Correspondence 0000777917-24-000042 from PRUCO LIFE INSURANCE CO (CIK 0000777917)
PRUCO LIFE INSURANCE CO (CIK 0000777917)
Date: June 4, 2024 · CIK: 0000777917 · Accession: 0000777917-24-000042
AI Filing Summary & Sentiment
File numbers found in text: 333-277924
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Re: Responses to SEC Staff Comments Pruco Life Insurance Company Registration Statement on Form S-3 File No. 333-277924
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on May 20, 2024 to the registration statement filing noted above, including the prospectus for FlexGuard Index Linked and Variable Annuity B Series contracts issued by Pruco Life Insurance Company (Pruco Life). Included with this submission is a revised prospectus for the FlexGuard B Series contract issued by Pruco Life, which includes the changes described below. The Staff’s comments and our responses are as follows.
1.Comment:
Why delete certain language in the first paragraph on the cover page?
Response:
This language was inadvertently deleted and has been restored.
Alberto H. Zapata, Esq.
June 4, 2024
Page 2
2.Comment:
Why delete the third and fourth paragraphs on the cover page?
Response:
The third and fourth paragraphs were inadvertently deleted and have been restored.
3.Comment:
Why delete the second paragraph on the third page of the cover pages?
Response:
The second paragraph was inadvertently deleted and has been restored.
4.Comment:
Why delete the “Other Contracts” section on the cover page?
Response:
The “Other Contracts” section was inadvertently deleted and has been restored.
5.Comment:
In the second paragraph of the cover page, the word “Contract” is used but is not a defined term.
Response:
We have added language on the cover page defining “Contract” as a defined term in the prospectus so its use in the second paragraph is appropriate.
6.Comment:
In the first paragraph on the cover page, the word “income” appears as two words, “in come.”
Response:
We have made this correction so “income” appears as one word.
7.Comment:
On the cover page, add a statement indicating that all material state contract variations are disclosed in this Prospectus, and cross reference Appendix D – “Special Contract Provisions for Annuities Issued in Certain States.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 3
Response:
As requested, we have added a statement on the cover page as follows: “Please see Appendix D – Special Contract Provisions for Annuities Issued in Certain States for information on all material state contract variations.”
8.Comment:
On the cover page, add disclosure indicating that indices offered in the Annuity are price return and do not include dividends.
Response:
As requested, we have added disclosure on the cover page as follows: “Index returns for Indexes offered under the Annuity are based on the closing share price (ie, price return) of each respective Index and do not include dividends and other distributions declared by the Index.”
9.Comment:
On the cover page, add disclosure describing Pruco Life’s ability to change features, eg, indexes, index strategies, caps, buffers.
Response:
As requested, we have added disclosure on the cover page as follows: “If an Index is discontinued or substantially changes, we reserve the right to select an alternative Index and we will notify you of any such changes. For these purposes, an Index would be substantially changed if an index sponsor announces that it will make a material change in the formula for the Index or the method of calculating the Index or in any other way materially modifies the Index. We would attempt to choose a substitute Index that has a similar investment objective and risk profile to the replaced Index.
As a result of economic market conditions, or utilization of the Index Strategies, we reserve the right to add and remove Index Strategies at any time, subject to regulatory requirements and approvals. Additions or removals would be effective with any newly issued contracts or upon reallocation for any existing contract holders. Removals would not impact existing contract holders currently allocated to an Index Strategy prior to the Index Strategy End Date.
We reserve the right to change Cap Rates, Spreads, Participation Rates, Step Rates and Buffers at any time, subject to Guaranteed Minimum Rates, Guaranteed Maximum Spread, and minimum Buffer levels. New Rates and Spreads may be set for new Index Strategy Terms upon Index Anniversary Dates. These new Rates and Spreads may be different than Rates and Spreads previously applied to your Annuity and from the Rates and Spreads that we are offering for newly issued contracts. New Buffers may be offered as new Index Strategy options.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 4
10.Comment:
Add the following disclosure at the end of the third paragraph of the third cover page, “Taking withdrawals, especially repetitive withdrawals can negatively impact your investment in the Annuity.”
Response:
We have added the disclosure as requested.
