Product Specification

Status: Draft, 2026-08-04 (all cited sources accessed 2026-08-04).

Scope note. A standardized composite specification for reference liability cash-flow modeling; not any single insurer’s product. [S#] (primary product documents) and [R#] (regulatory/actuarial references) are numbered per _research/deferred-income-annuity.md. [REG-R#] resolves against the cross-product library references/regulatory-and-actuarial-references.md, whose shared numbering now runs R1–R157 as one space, with most of the R73–R149 block unused: R1–R34 of life origin (provenance _research/regulatory-actuarial.md), R35–R72 annuity-specific (provenance _research/regulatory-actuarial-annuities.md), and R150–R157 the AP&P Manual appendix and actuarial-guideline prints read on 2026-08-06. std marks standardizations introduced for the reference implementation; every std table row carries a footnote giving the rationale and the observed range. unverified marks claims not confirmed against a retrieved document.

Representative design. Base case = the MassMutual RetireEase Choice / Guardian SecureFuture archetype S2 S3: flexible premium, each premium buying a guaranteed paid-up income slice at then-current purchase rates, return of premium on death in deferral on every option except Life Only, a one-time ±5-year income start date adjustment, an optional 1–4% annual increase, and payment acceleration as the only in-force liquidity. Pacific Secure Income S4 S5 is the extended case, adding commutation. The QLAC overlay is a restriction set on the base case.

Structural warning, up front. A DIA has no account value — no credited rate, no index crediting, no M&E or rider charge, no surrender charge, no free-withdrawal corridor, no market value adjustment, no benefit base, no interim value. See “Parameters that do not exist for this product”; do not carry empty parameter tables for them. Income-phase mechanics are not restated here: once income begins a DIA is a single-premium immediate annuity, and payout forms, refund mechanics, survivor reduction, COLA escalation and survivorship weighting are specified in products/immediate_annuity/product-spec.md and products/immediate_annuity/technical-notes.md. This document specifies the deferral phase, the transition to income and the QLAC overlay.

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Product overview and market role

VM-01 defines a DIA as “an annuity contract that guarantees a periodic payment for the life of the annuitant or a term certain and payments begin 13 months or later from the issue date if the contract holder and/or annuitant survives to a predetermined future age” R9. The Insurance Compact’s uniform standard states the same architecture contractually: an individual deferred paid-up non-variable annuity “with no cash surrender values prior to the commencement of annuity payments”, single or flexible premiums, “specified income payments beginning on a specified income commencement date for each premium paid”, all funds in the general account R13.

The fact that drives every modeling decision: each premium immediately and irrevocably buys a fully guaranteed paid-up annuity — “All income benefits, based on the specified income commencement date and specified income option associated with each premium paid, shall be guaranteed” R13 §3.H(1) — and the slices are combined into one payment stream at the income start date S1 S2 S3 S4. Guardian states it plainly: “Each payment purchases a specific amount of guaranteed lifetime income, based on annuity purchase rates that are in effect at the time each purchase payment is made” S3.

The contract states dollars of income, not rates, and the Compact expressly relieves the insurer of disclosure: “Since the premium and income benefit are fully defined in the contract, the mortality table and interest rate used in the deferral period and for determining the contractually specified income payable do not need to be disclosed in the contract or the Actuarial Memorandum” R13 §1.B(1)(a). No purchase-rate table or income-per-$100,000 figure was obtained from any source, so the purchase-rate function in technical-notes.md is an explicit std construction. The product is sold as pure longevity insurance with no fees and no market performance to track, to a client “between the ages of 50 and 65 and ready to retire in five to 10 years” with “$250,000 and $1.5 million” in investable assets S2; the qualified-money variant, the QLAC, additionally removes the contract’s value from the RMD account balance R4 R5.

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Representative specification

Product identity and issue rules

Parameter	Representative value	Basis
Design type	Flexible-premium deferred paid-up non-variable annuity; general account only; irrevocable	R13 S2 S3
Participation	Non-participating (no dividends)	std (1)
Contract nature	No cash surrender value, no withdrawals, no loans before the income start date	S1 S2 R13 §3.P
Market types	Nonqualified; Traditional / Roth / SEP / Custodial IRA; QLAC IRA and Custodial QLAC IRA	S2 S4
Market type — base model	Nonqualified, with QLAC as an overlay switch	scope std (2)
Age basis	Age nearest birthday (“74 years, six months and one day old ⇒ contract issue age 75”)	S2
Minimum issue age (annuitant)	22	S2 S4
Maximum issue age — nonqualified and Roth IRA	85	std (3)
Maximum issue age — traditional IRA	73	std (4)
Issue ages — QLAC	41–83	S2; band std (5)
Annuitants	Up to two; cannot be changed after issue; joint annuitant must be a spouse	S2 S4
Income option	Elected at issue; cannot be changed thereafter	S1 S2 S4
Anchor model cell	Female 60 ANB, nonqualified, $100,000 at issue + $50,000 at policy year 6, income start age 80, Life with Cash Refund, monthly	std (6)

1. No retrieved product is participating. The Compact contemplates one, pricing dividend-purchased income either on “current annuity purchase rates” or on the rates used for the related premium R13 §3.T; a participating form would also lose the Model #245 §3.A exemption (Regulatory context) R11.

2. All four insurers issue both S1 S2 S3 S4. The nonqualified form carries the fullest feature set (acceleration and commutation are nonqualified-only S1 S2 S4), so QLAC is modeled as a restriction set.

