Hot Topics at the Compact Compact’s Value-Added Benefits What’s Up with Compact Legislative...

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 (SERFF)

• 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 care

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


• 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 products

• Compact-approved LTC forms can be submitted for Partnership via easier certification /approval process


• Straightforward filing process using SERFF• Tools and checklists for filers on IIPRC web site• 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 compliance

• Average approval in 60 review days or less


• 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,

rollout• Simplified producer training

Getting Started with the Compact

• Visit the IIPRC website– www.insurancecompact.org– Check out the Company Resources Web

Page– 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 CompactProduct Review Team

• Charlie Rapacciuolo is our Product Operations Coordinator

• 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

6/10/2013– 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


• Filling in the Gaps on individual standards– Uniform Standard for Guaranteed Minimum

Death Benefits for Non-variable Annuities– Chronic illness triggers for Guaranteed Living

Benefits– 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


• 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 lines

– Industry Advisory Committee has provided comments– PSC expected to make a recommendation by mid-

summer


• What is the next new set of Uniform Standards– Last summer, solicited feedback on

framework for group Annuity Uniform Standards

– Will soon conduct advanced rulemaking to solicit comments for group Disability Uniform Standards

– 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


• 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


• Updated Fee Schedule – simplified and diversified

• 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


• 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


• 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


• 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 include – “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 standard

• 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 companies

• Currently working on guidance for states and companies re: content v. market regulation

• Increased outreach to member regulators and legislators

• Resources for addressing ongoing growth

Questions?

CONTACT IIPRC

• For more information, please contact us at:

[email protected]

www.insurancecompact.org

Phone: (202) 471-3962

Fax: (816) 460-7476

Hot Topics at the Compact Compact’s Value-Added Benefits What’s Up with Compact Legislative...

Documents

Transcript of Hot Topics at the Compact Compact’s Value-Added Benefits What’s Up with Compact Legislative...