Correspondence 0001128415-24-000003 from JACKSON NATIONAL LIFE INSURANCE CO OF NEW YORK (CIK 0001128415)
JACKSON NATIONAL LIFE INSURANCE CO OF NEW YORK (CIK 0001128415)
Date: March 5, 2024 · CIK: 0001128415 · Accession: 0001128415-24-000003
AI Filing Summary & Sentiment
File numbers found in text: 333-268464, 333-268466
Letter
nyrilasecresponsecombined
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 5, 2024
SUBJECT: Response to Comments for Initial Registration Statements filed on Form S-1 for File No. 333-268464 (Jackson Market Link Pro II); File No. 333-268466 (Jackson Market Link Pro Advisory II)
This memorandum is in response to the comments you provided via telephone on February 14, 2024 for the above referenced filings.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific comments, followed respectively by narrative responses (in bold).
Unless indicated otherwise below, the following comments and responses apply to all registration statements referenced above. Marked, excerpted pages of each prospectus, revised to reflect the changes discussed below, are filed herewith. Courtesy copies of both clean and marked copies of the prospectuses for each product will also be provided via electronic mail. Page references in the responses below are to the prospectus page number of the marked courtesy copy of the Jackson Market Link Pro II prospectus, unless indicated otherwise. Corresponding changes will be made to the Jackson Market Link Pro Advisory II prospectus as applicable. Additional pre-effective amendments to the registration statements will subsequently be filed in response to these comments.
Cover Page
1.Please add the following disclosure: 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 [ ]% 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.
Response: We have made this revision.
2.Please prominently disclose that the company could limit positive index gain and the maximum potential loss as a percentage that an investor could experience from negative index performance.
a.With respect to maximum potential loss: language could be similar to saying the contract currently offers options that offer buffers of -10 to -20 so loses could be up to 80-90% due to poor index performance.
Response: We have made this revision.
b.Please add that index options and downside options could change in the future. State that buffers will always be at least -5%.
Response: We have made this revision.
Summary (pp. 1-6)
3.Throughout this section and the prospectus, the disclosures reference both Protection Option and Protection Options. Please be consistent, check the tense used, and consider whether simply using "Buffer” or “Buffer Protection Option” would be clearer since the Buffer is the only Protection Option offered on the contract.
Response: We have made this revision.
4.When referencing guaranteed minimum Index Adjustment Factors, please make it clear early on and consistently that the client receives the greater of prorated or guaranteed minimums. Consider consistently referring to prorated Index Adjustment Factors as non-guaranteed prorated Index Adjustment Factors.
Response: We have made this revision.
5.In the subsection titled "Crediting Methods", consider dropping the parenthesis around Index Participation Rate (“Cap Rate with an IPR and the Performance Trigger…”).
Response: We have made this revision.
6.If there is a minimum cap rate, please include in the summary.
Response: We have made this revision.
7.Please move disclosures regarding IPR not being a stand-alone method and include as the last bullet point of cap crediting method disclosures in the summary.
Response: We have made this revision.
8.In the subsection titled “Protection Options”, please revise consistently with your response to comment 3.
Response: We have made this revision.
9.In the subsection titled “Interim Value Adjustment:
a.In the first sentence of the second paragraph, please review the description of prorated and guaranteed minimum Index Adjustment Factors and consider revising to use “either/or” rather than “and”.
Response: We have made this revision.
b.In the third paragraph, please note that the Staff prefers this usage of "(non-guaranteed) prorated" in the discussion of the prorated and guaranteed minimum Index Adjustment Factors. Consider revising this disclosure to a single sentence to simplify. For example, "When calculating your Interim Value, we will apply the greater of the (non-guaranteed) prorated Index Adjustment Factors or the guaranteed minimum Index Adjustment Factors”.
Response: We have made this revision.
10.The following comments address the “Contract Overview” table in the Summary section of the prospectus:
a.In the row titled "Intra-Term Performance Lock", consider simplifying by revising the first sentence to specify the Cap Index Account Option and deleting the final sentence before the cross-reference.
