Reviewing Draft Responses
Filers regularly contact the review team to ask whether a draft response will satisfactorily address pending compliance issues. While it can be tempting to ask if a specific proposed response will be successful, this approach is actually more time-consuming, because it causes the reviewer to step away from the workflow, is less direct than simply filing the draft response in SERFF, and amounts to a double review.
Communication concerning a filing during the review process should remain within the SERFF filing. When questions arise regarding a pending filing, including requests for clarification of a compliance issue, filers should first contact the assigned reviewer through a Filer-Reviewer Note in SERFF. Including the specific question(s) from the company will help facilitate a quicker response.
Please keep in mind that the Compact does not perform pre-filing compliance reviews of responses to compliance issues. Therefore, this type of request should not be submitted in SERFF, via email, or through a request for a call to review the issue and proposed response. It should go without saying that asking for review of a proposed response is highly disfavored for filings in the expedited review queue. Compliance issue responses will be analyzed only after they have been formally submitted via amendment to the filing and are ready for review.
If you have any questions, please reach out via comments@insurancecompact.org.
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