Introduction

 

The Insurance Marketing Coalition (IMC) is dedicated to maintaining high ethical standards and promoting best practices among its members. This document outlines the expectations for members involved in sales, marketing, and lead generation activities to ensure choice, transparency, consumer protection, and regulatory compliance.

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Standards of Conduct

1. Adherence to Legal Requirements

• IMC members must adhere to all applicable state and federal laws, CMS regulations, TCPA regulations, guidelines that apply to calls, SMS, DNC compliance, FTC and FCC regulations, and carrier guidelines. Members must stay updated on legal changes through continuing education to ensure compliance with new regulations.

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2. Consumer Consent and Communication

• Prior to outreach, IMC members must ensure that consumers provide their prior express consent to be contacted as required by applicable laws. Such consent must be clear and conspicuous and align with the types of outreach that the members and/or its network will be conducting (e.g., prior express consent for outreach using regulated technologies). Consent language should clearly communicate to the consumer what will happen once they submit their information. Deceptive, bait-and-switch, and other misleading advertising is prohibited. IMC members shall not engage in abusive calling practices. If a consumer requests no further contact, an IMC member must immediately add the consumer to its internal Do Not Contact list(s) and shall no longer attempt to contact the consumer unless and until such consumer requests to be contacted again. Revocations should also be communicated upstream, to publisher partners, and downstream to customers so that they also cease contact attempts where permissible by law.

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3. Ethical Conduct and Confidentiality

• IMC members must act ethically, ensuring accuracy and transparency in all marketing and sales practices. They must safeguard and maintain the confidentiality of customer personally identifiable information (PII) and treat all IMC discussions and documents as confidential.

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4. Inclusivity and Professionalism

• IMC members must foster an inclusive and diverse environment within the coalition. They must conduct all activities with a high level of professionalism and represent the coalition positively.

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5. Lead Management and Data Integrity

• IMC members must ensure that any data sharing and handling procedures are secure and compliant with relevant federal and state regulations. IMC members must not sell leads older than 90 days from when consent was obtained unless the consent agreement provides for contact past such time. For contact of leads older than 30 days from when consent was generated, IMC members must use reasonable means to ensure that the telephone number has not been reassigned. All members must use third-party technology to verify online consent records, and should consider taking advantage of 3rd-party technology and data sources to prevent fraudulently created leads and serial litigants from transiting their systems.

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6. Third Party Relationships

• IMC members are responsible for the partners with whom they do business. Prior to doing business with a new publisher or data-provider partner, members are required to vet them, at a minimum, using the Insurance Marketing Coalition Standards Appendix A: Know Your Partner. Contracts with third parties must include stipulations for leads found to be generated from non-compliant and/or unapproved ads or methods. IMC members must have a defined process for ongoing real time monitoring of third party ad compliance and for investigating concerns with questionable third party ads found in the market.

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7. Training and Continuous Learning

• IMC members must provide ongoing training for all agents and employees on legal requirements, ethical standards, and best practices. They must schedule regular training on compliance, document these sessions, and monitor the results to ensure adherence.

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8. Documentation and Record-Keeping

• IMC members must maintain accurate and organized records of coalition activities, documenting decisions, actions, and discussions. They must ensure reasonable access to records for regulatory inspections and internal audits.

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​9. Commitment to Excellence and Collaboration

• IMC members must strive for excellence in all coalition activities and initiatives. They must continuously seek ways to improve processes and outcomes. Members must also promote a culture of collaboration and teamwork, encouraging the sharing of ideas and expertise.

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10. Meeting Protocols and Feedback

• IMC members must adhere to established meeting schedules, and must commit to attending at least 80% of scheduled meetings or assigning a representative in their absence. They must come prepared with relevant information and materials. Members are encouraged to provide constructive feedback to improve coalition processes and dynamics.

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Accountability and Conflict Resolution

 

Anyone may submit a suspected violation of these Standards through a form on the IMC website. Upon being notified of a suspected violation, the IMC Standards Committee must notify the suspect party of the alleged violation. A 3-person subset of the Standards Committee (preferably including some expertise in the types of marketing activities under discussion) will be appointed to investigate the allegations and response in order to make a recommendation to the IMC Board of Directors regarding next steps. The IMC Board of Directors, at their discretion, may judge the violation to be a Substantiated Finding, via Board vote, and assess penalties, as set forth further below under "Substantiated Findings.” The Board must promptly communicate its decision-making back to the Standards Committee.

 

Member Response

• IMC Members agree that upon notice of a Reported Violation, Members will respond within seven (7) calendar days. Response must explain the reason for the violation and planned steps to remediate, if appropriate.

• In all cases, regardless of disposition as Substantiated or not, IMC Members agree to remediate any reported issues within seven (7) calendar days of their written response and to notify the Standards Committee upon completion.

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Substantiated Findings

• If the IMC Board of Directors deems a reported finding to be a Substantiated violation of these Standards, the following penalties may be assessed.

• First Finding: The IMC Member will be notified of the Board’s decision and reminded of the penalties for future violations.

• Second Finding: The IMC member may face up to a three (3) month Suspension of their membership in the IMC.

• Third Finding: After a third finding Substantiated by the IMC Board, a member may be suspended for a period of one (1) year.

• Fourth Finding: After a fourth finding Substantiated by vote of the IMC Board, a member may face permanent expulsion from the organization.

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​Membership Suspension

• Suspended members will be (1) unable to refer to their companies as IMC Members in good-standing or to display the IMC logo, (2) unable to attend official IMC events such as weekly calls or meetings, (3) unable to act in official capacity on the IMC Board or Committees, (4) unable to vote on official IMC business. Suspended members will be listed as such on the IMC website.

• In order to rejoin as a Member in good-standing after a suspension, a member must remediate all violating issues and document such in written form provided to the Standards Committee who will make a recommendation to the IMC Board.

 

Conclusion

The Insurance Marketing Coalition is committed to fostering a culture of integrity, transparency, and consumer respect. By adhering to these Standards of Conduct, members contribute to the Coalition's mission of promoting ethical practices in the insurance marketing industry.

Disclaimer

These are general guidelines. We are an organization that promotes ethical behavior, requires adherence to all federal and state laws and regulations, and does not condone fraudulent behavior. Failure of any member to adhere to the Insurance Marketing Coalition Standards may result in actions up to and including expulsion from the Coalition (Reference: Code of Conduct, Disclaimer).

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