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REPORT ON EXAMINATIONOFATLANTA INTERNATIONAL INSURANCE COMPANY(now known as WELLFLEET NEW YORK INSURANCE COMPANY)AS OFDECEMBER 31, 2018DATE OF REPORTMARCH 11, 2020EXAMINERSHEIK MOHAMED

TABLE OF CONTENTSITEMPAGE NO.1.Scope of examination22.Description of Company3A.B.C.D.E.3468103.Corporate governanceTerritory and plan of operationReinsurance cededHolding company systemSignificant ratiosFinancial statements12A. Balance sheetB. Statement of incomeC. Capital and surplus1214154.Losses and loss adjustment expenses155.Subsequent events166.Compliance with prior report on examination167.Summary of comments and recommendations16

ANDREW M. CUOMOGovernorLINDA A. LACEWELLSuperintendentMarch 11, 2020Honorable Linda A. LacewellSuperintendentNew York State Department of Financial ServicesAlbany, New York 12257Madam:Pursuant to the requirements of the New York Insurance Law, and in compliance with the instructionscontained in Appointment Number 31939 dated April 10, 2019, attached hereto, I have made anexamination into the condition and affairs of Wellfleet New York Insurance Company (formerly known asAtlanta International Insurance Company) as of December 31, 2018, and submit the following reportthereon.Wherever the designation “the Company” appears herein without qualification, it should be understood toindicate Wellfleet New York Insurance Company.Wherever the term “Department” appears herein without qualification, it should be understood to mean theNew York State Department of Financial Services.The examination was conducted at the Company’s administrative office located at 746 Alexander Road,Princeton, NJ 08540.One State Street, New York, NY 10004-1511 (212) 480-6400 www.dfs.ny.gov

21.SCOPE OF EXAMINATIONThe Department has performed an examination of the Company, a multi-state insurer. The previousexamination was conducted as of December 31, 2016. This examination covered the two-year period fromJanuary 1, 2017 through December 31, 2018. Transactions occurring subsequent to this period werereviewed when deemed appropriate by the examiner.The examination was conducted in conjunction with the State of Indiana, which was the facilitatingstate of the National Indemnity Company sub-group of the Berkshire Hathaway Group. Nebraska is the leadstate of the Berkshire Hathaway Group. The examination was performed concurrently with theexaminations of the following insurers:CompanyAttPro RRG Reciprocal Risk Retention GroupMedPro RRG Risk Retention GroupThe Medical Protective CompanyWellfleet Insurance CompanyPLICO, Inc.Princeton Insurance CompanyDomicileDistrict of ColumbiaDistrict of ColumbiaIndianaIndianaOklahomaNew JerseyOther states participating in this examination were Oklahoma, and New Jersey. The District ofColumbia also participated in this examination.This examination was conducted in accordance with the National Association of InsuranceCommissioners (“NAIC”) Financial Condition Examiners Handbook, which requires that we plan andperform the examination to evaluate the financial condition and identify current and prospective risks ofthe Company by obtaining information about the Company including corporate governance, identifying andassessing inherent risks within the Company and evaluating system controls and procedures used to mitigatethose risks. This examination also includes assessing the principles used and significant estimates made bymanagement, as well as evaluating the overall financial statement presentation, management’s compliancewith New York laws, statutory accounting principles, and annual statement instructions.This examination report includes, but is not limited to, the following:Company historyManagement and controlTerritory and plan of operationReinsuranceHolding company descriptionFinancial statement presentationLoss review and analysisSummary of recommendations

3A review was also made to ascertain what action was taken by the Company with regard to therecommendation contained in the prior report on examination.This report on examination is confined to financial statements and comments on those matters thatinvolve departures from laws, regulations or rules, or that are deemed to require explanation or description.2.DESCRIPTION OF COMPANYWellfleet New York Insurance Company was incorporated under the laws of the State of New Yorkon January 21, 1929. It became licensed and commenced business on January 22, 1929. Operations of theCompany were conducted under the title Seaboard Fire and Marine Insurance Company of New York fromorganization until October 1, 1975, Drake Insurance Company of New York until January 1, 1980, andAtlanta International Insurance Company until January 14, 2019 when the name Wellfleet New YorkInsurance Company was adopted.The Company ceased its underwriting operations in March 1985, and management directed the runoff of the Company’s inventory of claims.Effective August 7, 2009, all the outstanding shares of common stock of the Company were acquiredby National Indemnity Company (“NICO”), a subsidiary of Berkshire Hathaway Inc., from Aon ServicesGroup, Inc., a subsidiary of Aon Corporation.On January 1, 2017, NICO sold all the common shares of the Company to Columbia InsuranceCompany (“Columbia”), an affiliate. Immediately after the purchase, Columbia contributed all the commonshares to its affiliate MedPro Group Inc.In 2017, the Company re-commenced underwriting operations with a focus on blanket accident andstudent health products.A.Corporate GovernancePursuant to the Company’s charter and by-laws, management of the Company is vested in a boardof directors consisting of not less than seven nor more than twenty-one members. At December 31, 2018,the board of directors was comprised of the following seven members:

