Publications

March 3, 2025 – On February 26, 2025, Globe Life released its 2024 10-K. While management conveyed that it was business as usual there are several red flags in the 10-K and accompanying earnings call. Massive share buybacks were substantially funded by expensive debt. Policy acquisition cost growth continued to outpace premium growth. Lapse rates continued to climb. Agent growth slowed significantly, and agent counts shrank in December. The company saw rising legal costs and increased financial impact of litigation. Risk disclosures have been significantly expanded due to IT system weaknesses. This corroborates Viceroy’s views that Globe Life’s MLM-like operations are facing increasing headwinds from regulatory scrutiny and reputational problems. Operations are also beginning to suffer with life lapse rates increasing and policy acquisition costs continuing their upward trend.

February 17, 2025 - On June 14 2024 we published out letter to US insurance commissioners detailing Globe Life's data security failures. One of these vulnerabilities remains unresolved nearly 9 months later. Below is a redacted copy of a letter we sent to US insurance commissioners regarding this ongoing data security failure and Globe Life's complete failure to resolve it. To protect this information we have redacted the method of access and policyholder names, policy numbers and phone numbers. Significant policyholder data has been publicly available for at least 8 months, though we suspect it has been unsecured for far longer. This demonstrates a clear and persistent disregard for required data protection and management practices.

December 9, 2024 – On January 22, 2024, Globe Life sent a Legal Hold Notice (LHN) to several American Income Life (AIL) agents relating to identical subpoenas sent to Globe Life and AIL from the US Department of Justice (DOJ) though the US Attorney’s Office for the Western District of Pennsylvania (USAO). These are typically issued within an organization to preserve all relevant documents in anticipation of litigation, investigation, or legal proceedings. The LHN mandates the preservation of all documents and communications including: Those related to the financing, business, personnel and insurance activities of AIL agencies. Those related to insurance policies written by Arias Agencies and its affiliates including supporting documentation. All correspondence regarding Arias Agencies with the following individuals: Simon Arias, Justin Adams, Brody Evanson, Gregory Rudolph, Natalie Price, Tristan Dlabik, and Michael Russin. We have significant concerns that the LHN is not being complied with, putting at risk the integrity of the investigation by the DOJ and USAO. We have appended the LHN to the end of this report.  

December 5, 2024 – Globe Life issued a press release in response to Viceroy’s reporting on apparent agency closures across AIL’s network. Globe Life definitively stated: All businesses named in the report are still in operation: "Every single business named in the report is still in operation." Inaccuracy of disconnected phone numbers in the report: "We verified that the report listing of disconnected phone numbers is inaccurate and misleading." The response contradicts the facts: At least 3 of the properties for-lease were opened after the pandemic. The evidence that at least Arias-Dlabik and Arias-Diulus have shuttered is irrefutable. The websites and social media accounts for Arias-Dlabik, Williams Organization and Arias Diulus are inactive or have been deleted. An email was sent to all Arias Organisation agents this morning informing them that their company emails will be deactivated after December 31, 2024, is further contradiction of yesterday’s clumsy attempt to obfuscate the cascading agency closures: Globe Life is clearly covering up some sort of operational collapse in its agent network. Whatever is happening at American Income Life is being cause by another kind of disaster, not the COVID pandemic.

December 4, 2024 - Something is seriously wrong at AIL. The evidence is everywhere. Empty offices, disconnected phones, furniture fire sales, and no word from management. Several major AIL agencies appear to have shuttered their operations in early November 2024. Offices are being put up for lease and phone numbers are disconnected at multiple AIL agencies, with no announcement of their official closure. Viceroy searched online commercial real estate listings for available properties corresponding to agency addresses. The headquarters of several large agencies were listed as available for lease. Smaller agencies sometimes use virtual offices or co-working spaces and typically remained unlisted. Viceroy called the agency numbers listed on AIL’s agency website. Our phone calls to multiple agencies resulted in a disconnected dial tone or a message that the line had been disconnected. This included the headquarters of multiple major agencies. Phone lines for agencies representing more than 40% of AIL’s net sales in 2023 are disconnected. These possible closures have occurred in multiple states, despite agents retaining their licenses and appointments. This suggests a federal action against AIL as an organization instead of any agency-level action.

