DOB: Bankers Life Consent Order

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IN THE MATTER OF:

BANKERS LIFE AND
CASUALTY COMPANY

BLC FINANCIAL SERVICES, INC.
   (CRD No. 126638)


(Collectively, Respondents")

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CONSENT ORDER

No. CO-12-8018-S

I. PRELIMINARY STATEMENT

WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), and Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies promulgated under the Act (“Regulations”);
 
WHEREAS, BLC Financial Services, Inc. (“BLCFS”) is an Illinois corporation affiliated with Bankers Life and Casualty Company (“Bankers Life”).  BLCFS and Bankers Life are both located at 111 East Wacker Drive, 21st Floor, Chicago, Illinois 60601;
 
WHEREAS, state regulators from multiple jurisdictions, including the Securities and Business Investments Division of the State of Connecticut Department of Banking (the “Division”), conducted coordinated investigations of Bankers Life and BLCFS (collectively, “Bankers”) to determine whether Bankers should have been registered as a broker-dealer and investment adviser between January 1, 2005 and December 2, 2011;
 
WHEREAS, the state investigators determined that Bankers had acted as a broker-dealer and investment adviser in various jurisdictions without being registered, exempt from registration, or a federal covered investment adviser, and had employed or otherwise engaged agents and investment adviser representatives who were not so registered on behalf of Bankers;
 
WHEREAS, Bankers has engaged in similar conduct in Connecticut in violation of Section 36b-6 of the Act;
 
WHEREAS, Section 36b-27(a) of the Act authorizes the Commissioner to order any person who has violated, is violating or is about to violate any provision of the Act or any regulation, rule or order adopted or issued under the Act to cease and desist from such violation, and Section 36b-27(d) of the Act authorizes the Commissioner to impose a fine against any person who has violated any provision of the Act or any regulation, rule or order adopted or issued under the Act;
 
WHEREAS, an administrative proceeding under Section 36b-27 of the Act would constitute a “contested case” within the meaning of Section 4-166(2) of the General Statutes of Connecticut;
 
WHEREAS, Section 4-177(c) of the General Statutes of Connecticut and Section 36a-1-55(a) of the Regulations of Connecticut State Agencies provide that a contested case may be resolved by consent order, unless precluded by law;
 
WHEREAS, Section 36b-31(a) of the Act provides, in relevant part, that “[t]he commissioner may from time to time make . . . such . . . orders as are necessary to carry out the provisions of sections 36b-2 to 36b-34, inclusive”;
 
WHEREAS, Section 36b-31(b) of the Act provides, in relevant part, that “[n]o . . . order may be made . . . unless the commissioner finds that the action is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of sections 36b-2 to 36b-34, inclusive”;
 
WHEREAS, the conduct addressed herein has resulted in no known direct consumer harm, and the parties understand that registered agents or representatives of registered broker-dealers or investment advisers other than Bankers participated in all securities transactions and at locations that were registered with the appropriate securities authorities as broker-dealer locations of broker-dealers other than Bankers;
 
WHEREAS, Bankers has cooperated with state regulators conducting the investigations by responding to inquiries, providing documentary evidence, and halting the further receipt of broker-dealer and investment adviser related compensation while the investigations were pending;
 
WHEREAS, Bankers, in order to avoid protracted and expensive proceedings in numerous states, has agreed to resolve the investigations through a multistate settlement which includes this Consent Order;
 
WHEREAS, Bankers, as part of this settlement, agrees to comply with all state and federal licensing, registration, and other securities laws;
 
WHEREAS, Bankers, without admitting or denying the Conclusions of Law set forth below and solely for the purposes of this Consent Order, admits the jurisdiction of the Commissioner, admits the Findings of Fact set forth in paragraphs 1 through 11, inclusive, of Part II of this Consent Order, voluntarily consents to the entry of this Consent Order, and voluntarily waives the following rights:  (1) to be afforded notice and an opportunity for a hearing within the meaning of Sections 36b-27(a) and 36b-27(d)(2) of the Act and Section 4-177(a) of the General Statutes of Connecticut; (2) to present evidence and argument and to otherwise avail itself of Sections 36b-27(a) and 36b-27(d)(2) of the Act and Section 4-177c(a) of the General Statutes of Connecticut; (3) to present its position in a hearing in which it is represented by counsel; (4) to have a written record of the hearing made and a written decision issued by a hearing officer; and (5) to seek judicial review of, or otherwise challenge or contest the matters described herein, including the validity of this Consent Order;
 
WHEREAS, the Commissioner finds that the entry of this Consent Order is necessary or appropriate in the public interest and consistent with the purposes fairly intended by the policy and provisions of the Act;
 
NOW THEREFORE, the Commissioner hereby enters this Consent Order.