4Name and ResidencePrincipal Business AffiliationGraham T. Billingham, M.D.Auburn, CAChief Medical Officer,MedPro Group Inc.Anthony A. BowserFort Wayne, INVice President and Chief Financial Officer,MedPro Group Inc.Bruce J. ByrnesNew City, NYVice President,National Indemnity CompanyAndrew M. DiGiorgioMonson, MAPresident,Wellfleet Group, LLCCarl T. Hook, M.D.Norman, OKRetired Chief Executive Officer,PLICO, Inc.Timothy J. KeneseyFort Wayne, INPresident and Chief Executive Officer,MedPro Group Inc.Charles W. LefevreHamilton Square, NJPresident and Chief Executive Officer,Princeton Insurance CompanyAs of December 31, 2018, the principal officers of the Company were as follows:B.NameTitleAndrew M. DiGiorgioAngela M. AdamsAnthony A. BowserBrad A. OberPresidentSecretaryVice President and TreasurerChief Health ActuaryTerritory and Plan of OperationAs of December 31, 2018, the Company was licensed to write business in the District of Columbiaand in all states except Illinois.As of the examination date, the Company was authorized to transact the kinds of insurance asdefined in the following numbered paragraphs of Section 1113(a) of the New York Insurance Law:Paragraph345Line of BusinessAccident & healthFireMiscellaneous property

5Paragraph67891011121314151617192021Line of BusinessWater damageBurglary and theftGlassBoiler and machineryElevatorAnimalCollisionPersonal injury liabilityProperty damage liabilityWorkers' compensation and employers' liabilityFidelity and suretyCreditMotor vehicle and aircraft physical damageMarine and inland marineMarine protection and indemnityThe Company is also authorized to transact such workers’ compensation insurance as may beincident to coverages contemplated under paragraphs 20 and 21 of Section 1113(a), including insurancedescribed in the Longshoremen’s and Harbor Workers’ Compensation Act (Public Law No. 803, 69thCongress as amended; 33 USC Section 901 et seq. as amended).Based upon the lines of business for which the Company is licensed and the Company’s currentcapital structure, and pursuant to the requirements of Articles 13 and 41 of the New York Insurance Law,the Company is required to maintain a minimum surplus to policyholders in the amount of 2,200,000.The following schedule shows the direct premiums written by the Company for the period underexamination:Calendar Year20172018Total Direct Premiums 71,704,868 113,863,359The Company did not assume business during the examination period. The Company was in runoff from March 1985 until 2017 when the Company re-commenced underwriting operations with a focuson blanket accident and student health products. Its student health insurance program provides one-yearterm coverage to college and university students, while participant accident policies are issued on a blanketbasis and renewable after a one-year term. The Company’s accident and health insurance programs areadministered by an affiliate, Wellfleet Group, LLC, a Massachusetts administrator.

6A majority of the Company’s direct writings in 2018 were concentrated in New York (85.7%),followed by South Carolina (7.8%). Major written product lines in 2018 for the Company were groupaccident and health (97.6%) and workers compensation (2.4%). The Company sells its products throughagents and brokers for the health insurance market, and through agents and brokers, general agents and theinternet for the workers’ compensation insurance market.In 2018, the Company started to transition its non-New York student health products to its sistercompany, Wellfleet Insurance Company (formerly known as Commercial Casualty Insurance Company),thereby reducing its current in-force business as of December 31, 2018.Due to the large reinsurance program described below, the net exposure of the Company issignificantly different than its direct exposure.C.Reinsurance CededThe Company has structured its ceded reinsurance program as follows:Effective December 31, 2016, through a 100% quota share reinsurance agreement, the Companyceded its gross policy liabilities for policies incepting prior to the effective date to Finial ReinsuranceCompany (“Finial”), a Connecticut-domiciled affiliate. The Company simultaneously assigned the rightsto its reinsurance to Finial.The Company ceded 0 of premiums and has a reinsurance recoverable of 10,377,000 from Finial,as reported in the Company’s 2018 Annual Statement - Schedule F.Effective January 1, 2017, the Company entered into a quota share agreement with The MedicalProtective Company (“MedPro”), an Indiana-domiciled affiliate. Under this agreement, MedPro assumes80% of its prospective accident & health insurance premiums written and earned, thereafter, in return forassuming 80% of all accident & health insurance losses and loss adjustment expenses incurred afterDecember 31, 2016 by the Company and all underwriting expenses associated with the ceded subjectpremium.The Company ceded 88,885,000 of premiums and has a reinsurance recoverable of 43,081,000from MedPro, as reported in the Company’s 2018 Annual Statement - Schedule F.

