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Interstate Insurance Product Regulation Compact
The Interstate Insurance Compact created the Interstate Insurance Product Regulatory Commission (IIPRC). The IIPRC has developed, and continues to develop, uniform national product standards for life insurance, annuities, disability income and long-term care insurance. As the Commission adopts procedures and standards for these products, insurers will be able to draft forms for use in all states that have adopted the compact and in which the insurer is licensed.
The Interstate Compact has now been enacted in 43 jurisdictions. The states which may currently be included in filings are: Alabama, Alaska, Arkansas, Colorado, Georgia, Hawaii, Iowa, Idaho, Illinois, Indiana, Kansas, Kentucky, Louisiana, Maryland, Maine, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, North Carolina, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, Ohio, Oklahoma, Oregon, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, Tennessee, Texas, Utah, Virginia, Vermont, Washington, West Virginia, Wisconsin and Wyoming. . Montana will be eligible to be included on filings – pending, submitted, or previously approved – on Tuesday, October 15th. The IIPRC does not have rate authority with regards to life and annuities. Companies still need to comply with Montana's unisex requirement but can file their life and annuities products and forms through the Compact.
Florida recently adopted the Compact language but made extensive changes. The law does not become effective until July 1, 2014 and there may be further legislation in 2014.
The IIPRC began accepting filings in 2007. Filings may be made for any product for which Uniform Standards have been adopted. Currently, Uniform Standards are effective for most individual life, annuity, long-term care and disability income forms. Long-term care advertising and rates for long-term care and disability income insurance may be filed as well. Uniform standards for Group Term Life policies and certificates for employer groups as well as applications and policy and certificate change forms are effective. States are allowed to opt-out of specific Uniform Standards. Hawaii, Indiana, Montana, Nevada, and New Jersey have opted out of long-term care insurance standards. Colorado, Illinois, Maryland, Oklahoma & Washington will not permit use of modified rate schedule for long-term care insurance. Montana has opted out of the individual disability standards.
While it did not opt-out of a Uniform Standard, the state of Washington has issued a statement that it will not accept mix and match filings that involve the Return of Premium Standards. The state will recognize IIPRC approved filings that include a Return of Premium feature, provided there is no mix and match involved.
In addition, a number of Operating Procedures have been adopted by the IIPRC. These set out the IIPRC rulemaking process, how filings are to be made, public access to filings, foreign language translations and appeals procedures, among other things.
Filing Information Notices provide guidance on a number of topics including “mixing and matching” of IIPRC approved forms with state approved forms (for example an IIPRC policy with a state approved application). New nonforfeiture interest rate change filings, multi-company product filings, and amending filings.
The IIPRC requires companies register and pay an annual fee in order to make compact filings. A new fee schedule became effective in 2013.
The IIPRC also charges a fee for each filing submitted. The filing fee varies based on type of product. These fees will be in addition to state filing fees, which will continue to be payable.
New fee schedules became effective in 2013.
The headquarters of the Interstate Insurance Product Regulation Commission are in the District of Columbia.
The Management Committee of the IIPRC, which manages the affairs of the Commission, is made up of representatives of the member states. The Management Committee Members include the six largest Compacting States by premium volume, four mid-size states by premium, and one additional state from each of four regional zones.
The IIPRC has hired additional staff for review of filings and will continue to add staff as filing volume increases. Filings are to be approved or disapproved within 60 days, subject to certain limitations.
First Consulting is committed to staying on top of these changes and will keep you informed of any changes. Contact us with your Interstate Compact questions.