Correspondence 0000777917-22-000108 from PRUCO LIFE INSURANCE CO (CIK 0000777917)
PRUCO LIFE INSURANCE CO (CIK 0000777917)
Date: Nov. 17, 2022 · CIK: 0000777917 · Accession: 0000777917-22-000108
AI Filing Summary & Sentiment
File numbers found in text: 333-256966, 333-265370, 333-265387
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Post-Effective Amendment No. 1 to Registration Statement on Form S-3 File No. 333-265370 Post-Effective Amendment No. 1 to Registration Statement on Form S-3 File No. 333-265387
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on October 19, 2022 to the Post-Effective Amendment filings noted above, including the prospectuses for FlexGuard B Series and FlexGuard Income B Series contracts issued by Pruco Life Insurance Company (Pruco Life). Included with this submission is a revised prospectus for the FlexGuard Income B Series contract issued by Pruco Life, which includes the changes described below. The Staff’s comments and our responses are as follows.
A.FlexGuard Income B Series Prospectus
1.General Comment:
Going forward, the addition or substitution of new index options to the product requires a POSAM filing by the Registrant so the SEC staff can review the new index disclosure. The addition or substitution of new index options is not permitted through filing a Rule 424(b)(3) supplement.
Response:
As requested, going forward we will make POSAM filings for the addition or substitution of new index options.
2.General Comment:
Disclosure statements regarding Registrant’s ability to vary or change cap rates, par rates, buffers, indexes and index strategies must include conditional language disclosing any contractual or regulatory limitations, such as that such changes are subject to guaranteed minimum rates.
Alberto H. Zapata, Esq.
November 17, 2022
Page 2
Response:
As requested, we have made these changes. See Responses below.
3.Comment:
On page 1 of the prospectus in the “Special Terms” section, the last sentence of the definition of “Buffer” states that “Buffers may vary by Index and Index Strategy Term.” Please condition the statement by stating that Buffer levels are subject to the minimum Buffer level permitted under the contract and stating that Buffer level.
Response:
As requested, we have added the phrase to the sentence at issue, “subject to the minimum Buffer level of 5%.”
4.Comment:
On page 1 of the prospectus in the “Special Terms” section, the definition of “Cap Rate” refers to the Guaranteed Minimum Cap Rate. Please state what the Guaranteed Minimum Cap Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Cap Rate equals 1.00% for a one-year Index Strategy Term, 5.00% for a three-year Index Strategy Term and 10.00% for a six-year Index Strategy Term.”
5.Comment:
Confirm that the changes to the definitions of “Buffer” and “Cap Rate” in the “Special Terms” section do not impact or change the index crediting strategies.
Response:
We confirm that the changes to the definitions of “Buffer” and “Cap Rate” in the “Special Terms” section do not impact or change the index crediting strategies.
6.Comment:
On page 3 of the prospectus in the “Special Terms” section, the definition of “Participation Rate” refers to the Guaranteed Minimum Participation Rate. Please state what the Guaranteed Minimum Participation Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Participation Rate equals 100% for the Tiered Participation Rate Index Strategy. The Guaranteed Minimum Participation Rate equals 60% for the Step Rate Plus Index Strategy.”
7.Comment:
On page 3 of the prospectus in the “Special Terms” section, the date included in the Performance Lock definition (January 18, 2022) is different than the date included in the description of Performance Lock on page 22 (November 15, 2022). Should the dates be the same?
Alberto H. Zapata, Esq.
November 17, 2022
Page 3
Response:
The two dates should be the same and both will be updated to December 15, 2022.
8.Comment:
On page 3 of the prospectus in the “Special Terms” section, the definition of “Step Rate” refers to the Guaranteed Minimum Step Rate. Please state what the Guaranteed Minimum Step Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Step Rate equals 1.00% for the Step Rate Plus Index Strategy.”
9.Comment:
On page 5 of the prospectus in the “Summary” section, the new sentence added at the end of the second paragraph (“Although this prospectus describes key features of the Annuity contract, the prospectus is a distinct document, and is not part of the Contract.”) repeats a sentence in the first paragraph on page 5.
