SEC Company Response from PRUCO LIFE FLEXIBLE PREMIUM VARIABLE ANNUITY ACCOUNT (CIK 0000947703) — Dec 15, 2021
PRUCO LIFE FLEXIBLE PREMIUM VARIABLE ANNUITY ACCOUNT (CIK 0000947703)
Date: Dec. 15, 2021 · CIK: 0000947703 · Accession: 0000947703-21-000306
AI Filing Summary & Sentiment
File numbers found in text: 333-162673, 333-162678, 333-170466, 333-184887, 333-184890, 333-184891, 333-184892, 333-192701, 333-192702, 811-07325
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Re: Response to SEC Staff Comments on Registration Statement Pruco Life Flexible Premium Variable Annuity Account Post-effective Amendment No. 22 to Registration Statement on Form N-4 SEC File Nos. 333-184890 and 811-07325
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff oral comments received on December 1, 2021 to Post-effective Amendment No. 22 to Registration Statement noted above. Included in this submission are a revised prospectus and revised Item 27 of Registration Statement Part C which incorporate the changes described below.
The Staff’s comments regarding the Prudential Premier Retirement Variable Annuity and our proposed responses are as follows:
1.ISP and Template Filing
Confirm that there is no ISP that’s intended to be used with the contract and indicate whether this registration will be used as a template filing or not for other registrations.
Response: We confirm that this contract will not be using an ISP. This registration will be used as a template filing for the following products. Registrant will provide Staff with a draft request for template relief in the coming weeks.
Alberto H. Zapata, Esq.
December 15, 2021
Page 2
PLAZ 333-184890 Prudential Premier Retirement Variable Annuity
(for Annuities issued on or after February 10, 2014) v3.0
April 30, 2021 485(a) to be filed October 14, 2021
Prudential Premier Retirement Variable Annuity
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-170466 Prudential Premier Retirement Variable Annuity
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-184887 Prudential Premier Retirement Variable Annuity (B, L, and C Series)
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity (B, L, and C Series)
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-162673 Prudential Premier Retirement Variable Annuity (X, B, L, and C Series)
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-192701 Prudential Premier Investment Variable Annuity (B Series and C Series) April 30, 2021 485(b)(1)(vii) relief
PLNJ 333-184891 Prudential Premier Retirement Variable Annuity – NY version
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity – NY version
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-184892 Prudential Premier Retirement Variable Annuity (B, L, and C Series) – NY version
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity (B, L, and C Series) – NY version
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-162678 Prudential Premier Retirement Variable Annuity (X, B, L, and C Series) – NY version
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-192702 Prudential Premier Investment Variable Annuity (B Series and C Series) – NY version
April 30, 2021 485(b)(1)(vii) relief
PLAZ – Pruco Life Insurance Company; Pruco Life Flexible Premium Variable Annuity Account
PLNJ – Pruco Life Insurance Company of New Jersey; Pruco Life of New Jersey Flexible Premium Variable Annuity Account
2.EDGAR Class ID
The product name on the prospectus cover page and the EDGAR Class/Contract ID do not match. Is the second line under the product name on the cover page part of the product name? Clarify the Contract name and amend the EDGAR ID as necessary.
Response: The product name is Prudential Premier® Retirement Variable Annuity. This prospectus is to be used for Annuities that were issued on or after February 10, 2014. The second line in the current prospectus cover page is used as a further description of the variable annuity. We have revised the presentation of the title of the prospectus to match to the EDGAR Class/Contract ID which reflects the proper version of the contract.
3.Cover Page of Prospectus
a.We note that the legend informing investors about internet availability of reports pursuant to the requirements of rule 30(e)(3) is no longer required after 12/31/21. It is your option to either remove it or keep it.
Alberto H. Zapata, Esq.
December 15, 2021
Page 3
Response: We have removed the disclosure that was formerly required under rule 30(e)(3).
b.The website address included in the second paragraph of the rule 30(e)(3) disclosure has a website address that does not match the website address contained in Appendix A. Please confirm that the correct address is being used.
