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; it describes no single insurer’s product. Tags: [S#] / [R#] = primary product documents / regulatory-actuarial references numbered per _research/fixed-indexed-annuity.md; [REG-R#] = the cross-product library references/regulatory-and-actuarial-references.md, whose shared numbering now runs R1–R157 with most of the R73–R149 block unused — R1–R34 originating in _research/regulatory-actuarial.md and R35–R72 in _research/regulatory-actuarial-annuities.md. std marks standardizations introduced for the reference implementation, each with a footnote under its table giving the rationale and the observed range; unverified marks claims the research file could not confirm against a retrieved document.

Chassis. The base contract is a single-premium deferred annuity on the fixed-deferred chassis — surrender charge mechanics and the Model #805 nonforfeiture floor — documented in _research/fixed-deferred-annuity.md and products/fixed_deferred_annuity/, whose structure is referenced, not restated (the parameters below are this composite’s own, and the schedules, rates and the account-value roll-forward are stated here in full). Terminology bridge: the Model #805 floor is called the guaranteed minimum value (MGV) here, after S10; products/fixed_deferred_annuity/ calls the identical quantity the minimum guaranteed surrender value (MGSV), after its own specimen. Same concept, different source labels — do not model them as two quantities. Two base-contract items are restated rather than inherited, because the FIA composite selects differently from the fixed-deferred composite: the MVA family (ratio-of-yield-factors S10 here, against the linear (i₀ − iₜ) × T form with a symmetric surrender-charge cap adopted in products/fixed_deferred_annuity/product-spec.md) and the death benefit (max(account value, guaranteed minimum value) S1 S2 S5 S10 here, against full account value floored at the cash surrender benefit there — numerically the same whenever the MVA cannot lift the surrender value above the account value, but stated differently). The new material is index crediting, the premium bonus with vesting and clawback, and the GLWB rider. Index segment vocabulary is shared with products/indexed_ul/technical-notes.md, but an FIA has no cost of insurance, no net amount at risk and no death benefit corridor, and its rider is a guaranteed lifetime withdrawal benefit, not a no-lapse guarantee.

Product overview and market role#

An FIA is a general-account, non-registered deferred annuity whose credited interest is linked to an external index by a formula with a contractual floor, typically 0% S1 S6 S10 R1. The holder is never invested in equities: “The IndexMax ADV 5 is not a registered security and does not directly participate in stock or equity investments. Index returns do not include dividends” S6; two other currently-sold disclosure documents state the contract is not a security and is not registered under the Securities Act of 1933 S9 S10. The insurer invests most of the premium in fixed income and allocates the remainder to an option/hedge budget to buy the index exposure R1. The Academy records 2023 U.S. FIA sales of $95.6 billion, up 20% year over year (citing LIMRA) R1; the 2023 SOA/LIMRA study covered 17 companies, 57% of new sales and 58% of assets in force, 2.7 million contracts and $328 billion of surrender exposure R9.

A GLWB rider is “one of the most popular optional features in FIAs today,” paying for life “even if their account balance is reduced to $0” while — unlike annuitization — leaving the owner access to the account balance R1. It is the economic centre of the product: it converts a savings vehicle into a deferred-income guarantee whose cost is realised in the tail, when the account value is exhausted and the insurer pays from its own funds S1 S3 S9 R1. It also changes behaviour — in the year the surrender charge expires the surrender rate was 10% for contracts with a GLWB rider versus 33% without R8.

Representative specification#

Product identity and issue rules#

Parameter	Representative value	Basis
Design type	Single-premium deferred fixed indexed annuity, general account, not SEC-registered	S1 S2 S6 S9 S10 R1
Premium pattern	Single premium only	S1 S2 S6 S10; choice std (1)
Issue ages	40–80	S2 S3 S5 S8 S10; band std (2)
Single premium (anchor cell)	$100,000	std (2)
Minimum / maximum premium	$20,000 / $1,000,000	S3 S8 / S1 S2 S3
State basis	One composite state basis; no state variations modeled	std (3)
Free look	30 days, refund of premium less withdrawals, excluding the bonus	S6 S10
Anchor model cell	Male 62 ANB, single life, $100,000, GLWB elected at issue, lifetime withdrawals from attained age 70	std (3)

Observed: single premium only S1 S2 S6 S10; flexible premium S8; additional premium for 18 months in $25–$25,000 increments S3. Single chosen: subsequent deposits occur on 2.5% of contracts in years 2–10, 1.9% with a GLWB R8.
Observed issue ages: 35–80 / 35–74 by state group S2; maximum 80 S3; 18–80 with the rider issued 50–80 S5; 40–79 and 40–75 S8; through 80 implied by the bonus tiers S10. 40–80 spans every income-rider window; $100,000 sits inside all observed minimums ($10,000, $5,000 in listed states S1 S2; $20,000 S3 S8) and maximums.
State variation materially changes parameters — three Athene charge groups plus a California schedule S2; Midland CA/DE re-entry schedules and a CA-specific MVA collar S6 S7; Allianz’s state-specific charge naming S3 — so the research file recommends picking one basis. Issue at 62 with income at 70 puts the first withdrawal where utilization concentrates: withdrawal rates rise with attained age and are highest for qualified contracts at 70+ on RMDs R1.

