The AWC alleges that the significant potential risks posed by using mortgage proceeds to make securities investments and the high concentration level in the VUL investment, rendered the transaction unsuitable.

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My primary concern is that there has been insufficient disclosure of the potential risks to investors and of the intended use of the proceeds.

CENTERFORSECURITYPOLICY: Center For Security Policy

The net cash proceeds are prior to any adjustment for potential tax liabilities which are likely to arise from the sale of spectrum assets even after utilizing the existing net operating losses.

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