Sources#
Source ids, titles, publishers, URLs, access dates and retrieval markers are carried over
verbatim from _research/fixed-indexed-annuity.md (the citation ground truth for [S#]/[R#]
tags). Ids are never renumbered. Sources in the research file that are not cited in
product-spec.md or technical-notes.md are omitted (dropped here: S12, the Athene Ascent
Pro producer landing page, and S-f2, the Athene Ascent Series spec-sheet mirror that returned
HTTP 403). No new sources were fetched at drafting; nothing is marked “added at drafting.”
Two cross-product entries — REG-R8 and REG-R10 (AG 49 / AG 49-A) — were added to the
[REG-R#] table at review to carry the FIA-versus-IUL illustration-scope statement in
product-spec.md; both are pre-existing entries in _research/regulatory-actuarial.md, not new
retrievals. Four more — REG-R151, REG-R152, REG-R153 and
REG-R157 — were added on 2026-08-06, when seven AP&P Manual appendix items were read at first
hand from the free As of March 2026 download; those four are the ones this product’s documents
actually cite, and their metadata is carried from
references/regulatory-and-actuarial-references.md. They
supersede in fact — they do not replace — R11, REG-R33, REG-R39, REG-R40 and the A-820
half of REG-R110, all of which are retained unaltered below, because a superseded record is
evidence rather than clutter.
Access date for all citations: 2026-08-04, except the four post-drafting entries REG-R151, REG-R152, REG-R153 and REG-R157, accessed 2026-08-06.
Note on the two R-numberings: the [R#] ids below are local to
_research/fixed-indexed-annuity.md and are unrelated to the [REG-R#] ids in the
cross-product section further down. For example R3 here is NAIC Model #806, while REG-R3 is
the NAIC Valuation Manual.
Primary product sources [S#]#
S1. Athene Annuity and Life Company — “Athene AscentSM Pro 10 — For income that lasts as long as your retirement.” (consumer brochure, form 65178 (04/26/24))#
Publisher: Athene Annuity and Life Company, West Des Moines, IA (insurer’s own consumer brochure; PDF mirrored by an authorized distributor site)
Doc type: consumer product brochure (16 pages)
URL fetched: https://annuityeducator.com/storage/59206/athene-ascent-pro-10.pdf
Retrieved: YES (full PDF text-extracted locally)
Role in this library: reference for the simple-rollup-plus-stacking income rider, the three income-phase definitions, the Extended Income Guarantee (post-depletion) rule, and the income-doubler trigger.
S2. Athene Annuity and Life Company — “Athene AscentSM Pro 10 Bonus — Product Guide, Rates effective July 1, 2022” (form 65220 (07/01/22))#
Publisher: Athene Annuity and Life Company (insurer product guide / rate-and-spec sheet; PDF mirrored by a distributor site)
Doc type: producer product guide + declared rate sheet (6 pages)
URL fetched: https://iamsascend.com/wp-content/uploads/2023/01/Ascent-Pro-Fact-Sheet.pdf
Retrieved: YES (full PDF text-extracted locally)
Caveat carried over: declared rates are as of 07/01/2022 and are non-guaranteed; Athene’s current rate sheets could not be fetched (see S-f1).
S3. Allianz Life Insurance Company of North America — “Allianz Benefit Control® — Fixed Index Annuity” (consumer brochure, ABC-001 (R-11/2025))#
Publisher: Allianz Life Insurance Company of North America (official allianzlife.com URL)
Doc type: consumer product brochure (16 pages)
URL fetched: https://www.allianzlife.com/-/media/Files/Global/documents/2020/02/24/20/53/ABC-001.pdf
Retrieved: YES (full PDF text-extracted locally)
Role in this library: source of the representative lifetime-withdrawal age-band table, and the reference case for the benefit-base-only bonus and pure-stacking benefit-base design.
