SEC Company Response from JACKSON NATIONAL LIFE INSURANCE CO OF NEW YORK (CIK 0001128415) — Mar 12, 2026
JACKSON NATIONAL LIFE INSURANCE CO OF NEW YORK (CIK 0001128415)
Date: March 12, 2026 · CIK: 0001128415 · Accession: 0001128415-26-000036
AI Filing Summary & Sentiment
File numbers found in text: 333-292237, 333-292238, 333-292244, 333-292247
Letter
SECRESPONSEnyrila4n4COMBINED
MEMORANDUM
TO:Soo Im-Tang
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
U. S. Securities and Exchange Commission
FROM:Jennifer Grau, Esq.
Senior Attorney, Insurance Legal & Product Development
DATE:March 12, 2026
SUBJECT:Response to Comments for the Initial Registration Statements filed on Form N-4 for File Nos.
333-292237 & 333-292238; Jackson National Life Insurance Company, and File Nos. 333-292244 &
333-292247; Jackson National Life Insurance Company of New York
This memorandum is in response to the comments you provided verbally on February 23, 2026, for the above referenced
filings.
In the interest of convenience for the staff of the Securities and Exchange Commission ("SEC"), this memorandum
provides our understanding of the specific comment, followed respectively by a narrative response (in bold).
Unless indicated otherwise below, the following comments and responses apply to all registration statements referenced
above. Excerpted pages of the Jackson Market Link Pro 4, Jackson Market Link Pro Advisory 4, and New York Jackson
Market Link Pro 4 Statutory Prospectuses, marked to show the changes identified below under the respective product
headers, are attached and will be provided electronically. Page references in the responses are to the pdf page of the
marked excerpted prospectus pages. Corresponding changes have been made to all of the above-referenced registration
statements, as applicable. Pre-effective amendments to the above-referenced registration statements will subsequently be
filed in response to the comments.
General Comments
1.Where a comment is made in one location, it is applicable to all above-referenced registration statements, ISPs, and
rate sheet prospectus supplements, as applicable.
Response: Registrant acknowledges and confirms that corresponding changes have been made to all
documents, as applicable, in response to these comments.
2.Please confirm that anything marked "to be updated by amendment" will be reflected in the final pre-effective
filings.
Response: Registrant confirms that all disclosures marked "to be updated" will be complete and included in
the final pre-effective filings for all registrations.
JNL BROKERAGE PROSPECTUS
Cover Page (pp. 1-2)
3.In the second to last sentence of the fourth paragraph, please disclose that the investor would no longer be able to
increase his or her contract value and death benefit through additional premium payments if the company exercises
its right to refuse premium payments.
Response: This revision has been made.
4.In the first paragraph on the second page of the cover page, please clarify as you do on page 29 that although
protection options may be removed in the future, there will always be at least one protection option available for
election.
Response: This revision has been made.
Glossary (p. 3)
5.Please define "Rate Enhancement Option" and "Rate Enhancement Option Charge" in the Glossary.
Response: This revision has been made.
6.In the definition of Protection Option, please consider adding that the current contract only offers a Buffer.
Response: This definition is meant to generally define Protection Option as used in the prospectus. While
only a Buffer option is available at launch of the product, Registrant has previously offered, and may in the
future offer other Protection Options under the contract. Respectfully, the definition for Buffer identifies it
as the Protection Option currently offered under the contract, and Registrant does not feel that the more
general Protection Option definition implies other current offerings or creates confusion. As such, no
revision has been made in response to this comment.
Overview of the Contract (p. 4)
7.In the third bullet of the Guaranteed Cap subsection under Phases of the Contract, please consider adding a
parenthetical note that the Guarantee Period is the six-year period during which the index adjustment factors remain
unchanged.
Response: Respectfully, Guarantee Period is a defined term, included in the Glossary so that its use
throughout the prospectus does not require additional repetition of its definition. No revision has been made
in response to this comment.
8.The following comments relate to the Performance Lock subsection under Contract Features:
a.If there are contract limits on how soon after the term begins that an investor can exercise a Performance
Lock, please disclose the limitations as well as any cutoff dates for requesting a Performance Lock.
