Technical Notes#
Status: Draft, 2026-08-04 (all cited sources accessed 2026-08-04).
Scope note. A reference liability cash-flow projection model for the standardized composite product
defined in product-spec.md (same directory); not any single insurer’s product. [S#]/[R#] refer to
_research/deferred-income-annuity.md; [REG-R#] refers to
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;
R150–R157 the AP&P Manual appendix and actuarial-guideline prints read on 2026-08-06).
std marks standardizations introduced for
the reference implementation; unverified marks claims not confirmed against a retrieved document. Parameter
values are identical to those in product-spec.md.
Two structural facts govern the whole design.
There is 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 S1 fn.1 S2 S4 R13. Consequently there is no lapse decrement — VM-22’s standard-projection lapse section is expressly “not applicable” to contracts with no account value or surrender benefit R9 — and no annuitization decrement (prescribed at 0% R9). The full list is in
product-spec.md, “Parameters that do not exist for this product”. Do not synthesize any of them.The income phase is the immediate-annuity payout chassis. Payout forms, refund and certain-period guarantees, survivor reduction and its interaction with a guarantee period, COLA escalation and payment-survivorship weighting are specified in
products/immediate_annuity/technical-notes.mdand are not restated here. These notes cover the deferral phase, the transition, the in-force options and the QLAC overlay, and define only the payout-phase quantities the DIA changes — chiefly the refund base, which is cumulative premiums rather than a single premium.
Model scope and conventions#
Purpose. Project gross expected liability cash flows — premiums in; deferral death benefits, income payments, refund benefits, acceleration and commutation payments, maintenance expenses out — for a single-contract model point. Reserves are not computed (see “Valuation and reserve pointers”).
Projection frequency. Monthly, indexed
t = 0, 1, 2, …from issue std. Monthly is natural because the modal payment frequency is monthly S1 S2 S3 S4 and because the 13-month minimum deferral and the 13-month premium cut-off are expressed in months S2 S4 R9.Timing conventions std. Premiums are received at the start of month
t. Income is paid in arrears at the end of each payment period, matchingproducts/immediate_annuity/product-spec.md; the model exposespay_timing ∈ {advance, arrears}because no retrieved DIA document states the convention. Deferral death benefits are paid at the end of the month of death.Tis a month index and the income start date is the start of monthT(exactlyT/12years after issue); under arrears the first payment falls one payment period later,12/mmonths afterT— atm = 12, at the end of month indexT, i.e.T + 1months from issue. Consequently deaths in monthst < Tare deferral-phase deaths and deaths in monthst ≥ Tare payout-phase deaths.Age basis. Age nearest birthday (ANB) std: MassMutual states contract issue age on an ANB basis S2; prescribed VM-22 payout mortality is ANB with a conversion formula supplied for age-last-birthday companies R9; the 2012 IAM Basic and Period tables were developed ANB R15 REG-R59.
Model points. Single-contract model points on an expected (probability-weighted) basis: the in-force factor
l(t)multiplies every per-contract cash flow. Joint cells carry two lives and a joint status. No aggregation logic is specified here.Decrement set. Mortality only;
l(t)never decrements for lapse or surrender R9.Rounding. Full precision internally, cash flows to cents std. Generational mortality rates follow the Valuation Manual rule — three decimal places per 1,000, computed from the 2012 period rate each time, never by compounding an already-rounded prior-year rate R9 REG-R59. A-821 ¶14 prints the same rule and the same worked counter-example, so this is now sourced twice over rather than once REG-R153.
Model point attributes#
Attribute |
Type |
Example (anchor cell std) |
|---|---|---|
|
int (ANB); enum {M, F} |
60; F |
|
bool; int; enum |
false |
|
enum {0.50, 0.6667, 0.75, 1.00}; enum {either, primary} |
n/a |
|
bool |
false |
|
enum {NQ, TradIRA, RothIRA, QLAC} |
NQ |
|
enum {LO, LO_ROP, CR, IR, PC(n)} + joint variants |
CR |
|
years, 10–30 (PC forms only) |
n/a |
|
int months from issue; |
240 |
|
list of (month, amount) |
[(0, 100000), (60, 50000)] |
|
enum {ROP, NONE} |
ROP |
|
0.00, or 0.01–0.04 |
0.00 |
|
enum {12, 4, 2, 1}; enum {arrears, advance} |
12; arrears std |
|
bool; int |
true; 1 |
|
int 0–5; int {3, 6} |
2; 6 |
|
bool (extended case only) |
false |
|
bool — whether purchase rates for future premiums are guaranteed R13 §1.B(1)(h) |
false std |
|
currency (QLAC only) |
n/a |
Anchor cell std: Female 60 ANB, nonqualified, $100,000 at issue plus $50,000 at the start of policy
year 6, income start at attained age 80, Life with Cash Refund, monthly in arrears, return-of-premium death
benefit in deferral, no COLA. Used identically in product-spec.md and in the worked example.
