Updating Actuarial Memorandums in Response to Objections
Compliance team, please share this weekly tip with your actuaries.
This week's tip is a reminder that the actuarial submission requirements across the Uniform Standards are introduced with a requirement that the Actuarial Memorandum include the listed items. Filers sometimes respond to actuarial objections with explanation in the SERFF response letter only, or even with a separate response attachment, without also updating the relevant Actuarial Memorandum. This action often results in a follow-up objection to have the response added to the Actuarial Memorandum.
When responding to an actuarial objection, update the Actuarial Memorandum itself to include the information and do not send a response letter document. Sending a separate response letter makes the review more time-consuming and is not in compliance with the actuarial submission requirements. A summary of the changes made to address the objection can be provided in the Response Letter’s Comment in SERFF. Any explanations or additional information requested by the reviewing actuary to satisfy the Actuarial Memorandum requirements should be incorporated directly into the Actuarial Memorandum.
Note that for filings with rate reviews (LTC and DI), additional memorandum documents such as appendices or exhibits may be submitted either on the same line as the Actuarial Memorandum in SERFF or on separate lines on the Rate/Rule Schedule, so long as the additional documents are clearly labeled. For filings without rate review, all documents used to satisfy the Actuarial Memorandum requirements should be submitted on the same line with the Actuarial Memorandum under Supporting Documentation.