Sources#

Source ids, titles, publishers, URLs, access dates and retrieval markers are carried over verbatim from _research/fixed-deferred-annuity.md (the citation ground truth for [S#]/[R#] tags). Ids are never renumbered. Sources in the research file that are not cited by product-spec.md or technical-notes.md are omitted (dropped here: S17, S18, S19, R3, R10 — see the note at the end of the [R#] section). No new sources were fetched at drafting; nothing is marked “added at drafting”.

Access date for all citations: 2026-08-04, except the frozen [REG-R#] entries reproduced in full at the end of this file, whose own access dates (2026-08-03 or 2026-08-04) are carried from references/regulatory-and-actuarial-references.md, and the four AP&P Manual appendix entries REG-R151, REG-R152, REG-R153 and REG-R157, accessed 2026-08-06 and added after drafting. Those four are the only post-drafting additions; nothing else in this file changed source or status.

Primary product sources [S#]#

S1. Athene Annuity & Life Assurance Company — “ATHENE MaxRate® Multi-Year Guarantee Annuity (MYGA) CA Version”, producer fact sheet AN1007-CA (10/14)#

  • Publisher: Athene Annuity & Life Assurance Company (Wilmington, DE; main administrative office Greenville, SC). PDF hosted on iPipeline’s forms repository, which distributes carrier-authored producer material.

  • Doc type: producer product fact sheet (2 pages), “FOR PRODUCER USE ONLY”

  • URL fetched: https://files.ipipeline.com/AALAC/AN1007CA.pdf

  • Retrieved: YES (full text extracted)

  • Note carried over: this CA version has no market value adjustment provision.

S2. Athene Annuity & Life Assurance Company of New York — “ATHENE MaxRate® Multi-Year Guarantee Annuity (MYG)”, producer fact sheet AN1007-NY (06/16)#

  • Publisher: Athene Annuity & Life Assurance Company of New York (Nyack, NY)

  • Doc type: producer product fact sheet (4 pages), New York only

  • URL fetched: https://files.ipipeline.com/AALAC/AN1007NY.pdf

  • Retrieved: YES (full text extracted)

  • Role in this library: source of the symmetrically capped MVA (adjustment, positive or negative, not greater than the withdrawal charge) and of the renewal 5/4/3/2/1 schedule.

S3. Voya Retirement Insurance and Annuity Company — “Voya Multi-Rate Annuity (Voya MRA)” prospectus, Form 424B3, dated May 1, 2021#

  • Publisher: Voya Retirement Insurance and Annuity Company (Windsor, CT), filed with the SEC

  • Doc type: statutory prospectus for a single purchase payment, modified guaranteed deferred annuity contract (39 pages incl. Appendix I on the MVA); product closed to new sales

  • URL fetched: https://www.sec.gov/Archives/edgar/data/837010/000010300521000017/definitivemultirateannuity.pdf

  • Retrieved: YES (full text extracted, pages 1–17 and 37–39)

  • Role: uncapped geometric Treasury-based MVA; the gross-up example for a net check.

S4. Nationwide Life Insurance Company — “BOA Platinum Edge”, Form S-1 registration statement / prospectus dated May 1, 2023, “Flexible Purchase Payment Modified Guaranteed Annuity Contracts Supporting Guaranteed Periods”#

  • Publisher: Nationwide Life Insurance Company (Columbus, OH), filed with the SEC (filed 2023-04-07)

  • Doc type: registration statement containing the full prospectus, including Appendix A with MVA worked examples and a sensitivity table

  • URL fetched: https://www.sec.gov/Archives/edgar/data/1127203/000119312523095286/d490814ds1.htm

  • Retrieved: YES (full text extracted)

  • Role in this library: arithmetic unit-test anchor for the geometric MVA branch — the only retrieved source with fully worked MVA numbers.

S5. Midland National Life Insurance Company — “Oak ADVantage® multi-year guarantee annuity”, consumer brochure 34158Y REV 6-26#

  • Publisher: Midland National Life Insurance Company (West Des Moines, IA), a Sammons Financial Group member. Official insurer domain.

