485BPOS 1 finalnatvrm.htm 485BPOS National Integrity VAROOM 2020 Registration Statement Combined Document

National Integrity VAROOM

As filed with the Securities and Exchange Commission on April 24, 2020
Registration Nos. 333-167372 and 811-04846

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933
Pre-Effective Amendment Number
Post-Effective Amendment Number: 11    [ x]

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940
Amendment Number: 136    [ x]
(Check appropriate box or boxes)

Separate Account I of National Integrity Life Insurance Company
(Exact Name of Registrant)

National Integrity Life Insurance Company
(Name of Depositor)
400 Broadway, Cincinnati, Ohio 45202
(Address of Depositor's Principal Executive Offices) (Zip Code)
(513) 629-1114
(Depositor's Telephone Number, including Area Code)


The Western and Southern Life Insurance Company
(Name of Guarantor)
400 Broadway, Cincinnati, Ohio 45202
(Address of Guarantor's Principal Executive Offices) (Zip Code)
(513) 629-1114
(Guarantor's Telephone Number, including Area Code)

Bryan J. Kreyling, Esq.
Associate Counsel
Western & Southern Financial Group, Inc.
400 Broadway
Cincinnati, Ohio 45202
(Name and Address of Agent for Service)

Approximate Date of Proposed Public Offering: Continuous

It is proposed that this filing will become effective (check appropriate box)
 
 
immediately upon filing pursuant to paragraph (b) of Rule 485
 
x
on May 1, 2020 pursuant to paragraph (b) of Rule 485
 
 
60 days after filing pursuant to paragraph (a)(1) of Rule 485
 
 
on (date) pursuant to paragraph (a)(1) of Rule 485
 
 
75 days after filing pursuant to paragraph (a)(2) of Rule 485
 
 
on (date) pursuant to paragraph (a)(2) of Rule 485

If appropriate, check the following box:
 
 
This post-eff amendment designates a new effective date for a previously filed post-eff amendment.

Title of Securities Being Registered: VAROOM® Flexible Premium Variable Annuity


VAROOM® Variable Annuity
May 1, 2020

National Integrity Life Insurance Company
Separate Account I of National Integrity Life Insurance Company

This prospectus describes a flexible premium variable annuity contract. This prospectus contains information about Separate Account I of National Integrity Life Insurance Company (Separate Account I) and the contract that you should know before investing. You should read this prospectus and any supplements, and retain them for future reference.
The Securities and Exchange Commission (SEC) has not approved or disapproved these securities or determined that this prospectus is adequate. Any representation to the contrary is a criminal offense.

A registration statement relating to this contract, which includes a Statement of Additional Information (SAI) dated May 1, 2020, material incorporated by reference, and other information about Separate Account I and National Integrity Life Insurance Company, has been filed with the SEC (file numbers 811-04846 and 333-167372). The SAI is incorporated by reference into this prospectus. A free copy of the SAI is available by sending in the form on the last page of this prospectus, or by writing or calling our Administrative Office listed in the Glossary. The SEC maintains a website at www.sec.gov that contains the SAI and other information that is filed electronically with the SEC. The table of contents for the SAI is at the end of Part 9 of this prospectus.

Beginning on January 1, 2021, as permitted by regulations adopted by the SEC, paper copies of the annual and semi-annual shareholder reports for the Funds available under your variable annuity contract will no longer be sent by mail unless you specifically request paper copies of the reports from National Integrity Life Insurance Company or your financial intermediary. Instead, the reports will be made available on our website at www.westernsouthern.com, and you will be notified by mail each time a report is posted and provided with a website link to access the report.

You may elect to receive all future reports in paper and free of charge. You can contact us at 1-800-433-1778 or contact your financial intermediary if you wish to continue receiving paper copies of your shareholder reports. Your election to receive reports in paper will apply to all Funds available under your variable annuity contract.

The contract must be issued as a traditional IRA, Roth IRA, or SEP IRA (collectively referred to as IRAs). This contract does not provide the tax advantages typically provided by an annuity contract. The tax advantages of this contract exist solely through its qualification as an IRA.

Except for the Fidelity VIP Government Money Market Portfolio, the Funds available for investment under this contract are also available for direct purchase by the general public.

Two of the reasons Exchange-Traded Funds (ETFs) are attractive to direct purchasers are tax efficiency and cost-effectiveness.  Tax efficiency associated with ETFs will not be realized by purchasing this contract because this contract is an IRA.  The ETFs in which the subaccounts invest are cost-effective, but that cost-effectiveness will be reduced by the expenses of this contract. These expenses include the administration expenses that are used, in part, to reimburse us for the cost and commissions associated with investing in the underlying ETFs.

If you purchase shares of these Funds directly from a broker-dealer, you will not pay separate account expenses, but may pay commissions. You will also not have access to an annuity benefit, a guaranteed Death Benefit and an optional guaranteed living benefit. Because of these additional separate account expenses, which affect your contract values and the returns on your investment, you should refer only to information about returns on the Subaccount Units available through this contract, and should not refer to information about returns on these Funds that may be available through other sources.

This annuity is not a deposit of a bank or other financial institution. It is not insured by the Federal Deposit Insurance Corporation, the National Credit Union Share Insurance Fund or other federal entity. It is subject to investment risks, including possible loss of the principal amount invested.


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This prospectus does not constitute an offering in any jurisdiction where such offering may not lawfully be made. No person is authorized to make any representations in connection with this offering other than those contained in this prospectus.

You may invest your premiums in any of the Subaccounts listed below.
Equity Subaccounts
iShares® Core S&P 500 ETF
iShares® Core S&P Mid-Cap ETF
iShares® Core S&P Small-Cap ETF
iShares® S&P 500 Growth ETF
iShares® S&P 500 Value ETF
Vanguard® Dividend Appreciation Index Fund, ETF Shares
Vanguard® Large-Cap Index Fund, ETF Shares
Vanguard® Mega Cap Index Fund, ETF Shares
 
Fixed Income Subaccounts
Fidelity® VIP Government Money Market Portfolio, Initial Class
iShares® Core U.S. Aggregate Bond ETF
iShares® iBoxx $ High Yield Corporate Bond ETF
iShares® Intermediate-Term Corporate Bond ETF
iShares® TIPS Bond ETF
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
Vanguard® Short-Term Bond Index Fund, ETF Shares
Vanguard® Total Bond Market Index Fund, ETF Shares
 
International and Alternative Subaccounts
iShares® International Treasury Bond ETF
Vanguard® Developed Markets Index Fund, ETF Shares
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
Vanguard® Real Estate Index Fund, ETF Shares

iShares ® and Blackrock® are registered marks of BlackRock, Inc. and its affiliates (BlackRock). All other trademarks, service marks or registered trademarks are the property of their respective owners. BlackRock's only relationship to National Integrity Life is the licensing of certain trademarks and trade names of BlackRock. National Integrity Life's variable annuities are not sponsored, endorsed, sold or promoted by BlackRock. BlackRock makes no representations or warranties to the owners of National Integrity Life's variable annuities or any member of the public regarding the advisability of investing in them. BlackRock has no obligation or liability in connection with the operation, marketing, sale or trading of National Integrity Life's variable annuities.

Vanguard is a trademark of The Vanguard Group, Inc.










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TABLE OF CONTENT
 
Page VN-
Glossary
Part 1 – Fees and Expense Tables and Summary of Contract
Fees and Expenses
Contract Owner Transaction Expenses
Separate Account Annual Expenses
Total Annual Fund Operating Expenses
Examples
Accumulation Unit Values
Summary of Contract
This Contract is an IRA
Parties to the Contract
Your Rights and Benefits
Investment Goals and Risks
Account Value and Surrender Value
Your Right to Revoke (Free Look Period)
Part 2 – National Integrity Life and the Separate Account
National Integrity Life Insurance Company
Separate Account I
Subaccounts
Distribution of Variable Annuity Contracts
ETF Custodian
Changes in How We Operate
Part 3 – Your Investment Options
The Fund Families and the Funds
Static Asset Allocation Models
The Fixed Account
Part 4 – Deductions and Charges
Separate Account Charges
Fund Expenses
Withdrawal Charge
Reduction or Elimination of the Withdrawal Charge
Commission Allowance and Additional Payments to Distributors
Optional Benefit Charges
Tax Reserve
State Premium Tax
Part 5 – Terms of Your Variable Annuity
Purchasing the Contract
Premium Payments
Units in Our Separate Account
How We Determine Unit Value
Allocations and Transfers
Detrimental Effect of Trading on Unit Values
Specific Notice Regarding the Use of this Annuity for Market Timing or Frequent Trading
Withdrawals
Free Withdrawal Amount
Timing of Payment of a Withdrawal or Surrender
Assignments
Death Benefit
Spousal Continuation
Selecting and Changing Your Beneficiary

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Filing Death Claims
Maturity Date and Annuity Option
Annuity Payments
How You Make Requests and Give Instructions
Abandoned or Unclaimed Property
Part 6 – Optional Benefits
Guaranteed Lifetime Withdrawal Benefit
Lifetime Payout Amount (LPA)
Nonguaranteed Withdrawal
Other Important Facts about Withdrawals
GLWB Rider Charge
GLWB Investment Strategies
Allocations and Transfers for the GLWB
Withdrawal Protection for Required Minimum Distributions
Continuation of the Spousal GLWB at Owner’s Death
Guaranteed Payment Phase
Cancellation and Termination of Rider
Additional Rules
Additional Rules that Apply to the Spousal GLWB Rider
Should You Purchase the GLWB Rider
Examples
Part 7 – Voting Rights
How Fund Shares Are Voted
How We Determine Your Voting Shares
Part 8 – Tax Aspects of the Contract
Tax Status of the Contract
Types of IRAs
Rollovers and Transfers
Early Distributions
Required Minimum Distributions (RMD)
CARES Act
Inherited IRAs
Federal and State Income Tax Withholding
Tax Status of the Company
Transfers Among Subaccounts
Seek Tax Advice
Part 9 – Additional Information
Systematic Withdrawal Program
Cyber Security and Certain Business Continuity Risks
Anti-Money Laundering
Income Plus Withdrawal Program
Choices Plus Required Minimum Distribution (RMD) Program
Systematic Transfer Program
Customized Asset Rebalancing Program
Legal Proceedings
Table of Contents of Statement of Additional Information
Appendices
Appendix A – Financial Information for Separate Account I of National Integrity Life
Appendix B – Withdrawal Charge Examples
Appendix C – Illustrations of Guaranteed Lifetime Withdrawal Benefit

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GLOSSARY

Account Value - the value of your contract, which consists of the value of your Investment Options added together.

