SEC Company Response from JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730) — Feb 8, 2022
JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730)
Date: Feb. 8, 2022 · CIK: 0000927730 · Accession: 0000927730-22-000005
AI Filing Summary & Sentiment
File numbers found in text: 333-235565
Letter
EAIISECResponseMemo
MEMORANDUM
TO: Michael Rosenberg
Attorney-Adviser
Disclosure Review and Accounting Office
Division of Investment Management
U. S. Securities and Exchange Commission
FROM: Alison Samborn, Esq.
Associate General Counsel, Insurance Legal
DATE: February 8, 2022
SUBJECT: Response to Comments for Post Effective Amendment No. 4 for File No. 333-235565 (Elite Access II); to the Registration Statement on Form N-4; Jackson National Separate Account - I (“Registrant”) of Jackson National Life Insurance Company (“Jackson”)
This memorandum is in response to the comments you provided via telephone on January 10, 2021 for the above referenced filing.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific comments, followed respectively by narrative responses (in bold).
Excerpted pages of the Statutory Prospectus and the Rate Sheet for File No. 333-235565, 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. A post-effective amendment to the above-referenced registration statements will subsequently be filed in response to the comments. Corresponding changes will be made to the Initial Summary Prospectus and Updating Summary Prospectus, as applicable.
Glossary (p. 1)
1.Consider defining GMDB since it applies to the EarningsMax benefit and the Return of Premium (“ROP”) Death Benefit.
Response: Registrant currently does not include definitions for “GMDB” in any of its variable annuity product prospectuses, choosing instead to provide inline explanations as discussions of GMDBs arise throughout the prospectus. Adding this glossary term to the current product would make it inconsistent with all other product prospectuses. Registrant respectfully declines to make the suggested change at this time, but intends to do analysis of all products at an appropriate juncture to determine whether holistic changes are appropriate.
Information You Should Consider About the Contract (p. 5)
2.Under the Optional Benefits row of the table, consider adding the following sentence: “Withdrawals may reduce the value of certain benefits by an amount greater than the value withdrawn.”
Response: The above-referenced change has been made. (p. 1)
Jackson® is the marketing name for Jackson National Life Insurance Company® (Home Office: Lansing, Michigan) and Jackson National Life Insurance Company of New York® (Home Office: Purchase, New York).
Benefits Available Under the Contracts Table (p. 16)
3.Under the EarningsMax row, if accurate, please consider stating that the purpose of the death benefit is to help offset federal and state taxes payable upon death in the contract.
Response: The above-referenced change has been made. The “Purpose” field for EarningsMax now reads:
“Increases the amount of the death benefit payable at your death based on a percentage of Contract earnings, which may help offset state and federal taxes due at the time of your death.” (p. 2)
4.Under the EarningsMax row, in the “Maximum Fee” column, the parenthetical is different from the Liquidity rider parenthetical, but both use the same description in the fee table. For consistency, please use the same language or explain supplementally what the difference is.
Response: The parenthenticals for both EarningsMax and the Liquidity Option have been revised as follows:
“(as an annualized percentage of the average daily Contract Value in the Investment Divisions)” (pp. 2-3)
5.Under the ROP Death Benefit row, in the “Maximum Fee” column, add a parenthetical identifying that the maximum fee is a percentage of benefit base.
Response: The above-referenced change has been made. (p. 2)
6.Under the ROP Death Benefit row, in the “Brief Description of Restrictions/Limitations” column, where it is stated that withdrawals may prematurely reduce the value, please state "significantly" and add that withdrawals may reduce the value of the benefit by more than the amount withdrawn.
Response: The above-referenced change has been made. (p. 2)
Death Benefit (p. 32)
7.In the EarningsMax section, if accurate, please consider stating that the purpose of the death benefit is to help offset federal and state taxes payable upon death in the contract.
Response: The first sentence of the EarningsMax section has been revised as follows:
“The Earnings Protection Benefit is an optional benefit that may increase the amount of the death benefit payable at your death, which may help offset state and federal taxes due upon your death.” (p. 4)
8.In the EarningsMax section, in the second to last paragraph starting with “Unlike the basic death benefit...” please provide more clarity as to how this operates. For example, if you have earnings, reach age 95 and annuitize, how does this benefit operate?
