SEC Company Response from Equitable America Variable Account K of Equitable Financial Life Insurance Co of America (CIK 0001585490) — Jul 27, 2021
Equitable America Variable Account K of Equitable Financial Life Insurance Co of America (CIK 0001585490)
Date: July 27, 2021 · CIK: 0001585490 · Accession: 0001193125-21-225877
AI Filing Summary & Sentiment
File numbers found in text: 333-256251, 333-256256, 811-04335, 811-22886
Letter
VIA EDGAR United States Securities and Exchange Division of Investment Management Equitable America Variable Account K Equitable Financial Life Insurance Company of America Initial Registration Statement on Form N-6 File No. 333-256256; 811-22886
Dear Ms. Bentzinger:
The purpose of this letter is to provide a response to the supplemental comments you provided with respect to the above-referenced filing for Equitable Financial Life Insurance Company and Equitable Financial Life Insurance Company of America (the “Companies”). For your convenience, I have included those comments below, and followed each comment with the Company’s response. Please see the revised Statutory Prospectuses and Initial Summary Prospectuses filed herewith.
Request for Acceleration of the Effectiveness of the Registration Statement
On behalf of the Registrant and the principal underwriters, Equitable Distributors, LLC and Equitable Advisors, LLC, we hereby request acceleration of the effectiveness of the Registration Statement, pursuant to Rule 461 under the 1933 Act, so that the Registration Statement will be declared effective on August 20, 2021, or as soon thereafter as practicable. In this connection, the Registrant and the principal underwriters, Equitable Distributors, LLC and Equitable Advisors, LLC, have authorized me to represent on their behalf that they are aware of their obligations under the 1933 Act.
General
1. Please confirm that all missing information, including all exhibits, will be filed in a pre-effective amendment to each registration statement. We may have further comments when you supply the omitted information.
Response: All missing information, including all exhibits, will be filed in a pre-effective amendment to each registration statement.
2. Please include an active hyperlink or other means of facilitating access that leads directly to each website address referenced in the registration statement, as well as all other information incorporated by reference, such as Form VPFS. See General Instruction C.3(i) to Form N-6; Rule 411 under the Securities Act of 1933 (the “1933 Act”); Rule 0-4 under the Investment Company Act of 1940.
Response: All active hyperlinks will be included when we file for effectiveness.
3. Please provide powers of attorney that relate specifically to each registration statement as required by Rule 483(b) of the 1933 Act.
Response: Updated powers of attorney will be included when we file for effectiveness.
Cover Page
4. In the third sentence of the fourth paragraph, please clarify that in most states, the Company will refund the policy account value, plus any charges that were deducted, less any outstanding loan and accrued loan interest.
Response: The disclosure has been revised as requested.
Definition of Key Terms (pages 5-6)
5. Please remove the statement in the Alternative Death Benefit definition regarding there being a choice of a life insurance qualification test, as the Policy only offers one test. Further, please consistently refer to this death benefit as either the “alternative” death benefit or the “alternate” death benefit; both terms are currently used throughout the prospectus.
Response: The disclosure has been revised as requested.
Important Information You Should Consider About the Policy (pages 7-9)
6. When describing Insurance Company Risks, please note that any policy obligations, including under the fixed rate option and under the MSO, are subject to the Company’s claims-paying ability.
Response: The disclosure has been revised as requested.
7. In the Policy Lapse section of the Risks table, please reconcile the statement that an owner may need to pay more premiums to keep the policy from terminating if the policy continuation feature is in effect with page 44 of the prospectus, which states that no further premiums are required if policy continuation takes effect.
Response: The disclosure has been revised as requested.
Overview of the Policy (pages 10-11)
8. To avoid investor confusion, please group the four riders under the Policy into one list, and make clear that (a) both the Policy Continuation Rider and the Living Benefits Rider have a charge associated with exercising the rider; (b) the Policy Continuation Rider is automatically issued to all policies; (c) the Living Benefits Rider is only added at issue to Policies with a face amount of at least $100,000, and there is a $100 charge for those who decline the rider but later elect it after issue; (d) the No-Lapse Guarantee Rider is automatically added to all policies (or clarify the “eligible policies” to which it is automatically added); and (e) the Policy Continuation Rider protects against policy termination if the net policy account value is insufficient to cover the monthly deductions (regardless of whether there is an outstanding loan).