Response:
We have deleted the sentence added in the second paragraph.
10.Comment:
On page 7 of the prospectus in the “Summary” section, the second sentence of the first paragraph discloses that Pruco Life reserves the right to add and remove index strategies at any time as a result of economic market conditions, or utilization of the index strategies. This disclosure should be conditioned by adding disclosure that an index strategy will not be removed during an index term and that the addition of an index strategy is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that the addition or removal of an index strategy is subject to regulatory requirements and approvals. We have also added disclosure that removal of an index strategy would not impact existing contract holders currently allocated to an index strategy prior to the index strategy end date.
11.Comment:
On page 7 of the prospectus in the “Indices” subsection of the “Summary” section, we disclose that Pruco Life reserves the right to add and remove an index at any time. This disclosure should be conditioned by adding disclosure that an addition or substitution of a new index is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that an addition or substitution of a new index is subject to regulatory requirements and approvals.
Alberto H. Zapata, Esq.
November 17, 2022
Page 4
12.Comment:
On page 8 of the prospectus, explain why the first sentence in the fourth paragraph was deleted (“You may transfer Account Value between Variable Investment Subaccounts or from Index Strategies to Variable Investment Subaccounts at any time during the Savings Stage of the Benefit”).
Response:
This sentence was deleted because: (i) we currently offer only one Variable Investment Subaccount on the product, and (ii) for new business on or after December 15, 2022, transfers from the Index Strategies to the Variable Investment Subaccount are not permissible at any time during the life of the Annuity. Statement (ii) is disclosed in the “Managing Your Account Value” section of the prospectus on page 39.
13.Comment:
On page 9 of the prospectus in the “Risk Factors” section, “Limitation on Index Strategy Returns – Cap Rate” subsection, add disclosure that Cap Rates are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “Cap Rates will never be less than the Guaranteed Minimum Cap Rates. The Guaranteed Minimum Cap Rate equals 1.00% for a one-year Index Strategy Term, 5.00% for a three-year Index Strategy Term and 10.00% for a six-year Index Strategy Term.”
14.Comment:
On page 9 of the prospectus in the “Risk Factors” section, “Index Strategy Returns – Participation Rates” subsection, add disclosure that Participation Rates are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “Participation Rates will never be less than the Guaranteed Minimum Participation Rate. The Guaranteed Minimum Participation Rate equals 100% for the Tiered Participation Rate Index Strategy and equals 60% for the Step Rate Plus Index Strategy.”
15.Comment:
On page 10 of the prospectus in the “Risk Factors” section, “Availability of Index Strategies will vary over time” subsection, Pruco Life reserves the right to change Cap Rates, Participation Rates, Step Rates and Buffers at any time. Add disclosure that Cap Rates, Participation Rates, Step Rates and Buffers are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “We reserve the right to change Cap Rates, Participation Rates, Step Rates and Buffers at any time, subject to Guaranteed Minimum Rates and minimum Buffer level. Guaranteed Minimum Rates for each Index Strategy and the minimum Buffer level are disclosed in the ‘Special Terms’ section under the definitions of Cap Rates, Participation Rates, Step Rates and Buffer.”
16.Comment:
On page 10 of the prospectus in the “Risk Factors” section, “Reallocation of Index Strategies” subsection, there is reference to Guaranteed Minimum Rates for Cap Rates, Participation Rates and Step Rates. State what the Guaranteed Minimum Rates are for Cap Rates, Participation Rates and Step Rates for each Index Strategy.
Alberto H. Zapata, Esq.
November 17, 2022
Page 5
Response:
As requested, we have added the following disclosure: “Guaranteed Minimum Rates for each Index Strategy are disclosed in the ‘Special Terms’ section under the definitions of Cap Rates, Participation Rates and Step Rates.”
17.Comment:
On page 13 of the prospectus in the second paragraph of the “Index Strategies” section, we disclose that Pruco Life reserves the right to add and remove index strategies at any time as a result of economic market conditions, or utilization of the index strategies. This disclosure should be conditioned by adding disclosure that an index strategy will not be removed during an index term and that any addition of an index strategy is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that the addition or removal of an index strategy is subject to regulatory requirements and approvals. We currently include disclosure that removal of an index strategy would not impact existing contract holders currently allocated to an index strategy prior to the index strategy end date.
