In July 1988, petitioner, a life insurance agent and broker licensed by the State of New York, was served with a citation charging "untrustworthiness and/or incompetency to act as an insurance broker and/or agent within the meaning of Insurance Law § 2110". Specifically, petitioner was alleged to have sold "memberships" in the American Motor Club, Inc. (AMC), an entity which was not licensed by the Insurance Department, in violation of Insurance Law §§ 1102...
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