By looking at the hearing for Farm Mutual, it looks as though the responsibility and accountability should have been placed on the heads of Farm Mutual, rather than its employees. It clearly shows below that Farm Mutual itself bragged up and said the product was secure, as a matter of fact, very secure, and passed it to Mr Rainbird and others to sell. I cannot see for the like of me how the employees could have been disciplined for something that was not their fault! I believe injustice has been served here to Mr Rainbird and the other several employees that suffered reprimands under this decision.The source of the risky paper should have taken the rap, not the sellers of it. If you buy a brand new car from a dealer and it falls apart instantly, you do not charge the dealer, you have to go right back to the company that built the car, thats where the fault lies. The dealer is neither responsible nor accountable for a new car he sells, he is merely selling the product under the assurance that the product is up to standards and it is expected to be.

IMO

16. In September 2003, Farm Mutual's Manager of Compliance & Auditing had

distributed materials to Farm Mutual's branch managers describing the Debentures as

"highly-secured" and stating that the Debenture funds were "at significantly less risk than

typical investments in the equity markets". In October and November 2003, Farm

Mutual's President sent emails to the branch managers updating them on Farm Mutual's

due diligence review of FactorCorp, stating that Farm Mutual's legal counsel had

assessed the Debentures, and describing them as "an outstanding investment

opportunity."

17. On November 5, 2003, Farm Mutual's Manager of Compliance & Auditing began

approving advertisements describing the Debentures as "fully secured", with "guaranteed

rates" and "no market correlation or volatility". Subsequently, from November 2003

through July 2005, Farm Mutual's Manager of Compliance & Auditing approved at least

8 additional similar advertisements, including advertisements describing the Debentures

as "secured", as combining attractive growth "with reduced risk versus equity

investments", and as "a better alternative to GICs."

18. Based on the aforementioned materials, emails and approved advertisements, the

Respondents concluded that Farm Mutual had rated the Debentures as either a low or

medium-low risk product.