SEC Company Response from JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730) — Apr 29, 2021
JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730)
Date: April 29, 2021 · CIK: 0000927730 · Accession: 0000927730-21-000268
AI Filing Summary & Sentiment
File numbers found in text: 333-252332, 333-252333
Letter
responsecombined
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: April 29, 2021
SUBJECT: Response to Comments for Initial Registration Statement filed on Form N-4 for File Nos. 333-252333 (Jackson Retirement Investment Annuity); Jackson National Separate Account - I of Jackson National Life Insurance Company; and Initial Registration Statement filed on Form N-4 for File No. 333-252332 (New York Jackson Retirement Investment Annuity); JNLNY Separate Account I of Jackson National Life Insurance Company of New York
This memorandum is in response to the comments you provided via email on March 25, 2021 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 both registration statements referenced above. Comments and responses apply to both the Statutory Prospectus and Initial Summary Prospectus, as applicable, unless indicated otherwise below. Copies of the Statutory Prospectus, SAI, Rate Sheet Prospectus Supplement, and Initial Summary Prospectus for File No. 333-252333, and Statutory Prospectus for File No. 333-252332, 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 documents, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to each of the other Statutory Prospectus, SAI, Part C, Rate Sheet, and Initial Summary Prospectus for File No. 333-252332 as applicable. A pre-effective amendment to the above-referenced registration statements will subsequently be filed in response to the comments.
General Comments
1.Please confirm that all missing information, including the financial statements and all exhibits, will be filed in a pre-effective amendment to the registration statements. We may have further comments when you supply the omitted information.
Response: Confirmed. All missing information, including financial statements and all exhibits, will be filed in a pre-effective amendment to the registration statements.
2.Please include page numbers to cross-references throughout the prospectus.
Response: Registrant confirms that page numbers will be included with internal cross-references throughout the prospectus.
3.Please disclose to the staff whether there 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.
1 of 16
Response: Jackson National Life Insurance Company (“Jackson”) and Jackson National Life Insurance Company of New York (“Jackson NY”) will be solely responsible for payment of Contract benefits. There are no guarantee or support agreements with third parties to support any of Jackson’s or Jackson NY’s obligations under the Contracts.
4.Throughout the registration statement, all references 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).
Response: The above-referenced change has been made.
PROSPECTUS
5.Where appropriate in the prospectus, please discuss the impact of advisory fee deductions on contract benefits, 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 that the deductions of the advisory fee from contract value could reduce the relevant 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.
Response: Registrant does not permit the deduction of advisory fees from Contract Value if any optional benefit has been elected by the owner. As such, items referenced above regarding disclosures on impact of the deduction of advisory fees on optional benefits and optional benefit guaranteed values are not applicable and no revisions have been made in response thereto. Registrant confirms that it will make all necessary disclosure regarding impact on the basic death benefit and encouraging owners to discuss with their financial intermediaries in the same way it as complied with these requests on previous advisory product filings, which have since been approved by the Staff.
Cover Page
6.Disclose all material state variations and intermediary-specific variations (e.g., variations resulting from different brokerage channels) to the offering. (See Form N-4, Instructions to Item 8(a)).
Response: Registrant does not vary the offering of the Contract based on the type of distribution channel. Consistent with industry practice, the prospectus includes disclosure that certain individual broker-dealers may not recommend or make available certain riders or options from time to time. Such decisions may be based on a variety factors such as age, financial condition or other suitability factors that are within the internal policies, knowledge and discretion of the selling firm. Such policies may change frequently and are beyond the scope of Jackson’s offering document.
7.Disclose that the contract is/may be available through third-party financial intermediaries who charge and 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
2 of 16
reduce] the death benefit(s), and may be subject to federal and state income taxes and a 10% federal penalty tax. (See Form N-4, Item 1(a)).
Response: The following disclosure has been added to the cover page as a stand-alone paragraph immediately after the second paragraph:
"The Contracts are or may be available through third party financial professionals who charge an advisory fee for their services. This advisory fee is in addition to contract fees and expenses disclosed in this prospectus. If you elect to pay the advisory fee from your Contract Value, this deduction will or may reduce the death benefit and may be subject to federal and state income taxes and a 10% federal penalty tax." (p. 1)
8.With respect to obtaining a copy of the most recent Rate Sheet Prospectus Supplement, please use a more specific web address.
Response: The above-referenced disclosure has been revised as follows:
“This prospectus utilizes Rate Sheet Prospectus Supplements to describe the current annual charges 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/product-literature-3.html.” (p. 1)
9.Please provide the landing page where all the required documents are located.
Response: Registrant confirms that the landing page URL appears on the cover page of the prospectus.
10.With respect to the fourth paragraph, please consider whether the following language is necessary cover page disclosure, “[i]n some states, you may purchase the Contract through an automated electronic transmission/order ticket verification procedure.”
