Wednesday, February 24, 2021

No. 410: The Age 100 Problem Remains Alive and Well

My first article about the age 100 problem in cash-value life insurance was in the January 2001 issue of The Insurance Forum, my monthly newsletter that preceded this blog site. My first blog post on the subject was No. 141 (February 1, 2016).

The Age 100 Problem
The age 100 problem stems from the fact that cash-value life insurance policies are often sold as "permanent life insurance," "whole life insurance," or some other expression falsely suggesting that the life insurance protection will last for the insured's entire life. In fact, however, the protection lasts only until the policy's "terminal age." Today, many millions of cash-value life insurance policies are in force in the United States with a terminal age of 100. Thus the "whole life" policy is actually an endowment at age 100. Furthermore, cash-value life insurance policies are often sold with heavy emphasis on the facts that the "inside interest" is income-tax deferred and the death benefit is income-tax exempt.

Extended Maturity Riders
In No. 226 (July 20, 2017), I reported that some (but not all) companies had begun offering extended maturity riders (EMRs) to universal life policies. Here is language describing the EMR offered by Principal Life Insurance Company:
If the insured reaches the stated maturity age, maturity is extended to the date of his or her death. The rider is automatically added to policies in states where approved, and there is no charge for the rider. There will be no charges during the maturity extension period. However, loan interest will continue to be charged. No additional premium payments, other than loan payments, will be allowed.
At the time I was not aware of any companies offering EMRs on traditional whole life policies. Nor am I aware of any such offers today.

A New Mortality Table
As mentioned earlier, millions of policies now in effect are based on a mortality table that has a terminal age of 100. However, recent policies are based on a new mortality table that has a terminal age of 121. I have often asked, but no actuary has ever explained to me why it is impossible to issue a policy based on a mortality table that has no terminal age.

A 2018 Survey
In No. 277 (July 17, 2018), I reported on the results of a survey I conducted about the age 100 problem. I wrote to the chief executives of 22 life insurance companies asking some important questions about the age 100 problem. Nine of the companies acknowledged receipt of the survey in at least some fashion. However, some of the responses provided little or no information. I showed in detail the disappointing responses to the survey.

A Recent Email
Recently I received, out of the blue, an email from an individual with a family member who survived to age 100. The family member received a check for the face amount. Later the family member was hit with huge bills for federal and state income taxes, as well as penalties. Normally I would identify the company and provide other details. In this instance, however, I am choosing to protect the privacy of the individual and the family.

General Observations
Over the 20 years that I have been writing about the age 100 problem, it has become clear that life insurance officials are reluctant to discuss the problem. I think the reason is they fear that publicity about the problem might endanger the highly favorable income tax treatment of cash-value life insurance. Although there have been important developments, such as EMRs, progress has been slow. For example, no one has ever responded to the idea of using a 1035 exchange to replace a policy based on a mortality table containing a terminal age of 100 with a policy based on a mortality table containing a terminal age of 121. I would welcome comments from readers about the age 100 problem. Please send an email to


Thursday, February 11, 2021

No. 409: COVID-19 and Life Insurance Underwriting

The Consumer Federation of America (CFA) recently announced it had written to the National Association of Insurance Commissioners (NAIC) about COVID-19 and the underwriting of life insurance. The CFA sent copies of the letter to chief executives of several large life insurance companies based in the United States. The letter grew out of developments reportedly occurring in Europe. A week later, I asked the CFA whether it had received any replies. The CFA said no replies have been received as yet.

The CFA Announcement
The CFA announcement, dated January 29, 2021, is entitled "Recovered COVID-19 Patients Facing New Life Insurance Hurdles in Europe, Protections Needed for American Consumers." Here are the first, third, and fifth paragraphs of the announcement:
CFA sent a letter to the NAIC urging them to adopt a model rule for life insurance underwriters that might want to delay or deny coverage to people who had COVID-19 and recovered or had symptoms but no diagnosis. The letter is in response to recent reporting that some life insurers in Europe are already taking steps to delay or deny people life insurance coverage based on having contracted COVID-19 or suspected of it. Over 25.4 million Americans have already tested positive for the virus, according to The New York Times.
In Europe, some underwriters are imposing waiting periods before COVID-19 patients, even those who have recovered, can apply for coverage. Further, some insurers are limiting coverage for certain age groups as part of their response to the pandemic. Still others are postponing applications for anyone who had COVID-19 or lived with someone who got the disease.
CFA also sent the letter to the CEOs of the leading life insurance companies in America and their trade organization [American Council of Life Insurers, or ACLI] asking them to consider voluntary action to use transparent and reasonable underwriting rules relating to COVID.
My Letters
I will write soon by regular mail to the NAIC, the ACLI, the CEOs of a few of the life insurance companies to which the CFA wrote, and a few other CEOs. I will ask for their comments on the subject. I plan to post a follow-up report on the responses to my letters.

