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I could be wrong, but not all states recognize that license.
And other states allow fee based analysis with a normal agents license.
Just as with producer licensing is a state-by-state issuance, so is an analyst license. However, I admit that I haven't done a state-by-state search for such licensing. I know it exists in TX and CA for sure.
But he sells policies too. He is the insurance equivalent of a "hybrid firm". At least most state insurance regs that cover fee based agents prohibit double dipping.
And that would be where the language in the engagement letter needs to be specific as to when the duties of the analyst end, and when his duties as an agent would begin.
Once the analysis is done, is there a new recommendation to fit the client's needs where compensation is paid by the insurance company? Some kind of language like this MAY be in the engagement agreement (I would think) and show that the recommendation may be handled by any appropriately licensed individual, and not necessarily by Michael himself.
I'm not a compliance expert, but such language would make sense to me in the engagement agreement. Lots of standards to juggle.