Exhibits - Bates 22-201 PDF

Investigation Section Referral Form
Date of Referral: 04/09/2018
Referring Division: Company Supervision - Market Conduct Oversight, Market Analysis
OIC SIMBA #: N/A
Name of referring staff member: Ned Gaines
Name of staff member who handled matter: Ned Gaines
____________________________________________________________________________
Name and Address of Person/Entity to be Investigated: American Pet Insurance

Company/Trupanion Managers USA, Inc. 6100 4th Ave S, Seattle, WA 98108
OIC License #: Trupanion Managers - 718030, American Pet Insurance Company - 187058
License Expiration Date: Trupanion Managers - 01/15/2020
Date incident occurred: Sales over the past 2 years
Synopsis of matter to be investigated: Concerns that the Company is continuing activities that
were found to be violations during the 2015 Market Conduct Examination. Specifically the
Company is continuing to pay commission to the Seattle Humane Society based on the
activation of a promotional policy certificate presented to the consumer by the Humane
Society. There are concerns that the Company is providing trips to veterinarians based on how
many policy certificate activations are presented by the vets. The Company's use of qualified
leads appear to be based on whether or not a consumer purchases a policy rather than just the
referral on its own.
Cite the RCW or WAC possibly violated: RCW 48.30.133, WAC 284-17-825, RCW 48.17.490
WA State OIC 22
File #1569460 Exhibit #1A Page 1 of 19

Other relevant information: Company is currently on a compliance plan. Order numbers 16-
0127 and 13-0204.
Documents attached? Yes
WA State OIC 23

Vol.
Vol.5 5No.
Vol.
Vol. 5No.329
6No.
Vol.No. 1234 October
5354
No.
159 April 3,1,
January
October
May 15, 23,2017
2018
4,
2017 2017
2017
Trupanion: VCA Animal Hospital Practice of Recommending Trupanion Pet

Insurance Could Run Afoul of State Insurance Laws
Company Update
VCA—the operator of over 800 animal hospitals in the U.S. and Canada—encourages its hospital staff to
recommend Trupanion pet insurance policies, a practice that may run afoul of state insurance licensing laws,
according to a state insurance regulator and an industry expert interviewed for this article.
VCA named Trupanion its preferred vendor for pet insurance for cats and dogs in the U.S. as part of a partnership
entered into with Trupanion in 2014. VCA encourages its hospitals to recommend Trupanion, according to Aaron
Frazier, Vice President of Client Experience, Wellness Plans, Knowledge and Learning at VCA.
Recommending a particular type of pet insurance likely constitutes the solicitation of insurance—a licensable
activity that requires a property and casualty insurance license in most states. As we previously highlighted,
veterinary hospital staff are unlikely to carry property and casualty insurance licenses given the continuing
education and examination requirements, according to industry experts.
VCA has also previously created contests and offered financial incentives to its hospitals that are tied to hitting
Trupanion certificate activation targets, according to a VCA Interoffice Memorandum. Certificates give pet owners
a 30-day Trupanion trial.
In May of 2017, VCA offered hospitals that hit a 25 Trupanion certificate activation goal in June $200 in the
hospitals team special event account in July. Trupanion denied any involvement in the promotion and VCA
confirmed that the $200 was paid by VCA and not Trupanion.
In a previous Market Conduct Examination of American Pet Insurance Company (APIC), Trupanion’s wholly
owned insurance entity, the examiners found that a similar arrangement with animal shelters ran afoul of
Washington insurance law.
Specifically, the report states, “By providing the Company’s trial certificates to consumers and encouraging
activation the shelters are engaging in the solicitation of insurance…” and were therefore required to be licensed as
insurance producers. VCA operates a number of hospitals in the state of Washington.
If a regulator were to investigate VCA’s practices, and VCA hospitals were required to stop recommending
Trupanion over other pet insurance health policies, Trupanion could lose an important source of referrals and future
clients. A company presentation in February shows that 49 percent of Trupanion’s new customers came from
veterinary leads as of December 31. VCA operates a significant number of veterinary hospitals.
Any modification to Trupanion’s business model as a result of a regulatory inquiry into whether its referral sources
have the necessary licenses could harm Trupanion’s business. In its most recent annual filing, Trupanion states:
“Regulators have in the past and/or may in the future determine that certain of our ... referral sources were
performing licensable activities without the required license... Any modification of our business or marketing
practices in response to regulatory licensing requirements could harm our business, operating results or financial
WA State OIC 24
condition.”
1
© 2018 The Capitol Forum. Direct or indirect reproduction or distribution of this article without prior written permission from The Capitol Forum is a violation of Federal Copyright Law.

In-Depth: Trupanion Certificate Program and Licensing Requirements
Trupanion’s certificate program is designed to give pet owners the ability to experience Trupanion for 30 days.
Participating veterinary clinics can offer certificates after a veterinary exam. The certificates must be activated
within 24 hours of the veterinary exam and pet owners who do not activate their certificates within the required
time period are not eligible to participate in the certificate program, according to Trupanion’s website.
VCA offers incentives for Trupanion certificate activations. We recently were provided with a VCA Interoffice
Memorandum sent by Michael Gault, senior consultant at VCA, to All VCA Hospital Practice Managers. The
memo is dated May 26, 2017 and the subject is “Trupanion Pet Insurance June Promotion.”
The June 2017 incentive, as described in the memo, states, “all hospitals will be given a certificate activation goal
of 25 activations. If your hospital meets the certificate activation goal, your hospital will receive a $200 Deposit
into your hospitals team special event account in July.”
The memo also contains information about “Painting the Trupanion Certificate Patient Picture” by focusing on
animals who are coming in for their wellness exam. A great example, according to the memo, would be an animal
owner who decided to run early detection blood work on their pet.
If that owner activated the certificate prior to the blood work results coming back and the animal was found to have
some sort of liver disease, any additional testing, medications, and hospitalizations could be eligible for coverage
under the certificate program, assuming the pet was not showing any clinical signs or symptoms prior to the
certificate activation.
Recommending Trupanion likely constitutes the solicitation of insurance. The Producer Licensing Model Act
(PLMA), which serves as a model for individual state insurance laws, defines “solicit” as “attempting to sell
insurance or asking or urging a person to apply for a particular kind of insurance from a particular company.”
We presented the facts surrounding the VCA June incentive to a current state insurance regulator and asked whether
VCA staff would need to be licensed for recommending Trupanion. In response to our question, the state regulator
said in an email, “yes, the fact that the recommendation is for a specific insurer for a specific type of insurance is
the definition of solicitation and would require a person to be licensed.”
In addition, the examiners in the APIC market conduct examination already found this practice to run afoul of
Washington state insurance law. There, the examiners found that the shelters that were providing Trupanion’s trial
certificates to consumers and encouraging activation were engaging in the solicitation of insurance. The examiners
cited RCW 48.17.010 (14), which is the definition of solicitation and mirrors the definition of solicitation in the
PLMA. The relevant excerpt from the APIC Market Conduct Examination reads:
“14) “Solicit" means attempting to sell insurance or asking or urging a person to apply for a particular kind of
insurance from a particular insurer…The Company entered into agreements with nine (9) animal shelters in
Washington for the shelters to offer the Company's 30 day trial certificates to consumers who adopt a pet from their
facility. For every trial certificate that is activated the Company pays a commission to the shelter. If the trial
certificate then converts to a paid policy the Company issues an additional payment. The Company calls the
payment to the shelter a "Donation" implying it is charitable in nature. As no payment is issued to a shelter unless
WA State OIC 25
2

that shelter first provides a trial certificate to the consumer and encourages them to activate it, the Examiners
consider the payment to be a commission. By providing the Company's trial certificates to consumers and
encouraging activation the shelters are engaging in the solicitation of insurance per the definition of RCW
48.17.010(14) and therefore are required to be licensed as insurance producers” [emphasis ours].
In response to our request for comment, Michael Nank, Strategic Communications and PR at Trupanion, wrote in
an email, “Trupanion was not involved in the promotion described in the memorandum you forwarded. The details
of any such promotion would have been determined exclusively by VCA.”
We asked Nank whether Trupanion paid VCA any money to be the preferred partner. Nank responded, “Trupanion
is VCA’s preferred provider of medical insurance for cats and dogs in the United States. The specific terms of this
partnership are confidential.”
Aaron Frazier—who is cc:d on the memo—confirmed its authenticity. The $200 payment, according to Frazier,
came from VCA and not Trupanion. When clients have pet insurance it is typically a good thing, Frazier said.
Veterinary practices benefit if their customers have pet insurance, as every industry expert we have spoken with
has said that customers with pet insurance are more likely to visit the vet.
However, recommending one type of insurance over others likely violates state insurance licensing laws, and, as
discussed above, encouraging certificate activation likely constitutes the solicitation of insurance.
Lack of payment likely has no bearing on licensing question. There is no requirement in the PLMA that money
exchange hands or that the person selling insurance without a license receive compensation for doing so. Rather,
the PLMA simply reads, “A person shall not sell, solicit or negotiate insurance in this state for any class or classes
of insurance unless the person is licensed for that line of authority in accordance with this Act.”
We spoke with a pet insurance industry expert with a background in property and casualty insurance. If you are
recommending a single insurance policy, that is a licensable activity and you cannot do that, the expert said. It
doesn’t matter if money is changing hands, the expert continued. If you are recommending a particular policy
without a property and casualty license, the expert said, that is “game, set, match” from a regulator’s perspective.
WA State OIC 26
3

Vol.
Vol.5 5No.
Vol.
Vol. 5No.329
6No.
5354
No.
159 April
January
October
May 15,1,
20,
23,2017
2018
4,
2017 2017
2017
Trupanion: Recent Disclosures About Sharing Cost Savings With Veterinary

Hospitals Reveal Practices That Could Violate Multiple State Laws, According to
Insurance Experts and Regulators
Company Update
Trupanion (TRUP) recently updated its website to provide information about “Insurance Sounding Stuff” and
provide answers to some of the issues we have raised in our previous articles. In providing the answers to our
articles, Trupanion potentially acknowledged that it is engaged in practices that violate multiple state insurance
laws, according to insurance experts and regulators we interviewed. And veterinary hospital staff who accept
payment from Trupanion could unknowingly be at risk of violating state insurance laws.
Trupanion frames its answers to some of the issues we have raised as offering veterinary hospitals the opportunity
to share in the cost savings that Trupanion receives when Trupanion Express is used. The company admits that it
has “offered hospitals two programs to encourage the installation and use Trupanion Express™.” It specifically
admits that the points and rewards system, which provide—among other things—trips to Hawaii, Seattle, and Las
Vegas, is based on “enhanced” Trupanion Express usage.
In addition, Trupanion’s disclosure that it is paying “reasonable compensation” to Group Purchasing Organizations
(GPO) for submitting invoices using Trupanion Express, could constitute an unlawful rebate in violation of state
anti-rebate and kicback laws, according to insurance experts and regulators we interviewed.
When we asked the Colorado Division of Insurance about these practices, a spokesperson responded “these
practices could be problematic, both in terms of using and compensating people who are unlicensed, as well as the
compensation itself possibly running against anti-rebate laws.”
Trupanion provided the following emailed statement: “The Company rigorously tries to ensure all parts of its
business are fully compliant. With respect to your questions about passing on cost savings, we have provided
reasonable compensation to certain hospitals who invest time and effort to help provide pet owners with the best
overall veterinary experience, including reimbursing hospitals directly at the time of check-out. We do not
incentivize insurance enrollments.”
In-Depth: Trupanion Sharing Cost Savings
The payment of money or sharing of cost savings is not per se illegal. However, the Producer Licensing Model Act
(PLMA) and the laws in states that have adopted the tenants of the PLMA is clear: “An insurance company or
insurance producer shall not pay a commission, service fee, brokerage or other valuable consideration to a person
for selling, soliciting or negotiating insurance in this state if that person is required to be licensed under this Act
and is not so licensed.”
A spokesperson for the Iowa Insurance Division said, “An insurer could pay or pass along costs savings to an
unlicensed individual as long was [sic] they are not being compensated for selling, soliciting or negotiating
insurance.” A spokesperson for the Illinois Department of Insurance agreed that the payments are not necessarily
prohibited, but noted that “there are prohibitions against steering customers to a particular insurance agency or
product.”
WA State OIC 27
1

Cost savings indirectly incentivizes veterinary hospitals to recommend Trupanion. In a somewhat circular
way, Trupanion contends that increased use of Trupanion Express reduces Trupanion’s expenses. As a result,
Trupanion has created two incentives that are designed to encourage the installation and use of Trupanion Express.
Veterinary hospitals with enhanced Trupanion Express usage can earn rewards, including the trips about which we
have previously written. And hospitals who use Trupanion Express, and allow Trupanion to reduce its claims
processing expenses, can share in some of those savings.
So, in short, Trupanion is incentivizing vets to use Trupanion Express to participate in cost savings. Importantly,
Trupanion Express can only be used to process claims for pets who are covered by Trupanion. This is an indirect
system designed to create an incentive for veterinary hospital staff to recommend Trupanion to his or her pet owner
clients, according to Robert H. Jerry, the Isidor Loeb Professor of Law at the University of Missouri School of Law.
As we have previously written, if veterinary hospital staff are recommending Trupanion over other types of pet
insurance, that practice likely constitutes the solicitation or negotiation of insurance, which requires a property and
casualty license in almost every state.
Payment to unlicensed individuals who are soliciting and negotiating insurance runs afoul of state insurance
laws. The PLMA prohibits an insurance company from paying “valuable consideration” or “a commission” to a
person for selling, soliciting, or negotiating insurance if that person is not licensed.
The trip to Hawaii veterinary hospital staff earned for enhanced Trupanion Express usage would likely constitute
valuable consideration, according to Peter Kochenburger, a professor at the University of Connecticut Law School
and former attorney in the Iowa Department of Justice’s consumer protection division.
Trupanion states that it has offered GPOs the opportunity to receive “reasonable compensation to facilitate the
prompt payment of eligible veterinary invoices.” Regulators and investigators could, depending on the nature of
the compensation, determine that it is valuable consideration, and, as a result, Trupanion’s payment could be found
to run afoul of state insurance laws, according to Kochenburger.
Accepting valuable consideration or commissions puts veterinary hospital staff at risk of violating state laws.
In addition to making payments, the PLMA also provides that unlicensed individuals who are soliciting, negotiating,
or selling insurance shall not accept a commission or valuable consideration. Accordingly, the people who
participated in the Hawaii, Seattle, or Alaska trip could also be in violation of state insurance laws, Kochenburger
said.
State anti-rebate laws. In addition to potentially violating state insurance laws, Jerry said that payments from
Trupanion to vets could run afoul of state anti-rebate statute.
The model act for anti-rebate laws is the Unfair Trade Practices Act (UFTA), which prohibits, in pertinent part,
giving “directly or indirectly, as inducement to such policy. . . any valuable consideration or inducement whatever
not specified in the policy . . .” In addition, the UFTA prohibits “giving . . . or offering to give . . . anything of
value whatsoever not specified in the policy.” Some states have adopted laws that mirror or contain important
provisions from the UFTA.
WA State OIC 28
2

It is not clear whether Trupanion is making the payment directly to the GPO or to the members of the GPO. Jerry
was unaware of any exemption to the anti-rebate law for GPOs. And, importantly, the UFTA prohibits the indirect
payment, so to the extent the payment was made to the GPO as a whole and indirectly benefited the GPO’s members,
it could constitute an indirect payment.
Kickbacks or rebates could spur regulator interest. “If Trupanion is giving someone a payment to encourage
them to have their customers buy Trupanion insurance policies, a regulator is going to be interested in this, given
how broad the language is in the UFTA,” Professor Jerry said.
He continued, “If Trupanion is kicking back benefits from claims processing to a vet, if I were a regulator, I would
be very worried, as such a practice would clearly implicate the anti-rebate law.” There is “no question about this,”
Jerry said, because “the law prohibits the payment of ‘anything of value.’”
We presented the factual scenario to the Virginia Insurance Commissioner’s office. In response, a spokesperson
directed us to the Virginia statute on rebates, which mirrors the UFTA: “Except as otherwise expressly provided by
law, no person shall: Pay, allow or give, or offer to pay, allow or give, directly or indirectly, as inducement to any
insurance or annuity contract, any rebate of premium payable on the contract, any special favor or advantage in the
dividends or other benefits on the contract, any valuable consideration or inducement not specified in the contract,
except in accordance with an applicable rating plan authorized for use in this Commonwealth.”
The spokesperson said that under Virginia insurance law, it does not matter if the commission or rebate is being
shared with an unlicensed as opposed to a licensed producer.
Both Iowa and Illinois have similar anti-rebate laws.
WA State OIC 29
3

Trupanion News: Veterinarians: Earn a Trip to Hawaii, Las Vegas, or Seattle! Page 1 of 4
The Full Event
Veterinarians: Earn a Trip

to Hawaii, Las Vegas, or
Seattle!
We are excited to announce a new addition to the
Trupanion Rewards Program. When you join our
Partners Program, your hospital team can now
qualify for a trip for 2 to one of three exciting
destinations. This 4-night, 5-day trip for one staff
member and their guest is a wonderful opportunity
to reward someone for [...]The post Veterinarians:
Earn a Trip to Hawaii, Las Vegas, or Seattle!
appeared first on The Trupanion Blog.
Source: Trupanion Blog
Read full article >
Latest Events about Trupanion
Sep 30, 2017
Veterinarians: Earn a Trip to Hawaii, Las Vegas, or

Seattle!
WA State OIC 30
Sep 30, 2017
https://www.owler.com/reports/trupanion/veterinarians--earn-a-trip-to-hawaii--las-vegas--... 12/4/2017
Rehoming your pet in the face of a disaster

Sep 28, 2017
How to foster a dog or cat

Sep 24, 2017
5 ways to pamper your pup

Sep 23, 2017
Trupanion Inc (TRUP) Raised to Hold at BidaskClub

Sep 22, 2017
Cómo evacuar con su mascota de manera segura

Sep 19, 2017
Trupanion Inc (TRUP) Expected to Announce

Quarterly Sales of $61.50 Million
Sep 17, 2017
Unique Cat Furniture for the Stylish Cat Owner

Sep 15, 2017
Massachusetts pet names are inspired by Ireland,

coffee, and sports
Sep 13, 2017
How you can help pets after a natural disaster

Sep 12, 2017
Sep 12, 2017

WA State OIC 31
About Trupanion View Full Trupanion Profile >
Trupanion At-a-Glance Key Stats Headquarters
Revenue
$227.5M
Trailing Twelve Months
Founder & CEO

Employees
Darryl Rawlings
Approval Rating: 72% 450
14 Votes
Founded: 2000
6100
Headquarters: 4th Ave South,
Seattle,
Washington, USA
Status: Public, NYSE, TRUP
Industry Health Care
Sector: Services (6297)
Trupanion pet insurance offers dog and cat insurance in the United States and Canada. Trupanion was founded in 2000.
Trupanion's Headquarters are located at 6100 4th Ave South, Seattle, Washington, USA 98108. It has raised $109.3M in 3
rounds. The latest round was in 2014. Some of Trupanion's investors include Telegraph Hill Partners, Perot Investments,
Inc. and Maveron, LLC.
WHAT WE DO SUCCESS COMPANY RESOURCES ENTERPRISE
© 2017 Owler, Inc.

WA State OIC 32
WA State OIC 33
Trupanion Affiliate Partnership Program | Trupanion Page 1 of 3
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MENU

TRUPANION AFFILIATE PARTNERSHIP PROGRAM
Join Trupanion's Affiliate Partnership Program and share with your readers how medical pet insurance
for cats and dogs can help pet owners cover unexpected illnesses and injuries and how a Trupanion
policy can help.
Trupanion is medical insurance for cats and dogs and offers one simple plan, 90% coverage of all eligible
illness and injuries, no payout limits, and the option to pay your vet directly.
Terms and conditions apply. See the full policy for details
Benefits to being a Trupanion Affiliate

Partner
WA State OIC 34
https://trupanion.com/affiliates 4/3/2018
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MENU

Monthly reporting on traffic data and monthly compensation for Qualified Leads generated.
Access to personalized marketing tools to promote Trupanion.
Ongoing support from Trupanion’s Affiliate Marketing team.
Ready to join? Click below to fill out our quick form.
Apply now >
Frequently Asked Questions

Why Trupanion?
We believe that insuring your pet should be easy. We offer one simple plan for all pets to ensure that
they receive the best coverage. Our plan covers 90% of actual veterinary costs for eligible claims once
your deductible for that condition is met. We offer unlimited lifetime coverage with no payout limits or
caps. Lastly, we can pay vets directly. You pay your portion and we take care of the rest.
WA State OIC 35
How do I promote Trupanion?
promote Trupanion on your site.
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MENU
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What is a Qualified Lead?
A Qualified Lead is a lead that has completed an application and provided valid payment information for
purchasing a Trupanion Policy. They do not need to purchase the policy to be considered a Qualified
Lead.
How do you track and pay for Qualified Leads?
Unlike most affiliate programs that pay quarterly, we pay for Qualified leads monthly by using your unique
tracking link to measure how many applications were referred from your site.
How will the Affiliate Partnership Program benefit me?
It’s simple, you earn money every time a Qualified Lead that you send over to Trupanion’s site submits
an application for a Trupanion policy.
Apply now >
© 2018 Trupanion. All Rights Reserved.
USA – English  
Privacy Policy | Site Map | Terms of Use and Regulatory Info WA State OIC 36
Other Events Benefiting Us | Seattle Humane Page 1 of 4
Search Go
Adoption Volunteer Events Services & Resources
Education About Us Donate
Events
Pet Insurance Benefit for Seattle Humane

Upcoming
Events
Alleviate the financial stress associated with your
pet's medical expenses and generate funds for Seattle Humane at
Santa Paws:
Pet photos with the same time! Sign up for the Trupanion program using this link
Santa! and a $5 donation will be made to Seattle Humane.
Dec 2 , 1 pm
Shelter Grand Shop AmazonSmile!

Opening!
Dec 9 , 10 am You shop - Amazon gives! Sign up for AmazonSmile and they'll
donate 0.5% of your purchases to Seattle Humane when you
See the Calenda
select us to be your preferred charity. Learn more
at: bit.ly/AmazonSmile-SHS
Give Our Pets a Future While Building

Your Own
If you, a family member, friend or
neighbor is looking to buy or sell a
home consider working
with Brokers Supporting Pet Rescue
(BSPR), a network of animal-loving
Washington State
Windermere Brokers working together to help rescue animals.
BSPR will donate 10% of net commissions with every home sale or
purchase.
WA State OIC 37
http://www.seattlehumane.org/events/other-events-benefiting-us 12/1/2017
Visit their website to learn more and find a BSPR Broker in your
area.

