Weekly Tip: SOI & Non-Product Components

 

Weekly Tips

SOI & Non-Product Components

2/20/2015

In this week’s Weekly Tip we wanted to give you some helpful tips for the type of forms that should be included on the Statement of Intent (SOI) of a filing that is marked Mix and Match. 

When completing the SOI, please keep in mind that the governing rule specifically defines the kinds of forms that are eligible for mix and match.  Section 111 of the Interstate Insurance Product Regulation Commission Operating Procedure for the Filing and Approval of Product Filings, permits Commission Product Components (“Compact approved forms”) to be used with State Product Components (“State approved forms”) as long as the Statement of Intent identifies the state approved forms that will be used with the Compact approved forms.  A Product Component, as defined under Section 102(q) of the Operating Procedure, is a policy form, application, rider, amendment, or endorsement. In other words, a component is a separate and discrete part or component that when combined makes up the product.  That is why the procedures for mix and match only permit combinations of a Commission Product Component and a State Product Component that do not contain inconsistent, ambiguous, unfair, inequitable, or misleading clauses, or exceptions or conditions that unreasonably affect the risk purported to be assumed.  

Only State Product Components - the policy, the application, the rider, the amendment, or the endorsement - filed/approved by the Compacting States should be listed on the SOI Schedule. Ancillary forms that are used with the State Product Component - such as separate point-of-sale notice and disclosure forms - should not be listed on the SOI Schedule. Another example is when a Commission Product Component, such as an Accelerated Death Benefit Rider, is being used with a previously-approved state-approved life insurance policy and that state-approved life insurance policy is used with state-approved riders such as a Waiver of Premium Rider.  In this example, the SOI Schedule should only identify the state-approved life insurance policy as that is the State Product Component that the Compact Product Component is being used with and the SOI Schedule should not list the ancillary state-approved riders, like the Waiver of Premium Rider, being used with the state-approved life insurance policy. Being attentive to the State Product Component being used with the Commission Product Component can save you time entering SOI items.

Always remember to include complete and accurate information on the SOI Schedule and minimize the use of “Not Available” for fields where the information is ascertainable - Compacting States may follow up with the filer if the state-specific information does not match their records.  If you are not using the Preformatted Template to automatically upload SOI Schedule data to your filing upon submission or post-submission, consider this functionality as it saves significant data entry and time.

If you have any questions about this Weekly Tip or the Insurance Compact, please let us know.