Weekly Tip: Filing Information Notices Deconstructed

 

Weekly Tips

Filing Information Notices Deconstructed

1/03/2013

One of the key ingredients in a filer's recipe for making a great Insurance Compact product filing is learning to use the Insurance Compact's Filing Information Notices (FINs).

FINs are documents issued by the Insurance Compact Office to provide guidance, instruction, and best practices in order to facilitate the submission of compliant product filings to the Insurance Compact. FINs are not rulemaking, but serve rather to provide further explanation and clarification for filing and review in order to implement existing rulemaking documents such as Operating Procedures, Uniform Standards, and Actuarial Requirements contained in the Uniform Standards. A FIN serves to "flesh out" the details. Every FIN is developed by the Insurance Compact Office, before it is implemented. Where a FIN provides interpretive guidance of a Uniform Standard, the Compact Office will consult with its Product Standards Committee or Actuarial Working Group, as applicable.

The Insurance Compact Office has issued FINs to facilitate with the filing of mix and match information for the Statement of Intent Schedule; instructions for submitting long-term care and disability income products; and guidelines for filings with guaranteed living benefits and bonus features. These are just a few examples of the FINs that have been issued.

Every FIN will reference an applicable effective Uniform Standard and/or Operating Procedure adopted by the Commission. The FINs may be found on the Compact's website, namely the homepage under "Filing Information Notice". The Operating Procedures and Uniform Standards may be accessed on the "Record". Additionally, the FINs, Uniform Standards, and Operating Procedures are referenced in the Compact's General Instructions and Submission requirements in SERFF.

FINs are an important filing tool that should be a part of a filer's due diligence in preparing an Insurance Compact filing as they can enhance the compliance of a filing and likely minimize objections and review time.

If you have any questions regarding the Compact's FINs, please do not hesitate to contact the IIPRC Office.