Correspondence 0000931788-24-000014 from JACKSON NATIONAL LIFE INSURANCE CO (CIK 0000931788)
JACKSON NATIONAL LIFE INSURANCE CO (CIK 0000931788)
Date: Feb. 29, 2024 · CIK: 0000931788 · Accession: 0000931788-24-000014
AI Filing Summary & Sentiment
File numbers found in text: 333-268090
Letter
responseMemoCombined
MEMORANDUM
TO: Sonny Oh
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
U. S. Securities and Exchange Commission
FROM: Alison Samborn, Esq.
Assistant Vice President, Insurance Legal & Product Development
DATE: February 29, 2024
SUBJECT: Response to Comments for Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 for File No. 333-268090 (Jackson Market Link Pro II)
This memorandum is in response to the comments you provided via telephone on January 31, 2024 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 the post-effective amendment filing referenced above. Excerpted pages of the prospectus, marked to show the changes discussed below, are attached and will be provided electronically. Page references in the responses are to the PDF page of the attached marked copy of the document. A post-effective amendment to the above-referenced registration statement will subsequently be filed in response to the comments.
Cover (p. 1)
1.In the first sentence of the third paragraph, where you reference “add-on Guaranteed Minimum Withdrawal Benefits (“GMWB”) that we currently offer under the Contract”, please consider using “optional” rather than “add-on” when referring to the Guaranteed Minimum Withdrawal Benefits.
Response: The use of “add-on” rather than “optional” in connection with our riders is intentional. Registrant has updated its terminology to provide language that is easier for investors to understand, based on a language study conducted several years ago. This terminology is consistent throughout all of our registered product prospectuses and contracts, and would require extensive amendments to both in order to move away from the “add-on” terminology. As such, no revision has been made in response this comment.
2.In the first sentence of the third paragraph, where you reference “add-on Guaranteed Minimum Withdrawal Benefits (“GMWB”), please note that here, you use “GMWB” but throughout the prospectus, you reference this rider by multiple different names/defined terms. Please use one name for the rider and apply one defined term for the rider consistently throughout the prospectus. You may distinguish in the name and defined term whether it’s a single or two life version. See page 4, in the Summary subsection titled Guaranteed Minimum Withdrawal Benefit for an example of the staff’s preferred use of terminology.
Response: We have revised consistent with both a defined term that describes Guaranteed Minimum Withdrawal Benefits generally, as well as identified shortened naming conventions (the intended marketing names) for the +Income GMWB. We believe that both general references to GMWBs and their risks, as well as more focused language describing the GMWB currently offered under the contract are appropriate and necessary to investor understanding, and would like to retain both concepts. Revisions have been made throughout the prospectus to better align references for clarity.
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).
3.Please include contact information for Jackson’s Customer Care Center on the cover page as there are several cross-references throughout the prospectus directing the investor to the contact information on the cover page. Alternatively, please provide this contact information elsewhere in the prospectus and update the cross-references accordingly.
Response: We have made this revision.
Table of Contents
4.Please ensure that when submitting the prospectus via the EDGAR system that the Table of Contents is hyperlinked to the corresponding section and subsection pages for ease of review.
Response: The prospectus submitted via EDGAR will be hyperlinked, as requested.
Summary (pp. 2-7)
5.In the last sentence of the second paragraph, you reference “Annual Step-Ups.” Please consider adding this term to the glossary.
Response: We have made this revision.
6.In the the first paragraph of the subsection titled “Interim Value Adjustment”, you include a parenthetical describing the types of withdrawals to which an interim value adjustment applies, If the intent is to provide a complete list of withdrawal types, please consider adding automatic withdrawals to make the disclosure complete. In addition, please clarify whether interim value adjustments include withdrawal charges/fees.
Response: We have made this revision.
7.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, please review and break this subsection into shorter and simpler disclosure. Consider using bullets to make the information easier for an investor to understand.
Response: We have made this revision.
8.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, and throughout the prospectus, you use the following parenthetical when describing the GAWA: “(which will never be less than your Required Minimum Distribution (“RMD”), if applicable)” or similar variations of this parenthetical. Please consider whether providing an explanation that if RMDs apply, and the RMD is greater than the GAWA, you get the RMD, would be clearer for an investor than the repeated parenthetical.
Response: We have made revisions throughout the prospectus for clarity.
9.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, please move the description of the For Life Guarantee further down in the subsection.
Response: We have made this revision.
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).
10.The following comments address the Contract Overview table:
a.In the last sentence of the “Access to Your Money” row, please update to include disclosure that Withdrawal Charges may apply to Excess Withdrawals under the rider.
