Weekly Tip: Getting Started with the Compact


Weekly Tips

Getting Started with the Compact


Are you wondering how to get started with the Compact? Or are you creating a filing submission for a new product line? If so, please read below for this week's tips.

When gathering the requirements associated with submitting a Compact filing, we suggest you start by locating and reviewing the applicable Uniform Standard(s) which are found on the Record under the applicable product lines. The IIPRC Type of Insurance TOI Link provides a reference guide to help filers correlate Uniform Standards with TOIs and Sub-TOIs in the NAIC's Product Coding Matrix. We suggest carefully reviewing the Scope section as well as additional requirements or demonstrations in appendices. If the Uniform Standard requires an actuarial memorandum or information, we suggest providing the entire Uniform Standard to the actuary involved in preparing this information. The IIPRC publishes its reviewer checklists for all Uniform Standards which are simply the Uniform Standards in checklist format. The IIPRC strongly encourages filers to utilize these checklists in order to maximize compliance and minimize review time (checklists are not required to be filed). The checklists have recently been moved to the Record alongside the Uniform Standards and are now form-fillable!

Using the applicable Uniform Standards and reviewer checklists is only one step in preparing a Compact filing. We suggest filers consult the Operating Procedure for the Filing and Approval of Product Filings for applicable filing requirements especially with regards to mix and match filings (Section 111 of the Product Filing Rule). For mix and match filings, filers must have the Mix and Match indicator in the Filing Wizard on "Yes" and complete the Statement of Intent Schedule. Filers can utilize one of our four self-guided web tutorials on the Insurance Company Resources web page for guidance on how to prepare a Compact filing including completing the SOI Schedule. Through SERFF, Compact filers can use the "copy and paste" template features to make it easier to input SOI information. Next week, we are releasing an enhancement that will allow filers to automatically upload a pre-formatted Excel spreadsheet into the SOI Schedule!

Another important resource in preparing a Compact filing is to review the IIPRC's Filing Information Notices. The IIPRC provides a link to Filing Information Notices (FINs) on its home page and the Company Resources page. The purpose of FINs is to explain steps or clarifications in the IIPRC's process for filing and review of product filings under the applicable Uniform Standards. FINs cover a variety of topics including mix and match; disclosures and illustrations; making individual long-term care or disability income filings. FINs also provide guidance for filers in demonstrating compliance with particular provisions of the Uniform Standards. The IIPRC recently issued two FINs - one to provide guidance for nonforfeiture compliance for rider charges associated with guaranteed living benefits for individual deferred non-variable annuities and the other one to provide guidance for changes in nonforfeiture rates that affect Compact filings. Remember to check out the Compact's FINs before your SERFF!

We also suggest reviewing the Compact's submission requirements and general instructions in SERFF to determine requirements applicable to your Compact filing. It is also important to review the Member State Filing Fee Schedule and the Compact Fee Structure to determine the applicable IIPRC filing fees and state filing fees due, both of which may depend on the type and number of products and forms being submitted. Another "due diligence" tool is the Best Practices Checklist which can be found on the Company Resources page and is intended to help filers avoid common objections or filing mistakes. Filers are also encouraged to review the Best Practices Checklist before pressing the submit button!

Finally, we encourage filers to contact the IIPRC Office if you have any questions about the Uniform Standards or the Compact's filing process. Our team of professionals is accessible to promptly answer your questions both before and after you make a Compact filing. You can find information for contacting the IIPRC team members on the IIPRC's Contact Us link on its home page.

We look forward to working with you.

Please contact the IIPRC Office if you have any questions regarding this notice by sending an e-mail to comments@insurancecompact.org or calling (202) 471-3962.