CLIENT ALLEGES MISREPRESENTATION OF A VARIABLE LIFE SALE

$2,235.00

I am no longer the representative on the account and have not been on the account or a John Hancock representative for the past 15 years. As noted on U-4 I was not named in this situation, although I was the agent that placed the policy 23 years ago. I feel very strongly that the VUL product was suitable for the client. Personally, I have been funding three of these John Hancock policies for last 20 plus years and pleased with the results. It was my understanding that the clients main objective was to keep this policy. Unfortunately, the policy lapsed as a result of the client's actions. The client informed me that he felt there was a lack of service and communication with John Hancock.

CLAIMANT ALLEGES THE REPRESENTATIVE RECOMMENDED IN JULY 2007 THAT SHE COULD TAKE LARGER SYSTEMATIC WITHDRAWALS THAN HER ACCOUNTS COULD REASONABLY SUPPORT AND THAT HER INVESTMENTS WERE MISREPRESENTED AND UNSUITABLE.

$110,000.00

I sincerely believe the allegations are unfounded and that all actions, activities and transactions performed by me were ethical, professional and in accordance with standards governing investment planning fundamentals and practices and the sale of investment related products. I believe that this matter was primarily due to a decline in the financial markets from the time the investments were purchased. At the time client stated withdrawals were not needed but insisted that the funds would be used to build up savings accounts and future travel. I emphasized that the lower the distributions the greater the probability of income longevity. While I affirm my position on the lack of merit in this case, the cost of defending this action would have surpassed the cost of settlement. Therefore, as a business decision, this diminutive settlement offer was extended and accepted.

CLAIMANT ALLEGES THE REPRESENTATIVE RECOMMENDED IN JULY 2007 THAT SHE COULD TAKE LARGER SYSTEMATIC WITHDRAWALS THAN HER ACCOUNTS COULD REASONABLY SUPPORT AND THAT HER INVESTMENTS WERE MISREPRESENTED AND UNSUITABLE.

THE CLIENT ALLEGES THE REGISTERED REPRESENTATIVE MISLED HIM REGARDING THE REIT INVESTMENTS HE PURCHASED IN SEPTEMBER 2004 AND MAY 2007.

THE FIRM'S INVESTIGATION FOUND NO EVIDENCE TO SUPPORT THE CLIENT'S ALLEGATIONS AND CONFIRMED THE CLIENT RECEIVED THE APPROPRIATE INFORMATION TO MAKE AN INFORMED DECISION.

A MEDIATION REQUEST WAS RECEIVED IN WHICH THE CLIENT ALLEGES THE REPRESENTATIVE SUGGESTED IN JULY 2007 SHE COULD TAKE LARGER SYSTEMATIC WITHDRAWALS THAN HER ACCOUNTS COULD REASONABLY SUPPORT.

THE FIRM FOUND NO EVIDENCE TO SUPPORT THE CLIENT'S ALLEGATIONS AND BELIEVES THE AMOUNTS WITHDRAWN WERE THE RESULT OF THE CLIENT'S OWN REQUEST. IT APPEARS THE COMPLAINT IS DUE TO CURRENT MARKET PERFORMANCE AND THE CLIENT'S LOSS OF EXPECTED FUTURE SOURCES OF INCOME FROM OTHER UNRELATED VENTURES. THE FIRM DENIED THE CLIENT'S REQUEST FOR MEDIATION.

THE CLIENT CLAIMS HIS OVERALL PORTFOLIO HAS DECLINED CONSIDERABLY AND ALLEGES THAT THE INVESTMENTS RECOMMENDED BY THE REPRESENTATIVE IN JULY 2007 AND SEPTEMBER 2007 WERE UNSUITABLE, INCONSISTENT WITH HIS INVESTMENT OBJECTIVES AND THE ASSOCIATED RISKS, ILLIQUIDITY AND SURRENDER PENALTIES WERE NOT FULLY DISCLOSED.

$75,000.00

I SINCERELY BELIEVE THE ALLEGATIONS ARE UNFOUNDED AND THAT ALL ACTIONS, ACTIVITIES AND TRANSACTIONS PERFORMED BY ME WERE ETHICAL, PROFESSIONAL AND IN ACCORDANCE WITH STANDARDS GOVERNING INVESTMENT PLANNING FUNDAMENTALS AND PRACTICES AND THE SALE OF INVESTMENT RELATED PRODUCTS. I BELIEVE THAT THIS MATTER WAS PRIMARILY DUE TO A DECLINE OF THE FINANCIAL MARKETS FROM THE TIME THE INVESTMENTS WERE PURCHASED. WHILE I AFFIRM MY POSITION ON THE LACK OF MERIT IN THIS CASE, THE COST OF DEFENDING THIS ACTION WOULD HAVE SURPASSED THE COST OF SETTLEMENT. THEREFORE AS A BUSINESS DECISION, THIS DIMINUTIVE SETTLEMENT OFFER WAS EXTENDED AND ACCEPTED.

THE CLIENT ALLEGED MISREPRESENTATION BECAUSE FACTS MATERIAL TO HIS PURCHASE OF A VARIABLE ANNUITY CONTRACT IN MARCH 2009 WERE EITHER MISSTATED OR OMITTED, A FAILURE TO DISCLOSE PENALTIES AND FEES AND THAT A PORTION OF THE ASSETS WERE MOVED TO A VARIABLE SUB-ACCOUNT WITHOUT HIS KNOWLEDGE.