11.Comment:
Add the following disclosure in the middle of the fourth paragraph of the third cover page, “This Annuity is not a short-term investment and is not appropriate if an investor needs ready access to cash. Taking withdrawals, especially repetitive withdrawals can negatively impact your investment in the Annuity.”
Response:
We have added the disclosure as requested.
12.Comment:
On the cover page, disclose the minimum guaranteed buffer level offered under the annuity.
Response:
We have added disclosure on the cover page as follows: “The Buffer limits the amount of negative Index Credit that may be applied to the Account Value allocated to an Index Strategy. We will declare Buffers that will be available on the Index Strategy Start Date for each Index Strategy. The Buffer level for an Index Strategy will not change during the Index Strategy Term. The minimum Buffer level offered under the Annuity is 5%. The Annuity offers Index Strategies with 5%, 10%, 15%, 20%, 30% and 100% Buffer levels. Refer to the “Index Strategies” section of the Prospectus for more information.
13.Comment:
On the cover page, disclose the maximum potential loss as a percentage from negative index performance at the end of an Index Strategy Term taking into account the buffer.
Response:
We have added disclosure on the cover page as follows: “You take the investment risk for amounts allocated to one or more Index Strategies since the Index Credit, which can be positive or negative, is based upon the performance of the associated Index. The Buffer is the amount of protection from negative Index Return. Any negative Index Credit in excess of the Buffer reduces the Account Value allocated to the Index Strategy. You bear the risk of any negative Index Return in excess of the Buffer you choose except for any 100% Buffer Index Strategy where there is no risk of loss to you, should you stay allocated to the end of the Index Strategy
Alberto H. Zapata, Esq.
June 4, 2024
Page 5
Term. Under an Index Strategy, the maximum amount of loss that you could experience due to negative index performance at the end of an Index Strategy Term, after taking into account the Buffer protection from negative index performance currently provided under the Contract, would be 90% loss for a 10% Buffer level; 85% loss for a 15% Buffer level; 80% loss for a 20% Buffer level; 70% loss for a 30% Buffer level; and 0% loss for a 100% Buffer level. Refer to the “Index Strategies” section of the Prospectus for more information.”
14.Comment:
On the cover page, disclose the maximum potential loss as a percentage from negative interim value adjustments.
Response:
We have added disclosure on the cover page as follows: “If you take a withdrawal (including partial withdrawals, systematic withdrawals and full surrenders), transfer out of, annuitize, or we pay a death claim between an Index Strategy Start Date and Index Strategy End Date, we will use an Interim Value to determine the fair market value of each Index Strategy at the time of the transaction. The Interim Value is designed to represent the fair value of the Index Strategy on each Valuation Day, taking into account the potential gain or loss of the applicable Index at the end of the Index Strategy Term. The Interim Value reflects the change in fair value due to economic factors of the investment instruments (including derivatives) supporting the Index Strategies. The Interim Value may result in a loss even if the Index Value at the time the Interim Value is calculated is higher than the Index Value on the Index Strategy Start Date. Because the end-of-term downside protection provided by a Buffer normally does not apply to the Interim Value, it is theoretically possible that you could lose most of your investment, potentially up to 100% of your investment, in extreme scenarios such as an unprecedented complete market collapse. Refer to the “Interim Value of the Index Strategies” section of the Prospectus for more information.”
15.Comment:
Disclose all financial intermediary variations on the cover page and using an appendix to the prospectus that should list intermediaries by name and disclose which product features each intermediary does not make available to their clients.
Response:
Certain of our distribution partners, for reasons strictly internal to their firm’s practices such as suitability considerations, may be unwilling to make available to their clients certain index strategies or indices that are offered under the contract and described in the prospectus. If requested, we may support/administer certain of these variations at the point of sale, for example, by tailoring marketing material for a distribution firm and restricting the feature for that firm on the electronic order entry (EOE) platform. It is important to note that we have no involvement in a distribution firm’s determination not to make available a given feature such as an index strategy or index. In fact, we believe that some distribution firms restrict availability of a product feature without our knowledge and/or without our support.
Alberto H. Zapata, Esq.
