Section A
This section is specific to the members who reside outside of New York.

• We, Us, Our, or Company means Virginia Surety Company, Inc.
• You, Your, or Member means the individual person who has enrolled in a membership that this coverage is part of.
• Identity Theft means the use of Your name, address, Social Security number (SSN), bank, or credit card account number, or other identifying information without Your knowledge to commit fraud or other crimes.  
• Administrator means TWG Innovation Solutions, Inc. (TWGIS) located at 13922 Denver West Parkway, Golden CO, 80401.
• Identity Theft Expenses means the following when incurred as a direct result of Identity Theft:
  • Legal Expenses: Reasonable and necessary attorney fees or court costs associated with defending any suit brought against You by merchants, financial institutions or other credit grantors, or their collection agencies or the removal of any criminal or civil judgment wrongly entered against You;
  • Lost Wages: Actual U.S. wages or salary You lose as a direct result of time off work taken by You to report or address the effects of Identity Theft;
  • Miscellaneous: Loan applications fees, long distance telephone costs, mailing and postage costs, costs of having affidavits or other documents notarized. Costs to purchase up to four (4) credit reports from any of the three major credit bureaus (Experian, Equifax, or TransUnion). The credit reports may be purchased only after the Identity Theft has occurred and for the purpose of correcting inaccuracies that occur as a result of Identity Theft.

Coverage Agreement:

• We will reimburse You for Identity Theft Expenses You incur as a result of an Identity Theft incident that occurs or was first known to You while You are a Member to be eligible for coverage.
• Coverage is secondary to any other applicable insurance or coverage available to You.
• This Evidence of Coverage is not transferable to another person or entity.
  

Coverage Limitations:
Coverage is subject to:

• Reimbursement is limited to Your actual Identity Theft Expenses, not to exceed a total of $25,000 USD.
• There is a limit of two (2) Identity Theft incidents per twelve (12) month period.

Coverage Period:
This coverage begins on Your membership's effective date, and continues monthly unless non-renewed or cancelled by the Group Policyholder, the Company or You, and will end on the date Your membership is cancelled, non-renewed or expires.

Exclusions:
Identity Theft Expense Reimbursement coverage does not apply to:

• Any Identity Theft Expense not listed in the above Definitions section;
• Any act of theft, deceit, collusion, dishonesty or criminal act by You or any person acting in concert with You, or by any authorized representative of You, whether acting alone or in collusion with You or others;
• Damages or losses arising from the theft or unauthorized or illegal use of Your business name, d/b/a/ or any other method of identifying Your business activity;
• Any lost wages due to sickness or emotional breakdown;
• Damages or losses of any type for which the credit card company, bank, creditor, etc. is legally liable;
• Identity Theft Expenses that were incurred or commenced from a known Identity Theft incident that occurred prior to the effective date of Your membership;
• Damages or losses of any type resulting from fraudulent charges or withdrawal of cash from a debit or credit card or financial/bank/investment account;
• Any incident involving a loss or potential loss not notified to the relevant police authority within seventy-two (72) hours from the date You had knowledge of the loss;
• Fees or costs associated with the use of any investigative agencies or private investigators.

What to do if You are a Victim of Identity Theft:

• Contact TWG Innovation Solutions, Inc. (TWGIS) located at 13922 Denver West Parkway, Golden CO, 80401 to request assignment of a recovery advocate.
• Notify the Administrator within ten (10) days of discovery of Your Identity Theft problem.
• Notify the police in Your local jurisdiction within seventy-two (72) hours from the date You had knowledge of the Identity Theft loss.  Obtain a copy of the police report.

How to File for Reimbursement Under This Coverage:

• Contact  the Administrator at 1-888-398-4776 6am to 6pm MDT, M-F  to request an Identity Theft Expense Reimbursement claim form.  You must submit the following documentation within thirty (30) days to the Administrator after final resolution of Your Identity Theft incident or Your Identity Theft Expenses may not be covered:
• Completed and signed claim form;
• Proof that a fraud alert was placed with each major credit bureau (Experian, Equifax, TransUnion, etc.) immediately after discovery of Identity Theft;
• Copy of the complaint filed with the Federal Trade Commission (FTC);
• Copy of settlement reached by each party (creditors, collection agency, banks, etc.) involved with Your Identity Theft incident;
• Copy of a police report from Your local jurisdiction;
• Copy of all receipts, bills or other records that support the Identity Theft Expenses incurred by You;
• Any other documentation that may be reasonably requested to validate an Identity Theft incident.

