Client alleges that Registered Representative over-concentrated her portfolio in an unsuitable investment. Date of Activity: 10/29/14 to 4/22/20

$20,000.00

$6,500.00

Client alleges that due to an oversight Registered Representative submitted paperwork to sponsor that did not include supplemental rider. Date of Activity - 7/21/17 to 8/12/19

$5,000.00

$75,000.00

THE CLIENT ALLEGES THAT THE HARTFORD VARIABLE UNIVERSAL INSURANCE POLICY SHE PURCHASED IN 2007 WAS NOT A SUITABLE INVESTMENT.

$30,000.00

I WAS NOT THE ONLY ADVISOR PRESENT IN THE INITIAL MEETINGS OF SETTING UP THE CLIENT'S PLAN. ANOTHER WOODBURY FINANCIAL ADVISOR, WHOM SHE HAD MENTIONED IN HER LETTER, WAS ALSO PRESENT AT THE TIME. SINCE THEN I HAVE CHANGED BROKER DEALERS AND I AM NOW WITH H. BECK, INC. OUT OF BETHESDA MARYLAND. ESSENTIALLY THE FACTS OF OUR INITIAL PLANNING LEAD US TO BELIEVE A DIFFERENT SUMMARY THAN WHAT THE CLIENT HAS OUTLINED REGARDING THE PURCHASE OF THE HARTFORD LIFE INSURANCE POLICY. THE POLICY IN QUESTION IS A VARIABLE UNIVERSAL LIFE INSURANCE CONTRACT THAT HAS EXPOSURE TO THE STOCK MARKET AND IS LISTED AS A SECURITY WHICH ADDITIONALLY REQUIRES, AS I'M SURE YOU'RE AWARE, A SUITABILITY STANDARD REVIEWED BY THE BROKER DEALER TO BE APPROVED, IN THIS CASE WOODBURY FINANCIAL. OUR ORIGINAL DISCUSSIONS GAVE US THE IMPRESSION THAT, IN HER OWN WORDS, HER BUSINESS WAS FLOURISHING AND THAT SHE COULD SAVE ABOUT TWENTY THOUSAND DOLLARS A YEAR. WE RECOMMENDED THE USE OF THE INSURANCE CONTRACT NOT ONLY FOR THE DEATH BENEFIT, OF WHICH SHE HAD NONE AT THE TIME, BUT AS AN ADDITIONAL SUPPLEMENT TO HER INCOME PROGRAM. WITH HER EXISTING PORTFOLIO WE CHOSE TO USE AN INITIAL $30,000 CONTRIBUTION WITH $15,000 FOR FUTURE PREMIUMS, WHICH WOULD HAVE EASILY SATISFIED THE PROGRAM. ALSO, THE CONTRACT IS A VARIABLE CONTRACT; THE PREMIUMS ARE FLEXIBLE AND CAN BE ADJUSTED YEAR TO YEAR. WE ALSO HAD TAKEN OVER HER EXISTING ROTH INVESTMENTS THAT SHE REFERRED TO AS WELL AND TO KEEP MAKING THE ONGOING CONTRIBUTIONS WHICH SHE HAS DONE. WE ALSO PROPOSED EXCHANGING HER EXISTING IRA WHICH WAS IN ALL EQUITIES TO A JACKSON NATIONAL ANNUITY AND GAVE HER THE SAME EQUITY POSITION BUT SIGNIFICANTLY REDUCED HER FUTURE INCOME RISK AND WOULD PROVIDE THE RETIREMENT INCOME THAT SHE HAD MENTIONED SHE WAS SEEKING. MY REASON FOR BRINGING UP THIS ADDITIONAL INFORMATION IS TO POINT OUT THAT THE INSURANCE CONTRACT WAS NOT THE ONLY DIRECTION WE WERE RECOMMENDING AND THAT THE CLIENT HAS REASONABLE INVESTMENT KNOWLEDGE AND EXPERIENCE. IN THE FALL OF 2010 WE CHANGED OUR BROKER DEALER AND ON JANUARY 11, 2011, WE MAILED THE CLIENT A BROKER DEALER CHANGE FORM WHICH SHE DID NOT RETURN TO US. WE DROPPED OFF THE SAME CHANGE OF BROKER DEALER FORMS TO BE SIGNED IN JANUARY 2012 AND SHE ELECTED NOT TO RETURN THE FORMS. THIS PRESENTED A SIGNIFICANT PROBLEM SINCE IT LIMITED ACCESS OF ANY INFORMATION TO HER PLANS, TO US AND THEREFORE, I COULD NO LONGER ADVISE HER. OUR MEETING IN JUNE 2012 WAS AN EFFORT ON MY PART TO HELP HER DISCUSS OPTIONS REGARDING HER CONTRACT WITH THE HARTFORD, EVEN THOUGH I WAS NO LONGER THE REPRESENTATIVE OF THE CONTRACT. THE CLIENT STATED THAT AT THE END OF OUR MEETING THAT I OFFERED TO SEEK ARBITRATION FOR HER, WHICH WAS NEVER STATED. WHAT I SAID WAS THAT THE HARTFORD WOULD PURSUE HER REQUEST. SUBSEQUENTLY, SHE CALLED ME A LIAR, WHICH I TOOK AS BEING SUMMARILY DISMISSED AND REMOVED MYSELF FROM HER HOME WITHOUT ANY FURTHER COMMUNICATION. IN HER COMPLAINT THE CLIENT MENTIONED THAT IT WAS NEVER HER INTENT TO BUY INSURANCE OR PAY PREMIUMS. I WOULD DISAGREE WITH THAT CONTENTION. SHE INITIALLY STATED THAT SHE WOULD LIKE TO INVEST UP TO $20,000 ANNUALLY. OUR SUGGESTION WAS TO PUT $30,000 OF INITIAL CONTRIBUTION IN THE VARIABLE LIFE POLICY WITH ADDITIONAL PAYMENTS OF $15,000 ANNUALLY. SHE KNEW THIS WAS INSURANCE AND THAT ADDITIONAL PAYMENTS WOULD BE REQUIRED. SHE UNDERWENT A MEDICAL EXAMINATION, RECEIVED A PROSPECTUS AND SIGNED AN APPLICATION AND ILLUSTRATIONS. THE CLIENT SUGGESTS THAT BECAUSE SHE WAS A SENIOR CITIZEN THAT WAS BEING TAKEN ADVANTAGE OF. IN FACT, AT THE TIME OF OUR INITIAL MEETING, SHE WAS 57, RUNNING HER OWN BUSINESS AND HAD PRIOR INVESTMENT EXPERIENCE.

