SEC Company Response from ALLSTATE LIFE INSURANCE CO (CIK 0000352736) — May 4, 2020
ALLSTATE LIFE INSURANCE CO (CIK 0000352736)
Date: May 4, 2020 · CIK: 0000352736 · Accession: 0001628280-20-006228
AI Filing Summary & Sentiment
File numbers found in text: 000-31248, 333-236836
Referenced dates: April 6, 2020
Letter
Disclosure Review Office U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549
Dear Mr. Oh,
Please see our responses below addressing your follow-up comments on the Allstate MVA Account Option under Certain Variable Annuity Contracts (File No. 333-236836) given over the phone on April 28, 2020. We have included the applicable comments from your letter dated April 6, 2020, followed by our response in bold to your follow-up questions pertaining to the original comments. The page numbers in our responses refer to the attached redline of the prospectus reflecting our updates in response to your most recent comments.
(1)(c) Significant market events have occurred since this registration statement was filed as a result of the COVID-19 pandemic. Please consider whether the Company’s disclosures, including market risk disclosures, should be revised based on how these events are affecting the markets of the index that the Company is using to calculate the Company’s obligations under the contract. Further, given that the Company’s obligations under the contract are subject to the financial strength and claims-paying ability of the Company, please consider whether this disclosure should be revised based on how these events could affect the Company’s financial strength and claims-paying ability. If the Company believes that no additional disclosure is warranted, please explain supplementally why not.
Response: We updated the Risk Factors section to add quotation marks where appropriate (see page 4).
(3)(a) Again, although incorporation by reference for Item 3 is permissible, Item 502(a) of Reg S-K does require that the table of contents include "Risk Factors" required by Item 105 of Reg S-K.
Response: We updated the Risk Factors section to delete “Item 3” from the heading (see page 4).
(3)(d) The Important Terms section beginning on page 4 includes a definition of a “Credit Enhancement,” but the term only appears in the last paragraph on page 6. Please delete the term or confirm the term has been incorporated everywhere necessary in the prospectus.
Response: We updated the Description of the MVA Account Option discussion to delete the parenthetical reference to the term “Credit Enhancement” (see page 7).
(5)(c) In the first paragraph on page 7, please clarify supplementally whether the reference to a 4.5% Treasury Rate is representative of rates actually offered over the last few years and, if not, why it’s not misleading to use it here.
Response: We updated the Description of the MVA Account Option discussion to clarify that the example rate is for illustrative purposes (see page 7).
(9) Please provide file numbers for documents incorporated by reference. Please also provide all disclosure in the first paragraph required by Item 12(a)(2) of Form S-1, and you may delete the third and second to last sentences of the paragraph.
Response: We updated the Annual Reports and Other Documents discussion to remove the second instance of “filed pursuant” (see page 10).
(10) Please revise for a clearer explanation of “for the week preceding” in defining “I” and “J” and what .9 represents, and reconcile the reference to “denominator” in the second to last paragraph of the page.
Please also specify what “N” stands for and if N is less than 365 days (i.e., example reflects more specificity) and briefly explain why .0025 is added.
Response: We updated the Market Value Adjustment discussion to revise the definitions of “I” and “J,” describe what “.9” represents in the MVA formula, and provide a plain English explanation of the .0025 factor in the formula (see page 11).
We trust that these responses address your comments. If you have any questions, let me know.
Thanks,
/s/ Iman Naim
Iman Naim
Senior Associate Counsel
(847) 402-6222
inaim@allstate.com
Market Value Adjusted Fixed Account Under Certain Variable Annuity Contracts Issued by Allstate Life Insurance Company
Allstate Life Insurance Company Street Address: 5801 SW 6th Ave., Topeka, KS 66606-00001 Mailing Address: P.O. Box 758566, Topeka, KS 66675-8566 Telephone Number: 1-800-457-7617 Fax Number: 1-785-228-4584
Prospectus dated May 1, 2020
Allstate Life Insurance Company (“Allstate Life” or the “Company”) issues the Market Value Adjusted Fixed Account Option (the “MVA Account Option”) described in this prospectus. The MVA Option is available only under the following variable annuity contracts that we offer: Allstate Advisor; Allstate Advisor Plus, Allstate Advisor Preferred, Allstate Variable Annuity, Allstate Variable Annuity (L Share), STI Classic Variable Annuity, Advisor - STI, and Advisor Preferred - STI. None of those contracts currently are offered for new sales. However, under outstanding contracts you may be able to make additional purchase payments and allocate additional purchase payments or amounts of Contract Value to the MVA Account Option.
