Life Bureau Filing Guidance Note
Guidance Date: August 16, 2019

Supplemental Filing Requirements for Using the 2017 CSO Mortality Table

This guidance supplements filing guidance dated May 2, 2017 titled Filing Requirements for Using the 2017 CSO Mortality Table. The Life Bureau is currently experiencing a higher than normal volume of policy form submissions primarily due to 2017 CSO filings.  Although the Life Bureau began accepting 2017 CSO filings in May 2017, the bulk of the 2017 CSO filings have only recently been submitted. Also, many companies are taking this opportunity to make other changes to their products at the same time they are making the mortality table change and are requesting that the Life Bureau provide a full legal and actuarial review of these redesigned products. The Life Bureau expects this to result in slower than normal turn-around times under the prior approval process between now and the end of the year. Some companies are indicating to the Life Bureau that if they do not receive approval in the very near future, they will not be able to meet internal I.T. and other administrative deadlines in order to launch the products by 1/1/2020. The Life Bureau does not find this to be an acceptable outcome. Accordingly, the Life Bureau is instituting new procedures and providing the following recommendations to assist companies:

1)  Companies are encouraged to submit any new 2017 CSO policy form filings through the Circular Letter No. 6 (2004) certified process (CL-6 process), especially if adoption of the 2017 CSO is the only change being made.

  • If there is some aspect of the filing that is causing the company to be uncomfortable about using the CL-6 process or which the company believes would disqualify the filing from being submitted through the CL-6 process, the company should contact Peter Dumar (Chief Insurance Attorney), Kathleen Ryan (Supervising Insurance Attorney) or Todd Cafarelli (Supervising Insurance Attorney) to explore options for addressing that item so the filing can be made through the CL-6 process.

2) Companies with a pending prior approval file are encouraged to reconsider submitting the filing through the CL-6 process. Companies may contact the attorney assigned to the prior approval file to request permission to withdraw the file and resubmit through the CL-6 process.

  • Requests will be considered on a case-by-case basis.
  • The Life Bureau is open to considering such requests even where prior correspondence may have requested that the submission be made via the prior approval process.

3) The Life Bureau understands that companies who are making extensive changes to their products in addition to the mortality table may want a full review of the products and the Life Bureau is happy to provide that full review, however, to ensure that there will be no disruption in sales if companies are not ready to implement the new redesigned product on 1/1/2020, the Life Bureau offers the following solutions to bridge the 1/1/2020 date and the ultimate launch date of the new redesigned product:

  • A company may take the product it currently sells today, make just the mortality table change, and submit the revised current product through the CL-6 process (if the mortality table is only addressed in the spec pages of the current product and the spec pages of the current product were previously approved as a separate policy form from the base policy then only the revised spec pages would need to be submitted).
  • In lieu of submitting each product or set of spec pages as discussed in the prior bullet, the Life Bureau will permit, on a temporary basis, the use of a 2017 CSO change endorsement to the company’s current product(s) to bridge the period between 1/1/2020 and the implementation date of the new product(s). The endorsement must be limited to the 2017 CSO change and should be submitted through the CL-6 process. Approval will be conditioned on the endorsement being discontinued for new sales after 6/30/2020.

4) The Life Bureau has established the following dedicated email address to which all status inquiries should be submitted: [email protected]

At this time, the Life Bureau will no longer accept phone calls for status checks on pending form filings and will not respond to status checks sent via SERFF or emailed directly to reviewers. This consolidation will free up time for reviewers and support staff to address substantive issues companies may have and to focus on processing filings. This will also help the Life Bureau respond to status inquiries in a timely manner.