What problems does Colorado's Joseph have with life settlements?

In his April 2009 testimony before the U.S. Senate Special Committee on Aging in Washington, Joseph listed them. In particular, he said he is concerned about the risks facing unsophisticated individuals who invest in life settlement programs. The risks he named are:

• Ponzi schemes, set up so the organizers buy no settled policies.
• Fraudulent life expectancy evaluations prepared by captive physicians
• Inadequate premium reserves
• False promises of large profits with minimal risk
• Providers concealing information about material factors such as the fact that rates of return can vary significantly, depending upon the accuracy of life expectancy calculations.
• Illiquidity stemming from there being no secondary market for the secondary market.
• Viatical companies and their principals concealing disciplinary histories

What else?