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Is your company rushing to file and implement 2017 CSO mortality table life insurance products before the January 1, 2020 regulatory deadline? If so, the Insurance Compact Office recommends filers simplify and streamline filing submissions subject to this deadline. Review of a next-generation full product with associated riders and applications submitted between now and the end of the year is unlikely to receive approval unless it is filed in flawless condition. For more than three years, the Compact has been reviewing products subject to the 2017 CSO transition; crunch time is not the time for wide-ranging revisions and new features.

To this end, the Insurance Compact Office has pulled together a list of the simplest ways to update the nonforfeiture mortality basis in life insurance product filings. As a reminder, the mortality basis of state-approved products cannot be updated through a Compact product filing.

Short of a full product filing, the most common method to update the nonforfeiture mortality basis is to provide revised specifications pages and revised actuarial memorandum and Statement of Variability. The options are:

New specification page with new form number
Insert page if mortality table is in policy pages
Endorsement
Updated Statement of Variability with mortality table bracketed on specifications page
If the product does not develop cash value, update the actuarial memorandum to demonstrate this remains true using the 2017 CSO mortality table
Each of these methods requires an updated actuarial memorandum. The limited nature of the new form or update simplifies the review involved and should result in a quicker turnaround time, provided the filing is compliant with applicable uniform standards and does not contain revisions extraneous to the mortality table change.

The Insurer Resources page of the Insurance Compact website, specifically the Filing Reference Material section and the Weekly Tip Archive, has all the guidance you might need to prepare a mortality table change filing submission. If you have any questions about effecting 2017 CSO Mortality Table updates in your Compact filing, or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.

 
 
 
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