FIN 2017-1 ? Marking Non-Variable Items as Variable in a New Filing
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, this week we will review revisions to make non-variable items variable in a new filing submission using the new filing type, Supporting Documentation Update.
At times, revisions are required to items that were not marked as variable at the time of initial submission. Section I.C.2 of FIN 2017-1 clarifies that an item in an approved form may be revised to become variable, provided that the item is permitted to be marked as variable pursuant to the applicable Uniform Standard(s). Bracketing an item to denote variability continues to be generally restricted to the specifications page(s) unless otherwise expressly permitted by the applicable Uniform Standard(s).
For example, Section 1C(6) of the Individual Whole Life Insurance Policy Standards states that the signatures of company officers ?may be denoted as variable and changed without notice or prior approval.? If one of the company officers has changed, but the company did not bracket the officer signatures in the approved forms, FIN 2017-1 clears the way for the company to submit revised forms showing the company officer signature block as variable so that different officer signatures can be shown on the issued forms as the need arises.
To add variability for an item in a form approved for at least 90 days, a new submission shall be made using the Supporting Documentation Update as the filing type. Please note that the Statement of Variability in the new filing must be complete and not limited to the variable items being revised. Because the revision applies primarily to the Statement of Variability, the form to which the bracketing is being added should be attached to the Supporting Documentation tab rather than the Form Schedule tab. In contrast, if there are also revisions to static form language beyond the revised bracketed information, the revised forms shall be submitted as a new filing rather than a Supporting Documentation Update filing.
If you would like more clarification on the new FIN, please join us for one of the remaining Webinar sessions for Company Filers, on Wednesday, April 12th, Thursday, April 13th, Monday, April 17th, or Wednesday, April 19th. During these webinar sessions, we will go into greater detail on FIN 2017-1 and the updates to the amended filing process. More information regarding this webinar, including session dates and times, may be found on the Insurance Compact Event Calendar.
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.