The Interstate Insurance Compact ("Compact") is an important modernization initiative that benefits state insurance regulators, consumers and the insurance industry. 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 national 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. The Compact provides Member States with the ability to collectively use their expertise to develop uniform national 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.
The Management Committee of the IIPRC manages the affairs of the Commission. The Management Committee Members currently include the six largest Compacting States by premium volume: Texas, Pennsylvania, Ohio, Michigan, Massachusetts, and North Carolina; four mid-size states by premium, Georgia, Virginia, Minnesota and Indiana; and one additional state from each of four regional zones, Idaho, Oklahoma, West Virginia, and Vermont. Additional Members of the Compact include: Alaska, Colorado, Hawaii, Iowa, Idaho, Kansas, Kentucky, Maine, Maryland, Nebraska, New Hampshire, Puerto Rico, Rhode Island, Tennessee, Utah, Wisconsin, and Wyoming.
Since meeting its operational threshold in May 2006, the Interstate Insurance Product Regulation Commission (IIPRC) now has 31 Member States representing half of premium volume nationwide, and has been making great strides towards becoming fully operational in 2007. The following provides a highlight of achievements and outlines continuing plans.
- June 2006: 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.
- August 2006: IIPRC Publishes Bylaws. The IIPRC maps the framework of the organization through extensive consultations with regulators, legislative representatives, consumers, and industry.
- November 2006: First Annual IIPRC Meeting. In Lansdowne, VA, the IIPRC holds its first Annual Meeting where the membership elects Officers and announces the appointment of the organization’s new Executive Director to oversee the day-to-day operations.
- December 2006: First Standards Adopted. Within its initial six (6) months of operation, the IIPRC adopts its first Uniform Standards on Adjustable Life upon the completion of full public notice and comment. Legislative Committee Leadership. The IIPRC Legislative Committee names its leadership and works as an active partner to oversee the progress of the IIPRC.
- March 2007: Operational Progress. IIPRC Officers from West Virginia, Michigan and Minnesota conclude New York City Meeting with continued progress towards the start-up of IIPRC product filing operations.
- April to May 2007 : Start-Up Preparation. New Coordinator staff is brought on board to manage administrative requirements and vital public notice platforms. Additional work is completed on the System for Electronic Rate and Form Filing (SERFF) which allows companies to electronically file their products with the IIPRC, and a state filing fee collection structure is put in place to ensure that all proper state fees are collected on behalf of the Member States. The IIPRC is afforded a secondment of an interim product filing examiner from a Member State to review anticipated Compact filings .
- June 2007 : First Filings Received. In addition to its first five (5) adopted Standards, the IIPRC has Uniform Standards for a Life Application and six (6) Riders in filing effect for June. Upon adopting its Product Filing Rule which allows for the filing of already-approved Member State forms with IIPRC forms for review (“Mix and Match” provision), the IIPRC is open for business and receives its first product filings by insurers on target with its mid-2007 time frame .
- July 2007: First Filings Approved. The IIPRC approves the first product filings received in under 30 days and continues to receive new filings.
- September 2007: IIPRC implements Compact Fees. The IIPRC adopts a Compact filing fees structure as the Compact Statute provides that the IIPRC shall be funded by filing fees. The Commission held its Second Annual Meeting and elected officers from West Virginia, Ohio and Minnesota to serve during the remainder of 2007 and 2008; as well as adopting nine (9) more standards to bring the total Uniform Standards to thirty-six (36).
- January 2008: Experienced Regulators join the IIPRC team. Annual Registration Fees are instituted and collected from companies who wish to file with the IIPRC.
- February 2008: Experienced Actuary joins the IIPRC review team.
- March 2008: Code of Ethics is adopted. More standards become effective bringing the total Uniform Standards to thirty-eight (38) with Conforming Amendments. The IIPRC continues to adopt additional Uniform Standards, outreach to more States to join the Compact, and encourage insurers to utilize the IIPRC central point of product filing.
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