PIA Submits Comments on Anti-Rebating

To National Association of Insurance Commissioners
April 30, 2019

PIA National has submitted comments on the issue of rebating and the current anti-rebating language contained in the National Association of Insurance Commissioners’ (NAIC) Unfair Trade Practices Model Act (Model #880).

“…we are concerned that the model, which currently prohibits the giving of, essentially, ‘anything of value whatsoever not specified in the policy’ to a policyholder, is too restrictive,” stated PIA National Counsel & Director of Regulatory Affairs Lauren Pachman, Esq., in a letter to North Dakota Insurance Commissioner and Chair of the NAIC Innovation and Technology (EX) Task Force Jon Godfread.

PIA recommends that language be added “recognizing and permitting the independent agent custom of offering, as a token of thanks, an inexpensive item, such as a product featuring the agency logo, to policyholders periodically and not necessarily concurrently with the signing or renewal of a policy.”


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