Correspondence 0000923495-24-000003 from SEPARATE ACCOUNT EQ OF VENERABLE INSURANCE & ANNUITY Co (CIK 0000923495)
SEPARATE ACCOUNT EQ OF VENERABLE INSURANCE & ANNUITY Co (CIK 0000923495)
Date: Jan. 25, 2024 · CIK: 0000923495 · Accession: 0000923495-24-000003
AI Filing Summary & Sentiment
File numbers found in text: 333-273496, 333-273497, 333-273498, 811-08524
Letter
Division of Investment Management • Initial Summary Prospectuses for Registration Statements on Form N-4 for • Accumulator Series (8.1), File No. 333-273496 • Accumulator Series (7.0), File No. 333-273498 • Accumulator Series (6.0), File No. 333-273497
Dear Mr. Oh:
On behalf of Venerable Insurance and Annuity Company and Separate Account EQ of Venerable Insurance and Annuity Company, we are filing with this correspondence an Initial Summary Prospectus (“ISP”) for each of the variable annuities registered with the U.S. Securities and Exchange Commission (the “Commission”) through the above-referenced registration statements (the “Registration Statements”). We intend to include the ISPs as exhibits to the pre-effective amendments to the Registration Statements and would appreciate your review and comment prior to the filing of our pre-effective amendments. Any missing information in the ISPs (as reflected by brackets within the text) will be added and will track the disclosures in the prospectuses as filed in the pre-effective amendments to the Registration Statements. Any changes to the ISPs will be reflected in the prospectuses, and vice versa, if applicable.
We thank the Commission staff for its careful review of these ISPs and the Registration Statements. As a reminder, we intend to file our pre-effective amendments for the Registation Statements, including the ISPs as exhibits, so as to be declared effective by May 1, 2024.
Please do not hesitate to call me at 860-944-4114 or my colleague Ron Tanner at 610-249-2952 if you have any questions or comments concerning the proposed ISPs.
Sincerely,
/s/ J. Neil McMurdie
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CORRESP
1
filename1.htm
VENERABLE LETTERHEAD
J. NEIL MCMURDIE
VICE PRESIDENT AND DEPUTY GENERAL COUNSEL
PHONE: (860) 944-4114 | EMAIL: neil.mcmurdie@venerable.com
January 25, 2024
CORRESPONDENCE FILING VIA EDGARLINK
Mr. Sonny Oh
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549- 8629
Re:
Venerable Insurance and Annuity Company
Separate Account EQ of Venerable Insurance and Annuity Company, File No. 811-08524
• Initial Summary Prospectuses for Registration Statements on Form N-4 for
• Accumulator Series (8.1), File No. 333-273496
• Accumulator Series (7.0), File No. 333-273498
• Accumulator Series (6.0), File No. 333-273497
Dear Mr. Oh:
On behalf of Venerable Insurance and Annuity Company and Separate Account EQ of Venerable Insurance and Annuity Company, we are filing
with this correspondence an Initial Summary Prospectus (“ISP”) for each of the variable annuities registered with the U.S. Securities and Exchange Commission (the “Commission”) through the above-referenced registration statements (the “Registration
Statements”). We intend to include the ISPs as exhibits to the pre-effective amendments to the Registration Statements and would appreciate your review and comment prior to the filing of our pre-effective amendments. Any missing information in the
ISPs (as reflected by brackets within the text) will be added and will track the disclosures in the prospectuses as filed in the pre-effective amendments to the Registration Statements. Any changes to the ISPs will be reflected in the prospectuses,
and vice versa, if applicable.
We thank the Commission staff for its careful review of these ISPs and the Registration Statements. As a reminder, we intend to file our pre-effective
amendments for the Registation Statements, including the ISPs as exhibits, so as to be declared effective by May 1, 2024.
Please do not hesitate to call me at 860-944-4114 or my colleague Ron Tanner at 610-249-2952 if you have any questions or comments concerning the proposed
ISPs.
Sincerely,
/s/ J. Neil McMurdie
J. Neil McMurdie
cc:
Ron Tanner, Esq
Thomas Bisset, Esq.
Jay Lemoncelli, Esq.
Timothy Graves, Esq.
Venerable Insurance and Annuity Company
and its Separate Account EQ
The Accumulator® Series (8.1)
May 1, 2024, Summary Prospectus for New Investors
This summary prospectus (the “Summary Prospectus”) summarizes key features of Accumulator® Series (8.1), which are group
and individual deferred combination variable and fixed annuity contracts (the “Contract” or the “Contracts”) issued by Venerable Insurance and Annuity Company (the “Company,” “we,” “us” and “our”) through Separate Account EQ of Venerable Insurance
and Annuity Company (the “Separate Account”). The Accumulator® Series consists of four Contract classes:
•
Accumulator®;
•
Accumulator® PlusSM;
•
Accumulator® EliteSM; and
•
Accumulator® SelectSM.
