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									Market Conduct                           PROGRESSIVE SPECIALTY
Examination Report                          INSURANCE COMPANY
As of December 31, 1998


       MARKET CONDUCT EXAMINATION REPORT

  PROGRESSIVE SPECIALTY INSURANCE COMPANY

                      AS OF DECEMBER 31, 1995

                            EXAM LOCATION

                   2075 RESEARCH PARKWAY

         COLORADO SPRINGS, COLORADO 80920

       PREPARED BY INDEPENDENT CONTRACTORS FOR

     COLORADO DEPARTMENT OF REGULATORY AGENCIES

                          DIVISION OF INSURANCE

                                                            PCMC 97-7-AU

                                                              V5 (093197)

                            LARRY N. CAMPBELL, CIE

                            LUCILLE E. WHITTLE, CIE

                             JAMES T. AXMAN, AIE

                     Independent Market Conduct Examiners

                            Working in Coordination with

                           Colorado Division of Insurance

                             1560 Broadway, Suite 850

                              Denver, Colorado 80202

                                  (303) 894-7499
                                      October 10, 1997

The Honorable Jack Ehnes

Commissioner of Insurance

State of Colorado

1560 Broadway Suite 850

Denver, Colorado 80202

Commissioner:

In accordance with Sections 10-1-203 and 10-3-1106, C.R.S., an examination of selected
underwriting and claims practices of the private passenger automobile insurance business of
Progressive Specialty Insurance Company, hereinafter referred to as the "Company", has
been conducted. The Company’s records were examined at its regional office located at
2075 Research Parkway, Colorado Springs, Colorado, 80920.

The examination covered the period from January 1, 1995 to December 31, 1995.

A report of the examination is herein respectfully submitted.

           Larry N. Campbell, CIE.,

           Lucille E. Whittle, CIE

           James T. Axman, AIE

Independent Market Conduct Examiners




                                TABLE OF CONTENTS
I. COMPANY PROFILE

II. PURPOSE AND SCOPE OF EXAMINATION

III. EXAMINATION REPORT SUMMARY

IV. PERTINENT FACTUAL FINDINGS

           A. Underwriting
           B. Rating

           C. Claims Practices

V. SUMMARY OF RECOMMENDATIONS

VI. EXAMINATION REPORT SUBMISSION




                                 COMPANY PROFILE
Progressive Specialty Insurance Company is a 100% stock subsidiary of Progressive
Casualty Insurance Company, of the Progressive Insurance Group of Companies, and was
formed in Ohio in 1975, received its Colorado license on December 11, 1990, and began
writing business in Colorado in June 1994.

The Company is authorized to write the following lines of insurance: fidelity and surety, motor
vehicle, homeowners multiple peril, commercial multiple peril, and farm owners multiple peril.

In the State of Colorado, the Company markets only one line of business, private passenger
auto insurance. According to the NAIC, the Company reported $ 17,315,000 in total written
premiums in 1995 for its automobile market. This volume represented a 1.00 % market share
of all private passenger automobile insurance written in the State of Colorado.

                   PURPOSE AND SCOPE OF EXAMINATION
This market conduct report was prepared by independent examiners contracting with the
Colorado Division of Insurance for the purpose of auditing certain business practices of
insurers licensed to conduct the business of insurance in the State of Colorado. This
examination is in accordance with Colorado Insurance Law § 10-1-204, C.R.S., which
empowers the Commissioner to supplement his resources to conduct market conduct exams.
The findings in this report, including all work product developed in the production of this
report, are the sole property of the Colorado Division of Insurance.

The market conduct examination covered by this report was performed on a routine basis to
assist the Colorado Commissioner of Insurance to meet statutory requirements, by
determining Company compliance with the Colorado Insurance Law and generally accepted
operating principles. Additionally, findings of a market conduct examination serve as an aid
to the Division of Insurance’s early warning system. The intent of the information contained
in this report is to serve only those purposes.

This examination was governed by, and performed in accordance with, procedures
developed by the National Association of Insurance Commissioners, the Colorado Division
of Insurance, and the Insurance Regulatory Examiners Society. In reviewing material for this
report the examiners relied primarily on records and material maintained by the Company.
The examination period covered one calendar year of the Company’s operations, from
January 1, 1995 to December 31, 1995.

File sampling was based on review of systematically selected samples of underwriting and
claim files by category. Sample sizes were chosen based on guidance from procedures
developed by the National Association of Insurance Commissioners. Upon review of each
file, any concerns or discrepancies were noted on comment forms. These comment forms
were delivered to the Company for review. Once the Company was advised of a finding
contained in a comment form, the Company had the opportunity to respond. For each finding
the Company was requested to agree, disagree or otherwise justify the Company’s noted
action. At the conclusion of each sample, the Company was provided a summary of the
findings for that sample. The report of the examination is, in general, a report by exception.
Therefore, much of the material reviewed will not be contained in this written report, as
reference to any practices, procedures, or files which manifested no errors were omitted.

An error tolerance level of plus or minus $10.00 was allowed in most cases where monetary
values were involved; however, in cases where monetary values were generated by
computer, a $0 tolerance level was applied in order to identify possible system errors.
Additionally, a $0 tolerance level was applied in instances where there appeared to be a
consistent pattern of deviation from the Company’s rates on file with the Colorado Division of
Insurance.

This report contains information regarding exceptions to the Colorado Insurance Laws. The
examination included review of the following four Company operations:

1. Complaint Handling

2. Underwriting Practices.

3. Rate Application.

4. Claims Settlement Issues.

All unacceptable or non-complying practices may not have been discovered throughout the
course of this examination. Additionally, findings may not be material to all areas which
would serve to assist the Commissioner. Failure to identify or criticize specific Company
practices does not constitute acceptance by the Colorado Division of Insurance of such
practices. This report should not be construed to endorse nor discredit any insurance
company or insurance product. Statutory cites and regulation references are as of the period
under examination unless otherwise noted. Examination report recommendations which do
not reference specific insurance laws, regulations, or bulletins are presented to encourage
improvement of company practices and operations and ensure consumer protection.
Examination findings may result in administrative action by the Division of Insurance.

                        EXAMINATION REPORT SUMMARY
The examination resulted in a total of seventeen (17) issues arising from the Company’s
apparent noncompliance with Colorado statutes and regulations related to all property and
casualty insurance. These issues encompassed the following Company operations.

