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Life and Annuity Filings

Filing Submission Requirements
Annual Health Reporting Requirements
Rates and Forms Life and Annuity Contacts

Life and Annuity Submission Requirements

Filing submission requirements in this section are provided for your guidance only.  All filers all have the responsibility to read and correctly apply the laws as they pertain to each filing.  

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 Union coverage's please refer to Bulletin 128 and Regulation 2000-01-H.

Compliance Certificate- FORM Filings Only

The Life and Annuities Compliance Certification must be accurately completed, signed, and submitted with all FORM filings or it will be rejected; this is a mandatory life form filing submission requirement. The department does NOT accept carrier created compliance certifications. This certification was added to the form filing process reduce the number of non-compliant filings the department receives and to facilitate speed-to-market. Vermont’s “Recurring Issues Individual Life Insurance, Group Life Insurance and Annuities” document lists the regulatory issues most frequently encountered in the review of life and annuities insurance form filings. Filers must review the Recurring Issues document and make any corrections necessary to their filing to bring it into regulatory compliance. 

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.

Form F-105

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

Flesch Score Certification

Please provide a Flesch Score Certification signed and dated by an officer of the company. Flesch readability form documents must have a score of at least 40. Bulletin 107 § 4.

HIV Related Tests and 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.

Rate Filings Only

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.

Redlined Copy

Filings must include a side by side comparison if a filing contains a form replacing a previously approved form. Please provide a redlined copy of the changes to your forms.

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.

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.

Regulatory Requirements

8 VSA §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 110 - Indexed Annuities

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


NAIC Lost Policy Locator

Please note that for your convenience the NAIC Lost Policy Locator has been added to our Insurance Home Page as well as our Rates and Forms Life and Annuity Page and the Insurance Consumer Information page.

The NAIC can assist consumers in locating life insurance policies and annuity contracts of a family member or close relationship. It can be utilized by consumers or life insurance agents to locate a policy using basic identifying information. The NAIC will use the information to request that participating companies search their records to determine if there is a life insurance or annuity contract in their database related to the specific insured. If you have any questions on how to use the Lost Policy Locator, please contact Christine Menard-O'Neil at: or by phone at: 802- 828-5589

Submission Requirements

EFFECTIVE 10/01/2017: Filings must be submitted under the proper TOI and Sub-TOI, have a correctly completed and signed Form F-105, have a correctly completed and signed Life and Annuities Compliance Certification for FORM filings, a Flesch Score certification, and the correct filing fees and fee calculation under the "filing fees tab" or the filing will be rejected. In addition, filers will need to provide responses to the department’s objections within a 30-day timeframe or the filing will be marked disapproved-final. If a filing is rejected or marked disapprove-final, a new filing must be submitted with the proper filing fees. 

Costs of Outside Consultants

Effective immediately, and in accordance with the requirements of 8 V.S.A. § 18, the department will bill back to filers the reasonable costs of outside consultants hired to review rate and form 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 Phil Keller, Director of Insurance Regulation, at 802- 828-1464.

Life and Annuities Compliance Certification

The department's insurance Division requires all filers of Life and Annuities to review the following Recurring Issues Individual Life Insurance, Group Life Insurance, and Annuities document and complete the Life and Annuities Compliance Certification.  This requirement is being added to reduce the number of non-compliant filings the department receives and to enhance speed-to-market. Both of these documents can be found below.

Annual Life Reporting Requirements

Annual Reports of Life Insurance Illustrations are required to be submitted through SERFF.  There is no filing fee require.  Please select the filing type “Annual Report”.  Click the link below to find more information on this annual report.
Life Insurance Illustrations


Anna Van Fleet
Assistant Director of Rates and Forms - Life and Health
Emily Brown
Director of Rates and Forms
Christine Menard-O'Neil
Rates and Forms Analyst