Copyright © 2008, Greenwich Financial Management Inc., a registered investment advisor.
The following discussion is meant to help persons considering life insurance policies on their own lives or that of loved ones. It is intended to aid understanding of: what life insurance is; the different kinds of life insurance; how to analyze life insurance as an investment; financing options available to pay life insurance premiums; and current market trends. The discussion covers many topics in a summary way and is definitely no substitute for customized advice from an investment advisor or insurance agent based on analysis of individual needs.
Question: What is life insurance and what are the major types of life insurance policies?
Answer: There are two periods of life insurance: term and permanent. Term insurance contracts afford the policyholder life insurance coverage on an insured person for a defined period. Of all types of insurance policies, term life offers the least expensive coverage per year in the short term. The contracts are typically renewable without further underwriting until the insured reaches a certain maximum age, such as 75. Many policyholders abandon term life as they grow older and premiums skyrocket. “One year term” means that the rate resets upward every year. “Ten year term” means that the rate is locked for the first ten years, jumps in price at that time, then increases incrementally in each year thereafter (and similarly for “twenty year term,” etc.). Some term life policies are convertible into permanent policies, usually whole life, at the rates prevailing when converted.
With permanent insurance, in contrast to term life, the policyholder can maintain coverage until the death of the insured,[1] assuming premiums are paid as required; the premium payments are exactly level or relatively level. In effect, you pay much more in early years than you would with term life, in exchange for the benefit that your premium doesn’t keep going up (exponentially) as it does with term life, and for the equity you develop in your policy, called “cash value.” Whole life and universal life policies can develop this cash value, but term life by definition never will. In the event that a permanent life insurance policy is “lapsed,” or allowed to expire (usually after exhausting any cash value available to keep it in force), the insurance company issuer receives a windfall, as there will never be a death claim to pay. A certain rate of lapse is assumed in most insurance company underwriters, allowing them to price policies more aggressively; such assumptions are a sensitive matter to insurance companies and aren’t bandied about.
There are in turn two kinds of permanent insurance, depending upon who takes the risk concerning overall rates of mortality and administrative expenses. In “whole life,” the insurance company takes the risk that death rates or administrative costs may exceed actuarial expectations, and obliges itself contractually to accept a level (or “constant”) periodic premium payment from the policyholder in return for providing a certain death benefit. In “universal life,” the policyholder takes the risk that mortality rates or administrative expenses may go up, and in the case of at least one reputable insurance company, the policyholder also has enjoyed a benefit if mortality or administrative expenses go down (mortality rates have been declining historically, owing to better sanitation and nutrition and advances in medicine and pharmaceuticals). Universal life contracts are much more flexible than whole life, allowing many variations in contributions over time. Because the premiums on universal life are typically arranged to be low in the early years and to increase rapidly in later years, the lapse rates on universal life are extraordinarily high. [2]
Finally, there are two kinds of universal life: standard and variable. In standard universal life, the cash value of the policy is guaranteed to advance at a certain minimum rate, assuming the expenses stay the same; the insurance company makes the investments itself (primarily in bonds and bond-like instruments) for the group of policyholders. In variable universal life, the policyholder decides on investments from a menu of mutual funds or variable annuity sub-accounts (held in segregated custody for the benefit of the policyholder) and can make periodic changes; here, the policyholder takes the mortality risk and all of the investment risk, with the goal of superior performance.
The bottom line: a permanent life insurance policy contains implicitly an important option relevant to an investor. This option is the right to keep the policy in force indefinitely at a pre-agreed premium ledger, regardless of changes in health status. When the health status of the insured person falls below what an insurance underwriter anticipated in setting the policy premium ledger, such that life expectancy is significantly shortened, then the potential desirability of the policy from an investment perspective increases. This option is the very foundation for the life settlement market, to be discussed below.
Question: What are the potential tax benefits of permanent life insurance?[3]
Answer: There are significant tax benefits related to life insurance for high net worth persons. Virtually every serious exercise in tax and estate planning considers life insurance as a component. We will discuss here four potential tax benefits you can obtain through life insurance policies. Each is considered uncontroversial and well-accepted by law.
