(C) IIPRC 2010(C) IIPRC 2010

The IIPRC Today – 36 StrongThe IIPRC Today – 36 Strong

(C) IIPRC 2010(C) IIPRC 2010

Overview of Insurance CompactOverview of Insurance Compact

Innovative vehicle formalizing joint and Innovative vehicle formalizing joint and cooperative action among statescooperative action among states

Leveraging regulatory expertise to Leveraging regulatory expertise to establish Uniform Standards establish Uniform Standards

Central clearinghouse for prompt review of Central clearinghouse for prompt review of asset-based insurance productsasset-based insurance products

(C) IIPRC 2010

Overview of Insurance Overview of Insurance CompactCompact

Uniform Standards for Individual and Uniform Standards for Individual and Group Life, Annuity, Disability Income and Group Life, Annuity, Disability Income and Long-Term CareLong-Term Care

Compact filings submitted through the Compact filings submitted through the System for Electronic Rate and Form System for Electronic Rate and Form Filing (SERFF)Filing (SERFF)

File File oneone submission under submission under oneone set of set of standards for standards for oneone approval valid in approval valid in allall Compact jurisdictions today.Compact jurisdictions today.

(C) IIPRC 2010

Structure of Insurance CompactStructure of Insurance Compact

One member from each compacting stateOne member from each compacting state

Commission is public entityCommission is public entity

Governance: Compact law, Bylaws, Governance: Compact law, Bylaws, Uniform Standards, Rules and Operating Uniform Standards, Rules and Operating ProceduresProcedures

Authority to receive, review, approve or Authority to receive, review, approve or disapprove product filings disapprove product filings

(C) IIPRC 2010

Structure of Insurance CompactStructure of Insurance Compact

Management Committee (3-Tier Management Committee (3-Tier Composition)Composition)– 6 Largest Compacting States by Premium6 Largest Compacting States by Premium– 4 States with Greater than 2% Premium4 States with Greater than 2% Premium– 4 States with Less than 2% Premium by Zone4 States with Less than 2% Premium by Zone

SubcommitteesSubcommittees– Product Standards, Rulemaking, Audit, Product Standards, Rulemaking, Audit,

Finance, Technology, and CommunicationsFinance, Technology, and Communications

(C) IIPRC 2010

Structure of Insurance CompactStructure of Insurance Compact

Legislative CommitteeLegislative Committee

8 Members appointed by NCSL and NCOIL8 Members appointed by NCSL and NCOIL

Consumer Advisory CommitteeConsumer Advisory Committee

8 Members representing consumer orgs8 Members representing consumer orgs

Industry Advisory CommitteeIndustry Advisory Committee

8 Members representing companies, 8 Members representing companies,

producers and associationsproducers and associations

(C) IIPRC 2010

Registering with the IIPRCRegistering with the IIPRC

Registration fee must be paid before a Registration fee must be paid before a filing can be made filing can be made

Annual Registration Fee of $5,000 Annual Registration Fee of $5,000 Registration Fee Prorated to $2,500 after Registration Fee Prorated to $2,500 after July 1July 1stst each year each year

All fees paid via SERFF and EFTAll fees paid via SERFF and EFT

Must authorize IIPRC as payeeMust authorize IIPRC as payee

(C) IIPRC 2010

Tools for Preparing a Product Tools for Preparing a Product FilingFiling

Visit the Rulemaking RecordVisit the Rulemaking Record– Operating Procedure for the Filing and Operating Procedure for the Filing and

Approval of Product FilingsApproval of Product Filings– Uniform StandardsUniform Standards

Visit the Industry Resources PageVisit the Industry Resources Page– Filing Information NoticesFiling Information Notices– Member State Filing FeesMember State Filing Fees– IIPRC Type of Insurance (TOI) LinkIIPRC Type of Insurance (TOI) Link

(C) IIPRC 2010

(C) IIPRC 2010

Uniform StandardsUniform Standards Uniform Standards apply over conflicting state Uniform Standards apply over conflicting state

lawslaws

The Uniform Standards are listed by Product line The Uniform Standards are listed by Product line and then by TOIand then by TOI

Life, with Life Benefit Features followingLife, with Life Benefit Features following

Annuities, with the Benefit Features followingAnnuities, with the Benefit Features following

Provisions in the Uniform Standards are Provisions in the Uniform Standards are presented in alpha orderpresented in alpha order

Provisions in the Uniform Standards are Provisions in the Uniform Standards are presented in alpha orderpresented in alpha order

(C) IIPRC 2010

Basis of Product StandardsBasis of Product Standards Model Laws if they existModel Laws if they exist

Laws, regs or Desk Drawer Rules in effect Laws, regs or Desk Drawer Rules in effect in the majority of statesin the majority of states

Best Practices, if state regulation (or Best Practices, if state regulation (or interpretation of model laws) is varied or interpretation of model laws) is varied or lackinglacking

All requirements are carefully documented All requirements are carefully documented to be understood by company and reviewerto be understood by company and reviewer

(C) IIPRC 2010

IIPRC Uniform StandardsIIPRC Uniform Standards IIPRC more comprehensive and straightforwardIIPRC more comprehensive and straightforward

IIPRC more challenging in some areasIIPRC more challenging in some areas– Bar may be raised for some requirements (but Bar may be raised for some requirements (but

Compacting states may adopt those Compacting states may adopt those requirements anyway)requirements anyway)

– Compliance may require system changes or Compliance may require system changes or product redesignproduct redesign

IIPRC reflects consensus of all states, which IIPRC reflects consensus of all states, which may override single state interpretation of a may override single state interpretation of a model lawmodel law

(C) IIPRC 2010

Completing your Submission Completing your Submission RequirementsRequirements

Use the applicable UNIFORM Use the applicable UNIFORM STANDARD to help you.STANDARD to help you.

