Correspondence 0000931788-24-000017 from JACKSON NATIONAL LIFE INSURANCE CO (CIK 0000931788)
JACKSON NATIONAL LIFE INSURANCE CO (CIK 0000931788)
Date: March 25, 2024 · CIK: 0000931788 · Accession: 0000931788-24-000017
AI Filing Summary & Sentiment
File numbers found in text: 333-268090
Letter
jmlpiisecresponsecombined
MEMORANDUM
TO:
Sonny Oh, Esq.
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:
March 25, 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 March 21, 2024 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).
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 Page (p. 1)
1.In the third paragraph, where you make generic reference to the GMWB, please consider adding more specific
references to the two versions of the GMWB offered in this contract.
Response: Respectfully, this sentence generally identifies categories of contract options that are described
in the prospectus. We do not identify the indexes, crediting methods, or protection options specifically in
the first half of the sentence, so the general reference to GMWBs without specific identification of single or
joint life versions is in keeping with the totality of this disclosure. As such, no revision has been made in
response to this comment.
2.In the fifth paragraph, please remove the reference to advisory fees in the new disclosure block.
Response: We have made this revision.
3.In the second to last paragraph, please add in the mailing address to the Customer Care Center.
Response: We have made this revision.
Summary (pp. 4-10)
4.In the second paragraph, please introduce the "+Income GMWB" and "+Income GMWB with Joint Option"
terminology rather than the general reference to "+Income."
Response: We have made this revision.
5.In the second paragraph, we note that you refer to "Annual Step-Ups" but in the glossary have defined only "Step-
Up." Please consider whether revisions are required for consistency.
Response: The reference here to Annual Step-Ups is part of the full filed name of the add-on benefit. No
revisions have been made in response to this comment.
6.In the fourth to last line of the first paragraph of the subsection titled “Interim Value Adjustment”, where you
reference GAWA Withdrawals, please identify what a GAWA withdrawal is since this is the first reference to this
term in the prospectus.
Response: We have made this revision.
7.The following comments address the subsection titled “Guaranteed Minimum Withdrawal Benefit”:
a.In the first paragraph, please distinguish between the single and joint options as two different options.
Response: We have made this revision.
b.Please clarify in greater detail the GAWA and RMD, as seen in the last sentence of the first paragraph.
This area of information should conform to other references of this in the prospectus.
Response: We have made this revision.
c.In the first bullet, for clarity, please break out the information regarding how long the GAWA is
guaranteed so that the first bullet reads simply "The GAWA is guaranteed even if your Contract Value
drops to zero (other than due to an Excess Withdrawal or a total withdrawal)."
Response: We have made this revision.
d.Please consider breaking the Step-Up bullet disclosures into two bullets, with one addressing the annual
Step-Up and one addressing the Determination Date Step-Up.
Response: We have made this revision.
e.In the paragraph before the Contract Overview section, please break out the last sentence and make it a
stand-alone, bolded paragraph.
Response: We have made this revision.
8.Consider adding the last sentence from the Access to Your Money row of the Contract Overview table to the Add-
On Guaranteed Minimum Withdrawal Benefit row of the Contract Overview table as well. Please also note that if
annuitized in the first year, withdrawal charges would also apply. Ensure the disclosures are consistent with the
disclosures on the same mechanics in the Withdrawal Charge row of this table.
Response: We have added additional disclosure to the Add-On GMWB row of the table in response to this
comment. With regard to the reference to annuitization during the first year, respectfully, the Access to
Your Money row of the table addresses only the time period prior to the Income Date, so a reference to
annuitization does not belong in the row. No revision has been made in response to that portion of this
comment.
Glossary (pp. 11-12)
9.In the definition for Step-Up, consider including in the definition that there are two types of step-ups.
Additionally, please note the typo in the first word of the definition.
Response: We have made this revision.
10.In the definition for Withdrawal Charge, please conform the language in this definition to match the disclosures in
the Withdrawal Charge row of the Contract Overview table.
Response: We have made this revision.
