What to Include in the Filing Description
In this week?s Weekly Tip, we are offering suggestions about information to include in the Filing Description field on the General Information tab of an Insurance Compact filing submission. Many filers appropriately address requirements such as application format and applicable Uniform Standards in the Filing Description. However, we sometimes receive a single sentence to describe a full product filing, which leaves our reviewers searching for more information. The intent of today?s guidance is to provide insight into the details that Insurance Compact reviewers expect to find in the Filing Description that are not necessarily covered elsewhere in the filing submission. A comprehensive Filing Description can save the reviewer time in understanding and reviewing your filing submission.
The SERFF General Instructions state:
Please use the Filing Description in SERFF as your Cover Letter. The Filing Description should provide a detailed explanation of the product, including whether the product will be marketed with or without an illustration. Please review the Additional Submission Requirements section of the Uniform Standards applicable to your filing and include any required additional information in the Filing Description. If you require additional space, the Filing Description may be continued in a separate document and attached to the Supporting Documentation schedule on the filing.
In addition to this guidance, the Review Team suggests using the following questions when preparing your Filing Description to make the review more efficient:
- Include a short, 1-2 sentence description of each form or product in the filing. For example, ?low face amount ($5,000-$25,000) guaranteed issue term life policy, level term for 15, 20, or 30 years.?
- Do not attach a Cover Letter elsewhere in the filing unless you are submitting new LTC advertising material.
- How are the forms in the filing being used? Explain the intended use of forms in the filing with (1) Compact-approved components (Associated Filings) and (2) State-approved components (Statement of Intent). We appreciate detail on which forms in the Associated Filings are connected to the new filing.
- Is a rider in the filing to be used with policies that are not in the same filing, and only for new issues? Uniform Standards for benefit features require the filing to indicate if a rider will be (1) used with new business, existing business or both, and (2) available at issue, after issue or both.
- Even if not replacing a previously approved filing, is the product similar to a previously approved product? If so, identify the approved filing by tracking number and state the major differences between products. This saves reviewer time in figuring out what, if anything, is different from a product that is already in compliance with applicable Uniform Standards.
- Include e-mail and telephone contact information for the lead filer if different than the information provided on the Companies and Contacts tab.
If you have any questions about this Weekly Tip or the Compact, please contact the Insurance Compact Office at Comments@insurancecompact.org.