June 4, 2024
Page 6
It is also important to note that these variations are at point of sale only, and all index strategies and indices are available to all contract owners upon reallocation/renewal at the end of an index term. Any distribution-driven variations are not supported post-sale. All product features are available under the contract (i.e., any variations are not contractual) and are disclosed in the product prospectus. In other words, while a financial intermediary might vary the “availability” of certain features to its investors, our offering is the same for all investors across all our distribution partners, i.e., all such features are available under the contract, regardless of distribution partner. If we were “white labeling” a product for a specific distributor, we would create a separate prospectus.
Accordingly, we do not have knowledge (with any certainty) of all variations. We only have knowledge of the variations that we support/administer. Further, any financial intermediary variations are strictly at initial sale and all product features offered under the contract are available upon reallocation/renewal. Our current prospectus disclosure is intended to put investors on notice that they may be working with a distribution firm that may restrict certain index strategies or indices but that all index strategies and indices are available through other distribution firms. This disclosure regime has been in place for more than 2 years and informally for many years, and we do not believe that Form N-4, Item 8 was intended to cover financial intermediary versions that are not priced, designed and/or administered by the insurance company.
For the above reasons, the requested disclosure of all financial intermediary variations would be necessarily incomplete and potentially misleading for consumers and would not help consumers understand how the product works and whether it would be an appropriate investment.
16.Comment:
Will the new Enhanced Cap Rate Index Strategy be available for current contract owners (ie, in-force contracts)?
Response:
The new Enhanced Cap Rate Index Strategy will not be available to in-force contracts, only new business on or after July 1. This is different than our usual practice and that is due to the interim value formula change. We only have Enhanced Cap Rate Index Strategy filed on contracts with the new formula and decided not to vary the interim value formula based on index strategy to reduce administrative complexity.
17.Comment:
In the “Summary” section of the prospectus and the “Index Strategies” subsection describing the Enhanced Cap Rate Index Strategy, in point number 3 clarify that cap rates will be higher compared to the Point-to-Point with Cap Index Strategy.
Response:
We have added the phrase “and higher cap rates” to point number 3 so it reads,
Alberto H. Zapata, Esq.
June 4, 2024
Page 7
“Offers a level of protection with higher upside potential and higher cap rates when compared to the Point-to-Point with Cap Index Strategy, in exchange for a Spread reduction on positive returns.”
18.Comment:
In the “Summary” section of the prospectus and the “Index Strategies” subsection describing the Enhanced Cap Rate Index Strategy, in point number 2 clarify what is meant by the word “Otherwise” in the second sentence.
Response:
We have replaced “Otherwise” with the phrase “If the Index Return is negative and greater than the Buffer . . .” so the sentence reads, “If the Index Return is negative and greater than the Buffer, the Index Credit is equal to the negative Index Return in excess of the Buffer.”
19.Comment:
In the “Principal Risks of Investing in the Annuity” section of the prospectus and the “Limitations on Index Returns – Cap Rate” subsection, clarify that the cap rates available with the Enhanced Cap Rate Index Strategy will be higher than the Point-to-Point with Cap Strategy.
Response:
We have added the following sentence in the first paragraph of the subsection, “The Enhanced Cap Rate Index Strategy offers higher cap rates when compared to the Point-to-Point with Cap Index Strategy, in exchange for a Spread reduction on positive returns.”
20.Comment:
In the third paragraph of the “Index Strategies” section of the prospectus, redraft in plain English language in the second sentence around the $2,000 minimum amount required to allocate to an Index Strategy. Also add disclosure regarding what happens if the Index Strategy is not available.
Response:
We have revised the second sentence to read as follows, “In the event that the Account Value allocated to an Index Strategy falls below $2,000 and is not combined with subsequent purchase payments or reallocations from other Index Strategies on an Index Anniversary Date to meet the $2,000 minimum, these funds will automatically be renewed into the same Index Strategy.”
We have also added the following sentence, “If the same Index Strategy is no longer available, the funds associated with the closed Index Strategy will be transferred to the Holding Account, where they may be allocated among the Variable Investment Sub-accounts or into another Index Strategy on the next Index Anniversary Date.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 8
21.Comment:
In the “Index Strategies” section of the prospectus and the subsection describing the Enhanced Cap Rate Index Strategy, in Example 3 remove the phrase, “with no loss of Account Value.”
