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Are You Moving to a Real Estate Firm with a Firm E&O Policy? Is Your Firm Changing to a Firm E&O Policy? If So, Your Coverage May Be Affected!

Rice Insurance Services Company, LLC (RISC) administers real estate licensee errors and omissions (E&O) insurance policies issued by Continental Casualty Company in the vast majority of states that require licensees to maintain such coverage.  While policies administered vary from state to state, it is always important to understand how your coverage applies and what professional services it insures.  Real estate E&O policies typically apply to claims made against an insured alleging a negligent act, error, or omission in professional services.  

Most real estate E&O policies, including RISC’s policies, are claims-made-and-reported policies.  Under any policy, critical aspects of coverage include who is an insured and what professional services are insured, which may vary depending on the type of policy. The nature of claims-made-and-reported policies and the differences between insureds and professional services under two common types of insurance policies can create coverage issues for licensees moving from an individual policy to a firm policy.  

Determining Which Policy Applies to a Claim.  Under claims-made-and-reported policies, coverage is typically reviewed under the policy in effect when the claim is first made, regardless of when the underlying professional services occurred.  Changes in the persons or professional services insured from the time of the professional services to the date of the claim could impact coverage.  Four dates are important in determining whether a claim may be covered under a claims-made-and-reported policy:  

1. The Date the Claim is First Made Against the Insured.  Coverage is considered under the policy or extended reporting period (ERP or “tail coverage”) in effect when the claim is first made against the insured, even if a different policy was in effect when the professional services were performed.  If no policy or ERP was in effect when the claim arose, then there is no applicable policy to potentially provide coverage for the claim.  

If you do not renew your RISC policy for any reason, including because you are moving to a firm with a traditional firm policy or because your firm is changing to a traditional firm policy, you may want to consider purchasing an ERP endorsement to apply to claims that arise after your RISC policy’s end date and during the ERP.  Additionally, the professional services giving rise to the claim must have been performed after the retroactive date and before the expiration of the last policy period.  RISC offers ERP endorsements for a specific number of years, which must be purchased within ninety days of your last RISC policy’s end date.  

• The Retroactive Date.  E&O policies typically apply to professional services performed after the policy’s retroactive date, which may be determined differently under different policies.  Under RISC’s policies, the retroactive date is established separately for each insured licensee.  This is the date from which the licensee has continuously maintained uninterrupted E&O coverage.  Any gap in coverage (break between the end of one policy period and the beginning of the next) terminates the previously-established retroactive date. The new retroactive date will be the date the licensee reestablishes coverage.

• The date of the professional services giving rise to the claim.  The professional services giving rise to the claim must have occurred after the retroactive date for the policy to apply.  

• The date the insured reports the claim to the insurance company in writing.  The insured must report the claim in writing during the same policy period in which the claim first arose for the policy to apply.  Insureds should immediately report any claim they receive to their insurance carrier in writing. 

Under RISC’s policies, for a claim to be covered, the insured must have a policy or an ERP in effect on the date the claim is made, have had coverage on the date of the professional services, and have continuously maintained coverage between those two dates.  Further, the claim must be timely reported to the insurance company.

Determining Who and What Professional Services are Insured.  This may vary depending on the type of policy.  Below are brief descriptions of two common types of real estate E&O policies:  

1. Issued to Individual Licensees, such as RISC’s Policies.  
   1. Insureds:  Individual licensees purchase coverage through RISC policies.  Insureds include the licensee and any real estate firm the licensee represents for the firm’s vicarious liability for negligent acts, errors, or omissions in the licensee’s professional services (to the extent coverage would be available to the licensee).  
   1. Professional Services:  Those services included in the applicable state’s licensing law’s definition of broker or salesperson that require a real estate license. RISC’s policies follow the insured individual licensee, regardless of what real estate firm the licensee was associated with at the time of the professional services.

• Issued to Real Estate Firms (“Traditional Firm Policies”).

a.   Insureds:  The firm and the firm’s licensees, but only for the licensees’ professional services performed on behalf of the insured firm.  

b.   Professional Services:  Professional real estate services performed on behalf of the insured firm.  Traditional firm policies are unlikely to insure professional services provided before a licensee was affiliated with the insured firm, even if the claim is made during the traditional firm policy period.  

Because claims often arise years after the subject professional services, traditional firm policies may present coverage issues for licensees who were previously on their own or associated with a different real estate firm.  

