Willis is an insurance brokerage that provides risk management, human capital, and management consulting. The State alleged that Willis unlawfully deceived clients by steering clients insurance business to favored insurance companies, and soliciting fictitious bids to assure that insurance policies were placed to benefit insurers. Under the assurance, Willis will pay $50 million into a fund from which policyholders will be compensated. Further, Willis must undertake specific business reform to not accept: Contingent Compensation, requests or any compensation in connection with Willis?s selection of insurers from which to solicit bids for its clients, false or inflated quotes. Willis may not request insurers to use Willis?s own brokerage services or to conduct business through a wholesale broker unless agreed to by client after full disclosure of the compensation.