Newsletter

Greetings from the Compact! Thanksgiving is on Thursday, and we’re reminded of the power of community and collaboration. This season, we are especially grateful for our 48 member states whose dedication and partnership make our shared mission possible. Together, we’ve built a network that strengthens our work and amplifies our impact across the nation. Thank you for being an essential part of this journey.

As we near the end of the year, there’s still important work ahead. Chief among these is our Management Committee call on December 2. The Annual Meeting of the Commission is scheduled for Wednesday, December 10 at 10:30 a.m. ET in Hollywood, FL. Prior to that, a Joint Meeting of the Management Committee and Legislative Committee will begin at 10:00 a.m. ET. All Commission members and legislators attending the NAIC Fall National Meeting are welcome to participate. Full agendas for both meetings are available on the Events page of the Compact website.

Do you want a quick overview of what’s on each meeting’s agenda? The Compact Office is hosting regulator-only prep calls to get ready for all three December meetings—and there’s still time to register! Visit the Events page for details. Prefer to catch up later? Log in to NAIC Connect to watch the recording on demand. (Note: NAIC Connect is for regulators only.)

Earlier this month, the Compact Officers hosted their eighth Roundtable event in Omaha, NE on November 5. We extend our sincere thanks to Commissioners Grant and Pike, Directors Dunning, Dwyer, Deiter, and Nelson, along with regulators from Arizona, Connecticut, Delaware, Iowa, Maryland, Nebraska, North Dakota, Ohio, South Dakota, Vermont, and Washington, as well as consumer and industry representatives for their participation. A high-level recap of this important discussion is included in this issue.

We are grateful for the opportunity to serve our members, and we are here to provide whatever support they need.

Vignette 1 – Company discusses new product.

Company representatives emphasized the importance of introducing Compact standards early in the product development process to minimize state-by-state variations. Companies often involve marketing, legal, actuarial, underwriting, and compliance teams early, while administrative systems teams join later. Some companies prefer filing through the Compact when standards exist, as it reduces complexity and accelerates speed to market. However, for regionally tailored products or features outside existing standards, companies may still pursue state-by-state filings. Overall, the vignette reflected real-world practices and highlighted the value of proactive engagement with regulators.

Vignette 2 – Company meets with Compact Office.

This vignette focused on pre-filing communications. Companies see pre-filing as a way to identify objections early and avoid wasted effort on product designs that may not be viable. They appreciate the opportunity to “float” ideas and receive feedback before committing resources. Regulators noted that when they have a pre-filing conversation with the company, it helps them collaborate and share consistent guidance, but they stressed that companies should research state law and regulations first to make discussions productive. Confidentiality emerged as a major concern, with companies worried about sharing proprietary information too soon and questioning which laws would protect trade secrets during this process.

Product Standards Committee

The Products and Standards Committee (PSC) convened on November 18 to continue discussions on proposed amendments to the Individual Deferred Paid-Up Non-Variable Annuity Standards. The PSC also reviewed ACLI’s November 17 comment letter on the amendments to the Accidental Death and the Accidental Death and Dismemberment uniform standards. The PSC asked the Compact Office to draft proposed language for review.

The next PSC call is scheduled for December 2.

Dan is the Director of Regulatory Affairs and Counsel for the Interstate Insurance Product Regulation Compact (Insurance Compact). Dan is responsible for developing and overseeing strategies that align with member goals and promote robust member engagement and collaboration.

Prior to joining the Insurance Compact, Dan served as Assistant General Counsel to the Ohio Department of Insurance. In this role, Dan was responsible for managing a team of attorneys that supported the Department’s various divisions, including the Office of Product Regulation and Actuarial Services, Consumer Services, Market Conduct, Policy and Legislation, and the Office of the Executive. During his time with Ohio Department of Insurance, Dan was actively involved in representing the Department with the NAIC and Insurance Compact.

Dan began his career in private practice in Cincinnati, Ohio before taking on an in-house role with a large general agency. Dan earned his Bachelor of Science in Business Administration from Xavier University and a law degree from Northern Kentucky University.