  • Doc type: consumer product brochure (8 pages)

  • URL fetched: https://www.midlandnational.com/documents/35453/349595425/34158Y+-+Oak+ADVantage+brochure.pdf/57b2f6a9-d3fc-65d4-c613-83f262f42fab?t=1724168079212

  • Retrieved: YES (full text extracted)

  • Note carried over: features flagged as offered “by current company practice” are explicitly not contractual guarantees and can be withdrawn at any time.

S6. Midland National Life Insurance Company — “Oak ADVantage℠ multi-year guarantee annuity” highlight sheet 34199Y REV 11-24#

  • URL fetched: https://www.midlandnational.com/documents/35453/65313/34199Y+-+Oak+ADVantage+highlight+sheet.pdf/efeb0d27-884d-e0f2-535d-6430a37a58ac?t=1635796256861

  • Doc type: 2-page product highlight sheet

  • Retrieved: YES

S7. Midland National Life Insurance Company — “Oak ADVantage® and Oak ADVantage® Care” rate sheet 32400Y REV 7-23-26 (interest rates effective July 23, 2026)#

  • URL fetched: https://www.midlandnational.com/documents/35453/349595419/32400Y+-+Oak+ADVantage+rate+sheet.pdf/fa83c185-49b5-ef49-afc7-fdf4da62b245?t=1726160212636

  • Doc type: 1-page producer rate sheet

  • Retrieved: YES

  • Caveat carried over: the declared rates 5.45% / 5.60% / 5.50% are certain, but the text-extraction order does not unambiguously bind each rate to its guarantee period; the 3 / 5 / 7-year mapping is unverified. (No rate from S7 is used in the product documents; S7 is cited only for the $50,000 minimum premium and the Care variant.)

S8. Midland National Life Insurance Company — “Understanding the market value adjustment”, 32340Y-2 REV 7-25 (Midland National Capital Income® fixed index annuity)#

  • URL fetched: https://www.midlandnational.com/documents/35453/9032621/32340Y+-+Understanding+the+MVA/7446bfd5-4e75-8e71-db85-e055f63ea9de

  • Doc type: 2-page consumer MVA explainer

  • Retrieved: YES

  • Caveat carried over: written for the Capital Income fixed index annuity, not for a MYGA. Cited here because it states the Sammons/Midland MVA formula, base and caps explicitly, and Oak ADVantage uses the same MVA family S5 S6; the numeric example must not be attributed to a MYGA and is labelled as such wherever used.

S9. Midland National Life Insurance Company — “Midland National Capital Income® Fixed index annuity — Annuity disclosure statement”, 32372Y-5 (8-24)#

  • URL fetched: https://www.midlandnational.com/documents/35453/9032621/32372Y+-+Capital+Income+disclosure+for+most+states/f334edb5-4545-608e-3e7b-f8558ed021b8

  • Doc type: signed annuity disclosure statement (12 pages)

  • Retrieved: YES

  • Caveat carried over: FIA, not a MYGA. Cited for (a) contractually-precise MVA wording, (b) the nonforfeiture-floor wording and its net-of-charges withdrawal convention, and (c) the disclosure-statement structure that Model #245 R4 drives.

S10. MassMutual Ascend Life Insurance Company — “SecureGain 5 Annuity — A fixed annuity with a market value adjustment”, consumer brochure B1088822NW 4/23#

  • Publisher: MassMutual Ascend Life Insurance Company (Cincinnati, OH), a wholly owned subsidiary of Massachusetts Mutual Life Insurance Company (formerly Great American Life)

  • Doc type: consumer brochure (12 pages) with a product-features specification table

  • URL fetched: https://mybusiness.massmutualascend.com/docs/default-source/default-document-library/forms/marketing-materials/b1088822nw.pdf?sfvrsn=845c2fde_3

  • Retrieved: YES (full text extracted)

  • Role: the charge/liquidity anchor — 9/8/7/6/5 early withdrawal charge, 10% free withdrawal, extended-care and terminal-illness waivers.

S11. MassMutual Ascend Life Insurance Company — “SecureGain 5” client rate flier F1089525NW-1 (rates effective 09/22/25)#

  • URL fetched: https://mybusiness.massmutualascend.com/docs/default-source/default-document-library/forms/marketing-materials/f1089525nw-1.pdf?sfvrsn=7b719de_1

  • Doc type: 2-page rate flier with disclosure footnotes

  • Retrieved: YES

  • Note carried over: the single best retrieved statement of the nonforfeiture floor in a real product — the GMSV definition, its 2.80% rate, the 0.25% minimum interest rate and the express tie to NAIC Model #805.

