I have noticed no new material in years, but I noticed that the old marketers and the old "insurance" providers have changed.
My take is that the earlier promoters came to the conclusion that the product was questionable and not worth the risk in light of the tax shelter issues/penalties which did not exist when the concept was originally introduced. When there was little liability and enforcement, the commissions were attractive.
If the writers of the Opinion Letters have questions and enough concern to repeat the caveat, I would stay away. Then there is the issue raised by lvena.
