Sources#

Source ids, titles, publishers, URLs, access dates, and fetched/not-fetched markers are carried over verbatim from _research/registered-index-linked-annuity.md (the citation ground truth for [S#]/[R#] tags). Ids are never renumbered. Sources from the research file that are not cited in product-spec.md or technical-notes.md are omitted — none were dropped: all of S1–S6 and R1–R6 are cited. No new source was fetched at drafting; the only entries added afterwards are the AP&P Manual appendix items R151–R157, read on 2026-08-06 and listed in their own block at the end of the [REG-R#] section.

Access date for all citations: 2026-08-04 (cross-product entries R1–R34 carry their own access date of 2026-08-03, and the AP&P appendix entries R151–R157 carry 2026-08-06 — see the [REG-R#] section).

Primary product sources [S#]#

S1. Brighthouse Life Insurance Company of NY — “Brighthouse Shield Level Select 6-Year Annuity”, Form S-3 registration statement#

Publisher: Brighthouse Life Insurance Company of NY (“BLNY”), CIK 0001167609
Doc type: Securities Act registration statement / statutory prospectus (Form S-3, the pre-2024 RILA registration form). Filed 2019-02-06, accession 0001193125-19-030795.
URL fetched: https://www.sec.gov/Archives/edgar/data/1167609/000119312519030795/d695141ds3.htm
Retrieved: YES (full document downloaded and read; note sec.gov rejects generic fetchers with HTTP 403 — a declared User-Agent is required)
Product: Brighthouse Shield Level Select 6-Year Annuity — “an individual single premium deferred index-linked separate account annuity contract”. New York version only. Separate Account: Brighthouse Separate Account SA II.
Role in this library: documents the older, pro-rata “accrued rate” interim value design, retained as the legacy contrast module and first implementation target; also the source for issue rules, free-withdrawal and withdrawal-charge mechanics, the return-of-premium death benefit, the Transfer Period, and the Cap/Step crediting worked examples.

S2. Brighthouse Life Insurance Company — “Brighthouse Shield Level II 6-Year Annuity”, Rule 424(b)(3) prospectus#

Publisher: Brighthouse Life Insurance Company (“BLIC”), CIK 0000733076
Doc type: statutory prospectus filed under Rule 424(b)(3), filed 2024-07-26, accession 0001193125-24-180915
URL fetched: https://www.sec.gov/Archives/edgar/data/733076/000119312524180915/d747348d424b3.htm
Retrieved: YES (full document downloaded and read)
Product: Brighthouse Shield Level II 6-Year Annuity — individual single premium deferred index-linked separate account annuity contract.
Role in this library: the mechanics anchor. Appendix F “Interim Value of Shield Options” carries the complete Fixed Income Asset Proxy / Derivative Asset Proxy algebra, the per-crediting-type replicating option portfolios, and the worked proportional Investment Amount reduction on withdrawal.

S3. Pruco Life Insurance Company — “PRUDENTIAL FlexGuard — Flexible Premium Deferred Index-Linked and Variable Annuity (‘B Series’)”, prospectus supplement#

Publisher: Pruco Life Insurance Company (Prudential)
Doc type: prospectus supplement dated September 14, 2022 to the prospectus dated August 15, 2022, containing full amended-and-restated text of the index-strategy sections, the Interim Value discussion, and Appendix B (57 pages)
URL fetched: https://www.prudential.com/content/dam/us/sites/pru-com/pru/opt2/annuities/annuity-prospectuses/S3-flex-guard-prosp-B-plaz.pdf
Retrieved: YES (full PDF text extracted and read)
Product: Prudential FlexGuard indexed variable annuity, B Series — a combination contract offering index strategies alongside variable investment subaccounts.
Caveat carried over: this is a 2022 supplement, not the current prospectus. Numbers are as of that document; do not treat as current pricing. FlexGuard has since been re-registered on Form N-4 under the 2024 rule R1, so strategy menus, buffers and rates will have changed.