Your Own
You shop - Amazon gives! Sign up for AmazonSmile and they'll
Find a Sitter, Save a Life!

Seattle Humane has partnered with Rover.com, the country’s
largest dog boarding marketplace, to help dog owners connect with
local dog-friendly homes and dog sitters. When you book a dog
sitter through our SH Rover landing page and use the promo code
SH10, Rover.com will donate $10 to Seattle Humane. Sign up
today!
Shop Fred Meyer

Sign up for Fred Meyer's Community Rewards program and every
time you use your Rewards Card a donation will be made to
Seattle Humane! You'll still earn your rewards points, fuel points,
and rebates, just as you normally do. Visit
fredmeyer.com/communityrewards and link your card to "Seattle
Humane.
Seattle Humane is a SMCU Checking

Partner in 2017
Thanks to you, Seattle Humane was
selected as a SMCU Checking Partner for
2015! That means that for each new Feel
Good Checking account opened in 2015
we get $20 if selected among the 2015
highlighted charities. You also get 6.14%
APY on the first $500 in your account, free checks, Bill Pay, and
Online/Mobile Banking. Click here for more info!
WA State OIC 38
Book a Stay at the Paramount Today!

The gorgeous and glamorous
Paramount Hotel in the heart of
Downtown Seattle, which boasts a 4.5
star Trip Advisor rating and one of the
best Pan Asian restaurants in the city, is partnering with Seattle
Humane to raise funds for homeless pets! Anyone who uses this
site to book their stay will gift an automatic matched donation from
Paramount to Seattle Humane:
http://www.paramounthotelseattle.com/promotions/support-seattle-
humane-society.htm Booking a relaxing stay in style never felt so
good!
BarkHappy App hits Seattle

Is your dog BarkHappy? If you haven't
already, download the free BarkHappy
app at BarkHappy.com! It's really more
than an app. It's a community for the dog-
obsessed who enjoy taking their fluffy
friend with them everywhere. You can find
restaurants and venues that are dog-
friendly, and even search by ones that allow dogs indoors or have
covered patios. Plus they have events each week to mix, mingle,
and play! We're honored that BarkHappy has chosen Seattle
Humane as a charitable partner.
WA State OIC 39
Well Hello There!

We adopted
brother and sister
cats who love to
play, explore, and Join our
be loved. They're newsletter!
also great with our
grandchildren and
have brought a lot
of fun to our
household.
Proud Parents to Sunny &
Pansy
WA 98005
WA State OIC 40
Vol.
Vol.5 5No.
Vol.
Vol. 5No.329
6No.
5354
No.
159 April 3,1,
January
October
May 15, 23,2017
2018
4,
2017 2017
2017
Trupanion: VCA Animal Hospital Practice of Recommending Trupanion Pet

Insurance Could Run Afoul of State Insurance Laws
Company Update
VCA—the operator of over 800 animal hospitals in the U.S. and Canada—encourages its hospital staff to
recommend Trupanion pet insurance policies, a practice that may run afoul of state insurance licensing laws,
according to a state insurance regulator and an industry expert interviewed for this article.
VCA named Trupanion its preferred vendor for pet insurance for cats and dogs in the U.S. as part of a partnership
entered into with Trupanion in 2014. VCA encourages its hospitals to recommend Trupanion, according to Aaron
Frazier, Vice President of Client Experience, Wellness Plans, Knowledge and Learning at VCA.
Recommending a particular type of pet insurance likely constitutes the solicitation of insurance—a licensable
activity that requires a property and casualty insurance license in most states. As we previously highlighted,
veterinary hospital staff are unlikely to carry property and casualty insurance licenses given the continuing
education and examination requirements, according to industry experts.
VCA has also previously created contests and offered financial incentives to its hospitals that are tied to hitting
Trupanion certificate activation targets, according to a VCA Interoffice Memorandum. Certificates give pet owners
a 30-day Trupanion trial.
In May of 2017, VCA offered hospitals that hit a 25 Trupanion certificate activation goal in June $200 in the
hospitals team special event account in July. Trupanion denied any involvement in the promotion and VCA
confirmed that the $200 was paid by VCA and not Trupanion.
In a previous Market Conduct Examination of American Pet Insurance Company (APIC), Trupanion’s wholly
owned insurance entity, the examiners found that a similar arrangement with animal shelters ran afoul of
Washington insurance law.
Specifically, the report states, “By providing the Company’s trial certificates to consumers and encouraging
activation the shelters are engaging in the solicitation of insurance…” and were therefore required to be licensed as
insurance producers. VCA operates a number of hospitals in the state of Washington.
If a regulator were to investigate VCA’s practices, and VCA hospitals were required to stop recommending
Trupanion over other pet insurance health policies, Trupanion could lose an important source of referrals and future
clients. A company presentation in February shows that 49 percent of Trupanion’s new customers came from
veterinary leads as of December 31. VCA operates a significant number of veterinary hospitals.
Any modification to Trupanion’s business model as a result of a regulatory inquiry into whether its referral sources
have the necessary licenses could harm Trupanion’s business. In its most recent annual filing, Trupanion states:
“Regulators have in the past and/or may in the future determine that certain of our ... referral sources were
performing licensable activities without the required license... Any modification of our business or marketing
practices in response to regulatory licensing requirements could harm our business, operating results or financial
WA State OIC 41
condition.”
1
File #1569460 Exhibit #1B Page 1 of 6

In-Depth: Trupanion Certificate Program and Licensing Requirements
Trupanion’s certificate program is designed to give pet owners the ability to experience Trupanion for 30 days.
Participating veterinary clinics can offer certificates after a veterinary exam. The certificates must be activated
within 24 hours of the veterinary exam and pet owners who do not activate their certificates within the required
time period are not eligible to participate in the certificate program, according to Trupanion’s website.
VCA offers incentives for Trupanion certificate activations. We recently were provided with a VCA Interoffice
Memorandum sent by Michael Gault, senior consultant at VCA, to All VCA Hospital Practice Managers. The
memo is dated May 26, 2017 and the subject is “Trupanion Pet Insurance June Promotion.”
The June 2017 incentive, as described in the memo, states, “all hospitals will be given a certificate activation goal
of 25 activations. If your hospital meets the certificate activation goal, your hospital will receive a $200 Deposit
into your hospitals team special event account in July.”
The memo also contains information about “Painting the Trupanion Certificate Patient Picture” by focusing on
animals who are coming in for their wellness exam. A great example, according to the memo, would be an animal
owner who decided to run early detection blood work on their pet.
If that owner activated the certificate prior to the blood work results coming back and the animal was found to have
some sort of liver disease, any additional testing, medications, and hospitalizations could be eligible for coverage
under the certificate program, assuming the pet was not showing any clinical signs or symptoms prior to the
certificate activation.
Recommending Trupanion likely constitutes the solicitation of insurance. The Producer Licensing Model Act
(PLMA), which serves as a model for individual state insurance laws, defines “solicit” as “attempting to sell
insurance or asking or urging a person to apply for a particular kind of insurance from a particular company.”
We presented the facts surrounding the VCA June incentive to a current state insurance regulator and asked whether
VCA staff would need to be licensed for recommending Trupanion. In response to our question, the state regulator
said in an email, “yes, the fact that the recommendation is for a specific insurer for a specific type of insurance is
the definition of solicitation and would require a person to be licensed.”
In addition, the examiners in the APIC market conduct examination already found this practice to run afoul of
Washington state insurance law. There, the examiners found that the shelters that were providing Trupanion’s trial
certificates to consumers and encouraging activation were engaging in the solicitation of insurance. The examiners
cited RCW 48.17.010 (14), which is the definition of solicitation and mirrors the definition of solicitation in the
PLMA. The relevant excerpt from the APIC Market Conduct Examination reads:
“14) “Solicit" means attempting to sell insurance or asking or urging a person to apply for a particular kind of
insurance from a particular insurer…The Company entered into agreements with nine (9) animal shelters in
Washington for the shelters to offer the Company's 30 day trial certificates to consumers who adopt a pet from their
facility. For every trial certificate that is activated the Company pays a commission to the shelter. If the trial
certificate then converts to a paid policy the Company issues an additional payment. The Company calls the
payment to the shelter a "Donation" implying it is charitable in nature. As no payment is issued to a shelter unless
WA State OIC 42
2

that shelter first provides a trial certificate to the consumer and encourages them to activate it, the Examiners
consider the payment to be a commission. By providing the Company's trial certificates to consumers and
encouraging activation the shelters are engaging in the solicitation of insurance per the definition of RCW
48.17.010(14) and therefore are required to be licensed as insurance producers” [emphasis ours].
In response to our request for comment, Michael Nank, Strategic Communications and PR at Trupanion, wrote in
an email, “Trupanion was not involved in the promotion described in the memorandum you forwarded. The details
of any such promotion would have been determined exclusively by VCA.”
We asked Nank whether Trupanion paid VCA any money to be the preferred partner. Nank responded, “Trupanion
is VCA’s preferred provider of medical insurance for cats and dogs in the United States. The specific terms of this
partnership are confidential.”
Aaron Frazier—who is cc:d on the memo—confirmed its authenticity. The $200 payment, according to Frazier,
came from VCA and not Trupanion. When clients have pet insurance it is typically a good thing, Frazier said.
Veterinary practices benefit if their customers have pet insurance, as every industry expert we have spoken with
has said that customers with pet insurance are more likely to visit the vet.
However, recommending one type of insurance over others likely violates state insurance licensing laws, and, as
discussed above, encouraging certificate activation likely constitutes the solicitation of insurance.
Lack of payment likely has no bearing on licensing question. There is no requirement in the PLMA that money
exchange hands or that the person selling insurance without a license receive compensation for doing so. Rather,
the PLMA simply reads, “A person shall not sell, solicit or negotiate insurance in this state for any class or classes
of insurance unless the person is licensed for that line of authority in accordance with this Act.”
We spoke with a pet insurance industry expert with a background in property and casualty insurance. If you are
recommending a single insurance policy, that is a licensable activity and you cannot do that, the expert said. It
doesn’t matter if money is changing hands, the expert continued. If you are recommending a particular policy
without a property and casualty license, the expert said, that is “game, set, match” from a regulator’s perspective.
WA State OIC 43
3

Vol.
Vol.5 5No.
Vol.
Vol. 5No.329
6No.
5354
No.
159 April
January
October
May 15,1,
20,
23,2017
2018
4,
2017 2017
2017
Trupanion: Recent Disclosures About Sharing Cost Savings With Veterinary

Hospitals Reveal Practices That Could Violate Multiple State Laws, According to
Insurance Experts and Regulators
Company Update
Trupanion (TRUP) recently updated its website to provide information about “Insurance Sounding Stuff” and
provide answers to some of the issues we have raised in our previous articles. In providing the answers to our
articles, Trupanion potentially acknowledged that it is engaged in practices that violate multiple state insurance
laws, according to insurance experts and regulators we interviewed. And veterinary hospital staff who accept
payment from Trupanion could unknowingly be at risk of violating state insurance laws.
Trupanion frames its answers to some of the issues we have raised as offering veterinary hospitals the opportunity
to share in the cost savings that Trupanion receives when Trupanion Express is used. The company admits that it
has “offered hospitals two programs to encourage the installation and use Trupanion Express™.” It specifically
admits that the points and rewards system, which provide—among other things—trips to Hawaii, Seattle, and Las
Vegas, is based on “enhanced” Trupanion Express usage.
In addition, Trupanion’s disclosure that it is paying “reasonable compensation” to Group Purchasing Organizations
(GPO) for submitting invoices using Trupanion Express, could constitute an unlawful rebate in violation of state
anti-rebate and kicback laws, according to insurance experts and regulators we interviewed.
When we asked the Colorado Division of Insurance about these practices, a spokesperson responded “these
practices could be problematic, both in terms of using and compensating people who are unlicensed, as well as the
compensation itself possibly running against anti-rebate laws.”
Trupanion provided the following emailed statement: “The Company rigorously tries to ensure all parts of its
business are fully compliant. With respect to your questions about passing on cost savings, we have provided
reasonable compensation to certain hospitals who invest time and effort to help provide pet owners with the best
overall veterinary experience, including reimbursing hospitals directly at the time of check-out. We do not
incentivize insurance enrollments.”
In-Depth: Trupanion Sharing Cost Savings
The payment of money or sharing of cost savings is not per se illegal. However, the Producer Licensing Model Act
(PLMA) and the laws in states that have adopted the tenants of the PLMA is clear: “An insurance company or
insurance producer shall not pay a commission, service fee, brokerage or other valuable consideration to a person
for selling, soliciting or negotiating insurance in this state if that person is required to be licensed under this Act
and is not so licensed.”
A spokesperson for the Iowa Insurance Division said, “An insurer could pay or pass along costs savings to an
unlicensed individual as long was [sic] they are not being compensated for selling, soliciting or negotiating
insurance.” A spokesperson for the Illinois Department of Insurance agreed that the payments are not necessarily
prohibited, but noted that “there are prohibitions against steering customers to a particular insurance agency or
product.”
WA State OIC 44
1

Cost savings indirectly incentivizes veterinary hospitals to recommend Trupanion. In a somewhat circular
way, Trupanion contends that increased use of Trupanion Express reduces Trupanion’s expenses. As a result,
Trupanion has created two incentives that are designed to encourage the installation and use of Trupanion Express.
Veterinary hospitals with enhanced Trupanion Express usage can earn rewards, including the trips about which we
have previously written. And hospitals who use Trupanion Express, and allow Trupanion to reduce its claims
processing expenses, can share in some of those savings.
So, in short, Trupanion is incentivizing vets to use Trupanion Express to participate in cost savings. Importantly,
Trupanion Express can only be used to process claims for pets who are covered by Trupanion. This is an indirect
system designed to create an incentive for veterinary hospital staff to recommend Trupanion to his or her pet owner
clients, according to Robert H. Jerry, the Isidor Loeb Professor of Law at the University of Missouri School of Law.
As we have previously written, if veterinary hospital staff are recommending Trupanion over other types of pet
insurance, that practice likely constitutes the solicitation or negotiation of insurance, which requires a property and
casualty license in almost every state.
Payment to unlicensed individuals who are soliciting and negotiating insurance runs afoul of state insurance
laws. The PLMA prohibits an insurance company from paying “valuable consideration” or “a commission” to a
person for selling, soliciting, or negotiating insurance if that person is not licensed.
The trip to Hawaii veterinary hospital staff earned for enhanced Trupanion Express usage would likely constitute
valuable consideration, according to Peter Kochenburger, a professor at the University of Connecticut Law School
and former attorney in the Iowa Department of Justice’s consumer protection division.
Trupanion states that it has offered GPOs the opportunity to receive “reasonable compensation to facilitate the
prompt payment of eligible veterinary invoices.” Regulators and investigators could, depending on the nature of
the compensation, determine that it is valuable consideration, and, as a result, Trupanion’s payment could be found
to run afoul of state insurance laws, according to Kochenburger.
Accepting valuable consideration or commissions puts veterinary hospital staff at risk of violating state laws.
In addition to making payments, the PLMA also provides that unlicensed individuals who are soliciting, negotiating,
or selling insurance shall not accept a commission or valuable consideration. Accordingly, the people who
participated in the Hawaii, Seattle, or Alaska trip could also be in violation of state insurance laws, Kochenburger
said.
State anti-rebate laws. In addition to potentially violating state insurance laws, Jerry said that payments from
Trupanion to vets could run afoul of state anti-rebate statute.
The model act for anti-rebate laws is the Unfair Trade Practices Act (UFTA), which prohibits, in pertinent part,
giving “directly or indirectly, as inducement to such policy. . . any valuable consideration or inducement whatever
not specified in the policy . . .” In addition, the UFTA prohibits “giving . . . or offering to give . . . anything of
value whatsoever not specified in the policy.” Some states have adopted laws that mirror or contain important
provisions from the UFTA.
WA State OIC 45
2

It is not clear whether Trupanion is making the payment directly to the GPO or to the members of the GPO. Jerry
was unaware of any exemption to the anti-rebate law for GPOs. And, importantly, the UFTA prohibits the indirect
payment, so to the extent the payment was made to the GPO as a whole and indirectly benefited the GPO’s members,
it could constitute an indirect payment.
Kickbacks or rebates could spur regulator interest. “If Trupanion is giving someone a payment to encourage
them to have their customers buy Trupanion insurance policies, a regulator is going to be interested in this, given
how broad the language is in the UFTA,” Professor Jerry said.
He continued, “If Trupanion is kicking back benefits from claims processing to a vet, if I were a regulator, I would
be very worried, as such a practice would clearly implicate the anti-rebate law.” There is “no question about this,”
Jerry said, because “the law prohibits the payment of ‘anything of value.’”
We presented the factual scenario to the Virginia Insurance Commissioner’s office. In response, a spokesperson
directed us to the Virginia statute on rebates, which mirrors the UFTA: “Except as otherwise expressly provided by
law, no person shall: Pay, allow or give, or offer to pay, allow or give, directly or indirectly, as inducement to any
insurance or annuity contract, any rebate of premium payable on the contract, any special favor or advantage in the
dividends or other benefits on the contract, any valuable consideration or inducement not specified in the contract,
except in accordance with an applicable rating plan authorized for use in this Commonwealth.”
The spokesperson said that under Virginia insurance law, it does not matter if the commission or rebate is being
shared with an unlicensed as opposed to a licensed producer.
Both Iowa and Illinois have similar anti-rebate laws.
WA State OIC 46
3

The Full Event
Veterinarians: Earn a Trip

to Hawaii, Las Vegas, or
Seattle!
We are excited to announce a new addition to the
Trupanion Rewards Program. When you join our
Partners Program, your hospital team can now
qualify for a trip for 2 to one of three exciting
destinations. This 4-night, 5-day trip for one staff
member and their guest is a wonderful opportunity
to reward someone for [...]The post Veterinarians:
Earn a Trip to Hawaii, Las Vegas, or Seattle!
appeared first on The Trupanion Blog.
Source: Trupanion Blog
Read full article >
Latest Events about Trupanion
Sep 30, 2017
Veterinarians: Earn a Trip to Hawaii, Las Vegas, or

Seattle!
WA State OIC 47
Sep 30, 2017
File #1569460 Exhibit #1C Page 1 of 4
Rehoming your pet in the face of a disaster

Sep 28, 2017
How to foster a dog or cat

Sep 24, 2017
5 ways to pamper your pup

Sep 23, 2017
Trupanion Inc (TRUP) Raised to Hold at BidaskClub

Sep 22, 2017
Cómo evacuar con su mascota de manera segura

Sep 19, 2017
Trupanion Inc (TRUP) Expected to Announce

Quarterly Sales of $61.50 Million
Sep 17, 2017
Unique Cat Furniture for the Stylish Cat Owner

Sep 15, 2017
Massachusetts pet names are inspired by Ireland,

coffee, and sports
Sep 13, 2017
How you can help pets after a natural disaster

Sep 12, 2017
Sep 12, 2017

WA State OIC 48
About Trupanion View Full Trupanion Profile >
Trupanion At-a-Glance Key Stats Headquarters
Revenue
$227.5M
Trailing Twelve Months
Founder & CEO

Employees
Darryl Rawlings
Approval Rating: 72% 450
14 Votes
Founded: 2000
6100
Headquarters: 4th Ave South,
Seattle,
Washington, USA
Status: Public, NYSE, TRUP
Industry Health Care
Sector: Services (6297)
Trupanion pet insurance offers dog and cat insurance in the United States and Canada. Trupanion was founded in 2000.
Trupanion's Headquarters are located at 6100 4th Ave South, Seattle, Washington, USA 98108. It has raised $109.3M in 3
rounds. The latest round was in 2014. Some of Trupanion's investors include Telegraph Hill Partners, Perot Investments,
Inc. and Maveron, LLC.
WHAT WE DO SUCCESS COMPANY RESOURCES ENTERPRISE
© 2017 Owler, Inc.

WA State OIC 49
WA State OIC 50
  
MENU

TRUPANION AFFILIATE PARTNERSHIP PROGRAM
Join Trupanion's Affiliate Partnership Program and share with your readers how medical pet insurance
for cats and dogs can help pet owners cover unexpected illnesses and injuries and how a Trupanion
policy can help.
Trupanion is medical insurance for cats and dogs and offers one simple plan, 90% coverage of all eligible
illness and injuries, no payout limits, and the option to pay your vet directly.
Terms and conditions apply. See the full policy for details
Benefits to being a Trupanion Affiliate

Partner
WA State OIC 51
File #1569460 Exhibit #1D Page 1 of 3
  
MENU

Monthly reporting on traffic data and monthly compensation for Qualified Leads generated.
Access to personalized marketing tools to promote Trupanion.
Ongoing support from Trupanion’s Affiliate Marketing team.
Ready to join? Click below to fill out our quick form.
Apply now >

Why Trupanion?
We believe that insuring your pet should be easy. We offer one simple plan for all pets to ensure that
they receive the best coverage. Our plan covers 90% of actual veterinary costs for eligible claims once
your deductible for that condition is met. We offer unlimited lifetime coverage with no payout limits or
caps. Lastly, we can pay vets directly. You pay your portion and we take care of the rest.
WA State OIC 52
How do I promote Trupanion?
promote Trupanion on your site.
  
MENU

What is a Qualified Lead?
A Qualified Lead is a lead that has completed an application and provided valid payment information for
purchasing a Trupanion Policy. They do not need to purchase the policy to be considered a Qualified
Lead.
How do you track and pay for Qualified Leads?
Unlike most affiliate programs that pay quarterly, we pay for Qualified leads monthly by using your unique
tracking link to measure how many applications were referred from your site.
How will the Affiliate Partnership Program benefit me?
It’s simple, you earn money every time a Qualified Lead that you send over to Trupanion’s site submits
an application for a Trupanion policy.
Apply now >
© 2018 Trupanion. All Rights Reserved.
USA – English  
Privacy Policy | Site Map | Terms of Use and Regulatory Info WA State OIC 53
Search Go
Adoption Volunteer Events Services & Resources
Education About Us Donate
Events
Pet Insurance Benefit for Seattle Humane

Upcoming
Events
Alleviate the financial stress associated with your
pet's medical expenses and generate funds for Seattle Humane at
Santa Paws:
Pet photos with the same time! Sign up for the Trupanion program using this link
Santa! and a $5 donation will be made to Seattle Humane.
Dec 2 , 1 pm
Shelter Grand Shop AmazonSmile!

Opening!
Dec 9 , 10 am You shop - Amazon gives! Sign up for AmazonSmile and they'll
See the Calenda

Your Own
If you, a family member, friend or
neighbor is looking to buy or sell a
home consider working
with Brokers Supporting Pet Rescue
(BSPR), a network of animal-loving
Washington State
Windermere Brokers working together to help rescue animals.
BSPR will donate 10% of net commissions with every home sale or
purchase.
WA State OIC 54
File #1569460 Exhibit #1E Page 1 of 4
Visit their website to learn more and find a BSPR Broker in your
area.

