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In a previous article,1 we discussed a number of then-recent appellate decisions regarding important issues pertaining to actions against insurance agents or brokers for failure to procure desired and/or requested insurance coverage. We summarized several decisions that set forth and applied well-settled general propositions of law regarding the duties of an insurance agent or broker to its customer/insured, including the important concepts that “[a]n insurance agent or broker has a common-law duty to obtain requested coverage for a client within a reasonable amount of time or to inform the client of the inability to do so”; “an insurance agent’s (or broker’s) duty to its customer is generally defined by the nature of the customer’s request for coverage”; and “[a]bsent a specific request for coverage not already in a client’s policy or the existence of a special relationship with the client, an insurance agent or broker has no continuing duty to advise, guide or direct a client to obtain additional coverage.” See e.g., Obomsawin v. Bailey, Haskell & LaLonde Agency, 85 AD3d 1566 (4th Dept. 2011); Axis Constr. v. O’Brien Agency, 87 AD3d 1092 (2d Dept. 2011), and cased cited therein.

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