SEC Company Response from JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730) — Aug 29, 2022
JACKSON NATIONAL SEPARATE ACCOUNT - I (CIK 0000927730)
Date: Aug. 29, 2022 · CIK: 0000927730 · Accession: 0000927730-22-000446
AI Filing Summary & Sentiment
File numbers found in text: 333-217500, 333-226897, 333-252333
Letter
affcsecresponsecombined
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: August 29, 2022
SUBJECT: Response to Comments for Post-Effective Amendments to Registration Statements filed on Form N-4 for File No. 333-252333 (Jackson Retirement Investment Annuity); Jackson National Separate Account - I of Jackson National Life Insurance Company; File No. 333-226897 (Elite Access Advisory II); Jackson National Separate Account - I of Jackson National Life Insurance Company; and File No. 333-217500 (Perspective Advisory II); Jackson National Separate Account - I of Jackson National Life Insurance Company
This memorandum is in response to the comments you provided via telephone on August 22, 2022 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 comments, followed respectively by narrative responses (in bold).
The following comments and responses apply to all post-effective amendments referenced above. Excerpted pages of the Statutory Prospectus for File No. 333-252333, marked to show the change 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 supplements for File Nos. 333-226897 and 333-217500, as applicable.
General Comments on Contracts with the Advisory Fee From Contract Feature
1.For contract owners that take direct deduction of advisory fees from the contract prior to the effective date of this amendment, will they be automatically enrolled in the add-on benefit advisory fee withdrawal program? If not, please retain the prior disclosures about tax consequences of the deduction of advisory fees.
Response: The above-referenced disclosures regarding the tax consequences of the deduction of advisory fees were removed in response to a careful review of our existing administrative procedures and Private Letter Ruling (“PLR”) on advisory fee withdrawals. Removal of the disclosures was not related to the addition of the new Add-On Benefit Advisory Fee Withdrawal Program.
Registrant respectfully believes the prior disclosures were unnecessarily broad based on our administrative practices under our PLR. Corresponding updates have been made to the Tax section of the prospectus explicitly spelling out the terms of Jackson’s PLR, which correspond to our administrative rules for advisory fee withdrawals. The administrative rules are disclosed throughout relevant sections of the prospectus relating to advisory fee withdrawals. To the extent Jackson’s administrative rules are followed, the deduction of advisory fees will not be treated as a taxable distribution. As such, Registrant respectfully declines to retain the prior disclosures about the tax consequences of the deduction of advisory fees.
2.In the section titled “Principal Risks”, subsection titled “Deduction of Advisory Fees from Contract Value”, please add disclosure that deduction of advisory fees from contract value may also potentially reduce the Return of Premium death benefit and the amount of GMWB step-ups.
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).
Response: The following disclosure has been added following the third sentence of the above-referenced subsection:
“Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium add-on death benefit, which is equal to the greater of Contract Value or Premiums paid into your Contract (net of any applicable premium taxes and charges), reduced for withdrawals. Deductions to pay advisory fees may also reduce the step-ups available under the Jackson +Protect add-on benefit.” (p. 1)
In addition, the following disclosure was revised in the “Death Benefit” section of the prospectus, under the sub-subsection titled “Return of Premium Guaranteed Minimum Death Benefit” to clarify only the return of premium portion of the benefit base is protected from advisory fee withdrawals (italics added to identify revision):
“The direct deduction of advisory fees from Contract Value, made pursuant to our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program), are not considered withdrawals as described in your Return of Premium GMDB add-on benefit, and will not impact the Return of Premium portion of your GMDB Benefit Base. The payment of advisory fees from Contract Value, even pursuant to our rules, will always reduce Contract Value and the basic death benefit. For more information about the deduction of advisory fees from Contract Value, please see “Add- On Benefit Advisory Fee Withdrawal Program” beginning on page 38.” (p. 5)
In addition, the following disclosure was added to the “Jackson +Protect GMWB” subsection of the “Access to your Money” section of the prospectus, under the sub-subsection titled “Step-up”:
“PLEASE NOTE: The deduction of advisory fees pursuant to our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program) will always reduce Contract Value, and subsequently will reduce the value of step-ups under this add-on benefit.” (p. 4)
3.In the section titled “Benefits Available Under the Contracts”, in the column titled “Brief Description of Restrictions/Limitations” for the Return of Premium Guaranteed Minimum Death Benefit, you indicate that the deduction of advisory fees from Contract Value will not reduce the value of the Return of Premium death benefit. The staff feels this is not entirely accurate since the Return of Premium death benefit is the greater of Contract Value or Premiums, and the direct deduction of advisory fees will reduce Contract Value. Please revise accordingly.
