A lawsuit filed in federal court alleges that a large insurance distribution network systematically misled both consumers and its own agents through deceptive marketing tactics and restrictive business practices. The case centers on claims that the network’s structure left agents financially dependent while consumers were solicited with misleading promises about mortgage protection products.
The complaint was filed by Jackson Young Brooks in the United States District Court for the Western District of North Carolina on March 10, 2026, naming Quility Insurance Holdings, LLC; Symmetry Financial Group, LLC; Quility Financial Advisors, LLC; and several individuals as defendants.
According to the filing, the defendants operated a nationwide system that generated revenue by sending out mortgage-referenced solicitations to consumers. These solicitations allegedly gave recipients the impression that responding would protect or pay off their mortgages. The responses were then sold as leads to insurance agents like Brooks. The plaintiff claims that while agents were recruited with promises of running independent businesses and owning their client books, actual control remained with the defendants through proprietary digital platforms and centralized policies.
Brooks states he was recruited under representations that he would operate independently with broad access to multiple insurance carriers. However, he alleges that all essential activities—including consumer contact, product selection, commission routing, and even continued participation—were dictated by company policy. “Defendants dictated how agents solicited consumers, which products and carriers could be accessed, how commissions were routed, and whether an agent could continue operating at all,” according to the complaint.
The document details a highly structured onboarding process where new agents were funneled into mandatory training programs focused on selling mortgage protection insurance using scripts developed by company leadership. Agents were required to purchase leads exclusively from company-controlled platforms such as HQ and Opt CRM systems. Access to these systems was necessary for all aspects of an agent’s work—from contacting clients to submitting applications—and could be revoked at any time by company leadership.
The complaint also highlights past regulatory action against Symmetry Financial Group. In June 2016, Illinois banking regulators issued a cease-and-desist order after finding that Symmetry had sent mailers using a bank’s name without authorization—a practice deemed likely to confuse customers about who was offering the insurance product.
Brooks asserts that when he raised concerns about deceptive sales practices within this system—such as mailers implying lender affiliation or guaranteed mortgage payoff—the defendants did not address his complaints but instead retaliated against him. He claims he was locked out of all company platforms, stripped of carrier appointments and business records, effectively ending his ability to earn income in his chosen field.
The lawsuit describes a multi-level hierarchy within Symmetry Financial Group where advancement depended on meeting production quotas set by corporate policy. Training materials allegedly encouraged emotionally charged sales techniques emphasizing fear of foreclosure or loss if coverage was not purchased—even though the policies sold did not guarantee satisfaction of mortgage debt or involve lenders as beneficiaries.
Plaintiff Brooks argues that despite being classified as an independent contractor responsible for his own licensing fees and lead purchases, meaningful autonomy was lacking due to strict adherence requirements regarding training modules, lead purchasing through internal marketplaces only, scheduled meetings led by agency leadership, and reporting obligations up the supervisory chain.
In addition to monetary damages for lost income and business opportunity costs resulting from his removal from the network, Brooks seeks injunctive relief against what he describes as ongoing deceptive marketing practices affecting both consumers nationwide and other similarly situated agents. He contends these actions violate fair trade practices laws by creating false impressions among both potential customers and prospective recruits about the nature of their relationships with Quility Insurance Holdings and its affiliates.
The attorneys representing Jackson Young Brooks are not named in this portion of the filing reviewed. The case is identified as Case No. 1:26-cv-75-MR-WCM.
Source: 126cv00075_Brooks_v_Quility_Insurance_Holdings_LLC_Complaint_Western_District_North_Carolina.pdf