This prospectus is not your contract, although this prospectus provides a description of the material features of the MVA Account Option under your contract. The description of the MVA Account Option’s material features is current as of the date of this prospectus. If certain material provisions of the MVA Account Option are changed after the date of this prospectus, those changes will be described in a supplement to this prospectus and the supplement will become a part of this prospectus.
The principal underwriter for all of the Contracts (except the Allstate Variable Annuity and the Allstate Variable Annuity (L Share)) is Allstate Distributors, L.L.C. (ADLLC), a wholly-owned subsidiary of Allstate Life. The principal underwriter for the Allstate Variable Annuity and the Allstate Variable Annuity (L Share)) is Morgan Stanley & Co LLC (Morgan Stanley & Co.), a wholly-owned subsidiary of Morgan Stanley. ADLLC and Morgan Stanley & Co. are registered broker dealers under the Securities Exchange Act of 1934, as amended (the Exchange Act), and are members of the Financial Industry Regulatory Authority. ADLLC and Morgan Stanley & Co. are not required to sell any specific number or dollar amount of securities, but will use their best efforts to sell the securities offered.
Discussion of Risk Factors begins on page 4 of this prospectus.
Please read and keep this Prospectus for future reference. You should carefully read this prospectus in conjunction with any applicable supplements before taking any action involving the MVA Account Option. This Prospectus supersedes all prior prospectuses. Also, this Prospectus must be read along with the appropriate variable annuity contract prospectus. This Prospectus is in addition to the appropriate variable annuity contract prospectus. All information in the appropriate variable annuity contract prospectus continues to apply unless addressed by this Prospectus.
IMPORTANT NOTICES
Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved of the securities described in this prospectus or passed on the accuracy or the adequacy of this prospectus. Anyone who tell you otherwise is committing a federal crime.
The contracts of which the MVA Account Option is a part may have been distributed through broker-dealers that have relationships with banks or other financial institutions or by employees of such banks. However, the contracts and the MVA Account Option are not deposits or obligations of, or guaranteed by such institutions or any federal regulatory agency. Investment in the MVA Account Option involves investment risks, including possible loss of principal.
This prospectus does not constitute an offering in any jurisdiction in which such offering may not lawfully be made. We do not authorize anyone to provide any information or representations regarding the offering described in this prospectus other than as contained in this prospectus.
The Contracts and the MVA Account Option are not FDIC insured.
The MVA Account Option may not be available in all states.
Table of Contents
Page
Risk Factors
Who is Allstate Life Insurance Company?
Important Terms
Expenses
Description of the MVA Account Option
Distribution of the contracts
Additional Information
Reliance on Rule 12h-7
Experts
Legal Matters
Annual Reports and Other Documents
Disclosure of Commission Position on Indemnification for Securities Act Liabilities
Appendix I: Market Value Adjustment Examples
Appendix II: Information with Respect to the Registrant
Risk Factors
Responsive information is incorporated by reference to Part I, Item 1A in the Company’s Annual Report on Form 10-K, SEC File No. 000-31248, filed on February 28, 2020. A pandemic such as COVID-19 and its impacts were contemplated in many of the risk factors set forth under "Item 1A. Risks Factors’’ in our Annual Report on Form 10-K for the year ended December 31, 2019. Risks related to a pandemic and economic uncertainty are described in our risk factors titled "A large-scale pandemic, the occurrence of terrorism or military actions may have an adverse effect on our business" and "Conditions in the global economy and capital markets could adversely affect our business and results of operations." Currently, it is not possible to reliably estimate the length and severity of the pandemic or its impact to our operations, but the effects could be material.
Who is Allstate Life Insurance Company?
Allstate Life is the issuer of the variable annuity contracts under which the MVA Account Option is an investment option. Allstate Life was organized in 1957 as a stock life insurance company under the State of Illinois.
Allstate Life is a wholly-owned subsidiary of Allstate Insurance Company, a stock property-liability insurance company organized under the laws of the state of Illinois. All of the capital stock issued and outstanding of Allstate Insurance Company is owned by The Allstate Corporation.
Allstate Life is licensed to operate in the District of Columbia, Puerto Rico, and all jurisdictions except the State of New York. We intend to offer the MVA Account Option under variable annuity contracts in those jurisdictions in which we are licensed. Our home office is located at 3075 Sanders Road, Northbrook, Illinois 60062.