Response: Registrant has removed the above-referenced disclosure. (p. 1)
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.
Response: The above-referenced disclosure has been removed from the cover page and relocated to a new subsection titled "Rule 12h-7 Reliance" located under "Other Information". (p. 1)
12.With respect to the last paragraph, please separate the last sentence beginning, “[y]ou may elect to receive certain communication . . .” from the free look paragraph.
Response: The above-referenced change has been made. (p. 2)
13.With respect to the first bullet of the last paragraph, please confirm whether Jackson still intends to mail a postage-paid card when relying on Rule 498A. Further, please confirm whether “cover of this report” should be “prospectus.”
Response: There will be postage-paid cards available on the covers of the statutory prospectus, as well as both the Initial Summary Prospectus and the Updating Summary Prospectus. The disclosure has been revised as follows:
"You may elect to receive certain communications from Jackson electronically by doing one of the following:
•Mailing in the postage-paid card on the cover of either this report or the Summary Prospectus;
3 of 16
•Calling 1-866-349-4564; or
•Signing up on www.jackson.com" (p. 2)
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.
Response: The above-referenced change has been made. (p. 8)
15.Please change the “Charges for Early Withdrawal” heading to “Charges for Early Withdrawals.” (See Form N-4, Instruction 1(a) to Item 2).
Response: The above-referenced change has been made. (p. 8)
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 reflected, the fees and expenses would be higher.
Response: The above-referenced change has been made. (p. 8)
17.With respect to item one in the “Annual Fee” column, please confirm that “Base Contract” reflects the annual contract maintenance charge.
Response: Registrant confirms that the Base Contract row of the Key Information Table reflects consideration of the Annual Contract Maintenance Charge. (p. 8)
18.Change “Add-on Benefit” to “Optional Benefit” throughout the key information table. (See Instruction 1(a) to Item 2).
Response: The required headings and information contained in the key information table relating to optional benefits have been revised as requested. (p. 8)
19.In footnote 3, only identify the basis for the charge. (See Instruction 2(c) to Item 2).
Response: Footnote 3 has been revised as follows:
“The minimum fee reflects an annualized percentage of Contract Value. The maximum fee reflects an annualized percentage of the GWB.” (p. 8)
20.On page four, please remove “Estimate from each column heading.
Response: The above-referenced change has been made. (p. 9)
21.In each column at the top of page four, modify the bullets to read “No sales charges or advisory fees.”
Response: The above-referenced change has been made. (p. 9)
22.With respect to the fourth bullet in the “Risks Associated with Investment Options” row, please replace “the prospectuses for the available Funds” with “these investment options.” The form requires that investors review the investment options (including the fixed account investment options) before making an investment decision. We note that the fixed account investment options do not have a prospectus, but likewise should be reviewed. (See Instruction 3(c) to Item 2).
4 of 16
Response: The above-referenced change has been made. (p. 9)
23.With respect to the second and third bullets of the Add-On Benefits section on page five, as applicable, state 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.
Response: Registrant does not permit the deduction of advisory fees from Contract Value if any add-on benefit has been elected by the owner. As such, Registrant respectfully believes the above-referenced disclosure is not warranted here, and declines to make such revision.
24.With respect to the third bullet in the Add-On Benefits section, confirm any material state variations are disclosed in the prospectus. (See Instruction to Item 8(a)).
Response: All material state variations to the add-on benefits are disclosed in the prospectus.
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.
Response: The following new paragraph has been added to the Overview of the Contract section:
"Q. How is my Contract impacted by the deduction of advisory fees?
A. Currently, we permit you to deduct advisory fees directly from your Contract Value in order to pay third party financial professionals. This advisory fee is in addition to Contract fees and expenses disclosed in this prospectus. If you elect to pay the advisory fee from your Contract Value, this deduction may reduce the basic death benefit and may be subject to federal and state income taxes and a 10% federal penalty tax. In order to avoid negatively impacting your add-on benefits, we do not permit the deduction of advisory fees from your Contract Value if you have elected any of the available add-on benefits." (p. 12)
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.”
Response: The above-referenced disclosure has been revised as follows:
"Through the annuitization feature, the Contract can supplement your retirement income by providing a stream of income payments. The Contract also offers certain optional living benefits that provide you with the ability to take guaranteed withdrawals." (p. 11)
27.In the answer to “How do I accumulate assets in the Contract and receive income from the Contract?” please bold or prominently disclose “A list of Funds in which the Investment Divisions currently invest 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).
Response: The above-referenced change has been made, and the disclosure bolded and revised as follows:
"A list of Funds and additional information about the Funds in which the Investment Divisions currently invest is provided in Appendix A: Funds Available Under the Contract." (p. 11)
5 of 16
28.With respect to the penultimate sentence in the answer to “How do I accumulate assets in the Contract and receive income from the Contract?” please consider whether to add “depending on the income option you select.”