Response: Registrant confirms there are no such limitations.
b.Please disclose that if interim value is locked in, the investor will forgo any participation in the investment
of the index option, will not receive any interest at the end of the term based on index return, and may have
realized a higher gain by remaining invested in the index option.
Response: Respectfully, the requested risk disclosures are already covered extensively in the Principal
Risks section of the prospectus. Adding these disclosures here would double the length of the
summary of the Performance Lock feature in the Overview of the Contract section, which does not
appear consistent with the Form N-4 description that this section provide a "concise description" and
summary of contract features, particularly given the same disclosures already appear in a more
relevant location in the prospectus. No revisions have been made in response to this comment at this
time.
c.Please clarify that interim value does not reflect the performance of the index.
Response: Respectfully, this disclosure is covered in the Interim Value subsection on the same page of
the prospectus. No revisions have been made in response to this comment.
9.The following comments relate to the Rate Enhancement Option subsection under Contract Features:
a.Please clarify here that the Rate Enhancement Option cannot be elected in combination with the +Income
GMWB or the +Income GMWB with Joint Option.
Response: This revision has been made.
b.Please specify where the investor can locate the enhanced rates or include a cross-reference to the applicable
rate sheet supplement.
Response: This revision has been made.
Key Information Table (p. 5)
10.In the row titled "Are There Charges or Adjustments for Early Withdrawals", please consider adding a parenthetical
next to Withdrawal Charge Period that this refers to the first six years following receipt of premium.
Response: Respectfully, Withdrawal Charge Period is a defined term, included in the Glossary so that its use
throughout the prospectus does not require additional repetition of its definition. No revision has been made
in response to this comment.
11.In the row titled "Are There Restrictions on Contract Benefits", please also include any restrictions on the Rate
Enhancement Option.
Response: This revision has been made.
Principal Risks (pp. 6-8)
12.The following comments relate to the Premium Payments subsection under Principal Risks:
a.Please revise the disclosure to identify factors that restrict additional premium payments and cross-reference
where detailed, if applicable.
Response: This revision has been made.
b.Please revise the disclosure to explain how subsequent premium payments may or may not contribute to
various benefits.
Response: This revision has been made.
c.Please revise the disclosure to describe the circumstances under which the Company may lower the
maximum premium permitted and provide examples of the impact on benefits.
Response: This revision has been made.
13.In the risk section titled Tracking Index Performance, please briefly describe the risks associated with the newly
added Dow Jones Industrial Average Index.
Response: This revision has been made.
14.In the risk section titled Buffers, you note a reservation of right to remove protection options in the future. Please
clarify whether the use of protection option here refers to buffers and floors or only buffers as offered under this
contract.
Response: We retain general references to Protection Options throughout the prospectus as we have
historically offered, and may in the future offer additional types of Protection Options. The reservation of
right relates to our ability as it relates to any type of Protection Option. Registrant confirms that at this time,
the only Protection Option available is the Buffer Protection Option, and represents that the existing
disclosures make this clear.
Contract Options (p. 9)
15.In the Subsequent Premium Holding Account subsection under the section titled Fixed Account, please clarify that
the funds held in the subsequent premium holding account do not earn index-linked interest until allocated.
Response: This revision has been made.
16.In the Index Account subsection, please consider re-inserting the deleted table for ease of understanding.
Response: Respectfully, Registrant removed this table in favor of reliance on the Investment Options table in
Appendix A now that no rates are displayed in the prospectus. Registrant believes Appendix A, along with
disclosures in relevant crediting method and protection option sections, provide better information to the
investor on available options, consistent with new Form N-4 expectations. No revision has been made in
response to this comment.
Additional Information about the Index Account Options (p. 10)
17.Please update the bar charts in the Indexes subsection to include the year 2025 so that a 10-year period is reflected.
Response: Registrant confirms these bar charts will be updated to reflect the appropriate 10-year period
including calendar year 2025 and that information will be included in the final pre-effective filings.
18.In the fourth paragraph of the subsection titled Crediting Methods, please consider including clarifying language that
neither the owner of the contract nor others are investors in the derivative instruments used to hedge obligations and
cross-reference the section discussing general account and unregistered securities in the section titled Other
Information.
Response: This revision has been made.
Charges and Adjustments (pp. 11-12)
19.In the third bullet of the Withdrawal Charge subsection, please reconcile the inconsistency in how Free Withdrawal
is defined here versus the Glossary.
