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    "seq": 44,
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    "ocrText": "Vocket %. 301\nHIS.\nof the commissions paid by Madison Financial 10 Madison\nwhich significantly decives all of Its business from\nredison financial.\nMany of the sales, which generated these commissions, were 10\nMcDougal-Henley Croun members who are neting \" straw buvers. Madison\nCustanty. essencially retained the risks of ownershin on these\ntransactions because 16 folls financed these salva including che cisa\nsales commissions. Thus. Madison Guaranty's position deteriorated\nKy\nbecause il retained the name uwnership risks \" before, bue paid C388\nfees to these individuals. in addition, fees paid through Madison\nRoal Farnea were used \" Jown Divments in some of the .1.00 18.16\npurchases in an apparent 10 disquise 100% funding of the\npurchase by Madison Cuarnnty and its subsidiariss.\nLet\nMesses. McDougal and Latham clied in April 24, 1985 letter from 8\nFederal llome Loan Bank of Dallas Supervisorv Agene as permission to\npay real egrate gaina commissions 10 Madison Real Estate. However,\nthis letter in part. Isks that the Board of Directors review\nInsurance Regulation 571.7 which 19 ciled above in this comment.\n?.\nMadison Marketing\nMadison Marketing is paid for : gine all the general advertising for\nMadison Guarancy and most of the adversising for Hadison Financial's\nland development projects 111 of Madison Harketing's business is\nderived from Hadison Concenty or its subsidiaries. Since 1983 these\npayments total $1,537,000. 11 February 1086. Sunan McDougal owned\nMadison Marketing. Durine 1 oortion of this time, it was a cor-\nnoration which was incorpotated by Lisa Aunspaugh, reportediv a close\nfriend of Susan McDougal.\nMr. Incham stated that after Februarv 1986, Madison Marketing became\n10 earice \"d/b/a (doing business 291\" for Madison Financial and cassed\nto be a corpotation. However, it is noe registered as a \"d/b/a\" in\nthe County records. Also. its checking account has never been\nrecorded on the books of Madison Financial.\nCiven the evidence of Madison Marketing's invoices, it is questionaole\nhow much of these advertising services sre actually performed be the\nfirm. The actual work ot Javer such 33 the design and\nproduction of commercials and crovidine 311 time or newspaper space,\nappears 10 be performed be where. Madison Yarketing spperently just\nDavs 11100 bills of other providers and adds , 15% lee of its own.\nStaminers estimated this tee 10 be approximately $200,000 since 1983.\nIt would appear that \"Jdison Cuaranty could have an employee pertorm\nsimilar work for much less money.\nup. Latham stated chst Madison Marketine made no payments to ann\n... kholders. This statement 1: false. is .1 cast of a test for such\nthe examiners discovered 1 vo remittances from Madison /\n\"arketing to Susan lieDoneal which total $50.000. This was a cess. and\nthere may be additional payments.\n1.\nRegiener's Construction\nDesigner's Conserverion certerns construction work on some of the\ndevelopment projects and \" same of the property securing Madison land\nGuaranty loans. :- 1083 ind to date in 1986. 5247,000 was\nwork of lean \"ertormed \" Madison Guaranty and its subsidisries. The naid for\nparty borrowers proceed- - 11d :, Cegizner , Construction on work for amount third\n19 unknown. Designer's Construction appears 10 be a"
}