S4. Equitable Financial Life Insurance Company — “Structured Capital Strategies PLUS 26”, Form N-4 registration statement#

Publisher: Equitable Financial Life Insurance Company, CIK 0002039145 (a parallel, essentially identical filing exists for Equitable Financial Life Insurance Company of America, CIK 0002038891)
Doc type: Form N-4 registration statement (the post-2024 RILA form), filed 2026-06-18, accession 0001193125-26-275133
URL fetched: https://www.sec.gov/Archives/edgar/data/2039145/000119312526275133/d59590dn4.htm
Retrieved: YES (full document downloaded and read)
Product: Structured Capital Strategies PLUS (SCS PLUS 26) — index-linked annuity with a Structured Investment Option (SIO) of “Segments” plus a Guaranteed Interest Option (GIO). Non-unitized Separate Account No. 68 (NY) / 68A and 68E (AZ).
Role in this library: the richest segment-type menu publicly documented (Standard, Annual Lock, Step Up, Dual Direction, Dual Step Up, Optimal Mix) with the exact Segment Rate of Return decision table for each, and the most detailed Segment Interim Value description including the Cap Calculation Factor and the implied-volatility interpolation procedure.

S5. Allianz Life Insurance Company of North America / Allianz Life Variable Account B — “Allianz Index Advantage+ Select Income Annuity”, Form N-4 initial registration statement#

Publisher: Allianz Life Insurance Company of North America (CIK 0000072499) / Allianz Life Variable Account B (CIK 0000836346)
Doc type: Form N-4 initial registration statement, filed 2025-07-22, accession 0000836346-25-000047
URL fetched: https://www.sec.gov/Archives/edgar/data/836346/000083634625000047/iaplusselectincomn4july2025.htm
Retrieved: YES (full document downloaded and read)
Product: Allianz Index Advantage+ Select Income Annuity.
Role in this library: the structurally different presentation — a “Daily Adjustment” applied to an “Index Option Base” rather than a self-contained interim value — and the only retrieved source offering both buffer and floor crediting side by side (Index Guard Strategy = −10% Floor). Appendix C gives the Proxy Value formula for each of six crediting methods.
Caveat carried over: this is an initial N-4 filing; several fee-table cells are marked “[To be updated by amendment]” and the prospectus date is “[December XX, 2025]”. Fee figures from this document are preliminary and should be re-verified against the effective prospectus.

Failed / blocked retrievals (carried over; not sources, and nothing is cited from them)#

Brighthouse “Understanding Interim Value” educational PDF — https://www.brighthousefinancial.com/content/dam/brighthouse-financial/public/pdfs/shield/Shield-Interim-Value-Educational-Resource.pdf — HTTP 403. fetched_ok = false.
Brighthouse Shield current rate page — https://www.brighthousefinancial.com/products/annuities/shield-annuities/shield-rates/ — HTTP 403. fetched_ok = false. No current declared cap/step/edge rates captured — this is why every declared-rate value in product-spec.md is std.
Equitable performance cap rate page — https://equitable.com/annuities/variable-annuities/performance-cap-rates — request rejected by WAF. fetched_ok = false.
Federal Register HTML of the RILA adopting release — redirects off-host to unblock.federalregister.gov. fetched_ok = false; the SEC PDF (R1) was used instead and is authoritative.

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

These are the local R-numbers used inside _research/registered-index-linked-annuity.md. They are independent of the shared [REG-R#] space; several documents appear in both (noted per entry).

R1. U.S. Securities and Exchange Commission — Final rule, “Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities; Amendments to Form N-4 …; Other Technical Amendments”#

Publisher: SEC
Release Nos. 33-11294; 34-100450; IC-35273; File No. S7-16-23; RIN 3235-AN30. 17 CFR Parts 230, 232, 239, 274. 467 pages (conformed to Federal Register version).
URL fetched: https://www.sec.gov/files/rules/final/2024/33-11294.pdf
Retrieved: YES (full PDF; introduction and effective/compliance-date sections read in detail)
Cross-reference: the same rulemaking is catalogued at REG-R49, which was fetched via govinfo.gov (89 Fed. Reg. 59978) because sec.gov returned HTTP 403 there, and which flags the May 1, 2026 compliance date as unverified (section II.J not read). Both documents in this directory carry that unverified flag.

R2. NAIC — Actuarial Guideline LIV, “Nonforfeiture Requirements for Index-Linked Variable Annuity Products” (AG 54)#

Publisher: National Association of Insurance Commissioners
Doc type: adopted actuarial guideline plus project history (6 pages)
URL fetched: https://content.naic.org/sites/default/files/committees-pending-action-actuarial-guideline-liv-230224.pdf
Retrieved: YES (full text read)
Adoption trail printed on the document: adopted by Life Actuarial (A) Task Force 12/11/2022; adopted by Life Insurance and Annuities (A) Committee 2/24/2023. NAIC Executive (EX) Committee and Plenary adoption is unverified — not stamped on the retrieved document. The July 1, 2024 effective date is stated in the retrieved text.
Cross-reference: the same guideline is REG-R44.