Response: Registrant respectfu
Show Raw Text
CORRESP 1 filename1.htm responsecombined 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: April 29, 2021 SUBJECT: Response to Comments for Initial Registration Statement filed on Form N-4 for File Nos. 333-252333 (Jackson Retirement Investment Annuity); Jackson National Separate Account - I of Jackson National Life Insurance Company; and Initial Registration Statement filed on Form N-4 for File No. 333-252332 (New York Jackson Retirement Investment Annuity); JNLNY Separate Account I of Jackson National Life Insurance Company of New York This memorandum is in response to the comments you provided via email on March 25, 2021 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 both registration statements referenced above. Comments and responses apply to both the Statutory Prospectus and Initial Summary Prospectus, as applicable, unless indicated otherwise below. Copies of the Statutory Prospectus, SAI, Rate Sheet Prospectus Supplement, and Initial Summary Prospectus for File No. 333-252333, and Statutory Prospectus for File No. 333-252332, 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 documents, as identified by the original staff comment, unless indicated otherwise. Corresponding changes will be made to each of the other Statutory Prospectus, SAI, Part C, Rate Sheet, and Initial Summary Prospectus for File No. 333-252332 as applicable. A pre-effective amendment to the above-referenced registration statements will subsequently be filed in response to the comments. General Comments 1.Please confirm that all missing information, including the financial statements and all exhibits, will be filed in a pre-effective amendment to the registration statements. We may have further comments when you supply the omitted information. Response: Confirmed. All missing information, including financial statements and all exhibits, will be filed in a pre-effective amendment to the registration statements. 2.Please include page numbers to cross-references throughout the prospectus. Response: Registrant confirms that page numbers will be included with internal cross-references throughout the prospectus. 3.Please disclose to the staff whether there 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. 1 of 16 Response: Jackson National Life Insurance Company (“Jackson”) and Jackson National Life Insurance Company of New York (“Jackson NY”) will be solely responsible for payment of Contract benefits. There are no guarantee or support agreements with third parties to support any of Jackson’s or Jackson NY’s obligations under the Contracts. 4.Throughout the registration statement, all references 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). Response: The above-referenced change has been made. PROSPECTUS 5.Where appropriate in the prospectus, please discuss the impact of advisory fee deductions on contract benefits, 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 that the deductions of the advisory fee from contract value could reduce the relevant 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. Response: Registrant does not permit the deduction of advisory fees from Contract Value if any optional benefit has been elected by the owner. As such, items referenced above regarding disclosures on impact of the deduction of advisory fees on optional benefits and optional benefit guaranteed values are not applicable and no revisions have been made in response thereto. Registrant confirms that it will make all necessary disclosure regarding impact on the basic death benefit and encouraging owners to discuss with their financial intermediaries in the same way it as complied with these requests on previous advisory product filings, which have since been approved by the Staff. Cover Page 6.Disclose all material state variations and intermediary-specific variations (e.g., variations resulting from different brokerage channels) to the offering. (See Form N-4, Instructions to Item 8(a)). Response: Registrant does not vary the offering of the Contract based on the type of distribution channel. Consistent with industry practice, the prospectus includes disclosure that certain individual broker-dealers may not recommend or make available certain riders or options from time to time. Such decisions may be based on a variety factors such as age, financial condition or other suitability factors that are within the internal policies, knowledge and discretion of the selling firm. Such policies may change frequently and are beyond the scope of Jackson’s offering document. 7.Disclose that the contract is/may be available through third-party financial intermediaries who charge and 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 2 of 16 reduce] the death benefit(s), and may be subject to federal and state income taxes and a 10% federal penalty tax. (See Form N-4, Item 1(a)). Response: The following disclosure has been added to the cover page as a stand-alone paragraph immediately after the second paragraph: "The Contracts are or may be available through third party financial professionals who charge an advisory fee for their services. This advisory fee is in addition to contract fees and expenses disclosed in this prospectus. If you elect to pay the advisory fee from your Contract Value, this deduction will or may reduce the death benefit and may be subject to federal and state income taxes and a 10% federal penalty tax." (p. 1) 8.With respect to obtaining a copy of the most recent Rate Sheet Prospectus Supplement, please use a more specific web address. Response: The above-referenced disclosure has been revised as follows: “This prospectus utilizes Rate Sheet Prospectus Supplements to describe the current annual charges 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/product-literature-3.html.” (p. 1) 9.Please provide the landing page where all the required documents are located. Response: Registrant confirms that the landing page URL appears on the cover page of the prospectus. 