Administrative Office - the address you are required to use to make requests and give instructions about your annuity contract.
 
Regular Mail:
Overnight Mail:
National Integrity Life Insurance Company
PO Box 5720
Cincinnati, Ohio 45201-5720
National Integrity Life Insurance Company
400 Broadway, MS 74
Cincinnati, Ohio 45202-3341
 
 
Phone:
 
1-800-433-1778
 

Annuitant - the human being whose life is used to determine the Maturity Date of the contract and the amount of the Annuity Option.

Annuity Date - any date on or before the Maturity Date that you elect an Annuity Option.

Annuity Option - an arrangement under which income payments are made.

Business Day - any day that the New York Stock Exchange is open.

Contract Anniversary - occurs once annually on the same day as the Contract Date.

Contract Date - the date we issue you the contract; it is shown on the specification pages of your contract.

Contract Year - a year that starts on your Contract Date or any Contract Anniversary.

Death Benefit - benefit paid to the beneficiary on the Death Benefit Date.

Death Benefit Date - the date we receive an original certified death certificate and our death claim forms in Good Order, including the beneficiary's election of form of payment.

Exchange-Traded Funds (ETFs) - a type of investment fund that invests in a basket of securities or other assets and trades like a stock on an exchange.

Fixed Account - an Investment Option offering a fixed rate of return.

Free Withdrawal Amount - the amount you may withdraw in any Contract Year without paying a withdrawal charge.

Fund - an investment in which a Subaccount invests; all Funds in this annuity are ETFs, except the Fidelity VIP Government Money Market Portfolio.

General Account - the Company’s account that contains all of our assets other than those held in separate accounts.

Good Order - complete information we require to process your application, claim or any request received at our Administrative Office, the address of which is noted above in this Glossary.

Guaranteed Lifetime Withdrawal Benefit (GLWB) - an optional benefit Rider that guarantees lifetime payments will be available for withdrawal.

GLWB Investment Strategies - investment strategies available for the GLWB Rider.

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Investment Options - Subaccounts and the Fixed Account, collectively.

IRA - Individual Retirement Annuity under section 408(b), 408(k) or 408A of the Tax Code.

IRS - the Internal Revenue Service.

Maturity Date - the 100th birthday of the Annuitant named on the Contract Date. The Maturity Date is the latest date you can either elect an Annuity Option or receive a lump sum payment.

Rider - a supplement to your contract that provides optional benefits at an additional cost.

Required Beginning Date - April 1st of the year after the calendar year in which the owner reaches the qualified age under the Code and applicable IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72); this is the date when the owner must begin taking Required Minimum Distributions from a Traditional or SEP IRA unless an exemption is otherwise available under applicable law.

Required Minimum Distribution (RMD) - annual withdrawal amount required under the Tax Code based on the prior calendar year-end fair market value of this contract only, as calculated by us.

Separate Account - Separate Account I of National Integrity Life Insurance Company. Its assets are segregated from the General Account by National Integrity Life and divided into Subaccounts.

Subaccounts - Investment Options available to you under the contract other than the Fixed Account. Each Subaccount is a division of the Separate Account and invests exclusively in a single Fund with the same name.

Surrender Value - your Account Value reduced by any withdrawal charge and premium tax.

Systematic Transfer Option (STO) - a Fixed Account that accepts new premiums, which must be transferred from the STO into Subaccounts within either a six-month or one-year period.

Tax Code - the Internal Revenue Code of 1986, as amended, or any corresponding provisions of subsequent United States tax laws, and applicable regulations of the Internal Revenue Service (IRS).

Unit - measure of your ownership interest in a Subaccount.

Unit Value - value of each Unit calculated on each Business Day.
 


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Part 1 – Fees and Expense Tables and Summary of Contract

Fees and Expenses

The following tables describe the fees and expenses that you will pay when buying, owning, withdrawing from and surrendering the contract.

The following table describes the maximum fees and expenses that you will pay at the time you buy the contract, withdraw from or surrender the contract, or transfer contract value among Subaccounts.

Contract Owner Transaction Expenses

Maximum Deferred Sales Load (withdrawal charge) as a percentage of premiums 1
7%

The following table describes the fees and expenses that you will pay periodically during the time that you own the contract, not including Total Annual Fund Operating Expenses.
Separate Account Annual Expenses (as a percentage of average Account Value in Subaccounts)


Maximum Charge
Current Charge
Mortality and Expense Risk Charge
1.00%
1.00%
Administration Charge
0.75%
0.75%
Optional Guaranteed Lifetime Withdrawal Benefit, Investment Strategy 1
1.50%
0.60%
Optional Guaranteed Lifetime Withdrawal Benefit, Investment Strategy 2
1.50%
0.80%
Highest Possible Total Separate Account Annual Expenses 2, 3
3.25%
2.55%

Total Annual Fund Operating Expenses
(expenses deducted from Fund assets, including management fees, distribution fees and other expenses)

The next item shows the minimum and maximum total operating expenses charged by the Funds that you may pay periodically during the time you own the contract. More detail concerning each Fund’s fees and expenses is contained in the prospectus for each Fund.

Minimum: 0.04% Maximum: 0.49%

Details of the Fund operating expenses are on the next page.












_________________________________________________________
1The withdrawal charge decreases over time and is eliminated for each premium after it reaches five years old. See Part 4.
2Assessed daily on the Account Value in the Subaccounts.
3You may elect only one of the optional Guaranteed Lifetime Withdrawal Benefit Investment Strategies. Therefore, the Highest Possible Total Separate Account Annual Expenses reflect the election of Investment Strategy 2, which carries the higher current charge.


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Total Annual Fund Operating Expenses (continued)

Gross annual Fund expenses1 as a percentage of average net assets in each Fund:

Fund

Manage-
ment
Fees

12b-1
Fee

Other Expenses
Acquired Fund
Fees and Expenses
Total Annual Gross Expenses

Equity Subaccounts:
iShares Core S&P 500 ETF 2
0.04%
0.00%
0.00%
0.00%
0.04%
iShares Core S&P Mid-Cap ETF 2, 3
0.06%
0.00%
0.00%
0.00%
0.06%
iShares Core S&P Small-Cap ETF 2
0.07%
0.00%
0.00%
0.00%
0.07%
iShares S&P 500 Growth ETF 2
0.18%
0.00%
0.00%
0.00%
0.18%
iShares S&P 500 Value ETF 2
0.18%
0.00%
0.00%
0.00%
0.18%
Vanguard Dividend Appreciation Index Fund, ETF Shares
0.05%
0.00%
0.01%
0.00%
0.06%
Vanguard Large-Cap Index Fund, ETF Shares
0.03%
0.00%
0.01%
0.00%
0.04%
Vanguard Mega Cap Index Fund, ETF Shares
0.05%
0.00%
0.02%
0.00%
0.07%

Fixed Income Subaccounts:
Fidelity VIP Government Money Market Portfolio, Initial Class
0.17%
0.00%
0.09%
0.00%
0.26%
iShares Core U.S. Aggregate Bond ETF 2, 4, 5
0.04%
0.00%
0.00%
0.01%
0.05%
iShares iBoxx $ High Yield Corporate Bond ETF 2
0.49%
0.00%
0.00%
0.00%
0.49%
iShares Intermediate-Term Corporate Bond ETF 2, 6
0.06%
0.00%
0.00%
0.00%
0.06%
iShares TIPS Bond ETF 2
0.19%
0.00%
0.00%
0.00%
0.19%
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares
0.04%
0.00%
0.01%
0.00%
0.05%
Vanguard Short-Term Bond Index Fund, ETF Shares
0.06%
0.00%
0.01%
0.00%
0.07%
Vanguard Total Bond Market Index Fund, ETF Shares
0.03%
0.00%
0.01%
0.00%
0.04%

International and Alternative Subaccounts:
iShares International Treasury Bond ETF 2
0.35%
0.00%
0.00%
0.00%
0.35%
Vanguard Developed Markets Index Fund, ETF Shares
0.04%
0.00%
0.01%
0.00%
0.05%
Vanguard Emerging Markets Stock Index Fund, ETF Shares
0.08%
0.00%
0.02%
0.00%
0.10%
Vanguard Real Estate Index Fund, ETF Shares
0.11%
0.00%
0.01%
0.00%
0.12%

(1) Each Fund’s expenses were provided in the most recent prospectus for that Fund. We have not independently verified the information. Current or future expenses may be more or less than those shown. More details concerning each Fund's fees and expenses are contained in the prospectus for that Fund.
(2) The Fund's investment advisory agreement provides that the Fund's investment advisor will pay all operating expenses of the Fund, except the management fees, interest expenses, taxes, expenses incurred with respect to the acquisition and disposition of portfolio securities and the execution of portfolio transactions, including brokerage commissions, distribution fees or expenses, litigation expenses and any extraordinary expenses.
(3) The Fund's expense information in the table has been restated to reflect current fees.
(4) The Fund may incur Acquired Fund Fees and Expenses (AFFE). AFFE reflect the Fund’s pro rata share of the fees and expenses incurred by investing in other investment companies. The impact of AFFE is included in the total returns of the Fund. AFFE are not included in the calculation of the ratio of expenses to average net assets shown in the financial highlights section of the Fund’s prospectus
(5) The Fund’s net expenses are 0.04%. The Fund’s advisor has contractually agreed to waive a portion of its management fees in an amount equal to the AFFE, if any, attributable to investments by the Fund in other registered investment companies advised by the Fund's advisor, or its affiliates, through June 30, 2026. The contractual waiver may be terminated prior to June 30, 2026 only upon written agreement of the Trust and the advisor.
(6) The expense information in the table has been restated to reflect current fees.





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Examples

The examples that follow are intended to help you compare the cost of investing in this contract with the cost of investing in other variable annuity contracts. Each example assumes that you invest $10,0004 in the contract for the time period indicated. Each example also assumes that your investment has a 5% return each year. Your actual return may be higher or lower.

