Weekly Tip: FIN 2017-1 – More Tips for Revising Supporting Documentation

 

Weekly Tips

FIN 2017-1 – More Tips for Revising Supporting Documentation

4/18/2017

Continuing the series of Weekly Tips based on the new Filing Information Notice – FIN 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings (FIN 2017-1) issued on March 9th, this week we will review revisions to Supporting Documentation outside the Statement of Variability, in a new filing submission using the new filing type, Supporting Documentation Update.

The last subset of possible revisions commonly made to filing submissions are revisions to information that was originally submitted as Supporting Documentation and is outside of the statement of variability. A few examples include: adding information for unisex sales, such as an additional Actuarial Memorandum and/or an update to unisex submission requirements; expanding the format in which an approved application is to be used without adding any forms to the Form Schedule (i.e. indicating that the application will now be used electronically in addition to the paper and telephonic formats as indicated at the time of submission); or changing procedures used to verify the authenticity of telephonic or electronic application transactions. Under the new filing procedures, these revisions will now be required under a Supporting Documentation Update filing type.

If the revisions change the static form language beyond the revised bracketed information, new forms with new, unique form numbers are required to be filed for review and approval.

Over the past few weeks, you may have noticed that we have reviewed amendments and the filing process for filings that have been “Closed – Approved.” Two critical points to remember: if revision is needed in (1) static form language outside of bracketed information, or (2) filing with “Closed – Withdrawn” status, any and all amendments will need to be presented in a new filing submission.

If there are any filing situations not addressed within the FIN, please contact the Insurance Compact Office. If you have any questions regarding the new FIN or the processes outlined, please contact the Insurance Compact Office.