State variables#
Variable |
Description |
Updated |
|---|---|---|
|
Guaranteed annual income purchased to date, before COLA |
on each premium; on adjustment exercise |
|
Cumulative premiums paid — the deferral death benefit base and the refund base |
on each premium |
|
In-force (survival) probability at the start of month |
monthly |
|
{deferral, payout, terminated} |
at |
|
Current income start month (mutable once) |
on adjustment exercise |
|
Remaining refund balance |
monthly in payout, refund forms |
|
Derived guarantee period in years |
fixed at |
|
bool; int |
on exercise |
|
months of suspended payments remaining |
monthly |
|
extended case: guaranteed payments commuted; month the life-contingent tail resumes |
on exercise |
|
mortality selection multiplier applied after an adjustment exercise |
on exercise |
|
Indexed QLAC limit less premiums paid to this and any other intended QLAC |
on each premium |
Assumption inputs#
Class (a) is contractual and fixed at issue; class (b) is the only insurer-declared element in the product; class (c) is the modeler’s view of experience.
(a) Contractual / guaranteed elements#
Input |
Value |
Basis |
|---|---|---|
Guaranteed income per slice |
Fully guaranteed at the time each premium is paid |
|
Deferral death benefit |
100% of cumulative premiums, no interest, lump sum |
|
Permitted DB calculation methods |
% of premiums; % of premiums plus interest; flat dollar; combination |
|
Forms with no deferral DB |
Life Only, Joint Life Only; and Single Life — No Death Benefit (deferral ≥ 10 yrs, start date locked) |
|
Minimum / maximum deferral; max start age |
13 months / 30 years; attained age 85 |
|
Premium cut-off |
No premium within 13 months of the income start date |
|
Income start date adjustment |
One-time ±5 years; new date ≥ 13 months after the last premium; option, day of month and frequency locked |
|
Adjustment repricing inputs |
Originally scheduled payment; new date; Moody’s Seasoned Baa Corporate Bond Yield at the request date; Annuity 2012 Mortality Table; contractual interest-rate-change adjustment |
|
COLA |
Fixed compound 1%–4% on each income-start anniversary; elected at issue, irrevocable |
|
Payment acceleration |
6 monthly payments in one sum then 5 months without; 2 uses; age 59½; nonqualified |
|
Commutation (extended) |
≤100% of the PV of remaining guaranteed payments; interest-rate adjustment applies; life-contingent tail resumes |
|
Loans, surrender, withdrawals in deferral |
None; prohibited |
|
Explicit charges |
None disclosed in any source |
|
Minimum monthly income |
$100 |
|
Small-benefit termination right |
Company may terminate for present value after 2 years without considerations if the paid-up benefit is under $20 monthly |
(b) Insurer-declared current elements#
There is exactly one: the annuity purchase rate applied to each premium, set “at the time each purchase payment is made” S3 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)(b), floored at the income a new contract of the same class would buy R13 §3.B(1)(c).
No purchase-rate table was obtained, and none is published. The Compact expressly relieves the insurer of
disclosing the deferral-period basis: “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). The purchase-rate function below is therefore an explicit std
construction, not a sourced parameter. An in-force model that reads B from an administration extract does
not need it; it is required only for new business, subsequent premiums and the start-date adjustment.
Input |
Value |
Basis |
|---|---|---|
Pricing interest rate |
4.75% annual effective |
std (a) |
Expense and profit load |
6.0% of gross premium |
std (b) |
Pricing mortality |
2012 IAM Basic × Scale G2 generational, ANB, × 100% |
std (c) |
Interest-rate-change adjustment spread |
100 bp deducted from the Baa yield |
std (d) |
Commutation interest-rate adjustment margin |
50 bp |
std/unverified (e) |
(a) A pure modeling assumption; no DIA source discloses a pricing rate. Read it as a long-duration
general-account portfolio yield net of default costs; the prescribed VM-V portfolio credit-quality
distribution (5% Treasuries / 15% Aa / 40% A / 40% Baa R9) is a reasonable calibration frame.
(b) Reconciliation so the load is not arbitrary: on the anchor cell L × 100,000 = $6,000 against roughly
$900 of present-valued maintenance expense (item in class (c), survivorship-weighted at i_p, computed on
the worked example’s illustrative survival anchors extended past age 85 — the figure is sensitive to that
extension), a few thousand of first-year distribution cost, and the balance as profit margin. Sensitivity-test it before
relying on any absolute income level.
(c) VM-22 prescribes q_x^(2012+n) = q_x^(2012) · (1 − G2_x)^n · F_x on the 2012 IAM Basic table with F_x
from Table 6.8 for the standard projection R9; the pricing basis uses the same table and scale without the
prescribed F_x loading, at a std A/E of 100%.
(d) The contract’s “interest rate change adjustment” is named but never quantified in any retrieved source
S1 S2; 100 bp is a placeholder that keeps the repriced income directionally correct S4 S5.
(e) The Pacific Life interest-rate adjustment charge formula was not found in the fact sheet S4 or the
client guide S5; it would appear only in the contract or the actuarial memorandum. Equation (13) implements
only the Compact’s stated principle R13 §3.F(7) and is unverified.