Highest Cost Example with Rider
The following example includes the maximum mortality and expense risk charge, administration charge, withdrawal charge, and maximum Fund operating expenses; it also assumes you elect the GLWB Rider at the maximum charge. If the current GLWB Rider charge was used, the total cost would be less than indicated in this example. Based on these assumptions, your costs would be:

If you surrender your contract at the end of the applicable period:

1 year
3 years
5 years
10 years
$1,091
$1,786
$2,398
$4,108

If you remain invested in the contract, or if you select an Annuity Option with a life contingency at the end of the applicable period:

1 year
3 years
5 years
10 years
$391
$1,186
$1,998
$4,108

Highest Cost Example without Rider
The following example includes the maximum mortality and expense risk charge, administration charge, withdrawal charge, and maximum Fund operating expenses; it also assumes you do not elect the GLWB Rider. Based on these assumptions, your costs would be:

If you surrender your contract at the end of the applicable period:

1 year
3 years
5 years
10 years
$934
$1,322
$1,635
$2,644

If you remain invested in the contract, or if you select an Annuity Option with a life contingency at the end of the applicable period:

1 year
3 years
5 years
10 years
$234
$722
$1,235
$2,644

Accumulation Unit Values

See Appendix A








_________________________________________________________
4 This contract requires a minimum initial premium of $25,000.

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Summary of Contract

This Contract is an IRA

This contract is a variable annuity that must be issued as an Individual Retirement Annuity (IRA) as defined by section 408(b), 408(k) or 408A of the Tax Code. The contract itself does not provide the tax advantages typically provided by a variable annuity. The tax advantages available with this contract exist solely through the contract's qualification as an IRA.

You should read Part 8, “Tax Aspects of the Contract” for more information and consult a tax advisor about your particular circumstances. Most of the withdrawals you make before you are 59½ years old are subject to a 10% federal tax penalty on the amounts withdrawn.

You may want to purchase ETFs through a variable annuity issued as an IRA vs. directly though the IRA for several reasons, including, but not limited to, that this annuity provides a guaranteed minimum death benefit, access to guaranteed annuitization that can provide income for life and offers an optional living benefit that can provide income for life.

Parties to the Contract

National Integrity Life Insurance Company - “We,” “our,” “us,” “the Company” and “National Integrity Life” mean National Integrity Life Insurance Company.
Owner - “You” and “your” mean the owner. This variable annuity contract is a contract between you and us. You, as the owner, have certain rights under the contract. Because this contract is an IRA, joint owners are not allowed and you may not transfer ownership.
Annuitant - You are the Annuitant, the person whose life is used to determine the Maturity Date of the contract and the amount of the annuity benefit, when elected. The Annuitant must be a natural person, and cannot be changed after the Contract Date. Joint Annuitants are not allowed until an Annuity Option is elected and will have no effect until the Annuity Date.
Beneficiary - The beneficiary is the person or persons who will receive the Death Benefit upon your death prior to the Annuity Date and upon election of Annuity Benefit, to receive any remaining payments. See Part 5, sections titled “Death Benefit,” “Selecting and Changing Your Beneficiary,” and “Maturity Date and Annuity Options.”
Custodial Account - If the contract is purchased through an established IRA custodial account, the contract owner will be considered the account, the Annuitant will generally be you as the account owner, and the account must be the beneficiary.
Covered Person - A person covered under one of the GLWB Riders. See Part 6.

Your Rights and Benefits

As the owner of the contract, you have the following rights:

To contribute, transfer and withdraw money. See Part 5.
To invest your premiums in the Investment Options. See Part 3.
To elect the optional benefits available at the time you purchase the annuity contract (for an additional cost). See Part 6.
To elect an Annuity Option. See Part 5, section titled "Maturity Date and Annuity Option."
To name one or more beneficiaries to receive the Death Benefit. See Part 5, sections titled "Death Benefit" and “Selecting and Changing Your Beneficiary.” If the owner is a custodian, the owner must name itself as the sole beneficiary.

Your rights are subject to the rules and significant limitations stated in your contract, in this prospectus and under the Tax Code.


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Investment Goals and Risks

This contract allows you to accumulate money for retirement or other long-term goals. This contract is intended for long-term investing only and is not intended as a vehicle for frequent trading. Transfers among Subaccounts are strictly limited under the terms of this contract. See Part 5, section titled "Allocations and Transfers."

An investment in any of the Subaccounts carries with it certain risks, including the risk that the value of your investment will decline and you could lose money. The Subaccounts invest in ETFs (except the Fidelity VIP Government Money Market Portfolio), each of which invests primarily in either common stocks or bonds. You could lose money if one or more of the issuers of stocks or bonds held by the ETFs become financially impaired or if the market as a whole declines. There is also the inherent risk that holders of common stock generally are behind creditors and holders of preferred stock for payments in the event of the bankruptcy of a stock issuer. Holders of corporate bonds are subject to issuer risk as well as credit risk (the risk that the issuer will default on its payment obligations under the bond) and interest rate risk (the risk that changes in interest rates may reduce (or increase) the market value of the bond). Some of the Subaccounts invest in Funds that invest in high yield securities that are rated below investment grade, commonly referred to as “junk bonds.” High yield securities may be subject to greater levels of credit or default risk than higher-rated securities. Some of the Subaccounts also invest in securities issued by companies in foreign countries, which means that world events, such as political upheaval, financial troubles, or natural disasters, will adversely affect the value of these securities. Foreign investments are also subject to currency risk, which is the chance that the value of a foreign investment, measured in U.S. dollars, will decrease because of unfavorable changes in currency exchange rates.

Shares of ETFs may trade at a discount from their net asset value in the secondary market. This risk is separate and distinct from the risk that the net asset value of the ETF shares may decrease. The amount of such discount from net asset value is subject to change from time to time in response to various factors.

For a complete discussion of the risks associated with investing in any particular Subaccount, see the prospectus of the corresponding Fund.

Account Value and Surrender Value

Your Account Value consists of the values of your Investment Options added together. Any amount allocated to a Subaccount will go up or down in value depending on the investment performance of the Fund. The value of premiums allocated to the Subaccounts is not guaranteed. Your Account Value also is subject to charges. See Part 4.

Your Surrender Value is equal to your Account Value, minus any withdrawal charge and applicable premium tax. See Part 4.

Your minimum Account Value is $5,000 if this Contract is issued in New York and $2,000 if this Contract is issued in any other state. If the Account Value goes below the minimum Account Value and we have received no premiums from you for three years if this Contract is issued in New York and two years if this Contract is issued in any other state, we may terminate the contract and pay you the Account Value. We will notify you in advance and will give you at least 60 days to contribute additional premium to bring the Account Value above the minimum if you wish to keep your contract in force. The minimum Account Value does not apply if you have a GLWB Rider.

If you take withdrawals (other than the Free Withdrawal Amount or RMD), this contract also requires that you have a minimum Account Value of $20,000 remaining after the withdrawal. (Please note that you may fully surrender your contract at any time.) This rule does not apply if you have a GLWB Rider. See Part 5, section titled “Withdrawals.”

Your Right to Revoke (Free Look Period)

You may cancel your contract within 10 days after you receive it by returning it to our Administrative Office by mail, postmarked within the 10-day period. We will extend the 10-day period if required by state law. If you cancel your contract, we will return your Account Value, which may be more or less than your original premium depending upon

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the investment performance of the Subaccounts you selected and any applicable charges. You bear the investment risk, as well as any fees and charges incurred, during the free look period. See Part 4 for more discussion of the fees and charges. Some states require that we return your premium, or some amount other than your Account Value. In that case, we will return the greater of the amount required by state law and your Account Value.

Part 2 – National Integrity Life and the Separate Account
National Integrity Life Insurance Company

National Integrity Life is a stock life insurance company organized under the laws of New York on November 22, 1968. Our principal executive office is located at 400 Broadway, Cincinnati, Ohio 45202. We are authorized to sell life insurance and annuities in eight states and the District of Columbia. National Integrity Life is a subsidiary of The Western and Southern Life Insurance Company, a life insurance company organized under the laws of the State of Ohio on February 23, 1888.

National Integrity Life guarantees certain amounts under the contract. We refer to these guaranteed amounts as “insurance obligations,” such as income payments under the GLWB Rider after your Account Value is exhausted. In this case, we will pay you the income payments from our General Account. Benefit amounts paid from the General Account are subject to our financial strength and claims paying ability and our long-term ability to make such payments. There are risks to purchasing any insurance product.

The Western and Southern Life Insurance Company, National Integrity Life’s parent company, has guaranteed the insurance obligations of National Integrity Life to its contract owners, including the owners of this contract (the Guarantee). Amounts covered by the Guarantee are subject to the financial strength and claims paying ability of The Western and Southern Life Insurance Company. The Guarantee does not guarantee investment performance on the portion of your Account Value invested in the Subaccounts. The Guarantee provides that contract owners can enforce the Guarantee directly.

Separate Account I

Separate Account I of National Integrity Life Insurance Company was established in 1986, and is maintained under the insurance laws of the State of New York. The Separate Account is a unit investment trust, which is a type of investment company governed by the Investment Company Act of 1940 (1940 Act).

Under New York law, we own the assets of our Separate Account and use them to support the Subaccounts of your contract and other variable annuity contracts. You participate in the Separate Account in proportion to the amounts in your contract. National Integrity Life Insurance Company is responsible for all obligations under the contract.

Income, gains and losses, whether realized or unrealized, from assets allocated to the Separate Account are credited to or charged against the Separate Account without regard to our other income, gains or losses. The assets of the Separate Account may not be charged with the liabilities arising out of our other businesses. We may allow fees that are owed to us to stay in the Separate Account, and, in that way, we can participate proportionately in the Separate Account. We may also periodically withdraw amounts that are earned and owed to us from the Separate Account.

Subaccounts

The Separate Account is divided into Subaccounts. Each Subaccount invests in shares of a Fund with the same name. The Subaccounts available in this contract are listed in Part 3. We may add, substitute or close Subaccounts from time to time, and we may limit the amount of your investment in one or more of the Subaccounts on a nondiscriminatory basis.

Each Subaccount available in this contract (except for the Fidelity VIP Government Money Market Portfolio) invests in the shares of a distinct ETF. Each ETF available through a Subaccount is a registered investment company. ETF shares are traded throughout the day on exchanges, such as the NYSE Arca, Inc. ETF shares may trade at, above or below their net asset value; however, for purposes of valuing the Subaccount Units, we will use the daily closing price of each ETF on its primary exchange.