Response: The disclosure has been revised as requested, except that as one of the requirements for the Policy Continuation Rider at the time of exercise is for there to be an outstanding loan where policy loan and accrued loan interest exceeds the current base policy face amount.
Fee Table (pages 12-14)
9. To avoid investor confusion, please remove the label “Current and Maximum Charge” from the wire transfer charge, express mail charge, duplicate policy charge, and charge for returned payments in the Transaction Fees table. With regard to the policy history charge, please remove the label “Current” as $50 is the maximum charge, but not the current charge.
Response: The disclosure has been revised as requested.
10. In the fourth footnote to the Transaction Fees table, please include a cross-reference to the MSO prospectus.
Response: The disclosure has been revised as requested.
11. Please format the footnote in the Transaction Fees table describing the declining surrender charge to be consistent with the other footnotes (i.e., indent the table; replace “**” with a number).
Response: The disclosure has been revised as requested.
12. In the narrative preceding the Periodic Charges table, please remove the phrase “guaranteed maximum” consistent with the prescribed wording of Item 4 of Form N-6.
Response: The disclosure has been revised as requested.
13. Please clarify that the charge for adding the Living Benefits Rider is deducted “Once – on the date the rider is exercised” rather than “At the time of the transaction,” consistent with the description of the Policy Continuation Rider charge.
Response: The disclosure has been revised as requested.
Payment of Premiums and Determining Your Policy’s Value (pages 22-26)
14. Page 23 of the prospectus states that the policy will not lapse if the policy “has an outstanding loan that would qualify for ‘policy continuation.’” Please revise this disclosure to clarify that the policy will not lapse if the conditions of the Policy Continuation Rider are satisfied, including that there is sufficient net policy account value to cover the Policy Continuation Charge, and provide a corresponding cross-reference.
Response: The disclosure has been revised to clarify that the policy will not lapse if conditions of the Policy Continuation Rider are satisfied, including that there is sufficient net policy account value to cover the Policy Continuation Charge, with a correspondence cross-reference.
Death Benefits and Accessing Your Money (pages 29-33)
15. When providing an example on page 29 of the alternative death benefit under the cash value accumulation test, please reconcile the 144.0% death benefit percentage in the Separate Account FP prospectus with the 140.0% death benefit percentage in the Equitable America Variable Account K prospectus.
Response: The disclosure has been revised as requested.
16. (Equitable America Variable Account K prospectus only). Please remove the reference to the Long-Term Care Services Rider on page 30, which does not appear to be offered under the Policy.
Response: The disclosure has been revised as requested.
17. (Separate Account FP prospectus only). When describing on page 31 the effects of a policy loan, please state that a loan, repaid or not, has a permanent effect on the cash surrender value and death benefit. Item 13(d) of Form N-6.
Response: The disclosure has been revised as requested.
Tax Information (pages 34-39)
18. Please confirm that, to the extent relevant, the tax discussion here and throughout the prospectus reflects any currently effective provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the COVID-Related Tax Relief Act of 2020, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the American Rescue Plan Act of 2021.
Response: The tax discussion throughout the prospectus reflects any currently effective provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the COVID-Related Tax Relief Act of 2020, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the American Rescue Plan Act of 2021 applicable to the policy.
Other Benefits Available Under the Policy (pages 40-45)
19. In the benefits table, please reconcile the statement in the fourth column of the Policy Continuation Rider description, which states that the policy is automatically placed on policy continuation, with the disclosure on page 44 of the prospectus, which states that the owner must elect to exercise the rider.
Response: The disclosure has been revised as requested.
20. When describing the Policy Continuation Rider beginning on page 44, please remove the cross-reference to the cash value accumulation test when describing the Policy Continuation charge, as this test is not relevant to the calculation of the charge. Please also remove this cross-reference from the Policy Continuation Rider charge discussion on page 50 of the prospectus.
Response: The disclosure has been revised as requested.
21. (Equitable America Variable Account K prospectus only). On page 42, please remove the reference to the Substitution of Insured Person Rider and the discussion on the Long- Term Care Services Rider, which do not appear to be offered under the Policy. Please also remove the Substitution of Insured Person Rider discussion and the Long-Term Care Services Rider reference on page 53.
