Confusion Over New Grace Period Filing Requirements
On this last day of September, we are 6 calendar days away from the effective date (10/5/2008) of the new laws on Grace Period notices and durations for UL and VUL products in NY, and yet the Circular Letter with promised guidance has not yet been posted on the Department website! Despite the fact that there is an interpretation of the new laws that would have made filing already approved forms unnecessary, the Department did not adopt that interpretation and has instead decided to require all these forms to be re-filed. But as of this moment, has offered no official guidance on how they want this done in the incredibly short time frames allotted.
Companies have been waiting for the Department's instructions because they obviously want to do the filings right. But most have decided that they can no longer wait and are going ahead based on the proposal that was floated but not posted. Given the number of products that many life companies have that are impacted by this change in the law, it is stunning that we are so close to the effective date with no official process in place for handling these filings. Fingers crossed...the filings are on their way!!!
