Product Specification#

Status: Draft, 2026-08-04; AP&P Manual appendix material added 2026-08-06. All cited sources accessed 2026-08-04 except REG-R151 (AG 33) and REG-R156 (A-250), accessed 2026-08-06.

Scope note. This is a standardized composite specification assembled for reference liability cash-flow modeling of a U.S. individual deferred variable annuity (VA) carrying a guaranteed lifetime withdrawal benefit (GLWB/GMWB) and a guaranteed minimum death benefit (GMDB). It does not describe any single insurer’s product. Tag conventions: [S#]/[R#] resolve against the product research file _research/variable-annuity.md (its own local numbering: S1–S8 product documents, R1–R13 regulatory/actuarial references). [REG-R#] resolves against the single shared cross-product numbering space R1–R157 curated at references/regulatory-and-actuarial-references.md; R1–R34 originate in _research/regulatory-actuarial.md (life-origin, several of which also bind annuities), R35–R72 in _research/regulatory-actuarial-annuities.md (annuity-specific) and R151–R157 in the AP&P Manual appendix extractions read at first hand on 2026-08-06 (AG 33 REG-R151 and A-250 REG-R156 are the two cited here), with most of the R73–R149 block unused — one tag prefix, one numbering space. std marks a standardization introduced for the reference implementation; every std table row carries a footnote giving the rationale and the observed range across insurers. unverified marks a claim the research file could not confirm against a retrieved document; such flags are carried forward, never quietly dropped.

Implementation anchor. The Jackson National Perspective II chassis — statutory prospectus dated April 28, 2025 S1, initial summary prospectus S2, rate sheet supplement dated April 27, 2026 S3 — because it is the most contractually explicit disclosure in the set and exercises every mechanic a general VA model needs S1. Two documented variants ride alongside: the Corebridge VIX-linked non-discretionary rider fee formula S4 S6 and the Equitable formula-linked roll-up rate (10-year CMT + 1.00%, floored 4%, capped 8%) S7.

Product overview and market role#

A deferred VA has two phases: accumulation and income. Once annuitized, withdrawals and surrender cease and — with rider-specific exceptions — death and living benefits terminate S2 S4 S6 S7 S8. During accumulation, premium net of any premium tax buys units in subaccounts of a registered separate account, each investing in one underlying fund (“Investment Divisions” S1 S2; “Variable Portfolios” S4 S6; “variable investment options” S7; “Subaccounts” S8). Contract value follows fund performance with no insurer guarantee; the guarantees are sold as riders tracked on shadow benefit bases that do not follow the market down. The economic content is therefore an investment wrapper plus two written options: a GLWB (a lifetime payment stream funded by the insurer once the account is exhausted) and a GMDB (a floor under the death benefit). Both are path-dependent guarantees on a separate-account balance — which is why their cost cannot be established deterministically and why the statutory reserve for the whole contract is a stochastic CTE70 measure under VM-21 R1 REG-R35.

VAs are federally registered securities sold on SEC Form N-4 R6 REG-R52, with layered disclosure under Rule 498A (Initial and Updating Summary Prospectuses and a mandatory Key Information Table) R7 REG-R50 REG-R51. Modern writers reset GLWB payout percentages, bonus percentages and rider charges through rate sheet prospectus supplements filed on Form 497 rather than by amending the prospectus S3 S5 — a structural fact any model of this product must accommodate, because the parameter set is versioned by rate-sheet date, not by product name.

Representative specification#

Contract identity and issue rules#

Parameter	Representative value	Basis
Design type	Individual flexible-premium deferred variable annuity, non-participating	S1 S2
Funding	Separate account only; general-account Fixed Account Options not available with the elected Roll-up GMDB	S1
Subaccounts modeled	2 (one diversified equity, one fixed income)	std (1)
Allocation	60% equity / 40% fixed income, no rebalancing	std (1)
Tax status	Non-qualified	std (2)
Maximum issue age	85	S1
Anchor model cell	Male, issue age 60, single Designated Life	std (3)
Premium pattern	Single premium $100,000 at issue	std (4)
Minimum initial premium	$10,000 non-qualified; $5,000 qualified	S2
Minimum subsequent premium	$500 ($50 under an automatic payment plan)	S2
Maximum total premiums	$1,000,000 without prior approval	S2
Premium tax	0.00% in the base model, within an observed 0.0%–3.5% state range	std (5); range S2
Latest Income Date	Contract Anniversary on which the Owner is age 95	S2

Footnotes to std rows:

