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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

CASE NO. 12-CV-60936-COHN/SELTZER

PHILIP PULLEY, DEVRA PULLEY,JEROME DAVIS, and SUSAN DAVIS,individually and on behalf of themselvesand all others similarly situated,

Plaintiffs,v.

JPMORGAN CHASE BANK, N.A.,

CHASE BANK USA, N.A., CHASEINSURANCE AGENCY, JP MORGANINSURANCE AGENCY, ASSURANT,INC., AMERICAN SECURITYINSURANCE COMPANY, andVOYAGER INDEMNITY INSURANCECOMPANY,

Defendants.

CLASS ACTION STIPULATION ANDSETTLEMENT AGREEMENT ANDRELEASE

STIPULATION AND SETTLEMENT AGREEMENT

This Stipulation and Settlement Agreement (Agreement) is made and entered into by

and among the Plaintiffs Philip Pulley, Devra Pulley, Jerome Davis, and Susan Davis

(Plaintiffs), on behalf of themselves and all Class Members as defined herein, and JPMorgan

Chase Bank, N.A., Chase Insurance Agency, Inc., and JP Morgan Insurance Agency, Inc.

(Chase Defendants).

1. RECITALS

1.1. On May 17, 2012, Plaintiffs Philip and Devra Pulley commenced this litigation

against JPMorgan Chase Bank, N.A. and Chase Bank USA, N.A (the Litigation).

1.2. On June 5, 2012, Plaintiffs filed their First Amended Complaint, which,inter alia,

sought damages on behalf of a nationwide class of residential mortgage loan or line of credit

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borrowers whose loans or lines of credit were serviced by the Chase Defendants and were

subjected to the force placement of wind insurance on the secured property.

1.3. In July 2012, Plaintiffs and the Chase Defendants entered into intensive mediation

through JAMS mediator David Geronemus, who has extensive mediation experience.

1.4. The mediation included the exchange of mediation statements, numerous days of

face to face meetings, and dozens of conference calls. It also included the collection, production,

and review of thousands of pages of documents and electronically-stored data concerning wind

lender-placed insurance.

1.5. While settlement negotiations were ongoing, Plaintiffs served document requests,

to which Defendants responded. Pursuant to the Courts Scheduling Order, on March 4, 2013,

Plaintiffs filed a motion for class certification and a memorandum in support thereof. Plaintiffs

also filed a Second Amended Complaint, which added additional Plaintiffs Jerome Davis and

Susan Davis and additional Defendants Chase Insurance Agency, JP Morgan Insurance Agency,

Inc., Assurant Inc., American Security Insurance Company, and Voyager Indemnity Insurance

Company as parties. The Chase Defendants, as well as Chase Bank USA, N.A., and the

Assurant Defendants filed separate motions to dismiss, which, along with Plaintiffs motion for

Class Certification, currently remain pending.

1.6. Beginning in mid-January 2013, Plaintiffs and Chase Defendants began a series of

extensive telephonic negotiations that culminated in a Memorandum of Understanding

(MOU), which was executed on April 12, 2013. The MOU provides the outline of an

Agreement to settle and resolve all issues in the Litigation on a class-wide basis and to dismiss

with prejudice all claims against Defendants (the Settlement).

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1.7. As part of the MOU, Chase Defendants have produced additional documents and

data requested by Plaintiffs to confirm, among other things, certain aspects of the Settlement and

to value the injunctive relief contained in the Settlement.

1.8. Plaintiffs have also made extensive use of publicly-available information,

including hearings before the New York Department of Financial Services and the Florida

Insurance Commissioner, Fannie Mae documents, and various banking and insurance

publications.

1.9. Class Counsel believe that the Litigation has significant merit and that the

evidence developed supports Plaintiffs claims. Class Counsel recognize and acknowledge,

however, that prosecuting this Litigation through fact and expert discovery, class certification,

dispositive motions, trial, and appeals will involve considerable time and expense.

