A Michigan producer shares an applicant's health information with a third-party marketing firm without the applicant's authorization. Under Michigan law governing the use and disclosure of insurance information, this conduct is:

Why D is correct

Michigan's insurance privacy framework, M.C.L. 500.501 to 500.535 together with Michigan Administrative Code R 500.551 to R 500.560, restricts the use and disclosure of protected insurance information to permitted purposes or disclosures made with proper authorization. Passing an applicant's health information to a third-party marketing firm serves no permitted underwriting or claims purpose and carries no authorization, so it is an unlawful disclosure. The obligations bind producers as well as insurers, and the Michigan Department of Insurance and Financial Services (DIFS) enforces the framework against both.

Why the other options are wrong

• A) Collecting information during a licensed transaction does not authorize sharing it for third-party marketing purposes.
• B) Privacy protection does not depend on whether a policy was ultimately issued; the applicant's information is protected once gathered.
• C) The disclosure duties apply to producers as well as insurers, so the producer's own conduct can violate the rules.

Memory hook

No authorization, no disclosure.