Account structure and index crediting#

Parameter	Representative value	Basis
Accounts available	One fixed account plus one indexed account: S&P 500 annual point-to-point with cap	S1 S2 S4 S10; simplification std (4)
Baseline allocation	100% indexed	std (4)
Index	S&P 500 price index; dividends excluded	S2 S6 R1
Crediting method	Annual point-to-point, cap and floor	S2 S4 S10 R1
Declared annual cap (snapshot, non-guaranteed)	5.25%	S2; selection std (5)
Guaranteed minimum annual cap	0.25%	S4; selection std (5)
Index credit floor	0%	S1 S4 S10 R1
Fixed account declared rate (snapshot)	2.30%	S2
Fixed account guaranteed minimum rate	1.00%	S10; selection std (6)
Reallocation	Permitted at each contract anniversary	S1 S5
Bailout cap rate	Contract-stated; 1.00% declared in the 2022 rate sheet; not modeled	S1 S2; scope std (6)
Allocation / strategy charge	0%	current 0%, maximum 2.5% observed S3 S4; choice std (6)

Observed: six index strategies plus a fixed strategy S2; monthly-sum, annual and 2-/5-year participation methods S4; one fixed and three “Extendable” indexed accounts S10. One indexed account keeps the reference recursion to a single annual segment; the rest are variations.
Declared caps observed: 5.25% on the S&P 500 1-year point-to-point S2, effective 07/01/2022 and 4.50% S4; guaranteed minimum annual caps 0.25% S4 and 0.50% S10. The higher declared cap with the lower guaranteed minimum maximises the guaranteed-versus-current gap the model must exercise; all are NGEs revisable under ASOP No. 2 R6.
Fixed-account guaranteed minimums observed: 0.10% S4, 0.25% S6, 1.00% S10 — second-order at a 100% indexed baseline. The bailout provision (charge-free access to the accumulated value for 30 days after an anniversary at which the declared cap falls below the contractual bailout cap S1) is a real option against cap-setting discretion, described but not projected. Allianz’s allocation charge (0% current, 2.5% maximum, on point-to-point allocations, deducted from the accumulation value and in most states the guaranteed minimum value) S3 S4 and Nassau’s “Strategy Fee Amounts” S9 are set to zero so the rider charge is the only explicit deduction.

Premium bonus, vesting and clawback#

Parameter	Representative value	Basis
Premium bonus rate `b`	7% of the single premium	S5; selection std (7)
Credited to	Account value at issue, allocated as the premium is allocated	S5
Vesting vector (contract years 1–11+)	0, 10, 20, 30, 40, 50, 60, 70, 80, 90, 100%	S5
Vesting on death	100% immediately	S5
Non-vested bonus recovery	`(1 − A) × [B / (1 + B)] × C`, A = vested %, B = bonus %, C = gross withdrawal less free withdrawal amount	S10
Free-withdrawal protection	The vested amount cannot be forfeited by a free withdrawal	S5
Bonus excluded from the nonforfeiture base	Yes	S10

Observed account-value bonuses with vesting: 3% S2, 7% S5, 16% (issue age ≤75) / 14% (76–80) S10. Observed benefit-base-only bonuses: 25% of premium paid in the first 18 months S3, 45% S4, 2% of the GLWB value S8. The composite takes the middle account-value design (7% S5) with its vesting vector S5 and the verbatim clawback formula S10. Note the B/(1+B) factor — it strips the bonus out of a bonus-inclusive account value; applying B directly over-recovers. Worked at S10: contract year 5, bonus 16%, gross $100,000, free $7,000 → 70% × 0.1379 × $93,000 = $8,979.

Surrender, withdrawal, MVA, guaranteed minimum value#

Parameter	Representative value	Basis
Surrender charge, contract years 1–10	9.1, 9, 8, 7, 6, 5, 4, 3, 2, 1%; 0% thereafter	S5; selection std (8)
Surrender charge base	(gross withdrawal − free withdrawal amount) × charge %	S10
Free withdrawal amount	10% of the account value at the preceding anniversary, from contract year 1; no carry-forward	10% S1 S3 S5 S6; year 1 S1; base and no carry-forward S9 S10; combination std (9)
MVA period	The 10-year surrender charge period	S7 S10
MVA formula	`(gross withdrawal − free withdrawal amount) × { [(1 + i₀)/(1 + iₜ)]^(n/12) − 1 }`	S10; selection std (10)
MVA reference index	A declared investment-grade corporate bond yield index	generic std; the linear-form products name Barclay’s US Credit Index S6 S7
MVA limit	`max(0, gross withdrawal − charges and adjustments − guaranteed minimum value)`; a negative MVA plus charges never reduces the surrender value below the guaranteed minimum value, and the maximum positive MVA cannot exceed the maximum negative MVA	S10
Guaranteed minimum value (MGV) at issue	87.5% of premium, excluding the bonus	S10; 87.5% also at S5 S6; Model #805 §4A(2) R2
MGV accumulation rate	1.00%	corridor 0.15%–3% R2 S10; level std (11)
Annual contract charge in the MGV roll	$0	Model #805 permits $50 R2; choice std (11)
Cash surrender value	`max( account value − surrender charge − non-vested bonus recovery ± MVA , MGV )`	S1 S6 S10
Death benefit	`max( account value , MGV )`, 100% bonus vesting, no surrender charge or MVA	S1 S2 S5 S10

