Comtrack Admin

B. Producers (Part 1)

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Educational Objective
  • I.C2.1. Rules of agency and agent authority — be able to identify the responsibilities and duties of an agent, and the types of authority producers hold.
  • I.C2.6. Types of licensees — be able to identify the licensing requirements for insurance agents, life licensees, insurance brokers, and life settlement brokers.
  • I.C2.7. Solicitors — be able to identify the duties and limitations of a solicitor.

1. Rules of Agency and Agent Authority

A producer acts under the law of agency: the insurer is the principal, and the producer is the agent. Within the scope of the agent's authority, the acts of the agent are considered the acts of the insurer.

  • The agent always represents the insurer, not the applicant or insured;
  • The knowledge of the agent is imputed to be the knowledge of the insurer;
  • The insurer is responsible for the acts of its agent so long as those acts fall within the scope of the agent's authority; and
  • Payment of premium made to the agent is considered payment made to the insurer.

The agent is responsible for accurately completing applications, submitting them for underwriting, and delivering the policy. Because the agent owes a fiduciary responsibility to the insurer, it is illegal for the agent to commingle premium funds collected on the insurer's behalf with the agent's own personal or business funds.

Know This

Who is your pal? The principal! The insurer is the principal, and the agent always represents the insurer — never the insured — in the agency relationship.

Authority and Powers of Producers

A producer's authority to act on behalf of an insurer comes in 3 forms:

Express Authority
Authority specifically granted to the agent in writing, typically through the agent's contract with the insurer.
Implied Authority
Authority that is not written but is necessary for the agent to carry out express authority. For example, an agent expressly authorized to sell policies has the implied authority to explain policy provisions to applicants.
Apparent Authority
Authority that a reasonable third party would believe the agent has, based on the insurer's own actions — such as furnishing the agent with the insurer's stationery or applications — even if that authority was never actually granted.

Definition of "Transact"

Educational Objective
  • I.C2.4. Be able to identify what constitutes "transacting" insurance, and the penalties for unlicensed transacting.

Transacting insurance includes any of the following:

  • Solicitation;
  • Negotiations preliminary to execution of a contract of insurance;
  • The execution of a contract of insurance; and
  • Transaction of matters arising subsequent to the execution of a contract of insurance and arising out of it.

It is a misdemeanor to transact insurance business without a valid license. The penalty is a fine of up to $50,000, imprisonment in county jail for up to 1 year, or both.

2. Types of Licensees

California issues license types corresponding to the classes of insurance an agent or broker is authorized to transact: property and casualty, life, accident and health or sickness, personal lines, and surplus lines. Every applicant for a producer license must first complete 12 hours of California Insurance Code and Ethics education.

Agent vs. Broker

An agent represents the insurer. A broker represents the client (the insured or prospective insured) in placing coverage, rather than representing any single insurer.

An insurance agent license under the Insurance Code covers all classes of insurance business other than life, disability, or health insurance. Common lines authorized under this license include:

  • Private passenger automobile insurance;
  • Personal watercraft insurance;
  • Residential property insurance (including earthquake and flood endorsements);
  • Inland marine insurance; and
  • Personal umbrella or excess liability insurance.

A life agent license authorizes the sale of life insurance products, including endowments and annuities, and disability benefits such as accidental death and dismemberment and disability income. An accident and health (A&H) agent license authorizes coverage for sickness, bodily injury, accidental death, disability income, and 24-hour coverage.

A personal lines agent is limited to transacting personal lines property and casualty insurance for individuals and families. A limited lines automobile agent may transact only automobile insurance. A surplus line broker may place coverage with nonadmitted insurers when that coverage is unavailable from admitted insurers — no other agent or broker may advertise or transact business for a nonadmitted insurer.

Life and Disability Analysts

Educational Objective
  • I.C2.21. Life and disability analysts — be able to identify the licensing eligibility requirements, and the requirements and prohibitions surrounding the charging of fees.

A life and disability analyst is a person who, for a fee paid by a source other than an insurer, examines, appraises, reviews, or evaluates any life or disability insurance policy or annuity contract and renders advice, recommendations, counsel, or opinions.