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Each ETF available through a Subaccount in this contract seeks investment results that correspond to an index. The returns on the ETF shares will not precisely correlate with the performance of the index. You cannot invest directly in an index. You may want to purchase this variable annuity instead of one that does not invest in passively managed ETFs for several reasons, including, but not limited to, that the underlying fund costs are substantially lower than those of most variable annuities on the market today.

Distribution of Variable Annuity Contracts

Touchstone Securities, Inc., an affiliate of National Integrity Life, serves as the principal underwriter for our variable annuity contracts. Touchstone Securities, Inc. and National Integrity Life are under the common control of the same parent company: The Western and Southern Life Insurance Company. The principal business address of Touchstone Securities is 400 Broadway, Cincinnati, Ohio 45202. The contracts are sold by individuals who are licensed insurance agents and registered representatives of broker-dealers or financial institutions that have entered into distribution agreements with us.

ETF Custodian

Mid Atlantic Trust Company (MATC), a South Dakota registered non-depository trust company, is the custodian for the ETFs held by the Subaccounts. MATC provides certain services to the Separate Account, including custody of and accounting services for the ETFs owned by the Separate Account. MATC also facilitates execution of the purchase and sale of the ETFs through third-party broker-dealers. We pay for these services under an agreement with MATC. The third-party broker-dealers, working with MATC, provide the ETFs to the Separate Account at the daily closing price of each ETF on its primary exchange. These brokerage fees are paid by MATC.

The services of MATC and the third-party broker-dealers underlie the process supporting this variable annuity and the subaccounts’ investments. If either MATC or the third-party broker-dealers terminate or significantly modify the services provided to us, we will seek to replace those services through other providers or through other methods. If suitable replacement services are not available, we will take such other actions or make changes in how we operate as allowed by law and your annuity contract to mitigate any adverse effects on the Separate Accounts, you and us to the greatest extent reasonably possible. These actions could include working directly with broker-dealers to purchase ETFs; bringing in-house the services being provided by MATC; and/or making available index mutual funds as underlying investment options. While we believe it is highly unlikely, it is possible that under a worst-case scenario we would be required to disallow additional contributions into the contract, and that transfers could only be made into the money market subaccount (although your then-current allocations would not be affected).

Changes in How We Operate

We can change how the Company or our Separate Account operates, subject to the approval of federal or state regulators when required by the 1940 Act or other applicable laws. We will notify you if any changes result in a material change in the Funds or Investment Options. We may take one or more of the following actions:
combine the Separate Account with any other separate account we own;
transfer assets of the Separate Account to another separate account we own;
add, remove, substitute, close, change, combine or limit investment in Subaccounts or withdraw assets relating to your contract from one Subaccount and put them into another;
register or end the registration of the Separate Account under the 1940 Act;
operate our Separate Account under the direction of a committee or discharge a committee at any time (the committee may be composed of a majority of persons who are “interested persons” of National Integrity Life);
restrict or eliminate any voting rights of owners or others that affect our Separate Account;
cause one or more Subaccounts to invest in a fund other than or in addition to the Funds;
operate our Separate Account or one or more of the Subaccounts in any other form the law allows, including a form that allows us to make direct investments; we may make any legal investments we wish;
make any changes required by the 1940 Act or other federal securities laws;
make any changes necessary to maintain the status of the contracts as annuities and/or IRAs under the Tax Code; or
make other changes required under federal or state law relating to annuities.


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Part 3 – Your Investment Options

You may invest your premiums in the Subaccounts, the Fixed Account, or both, subject to any restrictions described in this prospectus. If you purchase one of the GLWB Riders, your Investment Options are limited. See Part 6.

Each Subaccount invests in the shares of a distinct Fund. Each Subaccount and its corresponding Fund share the same name. The value of your Subaccount will vary with the performance of the corresponding Fund. For a full description of each Fund, see that Fund’s prospectus and SAI.

The Fund Families and the Funds

Below is a description of each ETF Fund family, iShares and The Vanguard Group, as well as the Fidelity Variable Insurance Products, which offers the Government Money Market Portfolio in this annuity, followed by a brief description of each Fund. Each Fund has a separate prospectus and SAI that provides more details about management fees and other expenses deducted from the Fund, the Fund’s principal investment strategies, and the risks associated with investing in the Fund. The Fund descriptions included below were taken from the most recent publicly available documentation for the Funds as of the time this prospectus was drafted. More recent disclosure may be available in the Funds’ current prospectuses. There is no guarantee that a Fund will meet its investment objective. For a prospectus containing complete information on any Fund, including the risks associated with investing, call our Administrative Office toll-free at 1-800-325-8583.

Fidelity Variable Insurance Products
The Fidelity VIP Government Money Market Portfolio is a Fidelity® Variable Insurance Product and a series of Variable Insurance Products Fund V. Fidelity Management & Research Company, located at 245 Summer Street, Boston, MA 02210, is the investment advisor.

iShares  
iShares Trust is a registered investment company that consists of separate investment portfolios called Funds. All the Funds listed below are ETFs. BlackRock Fund Advisors (BFA), 400 Howard Street, San Francisco, CA 94105, is the investment advisor to each Fund listed in this section. BFA uses a “passive” or indexing approach to try to achieve each Fund’s investment objective. Unlike many investment companies, each iShares Fund does not try to “beat” the index it tracks and does not seek temporary defensive positions when markets decline or appear overvalued. BFA uses a representative sampling indexing strategy to manage each Fund as described in the Fund's prospectus. Each iShares Fund generally invests at least 90% of its assets in securities of the underlying index, depositary receipts representing securities of the underlying index, and/or securities that provide substantially similar exposure to securities in the underlying index. Each Fund, except iShares TIPS Bond ETF, may invest the remainder of its assets in certain futures, options and swap contracts, cash and cash equivalents, including money market funds advised by BFA or its affiliates, as well as in securities not included in its underlying index, but which BFA believes will help the Fund track its underlying index.

The Vanguard Group, Inc.
The Vanguard Group, Inc. is a family of investment companies. Many of the investment companies offer ETF shares, including all those listed below. Each corresponding Subaccount invests in the ETF share class. The Vanguard Group, Inc., P.O. Box 2600, Valley Forge, PA 19482, is the investment advisor to each Fund listed in this section.

Equity Funds:

iShares Core S&P 500 ETF
The Fund seeks to track the investment results of the S&P 500® Index, which measures the performance of the large-capitalization sector of the U.S. equity market. The component stocks of the index are weighted based on the float-adjusted market value of their outstanding shares. The index consists of securities from a broad range of industries. The components of the index are likely to change over time.

iShares Core S&P Mid-Cap ETF
The Fund seeks to track investment results of the S&P MidCap 400®, which measures the performance of the mid-capitalization sector of the U.S. equity market. The component stocks of the index are weighted based on the float-

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adjusted market value of their outstanding shares. Component stocks are selected by the index provider based on the index provider's liquidity measures. The index consists of stocks from a broad range of industries. The components of the index are likely to change over time.

iShares Core S&P Small-Cap ETF
The Fund seeks to track the investment results of the S&P SmallCap 600®, which measures the performance of the small-capitalization sector of the U.S. equity market. The component stocks of the index are weighted based on the float-adjusted market value of their outstanding shares. Component stocks are selected by the index provider based on the index provider's liquidity measures. The index consists of stocks from a broad range of industries. The components of the index are likely to change over time.

iShares S&P 500 Growth ETF
The Fund seeks to track the investment results of the S&P 500 Growth Index™, which measures the performance of the large-capitalization growth sector of the U.S. equity market. It is a subset of the S&P 500® and consists of those stocks in the S&P 500® exhibiting the strongest growth characteristics, as determined by the index provider. The components of the index are likely to change over time.

iShares S&P 500 Value ETF
The Fund seeks to track the investment results of the S&P 500 Value Index™, which measures the performance of the large-capitalization value sector of the U.S. equity market. It is a subset of the S&P 500® and consists of those stocks in the S&P 500® exhibiting the strongest value characteristics, as determined by the index provider. The components of the index are likely to change over time.

Vanguard Dividend Appreciation Index Fund, ETF Shares
The Fund seeks to track the performance of a benchmark index that measures the investment return of common stocks of companies that have a record of increasing dividends over time. The Fund employs an indexing investment approach designed to track the performance of the NASDAQ US Dividend Achievers Select Index, which consists of common stocks of companies that have a record of increasing dividends over time. The Fund attempts to replicate the target index by investing all, or substantially all, of its assets in the stocks that make up the index, holding each stock in approximately the same proportion as its weighting in the index.

Vanguard Large-Cap Index Fund, ETF Shares
The Fund seeks to track the performance of a benchmark index that measures the investment return of large-capitalization stocks. The Fund employs an indexing investment approach designed to track the performance of the CRSP US Large Cap Index, a broadly diversified index of large U.S. companies representing approximately the top 85% of the U.S. market capitalization. The Fund attempts to replicate the target index by investing all, or substantially all, of its assets in the stocks that make up the index, holding each stock in approximately the same proportion as its weighting in the index.

Vanguard Mega Cap Index Fund, ETF Shares
The Fund seeks to track the performance of a benchmark index that measures the investment return of large-capitalization stocks in the United States. The Fund employs an indexing investment approach designed to track the performance of the CRSP US Mega Cap Index. The index is a float-adjusted, market-capitalization-weighted index designed to measure equity market performance of mega-capitalization stocks in the United States. The Fund attempts to replicate the target index by investing all, or substantially all, of its assets in the stocks that make up the index, holding each stock in approximately the same proportion as its weighting in the index.

Fixed Income Funds:

Fidelity VIP Government Money Market Portfolio, Initial Class
The Fund seeks as high a level of current income as is consistent with preservation of capital and liquidity. The Fund normally invests at least 99.5% of its total assets in cash, U.S. Government securities and/or repurchase agreements that are collateralized fully (i.e., collateralized by cash or government securities). The Fund invests in U.S. Government securities issued by entities that are chartered or sponsored by Congress but whose securities are neither issued nor guaranteed by the U.S. Treasury. The Fund invests in compliance with industry-standard regulatory requirements for money market funds for the quality, maturity, liquidity, and diversification of investments.

