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Do you have a compliance professional in your firm to adress this with? If you are an independent, perhaps the institute has a “hotline” that can address this more conclusively. I believe this thread has actually done a pretty good job of the task, and if I were you I would lean against doing it based on what has been pointed out. It appears your client has hired you to cover its bases and follow the letter of the low and not the spirit. The fact that a judge is involved (and you should know these circumstances pretty well to proceed cautiously) raises flags. Even more flags are raised in my eyes from a simple circumstance: the prospective annuitant actually does not have a retained financial planner, and is therefore either (1) a layman being sold a product and has not been alerted that he/she needs to have one involved or (2) someone who believes self to be fairly up to the task. The fact that a judge has been involved raises suspicions with regard to the “gravity” of the situation. And indeed, the level of expertise you have so far provided does not go far enough to contribute to the safety margin the judge intends by his order. Sorry if I am repackaging what has already been said, but my opinion is to turn down the assignment. |
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