SEC Company Response from ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I (CIK 0001085612) — Mar 9, 2021
ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I (CIK 0001085612)
Date: March 9, 2021 · CIK: 0001085612 · Accession: 0001628280-21-004232
AI Filing Summary & Sentiment
File numbers found in text: 333-114560, 811-09327
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Registration Statement on Form N-4 SEC File Nos. 333-114560 and 811-09327 Allstate Financial Advisors Separate Account I (Registrant) Allstate Life Insurance Company (Depositor)
Dear Mr. Oh:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on Monday, November 23, 2020 on the registration statement noted above, and in bold are the additional comments received orally from Staff on Monday February 22, 2021. Included in this submission are a revised prospectus and Statement of Additional Information which are marked to show the changes described below. Also included is a revised Part C.
The Staff’s comments and our responses are as follows:
1.Comment: Supplement: Delete of change the supplement to make it relevant to 2021.
Response: We have deleted the supplement.
2.Comment: Cover Page: Use all defined terms consistently; e.g.: “Allstate Life” “Contract” “Investment Alternatives”
Response: We have made revisions throughout the document to make terms consistent.
3.Comment: Cover Page: Use the full official name of the contract in the definition of the contract.
Response: Full name has been added to the definition of contract.
4.Comment: Cover Page: The last two lines look like they need to go somewhere else.
Response: The two lines were supposed to be a footnote to the definition of “Contract” and has been corrected.
Sonny Oh, Esq.
March 9, 2021
Page 2
4A. NEW Comment: The cover page of the prospectus and the overview of the contract sections need additional disclosure related to the bonus (credit enhancement) that it may be recaptured upon free look, withdrawal, surrender, annuitization or death.
Response: We have amended the related paragraph on the cover page to read as follows:
For the Allstate Advisor Plus Contracts with the Credit Enhancement, Please note that the expenses for the Allstate Advisor Plus Contracts with the Credit Enhancement may be higher than for contracts without a Credit Enhancement, and the amount of the Credit Enhancement may be more than offset by the additional fees and charges associated with the Allstate Advisor Plus Contract, and the withdrawal charge period is longer. In certain circumstances (such as death, annuitization, or surrendering your contract within a few years of purchasing it, or upon cancellation during the Trial Examination Period) we may recapture the Credit Enhancement.
This paragraph has also been added to the first section of the “Overview of the Contract” table.
4B. Comment: If the bonus can be recaptured upon withdrawal or surrender, briefly state this in the early withdrawal section of the key information table.
Response: We have added the following sentence to the Allstate Advisor Plus paragraph in the Charges for Early Withdrawals section of the key information table:
In certain circumstances, we may recapture the Credit Enhancement upon withdrawal or surrender.
4C. Comment: For the ongoing fee and expenses item, confirm that lowest and highest annual cost does not reflect any bonus amount.
Response: The costs shown do not reflect any bonus (credit enhancement).
4D. Comment: Bonuses should be discussed as a principal risk including that the amount of the bonus may be more than offset by additional fees and charges associated with the bonus contract, the impact of any recapture provision for free look, withdrawal, surrender, annuitization or death benefit value and also the impact of bonuses on optional benefits, for example if they are excluded from a benefit amount. If bonus amounts are excluded from any contract benefit, disclose in the benefit table as a restriction or limitation.
Response: We have added the Credit Enhancement disclosure paragraph (see comment 4A for the paragraph language) under the “Not a Short-Term Investment” section of the Principal Risks section to address this. We have confirmed that any credit enhancements are not excluded from benefits, and benefits are increased by the credits.
5.Comment: Page 1: Is such a lengthy glossary necessary?
Sonny Oh, Esq.
March 9, 2021
Page 3
Response: We have shortened the glossary by primarily removing terms that are relevant only to optional benefits.
Comment: Include definition for “Good Order” and you can delete the definitions for Right to Cancel and Trial Examination Period.
Response: We have made these changes.
6.Comment: Page 6: Delete footnote in “Charges for Early Withdrawals” section
Response: The footnote has been deleted.
7.Comment: Page 6: Use “Investment Alternatives” not investment options - universal change throughout the prospectus.
Response: We have made this change throughout
Comment: Change “Investment Alternatives” to “Investment Options” in the Ongoing Fees and Expenses section, and the title columns of the Risks table and Restrictions Table.
Response: We have made these edits
8.Comment: Page 6: Use “Data Page” versus specifications page - universal change throughout the prospectus.
Response: We have made this change throughout.
