The DOI Regulatory Bulletin 2015-04 was issued on June 25th, 2015
The August 20th edition of the MAIA’s newsletter “The Massachusetts Agent” announced that in response to various questions from its member agents, the MAIA had decided to request that the Commissioner of Insurance Daniel Judson implement certain changes to Bulletin 2015-04 regarding “Issue of Notices of Transfer of Insurance Coverage”.
In a letter to Commissioner Judson, MAIA Vice President of Government Affairs and General Counsel Daniel J. Foley, Jr. Esq. requested that the Division take into consideration those “…insurance agencies who use agency bill for getting payments from their clients”. Further, the written request outlined the following scenario in which an agency bill may be adversely affected under the provisions of Bulletin 2015-04:
- 01/01/2015 auto policy bound with insurance carrier and client is set up for agency bill;
- 01/05/2015 Agency bill invoice generated and sent to client with payment expected within 30 days of coverage being bound;
- 01/30/2015 Down payment received and posted to client account.
- In this scenario, reading the language in the bulletin, the ten day notice of transfer would start on 01/30/2015 and would have to be sent no later than 02/09/2015. This would be very late in the process and, as a result, the 2A notice would not be going out in a timely fashion.
As a result, the MAIA has asked the DOI to amend the Notice of Transfer language in order to minimize the impact of Bulletin 2015-04 on agency accounts. More specifically, it has requested that the ten day notice of transfer language be amended “…so that in addition to the down payment or first payment being received it will allow for agency bill transactions by permitting agents to send the Notice of Transfer on the receipt and acceptance of a signed application for insurance. The signature could be either an original signature or an electronic signature.”
For more information, please refer to the August 20th edition of The Massachusetts Agent here.