Response: The above-referenced disclosure in the “Brief Description of Restrictions/Limitations” column for the Return of Premium Guaranteed Minimum Death Benefit has been revised as follows:
•“The deduction of advisory fees from Contract Value under the Add-On Benefit Advisory Fee Withdrawal Program will be capped at 1.25% of Contract Value annually.
•Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium Death Benefit, which is equal to the greater of Contract Value or Premiums paid.” (p. 2)
4.In the subsection titled “Transaction Expenses”, sub-subsection titled “Advisory Fees”, under the sub-sub-subsection titled “Our Administrative Rules”, you indicate that advisory fees may not exceed an amount equal to an annual rate of 1.5%, but elsewhere you indicate that the fees may not exceed an amount equal to an annual rate of 1.25%. Please reconcile. This comment applies throughout the prospectus to disclosures regarding the annual limit.
Response: Under our standard administrative rules relating to advisory fee withdrawals, pursuant to our PLR, where no add-on benefits have been elected, we do not permit the deduction of advisory fees to exceed an annual rate of 1.5% of the Contract’s cash value. Under our new Add-On Benefit Advisory Fee Withdrawal Program, which is designed to permit advisory fee withdrawals while protecting certain
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).
eligible add-on benefits, we cap advisory fee withdrawals at a lower annual rate of 1.25% of Contract Value. The above-referenced sub-subsection has been revised as follows to clarify this concept in the second sentence of the “Add-On Benefit Advisory Fee Withdrawal Program” sub-sub-subsection:
“Under this program, advisory fee deductions are capped at a lower annual rate than under our standard administrative rules, and will not be permitted to exceed an annual amount equal to an annual rate of 1.25% of Contract Value.” (p. 3)
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).
Risks Affecting our Administration of Your Contract. We and our service providers and business partners are subject to certain risks, including those resulting from system failures, cybersecurity events, the coronavirus (COVID-19) pandemic and other pandemics and epidemics, and other disasters. Such events can adversely impact us and our operations. These risks are common to all insurers and financial service providers and may materially impact our ability to administer the Contract (and to keep Contract owner information confidential). Add-On Benefits. You may never need or use certain features provided by the Contract. In that case, you may pay for a feature for which you never realize any benefits. Certain benefits are subject to conditions including waiting periods. You may die before you are able to access certain benefits under the Contract. Alternatively, you may not live long enough to receive enough benefit from the add-on benefits to exceed the amount of the fees you pay for those benefits. You may need to make early or excess withdrawals, which have the potential to substantially reduce or even terminate the benefits available under the Contract from the add-on benefits. The Investment Divisions may perform well enough that you may not need the guarantee that may otherwise be provided by the Contract or by one of the Contract’s add-on benefits available for an additional charge. Certain benefits may limit withdrawals or other rights under the Contract. If your Contract includes one of the add-on benefits, withdrawals will reduce the value of the benefits in proportion to the amount of the withdrawal relative to the total Contract Value at the time of withdrawal. Accordingly, under certain circumstances, a withdrawal could reduce the value of a benefit by more than the dollar amount of the withdrawal. Conditions to Contract Benefits. Certain benefits under the Contract are contingent on several conditions being met. If those conditions are not met, you may not realize a benefit from the Contract or add-on benefit for which you have been charged a fee. Alternatives to the Contract. Other contracts or investments may provide more favorable returns or benefits than the Contract. Potentially Harmful Transfer Activity. The Contract is not designed for frequent transfers by anyone. Frequent transfers between and among Investment Divisions may disrupt the underlying Funds and could negatively impact performance, by interfering with efficient management and reducing long-term returns, and increasing administrative costs. Frequent transfers may also dilute the value of shares of an underlying Fund. Neither the Contracts nor the underlying Funds are meant to promote any active trading strategy, like market timing. Allowing frequent transfers by one or some Owners could be at the expense of other Owners of the Contract. To protect Owners and the underlying Funds, we have policies and procedures to deter frequent transfers between and among the Investment Divisions. (See “Transfers and Frequent Transfer Restrictions—Restrictions on Transfers: Market Timing” for more information.) We cannot guarantee that these policies and procedures will be effective in detecting and preventing all transfer activity that could potentially disadvantage or hurt the rights or interests of other Owners. Fixed Account Option Rates. The rates we declare for the Fixed Account Options may be lower than you would find acceptable. Deduction of Advisory Fees from Contract