Trade Secrets

2005-2 NAIC Proc.

Ms. Parachini indicated the Compact legislation already recognizes a trade secret protection for product filings and this rule allows a company to keep competitive information protected.

Miriam Krol (ACLI) explained the Working Group developing the product standards is incorporating detailed submission requirements, many of which are actuarial in nature. These submissions may include pricing methodologies, which companies are prohibited from sharing because of antitrust laws.

NAIC Working Groups - Current / Recent

ACLI Emily 2019 Ish…

2005-2 NAIC Proc.

Mr. Birnbaum indicated that trade secret claims keep information from the public and the public adds value to this process. Mr. Birnbaum requested that the rule indicate that all filings submitted to the Commission be public information.

Patty Parachini (American Council of Life Insurers--ACLI) indicated that the initial draft contains good working definitions for official records and trade secret with clear guidance for what is public and what is protected.

Brendan Bridgeland (Center for Insurance Research) stated the presumption of trade secret creates a bias against public access to information for consumers