Order Summary
$950,000 fine with $200,000 suspended and a compliance plan for Ace American Insurance Company allowing the Healthy Paws website to operate without identifying Ace as the insurer, allowing Healthy Paws to send emails that did not identify Ace as the insurer, allowing Healthy Paws to distribute brochures that did not identify Ace by name or provide Ace’s domicile, failing to identify its legal name on Healthy Paws’ website, using rates different from those filed with and approved by the Insurance Commissioner, Ace violated RCW 48.05.190(1); WAC 284-30-670(4); RCW 48.30.050; RCW 48.19.040(6); thousands of times, justifying the imposition of a fine under RCW 48.05.185 and RCW 48.19.430.
Indemnity Insurance Company of North America for allowing Healthy Paws to produce policies for Indemnity without being properly appointed, using outdated declarations pages in its pet health insurance policy forms and pet health insurance notices for 1,180 Washington consumers and 1,509 pets, increasing the pet age factor annually contrary to language filed with and approved by the Insurance Commissioner indicating the pet age factor remained constant over the life of the policy, Indemnity violated RCW 48.17.160(1); RCW 48.17.160(2); RCW 48.18.140(2)(f); RCW 48.18.520; RCW 48.18.100(1); RCW 48.19.040(6); thousands of times, justifying the imposition of a fine under RCW 48.05.185 and RCW 48.19.430.
Ace American Insurance Company and Indemnity Insurance Company of North America for cancelling consumer policies without providing the required 10 day advanced notice, allowing Healthy Paws to circulate inaccurate information about the required cancellation procedure, producing documents with inconsistent information on said cancellation procedure, using the pet health change policy form as a renewal despite the form language explicitly prohibiting such use, applying the experience rating plan contrary to the approved filing, capping the applicable discounts at 10% total where the filing contained no such limitation, and increasing rates at the anniversary adjustment without providing 20 business days advance notice of the rate adjustment, the Companies violated RCW 48.18.290(1)(c); RCW 48.30.090; RCW 48.18.140(2)(f); RCW 48.18.520, RCW 48.18.100(1); RCW 48.19.040(6); and RCW 48.18.2901(1)(b); justifying the imposition of a fine under RCW 48.05.185 and RCW 48.19.430.