Response: The disclosure has been revised as requested.
More Information About Policy Charges (pages 46-51)
22. When describing the premium charge, please remove the reference to the “death benefit option,” as there is only one death benefit offered under the Policy. Similarly, please remove the “death benefit option” reference in the first paragraph on page 65 describing personalized illustrations.
Response: The disclosure has been revised as requested.
23. Please revise the fourth paragraph of the surrender charge discussion as follows: (a) move the first two sentences on how the surrender charge will be deducted to the following discussion on requesting a decrease in face amount; (b) more clearly explain in the third sentence that the maximum surrender charge contained in the policy is shown for the first policy month of each policy year; (c) revise the fourth sentence as follows: “[t]he current_ maximum surrender charge is 6% of each premium, not to exceed an amount per $1,000 of initial base policy face amount, which will be between $20.63 and $55.87 per $1,000 of initial base policy face amount;” and (d) in the last sentence, please replace “cash value” with “net cash surrender value.”
Response: The disclosure has been revised as requested.
24. In the first and second paragraphs describing the mortality and expense risk charge, please clarify that the Company “will” (rather than “may”) collect and deduct this charge.
Response: The disclosure has been revised as requested.
25. In the Optional Rider Charges discussion, please disclose that there is no additional charge for the No-Lapse Guarantee Rider.
Response: The disclosure has been revised as requested.
Appendix: Calculating the Alternate Death Benefit
26. Please reconcile the Appendix heading – Calculating the Alternate Death Benefit – with the first sentence of the first paragraph, stating that the examples therein demonstrate how the standard death benefit is calculated.
Response: The disclosure has been revised as requested.
27. In the first paragraph, please remove the statement that the examples assume the owner selected the cash value accumulation test, as the Policy does not offer a choice.
Response: The disclosure has been revised as requested.
28. Please revise the fourth row in the table to clarify that the Standard Death Benefit for Policy 2 is $100,000, and add two rows to the table to depict the Alternate Death Benefit ($50,400 for Policy 1 and $122,400 for Policy 2) and the Death Benefit Paid ($100,000 for Policy 1 and $122,400 for Policy 2).
Response: The disclosure has been revised as requested.
Appendix: Examples of How the Policy Continuation Rider Works
29. (Equitable America Variable Account K prospectus only). As disclosed in this appendix to the Separate Account FP prospectus, please explain that after the policy goes on policy continuation, future premium payments, partial withdrawals and requested policy changes are not allowed, the policy does not lapse and continues in force during the illustrated year and in all subsequent years, and loan interest continues to be due on each policy anniversary, and if not paid when due, is added to the outstanding loan.
Response: The disclosure has been revised as requested.
Requesting More Information
30. Please replace the last three sentences of the back cover page with the statement required by Item 1(b)(3) of Form N-6 (i.e., “Copies of this information may be obtained, upon payment of a duplicating fee, by electronic request at the following email address: publicinfo@sec.gov.”).
Response: The disclosure has been revised as requested.
31. Please include the EDGAR contract identifier for the Policy on the bottom of the back cover page in type size smaller than that generally used in the prospectus (e.g., 8-point modern type). Item 1(b)(4) of Form N-6.
Response: The disclosure has been revised as requested.
INITIAL SUMMARY PROSPECTUS
General
32. Please apply all comments herein to the summary prospectus, as applicable.
Response: The disclosure has been revised as requested.
Cover Page
33. Please revise the first sentence of the first paragraph to clarify that the Policy is a variable and index-linked life insurance policy.
Response: The disclosure has been revised as requested.
34. In the fourth paragraph, please make clear that an investor could experience a significant loss of principal and previously credited interest in connection with the MSO. Please also provide a cross-reference to the MSO prospectus, and inform investors as to how to obtain the MSO prospectus.
Response: The disclosure has been revised as requested.
