The Compact enhances the efficiency and effectiveness of the way insurance products are filed, reviewed, and approved allowing consumers to have faster access to competitive insurance products in an ever-changing global marketplace. The Compact promotes uniformity through application of uniform product standards embedded with strong consumer protections.
The Compact established a multi-state public entity, the Interstate Insurance Product Regulation Commission (IIPRC) which serves as an instrumentality of the Member States. The IIPRC serves as a central point of electronic filing for certain insurance products, including life insurance, annuities, disability income, and long-term care insurance to develop uniform product standards, affording a high level of protection to purchasers of asset protection insurance products.
The Compact is good news for both consumers and insurers. Consumer protection is the hallmark of the state-based regulatory system. Insurers may continue to rely on the extensive expertise of the states in reviewing complex products. State insurance regulators believe the state-based IIPRC is the preferred solution to enhance speed-to-market efficiencies while continuing to provide insurance consumers with strong and established protections.
Since meeting its operational threshold in May 2006, the IIPRC now has 45* Member States representing over 70% of the premium volume nationwide. The Management Committee Members currently include the six largest Compacting States according to premium volume: Texas, Pennsylvania, New Jersey, Illinois, Ohio, and Michigan; four states with at least 2% of the premium volume: Massachusetts, Missouri, Virginia, and Wisconsin; and one additional state from each of four regional zones, Idaho, Maine, Mississippi and Oklahoma. Additional Members of the Compact include: Alabama, Alaska, Arkansas, Arizona, Colorado, Connecticut*, Georgia, Hawaii, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Carolina, Oregon, Puerto Rico, Rhode Island, South Carolina, Tennessee, Utah, Vermont, Washington, West Virginia, and Wyoming.
*Connecticut enacted the Compact legislation in June 2016 and will be effective for filing on July 1, 2017.
The following provides a highlight of achievements and outlines continuing plans of the IIPRC.
Inaugural Meeting of IIPRC in Washington, DC. Under the motto banner of “States, Strength and Speed Aligned”, the IIPRC Members reaffirm their commitment to modernize state-based insurance regulation to meet the needs of the evolving global insurance marketplace while continuing to uphold strong consumer protections.
July through December 2006:
IIPRC established its operational foundation through extensive consultations with regulators, legislative representatives, consumers, and industry in developing and adopting the Bylaws. The IIPRC held the First Annual IIPRC Meeting in Lansdowne, VA. The first Uniform Standards were adopted within the initial six (6) months of operation The IIPRC Legislative Committee named its leadership and worked as an active partner to oversee the progress of the IIPRC.
IIPRC hired staff; and elected Officers from West Virginia, Michigan and Minnesota. Updates to the System for Electronic Rate and Form Filing (SERFF) were completed to allow companies to electronically file their products with the IIPRC including payment of Member state fees electronically. 11 individual life Uniform Standards were in effect for June. The IIPRC seconded an interim product filing examiner from a Member State to review Compact filings. Upon adopting the “Product Filing Rule”, the IIPRC opened for business and received the first product filings by insurers on target with the mid-2007 time frame. The IIPRC approved the first product filings received in under 30 days. The IIPRC adopted a Compact filing fee structure as the Compact Statute provides that the IIPRC shall be funded by filing fees. Nine (9) more Uniform Standards were adopted to bring the total Uniform Standards to 36.
Experienced Regulators and Actuary join the IIPRC team. Annual Registration Fees are instituted and collected from companies who wish to file with the IIPRC. Additional States join the Compact to bring the premium volume represented to over one-half of the premium volume nationwide. Additional Uniform Standards are developed and are in effect, bringing the total at the end of 2008, to 46 Uniform Standards.
Mississippi, New Mexico, and Missouri enact the Compact legislation for a total of 36 Member states. More Uniform Standards became effective in both the life and annuity product lines, bringing the total number of Uniform Standards in effect to over 50. The “Product Filing Rule” was amended to eliminate the two-year time frame associated with the “mix and match” filing process.
The IIPRC worked on the development and adoption of the full-suite of individual Long-Term Care Insurance Uniform Standards. The IIPRC convened an in-person meeting in May for the purpose of receiving comments on the Long-Term Care Rate Uniform Standards. With the adoption of these Uniform Standards, the IIPRC now has three (3) individual product lines – life, annuity and long-term care – in effect. The IIPRC amended the “Filing Fee Rule” to change the definition of Regional Filers and to adopt a Schedule of Fees to be adopted on an annual basis along with the IIPRC’s Annual Budget.
New Jersey, Alabama, Nevada, and Oregon enacted the Compact legislation bringing the total number of Member states to 41 with approximately 70% of the premium volume nationwide. Additional resources join the IIPRC Team with the retention of a new Product Review consultant. The four product lines designated in the Compact are all enacted with the adoption of the Disability Income Uniform Standards. There are over 80 Uniform Standards in effect. Additional actuarial resources and full-time staff join the IIPRC.
Group Term Life Uniform Standards for employee/employer groups are developed and adopted – the first of the group uniform product standards. Over 90 Uniform Standards have been adopted. The IIPRC adopted a new Schedule of Fees based on whether or not an actuarial review is required for the product filing and the premium volume of filing companies.
The IIPRC now has 43 members with the enactment of the Compact legislation in Montana and Arkansas. The IIPRC had a record year with the number of registered and filing companies. Over 180 companies utilized the speed-to-market platform of the Compact for product filings and approvals.
New Resources joined the IIPRC Team. Additional states are expected to join the IIPRC throughout the year. The IIPRC is currently conducting a five-year review as mandated in the “Rulemaking Rule” of all Uniform Standards.