The Maryland Insurance Administration (MIA) is flagging a persistent compliance problem: it keeps finding the same producer-related failures during market conduct examinations. Bulletin 26-28, issued November 10, 2026, calls out a pattern the administration says it “continues to observe” — insurers accepting business from producers who were not properly licensed, not formally appointed, or whose information was not correctly maintained on internal registers. The bulletin states that compliance with these requirements is essential to mitigate the risk of fraudulent activities and safeguard the interests of Maryland policyholders.
No person may sell, solicit, or negotiate insurance in Maryland without holding an active license for the specific line of authority they’re transacting — and, when acting on behalf of an insurer, a formal appointment with that insurer (Maryland Insurance Code § 10-103). Insurers are prohibited from accepting insurance business or paying commissions to individuals or business entities that do not hold an active Maryland license. It falls on the insurer to verify a producer’s current licensing status before allowing them to write or issue policies.
Insurers are required to maintain an internal producer register and update it within 30 days of any new appointment (§ 10-118(b); COMAR 31.03.13.02). Each record must include:
That register must be maintained for as long as the insurer is authorized in Maryland and must be readily available for inspection by the Commissioner on request.
Within 30 days of appointing a producer, the insurer must also provide the appointed producer with written documentation confirming the appointment (COMAR 31.03.13.04). That documentation must contain the specific information required under COMAR 31.03.13.04A.
Compliance doesn’t stop at the point of appointment. Insurers must actively check at least once every 31 days whether any registered producer’s license has been suspended or revoked (COMAR 31.03.13.03(A)). Insurers may rely on a report from the National Insurance Producer Registry (NIPR) for this purpose. If a producer’s license is no longer active or valid, the insurer has 5 business days to terminate the appointment. Within 30 days after the effective date of that termination, the insurer must update its register to reflect the termination — adding the date of termination and an identifier showing whether it was wholly or partly for cause (COMAR 31.03.13.02B(2)).
When an appointment is terminated because the insurer believes the producer has engaged or is engaging in any of the activities set forth in § 10-126, the insurer must notify the Commissioner within 30 days (§ 10-118(e)(1)(ii)). Submissions go through the MIA’s online enforcement portal or by email to the Enforcement Division. The MIA also referenced Bulletin 26-3 on appointment terminations for further guidance.
Failure to maintain an accurate producer register, run the 31-day license checks, or report for-cause terminations is a direct violation of Maryland law. The administration stated that violations may subject the insurer to administrative penalties, including fines and the suspension or revocation of their certificate of authority.