Complaint Handling Procedures

In the area of complaint handling, no compliance issues were noted.

Underwriting Practices

In the area of underwriting, eight (8) compliance issues are addressed in this report. These
issues arise from Colorado statutory and regulatory requirements which must be followed
whenever policies are issued, canceled, or non-renewed or the premiums increased or
decreased. The incidence of noncompliance in the area of underwriting exhibits a frequency
range of error between 2% to 31%. With regard to these eight (8) underwriting practices, it is
recommended that the Company review its underwriting procedures and make the necessary
changes to assure future compliance with applicable statutes and regulations.

Rating

In the area of rating, two (2) compliance issues are addressed in this report. These issues
arise from Colorado statutory and regulatory requirements which must be followed whenever
policies are issued, rated, or when premiums are increased or decreased. The incidence of
noncompliance in the area of rating demonstrates a frequency range of error between 2% to
3%. In regard to the two (2) compliance issues in this area, it is recommended that the
Company review its rating manuals, filings, and procedures and make the necessary
changes to assure future compliance with applicable statutes and regulations.

Claims Practices

In the area of claim practices, seven (7) compliance issues are addressed. These issues
arise from Colorado statutory and regulatory requirements dealing with the fair and equitable
settlement of claims, payment of claim checks, maintenance of records, timeliness of
payments, accuracy of claim payment calculations, and delay of claims. The incidence of
noncompliance in the area of claims practices shows a frequency range of error between 2%
and 22%. In regard to the seven (7) compliance issues in this area, it is recommended that
the Company review its claims handling procedures and make the necessary changes to
assure future compliance with applicable statutes and regulations.

                            PERTINENT FACTUAL FINDINGS

                          PRIVATE PASSENGER AUTOMOBILE

                            PERTINENT FACTUAL FINDINGS

                                            for

                                     UNDERWRITING
Issue A: Failure to submit forms for Certification to the Colorado Division of Insurance.

Section 10-3-1104(1)(u), C.R.S., states:

           Certifying pursuant to Section 10-4-725 or issuing, soliciting, or using an
           automobile policy form, endorsement, or notice form that does not comply with
           statutory mandates. Such solicitation or certification shall be subject to the
           sanctions described in sections 10-3-1107, 10-3-1108, and 10-3-1109.

Section 10-4-725(1)(2), C.R.S., Certification of policy and notice forms, states:

           (1) All insurers providing automobile insurance and who are authorized by the
           commissioner to conduct business in Colorado shall submit an annual report to
           the commissioner listing any policy forms, endorsements, cancellation notices,
           renewal notices, disclosure forms, notices of proposed premium increases,
           notices of proposed reductions in coverage, and such other forms as may be
           requested by the commissioner issued or delivered to any policyholder in
           Colorado. Such listing shall be submitted by July 15, 1993, and not later than July
           1 of each subsequent year and shall contain a certification by an officer of the
           organization that to the best of the officer's knowledge each policy form,
           endorsement, or notice form in use complies with Colorado law. The necessary
           elements of the certification shall be determined by the commissioner.

           (2) All insurers providing automobile insurance and who are authorized by the
           commissioner to conduct business in Colorado shall also submit to the
           commissioner a list of any new policy form, endorsement, cancellation notice,
           renewal notice, disclosure form, notice of proposed premium increase, notice of
           proposed reductions in coverage, and any other form as may be requested by the
           commissioner at least thirty-one (31) days before using such policy form,
           endorsement, cancellation notice, renewal notice, disclosure form, notice of
           proposed premium increase, notice of proposed reductions in coverage, and any
           other form as may be requested by the commissioner. Such listing shall also
           contain a certification by an officer of the organization that to the best of the
           officer's knowledge each new policy form, endorsement, or notice form proposed
           to be used complies with Colorado law. The necessary elements of the
           certification shall be determined by the commissioner.

Colorado Regulation 1-1-6 (III)(A)(7), Annual filing of forms and certification by officer,
states:

           "Listing of New Policy Forms for automobile private passenger insurance" shall
           mean a list of any new automobile private passenger policy forms, endorsements,
           cancellation notices, renewal notices, disclosure forms, notices of proposed
           premium increases, notices of reductions in coverage and any other such forms
           as requested by the Commissioner issued or delivered to any policyholder in
           Colorado with the description of the form, the form number and edition date, the
           title of the program or product affected by the form, and the effective date the form
           will be used.
The Company’s Automobile Private Passenger Forms Certification List submitted to the
Colorado Division of Insurance was compared to all forms used during the examination
period. Two (2) forms were noted as being used by the Company in their underwriting and
claims handling procedures but were not shown on the Certification list. They are as follows:

Notice of Cancellation (Form #L8145CCN - Edition 003-92)

Colorado Renewal Notice (Form #8231 - 6/95)

Recommendation # 1:

Within 30 days, the Company should be required to provided evidence demonstrating why it
should not be considered in violation of Section 10-3-1104(1)(u), C.R.S., Section 10-4-725,
C.R.S., and Regulation 1-1-6(III)(A)(7). In the event the Company is unable to provide such
documentation, it should be required to provide evidence pertaining to the submission of
forms for Certification to the Colorado Division of Insurance demonstrating that it has
implemented procedures which will ensure compliance with the requirements of the
Colorado Insurance Law.

Issue B: Failure to provide 30 days written notice to the insured as to the Company’s
intention of non-renewing the policy.

Section 10-4-720, C.R.S., Cancellation - renewal - reclassification, states in part:

           (1) Except in accordance with the provisions of this part 7, no insurer shall cancel
           or fail to renew a policy of insurance which complies with this part 7, issued in this
           state, as to any resident of the household of the named insured, for any reason
           other than nonpayment of premium, or increase a premium of any coverage on
           any such policy unless the increase is part of a general increase in premiums
           filed with the commissioner and does not result from a reclassification of the
           insured, or reduce the coverage under any such policy unless the reduction is
           part of a general reduction in coverage approved by the commissioner or to
           satisfy the requirements of other sections of this part 7.