Response: Registrant respectfully believes that this information is already covered in the preceding paragraphs which go into detail on the percentage of earnings that will be added to the death benefit amount at the time it becomes payable. The paragraph identified in this comment is intended solely to disclose that the benefit is only payable if the owner chooses to annuitize on the Latest Income Date as defined in the contract. No changes have been made.
9.In the ROP Death Benefit section, in the second to last paragraph starting with “Unlike the basic death benefit...” please provide more clarity as to how this operates. For example, if you have earnings, reach age 95 and annuitize, how does this benefit operate?
Response: Registrant respectfully believes that this information is already covered in the preceding paragraphs which go into detail on the how this death benefit is calculated at the time it becomes payable. The paragraph identified in this comment is intended solely to disclose that the benefit is only payable if the owner chooses to annuitize on the Latest Income Date as defined in the contract. No changes have been made.
10.In the Spousal Continuation Option sub-section, consider editing the "if your spouse elects to continue the Contract, any GMDB will terminate" paragraph to state that this includes EarningsMax.
Response: The above-referenced paragraph has been revised to more broadly capture all add-on death benefits as follows:
“If your spouse elects to continue the Contract, any add-on death benefit will terminate upon the death of the Owner.” (p. 5)
Rate Sheet
11.Please note that a change in current fees may also impact the dollar range for lowest and highest annual cost and consider including these in the rate sheet.
Response: The following section has been added to the Rate Sheet Supplement immediately following the section identifying the current minimum and maximum annual fees:
“The current lowest and highest annual cost estimates, as displayed in the “Ongoing Fees and Expenses (annual charges)” section of the table contained in the “IMPORTANT INFORMATION YOU SHOULD CONSIDER ABOUT THE CONTRACT” section of the prospectus are:
LOWEST ANNUAL COST: $_____ HIGHEST ANNUAL COST: $_____
Assumes:
•Investment of $100,000
•5% annual appreciation
•Least expensive combination of Fund fees and expenses
•No add-on benefits
•No sales charges
•No additional purchase payments, transfers or withdrawals
Assumes:
•Investment of $100,000
•5% annual appreciation
•Most expensive combination of add-on benefits, Fund fees, and expenses
•No sales charges
•No additional purchase payments, transfers or withdrawals
” (pp. 6-7)
Please contact me at (517) 331-4262 if you have any questions or require additional information.
Jackson® is the marketing name for Jackson National Life Insurance Company® (Home Office: Lansing, Michigan) and Jackson National Life Insurance Company of New York® (Home Office: Purchase, New York).
Optional Benefits • Not all add-on benefits are available through all broker-dealers and may vary by state or date of purchase. • We may modify or discontinue an add-on benefit at any time. • Withdrawals may reduce the value of certain benefits by an amount greater than the value withdrawn. Benefits Available Under the Contract TAXES Tax Implications • Consult with a tax professional to determine the tax implications of an investment in and purchase payments received under this Contract. • If you purchase the Contract through a tax-qualified plan or individual retirement account (IRA), you do not get any additional tax deferral. • Earnings on your Contract are taxed at ordinary income tax rates when you withdraw them, and you may have to pay a penalty if you take a withdrawal before age 59 ½. Taxes CONFLICTS OF INTEREST Investment Professional Compensation Your registered representative or other investment professionals may receive compensation for selling this Contract to you in the form of commissions, revenue sharing, and other compensation programs. Accordingly, investment professionals may have a financial incentive to offer or recommend this Contract over another investment. Distribution of Contracts Exchanges Some investment professionals may have a financial incentive to offer you a new contract in place of the one you own. You should only consider exchanging your contract if you determine, after comparing the features, fees, and risks of both contracts, that it is in your best interest to purchase the new contract rather than continue to own your existing contract. Non-Qualified Contracts - 1035 Exchanges. 5
