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There are three things that define independence, if you ask me:
1. Are you restricted in ANY way as to what products you can write?
2. If you want to move your contracts to another FMO/IMO/upline/whatever right away, can you do so?
3. Do you own your own business (you're listed as the agent on every app, if you leave your upline you retain all of your clients, and you don't have a non-compete)?
If it's yes to all three, then I call that independent no matter how many hands are in the upline.
Good description. That is what I would call independent also.
One more thing I would add that will eliminate a lot of grief is an agent should never sign a "Special Agent" contract or any paper work that will cause his/her commissions to be assigned.