A. On June 9, 2008, the Plaintiff entered into an agreement on the sale of golf membership (A evidence No. 10, No. 10, No. 1, 2008; hereinafter “the instant agreement”) with B Co., Ltd. (hereinafter “B”) by paying 22 billion won per unit (2.2 billion won per unit) to the sales price of 10 unit of corporate membership rights in the instant golf course (hereinafter “D”).

The main contents of the instant agreement are as follows.

(A) “A” and “B” refer to the Plaintiff, and “B”. (b)

On December 29, 2009, the Plaintiff entered into a membership agreement with B (Evidence No. 11) in accordance with Article 3(2) of the instant agreement.

C. On August 26, 201, the Defendant Financial Services Commission imposed upon the Plaintiff a penalty surcharge of KRW 740,000,000 for the ground for disposition (i) (ii) KRW 717,000 for the ground for disposition (ii) KRW 23,000 for the ground for disposition (hereinafter “instant penalty surcharge”). On September 2, 201, the Defendant Financial Supervisory Service issued an electronic warning disposition for the ground for disposition (hereinafter “instant electronic warning disposition”) to the Plaintiff (i) and (ii) and (iii) for the ground for disposition.

On June 9, 2008, the Plaintiff, a major shareholder, agreed to purchase the right of preferential purchase of ten unit of corporate membership (2.2 billion won per unit) of the instant golf course in which the approval of the instant golf course was not completed, and paid in advance the deposit amount of 22 billion won, thereby violating Articles 104 and 111 of the former Insurance Business Act, by providing B with credit equivalent to interest-free interest of KRW 2.2 billion during the period from June 29, 2008 (date of advance payment) to December 29, 2009 (date of initial payment).

(hereinafter “Cause A disposition.” The head of the Plaintiff’s former E branch provided 34 million won out of the solicitation allowances of 38 million won and 34 million won out of the solicitation allowances of 38 million won as special benefits to the policyholder at the time of distributed, transit, and treatment as if 3 persons, such as insurance solicitors of the E branch, etc., were recruited during the period from October 31, 2003 to December 22, 2003, including the G insurance of the policyholder F, etc. (752 million won in total).

(hereinafter “Grounds for Disposition B”. The Plaintiff