Risk Factors (pp. 13-14)
11.In the subsection titled “Add-On Benefit”, please update the header with more specificity to the riders offered
under the contract.
Response: We have made this revision.
12.Please include the third to last paragraph in the Guaranteed Minimum Withdrawal Benefit subsection of the
Summary as well.
Response: We have made this revision.
Performance Boost Crediting Method (pp. 23-25)
13.In the second paragraph, fourth sentence, please provide an example of when there is a mismatch.
Response: We have relocated this disclosure to the end of this subsection and added a cross-reference to
the examples of these scenarios in the Interim Value subsection.
+Income Rider (pp. 26-30)
14.In the section title, please update to include the full name of the benefit for both.
Response: We have made this revision.
15.In the first sentence, please remove reference to “for life” to remain consistent with the defined terms and any
earlier references of this benefit.
Response: We have made this revision.
16.In the fifth paragraph, please revise to read "This GMWB..." consistent with the note in the prior paragraph.
Response: We have made this revision.
17.In the second to last full paragraph before the subsection titled "Guaranteed Withdrawal Balance ("GWB"),
please note that this disclosure was relocated from the former tables that appeared in this section, however the full
former table disclosure was not included here. Please review to determine whether that disclosure should be
added. Please also incorporate this disclosure into the risk factor for the add-on benefit.
Response: When the former table disclosure was relocated, the portion omitted in the paragraph identified
by this comment was removed as that disclosure relates to spousal continuation and that information along
with more detailed rules around spousal continuation are already disclosed in the subsection titled
"Spousal Continuation." No additional revisions were made in response to that part of this comment. We
did revise to add this disclosure to the Risk Factor for the add-on benefit.
18.In the second sentence of the second to last paragraph of the subsection titled “Guaranteed Withdrawal Balance
("GWB")”, please consider adding disclosure to the first part of this sentence addressing the dollar-for-dollar
reduction of these withdrawals since the next sentence addresses proportional reduction for Excess Withdrawals.
Response: Respectfully, because of the phrasing of this sentence, it is intended to generally note that all
withdrawals reduce these values, with the reference to GAWA withdrawals intending only to emphasize
that "all withdrawals" includes permissible withdrawals. However, all withdrawals do not reduce these
values dollar-for-dollar, which is the reason for the emphasis on the proportional reduction of Excess
Withdrawals in the following sentence. Adding a reference to dollar-for-dollar reduction in the identified
sentence would confuse the mechanics here, so we have declined to make this revision.
19.The following comments address the subsection titled “Withdrawals”:
a.In the first sentence of the second paragraph, you note that GAWA withdrawals do not reduce the value
of the GMWB, however please note that GAWA Withdrawals do reduce the GWB dollar for dollar, so
please make this disclosure more precise language.
Response: We have revised to specifically note GAWA Withdrawals do not reduce the value of the For Life
Guarantee, as any reduction in GWB will have no impact on payout if the For Life Guarantee is in effect.
This was the intent of the original statement, so we believe this meets the requested specificity.
b.In the second bullet of the third paragraph, please note that we previously requested this disclosure be
added to the Risk Factor for the add-on benefit (See: prior comment 24).
Response: Respectfully, this information was already added to the Risk Factor section for the benefit. You
may find it in the second to last paragraph of that Risk Factor subsection.
c.In the third bullet of the third paragraph, please review and determine whether a distinction is needed with
regard to Excess Withdrawals.
Response: We have made this revision.
d.In the second paragraph following the GAWA% tables, please revise language regarding rate changes for
clarity.
Response: We have made this revision.
20.The following comments address the subsection titled “Step-Up”:
a.In the third to last sentence of the first paragraph, please include disclosure that opting out of annual Step-
Ups will trigger the Determination Date.
Response: We have made this revision.
b.In the second paragraph, here again, please add in a distinction regarding dollar-for-dollar reduction for
GAWA withdrawals.
Response: Please see response to comment 19. No revision made.
21.In the last paragraph of the RMD Notes table in the subsection titled "Required Minimum Distributions Under
Certain Tax Qualified Plans ("RMDs"), please check the cross reference to example 4 to ensure accuracy.
