The Consent Order
The consent order is similar to the FLOIR letter, but the language of the order is stronger. For example, the letter says the plan may violate Florida's insurable interest law, but the order says the FLOIR "finds" that the plan "lacks insurable interest."
Also, the order focuses on Pollock's inability to identify the life insurance company that would have issued the policies. The order says:
[Pollock] was unable to provide [FLOIR] with the name of the life insurance company that would be issuing the life insurance policies for the proposed products. [Pollock] represented to [FLOIR] that it had not yet identified the life insurance company that would issue the policies.
[FLOIR] finds that, by marketing a life insurance product in Florida to insure Florida lives without being appointed by an insurance company authorized to provide the product in the state of Florida, [Pollock] and its employees, including Mark G. Pollock and William "Bill" Olive, transacted insurance in the state of Florida without complying with the Florida Insurance Code, in violation of Sections 624.11 and 624.401, Florida Statutes.
Pollock does not admit violating any laws. However, Pollock agrees to comply with Florida laws and cease and desist from marketing the plan or any similar plan to Florida consumers. Pollock waives its right to a hearing and waives its rights to contest the order in any forum available to it. Each party bears its own costs. (In the Matter of Pollock Financial Group, Florida Office of Insurance Regulation, Case No. 155737-14-CO.)
General Observations
I do not know how Pollock illustrated the results of the plan over many years when it did not know what company was going to issue the policies. Perhaps the illustrated numbers were imaginary numbers.
This is my fourth post about the "too good to be true" plan Pollock offered Pasco. The earlier posts were Nos. 43, 48, and 53. From the first my unsolicited advice to the district was to reject the plan.
In No. 48, I offered a complimentary 14-page Pasco package of documents. In No. 53, I offered a complimentary 15-page second Pasco package of documents. Now I am offering a complimentary eight-page PDF containing the consent order. Send an e-mail to jmbelth@gmail.com and ask for the third Pasco package. The first two Pasco packages are still available.