State Filings Made EasyOr Not Filings from a

State Filings Made Easy…Or Not? !

Filings from a Regulator and (Former) Filer’s Perspective Sarah Neil Senior Insurance Analyst Rhode Island Insurance Division

My time in industry… • Worked at Met. Life from 2007 -2013 in Life and Annuity filing unit • Responsible for managing drafting process of product forms, in conjunction with Company’s legal, product, distribution, and actuarial departments • Drafted and prepared documents to be submitted with filings in 51 jurisdictions, e. g. Statement of Variability, bracketed for variability, added known state variations, etc. • Reviewed output from Contract Print to ensure product documents printed as filed

Most Common Objections Reasons • Filing fee is incorrect • Insurance Bulletin Number 200213 states filers pay retaliatory fee is greater than Rhode Island state filing fee • Rhode Island state fee is either $40 for new contract/certificate filing, or $25 charged for each contract to which a filer wants the filing to apply • Filers do not include previously approved contract/certificate information • Filers request to use forms on a general use basis, but Rhode Island fee is calculated based on the number of contracts to which a filing applies • Prior approval dates and SERFF Tracking Numbers must be provided, if applicable

Most Common Objection Reasons • Filer inserts language in cover letter asserting right to correct typos without refiling • Rhode Island procedure allows filers to request reopening of filing if company has not implemented filed forms • If company has implemented and issued forms, a new filing is required with filing fee • Filers do not include side-by-side comparison of replaced/amended forms • Rhode Island requires red-lined or otherwise tracked changes • This allows reviewers to easily see what has changed from last version

Most Common Objection Reasons • Filers use incorrect type of insurance (TOI) indicator in SERFF • Forms that cross lines of business (LOBs) should be filed using “ML 02. 000 Multi-Line – Other” • NOTE: filers should contact the DBR prior to submission if your filing applies to health lines • Omitting a Statement of Variability (So. V) on the Supporting Documentation tab • A So. V should be submitted whenever forms contain bracketed material • Reviewers look for variable material to match bracketed items and to be clear as to how the language varies

How to Find Filing Guidance • DBR has posted filing guidance on its website and in SERFF • http: //www. dbr. ri. gov/documents/divisions/insurance/life_accide nt_health/INS_LAC_Policy_Form_Filing_Requirements. PDF • Updates to prior versions are captured in red for ease of reference • Note: Filing Guidance document applicable for Life, Annuities, and Credit Insurance

More to remember… • Readability • Credit scoring • Deemer provisions • File & Use, Use & File, Prior Approval • Time limits • “a” rates • What to File

More to Remember… • Non-English forms • Confidentiality of filings • Discretionary clauses • Logo changes • Price optimization • Fraud warning statements

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