The registrant’s obligations under the contract are subject to the financial strength and claims paying ability of the registrant.
Refer to Appendix II: Information with Respect to the Registrant for additional information about Allstate Life.
4 PROSPECTUS
Important Terms
30-Day MVA Window – as defined on page 6.
Allstate Life (or the Company) – Allstate Life Insurance Company, the issuer of the variable annuity contracts under which the MVA Account Option is available.
Contracts – The Allstate Advisor, Allstate Advisor Plus, Allstate Advisor Preferred, Allstate Variable Annuity, Allstate Variable Annuity (L Share) and STI Classic Variable Annuity variable annuity contracts issued by Allstate Life under which the MVA Account Option is available.
Contract Value – During the accumulation phase, the sum of the value of your interest in the variable sub-accounts you have selected, plus your value in the fixed account option(s) offered by your Contract, including the MVA Account Option.
Death Proceeds – the death settlement as provided in the applicable Contract.
Fixed Account Option – Investment options offered under the Contracts through our general account that credit interest at rates we guarantee. The MVA Account Option is a Fixed Account Option.
Market Value Adjustment – A calculation we apply to reflect changes in interest rates from the time you first allocate money to a Market Value Adjusted Fixed Guarantee Period Account to the time the money is taken out of that Market Value Adjusted Fixed Guarantee Period Account under specified circumstances. The Market Value Adjustment may be positive or negative, depending on changes in interest rates. As such, you bear the investment risk associated with changes in interest rates.
Market Value Adjusted Fixed Guarantee Period or Guarantee Period – as defined on page 5.
Market Value Adjusted Fixed Guarantee Period Account – as defined on page 5.
Market Value Adjustment Date – as defined on page 10.
MVA Account Option – the Market Value Adjusted Fixed Account Option available under the Contracts, which is referred to as Guaranteed Maturity Amount Fixed Account under the STI Classic variable annuity contract.
New Account Start Date – as defined on page 7.
Payout Start Date – the date we apply your money under the Contract to provide income payments.
Treasury Rate – the U.S. Treasury Note Constant Maturity Yield as reported in Federal Reserve Board Statistical Release H.15. If such yields cease to be available, then we will use an alternate source for such information in our discretion.
5 PROSPECTUS
Expenses
There is no charge that applies specifically to the MVA Account Option. However, certain charges under certain base variable annuity contracts and riders added to the base contract are based on (i) the Contract Value, which includes the value held in the MVA Account Option, or (ii) net premiums, including premiums allocated to the MVA Account Option. Please refer to the appropriate variable annuity contract for more information as to these charges.
Description of the MVA Account Option
The MVA Account Option offers fixed interest rates that we guarantee for specified periods we call Guarantee Period Accounts. You may allocate new premium or existing Contract Value to the MVA Account Option. You may select the period for which the interest rate on our allocation will be guaranteed (the Guarantee Period) from among the Guarantee Periods we are then offering. Each allocation will establish a separate Guarantee Period Account. At the end of each Guarantee Period, you may choose to roll over the value of that Guarantee Period Account into a new Guarantee Period or allocate the value of that Guarantee Period Account to another investment option available under your variable annuity contract. If you withdraw Contract Value from a Guarantee Period Account prior to its expiration, a Market Value Adjustment (which can be positive or negative) will apply, except for withdrawals taken during the 10-day period after the expiration of a Guarantee Period Account.
You may allocate purchase payments or transfer amounts into the MVA Account Option. Each such allocation establishes a Guarantee Period Account within the MVA Account Option (“Market Value Adjusted Fixed Guarantee Period Account”), which is defined by the date of the allocation and the length of the initial interest rate guarantee period (“Market Value Adjusted Fixed Guarantee Period” or “Guarantee Period”). You may not allocate a purchase payment or transfer to any existing Guarantee Period Account. Each purchase payment or transfer allocated to a Market Value Adjusted Fixed Guarantee Period Account must be at least $100.
