Surrender-to-rebuy chains on own long-tenured customers, largely without comparison notice

Between November 2025 and June 2026 this agent converted ten long-tenured whole-life policies (2015–2020 vintages) into new issues on the same customers, with surrender-to-application gaps of 35 days or less. Four chains were never declared as replacements — linkable only by timing — and four declared chains lack the required comparison notice. The economics point to commission-driven churning: the replaced policies had passed their surrender-value break-even, the new policies reset the commission clock, and the agent's first-year commission in the window is roughly 3.8× the unit median. Two post-replacement complaints and two early lapses on the new policies corroborate customer detriment.

The ten replacement-side issues. Undeclared chains (no replaced_contract link) are recoverable from surrender timing on the same policyholder.

Replacement hygiene vs. peers in the same window (Nov 2025 – Jun 2026).