Insurance Distributors Research Articles

Client’s representations as a means for documenting by an insurance distributor of the client’s requirements and needs – an analysis of the market practice

This article contains an analysis of the practice applied by insurance distributors with a view to concluding the insurance contract, which consists in obtaining a declaration from the client confirming that his/her requirements and needs have been determined. Such declaration is also an indication that the insurance contract concluded by the client corresponds with his/her requirements and needs in respect of the insurance contract proposed to him/her. The article also deals with the procedure for determining the client’s requirements and needs as well as with the importance of such procedure and a manner in which it can be documented. In addition, the distributor’s liability for carrying out an improper assessment of the client’s requirements and needs has been presented. The authors argue why the practice of using such declarations is not in line with the Act of 15 December 2017 on Insurance Distributions as well as touch upon the contents of the representations by indicating legal implications thereof both for the client and for the distributor.

Insurance secrecy

This article discusses the issues related to insurance secrecy, which is an important matter from the perspective of insurance practice. The insurance is based on clients’ confidence in the payment of benefits if an event covered by the insurance has occurred as well as on the assumption that crucial data concerning major facts of the client’s life provided in the course of concluding the insurance contract (specifically in the medical survey concerning the insured’s health condition) and while the insurance relationship persists will be disclosed to nobody in an unauthorised manner. Insurance secrecy is a professional secrecy regulated by the Act of 11 September 2015 on Insurance and Reinsurance Activity in order to ensure the confidentiality of data transmitted and to maintain clients’ confidence in insurance companies. Insurance secrecy is related to the protection standard of the right to privacy, with this right constituting one of the major values.This article deals with the temporal, territorial, material and subjective scope of applying the insurance secrecy, principles of liability for the breach thereof, as well as the admissibility of consent to release the information covered by the secrecy, by citing different voices concerning those issues. In addition, the author presents judgments relating to a number of aspects concerning the practical application of provisions concerning the insurance secrecy and highlighting the basic characteristic of the institution in question. Some practical aspects related to the application of the insurance secrecy are also addressed, taking into account the current realities of the insurance market, including technical solutions (e.g. social media), by means of which beneficiaries of insurance contracts or the insured themselves inform the public about the liquidation procedure, which puts the insurance companies, or more broadly the insurance distributors, in a more difficult position in terms of their image. Finally, some de lege ferenda proposals are put forward in respect of those aspects of insurance secrecy, which, in the authors’ opinion, need to be dealt with by the legislator.

Determinants of the Behaviour of Entities on the Insurance Market in the Light of Changes Introduced by the IDD Directive

AbstractOne of the most significant legal acts concerning the sale and management of insurance risk was issued on January 20, 2016, based on Directive (EU) 2016/97 of the European Parliament and of the Council of 20 January 2016 on insurance distribution (IDD Directive). The adoption of European IDD principles aims to enhance transparency in the operations of insurance distributors and improve the standards of their business practices. Its protective scope encompasses all individuals and entities involved in the sale of insurance products. The aim of the article is to ascertain the regulatory authorities’ impact on the insurance market, consideration of consumer protection, in light of the changes introduced by the IDD directive. The primary entities under examination, in the mentioned context of consumer protection, are distributors and supervisory authorities. The discussion includes an overview of the scale of the insurance market and its fundamental applications, as well as compliance within the framework of behavioural economics theory. Additionally, the paper addresses the aspect of threats posed to consumers by the analyzed changes in the European insurance distribution market. In this segment, the authors concentrate on the economic and social ramifications of IDD implementation for entities operating within the insurance market. The concluding section outlines the potential for development and the future prospects of financial intermediation concerning IDD utilization.

Risk prevention and insurance. Reaching or trespassing the insurance boundaries?