General Provisions:
Cancellation and Non-Renewal:
The Policyholder or the Company can cancel or choose not to renew this coverage.  If this happens, You will be notified at least sixty (60) days in advance of the expiration of this coverage. Such notices need not be given if substantially similar replacement coverage takes effect without interruption. If coverage is canceled or non-renewed by the Policyholder or the Company, the coverage benefits will continue to be in force for the period that premium has already been paid for to the Company. Coverage will still apply to claims that occurred prior to the date of such cancellation or non-renewal, provided all other terms, conditions, and exclusions of coverage are met.
Payment of Coverage:
Benefits payable under this Evidence of Coverage for any loss will be paid upon receipt of acceptable proof of such loss and all required information necessary to support Your claim. All benefits will be paid to You directly or, in the case of Your death, to Your estate.
Subrogation:
If payment is made under this Evidence of Coverage, We are entitled to recover such amounts from other parties or persons.  Any person who receives payment under this coverage must transfer to Us his or her right to recover against any other party or person and must do everything necessary to secure these rights and must do nothing that would jeopardize them, or these rights will be recovered from You.
Concealment or Misrepresentation:
Your coverage shall be void if, whether before or after a loss, You have concealed or misrepresented any material fact or circumstances concerning this coverage or the subject thereof, or if You commit fraud or swear falsely in connection with any of the foregoing. 
Legal Actions:
No action at law or in equity shall be brought to recover under the Evidence of Coverage prior to expiration of sixty (60) days after proof of loss has been submitted in accordance with the requirements of the Evidence of Coverage.

End of Section A

Section B
This section is specific to the members who reside in the state of New York.

Virginia Surety Company Inc.
175 W. Jackson Blvd., Chicago, IL 60604

Identity Theft Expense Reimbursement
Certificate of Insurance

Coverage under this COI and the attached General Provisions are provided under a Group Policy issued to Consumerinfo.com, Inc., the Policyholder, by Virginia Surety Company, Inc. This COI and the attached General Provisions are governed by the conditions, limitations, and exclusions of the Group Policy.

A. DEFINITIONS

Throughout this document, You and Your refer to the person who is a member in the Program. Membership must not have expired or been canceled by You or the Program. We, Us, Our, and VSC refer to Virginia Surety Company, Inc. In addition, when in bold certain words and phrases are defined as follows:

Administrator means TWG Innovative Solutions, Inc. You may contact the Administrator if You have questions regarding this coverage or would like to make a claim. The Administrator can be reached by phone at 1-800-840-3582 or mail at 13922 Denver West Parkway, Golden, CO 80401.

Certificate of Insurance (COI) means this document and the attached General Provisions. They describe the terms, conditions, and exclusions. The COI and the attached General Provisions are the entire agreement between You and Us. Representations or promises made by anyone that are not contained in this COI or the attached General Provisions are not a part of Your coverage.

Coverage Period means the period starting on the Membership Effective Date and will continue monthly.

Identity Theft means the use of Your name, address, Social Security number (SSN), bank or credit card account number, or other identifying information without Your knowledge to commit fraud or other crimes.

1. Legal Expenses: Reasonable and necessary attorney fees or court costs associated with defending any suit brought against You by merchants, financial institutions or other credit grantors, or their collection agencies, or the removal of any criminal or civil judgment wrongly entered against You as a result of Identity Theft;
2. Lost Wages: Actual U.S. wages or salary You lose as a direct result of time off work taken by You to report or address the effects of Identity Theft;
3. Miscellaneous: Loan applications fees, long distance telephone costs, mailing and postage costs, and costs of having affidavits or other documents notarized as a result of Identity Theft. Costs to purchase up to four (4) credit reports from any of the three major credit bureaus (Experian, Equifax, or TransUnion). The credit reports may be purchased only after the Identity Theft has occurred and for the purpose of correcting inaccuracies that occur as a result of Identity Theft.

Membership Effective Date means the date You enroll as a member in the Program or upon receipt of payment of Your initial membership dues as per the membership terms and conditions for the Program, whichever occurs last.

Program means Membership Product.

B. COVERAGE AGREEMENT

We will reimburse You for Identity Theft Expenses incurred as a result of an Identity Theft incident that occurs or was first known to You during the Coverage Period.

This COI is not transferable to another person or entity.

C. LIMITATIONS

Coverage is limited to the actual Identity Theft Expenses, not to exceed a total of $10,000.

Coverage is further limited to $500 per week, for up to four (4) weeks for lost wages.

There is a limit of one (1) Identity Theft incident(s) per twelve (12) month period.

D. EXCLUSIONS

• Any Identity Theft Expense not listed in Section A - Definitions.
• Any act of theft, deceit, collusion, dishonesty, or criminal act by You or any person acting in concert with You, or by any authorized representative of You, whether acting alone or in collusion with You or others.
• Damages or losses arising from the theft or unauthorized or illegal use of a business name, d/b/a/ or any other method of identifying a business activity.
• Any lost wages due to sickness or emotional breakdown.
• Damages or losses of any type for which the credit card company, bank, creditor, etc. is legally liable.
• Identity Theft Expenses that were incurred or commenced from a known Identity Theft incident that occurred prior to the Coverage Period.
• Damages or losses of any type resulting from fraudulent charges or withdrawal of cash from a debit or credit card or financial/bank/investment account.
• Any incident involving a loss or potential loss not notified to the police within seventy-two (72) hours from the date You had knowledge of the loss.
• Fees or costs associated with the use of any investigative agencies or private investigators.

E. WHAT TO DO IF YOU ARE A VICTIM OF IDENTITY THEFT

• Contact ConsumerInfo.com for assistance upon discovery of the Identity Theft problem.
• Notify the police within seventy-two (72) hours from the date You had knowledge of the Identity Theft loss. Obtain a copy of the police report.

