SEC Company Response from JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730) — Mar 5, 2020
JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730)
Date: March 5, 2020 · CIK: 0000927730 · Accession: 0000927730-20-000073
AI Filing Summary & Sentiment
File numbers found in text: 333-235565, 333-235566, 333-235567, 333-235568
Letter
SEC Response 03-05-20 Combined Document
MEMORANDUM
TO:
DeCarlo S. McLaren, Esq.
Senior Counsel
Disclosure Review and Accounting Office
U. S. Securities and Exchange Commission
FROM:
Alison Samborn, Esq.
Senior Attorney, Legal Product Development
DATE:
March 5, 2020
SUBJECT:
Jackson National Separate Account-I (“Registrant”)
JNLNY Separate Account I (“Registrant”)
Initial Registration Statements on Form N-4
File Nos. 333-235565; 333-235566; 333-235567; 333-235568.
This memorandum is in response to the comments you provided via email on March 3, 2020, for the above referenced filings.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum quotes each of the specific comments, followed respectively by narrative responses (in bold).
Unless indicated otherwise below, the comments and responses apply to all registration statements referenced above. Copies of each prospectus, marked to show the changes discussed below, are attached and will be provided electronically. Page references in the responses are to the pdf page of the attached marked copies of the Jackson National Elite Access II or Jackson National Jackson Advantage prospectuses, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to the other prospectuses as applicable. Pre-effective amendments to the registration statements will subsequently be filed in response to the comments.
1.
General Comments
a.
Supplementally, please advise whether there are any types of guarantees or support agreements with third parties to support any of the obligations of Jackson National Life Insurance Company (“Jackson National”) and Jackson National Life Insurance Company of New York (“Jackson of New York”) under the Contract or whether Jackson National and Jackson of New York will be solely responsible for payment of contract benefits.
Response: Jackson National and Jackson of New York will be solely responsible for payment of Contract benefits. There are no guarantee or support agreements with third parties to support any of Jackson National’s or Jackson of New York’s obligations under the Contracts.
b.
Please remove all brackets and provide any missing information such as the financial in your next filing with the Commission. We may have further comments.
Response: We have removed brackets from the information included in the Appendix C GMWB Prospectus Examples section. The remaining brackets relate to our Example section and fund information, which has not yet been finalized and approved by our auditor. The fund expenses and information, including the Example section, will be fully updated for our final pre-effective amendment filing in early April. The financial information is not yet available for inclusion in our response, but will be fully incorporated along with an auditor’s consent when we make our final pre-effective amendment filing in early April. Our Distribution of Contracts section will be revised only to update the list of 20 financial institutions receiving the largest amount of marketing allowance
payments and/or marketing support payments in 2019. This information is not yet available to us, but will be fully updated for our final pre-effective amendment filing in early April.
c.
Please confirm that all material state variations of the contract are disclosed in this prospectus. If not, please add appropriate disclosure.
Response: All material state-required variations to the terms described in the prospectus are disclosed therein.
d.
Supplementally, please confirm that you will file any subsequent rate sheet in a reasonable amount of time prior to its effective date.
Response: Jackson does not utilize rate sheets for any of the contracts associated with these new registration filings, and does not intend to do so in the future.
Filings 333-235565 and 333-235566
2.
Cover Page (p. 2)
There does not appear to be any living benefits under this contract. To avoid confusion, delete the reference on the cover page to ‘certain living benefits’.”
Response: The above-referenced change has been made (p. 1).
3.
Fees and Expenses Table (p. 13)
The chart states that the only add-on is the liquidity option, the charge for which is already listed. Please supplementally clarify what benefit the “Add-On Benefit Charges” line entry is referring.
Response: The Add-On Benefit Charges line entry includes the charges for both Add-On Benefits available on the contract: The Liquidity Option and the Return of Premium Guaranteed Minimum Death Benefit, which are both listed in the Periodic Expenses table under the Add-On Benefits header.
4.
Withdrawal Charge (p. 45)
Describe the order in which withdrawals are taken in the first part of the Withdrawal Charge section.
Response: The disclosure describing the order in which withdrawals are taken has been relocated to immediately follow the list of withdrawals that will and will not incur a withdrawal charge in the first part of the Withdrawal Charge section (p. 43).
5.
