The formerly prevalent view that a party to an insurance contract is bound by his representations in all respects has been modified. Today, an increasing variety of acts or declarations by the insurance agent will shift the liability to the insurance company. The company is held to be estopped from pleading the insured's contract violations which were due to the actions of the insurer's agents. Because the general rules of agency apply to insurance agents, the company is responsible for those acts of a licensed agent performed within the scope of his authority.Thus the two problem areas in determining the extent of the principal's (i.e., insurer's) liability are the identity of the agent and the scope of authority, real or apparent, for different agents.
Kenneth Montlack, Insurance Companies' Liability for the Acts of Agents, 14 Clev.-Marshall L. Rev. 580 (1965)