Iowa Insurance Division Suspends Agent’s License, Issues Statement of Charges

March 8, 2004

Larry Lavin, of Milford, Iowa, doing business as Lavin & Associates, is, for the seventh time since 1998, the subject of actions being taken by the Iowa Insurance Division in reaction to his sales activities.

His past reported activities in violation of the Iowa Uniform Securities Act resulted in his signing a Consent Order on
March 31, 2003. That Order required that he only sell products through and approved by a broker or insurance company. Further, it stipulated that his insurance license could be immediately suspended if further complaints were received by the Division alleging violations of either the Securities or Insurance
Acts.

While that Order was in effect, the Division reportedly received another complaint about Lavin’s sale of unregistered securities in the form of promissory notes in McCarn’s Allstate Finance.

An investigation of that complaint led to the discovery of additional violations of insurance and securities laws, including the sale
of unregistered securities in an entity known as Spencer Capital Growth, which reportedly appears to be just another business name for Lavin & Associates.

Insurance Division Assistant Commissioner Rosanne Mead said,
“Investors in that entity, consisting mainly of senior citizens, believed that they were investing in real estate, while the funds appear to have been converted for Lavin’s personal use.”

The Division notified Lavin on Feb. 26, 2004, that his insurance license was immediately suspended. A hearing to permanently revoke his license and assess fines and costs is set for April 13, 2004. He is reportedly not licensed to sell securities, and he had previously been prohibited from all sales activities in the above or any other unregistered securities.