Response: We have made this revision.
b.In the “Add-On Guaranteed Minimum Withdrawal Benefit” row, please review and revise row into shorter and simpler disclosure, consistent with Comment 7.
Response: We have made this revision.
c.In the “Add-On Guaranteed Minimum Withdrawal Benefit” row, in the sentence beginning “The longer withdrawals are deferred (up to 9 years)...”, please check to ensure this disclosure, as well as similar disclosures throughout the prospectus, is consistent with a 9+ year option if included at launch.
Response: GAWA% hit their highest level and can no longer increase once the Deferral Year 9 has been reached, as such, we believe the existing disclosures are accurate. No revision has been made in response to this comment.
d.In the “Charges and Expenses” row, please revise consistent with Comment 6.
Response: We have made this revision.
Risk Factors (pp. 12-14)
11.The following comments address the subsection titled “Add-On Benefit”:
a.Please identify that the rider cannot be terminated by the contract owner independently from the contract.
Response: We have made this revision.
b. Please ensure terminology referencing the rider is consistent with Comment 2,
Response: We have made this revision.
c. In the second paragraph, where you reference waiting periods, please consider whether this should instead reference deferral periods/years.
Response: We have made this revision.
d. In the fourth paragraph, please consider whether the reference to Excess Withdrawals reducing the value of the “benefit” should be revised to Excess Withdrawals reducing the value of the “GWB” to provide more specificity and clarity to the investor.
Response: We have made this revision.
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).
e. Please include a description of the risk associated with not taking required RMD withdrawals and provide a cross-reference to any relevant tax or other RMD disclosures.
Response: We have made this revision.
12.The following comments address the subsection titled “Effects of Withdrawals, Annuitization, or Death”:
a.Please ensure terminology referencing withdrawals of the GAWA are consistent. In this subsection, you reference “GAWA withdrawals” while in the Summary section of the prospectus, you phrase this as “withdrawals of the GAWA.”
Response: We have made this revision.
b.In the last two sentences of the first paragraph, please revise to include disclosure about withdrawals of amounts in excess of the Free Withdrawal as you do in the Summary section of the prospectus.
Response: We have made this revision.
c.In the last sentence of the subsection, you note “[i]f your Contract Value falls below the minimum Contract Value remaining as a result of a withdrawal (as stated in your Contract), we may terminate your Contract.” Please confirm whether this termination trigger applies when the rider is elected and what type of withdrawal would trigger this termination.
Response: We have made this revision.
Glossary (pp. 8-11)
13.Consider reformatting so that the glossary appears immediately before or after the Summary for ease of review, particularly if an investor is reviewing in hard copy.
Response: We have made this revision.
14.Consider adding a defined term for GMWB with Joint Option.
Response: We have made significant revision to the references to GMWB, +Income GMWB, and +Income GMWB with Joint Option, and believe no additional defined term is required.
15.The following terms in the Glossary should be revised as indicated:
a.Covered Life - Please consider clarifying that the Covered Life only applies to the joint life GMWB. In addition, consider clarifying who the the Covered Lives are (i.e. Are they the measuring lives? Are they the lives who get the benefit of the rider?).
Response: We have made this revision.
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).
b.Deferral Year - Please consider adding disclosure that Deferral Years are capped at 9 years.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, no revision has been made to the Glossary definition for Deferral Year.
c.Designated Life - In the first sentence, instead of saying “the life on which certain add-on Guaranteed Minimum Withdrawal Benefit (“GMWB”) values are based,” consider revising to “the life on which the GAWA% for the GMWB is based” to add more specificity.
Response: Consistent with revisions to simplify Glossary definitions and provided detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
d.Determination Date - Please include disclosure explaining when the Determination Date is locked-in. For reference, in Appendix D, Example 2, there is an extensive list of what triggers the Determination Date and the GAWA% to be determined and locked-in.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
e.For Life Guarantee - Consider adding an explanation on when this guarantee is triggered and when and under what circumstances it terminates. In addition, please consider simply saying “Owner or Annuitant” instead of Designated Life.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
f.Guaranteed Annual Withdrawal Amount ("GAWA") - In the first sentence of the definition, consider simply referring to the “GWB” instead of “guaranteed annual level of income.” In the last sentence, consider identifying that the increase or decrease to the GAWA is based on Annual Step-Ups or Excess Withdrawals.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
g.Withdrawal Value - Consider revising the last sentence to read “...less any applicable Withdrawal Charge or rider charge.”
Response: We have made this revision.
