Procedural Changes in The Approval Process for Life Insurance and Annuity Policy Forms:

Circular Letter No. 8 (1999) March 16, 1999 TO: ALL INSURERS AUTHORIZED TO WRITE LIFE INSURANCE AND ANNUITIES, INCLUDING LIFE INSURERS, FRATERNAL BENEFIT SOCIETIES, CHARITABLE ANNUITY SOCIETIES, SAVINGS BANK LIFE INSURANCE DEPARTMENTS AND ALL LICENSED VIATICAL SETTLEMENT COMPANIES RE: PROCEDURAL CHANGES IN THE APPROVAL PROCESS FOR LIFE INSURANCE AND ANNUITY POLICY FORMS: I. Required Format For Policy Form Submission Letters II. Timely Responses to Comment Letters I. Required Format For Policy Form Submission Letters To facilitate the policy form filing process, the Department will no longer review the substance of a submission letter to determine the number, identity, or type of policy forms being submitted. The Department will no longer accept submission letters that do not follow the format detailed below. Effective for submissions made on or after April 15, 1999, all policy form submissions are to be made directly to the Life Bureau in Albany, New York. The filings should be addressed to: Ms. Kathleen Nelligan, Chief Insurance Policy Examiner Life Bureau-7 th Floor New York State Insurance Department Agency Building One Empire State Plaza Albany, New York 12257 The "Re" or the caption of the submission letter shall clearly identify each of the forms that are intended in the submission. This identification must include: the policy form identification number; a designation of the form as individual or group; a generic product description (See Appendix A for a list of acceptable generic product descriptions); and a generic form description (See Appendix B for a list of acceptable generic form descriptions). As an example, a submission of an individual whole life policy, application and rider would be identified in the "Re" or the caption of the submission letter as follows: Form No. "XX" Individual Whole Life Policy Form No. "YY" Individual Whole Life Application Form No. "ZZ"  Individual Accidental Death Benefit Rider Any additional information beyond this basic description, including references to fixed or flexible premiums or the period of coverage, (such as "life paid up at 85") which are consistent with the description on the policy cover page, is to be placed in the substance of the letter. If the submission consists of more than five forms, each of the forms should be listed in the required format on a separate attached sheet and the "Re" or caption should reference the attachment. These procedures will enable the staff to enter policy form submission information into the Department’s computer tracking system in a more expeditious manner thereby improving the overall policy form filing process. II. Timely Responses to Comment Letters To expedite the policy form review process, the Life Bureau will now close policy form files if a complete written response to the questions, comments, requests for explanation or other material in a comment letter from the Bureau are not received within fifteen calendar days of the date on the comment letter. Very truly yours, _______________________ Martin F. Carus Assistant Deputy Superintendent and Chief Examiner Life Bureau Appendix A Generic Product Description Individual Whole Life Individual Term Life Individual Indeterminate Premium Term Life Individual Universal Life Individual Variable Life Individual Variable Universal Life Group Whole Life Group Term Life Group Universal Life Group Variable Life Group Variable Universal Life Group Life - Regulation 123 Individual Fixed Annuity (MVA if applicable) Individual Variable Annuity Individual Fixed & Variable Annuity (MVA if applicable) Individual Funding Agreement Group Fixed Annuity (Regulation 139, Section 4223 or Regulation 128 as applicable) Group Variable Annuity Group Fixed & Variable Annuity Group Funding Agreement Synthetic GIC Structured Settlement Credit Life/Disability Credit Unemployment Charitable Annuity Viatical Settlement Individual Accelerated Death Benefit Group Accelerated Death Benefit Prepaid Legal Plan Miscellaneous Appendix B Generic Form Description Contract Insert Page for Contract Contract Amendment Contract Endorsement Policy Insert Page for Policy Policy Amendment Policy Endorsement Rider Rider Amendment Rider Endorsement Application Endorsement to Application Receipt (Temporary Insurance Agreement or Conditional Receipt or Receipt) Certificate Insert Page for Certificate Certificate Amendment Certificate Endorsement Certificate Rider Enrollment Form Administrative Form Disclosure Statement Variable Material Combination Policy and Certificate Rider Combination Policy and Certificate Insert Page Combination Rider and Certificate Insert Page Applicable to Fraternals Only By-Laws Amendments to By-Laws Constitution Amendments to Constitution Articles of Incorporation Amendments to Articles of Incorporation Amendments to Constitution and By-Laws Combination Amendment to Constitution, By-Laws and Articles of Incorporation Charter, Constitution and By-Laws Revised Constitution and By-Laws Resolutions Adopted