Example 1. Changing Real Estate Firms.  Mr. Licensee worked with Happy Property Real Estate from the time he was first licensed on January 1, 2012 to April 30, 2016.  On May 1, 2016, Mr. Licensee left Happy Property Real Estate and began working with Green Acres Realty, where he worked until December 31, 2018.  Mr. Licensee maintained continuous coverage while he was with Happy Property Real Estate and Green Acres Realty by purchasing individual policies through RISC.  Mr. Licensee’s last RISC policy expired January 1, 2019.  On January 1, 2019, Mr. Licensee began working with Big City Real Estate.  Big City Real Estate had coverage through another carrier’s traditional firm policy, which had effective dates of January 1, 2019 to January 1, 2020.  

To help with the following examples, below is a summary of Mr. Licensee’s work and insurance history:

Example 1.A. Changing Firms While Maintaining Continuous Coverage with RISC – Coverage Applies.*  While Mr. Licensee was with Happy Property Real Estate, he worked with a seller in a transaction that closed on December 1, 2014.  On June 1, 2016, just a month after Mr. Licensee left Happy Property Real Estate, the seller made a claim against him.  Mr. Licensee immediately reported the claim to RISC, his insurance carrier at the time the claim arose.  

The claim was first made against Mr. Licensee on June 1, 2016, during the effective dates of his 2016 RISC policy, so that policy applied to the claim.  That policy’s retroactive date was January 1, 2012, because that was the date Mr. Licensee first obtained E&O insurance and he had no gaps in coverage since that time.  The professional services giving rise to the claim occurred on December 1, 2014, after the policy’s retroactive date.  Additionally, Mr. Licensee timely reported the claim to RISC.  

Because RISC’s policies are sold to individual licensees, the fact that Mr. Licensee changed real estate firms between the date of the transaction and the date of the claim does not affect coverage.  Because Mr. Licensee had coverage with RISC when the claim was made, had E&O coverage at the time of the transaction, maintained continuous coverage between those dates, and timely reported the claim, it was covered.  

*For purposes of this example, assume the claim would otherwise be covered under the policy.  

Example 1.B. No RISC ERP Endorsement When Moving to a Firm with a Traditional Firm Policy – No Coverage Applies.  Mr. Licensee chose not to renew coverage through RISC when he moved to Big City Real Estate in 2019, because he believed he was adequately insured under the firm’s policy.

On April 1, 2019, a buyer that Mr. Licensee worked with while he was with Green Acres Realty made a claim against Mr. Licensee relating to a transaction that closed on January 1, 2017.  Big City Real Estate’s traditional firm policy would be the most likely to apply, because it was the policy in effect when the claim arose.  

Unfortunately, Big City Real Estate’s traditional firm policy only covered Mr. Licensee’s professional services performed while he was with Big City Real Estate, so that policy did not provide coverage for this claim involving his professional services with Green Acres Realty.  

Disappointed, Mr. Licensee submitted the claim to RISC, thinking it may be covered because he had a policy with RISC at the time of the transaction.  However, the RISC policy did not apply to the claim, because it expired before the claim was made and there was no ERP in effect. Therefore, Mr. Licensee had no coverage for this claim.

Example 1.C. Purchasing a 3-Year RISC ERP Endorsement When Moving to a Firm with a Traditional Firm Policy – Coverage Applies.*  Instead of assuming he was adequately covered through Big City Real Estate’s traditional firm policy as he did above, Mr. Licensee purchased a three-year ERP endorsement from RISC within ninety days of his policy’s expiration date of January 1, 2019. The endorsement extended the policy’s reporting period by three years to January 1, 2022.  When Mr. Licensee received the buyer’s claim on April 1, 2019, he immediately submitted it to both Big City Real Estate’s insurance carrier and RISC.  Although there was no coverage under Big City Real Estate’s firm policy, there was coverage under Mr. Licensee’s last RISC policy, because the claim arose during the ERP. Additionally, the professional services occurred after the retroactive date and Mr. Licensee timely reported the claim to his insurance company.  

