In the Oct/Nov ’09 issue of The Journal, a magazine produced by the Chartered Insurance Institute, the President wrote.

“The capability and effectiveness of people is especially important given that general levels of trust in financial services as a whole are so low.”

At the Expert International Adviser forum held in Singapore on 20th Oct 2009, one of the survey findings shared by a presenter is that the level of the consumers’ trust in banks has gone down presumably due to the recent failure of structured products.

Trust is so difficult to build but so easy to be destroyed.

One of the most important things we look for in our staff and advisers is honesty and integrity. And we train our advisers to also build clientele of the same ilk. Managing a difficult customer is one thing. Dealing with one who is dishonest is courting disaster.

However, it is never so white or black and therein lies the challenge.

“Building trust” is the first and most fundamental step in creating a new business relationship even before entering into any business talk. But how can trust be built between two people meeting for the first time?

It is surprising how often decisions are made supposedly based on trust but on hindsight, was really blind trust i.e. without any tangible basis. Brand building is a big thing today and basically it seeks to build trust in a name. To some extent, brand recognition is built more on advertising and marketing and may just be a construct of imaginative minds or just clever use of words.

“Personal branding” is now becoming a big thing i.e. every sales person is his own brand. It is right that every person in business or a profession, builds a good reputation for honesty, reliability, effectiveness etc. But again, if we just judge by how he looks or how he talks, one can be deceived. Parents with teens, especially girls, are particularly worried about their charges being misled and falling into bad company, or worse entering into a steady relationship with just a good looker or popular guy, but lacking in means and substance.

Since it is so difficult to be sure of who can be trusted, the best thing is to “inspect what you expect”. Be careful especially with strangers and also with people you know.

Try and test them out. Check out their credentials. The doctorate holder – is it real or just honorary? The stated number of years of experience – is it twenty years of the same or a rich build up of different and varied experiences?

The adviser who says he has the best product – has he done a valid comparison or just doing “sales talk”? Does he in the first place, have the power to represent more than one company, or is just a tied agent?

Trust should be earned and kept.

One of the challenges which my firm faced in the earlier years in the 1980’s was that we started from scratch. How would clients trust us to deliver? We knew that we would have to build trust and that we should never make promises which we can’t keep. This meant that we couldn’t talk big. This also meant we would have to give good service.

The words on the gift mugs we presented to our clients captured our intent.

“We don’t make promises that we can’t keep.”

This motto has stood us well indeed.

Our new motto?

Trusted Advice, Trusted Adviser.

What is the right thing to do in any situation is easier to decide if you have an absolute rulebook which spells out everything clearly.

For example, if you are God-fearing and abide by the Bible, the ten commandments would be examples of some do’s and don’ts.

However, knowing the rules does not mean automatically following them, but it is a start. You may still experience great difficulty to follow the rules and it is certainly not easy to resist temptation.

But you can abide by the rulebook but do it grudgingly and unwillingly, or even have wrong or ulterior motives for fulfilling the rules.

If you are not God-fearing, you may still fear being caught by the law and having to face the consequences. In this case, you are more concerned about not being caught rather than the rightness of the action.

Some will point to a higher law than just the rulebook and the laws of the state. This is the royal law of love, that whatever we do must be loving, not just right. The question we ask then is not “what is the right thing to do”, but “what is the loving thing to do?”

Is the royal law of love applicable to business or just social behaviour? If we practice love, can we succeed in business or will we be trampled upon and taken advantage of?

Business is said to be based on contracts and governed by the law of contract. Contractual rights and obligations which are mutually agreed may be said to be fair, although there are some manifestly unfair contracts. I have always thought the agency contract is somewhat unfair because the Principal has the right to terminate the contract without giving any reason, and usually the agent stands to lose monetarily.

Employment contracts also give both the employers and employees the right to terminate by giving the required period of notice, and employers have been known to exercise it. Employment contracts now even state the period of employment. When there is “wrongful termination”, the aggrieved party can seek remedies but this has to be proved, and employers can protect themselves by taking certain protective action and in the final result, get insurance cover.

Insurance companies which refuse to insure those who are medically unfit have been accused of cherry picking. Guaranteed renewability is also something which not all policies offer, and its absence means that the insurer can refuse to renew medical insurance policies for people who have made claims.

Some insurers do not refuse renewal, but offer exorbitant premiums which is a nice way of telling the insured to go elsewhere.

