Sue Eckler-Kerns Director, Regulatory Compliance and Technology

							                Sue Eckler-Kerns
Director, Regulatory Compliance and Technology
                   Prudential
               November 13, 2008
Current Situation…..
SERFF and Filing Requirements

 Filing Requirements are created and maintained
 within SERFF. SERFF is very efficient at collecting
 them when an industry user makes a filing.
Current Challenges…..
SERFF and Filing Requirements
 The process for states to create and maintain filing requirements in
 SERFF is somewhat cumbersome and very repetitive (so I am told).

 The current SERFF requirements are not granular enough. (e.g. for the
 state to indicate that a readability requirement applies to a group
 annuity certificate, but not a group annuity contract).

 There is no ability for industry to do a “pre filing planning query”
 (e.g., run a report ahead of time to find out in which states a cover
 letter might be required).

 Filing requirements are only available to SERFF users.
Current Situation…..
Product Requirements Locator
 The PRL exists on the NAIC website. It is an extremely
 well intentioned tool.

 P&C was set up several years ago, and many states have
 populated it with their product requirements.

  For Life and Health, only two states have added their
 product requirements. Participation was deliberately
 not encouraged as the tool was felt to need some
 enhancements to make it more useful, so it would not
 be productive to have states populate it initially and
 then redo later when the tool was redesigned.
Current Challenges…..
Product Requirements Locator
 Although there is some uniformity, there is still much
 inconsistency in how the tool is used by different states and the
 tool has become somewhat cluttered.

 The tool does not allow states to identify product requirements
 by UPCM TOIs and SubTOIs even though that is how industry
 will overwhelmingly actually file the product.

 The product requirements are not granular enough. (e.g. for the
 state to indicate that a readability requirement applies to a
 group annuity certificate, but not a group annuity contract).
Current Challenges…..
Product Requirements Locator
 For Life and Health, the list of requirements needs major revisions to
 make it useful to industry to query and straightforward for states to
 maintain.

 It is completely separate from the SERFF filing requirements,
 requiring states to maintain requirements in two separate and very
 different tools, even thought there is overlap.

 There is no link to Review Standards Checklist data for states who use
 them.

 Like SERFF filing requirements, I believe it is cumbersome for states
 to create and maintain requirements.
Current Situation…..
Review Standards Checklists
 Some states have developed Review Standards
 Checklists which companies complete to assist state
 reviewers with the review of filings.

  In most cases these are Word or Excel documents
 listing “requirements” and the company must evidence
 compliance with each item when they submit the filing.

 Generally stored on State Websites, with a link within
 SERFF. In some cases they are also stored within
 SERFF.
Current Challenges…..
Review Standards Checklists
 Although the Checklist would probably reference the same
 “requirements” which presumably are in the PRL or SERFF,
 there is no linkage whatsoever between the tools. So
 maintaining the checklist text is yet a third independent tool
 for states to maintain.

 The current Checklist are understandably very broad and do not
 identify requirements based on UPCM TOIs and SubTOIs even
 though that is how industry will overwhelmingly actually file
 the product.

 The current checklists are not granular enough. (e.g. for the
 Checklist to indicate that a readability requirement applies to a
 group annuity certificate, but not a group annuity contract). So
 many items are (correctly) marked by companies as “N/A”.
Proposed Solution
 A centralized “Requirements Organizer Database” which houses
 Filing Requirements and Product Requirements and includes
 the ability to directly incorporate Review Standards Checklist
 items (for states who use checklists).

 Filing requirement data and checklist data would ”feed” to
 SERFF automatically.

 One stop, fast and efficient data entry for states.

 One stop, fast and efficient query access for industry.
Proposed Solution
 Lays the groundwork for the “Form Driven Filings” enhancement on
 the SERFF BOD’s Design Roadmap.

 Would enable/facilitate other SERFF enhancements not otherwise
 possible today – e.g. in states which would otherwise allow multiple
 TOIs in a single filing, the ability to select multiple TOIs and get a
 tailored requirements list based on the specific TOIs selected.

 All the benefits of this tool would be automatically available to the
 IIPRC (and those filing to the IIPRC) as well – they would just be
 listed as another “state”. It may be possible to make more direct
 automated links to actual approved standard documents, eliminating
 the need for IIPRC staff to maintain information in multiple locations
 and formats.
Prototype Demo - Caveats
 This is a demo, not a fully functional tool. It is a visual representation
 of how it might look and function.

 It almost certainly would not be created in Lotus Notes!

 Further collaboration would be needed to nail down the actual
 functionality. This is just a concept.

 Show time!
Requirements Database
Requirements Database
Questions?