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Insurance Law

5 Simple Keys To Making An Interstate Insurance Compact Filing

   By: Sean Cox, First Consulting & Administration, Inc.

Have you been thinking about using the Interstate Insurance Compact to file your Life or Annuity product?  Are you curious what is involved in making the actual filing?  The following article will describe some tips for successfully submitting a “Compact Filing.”

Compact filings are made via the SERFF application, and the look and feel of the Compact Filing within SERFF is virtually identical to a typical form and rate filing with any other state.  However, there are a couple of differences.  Focusing on the following key areas can make creating and submitting your filing a very simple process.

1.    Getting Access:  Before you can make a Compact Filing you will need to contact the SERFF Helpdesk to be given filing authority for the Compact.

2.    Annual Fee:  This fee is paid to the Compact via an EFT (Electronic Fund Transfer) transaction through SERFF.  To pay this fee simply go to the “Create Filing” function in SERFF and select “Interstate Insurance Compact” as your state, and the SERFF application will walk you through the rest.  Note that this only applies when paying your annual fee.  All other form filings with the Compact will be made using the “Create Compact Filing” function.

3.    Statement of Intent (Mix and Match):  If you are filing a form with the Compact that will be used with other forms that have been previously approved in the individual states, then you’ll want to become very familiar with the Statement of Intent.  Completing this form is straight forward, and this form has now been incorporated into the SERFF application itself.  However, keep in mind that if you have an approved Compact filing, and at a future date you decide to add another state to that filing, then you will want to remember to go back and update this form to add the information pertaining to the newly added state.  Please note that there are no longer any time limitations on using Mix and Match.

4.    State Filing Fees:  Yes, you will still need to pay the applicable state filing fees for the states being filed through the Compact.  Make sure to closely review the filing fee chart on the Interstate Compact website.  You may find some surprising differences from what you are used to.  For example, some states that bill for their filings fees will now want them paid at the time of filing.  Also note that if you have more than one policy in your Compact filing, then most of the state fees, as well as the Compact fees, will be per policy, not per filing.

5.    Standards:  The Compact has created a detailed list of Standards for each applicable line of insurance.  The closer your product follows these Standards, the faster you will get to approval.

As you can see, the Compact filing process is very easy, and focusing on the five areas above will help to speed your Life and Annuity products on their way to approval in 36 jurisdictions (with Long Term Care coming soon)!

Sean Cox is Associate Consultant and Filing Unit Supervisor at First Consulting & Administration, Inc. He has more than a decade of experience with Form and Rate filings for group and individual life and health filings, property and casualty filings, and compliance matters, with an emphasis on SERFF filings. Mr. Cox studied history at the University of Missouri-Columbia.