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Licensing Hot States Requirements

GFI has identified specific “Hot States” with unique licensing and appointment requirements that directly impact upline override commission eligibility. Understanding these requirements is essential for compliance and uninterrupted compensation.

These 3 states require both a valid insurance license AND active carrier appointment for a writing agent and an upline to receive override commissions:

  • Florida (FL)
  • Virginia (VA)
  • West Virginia (WV)

In Florida, Virginia, and West Virginia, uplines must have both a license and active appointment with the carrier to receive override commissions from business written in these states.

In these 15 jurisdictions, an upline only needs to hold a valid insurance license (no appointment with the carrier needed) to earn override commissions:

  • Alabama (AL)
  • Georgia (GA)
  • Kentucky (KY)
  • Louisiana (LA)
  • Massachusetts (MA)
  • Mississippi (MS)
  • Montana (MT)
  • New Mexico (NM)
  • North Carolina (NC)
  • Pennsylvania (PA)
  • Puerto Rico (PR)
  • South Carolina (SC)
  • South Dakota (SD)
  • Utah (UT)
  • Wisconsin (WI)

In these states, a valid license is sufficient—no appointment is needed for upline override eligibility.

  1. Licensing Tracker

    • Maintain a state-by-state status tracker for each agent and upline
    • Flag upcoming license expirations at 60/30 days before lapse
    • Flag missing appointments in FL, VA, and WV
  2. Appointment Monitoring

    • Review carrier portals monthly for appointment confirmations
    • Verify appointments are active before writing business in FL, VA, WV
  3. Pre-Business Verification

    • Confirm your license and appointment before writing business
    • The writing date is key—without proper licensing and appointments, you will miss out on commissions and commission overrides
  4. Continuing Education (CE)

    • Monitor CE requirements for each licensed state
    • Agents are responsible for maintaining their insurance licenses, including CE requirements
    • Monitor the NAIC Producer Licensing Model Act for updates
  5. Stay Informed

    • Watch for GFI Compliance updates in the GFI Compliance Newsletter
    • Follow these guidelines for uninterrupted overrides and seamless business growth
  • Disciplinary Actions: Agents must inform GFI of any license suspension, revocation, or disciplinary action
  • Federal Law 18 USC 1033(e)(1)(A) and (B): Prohibits appointing individuals convicted of felonies involving dishonesty or breach of trust without specific written consent from insurance regulatory officials and GFI
  • Solicitation State Rule: Agents must be licensed and appointed in the solicitation state (where the client signs the application)
Requirement TypeStatesUpline Override Eligibility
License + AppointmentFL, VA, WVMust have both license AND active appointment
License OnlyAL, GA, KY, LA, MA, MS, MT, NM, NC, PA, PR, SC, SD, UT, WILicense is sufficient—no appointment needed

Important: If you’re mapping out where agents submit business or ensuring uplines are compliant, this breakdown allows you to align licensing strategy with override eligibility requirements directly.