The first large tax break regards the “death benefit,” which is the money payable to the beneficiary of a life insurance policy in force when the insured person dies. The death benefit, paid in a lump sum, is entirely exempt from income tax. The benefit can be very helpful when there is estate tax to pay and assets are tied up in illiquid investments, especially where the family desires to hold onto those assets or sell them at the best time and price. If the beneficiary decides to annuitize the death benefit, then the future interest portion but not the principal will be taxable.
The second tax benefit is growth of the cash value of the policy without income tax (since a Tax Court decision in 1963). The cash value is the equity in a whole life or universal life policy. The growth of the cash value is untaxed, and no federal tax report goes out to the policyholder or the IRS, even though the investments made by or on behalf of the policyholder might otherwise lead to realization of ordinary income or capital gains. This benefit does not apply, however, to term life, which does not develop cash value. So-called “dividends” normally represent premiums paid earlier on a whole life policy; these are not subject to income tax either.
A third advantage is that the policyholder may also borrow against the cash value of a life insurance policy, to the extent of any premiums paid to date, without tax effect. [Limits: where borrowing exceeds premiums paid, or when the policy is deemed a “modified endowment contract” (MEC). Advisors usually structure tax shelter oriented policies to include periodic premiums equal to the maximum non-MEC amounts.] Typically, interest paid is credited back to the policy’s cash value, so the borrowing is effectively free or of minimal cost.
A fourth benefit is exemption from estate tax on the estate of the insured, when the future proceeds to a beneficiary (or beneficiaries) are transferred to an irrevocable life insurance trust (ILIT). (Alternatively, your intended beneficiary could apply for and purchase insurance on your life, assuming that person has an “insurable interest.”) A properly structured trust places the property outside probate and the estate tax system. Exception: if you transfer property to an ILIT, but die within three years, the transfer may be subject to estate tax as made “in contemplation of death.” Your trust and estates attorney may establish “Crummey powers” within the ILIT to allow your contributions to qualify for the $12,000 per person ($24,000 for a married couple) annual exclusion from gift tax. However, the cash value of an existing policy transferred to an ILIT could still be subject to gift tax or reduce your lifetime exclusion. Frequently, ILIT’s provide a tax-efficient way to transmit wealth upon death to the next generation.
Background on estate taxes: For tax year 2008, under the federal Unified Estate and Gift Tax, up to $2 million is excluded from a person’s estate (minus amounts used up during that person’s lifetime, for example, by gifts); this excluded amount is scheduled to increase in future years up to $3,500,000 in 2009. The maximum marginal estate tax is 45%. The estate (but not gift) tax is slated to cease in 2010, then returns back to a $1,000,000 exclusion and maximum 55% rate in 2011, under a crazy-quilt “sunset” provision that Congress enacted. Unless you expect to die exactly in 2010, not planning for estate taxes could be costly. Elimination of the Estate Tax has been a stated priority of the Bush Administration, but the Democrats have opposed it, and this is a presidential election year. A likely political compromise would be to preserve the $3,500,000 exclusion (or slightly greater amount) after 2009 rather than to allow the sunset provision to take effect. The current financial and fiscal crisis obviously reduces greatly the possibility of imminent elimination of the Estate Tax in the near future.
Question: Can an insurance policy ever be worth more than its surrender value?
Answer: Traditionally, the money value of a permanent life insurance policy equaled its cash value minus surrender charges (if any). However, more recently, an alternative valuation of a permanent life policy—sometimes higher—is available through the secondary market for viatical settlements and life settlements.
Question: What is a viatical settlement? What is a life settlement?
According to industry nomenclature, a “life settlement” is the sale of a policy by the policy owner to a third party, except for “viatical settlements.” Viatical settlements entail the sale of a policy to a third party, where the life expectancy of the insured person, as certified by a physician, is two years or less.[4]
The secondary market for viatical settlements first attained significant size in the wake of the first wave of the AIDS crisis, in the late 1980s. Numerous ill men sought to sell permanent life insurance policies in order to raise money for medical treatment while still alive. The possibility of selling the policy for more than its cash value became tangible because at that time the life expectancy of AIDs victims was considered very short and the disease invariably terminal. The later development of a cocktail of medications that could inhibit the HIV virus for long periods led to a vast change in expected mortality for AIDS infected persons. As a result, many investors in pools of such policies were disappointed, and the sponsors of such investments were often sued. As an unsavory residue from this era, other sponsors were later accused of creating insurance mills in which known AIDS infected persons obtained new life insurance policies by providing fraudulent medical information. The subject of “viatical settlements” retains an unsavory reputation in some quarters. However, both life settlements and viatical settlements have legitimates uses; trust fiduciaries increasingly feel a responsibility to consider the life settlement market as an alternative to surrender of a life insurance policy, where discontinuance is being considered.