At the time you allocate a purchase payment or transfer amount to the MVA Account Option, you must select the Guarantee Period for that allocation from among the Market Value Adjusted Fixed Guarantee Periods available for the MVA Account Option. We currently offer Market Value Adjusted Fixed Guarantee Periods of 3, 5, 7, and 10 years. Market Value Adjusted Fixed Guarantee Periods of 3, 5, and 7 years may not be available in all states. We may offer other Guarantee Periods in the future. If you allocate a purchase payment to the MVA Account Option, but do not select a Market Value Adjusted Fixed Guarantee Period for the new Market Value Adjusted Fixed Guarantee Period Account, we will allocate the purchase payment or transfer to a new Market Value Adjusted Fixed Guarantee Per
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CORRESP 1 filename1.htm ALIC Model 2 Correspondence 4-5-20 Combined Document May 1, 2020 Sonny Oh Senior Counsel Disclosure Review Office U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Dear Mr. Oh, Please see our responses below addressing your follow-up comments on the Allstate MVA Account Option under Certain Variable Annuity Contracts (File No. 333-236836) given over the phone on April 28, 2020. We have included the applicable comments from your letter dated April 6, 2020, followed by our response in bold to your follow-up questions pertaining to the original comments. The page numbers in our responses refer to the attached redline of the prospectus reflecting our updates in response to your most recent comments. (1)(c) Significant market events have occurred since this registration statement was filed as a result of the COVID-19 pandemic. Please consider whether the Company’s disclosures, including market risk disclosures, should be revised based on how these events are affecting the markets of the index that the Company is using to calculate the Company’s obligations under the contract. Further, given that the Company’s obligations under the contract are subject to the financial strength and claims-paying ability of the Company, please consider whether this disclosure should be revised based on how these events could affect the Company’s financial strength and claims-paying ability. If the Company believes that no additional disclosure is warranted, please explain supplementally why not. Response: We updated the Risk Factors section to add quotation marks where appropriate (see page 4). (3)(a) Again, although incorporation by reference for Item 3 is permissible, Item 502(a) of Reg S-K does require that the table of contents include "Risk Factors" required by Item 105 of Reg S-K. Response: We updated the Risk Factors section to delete “Item 3” from the heading (see page 4). (3)(d) The Important Terms section beginning on page 4 includes a definition of a “Credit Enhancement,” but the term only appears in the last paragraph on page 6. Please delete the term or confirm the term has been incorporated everywhere necessary in the prospectus. Response: We updated the Description of the MVA Account Option discussion to delete the parenthetical reference to the term “Credit Enhancement” (see page 7). (5)(c) In the first paragraph on page 7, please clarify supplementally whether the reference to a 4.5% Treasury Rate is representative of rates actually offered over the last few years and, if not, why it’s not misleading to use it here. Response: We updated the Description of the MVA Account Option discussion to clarify that the example rate is for illustrative purposes (see page 7). (9) Please provide file numbers for documents incorporated by reference. Please also provide all disclosure in the first paragraph required by Item 12(a)(2) of Form S-1, and you may delete the third and second to last sentences of the paragraph. Response: We updated the Annual Reports and Other Documents discussion to remove the second instance of “filed pursuant” (see page 10). (10) Please revise for a clearer explanation of “for the week preceding” in defining “I” and “J” and what .9 represents, and reconcile the reference to “denominator” in the second to last paragraph of the page. Please also specify what “N” stands for and if N is less than 365 days (i.e., example reflects more specificity) and briefly explain why .0025 is added. Response: We updated the Market Value Adjustment discussion to revise the definitions of “I” and “J,” describe what “.9” represents in the MVA formula, and provide a plain English explanation of the .0025 factor in the formula (see page 11). We trust that these responses address your comments. If you have any questions, let me know. Thanks, /s/ Iman Naim Iman Naim Senior Associate Counsel (847) 402-6222 inaim@allstate.com Market Value Adjusted Fixed Account Under Certain Variable Annuity Contracts Issued by Allstate Life Insurance Company Allstate Life Insurance Company Street Address: 5801 SW 6th Ave., Topeka, KS 66606-00001 Mailing Address: P.O. Box 758566, Topeka, KS 66675-8566 Telephone Number: 1-800-457-7617 Fax Number: 1-785-228-4584 Prospectus dated May 1, 2020 Allstate Life Insurance Company (“Allstate Life” or the “Company”) issues the Market Value Adjusted Fixed Account Option (the “MVA Account Option”) described in this prospectus. The MVA Option is available only under the following variable annuity contracts that we offer: Allstate Advisor; Allstate Advisor Plus, Allstate Advisor Preferred, Allstate Variable Annuity, Allstate Variable Annuity (L Share), STI Classic Variable