3. Observed: 80 S1 S3, 85 S4, 88 S2; 80–88 across S6. 85 coincides with the modal maximum income-start age (footnote 11) and the QLAC ceiling, keeping one age cap in the model rather than three. It is not the binding constraint: the 13-month minimum deferral (footnote 9) together with the age-85 income-start cap (footnote 11) makes the effective maximum issue age 83 ANB — the same ceiling the QLAC band carries (footnote 5) — so the 85 row never binds on its own.

4. Observed: 68 S3, 2018, 69 S2, 2019 — both pre-SECURE-vintage documents keyed to an RMD age of 70½ and superseded by the current applicable RMD ages of 73/75 S1 S4 — 71 S4, 73 S1 S6. 73 is the post-SECURE representative; the mechanism behind it is NYL’s rule that issue age is “no later than 2 years before the client’s RMD age” S1.

5. Observed minima 31 S3, 35 S1, 41 S2; maxima 80 S1, 82 S3 S4, 83 S2 S6. The archetype’s band is adopted. The minimum is purely a product rule — the regulation sets only the age-85 outside date R1 (q)(1)(ii).

6. Pure modeling choice, carried identically into technical-notes.md. Age 60 with a 20-year deferral sits inside the stated target market S2; two premiums exercise the slice mechanic; Cash Refund is permitted on both nonqualified contracts and QLACs S2.

Premium

Parameter	Representative value	Basis
Premium pattern	Flexible: any number of premiums during the deferral period	S2 S3 S4 R13
Minimum initial premium	$10,000	S1 S2 S3 S6
Minimum subsequent premium	$500	std (7)
Maximum cumulative premium without home-office approval	$1,500,000	std (8)
Cut-off for subsequent premiums	None accepted within 13 months of the income start date	S2 S4
Cut-off for 1035 exchanges / transfers	16 months before the income start date	S4
Pricing of each premium	Company’s then-current annuity purchase rates, by attained age, income start date and income option	R13 §3.B(1)(b) S3
Floor on current purchase rates	Income purchased must be not less than that in a new contract of the same class, attained age and commencement date	R13 §3.B(1)(c)
Confirmation of each subsequent premium	Premium, additional income purchased, option and start date, within 30 days	R13 §3.B(1)(d)
Free look on each subsequent premium	Cancel by returning the confirmation within 10 calendar days; premium refunded	S2 S3 R13 §3.B(1)(d)
Minimum monthly income payment	$100	S2
QLAC aggregate premium limit — 2026	$210,000	R3 S4
Aggregation of cumulative-premium limits	Across all DIAs of the insurer group with the same owner or annuitant	S2

7. Observed: $100 S1 S3, $500 S2 S4. $500 is taken with the MassMutual/Pacific pair because it produces materially fewer slices in a flexible-premium projection; the choice changes no mechanic.

8. Observed: $1,000,000 S3, $1,500,000 S2, $2,000,000 S1 S4. The archetype’s value is taken. All four are soft limits — larger amounts require home-office approval, not prohibition S1 S2 S3 S4.

Deferral period and income start date

Parameter	Representative value	Basis
Minimum deferral	13 months from contract issue	std (9)
Maximum deferral	30 years from contract issue	std (10)
Maximum income start age — nonqualified and Roth	85	std (11)
Maximum income start — traditional IRA	April 1 of the year following the year the owner attains the applicable RMD age (73, or 75 for owners born in 1960 or later)	S1 S4
Income start ceiling — QLAC	Annuity starting date no later than the first day of the month next following the 85th anniversary of the owner’s birth	R1 (q)(1)(ii) S1 S2 S3 S4 REG-R57
Income start floor — QLAC	After the required beginning date. This is a product rule, not a QLAC rule — the regulation sets no earliest commencement date	S1 S2
Income start day of month	Any day between the 1st and the 28th	S2
Payment frequency menu	Monthly, quarterly, semiannual, annual	S1 S2 S3 S4
Payment frequency — base model	Monthly, fixed at issue, not changeable	S1 S2; choice std (12)
Payment timing — base model	Arrears (payment at the end of each payment period)	std (13)

9. Two conventions coexist: 13 months S2 S4, matching the VM-01 statutory floor R9 and the Florida annuitization mandate S2; 24 full months S1 S3. Fidelity’s current table lists Guardian at 13 months S6 — a conflict the research file could not resolve because no current Guardian primary document could be retrieved S9 S11; both figures stand on the record. 13 months is chosen as the regulatory minimum and the more common design.

10. Observed: 30 years S2 S4, 40 years S1 S3, both across five insurers S6. 30 is taken with the archetype; in practice the maximum income-start age binds first.

11. Observed: 85 S1 S3 S6, 90 S2 S4. 85 is modal, matches the regulation-fixed QLAC ceiling R1 (q)(1)(ii) and keeps one age cap across market types (footnote 3).

12. All four insurers offer all four frequencies S1 S2 S3 S4. Fixed at issue at NYL S1 and MassMutual — it cannot change even on an annuity-date adjustment S2 — but changeable at Guardian S3. The fixed-at-issue convention is adopted.

13. No retrieved DIA document states advance versus arrears. Arrears matches products/immediate_annuity/product-spec.md so one payout chassis serves both products; the model exposes pay_timing ∈ {advance, arrears}.