Death Benefit Charges (p.47)
For clarity, revise the bolded sentence beginning, “Upon such election…” with something comparable to “if the investor opts out of paying an increase in the GMDB charge….”
Response: The above-referenced sentenced has been revised as follows (p. 45):
“If you elect to opt out of the charge increases, no future Premium payments will be allowed.”
6.
Death Benefit (p. 58)
a.
For the second sentence of the first paragraph, “All adjustments will occur at the time of the withdrawal…,” provide examples of how this works. In addition, note when the adjustments will have a significantly negative impact on
the benefit before the statement that the adjustments could lead to its termination. In this regard, please ensure generally that the prospectus contains an example of any calculations or formulas noted in the prospectus.
Response: The following disclosure has been added immediately following the above-referenced sentence (p. 56):
“If the Contract Value is lower than the GMDB benefit base on the date of a withdrawal, that withdrawal may reduce the GMDB benefit base by more than the dollar amount of the withdrawal. For example, if the Contract Value is $80,000 and Premium is $100,000 prior to a withdrawal of $8,000, the withdrawal will reduce Premium to $90,000 using the formula $100,000 - ($100,000 x $8,000/$80,000). Withdrawals may prematurely reduce the value of this Return of Premium Death Benefit.”
b.
For the sentence beginning, “Unlike the basic death benefit, this add-on benefit may provide value on or after the Income Date…,” for clarity point out that the payment of this optional death benefit will be made only in the investor waits until the Latest Income Date to annuitize.
Response: The above-referenced disclosure has been revised as follows (p. 56):
“Unlike the basic death benefit, this add-on death benefit may provide value on or after the Income Date. Payment under this add-on death benefit will only be made if you wait until the Latest Income Date to begin receiving income payments. If the Income Date is before the Latest Income Date, then this add-on death benefit terminates, and no death benefit is payable.”
7.
Services (p. 82)
In the first paragraph of this section, the registrant states, “Jackson keeps the assets of the Separate Account.” Please state that Jackson is the custodian, if applicable.
Response: The above-referenced change has been made to the Services section of the Statement of Additional Information (p. 6).
Filings 333-235567 and 333-235568
8.
Cover Page (p. 4)
a.
Please avoid defined terms in the cover page, and instead use plain English to describe the concepts conveyed by the terms.
Response: Registrant respectfully believes that the use of the terms “Contract,” and “Premium” are necessary to provide the required disclosures on the cover page of the prospectus. These terms do not carry particularly specialized or unique meaning and are defined terms only to ensure clarity and provide additional information.
b.
State that the fixed options are not available with certain guaranteed minimum death benefits or,
Response: Registrant’s bolded disclosure regarding the unavailability of the fixed account options when certain add-on benefits are elected appears at the top of the page immediately following the cover page, which is the first instance in which the fixed account options are mentioned in the prospectus and immediately precedes the list of available investment options. Registrant respectfully believes this information is more helpful to the consumer in its current location as the cover page lacks any references to the fixed account options and therefore does not provide the necessary context with which to understand the disclosure on availability.
c.
Supplementally clarify the need to specify defined terms in the cover page before they have been discussed.
Response: Please see Registrant’s response to 8(a) above.
9.
Key Facts (p. 11)
a.
Please note, under “Add-on Benefits,” that (a) some of these add-on benefits impose restrictions on the availability of certain investment options and (b) failure to comply with the terms of the benefits can significantly reduce or even eliminate the benefit.
Response: The following disclosure has been added to the Add-On Benefits section of the Key Facts table (p. 10).
“Certain add-on death benefits impose restrictions on the availability of the Fixed Account investment options. Failure to comply with the terms of the add-on benefits can significantly reduce or result in the termination of the benefit.”
b.
In a couple of sentences, please explain what the add-on benefits are and what they generally do. Also, note that some of these benefits include one or more bonuses to encourage investors not to make withdrawals.
Response: The following disclosure has been added to the beginning of the Add-On Benefits section of the Key Facts table (p. 10):
“Several add-on benefits are available for purchase, which may add guaranteed income or enhanced death benefit features to your Contract. Some add-on benefits may include bonus features that only function if you do not take withdrawals from your Contract.”
10.