Example 2. Firm Changing to Traditional Firm Policy.  Ms. Agent started her career with Lots of Land Realty on January 1, 2014.  On April 1, 2016, Ms. Agent moved from Lots of Land Realty to Backwoods Real Estate, where she still works.  While with Lots of Land Realty, Ms. Agent maintained uninterrupted insurance through RISC.  When Ms. Agent first moved to Backwoods Real Estate, its licensees also maintained insurance though RISC, so Ms. Agent continued to renew her RISC policy. Shortly before the 2018 RISC policy was set to expire on January 1, 2019, Backwoods Real Estate told its licensees they no longer needed insurance through RISC, because Backwoods Real Estate was going to purchase a traditional firm policy with individual effective dates of January 1, 2019 to January 1, 2020.  Ms. Agent’s last RISC policy expired January 1, 2019, and Backwoods Real Estate continues to maintain a traditional firm E&O policy.

Example 2.A. Changing Firms While Maintaining Continuous Coverage with RISC – Coverage Applies.*  Ms. Agent closed her first listing on March 1, 2014, while she was with Lots of Land Realty and believed everyone was happy with the transaction.  However, on July 5, 2016, after she had moved to Backwoods Real Estate, Ms. Agent was served with a lawsuit alleging she negligently represented her very first client. Ms. Agent immediately submitted the claim to RISC.    

Ms. Agent’s 2016 RISC policy, with effective dates of January 1, 2016 to January 1, 2017 applied to the claim, because it was in effect when the claim arose.  That policy’s retroactive date was January 1, 2014, because that was the first date Ms. Agent obtained E&O coverage and she continuously maintained coverage since that time.  The professional services giving rise to the claim occurred on March 1, 2014, after the policy’s retroactive date.  

Because RISC’s individual policies are sold to individual licensees, the fact that Ms. Agent changed real estate firms between the date of the transaction and the date of the claim does not affect coverage.  Because Ms. Agent had coverage with RISC when the claim was made, had E&O coverage at the time of the transaction, maintained continuous coverage between those dates, and timely reported the claim, it was covered.  

*For purposes of this example, assume the lawsuit arises to a claim that would otherwise be covered under the RISC policy.

Example 2.B. No RISC ERP Endorsement When Firm Changes to Traditional Firm Policy – No Coverage Applies.  On May 1, 2019, Ms. Agent received a demand letter from a client she worked with in February 2015, while she was associated with Lots of Land Realty.  The most likely policy to apply to the claim would be Backwoods Real Estate’s traditional firm policy, because it was the policy in effect at the time the claim was made.  However, that policy did not provide coverage for the claim, because it only applies to professional services performed on behalf of Backwoods Real Estate.  It does not cover claims involving the professional services Ms. Agent rendered while she was associated with Lots of Land Realty.  

Ms. Agent then submitted the claim to RISC, hoping there would be coverage, since she had insurance with RISC at the time of the transaction.  Unfortunately, since there was no RISC policy or ERP in effect when the claim was made, Ms. Agent had no coverage for this claim.

Example 2.C.Purchasing a 3-Year RISC ERP Endorsement When Firm Changes to Traditional Firm Policy – Coverage Applies.* Assume instead Ms. Agent asked her broker at Backwoods Real Estate and the firm’s insurance agent whether the firm’s new traditional firm policy would apply to professional services she provided before she joined that firm.  When she learned it would not, Ms. Agent called RISC to see if there were any options for individual coverage.  She learned that she may continue to renew her individual coverage through RISC as long as she has an active real estate license or that she may purchase an optional ERP endorsement within ninety days of the expiration of her last RISC policy. 

Ms. Agent chose a three-year ERP endorsement, which she purchased within ninety days of the January 1, 2019 expiration of her last RISC policy.  The ERP endorsement extended the policy’s reporting date to January 1, 2022. After receiving the demand letter on May 1, 2019, Ms. Agent immediately submitted it to RISC.  Although there was no coverage under Backwoods Real Estate’s traditional firm policy, there was coverage under Ms. Agent’s last RISC policy, because the claim arose during the ERP, involved professional services performed after the retroactive date, and was timely reported.  

*For purposes of this example, assume the claim would otherwise be covered under the policy. 

Protect Yourself

If you have had individual coverage and are (1) moving to a firm with a traditional firm policy or (2) considering relying on the coverage provided by your firm’s traditional firm policy, talk to your broker or your firm’s insurance agent to determine if the traditional firm policy will cover professional services you performed while you were associated with another real estate firm.  If not, you may want to consider continuing to purchase individual coverage (as long as you have an active real estate license) or purchasing an ERP endorsement.  For more information, feel free to visit RISC’s website, www.risceo.com, or call 1-800-637-7319, ext. 1.  

