Is this a CMS Violation.

situation:

T65 is cold called. They absolutely did not send in a reply card or give their name/number to anyone about Medicare. Started out talked about supps, work their way to MAPD plan. No scope of appt obtained, the entire presentation was given over the phone and then an app was mailed to the T65 completely filled out, she only had to sign it and mail it in.

Agent is non-resident calling from out of state. Appointed with one MAPD and one med supp carrier only (so presumably not a captive if selling with other carriers).

Is this a CMS violation? I believe it is a carrier violation,
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