CLIENTS ALLEGE THE MFS SELECTED BY THE AGENT WERE INAPPROPRIATE FOR SHORT TERM INVESTMENT. CLIENTS FURTHER ALLEGE THEIR 2000 ISSUE VL INSURANCE POLICY WAS NOT SET UP APPRPRIATELY WITH DOLLAR COST AVERAGING. CLIENTS REQUEST ASSISTANCE BUT DID NOT SPECIFY ANY AMOUNT OF DAMAGES.

$27,964.47

CLIENT ALLEGES THE AGENT WORKED DIRECTLY WITH HER HUSBAND AND SUPPLIED HIM THE NECESSARY FORMS TO MAKE WITHDRAWALS WITH THE KNOWLEDGE THAT SHE HAD NOT GRANTED POWER-OF-ATTORNEY TO EXECUTE TRADES OR CONDUCT BUSINESS IN HER ACCOUNT. CLIENT REQUESTED THE RETURN OF $21,500.

$21,500.00

AFTER A THOROUGH REVIEW THE FIRM DETERMINED THAT I HAD NO PART IN THE ALLEGED WRONGDOING. ANY WRONGFUL ACTIVITIES APPEARED TO BE THOSE OF CUSTOMER'S HUSBAND.

COUNSEL ALLEGES THE SALE OF FOUR (4) VARIABLE ANNUITY CONTRACTS WERE UNSUITABLE. COUNSEL REQUESTED THE FIRM TO WAIVE EARLY WITHDRAWAL PENALTIES AND FORGIVE THE LOAN INTEREST AMOUNT. DAMAGES ARE UNSPECIFIED.

EQUITABLE FOUND NO BASIS TO THE CUSTOMER COMPLAINT.