SEC Company Response from ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I (CIK 0001085612) — Apr 16, 2021
ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I (CIK 0001085612)
Date: April 16, 2021 · CIK: 0001085612 · Accession: 0001628280-21-007087
AI Filing Summary & Sentiment
File numbers found in text: 333-114562, 811-09327
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Registration Statement on Form N-4 SEC File Nos. 333-114562 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, April 12, 2021 on the registration statement noted above, the Putnam Allstate Advisor Apex. 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: Correct name to proper name as used in SEC filings
Response: We have changed “The Putnam Allstate Advisor Apex Variable Annuity” to “Putnam Allstate Advisor Apex”.
2)Comment: Make sure all state variations are disclosed.
Response: Since this contract has not been sold for 18 years, we have deleted the second sentence in the second paragraph on page 1. We confirm that all state variations have been disclosed in Appendix F.
3)Comment: In the key information table, delete the row about Sales Charges Imposed on Purchase Payments and just add a sentence in the Transaction Charges row about the sales charge.
Response: We have deleted the first row and added the following at the end of the Transaction Charges description in the table: “In addition, you may incur sales charges imposed on purchase payments.”
Sonny Oh, Esq.
April 16, 2021
Page 2
4)Comment: Delete “Transfer Fee:” in the beginning of the description of the Transaction Charges in the key information table.
Response: We have made this deletion
5)Comment: Correct cross-references in the fees and expenses section of the key information table.
Response: We have deleted the references in the Charges for Early Withdrawals section for ‘Access to Your Money’ and ‘Income Payments’ and have left in “Expenses” as that section is where the primary disclosures are located with respect to Charges for Early Withdrawals.
6)Comment: Confirm the expenses shown for the Investment Options in the Ongoing Fees and Expenses information in the key information table are gross, before fee waivers.
Response: We have confirmed that the numbers shown are gross before fee waivers.
7)Comment: In the key information table, Ongoing Fees and Expenses section, in the smaller table in the “Optional benefits” row, put ‘for a single optional benefit, if elected’ in parentheses.
Response: We have added the parentheses.
8)Comment: In the Restrictions section of the table, change row heading from “Investment” to “Investments” and delete the 0.50% from the last line in the description.
Response: We have made these two corrections.
9)Comment: In the Optional Benefits section of the table, delete “to receive” from the second line.
Response: We have made this change.
10)Comment: In the Conflicts of Interest section of the table, change the section for “Investment Professional Compensation” to follow the correct language regarding financial incentives.
Response: We have changed the language to conform to what it should be by amending the first sentence and deleting the second sentence and replacing it as follows:
Some investment professionals may receive compensation for selling the Contracts to you in the form of commissions and other non-cash compensation (e.g., marketing allowances). Thus, these investment professionals may have a financial incentive to offer or recommend the Contracts over another investment.
11)Comment: In the Overview of the Contract chart, in the “Purpose” section, add the following disclosure: “The Contract is not intended for people who may need to make early or frequent withdrawals.”
Response: We have added this to the end of the first paragraph in that section.
Sonny Oh, Esq.
April 16, 2021
Page 3
12)Comment: In the expense table, confirm this part of footnote (2): “Currently assessed on Contracts that have total purchase payments of at least $1,000,000.”
Response: We have conferred with the product specifications and confirm that the charge is assessed on contracts of $1,000,000 or greater as stated.
13)Comment: In the introduction paragraph to the Annual Contract Expenses in the Expense Table section, delete “Company” in the second line.
Response: We have made the deletion.
14)Comment: In the Annual Contract Expenses table, in the line “Base Contract Expenses” replace ‘separate account’ with ‘variable account’
Response: We have made this change.
15)Comment: In the Annual Contract Expenses table, confirm there are no administrative fees in the base contract expenses.
Response: We can confirm that there are no administrative fees.
16)Comment: In the introduction paragraph to the Annual Portfolio Company Expenses, reference Appendix A as is required in the form.
Response: What we have as the introduction to the Annual Portfolio Company Expenses is taken from the new Form N-4. Here is what the Form states:
The next item shows the minimum and maximum total operating expenses charged by the Portfolio Companies that you may pay periodically during the time that you own the Contract. [These amounts also include applicable Platform Charges if you choose to invest in certain Portfolio Companies.] A complete list of Portfolio Companies available under the Contract, including their annual expenses, may be found at the back of this document.