           (2) An insurer intending to take an action subject to the provisions of this section
           shall, on or before thirty (30) days prior to the proposed effective date of the
           action, send written notice by first-class mail of its intended action to the insured
           at his last known address. The notice shall be in triplicate and shall state in clear
           and specific terms, on a form which has been certified by the insurer and the
           insurer has filed a certification with the commissioner that such notice form
           conforms to Colorado law and any rules or regulations promulgated by the
           commissioner:

The following charts illustrate the significance of error versus the population and sample
examined:

        PRIVATE PASSENGER AUTOMOBILE POLICIES NON-RENEWED 1995
    Population           Sample Size          Number of           Percentage to
                                              Exceptions             Sample

         22                   22                    2                   9%


An examination of 22 files representing 100% of all policies non-renewed by the Company in
Colorado during 1995, showed 2 instances (9% of the sample) in which a non-renewal notice
was issued without giving the insured 30 days advance notice of its intent to non-renew the
policy.

       PRIVATE PASSENGER AUTOMOBILE POLICIES SURCHARGED IN 1995


    Population           Sample Size          Number of           Percentage to
                                              Exceptions             Sample

        873                   50                    1                   2%


An examination of 50 files representing 5.7% of all policies non-renewed by the Company in
Colorado during 1995, showed 1 instance (2% of the sample) in which a policy being
surcharged was not given 30 days advance notice of its intent to increase the premium for
the renewal.

Recommendation # 2:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-4-720, C.R.S. In the event the Company is unable to
provide such documentation, it should be required to provide evidence demonstrating that it
has adopted and implemented procedures which will provide at least 30 days notice of its
intention to non-renew or surcharge Automobile policies in compliance with the requirements
of Colorado Insurance Law.

Issue C: Failure of the Company to retain documents for a market conduct exam review.

Section 10-4-413 (1), C.R.S., "Records required to be maintained", states in part that every
insurer:

           …shall maintain reasonable records, of the type and kind reasonably adapted to
           its method of operation, of its experience or the experience of its members and of
           the data, statistics, or information collected or used by it in connection with the
           rates, rating plans, rating systems, underwriting rules, policy or bond forms,
           surveys, or inspections made or used by it, so that such records will be available
           at all reasonable times to enable the commissioner to determine whether such
           organization, insurer, group or association complies with the provisions of this
           part 4 applicable to it.
Additionally, Colorado Regulation 1-1-7(III)(B), Market Conduct Record Retention, states in
part:

B. RECORDS REQUIRED FOR MARKET CONDUCT PURPOSES

           1. Every insurer/carrier or related entity licensed to do business in this state shall
           maintain its books, records, documents and other business records so that the
           insurer's/carrier's or related entity's claims, rating, underwriting, marketing,
           complaint, and producer licensing records are readily available to the
           commissioner. Unless otherwise stated within this regulation, records shall be
           maintained for the current calendar year plus two calendar years.

           2. A policy record shall be maintained for each policy issued in this state. Policy
           records shall be maintained for the current policy term, plus two calendar years,
           unless otherwise contractually required to be retained for a longer period.
           Provided, however, documents from policy records no longer required to be
           maintained under this regulation, which are used to rate or underwrite a current
           policy, must be maintained in the current policy records. Policy records shall be
           maintained so as to show clearly the policy term, basis for rating and, if
           terminated, return premium amounts, if any. Policy records need not be
           segregated from the policy records of other states so long as they are readily
           available to the commissioner as required under this rule. A separate copy need
           not be maintained in the individual policy records, provided that any data relating
           to that policy can be retrieved. Policy records shall include:

a. The application for each policy, if any;

           b. Declaration pages, endorsements, riders, termination notices, guidelines or
           manuals associated with or used for the rating or underwriting of the policy.
           Binder(s) shall be retained if a policy was not issued; and

           c. Other information necessary for reconstruction of the rating and underwriting of
           the policy.

           3. Claim files shall be maintained so as to show clearly the inception, handling
           and disposition of each claim. A claim file shall be retained for the calendar year
           in which it is closed plus the next two calendar years.

The following charts illustrate the significance of error versus the population and sample
examined:

               PRIVATE PASSENGER AUTOMOBILE NON-RENEWALS IN 1995


     Population           Sample Size           Number of           Percentage to
                                                Exceptions             Sample

          22                    22                    1                   4.5%
An examination of 22 files, representing 100% of all policies non-renewed by the Company
in Colorado during 1995, showed 1 instance (4.5% of the sample) in which the Company
failed to produce the file from storage for examination review.

    PRIVATE PASSENGER AUTOMOBILE REJECTIONS / DECLINATIONS IN 1995


    Population           Sample Size           Number of           Percentage to
                                               Exceptions             Sample

         14                    14                    1                   7.1%


An examination of 14 files, representing 100% of all applications/policies declined by the
Company in Colorado during 1995, showed 1 instance (7.1% of the sample) in which the
Company failed to produce a rejected / declined application file from storage for examination
review.

       PRIVATE PASSENGER AUTOMOBILE NEW BUSINESS WRITTEN IN 1995


    Population           Sample Size           Number of           Percentage to
                                               Exceptions             Sample

        7735                  100                   23                   23%


An examination of 100 files, representing 1.3% of all new business applications/policies
written by the Company in Colorado during 1995, showed 23 instances (23% of the sample)
in which the Company did not retain applications needed to examine new business policies
for compliance with Colorado Insurance Law.

Recommendation # 3:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-4-413(1), C.R.S., and Colorado Regulation
1-1-7(III)(B), Record Retention. In the event the Company is unable to provide such
documentation, it should be required to provided evidence demonstrating that has adopted
and implemented procedures for the retention of documents for future examination review
which will ensured compliance with the requirements of Colorado Insurance Law.

Issue D: Failure of the Company’s underwriting guidelines to comply with Colorado
Insurance Law.

Section 10-4-719.7 (1), C.R.S., Refusal to write, changes in, cancellation, or nonrenewal of
policies prohibited, states in part:

           No insurer shall cancel, fail to renew, refuse to write, reclassify an insured under,
           reduce coverage under, unless the reduction is part of a general reduction in
           coverage filed with the commissioner, or increase the premium for, unless the
           increase is part of a general increase in premiums filed with the commissioner,
           any complying policy because the applicant, insured, or any resident of the
           household of the applicant or insured has had an accident or accidents which are
           not the fault of such named applicant, insured, household member, or permissive
           user.

