✖ we had duties

duty = once you touch my money, health data, signatures, or billing, the law decides what you must do next.
not vibes. not favors. obligations.

when licensed reps handle my financials or medicals, they take on legal duties.

this isn’t “thanks for your time.”

this is: you’re now responsible for what you did.

✱ the financial cast

✨ross — onboarding optics
✨trish — financial planning / advice + intake
✨jess — assigned fror → med intake → underwriting
✨katie — servicing rep + billing confusion queen

✱ the vibe

collect data / assign a rep / take payment / make a recommendation = relationship.

you built the lane. now lie in it.

✖ ross

the doorway (onboarding optics)

what happened
💼 summer 2023: ross requests in office meeting with spouse, frames household onboarding, firm logistics start moving. i didn’t chase them. they initiated.

why duty attaches
inducement → reliance. frame the relationship = own the obligations.

their response
📝 admit: ross was involved.
🚫 deny: “no duty, just vibes.”
⚠️ contradict: later admit reps serviced + billed me.

law they tripped

• restatement (second) of torts § 552

• finra rule 3110(a) (supervision over rep activities)

• restatement (third) of agency § 2.03 (apparent authority)

✖ trish

the spreadsheet moment (financial intake)

what happened
🗂️ july 2023: full data sweep — income, biz revenue, tuition, insurance, ira plans — plus “one profile” consolidation pitch. not brunch. data possession.

why duty attaches
holding nonpublic personal info (npi) triggers: confidentiality, purpose clarity, competent handling (supervision + safeguards).

their response
📝 admit: licensed rep + meeting happened.
🚫 deny: “no fiduciary duty.”
⚠️ contradict: later say jess sold + serviced everything. pipelines don’t sprout overnight.

law they tripped

• glba, 15 u.s.c. § 6801–6809

• reg s-p, 17 c.f.r. pt 248 (privacy + safeguards)

• finra rule 2210 (no misleading comms)

• restatement (third) of agency § 8.11 (duty of care with data)

sep–oct 2023: paperwork → nurse at my door

what happened
📄 sep 2023: firm funnels me the medical history / paramed paperwork (ten-year disclosures).
🏠 oct 2023: a nurse comes to my condo for the paramed exam (vitals, fluids, identity checks). data capture happens in my living room under their process.

why duty attaches
once you initiate health-data collection and send a medical contractor to my home, you’ve crossed from “interest” into active processing:
privacy duties, clear purpose/use, secure custody, and supervision over everyone touching my NPI (nonpublic personal info). the pipeline is live months before jess is assigned FROR.

their response
📝 admit: medical workflows ran; paramed exam occurred.
🚫 deny: try to call it “preliminary” or “routine.”
⚠️ contradict: later claim i wasn’t their “client,” while holding my labs and pushing underwriting.

law they tripped

• reg s-p, 17 c.f.r. pt 248 — privacy & safeguard rules for customer info

• glba, 15 u.s.c. § 6801–6809 — protect nonpublic personal information

• hipaa business-associate logic (by function) — if you route a medical vendor to me, you must control use/disclosure (even if you’re not a covered entity, your vendor management must not leak my data)

• finra rule 3110 — supervise third-party interactions tied to customer onboarding

• restatement (third) of agency § 7.07 — firm liability for agents/contractors acting with apparent authority

translation: you don’t send a nurse, take my blood, then pretend you don’t owe me privacy + supervision. the minute the cuff hit my arm, the duties attached. ✶

—

✖ jess

fror assignment → medical history → e-signs → underwriting

what happened
📆 jan 12, 2024: assigned as my financial rep of record; sends 10-year medical history form
🖊️ jan 23–28: adult e-sign packets (me + husband)
💸 feb 9: welcome to underwriting (draft schedule, jess listed)
📩 apr 18: corporate email: “you are a client of jessica tenenbaum.”

why duty attaches
assignment + health data + e-signs + underwriting = privacy duties, accurate servicing, firm supervision.
you don’t underwrite me then claim i’m “not a client.” that’s delusional.

their response
📝 admit: yes to all.
🚫 deny: “no broader duty.”
⚠️ contradict: used my data + serviced my file, then disowned me. sir, that’s your questionnaire in my inbox.

law they tripped

• finra rule 4512 (customer/rep records)

• reg s-p, 17 c.f.r. § 248.10 (limits on sharing health/financial data)

• restatement (third) of agency §§ 8.01–8.12 (duties created by conduct)

• c.r.s. § 6-1-105(1)(e) (deceptive trade practices)

✖ katie

servicing + billing logic meltdown

what happened
📉 their claim: lapses — husband + child feb 19, 2025; mine may 9, 2025
📬 mar 25: bill lists payer: samantha lowe on husband’s policy
👶 may 28: new child policy issued to me as owner/payer
📮 jun 10: letter: “keep this coverage from ending” if paid by july 8

why duty attaches
servicing disclosures must be coherent, timely, truthful.
you can’t block me as “non-owner” while dunning me as the payer of record. pick a theory.

their response
📝 admit: dates, issuance, billing.
🚫 deny: “nothing misleading.”
⚠️ contradict: if it “lapsed” may 9, why beg on june 10 to “keep it from ending”? calendar said: you lie.

law they tripped

• c.r.s. § 10-3-1104 (unfair/deceptive insurance practices)

• restatement (second) of contracts § 90 (promissory estoppel)

• finra rule 3110(b) (supervise written customer comms)

• sec truth-in-billing principles (status must match charges)

they wrote the story, then tripped over it

on paper, they admit
• reps assigned • jess “sold + serviced” • katie is servicing rep
• i’m owner/payer of the new child policy • they supervise reps

translation
you don’t get to—
✖ collect my data ✖ assign reps ✖ underwrite me ✖ bill me ✖ call me a “client”
…then say “we owed her nothing.”

law they tripped

• finra rule 3110 (firm responsibility for supervised persons)

• reg s-p / glba (privacy + safeguards)

• restatement (third) of agency § 7.07 (firm liable within apparent authority)

• common-law fiduciary/confidential duty by conduct (control + reliance + custody)

🖊️ sep, 2023 — first medical request
🩸 oct 2023 — nurse home visit (paramed exam at my condo: health data collection starts)
📋 jan 12, 2024 — fror assignment + medical form sent
🖊️ jan 23–28, 2024 — adult e-sign packets issued
💸 feb 9, 2024 — underwriting confirmation (draft schedule, rep listed)
📩 apr 18, 2024 — firm: “you are a client of jessica tenenbaum”
📬 mar 25, 2025 — bill shows payer: samantha lowe
👶 may 28, 2025 — new child policy issued to me (owner/payer)
📮 jun 10, 2025 — letter: “keep this coverage from ending”

they treated me like a client when it paid,
and a stranger when it cost.

they built the pipeline.
they touched the data.
they billed the bills.
they signed the emails.
then pretended none of it happened.

not a misunderstanding.
not a mistake.
✖ a legal fxcking failure.