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Index Strategy Filing Reminders

Supporting Documentation Update (SDU) filings are a specific Compact filing type used to make updates to supporting documentation in Compact approved filings, such as statement of variability or actuarial memorandum. No forms for review are permitted in these types of filings, nor can items appear under the Statement of Intent.  When setting up SERFF for an SDU filing, the Filing Type of "Supporting Documentation Update" is required.  Failure to use this Filing Type will require a refiling of the submission under the Filing Type "Supporting Documentation Update".  For further guidance on SDU filings, please review FIN 2017-1.

A common usage of SDU filings is to add or change indices under individual indexed products as uniform standards require prior IIPRC approval before any change or addition of an index can be made.  This usage is permitted; however, It is not appropriate to use an SDU filing to add a new index crediting methodology in addition to or separately from adding or changing a specific index or indices.  A form filing is required to add a new index crediting methodology for a product.

When making an index update filing, best practice is to identify in the Filing Description, by filing tracking information, the filing containing the most recently approved supporting documentation.  For example:

The Statements of Variability and Actuarial Materials for ICC19 E-PTP-C, ICC23 E-PTP-PR, and ICC25 E-MPTP-C have been updated to add the S&P 500 Index® and the Dow Jones Industrial Average® indices.  The most recent SOV updates for the index endorsements listed above may be located under SERFF Tracking number WXYZ-IC-E26BASE with an approval date of 2/9/2026.

Make sure to associate the filing(s) containing the most recently approved supporting documentation.

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