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Attachment II: Living Trust Mills &
Pretext Interview Notice (Continued)

Put simply, a living trust mill is an unlawful marketing scheme designed to accomplish the sale of annuities that is principally used in the solicitation of senior citizens. While the specifics of living trust mills may vary, they all share the common attributes of misrepresentation of identity and purpose. Each misrepresents the actual business of the sales representative and the true purpose of the solicitation. The initial approach to clients may be to solicit senior citizens at "seminars," purportedly designed to educate participants about the benefits of living trusts and other estate planning devices. The approach may be through mass mailing, telemarketing, door-to-door solicitation, or even while providing entertainment at senior related functions.

Regardless of how clients are initially solicited, the sales presentations are basically the same. The representatives misrepresent themselves as experts in estate planning. They gain the trust and confidence of the client, and then misuse that trust to discover the extent of the client's assets under the pretext of determining whether the client can benefit from a living trust.

Trust mills typically use both licensed and unlicensed representatives, and often operate in conjunction with attorneys or attorney reference services in order to give the operation the appearance of legitimacy. After the living trust and related estate planning documents have been sold, a representative, usually a licensed agent, again misrepresenting his or her identity and purpose, attempts to sell an annuity to the client as part of their estate planning program. Clients characteristically perceive the agent as their legal adviser or estate planner and not as an insurance agent.


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Ohio National is not affiliated with, nor does it endorse or sponsor, any particular prospecting, marketing or selling system.

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