Sources#
Source ids, titles, publishers, URLs, access dates, and retrieval markers are carried
over verbatim from _research/universal-life.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 (dropped here: R9).
No new sources were fetched at drafting; nothing is marked “added at drafting”.
Access date for all citations: 2026-08-03 — except the superseded-but-kept REG-R110 entry, accessed 2026-08-04, and the post-drafting entries REG-R150 and REG-R153–REG-R155, accessed 2026-08-06.
Primary product sources [S#]#
S1. Symetra Life Insurance Company — “Symetra CAUL Universal Life Insurance — Fact Sheet” (LIM-1286 10/23)#
Publisher: Symetra Life Insurance Company (document distributed via Financial Markets Inc., an authorized distributor; PDF is the insurer’s own fact sheet)
Doc type: consumer/product fact sheet (2 pages)
URL fetched: https://www.fmiagent.com/wp-content/uploads/2024-05-22_Symetra_CAUL_Product_Highlights_LIM-1286_10-23.pdf
Retrieved: YES (full PDF read)
S2. Protective Life Insurance Company — “Protective Advantage Choice UL — Producer Guide” (PLAG.3459 (01.15))#
Publisher: Protective Life Insurance Company (distributed via MRW Financial, an authorized distributor; PDF is the insurer’s producer guide)
Doc type: producer/agent guide (8 pages)
URL fetched: https://www.mrwfinancial.com/wp-content/uploads/Advantage-Choice-UL.pdf
Retrieved: YES (full PDF read)
S4. Nationwide Life and Annuity Insurance Company — “Nationwide No-Lapse Guarantee UL II” producer presentation (FLM-1167AO.3 (06/22))#
Publisher: Nationwide (distributed via Krause Agency portal mirror)
Doc type: producer marketing deck / product highlights (19 slides)
URL fetched: https://portal.krauseagency.com/wp-content/uploads/2025/02/Nationwide-No-Lapse-Guarantee-Universal-Life.pdf
Retrieved: YES (full PDF read)
Role in this library: contrast case (guaranteed UL) for the current-assumption design; cited for market-role and out-of-scope rider/guarantee context.
S5. Symetra — CAUL product page, symetra.com (FAILED FETCH)#
URL attempted: https://www.symetra.com/IndividualsFamilies/Products/LifeInsurance/PermanentLifeInsurance/SymetraCAULUniversalLife/
Retrieved: NO — HTTP 403 Forbidden. Current declared crediting rates (symetra.com/liferates) therefore not captured. Nothing cited from this source except the fact of the failed fetch (used to document why current-scale assumptions are std).
Regulatory and actuarial references [R#] (product research file numbering)#
R1. NAIC — Universal Life Insurance Model Regulation (Model 585), January 2001 reprint#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/sites/default/files/model-law-585.pdf
Retrieved: YES (full PDF read, 14 pages)
R2. IRC §7702 — Life insurance contract defined#
Publisher: Legal Information Institute, Cornell Law School (U.S. Code)
URL fetched: https://www.law.cornell.edu/uscode/text/26/7702
Retrieved: YES (fetched and summarized)
Caveat carried over: the fetch was summarized by an automated reader; exact subsection text should be re-verified before quoting in a formal document.
R3. IRC §7702A — Modified endowment contract defined#
Publisher: Legal Information Institute, Cornell Law School (U.S. Code)
URL fetched: https://www.law.cornell.edu/uscode/text/26/7702A
Retrieved: YES (fetched and summarized)
R4. Society of Actuaries — 2017 Commissioners Standard Ordinary (CSO) Tables (resource page)#
Publisher: Society of Actuaries
URL fetched: https://www.soa.org/resources/experience-studies/2015/2017-cso-tables/
Retrieved: YES (page fetched; it is chiefly a download index)
Caveat carried over: 2017 CSO adoption-timeline and usage claims (mandatory from 2020-01-01; UL guaranteed COI cap; terminal age 121) come from search-result context, not a fetched primary document, and remain unverified.
