09/2007-09/2007; CLIENTS STATE THEY REPLACED WHOLE LIFE POLICIES ($18,000.00) THAT WERE GUARANTEED AS TO PREMIUM AND DEATH BENEFITS TO A NEW HARTFORD LIFE POLICY (IN SEPT. 2007). CLIENTS ALLEGE THEY TOLD THE FA THEY DID NOT WANT AN INVESTMENT THAT DID NOT HAVE A FIXED RATE. CLIENTS FURTHER ALLEGE THE FA INFORMED THEM THE HARTFORD LIFE POLICY WAS GUARANTEED NEVER TO CANCEL IF THE PREMIUMS WERE PAID AND THEY WERE ALSO ADVISED THE DEATH BENEFIT WOULD NEVER CHANGE. THE CLIENTS STATE THEY WERE ADVISED THE VARIABLE POLICY HAD AN INVESTMENT SIDE THAT WOULD GROW CASH VALUES MUCH FASTER THAN THE WHOLE LIFE POLICIES, BUT THEY WERE NEVER TOLD THAT THE $18,000.00 WOULD DECREASE TO APPROXIMATELY ONE-THIRD OF THE ORIGINAL VALUE. CLIENTS STATE THEY HAVE RECENTLY DISCOVERED THE POLICY HAS A NO LAPSE GUARANTEE FOR 20 YEARS AND IF THE CASH VALUE CONTINUED TO DEPLETE THEY WOULD HAVE TO PAY A HIGHER PREMIUM OR LOSE THE POLICY. CLIENT ALLEGES THIS IS NOT HOW THE POLICY WAS SOLD - THEY WERE NEVER TOLD THAT THE PREMIUM COULD CHANGE OR THEY WOULD RISK LOSING THE POLICY. CLIENTS REQUEST THAT THE ORIGINAL WHOLE LIFE POLICIES BE RESTORED AND IF THAT CANNOT HAPPEN THEY WANT TO CANCEL THE EXISTING POLICIES AND RECEIVE A FULL REFUND OF THE PREMIUM. LOSSES APPEAR TO BE APPROXIMATELY $12,000.00 - FILING REQUIRED.

$5,000.00

THE POLICY WAS ISSUED ON 01/18/08. THE POLICY PROJECTED A SIGNIFICANTLY HIGHER DEATH BENEFIT THAN THE WHOLE LIFE POLICIES THAT WERE BEING REPLACED. ACCORDING TO THE FA, THE CLIENTS WERE FULLY AWARE OF THE VARIABLE COMPONENT OF THE HARTFORD POLICY. HE HAS INDICATED HE WOULD HAVE EXPLAINED THE POTENTIAL FOR FLUCTUATION IN THE VALUE OF THE POLICY AND THAT THE PERFORMANCE OF THE POLICY IS BASED ON THE UNDERLYING SUB-ACCOUNTS. IT IS UNDERSTOOD THE CLIENTS WERE ALSO ADVISED THERE WOULD BE A NEW SURRENDER PERIOD AND THAT THE NEW POLICY CONTAINED A NO LAPSE GUARANTEE FOR TEN YEARS. THE CLIENTS SIGNED A REPLACEMENT: LIFE TO LIFE INSURANCE ACKNOWLEDGEMENT LETTER IN WHICH THEY ACKNOWLEDGED THEIR UNDERSTANDING THAT THERE WERE NO GUARANTEES THAT THE PERFORMANCE OF THE NEW POLICY WOULD BE THE SAME OR BETTER THAN THE POLICY BEING REPLACED. IN ADDITION, THEY ALSO ACKNOWLEDGED THERE MAY BE AN INCREASE IN THE ANNUAL PREMIUM PAYMENTS IN ORDER TO MAINTAIN THE DEATH BENEFIT. THE CLIENTS ALSO COMPLETED AN APPLICATION IN WHICH THEY INDICATED THEIR UNDERSTANDING THAT THE AMOUNT OF THE DEATH BENEFIT MAY VARY BASED ON THE PERFORMANCE OF THE UNDERLYING INVESTMENTS AND, AS A RESULT, THE POLICY VALUE MAY FLUCTUATE. IN ADDITION, THEY ALSO SIGNED ILLUSTRATION(S) WHICH PROVIDE INFORMATION RELATED TO THE POLICY INCLUDING THE NO LAPSE GUARANTEE PROVISION AS WELL INFORMATION OTHER INFORMATION RELATED TO THE POLICY. IT IS OUR OPINION THE POLICY WAS PURCHASED WITH THE CLIENTS' KNOWLEDGE AND AUTHORIZATION. IN ADDITION TO THE INFORMATION PROVIDED BY THE FA, THE CLIENTS ALSO SIGNED AN ACKNOWLEDGEMENT LETTER, APPLICATION, AND ILLUSTRATION(S). OUR RECORDS REFLECT THE POLICY WAS DELIVERED TO THE CLIENTS AS EVIDENCED BY THE DELIVERY RECEIPT SIGNED ON JANUARY 30, 2008. AS A RESULT OF OUR REVIEW, WE ARE RESPECTFULLY DENYING THE CLIENTS REQUEST FOR A REFUND OF THE PREMIUMS PAID.