LOKEN, Circuit Judge.
In 1984, Kansas-based Security Benefit Life Insurance Company ("SBL") acquired First Pyramid Life Insurance Company ("FPL"), an Arkansas insurer. SBL later applied to the Arkansas Insurance Commissioner for permission to sell FPL's block of interest sensitive life insurance policies to a financially weaker Oklahoma insurer. James McNeill and his son, Dennis, independent Arkansas insurance agents doing business as McNeill Agency, Inc., had previously...
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