State Filings Made Easy…Or Not?!

Filings from a Regulator and (Former) Filer’s Perspective Sarah Neil Senior Insurance Analyst Rhode Island Insurance Division

My time in industry… Worked at MetLife from 2007-2013 in Life and Annuity filing unit Responsible for managing drafting process of product forms, in conjunction with Company’s legal, product, distribution, and actuarial departments Drafted and prepared documents to be submitted with filings in 51 jurisdictions, e.g. Statement of Variability, bracketed for variability, added known state variations, etc. Reviewed output from Contract Print to ensure product documents printed as filed

Most Common Objections Reasons Filing fee is incorrect Insurance Bulletin Number 2002- 13 states filers pay retaliatory fee is greater than Rhode Island state filing fee Rhode Island state fee is either $40 for new contract/certificate filing, or $25 charged for each contract to which a filer wants the filing to apply Filers do not include previously approved contract/certificate information Filers request to use forms on a general use basis, but Rhode Island fee is calculated based on the number of contracts to which a filing applies Prior approval dates and SERFF Tracking Numbers must be provided, if applicable

Most Common Objection Reasons Filer inserts language in cover letter asserting right to correct typos without refiling Rhode Island procedure allows filers to request reopening of filing if company has not implemented filed forms If company has implemented and issued forms, a new filing is required with filing fee Filers do not include side-by-side comparison of replaced/amended forms Rhode Island requires red-lined or otherwise tracked changes This allows reviewers to easily see what has changed from last version

Most Common Objection Reasons Filers use incorrect type of insurance (TOI) indicator in SERFF Forms that cross lines of business (LOBs) should be filed using “ML02.000 Multi-Line – Other” NOTE: filers should contact the DBR prior to submission if your filing applies to health lines Omitting a Statement of Variability (SoV) on the Supporting Documentation tab A SoV should be submitted whenever forms contain bracketed material Reviewers look for variable material to match bracketed items and to be clear as to how the language varies

How to Find Filing Guidance DBR has posted filing guidance on its website and in SERFF http://www.dbr.ri.gov/documents/divisions/insurance/life_accide nt_health/INS_LAC_Policy_Form_Filing_Requirements.PDF Updates to prior versions are captured in red for ease of reference Note: Filing Guidance document applicable for Life, Annuities, and Credit Insurance

More to remember… Readability Credit scoring Deemer provisions File & Use, Use & File, Prior Approval Time limits “a” rates What to File

More to Remember… Non-English forms Confidentiality of filings Discretionary clauses Logo changes Price optimization Fraud warning statements

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