Observed 10-year schedules: 12/12/12/11/10/9/8/7/6/4 S2 S10; 9.30 grading to 1.05 S3; 9.1 grading to 1 S5; 10/10/10/10/10/9/8/6/4/2 S8. The research file’s mainstream shape is “10-year surrender charge grading roughly 9–10% down to 0–1%” S3 S5 S10, of which S5 is the cleanest instance; five-year designs with re-entry into a fresh charge period also exist S6.
Varies on percentage (10% S1 S3 S5 S6; 7% S10; 5% S8), base (accumulated value S1 S5; paid premium S3; beginning-of-year accumulation value S6; prior-anniversary daily accumulation value S10) and first availability (year 1 S1; year 2 S5 S6 S10). Chosen: the most common percentage on the most computable base, available immediately so it never binds against a first-year lifetime withdrawal.
Two verbatim formula families were retrieved: the ratio-of-yield-factors form [(1+i₀)/(1+iₜ)]^(n/12) − 1 S10 and the linear form (i₀ − iₜ) × T S6 S7. The ratio form is naturally bounded; the linear form is unbounded and must always be collared — Midland collars it at the lesser of the surrender charge and cumulative net interest credited, or 0.50% of the accumulation value in California S6 S7. Athene instead embeds a 0.25% deadband: rates must fall by more than 0.25% before the MVA turns positive S1. No MVA in Missouri S2.
Correction to a common misstatement: the Model #805 §4B floor on the indexed nonforfeiture rate is 15 basis points (0.15%), not 1% R2. §4B sets the rate at the lesser of 3% and the five-year Constant Maturity Treasury rate (rounded to the nearest 1/20 of 1%, observed no more than 15 months before issue or redetermination) reduced by 125 basis points, with the result not less than 15 basis points R2; Nassau’s contract language confirms the range — rates “will range between 0.15% and 3%” S10. A flat 1.00% is a std pick inside that corridor. The $50 annual contract charge Model #805 permits R2 is set to zero because no retrieved product declares an actual annual policy fee, making the modeled floor slightly conservative.

GLWB rider#

Parameter	Representative value	Basis
Rider status	Optional, elected at issue, single or joint life; not cancellable before the 10th rider anniversary	S5 S9 S11; cancellation window S1 S2 S9
Minimum age for lifetime withdrawals	50	S2 S3 S9
Initial benefit base `BB(0)`	The single premium — the bonus goes to the account value, not the benefit base	S9; combination std (12)
Growth mechanism (baseline)	Blended: guaranteed simple rollup plus index-credit stacking, plus an annual step-up	S2 S8 S9; blend std (13); step-up std (14)
Guaranteed simple rollup rate	5.00% of the rollup base in contract years 1–10; 2.00% in years 11–20; 0% thereafter	S2
Rollup base	Premium adjusted for withdrawals — a flat dollar increment, not simple interest on the grown base	S2 S9
Stacking factor	150% of the dollar interest credited in the contract year, floored at zero	S8 S9
Growth period	To the earlier of the first lifetime withdrawal and 20 contract years	S1 S2; selection std (13)
Annual step-up (ratchet)	`BB ← max(BB, account value)` tested at each anniversary	std (14)
Rider charge	0.95% p.a. of the benefit base, deducted from the account value at the end of each contract year, after index credits	S9
Rider charge maximum	1.50%; changeable only after contract year 15	S9
Charge after account-value exhaustion	Ceases — no account value to deduct from; income continues	S9
Lifetime withdrawal percentage	Attained-age band table below	S3; 80+ band and lock convention std (15)
Joint life	Single-life percentage − 0.50%, on the younger covered person	S1 S3
Excess withdrawal treatment	Pro rata to the contract-value reduction measured net of the guaranteed amount	S9
RMD treatment	Above the guaranteed annual amount, not an excess withdrawal after exercise; before exercise it reduces the base pro rata	S1 S9

Lifetime withdrawal percentages (of the benefit base):

Attained age band	50–54	55–59	60–69	70–79	80+
Single life	3.70%	4.20%	4.70%	5.20%	5.70%
Joint life	3.20%	3.70%	4.20%	4.70%	5.20%

Basis: S3 for the 50–80 bands and both columns; the 80+ band extends S3’s single “80” row std, supported by S4, which carries an 80–100 band.

