Reliance Insurance Company, which had consented to the entry of an Order of Rehabilitation by the Commonwealth Court of Pennsylvania on May 29, 2001, and which was ordered by the court into liquidation on October 3, 2001, reached a Commutation, Settlement Agreement, and Release with its reinsurer, Munich Reinsurance America. The Settlement Agreement is dated December 29, 2008. The court approved the Settlement Agreement in an Order dated July 16, 2009, finding that the Agreement was in the best interests of the Reliance estate, as it allowed the liquidator (the Pennsylvania Insurance Commissioner) to terminate and commute the underlying contracts of reinsurance and give the estate $73.25 million. Ario v. Reliance Insurance Co., Case No. 269 M.D. 2001 (Pa. Commw. Ct. July 16, 2009).