Expedited Review Process Pointers
Is your company interested in submitting a filing for Expedited Review? You can help ensure a smooth filing process with minimal correspondence by taking necessary steps on your end to ensure all aspects of the product filing comply with the Uniform Standards and filing rules. Before submitting your request to Expedited@insurancecompact.org, keep in mind the following points:
Does your filing have a feature you consider innovative or new to your products?
Keep in mind that not all product filings are conducive to the Expedited Review Process, especially if the company has not previously submitted a similar product for Compact review or if the product has features which require significant amount of back-and-forth between reviewers and filer. Please review the eligibility criteria to understand if the product filing is eligible for this process. If your product meets the eligibility criteria and has a feature the company is not certain fits cleanly within the applicable uniform standards, we strongly suggest submitting a Pre-Filing Communication to discuss with the Insurance Compact team in advance of product filing submission.
Is your filing as compliant as it can be, prior to submission?
Filings submitted for Expedited Review are expected to be predominantly ?clean? filings requiring minimal objections. We recommend that filers review objections received in similar approved filings to ensure that easy mistakes have been fixed prior to submission. The most common objection, even in the Expedited Review Process, is that the information in the actuarial memorandum, forms, and Statement of Variability are not consistent. Don?t forget to utilize our Best Practices checklist.
Is there currently a waiting list?
While companies should not avoid submitting requests for Expedited Review if there are a large number of filings on the waiting list, they should keep that number in mind when setting internal expectations for the review timeline. The Insurance Compact Office publishes an updated status of the Expedited Review Queue and waiting list on the Insurer Resources page daily. Additionally, companies on the waiting list to enter the Expedited Review Queue receive a weekly update regarding their place on the waiting list. The two-week anticipated review time estimated in the Expedited Review Process FAQ does not include time on the waiting list or upwards of three objection letters to achieve compliance.
Insurance Compact Resource Update
The good news is that we now have more reviewer resources. This week, the Insurance Compact Office welcomed Yada Horace as our newest Product Reviewer. Prior to joining the Compact team, Yada worked at the Alabama Department of Insurance for 13 years in a variety of roles, most recently as the Interim Life & Health Division Director. The Insurance Compact Review Team is delighted to have Yada join their ranks. In addition, Aimee Lawson is now reviewing product filings and coordinating filing intake as our Product Filing Specialist. With six product reviewers and three actuaries, the Insurance Compact team is working to be as responsive as possible to all filers, given the heavy workload associated with companies updating or filing new life products in advance of the January 1, 2020 deadline.
Even with the added resources and Expedited Review Process, the Insurance Compact Office strongly urges companies submitting product filings that incorporate CSO 2017 Mortality Table updates to file as soon as possible, and no later than September 30, as a prudent step to ensuring adequate time to review and respond to correspondence before this regulatory deadline.
If you are one of the few companies who still considers turnaround time as a determining factor in whether to file through the Insurance Compact or state-by-state, especially as the January 1, 2020 deadline approaches, keep in mind our commitment to working with filers to achieve compliance, and the post-approval benefits of having and maintaining a Compact-approved product compared to a product approved state-by-state.
If you have any questions about the Expedited Review Process Pilot, or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.