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Is your company updating its logo? Do you have approved Compact filings in which the logo was not marked as variable? In this week?s tip we will answer some frequently asked questions pertaining to logo change procedures in the era of Filing Information Notice (FIN) 2017-1.

Q: Our company is updating our logo. Do we have to file this for approval?
A: Yes. Change of logo is subject to review to ensure the new logo is not misleading, and there may be state-specific conditions for, or review of, logo changes.

Q: The logo is marked as variable in our approved Compact filings. Do we still have to file logo changes for approval?

A: Yes. The uniform standards permit the logo to be bracketed as variable, but a future change of logo is still subject to filing for review. The Supporting Documentation Update (SDU) filing type enables review without re-filing of forms on which the logo appears. The logo need not be on the form schedule, but should instead be attached under Supporting Documentation.

Q: How do we submit a logo change filing?

A: All logo changes should be filed using the SDU filing type, generally using the applicable ?Other? TOI. As an SDU filing, there should not be any forms on the form schedule. A single filing can address logo change for all approved Compact filings, including forms approved under multiple TOIs?use the TOI corresponding to the greatest number of previously approved filings.

The filing submission should provide:

1. A copy of the new logo attached under Supporting Documentation;
2. A certified letter signed by an officer of the Company indicating the logo has or will be approved/filed in States in accordance with their respective requirements, if any, along with the effective date of this change;
3. A detailed list of the forms impacted by the change in logo, including their TOIs, should be provided under Supporting Documentation; and
4. Associated filings should be indicated under View Associated Filings.

The Insurance Compact Office has created a new checklist for filers to use when creating a logo change product filing submission. The Logo Change Checklist is published to the Insurer Resources page of the Insurance Compact website, under Creating a Compact Filing. The checklist also includes information regarding filing fees and what filers can expect post-submission for a logo change filing. 

Q: The logo was not marked as variable in the initial Compact filing. How do we update the filing so that the logo is marked as variable going forward?
A: ? II.C.2 of FIN 2017-1 specifically addresses that a single SDU filing can be submitted to make items that were not originally approved as variable into variable items.

Q: Can we update our logo and the variability in the same filing?
A: Yes. The additional logo bracketing for any forms that did not include it and the logo change can be included in the same new SDU filing, which would be associated to all the filings where the new logo will appear going forward. These filings should also be listed in the a document attached to the Supporting Documentation tab per the logo change checklist.

If you have any questions about submitting a Logo Change filing or about filing with the Insurance Compact in general, please contact the Insurance Compact Office.