The Company's underwriting manual , under NOT-AT-FAULT ACCIDENTS, states:

           ..."supply the number of Not-at-fault accidents for all non-excluded drivers in the
           household. Not-at-fault accidents are counted if payment is over $500..."

The Company's underwriting procedure of using Not-At-Fault accidents is in direct conflict
with the statute, which prevents a Company from the use of Not-At-Fault accidents for risk
classification, premium considerations, and cancellations.

Recommendation # 4:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-4-719.7, C.R.S. In the event the Company is unable
to provide such documentation, it should be required to provide evidence demonstrating that
it has amended its underwriting rule in regard to the use of Not-At-Fault accidents which will
be in compliance with the requirements of Colorado Insurance Law.

Issue E: Failure to notify the Division of Insurance of producer appointments.

Section 10-2-415, C.R.S., Appointment of insurance producer by insurer - continuation -
exceptions, states in part:

           (1) No insurance producer shall claim to be a representative or authorized or
           appointed agent of, or any other term implying a contractual relationship with, a
           particular insurer or accept applications on behalf of such insurer unless such
           insurance producer becomes a producer appointee, appointed by that insurer in
           accordance with this section, to act in the capacity of an agent of that insurer.

           (2) (a) The insurer shall notify the commissioner of insurance of producer
           appointments. Each insurer shall keep on file with the commissioner a current list
           of insurance producers which it has appointed to solicit business on its behalf.
           The insurer shall file with the commissioner a list of new appointments of
           insurance producers. The list may be submitted to the commissioner monthly or at
           such other intervals as the commissioner may prescribed. The insurer shall report
           all pertinent appointment information as prescribed by the commissioner,
           including the effective date of appointment.

In the review of new business applications submitted to the Company during the examination
period, and a comparison review of the Division of Insurance listing against the Company
listing, the following appointment discrepancies were noted:
           (1) Agents/Agencies were not listed on the Colorado Division of Insurance
           records.

           (2) Agents were not appointed at the time the application for new business was
           submitted.

The following chart illustrates the significance of error versus the population and sample
examined:

       PRIVATE PASSENGER AUTOMOBILE NEW BUSINESS WRITTEN IN 1995


    Population           Sample Size            Number of           Percentage to
                                                Exceptions             Sample

        7735                  100                    31                   31%


An examination of 100 files representing 1.3% of all new business applications/policies
written by the Company in Colorado during 1995, showed 31 instances (31% of the sample)
in which the Company was unable to produce appointment certificates for agents submitting
new business applications.

Recommendation # 5:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-2-415, C.R.S. In the event the Company is unable to
provide such documentation, it should be required to provide evidence demonstrating that it
has audited its current producer appointments and properly notified the Division of Insurance
in order to be in compliance with the requirements of Colorado Insurance Law.

Issue F: Failure to obtain a signed form rejecting uninsured motorist coverage.

Section 10-4-609, C.R.S., Insurance protection against uninsured motorists - applicability,
states in part:

           (1)(a) No automobile liability or motor vehicle liability policy insuring against loss
           resulting from liability imposed by law for bodily injury or death suffered by any
           person arising out of the ownership, maintenance, or use of a motor vehicle shall
           be delivered or issued for delivery in this state with respect to any motor vehicle
           licensed for highway use in this state unless coverage is provided therein,
           supplemental thereto, in limits for bodily injury or death set forth in section
           42-7-103 (2), C.R.S., under provisions approved by the commissioner, for the
           protection of persons insured thereunder who are legally entitled to recover
           damages from owners of operators of uninsured motor vehicles because of
           bodily injury, sickness, or disease, including death, resulting therefrom; except
           that the named insured may reject such coverage in writing.
The following chart illustrates the significance of error versus the population and sample
examined:

       PRIVATE PASSENGER AUTOMOBILE NEW BUSINESS WRITTEN IN 1995


     Population           Sample Size           Number of          Percentage to
                                                Exceptions            Sample

        7735                  100                    1                   1%


An examination of 100 files, representing 1.3% of all new business applications/policies
written by the Company in Colorado during 1995, showed 1 instance (1% of the sample) in
which the Company failed to obtain a signed uninsured motorist rejection form on a new
business application wherein the applicant declined to accept uninsured motorist coverage.

Recommendation #6:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-4-609, C.R.S. In the event the Company is unable to
provide such documentation, it should be required to provided evidence demonstrating that it
will obtain uninsured motorist rejection forms on all new business in order to comply with the
requirements of Colorado Insurance Law

Issue G: Failure to correctly apply a driver exclusion.

Section 10-4-721 (1), C.R.S., Exclusion of named driver, states:

           In any case where an insurer is authorized under this part 7 to cancel or refuse to
           renew or increase the premiums on an automobile liability insurance policy under
           which more than one person is insured because of the claim experience or
           driving record of one or more but less than all of the persons insured under the
           policy, the insurer shall in lieu of cancellation, non-renewal, or premium increase,
           offer to continue or renew the insurance but to exclude from coverage, by name,
           the person whose claim experience or driving record would have justified the
           cancellation or non-renewal. The premiums charged on any such policy
           excluding a named driver shall not reflect the claims, experience, or driving
           record of the excluded named driver.

The following chart illustrates the significance of error versus the population and sample
examined:

       PRIVATE PASSENGER AUTOMOBILE POLICIES SURCHARGED IN 1995


     Population           Sample Size           Number of          Percentage to
                                                Exceptions            Sample
        873                    50                    3                   6%


An examination of 50 files, representing 5.7% of policies surcharged by the Company in
Colorado during 1995, showed 3 instances (6% of the sample) in which the Company
incorrectly applied an exclusion of a driver on the policy.

The Company did not allow an exclusion of a driver on the policy stating that an exclusion
was not allowed for a named insured according to their underwriting guidelines. This
conflicts with the above-captioned Colorado Insurance Law.

Recommendation #7:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-4-721 (1), C.R.S. In the event the Company is
unable to provide such documentation, it should be required to provided evidence
demonstrating that it has amended its procedures to correctly apply all driver exclusions
which will be in compliance with the requirements of Colorado Insurance Law.

Issue H: Surcharging policies in error.

Colorado Regulation 5-2-3 (D)(1)(a), Auto Accident Reparations Act (No-Fault) Rules and
Regulations, by authority of Section 10-4-720, C.R.S., states:

           D. RULES LIMITING INSURERS' ACTIONS TO REFUSE TO WRITE, CANCEL,
           NONRENEW, INCREASE PREMIUM, OR REDUCE COVERAGES.