General Observations
I think this is a very important subject. Instead of offering a complimentary package of relevant material, as I normally do, I am providing here a link to the CFA letter to the NAIC.

I would welcome comments from readers on the subject. Please send your comments by email to Should you write to me, please identify yourself and indicate whether your comments may be used with or without attribution. I will honor your request.


Tuesday, February 2, 2021

No. 408: A Recent Change in the Federal Income Tax Law Designed to Benefit Wealthy Life Insurance Policyholders

On January 10, 2021, The Wall Street Journal posted online an article by reporter Leslie Scism entitled "A Small Tax Change Is a Boon for Permanent Life Insurance." The next day, the print edition of the Journal carried on page B8 a revised version entitled "Tax Change Aids Life Insurance." Here are the first few sentences of the latter article:
Federal lawmakers' big year-end spending package includes a little-noticed revision of the tax code that is likely to boost sales of life insurance, particularly for wealthy Americans. The law lowers a minimum interest rate used to determine whether combination savings and death benefit policies known as permanent life insurance are too much like investments to qualify for tax advantages granted to insurance. The interest-rate floor was put in place in 1984 to weed out policies that were mostly investment vehicles with a thin layer of life insurance. Lowering the rate allows owners to put more in the savings portion.
Here I discuss in more detail the federal income tax advantages of cash-value life insurance. I also provide further background on the history of the federal income tax definition of cash-value life insurance.

Federal Income Taxation of Life Insurance
To understand the implications of the recent change, it is necessary to understand the history of the 1984 change in the tax code. That was a time of high market interest rates, far different from today's low market interest rates. Also, it is necessary to understand two extremely important income tax advantages of cash-value life insurance: (1) the "inside interest" in a cash-value life insurance policy is income-tax deferred, and (2) upon the death of the insured person, the death benefit paid to the beneficiary is income-tax exempt.

The Minimum Deposit Plan
One of my early encounters with clever marketers of cash-value life insurance involved the "minimum deposit plan." It was also called "minnie dee" or "minnie dip." To illustrate, Jones bought a favorably priced $100,000 participating whole life policy in 1950 at age 35. He used the minimum deposit plan; that is, each year he paid as little as possible to keep the policy in force. He paid the annual premium, deducted any dividend, borrowed as much as possible under the automatic premium loan clause, paid interest on the policy loan, and on his income tax returns he took a deduction for the policy loan interest he paid. Thus he essentially converted the policy from a level premium, level death benefit, whole life policy with nondeductible premiums into a term policy with a decreasing death benefit and deductible premiums. Or so he thought.

At the end of 1972, after 22 years, Jones decided to end the policy by allowing it to lapse. At that point, the cash value and the amount of the loan were each around $40,000. His income tax return filed in 1973 for the 1972 tax year showed a large deduction for the policy loan interest he had paid in 1972 and had deducted on his tax return for 1972. However, his tax return for 1973 filed in 1974 showed no deduction for policy loan interest paid in 1973. That triggered an Internal Revenue Service audit, which resulted in a whopping tax bill with penalties, as though he had surrendered an old participating whole life policy, which was exactly what he had done.

The Emergence of Universal Life
During the 1960s and 1970s, I often wrote about the need for rigorous disclosure of the price of the life insurance protection component of cash-value life insurance policies, and the need for rigorous disclosure of the rate of return on the savings component of those policies. In my writings, I viewed cash-value life insurance as a combination of a protection component and a savings component. It is a major understatement to say that the life insurance industry was not happy with my writings.

In the late 1970s, market interest rates were high and rising, and universal life insurance—which was also referred to as flexible-premium life insurance—burst on the scene. I will never forget a letter I received in 1979 from an official of one of the companies promoting universal life. He said: "Joe, I hope you're satisfied." The reason for his comment was that one of the claimed advantages of universal life was so-called transparency; that is, the separation of the protection and savings components. Unfortunately, while transparency sounded good, it did not provide adequate disclosure of the price of the protection component and the rate of return on the savings component. Instead, it created a new family of deceptive sales practices.

