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Lead Generation – Your Leads, Your Responsibility

Lead generation continues to be a concern in the insurance sales process. For example, Maine recently issued Bulletin 403 on May 11, 2015, which deals with a number of concerns around lead cards. The bulletin calls out some of the most prevalent issues we see with lead generation materials:

  • Containing words, symbols, seals, or logos that suggest to the consumers that the card comes from or is endorsed by any government agency.
  • Cards that fail to disclose conspicuously, in plain and understandable language and a typeface that will be visible to the mailing's intended audience, that the card is an insurance solicitation and that an insurance agent may contact the consumer.
  • Cards that suggest that the sole purpose of the card is to offer free information or a brochure to the consumer or provide a free review of benefits for the consumer ‘Free elder law information,‘ ‘Senior benefits update,‘ ‘Medicare health plan update,’ etc.
  • Cards requesting that consumers mail their response to an unspecified addressee, such as 'National Response Center,' 'Regional Reply Office,' or simply a Post Office Box, and which do not allow consumers to know the true identity of the addressee, whether it be a producer, insurance agency, or lead generating entity.

The bulletin also reinforces that producers and agencies using lead generation devices are responsible for ensuring compliance for the materials.  Similarly, back in 2012, Kansas issued a reminder that there is “no regulatory buffer” between third parties and carriers or agents. It’s become increasingly important to develop policies and procedures to monitor, review and act on issues within a carrier’s sales force. While there is not a one-size-fits all approach to how to set up such a program, it’s clear that not having a plan at all is no longer an option.