#404 | Who Killed PHL Variable?
Introduction
I have to start this article with an admission. When I first saw the news about PHL Variable Insurance Company (PHLVIC) being put under administration and then rehabilitation by the State of Connecticut, I didn’t think much of it. PHL Variable – what is that? At first, I thought it was something related to Philadelphia Life, a company that was owned by Conseco, or maybe Philadelphia Financial, a PPLI provider that is now part of Lombard. Then I heard that PHL Variable was actually part of Nassau (not technically true, as it turns out) and had an enormous negative RBC ratio related to some sort of reinsurance recapture. My first reaction was that if PHL Variable primarily wrote variable products, then it probably had a very thin capital and RBC requirement. A mere accounting or timing problem could crush the RBC for reporting purposes and Nassau would quickly correct it. Surely. Right?
Wrong – and wrong on so many fronts. The first indication that PHL Variable wasn’t what I thought it was came when a friend of mine pulled me aside after I spoke at a meeting a few weeks ago to show me some PHL Variable in-force illustrations for a client that he’d picked up. What was at stake wasn’t some small variable life or annuity policy. His client owned 20-year-old PHL Variable policies with tens of millions of dollars of death benefit spread out over survivorship and individual Universal Life coverage. The entire estate plan was essentially tied up in PHL Variable policies. Then I started to dig. The second indication came when I realized that the COI lawsuits that embroiled Phoenix a few years ago weren’t over Phoenix Life Insurance Company policies but PHL Variable. This ambiguously and incorrectly named little company was actually at the heart of a much bigger narrative.
A Brief History of PHL Variable
Phoenix was purchased by Nassau Re in 2015 and PHL Variable was included as part of the transaction. Nassau Re is owned by Golden Gate Capital, a private equity firm based in San Francisco. Nassau Re wrote fixed annuities, indexed annuities and life insurance out of PHL Variable until 2019, when it transitioned new product sales to Phoenix Life Insurance Company and Phoenix Life and Annuity, both of which had been recently rechristened to reflect the Nassau name.
In that same year, Connecticut allowed PHL Variable to reinsure its entire life and annuity blocks to a captive reinsurer, Concord Re. Simultaneously, Concord Re received support through an Excess of Loss (XOL) reinsurance agreement from an offshore Nassau Re subsidiary. We can presume that the reason Concord Re was established was so that Concord Re could book the XOL reinsurance as an asset for the purposes of providing a reserve credit back to PHL Variable, which improved the overall capitalization of the entity while keeping Nassau Re (the parent) on the hook for excess losses at PHL Variable.
In 2021, the Connecticut Insurance Department allowed for Nassau Re to formally transfer ownership of PHL Variable to GG Holdings, a direct subsidiary of Golden Gate Capital, and to transfer the XOL reinsurance agreement to a newly established and capitalized captive reinsurer, Palisado Re, and an additional capital contribution of $30 million from Nassau Re. It was, essentially, a way for Nassau Re to end its ongoing exposure and commitments to PHL Variable and at the time, all parties agreed that PHL Variable was in fine shape and could continue to operate as a standalone entity. The company actually posted a small net operating gain in 2022 and a small net loss due to other factors, including realized capital losses, a problem at many other insurers as well. The filing states that there was no doubt over PHL Variable’s ability to continue as a going concern.
And then, in 2023, things started going off the rails. Connecticut put the company under administration in March. The company posted $162 million statutory loss for the year. Surplus plummeted from $45 million at the end of 2022 to negative $135 million at the end of 2023. In the statutory statement, the notes say that “Management has…concluded that there is substantial doubt about the Company’s ability to continue as a going concern…[and that] a regulatory action, whereby the Department assumes control of PHL, would not be precluded at any time during the next twelve months.” The cause? Reinsurance. As the notes say, “The Concord Treaty provides PHL with reserve relief…the value of the underlying collateral [at Concord] deteriorated supporting this treaty declined significantly…[resulting] in a charge of $176 million.”
By the end of the first quarter of this year, the situation had gotten materially worse. Losses for that quarter alone were nearly $28 million, virtually all of which was from Concord. Surplus dropped to negative $162 million. On May 20th, the Connecticut Insurance Department filed a suit to place the company under rehabilitation. The court documents are stunning. According to the affidavit filed by the examiner, Michael Shanahan, the Department hired outside actuarial and financial counsel to evaluate the models used by PHL Variable and provide updated assumptions. The new projections showed that PHL Variable’s assets would be exhausted by 2030 with $1.46 billion in unpaid policyholder liabilities. The net present value of the future inadequacy of the assets creates a current surplus of “approximately negative $900 million.”
