THE SALE OF THE REIT WAS UNSUITABLE.

$20,000.00

THE ORIGINAL "COMPLAINT" WAS VAUGE, CLAIMED NO DAMAGES & DID NOT REQUEST SETTLEMENT. WHILE RESEARCHING THE DETAILS OF THE COMPLAINT, THE CLIENT REQUESTED FULL LIQUIDATION OF HER NON-TRADED REIT. THE PRODUCT SPONSOR REDEEMED UNITS AT 60% OF FACE VALUE & AGRD TO CONTRIBUTE $10,000 TOWARDS SETTLEMENT. AS AN ALTERNATIVE TO EXPENSIVE ARBITRATION, SFA AGREED TO PAY THE REMAINING $10,000 OF WHICH THE REP PAID $3,700. THE ORIGINAL TRANSACTION WAS PROPER AND SUITABLE AND ANY COMPLAINT WAS WITHOUT MERIT.

CUSTOMER ALLEGES THAT THERE WAS A FAILURE TO IMPLEMENT CONSERVATIVE GOALS WHEN HE TRANSFERRED FROM TWO EXISTING VARIABLE ANNUITIES TO TWO NEW VARIABLE ANNUITIES.

$70,513.00

THE CUSTOMER'S ALLEGATION IS WITHOUT MERIT. THE CUSTOMER'S GOALS WERE THE GOALS HE CHOSE TO IMPLEMENT. THE PORTFOLIO WAS CONSISTENT WITH HIS PRIMARY INVESTMENT OBJECTIVE, ON WHICH HE SIGNED OFF AT THE TIME OF TRANSFER. ADDITIONALLY, AT THE TIME OF TRANSFER HE EXPRESSED A DESIRE TO AND WAS COMFORTABLE WITH CONTINUING TO MAINTAIN A PORTFOLIO SIMILAR TO THE ONE THAT HE HAD. HIS REASONS FOR TRANSFERRING VARIABLE ANNUITIES WERE UNRELATED TO HIS PORTFOLIO. THEY WERE RELATED TO IMMEDIATE ACCESS TO THE GUARANTEE OF DEATH BENEFITS AT THE CONTRACT VALUES OF $193,343.85 AND $32,975.89, RESPECTIVELY, AND FOR THE OPPORTUNITY FOR THESE DEATH BENEFITS TO INCREASE AT A COMPOUNDING RATE OF 5% PER YEAR WITHOUT REGARD TO CHANGES IN UNDERLYING ACCOUNT VALUES. BY COMPARISON HE WAS GIVING UP A DEATH BENEFIT GUARANTEE OF $71,000 OR CURRENT MARKET VALUE AND NO MEANS OF BEING ABLE TO INCREASE HIS DEATH BENEFIT GUARANTEE, ANNUALLY OR OTHERWISE. THE ALLEGATION MADE BY THE CUSTOMER IS CONTRARY TO THE CONDUCT THAT THE CUSTOMER EXHIBITED AT THE TIME OF TRANSFER.