Income start date adjustment (the principal in-force option)

Parameter	Representative value	Basis
Direction and magnitude	One-time change, up to 5 years earlier or 5 years later	S1 S2 S3 S4
Number of exercises	Once over the life of the contract; new date irrevocable	S2; count std (14)
Floor on the new date	At least 13 months after the most recent premium payment	S1 S2 S3 S4
Ceiling on the new date	Within the maximum deferral period and the maximum income-start age	S1 S2 S4
What cannot change	Income option; day of month; payment frequency	S1 S2
Minimum resulting payment	$100 monthly	S2
Excluded forms	Life Only and Joint Life Only; Pacific Life additionally excludes Joint and Survivor Life Only and Period Certain	S1 S3 S4
Repricing basis	Originally scheduled payment; new annuity date; Moody’s Seasoned Baa Corporate Bond Yield at the request date; Annuity 2012 Mortality Table; plus an interest rate change adjustment set forth in the contract	S2 (NYL states the same construction against the A2000 tables S1)
Direction of income impact	Advancing the date reduces the payment; deferring increases it	S4 S5
Explicit charge for the change	None disclosed; any charge must be disclosed	S1 S2 S3 S4 R13 §§3.M, 1.B(1)(d)

14. One-time at all four insurers S1 S2 S3 S4; Guardian adds a one-time right to accelerate back after a deferral S3; Western & Southern allows two changes, the only multi-change design identified S6. One exercise is adopted and the count is exposed.

Income options (payout forms)

Parameter	Representative value	Basis
Single-life forms	Life Only (no death benefit in either phase); Life with Cash Refund; Life with Installment Refund; Life with Period Certain	S2 S4
Unbundled variant	Life Only with 100% Return of Purchase Payments Death Benefit — ROP in deferral, pure life annuity after income start	S4
Period certain range	10–30 years	S2; range std (15)
Joint forms	Each single-life form in a joint version with survivor reduction	S2 S4
Survivor percentage menu	50%, 66⅔%, 75%, 100%	S1 S2 S4; menu std (16)
Reduction trigger	Switch: reduction on the death of either annuitant, or of the primary annuitant only	S1 S2 S4
Joint × certain-period interaction	If the first annuitant dies inside a guaranteed period, payments to the survivor are not reduced until the end of that period	S1 S3
Convertible joint	Switch; convertible options guarantee two payouts — joint, and the corresponding single-life payout on conversion — so the joint payout is lower	S2; base = non-convertible std (17)
Convertible joint — period certain limit	10 years	S2
Refund mechanics	Cash Refund: lump-sum shortfall of premiums over payments made. Installment Refund: payments continue in the same amount and frequency until they equal the premiums. Period Certain: payments continue to the end of the certain period. Beneficiary may elect the present value instead under Installment Refund and Period Certain	S1 S2 S3
Compact framing of refunds	Income payments made before a return-of-premium death benefit “shall be considered period certain income”	R13 definitions

15. Observed: 5–30 years S1 period-certain-only, S3, 10–30 years S1 life-with-guarantee, S2, up to 30 years S4. The Compact floor is five years minimum with a twenty-year maximum deferral for a period-certain-only contract R13 §3.H(3). 10–30 is taken with the archetype; period-certain-only is out of base scope.

16. Observed: 100/66⅔/50% S1; ½, ⅔, ¾ S2; 50/67/75% S4. The union {50, 66⅔, 75, 100} is adopted, which is exactly the set carried in products/immediate_annuity/product-spec.md so the two payout chassis share one menu; 100% must be retained because it is the only continuance NYL permits on a joint Cash Refund form S1 — the joint counterpart of the anchor cell’s payout form.

17. Non-convertible is the simpler pricing equation and the default at three of four insurers. MassMutual alone exposes the distinction and its pricing consequence S2 — the most model-relevant pricing subtlety in the family — and it is specified as a switch in technical-notes.md.

Death benefit during the deferral period (the central design fork)

Parameter	Representative value	Basis
Base form	100% return of premiums paid, no interest, lump sum	S1 S2 S3 S4 R13 §3.I(1)(a)
Applies to	All income options except Life Only and Joint Life Only	S1 S3 S4
No-death-benefit form	Single Life — No Death Benefit: no death benefit before or after the income start date	S2
No-death-benefit form — conditions	Deferral period of 10 years or longer; income start date cannot be changed; state restrictions apply	S2 (18)
Trigger	Death of the owner (or of the annuitant where the owner is a non-natural person)	S1 S3 S4
Permitted calculation methods	(a) percentage of premiums paid; (b) percentage of premiums paid plus interest; (c) flat dollar amount; (d) any combination	R13 §3.I(1)
Application to subsequent premiums	Must be provided for both the initial premium and any additional premiums	R13 §3.I(2)
Charges used in determining the death benefit	None disclosed in any retrieved source; any such charge must appear on the specifications page	S1 S2 S3 S4 R13 §2.B(2)
Spousal continuation	Where the surviving spouse is joint annuitant and sole primary beneficiary the contract may continue instead of paying the benefit; on non-convertible continuation no further premiums are allowed	S1 S2 S4
Terminal-illness acceleration	Death benefit payable on diagnosis with life expectancy of 12 months or fewer (except Life Only forms)	S4; out of base scope
Cover-page disclosure — no death benefit	“The contract does not provide access to funds prior to the income commencement date. No death benefit is available to a beneficiary if the annuitant dies prior to the income commencement date.”	R13 §2.A(8) R10 §9
Cover-page disclosure — with death benefit	“The contract does not provide access to funds prior to the income commencement date other than payment of the death benefit.”	R13 §2.A(9)

18. The research file records an unresolved internal inconsistency: the option is said to be unavailable in “Connecticut or New York” in the body of the MassMutual guide and in “Connecticut or Florida” in its footnotes and product highlights S2. Both stand; neither is asserted. Separately, no source offered a “percentage of premiums plus interest” deferral death benefit, though the Compact permits it R13 §3.I(1)(b).

