The Commoditization of P&C Insurance
An article in the Insurance Journal was titled, "Agents react to Walmart, OverStock in Insurance; We aren't Dead or Dying, We are Evolving." The comments presented by agents and experts were clearly heartfelt. Their theme was that P&C, especially all insurance that is not personal auto, is complex when done right. The comments pointed out that many direct writers and these new entities do not explain the complexity. Consumers buying from these entities therefore might not get the coverages and the amount of coverage they truly need. Einstein had a great quote which makes this point well, "Make everything as simple as possible, but not simpler."
Another point they made was that a large portion of consumers are inadequately educated regarding insurance and the proper coverages. This goes without saying but a subtle insinuation or at least an inference can be drawn that these entities are taking advantage of inadequately informed consumers to sell them insurance these consumers think is adequate, but is not. These entities may get away with this practice because the standard of care for these kinds of writers is often less than it is for traditional agents. The standard of care is so low that some courts have ruled the standard of care is nothing more than caveat emptor. The insured will be left holding the bag whereas if they purchased insurance from an independent agent, they would be better informed (and while not stated, the conclusion is clear, the insured might have a better chance at suing the agent and winning, which is not a bad selling point).
I agree with these points. However, most of these points emphasizing how important agents are to clients choosing the right coverage are hypocritical. This hypocritical position is a fact. I am not offering an opinion, but an absolute fact. Hide and deny the fact if you want, but when you put your head in the sand, a prominent body part is made available for a painful whipping.
The fact is these opinions are hypocritical because while agents can definitely offer crucial and important education to consumers, in both personal lines and commercial clients, they too often choose to not offer any education, any coverage reviews, nor even review the insureds' true coverage needs. I have been visiting agencies for 25 years and I have been doing E&O audits for approximately 20 years. My experience is 90%+ of agencies do not use coverage checklists of any kind on a consistent basis. Without a coverage checklist, identifying the customer's true needs and offering them the coverages they truly need is not possible. My experience is that a majority of agencies go years without reviewing at least some portion of their clients' exposures. In other words, they do "renew as is" year after year. I have been in agencies where some clients have not had their coverages reviewed in ten or twenty years. Many agencies quote requested coverages or producers only match expiring coverages. A computer can do both these functions as well or better than a human. Quoting existing coverages is the epitome of commoditization.
These are facts and however unpleasant they are, deny them at your risk. To talk about how agents offer such valuable services but then to not actually do the work is hypocritical. Agents and some associations are trying to have it both ways. They want the spread of commoditization to slow or stop, but in the same magazine or the same convention venue, they will have E&O attorneys advising agents to rely on "duty to read" case law and to not advertise the agency is an expert and others advising agents to not spend time on small accounts. It is a fact that one cannot have their cake and eat it too.
Here are some facts to consider:
- If agents do not think insurance is a commodity and they do not want the public to think of insurance as a commodity, then AGENTS need to put their money where their mouth is and quit treating insurance as a commodity.
Rather than quoting requested coverages, explore the insured's needs and give them a quote for coverages most applicable. Most CSRs do not discuss the complexities of homeowners insurance. Most do not even offer higher liability limits. Higher is not defined as $300,000 or $500,000, although that would be an improvement in many agencies. Higher is defined as higher limits than the insured has requested regardless of what they requested.
Producers in personal lines and especially small commercial lines are often no better than CSRs and are often worse. 90% of producers in my experience refuse to use coverage checklists unless forced by management. Insurance is indeed complex. That is why a coverage checklist is so important. Use coverage checklists to determine an insured’s real needs. A properly used coverage checklist is valuable to identifying these complexities and building coverages customized to that one insured's needs. Customization is required to avoid commoditization. Not only are coverage checklists proven to reduce E&O exposures, but my best clients who use coverage checklists correctly and well always increase sales.
The idea that missing one item on a checklist creates an E&O exposure is simply an excuse. This is an excuse to avoid responsibility and any excuse to avoid responsibility is also a reason insurance should be commoditized. Additionally, if only one item is missed on a coverage checklist, that is much better than missing 10 coverages without one. Any attorney that says, "Yes, but we can win if you miss ten because I can show you are a peddler because you miss so much," is missing the bigger picture. How great is it to win a case based on being dumb and lazy?