Fees and Expenses Tables (p. 13)
Clarify what is intended by “benefit based” for the sentence that begins “the following add-on death benefit charges are benefit based.” Also, clarify whether that benefit base is the same as contract value at the time the benefit is elected.
Response: The benefit-based charges are calculated based upon the applicable percentage of the GMDB benefit base, which is specified in more detail in the applicable Contract Charges sections for the GMDBs. At the time the benefit is elected at issue, the benefit base is equal to contract value. This statement in the periodic expenses table is footnoted with a description and a cross-reference to the applicable Contract Charges section for a more detailed explanation.
11.
Contract Charges (p. 47)
Describe the order in which withdrawals are taken in the first part of the Withdrawal Charge section.
Response: The disclosure describing the order in which withdrawals are taken has been relocated to immediately follow the list of withdrawals that will and will not incur a withdrawal charge in the first part of the Withdrawal Charge section (p. 46).
12.
Access To Your Money (p. 62)
a.
The Registrant states, “[p]lease note that withdrawals in excess of certain limits may have a significantly negative impact on the value of your GMWB through prematurely reducing the benefit’s…” Consider adding disclosure that these benefits may not be appropriate for persons who might have cash needs in excess of the withdrawal limits imposed by the benefits that can’t be met from other sources.
Response: The following disclosure has been added to the above-referenced section of the prospectus (p. 61):
“These benefits may not be appropriate if you anticipate having cash needs in excess of the withdrawal limits imposed by the benefits that cannot be covered by sources other than your Contract.”
b.
In the RMD Notes section, Registrant states, “If your requested RMD exceeds our calculation of the RMD for your Contract, your request will not be eligible for the waiver of any applicable charges…” Please supplementally clarify what is the nature and limits of “the waiver.”
Response: The waiver of applicable charges in the above-referenced excerpt refers to the waiver of withdrawal charges for terminal illness or extended care, which are fully described at the beginning of the Access to Your Money section of the prospectus (p. 60).
c.
Consider deleting the chart at the bottom of p. 63 that outlines the “Highest Quarterly Contract Value.” This chart appears to be unnecessary, since the step up under this GMWB is assessed only on a quarterly basis. Supplement the narrative to note that the step up for this benefit is assessed only on a monthly basis.
Response: The above-referenced chart has been deleted, and the paragraph immediately before it has been revised as follows (p. 63):
“These GMWBs include a step-up to highest quarterly contract value feature, and permit, prior to being added to the Contract, a selection of bonus percentage amounts. The 6% bonus option is only available in conjunction with the purchase of the single life LifeGuard Freedom Flex GMWB with the LifeGuard Freedom Flex Death Benefit.”
d.
On page 64, first paragraph, second sentence states, “[t]he LifeGuard Freedom Flex GMWB and LifeGuard Freedom Flex with Joint Option GMWB allow the Owner … with the assistance of his or her financial professional, to select an available combination of Options…” This language indicates that there is something special about these GMWBs that allow the assessments of needs in a way that other GMWBs don’t. Either delete this sentence or revise to make it clear why these GMWBs allow the assessments of needs in a way that other GMWBs don’t.
Response: The above-referenced language was a carry-over from the way these benefits are described in Contracts with multiple alternative GMWB options. As a result, it has been determined unnecessary for this product, and the prospectus has been revised as follows (p. 63):
“These GMWBs allow the Owner (or the Owner and the Owner’s spouse), with the assistance of his or her financial professional, to select an available combination of Options, consistent with a variety of considerations, such as: his or her expectations of market performance; anticipated timing of subsequent Premiums; needs for future guaranteed annual percentage of withdrawals; expectation of need for early or unscheduled withdrawals to fund then current living expenses and obligations; marital and family status; and tax-qualified or non-tax-qualified purpose of the investment.”
e.
On page 64, the registrant states that “[d]ifferences in the percentage of a Bonus Option do not otherwise affect the operation of the resulting combination of Options.” This sentence, standing as it does by itself without context, isn’t clear. Please relocate the sentence to an appropriate location (e.g., the Bonus section) and clarify in plain English what is intended.
Response: The above-referenced sentence was a carry-over from a version of this benefit that had multiple additional options related to types of step-ups. As a result, it has been determined unnecessary for this product, and deleted (p. 63).
f.