Observed: Athene’s Initial Income Base = Initial Premium × (1 + Income Base bonus), 25% (Option 1) or 15% (Option 2) S2; Allianz credits 25% S3 or 45% S4 to the benefit base only; Nassau’s Income Benefit Base “equals the premium payment at issue” S9 while the companion contract credits a 16%/14% bonus to the account value S10. The composite follows the Nassau pair, so BB(0) = $100,000 while AV(0) = $107,000. In the benefit-base-only designs the bonus never touches the surrender benefit and is forfeited if income is never taken S3 S4.
The blended form is the research file’s mainstream 2020s shape: a base “rolling up at a guaranteed simple rate for a 10–20 year deferral window plus a stacking credit on realized index interest” S1 S2 S9. The guaranteed rate comes from Athene’s stacking option (5.00%/2.00%) rather than its non-stacking option (10.00%/5.00%), since rollup and stack are not both sold at standalone levels S2; 150% is the factor at Midland S8 and Nassau S9 (Athene’s stacking option uses 200% S2). The 20-year window is Athene’s S1 S2; Nassau’s runs 15 anniversaries S9.
No retrieved document describes an automatic annual ratchet during deferral. Documented instead: American Equity increases the Income Account Value to the Contract Value on the day before income begins if the Contract Value is higher S5; Nassau computes the Annual Benefit Amount on “the greater of the Income Benefit Base and the Accumulation Value on the exercise date” S9; Allianz ratchets the withdrawal amount upward whenever interest is credited, and it can never decrease S3. The annual step-up is a std generalisation — a superset that reduces to the documented design if tested once, at exercise.
The percentage is fixed by the attained age at the first lifetime withdrawal and does not re-read the table afterwards std. Alternatives: Allianz reads the band from “age at the most recent contract anniversary,” letting it step up with attained age S3; Nassau makes it depend on both age at issue and age of the youngest covered person at exercise S9; Athene grades by single year of age 50–90 across three payout options (Level, Earnings-Indexed, Inflation-Adjusted) S1; American Equity uses sex-distinct single-life factors, with Montana requiring gender-neutral issue on the female factors S5.

Contractual mechanics#

Only deltas from the fixed-deferred chassis; surrender charge assessment and the Model #805 floor follow _research/fixed-deferred-annuity.md. The MVA family and the death benefit are specified in the table above rather than inherited (see Chassis), because the fixed-deferred composite adopts the linear MVA form and a full-account-value death benefit.

Index credit#

At each anniversary the indexed account earns index credit = credit base × cr, with cr = max(floor, min(cap, R)) S2 S4 S10 R1, where R is the point-to-point return of the price index over the contract year, dividends excluded S6 R1, and floor = 0% S1 S4 S10. The same engine must support: max(f, p × R) (participation) S4 S10 R1; max(f, min(c, p × R)) (participation and cap) — worked at R1 as min(80% × 10%, 6%) = 6%; max(f, p × R − s) (spread / index margin) S8 R1; d × 1{R ≥ 0} (performance trigger — a declared rate credited whenever the return is non-negative) R1; and max(f, Σ₁₂ min(R_k, c_m)) (monthly sum with monthly cap) S4 R1.

Credits lock in once applied and cannot be lost to later declines S1; reallocation is permitted at the end of each crediting period, and an eliminated strategy’s value moves to the fixed strategy S1. The 0% floor applies to the index credit, not to the account value — Midland states that deductions for riders, strategy fees or enhanced crediting charges “can exceed interest credited,” “which would result in loss of premium” S7, so a model that floors the account value at its prior balance is wrong. The credit base is Midland’s “Interest Credit Basis”: the accumulation value at the beginning of the term less withdrawals from that index account, with pro rata advisory fees not reducing it S6. Mid-year withdrawal crediting varies: none in the year of withdrawal S1; prorated S3; gross × PAR/(1 + PAR), where PAR is Nassau’s Protected Account Return, not a participation rate S10; full earnings-to-date on the free amount and pro rata above S11. Volatility-controlled indices deduct embedded costs from the index return before any cap or participation rate — a 0.50% p.a. servicing cost calculated daily at BNP Paribas MAD 5 and AiPEX S2 — so they need an index-return haircut.

Premium bonus, vesting and clawback#

The 7% bonus is credited to the account value at issue and earns index credits from day one S5; on death 100% vests immediately S5. On a gross withdrawal exceeding the free amount, or on full surrender, the insurer recovers the non-vested portion S10:

non-vested bonus recovery = (1 − A) × [ B / (1 + B) ] × C

with A the vested percentage for the contract year, B the bonus percentage and C the gross withdrawal less the free withdrawal amount S10. The B/(1+B) factor exists because the account value already contains the bonus; using B directly over-recovers by (1+B). Nassau adds that a premium bonus “should never be considered an ‘offset’ to a penalty paid under the prior annuity, because it is repaid to the Company if you make certain withdrawals,” and the free-look refund excludes it S10.

