Wells Fargo Bank, National Association v. Transamerica Life Insurance Company

CourtDistrict Court, C.D. California
DecidedFebruary 12, 2020
Docket2:19-cv-06791-CAS-GJS
StatusUnknown

This text of Wells Fargo Bank, National Association v. Transamerica Life Insurance Company (Wells Fargo Bank, National Association v. Transamerica Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wells Fargo Bank, National Association v. Transamerica Life Insurance Company, (C.D. Cal. 2020).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES —- GENERAL ‘O’ No. 2:19-cv-06791-CAS(GJSx) Date February 12, 2020 Title WELLS FARGO BANK, NATIONAL ASSOCIATION v. TRANSAMERICA LIFE INSURANCE COMPANY

ee eee CHRISTINA ASNYDER Catherine Jeang Not Present N/A Deputy Clerk Court Reporter / Recorder Tape No. Attorneys Present for Plaintiffs: Attorneys Present for Defendants: Not Present Not Present Proceedings: (IN CHAMBERS) - DEFENDANT’S MOTION TO DISMISS PLAINTIFF’S FIRST AMENDED COMPLAINT (Dkt. [ 23 ], filed October 28, 2019) I. INTRODUCTION Plaintiff Wells Fargo Bank, National Association (“Wells Fargo”) filed this action against defendant Transamerica Life Insurance Company on August 5, 2019. Dkt. 1. Wells Fargo alleges that Transamerica wrongfully increased the monthly deduction rates (‘MDRs”) of certain universal life insurance policies in violation of the terms of the policies and various states’ laws. Id. Transamerica filed the operative first amended complaint on October 28, 2019. Dkt. 22 (“FAC”). The FAC asserts claims for: (1) breach of contract: (2) contractual breach of the implied covenant of good faith and fair dealing; (3) violation of the Pennsylvania Insurance Bad Faith Statute (“Section 8371”); (4) violation of California’s Unfair Competition Law (“UCL”): (5) violation of the Connecticut Unfair Trade Practices Act (“CUTPA”):; (6) conversion; and (7) declaratory relief. See generally id. Transamerica filed a motion to dismiss the FAC on November 22, 2019. Dkt. 23-1 (“Mot.”). Wells Fargo filed an opposition on December 20, 2019. Dkt. 24 (“Opp.”). Transamerica filed a reply on January 10, 2020. Dkt. 26 (“Reply”). The Court held a hearing on January 23, 2020. Having carefully considered the parties’ arguments, the Court finds and concludes as follows. II. BACKGROUND Transamerica is an Iowa corporation with its principal place of business in Iowa. FAC 46. Wells Fargo alleges that Transamerica is authorized to do (and does substantial)

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES — GENERAL ‘Oo’ No. 2:19-cv-06791-CAS(GJSx) Date February 12, 2020 Title WELLS FARGO BANK, NATIONAL ASSOCIATION v. TRANSAMERICA LIFE INSURANCE COMPANY business in California. FAC § 6. At issue in this case are certain universal life insurance policies that Transamerica issued between 1990 and 2005. Id. 4 1. Wells Fargo is a national banking association that maintains its principal place of business in South Dakota. FAC § 5. Wells Fargo acts as the securities intermediary for 15 Transamerica universal life insurance policies. Id. 1. These policies range in face amount from $400,000.00 to $35.5 million and were issued in California, Arizona, Connecticut, Florida, Illinois, Michigan, Pennsylvania, and Texas. Id. { 11. Wells Fargo alleges that all 15 policies “are contracts of adhesion in that they are form policies drafted by Transamerica, . . . [all 15 [p]olicies are substantially similar and are subject to the same or similar material terms and conditions.” Id. § 20. Transamerica’s life insurance policies contain two components: (1) a “mortality” component, for which Transamerica charges a cost to cover the risk of the insured’s death (“the cost of insurance’); and (2) a “cash value” component, where premiums paid in excess of the cost of insurance and other charges accumulate (“the Accumulation Value”) and earn interest. FAC 412. Transamerica’s policies “unbundle” these two components “to allow policyholders to choose whether to pay just enough premiums to cover the risk of death (i.e., pay solely for the life insurance) or pay more (subject to certain limitations) and build up a cash value that earns tax-deferred interest.” Id. Transamerica deducts funds from the accounts through MDRs to cover the cost of insurance and other charges. Id. § 13. If the balance of a particular universal life insurance policy is insufficient to cover these monthly charges, then the policy will enter a grace period and lapse unless additional payments are made. Id. Transamerica’s universal life insurance policies include both guaranteed and non- guaranteed elements. FAC § 17. Guaranteed elements—including the guaranteed minimum interest rate on which interest on the Accumulation Values accrue—are fixed and determined at a specific time, such as when a given policy is issued. Id. Transamerica, however, may adjust non-guaranteed elements, such as the MDRs, consistent with the universal life insurance policy’s terms. Id. Wells Fargo’s policies state that Transamerica “will determine the Monthly Deduction Rate for each policy month at the beginning of that policy month,” or, in the case of | policy, at the beginning of each year. FAC § 18. Wells Fargo alleges that at least some of its policies provide that “[a|ny change in the Monthly Deduction Rates will be prospective and will be subject to our expectations as to future cost factors. Such cost

