Insurance Program Launch Execution Checklist

Cover underwriting appetite drift, fronting-carrier credit risk, reinsurance recoverable concentration, and regulatory exposures (Anti-Fraud Plan filing gaps, NYDFS Part 500 scope additions, GLBA Safeguards). Attach the register file below — this becomes the artifact reviewed at the biennial Part 500 risk assessment.

Use the carrier's 5x5 enterprise risk matrix. Anything scoring above the program's stated risk appetite tolerance requires sign-off from the CUO and Head of Claims before mitigation drafting begins.

Each mitigation names the control owner, the test cadence, and the SOC 2 / Part 500 control mapping. "Monitor quarterly" is not a control — name the control activity, the evidence captured, and who reviews the evidence.

One accountable owner per risk — typically Program Manager, CUO, Head of Claims, or CISO. Consulted parties are fine to list separately; multiple accountable owners means nobody is accountable.

NYDFS Part 500 §500.09 requires biennial risk assessments at minimum; auditors expect annual in practice. Calendar the next review now and identify trigger events (new state, new line, M&A, major vendor change) that force an off-cycle review.

Capture the fronting carrier underwriting and credit contacts, treaty and facultative reinsurers, the TPA claims lead, and the bordereau accountant. Add surplus-lines stamping office contacts for any target E&S state.

Cedant: monthly bordereaux plus quarterly underwriting reports. Producers: appetite letters and ACORD 125/130 supplemental walk-throughs. Reinsurers: treaty performance against plan. Set the cadence here so renewals don't rebuild it from scratch.

Standing agenda: SERFF status by state, binding-authority blockers, IT build burn-down, TPA readiness, reinsurance attachment-point sign-off. Keep the agenda short or it turns into status theater.

Test the appetite letter and ACORD supplementals against three to five target wholesale brokers. Common feedback themes: hazard grade carve-outs too narrow, deductible options too thin, surplus-lines tax pass-through unclear.

The fronting carrier must approve the MGA's binding authority document — line of business, policy limits, hazard grade, premium ceilings, referral triggers — before any binder issues. A Declined or Conditional answer triggers the resubmission step below.

Common carrier-requested revisions: tighter per-risk limits, narrower class codes, additional referral triggers above a premium threshold. Re-run senior underwriting sign-off on the revised package before sending it back to the carrier.

Confirm each assigned underwriter holds an active resident or non-resident producer license with the correct line authority in every state where they will bind. NIPR is system of record — verify NPN status and CE currency, not just the agency-level appointment.

Line items: SERFF filing fees ($100–$200 per filing per state, typical), policy-admin configuration (PolicyCenter, Britecore, Insurity), bordereau tooling, outside counsel for form drafting, ISO/Verisk data license. Carry a 15% contingency.

Stand up sandboxes with the program's class codes, rating tables, and forms library. Confirm document templates render state-specific forms correctly — FL hurricane mitigation disclosure, CA WC Box 21, NY ANTI-fraud notice, TX Chapter 542 acknowledgement language.

Compare actual hours burned against the staffing plan weekly. Slippage on IT build or filing analyst capacity is the single most common cause of bind-date slip — catch it at week 4, not week 10.

Surplus-lines tax filings and stamping office submissions spike in the first 60 days post-bind. Pre-identify the overflow team or wholesale partner who can absorb that volume — compliance for SL tax remittance ultimately rests with the producer of record.

Tag each target state with its filing posture: prior-approval (PA), file-and-use (F&U), use-and-file (U&F), or no-file. PA states drive the critical path — typically NY, CA, MA, NJ, NC. Sequence PA filings first.

Form filings depend on rate filings depend on rule filings — but the dependency direction varies by state. Do not build the Gantt without your filing analyst; generic templates routinely miss state-specific sequencing.

One analyst per DOI relationship — these are interpersonal. The analyst handling FL OIR objections is rarely the right one for NY DFS. Name a primary and a backup for each state.

Capture the date of the first PA-state approval letter. This anchors launch communications, the cedant's attachment-point clock, and the producer appetite-letter release.

If a PA state runs past plan, decide between launching in approved states only versus holding for a unified launch. Document the decision rationale and notify the cedant — pushing rates live in a PA state without approval is the exact failure mode that draws an unauthorized-rate market-conduct finding.

Field-level rules: NAIC carrier code populated, FEIN format valid, state-specific class codes (NCCI vs. independent bureau), additional insured fields used correctly on ACORD 25 (Certificate Holder vs. Additional Insured). AMS auto-population is a known drift source over multiple renewal cycles.

Test paths: ACORD 125/130 intake → bind → policy issuance → first FNOL → first reserve set → first claim payment with OFAC re-screen. Each path runs at least three test policies with realistic insured data.

Mock against the NAIC Market Regulation Handbook chapters relevant to your lines. Anticipate findings on: TX Chapter 542 prompt-payment timing, producer commission disclosure (NY Reg 187, CA SB 250), declination notice content, and OFAC re-screening at claim payment.

Each defect carries severity (blocker, major, minor), the failing control, and the SOC 2 / Part 500 control mapping. Blockers stop launch sign-off — no exceptions absorbed verbally.

Program Manager, CUO, Head of Claims, and CISO each sign. The decision is Go, Conditional Go (with named exceptions and a remediation date), or No-Go. A No-Go branches into the remediation step below.

Address each blocker, retest the failing path end-to-end, and reconvene the four-person sign-off panel. Skipping the panel is how unauthorized rates and unfiled forms reach production — discovered later at a market-conduct exam, with statutory penalties.