(c) Behavioral and experience assumptions#
Input |
Recommended public basis |
Tags |
|---|---|---|
Payout-phase mortality |
2012 IAR / 2012 IAM Basic with Scale G2, generational, ANB, per Model #821 and VM-M §1.J; the appendix 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, and A-820 ¶6 makes A-821 the mortality leg of the CARVM triple by direct cross-reference |
|
Payout-phase A/E |
2020–2024 Individual Payout Annuity Mortality Experience Study — 23 parent groups / 26 companies, >80% of industry sales, 3.1m contract-years, 143,190 deaths, shown against the 2012 IAM table; the study explicitly includes deferred income annuities |
|
Deferral-phase mortality |
The weakest link. The only public sources are a 2011–2015 deferred annuity mortality study and a 2006 analysis of mortality during the deferred period, both identified via the SOA index, neither fetched |
|
Mortality improvement |
Scale G2 only (generational); none additional in the base run |
|
Lapse / surrender |
None. “For contracts in which there is no account value or surrender benefit, such as some contracts within the Payout Annuity Reserving Category …, this section is not applicable” |
|
Annuitization |
Not applicable; prescribed at 0% for the standard projection |
|
Maintenance expense |
$50 per contract per year escalated 2.5% (VM-22 prescribes $50 for individual Payout Annuity Reserving Category contracts, escalated by |
|
Premium persistency |
Deterministic schedule, factor 1.00 |
std (f) |
Start-date adjustment take-up |
1.5% p.a. of exposure, one exercise, 60% defer / 40% advance, with rate and selection overlays |
|
Payment acceleration take-up |
2% p.a. of exposure among eligible contracts |
|
Commutation take-up (extended) |
1.5% p.a. of exposure, rate-insensitive in the base |
(f) DIA subsequent premiums are wholly discretionary and no source publishes a distribution of them. The base
model projects the model point’s stated schedule with no attrition and exposes pp(y). Dump-in risk
differs structurally from a fixed deferred annuity’s: because a DIA prices each premium at then-current
rates there is no rate guarantee to select against — unless the contract guarantees paid-up annuity rates for
future premiums, which the Compact requires to be described where offered R13 §1.B(1)(h). VM-22 requires
“additional premium dump-ins under high guarantees in low-rate environments” to be reflected REG-R36; that
risk is switched on by guaranteed_future_rates and is off in the base std.
Cash flow components and recursions#
Notation (defined once, used throughout)#
Symbol |
Meaning |
|---|---|
|
policy month index |
|
payments per year (12 in the base) |
|
issue age ANB; attained age |
|
income start month ( |
|
premium index, amount, payment month; |
|
|
|
guaranteed annual income before COLA; cumulative premiums; COLA rate |
|
in-force probability at the start of month |
|
pricing interest rate; |
|
expense and profit load, fraction of gross premium |
|
probability a life aged |
|
APV at age |
|
APV at the premium date of $1 per annum of income in form |
|
APV at the premium date of $1 payable at the end of the month of death within a |
|
purchase rate: annual income per $1 of premium |
|
derived guarantee period in years; annual maintenance expense per contract; its escalation rate |
|
repricing rate for a start-date change; discount rate for a commutation |
Dimensional check. a_def and a^{(m)} are APVs per unit of annual income, so they carry units of
years; A_rop and L are dimensionless (per $1 of premium). Hence pr = (dimensionless)/(years) = 1/year,
P_k × pr is currency per year, and dividing by m gives the currency amount of one payment.
Pricing kernel: the purchase rate#
a_def(x, d, f; i) = v^d · _d p_x · a^{(m)}_{x+d}(f; i) (1)
a^{(m)}_y(f; i) is the APV of the payout form, built from the payment factor Φ(t) = max(C(t), L(t))
defined in products/immediate_annuity/technical-notes.md (certain floor C, life-contingent factor L,
survivor percentage and reduction trigger included); for a certain-and-life form with guarantee period n_g,
a^{(m)}_y(f; i) = Σ_{j=1..m·n_g} (1/m)·v^{j/m} + Σ_{j>m·n_g} (1/m)·v^{j/m}·_{j/m} p_y (2)
APV of the return-of-premium death benefit over the deferral, benefit paid at the end of the month of death
std, with q^[j]_x the probability of death in the j-th month:
A_rop(x, d; i) = Σ_{j=1..m·d} v^{j/m} · _{(j−1)/m} p_x · q^[j]_x (3)
The purchase rate follows from the equivalence principle applied per premium:
P·(1 − L) = B_slice · a_def(x, d, f; i_p) + 1{db_form = ROP} · P · A_rop(x, d; i_p)
⇒ pr(x, d, f) = [ (1 − L) − 1{ROP} · A_rop(x, d; i_p) ] / a_def(x, d, f; i_p) (4)
std, for the reasons in assumption class (b). Equation (4) makes the central design fork quantitative:
setting 1{ROP} = 0 raises the numerator from (1 − L) − A_rop to (1 − L), so the no-death-benefit form
buys strictly more income for the same premium, by the factor (1 − L)/((1 − L) − A_rop). That is the
mortality-gain economics behind MassMutual’s separately-conditioned Single Life — No Death Benefit option
S2 and behind the silent removal of the return of premium when Life Only is elected S1 S3 S4.
Refund forms and the circularity they create. The Compact treats income payments made before a return-of-premium death benefit as period certain income R13 definitions, which licenses the closed form. For installment refund, payments “continue in the same amount and frequency until they equal the purchase payments” S2, so the form is exactly a certain-and-life annuity with
n_g = CP(T) / B (5)
For cash refund the benefit is instead a lump-sum shortfall paid at death S1 S2, so (2) is an approximation; the exact factor adds a decreasing term benefit
a^{(m)}_y(CR) = a^{(m)}_y(life only)
+ (1/B) · Σ_j v^{j/m} · _{(j−1)/m} p_y · q^[j]_y · max(0, CP(T) − (j−1)·B/m) (6)
Both (5) and (6) put B on both sides. Resolve by fixed-point iteration on B (three iterations from a
life-only start are ample), or use the (5) approximation for both refund forms std with (6) as a check.
