SEC Company Response from JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730) — Oct 1, 2020
JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730)
Date: Oct. 1, 2020 · CIK: 0000927730 · Accession: 0000927730-20-000409
AI Filing Summary & Sentiment
File numbers found in text: 333-217500, 333-217502, 333-228801, 333-228802, 333-228806, 333-235567, 333-235568
Letter
secresponsememo
MEMORANDUM
TO: DeCarlo S. McLaren, Esq.
Senior Counsel
Disclosure Review and Accounting Office
U. S. Securities and Exchange Commission
FROM: Alison Samborn, Esq.
Associate General Counsel, Legal Product Development
DATE: October 1, 2020
SUBJECT: Response to Comments for Post-Effective Amendment No. 5 for File No. 333-228801; to the Registration Statement on Form N-4; Jackson National Separate Account - I (“Registrant”) of Jackson National Life Insurance Company (“Jackson”); and
Post-Effective Amendment No. 6 for File No. 333-228806; to the Registration Statement on Form N-4; JNLNY Separate Account I (“Registrant”) of Jackson National Life Insurance Company of New York (“Jackson of New York”)
This memorandum is in response to the comments you provided via telephone on September 28, 2020 for the above referenced filings.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific oral comments, followed respectively by narrative responses (in bold).
Unless indicated otherwise below, the comments and responses apply to both supplements to the registration statements referenced above. Copies of each supplement, 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 copy of the Jackson National Perspective II supplement, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to the other supplement as applicable. Post-effective amendments to the registration statements will subsequently be filed in response to the comments.
General Comments
1.Please remove all brackets and fill in any blanks before the next filing.
Response: All bracketed information will be revised with full and final disclosure prior to the final filing of these post-effective amendments.
2.On page 4, correct scrivener's error in header describing revisions related to the Guaranteed Withdrawal Balance Adjustment Percentages ("REALTED" should be "RELATED").
Response: The correction has been made as follows:
REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS FOR DISCLOSURE OF GUARANTEED WITHDRAWAL BALANCE ADJUSTMENT PERCENTAGES.
Page 1 of 4
Additional Information
The filings referenced in this memorandum are Template Filings, with similar changes being made in several other Replicate Filings. While the disclosure changes in the Template Filings are substantially identical to the disclosure changes in the Replicate Filings, there are some variations due to differences in the current availability of certain add-on benefits and product age. The following outlines the variations found in the Replicate Filings:
1.Jackson National Separate Account - I Replicate Filing Variations:
a.Jackson Advantage (Registration File No. 333-235567)
i.Jackson Advantage does not offer the LifeGuard Freedom Net Guaranteed Minimum Withdrawal Benefit ("GMWB"). As such, there are no references to the LifeGuard Freedom Net GMWB in the supplement.
ii.Jackson Advantage does not offer a Contract Anniversary Value GWB Step-Up option. As such, there are no references to a Contract Anniversary Value Step-Up in the supplement.
iii.The date range for information in the new historical appendices will go as far back as April 27, 2020 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
b.Perspective Advisory II (Registration File No. 333-217500)
i.Perspective Advisory II is an older product than the Perspective II product used in the Template Filing. As such, there is disclosure relating to historical values included in the Perspective Advisory II prospectus that does not exist in Perspective II. The following represent variations in Perspective Advisory II due to disclosure related to historical values:
1.Immediately following the GAWA% tables in the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," the following paragraph will be deleted:
a.If your endorsement was issued before June 24, 2019, different GAWA percentages than those reflected in the above table may apply. Please refer to your Contract endorsement and the related prospectus disclosure for the GAWA percentages applicable under your Contract at the time of purchase. If you need assistance finding this information, please contact your financial professional, or contact us at our Service Center. Our contact information is on the first page of the prospectus.
2.In the subsections titled "Guaranteed Withdrawal Balance Adjustment." within the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," disclosure related to historical values will remain to identify that, for Contracts issued before June 24, 2019, the maximum Guaranteed Withdrawal Balance ("GWB") Adjustment is $5 million.
3.In the subsection titled "Optional Death Benefits." and sub-subsection titled "LifeGuard Freedom Flex DB" under the section titled "DEATH BENEFIT," disclosure related to historical values is retained to clarify that the maximum age of the Designated Life for election of the LifeGuard Freedom Flex DB is 72 for endorsements issued before February 11, 2019.
Page 2 of 4
4.The date range for information in the new historical appendices will go back as far as September 25, 2017 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
c.Retirement Latitudes (Registration File No. 333-228802)
i.No material variations.
