SUMMARY OF THE NOVEMBER 2025 COMPACT ROUNDTABLE
Prepared by the Compact Office
EXECUTIVE SUMMARY
The eighth Compact Roundtable was held on November 5, 2025, in Omaha, Nebraska, with 19 commissioners and regulators, along with 31 company representatives, two industry association representatives, and three consumer representatives to discuss the role of the Compact in product development, opportunities to improve pre-filing engagement, and the proposed Consultation and Advisory Services Office (CASO)1 framework . The discussion centered on how the Compact can continue to support innovation while providing efficient, consistent, and high-quality product review.
Participants consistently identified the Compact's efficiency, reviewer expertise, and ability to promote greater uniformity across jurisdictions as key strengths. Companies noted the value of filing through the Compact when Uniform Standards are available and emphasized the speed-to-market advantages provided by a centralized review process. Regulators highlighted the efficiencies gained through Compact reviews and the ability to leverage specialized expertise that may not be available within individual states.
The Roundtable also explored how companies and regulators engage during product development and pre-filing activities. Participants generally agreed that early communication can help identify potential issues, improve consistency, and provide more meaningful feedback before significant development resources are committed. Several attendees emphasized the importance of involving the appropriate subject matter experts and providing specific, actionable feedback during pre-filing discussions.
A significant portion of the discussion focused on the proposed CASO framework. Participants identified potential benefits including earlier regulator engagement, enhanced information sharing among states, increased consistency in regulatory review, and opportunities to identify gaps in existing Uniform Standards. At the same time, attendees stressed the importance of addressing confidentiality protections, clearly defining deliverables and expectations, and ensuring that any framework provides tangible value to companies and participating states.
Overall, participants expressed strong support for the Compact's mission while discussing ways to improve communication, strengthen consistency, enhance pre-filing engagement, and support innovation through collaborative review processes. Interest in continued development of the CASO concept was evident throughout the discussions.
DETAILED SUMMARY
On November 5, 2025, regulators, industry representatives, and Compact staff participated in a Roundtable discussion focused on product development, pre-filing communications, and the potential implementation of the Consultation and Advisory Services Office (CASO) framework. Discussion was organized around a series of hypothetical scenarios designed to explore how companies develop products, interact with regulators during the pre-filing process, and might utilize a future CASO process.
PRODUCT DEVELOPMENT AND FILING STRATEGY
DISCUSSION QUESTIONS
- How do companies currently incorporate regulatory considerations into product development?
- At what point do companies determine whether a product will be filed through the Compact or directly with states?
- What role can the Compact play earlier in the process?
Participants described product development as a multidisciplinary process involving product development, legal, actuarial, underwriting, compliance, claims, marketing, and administrative personnel. Several attendees indicated that regulatory considerations are often incorporated early in the process, particularly when a company intends to utilize the Compact filing process.
Companies noted that the existence of applicable Uniform Standards frequently influences filing strategy decisions. Where standards exist, participants generally expressed a preference for filing through the Compact due to the efficiencies and consistency associated with centralized review. However, companies also indicated that some innovative products or unique product features continue to be developed outside existing Uniform Standards, resulting in state-specific filing strategies.
Several attendees discussed the importance of engaging with the Compact early in product development. Participants noted that early discussions can help determine whether a concept is compatible with existing standards and whether it is worthwhile to invest additional resources in product design and development. Some regulators encouraged companies to contact the Compact and states early when innovative concepts are being considered.
PRE-FILING COMMUNICATIONS
DISCUSSION QUESTIONS
- How are pre-filing communications currently used?
- What information is most valuable to participants?
- How can the process be improved?
Participants generally agreed that pre-filing communications provide significant value. Companies noted that pre-filing discussions can help identify objections, clarify regulatory expectations, and provide feedback before product filings are finalized. Regulators also emphasized the benefits of early dialogue, particularly where multiple states may have similar questions or concerns.