Response: We have made this revision.
22.In the subsection "Guaranteed Minimum Withdrawal Benefit Considerations", please note that a paragraph was
deleted that identified the single life version of the benefit being available to spouses and unrelated parties while
the joint life version of the benefit is available only to spouses. Please ensure that this disclosure appears
somewhere in the add-on benefit disclosures section of the prospectus.
Response: We have incorporated this disclosure into the introductory section of the rider disclosures.
Appendix D (p. 32)
23.In Example 5, please include the description you provided in response to prior comment 41 in the example itself
to assist an investor in understanding the GAWA value that appears not to follow the assumption provided in the
introduction to this Appendix.
Response: We have made this revision.
Please contact me at (517) 367-3754 if you have any questions or require additional information.
THE INFORMATION IN THE PROSPECTUS IS NOT COMPLETE AND MAY BE CHANGED. WE MAY NOT SELL THE SECURITIES UNTIL THE REGISTRATION STATEMENT FILED WITH THE SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THIS PROSPECTUS IS NOT AN OFFER TO SELL THESE SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED. JACKSON MARKET LINK PRO® II SINGLE PREMIUM DEFERRED INDEX-LINKED ANNUITY Issued by Jackson National Life Insurance Company® The date of this prospectus is ________, 2024. This prospectus contains information about the Contract and Jackson National Life Insurance Company (“Jackson®”) that you should know before investing. This prospectus is a disclosure document and describes all of the Contract’s material features, benefits, rights, and obligations of annuity purchasers under the Contract. The description of the Contract’s material provisions in this prospectus is current as of the date of this prospectus. If certain material provisions under the Contract are changed after the date of this prospectus, in accordance with the Contract, those changes will be described in a supplemented prospectus. It is important that you also read the Contract and endorsements, which may reflect additional non-material state variations. Jackson's obligations under the Contract are subject to our financial strength and claims-paying ability. The information in this prospectus is intended to help you decide if the Contract will meet your investment and financial planning needs. Index-linked annuity contracts are complex insurance and investment vehicles. Before you invest, be sure to discuss the Contract’s features, benefits, risks, and fees with your financial professional in order to determine whether the Contract is appropriate for you based upon your financial situation and objectives. Please carefully read this prospectus and any related documents and keep everything together for future reference. This prospectus describes the Indexes, Terms, Crediting Methods, Protection Options, and add-on Guaranteed Minimum Withdrawal Benefits ("GMWB") that we currently offer under the Contract. We reserve the right to limit the number of Contracts that you may purchase. We also reserve the right to refuse any Premium payment. Please confirm with us or your financial professional that you have the most current prospectus that describes the availability and any restrictions on the Crediting Methods and Protection Options. The Jackson Market Link Pro II Contract is an individual single Premium deferred registered index-linked annuity Contract issued by Jackson. The Contract provides for the potential accumulation of retirement savings and partial downside protection in adverse market conditions. The Contract is a long-term, tax-deferred annuity designed for retirement or other long-term investment purposes. It is available for use in Non-Qualified plans, Qualified plans, Tax-Sheltered annuities, Traditional IRAs, and Roth IRAs. The Contract may not be appropriate for you if you plan to take withdrawals from an Index Account Option prior to the end of the Index Account Option Term, especially if you plan to take ongoing withdrawals such as Required Minimum Distributions or the payment of advisory fees to your third-party advisor. We apply an Interim Value adjustment to amounts removed from an Index Account Option during the Index Account Option Term, and if this adjustment is negative, you could lose up to 100% of your investment. Withdrawals could also result in significant reductions to your Contract Value and the death benefit (perhaps by more than the amount withdrawn), as well as to the Index Adjustment credited at the end of the Index Account Option Term. Withdrawals may also be subject to income taxes and income tax penalties if taken before age 59 1/2. If you do intend to take ongoing withdrawals under the Contract, particularly from an Index Account Option during the Index Account Option Term, you should consult with a financial professional. Crediting Methods such as the Cap, Performance Trigger, and Performance Boost could limit positive Index gain. The Contract currently offers 10% Floor, and 10% and 20% Buffer P
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filename1.htm
jmlpiisecresponsecombined
MEMORANDUM
TO:
Sonny Oh, Esq.
