Family First Life’s (former?) CFO, circa 2022, is alleged to have referred to the company’s compensation plan as a “Ponzi scheme”.

Integrity Marketing Group (IMG) own Family First Life, the insurance niche MLM company.

As alleged by IMG in a March 3rd, 2023 filed lawsuit, defendants Nicholas Ayala, Michael Killimett, Ryan Montalto and Matthew Smith

wrongfully induced Integrity to pay them millions of dollars in exchange for their businesses, material promises, and related services.

Defendants not only failed to live up their promises; it also appears that they never intended to do so.

Ayala, Killimett, Montalto and Smith are all cited as “former Integrity executive employee(s)”.

Nicholas Ayala owned Priority Life Insurance Agency LLC

Michael Killimett owned FFL Southeast

Ryan Montalto owned FFL United and

Matthew Smith owned FFL Northwest

IMG claims it bought the above entities from the Defendants in 2020.

Those insurance agencies – Priority Life, FFL Northwest, FFL Southeast and FLL United – then became wholly owned subsidiaries of Integrity.

As part of the acquisition, Ayala, Killimet, Montalto and Smith signed Employment Agreements with IMG.

Each Employment Agreement provided that each Defendant would “serve as President” of his respective Agency after Integrity acquired that Agency.

In a nutshell, IMG argues that, based on ongoing monthly financial reports, the Defendants failed to uphold their end of acquisition agreement.

At the time of Integrity’s acquisition of each Agency, each Agency was generating net income of between $600,000 and $1.2 million annually.

In 2023, each Agency reported negative annual net income.

Integrity provided each Defendant with monthly financial reports to asses the ongoing performance of his respective Agency.

Integrity identified severe and ongoing underperformance in connection with each Defendant’s management of his respective Agency.

On information and belief, each Defendant has failed to devote his best efforts, full business time, or attention, or all of them, to the business and affairs of his respective Agency.

In an attempt to address the collapse of the four Family First Life businesses, IML met with the Defendants in February 2023.

Integrity met with each Defendant to explain the steps the Defendant must take, consistent with his Employment Agreement, to improve his respective Agency’s business.

IMG followed up with “required immediate steps” demands and a “Partner Action Plan”.

At the time of filing its lawsuit, IMG claims

on information and belief, no Defendant progressed in taking the immediate steps required by the Partner Action Plan to improve his respective Agency’s business results.

IMG asserts that each of the Defendants instead were focused on “establish(ing) and operat(ing) his own independent marketing organization”. This would allegedly be a violation of the Defendant’s Employment Agreements.

By the end of February 2023 the Defendants appear to have had enough. On

🤖 Quick Answer

What allegations have been made regarding Family First Life's compensation plan?
Family First Life's former CFO allegedly referred to the company's compensation plan as a "Ponzi scheme" around 2022, according to statements cited in legal proceedings involving the insurance MLM company owned by Integrity Marketing Group.

Who filed a lawsuit against former Family First Life executives in March 2023?
Integrity Marketing Group filed a lawsuit on March 3rd, 2023, against Nicholas Ayala, Michael Killimett, Ryan Montalto, and Matthew Smith, alleging they wrongfully induced the company to pay millions of dollars through false promises regarding their businesses and services.

What positions did the defendants hold at Integrity Marketing Group?
Nicholas Ayala, Michael Killimett, Ryan Montalto, and Matthew Smith all served as former Integrity executive employees. Ayala owned Priority Life Insurance Agency LLC,

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