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L&HCaliforniaeasy

A California life-only licensed producer wants to start selling variable universal life policies. What additional license, if any, must the producer obtain?

A variable contract qualification under Ins. Code § 1758.1, requiring a FINRA Series 6 or 7 securities registration
BNo additional license is needed, because a California life-only license by itself authorizes the sale of variable products
CA California Real Estate Broker license, because separate-account sub-accounts are pooled real-property investments
DA property and casualty broker-agent license issued by the Department of Insurance to transact variable coverage

Why this is the answer

California treats variable life and variable annuities as both insurance AND securities because the cash value is invested in separate-account sub-accounts whose value fluctuates with market performance. Ins. Code § 1758.1 explicitly conditions a producer's authority to transact variable contracts on holding a variable contract qualification with the CDI AND being registered as a securities broker-dealer agent under the Corporate Securities Law of 1968 (Fin. Code § 25200 et seq.) — in practice a FINRA Series 6 (packaged products) or Series 7 (general securities) license. A life-only license alone is insufficient. The other distractors are nonsense: a real-estate broker license does not authorize securities sales, and a P&C license has no nexus with variable contracts.

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