18.Comment:
On page 13 of the prospectus in the “Index Strategies” section, “Indices” subsection, with respect to the description of the AB 500 Plus Index, (i) provide additional disclosure explaining the phrase, “offering meaningful exposure to one of the most widely used equity indices” and (ii) revise the following phrase using Plain English disclosure, “From there, the Index adds a proprietary signal . . . .”
Response:
We have revised the disclosure describing the AB 500 Plus Index as follows below, including removing the phrases noted above in the Comment.
“The AB 500 Plus IndexSM is a rules based, allocation index that utilizes the SPDR® S&P 500® ETF Trust as its default allocation. The Index will tactically reallocate to additional US listed equity index ETFs: Invesco QQQ TrustSM, SERIES 1 ETF, iShares® Russell 2000 ETF, Shares® MSCI EAFE ETF, and iShares® MSCI Emerging Markets ETF when our proprietary positioning signals indicate that those other equity index ETFs have a higher expected return potential than the default allocation. At all times, the Index is fully allocated to equity index ETFs, with a significant allocation to equity index ETFs that track US listed companies. By following proprietary positioning signals, the Index aims to maintain significant exposure to the SPDR® S&P 500® ETF Trust, while providing differentiated returns through a tactical reallocation process.”
19.Comment:
On page 14 of the prospectus in the “Index Strategies” section, “Buffers” subsection, add disclosure stating the minimum Buffer level under the contract.
Response:
As requested, we have added the following disclosure in the “Buffers” subsection, “The minimum Buffer level offered under the Annuity is 5%.”
20.Comment:
On page 17 of the prospectus in the description of the Dual Directional index strategy, Example 5, suggest removing the phrase, “there would be a loss of Account Value because . . .”
Response:
Alberto H. Zapata, Esq.
November 17, 2022
Page 6
We have made the suggested revision so that Example 5 now reads, “Example 5: If the Index decreased by 12%, which is greater than the 10% Buffer, the Index Credit would be -2%.”
21.Comment:
On page 17 of the prospectus in the description of the Dual Directional index strategy, in the last paragraph include disclosure stating the Guaranteed Minimum Cap Rate for each index strategy term.
Response:
We have included the following disclosure in the paragraph at issue, “The Guaranteed Minimum Cap Rate equals 10.00% for a six-year Index Strategy Term.” Note that the Dual Directional index strategy is only offered for a six-year index strategy term.
B.FlexGuard B Series Prospectus
1.Comment:
Incorporate as applicable corresponding comments from the FlexGuard Income B Series prospectus.
Response:
We have made the applicable changes to the prospectus for the FlexGuard B Series contract.
If you have any questions, please call me at (203) 925-3707.
Very truly yours,
/s/Richard H. Kirk
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CORRESP
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filename1.htm
S-3 FlexGuard Income Response to SEC Comments11.17.22
Richard H. Kirk
Vice President, Corporate Counsel
The Prudential Insurance Company of America
213 Washington Street, Newark, NJ 07102-2917
Tel 203-925-3707
richard.kirk@prudential.com
November 17, 2022
VIA EDGAR
Alberto H. Zapata, Esq.
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Responses to SEC Staff Comments
Pruco Life Insurance Company
Post-Effective Amendment No. 1 to Registration Statement on Form S-3
File No. 333-265370
Post-Effective Amendment No. 1 to Registration Statement on Form S-3
File No. 333-265387
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on October 19, 2022 to the Post-Effective Amendment filings noted above, including the prospectuses for FlexGuard B Series and FlexGuard Income B Series contracts issued by Pruco Life Insurance Company (Pruco Life). Included with this submission is a revised prospectus for the FlexGuard Income B Series contract issued by Pruco Life, which includes the changes described below. The Staff’s comments and our responses are as follows.
