SEC Company Response from Jackson National Life Insurance Co (RILA) (CIK 0002047976) — Apr 15, 2026
Jackson National Life Insurance Co (RILA) (CIK 0002047976)
Date: April 15, 2026 · CIK: 0002047976 · Accession: 0002047976-26-000096
AI Filing Summary & Sentiment
File numbers found in text: 333-292237, 333-292238, 333-292244, 333-292247
Letter
04-2026 JNL and NY JMLP/JMLPA 4 - N4 SEC Comment Letter
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:April 15, 2026
SUBJECT:Response to Comment 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 comment you provided verbally on April 15, 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 comment and response applies to all registration statements referenced above.
Pre-effective amendments to the above-referenced registration statements will subsequently be filed in response to the
comment.
Distribution of Contracts
1.In response to Comment 29 provided by the staff on February 23, 2026, you provided a supplemental explanation on
the distinction between Independent Registered Investment Advisors and Registered Investment Advisors. Please
include this explanation in the Distribution of Contracts section prospectus where reference is made to Independent
Registered Investment Advisors.
Response: We have incorporated this explanation into the Distribution of Contracts section as follows:
"When a contract is offered to persons who are also customers of an Independent
Registered Investment Advisor, JNLD may act in its capacity as a Selling Firm and be
responsible for delivering disclosure documents and making recommendations that are in
the best interest of the customer. 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. Neither JNLD nor
the Independent Registered Investment Advisors receive commission when one of their
customers purchases a contract from JNLD. JNLD will not make marketing support
payments to Independent Registered Investment Advisors if the payment or non-cash
compensation is preconditioned on achievement of a sales target or on achievement of
maintaining a level of premium with Jackson." (Emphasis added for the purpose of
highlighting the new disclosure.)
Please contact me at (517) 367-3754 if you have any questions or require additional information.
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04-2026 JNL and NY JMLP/JMLPA 4 - N4 SEC Comment Letter
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:April 15, 2026
SUBJECT:Response to Comment 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 comment you provided verbally on April 15, 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 comment and response applies to all registration statements referenced above.
Pre-effective amendments to the above-referenced registration statements will subsequently be filed in response to the
comment.
Distribution of Contracts
1.In response to Comment 29 provided by the staff on February 23, 2026, you provided a supplemental explanation on
the distinction between Independent Registered Investment Advisors and Registered Investment Advisors. Please
include this explanation in the Distribution of Contracts section prospectus where reference is made to Independent
Registered Investment Advisors.
Response: We have incorporated this explanation into the Distribution of Contracts section as follows:
"When a contract is offered to persons who are also customers of an Independent
Registered Investment Advisor, JNLD may act in its capacity as a Selling Firm and be
responsible for delivering disclosure documents and making recommendations that are in
the best interest of the customer. 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. Neither JNLD nor
the Independent Registered Investment Advisors receive commission when one of their
customers purchases a contract from JNLD. JNLD will not make marketing support
payments to Independent Registered Investment Advisors if the payment or non-cash
compensation is preconditioned on achievement of a sales target or on achievement of
maintaining a level of premium with Jackson." (Emphasis added for the purpose of
highlighting the new disclosure.)
Please contact me at (517) 367-3754 if you have any questions or require additional information.