALE IN WA MUST CERTIFY ANNUALLY THAT ALL OF ITS PRODUCERS HAVE (A) COMPLETED THE 8 HR. ONE TIME LTC
EDUCATION AND TRAINING COURSE REQUIRED BY RCW 48.83.130(1)(A)(I) PRIOR TO SELLING, SOLICITING, OR NEGOTIATING THE COMPANY'S LTC
COVERAGE IN WA; AND (B) IF DUE, COMPLETED THE REQUIRED 4 HOUR LTC CE REQUIREMENT IMPOSED BY RCW 48.83.130(2)(B). BY FAILING TO
VERIFY THAT TWO PRODUCERS HAD RECEIVED THE REQUIRED LONG-TERM CARE TRAINING PRIOR TO SELLING, SOLICITING, OR NEGOTIATING THE
SALE OF THE COMPANY'S INSURANCE PRODUCTS, IT WAS ALLEGED THAT THE COMPANY HAD VIOLATED RCW 48.83.130(4) JUSTIFYING A FINE UNDER
RCW 48.83.160. THE INSURANCE COMMISSIONER AND THE COMPANY AGREED TO RESOLVE THE MATTER WITHOUT FURTHER ADMINISTRATIVE OR
JUDICIAL PROCEEDINGS. THE INSURANCE COMMISSIONER CONSENTED TO SETTLE THE MATTER IN CONSIDERATION OF THE COMPANY'S PAYMENT OF A
FINE AND UPON SUCH TERMS AND CONDITIONS, INCLUDING (1) THE COMPANY ACKNOWLEDGES THE DUTY TO COMPLY FULLY WITH THE APPLICABLE
LAWS OF THE STATE OF WASHINGTON; AND (2) THE COMPANY CONSENTED TO THE ENTRY OF THE ORDER, WAIVED ANY AND ALL HEARING OR OTHER
PROCEDURAL RIGHTS AND FURTHER ADMINISTRATIVE OR JUDICIAL CHALLENGES TO THE ORDER. BY AGREEMENT, THE INSURANCE COMMISSIONER
IMPOSED A FINE IN THE AMOUNT OF $10,000 TO BE PAID WITHIN 30 DAYS.