Response:
As requested, we have removed the phrase, “w
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CORRESP
1
filename1.htm
FlexGuard Correspondence S3 COMBO
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
June 4, 2024
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
Registration Statement on Form S-3
File No. 333-277924
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on May 20, 2024 to the registration statement filing noted above, including the prospectus for FlexGuard Index Linked and Variable Annuity B Series contracts issued by Pruco Life Insurance Company (Pruco Life). Included with this submission is a revised prospectus for the FlexGuard B Series contract issued by Pruco Life, which includes the changes described below. The Staff’s comments and our responses are as follows.
1.Comment:
Why delete certain language in the first paragraph on the cover page?
Response:
This language was inadvertently deleted and has been restored.
Alberto H. Zapata, Esq.
June 4, 2024
Page 2
2.Comment:
Why delete the third and fourth paragraphs on the cover page?
Response:
The third and fourth paragraphs were inadvertently deleted and have been restored.
3.Comment:
Why delete the second paragraph on the third page of the cover pages?
Response:
The second paragraph was inadvertently deleted and has been restored.
4.Comment:
Why delete the “Other Contracts” section on the cover page?
Response:
The “Other Contracts” section was inadvertently deleted and has been restored.
5.Comment:
In the second paragraph of the cover page, the word “Contract” is used but is not a defined term.
Response:
We have added language on the cover page defining “Contract” as a defined term in the prospectus so its use in the second paragraph is appropriate.
6.Comment:
In the first paragraph on the cover page, the word “income” appears as two words, “in come.”
Response:
We have made this correction so “income” appears as one word.
7.Comment:
On the cover page, add a statement indicating that all material state contract variations are disclosed in this Prospectus, and cross reference Appendix D – “Special Contract Provisions for Annuities Issued in Certain States.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 3
Response:
As requested, we have added a statement on the cover page as follows: “Please see Appendix D – Special Contract Provisions for Annuities Issued in Certain States for information on all material state contract variations.”
8.Comment:
On the cover page, add disclosure indicating that indices offered in the Annuity are price return and do not include dividends.
Response:
As requested, we have added disclosure on the cover page as follows: “Index returns for Indexes offered under the Annuity are based on the closing share price (ie, price return) of each respective Index and do not include dividends and other distributions declared by the Index.”
9.Comment:
On the cover page, add disclosure describing Pruco Life’s ability to change features, eg, indexes, index strategies, caps, buffers.
Response:
As requested, we have added disclosure on the cover page as follows: “If an Index is discontinued or substantially changes, we reserve the right to select an alternative Index and we will notify you of any such changes. For these purposes, an Index would be substantially changed if an index sponsor announces that it will make a material change in the formula for the Index or the method of calculating the Index or in any other way materially modifies the Index. We would attempt to choose a substitute Index that has a similar investment objective and risk profile to the replaced Index.
As a result of economic market conditions, or utilization of the Index Strategies, we reserve the right to add and remove Index Strategies at any time, subject to regulatory requirements and approvals. Additions or removals would be effective with any newly issued contracts or upon reallocation for any existing contract holders. Removals would not impact existing contract holders currently allocated to an Index Strategy prior to the Index Strategy End Date.
We reserve the right to change Cap Rates, Spreads, Participation Rates, Step Rates and Buffers at any time, subject to Guaranteed Minimum Rates, Guaranteed Maximum Spread, and minimum Buffer levels. New Rates and Spreads may be set for new Index Strategy Terms upon Index Anniversary Dates. These new Rates and Spreads may be different than Rates and Spreads previously applied to your Annuity and from the Rates and Spreads that we are offering for newly issued contracts. New Buffers may be offered as new Index Strategy options.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 4
10.Comment:
Add the following disclosure at the end of the third paragraph of the third cover page, “Taking withdrawals, especially repetitive withdrawals can negatively impact your investment in the Annuity.”
Response:
We have added the disclosure as requested.
11.Comment:
Add the following disclosure in the middle of the fourth paragraph of the third cover page, “This Annuity is not a short-term investment and is not appropriate if an investor needs ready access to cash. Taking withdrawals, especially repetitive withdrawals can negatively impact your investment in the Annuity.”