Insurance presents a well-recognized preventive value. However, in recent times when it comes to the preventive function of insurance, it is about much more and this can be heard in voices of increasing numbers of experts and insurers. Three fundamental motivators prompted the pursuit of this study: (1) dynamic shifts in the risk landscape, (2) emerging technologies facilitating risk prevention, and (3) a perceived regulatory gap in addressing societal needs and technological potentials. Legal considerations related to the utilization of new technologies in insurance have been extensively discussed, albeit selectively. These discussions have focused on issues such as the policyholder’s risk declaration, the potential use of sensitive data for risk assessment, and the automated distribution process (robo-advice). No comprehensive legal analysis of the preventive function of insurance in this context is available. There is a noticeable research and publication gap that should be filled by holistic considerations on risk prevention in insurance, both on the level of private law (insurance contract, duties of the insurance distributors, as well as public law, concerning the supervision over applying the risk prevention measures by the insurance carriers. Finding a new approach that could address the legal challenges is, according to the author, of great importance for the development of insurance as a protection tool for the most imminent social risks. The objectives included in the paper include showing the impact of new technologies on risk prevention, as well as analysis of what the role of the insurer in risk prevention may and should be from the legal perspective, including the potential change of roles in performing the insurance contract. The objectives of the paper involve several aspects, such as whether prevention has the potential to become a distinguished (re-) insurance service, as well as what the boundaries of the insurance contract and insurance business in terms of its compensatory and preventive function are.

Dispute Resolution in the Market for Insurance Distribution as one of the Tasks of Supervisory Authorities – Selected Issues

The purpose of this article is to indicate some of the tasks of microprudential supervision authorities (EIOPA and KNF) in the field of out-of-court dispute resolution on the insurance distribution market, which may directly concern customers of insurance distributors. The second part of the study will present the tasks of microprudential supervision authorities that solve problems on the insurance distribution market by indirectly influencing the customer and by ensuring customer security – for example EIOPA cross-border dispute resolution.

Regulating Robo-Advisors in Insurance Distribution: Lessons from the Insurance Distribution Directive and the AI Act

Insurance distributors are increasingly using robo-advisors for a variety of tasks, ranging from facilitating communication with customers to providing substantive advice. Like many other AI-empowered applications, robo-advisors have the potential to pose substantial risks that should be regulated and corrected by legal instruments. In this article, we attempt to discuss the regulation of robo-advisors from the perspective of the Insurance Distribution Directive and the draft AI Act. We ask two questions for each. (1) From a positive legal perspective, what obligations are imposed on insurance distributors by the legislation when they deploy robo-advisors in their business? (2) From a normative perspective, are the incumbent provisions within that legislation effective at ensuring the ethical and responsible use of robo-advisors? Our results show that neither the Insurance Distribution Directive nor the AI Act adequately address the emerging risks associated with robo-advisors. The rules implicated by them regarding the use of robo-advisors for insurance distribution are inconsistent, disproportionate, and implicit. Legislators shall further address these issues, and authorities such as EIOPA and national competent authorities must also participate by providing concrete guidelines.

Robo-advice in insurance distribution under Polish law. Outline of the problem

This article relates to the problems of introducing new technologies in the activities of insurance distributors, especially brokers, and points to essential legal aspects of non-adjustment or absence of legal solutions in this respect. The author focused her investigations on the essence, application of robo-advice in economic insurance, as well as its admissibility in the Polish insurance distribution model. The article points to the types of cooperation of robo-advisors with the traditional insurance distributor and imperfections of the outsourcing agreement’s legal regime. The applicable Polish civil law norms on civil liability for damages caused by artificial intelligence are also not keeping pace with the development of new technologies and require reform, in the first place, on the level of UE law.

Consumer Facing Artificial Intelligence Challenges in the Insurance Market

The Polish Insurance Distribution Act implementing the IDD Directive imposed on all insurance distributors a duty to ascertain customers’ demands and needs on the basis of information obtained from them. Legal doctrine holds that the distributor shall not refuse to conclude the insurance contract if the customer does not provide relevant information. Some authors claim that the refusal to provide a distributor with relevant information is tantamount to the customer’s waiver of demands and needs analysis. The article criticises not only this viewpoint but also practices developed by some insurance distributors who persuade their clients to sign the standard waiver form. According to the author, distributors should explain to their clients the importance of the demand and needs test rather than try to release themselves from the obligation to carry out such an analysis. In the author’s opinion, the refusal to provide the distributor with certain information may release him from the liability for failing to ensure that the insurance contract meets the customer’s demands and needs only in respect of this particular piece of information. Persuading the client to sign the standard waiver form without trying to elicit the relevant information should be treated as contrary to law or principles of social coexistence (good commercial practices). In such a situation, the client’s signature will not produce any legal effects.

