News

The ability to file combination product filings, by which we mean products that combine more than one TOI, is one of the many benefits of utilizing the Insurance Compact for your product reviews and approvals. This process is authorized in ? 103(c) of the Product Filing Rule. This week?s Weekly Tip reminds you of the importance of selecting the proper TOI for your product filing submission. The correct TOI is what determines the governing Submission Requirements for the product filing.

For all filings that contain a LTC or DI component, the Compact requires the filer to select either the LTC TOI or DI TOI, whichever is applicable. The life or annuity TOI should NOT be selected, even if the filing predominantly contains a life product.  If a combination filing with long-term care insurance or disability income insurance components is submitted utilizing a life or annuity TOI, the filer must withdraw the initial submission and resubmit utilizing the correct TOI. Selecting the LTC or DI TOI ensures only those Compacting States participating in LTC and DI product lines are included on the product filing and facilitates the search process for the Compact team and Compacting States. It is important to note the Compact fees will not be required in the second submission, however, the state fees will be required again. It is important to note that state fees within the withdrawn filing are forfeited, and are required within the new submission with the correct TOI.

The Insurance Compact has published two Filing Information Notices (FINs), specifically FIN 2017-2 and FIN 2018-1, which explain the steps involved in preparing and submitting either an LTC or DI combination filings.

If you have any questions regarding this Weekly Tip or combination filings in general, please contact the Insurance Compact Office.