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iShares Core U.S. Aggregate Bond ETF
The Fund seeks to track investment results of the Bloomberg Barclays U.S. Aggregate Bond Index, which measures the performance of the total U.S. investment-grade bond market. The index includes investment-grade U.S. Treasury bonds, government-related bonds, corporate bonds, mortgage-backed pass-through securities, commercial mortgage-backed securities (MBS) and asset-backed securities (ABS) that are publicly offered for sale in the United States. The components of the index are likely to change over time. The securities in the index must have $300 million or more of outstanding face value and at least one year remaining to maturity, with the exception of amortizing securities such as ABS and MBS, which have lower thresholds as defined by the index provider. In addition, the securities in the index must be denominated in U.S. dollars and must be fixed-rate and non-convertible. The index is market capitalization-weighted and index components are updated on the last business day of each month.

iShares iBoxx $ High Yield Corporate Bond ETF
The Fund seeks to track investment results of the Markit iBoxx® USD Liquid High Yield Index, which is a rules-based index consisting of U.S. dollar-denominated, high yield corporate bonds for sale in the United States. The index is designed to provide a broad representation of the U.S. dollar-denominated liquid high yield corporate bond market. The index is a modified market-value weighted index with a cap on each issuer of 3%. There is no limit to the number of issues in the index. The components of the index are likely to change over time. The bonds eligible for inclusion in the index include U.S. dollar-denominated high yield corporate bonds that: (i) are issued by companies domiciled in countries classified as developed markets by the index provider, (ii) have an average rating of sub-investment grade, (iii) are from issuers with at least $1 billion outstanding face value, (iv) have at least $400 million of outstanding face value, (v) have an original maturity date of less than 15 years, (vi) have at least one year to maturity, and (vii) have at least one year and six months to maturity for new index insertions.

iShares Intermediate-Term Corporate Bond ETF
The Fund seeks to track the investment results of the ICE BofAML 5-10 Year US Corporate Index, which measures the performance of investment-grade corporate bonds of both U.S. and non-U.S. issuers that are U.S. dollar-denominated, publicly issued in the U.S. domestic market, fixed-rate, have a remaining maturity of greater than or equal to five years and less than ten years, and have $250 million or more of outstanding face value. Excluded from the index are equity-linked securities, securities in legal default, hybrid securitized corporates, Eurodollar bonds, taxable and tax-exempt U.S. municipal securities, and dividends-received-deduction-eligible securities. The index is market capitalization-weighted, and the securities in the index are updated on the last calendar day of each month.

iShares TIPS Bond ETF
The Fund seeks to track the investment results of the Bloomberg Barclays U.S. Treasury Inflation Protected Securities (TIPS) Index (Series-L), which measures the performance of the inflation-protected public obligations of the U.S. Treasury, commonly known as “TIPS.” TIPS are income-generating instruments issued by the U.S. Treasury whose interest and principal payments are adjusted for inflation. The inflation adjustment, which is typically applied monthly to the principal of the bond, follows a designated inflation index, the consumer price index (“CPI”), and TIPS’ principal payments are adjusted according to changes in the CPI. A fixed coupon rate is applied to the inflation-adjusted principal so that as inflation rises, both the principal value and the interest payments increase. This can provide investors with a hedge against inflation, as it helps preserve the purchasing power of an investment. Because of this inflation adjustment feature, inflation-protected bonds typically have lower yields than conventional fixed-rate bonds. The index includes all publicly-issued U.S. Treasury inflation-protected securities that have at least one year remaining to maturity, are rated investment-grade, and have $300 million or more of outstanding face value, excluding amounts held by the Federal Reserve System Open Market Account or bought at issuance by the Federal Reserve System. The Fund generally invests at least 95% of its assets in U.S. government bonds. The Fund also may invest up to 5% of its assets in repurchase agreements collateralized by U.S. government obligations and in cash and cash equivalents, including shares of money market funds advised by BFA or its affiliates.

Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares
The Fund seeks to track the performance of a market-weighted corporate bond index with an intermediate-term dollar-weighted average maturity. The Fund employs an indexing investment approach designed to track the performance of the Bloomberg Barclays U.S. 5-10 Year Corporate Bond Index. This index includes U.S. dollar-denominated, investment-grade, fixed-rate, taxable securities issued by industrial, utility, and financial companies,

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with maturities between 5 and 10 years. The Fund invests by sampling the index, meaning that it holds a range of securities that, in the aggregate, approximates the full index in terms of key risk factors and other characteristics. All of the Fund’s investments will be selected through the sampling process, and under normal circumstances, at least 80% of the Fund’s assets will be invested in bonds included in the index. The Fund maintains a dollar-weighted average maturity consistent with that of the index.

Vanguard Short-Term Bond Index Fund, ETF Shares
The Fund seeks to track the performance of a market-weighted bond index with a short-term dollar-weighted average maturity. The Fund employs an indexing investment approach designed to track the performance of the Bloomberg Barclays U.S. 1-5 Year Government/Credit Float Adjusted Index. This index includes all medium and larger issues of U.S. government, investment-grade corporate, and investment-grade international dollar-denominated bonds that have maturities between 1 and 5 years and are publicly issued. The Fund invests by sampling the index, meaning that it holds a range of securities that, in the aggregate, approximates the full index in terms of key risk factors and other characteristics. All of the Fund’s investments will be selected through the sampling process, and at least 80% of the Fund’s assets will be invested in bonds held in the index. The Fund maintains a dollar-weighted average maturity consistent with that of the index, which generally does not exceed 3 years.

Vanguard Total Bond Market Index Fund, ETF Shares
The Fund seeks to track the performance of a broad, market-weighted bond index. The Fund employs an indexing investment approach designed to track the performance of the Bloomberg Barclays U.S. Aggregate Float Adjusted Index. This index represents a wide spectrum of public, investment-grade, taxable, fixed income securities in the United States, including government, corporate, and international dollar-denominated bonds, as well as mortgage-backed and asset-backed securities, all with maturities of more than 1 year. The Fund invests by sampling the index, meaning that it holds a broadly diversified collection of securities that, in the aggregate, approximates the full index in terms of key risk factors and other characteristics. All of the Fund’s investments will be selected through the sampling process, and at least 80% of the Fund’s assets will be invested in bonds held in the index. The Fund maintains a dollar-weighted average maturity consistent with that of the index, which generally ranges between 5 and 10 years.

International and Alternative Funds:

iShares International Treasury Bond ETF
The Fund seeks to track the investment results of the S&P International Sovereign Ex-U.S. Bond Index, which is a broad, diverse, market value-weighted index designed to measure the performance of bonds denominated in local currencies and issued by foreign governments in developed market countries outside the U.S. The index methodology is designed to balance the weighting of each country within the index by limiting the weightings of countries with higher debt outstanding and reallocating this excess to countries with lower debt outstanding. To be eligible for inclusion in the index, the issuing country must be a “Developed Country” as classified by the index provider. The index includes securities issued by the governments in the following 19 countries: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Ireland, Italy, Japan, the Netherlands, Norway, Portugal, South Korea, Spain, Sweden, Switzerland, and the United Kingdom. The index includes bonds having a remaining maturity greater than one year.

Vanguard Developed Markets Index Fund, ETF Shares
The Fund seeks to track the performance of a benchmark index that measures the investment return of stocks issued by companies located in Canada and the major markets of Europe and the Pacific region. The Fund employs an indexing investment approach designed to track the performance of the FTSE Developed All Cap ex US Index, a market-capitalization-weighted index that is made up of approximately 3,885 common stocks of large-, mid-, and small-cap companies located in Canada and the major markets of Europe and the Pacific region. The Fund attempts to replicate the target index by investing all, or substantially all, of its assets in the stocks that make up the index, holding each stock in approximately the same proportion as its weighting in the index.

Vanguard Emerging Markets Stock Index Fund, ETF Shares
The Fund seeks to track the performance of a benchmark index that measures the investment return of stocks issued by companies located in emerging market countries. The Fund employs an indexing investment approach designed to track the performance of the FTSE Emerging Markets All Cap China A Inclusion Index, a market-

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capitalization-weighted index that is made up of approximately 4,018 common stocks of large-, mid-, and small-cap companies located in emerging markets around the world. The Fund invests by sampling the index, meaning that it holds a broadly diversified collection of securities that, in the aggregate, approximates the index in terms of key characteristics. These key characteristics include industry weightings and market capitalization, as well as certain financial measures, such as price/earnings ratio and dividend yield.

Vanguard Real Estate Index Fund, ETF Shares
The Fund seeks to provide a high level of income and moderate long-term capital appreciation by tracking the performance of a benchmark index that measures the performance of publicly traded equity real estate investment trusts (REITs) and other real estate-related investments. The Fund employs an indexing investment approach designed to track the performance of the MSCI US Investable Market Real Estate 25/50 Index, an index that is made up of stocks of large, mid-size, and small U.S. companies within the real estate sector, which is composed of equity REITs, including specialized REITs, and real estate management and development companies. The Fund attempts to track the index by investing all, or substantially all, of its assets in the stocks that make up the index, holding each stock in approximately the same proportion as its weighting in the index.

Static Asset Allocation Models

We may offer one or more asset allocation models in connection with your variable annuity at no extra charge. Asset allocation is the process of investing in different asset classes – such as equity funds, fixed income funds, and alternative funds – depending on your personal investment goals, tolerance for risk, and investment time horizon. By spreading your money among a variety of asset classes, you may be able to reduce the risk and volatility of investing, although there are no guarantees.

We have no discretionary authority or control over your choice of Subaccounts or your other investment decisions. We may make available educational information and materials, such as a risk tolerance questionnaire, that may help you select an asset allocation model, but we do not recommend asset allocation models or otherwise provide advice about whether an asset allocation model may be appropriate for you.

Our asset allocation models are "static."  Although we may change or terminate asset allocation models we are offering to new contract purchasers, we will not change your allocations unless you advise us to do so. You will not be notified if the models are terminated or changed. You will not be provided with information regarding any terminations or changes to the asset allocation models. If you elect to invest using an asset allocation model, and if you elect automatic rebalancing, we will continue to rebalance your percentage allocations among the Funds in your existing model.  

You should consult your investment professional periodically to consider whether any model you have selected is still appropriate for you. You may choose to invest in an asset allocation model or change your asset allocation at any time, subject to the limitations stated in your contract and this prospectus. See Part 5, section titled “Allocations and Transfers.”

Asset allocation does not ensure a profit, guarantee that your Account Value will increase or protect against a decline if market prices fall. An asset allocation model may not perform as intended. Any asset allocation models offered are based on then-available Funds in this annuity. We may discontinue, add, eliminate or change the models at any time.

