Allegations
(a) National General was perpetrating a massive forced-placed CPI scheme to fraudulently saddle its own customers with unwanted and unneeded automobile insurance policies that it had underwritten; (b) National General’s illicit conduct in foisting unwanted and unneeded automobile insurance on its customers had resulted in some of the victims being declared delinquent, suffering adverse impacts to their creditworthiness, and/or having their cars improperly repossessed; (c) National General was exposed to an extreme risk of regulatory scrutiny, legal risks, and reputational harm as a result of its participation in the forced placed CPI scheme; (d) the Company had failed to maintain effective internal controls over its financial reporting, including by failing to maintain formal documentation sufficient to reasonably ensure the accuracy of internal reporting and accounting procedures across much of its business, including with respect to insurance policy premiums; (e) the Company’s reported quarterly revenues and policy premiums were in part the product of a fraudulent forced-placed insurance scheme and were therefore artificially inflated and unsustainable; and (f) National General had in fact lost substantial business with Wells Fargo because Wells Fargo had terminated the forced-placed CPI scheme after concluding that it posed excessive reputational risk and legal exposure.