Check our Filing information Notices (FIN).Check our Filing information Notices (FIN).

Check our General Instructions in SERFF.Check our General Instructions in SERFF.

Review How to File a Statement of Intent Review How to File a Statement of Intent (SOI) in SERFF (SOI) in SERFF

(C) IIPRC 2010

The Actuarial MemorandumThe Actuarial Memorandum

Most Uniform Standards include a section Most Uniform Standards include a section dedicated solely to the Actuarial Requirements. dedicated solely to the Actuarial Requirements.

Be sure to review the provisions in the Uniform Be sure to review the provisions in the Uniform Standard for other submission requirements.Standard for other submission requirements.

Be sure to include necessary formulae, Be sure to include necessary formulae, calculations and examples.calculations and examples.

Submit all under Actuarial Memorandum.Submit all under Actuarial Memorandum.

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Statement of Variability and Statement of Variability and Specifications PageSpecifications Page

The requirements for each are in the Additional The requirements for each are in the Additional Submission Requirements section of every Submission Requirements section of every applicable Uniform Standard.applicable Uniform Standard.

Be careful to make these elements consistent Be careful to make these elements consistent with the actuarial memoranda and the forms.with the actuarial memoranda and the forms.

You must attach a detailed listing of all variable You must attach a detailed listing of all variable items, and certify to it.items, and certify to it.

Be sure to have the specifications page Be sure to have the specifications page consistent with the rest of the filing.consistent with the rest of the filing.

(C) IIPRC 2010

““Mix and Match”Mix and Match” The Product Filing Rule was amended to The Product Filing Rule was amended to

eliminate the two-year time frame associated eliminate the two-year time frame associated with the “mix and match” filing process. with the “mix and match” filing process.

All Uniform Standards that are adopted to date All Uniform Standards that are adopted to date are eligible for “mix and match” (except CSO); all are eligible for “mix and match” (except CSO); all future uniform standards will specify if eligible for future uniform standards will specify if eligible for “mix and match”.“mix and match”.

Review our General Instructions in SERFF and Review our General Instructions in SERFF and FIN 9 (2009) for more for detailed information on FIN 9 (2009) for more for detailed information on completing mix and match requirements.completing mix and match requirements.

A new SOI Schedule tab was introduced on A new SOI Schedule tab was introduced on 12/9/09 and must be used for all filings made 12/9/09 and must be used for all filings made thereafter.thereafter.

(C) IIPRC 2010

LETS MAKE THAT FILING NOW - LETS MAKE THAT FILING NOW - IIPRC in SERFFIIPRC in SERFF

(C) IIPRC 2010

Double Check Those Submission Double Check Those Submission Requirements!Requirements!

If the filing does not contain a Mix & Match element, the filer will set the “SOI Schedule Required” field to No. If the filing does not contain a Mix & Match element, the filer will set the “SOI Schedule Required” field to No. Otherwise, the filer must select the “Filing Type” and attach the Statement of Intent Certification Form. The Otherwise, the filer must select the “Filing Type” and attach the Statement of Intent Certification Form. The

filer will then add rows as necessary to enter the detailed SOI information.filer will then add rows as necessary to enter the detailed SOI information.

The filer completes the fields on the SOI schedule, which are taken directly from the SOI document previously The filer completes the fields on the SOI schedule, which are taken directly from the SOI document previously in use on IIPRC Mix & Match filings. Once the SOI schedule and the remainder of the filing is complete, it can in use on IIPRC Mix & Match filings. Once the SOI schedule and the remainder of the filing is complete, it can

be submitted to the IIPRC. The included state will receive a message.be submitted to the IIPRC. The included state will receive a message.

Double Check your Filing Fees – the Double Check your Filing Fees – the IIPRC & State FeesIIPRC & State Fees

Product Review and ApprovalProduct Review and Approval Intake review verifies filing fees and

includes all submission requirements

Objections are specific and reference requirements found in the various sections of the Uniform Standards.

We use our review checklists and attach to We use our review checklists and attach to filings.filings.

(C) IIPRC 2010

Product Review and ApprovalProduct Review and Approval

Required to review products in 60 days or Required to review products in 60 days or less.less.

Review time depends upon quality of Review time depends upon quality of company submission and company company submission and company response time.response time.

Upon approval, company can use in up to Upon approval, company can use in up to 36 compacting as listed on the product 36 compacting as listed on the product filing.filing.

(C) IIPRC 2010

(C) IIPRC 2010

As states join the Compact, you may add them to your ProductAs states join the Compact, you may add them to your ProductFilings…Filings…

ADD A STATEADD A STATE

(C) IIPRC 2010

CONTACT IIPRCCONTACT IIPRC

For more information, please contact us at:For more information, please contact us at:– comments@insurancecompact.org– www.insurancecompact.org– Main number: (202) 471-3962Main number: (202) 471-3962

(C) IIPRC 2010