Applying “love” in the business world means that “one-sided” contracts would have to be changed. Terms must at least be fair to both parties.

A travel agent friend says some big companies take 90 days to pay their bills, even though the margin is so small and the interest incurred in financing these big bullies can wipe out whatever small profit there is. You may ask “why then continue doing business with them?” The answer is that it still helps to keep the company going and surviving on other smaller customers.

But the question is why should the big corporations take advantage of their strength and drive down prices until they are being subsidised by the smaller firms?

Some contracts contain terms which look pretty good, but will they be fulfilled? For example, I hear from certain advisers that although their previous FA firms have “vesting rights” in their contract, they are not assured that these fees and commissions for the investment and insurance contracts which they have sold during their stay with the firm, would be paid to them. The catch is that these amounts may not exceed $10,000 and it would be relatively costly to press for legal payment. The story goes that if the Representatives make a fuss, they would be paid a portion of what is due them.

These are just some examples of business practices which are based on power play, delay tactics, deception, etc.

The old adage is that honesty is the best policy. A twist to it is that honesty is not the best policy – it is the only policy.

Honesty, integrity, righteousness, fairness, equality – these are virtues that are still highly valued but are hard to find.

A very rich and powerful man instructed his assistant to lie to a man who called and wanted to speak to him, that he was not there. The assistant refused and told him politely to tell the man himself. He said that if he can lie for his boss, he would soon lie to his boss. It was no surprise that his wise boss promptly promoted him because honesty is essential to building trust.

I remember an interview I gave to a friend who wanted to join the insurance industry. I gave him honest and direct answers to all his questions, making sure not to exaggerate or make statements or promises which were not true. Since my firm was only a year old then, it was small and not too flattering. He went for an interview with a manager of another firm (a tied agency), and was told all kinds of things and promises. A year later, I asked him whether all the things he was told were true, and his answer was, “No”, but he was doing well enough and the loss of renewal commissions was painful if he were to leave. It seems fishermen are not the only ones using bait to hook their prey.

You see, his agency contract spelt out that if an agent were to leave, he would forfeit his right to all the remaining commissions. This agency termination terms have remained unchanged till today.

Being one of the pioneer life insurance broker in the 80’s, we implemented vesting rights in the 90’s, but subject to the Representatives serving a certain number of years and they apply only if the Representatives do not leave to join a competitor. This was an improvement but still restricted the Representatives’ rights.

Today, we have found that the loving thing is to grant vesting rights immediately and without any condition.

The proof that this sits well with Representatives is that it has strengthened the relationship between Representatives and the firm. They now look at each other as equals, as associates rather than master-servant or principal-agent.

Companies fulfill the royal law of love when they treat their employees and associates with respect and integrity. “Clients’ interest first” applies to them as well. The most beautiful thing is that if clients, staff and associates exercise this royal law also in response.

In 1985, I took the unlikely and, to many, the shocking step to enter the insurance industry to do sales.

Banking perhaps or even academia, but sales? And insurance of all things?

My wife, my parents, my friends and church – all cautioned me whether it was a wise move and whether it was the right time.

With four boys, the youngest two just one year old, and being the sole breadwinner, my wife just having stopped work, and with a maid to support as well, the financial responsibility on me was not enviable. Although my house and my car were paid for, I had only about $30,000 in my savings account and little else. This would, I calculated, last me only about two years on a very tight budget.

What only a few knew at that time was that going into business in insurance was not my preferred vocation.

When I was called to be an elder of my church in early 1984, my concern was to serve God in the best way. I remember being challenged by these thoughts:

(i) “Only one life. How to live it for the greatest glory of God and the greatest blessing to men?”
(ii) “Only one life and it’ll soon be past. Only what’s done for Christ will last”

My first choice for a vocation is to serve God full-time in the church if that was His calling for my life.

I prepared myself through prayer and reading the Bible avidly, and sought counsel from several senior Christian counselors.

Many factors were in favour of my going into full-time Christian service, but my wife and I felt it would not be fair for the church to support our big family, although I was prepared to live simply on the possible $2,000 monthly support.

Because of my desire to make my life still count for God, I decided, after some divine guidance and confirmations from God, to be a “tent-maker”. Paul, the great missionary in the early church, supported himself mainly through making tents. The term “tent-maker” came to be used to describe a person who supports himself while serving God.