9.Comment: Page 7: Make sure the base contract expense reflects the $30 annual charge as a percentage and is included; incorporate this into previous page fees and expenses table. Make sure the table is one combined table and not separated out.
Response: We have added the annual charge as required. We have checked to confirm the formatting of the table.
Comment: Confirm the base contract expenses
Response: We have confirmed with Calculation Management that the expenses are correct and do not reflect any credit enhancement amounts.
Comment: Confirm the Investment Option expenses are accurate for the three versions of the contract – do they need to be broken out for each class?
Response: We have confirmed with Calculation Management that there is only one min/max charge for this prospectus – including all classes.
10.Comment: Page 7: Add “(as a percentage of Separate Account Assets)”
Response: Parenthetical added
11.Comment: Page 7: Combine the break outs for the three Allstate Advisor Preferred options into just one line – overall minimum and maximum. Say “(varies by class)”.
Response: These changes have been made.
12.Comment: Page 7: Double check fee ranges to other tables; For Allstate Advisor Preferred, combine the three options into one.
Sonny Oh, Esq.
March 9, 2021
Page 4
Response: We have confirmed the fees and corrected where needed. Allstate Advisor Preferred now shows one line not three.
13.Comment: Page 7: Add “(for a single optional benefit if elected)”
Response: Change made
14.Comment: Page 7: The paragraph below the * footnote is the introduction paragraph for the next table; Bold the sentence "This estimate assumes…which could substantially increase costs"
Response: We have corrected the formatting and bolded the referenced sentence.
15.Comment: Page 7: Add “(in dollars)” to first column title; For Allstate Advisor Preferred, just do one line item for the contract; In assumptions sections, change “combination of Contract charges” to “combination of Contract classes”.
Response: These changes have been made
Comment: Need to add in the dollar amounts
Response: These will be added when the amounts are known, at the end of March.
16.Comment: Page 7: In “Risk of Loss” row, reference Principal Risks section instead of Important Notices
Response: This change has been made
17.Comment: Page 7: “Funds” or “Portfolios” - just use one – universal change throughout the prospectus.
Response: We have deleted “Funds” and just use “Portfolios” throughout.
18.Comment: Page 8: Add disclosure: “Withdrawals that exceed limits specified by the terms of an optional benefit may affect the availability of the benefit by reducing the benefit by an amount greater than the value withdrawn, and/or could terminate the benefit.”
Response: We have added this disclosure
19.Comment: Page 9: Use “Contract” not “Policy” - universal change throughout prospectus; Second paragraph, indicate that the investor may incur additional fees for choosing a particular benefit, as summarized below.
Response: We have made a global change to remove “Policy” and use “Contract”; added “An investor may incur additional fees for choosing a particular benefit, as summarized below.” to the end of the second paragraph in the “Purpose” section.
Comment: This did not appear to be added
Response: We have added this to the end of the second paragraph in the “Purpose” section.
20.Comment: Page 9: Bold: “Additional information about each Portfolio is provided in Appendix A to this prospectus.”
Sonny Oh, Esq.
March 9, 2021
Page 5
Response: The sentence has been bolded.
Comment: This was not bolded
Response: This sentence has been bolded.
21.Comment: Page 10: Make sure this table is part of the above table
Response: We have verified the formatting to ensure the table is all one.
22.Comment: Page 10: Add "at no additional charge" to the Portfolio Rebalancing and Systematic Withdrawal Program.
Response: These have been added.
23.Comment: Page 11: Delete the second paragraph under “Expense Table”; Under “Transaction Expenses” delete “Sales load imposed on…”
Response: These deletions have been made
24.Comment: Page 11: Make the additional information about the withdrawal charges in a footnote and smaller font
Response: We have corrected the formatting for this
25.Comment: Page 12: Maximum column should be first; minimum should be called ‘current’ and come second; “Mortality and Expense Risk Charge” should be “Base Contract Expenses” and include the administrative charge.
Response: We have reformatted the columns and corrected the base contract expenses.
Comment: Footnote 2 change M&E reference to base contract charge.
Response: We have made this change
26.Comment: Page 12: Add “(as a percentage of [appropriate factor])”
Response: We have added this information
Comment: Delete the reference parenthetical to the contract maintenance charge
Response: This has been deleted
27.Comment: Page 12: Clarify which optional benefits cannot be held at the same time; make sure all optional benefits are broken out by expenses; For the SureIncome option, incorporate the three different cost structures. Add Sure Income ROP death benefit too.