Two subaccounts is the minimum that exercises pro-rata charge allocation and unit accounting; real contracts offer far more (Corebridge Build Your Own Allocation lists 76 options across 12 asset classes S4). The 60/40 split is a modeling convention — no fetched document prescribes an allocation for this chassis. The other designs impose hard allocation controls this one does not: Corebridge requires a 20% (Income Max) or 10% (Daily Flex) general-account Secure Value Account plus mandatory quarterly rebalancing S4; Equitable walls guarantees into a separate Protection account S7.
Non-qualified keeps the RMD interaction in the GLWB withdrawal rules disclosed but inactive; RMD relief is a cited mechanic S1 S6 and belongs in the model as a switch.
Issue age 60 sits inside the GMWB eligible band (35–80 S1) and the add-on GMDB band (79 or younger at issue S1), above the 59½ threshold at which the For Life Guarantee is effective from issue S1, and at or below 69 so the higher 6.00% GMDB roll-up percentage applies S3.
Single premium keeps the base recursion minimal. The chassis is flexible-premium S1 S2; premium receipt increases the GWB, GAWA and Bonus Base S1 and is retained in the recursion as an active term.
Set to zero so GWB(0) equals gross premium and the worked example is checkable; premium tax is contractually deducted from the amounts that initialize the guarantee bases S1.

Separate account and base contract charges#

Parameter	Representative value	Basis
Total base contract asset charge	1.30% p.a. of average daily separate-account value	S2
— mortality & expense risk (M&E) component	1.00% p.a.	std (6)
— administrative asset charge component	0.30% p.a.	S7 component value; split std (6)
Large-contract reduction	1.15% p.a. if contract value ≥ $1,000,000 at the later of issue or the most recent Contract Quarterly Anniversary	S2
Annual contract maintenance charge	$35, waived if contract value ≥ $50,000; deducted proportionally across investment divisions on the Contract Anniversary or on total withdrawal	S2
Fund expense — equity subaccount	0.95% p.a. of fund net assets	std (7)
Fund expense — fixed income subaccount	0.65% p.a. of fund net assets	std (7)
Transfer charge	$25 per transfer after 25 transfers in a Contract Year (reserved right)	S2

Jackson blends M&E and administration into one “Core Contract Charge” of 1.30% maximum assessed daily on average daily Investment Division value S2; its Key Information Table shows base contract cost 1.31% minimum = 1.31% maximum including the amortized contract fee S2, i.e. current equals contractual maximum. Equitable alone unbundles — Series B: operations 0.80% + administration 0.30% + distribution 0.20% = 1.30% S7. The composite therefore takes the 0.30% administrative component directly from S7 and assigns the 1.00% residual to M&E std, so the parts sum exactly to the cited 1.30% total S2. Observed totals: Jackson 1.30% S2; Corebridge Polaris Choice IV 1.65% S6; Corebridge Polaris Advisory 0.40% S4; Equitable 0.65% (ADV) to 1.70% (C) S7; Lincoln 1.55%–1.90% by elected death benefit S8.
Observed fund expense ranges: 0.52%–2.28% (Jackson, stated as of December 31, 2021, so indicative rather than current S2); 0.46%–1.85% S6; 0.21%–1.60% S4; 0.27%–3.48% S8. The two std values sit inside all four with the usual equity/bond ordering.

Contingent deferred sales charge (withdrawal charge) and free withdrawal#

Parameter	Representative value	Basis
CDSC basis	Percentage of Remaining Premium withdrawn, by completed years since receipt of that premium (not contract year)	S2
CDSC schedule	0–1 yr 8.5%; 1–2 7.5%; 2–3 6.5%; 3–4 5.5%; 4–5 5.0%; 5–6 4.0%; 6–7 2.0%; 7+ 0.0%	S2
Remaining Premium	Total premium paid, reduced by withdrawals of premium (including withdrawal charges), before adjustment for MVA or charges	S2
Free withdrawal	10% of Remaining Premium each Contract Year that would otherwise incur a charge, minus earnings; earnings (contract value less Remaining Premium) come out free first; aged-out premium is also free; RMD withdrawals reduce the allowance	S1
Guaranteed-withdrawal carve-out	Cumulative withdrawals within the GLWB annual limit incur no withdrawal charge	S1
Terminal illness / extended care waiver	Increases the charge-free amount on a 12-month terminal prognosis or 90 consecutive days’ confinement; maximum $250,000 of contract value; exercisable once	S2

GLWB rider — representative election: Flex GMWB, Single life, “Core” benefit option#

