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Insurance Compact

Update AICP Mid-Atlantic Chapter

Education Day 2017

Anne Marie Narcini, CIE, CPCU

Regulatory Consultant - IIPRC

anarcini@insurancecompact.org

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

anarcini@insurancecompact.org

(609) 901- 4113

Insurance Compact

Comments@insurancecompact.org

(202) 471-3962