Among them:

? Improving the distinction between brokers and insurance agents.

? Ensuring that consent and disclosure rules are "sensible and reasonable" and can be achieved.

? Clarifying that the requirement doesn't apply to renewal and residual market business.

IIABA also cited concerns with the deferred portion of the draft, Section B, which the group says was "overkill" because it would apply to "every agent and broker in the country."

The section, which the NAIC said it would address within 90 days, deals with specific disclosure issues regarding a broader class of producers. The section goes back to the NAIC's Executive Task Force on Broker Activities for further development.

"Significant progress was made in the most recent draft. But there are still other issues that need improvement and clarification," Wesley Bissett, IIABA senior vice president of state relations and government affairs, told National Underwriter.

But the president of the Kansas City, Mo.-based NAIC, and Pennsylvania Insurance Commissioner, Diane Koken said the association's plan has been to adopt at least part of the proposal before the end of 2004.

"Our commitment has always been that we would try to get something moved out by the end of the year for the benefit of those states whose legislatures only meet for a limited period of time in the calendar year," said Ms. Koken said during the NAIC's conference call on Wednesday.

"These [requirements] are not engraved in stone. They can be changed later if we identify errors," she said.

In an interview with NU after the conference call, Ms. Koken tried to address IIABA's concerns, making the following points:

? On improving distinctions among different types of producers, she said: "It's very difficult to come up with a bright-line distinction between brokers and agents.?It depended upon how they were functioning. My question would be, 'Why is more disclosure bad?'"

? On ensuring that consent and disclosure requirements are "sensible and reasonable" and can be achieved: "I would like to think that we would never propose anything we don't think is sensible and reasonable. We think it is a balanced approach. We will continue to look at this issue and continue to work on development of additional model laws."

? On whether the requirement applies to renewal and residual-market business: "As far as I am concerned, the language does apply to renewal of a policy. There are other questions about whether you have a policy and you add a car, does it apply to that? My position would be it does not."

Among the requirements contained in the model legislation, brokers would be required to disclose the amount of compensation from the insurer and the method for calculating the compensation, including any contingent compensation.

In cases where the contingent commission is not known, brokers would be required to provide a reasonable estimate of the amount and method for calculating such compensation. Producers who represent companies, and do not receive compensation from customers, would have a duty to disclose that relationship in certain circumstances.

A request for comment from the Council of Insurance Agents & Brokers, a trade association representing the world's largest brokers, was not returned.

A draft of the model legislation is available on the NAIC Web site at www.naic.org.