Parameter	Representative value	Basis
Benefit base name	Guaranteed Withdrawal Balance (GWB)	S1
GWB at issue	Premium net of premium tax = $100,000	S1
Rider charge — current	1.25% p.a. of the GWB	S3
Rider charge — assessment	Quarterly, at rate/4 applied to the GWB on the Contract Quarterly Anniversary	frequency S1; base S1 S3
Rider charge — deduction	Cancelled from subaccounts pro rata to their values	std (8)
Rider charge — guaranteed maximum	3.00% p.a.	std (9)
Rider charge — maximum single increase	+0.25% per increase (Core-tier options)	S1
Rider charge — reset mechanism	Discretionary increase permitted on each fifth Contract Anniversary, with an irrevocable opt-out	S1; selection std (10)
Bonus (roll-up) percentage	6.00% of the Bonus Base	S3
Bonus condition	Credited to the GWB at the end of each Contract Year in which no withdrawal was taken, within the Bonus Period	S1
Bonus Period	10 Contract Years from the endorsement effective date, restarting on each Bonus-Base-increasing step-up occurring on or before the anniversary following the Designated Life’s 80th birthday	S1
Step-up basis	Annual Contract Value on each Contract Anniversary	S3
GWB Adjustment percentage	105%	S3
GWB Adjustment Date	Later of the anniversary on/after the Designated Life’s 70th birthday and the 12th Contract Anniversary; applies only if no withdrawal has been taken by then	S1
GAWA% by attained age at first withdrawal	35–59: 4.00%; 60–64: 4.00%; 65–69: 5.55%; 70–74: 5.75%; 75–80: 5.95%; 81+: 6.20%	S3
For Life Guarantee	Effective at issue because the Designated Life is 59½ or older	S1
Benefit base cap	GWB and Bonus Base each capped at $10,000,000	S1
Eligible ages	Designated Lives 35–80	S1

The research file records the rider charge’s base (GWB) and frequency (quarterly) S1, and records that the annual contract maintenance charge is deducted proportionally across investment divisions S2, but records no allocation rule for the rider charge itself. Pro-rata deduction is therefore a std convention extended from the cited contract-fee rule S2 — near-universal in practice, but not on this evidence a cited contract term.
Guaranteed maxima in the historical charge appendix run 1.20% to 3.00% by option and vintage — Flex Net GMWB Core max 3.00% / current 1.30%; Flex Net Value max 1.70% / current 0.60%; Flex Net Joint Core max 3.00% / current 1.60%; LifeGuard Freedom Net max 2.90% / current 1.45% S1. No guaranteed maximum is recorded for the currently-offered Flex GMWB Single Core option itself, so 3.00% is a std pick at the top of the observed band. Cross-insurer maxima: 2.50% with a 0.60% minimum S4; 2.75% single and joint S8; 1.25% S7.
Three reset mechanisms exist in the set; all three are documented under “Contractual mechanics” below. The model defaults to the Jackson five-yearly discretionary reset std because it matches the chassis, with the VIX-squared formula as a variant.

GMDB rider — representative election: Roll-up GMDB#

Parameter	Representative value	Basis
Benefit form	Greatest of contract value, total Net Premiums, and the roll-up GMDB Benefit Base	S1
Roll-up percentage	6.00% p.a. compounded (age 69 or younger at election); 5.00% if age 70 or older	S3
Roll-up accrual window	From the Issue Date until the Contract Anniversary immediately preceding the oldest Covered Life’s 81st birthday	S1
Rider charge — current	0.90% p.a. of the GMDB Benefit Base	S2 S3
Rider charge — guaranteed maximum	1.80% p.a.	S2
Rider charge — assessment	Quarterly at rate/4 on the GMDB Benefit Base, deducted pro rata	frequency std (11); base S3
Withdrawal adjustment	Dollar-for-dollar up to `roll-up% × Benefit Base at the previous anniversary`; proportional to the contract-value reduction above that; applied at the end of the Contract Year	S1
Eligibility	Owner age 79 or younger at issue	S1
Interaction	Fixed Account Options are unavailable when this GMDB is elected	S1
Included basic death benefit (no charge)	Greater of contract value and total premiums reduced for prior withdrawals in the same proportion the contract value was reduced — a proportional return-of-premium, not dollar-for-dollar	S1 S2

The research file records charge frequency quarterly for the GMWB family S1 but does not state the frequency for the add-on GMDB charge; the std choice aligns the two so a single quarterly charge routine serves both. The charge base (GMDB Benefit Base) and rate (0.90% current / 1.80% maximum) are cited S2 S3.