Response: We have added a footnote for the True Return option stating it cannot be combined with any other living benefits. The three cost structures for the SureIncome option have been added. For the ROP Death Benefit, we have reviewed the SureIncome riders and note that the SureIncome ROP is part of those two riders – it is not stand alone, and there is no extra fee for it.
Comment: Clarify which optional benefits are no longer available and let the reviewer know.
Response: As shown in footnote (6) only RIG 1 and RIG 2 are no longer available.
Sonny Oh, Esq.
March 9, 2021
Page 6
28.Comment: Page 12: Disclose what features and options are in the example; and note that example is $100k, so add a zero at end of the numbers
Response: We have added the features and options shown in the example and corrected the numbers.
29.Comment: Page 13: Connect last three tables for Allstate Advisor Preferred
Response: We have changed the formatting
30.Comment: Page 14: Make sure all risks are shown - include the ones from page 5.
Response: We have copied and pasted the risks from page 5.
31.Comment: Page 18: Confirm that contract owners who have this now can receive the credit enhancements – and add to page 10 policy features item 10c
Response: Yes, we have confirmed this and it is accurately reflected in the referenced section.
32.Comment: Page 19: Can delete the first paragraph after the credit enhancement table since it is N/A now
Response: We have deleted the paragraph “If you exercise your right…”
33.Comment: Page 19: Confirm that all material state variations are disclosed
Response: Yes, all material state variations are disclosed.
34.Comment: Page 25: Group similar benefits together and organize this section better; use footnotes to state when benefits were altered.
Response: We have re-organized the table and added appropriate footnotes.
35.Comment: Page 25: In the “Brief Description of Restrictions or Limitations” column, be more brief, for example, simply say “Must meet certain criteria to be considered confined to a long term care facility and provide proof of confinement.”
Response: We have shortened the longer descriptions to be more brief.
36.Comment: Page 21: The current charge needs to be in a separate column; change the title of the “Maximum/Current Fee” column to only “Maximum Fee”; and for all of the ones that show a fee add “(as a percentage of [appropriate factor])”
Response: We have added a “Current Fee” column and corrected the title of the Maximum Fee column. We have added “(as a percentage of [appropriate factor])” where needed.
37.Comment: Page 22: Only show one max charge for a benefit - do not separated them out by age.
Response: We have made this correction
Comment: For the Earnings Protection Death Benefit Option, just show one change and delete the information about charges based on age
Response: This has been deleted and now just reflects one charge
Sonny Oh, Esq.
March 9, 2021
Page 7
38.Comment: Page 23: Delete parentheticals for each of the charges
Response: We have deleted these
39.Comment: Page 24: SureIncome ROP: Just show the maximum - the highest, not for all ages.
Response: We have made this change.
Comment: For the Return of Premium Death Benefit, add to the limitations column that it is only offered as part of the SureIncome options and state which SureIncome benefits it is included with.
Response: We have added this information.
40.Comment: Page 24: TrueReturn Accumulation Benefit Option: Is the last sentence correct regarding Premiums in the first 12 rider months? Double check and be consistent in rest of prospectus
Response: Yes, we checked and the sentence is correct. We have verified the rest of the prospectus.
41.Comment: Page 25: Put the SAI information in here for the AUV sections.
Response: AUV calculation information taken from the SAI and included in this section now.
42.Make sure to discuss fees and costs associated with all optional benefits; Include examples for all major benefits as to how they operate
Response: We have included the optional benefits fees and expenses and have examples as Appendices.
Comment: Make sure examples of all benefits are included, e.g.: DCA, portfolio rebalancing, etc. are included
Response: We have added an Appendix D which contains examples of the DCA accounts, automatic portfolio rebalancing, systematic withdrawals and automatic additions program and have referenced the appendix in the narrative.
Comment: RIG 1 and 2 and Enhanced Beneficiary Protection Options need edits and more detail
Response: We have included more detail on how the calculations are arrived at.
43.Comment: Page 43: “Appendix A” not “XXX”
Response: This has been corrected throughout the prospectus
44.Comment: Page 43: Delete the sentence 'we will mail you...'
Response: This has been deleted
Sonny Oh, Esq.
March 9, 2021
Page 8
45.Comment: Page 46: Reference here to Appendix A is not correct. Fix this and do a global check to make sure Appendix references are correct.
Response: We have made this change and have corrected all Appendix references.
46.Comment: Page 46: State what the actual true lowest minimum is;
Response: We have added the actual rate.
