one - Association of Insurance Compliance Professionals

Hot Topics at the Compact
Compact’s Value-Added Benefits
What’s Up with Compact Legislative Activity
What Uniform Standards to Expect Next
What’s New for Filers
What are Filing Information Notices
Let’s Discuss Mix and Match
What Else is Happening
Questions and Conclusion
Overview of Insurance Compact
Compact filings submitted through the
System for Electronic Rate and Form Filing
File one submission under one set of
standards for one review and one approval
valid in all Compact jurisdictions
Uniform Standards for individual and group
life, annuity, disability income and long-term
Compact’s Value-Added Benefits
• Submit one product filing vs. state-by-state
• Use one set of comprehensive Uniform
Standards to prepare product forms vs. multiple
state variations
• Undergo one filing review vs. many reviews
• Reduce duplicative paperwork, processes and
systems implementations
Compact’s Value-Added Benefits
• Receive one approval on behalf of 41
Compacting States for individual life,
annuities, and disability income
• Receive one approval on behalf of 37
Compacting States for individual LTC
• Compact-approved LTC forms can be
submitted for Partnership via easier
certification /approval process
Compact’s Value-Added Benefits
• Straightforward filing process using SERFF
• Tools and checklists for filers on IIPRC web
• Prompt, easy access to professional team of
product reviewers and actuaries who will
work with companies pre- and post-filing to
answer questions and provide guidance for
• Average approval in 60 review days or less
Compact’s Value-Added Benefits
• Easy to update product filings and add states
to previously-approved filings
• Mix and match accommodates product needs
• Implement and administer standard product
forms across Compacting States
• Streamlined systems programming, testing,
• Simplified producer training
Getting Started with the Compact
• Visit the IIPRC website
– Check out the Company Resources Web
– View IIPRC Tutorials
• Contact IIPRC Office with any questions or to
set up a one-on-one webinar
• Reviewers are available to answer questions
both before and after you make your filing
Getting Started with the Compact
Product Review Team
• Charlie Rapacciuolo is our Product Operations
• David Morris is our Primary Life Reviewer
• Karen Givens is our Primary Annuity Reviewer
• Maureen Perry is our Primary LTC/DI Reviewer
• Jeanne Daharsh is our full-time Actuary
• Alice Fontaine is our part-time Actuary
• Sara Dubsky is our Operations Manager
The IIPRC Today
Compact Legislative Activity
• Arkansas
– Enacted on 4/19
– Effective 90 days after last day of session which will
be 5/17
– Expect to add Arkansas at end of August
• Montana
Enacted last week
Effective on October 1 (open for filing on 10/15)
Opts out of LTC and individual DI
MT constitutional unisex rate requirement still applies
• Florida
– HB383 is non-standard version of the Compact
Compact Legislative Activity
• Connecticut
– SB35 is no longer active
– Several companies visited with DOI staff to
discuss the Compact and Uniform Standards
• New York
– A01983/S02895 introduced in January
– LICONY encouraging DFS to consider Compact
• California
– No legislative activity in 2013
– Compact outreach to DOI in 2012
Uniform Standards
• 88 Uniform Standards adopted to date
– Individual Life
– Individual Annuities
– Individual Long-Term Care
– Individual Disability Income and Business
Overhead Expense
– Employer / Employee Group Term Life
• Combination product filings accepted
Uniform Standards Development
• Group Life Uniform Standards
– Policy/Certificate Standard effective on 1/6/2013
– Standards for Policyholder Application and Policy/Cert
Changes effective on 3/10/2013
– Statement of Insurability Standard will be effective on
– Standards for Waiver of Prem, Accidental Death and
AD&D in comment period (est. eff. 8/2013)
– Product Standards Comm. will recommend
Accelerated Death Benefit Standard to Management
Comm. at April 8th meeting (est. eff. 10/2013)
• Mix and match is allowed
Uniform Standards Development
• Filling in the Gaps on individual standards
– Uniform Standard for Guaranteed Minimum
Death Benefits for Non-variable Annuities
– Chronic illness triggers for Guaranteed Living
– Addressing language in individual disability
income standards re: filing of individual
disability income riders
– Indexed-Linked Crediting Feature Provided
through the Separate Account for Annuities
Uniform Standards Development
• Five-year Review Process
– Rulemaking Rule requires review of Uniform
Standards and Operating Procedures every five years
– Scope of review is whether circumstances or
underlying assumptions have changed since the last
time the rule was adopted, amended or reviewed