S12. MassMutual Ascend Life Insurance Company — “How a market value adjustment works”, S6075424NW 8/24#

  • URL fetched: https://mybusiness.massmutualascend.com/docs/default-source/default-document-library/forms/marketing-materials/s6075424nw.pdf?sfvrsn=d91920de_2

  • Doc type: 2-page consumer MVA explainer

  • Retrieved: YES

  • Role: the asymmetric cap design (positive capped at the early withdrawal charge, negative floored by the standard nonforfeiture law minimum) and the blended Treasury/corporate reference indices.

S13. New York Life Insurance and Annuity Corporation (NYLIAC) — “Secure Term MVA Fixed Annuity II — Just the facts”, client fact sheet ML25-007661 / SMRU5821693 (Exp. 03.20.2028)#

  • Publisher: New York Life Insurance and Annuity Corporation (a Delaware corporation), wholly owned subsidiary of New York Life Insurance Company. Official insurer domain (nylannuities.com).

  • Doc type: 4-page client fact sheet with full feature table and footnotes

  • URL fetched: https://www.nylannuities.com/connectedassets/final-assets/marketing-materials/fact-sheet-products/TPD_Client_FactSheet_ST_MVA_II_Generic.pdf

  • Retrieved: YES (full text extracted). An earlier WebFetch of the same URL and of an immediateannuities.com copy returned HTTP 403; the direct Python fetch succeeded.

  • Role: the Camp B renewal architecture (annually redeclared rates, no new surrender charge) and the GMIR-floored MVA. Gap carried over: the exact MVA algebra is not in the fact sheet — it points to a separate “Examples and Explanation” flyer, not retrieved.

S14. Symetra Life Insurance Company — “Form of Section 457 Contract Data Page”, Exhibit 99.4(i) to Form 485BPOS for Symetra Separate Account C (filed 2009)#

  • Publisher: Symetra Life Insurance Company (Bellevue, WA), filed with the SEC

  • Doc type: specimen contract data page (bracketed values), for the Spinnaker Advisor Variable Annuity

  • URL fetched: https://www.sec.gov/Archives/edgar/data/0000912869/000119312509093761/dex994i.htm

  • Retrieved: YES (full text extracted)

  • Caveat carried over: a VA chassis, not a standalone MYGA, and the values are bracketed specimen values. Cited only for the MVA on its Guaranteed Interest Period Fixed Account Option — the classic declared-rate-differential W × (Ic − In) × Fs design with its contractual duration-factor table.

S15. Forethought Life Insurance Company (Global Atlantic) — “SecureFore II Fixed Annuities” product page#

  • Publisher: Global Atlantic / Forethought Life Insurance Company (Indianapolis, IN)

  • Doc type: insurer web page (not a disclosure document)

  • URL fetched: https://www.globalatlantic.com/retirement-annuities/fixed-annuities/securefore-ii

  • Retrieved: YES (web page)

  • Note carried over: withdrawal charge percentages, issue ages, premium minima, death benefit and annuitization details were not stated on the page.

S16. Oceanview Life and Annuity Company — “Harbourview Multi-Year Guaranteed Annuity — Product Disclosure”, OVLAC-MYGA-DISC Rev. 01/20#

  • Publisher: Oceanview Life and Annuity Company. A smaller MYGA specialist, not a “major” carrier — included because it is a genuine signed MYGA product disclosure in the Model #245 format, which the majors do not post publicly.

  • Doc type: 2-page signed product disclosure with owner/producer signature block

  • URL fetched: https://oceanviewlife.com/wp-content/uploads/2020/05/OVLAC-MYGA-DISC.pdf

  • Retrieved: YES (full text extracted)

Dropped (in the research file, not cited here): S17 (New York Life Secure Term MVA IV fact sheet via Fidelity — Retrieved: NO, HTML interstitial); S18 (American Equity GuaranteeShield brochure — Retrieved: NO, DNS resolution failure); S19 (three immediateannuities.com brochures — Retrieved: NO, HTTP 403). Nothing is asserted from any of them anywhere in this library.