Your Own
You shop - Amazon gives! Sign up for AmazonSmile and they'll
Find a Sitter, Save a Life!

Seattle Humane has partnered with Rover.com, the country’s
largest dog boarding marketplace, to help dog owners connect with
local dog-friendly homes and dog sitters. When you book a dog
sitter through our SH Rover landing page and use the promo code
SH10, Rover.com will donate $10 to Seattle Humane. Sign up
today!
Shop Fred Meyer

Sign up for Fred Meyer's Community Rewards program and every
time you use your Rewards Card a donation will be made to
Seattle Humane! You'll still earn your rewards points, fuel points,
and rebates, just as you normally do. Visit
fredmeyer.com/communityrewards and link your card to "Seattle
Humane.
Seattle Humane is a SMCU Checking

Partner in 2017
Thanks to you, Seattle Humane was
selected as a SMCU Checking Partner for
2015! That means that for each new Feel
Good Checking account opened in 2015
we get $20 if selected among the 2015
highlighted charities. You also get 6.14%
APY on the first $500 in your account, free checks, Bill Pay, and
Online/Mobile Banking. Click here for more info!
WA State OIC 55
Book a Stay at the Paramount Today!

The gorgeous and glamorous
Paramount Hotel in the heart of
Downtown Seattle, which boasts a 4.5
star Trip Advisor rating and one of the
best Pan Asian restaurants in the city, is partnering with Seattle
Humane to raise funds for homeless pets! Anyone who uses this
site to book their stay will gift an automatic matched donation from
Paramount to Seattle Humane:
http://www.paramounthotelseattle.com/promotions/support-seattle-
humane-society.htm Booking a relaxing stay in style never felt so
good!
BarkHappy App hits Seattle

Is your dog BarkHappy? If you haven't
already, download the free BarkHappy
app at BarkHappy.com! It's really more
than an app. It's a community for the dog-
obsessed who enjoy taking their fluffy
friend with them everywhere. You can find
restaurants and venues that are dog-
friendly, and even search by ones that allow dogs indoors or have
covered patios. Plus they have events each week to mix, mingle,
and play! We're honored that BarkHappy has chosen Seattle
Humane as a charitable partner.
WA State OIC 56
Well Hello There!

We adopted
brother and sister
cats who love to
play, explore, and Join our
be loved. They're newsletter!
also great with our
grandchildren and
have brought a lot
of fun to our
household.
Proud Parents to Sunny &
Pansy
WA 98005
WA State OIC 57
•
trt.:Jpa I
TOP 10 RE S NS
WE'RE BETTER
VPl/Nationwide
1. WE DON'T EXCLUDE COVERED CONDITIONS AT RENEWAL.
Conditions a pet has developed over the past year, that were covered by the VPI/
Nationwide policy (or related conditions), can be considered an exclusion at annual
renewal.
2. WE DON'T RAISE RATES WHEN A PET HAS A BIRTHDAY.

VPl/Na1'ionwide utilize "Birthday Pricing", where policyholder's rates increase each
year due to their pet aging. These rates grow by 15-183 per year and are in addition to
infiation changes.
3. WE DON'T DROP COVERAGE.

VPl/Nationwide has the ability to cancel a policy with only ten days' notice, for
absolutely no reason at all, or choose not to renew it when a policyholder's annual
anniversary comes up.
4. WE DON'T EXCLUDE CONDITIONS MOST LIKELY TO HAPPEN TO SPECIFIC BREEDS.

The majority of VPl/Na1·ionwide's plans do not cover the things most likely to happen
to specific breeds, known as congenital or hereditary conditions. In addition, they also
exclude over 182 conditions from most of their plans.
5. WE DON'T SHARE MEMBER'S PRIVATE INFORMATION.

Nationwide is a huge company with over 30 individual insurance products. They share
policyholder's private information with third parties to attempt to sell other products, like
car and home insurance, with no opt out option.
6. WE REIMBURSE ON THE ACTUAL VETERINARY INVOICE.

Most of VPl/Nationwide's plans reimburse policyholders based on a Benefit Schedule.
Basically, they are deciding how much a pet's treatments should cost, not what they
actually cost according to the veterinarian.
WA State OIC 58
Comparison based on public-facing information as of June 9, 2016.

Please read VPl/Nationwide's policy for full coverage details.
File #1569460 Exhibit #1F Page 1 of 2
7. WE DON'T NEED TO "APPROVE" PETS FOR COVERAGE.
When a pet owner' enrolls, VPl/Nationwide's underwriters check to make sure that a pet
doesn't appear to be a liability for·them, usually "approving" a pet within 3 days. They'll
also make a decision about what plan a pet "qualifies" for.
8. WE'RE HERE 24/7.

VPl/Nationwide is only available M-F, 7:30am -4:30pm. That means they're open
less than 273 of the week.
9. WE OFFER FINANCIAL FLEXIBILITY & A DEDUCTIBLE RANGE FROM $0 - $1000.

VPl/Nationwide has two deductible options available, $100 and $250. This makes it hard
to ensure coverage can fit into a monthly budget
10. WE DON'T COVER WELLNESS.

Because we believe that we should focus on providing the coverage that gives the
pet owner the most value - covering those conditions that are often the most costly to
treat, injuries and illnesses.
Comparison based on put)lic-facing information as of .June 9, 2016.

!'lease read VPl/Nationwide's policy for full coverage details.
WA State OIC 59
Trupanlon Is a registered trademark owned by Trupanion, Inc. Underwritlen by Omego General Insurance
Company (Canada) and American Pet Insurance Company (USA): 6100 4th Ave S, 2nd Floor, Seattle, WA 98108

State of Washington
Office of Insurance Commissioner
Legal Affairs Division
Interview of Ned Gaines

OIC Case Number 1569460
Interview Date 9/27/2018
Interviewee Contact Ned Gaines
Information
Investigator Conducting Harvey Churchill
Interview
Others Present N/A
Location of Interview OIC Tumwater
Interview Recorded No
Declaration Prepared No
On the above date, I met with Ned Gaines from Market Conduct.
Ned clarified that he had concern the Trupanion were providing a false statement in the comparison with
Nationwide by stating that they would pay any veterinarian fee charged whereas other insurers restricted
claim fee to amounts in an agreed benefit schedule.
His experience is that most all insurers pay claims based on some sort of benefit schedule.
WA State OIC 60
Page 1 of 1
File #1569460 Exhibit #1G
Simba: Printer Friendly Version Page 1 of2
Churchlll, Harv~y ()
COMPANY MASTER INQUIRY
WAOIC .ft NAIC #
Company Information
Name American Pet Insurance Company Inc FEIN 74-3211949
NAIC# 12190 Org.Type Property Comp. Type Stock
WAOIC# 187058 CIC # NIPPOIC997QN NAIC Code
Adm. Date 11/15/2001 Dom.Type Foreign Dom, State New York
status Active Status Date 11/15/2001 Inact, Reason
Mailing Address Domicile

SOP Address
Address
6100 4TH AVES STE 200 45 ROCKEFELLER 300 DESCHUTES WAY SW STE 304
SEATTLE WA, 98108 PLAZA STE 200 TUMWATER WA, 98501
Tel:888-738-747B New York NY, Tel:SSS-690-3882
Fax: 10111 Fax:302-6.'36-5454
emall:aplc __ compllance@amerlcanpetlnsurance.com Tel:888-738- ema!l~aplc__compllance@al'nericanpetlnsurance.com
7478
Fax;
email:
Total Active Lines: 6 Total Non-Active Lines: O OAll ®Active
!Company Lines Status jApproval Date Cancel Date

asualty Active .1.1/15/2.001
Disability Active 11/15/2001
Marine Active 11/l~i/2001
Property Active 11/15/2001
3urely Active 11/15/2001
ehlcle Active 11/15/2001
Total Active Appointments: 16 Totaf Non··Actlve Appointments: 58 OAll ®Active
WAOIC !Cancel Appt, • Cases Orders

A.ppolntee Name
..'.HAMES JR, LOUIS P

•
259668
IAppt. Date
01/09/2018
Date
License Type
Insurance
Type
RAP
Lines Count
Ii·,.,
Count
)
Producer
Insurance
"'enter, Amanda R.'39756 b1.10912orn
Producer
Insurance
RAP
I" )
Markham, Jayme E 885485 01/09/2018 RAP '..) )

Producer
Benexchangc Financial Group Insurance [;J
·~rn
964440 P•/09/2018 RAP )
roducer
nsurance
3y You, LLC 969812 12/11./2017 RAP " 0
P1·oducer
,ompare Pet Insurance nsurance I'.}
922265 b4/04/2018 RAP ')
ervlces Inc Producer
.....onsumers Advocate Group, nsurance
892652 )3/30/2016 RAP 0 0
Lt Producer
Insurance
r:over Financial, Inc, 923757 19/08/2016 RAP J) )
Producer
rNSURANCE PLACEMENT Insurance
18121.0 fl1J20/2018 RAP :1 )
ERVICES INC Producer
nsurance
)ETPARTNERS INC 226508 P7/14/2014 RAP 1 2
Producer
Insurance
PETPARTNERS INC 226508 fl?/10/2017
Producer
MAP 1 ~
lETS BEST INSURANCE Insurance ')
270403 flB/31/2016 RAP .)
"ERVICES LLC Producer
ETS BEST INSURANCE Insurance
270403 P7/1012017 MAP D 0
ERVICES LLC Produc()r
Insurance
PlQ LLC ~77530 03/24/2.017 RAP 1 )
Producer
WA State OIC 61
Insurance
rrupanlon Managers USA, Inc. 718030 p1/0112009 RAP 1. 1
Producer

http://iuisimbacore/Protected/MNT/CompanyMasterlnquiry.aspx?mode=M&calledFrom=I. .. 912712018
:~rupanlo11 Managers USA, Inc, [718030 ~7/10/20171 / Insurance

Producer
1
IMAP I lz 11 I
leases by Division 2014 2015 2016 2017 2018 tTotal till Date
otal Cases 1 14 5 43
ompany Supervision a a 0 1
onsumer Advocacy 8 1 14 ~ 2
nvestlgatlon 0 a a 0 1
.egal 1 a 3
~rders Division 12014 i201s !2016 j2011 ]2018 ~otal till Date I
Legal 10 10 11 10 10 ~
Addltional Company Information Prnflle
Cases bv Division
• Total Cases count displays the number of unique cases closed for that year.
• The division counts display the number of closed cases assigned to that division. If the case was assigned to multiple
divisions, the case will be Included In each of the cllvlslon counts.
• Total till Date Is the count for both Closed and the Open Cases.
Orde1·s Division
• Count against the years In the Orders Division Is the count for the Orders Issued.
• Total till Date In the Orders Division Is the Count for the total Orders.
SIMBA (Production Web IU!) Release Date: September 16, 2018

copyright@ 2010 by Office of the Insurance commissioner
WA State OIC 62
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- American Pet Insurance Company Inc 187058 NIPPOIC997QN 12190 Active Property D, P, C, M, S, V
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SIMBA {Production Web IUI} Release Date~ September 16r 2018

Copyright© 2010 by Office of the Insurance Cornmlssloner
WA State OIC 63
http://iuisimbacore/Protected/CS/CompanySearch.aspx?mode=S 9/27/2018
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VIEW COMPANY
Company Information
Name FEIN
Organization Cornpany
NAJC # Prope1·t.y
Type Type
NA!C
WAO!C # 187058 CIC # NIPPOJC997QN Group
Code
Order Documents Documents
Authorization Information
Dornlclle
Adrrlisslon Date Dornlclle Type 'Forei(.Jn New York
State
Status Date
Inactivation
Status Active : 1 lJ l.5/?{)():I Reason
Application Review
...
.0
Recv. Date AsSlgn Date Assign To Deemed Comp Date Appl. Status Appl. Status Date
11/15/2001 11/15/2001 Migration Migration 11/15/2001 Approved il/15/2001 D

Company Lines Show All
Lines Status Approval Date Cancel Date 0
[J
D
Domiciliary Address
Contact Name KUTAK ROCK LLP
Street 1
Street 2
WA State OIC 64
http://iuisimbacore/Protected/CS/Company .aspx?CompanyNumber= 187058&mode=V&Is... 912712018

City YO;'k , :Country
State/ Province New Yor-k Zip
Phone # Bfl8·7:lt> 7478 Extension Fax
E-mall
Mailing Address
Contact Nan)e
Street 1
Street 2
City ;country
State/ Province W;a_?hinqton Zip
Phone# Extension Fax
E-mail
Service Of Process Address
Contact Name jCOR-PORATION SERVJ:CE COMPANY
St~·eet 1
Street 2
City TUMVVf\Tf:.R. ,~country :United
State/ Province ,YJashi1:'JQ_l:on Zip
Phone# Fax
E-mail
,Action Log Show All
created
on Action Comments Created By D
SOP Address changed FROM: 300 '
. 02/22/2018 SA - SOP Address
DESCHUIES WAY SW,.,
Sarah Gosney 1:0
Malling Address changed FROM; 6100 4TH
02/22/2018 MA - Malling Address
AVES,, .. ,
Sarah Gosney D
.
Domiciliary Address changed FROM: 16th Fl
. 02/22/2018 RA • Domiclllary Address
45 Br.,,
Sarah Gosney D
Tax Address changed from: Liz Malthews, Amer'lcan Pet Insurance
02/24/2017 TX - Tax Addr·ess
6100 4t ... Company Inc D
.
CP - Company Complaint Cornplalnt Address changed from: Louis American Pet Insurance
10/ll/2016
Address Charnes, 9 ... Cornpany Inc D
Tax Address changed from: Liz Matthews, American Pet Insurance
09/13/2016 TX - Tax Address
907 NW ... Company Inc D
..
'
Malling Address changed FROM: 907 NW
BALLARD WA ...
Glenda Cummings 0.
.
Tax Address changed fro in :-Liz Matthews, American Pet Insurance
02/26/2016 TX - Tax Address
5245 Sh ... Company Inc D
ADDRESS CHANGED PER 2013 ANNUAL
09/.1.7/2014 OT - Other
STATEMENT.
Susan Miller D
Malling Address changed FROM: 3022
09/17/2014 MA ~ Malling Address Susan Miiier D
WA State OIC 65
BROADWAY ROO ...
http://iuisimbacore/Protected/CS/Company .aspx?CompanyNumber= 187058&mode=V&Is .. , 9/27/2018

CP " Company Complaint Complaint Address changed from: Lours American Pet Insurance
03/25/2014
Address Chames, 9 ... Co1npany Inc D
SOP Address changed FROM; 505 UNION AVE
03/21/2013 SA - SOP Address
SE, SUI. ..
Shelly Goodwin D
'
CP - Company Cornplalnt Company Ccmpfalnt Address Added: Louis
1.2/19/2012
Address Chames, ...
Desiree Rosenberg D
SOP Email Address changed FROM:
CTWADOI@wolters ...
Lisa Whiton D
SOP Address changed FROM: CT
09/2:1/2012 SA " SOP Address
CORPORATION SYSTEM .. ,
Lisa Whiton D
SOP Address changed FROM: 6505 216th St
SW Bldg,.,
Tierra Dickinson D
Malling Address changed FROM: 1148 NW
06/l3/2012 MA • Malling Address
LEARY WAY ...
Tierra Dickinson D
Status Date Changed to Admission Date.
' 11/20/2009 OT~ Other
Active c ...
Kevin Torgerson D
Address change per e .. mall from Louis
08/19/2009 OT - Other
Chames
Shelly Goodwin []
Malling Address changed to: 1148 NW LEARY
08/19/2009 MA .. Malling Address
WAYS ...
Shelly Goodwin D
''
Company's Name American Pet Insruance

02/08/2008 NC - Name Change
Company I ...
Susan Miller D
SOP Address changed to: 6505 216th St SW
Bldg A .. , '
Susan Miiier D
Malling Address changed to: 6505 216th St:
SW Bl ...
Susan Miiler D
Do1nlcl!lary Address changed to: 16th Fl 45
01/03/2008 RA - Domlclllary Address
Broa ...
Susan Miiier D
Company's Nam·e NIPPONKOA INSURANCE
01/03/2008 NC w Name Change
COMPANY OF A...
Susan Miiler· D
Address changes per a letter from Ken
05/22/2007 01- Other
Soldwedel
Shelly Goodwin D
Malling Address changed to: 505 FIFTH AVES
STE ...
Shelly Goodwin [J
Domlclllary Address changed to: 10 EAST
05/22./2007 RA ·· Domiciliary Address
40TH ST ...
Shelly Goodwin D
05/09/2007 OT - Other FEIN changed from 'Null' to '13-4151621' Import Interface D
11/14/2003 MA - Malling Address MAILING ADDRESS CHANGE Mlgl'atlon Migration D
'
11/14/2003 RA ~ Don1lclllary Addre$S REGISTERED ADDRESS CHANGE Migration Migration D

AC - Company
11/15/2001
Authorized
NY NEW YORK Migration Migration '0
AC - Company
11/15/2001
Authorized
COMPANY ADMITIED Migration Migration D
Payments
INo payment records available.

WA State OIC 66
http://iuisimbacore/Protected/CS/Company .aspx?CompanyNumber= 18705 8&mode=V &Is... 9/27/2018

0Q0934A72 în'ij'iL- IDOI'JOO.-JU
STATE OF WASHINGTON
OFFICE OF THE INSURANCE COMMISSIONER
In the Matter of
AMERICAN PET INSURANCE Order No. 16-0127

COMPANY, INC.
WAOICNo. 187058
NAICNo. 12190
Authorized Insurer.
CONSENT ORDER LEVYING
A FINE
This Consent Order Levying a Fine ("Order") is entered into by the Insurance
Commissioner of the state of Washington ("Insurance Commissioner"), acting pursuant to the
authority set forth in RCW 48.02.060, RCW 48.05.140 and RCW 48.05.185, and American Pet
Insurance Company, Inc. This Order is a public record and will be disseminated pursuant to Title
48 RCW and the Insurance Commissioner's policies and procedures.
BASIS:
1. American Pet Insurance Company, Inc. ("APIC" or "the Company") is an
authorized insurer domiciled in New York and duly authorized to engage in the business of
insurance in the state of Washington. Tnipanion, Inc. is the present name of the parent
company of both APIC (insurer) and Trupanion Managers USA, Inc. ("Trupanion") (its
affiliate and licensed agency).
2. The Market Conduct Examination ("MCE") dated September 22, 2015, noted
deficiencies with the Company's oversight of insurance operations, complaint handling
practices, marketing and sales materials, producer activities, rate and form filings, and policy
administration and underwriting practices.
3. As of the begirming of the examination period, APIC is licensed in 50 states,
Washington D.C., Puerto Rico, and Canada. The Company is authorized to write multiple
WA State OIC 67
CONSENT ORDER LEVYING A PINT Siaic of Washington

ORDER NO. 16-0127 Office of ihe Insurance Commissioner
PO Box 40255
LA 133055S- I Olympia. WA 98504-0255
lines of property and casualty insurance. In practice, the Company only sells a single inland
marine product; pel health insurance.
4. Historically, APIC has delegated administrative and service ftinctions to its
two licensed agencies: Trupanion Managers USA, Inc. and PetPartners, Inc. The agencies
handle all sales, policy servicing, and claim functions on behalf of APIC. Each of the agencies
offer distinct policies underwritten by APIC. Trupanion Managers USA, Inc. is the primary
agency and APIC's Trupanion policy accounts for the majority of the Company's policies in
force.
Company Operation and Management
5. The MCE found that during the examination period, the Company
demonstrated a lack of adequate controls in all of the areas of operations reviewed. The
majority of violations noted were the direct result of programs implemented by the Customer
Service Contact Center, Information Technology, and the Marketing departments. The
Company verified that no formal or informal audit policies or procedures were in place during
the examination period. Each business unit was responsible for its own operations with limited
communication related to compliance or legal issues between departments.
6. The Examiners found multiple violations regarding the use of the Company's
legal name. These include the Company's failure to use its legal name on all system generated
correspondence to policyholders, marketing materials that did not include the Company's full
legal name and marketing of the brand name "Trupanion" in a way as to indicate that
"Trupanion" was the name of the insurance company.
7. The Examiners also noted that the Company did not establish record retention
policies and procedures. In some cases, APIC was unable to produce records because they
failed to keep policy documents for more than five (5) months. In some cases, employees used
their work email to maintain and hold policy documents and file notes rather than store them
in a central location under general record retention standards.
8. Although it appeared unintentional in most cases, some of the practices
established by the Company appeared to be discriminatory. For example, even though it was
not listed as an underwriting qualification, the Company only issued policies to people with
WA State OIC 68
CONSENT ORDER LEVYING A FINE 2 State of Washington

ORDER NO. 16-0127 Office of the Insurance Commissioner
PO Box 40255
LA 133055S - I Olympia. WA 98504-0255
email addresses. The Company also allowed waiving and reftmding of policy enrollment fees
for reasons other than as filed. Additionally, the Company allowed call center employees to
refijnd all or part of a premium payment to settle disputes or complaints without regard to
filed rates.
9. RCW 48.05.190(1) states that every insurer shall conduct its business in its
own legal name. The Company consistently failed to identify its legal name, American Pet
Insurance Company, in all of its business dealings. In each instance of file, phone calls,
recordings, and advertising material reviewed, the Company's legal name was not identified
in violation of RCW 48.05.190.
10. RCW 48.05.280 provides that every insurer shall keep fijil and adequate
accounts and records of its assets, obligations, transactions, and affairs. The Company failed
to maintain adequate accounts and records of its transactions and affairs in violation of
RCW 48.05.280.
11. RCW 48.18.480 states that no insurer shall make or permit any unfair
discrimination between insureds or subjects of insurance having substantially like insuring,
risk, and exposure factors, and expense elements, in the terms or conditions of any insurance
contract, or in the rate or amount of premium charged therefor, or in the benefits payable or
in any otherrightsor privileges accruing thereunder. The Company allowed practices that did
not treat all consumers in an equitable manner such as the practice of waiving policy
enrollment fees, discounting enrollment fees, and indiscriminately applying deductibles for
some but not all in violation of RCW 48.18.480.
12. WAC 284-30-650 provides that it is an unfair practice for an insurer to fail to
respond promptly to any inquiryfi-omthe Insurance Commissioner relative to the business of
insurance. A lack of response within fifteen business days from receipt of an inquiry will be
considered untimely. A response must be in writing and submitted using the Insurance
Commissioner's electronic company complaint system. The Company failed to timely
respond thirty-one (31) times in violation of WAC 284-30-650.
WA State OIC 69
CONSENT ORDER LEVYING A FINE Slate of Washington