By age 34, I had already served six years as a Divisional Manager in a public-listed company, and three years as a Regional Materials Manager in a foreign international company. I was also presented with an opportunity to go into politics. But my passion and my conviction were more on getting to know God better and to serve Him in my church. God had become very real to me, and my faith in Him had been strengthened through many answered prayers and feeding on the Bible. I wanted to live for Him out of gratitude for His saving me and my parents and my siblings.

The decision to turn my back on being a salaried manager and to become a tent-maker was not easy, and was only sealed at the last hour of 1984 at the Watch Night service when the song “How Great Thou Art” was sung. God assured me that He would take care of me and my family if I just trust Him.

My goal in coming into the industry in 1985 was to work half a week to support my family and devote the other half to serving God. My goal was not to start a company but just to do sales so that I could have more time for my church, which at that juncture did not have any fulltime elder or pastor (we now have five pastors).

God blessed my decision and my brother who taught me the ropes, and I began to bring in good business. Thanks be to God for the many friends and business contracts who supported us. Many of the clients were clearly God’s gifts to me, and my faith was greatly encouraged. Without planning to do so, my brother and I found ourselves having to start our own business in early 1986 because we could not get the required support to cope with our growing business.

Promiseland was founded in February 1986 by my brother and I with two staff. Soon we recruited an Administrative Officer so that we could devote ourselves to sales.

We both had limited capital and had to build the company slowly, but somehow, we had the favour of the insurance companies (including Prudential and Great Eastern) and many clients, both individuals and corporations.

In the early years, I had to supplement my income with part time lecturing in the evenings at Singapore Institute of Management and Singapore College of Insurance. The contacts made further helped in my sales and recruitment.

The history of the company is related elsewhere. What I’d like to focus on here is my personal and spiritual journey.

As the company grew, I had to remind myself of my purpose in coming into the industry, which was to be a tent-maker. There were opportunities to make a lot of money if I had worked longer hours or did what other businessmen did. For example, if I had not committed myself to several Christian organisations including 10 years as the chairperson of one, I could have become more active in actual sales and joining trade and business association or other networking groups, and prospered more. Although I believe in God’s provision and gifts, I also know that there are material success principles which will work, irrespective of one’s religion.

Over the last 20 years, I have seen many Christians who had focussed more on the industry alone, and had become millionaires. Every now and then I was tempted to focus more on the business to get very rich, and not just regard my business as “tent-making”, but each time, I was reminded of the reason I came into the industry. I am glad I kept to my vision as I value the opportunities to serve God in the local church.

Perhaps the problems which Promiseland suffered in the troubled years of the 90’s could have been avoided if I had given all my time and energy to managing it. But I was not given the support to manage the firm then, and it happened that my church needed my time to help resolve certain issues.

So in a sense, what you see today is not because of the good work the Directors have done, but in spite of what we failed to do. I know what we have today is entirely by God’s grace, and I’m glad to celebrate His goodness to us in seeing us through the last 23 years. From the very beginning, my theme verse from the Bible has been Psalm 127:1-2.

“Unless the Lord builds the house, they labour in vain who build it;
Unless the Lord guards the city, the watchman keeps awake in vain
It is vain for you to rise up early, to retire late,
To eat the bread of painful labours
For He gives to His beloved even in his sleep.”

I am often asked why we chose the name “Promiseland” for our company. I remember the time in 1985 when my brother and I thought of and prayed for a name which will remind us to have faith in God and to honour Him always. One day as I read the story of the twelve Israelite spies who were selected to do the reconnaissance of Canaan, which they were commanded to enter, only two of them, Joshua and Caleb, had the faith to advise the Israelites to enter it. There we were just two brothers in a small rented office trying to make ends meet and under severe business and financial pressure – we thought the name Promiseland was exactly what we need to remind us of our dependence on God for the “milk and honey”.

To say that it was all smooth and plain sailing would be untrue. It is not easy to have to bring in sales, conduct recruitment and training, manage staff and do part time teaching during an era without PCs and email, while taking care of church and family as well. We had to bring in enough sales to cover all the expenses and still have enough for the directors.

There were times when we had little left. But looking back, God had provided and His grace was more than sufficient for our needs.

As the company weathered several severe storms, the thought of going back to employment was tempting. I was offered a regional materials manager post three years after I got into insurance but turned it down. My conviction that God had blessed my tent-making vision enabled me to press on.