At the bottom of page 64, the registrant states, “If the For Life Guarantee is the in effect the guarantee lasts for the lifetime of the Designated Life, or if there are joint Owners, the lifetime of the joint Owner who dies first…” For clarity, the phrase beginning with the word “first” should be placed in bold.
Respo
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CORRESP 1 filename1.htm SEC Response 03-05-20 Combined Document MEMORANDUM TO: DeCarlo S. McLaren, Esq. Senior Counsel Disclosure Review and Accounting Office U. S. Securities and Exchange Commission FROM: Alison Samborn, Esq. Senior Attorney, Legal Product Development DATE: March 5, 2020 SUBJECT: Jackson National Separate Account-I (“Registrant”) JNLNY Separate Account I (“Registrant”) Initial Registration Statements on Form N-4 File Nos. 333-235565; 333-235566; 333-235567; 333-235568. This memorandum is in response to the comments you provided via email on March 3, 2020, for the above referenced filings. In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum quotes each of the specific comments, followed respectively by narrative responses (in bold). Unless indicated otherwise below, the comments and responses apply to all registration statements referenced above. Copies of each prospectus, marked to show the changes discussed below, are attached and will be provided electronically. Page references in the responses are to the pdf page of the attached marked copies of the Jackson National Elite Access II or Jackson National Jackson Advantage prospectuses, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to the other prospectuses as applicable. Pre-effective amendments to the registration statements will subsequently be filed in response to the comments. 1. General Comments a. Supplementally, please advise whether there are any types of guarantees or support agreements with third parties to support any of the obligations of Jackson National Life Insurance Company (“Jackson National”) and Jackson National Life Insurance Company of New York (“Jackson of New York”) under the Contract or whether Jackson National and Jackson of New York will be solely responsible for payment of contract benefits. Response: Jackson National and Jackson of New York will be solely responsible for payment of Contract benefits. There are no guarantee or support agreements with third parties to support any of Jackson National’s or Jackson of New York’s obligations under the Contracts. b. Please remove all brackets and provide any missing information such as the financial in your next filing with the Commission. We may have further comments. Response: We have removed brackets from the information included in the Appendix C GMWB Prospectus Examples section. The remaining brackets relate to our Example section and fund information, which has not yet been finalized and approved by our auditor. The fund expenses and information, including the Example section, will be fully updated for our final pre-effective amendment filing in early April. The financial information is not yet available for inclusion in our response, but will be fully incorporated along with an auditor’s consent when we make our final pre-effective amendment filing in early April. Our Distribution of Contracts section will be revised only to update the list of 20 financial institutions receiving the largest amount of marketing allowance payments and/or marketing support payments in 2019. This information is not yet available to us, but will be fully updated for our final pre-effective amendment filing in early April. c. Please confirm that all material state variations of the contract are disclosed in this prospectus. If not, please add appropriate disclosure. Response: All material state-required variations to the terms described in the prospectus are disclosed therein. d. Supplementally, please confirm that you will file any subsequent rate sheet in a reasonable amount of time prior to its effective date. Response: Jackson does not utilize rate sheets for any of the contracts associated with these new registration filings, and does not intend to do so in the future. Filings 333-235565 and 333-235566 2. Cover Page (p. 2) There does not appear to be any living benefits under this contract. To avoid confusion, delete the reference on the cover page to ‘certain living benefits’.” Response: The above-referenced change has been made (p. 1). 3. Fees and Expenses Table (p. 13) The chart states that the only add-on is the liquidity option, the charge for which is already listed. Please supplementally clarify what benefit the “Add-On Benefit Charges” line entry is referring. Response: The Add-On Benefit Charges line entry includes the charges for both Add-On Benefits available on the contract: The Liquidity Option and the Return of Premium Guaranteed Minimum Death Benefit, which are both listed in the Periodic Expenses table under the Add-On Benefits header. 4. Withdrawal Charge (p. 45) Describe the order in which withdrawals are taken in the first part of the Withdrawal Charge section. Response: The disclosure describing the order in which withdrawals are taken has been relocated to immediately follow the list of withdrawals that will and will not incur a withdrawal charge in the first part of the Withdrawal Charge section (p. 43). 