R5. NAIC — Principle-Based Reserving (insurance topic page; gateway to Valuation Manual / VM-20)#
Publisher: National Association of Insurance Commissioners
URL fetched: https://content.naic.org/insurance-topics/principle-based-reserving
Retrieved: YES
R6. American Academy of Actuaries — Life Illustrations Practice Note (September 2021 update)#
Publisher: American Academy of Actuaries, Life Illustrations Work Group
URL fetched: https://actuary.org/wp-content/uploads/2021/09/Life_Illustrations_Practice_Note_Update.pdf
Retrieved: YES (fetched and summarized)
R8. Actuarial Standards Board — ASOP No. 2 (Revised Edition, Doc. No. 204): “Nonguaranteed Elements for Life Insurance and Annuity Products” (adopted September 2021)#
Publisher: Actuarial Standards Board
URL fetched: https://www.actuarialstandardsboard.org/wp-content/uploads/2021/12/asop002_204-2.pdf
Retrieved: YES (full PDF read)
Cross-product regulatory references [REG-R#]#
These are cited with the [REG-R#] prefix to avoid collision with the product research
file’s own R-numbering. Full annotated entries (titles, publishers, URLs, retrieval
markers, access date 2026-08-03) live in _research/regulatory-actuarial.md;
the shared reference library is
references/regulatory-and-actuarial-references.md (same R-numbering, which now runs
R1–R157, with most of the R73–R149 block unused; R1–R34 originate in
_research/regulatory-actuarial.md and R35–R72 — annuity-specific entries not
cited here — in _research/regulatory-actuarial-annuities.md; R150–R157 are the
post-drafting entries — the NAIC PBR topic page and the seven AP&P Manual appendix
items read at first hand on 2026-08-06, of which this directory cites R153 (A-820,
with A-821 and A-822), R154 (A-830) and R155 (A-585)).
Entries cited by the two documents in this directory:
Tag |
Short title |
Retrieval status (per that file) |
|---|---|---|
REG-R3 |
NAIC Valuation Manual, Jan. 1, 2026 edition (VM-01/02/20/31, VM-M/G/C/V) |
fetched (cover, adoption history, full TOC read) |
REG-R5 |
NAIC Universal Life Insurance Model Regulation (Model #585) |
fetched (same document as R1 above) |
REG-R6 |
NAIC Valuation of Life Insurance Policies Model Regulation (Model #830, “XXX”) |
fetched |
REG-R7 |
Actuarial Guideline XXXVIII (AG 38), 2012 text incl. 8D/8E |
fetched |
REG-R13 |
26 U.S.C. §7702 (same statute as R2 above) |
fetched |
REG-R14 |
26 U.S.C. §7702A (same statute as R3 above) |
fetched |
REG-R16 |
26 U.S.C. §807 — tax reserves |
fetched |
REG-R17 |
2017 CSO tables (SOA landing page; same page as R4 above) |
fetched (landing page) |
REG-R18 |
2015 Valuation Basic Table (VBT) — SOA landing page |
fetched (landing page) |
REG-R19 |
ILEC 2012–2019 Individual Life Mortality Experience Report (landing page) |
fetched (landing page) |
REG-R20 |
LIMRA/SOA U.S. Individual Life Persistency Update (2009–2013) |
fetched (landing page) |
REG-R21 |
LIMRA/SOA 2015–2021 UL Premium Persistency and Lapse/Surrender Study (landing page; highlights PDF fetched as R7 above) |
fetched (landing page) |
REG-R23 |
AAA — Life PBR Under VM-20 Practice Note (April 2020) |
fetched |
REG-R26 |
ASOP No. 2 — Nonguaranteed Elements (same standard as R8 above) |
fetched |
REG-R27 |
ASOP No. 7 — Life or Health Cash Flow Analysis (rev. Dec 2025) |
fetched |
REG-R31 |
ASOP No. 52 — Principle-Based Reserves for Life Products under the NAIC Valuation Manual |
fetched |
REG-R32 |
ASOP No. 56 — Modeling |
fetched |
Two entries are kept below in full annotated form rather than as table rows.
