Plaintiff states alleged that Marsh, an insurance broker, engaged in a bid rigging scheme that allowed Marsh to designate which insurance company’s bid would “win” a particular account. To create the appearance of a competitive bidding process, Marsh would instruct certain insurers to submit inflated, intentionally uncompetitive bids. These schemes gave commercial policyholders the impression that they were receiving the most competitive commercial premiums available, when they were actually being overcharged. The states alleged that Marsh was involved with a “pay-to-play” arrangement centered on its receipt of contingent commissions, in addition to standard commissions and fees, from certain insurance companies. Contingent commissions, also known as profit sharing commissions, are incentive-based compensation programs offered to brokers by insurance companies. These arrangements were often undisclosed to consumers, and provided an incentive for brokers to steer business to the insurer who offered the most lucrative contingent commissions, often in violation of their clients’ interests. Marsh agreed to pay the state $7 million and to disclose to its clients all compensation received from insurance companies in connection with the placement of an insurance policy, obtain the client’s written consent to the compensation, and disclose at the end of each year annual totals of compensation received in connection with a client’s policy.