RIS-Page 7
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or
the public). Include the costs of education, training, application fees, examination fees, license fees, new
equipment, supplies, labor, accounting, or recordkeeping.
The actual statewide compliance costs of the proposed rules on the regulated individuals, i.e., those applying for a
license listed under #1, would be nominal, if there are any additional costs associated with the proposed rules at all.
Applicants are already subject to assessment and approval by DIFS.
A. How many and what category of individuals will be affected by the rules?
Any applicant for a license listed under #1 would be affected by the proposed rules; the number of individuals
affected would depend on the number of applications submitted to DIFS. To illustrate an annual estimation of the
number of applications received by DIFS, the following lists applications received for 2021 and 2022:
-Producer applications: 74,039 (2021 total); 35,435 (as of 7/22/2022)
-Adjuster applications: 9,609 (2021 total); 7,388 (as of 7/22/2022)
-Insurance Counselor applications: 212 (2021 total); 136 (as of 7/22/2022)
-Solicitor applications: 232 (2021 total); 147 (as of 7/22/2022)
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
Certain criminal convictions would be identified under the proposed rules as establishing evidence of an applicant’s
lack of good moral character. There would be clear factors established for the Director’s consideration of that
conviction, and the applicant would have notice of the Director’s determination that a conviction evidences a lack of
good moral character and an opportunity to submit a rebutting claim.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
The proposed rules would not result in any cost reductions to businesses, individuals, groups of individuals, or
governmental units.
31. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please
provide both quantitative and qualitative information, as well as your assumptions.
The insurance industry will benefit by the proposed rules’ facilitation of ensuring that the licensees listed in #1 will
perform in a fair, open, and honest manner, while also not excluding those applicants from licensure who are able to
demonstrate rehabilitation since the occurrence of the criminal conviction.
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
The proposed rules are not expected to impact business growth or job creation in Michigan.
33. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their
industrial sector, segment of the public, business size, or geographic location.
Apart from applicants for licensure listed under #1, no individuals or businesses will be disproportionately affected
by the proposed rules as a result of their industrial sector, segment of the public, business size, or geographic
location.
34. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-
benefit analysis of the proposed rules.
DIFS relied on the following sources in compiling the regulatory impact statement:
1) Other states’ law and/or standards regarding licensing criteria and discretion of insurance commissioners/directors
in other states.
2) Internal DIFS’ data systems reporting licensure application totals.
A. How were estimates made, and what were your assumptions? Include internal and external sources, published
reports, information provided by associations or organizations, etc., that demonstrate a need for the proposed
rules.
Estimates regarding compliance of individuals affected by the proposed rules and the proposed rules’ costs were
based on estimates of the current number of applicants for licensure listed under #1 and the effect of the proposed
rules on the existing application process applicable to those applicants. Generally, the proposed rules’ estimated cost
of compliance or implementation by DIFS, other state agencies, local governments, or businesses or groups is based
on the effect of the proposed rules in relation to the existing application process, leading to the conclusion that those
entities or agencies should not have any costs or additional costs associated with the promulgation of the proposed
rules.
MCL 24.245(3)