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Pre-Filing Communication Process Reminders

As we start the new year, this is a great time to refresh filers on the purpose and process of making pre-filing communication requests.  The Compact encourages filers to submit questions regarding compliance with uniform standards or appropriateness of filing specific product features through the Compact as pre-filing communication requests.  These requests are to be made on the "Pre-Filing Communication Form" which can be accessed electronically through the Compact website under Industry Resources/Creating A Compact Filing/Pre-Filing Communication Form.  The form is an interactive pdf and can be completed electronically.  As the prefiling communication process is to discuss questions and issues regarding a potential Compact product filing, Compact registration is generally required to make these requests.  

When completing the form, please make sure to complete all fields in their entirety paying special attention to the section asking for specific issues or questions you wish to address. As this is the purpose of the form, if these fields are left blank or do not include enough detail in which to provide thoughtful responses, the Compact will require that additional information be provided before the request can be considered.  Please remember to complete the form from both a form and actuarial perspective if actuarial issues are involved.  If a call is requested to discuss an issue with Compact staff, sample language and or forms are required before any call can be scheduled.   The completed form should be submitted via email to comments@insurancecompact.org.  Please be advised responses to pre-filing communication requests are based on the information provided by the Company and should not be interpreted to mean approval of the product.  Any forms submitted to the Compact for review and approval will be subject to form and actuarial compliance review. 

Questions on fees, SERFF, or help desk questions do not require completion of the Pre-Filing Communication Form and can be sent as an email inquiry to comments@insurancecompact.org.  

Pre-filing communication requests are now housed on the JIRA platform.  All responses to requests will be sent from 'Insurance Compact Filing Support jira_no_reply@naic.org' or a specific Compact team member's name with jira_no_reply@naic.org after. To ensure you are receiving responses from JIRA, please make sure your security settings are such that emails from the JIRA address are permitted.  This is important as some filers are not receiving responses due to email security settings.

If you have any questions regarding this week's tip, please contact the Insurance Compact Office.

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