As a member of the life committee of the New York State Insurance Department’s task force on modernizing insurance regulation, I worked with Ms. Nelligan on the creation of a checklist for use when drafting memoranda of variable material for life and annuity policy form submissions. This was an area of concern because so many certified submissions (CL-6) are rejected due to variable material problems. In drafting the checklist, we tried to identify the most common errors and provide concrete tips for avoiding them. The [checklist] we came up with was posted on the NYSID website last week.
This week, I had my first occasion to use it during the process of preparing variable material for a client. While I was obviously familiar with its content, I found the checklist format very helpful as I went through the process. I found it useful both in the initial drafting and in doing a check before finalizing. I think anyone who is preparing these for submission will find it of value and I encourage you to check it out on the website and use it in conjunction with the other posted guidance on this topic.form filings variable material checklist insurance regulation modernization