On Waiver of Demands and Needs Analysis in Insurance Distribution

The Polish Insurance Distribution Act implementing the IDD Directive imposed on all insurance distributors a duty to ascertain customers’ demands and needs on the basis of information obtained from them. Legal doctrine holds that the distributor shall not refuse to conclude the insurance contract if the customer does not provide relevant information. Some authors claim that the refusal to provide a distributor with relevant information is tantamount to the customer’s waiver of demands and needs analysis. The article criticises not only this viewpoint but also practices developed by some insurance distributors who persuade their clients to sign the standard waiver form. According to the author, distributors should explain to their clients the importance of the demand and needs test rather than try to release themselves from the obligation to carry out such an analysis. In the author’s opinion, the refusal to provide the distributor with certain information may release him from the liability for failing to ensure that the insurance contract meets the customer’s demands and needs only in respect of this particular piece of information. Persuading the client to sign the standard waiver form without trying to elicit the relevant information should be treated as contrary to law or principles of social coexistence (good commercial practices). In such a situation, the client’s signature will not produce any legal effects.

Rules for Co-manufacturing and Governance of Insurance Products by an Insurance Undertaking and an Insurance Broker in the Light of Insurance Distribution Regulations

The entry into force of the Directive (EU) of the European Parliament and of the Council on the distribution of insurance, the Commission Delegated Regulation (EU) supplementing Directive (EU) 2016/97 of the European Parliament and of the Council with regard to product oversight and governance requirements for insurance undertakings and insurance distributors, as well as the Insurance Distribution Act of 15 December 2017 have created new opportunities for cooperation between insurance companies and brokers involving insurance products co-manufacturing and management. Such cooperation remains an exception to the principle of inadmissibility of brokers’ permanent contractual relationship with insurance undertakings, specified in Article 30 para. 1 point 2 of the Insurance Distribution Act. The article presents legal provisions relating to an insurance product manufacturing and governance and contracts regulating such cooperation. Its authors seek to answer a question whether it is necessary to maintain brokers’ independence from insurance undertakings in the course of an insurance product development and governance, and finally discuss the benefits and risks resulting from it.

Obligations of Insurance Broker as Insurance Distributor

The Insurance Distribution Act introduced a wide variety of notions and imposed a number of new statutory obligations, in particular, the definitions of insurance distribution and insurance distributor. The aim of the article is to present the statutory obligations imposed on insurance and reinsurance brokers as insurance distributors. The author points out that these duties can be divided according to different criteria and emphasizes that the broker's obligations towards the client are the most important in insurance practice. She discusses the duty to analyse client's needs and requirements, to prepare brokerage recommendation and provide a product card or prepare it if the broker is its creator. Moreover, she discusses the necessity to reveal the nature (and sometimes even the amount) of brokerage remuneration as well as to give the information about the method and procedure of handling claims (so-called claims policy). Having analysed the statutory obligations imposed on the insurance broker, the author comes to the conclusion that the basic purpose is the protection of clients and their interests. However, there is a concern that some duties might be treated as formal ones to be fulfilled in order to avoid legal liability. Additionally, the obligation of loyalty towards the client may be derived from the duty to keep good faith and perform due diligence.

Legal Barriers to the Development of Digital Distribution Channels in the Activities of Insurance Companies in Poland

The use of modern technologies in business is primarily aimed at simplifying business processes, reducing the costs of business operations as well as improving the quality of services offered to clients. It is also a response to the changing preferences of customers who are increasingly using digital solutions. Technological solutions may in particular be used in the insurance distribution process, which in recent years has become much more demanding, due a number of provisions regulating the distribution of insurance contracts were introduced. These changes are mainly aimed at ensuring that client makes conscious decisions regarding the conclusion of the contract, due to broad information requirements as well as matching the insurance to the client's needs. The use of mobile applications, Big Data, artificial intelligence or blockchain technology may allow for simplification, acceleration and reduction of costs in the process of distribution of insurance contracts. The article is an attempt to indicate the main possibilities of using technological solutions, both in relation to the requirements for insurance distributors and in relation to the technologies that can be used. Selected barriers were also discussed, which in the author's opinion significantly limit the possibility of development of digital insurance distribution channels.

