Updating the List of Available Indices in Your Actuarial Memorandum
Companies that offer Compact-approved individual life insurance and annuity products with index features will want to pay attention to this Weekly Tip, in which we address the best practice for updating and adding to the list of available indices for a product.
All Uniform Standards for index-linked crediting and payment features for individual life insurance and annuity products call for the Actuarial Memorandum to describe the index or indices used. A list of the index names satisfies this requirement. Occasionally there are business, operational, or compliance issues that necessitate the changes in the index/indices information in approved filings ? for example, when the name of an index is changed, or the company wishes to add or substitute a different index.
A revision to the description of available indices used may be submitted using the Supporting Documentation Update Filing Type. Filers making a revision using this process may file an addendum to the Actuarial Memorandum for the sole purpose of updating the list of indices, instead of filing a complete Actuarial Memorandum. The Statement of Variability may be updated in the same new Supporting Documentation Update filing submission. Please see Section II.C.1 of Filing Information Notice 2017-1 regarding revising variable items that require prior approval. As with all Supporting Documentation Update submissions, the company filer is required to connect the original filing submission to the new filing submission using the Associated Filing feature.
While the filing does not include a complete Actuarial Memorandum, the Insurance Compact actuaries are required to review the addendum because the description of the index/indices is an actuarial submission requirement. Therefore, the filing fee for this new Supporting Documentation Update submission is ?Actuarial Review? - $1,250 for companies with greater than $50 million in reported premium volume, and $600 for those with less than $50 million in reported premium volume.
If you have any questions about this Weekly Tip or the Insurance Compact, please contact the Insurance Compact Office at Comments@insurancecompact.org.