Make your SOV easy to review
As regular readers know, I have been advocating the simplification of filings for submission to New York. In my recent experience, problems with filings are most likely to involve variable material. While the policy forms themselves are not reviewed under the certified process, the variable material (which is now considered a policy form and stamped approved) is read in detail and is the source of many policy form rejections. As one reader commented to me and I agree, this seems completely inconsistent with the whole concept of CL6 filings - i.e. they are not reviewed - but that is the practice today.
I cannot stress enough that the person who is doing the reviewing is not a product expert. She (at this point, they are all she) will be going through your forms and looking for brackets and corresponding entries on the SOV. She isn't supposed to have to understand the product to be able to figure out if the explanation matches the brackets. It is supposed to be clear on its face and provide all information necessary for an administrative staff person to figure out if all permutations are present and if their use is fully explained. If they can't be determined at this time, it must be clear that a subsequent filing for approval will be made at the time of the change.
To keep your file moving, we want the staff person to be able to go right down the form and the SOV. Boom, boom, boom. I have seen many different styles and kinds of SOVs. Based on what I have seen and corresponding approval times, my recommendation is one bracket, one clearly labeled explanation. That way seems to be easiest for the administrative staff member to find the applicable entry on the SOV - and there is the added benefit of helping us in the preparation of the submission to make sure we didn't miss anything!
Once again, I think all of our filings are most likely to be closed based on the SOV and the time we spend making it clear and well organized may save your company months waiting for approval!
