ARTER & HADDEN 1919 Pennsylvania Avenue, NW.

1. Washington, D.C. 20006 202/1775-7100 Telecopier 202/857-0172 Telex 6502156242-MCI Writers Direct Dial Number:

(202) 775-7129 November 7, 1990 Honorable James F. Rill Assistant Attorney General Antitrust Division U. s. Department of Justice 10th and Pennsylvania Ave. N.W.

Washington, D.C. 20530 Re: Request for Business Review Dear Mr. Rill:

1. This letter is submitted on behalf of Experience Information Bureau, Inc. ("EIB") to request business review by the Antitrust Division pursuant to 28 C.F.R. § 50.6 (1990).
   1. EIB is a North Carolina corporation which has been formed primarily to serve as a clearing house for underwriters of credit life and disability insurers. It is not yet operational. EIB is neither owned nor operated by any insurance carrier. Its principal stockholder is an independent insurance agent. A copy of its articles of incorporation are enclosed.
      1. EIB proposes to function much like a credit bureau for insurance carriers. It proposes to collect and distribute loss ratio information among its subscribers to assist them in evaluating risk. Much like a credit bureau which collects and disseminates information on individuals, EIB proposes to disseminate data relating to the experience of group creditor clients, i.e., lending institutions. To that end, EIB proposes to collect from subscribing insurance carriers data on their underwriting experiences for credit life and disability insurance for the past six years. It will ask for the name and address of the lending institution, the average term, average age and average duration of loans, and data on the net written premium, earned premium, claims incurred and paid, and the type of insurance in force. From this data, EIB will calculate the loss ratio. A sample of the suggested report to be generated is attached. IN CLEVELAND I'.\' COLUMBUS IN DALLAS IN LOS ANGELES ARTER & HADDEN ARTER&HADDEN ARTER & HADDEN ARTER, HADDEN, 1100 Huntington Building 10 West Broad Street l 717 Main Street, Suite 4100 LAWLER, FELIX & HALL Cleveland, Ohio 44115 Columbus, Ohio 43215 Dallas, Texas 75201 700 South Flower Street 216/696-1100 614/1221-3155 214/761-2100 Los Angeles, California 90017 2 1 3/629-9300 ARTER & HADDEN Honorable James F. Rill November 7, 1990 Page 2 Subscribers will pay membership dues annually which will entitle them to obtain the experience data collected from other subscribers for a nominal charge. EIB will neither comment on the data nor make any recommendation concerning the information disclosed. The disclosure will be accompanied by a statement that the information is conveyed for risk information purposes only and that discretion whether to deal with any entity on whom information is given is solely within the requesting member.
         1. It is EIB's hope and belief that its contemplated business will facilitate competition and efficiency. We hope this information provides a basis on which for you to inform us of the Department's enforcement intentions concerning the proposed conduct. If you need additional information or have any questions, please do not hesitate to contact me. Thank you in advance for your consideration of this matter.

            Sincerely, Laura Metcof f Klaus cc: Mr. Fred R. Costing State of Depart ment of the North Secretary of State Carolina To all to whom these presents shall come, Greeting:

            I, Thad Eure, Secretary of State of the State of North Carolina, do hereby certify the follotving and here to attached ( sheets) to be a true copy of . ARTICLES OF INCORPORATION OF EXPERIENCE INFORMATION BUREAU, INC.

            and the probates thereon, the original of which was filed in this office on the day of 1987 , 19th August after having been found to confonn to law.

            In Witness Whereof, I have hereunto set rny hand and affixed my o fficial seal.

            Done in Office, at Raleigh, this day 19th of in the year of our Lord 1987.

            August Secretary of State SCIHGANPATTEURR E3 4O9M, IT1T9E8D7 PSUERSSSUIOANN TL TAOW S By Deputy Secretary of State State of North Carolina NOTICE The issuance of c corporcte chcrter to any domestic corporation oro certificote of cvthority to cny foreign corporation does not cvthorize the use in this State of the corporate ncme in violation of the rights of any third party under the Federal Tr ade marks Act, the Trcdemork Act of this State, c trcde name or the common low; end the issuance of svch charter or certificate will not be c defense to en cdion for violetion of cny such righ1s.