Annual increase (COLA)

Parameter	Representative value	Basis
Menu	1%, 2%, 3% or 4%	S2; menu std (19)
Base model election	None (0%); 2% in the COLA variant	scope std (19)
Mechanics	Fixed compound increase on each anniversary of the income start date	S2 S3 S4
Election	At issue only; cannot be cancelled or changed	S1 S2 S3 S4
Trade-off	Initial payments are smaller than on an otherwise identical contract	S1 S2 S4
Age condition	Owner at least 59½ at the first income payment	S1
Availability on QLAC	Not offered	S1 S3 S4 (20)
Availability on other qualified contracts	May be limited or unavailable because of RMD rules	S2 S3 S4
Index linkage	None — every observed option is a fixed compound escalator, not CPI-linked	S1 S2 S3 S4

19. Observed: 1–3% S1, and USAA per S6, 1–4% S2, 2/3/4% S4, 1–5% [Guardian and Western & Southern per S6]. The archetype’s 1–4% is adopted; the base model runs at 0% so the payout stream is level, and exposes cola_rate.

20. Correction worth stating: a QLAC “does not fail” the not-variable/not-indexed requirement “merely because it provides for a cost-of-living adjustment as described in paragraph (o)(2)” R1 (q)(4)(iv). The market is more restrictive than the regulation — NYL, Guardian and Pacific Life all exclude COLA from their QLAC offering S1 S3 S4 and MassMutual limits it on qualified contracts S2.

Liquidity

Parameter	Representative value	Basis
Cash surrender value	None, at any time before the income start date	S1 S2 R13 scope
Withdrawals before income start	None	S1 S2
Loans	Prohibited by the uniform standard	R13 §3.P
Payment acceleration — amount	Next scheduled monthly payment plus five subsequent payments = six months of income in one sum; no payments for the following five months	S1; three-or-six variant S2 S4
Payment acceleration — uses	2 over the life of the contract	std (21)
Payment acceleration — conditions	Owner at least 59½; monthly frequency; nonqualified only; at least one regular payment between uses	S1 S2 S4
Payment acceleration — characterization	Expressly “not a liquidity feature” — a timing shift, not a withdrawal	S2
Payment acceleration on QLAC	Not available	S4
Commutation — base model	Not offered	S1 S2 S3
Commutation — extended model	Up to 100% of the present value of remaining guaranteed income payments; nonqualified only; 59½ or older; an interest-rate adjustment charge applies; no limit on the number of withdrawals; life-contingent tail preserved (payments resume at the end of the would-be guaranteed period if the annuitant is living)	S4 S5
Commutation — regulatory frame	Lump sum only; non-commuted benefits unaffected; must be an actuarial present value; the interest rate “can be adjusted for changes in interest rates … between the issue date and the commutation date”, intended “to reduce interest risk in the event of rising interest rate after issue”	R13 §§3.F(1)–(7)
Commutation on QLAC	Prohibited after the required beginning date, other than a rescission right not exceeding 90 days from purchase	R1 (q)(1)(iv) R2 §202(a)(4) REG-R57
Feature interlocks	Six-month waiting periods interlock acceleration, commutation and the start-date adjustment in both directions	S4

21. Observed: 1 use S3, 2 uses S1 S4, 5 uses S2. Two is modal and is adopted; the count is a parameter. Eligibility also differs — Guardian requires a guarantee or cash-refund period with at least six months remaining S3, and Pacific Life requires the acceleration period to fall in the same tax year on qualified contracts S4.

Parameters that do not exist for this product

An implementer arriving from a fixed, indexed or variable deferred annuity chassis will look for the following and must not find them. Their absence is a structural feature confirmed at contract level, not a research gap S1 fn.1 S2 product highlights S4 R13.

Parameter class	Status
Account value / accumulation value	Does not exist. “There is also no accumulation or cash value with RetireEase Choice and, therefore, no liquidity” S2
Credited or declared interest rate; guaranteed minimum crediting rate	Do not exist. The contract states dollars of income, and the deferral-period interest and mortality basis need not be disclosed at all R13 §1.B(1)(a)
Index crediting parameters — caps, participation rates, spreads, buffers, floors, index terms	Do not exist. The product is non-variable and non-indexed; a QLAC is additionally required not to be indexed R1 (q)(1)(vii)
M&E charge, administrative charge, contract fee, rider charges	Do not exist. No retrieved document discloses any explicit charge — “There are no fees” S2. Pricing margin is embedded in the purchase rate R13 §1.B(1)(a)
Surrender charge schedule; free-withdrawal corridor	Do not exist. There is nothing to surrender S1 S2 R13
Market value adjustment	Does not exist. The nearest analogue is the interest-rate adjustment on commutation in the extended case S4 R13 §3.F(7)
Benefit base, roll-up, step-ups, withdrawal percentages by attained-age band	Do not exist. There is no living-benefit rider layer; the income guarantee is the contract
Interim value	Does not exist (an AG 54 concept for index-linked variable annuities REG-R44)
Lapse / surrender assumption	Not applicable. For contracts with “no account value or surrender benefit, such as some contracts within the Payout Annuity Reserving Category …, this section is not applicable” R9
Annuitization rate assumption	Prescribed at 0% at all projection intervals R9; the contract annuitizes by construction at the income start date
Policy loan parameters	Prohibited R13 §3.P
Premium / persistency bonus	Not offered by any retrieved product S1 S2 S3 S4

The only non-guaranteed quantity in the product is the current annuity purchase rate applied to a future premium R13 §3.B(1)(b)–(c), and even that is floored at the rate a new contract of the same class receives.