Rehabilitation
The framework for rehabilitation is to lock down the asset base so that the Department can do what they have to do to salvage as much benefit as possible for policyholders. There are some minimum benefits available to policyholders because of coverage from the state guaranty funds. General Account and non-unitized Separate Account policyholders have zero access to cash values for surrenders, withdrawals or policy loans, but death benefits are payable up to $300,000 and annuity benefits are payable up to a cumulative amount of $250,000. Unitized Separate Account policyholders have full access to their funds, but death benefits or income benefits funded by the General Account are capped at the same $300k/$250k. If ever you wanted the perfect case study for when policyholders have real and tangible protection from unitized separate accounts in variable life insurance and annuity products, this is it.
There is roughly $1 billion of General Account and non-unitized Separate Account value tied up in life insurance and annuity products that will not be accessible to policyholders. Annuitants who are already receiving payouts are capped at $250,000 in cumulative distributions. Policyholders who have not started taking income are not allowed to trigger income payouts. This is a disaster, to put it mildly, considering that the vast majority of annuities sold by PHL Variable have guaranteed income benefits.
But those problems are nothing compared to what policyholders with large death benefits will face. Phoenix marketed itself as a company focused on the very upper echelon of the market. Consider a policy with a $12 million death benefit and a little over $1 million in (now inaccessible) cash value. The client is attained age 85 and uninsurable. Without any additional premiums, the policy will lapse in 4 years. The premiums to maintain the coverage for another 4 years are around $400,000 per year.
This client is faced with a real conundrum. If they don’t pay the premium, the policy will lapse. If they do pay the premium, they may end up paying an extra $1.6 million and only get $300,000 back. And this client is lucky because they get the choice. The Guaranteed UL policyholders with some $1.6 billion of in-force death benefit have to pay the premiums or they lose the coverage. Talk about putting good money after bad.
The downfall of PHL Variable is an unmitigated disaster for the life insurance industry. If the Connecticut Insurance Department is correct in its projections, then this may be the first time in history that death benefits are not fully paid. There simply won’t be enough assets to do it. The company has around $30 billion of outstanding death benefit. Around $18.6 billion is reinsured to third party reinsurers, which leaves $11.4 billion or so stranded (and presumably unreinsured) at Concord Re. If there’s an asset hole of $1.46 billion by 2030, just imagine what it would look like in 2040. This is the equivalent of SVB going under in that the majority of depositors weren’t covered by FDIC insurance. The same is true for PHL Variable policyholders who average $586,210 of death benefit according to the 2023 statement, nearly double the $300,000 guaranteed payout.
Now, to the real question – how did this happen? Because PHL Variable failed on Nassau and Golden Gate’s watch, it is very tempting to blame them for what happened. Some observers have already drawn that conclusion and I think it’s the wrong one. This is not an example of offshore reinsurance gone bad. This is not a case where affiliated assets caused a problem. This is not a situation where the parent company scraped the insurance entity clean with dividends and left it to die. We have seen all of those things happen at other firms, but not here. Who killed PHL Variable? The company died on Golden Gate’s watch, but it died because of a terminal disease that it contracted while it was owned by Phoenix. To understand what happened, we have to go back to the beginning.
The Real History of PHL Variable
PHL Variable was founded in 1981 as a subsidiary of what was then Phoenix Mutual Life. In 2001, the company demutualized and became The Phoenix Companies, trading under the ticker PNX. Around the same time, it appears that Phoenix decided to shift its strategy for writing business. Its primary life insurance subsidiary, Phoenix Life Insurance Company, was domiciled in New York. Most demutualized insurers had pursued a 49/1 strategy in order to remain competitive by avoiding NY regulations on non-NY activity. It seems that Phoenix dusted off PHL Variable and effectively turned it into the non-NY writing entity for Phoenix life insurance and annuities. Maine and Puerto Rico also continued to use Phoenix Life Insurance Company*.
We can see the effect in the filings of the companies. Statutory reports list reserves by age ranges and CSO vintages. Read carefully and you can patch together the history of the policies on an insurance company’s balance sheet. Take a look at the cumulative life insurance reserves of Phoenix Life Insurance Company and PHL Variable over time with reserves tagged to the first year of the tranche.