Regulatory and actuarial references [R#] (product research file numbering)#

R1. NAIC — Model #805, “Standard Nonforfeiture Law for Individual Deferred Annuities” (NAIC Model Laws, Regulations, Guidelines and Other Resources — Fall 2020)#

  • Publisher: National Association of Insurance Commissioners

  • URL fetched: https://content.naic.org/sites/default/files/model-law-805.pdf

  • Retrieved: YES (all 5 pages)

  • Correction carried over: in the retrieved Fall 2020 edition the indexed nonforfeiture rate floor is 15 basis points (0.15%), not 1%. The corridor is 0.15% ≤ i ≤ 3.00% with i = round(5-yr CMT, 1/20 of 1%) − 1.25%. The commonly cited 1% floor reflects the 2003 amendment as originally adopted and is unverified.

  • Same document as REG-R42.

R2. NAIC — Valuation Manual, Jan. 1, 2026 edition; VM-22: Requirements for Principle-Based Reserves For Non-Variable Annuities#

  • Publisher: NAIC (© 2025 NAIC). 457-page PDF; VM-22 begins at PDF page 227 (manual page 22-1)

  • URL fetched: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf

  • Retrieved: YES (downloaded and text-extracted; VM-22 sections read directly)

  • Gaps carried over: VM-22 Table 6.2 (partial withdrawals) was extracted only for the Qualified column and the attained-age-80-and-over row was truncated; the mandatory application date “three years after the effective date” is printed as a rule, not a date, so 2029 is arithmetic and carries unverified.

  • Same document as REG-R36 (and the parent Valuation Manual as REG-R3).

R4. NAIC — Model #245, “Annuity Disclosure Model Regulation” (NAIC Model Laws — Summer 2021)#

  • Publisher: NAIC

  • URL fetched: https://content.naic.org/sites/default/files/model-law-245.pdf

  • Retrieved: YES (40 pages; §§1–6 read)

  • Numbering note carried over: the NAIC Annuity Disclosure Model Regulation is #245, not #250. (#250 is the Variable Annuity Model Regulation — see REG-R43.)

  • Same document as REG-R45.

R5. NAIC — Model #275, “Suitability in Annuity Transactions Model Regulation” (NAIC Model Laws — Spring 2020; the best-interest revision)#

  • Publisher: NAIC

  • URL fetched: https://content.naic.org/sites/default/files/model-law-275.pdf

  • Retrieved: YES (20 pages; §§1–6 read)

  • Same document as REG-R46.

R7. IRS — Rev. Rul. 2002-6, 2002-1 C.B. (Section 807 — Rules for Certain Reserves), used to establish AG 33’s identity and effective date#

  • URL fetched: https://www.irs.gov/pub/irs-drop/rr-02-6.pdf

  • Retrieved: YES (3 pages)

  • Gap carried over at drafting: “the full text of AG 33 was not retrieved … published in the NAIC Accounting Practices and Procedures Manual, Appendix C, which is not freely accessible.” Both halves of that gap are now closed and the entry must be read with the corrections below. The AP&P Manual is a free download and was retrieved in full; AG 33 was read as printed at REG-R151, so its mechanics are no longer unverified.

  • Corrections this entry now carries. What R7 sources is the Revenue Ruling’s account of AG 33, and it differs from the manual’s print in two respects. (a) Title: R7 gives “Determining Minimum Commissioners Annuities Reserve Valuation Method (CARVM) Reserves for Individual Annuity Contracts”; the manual prints “Determining CARVM Reserves for Annuity Contracts With Elective Benefits” REG-R151. (b) Effective date: R7 gives December 31, 1995; the manual prints December 31, 1998, with the same January 1, 1981 issue-date reach REG-R151. Both are recorded; the AG 33 pages carry no amendment history, so the reconciliation is unresolved and “a later revision” is an inference, not a fact from either document. R7 remains the citation for the 1995 date and the Revenue Ruling title, and for the IRS’s §807(f) treatment; it is not a citation for the current guideline’s title, date or mechanics.

  • See also REG-R39 (the frozen title-only record, superseded in fact by REG-R151).

