Guaranteed Issue Mortality Tables
Earlier this month the NAIC adopted a revision to Valuation Manual-02 that changed the mortality table required to be used for minimum nonforfeiture standard values for guaranteed issue life insurance products in 2020. The change is to revert to the ultimate form of the 2001 Commissioners Standard Ordinary (CSO) Mortality Table and move away from the 2017 Commissioners Standard Guaranteed Issue (CSGI) Mortality Table. The change is mandatory for guaranteed issue life insurance policies issued after December 31, 2019. It is expected that the NAIC will develop and adopt a different CSGI Mortality Table in the future.
This change affects guaranteed issue life insurance products filed with the Compact if the product has been approved using the 2017 CSGI or 2017 CSO Mortality Tables for minimum nonforfeiture standard values.
Filers have several options for re-filing or updating the minimum nonforfeiture values of previously approved filings. To help you understand and apply the criteria regardless of the type of filing or revision you want to make, the Insurance Compact has transparent and well-documented guidelines for updating product filings. Here is a roundup of resources the Compact has published about updating products:
- FIN 2017-1. This is your go-to reference. Most questions we receive about re-opening filings or making changes to approved filings are answered in FIN 2017-1. It addresses revising pending and approved Compact products, as well as state fees due for Supporting Documentation Update filings.
- Frequently Asked Questions about FIN 2017-1. This is another resource about revising Compact products, in Q&A format. It is located on the Insurer Resources page and the Filing Information Notices index.
- Weekly Tips on FIN 2017-1. By entering ?2017-1? in the keyword search box on the Weekly Tip Archive page, you find eight tips specific to different aspects of revising Compact products.
- FIN 2016-1. This reference details options for implementing the 2017 CSO Mortality Table for Compact products. The guidance is applicable to any change in mortality table.
- Webinar on FIN 2016-1. These webinar slides are such an important resource for filers we gave them a permanent home on the website, on the Insurer Resources page and the Filing Information Notices index.
If, after reviewing these resources, you would like to confirm the correct course of action with the Insurance Compact Office, please submit your inquiry to firstname.lastname@example.org and use the Pre-Filing Communication process to ask about uniform standards applicable to the revision being made.
The Insurance Compact Office strongly urges companies submitting product filings that incorporate CSO 2017 Mortality Table updates to file as soon as possible, and no later than September 30, as a prudent step to ensuring adequate time to review and respond to correspondence before this regulatory deadline.