Phoenix Life Insurance Company’s life reserves are, essentially, old-line Whole Life and Universal Life policies. PHL Variable’s policies, by contrast, are predominately Guaranteed UL and Universal Life written prior to 2009. What was being sold in the mid-2000s? A lot of high-end, estate planning-oriented life insurance, to be sure, and Phoenix got their fair share of that. But they also sold a lot of STOLI. We’ve seen that from court proceedings where institutional buyers of life insurance policies have sued PHL Variable over COI increases. And anyone who was involved in the industry at the time would tell you that they saw it first-hand. A lot of sales people got rich – very rich – promoting and facilitating STOLI transactions at Phoenix.
At the time, there was a question as to whether or not STOLI would actually be bad for insurance companies. It pretty clearly ran afoul of insurable interest laws, although there was a lot of gray area at the time. It certainly required that life insurance violate their own financial underwriting standards. It created a high concentration of older clients, but the carriers were charging premiums appropriately. So while it was a shady and bizarre business practice, the jury was and is still out about whether or not it was toxic for insurers.
Consider PHL Variable to be the definitive answer. Yes, it is toxic for insurers. PHL Variable’s statutory statements specifically point out “adverse mortality experience in the universal life business” as the primary reason for the “deteriorating financial condition of the Company.” The Connecticut Department of Insurance draws a similar conclusion, pointing out that “Phoenix Accumulator Universal Life (PAUL), which was the primary universal life policy sold by PHL Variable until 2009…were to policyholders with issue ages over 70 and high face amounts. A material number of those policies were later sold by policyholders to unrelated third party investors…these policies comprise PHL’s most unprofitable block and are a major cause of the continued deterioration of the Companies’ financial condition.”
The problem with STOLI policies is also explained in the affidavit, saying “the investor-owned policies are problematic for PHL because the investors typically only pay the minimum premium required to keep the policy in force. The policies were priced under the assumption that the policyholders would pay significantly more than the minimum premium…this would have provided more funds that PHL could have invested before being required to pay death benefits.” For anyone who is familiar with life settlements in general and STOLI in particular, this comes as no surprise. The whole deal is contingent on mortality arbitrage. If the insurer has priced the life expectancy at 88 and the investor thinks it’s actually 83, then why pay anything more than the minimum premium?
6/13 Update – Someone who I really respect read this article and pointed out that calling all of the problematic business at PHL Variable “STOLI” was painting with too broad of a brush. It’s a very fair point. Phoenix certainly wrote a lot of STOLI, but they were also involved in numerous “hybrid” transactions that weren’t strictly STOLI. But they’d committed another great sin too – they’d completely mispriced their products. Even non-STOLI/hybrid folks were minimum funding their PAUL products because there was clear mortality arbitrage in the way that Phoenix had priced it. The actuaries made a lot of unforced, rookie errors in pricing their UL products that led to much of the abuse and they were incredibly slow to acknowledge and fix the issues. The one pricing error that sticks out to me is that they’d priced their Guaranteed UL and SUL policies so that you could pay one Target premium and get coverage, in some cases, for 30-40 years with no additional premium. Agents sold the daylights out of that and often bought those policies on themselves. I remember having a conversation with an agent who had bought one on himself in 2009 and we discussed whether we thought Phoenix would even be there to pay the claim. His point was, basically, that he didn’t care because it was free insurance. He was right. He may just end up getting a lot less free insurance than he thought.
We can see that dynamic playing out in PHL Variable’s books. For Phoenix’s Guaranteed UL business, which was not (in my experience) oriented towards STOLI, the ratio of premiums to reserves is around 27-to-1. Phoenix sold extremely cheap Guaranteed UL and it shows. For Phoenix’s Universal Life business, which is primarily STOLI-oriented, the ratio is just 1.5. In other words, the average UL policy on the books at PHL Variable has $1.5 of cash value for every $1 of premium. What is that telling us? That these policies are being minimally funded on a systematic basis by most of the block because the average cash value is just 1.5 times the average premium.