Out of the market for viatical settlements, a different market arose for life settlements, particularly for those with chronic illness and highly reduced life expectancy (but greater than two years), and to seniors aged about seventy or greater. Even for such seniors, there is the possibility but not the certainty that any given policy on an insured person might find a market bid from some investor greater than the policy’s surrender value.
Question: Who are the major players in the life settlement market?
Answer: The life settlement industry, although relatively young, is stratified (both by practice and to some extent by regulation) into distinct categories of activity, although occasionally these overlap.[5]
Those who arrange or facilitate the sale of a life policy to a life settlement provider, or another life settlement broker, are known as life settlement brokers. Such brokers are not the contractual buyer of seller of policies; they are arrangers. In life settlements, the brokers act as agents of the life settlement provider, not the consumer, a fact that is not always clearly understood. There are several hundred licensed life settlement brokers in the different states.
Those who act as the contractual purchaser of life settlements are considered life settlement providers under the laws of many states. In the majority of cases, life settlement providers are not principals either, though they can be; they typically act as agent of behalf of end investors. There are approximately twenty rather active life settlement providers.
Life insurance agents, generally speaking, act on behalf of the insurance carriers they are appointed with; this is a murky area, however, and the agents also have specific responsibilities to consumers under state laws. Agents may be either “independent”—associated with multiple carriers—or “captive.” Captive agents include the majority of those associated with Northwestern Mutual Life and Metropolitan Life. Independent agents, especially smaller ones, are not allowed to deal directly with insurance carriers, but instead must deal through a wholesaler called a “general agency.”
End investors in life settlements buy life settlements to hold, not to resell Among the most aggressive investors in recent years have been German mutual funds dedicated to life settlements.[6] Europe lacks a developed market in universal life insurance policies, so fixed income investors seeking life settlement opportunities must look to the US.
Clients sometimes ask: why not deal with the end investors, cutting out the middleman? However, for the most part, the end investors wish to deal exclusively with wholesalers, namely, the life settlement providers. The brokers add value by providing access to numerous life settlement providers. However, the client’s best interests are served when life settlement commissions are reasonable and fully disclosed. In the end, receiving the highest possible net price is the goal, and the intermediaries are a means.
Question: What is the tax treatment of life settlements?
Answer: There are several questions regarding the tax treatment of life settlements that have not been clearly resolved.
The proceeds of a life insurance policy, payable in a lump sum at death, are generally exempt from income tax to the beneficiary.[7] However, if the “transfer for value” rule is violated, this income tax-free treatment is lost.[8] The transfer for value rules are complex, but the market consensus is that a life settlement investor is not entitled to income tax free treatment of the death benefit.
If income tax might be payable on receipt of life insurance proceeds by an investor, there is then the problem of calculating gain, which turns in part on establishing a cost basis. The IRS has held in several situations that premiums paid to keep a policy in force may be included in basis, but against such payments a deduction should be made for the value of the insurance benefit received. [9] As a practical matter, the IRS guideline appears to be that basis is increased (or decreased) by augmentation (diminution) in the cash value of a policy, not by the mere payment of premiums.
If a life settlement is a capital asset in the hands of the life settlement investor, and it is held for at least one year and a day, it might be eligible for favorable long-term capital gains treatment. This appears to be a cogent position, but it is not explicitly supported by the Code, regulations, or private letter rulings, nor is it clearly presented and resolved by case law.
Question: If I look at my policy as an investment, how should I value it?
Answer: The valuation of an insurance policy is different in some key ways from other financial assets. One key variable is the timing of the death of the policy holder, which is uncertain, but about which one can make an estimate, especially with the help of complete medical records from the insured. Such records are in practice submitted to a third party life expectancy estimator, of which about seven are established in the market. A second key variable is the schedule of premium payments laid out in the original life insurance contract, as updated by an in-force policy illustration. Unless such premiums are paid on schedule or at least within the allotted grace period, the policy will lapse and become void.