Response: This revision has been made.
20.The following comments relate to the Rate Enhancement Option Charge subsection:
a.Please provide a numerical example illustrating accrual and deduction of the Rate Enhancement Option
Charge and its impact on the Contract Value and Interim Value.
Response: These examples were present in the Calculation Examples appendix but mis-identified as
being found in the SAI. We have revised in-line text for clarity and updated the cross-reference to the
appropriate Calculation Examples appendix with specificity to example numbers.
b.If the timing of the deduction of the Rate Enhancement Option Charge triggers a Contract Adjustment,
please disclose that the Contract Adjustment could be negative, meaning the Index Account Option Value
could decrease by more than the amount of the charge deducted. In addition, please prominently disclose
that this could result in greater decreases in Index Account Option Value and, over time, the deduction of
ongoing charges with recurring adjustments could result in significant loss.
Response: The timing of the deduction of the charge does not trigger a Contract Adjustment. The
charge is designed to be deducted at the end of the Index Account Option Term when no Contract
Adjustment would apply. If, however, a Contract Adjustment is triggered due to the removal of
Interim Value prior to the end of an Index Account Option Term, that would in turn trigger a
proportional deduction of the charge (as illustrated in existing examples). In other words, the election
of the Rate Enhancement Option does not itself result in recurring charge deductions that would
trigger Contract Adjustments. No revisions have been made in response to this comment.
c.In the last sentence of the third paragraph from the bottom of the subsection, please specify the relevant
section of the SAI rather then providing a general reference.
Response: This revision has been made.
Appendix C (State Variations)
21.Please provide a completed copy of Appendix C for review.
Response: Respectfully, the disclosures in this appendix are subject to state regulatory requirements on
pending filings and are not yet available. Registrant confirms this appendix will be fully updated at the time
of the final pre-effective amendment filing.
Appendix I (Financial Intermediary Variations)
22.Please provide a completed copy of Appendix I for review.
Response: Respectfully, the disclosures in this appendix are subject to input from financial intermediaries
and are not yet available. Registrant confirms this appendix will be updated with all known material
variations at the time of the final pre-effective amendment filing.
JNL ADVISORY PROSPECTUS
Key Information Table (pp. 13-14)
23.In the Fees, Expenses, and Adjustments section of the table, please add advisory fees after "no sales charges" in the
disclosures for Highest Annual Cost field.
Response: This revision has been made.
24.In the third paragraph of the row titled "Is this a short-term investment", wherever you discuss renewal, please make
it clear that both the upside and downside rates will change to the then applicable renewal rates.
Response: This revision has been made.
25.In the row titled "Are there Restrictions on Investment Options", please correct the typographical error in the last
sentence of the Premium Payments disclosures.
Response: This revision has been made.
Contract Options
26.If advisory fees are deducted from contract value, please include such deduction in the list of transactions that
reduce Fixed Account Value in the subsection titled Fixed Account Value.
Response: Advisory fee withdrawals are already included in this list of transactions as the fifth numbered
transaction type reducing the Fixed Account Value.
Additional Information About the Index Account Options
27.In the subsection titled Protection Options, you note that the Buffer rates are the new business or renewal rates
effective as of the first day of the Index Account Option Term. Please confirm that the rate sheet prospectus
supplement will show both new business and renewal buffer rates, if different.
Response: To date, new business and renewal rates for Buffers have been identical. To the extent Registrant
offers renewal Buffer rates in the future that differ from the new business Buffer rates, those renewal rates
would be disclosed on the rate sheet prospectus supplement.
Taxes (p. 15)
28.In the subsection titled Constructive Withdrawals - Investment Adviser Fees, please clarify that the 10% federal
penalty applies if amounts are withdrawn before age 59 ½.
Response: This revision has been made.
Distribution of Contracts
29.In the disclosures covering Compensation to JNLD, you reference contracts "offered to persons who
are also customers of an Independent Registered Investment Advisor". Please clarify the distinction between
"Independent Registered Investment Advisor" and "Registered Investment Advisor."
Response: Independent Registered Investment Advisors are Registered Investment Advisers that are not
affiliated with a Broker-Dealer, and who require additional support in the recommendation and sale of
contracts.