Response: We have made this revision.
b.In the row titled “Access to your Money”, you refer to the Free Withdrawal amount in the last sentence. Please consider defining “Free Withdrawal”.
Response: We have made this revision.
c.In the row titled “Income Options”, please review the third sentence of the first paragraph to see if this sentence should be deleted.
Response: We have made this revision.
Risk Factors (pp. 10-13)
11.In the subsection titled “Reallocations”, please relocate the second to last sentence to avoid locating it between two cross references.
Response: We have made this revision.
12.In the subsection titled “Buffers”, please revise the second sentence to “[w]hen you select the buffer” rather than when you "elect" since the Buffer is the only Protection Option available.
Response: We have made this revision.
Glossary (pp. 7-9)
13.In the definition for “Index Adjustment Factors”, please consider mentioning the application of non-guaranteed prorated or guaranteed minimum Index Adjustment Factors. If the Glossary definitions are ultimately kept at a high level with more detailed disclosure elsewhere in the prospectus, consider adding a sentence that simply notes that Index Adjustment Factors apply at the end of the Term, and prior to the end of the Term you will apply the greater of prorated or guaranteed minimum Index Adjustment Factors.
Response: We have revised the Glossary definitions to be more high level, including detailed information in the body of the prospectus. In connection with these revisions, we have removed similar disclosure from the Index Adjustment definition, and opted not to incorporate this suggested revision to the Index Adjustment Factors definition.
14.For the term “Protection Option”, please consider removing definition/defined term.
Response: We have retained this definition, with revisions. This terminology is used throughout all of our RILA product prospectuses and marketing collateral to help investors better understand the mechanics of the products. We prefer to retain the consistency and preserve the ability to easily add new Protection Options in the future.
Annuity Contract (pp. 14-15)
15.In the subsection titled “Ownership Changes”, please make sure to include the contact information for the Customer Care Center.
Response: We have made this revision.
Contract Options (pp. 16-20)
16.In the subsection titled “Index Adjustment”, please revise the second sentence of the first paragraph to read "This Index Adjustment can be zero, positive, or negative, depending on the performance of the Index and the Crediting Method and Protection Option chosen."
Response: We have made this revision.
17.The following comments address the subsection titled “Interim Value”:
a.Please revise consistently with your response to comments 9a and 9b with regard to the language used to describe the (non-guaranteed) prorated and guaranteed minimum Index Adjustment Factors.
Response: We have made this revision.
b.Supplementally, please explain the basis for the formula for guaranteed minimums.
Response: The purpose of the guaranteed minimums is to increase the interim value in scenarios where the prorated index adjustment factors result in interim values that are materially lower than the value of a hypothetical portfolio of derivatives that replicate the term length crediting method. Analysis has indicated that the largest differences occur early in the Index Account Option Term and decrease over time, and the
convergence happens at different points for different Index Account Option Term Lengths. These considerations informed the derivation of the formula.
c.Please explain in an example that the guaranteed minimum formula doesn’t change if your term is longer than a year.
Response: We have made this revision.
d.Please consider providing a break-even point where the prorated value would be higher than the guaranteed minimum value.
Response: We have made this revision.
e.In the cross-reference to Appendix A after the Index Adjustment Factor Proration Example utilizing Guaranteed Minimums, please confirm the cross-reference in the third bullet to Examples 1-4.
Response: We have confirmed the accuracy of the cross-reference.
Additional Information About the Index Account Options (pp. 20-25)
18.In the third paragraph of the subsection titled “Protection Option”, please note the staff's preference to the description in the second sentence of the interplay between prorated and guaranteed minimum Index Adjustment Factors. Consider using this phrasing throughout the prospectus.
Response: We have made revisions to disclosures throughout the prospectus describing the interplay between prorated and guaranteed minimum Index Adjustment Factors.
19.In the subsection titled “Cap with Buffer”, please revise any language identifying "if the market is flat" to "if the market is zero" consistent with the Performance Trigger with Buffer example.