           1. In reviewing protests under Section 10-4-720, C.R.S. (Cancellations), the
           Division of Insurance will apply the following time limitations:

           a. If the insurer bases its action upon the fact that the insured has been involved
           in an accident which resulted in payment under the policy and/or has been
           convicted of a motor vehicle violation, the insurer may base its action on
           convictions or accidents which occurred during the three (3) year period
           preceding the date of the proposed action. However, in case of non-renewals,
           increase in premiums or reduction in coverage in order to take action upon events
           occurring during this three (3) year period, at least one (1) significant event must
           have occurred during the fifteen (15) month period immediately preceding the
           next renewal date. Cancellations are subject to the restrictions set forth in Section
           10-4-602, C.R.S.

           b. An insurer may exceed the fifteen (15) month period if such renewal is the first
           opportunity to underwrite an additional insured, i.e., new driver in household.
           Surcharge or merit rating changes may only be made on the policy renewal date.

The following chart illustrates the significance of error versus the population and sample
examined:
        PRIVATE PASSENGER AUTOMOBILE POLICIES SURCHARGED IN 1995


     Population            Sample Size          Number of          Percentage to
                                                Exceptions            Sample

         873                     50                  6                   12%


An examination of 50 files, representing 5.7% of policies surcharged by the by the Company
in Colorado during 1995, showed 6 instances (12% of the sample) in which the Company
surcharged a policy based on a violation that occurred more than 15 months prior to the
renewal.

In all 6 exceptions, the Company incorrectly applied a surcharge to policies based on a
violation that occurred more than 15 months prior to the renewal. The Colorado Insurance
Law only allows increasing premiums (surcharges) upon events occurring during a three (3)
year period preceding the date of the proposed action, and at least one (1) significant event
must have occurred during the fifteen (15) month period immediately preceding the next
renewal date.

Recommendation #8:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Colorado Regulation 5-2-3 (D)(1)(a), by authority of Section
10-4-720, C.R.S. In the event the Company is unable to provide such documentation, it
should be required to provided evidence demonstrating that it has amended its procedures to
apply surcharges based on a violations that occur only up to 15 months prior to the renewal
and will be in compliance with the requirements of Colorado Insurance Law.

Additionally, the Company should be required to conduct a self audit of all policies
surcharged in Colorado from January 1, 1995 to present and make remuneration of any
refund due as found by the audit.

                               PERTINENT FACTUAL FINDINGS

                                              for

                                           RATING

Issue I: Failure to file rating plans.

Section 10-3-1104 (1)(f)(II), C.R.S., Unfair Competition-Deceptive Practices, states in part:

            (II) Making or permitting any unfair discrimination between individuals of the
            same class or between neighborhoods within a municipality and of essentially the
            same hazard in the amount of premium, policy fees, or rates charged for any
            policy or contract of insurance, or in the benefits payable thereunder, or in any of
           the terms or conditions of such contract, or in any other manner whatever;

Section 10-4-404.5, C.R.S., Rating plans - property and casualty Type II insurers - rules and
regulations, states:

           The Commissioner may promulgate rules and regulations for type II insurers
           which establish reasonable standards for rating plans, including experience
           rating plans, schedule rating plans, and expense reduction plans, and which are
           designed to modify rates in the development of premiums for individual risks
           insured in the property and casualty insurance market. Such rules and
           regulations may permit recognition of expected differences in loss and expense
           characteristics and shall be designed so that such plans are reasonable and
           equitable in their application and are not unfairly discriminatory. Such rules and
           regulations shall not prevent the development of new rating methods which would
           otherwise comply with this part 4. The rules and regulations may establish
           maximum charges against and credits to the experience rating of an insured that
           may result from the application of a rating plan. The rules and regulations may
           encourage the use of loss control programs, safety programs, and other methods
           of risk management and may require insurers to maintain documentation of the
           basis for the charges and credits applied under any plan. The rules and
           regulation may also require the rating plans to include merit rating to the extent
           feasible.

Additionally, Colorado Regulation 5-1-10 (III)(B)(1), Rate and Rule filing requirements,
promulgated under the authority of Section 10-1-109, C.R.S., states:

B. RATE AND RULE FILING REQUIREMENTS.

1. Every property and casualty insurer, including workers' compensation and title insurers,
are required to file insurance rates, minimum premiums, schedule of rates, rating plans,
dividend plans, individual risk modification plans, deductible plans, rating classifications,
territories, rating rules, rate manuals and every modification of any of the foregoing which it
proposes to use. Such filings must state the proposed effective date thereof, and indicate the
character and extent of the coverage contemplated.

The Company began writing Private Passenger Automobile policies in the State of Colorado
in June 1994. At that time, they filed base rates and actuarial support with the Division of
Insurance but failed to file the rating plan itself. The rating plan contains various factors such
as the age of the driver, sex, territory in which the vehicle is garaged, and type of vehicle, all
of which are used in arriving at the final actual premium charged. Policy premium cannot be
determined without the use of these factors.

Recommendation #9:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-3-1104 (1)(f)(II), C.R.S., Section 10-4-404.5, C.R.S.,
and Colorado Regulation 5-1-10(III)(B)(1). In the event the Company is unable to provide
such documentation, it should be required to provide evidence demonstrating that it has a
complete understanding of the Colorado Insurance Law regarding rate filings .

Issue J: Failure to correctly rate new business applications.

Section 10-3-1104 (1)(f)(II), C.R.S., Unfair Competition-Deceptive Practices, states in part:

           Making or permitting any unfair discrimination between individuals of the same
           class or between neighborhoods within a municipality and of essentially the same
           hazard in the amount of premium, policy fees, or rates charged for any policy or
           contract of insurance, or in the benefits payable thereunder, or in any of the terms
           or conditions of such contract, or in any other manner whatever,

Section 10-4-404.5, C.R.S., Rating plans - property and casualty Type II insurers - rules and
regulations, states:

           The Commissioner may promulgate rules and regulations for type II insurers
           which establish reasonable standards for rating plans, including experience
           rating plans, schedule rating plans, and expense reduction plans, and which are
           designed to modify rates in the development of premiums for individual risks
           insured in the property and casualty insurance market. Such rules and
           regulations may permit recognition of expected differences in loss and expense
           characteristics and shall be designed so that such plans are reasonable and
           equitable in their application and are not unfairly discriminatory. Such rules and
           regulations shall not prevent the development of new rating methods which would
           otherwise comply with this part 4. The rules and regulations may establish
           maximum charges against and credits to the experience rating of an insured that
           may result from the application of a rating plan. The rules and regulations may
           encourage the use of loss control programs, safety programs, and other methods
           of risk management and may require insurers to maintain documentation of the
           basis for the charges and credits applied under any plan. The rules and
           regulation may also require the rating plans to include merit rating to the extent
           feasible.