Appendix A (Investment Options Available Under the Contract) (p. 16)
30.Please also disclose the rates reflecting the Rate Enhancement Option in Appendix A.
Response: Respectfully, the Rate Enhancement Option does not provide for separate or unique guaranteed
minimum crediting rates or pr
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SECRESPONSEnyrila4n4COMBINED
MEMORANDUM
TO:Soo Im-Tang
Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
U. S. Securities and Exchange Commission
FROM:Jennifer Grau, Esq.
Senior Attorney, Insurance Legal & Product Development
DATE:March 12, 2026
SUBJECT:Response to Comments for the Initial Registration Statements filed on Form N-4 for File Nos.
333-292237 & 333-292238; Jackson National Life Insurance Company, and File Nos. 333-292244 &
333-292247; Jackson National Life Insurance Company of New York
This memorandum is in response to the comments you provided verbally on February 23, 2026, for the above referenced
filings.
In the interest of convenience for the staff of the Securities and Exchange Commission ("SEC"), this memorandum
provides our understanding of the specific comment, followed respectively by a narrative response (in bold).
Unless indicated otherwise below, the following comments and responses apply to all registration statements referenced
above. Excerpted pages of the Jackson Market Link Pro 4, Jackson Market Link Pro Advisory 4, and New York Jackson
Market Link Pro 4 Statutory Prospectuses, marked to show the changes identified below under the respective product
headers, are attached and will be provided electronically. Page references in the responses are to the pdf page of the
marked excerpted prospectus pages. Corresponding changes have been made to all of the above-referenced registration
statements, as applicable. Pre-effective amendments to the above-referenced registration statements will subsequently be
filed in response to the comments.
General Comments
1.Where a comment is made in one location, it is applicable to all above-referenced registration statements, ISPs, and
rate sheet prospectus supplements, as applicable.
Response: Registrant acknowledges and confirms that corresponding changes have been made to all
documents, as applicable, in response to these comments.
2.Please confirm that anything marked "to be updated by amendment" will be reflected in the final pre-effective
filings.
Response: Registrant confirms that all disclosures marked "to be updated" will be complete and included in
the final pre-effective filings for all registrations.
JNL BROKERAGE PROSPECTUS
Cover Page (pp. 1-2)
3.In the second to last sentence of the fourth paragraph, please disclose that the investor would no longer be able to
increase his or her contract value and death benefit through additional premium payments if the company exercises
its right to refuse premium payments.
Response: This revision has been made.
4.In the first paragraph on the second page of the cover page, please clarify as you do on page 29 that although
protection options may be removed in the future, there will always be at least one protection option available for
election.
Response: This revision has been made.
Glossary (p. 3)
5.Please define "Rate Enhancement Option" and "Rate Enhancement Option Charge" in the Glossary.
Response: This revision has been made.
6.In the definition of Protection Option, please consider adding that the current contract only offers a Buffer.
Response: This definition is meant to generally define Protection Option as used in the prospectus. While
only a Buffer option is available at launch of the product, Registrant has previously offered, and may in the
future offer other Protection Options under the contract. Respectfully, the definition for Buffer identifies it
as the Protection Option currently offered under the contract, and Registrant does not feel that the more
general Protection Option definition implies other current offerings or creates confusion. As such, no
revision has been made in response to this comment.
Overview of the Contract (p. 4)
7.In the third bullet of the Guaranteed Cap subsection under Phases of the Contract, please consider adding a
parenthetical note that the Guarantee Period is the six-year period during which the index adjustment factors remain
unchanged.
Response: Respectfully, Guarantee Period is a defined term, included in the Glossary so that its use
throughout the prospectus does not require additional repetition of its definition. No revision has been made
in response to this comment.
8.The following comments relate to the Performance Lock subsection under Contract Features:
a.If there are contract limits on how soon after the term begins that an investor can exercise a Performance
Lock, please disclose the limitations as well as any cutoff dates for requesting a Performance Lock.
Response: Registrant confirms there are no such limitations.
b.Please disclose that if interim value is locked in, the investor will forgo any participation in the investment
of the index option, will not receive any interest at the end of the term based on index return, and may have
realized a higher gain by remaining invested in the index option.
