Life & Annuity Filing Requirements


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..


Effective immediately and in accordance with the requirements of 8 V.S.A. Section 18, the Rates & Forms Section of the Vermont Department of Financial Regulation will begin billing back to filers the reasonable costs of outside consultants hired to review filings.  While the most significant impact of this policy will be on rate filings requiring prior actuarial review, the statute cited above applies to both rate and form filings.  Therefore, an especially complex form filing that, in the commissioner’s discretion, requires review by outside consultants may also be subject to this policy.

Questions about this policy may be directed to Kevin Gaffney, Director of Rates and Forms, at (802) 828-4845 or Phil Keller, Director of Insurance Regulation, at (802) 828-1464.



The checklist below applies to all Life and Annuity filings. It is intended to help you through the filing process by listing the necessary elements of the filing packet. In order to pass to the next stage of review by an analyst, your submission must comply with the instructions below for inclusions and compliance.

Please be sure to also review the list of regulatory requirements pertaining to L&A filing.


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.

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. 

Vermont Transmittal Forms
Form filings must be accompanied by a completed form F105 per Bulletin 120.

Expedited filings of the HIV Information Statement & Consent Form and Notification of Test Result Letters must be filed by use of a completed Form VT HIV TRANS FMB 02/02, as outlined in the "HIV-Related Filing Instructions as Referenced in Insurance Bulletin 138."

For Forms
A side-by-side comparison of changes in the prescribed format is required (click here for an example). Even if the submission is a new form, a Side-by-Side comparison of the new product to others in its family of products is required. For example: in the case of a new term life product, show the difference between this product and the provisions of existing term life products in the company's portfolio of products.

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. See the Department's requirements for the contents of an Actuarial Memorandum.

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.

Copy of any Referenced Material
All referenced material must be included with each filing.

Additional Points

Filing Revisions
Treated as a new filing (does not apply to your responses to declined filings).