PO Box 40255
LA 1330558 - I Olympia. WA 98504-0255
Complaint Processes and Procedures
13. The Examiners reviewed all available complaints submitted by consumers to

APIC during the examination period. The complaints were processed by the licensed producer
at either Trupanion Managers USA, Inc. or PetPartners, Inc., depending upon which producer
sold the policy. The complaint records indicate that the complaints processed through
Trupanion Managers USA, Inc. were handled in a timely fashion. Complaint records for
policies issued through PetPartners, Inc. were not available to the Examiners because
PetPartners, Inc. did not maintain complaint logs or track direct consumer complaints.
14. Consumer complaints received by the Insurance Commissioner during the
examination period were for Trupanion Managers USA, Inc. policies only. The Company
failed to timely respond to approximately one-third (1/3) of the Insurance Commissioner's
complaint inquiries. During the examination period the Company did not have formal
complaint handling processes and procedures, or a clearly defined definition of a complaint.
15. WAC 284-30-360(2) provides that upon receipt of any inquiry fi-om the
Insurance Commissioner concerning a complaint, every insurer must fiimish the Insurance
Commissioner with an adequate response to the inquiry within fifteen working days after
receipt of the Insurance Commissioner's inquiry using the Insurance Commissioner's
electronic company complaint system. The Company violated WAC 284-30-360(2) on two
(2) occasions.
16. WAC 284-30-650 states that it is an unfair practice for an insurer to fail to
respond promptly to any inquiry from the Insurance Commissioner relative to the business of
insurance. A lack of response within fifteen business days from receipt of an inquiry will be
considered untimely. A response must be in writing and submitted using the Commissioner's
electronic company complaint system. The Company violated WAC 284-30-650 on two
occasions by failing to respond promptly.
17. WAC 284-30-670(5) provides that to assist the Insurance Commissioner in
identifying the legal name of the insurer, insurers' written communications to the Insurance
Commissioner in response to any investigation, inquiry, enforcement matter or examination
must include the insurer's NAIC code. The Company violated WAC 284-30-670(5) on three
(3) occasions by failing to include its NAIC code in its written communications.
WA State OIC 70
CONSENT ORDER LEVYING A FINE 4 Siate of Washington

ORDER NO. 16-0127 Office of ihe Insurance Commissioner
PO Bo.x 40255
LA 1350558 - I Olympia, WA 98504-0255
Marketing and Sales
18. During the examination period APIC utilized the Trupanion Managers USA,
Inc. agency to create and distribute all of the marketing and sales material for its Trupanion
policies, while the materials for its PetPartners policies were created and distributed by
PetPartners, Inc.
19. The Examiners noted significant violations concerning marketing and sales
materials for both the Trupanion and PetPartners, Inc. policy forms. The violations included
instances of false, deceptive and misleading information contained in the materials such as
use of the phrase "Trupanion is unlike any other pet insurance company out there," and
"Trupanion is a mono-line insurance company." Marketing materials included statements
indicating that discounts are available but these discounts were not filed with their rates, and
were applied in a discriminatory manner. The violations were applicable to both the
Trupanion and PetPartners marketed products.
20. RCW 48.30.040 provides thai no person shall knowingly make, publish, or
disseminate any false, deceptive or misleading representation or advertising in the conduct of
the business of insurance, or relative to the business of insurance or relative to any person
engaged therein. The Market Conduct Exam revealed that RCW 48.30.040 was violated three
(3) times.
21. RCW 48.30.050 states that every advertisement of, by, or on behalf of an
insurer shall set forth the name in full of the insurer and the location of its home office or
principal office, i f any, in the United States (if an alien insurer). APIC violated RCW
48.30.050 on ninety-three (93) occasions through Trupanion's actions and on five (5)
occasions through PetPartners' actions.
22. RCW 48.30.060 provides that no person who is not an insurer shall assume or
use any name which deceptively infers or suggests that it is an insurer. The Market Conduct
Examination revealed that APIC permitted Trupanion to violate RCW 48.30.060 fifty (50)
times.
23. RCW 48.30.140( 1) states that except to the extent provided for in an applicable
filing with the commissioner then in effect, no insurer, insurance producer, or title insurance
agent shall, as an inducement to insurance, or after insurance has been effected, direcdy or
WA State OIC 71
CONSENT ORDER LEVYING A FINE 5 Stale of Washington

PO Box 40255
LA 1330558 - 1 Olympia, WA 98504-0255
indirectly, offer, promise, allow, give, set off, or pay to the insured or to any employee of the
insured, any rebate, discount, abatement, or reduction of premium or any part thereof named
in any insurance contract, or any commission thereon, or earnings, profits, dividends, or other
benefit, or any other valuable consideration or inducement whatsoever which is not expressly
provided for in the policy. APIC permitted Trupanion to violate RCW 48.30.140(1) twenty
(20) limes and PetPartners fourteen (14) times.
24. RCW 48.30.I50(l)(c) provides that no insurer, insurance producer, title
insurance agent, or other person shall, as an inducement to insurance, or in connection with
any insurance transaction, provide in any policy for, or offer, or sell, buy, or offer or promise
to buy or give, or promise, or allow to, or on behalf of, the insured or prospective insured in
any manner whatsoever:
(c) Any prizes, goods, wares, gift cards, gift certificates, or merchandise of an
aggregate value in excess of one hundred dollars per person in the aggregate in any
consecutive twelve-month period. APIC permitted Trupanion to violate RCW 48.30.150 four
(4) times.
25. WAC 284-30-670(3) and (4) state that;
(3) When used in this regulation, "legal name" of the insurer means the
name displayed on the Washington stale certificate of authority issued by the commissioner.
(4) Each insurer must have standards and procedures to ensure that each
consumer with whom they conduct an insurance transaction is informed of and can
consistently identify the legal name of the insurer. Each insurer must provide the Insurance
Commissioner with its standards and procedures and proof of its compliance upon request.
The insurer must be able to show the legal name was provided when issuing policy
documents, billing statements, and other written communications regarding policy services,
underwriting, and claims and at the point during policy sales transactions when the company
is determined. APIC permitted Trupanion to violate WAC 284-30-670(3) forty-seven (47)
times and Petpartners five (5) times.
WA State OIC 72
CONSENT ORDER LEVYING A FINE State of Washington

PO Bo.x 40255
LA 1330558 - i Olympia. WA 98504-0255
Producer Acti\1t\'
26. The Company used several channels to market and sell its pet insurance
policies. The primary channels were through its two appointed agencies, Trupanion Managers
USA, Inc. and PetPartners, Inc. Both agencies are licensed as Washington producers.
However, none of the call center representatives who actually solicited and sold policies to
consumers were licensed as producers in Washington nor were they appointed with the
Company. As part of the examination process, the Examiners reviewed recordings of
consumer sales calls. The Examiners confirmed that the call center employees were actively
engaged in the process of selling and soliciting insurance and were therefore required to be
licensed. No records showed that the call center employees were ever licensed or appointed
producers in Washington. This was true for both Trupanion and PetPartners. This has since
been corrected and all call center employees for Washington business are licensed in
Washington.
27. RCW 48.17.060(1) provides that a person shall not sell, solicit, or negotiate
insurance in this state for any line or lines of insurance unless the person is licensed for that
line of authority in accordance with this chapter. The MCE found that APIC permitted
Trupanion to violate RCW 48.17.060( 1) sixty-seven (67) times and PetPartners nine (9) times.
28. RCW 48.17.160 (1) and (2) state:
(1) An insurance producer shall not act as an agent of an insurer unless the
insurance producer becomes an appointed agent of the insurer.
(2) To appoint an insurance producer or title insurance agent as its agent,
the appointing insurer shall file, in a format approved by the commissioner, a notice of
appointment within fifteen days fi*om the date the agency contract is executed or the first
insurance application is submitted, whichever is earlier. APIC violated RCW 48.17.160 by
failing to appoint its producers, who sold, solicited and negotiated insurance.
29. RCW 48.17.490( 1) and (4) state thai:
(1) An insurance company, insurance producer, or title insurance agent
shall not pay a commission, service fee, or other valuable consideration to a person for selling,
soliciting, or negotiating insurance in this state if that person is required to be licensed under
this chapter or chapter 48.15 RCW and is not so licensed.
WA State OIC 73
CONSENT ORDER LEVYING A FINE 7 Slate of Washington

PO Bo.x 40255
LA 1330558- 1 Olympia, WA 98504-0255
(4) An insurer, except a title insurer, or insurance producer may pay or
assign commissions, service fees, or other valuable consideration to an insurance agency, or
to persons who do not sell, solicit, or negotiate insurance in this state, unless the payment
would violate RCW 48.30.140, 48.30.150, 48.30.155, 48.30.157, or 48.30.170. The MCE
found diat APIC violated RCW 48.17.490 forty-five (45) times.
30. WAC 284-17-429(2) provides thai insurance producers upon initial
appointment by an insurer or upon initial affdiation by a business endty must be authorized
to transact at least one line of authority within the authority of the insurer or the business
entity. APIC violated WAC 284-17-429(2) by permitting Trupanion call center employees to
sell, solicit, and negotiate insurance, who were not authorized to transact insurance within the
line of authority.
Form Filings
31. During the examination period the Company's form filings were handled by
Trupanion Managers USA, Inc. for APIC's Trupanion Managers USA and PetPartners
policies. The Examiners found that the Company issued policy forms that differed from the
filed and approved forms submitted to the Insurance Commissioner.
32. RCW 48.18.100 provides that no insurance policy form or application form
where written application is required and is to be attached to the policy, or printed life or
disabilityrideror endorsement form may be issued, delivered, or used unless it has been filed
with and approved by the commissioner. APIC permitted Trupanion to violate RCW
48.18.100 twenty-four (24) times and PetPartners twenty-five (25) times.
33. RCW 48.18.140 (2)(a-0 states that a policy shall specify: (a) The names of the
parties to the contract. The insurer's name shall be clearly shown in the policy, (b) The subject
of the insurance, (c) The risk insured against, (d) The time at which the insurance thereunder
takes effect and the period during which the insurance is to continue, (e) A statement of the
premium, and if other than life, disability, or title insurance, the premium rale where
applicable, (f) The conditions pertaining to the insurance. The Market Conduct Examination
found that APIC permitted Trupanion to violate RCW 48.18.140 one hundred and nineiy-six
(196) times.
WA State OIC 74

PO Box 40255
LA 1330558 - 1 Olympia, WA 98504-0255
34. RCW 48.18.190 provides that no agreement in conflict with, modifying, or
extending any contract of insurance shall be valid unless in writing and made a part of the
policy. The Company's business practice of using emails that are not made part of the policy
to communicate policy modifications violated RCW 48.18.190.
35. WAC 284-208-030(4) states that each form must have a unique identifying
number and a way to distinguish it from other editions of the same form. APIC violated WAC
284-20B-030 two hundred and twenty-one times (221).
36. WAC 284-92-260(1) provides that the requirements for filing and approval of
policy rates and forms apply to forms issued to or in coruiection with purchasing groups to
the same extent as they apply in other situations. APIC violated WAC 284-92-260( 1) through
PetPartners' actions 1,160 times.
Rate Filings
37. During the examination period the Company's rate filings were handled by
Trupanion Managers USA, Inc. for the APIC Trupanion and PetPartners policies. The
Examiners' review determined that the Company issued policies using rates other than those
filed and approved. For example, the Company allowed management to waive and refiind
policy premium for other reasons than those that were filed with the Insurance Commissioner.
In addition, for PetPartners, the Company knowingly issued policiesft"omNovember 1, 2012,
through November 4, 2013, with unfiled rates.
38. APIC's actions violated RCW 48.19.040(1) three hundred and ninety-seven
(397) times. RCW 48.19.040( I) states that every insurer or rating organization shall, before
using, file with the commissioner every classifications manual, manual of rules and rates,
rating plan, rating schedule, minimum rate, class rate, and rating rule, and every modification
of any of the foregoing which it proposes. The insurer need not so file any rate on individually
rated risks as described in subdivision (1) of RCW 48.19.030; except that any such specific
rate made by a rating organization shall be filed.
39. RCW 48.19.040(6) states that where a filing is required no insurer shall make
or issue an insurance contract or policy except in accordance with its filing then in effect,
except as is provided by RCW 48.19.090. APIC violated RCW 48.19.040(6) through
WA State OIC 75
CONSENT ORDER LEV^ÎNG A FINE 9 State of Washington

PO Box 40255
LA 1330558 - 1 Olympia, WA 98504-0255
Trupanion's action two hundred and seventeen (217) times and through PetPartners' actions
five (5) times.
Policy Administradon and Underwriting
40. For Trupanion policies, (administered by Trupanion Managers USA, Inc.) the
Examiners found instances where the Company continued policy coverage after an insured
no longer held an insurable interest in a pet covered under the policy, such as when a pet died
or when the policy owner no longer owned the pet. The Company did not follow Washington
policy cancellation laws and rules consistently.
41. The Examiners discovered cases where the Company failed to provide
complete policy documentation to policyholders. The Company also failed to provide 100%
of its policyholders widi the required initial and annual privacy notices.
42. The Examiners' review did not reveal any policy administration and
underwriting violations on PetPartners' book of business.
43. RCW 48.18.260(1) provides that subject to the insurer's requirements as to
payment of premium, every policy shall be delivered to the insured or to the person entitled
thereto within a reasonable period of time after its issuance. APIC's actions violated RCW
48.18.260( 1) one hundred and ninety-six (196) times.
44. RCW 48.l8.290(l)(c) states that cancellation by the insurer of any policy
which by its terms is cancellable at the option of the insurer, or of any binder based on such
policy which does not contain a clearly stated expiration date, may be effected as to any
interest only upon compliance with the following: (c) If an insurer cancels a policy described
under (a) or (b) of this subsection for nonpayment of premium, the insurer must deliver or
mail the cancellation notice to the named insured at least ten days before the effective date of
the cancellation. The Market Conduct Examination found fifteen (15) violations of RCW
48.18.290.
45. RCW 48.18.290(2) provides that the mailing of any such notice shall be
effected by depositing it in a sealed envelope, directed to the addressee at his or her last
address as known to the insurer or as shown by the insurer's records, with proper prepaid
postage affixed, in a letter depository of the United States post office. The insurer shall retain
WA State OIC 76

PO Bo.x 40255
LA i 330558 - I Olympia. WA 98504-0255
in its records any such item so mailed, together with its envelope, which was returned by the
post office upon failure to find, or deliver the mailing to, the addressee. TTie Market Conduct
Exam found ninety-nine (99) violations of RCW 48.18.290(2).
46. WAC 284-04-200 stales that initial privacy notice to customers are required.
The Company failed to provide the required initial privacy notice to policyholders 2,803
times.
47. WAC 284-04-205 provides that annual privacy notice to customers are
required. The Company failed to provide the required annual privacy statements to
policyholders 6,313 times.
48. WAC 284-30-570 stales that whenever an insurer is required by law to give
the reason for its canceling, denying, or reftjsing to renew insurance, as, for example, pursuant
to RCW 48.18.291, 48.18.292, or 48.30.320, it shall give the true and actual reason for its
action in clear and simple language, so that the insured or applicant will not need to resort to
additional research to understand the real reason for the action. It is not suf?icient, for example,
to state that an insured "does not meet the company's underwriting standards." The reason
why the individual does not meet such underwriting standards is what must be given. The
Company failed to provide sufficient reasons for canceling insurance to consumers fifty-eight
(58) times.
49. WAC 284-30-590(8)(b) provides that if a policy includes conditions allowing
the insured to cancel the policy, the insured may cancel the policy or binder issued as evidence
of coverage, (b) If the insurer receives notice of cancellationft-omthe insured, it must accept
and promptly cancel the policy or any binder issued as evidence of coverage effective the later
of: (i) The date notice is received; or (ii) The date the insured requests cancellation. The
Company violated WAC 284-30-590(8)(b) thirty-five (35) times by failing to cancel a policy
on the date requested by the policyholder.
50. RCW 48.05.140(1) provides the Insurance Commissioner authority to refuse,
suspend, or revoke an insurer's certificate of authority, in addition to other grounds therefor
in this code, if the insurer fails to comply with any provision of this code other than those for
violation of which refusal, suspension, or revocation is mandatory, or fails to comply with
any proper order or regulation of the Insurance Commissioner.
WA State OIC 77

PO Bo.x 40255
LA I33055S- I Olympia. WA 98504-0255
51. RCW 48.05.185 provides that after hearing or with the consent of the insurer
and in addition to or in lieu of the suspension, revocation, or refusal to renew any certificate
of authority the Insurance Commissioner may \c\y a fine upon the insurer in an amount not
less than two hundred fifty dollars and not more than ten thousand dollars.
CONSENT TO ORDER:
The Insurance Commissioner of the state of Washington and the Company agree the
best interest of the public will be served by entering into this Order. NOW, THEREFORE,
the Company consents to the following in consideration of its desire to resolve this matter
without further administrative or judicial proceedings. The Insurance Commissioner consents
to settle this matter in consideration of the Company's payment of a fine, upon the Company
fijlly carrying out its obligations under the Compliance Plan attached hereto as Exhibit A, and
upon such terms and conditions as are set forth below:
1. The Company acknowledges its duty to comply fully with the applicable laws
of the state of Washington.
2. The Company consents to the entry of this Order, waives any and all hearing
or other procedural rights, and further administrative or judicial challenges to this Order.
3. By agreement of the parlies, the Insurance Commissioner will impose a fine
of Two Hundred Fifty Thousand Dollars (5250,000.00) and suspend One Hundred Thousand
Dollars (5100,000.00) of that, on the conditions that:
a. The Company-pays One Hundred Fifty Thousand Dollars (5150,000.00)
by July 15, 2016; and
b. The Company commits no fiirther violations of the statutes and/or

regulations that are the subject of this Order for a period of two years
fi"om the date this Order is entered;
c. The Company complies with and carries out the Compliance Plan set
forth in Exhibit A hereto, which Compliance Plan is hereby incorporated
into this Order by reference as though fully set forth herein.
4. The suspended portion of this fine will be imposed at the sole discretion of the
Insurance Commissioner according to the conditions as set forth above, without any right to
hearing, appeal, or advance notice. The suspended portion of the fine will be paid within thirty
(30) days of the entry of an Order imposing it. Failure to pay the suspended portion of the fine
WA State OIC 78

ORDER NO. 16-0127 Office of ihc Insurance Commissioner
PO Bo.x 40255
LA 1330558 - 1 Olympia, WA 98504-0255
when imposed shall constitute grounds for revocation of the Company's certificate of
authority.
5. The Company understands and agrees that any fiirther failure to comply with
the statutes and/or regulations that are the subject of this Order constitutes grounds for fijrther
penalties, which may be imposed in direct response to fiirther violations in addition to the
imposition of the suspended portion of the fine.
6. This Order and the violations set forth herein constitute admissible evidence
that may be considered in any fiiture action by the Insurance Commissioner involving the
Company. However, the facts of this Order, and any provision, finding, or conclusion
contained herein does not, and is not intended to, determine any factual or legal issue or have
any preclusive or collateral estoppel effects in any lawsuit by any party other than the
Insurance Commissioner.
EXECUTED Uiis dayof ,2016.
AMERICAN BET CE COMPANY, INC.
By:
Printed Name: îr\OTfiy ^ Cjet4fA
Printed Corporate Title:
AGREED ORDER:
Pursuant to the foregoing factual Basis and Consent to Order, the Insurance
Commissioner of the slate of Washington hereby Orders as follows:
I. The Company shall pay a fine in the amount of Two Hundred Fifty Thousand
Dollars (5250,000.00) by July 15, 2016, of which amount the sum of One Hundred Thousand
Dollars (5100,000.00) is suspended on the condition that the Company fijlly complies with
the stamtes and regulations of the state of Washington which are the subject of this Order for
WA State OIC 79

PO Box 40255
LA I33055S - 1 OI>*mpia, WA 98504-0255
the next two years, and upon the fiirther condition that the Company fiilly carries out its
obligations under the Compliance Plan attached hereto as Exhibit A.
2. This Order and the violations set forth herein constitute admissible evidence
that may be considered in any future action by the Insurance Commissioner involving the
Company. However, the facts of this Order, and any provision, finding, or conclusion
contained herein does not, and is not intended to, determine any factual or legal issue or have
any preclusive or collateral estoppel effects in any lawsuit by any party other than the
Insurance Commissioner.
ENTERED at Tumwater, Washington, this ^J>1 day of ^^^^^n^ 2016.
MIKE KREIDLER
Insurance Commissioner
By and through his designee
M^tedy vfcks
iceEr
Insurance Enforcement Specialist
WA State OIC 80
CONSENT ORDER LEVYING A FINE 14 Slate of Washington

PO Bo.x 40255
LA 1330558- I Olympia, WA 98504-0255
EXHIBIT A
COMPLIANCE PLAN
Introduction
This attachment outlines the plan to address thefindingsin Consent Order Levying a Fine, Order
No. 16-0127 ("the Order"). The plan is intended to ensure that the business conducted by American
Pet Insurance Company, Inc. ("the Company") is in compliance with the Washington State
insurance statutes and regulations.
The plan encompasses two component parts: corrective actions and internal audits with reports to
the Office of the Insurance Commissioner ("OIC").
Effective Date of Plan
This plan will become effective upon execution of the Order.
Part I - Administrative Actions:
Within thirty (30) days of the entry of the Order, the Company will provide a corrective action
plan. This corrective action plan will include all steps planned and/or taken to resolve the violations
in the Order. This description will include:
a. The type of action taken (i.e., changes to computer systems or tracking and reporting
procedures, training);
b. The identities of the personnel that are/were involved in the corrective action;
c. Relevant dates; and
d. Copies of any material provided as part of corrective action (i.e., memoranda, written
policies, educational materials, etc.).
This information will be sent to:
Mandy Weeks
Office of the Insurance Commissioner
P O Box 40255
Olympia WA 98504-0255
Email: MandyW@oic.wa.gov
FAX: 360-664-2782
Provision of this information via fax or electronic means is acceptable.

WA State OIC 81
American Pet Insurance Company, Inc.

