Variable Material
Many life insurance companies are struggling with the evolving standards for filing and receiving approval of variable material. The NY Insurance Department published guidelines for variable material on their website, www.ins.state.ny.us/acrobat/il_fgsvm.pdf, and it is certainly helpful, it does not address many of the problems plaguing companies in recent months.
I find that it is important to remember that the people who are reviewing these submissions are not product experts and although they work very hard and are dedicated to doing a good job, they do not have the understanding to be able to figure out some of the references and notations that are often included in the Memoranda of Variable Material that I see in my practice. As these are being drafted and prepared for submission, I recommend keeping in mind the process at the Department's end and trying to make sure that the administrative staff member who is reviewing the submission will be able to determine if every bracketed term is adequately explained in the memo.
