The allegations read: Failure to file trade name being used with the insurance commissioner; owes income taxes with the state; use of deceptive/fraudulent scheme to sell deferred annuities; induced the replacement of annuities at the detriment of clients; failure to determine the suitability of transactions; twisting; misrepresentations of and failure to dislcose material aspects of transactions; alteration of client applications after client executed said documents; false completion of applications and associated material by misrepresenting age, reasons for replacements, and surrender penalties; purchasers receive no benefit from transactions yet $244,701 in surrender penalities incurred while representative generated $245,793 in commissions.