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Contractual mechanics

Premium and the income-slice mechanic. Each premium k paid at time t_k generates a paid-up annuity priced on “the attained age of the annuitant, the specified income commencement date and specified income option, and the company’s then current annuity purchase rates” R13 §3.B(1)(a)–(b), so the guaranteed annual income at the income start date is

B  =  sum over k of  P_k  x  pr( x + t_k , T - t_k , f )

with pr(.) the purchase rate (annual income per dollar of premium), x + t_k the attained age at payment, T - t_k the remaining deferral and f the income option elected at issue. Because purchase rates are set at each payment and are never published, pr(.) is a std construction — see technical-notes.md.

Deferral-phase death benefit. On death of the owner (or of the annuitant where the owner is an entity) before the income start date the benefit is a lump-sum return of premiums paid, without interest S1 S2 S3 S4:

DB_deferral  =  100%  x  (cumulative premiums paid to the date of death)

payable on every option except Life Only and Joint Life Only, which carry no death benefit either before or after the income start date S1 S3 S4. Economics of the fork: with ROP, deferral mortality is close to neutral (the premium comes back); without it, deferral deaths release the entire reserve as mortality gain — which is why the no-death-benefit form buys materially more income for the same premium and why it is conditioned on a deferral of ten years or longer S2; derived from S1–S4, R13.

Income start date adjustment. Payments are recalculated on actuarial-equivalence inputs MassMutual discloses in full: “Your originally scheduled annuity payment; the new annuity date; Moody’s Seasoned Baa Corporate Bond Yield rate at the time we receive the annuity date change request; the Annuity 2012 Mortality Table; an interest rate change adjustment set forth in the contract” S2; NYL states the same construction against the A2000 tables S1. Advancing reduces the payment, deferring increases it S4 S5. Where a change right is granted the contract must disclose the alternatives, the timing and frequency limits and any explicit charge, and must either state the mortality and interest assumption used for actuarial equivalence or contain a table of alternative income benefits R13 §§3.M, 3.H(1).

Transition to income. On the income start date the slices are paid as one stream in the form elected at issue S1 S2 S3 S4 and the contract becomes a SPIA — mechanics in products/immediate_annuity/product-spec.md. Two DIA-specific carry-overs: the refund base is cumulative premiums paid, not a single premium S2 S4; and the Compact treats income payments made before a return-of-premium death benefit as period certain income R13 definitions, which is what lets a cash-refund or installment-refund DIA be valued as a life annuity with a derived certain period.

Payment acceleration and commutation. Acceleration is a timing shift, not a withdrawal — expressly “not a liquidity feature” S2. Its 59½ gate exists because of the IRC §72(q) 10% additional tax R8; NYL warns that exercising it on a policy purchased before 59½ can trigger that tax retroactively, plus interest, on payments received before 59½ S1. Commutation exists only in the extended case, and distinctively “except for the Period Certain option, if you are still living at the end of the period when your guaranteed income payments would have stopped, Pacific Life will resume income payments until your death” — the life-contingent tail survives commutation S4. The interest-rate adjustment formula is not published in any retrieved document S4 S5; the Compact supplies only the principle R13 §3.F(7), so the construction in technical-notes.md is std/unverified.

QLAC overlay. The same contract in qualified money under the seven conditions of §1.401(a)(9)-6(q)(1): the premium limitation; commencement no later than the first day of the month next following the 85th anniversary of birth; RMD compliance after commencement; no commutation benefit, cash surrender right or other similar feature after the required beginning date (other than a rescission right not exceeding 90 days from purchase); no death benefits other than those in (q)(3); a statement that the contract is intended to be a QLAC; and that it is not variable under section 817, indexed, or similar R1 REG-R57. Specifics:

• Premium limit $200,000 as enacted, indexed (base period the calendar quarter beginning July 1, 2022, increments rounded to the next lowest multiple of $10,000); $210,000 for 2026, unchanged from 2025 R1 (q)(2)(ii), (q)(4)(ii)(A) R2 §202(a)(2) R3, independently confirmed by Pacific Life S4. The limit is reduced by premiums paid to this contract and to any other contract intended to be a QLAC under any 401(a), 403(a), 403(b), 408 or governmental 457(b) arrangement R1 (q)(2)(ii)(B); the issuer may rely on the owner’s written representation R5 (h)(2). The percentage-of-account-balance limit is gone — SECURE 2.0 § 202(a)(1) directed Treasury to eliminate the 25% requirement and the codified text now contains only a dollar limitation R1 R2, so pre-2023 documents stating 25% and $130,000 are superseded S2.

• Permitted death benefits are exhaustive R1 (q)(3): a life annuity to a sole-beneficiary surviving spouse not exceeding 100% of the employee’s payment; a life annuity to another beneficiary not exceeding the applicable percentage; or, in lieu of a life annuity, a return of premiums “up to the amount by which the premium payments made with respect to the QLAC exceed the payments already made under the QLAC”, payable by the end of the calendar year following the year of death and treated as an RMD (not rollover-eligible) where death is after the required beginning date R1 (q)(3)(v). The applicable percentage is 0 where the contract provides a return of premium R1 (q)(3)(iii)(C) — so a QLAC carries a ROP death benefit or a beneficiary life annuity, never both. The contract’s value is excluded from the RMD account balance R4, a rule that applies to IRAs but not to a Roth IRA R5 R5 (h)(4).

