Page  of  pages
Koenig to TDI’s Sullivan:  
sale of USAA Asset Management to Victory Capital
February 10 2019 1656 GMT

Started January 30 2019

Commissioner of Insurance
Texas Department of Insurance
The Honorable Kent C Sullivan
TX Bar Card Number: 19487300
333 Guadalupe
Austin TX 78701

BY FAX TO +1.512.490.1045


RE:  USAA Asset Management Company to Victory Capital Management Inc

Dear Commissioner Sullivan:

United Services Automobile Association’s [1] insurance syndicate manager,  Stuart Blain Parker  [2]  [3],  has successfully and properly sold USAA Asset Management Company  [4] to Victory Capital Management Inc. [5].  Right?  Well maybe.

This sale by USAA to Victory is organized by attorney-in-fact  Laura Ann Mahan Bishop  [6]  [7] who simultaneously serves in these three manifestly conflicting capacities:

Laura Ann Mahan Bishop
Chief Financial Officer
United Services Automobile Association
9800 Fredericksburg Road
San Antonio TX 78228

Laura Ann Mahan Bishop
President Treasurer and Secretary
USAA Reciprocal Attorney-in-Fact Inc
9800 Fredericksburg Road
San Antonio TX 78228

Very secretly:
Laura Ann Mahan Bishop
USAA Capital Corporation
9800 Fredericksburg Road
San Antonio TX 78228

At the end of 2017, Laura Ann Mahan Bishop’s NAIC Filings (which are now freely available for immediate download from the California DOI) show that Ms Bishop owes $19,282,965,387 back to her syndicate names.

USAA Capital Corporation

Book/Adjusted Carrying Value:  $8,194,315,660  Fair Value:  $8,194,315,660
of total Common Stock in Parent, Subsidiary and Affiliates of $19,282,965,387.
in pdf)

The USAA Asset Management sale to Victory Management, which will be paid with an extraordinary and incredible $1.3 billion borrowing from Barclays Bank and the Royal Bank of Canada, will reportedly yield a $850,000,000 purchase price to the USAA syndicate names.

The Barclays/RBC unincorporated lending syndicate’s confidential and private commitment letter may be reviewed here. 

[nb:  Unresolved technical problems with Google may mean that you have to copy this url (above) into your browser.]

The Commissioner is asked to take commission note of the otherworldly quality of the financing for “this sale” by two these foreign banks.

I smell an out-of-country financing deal in which Barclays and Royal Bank of Canada are backstopped and stop-lossed:  and I don’t like it.  It stinks.

After SEC fees and whistleblower fees, which I estimate at $255,000,000: Ms Bishop will net $595,000,000:  which leaves her with a further balance of $18,687,965,387 which needs to be repaid to the 2.5 million USAA syndicate names.

It is my genuine and good-faith belief that the USAA syndicate names and the so-called USAA associate members (who - we are told by Victory’s 8K - number 1.5 million) would be far far better off if their accounts were transferred to BlackRock, Schwab, Fidelity or Vanguard (inter al.).

This would be true even if a credible deep-pocket buyer paid only $500,000,000 for the same intangible USAA “assets”.

I am going to guess that Stuart Parker and Laura Ann Mahan Bisop are under tremendous pressure to simultaneously accomplish three missions:

  1. Get a lot of money real fast so they can pay $19,282,965,387 owed back to the syndicate names so they can both stay out of prison.
  2. Somehow continue to earn a revenue stream from leasing the name USAA to Victory.
  3. Yet: satisfy their fiduciary duty to the 1.5 million syndicate names and USAA associate members who have signed on to their juggernaut.

This is a very dangerous situation.  No 1 and No 2 (above) fly in the face of No 3.

The TDI is the mother regulator for 2.5 million syndicate names all around the USA.  It is my belief and hope that the TDI, as USAA’s de facto national regulator,  will look into this matter very carefully.

Who else is better situated to protect the innocent defenseless USAA members (and non-members) who further divide into these subsets:

  1. The canonical syndicate names whose personal funds have been  converted and purloined to capitalize Stuart Parker’s juggernaut - and who need to be repaid.
  2. The syndicate names and the murkily described USAA associate members and the off-the-street walk-in non-member customers who have entrusted their savings to Stuart Parker’s questionable ministrations.


I am now looking very carefully to see exactly how USAA syndicate manager Stuart Parker satisfies the prime directive: which is to return the money to the individual policyholder who supplied it. This is how Justice Louis Brandeis described Stuart Parker’s duty and obligation.

It is of the essence of mutual insurance that the excess in the premium over the actual cost as later ascertained shall be returned to the policy holder.

Mr Justice Louis Brandeis [8]

As always - I am available to discuss this matter in depth with the Commissioner and his staff.  I may be phoned 24 x 7 at my personal cell phone number - +1212.203.9712.

It would also be very very nice if Stuart Blain Parker and Laura Ann Mahan Bishop and Lester Lawrence Lyles would phone me directly if they have any concerns or questions rather than trying to jail me.

I must point out that having their lawyer Ted Schultz sneak down to the San Antonio YMCA to login so his IP address can’t be tracked is emblematic of Stuart Parker’s and Laura Bishop’s style of dealing with critics.   Parker and Bishop prefer to surveil, tail and jail.   They are fundamentally unable to pick up the phone and find out what’s going on.

Very truly yours,

Robert J Koenig
POB 720843
Jackson Heights NY 11372

[1] United Services Automobile Association; NAIC # 25941; FEIN  74-0959140; TDI Company Number 14-86800; Current TDI Certificate of Authority  [CofA]  # 14585 granted on April 2 2008: an unincorporated insurance syndicate organized as a Texas reciprocal inter-insurance exchange.

Unlawfully commenced inter-insuring by receipt of a syndicate name's deposit against a reciprocal contract on either June 20 or June 22 1922. First one year license (expired February 28 1926) to commence inter-insuring by reciprocal contract granted on or slightly before March 23 1925 (two and nine years after USAA's unlawful 1922 "receipt of a first deposit from a "syndicate name".

[2] Stuart Blain Parker
16 De Zavala Pl
Shavano Park TX 78231-1446
+1.803.767.8739 (cell)


[4] USAA Asset Management Company:  A DE Corporation; FEIN 45-3083097 which is a subsidiary of USAA Capital Corporation :  A DE Corporation; FEIN 51-0291843.

[5] Victory Capital Management Inc: EIN # 13-2700161.  A NY Corporation NYSDOS ID #: 324189.   SEC Advisor #: 801-46878  (CRD # 106189).  Legal Identifier #:  549300YNO08S1SH3I683.  Subsidiary of Victory Capital Holdings Inc; NASDAQ GS: VCTR.  A DE Corporation. FEIN 32-0402956

[6] Laura Ann Mahan Bishop
131 Westwood Way
San Antonio TX 78218


[8]     Penn Mutual Life Insurance Co. v. Lederer, 252 U.S. 523 (1920)

It is of the essence of mutual insurance that the excess in the premium over the actual cost as later ascertained shall be returned to the policy holder.  Mr Justice Louis Brandeis