STATE OF NEW YORK
25 BEAVER STREET
NEW YORK, NEW YORK 10004
||Circular Letter No. 22 (1999)
June 1, 1999
||All licensed life insurers, fraternal benefit
societies, charitable annuity societies, property/casualty insurers, co-operative
property/casualty insurers, financial guaranty insurers, mortgage guaranty insurers,
accident and health insurers, Article 43 Corporations, Public Health Law Article 44 health
maintenance organizations and integrated delivery systems, title insurers, the State
Insurance Fund, the Medical Malpractice Insurance Association and municipal cooperative
health benefit plans; all hereinafter referred to as "insurers".
||Suggested Best Practices Resulting
From the Joint Department/Industry Working Groups on Form and Rate Filings
In May 1998, the New York Insurance Department convened
three joint Department/Industry working groups, one each for the life, health and property
insurance industries, to discuss ways in which to improve the Departments form and
rate filing processes.
The working group meetings were productive. We were able to
identify a number of best practices for insurers and a number of recommendations for the
Department to adopt in order to improve our internal procedures and expedite the filing
Some of the best practices for insurers discussed at the
- Meet with the Department early on in the product development
process, especially for new and innovative products. This will allow insurers to address
Department concerns while products are still in the development stage and will make our
review more effective and timely.
- Submit complete, accurate and timely filings. In accordance
with previously issued Circular Letters, filing submissions that are determined to be
incomplete or inaccurate will be returned or closed.
- Submit filings in a format that readily allows for
side-by-side comparison of all new language and changes, such as blacklined versions of
previously approved filings.
- Respond to all Department comments and questions in a
thorough and timely manner. In accordance with previously issued Circular Letters, the
Department will close submission files if complete written responses are not received in a
- Make greater use of the expedited approval provision in
Section 3201(b)(6) of the Insurance Law, where applicable and appropriate.
The recommendations for improving the Departments
procedures in processing filings include:
- Hold meetings with insurance company representatives at the
Department or via conference calls as needed to discuss product filing and rate matters.
- Clarify the Departments procedural and substantive
filing requirements by creating and disseminating product outlines and/or checklists. Some
product outlines and checklists are already completed and can be accessed at the
- Expand and periodically update the material on the
Departments website to assist in the form and rate filing process and to keep pace
with substantive and procedural changes.
- Hold educational seminars for insurance company compliance
personnel discussing the Departments procedures and requirements.
- Commit to transparency in the approval process.
- Commit to making greater use of technology, including
electronic forms and rate filings, to expedite the filing and approval process.
- Commit to greater management oversight of, and involvement
in the filing process.
- Commit to responding to insurers in a timely manner.
- Make approved forms more accessible to the public with
viewing stations in Albany and New York City.
- Conduct periodic quality surveys of insurers to assess and
improve the form and rate submission process.
The Department appreciates the efforts expended by the
industry representatives who participated in the working groups. We are committed to
implementing the recommendations, improving the rate and form filing process and being
responsive to the insurance industrys need for timely approvals.
|Martin F. Carus
|Assistant Deputy Superintendent
||Assistant Deputy Superintendent
|and Chief Examiner
||and Chief Examiner
|Acting Chief Insurance Examiner
||Acting Chief Insurance Examiner
|| Health Bureau