• Market implementation and failure modes. MassMutual permits only Single Life — No Refund, Cash Refund and No Death Benefit plus Joint and Survivor — Cash Refund, excluding Installment Refund and Period Certain S2; Pacific Life likewise excludes Period Certain and Installment Refund S4; Guardian excludes guarantee periods and subsequent premiums S3; commutation, acceleration and inflation protection are all off S4. An excess premium ends QLAC status on the date paid unless returned to the non-QLAC portion of the account by the end of the following calendar year (returning it is not a prohibited commutation) R1 (q)(4)(i)(B); any other failure voids status retroactively to the date of purchase R1 (q)(4)(iii)(A). A joint-and-survivor QLAC survives a post-purchase, pre-commencement divorce under QDRO conditions R1 (q)(3)(vii) R2 §202(a)(3), retroactive to contracts purchased on or after July 2, 2014 R2 §202(c)(1)(B); MassMutual’s pre-SECURE-2.0 guide shows the old, harsher treatment and illustrates what changed S2.

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Riders and options

In scope (modeled, or modeled as switches): annual increase / inflation protection option (COLA), 1%–4% compound on each income-start anniversary, elected at issue and irrevocable S1 S2 S3 S4, base 0%; annuity date adjustment rider / income start date adjustment option, one-time ±5 years with repricing S1 S2 S3 S4; payment acceleration S1 S2 S3 S4; commutation / withdrawal of guaranteed income payments, extended case only S4 S5; the QLAC endorsement — the statement of intent required by R1 (q)(1)(vi) plus the restriction set above S2 S4; and the deferral-phase death benefit switch (ROP vs none), which is the product’s central pricing fork rather than a rider proper S1 S2 S3 S4.

Out of scope (described, not modeled): terminal-illness acceleration of the death benefit S4; spousal continuation and beneficiary-IRA continuation, including the QLAC rules that spousal continuances are not allowed and that a spouse keeping the contract holds it as a spousal beneficiary IRA with no new premiums S2; custodial QLAC IRA forms where payee and beneficiary must be the custodian S2; participating / dividend forms R13 §3.T; misstatement of age or sex adjustments, corrected at interest “not exceeding 6%” R13 §3.R; up to ten payees per contract S2; evidence-of-survival requirements R13 §3.L; the beneficiary’s election of the present value of remaining payments S1 S2 S3; the ten-day free look on each subsequent premium, carried as a cancellation flag only S2 S3 R13 §3.B(1)(d); and state overrides (Florida’s mandate that the annuity date be advanceable on all options — including the No-Refund options — to as early as 13 months after issue, which is a start-date-adjustment override and not the payment acceleration feature S2; Pacific Life unavailable in CA, IL, NC, OR, PA and TX, its start-date adjustment unavailable in CT and NY, and its commutation unavailable in MO S4).

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Variations across insurers

1. Minimum deferral — 13 vs 24 months. 13 S2 S4, matching VM-01 R9; 24 full months S1 S3, against 13 months for Guardian in Fidelity’s current table S6 — unresolved S9 S11. Chosen: 13 months, the regulatory minimum and the more common design.

2. Maximum deferral — 30 vs 40 years. 30 at MassMutual, Pacific Life and USAA; 40 at NYL, Guardian and Western & Southern S1 S2 S3 S4 S6. Chosen: 30, with the archetype; the income-start age binds first.

3. Maximum income-start age — 85 vs 90 (nonqualified). 85 at NYL, Guardian, USAA and Western & Southern; 90 at MassMutual and Pacific Life S1 S2 S3 S4 S6. Chosen: 85 — also the regulation-fixed QLAC ceiling R1, so the model carries one age cap.

4. Deferral death benefit packaging. All four default to 100% ROP S1 S2 S3 S4; what varies is the no-death-benefit corner — implicit in a Life Only election S1 S3 S4, an explicit option conditioned on a 10+ year deferral S2, or fully unbundled S4. Chosen: the unbundled treatment as the model’s parameterization (a db_form switch independent of the payout form, which makes the two mortality exposures independent), while the representative product defaults to ROP on every option but Life Only.

5. Income start date adjustment. Uniform ±5 years, one time S1 S2 S3 S4, with Guardian’s accelerate-back right S3 and Western & Southern’s two changes S6 as exceptions; Florida forces acceleration on all options S2 and Pacific Life cannot offer it in CT or NY S4. Chosen: one-time ±5 years on the MassMutual repricing recipe, the only fully disclosed one S1 S2.

6. COLA range — 1% to 5% across the market. 1–3% S1; 1–4% S2; 1–5% S3 per S6; 2/3/4% S4; all fixed compound escalators elected at issue, none CPI-linked. Chosen: 1–4%, base model 0%.

7. Post-income liquidity. Acceleration everywhere but with different limits — 2 uses / 6 months S1; 5 / 3 or 6 S2; 1 use and only with a guarantee or refund period with ≥6 months left S3; 2 / 3 or 6 S4. Only Pacific Life offers true commutation S4 S5. Chosen: 2 uses of a six-month acceleration in the base case, commutation only in the extended case — the single largest liability-modeling difference across the four products.

8. Joint reduction trigger and convertibility. Reduction on the death of either annuitant versus of the primary annuitant coexist S1 S2 S4; MassMutual alone exposes convertible vs non-convertible and states that convertible joint payouts are lower because they also guarantee a single-life payout if one annuitant dies during deferral S2. Chosen: non-convertible base with a convertible switch, trigger likewise a switch, matching the immediate-annuity chassis.

9. Minimum premium. $10,000 at four of five products S1 S2 S3 S6; Pacific Life alone $15,000 S4. Subsequent minima split $100 S1 S3 vs $500 S2 S4. Chosen: $10,000 / $500.

