Amending Approved Forms Under FIN 2017-1
Continuing the series of Weekly Tips based on the new Filing Information Notice ? FIN 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings (FIN 2017-1) ? issued on March 9th, we will review how to submit revisions to filings that have been closed within 90 calendar days, provided the forms have not been marketed or issued. This process is covered in Section I.D of FIN 2017-1.
Outside of the amendments to filings as detailed in Section I.C in the FIN (e.g. SOI updates, add a state, Foreign Language Translation inclusion, typographical error corrections, etc.), amendments to a form marked as ?Approved? may be made within 90 calendar days of the disposition, provided the form has not been marketed or issued. Specifically, the request to re-open the approved filing must be submitted within 90 calendar days of the filing?s ?Closed-Approved? disposition. Any filing re-opened at the filer?s request will remain open for 10 business days for the revised material to be submitted. If the filer does not update the filing per the request within 10 business days from when it is reopened, the filing will be closed for inaction.
To amend a form within a ?Closed-Approved? product filing, the filer shall submit a detailed Note to Reviewer requesting that the filing be re-opened. In this detailed Note to Reviewer, the filer will need to describe the proposed revisions to be made and the parts of the filing affected. The amendment letter submitted with the revised form(s) must also include a statement that the form(s) being revised has not been marketed or issued. The revised form should replace the approved form on the Form Schedule and the form number should remain as approved. Insurance Compact amended filing fees are due for this amended filing scenario.
Revisions properly submitted using this process are generally reviewed on a more expedient timeline than a new filing submission. This process is not available for adding a new form to the Form Schedule of a closed filing. Likewise, any amendment to a form that has been marketed or issued requires a new product filing submission with new forms, new form numbers and Insurance Compact and state filing fees payable for a new product filing submission, even if the form being revised was approved within 90 calendar days. All of these points are covered in FIN 2017-1, Section I.D.
As the weeks progress, we will detail the various new procedures that filers will be expected to follow as of April 1st. Throughout the month of April, the Insurance Compact Office is also offering an all-new webinar for company filers to support compliance with FIN 2017-1. Please see the Event Calendar, located on the Insurance Compact website, for more information on session dates and times.
If there are any filing situations not addressed within the FIN, please contact the Insurance Compact Office. If you have any questions regarding the new FIN or the processes outlined, please contact the Insurance Compact Office.