So how big is the problem for PHL Variable? The outstanding Universal Life death benefit that has been reinsured to Concord Re is a whopping $5.3 billion. Besides Term, it is by far the largest outstanding death benefit at PHL Variable. In 2023, PHL Variable paid $670 million in death benefits. Some of that was Term, to be sure, but I’ll bet that quite a bit of it was on the UL line. And from what I can tell, the Universal Life death benefits don’t have much third party reinsurance, potentially because they were STOLI transactions and the reinsurers wouldn’t take them. However, Phoenix had a high enough retention (up to $5 million in 2008) to retain the vast majority of cases anyway. It’s a shame for policyholders that they did.
The Slow Descent of PHL Variable
The net effect of the life insurance business on PHL Variable has been catastrophic. Below is a table showing cumulative earnings at PHL Variable from 2009-2023. Yellow is the life insurance business and blue is the annuity business. The gray line shows the cumulative net earnings.
Aside from 2010-2012 and the immediate aftermath of the Concord Re transaction, the life business at PHL Variable has been consistently losing money. All told, life insurance has racked up cumulative losses of just over $700 million. Meanwhile, the annuity business has generated a little under $400 million in cumulative earnings – and most of that is actually from variable annuities, not FIAs**.
What becomes increasingly clear in looking at these charts is that PHL Variable was losing money before Nassau bought it. Without the earnings contribution of the annuity block, PHL Variable probably would have gone belly up as early as 2014. But on the whole, PHL Variable probably seemed fairly stable to Nassau, who purchased all of Phoenix for just over $200 million. They presumably didn’t know how incredibly toxic the STOLI block was or would turn out to be, but they also had to have known they were taking a risk by bringing on PHL Variable.
If they didn’t know when they bought it, they surely did within a couple of years. The pace of losses in the life business picked up substantially from 2016 to 2018. What did Nassau do? They put more capital into the business, a total of nearly $210 million through 2023***. Without the capital support from Nassau, PHL Variable would have failed in 2019. I don’t think it’s a stretch to say that until 2021, Nassau did everything it could to maintain the health of PHL Variable. But they presumably knew by 2018 that there was a chance the company wouldn’t make it. Hence, the decision at the end of that year to switch new business from PHL Variable to the other Nassau-branded life insurers.
It’s not hard to see why. The net effect of the mounting losses on PHL Variable is a nearly continuous deterioration of its surplus. Below is a table showing the development of PHL Variable’s surplus since 2009. Paid-in surplus is capital contributed by investors. Earned surplus is retained earnings (or losses). Surplus notes are quasi-debt that count as surplus. Total surplus is the sum of the three components. You’ll also note that when Nassau purchased Phoenix, it did a quasi-reorganization and basically reset the deck on the enormous losses that had been incurred by PHL Variable up to that point. Most of those losses were probably related to rapidly growing the business and writing new policies.
Separating PHL Variable From Nassau
In 2021, Nassau managed to extricate itself from PHL Variable by essentially doing a deal with the Connecticut Insurance Department. Nassau agreed to put an additional $30 million into PHL Variable in exchange for removing the company from its balance sheet and placing it under direct control of Golden Gate. To some degree, it’s a distinction without a difference. Golden Gate owns both insurers anyway and it’s not hard to understand why CID might agree to the transaction as long as PHL Variable is adequately capitalized.
But strategically, there is a huge difference. Separating PHL Variable from Nassau theoretically protects the new business franchise at Nassau that has been picking up steam over the past few years. But practically, PHL Variable still poses a reputational threat. Distributors selling Nassau products probably don’t know that virtually every non-NY/ME/PR policy sold by Nassau from the time of the acquisition until 2019 tallying up to around $1.5 billion in premium was written on PHL Variable paper. When their clients and agents start getting letters, they’re going to point the finger at Nassau – even though PHL Variable isn’t technically part of Nassau anymore.
It’s reasonable to assume that, as a part of the 2021 transaction, Golden Gate informed CID that it was done putting capital into PHL Variable. Whether that’s what they told CID or not, it’s certainly what they did. And the fact that they left PHL Variable to stand or fall on its own raises an interesting question – does the buyer of a life insurer have the obligation to keep it afloat? The simple answer is no. There is no obligation for GG Holdings to sink the $1 billion or more into PHL Variable to keep it going. The current regulatory regime for risky purchases such as PHL Variable is heads I win, tails you lose. The fact that Golden Gate stuck with it and sunk $210 million into PHL Variable before they cut bait is a credit to them. Or, perhaps, it was the cost of the time it took to get the FIA suite off PHL Variable paper and on to the other Nassau-branded insurers.