Response: As we are removing the rule 30(e)(3) language, this is no longer an issue.
4.Glossary
Remove the free look paragraph if it is no longer applicable if the product is no longer being sold.
Response: We have removed references to the free look provision throughout the prospectus.
5.Key Information Table
a.The formatting of the Key Information Table appears to be off (i.e., lines being added within the table cells where they shouldn’t be). Conform the formatting of the Key Information Table to the Form N-4.
Response: We have revised the formatting of the Key Information Table.
b.Please confirm that the Base Contract Charge includes administrative fees.
Response: We confirm that administrative fees are included in the Base Contract Charge.
6.Fee Table section
a.We note that Form N-4 uses the term “Surrender Charge.” The prospectus uses the term “Contingent Deferred Sales Charge.” If this were a newer contract, we would want the term “Surrender Charge” to be used, however, as this is an older contract in which the term Contingent Deferred Sales Charge may be used throughout the annuity contract, we will not request that it be changed in this prospectus.
Response: This product uses the term Contingent Deferred Sales Charge in the contract. We will keep the new terminology in mind for new product launches.
b.In footnote 4 on the Base Contract Expenses in the Annual Expenses table, please explain what the “Settlement Service Charge” is and consider whether or not it should be included as part of the Base Contract Charge and where else it would be reflected.
Response: The Settlement Service Charge only applies in the limited circumstance that the contract is issued as a beneficiary continuation contract. In those instances, the Base Contract Expense would not apply. Therefore, we believe it should be presented independently, and not cumulatively. We have revised the footnote disclosure to be more descriptive.
Alberto H. Zapata, Esq.
December 15, 2021
Page 4
c.In the Annual Expenses table, the title of “Your Optional Benefit Fees and Charges” should not have the word “Your” within the title.
Response: We have removed the word “Your” from the title.
d.Confirm that the Example does include the most expensive combination of contract charges.
Response: We confirm that the Example contains the most expensive combination of contract charges.
e.Confirm whether an investor can invest in multiple optional benefits.
Response: We confirm that an investor can only invest in a single optional income benefit.
f.Please complete the Example table in a subsequent filing when the data is available.
Response: The table will be completed in subsequent filing for the 2022 annual update.
g.Consider adding a cross-reference and/or hyperlink to the footnote beneath the Example table to the section explaining the limitation on the ability to annuitize in the first 3 Annuity Years.
Response: We have revised the footnote to cross-reference to the Annuity Options section of the prospectus.
7.Principal Risks
Confirm that all the principal risks associated with any of the optional benefits or other product features have been included.
Response: We confirm that all principal risks have been included.
8.Purchasing Your Annuity
a.Consider adding “or re-elections” to the end of the first line under the heading of the Purchasing Your Annuity section.
Response: We have revised the sentence to include “or re-elections.”
b.In the heading of “General Impact of New Limitation” on the next line, clarify what the new limitations are in the heading or within the paragraph following the heading. Consider whether the first paragraph under the heading of “General Impact of New Limitation” can be redrafted to be a little clearer.
Response: We have removed the “General Impact of New Limitation” section in its entirety. Disclosure from this section that is not elsewhere in the prospectus has been incorporated into the Additional Purchase Payments paragraph included in the “Purchasing Your Annuity” section. Additionally, we have made conforming changes throughout the prospectus to clarify that with
Alberto H. Zapata, Esq.
December 15, 2021
Page 5
the exception of contracts where an optional benefit has been elected, additional purchase payments are allowed.
c.Confirm that the right to suspend, reject and/or place limitations on the acceptance of additional purchase payments was contained in the initial contract language and was not added just for existing contract holders.
Response: We confirm that this right was included in the contracts at the time of issuance.
9.Optional Living Benefits
Confirm that the examples for each optional living benefit is included in the prospectus per Item 10(b) and (c).