Additionally, Colorado Regulation 5-1-10 (III)(B)(1), Rate and Rule Filing, promulgated under
the authority of Section 10-1-109, C.R.S., states:

B. RATE AND RULE FILING REQUIREMENTS.

1. Every property and casualty insurer, including workers' compensation and title insurers,
are required to file insurance rates, minimum premiums, schedule of rates, rating plans,
dividend plans, individual risk modification plans, deductible plans, rating classifications,
territories, rating rules, rate manuals and every modification of any of the foregoing which it
proposes to use. Such filings must state the proposed effective date thereof, and indicate the
character and extent of the coverage contemplated.

The following chart illustrates the significance of error versus the population and sample
examined:
       PRIVATE PASSENGER AUTOMOBILE NEW BUSINESS WRITTEN IN 1995


    Population           Sample Size           Number of          Percentage to
                                               Exceptions            Sample

        7735                  100                    3                   3%


An examination of 100 files, representing 1.3% of all new business applications/policies
written by the Company in Colorado during 1995, showed 3 instance (3% of the sample)
wherein the Company used the incorrect rates in producing new business applications.

Recommendation #10:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Section 10-3-1104 (1)(f)(II), C.R.S., Section 10-4-404.5, C.R.S.,
and Colorado Regulation 5-1-10 (III)(B)(1). In the event the Company is unable to provide
such documentation, it should be required to provide evidence demonstrating that it has
instituted a system to ensure the use of correct rates in processing new business
applications which will promote compliance with the requirements of Colorado Insurance
Law.

                            PERTINENT FACTUAL FINDINGS

                                             for

                                    CLAIMS PRACTICES

Issue K: Failure of the Company to obtain specific written authorization from the insured
before issuing drafts to any person other than the insured.

Colorado Regulation 5-1-5 (III), Unfair Claims Settlement Practices, under the authority of
Section 10-1-109, C.R.S., requires that:

           No insurer shall attempt to settle any claim made by their insured by means of
           ordering claim checks, drafts or other choses-in-action payable to any person
           other than their insured (s), without specific written assignment thereof by the
           insured.

The following chart illustrates the significance of error versus the population and sample
examined:

 PRIVATE PASSENGER AUTOMOBILE 1ST PARTY COMPREHENSIVE & COLLISION
                         CLAIMS PAID-1995


    Population           Sample Size           Number of          Percentage to
                                               Exceptions            Sample
        1487                   50                    1                   2%


An examination of 50 systematically selected claim files, representing 3.4% of all
comprehensive and collision claims paid by the Company in 1995, showed one (1) instance
(2% of the sample) in which the Company issued a check made payable to a third-party
without a specific written assignment from the insured.

Recommendation # 11:

Within 30 days, the Company should provide written documentation demonstrating why the
Company should not be considered in violation of Section 10-1-109, C.R.S., and Colorado
Insurance Regulation 5-1-5 (III). In the event the Company is unable to provide such
documentation, it should be required to provide written procedures showing that prior written
assignment from the insured is required before checks are issued to a third party ensuring
compliance with Colorado Insurance Law.

Issue L: Failure to pay insurance claims in accordance with policy provisions and / or written
Company claims handling procedures.

Section 10-3-1104(1)(h)( VI ), C.R.S., defines an unfair claims settlement practice as:

           Not attempting in good faith to effectuate prompt, fair, and equitable settlements
           of claims in which liability has become reasonably clear.

The following chart illustrates the significance of error versus the population and sample
examined:

      PRIVATE PASSENGER AUTOMOBILE CLAIMS IN WHICH A VEHICLE WAS
                     DECLARED A TOTAL LOSS IN 1995


    Population           Sample Size           Number of           Percentage to
                                               Exceptions             Sample

         225                   50                    2                   4%


An examination of 50 files, representing 22.2% of claims paid by the Company in 1995 in
which a vehicle was declared a total loss, showed 2 instances (4% of the sample) wherein
the Company either failed to pay the claims in accordance with their claims manual or failed
to pay the claims in accordance with auto policy provisions.

In one instance, the Company underpaid a total loss claim in the amount of $280 on the
basis of an calculation error in applying an incorrect deductible amount to the final settlement
of the claim.

In the other instance, the Company overpaid the total loss claim in the amount of $698.84. It
allowed the insured to retain the salvage but failed to deduct the value from the final
settlement amount paid to the insured. This is in conflict with the Company’s claims handling
procedures which requires that when the salvage is retained by the insured, the salvage
amount is to be deducted from the total loss final payment. While the Colorado portion of the
Claim Manual does not specifically outline this procedure, the Company total loss worksheet
indicates that the salvage value is to be deducted. In all other total loss claims examined,
where salvage was retained, the value was deducted from the amount payable to the
insured.

Recommendation # 12:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered to be in violation of Section 10-3-1104(1)(h)(VI), C.R.S. In the event the
Company is unable to provide such documentation, the Company should be required to
provide evidence that it has reviewed its procedures concerning total losses in order to
ensure compliance with the Colorado Insurance Law.

Issue M: Failure of the Company to provide the appropriate statement setting forth coverage
under which payments were made to the insured.