Response:
We have added the disclosure as requested.
12.Comment:
On the cover page, disclose the minimum guaranteed buffer level offered under the annuity.
Response:
We have added disclosure on the cover page as follows: “The Buffer limits the amount of negative Index Credit that may be applied to the Account Value allocated to an Index Strategy. We will declare Buffers that will be available on the Index Strategy Start Date for each Index Strategy. The Buffer level for an Index Strategy will not change during the Index Strategy Term. The minimum Buffer level offered under the Annuity is 5%. The Annuity offers Index Strategies with 5%, 10%, 15%, 20%, 30% and 100% Buffer levels. Refer to the “Index Strategies” section of the Prospectus for more information.
13.Comment:
On the cover page, disclose the maximum potential loss as a percentage from negative index performance at the end of an Index Strategy Term taking into account the buffer.
Response:
We have added disclosure on the cover page as follows: “You take the investment risk for amounts allocated to one or more Index Strategies since the Index Credit, which can be positive or negative, is based upon the performance of the associated Index. The Buffer is the amount of protection from negative Index Return. Any negative Index Credit in excess of the Buffer reduces the Account Value allocated to the Index Strategy. You bear the risk of any negative Index Return in excess of the Buffer you choose except for any 100% Buffer Index Strategy where there is no risk of loss to you, should you stay allocated to the end of the Index Strategy
Alberto H. Zapata, Esq.
June 4, 2024
Page 5
Term. Under an Index Strategy, the maximum amount of loss that you could experience due to negative index performance at the end of an Index Strategy Term, after taking into account the Buffer protection from negative index performance currently provided under the Contract, would be 90% loss for a 10% Buffer level; 85% loss for a 15% Buffer level; 80% loss for a 20% Buffer level; 70% loss for a 30% Buffer level; and 0% loss for a 100% Buffer level. Refer to the “Index Strategies” section of the Prospectus for more information.”
14.Comment:
On the cover page, disclose the maximum potential loss as a percentage from negative interim value adjustments.
Response:
We have added disclosure on the cover page as follows: “If you take a withdrawal (including partial withdrawals, systematic withdrawals and full surrenders), transfer out of, annuitize, or we pay a death claim between an Index Strategy Start Date and Index Strategy End Date, we will use an Interim Value to determine the fair market value of each Index Strategy at the time of the transaction. The Interim Value is designed to represent the fair value of the Index Strategy on each Valuation Day, taking into account the potential gain or loss of the applicable Index at the end of the Index Strategy Term. The Interim Value reflects the change in fair value due to economic factors of the investment instruments (including derivatives) supporting the Index Strategies. The Interim Value may result in a loss even if the Index Value at the time the Interim Value is calculated is higher than the Index Value on the Index Strategy Start Date. Because the end-of-term downside protection provided by a Buffer normally does not apply to the Interim Value, it is theoretically possible that you could lose most of your investment, potentially up to 100% of your investment, in extreme scenarios such as an unprecedented complete market collapse. Refer to the “Interim Value of the Index Strategies” section of the Prospectus for more information.”
15.Comment:
Disclose all financial intermediary variations on the cover page and using an appendix to the prospectus that should list intermediaries by name and disclose which product features each intermediary does not make available to their clients.
Response:
Certain of our distribution partners, for reasons strictly internal to their firm’s practices such as suitability considerations, may be unwilling to make available to their clients certain index strategies or indices that are offered under the contract and described in the prospectus. If requested, we may support/administer certain of these variations at the point of sale, for example, by tailoring marketing material for a distribution firm and restricting the feature for that firm on the electronic order entry (EOE) platform. It is important to note that we have no involvement in a distribution firm’s determination not to make available a given feature such as an index strategy or index. In fact, we believe that some distribution firms restrict availability of a product feature without our knowledge and/or without our support.
Alberto H. Zapata, Esq.
