Filing With the Interstate Insurance Product Regulation Commission (IIPRC)

   By David Morris and Karen Schutter, Interstate Insurance Product Regulation Commission

The Interstate Insurance Product Regulation Compact ("Compact") is an important modernization initiative that is transforming the way asset-based insurance products are filed, reviewed and approved allowing consumers to have faster access to competitive insurance products in an ever-changing global marketplace. The Compact promotes uniformity through the application of uniform standards embedded with strong consumer protections.

The Interstate Insurance Product Regulation Commission ("IIPRC") serves as an instrumentality of its Member States by leveraging regulatory resources and expertise to establish uniform standards. These uniform standards are the foundation for the IIPRC's central point of electronic filing.

IIPRC began accepting filings in June 2007. At that time, there were only 26 Members and six uniform standards in the individual life line. It received 38 product filings in that first year.  IIPRC has experienced significant growth in three short years and now has 36 Members, 57 uniform standards for individual life and annuities and 82 registered companies.  Almost 400 product filings have been submitted to date, and many more are anticipated in 2010.

More Uniform Standards will be effective for filing soon.  Additional Standards for Guaranteed Living Benefits applicable for Individual Deferred Non-Variable Annuities and for Individual Deferred Variable Annuities, and Additional Standards for Guaranteed Minimum Death Benefits for Individual Deferred Variable Annuities become effective on June 3, 2010.

In addition, an entire suite of uniform standards for individual long-term care insurance are currently moving through the rulemaking process.  These include the core standards for individual long-term care insurance policies, as well as the various benefit features and other supporting forms, standards for initial rate filings and modified rate filings as well as advertisements. The long-term care insurance uniform standards provide benefits for one or more of the following: nursing home care, assisted living care or home health care and adult day care. Only those policies, riders, endorsements or amendments that provide all such benefits as outlined in the uniform standards may be titled "long-term care insurance" without further clarification. A public comment period was followed by a public hearing on March 25, 2010 as these products continue to move toward finalization and adoption.

Following the decision to eliminate the timeline associated with "mix and match" filings, the IIPRC made several enhancements to its electronic filing platform in the System for Electronic Rate and Form Filing (SERFF) to allow states to more closely track state-approved and IIPRC-approved components of mix and match filings.  Further enhancements are in the works to make the entry of Statement of Intent ("SOI") information more streamlined for the filer.

With all of these exciting developments, now is the time to visit the IIPRC web site to find out how easy it is to register with and file through the IIPRC. Don't be left at the starting line while the competition speeds past!

All IIPRC filings are submitted through the System for Electronic Rate and Form Filing (SERFF).  File one submission under one set of standards for one approval valid in all Compact jurisdictions today. IIPRC filers experience uniformity, one-stop filing and enhanced speed-to-market efficiencies while continuing to provide insurance consumers with strong and established protections.

Filing Preparation

All resources needed to complete your Product Filing are found on the IIPRC web site: www.insurancecompact.org.  Access information from our Home page:

•   The Docket contains all uniform standards, along with the rulemaking history, under consideration whether a new uniform standard or an amendment to one already adopted. You can be sure to have the most up to date information necessary for the preparation of a compliant filing.

•   The Record contains all Uniform Standards and Operating Procedures that have been adopted. Here you will find the Operating Procedure for the Filing and Approval of Product Filings ("Product Filing Rule") and the recently adopted Self Certification Rule (currently there are no products that may be self certified).

•   The Industry Resources page contains reference tools and information ranging from directions that assist with creating a product filing, completing the Statement of Intent (SOI) and adding a state to a product filing to the TOI Link, and filing fee information. This page should become your best friend.

•   Additional resources found on the Home page include the Filing Information Notices (FINS), which clarify the filing process and our Event Calendar, which lists all IIPRC meetings and outreach events.

Make Your Filing:

•   To begin, click on "Create Compact Filing". Companies must be registered with the IIPRC to have this option available to them in SERFF. The process for submitting a product filing to the IIPRC is the same as it is for the states - except that you only need to make one submission to the states in which a company is licensed to do business in.

•   Use the applicable Uniform Standard to help create your product. All of the requirements are provided in alpha order. Uniform Standards are listed on the web site Record by product line and then by TOI, starting with Life and Life Benefit Features followed by Annuities and Benefit Features. Use the IIPRC TOI Link which provides a crosswalk between IIPRC Uniform Standards and those identified in SERFF's PCM.

•   Reference the FINS to assist with some of the filing submission processes.

•   Pay your filing fees - both the IIPRC and the member state fees. The Filing Fee Submission Requirement provides a link to the Industry Resources page on the web site for information about the state filing fees. All fees are due at the time of submission and a filing may not be reviewed until all fees are paid in full.

•   Use our tutorial to help you complete the Statement of Intent Schedule and be sure to double check our General Instructions in SERFF, and our FINs for more information. In 2009, the Product Filing Rule was amended to eliminate the two-year time frame associated with the "mix and match" filing process. The Statement of Intent Schedule within SERFF was created to provide Member States with easier access to information needed to monitor the use of such forms. All Uniform Standards that are adapted to date are eligible for "mix and match" (except the CSO Uniform Standards). All future uniform standards will specify if they are eligible for "mix and match".

•   Satisfy applicable Submission Requirements

- Actuarial Memorandum.  The Uniform Standards include a section dedicated solely to the Actuarial Requirements.  Be sure to review the provisions in the Uniform Standard for other submission requirements.  Be sure to include necessary formulae, calculations and examples all under Actuarial Memorandum.

- The Flesch Score and Certification.  This can be found in the Additional Submission Requirements under "General" for each applicable Uniform Standard.  The minimum acceptable Flesch Score for a Compact form is 50. All have agreed it's a good consumer benefit.

- Statement of Variability. These requirements are in the Additional Submission Requirements section of every applicable Uniform Standard.  These elements should be consistent with the actuarial memoranda and the forms.  A detailed listing of all variable items, and certification, must be attached.

 - Companies may use a Third Party Filer to submit their product filing.    A letter from the insurer is required authorizing the Third Party Filer.

•   Submit a detailed filing description that contains the name of the forms and form numbers along with the Uniform Standards that were used to submit the product filing. Include any other useful information about the filing as the more we understand about the filing, the better it will be. All of this information should be submitted under the "Filing Description" field. A separate cover letter should not need to be included unless more space is needed.

•   Attach your forms and any other supporting information before submitting the filing.

The IIPRC REVIEW PROCESS

Intake reviews are performed on each filing for the filing fees and the satisfaction of all Submission Requirements.   Objections provided cite the specific requirements found in the various sections of the Uniform Standards.  Responses to any objections should be submitted within 10 business days.  The IIPRC review is based upon checklists that are formatted from the Uniform Standards.  All applicable checklists are attached to our filings.   The Product Filing Rule requires that all reviews are completed in 60 days. Currently the IIPRC is completing the review in under 30 days on average.

ADD A STATE

Another great feature of filing with the IIPRC is that as states join the Compact, you may add them to your Product Filings as soon as their membership becomes effective. The SERFF IIPRC instance includes a "button" to facilitate this.  Simply add the state and pay any applicable state fee - no additional IIPRC fees are required.  If mix and match is involved, the filling will need to be reopened to allow for an update of mix and match information. More information on this process can be found on the web site.

We are sure you will like our filing process.  If you have used the IIPRC please give us your feedback.  If you have not, contact us to get the ball rolling for you down the road to Speed to Market.

•   Comments@insurancecompact.org

•   www.insurancecompact.org