Response: We confirm that examples have been included for each optional living benefit.
10.Appendix A: Portfolio Companies Available Under the Contract
We have concerns regarding whether the website page referenced in the Appendix is consistent with Rule 498A, paragraph (h) therein. Please review Rule 498A(h) and (j) and analyze whether the webpage is consistent with those rules. To the extent that you plan to use the summary prospectus under Rule 498A with these products, you may want to look at the website getting a more stream-lined place where a contract owner can find the summary prospectus.
Response: We will be modifying our website page to comply with the requirements of Rule 498A before beginning usage of Summary Prospectuses.
11.Part C, Item 27
a.The heading of Item 27 was amended in the new Form N-4. Please delete “Financial Statements” from the heading.
Response: We have revised the heading for Item 27.
b.The numbering convention for Item 27 does not appear to be correct. Please revise the numbering of the exhibits to conform to Form N-4.
Response: We have revised the numbering of the exhibits listed under Item 27.
If you have any questions, please call me at (203) 402-1624.
Very truly yours,
/s/Elizabeth Gioia
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Elizabeth Gioia
Vice President, Corporate Counsel
The Prudential Insurance Company of America
213 Washington Street, Newark, NJ 07102-2917
Tel 203-402-1624
Elizabeth.gioia@prudential.com
December 15, 2021
VIA EDGAR
Alberto H. Zapata, Esq.
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Response to SEC Staff Comments on Registration Statement
Pruco Life Flexible Premium Variable Annuity Account
Post-effective Amendment No. 22 to Registration Statement on Form N-4
SEC File Nos. 333-184890 and 811-07325
Dear Mr. Zapata:
On behalf of the above-referenced Registrant, below are responses to Staff oral comments received on December 1, 2021 to Post-effective Amendment No. 22 to Registration Statement noted above. Included in this submission are a revised prospectus and revised Item 27 of Registration Statement Part C which incorporate the changes described below.
The Staff’s comments regarding the Prudential Premier Retirement Variable Annuity and our proposed responses are as follows:
1.ISP and Template Filing
Confirm that there is no ISP that’s intended to be used with the contract and indicate whether this registration will be used as a template filing or not for other registrations.
Response: We confirm that this contract will not be using an ISP. This registration will be used as a template filing for the following products. Registrant will provide Staff with a draft request for template relief in the coming weeks.
Alberto H. Zapata, Esq.
December 15, 2021
Page 2
PLAZ 333-184890 Prudential Premier Retirement Variable Annuity
(for Annuities issued on or after February 10, 2014) v3.0
April 30, 2021 485(a) to be filed October 14, 2021
Prudential Premier Retirement Variable Annuity
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-170466 Prudential Premier Retirement Variable Annuity
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-184887 Prudential Premier Retirement Variable Annuity (B, L, and C Series)
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity (B, L, and C Series)
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-162673 Prudential Premier Retirement Variable Annuity (X, B, L, and C Series)
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-192701 Prudential Premier Investment Variable Annuity (B Series and C Series) April 30, 2021 485(b)(1)(vii) relief
PLNJ 333-184891 Prudential Premier Retirement Variable Annuity – NY version
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity – NY version
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-184892 Prudential Premier Retirement Variable Annuity (B, L, and C Series) – NY version
(for Annuities issued on or after February 10, 2014)
April 30, 2021 485(b)(1)(vii) relief
Prudential Premier Retirement Variable Annuity (B, L, and C Series) – NY version
(for Annuities issued on or after February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-162678 Prudential Premier Retirement Variable Annuity (X, B, L, and C Series) – NY version
(for Annuities purchased prior to February 25, 2013)
April 30, 2021 485(b)(1)(vii) relief
333-192702 Prudential Premier Investment Variable Annuity (B Series and C Series) – NY version
April 30, 2021 485(b)(1)(vii) relief
PLAZ – Pruco Life Insurance Company; Pruco Life Flexible Premium Variable Annuity Account
PLNJ – Pruco Life Insurance Company of New Jersey; Pruco Life of New Jersey Flexible Premium Variable Annuity Account
2.EDGAR Class ID
The product name on the prospectus cover page and the EDGAR Class/Contract ID do not match. Is the second line under the product name on the cover page part of the product name? Clarify the Contract name and amend the EDGAR ID as necessary.