10. Source-vintage caveat. MassMutual’s guide is 2019 and its QLAC figures ($130,000, 25% of balance, RMD age 70½) are superseded S2 R1 R2 R3; the current guide could not be retrieved S8. Guardian’s fact sheet is January 2018 and references RMD age 70½ S3. The current-vintage primary sources are NYL’s June 2026 product overview S1 and Pacific Life’s February 2026 fact sheet S4. USAA and Western & Southern parameters come only from a distributor comparison S6 S9. Mechanics are stable across these vintages; tax and age parameters follow the current-law sources R1 R2 R3.

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Regulatory context

NAIC Standard Nonforfeiture Law for Individual Deferred Annuities (Model #805). It does apply during deferral — the Section 2 exclusions cover immediate annuities and “any deferred annuity contract after annuity payments have commenced”, and a DIA before the income commencement date is in none of them R10. The cash-surrender requirement is conditional, biting only “if a contract provides for a lump sum settlement at maturity, or at any other time” R10 §3.A(2), so a contract that never offers a lump sum never triggers it; what is triggered is the paid-up annuity benefit R10 §3.A(1), satisfied by construction R13 §3.H(1), with Section 7 governing its valuation and Section 9 forcing the prominent disclosure realized as the Compact’s cover-page language R10 R13 §§2.A(8)–(9). Correction to a common misstatement: the Model #805 indexed nonforfeiture interest rate is the lesser of 3% and the five-year Constant Maturity Treasury rate (rounded to the nearest 1/20th of one percent) reduced by 125 basis points, subject to a floor of 15 basis points (0.15%) — not a 1% floor REG-R42. The research file left “floored at 1%” unverified because its own extract did not capture Section 4.B R10; the fully fetched text settles it at 15 bp REG-R42. Largely academic here — a DIA has no cash value and the minimum nonforfeiture amount (net considerations of 87.5% of gross, less a $50 annual contract charge and other stated items REG-R42 R10 §4.A(1)) never binds — but the number should not be propagated wrongly.

IIPRC uniform standard IIPRC-A02-I-LONG. The Compact’s “Individual Deferred Paid-Up Non-Variable Annuity Contract Standards (Commonly Marketed as Deferred Income Annuities or Longevity Annuities)”, adopted August 5, 2017 and effective November 20, 2017, is the contractual-language authority throughout this document and the closest substitute for a specimen contract, none having been located R13. It supplies the scope definition, the closed list of permitted death benefit formulas R13 §3.I(1), the purchase-rate rule for subsequent premiums R13 §3.B, the commutation rules R13 §3.F, the loan prohibition R13 §3.P, and the filing accommodation that matters most — a comparative-adequacy certification in lieu of a nonforfeiture demonstration, certifying “that the income benefit provided under this contract is greater than that guaranteed at issue for the same premium under any non-variable deferred annuity contract offered by the company that provides cash surrender values during the deferral period or on the income commencement date” R13 §1.B(1)(g). Its ICCxx prefix is why DIA forms appear as ICC11–P101 S1 and ICC12-FPDIA12 S2 R13 §2.A(6).

NAIC Annuity Disclosure Model Regulation (Model #245) — with a numbering correction. The annuity disclosure model is #245; #250 is the Variable Annuity Model Regulation, which defines a variable annuity by reference to separate-account investment experience and does not reach a general-account DIA R11 R12 REG-R43 REG-R45. Model #245 probably does not apply to a plain DIA either: Section 3.A exempts “immediate and deferred annuities that contain no non-guaranteed elements” R11 and every income benefit in a non-participating DIA is guaranteed R13 §3.H(1) — a direct reading of the retrieved text, though whether individual states apply the exemption to DIAs was not verified unverified. A participating DIA would not be exempt on that ground R11 R13 §3.T. Separately, the Suitability in Annuity Transactions Model Regulation (Model #275, 2020 best-interest revision) binds at the distribution layer — new-business mix and the 1035-exchange flows that feed a DIA as an exchange destination REG-R46 REG-R56.

Valuation Manual — VM-01, VM-22 and VM-V. VM-01 supplies the statutory definition R9. VM-22, “PBR for Non-Variable Annuities”, names Deferred Income Annuity contracts explicitly in the Payout Annuity Reserving Category R9 §3.F.1.a REG-R36 and constitutes CARVM for contracts in scope, applying for valuation dates on or after January 1, 2026 with an elective three-year transition on VM-A/VM-C/VM-M/VM-V for newly issued business R9 REG-R36. For contracts not passing the Stochastic Exclusion Test, VM-V Section 1 “Income Annuities” — not VM-22 — carries the statutory maximum valuation interest rate, its scope expressly including “deferred income annuity contracts issued after Dec. 31, 2017” R9 REG-R37; VM-V §1 supersedes the interest-rate guidance in AG IX-B and the interest references in AG IX-C REG-R37. A model citing “VM-22 income annuity interest rates” against the current Valuation Manual is citing the wrong section REG-R36. VM-21 does not apply — it is the variable-annuity standard REG-R35 REG-R36. The guideline family incorporated by VM-C (AG II, VIII, IX, IX-A/B/C, XIII, XXXIII, XXXV, XL, XLI) is indexed at REG-R41.