Exhibit A10 Order No. 16-0127
Page 1 of 3

Widlin thirty (30) days following receipt of the Company's corrective action plan, the OIC will
respond to the plan. This response will either be approval, in which case the plan is to be
implemented immediately, or a detailed statement of the areas in which the plan requires changes
to be acceptable, in which case the Company will have fifteen (15) days to respond. This process
will continue until the corrective action plan has been approved by the OIC. Once the plan is
approved by the OIC, it will be implemented immediately.
Part 2. Internal Audits
In order to assess the effects of the corrective action plan, the Company will perform at least four
semi-annual audits to ensure that no further violations of the statutes and/or regulations that are
the basis of the Order have occurred. The audits will evaluate whether all corrective actions set
forth in the corrective action plan are complete, and whether the corrective action has been
successfial in preventing any fiirther violations of the statutes and/or regulations that are the basis
of the Order. The audits will occur during a two-year period beginning on the date of entry of the
Order. The audit structure will be designed by the Company and will be presented to the OIC for
approval upon the same schedule set forth above for the corrective action plan.
Therefore, the proposed audit structure will be due to the OIC within sixty (60) days of the date of
entry of the Order. Within thirty (30) days following receipt of the proposed audit structure, the
OIC will respond to it. This response will be either approval, in which case no fiirther action is
necessary, or a detailed statement of the areas in which the audit structure requires changes to be
acceptable, in which case the Company will have fifteen (15) days to respond. This process will
continue until the audit structure has been approved by the OIC.
The audit structure to be designed by the Company and approved by the OIC will include audit
summaries. Audit summaries are reports from the Company to the OIC of the results of the semi-
annual internal audits. The form to be used for the audit summaries will be designed by the
Company and approved by the OIC.
The audit structure, including summaries, will be designed to evaluate whether the corrective
action plan has been successfial in preventing any fiirther violations of the statutes and/or
regulations that are the basis for the Order. The audit summaries will be designed to demonstrate
whether, during the audit period, the Company has violated the statutes and/or regulations that are
the basis for the Order. As an example, it may include a review of any new rates being used by the
Company since the last audit, to determine whether the rates used have been filed and approved
by the OIC.
For each exception (violation) found as a result of the audit process, the Company will include an
explanation of the cause(s) and the remedial action taken. The Company will undertake appropriate
remedial action acceptable to the OIC for each violation found within any audit.
WA State OIC 82
American Pet Insurance Company, inc.

Exhibit A to Order No. 16-0127
Page 2 of 3

The first audit period will begin on the date of entry of the Order. Each audit period is six (6)
months. The Company will provide each audit summary to the OIC no later than thirty (30)
calendar days after the end of the time period audited.
The audit summaries will be sent to:
Christine Tribe
Paralegal - Legal Affairs
Office of the Insurance Commissioner
P O Box 40255
Olympia WA 98504-0255
ChrisT@oic.wa.gov
FAX: 360-586-0152
Provision of the audit summaries via fax or electronic means is acceptable.
WA State OIC 83
American Pet Insurance Company, Inc.

Exhibit A to Order No. 16-0127
Page 3 of 3

Simba: Printer Friendly Version Page 1of1
di)churehfll, Harvoy ()
LICENSEE MASTER INQUIRY
WAOIC .ft
Licensee Details
Name Trupanlon Mf.lnagers USA, Inc. WAOIC # 718030 CIC I PIC #

DBA Name
Trupanlon
~ Onllne Documents
Documents
Mailing Address Business Address

61.00 4th Aves 6100 4th Ave S
Seattle WA, 98108-3234 Seattle WA, 98108 .. 3234
Tel:206-607-1897 Tel:206-607-1897
Fax:206-297-5952 Fax:206-29i'-5952
emaJ I : rou Is. chames@t ru pan lo n. com em al I: lou Is. ch ames@tru pan Ion. com
11-lcense 'Type Lines Effective Date Expiry Date Cancel Date Formed Date !Status
nsurance Producer , D, P, C 07/01/2009 01/15/2020 01/15/2008 ctive
gent Ol./15/?.008 01/15/2010 ~7 /01/2009 01/15/2008 Moved to Producer
!Cases by Division 2014 2015 2016 2017 2018 tfotal till Date
rota! cases I I ~ 0 2
!nvestJgatlon 1 n J 11
egal 0 1 p I
·:Prders Division 2014 )2015 J2016 J2017 )201s ~otal till Date
-k.egal 0 11 lo lo lo h I,
Additional Licensee Information Profile
cases by Division
divisions, the case w!ll be Included In each of the dlvlslon counts.
• Total tit! Date Is the count for both Closed and the Open C<.ises.
Orders Dlvisio11
• Count against the years Jn the Orders Division Is the count for ttw: 01·ders Issued.
• Total till Date In the Orders Dlvis!on Is the Count: for tile total Order·s.
SIMBA (Production Web IUl) Release Date: September 16, 2018

Copyright © 201.0 by Offlce of the Insurnnce Commissioner
WA State OIC 84

http://iuisimbacore/Protected/MNT/LicenseeMasterEnquiry.aspx?mode=M&IsFind=Y&W... 9/2712018
Print
INSURANCE PRODUCER LICENSE DETAILS
Total Active Lines: 4 Total Non-Active Lines: 0 OAll @Active
License Lines Status Approval Date Cancel" Date

!Casualty Active 07/01/2009
Life Active 07/01/2009
Dlsablf!ty Active 07/01/2009
Total Active Affillatlons: 140 Total Non-Active Affiliations: 72 OAll ®Active
Licensee ""AOIC # Eff, Date cancel Date Lines Cases Count !orders Count
A.lrd, Alexis f.!68241 11/28/2017 0 p
Amato, Linzie Rene S69844 12/16/2017 0 0
Aquino, Robee Henry 74901 3/13/2018 0 0
Arensberg, Phillip 926300 08/15/2016 (i 0
Ayers, Danlel 941403 01./30/2017 () 0
: Balbln 1 Mark Absalon S79152 04/09/2015 () J
Bennett, Jacob Dalton 825303 07/05/2016 () )
Bingham, Kacie Shauna S83291 06/21/2018 0

Blount, Andrew 952467 08/25/2017 0 D
Boling, Sarah Anne 938018 12/05/2016 fJ D
Botelho, Jordan 86366 07/12/2018 0 0
Brazil, Chryssa 969807 01/03/2018 0 0
Britton, Katl1erl ne 950363 05/25/2017 0 0
Brooks, Dominique Malloy 989506 08/16/2018 0 ()
Burglund, Aarlk 890943 07/23/2015 0 0

Burrow, Kayla 46444 04/18/2017 0 Q
Carlen, Megan Ann 756444 10/05/2016 0
Carter, Che1yl 330552 08/25/2017 (j ,)
Castillo, Jorge 974432 03/J.3/2018 0 0

HAMES JR, LOUIS P 259668 07/01/2009 0 0
Chrlstensen, Allee C ~41000 Ol./:l9/20.1.7 (j 0
Chung, Cllrlstopher Joseph ll76402 03/13/2018 0 0
Clark, Llsa Marla 944636 03/09/2017 () '.l
Clark, Samantha ll52931 07/11/2017 0 Q
Collins, Jennifer Marie 951801 06/14/2017 () ()
Cucolo, Shelby 036778 12/05/2016 0 0

, Dagley, Mlkai!a Nicole '49560 ~5/11/2017 0 Q
Davidson, Joseph Burton ~80570 04/09/2015 0 Q

Deleon, Meshell S57627 08/23/2017 0 0
Druxman 1 Kenda Lynn ~86044 p4;2212015 0 0
Duenas, Cecilla 955259 07/26/2017 0 0
, Eastlick, Aaron R. ll12244 03/02/2016 0 ;)
Ehrlich, Kelsey 967007 ll/09/2017 0 0

Eide, Kimberly 991070 09/10/2018 0 '.)
: El Ouaal, Soukalna 985975 07/03/201.8 0 0
Ellsworth, Kristopher King 991256 09/10/2018 Kl D
WA State OIC 85
Fenter, Amanda 839756 09/06/2013 0 0
http://iuisimbacore!Protected/MNT/LicenseDetails.aspx?SelectedLicenseeType=B&Entity... 912712018
Simba: Printer Friendly Version Page 2 of 3
Flnnev. Geoffrev Walter 986530 07/12/2018 0 I

Fltzgerald, Jeanine Lynn 85778 07/03/2018 0 0
Flaherty, Jense Michael 390859 06/29/2015 0 D
French, Tara Lynn ~5012J. ~5/25/2017 0 '.I
Fry, Jacqueline ~J.0972 01/28/2016 0 )
Gallagher, Jolin Ross 52118 06/27/2017 0 D

Gehrig, Jessica Leigh 93838 09/l.3/2018 () 0
Gibson, Kreana Marie 69223 12/05/2017 0 ()
Goldsteln, Kathleen Ellen 51508 36/08/2017 () '.)
GOURLEY, PAUL 66530 1.2/11/2017 0

raham 1 Camille 71952 02/16/2018 0 )
reer, Harin K 920240 08/09/201.7 0

GRISSOM, TRAVIS JACOB 41015 03/29/2018 (I ))
, Gritz, Brittany Shay f.)46647 04/18/2017 0 '.J

Gurlan 1 Zerene H 21315 06/09/2016 0 J
Hahn, Holly 900663 l0/07/2015 0 p
HAHN, HOLLY J 205682 06/20/2016 0 0
Hartmann, Jessica Lorraine 985953 07/03/2018 () J
Hayden, Kelly Elizabeth 36772 12/05/2016 0 0
111, Meredith Gedlund 39337 12/22/2016 () D
Hiser, Bethany Dawn 86282 07/06/2018 0 0
Howard, Joshua Len 26184 09/21/2017 I) J
hubbard 1 shannon 938650 12/15/20!.6 0 0
Hunt, Amber M 46644 04/18/2017 (I ))
Hunt, Jodi Samantha 62890 10/04/2017 0 0

Hunt, Sheborne Marie ~27584 08/26/2016 0
Hurlbert, Alyssa Joyce ~61932 10/04/2017 0 0
Hurley, Markesa Jeanne 924511 07/25/2016 0 0
HURLEY, MICHAEL SEAN 754129 07/11/2017 0 0
annetto, Krista Ann l75393 03/13/2018 () Q
ones, Latonya Patrice 050269 05/25/2017 0 ))
Kelleher, J Daniel 952831 06/27/2017 0 0

Kennedy; Nikki 62875 10/04/2017 0 b
Kenny, Brendan James 53220 35/31/2016 0 )
King, Shantel R 98587 01/11/2016 0 0

Krider, Rhonda Lynn ~61706 1.0/04/2017 () '_)
Krogstadt, Megan Allee 70136 12/16/2017 0 0

KUNDE, MELANIE RITH ~78063 04/05/2018 0 ')
Larkin, Matthew 947160 p4;1s12017 0 D

Lash, Stephanie 901409 10/12/2015 0 0
LaVarnway, Amy Catt1erlne 95854 08/21/201.5 () 0
Lawrence-Cabe, Camllle Elizabeth 966698 11/03/2017 0 0
Lee, Erica N 940311 01/10/2017 !) l
Likens, Zachary 991465 09/10/2018 0 .I
'Lopez, Stefani Lynne 911980 02/l.6/2016 (I .I
Machin, Hailey Shay 963573 10/l0/201.7 0 0
Maheu, Kelly Marie 940852 01/19/2017 0
!!Mao, Srellak 948839 05/03/201.7 () 0
: Markham, Jayme Elizabeth 85485 04/09/2015 0 0
. MARKWARDT, KARLA R 78316 04/06/2018 0 ~ ()
· Marn1ol 1 Jenny 938240 12/06/2016 0 Kl

, martlnez, Aleyda 80806 05/16/2018 () 0
McGiii, Demetrice Jamal ~71594 01/12/2018 0
Mesick, David G ~20644 06/09/2016 ll 0
Miiier, Kevin Scott ~48232 05/04/201.7 (J D
'
Monge 1 Jose ~72331 ~2/16/2018 0 D
Mostad~Krelder, Leilani ~63033 10/09/2017 0 :i
'Murphy, Tracy LeAnn ~90070 P8/29/2018 0 Q
WA State OIC 86
Nason, Carmen Maria ~36266 11/17/201.6 (I :l
http ://iuisimbacore/Protected/MNT/Li censeDetails. aspx?SelectedLicenseeType=B&Entity,,. 912712018

Neuman. Kalri ::.47193 04/18/2017 0 ')

Newton 1 Christopher C~1arles 66559 11/03/2017 0 0
Nguyen, An-Ha Angelique '82978 07/12/2018 () ,)
NJday, Blair S87867 08/08/2018 () 0

O'Connell, Lacey 939341 12/22/2016 0 0
Olsen, Lisa Marie 53213 07/ll/2017 0 0
OLSON, KYRA L 224609 07/22/2016 0
Plfferlnl, Angela 85968 7/12/2018 0 0
Powell, Sarah Jennifer S14885 09/17/2018 0 ')
Pugh, Pamel'a Renee S47833 04/21/2017 () )
Purrazzella, Timothy J S6701l 11/09/2017 Q p

Qulllen 1 Kaitlynn 35456 11/1"1/2016 0 J
Rascoe, H Lee S298l1 09/15/2016 0 '.)
Ray, Eric Michael kl94334 09/21/2015 0 :J

Renaut-Relnhardt, Kira Lolita 8'1379 05/17/2018 J J
Renfro, Aubree 972079 03/13/2018 0 D
; Rich, Ollvla 62866 10/04/2017 0 )
'.Rinehart, Stephanie Ann 11136 02/09/2016 0 0

: Rogers, Morgan 994960 09/24/2018 0 j
Roth, Lindsey 73285 02/05/201.8 () )
Sable, Brian Anthony 27548 08/26/2016 0

~Shea, Gregory Bernard 982968 06/21/2018 0 0
Sirois, Kelcie 945742 03/13/2018 l) 0
Smith, Arianna Marie 877101 05/22/2015 0 )
Smith, Carlenn 44684 03/09/2017 0 0

Snow 1 Sterling S71316 1/05/2018 0 ()
Solari, Tabitha Rae 953299 07/11/2017 0 0

'Spear, Brooke Halley 55434 07/26/2017 0 p
Stokes, Kristian Carole tJ49059 05/08/2017 0 0
Strannlgan, Jonathan Scott 977058 03/27/2018 0 (l
Switzer, Stephen =141413 O:l/30/2017 0 0

...rent, Nicolette Renee · ~66699 :Ll/03/2017 0 p
Ullinann, Jakob ~41521 01/30/2017 0 l
un·ER, PATRICK D 159784 P4/2712016 0 b
VANN, NARIN B 708698 P3/27/2018 () 0
Varner, Michael 1958175 08/24/2017 0 :i
Veleta, Chantel 969333 01/09/2018 0 0
:.tersteegh, Alyssa J71591 Jl./12./2018 0 0
Illa, Abtgall 969929 12/16/2017 (I :i
: watts, George Imai 891238 ~6/20/2016 )) 0
Welnrauch, Steve Adam B92223 07/15/2015 0 0
N/ESTMORE, ELIZABETH S 983661 06/21/2018 (j )
'Wilson, Michael Tln1othy 890211 07/23/2015 0 p

"oung, Alicia Lee 932309 10/05/2016 0 r.i
.
Total Active Appointments: 2 Total Non-Active Appointments: O :0 All ®Active
Company Name WAOIC# Eff, Date !Cancel Date Appt, Type Lines Cases Count Orders Count
rnerican Pet Insurance Con1p ... 187058 07/01/2009 RAP 47 2
.l\merlcan Pet Insurance Co1np ... 187058 07/10/2017 MAP 47 2
WA State OIC 87
http://iuisimbacore/Protected/MNTIL icenseD etails ,aspx?SelectedLicenseeType=B&Entity,,, 9/27/2018

Print
ORDERS LIST
Order Class Order# Order Type Owner Division Issue Date Effective Date Order Stayed
'
Disciplinary 13-0204 Consent Order with Fine Legal 04/03/2015 NO
WA State OIC 88

http://iuisimbacore/Protected/MNT/OrdersList.aspx?Hyper=Y&Entityld=20642l&EntityT ... 9/27/2018
Jichurehill, Harvey ()
SEARCH LICENSEE
BE Name/ Last !'rupanicii

Name ® Current 0 Did 0 OBA
First Nan1e Middle Name Old WAOIC #
WAQIC # Licensee Type All $SN I FEIN
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Trupanlon Managers USA, Inc. 718030 XX/XX/XXXX Seattle WA II
SIMBA (Production Web IUI) Release Date: S0ptamber 16, 2018

Copyright© 2.0l.O by Office of the Insurance Cornm!ssloner
WA State OIC 89
http://iuisimbacore/Protected/LIC/LicenseeSearch.aspx 9/27/2018
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LICENSEE PROFILE
Business Entity Information
Name
FEIN Org. Structure
Licensee Information
CIC,/P!C # WAOIC # 718030 Formed Date 01/15/2008
NPN Resident •® Yes 0 No D Dlscp. Block
CRD# Online Registered? Yes
OJ Online Documents
Documents Order Documents
Disciplinary Block
DON# Action Date D Block
Comments
Action By
Doing Business As
I Cancel Date D
D
Mailing Address
Contact Name
Street 1
Street 2
State/ Province v,u1shir:QtOr' Zlp
Phone# 206·007·1 Extension Fax
E-mail
Website
Business Address
WA State OIC 90
Contact Name
http://iuisimbacore/Protected/LIC/LicenseeProfile.aspx?WAOICNo=278550-7 l 8030&mo... 9/2712018

Street 1 $100 4th
Street 2
City
State/ Province Washington Zip 9f.)'!08'-·J234
Phone # Extension Fax 106--2.97··5952
E-mall
Website
Licenses
License Type Lines Effective Date Expiry Date Cancel Date Status
Insurance Producer L1 D, P, C 07/01/2009 01/15/2020 Active
Agent Ol/15/2008 01./15/2010 07/01/2009 Moved to Producer
Branch List
Action Log Show All
, created
Action Comments Created By
On
Trupanlon Managers USA,

01/16/2018 RD - Renewal Processed Date Insurance Producer License renewed on '1/16/201. ..
Inc.
LFE - Licensing rree Form
12/15/2017 Notice for WA Disability Producet~ - Coordinate ... Jeff Baughman
Email
Ll-'E - Licensing Free Farin

12/14/2017 Notice for WA Disability Producers - coordinate.,, Jeff Baughman
Email
Licensee Renewal
11/16/2017 RN - Renewal Notice License Renewal Notice was emailed to louls.cha.,,
Notifications
LFE - Licensing Free Form

03/14/2017 Important Reminder Kathy Marshall·
Ema II
02/17/2017 OT- Other admln action-LA- fine of $25,000 for having uni, .. Janet Sutherland
08/12/2016 OT - Other ad min action-WA fine of $150,000 for untlcensed ... Janet Sutherland
Trupanfon Managers USA 1

07/19/2016 MA - Malling Address Change MLG Address: Street1: from 907 NW Ballard Wayt...
Inc.

07/19/2016 BA - Business Acidness Cl1ange BUS Address: Streetl: from 907 NW Ballard Wayt ...
Inc.
11/24/2015 OT- Other dba ok Janet Sutherland

ll/l8/20l5 RD - Renewal Processed Date Insurance Producer License renewed on 'l.:1./18/20 ...
Inc.
Licensee Renewal
11/16/2015 RN - Renewal Notice License Renewal Notice was emailed to louls@vet ...
Notifications
Trupanlon Managers USA 1

06/ll/2015 BA - Business Address Change BUS Address: City; from SEATTLE to Seattle
Inc.

08/25/2014 Email
Kreidler announces limited special enrollment p ... Kathy Marshall
Licensee's name ch<lnQed from VETINSURANCE

02/04/2014 NC - Name Change Shella Ribble
MANAG ...
Trupanion Manager;, USA,
02/04/2014 RD - Renewal Processed Date Insurance Producer License renewed on '2/4/2014 ...
Inc.
Licensee Renewal
ll/16/20:1.3 RN - Renewal Notice License Renewal Notice was emailed to louls@vet. ..
WA State OIC 91
Notifications

http://iuisimbacore/Protected/LIC/LicenseeProfile.aspx?WAOICNo=2785 50~ 7 l 8030&mo... 9/27/2018
Trupanion Managers USA,

09/06/2013 MA - Malllng Address Change MLG Address: Street:l: from 5245 Shllshole Ave N ...
Inc,
Trupanion Managers USA,
09/06/2013 BA - Business Address Change BUS Address: Street!: from 5245 Shllshole Ave N .. ,
lt)C.

06/12/201.3 New Travel License Requiremerits Kathy Marshall
Email
11/17/2011 RD - Renewal Processed Date Insurance Producer License renewed on '11/1'7/20 ...
Inc,
ll/17/2011 BA - Business Address Change BUS Address: Streett: from 1148 NW Leary way to ...
Inc.
11/17/2011 MA - Malling Address Change MLG Address: ContactName: from Louis Chames to ...
Inc.
11/1.8/2009 RD - Renewal Processed Date Insurance Producer License renewed on '11/18/20 ...
Inc.

' 07 /30/2009 MA - Malling Address Change MLG Address: Streett: from 505 FIFn-J AVES STE ...
Inc.

