Correspondence 0001193125-25-205148 from GUARDIAN INSURANCE & ANNUITY CO INC (CIK 0000044393)
GUARDIAN INSURANCE & ANNUITY CO INC (CIK 0000044393)
Date: Sept. 16, 2025 · CIK: 0000044393 · Accession: 0001193125-25-205148
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-272291
Letter
Re: The Guardian Insurance & Annuity Company, Inc. (GIAC)
September 16, 2025 Eileen Smiley US Securities and Exchange Commission Division of Investment Management Disclosure Review & Accounting Office 100 F Street, NE Washington, DC 20549
Response to Comments to Post-Effective Amendment No. 6 to the Registration Statement on Form N-4 – File No. 333-272291 Dear Ms. Eileen Smiley: This letter contains our responses to the Staff comments regarding the above-referenced filing received via telephone on August 4, 2025. For the responses that follow, page references reflect the page number in Guardian MarketPerform ™ a single premium deferred registered index-linked annuity prospectus filed with the SEC on July 4, 2025. Along with this letter, we have included the revised prospectus pages reflecting the Company’s revisions in response to the Staff’s comments. A courtesy blackline of the revised prospectus will be provided to the Staff.
1. Comment: (General) – Complete and fill in all items in brackets in the next filing. Response: All items in brackets throughout will be filled in and completed for the next filing.
2. Comment: Page TX6, the sentence “ We guarantee that the Participation Rate will never be less than 100%, the Cap Rate will never be less than 1.50% .” add “declared” before Cap Rate. The sentence is missing a phrase, if not add “and” after 100%. Response: We have added missing disclosure.
3. Comment: Page TX12, 4 th bullet of the second set of bullets add reservation to not declare a Cap Rate for a Cap with Par & Spread IPCS. Response: Added
4. Comment: Page TX24, 1 st sentence under the Application Rate Lock section, add Trigger Rates to the parenthetical. Response : Added
5. Comment: Page TX36, 2 nd bullet last sentence and each opening paragraph of the following example, review and revise to be consistent with disclosure on page TX 6. Response : Revisions made. Regarding timing, the Company notes that it is seeking to go effective on November 10, 2025. Please contact the undersigned at (212) 598-8714 with any comments or questions concerning our responses to staff comments. Thank you for your attention to this matter.
Very truly yours,
/s/ Patrick Ivkovich
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CORRESP 1 filename1.htm CORRESP September 16, 2025 Eileen Smiley US Securities and Exchange Commission Division of Investment Management Disclosure Review & Accounting Office 100 F Street, NE Washington, DC 20549 Re: The Guardian Insurance & Annuity Company, Inc. (GIAC) Response to Comments to Post-Effective Amendment No. 6 to the Registration Statement on Form N-4 – File No. 333-272291 Dear Ms. Eileen Smiley: This letter contains our responses to the Staff comments regarding the above-referenced filing received via telephone on August 4, 2025. For the responses that follow, page references reflect the page number in Guardian MarketPerform ™ a single premium deferred registered index-linked annuity prospectus filed with the SEC on July 4, 2025. Along with this letter, we have included the revised prospectus pages reflecting the Company’s revisions in response to the Staff’s comments. A courtesy blackline of the revised prospectus will be provided to the Staff. 1. Comment: (General) – Complete and fill in all items in brackets in the next filing. Response: All items in brackets throughout will be filled in and completed for the next filing. 2. Comment: Page TX6, the sentence “ We guarantee that the Participation Rate will never be less than 100%, the Cap Rate will never be less than 1.50% .” add “declared” before Cap Rate. The sentence is missing a phrase, if not add “and” after 100%. Response: We have added missing disclosure. 3. Comment: Page TX12, 4 th bullet of the second set of bullets add reservation to not declare a Cap Rate for a Cap with Par & Spread IPCS. Response: Added 4. Comment: Page TX24, 1 st sentence under the Application Rate Lock section, add Trigger Rates to the parenthetical. Response : Added 5. Comment: Page TX36, 2 nd bullet last sentence and each opening paragraph of the following example, review and revise to be consistent with disclosure on page TX 6. Response : Revisions made. Regarding timing, the Company notes that it is seeking to go effective on November 10, 2025. Please contact the undersigned at (212) 598-8714 with any comments or questions concerning our responses to staff comments. Thank you for your attention to this matter. Very truly yours, /s/ Patrick Ivkovich Patrick Ivkovich Senior Counsel The Guardian Life Insurance Company of America New York City, NY 10001 Phone: 212-598-8714 E-mail: patrick_ivkovich@glic.com