Annuity, Advisor - STI, and Advisor Preferred - STI. None of those contracts currently are offered for new sales. However, under outstanding contracts you may be able to make additional purchase payments and allocate additional purchase payments or amounts of Contract Value to the MVA Account Option. This prospectus is not your contract, although this prospectus provides a description of the material features of the MVA Account Option under your contract. The description of the MVA Account Option’s material features is current as of the date of this prospectus. If certain material provisions of the MVA Account Option are changed after the date of this prospectus, those changes will be described in a supplement to this prospectus and the supplement will become a part of this prospectus. The principal underwriter for all of the Contracts (except the Allstate Variable Annuity and the Allstate Variable Annuity (L Share)) is Allstate Distributors, L.L.C. (ADLLC), a wholly-owned subsidiary of Allstate Life. The principal underwriter for the Allstate Variable Annuity and the Allstate Variable Annuity (L Share)) is Morgan Stanley & Co LLC (Morgan Stanley & Co.), a wholly-owned subsidiary of Morgan Stanley. ADLLC and Morgan Stanley & Co. are registered broker dealers under the Securities Exchange Act of 1934, as amended (the Exchange Act), and are members of the Financial Industry Regulatory Authority. ADLLC and Morgan Stanley & Co. are not required to sell any specific number or dollar amount of securities, but will use their best efforts to sell the securities offered. Discussion of Risk Factors begins on page 4 of this prospectus. Please read and keep this Prospectus for future reference. You should carefully read this prospectus in conjunction with any applicable supplements before taking any action involving the MVA Account Option. This Prospectus supersedes all prior prospectuses. Also, this Prospectus must be read along with the appropriate variable annuity contract prospectus. This Prospectus is in addition to the appropriate variable annuity contract prospectus. All information in the appropriate variable annuity contract prospectus continues to apply unless addressed by this Prospectus. IMPORTANT NOTICES Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved of the securities described in this prospectus or passed on the accuracy or the adequacy of this prospectus. Anyone who tell you otherwise is committing a federal crime. The contracts of which the MVA Account Option is a part may have been distributed through broker-dealers that have relationships with banks or other financial institutions or by employees of such banks. However, the contracts and the MVA Account Option are not deposits or obligations of, or guaranteed by such institutions or any federal regulatory agency. Investment in the MVA Account Option involves investment risks, including possible loss of principal. This prospectus does not constitute an offering in any jurisdiction in which such offering may not lawfully be made. We do not authorize anyone to provide any information or representations regarding the offering described in this prospectus other than as contained in this prospectus. The Contracts and the MVA Account Option are not FDIC insured. The MVA Account Option may not be available in all states. Table of Contents Page Risk Factors 4 Who is Allstate Life Insurance Company? 4 Important Terms 5 Expenses 6 Description of the MVA Account Option 6 Distribution of the contracts 9 Additional Information 9 Reliance on Rule 12h-7 9 Experts 9 Legal Matters 10 Annual Reports and Other Documents 10 Disclosure of Commission Position on Indemnification for Securities Act Liabilities 10 Appendix I: Market Value Adjustment Examples 11 Appendix II: Information with Respect to the Registrant 14 Risk Factors Responsive information is incorporated by reference to Part I, Item 1A in the Company’s Annual Report on Form 10-K, SEC File No. 000-31248, filed on February 28, 2020. A pandemic such as COVID-19 and its impacts were contemplated in many of the risk factors set forth under "Item 1A. Risks Factors’’ in our Annual Report on Form 10-K for the year ended December 31, 2019. Risks related to a pandemic and economic uncertainty are described in our risk factors titled "A large-scale pandemic, the occurrence of terrorism or military actions may have an adverse effect on our business" and "Conditions in the global economy and capital markets could adversely affect our business and results of operations." Currently, it is not possible to reliably estimate the length and severity of the pandemic or its impact to our operations, but the effects could be material. Who is Allstate Life Insurance Company? Allstate Life is the issuer of the variable annuity contracts under which the MVA Account Option is an investment option. Allstate Life was organized in 1957 as a stock life insurance company under the State of Illinois. Allstate Life is a wholly-owned subsidiary of Allstate Insurance Company, a stock property-liability insurance company organized under the laws of the state of Illinois. All of the capital stock issued and outstanding of Allstate Insurance Company is owned by The Allstate Corporation. Allstate Life is licensed to operate in the District of Columbia, Puerto Rico, and all jurisdictions except the State of New York. We intend to offer the MVA Account Option under variable annuity contracts in those jurisdictions in which we are licensed. Our home office is located at 