When the company was left with just three producers in 1996, I was again encouraged by a divine confirmation to restart the company, but this time, without any other shareholder. I was to be like Israel, not looking to Egypt for help and not relying on horses or chariots, but wholly depending on the Lord. This is the reason why I have not added any other shareholder. At the crucial and lowest point in 1996, God caused faith to arise in my heart and I re-embarked on building the company. This time, I had more capital and experience and the rebuilding was quick, but not without problems. Interpersonal conflicts between managers which had caused the first break up resurfaced, but thankfully this time, we managed to hold the ship steady.

The last ten years are best described as reconstruction years. Many of the current advisers have contributed much to the improvements in the firm, which are only manifest to those who had joined prior to 1998. We have been able to strengthen the company structure, the staff and the training. There are still many areas for improvement, but we now have the experience and the resources to accomplish them.

My journey is still in the making. The best part of the journey is still ahead.

I am excited that the new vision given to me now is to concentrate almost totally on Promiseland, and to regard this as my ministry or service for God. My contribution to my church is largely done although I will remain as an elder for many more years.

What I am committed to do is to build Promiseland to be worthy of the name, and to bring glory to God.

It will be a challenging mission and there will be obstacles and perhaps even enemies who will seek to spoil our plans.

The task is not going to be mine alone, but also those of committed staff and Advisers in the company.

What is different now compared to the 80’s and 90’s is that I have learned many valuable spiritual lessons which would help me take better care of the company and staff and advisers. I have a dream that Promiseland is going to make an impact for God in Singapore, not only in business but in witness.

And the mandate falls on the present generation of Promiselanders to inspire the next generation.

Let us press on and build a company we can be proud of and pass on to the next generation.

In 1985, I took the unlikely and, to many, the shocking step to enter the insurance industry to do sales.

Banking perhaps or even academia, but sales? And insurance of all things?

My wife, my parents, my friends and church – all cautioned me whether it was a wise move and whether it was the right time.

With four boys, the youngest two just one year old, and being the sole breadwinner, my wife just having stopped work, and with a maid to support as well, the financial responsibility on me was not enviable. Although my house and my car were paid for, I had only about $30,000 in my savings account and little else. This would, I calculated, last me only about two years on a very tight budget.

What only a few knew at that time was that going into business in insurance was not my preferred vocation.

When I was called to be an elder of my church in early 1984, my concern was to serve God in the best way. I remember being challenged by these thoughts:

(i) “Only one life. How to live it for the greatest glory of God and the greatest blessing to men?”
(ii) “Only one life and it’ll soon be past. Only what’s done for Christ will last”

My first choice for a vocation is to serve God full-time in the church if that was His calling for my life.

I prepared myself through prayer and reading the Bible avidly, and sought counsel from several senior Christian counselors.

Many factors were in favour of my going into full-time Christian service, but my wife and I felt it would not be fair for the church to support our big family, although I was prepared to live simply on the possible $2,000 monthly support.

Because of my desire to make my life still count for God, I decided, after some divine guidance and confirmations from God, to be a “tent-maker”. Paul, the great missionary in the early church, supported himself mainly through making tents. The term “tent-maker” came to be used to describe a person who supports himself while serving God.

By age 34, I had already served six years as a Divisional Manager in a public-listed company, and three years as a Regional Materials Manager in a foreign international company. I was also presented with an opportunity to go into politics. But my passion and my conviction were more on getting to know God better and to serve Him in my church. God had become very real to me, and my faith in Him had been strengthened through many answered prayers and feeding on the Bible. I wanted to live for Him out of gratitude for His saving me and my parents and my siblings.

The decision to turn my back on being a salaried manager and to become a tent-maker was not easy, and was only sealed at the last hour of 1984 at the Watch Night service when the song “How Great Thou Art” was sung. God assured me that He would take care of me and my family if I just trust Him.

My goal in coming into the industry in 1985 was to work half a week to support my family and devote the other half to serving God. My goal was not to start a company but just to do sales so that I could have more time for my church, which at that juncture did not have any fulltime elder or pastor (we now have five pastors).

God blessed my decision and my brother who taught me the ropes, and I began to bring in good business. Thanks be to God for the many friends and business contracts who supported us. Many of the clients were clearly God’s gifts to me, and my faith was greatly encouraged. Without planning to do so, my brother and I found ourselves having to start our own business in early 1986 because we could not get the required support to cope with our growing business.

Promiseland was founded in February 1986 by my brother and I with two staff. Soon we recruited an Administrative Officer so that we could devote ourselves to sales.

We both had limited capital and had to build the company slowly, but somehow, we had the favour of the insurance companies (including Prudential and Great Eastern) and many clients, both individuals and corporations.

