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Insurance Compact
Update AICP Mid-Atlantic Chapter
Education Day 2017
Anne Marie Narcini, CIE, CPCU
Regulatory Consultant - IIPRC
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 May 1, 2017)
• 177 Companies Registered
• 226 Companies Registered in 2016
• 1761 forms for 339 products filed
• 494 products approved
• Mix and Match level to 2016 at 50%
• Average approval time 27 business days*
* excludes company response time to objection letters
58% 29%
3%
10% Life
Annuity
Disability Income
Long-term Care
Breakdown of 2016 Filings
Using the Insurance Compact
Website for Guidance
Instructions on
Associated
Filings
Filing Fee
Schedule
Weekly Tip
Archive
Using the Insurance Compact
Website for Guidance
FINs
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
FIN 2016-1
Using the Insurance Compact
Website for Guidance
FIN 2017-1
Filing Guidance: FIN 2016-1
FIN 2016-1 – Filing Process to Effectuate the 2017 Commissioners Standard Ordinary (CSO) Mortality Table
• The Compact makes updating Compact-approved products for mortality table changes seamless through a variety of options:
• New Specification Pages
• Updated Statement of Variability
• Replacement pages and/or
• Endorsement.
• An updated Actuarial Memorandum is required under each of these options.
Filing Guidance: FIN 2017-1
FIN 2017-1 Process for Revisions to Forms and Supporting Documentation in Compact Filings:
• Issued 3/9, effective 4/1.
• 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
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
Filing Guidance: FIN 2017-1
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 6/26
Five-Year Review of Uniform
Standards – Phase 7 Uniform Standards:
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
• Comment period expired 5/22. You can view proposals on the Docket, under Amendments to Uniform Standards
• Public hearing June 26, 2017
• Consider for adoption at Summer meeting
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
• Plan to expose with Public call late June/Early July
• PSC discussions through Summer into Fall
• Goal is to have recommendations to Management Committee later in Fall
• Consideration of which Group DI standards should also be in iDI
Other Items on PSC Workload
• June 6 – Public meeting to receive comments on request
by Industry Advisory Committee to amend annuity
standards to address interest on death benefits
• You can view the materials on the Event Calendar
• Additional Standards for Incidental and Ancillary Benefits
for Life Insurance Products in drafting stage. Anticipate
exposure for public comment late June/ early July
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
Anne Marie Narcini
(609) 901- 4113
Insurance Compact
(202) 471-3962