This is what we have in the prospectus, except the parenthetical from the form is deleted as it is N/A. This is what we have:
The next item shows the minimum and maximum total operating expenses charged by the Portfolio Companies that you may pay periodically during the time that you own the Contract. A complete list of Portfolio Companies available under the Contract, including their annual expenses, may be found at the back of this document.
I checked and all of our other N-4’s have this same language in there.
17)Comment: in the Example at the end of the Expense Table section, you can combine these three rows into one since they are all the same numbers.
Response: We have combined these into one row and amended the row heading to incorporate all three scenarios.
18)Comment: You may delete the Trial Exam Period section on page 14 since this contract is no longer sold.
Sonny Oh, Esq.
April 16, 2021
Page 4
Response: We have deleted that section.
19)Comment: Confirm hyperlinks are working and they take the reader where they are supposed to go and contain the correct documents / information (ie: see page 17, end of third paragraph of the Investment Alternatives: The Variable Sub-Accounts section.
Response: For the SEC filing, we cannot use an external hyperlink or the filing will be suspended. (When hyperlink is typed out or copy/pasted into browser it will take you to the correct page.) We have confirmed that the hyperlinks are correct and working in the pdf version that will be available online to investors.
20)Comment: Page 23; Expenses section – Explain the Mortality and Expense Risk Charge in relation to the base contract charge and also add in language to explain that the charges described in that section are current charges.
Response: We added the following sentence to that section: The mortality and expense risk charge is included in the base contract expense as shown in the "Expense Table" section. To reflect that the charges shown in the listing in this section are current (versus maximum), we added “current” to the introduction sentence to the list to read: “We deduct a mortality and expense risk charge daily at the following current annual rates (as a percentage of daily net assets):”
21)Comment: Add in sections like the Retirement Income Guarantee Rider Charge for the Earnings Protection Death Benefit Option charges and the Enhanced Beneficiary Protection Option charges.
Response: We have added two sections for these benefit option charges below the Retirement Income Guarantee Rider Charge.
22)Comment: In the “Portfolio Expenses” section, please add the information for the Portfolio annual expenses.
Response: Just before the Appendix A reference in that paragraph, we have added in the following required sentence: “For a summary of Portfolio annual expenses, see the “Expense Table” section of this prospectus.”
23)Comment: In the Benefits Table, remove the “current fee” column
Response: In the new form, for that table (Item 10), instruction 6 states:
6. Current Fee. The Registrant may disclose the current charge in a separate column titled “Current Charge,” if the disclosure of the current charge is no more prominent than, and does not obscure or impede understanding of, the disclosure of the maximum charge.
We believe the table as it is conforms to the form instructions.
24)Comment: In the Benefits Table, make sure the names of the benefits are correctly shown, ie: the DCA should include ‘Basic’.
Sonny Oh, Esq.
April 16, 2021
Page 5
Response: We have corrected the name of the DCA to “Basic Dollar Cost Averaging Fixed Account Options.”
25)Comment: Make sure there are examples for the Basic DCA and the DCA 6 and 12 Month options.
Response: The examples are in Appendix E and we have added a 12 month example and Basic DCA example in addition to the 6 month example that was already shown.
26)Comment: In the Benefits Table, for the DCA, check the bullet points in the restrictions and limitations column and review if they all should be included or removed to the narrative section (if not already in there).
Response: We have added the following information to the narrative for the Basic Dollar Cost Averaging Fixed Account Option in the section “The Investment Alternatives: The Fixed Account Options”:
This Option is only available during Accumulation Phase
This Option is not available in Oregon or Washington
We have added the following information to the narrative for the 6 and 12 Month Dollar Cost Averaging Fixed Account Option in the section “The Investment Alternatives: The Fixed Account Options”:
You may not use Automatic Additions Program to allocate purchase payments to either of these Options.
This Option is not available in Oregon.
We have removed bullet #2 in the benefits table. We have confirmed that the other information in the bullets is now included in the narrative for each of the DCAs.