            Certified Copy from The Department of The Secretary of State to be Recorded with the Register of Deeds ofCounty of Registered ,office EXPERIENCE INFORMATION BUREAU Account: FINANCIAL LENDING INSTITUTION Address: 123 YOUR STREET City: YOUR CITY State: YOUR STATE Zip: 12345 Date: 12/10/90 Report Date: 12/06/90 Begin Date: 11/01/87 End Date: 11/30/90 Average Term: 43 11os Average Duration: 37 11os Average Age: 44 Yrs Type B Life Disability Combined Net Written Premium: 1234567 2345678 3580245 Earned Premium: 617284 1423456 2040740 Claims Paid: 389776 789677 1179453 EjPaid Loss Ratio: 0.63 0.55 0.58 Claims Incurred: 411381 1323342 1734723 E/Incurred Loss Ratio: 0.67 0.93 0.85 Premium Earned By: 78'S 78'S/PR Single Reducing Y Joint Reducing Y Level Y Wait 14 Begin 1 Pre Exist Y Note: INCREASING NUMBER OF LONG TERM OPEN DISABILITY CLAIMS Underwriter: INSURANCE C0MPANY OF THE NORTH SOUTH EAST WEST. This information is conveyed for risk information purposes only and that discretion whether to deal with any entity on whom information is given is solely within the requesting member.

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ARTICLES CF INCORPORATION CF EXPERIENCE INFORMATION BUREAU, INC.

. ... ... : : ...

1. We,t he undersigned natural persons of the age of eighteen years or more.,. do . .... hereby associate ourselves into a business corporation under the laws of the ..... State of North Carolina, as contained in Chapter SS of the General Statutes of North Carolina, entitled "Business Corporation Act," and the several amendments thereto, and to that end do hereby set forth:
   1. 1. The name of the Corporation is EXPERIENCE INFORMATION BUREAU, INC.
      1. 2. The period of duration of the corporation shall be perpetual.
      2. 3. The purposes for which the corporation is organized are:
         1. a. the operation of a service bureau for the collection and dissemination of information beneficial to its members.
         2. b. To engage in any other lawful business authorized by law.
      3. 4. The total authorized capital stock of the corporation shall be one Hundred Thousand Dollars ( $100 ,000) , divided into 1,000 shares of common stock, with a par value of $100.00 per share.
      4. 5. The minimum amount of consideration for its shares to be received by the corporation before it shall commence business is $500.00.
      5. 6. The address of the initial registered office of the corporation is 2201 Leona Drive, Greensboro, Guilford County, North Carolina 27406, and the name of the initial registered agent at such address is Fred R. Oosting.
      6. 7. The number of directors of the corporation may be fixed by the bylaws, but shall not be less than two (except as permitted by N.C.G.S. 55-25). The number of directors constituting the initial board of directors shall be two, and the name and address of each person who is to serve as a director until the first meeting of shareholders or until his successor be elected and qualified is:

NAME ADDRESSES Fred R. Oosting 2201 Leona Drive Greensboro, NC 27406 Kermit F. Oosting 2201 Leona Drive Greensboro, NC 27406 a.

The name and address of each incorporator is:

Fred R. Oosting 2201 Leona Drive Greensboro, NC 27406 IN TESTIMONY WHEREOF, we have hereunto set our hands, this the D Yof August , 1987 .

1. Fred R. Oosting NORTH CAROLINA- GUILFORD COUNTY This is to certif.y, that on the / t day of August, 1987, before me, a Notary Public, personally appeared FRED R. OOSTING, who I am satisfied is the person named in and who executed the foregoing Articles of Incorporation, and I have first made known to him the contents thereof, he did acknowledge that he signed and delivered the same as his voluntary act and deed for the uses and purposes therein expressed.
   1. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed my official seal, this the day of August, 1987.

Notary Public My conmission expires:

JUDY McCONNELL NOTARY PUB LIC GUILFORD COUNTYNC COMMISSION Expires 11/20/87 -2-