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It is a best practice to submit form filings and Supporting Documentation Updates in separate filings. While the Compact recognizes the need for filing efficiencies, turnaround time and data integrity in SERFF are negatively affected when a form filing contains unrelated updates to the Statement of Variability or Actuarial Memorandum for a different or associated filing.

For example, in a guaranteed living benefit form filing, including revised statement of variability on approved indexed annuity contracts in order to add a new index.  The statement of variability updates to the index annuity are unrelated to the guaranteed living benefit form filing.  Including unrelated supporting document updates in a form filing slows down review time because it amounts to a second review to consult and compare different underlying materials and forms. On the filer side, combining forms for review with supporting documentation revisions generates more opportunity for error in handling the filing documents.

Revisions or updates to supporting documents should be submitted in a separate filing where the Filing Type is "Supporting Documentation Update".  Please review FIN 2017-1 for filing guidance related to supporting documentation updates.  For your convenience, you can access FIN 2017-1 here.  If a filer is unsure if a supporting document revision or update is related to the forms in the filing, please reach out to the Compact Office for assistance.