Use of 8/9/2010 Variable Material Checklist for NY Policy Form Submissions

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