In the early years, I had to supplement my income with part time lecturing in the evenings at Singapore Institute of Management and Singapore College of Insurance. The contacts made further helped in my sales and recruitment.

The history of the company is related elsewhere. What I’d like to focus on here is my personal and spiritual journey.

As the company grew, I had to remind myself of my purpose in coming into the industry, which was to be a tent-maker. There were opportunities to make a lot of money if I had worked longer hours or did what other businessmen did. For example, if I had not committed myself to several Christian organisations including 10 years as the chairperson of one, I could have become more active in actual sales and joining trade and business association or other networking groups, and prospered more. Although I believe in God’s provision and gifts, I also know that there are material success principles which will work, irrespective of one’s religion.

Over the last 20 years, I have seen many Christians who had focussed more on the industry alone, and had become millionaires. Every now and then I was tempted to focus more on the business to get very rich, and not just regard my business as “tent-making”, but each time, I was reminded of the reason I came into the industry. I am glad I kept to my vision as I value the opportunities to serve God in the local church.

Perhaps the problems which Promiseland suffered in the troubled years of the 90’s could have been avoided if I had given all my time and energy to managing it. But I was not given the support to manage the firm then, and it happened that my church needed my time to help resolve certain issues.

So in a sense, what you see today is not because of the good work the Directors have done, but in spite of what we failed to do. I know what we have today is entirely by God’s grace, and I’m glad to celebrate His goodness to us in seeing us through the last 23 years. From the very beginning, my theme verse from the Bible has been Psalm 127:1-2.

“Unless the Lord builds the house, they labour in vain who build it;
Unless the Lord guards the city, the watchman keeps awake in vain
It is vain for you to rise up early, to retire late,
To eat the bread of painful labours
For He gives to His beloved even in his sleep.”

I am often asked why we chose the name “Promiseland” for our company. I remember the time in 1985 when my brother and I thought of and prayed for a name which will remind us to have faith in God and to honour Him always. One day as I read the story of the twelve Israelite spies who were selected to do the reconnaissance of Canaan, which they were commanded to enter, only two of them, Joshua and Caleb, had the faith to advise the Israelites to enter it. There we were just two brothers in a small rented office trying to make ends meet and under severe business and financial pressure – we thought the name Promiseland was exactly what we need to remind us of our dependence on God for the “milk and honey”.

To say that it was all smooth and plain sailing would be untrue. It is not easy to have to bring in sales, conduct recruitment and training, manage staff and do part time teaching during an era without PCs and email, while taking care of church and family as well. We had to bring in enough sales to cover all the expenses and still have enough for the directors.

There were times when we had little left. But looking back, God had provided and His grace was more than sufficient for our needs.

As the company weathered several severe storms, the thought of going back to employment was tempting. I was offered a regional materials manager post three years after I got into insurance but turned it down. My conviction that God had blessed my tent-making vision enabled me to press on.

When the company was left with just three producers in 1996, I was again encouraged by a divine confirmation to restart the company, but this time, without any other shareholder. I was to be like Israel, not looking to Egypt for help and not relying on horses or chariots, but wholly depending on the Lord. This is the reason why I have not added any other shareholder. At the crucial and lowest point in 1996, God caused faith to arise in my heart and I re-embarked on building the company. This time, I had more capital and experience and the rebuilding was quick, but not without problems. Interpersonal conflicts between managers which had caused the first break up resurfaced, but thankfully this time, we managed to hold the ship steady.

The last ten years are best described as reconstruction years. Many of the current advisers have contributed much to the improvements in the firm, which are only manifest to those who had joined prior to 1998. We have been able to strengthen the company structure, the staff and the training. There are still many areas for improvement, but we now have the experience and the resources to accomplish them.

My journey is still in the making. The best part of the journey is still ahead.

I am excited that the new vision given to me now is to concentrate almost totally on Promiseland, and to regard this as my ministry or service for God. My contribution to my church is largely done although I will remain as an elder for many more years.

What I am committed to do is to build Promiseland to be worthy of the name, and to bring glory to God.

It will be a challenging mission and there will be obstacles and perhaps even enemies who will seek to spoil our plans.

The task is not going to be mine alone, but also those of committed staff and Advisers in the company.

What is different now compared to the 80’s and 90’s is that I have learned many valuable spiritual lessons which would help me take better care of the company and staff and advisers. I have a dream that Promiseland is going to make an impact for God in Singapore, not only in business but in witness.

