Opal, age 75, has a $100,000 ordinary life insurance policy that has a cash value of $35,000. Opal is con- cerned about the cost of long-term care in a nursing home. A new agent of a national life insurer persuaded her to transfer the $35,000 into a deferred annuity. The agent told Opal that the annuity pays lifetime income benefits and also allows her to withdraw the $35,000 without penalty if she should enter a nursing home. After the policy was issued, Opal had ten days to change her mind. During the free-look period, a friend of Opal examined the policy. Analysis of the policy showed that only 10 percent of the cash value could be withdrawn each year without penalty. A 7 percent surrender charge would apply to any excess amounts withdrawn. In addition, the income pay- ments were scheduled to start in 10 years when Opal attained age