Response: The product name is Prudential Premier® Retirement Variable Annuity. This prospectus is to be used for Annuities that were issued on or after February 10, 2014. The second line in the current prospectus cover page is used as a further description of the variable annuity. We have revised the presentation of the title of the prospectus to match to the EDGAR Class/Contract ID which reflects the proper version of the contract.
3.Cover Page of Prospectus
a.We note that the legend informing investors about internet availability of reports pursuant to the requirements of rule 30(e)(3) is no longer required after 12/31/21. It is your option to either remove it or keep it.
Alberto H. Zapata, Esq.
December 15, 2021
Page 3
Response: We have removed the disclosure that was formerly required under rule 30(e)(3).
b.The website address included in the second paragraph of the rule 30(e)(3) disclosure has a website address that does not match the website address contained in Appendix A. Please confirm that the correct address is being used.
Response: As we are removing the rule 30(e)(3) language, this is no longer an issue.
4.Glossary
Remove the free look paragraph if it is no longer applicable if the product is no longer being sold.
Response: We have removed references to the free look provision throughout the prospectus.
5.Key Information Table
a.The formatting of the Key Information Table appears to be off (i.e., lines being added within the table cells where they shouldn’t be). Conform the formatting of the Key Information Table to the Form N-4.
Response: We have revised the formatting of the Key Information Table.
b.Please confirm that the Base Contract Charge includes administrative fees.
Response: We confirm that administrative fees are included in the Base Contract Charge.
6.Fee Table section
a.We note that Form N-4 uses the term “Surrender Charge.” The prospectus uses the term “Contingent Deferred Sales Charge.” If this were a newer contract, we would want the term “Surrender Charge” to be used, however, as this is an older contract in which the term Contingent Deferred Sales Charge may be used throughout the annuity contract, we will not request that it be changed in this prospectus.
Response: This product uses the term Contingent Deferred Sales Charge in the contract. We will keep the new terminology in mind for new product launches.
b.In footnote 4 on the Base Contract Expenses in the Annual Expenses table, please explain what the “Settlement Service Charge” is and consider whether or not it should be included as part of the Base Contract Charge and where else it would be reflected.
Response: The Settlement Service Charge only applies in the limited circumstance that the contract is issued as a beneficiary continuation contract. In those instances, the Base Contract Expense would not apply. Therefore, we believe it should be presented independently, and not cumulatively. We have revised the footnote disclosure to be more descriptive.
Alberto H. Zapata, Esq.
December 15, 2021
Page 4
c.In the Annual Expenses table, the title of “Your Optional Benefit Fees and Charges” should not have the word “Your” within the title.
Response: We have removed the word “Your” from the title.
d.Confirm that the Example does include the most expensive combination of contract charges.
Response: We confirm that the Example contains the most expensive combination of contract charges.
e.Confirm whether an investor can invest in multiple optional benefits.
Response: We confirm that an investor can only invest in a single optional income benefit.
f.Please complete the Example table in a subsequent filing when the data is available.
Response: The table will be completed in subsequent filing for the 2022 annual update.
g.Consider adding a cross-reference and/or hyperlink to the footnote beneath the Example table to the section explaining the limitation on the ability to annuitize in the first 3 Annuity Years.
Response: We have revised the footnote to cross-reference to the Annuity Options section of the prospectus.
7.Principal Risks
Confirm that all the principal risks associated with any of the optional benefits or other product features have been included.
Response: We confirm that all principal risks have been included.
8.Purchasing Your Annuity
a.Consider adding “or re-elections” to the end of the first line under the heading of the Purchasing Your Annuity section.