REG-R110 is a superseded-but-kept record — the supersession notes of REG-R153
and REG-R154 preserve it unaltered; REG-R150 is a post-drafting entry from the
2026-08-06 pass. Id, title, publisher, URL, access date and fetched marker are carried
from references/regulatory-and-actuarial-references.md.
Ids are never renumbered.
REG-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 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, because the reserves stream worked under R33’s “paid publication” assumption. Formulaic CRVM detail in this directory therefore rests on the Standard Valuation Law itself (R1) and Model #830 (R6).
Superseded in fact for five of the items it indexes, the sentence above being preserved verbatim as the record of what was true when it was written. A-820 is now R153, A-830 is R154, A-585 is R155, A-250 is R156 and A-255 is R157, all read in full from the same free As of March 2026 download as R73. A-270, A-791, A-812, A-815, VM-A-814 and A-817 are still unretrieved, and A-270, although extracted alongside R155, has no reference id assigned and is therefore not citable.
REG-R150. NAIC — Principle-Based Reserving (insurance topic page)#
Publisher: NAIC
URL: https://content.naic.org/insurance-topics/principle-based-reserving
Accessed: 2026-08-06 · Fetched: yes (page shows “Last Updated: 8/1/2025”)
Note: the shared-library entry for this file’s local R5 — the same document, now addressable from the cross-product bibliography. Cited for two verbatim statements: “Effective Jan. 1, 2017, the Valuation Manual became operative” and “PBR which became an accreditation standard Jan. 1, 2020.” Do not confuse with REG-R5, which is the Universal Life Insurance Model Regulation (Model #585) — a different document that this file also cites.
Entries added for the AP&P Manual appendix reading (2026-08-06)#
Newly cited by the “Valuation and reserve pointers” section of technical-notes.md
and by the “Regulatory context” section of product-spec.md. Id, title, publisher,
URL, access date, fetched marker and limits are carried from
references/regulatory-and-actuarial-references.md. Ids are never renumbered.
One physical document behind them. R153, R154 and R155 are appendix items of the NAIC
Accounting Practices and Procedures Manual, As of March 2026 — the same 2,117-page
consolidated PDF catalogued as R73 (the manual itself; its entry lives in
references/regulatory-and-actuarial-references.md and is not reproduced here), a
free download from content.naic.org. They take
appendix-level ids so a document can cite A-585 ¶8.c or A-820 ¶11 instead of a
2,117-page manual. Edition line: none of these items prints “As of March 2026” on its own
pages; every extracted page carries only the footer “© 1999-2026 National Association of
Insurance Commissioners”, which is a copyright span, not an adoption, effective or revision
date, and must never be cited as one. Licence caution inherited from R73: personal and
non-commercial use; redistribution or integration “into any software or other publication”
requires written NAIC permission — the two documents in this directory paraphrase the
mechanics, cite the paragraph, and quote only short anchors. A-270 (variable life) was
extracted alongside A-585 but was assigned no reference id; it is referred to
descriptively where the variable-UL sibling is discussed and nothing is cited from it.
REG-R153. Appendix A-820 — Minimum Life and Annuity Reserve Standards (with Appendix A-821, Annuity Mortality Table for Use in Determining Reserve Liabilities for Annuities, and Appendix A-822, Asset Adequacy Analysis Requirements)#
Publisher: NAIC
URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; A-820 printed A820-1 to A820-13 = PDF pages 1186–1198, A-821 printed A821-1 to A821-6 = PDF pages 1199–1204, A-822 printed A822-1 = PDF page 1205; same physical document as R73
Accessed: 2026-08-06
Fetched: yes (local text extraction; A-820 ¶¶1–28 read in full, A-821 read in full including the 2012 IAM Period Table and Projection Scale G2 printed at its Appendices I–IV, and A-822’s four paragraphs read in full)
Limits carried forward from
_research/appp-a820-a821-a822.md: “As of March 2026” is not printed on PDF pp. 1186–1205 — cite the copyright footer for what those pages print. A-821 prints only the 2012 IAM Period Table and Projection Scale G2; the 1994 GAR table and 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 (R101/R102) — A-820’s own header does not list Model #820 while A-822’s does.Supersedes in fact: the A-820 half of R110’s limit (“A-820 and A-830 as printed in the AP&P Manual were not retrieved”), and, for the paragraphs it carries, the reliance on R1 and R6 alone. R110 is frozen and is preserved unaltered above.