Response: Respectfully, the requested risk disclosures are already covered extensively in the Principal
Risks section of the prospectus. Adding these disclosures here would double the length of the
summary of the Performance Lock feature in the Overview of the Contract section, which does not
appear consistent with the Form N-4 description that this section provide a "concise description" and
summary of contract features, particularly given the same disclosures already appear in a more
relevant location in the prospectus. No revisions have been made in response to this comment at this
time.
c.Please clarify that interim value does not reflect the performance of the index.
Response: Respectfully, this disclosure is covered in the Interim Value subsection on the same page of
the prospectus. No revisions have been made in response to this comment.
9.The following comments relate to the Rate Enhancement Option subsection under Contract Features:
a.Please clarify here that the Rate Enhancement Option cannot be elected in combination with the +Income
GMWB or the +Income GMWB with Joint Option.
Response: This revision has been made.
b.Please specify where the investor can locate the enhanced rates or include a cross-reference to the applicable
rate sheet supplement.
Response: This revision has been made.
Key Information Table (p. 5)
10.In the row titled "Are There Charges or Adjustments for Early Withdrawals", please consider adding a parenthetical
next to Withdrawal Charge Period that this refers to the first six years following receipt of premium.
Response: Respectfully, Withdrawal Charge Period is a defined term, included in the Glossary so that its use
throughout the prospectus does not require additional repetition of its definition. No revision has been made
in response to this comment.
11.In the row titled "Are There Restrictions on Contract Benefits", please also include any restrictions on the Rate
Enhancement Option.
Response: This revision has been made.
Principal Risks (pp. 6-8)
12.The following comments relate to the Premium Payments subsection under Principal Risks:
a.Please revise the disclosure to identify factors that restrict additional premium payments and cross-reference
where detailed, if applicable.
Response: This revision has been made.
b.Please revise the disclosure to explain how subsequent premium payments may or may not contribute to
various benefits.
Response: This revision has been made.
c.Please revise the disclosure to describe the circumstances under which the Company may lower the
maximum premium permitted and provide examples of the impact on benefits.
Response: This revision has been made.
13.In the risk section titled Tracking Index Performance, please briefly describe the risks associated with the newly
added Dow Jones Industrial Average Index.
Response: This revision has been made.
14.In the risk section titled Buffers, you note a reservation of right to remove protection options in the future. Please
clarify whether the use of protection option here refers to buffers and floors or only buffers as offered under this
contract.
Response: We retain general references to Protection Options throughout the prospectus as we have
historically offered, and may in the future offer additional types of Protection Options. The reservation of
right relates to our ability as it relates to any type of Protection Option. Registrant confirms that at this time,
the only Protection Option available is the Buffer Protection Option, and represents that the existing
disclosures make this clear.
Contract Options (p. 9)
15.In the Subsequent Premium Holding Account subsection under the section titled Fixed Account, please clarify that
the funds held in the subsequent premium holding account do not earn index-linked interest until allocated.
Response: This revision has been made.
16.In the Index Account subsection, please consider re-inserting the deleted table for ease of understanding.
Response: Respectfully, Registrant removed this table in favor of reliance on the Investment Options table in
Appendix A now that no rates are displayed in the prospectus. Registrant believes Appendix A, along with
disclosures in relevant crediting method and protection option sections, provide better information to the
investor on available options, consistent with new Form N-4 expectations. No revision has been made in
response to this comment.
Additional Information about the Index Account Options (p. 10)
17.Please update the bar charts in the Indexes subsection to include the year 2025 so that a 10-year period is reflected.
Response: Registrant confirms these bar charts will be updated to reflect the appropriate 10-year period
including calendar year 2025 and that information will be included in the final pre-effective filings.
18.In the fourth paragraph of the subsection titled Crediting Methods, please consider including clarifying language that
neither the owner of the contract nor others are investors in the derivative instruments used to hedge obligations and
cross-reference the section discussing general account and unregistered securities in the section titled Other
Information.
Response: This revision has been made.
Charges and Adjustments (pp. 11-12)
19.In the third bullet of the Withdrawal Charge subsection, please reconcile the inconsistency in how Free Withdrawal
is defined here versus the Glossary.
Response: This revision has been made.
20.The following comments relate to the Rate Enhancement Option Charge subsection:
a.Please provide a numerical example illustrating accrual and deduction of the Rate Enhancement Option
Charge and its impact on the Contract Value and Interim Value.
