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A national insurer plans to sell Massachusetts personal auto policies directly to consumers by telephone and website, with no walk-in office and no individual producer signing each application. Under Massachusetts DOI direct-response rules, what licensure is required?

ANo licensure is needed because no individual producer signs the application, and the insurer's Certificate of Authority alone satisfies all Massachusetts producer-licensing requirements for every employee who contacts applicants
The insurer must hold a Certificate of Authority, and each individual telephone representative who solicits and negotiates Massachusetts policies must hold a Massachusetts producer license
COnly the customer service supervisor in the home office needs licensure
DA separate direct-response license that exempts the insurer from c. 175 §162H

Why this is the answer

Massachusetts producer licensing under c. 175 §162H is medium-neutral. A direct-response insurer must hold a Certificate of Authority from the DOI to transact insurance in the Commonwealth, and each individual representative who solicits, negotiates, or sells personal auto coverage to Massachusetts residents — whether by phone, mail, website chat, or electronic application — must hold a Massachusetts producer license. There is no separate 'direct-response' licensing exemption that waives §162H. Customer service representatives who only answer billing or policy-status questions and do not solicit or negotiate coverage are not selling insurance and do not need a producer license.

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