Supporting Documentation Update Purpose Reminder
In early 2017, the Insurance Compact announced a new type of filing submission, the Supporting Documentation Update, via Filing Information Notice 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings (FIN 2017-1). This new filing type was created to make the amended filing process uniform for all filers.
All amendments that are outside the requests to update the Statement of Intent (SOI), add a state to a filing submission, fix a typographical error that does not alter the meaning or intent of the language in the forms (e.g. correcting "contact owner" to "contract owner"), or to submit a foreign language translation, must be filed as detailed in FIN 2017-1.
The Supporting Documentation Update (SDU) is a filing type that may be used to make certain amendments to filings that have already been approved by the Insurance Compact. Common SDU submissions include:
- Updating the format in which an application will be used;
- Amending a Statement of Variability to add one or more new variable items;
- Revising nonforfeiture compliance for both mortality table and interest rate;
- Changing the maximum expense charge or minimum interest rate for UL products;
- Changing the issue age range or minimum specified amount for life products;
- Making updates related to the index used to determine the credited rate for indexed annuity or UL products.
A good principle to keep in mind is to review the Variability section of the Uniform Standards to identify which items require an approval in order to vary, may be varied within approved range, or may vary without notice.
As a reminder, SDU filings are not appropriate to change variability so extensively that new forms and or products are created. This would require a new form submission and, if applicable, actuarial review.
It is important to note that only the states included in the original filing that is tied to the SDU submission via the Associated Filings feature should be included in the SDU filing submission. The filing fees for the SDU submissions are little different than for a normal submission. We would strongly advise that you pay close attention to Appendix B of FIN 2017-1. The fees shown on Appendix B have been vetted by the applicable states.
If you have any questions regarding the Tip this week, or FIN 2017-1, please contact the Insurance Compact Office