New Law Requires Licensees to Include Their License Number on Emails
Starting January 1, 2023, a new law will require most types of insurance producers, as well as
independent insurance adjusters, public insurance adjusters, and analysts, to include their license
number on emails. (California Insurance Code section 1725.5, as amended by Senate Bill 1242
[Committee on Insurance, Chapter 424, Statutes of 2022])
This Notice answers some of the most common questions about the new law.
Which types of insurance license does the law apply to? The law applies to individuals and
organizations* licensed as:
• Property broker-agents
• Casualty broker-agents
• Life agents
• Accident and health or sickness agents
• Personal lines agents
• Limited lines automobile insurance agents
• Surplus lines brokers
• Independent insurance adjusters
• Public insurance adjusters
• Life and disability insurance analysts
*Insurance Code section 1628 defines “organization” as meaning any legal entity other than a
natural person. The term “organization” includes corporations, partnerships, Limited Liability
Companies, and unincorporated associations that hold a license.
Does the law apply to non-resident licensees to the same extent as resident licensees?
Yes.
Does the law apply to all emails?
Many but not all. Effective 1/1/23, Insurance Code Section 1725.5(c) will require licensees to
include their “license number in the emails the person sends that involve an activity for which a
license is required.” Pursuant to Insurance Code Section 1725.5(i), this requirement “does not
apply to a person or entity that is not currently required to be licensed by the department or that
is exempted from licensure.”
Under Department regulations, “clerical activities” may be performed without a license;
therefore, no license number would be required in clerical emails.
Title X, Section 2193.1 of the California Code of Regulations, states that “Clerical activities
indirectly related to the solicitation, negotiation, or effecting the sale of insurance which,
pursuant to Insurance Code Section 1635(l), are exempt from licensure, include, but are not
limited to:
(a) Distribution of brochures, business cards, or other general information advertising insurance
agencies or insurers, or insurance products, services or promotions, provided that unlicensed
persons do not analyze, give advice or make recommendations concerning insurance contracts or
potential insurance contract terms to applicants for insurance coverage, potential applications for
insurance coverage, or policyholders.
(b) Preparation of applications for insurance coverage without any contact with applicants, other
than the contact permitted in Section 2193.2(d).
(c) Obtaining underwriting information from third parties, including, but not limited to, the
Department of Motor Vehicles, credit reporting agencies and other insurance companies.
(d) Preparation of binders, certificates, endorsements, identification cards, policies and similar
evidences of insurance, under the supervision of licensees and for the review and signature of
licensees, provided that the unlicensed persons are not signing such documents, either in their
names or in the names of the licensees.
Section 2193.2 of those regulations further states: Clerical activities involving the making of
changes to existing insurance policies or providing indirect insurance marketing and servicing
support which, pursuant to Insurance Code Section 1635(m), are exempt from licensure, include,
but are not limited to:
(a) Dissemination of buyers’ guides for insurance, applications for insurance coverage, insurance
coverage selection forms, or related forms, in response to consumer requests, provided that
unlicensed persons do not analyze, give advice or make recommendations concerning insurance
contracts or potential insurance contract terms to applicants for insurance coverage, potential
applicants for insurance coverage, or policyholders.
(b) Receiving information from applicants for insurance coverage, potential applicants for
insurance coverage, or policyholders, or recording information from applicants for insurance
coverage, potential applicants for insurance coverage, or policyholders to give to licensees for
response, provided that the unlicensed persons do not analyze, give advice or make
recommendations concerning insurance contracts or potential insurance contract terms to
applicants for insurance coverage, potential applicants for insurance coverage, or policyholders.
(c) Scheduling appointments with licensees to discuss insurance, provided that there are no
conversations, or other exchanges of information concerning insurance contracts or potential
insurance contract terms between unlicensed persons and applicants for insurance coverage,
potential applicants for insurance coverage, or policyholders.
(d) Communicating with applicants for insurance coverage, potential applicants for insurance
coverage, or policyholders solely in order to obtain factual information requested by licensees,
provided that unlicensed persons do not analyze, give advice or make recommendations
concerning insurance contracts or potential insurance contract terms to applicants for insurance
coverage, potential applicants for insurance coverage, or policyholders.
(e) Acceptance of insurance premiums for delivery to licensees.
(f) Receiving and recording insureds’ requests for additions or deletions to existing insurance
policies, and preparing endorsement forms for the review and signature of licensees.
