NYSID Posts more Filing Guidance for Variable Material
The NY Insurance Department has posted updated Filing Guidance on the use of Variable Material for Individual Annuity Contracts and Life Insurance Policies. While some of the guidance is duplicative of previously posted documents, the new rules for List of Fund filings are now included here, not just in the revised SERFF general instructions. This is helpful. In addition, there is guidance on informational filings.
The Department indicates that informational filings will be acknowledged. Companies are advised that they must wait for this "placed on file" acknowledgment prior to use of the new material. While we generally prefer to receive something from the Department in order to have complete files documenting the filing, the recent slowdowns in processing submissions makes this requirement more onerous and something to plan around. If recent List of Funds filings are any indication, receipt of this acknowledgment of informational filings could take a few weeks.