Preparing for the Suicide Exclusion Period Amendments to take effect October 3rd – New Issues of Approved Products
As of October 3, 2023, new issues of Compact products approved prior to April 3rd will need to comply with the suicide exclusion period amendments. This Weekly Tip provides guidance so filers can ensure product compliance with these amendments. To demonstrate compliance, a filer can update products several ways:
- If the filing was approved within 90-days and no forms have been issued, the filing may be reopened for amendments on the approved forms. Follow the guidance set forth in the 3/3/23 Weekly Tip for ways to amend the forms.
- File a uniquely numbered endorsement form to change or add an exception to the suicide exclusion period. The applicable filing type for this form is Riders/Endorsements/Amendments. A single form can be used with multiple types of insurance. Keep in mind the applicable Uniform Standards for the filing are the applicable policy Uniform Standard (suicide provision) as well as the Additional Standards for All Benefit Features.
- Following the guidance in FIN 2017-1 for Supporting Documentation Update filings, create a new bracketed item for the suicide exclusion period to make it a variable value either within the product form provisions or as a new specification page item. A single filing can be made to use this option for multiple types of insurance.
a. A specimen copy of the form reflecting the new variable item should be provided under the Supporting Documentation tab along with a revised Statement of Variability of the form incorporating the new variable field stating the time period to be used will be a maximum of two years or a shorter numerical period, such as one year, where required by applicable law in the state where the policy is delivered or issued for delivery.
b. An addendum to the previously approved SOV may be submitted for the sole purpose of demonstrating compliance with the suicide exclusion period amendments. If any other update of any kind is being submitted with the suicide exclusion period update, a revised, complete SOV must be filed in accordance with Section II.C.2.b of Filing Information Notice 2017-1.
Amendments to the suicide exclusion period requirement applies to initial coverage, reinstatements, policy exchanges and any policy increases. Please review FIN 2023-1 for further filing guidance when making your Compact submissions.
If you have any questions regarding this Weekly Tip or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.