27)Comment: Benefits Table: Need an example for the Standard Death Benefit
Response: This was already included in Appendix C, but we fixed wording to make this clear. Slight calculation adjustment made in the Appendix C table. The existing example covers the sole moving part of the Standard Death benefit. The Death Benefit is the premium, adjusted for withdrawals, which this example illustrates.
28)Comment: In the Benefits Table: for the Enhanced Beneficiary Protection Option, the description in the table doesn’t really line up with the narrative on page 36. Include the bullet regarding withdrawals into the narrative description. Also need an example.
Response: We have amended the description to clarify this option to:
Provides the option for an increased death benefit equal to the Contract Value, plus interest at an annual rate of 5% per year until a specified time.
We have added the information about withdrawals in the fourth bullet for this option to the narrative for this option. The example calculation is in Appendix C.
29)Comment: The examples in Appendix B for the two Retirement Guarantee Options might need more details in the narrative. Please explain.
Sonny Oh, Esq.
April 16, 2021
Page 6
Response: From Calculation Management: There might be some confusion related to the two sets of RIG benefits (RIG 1 and RIG 2) which appear in this prospectus and in the Allstate Advisor prospectus. The naming convention of the benefits is generic. Therefore, the names are the same, but the benefits are different between the two books. The version for the RIG benefits in this book are much simpler than in the other book. Therefore, the examples are also simpler. We believe there is enough detail and narrative provided in the current examples.
30)Comment: In the “Income Plans” sub-section of the “Income Payments” section, add any transfer limitations after the payout start date.
Response: We have moved the information regarding transfers after the payout start date down one line to its own paragraph and added an italicized caption “Transfers:” All transfer limitations are noted in this section.
31)Comment: In the Income Plan 1 and Income Plan 3 sections, add disclosure as to who is paid after the annuitant dies.
Response: We have added the following to these sections: “If the sole surviving Contract Owner dies prior to the payment of all of the guaranteed income payments, the Primary Beneficiary will receive any guaranteed income payments scheduled to continue.”
32)Comment: Please confirm the accuracy of this statement, which is in the second paragraph after Income Plan 3 [emphasis added]:
For example, if you choose an Income Plan with payments that depend on the life of the Annuitant but with no minimum specified period for guaranteed payments, the income payments generally will be greater than the income payments made under the same Income Plan with a minimum specified period for guaranteed payments.
Response: We have deleted this paragraph and replaced it with an easier-to-understand description of the impact of frequency and duration on income payments. The new paragraph is:
Some of the factors that may affect the amount of the income payments include: your age, your Contract Value, the Income Plan selected (including the frequency and duration of payments under the Income Plan selected), number of guaranteed payments (if any) selected, and whether you select variable or fixed income payments. As a general rule, more frequent income payments will result in smaller individual income payments. Likewise, income payments that are anticipated over a longer period of time will also result in smaller individual income phase payments.
33)Comment: In the second paragraph above the “Variable Income Payments” Section the sentence containing the Performance Income Benefit Option, etc. appears N/A as these benefits do not appear in this product.
Response: We agree and have deleted this sentence as N/A.
34)Comment: In the “More Information” section under “The Variable Account” delete ‘Depositor’.
Sonny Oh, Esq.
April 16, 2021
Page 7
Response: We have deleted this.
35)Comment: Verify that the Tax section been updated
Response: Yes, the Tax section has been updated.
36)Comment: Appendix C: Make a cross-reference to the prospectus and make it clearer what this example is for.
Response: We have added the following to the narrative on page 35: “See Appendix C for an example of the Enhanced Beneficiary Protection withdrawal adjustment.” In Appendix C, we have also added “(see the benefit description in the Death Benefit section)” to point the reader to the narrative.
37)Comment: In the SAI, first page fourth paragraph, this needs to be edited to reflect that there is only one contract class.
Response: We have made this change so that it now reads [emphasis added here only] “…prospectus for the Contract, except as specifically noted.” instead of “…prospectus for each Contract that we offer, except as specifically noted.”
38)Comment: In the SAI, add in the section from the prospectus about the Net Investment Factor above the Calculation of Annuity Unit Values.