GLWB benefit base#

The benefit base is notional: no cash value, cannot be withdrawn, cannot be taken as a lump sum S1 S9. At each anniversary during the growth period:

rollup = g(t) × rollup base                (simple, flat dollar)   [S2] [S9]
stack  = 150% × max(0, index credit + fixed interest)              [S8] [S9]
BB     = max( BB(prior) + rollup + stack , account value )         step-up **[std]**

Two distinctions are commonly got wrong. The rollup is not simple interest on the current base — Athene computes it on “the Premium minus Withdrawals” S2, Nassau on the “Adjusted Initial Income Benefit Base” S9; both give a flat dollar increment, confirmed by Nassau’s 15-year guaranteed-value table at a flat $3,000 per year on a $100,000 adjusted initial base, $103,000 → $145,000 over 15 years S9. The stack is on realised dollar credits, net of strategy fees, floored at zero — Nassau’s Echo Amount = 150% × [fixed interest paid over the contract year + index credit amounts − Strategy Fee Amounts], floored at zero, worked at S9 as a $3,000 roll-up plus a $15,000 echo taking a $200,000 base to $218,000. Growth ceases at the earlier of the first lifetime withdrawal and the end of the growth period S1 S9.

Rider charge#

rider charge = 0.95% × benefit base S9, deducted from the account value at the end of each contract year after index credits are added, from the fixed account first and then proportionately across indexed accounts S9. The rate may be reset after contract year 15 but never above 1.50%, a proportional charge is taken on surrender or rider termination, and the signature page requires the owner to acknowledge that the charge “will continue even after the surrender charge period on my contract has ended” S9. Once the account value is exhausted the charge stops — there is nothing to deduct it from, and Nassau is explicit that income continues in that state S9; whether Athene’s charge continues is not documented in any retrieved source unverified. Alternatives: charge on the contract value S5; no explicit charge, funded through the option budget — Midland discloses that a built-in GLWB “may offer lower credited interest rates, lower index cap rates, lower participation rates and/or greater index margins” S8, and Allianz states there is no additional charge for its benefit-base riders S3.

Lifetime withdrawals and excess withdrawals#

LW = payout%( attained age at the first lifetime withdrawal , single/joint ) × BB

Withdrawals up to LW incur no surrender charge, no MVA and no bonus clawback even if LW exceeds the free withdrawal amount S9; unused LW does not carry forward S9 (Allianz is the exception, accumulating the shortfall without interest as a “cumulative withdrawal amount” S3). A withdrawal is applied first against the guaranteed annual amount — that portion reduces the account value dollar for dollar and leaves BB and LW unchanged. Only the excess reduces the guarantee, pro rata to the contract-value reduction measured net of the guaranteed amount S9:

E = max(0, gross withdrawal − LW)
ρ = E / ( account value before the withdrawal − LW )
BB ← BB × (1 − ρ)        LW ← LW × (1 − ρ)

Worked verbatim at S9: account value $100,000, base $200,000, annual benefit amount $10,000 (5%), withdrawal $28,000 → denominator $90,000, excess $18,000, reduction 20%, base → $160,000, benefit amount → $8,000. Before exercise, any withdrawal (including an RMD) reduces the benefit base, the rollup base and future income in the same proportion the account value is reduced — ρ = gross withdrawal / account value before the withdrawal S1 S3 S5 S9. The excess above the free withdrawal amount additionally attracts the surrender charge, the MVA and the bonus clawback.

Account value exhaustion — the load-bearing rule#

Treatment is cause-dependent. If lifetime withdrawals and rider charges alone drive the account value to zero, the contract enters a depleted-but-in-force state and the insurer pays the lifetime withdrawal amount from its own funds for the rest of the covered life S1 S3 S9 R1: Athene’s “Extended Income Guarantee Phase” states that if lifetime income withdrawals “reduce your Accumulated Value to zero, you’ll continue to receive the Lifetime Income Withdrawal amount for the rest of your life” S1; Nassau’s income continues if the accumulation value reaches zero “as a result of rider fee deductions or guaranteed income payments” S9; Allianz’s worked example runs the account value to zero at age 75 with income continuing S3. If excess withdrawals, surrender charges or MVAs drive the account value to zero, payments stop and the rider terminates S1 S9; American Equity: “Should excess withdrawals reduce the Contract Value to zero, the IAV will also be reduced to zero, and the contract as well as the rider will be considered Surrendered” S5. In the depleted state there is no surrender value, no death benefit and no possibility of lapse — the only exit is death (or of the survivor under the joint option) S1 S9.

Rider termination and continuation#

The rider terminates on the earliest of: death of the (surviving) covered person; the benefit base reduced to zero; termination of the base contract; assignment; owner cancellation on or after the earliest cancellation date; or a change in a covered person — with no refund of past charges S9. Athene permits cancellation on or after the 10th rider anniversary S1 S2 and continues the rider on spousal continuation in the accumulation phase, but in the income or extended-guarantee phase only if the joint option was elected S1; American Equity requires the spouse to be sole primary beneficiary, elect continuation, and be at least 50 S5.

Riders and options#

In scope (modeled): the GLWB rider above, single life on the anchor cell, with the joint-life payout column available as a model-point switch S1 S3.

