Disclaimer: I speak only for myself here. I do not purport to speak for "the industry." I do not purport to speak for my clients. This is just me. So....
In the policy forms meeting with the Department today there was an extended discussion about the process for making fund changes and a good deal of dissatisfaction expressed. I can understand wanting more flexibility in Variable Material, particularly with respect to fund changes. However, as of today, we have a clear process. We know what to do, the guidance is easy to comply with and it is fast! For me, this is the definition of a good process. We can argue around and around about what is necessary from a legal and regulatory viewpoint, but on a day-to-day basis, this process is a good one because it is clear. I like knowing that within 5-10 days of getting final fund change information I can have documented approval for them to be used because I know exactly what to do and how long it will take.
What I am very concerned about is opening up a protracted discussion which will, by definition, create uncertainty. But not only that, most importantly, who is going to be involved in this discussion? At the Department, it is going to be the people we need to have spending time on other, in my personal view, more important matters. I would like Kathy, Ralph, Deb, Dennis and Tom and the people who report to them, spending time on innovative products, on revising the outlines, on new regulations, on wrapping up post-approval reviews and on the myriad of other things that need their attention so that life insurers can do their business in New York. They will likely spend hours internally - and with us - talking about Variable Material and fund changes - all to fix something that may not be perfect, but it works! At least we know how to get fund changes approved!
Who can get an "innovative product" approved quickly? And we won't be able to if the staff is spending all their time debating fund change nuances and other items already dealt with in the recently posted guidance. Some may not have gotten everything they want, that rarely happens in a regulated industry. But can't we pick our battles, deal with it and get on to more pressing issues? After all, there are only so many hours in a day.....
