SUMMARY OF OCTOBER 2024 OMAHA COMPACT ROUNDTABLE
Prepared by the Compact Office
EXECUTIVE SUMMARY
The sixth Compact Roundtable was held on October 30th in Omaha, Nebraska, with 23 commissioners and regulators, 1 legislator from a Compacting State along with 30 company representatives, 2 industry association representatives, and 3 consumer representatives. Participants provided feedback on the framework and pre-filing questionnaire exposed by the Adjunct Services Committee. The discussion focused on the goals of the process. Many agreed it could be efficient to present a new or novel concept to the Compacting States while leveraging the Compact’s expertise and assistance, which could lead to the identification of features/products conducive to new or amended standards. Most groups cited the importance of confidentiality and understanding the parameters of protecting trade secret information. The process should also provide a deeper understanding of the consumer needs and impact of the concept. The feedback was positive at this stage.
Attendees had the opportunity to apply the framework and questionnaire to a fictional product scenario. They suggested adding other sections to the questionnaire, including technology involved, actuarial information, and tax implications. It would be important to have decision makers from the states involved in this process, similar to how a department does it today. It was suggested there is a point of contact for each state. Most agreed this process could help companies understand the concerns and pitfalls it might encounter when it files with the states. from this process and agreed it needs to be clear.
Participants exchanged perspectives on the Insurance Compact and suggestions for enhancements. The Insurance Compact is very responsive, accessible at all levels, and appreciated by filing companies. Some specific requests were made to the current operations including expanding expedited review and improving the mix and match process. Companies shared having standards is very helpful today, and products approved help keep costs predictable for consumers and promote accessibility and availability. A common suggestion was to provide training to member states to keep pace with how rapidly the insurance marketplace changes. The role of artificial intelligence (AI) was raised; there is a need to anticipate how AI can help regulators in keeping up with the industry’s use of AI.
DETAILED SUMMARY
During the Roundtable, regulators, industry representatives, and Compact staff discussed a proposed framework and pre-filing questionnaire intended to facilitate earlier dialogue regarding innovative insurance products and concepts that may fall outside existing Uniform Standards. Participants also provided feedback on the Compact's current operations and discussed broader issues including regulatory education, coordination of reviews, emerging technologies, and opportunities for future strategic initiatives.
BREAKOUT 1 TOPICS AND DISCUSSION
DISCUSSION QUESTIONS
- What parameters should be included in the proposed framework and pre-filing questionnaire?
- How should confidentiality and proprietary information be addressed?
- What outputs would provide value to both regulators and companies?
Participants discussed the overall purpose of the proposed framework and its potential role in facilitating early communication between regulators and companies regarding innovative products and concepts. Many attendees agreed that the process could provide efficiencies by allowing companies to present concepts to multiple Compacting States simultaneously while leveraging the expertise of Compact staff and participating regulators. Several participants suggested that the process could help identify potential pathways for new Uniform Standards or amendments to existing standards.
Confidentiality emerged as one of the most significant discussion topics. Participants emphasized the importance of protecting proprietary business concepts and trade secret information throughout the review process. Discussion focused on how confidential information would be handled by participating states, what information would qualify for protection, and how companies could be assured that innovative concepts would not be disclosed before a product is brought to market. Several attendees suggested that confidentiality questions should be more prominently addressed within the questionnaire and that the process should clearly describe how confidential information will be managed.
Participants also discussed the appropriate level of regulator participation. Many believed that any review should involve regulators with sufficient authority and expertise to provide meaningful feedback and communicate effectively with reviewers and industry representatives. The importance of establishing clear points of contact and communication channels was also discussed.
The conversation explored what companies and regulators would expect to receive from the process. Participants noted that useful outputs could include feedback regarding the approvability of a concept, identification of regulatory concerns, and guidance regarding issues that may require additional development prior to filing. Several attendees also suggested that the framework should include greater consideration of consumer impact when evaluating innovative concepts.
Overall, participants viewed the framework as a potential enhancement to existing pre-filing communications that could improve efficiency, encourage innovation, and promote greater collaboration among regulators and industry representatives.
BREAKOUT 2 TOPICS AND DISCUSSION
DISCUSSION QUESTIONS
- How would the framework apply to a new or innovative product concept?
- What information should be included in the questionnaire?
- What outcomes would provide value to regulators and companies?
Participants applied the proposed framework and questionnaire to a fictitious product concept and discussed how the process could function in practice. A common theme was the potential value of using the framework to promote greater uniformity among states while allowing regulators and companies to explore innovative concepts before the formal filing stage. Attendees noted that a collaborative review process could help identify regulatory concerns early and reduce uncertainty regarding potential state reactions.
