The original complaint contained allegations that AIG engaged in sham transactions with a reinsurance company to create the appearance of insurance reserves when none existed; hid underwriting losses from a unit by transferring the losses to a secretly controlled off-shore entity; transferred losses between subsidiaries; created false underwriting income; repeatedly deceived state regulators about ties to off-shore entities; and improperly booked income. As part of the ongoing insurance investigation, there was also evidence that AIG participated with the brokers in bid-rigging. Since at least the mid-1990’s AIG and other insurers have paid hundreds of millions of dollars in “contingent commissions” to various insurance brokers and independent agents. In return for these commissions brokerages and brokers agreed to steer clients towards AIG. The contingent commission agreements (both formal and informal) were not disclosed to consumers who believed they were receiving the brokers’ unbiased advice. To guarantee that AIG obtained the business it wanted one brokerage, Marsh, arranged for other insurance companies to submit fraudulent bids which were known as “B Quotes” or “Bs.” AIG was aware of this anti-competitive behavior. In a global settlement with the New York Attorney General, the New York Insurance Department, the Securities and Exchange Commission, and the U.S. Department of Justice, AIG acknowledged the misconduct, agreed to extensive reforms, and agreed to pay over $1.6 billion dollars in restitution and penalties.