Add-On Death Benefits Available for a Fee. NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS EarningsMax Increases the amount of the death benefit payable at your death based on a percentage of Contract earnings, which may help offset state and federal taxes due at the time of your death. Maximum: 0.70% (as an annualized percentage of daily account value of your allocations tothe average daily Contract Value in the Investment Divisions) • Available only at Contract issue. • The benefit cannot be terminated. • Available to owners age 75 or younger. • Subject to maximum benefit. • On each fifth Contract Anniversary, the Guaranteed Minimum Death Benefit (“GMDB”) charge may be increased. • No benefit will be paid if (i) there are no earnings in your contract, or (ii) your spouse exercises the Spousal Continuation Option. • The Fixed Account Options are not available if you elect EarningsMax. Return of Premium Guaranteed Minimum Death Benefit Changes your basic death benefit during the accumulation phase of your Contract to the greater of: (i) Contract Value as of the end of the Business Day on which we receive all required documentation from your Beneficiary; or (ii) all Premiums paid into the Contract (net of any applicable premium taxes and charges), reduced for withdrawals (including any applicable adjustments) in proportion to the reduction in the Contract Value at the time of the withdrawal. Maximum: 0.40% (as a percentage of benefit base) • Withdrawals may significantlyprematurely reduce the value of this Return of Premium Death Benefit. • Withdrawals may reduce the value of this benefit by more than the dollar amount of the withdrawal. • On each fifth Contract Anniversary, the GMDB charge may be increased. • Ownership changes are allowed, but Covered Lives cannot be changed. Add-On Living Benefits Available for a Fee. The current annual charges for the add-on benefits are disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com/product-literature-1.html. For a list of historical add-on benefit charges, please see “Appendix E (Historical Add- On Benefit Charges).” All add-on living benefits: • must be added on the Issue Date. • terminates when you annuitize. • cannot be cancelled by you (except upon spousal continuation). 17
NAME OF BENEFIT PURPOSE FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Liquidity Option If you elect this Option, you will not pay a withdrawal charge when you make a partial or full withdrawal. This option removes the five year withdrawal charge schedule that would otherwise apply. Best if you anticipate taking or needing to take a large withdrawal that would otherwise be subject to charges under the five year withdrawal charge schedule imposed on each Premium payment. 0.25% on (as an annual basisannualized percentage of the average daily Contract Value in the Investment DivisionsDivision s) • Charges are deducted daily as part of the calculation of the value of the Accumulation Units. • The Capital Protection Program is not available on Contracts with the Liquidity Option. Other Add-On Benefits Included With All Contracts At No Additional Cost. NAME OF BENEFIT PURPOSE FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Rebalancing Automatically reallocates your Contract Value among Investment Divisions and the one-year Fixed Account Option (if currently available) periodically to maintain your selected allocation percentages. None • Rebalancing will terminate if your rebalancing program includes the one-year Fixed Account Option and we impose any transfer restrictions or requirements on the one- year Fixed Account Option. Dollar Cost Averaging Automatically transfers a dollar amount or percentage of money periodically from the one-year Fixed Account Option or any of the Investment Divisions into the Investment Divisions and other Fixed Account Options. None • Restrictions may apply if we impose any transfer restrictions on the one-year Fixed Account Option You may cancel your Dollar Cost Averaging program using whatever methods you use to change your allocation instructions. Dollar Cost Averaging Plus (DCA+) If available, offers a fixed interest rate that we guarantee for a period of up to one year in connection with systematic transfers from the DCA+ Fixed Account Option to one or more of the Investment Divisions or other Fixed Account Options. From time to time, we will offer special enhanced rates on the DCA+ Fixed Account Option. None • Restrictions may apply if we impose any transfer restrictions on the one-year Fixed Account Option. • The DCA+ Fixed Account Option is only available for new Premiums. • A Contract Value of $15,000 is required to participate. Earnings Sweep Allows you to choose to move your earnings from the source accounts (only applicable from the one-year Fixed Account Option, if currently available, and the JNL/WMC Government Money Market Investment Division). None • May only be added within 30 days of the issue date of your Contract. • You may cancel your Earnings Sweep program using whatever methods you use to change your allocation instructions. 18
We will pay the Contract's basic death benefit unless you have elected an add-on death benefit. If the Contract includes a guaranteed minimum death benefit, we will, according to the Contract's current allocation instructions on file, deposit into the Contract's Investment Divisions and Fixed Account the amount by which the guaranteed minimum death benefit exceeds the Contract's account value established at the close of business on the date we receive all documentation in Good Order from the first Beneficiary to submit a claim form. Basic Death Benefit. The basic death benefit is payable during the accumulation phase. The death benefit equals your Contract Value on the date we receive all required documentation from your Beneficiary. If you die before moving to the income phase, the person you have chosen as your Beneficiary will receive a death benefit. If you have a joint Owner, the death benefit will be paid when the first joint Owner dies. The surviving joint Owner will be