1.10. Class Counsel have concluded that it is in the best interests of the Class as a

whole that the claims asserted in the Litigation be resolved on the terms and conditions set forth

in this Agreement. Class Counsel reached that conclusion after extensive consideration and

analysis of the factual and legal issues presented in the Litigation, the substantial benefits that

Class Members will receive as a result of the Settlement, the risks and uncertainties of continued

litigation, the expense that would be necessary to prosecute the Litigation through trial and any

appeals that might be taken, and the likelihood of success at trial.

1.11. Defendants have denied and continue to deny each and every allegation of

liability, wrongdoing, and damages, and assert that they have substantial factual and legal

defenses to all claims and class allegations in the Litigation. Defendants maintain and continue

to maintain that they have acted in accordance with governing law. Defendant Chase Bank

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USA, N.A. separately denies the factual allegations against it and that it has or had anything to

do with lender-placed insurance or the subject of this Litigation. Nonetheless, Chase Defendants

have concluded that because continuation of the Litigation would be protracted and expensive, it

is desirable that the Litigation be fully and finally settled on a class-wide basis in the manner and

upon the terms set forth in this Agreement.

1.12. Without admitting any liability or wrongdoing whatsoever, Chase Defendants

agree to the terms of this Agreement, provided that all Released Claims are settled and

compromised, in order to resolve all issues relating to the subject matter of the Litigation.

NOW, THEREFORE, for and in consideration of the mutual understandings contained

herein, and for other good and valuable consideration, the receipt and adequacy of which is

hereby acknowledged, Plaintiffs, on behalf of the Class, and Chase Defendants stipulate and

agree as follows:

2. DEFINITIONS

As used herein, the following terms have the meanings set forth below.

2.1. Administrator or Settlement Administrator means a qualified third party

appointed by the Court for the oversight and/or dissemination of Class Notice, the processing

and fulfillment of claims in connection with this Settlement, and ensuring that claims fulfillment

is properly implemented.

2.2. Agreement or Settlement Agreement means this Settlement Agreement,

including all exhibits thereto.

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2.3. Attorneys' Fees and Expenses means fees and expenses allowed by the Court

that are sought by Plaintiffs' Counsel in the prosecution of the Litigation. Any Attorneys Fees

and Expenses shall be paid from the Settlement Fund.

2.4. Award means a payment to a Settlement Class Member under the Settlement

pursuant to the Plan of Allocation in Paragraph 5 of this Agreement.

2.5. CAFA Notices means the notice of this settlement to be served upon State and

Federal regulatory authorities as required by the Class Action Fairness Act of 2005, 28 U.S.C.

1715.

2.6. Case Contribution Award means compensation for the Named Plaintiffs in the

Litigation for their time and effort undertaken in this Litigation.

2.7 Cashed Settlement Check Member List means the list of class members who

have cashed settlement checks within 120 days under the Plan of Allocation described in

Paragraph 5.

2.8. Chase Bank means JPMorgan Chase Bank, N.A. It does not include Chase

Bank USA, N.A..

2.9. Class Counsel means the law firm of Meredith & Narine.

2.10. Class List refers to the list of borrower on whose property Chase Defendants

placed wind insurance during the period January 1, 2008 through March 4, 2003, as identified in

Paragraph 5.1 of this Agreement.

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2.11. Class Member Payment List means the list of the Settlement Class Members

who have not opted out and who will receive settlement payments under the Plan of Allocation

described in Paragraph 5 of this Agreement.

2.12. Class Notice means the Court-approved form of notice to Settlement Class

Members, in substantially the same form as Exhibit A, which, among other things, will comply

with the requirements of Paragraphs 5.5 and 12 and will notify Settlement Class Members of the

preliminary approval of the Settlement and the scheduling of the Final Approval Hearing.

2.13. Class Period means the period of time from January 1, 2008 through March 4,

2013.

2.14. Court means the United States District Court for the Southern District of

Florida.

2.15. Days means calendar days, except that, when computing any period of time

prescribed or allowed by this Agreement, the day of the act, event, or default from which the

designated period of time begins to run shall not be included. Further, when computing any

period of time prescribed or allowed by this Agreement, the last day of the period so