II. FINDINGS OF FACT

1. Bankers Life is a life insurance company located in Illinois that has never been registered as a broker-dealer or investment adviser.
2.
BLCFS is a wholly-owned subsidiary of Bankers Life that also is located in Illinois.  BLCFS has been a member of NASD or FINRA since 2003 and is registered as a broker-dealer only in Illinois.  During its existence, BLCFS has had no business activity other than as described herein.  BLCFS has never been registered as a broker-dealer or investment adviser in Connecticut, and it has not registered any agents or investment adviser agents in Connecticut.
3.
Effective January 1, 2005, Bankers Life entered into a Financial Services Agreement with UVEST Financial Services Group, Inc. (the “UVEST Agreement”), under which insurance agents of Bankers Life who became licensed as registered representatives and/or investment adviser representatives of UVEST would provide brokerage and investment advisory services out of Bankers Life branch office locations.  At all relevant times, UVEST has been a broker-dealer registered in Connecticut and (through an affiliate) a federally covered investment adviser.  The UVEST Agreement specified that UVEST would “exercise exclusive control” over the broker-dealer and investment advisory activities of the dual agents, and assigned Bankers Life several securities-related roles, which Bankers Life did perform, including:

a.    appointing the persons to be dual agents and having sole discretion to withdraw appointments at any time;
 
b.    determining with UVEST the number and identity of dual agents at each office;
   
c.     determining with UVEST the compensation to be paid to each agent;
   
d.     determining with UVEST the “brokerage product offerings available for distribution” by the dual agents;
   
e.     approving the clearing broker selected by UVEST;
   
f.   approving advertising and promotional material; and
 
g.   paying for:  (i) pre-examination training for required NASD/FINRA examinations; (ii) investment research materials used in the branch offices; (iii) recruitment and travel costs; and (iv) UVEST stationery and business cards.
 
4. The UVEST Agreement provided for UVEST to pay Bankers Life “Revenue Sharing Payments” according to a schedule that varied from 82% to 85% of the gross commissions received by UVEST for the dual agents’ securities transactions.  The UVEST Agreement characterized these payments as representing reimbursement for the compensation Bankers Life pays to the dual agents and “payment for the use of the facilities and equipment” of Bankers Life.
5. In March of 2005, Bankers Life determined that BLCFS should have been a party to the UVEST Agreement.  As a result, the three firms agreed to a new first page of the UVEST Agreement that added BLCFS as a party and a new signature page, which was executed by the three parties.  The revised UVEST Agreement did not assign BLCFS any rights or duties separate from those of Bankers Life and made all of Bankers Life’s rights and duties also apply to BLCFS.
6. Coincident with Bankers and UVEST terminating the UVEST Agreement, Bankers Life and BLCFS entered into a similar agreement with ProEquities, Inc. (“ProEquities) effective April 30, 2010 (the “ProEquities Agreement”).  At all relevant times, ProEquities has been a broker-dealer registered in Connecticut and (through an affiliate) a federally covered investment adviser.  The ProEquities Agreement specified that ProEquities would “exercise exclusive control” over the broker-dealer and investment advisory activities of the dual agents, and assigned the following securities-related roles to BLCFS or to BLCFS and Bankers Life, roles in which BLCFS and Bankers Life subsequently engaged:
 
a.     consulting with ProEquities on the persons to be appointed as representatives of ProEquities;
 
b.     identifying securities product training and marketing opportunities;
   
c.     determining with ProEquities the securities products made available for distribution by the dual agents;
   
d.     approving the clearing broker selected by ProEquities (BLCFS only);
   
e.     approving advertising and promotional material (BLCFS only);
   
f.     recruiting representatives for ProEquities and assisting with the licensing and registration process;
   
g.     providing marketing, training, and support; and
   
h.     paying for:  (i) pre-examination training for required FINRA examinations; (ii) sales training materials; (iii) recruitment and travel costs; and (iv) ProEquities stationery and business cards. 
 