Under arrears, a death between T and T + 1/m yields a cash refund of the full CP(T), no payment having
been made.
Deferral-phase recursions#
CP(t) = CP(t−1) + Σ_{k : t_k = t} P_k, CP(−1) = 0 (7)
B(t) = B(t−1) + Σ_{k : t_k = t} P_k · pr( x(t_k), (T − t_k)/12, f ), B(−1) = 0 (8)
l(t+1) = l(t) · (1 − q(t)), l(0) = 1 (9)
Equation (8) is the core of the product: income is additive across slices, each priced at the annuitant’s
attained age and the remaining deferral at its own payment date R13 §3.B(1)(b) S3. Nothing
accumulates; there is no balance to roll forward. Admissibility tested at each premium: P_k ≥ 10,000 (first)
or ≥ 500 (subsequent) S1 S2 S3 S6; CP(t) ≤ 1,500,000 without approval std; t_k ≤ T − 13
S2 S4; and, on a QLAC, CP(t) ≤ qlac_room.
Monthly processing order#
At month t, with l(t) the in-force probability at the start of the month:
Roll attained age and policy year; look up
q(t), applyingsel_mult(t)if a start-date adjustment has been exercised.Premium (deferral only): if a scheduled premium falls at
t, test admissibility, computeprby (4), updateCPandBby (7)–(8). Cash flow in:P_k · l(t).Option exercises (start of month): start-date adjustment (deferral, once); payment acceleration or commutation (payout only). Any of these may reset
B,T,accel_blackoutorcommuted.Income payment (
t ≥ T, arrears — at the end of the month): payB(t)/m · (1+c)^{floor((t − T)/12)}weighted by the form’s payment survivorship, unless suppressed by an acceleration blackout or a commutation.Death benefits: deaths during month
tat rateq(t); ift < Tpay the ROP benefit (or nothing under a no-death-benefit form); ift ≥ Tpay the form’s refund benefit.Expenses:
(e/12)·(1+g)^{y−1} · l(t).Decrement: apply (9).
Order note std: contractual transactions precede the decrement, and the end-of-month income payment is contingent on survival to that point — which is what the arrears convention means.
Expected cash flows (per contract, month t)#
Cash flow |
Formula |
Sign |
|---|---|---|
Premium income |
|
+ |
Deferral death benefit |
|
− |
Income payments |
|
− |
Refund / certain-period benefits |
per form; cash refund |
− |
Payment acceleration |
|
− |
Commutation (extended) |
|
− |
Maintenance expense |
|
− |
L_pay(t) is the form-specific payment-survivorship weight defined in the immediate-annuity notes: l(t)
for a life-only payment, certain inside a guarantee period, and the survivor-percentage-weighted joint status
for joint forms. The DIA-specific change is only the base of the guarantee: CP(T), the sum of all
premiums, not a single premium S2 S4. There is no surrender cash flow row, and none should be added.
Income start date adjustment#
Exercised once at month t_e in deferral, moving T → T′ with |T′ − T| ≤ 60 months, T′ ≥ (last premium month) + 13, and T′ inside the maximum deferral and maximum income-start age S1 S2 S3 S4. The
disclosed recalculation keys on the originally scheduled payment, the new date, the Moody’s Seasoned Baa
Corporate Bond Yield at the request date, a published annuity mortality table, and a contractual
interest-rate-change adjustment S1 S2. Implemented as actuarial equivalence at t_e std:
i_e(t_e) = Baa(t_e) − s_adj (10)
B′ = B(t_e) · a_def( x(t_e), (T − t_e)/12, f; i_e ) / a_def( x(t_e), (T′ − t_e)/12, f; i_e ) (11)
Direction check: a_def decreases in d, so T′ > T ⇒ B′ > B and T′ < T ⇒ B′ < B, matching Pacific
Life’s statement that advancing reduces and deferring increases the payment S4 S5. Two refinements the
disclosed recipe does not mention and the reference model therefore does not apply: the ROP exposure
changes with deferral length (the A_rop term in (4)), and CP is unchanged so the derived guarantee period
(5) shifts. Both are flagged rather than modeled std. Not available on Life Only or Joint Life Only
S1 S3 S4, nor on the Single Life — No Death Benefit option, whose annuity date cannot be changed S2.
Payment acceleration#
At exercise month t_a (payout phase, attained age ≥ 59½, nonqualified, monthly frequency,
accel_used < 2) S1 S2 S3 S4 the contract pays n_a = 6 monthly payments in one sum and suspends
payments for the following n_a − 1 months S1. Accelerated payments are made unconditionally, so the
insurer forgoes the survivorship and interest discount on payments 2 through n_a:
Cost(t_a) = (B/m) · Σ_{j=1..n_a−1} [ 1 − v^{j/m} · _{j/m} p_{x(t_a)} ] (12)
Small but real, and the reason the feature is capped in uses and gated at 59½ S1 S2 S4; the 59½ gate itself is driven by the IRC §72(q) 10% additional tax R8 REG-R55. Not available on a QLAC S4.
