New Filing Type from FIN 2017-1 ? Supporting Documentation Update
Continuing on 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 cover revisions to filings that require a new filing submission using the new filing type ? Supporting Documentation Update.
Last week, the Weekly Tip addressed when companies need to make a revision to a filing that is within 90 calendar days of approval. This week, we will address the new process for making certain revisions past the 90-day calendar mark. To revise an item that is specifically permitted to change upon prior approval, the item must have been bracketed or otherwise marked to denote variability and included in the Statement of Variability in the Compact-approved filing submission. Should this scenario come up and revisions are required of supporting documentation such as the Statement of Variability, Actuarial Memorandum, or the Specification Pages, the company filer will be required to submit the revisions via Supporting Documentation Update. No forms are permitted to be submitted for review under the Supporting Documentation Update filing type. If new forms are being submitted or if static form language is being revised, a new filing with new form numbers must be submitted, as detailed in the Weekly Tip issued on March 23rd.
To submit a Supporting Documentation Update and revisions, select the corresponding TOI from the initial filing ? i.e. if the filing was made under L07I, then the revisions should be submitted under L07I as well. Once you have selected the proper TOI and sub-TOI, select Supporting Documentation Update as the Filing Type.
Remember: the proper selection of the Filing Type triggers the proper Submission Requirements.
Another reminder is to be sure to satisfy all Submission Requirements ? even a negative response is considered satisfying the Submission Requirement rather than bypassing it. Any updated supporting documentation shall be submitted under the appropriate Submission Requirements and it shall be complete. In other words, a revised Statement of Variability should contain all previously approved information still applicable and include the new, revised information. If the filing contains a new Statement of Variability, the filing shall also include a new certification that any change or modification to a variable item will be administered in accordance with the requirements in the Variability of Information section of the governing Uniform Standards. The Filing Description on the General Information tab in the filing needs to describe the items being revised from the approved Supporting Documentation. While the filer is not required to provide supporting materials highlighting the revisions in a redline format, it is helpful. All filers will be required to tie the new submission with the previously-approved submission utilizing the Associated Filings link.
As Mix and Match is not permitted, no information shall be provided on the Statement of Intent Schedule for the Supporting Documentation Update submission. Should revisions lead to updated information for the SOI, then the SOI in the original submission shall be updated to reflect this information. Compact filing fees are due for the new filing, as well as all applicable state fees.
Starting on Tuesday, April 4th the Insurance Compact Office will offer a webinar for company filers detailing FIN 2017-1 and the updates to the amended filing process. Information regarding this webinar may be found on the 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.