The New Insurance Distribution Regulation in the EU—A Critical Assessment from a Legal and Economic Perspective

The new Insurance Distribution Directive (IDD) regulates insurance distribution more precisely and more comprehensively than the former Insurance Mediation Directive (IMD). For one thing, all insurance distributors will now be encompassed; for another, there will be a substantial increase in the obligations relating to information, advisory services, documentation and business conduct. Considering the effort and expense involved, this raises the question of possible benefits. In this article, the IDD provisions are assessed for the first time with a focus on Europe and from both a legal and an economic perspective. There are regulations that are considered positive from both perspectives (e.g. the Insurance Product Information Document in the non-life segment), others that are viewed rather critically from both perspectives (e.g. product oversight and governance requirements) as well as those that are partly assessed differently (e.g. conduct of business rules). All in all, the IDD appears to be associated with over-regulation in some areas. The legislator should subject these areas to critical scrutiny at the time of the IDD review after 3 years.

PROSPECTS OF DEVELOPMENT OF INSURANCE MEDIATION IN UKRAINE

The purpose of the paper is to explore prospects for the development of insurance mediation in Ukraine in line with the key vectors of the dynamics of the insurance mediation institute in Europe. The objectives of the article are determined by the need to analyse: the new EU Directive No. 97, the provisions of the new draft Law of Ukraine “On Insurance”, and the mechanisms for introducing certification of insurance mediators in Ukraine. Methodology. General scientific and specific research methods were used for the present research. In particular, the method of synthesis and analysis was used in determining the modern approaches to addressing the key trends and prospects for the development of Ukrainian insurance mediation; comparative method was used for a comparative analysis of the specifics of the European and Ukrainian intermediary market; the method of ascending from abstract to specific was used when investigating the mechanisms of certification of insurance mediation. Results. The prospects of development of insurance mediation in Ukraine are investigated in the article. The new EU Directive No 97 and the ways of modernizing the national mediation for the latter are analysed. Mechanisms for improving the Ukrainian institute of mediation according to the European document are identified. The new draft Law of Ukraine “On Insurance” is studied taking into account the modern trends of the insurance mediation development. The necessity of adaptation of the drafted law according to demands of the new Directive is emphasized. The necessity of introduction of certification for insurance mediators is justified; the benefits of implementation of this process in practice are pointed out. Practical implications. The paper identifies the key practical issues and activities on an adaptation of Ukrainian legislation to the European regulation under the European integration processes. First of all, in the legislation of Ukraine, it is necessary to determine the individual distributors (insurance mediators) and the conditions of their registration. At the same time, the provisions on limiting the volume of insurance premiums, a list of insurance risks, regulation of insurance agents and insurance (reinsurance) brokers are the eligible issues for Ukraine nowadays. Notably, the development of mechanisms to control the efficiency, assessing the knowledge, professional training of insurance (reinsurance) mediators, and employees of insurance (reinsurance) companies is highly relevant for Ukraine. Under the condition of legislative consolidation in the insurance market of Ukraine, it is possible to establish a requirement for insurance (reinsurance) mediators, entities, for which the consignment of insurance products is not the main activity, to have an insurance policy of professional liability. Conditionally, the Code of Professional Ethics for Insurance Brokers, acting in Ukraine, is a response to the theses of the Directive on fair, just, professional actions, and their compliance with the client’s interests. The question remains open on regulating the following issues at the legislative level: remuneration of insurance distributors, requirements for the compulsory conclusion of a contract on providing consumers with information on the status of the seller of the insurance product, the type of its remuneration and cross-selling. Value/originality. The paper proves a highly relevant issue for Ukraine – the implementation of the registration process for all categories of insurance mediators and the keeping track on statistics of their activities. It will justify the process of adaptation of Ukrainian legislation to the EU standards. The research results prove the great significance of the adoption of the new Law of Ukraine “On Insurance”, which will allow the introduction of a new procedure for legislative regulation of insurance (reinsurance) mediation in the field of insurance; improve the system of legal support for the development of insurance mediation, its state regulation, monitoring the activities of insurers and insurance mediators. The analysis of the existing draft of the law justifies taking into account the basic recommendations of Directive 2009/138/EU of 2009 that is why it is necessary to align its provisions with the new Directive No. 97. The paper suggests that certification of insurance agents includes the establishment of the level of education, training, professional skills, knowledge, the experience of a professional to confirm compliance with standards, requirements as to the conduct of insurance actions. National certification conditions must be in line with EU laws. It is proved that introduction of certification of insurance agents: increases the authority of professionals in the insurance market, payment for their labour; promotes the development of the insurance market; certifies the professionalism of insurance mediators; raises trust; meets the requirements of international insurance markets and labour markets; allows assessing the quality of mediator training; provides quality services to the insured; protects against fraud by insurance mediators, insurers or insurers.