S4. Allianz Life Insurance Company of North America — “Allianz 222® Annuity — Guide to current rates as of 8/4/2026” (form M-7246 (R-8/2026))#
Publisher: Allianz Life Insurance Company of North America (official allianzlife.com URL)
Doc type: declared-rate sheet (3 pages)
URL fetched: https://www.allianzlife.com/what-we-offer/annuities/fixed-index-annuities/222/rates/-/media/Files/Allianz/PDFs/declared-rates/fixed-index-annuity/M-7246-Declared.pdf
Retrieved: YES (full PDF text-extracted locally)
Role in this library: the guaranteed minimum index parameters (minimum annual cap, minimum monthly cap, minimum participation rate, minimum fixed rate) that bound the non-guaranteed scale.
S5. American Equity Investment Life Insurance Company — “IncomeShield 10 with Optional Lifetime Income Benefit Rider” (consumer brochure, 01SB1164-10 10.16.19)#
Publisher: American Equity Investment Life Insurance Company (insurer brochure; the official media.american-equity.com URL failed DNS from this environment, so a distributor mirror of the same form number was used — see S-f3)
Doc type: consumer product brochure (12 pages)
URL fetched: https://www.annuityresources.com/assets/brochures/americanequityincomeshield10.pdf
Retrieved: YES (full PDF text-extracted locally)
Role in this library: source of the representative premium bonus rate, bonus vesting vector and surrender charge schedule, and of the at-exercise step-up of the income base to contract value.
Caveat carried over: 2019 brochure; current IAV rates, the rider fee percentage and its base, and the Minimum Guaranteed IAV Rate are undocumented.
S6. Midland National Life Insurance Company — “IndexMax ADV® 5 Fixed index annuity — Annuity disclosure statement” (form 32908Y-1, 8-24)#
Publisher: Midland National Life Insurance Company (Sammons Financial) — official midlandnational.com document library URL
Doc type: signed annuity disclosure statement (12-page form; the most contractually precise consumer-facing document short of the contract itself)
URL fetched: https://www.midlandnational.com/documents/35453/9032621/32908Y+IndexMax+ADV+5+disclosure/e1927985-0db5-24cb-257c-61b46011487e
Retrieved: YES (full PDF text-extracted locally)
Role in this library: the “not a registered security” and dividend-exclusion statements, the Interest Credit Basis definition, the linear MVA form and collar, and the 87.5% minimum surrender value.
S7. Midland National Life Insurance Company — “Midland National Capital Income® fixed index annuity — Understanding the market value adjustment” (form 32340Y-CA, REV 10-24, for use in California only)#
Publisher: Midland National Life Insurance Company — official midlandnational.com URL
Doc type: contract-feature explanatory disclosure (2 pages)
URL fetched: https://www.midlandnational.com/documents/35453/9032621/32340Y-04+-+Understanding+the+MVA+CA/e6de4768-02a1-cdef-4370-aa8c1896db2d
Retrieved: YES (full PDF text-extracted locally)
Role in this library: the California MVA collar, and the explicit statement that rider and strategy charges can exceed interest credited — i.e. that the 0% floor applies to the index credit and not to the account value.
S8. Midland National Life Insurance Company — “MNL IncomeVantage® fixed index annuity — quick reference guide” (form 25665Y REV 1-20)#
Publisher: Midland National Life Insurance Company — official midlandnational.com URL
Doc type: producer quick reference guide (1 page; “FOR FINANCIAL PROFESSIONAL ONLY”)
URL fetched: https://www.midlandnational.com/documents/35445/8312558/25665Y.pdf/dcf404b7-a1fd-037e-b188-60cfacb0c537
Retrieved: YES (full PDF text-extracted locally)
Role in this library: the 150% stacking factor, the index-margin (spread) crediting method, and the disclosure that a built-in GLWB is funded through lower caps, participation rates and higher index margins rather than an explicit charge.