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES — GENERAL ‘Oo’ No. 2:19-cv-06791-CAS(GJSx) Date February 12, 2020 Title WELLS FARGO BANK, NATIONAL ASSOCIATION v. TRANSAMERICA LIFE INSURANCE COMPANY factors may include, but are not limited to: mortality; expenses; interest; persistency; and any applicable federal, state and local taxes.” FAC 4 18. Moreover, Wells Fargo’s policies indicate that Transamerica “does not distribute past surplus or recover past losses by changing the Monthly Deduction Rates.” Id, § 19 (internal alterations omitted). According to Wells Fargo, then, the policies’ terms limit Transamerica’s ability to raise MDRs in two critical aspects, such that: “(a) changes can only be based on Transamerica’s expectations as to future cost factors; and (b) changes must be prospective in nature only (i.e., Transamerica cannot change rates to recover past losses (or distribute past surplus)).” Id. 21. Wells Fargo alleges that Transamerica raised the MDRs on 10 of Wells Fargo’s policies in 2016 and 2017 and on 5 of Wells Fargo’s policies in 2018. FAC § 23. According to Wells Fargo, “Transamerica has never explained the methodology used to determine each policy’s increase. However, recent calculations estimate that, on average, Transamerica has increased the Monthly Deduction Rate on the Policies by between 10% and 269%.” Id. Wells Fargo therefore contends that Transamerica’s MDR increases “constitute| | express breaches of the [p]olicies,” as well as “breaches of both common law and codified implied covenant of good faith and fair dealing and a violation of” various states’ laws. Id. 4. Wells Fargo asserts that the purpose of these increases 1s to “force Wells Fargo either to (a) pay exorbitant premiums that Transamerica knows would no longer justify the ultimate death benefits or (b) lapse or surrender their policies, thereby forfeiting the premiums paid by Wells Fargo . . . over the last decades.” Id. 4 56. i. LEGAL STANDARDS A. Rule 12(b)(2) When a defendant moves to dismiss for lack of personal jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(2), the “plaintiff bears the burden of establishing that jurisdiction is proper.” Boschetto v. Hansing, 539 F.3d 1011, 1015 (9th Cir. 2008) (citation omitted). Where, as here, the defendant’s motion is based on written materials rather than an evidentiary hearing, “the plaintiff need only make a prima facie showing of jurisdictional facts to withstand the motion to dismiss.” Brayton Purcell LLP v. Recordon & Recordon, 606 F.3d 1124, 1127 (9th Cir. 2010) (quoting Pebble Beach Co. v. Caddy, 453 F.3d 1151, 1154 (9th Cir. 2006)).

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Bluebook (online)
Wells Fargo Bank, National Association v. Transamerica Life Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-national-association-v-transamerica-life-insurance-cacd-2020.