Protective Life Ins. Co. v. Nationscredit Fin. Servs. Corp.

2016 NCBC 10
CourtNorth Carolina Business Court
DecidedFebruary 2, 2016
Docket15-CVS-6885
StatusPublished

This text of 2016 NCBC 10 (Protective Life Ins. Co. v. Nationscredit Fin. Servs. Corp.) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Protective Life Ins. Co. v. Nationscredit Fin. Servs. Corp., 2016 NCBC 10 (N.C. Super. Ct. 2016).

Opinion

Protective Life Ins. Co. v. NationsCredit Fin. Servs. Corp., 2016 NCBC 10.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF MECKLENBURG 15 CVS 6885

PROTECTIVE LIFE INSURANCE ) COMPANY, ) Plaintiff, ) ) v. ) ORDER ON MOTION TO COMPEL ) ARBITRATION NATIONSCREDIT FINANCIAL SERVICES ) CORPORATION, ) Defendant. )

THIS MATTER comes before the Court on Defendant's Motion to Compel Arbitration

("Motion" or "Motion to Compel") pursuant to the Federal Arbitration Act, 9 U.S.C. § 1, et

seq. On January 19, 2016, the Court held a hearing on the Motion.

THE COURT, having considered the Motion, Plaintiff's opposition to the Motion, the

affidavits and evidence provided by the parties, the arguments of counsel, and other

appropriate matters of record, FINDS and CONCLUDES as follows:

A. Factual and Procedural Background.

1. Plaintiff Protective Life Insurance Company ("Protective") is a Tennessee

corporation. Plaintiff sells life insurance and other insurance products.

2. Defendant NationsCredit Financial Services Corporation ("NFS") is a North

Carolina corporation. NFS is a residential mortgage lender.

3. NationsCredit Insurance Agency, Inc. ("NIA") apparently is a "captive"

insurance agency of Bank of America, and formerly, of Nationsbank. NFS and NIA were at

all times relevant to this matter subsidiaries of Equicredit Corporation of America, which is

a subsidiary of Bank of America, and are "affiliate companies."1 NIA is not a residential

mortgage lender. NIA is not a party to this lawsuit.

1 Costamanga Aff. ¶ 3; First Hickey Aff. ¶ 5. 4. From March through May 1997, Protective and NIA negotiated the Agency

Agreement and the Administrative Accounting Agreement ("Administrative Agreement").2

The parties executed the Agency Agreement on May 1, 1997, and the Administrative

Agreement on May 28, 1997. The Agreements were signed by Protective and by NIA. NFS

was not expressly named as a party to either agreement, and did not sign the Agreements.

The Agreements contained identical arbitration provisions. Those provisions stated, in

pertinent part, as follows:

All disputes and differences made between the parties to which an amicable understanding cannot be reached are to be decided by arbitration. Punitive damages against the parties shall not be awarded in, under, or as a part of any such proceeding, but punitive damages assessed against [Protective] in a civil proceeding brought by a third party may be recovered from the Agent in arbitration if the facts establish a right of indemnification. The arbiters, who shall regard this Agreement from the standpoint of practical business and equity rather than from that of strict law, are empowered to fully interpret this Agreement and the obligations upon the parties created thereunder.3

5. In or around the same time that the Agreements were executed, Protective

issued to NFS a "Single Premium Group Policy," with an effective date of May 1, 1997 ("Group

Policy").4 NIA was not named as a party to or an insured under the Group Policy. The Group

Policy defined NFS as the "Creditor," required Protective to furnish NFS with certificates of

insurance to be delivered to each insured, and required NFS to pay the premiums to

Protective.5

6. In or around May 1997, Protective also issued to NIA a "Single Premium Group

Net Pay-Off Policy" ("Net Pay-Off Policy").6 The Net Pay-Off Policy was nearly identical to

the Group Policy except for the maximum benefits payable. The effective date of coverage

2 First Hickey Aff., Exs. A and B; the Agency and Administrative Agreements collectively are hereinafter referred to "the Agreements". 3 Id. at § 19. 4 Pl.'s Opp. to Mot. to Compel, Ex. 3. 5 Id. 6 Id. under the Net Pay-Off Policy was May 28, 1997.7 The Net Pay-Off Policy defined NIA as the

"Creditor" and required NIA to pay the premiums to Protective.

7. There is no dispute that the purpose of the relationship created by the

Agreements and policies was to permit NFS to offer and sell credit life and disability policies

to borrowers to whom NFS made residential mortgage loans. Protective underwrote and

provided the policies of insurance. In the event a borrower died or became disabled, the policy

would pay off the borrower's mortgage. The relationship benefited each of the parties:

Protective received premiums on the policies sold by the lender, NIA received an

administrative fee, and NFS "as the lender, received a benefit through lower default rates

and customer satisfaction."8

8. The Agreements provided that NIA was responsible for obtaining the requisite

licensing for individuals selling its insurance products, and that Protective would appoint

these individuals as its agents. It is undisputed that the individuals primarily appointed to

act as Protective's agents were NFS loan officers responsible for residential mortgage loans.

The agreements also provided that NIA had authority to deliver certificates of insurance on

behalf of Protective to debtors who met certain health requirements. Finally, the agreements

provided that NIA would pay the premiums collected to Protective, and that NIA would

receive an administrative fee for the policies it sold.

9. NFS' loan officers sold credit life and disability insurance policies issued by

Protective to North Carolina borrowers from May 1, 1997, to April 30, 1999.

10. In 2002, a group of NFS' North Carolina borrowers filed a lawsuit against NFS

for alleged unfair and deceptive trade practices, breach of the duty of good faith and fair

dealing, and unjust enrichment related to the sale of the insurance policies written by, among

7 Id. 8 Id. Ex. 4, interrogatory nos. 49 and 51. others, Protective. (Juanita Richardson, Robert and Gloria Gower, and Joyce M. Smith v.

Bank of America, N.A. and NationsCredit Financial Services Corporation (Durham County,

02-CVS-2398); "the Richardson lawsuit"). The Richardson lawsuit subsequently was certified

as a class action. The trial court ultimately determined that many of the policies written by

Protective and issued to NFS' borrowers were unlawful and in violation of public policy. After

the trial court's orders were affirmed on appeal, the parties reached a settlement, with class

members' claims to be paid from a settlement fund not to exceed $36,907,263.33. The

payment amount of each individual claim was determined according to formulas contained

within the settlement agreement, derived from the trial court's determination of the measure

of damages. The payment amount did not include an allowance for punitive damages, but

did include treble damages as allowed by the North Carolina Unfair Trade Practice Act, N.C.

Gen. Stat. §§ 75-1.1 et seq. NationsCredit funded the settlement agreement in March 2009.

11. The Agency and Administrative Agreements contained identical

indemnification provisions which provide, in pertinent part, as follows:

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Bluebook (online)
2016 NCBC 10, Counsel Stack Legal Research, https://law.counselstack.com/opinion/protective-life-ins-co-v-nationscredit-fin-servs-corp-ncbizct-2016.