Many participants expressed interest in a "sandbox" approach that could provide a pathway for concepts that may not fit squarely within existing Uniform Standards. Discussion focused on whether innovative concepts that demonstrate consumer value could receive some form of provisional support while standards development activities are underway. Participants also emphasized the importance of balancing innovation with appropriate consumer protections and state regulatory oversight.
Speed-to-market considerations were raised repeatedly throughout the discussion. Several attendees observed that the process would need to produce timely feedback to remain valuable for companies. If the review process becomes too lengthy, participants noted that companies may choose to pursue alternative filing strategies rather than utilize the framework. As a result, many suggested that timelines, expectations, and deliverables be clearly communicated to all participants.
Participants also identified several enhancements for the questionnaire. Suggestions included adding sections addressing actuarial considerations, technological requirements, tax implications, and other information needed to evaluate complex product concepts. Some attendees recommended establishing a gatekeeping mechanism to ensure that submissions are sufficiently developed before entering the process and to help manage regulatory resources effectively.
Additional discussion focused on the value of regulator participation and information sharing. Participants suggested identifying a point of contact within each participating state and involving appropriate subject matter experts throughout the process. There was also recognition that state feedback could help companies better understand potential concerns before filing and improve the likelihood of successful implementation.
During a Slido polling exercise, participants identified efficiency, uniformity, collaboration, and streamlined approval pathways for innovative products as among the most desirable outcomes of the proposed framework. Attendees generally agreed that facilitating communication among regulators and reducing unnecessary variation across states would provide meaningful value for both regulators and industry participants.
BREAKOUT 3 TOPICS AND DISCUSSION
DISCUSSION QUESTIONS
- What strategic issues should the Compact prioritize?
- How can the Compact improve current processes?
- What future challenges and opportunities should be considered?
Discussion during the third breakout session focused on the Compact's current activities and opportunities for future improvement. Participants discussed situations where standards may not explicitly address a product concept and explored how the Compact could help identify when new standards development may be warranted. Some attendees noted that innovative product concepts can reveal gaps in existing standards and provide opportunities for future regulatory development.
Education and training emerged as a recurring theme. Participants emphasized the importance of providing training opportunities that help regulators keep pace with developments in the insurance marketplace. Several attendees noted that the Compact is uniquely positioned to facilitate education for regulators, companies, and other stakeholders due to its expertise and nationwide perspective.
The role of artificial intelligence was also discussed. Participants recognized that insurers are increasingly incorporating AI and other technologies into their operations and product development activities. Attendees noted the importance of understanding how these developments may affect regulatory review processes and consumer outcomes. Discussion included how regulators can remain informed regarding technological changes and how the Compact can help prepare states for an increasingly technology-driven marketplace.
Participants also discussed opportunities to improve efficiency through greater coordination of form and actuarial reviews. Several attendees suggested that closer alignment of these review activities could reduce delays and improve the overall filing experience. Transparency regarding what information is available to participating states and how reviews are conducted was also identified as an area of interest.
Additional discussion focused on the cost-benefit considerations associated with filing decisions. Participants noted that companies continue to evaluate whether to pursue Compact or state-based filings and suggested that additional guidance regarding filing options may be beneficial. The Compact's fee structure and its relationship to potential future services were also discussed.
Slido polling results indicated strong interest in issues related to expedited implementation, uniformity, efficiency, streamlined review processes, consumer benefits, transparency, and resource limitations. Participants generally agreed that maintaining a consistent and efficient regulatory framework remains an important objective for the Compact.
GROUP DISCUSSION
During the group discussion, many of the themes identified in the breakout sessions were revisited. Participants agreed that the proposed framework could provide a useful mechanism for discussing innovative products and concepts before significant resources are invested in formal filings. At the same time, attendees emphasized that the value of the process would depend on maintaining confidentiality, establishing clear expectations, providing meaningful feedback, and preserving speed-to-market advantages.
There was broad agreement that education and communication remain important functions of the Compact. Participants discussed opportunities to expand regulator training, improve coordination among regulators, and help states keep pace with rapidly evolving products and technologies. The role of artificial intelligence was also discussed, with several attendees noting the need to anticipate how technological developments may affect both the insurance marketplace and regulatory review processes.
Participants expressed continued support for the Compact's centralized review model, citing its efficiency, accessibility, and expertise. Discussion highlighted opportunities to improve pre-filing communications, enhance coordination between form and actuarial reviews, expand expedited review capabilities, and continue exploring innovation-focused services. Overall, attendees viewed the proposed framework as a promising concept that warrants further development and refinement.