Curtis Ray and MPI: An Honest Review, Including the Cease and Desist

Two searches bring most people to this page. One is some version of what is MPI, usually after a TikTok. The other is Curtis Ray cease and desist, usually after hearing that a state regulator took action and wanting to know whether the thing they were about to buy is in trouble. Both deserve a straight answer, and most of what is written about this is either a fan page or a hit piece.

We are not neutral and it would be dishonest to pretend otherwise. We sell life insurance. We sell whole life, and we sell indexed universal life. Curtis Ray and I have very different views about how a retirement should be funded, and we have said so to each other directly, on camera, for just over an hour. That interview is embedded below and we published all of it, including the parts where he got the better of the exchange.

The marketing is the problem here, not the product.

That distinction is the whole article. An indexed universal life policy is a legal, ordinary, widely sold contract. The regulator did not say otherwise. What the regulator objected to was the story told around it.

01 / The PersonWho Is Curtis Ray?

Curtis Ray is the founder of MPI Unlimited and the creator of what he calls the MPI strategy, short for Maximum Premium Indexing. He built one of the largest personal followings in retirement content, mostly on TikTok, where he crossed a million followers in about fifteen months. He owns compoundinterest.com, which is one of the better domains in personal finance. He has written two books, Everyone Ends Up Poor and The Lost Science of Compound Interest, and he produced a free video series explaining his approach.

He is a genuinely good communicator, and that is not a backhanded compliment. When he sat down with us he was direct and he answered what he was asked. Plenty of people in this industry will not come on a show where they expect to be challenged. He did.

He is also the reason a meaningful number of people started saving money at all. He said it himself on our show and we believe it: the biggest problem in American retirement is not which product you pick, it is that the savings rate is close to nothing. Anyone moving that number is doing something useful.

02 / The ProductWhat Is MPI?

MPI is a maximum funded indexed universal life policy, paired with a participating policy loan that is used to put additional money into the same policy. Strip the branding away and there are three ordinary parts.

1. An indexed universal life contract. Your cash value earns interest tied to the performance of an index, usually the S&P 500, with a cap on the upside and a floor of zero on the downside. You do not own the index and you do not receive its dividends. The carrier buys options to deliver the crediting.
2. Maximum funding. The policy is designed with the smallest death benefit the tax code allows for the premium, so that as much money as possible goes to cash value instead of insurance cost. This part is not controversial. It is how any cash value policy should be built if the goal is capital rather than death benefit.
3. A participating loan used as additional premium. After the first couple of years you borrow against the policy at a fixed loan rate, and that borrowed money goes back into the same policy as more premium. Your full cash value keeps earning the index credit while you pay a lower rate on the loan. The gap between the two is the entire engine.

Curtis Ray was careful with us about the label. The industry term for borrowing against a policy to pay its own premiums is hyperfunding, and he rejected that description of what he does. In his words: "hyperfunding is when you stop premiums and you use the loan feature to make your premiums for you. I don't believe in that." His version keeps your own contributions going and uses the loan to double them rather than replace them. That is a real distinction and he is entitled to it.

It is arbitrage inside an insurance contract.

If the policy credits more than the loan costs, the spread compounds, and over thirty or forty years a persistent spread produces very large numbers. That is not a trick. It is the same reason a mortgage works when the property earns more than the loan costs. Curtis Ray says this openly and calls it the third leg of what he describes as the triple advantage: security, growth, and leverage.

03 / The OrderWhat Did the Washington Cease and Desist Say?

In 2024 an attorney brought a Washington State Office of the Insurance Commissioner cease and desist order naming Curtis Ray and his company onto our show, and read it on screen rather than summarizing it. That video is below, and it is the basis for everything in this section.

We owe you one caveat on sourcing. We have not been able to pull that order out of the Commissioner's public database ourselves, so what follows rests on the document as the attorney read it on camera, not on a filing we can hand you. If you have the order number, send it and we will link the document here.

Three things about that order matter more than the headline.

It started with another agent. The investigation did not begin with an angry client. It began with a complaint from a fellow insurance agent, who alleged that consumers across the country were being defrauded by having an indexed universal life policy presented to them as a Curtis Ray product. Whatever you think of the complaint, that origin is worth noticing. This was the industry policing its own marketing.