To be eligible for a life and disability analyst license, an applicant must:

  • Be a resident of California;
  • Pass the required examination within 12 months of application;
  • Be of good reputation and business integrity;
  • Demonstrate thorough knowledge of life and disability insurance;
  • Not have failed to discharge a fiduciary duty to a client in another business;
  • Not have used the license to avoid the intent of state insurance laws; and
  • Not be a current employee of an insurance company.

An applicant must also have been licensed as a life agent, or as an accident and health agent, for at least 5 years immediately preceding application.

Requirements and Prohibitions for Charging Fees (CIC 1848)

An analyst must enter into a written agreement, signed by the client, before charging a fee. An analyst may not charge a fee for services that are customarily performed as part of soliciting or transacting insurance, or for which the analyst is otherwise compensated by an insurer. The written agreement must disclose that information about the policy is available at no charge, and if the analyst also holds an agent's license, must disclose any commission the analyst will receive.

Life Agent vs. Life Analyst

A life analyst is not paid a commission by an insurer for the advice given. A life agent, by contrast, transacts insurance business — soliciting applications and executing contracts — and is compensated by commission from the insurer.

Certified Insurance Agent

A certified insurance agent is certified by Covered California (the state's health benefit exchange) to assist individuals and small employers with enrollment through the Exchange or the Small Business Health Options Program (SHOP). To become certified, an applicant must be a natural person holding an accident and health license in good standing. Certification must be renewed every 5 years.

Life Settlement Brokers

A life settlement is the sale of a life insurance policy, by the owner, to a third party for compensation that is less than the policy's death benefit but generally more than its cash surrender value. A viatical settlement is a similar transaction, historically limited to insureds who are terminally or chronically ill; a life settlement may involve a seller with a life expectancy of more than 1 year.

Business of Life Settlement
Any activity related to the offer, negotiation, or effectuation of a life settlement contract.
Owner
The owner of a life insurance policy or certificate holder under a group policy who enters into a life settlement contract.
Insured
The person covered under the life insurance policy that is the subject of a life settlement contract.
Qualified Institutional Buyer
A financially sophisticated institutional purchaser recognized under securities law as capable of evaluating and bearing the risk of a life settlement investment.
Life Expectancy
The mean number of months an insured with a given health status is expected to live, as determined by a qualified actuary or physician.

A life settlement contract is an agreement establishing the terms under which compensation is provided in exchange for the death benefit, ownership, or a beneficial interest in a life insurance policy or an interest in a trust that owns a policy. A life settlement contract may also include a premium finance loan made for the purpose of ultimately settling the policy, under specified conditions.

The following are not considered life settlement contracts:

  • A policy loan made by a life insurance company under the terms of the policy;
  • A loan made by a bank or other licensed lender using the policy as collateral;
  • A collateral assignment of a policy by its owner;
  • An agreement between an insured and a closely related family member or business associate;
  • A bona fide business succession planning arrangement;
  • An employer-owned policy insuring the life of a key employee;
  • An agreement between a service recipient and a service provider not primarily for the purpose of settling the policy; and
  • Any other transaction that the Commissioner determines is not a life settlement contract.
Life Settlement Broker
A person who, for a fee, offers or advertises the availability of life settlements, and who owes a fiduciary duty to the owner and must act according to the owner's instructions and in the owner's best interest.
Life Settlement Producer
A licensed insurance agent or broker acting as a life settlement broker on behalf of an owner.
Financing Entity / Financing Transaction
A financing entity provides funds to acquire life settlement contracts or policies; a financing transaction is any transaction in which such funding is arranged, typically involving a lender secured by the policy.

Broker License Requirements

  • Completion of 15 hours of continuing education specific to life settlements;
  • Filing of an application with the Commissioner;
  • Payment of a $171 fee for a 1-year license term; and
  • Demonstration of competence and trustworthiness.

A life agent licensed for 1 year or more may act as a life settlement broker without a separate license by providing the Department of Insurance with 10 days' notice, along with an $85 notification fee, renewable every 2 years. Viatical settlement brokers and providers already licensed are deemed to meet the licensing requirements for life settlement brokers.

Solicitors

Educational Objective
  • I.C2.7. Solicitors — be able to identify the duties and limitations of a solicitor.