Described, out of scope (not projected):

Income doubler / enhanced income benefit. Athene: 2× for up to 60 months on confinement to a qualified care facility 180 of 250 days, after 1 year in force and while in the income phase; not in CA or MA S1. Allianz Income Multiplier: 2× after 5 years in force on inability to perform ≥2 of 6 ADLs or confinement ≥90 days in a consecutive 120-day period S3. American Equity Wellbeing Benefit: ADL-driven, home care qualifies, 2-year wait, up to 5 years S5.
Confinement and terminal illness waivers. Up to 100% of the account value free of charge and MVA S1 S5 S6; Nassau waives the surrender charge only, leaving bonus clawback and MVA in force S10. At Athene these are excess withdrawals that terminate the income rider S1 — a genuine interaction to flag.
Other base-contract options: the bailout cap provision S1 S2 (footnote 6); the advisory-fee (fee-based / RIA) variant of up to 1.5% of accumulation value annually, treated as a partial surrender S6; the Minimum Interest Credit true-up at the end of the withdrawal charge period, percentage not disclosed S1; index-value locks and interim-value designs (Allianz Index Lock and Auto Lock S3; Nassau’s Daily Account Value / Protected Account Value with a 90% protection level and Reset/Extend elections S10; Nationwide’s daily Balanced Allocation Value with a one-time lock-in S11).
Additional index accounts: multi-year (2- and 5-year) participation strategies S2 S4; volatility-controlled proprietary indices S2 S10; monthly sum with cap S4; performance trigger R1; threshold participation and daily average with index margin S8; term participation with annual performance credits on a 5-year re-entry chassis S6; the Balanced Allocation Strategy S11.
Benefit-base death benefit — the PIV taken over ≥5 years, limited to 250% of the accumulation value, as an alternative to an account-value lump sum S3 — and annuitization / payout options S6 S10, including Nassau’s election of lifetime payments of 1/12 of the annual benefit amount at the contract maturity date S9. Model #805 §8 fixes the maturity date for minimum-value purposes at the later of the anniversary following the annuitant’s 70th birthday and the 10th contract anniversary R2.

Variations across insurers#

Where the bonus lands — the biggest structural fork. Account-value bonus with vesting and clawback: 3% S2, 7% S5, 16%/14% S10. Benefit-base-only bonus: 25% S3, 45% S4, 2% of the GLWB value S8. These need different code — a vesting vector and a clawback on the surrender path versus a second value stream that never feeds the surrender benefit. Chosen: the account-value design, which exercises both the vesting vector and the b/(1+b) clawback; the other is a strict simplification of it.
Benefit base growth: guaranteed rollup, pure stacking, or blended. Rollup: Athene 10.00%/5.00% simple on premium less withdrawals S1 S2; American Equity compound (Options 1, 3, 5) or simple (Options 2, 4) at a declared IAV rate with 15-, 7- and 10-year guarantee windows S5; Nassau 3% simple on the adjusted initial base over 15 anniversaries S9. Pure stacking: Allianz — the Protected Income Value grows only by 150% (Balanced) or 250% (Accelerated) of index credits, and in the Accelerated option only 50% of index credits reach the account value S3 S4. Blended: Athene Option 2 (5.00%/2.00% + 200% stacking) S2; Midland IncomeVantage (2% of the GLWB value + 150% of dollar interest credited) S8; Nassau (3% roll-up + 150% Echo) S9. Chosen: blended — the mainstream shape, degenerating to either pure form by zeroing one term. Pure stacking shifts the deferral guarantee from insurer to market and is cheaper to hedge.
Rider charge base, and whether the rider is optional. On the benefit base: 1.00% S1 S2, 0.95% S9 — the classic GLWB charge, which grows as the base rolls up. On the contract value: American Equity, with Option 1 carrying no fee at all S5. No explicit charge, funded through reduced caps and participation rates: Allianz S3 S4 and Midland IncomeVantage S8. Built-in and mandatory (Athene, Midland IncomeVantage) versus optional (American Equity, Nassau, Nationwide) S1 S5 S8 S9 S11. Chosen: optional, 0.95% of the benefit base S9 — the largest and most explicit tail exposure and the only one with a retrieved verbatim charge base.
Withdrawal percentage structure. Five bands 50–80 with a flat 0.50% joint reduction S3; three bands 60–100 S4; single years of age 50–90 across three payout options S1; single years of age 50–80 by sex plus a joint column S5. Chosen: the S3 band table — the simplest structure that still shows the age gradient, and its joint column is exactly single − 0.50%, matching S1.
What happens at exhaustion. Universally, lifetime income survives exhaustion by guaranteed withdrawals and fees S1 S3 S9 R1; universally it does not survive exhaustion by excess withdrawal S1 S5 S9. Athene’s Earnings-Indexed payout additionally increases 1% annually in the extended phase S1. Chosen: level payments after exhaustion S1.
Interim value and term structure. Three interim-value tiers: none — credits only at anniversary, no credit in the year of withdrawal S1; prorated or partial credit on withdrawal S3 S10 S11; full daily interim value at Nassau S10 and Nationwide S11, a daily mark of the embedded option and the hardest to model. Most products credit annually with annual reallocation S1 S3 S5 S10, but Midland IndexMax ADV 5 is a 5-year term product with automatic re-entry into a second 5-year term carrying a fresh surrender charge and MVA period S6, and Nassau’s Extendable accounts let the owner extend a segment a year at a time, participation-rate changes applying retroactively to the whole segment and cap changes prospectively only S10. Chosen: no interim value, annual single segment S1.
MVA formula family and collar — see footnote 10. Free withdrawal percentage tracks the income orientation of the product: 10% on accumulation-oriented and hybrid products S1 S3 S5 S6; 7% with none in year 1 on the high-bonus Nassau Athos S10; 5% on the income-focused MNL IncomeVantage S8. Chosen: 10%.
Vintage caveat. Declared rates are stamped at different dates — Allianz 222 as of the access date S4, Athene as of 07/01/2022 S2 — and Athene’s current rate sheets could not be fetched [S-f1]. Declared caps, participation rates, rollup rates and rider charges are non-guaranteed elements captured only as of those dates; they illustrate parameter levels, not durable product constants R6.