REG-R154. Appendix A-830 — Valuation of Life Insurance Policies (Including the Introduction and Use of New Select Mortality Factors)#
Publisher: NAIC
URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; printed pages A830-1 to A830-27 = PDF pages 1206–1232 — operative text A830-1 to A830-14 (PDF 1206–1219), the Attachment heading and explanatory note at A830-15 (PDF 1220), and the six select-mortality-factor tables at A830-16 to A830-27 (PDF 1221–1232); same physical document as R73
Accessed: 2026-08-06
Fetched: yes (local text extraction; ¶¶1–32 and the Attachment read in full; the six factor tables transcribed programmatically, each parsing to 71 issue-age rows × 20 duration columns)
Limits carried forward from
_research/appp-a830.md: the appendix is a flat sequence of paragraphs ¶¶1–32 plus an unnumbered Attachment and has no Sections at all, so a “Model 830 Section 7” citation does not resolve against this print — the ULSG material is at ¶¶29–32 — and the words “Model #830” and “Regulation XXX” appear nowhere in it. It prints no calendar effective date for itself: “the effective date of this appendix” is an unresolved placeholder used eleven times, and the only calendar dates printed anywhere are the 1 January 2004 cutover to the 2001 CSO. There is no worked numerical example in it, no AG 38 content, no prescribed X value, and no annuity content. Its ¶17 X-factor cross-reference is garbled in the print and is flagged rather than resolved, as is ¶32.b’s unnamed “other appendices governing universal life plans”. The transcribed factor tables were not checked against an independent copy and are not reproduced in this directory.Supersedes in fact: the A-830 half of R110’s limit, and the second-hand reliance on Model #830 (R6) for the segmented/unitary construction. R6 and R110 are frozen and unaltered.
REG-R155. Appendix A-585 — Universal Life Insurance#
Publisher: NAIC
URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; printed pages A585-1 to A585-4 = PDF pages 1102–1105; same physical document as R73
Accessed: 2026-08-06
Fetched: yes (local text extraction; ¶¶1–13 and all three footnotes read in full)
Limits carried forward from
_research/appp-a585-a250-a255-a270.md: the item’s own “Relevant NAIC Model Laws/Regulations” line names only the Standard Valuation Law (#820) — it does not name Model #585 anywhere, so “A-585 is Model #585 §5” is unsupported by this print, and Model #585 (R5) was not re-read against it. A-585 carries the valuation half only: no nonforfeiture provisions, no mandatory policy provisions, no annual-report requirements and no separate interest-indexed UL section. It prints no effective date and no number of any kind — every rate, table and factor is delegated to A-820 (¶¶8.j, 10) — and its ¶8.f pointer to “paragraph 9 of Appendix A-820” does not resolve against the A-820 print read at R153, where ¶9 is the reference-interest-rate paragraph. The fraction bars in ¶¶8.a.ii, 8.f and 13 are lost in the text layer, so those denominators are inferred from layout, not read from a bar character.
Provenance note#
Extraction details live in _research/universal-life.md: that file records which
facts came from which source, including the unverified flags, the failed/partial
fetches (S5, R10), the mirror-hosting caveat for S1/S2/S4 (fetched from
authorized-distributor mirrors carrying the insurers’ own form numbers), and the
vintage caveat that parameter levels are era-representative while mechanics are
stable. The cross-product bibliography _research/regulatory-actuarial.md plays
the same role for [REG-R#] tags — except for the AP&P appendix entries, whose provenance
files are _research/appp-a820-a821-a822.md (R153), _research/appp-a830.md (R154)
and _research/appp-a585-a250-a255-a270.md (R155, and A-270 unnumbered). Those files
record every text-layer artefact repaired and every reading inferred from layout rather
than read; where one of them and a document in this directory 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.