With the June target date for the Interstate Insurance Product Regulation Commission to start accepting product filings fast approaching, discussions are focusing on how to encourage companies to use the commission.
A couple of ideas were broached during the spring meeting of the National Association of Insurance Commissioners here. “Mix and match,” a concept that would allow companies to use state product filings and commission filings in different combinations, was discussed by commission members. This means that if a product form already existed in a state and a form for a rider were filed with the commission, a company could ‘mix and match,’ or vice versa.
Another idea that insurers raised was the creation of group standards in addition to the individual standards that are being established.
On the ‘mix and match’ issue, commissioners questioned where authority would rest if an issue arose in which both state and commission product filings were used.
Nebraska Director Tim Wagner also raised the issue of Commission fees and whether a ‘mix and match’ program would reduce filing revenue.
Ohio Director Mary Jo Hudson said that perhaps the ‘mix and match’ concept could be used for a limited transition period, such as 2 years, until there is a full complement of forms available through the Commission.
The ‘mix and match’ concept was not envisioned when the Commission was being created, according to Frances Arricale, executive director of the IIPRC, Washington. However, she said the Commission would look at the industry suggestion.
When the Commission was formed, she continued, the agreement was that it would be revenue neutral so that it would not reduce filing fees that states receive. The Commission is currently working on a fee structure, Arricale adds.
Industry representatives spoke about why companies need this option.
‘Mix and match’ is necessary because it is “very unlikely” that there will be a full complement of commission policy forms available for file by the June target date for startup, said Michael Lovendusky, a representative with the American Council of Life Insurers, Washington.