DATE: September 28, 2026
TO: All Insurers Authorized to Transact Business in the State of Maryland
RE: Insurer Responsibilities Regarding Producer Licensing, Internal Appointments, and Maintenance of Producer Registers
The Maryland Insurance Administration will consider comments concerning this draft bulletin that are submitted to Mary Kwei, Associate Commissioner, Market Regulation and Professional Licensing. [email protected], on or before October 28, 2026.
The purpose of this Bulletin is to remind all insurers authorized to transact business in Maryland of their statutory and regulatory obligations regarding insurance producer qualifications, internal appointments, and the maintenance of producer registers.
The Maryland Insurance Administration (MIA) continues to observe instances during market conduct examinations where insurers have accepted business from producers who were either unlicensed, not appointed, or whose information was not properly maintained on the insurer's internal register. Ensuring compliance with these requirements is essential to mitigate the risk of fraudulent activities and safeguard the interests of Maryland policyholders.
Verification of Licensing and Authority
Pursuant to § 10-103, no person may sell, solicit, or negotiate insurance in Maryland unless they are properly licensed for the specific line of authority being transacted, and hold an appointment with the insurer. Insurers are legally prohibited from accepting insurance business or paying commissions to individuals or business entities who do not hold an active Maryland license. It is the responsibility of the insurer to verify a producer's current licensing status before allowing the producer to write or issue policies.
Mandatory Maintenance of the Producer Register
In accordance with § 10-118(b) and COMAR 31.03.13.02, insurers are mandated to maintain an internal producer register.
Within 30 days of appointing an insurance producer, the insurer must record the following details within its producer register:
The full name of the insurance producer and residence or business address
If the producer is a business entity, the business name, address and tax ID number
The active Maryland license number.
- The effective date of the appointment.
Insurers must maintain this register for as long as they act as an insurer within the State of Maryland, ensuring it is readily available for inspection by the Commissioner upon request.
Notification and Documentation to the Producer
Under COMAR 31.03.13.04, within 30 days of appointing a producer, the insurer must provide the appointed producer with written documentation confirming the appointment. This documentation must contain the specific information required under 31.03.13.04A.
Ongoing Supervision and License Verification
Under COMAR 31.03.13.03(A), at least once every 31 days, an insurer must actively determine whether the license of any insurance producer currently on its register has been suspended or revoked. If a producer's license is no longer active or valid, the insurer, within 5 business days, must terminate the appointment of the insurance producer. Under COMAR 31.03.13.02B(2), within 30 days after the effective date of termination, the insurer must update its register to reflect the termination, adding the date of termination and an identifier that indicates if the termination was wholly or partly “for cause".
Reporting Terminations "For Cause"
Under § 10-118(e)(1)(ii) and Bulletin 26-3, an insurer must notify the Insurance Commissioner within 30 days if a producer's appointment is terminated whole or in part due to the belief that the producer has engaged or is engaging in any of the activities set forth in § 10-126. These submissions must be handled via the MIA's online enforcement portal or emailed to the Enforcement Division.
Failure to maintain an accurate producer register, check license status every 31 days, or report "for cause" terminations constitute a direct violation of Maryland law and may subject the insurer to administrative penalties, including fines and the suspension or revocation of their certificate of authority.
MARIE GRANT
Commissioner
Signature on Original
Mary M. Kwei
Associate Commissioner
Market Regulation & Professional Licensing