The objection was to uniqueness, not to the contract. The core of it, as the attorney read it out, is that the marketing described the policy as not a typical life insurance policy. It is a typical life insurance policy. Any agent appointed with the same carrier can sell the same contract, and in principle design it the same way. Calling an ordinary contract proprietary is the kind of claim regulators act on, because it removes a consumer's ability to shop.

A cease and desist is not a verdict on the strategy. It is a regulator telling someone to stop doing a specific thing while the process runs. Indexed universal life remains legal, the policies people own remain in force, and the math behind the strategy stands or falls on its own. What crossed a line in one state was the way it was sold.

04 / The QuestionIs MPI a Scam?

No, and the word is doing damage in both directions.

A scam is when the thing you bought does not exist or does not do what it is contractually required to do. These are real policies, issued by a real carrier, with real cash value and real contractual guarantees on the floor. Nobody is running off with the money. People who call it a scam usually mean one of two things: that the projections are too optimistic, or that the marketing oversold it. Those are fair criticisms and they are not the same as fraud.

But the defense people give is also too easy. The usual line is that the critics do not understand it. Some do not. The attorney who read the Washington order on our show has been warning advisors about this structure for close to twenty years, and understands it in more detail than most of the people selling it.

Here is the honest version. The product is real. The math is real if the assumptions hold. The assumptions are the part that deserves scrutiny, and the marketing did not invite scrutiny.

05 / The MathThe 6.87% and What It Assumes

When we asked him directly what the strategy earns, Curtis Ray gave a specific answer, which is more than most people in this business will do. Over the last twenty five years, he said, the crediting has averaged 6.87%, assuming a 10% cap. That is a gross crediting rate, not a return: the cost of insurance comes out after it. He described that cap as conservative relative to the bond rates a carrier was earning at the time.

Take that 6.87% seriously for a moment, because it is the strongest version of his case, and it is not an outrageous number. A cap of 10% on an S&P linked account, over a twenty five year stretch that included 2008, producing something just under 7%, is plausible.

The problem is not the number. The problem is that three of the inputs belong to the insurance company, not to you.

• The cap is not guaranteed. The carrier sets it and can lower it. If the 10% cap becomes 7%, the crediting average falls, and it falls on money you have already leveraged.
• The loan rate is not guaranteed forever. The spread between crediting and loan cost is the engine. Compress the spread and the engine stops producing.
• Cost of insurance rises with age. In a universal life chassis the internal cost climbs as you get older. In the years when your cash value is largest and your loan is largest, the cost is also largest.

A zero floor protects you from the market. It does not protect you from the carrier.

06 / The InterviewWhat We Asked Him on Camera

We published the whole conversation, just over an hour of it, without edits, including the parts where the questions were softer than they should have been.

The central question was this one, and it still is: "it feels like it potentially could be built on a house of cards. What happens if the insurance company stops this? What happens if interest rates go down? What happens if and when the market doesn't perform?"

The second one was about the category itself. Life insurance is not an investment, and the marketing treats it like one. When a strategy's entire appeal is a projected rate of return, the buyer is making an investment decision using a product built on a different promise.

The third was the one the Washington regulator eventually reached from a different direction. If this is genuinely better than everything else, why do most carriers not want it sold? Insurance companies want premium. A design that brings in enormous premium and gets refused by carrier after carrier is telling you something.

07 / His DefenseWhat Curtis Ray Said Back

He did not dodge, and a fair review has to give his answers as he gave them.

On the doomsday scenario. He said he had run the strategy through a two percent bond environment and through the fifteen years from 1929 to 1944. It produced less, in his telling around seven to nine percent of income rather than twelve to fourteen, which he pointed out is still well above the four percent rule. His broader point was that if the bond market truly fails, whole life fails with it, because general account assets sit in bonds too. That is correct, and people who criticize indexed universal life while assuming whole life is immune are not being consistent.

On blowups. His claim was that a maximum funded contract does not blow up the way the underfunded policies of the 1980s and 1990s did, and that the failures people remember were policies stuffed with death benefit and starved of premium. That is largely true, and it is the same argument we make about whole life being judged on badly built examples.

On the exit. He said there is always an exit: if the spread between crediting and loan cost disappears, you stop the loan strategy and revert to an ordinary maximum funded policy. This is the answer we found least satisfying, and we said so. An exit that depends on noticing the problem in time, and on the contract still working after decades of leverage, is a plan, not a guarantee.

08 / The RiskWhere This Can Actually Unravel

Forget the word scam. Here is the failure mode, in order of how likely it is.

