States on the management committee of the Interstate Insurance Product Regulation Commission voted to adopt product standards and to create a 2-year transition period that would allow the ‘mix and match’ of compact product standards and state requirements.
The decision on a proposal developed by Ohio and Vermont was adopted by a vote of 9-1 with 1 abstention.
The standards include individual current assumption whole life, individual modified single premium variable life, and individual modified single premium joint first-to-die variable life insurance policy standards.
Further revisions to the product filing rule would require that all state filing fees are paid and would create an appendix listing product lines and uniform standards that will be used to determine when mix and match will end for a product line. It will be developed within 6 months of the effective date of the product filing rule. Revisions would also allow mix and match for any insurance/annuity contract in effect as of an applicable product line sunset date to continue indefinitely.
The vote followed a motion made by Pennsylvania to defer any action until a legal analysis is completed. The rationale for the motion was that it would be difficult for a commissioner to disapprove a mix and match filing because it would be under the commission’s jurisdiction. Pennsylvania said there could only be action taken on a fee-based form and not on a compact-based form. That motion was defeated 10-2, with Pennsylvania and Washington state dissenting.