An Example of Universal Life Deception
In the May 1984 issue of my monthly newsletter, The Insurance Forum, I wrote an article entitled "How Not to Advertise Universal Life." The article focused on a deceptive newspaper advertisement by Indianapolis-based Golden Rule Insurance Company. The article, including a replica of the advertisement, is in the complimentary package offered at the end of this post.

The 1984 Change in the Tax Law
I asked representatives of the American Council of Life Insurers (ACLI), which had lobbied for the 2021 change in the tax law, whether they could provide me with material about the 1984 change. They said they could not locate any such material. Therefore, I will describe what happened, based on my memory.

As market interest rose in the 1970s, clever promoters of life insurance often sold their wealthy clients on the idea of buying a small universal life policy and pouring a large amount of money into the policy in order to benefit from the income-tax deferred inside interest and the income-tax exempt death benefit. That abuse of the income tax system became too much for the Internal Revenue Service and Congress to tolerate. Thus a change was made in the tax code in 1984 to define life insurance in such a way as to prevent the abuse. The tax law was amended to make such an arrangement subject to taxation as an ordinary investment rather than as a life insurance policy.

The 2021 Change in the Tax Law
Today, however, low market interest rates have threatened the viability and the very survival of cash-value life insurance. Thus the life insurance industry, through the ACLI, lobbied Congress to change the definition of life insurance in the tax code in such a way as to preserve cash-value life insurance as a viable financial instrument.

The definition in the new tax provision requires a policy to pass at least one of two tests in order to qualify as life insurance for tax purposes: a cash-value accumulation test (CVAT), or a guideline-premium test (GPT). If a policy fails both tests, the policy is called a modified endowment contract (MEC), and is taxed as an investment vehicle rather than as a life insurance policy. A statement by the ACLI about the 2021 change is in the complimentary package at the end of this post, along with a statement by Bobby Samuelson, editor of The Life Product Review and a nationally-recognized expert on policy design.

General Observations
The January 2021 change in the income tax law, as lobbied for by the ACLI, is an important development in the history of the life insurance business. In this post, I do not attempt to explain the complex changes in the income tax law. However, I urge readers to request the complimentary 14-page package offered below.

Available Material
I am offering a complimentary 14-page PDF consisting of the May 1984 Forum article (2 pages), the ACLI statement on the 2021 tax changes (3 pages), and the Samuelson statement on those changes (9 pages). Email and ask for the February 2021 package about the changes in the income tax law relating to cash-value life insurance. 


Monday, January 25, 2021

No. 407: Security Life of Denver Is the Defendant in an Ongoing 2018 Cost-of-Insurance Class Action Lawsuit

The July 2018 Complaint
On July 26, 2018, Advance Trust & Life Escrow Services (Advance Trust) filed a cost-of-insurance class action lawsuit against Security Life of Denver Insurance Company (Security Life), a subsidiary of Voya Financial, Inc. (Voya). The complaint contains a single count of breach of contract. The complaint is in the complimentary package offered at the end of this post. On August 28, 2018, Security Life answered the complaint. (See Advance Trust v. Security Life, U.S. District Court, District of Colorado, Case No. 1-18-cv-1897.)

The Judge
The case is in the hands of U.S. District Court Judge Daniel D. Domenico. President Trump nominated him in January 2019. The Senate confirmed him in April 2019 by a vote of 55-42 along party lines.

Advance Trust's Motion to Certify a Class
On August 23, 2019, Advance Trust filed a motion to certify a class. On April 13, 2020, after extensive briefing, the judge denied without prejudice Advance Trust's motion to certify a class.

Security Life's Motion for Summary Judgment
On July 22, 2020, Security Life filed a motion for summary judgment. Interestingly, Security Life said in its motion that Advance Trust is a securities intermediary for Life Partners Position Holders Trust (Trust), which owns five universal life insurance policies originally issued by Security Life, and that the Trust is a successor owner, through bankruptcy, of a company that purchased the policies from the original policyholders in the secondary market. Brian Pardo's Life Partners Holdings, Inc. filed for bankruptcy protection on January 20, 2015. See, for example, No. 81 (January 22, 2015). Security Life's motion for summary judgment is in the complimentary package offered at the end of this post.

