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Longevity annuities and deferred non-variable annuities share the same TOI and sub-TOI, however, each product has a specific deferral of payment certification that is required under the Uniform Standards. This distinction is important in order to appropriately satisfy the Deferral of Payment Certification submission requirement. Please be mindful to include the appropriate certification for the forms in your filing, and that the submission requirement reflects a status of ?satisfied.?

The deferral of payment certification required for deferred non-variable annuities found under ?1A (7) of the Individual Deferred Non-Variable Annuity Contract Standards (IIPRC-A-02-I) requires companies to provide a ?certification by a company officer that written request will be made and written approval received from the chief insurance regulator of the state of domicile of the company prior to the company exercising any contractual right to defer the payment of the cash surrender value, partial withdrawal, or loan value for a period of not more than six months.?

For longevity annuities that offer commutation, ?1A (8) of the Individual Deferred Paid-Up Non-Variable Annuity Contract Standards (IIPRC-A02-I-LONG) requires companies to provide a ?certification by a company officer that written request will be made to and written approval received from the chief insurance regulator of the state of domicile of the company prior to the company exercising any contractual right to defer the payment of any amounts payable on commutation [emphasis added] for a period of not more than six months.?                          

Note that the deferral of payment certification for longevity annuities is specific to commutation only, whereas the deferral of payment certification for deferred non-variable annuities refers to deferral of cash value, partial withdrawal, or loan value. 

If your filing includes both types of products, both certifications are required in order to satisfy this submission requirement. 
If your filing contains only one of those contracts, be mindful to include the appropriate certification.
If your longevity contract does not offer commutation, no certification is required; however, in order to satisfy the submission requirement please include an explanation under the comment field of the submission requirement that no certification is required since the contract does not offer commutation. 
If you have any questions about filing requirements for longevity annuities, or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.