Contractual mechanics#

Account value and unit accounting#

Contract value is the sum over subaccounts of units held times unit value. Unit value evolves with the fund’s gross return less the fund’s own expenses less the base contract asset charge, assessed daily as a percentage of the average daily account value of the Investment Divisions S2. Charges assessed per contract rather than per unit of value — the annual contract maintenance charge S2 and the two rider charges S1 S3 — are collected by cancelling units, leaving unit value undisturbed. The generic separate-account charge-accrual convention is specified once in products/variable_ul/technical-notes.md and reused here, with two differences that follow from that being a life file: it works at the subaccount-value level and carries no unit count, so the unit ledger above is stated here rather than inherited; and a VA has no cost of insurance and no IRC §7702 corridor, its guarantees being GMDB and GLWB benefit bases rather than a death benefit on a net amount at risk.

GLWB benefit base — the core algebra#

All withdrawals count toward the GLWB annual limit, including automatic withdrawals, RMDs, advisory-fee withdrawals, partial 1035 exchanges and free withdrawals; for guarantee purposes a withdrawal is the total amount withdrawn including withdrawal charges, asset allocation fees, market value adjustments and other charges and adjustments S1. Withdrawals under IRC §72(t)/§72(q) are not treated as RMDs for guarantee-preservation purposes S1 R9. Let W be the current partial withdrawal, ΣW cumulative withdrawals in the Contract Year including W, and L = max(GAWA, RMD) for a qualified contract (L = GAWA otherwise) S1:

Excess Withdrawal  E = min( W , ΣW − L )   if ΣW > L, else 0
Non-excess portion N = W − E

If ΣW ≤ L :   GWB_new  = max( GWB_old − W , 0 );      GAWA unchanged
If ΣW > L :   GWB_new  = max( (GWB_old − N) × (1 − E / CV_pre_excess) , 0 )
              GAWA_new = min( GAWA_old × (1 − E / CV_pre_excess) , GWB_new )

where CV_pre_excess is the contract value after the non-excess portion has been deducted. This is dollar-for-dollar for the guaranteed portion, then pro rata to the contract-value reduction caused by the excess S1 — a treatment that is essentially universal across the set S1 S4 S7 S8. If the For Life Guarantee is not in effect and GWB < GAWA at the end of a Contract Year, GAWA is set equal to GWB S1.

Bonus. GWB += Bonus% × Bonus Base at the end of each Contract Year in the Bonus Period in which no withdrawal was taken; any withdrawal, including an automatic withdrawal or RMD, kills that year’s bonus S1. The Bonus Base initializes at GWB, increases by net premium, is set to min(GWB_after, BB_before) on an excess withdrawal and to max(GWB_after_step-up, BB_before) on a step-up, and is otherwise unaffected by withdrawals; applying the bonus does not change it S1.

Step-up. On each Contract Anniversary, if contract value exceeds the GWB, the GWB resets to contract value S1; the representative basis is the anniversary Contract Value S3. The alternative fixed at election is the Highest Quarterly Contract Value — the highest quarterly adjusted contract value over the four most recent Contract Quarterly Anniversaries, each adjusted for subsequent premiums (net of tax) and withdrawals under the same dollar-for-dollar / proportional rule S1. After the first withdrawal a step-up sets GAWA_new = max(GAWA% × GWB_new, GAWA_old) S1.

GWB Adjustment. A one-shot deferral reward: on the GWB Adjustment Date, GWB = max(GWB, GWB Adjustment), the adjustment initializing at 105% × GWB at endorsement S3, provided no partial withdrawal has been taken by then; any earlier withdrawal voids it without value and the provision terminates S1.

Contract value zero. With the For Life Guarantee in effect, annual payments of GAWA continue for the life of the Designated Life while the contract remains in the accumulation phase; without it, payments continue until the earlier of death or GWB depletion, the final payment truncated to the remaining GWB S1. All other contract rights cease: no further premiums, all other endorsements terminate without value, and no death benefit is payable on subsequent death S1.

GMDB#

The death benefit is the greatest of contract value, total Net Premiums and the roll-up Benefit Base S1; the guarantee component — the insurer’s general-account cost — is the excess of that over contract value. Add-on death benefits may retain value on or after the Income Date: at the Latest Income Date the death benefit becomes GMDB Benefit Base − contract value; at an earlier Income Date the endorsement terminates with no benefit S1.

