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Agent Liability — Acts of Commission & Omission

Agents can find themselves in breach of their ethical responsibilities both by the actions they take (acts of commission) and by their failures to act (acts of omission). Customers have a reasonable expectation that the agent they deal with is a professional who will exercise due care in representing insurers to the public and be competent in servicing the business once it is placed. Failing to do so, in the eyes of many courts, exposes the agent to personal liability.

Example: Failure to Notify
An agent forwards a customer’s signed application and first premium payment for flood insurance to the insurer, assuring the client that coverage will be underwritten. The insurance company rejects the application and notifies the agent — but the agent fails to notify the applicant. A flood strikes and the client learns he is uninsured. Courts have held in circumstances like these that the agent was liable for the flood-related losses.
Due Diligence & Unauthorized Entities

Agents who fail to exercise “due diligence” may be personally liable for their failure. As discussed in Chapter 2, agents who represent unlicensed insurance entities are personally liable for losses their clients believed would be covered under the fraudulent contract. In addition to the personal liability, the agent is also guilty of a felony by representing an “unauthorized entity.”

Errors & Omissions Insurance

While no substitute for due diligence and competent business practices, Errors and Omissions (E&O) Insurance is a type of “malpractice” insurance available to insurance agents who may unwittingly be caught up in such circumstances. As our society becomes ever more litigious, agents will want to seriously consider such coverage.

The Free Look Provision

Most agents will describe to an applicant the full range of rights the policy will confer — non-forfeiture options, policy loans, assignment, etc. There is one right, however, that could adversely affect the agent: the Free Look provision. This provision gives the applicant a short period of time to reconsider the purchase and recover his or her initial premium for any reason — or for no reason at all.

Life & Most Health Insurance
10 Days
Minimum Free Look period required by Florida law
Medicare Supplement (Medigap)
30 Days
Extended minimum required by Florida law
Long Term Care Policies
30 Days
Extended minimum required by Florida law
Insurers may extend these Free Look timeframes for their policies, but may not shorten them.
The Conflict of Interest

If the applicant cancels the policy within the Free Look period, the agent will not earn his or her commission. This creates a conflict of interest between the best interests of the client and the interests of the agent — and this conflict must be disclosed.

The agent’s failure to advise the policyowner of his or her rights under the Free Look provision, or to explain the details of the provision, constitutes unethical behavior.
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