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:
March 25, 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 March 21, 2024 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).
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 Page (p. 1)
1.In the third paragraph, where you make generic reference to the GMWB, please consider adding more specific
references to the two versions of the GMWB offered in this contract.
Response: Respectfully, this sentence generally identifies categories of contract options that are described
in the prospectus. We do not identify the indexes, crediting methods, or protection options specifically in
the first half of the sentence, so the general reference to GMWBs without specific identification of single or
joint life versions is in keeping with the totality of this disclosure. As such, no revision has been made in
response to this comment.
2.In the fifth paragraph, please remove the reference to advisory fees in the new disclosure block.
Response: We have made this revision.
3.In the second to last paragraph, please add in the mailing address to the Customer Care Center.
Response: We have made this revision.
Summary (pp. 4-10)
4.In the second paragraph, please introduce the "+Income GMWB" and "+Income GMWB with Joint Option"
terminology rather than the general reference to "+Income."
Response: We have made this revision.
5.In the second paragraph, we note that you refer to "Annual Step-Ups" but in the glossary have defined only "Step-
Up." Please consider whether revisions are required for consistency.
Response: The reference here to Annual Step-Ups is part of the full filed name of the add-on benefit. No
revisions have been made in response to this comment.
6.In the fourth to last line of the first paragraph of the subsection titled “Interim Value Adjustment”, where you
reference GAWA Withdrawals, please identify what a GAWA withdrawal is since this is the first reference to this
term in the prospectus.
Response: We have made this revision.
7.The following comments address the subsection titled “Guaranteed Minimum Withdrawal Benefit”:
a.In the first paragraph, please distinguish between the single and joint options as two different options.
Response: We have made this revision.
b.Please clarify in greater detail the GAWA and RMD, as seen in the last sentence of the first paragraph.
This area of information should conform to other references of this in the prospectus.
Response: We have made this revision.
c.In the first bullet, for clarity, please break out the information regarding how long the GAWA is
guaranteed so that the first bullet reads simply "The GAWA is guaranteed even if your Contract Value
drops to zero (other than due to an Excess Withdrawal or a total withdrawal)."
Response: We have made this revision.
d.Please consider breaking the Step-Up bullet disclosures into two bullets, with one addressing the annual
Step-Up and one addressing the Determination Date Step-Up.
Response: We have made this revision.
e.In the paragraph before the Contract Overview section, please break out the last sentence and make it a
stand-alone, bolded paragraph.
Response: We have made this revision.
8.Consider adding the last sentence from the Access to Your Money row of the Contract Overview table to the Add-
On Guaranteed Minimum Withdrawal Benefit row of the Contract Overview table as well. Please also note that if
annuitized in the first year, withdrawal charges would also apply. Ensure the disclosures are consistent with the
disclosures on the same mechanics in the Withdrawal Charge row of this table.
Response: We have added additional disclosure to the Add-On GMWB row of the table in response to this
comment. With regard to the reference to annuitization during the first year, respectfully, the Access to
Your Money row of the table addresses only the time period prior to the Income Date, so a reference to
annuitization does not belong in the row. No revision has been made in response to that portion of this
comment.
Glossary (pp. 11-12)
9.In the definition for Step-Up, consider including in the definition that there are two types of step-ups.
Additionally, please note the typo in the first word of the definition.
Response: We have made this revision.
10.In the definition for Withdrawal Charge, please conform the language in this definition to match the disclosures in
the Withdrawal Charge row of the Contract Overview table.
Response: We have made this revision.
Risk Factors (pp. 13-14)
11.In the subsection titled “Add-On Benefit”, please update the header with more specificity to the riders offered
under the contract.
Response: We have made this revision.
12.Please include the third to last paragraph in the Guaranteed Minimum Withdrawal Benefit subsection of the
Summary as well.
Response: We have made this revision.
