NYSID Guidance on Equity Indexed Products
The Department has recently posted a document entitled Guidance on Equity Index Products on their website. The guidance is not broken down by product type but rather addresses annuities and life products as well as individual and group. One thing that jumps out at me is that there is not a single citation to law, regulation or circular letter. This makes it more difficult to assess the basis for the positions as expressed in the product design guidance. Some clues lie in the word groupings, but because the guidance applies to all products, some of these terms would not ordinarily apply to the product, based on where they are found in the law.
For those companies that elected to file equity indexed products on a certified basis, there isn't a lot to determine what might come up on post-approval review that is based on law, regulation or circular letter. However, the guidance does give a very good indication of what the examiners will be looking and asking for upon review. And that is more than we have had in the past!