This information is for illustrative purposes only and is not a contract.  Nothing herein should be construed as legal advice or advice regarding any applicable standard of care.  Rather, this information is intended to provide a general overview of certain products, services, and situations encountered in the course of our business. This information does not amend any E&O policy in any way.  Only the policy can provide actual terms, coverages, amounts, conditions, and exclusions.  The program referenced herein is underwritten by Continental Casualty Company, a CNA insurance company.   This information is for illustrative purposes only and is not a contract.  It is intended to provide a general overview of the products and services offered.  Only the applicable policy can provide the actual terms, coverages, amounts, conditions, and exclusions, which may be subject to change without notice.  In the event of a claim, the nature and extent of coverage is determined based upon the claim’s facts, circumstances, and allegations and application of the relevant policy’s terms, conditions, and exclusions.  The E&O program described herein is only available in certain states.   CNA is a registered trademark of CNA Financial Corporation.  Copyright © 2019 CNA.  All rights reserved.  Prepared by Rice Insurance Services Company, LLC © 2019

Commission Guidance on using Federal Proprietary Purchase Agreements/Contracts

At its June 20, 2019 meeting, the Louisiana Real Estate Commission approved the use of federal proprietary purchase agreements/contracts when required. This decision pertains only to the agencies in the below motion. No additional agencies or third parties may be substituted in place of those mentioned below.

The LREC mandatory contract shall still be used in all cases other than those mentioned in the following motion:

Don’t Let Your Coverage Lapse: The Importance of Maintaining Continuous E&O Coverage

While the policies RISC administers vary from state to state, it is uniformly important to maintain continuous coverage. That means having no gaps, not even one day, between when one policy period ends and the next begins. Having a gap in coverage has multiple ramifications, including:

1. violating the law in states that require real estate licensees to carry E&O insurance, which can result in regulatory penalties and fines and

2. loss of your retroactive date, which may lead to loss of prior acts coverage (loss of coverage for professional services performed before the new policy’s effective date).

RISC’s policies, like most E&O policies, are claims-made-and-reported policies. Four dates are important in determining whether a claim will be covered under a claims-made-and-reported policy:

1. the insured’s retroactive date, which is the date from which the insured has maintained continuous E&O insurance with no gaps;

2. the date of the professional services giving rise to the claim;

3. the date the claim is made; and

4. the date the insured reports the claim to the insurance company.

RISC’s policies’ retroactive dates are established separately for each insured licensee. The retroactive date is the date the licensee first obtained and from which has continuously maintained uninterrupted E&O coverage. Any gap in coverage will terminate the previously-established retroactive date and the new retroactive date will be the date the licensee reestablishes coverage.

Coverage is considered under the policy in effect the date the claim is first made. RISC’s policies only cover claims that relate to professional services provided on or after the retroactive date. That means for a claim to be covered, the insured must have coverage on the date the claim is made, have had coverage on the date of the professional services giving rise to the claim, and have continuously maintained coverage between the date of the professional services and the date of the claim. If there is even one day break in coverage during that time, then the policy’s retroactive date would not go back to the date of the professional services, so there would be no coverage for the claim. Further, the claim must be timely reported to the insurance company.

Example: Ramifications of Failure to Timely Renew Coverage

Ms. Agent first purchased E&O coverage when she obtained her real estate license on May 1, 2015. The effective dates of her 2015 policy were May 1, 2015 to January 1, 2016. Ms. Agent timely renewed coverage in 2016 and 2017, which policies had effective dates of January 1, 2016 to January 1, 2017 and January 1, 2017 to January 1, 2018, respectively. The retroactive date of her 2016 and 2017 policies was May 1, 2015, because that was the first date Ms. Agent obtained E&O coverage and she had maintained it continuously from that time.

Ms. Agent forgot to timely renew her coverage in 2018 and did not pay her premium until April 1, 2018. Therefore, her 2018 policy’s effective dates were April 1, 2018 to January 1, 2019. Due to the gap in coverage from January 1, 2018 to April 1, 2018, Ms. Agent’s new retroactive date was April 1, 2018. Ms. Agent did purchase coverage timely in 2019. Because she renewed coverage timely, there have been no gaps since April 1, 2018. Her retroactive date under the 2019 policy is April 1, 2018 (the date from which she has maintained continuous coverage).