2.JNLNY Separate Account I Replicate Filing Variations:
a.Jackson Advantage (Registration File No. 333-235568)
i.Jackson Advantage does not offer the LifeGuard Freedom Net Guaranteed Minimum Withdrawal Benefit ("GMWB"). As such, there are no references to the LifeGuard Freedom Net GMWB in the supplement.
ii.Jackson Advantage does not offer a Contract Anniversary Value GWB Step-Up option. As such, there are no references to a Contract Anniversary Value Step-Up in the supplement.
iii.The date range for information in the new historical appendices will go as far back as April 27, 2020 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
b.Perspective Advisory II (Registration File No. 333-217502)
i.Perspective Advisory II is an older product than the Perspective II product used in the Template Filing. As such, there is disclosure relating to historical values included in the Perspective Advisory II prospectus that does not exist in Perspective II. The following represent variations in Perspective Advisory II due to disclosure related to historical values:
1.Immediately following the GAWA% tables in the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," the following paragraph will be deleted:
a.If your endorsement was issued before June 24, 2019, different GAWA percentages than those reflected in the above table may apply. Please refer to your Contract endorsement and the related prospectus disclosure for the GAWA percentages applicable under your Contract at the time of purchase. If you need assistance finding this information, please contact your financial professional, or contact us at our Annuity Service Center. Our contact information is on the first page of the prospectus.
2.In the subsections titled "Guaranteed Withdrawal Balance Adjustment." within the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," disclosure related to historical values will remain to identify that, for Contracts issued before June 24, 2019, the maximum Guaranteed Withdrawal Balance ("GWB") Adjustment is $5 million.
3.In the subsection titled "Optional Death Benefits." and sub-subsection titled "LifeGuard Freedom Flex DB NY" under the section titled "DEATH BENEFIT," disclosure related to historical values is retained to clarify that the maximum age of the Designated Life for election of the LifeGuard Freedom Flex DB NY is 72 for endorsements issued before February 11, 2019.
Page 3 of 4
4.The date range for information in the new historical appendices will go back as far as April 30, 2018 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
Please contact me at (517) 331-4262 if you have any questions or require additional information.
Page 4 of 4
THE INFORMATION IN THE PROSPECTUS AS MODIFIED BY THIS SUPPLEMENT IS NOT COMPLETE AND MAY BE CHANGED. WE MAY NOT SELL THESE SECURITIES UNTIL THE REGISTRATION STATEMENT FILED WITH THE SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THE PROSPECTUS AS MODIFIED BY THIS SUPPLEMENT IS NOT AN OFFER TO SELL THESE SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED.
Supplement Dated _______________, 2020
To The Prospectus Dated April 27, 2020 For
PERSPECTIVE II®
FLEXIBLE PREMIUM VARIABLE AND FIXED DEFERRED ANNUITY
(Contracts offered for sale on and after June 24, 2019)
Issued by
Jackson National Life Insurance Company® through
Jackson National Separate Account - I
This supplement updates the above-referenced prospectus. Please read and keep it together with your prospectus for future reference. To obtain an additional copy of the prospectus, please contact us at our Service Center, P.O. Box 24068, Lansing, Michigan, 48909-4068; 1-800-644-4565; www.jackson.com.
Effective ____________, 2020, your prospectus is revised to accommodate changes to the way Bonus percentage options, Guaranteed Withdrawal Balance Adjustment percentages, and Guaranteed Annual Withdrawal Amount percentages are disclosed for certain optional living and death benefits. Starting on the effective date of this supplement, these values will be disclosed in Rate Sheet Prospectus Supplements, and will be removed from the body of the prospectus. Your prospectus is revised as follows:
GENERAL REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS.
Ø On the cover page of the prospectus, immediately after the second paragraph, the following paragraph is inserted:
This prospectus utilizes Rate Sheet Prospectus Supplements to describe the current Bonus percentages, Guaranteed Withdrawal Balance Adjustment percentages, and Guaranteed Annual Withdrawal Amount percentages for certain add-on living and death benefits. To obtain a copy of the most recent Rate Sheet Prospectus Supplement(s), please visit www.jackson.com.
Ø In the Table of Contents of the prospectus, new line-items for newly added appendices are added as follows:
APPENDIX E (Historical GAWA Percentages)
E-1
APPENDIX F (Historical GWB Adjustment Percentages)
F-1
APPENDIX G (Historical GMWB Bonus Percentages)
G-1
Ø In the section titled “Glossary” on page 1 of the prospectus, a new definition for Rate Sheet Prospectus Supplement is added as follows:
Rate Sheet Prospectus Supplement - a supplement to the prospectus that lists certain values currently applicable to new purchases of add-on benefits.
REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS FOR DISCLOSURE OF GMWB BONUS PERCENTAGES.
Ø In the table titled “Periodic Expenses”, appearing under “FEES AND EXPENSES TABLES” on page 5 of the prospectus, the line items for the following add-on benefits are deleted and replaced with the following:
Page 1
Maximum
Annual
Charge
Current
Annual
Charge
For Life GMWB With Bonus and Step-Up to the Highest Quarterly Contract Value (“LifeGuard Freedom Flex® GMWB”) with the Income Stream Max GAWA% Table, Bonus III, and Annual Step-Up 14
3.00% 1.65%
Joint For Life GMWB With Bonus and Step-Up to the Highest Quarterly Contract Value (“LifeGuard Freedom Flex® With Joint Option GMWB”) with the Income Stream Max GAWA% Table, Bonus III, and Annual Step-Up 15
3.00% 1.75%
Ø In the sections titled “For Life Guaranteed Minimum Withdrawal Benefit With Bonus And Step-Up (“LifeGuard Freedom Flex GMWB”) Charge.” and “Joint For Life Guaranteed Minimum Withdrawal Benefit With Bonus And Step-Up (“LifeGuard Freedom Flex With Joint Option GMWB”) Charge.” appearing under “CONTRACT CHARGES” on pages 41 and 43, respectively, of the prospectus, all references to the 4% Bonus are replaced with references to “Bonus I,” all references to the 5% Bonus are replaced with references to “Bonus II,” and all references to the 6% Bonus are replaced with references to “Bonus III.”
Ø In the subsection titled “LifeGuard Freedom Flex DB Charge.” appearing under the section titled “Death Benefit Charges.” on page 48 of the prospectus, the first paragraph is deleted and replaced with the following:
LifeGuard Freedom Flex DB Charge. If you select the LifeGuard Freedom Flex DB optional death benefit, which is only available in conjunction with the purchase of the LifeGuard Freedom Flex GMWB with the Bonus II option, you will pay two separate charges for the combined benefit. The charge for LifeGuard Freedom Flex DB, which is based on a percentage of the GMWB Death Benefit, is separate from and in addition to the charge for the LifeGuard Freedom Flex GMWB. The charge for this death benefit begins when the endorsement is added to the Contract and is expressed as an annual percentage of the GMWB Death Benefit. The percentage varies depending on which Guaranteed Annual Withdrawal Amount Percentage (“GAWA%”) table you elect (see table below). At the time you purchased your Contract, different Bonus option requirements may have been in place for election of the LifeGuard Freedom Flex DB. Please see “Appendix G (Historical GMWB Bonus Percentages)” for more information.
Ø In the subsections titled “Bonus” appearing under both the section titled “For Life Guaranteed Minimum Withdrawal Benefit with Bonus, Annual Step-Up and Earnings-Sensitive Withdrawal Amount (“LifeGuard Freedom Net GMWB”).” and the section titled “Joint For Life Guaranteed Minimum Withdrawal Benefit With Bonus, Annual Step-Up And Earnings-Sensitive Withdrawal Amount (“LifeGuard Freedom Net With Joint Option GMWB”).” on pages 63 and 74, respectively, of the prospectus, the following revisions are made:
1. all references to the “5% Bonus” generally, and references to “5% of the Bonus Base” are deleted and replaced with references to “a percentage,”; and
2. In the first paragraph of the subsection, the following language is inserted immediately after the second sentence:
The current bonus percentage is disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com. For a list of historical bonus percentages, please see “Appendix G (Historical GMWB Bonus Percentages).”
Ø In the section titled “Guaranteed Minimum Withdrawal Benefits for a Single Life or two Covered Lives with Combinations of Optional Bonus Percentage Amounts, Annual or Quarterly Contract Value-Based Step-Ups, and Guaranteed Death Benefit (“LifeGuard Freedom Flex GMWB” and “LifeGuard Freedom Flex with Joint Option GMWB”).” on page 87 of the prospectus, the following changes are made:
1. In the third paragraph, the first bullet point is deleted and replaced with the following:
•a range of bonus percentage amounts (Current bonus percentage amounts are disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com. For a list of historical bonus percentages, please see “Appendix G (Historical GMWB Bonus Percentages).”),
2. In the "
Show Raw Text
CORRESP
1
filename1.htm
secresponsememo
MEMORANDUM
TO: DeCarlo S. McLaren, Esq.