Response: We have added in that section.
39)Comment: In the Calculation of Annuity U
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CORRESP
1
filename1.htm
putnamapexcombo
[ALLSTATE LOGO]
April 16, 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. 27 to the
Registration Statement on Form N-4
SEC File Nos. 333-114562 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, April 12, 2021 on the registration statement noted above, the Putnam Allstate Advisor Apex. 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: Correct name to proper name as used in SEC filings
Response: We have changed “The Putnam Allstate Advisor Apex Variable Annuity” to “Putnam Allstate Advisor Apex”.
2)Comment: Make sure all state variations are disclosed.
Response: Since this contract has not been sold for 18 years, we have deleted the second sentence in the second paragraph on page 1. We confirm that all state variations have been disclosed in Appendix F.
3)Comment: In the key information table, delete the row about Sales Charges Imposed on Purchase Payments and just add a sentence in the Transaction Charges row about the sales charge.
Response: We have deleted the first row and added the following at the end of the Transaction Charges description in the table: “In addition, you may incur sales charges imposed on purchase payments.”
Sonny Oh, Esq.
April 16, 2021
Page 2
4)Comment: Delete “Transfer Fee:” in the beginning of the description of the Transaction Charges in the key information table.
Response: We have made this deletion
5)Comment: Correct cross-references in the fees and expenses section of the key information table.
Response: We have deleted the references in the Charges for Early Withdrawals section for ‘Access to Your Money’ and ‘Income Payments’ and have left in “Expenses” as that section is where the primary disclosures are located with respect to Charges for Early Withdrawals.
6)Comment: Confirm the expenses shown for the Investment Options in the Ongoing Fees and Expenses information in the key information table are gross, before fee waivers.
Response: We have confirmed that the numbers shown are gross before fee waivers.
7)Comment: In the key information table, Ongoing Fees and Expenses section, in the smaller table in the “Optional benefits” row, put ‘for a single optional benefit, if elected’ in parentheses.
Response: We have added the parentheses.
8)Comment: In the Restrictions section of the table, change row heading from “Investment” to “Investments” and delete the 0.50% from the last line in the description.
Response: We have made these two corrections.
9)Comment: In the Optional Benefits section of the table, delete “to receive” from the second line.
Response: We have made this change.
10)Comment: In the Conflicts of Interest section of the table, change the section for “Investment Professional Compensation” to follow the correct language regarding financial incentives.
Response: We have changed the language to conform to what it should be by amending the first sentence and deleting the second sentence and replacing it as follows:
Some investment professionals may receive compensation for selling the Contracts to you in the form of commissions and other non-cash compensation (e.g., marketing allowances). Thus, these investment professionals may have a financial incentive to offer or recommend the Contracts over another investment.
11)Comment: In the Overview of the Contract chart, in the “Purpose” section, add the following disclosure: “The Contract is not intended for people who may need to make early or frequent withdrawals.”
Response: We have added this to the end of the first paragraph in that section.
2
Sonny Oh, Esq.
April 16, 2021
Page 3
12)Comment: In the expense table, confirm this part of footnote (2): “Currently assessed on Contracts that have total purchase payments of at least $1,000,000.”
Response: We have conferred with the product specifications and confirm that the charge is assessed on contracts of $1,000,000 or greater as stated.
13)Comment: In the introduction paragraph to the Annual Contract Expenses in the Expense Table section, delete “Company” in the second line.
Response: We have made the deletion.
14)Comment: In the Annual Contract Expenses table, in the line “Base Contract Expenses” replace ‘separate account’ with ‘variable account’
Response: We have made this change.
15)Comment: In the Annual Contract Expenses table, confirm there are no administrative fees in the base contract expenses.
Response: We can confirm that there are no administrative fees.
16)Comment: In the introduction paragraph to the Annual Portfolio Company Expenses, reference Appendix A as is required in the form.
Response: What we have as the introduction to the Annual Portfolio Company Expenses is taken from the new Form N-4. Here is what the Form states:
The next item shows the minimum and maximum total operating expenses charged by the Portfolio Companies that you may pay periodically during the time that you own the Contract. [These amounts also include applicable Platform Charges if you choose to invest in certain Portfolio Companies.] A complete list of Portfolio Companies available under the Contract, including their annual expenses, may be found at the back of this document.
