Weekly Tip: Using the Correct TOI for LTC Combo Filings

 

Weekly Tips

Using the Correct TOI for LTC Combo Filings

8/27/2014

The ability to file Combo Filings, which we use to describe products that combine more than one TOI, are one of the many benefits of utilizing the Insurance Compact for your product reviews and approvals. The most common product combo filing is a life insurance policy with a long-term care (LTC) rider. This week’s Weekly Tip is to remind you about selecting the proper TOI for your product filing submission.  The correct TOI is what determines the governing Submission Requirements for the product filing.

For all products that contain a LTC component, the filer shall select the applicable LTC TOI.  If the Compact filing submission contains individual life or annuity policies and individual LTC rider(s), please select the TOI for LTC– do NOT select the life or annuities TOI.  By selecting the LTC TOI, your review process will move in an efficient and effective manner as the Insurance Compact Reviewer will not need to issue any objections because particular Submission Requirements were not satisfied due to the incorrect TOI being selected. It also ensures the Compacting States that have opted out of individual LTC are not included on the product filing since it has an individual LTC component. It is also important to remember that if you have any LTC advertising associated with this combo product that you submit them in a separate advertising-only filing under the LTC TOI with Advertising as the Filing Type.  Again, this is to ensure an efficient review of your product filing by presenting critical Submission Requirements before the filing is submitted. 

The Insurance Compact published a Filing Information Notice (FIN), specifically FIN 2013-2, which explains the steps involved in preparing and submitting an individual LTC insurance product filing including Combo Filings.  Also, please be aware at this time the Insurance Compact does not have a Uniform Standard to review individual disability riders being used with individual life or annuity policies.

If you have any questions regarding this Weekly Tip or Combo Filings in general, please contact the Insurance Compact.