Response: We have revised the sentence to include “or re-elections.”
b.In the heading of “General Impact of New Limitation” on the next line, clarify what the new limitations are in the heading or within the paragraph following the heading. Consider whether the first paragraph under the heading of “General Impact of New Limitation” can be redrafted to be a little clearer.
Response: We have removed the “General Impact of New Limitation” section in its entirety. Disclosure from this section that is not elsewhere in the prospectus has been incorporated into the Additional Purchase Payments paragraph included in the “Purchasing Your Annuity” section. Additionally, we have made conforming changes throughout the prospectus to clarify that with
Alberto H. Zapata, Esq.
December 15, 2021
Page 5
the exception of contracts where an optional benefit has been elected, additional purchase payments are allowed.
c.Confirm that the right to suspend, reject and/or place limitations on the acceptance of additional purchase payments was contained in the initial contract language and was not added just for existing contract holders.
Response: We confirm that this right was included in the contracts at the time of issuance.
9.Optional Living Benefits
Confirm that the examples for each optional living benefit is included in the prospectus per Item 10(b) and (c).
Response: We confirm that examples have been included for each optional living benefit.
10.Appendix A: Portfolio Companies Available Under the Contract
We have concerns regarding whether the website page referenced in the Appendix is consistent with Rule 498A, paragraph (h) therein. Please review Rule 498A(h) and (j) and analyze whether the webpage is consistent with those rules. To the extent that you plan to use the summary prospectus under Rule 498A with these products, you may want to look at the website getting a more stream-lined place where a contract owner can find the summary prospectus.
Response: We will be modifying our website page to comply with the requirements of Rule 498A before beginning usage of Summary Prospectuses.
11.Part C, Item 27
a.The heading of Item 27 was amended in the new Form N-4. Please delete “Financial Statements” from the heading.
Response: We have revised the heading for Item 27.
b.The numbering convention for Item 27 does not appear to be correct. Please revise the numbering of the exhibits to conform to Form N-4.
Response: We have revised the numbering of the exhibits listed under Item 27.
If you have any questions, please call me at (203) 402-1624.
Very truly yours,
/s/Elizabeth Gioia
Elizabeth Gioia
Alberto H. Zapata, Esq.
December 15, 2021
Page 6
Vice President, Corporate Counsel
PRUCO LIFE INSURANCE COMPANY
Pruco Life Flexible Premium Variable Annuity Account
A Prudential Financial Company
751 Broad Street, Newark, NJ 07102-3777
PRUDENTIAL PREMIER® RETIREMENT VARIABLE ANNUITY
(For Annuities issued on or after February 10, 2014)
Flexible Premium Deferred Annuity Offering Highest Daily Lifetime® Income v3.0 Optional Living Benefits and Legacy Protection Plus Optional Death Benefit
This prospectus describes a flexible premium deferred annuity contract (“Annuity”) offered by Pruco Life Insurance Company (“Pruco Life”, “we”, “our”, or “us”). The Annuity provides for the potential accumulation of retirement savings and retirement income through Annuitization. The Annuity is intended for retirement or other long-term investment purposes. This prospectus describes all material rights and obligations of Annuity Owners under the Annuity contracts.
If you are receiving this prospectus, it is because you currently own the Annuity. The Annuity is no longer offered for new sales. Please read this prospectus and retain it for future reference.
The Annuity or certain of its Investment Options and/or features may not be available in all states.
In compliance with U.S. law, Prudential Annuities delivers this prospectus to Annuity Owners that currently reside outside of the United States. In addition, we may not market or offer benefits, features, or enhancements to prospective or current Annuity Owners while outside of the United States.
These Annuities are NOT deposits or obligations of, or issued, guaranteed or endorsed by, any bank, are NOT insured or guaranteed by the U.S. government, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board or any other agency. An investment in an annuity involves investment risks, including possible loss of value.