Senior Counsel
Disclosure Review and Accounting Office
U. S. Securities and Exchange Commission
FROM: Alison Samborn, Esq.
Associate General Counsel, Legal Product Development
DATE: October 1, 2020
SUBJECT: Response to Comments for Post-Effective Amendment No. 5 for File No. 333-228801; to the Registration Statement on Form N-4; Jackson National Separate Account - I (“Registrant”) of Jackson National Life Insurance Company (“Jackson”); and
Post-Effective Amendment No. 6 for File No. 333-228806; to the Registration Statement on Form N-4; JNLNY Separate Account I (“Registrant”) of Jackson National Life Insurance Company of New York (“Jackson of New York”)
This memorandum is in response to the comments you provided via telephone on September 28, 2020 for the above referenced filings.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific oral comments, followed respectively by narrative responses (in bold).
Unless indicated otherwise below, the comments and responses apply to both supplements to the registration statements referenced above. Copies of each supplement, 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 copy of the Jackson National Perspective II supplement, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to the other supplement as applicable. Post-effective amendments to the registration statements will subsequently be filed in response to the comments.
General Comments
1.Please remove all brackets and fill in any blanks before the next filing.
Response: All bracketed information will be revised with full and final disclosure prior to the final filing of these post-effective amendments.
2.On page 4, correct scrivener's error in header describing revisions related to the Guaranteed Withdrawal Balance Adjustment Percentages ("REALTED" should be "RELATED").
Response: The correction has been made as follows:
REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS FOR DISCLOSURE OF GUARANTEED WITHDRAWAL BALANCE ADJUSTMENT PERCENTAGES.
Page 1 of 4
Additional Information
The filings referenced in this memorandum are Template Filings, with similar changes being made in several other Replicate Filings. While the disclosure changes in the Template Filings are substantially identical to the disclosure changes in the Replicate Filings, there are some variations due to differences in the current availability of certain add-on benefits and product age. The following outlines the variations found in the Replicate Filings:
1.Jackson National Separate Account - I Replicate Filing Variations:
a.Jackson Advantage (Registration File No. 333-235567)
i.Jackson Advantage does not offer the LifeGuard Freedom Net Guaranteed Minimum Withdrawal Benefit ("GMWB"). As such, there are no references to the LifeGuard Freedom Net GMWB in the supplement.
ii.Jackson Advantage does not offer a Contract Anniversary Value GWB Step-Up option. As such, there are no references to a Contract Anniversary Value Step-Up in the supplement.
iii.The date range for information in the new historical appendices will go as far back as April 27, 2020 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
b.Perspective Advisory II (Registration File No. 333-217500)
i.Perspective Advisory II is an older product than the Perspective II product used in the Template Filing. As such, there is disclosure relating to historical values included in the Perspective Advisory II prospectus that does not exist in Perspective II. The following represent variations in Perspective Advisory II due to disclosure related to historical values:
1.Immediately following the GAWA% tables in the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," the following paragraph will be deleted:
a.If your endorsement was issued before June 24, 2019, different GAWA percentages than those reflected in the above table may apply. Please refer to your Contract endorsement and the related prospectus disclosure for the GAWA percentages applicable under your Contract at the time of purchase. If you need assistance finding this information, please contact your financial professional, or contact us at our Service Center. Our contact information is on the first page of the prospectus.
2.In the subsections titled "Guaranteed Withdrawal Balance Adjustment." within the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," disclosure related to historical values will remain to identify that, for Contracts issued before June 24, 2019, the maximum Guaranteed Withdrawal Balance ("GWB") Adjustment is $5 million.
3.In the subsection titled "Optional Death Benefits." and sub-subsection titled "LifeGuard Freedom Flex DB" under the section titled "DEATH BENEFIT," disclosure related to historical values is retained to clarify that the maximum age of the Designated Life for election of the LifeGuard Freedom Flex DB is 72 for endorsements issued before February 11, 2019.
Page 2 of 4
4.The date range for information in the new historical appendices will go back as far as September 25, 2017 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
c.Retirement Latitudes (Registration File No. 333-228802)
i.No material variations.