The Contracts are offered solely to owners of Accumulator® Series variable annuity contracts (“EFLIC Contracts”) issued by Equitable
Financial Life Insurance Company (“EFLIC”) in connection with the Company’s assumption reinsurance of the EFLIC Contracts. This Summary Prospectus describes the features and benefits of the Contracts issued to EFLIC Contract owners who elect to
exchange their EFLIC Contract for the Contract. An EFLIC Contract may only be exchanged for a Contract of the same contract class and with the same optional benefit riders. Additional information about the terms and conditions of the exchange offer
can be found in a supplement that accompanies this Summary Prospectus and the Notice of Transfer owners will receive from EFLIC. The Contracts are not offered for sale to any other prospective purchasers.
Before you invest, you should also review the full prospectus for the Contract, which contains more information about the Contract's features, benefits,
and risks. You can find this document and other information about the Contract online at https://docs.venerable.com/#/landing?prod=[ ]. You can also obtain
this information at no cost by calling 1-800-366-0066 or by sending an email request to smb-usa-mailbox@venerable.com.
Additional information about certain investment products, including variable annuities, has been prepared by the staff of the Securities and Exchange
Commission (“SEC”) and is available at Investor.gov.
The SEC has not approved or disapproved the Contract or determined if this Summary Prospectus is accurate or complete. Any
representation to the contrary is a criminal offense.
(8.1)
TABLE OF CONTENTS
Page
SPECIAL TERMS
3
IMPORTANT INFORMATION YOU SHOULD CONSIDER ABOUT THE CONTRACT
4
OVERVIEW OF THE CONTRACT
7
BENEFITS AVAILABLE UNDER THE CONTRACT
8
BUYING THE CONTRACT
11
MAKING WITHDRAWALS: ACCESSING THE MONEY IN YOUR CONTRACT
15
ADDITIONAL INFORMATION ABOUT FEES
18
APPENDIX A – FUNDS AVAILABLE UNDER THE CONTRACT
21
HOW TO GET MORE INFORMATION
Back Cover
SPECIAL TERMS
The following special terms have special meaning and are used throughout this Summary Prospectus. Other special terms are generally defined in the
sections where those terms appear.
Account Value
The total value of the values you have in (i) the Subaccounts; (ii) the Guaranteed Interest Option; (iii) the Account for Special DCA (applies to
Accumulator® and Accumulator® EliteSM Contracts only) and (iv) the loan reserve account (applies for Rollover 403(b) Contracts only).
Annual Ratchet
An Annual Ratchet occurs when your benefit base under an optional benefit is increased to equal your Account Value on a Contract Date
Anniversary.
Annuitant
The person who is the measuring life for determining the Contract Maturity Date. The Annuitant is not necessarily the Owner.
Business Day
Generally, any day the New York Stock Exchange (“NYSE”) is open for regular trading and generally ends at 4:00 p.m. Eastern Time (or as of an
earlier close of regular trading). A Business Day does not include a day on which the NYSE is closed due to emergency conditions determined by the SEC. We may also close early due to such emergency conditions.
Cash Value
At any time before annuity payments begin, your Contract’s Cash Value is equal to the Account Value less: (i) the total amount or a pro rata
portion of the Annual Administrative Charge, as well as any optional benefit charges; (ii) any applicable Withdrawal Charges (not applicable to Accumulator® SelectSM Contracts); and (iii) the amount of any outstanding
loan plus accrued interest (applicable to Rollover 403(b) Contracts only).
Contract Date
The effective date of an EFLIC Contract. Your Contract Date is shown in your Contract.
Contract Date Anniversary
The end of each 12-month period following the Contract Date. For example, if your Contract Date is May 1st, your Contract Date Anniversary is
April 30th.
Contract Year
The 12-month period beginning on your Contract Date and each 12-month period after that date.
Credit
If you own an Accumulator® PlusSM Contract, we will add a Credit to your contributions. Credits may be recaptured upon
annuitization and death.
EFLIC Contract
The Accumulator® Series variable annuity contract issued by Equitable Financial Life Insurance Company that may be exchanged for the Contract
described in this Summary Prospectus of the same contract class and with the same optional benefit riders.
Fund
An underlying mutual fund in which a Subaccount invests.
Good Order
An instruction received by us, utilizing such forms as we may require, that is sufficiently complete and clear that we do not need to exercise
any discretion to follow such instruction.
Guaranteed Interest Option
Part of our general account that pays interest at guaranteed rates.
Maturity Date
Generally, the Contract Date Anniversary that follows the Annuitant’s 95th birthday.
Owner
The person who is the named Owner of the Contract and, if a natural person, the measuring life for determining Contract benefits. If the Owner is
a non-natural person, the Annuitant is the measuring life for determining Contract benefits.
