Ready for Review - Actuarial Components

This week, we continue the series to help you determine whether your filing submission is ready for review. Ready for review means the filing contains all attachments, certifications, and filing components necessary to perform substantive review.

This week we will focus on the actuarial components of a filing submission. We would encourage you to forward this tip to your company’s actuaries.

Are you unsure of how to tell whether your Compact product filing requires an Actuarial Memorandum? The best way to be certain whether actuarial review of an Insurance Compact filing is required is to look at the applicable Uniform Standards for an Actuarial Submission Requirements section. If the Uniform Standards do not contain this section, actuarial review is not required. You can double-check this determination by consulting the tool specifically designed to list Uniform Standards Without Actuarial Review. This tool is published to the Insurer Resources page of the Insurance Compact website. This is important as Compact filing fees vary by whether actuarial review is required and attaching an actuarial memorandum to a submission when not required or not submitting an actuarial memorandum when required automatically generates an objection. Please note that it is possible for more than one Uniform Standard to apply to a filed product; if unsure, you can check the scope sections of the Uniform Standards.

Did you know that the Insurance Compact has different requirements for an actuarial memorandum than the states? Submitting a boilerplate actuarial memorandum will generate objections in SERFF and a delay in the approval. Company actuaries should refer to the Actuarial Requirements section in the applicable Uniform Standards when drafting the actuarial memorandum for a Compact product filing. The Compact actuaries use the applicable Uniform Standards as a checklist when conducting the actuarial review. All actuarial requirements listed in the Uniform Standards must be satisfied to achieve compliance.

Are your actuarial documents consistent with the rest of the filing? It is important to make sure that all actuarial memorandums submitted are consistent with the components of the rest of the filing such as Policy Forms and Statements of Variability.

Answering these questions and utilizing the resources in this tip will help to avoid time-consuming or easily avoidable objections. If you or your company actuary have any questions about the preparation of actuarial materials for a Compact product filing, submit a completed Pre-Filing Communication Form. Your pre-filing questions will then be routed to the appropriate members of the Compact Review Team and answered via email or conference call, if necessary.

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