Section 10-3-1104, C.R.S., Unfair methods of competition and unfair or deceptive acts or
practices:

           (1) The following are defined as unfair methods of competition and unfair or
           deceptive acts or practices in the business of insurance…

           (h) Unfair Claims Settlement practices: committing or performing, either in willful
           violation of this part 11 or with such frequency as to indicate a tendency to
           engage in a general business practice, any of the following:

           (x) Making claims payments to insureds or beneficiaries not accompanied by a
           statement setting forth the coverage under which the payments are being made;

The following charts illustrate the significance of error versus the population and sample
examined:

 PRIVATE PASSENGER AUTOMOBILE 1 st PARTY COMP/COLL CLAIMS PAID IN 1995


    Population           Sample Size           Number of           Percentage to
                                               Exceptions             Sample

        1487                   50                    1                   2%


An examination of 50 files, representing 3.4% of all claims paid by the Company in Colorado
during 1995, showed 1 instance (2% of the sample) wherein the Company failed to provide
the appropriate statement setting forth coverage under which payments were made to the
insured.

           PRIVATE PASSENGER AUTOMOBILE SUBROGATION CLAIMS IN 1995


    Population          Sample Size           Number of          Percentage to
                                              Exceptions            Sample

           378                50                   1                   2%


An examination of 50 files, representing 13.2% of all subrogation claims for the Company in
Colorado during 1995, showed 1 instance (2% of the sample) wherein the Company failed to
provide the appropriate statement setting forth coverage under which payments were made
to the insured.

            PRIVATE PASSENGER AUTOMOBILE UM/UIM CLAIMS PAID IN 1995


    Population          Sample Size           Number of          Percentage to
                                              Exceptions            Sample

           46                 46                   2                  4.3%


An examination of 46 files, representing 100% of all UM/UIM claims paid by the Company in
Colorado during 1995, showed 2 instances (4.3% of the sample) wherein the Company
failed to provide the appropriate statement setting forth coverage under which payments
were made to the insured.

      PRIVATE PASSENGER AUTOMOBILE TOTAL LOSS CLAIMS PAID IN 1995


    Population          Sample Size           Number of          Percentage to
                                              Exceptions            Sample

           225                50                   9                  18%


An examination of 50 files, representing 22.2% of all total loss claims for the Company in
Colorado during 1995, showed 9 instances (18% of the sample) wherein the Company failed
to provide the appropriate statement setting forth coverage under which payments were
made to the insured.

Recommendation # 13:

Within 30 days, the Company should provide written documentation demonstrating why it
should not be considered in violation of 10-3-1104 (1)(h)(x), C.R.S. In the event the Company
is unable to provide such documentation, it should be required to provide evidence
demonstrating the Company has reviewed its procedures to provide the appropriate
statement setting forth coverage under which payments were made to the insured and is in
compliance with Colorado Insurance Law.

Issue N: Delay of PIP benefit payments.

Section 10-4-708(1), C.R.S., requires in part, that:

           Payment of benefits under the coverage enumerated in section 10-4-706(1)(b) to
           (1)(e) or alternatively, as applicable, section 10-4-706(2) or (3) shall be made on a
           monthly basis. Benefits for any period are overdue if not paid within thirty days
           after insurer receives reasonable proof of the fact and amount of expenses
           incurred during that period; except that an insurer may accumulate claims for
           periods not exceeding one month, and benefits are not overdue if paid within
           fifteen days after the period of accumulation. If reasonable proof is not supplied
           as to the entire claim, the amount supported by reasonable proof is overdue if not
           paid within thirty days after such proof is received by the insurer. Any part or all of
           the remainder of the claim that is later supported by reasonable proof is overdue
           if not paid within thirty days after such proof is received by the insurer. In the
           event that the insurer fails to pay such benefits when due, the person entitled to
           such benefits may bring action in contract to recover the same.

Colorado Regulation 5-2-8 (III), Timely Payment of Personal Injury Benefits, (A)(B), Rules,
states:

           A. Section 10-4-708(1), C.R.S., provides that benefits under the coverages
           enumerated in §10-4-706 are overdue if not paid within thirty days after the
           insurer receives reasonable proof of the fact and amount off expenses incurred.

           B. In the usual case, for purposes of triggering the thirty-day time period in section
           10-4-708(1), C.R.S., the following documents are sufficient to establish
           reasonable proof of the fact and amount of the expenses incurred:

           1.   A properly executed application for benefits from the PIP claimant;

           2. A notice to an insurer which meets the requirements of Section 10-4-708.5,
           C.R.S.; and

           3. A billing statement for a procedure or treatment, which is subject to the
           obligations of Section 10-4-708.6, C.R.S.

The following chart illustrates the significance of error versus the population and sample
examined:

PRIVATE PASSENGER AUTOMOBILE PERSONAL INJURY PROTECTION BENEFITS
                           PAID IN 1995


      Population          Sample Size        Number of         Percentage to
                                            Exceptions           Sample

          488                   50               20                40%


An examination of 50 systematically selected files, representing 10.2% of all personal injury
protection benefit claims paid by the Company in 1995, showed 20 instances (40% of
sample) wherein the Company failed to pay PIP claims within the statutory standard of 30
days.

Recommendation #_14:

Within 30 days, the Company should provide written documentation demonstrating why it
should not be considered in violation of Section 10-4-708(1), C.R.S., and Colorado
Regulation 5-2-8 (III). In the event the Company is unable to provide such documentation, it
should be required to provide evidence demonstrating the Company has reviewed its
procedures pertaining to timely PIP benefit payments and show that the Company has
implemented procedures which will ensure future compliance with the Colorado Insurance
Law.

Issue O: Failure to obtain specific written assignment from insureds prior to making direct
payment of PIP benefits to health care providers.

Section 10-4-708.4(1)(a), C.R.S., provides for the direct payment of benefits as follows:

           A policy of motor vehicle insurance which provides coverage pursuant to this part
           7 shall allow, but not require, an insured under the policy to assign, in writing,
           payments due under the policy to a licensed hospital or other licensed health
           care provider for services provided to the insured which are covered under the
           policy.

Section 10-4-708.4(2), C.R.S., provides in part, that:

           When a licensed hospital or other licensed health care provider receives an
           assignment from an insured, it is the responsibility of the provider to bill the
           insurer, including a copy of the assignment. The provider shall also provide a
           copy of such bill to the insured, stating on such copy that it is for informational
           purposes only and that the insurer has been billed for covered benefits. The
           provider shall also furnish to the insurer a current taxpayer identification number
           as part of the initial bill and each subsequent billing. Subsequent billing to an
           insurer need not include a copy of the assignment unless required by the insurer
           so long as it is clearly noted on each such subsequent billing that the benefits
           have been assigned. The insurer shall honor such assignment and make
           payment of covered benefits directly to such licensed hospital or other licensed
           health care provider.