Performance Boost Crediting Method (pp. 23-25)
13.In the second paragraph, fourth sentence, please provide an example of when there is a mismatch.
Response: We have relocated this disclosure to the end of this subsection and added a cross-reference to
the examples of these scenarios in the Interim Value subsection.
+Income Rider (pp. 26-30)
14.In the section title, please update to include the full name of the benefit for both.
Response: We have made this revision.
15.In the first sentence, please remove reference to “for life” to remain consistent with the defined terms and any
earlier references of this benefit.
Response: We have made this revision.
16.In the fifth paragraph, please revise to read "This GMWB..." consistent with the note in the prior paragraph.
Response: We have made this revision.
17.In the second to last full paragraph before the subsection titled "Guaranteed Withdrawal Balance ("GWB"),
please note that this disclosure was relocated from the former tables that appeared in this section, however the full
former table disclosure was not included here. Please review to determine whether that disclosure should be
added. Please also incorporate this disclosure into the risk factor for the add-on benefit.
Response: When the former table disclosure was relocated, the portion omitted in the paragraph identified
by this comment was removed as that disclosure relates to spousal continuation and that information along
with more detailed rules around spousal continuation are already disclosed in the subsection titled
"Spousal Continuation." No additional revisions were made in response to that part of this comment. We
did revise to add this disclosure to the Risk Factor for the add-on benefit.
18.In the second sentence of the second to last paragraph of the subsection titled “Guaranteed Withdrawal Balance
("GWB")”, please consider adding disclosure to the first part of this sentence addressing the dollar-for-dollar
reduction of these withdrawals since the next sentence addresses proportional reduction for Excess Withdrawals.
Response: Respectfully, because of the phrasing of this sentence, it is intended to generally note that all
withdrawals reduce these values, with the reference to GAWA withdrawals intending only to emphasize
that "all withdrawals" includes permissible withdrawals. However, all withdrawals do not reduce these
values dollar-for-dollar, which is the reason for the emphasis on the proportional reduction of Excess
Withdrawals in the following sentence. Adding a reference to dollar-for-dollar reduction in the identified
sentence would confuse the mechanics here, so we have declined to make this revision.
19.The following comments address the subsection titled “Withdrawals”:
a.In the first sentence of the second paragraph, you note that GAWA withdrawals do not reduce the value
of the GMWB, however please note that GAWA Withdrawals do reduce the GWB dollar for dollar, so
please make this disclosure more precise language.
Response: We have revised to specifically note GAWA Withdrawals do not reduce the value of the For Life
Guarantee, as any reduction in GWB will have no impact on payout if the For Life Guarantee is in effect.
This was the intent of the original statement, so we believe this meets the requested specificity.
b.In the second bullet of the third paragraph, please note that we previously requested this disclosure be
added to the Risk Factor for the add-on benefit (See: prior comment 24).
Response: Respectfully, this information was already added to the Risk Factor section for the benefit. You
may find it in the second to last paragraph of that Risk Factor subsection.
c.In the third bullet of the third paragraph, please review and determine whether a distinction is needed with
regard to Excess Withdrawals.
Response: We have made this revision.
d.In the second paragraph following the GAWA% tables, please revise language regarding rate changes for
clarity.
Response: We have made this revision.
20.The following comments address the subsection titled “Step-Up”:
a.In the third to last sentence of the first paragraph, please include disclosure that opting out of annual Step-
Ups will trigger the Determination Date.
Response: We have made this revision.
b.In the second paragraph, here again, please add in a distinction regarding dollar-for-dollar reduction for
GAWA withdrawals.
Response: Please see response to comment 19. No revision made.
21.In the last paragraph of the RMD Notes table in the subsection titled "Required Minimum Distributions Under
Certain Tax Qualified Plans ("RMDs"), please check the cross reference to example 4 to ensure accuracy.
Response: We have made this revision.
22.In the subsection "Guaranteed Minimum Withdrawal Benefit Considerations", please note that a paragraph was
deleted that identified the single life version of the benefit being available to spouses and unrelated parties while
the joint life version of the benefit is available only to spouses. Please ensure that this disclosure appears
somewhere in the add-on benefit disclosures section of the prospectus.
