SUMMARY OF THE MAY 2025 DC COMPACT ROUNDTABLE
Prepared by the Compact Office
EXECUTIVE SUMMARY
The seventh Compact Roundtable was held on May 13, 2025, in Washington, DC, with 20 commissioners and regulators, one legislator, along with 24 company representatives, two industry association representatives, and one consumer representative to discuss the performance of the Interstate Insurance Product Regulation Compact, opportunities for continuous improvement, and potential approaches for supporting product innovation. Discussion focused on feedback regarding the Compact's current operations and consideration of a proposed Consultation and Advisory Services Office (CASO) framework pilot.
Participants consistently cited the Compact's speed-to-market benefits, centralized review process, reviewer expertise, and ability to provide a single filing pathway across multiple jurisdictions as key strengths. The efficiency and consistency provided by the Compact, along with the accessibility of staff and reviewers, were viewed positively by both regulators and industry representatives.
While support for the Compact remained strong, attendees identified several opportunities for improvement. Common themes included maintaining review turnaround times, increasing staffing and resources, accelerating Uniform Standards development, expanding training opportunities, and improving transparency regarding filing expectations and review processes. Participants also discussed the need for continued focus on emerging products and innovative product features that may not fit within existing Uniform Standards.
A significant portion of the Roundtable focused on the proposed CASO framework pilot. Participants generally supported further exploration of a collaborative process that would allow regulators and companies to discuss innovative products and product features before formal filing activity. Potential benefits included facilitating communication among states, leveraging subject matter expertise, identifying gaps in existing Uniform Standards, and informing future standards development efforts.
Attendees also emphasized the importance of clearly defining the framework's purpose, value, timelines, confidentiality protections, resource requirements, and relationship to subsequent state review processes. Industry representatives stressed that any framework should preserve the Compact's speed-to-market advantages and provide meaningful benefits to participating companies and states. Suggested review timeframes generally centered on 30 to 45 days.
Overall, the Roundtable reaffirmed strong support for the Compact's core mission while highlighting opportunities to enhance operational efficiency, accelerate standards development, strengthen stakeholder engagement, and explore new approaches to supporting innovation within the framework of state-based insurance regulation. Interest in further refinement of the CASO concept was evident throughout the discussions.
DETAILED SUMMARY
On May 13, 2025, Commissioners, regulators, company representatives, industry representatives, and Compact staff gathered in Washington, DC for the sixth Compact Roundtable discussion. The Roundtable focused on stakeholder feedback regarding the Compact's current operations and explored potential frameworks for addressing product innovations that fall outside existing Uniform Standards. A significant portion of the discussion centered on the proposed Consultation and Advisory Services Office (CASO) framework pilot and opportunities for continued modernization of Compact processes.
Participants engaged in breakout sessions and group discussions designed to identify strengths of the current Compact system, opportunities for improvement, and considerations for future initiatives. Across all discussion groups, there was broad agreement regarding the value of the Compact's centralized review process, expertise, and efficiency. At the same time, stakeholders identified opportunities to strengthen communications, staffing, standards development, and innovation pathways.
BREAKOUT 1 TOPICS AND DISCUSSION
DISCUSSION QUESTIONS
- What works well today within the Compact process?
- What can the Compact do more of, less of, add, change, or improve?
- How can the Compact continue to support innovation while maintaining efficiency and consistency?
What Works Well
Across the breakout groups, participants consistently cited the Compact's ability to provide a single filing pathway for multiple jurisdictions as one of its greatest strengths. Companies noted the significant efficiency gained by avoiding separate state-by-state filings and emphasized that speed-to-market remains a primary reason for utilizing the Compact. Several participants also highlighted the value of expedited review programs and expressed interest in continued expansion of those capabilities.
Many attendees praised the expertise of Compact reviewers and staff. Stakeholders noted that the Compact provides access to specialized product review expertise that may not exist within individual state departments of insurance. Regulators observed that the Compact's review process allows states to leverage expertise and conserve their own resources while still receiving high-quality product reviews. Participants also cited the consistency of Compact reviews as an important benefit.
Communication was another frequently cited strength. Participants referenced the accessibility of Compact leadership and staff, the usefulness of member state calls, industry webinars, weekly communications, and the ability to contact reviewers to obtain clarification during the filing process. Some companies noted that pre-filing communications and direct dialogue with staff can help resolve questions and facilitate filings.
Opportunities for Improvement
A common theme across groups was the need for additional resources and staffing. Participants expressed concern that review timelines may be increasing and suggested that additional personnel could help maintain service levels and support increasing filing volumes. Industry representatives emphasized that they would support increased resources if those resources improved review timeliness and maintained the Compact's speed-to-market advantages.
Stakeholders also discussed the need for expanded education and training opportunities. Suggestions included training programs for newer regulators and industry participants, greater education on the Uniform Standards development process, and more frequent communications regarding emerging issues, filing expectations, and new standards. Several attendees emphasized the importance of ensuring that states remain knowledgeable about newly adopted Uniform Standards and evolving product designs.
Numerous attendees advocated for faster development of new Uniform Standards. Participants indicated that emerging products and evolving market conditions frequently move faster than the standards development process. Some expressed concern that innovative product concepts often cannot be accommodated under current standards, requiring carriers to pursue state-by-state filings. Suggestions included developing standards more quickly, using broader stakeholder participation during drafting, and creating mechanisms for addressing innovative product features while formal standards are under development.