Value. Under certain circumstances, you may elect to have advisory fees directly deducted from your Contract Value and automatically transmitted to your third party financial professional, subject to certain administrative rules. If you do elect to pay your advisory fees via direct deductions under our rules, we will not treat such deductions as withdrawals in two specific ways: (i) we will not report them as taxable distributions under your Contract; and (ii) any such deduction will not trigger a reduction in the value of any eligible add-on benefit you elected. It is important to note that deductions to pay advisory fees will always reduce the basic death benefit and your Contract Value, and they are otherwise subject to all contractual provisions and other restrictions and penalties, including minimum withdrawal requirements and Market Value Adjustments. Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium add-on death benefit, which is equal to the greater of Contract Value or Premiums paid into your Contract (net of any applicable premium taxes and charges), reduced for withdrawals. Deductions to pay advisory fees may also reduce the step-ups available under the Jackson +Protect add-on benefit. Advisory fees are in addition to Contract fees and expenses disclosed in this prospectus. This means if you take withdrawals to pay advisory fees and do not follow our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program) and/or elect an ineligible add-on benefit, all such withdrawals will be subject to any applicable income taxes and penalties and will reduce your add-on benefit(s). BENEFITS AVAILABLE UNDER THE CONTRACTS The following tables summarize information about the benefits available under the Contract. 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-3.html. For a list of historical add-on benefit charges, please see “Appendix F (Historical Add-On Benefit Charges).” 15
Basic Death Benefit (automatically included with the Contract) NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Basic Death Benefit Guarantees your beneficiaries will receive a benefit of at least your Contract Value on the date Jackson receives all required documentation from your Beneficiary. No additional charge • Withdrawals could significantly reduce the benefit. • Payment of advisory fees via direct deduction from Contract Value could significantly reduce the benefit. • Benefit terminates on annuitization. Add-On Death Benefits Available for a Fee NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS 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 significantly 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. • The deduction of advisory fees from Contr
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CORRESP 1 filename1.htm affcsecresponsecombined 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: August 29, 2022 SUBJECT: Response to Comments for Post-Effective Amendments to Registration Statements filed on Form N-4 for File No. 333-252333 (Jackson Retirement Investment Annuity); Jackson National Separate Account - I of Jackson National Life Insurance Company; File No. 333-226897 (Elite Access Advisory II); Jackson National Separate Account - I of Jackson National Life Insurance Company; and File No. 333-217500 (Perspective Advisory II); Jackson National Separate Account - I of Jackson National Life Insurance Company This memorandum is in response to the comments you provided via telephone on August 22, 2022 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 comments, followed respectively by narrative responses (in bold). The following comments and responses apply to all post-effective amendments referenced above. Excerpted pages of the Statutory Prospectus for File No. 333-252333, marked to show the change 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 supplements for File Nos. 333-226897 and 333-217500, as applicable. General Comments on Contracts with the Advisory Fee From Contract Feature 1.For contract owners that take direct deduction of advisory fees from the contract prior to the effective date of this amendment, will they be automatically enrolled in the add-on benefit advisory fee withdrawal program? If not, please retain the prior disclosures about tax consequences of the deduction of advisory fees. Response: The above-referenced disclosures regarding the tax consequences of the deduction of advisory fees were removed in response to a careful review of our existing administrative procedures and Private Letter Ruling (“PLR”) on advisory fee withdrawals. Removal of the disclosures was not related to the addition of the new Add-On Benefit Advisory Fee Withdrawal Program. Registrant respectfully believes the prior disclosures were unnecessarily broad based on our administrative practices under our PLR. Corresponding updates have been made to the Tax section of the prospectus explicitly spelling out the terms of Jackson’s PLR, which correspond to our administrative rules for advisory fee withdrawals. The administrative rules are disclosed throughout relevant sections of the prospectus relating to advisory fee withdrawals. To the extent Jackson’s administrative rules are followed, the deduction of advisory fees will not be treated as a taxable distribution. As such, Registrant respectfully declines to retain the prior disclosures about the tax consequences of the deduction of advisory fees. 2.In the section titled “Principal Risks”, subsection titled “Deduction of Advisory Fees from Contract Value”, please add disclosure that deduction of advisory fees from contract value may also potentially reduce the Return of Premium death benefit and the amount of GMWB step-ups. 