Insurance Compact Update Edward Charbonnier Product Reviewer Echarbonnier@insurancecompact.org

Session Overview Updates on Product Operations Updates on Filing Guidance Updates on Uniform Standards

Overview of Insurance Compact Compact filings submitted through the System for Electronic Rate and Form Filing (SERFF) File one submission under one set of standards for one review and approval valid in all Compact jurisdictions No state opt-outs of individual life or annuity standards

Compacting Jurisdictions – What’s New Connecticut – Newest Compact member Effective July 1, 2017 Effective for filings July 18, 2017 District of Columbia and New York – Pending legislation

The IIPRC Team Karen Schutter – Executive Director Becky McElduff – Assistant Director of Product Operations Sara Dubsky – Senior Operations Manager Ed Charbonnier – Life Reviewer Mindy Bradford – Life Reviewer Karen Givens – Primary Annuity Reviewer Maureen Perry – Primary LTC/DI Reviewer Jeanne Daharsh – Actuary (Life, LTC, DI) Katie Campbell – Actuary (Life & Annuities) Anne Marie Narcini – Regulatory Consultant Aimee Lawson – Product Filing Support Coordinator Lucy Smoucha – Administrative Assistant Karla Coellner – Administrative Assistant

Compact Filing Trends and Stats (as of March 1, 2017) 177 Companies Registered 226 Companies Registered in 2016 917 forms for 151 products filed 305 products approved Mix and Match down to 47% (50% in 2016) Average approval time 28 business days* * excludes company response time to objection letters

Breakdown of 2016 Filings

Using the Insurance Compact Website for Guidance Instructions on Associated Filings Filing Fee Schedule

Using the Insurance Compact Website for Guidance FINs Weekly Tip Archive

Using the Insurance Compact Website for Guidance Multiple filters by year and categories Search by terms, with or without filters Can view complete tip and date published Updated monthly

Using the Insurance Compact Website for Guidance Filing Information Notices Find on www.insurancecompact.org Home page > Filing Information Notices Insurer Resources page > Reference Materials block > Filing Information Notices

Using the Insurance Compact Website for Guidance

Filing Guidance FIN 2016-1 – Filing Process to Effectuate the 2017 Commissioners Standard Ordinary (CSO) Mortality Table FIN 2016-2 – Group Disability Income Insurance Filings and Filing Group Disability Income Products with Group Term Life Products FIN 2016-3 – Guaranteed Living Benefit Increases for Qualifying Events FIN 2017-1 – Process for Revisions to Forms and Supporting Documentation in Compact Filings Weekly Tips – Review for updated information on filing tips, useful information, upcoming events

Filing Guidance: FIN 2017-1 FIN 2017-1 Process for Revisions to Forms and Supporting Documentation in Compact Filings: Issued March 9th. Effective April 1st. Adding states, updating SOI and translation certifications still do not require Compact review fee Not changing what we have been applying. Rather, reducing our process/procedure to writing to provide consistency, uniformity and predictability for filers New Filing Type – Supporting Documentation Update

Filing Guidance: FIN 2017-1 FIN 2017-1 Process for Revisions to Forms and Supporting Documentation in Compact Filings: Pending Filings: Objections not issued – free to revise forms or submit new forms. Be mindful of fees. Objections issued – revisions allowed if in response to an objection. Otherwise, revisions require amended filing fee. New forms not permitted – submit as a new filing.

Filing Guidance: FIN 2017-1 FIN 2017-1 Process for Revisions to Forms and Supporting Documentation in Compact Filings: “Closed-Approved” Filings: Closed < 90 days and forms not issued or marketed: Revisions allowed by sending a Note to Reviewer requesting the filing be re-opened. Include the reason for the request and describe the revisions. Once re-opened, submit revisions in an amendment and pay amended filing fee. Closed > 90 days or forms have been issued: Submit revisions in a new filing New filing type – Supporting Documentation Update

Filing Guidance: FIN 2017-1 FIN 2017-1 Process for Revisions to Forms and Supporting Documentation in Compact Filings: “Closed-Withdrawn” or “Closed-Disapproved” Filings – always requires new filing In-Force Products – call Compact office to discuss individual situation in order to best advise how to proceed

