News

The Compact Office is experiencing higher than usual turnaround times in the regular review queue and waitlists for the expedited review queue. The form reviewers and actuaries are triaging between filings ready for review and those further along in the process. We have also spent time at all levels responding to filer status requests and questions. We understand that status requests are looking for information to help manage expectations.

Here are some factors leading to response times longer than filers generally experience:

• An influx of filings was submitted in the fourth quarter, many of them with actuarial components. The volume of filings requiring actuarial review was 65% higher than in the 3rd quarter with the number of forms more than 85% higher than in the 3rd quarter.
• Annuity product filings are the bulk of the current regular and expedited queues. In December 2024, annuity submissions exceeded life insurance submissions in both queues.
• With the implementation of the Index-Linked Variable Annuity Standards (ILVA), the Compact has received more than 30 full ILVA filings. The ILVA filings and indexed UL filings include multiple strategies that require separate nonforfeiture compliance reviews.
• A steady stream of life insurance nonforfeiture updates are also in the queue as higher life nonforfeiture interest rate translates to lower cash values for some whole life products. This workstream arose in July 2024 and will continue through the January 2026 effective date.
• Another driver taking more time for the Compact reviewers is the level of effort and correspondence with the filer to reach compliance. More filings have multiple rounds of objections due in large part to not complying with the requirement(s) cited by the Compact reviewers in their correspondence. The Compact Office has noticed an uptick in the number of incomplete or non-responsive answers to objections.
• We are also seeing submissions that are not attentive to the applicable provisions in the Uniform Standards, especially actuarial requirements.

If you look at these factors and determine they don't apply to your filing, please understand these factors are currently affecting the ability to stay within the turnaround times that filers have become accustomed to with respect to their Compact filings.

Here are some suggestions for your internal planning:

• Limit status requests in SERFF filings to immediate timing concerns. These inquiries take the reviewer away from substantive review.
• Identify realistic implementation dates. Adjust expectations for time to approval to track turnaround times ranging from 60 to 90 days from submission.
• Clearly identify when a form or benefit is based on a similar version previously approved by the Compact and associate the prior filing. It does not help when the filer raises the existence of a previous approval after it has received an objection.
• Support the reviewer by identifying where and how a compliance issue has been addressed. Here is an example:  The third sentence in the Assignment provision has been revised to include the reference to “unless otherwise specified by the owner” to comply with standard requirements.
• Ensure that all parts of a compliance issue have been addressed. 
• You may notice other Compact team members responding to requests for status. We are temporarily relieving the assigned reviewers from this responsibility so that they can focus on substantive review. Thank you for bearing with us during this time. We are addressing the review workload with additional strategies as well.

If you have any questions, please reach out to the Compact Office via comments@insurancecompact.org.