Response: We have ensured that any reference to market performance in the Crediting Methods examples which includes reference to a flat market has been so revised. The Cap crediting method only includes reference to a positive market return, so no revisions were made to the identified subsection.
Transfers and Reallocations (pp. 25-28)
20.In the third paragraph of the subsection titled “Transfer Requests”, please explain the meaning of the last sentence. Clarify if the term ‘transfers’ in this sentence means mid-term transfers or contract anniversary transfers or if it refers to both.
Response: This language relates to a New York requirement that if all Index Account Options were closed, that we permit transfers or withdrawals without the application of any otherwise applicable withdrawal charges. As the staff has required us to affirm this scenario would never occur because we will always make more than one Index Account Option available, we have deleted this disclosure.
21.In the last sentence of the fifth paragraph in the subsection titled “Intra-Term Performance Lock”, please revise to "Jackson of NY Customer Care Center" for consistency.
Response: We have made this revision.
Withdrawal Charge (pp. 29-31)
22.Please ensure there are no references to an income date within one year of the issue date.
Response: We have made this revision.
23.In the second paragraph of the subsection titled “Waiver of Withdrawal Charge”, please revise to remove plural references to waivers since there is only one type of waiver.
Response: We have made this revision.
Income Payments
24.In the sixth paragraph, please consider offering clarification between Withdrawal Value and Contract Value here rather than solely relying upon the definitions in the Glossary.
Response: We have made this revision.
Death Benefit (pp. 33-35)
25.In the second to last paragraph before the subsection titled "Payout Options", the last sentence notes that interest will be paid on death benefits “as required by law”. Please explain what the interest rate is under New York law, or supplementally explain why this reference is left as is.
Response: Under New York law, there are two different statutes dictating the payment of interest on death benefit claims, depending upon whether the funds are being withdrawn from the Fixed Account or Index Account Options. These statutes are complex and involve timing, calculation, and procedural elements which would not serve to aid in investor understanding. The disclosure has been left as is to indicate simply that the Company will comply with all laws dictating the payment of interest on death benefits. No revision has been made in response to this comment.
26.In the first paragraph of the subsection titled “Spousal Continuation Option”, please consider deleting the second to last sentence since this product is only offered in New York.
Response: We have made this revision.
Jackson of NY Taxation (pp. 38-39)
27.Please confirm the premium tax information included in the first paragraph, which references a range for premium taxes. Is this range accurate or is there a set premium tax percentage for New York?
Response: We have confirmed the accuracy of the premium tax range referenced in this comment.
Appendix A: Calculation Examples (pp. A-1 - A-27)
28.In the fifth bullet of Example 1, please be consistent if rounding decimals. Here, using 5.26% in the formula listed would not result in a value of $150,260.27. Please review this rounding practice throughout the Appendix and revise accordingly.
Response: Respectfully, we were utilizing a consistent approach to the rounding of decimal places on displayed values expressed as dollar amounts and values expressed as percentages, while using un-rounded values in the calculations for a more precise answer. In the instance referenced in the comment, the 5.26% is rounded, but the ultimate value of $150,260.27 is the result of using full, un-rounded values. Revising the Example to remove rounding, the percentage we will need to use will be 5.26027%, which we believe to be unhelpful to the average investor. Nevertheless, we have made revisions in response to this comment to remove the conflict between the rounded and un-rounded values.
29.In the Tabular Representation of Example 3:
a.In the first column of the Index Adjustment row, please confirm whether the 3.95% shown is accurate or whether it should be zero (representing zero days elapsed in crediting term).
Response: We have revised accordingly.
b.In the first column of the Pre-Withdrawal Interim Value and Total Withdrawal Value rows, should these values be $100,000?
Response: We have revised accordingly.
30.In the Tabular Representation of Example 4:
a.In the second column of the Year to Date Index Change row, should this read 1.00% instead of 10.00%?
Response: We have made this revision.
b.Please review prior comments provided on Example 3 and ensure they are addressed here as well.