47.Comment: Page 47: Correct Appendi
Show Raw Text
CORRESP
1
filename1.htm
combo
[ALLSTATE LOGO]
March 9, 2021
VIA EDGAR
Sonny Oh, Esq.
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 Post-Effective Amendment No. 21 to the
Registration Statement on Form N-4
SEC File Nos. 333-114560 and 811-09327
Allstate Financial Advisors Separate Account I (Registrant)
Allstate Life Insurance Company (Depositor)
Dear Mr. Oh:
On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on Monday, November 23, 2020 on the registration statement noted above, and in bold are the additional comments received orally from Staff on Monday February 22, 2021. Included in this submission are a revised prospectus and Statement of Additional Information which are marked to show the changes described below. Also included is a revised Part C.
The Staff’s comments and our responses are as follows:
1.Comment: Supplement: Delete of change the supplement to make it relevant to 2021.
Response: We have deleted the supplement.
2.Comment: Cover Page: Use all defined terms consistently; e.g.: “Allstate Life” “Contract” “Investment Alternatives”
Response: We have made revisions throughout the document to make terms consistent.
3.Comment: Cover Page: Use the full official name of the contract in the definition of the contract.
Response: Full name has been added to the definition of contract.
4.Comment: Cover Page: The last two lines look like they need to go somewhere else.
Response: The two lines were supposed to be a footnote to the definition of “Contract” and has been corrected.
Sonny Oh, Esq.
March 9, 2021
Page 2
4A. NEW Comment: The cover page of the prospectus and the overview of the contract sections need additional disclosure related to the bonus (credit enhancement) that it may be recaptured upon free look, withdrawal, surrender, annuitization or death.
Response: We have amended the related paragraph on the cover page to read as follows:
For the Allstate Advisor Plus Contracts with the Credit Enhancement, Please note that the expenses for the Allstate Advisor Plus Contracts with the Credit Enhancement may be higher than for contracts without a Credit Enhancement, and the amount of the Credit Enhancement may be more than offset by the additional fees and charges associated with the Allstate Advisor Plus Contract, and the withdrawal charge period is longer. In certain circumstances (such as death, annuitization, or surrendering your contract within a few years of purchasing it, or upon cancellation during the Trial Examination Period) we may recapture the Credit Enhancement.
This paragraph has also been added to the first section of the “Overview of the Contract” table.
4B. Comment: If the bonus can be recaptured upon withdrawal or surrender, briefly state this in the early withdrawal section of the key information table.
Response: We have added the following sentence to the Allstate Advisor Plus paragraph in the Charges for Early Withdrawals section of the key information table:
In certain circumstances, we may recapture the Credit Enhancement upon withdrawal or surrender.
4C. Comment: For the ongoing fee and expenses item, confirm that lowest and highest annual cost does not reflect any bonus amount.
Response: The costs shown do not reflect any bonus (credit enhancement).
4D. Comment: Bonuses should be discussed as a principal risk including that the amount of the bonus may be more than offset by additional fees and charges associated with the bonus contract, the impact of any recapture provision for free look, withdrawal, surrender, annuitization or death benefit value and also the impact of bonuses on optional benefits, for example if they are excluded from a benefit amount. If bonus amounts are excluded from any contract benefit, disclose in the benefit table as a restriction or limitation.
Response: We have added the Credit Enhancement disclosure paragraph (see comment 4A for the paragraph language) under the “Not a Short-Term Investment” section of the Principal Risks section to address this. We have confirmed that any credit enhancements are not excluded from benefits, and benefits are increased by the credits.
5.Comment: Page 1: Is such a lengthy glossary necessary?
2
Sonny Oh, Esq.
March 9, 2021
Page 3
Response: We have shortened the glossary by primarily removing terms that are relevant only to optional benefits.
Comment: Include definition for “Good Order” and you can delete the definitions for Right to Cancel and Trial Examination Period.
Response: We have made these changes.
6.Comment: Page 6: Delete footnote in “Charges for Early Withdrawals” section
Response: The footnote has been deleted.
7.Comment: Page 6: Use “Investment Alternatives” not investment options - universal change throughout the prospectus.
Response: We have made this change throughout
Comment: Change “Investment Alternatives” to “Investment Options” in the Ongoing Fees and Expenses section, and the title columns of the Risks table and Restrictions Table.
Response: We have made these edits
8.Comment: Page 6: Use “Data Page” versus specifications page - universal change throughout the prospectus.
Response: We have made this change throughout.