– Looking at Uniform Standards adopted before July 1,
2008 which are primarily for the individual life product
– Industry Advisory Committee has provided comments
– PSC expected to make a recommendation by midsummer
Uniform Standards Development
• What is the next new set of Uniform
– Last summer, solicited feedback on
framework for group Annuity Uniform
– Will soon conduct advanced rulemaking to
solicit comments for group Disability Uniform
– Provide your feedback to us and ACLI on next
set of group uniform standards
What’s New for Compact Filers
• Webinar series for filers
– Filing Tips & Tools
– Mix and Match
– Ind. And Group Life Products
– Ind. Annuity Products
– Ind. Long-Term Care Products & Combos
– Ind. Disability Income Products
– Actuarial Tips
• Next series starts in mid-May
What’s New for Compact Filers
• Interactive checklists of the Uniform Standards
(now found on the Rulemaking Record)
• Weekly Tips for Filers (now published on the
Company Resources web page)
• Best Practices Checklist (Company Resources)
• Suggestion Box – send us your suggestions for
improving the process
• Updated Filing Information Notices
What’s New for Compact Filers
• Updated Fee Schedule – simplified and
• Separate fee schedule for companies with
<$50M in asset-based premium volume
• Filing fee based on whether or not
actuarial review is required (costs to
Compact are higher)
• Amended filing fees are ½ of original filing
fee under new schedule
What’s New for Compact Filers
• New SERFF feature enables automatic upload to
Statement of Intent Schedule
• Filers populate preformatted Excel spreadsheet with
SOI information (can import from internal sources)
• Filers use template functionality to upload from file
into SOI Schedule
• Can upload from more than one Excel file and from
file that includes states not included in the filing
• Detailed instructions and preformatted Excel filing
found on Insurance Company Resources web page
Filing Information Notices
• Issued by the Compact Office
• Explains or clarifies steps or requirements
in the process for filing and review
• References applicable Uniform Standards
or Operating Procedures
• When involves interpretation of Uniform
Standard, will consult PSC or Actuarial
Working Group
Mix and Match Filings
• Companies can file an application, policy, rider,
amendment, endorsement with Compact to be used with
state-approved forms
• Review Section 111 of the Product Filing Rule for Mix
and Match procedures
– Company must certify combination of components does not
contain inconsistent, ambiguous, unfair, inequitable or
misleading clauses, or exceptions or conditions that
unreasonably affect the risk purported to be assumed
• Review Filing Information Notice 2009-4 and SERFF
General Instructions
• SOI tutorial on Company Resources web page
Mix and Match Filings
• No timeline for mix and match (two-year timeline
removed in 2009)
• Uniform Standard specifies if it can be used for mix and
match (if silent, then allowed)
– All Life & Annuity Standards (other than CSO
mortality tables)
– Not allowed for LTC products but can mix and match
LTC riders with life and annuity products
– Not allowed for DI products other than can mix and
match DI application with state-approved DI forms
Mix and Match Filings
• Intended to accommodate standards development
and considerations involved with company’s product
development cycle
• IIPRC forms cannot alter or change values or
nonforfeiture requirements in state-approved forms
• Cannot use mix and match to fully comply with
Uniform Standard (e.g. IIPRC form + state form
meets the Uniform Standard)
• Cannot use mix and match to bypass provision
within a Uniform Standard
Mix and Match for Applications
• Uniform standards for applications require the filing to
– “all the sections and questions that may be required to be
completed by an applicant, including additional drop downs,
scripts, questions, questionnaires or supplements that would be
required if the applicant answers questions in a certain way,
such as a “yes” response.
• Application parts, questionnaires and supplements
cannot be mixed and matched to satisfy uniform
• Statement of Intent Schedule can generally describe
forms to be used with Compact-approved application
(except Oregon)
What Else is Happening
• Market Regulation Handbook updated to include
IIPRC and Compact-approved products
• Currently reviewing the scope of “reverse” mix and
match and may issue guidance for states and
• Currently working on guidance for states and
companies re: content v. market regulation
• Increased outreach to member regulators and
• Resources for addressing ongoing growth
• For more information, please contact us at:
[email protected]
Phone: (202) 471-3962
Fax: (816) 460-7476

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