THESE SECURITIES HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES COMMISSION NOR HAS THE COMMISSION OR ANY STATE SECURITIES COMMISSION PASSED UPON THE ACCURACY OR ADEQUACY OF THIS PROSPECTUS. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE.
Additional information about certain investment products, including variable annuities, has been prepared by the Securities and Exchange Commission’s staff and is available at www.investor.gov.
FOR FURTHER INFORMATION CALL 1-888-PRU-2888 OR VISIT: WWW.PRUDENTIAL.COM
Prospectus dated: [April___, 2022] Statement of Additional Information dated: [April___, 2022]
(For Annuities issued on or after February 10, 2014) (For Annuities issued on or after February 10, 2014)
PPRTB30DPROS
CONTENTS
GLOSSARY OF TERMS 1
KEY INFORMATION 4
OVERVIEW OF THE ANNUITY 6
FEE TABLE 7
PRINCIPAL RISKS OF INVESTING IN THE ANNUITY 9
INVESTMENT OPTIONS 10
WHAT ARE THE VARIABLE INVESTMENT OPTIONS? 10
MARKET VALUE ADJUSTMENT OPTION 10
MARKET VALUE ADJUSTMENT 10
RATES FOR DCA MARKET VALUE ADJUSTMENT OPTIONS 10
FEES, CHARGES AND DEDUCTIONS 12
DCA MARKET VALUE ADJUSTMENT OPTION CHARGES 16
EXCEPTIONS/REDUCTIONS TO FEES AND CHARGES 16
ANNUITY PAYMENT OPTION CHARGES 16
PURCHASING YOUR ANNUITY 17
REQUIREMENTS FOR PURCHASING THE ANNUITY 17
DESIGNATION OF OWNER, ANNUITANT AND BENEFICIARY 18
SCHEDULED PAYMENTS DIRECTLY FROM A BANK ACCOUNT 19
SALARY REDUCTION PROGRAMS 19
MANAGING YOUR ANNUITY 20
CHANGE OF OWNER, ANNUITANT AND BENEFICIARY DESIGNATIONS 20
MANAGING YOUR ACCOUNT VALUE 22
DOLLAR COST AVERAGING PROGRAMS 22
6 OR 12 MONTH DOLLAR COST AVERAGING PROGRAM (THE "6 OR 12 MONTH DCA PROGRAM") 22
AUTOMATIC REBALANCING PROGRAMS 23
FINANCIAL PROFESSIONAL PERMISSION TO REQUEST WITHDRAWALS AND FORWARD TRANSACTION INSTRUCTIONS 24
RESTRICTIONS ON TRANSFERS BETWEEN INVESTMENT OPTIONS 24
ACCESS TO ACCOUNT VALUE 26
TYPES OF DISTRIBUTIONS AVAILABLE TO YOU 26
TAX IMPLICATIONS FOR DISTRIBUTIONS FROM NON-QUALIFIED ANNUITIES 26
CHARGE FREE WITHDRAWAL AMOUNTS 26
SYSTEMATIC WITHDRAWALS FROM MY ANNUITY DURING THE ACCUMULATION PERIOD 27
SYSTEMATIC WITHDRAWALS UNDER SECTIONS 72(t)/72(q) OF THE INTERNAL REVENUE CODE 28
REQUIRED MINIMUM DISTRIBUTIONS 28
SURRENDERS 30
SURRENDER VALUE 30
MEDICALLY-RELATED SURRENDERS 30
ANNUITY OPTIONS 31
BENEFITS AVAILABLE UNDER THE ANNUITY 33
OPTIONAL LIVING BENEFITS 34
HIGHEST DAILY LIFETIME INCOME® v3.0 BENEFIT
36
SPOUSAL HIGHEST DAILY LIFETIME INCOME® v3.0 BENEFIT
49
DEATH BENEFITS 59
TRIGGERS FOR PAYMENT OF THE DEATH BENEFIT 59
EXCEPTIONS TO AMOUNT OF DEATH BENEFIT 59
MINIMUM DEATH BENEFI