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CORRESP 1 filename1.htm EAIISECResponseMemo MEMORANDUM TO: Michael Rosenberg Attorney-Adviser Disclosure Review and Accounting Office Division of Investment Management U. S. Securities and Exchange Commission FROM: Alison Samborn, Esq. Associate General Counsel, Insurance Legal DATE: February 8, 2022 SUBJECT: Response to Comments for Post Effective Amendment No. 4 for File No. 333-235565 (Elite Access II); to the Registration Statement on Form N-4; Jackson National Separate Account - I (“Registrant”) of Jackson National Life Insurance Company (“Jackson”) This memorandum is in response to the comments you provided via telephone on January 10, 2021 for the above referenced filing. In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific comments, followed respectively by narrative responses (in bold). Excerpted pages of the Statutory Prospectus and the Rate Sheet for File No. 333-235565, 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. A post-effective amendment to the above-referenced registration statements will subsequently be filed in response to the comments. Corresponding changes will be made to the Initial Summary Prospectus and Updating Summary Prospectus, as applicable. Glossary (p. 1) 1.Consider defining GMDB since it applies to the EarningsMax benefit and the Return of Premium (“ROP”) Death Benefit. Response: Registrant currently does not include definitions for “GMDB” in any of its variable annuity product prospectuses, choosing instead to provide inline explanations as discussions of GMDBs arise throughout the prospectus. Adding this glossary term to the current product would make it inconsistent with all other product prospectuses. Registrant respectfully declines to make the suggested change at this time, but intends to do analysis of all products at an appropriate juncture to determine whether holistic changes are appropriate. Information You Should Consider About the Contract (p. 5) 2.Under the Optional Benefits row of the table, consider adding the following sentence: “Withdrawals may reduce the value of certain benefits by an amount greater than the value withdrawn.” Response: The above-referenced change has been made. (p. 1) Jackson® is the marketing name for Jackson National Life Insurance Company® (Home Office: Lansing, Michigan) and Jackson National Life Insurance Company of New York® (Home Office: Purchase, New York). Benefits Available Under the Contracts Table (p. 16) 3.Under the EarningsMax row, if accurate, please consider stating that the purpose of the death benefit is to help offset federal and state taxes payable upon death in the contract. Response: The above-referenced change has been made. The “Purpose” field for EarningsMax now reads: “Increases the amount of the death benefit payable at your death based on a percentage of Contract earnings, which may help offset state and federal taxes due at the time of your death.” (p. 2) 4.Under the EarningsMax row, in the “Maximum Fee” column, the parenthetical is different from the Liquidity rider parenthetical, but both use the same description in the fee table. For consistency, please use the same language or explain supplementally what the difference is. Response: The parenthenticals for both EarningsMax and the Liquidity Option have been revised as follows: “(as an annualized percentage of the average daily Contract Value in the Investment Divisions)” (pp. 2-3) 5.Under the ROP Death Benefit row, in the “Maximum Fee” column, add a parenthetical identifying that the maximum fee is a percentage of benefit base. Response: The above-referenced change has been made. (p. 2) 6.Under the ROP Death Benefit row, in the “Brief Description of Restrictions/Limitations” column, where it is stated that withdrawals may prematurely reduce the value, please state "significantly" and add that withdrawals may reduce the value of the benefit by more than the amount withdrawn. Response: The above-referenced change has been made. (p. 2) Death Benefit (p. 32) 7.In the EarningsMax section, if accurate, please consider stating that the purpose of the death benefit is to help offset federal and state taxes payable upon death in the contract. Response: The first sentence of the EarningsMax section has been revised as follows: “The Earnings Protection Benefit is an optional benefit that may increase the amount of the death benefit payable at your death, which may help offset state and federal taxes due upon your death.” (p. 4) 8.In the EarningsMax section, in the second to last paragraph starting with “Unlike the basic death benefit...” please provide more clarity as to how this operates. For example, if you have earnings, reach age 95 and annuitize, how does this benefit operate? Response: Registrant respectfully believes that this information is already covered in the preceding paragraphs which go into detail on the percentage of earnings that will be added to the death benefit amount at the time it becomes payable. The paragraph