R8. Society of Actuaries Research Institute & LIMRA — “2023-2024 Fixed-Rate Deferred Annuity Surrender Study” (public report), February 2026#

  • URL fetched: https://www.soa.org/globalassets/assets/files/resources/research-report/2026/2023-24-frda-public-report.pdf

  • Retrieved: YES (7 pages — the public highlights report)

  • Note carried over: detailed results sit behind the Experience Studies Pro subscription and were not retrieved; only the qualitative behavioural findings and the exposure statistics are cited.

  • Related landing page catalogued cross-product as REG-R63.

R9. Society of Actuaries — 2012 Individual Annuity Reserving Report & Table; and the 2012 IAM Basic Table on mort.soa.org#

  • URLs fetched: https://www.soa.org/resources/experience-studies/2011/2012-ind-annuity-reserving-rpt/ and https://mort.soa.org/ViewTable.aspx?TableIdentity=2581

  • Retrieved: YES (web page; table page)

  • Related entries in the cross-product library: REG-R59 (Model #821 + VM-M definitions), REG-R60 (the 2012 IAR development report).

Dropped (in the research file, not cited here): R3 (NAIC “Valuation Manual (VM)-22 (A) Subgroup” committee page — retrieved, but nothing from it is cited; VM-22 facts come from the manual itself at R2); R10 (SOA “2015-2022 Fixed Rate Deferred Surrender Experience Study” — Retrieved: NO, HTTP 404; nothing asserted from it).

Cross-product regulatory references [REG-R#]#

Cited with the [REG-R#] prefix to avoid collision with the product research file’s own R-numbering. [REG-R#] resolves against a single shared numbering space running R1–R157, with most of the R73–R149 block unused. The numbering is curated in references/regulatory-and-actuarial-references.md. Research provenance is split across seven files: R1–R34 (life-origin, several of which also bind annuity models) come from _research/regulatory-actuarial.md; R35–R72 (annuity-specific) come from _research/regulatory-actuarial-annuities.md, which also carries the table showing which of R1–R34 bind annuity models and how; and R151–R157 (the seven AP&P Manual appendix items, read at first hand on 2026-08-06) come from _research/appp-ag33.md (R151), appp-ag35.md (R152), appp-a820-a821-a822.md (R153), appp-a830.md (R154) and appp-a585-a250-a255-a270.md (R155–R157). Ids are never renumbered. Entries cited by the two documents in this directory:

Tag

Provenance file

Short title

Retrieval status (per that file)

REG-R2

life

Standard Nonforfeiture Law for Life Insurance (Model #808) — cited only to record that it does not apply to annuities

fetched

REG-R16

life

26 U.S.C. §807 — tax reserves

fetched

REG-R26

life

ASOP No. 2 — Nonguaranteed Elements for Life Insurance and Annuity Products

fetched

REG-R27

life

ASOP No. 7 — Life or Health Cash Flow Analysis

fetched

REG-R29

life

ASOP No. 22 — Opinions based on asset adequacy analysis

fetched

REG-R32

life

ASOP No. 56 — Modeling

fetched

REG-R34

life

FASB ASU 2018-12 (LDTI)

fetched

REG-R36

annuities

VM-22 — PBR for Non-Variable Annuities (same document as R2)

fetched (local text extraction)

REG-R37

annuities

VM-V §1 — statutory maximum valuation interest rates, income annuities

fetched (local text extraction)

REG-R39

annuities

Actuarial Guideline XXXIII (AG 33)

no — title verified via REG-R41; mechanics unverified. Frozen, and superseded in fact by REG-R151, which read the guideline in full

REG-R41

annuities

VM-C — index of actuarial guidelines incorporated into the Valuation Manual

fetched (local text extraction)

REG-R42

annuities

Standard Nonforfeiture Law for Individual Deferred Annuities (Model #805) (same document as R1)

fetched (local text extraction)

REG-R43

annuities

Variable Annuity Model Regulation (Model #250) — cited for the #245/#250 numbering correction and the §7.B fixed-account carve-out

fetched (local text extraction)

REG-R44

annuities

Actuarial Guideline LIV (AG 54) — ILVA nonforfeiture; cited for the Model #805 scope boundary

fetched (local text extraction, complete)

REG-R45

annuities

Annuity Disclosure Model Regulation (Model #245) (same document as R4)

fetched (local text extraction)

REG-R46

annuities

Suitability in Annuity Transactions Model Regulation (Model #275) (same document as R5)

fetched (local text extraction)

