A New Hampshire insurance agency owner who held a Massachusetts non-resident producer license for more than a quarter century has lost the right to do any insurance business in the Commonwealth — not because of the conduct that first drew a regulator’s attention, but because he never told Massachusetts about it and then denied it under oath.
On June 8, 2026, a Division of Insurance (“DOI”) Presiding Officer, Matthew A. Taylor, Esq., entered a Summary Decision and Order revoking every insurance producer license issued to John K. Obrey of Londonderry, New Hampshire, and assessing a $2,000 civil penalty. Mr. Obrey is the designated responsible producer for the Obrey Insurance Agency and had been licensed in Massachusetts as a non-resident producer since 1998.
The decision is the latest in a line of Agency Checklists revocation cases — the Ramon Noronha and Jay Seitz matters among them — in which a producer’s undoing was not the original violation alone, but the failure to disclose it.
A coverage placement that fell apart in New Hampshire
The chain of events began in early 2022, when Mr. Obrey was handling a commercial liability renewal for a New Hampshire construction company identified in the regulatory record only as “L.R.” On January 4, 2022, Mr. Obrey invoiced the client $12,228.48 for the renewal, and on January 27, he cashed the client’s check.
The placement, however, was already coming undone. After the carrier received a demand package arising from a prior loss involving the insured, it withdrew its offer of renewal, and L.R.’s coverage lapsed on February 5, 2022. Mr. Obrey told New Hampshire regulators that he had relayed the carrier’s decision to the client, but he could produce no documentation that he had done so.
What the record does document is that, with no policy in force, Mr. Obrey’s office issued four certificates of insurance to L.R. between February 14 and April 1, 2022 — three of them over Mr. Obrey’s own signature — each representing coverage that did not exist. The exposure became concrete on March 30, 2022, when L.R. suffered a loss and an outside broker had to be engaged that same day to quote and bind replacement coverage.
The New Hampshire Consent Order
On June 18, 2024, the New Hampshire Insurance Department (“NHID”) resolved the matter through a Consent Order. Mr. Obrey admitted a violation of NH RSA 400-B:3, IV, for failing to retain written communications with the client, and four violations of NH RSA 402-J:12, I(h), for issuing certificates of insurance for a policy that was not in effect. The NHID imposed a $12,500 penalty but suspended $7,500 of it for two years, conditioned on Mr. Obrey committing no further insurance-law violation during that period, and required him to document improvements to the agency’s recordkeeping.
The Consent Order also expressly notified Mr. Obrey that it was a public, reportable action and that, going forward, he would have to answer “yes” to any question asking whether he had ever been named or involved as a party in an administrative proceeding. That instruction would prove central to what came next.
The reporting failure — and the renewal application
Here, Massachusetts law took over. Under M.G.L. c. 175, § 162V(a), a producer must report an administrative action taken against him in another jurisdiction to the Commissioner within 30 days. Mr. Obrey did not report the New Hampshire Consent Order.
The omission hardened into an affirmative misstatement nearly a year later. On May 2, 2025, Mr. Obrey submitted his Massachusetts non-resident license renewal and answered “No” to the application’s question whether he had “been named or involved as a party in an administrative proceeding … which has not been previously reported to this insurance department.” He certified the application’s truth under the pains and penalties of perjury.
A default, and a summary decision
The DOI filed its Order to Show Cause on October 30, 2025. As in many of these matters, Mr. Obrey never answered. Because no answer was filed within the 21 days required by 801 CMR § 1.01(6)(d)(2), the allegations were taken as true, and the Division was entitled to summary decision under 801 CMR § 1.01(7)(h).
The Presiding Officer found that Mr. Obrey’s conduct supported discipline under two clauses of M.G.L. c. 175, § 162R(a):
- Clause (a)(1) — providing incorrect, misleading, incomplete, or materially untrue information on a license application, based on the “No” answer on his May 2, 2025, renewal; and
- Clause (a)(2) — violating the insurance laws, based on his failure to report the New Hampshire action as § 162V(a) requires.
Notably, the Presiding Officer declined to decide the harder question the Division had also pressed — whether the underlying New Hampshire conduct described in the Consent Order was itself independently disciplinable in Massachusetts. Because the reporting failure and the false renewal answer each arose after, and wholly apart from, the conduct addressed in the Consent Order, he found it unnecessary to reach that issue. The revocation therefore rests entirely on the candor and reporting failures — not on the certificate-of-insurance conduct that started the matter in New Hampshire.
The fine: a $2,000 tally
In setting the penalty, the Presiding Officer worked from two — and only two — disciplinable acts. For each act, the statute offered a choice of caps: up to $500 under M.G.L. c. 175, § 194, or up to $1,000 per act or practice under M.G.L. c. 176D, § 7. Reasoning that fining the same act under both statutes would be duplicative, he assessed only the greater available cap for each act:
- $1,000 for failing to report the New Hampshire administrative action; and
- $1,000 for providing materially untrue information on the renewal application.
The result was a $2,000 civil penalty, payable within 30 days.
Final orders and the compliance takeaway
Beyond the fine, the Order revokes all of Mr. Obrey’s Massachusetts producer licenses; directs him to return any licenses in his possession; orders him to cease and desist and to refrain from transacting insurance business in the Commonwealth, directly or indirectly; and requires him to dispose of any Massachusetts insurance interests in compliance with M.G.L. c. 175, § 166B.
There is also a sting in the tail back home. Because the New Hampshire Consent Order suspended $7,500 of Mr. Obrey’s fine on the condition that he commit no insurance-law violation within two years of its June 18, 2024 execution, the Massachusetts adjudication — finding violations of the Commonwealth’s insurance laws comfortably within that window — may put the suspended balance back in play in New Hampshire as well.
For Massachusetts producers and the compliance officers who advise them, the lesson is the familiar one these cases keep teaching: an out-of-state action is survivable, but the duty to disclose it is not discretionary. As the Obrey, Noronha, and Seitz files all show, the reporting failure routinely does more lasting damage than the conduct it was meant to conceal.
This article is based on the public records available to the author, including the Division of Insurance’s decision and orders, and on prior Agency Checklists reporting. The allegations and findings described are those of the cited authorities; nothing in this article should be read as an independent determination of any individual’s conduct. Where a proceeding remains pending or its disposition has not been independently confirmed, that is noted in the text.
