Montana Law Change - How to Address in Previously Approved Compact Filings
In September, the Insurance Compact Office issued Filing Information Notice - FIN 2021-2: Filing Process for Product Filings that Include Montana to Address the Amendment of § 49-2-309, Montana Code Annotated. This FIN provides guidance on the filing steps companies may take to begin issuing Compact approved products in Montana on a sex-distinct basis, beginning no earlier than January 1, 2022. FINs are published on our website on the Industry Resources page under Filing Reference Materials, and the Insurance Compact home page in the Links section.
Key points for applying FIN 2021-2 for products previously approved by the Compact:
- None of the items in the originally approved filing should be revised or replaced, including changing any of the actuarial material, statement of variability or the information contained under the Sex-Distinct or Unisex Policies submission requirement.
- Attach an amendment letter in the applicable form filing to provide the required documentation.
- If a company chooses to continue to issue approved products on a unisex basis in Montana after January 1, 2022, no filing action is required by the company.
- A company may continue to issue approved products on a unisex basis in Montana as well as introduce sex-distinct products in Montana after January 1, 2022. The documentation called for in FIN 2021-2 may include that the company may continue to issue products on a unisex basis in Montana for plans subject to the Norris decision or otherwise.
If you have any questions regarding the FIN or the Weekly Tip, please contact the Insurance Compact Office.