Just a week after the last draft outline was posted, NY has posted another draft for comments. This time it is the Individual Whole Life and Endowment Product Outline and comments are due by April 10, 2011. Updating these outlines was one of the major topics of the Life section of the Modernization Initiative committee and it is great to see it happening. Of particular note is that this outline contains a section on nonforfeiture.
The lack of actuarial information and guidance in the earlier versions of the life outlines left insurers in the dark about department interpretations and positions. A preliminary review of this outline suggests that there are still gaps in that area. Many of us who have seen PAR letters know that there are many interpretations and it is much better to know them before a product was submitted than afterward! This is a great step in that direction. Hopefully, the comment process will result in more PAR positions being included in the outline.