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Global Growth Letter to the North Carolina Department of Insurance Commissioner

June 23, 2022

Mr. Mike Causey


North Carolina Department of Insurance

25 N. Salisbury St.

Raleigh, NC 27603

Mr. Causey,

As you know, Global Growth has been working with your team at the Department of Insurance for quite some time to help ensure policyholders are protected and we greatly appreciate this dialogue. There can be no question that your agency, like Global Growth, wants to ensure that policyholders are protected and have access to their funds as soon as possible. As CEO, I came to this job with a commitment to make this situation right for our policyholders, and we have a strong plan to do so.

As an important next step in our work together, today I am requesting an in-person meeting with you and your team as soon as possible to allow us to present to you our accelerated rehabilitation plan for the insurance companies affiliated with Global Growth. We share your commitment to policyholders, and we have a methodical and strong plan to help get policyholders their resources on an expedited basis. As it stands today, under the current North Carolina Department of Insurance plans, policyholders would gain access to their insurance funds in 2029. Our plan would allow policyholders to have full access to their insurance funds as soon as the next twelve months – six years earlier than the current plans that have been put in place by your agency.

Attached you will find a summary of our plan which we submitted to your agency in detail on Monday, June 6. You will also find attached a signed indication of interest (IOI) from a major insurance industry buyer who is interested in acquiring all three North Carolina insurance companies that relate to the issues at hand. We received their letter and promptly forwarded it to your team. For context, as you know, Global Growth has already paid $370 million to all of its insurance companies. We now have a prudent, methodical and disciplined plan to repay the remaining $1 billion in affiliated investments to the North Carolina entities and are hopeful that the NCDOI will support our efforts. My team and I have been working diligently over the last six months to arrange a series of near-term transactions that will reduce the concentration of affiliated investments held by the North Carolina insurance companies, improve their liquidity and enable their rehabilitation well ahead of schedule. The rehabilitation proposal by Global Growth involves (1) expediting additional refinancing and sale transactions to reduce the insurance companies’ affiliated investments, and (2) selling the North Carolina insurance companies to a new owner who can return them to regular operations.

If approved by NCDOI, this plan would accomplish the goal of rehabilitating the insurance companies and making sure that policyholders receive their policy benefits within two years, if not sooner.

It is important to note that with every month that passes, policyholders are denied access to an additional $4 million in benefits. This has been a painful time for policyholders, and I know you are as troubled as I am by the very real stories we have heard from those impacted. Working together, I firmly believe we can implement our plan to help policyholders get their resources as soon as possible. Thank you for your consideration and attention to this important matter. I look forward to meeting with you very soon.


Justin Holbrook

Chief Executive Officer

Global Growth Holdings, Inc.


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