9.Comment: Page 7: Make sure the base contract expense reflects the $30 annual charge as a percentage and is included; incorporate this into previous page fees and expenses table. Make sure the table is one combined table and not separated out.
Response: We have added the annual charge as required. We have checked to confirm the formatting of the table.
Comment: Confirm the base contract expenses
Response: We have confirmed with Calculation Management that the expenses are correct and do not reflect any credit enhancement amounts.
Comment: Confirm the Investment Option expenses are accurate for the three versions of the contract – do they need to be broken out for each class?
Response: We have confirmed with Calculation Management that there is only one min/max charge for this prospectus – including all classes.
10.Comment: Page 7: Add “(as a percentage of Separate Account Assets)”
Response: Parenthetical added
11.Comment: Page 7: Combine the break outs for the three Allstate Advisor Preferred options into just one line – overall minimum and maximum. Say “(varies by class)”.
Response: These changes have been made.
12.Comment: Page 7: Double check fee ranges to other tables; For Allstate Advisor Preferred, combine the three options into one.
3
Sonny Oh, Esq.
March 9, 2021
Page 4
Response: We have confirmed the fees and corrected where needed. Allstate Advisor Preferred now shows one line not three.
13.Comment: Page 7: Add “(for a single optional benefit if elected)”
Response: Change made
14.Comment: Page 7: The paragraph below the * footnote is the introduction paragraph for the next table; Bold the sentence "This estimate assumes…which could substantially increase costs"
Response: We have corrected the formatting and bolded the referenced sentence.
15.Comment: Page 7: Add “(in dollars)” to first column title; For Allstate Advisor Preferred, just do one line item for the contract; In assumptions sections, change “combination of Contract charges” to “combination of Contract classes”.
Response: These changes have been made
Comment: Need to add in the dollar amounts
Response: These will be added when the amounts are known, at the end of March.
16.Comment: Page 7: In “Risk of Loss” row, reference Principal Risks section instead of Important Notices
Response: This change has been made
17.Comment: Page 7: “Funds” or “Portfolios” - just use one – universal change throughout the prospectus.
Response: We have deleted “Funds” and just use “Portfolios” throughout.
18.Comment: Page 8: Add disclosure: “Withdrawals that exceed limits specified by the terms of an optional benefit may affect the availability of the benefit by reducing the benefit by an amount greater than the value withdrawn, and/or could terminate the benefit.”
Response: We have added this disclosure
19.Comment: Page 9: Use “Contract” not “Policy” - universal change throughout prospectus; Second paragraph, indicate that the investor may incur additional fees for choosing a particular benefit, as summarized below.
Response: We have made a global change to remove “Policy” and use “Contract”; added “An investor may incur additional fees for choosing a particular benefit, as summarized below.” to the end of the second paragraph in the “Purpose” section.
Comment: This did not appear to be added
Response: We have added this to the end of the second paragraph in the “Purpose” section.
20.Comment: Page 9: Bold: “Additional information about each Portfolio is provided in Appendix A to this prospectus.”
4
Sonny Oh, Esq.
March 9, 2021
Page 5
Response: The sentence has been bolded.
Comment: This was not bolded
Response: This sentence has been bolded.
21.Comment: Page 10: Make sure this table is part of the above table
Response: We have verified the formatting to ensure the table is all one.
22.Comment: Page 10: Add "at no additional charge" to the Portfolio Rebalancing and Systematic Withdrawal Program.
Response: These have been added.
23.Comment: Page 11: Delete the second paragraph under “Expense Table”; Under “Transaction Expenses” delete “Sales load imposed on…”
Response: These deletions have been made
24.Comment: Page 11: Make the additional information about the withdrawal charges in a footnote and smaller font
Response: We have corrected the formatting for this
25.Comment: Page 12: Maximum column should be first; minimum should be called ‘current’ and come second; “Mortality and Expense Risk Charge” should be “Base Contract Expenses” and include the administrative charge.
Response: We have reformatted the columns and corrected the base contract expenses.
Comment: Footnote 2 change M&E reference to base contract charge.
Response: We have made this change
26.Comment: Page 12: Add “(as a percentage of [appropriate factor])”
Response: We have added this information
Comment: Delete the reference parenthetical to the contract maintenance charge
Response: This has been deleted
27.Comment: Page 12: Clarify which optional benefits cannot be held at the same time; make sure all optional benefits are broken out by expenses; For the SureIncome option, incorporate the three different cost structures. Add Sure Income ROP death benefit too.