L’eclatement De La Distribution Des Produits D’assurances Au Maroc Quel Avenir Pour La Présentation Des Opérations D’assurances ?

The primary purpose of this article is to present a legal research on the evolution of the distribution of the insurance sector in Morocco. This aims to provide an overview on the current trend in the retail insurance market and anticipate future challenges faced by the traditional insurance distributors with the current legal system. This article consists of four main parts: 1) stape of legal framework and organization of the Moroccan insurance market; 2) opening stage of the Moroccan insurance market to new players; 3) the consequences and risks of opening of the Moroccan insurance market; and 4) Conclusion.

THE PRINCIPLE OF GOOD FAITH IN EUROPEAN AND NATIONAL INSURANCE LAW

In recent years, insurance markets have become more dynamic due to deregulation of insurance industry, globalization of insurance institutions, increased competition, technological progress, changing customer behavior and regulatory activity, which have greatly intensified in recent years in response to the global financial crisis. In the wake of the global financial crisis, additional measures aimed at enhancing consumer protection were passed in Europe. These include the Insurance Distribution Directive (IDD) and the Markets in Financial Instruments Directive (MiFID II). The IDD contains numerous innovations compared with the Insurance Mediation Directive (IMD Directive 2002/92/EC), including a new conduct requirement for the insurance distributors to „always act honestly, fairly and professionally in accordance with the best interests of the customer“. The main concept behind this rule is that an insured shall only be able to make right decision when he is clearly informed on services offered (and their risks) and distributors can only provide services to clients in accordance with clients’ best interests once they became fully familiar with a kind of a customer that they are dealing with. Most of the EU Member States have a civil law system, with the general clauses of fairness and good faith. EU Member States shall implement the IDD into national law, therefore it is arguable that they should decide whether these standards are mere synonyms of the existing general clauses, or these standards are different from those clauses.

Ostomy appliance prices in Europe

Objective: This article aims to compare market prices (i.e., third-party reimbursement and patient co-payment) of one-piece and two-piece colostomy, ileostomy and ureterostomy appliances in Belgium, Denmark, England and the Netherlands in 2005.Methods: Data were collected through contacts with health authorities, health insurance companies, manufacturers, industry associations and distributors. The price difference between Belgium and another country was expressed as a proportion of the Belgian price.Results: A total of 64 out of the 72 ostomy appliance products considered were cheaper in Belgium. Prices of one-piece colostomy appliances and two-piece ileostomy appliances were consistently lower in Belgium. The highest prices of ostomy appliances were observed in the Netherlands. Sixteen out of 20 products and 21 out of 25 products were more expensive in Denmark and England, respectively, than in Belgium. Colostomy appliances were more expensive in England than in Belgium.Conclusions: Market prices varied substantially between countries, indicating that manufacturers adapt their pricing strategy to the policy environment existing in the ostomy appliance market of each country. Also, there appears to be scope for reducing prices in some countries.

International comparison of orthotic brace prices

This study compared market prices (i.e. third-party reimbursement and patient co-payment) of prefabricated neck, wrist and knee braces in Belgium, France, the Netherlands, Ontario (Canada) and the UK. Data were collected through contacts with health authorities, health insurance funds, manufacturers and distributors. Market prices varied substantially between countries, indicating that manufacturers adapt their price setting strategy to the policy environment and the structure of the brace market of a country. Belgian prices tended to exceed prices in other countries for the selected neck, wrist and knee braces. There seems to be scope for reducing Belgian prices of selected braces.

