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California Insurance Licensees Must Now Include License Number on Emails

By Robert R. Boeche, Partner, Robert D. Conca, Partner, and Andrew R. Steiger, Associate Attorney of Shustak Reynolds & Partners, P.C. posted on Friday, March 10, 2023.

Starting on January 1, 2023, an update to the California Insurance Code took effect requiring certain insurance license holders to include their license number on each email they send that involves their licensed activities. These changes will impact investment advisers, broker-dealers, and other financial professionals who provide insurance services as part of their overall client offerings.

Before, the rule required license numbers printed on business cards, written price quotations, and print advertisements. Now, every licensed person and agency that appears in an email must also list their license number within the email. The rule applies to all emails “that involve an activity for which a license is required.”[1]

Affected Licenses. The licenses affected are as follows:

  • Property broker-agents (Cal. Ins. Code section 1625)
  • Casualty broker-agents (Cal. Ins. Code section 1625)
  • Life agents (Cal. Ins. Code section 1626)
  • Variable life and variable annuity (Cal. Ins. Code section 1758.1)
  • Accident and health or sickness agents (Cal. Ins. Code section 1626)
  • Personal lines agents (Cal. Ins. Code section 1625.5)
  • Limited lines automobile insurance agents (Cal. Ins. Code section 1625.55)
  • Surplus lines brokers (Cal. Ins. Code section 1765)
  • Independent insurance adjusters (Cal. Ins. Code section 14020)
  • Public insurance adjusters (Cal. Ins. Code section 15006)
  • Life and disability insurance analysts (Cal. Ins. Code sections 1831 through 1849)

Prominent Placement. The license number must be listed in a type size no smaller than the largest of any street address, email address, or telephone number of the licensee. For example, if a 10-point, 11-point, and 12-point are used for such information, the license number must be at least 12-point. Further, the license number must be on the same line, or the line below, the licenses name or title in the email.

Non-Resident Licensees. If a CA licensee is based in another state which already requires insurance-related emails contain license numbers, the licensee must comply with both sets of disclosure rules. Out-of-state licensees can no longer omit their CA license number in emails, even if the license of another state already appears on the email. If the name of any CA insurance license holder appears in an email involving “an activity for which a license is required,” so must their CA insurance license number.

Official Examples. The following are examples provided by the California Insurance Commissioner’s office.

John Doe, Claims Adjuster, CA license #2C00000
Jane Doe, Qualified Manager, CA license #2A00000
Adjuster Insurance Services, CA license #2B00000

If you have any questions, or if you want assistance developing policies and procedures to ensure compliance with the new rule, we are here to help.

Shustak Reynolds & Partners, P.C. focuses its practice on securities and financial services law and complex business disputes.
We represent many investment advisers, IARs, broker-dealers, registered representatives, and businesses.
Attorneys Robert R. Boeche, Robert D. Conca, and Andrew Steiger can be reached in the firm’s San Diego office at (619) 696-9500.

[1] Cal. Ins. Code § 1725.5(c).

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