This is what we have in the prospectus, except the parenthetical from the form is deleted as it is N/A. This is what we have:
The next item shows the minimum and maximum total operating expenses charged by the Portfolio Companies that you may pay periodically during the time that you own the Contract. A complete list of Portfolio Companies available under the Contract, including their annual expenses, may be found at the back of this document.
I checked and all of our other N-4’s have this same language in there.
17)Comment: in the Example at the end of the Expense Table section, you can combine these three rows into one since they are all the same numbers.
Response: We have combined these into one row and amended the row heading to incorporate all three scenarios.
18)Comment: You may delete the Trial Exam Period section on page 14 since this contract is no longer sold.
3
Sonny Oh, Esq.
April 16, 2021
Page 4
Response: We have deleted that section.
19)Comment: Confirm hyperlinks are working and they take the reader where they are supposed to go and contain the correct documents / information (ie: see page 17, end of third paragraph of the Investment Alternatives: The Variable Sub-Accounts section.
Response: For the SEC filing, we cannot use an external hyperlink or the filing will be suspended. (When hyperlink is typed out or copy/pasted into browser it will take you to the correct page.) We have confirmed that the hyperlinks are correct and working in the pdf version that will be available online to investors.
20)Comment: Page 23; Expenses section – Explain the Mortality and Expense Risk Charge in relation to the base contract charge and also add in language to explain that the charges described in that section are current charges.
Response: We added the following sentence to that section: The mortality and expense risk charge is included in the base contract expense as shown in the "Expense Table" section. To reflect that the charges shown in the listing in this section are current (versus maximum), we added “current” to the introduction sentence to the list to read: “We deduct a mortality and expense risk charge daily at the following current annual rates (as a percentage of daily net assets):”
21)Comment: Add in sections like the Retirement Income Guarantee Rider Charge for the Earnings Protection Death Benefit Option charges and the Enhanced Beneficiary Protection Option charges.
Response: We have added two sections for these benefit option charges below the Retirement Income Guarantee Rider Charge.
22)Comment: In the “Portfolio Expenses” section, please add the information for the Portfolio annual expenses.
Response: Just before the Appendix A reference in that paragraph, we have added in the following required sentence: “For a summary of Portfolio annual expenses, see the “Expense Table” section of this prospectus.”
23)Comment: In the Benefits Table, remove the “current fee” column
Response: In the new form, for that table (Item 10), instruction 6 states:
6. Current Fee. The Registrant may disclose the current charge in a separate column titled “Current Charge,” if the disclosure of the current charge is no more prominent than, and does not obscure or impede understanding of, the disclosure of the maximum charge.
We believe the table as it is conforms to the form instructions.
24)Comment: In the Benefits Table, make sure the names of the benefits are correctly shown, ie: the DCA should include ‘Basic’.
4
Sonny Oh, Esq.
April 16, 2021
Page 5
Response: We have corrected the name of the DCA to “Basic Dollar Cost Averaging Fixed Account Options.”
25)Comment: Make sure there are examples for the Basic DCA and the DCA 6 and 12 Month options.
Response: The examples are in Appendix E and we have added a 12 month example and Basic DCA example in addition to the 6 month example that was already shown.
26)Comment: In the Benefits Table, for the DCA, check the bullet points in the restrictions and limitations column and review if they all should be included or removed to the narrative section (if not already in there).
Response: We have added the following information to the narrative for the Basic Dollar Cost Averaging Fixed Account Option in the section “The Investment Alternatives: The Fixed Account Options”:
This Option is only available during Accumulation Phase
This Option is not available in Oregon or Washington
We have added the following information to the narrative for the 6 and 12 Month Dollar Cost Averaging Fixed Account Option in the section “The Investment Alternatives: The Fixed Account Options”:
You may not use Automatic Additions Program to allocate purchase payments to either of these Options.
This Option is not available in Oregon.
We have removed bullet #2 in the benefits table. We have confirmed that the other information in the bullets is now included in the narrative for each of the DCAs.