But the same would have been true had Nassau never purchased Phoenix. It’s hard to imagine that Phoenix wouldn’t have figured out how to cut a similar deal with CID in order to protect the franchise. Otherwise, it’s possible that PHL Variable could have taken down Phoenix just like it could have taken down all of Nassau. Consider the fact that Nassau has, in aggregate, around $500 million in surplus. If the loss of $900 million at CID is correct, then PHL Variable posed a fatal threat to the policyholders of Nassau Life Insurance Company and Nassau Life and Annuity. You can see the logic of sticking the loss to the people who created it, the STOLI investors. Yes, there’s collateral damage to other policyholders, but nowhere near what the damage would have been if PHL Variable was still a part of Nassau.
Lots of companies took a lot of STOLI business. Why aren’t they failing as well? They contracted the same disease but it wasn’t terminal because they have healthy immune systems courtesy of other, hopefully profitable business lines that are much larger than their STOLI exposure. But make no mistake about it, other companies have the same issue buried in their books. It’s just a lot harder to see.
Who Killed PHL Variable
So let’s get back to the central question – who killed PHL Variable? It wasn’t Nassau. If anything, Nassau kept PHL Variable alive longer than it should have been. It wasn’t the Connecticut Department of Insurance, either, although it does seem as though CID was either unaware of the problem or ignoring it for far too long. It also seems as though CID wasn’t willing to look at alternative solutions once the problem had come to a head. In the PHL Variable Board resolution allowing the rehabilitation efforts, the Board noted that CID didn’t allow PHL Variable to consider raising COI charges again or entering into a transaction with Wilton Re that would have further split and segmented the company****.
Both of those decisions are curious. If policies owned by investors are the problem, then why not basically force the investors to eat their own cooking? Why not allow PHL Variable to raise COI charges? Why not allow Wilton Re to potentially acquire the healthy blocks and leave the Universal Life block, which is almost entirely STOLI, to die on its own? If the CID was willing in 2021 to wall PHL Variable off to avoid contagion to the rest of Nassau’s policyholders, why doesn’t that logic apply within PHL Variable? We can’t know for sure, but there is a statute in Connecticut that prevents companies from splitting while under stress. It was designed to prevent moral hazard for writing risky business. But the collateral damage in this case is that it prevented PHL Variable from forcing the STOLI investors to eat their own cooking.
The reality is that Phoenix killed PHL Variable by allowing it to contract a terminal disease. Phoenix demutualized and, like many other insurers, chased growth without realizing what it would ultimately cost them. PHL Variable is more of a cautionary tale of demutualization, reckless growth and potentially even regulatory missteps than it is a cautionary tale of private equity firms buying life insurers. The fact that PHL Variable died on Nassau’s watch is almost irrelevant.
But where did the terminal disease come from? It came from the producers, distributors, financiers and investors who created and profited from the massive STOLI industrial complex of the mid-2000s. I know some of these people by name. I’ve met them. I’ve heard their presentations. I’ve sat at dinner next to them. They don’t have horns on their heads. They were just making a sale that the carrier was telling them, however quietly, that they were willing to take despite the fact that it was shady, unethical and borderline legal. And that carrier was often Phoenix.
The Fallout
One terrifying part of the PHL Variable story is that the people who killed this company are still out there selling life insurance. They’ve transitioned to selling other things. In my experience, these sorts of people are always looking for an angle, a way to sell life insurance that’s “easy.” The beauty of STOLI is that the pitch to clients appealed to their sense of greed. The same applied to premium financed IUL, which purports to offer some variant of “free” or reduced-cost life insurance or illustrated income for life. It’s a greed sale rather than a need sale. Could it come back to bite insurers? Not in the same way as STOLI, but it still could. I am getting 1-2 calls a week on failed premium financing cases where policyholders are exploring litigation. I don’t work on those cases, but I still get the calls. And I’m getting a lot more than I used to.
Another terrifying part is the fact that the vast majority of clients probably had no idea they were buying a policy on PHL Variable paper. All of the marketing material just said Phoenix. This happens all the time. Symetra issues policies out of Symetra Life and Symetra National Life. Principal, Prudential and MassMutual have sub-writing entities that they regularly use for certain business lines. Global Atlantic was writing life insurance out of Accordia rather than its flagship Forethought entity. Mutual of Omaha uses United of Omaha. Nationwide, PacLife, New York Life and Penn Mutual all have secondary entities with “& Annuity” in the name to differentiate from the main writing entity. These sorts of secondary entities are incredibly common. The standard line from any company using secondary entities is that the support of the parent is the same across all entities. I’m sure that’s true. I’m also sure that’s what Phoenix said about PHL Variable, too.