A solicitor is a natural person who assists a property and casualty agent or broker in transacting insurance business other than life, disability, or health insurance. A solicitor may not simultaneously hold a license as an agent or broker.

A solicitor's duties may include prospecting for new business, making appointments, providing quotes, and taking applications, but the solicitor must always act on behalf of a licensed agent or broker. A solicitor may work for more than one producer, but a notice of appointment must be filed for each producer beyond the first. A solicitor's license is required to perform these functions.

There is no such license as a "life solicitor" or an "accident and health solicitor" — the solicitor license applies only to property and casualty business.

3. Administrator

A third-party administrator (TPA) collects premiums or settles claims on behalf of an insurer or insured. An administrator must meet the same qualifications required of a life agent and must operate under a written agreement, and must hold a certificate of registration.

Payments made to an administrator are considered to have been received by the insurer. However, payments made by the insurer that pass through an administrator are not considered received by the insured until actually delivered.

The following are not considered administrators:

  • An employer administering the benefit plan of its own employees;
  • A union administering the benefit plan of its own members;
  • An insurer;
  • A life agent whose administrative functions are limited to business they exclusively sell;
  • A creditor administering group insurance covering its debtors;
  • A trust or trustee administering an employee benefit plan;
  • Custodians of funds under IRC Section 501(c) or 401(f);
  • A bank, credit union, or other financial institution;
  • A credit card company that does not adjust or settle claims;
  • An attorney who does not collect claims-related charges from clients;
  • A licensed adjuster;
  • A nonprofit agricultural association administering employee benefit plans; and
  • A managed care organization licensed by the Department of Managed Health Care.

4. Continuing Education Requirements

Educational Objective
  • I.C2.18. Continuing education requirements — be able to identify the general CE requirements for agents.
  • I.C2.19. Be able to identify the CE requirements for agents selling annuity products.
  • I.C2.20. Be able to identify the CE requirements for agents writing long-term care insurance.

Continuing education (CE) ensures that licensees stay current on insurance law, products, and ethical standards. All producers must complete 24 hours of CE, including 3 hours of ethics, during each 2-year license term. This requirement applies to life, accident and health, property, casualty, and personal lines licensees.

CE may be completed at any time before renewal and must be approved by the Commissioner. A licensee holding 2 or more license types may satisfy the CE requirement by completing courses applicable to any one of those license types. CE hours completed in excess of the requirement carry over, but only the excess from the most recent year carries over, and it is capped at the amount needed to satisfy the next renewal's requirement.

CE courses may be taken in a classroom (contact) setting or as self-study, but must be approved by the Department of Insurance. A licensee who has held a license in good standing for 30 years and is 70 years of age or older is exempt from the CE requirement.

Agents Selling Annuity Products

An agent must complete 8 hours of annuity training before the first sale of an annuity product, and 4 hours every 2 years thereafter. This training is part of, and does not increase, the agent's overall CE requirement.

Agent Writing Long-Term Care Insurance (CIC 10234.93)

Educational Objective
  • I.C2.20. Long-term care training — be able to identify the training requirements for agents selling policies with LTC riders, and the insurer's responsibilities.

LTC training is required for agents selling policies or riders that provide coverage for personal care services; it is not required for riders that do not include personal care services.

An agent must complete 8 hours of LTC training in each of the first 4 years after the original license is issued, and 8 hours before each subsequent license renewal.

Insurer's Responsibility

Insurers must ensure that their agents are able to explain the differences between an accelerated death benefit and long-term care insurance, and that agents can accurately communicate:

  • The differences between long-term care insurance and other health-related coverage;
  • The differences between the levels of care covered by a policy;
  • The importance of inflation protection; and
  • The existence of the Health Insurance Counseling and Advocacy Program (HICAP) for consumer assistance.

Agents Writing California Partnership Coverage

Agents who sell California Partnership for Long-Term Care (CPLTC) policies must complete 1 LTC training course and 1 8-hour live classroom CPLTC-specific course before their initial sale, and an 8-hour live classroom CPLTC course every 2 years thereafter. Life agents who complete this training may solicit LTC riders; this training does not increase the agent's total CE hour requirement.