Stipulation and Consent Order Regarding Homesite Insurance Company

STATE OF VERMONT
DEPARTMENT OF FINANCIAL REGULATION
INSURANCE DIVISION
)
)
IN RE: HOMESITE INSURANCE )
COMPANY )
NAIC # 17221 )
DOCKET NO. 26-010- I
CONSENT ORDER
Having fully reviewed the Stipulation for Entry of Consent Order (“Stipulation”), including the Statement of Facts, Descriptions of Violations, and Resolution, IT IS HEREBY ORDERED:

1. The Statement of Facts is incorporated herein as the Findings of Fact.
2. The Legal Standards and Description of Violations are incorporated herein as the
   Conclusions of Law.
3. The Resolution section is incorporated herein as the remedies and is so ordered.
4. Pursuant to the Stipulation, the Insurance Division and Respondent consent to the entry
   of this Consent Order.
5. The entry of this Consent Order is in the public interest and consistent with the purposes
   intended by the law to which it pertains.
6. Noncompliance with any of the terms and conditions in this Consent Order shall be a
   violation of a lawful order of the Commissioner and a violation of the laws of the State of Vermont and may result in additional legal action and the imposition of injunctive relief, Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

sanctions and additional penalties pursuant to applicable provisions of Title 8 of the Vermont Statues Annotated, including provisions imposing enhanced penalties for willful or knowing violations.
7. Nothing herein shall be construed as limiting the Commissioner’s ability to investigate
Respondent for violations not resolved herein or to respond to and address any consumer complaints made regarding Respondent’s past or future actions, including but not limited to ordering restitution in connection with any such complaint. Entered at Montpelier, Vermont this 21st day of May. ___________________________________ Kaj Samsom, Commissioner Vermont Department of Financial Regulation Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

STATE OF VERMONT
DEPARTMENT OF FINANCIAL REGULATION
INSURANCE DIVISION
)
) DOCKET NO. 26- 010 -I
)
IN RE: HOMESITE INSURANCE )
COMPANY )
(NAIC# 17221) )
STIPULATION FOR THE ENTRY OF CONSENT ORDER
This Stipulation and Consent Order is entered this _____ day of May 2026 by and among Homesite Insurance Company (“Respondent”) and the Insurance Division of the State of Vermont Department of Financial Regulation (“Division”). WHEREAS, the Commissioner of the Department (“Commissioner”) is responsible for administering and enforcing the Vermont insurance laws, set forth in Title 8 of the Vermont Statutes Annotated, pursuant to which the Department has conducted a routine market conduct review of Respondent’s activities with respect to property and casualty insurance policies; and WHEREAS, as a result of the Division’s review, the Division has concluded that Respondent violated the Vermont insurance laws by improperly canceling certain insurance policies in effect for 60 days or longer; and WHEREAS, Respondent and the Division wish to resolve these violations without further administrative proceedings or litigation. NOW THEREFORE, Respondent and the Division stipulate and agree to the terms of this Stipulation for the entry of Consent Order (“Stipulation”) and jointly request that the Commissioner of Financial Regulation (“Commissioner”) enter the proposed Consent Order Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 18th Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

submitted with this Stipulation. (“Consent Order”).
STATEMENT OF FACTS

1. Respondent is a property and casualty insurance company with a principal
   place of business in Madison, Wisconsin.

2. At all times relevant to this matter, Respondent held a license issued by the
   Division pursuant to 8 V.S.A.§ 3361, authorizing Respondent to operate as an insurer in the State of Vermont.

3. The Division recently conducted a routine market conduct analysis of property
   and casualty insurers licensed in Vermont and discovered that Respondent had violated Vermont insurance law during 2023 by improperly canceling certain homeowners’ insurance policies in effect for 60 days or longer and by failing to adequately document and preserve records relative to the mailing of certain notices of cancellation. LEGAL STANDARDS AND DESCRIPTION OF VIOLATIONS

4. The Commissioner of Financial Regulation is responsible for administering and
   enforcing the insurance laws of the State of Vermont and is authorized to investigate insurance companies to determine compliance with Vermont law and to issue orders imposing remedial actions and civil administrative penalties, pursuant to 8 V.S.A. §§10, 15, 3661 and 4229.

5. Pursuant to 8 V.S.A. §3661, the Commissioner may impose a civil
   administrative penalty for each violation of Title 8, an administrative rule of the Department, or an order of the Commissioner relating to insurance, of up to $1000 per violation or $10,000 per willful violation. Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

6. Pursuant to 8 V.S.A.§ 3879, homeowners’ insurance policies in effect
   for 60 days or longer may only be cancelled for a) nonpayment of premium; b) fraud or material misrepresentation affecting the policy or in the presentation of a claim; or c) substantial increase in hazard, with the prior approval of the Department’s Commissioner.

7. Pursuant to 8 V.S.A. §3883, notices of cancellation must be sent by
   certified mail, unless the cancellation is for the nonpayment of premium, in which case notice shall be by certified mail, certificate of mailing, or any similar first class tracking method used or approved by the U.S. Postal Service (including IMb tracing), such that a record is preserved.

8. On one occasion in 2023 and on two occasions in 2024, Respondent cancelled
   homeowners’ insurance policies in effect for 60 days or longer citing a substantial increase in hazard, however, Respondent did not seek the prior approval of the Commissioner in violation of Section 3879.