I cannot imagine half as many E&O claims occurring if clients had their coverages customized and then reviewed annually. In fact, a Utica Mutual study following Hurricane Katrina found that approximately 50% of the E&O claims that occurred would not have occurred had agents used coverage checklists. So it is great to talk about agent advantages, but agents must walk the walk to have value.
- Customers need an agent's professional advice. If you really believe customers need your professional advice, do not hide behind E&O defenses like "Duty to Read" your policy. Consumers do not need an agent if they have to read the policy, understand the policy, question the policy, and do all this in a timely manner. That is why they are paying you a commission. They are paying you to do this for them.
- The article cited experts saying an online presence was key. I do not disagree but what is an agent going to advertise if they hide behind so much E&O advice such as, "Don't advertise that you are an expert." Are agencies going to advertise instead, "Best price for a commodity!"?
Step up and advertise your real value and then follow through is my suggestion. If you do not want to be commoditized, only one true alternative exists and that is to become a true professional and then act as a professional for each client. Very few agents have the guts and work ethic to do this which is why this strategy is so great.
- Quit being lazy. I cannot write how many times I have heard producers say they do not know whether their client has certain coverages because they never verify the coverages when the policy arrives. They do not know the forms because they do not read the forms. They do not understand BI coverage because they will not take a BI class.
Recently I have witnessed several instances where producers were too lazy to even get client signatures on applications. Consumers do not need lazy agents.
- The article cites a PIA study showing 67% of consumers want their agent to contact them at least every six months. This is great news. Why agents so consistently ignore what their clients want is beyond me. My real world E&O audits and agency due diligence for acquisitions shows consistently that agents do not always even communicate beyond perfunctory forms annually. If a client says they want communication every six months and do not receive communication of value even annually, for what do they need the agent?
I have no doubt some readers will be upset reading this article, if they've gotten this far without turning red. Hypocrites usually get upset when called out. Others will get upset that I am somehow singling them out even when I do not know them. As crazy as that sounds, it happens most times I write an article like this where someone I do not know thinks I have singled them specifically out. Others will be upset that I am saying all agents take this track when they are actually using checklists, reviewing forms, getting true technical education (versus rote CE courses), etc. That always happens too. No where do I write or believe 100% of agents do this or that.
Every time I write about the value of stepping up and being a true professional, I receive disparaging comments from clearly insecure agents and company people. But I also get EVIDENCE, not just comments, from agents that are true professionals regarding how they take advantage of the amateurs. Their customer satisfaction is clearly higher, their sales are greater, their profits are higher, and their E&O exposure is clearly lower.
My consulting experience is agents who do not treat insurance as a commodity have average commission per account 10%-30% higher than norms. The PIA study mimics an IIABA study from 15 years ago that showed great opportunities existed then and now for agents that have strong work ethics to become true professionals, to learn coverages and learn to articulate those coverages to clients so customers understand and appreciate the complexity of insurance when it is done right. These studies tell agents what consumers want and agents that listen have much better opportunity than those who do not. Studies then and now tell agents that consumers want professional agents. They do not want a commodity.
I don't expect to win the hearts and minds of agents and companies turning red reading this. My goal is to explain the situation and hope the best agents and companies realize how great the opportunity is to take advantage of their lesser competitors.
(If you're not sure how to go about becoming a professional but want to realize the opportunities or use a checklist positively, contact me. It is fun to take advantage of amateurs and to provide better coverage to clients.)
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E&O: Does increased professionalism increase the risk of being sued?
I have been wondering about this for ten years. I do not have statistical proof one way or another but I have been completing E&O audits for twenty years and I have seen my share of claims. Moreover, the claims I see involve agencies I get to know relatively well during the audits, where I interview all employees. My perspective then goes beyond what is on paper.
Maybe my first week of audits twenty years ago set the stage. The agency owner had requested a voluntary audit. Upon walking into his office, he advised he'd never been sued in 40 years of operation. Given his location, a well-known litigious district, I asked how he managed such a feat. He said he never insured any one he did not trust. His agency as I recall, had average E&O exposures based on its procedures. The producers' knowledge was a bit better than normal, but not superb. On paper, he had an average agency that was never sued.
A few years ago, preceding a large natural catastrophe that resulted in hundreds of E&O claims, I audited many agencies that were to be hit by these E&O claims. On a scale of 1 to 10, with 10 being the best relative to E&O risk management, one agency was a 1 or 2, several would have scored between 4 & 7, and two or three were 8's or 9's. Which group incurred the fewest E&O claims? The agency that would have scored a 1 or 2! It was incompetent and sloppy, but it was not sued.