A.FlexGuard Income B Series Prospectus
1.General Comment:
Going forward, the addition or substitution of new index options to the product requires a POSAM filing by the Registrant so the SEC staff can review the new index disclosure. The addition or substitution of new index options is not permitted through filing a Rule 424(b)(3) supplement.
Response:
As requested, going forward we will make POSAM filings for the addition or substitution of new index options.
2.General Comment:
Disclosure statements regarding Registrant’s ability to vary or change cap rates, par rates, buffers, indexes and index strategies must include conditional language disclosing any contractual or regulatory limitations, such as that such changes are subject to guaranteed minimum rates.
Alberto H. Zapata, Esq.
November 17, 2022
Page 2
Response:
As requested, we have made these changes. See Responses below.
3.Comment:
On page 1 of the prospectus in the “Special Terms” section, the last sentence of the definition of “Buffer” states that “Buffers may vary by Index and Index Strategy Term.” Please condition the statement by stating that Buffer levels are subject to the minimum Buffer level permitted under the contract and stating that Buffer level.
Response:
As requested, we have added the phrase to the sentence at issue, “subject to the minimum Buffer level of 5%.”
4.Comment:
On page 1 of the prospectus in the “Special Terms” section, the definition of “Cap Rate” refers to the Guaranteed Minimum Cap Rate. Please state what the Guaranteed Minimum Cap Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Cap Rate equals 1.00% for a one-year Index Strategy Term, 5.00% for a three-year Index Strategy Term and 10.00% for a six-year Index Strategy Term.”
5.Comment:
Confirm that the changes to the definitions of “Buffer” and “Cap Rate” in the “Special Terms” section do not impact or change the index crediting strategies.
Response:
We confirm that the changes to the definitions of “Buffer” and “Cap Rate” in the “Special Terms” section do not impact or change the index crediting strategies.
6.Comment:
On page 3 of the prospectus in the “Special Terms” section, the definition of “Participation Rate” refers to the Guaranteed Minimum Participation Rate. Please state what the Guaranteed Minimum Participation Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Participation Rate equals 100% for the Tiered Participation Rate Index Strategy. The Guaranteed Minimum Participation Rate equals 60% for the Step Rate Plus Index Strategy.”
7.Comment:
On page 3 of the prospectus in the “Special Terms” section, the date included in the Performance Lock definition (January 18, 2022) is different than the date included in the description of Performance Lock on page 22 (November 15, 2022). Should the dates be the same?
Alberto H. Zapata, Esq.
November 17, 2022
Page 3
Response:
The two dates should be the same and both will be updated to December 15, 2022.
8.Comment:
On page 3 of the prospectus in the “Special Terms” section, the definition of “Step Rate” refers to the Guaranteed Minimum Step Rate. Please state what the Guaranteed Minimum Step Rate is for each index strategy.
Response:
As requested, we have added the following disclosure to the definition: “The Guaranteed Minimum Step Rate equals 1.00% for the Step Rate Plus Index Strategy.”
9.Comment:
On page 5 of the prospectus in the “Summary” section, the new sentence added at the end of the second paragraph (“Although this prospectus describes key features of the Annuity contract, the prospectus is a distinct document, and is not part of the Contract.”) repeats a sentence in the first paragraph on page 5.
Response:
We have deleted the sentence added in the second paragraph.
10.Comment:
On page 7 of the prospectus in the “Summary” section, the second sentence of the first paragraph discloses that Pruco Life reserves the right to add and remove index strategies at any time as a result of economic market conditions, or utilization of the index strategies. This disclosure should be conditioned by adding disclosure that an index strategy will not be removed during an index term and that the addition of an index strategy is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that the addition or removal of an index strategy is subject to regulatory requirements and approvals. We have also added disclosure that removal of an index strategy would not impact existing contract holders currently allocated to an index strategy prior to the index strategy end date.
11.Comment:
On page 7 of the prospectus in the “Indices” subsection of the “Summary” section, we disclose that Pruco Life reserves the right to add and remove an index at any time. This disclosure should be conditioned by adding disclosure that an addition or substitution of a new index is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that an addition or substitution of a new index is subject to regulatory requirements and approvals.