10.With respect to the fourth paragraph, please consider whether the following language is necessary cover page disclosure, “[i]n some states, you may purchase the Contract through an automated electronic transmission/order ticket verification procedure.” Response: Registrant has removed the above-referenced disclosure. (p. 1) 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. Response: The above-referenced disclosure has been removed from the cover page and relocated to a new subsection titled "Rule 12h-7 Reliance" located under "Other Information". (p. 1) 12.With respect to the last paragraph, please separate the last sentence beginning, “[y]ou may elect to receive certain communication . . .” from the free look paragraph. Response: The above-referenced change has been made. (p. 2) 13.With respect to the first bullet of the last paragraph, please confirm whether Jackson still intends to mail a postage-paid card when relying on Rule 498A. Further, please confirm whether “cover of this report” should be “prospectus.” Response: There will be postage-paid cards available on the covers of the statutory prospectus, as well as both the Initial Summary Prospectus and the Updating Summary Prospectus. The disclosure has been revised as follows: "You may elect to receive certain communications from Jackson electronically by doing one of the following: •Mailing in the postage-paid card on the cover of either this report or the Summary Prospectus; 3 of 16 •Calling 1-866-349-4564; or •Signing up on www.jackson.com" (p. 2) 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. Response: The above-referenced change has been made. (p. 8) 15.Please change the “Charges for Early Withdrawal” heading to “Charges for Early Withdrawals.” (See Form N-4, Instruction 1(a) to Item 2). Response: The above-referenced change has been made. (p. 8) 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 reflected, the fees and expenses would be higher. Response: The above-referenced change has been made. (p. 8) 17.With respect to item one in the “Annual Fee” column, please confirm that “Base Contract” reflects the annual contract maintenance charge. Response: Registrant confirms that the Base Contract row of the Key Information Table reflects consideration of the Annual Contract Maintenance Charge. (p. 8) 18.Change “Add-on Benefit” to “Optional Benefit” throughout the key information table. (See Instruction 1(a) to Item 2). Response: The required headings and information contained in the key information table relating to optional benefits have been revised as requested. (p. 8) 19.In footnote 3, only identify the basis for the charge. (See Instruction 2(c) to Item 2). Response: Footnote 3 has been revised as follows: “The minimum fee reflects an annualized percentage of Contract Value. The maximum fee reflects an annualized percentage of the GWB.” (p. 8) 20.On page four, please remove “Estimate from each column heading. Response: The above-referenced change has been made. (p. 9) 21.In each column at the top of page four, modify the bullets to read “No sales charges or advisory fees.” Response: The above-referenced change has been made. (p. 9) 22.With respect to the fourth bullet in the “Risks Associated with Investment Options” row, please replace “the prospectuses for the available Funds” with “these investment options.” The form requires that investors review the investment options (including the fixed account investment options) before making an investment decision. We note that the fixed account investment options do not have a prospectus, but likewise should be reviewed. (See Instruction 3(c) to Item 2). 4 of 16 Response: The above-referenced change has been made. (p. 9) 23.With respect to the second and third bullets of the Add-On Benefits section on page five, as applicable, state 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. Response: Registrant does not permit the deduction of advisory fees from Contract Value if any add-on benefit has been elected by the owner. As such, Registrant respectfully believes the above-referenced disclosure is not warranted here, and declines to make such revision. 24.With respect to the third bullet in the Add-On Benefits section, confirm any material state variations are disclosed in the prospectus. (See Instruction to Item 8(a)). Response: All material state variations to the add-on benefits are disclosed in the prospectus. 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. Response: The following new paragraph has been added to the Overview of the Contract section: "Q. How is my Contract impacted by the deduction of advisory fees? A. Currently, we permit you to deduct advisory fees directly from your Contract Value in order to pay third party financial professionals. This advisory fee is in addition to Contract fees and expenses disclosed in this prospectus. If you elect to pay the advisory fee from your Contract Value, this deduction may reduce the basic death benefit and may be subject to federal and state income taxes and a 10% federal penalty tax. In order to avoid negatively impacting your add-on benefits, we do not permit the deduction of advisory fees from your Contract Value if you have elected any of the available add-on benefits." (p. 12) 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.” Response: The above-referenced disclosure has been revised as follows: "Through the annuitization feature, the Contract can supplement your retirement income by providing a stream of income payments. The Contract also offers certain optional living benefits that provide you with the ability to take guaranteed withdrawals." (p. 11) 27.In the answer to “How do I accumulate assets in the Contract and receive income from the Contract?” please bold or prominently disclose “A list of Funds in which the Investment Divisions currently invest 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). Response: The above-referenced change has been made, and the disclosure bolded and revised as follows: "A list of Funds and additional information about the Funds in which the Investment Divisions currently invest is provided in Appendix A: Funds Available Under the Contract." (p. 11) 5 of 16 28.With respect to the penultimate sentence in the answer to “How do I accumulate assets in the Contract and receive income from the Contract?” please consider whether to add “depending on the income option you select.” Response: Registrant respectfu