To induce a policyholder in Greensboro to surrender an existing life policy and buy a new one, a producer makes an incomplete comparison of the two contracts' terms. This conduct constitutes:

Why D is correct

Under G.S. 58-33-75, no producer may make any written or oral statement that willfully misrepresents the terms of a policy or makes an incomplete comparison to induce a policyholder to lapse, forfeit, surrender, exchange, or convert a policy. This is twisting, and penalties run through the civil penalty provisions of G.S. 58-2-70 and license action under G.S. 58-33-46.

Why the other options are wrong

• A is wrong because rebating involves giving something of value not specified in the policy; this scenario involves misrepresentation through an incomplete comparison, and nothing of value was given.
• B is wrong because defamation concerns false statements about a competitor's financial condition or business, not misleading comparisons made to induce a surrender.
• C is wrong because G.S. 58-2-180 addresses willful false statements under oath or subscription in required financial statements, not sales misrepresentations.

Memory hook

Twisting twists the truth to make an old policy look bad enough to surrender.