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Insurance Compact

Update AICP Mid-Atlantic Chapter

Education Day 2017

Anne Marie Narcini, CIE, CPCU

Regulatory Consultant - IIPRC

[email protected]

mailto:[email protected]

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



FINs

Filing Information Notices

• Find on www.insurancecompact.org

• Home page > Filing Information Notices

• Insurer Resources page > Reference Materials block >

Filing Information Notices



http://www.insurancecompact.org/

FIN 2016-1



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.


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


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.


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


• 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


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


Supporting Documentation Update Filing Type Cont’d:

• New Submission Requirements

• Leave Form Schedule Tab empty and confirm


Supporting Documentation Update Filing Type Cont’d:

• Leave Statement of Intent empty and confirm. SOI

updates should be made in original filing.


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


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


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


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


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

[email protected]

(609) 901- 4113

Insurance Compact

[email protected]

(202) 471-3962



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