The market standard for analytical software to calculate the value of life settlements is Milliman [see www.Milliman.com]. The Milliman software takes the key financial variables, as inputted by the user—that is, the illustrated premiums to keep the policy in the force and the life expectancy of the insured—and from these, calculates a present value and a predicted internal rate of return.
Question: How is life expectancy calculated?
Answer: The underwriting department of each insurance company calculates life expectancy of a proposed insured, based on the submitted health questionnaire, complete medical records, and a fresh medical exam and tests supervised under the auspices of the carrier. Investors do not have access to this information gathered by the carrier. Instead, investors seek life expectancy reports from independent, third party life expectancy consultancies. Of the life expectancy estimators, probably the foremost are American Viatical Services, or AVS, and 21st Services. AVS estimates of life expectancy, are generally regarded as among the most conservative by investors; “conservative” in this context means that their bias is toward longer life expectancies, allowing investors to pay a lower price for each policy given some stated internal rate of return. 21st has been moving toward longer life expectancies recently, partly in response to newly released insurance industry mortality data. Other life expectancy estimators in include Fasano Associates, which is also considered conservative. Among estimators considered more aggressive by some investors are EMSI and Midwest. End investors differ to some degree in the credence given to particular estimators. A typical approach of investors, though, is to request three estimates, of which two must be from AVS and 21st Services.
Question: Suppose I intend to hold my policy for a short time and then sell it at a profit, thereby repaying the loan. Is this permitted?
Answer: The answer has two parts. First, it is well established under American law that a valid insurance policy is a form of property, like a stock or bond, which can be sold by the insured or policy owner. Justice Oliver Wendell Holmes wrote a famous opinion in a Supreme Court case enunciating this principle. [10]Second, however, an insurance policy can only be initiated by someone who has an “insurable interest,” which can be thought of in crude terms as the interest of someone who would rather see the insured person alive than dead. This could be a close relative, a spouse or a business partner, for example. The law seeks to discourage “speculative” or “gaming” interests in life insurance policies. If you take out a policy only with the intention to resell the policy at a later time, an insurance company may be able to argue that you lacked an insurable interest in the life of the insured person. This is a ground for voiding a policy in all fifty states during the contestability period (the first two years of the policy, as defined under state law), and in a few states the lack of insurable interest may arguably be a ground for rescission indefinitely.
Question: What is life insurance arbitrage?
Answer: Life insurance arbitrage consists of the analysis of a life insurance policy to an insured person, where the decision of whether to initiate or continue the policy is determined by a hard-headed analysis of whether the likely economic benefits exceed the pre-determined cost of carrying the policy and paying the premiums (and also interest payments, if borrowing is involved) until either the death of the insured or sale of the policy into the secondary market.
Classical financial arbitrage entails the exploitation of a risk-free profit by the simultaneous buying and selling of securities into two markets. Such risk-free profit is not available in the life insurance policy market. More loosely, though, the purchaser of a policy may make sound comparisons of policies, properly equilibrated in terms of illustrated cash flows, as to cost.
Question: What steps have insurance carriers taken to prevent arbitrage of their insurance policies?
Answer: The insurance carriers and their advocates label any life insurance policy that is initiated with the intention to resell that policy at a profit to investors as Investor Owned Life Insurance (IOLI) or, more pejoratively, as Stranger Owned Life Insurance (STOLI). The insurance carriers have taken several steps to inhibit writing of IOLI/STOLI policies. First, they have reduced the assumption on the percentage of life insurance policies that will lapse, which has had the effect of raising the cost of insurance, especially for those persons over 65 to 70 years old. Second, they have alerted their insurance agents that they will discipline those who promote life insurance arbitrage schemes, including termination of appointment. Third, they have pursued in selected cases actions in state courts to rescind existing life insurance policies, where they believe there have been abuses in the nature of STOLI.
Question: When does it make sense to borrow money to fund a life insurance policy?
Answer: It can make sense to leverage a life insurance policy under several scenarios:
1. where there is a need for life insurance, but temporary conditions require borrowed funds to do so.
2. as part of a long-term plan to invest in life insurance, where the projected rate of return on the investment is higher than the borrowing rate.
Question: If I borrow to fund a life insurance policy, is my interest deducible?
Answer: No. Under Section 51(1) of the Internal Revenue Code, interest payments on a loan used to fund a life insurance policy are not deductible. Congress considers life insurance a highly tax privileged form of investment and declines to afford this additional benefit. [As I have also explained online at the site WikiAnswers.com.]
