Plaintiff State alleged tht ACE conspired with Marsh McLennan and other brokers by submitting fake bids to create the illusion of a competitive bidding process, even though the broker had already determined which insurer would receive a particular policyholder’s business. ACE was rewarded by brokers, who steered other lucrative business to it. ACE paid “contingent commissions” to these brokers, and these commissions were not disclosed to policyholders. Prior to this settlement, ACE provided reimbursement to a nationwide group of policyholders and adopted significant business reforms that govern its bidding and underwriting practices. Under the consent decree and final judgment, ACE will be required to abide by those reforms and, upon the request of its customers or prospective policyholders, to disclose the actual amount of payments made to insurance brokers. See also District of Columbia v. ACE, Oregon v. ACE, Texas v. ACE, settled simultaneously).