Contract Options (pp. 17-20)
16.In the first paragraph of the subsection titled “Interim Value”, please update the disclosures consistently with Comment 6 to include reference to automatic withdrawals, and a statement identifying that withdrawal charges will be assessed in addition to the Interim Value adjustment.
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: We have made this revision.
Access To Your Money (pp. 28-29)
17.The following comments address the subsection titled “Guaranteed Minimum Withdrawal Benefit Considerations”:
a.Please bold the first sentence of the third paragraph.
Response: We have made this revision.
b. In the fourth paragraph, please note the inconsistent references to “Joint For Life GMWB” and revise consistently with defined terms. In addition, if there is an opportunity to make a distinction between the Joint Life option only being available to spouses while the Single Life option is available to spouses and unrelated parties earlier in the prospectus, please do so.
Response: We have made this revision.
+Income For Life Guaranteed Minimum Withdrawal Benefit (pp. 29-40)
18.Please move the subsection titled “+Income For Life Guaranteed Minimum Withdrawal Benefit with Annual Step-Up for a Single Life or Two Covered Lives (“+Income GMWB” and “+Income GMWB with Joint Option”)” to the beginning of the Access to Your Money section of the prospectus, and make the “Guaranteed Minimum Withdrawal Benefit Considerations” subsection a child subsection lower in the section.
Response: We have made this revision.
19.In the parenthetical within the subsection title “+Income For Life Guaranteed Minimum Withdrawal Benefit with Annual Step-Up for a Single Life or Two Covered Lives (“+Income GMWB” and “+Income GMWB with Joint Option”)”, please add the word “respectively” after +Income GMWB with Joint Option.
Response: We have made a slightly different revision to address this comment, breaking the parenthetical into two parentheticals immediately following each version of the benefit in the subsection title.
20.Please reconcile the disclosure in the second sentence of the second paragraph of the section with the definition of “Covered Life” glossary (e.g. to include qualified custodial accounts).
Response: We have made this revision.
21.In the last paragraph of this section immediately preceding the tables, please consider using the term “annuitization” instead of Income Date.
Response: The use of “Income Date” rather than “annuitization” is intentional. Registrant has updated its terminology to provide language that is easier for investors to understand, based on a language study conducted several years ago. This terminology is consistent throughout all of our registered product prospectuses and contracts, and would require extensive amendments to both in
Jackson® is the marketing name for Jackson National Life Ins
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filename1.htm
responseMemoCombined
MEMORANDUM
TO: Sonny Oh
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
U. S. Securities and Exchange Commission
FROM: Alison Samborn, Esq.
Assistant Vice President, Insurance Legal & Product Development
DATE: February 29, 2024
SUBJECT: Response to Comments for Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 for File No. 333-268090 (Jackson Market Link Pro II)
This memorandum is in response to the comments you provided via telephone on January 31, 2024 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 the post-effective amendment filing referenced above. Excerpted pages of the prospectus, marked to show the changes discussed below, are attached and will be provided electronically. Page references in the responses are to the PDF page of the attached marked copy of the document. A post-effective amendment to the above-referenced registration statement will subsequently be filed in response to the comments.
Cover (p. 1)
1.In the first sentence of the third paragraph, where you reference “add-on Guaranteed Minimum Withdrawal Benefits (“GMWB”) that we currently offer under the Contract”, please consider using “optional” rather than “add-on” when referring to the Guaranteed Minimum Withdrawal Benefits.
Response: The use of “add-on” rather than “optional” in connection with our riders is intentional. Registrant has updated its terminology to provide language that is easier for investors to understand, based on a language study conducted several years ago. This terminology is consistent throughout all of our registered product prospectuses and contracts, and would require extensive amendments to both in order to move away from the “add-on” terminology. As such, no revision has been made in response this comment.
2.In the first sentence of the third paragraph, where you reference “add-on Guaranteed Minimum Withdrawal Benefits (“GMWB”), please note that here, you use “GMWB” but throughout the prospectus, you reference this rider by multiple different names/defined terms. Please use one name for the rider and apply one defined term for the rider consistently throughout the prospectus. You may distinguish in the name and defined term whether it’s a single or two life version. See page 4, in the Summary subsection titled Guaranteed Minimum Withdrawal Benefit for an example of the staff’s preferred use of terminology.
Response: We have revised consistent with both a defined term that describes Guaranteed Minimum Withdrawal Benefits generally, as well as identified shortened naming conventions (the intended marketing names) for the +Income GMWB. We believe that both general references to GMWBs and their risks, as well as more focused language describing the GMWB currently offered under the contract are appropriate and necessary to investor understanding, and would like to retain both concepts. Revisions have been made throughout the prospectus to better align references for clarity.
