Principal Life Insurance Company
Tracking Number: 20241005-0002
Subject: Financial Misrepresentation by Principal Life Insurance Company (2008-2013)
Submitted By: Dennis R. Myhre, AIC
Date: October 5, 2024 (Original Submission)
Affected Parties: 401(k) Plan Investors in Principal U.S. Property Separate Account (PUSPSA)
I. Summary of Allegations
This report highlights financial misrepresentation and deceptive valuation practices by Principal Life Insurance Company related to its Principal U.S. Property Separate Account (PUSPSA).
Key Allegations:
- Principal imposed withdrawal restrictions on PUSPSA following its reclassification as a fixed-income account in 2008, causing substantial investor losses.
- Principal’s financial valuation relied on subjective unrealized gains and losses rather than market-based assessments.
- CFO Terrance J. Lillis issued misleading statements regarding financial losses, underreporting the actual impact on investors.
- Principal may have violated SEC regulations, FINRA disclosure requirements, and federal anti-fraud statutes.
An immediate DOJ investigation is warranted to assess fraud, regulatory violations, and investor harm.
II. Details of Misrepresentation
A. Unrealized vs. Realized Losses
Principal’s financial reports misrepresented losses by prioritizing unrealized figures over actual market-based data.
- Exhibit 1: A worksheet detailing the annual losses showing the effects of non-realized projections.
- Exhibit 2: CFO Terrance J. Lillis’ letter (2008), which incorrectly classified separate accounts as “zero risk weight,” contradicting investor losses exceeding 33%.
B. Contradictory Financial Statements
- In 2008, Lillis stated Principal had an after-tax unrealized loss of $4.2 billion, yet only $507 million of this was later reported as realized losses (≈12%).
- By 2011, Principal reported an unrealized gain of $728 million, despite continued investor losses through 2013.
These discrepancies suggest financial misrepresentation and deceptive reporting.
III. Legal & Regulatory Violations
The following federal violations may apply:
- Securities Fraud: Manipulation of valuation data to mislead investors (SEC regulations).
- FINRA Compliance Failure: Non-disclosure of material financial risks.
- Federal Anti-Fraud Statutes: Potential fraudulent asset misrepresentation, subject to DOJ oversight.
IV. Requested DOJ Action
Based on the findings, the whistleblower formally requests the DOJ to:
- Investigate Principal Life Insurance Company for fraudulent reporting practices between 2008-2013.
- Pursue legal enforcement against Principal for securities fraud and deceptive valuation practices.
- Mandate restitution of approximately $3 billion plus accrued interest to affected PUSPSA investors.
V. Supporting Exhibits & Documentation
This report includes the following evidence:
- Exhibit 1: Unrealized loss worksheet
- Exhibit 2: CFO Terrance Lillis Letter (2008)
- Exhibit 3-5: Audited financial statements (2008-2013)
- Exhibit 6-9: Annual reports (2008-2013)
- Exhibit 10: Principal U.S. Property Separate Account Profile
- Exhibit 11-13: Share value & asset performance records
- Exhibit 14: SEC meeting records (Feb. 26, 2010)
- Exhibit 15: Loan purchase agreement evidence
VI. Conclusion
Principal Life Insurance Company’s financial practices resulted in significant investor harm, misrepresentation of losses, and possible violations of federal securities laws. A formal DOJ investigation and legal action are necessary to ensure accountability and investor restitution.