Summary of Ms. Agent’s coverage dates:

Policy Period Retroactive Date

May 1, 2015 – January 1, 2016 May 1, 2015

January 1, 2016 – January 1, 2017 May 1, 2015

January 1, 2017 – January 1, 2018 May 1, 2009

**Gap in coverage from January 1, 2018 to April 1, 2018 –> Loss of previously established retroactive date**

April 1, 2018 – January 1, 2019 April 1, 2018

January 1, 2019 – January 1, 2020 April 1, 2018

Shortly after obtaining her license, Ms. Agent represented a buyer in a real estate transaction that closed August 1, 2015. On February 1, 2019, the client sued Ms. Agent alleging that Ms. Agent’s professional services in the 2015 transaction were negligent and damaged the client. Ms. Agent timely submitted the complaint to her insurance company and asked the company to hire an attorney to represent her in the lawsuit. Ms. Agent was upset to learn the claim is not covered, because the professional services took place before her 2019 policy’s April 1, 2018 retroactive date. For purposes of this example, assume the lawsuit would otherwise be covered under the policy.

In this example, the claim arose on February 1, 2019, so coverage is considered under Ms. Agent’s 2019 policy, which has an individual policy period of January 1, 2019 to January 1, 2020 and a retroactive date of April 1, 2018, because that is the date from which Ms. Agent continuously maintained coverage. The transaction closed on August 1, 2015, which is before the retroactive date. Even though Ms. Agent had E&O coverage when the transaction closed and when the claim arose, the claim is not covered, because the applicable policy does not cover conduct that occurred before its retroactive date. Ms. Agent’s failure to timely renew coverage in 2018 caused her to lose coverage for claims relating to any services provided before April 1, 2018.

In the example above, Ms. Agent had a three-month gap in coverage. However, the result would be the same if the gap was one day. Thus, it is important to timely renew your coverage each year.

Protect Yourself

In light of the serious consequences of even a one-day gap, the carrier may approve requests to backdate the inception date for licensees who fail to timely renew in certain situations. The carrier is not obligated to backdate coverage and reserves the right to deny requests to backdate, so do not rely on it. The best way to protect yourself from situations like Ms. Agent’s is to always renew your coverage and pay your premium on time.

Further, real estate commissions in states that require E&O coverage may issue fines and penalties for a licensee’s failure to timely renew even if coverage is backdated, because backdating does not change the fact that the licensee was without coverage for a period of time.

Your insurance coverage is important. Please take the time to read and understand your policy’s coverage provisions, conditions, and exclusions.

This information is for illustrative purposes only and is not a contract. Nothing herein should be construed as legal advice or advice regarding any applicable standard of care. Rather, this information is intended to provide a general overview of certain products, services, and situations encountered in the course of our business. This information does not amend any E&O policy in any way. Only the policy can provide actual terms, coverages, amounts, conditions, and exclusions. The program referenced herein is underwritten by Continental Casualty Company, a CNA insurance company. This information is for illustrative purposes only and is not a contract. It is intended to provide a general overview of the products and services offered. Only the applicable policy can provide the actual terms, coverages, amounts, conditions, and exclusions, which may be subject to change without notice. In the event of a claim, the nature and extent of coverage is determined based upon the claim’s facts, circumstances, and allegations and application of the relevant policy’s terms, conditions, and exclusions. The E&O program described herein is only available in certain states. CNA is a registered trademark of CNA Financial Corporation. Copyright © 2019 CNA. All rights reserved.

Prepared by Rice Insurance Services Company, LLC © 2019

—We put the Experience and Options in E&O programs—
502-897-1876 / 1-800-637-7319
4211 Norbourne Blvd., Louisville, KY 40207-4048
P.O. Box 6709, Louisville, KY 40206-0709
www.risceo.com

LREC is Moving Into the Digital Age

The continuing evolution and use of technology in our real estate industry has produced dramatic changes in how consumers get their information when considering listing or selling property and how our Louisiana licensees interact with all stakeholders in real estate transactions. Social media has replaced traditional print and other media as the predominant means of consumers and real estate practitioners communicating and getting their “news.”