7. Under the ProEquities Agreement, ProEquities was required to pay BLCFS between 87% and 91% of revenue received by ProEquities for the securities business conducted by the dual agents.  ProEquities also was required to provide reports to BLCFS of the amount of compensation to be paid to each dual agent for securities work, and BLCFS was to retain the difference.
8.
BLCFS, in its current Form BD filing, lists the following as other business:
 
     BLC Financial Services, Inc. (BLCF) provides sales support & a marketing program to Bankers Life & Casualty agents who are securities licensed with ProEquities.  BLCFS will receive compensation from ProEquities based on these securities sales.  BLCFS will not have any representatives that sell to the public.
9. The involvement of Bankers in securities-related roles led to confusion in the reporting and responsibility hierarchies as between Bankers and the applicable broker-dealer.
10. At no time were the dual agents licensed as agents or investment adviser representatives of Bankers Life or BLCFS.  The agents were registered representatives and investment adviser representatives of UVEST or ProEquities.
11. From January 1, 2005, through November 31, 2011, Bankers received, on a nationwide basis, a total of approximately $21 million from UVEST and ProEquities under their respective agreements for variable annuity and securities transactions and investment advice.  Approximately $15 million of this amount was passed on by Bankers to the dual agents as compensation, leaving approximately $6 million retained by Bankers or used by Bankers for expenses.

III. CONCLUSIONS OF LAW

1.
Under Section 36b-6(a) of the Act, a person may not transact business as a broker-dealer in Connecticut unless registered.
2.
Similarly, under Section 36b-6(c) of the Act, a person may not transact business as an investment adviser in Connecticut unless registered or exempt from registration.
3. Section 36b-6(b) of the Act prohibits a broker-dealer from employing an agent unless that agent is registered under the Act or an associated person who represents a broker-dealer in effecting transactions described in subdivisions (2) and (3) of Section 15(h) of the Securities Exchange Act of 1934.
4. Section 36b-6(c)(3) of the Act prohibits an investment adviser from engaging an investment adviser agent unless such investment adviser agent is registered under the Act.
5. By engaging in the conduct set forth above, Bankers transacted business as a broker-dealer and as an investment adviser absent registration in Connecticut in violation of Sections 36b-6(a) and 36b-6(c) of the Act.
6. Furthermore, by employing or engaging dual agents who were not registered in Connecticut as agents or investment adviser agents of Bankers, Bankers violated Sections 36b-6(b) and 36b-6(c)(3) of the Act.
7. As a result, the entry of this Consent Order is necessary or appropriate in the public interest and consistent with the purposes fairly intended by the policy and provisions of the Act.

IV. CONSENT ORDER


On the basis of the Findings of Fact, Conclusions of Law, and the consent of the Respondents to the entry of this Consent Order,

IT IS HEREBY ORDERED THAT:

1.
Bankers shall CEASE AND DESIST from (1) transacting business as a broker-dealer or investment adviser in Connecticut unless and until registered to do so; (2) employing or engaging agents or investment adviser agents in Connecticut unless such individuals are registered under the Act as agents or investment adviser agents of Bankers; and (3) otherwise violating the Act; provided, however, that nothing in this Consent Order shall prevent Bankers from employing or engaging insurance producers who are also registered under the Act as broker-dealer agents or investment adviser agents of a Connecticut-registered broker-dealer so long as all securities-related functions are carried out consistently with the conditions set forth below.
2.
In accordance with the terms of the multistate settlement, Bankers Life and/or BLCFS shall pay $9.9 million to be distributed among the states where dual agents were located during the period from January 1, 2005, through December 2, 2011.  Within ten (10) business days following the entry of this Consent Order by the Commissioner, Bankers shall pay to the “Treasurer, State of Connecticut”, by electronic funds transfer or wire transfer, the sum of Nine Hundred Sixty Five Thousand Four Hundred Sixty Nine and 30/100 Dollars ($965,469.30) as an administrative fine, which amount constitutes Connecticut’s proportionate share of the total state settlement amount of $9.9 million.
3.
Bankers Life and/or BLCFS shall pay past licensing and registration fees totaling $260,000 to the states where dual agents were located during the period from January 1, 2005, through December 2, 2011.  Within ten (10) business days following the entry of this Consent Order by the Commissioner, Bankers shall pay to the “Treasurer, State of Connecticut” by electronic funds transfer or wire transfer, the sum of Five Thousand Dollars ($5,000) representing licensing fee reimbursement due to Connecticut under the multistate settlement.
4.
Bankers Life and/or BLCFS shall pay One Hundred Six Thousand Dollars ($106,000) to fund state audits to ensure compliance with this Consent Order and similar orders, decrees, and agreements in other states.  Bankers Life and/or BLCFS shall pay the expenses associated with one or more examinations to be conducted by the Division within twenty four (24) months following the Commissioner’s entry of this Consent Order.  Such expenses shall be in accordance with state travel regulations, and shall not exceed two thousand dollars ($2,000) in the aggregate, which amount represents Connecticut’s share of the $106,000 audit allocation pursuant to the multistate settlement.
5.
Bankers shall contract with an independent third party, with disclosure of any prior relationship to Bankers and with a scope of work not unacceptable to the Securities Administrator for the State of Maine (the Lead State in the multistate investigation) for the purpose of reviewing Bankers’ compliance with the terms of this Consent Order.  The independent third party shall submit annual reports of the same, including findings and recommendations, to the Maine Securities Administrator, which report shall be delivered on or before September 30th of each year commencing with the September 30, 2012 report and ending with the September 30, 2014 report.  Bankers shall make no claim of privilege or other protection from disclosure to the Maine Securities Administrator with respect to the reports or any information received or considered by the independent third party, and Bankers shall not take any action to prevent or impede the Maine Securities Administrator from sharing the reports or information with other state securities regulators, including the Commissioner.
6.
If any state securities regulator determines not to accept the settlement offer of Bankers reflected herein, the monetary payments to Connecticut hereunder shall not be affected, and Bankers shall not be relieved of any of the non-monetary provisions of this Consent Order.
7. Bankers shall not attempt to recover any part of the payments described in this Consent Order from dual agents, UVEST, ProEquities, or customers of Bankers (including through premium increases); provided, however, that nothing in this Consent Order prohibits Bankers from modifying its premiums or expenses for reason(s) unrelated to the payments referenced herein.
8. Bankers shall fully cooperate with any investigation or proceeding related to the subject matter of this Consent Order.
9. Bankers has an existing relationship with ProEquities, a third party licensed broker-dealer.  From the date of this Consent Order through March 31, 2015 and while Bankers has dual agents that are registered representatives or investment adviser representatives of a third party broker-dealer, any agreement between Bankers and the third party broker-dealer shall be consistent with the provisions set forth below, provided, however, Bankers may seek leave with the applicable securities administrators for relief from this provision:
 
a.     The third party broker-dealer (“TPBD”) must be solely responsible for the hiring, training, supervision and conduct of each of its registered representatives and investment adviser representatives as that conduct relates to securities or other TPBD products and the provision of investment advisory services.
 
b.     Bankers Life and its affiliates, including without limitation BLCFS (“Bankers affiliates”), shall have no responsibility for the hiring, training, supervision and conduct of any registered representative or investment adviser representative as that conduct relates to securities or other TPBD products and the provision of investment advisory services.
   
c.     Bankers affiliates shall not:  (i) Exercise any control over whom the TPBD appoints as registered representatives or investment adviser representatives; (ii) identify securities product training and marketing opportunities; (iii) determine with the TPBD the securities products made available for distribution; (iv) approve the clearing broker selected by the TPBD; (v) approve advertising and promotional material, provided, however, that Bankers shall maintain the right to object to advertising or promotional material that is either in violation of the law or that in any way refers to Bankers; and (vi) pay for pre-examination training, sales training materials, travel costs or TPDB stationery and business cards for registered representatives or investment adviser representatives.
   
d.     The TPBD must be solely responsible for commission payments to registered representatives and investment adviser representatives, including the commission grid applicable to each registered representative and investment adviser representative, as that grid may be modified from time to time at the sole discretion of the TPBD.
   