Commutation (extended case only)#
i_c(t) = i_p + max(0, r_ref(t) − r_ref(0)) + m_c (13)
CV(t_c) = Σ_{j ∈ J_g(t_c)} (B/m) · (1 + i_c(t_c))^{−(j − t_c)/12} (14)
J_g(t_c) is the set of remaining guaranteed (non-life-contingent) payment months and r_ref a
reference market rate. Equation (13) is one-sided — it rises with rates and does not fall — implementing the
Compact’s stated intent that the adjustment “reduce interest risk in the event of rising interest rate after
issue” and its required disclosure that “the higher the interest rate the lower the commuted value”
R13 §3.F(7). The actual contractual formula is not published anywhere S4 S5, so (13) is
std/unverified. After a 100% commutation the payments in J_g are suppressed; if the annuitant is
alive at resume_month (the end of the would-be guaranteed period) income resumes until death — the
life-contingent tail is not commuted S4, and only Period Certain is fully extinguished. Unavailable on the
Life Only family S4; prohibited on a QLAC after the required beginning date other than a rescission period
not exceeding 90 days R1 (q)(1)(iv) R2 §202(a)(4); interlocked with acceleration and the start-date
adjustment by six-month waiting periods in both directions S4.
Convertible versus non-convertible joint life#
The most model-relevant pricing subtlety in the family, and the only place a joint DIA differs structurally
from a joint SPIA. With lives aged x₁, x₂ and survivor percentage s:
Non-convertible — priced on “a single payout assumption that both annuitants will be alive on the annuity date” S2, and if one annuitant dies in deferral the contract continues on the option chosen at issue S2:
P(1−L) − P·A_rop = B_J · [ a_def^{(both)} + s · Σ_{i=1,2} a_def^{(only i)} ] (15)
Convertible — priced on “two different payout assumptions”: the joint payout if both are alive at the annuity date, and the corresponding single life payout for each annuitant if only one is alive and the contract converts S2:
P(1−L) − P·A_rop = B_J^c · a_def^{(both)} + Σ_{i=1,2} B_S^{(i)} · a_def^{(only i)} (16)
a_def^{(both)} = v^d · _d p_{x₁x₂}(both alive) · a^{(m)}_joint(f)
a_def^{(only i)} = v^d · ( _d p_{x_i} − _d p_{x₁x₂} ) · a^{(m)}_{x_i + d}(single f)
Because B_S^{(i)} (a full single-life payout) exceeds s·B_J (the reduced survivor amount), the right-hand
side of (16) carries more value per unit of B_J, so B_J^c < B_J — reproducing MassMutual’s statement
exactly: “In general, if both annuitants are alive on the annuity date, the joint life payout will be
lower with a convertible joint life annuity option” S2. The convertible variant also caps the period
certain at 10 years and is unavailable with the inflation protector S2. Base model: non-convertible
std; convertible_joint switches to (16).
QLAC overlay#
A validation-and-restriction layer over the same recursions. It generates no cash flows of its own — it
caps premiums, restricts forms, constrains T, disables features and raises compliance flags. Loss of QLAC
status changes the owner’s RMD position, not the insurer’s liability cash flows.
Rule |
Implementation |
Basis |
|---|---|---|
Premium limit |
|
|
Limit level and indexing |
$200,000 as enacted; indexed like §415(d) limits with base period the calendar quarter beginning July 1, 2022, increments rounded to the next lowest multiple of $10,000; $210,000 for 2026 |
|
Percentage-of-account-balance limit |
None. SECURE 2.0 § 202(a)(1) directed its elimination and the codified text has no percentage test. Do not implement a 25% test |
|
Latest income start |
|
|
Earliest income start |
A product rule, not a QLAC rule: after April 1 of the year following the year the owner attains the applicable RMD age |
|
Permitted death benefits |
Exhaustive: (i) life annuity to a sole-beneficiary surviving spouse ≤100% of the employee’s payment, commencing no later than the employee’s annuity would have; (ii) life annuity to another beneficiary ≤ the applicable percentage, commencing by the last day of the year following the year of death; or (v) return of premiums up to premiums paid less payments already made, payable by the end of the year following the year of death |
|
Applicable percentage |
MDIB table where there is no pre-annuity-starting-date non-spousal death benefit; Table 6 (≤2 yrs → 100% … 25+ yrs → 20%) where the non-spousal beneficiary is irrevocably set; 0 where the contract provides a return of premium |
|
Model consequence |
A QLAC carries either the ROP death benefit or a beneficiary life annuity — never both, since the applicable percentage is 0 when ROP is present |
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Liquidity |
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R1 (q)(1)(iv) S4; the COLA restriction is a market choice, not a regulatory one (a) |
Permitted forms |
Restrict |
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RMD exclusion |
The contract’s value is excluded from the RMD account balance; not for a Roth IRA |
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Failure flags |
Excess premium ends QLAC status on the date paid unless returned by the end of the following calendar year; any other failure voids status retroactively to purchase |
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Rescission |
A rescission right not exceeding 90 days from purchase does not violate the no-commutation rule |
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Divorce |
A joint-and-survivor QLAC survives a post-purchase, pre-commencement divorce under QDRO conditions, retroactive to contracts purchased on or after July 2, 2014 |
(a) Research finding worth carrying into the model as a comment: the regulation expressly permits a QLAC to provide a cost-of-living adjustment described in paragraph (o)(2) R1 (q)(4)(iv), yet NYL, Guardian and Pacific Life all exclude COLA from their QLAC offering S1 S3 S4 and MassMutual limits it on qualified contracts S2. The market is more restrictive than the law; follow the market by default and expose the switch.
