OR | On August 14, 2020, the Oregon Insurance Division sent the following letter to active insurance licensees:
To our active insurance licensees,
It’s been about four months since we had to close our physical offices to the public as a result of the Covid-19 outbreak and it appears that will continue through at least October 31, 2020. Although most of the staff is working from home, we are able to receive and return phone calls and we encourage individuals to use email to contact us at email@example.com. We hope though that this update will provide answers to common questions and help prevent common mistakes we are encountering on applications.
Remote proctored exams now available through PSI
On July 15th, PSI began offering online, remote-proctored exams for applicants for Oregon insurance licensees. Due to the pandemic, many of our test sites were forced to close temporarily. We were reduced to one operational site for a short period of time. This year, we were planning to put our test contract out for bid and we wanted the successful bidder to be able to offer remote proctored testing so that we can offer better options for those in some of the remote parts of Oregon. However, due to the pandemic and closing testing centers, we entered into a contract extension with PSI, our current testing vendor, that required them to begin offering this remote exam option now. While the test sites have re-opened, most are at reduced capacity to accommodate social distancing. So this online option not only assists those that are more distant from one of the test centers but also can be a viable option for those that are concerned about limiting possible exposure to Covid-19. If you take your exam remotely, you do not have to go to a PSI test site to have your fingerprints done. See the option of Fieldprint below.
Additional fingerprinting options through Fieldprint
In July, we began offering applicants the ability to use Fieldprint locations for fingerprinting. Because fingerprinting had previously only been allowed at PSI testing centers, when the test centers closed, it also impacted applicants’ ability to meet the fingerprinted background check requirements. In addition, we knew we needed to expand our fingerprinting options to take better advantage of the benefits offered by remote online-proctored testing. As a result, we entered into a contract with Fieldprint that opened up around 50 additional locations for applicants to be fingerprinted. PSI test centers continue to offer this service as well. When using Fieldprint to be printed in connection with an Oregon insurance license application, be sure to use the code using the code FPORDeptConsumerBusServDAS when you sign up.
New applications are being processed as normal, but may take a little longer
With remote proctored testing and additional fingerprinting options, it seemed that we addressed the pain points that applicants were sharing and things seemed to be back on track for those seeking a new license or needing to transfer their license to Oregon. However, we have seen a large increase in the number of new applications. At the same time, we celebrated the well-deserved retirement of long-time licensing team member, Lee Ann March, and wished well to another team member that was selected for a job rotation. We are in the process of recruiting replacements for these team members and will have some decrease in productivity until we can hire and train replacements. The combination of the increased volume and being short-staffed means that new applications may take longer for us to process than previously experienced. Right now, applications are taking between two and three weeks to process. We ask that you wait at least two weeks before contacting the office regarding your application. The increased volume of calls to ask about the status of applications is reducing the time we have to work on applications.
Renewal applications are being processed as normal
The recent loss of staff members has not had as noticeable of an effect on the processing of our renewal applications. Applications that require a manual touch are still being reviewed within a matter of days. However, we receive a lot of renewal applications that require manual review. Many of them cannot be approved at the first review and require that we reach out to the licensee for additional information, which delays our ability to approve the renewal and may result in the individual’s renewal not being approved prior to the expiration of the license.
24 hours of continuing education still required to renew producer license
Oregon requires twenty-four (24) hours of continuing education to renew the producer license consisting of three (3) hours of Oregon law, three (3) hours of ethics and eighteen (18) hours of general courses. If you take extra hours of Oregon law or ethics, the hours will apply toward the hours of general courses. The system will only apply a course number once in the reporting period because you cannot take the same course twice in the same reporting period. These requirements were not changed in light of the pandemic. Oregon does not require in-person continuing education. There are a variety of providers licensed who provide the education online in a manner that doesn’t require any physical contact and can be taken from any location. Others have elected methods that do require a proctor to certify that the examination for the continuing education was taken without assistance from written materials or any person. While that could be done remotely with the correct processes and procedures, not all companies offering other methods of education are set up for this kind of remote proctoring.
Select an education provider that can meet your education timing requirements
For those who need to complete continuing education to renew their licenses, we strongly encourage that you check with the education provider that they can meet your education timing requirements before you select your provider. We have not extended deadlines for completing continuing education as there are methods currently in place to obtain the education while complying with recommendations to reduce the spread of the virus.
