Weekly Tip: Revisions to Pending Filings - Diving Deeper on FIN 2017-1

 

Weekly Tips

Revisions to Pending Filings - Diving Deeper on FIN 2017-1

3/23/2017

On March 9th, the Insurance Compact Office issued a new Filing Information Notice – FIN 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings (FIN 2017-1). Here is the second in a series of Weekly Tips based on the new Filing Information Notice. This week, we will review revisions to information in pending filings. As was stressed last week, filers are urged to ensure the product filing is in as final form as possible at the time of filing.

Revisions to forms and supporting documentation in response to substantive objections issued by the Insurance Compact reviewer(s) are part of the review process. Substantive objections are based on complete form and/or actuarial review of the filing for compliance with the applicable Uniform Standard(s) by the reviewer(s). Substantive review is distinct from intake and preliminary review, which ensure that all filing fees were properly submitted and the filing contents are complete for substantive review to occur. These processes have not changed. Revisions to respond to substantive objections were covered in last week’s Weekly Tip and can be found in § I.A of FIN 2017-1.

Occasionally, filers will make significant, unanticipated revisions that are not requested or required to respond to the intake, preliminary or substantive objections issued by the Insurance Compact reviewer(s). This can include adding new forms to the Form Schedule, removing or adding product charges and re-working product features. These actions bring the filing review process to a halt, as reviewers have to re-evaluate form and actuarial compliance or apply additional Uniform Standards. Unless so instructed by the Compact reviewer(s), submitting a new form to the Form Schedule in a filing that is currently under review will now require a new filing submission to keep the original filing moving and better capture the review involved. Revisions that are initiated by the filer after substantive objections are issued and are not in response to substantive objections will require a Compact Amended Filing Fee and may extend the review time. Section I.B of FIN 2017-1 outlines the procedures that filers are required to follow as of April 1st.

We detailed last week that certain revisions to Compact filings are available at any time and do not generate additional Compact filing fees, as described in § I.C of FIN 2017-1. As the weeks progress, our Weekly Tip series will detail the various new procedures that filers will be expected to follow on and after April 1st. Be on the lookout for an announcement of dates for a webinar on FIN 2017-1 offered by the Insurance Compact Office.

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.