UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,404

NATIONWIDE MUTUAL INSURANCE COMPANY

P&C COMMERCIAL LINES PROCESSING

DES MOINES, IOWA

TA-W-96,404A

NATIONWIDE MUTUAL INSURANCE COMPANY

P&C COMMERCIAL LINES PROCESSING

CANTON, OHIO

TA-W-96,404B

NATIONWIDE MUTUAL INSURANCE COMPANY

P&C COMMERCIAL LINES PROCESSING

GAINESVILLE, FLORIDA

TA-W-96,404C

NATIONWIDE MUTUAL INSURANCE COMPANY

P&C COMMERCIAL LINES PROCESSING

HARLEYSVILLE, PENNSYLVANIA

TA-W-96,404D

NATIONWIDE MUTUAL INSURANCE COMPANY

P&C COMMERCIAL LINES PROCESSING

RALEIGH, NORTH CAROLINA

Certification Regarding Eligibility

To Apply for Trade Adjustment Assistance for Workers

In accordance with Section 223 of the Trade Act of 1974, as amended ("the Act"), 19
U.S.C. § 2273, the Department of Labor ("Department") herein presents the results of an
investigation regarding certification of eligibility to apply for Trade Adjustment Assistance
("TAA") for workers.

The investigation was initiated in response to a TAA petition dated September 25, 2020
and filed on September 28, 2020 by a State Workforce Office, on behalf of workers and former
workers of Nationwide Mutual Insurance Company, P&C Commercial Lines Processing, Des
Moines, Iowa (TA-W-96,404); Nationwide Mutual Insurance Company, P&C Commercial
Lines Processing, Canton, Ohio (TA-W-96,404A); Nationwide Mutual Insurance Company,
P&C Commercial Lines Processing, Gainesville, Florida (TA-W-96,404B); Nationwide
Mutual Insurance Company, P&C Commercial Lines Processing, Harleysville, Pennsylvania
(TA-W-96,404C); and Nationwide Mutual Insurance Company, P&C Commercial Lines
Processing, Raleigh, North Carolina (TA-W-96,404D) (hereafter referred to as the "worker
group"). In accordance with 20 C.F.R. 618.110 a worker group is defined as, ""¦inclusive of
teleworkers and staffed workers."

The worker group is engaged in activities related to the supply of internal
administrative support services for commercial line insurance policies and are not separately
identifiable by service.

The petition alleged that worker separations, or threats thereof, were due to foreign trade
positions transitioning to India.

During the course of the investigation, the Department collected information from the
petitioner(s), the workers' firm, and other relevant sources.

The group eligibility requirements for workers of a firm under Section 222(a) of the Act,
19 U.S.C. § 2272(a), are satisfied if the following criteria are met:

Employment Criterion

(1) A significant number or proportion of the workers in such workers' firm have become
totally or partially separated, or are threatened to become totally or partially separated.

20 C.F.R. 618.225(c)(1)(ii) states that an "Analysis of separation data must generally
consist of a: "(A) Comparison of employment on the petition date to employment on the date that
is 1 year prior to the petition date; (B) Review of employment activity during the 1-year period
prior to the petition date; and (C) Review of evidence provided by the workers' firm regarding
actual and threatened separations that occur, or are scheduled to occur, after the petition date."

The Department determines that the employment criterion has been met.

Shift/Acquisition Criterion

(2)(B)(i)(I) there has been a shift by the workers' firm to a foreign country in the production
of articles or the supply of services like or directly competitive with articles which
are produced or services which are supplied by such firm; or

(II) such workers' firm has acquired from a foreign country articles or services that
are like or directly competitive with articles which are produced or services which
are supplied by such firm;

According to 20 C.F.R. 618.225(c)(2)(ii), "Analysis of acquisition data must generally
consist of a: (1) Comparison of shift data on the petition date to shift/acquisition data that is 1 year
prior to the petition date; (2) Review of shift/acquisition activity during the 1-year period prior to
the petition date; and (3) Review of evidence provided by the workers' firm regarding
shift/acquisition activity scheduled to occur after the petition date."

The Department determines that the acquisition criterion has been met.

Contributed Importantly Criterion

(ii) the shift described in clause (i)(I) or the acquisition of articles or services
described in clause (i)(II) contributed importantly to such workers' separation or
threat of separation.

Sec. 222(c) of the Trade Act and 20 C.F.R. 618.110 defines contributed importantly as "a
cause that is important but not necessarily more important than any other cause."

According to 20 C.F.R. 618.225(c)(3)(i), "Analysis of impact of acquisition data on worker
separations must generally consist of determining: (A) Whether there are one or more events or
factors that lessen or sever the causal nexus between the acquisition activity and worker separations
or threat of separation; (B) What percentage of the workers' firm sales or production declines was
attributable to the firm's acquisition activity; (C) Whether operations at the workers' firm domestic
facility or facilities decreased at the same or at a greater rate than contractor or licensee operations
in the foreign country; and (D) Whether there are other events or factors that mitigate or amplify
the impact of acquisition activity on the workers' firm. (ii) Whether there are other events or factors
that mitigate or amplify the impact of shift activity on the workers' firm. (B) The impact may be
determined using a quantitative or qualitative analysis."

The Department determines that the contributed importantly criterion has been met.

Conclusion

After careful review of the facts obtained in the investigation, I determine that workers of
Nationwide Mutual Insurance Company, P&C Commercial Lines Processing, Des Moines,
Iowa (TA-W-96,404); Nationwide Mutual Insurance Company, P&C Commercial Lines
Processing, Canton, Ohio (TA-W-96,404A); Nationwide Mutual Insurance Company, P&C
Commercial Lines Processing, Gainesville, Florida (TA-W-96,404B); Nationwide Mutual
Insurance Company, P&C Commercial Lines Processing, Harleysville, Pennsylvania (TA-W-
96,404C); and Nationwide Mutual Insurance Company, P&C Commercial Lines Processing,
Raleigh, North Carolina (TA-W-96,404D), who are engaged in activities related to the supply
of internal administrative support services for commercial line insurance policies meet the worker
group certification criteria under Section 222(a) of the Act, 19 U.S.C. § 2272(a). In accordance
with Section 223 of the Act, 19 U.S.C. § 2273, I make the following certification:

"All workers of Nationwide Mutual Insurance Company, P&C Commercial Lines
Processing, Des Moines, Iowa (TA-W-96,404); Nationwide Mutual Insurance
Company, P&C Commercial Lines Processing, Canton, Ohio (TA-W-96,404A)
Nationwide Mutual Insurance Company, P&C Commercial Lines Processing,
Gainesville, Florida (TA-W-96,404B); Nationwide Mutual Insurance Company, P&C

Commercial Lines Processing, Harleysville, Pennsylvania (TA-W-96,404C); and
Nationwide Mutual Insurance Company, P&C Commercial Lines Processing, Raleigh,
North Carolina (TA-W-96,404D), who became totally or partially separated from
employment on or after September 25, 2019 through two years from the date of
certification, and all workers in the group threatened with total or partial separation from
employment on the date of certification through two years from the date of certification,
are eligible to apply for adjustment assistance under Chapter 2 of Title II of the Trade Act
of 1974, as amended."

Signed in Washington, D.C. this 19th day of April, 2021.

/s/ Hope D. Kinglock
_______________________
HOPE D. KINGLOCK

Certifying Officer, Office of

Trade Adjustment Assistance