REG-R49

annuities

SEC Release 33-11294 — registration for index-linked and registered MVA annuities; Form N-4

fetched via govinfo.gov (sec.gov PDF returned 403); compliance date unverified

REG-R55

annuities

26 U.S.C. §72 (same statute as R6)

fetched

REG-R56

annuities

26 U.S.C. §1035 — exchanges

fetched

REG-R59

annuities

NAIC Model #821 + VM-M annuity mortality definitions (2012 IAM/IAR, Scale G2)

fetched (local text extraction, both)

REG-R60

annuities

2012 Individual Annuity Reserving Table — AAA/SOA development report

fetched (local text extraction)

REG-R61

annuities

2020–2024 Individual Payout Annuity Mortality Experience Study

fetched (landing page)

REG-R62

annuities

Fixed Indexed Annuity Policyholder Behavior Experience Studies

fetched (both landing pages); headline shock-lapse split unverified

REG-R63

annuities

Fixed Rate Deferred Surrender Experience Studies (2023–24, 2015–2022)

partial (verified via the SOA index REG-R65); quantitative figures unverified

REG-R64

annuities

VA contract holder behavior and GLB utilization studies

fetched (2022–24 landing page)

REG-R65

annuities

SOA Individual Annuity Experience Studies — index

fetched

REG-R70

annuities

ASOP No. 54 — Pricing of Life Insurance and Annuity Products

fetched

REG-R71

annuities

ASOP No. 10 — U.S. GAAP for Long-Duration Life, Annuity, and Health Products (Doc. No. 207)

fetched (local text extraction)

Note on the curated page: references/regulatory-and-actuarial-references.md carries both halves — all of R1–R72 — with the life-origin entries (R1–R34) frozen and the annuity entries (R35–R72) merged in. Research provenance remains split between _research/regulatory-actuarial.md (R1–R34) and _research/regulatory-actuarial-annuities.md (R35–R72); the numbering is the same shared space in every file and is never renumbered.

Id, title, publisher, URL, access date and fetched marker of the frozen entries reproduced below are carried from references/regulatory-and-actuarial-references.md. No new sources were fetched at drafting. Two formatting notes, neither of which changes any id: headings carry the REG- prefix used throughout this section, because the shared numbering collides with the product research file’s own R# numbering above (this file’s R1 is Model #805; REG-R1 is the Standard Valuation Law); and bare R# references inside a carried-over entry are that entry’s own text and resolve against the shared [REG-R#] numbering, not against the [R#] section above.

Frozen entries (R1–R72) newly cited here.

REG-R1. Standard Valuation Law (Model #820)#

  • Publisher: National Association of Insurance Commissioners (NAIC)

  • URL: https://content.naic.org/sites/default/files/model-law-820.pdf

  • Accessed: 2026-08-03 · Fetched: yes (27-page PDF retrieved and read; re-read for the reserves stream at §§3, 4b, 5, 5a, 6, 7, 11, 12)

REG-R40. Actuarial Guideline XXXV — The Application of the Commissioners Annuity Reserve Method to Equity Indexed Annuities (AG 35)#

  • Publisher: NAIC

  • URL: none — no free official standalone text was located. Exact title verified from the VM-C index (page C-2) R41; the authoritative text is in the AP&P Manual Appendix C.

  • Accessed: 2026-08-04 (search date; guideline text not retrieved)

  • Fetched: no. Same limit as R39.

  • Frozen, and superseded in fact by REG-R152, which read AG 35 in full from the AP&P Manual on 2026-08-06. This record is preserved unaltered as evidence of what was true at drafting.

AP&P Manual appendix entries (R151–R157) cited here — added after drafting. Id, title, publisher, URL, access date, fetched marker and carried-forward limits below are reproduced from references/regulatory-and-actuarial-references.md. Three facts stated there apply to all of them and are carried with the entries. (a) One physical document: all seven R151–R157 items are appendix items of the NAIC Accounting Practices and Procedures Manual, As of March 2026 — the same 2,117-page consolidated PDF already catalogued as R73, a free download from content.naic.org. They take appendix-level ids so a document can cite A-820 ¶15 or AG 33 Text 4 instead of a 2,117-page manual. This supersedes in fact the library’s earlier record of the manual as a paid publication that could not be fetched, which is what caused AG 33 and AG 35 to be cited by title only REG-R39 REG-R40. (b) Edition line: none of these items prints “As of March 2026” on its own pages; every extracted page carries only the footer “© 1999-2026 National Association of Insurance Commissioners”, which is a copyright span, not an adoption, effective or revision date and must never be cited as one. (c) Licence caution, inherited from R73: personal and non-commercial use; redistribution or integration “into any software or other publication” requires written NAIC permission — so the two documents in this directory paraphrase the mechanics and cite the block, paragraph or page, quoting only short anchors.