The dust is yet to settle on this transaction. Policyholders have only recently been notified. That case I hypothesized earlier in the article with a $12 million death benefit is a real case that I saw last week. Real people are about to be materially affected by the rehabilitation of PHL Variable. It is possible that the rehabilitation manages to make them whole by walling off the STOLI block through some sort of legislative or regulatory process. But it’s going to take years for all of that to come to fruition. In the meantime, there will be hell to pay. Annuitants will stop getting income. People who were relying on Phoenix life insurance policies for their estate plans will get hardly enough for their heirs to pay the lawyers. No one except the folks with unitized and insulated separate accounts in variable products will be able to access their cash. It’s going to be an absolute mess.
Someone asked me today if I thought that the rehabilitation of PHL Variable and the potential issues at A Cap and SILAC would cause folks to stop to consider where they place life insurance and annuity business. The short answer is yes, I think it will. Producers have long said that every death claim gets paid and we might see the first situation where that legitimately doesn’t happen in PHL Variable – and from a company that was rated A by AM Best, A3 by Moody’s, A- by S&P and A+ by Fitch as recently as 2008. If you were relying just on ratings, then it would seem impossible to have known what would happen to PHL Variable.
But if you were active in the market and had a pulse on what was being sold, you knew something was up at Phoenix. Your gut was telling you that not all was well. And in cases like these, it’s not a bad idea to trust your gut. If a carrier is doing things in life insurance or annuities that seem to defy gravity, then you should assume that it’s only a matter of time before the ball drops – even if it takes 20 years to hit the ground.
Rehabilitation is only the first step towards the final resolution of PHL Variable. The worst case scenario is that annuitants and life insurance policyholders only get the minimum guaranteed amounts. I think that’s a distinct possibility given the inadequacy of the assets at PHL Variable. However, I think there’s an outside shot of a better outcome for real, non-STOLI policyholders. STOLI investors are going to be in a bind because of the rehabilitation. They have to continue to pay premiums in order to keep the policies in-force because these contracts (generally) have no cash value but their death benefits are capped at $300k. Will they keep funding the policies, cut their losses or start suing? If they cut their losses and drop the policies, would PHL Variable survive? If they start suing, does that give CID grounds to treat them differently from other policyholders? Might it be possible to actually wall off the investor-owned policies?
I don’t know, but after spending a lot of time looking at PHL Variable, I am confident that if the STOLI policies are lapsed, walled off or experience COI increases then PHL Variable could be saved. It’s possible that CID didn’t allow the Board of PHL Variable to do a transaction with Wilton Re or to raise COI charges because it knew that PHL Variable couldn’t pull either of those off as an independently operating company. But by making PHL Variable a ward of the state, CID may open up more options for resolution that are favorable for the real policyholders of PHL Variable. It’s like the scene you’ve seen in countless action movies. STOLI investors pulled the pin and chucked the grenade. Even though it looks like everyone is scrambling for cover and waiting for the explosion, maybe – just maybe – CID is about to pick up the grenade and throw it right back.
*I’m not sure why Maine never approved PHL Variable, but policyholders in Maine can count themselves lucky because their policies remain unincumbered at Nassau Life Insurance Company.
**This is actually an interesting little sidebar. As mentioned previously, PHL Variable sold a lot of FIA with rich income benefits. Turns out, those aren’t particularly profitable either. PHL Variable started reporting line-by-line profitability in 2023 in its 5 Year History and we can see that FIAs lost $160 million, which was probably due in large part to problems at Concord Re, but were offset by a $153 million gain in VA. The year before, FIAs lost $5 million and VAs posted a $15 million gain.
***$33 million in 2015, $50.5 million in 2016, $16 million in 2017 plus $25 million in surplus notes owned by the parent, a net contribution of $54.75 million in 2019 and, finally, $30.25 million in 2021.
****This is an inference. The Board referenced the Connecticut statute on insurer splits as the reason why the Wilton Re transaction was declined, but didn’t provide any detail on what the transaction might have been.