07/30/2009 BA - Business Address Change BUS Address: ContactName: froni to Louis chames ...
Inc, '
06/30/2009 OT - Other Llcense(s) Moved To Producer: AG. PLMA Migration
01/15/2008 OA - OrlgJnaf Address Original Business Address: sos FIFTH AVE s STE ... Monica Solberg
01/15/2008 OA - Orlglnal Address Orlglnal Malllng Address: SOS FIFTH AVES STE 6 ... Monica Solberg
01/15/2008 ON - Original Name Orlglnal name of the Licensee: VETINSURANCE MAN.,, Monica Solberg
Link Payment
1 - 10 of 81 records
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\/al.# \/al. Date \/al. Amount Dist. Amount Division Payment Mode
1217467 09/24/2018 20.00 20.00 Ucenslng Online Visa/MC
1214682 09/17/20l8 20.00 20.00 Licensing Online Visa/MC
1213063 09/13/2018 20.00 20 00 Licensing Online Visa/MC
1211260 09/10/2018 40.00 40.00 Licensing Online Visa/MC
1206878 08/29/2018 20.00 20.00 ucensfng Online Visa/MC
1188329 07/12/2018 100.00 100.00 ucenslng Online Visa/MC
1186053 07/06/2018 20.00 20.00 Licensing Online vrsa/MC
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WA State OIC 92

http://iuisimbacore/Protected/LIC/LicenseeProfile.aspx?WAOI CNo=2785 50-7 l 8030&mo... 912712018
tjG0Yj-^67i G7/I3/I6 ISDIGJJU.OU
STATE OF WASHINGTON
OFFICE OF THE INSURANCE COMMISSIONER
In The Matter of
Order No. 13-0204
TRUPANION MANAGERS USA, INC. WAOICNo. 718030
DBA, TRUPANION, FEIN No. 38-3756263
Licensee. CONSENT ORDER
LEVYING A FINE
This Consent Order Levying A Fine ("Order") is entered into by the Insurance
Commissioner of the state of Washington ("Insurance Commissioner"), acting pursuant to the
audiority set forth in RCW 48.02.060, RCW 48.17.530 and RCW 48.17.560, and Licensee,
Trupanion Managers USA, Inc. dba Trupanion.
BASIS:
1. Trupanion Managers USA, Inc. is a Washington corporation that holds a resident
insurance producer's license, WAOIC # 718030. Trupanion Managers USA, Inc.'s principal
place of business is in Seattle, Washington. Trupanion is a registered dba of Trupanion
Managers, Inc. (Trupanion).
2. Trupanion is in the business of selling pet insurance and is licensed for the lines
of property and casualty insurance. Pet insurance is categorized as inland marine property
insurance. Trupanion is an appointed producer of American Pet Insurance Company, Inc.,
(APIC), WAOIC # 187058.
3. Between January I , 2012 and June 1, 2013, Trupanion employed at least sixty-
seven (67) individuals, known as "customer care partners" in Trupanion's call center.
Trupanion's customer care partners' job duties entail receiving phone calls ft"om consumers to
answer questions regarding APIC's pet insurance product, and process requests for the purchase.
Consent Order Levying a Fine

WA State OIC 93
Order No. 13-0204 ' Office of ihe Insurance Commissioner

PO Bo.x 40255
LA 1093963 - 1 Olympia, WA 98504-0255
and complete the sale of pel insurance. During this period of time, none of these sixty-seven (67)
customer care partners were licensed by the Insurance Commissioner.
4. Between January I , 2012, and June 1, 2013, Trupanion's unlicensed customer
care partners sold approximately three thousand two hundred and eighty-five (3,285) pet
insurance policies in Washington with a total written premium of $3,315,666.
5. During this period of time, Trupanion also contracted with unlicensed individuals
(called Territory Partners) in Washington to market its products; engaging in the sale,
solicitation, and negotiation of insurance.
6. RCW 48.I7.530(1)(1) authorizes the Insurance Commissioner to place on
probation, suspend, revoke, or refiise to issue or renew an insurance producer's license for
knowingly accepting insurance business from a person who is required to be licensed under this
tide and is not so licensed.
7. RCW 48.17.530 and RCW 48.17.560 authorize the Insurance Commissioner to
impose a fine up to S1,000 for each instance of a violation of the insurance laws and rules of the
state of Washington.
8. By knowingly accepting insurance businessfi-omunlicensed employees who were
required to be licensed under RCW Tide 48 and are not so licensed, Trupanion violated
RCW 48.17.530( I )(l). justifying the imposition of a fine.
CONSENT TO ORDER:
The Insurance Commissioner of the state of Washington and Trupanion agree that the
best interest of the public will be served by entering into this Order. NOW, THEREFORE,
Trupanion consents to the following in consideration of its desire to resolve this matter without
fiirther administrative or judicial proceedings. The Insurance Commissioner consents to settle
this matter in consideration of Trupanion's payment of a fine, and upon such terms and
conditions as are set forth below:
I. Trupanion acknowledges its duty to comply fiilly with the applicable laws of the
state of Washington.
Consent Order Lc\'ying a Fine

WA State OIC 94
Order No. 13-0204 Office of the Insurance Commissioner

PO Bo.x 40255
LA 1093963 - 1 Olympia, WA 98504-0255
2. Trupanion consents to the entry of this Order, waives any and all hearing or
other proceduralrights,and fiirther administranve or judicial challenges to this Order.
3. By agreement of the parties, the Insurance Commissioner will impose a fine of
5150,000 (One Hundred Fifty Thousand Dollars). Thisfineshall be fiilly paid by July 15, 2016.
4. Trupanion understands and agrees that any ftiture failure to comply with insurance
statutes and regularions constitutes grounds for fiirther penalties, which may be imposed in direct
response tofiirtherviolations.
5. This Order and the violations set forth herein constitute admissible evidence that
may be considered in any ftiture action by the Insurance Commissioner involving the Trupanion.
However, the facts of this Order, and any provision, finding or conclusion contained herein does
not, and is not intended to, determine any factual or legal issue or have any preclusive or
collateral estoppel effects in any lawsuit by any party other than the Insurance Commissioner.
EXECUTED diis 1^^^ day of Jcl/w . 2016.
TRUPANION MANAGERS USA, INC. DBA TRUPANION
By:^
Printed Name: Loî3 Cli^êj-, Tr.
Consent Order Le\'ying a Fine

WA State OIC 95
Order No. 13-0204 ^ Office of the Insurance Commissioner

PO Bo.x 40255
LA 1093963 - I Olympia, WA 98504-0255
AGREED ORDER
Pursuant to die foregoing Basis and Consent to Order, die hisurance Commissioner hereby Orders
as follows:
1. Trupanion shall pay a fine of 5150,000 (One Hundred Fifty Thousand Dollars) by
July 15, 2016, receipt of which is hereby acknowledged by the Insurance Commissioner.
2. This Order and die violations set forth herein constitute admissible evidence that
may be considered in any ftiture action by the Insurance Commissioner involving the Licensee,
Trupanion. However, die facts of this Order, and any provision, finding or conclusion contained
herein does not, and is not intended to, determine any factual or legal issue or have any preclusive or
collateral estoppels effects in any lawsuit by any party other than the Insurance Commissioner.
ENTERED at Tumwater, Washington this "ZJjy^ day of ,2016.
MIKE ICREIDLER
Insurance Commissioner
'EEKS
Consent Order Lev-ying a Fine

WA State OIC 96
Order No. 13-0204 Office of the Insurance Commissioner

PO Box 40255
LA 1093963-1 Olympia. WA 98504-0255
_Simba: Printer Friendly_ Version Page I of!
8 Churchill, Harvey { )
WAOIC I/:
licensee Details
Name Facer, David J, WAOIC # 756281 CIC/ PIC #

DBA Name
Online Documents
Documents
Mailing Address
21001 N. Perry Road

Colbert WA, 99005
Tel:S09-435-3211
Fax:
em al I :dav ldfacer@comcast.net
icense Type Lines Effective Date Expiry Date ancel Date Formed Date
nsurance Producer L, D, P, C 12/30/2009 09/11/2019 12/30/2009
Cases by Division
• Total Cases count dlsplays the nurnber of unique cases closed for that year.
• The division counts display the numlJer of closed cases asslgnf'..d to th·at division. If t!ie case was assigned to multiple
divisions, the case will be Included In each of the division counts.
Orders Division
• Count against the yellrs in the Orders Dlvlslon Is the count for the Orders Issued.
• Total till Date In the Orders Division ·rs the Count for the total Orders.
SIMBA (Production Web IUI) Release Date: September 16, 2018

Copyright@ 2010 by Office of the Insurance Commissioner
WA State OIC 97
http://iuisimbacore/Protected/MNT/LicenseeMasterEnquiry .aspx?mode=M&IsFind=Y&... 10/29/2018

SiITlba: Printer Frit)ndly:Vet'sion . -Page l of-1
Print
Total Active Lines: 4 Total Non-Active Lines: O OA!I ®Active
License Lines Status !Approval Date Cancel Date

Casualty Active 06/29/2012
Disability Active 12/30/2009
Total Active Affiliations: 0 Total Non-Active Affiliations: 0 0 All ®Active
Total Active Appointments: 10 Total Non-Active Appointments: 14 0 All (<!)Active
~ompany Name WAOIC # Eff, Date !Cancel Date ,O.ppt. Type Lines ~ases Count Orders Count
l'\LLIANZ LIFE INSURANCE COMP ... 961 03/24/2016 RAP 132 14
16.MERICAN GENERAL LIFE INSUR ... 81 05/29/2016 RAP 1163 1
/\MERICAN NATIONAL INSURANCE ... 110 07/31/2015 RAP 257 5
i<IMERICO FINANCIAL LIFE AND ... 282 11/13/2017 RAP 30 0
\\THENE ANNUITY AND LIFE COM ... 239 10/lB/2018 RAP 177 4
'EQUITRUST LIFE INSURANCE CO ... 342 08/08/2018 RAP ~1 ~
FIDELITY & GUARANTY LIFE IN ... 445 07/30/2018 RAP ~7 6
f;UGGENHEIM LIFE AND ANNUITY ... 500655 09/26/2016 AP p 0
MINNESOTA LIFE INSURANCE CO ... 840 04/11/2016 AP 211 4
NORTH AMERICAN COMPANY FOR ... 959 03/16/2015 RAP k;O ()
WA State OIC 98
http://iuisimbacore/Protected/MNT/LicenseDetails.aspx?SelectedLicenseeType=!&Entity... I 0/29/2018
Simba: Printer Friendly Version Page I of .I
it) Churchill, Harvoy ()

WAOIC ·It
Licensee Details
Name Hahn, Holly WAOIC# 900663 CIC/ PIC :tt

OBA Name
la Documents
~ Onllne Documents
Mailing Address
Business Address
1445 293RD Ave NE
907 NW Ballard way
Carnation WA, 98014
Seattle WA, 98107
Tel:360-348-1551
Tel:877.. 589 .. 1B62
Fax:
Fax:
em al I: Ho llY. ha hn@tn1pa11 Ion, com
email:
lcense Type ines Effective Date Expiry Date Cancel Date Formed Date tatus
nsurance Producer I C 09/29/2015 7/03/2019 09/29/2015 ctive
cas¢s by Division
• The division counts display the number of closed cases assigned to that cllvlsion. If the case was assigned to multiple
divisions, the case will be included In each of the divlslo·n counts.
• Total till Date is the count for both Closed and the Open cases.
Orders Division
• count against the years in the Orders Division Is the count for the Orders Issued.
• Total till Date In the Orders Division is the Count for the total Orders.
SIMBA {Produetlon Web IUI) Release Oate: September 16, 2018

Copyright¢) 2010 by Office of the Insurance Commissioner
WA State OIC 99

http://iuisimbacore/Protected/MNT/LicenseeMasterEnquiry.aspx?mode=M&IsFind= Y&... 10/29/2018
_Simba: Printer Friendly Version _ Pagel of l _
Print
Total Active Lines: 2 Total Non~Actlve Lines: 0 0 All ®Active
License Lines Status Approval Date !cancel Date

.
Total Active Affiliations: 1 Total Non~Actlve Afflllatlons: o 0 All ® Active
Licensee WAOIC# Eff. Date Cancel Date Lines Cases Count Orders Count
h-rupanlon Managers USA, Inc. 718030 10/07/2015 2 1
Total Active Appointments: O Total Non~Actlve Appointments: O 0All ®Active
WA State OIC 100
http://iuisimbacore/Protected/MNT/LicenseDetails.aspx?SelectedLicenseeType=I&Entity... l 0/29/2018
Simba: Printer Friendly Version Page 1 of I
8 ChurchHI, Harv~y ()
WAOIC #
Licensee Detail$
Name Flaherty, Jense Michael WAOIC # 890859 CIC/ PIC #

OBA N<1me
@1 Onllne Documents
Documents

3817 Corliss Ave. N 3817 Corliss Ave. N
Seattle WA, 98103 Seattle WA, 98103
Tel:425-478-1973 Tel:425-478-1973
Fax: Fax:
ema 11 :jensefla herty@g ma II. com emall:jenseflaherty@gmall.com
lcense Type Ines Effective Date Cancel Date Formed Date
nsurance Producer c 06/22/2015 06/22/2015
Additional Licen:See Xnfo1·mation Profile
Cases by Division
• The division counts display the number of closed cases assigned to that tllvlslon. If the case was assigned to multiple
divisions, the case wlll be lncludecl In each of the division counts.
• Total till Date is the count for both Closed and the Open Cases.
Orders Division
• Total tlll Date in the Orders Division is the Count for the total Orders,
SUJ!BA (Production Web IUI) Release Date: September 16, 2018

Copyright© 2010 by Oftlcc of the Insurance Commissioner
WA State OIC 101
File #1569460 Exhibit #2G Page 1 of 2

http://iuisimbacore/Protected/MNT/LicenseeMasterEnquiry.aspx?mode=M&IsFind= Y&... 10/29/2018
Prlnt
Total Active Lines: 2 Total Non-Active Lines: O OAll ®Active
License Lines Status Approval Date !cancel Date

Total Active Affiliations: 1 Total Non-Active Afflllatlons: o 0 All ®Active
, Licensee WAOIC # Eff, Date Cancel Date Lines Cases Count Orders Count
'rupanlon Managers USA, Inc. 718030 06/29/2015 2 1
Total Active Appointments: O Total Non-Active Appointments: O OAll ®Active
WA State OIC 102
File #1569460 Exhibit #2G Page 2 of 2
http ://iuisimbacore/Protected/MNT/LicenseDetails. aspx?SelectedLicenseeType=I&Entity... 10/29/2018

a Church Ill, Harvey ()
802652
WAOIC #
.licensee Details
Name Consumers Advocate Group, LLC WAOIC # 892652 CIC I PIC #

DBAName
~ Onllne Documents
Documents
Malling Address Business Address
18062 Vfklng Way NW 18062. Viking way NW

Poulsbo WA, 98370 Poulsbo WA, 98370
Tel:206-817-3333 Tel:206-817-3333
Fax: Fax:
emal I:fra n@co nsu mersadvocate .org emal I:fra n@consumersadvocete.org
License Type Lines Effective Date ancel Date Formed Date Status
, nsurance Producer L, P, C, TR 07/16/2015 07/16/2015 Active
Additional Licensee Informiition Profile
Cases bv Division
• The division counts display the number of closed cases assigned to that division. If tl1e case was assigned to multiple
Orders Division
• count against the years In the Orders Division is the count for the Orders Issued.
SIMSA {Production Web IUI) Release Date: September 16 1 2018

Copyright@ 2010 by Office of the Insurance Commissioner
WA State OIC 103
File #1569460 Exhibit #2H Page 1 of 2

Print
Total Active Lines:-4 Total Non~Active Lines: 0 0 All ®Active
License Lines Status Approval Date Cancel Date

'trravel Active 01/24/2017
lc:asualty Active 07/16/2015
Total Active Affiliations: 1 Total Non~Active Affiliations: O OAll ®·Active
i..lcensee "1tAOIC # Eff. Date Cancel Date in es Cases Count Orders Count
, Powel, Francine Hay ~89919 07/16/2015 'I 0
Total Active Appointments: 5 Total Non~Active Appointments: O OAll ®Active
!Company Name WAOIC # Eff, Date Cancel Date Appt. Type Lines Cases Count Orders Count
~MERICAN MODERN HOME !NSURA ... 100 09/11/20,18 RAP 205 3

An1erlcan Pet Insurance Comp ... 187058 03/30/2016 RAP ~B ~
.
BERKSHIRE HATHAWAY SPECIALT... 1266 OS/23/2018 RAP 23 ~
MARKEL AMERICAN INSURANCE C ... l05958 01/30/2018 RAP 33 1
TRANSAMERICA CASUALTY INSUR ... 682 02/17/2017 RAP f.>2 ~
WA State OIC 104
File #1569460 Exhibit #2H Page 2 of 2

http ://i uisimbacore/Protected/MNT/LicenseDetails.aspx?SelectedLicenseeType=B&Entit... 10/29/2018
In Re the Matter of:
OIC Case#: 1569460
Rosalie Milburn DECLARATION OF:

JEFF BAUGHMAN
I, Jeff Baughman, am over the age of eighteen. I make the following declaration based
on first-hand, personal knowledge and I am competent to testify to the facts set forth
herein:
1. I am the Producer Licensing & Oversight Manager for the State of Washington's Office of
the Insurance Commissioner.
2. As part of my official duties, I am able to search the official licensing records of the State of
Washington's Office of the Insurance Commissioner, and certify if an individual and/or business
entity possesses a State of Washington issued license to transact the business of insurance in the
State of Washington.
3. I have conducted a diligent search of the State of Washington's Office ofinsurance

Commissioner's official licensing records and have found no record of: Rosalie Milburn, 23010
SE 5gth St, Issaquah, WS, 98029 possessing a license to act as an insurance producer and to
transact the business of insurance in the State of Washington as ofNovember 3, 2010.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF WASHINGTON

STATE THAT THE FOREGOING IS TRUE AND CORRECT.
2cgj_J; day ofNovember, 2018.
:igtlt~rjt';n Declarant
Prinred~~Dc<~ ~~~
WA State OIC 105
File #1569460 Exhibit #2I Page 1 of 3

Jjchurchill, Harv&y ()
WAOIC1/:
Licensee Details
Name MILBURN, ROSALIE L WAOIC # 128731 CIC I PIC # MILBURL598QB

DBAName
Online Documents
Documents
Malling Address
Business Address
23010 SE 58TH ST
23010 SE SSTH ST
ISSAQUAH WA, 98029
ISSAQUAH WA, 98029
Tel:425~677-7723
Tel:425-677-7723
Fax:
Fax:
ema II: leem ii bu rn@comcast, net
email: leemilburn@comcast.net
, ~lcense Type Lines Effective Date Expiry Date Cancel Date Formed Date !Status
nsurance Producer 07/01/2009 11/02/2010 11/02/2010 05/28/2009 Expired
gent 02/12/1997 1/02/2002 1/02/2002 5/28/2009 Expired
~- 05/28/2009 11/02/2010 07/01/2009 05/28/2009 Moved to Producer
Additlonal Licensee Information Profile
Cases by Division
divisions, the case will be Included In eacl1 of the division counts.
• Total till Date Is the count For both Closed and the Open Cases .
.Qrders Division
• Total till Date In the Orders Division Js the ~ount for the total Orders.
SlMBA (Production Web IUI) Release Date: September 16, 2018

Copyright@ 2.010 by Office of the Insurance Commissioner
WA State OIC 106

Print
Total Active Lines: O Total Non-Active Lines: 2 ®All 0Active
License Lines Status Approval Date !Cancel Date
Life '"'ancelled 07/01/2009 11/02/2010

Dlsabllfty Cancelled 07/01/2009 11/02/2010
Total Active Affiliations: 0 Total Non-Active Afflllations: O ®All 0Active
Total Active Appointments: 0 Total Non-Active Appointments: 1 ®All 0Active
!Company Name ~AOIC# Eff, Date !Cancel Date ~ppt. Type Lines Cases Count Orders Count
nLONIAL LIFE & ACCIDENT IN ... 289 07/01/2009 ~7/21/2009 RAP 95 ()
WA State OIC 107
http://iuisimbacore!Protected/MNT/L icenseDetails.aspx?SelectedLicenseeType=!&Entity... I 0/29/2018

& Churchill, Harvey ()

WAOIC #
Licensee Details
Name PALUCH, STANLEY FRANCIS WAOIC# 726265 CIC/ PIC #

DOA Name
Online Documents
Documents

6903 S SHELBY RIDGE 6903 S SHELBY RIDGE
SPOKANE WA, 99224 SPOKANE WA, 99224
Tel:509-939-9361 Tel:509-939-936:1.
Fax: Fax:
ema 11 : spalu ch@comcast.net emall:spaluch@comcast.net
11.icense Type Ines Effective Date Expiry Date Cancel Date Formed Date Status
nsurance Producer 7/0l/2009 1 t/01/2015 11/01/?.015 06/06/2008 Expired
'-\gent 6/06/2008 11/0.1/2009 07/01//_0()9 06/06/2008 Moved to Producer
Additional Licensee Information Proflle
Cases bv Division
• Total Cases count dlsplays the number ofunlque cases closed for that year.
Orders Division.
SIMBA (Production Web IOI) Release Date: September 16, 2018

Copyright If) 2010 by Office of the Insurance Commissioner
WA State OIC 108
File #1569460 Exhibit #2J Page 1 of 2
http://iuisimbacore/Protected/MNT/LicenseeMasterEnquiry .aspx?mode=M&IsFind= Y&... 10/29/2018

Print
Total Active Lines: O Total Non-Active Lines: 5 ®All 0Active
License Lines Status Approval Date Cancel Date
Property Cancelled 07/09/2012 11/01/2015

!casualty Cancelled 07/09/2012 11/01/201.5
Jarlable Life & Variable Annuity Cancelled 07/08/2009 11/01/2015
Life cancelled 07/01/2009 11/01/2015
Dlsablllty Cancelled 07/0:1/2009 ll/01/2015
Total Active Afflllatlons: O Total Non-Active Affiliations: 2 @All OcActive
Licensee ~AOIC# Eff. Date Cancel Date Lines Cases Count Orders Count
HealthMarkets Insurance Agency 1 Inc. 748466 03/07/2012 05/24/2012 1 0
.~ONES EDWARD D & CO LP ~0875 07/01/2009 08/28/2010 0 0
Total Active Appointments: O Total Non-Active Appointments: 27 OAll ®Active
WA State OIC 109
File #1569460 Exhibit #2J Page 2 of 2
http ://iuisimbacore/Protected/MNT/LicenseDetails.aspx?SelectedLicenseeType~!&Entity... 10/29/2018

OIC Case#: 1569460
Kristin Wuhrman DECLARATION OF:

JEFF BAUGHMAN
herein:
3. I have conducted a diligent search of the State of Washington's Office oflnsurance

Conunissioner's official licensing records and have found no record of Kristin Wuhrman, 702
98th Ave NE, Bellevue, WA 98004 possessing a license to act as an insurance producer and to
transact the business of insurance in the State of Washington.

is 2t/i day of November 2018.

fDeclarant
) .. f" i'JJ,_,
WA State OIC 110
File #1569460 Exhibit #2K Page 1 of 2

~GhurchUI, Harvey ()
SEARCH LICENSEE
BE Name I Last W;Jhfffi"1'\

Name @ Current 0 'Old 0 DBA
First Name Middle Name Old WAOIC #
WAOIC # Licensee Type -All SSN I FEIN
License Type Status
IThere are no Search Results to display,
SlMBA (Production Web lUI) Release Date: Sunday, November 18, 2018
Copyright @) 2010 by Office of the Insurance Commissioner
WA State OIC 111
File #1569460 Exhibit #2K Page 2 of 2

http ://iuisimbacore/Protected/LI C/LicenseeSearch.aspx 11/29/2018
· OIC Case#: 1569460
Melissa Manwell DECLARATION OF:

JEFF BAUGHMAN
herein:

Commissioner's official licensing records and have found no record of Melissa Manwell, 1227
NE 148111 St, Shoreline, WA 98155 possessing a license to act as an insurance producer and to

WA State OIC 112
File #1569460 Exhibit #2L Page 1 of 2

Simba: Printer Friendly Version Page 1 of 1
8churx:hill, M11r11-0y ()
SEARCH LICENSEE
BE Name/ Last Mai 1w,,n

Name @ Current 0 Old 0 DBA
First Name Middle Name Old WAOlC 11
WAOIC # Licensee Type Ail SSN /FEIN
License Type Al' Status 'J\11
IThere are no Search Results to dlsplay.
SXMBA (Production Web IUI) Release Date: September 16, 2018

