Electronic Producer Appointments Guidance

The Department has received a variety of inquiries since the passage of RI Gen. Laws 27-2.4-14.1 and the subsequent issuance of Insurance Bulletin 2024-6. This content was assembled in response to feedback received from industry regarding technical limitations with the “putting up” and “taking down” of certain appointments. We appreciate the feedback received and continued engagement with those persons responsible for tracking/filing appointments.

[2024 R.I. Public Laws Ch. 318 & 319, to be codified as R.I. Gen. Laws §27-2.4-14.1]

 

RI is transitioning from the calendar year Annual Contracted Producer Report (ACPR) appointment filing to real-time electronic appointments. During this initial transition year, there is a distinction to be made between electronic appointment filings and the repealed ACPR filing.

During the month of January 2025, RI will require all active appointments to be filed electronically. 

This means that anyone who is actively licensed and actively still appointed on 01/01/2025 must be appointed electronically with the appointment flowing through NIPR and landing on the national producer database; the Rhode Island fee is $15 per appointment filing.

This also means that anyone who was appointed in 2024 and is no longer appointed on 01/01/2025 must be listed on the ACPR and filed through OptIns by March 1, 2025, with the payment trigger for OptIns still applicable (all producers who earned $100 or more in commission yields a $30 fee).

   

Question: When we process all of the appointments for those producers who were appointed any time in 2024, how will we handle those whose licenses have cancelled/non-renewed during that timeframe?

Answer: We did not contemplate this when we issued the guidance in Bulletin 2024-6. Anyone who is actively licensed and actively still appointed on 01/01/2025 must be appointed electronically with the appointment flowing through NIPR and landing on the national producer database; the Rhode Island fee is $15 per appointment filing. Anyone who was appointed in 2024 and is no longer appointed on 01/01/2025 must be listed on the ACPR and filed through OptIns by March 1, 2025, with the payment trigger for OptIns still applicable (all producers who earned $100 or more in commission yields a $30 fee).

 Question: We have always maintained a list of our Insurance Producers for the purpose of annual tax reporting. Do I understand correctly we are now required to submit appointments for the Individual Insurance Producers?

Answer: Yes, individual insurance producers will now need to be appointed electronically instead of reporting appointments via the ACPR. 

Question: Is Rhode Island requiring business entities to be appointed?

Answer: No. Only individuals are required to be appointed.

Question: For RI's Appointment and Termination implementation, the effective date for the legislation is 1/1/2025. Due to the holiday, is there flexibility to activate this product on 1/2/25 instead?

Answer: Yes. Due to the holiday, it makes sense to activate the product 1/2/2025.

Question: We understand we can terminate for cause and refer for regulatory review, but how do we submit a termination for cause “package” for a statutory termination for cause? In other words, how do we notify the insurance commissioner?

Answer: We developed a new Statutory Termination for Cause reporting form on our website. Detailed information as required by R.I. General Laws 27-2.4-16(a) can be submitted using the form on our website found here https://dbr.ri.gov/node/2776. 

Question: Are appointment renewal payments due on January 31st?

Answer: NIPR generates the invoices based on appointments that are active as of 5 days before January 31st. If the invoice isn’t paid within 60 days, the appointments go down.

Question: Will the appointment fees be invoiced or will NIPR be sweeping our account?

Answer: This depends on your account relationship with NIPR, or any other vendor you use to manage producer appointment filings.

 Question: We are preparing to accept Rhode Island electronic appointments in 2025. We want to accurately depict the appointment expiration date in our internal Company systems. Is 01/31 annually (started 01/31/26) an accurate depiction?

Answer: Yes, RI’s appointments will renew annually with the first electronic appointments renewing 01/31/26.

Question: It looks like the ask is to electronically appoint (via NIPR) anyone still appointed on 01/01/25. Anyone appointed in 2024 and no longer appointed on 01/01/25, will not need to be electronically appointed. We need to include them on the ACPR.

Answer: Yes.

Question: We need to update our internal system to reflect the new RI appointment expiration date. I just want to confirm that 01/31 annually (starting in 2026) is accurate.

Answer: Yes, the appointments will need to be renewed or terminated by 01/31/2026. However, NIPR generates the invoice a few days prior, therefore, even though the actual expiration date is 01/31, the invoice will generate five days in advance and all appointments that are not terminated by that date will appear on the 01/31 appointment renewal invoice.

Question: We utilize Vertafore’s Sircon Producer Manager product to electronically appoint producers.  Is this acceptable to process appointments? 

Answer: As long as the appointment flows through to NIPR everything is good. We understand that NIPR authorizes companies to collect and send that same information to the PDB versus using NIPR directly.  

 Question: Is the carrier required to order a background report before submitting the appointment to the state of Rhode Island for approval?  

Answer: No, we are not requiring that a carrier order a background report before submitting a notice of appointment.