Important Information You Should Consider About the Policy (pages 3-5)
35. Certain cross-references in this section refer to other sections of the summary prospectus. Please provide cross-references to the location in the statutory prospectus where the subject matter is discussed in greater detail. Further, all cross-references should link directly to the relevant sections of the statutory prospectus, or should provide a means of facilitating access to that information through equivalent methods or techn
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CORRESP 1 filename1.htm CORRESP 1290 Avenue of the Americas New York, NY 10104 Julie Collett Senior Director and Counsel Julie.collett@equitable.com (303) 902-9135 July 27, 2021 VIA EDGAR Elisabeth Bentzinger, Esq. United States Securities and Exchange Commission Office of Insurance Products Division of Investment Management Mail Stop 8629 Washington, DC 20549-8629 Re: Separate Account FP Equitable Financial Life Insurance Company Initial Registration Statement on Form N-6 File Nos. 333-256251; 811-04335 Equitable America Variable Account K Equitable Financial Life Insurance Company of America Initial Registration Statement on Form N-6 File No. 333-256256; 811-22886 Dear Ms. Bentzinger: The purpose of this letter is to provide a response to the supplemental comments you provided with respect to the above-referenced filing for Equitable Financial Life Insurance Company and Equitable Financial Life Insurance Company of America (the “Companies”). For your convenience, I have included those comments below, and followed each comment with the Company’s response. Please see the revised Statutory Prospectuses and Initial Summary Prospectuses filed herewith. Request for Acceleration of the Effectiveness of the Registration Statement On behalf of the Registrant and the principal underwriters, Equitable Distributors, LLC and Equitable Advisors, LLC, we hereby request acceleration of the effectiveness of the Registration Statement, pursuant to Rule 461 under the 1933 Act, so that the Registration Statement will be declared effective on August 20, 2021, or as soon thereafter as practicable. In this connection, the Registrant and the principal underwriters, Equitable Distributors, LLC and Equitable Advisors, LLC, have authorized me to represent on their behalf that they are aware of their obligations under the 1933 Act. General 1. Please confirm that all missing information, including all exhibits, will be filed in a pre-effective amendment to each registration statement. We may have further comments when you supply the omitted information. Response: All missing information, including all exhibits, will be filed in a pre-effective amendment to each registration statement. 2. Please include an active hyperlink or other means of facilitating access that leads directly to each website address referenced in the registration statement, as well as all other information incorporated by reference, such as Form VPFS. See General Instruction C.3(i) to Form N-6; Rule 411 under the Securities Act of 1933 (the “1933 Act”); Rule 0-4 under the Investment Company Act of 1940. Response: All active hyperlinks will be included when we file for effectiveness. 3. Please provide powers of attorney that relate specifically to each registration statement as required by Rule 483(b) of the 1933 Act. Response: Updated powers of attorney will be included when we file for effectiveness. Cover Page 4. In the third sentence of the fourth paragraph, please clarify that in most states, the Company will refund the policy account value, plus any charges that were deducted, less any outstanding loan and accrued loan interest. Response: The disclosure has been revised as requested. Definition of Key Terms (pages 5-6) 5. Please remove the statement in the Alternative Death Benefit definition regarding there being a choice of a life insurance qualification test, as the Policy only offers one test. Further, please consistently refer to this death benefit as either the “alternative” death benefit or the “alternate” death benefit; both terms are currently used throughout the prospectus. Response: The disclosure has been revised as requested. Important Information You Should Consider About the Policy (pages 7-9) 6. When describing Insurance Company Risks, please note that any policy obligations, including under the fixed rate option and under the MSO, are subject to the Company’s claims-paying ability. Response: The disclosure has been revised as requested. 7. In the Policy Lapse section of the Risks table, please reconcile the statement that an owner may need to pay more premiums to keep the policy from terminating if the policy continuation feature is in effect with page 44 of the prospectus, which states that no further premiums are required if policy continuation takes effect. Response: The disclosure has been revised as requested. Overview of the Policy (pages 10-11) 8. To avoid investor confusion, please group the four riders under the Policy into one list, and make clear that (a) both the Policy Continuation Rider and the Living Benefits Rider have a charge associated with exercising the rider; (b) the Policy Continuation Rider is automatically issued to all policies; (c) the Living Benefits Rider is only added at issue to Policies with a face amount of at least $100,000, and there is a $100 charge for those who decline