Correspondence 0001104659-24-086226 from Forethought Life Insurance Co (CIK 0001791963)
Forethought Life Insurance Co (CIK 0001791963)
Date: Aug. 6, 2024 · CIK: 0001791963 · Accession: 0001104659-24-086226
AI Filing Summary & Sentiment
File numbers found in text: 333-276707
Letter
Division of Investment Management, Disclosure Review Office 100 F Street, NE Washington, DC 20549-8629 Re: Forethought Life Insurance Company Registration Statement on Form S-1 (File No. 333-276707) for the ForeStructured Growth II and the ForeStructured Growth II Advisory Contracts, Individual Single Premium Deferred Index-Linked Annuity Contracts
Dear Ms. Rowland:
On January 26, 2024, Forethought Life Insurance Company (the “Company,” “we,” “us,” “our”) filed the above-referenced registration statement (the “Registration Statement”) for the ForeStructured Growth II and the ForeStructured Growth II Advisory Contracts (the “Contracts”), a new product offering by the Company. Previously, on May 9, June 26, and July 30, 2024, the Company filed correspondence responding to staff comments. On August 2, 2024, via telephone, you provided additional staff comments on the Registration Statement. Below please find the staff’s additional comments in bold followed by the Company’s responses thereto. The Company has separately filed pre-effective amendment no. 1 to the Registration Statement reflecting the Company’s responses to the staff’s additional comments. The Company has requested acceleration of effectiveness for no later than August 12, 2024.
COMMENTS
1. On page 62, when explaining how the MVA was calculated in the preceding examples, please remove reference to the minimum non-forfeiture amount.
The above-referenced disclosure has been deleted.
2. In Appendix H, please clarify that the examples relate to the surrender of amounts in an Indexed Strategy and remove all references to the minimum non-forfeiture amount. For clarity, please also specify an Indexed Strategy to which the examples relate.
The prospectus has been revised accordingly.
* * *
Thank you for conveying the Commission staff’s comments. The Company appreciates the Commission staff’s attention to this filing. Please let the undersigned know if you have any questions.
Kind Regards,
/s/ Sarah M. Patterson
Forethought Life Insurance Company
Managing Director, General Counsel for Individual Markets, and Assistant Secretary
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CORRESP 1 filename1.htm Sarah M. Patterson Managing Director General Counsel for Individual Markets and Assistant Secretary Legal Department Direct Dial: (860) 325-1538 August 6, 2024 Ms. Emily Rowland U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street, NE Washington, DC 20549-8629 Re: Forethought Life Insurance Company Registration Statement on Form S-1 (File No. 333-276707) for the ForeStructured Growth II and the ForeStructured Growth II Advisory Contracts, Individual Single Premium Deferred Index-Linked Annuity Contracts Dear Ms. Rowland: On January 26, 2024, Forethought Life Insurance Company (the “Company,” “we,” “us,” “our”) filed the above-referenced registration statement (the “Registration Statement”) for the ForeStructured Growth II and the ForeStructured Growth II Advisory Contracts (the “Contracts”), a new product offering by the Company. Previously, on May 9, June 26, and July 30, 2024, the Company filed correspondence responding to staff comments. On August 2, 2024, via telephone, you provided additional staff comments on the Registration Statement. Below please find the staff’s additional comments in bold followed by the Company’s responses thereto. The Company has separately filed pre-effective amendment no. 1 to the Registration Statement reflecting the Company’s responses to the staff’s additional comments. The Company has requested acceleration of effectiveness for no later than August 12, 2024. COMMENTS 1. On page 62, when explaining how the MVA was calculated in the preceding examples, please remove reference to the minimum non-forfeiture amount. The above-referenced disclosure has been deleted. 2. In Appendix H, please clarify that the examples relate to the surrender of amounts in an Indexed Strategy and remove all references to the minimum non-forfeiture amount. For clarity, please also specify an Indexed Strategy to which the examples relate. The prospectus has been revised accordingly. * * * Thank you for conveying the Commission staff’s comments. The Company appreciates the Commission staff’s attention to this filing. Please let the undersigned know if you have any questions. Kind Regards, /s/ Sarah M. Patterson Forethought Life Insurance Company Managing Director, General Counsel for Individual Markets, and Assistant Secretary