SecProbe.io

March 25, 2021
VIA ELECTRONIC MAIL
Alison Samborn
Associate General Counsel, Legal Product Development
Jackson National Life Insurance Company
1 Corporate Way
Lansing, MI 48951
RE: Jackson Retirement Investment Annui ty Flexible Premium Variable and
Fixed Deferred Annuity
Jackson National Separate Account – I
JNLNY Separate Account IInitial Registration Statements on Form N-4File Nos. 333-252333; 333-252332
Dear Ms. Samborn:
The staff has reviewed the above-referen ced initial registration statements, which
the Commission received on January 22, 2021.  Comments and page references correspond
to the numbering on the bottom of the pages of the filings provided to staff from the
registrant via email. Unless otherwise indicated, the comments below apply to filing 333-
252333; please make confirming changes to th e other filing referenced above, as
applicable.  Based on our review , we have the following comments.1
General Comments
1. Please confirm that all missing informati on, including the financial statements and
all exhibits, will be filed in a pre-effective amendment to the registration statement.  We may have further comments when you supply the omitted information.
2. Please include page numbers to cross- references throughout the prospectus.
3. Please disclose to the staff whether ther e are any types of guarantees or support
agreements with third parties to support any Contract features or benefits, or
whether Jackson will be solely responsible for any benefits or features associated
with the Contract.
1Capitalized terms have the same meaning as in the registration statement unless otherwise indicated.

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 2 of 11
4. Throughout registration statement, all refe rences to website address for contract-
related documents should be to the landing page address, not the corporate home
page address (e.g., www.jackson.com).
PROSPECTUS
5. Where appropriate in the prospectus, pl ease discuss the impact of advisory fee
deductions on contract benefi ts, including the following:
how such deductions will impact various transactions and benefits under the
contract, including how each deduction will reduce the death benefit and any
other guaranteed benefit values;
be clear as to whether these withdrawals will reduce values on a dollar-for-
dollar basis or proportionately;
if such withdrawals will be treated as  a proportionate reduction, then there
should be prominent disclosure stating th at deductions of the advisory fee from
contract value could reduce the rele vant values significantly, and by
substantially more than the actual amount of the deduction;
an example demonstrating the impact of  advisory fee deductions on benefits
should be provided for each such benefit that is impacted ( e.g., death benefit,
guaranteed benefit, etc.); and
contract owners should be encouraged  to discuss with their financial
intermediaries the impact of deducting advisory fees from contract value prior
to making any election.
Cover Page
6. Disclose all material state variations an d intermediary-specific variations (e.g.,
variations resulting from different brokerage channels) to the offering. ( See Form
N-4, Instructions to Item 8(a)).
7. Disclose that the contract is/may be available through third-party financial
intermediaries who charge an advisory fee for their services, and that this fee is in addition to contract fees and expenses.  Also  state that if a contract owner elects to
pay the advisory fee from his or her contract value, then this deduction [will reduce][may reduce] the death benefit(s), and may be subject to federal and state
income taxes and a 10% federal penalty tax. ( SeeForm N-4, Item 1(a)).
8. With respect to obtaining a copy of the most recent Rate Sheet Prospectus
Supplement, please use a mo re specific web address.

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 3 of 11
9. Please provide the landing page where a ll the required documents are located.
10. With respect to the fourth paragraph, please consider whether the following
language is necessary cover page disclosu re, “[i]n some states, you may purchase
the Contract through an automated electr onic transmission/order ticket verification
procedure.”
11. Please move the Rule 12h-7 paragraph from  the cover page to a more appropriate
location in the prospectus itself.  Rule 12h-7 only requires that this statement be
somewhere in the prospectus.
12. With respect to the last paragraph, pl ease separate the last sentence beginning,
“[y]ou may elect to receive certain communications . . .” from the free look paragraph.
13. With respect to the first bullet of the last paragraph, please confirm whether Jackson
still intends to mail a postage-paid ca rd when relying on Rule 498A. Further,
please confirm whether “cover of this report” should be “prospectus.”
Key Information (pp. 3-5) (please apply these comments to the ISP as well)
14. With respect to the narrative paragraph preceding the key information table, please
remove this language as it is not permitted nor required by Form N-4.
15. Please change the “Charges for Early Wit hdrawal” heading to “Charges for Early
Withdrawals.” ( SeeForm N-4, Instruction 1(a) to Item 2).
16. With respect to the “Ongoing Fees and Expenses” row, second column, please
modify the legend to state that the fees and expenses do not reflect any advisory
fees paid to financial intermediaries from  contract value or other assets of the
owners, and that if such charges were re flected, the fees and expenses would be
higher.
17. With respect to item one in the “Annual Fee” column, please confirm that “Base
Contract” reflects the annual contract maintenance charge.
18. Change “Add-on Benefit” to “Optional Be nefit” throughout the key information
table. ( See Instruction 1(a) to Item 2).
19. In footnote 3, only identify the basis for the charge. ( See Instruction 2(c) to Item 2).
20. On page four, please remove “Estimate” from each column heading.
21. In each column at the top of page four, modify the bullets to read “No sales charges
or advisory fees.”