Rider fee reset provisions — three documented mechanisms#

Periodic discretionary reset with a forfeiting opt-out (std default). The GMWB charge may be increased on each fifth Contract Anniversary, subject to a stated maximum single increase (+0.25% Core-tier, +0.15% Value-tier) and an absolute maximum rate. The owner may opt out, but doing so forfeits the GWB bonus, the automatic step-up, the GWB Adjustment and any other increases to GWB/GAWA; blocks all future premiums; and fixes the GAWA% with no future recalculation. The election is irrevocable S1 S3.
Step-up-triggered reset with a reversing opt-out. The fee rate may increase on every Account Value Step-up, and after the tenth Benefit Year on every Enhancement if the Enhancement Period has renewed. Opting out within 30 days of the Benefit Year anniversary reverses both the fee rate and the Protected Income Base to their pre-step-up levels, for that year only. The rate also rises with no opt-out once cumulative purchase payments after the first Benefit Year anniversary reach $100,000 S8.
Non-discretionary VIX-squared formula reset. For each Benefit Quarter,
```
Annual Fee Rate(t) = Initial Annual Fee Rate
                   + 0.05% × [ QuarterlyAverage(Daily VIX²) / 33 − 10 ]
```
clipped to a movement band against the prior quarter’s rate (±0.40% annualized advisory class, ±0.25% commission class) and to an absolute corridor of [0.60%, 2.50%]; the quarterly deduction is the annual rate ÷ 4 S4 S6. Disclosed examples: initial rate 1.45% with quarterly average VIX² of 204.42 gives 1.45% + 0.05% × (−3.81) = 1.26% (quarterly 0.3150%); a VIX² average of 602.30 gives an unclipped 1.86%, but against a prior rate of 1.42% the +0.40% band caps it at 1.82% S4.

A fourth mechanism resets the benefit growth rate rather than the fee: the Equitable Annual Roll-up rate is the average of daily 10-year U.S. Treasury rates over the 20 calendar days ending on the 15th day of the last month of the preceding calendar quarter, plus 1.00%, rounded to 0.10%, floored at 4%, capped at 8%; the pre-first-withdrawal Deferral bonus rate uses +1.50% on the same formula and floor/cap and terminates permanently on the first withdrawal from the Protection account S7.

Riders and options#

In scope (modeled). Flex GMWB Single Core and the Roll-up GMDB, both parameterized in the tables above S1 S3; the included Basic Death Benefit (no charge, proportional return of premium) S1 S2; the CDSC and free-withdrawal allowance S1 S2.

Described but not modeled. Terminal Illness / Extended Care Benefit (free with all contracts) S2; the rider-created annuitization options — Life Income of GAWA, Specified Period Income of the GAWA (years = GWB ÷ GAWA), and the AutoGuard Fixed Payment Income Option S1; spousal continuation of the GMWB without the For Life Guarantee S1.

Out of scope. Joint-life Flex GMWB, Flex Net GMWB, Flex Strategic Income GMWB (accelerated-then-standard payout), AutoGuard non-lifetime GMWB at a flat 5.00% GAWA%, and MarketGuard Stretch S3; the Highest Quarterly Anniversary Value and Combination Roll-up + HQAV GMDBs S3; Flex DB, a GMWB-linked death benefit with a 100.00% step-up percentage S3; EarningsMax (40% of earnings if issue age < 70, 25% at 70–75, earnings capped at 250% of remaining premiums; closed 2023-08-28) S1; the Four Year Withdrawal Charge Schedule option (+0.40%) and the Capital Protection Program, a closed self-funded GMAB-equivalent S1; Fixed Account Options and their market value adjustment, excluded here by the Roll-up GMDB election S1; dollar cost averaging, DCA+, Earnings Sweep and rebalancing programs S2; GMIB/annuitization guarantees such as the Equitable GIB S7; payout-phase guarantees such as Lincoln i4LIFE® Advantage S8; and Corebridge’s mandatory Secure Value Account allocation S4. No currently-sold GMAB was located in the four registrations read — a research gap, not an omission S1.