Regulatory context#

Nonforfeiture — NAIC Model #805 and Model #806. The minimum nonforfeiture amount accumulates net considerations of 87.5% of gross considerations at the §4B rate, less accumulated withdrawals, an accumulated $50 annual contract charge, premium tax paid and indebtedness R2 REG-R42. The §4B rate is the lesser of 3% and (five-year CMT − 125 bp), floored at 15 basis points — not 1% R2 REG-R42; Nassau’s contract language confirms the 0.15%–3% range S10. Under §4C, while the contract provides “substantive participation in an equity indexed benefit” the 125 bp reduction may be increased by up to an additional 100 bp if the present value of the extra reduction does not exceed the market value of the equity benefit R2. Model #806 §7 operationalises that: if the annualized option cost of the guaranteed index features is ≥25 bp, the reduction is the lesser of 100 bp and that option cost, certified by an Academy member at filing and annually R3. Model #806 §6B also permits more than one nonforfeiture rate per contract, the minimum being the sum of per-benefit minimums with excess withdrawals deducted from the lowest-rate benefit first R3. Model #808 (life nonforfeiture) does not apply to annuities REG-R2 REG-R42.

Disclosure and illustrations — NAIC Model #245, not #250. The Annuity Disclosure Model Regulation is #245; #250 is the Variable Annuity Model Regulation, which by its own definition reaches only separate-account products and so does not apply to a general-account FIA R5 REG-R43 REG-R45. Model #245 §6 requires non-guaranteed elements no more favorable than current with no assumed improvements, an index in existence at least 10 years before it may be illustrated, and three prescribed historical scenarios (most recent 10 calendar years; worst 10 continuous of the last 20; highest 10 consecutive of the last 20) each on the geometric mean annual effective rate, plus MVA upside/downside requirements R1 (§6 is the illustration-standards section and Appendix A the illustration example; the section text itself was not retrieved REG-R45). AG 49 and AG 49-A are illustration guidelines under the Life Insurance Illustrations Model Regulation (#582) and must not be reused for FIA illustrations, which run through Model #245 REG-R8 REG-R10 REG-R45.

Suitability — NAIC Model #275. The 2020 best-interest revision requires producers to act in the consumer’s best interest and insurers to supervise recommendations R4 REG-R46. Its definition of “non-guaranteed elements” — premiums, credited rates including any bonus, benefits, values, charges or the formula elements behind them, subject to company discretion and not guaranteed at issue R4 — is the cleanest available definition of a cap, participation rate, spread or declared rollup rate. Modelling relevance is indirect but real: best-interest supervision changes exchange and replacement activity, hence surrender assumptions REG-R46.