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 4 of 11
22. With respect to the fourth bullet in the “R isks Associated with Investment Options”
row, please replace “the prospectuses for the available Funds” with “these
investments options.” The form requires th at investors review the investment
options (including the fixed account i nvestment options) before making an
investment decision.  We note that the fi xed account investment options do not have
a prospectus, but likewise should be reviewed. ( SeeInstruction 3(c) to Item 2).
23. With respect to the second and third bullets  of the Add-On Bene fits section on page
five, as applicable, state that if a contr act owner elects to pay third-party advisory
fees from his or her contract value, then this deduction will reduce the death
benefit(s) and other guarante ed benefits, and may be s ubject to federal and state
income taxes and a 10% fede ral penalty tax.  Add appr opriate cross-references.
24. With respect to the third bullet in the Add-On Benefits section confirm any material
state variations are disclo sed in the prospectus. ( SeeInstruction to Item 8(a)).
Overview of the Contract (pp. 5-6) (please apply these comments to the ISP as well)
25. Include a separate paragraph regarding the deduction of third-party advisory fees,
disclosing that if a contract owner elects to  pay third-party advisory fees from his or
her contract value, then this deduction will reduce the death benefit(s) and other
guaranteed benefits, and may be subject to federal and state income taxes and a
10% federal penalty tax.  Add appropriate cross-references.
26. With respect to the second sentence of the answer to “What is this Contract, and
what is it designed to do?” please consider  whether it would be appropriate to also
mention the “withdrawal benefit.”
27. In the answer to “How do I accumulate assets in the Contract and receive income
from the Contract?” please bold or prominen tly disclose “A list of Funds in which
the Investment Divisions currently inve st is provided in Appendix A: Funds
Available Under the Contract” and also state that the appendix includes additional information about each fund. ( See Instruction 1 to Item 3).
28. With respect to the penultimate sentence in the answer to “How do I accumulate
assets in the Contract and receive inco me from the Contract?” please consider
whether to add “depending on the income option you select.”
29. Please remove the word “full” from the first sentence of the “Accessing your
money” paragraph because investors have to  pay charges if they access their money
and won’t really have “full” access.
30. Please specify in the “Earnings sweep” paragraph where investors can choose to
move their earnings.

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 5 of 11
Fees and Expenses Tables (pp. 6-8)
31. In the narrative preceding the fee table, state that the fees and expenses do not
reflect any advisory fees paid to financ ial intermediaries from contract value or
other assets of the owner, and that if such charges were reflected, the fees and
expenses would be higher.
32. In the narrative preceding the fee table please add, “[p]lease refer to your Contract
specifications page for information about the specific fees you will pay each year
based on the options you have elected.” ( SeeItem 4).
33. To improve investor comprehension, please move the last paragraph in the narrative
preceding the fee table up to precede the paragraph beginning “[t]he first table ….”
34. Please remove “minimum” row from th e “Transaction Expenses” table. ( See
Instruction 5 to Item 4).
35. Please remove the “Base Contract Charge s (Without Add-On Benefits)” heading
from the “Annual Contract Ex penses” table as base contract charges is a line-item
in the table already.
36. Change “Core Contract Charge” to “Base Contract Expenses” in the “Annual
Contract Expenses” table. ( SeeInstruction 13 to Item 4).
37. The optional benefits under the “Annual C ontract Expenses” section can be grouped
under headings by type, but should all be in one “Annual Contract Expenses” table.
38. Please remove the “Guara nteed Maximum Charges” heading below the “Annual
Fund Expenses” table.  While riders a nd contracts may have guaranteed max
charges, funds do not and this heading may be potentially misleading.
39. With respect to the expense example, state that the examples do not reflect any
advisory fees paid to financial intermediari es from contract value or other assets of
the owner, and that if such fees we re reflected, costs would be higher. ( SeeItem 4).
Investment Divisions (pp. 11-13)
40. With respect to the second sentence of the second paragraph, please disclose any
material intermediary specific limitations. ( See Instruction to Item 8(a)).
41. With respect to the first sentence in the “Substitution” section, please explain your
legal basis for being able to unilaterally m ove investors to the general account. (The
staff’s historic position has been that a pr ovision in a variable annuity contract
which results in the automatic transfer to  a “fixed” account of amounts which have
been accumulating on a variable basis is not consistent with the redeemability