5. Death Benefit Charges (p.47) For clarity, revise the bolded sentence beginning, “Upon such election…” with something comparable to “if the investor opts out of paying an increase in the GMDB charge….” Response: The above-referenced sentenced has been revised as follows (p. 45): “If you elect to opt out of the charge increases, no future Premium payments will be allowed.” 6. Death Benefit (p. 58) a. For the second sentence of the first paragraph, “All adjustments will occur at the time of the withdrawal…,” provide examples of how this works. In addition, note when the adjustments will have a significantly negative impact on 2 the benefit before the statement that the adjustments could lead to its termination. In this regard, please ensure generally that the prospectus contains an example of any calculations or formulas noted in the prospectus. Response: The following disclosure has been added immediately following the above-referenced sentence (p. 56): “If the Contract Value is lower than the GMDB benefit base on the date of a withdrawal, that withdrawal may reduce the GMDB benefit base by more than the dollar amount of the withdrawal. For example, if the Contract Value is $80,000 and Premium is $100,000 prior to a withdrawal of $8,000, the withdrawal will reduce Premium to $90,000 using the formula $100,000 - ($100,000 x $8,000/$80,000). Withdrawals may prematurely reduce the value of this Return of Premium Death Benefit.” b. For the sentence beginning, “Unlike the basic death benefit, this add-on benefit may provide value on or after the Income Date…,” for clarity point out that the payment of this optional death benefit will be made only in the investor waits until the Latest Income Date to annuitize. Response: The above-referenced disclosure has been revised as follows (p. 56): “Unlike the basic death benefit, this add-on death benefit may provide value on or after the Income Date. Payment under this add-on death benefit will only be made if you wait until the Latest Income Date to begin receiving income payments. If the Income Date is before the Latest Income Date, then this add-on death benefit terminates, and no death benefit is payable.” 7. Services (p. 82) In the first paragraph of this section, the registrant states, “Jackson keeps the assets of the Separate Account.” Please state that Jackson is the custodian, if applicable. Response: The above-referenced change has been made to the Services section of the Statement of Additional Information (p. 6). Filings 333-235567 and 333-235568 8. Cover Page (p. 4) a. Please avoid defined terms in the cover page, and instead use plain English to describe the concepts conveyed by the terms. Response: Registrant respectfully believes that the use of the terms “Contract,” and “Premium” are necessary to provide the required disclosures on the cover page of the prospectus. These terms do not carry particularly specialized or unique meaning and are defined terms only to ensure clarity and provide additional information. b. State that the fixed options are not available with certain guaranteed minimum death benefits or, Response: Registrant’s bolded disclosure regarding the unavailability of the fixed account options when certain add-on benefits are elected appears at the top of the page immediately following the cover page, which is the first instance in which the fixed account options are mentioned in the prospectus and immediately precedes the list of available investment options. Registrant respectfully believes this information is more helpful to the consumer in its current location as the cover page lacks any references to the fixed account options and therefore does not provide the necessary context with which to understand the disclosure on availability. 3 c. Supplementally clarify the need to specify defined terms in the cover page before they have been discussed. Response: Please see Registrant’s response to 8(a) above. 9. Key Facts (p. 11) a. Please note, under “Add-on Benefits,” that (a) some of these add-on benefits impose restrictions on the availability of certain investment options and (b) failure to comply with the terms of the benefits can significantly reduce or even eliminate the benefit. Response: The following disclosure has been added to the Add-On Benefits section of the Key Facts table (p. 10). “Certain add-on death benefits impose restrictions on the availability of the Fixed Account investment options. Failure to comply with the terms of the add-on benefits can significantly reduce or result in the termination of the benefit.” b. In a couple of sentences, please explain what the add-on benefits are and what they generally do. Also, note that some of these benefits include one or more bonuses to encourage investors not to make withdrawals. Response: The following disclosure has been added to the beginning of the Add-On Benefits section of the Key Facts table (p. 10): “Several add-on benefits are available for purchase, which may add guaranteed income or enhanced death benefit features to your Contract. Some add-on benefits may include bonus features that only function if you do not take withdrawals from your Contract.” 