Filing Guidance: FIN 2017-1 Appendix A – Flow Chart Appendix B – State Fees for new filing type FAQ posted to Insurer Resources page of Insurance Compact website A Series of Weekly Tips issued in March & April provide in-depth detail on FIN 2017-1

Filing Guidance: FIN 2017-1 Supporting Documentation Update Filing Type: Update material originally submitted on the Supporting Documentation tab Select TOI and sub-TOI of original filing, then SDU Filing Type Associate to filing(s) being updated Provide detailed description of update in Filing Description on General Information tab NO FORMS PERMITTED ON FORM SCHEDULE TAB

Filing Guidance: FIN 2017-1 Supporting Documentation Update Filing Type Cont’d: New Submission Requirements Leave Form Schedule Tab empty and confirm

Filing Guidance: FIN 2017-1 Supporting Documentation Update Filing Type Cont’d: Leave Statement of Intent empty and confirm. SOI updates should be made in original filing.

Filing Guidance: FIN 2017-1 Supporting Documentation Update Filing Type, Cont’d Submit Compact Product Filing Fee for new filing depending on whether uniform standards for item being updated require actuarial review. Same fee amounts as new product filing. Submit applicable state filing fees per Appendix B. State fees apply per submission only. Provide complete Statement of Variability including updated/new items Provide new certification of variability If making non-variable item variable, include approved form with complete, revised bracketing on the Supporting Documentation tab—not the Form Schedule

Uniform Standards Update Product Standards Committee (PSC) 20 Regulators from Member States Develop and amend Uniform Standards Input from industry, consumer representatives, legislators, other regulators Uniform Standards approved by a 2/3 super majority of Member States

New Uniform Standards Group Disability Income Insurance Suite of Uniform Standards covering Policy Standards, Enrollment Forms, Statement of Insurability Forms, Rate Filings and Rate Changes Policyholder application for all group products that can be filed with the Compact Mix and Match: Only in combination with state-approved group life or annuity contracts if the DI rider and all DI components are filed with the Compact Standards available for filings effective 6/8/2016 FIN 2016-2 addresses filing requirements for Group DI Standards

Five-Year Review of Uniform Standards Adopted standards reviewed on a rolling five-year basis Did circumstances or underlying assumptions change since the last time the rule was amended? Substantive changes, clarification, conforming amendments, technical corrections PSC provides recommendations to Management Committee, then exposed for public comment

Five-Year Review of Uniform Standards – Phase 6 Includes all Individual LTC Standards Substantive changes include: Dollar-for-dollar benefit riders in rate review Update Uniform Standards to most include recent changes to LTC Model Regulation Management Committee will consider adoption of revisions at a joint call of the Management Committee and Commission on June 26th

Five-Year Review of Uniform Standards – Phase 7 Graded Death Benefits – Whole Life Longevity Annuities Private Placement – Deferred Variable Annuities Private Placement – Variable Adjustable Life Change of Insurance Benefit – Life Overloan Protection Benefit – Life Written comments on recommendations due 5/22 You can view proposals on the Docket, under Amendments to Uniform Standards

Five-Year Review of Uniform Standards – Phase 8 Includes all Individual Disability Income Uniform Standards Comment period ended 3/31 Compact office preparing a report summarizing comments and proposed revisions for PSC consideration Goal is to have recommendations to Management Committee by fall

Other Items on PSC Workload Incidental Benefits for Life Insurance Products Uniform Standards for review and comment Post a request by IAC to amend annuity standards to allow for the addition of a interest on death benefits provision

Uniform Standards: How You Can Help Follow the PSC meetings; If a product doesn’t have standards, let us know Consider best practices that can be incorporated into new standards Offer to assist with drafting or product education Balance consumer protections and Industry initiatives PSC Call Summaries on About the IIPRC page

Five-Year Review Information Amended Standards under review are found on the Docket

Five-Year Review Information Adopted Standards contain Standard History, including comments and redlined proposal(s)

Link to Redlined Proposed Amendments for Five-Year Review Original Standards Other Amendments

Questions? Contact Edward Charbonnier: (617) 944-0926 Echarbonnier@insurancecompact.org (617) 944-0926 Insurance Compact: Comments@insurancecompact.org (202) 471-3962