The allegations read: The insurance commissioner of washington state received a complaint alleging that the licensee: 1) engaged in "twisting," by misrepresenting the terms and benefits of two annuities in order to induce two washington consumers, husband and wife, to replace and surrender two existing annuities to purchase new ones, resulting in large surrender charges; 2) sold the husband and wife two unsuitable annuities by misrepresenting the terms and benefits of these annuities in violation of rcw 48.30.180, rcw 48.17.530(1)(h), rcw 48.17.530 (1)(e), rcw 48.23.015(2)(a), wac 284-023-390(2), and rcw 48.17.530(1)(b).