S9. Nassau Life and Annuity Company — “Indexed Annuity Rider Disclosure Document — Amplified Income Plus” (form OL5370B, 8/25; rider forms 19GLWB3, ICC19GLWB3.1) — SAMPLE#
Publisher: Nassau Life and Annuity Company (Nassau Financial Group) — official assets.nfg.com document
Doc type: signed rider disclosure document (specimen) — the most contractually precise GLWB description retrieved
URL fetched: https://assets.nfg.com/documents/salesnet/NGARider-OL5370-sample.pdf
Retrieved: YES (full PDF text-extracted locally)
Role in this library: the primary GLWB mechanics anchor — simple roll-up on the adjusted initial base, the 150% Echo stacking credit, the 0.95%-of-benefit-base rider fee and its 1.50% cap, the verbatim excess-withdrawal reduction formula, and the cause-dependent post-depletion rule.
S11. Nationwide Life and Annuity Insurance Company — “Nationwide New Heights® fixed indexed annuities — Index and Strategy Growth Opportunities” (form FAM-0475AO.2 (1/17))#
Publisher: Nationwide Life and Annuity Insurance Company (Nationwide-operated marketing asset host
s3.amazonaws.com/nh3)Doc type: consumer strategy brochure (6 pages)
URL fetched: https://s3.amazonaws.com/nh3/FAM-0475AO.2_Strategy_Brochure.pdf
Retrieved: YES (full PDF text-extracted locally)
Note carried over: a 2017-vintage document retained because it documents a structurally different FIA design (the Balanced Allocation Strategy / Balanced Allocation Value) that is worth modeling as a variation. Current New Heights Select rates were not retrieved (see S-f4); the design is described qualitatively only, with no numeric parameters.
Documents attempted but NOT retrieved (no content asserted from these)#
ID |
Document |
URL |
Failure |
|---|---|---|---|
S-f1 |
Athene Ascent Pro 10 “Rates and Availability” |
https://athenecentral.widen.net/s/lhw7bjvvzz/65219 |
Widen viewer / password-protected PDF; no text |
S-f3 |
American Equity IncomeShield 10 brochure (official) |
https://media.american-equity.com/Documents/1164-SB-10.pdf |
DNS resolution failure ( |
S-f4 |
Nationwide New Heights Select 10 product brochure |
https://nationwidefinancial.com/media/pdf/FAM-1606AO.pdf |
HTTP 403 |
These three are cited in product-spec.md and technical-notes.md only as the reason certain
declared-rate parameters are stale or absent.
Regulatory and actuarial references [R#] (product research file numbering)#
R1. American Academy of Actuaries, Life Experience Committee — “Fixed Indexed Annuities—Product Mechanics and Risk Management” (February 2026)#
Publisher: American Academy of Actuaries
URL fetched: https://actuary.org/wp-content/uploads/2026/02/life-FIA-policypaper.pdf
Retrieved: YES (31-page PDF text-extracted locally)
Status disclaimer carried over: not an ASOP, not binding, “a list of considerations and resources.”
Same document as REG-R68 in the cross-product library.
R2. NAIC — “Standard Nonforfeiture Law for Individual Deferred Annuities” (Model #805), 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 (5-page PDF text-extracted locally)
Same document as REG-R42.
R3. NAIC — “Annuity Nonforfeiture Model Regulation” (Model #806), October 2007 edition#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/sites/default/files/model-law-806.pdf
Retrieved: YES (12-page PDF text-extracted locally)
No counterpart entry exists in the cross-product library; cite R3 for the §7 substantive- participation option-cost test.
R4. NAIC — “Suitability in Annuity Transactions Model Regulation” (Model #275), Spring 2020 edition#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/sites/default/files/model-law-275.pdf
Retrieved: YES (20-page PDF; sections 1–5 text-extracted locally)
Same document as REG-R46.