Recently I saw two agencies get sued that I would score a 6 or 7 on an E&O risk management scale. However, the suits involved the agencies’ best people who I’d score a nine. Both are diligent, smart, competent, detailed, and nice people.
Why, if the hypothesis is possibly accurate, would good agencies be sued more often than lousy agencies? I do not know of any E&O studies on this subject but the medical malpractice field does have studies on this subject which may be a good proxy.
The University of Toronto completed a study of two groups of doctors. The first group had been sued at least twice. The second group had never been sued. The researches taped client-patient interactions and played them for the public. Ordinary people could predict with 80% accuracy, which doctors were sued and which doctors would not be sued.
Harvard then took the base audio data and distorted the audio. Through a complicated audio testing program based on the physicians' speech inflections, researchers obscured all the words through the software and shortened the dialogue to 30 seconds. The public again identified the doctors most likely to be sued with a high accuracy level. The conclusion assumes that people like or dislike doctors based on their speech pattern and are in turn, less likely to sue doctors whose speech patterns are most likeable.
These studies seem to support my experience. If incompetent, make sure your customers really like you. Make sure your speech patterns are easy on the ear. Be extremely likeable. Be a loveable goof!
That advice has to just rub raw highly competent, though maybe less loveable, agents. Here is some salve: First, you can become more loveable. The old but true book, How to Win Friends and Influence People by Dale Carnegie is almost an exhausted anecdote but it is a good place to begin. Second, tape yourself talking and listen. A painful exercise I know but less painful than a suit.
On the other hand, loveable but sloppy and incompetent is not a panacea. How much someone likes you is less important today because often the party suing or forcing the suit has no relationship with the agent. These third parties may be an insurance company, a lender, a subcontractor of some kind, or a government entity. The decision to sue will not be the agent’s buddy’s decision. In particular, insurance companies seem to sue their own agencies more often these days. I haven't personally seen an insurance company not sue an agent just because they liked them if the dollars were large enough.
Another reason is the change in consumer buying. Customers with low expectations are moving to buy from direct sellers. Additionally, if the claim is big enough, likeability has less influence. For the insured, getting money from someone may mean economic survival.
Competence may be why a customer more likely to sue buys from a competent agent in the first place. These clients understand the complexity of their situation. They want an agent who is knowledgeable, thorough, and competent. They also know these kinds of agents likely can be sued successfully more easily. After all, if a complex account buys from a loveable goof, what happens in court? More than one court, including Federal courts, have ruled caveat emptor when goofs were the seller.
The size of agencies is also forcing a change because as agencies are forced to get bigger, it is impossible to really know all your clients. Remember that to get away with incompetence, one has to be very likeable but if the client does not know you, the likeability factor becomes a moot point.
I don't know the future is all that bright for incompetent but loveable goofballs. The future for the competent agent can be enhanced by becoming a bit more loveable though. I am not suggesting competent agents I've known are not loveable or likeable. I am suggesting that an incompetent agent has nothing else upon which to rely but their personality so they've honed their likeability to a 10. Competent agents frankly do not need a likeability score of 10. Improving the score a little may be the difference between incurring or not incurring a suit though and may even lead to taking a few sales from the incompetent agents in town. Try it, you might like it.
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Many carriers are nervous
Many insurance companies are nervous about their future. Obviously a company can't be nervous but the people running these companies are nervous. Some are silently scared. They are nervous and they are scared because they are smart to understand their business model is in peril. Their business model is at risk because the traditional independent insurance company, and captive insurance company model for that matter, is dependent on agencies being smallish and run by individuals. When the agencies are small, the company has more power and their risk is diversified. After almost two decades of demanding more and more from their agencies, consolidation has occurred. They have lost the power and their risk has become concentrated.
Twenty years of constantly demanding more and more volume, now exacerbated by predictive modeling systems which minimize the importance of upfront underwriting, is limiting the importance of agencies to just finding as much new business as possible, and agents are giving companies what they asked for. They have sold, they have joined clusters, and they have joined aggregators. Many of these organizations are now larger than all but the top 30 or so insurance companies. The companies now need them far more than these agencies/brokers need any one carrier and the smartest insurance company executives understand this fact plainly. The result? Loss of power, a concentration of risk, and a sales force that simply got bigger and still is not selling any more insurance.
