The Interstate Insurance Product Regulation Commission (Compact)

What the Compact covers

The Compact's scope is limited to what the NAIC handbook calls asset-based insurance products. The handbook describes the central filing point as covering select individual and group life, annuity and disability income products and individual long-term care products. The Commission's own FAQ lists life insurance, annuities, disability income and long-term care, individual and group.

What can actually be filed depends on the uniform standards the Commission has adopted. Its record of adopted standards is organized by product type and by filing type, such as policy or contract, application, rider or benefit feature, and rates. The Commission's FAQ says its uniform standards are the exclusive provisions applicable to the content and approval of the products, rates and advertising filed with it.

Why property and casualty carriers don't use it

Property and casualty products are outside the Compact's scope entirely. Homeowners, auto, commercial lines and workers' compensation rates and forms are filed with each state, under that state's rating and form laws, usually through SERFF. The NAIC's speed-to-market work treats the two areas differently: a central point of filing for life and health products on one side, and on the property and casualty side, encouraging states to rely more on competition for commercial lines and integrating multistate procedures with each state's own requirements. See rate, rule and form filings for how state-level P&C filings work.

Uniform standards

A uniform standard sets the content requirements for a type of product: required and prohibited provisions, disclosures, and for some lines the rate filing requirements. The NAIC handbook says standards are developed through public notice and comment periods open to industry, consumers and the general public. The Commission publishes its adopted standards, the standards under development and its annual priority list for new ones on its standards pages.

For long-term care, the handbook notes that the Compact's standards must provide the same or greater protections as the NAIC's LTC model regulation, that an initial rate filing must have uniform premiums for all Compact states, and that premiums in a rate increase filing may vary by state where actuarially justified. It also notes that the Compact's authority over LTC rate increases may vary by state.

Member states and opt-outs

The Commission reports 48 members representing about 75% of premium volume nationwide. Its membership page lists 46 states, the District of Columbia and Puerto Rico. California, Florida, New York and South Carolina are not among them, so products sold in those states still need state filings. Check the membership page for the current list before planning a filing.

Membership is not all-or-nothing for every product. Under the Commission's FAQ:

• A member state may opt out of a uniform standard by enacting legislation, at any time and for any reason.
• A state may also opt out by regulation, which includes giving the Commission notice of its intent to opt out within ten days of promulgation.
• A state that has opted out of a standard is not available for selection when filing under the related type of insurance.

The Commission also publishes state-specific information for some product lines, such as state rules affecting long-term care rate schedules and certain disability income exclusions. A Compact filing therefore still needs a state-by-state check of where the product can be approved and on what terms.

How a Compact filing works

Filing through SERFF

The Commission's FAQ says all Compact filings are submitted through SERFF. A company registers through SERFF each calendar year and then uses the Create Compact Filing option. Since March 3, 2025, Compact filings have used the modernized SERFF platform, while most state-based filings remain on the legacy application as states migrate. The screens a Compact filer sees can therefore differ from those used for the same company's state filings. What is SERFF? covers the legacy structure.

Fees

The FAQ says filing companies pay an annual registration fee and a per-product filing fee, set in a schedule of fees adopted each year with the Commission's budget. The Commission's filing fees page has the current schedule and related fee information.

Review and approval

Under the Commission's Product Filing Rule, as described in the FAQ, the Compact must approve or disapprove a product filing within 60 days, with the time the company spends responding to objections deducted from that period. The FAQ names compliance with the uniform standards as the largest factor in how long review takes. Approval covers every member state the filer selected and that has not opted out of the applicable standards.

State filing remains an option

Using the Compact is optional. The FAQ says companies can file through the Compact or directly with a state. The NAIC handbook explains the consequence: a company that files with a state is reviewed under that state's product standards and procedures, and a company that files with the Compact is reviewed under the Compact's uniform standards and procedures. The handbook also says forms filed with the Compact generally should not be mixed with forms filed with individual states.

Pros and cons for filers

The main advantages are speed and consistency: one review, one set of objections, one approved form set. The main limitations are scope and fit. A product or feature that no adopted uniform standard addresses is a poor fit for the Compact. Opt-outs and non-member states mean a national product almost always needs some state filings too. Insurers that use both routes must keep the Compact form set and the state form sets distinct and track which version is approved where.

Practical tips

• Map the footprint first. List the target states, mark the non-members and the states that opted out of each standard you will use, and plan those state filings alongside the Compact filing.
• Read the standard before designing the product. Compact review is against the text of the uniform standard, so features it does not contemplate are likely to draw objections.
• Treat the 60-day clock as conditional. Time spent answering objections does not count, so complete, standard-compliant filings move fastest.
• Keep form numbering clean. Use separate form numbers or editions for Compact-approved and state-approved versions so policy issuance systems attach the right one in each state.
• Check the Commission's filing notices and state-specific information. They change more often than the standards themselves.