The insurance practices of twisting and churning are also violations of the Unfair Trade Practices Act. Twisting is the act whereby an insurance agent encourages a policyholder to relinquish (or allow to expire) his or her current policy for the sole purpose of selling a new policy to replace it; hence, earning another commission. Any of the following practices, if committed in violation of Section 3, are hereby defined as unfair trade practices in the business of insurance: A. Misrepresentations and False Advertising of Insurance Policies. On the other hand, however, the insurance agent is likely to be sued under Article 21.21 of the Texas Insurance Code, titled the Unfair Trade Practices Act, and not DTPA. His defense under 21.21 does not include protections afforded the realtor who was sued under DTPA. Unlike the realtor,