the rider but later elect it after issue; (d) the No-Lapse Guarantee Rider is automatically added to all policies (or clarify the “eligible policies” to which it is automatically added); and (e) the Policy Continuation Rider protects against policy termination if the net policy account value is insufficient to cover the monthly deductions (regardless of whether there is an outstanding loan). Response: The disclosure has been revised as requested, except that as one of the requirements for the Policy Continuation Rider at the time of exercise is for there to be an outstanding loan where policy loan and accrued loan interest exceeds the current base policy face amount. Fee Table (pages 12-14) 9. To avoid investor confusion, please remove the label “Current and Maximum Charge” from the wire transfer charge, express mail charge, duplicate policy charge, and charge for returned payments in the Transaction Fees table. With regard to the policy history charge, please remove the label “Current” as $50 is the maximum charge, but not the current charge. Response: The disclosure has been revised as requested. 10. In the fourth footnote to the Transaction Fees table, please include a cross-reference to the MSO prospectus. Response: The disclosure has been revised as requested. 11. Please format the footnote in the Transaction Fees table describing the declining surrender charge to be consistent with the other footnotes (i.e., indent the table; replace “**” with a number). Response: The disclosure has been revised as requested. 12. In the narrative preceding the Periodic Charges table, please remove the phrase “guaranteed maximum” consistent with the prescribed wording of Item 4 of Form N-6. Response: The disclosure has been revised as requested. 13. Please clarify that the charge for adding the Living Benefits Rider is deducted “Once – on the date the rider is exercised” rather than “At the time of the transaction,” consistent with the description of the Policy Continuation Rider charge. Response: The disclosure has been revised as requested. Payment of Premiums and Determining Your Policy’s Value (pages 22-26) 14. Page 23 of the prospectus states that the policy will not lapse if the policy “has an outstanding loan that would qualify for ‘policy continuation.’” Please revise this disclosure to clarify that the policy will not lapse if the conditions of the Policy Continuation Rider are satisfied, including that there is sufficient net policy account value to cover the Policy Continuation Charge, and provide a corresponding cross-reference. Response: The disclosure has been revised to clarify that the policy will not lapse if conditions of the Policy Continuation Rider are satisfied, including that there is sufficient net policy account value to cover the Policy Continuation Charge, with a correspondence cross-reference. Death Benefits and Accessing Your Money (pages 29-33) 15. When providing an example on page 29 of the alternative death benefit under the cash value accumulation test, please reconcile the 144.0% death benefit percentage in the Separate Account FP prospectus with the 140.0% death benefit percentage in the Equitable America Variable Account K prospectus. Response: The disclosure has been revised as requested. 16. (Equitable America Variable Account K prospectus only). Please remove the reference to the Long-Term Care Services Rider on page 30, which does not appear to be offered under the Policy. Response: The disclosure has been revised as requested. 17. (Separate Account FP prospectus only). When describing on page 31 the effects of a policy loan, please state that a loan, repaid or not, has a permanent effect on the cash surrender value and death benefit. Item 13(d) of Form N-6. Response: The disclosure has been revised as requested. Tax Information (pages 34-39) 18. Please confirm that, to the extent relevant, the tax discussion here and throughout the prospectus reflects any currently effective provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the COVID-Related Tax Relief Act of 2020, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the American Rescue Plan Act of 2021. Response: The tax discussion throughout the prospectus reflects any currently effective provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the COVID-Related Tax Relief Act of 2020, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the American Rescue Plan Act of 2021 applicable to the policy. Other Benefits Available Under the Policy (pages 40-45) 19. In the benefits table, please reconcile the statement in the fourth column of the Policy Continuation Rider description, which states that the policy is automatically placed on policy continuation, with the disclosure on page 44 of the prospectus, which states that the owner must elect to exercise the rider. Response: The disclosure has been revised as requested. 20. When describing the Policy Continuation Rider beginning on page 44, please remove the cross-reference to the cash value accumulation test when describing the Policy Continuation charge, as this test is not relevant to the calculation of the charge. Please also remove this cross-reference from the Policy Continuation Rider charge discussion on page 50 of the prospectus. Response: The disclosure has been revised as requested. 