Federation of Regulatory Counsel Journal 

Insurance company executives and agents warned in 1996 that despite a growing number of online shoppers, insurance is not a commodity, and the "freewheeling nature of the Internet [renders it] a difficult marketplace to police."1 They cited the regulatory hurdles and potential for fraud that make the online marketing and sale of insurance more difficult than other products.2 The National Association of Insurance Commissioners (NAIC) at that time had charged its Market Conduct and Consumer Affairs (EX3) Subcommittee with reviewing some of the issues raised by the use of the Internet in the marketing and sale of insurance, including issues regarding: electronic signatures, fund transfers and applications; privacy and confidentiality; policy forms; and producer and company licensing.3 Two years later, the NAIC issued a white paper in 1998 on "The Marketing of Insurance Over the Internet," noting that "Internet technology is clearly no longer considered a fad." 

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