10. Fees and Expenses Tables (p. 13) Clarify what is intended by “benefit based” for the sentence that begins “the following add-on death benefit charges are benefit based.” Also, clarify whether that benefit base is the same as contract value at the time the benefit is elected. Response: The benefit-based charges are calculated based upon the applicable percentage of the GMDB benefit base, which is specified in more detail in the applicable Contract Charges sections for the GMDBs. At the time the benefit is elected at issue, the benefit base is equal to contract value. This statement in the periodic expenses table is footnoted with a description and a cross-reference to the applicable Contract Charges section for a more detailed explanation. 11. Contract Charges (p. 47) Describe the order in which withdrawals are taken in the first part of the Withdrawal Charge section. Response: The disclosure describing the order in which withdrawals are taken has been relocated to immediately follow the list of withdrawals that will and will not incur a withdrawal charge in the first part of the Withdrawal Charge section (p. 46). 12. Access To Your Money (p. 62) a. The Registrant states, “[p]lease note that withdrawals in excess of certain limits may have a significantly negative impact on the value of your GMWB through prematurely reducing the benefit’s…” Consider adding disclosure that these benefits may not be appropriate for persons who might have cash needs in excess of the withdrawal limits imposed by the benefits that can’t be met from other sources. 4 Response: The following disclosure has been added to the above-referenced section of the prospectus (p. 61): “These benefits may not be appropriate if you anticipate having cash needs in excess of the withdrawal limits imposed by the benefits that cannot be covered by sources other than your Contract.” b. In the RMD Notes section, Registrant states, “If your requested RMD exceeds our calculation of the RMD for your Contract, your request will not be eligible for the waiver of any applicable charges…” Please supplementally clarify what is the nature and limits of “the waiver.” Response: The waiver of applicable charges in the above-referenced excerpt refers to the waiver of withdrawal charges for terminal illness or extended care, which are fully described at the beginning of the Access to Your Money section of the prospectus (p. 60). c. Consider deleting the chart at the bottom of p. 63 that outlines the “Highest Quarterly Contract Value.” This chart appears to be unnecessary, since the step up under this GMWB is assessed only on a quarterly basis. Supplement the narrative to note that the step up for this benefit is assessed only on a monthly basis. Response: The above-referenced chart has been deleted, and the paragraph immediately before it has been revised as follows (p. 63): “These GMWBs include a step-up to highest quarterly contract value feature, and permit, prior to being added to the Contract, a selection of bonus percentage amounts. The 6% bonus option is only available in conjunction with the purchase of the single life LifeGuard Freedom Flex GMWB with the LifeGuard Freedom Flex Death Benefit.” d. On page 64, first paragraph, second sentence states, “[t]he LifeGuard Freedom Flex GMWB and LifeGuard Freedom Flex with Joint Option GMWB allow the Owner … with the assistance of his or her financial professional, to select an available combination of Options…” This language indicates that there is something special about these GMWBs that allow the assessments of needs in a way that other GMWBs don’t. Either delete this sentence or revise to make it clear why these GMWBs allow the assessments of needs in a way that other GMWBs don’t. Response: The above-referenced language was a carry-over from the way these benefits are described in Contracts with multiple alternative GMWB options. As a result, it has been determined unnecessary for this product, and the prospectus has been revised as follows (p. 63): “These GMWBs allow the Owner (or the Owner and the Owner’s spouse), with the assistance of his or her financial professional, to select an available combination of Options, consistent with a variety of considerations, such as: his or her expectations of market performance; anticipated timing of subsequent Premiums; needs for future guaranteed annual percentage of withdrawals; expectation of need for early or unscheduled withdrawals to fund then current living expenses and obligations; marital and family status; and tax-qualified or non-tax-qualified purpose of the investment.” e. On page 64, the registrant states that “[d]ifferences in the percentage of a Bonus Option do not otherwise affect the operation of the resulting combination of Options.” This sentence, standing as it does by itself without context, isn’t clear. Please relocate the sentence to an appropriate location (e.g., the Bonus section) and clarify in plain English what is intended. Response: The above-referenced sentence was a carry-over from a version of this benefit that had multiple additional options related to types of step-ups. As a result, it has been determined unnecessary for this product, and deleted (p. 63). f. At the bottom of page 64, the registrant states, “If the For Life Guarantee is the in effect the guarantee lasts for the lifetime of the Designated Life, or if there are joint Owners, the lifetime of the joint Owner who dies first…” For clarity, the phrase beginning with the word “first” should be placed in bold. 5 Respo