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Washington Comment Letter

FACC would like to make one suggestion to the Department which is to promulgate another rule that would specify content of the required disclosures referenced in the updated statutes consistent with the NAIC Model Regulation as set forth in Appendices A, B, and C.   HB 1120 provides that the Department shall post the Appendices on its website which FACC presumes will be the same forms as provided in the NAIC Model Regulation.  FACC requests the Department consider adopting the NAIC appendices through a regulation that could lay out the sample forms or incorporate the NAIC forms by reference.  Such promulgation, or incorporation of the NAIC forms by reference, would ensure that Washington is consistent with the NAIC model regulation in regard to disclosure requirements and provide certainty to regulated parties both now and into the future. 

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