9. On two occasions in 2024, Respondent sent out notices without adequately
   documenting or preserving a record of the notice provided, in violation of 8 V.S.A.§3883.

10. As a result of Respondent’s violations, the Commissioner is authorized to
    impose civil administrative penalties.
    RESOLUTION

11. Respondent acknowledges and agrees that this Stipulation is entered into
    freely and voluntarily and that no promise was made, nor was any coercion used, to induce the Respondent to enter into it. Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

12. Respondent shall comply with the Vermont Insurance Laws.

13. Respondent agrees to pay $4250 as a civil penalty to the Department of Financial
    Regulation. Payment is due to the Department within 10 days of the execution of this Stipulation and Consent Order.

14. Respondent agrees to pay $750 to the Vermont Financial Services Education and
    Victim Restitution Fund, within 10 days of the execution of this Stipulation and Consent Order.

15. The amounts identified in Paragraphs 3 and 4 shall be made via wire or check
    made payable to the “Department of Financial Regulation” and mailed to Cheryl Lancaster, Docket Clerk, Department of Financial Regulation, 89 Main Street, Montpelier, VT 05620-3101.

16. The Insurance Division and Respondent will coordinate the exchange of any
    additional details necessary to facilitate payment.

17. Respondent acknowledges and admits the jurisdiction of the Commissioner over
    the subject matter of this Stipulation, including for purposes of enforcing any consent order issued by the Commissioner in response to this Stipulation.

18. With respect to the facts and violations identified herein, Respondent waives its
    right to a hearing before the Commissioner or Commissioner’s designee, waives the right, if any, to a jury trial, and waives its right to all other administrative or judicial review otherwise available under Vermont law, including the rules of the Vermont Department of Financial Regulation and the provisions of 3 V.S.A. Chapter 25.

19. Respondent understands all terms and conditions of this Stipulation, consents to
    the entry of the Consent Order, and acknowledges that its consent is given freely and voluntarily and that, except as set forth herein, no promise was made to induce Respondent’s consent.

20. Respondent acknowledges that noncompliance with any of the terms and
    Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

conditions in this Consent Order shall be a violation of a lawful order of the Commissioner and a violation of the laws of Vermont and may result in additional legal action and the imposition of injunctive relief, sanctions and additional penalties pursuant to applicable provisions of Title 8 of the Vermont Statues Annotated, including provisions imposing enhanced penalties for willful or knowing violations.
11. Nothing herein shall be construed as having relieved, modified, or in any manner
affected Respondent’s ongoing obligation to comply with all federal, state, or local statues, rules and regulations applicable to Respondent.
12. Nothing herein shall be construed as limiting any private right of action a person
may have against Respondent, nor shall anything herein be construed as determining whether such right exists.
13. Nothing shall be construed as limiting the Commissioner’s ability to investigate
Respondent for violations not resolved herein or to respond to and address any consumer complaints made regarding Respondent’s past or future actions, including but not limited to ordering restitution in connection with any such complaint.
14. This Stipulation is entered into solely for the purpose of resolving the violations
identified herein and is not intended for any other purpose.
15. This Consent Order shall be binding upon Respondent’s affiliates, subsidiaries,
successors and assigns as well as to the successors and assigns of relevant affiliates.
16. Respondent understands that the Insurance Division has relied fully upon
Respondent’s disclosures and representations in stipulating to the facts stated herein and that nothing herein shall be construed as limiting the Commissioner’s remedies if the Commissioner finds that the facts stated herein are based on false, omitted, misleading or materially incomplete Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D

information.
17. The Insurance Division and Respondent have made specific compromises to reach
this Stipulation. If the Commissioner fails to approve the Consent Order in its entirety or any portion thereof, the Insurance Division and Respondent agree that the Stipulation will terminate, and each party will have the same rights each would have had absent the Stipulation. Further, if terminated, the Stipulation and the negotiations that resulted in the Stipulation may not be used as evidence in any administrative or civil proceeding.
18. If Respondent fails or neglects to comply with any of the terms, conditions or
undertakings set forth in this Stipulation, the Division may, upon written notice to Respondent, institute any legal or administrative proceedings it deems appropriate to enforce same and to seek such other appropriate sanctions, and Respondent shall consent to the entry of judgment for any unpaid balance.
19. This Stipulation and any resulting Consent Order shall be governed by and
construed under the laws of the State of Vermont.
SIGNATURES ON FOLLOWING PAGE
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SIGNATURES
Respondent stipulates and agrees to the terms of this Stipulation. I certify under the pains and penalties of perjury that I have taken all the necessary steps to bind Respondent to this Stipulation and that I have been duly authorized to enter into this Stipulation for Entry of Consent Order on behalf of Homesite Insurance Company . HOMESITE INSURANCE COMPANY By: __________________________________________ Date:
Printed Name:__________________________________ Title: _________________________________________ DEPARTMENT OF FINANCIAL REGULATION INSURANCE DIVISION By:________________________________________ Date:
Mary Block
Deputy Commissioner, Insurance Division
Vermont Department of Financial Regulation
Docusign Envelope ID: C030AC78-4EC0-8D57-8371-DC3E380209F6 Vice President, Compliance and Corporate Legal 5/18/2026 Bryce Tolefree Docusign Envelope ID: 279675E6-E1D4-831F-8287-07F32C8F75C3 5/18/2026 Docusign Envelope ID: 98A8C81E-EBDF-8472-8333-F80B32DE570D