e.     Bankers affiliates shall provide no compensation to registered representatives and investment advisers based on securities production including, without limitation, payment of expenses associated with the annual convention; provided, however, Bankers may continue to reimburse convention-related expenses to the extent they are based on insurance production.
   
f.     Bankers may be compensated for its costs associated with the registered representatives and investment adviser representatives and the office space and equipment by the TPBD in the form of an administrative fee.  The administrative fee must be reasonable and may not be based in any way on securities production, securities gross dealer compensation, or the number of securities transactions.
   
g.     Bankers shall not conduct or permit its branches, employees, or insurance agents to conduct securities statement or referral contests on an individual or group basis or otherwise create incentives for obtaining securities statements from customers or prospective customers, regardless of whether the contest or incentive is based partly on chance.
   
h.    Bankers Life shall promptly provide:  (i) any information or visitation requested at any time by the Division or any other state securities regulator regarding Bankers Life’s relationships, such information and visitation including, without limitation, documents; written statements; testimony of agents, employees, or other representatives; and unannounced examinations of dual offices; and (ii) written notification of any complaint from a broker-dealer or investment adviser client to the state securities regulators in the states where the complainant and all involved agents or representatives are located so that the notification is received within 15 days of the complaint.
   
i.     Within 60 days of Bankers entering into an agreement with a TPBD other than ProEquities, the independent third party reviewer referenced in paragraph 5 of Part IV of this Consent Order shall review the agreement with the TPBD to confirm compliance with this paragraph and shall submit a report of the same, with any relevant findings and recommendations, to the Securities Administrator for the State of Maine. 
 
10. Bankers Life shall comply with the following practices:
 
a.     An insurance producer who is not licensed to give advice concerning securities products (an “Insurance Producer”) may gather all financial information necessary to complete a Bankers Factfinder or similar document or tool required to determine insurance product suitability and may provide the consumer with a business card of, and pre-addressed stamped envelope to, a person properly licensed/registered to provide advice concerning securities products. The Insurance Producer shall not obtain a copy of the consumer’s statement(s) for securities products or discuss any other aspect of the securities products and the Insurance Producer cannot arrange for the consumer to meet with a person properly registered to provide advice concerning securities products.  The Insurance Producer may explain that the Insurance Producer is not licensed to discuss securities products.
 
b.     While gathering information for the Bankers’ Factfinder or similar document or tool, an Insurance Producer shall not inquire into a consumer’s satisfaction with the consumer’s current investments in securities or with the consumer’s current broker-dealer, investment adviser, registered representative, or investment adviser representative or make comparisons between securities and non-securities products.  As used in this subparagraph, “securities” refers both to specific securities products and to securities in general.
   
c.     No commissions or other compensation derived from a securities transaction shall be paid to or split with an Insurance Producer. 
 
11. Pursuant to a Consent Order entered with the Maine Securities Administrator on April 27, 2012, BLCFS made the filings necessary to withdraw its registration as a broker-dealer with the Securities and Exchange Commission and the State of Illinois and terminate its membership with FINRA.  BLCFS shall not reapply for such registration or membership.
12. This Consent Order concludes the investigation by the Division and any other action that the Commissioner could commence under the Act on behalf of Connecticut as it relates to the violations described above, up to and including activity occurring through December 2, 2011; provided, however, that excluded from and not covered by this paragraph are any claims by the Commissioner arising from or relating to enforcement of the terms and conditions of this Consent Order.
13. If payments are not made by Bankers Life or BLCFS, or if Bankers defaults in any of its obligations set forth in this Consent Order, the Commissioner may vacate this Consent Order, at the Commissioner’s sole discretion, upon 10 days notice to Bankers and without opportunity for administrative hearing or judicial review.
14. Nothing herein shall preclude the State of Connecticut, its departments, agencies, boards, commissions, authorities, political subdivisions and corporations, other than the Commissioner and only to the extent set forth herein, (collectively, “State Entities”) and the officers, agents or employees of State Entities from asserting any claims, causes of action, or applications for compensatory, nominal and/or punitive damages, administrative, civil, criminal, or injunctive relief against Bankers; provided, however, that this Consent Order shall not be deemed to constrain, estop or preclude Bankers from asserting any legal or factual position, response or defense, provided, however, that Bankers admits the facts set forth in the Findings of Fact contained in paragraphs 1 through 11, inclusive, of Part II of this Consent Order.
15. This Consent Order is not intended by the Commissioner to subject any person to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the Virgin Islands including, without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions.
16. This Consent Order and the order of any other state in related proceedings against Bankers (collectively, the “Orders”) shall not disqualify any person from any business that they otherwise are qualified, licensed or permitted to perform under applicable securities laws of Connecticut, and any disqualifications from relying upon this state’s registration exemptions or safe harbor provisions that arise from the Orders are hereby waived.
17. This Consent Order and any dispute related thereto shall be construed and enforced in accordance with, and governed by, the laws of Connecticut without regard to any choice of law principles.
18. This Consent Order shall be binding upon Bankers, its affiliates, successors and assigns.
19. This Consent Order is entered into solely for the purposes of resolving the referenced multistate investigation, and is not intended to be used for any other purpose.  For any person or entity not a party to the Consent Order, this Consent Order does not create any private rights or remedies against Bankers, create liability of Bankers, or limit or preclude any legal or factual positions or defenses of Bankers in response to any claims.
20. Except as set forth above, the Commissioner agrees to take no action adverse to Bankers or its agents based solely on the same conduct addressed in this Consent Order.  However, nothing in this Consent Order shall preclude the Commissioner from:  (a) taking adverse action based on other conduct; (b) taking this Consent Order and the conduct described above into account in determining the proper resolution of action based on other conduct; (c) taking any and all available steps to enforce this Consent Order; or (d) taking any action against other entities or individuals, regardless of any affiliation or relationship between Bankers and the entities or individuals.