3075 Sanders Road, Northbrook, Illinois 60062. The registrant’s obligations under the contract are subject to the financial strength and claims paying ability of the registrant. Refer to Appendix II: Information with Respect to the Registrant for additional information about Allstate Life. 4 PROSPECTUS Important Terms 30-Day MVA Window – as defined on page 6. Allstate Life (or the Company) – Allstate Life Insurance Company, the issuer of the variable annuity contracts under which the MVA Account Option is available. Contracts – The Allstate Advisor, Allstate Advisor Plus, Allstate Advisor Preferred, Allstate Variable Annuity, Allstate Variable Annuity (L Share) and STI Classic Variable Annuity variable annuity contracts issued by Allstate Life under which the MVA Account Option is available. Contract Value – During the accumulation phase, the sum of the value of your interest in the variable sub-accounts you have selected, plus your value in the fixed account option(s) offered by your Contract, including the MVA Account Option. Death Proceeds – the death settlement as provided in the applicable Contract. Fixed Account Option – Investment options offered under the Contracts through our general account that credit interest at rates we guarantee. The MVA Account Option is a Fixed Account Option. Market Value Adjustment – A calculation we apply to reflect changes in interest rates from the time you first allocate money to a Market Value Adjusted Fixed Guarantee Period Account to the time the money is taken out of that Market Value Adjusted Fixed Guarantee Period Account under specified circumstances. The Market Value Adjustment may be positive or negative, depending on changes in interest rates. As such, you bear the investment risk associated with changes in interest rates. Market Value Adjusted Fixed Guarantee Period or Guarantee Period – as defined on page 5. Market Value Adjusted Fixed Guarantee Period Account – as defined on page 5. Market Value Adjustment Date – as defined on page 10. MVA Account Option – the Market Value Adjusted Fixed Account Option available under the Contracts, which is referred to as Guaranteed Maturity Amount Fixed Account under the STI Classic variable annuity contract. New Account Start Date – as defined on page 7. Payout Start Date – the date we apply your money under the Contract to provide income payments. Treasury Rate – the U.S. Treasury Note Constant Maturity Yield as reported in Federal Reserve Board Statistical Release H.15. If such yields cease to be available, then we will use an alternate source for such information in our discretion. 5 PROSPECTUS Expenses There is no charge that applies specifically to the MVA Account Option. However, certain charges under certain base variable annuity contracts and riders added to the base contract are based on (i) the Contract Value, which includes the value held in the MVA Account Option, or (ii) net premiums, including premiums allocated to the MVA Account Option. Please refer to the appropriate variable annuity contract for more information as to these charges. Description of the MVA Account Option The MVA Account Option offers fixed interest rates that we guarantee for specified periods we call Guarantee Period Accounts. You may allocate new premium or existing Contract Value to the MVA Account Option. You may select the period for which the interest rate on our allocation will be guaranteed (the Guarantee Period) from among the Guarantee Periods we are then offering. Each allocation will establish a separate Guarantee Period Account. At the end of each Guarantee Period, you may choose to roll over the value of that Guarantee Period Account into a new Guarantee Period or allocate the value of that Guarantee Period Account to another investment option available under your variable annuity contract. If you withdraw Contract Value from a Guarantee Period Account prior to its expiration, a Market Value Adjustment (which can be positive or negative) will apply, except for withdrawals taken during the 10-day period after the expiration of a Guarantee Period Account. You may allocate purchase payments or transfer amounts into the MVA Account Option. Each such allocation establishes a Guarantee Period Account within the MVA Account Option (“Market Value Adjusted Fixed Guarantee Period Account”), which is defined by the date of the allocation and the length of the initial interest rate guarantee period (“Market Value Adjusted Fixed Guarantee Period” or “Guarantee Period”). You may not allocate a purchase payment or transfer to any existing Guarantee Period Account. Each purchase payment or transfer allocated to a Market Value Adjusted Fixed Guarantee Period Account must be at least $100. At the time you allocate a purchase payment or transfer amount to the MVA Account Option, you must select the Guarantee Period for that allocation from among the Market Value Adjusted Fixed Guarantee Periods available for the MVA Account Option. We currently offer Market Value Adjusted Fixed Guarantee Periods of 3, 5, 7, and 10 years. Market Value Adjusted Fixed Guarantee Periods of 3, 5, and 7 years may not be available in all states. We may offer other Guarantee Periods in the future. If you allocate a purchase payment to the MVA Account Option, but do not select a Market Value Adjusted Fixed Guarantee Period for the new Market Value Adjusted Fixed Guarantee Period Account, we will allocate the purchase payment or transfer to a new Market Value Adjusted Fixed Guarantee Per