Question: What kind of risk do I take if I borrow to fund a life insurance policy?
Answer: It depends on the type of loan. With a “collateralized loan,” the borrower posts hard collateral, such as cash, cash value in a life insurance policy, a control agreement over a securities account, or real estate (and also, frequently, a personal guarantee). Under a “full recourse” loan the borrower personally guarantees the full interest and principal of the loan, but the borrower posts no collateral other than the life insurance policy itself. If you default on a full recourse loan, the lender can sue you. Under a “non-recourse” loan, the lender has no personal recourse to you; the loan is backed solely by the life insurance policy, without an accompanying promissory note. Under a so-called “hybrid” loan, the borrower guarantees, or backs with collateral, part but not all of the loan. The risks of borrowing may come home to roost in the event that the policy loan becomes due, if the surrender and/or market value of the policy is insufficient to repay the loan in full, or if repayment cuts excessively into the expected residual value after loan repayment.
Question: Why would anyone guarantee a loan or collateralize it, even in part, when a non-recourse loan is available?
Answer: There are three major reasons. The first is that life insurance carriers are implacably opposed to life insurance policies funded by non-recourse loans. Their insurance applications will ask if there is any borrowing to fund the policy. If you answer truthfully, as you must by law, the insurer will then ask much more detailed questions of you, and your insurance agent, including whether the loan is non-recourse. If the insurer discovers that it is non-recourse, they will reject the application, as they have a right to. The second reason is that interest rates are much higher on non-recourse loans. A fully collateralized loan may run at LIBOR + 2%. A hybrid loan may run LIBOR+ 5%. A non-recourse loan may charge an interest rate of LIBOR + 14% or a fixed rate of 18-20%. Such extremely high rates will substantially eat into policy value after repayment of debt, and they could well make the life insurance packaged with the loan a bad investment.
The fact is that only the lowest interest rates can possibly support borrowing of all or substantially all of the premiums on a life insurance policy for the long term, such as until the death of the insured person. This is why a collateralized full-recourse loan is the only suitable choice for any person seeking to finance a life insurance policy for the long term.
Question: Why would a borrower consider a hybrid program, then?
Answer: For some, the hybrid programs offer the best combination of risk and potential reward. Under such programs, the borrower may guarantee only ¼ of the total principal and interest (on a first loss basis) and may defer all interest payments for two to three years. Under another variety, the borrower may guarantee only 1/10 of the principal and interest but make regular interest payments rather than deferring them. The signal advantage over the non-recourse programs is that by definition, a hybrid program is approved by certain insurance carriers. Therefore, the insured may declare on the application, this policy is funded with a loan from the carrier-approved hybrid program and not face automatic rejection.
Question: Suppose I went with a non-approved program and did not declare the financing on my insurance application, and the policy is subsequently put into force via such borrowing? What could happen?
Answer: The carrier could later argue that the policy is voidable and seek to rescind. The carrier would return the premiums paid to the policy owner. It is well agreed that the insurance carriers have grounds for policy rescission—given a material misstatement or omission on the policy application--during the contestability period.
Question: How has the current credit crunch affected the value of life insurance as an investment, particular for seniors?
Answer: There have been cross-cutting factors, both positive and negative, but mainly negative. The positive factor has been interest rates. The interest rates on US Treasury notes and bonds are very low, in part because the monetary position of the US Fed (as well as many foreign central banks) is very accommodative. On the other hand, the spread between the yield on many risky fixed income assets--including high yield bonds and investment grade corporate bonds--and US Treasuries has been rising. Life settlements compete with such assets for investor demand. As a result, the quoted yields on life settlements have been rising sharply, that is, the money value of life settlements has been falling. The credit quality of top insurance carriers in the United States has even been questioned in the current chaotic environment. Whereas a life settlement might have fetched a bid as low as 10% in October of 2007, currently (October 2008) the same investor may seek a yield as high as 14% to 15%, and some investors have dropped out altogether.
Question: What advice do you give to those considering life insurance as a risk control measure and investment?
In recent years (especially since about 2004), the speculative element of life insurance has been has been highlighted by the growth of the secondary life settlement market. This has led to rapid growth in the amount of life insurance put into force, particularly for seniors. I expect this speculative element to recede.