Response: We have made these revisions.
31.In the Index Adjustment row of the Tabular Representation of Example
Show Raw Text
CORRESP
1
filename1.htm
nyrilasecresponsecombined
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 5, 2024
SUBJECT: Response to Comments for Initial Registration Statements filed on Form S-1 for File No. 333-268464 (Jackson Market Link Pro II); File No. 333-268466 (Jackson Market Link Pro Advisory II)
This memorandum is in response to the comments you provided via telephone on February 14, 2024 for the above referenced filings.
In the interest of convenience for the staff of the Securities and Exchange Commission, this memorandum provides our understanding of each of the specific comments, followed respectively by narrative responses (in bold).
Unless indicated otherwise below, the following comments and responses apply to all registration statements referenced above. Marked, excerpted pages of each prospectus, revised to reflect the changes discussed below, are filed herewith. Courtesy copies of both clean and marked copies of the prospectuses for each product will also be provided via electronic mail. Page references in the responses below are to the prospectus page number of the marked courtesy copy of the Jackson Market Link Pro II prospectus, unless indicated otherwise. Corresponding changes will be made to the Jackson Market Link Pro Advisory II prospectus as applicable. Additional pre-effective amendments to the registration statements will subsequently be filed in response to these comments.
Cover Page
1.Please add the following disclosure: 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 [ ]% 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.
Response: We have made this revision.
2.Please prominently disclose that the company could limit positive index gain and the maximum potential loss as a percentage that an investor could experience from negative index performance.
a.With respect to maximum potential loss: language could be similar to saying the contract currently offers options that offer buffers of -10 to -20 so loses could be up to 80-90% due to poor index performance.
Response: We have made this revision.
b.Please add that index options and downside options could change in the future. State that buffers will always be at least -5%.
Response: We have made this revision.
Summary (pp. 1-6)
3.Throughout this section and the prospectus, the disclosures reference both Protection Option and Protection Options. Please be consistent, check the tense used, and consider whether simply using "Buffer” or “Buffer Protection Option” would be clearer since the Buffer is the only Protection Option offered on the contract.
Response: We have made this revision.
4.When referencing guaranteed minimum Index Adjustment Factors, please make it clear early on and consistently that the client receives the greater of prorated or guaranteed minimums. Consider consistently referring to prorated Index Adjustment Factors as non-guaranteed prorated Index Adjustment Factors.
Response: We have made this revision.
5.In the subsection titled "Crediting Methods", consider dropping the parenthesis around Index Participation Rate (“Cap Rate with an IPR and the Performance Trigger…”).
Response: We have made this revision.
6.If there is a minimum cap rate, please include in the summary.
Response: We have made this revision.
7.Please move disclosures regarding IPR not being a stand-alone method and include as the last bullet point of cap crediting method disclosures in the summary.
Response: We have made this revision.
8.In the subsection titled “Protection Options”, please revise consistently with your response to comment 3.
Response: We have made this revision.
9.In the subsection titled “Interim Value Adjustment:
a.In the first sentence of the second paragraph, please review the description of prorated and guaranteed minimum Index Adjustment Factors and consider revising to use “either/or” rather than “and”.
Response: We have made this revision.
b.In the third paragraph, please note that the Staff prefers this usage of "(non-guaranteed) prorated" in the discussion of the prorated and guaranteed minimum Index Adjustment Factors. Consider revising this disclosure to a single sentence to simplify. For example, "When calculating your Interim Value, we will apply the greater of the (non-guaranteed) prorated Index Adjustment Factors or the guaranteed minimum Index Adjustment Factors”.
Response: We have made this revision.
10.The following comments address the “Contract Overview” table in the Summary section of the prospectus:
a.In the row titled "Intra-Term Performance Lock", consider simplifying by revising the first sentence to specify the Cap Index Account Option and deleting the final sentence before the cross-reference.