Policyholder behavior modeling#
All dynamic formulas are std reference constructions. No DIA behavioral experience study exists in any retrieved source, and VM-22’s standard projection prescribes 0% annuitization and no lapse assumption for this reserving category R9, so these are genuinely modeler’s choices rather than calibrations.
Lapse and surrender: exactly zero, at all durations. Not conservatism — there is no surrender benefit to elect R9 R13. A nonzero lapse assumption in a DIA model is a defect, not a margin.
Income start date adjustment. One-time, deferral only, excluded on Life Only and Joint Life Only S1 S3 S4:
h_adj(t) = h_0 · M_dir(t), h_0 = 1.5% p.a. of exposure; window policy year 3 to (T/12 − 2) **[std]**
direction split: 60% defer / 40% advance **[std]**
M_def(t) = min( 3.0, 1 + 3 · max(0, i_e(t) − i_p − 0.01) ) **[std]**
M_adv(t) = min( 3.0, 1 + 3 · max(0, i_p − i_e(t) − 0.01) ) **[std]**
Rationale: the option’s value is driven by the spread between the pricing rate locked at issue and the Baa
yield at exercise, which is why the right is one-time and why the forms with the strongest health-driven
selection are excluded S1 S2 S3 S4. In a higher-rate environment deferring buys proportionally more
income (equation (11) with a larger i_e), so M_def rises with rates and M_adv rises when rates fall.
Selection on health. sel_mult = 0.90 for contracts exercising to defer and 1.10 for those
advancing, applied to q(t) from the exercise month std. Rationale: insurers exclude the Life Only
forms from the adjustment right precisely because that is where anti-selection on health bites hardest
S1 S3 S4 — the exclusion is evidence the effect is believed real — and 10% is a deliberately modest
reference magnitude with no experience behind it.
Payment acceleration. h_acc(t) = 2% p.a. of exposure among contracts that are nonqualified, on monthly
frequency, at attained age ≥ 59½, in the payout phase, with uses remaining, and outside both a blackout and
the six-month interlocks std S1 S2 S3 S4. Modeled as pure timing plus the cost in (12).
Commutation (extended case). h_com(t) = 1.5% p.a. of exposure among eligible contracts,
rate-insensitive in the base run std: the interest-rate adjustment in (13) is designed to
neutralize rate-driven anti-selection R13 §3.F(7), so a rate multiplier would double-count the protection.
Expose M_com(t) = min(3.0, 1 + 4·max(0, r_ref(t) − r_ref(0))) for sensitivity testing only.
Spousal continuation on death in deferral. Where the surviving spouse is joint annuitant and sole primary beneficiary the contract may continue instead of paying the death benefit S1 S2 S4. Base std: 100% election of the death benefit. The continuation branch is a switch; under non-convertible continuation no further premiums are allowed S2.
Premium behavior. Per assumption note (f): deterministic schedule, no dump-in dynamics unless
guaranteed_future_rates is set std.
Worked example#
Anchor cell std: Female 60 ANB, nonqualified, Life with Cash Refund, monthly in arrears, ROP death
benefit in deferral, no COLA. Premiums $100,000 at issue (age 60, 20-year deferral) and $50,000 at the start
of policy year 6 (age 65, 15-year deferral). Income start at attained age 80 (T = 240). Pricing basis
i_p = 4.75%, L = 6.0% std.
Illustrative factors std. The 2012 IAM Basic / Scale G2 numerical tables were not retrieved — they
live at mort.soa.org R16 — so the factors below are mutually consistent illustrative values, not
table lookups; a production implementation must substitute table values R9 REG-R59. Anchors:
_5p_60 = 0.975000, _10p_60 = 0.920000, _15p_60 = 0.838000, _20p_60 = 0.715000, _5p_80 = 0.780000,
with geometric interpolation inside each five-year band, hence _15p_65 = 0.715000/0.975000 = 0.733333.
Payout factor a^{(12)}_80(cash refund, female; 4.75%) = 8.60; discount factors v^20 = 0.395293,
v^15 = 0.498528. A_rop is computed from the same survival anchors with a mid-band death-timing
approximation: A_rop(60, 20) = 0.157900, A_rop(65, 15) = 0.180200.
Slice pricing, equation (4). Slice 1 (age 60, d = 20): a_def = 0.395293 × 0.715000 × 8.60 = 2.430657;
pr₁ = (0.940000 − 0.157900)/2.430657 = 0.321765; B₁ = 100,000 × 0.321765 = $32,176.50 per year. Slice 2
(age 65, d = 15): a_def = 0.498528 × 0.733333 × 8.60 = 3.144050;
pr₂ = (0.940000 − 0.180200)/3.144050 = 0.241663; B₂ = 50,000 × 0.241663 = $12,083.15 per year. Total from
T: B = $44,259.65 per year = $3,688.30 per month. Derived guarantee period (5):
n_g = 150,000/44,259.65 = 3.3891 years, so the cash-refund guarantee is exhausted during the fourth payment
year, at attained age ≈ 83.4.