R5. NAIC — “Variable Annuity Model Regulation” (Model #250), October 2007 edition#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/sites/default/files/model-law-250.pdf
Retrieved: YES (13-page PDF; sections 1–3 text-extracted locally)
Cited only for the correction carried into
product-spec.md: #250 is the Variable Annuity Model Regulation and does not reach general-account FIAs; the Annuity Disclosure Model Regulation is #245. Same document as REG-R43.
R6. Actuarial Standards Board — ASOP No. 2, “Nonguaranteed Elements for Life Insurance and Annuity Products” (Doc. No. 204)#
Publisher: Actuarial Standards Board
URL fetched: http://www.actuarialstandardsboard.org/wp-content/uploads/2021/12/asop002_204-2.pdf
Retrieved: YES (33-page PDF; front matter and sections 1–3.4 text-extracted locally)
Same standard as REG-R26.
R7. NAIC — Valuation Manual (VM)-22 (A) Subgroup#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/committees/a/valuation-manual-22-sg
Retrieved: YES (HTML page)
R8. Society of Actuaries Research Institute / LIMRA — “2019-20 Fixed Indexed Annuity Contract Owner Behavior Study” (announcement page)#
Publisher: Society of Actuaries Research Institute (joint with LIMRA)
URL fetched: https://www.soa.org/resources/announcements/press-releases/2023/fixed-indexed-annuity/
Retrieved: YES (HTML page). The report PDF at https://www.soa.org/4a3268/globalassets/assets/files/resources/experience-studies/2023/19-20-fia-contract-owner.pdf returned HTTP 404 and was not retrieved.
Role in this library: the retrieved source for the 10%-with-GLWB versus 33%-without shock-lapse contrast, the 37% versus <30% withdrawal-incidence contrast, and the subsequent-premium rates. Related landing pages are catalogued as REG-R62, where the same shock-lapse figures are tagged unverified.
R9. Society of Actuaries Research Institute / LIMRA — “2023 Fixed Indexed Annuity Contract Owner Behavior Experience Study” (study landing page, 2025)#
Publisher: Society of Actuaries Research Institute
URL fetched: https://www.soa.org/resources/experience-studies/2025/2023-fixed-index-annuity/
Retrieved: YES (HTML page). Detailed results are behind a paid Experience Studies Pro subscription and were not retrieved; the report PDF is listed at https://www.soa.org/globalassets/assets/files/research/exp-study/2025/2023-fixed-indexed-anuity-study.pdf (not fetched).
Cited for study scope only.
R10. SEC — Final Rule, “Indexed Annuities,” Release No. 33-9152 (removal of Rule 151A)#
Publisher: U.S. Securities and Exchange Commission
URLs attempted:
https://www.sec.gov/files/rules/final/2010/33-9152.pdf → HTTP 403 (not retrieved)
https://www.federalregister.gov/documents/2010/10/20/2010-26347/indexed-annuities → 302 redirect to an interstitial host (not retrieved)
Retrieved: NO
Everything cited to R10 is tagged unverified: the American Equity Investment Life Insurance Co. v. SEC vacatur and the specific conditions of Dodd-Frank §989J. What is verified is Model #275’s own drafting note R4 and the not-a-security statements in S6 S9 S10.
R11. NAIC Actuarial Guidelines XXXIII and XXXV (AG 33, AG 35)#
Retrieved: NO — the guidelines live in the NAIC Accounting Practices & Procedures Manual, which is not freely served in text form; no primary copy was successfully fetched.
Everything this library says about AG 33 / AG 35 derives from R1 (the Academy FIA paper), a secondary but authoritative professional source, and is tagged accordingly. The “Type 1” / “Type 2” naming is unverified. Titles and continued incorporation into the Valuation Manual are independently verifiable via REG-R41; the authoritative text sits in REG-R33.