Variations across insurers#

Where the guarantee sits. Jackson S1 and Corebridge S4 use the mainstream design — one contract value, a shadow benefit base, guaranteed withdrawals while contract value > 0, insurer-funded payments after zero. Equitable bifurcates into an Investment Performance account (no guarantees) and a Protection with Investment Performance account (funds the guarantees), with an annuitization rather than a withdrawal guarantee S7. Lincoln offers both a conventional GLWB and i4LIFE®, a variable annuitization payout rider with a guaranteed floor S8. Chosen: the mainstream withdrawal-phase design — the one a general VA model must handle, and the one with published algebra S1.
How the benefit base grows. Four mechanics: a bonus on a separate Bonus Base with a 10-year window that restarts on step-up (Jackson, 5%/6%/7% by option) S1 S3; a 7.00% Income Credit on an Income Credit Base that ratchets to Higher Anniversary Values but is not increased by the credits themselves, making the roll-up simple rather than compound (Corebridge Income Max) S4 S5; a formula rate of 10-year CMT + 1.00% floored 4% capped 8% (Equitable) S7; and a flat 6% Enhancement over a 10-year period that does not reset for current elections (Lincoln) S8. Chosen: the Jackson bonus-with-restarting-window — the restart-on-step-up interaction is the hardest of the four to model and subsumes the flat-window designs.
Step-up frequency spans three orders of granularity: annual anniversary (Jackson Value/Core, Lincoln, Corebridge Income Max), highest-of-four-quarters applied annually (Jackson Plus), and daily (Corebridge Daily Flex, where “on any day that the contract value is greater than the Income Base on that day, the Income Base is stepped up to that value”) S1 S3 S4 S8. Chosen: annual, with the highest-quarterly variant as an election so the model can price the granularity difference.
Rider fee base and frequency. The base is consistently the benefit base, never account value: GWB S3, Income Base S4, GIB benefit base S7, Protected Income Base S8. Frequency is quarterly at Jackson S1, Corebridge S4 and Lincoln S8, while Equitable deducts on each contract date anniversary S7. (The research file’s cross-insurer summary calls all four quarterly; this specification follows the per-insurer extraction.) Chosen: quarterly on the benefit base.
Fee reset mechanism differs sharply — five-yearly discretionary with a forfeiting opt-out S1, step-up-triggered with a reversing opt-out plus a no-opt-out $100,000-premium trigger S8, and the non-discretionary VIX² formula S4. Chosen: the five-yearly reset as default, with the VIX² formula as a variant because it is the only one that is a deterministic function of an observable market variable, and so the only one a model can reproduce faithfully.
Investment-risk controls. Corebridge imposes the strongest — a mandatory Secure Value Account (20% with Income Max, 10% with Daily Flex) that cannot be transferred out unless the living benefit is cancelled, plus mandatory quarterly rebalancing S4. Equitable restricts which account funds guarantees S7; Lincoln uses Investment Requirements and managed-risk fund suites S8; Jackson restricts the fixed account instead — Fixed Account Options are unavailable with the Roll-up GMDB, Combination GMDB, Flex DB or EarningsMax S1. Chosen: the Jackson restriction, which removes the fixed account and its MVA from the base model.
GMDB growth ceilings differ by age: Jackson stops all roll-up and ratchet growth at the anniversary preceding the oldest Covered Life’s 81st birthday S1; Equitable’s Highest Anniversary Value ratchets to the anniversary following the 85th and the Roll-up to age 85 base stops there S7; Corebridge’s Maximum Anniversary Value has no stated cutoff in the retrieved text, though its spousal-continuation version stops at the continuing spouse’s 83rd birthday S6. Chosen: age 81, matching the chassis.
Share-class structure trades surrender charge against asset charge. Equitable is the clearest illustration: Series B 1.30% total with a 7-year schedule; L 1.65% with 4 years; C 1.70% with none; CP® 1.55% with a 4–5% credit and 9 years; ADV 0.65% with none S7. Corebridge shows the same trade across two registrations — Polaris Choice IV at 1.65% with an 8/7/6/5 schedule S6 versus Polaris Advisory at 0.40% with no withdrawal charge S4. Chosen: a commission-style class with a 7-year CDSC, because the CDSC drives both the expiry lapse shock and the free-withdrawal interaction.
Post-depletion payout rate. Lincoln alone uses a two-table structure: Table A while contract value > 0, and a materially lower Table B once it reaches zero, at which point the payment is recalculated as Protected Income Base × Table B rate (Select Max ages 70–74: 8.75% single falling to 3.50%) S8. Jackson, Corebridge and Equitable continue at the same percentage S1 S4 S7. Chosen: single-table continuation, with the two-table design noted as a first-order pricing variant.
Rate-sheet volatility. Every current-rate table carries a “can be superseded at any time” clause with a 10-day advance-filing commitment S3 S5 S8, so the parameter set is versioned: Jackson rate sheet dated April 27, 2026 S3. The historical tables show the de-risking cycle plainly — Flex GMWB bonus options were 5%/6%/7% for issues 2019-06-24 → 2020-08-09, cut to 4%/5%/6% for 2020-08-10 → 2022-07-31, restored to 5%/6%/7% from 2022-08-01; the GWB Adjustment fell from 200% through 170/180/190% by bonus option to 105% from 2021-03-01 S1.