Response: We have added a footnote for the True Return option stating it cannot be combined with any other living benefits. The three cost structures for the SureIncome option have been added. For the ROP Death Benefit, we have reviewed the SureIncome riders and note that the SureIncome ROP is part of those two riders – it is not stand alone, and there is no extra fee for it.
Comment: Clarify which optional benefits are no longer available and let the reviewer know.
Response: As shown in footnote (6) only RIG 1 and RIG 2 are no longer available.
5
Sonny Oh, Esq.
March 9, 2021
Page 6
28.Comment: Page 12: Disclose what features and options are in the example; and note that example is $100k, so add a zero at end of the numbers
Response: We have added the features and options shown in the example and corrected the numbers.
29.Comment: Page 13: Connect last three tables for Allstate Advisor Preferred
Response: We have changed the formatting
30.Comment: Page 14: Make sure all risks are shown - include the ones from page 5.
Response: We have copied and pasted the risks from page 5.
31.Comment: Page 18: Confirm that contract owners who have this now can receive the credit enhancements – and add to page 10 policy features item 10c
Response: Yes, we have confirmed this and it is accurately reflected in the referenced section.
32.Comment: Page 19: Can delete the first paragraph after the credit enhancement table since it is N/A now
Response: We have deleted the paragraph “If you exercise your right…”
33.Comment: Page 19: Confirm that all material state variations are disclosed
Response: Yes, all material state variations are disclosed.
34.Comment: Page 25: Group similar benefits together and organize this section better; use footnotes to state when benefits were altered.
Response: We have re-organized the table and added appropriate footnotes.
35.Comment: Page 25: In the “Brief Description of Restrictions or Limitations” column, be more brief, for example, simply say “Must meet certain criteria to be considered confined to a long term care facility and provide proof of confinement.”
Response: We have shortened the longer descriptions to be more brief.
36.Comment: Page 21: The current charge needs to be in a separate column; change the title of the “Maximum/Current Fee” column to only “Maximum Fee”; and for all of the ones that show a fee add “(as a percentage of [appropriate factor])”
Response: We have added a “Current Fee” column and corrected the title of the Maximum Fee column. We have added “(as a percentage of [appropriate factor])” where needed.
37.Comment: Page 22: Only show one max charge for a benefit - do not separated them out by age.
Response: We have made this correction
Comment: For the Earnings Protection Death Benefit Option, just show one change and delete the information about charges based on age
Response: This has been deleted and now just reflects one charge
6
Sonny Oh, Esq.
March 9, 2021
Page 7
38.Comment: Page 23: Delete parentheticals for each of the charges
Response: We have deleted these
39.Comment: Page 24: SureIncome ROP: Just show the maximum - the highest, not for all ages.
Response: We have made this change.
Comment: For the Return of Premium Death Benefit, add to the limitations column that it is only offered as part of the SureIncome options and state which SureIncome benefits it is included with.
Response: We have added this information.
40.Comment: Page 24: TrueReturn Accumulation Benefit Option: Is the last sentence correct regarding Premiums in the first 12 rider months? Double check and be consistent in rest of prospectus
Response: Yes, we checked and the sentence is correct. We have verified the rest of the prospectus.
41.Comment: Page 25: Put the SAI information in here for the AUV sections.
Response: AUV calculation information taken from the SAI and included in this section now.
42.Make sure to discuss fees and costs associated with all optional benefits; Include examples for all major benefits as to how they operate
Response: We have included the optional benefits fees and expenses and have examples as Appendices.
Comment: Make sure examples of all benefits are included, e.g.: DCA, portfolio rebalancing, etc. are included
Response: We have added an Appendix D which contains examples of the DCA accounts, automatic portfolio rebalancing, systematic withdrawals and automatic additions program and have referenced the appendix in the narrative.
Comment: RIG 1 and 2 and Enhanced Beneficiary Protection Options need edits and more detail
Response: We have included more detail on how the calculations are arrived at.
43.Comment: Page 43: “Appendix A” not “XXX”
Response: This has been corrected throughout the prospectus
44.Comment: Page 43: Delete the sentence 'we will mail you...'
Response: This has been deleted
7
Sonny Oh, Esq.
March 9, 2021
Page 8
45.Comment: Page 46: Reference here to Appendix A is not correct. Fix this and do a global check to make sure Appendix references are correct.
Response: We have made this change and have corrected all Appendix references.
46.Comment: Page 46: State what the actual true lowest minimum is;
Response: We have added the actual rate.
47.Comment: Page 47: Correct Appendi