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This tip is the first in a series about best practices in using the Associated Filings feature in the new SERFF platform. The feature now has expanded capability to better pinpoint the ways components of a product are connected.

As a baseline concept, the purpose of associated filings is:
(1) Identify the components of a product, and
(2) Assist review by denoting forms that are similar to the new submission.

The key to remembering which prior filings to associate is to include only those filings with a direct relationship to the new submission. Think about how the reviewer will understand the new filing and its relationship to other components, or prior versions, of the product.

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. The new rider filing should be associated with the base contract form. In contrast, a 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 (1) the approved version of the policy form, and (2) 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.

Associating only those filings that have a direct relationship to the new submission will improve the information in your filing and minimize work in preparing the filing. If you are too conservative in adding associated filings, the reviewer or actuary may ask you to provide additional associations during the course of review. That is normal and based on the substance of the review. The best practice is to limit associated filings to those with a direct relationship to the new submission.

Next week we will reveal how to make the direct relationship between filings and forms even stronger using the updated feature in SERFF.

If you have any questions, please reach out to the Compact Office via comments@insurancecompact.org.