In addition, Colorado Insurance Regulation 5-1-5 (III), authorized by Section 10-1-109(1),
C.R.S., states:
           No insurer shall attempt to settle any claim made by their direct insured by means
           of ordering claim checks, drafts or other choses-in-action payable to any person
           other than their insured(s) without specific written assignment thereof by the
           insured.

The following chart illustrates the significance of error versus the population and sample
examined:

PRIVATE PASSENGER AUTOMOBILE PERSONAL INJURY PROTECTION BENEFITS
                           PAID IN 1995


    Population           Sample Size           Number of          Percentage to
                                               Exceptions            Sample

        488                    50                   10                  20%


An examination of 50 systematically selected files, representing 10.2% of all personal injury
protection benefit claims paid by the Company in 1995, showed 10 instances (20% of the
sample) wherein the Company failed to obtain written assignments from insureds prior to
making direct payment of PIP benefits to health care providers.

Recommendation # 15:

Within 30 days, the Company should provide written documentation demonstrating why the
Company should not be considered in violation of Section 10-4-708.4(1)(a) and (2), C.R.S.,
and Colorado Insurance Regulation 5-1-5 (III). In the event the Company is unable to provide
such documentation, it should be required to provide written procedures showing that prior
written assignment from the insured is required before making direct payment of personal
injury protection benefits.

Issue P: Failure of the Company to reimburse the correct amount of the insured’s deductible
interest in the Company’s subrogation recovery.

Section 10-3-1104 (1)(h)(VI), C.R.S., Unfair methods of competition and unfair or deceptive
acts or practices, states:

           Not attempting in good faith to effectuate prompt, fair, and equitable settlements
           of claims in which liability has become reasonably clear,…

The following chart illustrates the significance of error versus the population and sample
examined:

     PRIVATE PASSENGER AUTOMOBILE SUBROGATION CLAIMS PAID IN 1995


    Population           Sample Size           Number of          Percentage to
                                               Exceptions            Sample
        378                    50                    1                   2%


An examination of 50 systematically selected files, representing 13.2% of all subrogation
claims pursued by the Company in 1995, showed one (1) instance (2% of the sample)
wherein the Company failed to reimburse the correct amount of the insured’s deductible
interest in the Company’s subrogation recovery.

Recommendation #16:

Within 30 days, the Company should provide documentation demonstrating why it should not
be considered to be in violation of Section 10-3-1104 (1)(h)(VI), C.R.S. In the event the
Company is unable to provide such documentation, the Company should be required to
provide evidence that it has reviewed all related procedures and has implemented all
necessary changes to assure that the insured’s interest is addressed in subrogation in order
to fall in compliance with the Colorado Insurance Law.

Issue Q: Failure to adequately document claim files when determining total loss payments

Colorado Regulation 1-1-7, (Record Retention), under the authority of Section 10-1-109,
C.R.S., states in part:

           3. Claim files shall be maintained so as to show clearly the inception, handling
           and disposition of each claim. A claim file shall be retained for the calendar year
           in which it is closed plus the next two calendar years.

The following chart illustrates the significance for error versus the population and sample
examined:

      PRIVATE PASSENGER AUTOMOBILE TOTAL LOSS CLAIMS PAID IN 1995


    Population           Sample Size           Number of           Percentage to
                                               Exceptions             Sample

        225                    50                    3                   6%


An examination of 50 files, representing 22.2% of all total loss claims for the Company in
Colorado during 1995, showed 3 instances (6% of the sample) in which the file
documentation was inadequate to allow the examiners to determine whether or not the
Company’s determination of the payment complied with Colorado Insurance Laws.

In all 3 instances the Company claim files did not contain documentation to support the total
loss payments that were made.

Recommendation # 17:
Within 30 days, the Company should provide documentation demonstrating why it should not
be considered in violation of Colorado Regulation 1-1-7, Record Retention. In the event the
Company is unable to provide such documentation , it should be required to provide
evidence demonstrating that it has adopted and implemented procedures for the retention of
these documents for future examination review which will ensure compliance with the
requirements of Colorado Insurance Laws.

                     SUMMARY OF RECOMMENDATIONS LOCATOR

                      ISSUE                  RECOMMENDATION            PAGE #

  A    Failure to submit forms for                    1                   8
       Certification to the Colorado
       Division of Insurance.

  B    Failure to provide 30 days written             2                  10
       notice to the insured as to the
       Company’s intention of
       non-renewing the policy.

  C    Failure of the Company to retain               3                  12
       documents for a market conduct
       exam review.

  D    Failure of the Company’s                       4                  13
       underwriting guidelines to comply
       with Colorado Insurance Law.

  E    Failure to notify the Division of              5                  15
       Insurance of producer
       appointments.

  F    Failure to obtain a signed form                6                  16
       rejecting uninsured motorist
       coverage.

  G    Failure to correctly apply a driver            7                  17
       exclusion.

  H    Surcharging policies in error.                 8                  19

  I    Failure to file rating plans.                  9                  22

  J    Failure to correctly rate new                  10                 24
       business applications.
K    Failure of the Company to obtain                          11                         26
     specific written authorization from
     the insured before issuing drafts to
     any person other than the insured.

L    Failure to pay insurance claims in                        12                         27
     accordance with policy provisions
     and / or written Company claims
     handling procedures.

M    Failure of the Company to provide                         13                         29
     the appropriate statement setting
     forth coverage under which
     payments were made to the
     insured.

N    Delay of PIP benefit payments.                            14                         31

O    Failure to obtain specific written                        15                         33
     assignment from insureds prior to
     making direct payment of PIP
     benefits to health care providers.

P    Failure of the Company to                                 16                         34
     reimburse the correct amount of
     the insured’s deductible interest in
     the Company’s subrogation
     recovery.

Q    Failure to adequately document                            17                         35
     claim files when determining total
     loss payments

                              Independent Market Conduct Examiners

                                    LARRY N. CAMPBELL, CIE

                                     LUCILLE E. WHITTLE, CIE

                                      JAMES T. AXMAN, AIE

                participated in this examination and in the preparation of this report.



    For comments or questions, send email to:kirk.yeager@dora.state.co.us

    Last modified 3/19/98

								
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