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Producer compensation disclosure.

Dear Steve:

Great job reporting on compensation disclosure! Here is a copy of my e-mail back in January to Mr. Gaul in opposition of mandatory disclosure, please feel free to re-print it in whole or part.

See you soon.

David R. Bauer, CIC, CPIA


Capital Bauer

Albany, NY 12212-5094

Dear Mr. Gaul:

I am writing you today in opposition of the proposed producer compensation disclosure (PCD) regulation. Capital Bauer currently discloses compensation on a voluntary basis in our property and casualty business and on a mandatory basis in our employee benefits practice as required by the 5500 form.

I had a unique perspective on PCD during my tenure as chair of the Independent Insurance Agents & Brokers Association of NY (IIABNY). During the years of 2004-5 there was extreme pressure to legislate or regulate PCD due to abuses by public brokers which were addressed appropriately on a case by case basis. The board of IIABNY formulated and currently endorses a voluntary disclosure notice.

My concern with the regulation is not disclosure; it is the frictional cost of disclosure and the unintended consequences of compliance. I understand the reasoning with mandatory disclosure; however, consumers are not requesting compensation information in the course of our business. In fact, most consumers are purely focused on the premium each carrier is quoting.

Please consider allowing the current voluntary disclosure or re-draft the proposed regulation to be less onerous.

Thank you for your time and your service to the insurance consumers of our great state.

David R. Bauer, CIG CPIA


Capital Bauer

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Title Annotation:LETTERS
Author:Bauer, David R.
Publication:Insurance Advocate
Article Type:Letter to the editor
Date:Jun 7, 2010
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