Regulatory bodies across the country have been playing catch up in this digital age and your LREC is no exception. However, LREC is now on the digital move with current and future mobile-friendly upgrades to help us better serve all of our stakeholders! Some of these efforts include:

• A comprehensive social media plan for LREC to communicate important alerts and news you can use was recently launched. Join us on Facebook to stay in touch!

• A brand new LREC website is now live! This mobile-friendly tool includes a unique “My LREC” portal which will enable you to search license and fee history and education records with ease.

• LREC has partnered with Statereporting.com to streamline and improve vendor course approval and class attendance records. With an account, you will be able to access a complete list of all scheduled live CE courses as well as online courses available. Each licensee who creates an account will get monthly email reminders of remaining CE hours they may need for compliance prior to renewal of their license.

• LREC will be moving toward 100% online capability in the coming months! Whether you need to change your license status, change broker sponsorship, become a new licensee, or complete any of the myriad registrations or transactions available to our licensees you will be able to complete and pay any required fee right from your phone or tablet!

Of course, for any consumer or licensee who still wants to submit paper forms and applications, our LREC staff remains ready and willing to assist!

Steven Hebert, Chairman

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Auto-forward Your LREC Email

The Commission’s primary way to communicate with you is through your LREC-assigned email account. To make it convenient for you to stay up-to-date with our latest news and information, we have a simple auto-forward function that takes just a minute to set up.

Follow these 5 steps to set up your auto-forward function:

1. Login to your LREC-assigned email account through your MyLREC portal
2. Click on “Options” on the sidebar
3. Click on “Auto Forwarding”
4. Add email(s) to Forward Address dialog box
5. Check the box for “After forward save a copy to local mailbox” – this will keep a copy of the email in your LREC-assigned email inbox
6. Click “Save”

You should always login into your LREC assigned email account periodically and ensure your auto-forwarding email(s) is valid and the option “After forward save a copy to local mailbox” is checked.

Note: Due to various email provider’s security/spam policies always check your spam folder for any LREC emails. Move, Mark and or add all LREC emails to your email safe list.

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Audited? Don’t Panic!

Have you received an audit notice? Below are some helpful tips to get you through the process.

1. Read the notice thoroughly

The notice that you received gives instructions on what you must do as a result of being audited. Being audited does not necessarily mean you did something wrong. Our system pulls an audit list based on the date renewed and the date and number of continuing education hours on file. The audit program also looks to make sure the four-hour mandatory course was completed on time.

2. Know your education requirements

Licensees are required to complete 12 hours each year—at least four of which must be the mandatory course. New licensees are subject to the post-licensing education requirement,  which will fulfill a portion of the 12-hour requirement, but you must still complete all mandatory course(s) necessary for your license type.

In 2017 brokers were required to take an additional four-hour mandatory course. Brokers who did not complete the four-hour mandatory, the four-hour broker mandatory, and an additional four hours of elective CE will be included in the audit.

Nobody’s perfect. We all make mistakes. You should check your files to see which courses you completed for the year and what dates are on the education certificates. Make sure the license number on your education certificate matches the number on your license.

3. Verify your certificates using the MyLREC Portal

If you verify that you have the necessary hours with your certificates, check the Commission website using the MyLREC Portal to ensure your records match ours. To do this, visit our website and click “Current Licensees” and select your license type from the sidebar. Once logged in to your MyLREC portal, you will be able to view the information that has been reported to the Commission. If your records don’t match the Commission’s records, you will need to contact the vendor who taught the education course to see why your completed education was not reported.

If all of the hours on your education certificates are reflected in your MyLREC’s “View Education Records” page, make sure the year applied does not show a previous year and that the hours show the correct number and not zero. You may have been required to complete education as part of a previous year’s audit or the hours could have been used as part of a transfer to active status.

If you renewed delinquently and completed your hours prior to renewing, you may need to provide copies of the certificates to our office. Education completed online is reported to the Commission with a completion date of the end of the month. If you completed your online education on January 15, 2018, then renewed January 16, 2018, your education in the MyLREC Portal will show a completion date of January 31, 2018. This may be why you are captured in the audit but are not actually in violation.

4. Don’t panic

There may be a perfectly good reason why you were audited; we just need to get it figured out. If that reason is because you didn’t complete the required number of hours in a timely manner, don’t panic. Gather and review all your records so you have a clear understanding of what you have and what you are missing. Then, make sure you respond to the audit notice. Failure to respond to a Commission request could lead to more serious charges and possible revocation of your license.