21. (Equitable America Variable Account K prospectus only). On page 42, please remove the reference to the Substitution of Insured Person Rider and the discussion on the Long- Term Care Services Rider, which do not appear to be offered under the Policy. Please also remove the Substitution of Insured Person Rider discussion and the Long-Term Care Services Rider reference on page 53. Response: The disclosure has been revised as requested. More Information About Policy Charges (pages 46-51) 22. When describing the premium charge, please remove the reference to the “death benefit option,” as there is only one death benefit offered under the Policy. Similarly, please remove the “death benefit option” reference in the first paragraph on page 65 describing personalized illustrations. Response: The disclosure has been revised as requested. 23. Please revise the fourth paragraph of the surrender charge discussion as follows: (a) move the first two sentences on how the surrender charge will be deducted to the following discussion on requesting a decrease in face amount; (b) more clearly explain in the third sentence that the maximum surrender charge contained in the policy is shown for the first policy month of each policy year; (c) revise the fourth sentence as follows: “[t]he current_ maximum surrender charge is 6% of each premium, not to exceed an amount per $1,000 of initial base policy face amount, which will be between $20.63 and $55.87 per $1,000 of initial base policy face amount;” and (d) in the last sentence, please replace “cash value” with “net cash surrender value.” Response: The disclosure has been revised as requested. 24. In the first and second paragraphs describing the mortality and expense risk charge, please clarify that the Company “will” (rather than “may”) collect and deduct this charge. Response: The disclosure has been revised as requested. 25. In the Optional Rider Charges discussion, please disclose that there is no additional charge for the No-Lapse Guarantee Rider. Response: The disclosure has been revised as requested. Appendix: Calculating the Alternate Death Benefit 26. Please reconcile the Appendix heading – Calculating the Alternate Death Benefit – with the first sentence of the first paragraph, stating that the examples therein demonstrate how the standard death benefit is calculated. Response: The disclosure has been revised as requested. 27. In the first paragraph, please remove the statement that the examples assume the owner selected the cash value accumulation test, as the Policy does not offer a choice. Response: The disclosure has been revised as requested. 28. Please revise the fourth row in the table to clarify that the Standard Death Benefit for Policy 2 is $100,000, and add two rows to the table to depict the Alternate Death Benefit ($50,400 for Policy 1 and $122,400 for Policy 2) and the Death Benefit Paid ($100,000 for Policy 1 and $122,400 for Policy 2). Response: The disclosure has been revised as requested. Appendix: Examples of How the Policy Continuation Rider Works 29. (Equitable America Variable Account K prospectus only). As disclosed in this appendix to the Separate Account FP prospectus, please explain that after the policy goes on policy continuation, future premium payments, partial withdrawals and requested policy changes are not allowed, the policy does not lapse and continues in force during the illustrated year and in all subsequent years, and loan interest continues to be due on each policy anniversary, and if not paid when due, is added to the outstanding loan. Response: The disclosure has been revised as requested. Requesting More Information 30. Please replace the last three sentences of the back cover page with the statement required by Item 1(b)(3) of Form N-6 (i.e., “Copies of this information may be obtained, upon payment of a duplicating fee, by electronic request at the following email address: publicinfo@sec.gov.”). Response: The disclosure has been revised as requested. 31. Please include the EDGAR contract identifier for the Policy on the bottom of the back cover page in type size smaller than that generally used in the prospectus (e.g., 8-point modern type). Item 1(b)(4) of Form N-6. Response: The disclosure has been revised as requested. INITIAL SUMMARY PROSPECTUS General 32. Please apply all comments herein to the summary prospectus, as applicable. Response: The disclosure has been revised as requested. Cover Page 33. Please revise the first sentence of the first paragraph to clarify that the Policy is a variable and index-linked life insurance policy. Response: The disclosure has been revised as requested. 34. In the fourth paragraph, please make clear that an investor could experience a significant loss of principal and previously credited interest in connection with the MSO. Please also provide a cross-reference to the MSO prospectus, and inform investors as to how to obtain the MSO prospectus. Response: The disclosure has been revised as requested. Important Information You Should Consider About the Policy (pages 3-5) 35. Certain cross-references in this section refer to other sections of the summary prospectus. Please provide cross-references to the location in the statutory prospectus where the subject matter is discussed in greater detail. Further, all cross-references should link directly to the relevant sections of the statutory prospectus, or should provide a means of facilitating access to that information through equivalent methods or techn