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Are you unsure of how to tell whether your Compact product filing requires an Actuarial Memorandum? The best way to be certain whether actuarial review of an Insurance Compact filing is required is to look at the applicable Uniform Standards for an Actuarial Submission Requirements section. If the Uniform Standards do not contain this section, actuarial review is not required in most circumstances. You can double-check this determination by consulting the tool specifically designed to list Uniform Standards Without Actuarial Review. This tool is published on the Industry Resources page of the Insurance Compact website. This is important as Compact filing fees vary by whether actuarial review is required and attaching an actuarial memorandum to a submission when not required or not submitting an actuarial memorandum when required automatically generates an objection. Please note that it is possible for more than one Uniform Standard to apply to a filed product; if unsure, you can check the scope sections of the Uniform Standards. Occasionally the inclusion of a specific rider charge will have an impact on nonforfeiture compliance, which triggers actuarial review.

Supporting Documentation Update Filings - In general, if any product is changing in a way that is outside of the previously approved actuarial memorandum, a revised actuarial memorandum with an updated certification is needed.  Many of these may also necessitate a revised Statement of Variability. Common examples include:

• Changing index options
• Expanding the issue age range
• Decreasing the minimum issue amount
• Changing non-level premiums
• Adding a new level term period or premium payment period
• Changing the maturity / expiry age
• Changing the nonforfeiture mortality or interest basis
• Changing level premiums where the premiums affect the death benefit (e.g. for a graded death benefit whole life)
• Note that a post-filing marketing restriction (such as narrowing the issue age range, raising the minimum issue amount, or no longer selling a level term period option) does not require a revised memorandum.

If you have any questions regarding this week’s tip, please contact the Insurance Compact Office.