How does NAIC issue assessment responses when a bill of lading is updated?

How does NAIC issue assessment responses when a bill of lading is updated?

The following are key considerations regarding NAIC responses when a bill of lading is updated:


General Update Rules:

  • Any update to a bill of lading re‑triggers MPCI risk and compliance assessment.
    The first version must be filed before loading; updates can be submitted at any time, even after arrival.
  • Every update will receive an MPCI response (DNL, ACT, ACW, RFI, PSF, or EXP), but the final filing must end with ACT, ACW, or DNL to be considered closed.
  • A DNL issued after loading means the shipment should be intercepted upon arrival.
  • Any RFI or PSF must be resolved before a final acceptable status is issued.
  • If multiple updates are submitted while an assessment is ongoing, only the latest version is assessed, and only the most recent response applies.
  • When multiple RFIs are issued, only the latest RFI should be acted upon, as it consolidates all prior requests.

Handling Sequential Updates:

  • When multiple updates are submitted, only the latest version is assessed, and only its response should be followed.
  • If different responses are issued across versions, the most recent response takes precedence.
  • If multiple RFIs are issued, only the latest RFI applies, as it consolidates all prior requests and attachment requirements.

 

Filing Expiration:

  • MPCI filings expire 200 days after the initial submission.
  • Any update submitted after the 200‑day expiration will be rejected.
  • If an RFI remains unresolved for 200 days, the filing will receive an EXP (expiration) response, and no further updates are allowed for that bill of lading.