1 © 2015 CSAA Insurance Group. Confidential and proprietary. April 2015 DOI Complaint File Handling Update Claims Policy & Standards

2 © 2015 CSAA Insurance Group. Confidential and proprietary. Current Process 1 P & S analyst receives, logs, sends to Operations with response timelines 2 Supervisor and manager reviews, drafts response letters, and sends to P & S analyst for review and approval 3 P & S analyst reviews, edits, approves, sends back to supervisor and manager to mail. Risks/Issues:  Inconsistency with response letters being scanned to claim files  Review and approval of response letters by Analysts adds to overall response time.  Incomplete details in compliance tracking tool by Analyst.

3 © 2015 CSAA Insurance Group. Confidential and proprietary. Updated Process 1 P & S analyst receives complaint, logs, sends to operations with response timelines. 2 Supervisor will draft the letter and review with their manager for approval and mailing. 3 Supervisor will send an notification to the P & S analyst with a brief synopsis of the outcome and informing analyst that response letters have been mailed and scanned to the claim file. 4 P & S analyst will diary their file to confirm letters are mailed on time and letters are scanned to the claim file. Efficiency/ Gains:  Reduction in cycle time by average of two days  Operations owns response letters  Claim files are documented appropriately  Analyst continues to be support and act as SME  Exceptions such as disputing DOI justification, operations will continue to engage the P & S analyst to support additional handling steps.

4 © 2015 CSAA Insurance Group. Confidential and proprietary. Results Operations has ownership of response letters timing and quality Reduced time to resolve Over time, expectation with developing relationships between the DOI compliance officers and Operations will grow – This is critical to maintain relationships to support Market Conduct Audits Beginning and final steps maintained by P&S to capture compliance reporting details, tracking trends, and annual justified complaint review. P&S site will be maintained to include all states DOI information and appropriate letter templates for operations reference. Q & A will conduct a 90 day audit following implementation to assess risks. Thereafter, annual routine audit by Q & A.

5 © 2015 CSAA Insurance Group. Confidential and proprietary. April 2015 DOI Complaint File Handling Recommendation Claims Policy & Standards