August 12, 2024 – On August 7, 2024, Globe Life published its 10-Q for Q2 2024 which contains several damning admissions about the company’s conduct and unexplained changes in disclosure. Globe Life management misled analysts and shareholders about the existence of an SEC investigation In its Q2 2024 10-Q, Globe Life finally disclosed that it received the first inquiry of the SEC investigation in April 2024, at least 2 weeks before management told JP Morgan it was not under investigation. The inquiries made by the SEC are no longer described as “informal, preliminary”, and the company is apparently subject to a formal investigation. Our analysis of Globe Life’s disclosures suggests the SEC has made at least 2 inquiries with the company. The 10-Q also contains multiple other changes in disclosure, despite the company claiming that the recently-completed independent investigation by Wilmer Hale and FTI Consulting found no fault in its reporting. No explanation is given for these changes. The company included a legal case last mentioned in its Q2 2022 10-Q, despite the last major event in the case occurring in Q1 2023. The company has changed the language around its performance metrics: net sales and first year collected premium. Globe Life spent over 85% of the $370mm high end of its buyback program guidance for 2024 in just two months. Globe Life drew a total of $345m in liquidity from their FHLB funding; regardless of the original purpose for this liquidity draw, it was effectively used to finance the buyback.

August 6, 2024 – On July 31, 2024, Viceroy published a report including the name of a former AIL agent who made repeated complaints of sexual harassment and the complete failure of Globe Life to investigate her claims. The same day Globe Life sent an email to the former agent about its investigation of the complaint. However, because this is Globe Life, the company has engaged Phillips Murrah, a hopelessly conflicted law firm whose remit appears to be shielding Globe Life from responsibility instead of a good-faith investigation. The full details of their conflict is in the report below.

July 31, 2024 – Globe Life’s Liberty National agents regularly misrepresent themselves as government employees to generate leads. This practice is instructed and mandated from the corporate level, and we believe is illegal. This, together with abundant evidence Viceroy have produced across 12 reports, directly contradicts Globe Life’s earnings call on July 25, 2024, where they implied that their extremely limited independent investigation had detected no issues with their processes. Management claims that the gross misconduct reported by Viceroy and multiple other parties is isolated to individual American Income Life agencies and agents. As we have shown, and will continue to show, this is absolutely false.

July 11, 2024 – Former Globe Life agents have sent Viceroy a trove of revealing Globe Life agent training materials hosted on www.thekeefersuccess.com. These training materials include multiple false claims and misrepresentations that agents are expected and encouraged to repeat to customers to close a sale. Viceroy has AI-transcribed these videos for the purposes of this report. An archived version of the site from July 2020 can be found at the link below. https://web.archive.org/web/20200720190057/https:/thekeefersuccess.com/ The bulk of the content on the website is in the form of videos of training sessions for agents already out in the field and include false claims, misleading sales tactics and outright fabrications, including: False claims of program exclusivity False claims of limited enrollment periods False claims that decisions must be made on the day of the presentation Misrepresenting when rate increases on other policies occur Fabricating sob stories including the deaths of family members Using beneficiaries as leads without the policyholder’s consent, which has resulted in formal complaints The videos also acknowledge that virtually every agent has misrepresented themselves as union representatives and alcohol use in the office. The significance of these videos cannot be understated, featuring top-producing SGAs and senior management promoting misleading – and in some cases illegal – conduct as the pathway to success at AIL

June 27, 2024 – On June 20, 2024, the SEC FOIA office responded to a Viceroy-instigated appeal to disclose any investigation and communication records between the regulator and Globe Life. Our appeal for these records was unsuccessful on the basis that Globe Life is under formal, active and ongoing investigation by the SEC’s Division of Enforcement. We reiterate that Globe Life’s management team has no intention of being transparent with shareholders. The problems for Globe Life will not go away, no matter how much management pretends that they do not exist. We delayed the publication of this document to see if the company would make any disclosure whatsoever to inform the market of these developments:  they did not.

June 14, 2024 – This morning, Globe Life reported it received concerns of vulnerabilities related to access permissions to consumer and policyholder information. This is a direct result of Viceroy having been able to evidence significant vulnerabilities in the data privacy and protection practices of Globe Life Inc and its subsidiaries. We report that Protected Health Information (PHI) records of Globe Life’s clients are freely accessible via online portals with universal login credentials distributed by agents across the web. While Globe Life reports that the vulnerabilities have been patched, Viceroy has still been able to re-access consumer and policyholder data. We do not intend to disclose instructions on how to access live data and have not retained exploited data except for the purposes of reporting it to regulatory authorities. We note that Health Insurance Portability and Accountability Act (HIPAA) violations carry severe penalties and attract expensive civil suits. Globe life fails to meet their legal obligations to safeguard policyholders' personal and private information.

June 7, 2024 – Former agents have informed Viceroy of several agents who continue to work for American Income Life subsequent to for-cause termination, writing fraudulent policies, or fraudulently recruiting agents. This includes agents who stand accused of multiple sexual assaults from multiple sources, an agent who pretended to be a licensed physician to clients and agents who wrote multiple fraudulent policies. It’s clear that Globe Life and AIL have no interest in vetting their existing agents, let alone ensuring that those who are submitting fraudulent policies and sexually assaulting other agents are no longer involved with the company. Not only is this a complete failure of governance, its further proof of the at-all-cost sales structure at AIL.