UNIVERSAL AMERICAN FINANCIAL CORP. AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

10. STATUTORY CAPITAL AND SURPLUS REQUIREMENTS AND DIVIDEND RESTRICTIONS:

The Insurance Subsidiaries are required to maintain minimum amounts of capital and surplus as determined by statutory accounting. Each of the Insurance Subsidiaries' statutory capital and surplus exceeds its respective minimum requirement. However, substantially more than such minimum amounts are needed to meet statutory and administrative requirements of adequate capital and surplus to support the current level of the Insurance Subsidiaries' operations. At December 31, 2000 and 1999 the statutory capital and surplus, including asset valuation reserve, of the U.S. insurance subsidiaries totaled $86.5 million and $89.2 million, respectively. Total statutory net income for the three years ended December 31, 2000, 1999 and 1998 was $12.2 million ($14.7 million of which related to the Acquired Companies), $24.2 million ($25.4 million of which related to the Acquired Companies) and $0.6 million, respectively.

The National Association of Insurance Commissioners ("NAIC") imposes regulatory risk-based capital ("RBC") requirements on life insurance enterprises. At December 31, 2000 all of the Insurance Subsidiaries maintained ratios of total adjusted capital to RBC in excess of the Authorized Control Level.

PennCorp Life of Canada and Pennsylvania Life's Canadian Branch report to Canadian regulatory authorities based upon Canadian statutory accounting principles that vary in some respects from U.S. statutory accounting principles. Canadian net assets based upon Canadian statutory accounting principles were $56.4 million and $63.9 million as of December 31, 2000 and 1999, respectively. PennCorp Life of Canada maintained a Minimum Continuing Capital and Surplus Requirement Ratio ("MCCSR") in excess of the minimum requirement and Pennsylvania Life's Canadian branch maintained a Test of Adequacy of Assets in Canada and Margin Ratio ("TAAM") in excess of the minimum requirement at December 31, 2000.

Dividend payments from American Progressive to the Company would require regulatory approval, which, in all likelihood, would not be obtained until American Progressive generated enough statutory profits to offset its entire negative unassigned surplus, which was approximately $8.2 million at December 31, 2000. American Progressive made no dividends or distributions during the three years ended 2000.

American Pioneer may pay a dividend or make a distribution without the prior written approval of the Florida Insurance Department when (a) the dividend is equal to or less than the greater of (1) 10% of the insurer's surplus as to policyholders derived from net operating profits on its business and net realized capital gains ("policyholder surplus from operations"); or (2) the insurer's entire net operating profits and realized net capital gains derived during the immediately preceding calendar year but not more than its policyholder surplus from operations; (b) the insurer will have surplus as to policyholders equal to or exceeding 115% of the minimum required statutory surplus as to policyholders after the dividend or distribution is made; and (c) the insurer has filed notice with the department at least 10 business days prior to the dividend payment or distribution. American Pioneer did not pay any dividends during the three years ended December 31, 2000.

Under current Pennsylvania and Texas insurance law, a life insurer may pay dividends or make distributions out of unassigned surplus without the prior approval of the Insurance Department as long as the dividend distributions do not exceed the greater of (i) 10% of the insurer's surplus as to policyholders as of the preceding December 31st; or (ii) the insurer's net gain from operations for the immediately preceding calendar year. American Exchange made no dividends or distributions during the three years ended December 31, 2000. During the year ended December 31, 2000, Pennsylvania Life and Union Bankers paid ordinary dividends to American Exchange of $2.9 million and $2.0 million, respectively. Additionally, Peninsular Life paid an extraordinary dividend of $1.5 million to Universal American in 2000.

Under current Canadian law, a life insurer may pay a dividend after such dividend declaration has been approved by its board of directors and upon at least 10 days prior notification to the Superintendent of Financial Institutions. In considering approval of a dividend, the board of directors must consider whether the payment of such dividend would be in contravention of the Insurance Companies Act of Canada. PennCorp Life of Canada did not pay any dividends in 2000.

The Insurance Subsidiaries' statutory basis financial statements are prepared in accordance with accounting practices prescribed or permitted by their respective domiciliary states. "Prescribed" statutory accounting practices include state laws, regulations and general administrative rules, as well as publications of the NAIC. "Permitted" statutory accounting practices encompass all accounting practices that are not prescribed but are authorized by the relevant insurance departments; such practices may differ from state to state, may differ from company to company within a state and may change in the future.

In 1998, the NAIC approved a codification of statutory accounting principles, effective January 1, 2001, which will serve as a comprehensive and standardized guide to statutory accounting principles. The adoption of the codification will change, to some extent, the accounting practices that the Company's Insurance Subsidiaries use to prepare their statutory financial statements. The Company does not believe that such changes will have a material adverse impact on the reported statutory financial condition of any such subsidiaries.