Superseded in fact on 2026-08-06, and this product’s documents say so at the point of use. The AP&P Manual’s As of March 2026 edition is a free download and was retrieved in full; AG 33 was read in full at REG-R151 and AG 35 at REG-R152, so their mechanics are no longer second-hand and no longer unverified. Two specific corrections follow from that reading: “Type 1” and “Type 2” are the guideline’s own printed section headings, not shorthand, so the unverified flag on the naming is closed; and AG 35 does not free-standingly require asset adequacy testing — it directs testing “to the extent required by law, regulation, or regulatory requirements”, so the claim previously carried on R1 is corrected rather than confirmed. The entry above is preserved verbatim because it correctly records the state of the research file, which governs. What R11 disclaimed and the reading did not supply: AG IX-B, named three times by AG 35 as an alternative valuation-rate source, and the NAIC Interest-Indexed Annuity Contracts Model Regulation whose Sections 5 and 6 AG 35 supersedes — neither is in this library.
Cross-product regulatory references [REG-R#]#
Cited with the [REG-R#] prefix to avoid collision with the product research file’s own
R-numbering. The curated page these resolve to is
references/regulatory-and-actuarial-references.md. That page carries one shared numbering
space, now running R1–R157, with most of the R73–R149 block unused: entries
R1–R34 originate in _research/regulatory-actuarial.md (the life bibliography, several
entries of which also bind annuity models), entries R35–R72 in
_research/regulatory-actuarial-annuities.md (the annuity extension), R150 in the NAIC
principle-based-reserving topic page, and entries R151–R157 in the five AP&P Manual extractions
read on 2026-08-06 (_research/appp-ag33.md, _research/appp-ag35.md,
_research/appp-a820-a821-a822.md, _research/appp-a830.md,
_research/appp-a585-a250-a255-a270.md). The gaps are not losses
and must not be back-filled — the block convention lets a stream finish with spare numbers so a
later pass can extend it without renumbering anything already cited. Retrieval markers below are
those recorded in the originating research file.
Tag |
Short title |
Research file |
Retrieval status per that file |
|---|---|---|---|
REG-R1 |
Standard Valuation Law (Model #820) |
life (R1–R34) |
see the reference page’s per-entry marker |
REG-R2 |
Standard Nonforfeiture Law for Life Insurance (Model #808) |
life |
see the reference page; cited here only to prevent mis-application to annuities |
REG-R3 |
NAIC Valuation Manual, Jan. 1, 2026 edition |
life |
fetched |
REG-R8 |
Actuarial Guideline XLIX (AG 49) — IUL illustrations under Model #582 |
life |
see the reference page (no standalone official text located) |
REG-R10 |
Actuarial Guideline XLIX-A (AG 49-A, incl. the 2023 “AG 49-B” revisions) — IUL illustrations |
life |
fetched |
REG-R16 |
26 U.S.C. §807 — tax reserves |
life |
fetched |
REG-R26 |
ASOP No. 2 — Nonguaranteed Elements (same standard as R6) |
life |
fetched |
REG-R27 |
ASOP No. 7 — Life or Health Cash Flow Analysis |
life |
fetched |
REG-R29 |
ASOP No. 22 — Opinions based on asset adequacy analysis |
life |
see the reference page |
REG-R32 |
ASOP No. 56 — Modeling |
life |
fetched |
REG-R33 |
NAIC AP&P Manual (home of AG 33 / AG 35, Appendix C) |
life |
see the reference page (paid publication) |
REG-R34 |
FASB ASU 2018-12 (LDTI) — market risk benefits |
life |
see the reference page |
REG-R36 |
VM-22 — PBR for non-variable annuities (2026 edition) |
annuities (R35–R72) |
yes (local text extraction) |
REG-R37 |
VM-V Section 1 — income annuity maximum valuation interest rates |