R3. NAIC — Valuation Manual, Jan. 1, 2026 edition, VM-21 “Requirements for Principle-Based Reserves for Variable Annuities”#

Publisher: NAIC
URL fetched: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf
Retrieved: YES (457 pages; VM-21 Sections 1 and 2 read in detail)
Cross-reference: REG-R35 (VM-21 as a section) and REG-R3 (the parent Valuation Manual).

R4. NAIC — Model #250, “Variable Annuity Model Regulation”#

Publisher: NAIC (October 2007 edition of the NAIC Model Laws compilation)
URL fetched: https://content.naic.org/sites/default/files/model-law-250.pdf
Retrieved: YES (13 pages; Sections 2, 3 and 7 read)
Cross-reference: REG-R43. Note the model-number correction recorded there and in product-spec.md: #250 is the Variable Annuity Model Regulation; the Annuity Disclosure Model Regulation is #245 (REG-R45).

R5. 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 pages; Sections 1 and 2 read)
Note carried over: the title has changed from the older “Nonguaranteed Charges or Benefits for Life Insurance Policies and Annuity Contracts”.
Cross-reference: REG-R26.

R6. American Academy of Actuaries — “Index-Linked Variable Annuity (ILVA) / Registered Index-Linked Annuity (RILA)” policy paper#

Publisher: American Academy of Actuaries, Life Practice Council
Doc type: policy paper, 26 pages, dated December 2025 (file name Life-PolicyPaper120225.pdf)
URL fetched: https://actuary.org/wp-content/uploads/2025/12/Life-PolicyPaper120225.pdf
Retrieved: YES (full PDF text extracted and read)
Role in this library: the fully worked numeric hypothetical-portfolio interim value example (6-year, 10% buffer, Black-Scholes inputs disclosed), the survey of common ILVA product features used to calibrate the composite, and the open-source Excel Lambda library reproducing the AG 54 calculation.
Cross-reference: REG-R69.
Caveat carried over: the Interstate Compact standard IIPRC-03-I-ILVA is quoted only second-hand through this paper; the Compact standard itself was not retrieved unverified.

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

[REG-R#] tags resolve against the single shared numbering space, which now runs R1–R157, curated at references/regulatory-and-actuarial-references.md, with most of the R73–R149 block unused. The gaps are not losses and must not be back-filled. Ids are never renumbered. It is one space in three blocks:

R1–R34 — life-origin entries, several of which also bind annuity models. Research provenance: _research/regulatory-actuarial.md. Access date 2026-08-03.
R35–R72 — annuity-specific entries. Research provenance: _research/regulatory-actuarial-annuities.md, which also carries the table of which R1–R34 entries bind annuity models. Access date 2026-08-04.
R151–R157 — the seven AP&P Manual appendix items read at first hand on 2026-08-06, after this directory was drafted. Research provenance: _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; the per-entry bibliography is references/regulatory-and-actuarial-references.md. Five of the seven are cited here and are listed in their own block below. Access date 2026-08-06.

Entries cited by the two documents in this directory:

Tag	Half	Short title	Retrieval status (per the research files)
REG-R15	R1–R34	26 U.S.C. §817 (esp. §817(h) diversification)	fetched
REG-R16	R1–R34	26 U.S.C. §807 — tax reserves	fetched
REG-R26	R1–R34	ASOP No. 2 — Nonguaranteed Elements (same standard as R5 above)	fetched
REG-R27	R1–R34	ASOP No. 7 — Life or Health Cash Flow Analysis (rev. Dec 2025)	fetched
REG-R29	R1–R34	ASOP No. 22 — Opinions based on asset adequacy analysis	fetched
REG-R31	R1–R34	ASOP No. 52 — PBR for Life Products under the Valuation Manual	fetched (cited only to record that it does not cover VM-21/VM-22)
REG-R32	R1–R34	ASOP No. 56 — Modeling	fetched
REG-R34	R1–R34	FASB ASU 2018-12 (LDTI; market risk benefits)	fasb.org blocked (HTTP 403); annotated from an accessible third-party full text
REG-R35	R35–R72	VM-21, Valuation Manual Jan. 1, 2026 ed. (same document as R3 above)	yes (local text extraction; §§1–3 and TOC read)
REG-R38	R35–R72	Actuarial Guideline XLIII (AG 43), VAIWG redline	yes (local text extraction)
REG-R42	R35–R72	Standard Nonforfeiture Law for Individual Deferred Annuities (Model #805)	yes (local text extraction; §§1–8 read in full)
REG-R43	R35–R72	Variable Annuity Model Regulation (Model #250) (same document as R4 above)	yes (local text extraction; TOC and §7 read)
REG-R44	R35–R72	Actuarial Guideline LIV (AG 54) (same document as R2 above)	yes (local text extraction; complete guideline read)
REG-R45	R35–R72	Annuity Disclosure Model Regulation (Model #245)	yes (local text extraction; §§1 and 3 read)
REG-R46	R35–R72	Suitability in Annuity Transactions Model Regulation (Model #275)	yes (local text extraction; TOC and §1 read)
REG-R47	R35–R72	C-3 RBC Instructions and Appendices (C-3 Phase II)	yes (local text extraction)
REG-R48	R35–R72	Oliver Wyman QIS II public report and executive summary (VA framework reform)	yes, both (local text extraction)
REG-R49	R35–R72	SEC Release 33-11294 — RILA registration / Form N-4 (same rulemaking as R1 above)	yes, via govinfo.gov (89 Fed. Reg. 59978); sec.gov PDF returned HTTP 403 there; compliance date May 1, 2026 flagged unverified
REG-R49b	R35–R72	GAO rule report B-336553 (corroborates R49 publication metadata)	yes
REG-R51	R35–R72	17 C.F.R. §230.498A — summary prospectuses, extended to registered non-variable annuities	yes
REG-R52	R35–R72	SEC Form N-4	no — sec.gov returned HTTP 403; content described only through the adopting releases
REG-R53	R35–R72	CRS Report R40656 — SEC Rule 151A and annuities (why FIAs are not registered)	yes
REG-R54	R35–R72	FINRA Rule 2330 — deferred variable annuities	yes; unverified whether FINRA applies it to RILAs specifically
REG-R55	R35–R72	26 U.S.C. §72 — Annuities	yes
REG-R56	R35–R72	26 U.S.C. §1035 — exchanges	yes
REG-R58	R35–R72	T.D. 10001 — RMD final regulations (2024)	yes, via govinfo.gov
REG-R59	R35–R72	Model #821 + VM-M annuity mortality definitions (2012 IAM / IAR, Scale G2)	yes, both (local text extraction)
REG-R60	R35–R72	2012 Individual Annuity Reserving Table — Academy/SOA Payout Annuity Table Team report (source of the 10% margin loaded into the Period / IAR table)	yes (local text extraction; margin/loading sections read)
REG-R61	R35–R72	2020–2024 Individual Payout Annuity Mortality Experience Study	yes (landing page; full report PDF and paid data package not retrieved)
REG-R62	R35–R72	FIA policyholder behavior experience studies (2021–22, 2019–20)	yes (both landing pages); the ~10%/~33% shock-lapse split is unverified
REG-R63	R35–R72	Fixed rate deferred surrender experience studies (2023–24, 2015–22)	partial (verified via the SOA index R65); the ~52%/~56% figures are unverified
REG-R64	R35–R72	VA / RILA contract holder behavior and GLB utilization studies (2022–24)	yes (2022–24 landing page); detailed tables behind a paid data package
REG-R65	R35–R72	SOA Individual Annuity Experience Studies — index	yes (complete list read)
REG-R66	R35–R72	AAA VM-21 practice note supplement (Feb 2022)	yes (local text extraction)
REG-R69	R35–R72	AAA ILVA / RILA policy paper (same document as R6 above; listed as the cross-reference for R6, which is the tag actually used in the two documents)	yes (local text extraction)
REG-R70	R35–R72	ASOP No. 54 — Pricing of Life Insurance and Annuity Products	yes
REG-R71	R35–R72	ASOP No. 10 — U.S. GAAP for Long-Duration Life, Annuity, and Health Products (Doc. No. 207)	yes (local text extraction)

Frozen entries not previously cited here#

Id, title, publisher, URL, access date and fetched marker are carried from references/regulatory-and-actuarial-references.md, together with the retrieval limits and unverified flags that bear on how the entry may be used. Ids are never renumbered. No new source was fetched at drafting.

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).

R39. Actuarial Guideline XXXIII — Determining CARVM Reserves for Annuity Contracts With Elective Benefits (AG 33) — Publisher: NAIC · URL: none — no free official standalone text was located; title and current status verified from the Valuation Manual’s VM-C index (page C-1); the authoritative text is in the AP&P Manual Appendix C · Accessed: 2026-08-04 (search date; guideline text not retrieved) · Fetched: no. AG 33 mechanics are quoted nowhere in this library.

