âConsumer organizations have not had the opportunity to digest these additional changes and comment upon them,â says Scott Clark, director of RIMS External Affairs Committee and risk and benefits officer for Miami-Dade County Public Schools. âThe previous revision had reinstated the disclosure requirements for most renewals so the reversal would appear to warrant another comment period.â
The intent of the rule, as it was initially presented, was to bring greater clarity and certainty to the insurance purchase transaction in order to protect consumers. While this objective was a positive first step by the Department; each subsequent revision has diluted the original intent and has resulted in the final rule that falls short of complete and mandatory disclosure, for which RIMS has been a long-time advocate.â
If New York returns to a policy that permits contingent fees on a wide scale basis, smaller consumer entities, in particular, would be subject to a lack of complete transparency of producer compensation as a piece of the insurance purchase transaction. That could give rise to the same conflict-of-interest concerns that the proposed rule was meant to address.
âWhile RIMS will continue its mission of educating consumers, the published rule potentially puts many at a disadvantage when dealing with producers,â says Clark. âRIMS believes the Department should permit another comment period so that affected parties might once again have an opportunity to be heard.â