Response: We have made this revision.
b.In the row titled “Access to your Money”, you refer to the Free Withdrawal amount in the last sentence. Please consider defining “Free Withdrawal”.
Response: We have made this revision.
c.In the row titled “Income Options”, please review the third sentence of the first paragraph to see if this sentence should be deleted.
Response: We have made this revision.
Risk Factors (pp. 10-13)
11.In the subsection titled “Reallocations”, please relocate the second to last sentence to avoid locating it between two cross references.
Response: We have made this revision.
12.In the subsection titled “Buffers”, please revise the second sentence to “[w]hen you select the buffer” rather than when you "elect" since the Buffer is the only Protection Option available.
Response: We have made this revision.
Glossary (pp. 7-9)
13.In the definition for “Index Adjustment Factors”, please consider mentioning the application of non-guaranteed prorated or guaranteed minimum Index Adjustment Factors. If the Glossary definitions are ultimately kept at a high level with more detailed disclosure elsewhere in the prospectus, consider adding a sentence that simply notes that Index Adjustment Factors apply at the end of the Term, and prior to the end of the Term you will apply the greater of prorated or guaranteed minimum Index Adjustment Factors.
Response: We have revised the Glossary definitions to be more high level, including detailed information in the body of the prospectus. In connection with these revisions, we have removed similar disclosure from the Index Adjustment definition, and opted not to incorporate this suggested revision to the Index Adjustment Factors definition.
14.For the term “Protection Option”, please consider removing definition/defined term.
Response: We have retained this definition, with revisions. This terminology is used throughout all of our RILA product prospectuses and marketing collateral to help investors better understand the mechanics of the products. We prefer to retain the consistency and preserve the ability to easily add new Protection Options in the future.
Annuity Contract (pp. 14-15)
15.In the subsection titled “Ownership Changes”, please make sure to include the contact information for the Customer Care Center.
Response: We have made this revision.
Contract Options (pp. 16-20)
16.In the subsection titled “Index Adjustment”, please revise the second sentence of the first paragraph to read "This Index Adjustment can be zero, positive, or negative, depending on the performance of the Index and the Crediting Method and Protection Option chosen."
Response: We have made this revision.
17.The following comments address the subsection titled “Interim Value”:
a.Please revise consistently with your response to comments 9a and 9b with regard to the language used to describe the (non-guaranteed) prorated and guaranteed minimum Index Adjustment Factors.
Response: We have made this revision.
b.Supplementally, please explain the basis for the formula for guaranteed minimums.
Response: The purpose of the guaranteed minimums is to increase the interim value in scenarios where the prorated index adjustment factors result in interim values that are materially lower than the value of a hypothetical portfolio of derivatives that replicate the term length crediting method. Analysis has indicated that the largest differences occur early in the Index Account Option Term and decrease over time, and the
convergence happens at different points for different Index Account Option Term Lengths. These considerations informed the derivation of the formula.
c.Please explain in an example that the guaranteed minimum formula doesn’t change if your term is longer than a year.
Response: We have made this revision.
d.Please consider providing a break-even point where the prorated value would be higher than the guaranteed minimum value.
Response: We have made this revision.
e.In the cross-reference to Appendix A after the Index Adjustment Factor Proration Example utilizing Guaranteed Minimums, please confirm the cross-reference in the third bullet to Examples 1-4.
Response: We have confirmed the accuracy of the cross-reference.
Additional Information About the Index Account Options (pp. 20-25)
18.In the third paragraph of the subsection titled “Protection Option”, please note the staff's preference to the description in the second sentence of the interplay between prorated and guaranteed minimum Index Adjustment Factors. Consider using this phrasing throughout the prospectus.
Response: We have made revisions to disclosures throughout the prospectus describing the interplay between prorated and guaranteed minimum Index Adjustment Factors.
19.In the subsection titled “Cap with Buffer”, please revise any language identifying "if the market is flat" to "if the market is zero" consistent with the Performance Trigger with Buffer example.