NOW THEREFORE, the Commissioner enters the following:

1. The Findings of Fact, Conclusions of Law and Consent Order set forth above, be and are hereby entered;
2. Entry of this Consent Order by the Commissioner is without prejudice to the right of the Commissioner to take enforcement action against Respondents as set forth in paragraph 20 of Part IV of this Consent Order; and
3. This Consent Order shall become final when entered.


 
So ordered at Hartford, Connecticut      _______/s/_________
this 29th day of June 2012.      Howard F. Pitkin 
    Banking Commissioner 


CONSENT TO ENTRY OF ORDER

I, William D. Fritts, Jr., state on behalf of Bankers Life and Casualty Company, that I have read the foregoing Consent Order; that I know and fully understand its contents; that I am authorized to execute this Consent Order on behalf of Bankers Life and Casualty Company; that Bankers Life and Casualty Company, agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that Bankers Life and Casualty Company voluntarily consents to the entry of this Consent Order, expressly waiving any right to a hearing on the matters described herein.     

 
     Bankers Life and Casualty Company
  
           
By: __________ /s/__________________
Name:  William D. Fritts, Jr.
  Title:   Senior Vice President
            Government Relations 

 
State of:  Indiana

County of:  Hamilton

On this the 25th day of June, 2012, before me, the undersigned officer, personally appeared William D. Fritts, Jr., who acknowledged himself to be the Senior Vice President, Government Relations of Bankers Life and Casualty Company, a corporation, and that he, as such Senior Vice President, Government Relations, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself as Senior Vice President, Government Relations.
 
In witness whereof I hereunto set my hand.



______/s/____________________________
Notary Public
Date Commission Expires:  4-23-2016
 

CONSENT TO ENTRY OF ORDER

I, Thomas R. Kaehr, state on behalf of BLC Financial Services, Inc., that I have read the foregoing Consent Order; that I know and fully understand its contents; that I am authorized to execute this Consent Order on behalf of BLC Financial Services, Inc.; that BLC Financial Services, Inc., agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that BLC Financial Services, Inc. voluntarily consents to the entry of this Consent Order, expressly waiving any right to a hearing on the matters described herein.     

 
BLC Financial Services, Inc.
  
           
By: ___________/s/___________
Name:  Thomas R. Kaehr
  Title:    President

 
State of:  Indiana

County of:  Hamilton

On this the 25th day of June, 2012, before me, the undersigned officer, personally appeared Thomas R. Kaehr, who acknowledged himself to be the President of BLC Financial Services, Inc., a corporation, and that he, as such President, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself as President.
 
In witness whereof I hereunto set my hand.
 

_____/s/________________________
Notary Public
Date Commission Expires:  1/18/2018


  

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