identified in this comment is intended solely to disclose that the benefit is only payable if the owner chooses to annuitize on the Latest Income Date as defined in the contract. No changes have been made. 9.In the ROP Death Benefit section, in the second to last paragraph starting with “Unlike the basic death benefit...” please provide more clarity as to how this operates. For example, if you have earnings, reach age 95 and annuitize, how does this benefit operate? Response: Registrant respectfully believes that this information is already covered in the preceding paragraphs which go into detail on the how this death benefit is calculated at the time it becomes payable. The paragraph identified in this comment is intended solely to disclose that the benefit is only payable if the owner chooses to annuitize on the Latest Income Date as defined in the contract. No changes have been made. 10.In the Spousal Continuation Option sub-section, consider editing the "if your spouse elects to continue the Contract, any GMDB will terminate" paragraph to state that this includes EarningsMax. Response: The above-referenced paragraph has been revised to more broadly capture all add-on death benefits as follows: “If your spouse elects to continue the Contract, any add-on death benefit will terminate upon the death of the Owner.” (p. 5) Rate Sheet 11.Please note that a change in current fees may also impact the dollar range for lowest and highest annual cost and consider including these in the rate sheet. Response: The following section has been added to the Rate Sheet Supplement immediately following the section identifying the current minimum and maximum annual fees: “The current lowest and highest annual cost estimates, as displayed in the “Ongoing Fees and Expenses (annual charges)” section of the table contained in the “IMPORTANT INFORMATION YOU SHOULD CONSIDER ABOUT THE CONTRACT” section of the prospectus are: LOWEST ANNUAL COST: $_____ HIGHEST ANNUAL COST: $_____ Assumes: •Investment of $100,000 •5% annual appreciation •Least expensive combination of Fund fees and expenses •No add-on benefits •No sales charges •No additional purchase payments, transfers or withdrawals Assumes: •Investment of $100,000 •5% annual appreciation •Most expensive combination of add-on benefits, Fund fees, and expenses •No sales charges •No additional purchase payments, transfers or withdrawals ” (pp. 6-7) Please contact me at (517) 331-4262 if you have any questions or require additional information. Jackson® is the marketing name for Jackson National Life Insurance Company® (Home Office: Lansing, Michigan) and Jackson National Life Insurance Company of New York® (Home Office: Purchase, New York). Optional Benefits • Not all add-on benefits are available through all broker-dealers and may vary by state or date of purchase. • We may modify or discontinue an add-on benefit at any time. • Withdrawals may reduce the value of certain benefits by an amount greater than the value withdrawn. Benefits Available Under the Contract TAXES Tax Implications • Consult with a tax professional to determine the tax implications of an investment in and purchase payments received under this Contract. • If you purchase the Contract through a tax-qualified plan or individual retirement account (IRA), you do not get any additional tax deferral. • Earnings on your Contract are taxed at ordinary income tax rates when you withdraw them, and you may have to pay a penalty if you take a withdrawal before age 59 ½. Taxes CONFLICTS OF INTEREST Investment Professional Compensation Your registered representative or other investment professionals may receive compensation for selling this Contract to you in the form of commissions, revenue sharing, and other compensation programs. Accordingly, investment professionals may have a financial incentive to offer or recommend this Contract over another investment. Distribution of Contracts Exchanges Some investment professionals may have a financial incentive to offer you a new contract in place of the one you own. You should only consider exchanging your contract if you determine, after comparing the features, fees, and risks of both contracts, that it is in your best interest to purchase the new contract rather than continue to own your existing contract. Non-Qualified Contracts - 1035 Exchanges. 5 Add-On Death Benefits Available for a Fee. NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS EarningsMax Increases the amount of the death benefit payable at your death based on a percentage of Contract earnings, which may help offset state and federal taxes due at the time of your death. Maximum: 0.70% (as an annualized percentage of daily account value of your allocations tothe average daily Contract Value in the Investment Divisions) • Available only at Contract issue. • The benefit cannot be terminated. • Available to owners age 75 or younger. • Subject to maximum benefit. • On each fifth Contract Anniversary, the Guaranteed Minimum Death Benefit (“GMDB”) charge may be increased. • No benefit will be paid if (i) there are no earnings in your contract, or (ii) your spouse exercises the Spousal Continuation Option. • The Fixed Account Options are not available if you