As to life settlements of existing policies--or as a prelude to replacement by a more suitable or more price efficient policy--this option will increasingly be considered as an alternative to policy surrender. Moreover, the availability of this option is unambiguously pro-consumer. Because overall mortality rates continue to fall, opportunities will arise to replace existing policies, embodying historic mortality costs, with lower priced alternatives (holding credit quality of the insurance carrier constant).
As to the role of financing, expect these trends:
1. The disappearance of non-recourse financing as an option for life insurance financing--because of carrier and state regulator opposition, the drying up of financing sources, and the prohibitive interest rates that are charged even when such financing is made available.
2. The continuation of certain “hybrid” programs with approved carriers, typically for transitional situations that do not call for lifetime premium financing, or where the possibility of a future life settlement is being kept open as an option by the borrower.
3. The continuation of collateralized full-recourse lending as the only viable choice for long-term lifetime funding of life insurance policies.
As a result of these trends, I foresee a massive decline (by 30-50%) in the face amount of new life insurance policies put into force. Such decline in new cases will put additional pressure on the domestic insurance industry, which already was suffering from over-capacity. As a result of this competitive pressure, we will see a wave of consolidation, including merger and acquisition activity and state efforts to rescue more marginal carriers.
One potentially positive factor for the carriers: some investor-owned policies may be abandoned (lapsed), contrary to expectation, which (depending on mortality experience) could benefit the issuer of the policy.
In the current market, expect a return to greater emphasis on life insurance fundamentals. Traditionally, some of the main motives for taking out life insurance policies included: income replacement for survivors; provision of adequate liquidity to pay estate taxes at time of the death of the insured person, and protection of businesses against the risk of death of key persons (“Key Person” insurance), or to buy out business partnership or LLC membership interests from the estate of a deceased person (“Buy/Sell Agreements”). I believe these traditional motives should be the governing ones in most cases today where additional life insurance is being considered.
[1] In the past, life insurance coverage under the ledger was assured until age 100; more recently, some policies offer a rider extending coverage indefinitely past age 100 until the death of the insured person.
[2] Some have inferred from information provided by the Insurance Information Institute that the lapse rate on universal life policies is approximately 90%. See http://www.lisassociation.org/vlsaamembers/news/files/lisanews_5_march_2007_Be_Alert_to_The_Truth_About_Stoli_Alert.pdf, a polemic piece by the life settlement trade association.
[3] This memorandum does not present expert tax advice customized to the needs of a particular individual or family. The author does not practice accounting or tax law. To receive such expert advice, please contact your accountant or tax attorney.
[4] The Health Insurance Portability and Accountability Act of 1996 provides for tax free treatment of the proceeds from viatical settlements. The proceeds from such payments, under a special favorable treatment, are free of federal income tax. By contrast, an Accelerated Death Benefit (ADB) is provided by the insurance policy carrier to a similar insured person with two years or less of certified life expectancy, under the terms of a rider attached to the original policy. The proceeds from an ADB are generally considered to be “ordinary income.” See “New Tax Free Treatment of Viatical Settlements,” CPA Journal Online (2008), http://www.nysscpa.org/cpajournal/1997/0597/features/f30.htm.
[5] For discussion by the leading trade association in life settlements, the Life Insurance Settlements Association (LIFA), see http://www.lisassociation.org/public/glossary.html.
[6] This is driven by the US-German Taxation Treaty, which is interpreted to allow the transfer of proceeds from life settlements without US withholding tax.
[7] IRC §101.
[8] IRC §101(a)(2).
[9] See advice of the Chief Counsel of the IRS, CCA 200,504,001 (2004) and PLR 9,443,020 (1999).
[10] The insured, John Burchard, had paid two insurance premiums on his policy, but he then fell short of cash and needed to pay for surgery. He sold the policy to Dr. Grigsby for $100. Burchard died with the policy in force. The issue presented was whether the death claim should be paid to Burchard’s estate or to his assignee, Dr. Grigsby, and the decision hinged on whether the assignment was valid. Grigsby v. Russell, 222 U.S. 149 (1911).
Andrew Szabo CFA is managing director of Greenwich Financial Management Inc., a registered investment advisor. Questions--call 917-796-8500 or e-mail Szabo@GreenwichFinancial.com).
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