2. Insurance Compact Update
Edward Charbonnier
Product Reviewer

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

4. 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

6. 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

7. 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

8. 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

9. Breakdown of 2016 Filings

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

11. Using the Insurance Compact Website for Guidance
FINs
Weekly Tip Archive

12. 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

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

14. Using the Insurance Compact Website for Guidance

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

16. Filing Guidance: FIN
FIN 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

17. Filing Guidance: FIN
FIN 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.

18. Filing Guidance: FIN
FIN 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

19. Filing Guidance: FIN
FIN 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

20. 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

21. Filing Guidance: FIN
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

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

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

24. Filing Guidance: FIN
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

25. 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

26. 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 addresses filing requirements for Group DI Standards

27. 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

28. 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

29. 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

30. 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

31. 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

32. 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

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

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

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

36. Questions? Contact Edward Charbonnier: (617) 944-0926
(617)
Insurance Compact:
(202)