Weekly Tip: Annuity Filings


Weekly Tips

Annuity Filings


Welcome to the start of the summer months! Are you dreaming of lazy days at the pool or beach or instead, are you dreaming of your next annuity product or benefit rider filing? If the latter, this week's tip from the IIPRC is for you!

The IIPRC has a wide range of Uniform Standards for variable and fixed individual annuities including deferred and immediate categories. For fixed or non-variable, products with index-linked features or that are paid-up / longevity are also covered. Further, the IIPRC has additional Uniform Standards to cover several benefit features common in the marketplace including bonus features, guaranteed benefits, market value adjustments, waiver of surrender charge and private placement. All adopted Uniform Standards can be found on the Record on the IIPRC's website by clicking on the "+" next to the applicable individual annuity product line or the "+" next to the Uniform Standards for individual annuity benefit features. Note: the individual annuity application standard is under the tab titled Individual Application with all application Uniform Standards across the product lines.

Please carefully review the scope section of the Uniform Standard(s) to assess the applicability to your product design as particular attention was paid to outline the type of products that could be filed pursuant to the Uniform Standard. If you have any questions about the applicability or scope of the Uniform Standards, please contact us and one of our reviewers will work with you to answer your questions.

We encourage filers to contact the IIPRC even if their preliminary assessment shows no applicable Uniform Standards to their product design. Through this process, the IIPRC can work through its Uniform Standards development process to update an existing Uniform Standard or develop a new one. For example, there is no current Uniform Standard to review Guaranteed Minimum Death Benefits for fixed or nonvariable annuities. The good news is we are working to remedy and a draft uniform standard for this benefit feature is currently in the IIPRC's formal comment and rulemaking period. The draft of this particular uniform standard may be found on the Docket on the IIPRC website. It is important for filers to follow the IIPRC's uniform standards development process and provide input while they are still in the drafting and consideration phase.

We also suggest filers pay close attention to the appendices of the annuity Uniform Standards as well as provide the filer's actuary with a complete version of the applicable Uniform Standard(s). Many times, these appendices contain guidance and requirements affecting the actuarial memorandum and nonforfeiture demonstrations. For instance, the appendices to the additional standards for market value adjustment features outlines the limitations on surrender charges when there is an MVA and the product is not a multi-year guarantee annuity (MYGA).

We encourage all Compact filers to utilize the applicable checklist(s) available on the Record adjacent to the applicable Uniform Standard. It is also helpful for annuity filers to review the Filing Information Notices (FINs) to determine if any are applicable to their product filing. FINs explains or clarifies IIPRC steps or requirements in the process for filing and review of product filings including common issues we may be seeing in the application of the Uniform Standards. We have five FINs specifically related to aspects of certain annuity Uniform Standards or annuity product filings. The IIPRC home page and the Insurance Company Resources both provide links to FINs.

Please contact the IIPRC Office if you have any question about the IIPRC Uniform Standards or filing process and we will gladly work with you to maximize a smoother filing preparation and submission process which will likely minimize compliance issues when it is in the Compact review process.