Discussion focused on the importance of receiving consistent and actionable feedback. Attendees indicated that pre-filing discussions are most useful when product concepts are presented with sufficient detail and when the appropriate decision makers and subject matter experts participate. Several participants observed that involving reviewers and approvers early in the process could improve the usefulness of the feedback provided.
Participants also discussed the value of bringing states together for a common discussion. Companies noted that hearing multiple perspectives simultaneously could improve efficiency and reduce duplicative conversations. Regulators cited opportunities for greater collaboration and consistency among participating states.
FRAMEWORK DISCUSSION
DISCUSSION QUESTIONS
- What value could a CASO process provide?
- What information should be included in a CASO report?
- What concerns should be addressed before implementation?
Participants discussed several potential benefits of the proposed CASO framework. One frequently cited advantage was the opportunity for companies to receive feedback early in the development process before making significant investments in product design. Attendees suggested that the framework could provide a roadmap for companies by identifying possible regulatory concerns and highlighting areas requiring additional development or discussion.
Regulators discussed the value of increased collaboration and information sharing. Some participants noted that a formalized process could help states with limited actuarial or product expertise benefit from the perspectives of other regulators. Participants also suggested that the resulting reports could help states understand the issues discussed and provide context regarding potential filing approaches.
Several attendees emphasized that report quality would be critical to the success of the program. Suggestions included documenting questions raised by regulators, providing explanations for concerns identified during discussions, and including citations or references supporting findings and recommendations. Some companies indicated that receiving consolidated feedback from multiple jurisdictions would help create more consistent filing approaches.
Confidentiality emerged as a significant theme. Industry representatives consistently stressed the importance of protecting proprietary information and trade secrets. Questions were raised regarding which parties would have access to reports, the legal protections that would apply to shared information, and how confidential product concepts would be safeguarded throughout the process.
Participants also discussed the need for clarity regarding the weight and impact of CASO recommendations. Companies indicated that the usefulness of the framework would depend heavily on whether output from the process would meaningfully influence subsequent state reviews. Several attendees emphasized that the framework must provide clear, actionable value while avoiding unnecessary delays or duplication of effort.
FEEDBACK ON CURRENT COMPACT OPERATIONS
Throughout the discussions, participants offered feedback on the Compact's current operations. Attendees consistently praised the Compact's expertise, responsiveness, and ability to provide efficient review across multiple jurisdictions. Participants also highlighted the value of reviewer consistency and the organization's willingness to engage with stakeholders throughout the filing process.
Areas identified for potential improvement included maintaining consistency in objections, continuing to address SERFF-related challenges, providing additional information resources for filers, improving access to state contacts, and exploring mechanisms to address disagreements during the review process. Several attendees discussed the potential value of an escalation process that could provide additional regulatory review before an adverse determination is reached.
GROUP DISCUSSION
During the closing discussion, participants reiterated strong support for the Compact's mission and operations. There was broad agreement that the Compact provides valuable expertise, promotes efficiency, and supports greater consistency in product review. Attendees generally agreed that earlier communication, access to subject matter expertise, and opportunities for collaborative discussion can improve outcomes for both regulators and industry.
Participants expressed interest in continued development of the CASO concept while emphasizing the importance of confidentiality protections, stakeholder participation, clear deliverables, and meaningful regulatory value. Discussion also highlighted the need for continued focus on consistency between Compact and state interpretations, ensuring that any future framework complements existing review processes while preserving the efficiencies that stakeholders value most.
The Roundtable concluded with a shared recognition that collaboration between regulators and industry remains essential to supporting product innovation while maintaining effective consumer protections and state-based insurance regulation.
Appendix
1 Following the Roundtable, the Consultation and Advisory Services Office (CASO) concept evolved into the Compact Center of Expertise. The collaborative review, advisory support, and regulator engagement concepts discussed in this summary informed the development of the Compact Center of Expertise framework.