The Judge's Order
On January 6, 2021, after extensive briefing, the judge granted Security Life's motion for summary judgment in part, denied the motion in part, and preliminarily certified a class of policyholders. The judge's order, which prompted me to prepare this post, is in the complimentary package offered at the end of this post.

General Observations
Despite the fact that this case is in its 18th month, it still has a long way to go. Fairly soon we should learn what the members of the class will be told when they are notified of the existence of the lawsuit. Farther down the road, we will probably learn what type of settlement may be reached. I plan to follow developments in the case.

Available Material
I am offering a complimentary 71-page PDF consisting of the July 2018 complaint (26 pages), Security Life's motion for summary judgment (21 pages), and the judge's January 2021 order (24 pages). Email and ask for the January 2021 package relating to the case of Advance Trust v. Security Life.


Friday, January 8, 2021

No. 406: Genworth and Oceanwide—Recent Developments

The January 4 Genworth/Oceanwide Update
On October 21, 2016, Genworth Financial Inc, (Genworth) entered into a merger agreement with China Oceanwide (Oceanwide). Since then, the parties have entered into "waiver agreements," under which the parties extended the "end date" in the merger agreement. On October 1, 2020, Genworth said the parties had entered into a 16th waiver agreement under which they extended the end date to December 31, 2020. On January 4, 2021, Genworth and Oceanwide issued an update in which they said in part (the full update is in the complimentary package offered at the end of this post):
Given uncertainty around the completion and timing of the remaining steps required to close the transaction, Genworth and Oceanwide have not extended the current December 31, 2020 "end date" under the merger agreement. Oceanwide has indicated that the factors contributing to the delay since the parties agreed to their most recent extension of the merger agreement on November 30, 2020, were: (a) the finalization of the Hony Capital financing terms; and (b) the COVID-19 pandemic and associated restrictions. However, the merger agreement remains in effect, although either party is able to terminate the merger agreement at any time. Genworth has shared that it will continue to work towards closing the transaction, and Genworth remains open to completing the transaction if Oceanwide completes the remaining steps.
The January 4 Genworth News Release
On January 4, Genworth issued a news release announcing it will hold a special topics call with Genworth's CEO on January 5 at 8:00 a.m. to discuss the recent update relating to Oceanwide. Genworth said a replay of the call will be available until January 19 at (888) 203-1112 (U.S.) or (719) 457-0820 (outside the U.S.) The conference ID is # 3039080. The webcast will also be archived on the company's website for one year.

The January 4 Genworth 8-K Report
On January 4, Genworth filed an 8-K (significant event) report with the Securities and Exchange Commission. Among other things, the above mentioned January 4 Genworth/Oceanwide Update was included.

Available Material
I am offering a complimentary 8-page PDF consisting of the January 4 Genworth/Oceanwide Update (6 pages) and the January 4 Genworth News Release (2 pages). Email and ask for the January 2021 package relating to Genworth and Oceanwide.


Wednesday, January 6, 2021

No. 405: American National and Lincoln Benefit Are the Defendants in Two Similar Class Action Lawsuits

American National Insurance Company (ANIC) and Lincoln Benefit Life Company (LBL) are the defendants in two similar class action lawsuits. The cases were filed in December 2020 by the same plaintiffs' attorneys, and in the Central and Eastern federal district courts in California. The cases are discussed briefly in this post.

The Complaint Against ANIC
The complaint against ANIC was filed on December 10. The named plaintiffs are Myra Steen and Janet Williams. Here are portions of the "Nature of the Case" section of the complaint:
Since January 1, 2013, ANIC and other related entities have systematically and purposely failed to provide certain classes of policy owners, insureds, assignees and others, proper notices of pending lapse or termination. ANIC has failed to notify thousands of policy owners of their right to designate someone to receive critical notices and information regarding life insurance despite being required to do so on an annual basis. All of these important safeguards are required by, among other sources, California Insurance Code Sections 10113.71 and 10113.72. California law requires strict compliance with these safeguards and ANIC refuses to comply.
As a result, ANIC has failed to properly administer policies, evaluate the status of payments due under policies and pay claims to beneficiaries for policies improperly lapsed or terminated. Indeed, thousands of policy owners and beneficiaries have lost, and continue to lose, the benefit, value and security of their life insurance; have been, and continue to be, forced into unnecessary reinstatements; and in many instances have lost all reasonable access to any insurance at all.
The complaint against ANIC includes four counts: two counts seeking declaratory judgment relief, one count for breach of contract, and one count of unfair competition under California law. The full complaint against ANIC is in the complimentary package offered at the end of this post. (See Steen v. ANIC, U.S. District Court, Central District of California, Case No. 2:20-cv-11226.)

