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Regulation and Compliance > State Regulation

Compact Commission Prepares For First Filings

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The Interstate Insurance Product Regulation Commission says it is ready to receive product filings.

Members of the IIPRC have voted here in San Francisco to adopt an interim “mix-and-match” system for product filing operations, which will allow insurers to use already-approved member state forms along with forms approved by the IIPRC under its Uniform Standards rules.

The system will give insurers the ability to start sending product filings to the IIPRC while the IIPRC develops new Uniform Standards for life insurance, annuities, disability income and long term care insurance, IIPRC officials say.

The IIPRC wants to see insurers filing products with it soon, so that the IIPRC will become self-sustaining, says IIPRC Executive Director Fran Arricale.

“This is a start-up, and there may be some bumps in the road,” but insurance companies seem to be interested in using the system, says IIPRC Chair and West Virginia Insurance Commissioner Jane Cline.

The mix-and-match system rules:

- Require insurers to provide compacting states with informational copies of the combined forms upon request.

- Permit a compacting state to make a standing request for such copies so that companies routinely submit documents.

- Clarify that the commissioner of a compacting state has the authority to prohibit the sale of combination forms if the combination results in ambiguous, unfair, inequitable or misleading clauses.

- Clarify that certification from the company does not create a presumption that the combination is compliant and does not prevent the commissioner of a compacting state from prohibiting the use of the combined form when a conflict is identified.

The IIPRC also approved a motion to expose proposed policy standards for 60 days of public exposure.

The proposed standards relate to individual joint last-to-die survivorship endowments, individual single premium joint last-to-die survivorship endowments, and the individual flexible-premium deferred variable annuity, with separate and general accounts.

IIPRC members also talked about filing fees, including a proposal to set a $5,000 annual fee and a $500 fee per filing.

The IIPRC would start a 1-year project to study the feasibility of a flat filing fee.

IIRPC’s Arricale emphasized that the fee filing proposal is just a proposal.

Joshua May, a representative for Coventry First L.L.C., Fort Washington, Pa., and Lovendusky expressed different perspectives during another discussion, about a policy standards provision that might restrict the policyholder’s right to assign the policy.

May said the current language could restrict consumers’ rights.

The ACLI’s Lovendusky said the issue is “a resolved issue.”

“There are interested parties with other interests that are irrelevant to the commission’s goals,” Lovendusky said.


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