(g) Informing insureds factually, in response to their inquiries, as to the category and financial
limits of insurance coverages indicated in policy records, whether coverages are in effect and any
premium balances due, provided that the unlicensed persons are not otherwise explaining,
interpreting, or offering opinions on such coverages or limits, or any other terms of the insurance
contracts.
(h) Answering telephone calls, receiving faxes, opening electronic mail, opening written mail,
processing outgoing mail, doing filing, and engaging in other general secretarial or
administrative functions not otherwise prohibited herein.
(i) Merely translating between licensees and applicant for insurance coverage, potential
applicants for insurance coverage, or policyholders.
The law applies to every email, regardless of where the email is sent from or to, that involves an
activity for which a person must hold one of the above types of license.
Examples of emails that involve an activity for which a person must hold one of the above types
of license include, but are not limited to, emails that involve:
(a) Explanations or interpretations of, and offering of opinions or recommendations on, insurance
coverages, exposures, limits, premiums, rates, deductibles, payment plans, or any other insurance
contract, or potential insurance contract, terms.
(b) Recommending, advising, or urging applicants for insurance coverage, potential applicants
for insurance coverage, or policyholders to buy particular insurance policies or to insure with
particular companies or insurers.
(c) Binding of insurance coverages.
In addition, any other emails constituting the transaction of insurance by an insurance licensee, if
not otherwise exempted from licensure, must include the licensee’s California Department of
Insurance license number, including emails that involve:
• Solicitation Advertise a producer’s insurance business in general, or that advertise a specific
policy offered by the producer;
• Negotiations preliminary to execution Convey a premium quote or mention any other provision
of a current, past, or potential policy;
• Execution of a contract of insurance Request rating or underwriting information from an
insured or prospective insured;
• Transaction of matters subsequent to execution of the contract and arising out of it Request
payment of premium;
• In the case of an independent adjuster or public adjuster, ask a claimant for claim information,
or provide information about a claim or about filing a claim.
Does the license number need to be a minimum size?
Yes. The license number must be in a type size that is no smaller than the largest of any street
address, email address, or telephone number of the licensee. For example, if an email includes a
10-point street address, an 11-point email address, and a 12-point telephone number, then the
license number must be at least 12-point.
Does the license number need to be in a specific location on the email?
Yes. The license number of an individual licensee must appear adjacent to or on the line below
the individual’s name or title. The license number of an organization must appear adjacent to or
on the line below the organization’s name.
If an individual licensee sends an email while working for a licensed agency, and both the
individual’s and the agency’s names appear on the email, which license number should be
included on the email – the individual’s or the agency’s?
Both. Either.
If an individual licensee sends an email while working for two or more licensed agencies, but
only one of the agencies is involved in the transaction to which the email relates, does the license
number of the other agency also need to be included on that email?
Yes. An email must include the license number of every agency whose name appears on an
email.
Can a producer use their National Producer Number (NPN) to satisfy these requirements, instead
of the CDI number?
No. The statute requires the California license number, and that number is essential for
consumers to use to be able to determine license validity and examine producer disciplinary
status, if any, on the CDI website.
Please direct questions to the Producer Licensing Bureau by Live Chat at Agents & Brokers
Overview, email at [email protected], or telephone at (800) 967-9331
State Licenses
Alabama
222062
Alaska
18885
Arizona
1138201
Arkansas
100116374
California
0D73849
Colorado
99115
Connecticut
966203
Delaware
1001981
District of Columbia
0188478
Florida
L013650
Georgia
104073
Hawaii
312343
Idaho
36491
Illinois
100316435
Indiana
31014
Iowa
1001001129
Kansas
956064611-000
Kentucky
629361
Louisiana
274374
Maine
AGN74429
Maryland
185167
Massachusetts
1934597
Michigan
0108929
Minnesota
20500184
Mississippi
12498
Missouri
8015452
Montana
0932218
Nebraska
100182910
Nevada – Resident
100182910
Nevada – Non-Resident
3106821
New Hampshire
0382368
New Jersey
1041231
New Mexico
100013870
New York
PC-821510
New York – Broker
BR-821510
North Carolina
1000008007
North Dakota
20292312
Ohio
1079583
Oklahoma
15338
Oregon
100154821
Pennsylvania
61115
Rhode Island
1081378
South Carolina
147401
South Dakota
C7321
Tennessee
2319803
Texas
2035594
Utah
5800
Vermont
1108
Virginia
115621
Washington
895848
West Virginia
100113555
Wisconsin
1826
Wyoming
198226