Copyright © 2010 by Office of the Insurance Commissioner·
WA State OIC 113
File #1569460 Exhibit #2L Page 2 of 2

OIC Case#: 1569460
Reviews, LLC DECLARATION OF:

JEFF BAUGHMAN
I
herein:
2. As part of my official duties, I am able to search the official licensing rec?rds of the State of
-Washington's-Office-of the Insurance Commissioner;-and-certify-if-an-individual-and/or business - -

Commissioner's official licensing records and have found no record of Reviews, LLC, 1525 4th
Ave., Suite 500, Seattle, WA 98101 possessing a license to act as an insurance producer and to

o/1 dayofDecember,2018.
J~ Zru. J~ 'L")
Printed Name of DeC!af;{£:t
WA State OIC 114
File #1569460 Exhibit #2M Page 1 of 2

djchur<:hlll, Harvoy {)
SEARCH LICENSEE
BE Name/ Last
Narne
U .. C @ Current 0 :01d 0 DBA
First Name Middle Name Old WAOIC #
WAOIC # Licensee Type All SSN I FEIN
License Type Al: Status All
·Show Advanced Search
There are no Search Results to display,
SIMBA {Production Web IUI) Release Date: Sunday, November 18, 2018
Copyright @ 2010 by Office of the Insurance Comm!ssloner
WA State OIC 115
File #1569460 Exhibit #2M Page 2 of 2
June 12, 2018
Trupanion Managers USA, Inc. /

American Pet Insurance Company
6100 4th Ave S
Seattle, WA 98108-3234
Re: OIC Case # 1569460
Dear Trupanion Managers USA / American Pet Insurance Company,
This letter is to advise you that the Washington State Office of the Insurance Commissioner (WA
OIC) has concerns that your company is continuing activities that were found to be violations of
the Revised Code of Washington and/or the Washington Administrative Code, during a 2015
Market Conduct Examination. It appears your company is continuing to pay commission to the
Seattle Humane Society based on activation of a promotional policy certificate presented to the
consumer by the Humane Society. Further, it appears your company is providing rewards to
veterinarians and/or their employees based on how many policy certificate activations are
presented by the vets. This is a possible violation of RCW 48.17.490(1), RCW 48.30.133(2) and
RCW 48.30.150(1)(c).
I have been assigned to investigate this matter. As part of this investigative process, I am
requesting that you provide this office with a written response to the allegation. Specifically,
please address the following issues:
1. Do/did you provide a donation (commission) to The Seattle Humane Society (SHS) each
time someone signed up for the Trupanion program using a link on SHS website which
forwarded an individual to the Trupanion website?
2. Do you offer trips and gift cards to Washington State veterinarians and/or their employee
via a rewards program?
3. If you do offer rewards, please explain how the rewards program works.
4. If you do offer rewards, is any part of it based on a Trupanion certificate activation?
5. Do you provide Washington State members of your Affiliate Partnership Program (APP)
with money or compensation for providing “qualified leads” that originate from “unique
tracking links, banners, and infographics” you provided them?
6. If you do offer money or compensation to APP member for “qualified leads”, please
explain how that works.
WA State OIC 116
File #1569460 Exhibit #3 Page 1 of 2

Also, please provide the following:
1. If you provided donations (commissions) to SHS, please provide a monthly breakdown of

the donations (commissions) from January 2015 to present.
2. If you offered a rewards program please provide a list of Washington State veterinarians
and their employees that received a reward(s) and the value of the reward per entity for
each month from January 2015 to present.
3. If you provided money and/or compensation to your Washington State APP members,
please provide a list of members and how much money/compensation was provided to
each one monthly from January 2015 to present.
Please provide your written response to our office by July 3, 2018. Also, please be aware that
RCW 48.17.475 requires that licensees promptly reply in writing to an inquiry of the commissioner
relative to the business of insurance within fifteen (15) business days from the receipt of the
inquiry. Failure to make a timely response constitutes a violation of this section.
I appreciate your cooperation in this matter. I may be reached directly at (360) 725-7231 or
christiand@oic.wa.gov for further information.
Sincerely,
Christian J. Dixson
Senior Investigator
Regulatory Investigations Unit
Washington State Office of the Insurance Commissioner
File
WA State OIC 117

State of Washington
Office of Insurance Commissioner
Interview of Melody Stone

OIC Case Number 1569460
Interview Date 12/5/2018
Interviewee Contact Melody Stone
Information 13212 SE Eastgate Way
Bellevue, WA 98005
Work: 425-649-7563 (Preferred)
Email: melody@seattlehumane.org
Investigator Conducting Harvey Churchill
Interview
Others Present N/A
Location of Interview Telephone
Interview Recorded No
Declaration Prepared No
On the above date, INV. Churchill contacted Melody Stone, Adoption Manager for the Seattle Humane
Society.
Ms. Stone confirmed that Trupanion no longer makes donations to SHS based on sales of insurance.
Trupanion has provided quarterly donations. She was aware that the sales reference to Trupanion on the
website was supposed to have been removed a number of years ago. She was unaware until being
informed recently by Trupanion. She believes the site has been updated and no longer makes the
reference.
WA State OIC 118
Page 1 of 1
American Pct Insurance Company
July 3, 2018 Via Electronic Delivery christiand@oic.wa.gov
Christian J. Dixson
Senior Investigator
5000 Capitol Blvd.
Tumwater, WA 98501
RE: American Pet Insurance Company ("APIC") (NAIC #12190); Case# 1569460
Dear Mr. Dixson:
This letter responds to your June 12, 2018 request for information regarding the above-referenced Case
Number. For your convenience I have responded to each of the questions in the order raised in your
letter.
1. No. APIC ended its program to make donations per enrollment as part of its 2015
discussions with the WA OIC that led to the Consent Order with the Company. The last
payment to the SHS based on someone signing up for the Trupanion program using a link on
the SHS website was July 2015. To our knowledge, at that time the SHS's website reference
to the donation program was removed. When we received your letter we looked at the SHS
website and noticed an apparent link to sign up for the Trupanion program on their website.
The link did not in fact lead to a sign-up page; it led to a page referencing someone who had
previously signed up with the Trupanion program. The Adoptions Program Manager at the
SHS was surprised at this link as her belief was that any reference to the program was
removed from the SHS website in 2015. In any event, SHS has removed the incorrect
purported link. Most importantly, no payments were made under this program since we
agreed with the OIC to end them .
2-3 . Yes. Trupanion does offer a Rewards Program that includes Washington State veterinarian
clinics. The Rewards Program is premised on usage of Trupanion Express, our patented
software application that can integrate with a compatible veterinary Practice Management
System (PMS). The primary benefit of Trupanion Express is its ability to facilitate claims
payments directly to the hospital at the time the customer is checking out. This avoids the
customer fronting the funds that in a traditional reimbursement model would later be
reimbursed - which can be the difference between a pet receiving a recommended
treatment or not. Examples of how hospitals can earn points include setting up direct
deposit for the hospital to receive claims payments, submitting paid claims through
Trupanion Express, and fulfilling an initial records request for a new pet to enable the real-
time processing of claim when the pet later visits the hospital. There is no cost to the
WA State OIC 119
hospitals to participate, nor is it required as a condition of using Trupanion Express. A

Ame rlc<in Pd lnsurltncc Com pan) July 3, 2018
Page I 2
hospital can redeem rewards using points accumulated . Trips and gift cards are part of the
suite of available rewards.
4. No.
5. Yes. There are two Washington entities with whom Trupanion has contracted to provide
compensation for referring "qualified leads", but only one of these has referred any
prospective customers to Trupanion (Reviews.com).
6. Trupanion's Affiliate program is a standard program that pays compensation based on a

partner referring a prospective customer who completes the information necessary to
enroll. Trupanion pays the referral fee regardless of whether or not the prospective
customer enrolls. Amounts paid per lead can vary, but $35 is a common amount.
In addition, please see below responses to your further requests for information.
1. Please see attached as Exhibit A a breakdown of donations to the SHS. (You will note the
non-round numbers end in July 2015 when we ended the practice of making donations
based on a per-enrollment amount).
2. Please see attached as Exhibit B a document showing the rewards points accrued by each
participating Washington State hospital since June 2017. Each point is worth ten cents.
Please note that the program began in November 2016 but we began tracking the points
accrued in this way in June 2017. We are working to compile the data for the period
November 2016 through May 2017 and will provide that supplemental information shortly .
WA State OIC 120
6100 4th Ave S

Seattle, WA 98108
AmericanPetlnsurance.com
File #1569460
877.589.1841
Exhibit #5A Page 2 of 7
American Pet Insurance Company July 3, 2018
Page I 3
3. Reviews.com is the lone Washington State Affiliate Program participant to whom we have
paid referral fees. Attached as Exhibit C is a list of all the payments made to Reviews.com
(at $35 per referral).
Please let me know if you have any additional questions.
Sincerely,
Gavin Friedman
General Counsel & SVP, Regulatory
gavin.friedman@trupanion.com
(206) 607-1924
WA State OIC 121
6100 4th Ave S

Seattle, WA 98108
AmericanPetlnsurance.com
File #1569460
877.589.1841
Exhibit #5A Page 3 of 7
Seattle Humane Society Donations EXHIBIT A
Date Amount
1/30/2015 $1,208
5/27/2015 $3,672
6/22/2015 $728
7/20/2015 $804
11/11/2015 $3,500
3/9/2016 $3,500
5/5/2016 $3,000
8/16/2016 $3,000
11/16/2016 $3,000
3/20/2017 $1,500
4/11/2017 $3,000
7/25/2017 $3,000
10/17/2017 $3,000
1/10/2018 $3,000
4/1/2018 $3,000
WA State OIC 122

Summary of Reward Points for WA hospitals Exhibit B
Hose Ital Jun-17 Jul -17 Aug-1 7 see- 11 Od- 17 Nov-17 Dec-17 Jan-18 Feb-18 Mar-18 Aer-18 Ma~· 18
Anima l Hospilol Of Focloria 102 70 90 60 70
Lake Union Veterinary Clinic - 170
Duvall Veterinary Hospital 20 225
Bellevue Animal Hospital
Northshore Veterinary Hospital
Afford-A-Vet Animal Clinic
Reber Ranch Veterinary Clinic . . . . 20
Eastside Veterinary Associates - Newcastle I Renton
Fair Isle Animal Clinic
Hawthorne Hills Veterinary Hospital - . - 141 70
Lien Animal Clinic 340 223 166 900 150 183 112 165 126 240
Arlington Veterinary Hospital
VCA Pacific Avenue Animal Hospital
Animal Care Center
Cascade Pet Hospital 41 7 50
VCA West Seattle Veterinary Hospital
Marine View Veterinary Hospital - . 57 49 105 125
Broadway Animal Hospital . - 43 95
Dupont Veterinary Center 416 665 485 170
Diamond Veterinary Associates 20
Frontier Village Veterinary Clinic
Family Pet Medical & Surgery 20 10
Kulshan Veterinary Hospital
Northwest Veterinary Clinic
Jet City Animal Clinic 158 89 327 108 160 32 41 132 170
Lynden Vet Hospital l 30 21 50
VCA Five Corners Animal Hospital
Latah Creek Animal Hospital 150 155 25 177 200 575 206 480 891 601 11 5
Maplewood Animal Hospital
Northwest Veterinary Clinic Of Stanwood
Millwood Animal Clinic
Shoreline Veterinary Hospital
Burien Veterinary Hospital - - . 30 165
Mountain View Veterinary Hospital 100 250 50 50 225 135 104 80 131 70 235
Poulsbo Animal Clinic - 21 85
Oceanside Animal Clinic
Ferndale Veterinary Hospital 10 5
Salish Veterinary Hospital 203 200
Cascade Park Animal Hospital
Everett Veterinary Hospital
East Padden Animal Hospital 695 700 755 248 256 950 244 232 247 326 352 310
Eastside Veterinary Associates
Fidalgo Animal Medical Center
Cascade Veterinary Center - - 21 21 23 35
WA State OIC 123

Mount Vernon Veterinary Hospital
A.nima l Hospital Of Parkland

Yelm Veterinary Hospital
Parker Way Veterinary Clinic
Salmon Creek Veterinary Clinic 10 5 4 31 75 37 4 21 32 22 35
Lower Columbia Veterinary Clinic 425 25 54 21 94 82 85
WA State OIC 124

WA Affiliate Payments -- Reviews.com Exhibit C
Payment Date Payment Amount

4/8/2017 $35
11/1/2017 $70
12/31/2017 $140
1/31/2018 $35
3/1/2018 $280
4/1/2018 $175
5/1/2018 $245
WA State OIC 125

American Pet Insurance Company
July 10, 2018 Via Electronic Delivery christiand@oic.wa .gov
Christian J. Dixson
Senior Investigator
5000 Capitol Blvd.
Tumwater, WA 98501
Dear Mr. Dixson:
This letter is APIC's supplemental response to your June 12, 2018 request for information regarding the
above-referenced Case Number. It supplements my July 3 response in two ways:
First, with respect to the rewards program points, attached is an updated Exhibit B that now includes
the requested data for the period prior to June 2017.
Second, with respect to APIC's response to Question 5 (regarding referrals for qualified leads), please
note that Trupanion has paid referral fees to two Washington entities for referring qualified leads.
Apart from Reviews.com, Trupanion has also paid referral fees to Consumers Advocate. Consumers
Advocate did not appear as responsive to our initial inquiry because it is based in Puerto Rico, but we
understand it used to be in Washington before it relocated to Puerto Rico in or about December 2016.
Beginning in December 2016 the Company's product has not been included on the organization's United
States website, so any qualified lead referral payments since that time are for Canada only. Attached is
an updated Exhibit C that includes the payments made to Consumers Advocate since 2015 (at $100 per
qualified lead).
Sincerely,
Gavin Friedman
(206) 607-1924
WA State OIC 126

Summary of Reward Points for WA hospitals Exhibit B
Hospital Nov-16 Dec -16 Jan-1 7 Feb- 17 Mar-17 Apr- 17 May-1 7 Jun- 17 Jul-1 7 Aug- 17 Sep-17 Oct-17 Nov- 17 Dec - 17 Jan-18 Feb-1 8 Mar-1 8 Apr-18 May- 18
Animol Hospital Of Foctoria 102 70 90 60 70
Columbia River Veterinary Specialist 5 470 120 175
Orchard Hills Animal Hospital 150
Bellingham Veterinary 100 20 5
Lake Union Veterinary Clinic 170
Duvall Veterinary Hospital 20 225
Bellevue Animal Hospital
Northshore Veterinary Hospital 310 100 100
Afford-A-Vet Animal Clinic
Reber Ranch Veterinary Clinic 20
Eastside Veterinary Associates - Newcastle/ Renton
Fair Isle Animal Clinic
Hawthorne Hills Veterinary Hospital 141 70
Lien Animal Clinic 340 223 166 900 150 183 112 165 126 240
Arlington Veterinary Hospital
VCA Pacific Avenue Animal Hospital
Animal Care Center
Cascade Pet Hospital 41 7 50
VCA West Seattle Veterinary Hospital
Marine View Veterinary Hospital 57 49 105 125
Broadway Animal Hospital 43 95
Dupont Veterinary Center 416 665 485 170
Diamond Veterinary Associates 20
Frontier Village Veterinary Clinic
Family Pet Medical & Surgery 205 215 20 10
Kulshan Veterinary Hospital
Northwest Veterinary Clinic
Jet City Animal Clinic 158 89 327 108 160 32 41 132 170
Lynden Vet Hospital 30 21 50
VCA Five Corners Animal Hospital
Latah Creek Animal Hospital 50 150 5 150 155 25 177 200 575 206 480 891 601 115
Maplewood Animal Hospital
Northwest Veterinary Clinic Of Stanwood
Millwood Animal Clinic
Shoreline Veterinary Hospital
Burien Veterinary Hospital 30 165
Mountain View Veterinary Hospital 100 250 50 50 225 135 104 80 131 70 235
Poulsbo Animal Clinic 21 85
Oceanside Animal Clinic
Ferndale Veterinary Hospital 10 5
Salish Veterinary Hospital 203 200
Cascade Park Animal Hospital
Everett Veterinary Hospital
East Padden Animal Hospital 1240 595 630 695 700 755 248 256 950 244 232 247 326 352 310
Eastside Veterinary Associates
Fidalgo Animal Medical Center
Cascade Veterinary Center 21 21 23 35
WA State OIC 127

Mount Vernon Veterinary Hospital
Animal Hospital Of Parkland
Yelm Veterinary Hospital
Parker Way Veterinary Clinic
Salmon Creek Veterinary Clinic 210 20 10 5 4 31 75 37 4 21 32 22 35
Lower Columbia Veterinary Clinic 425 25 54 21 94 82 85

WA Affiliate Payments -- Reviews.com Exhibit C
Reviews.com
4/8/2017 $35
11/1/2017 $70
12/31/2017 $140
1/31/2018 $35
3/1/2018 $280
4/1/2018 $175
5/1/2018 $245
Consumers Advocate
7/16/2015 $35,760
8/26/2015 $9,850
9/10/2015 $9,360
10/8/2015 $24,420
11/6/2015 $8,760
12/4/2015 $8,880
1/14/2016 $6,180
2/4/2016 $4,920
3/17/2016 $4,860
4/13/2016 $6,060
5/19/2016 $6,960
6/8/2016 $7,200
7/13/2016 $13,495
8/18/2016 $17,525
9/22/2016 $17,135
10/13/2016 $21,845
11/10/2016 $30,045
12/15/2016 $2,940
1/13/2017 $3,120
2/8/2017 $1,935
4/6/2017 $1,020
4/13/2017 $1,320
5/11/2017 $840
6/13/2017 $960
7/13/2017 $900
8/25/2017 $1,380
9/13/2017 $1,080
12/15/2017 $960
1/11/2018 $780
1/18/2018 $1,860
2/8/2018 $1,440
3/9/2018 $960
WA State OIC 128
4/12/2018 $1,260
5/3/2018 $1,200

trYpanion™
October 26, 2018 Via Electronic Delivery - harveyc@oic.wa.gov
Harvey Churchill
Senior Investigator
5000 Capitol Blvd.
Tumwater, WA 98501
Dear Mr. Churchill:
This letter responds to your October 24, 2018 requests for information regarding the above-referenced
Case Number. Following are your questions and our responses:
1. How is the software provided to the various pet/vet hospitals?
For hospitals that elect to use Trupanion Express as part of their customer service experience
to their customers, Trupanion offers the software via a self-install process over the internet.
The software is provided free to these hospitals.
2. At the vet locations, who enters the information for an insurance application?
Trupanion Express does not facilitate applying for insurance. Rather, Trupanion Express's
primary purpose is to integrate with a compatible veterinary Practice Management System
(the software a veterinarian uses to manage customer appointment scheduling, medical
history, customer and pet medical data records, billing etc.) to facilitate the direct payment of a
claim to the hospital (in minutes if Trupanion already has the pet's medical records).
In addition, Trupanion Express can be used to inform Trupanion that a veterinarian has
examined a given pet, which makes the pet eligible for a Trupanion Exam Day Certificate. After
receiving the notification via Trupanion Express, Trupanion emails the pet owner with
information about that Certificate. If a hospital does not use Trupanion Express, the pet owner
may receive the same information about the Certificate in hard copy form at the hospital. To
activate a Certificate (regardless of whether received in hard copy format or by email) the pet
owner either enrolls online or calls Trupanion and talks to a licensed agent. 1 Attached as Exhibit
1
Under the Certificate program, pet owners have 24 hours after the vet exam to activate the Certificate,
regardless of how the activation is done. (This proximity to the exam provides greater comfort about the
medical condition of the pet and is the basis for providing the benefits of the program). Pet owners who
activate a Certificate receive coverage for thirty days without providing payment information up-front. If
WA State OIC 129
61 C0-4th Ave. S., Ste. 200 800.569-7913 201-185 Forester St.

Seattle, WA 98108 TRUPANION.COM N. Vancouver, BC V7H OA6
File #1569460 Exhibit #5Ci Page 1 of 5

trb:Jpanion™
Dis a copy of an email that Trupanion sends to pet owners about the Certificate, along with a
hard copy version of the Certificate.
In sum, nobody at a vet hospital is involved in a policyholder applying for insurance or enrolling
a pet.
3. Who is the producer for the product applied for through Trupanion Express?
Again, there is no product "applied for through Trupanion Express". If a pet owner elects to
enroll a pet on line there is no producer. If a pet owner elects to enroll a pet by telephone, the
producer is the licensed Trupanion employee who takes the call.
4. Who receives a commission and/or benefit for any sale of an insurance product through
Trupanion Express?
To reiterate, no products are sold through Trupanion Express. For enrollments, only the
licensed employee-producer receives a commission (if the enrollment is by phone). 2 Territory
Partners (who are independent contractors) receive an initial payment of $10 when a pet in
their territory enrolls and remains enrolled for a month, and then $2 for each month thereafter
that the pet remains enrolled. These payments are intended to reflect the Territory Partner's
efforts to market the benefits of insuring pets to veterinarians and are made regardless of how
the pet was enrolled. For example, the payments to the Territory Partner are made if a pet
owner enrolls on line and there is no producer involved in the sale.
5. Total# of Trupanion policies sold in Washington and monies collected, 2015 to present.
Total# of Trupanion policies issued from 1/1/5 through 9/30/18: 20,875.
Total premium collected for the same period: $19,156,821.
6. Is there a written agreement between Seattle Humane Society and APIC/Trupanion with
regard to donations? If yes, please provide.
No. Trupanion voluntarily supports the Seattle Humane Society.
they do nothing further the policy cancels after thirty days. If they choose, pet owners can convert their
activated certificate to a regular policy by providing payment information to Trupanion before the end of
the thirty-day period.
2
On average, about half of an employee-producer's total compensation is paid in salary, and the other half is a
commission.
WA State OIC 130
6100-4th Ave. S., Ste. 200 800.569-7913 201-185 Forester St.

