Introduction to FIN 2017-1
On March 9th, the Insurance Compact Office issued a new Filing Information Notice ? FIN 2017-1: Process for Revisions to Forms and Supporting Documentation in Compact Filings (FIN 2017-1). The purpose of FIN 2017-1 is to establish a consistent process for the submission of revisions to previously-approved filings with a disposition of ?Closed-Approved,? as well as unanticipated revisions to pending filings under review. This week, we begin a series of Weekly Tips to provide a detailed review of the filing process for revisions. FIN 2017-1 is effective on April 1, 2017, though companies are urged to start following sooner, if possible.
The first and most important tip is to ensure that all the information in a product filing is in final form at the time of filing. This includes not only form language, but the required actuarial documentation. Companies are strongly urged to use the interactive checklists found on the Rulemaking Record page of the Insurance Compact website, and strongly discouraged from filing a replica of a previous state-approved product or actuarial memorandum. The Insurance Compact offers other tools to facilitate a complete and compliant product filing and invites companies to submit a Pre-Filing Communication Form to ask questions about the Uniform Standards or the filing process.
The role of the Insurance Compact Office form and actuary reviewers is to ensure that each product filing complies with the applicable Uniform Standards. Therefore, revisions to forms and supporting documentation in response to substantive objections issued by reviewers are part of the normal review process and are not subject to FIN 2017-1. In other words, no additional Compact Product Filing Fees or state filing fees are due, even if the substantive objections lead to considerable changes in the form or actuarial documentation.
There are other common scenarios in which no additional Compact Product Filing Fees are due for updating a product filing. That is, the procedures for adding states to filings, correcting typographical or formatting errors, updating the Statement of Intent (SOI) Schedule in filings that include Mix and Match, along with the submission of the Foreign Language Certifications remain unchanged. A Note to Reviewer should be submitted describing the specific reason(s) for opening the filing. For example, a number was transposed, a word misspelled, or a section header was misplaced. The filing will be re-opened within 1 business day and will remain open for a period of 10 business days. Failure of the filer to make the amendment within that time frame will result in the filing being closed without change. Remember the tip to ensure that all information needed to update the product filing is ready before sending a Note to Reviewer requesting a reopening.
In the upcoming weeks, we will focus on other types of revisions or updates addressed in FIN 2017-1. 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.