Alberto H. Zapata, Esq.
November 17, 2022
Page 4
12.Comment:
On page 8 of the prospectus, explain why the first sentence in the fourth paragraph was deleted (“You may transfer Account Value between Variable Investment Subaccounts or from Index Strategies to Variable Investment Subaccounts at any time during the Savings Stage of the Benefit”).
Response:
This sentence was deleted because: (i) we currently offer only one Variable Investment Subaccount on the product, and (ii) for new business on or after December 15, 2022, transfers from the Index Strategies to the Variable Investment Subaccount are not permissible at any time during the life of the Annuity. Statement (ii) is disclosed in the “Managing Your Account Value” section of the prospectus on page 39.
13.Comment:
On page 9 of the prospectus in the “Risk Factors” section, “Limitation on Index Strategy Returns – Cap Rate” subsection, add disclosure that Cap Rates are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “Cap Rates will never be less than the Guaranteed Minimum Cap Rates. The Guaranteed Minimum Cap Rate equals 1.00% for a one-year Index Strategy Term, 5.00% for a three-year Index Strategy Term and 10.00% for a six-year Index Strategy Term.”
14.Comment:
On page 9 of the prospectus in the “Risk Factors” section, “Index Strategy Returns – Participation Rates” subsection, add disclosure that Participation Rates are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “Participation Rates will never be less than the Guaranteed Minimum Participation Rate. The Guaranteed Minimum Participation Rate equals 100% for the Tiered Participation Rate Index Strategy and equals 60% for the Step Rate Plus Index Strategy.”
15.Comment:
On page 10 of the prospectus in the “Risk Factors” section, “Availability of Index Strategies will vary over time” subsection, Pruco Life reserves the right to change Cap Rates, Participation Rates, Step Rates and Buffers at any time. Add disclosure that Cap Rates, Participation Rates, Step Rates and Buffers are subject to contractual minimum rates and state those rates.
Response:
As requested, we have added the following disclosure: “We reserve the right to change Cap Rates, Participation Rates, Step Rates and Buffers at any time, subject to Guaranteed Minimum Rates and minimum Buffer level. Guaranteed Minimum Rates for each Index Strategy and the minimum Buffer level are disclosed in the ‘Special Terms’ section under the definitions of Cap Rates, Participation Rates, Step Rates and Buffer.”
16.Comment:
On page 10 of the prospectus in the “Risk Factors” section, “Reallocation of Index Strategies” subsection, there is reference to Guaranteed Minimum Rates for Cap Rates, Participation Rates and Step Rates. State what the Guaranteed Minimum Rates are for Cap Rates, Participation Rates and Step Rates for each Index Strategy.
Alberto H. Zapata, Esq.
November 17, 2022
Page 5
Response:
As requested, we have added the following disclosure: “Guaranteed Minimum Rates for each Index Strategy are disclosed in the ‘Special Terms’ section under the definitions of Cap Rates, Participation Rates and Step Rates.”
17.Comment:
On page 13 of the prospectus in the second paragraph of the “Index Strategies” section, we disclose that Pruco Life reserves the right to add and remove index strategies at any time as a result of economic market conditions, or utilization of the index strategies. This disclosure should be conditioned by adding disclosure that an index strategy will not be removed during an index term and that any addition of an index strategy is subject to regulatory requirements and approvals.
Response:
As requested, we have added disclosure that the addition or removal of an index strategy is subject to regulatory requirements and approvals. We currently include disclosure that removal of an index strategy would not impact existing contract holders currently allocated to an index strategy prior to the index strategy end date.
18.Comment:
On page 13 of the prospectus in the “Index Strategies” section, “Indices” subsection, with respect to the description of the AB 500 Plus Index, (i) provide additional disclosure explaining the phrase, “offering meaningful exposure to one of the most widely used equity indices” and (ii) revise the following phrase using Plain English disclosure, “From there, the Index adds a proprietary signal . . . .”
Response:
We have revised the disclosure describing the AB 500 Plus Index as follows below, including removing the phrases noted above in the Comment.
