> What specifically is violating policies?

Guideline materially and repeatedly breached their fiduciary duties under ERISA.

Their definition of when an expense is “incurred” varies materially from case to case and diverged substantially in almost all of them from IRS guidance. Multiple times, a customer service agent said—in writing—the last person I interacted with misrepresented something material that I had subsequently acted on.

Disclaimer: I am not a lawyer. I am describing my personal experiences. Don’t cite this comment if you decide to pursue these fuckwits.