In many cases carriers have exacerbated their problem by paying more for no better results just because of size. Whether this is because they are poor negotiators or not bright or because they know they have lost the upper hand and this is simply the easiest method of dealing with reality, the answer probably varies. Regardless, paying more for no more sales is not a long-term solution.
Another solution some carriers have calculated is to convince agencies to place business in their service centers. This sounds like a good solution because companies have analyzed that their retention is better, which makes sense. Agencies place the customer in the service center and forget about it. I find fascinating the arguments companies use to convince agencies to place business in their service centers. So far, I haven't discovered any that hold water from an agency's perspective. For example, the retention argument might be true for companies but I have not seen any evidence retention increases for agencies. Even if it does increase, say from the average 90% to 92%, is it worth two percentage points of commission? Financially, based on analyzing actual, not hypothetical, agency results, the agency loses.
The idea of the service center is to capture and hold the business forever, to limit competition, and keep the agency from moving accounts. Similarly is the long held strategy of simply buying agencies. More of this happens by companies than many agency owners realize, especially when it is quietly completed. Both strategies are predicated on the belief that once written, if people inside the agency will not move the business, the clients will not move on their own. I have heard company executives bluntly state this belief and I have seen companies whose actions clearly state this same belief. Moving customers cost agencies a lot of money and increase their E&O exposures so they do not move clients just to aggravate their company partners. A company that loses site of this fact will likely lose significantly because at first, their model will look really good. Then their rates will become uncompetitive or their product will come up short or heaven forbid, the customers will realize they are no longer doing business with an independent agency but a direct writer. That is not going to end well for anyone.
As an aside, again using actual results, I find few agencies actually make more money when they use company service centers because the commission loss is not offset by a reduction in workload. Sometimes agencies continue to service clients because they simply cannot let go and other times they simply are unsatisfied with the quality of the carriers' service center.
Those agencies that have remained independent pose another anxiety because their size makes independent perpetuation more difficult. I am not writing about the financial difficulty of perpetuation because if both parties are reasonable and enough planning time exists, the financial factors can be engineered. The difficulty is that internally perpetuating a larger agency requires significantly more management skill. I find that almost no insurance company executives acknowledge this fact.
While maybe not clearly articulated yet the writing is clearly spray painted on a big wall, another solution some companies have is to cut agency compensation. Part of this strategy is hidden by the push to service centers. Part is hidden by the change in contingency contracts. The solution is key for carriers with inadequate profit margins. Given how profitable this industry has been, the fact that surplus is at record highs, and how some companies are making as much as ever in investment income even though yields are low, these factors should be a red flag for everyone reading this article who has heard a carrier complain about profitability and the lack of investment income. This warning is also meant for company employees.
I cannot figure out if company executives really do not understand their own investment income or if they ignore the situation because they hope to get past their company's problem without acknowledging the situation. The situation is fairly simple. Some companies have made so much money their investment portfolio has grown much faster than yields have decreased thereby generating far more investment income. Combine this fact with 2013 and 2014's huge stock market increase and some insurance companies are making excellent returns (and besides, yields have been relatively steady for the last four years). Quite a few companies have not made enough or some made enough but did not leave enough cash in the company to enjoy this opportunity. If these companies cut commissions and their competitors do not, this outcome will not be pretty either.
This sounds dire but it is not dire at all for those companies whose executives have the luxury of a large investment portfolio (generally at least 300% of NWP) or executives who are willing to learn. And that is maybe the biggest mistake company executives make. In 25 years in this industry, I have found extremely few, less than five really, top insurance company executives that did not already know all the answers. If by chance someone is reading this article clearly, the opportunities presented by your lack of excessive ego have never, ever been better.
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The Opposite of Accountability
I seem to cross many insurance people the wrong way by insisting accountability is important to agency success. For example, it seems so logical that an agency will be more successful if producers are held accountable for actually making sales. I have a Berlin Wall size mental block on how zero accountability for producers not producing will lead to producers producing. My Berlin Wall mental block grows to a Great Wall of China mental block when producers are paid even if they don’t produce. For the absolute life of me, I cannot fathom why producers not held accountable for selling, but being paid anyway, will be so motivated to change their ways to begin producing when they really have never done so previously.
