Weekly Tip: From the Archives - Application Process FAQ

Weekly Tips

From the Archives - Application Process FAQ

11/8/19

Did you know that we publish the prior month?s weekly tips to our online Weekly Tips Archive at the beginning of each month? The archive is searchable by keywords, or you can filter by year and/or category. Over the next few weeks, we will re-publish a few of our most frequently cited weekly tips from the archives. Stay tuned!

Applications are the form most commonly submitted for review and approval to the Insurance Compact. Approximately half of the submissions made this year include an application, and we receive a number of questions about application submissions. This week, we will address a few of the more commonly asked questions about processes related to application submissions. 

Q: Does the Insurance Compact require screenshots?

A: Not if the application questions and the answer format are the same across versions. If drop-down choices in electronic format vary from paper choices, they should be attached to Supporting Documentation.

Q: Does the Insurance Compact require wet signature following telephonic or electronic application?

A: No. The Uniform Standards call for the company?s signature verification process to be described. A paragraph is sufficient. As an example, see Section 1.A(10) of the Individual Life Insurance Application Standards (IIPRC-L-I-APP), which states: ?For electronic and telephonic uses, the company shall describe the procedures that will be used to verify the authenticity of the transaction.?

Q: How does the company filer update an approved filing to reflect the use of an additional format?

A: (Updated for compliance with FIN 2017-1) If there is a change to the format of the application or the company?s procedures to verify the authenticity of an electronic or telephonic transaction, either an amendment or Supporting Documentation Update (SDU) filing is required to update compliance with the Application Use submission requirement. Per Filing Information Notice 2017-1, if a filing was approved fewer than 90 ago, the filing can be reopened to amend the application use section. If the filing has surpassed the 90-day threshold that would allow it to be reopened for certain changes, you can update the filing for the electronic application process by submitting a new Supporting Documentation Update (SDU) filing, provided there are no changes to the form(s). Create the new filing, provide the necessary Supporting Documentation, including application use, and associate the original filing(s) to the new SDU filing. Both methods require Compact filing fees. An SDU filing may also require state filing fees; for more information, please see the Member State Supporting Documentation Update Fees chart published on the Insurer Resources page of the Insurance Compact website.

Q: Do reflexive questions need to be filed for approval?

A: Yes. Section 1A(5) of the Individual Life Insurance Application Standards provides, ?The filing shall include all the sections and questions that may be required to be completed by an applicant, including additional drop downs, scripts, questions, questionnaires or supplements that would be required if the applicant answers questions in a certain way, such as a ?yes? response.? This provision is common across all Uniform Standards for applications.

Q: Can reflexive questions be revised without re-filing?

A: No. Revisions to reflexive questions are subject to prior approval per Section 1A(5). If reflexive questions are attached to the filing as supporting documentation, revisions to reflexive questions can be submitted without re-filing the Form Schedule items for review.

If you have any other questions about the applications, please let us know. For more specific product development questions, please use the Pre-Filing Communication Form found on the Insurer Resources page of the Insurance Compact website.