F. HOW TO FILE A CLAIM

Call the Administrator at 1-800-840-3582 to request a claim form. You must report the claim within ninety (90) days of the Identity Theft or as soon as reasonably possible.

1. The fully completed claim form.
2. Proof that a fraud alert was placed with each major credit bureau (Experian, Equifax, TransUnion, etc.) immediately after discovery of Identity Theft.
3. Copy of the complaint filed with the Federal Trade Commission (FTC).
4. Copy of settlement reached by each party (creditors, collection agency, banks, etc.) involved with Your Identity Theft incident.
5. Copy of the police report.
6. Copy of all receipts, bills or other records that support the Identity Theft Expenses incurred.
7. Any other documents that the Administrator may reasonably request to validate a claim.

Virginia Surety Company, Inc.
175 W. Jackson Blvd., Chicago, IL 60604

General Provisions
This General Provisions is attached to the COI and is provided under a Group Policy issued to ConsumerInfo.com, Inc (a/k/a/ Experian Consumer Direct) , the Policyholder, by Virginia Surety Company, Inc. Program benefits are subject to the terms and conditions outlined in the COI and include certain restrictions, limitations, and exclusions. In the event of any conflict between the COI and the Group Policy, the Group Policy will govern. The Group Policy is on file at the offices of the Administrator. The COI shall be interpreted and enforced according to the laws of the state of Illinois.

Cancellation and Non-Renewal:
a) Coverage can be cancelled by Us or Our designated representative for the following reasons:
i. Non payment of premium;
ii. Misrepresentation and Fraud (see below);
iii. The Department of Insurance determines that the COI would result in a violation of their law.
If we cancel coverage, the Policyholder will send You written notification at least ten (10) days in advance of cancellation for non-payment of premium and at least sixty (60) days in advance of cancellation for any other reason.
b) Coverage can be cancelled by the Policyholder at any time. If this happens, the Policyholder will send You written notification at least sixty (60) days in advance of the expiration of this coverage. Such notices need not be given if substantially similar replacement coverage takes effect without interruption and is provided by VSC. Coverage will continue to be in force for the period for which premium has already been paid to VSC.
c) Coverage can be non-renewed by Us. The Policyholder will send You written notification at least thirty (30) days in advance of the expiration of coverage.

Duplicate Membership Coverage: In the event there are, intentionally or unintentionally, more than one (1) membership within a household in the Program, coverage under the Group Policy is limited to one (1) benefit payable per loss.

Legal Actions: No action at law or in equity shall be brought to recover under the COI prior to the expiration of sixty (60) days after proof of loss has been furnished in accordance with the requirements of this coverage.
Misrepresentation and Fraud: Coverage may be cancelled if, whether before or after a loss, any party or person whom coverage is provided has concealed or misrepresented any material fact or circumstance concerning this coverage or the subject thereof, or the interests therein. Coverage may also be cancelled if fraud or false is committed swearing in connection with any of the above.
Other Insurance: Coverage is secondary to any other applicable insurance or indemnity available to any party or person whom coverage is provided. Coverage is limited to only those amounts not covered by any other insurance or indemnity. In no event will this coverage apply as contributing insurance. This Other Insurance clause will take precedence over a similar clause found in other insurance or indemnity language.
Subrogation: If payment is made under the COI, We are entitled to recover such amounts from other parties or persons. Any party or person to or for whom We make payment must transfer to Us his or her rights to recovery against any other party or person and must do everything necessary to secure these rights and must do nothing that would jeopardize them, or these rights will be recovered from that person.

Virginia Surety Company, Inc.
175 West Jackson Blvd., Chicago, IL 60604

NEW YORK AMENDATORY ENDORSEMENT
THIS ENDORSEMENT CHANGES THE POLICY, PLEASE READ IT CAREFULLY

Policy Number: EXP-ID-001
Effective Date of this Endorsement: June 1, 2009
It is agreed that the following revisions are made to the above captioned policy:

Under Section F Additional Provisions - Cancellation of This Policy, Section 2.a is replaced with the following:

• a. If cancelled within sixty (60) days of the Policy Effective Date:
• i. twenty (20) days before the effective date of cancellation if the Company cancels for nonpayment of premium; or
• ii. forty-five (45) days before the effective date if the Company cancels for any other reason.

Under Section F Additional Provisions - Cancellation of This Policy, Section 2.b.i is replaced with the following:
Twenty (20) days before the effective date of cancellation if the Company cancels for nonpayment of premium; or

Under Section F Additional Provisions, Cancellation of the Policy #3 is replaced with the following:
This Policy may be non-renewed as of any Policy Anniversary Date by the Company mailing to the Policyholder, by certified mail, at the last address known by the Company, written notice stating when, not less than forty-five (45) days, such nonrenewal will be effective and shall provide a specific explanation of the reasons for conditional renewal.

Under Section F Additional Provisions, Nonrenewal of the Policy is amended to add:
The Company will mail or deliver the notice to the Policyholder´s last mailing address known to the Company and the notice will contain the reason for cancellation.