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Basics of Filing Series Cont'd - Associating Filings

SERFF modernization has expanded functionality for associating related filings, providing greater context and meaning to filing relationships. Forms and supporting documentation associations can be provided at any time regardless of the SERFF status of the filing and allow to the filer to:

  • Specifically link a form in an associated filing to the new filing submission. 
  • State the reason for the association.

The key to remembering which prior filings and forms to associate is to include only those filings and forms with a direct relationship to the new submission.  A direct relationship exists when the form(s) in the pending filing will be used with forms in an approved filing, such as associating a benefit rider in the pending filing with the base contract(s) the rider will be issued with, or associating an application in the pending filing with the base contract(s) the application will be used to apply for the product. A direct relationship also exists when a form in the pending filing is replacing an approved form. This same reasoning applies to supporting documentation.

A brief statement in the Reason field provides context around why a form/filing is associated and saves reviewers time researching in associated filings. Providing your reasoning for the form association greatly assists form reviewers in comprehending the relationships of the associated filings, so including a meaningful statement in the Reason field will eliminate the need for follow-up.

An example of a meaningful Reason entry isRider form ICC24-56E493A18 will be used with contract ICC18-3256B85F." Please do not populate the Reason field with "N/A" or similar fillers.  

For example, assume you are submitting a new rider form. What prior filings have a direct relationship with the form in the new filing? 
The rider has a direct relationship with the base contract with which it will be used, therefore the new rider filing should be associated with the base contract form. In contrast, a previously approved tax-qualified endorsement for the base contract does not have a direct relationship with the new rider, nor would a different rider offered with the base contact that is independent of the new rider. Associations that are not directly related to the new submission create clutter in the associated filings.

Another example: If your new filing is a Supporting Documentation Update to change variability in an approved policy form, what prior filings have a direct relationship with the update being made?

The answer is:

  • The approved version of the policy form.
  • The filing containing the most recent update(s) made to the supporting documentation since the policy form was approved.
    In contrast, riders or endorsements that can be issued with the policy do not have a direct relationship with the Supporting Documentation Update and are likely extraneous.

If the Manage Associated Filings view is completed thoroughly and meaningfully, the information will not need to be duplicated in the Filing Description, saving the filer time and making the review more efficient.