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); 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.

R39 and R40 are retained although neither document in this directory cites them any longer. They are the “AG 33 / AG 35 text not retrieved” records, superseded in fact by R151 and R152 in the AP&P appendix block below. Their wording is frozen and is not edited: a superseded record is evidence, not clutter — the same treatment R33 received when R73 superseded it. Read them as history, never as a live limit.

R110. VM-A: Appendix A — Requirements (Valuation Manual, Jan. 1, 2026 Edition) — Publisher: NAIC · URL: same document as R3, pages A-1 to A-2 · 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 — including A-250 (variable annuities) and A-255 (modified guaranteed annuities), and above all A-820 and A-830 — live in AP&P Appendix A and were not retrieved.

R110’s limit is frozen and is superseded in fact for three of the items it names. A-820, A-250 and A-255 have since been read in full and carry their own ids — R153, R156 and R157 in the AP&P appendix block below. R110 remains the authority for the VM-A index itself and for the items still unread; its “were not retrieved” wording is preserved unaltered and must not be read as current for A-820, A-250 or A-255.

AP&P Manual appendix entries (R151–R157), read 2026-08-06#

Added after drafting — the only entries in this file that were. All 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 (catalogue entry “APPM-2026 … Free Download” on https://content.naic.org/publications; file https://content.naic.org/sites/default/files/publication-app-manual.pdf). They take appendix-level ids rather than being folded into R73 so a document can cite A-820 ¶15 or AG 33 Text 4 instead of a 2,117-page manual. Each was read by local text extraction from that download. Id, title, publisher, URL, access date, fetched marker and every retrieval limit below are carried from references/regulatory-and-actuarial-references.md. Ids are never renumbered. Only the five cited by the two documents in this directory are listed: R154 (A-830, valuation of life insurance policies) and R155 (A-585, universal life) are life-side items neither document cites.

Edition line, stated once for all five. 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 for any of these instruments and must never be cited as one. The “As of March 2026” designation is the manual’s own front matter, recorded at R73.

Licence caution, inherited from R73 and applying to all five. Personal and non-commercial use; redistribution or integration “into any software or other publication” requires written NAIC permission. Both documents in this directory paraphrase the mechanics and cite the paragraph, section or page, and quote only short anchors.

A-270 (Variable Life Insurance) was extracted alongside R155 at printed pages A270-1 to A270-3 = PDF pages 1097–1099, but the extraction assigned it no reference id. Nothing in this directory is cited from it and it must not be given one here; any reference to it stays descriptive.

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, so the AG 33 / AG 43 / VM-21 precedence reading in technical-notes.md is the library’s inference. It never cites SVL §5a by number: the mapping to §5a is the library’s own, made on content. 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 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 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. Product-specific limit, and it is why this entry matters here: AG 35 says nothing about separate accounts, registered products, index-linked variable annuities, buffers, floors or AG 54, and is recorded as neither including nor excluding RILA. Supersedes in fact: R40 (“guideline text not retrieved”), 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 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. Cited here only for ¶15 (the CARVM print) and ¶¶7–10 (the valuation-rate machinery SSAP No. 56 ¶30 points at). Supersedes in fact: the A-820 half of R110’s limit.

R156. Appendix A-250 — Variable 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 A250-1 = PDF page 1095; same physical document as R73 · Accessed: 2026-08-06 · Fetched: yes (local text extraction; the whole item read in full — three paragraphs, seven printed lines of substance). Limit, and it is the point of the entry: A-250 is a pointer, not a reserve method. It gives a definition, a separate-account asset-coverage requirement, and a delegation of the reserve itself to Appendix A-820 “in accordance with actuarial procedures that recognize the variable nature of the benefits provided and any mortality guarantees”. It contains no formula, no symbol, no factor, no table, no CARVM adaptation, no elective-benefit path rule, no interim-value rule and not the word CARVM, and prints no effective date. It is cited by technical-notes.md for that verified negative finding as much as for anything it supplies. Supersedes in fact: the A-250 half of R110’s limit.

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. Its ¶1 definition is separately load-bearing for this product as the test VM-21 §2.A.2 uses to disapply VM-21 to contracts falling under VM-A item A-255 REG-R35; that exclusion is VM-21’s text, not A-255’s, and A-255 supplies only the definition. Supersedes in fact: the A-255 half of R110’s limit.