Qualified Contract
A Contract purchased through a tax-qualified retirement plan or program under Sections 401(a), 401(k), 403(b), 408, or 408A of the Tax Code.
Contracts that are not Qualified Contracts are referred to as “Nonqualified Contracts.”
Subaccounts
Subaccounts of the Separate Account available for investment under the Contracts, each of which invests in a single Fund.
Tax Code
The Internal Revenue Code of 1986, as amended.
IMPORTANT INFORMATION YOU SHOULD CONSIDER ABOUT THE CONTRACT.
FEES AND
EXPENSES
Charges for Early Withdrawals
Each class of the Contract provides for different Withdrawal Charge periods and percentages:
• Accumulator® — If you
surrender your Contract, apply Cash Value to a non-life contingent annuity payout option, or withdraw money from the Accumulator® Contract within 7 years following your last contribution, you will be assessed a Withdrawal
Charge of up to 7% of such contribution. For example, if you make a withdrawal in the first year, you could pay a Withdrawal Charge of up to $7,000 on a $100,000 investment;
• Accumulator® PlusSM — If you surrender your Contract, apply Cash Value to a non-life contingent annuity payout
option, or withdraw money from the Accumulator® PlusSM Contract within 9 years following your last contribution, you will be assessed a Withdrawal Charge of up to 8% of such contribution. For example, if you make a
withdrawal in the first year, you could pay a Withdrawal Charge of up to $8,000 on a $100,000 investment;
• Accumulator® EliteSM — If you surrender your Contract, apply Cash Value to a non-life contingent annuity payout
option, or withdraw money from the Accumulator® EliteSM Contract within 4 years following your last contribution, you will be assessed a Withdrawal Charge of up to 8% of such contribution. For example, if you make a
withdrawal in the first year, you could pay a Withdrawal Charge of up to $8,000 on a $100,000 investment; and
• Accumulator® SelectSM — No Withdrawal Charge.
For additional information about charges for surrenders and early withdrawals see “Withdrawal Charge” in “CHARGES AND FEES” in the full prospectus for the Contract.
Transaction Charges
In addition to Withdrawal Charges, you may also be charged for other transactions (for special requests such as express mail and duplicate
Contracts).
For additional information about transaction charges see “Special Service Charges” in “CHARGES AND FEES” in the full prospectus for the Contract.
Ongoing Fees and Expenses (annual charges)
Each class of the Contract provides for different ongoing fees and expenses. The table below describes the fees and expenses that you may pay each year under the Contract, depending on the options you choose. Please refer to your Contract specifications page for information about
the specific fees you will pay each year based on the options you have elected.
Annual Fee
Minimum
Maximum
Base Contract (varies by Contract class)(1)
[ ]%
[ ]%
Investment options (Fund fees and expenses)(2)
[ ]%
[ ]%
Optional benefits available for an additional charge (for a single optional benefit, if elected)(3)
0.25%
1.05%
(1) Expressed as an annual percentage of daily net assets in each Subaccount. The Base Contract fee consists of the Mortality and
Expense Risk Charge, the Distribution Charge, and the annual $30 Administrative Charge converted into a percentage and rounded up to the nearest one-hundredth of a percent. The annual $30 Administrative Charge is waived if your Account
Value on a Contract Date Anniversary is $50,000 or more. We calculate the Base Contract fee by dividing the total amount of these charges collected during the last fiscal year by the total average net assets attributable to the Contracts
for that year. The minimum amount above reflects the Base Contract fee for the least expensive Contract class (Accumulator®), while the maximum amount reflects the Base Contract fee for the most expensive Contract class (Accumulator®
Select).
(2) Expressed as an annual percentage of daily net assets of the Funds. This range is for the year ended December 31, 2023 and
could change from year to year.
(3) Expressed as an annual percentage of the applicable benefit base.
Because your Contract is customizable, the choices you make affect how much you will pay. To help you understand the cost of owning your
Contract, the following table shows the lowest and highest cost you could pay each year, based on current charges. This estimate
assumes no Credits, no loans, and that you do not take withdrawals from the Contract or make any other transactions, which could add Withdrawal
Charges that substantially increase costs.
Lowest Annual Cost
$[ ]
Highest Annual Cost
$[ ]
Assumes:
• Investment of $100,000
• 5% annual appreciation
• Least expensive combination of Contract class and Fund fees and expenses
• No optional benefits
• No sales charges
• No additional contributions, transfers, or withdrawals
Assumes:
• Investment of $100,000
• 5% annual appreciation
• Most expensive combination of Contract class (Accumulator® SelectSM), optional benefits (GMIB and
Greater of 6% Roll-up to Age 85 or Annual Ratchet to Age 85 death benefit, and the Earnings Enhancement Benefit (“EEB”)) and Fund fees and expenses
• No sales charges
• No additional contributions, transfers, or w