1. The spread compresses. The carrier lowers the cap or raises the loan rate. Nothing dramatic happens on day one. The plan just quietly stops producing what the illustration said, and by the time it is obvious you have been leveraged for fifteen years.
2. The owner stops funding. The design requires maximum funding. Curtis Ray was explicit: "if you're not willing to max fund a contract, you're not an MPI plan." Life happens, income drops, and a plan that needs full contributions for decades meets a person who has a bad five years.
3. Sequence of zeros. A zero floor is not the same as a good year. Several flat years in a row while loan interest accrues and insurance costs rise is the scenario that hurts, and it does not require a crash.
4. The owner does not understand what they bought. This is the one the regulator cared about. If you were told it was a unique product available only through one company, you were not in a position to compare it to anything.

The other big indexed universal life brand has a different but related story in the public record, which we go through in our review of Doug Andrew and the LASER Fund.

09 / The ComparisonMPI Versus Whole Life

This is the comparison most people are running, so here it is without spin.

Those two numbers are not on the same footing, and it would be dishonest to show them as if they were. The indexed figure is gross crediting, before the cost of insurance comes out of it. Ours is net of costs. Ask anyone who shows you a projection which of the two you are looking at.

Notice that we did not give whole life a flattering number. Around 4% net over a long holding period is what an honestly built policy does, and anyone quoting you the dividend rate as if it were your return is quoting a gross number that you will never personally receive. If we are going to hold someone else's projections to a standard, ours have to meet the same one.

10 / The FitWho This Works For

A fair review says who the thing is for. MPI is most defensible for someone who has a long runway, a stable and high income, genuine tolerance for a plan that depends on carrier behavior, and who already has money working elsewhere. Curtis Ray made a version of this argument himself: take ten percent of your assets and put it somewhere with this kind of long term projection.

It is least defensible for the person the TikToks reach best. Someone in their thirties with an uneven income, no other assets, and a screenshot of a calculator is the worst possible candidate for a strategy that requires maximum funding for decades and punishes you for stopping.

11 / Our NumbersWhat We Tell People, Including the Unflattering Part

We build policies for a living, so the only fair way to end this is with our own numbers on the table.

• A well built whole life policy gets to roughly a four percent net internal rate of return over a long holding period. Not the dividend rate. The dividend rate is a gross number and it is not what you earn.
• The first several years look bad. Cash value lags premium at the start, and anyone who tells you otherwise is selling you an illustration instead of a contract.
• The policy is not the investment. It is where capital sits so you can use it for something that actually produces a return.
• We tell people not to buy one regularly. If there is no productive use for the capital and no ability to fund it consistently, it is the wrong tool.

If the return inside the contract is the whole reason to buy it, you are buying the wrong thing.

That is the real disagreement between us and Curtis Ray, and it is bigger than the cease and desist. He believes a single contract, borrowed against correctly, can carry a retirement. We believe the contract is the foundation and the returns come from what you do with the capital.

12 / The ChecklistWhat to Check If You Already Own One

Most people reading this are not deciding whether to buy. They already own the policy and want to know where they stand. You can answer that yourself with the annual statement and the original illustration, and you do not need anyone's permission to look.

1. Find the current cap and compare it to the cap in your original illustration. This is the single most important number and it is the one most owners have never checked. If the illustration assumed 10% and your current cap is lower, every projection you were shown is already stale.
2. Find your current loan rate and your outstanding loan balance. The strategy only works while crediting beats the loan cost. Write both numbers down. If you cannot find them on the statement, call the carrier directly rather than the agent.
3. Look at the cost of insurance line, this year versus five years ago. In a universal life chassis this number rises with age. Seeing the slope is more useful than any projection.
4. Compare cash value to total premium paid. Not to the illustration. To what you actually put in. This tells you where you really are, without anyone's interpretation.
5. Ask what happens if you stop funding for two years. Put it in writing to the carrier. The answer to that question is the real stress test of the plan, and it is the scenario the marketing never covers.
6. Ask who else can service this policy. If the honest answer is only one agency, that is the uniqueness problem the Washington regulator objected to, showing up in your own file.

All six answers sit on two documents you already have: the annual statement and the original illustration. An hour with those tells you where you stand. If the numbers come back fine, you own a real asset and you understand it better than you did. If they come back uncomfortable, you found out while there is still time to act.

FAQCommon Questions About Curtis Ray and MPI