The Complaint Against LBL
The complaint against LBL was filed on December 16. The named plaintiff is Deana Farley. Much of the language in the complaint against LBL is similar or identical to the language in the complaint against ANIC. The full complaint against LBL is in the complimentary package offered at the end of this post. (See Farley v. LBL, U.S. District Court, Eastern District of California, Case No. 2:20-cv-2485.)

My Email to Craig Nicholas
Craig M. Nicholas of the San Diego firm of Nicholas & Tomasevic is one of the plaintiffs' attorneys who signed the complaints in the ANIC and LBL cases. On December 28, I sent Nicholas an email. After identifying myself, I asked two questions: first, whether he is aware of other similar lawsuits filed against insurance companies, and, if so, to identify them; and second, whether he anticipates further similar cases, and, if so, to identify them when they are filed. I gave him my telephone number if he wished to speak with me. I asked him to respond to my email by 5:00 pm Eastern time on January 4. I received no reply.

General Observations
The ANIC and LBL cases are similar or identical to one another in many respects. Also, the cases contain serious allegations of wrongdoing. Finally, it is interesting that the cases were filed only a few days apart in different federal district courts in California. I perused lists of cases in the other two California districts—the Northern and Southern districts—to see if I could spot any other similar cases. I did not see any other similar cases. I plan to write further about these cases.

Available Material
I am offering a complimentary 52-page PDF consisting of the complaint in the ANIC case (28 pages) and the complaint in the LBL case (24 pages). Email and ask for the January 2021 package about the ANIC and LBL cases.


Wednesday, December 23, 2020

No. 404: Executive Compensation in the Insurance Industry—2019 Data from the Nebraska Department of Insurance

Beginning in 1975, in many issues of The Insurance Forum, I provided tabulations of executive compensation data in the insurance industry. The final tabulation was in the July 2013 issue, because the Forum ended with the December 2013 issue. From time to time since then, I have posted some executive compensation data on my blog. Recent tabulations include No. 335 (October 3, 2019), where I showed 2018 data from my three sources of information: the Securities and Exchange Commission (SEC), the New York State Department of Financial Services (DFS), and the Nebraska Department of Insurance (NDI). In No. 381 (July 13, 2020), I showed 2019 data from the SEC. In No. 385 (August 7, 2020), I showed 2019 data from the DFS. Here I show 2019 data from the NDI.

NDI Data for 2019
NDI data are in a "Supplemental Compensation Exhibit" (Exhibit) filed by each insurance company doing business in Nebraska. Each Exhibit normally shows figures for the ten top company officials. The figure I show for each individual is the "total." Components of the "total" are "salary," "bonus," "stock awards," "option awards," "sign-on payments," "severance payments," and "all other compensation." NDI provides all the Exhibits on a CD to any member of the public for $80.

In the tabulation below, I show data for individuals who received at least $5 million in 2019. Where two or more individuals in a company are shown, they are listed in descending order of compensation.

The Allocation Problem and a Modification
Where companies are members of a holding company group, some companies show the total amount received by each individual from all companies in the holding company group. Some companies, however, allocate each individual's compensation to each company in the holding company group.

For companies that allocate, the difficulty in locating all companies doing business in Nebraska that are part of a holding company group has become increasingly prohibitive. For that reason, I have modified the tabulation shown below from past years in that this year I did not attempt to assemble the group data. I have instead shown the figures for the company with the largest dollar amounts for each group.

For some individuals listed below, because of the modification, the compensation figure shown is smaller, and in some instances probably much smaller, than the individual's total compensation from all members of the holding company group. Also, because of the modification, some companies probably are not listed because no individual had at least $5 million of compensation from a single company in their group.