annuities |
yes (local text extraction) |
REG-R39 |
Actuarial Guideline XXXIII (AG 33) |
annuities |
no (title verified via REG-R41) |
REG-R40 |
Actuarial Guideline XXXV (AG 35) |
annuities |
no (title verified via REG-R41) |
REG-R41 |
VM-C — index of actuarial guidelines incorporated |
annuities |
yes (local text extraction) |
REG-R42 |
Model #805 nonforfeiture (same document as R2) |
annuities |
yes (local text extraction) |
REG-R43 |
Model #250 Variable Annuity Model Reg (same document as R5) |
annuities |
yes (local text extraction) |
REG-R45 |
Model #245 Annuity Disclosure Model Regulation |
annuities |
yes (local text extraction) |
REG-R46 |
Model #275 Suitability (same document as R4) |
annuities |
yes (local text extraction) |
REG-R49 |
SEC Release 33-11294 — RILA registration, Form N-4 |
annuities |
yes (govinfo); sec.gov PDF 403 |
REG-R53 |
CRS Report R40656 — Rule 151A and Dodd-Frank §989J |
annuities |
yes |
REG-R55 |
26 U.S.C. §72 — annuity taxation |
annuities |
yes |
REG-R56 |
26 U.S.C. §1035 — exchanges |
annuities |
yes |
REG-R57 |
26 C.F.R. §1.401(a)(9)-6 — RMDs for annuity contracts / QLACs |
annuities |
yes |
REG-R58 |
T.D. 10001 — RMD final regulations (2024) |
annuities |
yes (govinfo) |
REG-R59 |
Model #821 + VM-M — 2012 IAM / 2012 IAR, Scale G2 |
annuities |
yes (local text extraction, both) |
REG-R60 |
2012 IAR development report (AAA/SOA) |
annuities |
yes (local text extraction) |
REG-R61 |
2020–2024 Individual Payout Annuity Mortality Experience Study |
annuities |
yes (landing page) |
REG-R62 |
FIA policyholder behavior studies 2021–22 and 2019–20 |
annuities |
yes (both landing pages); the shock-lapse figures are unverified there |
REG-R63 |
Fixed rate deferred surrender studies (2023–24, 2015–2022) |
annuities |
partial (via the REG-R65 index) |
REG-R64 |
VA contract holder behavior / GLB utilization studies |
annuities |
yes (2022–24 landing page); utilization figures unverified |
REG-R65 |
SOA Individual Annuity Experience Studies — index |
annuities |
yes |
REG-R67 |
AAA — Utilization Assumptions of Guaranteed Living Benefits (May 2024) |
annuities |
yes (local text extraction) |
REG-R68 |
AAA — Fixed Indexed Annuities: Product Mechanics and Risk Management (same paper as R1) |
annuities |
yes (local text extraction) |
REG-R70 |
ASOP No. 54 — Pricing of Life Insurance and Annuity Products |
annuities |
yes |
REG-R71 |
ASOP No. 10 — U.S. GAAP for Long-Duration Products (Doc. No. 207) |
annuities |
yes (local text extraction) |
Four rows in that table are now superseded in fact, and are kept because they record what the originating research files said. REG-R33 (“paid publication”) is superseded by the free retrieval of the As of March 2026 AP&P Manual; REG-R39 and REG-R40 (“no — title verified via REG-R41”) are superseded by the first-hand reads at REG-R151 and REG-R152; and the A-820 half of REG-R110’s limit is superseded by REG-R153. The retrieval-status column is left unaltered in each case: it states the status per the originating research file, which is still an accurate statement about that file. Nothing is renumbered, and no frozen entry is rewritten.
R110. VM-A: Appendix A — Requirements (Valuation Manual, Jan. 1, 2026 Edition)#
Publisher: NAIC
URL: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf (pages A-1 to A-2; same document as REG-R3)
Accessed: 2026-08-04 · Fetched: yes (local text extraction; the complete two-page index read)
Limit carried forward: VM-A is an index, not a text. The requirements it indexes — above all A-820 (minimum life and annuity reserve standards) and A-830 (valuation of life insurance policies) — live in AP&P Appendix A and were not retrieved.