The Fixed Account

Our Fixed Account is offered through our General Account, which also supports any portion of the Death Benefit, the annuity benefit, and any guarantees under a Rider that are in excess of Account Value. The General Account is not registered under the Securities Act of 1933 or the 1940 Act. Disclosures regarding the Fixed Account and the General Account are subject to certain provisions of the federal securities laws relating to the accuracy and completeness of statements made in prospectuses.

Systematic Transfer Option (STO)
We offer a STO (a Fixed Account) that provides a fixed interest rate on each premium allocated to the STO. That interest rate is guaranteed for that premium while in the STO period selected. Available STO periods are six

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months or one year. All STO premiums will be automatically transferred into the Subaccounts within either six months or one year of your premium payment into the STO, depending on which STO period you select. You can invest in either the six-month or one-year STO at any one time, but not both. We require a minimum premium to the STO of $6,000 to fund the six-month STO or $12,000 to fund the one-year STO. We will automatically transfer equal amounts monthly for the six-month STO and either monthly or quarterly for the one-year STO. Once you have invested premium in a STO, it cannot be transferred from the STO except as the automatic transfers described above.

The STO is available for new premiums only. You cannot transfer from the Subaccounts into the STO. See “Systematic Transfer Program” in Part 9 for more details on this program. If you elect a GLWB Rider, the STO is only available for your initial premium received by us on or before the Contract Date.

Part 4 – Deductions and Charges

Separate Account Charges

We deduct a daily charge equal to an annual effective rate of 1.75% of your Account Value in each of the Subaccounts to cover our separate account charges, which include

mortality and expense risk charge of 1.00%; and
administration expense charge of 0.75%.

A portion of the separate account charges pays us for assuming the mortality risk and the expense risk under the contract. The mortality risk, as used here, refers to our risk that Death Benefits are greater than anticipated, or that annuitants, as a class of persons, will live longer than estimated and we will be required to pay out more annuity benefits than anticipated. The expense risk is our risk that the expenses of administering the contract will exceed the reimbursement for administrative expenses.

The administration expense charge is used to reimburse us for administrative expenses, including, but not limited to, processing applications, issuing contracts, processing customer orders and other requests, making investments, providing regular reports and confirmations to customers, providing reports and updates to regulators, maintaining accounting records for each contract owner, administering income payments, furnishing accounting and valuation services (including the calculation and monitoring of the daily Unit Values), reconciling and depositing cash receipts, and providing forms.

The administration expense charge also reimburses us for the cost and commissions associated with investing in the underlying ETFs, including brokerage commissions. The brokerage commissions associated with the ETF trades will be paid directly by MATC to the executing broker, and indirectly by us under an arrangement with MATC. See Part 2, section titled “ETF Custodian.” This arrangement is a proprietary fee arrangement based on a percentage of assets invested in the ETFs. Ultimately, this cost is passed along to you as part of this administrative expense.

The administration expense charge may also reimburse us for the costs of distribution of this variable annuity. We expect to make a profit from the separate account charges. The separate account charges cannot be increased without your consent.

Fund Expenses

The net asset value of the Fund shares reflects investment management fees and other expenses that have already been deducted from the assets of the Funds. Please refer to Part 1, section titled “Total Annual Fund Operating Expenses,” and the individual Fund’s prospectus for details on Fund expenses.

Withdrawal Charge

If you withdraw your premiums, you may be charged a withdrawal charge of up to 7% of the premium. The amount of the withdrawal charge is a percentage of each premium withdrawn and not of the Account Value. The charge

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varies, depending upon the "age" of the premiums included in the withdrawal. The “age” of a premium is the number of years that have passed since each premium was paid.
Premium
Year
Charge as a Percentage of the Premium Withdrawn
1
7%
2
7%
3
6%
4
5%
5
4%
thereafter
0

When you take a withdrawal, the oldest premium is treated as the first withdrawn, then next oldest and so on. Any gain or earnings in your contract come out only after an amount equal to all your premiums, and any applicable charges on those premiums, is withdrawn. Please note, however, that for tax purposes, withdrawals are generally considered to be gain first. See Part 8.

Because the withdrawal charge applies to each premium, if your Account Value has declined due to poor performance of your selected Subaccounts or you have taken previous withdrawals, including the Free Withdrawal Amount, the withdrawal charge may be greater than the amount available for withdrawal. In some instances, your Account Value may be positive, but you will not have money available to withdraw due to the amount of the withdrawal charge still applicable to your premiums. A withdrawal charge applies to the withdrawal charge amount itself since this amount is part of the premium withdrawn.

You may take your Free Withdrawal Amount each Contract Year without paying a withdrawal charge. More details on the Free Withdrawal Amount are in Part 5, in the section titled "Free Withdrawal Amount."

We will not deduct a withdrawal charge from:
the Death Benefit; or
a withdrawal used to buy an immediate annuity from us after the first Contract Anniversary with either: (i) life contingencies; or (ii) a period certain that provides for fixed payments over 10 or more years.

If you take withdrawals (other than the Free Withdrawal Amount or RMD), this contract also requires that you have a minimum Account Value of $20,000 remaining after the withdrawal. (Please note that you may fully surrender your contract at any time.) This rule does not apply if you have a GLWB Rider. See Part 5, section titled “Withdrawals.”

For more information and examples of application of the withdrawal charge, see Appendix B.

Reduction or Elimination of the Withdrawal Charge

We can reduce or eliminate the withdrawal charge for individuals or a group of individuals if we anticipate expense savings. We may do this based on the size and type of the group, the amount of the premium, or whether there is some relationship with us. Examples of these relationships would include being an employee of National Integrity Life or an affiliate, receiving distributions or making internal transfers from other contracts we issued, or transferring amounts held under qualified plans that we, or our affiliates, sponsored. We will not unlawfully discriminate against any person or group if we reduce or eliminate the withdrawal charge.

Commission Allowance and Additional Payments to Distributors

We generally pay a commission to the sales representative equal to a maximum of 6% of premiums, and up to 0.70% trail commission paid on Account Value starting in the second Contract Year. Commissions may vary due to differences between states, sales channels, sales firms and special sales initiatives.

A broker-dealer or financial institution that distributes our variable annuity contracts may receive additional compensation from us for training, marketing or other services provided. These services may include special

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access to sales staff and advantageous placement of our products. We do not make an independent assessment of the cost to the broker-dealer or financial institution of providing such services.

National Integrity Life has agreements with some broker-dealer firms under which we pay varying amounts, but no more than 0.25% of Account Value, for enhanced access to their registered representatives. This payment to broker-dealer firms is separate from and in addition to brokerage commissions paid to our distributors from your Distribution Charge. The broker-dealer firms are BBVA Securities, Inc., BOK Financial Securities, Inc., Cetera Investment Services LLC, Commerce Brokerage Services, Inc., CUSO Financial Services, LP, Frost Brokerage Services, Inc., Hancock Investment Services, Inc., Infinix Investments, Inc., LPL Financial LLC, M&T Securities, Inc., PNC Investments LLC, and US Bancorp Investments, Inc.

Depending on the arrangements in place at any particular time, a broker-dealer, and the registered representatives associated with it, may have a financial incentive to recommend a particular variable annuity contract. This could create a conflict of interest between the broker-dealer or the registered representative and the customer. These payments could provide incentive to a broker-dealer or registered representative to recommend a Contract that is not in your best interest. You can find more about compensation in the SAI.

Optional Benefit Charges

You may purchase one of the GLWB Riders offered with this contract, which provide optional benefits for an additional cost. The additional cost of the Riders, along with complete details about their benefits, is provided in Part 6.
Tax Reserve

In the future, we may charge for taxes or set aside reserves for taxes, which will reduce the investment performance of the Subaccounts.

State Premium Tax

We will not deduct state premium taxes from your premiums before investing them in the Investment Options, unless required by your state law. If you elect an Annuity Option, we will deduct any applicable state premium taxes from the amount available for the Annuity Option. State premium taxes currently range from 0 to 1.0% for IRAs.

Part 5 – Terms of Your Variable Annuity

Purchasing the Contract

If you wish to purchase a contract, you must apply for it through an authorized sales representative. The sales representative will send your completed application to us, and we will decide whether to accept or reject it. If we accept your application, we will issue a contract and send it to you either directly or through your sales representative.

To apply for a contract, you must be of legal age to enter into a contractual relationship under applicable state law, generally 18 years old. You must be no older than 80 at the time of application.

This contract must be issued as an IRA. Subject to various rules and limitations, the Tax Code permits you to transfer or roll over money tax-free from one IRA to another IRA or from certain other qualified plans, such as a 401(k) plan, to an IRA. See Part 8.

If you are transferring money from another annuity contract that is an IRA to acquire this contract, you should carefully compare this contract to your current contract. You may have to pay a withdrawal charge under your current contract to transfer to this contract, and this contract has its own withdrawal charges that would apply to you. The other fees and charges under this contract may be higher (or lower), and the benefits may be different, than those of your current contract. In addition, you may have to pay federal income and penalty taxes on the transfer if it does not qualify for tax-free transfer or rollover treatment. You should not transfer from another annuity contract unless you determine that the transfer is right for you. Please note that the person who sells you this

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contract generally will earn a commission on the sale. You should also consult a tax advisor before requesting a tax-free transfer or rollover.

Premium Payments
Minimum initial premium
$25,000
Minimum additional premium
$1,000
Maximum total premium without prior approval
$1,000,000
Maximum additional premium
up to applicable IRA limits each calendar year plus permissible transfers and rollovers


 
Because the initial premium must be $25,000 or more, the contract can only be purchased by transfer or rollover from an existing IRA or from certain other qualified plans, such as a 401(k) or a 403(b) plan. You can make additional premium payments at any time before age 81, or earlier if limited by the Tax Code. For example, you cannot contribute new premiums other than transfers and rollovers to a traditional IRA for the calendar year in which you reach the qualified age under IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72), and thereafter.
 
 
You must determine whether any premium qualifies as a permissible contribution subject to favorable tax treatment under the Tax Code. You must also determine whether such amount qualifies as a permissible transfer or rollover contribution under the Tax Code. For example, you cannot roll over from a SIMPLE IRA during the first two years of participation in the SIMPLE IRA and a roll over of an after-tax contribution that had been made to a Roth IRA may be a taxable event. You cannot roll over distributions from an existing IRA or from certain other qualified plans that are part of a series of substantially equal payments made over your life expectancy, distributions made for a specified period of 10 years or more, RMD distributions or hardship distribution. For more information about limitations, see Part 8, section titled “Rollovers and Transfers.”

