The NAIC goal is to receive further comment so the draft can be fully adopted by the NAIC in September and brought before state legislatures starting in January 2003.

The American Council of Life Insurers, Washington, expressed support for the draft, but urged that long-term care be added to the compact.

If LTCI is not included in the compact, and the compact is adopted by states verbatim, then it would have to be amended in legislatures at a later point for LTCI to be included, according to Patricia Parachini, ACLI senior director-state relations.

In written comment submitted to the NAIC, the ACLI noted the importance of the product as a financial planning tool.

It is close in nature to DI products, the ACLI says. And, according to the ACLI, it raises the issue of the treatment of life insurance and annuity products that accelerate benefits for long-term care.

Other concerns expressed by the ACLI include ensuring that companies have the option of either filing product forms through the compact or through individual state filings.

Additionally, Ms. Parachini raised a concern that standards are developed before 12 states, the number needed to make the compact operational, sign on to the plan. Waiting until there are 12 states, "puts us out a long time," she said.

Bob Hunter, a consumer advocate representing the Consumer Federation of America, Washington, asked regulators what will hold this compact together when others haven't worked.

Commenting on Mr. Hunter's point, NAIC President Terri Vaughan said "it goes to the heart of the political challenge of getting this done in the states." Although a poll of states has not been taken, during the spring NAIC meeting in March, states showed strong support for proceeding to draft a compact, according to Ms. Vaughan.

And Birny Birnbaum, executive director with the Center for Economic Justice, Austin, Texas, said that compact standards need to be examined to ensure that they adequately protect consumers.

Mr. Birnbaum also stressed the importance of an interstate consumer advocate since existing states' processes would be removed and replaced with a centralized, national form. Some states have consumer advocates at the state level. Failure to include this provision is a "dealbreaker" for consumer advocates, he said.

Additionally, Mr. Birnbaum said protections would have to be put in place to avoid a "revolving door" where members on the compact's commission or managing committee would take jobs in the industry or for consumer organizations.

The point was also raised that the compact might need congressional action. Previously, the NAIC said that it thought that no congressional action would be needed.

The reason cited during the NAIC discussion was that, in the event of a dispute among states, the dispute could end up in the state court of one of the participating states rather than in a U.S. District Court.