(C) IIPRC 2010

The IIPRC Today – 36 Strong (C) IIPRC 2010

Overview of Insurance Compact  Innovative vehicle formalizing joint and cooperative action among states  Leveraging regulatory expertise to establish Uniform Standards  Central clearinghouse for prompt review of asset-based insurance products (C) IIPRC 2010

Overview of Insurance Compact Overview of Insurance Compact  Uniform Standards for Individual and Group Life, Annuity, Disability Income and Long-Term Care  Compact filings submitted through the System for Electronic Rate and Form Filing (SERFF)  File one submission under one set of standards for one approval valid in all Compact jurisdictions today. (C) IIPRC 2010

Structure of Insurance Compact  One member from each compacting state  Commission is public entity  Governance: Compact law, Bylaws, Uniform Standards, Rules and Operating Procedures  Authority to receive, review, approve or disapprove product filings (C) IIPRC 2010

Structure of Insurance Compact  Management Committee (3-Tier Composition) –6 Largest Compacting States by Premium –4 States with Greater than 2% Premium –4 States with Less than 2% Premium by Zone  Subcommittees –Product Standards, Rulemaking, Audit, Finance, Technology, and Communications (C) IIPRC 2010

Structure of Insurance Compact  Legislative Committee 8 Members appointed by NCSL and NCOIL 8 Members appointed by NCSL and NCOIL  Consumer Advisory Committee 8 Members representing consumer orgs 8 Members representing consumer orgs  Industry Advisory Committee 8 Members representing companies, 8 Members representing companies, producers and associations producers and associations (C) IIPRC 2010

Registering with the IIPRC  Registration fee must be paid before a filing can be made  Annual Registration Fee of $5,000 Registration Fee Prorated to $2,500 after July 1 st each year  All fees paid via SERFF and EFT  Must authorize IIPRC as payee (C) IIPRC 2010

Tools for Preparing a Product Filing  Visit the Rulemaking Record –Operating Procedure for the Filing and Approval of Product Filings –Uniform Standards  Visit the Industry Resources Page –Filing Information Notices –Member State Filing Fees –IIPRC Type of Insurance (TOI) Link (C) IIPRC 2010

Uniform Standards  Uniform Standards apply over conflicting state laws  The Uniform Standards are listed by Product line and then by TOI  Life, with Life Benefit Features following  Annuities, with the Benefit Features following  Provisions in the Uniform Standards are presented in alpha order (C) IIPRC 2010

Basis of Product Standards  Model Laws if they exist  Laws, regs or Desk Drawer Rules in effect in the majority of states  Best Practices, if state regulation (or interpretation of model laws) is varied or lacking  All requirements are carefully documented to be understood by company and reviewer (C) IIPRC 2010

IIPRC Uniform Standards  IIPRC more comprehensive and straightforward  IIPRC more challenging in some areas –Bar may be raised for some requirements (but Compacting states may adopt those requirements anyway) –Compliance may require system changes or product redesign  IIPRC reflects consensus of all states, which may override single state interpretation of a model law (C) IIPRC 2010

Completing your Submission Requirements  Use the applicable UNIFORM STANDARD to help you.  Check our Filing information Notices (FIN).  Check our General Instructions in SERFF.  Review How to File a Statement of Intent (SOI) in SERFF (C) IIPRC 2010

The Actuarial Memorandum  Most Uniform Standards include a section dedicated solely to the Actuarial Requirements.  Be sure to review the provisions in the Uniform Standard for other submission requirements.  Be sure to include necessary formulae, calculations and examples.  Submit all under Actuarial Memorandum. (C) IIPRC 2010

Statement of Variability and Specifications Page  The requirements for each are in the Additional Submission Requirements section of every applicable Uniform Standard.  Be careful to make these elements consistent with the actuarial memoranda and the forms.  You must attach a detailed listing of all variable items, and certify to it.  Be sure to have the specifications page consistent with the rest of the filing. (C) IIPRC 2010

“Mix and Match”  The Product Filing Rule was amended to eliminate the two-year time frame associated with the “mix and match” filing process.  All Uniform Standards that are adopted to date are eligible for “mix and match” (except CSO); all future uniform standards will specify if eligible for “mix and match”.  Review our General Instructions in SERFF and FIN 9 (2009) for more for detailed information on completing mix and match requirements.  A new SOI Schedule tab was introduced on 12/9/09 and must be used for all filings made thereafter. (C) IIPRC 2010

LETS MAKE THAT FILING NOW - IIPRC in SERFF (C) IIPRC 2010

Double Check Those Submission Requirements!

If the filing does not contain a Mix & Match element, the filer will set the “SOI Schedule Required” field to No. Otherwise, the filer must select the “Filing Type” and attach the Statement of Intent Certification Form. The filer will then add rows as necessary to enter the detailed SOI information.

The filer completes the fields on the SOI schedule, which are taken directly from the SOI document previously in use on IIPRC Mix & Match filings. Once the SOI schedule and the remainder of the filing is complete, it can be submitted to the IIPRC. The included state will receive a message.

Double Check your Filing Fees – the IIPRC & State Fees

Product Review and Approval   Intake review verifies filing fees and includes all submission requirements   Objections are specific and reference requirements found in the various sections of the Uniform Standards.  We use our review checklists and attach to filings. (C) IIPRC 2010

Product Review and Approval  Required to review products in 60 days or less.  Review time depends upon quality of company submission and company response time.  Upon approval, company can use in up to 36 compacting as listed on the product filing. (C) IIPRC 2010

As states join the Compact, you may add them to your Product Filings… ADD A STATE

(C) IIPRC 2010

CONTACT IIPRC  For more information, please contact us at: – –Main number: (202) (C) IIPRC 2010