Cost Effectiveness in Insurance Distribution

This article explores the extent to which the independent and the systems of distribution of property and liability insurance differ in terms of cost effectiveness. Results of a survey of both types of insurance distributors were used to compare the two systems along several cost effectiveness dimensions. The conclusion of the study is that the system indicates greater effectiveness. It exhibits better performance as regards orchestration of activities of insurers and agents, and has achieved greater productivity at the level. The post-war growth of the writers and the systems' in the property and liability insurance industry has caused many to fear that the independent insurance agent may eventually disappear or occupy only a marginal role in the distribution of property and liability insurance. The alarm felt by many has been expressed by Kenney as follows: Unless major corrective measures are undertaken by those in position to do so, the presently waning system of insurance distribution faces complete disintegration in many areas of our business, and a perpetual state of impotence in those areas wherein we continue to operate.2 A major concern has been the ability of the stock and the mutual insurance companies and of the independent agents to compete effectively on the basis of costs with the writers and the companies. For example, Mehr suggested that: By means of central billing, lower commission scales, lower operating costs, these companies [the writers and the insurers] soon had made great inroads in the automobile insurance field. Their means of attack were classic: they offered a lower cost, comparable quality product. Michael Etgar, Ph.D., is Assistant Professor of Operations Analysis in the School of Management of State University of New York at Buffalo. He has contributed to the Journal of Industrial Economics, Journal of Retailing, Journal of Business Administration, and Industrial Organization Reviewv. 'The careful (as distinguished from common) designation for operations like those of State Farm is exclusive agency while CEICO and Factor Mutuals are direct writers. In this article the focus of analysis is on the former. 2 Roger Kenney, Critique of American Agency System, In Wayne Snyder (ed.), Readings in Property and Casualty Insurance (Homewood, Ill.: Irwin, 1959), p. 266.

Service Performance of Insurance Distributors

This article examines whether the independent agents provide better service to their customers than sole representatives of direct writers. Results of a survey of a sample of both types of insurance agents indicate that even though the former apparently excel on some service dimensions, the latter perform as well as or even better than the independent agents on other dimensions. The emergence of the direct writing insurers as major suppliers has been one of the most important changes which has occurred in the property and liability insurance industry in the past two decades. The direct writers, who in the thirties controlled only a small part of the market, today control over thirty percent and in some specific areas of property and liability insurance, e.g. automobile insurance, write well over fifty percent of the premium volume.' Several studies indicate that a major advantage of the direct writers has been their ability to reduce acquisition costs well below industry's averages, largely by paying lower commission rates. According to the Stanford Report, in the 1960-1965 period, the direct writers had an average expense ratio of 21-23 percent as compared to 33-35 percent for all stock companies. The lower expense costs allowed the direct writers to experience lower than average combined ratios and to achieve underwriting profits.2 A frequent argument is that the direct writers could pay lower commission rates because their distributors provide less service to their customers than do the independent agents. This point of view was summed up by Mehr as follows: Independent insurance agents and brokers for example argue that they are needed for creative selling, to give personalized risk management counsel Michael Etgar is Assistant Professor in the School of Management, State University of New York at Buffalo. Dr. Etgar has published not only in The Journal of Risk and Insurance but also in the Journal of Marketing Research, Journal of Industrial Economics and the Journal of Business Research. This paper was submitted for publication in final form in April, 1976. ' See Paul L. Joskow, Cartels, Competition and Regulation in the Property and Liability Insurance Industry, Bell Journal of Economics and Management Science, Vol. 4, 2 (Autumn 1973) 375-427; and, The Future of the Independent Agent prepared by the Stanford Research Institute (known as the Stanford Report) (New York: The National Association of Insurance Agents, 1967) 4. 2 Stanford Report, Table 16. ( 487 ) This content downloaded from 207.46.13.114 on Thu, 26 May 2016 06:05:10 UTC All use subject to http://about.jstor.org/terms 488 The Journal of Risk and Insurance to prospective insureds, to find adequate markets for needed coverages and to aid in loss adjusting.3 The independent agents thus have been depicted as providers of a variety of personalized services tailored to the individual needs of specific insurance buyers. The direct writers on the other hand were perceived as mass merchandisers who sacrifice personalized service for the sake of lower costs and prices. Yet to what extent is such differentiation correct? Do independent agents provide better service than the representatives of the direct writers? So far, no attempts have been made to test the issue empirically; statements made on the subject usually reflect impressions or hypothetical argumentations. The absence of empirical research on this issue reflects the inherent difficulties which face any scholar who attempts to measure the services that insurance agents provide to their customers. While the notion of such services is intuitively patent, expression of the concept through measurable and quantifiable variables is both highly complex and controversial. This article treats the complex issue of measurement and then proceeds to compare the service performance of independent insurance agents and of sole representatives of direct writers. The data used were developed from a survey of insurance distributors of both types. The methodological complexities involved suggest that the study is exploratory and should be so viewed. Its major purpose primarily is to indicate that empirical research on these issues is feasible and to encourage further research and discussion. The hope is that this discussion will help clarify to insurance suppliers, distributors, regulators, and the public, the nature of the services provided by insurance distributors to their customers. Also, hopefully, it will help determine the relative performance of the different types of insurance distributors in providing customer services.