7Effective January 1, 2018, the Company entered into a quota share agreement with NICO, aNebraska-domiciled affiliate. Under this agreement, NICO assumes 80% of its prospective worker’scompensation insurance premiums written and earned, thereafter, in return for assuming 80% of allworker’s compensation insurance losses and loss adjustment expenses incurred after December 31, 2017by the Company and all underwriting expenses associated with the ceded subject premium.The Company ceded 2,206,000 of premiums and has a reinsurance recoverable of 2,047,000 fromNICO, as reported in the Company’s 2018 Annual Statement - Schedule F.The vast majority of the recoverable amounts reported on Schedule F – Part 3 are due from MedPro,Finial, and NICO, all authorized insurers. It is noted that the reinsurance recoverables from MedPro (149%of surplus) is the Company’s most significant financial item and ultimately the Company’s most significantfinancial risk, which is its ability to collect on the reinsurance recoverables. It is noted that MedPro wasexamined concurrently with the Company, and there were no financial adjustments that impacted thesurplus of MedPro as a result of the examination.Reinsurance agreements with affiliates were reviewed for compliance with Article 15 of the NewYork Insurance Law. It was noted that all affiliated reinsurance agreements were filed with the Departmentpursuant to the provisions of Section 1505(d)(2) of the New York Insurance Law.It is the Company's policy to obtain the appropriate collateral for its cessions to unauthorizedreinsurers. Letters of credit obtained by the Company to take credit for cessions to unauthorized reinsurerswere reviewed for compliance with Department Regulation 133. No exception was noted.All significant ceded reinsurance agreements in effect as of the examination date were reviewed andfound to contain the required clauses, including an insolvency clause meeting the requirements of Section1308 of the New York Insurance Law.Examination review found that the Schedule F data reported by the Company in its filed annualstatement accurately reflected its reinsurance transactions. Additionally, management has represented thatall material ceded reinsurance agreements transfer both underwriting and timing risk as set forth in theNAIC Accounting Practices and Procedures Manual, Statement of Statutory Accounting Principles(“SSAP”) No. 62R. Representations were supported by an attestation from the Company's Chief ExecutiveOfficer and Chief Financial Officer pursuant to the NAIC annual statement instructions. Additionally,examination review indicated that the Company was not a party to any finite reinsurance agreements. All

8ceded reinsurance agreements were accounted for utilizing reinsurance accounting as set forth in SSAP No.62R.D.Holding Company SystemThe Company is a member of the Berkshire Hathaway Group. The Company is 100% owned byMedPro Group Inc., an Indiana corporation, which is ultimately controlled by Berkshire Hathaway Inc.(“BHI”). Mr. Warren E. Buffett owned approximately 31.17559% of BHI at December 31, 2018.BHI is a public holding company which owns subsidiaries that engage in a number of diversebusiness activities. BHI’s various operating businesses are managed on a decentralized basis. Its insuranceunderwriting operations include the following groups: (i) GEICO, (ii) The Berkshire Hathaway ReinsuranceGroup, and (iii) The Berkshire Hathaway Primary Group. The Berkshire Hathaway Primary Group is acollection of independently managed primary insurers that provide a wide variety of insurance coveragesto policyholders that are primarily located in the United States. The Company is a component of theBerkshire Hathaway Primary Group.A review of the holding company registration statements filed with this Department indicated thatsuch filings were complete and were filed in a timely manner pursuant to Article 15 of the New YorkInsurance Law and Department Regulation 52.The following is an abridged chart of the holding company system at December 31, 2018:

9Berkshire Hathaway Inc.(31.17559% owned by Warren E. Buffet)(Delaware)Columbia InsuranceCompany(Nebraska)NAIC #27812MedPro Group Inc.(Indiana)Wellfleet New YorkInsurance Company(New York)NAIC #20931National IndemnityCompany(Nebraska)NAIC #20087Finial ReinsuranceCompany(Connecticut)NAIC #39136The Medical ProtectiveCompany(Indiana)NAIC #11843Wellfleet Group, LLC(Massachusetts)Holding Company AgreementsAt December 31, 2018, the Company was party to the following agreements with other members ofits holding company system:Administrative Services AgreementEffective December 8, 2016, the Company and Wellfleet Group, LLC (formerly ConsolidatedHealth Plans, Inc.) entered into an administrative services agreement. Pursuant to the agreement, WellfleetGroup, LLC provides certain administrative and claims handling services to the Company. The Companypaid 4,019,961 and 9,210,511 for administrative services to Wellfleet Group, LLC in 2017 and 2018,respectively.The Department non-objected to the implementation of this agreement on January 12, 2017.

10Tax Allocation AgreementAt December 31, 2018, the Company was party to a tax allocation agreement with its ultimateparent, Berkshire Hathaway Inc., and various affiliated members. The agreement was dated August 8, 2009and was amended on May 11, 2013. Pursuant to the terms of the agreement, the parties agree to fileconsolidated federal income tax returns, which stipulates that the Company’s tax liability on a consolidatedbasis would not exceed the liability if the Company had filed its tax return on a stand-alone basis. Theagreement was filed with the Department pursuant to Circular Letter 33 (1979).The Company was also party to the following agreements, which were either not significant or notin use, as no expenses, or very minimal expenses, were paid under these agreements during the examinationperiod:E. Service agreement with National Liability & Fire Insurance Company and National IndemnityCompany; Service agreement with FlightSafety International Inc.; Service agreement with Resolute Management Inc.; Service agreement with WestGUARD Insurance Company; Investment services agreement with Berkshire Hathaway Inc.; Joint agency agreement among biBERK Insurance Services Inc., Berkshire Hathaway DirectInsurance Company, Commercial Casualty Insurance Company (now known as Wellfleet InsuranceCompany), and National Liability & Fire Insurance Company; and, Amended and restated cost sharing agreement with MedPro Group Inc.Significant RatiosThe Company’s operating ratios, computed as of December 31, 2018, fall within the benchmarkranges set forth in the Insurance Regulatory Information System of the NAIC.Operating RatiosNet premiums written to policyholders’ surplusAdjusted liabilities to liquid assetsTwo-year overall operatingResult79%96%93%Underwriting RatiosThe underwriting ratios presented below are on an earned/incurred basis and encompass the twoyear period covered by this examination:

11AmountsRatiosLosses and loss adjustment expenses incurredOther underwriting expenses incurredNet underwriting gain (loss) s earned 33,477,667100.00%The Company’s reported risk-based capital (“RBC”) score was 1,063.7% at December 31, 2018. TheRBC is a measure of the minimum amount of capital appropriate for a reporting entity to support its overallbusiness operations in consideration of its size and risk profile. An RBC of 200% or below can result inregulatory action. There were no financial adjustments in this report that impacted the Company’s RBCscore.

123.A.FINANCIAL STATEMENTSBalance SheetThe following shows the assets, liabilities and surplus as regards policyholders as of December 31,2018 as reported by the Company:AssetsAssetsBondsCommon stocks (stocks)Cash, cash equivalents and short-terminvestmentsReceivables for securitiesInvestment income due and accruedUncollected premiums and agents' balancesin the course of collectionDeferred premiums, agents' balances andinstallments booked but deferred and not yetdueAmounts recoverable from reinsurersCurrent federal and foreign income taxrecoverable and interest thereonReceivables from parent, subsidiaries andaffiliatesOther receivables 4,547,29513,798,400Total assetsAssets NotAdmittedNet AdmittedAssets 02,576,980 38017,23838,8610 90,450,192 3,650,880 86,799,312

13Liabilities, Surplus and Other FundsLiabilitiesLosses and loss adjustment expensesReinsurance payable on paid losses and loss adjustment expensesCommissions payable, contingent commissions and other similar chargesOther expenses (excluding taxes, licenses and fees)Taxes, licenses and fees (excluding federal and foreign income taxes)Net deferred tax liabilityUnearned premiumsCeded reinsurance premiums payable (net of ceding commissions)Funds held by company under reinsurance treatiesProvision for reinsurancePayable to parent, subsidiaries and affiliatesOther liabilities ,97844,831,155274,595426,5011,092,928748,222Total liabilities 57,898,129Surplus and Other FundsCommon capital stockGross paid in and contributed surplusUnassigned funds (surplus)Surplus as regards policyholdersTotal liabilities, surplus and other funds 3,001,98164,900,003(39,000,801)28,901,183 86,799,312Note: The Internal Revenue Service has completed its audits of the Company’s consolidated FederalIncome Tax returns through tax year 2011. All material adjustments, if any, made subsequent to the dateof examination and arising from said audits, are reflected in the financial statements included in this report.Audits covering tax years 2012 and 2013 are currently under examination. The examiner is unaware of anypotential exposure of the Company to any tax assessment and no liability has been established hereinrelative to such contingency.

