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It is important that for any forms that could be used with groups other than employer groups, the filer prominently and clearly identifies in the Filing Description the potential to use the forms in the filing with non-employer groups (NEG). This is necessary because there are specific submission requirements relative to NEG filings that need to be met.  With respect to group annuities, groups with two or more employers or trustees of employers are treated as NEGs.

Here are our quick tips for NEG filings:

• Use the Filing Type "Group Policy Forms - NEG" instead of any other filing type, even if the material in the filing is also for use with employer groups. Use of this Filing Type is critical to support the state-specific reporting and filing requirements underpinning the Compact's approval of NEG products.
• If the NEG Filing Type is not used, filers will be put on notice that for future NEG filings, a refiling will be required when the NEG Filing Type is not used.
• The Filing Description must prominently indicate if the forms will be used with employer groups, NEGs or both.
• For NEGs, the filer MUST identify what types of non-employer groups the forms will be used with. We have seen filings that do not indicate in the Filing Description that the material in the filing can be used with NEGs but the forms themselves or the supporting documents may reference specific NEGs.