Formulaic CARVM — Appendix A-820 and Actuarial Guideline XXXIII, now read in the AP&P Manual print. The NAIC Accounting Practices and Procedures Manual, which this library had recorded as a paid publication it could not fetch REG-R110 limit, is in fact a free download, and both items were read in full from it on 2026-08-06: A-820, “Minimum Life and Annuity Reserve Standards” with A-821 and A-822 REG-R153, and AG 33, “Determining CARVM Reserves for Annuity Contracts With Elective Benefits” REG-R151 — the printed title, not the wording IRS Rev. Rul. 2002-6 uses. A-820 ¶6 makes the minimum standard for an individual annuity contract the triple method ¶¶14–15, interest ¶¶7–10, mortality Appendix A-821, and ¶14 excludes only employer-plan group annuity business, so an individual DIA is squarely inside CARVM REG-R153 ¶¶6, 14–15. AG 33 then interprets that CARVM: it applies “to all annuity contracts subject to CARVM, where any elective benefits … are available to the contract owner”, with no product list and no size or premium threshold, so the ±5-year income start date adjustment, payment acceleration and (extended case) commutation each put the contract inside it — while a cell offering none of them, such as a Life Only QLAC, falls outside AG 33 although CARVM still applies, AG 33’s own Definitions expressly treating a deferred annuity “where no benefit options are available” as non-elective REG-R151. Three consequences matter at specification level: the start-date adjustment changes the valuation interest rate, because the annuitization guarantee duration runs from issue to the assumed commencement date and the ±5 years can cross A-820 ¶8.c.i’s guarantee-duration bands; a commutation right bars AG 33 Text 4(B)’s annuitization treatment for the payments it can reach; and the guideline’s 7% expense-allowance floor has no base here, being expressed on an accumulation fund this product does not have. AG 33 carries no formulas, tables or factors beyond that 7% cap and its 1998–2000 grade-in percentages, and never cites SVL §5a by number — the §5a pairing this library uses is its own, made on content REG-R151.

Annuity valuation mortality. Model #821 recognizes the 2012 Individual Annuity Reserving (2012 IAR) table, a generational table combining the 2012 IAM Period Table with Projection Scale G2 REG-R59; VM-M prints the application formula and the rounding rule R9 REG-R59, and the Academy/SOA development report records the LATF margin of 10% at ages up to and including 100, grading down 1% per year above 100 until an ultimate mortality cap of 0.40000 R14 REG-R60. The AP&P print says the same: A-821 ¶11 prescribes the 2012 IAR table for any individual annuity or pure endowment contract issued on or after January 1, 2015 (¶10, the Annuity 2000 table for issues from January 1, 2001 through December 31, 2014), and ¶14 prints the no-chaining rounding rule with its own counter-example REG-R153. A-821 prints only the 2012 IAM Period Table and Scale G2, however — the Annuity 2000 table, 1983 Table “a” and the 1994 GAR table are named and not printed, and no standard is printed for individual annuities issued before January 1, 2001 REG-R153. Annuitant mortality is a different and lighter basis than insured-life mortality — the 2017 CSO and 2015 VBT families must never be used for annuitant longevity REG-R59 REG-R61.

Federal securities regulation — none applies. A DIA is a non-registered, general-account, non-variable, non-indexed contract; EDGAR full-text searches located no DIA specimen contract and no retrieved source describes SEC registration, a prospectus, Form N-4 or a Key Information Table for any of these products [research-file finding; the framework for why fixed annuities are state-regulated non-securities is at REG-R53] [unverified as a legal statement]. This is the sharpest contrast with the registered index-linked and variable annuity chassis in this library REG-R49 REG-R52.

IRC § 72 (nonqualified taxation). The excludable portion of each payment is the exclusion ratio — investment in the contract over expected return — capped at the unrecovered investment, with any unrecovered investment remaining at death allowed as a deduction for the annuitant’s last taxable year R8 §72(b) REG-R55. Investment in the contract is aggregate premiums less amounts previously received excludably R8 §72(c) — for a flexible-premium DIA, the sum of all purchase payments. The 10% additional tax on premature distributions, with its 59½, death, disability and substantially-equal-periodic-payments exceptions R8 §72(q), is why every acceleration and commutation feature is gated at 59½ S1 S3 S4. Section 72(s) governs required distributions on the holder’s death R8.

IRC § 401(a)(9) and the QLAC. The current rules live in paragraph (q), not the old “A-17” Q&A format: T.D. 10001 (89 FR 58886, July 19, 2024, effective September 17, 2024) restructured them and implemented SECURE 2.0 § 202 R1 credit line R6 REG-R58; the original rule was T.D. 9673, “Longevity Annuity Contracts”, 79 FR 37633 (July 2, 2014) R7. Cite § 1.401(a)(9)-6(q) for current law R1 REG-R57 and SECURE 2.0 Act of 2022 § 202 (Division T of Pub. L. 117-328) for the statutory command that raised the dollar limit from $125,000 to $200,000, eliminated the 25%-of-account-balance limit, preserved joint-and-survivor benefits through divorce and permitted a rescission period not exceeding 90 days R2 REG-R58. The RMD exclusion is § 1.401(a)(9)-5(b)(4) R4, applied to IRAs by § 1.408-8(h) and switched off for Roth IRAs by § 1.408-8(h)(4) R5.

Accounting and professional standards. Under LDTI a payout annuity carries a liability for future policy benefits with annually reviewed assumptions and no market risk benefit — there is no account value for an MRB to attach to REG-R34 REG-R71. The tax reserve is the greater of net surrender value (zero here) and 92.81% of the NAIC-prescribed method, capped at the statutory reserve REG-R16. Pricing is governed by ASOP 54 REG-R70, the projection by ASOP 7 REG-R27, model governance by ASOP 56 REG-R32, asset adequacy opinions by ASOP 22 REG-R29. ASOP 2’s scope covers non-guaranteed elements for annuity products REG-R26; whether a DIA’s current purchase rate for a future premium falls within it was not verified unverified — the operative constraint on that rate is the Compact’s “current annuity purchase rates” floor R13 §3.B(1)(c).