elect EarningsMax. Return of Premium Guaranteed Minimum Death Benefit Changes your basic death benefit during the accumulation phase of your Contract to the greater of: (i) Contract Value as of the end of the Business Day on which we receive all required documentation from your Beneficiary; or (ii) all Premiums paid into the Contract (net of any applicable premium taxes and charges), reduced for withdrawals (including any applicable adjustments) in proportion to the reduction in the Contract Value at the time of the withdrawal. Maximum: 0.40% (as a percentage of benefit base) • Withdrawals may significantlyprematurely reduce the value of this Return of Premium Death Benefit. • Withdrawals may reduce the value of this benefit by more than the dollar amount of the withdrawal. • On each fifth Contract Anniversary, the GMDB charge may be increased. • Ownership changes are allowed, but Covered Lives cannot be changed. Add-On Living Benefits Available for a Fee. The current annual charges for the add-on benefits are disclosed in a Rate Sheet Prospectus Supplement. To obtain a copy, please visit www.jackson.com/product-literature-1.html. For a list of historical add-on benefit charges, please see “Appendix E (Historical Add- On Benefit Charges).” All add-on living benefits: • must be added on the Issue Date. • terminates when you annuitize. • cannot be cancelled by you (except upon spousal continuation). 17 NAME OF BENEFIT PURPOSE FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Liquidity Option If you elect this Option, you will not pay a withdrawal charge when you make a partial or full withdrawal. This option removes the five year withdrawal charge schedule that would otherwise apply. Best if you anticipate taking or needing to take a large withdrawal that would otherwise be subject to charges under the five year withdrawal charge schedule imposed on each Premium payment. 0.25% on (as an annual basisannualized percentage of the average daily Contract Value in the Investment DivisionsDivision s) • Charges are deducted daily as part of the calculation of the value of the Accumulation Units. • The Capital Protection Program is not available on Contracts with the Liquidity Option. Other Add-On Benefits Included With All Contracts At No Additional Cost. NAME OF BENEFIT PURPOSE FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Rebalancing Automatically reallocates your Contract Value among Investment Divisions and the one-year Fixed Account Option (if currently available) periodically to maintain your selected allocation percentages. None • Rebalancing will terminate if your rebalancing program includes the one-year Fixed Account Option and we impose any transfer restrictions or requirements on the one- year Fixed Account Option. Dollar Cost Averaging Automatically transfers a dollar amount or percentage of money periodically from the one-year Fixed Account Option or any of the Investment Divisions into the Investment Divisions and other Fixed Account Options. None • Restrictions may apply if we impose any transfer restrictions on the one-year Fixed Account Option You may cancel your Dollar Cost Averaging program using whatever methods you use to change your allocation instructions. Dollar Cost Averaging Plus (DCA+) If available, offers a fixed interest rate that we guarantee for a period of up to one year in connection with systematic transfers from the DCA+ Fixed Account Option to one or more of the Investment Divisions or other Fixed Account Options. From time to time, we will offer special enhanced rates on the DCA+ Fixed Account Option. None • Restrictions may apply if we impose any transfer restrictions on the one-year Fixed Account Option. • The DCA+ Fixed Account Option is only available for new Premiums. • A Contract Value of $15,000 is required to participate. Earnings Sweep Allows you to choose to move your earnings from the source accounts (only applicable from the one-year Fixed Account Option, if currently available, and the JNL/WMC Government Money Market Investment Division). None • May only be added within 30 days of the issue date of your Contract. • You may cancel your Earnings Sweep program using whatever methods you use to change your allocation instructions. 18 We will pay the Contract's basic death benefit unless you have elected an add-on death benefit. If the Contract includes a guaranteed minimum death benefit, we will, according to the Contract's current allocation instructions on file, deposit into the Contract's Investment Divisions and Fixed Account the amount by which the guaranteed minimum death benefit exceeds the Contract's account value established at the close of business on the date we receive all documentation in Good Order from the first Beneficiary to submit a claim form. Basic Death Benefit. The basic death benefit is payable during the accumulation phase. The death benefit equals your Contract Value on the date we receive all required documentation from your Beneficiary. If you die before moving to the income phase, the person you have chosen as your Beneficiary will receive a death benefit. If you have a joint Owner, the death benefit will be paid when the first joint Owner dies. The surviving joint Owner will be