If you transfer or roll over money into this contract in the calendar year on or after you reach the qualified age under IRS regulations, you must take your RMD for the current calendar year before you purchase this contract.

We may refuse additional premiums if: (1) you have allocated some or all of the premium to an Investment Option, to which we are no longer accepting additional premiums; (2) the additional premium does not meet our minimum additional premium amount or exceeds our maximum premium amount for the annuity contract or for a specific Investment Option; (3) the total premiums paid under all annuity contracts issued by us, or our affiliates, on your life exceed $1,000,000; (4) we believe that the additional premium is being made by or on behalf of an institutional investor; or (5) for any reason allowed by law. You cannot purchase this contract with a rollover or transfer of death benefits from another annuity.

Your premiums are invested in the Investment Options you select. Each premium is credited as of the date we receive the premium in Good Order at our Administrative Office, except that additional time is allowed for the application of the initial premium under Rule 22c-1 of the 1940 Act. Good Order means complete information we require to process your application or any request.

Initial premium allocated to the subaccounts will be priced at the unit value determined no later than two business days after receipt of a completed application (including all necessary related information).  If the application is not complete, we may retain the initial premium for up to five business days while attempting to complete it.  If the application is not completed within five business days, you will be informed of the reason for the delay.  The initial premium will be returned unless you specifically allow us to hold the premium until the application is completed.

Once received in Good Order, premiums allocated to Subaccounts are used to purchase Units at the Unit Value as of the next close of the New York Stock Exchange.

Each additional premium will be credited to your Subaccount under your stated allocation as of the date we have received the premium in Good Order at our Administrative Office. If you submit a different allocation, a 60-day waiting period will start before you can make a subsequent transfer or allocation change. See Part 5, section titled "Allocations and Transfers."

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All premiums are deemed received when they are received in Good Order at our Administrative Office.

Units in Our Separate Account

Your investment in the Subaccounts is used to purchase Units. On any given day, the value you have in a Subaccount is the number of Units you own in that Subaccount multiplied by the Unit Value. The Units of each Subaccount have a different Unit Value.

Units are purchased when you contribute new premium to your contract or transfer amounts to a Subaccount. Units are redeemed (sold) when you make withdrawals or transfer amounts out of a Subaccount into a different Subaccount. We also redeem Units to pay the Death Benefit or if you elect an Annuity Option, or as permitted or required by law. The number of Units purchased or redeemed in any Subaccount is calculated by dividing the dollar amount of the transaction by the next computed Unit Value for that Subaccount, calculated as of the next close of business of the New York Stock Exchange.

Each Unit represents a fractional undivided interest in the assets held in the related Subaccount. If Units of any Subaccount are redeemed, the fractional undivided interest represented by each remaining Unit will be increased. If additional Units are issued by any Subaccount, the fractional undivided interest represented by each remaining Unit will be decreased. Units will remain outstanding until redeemed by a contract owner.

If we make a mistake in executing any purchase or redemption, we will reprocess, if necessary, any trades made in error and ensure that you receive the correct Unit Values. We will put you in the same position you otherwise would have been in. Depending on the change in Unit Values between the error and correction, we may experience a gain or loss as a result of any reprocessing.

The Unit Value of each Subaccount will fluctuate with the investment performance of the corresponding Fund, which reflects the investment income, realized and unrealized capital gains and losses of the Fund, and the Fund’s expenses.

How We Determine Unit Value

We determine the Unit Value for each Subaccount after the close of business of the New York Stock Exchange, which is normally 4 p.m. Eastern Time on each Business Day. To value your Subaccount Units invested in ETFs, we use the daily closing price of each ETF on its primary exchange. Note that the ETF shares may trade at a discount from the net asset value of the ETF. To value your Subaccount Units invested in the Fidelity VIP Government Money Market Portfolio, we use the daily net asset value provided by Fidelity for the VIP Government Money Market Portfolio. In addition to the Fund shares, the Subaccounts that invest in the ETFs also hold an accrual for any dividends or other distributions declared by the ETF, which will be reinvested in the ETF on the next Business Day after payment.

The Unit Value of each Subaccount for any Business Day is equal to the Unit Value for the previous Business Day, multiplied by the net investment factor for that Subaccount on the current Business Day. The net investment factor measures the investment performance of a Subaccount from one Business Day to the next.

We determine the net investment factor by dividing the net asset value of the Subaccount for that valuation period by the net asset value of the Subaccount for the preceding valuation period. We subtract from that result the daily equivalent of the annual separate account charges for each calendar day since the last day that a Unit Value was determined (for example, a Monday calculation will include charges for Saturday and Sunday).

Generally, this means that we adjust Unit Values to reflect the change in value of the Fund shares, for the separate account charges and, if elected, the GLWB Rider charge.

Allocations and Transfers

Only one investment allocation to the Subaccounts may be in place at any time on your contract. This allocation applies to your current investment, future premiums, and rebalancing. In addition to your one allocation to the

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Subaccounts, you may allocate some or all of your initial premium and additional new premium to the STO. Transfers from the STO to the Subaccounts must be according to your one investment allocation to the Subaccounts.

You may reallocate all or part of your Account Value among the Subaccounts; however, each reallocation triggers a 60-day waiting period before you can make another allocation change. A transfer between or among Subaccounts is an “allocation change.” Here are the details:

A 60-day waiting period applies after your initial allocation on the Contract Date. This means you must wait 60 days after the contract is issued before you make an allocation change.
A 60-day waiting period applies after any voluntary allocation change. This means you must wait 60 days after the date you make an allocation change before you make another allocation change.
The following allocation changes will not trigger the 60-day waiting period:
automatic rebalancing;
automatic transfers from the STO;
reallocation as a result of any material change in a Fund or a Subaccount (see Part 2, section titled “Changes in How We Operate”);
automatic transfers that take place upon cancellation of a GLWB Rider, unless you make additional voluntary allocation changes in connection with the GLWB Rider cancellation.

Allocations and transfers are restricted further if you have a GLWB Rider. See Part 6.

To request a reallocation, you may write to our Administrative Office at the address in the Glossary. Mail sent to any other address may not be in Good Order. You may also contact your sales representative to request a reallocation. Each request for a reallocation or transfer must specify:
the contract number; and
the Subaccounts and allocation percentages stated in whole percentages.

If one portion of a reallocation request involving multiple Subaccounts violates our policies or is not in Good Order, the entire request will not be processed. You will need to resubmit a request that is in Good Order for your reallocation to be processed.

You may also request a reallocation through our telephone transfer service using your personal identifiers. We will honor telephone instructions from any person who provides correct identifying information. We are not responsible for fraudulent telephone requests we believe to be genuine according to these procedures. Accordingly, you bear the risk of loss if unauthorized persons make reallocations on your behalf. Telephone reallocations may be requested from 9:00 a.m. to 5:00 p.m. Eastern Time, on any day we are open for business. We do not guarantee that we will be able to accept transaction instructions via telephone at all times, and we reserve the right to limit, restrict or terminate telephonic transaction privileges at any time.

If we receive your request in Good Order at our Administrative Office before the close of regular trading on the New York Stock Exchange (normally, 4:00 p.m. Eastern Time) on a Business Day, you will receive the Unit Values for the Subaccounts as of the close of business on the day you call.

Requests received at our Administrative Office at or after the close of regular trading on the New York Stock Exchange (normally, 4:00 p.m. Eastern Time) on a Business Day, or received on a day other than a Business Day, will be processed using Unit Values as of the close of business on the next Business Day. We will confirm all reallocations in writing.

Detrimental Effect of Trading on Unit Values

This contract is intended for long-term investing only and is not intended as a vehicle for frequent trading. Reallocations (transfers) among Subaccounts are strictly limited under the terms of this contract. See Part 5, section titled "Allocations and Transfers." We may refuse any reallocation request for an owner or certain owners if we believe, in our sole discretion, that a specific request or group of requests may have a detrimental effect on Unit Values. We will notify you or your designated representative if your requested reallocation is not made.


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Specific Notice Regarding the Use of this Annuity for Market Timing or Frequent Trading

This contract is not designed to serve as a vehicle for trading in response to short-term fluctuations in the market. You cannot engage in intra-day trading of the ETFs available through the Subaccounts. Any person that intends to engage in stale price arbitrage, utilize market timing practices or make frequent transfers for any reason should not purchase this contract.

If we determine, in our sole discretion, that a contract owner is attempting to engage in improper trading, we may revoke their same-day reallocation/transfer privileges and require their trades to be submitted via U.S. Mail or overnight delivery service. We may reject transactions made in violation of our market timing policies. We may modify these restrictions at any time in our sole discretion.

Withdrawals

You may make withdrawals as often as you wish, subject to following rules:
Each withdrawal must be at least $250.
Your Account Value remaining after a partial withdrawal, including any withdrawal charge, must be at least $20,000. (Please note that you may fully surrender your contract at any time.) This rule does not apply to a withdrawal of your Free Withdrawal Amount, your RMD, or if you have a GLWB Rider.

Unless you request a withdrawal from a specific Investment Option, we will take the withdrawal from your Investment Options, pro rata, in the same proportion their value bears to your total Account Value. For example, if your Account Value is divided in equal 25% portions among four Subaccounts, when you make a withdrawal, 25% of the withdrawal will come from each of your four Subaccounts.

Withdrawals are processed when a request is received in Good Order at our Administrative Office. When you take a withdrawal from a Subaccount, Units are redeemed at the Unit Value as of the next close of the New York Stock Exchange.

The total amount deducted from your Account Value will be the withdrawal amount requested, plus any withdrawal charge that applies (see Part 4, section titled "Withdrawal Charge"). The amount you receive will be the amount you requested, less any applicable tax withholding. Withdrawals are handled differently if you elect a GLWB Rider. See Part 6.

Withdrawals are attributed to your Account Value in the following order: (1) any remaining Free Withdrawal Amount; (2) premiums that are no longer subject to a withdrawal charge and have not yet been withdrawn; (3) premiums subject to a withdrawal charge; and (4) any gain, interest, or other amount that is not considered a premium. Your investment comes out first, beginning with the oldest premium first, then next oldest and so on. Any gain or earnings in your contract come out only after an amount equal to all premiums, and any applicable charges on those premiums, are withdrawn. Please note, however, that for tax purposes, withdrawals prior to the annuity starting date are considered to be gain first. See Part 8.