And the mandate falls on the present generation of Promiselanders to inspire the next generation.

Let us press on and build a company we can be proud of and pass on to the next generation.

“Forbidden fruit tastes sweetest”.

Many years ago when I heard this quote from St. Augustine in his “Confessions” (if my memory serves me right), I was reminded of the mangoes which we boys “picked” from the estate of a rich family. We did this at some risk because of the dogs which guarded the estate. How delicious those stolen mangoes tasted, and how assuaged our hunger was, but not the pangs of conscience!

We had to time how long the dogs would take from discovering us to the time they pounce on us. And we had to practice our shuttle run. At times, we had to place decoys or distracted the dogs in some ways. But there was always a way to beat the system.

If this cheeky streak remains kids’ play only, no harm done. But beating the system is becoming an adult preoccupation.

The daily papers throw up many stories of how people beat the system and how the law caught up with them. Some companies had resorted to having bogus employees on their payroll, in order to employ additional cheaper foreign workers, to beat the quota set by MOM.

Some employers pay their S Pass foreign employees less than $1,800 per month by requiring them to return a portion of their pay each month.

The grapevine abounds with stories of how certain Financial Advisers and financial adviser Representatives give incentives and cash rebates to induce prospects to purchase certain products. Since inducements are not permitted by the authorities, these cash rebates are given as “introducer fees” or “coffee money”. Where CPF investments are concerned, the cash rebates are actually certain percentages of the fees which are charged and should be returned to the CPF accounts, but since it is in cash form, it is easy to beat the system.

There is a thin line between the legitimate offering of rebates because of business reasons (for large sums, loyal customers, etc.) and using rebates as an inducement.

What is inducement anyway they ask? Who decides whether it is inducement? The fact is that if it is up to the prospect / client, then there will unlikely be anyone reporting it because it benefits him also.

But there are risks. In the case of inducements for investments, the risk is that insufficient attention is paid to the investment per se, and the prospect can end up losing more than what he gains in cash rebates.

In the case of insurance, where medical underwriting is required, offering inducements up front is often accompanied by the Representative filling in the medical questionnaire with answers that are favourable. The problem of misrepresentation or non-disclosure would only surface at the time of a claim. So when you encounter Representatives offering cash rebates at road-shows, be careful that you do not end up later with disallowed claims.

The question which will surely come to mind is what can be done to stop individuals and companies from beating the system?

The first thing to note is that given the financial “rewards” that forbidden fruit can bring, there will be many who will be tempted.

It has been observed that there are insurance broking companies which have been attracted to do Financial Advisory business, particularly investments, not by the legitimate way of distributing unit trusts, but by the money which can be brought in by “churning” of CPF investments using cash rebates as an inducement. The fact that there are “syndicates” willing to supply these firms with a steady stream of business makes it easy for them to be sucked in.

That there are licensed FA firms or groups within the firms which have succumbed to the temptation, is also circulating in the grapevine and presumably known to the authorities as well.

The second thing to note is that all these offenders presumably expect to be found out sooner or later. So why are they still continuing the offence? The answer is that they are prepared to terminate the “culprits” and if so be it, to stop their FA business. That was what happened to three companies in 2008, and the possible thinking of firms which have been doing the same thing but not found out yet, is that it is worth it.

It has been calculated that a firm which goes into heavy churning business can make millions in a few years before the law catches up with them. Anyway, if the shareholders and directors are of retirement age, they can go into a cash rich retirement.

The obvious deterrent to these firms or individuals beating the system is to be found out before they can make a pile, or for a heavy punitive punishment. There have been several suggestions of more effective deterrents:

1. If the firm is responsible or accountable (e.g. because the malpractice is rampant and obvious), the license to do even general insurance should be cancelled. This is because ceasing the FA business is not a penalty at all.

2. Fines under the Financial Advisers Act could be imposed on both the offending firms and the Representatives. This can be hefty.

3. Quicker action could be taken so that other firms would not be tempted to join the bandwagon. In addition, it is important that the public be educated on the disadvantages of churning.

Beating the system must not be allowed to go on unchecked. It is good that St. Augustine reached the place of repentance and confession for “beating the system” in his childhood.

While the temptation is always there to take advantage of other peoples’ follies and gullibility, it is important to keep to the straight and narrow road, and keep a clear conscience.

Forbidden fruit may taste sweetest, but it often leaves a bad stomach ache.