14B.Statement of IncomeThe net income for the examination period as reported by the Company was 10,215,588 as detailedbelow:Underwriting IncomePremiums earnedDeductions:Losses and loss adjustment expenses incurredOther underwriting expenses incurred 33,477,667 28,085,4824,374,049Total underwriting deductions32,459,531Net underwriting gain or (loss) 1,018,136Investment IncomeNet investment income earnedNet realized capital gain 1,033,1758,977,133Net investment gain or (loss)10,010,308Other IncomeFinance and service charges not included in premiumsTotal other incomeNet income before federal and foreign income taxesFederal and foreign income taxes incurredNet income 2,4022,402 11,030,846815,258 10,215,588

15C.Capital and SurplusSurplus as regards policyholders increased 6,585,944 during the two-year examination periodJanuary 1, 2017 through December 31, 2018, as reported by the Company, detailed as follows:Surplus as regards policyholders, as reported bythe Company as of December 31, 2016 22,315,239Gains inSurplusNet incomeNet unrealized capital gains or lossesChange in net deferred income taxChange in non-admitted assetsChange in provision for reinsurance 10,215,588Net increase (decrease) in surplus 13,998,690Losses inSurplus3,026,933756,169 04,094,1913,318,5550 7,412,746Surplus as regards policyholders, as reported bythe Company as of December 31, 20186,585,944 28,901,183No adjustments were made to surplus as a result of this examination.Capital paid in is 3,001,981 consisting of 142,274 shares of 21.10 par value per share commonstock. Gross paid in and contributed surplus is 64,900,003. Gross paid in and contributed surplus did notchange during the examination period.4.LOSSES AND LOSS ADJUSTMENT EXPENSESThe examination liability for the captioned items of 3,175,700 is the same as reported by theCompany as of December 31, 2018. The examination analysis of the loss and loss adjustment expensereserves was conducted in accordance with generally accepted actuarial principles and statutory accountingprinciples, including the SSAP No. 55. The Company’s reserves are concentrated in the group accident andhealth line of business.

165.SUBSEQUENT EVENTSOn March 11, 2020, the World Health Organization declared an outbreak of a novel coronavirus(“COVID-19”) pandemic. The risks and uncertainties surrounding the COVID-19 pandemic may impactthe Company’s, and its competitors’, operational and financial performance. The extent of the impact ofthe COVID-19 pandemic on the Company’s operational and financial performance will depend on certaindevelopments, including the duration and spread of the outbreak, regulatory decisions, and the impact onthe financial markets. All of these developments are uncertain and cannot be predicted. The relatedfinancial impact cannot be reasonably estimated at this time.6.COMPLIANCE WITH PRIOR REPORT ON EXAMINATIONThe prior report on examination contained one recommendation as follows (page number refers tothe prior report):ITEMA.PAGE NO.It was recommended that the Company submit any agreement with itsaffiliates to the Department for approval at least thirty days prior to itsapplication as required by Section 1505(d)(3) of the New York InsuranceLaw.The Company has complied with this recommendation.7.SUMMARY OF COMMENTS AND RECOMMENDATIONSThis report on examination contains no comments or recommendations.8

Respectfully submitted,/S/Sheik H. Mohamed, CPAAssociate Insurance ExaminerSTATE OF NEW YORK))ss:COUNTY OF NEW YORK )Sheik H. Mohamed, being duly sworn, deposes and says that the foregoing report, subscribed byhim, is true to the best of his knowledge and belief./S/Sheik H. MohamedSubscribed and sworn to before methisday of, 2020.

The Medical Protective Company Indiana Wellfleet Insurance Company Indiana PLICO, Inc. Oklahoma Princeton Insurance Company New Jersey Other states participating in this examination were Oklahoma, and New Jersey. . Company were conducted under the title Seaboard Fire and Marine Insurance Company of New York from organization until October 1 .