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).
3.Please include contact information for Jackson’s Customer Care Center on the cover page as there are several cross-references throughout the prospectus directing the investor to the contact information on the cover page. Alternatively, please provide this contact information elsewhere in the prospectus and update the cross-references accordingly.
Response: We have made this revision.
Table of Contents
4.Please ensure that when submitting the prospectus via the EDGAR system that the Table of Contents is hyperlinked to the corresponding section and subsection pages for ease of review.
Response: The prospectus submitted via EDGAR will be hyperlinked, as requested.
Summary (pp. 2-7)
5.In the last sentence of the second paragraph, you reference “Annual Step-Ups.” Please consider adding this term to the glossary.
Response: We have made this revision.
6.In the the first paragraph of the subsection titled “Interim Value Adjustment”, you include a parenthetical describing the types of withdrawals to which an interim value adjustment applies, If the intent is to provide a complete list of withdrawal types, please consider adding automatic withdrawals to make the disclosure complete. In addition, please clarify whether interim value adjustments include withdrawal charges/fees.
Response: We have made this revision.
7.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, please review and break this subsection into shorter and simpler disclosure. Consider using bullets to make the information easier for an investor to understand.
Response: We have made this revision.
8.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, and throughout the prospectus, you use the following parenthetical when describing the GAWA: “(which will never be less than your Required Minimum Distribution (“RMD”), if applicable)” or similar variations of this parenthetical. Please consider whether providing an explanation that if RMDs apply, and the RMD is greater than the GAWA, you get the RMD, would be clearer for an investor than the repeated parenthetical.
Response: We have made revisions throughout the prospectus for clarity.
9.In the subsection titled “Guaranteed Minimum Withdrawal Benefit”, please move the description of the For Life Guarantee further down in the subsection.
Response: We have made this revision.
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).
10.The following comments address the Contract Overview table:
a.In the last sentence of the “Access to Your Money” row, please update to include disclosure that Withdrawal Charges may apply to Excess Withdrawals under the rider.
Response: We have made this revision.
b.In the “Add-On Guaranteed Minimum Withdrawal Benefit” row, please review and revise row into shorter and simpler disclosure, consistent with Comment 7.
Response: We have made this revision.
c.In the “Add-On Guaranteed Minimum Withdrawal Benefit” row, in the sentence beginning “The longer withdrawals are deferred (up to 9 years)...”, please check to ensure this disclosure, as well as similar disclosures throughout the prospectus, is consistent with a 9+ year option if included at launch.
Response: GAWA% hit their highest level and can no longer increase once the Deferral Year 9 has been reached, as such, we believe the existing disclosures are accurate. No revision has been made in response to this comment.
d.In the “Charges and Expenses” row, please revise consistent with Comment 6.
Response: We have made this revision.
Risk Factors (pp. 12-14)
11.The following comments address the subsection titled “Add-On Benefit”:
a.Please identify that the rider cannot be terminated by the contract owner independently from the contract.
Response: We have made this revision.
b. Please ensure terminology referencing the rider is consistent with Comment 2,
Response: We have made this revision.
c. In the second paragraph, where you reference waiting periods, please consider whether this should instead reference deferral periods/years.
Response: We have made this revision.
d. In the fourth paragraph, please consider whether the reference to Excess Withdrawals reducing the value of the “benefit” should be revised to Excess Withdrawals reducing the value of the “GWB” to provide more specificity and clarity to the investor.
Response: We have made this revision.
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).
e. Please include a description of the risk associated with not taking required RMD withdrawals and provide a cross-reference to any relevant tax or other RMD disclosures.
Response: We have made this revision.
12.The following comments address the subsection titled “Effects of Withdrawals, Annuitization, or Death”:
a.Please ensure terminology referencing withdrawals of the GAWA are consistent. In this subsection, you reference “GAWA withdrawals” while in the Summary section of the prospectus, you phrase this as “withdrawals of the GAWA.”
Response: We have made this revision.
b.In the last two sentences of the first paragraph, please revise to include disclosure about withdrawals of amounts in excess of the Free Withdrawal as you do in the Summary section of the prospectus.
Response: We have made this revision.
c.In the last sentence of the subsection, you note “[i]f your Contract Value falls below the minimum Contract Value remaining as a result of a withdrawal (as stated in your Contract), we may terminate your Contract.” Please confirm whether this termination trigger applies when the rider is elected and what type of withdrawal would trigger this termination.
Response: We have made this revision.