Complete continuing education early as there are time limitations
We also highly recommend that individuals complete their continuing education requirements at least a month before renewal. There are rules that prohibit a person from taking more than eight (8) hours of CE each day. Therefore, you will need at least three (3) days to complete your CE, even if you are taking the maximum number of hours each day. In addition, education providers have fifteen (15) days to upload completion information after you complete the course. You will not be permitted to submit your renewal request until the system shows you have completed the required education, which often only will happen in an overnight process after the course information is uploaded by the course provider. So even if the course provider uploads the information today, you may still be blocked from submitting your renewal until tomorrow. Also, our staff still may need to manually review your renewal application before it can be approved, especially if you answered yes to any of the disclosure questions or hold a certain line of authority, such as a variable line. So it’s possible that for it take three weeks for you to complete the education, the course provider upload the information, the system to recognize that it’s complete, you to submit your renewal request, and our team here to review it.
As a result, it’s very important to complete your continuing education well before your expiration date and to submit your renewal early in the 90 day renewal period. Each month we have a few individuals who contact us because they were unable to complete their education timely asking for us to give them more time or waive the $45 late fee. Our ability to do that is very limited under ORS 744.073, which allows us to make exceptions for those unable to comply with the requirements as a result of military service or something like long-term medical disability. Issues such as technical difficulties with your computer while completing the education, a delay of less than 15 days by the education company in submitting the completion certificates, or a cold in days prior to renewal that prevented a person from completing the course are not sufficient for an extension. Therefore, we highly recommend that you complete your continuing education early.
Make sure your contact information is up-to-date
It’s very important that your contact information be up-to-date in case we need to contact you. This happens a lot when we are processing applications and find that we need additional information. If you change your contact information, you are supposed to update it within 30 days.
To change your contact information, go to www.nipr.com. Find the “Licensing Center” and click on the “Change Contact Information.” Follow the rest of the on-screen prompts. If you have any difficulty navigating through the screens, please contact the NIPR at (855) 674-6477.
You cannot change your contact information through the renewal process. You will need to submit that as a separate change on a different day than you submit the renewal.
You are responsible for the accuracy and timeliness of the information
The system will allow an authorized submitter to complete an application or changes for the applicant, but the licensee is still ultimately responsible for the information that is submitted. So make sure that you check the information for accuracy before it is submitted. Although an authorized submitter is permitted to respond to our questions about your application or a requested change, the licensee is ultimately responsible for ensuring that the application is complete and accurate and that responses to our questions are provided timely. If you fail to respond to a request for additional information, we may declare an initial application or amendment as abandoned. Because the law provides that a license continues if the renewal fee is paid even if the application is incomplete, if you fail to respond to requests to provide information to complete a renewal application, we will submit a request to enforcement to revoke the license. You will have to report any revocation to any other jurisdiction in which you hold an insurance license. So it’s very important that you respond to any emails that you receive from the division requesting information to complete your application.
Other things that delay approval of individual renewals or license applications
There are several common mistakes on applications that delay our ability to process your application. For instance, if you answer yes to a disclosure question on the application, make sure that you upload documents to the warehouse addressing the yes answer. If you do not provide a complete explanation and supporting documents, such as court records or a copy of the administrative order, we will not be able to process the application as submitted. We have to reach out to obtain this information from the applicant and the application will be delayed in processing.
If you are applying for a variable line of authority, make sure that you include your CRD number and make sure that your CRD records shows that you are approved to sell securities or act as an investment advisor in Oregon. We frequently receive applications for the variable line of authority that we cannot process or approve because we cannot verify that the person is approved in Oregon on the CRD.
People are trying to add a line of authority at the time of renewal to avoid the application fee associated with adding a line of authority. This is not allowed. It must be done by separate application. To add a line of authority, go to www.nipr.com. Find the “Licensing Center” and click on the “Add a Line of Authority.” Click on the appropriate License Type. Click on the “Go to the Online Application” button then follow the rest of the on-screen prompts. If you have any difficulty navigating through the screens, please contact the NIPR at (855) 674-6477. Follow the rest of the on-screen prompts. If you have any difficulty navigating through the screens, please contact the NIPR at (855) 674-6477.
People are trying to renew, but don’t want to renew all their lines of authority. You must renew all lines of authority you have; partial renewals are not allowed. If you don’t want to renew a particular line of authority, you will need to surrender it before you submit the renewal. The form to surrender a line of authority is at https://dfr.oregon.gov/business/licensing/insurance/Documents/5054.pdf.
Common mistakes in submitting business entity renewals or license applications
For business entities, we often receive applications only to find that the company does not have designed responsible licensed producer (DRLP) or that the DRLP doesn’t have an active insurance license in Oregon with the same lines of authority. Another common issue is that the company doesn’t have any affiliated individuals that are licensed in Oregon. As a result, we cannot approve the application and must contact the company to obtain this information. This significantly delays the processing of applications.
The form to add or remove an affiliation or DRLP is available at https://dfr.oregon.gov/business/licensing/insurance/Documents/2139.pdf.