1. State Filings Made Easy…Or Not?!

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

3. My time in industry…
Worked at MetLife from 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

4. Most Common Objections Reasons
Filing fee is incorrect
Insurance Bulletin Number 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

5. 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

6. 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 “ML 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

7. How to Find Filing Guidance
DBR has posted filing guidance on its website and in SERFF
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

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

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

10. This Photo by Unknown Author is licensed under CC BY-SA