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). Response: The following disclosure has been added following the third sentence of the above-referenced subsection: “Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium add-on death benefit, which is equal to the greater of Contract Value or Premiums paid into your Contract (net of any applicable premium taxes and charges), reduced for withdrawals. Deductions to pay advisory fees may also reduce the step-ups available under the Jackson +Protect add-on benefit.” (p. 1) In addition, the following disclosure was revised in the “Death Benefit” section of the prospectus, under the sub-subsection titled “Return of Premium Guaranteed Minimum Death Benefit” to clarify only the return of premium portion of the benefit base is protected from advisory fee withdrawals (italics added to identify revision): “The direct deduction of advisory fees from Contract Value, made pursuant to our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program), are not considered withdrawals as described in your Return of Premium GMDB add-on benefit, and will not impact the Return of Premium portion of your GMDB Benefit Base. The payment of advisory fees from Contract Value, even pursuant to our rules, will always reduce Contract Value and the basic death benefit. For more information about the deduction of advisory fees from Contract Value, please see “Add- On Benefit Advisory Fee Withdrawal Program” beginning on page 38.” (p. 5) In addition, the following disclosure was added to the “Jackson +Protect GMWB” subsection of the “Access to your Money” section of the prospectus, under the sub-subsection titled “Step-up”: “PLEASE NOTE: The deduction of advisory fees pursuant to our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program) will always reduce Contract Value, and subsequently will reduce the value of step-ups under this add-on benefit.” (p. 4) 3.In the section titled “Benefits Available Under the Contracts”, in the column titled “Brief Description of Restrictions/Limitations” for the Return of Premium Guaranteed Minimum Death Benefit, you indicate that the deduction of advisory fees from Contract Value will not reduce the value of the Return of Premium death benefit. The staff feels this is not entirely accurate since the Return of Premium death benefit is the greater of Contract Value or Premiums, and the direct deduction of advisory fees will reduce Contract Value. Please revise accordingly. Response: The above-referenced disclosure in the “Brief Description of Restrictions/Limitations” column for the Return of Premium Guaranteed Minimum Death Benefit has been revised as follows: •“The deduction of advisory fees from Contract Value under the Add-On Benefit Advisory Fee Withdrawal Program will be capped at 1.25% of Contract Value annually. •Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium Death Benefit, which is equal to the greater of Contract Value or Premiums paid.” (p. 2) 4.In the subsection titled “Transaction Expenses”, sub-subsection titled “Advisory Fees”, under the sub-sub-subsection titled “Our Administrative Rules”, you indicate that advisory fees may not exceed an amount equal to an annual rate of 1.5%, but elsewhere you indicate that the fees may not exceed an amount equal to an annual rate of 1.25%. Please reconcile. This comment applies throughout the prospectus to disclosures regarding the annual limit. Response: Under our standard administrative rules relating to advisory fee withdrawals, pursuant to our PLR, where no add-on benefits have been elected, we do not permit the deduction of advisory fees to exceed an annual rate of 1.5% of the Contract’s cash value. Under our new Add-On Benefit Advisory Fee Withdrawal Program, which is designed to permit advisory fee withdrawals while protecting certain 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). eligible add-on benefits, we cap advisory fee withdrawals at a lower annual rate of 1.25% of Contract Value. The above-referenced sub-subsection has been revised as follows to clarify this concept in the second sentence of the “Add-On Benefit Advisory Fee Withdrawal Program” sub-sub-subsection: “Under this program, advisory fee deductions are capped at a lower annual rate than under our standard administrative rules, and will not be permitted to exceed an annual amount equal to an annual rate of 1.25% of Contract Value.” (p. 3) 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). Risks Affecting our Administration of Your Contract. We and our service providers and business partners are subject to certain risks, including those resulting from system failures, cybersecurity events, the coronavirus (COVID-19) pandemic and other pandemics and epidemics, and other disasters. Such events can adversely impact us and our operations. These risks are common to all insurers and financial service providers and may materially impact our ability to administer the Contract (and to keep Contract owner information confidential). Add-On Benefits. You may never need or use certain features provided by the Contract. In that case, you may pay for a feature for which you never realize any benefits. Certain benefits are subject to conditions including waiting periods. You may die before you are able to access