Response: We have incorporated this disclosure into the introductory section of the rider disclosures.
Appendix D (p. 32)
23.In Example 5, please include the description you provided in response to prior comment 41 in the example itself
to assist an investor in understanding the GAWA value that appears not to follow the assumption provided in the
introduction to this Appendix.
Response: We have made this revision.
Please contact me at (517) 367-3754 if you have any questions or require additional information.
THE INFORMATION IN THE PROSPECTUS IS NOT COMPLETE AND MAY BE CHANGED. WE MAY NOT SELL THE SECURITIES UNTIL THE REGISTRATION STATEMENT FILED WITH THE SECURITIES AND EXCHANGE COMMISSION IS EFFECTIVE. THIS PROSPECTUS IS NOT AN OFFER TO SELL THESE SECURITIES AND IS NOT SOLICITING AN OFFER TO BUY THESE SECURITIES IN ANY STATE WHERE THE OFFER OR SALE IS NOT PERMITTED. JACKSON MARKET LINK PRO® II SINGLE PREMIUM DEFERRED INDEX-LINKED ANNUITY Issued by Jackson National Life Insurance Company® The date of this prospectus is ________, 2024. This prospectus contains information about the Contract and Jackson National Life Insurance Company (“Jackson®”) that you should know before investing. This prospectus is a disclosure document and describes all of the Contract’s material features, benefits, rights, and obligations of annuity purchasers under the Contract. The description of the Contract’s material provisions in this prospectus is current as of the date of this prospectus. If certain material provisions under the Contract are changed after the date of this prospectus, in accordance with the Contract, those changes will be described in a supplemented prospectus. It is important that you also read the Contract and endorsements, which may reflect additional non-material state variations. Jackson's obligations under the Contract are subject to our financial strength and claims-paying ability. The information in this prospectus is intended to help you decide if the Contract will meet your investment and financial planning needs. Index-linked annuity contracts are complex insurance and investment vehicles. Before you invest, be sure to discuss the Contract’s features, benefits, risks, and fees with your financial professional in order to determine whether the Contract is appropriate for you based upon your financial situation and objectives. Please carefully read this prospectus and any related documents and keep everything together for future reference. This prospectus describes the Indexes, Terms, Crediting Methods, Protection Options, and add-on Guaranteed Minimum Withdrawal Benefits ("GMWB") that we currently offer under the Contract. We reserve the right to limit the number of Contracts that you may purchase. We also reserve the right to refuse any Premium payment. Please confirm with us or your financial professional that you have the most current prospectus that describes the availability and any restrictions on the Crediting Methods and Protection Options. The Jackson Market Link Pro II Contract is an individual single Premium deferred registered index-linked annuity Contract issued by Jackson. The Contract provides for the potential accumulation of retirement savings and partial downside protection in adverse market conditions. The Contract is a long-term, tax-deferred annuity designed for retirement or other long-term investment purposes. It is available for use in Non-Qualified plans, Qualified plans, Tax-Sheltered annuities, Traditional IRAs, and Roth IRAs. The Contract may not be appropriate for you if you plan to take withdrawals from an Index Account Option prior to the end of the Index Account Option Term, especially if you plan to take ongoing withdrawals such as Required Minimum Distributions or the payment of advisory fees to your third-party advisor. We apply an Interim Value adjustment to amounts removed from an Index Account Option during the Index Account Option Term, and if this adjustment is negative, you could lose up to 100% of your investment. Withdrawals could also result in significant reductions to your Contract Value and the death benefit (perhaps by more than the amount withdrawn), as well as to the Index Adjustment credited at the end of the Index Account Option Term. Withdrawals may also be subject to income taxes and income tax penalties if taken before age 59 1/2. If you do intend to take ongoing withdrawals under the Contract, particularly from an Index Account Option during the Index Account Option Term, you should consult with a financial professional. Crediting Methods such as the Cap, Performance Trigger, and Performance Boost could limit positive Index gain. The Contract currently offers 10% Floor, and 10% and 20% Buffer P