Regulatory context#

NAIC Model #250 (Variable Annuity Model Regulation). Correction, per the research file: #250 is the Variable Annuity Model Regulation, not the Annuity Disclosure Model Regulation — that is #245 REG-R43 REG-R45, confirmed independently by AG 54, which cites “NAIC Model 250, Variable Annuity Model Regulation” REG-R44. Model #250 governs insurer qualification, separate accounts, filing, required provisions, nonforfeiture and reports; its §7.B is the boundary rule — to the extent a VA provides benefits that do not vary with separate-account performance before the annuity commencement date, those provisions must satisfy Model #805 REG-R43. Note on the appendix print, which is not a substitute: the AP&P Manual’s Appendix A item for this subject, A-250 (Variable Annuities), has now been read in full and is one page of three paragraphs — the ¶1 definition of a variable annuity, a ¶2 requirement that each separate account hold assets at least equal to the reserves and other contract liabilities of that account, and a ¶3 delegation of the reserve to Appendix A-820 REG-R156. It carries none of the qualification, filing, required-provisions, nonforfeiture or reports material above, and its own header names only the Standard Valuation Law (#820) and SSAP No. 56 — it does not name Model #250 anywhere REG-R156. Every Model #250 statement in this paragraph therefore continues to rest on REG-R43, not on the appendix.

Model #805 and the nonforfeiture floor. Second correction: Model #805 expressly excludes variable annuities, so it does not reach the separate account at all REG-R42; it bites only on a VA’s fixed account, via Model #250 §7.B REG-R43. Where it does bite, its indexed nonforfeiture rate is the lesser of 3% and the five-year Constant Maturity Treasury rate (rounded to the nearest 1/20th of one percent) reduced by 125 basis points, subject to a floor of 15 basis points (0.15%) — not the 1% floor often quoted; the minimum nonforfeiture amount accumulates net considerations of 87.5% of gross, less prior withdrawals, an annual contract charge of $50, premium tax paid and indebtedness REG-R42. None of it is operative here: electing the Roll-up GMDB makes Fixed Account Options unavailable S1.

VM-21 — the statutory reserve standard. VM-21 covers variable deferred and immediate annuities with or without GMDB/VAGLB and constitutes CARVM for contracts in scope R1 REG-R35. Aggregate reserve = Stochastic Reserve + additional standard projection amount + any Alternative Methodology reserve, with the SR being CTE70 of the scenario reserves, each contributing the greatest present value of accumulated deficiency R1 REG-R35. The Alternative Methodology is available only for contracts with no guaranteed benefits or only GMDBs — never a GLWB block R1 — so this product is unavoidably stochastic. Effective for valuation dates on or after January 1, 2020, with an elective 36-month phase-in and a separate economic scenario generator phase-in of 36 months beginning January 1, 2026 R1 REG-R35. Third correction: AG 43 is not simply superseded — through reference in AG 43 the VM-21 requirements also reach contracts issued before January 1, 2017, and the two populations may be aggregated R1 REG-R38.

AG 33 and why it is not the reserve standard here. AG 33 — “Determining CARVM Reserves for Annuity Contracts With Elective Benefits” — has been read in full and applies “to all annuity contracts subject to CARVM, where any elective benefits … are available to the contract owner under the terms of the contract”, with no product list and no separate-account exception; its own examples of elective benefits are full surrenders, partial withdrawals and full and partial annuitizations, which this contract has REG-R151. It is displaced by its own precedence clause — “the product specific actuarial guideline or regulation will take precedence” — which is why AG 43 and VM-21 govern instead. The principle is sourced, the pairing is not: AG 33 names no other guideline anywhere in its eight printed pages and never mentions separate accounts, variable annuities or the Valuation Manual, so the AG 43 pairing is this library’s inference from the general clause, [std, derived] REG-R151. The guideline’s printed effective date is December 31, 1998, “affecting all contracts issued on or after January 1, 1981”, with a grade-in that reached 100% by December 31, 2000 and so has no live effect on any current valuation REG-R151; the library elsewhere carries December 31, 1995 under a different title from IRS Rev. Rul. 2002-6, and because the extracted pages contain no amendment history the reconciliation is unresolved and neither date is presented as settled. The mechanics AG 33 does supply impose a behavioral frame — elective incidence maximised over rather than assumed — which is the opposite of VM-21’s prudent-estimate approach, so assumptions must never be carried between the two frames.

