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The April 3rd effective date for amendments affecting all individual life insurance policy Uniform Standards is quickly approaching. This Weekly Tip provides guidance on compliance for new policies filed on or after April 3rd.  This Tip restates the filing options provided in Filing Information Notice 2023-1.  

For new product filings, a filer has several options to demonstrate compliance with the amendments:

1. Include the suicide provision amendment language in policies for approval. This option is the traditional method of writing the suicide exclusion period into the policy. Language should appear in the specific suicide provision of the form reflecting “The suicide exclusion period shall not exceed two years from the date of issue of the policy or any shorter period as may be required by applicable law in the state where the policy is delivered or issued for delivery.” The company then administers the uniform provision(s) in accordance with state law.
    
2. File separate policies, one that reflects a 2-year suicide exclusion period and another policy that reflects a 1-year suicide exclusion period.  Make sure to communicate in the filing information which form will be issued in which states. Note, state fees are due for all included states for all forms regardless of the states each policy will be issued in. Therefore, the company should consider submitting the policy with a shorter exclusion period in a separate filing containing only the applicable states.
    
3. Bracket as a variable item the suicide exclusion period within the form (this is an exception to the requirement that variability is limited to the specifications page), and in the statement of variability provide a range for the exclusion period accompanied by the explanation “or any shorter period where required by applicable law in the state where the policy is delivered or issued for delivery.”
    
4. Bracket as a variable item the suicide exclusion period on the specification page and include a range in the statement of variability accompanied by the explanation “or any shorter period where required by applicable law in the state where the policy is delivered or issued for delivery.”

Amendments to the suicide exclusion period requirement apply to initial coverage, reinstatements, policy exchanges and any policy increases.  Please review FIN 2023-1 for further filing guidance when making your Compact submissions.