certain benefits under the Contract. Alternatively, you may not live long enough to receive enough benefit from the add-on benefits to exceed the amount of the fees you pay for those benefits. You may need to make early or excess withdrawals, which have the potential to substantially reduce or even terminate the benefits available under the Contract from the add-on benefits. The Investment Divisions may perform well enough that you may not need the guarantee that may otherwise be provided by the Contract or by one of the Contract’s add-on benefits available for an additional charge. Certain benefits may limit withdrawals or other rights under the Contract. If your Contract includes one of the add-on benefits, withdrawals will reduce the value of the benefits in proportion to the amount of the withdrawal relative to the total Contract Value at the time of withdrawal. Accordingly, under certain circumstances, a withdrawal could reduce the value of a benefit by more than the dollar amount of the withdrawal. Conditions to Contract Benefits. Certain benefits under the Contract are contingent on several conditions being met. If those conditions are not met, you may not realize a benefit from the Contract or add-on benefit for which you have been charged a fee. Alternatives to the Contract. Other contracts or investments may provide more favorable returns or benefits than the Contract. Potentially Harmful Transfer Activity. The Contract is not designed for frequent transfers by anyone. Frequent transfers between and among Investment Divisions may disrupt the underlying Funds and could negatively impact performance, by interfering with efficient management and reducing long-term returns, and increasing administrative costs. Frequent transfers may also dilute the value of shares of an underlying Fund. Neither the Contracts nor the underlying Funds are meant to promote any active trading strategy, like market timing. Allowing frequent transfers by one or some Owners could be at the expense of other Owners of the Contract. To protect Owners and the underlying Funds, we have policies and procedures to deter frequent transfers between and among the Investment Divisions. (See “Transfers and Frequent Transfer Restrictions—Restrictions on Transfers: Market Timing” for more information.) We cannot guarantee that these policies and procedures will be effective in detecting and preventing all transfer activity that could potentially disadvantage or hurt the rights or interests of other Owners. Fixed Account Option Rates. The rates we declare for the Fixed Account Options may be lower than you would find acceptable. Deduction of Advisory Fees from Contract Value. Under certain circumstances, you may elect to have advisory fees directly deducted from your Contract Value and automatically transmitted to your third party financial professional, subject to certain administrative rules. If you do elect to pay your advisory fees via direct deductions under our rules, we will not treat such deductions as withdrawals in two specific ways: (i) we will not report them as taxable distributions under your Contract; and (ii) any such deduction will not trigger a reduction in the value of any eligible add-on benefit you elected. It is important to note that deductions to pay advisory fees will always reduce the basic death benefit and your Contract Value, and they are otherwise subject to all contractual provisions and other restrictions and penalties, including minimum withdrawal requirements and Market Value Adjustments. Because deductions to pay advisory fees reduce your Contract Value, they may also negatively impact your Return of Premium add-on death benefit, which is equal to the greater of Contract Value or Premiums paid into your Contract (net of any applicable premium taxes and charges), reduced for withdrawals. Deductions to pay advisory fees may also reduce the step-ups available under the Jackson +Protect add-on benefit. Advisory fees are in addition to Contract fees and expenses disclosed in this prospectus. This means if you take withdrawals to pay advisory fees and do not follow our administrative rules (including the Add-On Benefit Advisory Fee Withdrawal Program) and/or elect an ineligible add-on benefit, all such withdrawals will be subject to any applicable income taxes and penalties and will reduce your add-on benefit(s). BENEFITS AVAILABLE UNDER THE CONTRACTS The following tables summarize information about the benefits available under the Contract. 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-3.html. For a list of historical add-on benefit charges, please see “Appendix F (Historical Add-On Benefit Charges).” 15 Basic Death Benefit (automatically included with the Contract) NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS Basic Death Benefit Guarantees your beneficiaries will receive a benefit of at least your Contract Value on the date Jackson receives all required documentation from your Beneficiary. No additional charge • Withdrawals could significantly reduce the benefit. • Payment of advisory fees via direct deduction from Contract Value could significantly reduce the benefit. • Benefit terminates on annuitization. Add-On Death Benefits Available for a Fee NAME OF BENEFIT PURPOSE MAXIMUM FEE BRIEF DESCRIPTION OF RESTRICTIONS/LIMITATIONS 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 significantly 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. • The deduction of advisory fees from Contr