File #1569460 Exhibit #5Ci Page 2 of 5

trYpanion™
7. In a review of Trupanion's comparison with Nationwide, Trupanion states that they pay
actual costs (a percentage thereof) according to the veterinarian. Is that statement accurate?
Does that include costs from any veterinary hospital/clinic?
Yes. Trupanion processes claims based on the veterinary expenses as incurred on the actual
veterinary invoice, with no annual or lifetime limits. Pets are covered for treatment at any
veterinary hospital in the United States, Canada and Puerto Rico.
8. Is there any benefit to the consumer for the purchase of the insurance through the Seattle
Humane Society? If so, explain.
No consumer is able to enroll or purchase coverage through the Seattle Humane Society. As
with pet owners whose pets are examined at a veterinary hospital, pet owners who adopt a pet
through the Seattle Humane Society may receive an Exam Day Certificate (in hard copy form)
from the Seattle Humane Society at the time of adoption. The pet owner may then elect to use
the Exam Day Certificate - either online or by calling a licensed Trupanion sales agent.
Consumers that enroll via this path receive no additional benefit, and the Seattle Humane
Society also receives no benefit for any enrollment.
9. What is a qualified lead?
A "qualified lead" is an individual that is referred to Trupanion who completes an application,

without regard to whether the pet owner enrolls with Trupanion or not. (This definition is
standard throughout the pet insurance and other industries).
10. Have any Washington entities received rewards through the program? If so, provide the
reward received and a cost.
Yes. Trupanion introduced the points rewards program on a test basis in Q4 2016 to encourage
the use of Trupanion Express, particularly to submit claims electronically using the software to
facilitate real-time payment of claims to the veterinary hospitals. Since inception, a total of
seven veterinary hospitals in Washington have earned (but not redeemed) points totaling
about $6,650. These hospitals in Washington have redeemed points totaling $1,973 since the
program began. The items redeemed are: Two cookware sets ($321 and $159); two Fitbit
trackers ($181 each); a set of Snapware food storage containers ($53), nine gift cards (either
$50 or $100); a portable speaker ($40); a dog drying towel ($14); headphones ($72); a dog
brush ($25), a dog mat ($50), a dog collar ($22), an air circulator ($80), and a chair ($57).
As you can see from these numbers, relative to our footprint in Washington the program has
generated almost no interest. We are thus discontinuing it. As of November pt 2018, no
hospitals will earn additional points under the program.
WA State OIC 131
6100-4th Ave. S., Ste. 200 800.569-7913 201-185 Forester St.

File #1569460 Exhibit #5Ci 3 Page 3 of 5

trb:1panion™
Further, with respect to your request for documents, please note the following :
1. Attached as Exhibit E is the original brochure we designed for use with the program. Please note
we discontinued this brochure as we iterated the test program, but I am including it to ensure our
response is comprehensive. One of the changes we made to the program in April 2018 was to
focus the points more on the claims related benefits of Trupanion Express, and we removed issuing
Certificates as a category for earning points. 3 We did not replace this brochure; rather, we
provided hospitals with access to an online rewards portal. Attached as Exhibit Fare screenshots of
the welcome screen to the portal, as well as the screen showing hospitals the different ways they
can earn points (until the program ends at the end of this month).
2. Attached are the following:
• Exhibit G: The Marketing Agreement between Trupanion and Reviews.com .
• Exhibit H: The Licensed Broker Marketing Agreement between Trupanion and Consumers
Advocate Group. 4
• Exhibit I: A standard Territory Partner Agreement.
3. Attached as Exhibit J is a report showing payments made to Washington Territory Partners since
2015.
Confidential Treatment Requested

Please note that we have labeled Exhibits G, H, I and J as "Confidential". In addition, please also consider
Exhibits A, Band C, previously provided to Mr. Dixson, as Confidential. These documents contain
Trupanion's confidential trade secret, commercial and/or financial information and disclosure would
substantially harm the competitive position of Trupanion in the marketplace and would negatively impact
the overall health of the pet medical insurance marketplace and ultimately the consumer. The designated
information is held in strict confidence by Trupanion and is not disclosed publicly. It is not known or
otherwise generally available in the public. We request that these documents be treated as confidential
under the RCW 45.56.270, RCW 42.56.070(1) and RCW 19.108 and any comparable exemption that exists
3
Under the prior version of the rewards program, hospitals that gave certificates to customers using
Trupanion Express earned the available points regardless of whether a pet owner ever activated their
Certificate or ultimately chose to continue their policy beyond the Certificate period.
4
In my July 10, 2018 letter to Mr. Dixson, I advertently incorrectly referred to the payments to Consumers
Advocate as based on qualified leads. They were in fact based on enrollm~nts. Please note further that
Consumers Advocate Group is a licensed insurance agency, so no payments were made to an unlicensed
entity.
WA State OIC 132
6100-4th Ave. S., Ste. 200 800.569-7913 201 -185 Forester St.

trYpan·on™
under law, we thus respectfully request that these Exhibits be exempt from disclosure in response to a
public records request . In addition, Trupanion respectfully that the OIC notify Trupanion to the extent it is
contemplating providing any of these designated documents in response to a request with sufficient notice
to enable Trupanion to object to the disclosure.
Sincerely,
Gavin Friedman
(206) 607-1924
WA State OIC 133
6100-4th Ave. S., Ste. 200 800.569-7913 201- 185 Forester St.

WA State OIC 134
File #1569460 Exhibit #5Cii Page 1 of 4

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Exhibit J: Washington Territory Partner Payments
Entity Name (if applicable) Territory Partner 2015 2016 2017 2018(**)
Bluegrass Mgmt Consulting Facer, David 946.00 828.00 738.00 524.00
File #1569460
Cadi Inc Hahn, Holly 74,306.00 120,230.00 147,282.00 157,295.00
Stanley Paluch Paluch, Stanley 168,162.00 1,276.00 1,088.00 722.00
R. Lee Milburn Milburn, R. Lee 48,448.00 43,734.00 38,132.00 28,616.00
People for Paws, LLC Manwell, Melissa 534.00 3,746.00 4,957.00
People Who Love Pets, LLC Flaherty, Jense 1,612.00 206,044.00 218,454.00 208,249.00
Kristin Wuhrman Wuhrman, Kristin 3,800.00 3,284.00 2,888.00 2,192.00
mPaw, LLC (*) Markham, David 79,300.00 106,924.00 138,844.00 127,686.29
Total 376,574.00 482,854.00 551,172.00 530,241.29
C
(*) mPaw, LLC (David Markam) territory is primarily based in Oregon, with a small amount of
O
overlap into Washington. Therefore a majority of this payment was for the Oregon territory.
(**) This covers payments 1/1/18 through 10/7/18.

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WA State OIC 193
SPOTLIGHT ON:
What the veterinary profession

should know regarding insurance
licensing requirements
Executive Summary
It’s important that veterinarians and their teams have confidence in what they
can and cannot do when it comes to discussing insurance to their clients.
It’s fine to:

• Ask every pet owner who their medical insurance provider is at check-in
• Make a recommendation to call provider(s) with any specific questions
• S hare personal experiences related to the speed of claims, the ease of claims
submission or the customer service
• Issue Exam Day Offers or display brochures, so long as there is no solicitation,
negotiation or selling.
As the category of medical insurance for cats and dogs accelerates its growth in the United
States, we at Trupanion have been receiving questions from veterinarians and their staff about
insurance licensing regulations.
Our decision to be transparent is deliberate. We are committed to our work within the
veterinary industry, and it is our intention to provide support and transparency to allow
veterinarians and their staff to speak with confidence when talking about insurance, as well as
remedy any misinformation on the subject.
Before we dive into the questions, we thought it would be helpful to you to explain the
regulations so you and your teams can be informed and educated with the facts.
WA State OIC 194

What veterinarians and their staff may do:
sk clients at check-in: “Who provides the medical insurance for your pet?” This
1. A
simple question drives increased treatment compliance and acceptance for medical
insurance for pets. In fact this is what happened in the dental industry to generate
compliance of care. If a client already has insurance, you may help them with their
claims process.
2. R
ecommend the concept of medical insurance if you believe it is in your clients’ best
interests. Veterinarians and their staff are among the most trusted professionals, and
responsible pet owners will continue to ask your opinion about how a pet owner should
best budget for their pet becoming sick or injured.
3. Inform clients that there are many insurance options in the marketplace.
4. S uggest that your clients should ask for information from the different companies
that provide medical insurance for pets to ensure pet owners obtain all pertinent
information to make an informed decision. For example:
a. What is covered and what is not, including congenital or hereditary conditions?
b. How does the claims process work, including whether claims are reimbursed
to the pet owner after paying out-of-pocket, or paid to the veterinary hospital
directly?
Respond to questions about a given company with facts based on your personal experiences
related to service or customer care. Good examples could be to reference a fast claims
experience or 24/7 customer care.
Applying the regulations in practice
There are many ways that a hospital team can integrate the care of insured pets into their
workflow. Staying familiar with the basic rules and regulations of what you should not do will
increase the confidence of the team as they become increasingly familiar with treating an
insured client base.
It’s important to recognize that medical insurance for pets is regulated by each individual
state, but as a general matter the concepts related to the do’s and don’ts of insurance apply
across-the-board. WA State OIC 195

At the highest level, veterinarians and their staff may not:
Sell, solicit, or negotiate insurance unless they are a licensed insurance producer in their State.
What does this mean in practice?
Using New York as an example, the New York Insurance Code Section 2012 (a)(1)(A) provides
the following definition:
“No person, firm, association or corporation shall act as an insurance producer,
insurance adjuster or life settlement broker in this state without having authority
to do so by virtue of a license issued and in force pursuant to the provisions of this
chapter.”
The key point to focus on here is what it means to be an “insurance producer”? New York
defines an insurance producer in Section 2101(k) as:
“An insurance agent, title insurance agent, insurance broker, reinsurance
intermediary, excess lines broker, or any other person required to be licensed under
the laws of this state to sell, solicit or negotiate insurance.”
The areas underlined below are where there are common misinterpretations of insurance
code — which is why regulators define these specific activities too:
Sell
The New York Insurance Code Section 2101(n) defines “sell” as :
“Exchange a contract of insurance for money on behalf of an insurer.”
One can conclude from this rule that veterinarians or their staff, who are not licensed, may not
receive premiums from a pet owner to pay for insurance.
Solicitation
New York Section 2101(o) defines a “solicitation” as:
“Attempting to sell insurance or asking or urging a person to apply for a particular
kind of insurance from a particular licensed insurer, fraternal benefit society or
health maintenance organization.”
Therefore, veterinarians or their staff, who are not licensed, may not directly ask or urge a pet
owner to apply for a particular kind of insurance from a particular licensed insurer. Trupanion
has licensed representatives available 24/7 to speak with pet owners about enrolling for
coverage. Veterinarians should advise their clients on responsible pet ownership, including
the value of high quality medical insurance. Veterinarians also may recommend that pet
owners speak to one or more providers for additional information, if they do not already have
coverage.
Negotiate
New York’s definition of negotiate: Section 2101(m) is:
“Conferring directly or offering advice directly to a prospective purchaser regarding
any of the substantive terms and conditions of the contract.”
Therefore, veterinarians or their staff, who are not licensed, may not go into specific product
and policy details about the coverage of any specific company.
WA State OIC 196

To help apply some context and clearly demonstrate how these rules can be interpreted,
below are some of the more frequently asked questions and Trupanion’s responses: 1
• Can I discuss the general benefits of insurance?

Yes. Insured pet owners visit their local veterinarian more frequently and are more
likely to authorize your recommended treatment if they are not paying the entire bill
themselves. We are a long way from insurance becoming the norm (think about going
to your dentist where it is the first question asked), and we view veterinarians as playing
an important role in explaining the benefits of protecting pets against unexpected
accidents or illnesses.
• Can I give my clients an Exam Day Offer?

Yes. Exam Day Offers have been approved by Departments of Insurance. The Exam
Day Offers are often sent directly by Trupanion using Trupanion’s patented software,
which puts the information directly in the hands of the pet owner, or are provided in
hard copy format at a hospital. The Offers provide pet owners with information about
how to contact Trupanion if they want to activate the Offer. As such, they are a great
way to appropriately introduce the concept of medical insurance for a pet, along with
the other information you give owners of puppies and kittens.
• Can I make brochures available to my clients?

Absolutely. A brochure is a way to introduce pet owners to insurance and we
encourage you to put brochures in your waiting room for all programs you and your
teams personally feel good about.
• C
an I talk about specific coverage (for example, Company A covers congenital and
hereditary conditions but Company B does not)?
No, this could be considered “negotiating”. While reiterating your personal experiences
about how you have interacted with a particular company is fine, you should leave
the details of the coverage and explanations of the details to a licensed insurance
professional.
That said, without discussing any particular company’s coverage or restrictions, you
can generally encourage your clients to seek out the insurance that best meets their
needs.
• Can we discuss our experiences related to an individual company’s customer service?

Yes. Letting pet owners know about your experience dealing with a specific
company’s services is different than discussing specific policy terms. It is okay to talk
about your experience with a specific company service, for example talking about an
ability to pay a hospital directly, discussing the call center availability and timeliness of
responses to questions, as long as you do not go into details related to policy coverage.
(As a reminder, a person without a valid producers license should not cover a specific
company’s policy details).
1
Please note that this is our attempt to provide you helpful generalized information. We have drafted this in
conjunction with an outside law firm. While this information might concern legal or regulatory issues, please do
not consider it legal advice.
WA State OIC 197

• Are Trupanion’s Territory Partners licensed?
Being a Territory Partner does not require a license because Territory Partners are not
required to sell, solicit, or negotiate Trupanion directly to pet owners. That said, some
Territory Partners do elect to become licensed so that if they interact directly with
a pet owner about the subject of insurance they can do so without needing to be
concerned about whether a conversation involves a solicitation. Ultimately, for a pet
owner to enroll, they need to either visit a website or speak directly to the insurance
company.
• C
ould an insurance company pay a veterinarian or their staff based on a client
enrolling with that company?
No. Insurance regulations expressly prohibit sharing commissions with someone who is
not a licensed insurance agent.
• C
ould an insurance company pay an unlicensed individual or entity for providing
a lead?
Yes. It is permissible to pay an unlicensed person a modest fee for a lead, provided
there was not any selling, solicitation or negotiating, and so long as the payment was
made for each lead regardless of whether the lead purchased insurance. Examples of
where insurance companies commonly pay for leads include Google, Facebook, TV
and radio.
• Could an insurance company pay a hospital for aiding in a claims submission?

Yes. For example, helping expedite the claims process can be compensated, if services
have been provided by the veterinarian or a hospital employee.
Working with insurance should be simple. We hope this guide helps to overcome
any concerns and answers questions.
Trupanion is a registered trademark owned by Trupanion, Inc. Underwritten in Canada by Omega General Insurance
Company and in the United States by American Pet Insurance Company, 6100-4th Ave S, Seattle, WA 98108. Please visit
WA State OIC 198
AmericanPetInsurance.com to review all available pet health insurance products. HL015-1018

From: Gavin Friedman
To: Churchill, Harvey (OIC)
Subject: Follow up to our meeting of 11/07/18
Date: Tuesday, November 13, 2018 2:31:01 PM
Attachments: image002.png
image003.png
image004.png
Mr. Churchill:
Thank you for the follow-up questions, and thanks again for your and Ms. Osberg’s time last week. Below are responses.

1. Contact information for those Territory Partners I could not identify through licensing info, Kristin Wuhrman and
Melissa Maxwell.
Kristin Wuhrman: Ms. Wuhrman’s contact information is kmotzwuhrman@gmail.com. Her telephone number is (206)
858-0140. Her contract with Trupanion ended on December 31, 2013.
Melissa (MJ) Manwell (spelled “Maxwell in your email): Ms. Manwell’s contact information is
Melissa.manwell@trupanion.com. Her phone number is (206) 919-9659. FYI Ms. Manwell also works in Trupanion’s
marketing department. In July 2016, she bought a relatively small territory in Spokane and hired an employee to call on
veterinary hospitals. Our understanding is that the employee is no longer working for Ms. Manwell and that currently
nobody is calling on hospitals in this territory on behalf of Trupanion.
2. Contact info, representative of Seattle Humane Society

Melody Stone. Her contact information is melody@seattlehumane.org. Her telephone is (425) 649-7563.
3. Information on donations made to other humane societies

In addition to the Seattle Humane Society, Trupanion donates money to four other rescue organization:
1. San Diego Humane Society. We donate $8,000 per year to this organization.
2. Big Dog Ranch Rescue. We donate $2,200 per year to this organization.
3. Northeast Animal Shelter. We donate $8,000 per year to this organization.
4. Humane Society of Tacoma and Pierce County. We donate $7,000 per year to this organization.
As with the Seattle Humane Society, the donations are made voluntarily and are unrelated to any enrollment activity.
Rather, the payments reflect our recognition that their values align 100% with Trupanion’s, i.e. to help pets. Please also
note that our internal accounting system and the check stub that goes to the shelters refer to the payments as “Shelter
Donation Q__”. Please let me know if you would like any further information regarding these organizations, including any
contact information.
In addition, we have a general fund available to shelter organizations to access in the event they would like Trupanion to
sponsor a part of an event they are hosting, typically a small sponsorship at a fundraising event (e.g. tickets or a table).
The total fund is about $48,000 per year and organizations can apply on a one-off basis for any sponsorship. About 75
organizations participate in this program.
4. Clarification for me of what information is shared between the hospital and Trupanion Express from a consumer
who, as the result of the recent examination, is eligible for the 30 day free-look offer.
The process is initiated when a pet has a veterinary exam. After the exam, through Trupanion Express we receive the pet
owner’s contact information, i.e. their name, email address and phone number. The only piece of information we use is
the email address, to electronically send a brochure to the pet owner that their pet is eligible for the Exam Day Offer so
long as they activate it within 24 hours of the exam. We do not call pet owners. We also do not share the information
received. The emails we send comply fully with applicable requirements to include physical address/contact information
and provide an unsubscribe option. As you are aware, the brochure providing information about the Exam Day Offer acts
only as an invitation to further inquire: The pet owner can then call Trupanion and talk to a licensed agent or they can go
online to research and/or activate their Offer.
WA State OIC 199
5. Confirmation that information is entered on the hospital software but may be shared to Trupanion Express by the

operator.
My apologies, but I am not 100% sure I am following this question. Please let me know if my response to Question 4 above
did not provide what you are looking for.
6. You mentioned a legal opinion that an attorney had provided regarding the need to license Territory Partners,
may a copy be available?
The advice was provided by Low & Childers P.C. on March 6, 2008. At that time Low & Childers was our regulatory counsel
and the advice was based on Arizona law. Both Mr. Low and Mr. Childers are former Directors of the Arizona Department
of Insurance. I would be happy to provide a copy, but in an abundance of caution unfortunately need to decline to provide
it because I do not want any third party to contend that our provision of the document waived the attorney-client privilege
in any broader context. I can confirm that the advice was entirely consistent with our discussion regarding the licensing
status of Territory Partners. I would also be happy to discuss this issue further with you, including the general substance of
the advice received.

Please let me know if you have any further questions, or if you would like to discuss anything further by phone or in-
person.

Regards,

Gavin Friedman

GAVIN FRIEDMAN GENERAL COUNSEL & SVP, REGULATORY
T 1.206.607.1924| F 1.888.959.9181
Follow us on Facebook
6100 4th Ave S| Suite 200| Seattle, WA 98108 | TRUPANION.COM

ATTENTION: The information contained in this message may be privileged and/orconfidential. It is intended to be read only by the individual or entity to whom it
is addressed. If you have received this message in error please immediately notify the sender and delete the message. Trupanion policies are underwritten by
American Pet Insurance Company (USA), which is owned by Trupanion, Inc., and by Omega General Insurance Company (Canada). Trupanion is a registered
trademark of Trupanion, Inc., a Delaware corporation.

From: Churchill, Harvey (OIC) <HarveyC@oic.wa.gov>
Sent: Wednesday, November 7, 2018 1:57 PM
To: Gavin Friedman <gavin.friedman@trupanion.com>
Subject: [EXTERNAL] Follow up to our meeting of 11/07/18

Mr. Friedman,

A thank you to both yourself and Mr. Chames for coming down and speaking with us today.

I wanted to follow up with my additional requested information:

1. Contact information for those Territory Partners I could not identify through licensing info, Kristin Wuhrman and
Melissa Maxwell.
2. Contact info, representative of Seattle Humane Society
3. Information on donations made to other humane societies
4. Clarification for me of what information is shared between the hospital and Trupanion Express from a consumer
WA State OIC 200
who, as the result of the recent examination, is eligible for the 30 day free-look offer.
5. Confirmation that information is entered on the hospital software but may be shared to Trupanion Express by the

operator
6. You mentioned a legal opinion that an attorney had provided regarding the need to license Terrotory Partners,
may a copy be available?

Thanks again for your assistance.

Harv

Harvey Churchill, CFE

Senior Investigator, Regulatory Investigations Unit, Legal Affairs
360-725-7045 (office)
HarveyC@oic.wa.gov
Protecting Insurance Consumers

www.insurance.wa.gov | twitter.com/WA_OIC | wainsurance.blogspot.com | email/text alerts

WA State OIC 201

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Investigation Section Referral Form

Date of Referral: 04/09/2018

Referring Division: Company Supervision - Market Conduct Oversight, Market Analysis

OIC SIMBA #: N/A

Name of referring staff member: Ned Gaines

Name of staff member who handled matter: Ned Gaines

Name and Address of Person/Entity to be Investigated: American Pet Insurance

License Expiration Date: Trupanion Managers - 01/15/2020

Date incident occurred: Sales over the past 2 years

File #1569460 Exhibit #1A Page 1 of 19

Documents attached? Yes

File #1569460 Exhibit #1A Page 2 of 19

Trupanion: VCA Animal Hospital Practice of Recommending Trupanion Pet

File #1569460 Exhibit #1A Page 3 of 19

File #1569460 Exhibit #1A Page 4 of 19

File #1569460 Exhibit #1A Page 5 of 19

Trupanion: Recent Disclosures About Sharing Cost Savings With Veterinary

In-Depth: Trupanion Sharing Cost Savings

File #1569460 Exhibit #1A Page 6 of 19

File #1569460 Exhibit #1A Page 7 of 19

Both Iowa and Illinois have similar anti-rebate laws.

File #1569460 Exhibit #1A Page 8 of 19

The Full Event

Veterinarians: Earn a Trip

Read full article >

Latest Events about Trupanion

Sep 30, 2017

Veterinarians: Earn a Trip to Hawaii, Las Vegas, or

Sep 30, 2017

File #1569460 Exhibit #1A Page 9 of 19

Rehoming your pet in the face of a disaster

How to foster a dog or cat

5 ways to pamper your pup

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Sep 12, 2017

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About Trupanion View Full Trupanion Profile >

Trupanion At-a-Glance Key Stats Headquarters

Founder & CEO

WHAT WE DO SUCCESS COMPANY RESOURCES ENTERPRISE

© 2017 Owler, Inc.

File #1569460 Exhibit #1A Page 11 of 19

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TRUPANION AFFILIATE PARTNERSHIP PROGRAM

Benefits to being a Trupanion Affiliate

File #1569460 Exhibit #1A Page 13 of 19

Access to personalized marketing tools to promote Trupanion.

Ongoing support from Trupanion’s Affiliate Marketing team.

Ready to join? Click below to fill out our quick form.

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Frequently Asked Questions

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File #1569460 Exhibit #1A Page 14 of 19

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