As for how the states succeeded in maintaining some degree of uniformity, Mr. O'Hern said “about as well as any standardized law or uniform law has succeeded.”

Among the states, he said the Oregon disclosure law comes closest to the National Association of Insurance Commissioners' model statute. Oregon requires not only the dollar amount of compensation as opposed to just its method of calculation, but also documented acknowledgement by the policyholder, Mr. O'Hern said.

Oregon is also unique in that the law is applied across the board rather than to a certain class of business, he added. “A lot of states have required them just of brokers, whereas Oregon uses the term 'insurance producer.'”

Other states require less detail.

“Compliance with these types of regulations requires extreme vigilance because legislation is just beginning to emerge,” said Mr. O'Hern. “Producers don't want to be caught unaware as states impose compensation regulations individually and on their own schedule.”

States such as New York and Utah have requirements similar to Oregon that were imposed prior to the 2004 investigations.

Despite the fact that the NAIC and the National Conference of Insurance Legislators have issued recommendations, each state has imposed unique requirements, so producers need to be aware of the regulations of every state in which they do business, Mr. O'Hern said.

Mr. O'Hern developed the guidelines in response to the needs of the many producers GE Insurance Solutions utilizes in its programs business segment.

GE said its guidelines also apply to any brokers who receive commissions and also charge a producer fee.