VM-22 and VM-V — where the post-depletion stream lands. VM-22 is the PBR framework for non-variable annuities and does not cover VAs, but fixed income streams from guaranteed living benefits after account exhaustion are named in its Reserving Categories and in VM-V §1’s scope REG-R36 REG-R37. Fourth correction: in the January 1, 2026 Valuation Manual VM-22 is entirely the PBR framework, and maximum valuation interest rates for income annuities live in VM-V Section 1, not VM-22 REG-R36 REG-R37.

C-3 Phase II risk-based capital. One projection, two outputs: VM-21 §§4.A–4.E and the RBC requirements are identical apart from the elective federal income tax treatment REG-R35. Per LR027, C-3 uses CTE(98) — the average of the 2% largest scenario reserves — on the same process as the reserve, with TAR = pre-phase-in VM-21 reserve + the C-3 amount; the C-3 amount is then divided by (1 − the enacted maximum federal corporate income tax rate) and split into interest-rate-risk and market-risk portions R3. The 2020 revisions moved the stochastic measure to 25% of CTE 98 from CTE 90 R4 — which is why the older C-3 Phase II instructions package still prints the pre-reform CTE 90 Total Asset Requirement and a 35% tax rate REG-R47: cite it for structure, R3 for the current level. The reform’s diagnosis — that fully hedging fair value increased capital requirements and volatility — is in the Oliver Wyman QIS II reports R2 REG-R48.

Federal securities law. Registration is on Form N-4 R6 REG-R52, whose Part A order (Item 2 Overview, Item 3 Key Information, Item 4 Fee Table, in numerical order at the front) produces the structure every prospectus in the set follows, with Inline XBRL tagging of specified items R6 — first-hand from the retrieved form; the cross-product entry REG-R52 records a failed fetch and describes the form only through the adopting releases. Rule 498A authorizes the Initial and Updating Summary Prospectuses and the Key Information Table R7 REG-R50 REG-R51. FINRA Rule 2330 governs recommended purchases, exchanges and initial subaccount allocations (not later reallocations), requires principal review within seven business days and surveillance of exchanges within the preceding 36 months — the proximate brake on 1035 exchange velocity and therefore on replacement-driven surrender assumptions R8 REG-R54 REG-R56.

Federal tax. IRC §72 supplies the exclusion ratio, the income-first (LIFO) rule for pre-annuitization distributions, the 10% additional tax under §72(q), and the §72(s) required-distribution-at-death rules that shape death benefit payout modeling R9 REG-R55. §817(h) diversification is a product qualification condition: under Treas. Reg. §1.817-5 no more than 55% of the account’s total assets may be in any one investment, 70% in any two, 80% in any three, 90% in any four, tested quarterly with a 30-day cure window and a look-through to underlying RIC assets R10 REG-R15. RMD timing under the 2024 final regulations is a behavioral input, not merely a tax one, because GLWB activation clusters at the RMD age REG-R57 REG-R58 REG-R64 — unverified. Tax reserves under §807 are the greater of net surrender value and 92.81% of the NAIC-prescribed method (CARVM, i.e. VM-21), capped at statutory REG-R16 REG-R72 — unverified.

Disclosure, suitability, accounting and professional standards. Model #245 largely exempts registered products complying with SEC and FINRA rules under its §3.D, but the Buyer’s Guide is still required in variable annuity sales REG-R45; Model #275’s best-interest standard changes exchange and replacement behavior and therefore surrender assumptions REG-R46. Under LDTI the GLWB and GMDB are the paradigm market risk benefits, at fair value through earnings [REG-R34 — unverified: fasb.org returned 403, so ASU 2018-12 itself was never retrieved and its substance rests on secondary summaries](#uslib-reg-r34) REG-R71 for the MRB-vs-insurance-liability classification, which was retrieved — a second consumer of the same cash flows on a risk-neutral basis. Fifth correction: there is no ASOP for principle-based reserves for annuities — ASOP No. 52 is scoped to VM-20 life products, so any claim that it governs VM-21 is unverified and, on the retrieved ASB text, wrong R11 R12 REG-R31. The applicable standards are ASOP Nos. 7 REG-R27, 22 REG-R29, 56 REG-R32, 2 (non-guaranteed elements, expressly covering variable deferred annuities and so governing the rider-charge reset) REG-R26, 54 REG-R70 and 10 REG-R71; the nearest VM-21-specific guidance is the non-binding Academy practice note supplement R4 REG-R66.