“The AB 500 Plus IndexSM is a rules based, allocation index that utilizes the SPDR® S&P 500® ETF Trust as its default allocation. The Index will tactically reallocate to additional US listed equity index ETFs: Invesco QQQ TrustSM, SERIES 1 ETF, iShares® Russell 2000 ETF, Shares® MSCI EAFE ETF, and iShares® MSCI Emerging Markets ETF when our proprietary positioning signals indicate that those other equity index ETFs have a higher expected return potential than the default allocation. At all times, the Index is fully allocated to equity index ETFs, with a significant allocation to equity index ETFs that track US listed companies. By following proprietary positioning signals, the Index aims to maintain significant exposure to the SPDR® S&P 500® ETF Trust, while providing differentiated returns through a tactical reallocation process.”
19.Comment:
On page 14 of the prospectus in the “Index Strategies” section, “Buffers” subsection, add disclosure stating the minimum Buffer level under the contract.
Response:
As requested, we have added the following disclosure in the “Buffers” subsection, “The minimum Buffer level offered under the Annuity is 5%.”
20.Comment:
On page 17 of the prospectus in the description of the Dual Directional index strategy, Example 5, suggest removing the phrase, “there would be a loss of Account Value because . . .”
Response:
Alberto H. Zapata, Esq.
November 17, 2022
Page 6
We have made the suggested revision so that Example 5 now reads, “Example 5: If the Index decreased by 12%, which is greater than the 10% Buffer, the Index Credit would be -2%.”
21.Comment:
On page 17 of the prospectus in the description of the Dual Directional index strategy, in the last paragraph include disclosure stating the Guaranteed Minimum Cap Rate for each index strategy term.
Response:
We have included the following disclosure in the paragraph at issue, “The Guaranteed Minimum Cap Rate equals 10.00% for a six-year Index Strategy Term.” Note that the Dual Directional index strategy is only offered for a six-year index strategy term.
B.FlexGuard B Series Prospectus
1.Comment:
Incorporate as applicable corresponding comments from the FlexGuard Income B Series prospectus.
Response:
We have made the applicable changes to the prospectus for the FlexGuard B Series contract.
If you have any questions, please call me at (203) 925-3707.
Very truly yours,
/s/Richard H. Kirk
Richard H. Kirk
Vice President, Corporate Counsel
THE INFORMATION IN THE PROSPECTUS IS NOT COMPLETE AND MAY BE CHANGED. WE MAY NOT SELL THESE SECURITIES UNTIL THE REGISTRATION STATEMENT FILED WITH THE SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THIS PROSPECTUS IS NOT AN OFFER TO SELL THESE SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED.
PRUCO LIFE INSURANCE COMPANY
A Prudential Financial Company
751 Broad Street, Newark, NJ 07102-3777
PRUDENTIAL FLEXGUARD® INCOME
Single Premium Deferred Index-Linked and Variable Annuity (“B SERIES”)
PROSPECTUS: [_______, 2022]
This prospectus describes the Index Strategy crediting options available with Prudential FlexGuard Income B Series, a single premium deferred index-linked and variable annuity (“Annuity”) offered by Pruco Life Insurance Company (“Pruco Life”, “we”, “our”, or “us”). The Annuity provides for the potential accumulation of retirement savings through investment in certain Index Strategies and Variable Investment Subaccount during the Savings Stage and opportunity for lifetime income through a built-in living benefit rider during the Income Stage and Insured Income Stage, as well as annuitization options. The Annuity is intended for retirement or other long-term investment purposes. The Variable Investment Subaccount options available with this Annuity are described in a separate prospectus, Prudential FlexGuard Income, Single Premium Deferred Index-Linked and Variable Annuity (B Series), File Number 333-256966 (the “Variable Subaccount Prospectus”) and can be found on our website at www.prudential.com/PLAZ-FlexGuard-Inc.
This prospectus is not your contract, although this prospectus provides a description of the material features of the Index Strategies under your contract. The description of the material features of the Index Strategies is current as of the date of this prospectus. If certain material provisions of the Index Strategies 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.
Clients seeking information regarding their p