The death-benefit fork, same premiums. Setting 1{ROP} = 0 in (4): pr₁ = 0.940000/2.430657 = 0.386727
and pr₂ = 0.940000/3.144050 = 0.298977, so B = 38,672.70 + 14,948.85 = $53,621.55 per year — 21.2% more
income for the same $150,000. That difference is the price of the return-of-premium guarantee, and it is
mortality gain in the insurer’s hands if the annuitant dies in deferral: at the year-10 death below, the ROP
form pays $150,000 and the no-death-benefit form pays nothing while releasing the entire reserve.
Projection (annual display grid; the model runs monthly). E[DB] is the expected deferral death benefit
paid in policy year t, = (l(t−1) − l(t)) × CP(t); E[income] is the expected income paid at the end of
policy year t on an annual-payment display approximation.
Policy year |
Age at start of year (ANB) |
Premium at start |
|
|
|
|
|
|---|---|---|---|---|---|---|---|
1 |
60 |
100,000 |
100,000 |
32,176.50 |
0.994949 |
505.08 |
— |
5 |
64 |
— |
100,000 |
32,176.50 |
0.975000 |
494.95 |
— |
6 |
65 |
50,000 |
150,000 |
44,259.65 |
0.963743 |
1,688.54 |
— |
10 |
69 |
— |
150,000 |
44,259.65 |
0.920000 |
1,611.90 |
— |
15 |
74 |
— |
150,000 |
44,259.65 |
0.838000 |
2,369.01 |
— |
19 |
78 |
— |
150,000 |
44,259.65 |
0.738063 |
3,571.09 |
— |
20 |
79 |
— |
150,000 |
44,259.65 |
0.715000 |
3,459.50 |
— |
21 |
80 |
— |
150,000 |
44,259.65 |
0.680338 |
— |
30,111.54 |
25 |
84 |
— |
150,000 |
44,259.65 |
0.557700 |
— |
24,683.61 |
Trace, policy year 6: the $50,000 premium arrives at the start of the year while the annuitant is alive, so
expected premium income is 50,000 × l(5) = $48,750.00; it buys slice 2 at the age-65 / 15-year purchase
rate, taking B from $32,176.50 to $44,259.65 by (8) and CP to $150,000 by (7). Deaths during year 6
(l(5) − l(6) = 0.0112569) now attract the larger benefit CP(6) = 150,000, giving E[DB] = $1,688.54.
Nothing accumulates and nothing is credited: between premiums the only state change is the survivorship in
(9). The income start date is the start of month index T = 240 (20 years from issue); under arrears the
first payment falls one month later, 241 months from issue — which is why policy year 20 (months 228–239)
still shows a deferral death benefit and policy year 21 (months 240–251) carries the first twelve payments.
Valuation and reserve pointers#
This library projects gross liability cash flows; reserve layers consume them and are cited, not reproduced.
Statutory — principle-based. VM-22, “PBR for Non-Variable Annuities”, constitutes CARVM for contracts in scope and names Deferred Income Annuity contracts explicitly in the Payout Annuity Reserving Category R9 §3.F.1.a REG-R36. Effective 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 and mandatory prospective application three years after the effective date R9 REG-R36. Aggregate reserve = SR (stochastic, CTE70) + DR for contracts passing the Single Scenario Test + formulaic reserves for excluded contracts; the Additional Standard Projection Amount is a VM-31 disclosure item R9 REG-R36. Payout and Accumulation categories may be aggregated only under an integrated risk management process and a single portfolio or portfolios with the same ALM strategy R9.
Statutory — formulaic fallback. For contracts not passing the Stochastic Exclusion Test, VM-V Section 1 “Income Annuities” — not VM-22 — sets the statutory maximum valuation interest rate, its scope expressly including “deferred income annuity contracts issued after Dec. 31, 2017” R9 REG-R37. The rate is a function of the Valuation Rate Bucket (A–D by reference period and initial age; a DIA issued below age 70 with a long reference period lands in Bucket D), the premium determination date — for a DIA the “date consideration is determined and committed to by contract holder”, with an immateriality tolerance of a change under 10% in present value and under $1 million — and jumbo versus non-jumbo status; rates are published daily (jumbo) and quarterly (non-jumbo) by the NAIC R9. VM-V §1 supersedes the interest-rate guidance in AG IX-B and the interest references in AG IX-C REG-R37; the incorporated guideline family is indexed at REG-R41. VM-21 does not apply — it is the variable-annuity standard REG-R35 REG-R36.
Statutory — the formulaic chain itself. CARVM is A-820 ¶¶14–15 (method), ¶¶7–10 (interest) and Appendix A-821 (mortality) REG-R153 ¶6, as interpreted for contracts with elective benefits by AG 33 REG-R151. Both were read from the AP&P Manual print on 2026-08-06. The DIA-specific consequences — which mandatory stream families are empty, why the ±5-year adjustment re-rates the annuitization portion, why a commutation right bars Text 4(B), and why the 7% expense-allowance floor has no base here — follow from those two prints REG-R151 REG-R153.
