Weekly Tip: Use of Mix & Match

 

Weekly Tips

Use of Mix & Match

9/23/2013

More than half of the submissions that are submitted to the Insurance Compact use the so-called “mix and match” process.  This week the Insurance Compact would like to highlight key principles behind the use of mix and match. 

Mix and match was created in the Operating Procedures for the Filing and Approval of Product Filings (Product Filing Rule) to encourage companies to utilize the Insurance Compact before all Uniform Standards had been adopted and in effect.  Mix and match can also be used when a filer is not ready to refile its whole product portfolio but rather refresh a component, such as a policy or an application, or file a new product feature by way of a rider.

The drafters of this Product Filing Rule had intended the companies to submit for approval a “product component,” which is defined as a policy form, an application, a rider, an amendment, or an endorsement, with the Insurance Compact to be used with an already-approved state product component.   To assist the Member States with their understanding of what is being sold in their states, the company filers are required to submit specific information as to what state-approved forms are to be used with the Insurance Compact forms upon approval.  This information is entered into the product filing submission through the Statement of Intent (SOI) schedule and must be kept updated by the filer.  This SOI requires companies to enter identifying details regarding the form, to include the State Tracking Number, the SERFF Tracking Number, and the date of approval.  This information should be updated as the forms are either (1) approved by the state and/or (2) as business decisions change and additional components are to be sold with the Insurance Compact component. 

As the Insurance Compact has implemented full suites of Uniform Standards across the individual product lines, the need for filers to bifurcate a product filing by contemporaneously, concurrently, or subsequently filing one product component with the state insurance departments to be mixed and matched with a product component filed with the Insurance Compact should be a rare occurrence.  The timing of this type of filing is called reverse mix and match where the state filing is made at, around, or after the time of the Insurance Compact filing.  If the product component being filed with the state insurance departments is within the scope of an applicable Uniform Standard, it should be filed with the Insurance Compact rather than split between the Insurance Compact and the state insurance department through mix and match.

Keep in mind a few simple guidelines for mix and match. The use of mix and match cannot alter, change or affect values or nonforfeiture requirements in state-approved forms.  Mix and match cannot be used to fully comply with the Uniform Standard (e.g. IIPRC form standing alone has to comply fully with the applicable Uniform Standard), nor can it be used to bypass provisions within a Uniform Standard (e.g. filing a form with a Compacting State(s) for use only with a Compact-approved form even though the Compact has Uniform Standards applicable to the state-filed form).  Application parts cannot be mixed and matched. If filing an application with the Compact, the Application Uniform Standards require that a filing include all sections and questions required to be completed by an applicant, including additional drop downs, scripts, questions, questionnaires or supplements.

Also as part of the submission requirements associated with mix and match, a Company Officer must certify that the combination of components does not contain inconsistent, ambiguous, unfair, inequitable, or misleading clauses, or exceptions or conditions that unreasonably affect the risk purported to be assumed must be included in the filing.   

More information regarding mix and match and the submission of product filings that contain mix and match can be found on the Insurance Company’s website.   Numerous resources (e.g. web-based tutorials, previous weekly tips, instructions for completing the SOI and the SOI template) may be found specifically on the Insurance Company Resources page, the Filing Information Notices page, and the Record

If you have any questions about this Weekly Tip or mix and match, please contact the Insurance Compact’s Office.