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MARYLAND INSURANCE ADMINISTRATION

JUNE 24, 2004

HOME OFFICE

XIV.

COMPANY REPLACEMENT REGISTER SUMMARY

Agent

District No.

Policy Replacements

863-1

A66

17

844-2

B06

19

828-2

A66

16

811-1

B06

31

823-1

B06

28

822-2

A66

29

806-2

K55

21

818-1

B16

20

882-4

B16

21

865-3

L56

26

807-4

L56

17

874-1

K66

15

The Company provided the examiners a register containing the names of agents having replaced life insurance. The register contains the policy number, policy plan, policyholder first name and last names, the transaction date, the agent first and last names, the district office, agent identification number and the names of companies whose policies were replaced.

The examiners expressed to the Company that for certain agents the policy replacement frequency appeared to be large. The Company responded that in the replacement of policies when they determined that an agent was involved in large amounts of replacements remedial counseling and training were provided.

While the replacement of existing contracts is of concern, when it is done in accordance with COMAR 31.09.05.01, 02, 03, 04, and 05 it does not constitute a violation of Maryland law. This will be discussed under Company Complaints section of report.

An analysis of the company replacement register for the years 1998 through 2000 showed the following agents to have replaced 15 or more policies during this period without regard to the volume of business written.

_____________________________________________________________________________________________

MET LIFE REPORT NO. 786-01

PAGE 23

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