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Wednesday, March 09, 2005

First Command Sales Practices 
Here's yet another corroboration of the abusive and fraudulent sales practices of First Command, from the San Diego Union Tribune.



McPhail said the agent was able to convince him that putting money in other mutual funds amounted to "risky speculation." Only through a "disciplined" program like the one offered by First Command could he guarantee a secure retirement, the agent told him.


If true, the agent is guilty of fraud. First of all, other funds taken as a whole are no more risky or speculative than First Command's. Second, no fund can "guarantee a secure retirement." If the agent used those words in connection with a mutual fund, he likely committed a serious misrepresentation.

Mercer Bullard, a former SEC lawyer who now heads Fund Democracy, an advocacy group for mutual fund shareholders' interests, criticized the SEC's settlement as being too narrow and lenient. First, the $12 million First Command agreed to pay is only a fraction of the $175 million the SEC believes the company received in fees between 1999 and 2004.

"The SEC should have levied much more severe sanctions," Bullard said.


Yes. $12 million is pocket change in the financial services industry. When the SEC only levied 12 million in fines, there must have been dancing in the cubicles at First Command headquarters. They probably had a big corporate party to celebrate.

At the heart of the case is the concept of affinity marketing – using salespeople who have worked in the same field or have some other familiarity with their customers. It is especially effective in the military setting, Brewer said.


Now, let's not get stupid, here. There's nothing wrong with affinity marketing, and almost everyone practices it to some degree. All marketing is about making and exploiting a connection with a target audience. Most affinity marketing is too subtle for those outside the target group to even notice.

They also bad-mouthed the federal government's Thrift Savings Plan, according the the suit and the SEC order. The plan is set up much like a company 401(k) plan, with employees contributing monthly to low-cost mutual funds and the government providing matching contributions of up to 4 percent.

The characterizations of no-load mutual funds are "blatantly false," said Bullard. He said the Thrift Savings Plan is considered one of the most efficient employee investment plans in the country.


Bullard's right. If any First Command rep was badmouthing the Thrift Savings Plan on the basis of expenses, it's time to tar and feather them and run them out of town on a rail.

"This guy was good and convinced me to stick with it," Kimnach said. "I was only an ensign, and I couldn't believe he would steer me wrong."


Really?

Hey, ensign! Do me a favor and ask Master Chief Portman if he's got a box of chem light batteries and a can of rotor wash, will ya? And bring me a box of grid squares while you're at it!

Splash, out

Jason

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