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Is your company considering filing a supplemental application or questionnaire about COVID-19 with the Compact? Please remember that in general, a supplemental application or questionnaire may NOT be filed with the Compact for use with a state-filed main application.

As a quick refresher, the Insurance Compact's Mix and Match process derives from §111 of the Operating Procedure for the Filing and Approval of Product Filings (Product Filing Rule), which permits Commission Product Components to be used with State Product Components, provided the Statement of Intent identifies the approved State Product Components that will be used with the approved Commission Product Components. Product components are defined in §102 of the Product Filing Rule. The permissibility of Mix and Match is specifically noted on the first page of each set of Uniform Standards (located right after the Scope section).

Mix and Match is available for application forms filed with the Compact, however the Mix and Match of parts of an application contravenes the Uniform Standards requirement that "the filing shall include all the sections and questions that may be required to be completed by an applicant, including additional drop downs, scripts, questions, questionnaires or supplements that would be required if the applicant answers questions in a certain way, such as a 'yes' response." (See §1A(5), General, Individual Life Insurance Application Standards).

The exceptions to this requirement are:

• A filing company is transitioning to the use of exclusively Compact-approved application forms within a reasonable amount of time, or
• A filing company is transitioning to use previously approved Compact applications in Insurance Compact member states new to join the Insurance Compact, or new to the company's Insurance Compact portfolio.

If you have any questions about Uniform Standards requirements, Mix and Match, or other COVID-related filing issues, please contact the Insurance Compact Office. Click here to access the Insurance Compact's COVID-19 resource center for filers.