Glossary (pp. 8-11)
13.Consider reformatting so that the glossary appears immediately before or after the Summary for ease of review, particularly if an investor is reviewing in hard copy.
Response: We have made this revision.
14.Consider adding a defined term for GMWB with Joint Option.
Response: We have made significant revision to the references to GMWB, +Income GMWB, and +Income GMWB with Joint Option, and believe no additional defined term is required.
15.The following terms in the Glossary should be revised as indicated:
a.Covered Life - Please consider clarifying that the Covered Life only applies to the joint life GMWB. In addition, consider clarifying who the the Covered Lives are (i.e. Are they the measuring lives? Are they the lives who get the benefit of the rider?).
Response: We have made this revision.
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).
b.Deferral Year - Please consider adding disclosure that Deferral Years are capped at 9 years.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, no revision has been made to the Glossary definition for Deferral Year.
c.Designated Life - In the first sentence, instead of saying “the life on which certain add-on Guaranteed Minimum Withdrawal Benefit (“GMWB”) values are based,” consider revising to “the life on which the GAWA% for the GMWB is based” to add more specificity.
Response: Consistent with revisions to simplify Glossary definitions and provided detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
d.Determination Date - Please include disclosure explaining when the Determination Date is locked-in. For reference, in Appendix D, Example 2, there is an extensive list of what triggers the Determination Date and the GAWA% to be determined and locked-in.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
e.For Life Guarantee - Consider adding an explanation on when this guarantee is triggered and when and under what circumstances it terminates. In addition, please consider simply saying “Owner or Annuitant” instead of Designated Life.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
f.Guaranteed Annual Withdrawal Amount ("GAWA") - In the first sentence of the definition, consider simply referring to the “GWB” instead of “guaranteed annual level of income.” In the last sentence, consider identifying that the increase or decrease to the GAWA is based on Annual Step-Ups or Excess Withdrawals.
Response: Consistent with revisions to simplify Glossary definitions and provide detailed information in appropriate prospectus sections, we have made a slightly different revision in response to this comment.
g.Withdrawal Value - Consider revising the last sentence to read “...less any applicable Withdrawal Charge or rider charge.”
Response: We have made this revision.
Contract Options (pp. 17-20)
16.In the first paragraph of the subsection titled “Interim Value”, please update the disclosures consistently with Comment 6 to include reference to automatic withdrawals, and a statement identifying that withdrawal charges will be assessed in addition to the Interim Value adjustment.
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: We have made this revision.
Access To Your Money (pp. 28-29)
17.The following comments address the subsection titled “Guaranteed Minimum Withdrawal Benefit Considerations”:
a.Please bold the first sentence of the third paragraph.
Response: We have made this revision.
b. In the fourth paragraph, please note the inconsistent references to “Joint For Life GMWB” and revise consistently with defined terms. In addition, if there is an opportunity to make a distinction between the Joint Life option only being available to spouses while the Single Life option is available to spouses and unrelated parties earlier in the prospectus, please do so.
Response: We have made this revision.
+Income For Life Guaranteed Minimum Withdrawal Benefit (pp. 29-40)
18.Please move the subsection titled “+Income For Life Guaranteed Minimum Withdrawal Benefit with Annual Step-Up for a Single Life or Two Covered Lives (“+Income GMWB” and “+Income GMWB with Joint Option”)” to the beginning of the Access to Your Money section of the prospectus, and make the “Guaranteed Minimum Withdrawal Benefit Considerations” subsection a child subsection lower in the section.
Response: We have made this revision.
19.In the parenthetical within the subsection title “+Income For Life Guaranteed Minimum Withdrawal Benefit with Annual Step-Up for a Single Life or Two Covered Lives (“+Income GMWB” and “+Income GMWB with Joint Option”)”, please add the word “respectively” after +Income GMWB with Joint Option.
Response: We have made a slightly different revision to address this comment, breaking the parenthetical into two parentheticals immediately following each version of the benefit in the subsection title.
20.Please reconcile the disclosure in the second sentence of the second paragraph of the section with the definition of “Covered Life” glossary (e.g. to include qualified custodial accounts).
Response: We have made this revision.
21.In the last paragraph of this section immediately preceding the tables, please consider using the term “annuitization” instead of Income Date.
Response: The use of “Income Date” rather than “annuitization” is intentional. Registrant has updated its terminology to provide language that is easier for investors to understand, based on a language study conducted several years ago. This terminology is consistent throughout all of our registered product prospectuses and contracts, and would require extensive amendments to both in
Jackson® is the marketing name for Jackson National Life Ins