Response: We have ensured that any reference to market performance in the Crediting Methods examples which includes reference to a flat market has been so revised. The Cap crediting method only includes reference to a positive market return, so no revisions were made to the identified subsection.
Transfers and Reallocations (pp. 25-28)
20.In the third paragraph of the subsection titled “Transfer Requests”, please explain the meaning of the last sentence. Clarify if the term ‘transfers’ in this sentence means mid-term transfers or contract anniversary transfers or if it refers to both.
Response: This language relates to a New York requirement that if all Index Account Options were closed, that we permit transfers or withdrawals without the application of any otherwise applicable withdrawal charges. As the staff has required us to affirm this scenario would never occur because we will always make more than one Index Account Option available, we have deleted this disclosure.
21.In the last sentence of the fifth paragraph in the subsection titled “Intra-Term Performance Lock”, please revise to "Jackson of NY Customer Care Center" for consistency.
Response: We have made this revision.
Withdrawal Charge (pp. 29-31)
22.Please ensure there are no references to an income date within one year of the issue date.
Response: We have made this revision.
23.In the second paragraph of the subsection titled “Waiver of Withdrawal Charge”, please revise to remove plural references to waivers since there is only one type of waiver.
Response: We have made this revision.
Income Payments
24.In the sixth paragraph, please consider offering clarification between Withdrawal Value and Contract Value here rather than solely relying upon the definitions in the Glossary.
Response: We have made this revision.
Death Benefit (pp. 33-35)
25.In the second to last paragraph before the subsection titled "Payout Options", the last sentence notes that interest will be paid on death benefits “as required by law”. Please explain what the interest rate is under New York law, or supplementally explain why this reference is left as is.
Response: Under New York law, there are two different statutes dictating the payment of interest on death benefit claims, depending upon whether the funds are being withdrawn from the Fixed Account or Index Account Options. These statutes are complex and involve timing, calculation, and procedural elements which would not serve to aid in investor understanding. The disclosure has been left as is to indicate simply that the Company will comply with all laws dictating the payment of interest on death benefits. No revision has been made in response to this comment.
26.In the first paragraph of the subsection titled “Spousal Continuation Option”, please consider deleting the second to last sentence since this product is only offered in New York.
Response: We have made this revision.
Jackson of NY Taxation (pp. 38-39)
27.Please confirm the premium tax information included in the first paragraph, which references a range for premium taxes. Is this range accurate or is there a set premium tax percentage for New York?
Response: We have confirmed the accuracy of the premium tax range referenced in this comment.
Appendix A: Calculation Examples (pp. A-1 - A-27)
28.In the fifth bullet of Example 1, please be consistent if rounding decimals. Here, using 5.26% in the formula listed would not result in a value of $150,260.27. Please review this rounding practice throughout the Appendix and revise accordingly.
Response: Respectfully, we were utilizing a consistent approach to the rounding of decimal places on displayed values expressed as dollar amounts and values expressed as percentages, while using un-rounded values in the calculations for a more precise answer. In the instance referenced in the comment, the 5.26% is rounded, but the ultimate value of $150,260.27 is the result of using full, un-rounded values. Revising the Example to remove rounding, the percentage we will need to use will be 5.26027%, which we believe to be unhelpful to the average investor. Nevertheless, we have made revisions in response to this comment to remove the conflict between the rounded and un-rounded values.
29.In the Tabular Representation of Example 3:
a.In the first column of the Index Adjustment row, please confirm whether the 3.95% shown is accurate or whether it should be zero (representing zero days elapsed in crediting term).
Response: We have revised accordingly.
b.In the first column of the Pre-Withdrawal Interim Value and Total Withdrawal Value rows, should these values be $100,000?
Response: We have revised accordingly.
30.In the Tabular Representation of Example 4:
a.In the second column of the Year to Date Index Change row, should this read 1.00% instead of 10.00%?
Response: We have made this revision.
b.Please review prior comments provided on Example 3 and ensure they are addressed here as well.
Response: We have made these revisions.
31.In the Index Adjustment row of the Tabular Representation of Example