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 6 of 11
requirements of Secti ons 2(a)(32) and 27(i) of the 1940 Act.  See1988 Dear
Registrant Letter.)
Principal Risks (pp. 13-14)
42. There should be a separate paragraph summarizing the risks relating to the
deduction of third-party advisory  fees from contract value ( e.g., this deduction will
reduce the death benefit(s) and other guaran teed benefits, and may be subject to
federal and state income taxes and a 10% federal penalty tax).
43. With respect to the “Fees and Charges” pa ragraph, please add “and disclosed in the
fee table” to the end of the last sentence.
Benefits Available Under the Contracts (pp.  14-16) (please appl y these comments to
the ISP as well)
44. With respect to contract related documents , please direct investors to the landing
page address, not the corporate home page.
45. Here, and throughout prospectus, please not e that these are “optional” benefits
instead of “add-on” benefits.
46. Please change the “Fee” h eading to “Maximum Fee.” ( SeeItem 10(a)).
47. With respect to the stated maximum fee, please include parentheticals providing
information about what the stat ed percentage refers to. ( SeeInstruction 5 to Item
10).
48. In the “Brief Description of Restrictions/Limitations” column, please disclose the
impact of advisory fee deductions.
49. Please remove all the narrative below “A dd-On Living Benefits Available for a
Fee.” ( SeeItem 10(a)).
50. With respect to the “Other Add-On Benef its Included With All Contracts at No
Additional Cost” table, please spec ify “standard” or “optional.”
Contract Charges (pp. 16-19)
51. Please disclose the following w ith respect to advisory fees:
the basis upon which the advisory fee is calculated ( e.g., as a percentage of
contract value);

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 7 of 11
explain how and when the advisory fee will  be deducted if an investor elects to
have advisory fees deducted from the contract ( e.g., pro-rata from each
investment option on an annual basis); and
a brief description of the deduction of advisory fee authorization agreement
between the insurer and the contract ow ner, including how the contract owner
may terminate the agreement.
52. In the first paragraph, cha nge “add-on” to “optional.”
53. Please cross-reference the “Commutation Fee” in the “Income Options” section.
54. With respect to the “Transaction Expenses” section, please clarify the concept of
commutation.  Is it correct that the commuta tion fee applies to annuitants, but not to
beneficiaries?  When commutation applies to annuitants, is it based on the present
value of all expected future payments (l ess the commutation fee) , or is it based on
the present value of the guaranteed remaining payments?
55. With respect to the second sentence of the “Return of Premium Guaranteed
Minimum Death Benefit Charge” paragraph, the prospectus and rate sheet should
state that information about current rates is available on the insurance company’s
website at a specified internet address. ( SeeADI 2018-05 Use of rate sheet
supplements in connection with  variable insurance products).
Purchases (pp. 21-23)
56. With respect to the “Accumulation Units” section and the paragraph beginning,
“[t]he value of an Accumulation Unit”, if a dvisory fees are deducted from contract
value, then disclose that the deduction of advisory fees will result in the
cancellation of accumulation units (in addi tion to other transactions such as
withdrawals and transfers).
Access to Your Money (pp. 26-35)
57. In the fifth full paragraph beginning, “[t] he Contract is desi gned for Contract
Owners,” and in the context of where a dvisory fee deductions are treated as
withdrawals, please disclose the following:
whether any surrender charges will apply to each partial withdrawal and whether such withdrawals will count to ward the annual fee withdrawal amount;
if true, that each withdrawal will reduce the death benefit(s) and any other
guaranteed benefit values, perhaps si gnificantly, with appropriate cross-
references to the Item 10 disclosure; and

Alison Samborn
Jackson Retirement Investment Annuity Flexible Premium Variable and Fixed Deferred Annuity
March 25, 2021
Page 8 of 11
contract owners shou