New Reg 149 Filings
At today's policy forms filing task force meeting, the NYSID indicated that they are discussing internally what the process will be to allow companies to file revised policies during the period between now and when the new regulation becomes effective on 1/1/08.
The issue is that certification is problematic when the regulation is not yet effective. Forms drafted to comply with the new regulation would not be in compliance with the current regulation, but the certification is happening now. Because the certification cannot be modified, companies cannot take it upon themselves to make changes to the certification that would make it accurate. Therefore, a specific process is necessary. It appears that guidance on how to handle this situation will be forthcoming so that companies can begin to put these submissions together and get them approved in time for a January 1 launch under the new regulation.