However, in light of the often strongly worded emails I receive and lectures I hear where good hearted people try to convince me that accountability ruins an agency’s good mojo, I felt it wise to see if I could tear down the walls of my mind and discover their point. I did and I think they're correct.
Accountability ruins a party. Now apply it to an agency. Take a handful of people that are paid well, have little responsibility and hence little accountability and who get to socialize at will with important people. This creates an ideal, fun work environment. Introduce accountability, where sales have to come from golf, entertainment, socializing, fund raisers, and so forth, and the job's fun deteriorates quickly. Accountability ruins a party. I actually get this, a surprising light bulb some people who know me might appreciate.
Another aspect is why does accountability even matter if the agency is making plenty of money? Accountability probably does not matter if that profit is assured forward or if tomorrow does not matter. For example, if a person is 85, accountability probably does not matter. Or if someone is a lucky person that never considers the future or is simply an irrationally optimistic person, accountability is a bummer. I get that too. I think the favorite phrase of such people is, "Don’t be such a downer maaaaan." Bumming out an irrationally optimistic person is no fun.
Which brings me to the opposite of accountability and that is the faith of Karl Marx and the '60's movement, that if people are freed from the chains of capitalism, each individual will rise to the occasion, work hard to their fullest ability, achieve all their goals, and as a result, ability and hard work need not be specifically recognized.
This is a really appealing concept. It goes hand-in-hand with the idea of "build it and they will come." Good karma helps too. I don't believe a vacuum of accountability has ever worked anywhere to my knowledge on a large scale and using minimum producer standards, I have not seen it work with a team of producers either. But I'd like to see it work. Then again, what happens when people in general are not held accountable, do not have responsibilities, and are no longer children or old enough to be that part of society usually exempted from work? That’s not important--just my old way of thinking creeping back into my brain.
In a lack of accountability environment, someone still has to pay the bills. So how can income be earned without producers producing? Agencies can buy other agencies. Buying agencies is often much more fun than holding producers accountable which may be one reason why so many agencies are sold and why few buyers ever achieve material organic growth (real organic growth, not nominal organic growth). Another indication that buyers avoid accountability is that many serial buyers do not try hard to integrate their various acquisitions beyond minimal requirements. Integration requires accountability. So maybe the lack of an accountability environment resembles a serial acquirer's environment. With the federal government printing money far faster than it can be spent, if a person has access to that money, it is a fairly easy environment to create and just might be the opposite of accountability.
Another perspective might be an agency in a location where little competition exists. A lot of money is being left on the table by not having accountability, but if enough money exists for the party, that is all that matters. More than a few such locations exist.
Another type of situation is where one person is an extraordinary producer that wants everyone to just get along so much that he/she is willing to subsidize all the producers that don’t produce. Harmony is important. Would the agency be more successful, generate a better living for its employees, likely provide better service to clients, and generally have a better future if more than one producer produced? Absolutely! But that would kill the party.
As you might tell, I've never been much of a party person. Even though I'm getting older and people usually party less as they age, I'm going to work on this aspect of my life. I think I am going to try to find someone that can sell lots of consulting for me and someone else to do all the work, and then both people will value harmony far more than accountability so that I can party more. I encourage all the readers who already know how important it is to let others do all the hard work but not be paid commensurately to keep living the great life. For all the others, maybe we'll need to form a support group so we can learn the better life too.
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Paradigm Change: Is being a "nice guy" still a ticket to success?
One of the reasons I became an agency consultant 20+ years ago was because I wanted to work closely with the nicest group of people I'd ever met. I really enjoyed and still enjoy being around agency owners.
The insurance distribution industry is changing fast though. It is changing faster than I've ever seen, due to many different forces including multi-billion dollar advertising, changing buyer preferences, regulation and more regulation, carrier consolidation, predictive modeling, the easy money policy of the Federal Reserve, and the wave of clusters and aggregators. Some forces counter one another, but in total, this mass means being nice is not the solution it once was. More grit, more ability to tolerate conflict, and more ability to enter conflict is required to succeed in today's changing environment.
Keep in mind the generation of which I am writing. They became adults listening to Joan Baez singing Kumbaya. One of the most memorable commercial jingles was Coke's, "I want to teach the world to sing in perfect harmony." The most famous protest placard was, "Make Love Not War!"