Corrections carried forward from the research files and made explicit in product-spec.md, rather than repeating the common misstatements:

Model #805’s indexed nonforfeiture rate floor is 15 basis points (0.15%), not 1% — the rate is the lesser of 3% and the five-year CMT (rounded to the nearest 1/20 of one percent) reduced by 125 basis points, subject to that 15 bp floor REG-R42.
The Annuity Disclosure Model Regulation is #245, not #250 — #250 is the Variable Annuity Model Regulation, verified from both model-law prints and from AG 54’s own citation REG-R43 REG-R44 REG-R45.
Model #805 does not apply to a RILA if and only if AG 54 is satisfied REG-R42 REG-R44.
VM-21 does not automatically apply to a RILA: §2.A.3 excludes separate-account contracts that guarantee an index and offer no GMDB/VAGLB R3 REG-R35.
AG 43 is not simply superseded by VM-21 — through reference in AG 43, VM-21’s requirements reach pre-2017 contracts outside VM-21’s own scope REG-R35 REG-R38.
VM-22 is not the RILA reserve standard and, in the Jan. 1, 2026 edition, no longer holds the income-annuity maximum valuation interest rates (those are in VM-V §1) — see the VM-22 and VM-V entries in _research/regulatory-actuarial-annuities.md. Noted here only to prevent mis-application; neither entry is cited by the documents in this directory and neither is listed in the table above.
“A RILA CARVM run rests on the SVL text alone, and A-250/A-255 are the closest formulaic items but were not read” is superseded. All three have been read. AG 33 applies — to all annuity contracts subject to CARVM where elective benefits are available, with no product list, no separate-account exception and no threshold REG-R151 — so the interpretive layer is now first-hand and the run rests on the SVL text as read through AG 33. AG 35 was retrieved and does not address this design; record it as neither including nor excluding RILA REG-R152. A-250 and A-255 are not reserve methods at all — one printed page each, each delegating the reserve to A-820, and between them containing no formula, symbol, factor, table, elective-path rule, interim-value rule or the word CARVM REG-R156 REG-R157. Calling them “the closest formulaic items” is defensible only as nearest by subject matter. A verified negative is a result; what stays open is narrower — no retrieved document says how an Interim Value becomes “the future guaranteed benefit” of §5a.
AG 33’s printed effective date is December 31, 1998, not the December 31, 1995 the library carries from IRS Rev. Rul. 2002-6, and the guideline’s printed title is Determining CARVM Reserves for Annuity Contracts With Elective Benefits — which is the title R39 already carries correctly. The January 1, 1981 issue reach is confirmed and is the limb that binds every in-force RILA; the effective date is not. The extracted pages carry no amendment history, so “a later revision” is an inference, not a fact: both dates are recorded and the reconciliation is unresolved REG-R151. Related cautions from the same print: AG 33 contains no formulas, tables or factors beyond the 7% expense-allowance cap and the 33⅓ / 66⅔ / 100% grade-in, it never cites SVL §5a by number (the §5a mapping is the library’s own, made on content), and “efficient policyholder selection” is not its language and appears nowhere in it — the actual construction is that experience-based elective incidence is prohibited, trial sets are maximised over, and the actuary must “consider, not necessarily test” all potential integrated benefit streams REG-R151.

Provenance note#

Extraction details live in _research/registered-index-linked-annuity.md: that file records which facts came from which source, the unverified flags, the per-insurer interim-value algebra, the failed/blocked retrievals listed above, and the twelve documented gaps — most consequentially that no current declared rate sheet was retrievable (gap 1), that annuity purchase rate tables were not found (gap 2), that Trading Costs are required by AG 54 but quantified nowhere (gap 8), and that no specimen contract or policy form was located for any of these products (gap 7), so all product facts come from prospectuses rather than from the contracts themselves. The cross-product bibliographies _research/regulatory-actuarial.md (R1–R34) and _research/regulatory-actuarial-annuities.md (R35–R72) play the same role for [REG-R#] tags, as do _research/appp-ag33.md (R151), _research/appp-ag35.md (R152), _research/appp-a820-a821-a822.md (R153) and _research/appp-a585-a250-a255-a270.md (R156, R157 — and A-270, which carries no reference id and must not be given one) for the AP&P Manual appendix items — those files govern where they and any document in this directory disagree. Standardizations marked std in product-spec.md and technical-notes.md — including the entire declared-rate snapshot, the trading-cost factor, the market-data assumptions used in the worked example, and every behavioral assumption — are introduced at drafting and are not attributable to any source.