2.JNLNY Separate Account I Replicate Filing Variations:
a.Jackson Advantage (Registration File No. 333-235568)
i.Jackson Advantage does not offer the LifeGuard Freedom Net Guaranteed Minimum Withdrawal Benefit ("GMWB"). As such, there are no references to the LifeGuard Freedom Net GMWB in the supplement.
ii.Jackson Advantage does not offer a Contract Anniversary Value GWB Step-Up option. As such, there are no references to a Contract Anniversary Value Step-Up in the supplement.
iii.The date range for information in the new historical appendices will go as far back as April 27, 2020 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
b.Perspective Advisory II (Registration File No. 333-217502)
i.Perspective Advisory II is an older product than the Perspective II product used in the Template Filing. As such, there is disclosure relating to historical values included in the Perspective Advisory II prospectus that does not exist in Perspective II. The following represent variations in Perspective Advisory II due to disclosure related to historical values:
1.Immediately following the GAWA% tables in the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," the following paragraph will be deleted:
a.If your endorsement was issued before June 24, 2019, different GAWA percentages than those reflected in the above table may apply. Please refer to your Contract endorsement and the related prospectus disclosure for the GAWA percentages applicable under your Contract at the time of purchase. If you need assistance finding this information, please contact your financial professional, or contact us at our Annuity Service Center. Our contact information is on the first page of the prospectus.
2.In the subsections titled "Guaranteed Withdrawal Balance Adjustment." within the LifeGuard Freedom Net (Single and Joint) and LifeGuard Freedom Flex (Single and Joint) sections under "ACCESS TO YOUR MONEY," disclosure related to historical values will remain to identify that, for Contracts issued before June 24, 2019, the maximum Guaranteed Withdrawal Balance ("GWB") Adjustment is $5 million.
3.In the subsection titled "Optional Death Benefits." and sub-subsection titled "LifeGuard Freedom Flex DB NY" under the section titled "DEATH BENEFIT," disclosure related to historical values is retained to clarify that the maximum age of the Designated Life for election of the LifeGuard Freedom Flex DB NY is 72 for endorsements issued before February 11, 2019.
Page 3 of 4
4.The date range for information in the new historical appendices will go back as far as April 30, 2018 (the product's effective date). This varies from the date range in the Perspective II supplement, which has an effective date of June 24, 2019.
Please contact me at (517) 331-4262 if you have any questions or require additional information.
Page 4 of 4
THE INFORMATION IN THE PROSPECTUS AS MODIFIED BY THIS SUPPLEMENT IS NOT COMPLETE AND MAY BE CHANGED. WE MAY NOT SELL THESE SECURITIES UNTIL THE REGISTRATION STATEMENT FILED WITH THE SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THE PROSPECTUS AS MODIFIED BY THIS SUPPLEMENT IS NOT AN OFFER TO SELL THESE SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED.
Supplement Dated _______________, 2020
To The Prospectus Dated April 27, 2020 For
PERSPECTIVE II®
FLEXIBLE PREMIUM VARIABLE AND FIXED DEFERRED ANNUITY
(Contracts offered for sale on and after June 24, 2019)
Issued by
Jackson National Life Insurance Company® through
Jackson National Separate Account - I
This supplement updates the above-referenced prospectus. Please read and keep it together with your prospectus for future reference. To obtain an additional copy of the prospectus, please contact us at our Service Center, P.O. Box 24068, Lansing, Michigan, 48909-4068; 1-800-644-4565; www.jackson.com.
Effective ____________, 2020, your prospectus is revised to accommodate changes to the way Bonus percentage options, Guaranteed Withdrawal Balance Adjustment percentages, and Guaranteed Annual Withdrawal Amount percentages are disclosed for certain optional living and death benefits. Starting on the effective date of this supplement, these values will be disclosed in Rate Sheet Prospectus Supplements, and will be removed from the body of the prospectus. Your prospectus is revised as follows:
GENERAL REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS.
Ø On the cover page of the prospectus, immediately after the second paragraph, the following paragraph is inserted:
This prospectus utilizes Rate Sheet Prospectus Supplements to describe the current Bonus percentages, Guaranteed Withdrawal Balance Adjustment percentages, and Guaranteed Annual Withdrawal Amount percentages for certain add-on living and death benefits. To obtain a copy of the most recent Rate Sheet Prospectus Supplement(s), please visit www.jackson.com.
Ø In the Table of Contents of the prospectus, new line-items for newly added appendices are added as follows:
APPENDIX E (Historical GAWA Percentages)
E-1
APPENDIX F (Historical GWB Adjustment Percentages)
F-1
APPENDIX G (Historical GMWB Bonus Percentages)
G-1
Ø In the section titled “Glossary” on page 1 of the prospectus, a new definition for Rate Sheet Prospectus Supplement is added as follows:
Rate Sheet Prospectus Supplement - a supplement to the prospectus that lists certain values currently applicable to new purchases of add-on benefits.