AP&P Manual appendix items read at first hand (R151–R157), added 2026-08-06#
Seven appendix items were read in full from the free As of March 2026 AP&P Manual download on
2026-08-06 and given ids R151–R157 in the shared numbering — R151 AG 33, R152 AG 35, R153
A-820 with A-821 and A-822, R154 A-830, R155 A-585, R156 A-250, R157 A-255. Only the four this
product’s documents cite are reproduced below. R154 (A-830, life insurance valuation), R155
(A-585, universal life) and R156 (A-250, variable annuities) are not cited here and are therefore
not repeated, on the same rule that omits uncited entries elsewhere in this file. Id, title,
publisher, URL, access date, fetched marker and every carried-forward limit below are reproduced
from references/regulatory-and-actuarial-references.md, which in turn carries them
from the extractions in
_research/appp-ag33.md, _research/appp-ag35.md, _research/appp-a820-a821-a822.md and
_research/appp-a585-a250-a255-a270.md. Ids are never renumbered. A fifth item read in that
pass, A-270 (variable life), was given no reference id, so nothing anywhere in this library
is cited from it.
Access date for every entry in this subsection: 2026-08-06.
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 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”) and the AG 33 half of the local R11 entry, both of which are frozen and preserved unaltered above.
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 isSP% = (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 (REG-R41). Text-layer artefacts noted at the point of use: a lost superscript in the Attachment 2 option-replicationSP%formula, and irregular intra-word spacing throughout.Supersedes in fact: R40 (“guideline text not retrieved”) and the AG 35 half of the local R11 entry, both frozen and preserved unaltered above.
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 itsAA_xfactors, 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 lostR1/R2subscripts, 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 — A-820’s own header does not list Model #820 while A-822’s does.Supersedes in fact: the A-820 half of REG-R110’s limit (“A-820 and A-830 as printed in the AP&P Manual were not retrieved”). R110 is frozen and is preserved unaltered above.
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.
Why this product cites it: for the verified negative that A-255 does not reach a general-account FIA. Its ¶1 definition requires the underlying assets to be held in a separate account throughout the period the holder can surrender; this composite has no separate account.
Provenance note#
Extraction details live in _research/fixed-indexed-annuity.md: that file records which facts
came from which source, including every unverified flag, the failed fetches (S-f1 through S-f4,
R10, R11), the mirror-hosting caveat for S1, S2 and S5 (fetched from authorized-distributor
mirrors carrying the insurers’ own form numbers), the retrieval method note (several publisher
PDFs were downloaded and text-extracted locally with pypdf, and nothing is asserted from a
document marked Retrieved: NO), and the vintage caveat that all declared rates are non-guaranteed
elements captured only as of the dates stamped on their documents. The cross-product
bibliographies _research/regulatory-actuarial.md (R1–R34),
_research/regulatory-actuarial-annuities.md (R35–R72) and the five AP&P Manual extractions
_research/appp-ag33.md, _research/appp-ag35.md, _research/appp-a820-a821-a822.md,
_research/appp-a830.md and _research/appp-a585-a250-a255-a270.md (R151–R157) play the same
role for [REG-R#] tags,
and references/regulatory-and-actuarial-references.md is the curated page those tags resolve
to; where this file and a research file disagree, the research file governs. Standardizations
marked std in product-spec.md and technical-notes.md are introduced at drafting and are
not attributable to any source. unverified flags are carried forward unchanged with one
documented exception: the AG 33 and AG 35 mechanics, whose flags were closed on 2026-08-06 by
reading the primary texts REG-R151 REG-R152 — the only route by which a flag may be closed. No
std marker in this product’s documents was a standardization because one of the seven
appendix items was unavailable, so none was upgraded; the AP&P print of the 2012 IAM Period
Table was added at “Age basis” as corroboration REG-R153 and the std there, which marks the
model’s choice of a single age basis, stands.