Prescribed standard-projection assumptions reusable directly: mortality
q_x^(2012+n) = q_x^(2012) · (1 − G2_x)^n · F_xon the 2012 IAM Basic table withF_xfrom Table 6.8 (ANB) R9; lapse: not applicable; annuitization: 0% at all projection intervals; maintenance expense $50 per individual Payout Annuity Reserving Category contract per year escalated at 2.5%, plus 7 basis points applied, for contracts without an account value, to a present-value base R9 (the exact base was truncated at a page break in the research extract R9).Nonforfeiture. Model #805 applies during deferral but the cash-surrender requirement is conditional and untriggered; the paid-up annuity requirement is satisfied by construction R10 R13 §3.H(1). For Compact filings a comparative-adequacy certification replaces the demonstration R13 §1.B(1)(g). Corrected parameter: the Model #805 indexed nonforfeiture rate is floored at 15 basis points, not 1% REG-R42 — see
product-spec.md, Regulatory context.Tax. IRC §807: the tax reserve is the greater of net surrender value (zero here) and 92.81% of the NAIC-prescribed method — CARVM — capped at the statutory reserve REG-R16. Contract-holder taxation runs through IRC §72’s exclusion ratio and the §72(q) penalty R8 REG-R55.
U.S. GAAP. 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.
Standards for the modeling work. ASOP 7 (cash flow analysis) REG-R27; ASOP 22 (asset adequacy) REG-R29; ASOP 54 (pricing) REG-R70; ASOP 56 (modeling) REG-R32. There is no ASOP for principle-based reserves for annuities — ASOP 52 is scoped to VM-20 life products REG-R31 REG-R70 context.
Key sensitivities and model risks#
Longevity, levels and improvement. With no lapse decrement nothing offsets a mortality miss; the liability runs to the last survivor. The valuation table is the 2012 IAR/IAM family with Scale G2 R9 REG-R59 REG-R60 while the experience under it has moved — the 2020–2024 payout study measures directly against the 2012 IAM basis and is the right place to look for drift R15 REG-R61. Test the A/E factor and an improvement scale stronger than G2 first.
Deferral-phase mortality, especially on no-death-benefit forms. Equation (4) puts the whole ROP cost in the numerator: on the anchor cell, removing the ROP moves income by 21.2%. Deferred-period annuitant mortality is served publicly by only two dated sources REG-R65 and is the least-evidenced assumption in the model. It is also asymmetric — a higher assumed deferral mortality lets the insurer offer more income — so an error here is not conservative in either direction by default.
The pricing rate
i_pand the loadL. They set the income level directly through (4). If the model readsBfrom an administration extract these drop out of the in-force projection entirely, which is the recommended configuration for valuation work and removes the largest std exposure.Start-date adjustment take-up. A one-time, ±5-year, rate-sensitive option granted without an explicit charge in every retrieved product S1 S2 S3 S4. Take-up, direction split and selection multiplier are all std with no experience behind them.
Commutation in the extended case. The interest-rate adjustment formula is unpublished S4 S5; equation (13) is a construction. Because commutation removes guaranteed payments and leaves the life-contingent tail S4, a wrong adjustment changes the shape of the residual liability, not just its timing.
Timing conventions. Arrears versus advance moves the whole payout stream by one payment period; end-of-month versus mid-month death benefit timing moves deferral claims by half a month. Both are std and must be documented when reconciling to an administration system.
Known pitfalls specific to this product:
Building a lapse module. There is nothing to lapse to R9. A “prudent” 2% lapse assumption is wrong here and understates the liability.
Building an account-value roll-forward. The liability is a schedule of income slices keyed on (premium, purchase date, income start date, income option), not a balance [derived from S1–S4, R13]. Any credited rate, charge or interim value invented to fill a template is fictitious.
Using life-insurance mortality tables. 2017 CSO and 2015 VBT are for insured lives; annuitant longevity must use the 2012 IAM/IAR family and the payout experience studies REG-R59 REG-R61.
Chaining rounded generational rates.
q_x^(2012+n)must be computed from the 2012 period rate each time; the Valuation Manual explicitly flagsq^2014 = q^2013(rounded) × 0.99as incorrect R9 REG-R59, and A-821 ¶14 prints the identical prohibition and the identical counter-example REG-R153.Feeding the behavioral take-up rates into a CARVM run.
h_adj,h_accandh_comare projection assumptions. AG 33 prohibits experience-based elective incidence and makes the elective path a decision variable maximised over, so importing them into a formulaic reserve is a defect, not a refinement REG-R151.Single-premium refund bases. For a flexible-premium DIA the cash-refund and installment-refund bases are cumulative premiums
CP(T), not the initial premium S2 S4.Circularity in refund forms. (5) and (6) put
Bon both sides; failing to iterate leaves a systematic bias in the derived guarantee period and hence in the income.Double-counting the deferral death benefit. Its cost belongs in the purchase rate (4) and in the projected cash flows; it must not additionally be loaded into
a_def.Modeling payment acceleration as a withdrawal. It is a timing shift expressly labelled “not a liquidity feature” S2; the only economic cost is (12).
QLAC arithmetic from stale documents. A 25%-of-account-balance test, a $125,000 or $130,000 cap, or an RMD age of 70½ are all superseded R1 R2 R3, though pre-2023 insurer guides still print them S2 S3. Cite § 1.401(a)(9)-6(q), not “A-17” R1 R6.
Treating the COLA as index-linked. Every observed option is a fixed compound escalator elected at issue, not a CPI adjustment S1 S2 S3 S4.