Several attendees also raised questions regarding review processes, objection handling, and appeals procedures. Participants indicated that additional transparency around escalation paths, decision-making authority, and opportunities to challenge review determinations would be beneficial. Some companies expressed a desire for a clearer process when disagreements arise regarding interpretation of standards or review outcomes.
Innovation remained a recurring theme throughout the discussions. Examples identified by participants included long-term care insurance products, pension risk transfer products, contingent deferred annuities, group products, and products incorporating innovative benefit designs. Attendees discussed the challenges associated with introducing new features when existing Uniform Standards do not directly contemplate the proposed approach.
BREAKOUT 2 TOPICS AND DISCUSSION
DISCUSSION QUESTIONS
- What parameters should be considered for a CASO framework pilot?
- What value would such a process provide to regulators and companies?
- What challenges or concerns should be addressed before implementation?
General Concepts and Objectives
Participants discussed a proposed Consultation and Advisory Services Office (CASO) framework intended to facilitate collaborative conversations between regulators and industry regarding products or product features that may not fit squarely within existing Uniform Standards. The concept generally focused on products within the Compact's existing lines of authority, including life insurance, annuities, long-term care insurance, and disability income products.
Many attendees viewed the concept as a potential opportunity to enhance communication among regulators, companies, and subject matter experts. Regulators noted that a collaborative process could provide earlier visibility into developing products and emerging marketplace trends. Participants also suggested that the process could help identify areas where Uniform Standards may need modification or expansion.
Several stakeholders discussed the possibility of using the framework as an intermediate step while standards are being developed. Participants suggested that structured discussions between states and companies could improve understanding of product features, identify potential regulatory concerns earlier, and provide information useful to future standards development efforts.
Benefits Identified by Participants
Supporters of the framework noted that it could provide states with access to expertise and collaborative discussions that may not otherwise occur. Some regulators indicated that participation in multi-state discussions could improve consistency and reduce duplication of effort. The process was also viewed as a potential method for highlighting deficiencies, gaps, or ambiguities within existing standards.
Participants observed that a consultative framework could facilitate broader conversations regarding innovative features and allow companies to receive feedback from multiple states simultaneously. Several attendees believed that the process could provide valuable insights regarding the likelihood of state acceptance and identify key issues before a company commits significant resources to filing efforts.
Questions and Concerns
Although there was interest in the concept, participants identified numerous practical questions that would require resolution before implementation. These included confidentiality protections, treatment of proprietary information, applicable fees, staffing requirements, timelines, expected deliverables, and methods for documenting outcomes. Stakeholders emphasized the need for clearly defined expectations and transparent procedures.
Companies questioned how participation would create measurable efficiencies if a product would ultimately still require separate state approvals. Some participants noted that speed-to-market remains one of the Compact's greatest strengths and expressed concern that an additional advisory process could inadvertently slow product development and implementation efforts.
Participants also discussed whether the process should be voluntary and how recommendations would be used by participating states. Several attendees stressed the importance of ensuring that participation does not unintentionally create adverse outcomes by drawing broader attention to issues that might otherwise be resolved through existing filing processes.
Questions were raised regarding the standards or benchmarks that would be used during any advisory review and how a recommendation would be developed when no applicable Uniform Standard exists. Participants also discussed the importance of maintaining state participation throughout the process and ensuring the availability of the appropriate subject matter expertise.
Timing and Process Considerations
Timing emerged as one of the most important considerations. Across multiple discussions, participants suggested that any advisory process would need to operate on an accelerated timeline to maintain industry interest and preserve speed-to-market benefits. Many attendees viewed turnaround times in the range of approximately 30 to 45 days as desirable and expressed concern that significantly longer timeframes could reduce utilization of the framework.
Participants repeatedly emphasized that the value proposition, workflow, deliverables, and expectations associated with the program would need to be clearly articulated before companies and states could effectively evaluate participation.
GROUP DISCUSSION
During the group discussion, many of the themes identified during the breakout sessions were revisited. Participants agreed that the Compact continues to provide substantial value through centralized reviews, reviewer expertise, communication, and efficiency. There was broad support for maintaining and strengthening these core capabilities.
Stakeholders also discussed potential improvements to the Uniform Standards development process. Suggestions included establishing maximum development timelines for certain stages of the process, expanding stakeholder participation in drafting discussions, utilizing industry working groups, and ensuring broad engagement among companies, regulators, and consumer representatives. Participants generally recognized that product complexity should remain an important consideration in determining appropriate development timelines.
The discussion also included consideration of a more formal appeals process for Compact review determinations. Participants discussed possible approaches for escalation, oversight, transparency, and timing. Attendees emphasized the importance of clear expectations and efficient procedures that allow companies to evaluate whether further review is warranted.
Regarding CASO, participants generally viewed the concept as worthy of additional exploration but emphasized the need for careful design and clear incentives for participation. Many believed that the initiative could serve as a useful avenue for innovation, education, and future standards development if concerns regarding timing, confidentiality, staffing, state participation, and overall value can be effectively addressed.
Overall, the Roundtable discussions demonstrated continued confidence in the Compact's mission and operations while highlighting opportunities to enhance innovation pathways, strengthen stakeholder engagement, accelerate standards development, and maintain the speed and consistency that participants view as central to the Compact's success.