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The Interstate Insurance Product Regulation Compact
Life insurers offer a wide array of products, including many designed to provide financial security to people who are planning for retirement. In today’s rapidly evolving world, life companies are continuously working to bring new products to the marketplace. To do so, each new product needs regulatory approval.
Insurance companies can get these products approved and into the market in 44 states and Puerto Rico through a single point of contact called the Interstate Insurance Product Regulation Compact. The Commission operates a streamlined system of product form filing that allows insurers to have a single point of filing for approval of insurance policy forms.
It was created several years ago by the National Association of Insurance Commissioners (NAIC), the national organization that establishes standards and best practices for the insurance industry.
Unfortunately, New York is not one of the states that participates in the compact. That means, for an insurance company to sell a new product in New York, companies have to go through an entirely separate approval process.
Simply put, it means companies need to invest more time, more money and more effort to get the same product that is offered in other states, to New Yorkers.
To make matters more pressing, these long-term, investment-oriented insurance products compete directly with other retirement and estate planning instruments that are sold by banks and security firms that already use a more streamlined product approval process. As a result, an unlevel playing field has been created in the financial products market place.
By joining the Compact, New York consumers would clearly benefit, however, they would also remain protected. States that enact the Compact appoint a member to the Commission, which has, and continues to, develop standards to review life insurance products. States with large premium volume, like New York, also become part of the Management Committee of the Commission, ensuring New York has a strong voice on the commission. In addition, the system allows a state to opt-out of authorizing the sale of any product in NY that they might not fully endorse.
Joining the Compact is one of LICONY’s top legislative priorities for 2017 and legislation has been introduced in both houses of the State Legislature to make it a reality. Senator James Seward is sponsoring a bill in the Senate (S.426) and Assembly member Aravella Simotas is carrying the same bill in the Assembly (A.4973). The bill has passed the Senate for seven consecutive sessions, under both Republican and Democratic leadership.
LICONY will advocate for passage of both bills because this bill is a win for consumers, insurers and regulators.
Interstate Insurance Product Regulation Compact Website:http://www.insurancecompact.org/
The life insurance industry understands just how important it is to protect customers from cyber attacks. The industry is a leader in developing protocols and procedures to ensure that the important information it holds, is protected.
The industry also realizes this is an evolving issue and efforts should always be made to improve security efforts.
In New York, the Department of Financial Services has proposed new regulations which would govern how companies maintain and implement cybersecurity procedures.
LICONY submitted comments on the proposed regulation in November and is closely monitoring the situation. We would happily support any effort to identify a cyber security framework that is risk-based, flexible and scalable and can be implemented uniformly on a national basis, with flexibility reflected in the standards adopted by each insurer.
On December 28th, the DFS proposed updated regulations that make many revisions to the original proposals.
DFS is now accepting comments on the updated regulations through Friday, January 27 and the new regulation is scheduled to go into effect March 1, 2017.
Further Reading on the Issue:
LICONY members who want the latest on the Association's efforts can go to our Cybersecurity section (log-in required).