REG-R151. Actuarial Guideline XXXIII — Determining CARVM Reserves for Annuity Contracts With Elective Benefits (AG 33), as printed in the AP&P Manual#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Appendix C — Actuarial Guidelines; printed pages AG33-1 to AG33-8 = PDF pages 1496–1503; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; all eight printed pages read in full — Background Information, Purpose, Definitions, Text 1–7 and Effective Date)

  • Limits carried forward from _research/appp-ag33.md: the running heads confirm Appendix C, but these pages carry no volume statement — the Volume II placement is R73’s record, not theirs. They carry no amendment history, no adoption note and no revision log, so the guideline’s printed Effective Date of 31 December 1998 cannot be reconciled here against the 31 December 1995 date the library carries from IRS Rev. Rul. 2002-6 R7 for a differently-titled instrument; both are recorded and neither is presented as settled. AG 33 contains no formulas, symbols, tables or factors beyond the 7% expense allowance and the 1998–2000 phase-in percentages, and names no other guideline anywhere — not AG 35, not AG 43. Cite by block (Background / Definitions / Text), since all three restart at 1. Spurious intra-word spaces at justified-line breaks are text-layer artefacts and were closed up in the research file’s quotations.

  • Supersedes in fact: R39 (“guideline text not retrieved”), which is frozen and is preserved unaltered above.

REG-R152. Actuarial Guideline XXXV — The Application of the Commissioners Annuity Reserve Method to Equity Indexed Annuities (AG 35), as printed in the AP&P Manual#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Appendix C — Actuarial Guidelines; printed pages AG35-1 to AG35-10 = PDF pages 1505–1514; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; all ten printed pages read in full, including Attachment 1 — the four computational methods, Attachment 2 — the “Hedged as Required” criteria, and the Attachment 3 and 4 certification forms)

  • Limits carried forward from _research/appp-ag35.md: the guideline prints no effective, adoption or operative date, no transition, no phase-in, no grandfathering and no sunset — the only temporal language in the document is “regardless of the date of issue”, so any date attached to AG 35 elsewhere is an inference from outside this text. It defines no term “equity indexed annuity”, contains no symbols and no algebraic notation (every method is prose; the sole printed formula is SP% = (1 - .03) ^ 5 = 86%), and prints no volatility, dividend yield, risk-free curve or option pricing model. Its supersession clause reaches Sections 5 and 6 of the NAIC Interest-Indexed Annuity Contracts Model Regulation, an instrument not in this library at all and recorded as a cross-reference only. It names Actuarial Guideline IX-B three times as an alternative source of the valuation interest rate; AG IX-B has not been read and is held only as a VM-C index entry (R41). Text-layer artefacts noted at the point of use: a lost superscript in the Attachment 2 option-replication SP% formula, and irregular intra-word spacing throughout.

  • Cited here for a negative finding only. AG 35’s Scope is limited to “all equity indexed annuity contracts, regardless of the date of issue, that are subject to CARVM”, so it does not reach the book-value MYGA specified in this directory. Nothing in its four computational methods is used or restated here.

  • Supersedes in fact: R40 (“guideline text not retrieved”), frozen and preserved unaltered above.

