October 05, 2011


Independent Insurance Agent

January 14, 2000

Mr. Sherwin P. Simmons
Commission on Multidisciplinary Practice
Center for Professional Responsibility
American Bar Association
541 North Fairbanks Court
Chicago, IL 60611-3314

Dear Mr. Simmons:

The Independent Insurance Agents Association of New York represents nearly 1,700 businesses throughout the state who specialize in satisfying the insurance needs of their clients.  Most of our members are less than 15 employees and frequently work in close contact with CPA's, attorneys, and real estate  professionals in an effort to provide professional services to their clients.  It simply makes sense that private business professionals who choose to combine their practices in the best service to their clients should be able to do so.

Our industry is no stranger to consolidations and combinations of associated businesses.  The recent passage of S900, The Financial Services Modernization Act, has created an entirely new environment for the delivery and underwriting of all financial services.  I hope that you recognize that other professions have the same high standards for ethics and continuing education as attorneys, and therefore, there is no reason as long as the individuals practicing within a field are properly licensed and certified by their sanctioning bodies, that there should not be multidisciplinary practices.

It is my hope that you do the right thing and provide the environment for mutidisciplinary practices to flourish.


Richard A. Poppa, CEA, AAI
Chief Executive Officers