One way or another, peace and harmony became the foundation of so many agency owners it is now a crumbling cornerstone of the entire industry. Going along and getting along explains the proximate cause of agencies suffering today. For example, it explains why agency owners:
- Will not negotiate constructively with carriers for more compensation unless they join a cluster and then hide behind the thin shield the cluster provides.
- Do whatever the client requests even if the action is not in the agency's best E&O interest or maybe even the client's best interest.
- Do not force producers to follow agency rules or for that matter, they do not even force producers to produce.
- Desire to do acquisitions rather than make true sales.
- Focus on marketing and joining clubs rather than asking for a sale. To actually boldly ask for the sale creates conflict in their minds so they work to get the customer to ask to purchase.
A willingness, even if reluctantly, to enter into what you believe is conflict is crucial to building an agency today. The good news is that what you might feel is conflict is not perceived that way by many people on the other side of the meeting. The conflict is only in your mind. Do not argue for it. As Richard Bach said, "Argue for your limitations and sure enough, they're yours."
Ridiculous would be the word to describe any suggestion that owners can just flip a switch and cease being conflict avoiders. Instead, I am suggesting proactively creating positive environments in which a sale can be made instead of waiting to take an order (a difference between marketing and selling is that in marketing, the agency takes an order whereas in a sale, the agency asks for the order). For example, an environment in which a solidly knowledgeable owner can espouse the need for great coverage and how the right coverage can change lives for the better will result in sales. An owner making proactive sales is a far better agency leader than one who is not.
Another option I have seen work spectacularly is to hire someone that can deal with conflict, particularly holding producers accountable without missing a beat and without sweating a drop. Keep in mind, when a producer does an end-run around this "Enforcer," as they'll initially be known, the agency owner MUST support their manager. It only has to happen once. In my experience with this option, the agency's transformation is like a rising sun. It is a brand new day full of opportunities that did not exist the previous day.
If you are a people pleasing, conflict avoiding agency owner feeling overwhelmed, knowing what needs to be done but paralyzed to do it, the agency's future and your future has severe limitations. I am not writing about changing. I am writing about progressing. Progression does not mean painful change. In fact, with coaching, a custom strategy meant specifically for your agency, and execution on that plan, the angst you feel today can be eliminated. You just need to take the most difficult step, the first step, and make a call to ask for help.
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Chris Burand is president and owner of Burand & Associates, LLC, a management consulting firm that has been specializing in the property/casualty insurance industry since 1992. Burand is recognized as a leading consultant for agency valuations, helping agents increase profits and reduce the cost of sales. His services include: agency valuations/due diligence, producer compensation plans, expert witness services, E&O carrier approved E&O procedure reviews, and agency operation enhancement reviews. He also provides the acclaimed Contingency Contract Analysis® Service and has the largest database and knowledge of contingency contracts in the insurance industry.
Burand has more than 20 years' experience. He is a featured speaker across the continent at more than 180 conventions and educational programs. He has written for numerous industry publications including Insurance Journal, American Agent & Broker, and National Underwriter. He also publishes Burand's Insurance Agency Adviser for independent insurance agents.
Burand is a member of the Institute of Business Appraisers, a department head for the Independent Insurance Agents and Brokers of America's Virtual University, an instructor for Insurance Journal's Academy of Insurance, and a volunteer counselor for the Small Business Administration's SCORE program.
NOTE: The information provided in this newsletter is intended for educational and informational purposes only and it represents only the views of the authors. It is not a recommendation that a particular course of action be followed. Burand & Associates, LLC and Chris Burand assume, and will have, no responsibility for liability or damage which may result from the use of any of this information.
Burand & Associates, LLC is an advocate of agencies which constructively manage and improve their contingency contracts by learning how to negotiate and use their contingency contracts more effectively. We maintain that agents can achieve considerably better results without ever taking actions that are detrimental or disadvantageous to the insureds. We have never and would not ever recommend an agent or agency implement a policy or otherwise advocate increasing its contingency income ahead of the insureds' interests.
A complete understanding of the subjects covered in this newsletter may require broader and additional knowledge beyond the information presented. None of the materials in this newsletter should be construed as offering legal advice, and the specific advice of legal counsel is recommended before acting on any matter discussed in this newsletter. Regulated individuals/entities should also ensure that they comply with all applicable laws, rules, and regulations.
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