Updating Previously-Approved Compact Products
With the 2017 CSO Mortality Table transition entering final stages and 2019 projects underway, a refresher on how products filed with the Insurance Compact can be revised is in order. In this weekly tip, we re-visit Filing Information Notice (FIN) 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings and related resources for determining what is required to update to a Compact filing. FIN 2017-1 applies to the revisions of all individual and group product filing submissions, except for Long-Term Care advertising.
To determine what type of action, if any, is required to update a Compact filing, filers should answer the following three questions:
- How old is the filing being revised?
-The filing being revised has been approved for 90 days or more
-The filing being revised is pending review, or was approved within 90 days
- What type of revision or update is required?
The following are some possible types of updates:
-Adding a state
-Correcting a Typographical Error (does not change the meaning of sentence or provision)
-New form on the form schedule
-Changing static language
-Changing language that was marked as variable
-Revision to forms already marketed or issued
- Has the form/product already been marketed or issued?
Armed with the answer to these three questions, filers can utilize FIN 2017-1 to determine how to make the update, whether a new filing is necessary or if the approved filing can be reopened, and whether a fee is required to make the change. Appendix A of FIN 2017-1 contains a useful chart that indicates the process and requirements for revisions to forms and supporting documentation, sorted by the type of revision or update.
To help you understand and apply the criteria regardless of the type of filing or revision you want to make, the Insurance Compact has transparent and well-documented guidelines for updating product filings. Here is a roundup of resources the Compact has published about updating products:
- FIN 2017-1. This is your go-to reference. Most questions we receive about re-opening filings or making changes to approved filings are answered in FIN 2017-1. It addresses revising pending and approved Compact products, as well as state fees due for Supporting Documentation Update filings.
- Frequently Asked Questions about FIN 2017-1. This is another resource about revising Compact products, in Q&A format. It is located on the Insurer Resources page and the Filing Information Notices index.
- Weekly Tips on FIN 2017-1. By entering ?2017-1? in the keyword search box on the Weekly Tip Archive page, you find eight tips specific to different aspects of revising Compact products.
- FIN 2016-1. This reference details options for implementing the 2017 CSO Mortality Table for Compact products.
- Webinar on FIN 2016-1. These webinar slides are such an important resource for filers we gave them permanent home on the website, on the Insurer Resources page and the Filing Information Notices index.
If, after reviewing these resources, you would like to confirm the correct course of action with the Insurance Compact Office, please submit your inquiry to firstname.lastname@example.org and use the Pre-Filing Communication process to ask about uniform standards applicable to the revision being made.