NDI Data for 2019
Acuity, A Mutual Ins Co
Benjamin M Salzmann
Aetna Life Ins Co
Richard M Jelinek
Karen S Lynch
Daniel P Amos
Frederick J Crawford
Allianz Life Ins North America
Walter R White
Allstate Ins Co
Thomas J Wilson
Steven E Shebik
AMBAC Assurance Corp
Claude LeBlanc
American Family Ins Co
Jack C Salzwedel
American General Life Ins Co
Kevin Hogan
American United Life Ins Co
James S Davison
Amguard Ins Co
Sy Foguel
Assured Guaranty Corp
Dominic Frederico
Assurity Life Ins Co
Thomas E Henning
Athene Annuity & Life Assur Co
James Belardi
Atlantic Specialty Ins
Timothy M Miller
AXA Equitable Life Ins Co
Mark Pearson
BCS Ins Co
Howard F Beacham III
Brighthouse Life Ins Co
Eric T Steigerwalt
Care Improvement Plus of Texas
Janice Clayton Zigler
Chicago Title Ins Co
Raymond Randall Quirk
Roger Scott Jewkes
Michael Joseph Nolan
Anthny John Park
Chubb Indemnity Ins Co
John J Lupica
Paul J Krump
Continental Casualty Co
Dina Robusto
Employers Assurance Co
Douglas Dean Dirks
Essent Guaranty Inc
Mark Casale
Everest Reinsurance Co
Dominic J Addesso
Juan C Andrade
Farmers Ins Exchange
Jeffrey J Dailey
First American Title Ins Co
Dennis Gilmore
GEICO Casualty Co
Olza Minor Nicely
William Evan Roberts
Genworth Life Ins Co
Thomas McInerney
Globe Life & Accident Ins Co
Frank M Svoboda
William M Pressley
Bill E Leavell
Great American Ins Co
Carl H Lindner III
Great-West Life Assur Co (US)
Robert Shaw
Andra S Bolotin
Edmund F Murphy
Guardian Life Ins Co of America
Deanna Mulligan
Tracy L Rich
Hartford Fire Ins Co
Christopher Swift
Health Care Service Corp
Paula Steiner
Eric Feldstein
David Lesar
Horace Mann Ins Co
Marita Zuraitis
Humana Ins Co
Bruce D Broussard
Illinois Ins Co
Steven Menzies
Insurance Co of the West
Kevin Prior
Ernest Rady
Jackson National Life Ins Co
Paul C Myers
John Hancock Life Ins Co USA
Daniel Janis III
Emory Sanders Jr
Christopher Conkey
Liberty Mutual Ins Co
David H Long
Timothy Sweeney
Lincoln National Life Ins Co
Dennis R Glass
Randal J Freitag
Wilford H Fuller
Ellen G Cooper
Lisa M Buckingham
Massachusetts Mutual Life Ins Co
Roger Crandall
Elizabeth Chicares
Michael Fanning
Melvin T Corbett
Metropolitan Life Ins Co
Michel Khalaf
Steven J Goulart
Mortgage Guaranty Ins Corp
Patrick Sinks
National Western Life Ins Co
Ross R Moody
National Life Ins Co
Mehran Assadi
New York Life Ins Co
Theodore A Mathas
Craig L DeSanto
Anthony R Malloy
Northwestern Mutual Life Ins Co
John E Schlifske
Ohio National Life Ins Co
Gary Thomas Huffman
Pacific Life Ins Co
James T Morris
Penn Mutual Life Ins Co
Eileen McDonnell
Philadelphia Indemnity Ins Co
Robert D O'Leary
Principal Life Ins Co
Karl W Nolin
Daniel J Houston
Mustafa Sagun
Protective Life Ins Co
John Johns
Richard Bielen
Prudential Ins Co of America
Mark Brown Grier
Charles F Lowrey
Robert Michael Falzon
Stephen Pelletier
QCC Ins Co
Daniel J Hilferty
Radian Guaranty Inc
Richard Thornberry
Sagicor Life Ins Co
Dodridge Miller
Scor Reinsurance Co
Mark Kociancic
Selective Ins Co of America
Gregory Murphy
Standard Ins Co
John Gregory Ness
Starr Indemnity & Liability Co
Maurice R Greenberg
State Farm Mutual
Michael Leon Tipsord
Teachers Ins & Annuity Assn
Ronald Pressman
Roger Ferguson
Thrivent Financial for Lutherans
Bradford L Hewitt
Transatlantic Reinsurance Co
Michael C Sapnar
Kenneth Apfel
Travelers Casualty Co
Alan D Schnitzer
Willaim H Heyman
Avrohom J Kess
Jay S Benet
United of Omaha Life Ins Co
James T Blackledge
United States Liability Ins Co
Thomas P Nemey
Voya Retirement Ins & Annuity
Charles Patrick Nelson
Western & Southern Life Ins Co
John Barrett