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MARYLAND INSURANCE ADMINISTRATION

JUNE 24, 2004

HOME OFFICE

XIX. LEAP PROGRAM

The Company makes available to its senior sales staff a special program to facilitate sales. This is an ‘outside’ planning system sponsored by a company in New Jersey, marketed as Lifetime Economic Acceleration Program (LEAP). This plan is targeted toward individuals with an annual income of $60,000, and generally 50 years or age or older.

The plan is not a single sale product, but generally requires a series of 4 to 6 interviews between the agent and proposed insured. The Company acknowledges the LEAP product is a complex product that requires special expertise.

An agent pays a fee to LEAP and must be licensed to use LEAP materials. The sales materials consist of videos and software providing the agent with instruction through several seminars.

The LEAP process attempts to identify the specific needs of an individual or family and the funding mechanisms available to make the complex products presumably affordable. The desired result is a more sophisticated sales product, a larger sale, increased conservation, higher consumer satisfaction, and higher commissions to the sales representative.

The Company provided the examiners with a listing of District Offices in Maryland licensed to use the LEAP system, along with the appropriately licensed agents.

The Company has an arrangement with the agents participating in the LEAP program to advance the fees associated with the LEAP program, and recouping them through a type of payroll deduction. Examiners observed several LEAP cases in reviewing policies, and conclude these sales should be monitored.

_____________________________________________________________________________________________

MET LIFE REPORT NO. 786-01

PAGE 33

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