June 4, 2024
Page 6
It is also important to note that these variations are at point of sale only, and all index strategies and indices are available to all contract owners upon reallocation/renewal at the end of an index term. Any distribution-driven variations are not supported post-sale. All product features are available under the contract (i.e., any variations are not contractual) and are disclosed in the product prospectus. In other words, while a financial intermediary might vary the “availability” of certain features to its investors, our offering is the same for all investors across all our distribution partners, i.e., all such features are available under the contract, regardless of distribution partner. If we were “white labeling” a product for a specific distributor, we would create a separate prospectus.
Accordingly, we do not have knowledge (with any certainty) of all variations. We only have knowledge of the variations that we support/administer. Further, any financial intermediary variations are strictly at initial sale and all product features offered under the contract are available upon reallocation/renewal. Our current prospectus disclosure is intended to put investors on notice that they may be working with a distribution firm that may restrict certain index strategies or indices but that all index strategies and indices are available through other distribution firms. This disclosure regime has been in place for more than 2 years and informally for many years, and we do not believe that Form N-4, Item 8 was intended to cover financial intermediary versions that are not priced, designed and/or administered by the insurance company.
For the above reasons, the requested disclosure of all financial intermediary variations would be necessarily incomplete and potentially misleading for consumers and would not help consumers understand how the product works and whether it would be an appropriate investment.
16.Comment:
Will the new Enhanced Cap Rate Index Strategy be available for current contract owners (ie, in-force contracts)?
Response:
The new Enhanced Cap Rate Index Strategy will not be available to in-force contracts, only new business on or after July 1. This is different than our usual practice and that is due to the interim value formula change. We only have Enhanced Cap Rate Index Strategy filed on contracts with the new formula and decided not to vary the interim value formula based on index strategy to reduce administrative complexity.
17.Comment:
In the “Summary” section of the prospectus and the “Index Strategies” subsection describing the Enhanced Cap Rate Index Strategy, in point number 3 clarify that cap rates will be higher compared to the Point-to-Point with Cap Index Strategy.
Response:
We have added the phrase “and higher cap rates” to point number 3 so it reads,
Alberto H. Zapata, Esq.
June 4, 2024
Page 7
“Offers a level of protection with higher upside potential and higher cap rates when compared to the Point-to-Point with Cap Index Strategy, in exchange for a Spread reduction on positive returns.”
18.Comment:
In the “Summary” section of the prospectus and the “Index Strategies” subsection describing the Enhanced Cap Rate Index Strategy, in point number 2 clarify what is meant by the word “Otherwise” in the second sentence.
Response:
We have replaced “Otherwise” with the phrase “If the Index Return is negative and greater than the Buffer . . .” so the sentence reads, “If the Index Return is negative and greater than the Buffer, the Index Credit is equal to the negative Index Return in excess of the Buffer.”
19.Comment:
In the “Principal Risks of Investing in the Annuity” section of the prospectus and the “Limitations on Index Returns – Cap Rate” subsection, clarify that the cap rates available with the Enhanced Cap Rate Index Strategy will be higher than the Point-to-Point with Cap Strategy.
Response:
We have added the following sentence in the first paragraph of the subsection, “The Enhanced Cap Rate Index Strategy offers higher cap rates when compared to the Point-to-Point with Cap Index Strategy, in exchange for a Spread reduction on positive returns.”
20.Comment:
In the third paragraph of the “Index Strategies” section of the prospectus, redraft in plain English language in the second sentence around the $2,000 minimum amount required to allocate to an Index Strategy. Also add disclosure regarding what happens if the Index Strategy is not available.
Response:
We have revised the second sentence to read as follows, “In the event that the Account Value allocated to an Index Strategy falls below $2,000 and is not combined with subsequent purchase payments or reallocations from other Index Strategies on an Index Anniversary Date to meet the $2,000 minimum, these funds will automatically be renewed into the same Index Strategy.”
We have also added the following sentence, “If the same Index Strategy is no longer available, the funds associated with the closed Index Strategy will be transferred to the Holding Account, where they may be allocated among the Variable Investment Sub-accounts or into another Index Strategy on the next Index Anniversary Date.”
Alberto H. Zapata, Esq.
June 4, 2024
Page 8
21.Comment:
In the “Index Strategies” section of the prospectus and the subsection describing the Enhanced Cap Rate Index Strategy, in Example 3 remove the phrase, “with no loss of Account Value.”
Response:
As requested, we have removed the phrase, “w