27)Comment: Benefits Table: Need an example for the Standard Death Benefit
Response: This was already included in Appendix C, but we fixed wording to make this clear. Slight calculation adjustment made in the Appendix C table. The existing example covers the sole moving part of the Standard Death benefit. The Death Benefit is the premium, adjusted for withdrawals, which this example illustrates.
28)Comment: In the Benefits Table: for the Enhanced Beneficiary Protection Option, the description in the table doesn’t really line up with the narrative on page 36. Include the bullet regarding withdrawals into the narrative description. Also need an example.
Response: We have amended the description to clarify this option to:
Provides the option for an increased death benefit equal to the Contract Value, plus interest at an annual rate of 5% per year until a specified time.
We have added the information about withdrawals in the fourth bullet for this option to the narrative for this option. The example calculation is in Appendix C.
29)Comment: The examples in Appendix B for the two Retirement Guarantee Options might need more details in the narrative. Please explain.
5
Sonny Oh, Esq.
April 16, 2021
Page 6
Response: From Calculation Management: There might be some confusion related to the two sets of RIG benefits (RIG 1 and RIG 2) which appear in this prospectus and in the Allstate Advisor prospectus. The naming convention of the benefits is generic. Therefore, the names are the same, but the benefits are different between the two books. The version for the RIG benefits in this book are much simpler than in the other book. Therefore, the examples are also simpler. We believe there is enough detail and narrative provided in the current examples.
30)Comment: In the “Income Plans” sub-section of the “Income Payments” section, add any transfer limitations after the payout start date.
Response: We have moved the information regarding transfers after the payout start date down one line to its own paragraph and added an italicized caption “Transfers:” All transfer limitations are noted in this section.
31)Comment: In the Income Plan 1 and Income Plan 3 sections, add disclosure as to who is paid after the annuitant dies.
Response: We have added the following to these sections: “If the sole surviving Contract Owner dies prior to the payment of all of the guaranteed income payments, the Primary Beneficiary will receive any guaranteed income payments scheduled to continue.”
32)Comment: Please confirm the accuracy of this statement, which is in the second paragraph after Income Plan 3 [emphasis added]:
For example, if you choose an Income Plan with payments that depend on the life of the Annuitant but with no minimum specified period for guaranteed payments, the income payments generally will be greater than the income payments made under the same Income Plan with a minimum specified period for guaranteed payments.
Response: We have deleted this paragraph and replaced it with an easier-to-understand description of the impact of frequency and duration on income payments. The new paragraph is:
Some of the factors that may affect the amount of the income payments include: your age, your Contract Value, the Income Plan selected (including the frequency and duration of payments under the Income Plan selected), number of guaranteed payments (if any) selected, and whether you select variable or fixed income payments. As a general rule, more frequent income payments will result in smaller individual income payments. Likewise, income payments that are anticipated over a longer period of time will also result in smaller individual income phase payments.
33)Comment: In the second paragraph above the “Variable Income Payments” Section the sentence containing the Performance Income Benefit Option, etc. appears N/A as these benefits do not appear in this product.
Response: We agree and have deleted this sentence as N/A.
34)Comment: In the “More Information” section under “The Variable Account” delete ‘Depositor’.
6
Sonny Oh, Esq.
April 16, 2021
Page 7
Response: We have deleted this.
35)Comment: Verify that the Tax section been updated
Response: Yes, the Tax section has been updated.
36)Comment: Appendix C: Make a cross-reference to the prospectus and make it clearer what this example is for.
Response: We have added the following to the narrative on page 35: “See Appendix C for an example of the Enhanced Beneficiary Protection withdrawal adjustment.” In Appendix C, we have also added “(see the benefit description in the Death Benefit section)” to point the reader to the narrative.
37)Comment: In the SAI, first page fourth paragraph, this needs to be edited to reflect that there is only one contract class.
Response: We have made this change so that it now reads [emphasis added here only] “…prospectus for the Contract, except as specifically noted.” instead of “…prospectus for each Contract that we offer, except as specifically noted.”
38)Comment: In the SAI, add in the section from the prospectus about the Net Investment Factor above the Calculation of Annuity Unit Values.
Response: We have added in that section.
39)Comment: In the Calculation of Annuity U