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Life and Annuity Regulatory and Submission Requirements

The Regulatory filing requirements, Submission Requirements and the Recurring Issues list  provided under this section are for your guidance only; all insurers/filers have the responsibility to read and correctly apply the laws as they pertain to each filing.

Regulatory Requirements

8VSA §3541 - General filing requirements

Reg. I-88-03 - All variable life insurance forms must be filed for prior approval

Reg. I-2001-03 - Concerns replacement of life policies and annuity contracts - now applies to both in certain circumstances

Bulletin 110Indexed Annuities

Bulletin 120 - Life, Annuity and Health filings/fees and Form -105

Bulletin 121 - Indexed life insurance/elements of filing - include a draft of the buyer's guide

Bulletin 128 - Civil unions/if filing an alternate to the Vermont prescribed endorsement

Bulletin 132 - GLB Sec 305 - expedited filing procedure for disclosure requirements

Bulletin 137 - Terrorist exclusions not approved

Bulletin 138 - Expedited filing procedures for HIV-related tests. See also: HIV-Related Forms Filing Resources for Insurers


Submission Requirements

  • Actuarial Memorandum

Provide an Actuarial Memorandum where appropriate for the filing submission being made. For instance if you are filing a product that requires compliance with the Standard Non-forfeiture and Valuation Law, then an Actuarial Memorandum must be provided. In most cases, an Actuarial Memorandum will be required.

  • Articles of Incorporation and By Laws

Group submissions must include copies of the Articles of Incorporation and the By Laws of the Master Policy Owner. Include the signature page with the incorporators identified and show the date of all signatures. The identification should also state for whom each signatory was employed at the time of signing.

  • Civil Union Compliance

To be in compliance with Vermont's Civil Uion coverage's please refer to Bulletin 128 and Regulation 2000-01-H.

  • Explanatory Memorandum

This should be included as a narrative in the Transmittal Letter and should provide details and supporting documentation with respect to the filed materials. Any reference to previously filed and approved policies/forms needs to identify those submissions by your form number, your narrative description of the form, our Department File Number and Departmental Approval Date.

A completed F-105 must be submitted with every filing.

  • Filing Fee

Each rate and form filing (or a combination) must be accompanied by a non-refundable fee of $50.00 or the retaliatory fee whichever is greater. 

  • Filing Revisions

All filing revisions are treated as a new filing. This does not apply to your responses to declined filings.

  • HIV Related Tests & Informed Consent

If the company needs to test an applicant for HIV/ARC, use the attached HIV Testing information Statement & Consent Form and Notification of Test Result Letter as Reference in Bulletin 138.

  • Indexed Life Insurance

Please certify you are in compliance with Bulletin 121.

  • Individual and Group Life Insurance and Annuities Certificaiton

Beginning September 1, 2015, the Insurance Division will be requiring all filers of Individual and Group Life insurers and Annuities to review the following Recurring Issues checklist and complete the following Compliance Certification. This requirement is being added to reduce the number of non-compliant filings the Department receives and to enhance speed-to-market.

  • For Rates

Life and Annuity products do not need prior approval for rates (except for Credit related products and health insurance, which is included in a life contract or ridered to a life contract). Rates and supporting actuarial and company financial data must be filed with the Department.

  • Readabililty Certification

Forms shall be written in non-technical, readily understandable language, using words of common every day usage. Each insurer is required to test the readability of its policies, certificates, riders, endorsements and applicationsA total readability score of forty (40) or more on the Flesch scale is required.

  • Referenced Material

All referenced material must be included with each filing.

  • Reports to Policyholders(Variable Life only)

Attach exhibits of the statements of report required under Article IX of Regulation I-88-3.

  • Segregated / Separate Accounts

Variable Products: Applications/forms showing the distribution options for segregated/separate accounts must be filed with the Department. The choice of accounts offered may be shown as variable (i.e. they may be withdrawn or others may be added) as long as the company certifies that any changes will be filed for departmental information.

  • Side-By-Side Comparisons

Each submission must include a Side-By-Side Comparison, even if the changes minor or if it is a new form and not replacing an older one. If so, compare it to the nearest contract in your portfolio of products.

  • Situs State Approval

Your submission should have received situs state (state of domicile) approval prior to your having submitted it to Vermont. Please include evidence of situs state approval or a thorough explanation as to why it has not been received.

  • Third Party Filing Authorization

Any insurer who uses a third party to submit, defend and approve contract provisions, must submit a letter of authorization which names the appointed agent, the date and duration of such authorization and any limits which the company impose on the agent. The authorization must be signed by an officer of the corporation.

  • Variable Life Certification

Certify that you are in compliance with all of the provisions of Regulation I-88-3, include a specific reference to Article VII. If you have not elected an option under Article VII, supply an exhibit of any documents which you intend to use in place of a prospectus or private placement offering.