Response: These examples were present in the Calculation Examples appendix but mis-identified as
being found in the SAI. We have revised in-line text for clarity and updated the cross-reference to the
appropriate Calculation Examples appendix with specificity to example numbers.
b.If the timing of the deduction of the Rate Enhancement Option Charge triggers a Contract Adjustment,
please disclose that the Contract Adjustment could be negative, meaning the Index Account Option Value
could decrease by more than the amount of the charge deducted. In addition, please prominently disclose
that this could result in greater decreases in Index Account Option Value and, over time, the deduction of
ongoing charges with recurring adjustments could result in significant loss.
Response: The timing of the deduction of the charge does not trigger a Contract Adjustment. The
charge is designed to be deducted at the end of the Index Account Option Term when no Contract
Adjustment would apply. If, however, a Contract Adjustment is triggered due to the removal of
Interim Value prior to the end of an Index Account Option Term, that would in turn trigger a
proportional deduction of the charge (as illustrated in existing examples). In other words, the election
of the Rate Enhancement Option does not itself result in recurring charge deductions that would
trigger Contract Adjustments. No revisions have been made in response to this comment.
c.In the last sentence of the third paragraph from the bottom of the subsection, please specify the relevant
section of the SAI rather then providing a general reference.
Response: This revision has been made.
Appendix C (State Variations)
21.Please provide a completed copy of Appendix C for review.
Response: Respectfully, the disclosures in this appendix are subject to state regulatory requirements on
pending filings and are not yet available. Registrant confirms this appendix will be fully updated at the time
of the final pre-effective amendment filing.
Appendix I (Financial Intermediary Variations)
22.Please provide a completed copy of Appendix I for review.
Response: Respectfully, the disclosures in this appendix are subject to input from financial intermediaries
and are not yet available. Registrant confirms this appendix will be updated with all known material
variations at the time of the final pre-effective amendment filing.
JNL ADVISORY PROSPECTUS
Key Information Table (pp. 13-14)
23.In the Fees, Expenses, and Adjustments section of the table, please add advisory fees after "no sales charges" in the
disclosures for Highest Annual Cost field.
Response: This revision has been made.
24.In the third paragraph of the row titled "Is this a short-term investment", wherever you discuss renewal, please make
it clear that both the upside and downside rates will change to the then applicable renewal rates.
Response: This revision has been made.
25.In the row titled "Are there Restrictions on Investment Options", please correct the typographical error in the last
sentence of the Premium Payments disclosures.
Response: This revision has been made.
Contract Options
26.If advisory fees are deducted from contract value, please include such deduction in the list of transactions that
reduce Fixed Account Value in the subsection titled Fixed Account Value.
Response: Advisory fee withdrawals are already included in this list of transactions as the fifth numbered
transaction type reducing the Fixed Account Value.
Additional Information About the Index Account Options
27.In the subsection titled Protection Options, you note that the Buffer rates are the new business or renewal rates
effective as of the first day of the Index Account Option Term. Please confirm that the rate sheet prospectus
supplement will show both new business and renewal buffer rates, if different.
Response: To date, new business and renewal rates for Buffers have been identical. To the extent Registrant
offers renewal Buffer rates in the future that differ from the new business Buffer rates, those renewal rates
would be disclosed on the rate sheet prospectus supplement.
Taxes (p. 15)
28.In the subsection titled Constructive Withdrawals - Investment Adviser Fees, please clarify that the 10% federal
penalty applies if amounts are withdrawn before age 59 ½.
Response: This revision has been made.
Distribution of Contracts
29.In the disclosures covering Compensation to JNLD, you reference contracts "offered to persons who
are also customers of an Independent Registered Investment Advisor". Please clarify the distinction between
"Independent Registered Investment Advisor" and "Registered Investment Advisor."
Response: Independent Registered Investment Advisors are Registered Investment Advisers that are not
affiliated with a Broker-Dealer, and who require additional support in the recommendation and sale of
contracts.
Appendix A (Investment Options Available Under the Contract) (p. 16)
30.Please also disclose the rates reflecting the Rate Enhancement Option in Appendix A.
Response: Respectfully, the Rate Enhancement Option does not provide for separate or unique guaranteed
minimum crediting rates or pr