REG-R153. Appendix A-820 — Minimum Life and Annuity Reserve Standards (with Appendix A-821, Annuity Mortality Table for Use in Determining Reserve Liabilities for Annuities, and Appendix A-822, Asset Adequacy Analysis Requirements)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; A-820 printed A820-1 to A820-13 = PDF pages 1186–1198, A-821 printed A821-1 to A821-6 = PDF pages 1199–1204, A-822 printed A822-1 = PDF page 1205; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; A-820 ¶¶1–28 read in full, A-821 read in full including the 2012 IAM Period Table and Projection Scale G2 printed at its Appendices I–IV, and A-822’s four paragraphs read in full)

  • Limits carried forward from _research/appp-a820-a821-a822.md: “As of March 2026” is not printed on PDF pp. 1186–1205 — cite the copyright footer for what those pages print. A-821 prints only the 2012 IAM Period Table and Projection Scale G2; the 1994 GAR table and its AA_x factors, the Annuity 2000 table and 1983 Table “a” are named and not printed, so A-821 ¶16 is not computable from library sources, and no standard is printed for individual annuities issued before 1 January 2001. A-820 names its life mortality tables without printing them and the 2017 CSO is nowhere in its text. Three text-layer repairs are recorded in the research file rather than hidden: the lost fraction bar at ¶7.a.i(a) (the term is (W/2)·(R2 − .09)), the lost R1/R2 subscripts, and the ¶8.c weighting-factor tables, which were reassembled by column position from a scrambled layer. Two internal oddities are recorded as printed and not reconciled: ¶22’s empty window and ¶7’s “effective date of the Codification”, a threshold whose date A-820 never prints. Naming trap: AP&P Appendix A-822 is not NAIC Model #822 (R101/R102) — A-820’s own header does not list Model #820 while A-822’s does.

  • Supersedes in fact: the A-820 half of R110’s limit (“A-820 and A-830 as printed in the AP&P Manual were not retrieved”), and, for the paragraphs it carries, the reliance on R1 and R6 alone. R110 is frozen and is preserved unaltered in references/regulatory-and-actuarial-references.md.

  • Used in this directory for the CARVM construction (¶15) and its scope gate (¶¶13.b, 14), and for the SVL §4b weighting-factor machinery AG 33 points at (¶8.c). A-820 gives no elective-path list — that is AG 33’s subject REG-R151.

REG-R157. Appendix A-255 — Modified Guaranteed Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; printed page A255-1 = PDF page 1096; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; the whole item read in full — seven paragraphs)

  • Limit: like A-250, A-255 delegates the reserve method itself to Appendix A-820; what it adds is three operative rules — the separate account liability must be at least the surrender value produced by the contract’s own market-value-adjustment formula, a shortfall against the market value of the separate account assets must be made good by a transfer into that account, and any additional reserve needed to cover future guaranteed benefits must be established. No MVA formula and no parameters for one are printed — the formula is the contract’s. Like A-250 it contains no formula, symbol, factor or table, does not mention CARVM, and prints no effective date.

  • Cited here for a boundary, not a mechanic. A-255 ¶1 defines a Modified Guaranteed Annuity by asset location — underlying assets held in a separate account during any period when the contract holder can surrender — so it does not reach the general account, book-value MYGA specified in this directory, and none of its rules is applied to the MVA modelled here.

Provenance note#

Extraction details live in _research/fixed-deferred-annuity.md: that file records which facts came from which source, including the unverified flags (the Model #805 1% floor, the Midland rate-to-period mapping, AG 33’s mechanics, the pre-2026 content of VM-22, the absence of a bailout provision, the VM-22 mandatory application date), the failed fetches (S17, S18, S19, R10), the FIA-not-MYGA caveats on S8/S9, the VA-chassis caveat on S14, and the “current company practice” caveat on S5/S6. One of those flags is now closed: AG 33’s mechanics are no longer unverified — the guideline was read in full from the AP&P Manual on 2026-08-06 REG-R151, and with it AG 35 REG-R152 and A-820 with A-821 and A-822 REG-R153. The research file’s own R7 entry, its §15 and its Gaps item 1 still carry the pre-2026-08-06 wording and the December 31, 1995 date; the corrected record is the R7 entry above and the AG 33 paragraphs in product-spec.md and technical-notes.md. Every other flag in that list stands. The cross-product bibliographies _research/regulatory-actuarial.md (R1–R34), _research/regulatory-actuarial-annuities.md (R35–R72) and the AP&P Manual appendix extractions _research/appp-ag33.md (R151), appp-ag35.md (R152), appp-a820-a821-a822.md (R153) and appp-a585-a250-a255-a270.md (R155–R157) play the same role for [REG-R#] tags. Standardizations marked std in product-spec.md and technical-notes.md are introduced at drafting and are not attributable to any source.

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