Statutory valuation — AG 33, AG 35, VM-22. Reserves run through AG 33, printed as “Determining CARVM Reserves for Annuity Contracts With Elective Benefits”, and AG 35, “The Application of the Commissioners Annuity Reserve Method to Equity Indexed Annuities”. Both were read in full in AP&P Manual Appendix C on 2026-08-06 REG-R151 REG-R152 — the manual turned out to be a free download, not the paid publication this file previously recorded REG-R33 — so their mechanics are no longer unverified, and titles and continued incorporation remain confirmed by the VM-C index REG-R41. AG 33 applies “to all annuity contracts subject to CARVM, where any elective benefits … are available to the contract owner” — no product list, no threshold, no size test — sorts every benefit into elective or non-elective, prohibits experience-based elective incidence (trial sets are maximised over instead), and determines the SVL §4b parameters at contract level (issue-year versus change-in-fund basis, cash settlement options, interest guaranteed on considerations received beyond 12 months) and at benefit level (guarantee duration, Plan Type) REG-R151. AG 35 applies “to all equity indexed annuity contracts, regardless of the date of issue, that are subject to CARVM” and supplies four computational methods — CARVM with Updated Market Values, the Market Value Reserve Method, its Black-Scholes Projection Method adaptation and the Enhanced Discounted Intrinsic Method — each of which ends by handing the greatest-present-value calculation back to AG 33; “Type 1” and “Type 2” are the guideline’s own printed section headings, not industry shorthand, Type 1 (EDIM) gated on the “Hedged as Required” criteria with quarterly appointed-actuary certification and Type 2 on the Attachment 4 assumption certification REG-R152. Two corrections the reading forces on what this paragraph used to say. (1) AG 33’s Effective Date block reads “This guideline shall be effective on December 31, 1998, affecting all contracts issued on or after January 1, 1981” REG-R151; the library elsewhere carries December 31, 1995 from IRS Rev. Rul. 2002-6 under a different title. The 1981 issue-date reach is common to both, but the extracted pages carry no amendment history, so the reconciliation is unresolved — “a later revision” would be an inference, not a fact. (2) AG 35 does not free-standingly require asset adequacy testing. Its provision is one conditional sentence — “To the extent required by law, regulation, or regulatory requirements, reserves established for equity indexed annuity policies must be tested for adequacy using appropriate methods and assumptions” REG-R152 — which presupposes the obligation rather than creating it; the binding authority is SVL §6.B and VM-30, with ASOP No. 22 the standard the analysis runs under REG-R1 REG-R100 REG-R29, and AG 35 is corroboration. AG 35 also prints no effective, adoption or operative date, no transition and no sunset; its only temporal language is “regardless of the date of issue”, so no date may be attributed to it REG-R152. VM-22 is the principle-based framework for non-variable annuities, effective for valuation dates on or after January 1, 2026, with a three-year elective transition and mandatory prospective application three years after the effective date REG-R36 (the Academy paper states elective 1/1/2026, required 1/1/2029 R1; post-launch monitoring sits with the VM-22 (A) Subgroup R7). An FIA falls in VM-22’s Accumulation category, which expressly includes “fixed income streams from guaranteed living benefits after account exhaustion”; GLB utilization risk is named among the risks to be reflected and the stochastic reserve is CTE70 REG-R36. Correction: in the January 1, 2026 Valuation Manual VM-22 is entirely the PBR framework — maximum valuation interest rates for income annuities are in VM-V Section 1, whose scope also covers guaranteed-living-benefit streams after exhaustion REG-R36 REG-R37. Enabling statute: Model #820 REG-R1 REG-R3.

Federal securities law — FIAs are not registered. Three currently-sold disclosure documents state the contract is not a security and is not SEC-registered S6 S9 S10. Rule 151A would have classified indexed annuities as securities; it was vacated by the D.C. Circuit, and Dodd-Frank §989J then directed the SEC to treat qualifying annuities as exempt securities, returning them to state regulation REG-R53 — Model #275’s drafting note records that §989J “confirmed this exemption of certain annuities from the Securities Act of 1933 and confirmed state regulatory authority” R4. The SEC release and Federal Register text could not be fetched R10; the vacatur and the §989J exempt-security direction are carried on the CRS report REG-R53, and only the enumerated §989J conditions remain unverified, never having been read against a primary document. The contrast product, a registered index-linked annuity exposing the holder to index losses, registers on Form N-4 under the 2024 SEC rule REG-R49.

Federal tax — IRC §72 and the RMD regime. Pre-annuitization distributions follow the LIFO / income-first rule of §72(e), against ratable basis recovery under the §72(b) exclusion ratio; §72(q) adds a 10% penalty on the includible portion of non-qualified distributions with exceptions including age 59½, death and disability; §72(s) requires the remaining interest to be distributed within five years of the holder’s death before annuitization, subject to a beneficiary-life-expectancy exception; and all contracts issued by one company to one policyholder in a calendar year are treated as one contract REG-R55. §1035 permits tax-free annuity → annuity exchanges but not annuity → life REG-R56, making exchange activity a first-class surrender input. For qualified money the RMD regime finalized in T.D. 10001 (applicable for calendar years beginning January 1, 2025) is a behavioral input as much as a tax one: utilization clusters at the RMD age REG-R57 REG-R58 REG-R64. RMDs are free withdrawals contractually at Athene S1 and Nassau S10, and by current company practice — explicitly not a guarantee at Midland S6 S8.

Non-guaranteed elements and other layers. Declared caps, participation rates, spreads, index margins, fixed rates, bonuses and declared rollup rates are NGEs under ASOP No. 2, revised only if anticipated experience factors have changed and never to recoup past losses; the guaranteed minimum caps and participation rates at S4 and S10 are the “minimum index parameters” §2.3 names as the guaranteed elements bounding those scales R6 REG-R26. In practice insurers reset them frequently (e.g. monthly) against the priced product option budget R1 REG-R68. Also binding: ASOP No. 7 (cash flow analysis) REG-R27; ASOP No. 22 (asset adequacy — the route AG 35’s requirement runs through) REG-R29; ASOP No. 54 (pricing) REG-R70; ASOP No. 56 (modeling) REG-R32; ASOP No. 10 and FASB ASU 2018-12 (LDTI), under which the index feature is an embedded derivative and the GLWB is a market risk benefit at fair value R1 REG-R34 REG-R71; and IRC §807, which makes the statutory annuity engine the tax-reserve engine REG-R16.