Comments on Model 880 Amendments Draft 3
Summary
Dated July 24, 2023, this letter from NAIC Consumer Representatives addresses the amendments to Model 880 (Unfair Trade Practices Act) in its third draft. The letter commends the inclusion of health insurance lead generators in the prohibition of unfair trade practices and suggests a minor change to the definition of “person” to ensure comprehensive regulatory authority. The representatives advocate for stronger standards to protect consumers from improper marketing practices.