Weekly Tip – Trade Secret FIN

Did you notice the Compact Office published Filing Information Notice (FIN) 2024-1 pertaining to the Trade Secret process earlier this week? FIN 2024-1 details how filers may request a Trade Secret treatment for certain information submitted in a Product Filing to the Compact. The FIN may be found on the Industry Resources page of the Compact website, specifically under the Filing Information Notice (FINS) header. 

The process detailed in FIN 2024-1 is not new. We see trade secret requests generally in rate review filings for long-term care and disability income insurance, and then only for the information supporting the company's assumptions underlying the rate schedule. Please note FIN 2024-1 includes the presumption that approved rates and forms themselves are unlikely to meet the definition of trade secret information in the Public Access Rule. The Compact Office would not expect to receive more trade secret requests as a result of this FIN; it was published to enhance transparency by gathering the procedural steps into one resource outside of SERFF.

All FINS are published in chronological order and are valuable tools for filers. All filers are strongly encouraged to review the FINS as they prepare filings for specifics to creating the product filings as well as providing additional interpretational guidance.

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