REVISIONS RELATED TO THE UTILIZATION OF RATE SHEET PROSPECTUS SUPPLEMENTS FOR DISCLOSURE OF GMWB BONUS PERCENTAGES.
Ø In the table titled “Periodic Expenses”, appearing under “FEES AND EXPENSES TABLES” on page 5 of the prospectus, the line items for the following add-on benefits are deleted and replaced with the following:
Page 1
Maximum
Annual
Charge
Current
Annual
Charge
For Life GMWB With Bonus and Step-Up to the Highest Quarterly Contract Value (“LifeGuard Freedom Flex® GMWB”) with the Income Stream Max GAWA% Table, Bonus III, and Annual Step-Up 14
3.00% 1.65%
Joint For Life GMWB With Bonus and Step-Up to the Highest Quarterly Contract Value (“LifeGuard Freedom Flex® With Joint Option GMWB”) with the Income Stream Max GAWA% Table, Bonus III, and Annual Step-Up 15
3.00% 1.75%
Ø In the sections titled “For Life Guaranteed Minimum Withdrawal Benefit With Bonus And Step-Up (“LifeGuard Freedom Flex GMWB”) Charge.” and “Joint For Life Guaranteed Minimum Withdrawal Benefit With Bonus And Step-Up (“LifeGuard Freedom Flex With Joint Option GMWB”) Charge.” appearing under “CONTRACT CHARGES” on pages 41 and 43, respectively, of the prospectus, all references to the 4% Bonus are replaced with references to “Bonus I,” all references to the 5% Bonus are replaced with references to “Bonus II,” and all references to the 6% Bonus are replaced with references to “Bonus III.”
Ø In the subsection titled “LifeGuard Freedom Flex DB Charge.” appearing under the section titled “Death Benefit Charges.” on page 48 of the prospectus, the first paragraph is deleted and replaced with the following:
LifeGuard Freedom Flex DB Charge. If you select the LifeGuard Freedom Flex DB optional death benefit, which is only available in conjunction with the purchase of the LifeGuard Freedom Flex GMWB with the Bonus II option, you will pay two separate charges for the combined benefit. The charge for LifeGuard Freedom Flex DB, which is based on a percentage of the GMWB Death Benefit, is separate from and in addition to the charge for the LifeGuard Freedom Flex GMWB. The charge for this death benefit begins when the endorsement is added to the Contract and is expressed as an annual percentage of the GMWB Death Benefit. The percentage varies depending on which Guaranteed Annual Withdrawal Amount Percentage (“GAWA%”) table you elect (see table below). At the time you purchased your Contract, different Bonus option requirements may have been in place for election of the LifeGuard Freedom Flex DB. Please see “Appendix G (Historical GMWB Bonus Percentages)” for more information.
Ø In the subsections titled “Bonus” appearing under both the section titled “For Life Guaranteed Minimum Withdrawal Benefit with Bonus, Annual Step-Up and Earnings-Sensitive Withdrawal Amount (“LifeGuard Freedom Net GMWB”).” and the section titled “Joint For Life Guaranteed Minimum Withdrawal Benefit With Bonus, Annual Step-Up And Earnings-Sensitive Withdrawal Amount (“LifeGuard Freedom Net With Joint Option GMWB”).” on pages 63 and 74, respectively, of the prospectus, the following revisions are made:
1. all references to the “5% Bonus” generally, and references to “5% of the Bonus Base” are deleted and replaced with references to “a percentage,”; and
2. In the first paragraph of the subsection, the following language is inserted immediately after the second sentence:
The current bonus percentage is disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com. For a list of historical bonus percentages, please see “Appendix G (Historical GMWB Bonus Percentages).”
Ø In the section titled “Guaranteed Minimum Withdrawal Benefits for a Single Life or two Covered Lives with Combinations of Optional Bonus Percentage Amounts, Annual or Quarterly Contract Value-Based Step-Ups, and Guaranteed Death Benefit (“LifeGuard Freedom Flex GMWB” and “LifeGuard Freedom Flex with Joint Option GMWB”).” on page 87 of the prospectus, the following changes are made:
1. In the third paragraph, the first bullet point is deleted and replaced with the following:
•a range of bonus percentage amounts (Current bonus percentage amounts are disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com. For a list of historical bonus percentages, please see “Appendix G (Historical GMWB Bonus Percentages).”),
2. In the "