Your financial professional or a third party may have offered you asset allocation or investment advisory services for your contract. Fees you pay for such investment advisory services are in addition to any contract charges. While we no longer accept these arrangements, if you already have them in place the payments are withdrawals from your Account Value and will be subject to any applicable withdrawal charge. We will withdraw the requested payment according to the third party's instructions (including instructions about which Subaccounts to withdraw the fee from) and send you a confirmation of the transaction. We will not verify the accuracy of the amount being requested.

Examples of withdrawals and the application of a withdrawal charge are located in Appendix B.

Additional restrictions apply to withdrawals if you have a GLWB Rider. See Part 6.

Your Death Benefit is reduced by withdrawals on a proportional basis. See Part 5, section titled "Death Benefit."


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Most of the withdrawals you make before you are 59½ years old are subject to a 10% federal tax penalty. See Part 8.

Free Withdrawal Amount

You may take your Free Withdrawal Amount each Contract Year without paying a withdrawal charge. The Free Withdrawal Amount is the greater of:
10% of your Account Value on the date of the withdrawal, minus any partial withdrawals taken during the current Contract Year; or
10% of your Account Value at your most recent Contract Anniversary, minus any partial withdrawals taken during the current Contract Year. (During your first Contract Year, this amount is 10% of your initial premium received on the Contract Date.)

If your RMD (based on the fair market value of this contract only as calculated by us) is greater than your Free Withdrawal Amount, we will allow you to take the RMD as your Free Withdrawal Amount, but only once each Contract Year. Because your RMD is based on a calendar year, you should plan in advance to coordinate your RMD with your available Free Withdrawal Amount.

If you do not take the Free Withdrawal Amount in any one Contract Year, you cannot add it, or any unused portion of it, to the next year’s Free Withdrawal Amount.

The Free Withdrawal Amount does not apply to a full surrender. Taking your Free Withdrawal Amount will not reduce the total withdrawal charge applicable to your premium. If you take a subsequent withdrawal for more than the Free Withdrawal Amount or if you surrender the contract, we will assess any applicable withdrawal charge on the amount of your premiums withdrawn, which are not reduced for any Free Withdrawal Amount you have taken.

The Free Withdrawal Amount is available for withdrawal only. The Free Withdrawal Amount is not available for transfer to another IRA or other qualified contract or account.

Timing of Payment of a Withdrawal or Surrender

We normally send you partial or full withdrawals (or apply your Account Value to the purchase of an Annuity Option) within seven days after receipt of the required form at our Administrative Office. However, we can defer our action for any period during which:

(1)
the New York Stock Exchange has been closed, other than a weekend or holiday, or trading on it is restricted;

(2)
an emergency exists as determined by the SEC so that disposal of securities is not reasonably practicable or it is not reasonably practicable for the Separate Account fairly to determine the value of its net assets; or

(3)
the SEC, by order, permits us to defer action in order to protect persons with interests in the Separate Account.

Assignments

This contract is an IRA and you are not legally permitted to assign, pledge or otherwise transfer the contract. Pledging or assigning an IRA can cause loss of qualified status and result in some or all of the Account Value being included in your income. A 10% federal tax penalty also may apply.

Death Benefit

We will pay the Death Benefit to your properly designated beneficiary if you die before the Annuity Date.

The Death Benefit amount will be the greater of:
1.
the Account Value on the Death Benefit Date; and

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2.
your total premiums minus proportionate adjustments for partial withdrawals, including any withdrawal charge. A proportional adjustment means that your Death Benefit will be reduced by the same percentage as your withdrawal bears to your Account Value at the time of withdrawal.

Example of the effect of withdrawals on the Death Benefit:
if your Death Benefit is $100,000 and your current Account Value is $80,000,
and you take a withdrawal of $10,000,
we will reduce your Death Benefit by 12.5% because that is the same percentage that your withdrawal bears to the Account Value at the time of the withdrawal
($10,000 / $80,000);
therefore, your Death Benefit is reduced by $12,500.

Because the Account Value at the time of the withdrawal in this example is less than the Death Benefit, the Death Benefit is decreased by a larger dollar amount than the partial withdrawal amount.

This example is for illustrative purposes only and does not predict results.

Your beneficiary generally has a choice of how to receive the Death Benefit.

1.
The beneficiary may take a lump sum. If the beneficiary elects this option, we will pay the Death Benefit to the beneficiary.

2.
The beneficiary may defer for up to five years. If the beneficiary elects this option, we will allow the beneficiary to keep the Death Benefit invested in the available Subaccounts for a period of up to five years. Separate account charges will continue to apply. At the end of five years, the entire amount must be paid to the beneficiary.

3.
The beneficiary may treat the contract as an inherited IRA. If the beneficiary elects this option, we will allow the beneficiary to keep the Death Benefit amount invested in the available Subaccounts. Separate account charges will continue to apply. The beneficiary must choose to receive the Death Benefit as either:

a)
an immediate annuity with a life contingency; or
b)
substantially equal payments over his or her life expectancy or other payout period as defined by the Tax Code. Certain beneficiaries may choose the longer of his or her life expectancy or the deceased owner’s life expectancy (both as defined by the Tax Code) if the owner dies after the Required Beginning Date; for other beneficiaries, the payout period may be limited to 10 years. (For Roth IRAs, the owner is presumed to have died before the Required Beginning Date.)

Distributions must begin by December 31 of the calendar year after the owner’s death; however if the beneficiary is your spouse and has elected this option, distributions may begin at the end of the calendar year in which the owner would have reached the qualified age under IRS regulations, if later. A spouse also may elect to continue the contract as described below in the section titled “Spousal Continuation.” If the beneficiary fails to make an election within a reasonable time, we may automatically process the claim as if option two were elected.

The following restrictions apply to the inherited IRA contract: (i) the inherited IRA owner may not add premium to the contract; (ii) the Death Benefit available to the beneficiary of the inherited IRA owner is the Account Value on the Death Benefit Date after the death of the inherited IRA owner; and (iii) the beneficiary of the inherited IRA owner will be required to receive the remaining Account Value either in a lump sum, over five years or over the life expectancy of the inherited IRA owner as determined by the Tax Code.

For more information on inherited IRAs, see Part 8, section titled “Inherited IRAs” and IRS Publication 590. You should seek independent tax advice.


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If your beneficiary is not a human being, the beneficiary must elect either a lump sum or deferral for up to five years. If the owner is a trust, custodian or other entity, the owner must name itself as the sole beneficiary.

Spousal Continuation

If your sole primary beneficiary is your spouse, the contract may be continued in your spouse’s name as the owner. If spousal continuation is elected, we will increase the continued contract’s Account Value to the same amount that would have been paid to your surviving spouse had he or she taken the Death Benefit as a lump sum distribution. This increase will be added to the Subaccounts you have selected on a pro rata basis. For example, if the Account Value at death was $100,000, but we would have paid out a Death Benefit of $115,000, the surviving spouse’s contract will continue with $115,000 as the Account Value.

All terms and conditions of the contract continue to apply including the withdrawal charge. When the surviving spouse dies, the Death Benefit will be paid to the beneficiary named by the surviving spouse.

A same-sex surviving spouse is recognized as your spouse under the Tax Code and will qualify for the federal tax advantages of spousal continuation.

The survivor of a civil union or domestic partnership is not recognized as your spouse under the Tax Code and the federal tax advantages of spousal continuation are not available. The survivor of a civil union or domestic partnership may elect to continue the contract under its terms. The continuation of the contract by such surviving civil union or domestic partner, however, is treated as an ordinary transfer of ownership and will be a taxable event.

Selecting and Changing Your Beneficiary

You may name one or more beneficiaries as primary or contingent beneficiaries. The Death Benefit will be paid to your primary beneficiaries who are alive at the time of your death. If no primary beneficiary survives your death, then the Death Benefit will be paid to your contingent beneficiaries, if any. If no beneficiary survives your death (primary or contingent) or none has been named, the Death Benefit will be paid to your estate.

If multiple beneficiaries in either category (primary or contingent) are named, the Death Benefit will be split into equal shares among the beneficiaries in that category who are alive at the time of your death, unless you specify otherwise in your beneficiary designation.

If you die on or after the Annuity Date and before the entire interest in the contract has been distributed, then the rest of the annuity must be distributed to the beneficiary at least as quickly as the method in effect when you died.

You may change any beneficiary by sending the appropriate form in Good Order to the Administrative Office. We may limit the number of beneficiaries you can have at one time. Please consult your financial professional and tax advisor to properly identify your beneficiaries so that the Death Benefit is paid as you intend. Please be sure to name your spouse as your sole primary beneficiary so that spousal continuation of the contract can occur, if that is your intention. You may wish to name a contingent beneficiary in case your spouse dies before you. If the owner is a custodian, the owner must name itself as the sole beneficiary.

Filing Death Claims

To file a death claim, the beneficiary must promptly submit an original certified death certificate and company death claim paperwork that is in Good Order, including the beneficiary's election of how they wish to receive the Death Benefit proceeds. On the date we first receive notice of the owner’s death, we will stop all pending automatic transactions including rebalancing and systematic withdrawals; however, any money in the STO will be transferred to the Subaccounts according to the owner’s allocation.

During the period from the date of death until we receive all required paperwork in Good Order, the Account Value will remain invested in the Subaccounts as allocated by you at the time of your death. As a result, the Account Value continues to reflect the investment performance of the Subaccounts during this period and will be subject to market fluctuations. Separate account charges will continue to apply.


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If there are multiple beneficiaries, after one beneficiary submits death claim paperwork, the Death Benefit will be calculated and the first beneficiary will receive payment according to his or her election. The remaining beneficiaries’ share of the Death Benefit will be invested in the Subaccounts as allocated by you at the time of your death and subject to market fluctuations.

Maturity Date and Annuity Option

Your Annuity Option is available anytime on or after your first Contract Anniversary until the Maturity Date. You may elect your Annuity Option by writing to the Administrative Office any time on or after your first Contract Anniversary and before the Maturity Date. Upon the Maturity Date, you may elect to receive a lump sum of your Account Value, or you may elect an Annuity Option.

An Annuity Option can provide for fixed payments, which may be made monthly, quarterly, semi-annually or annually. For any annuity, the minimum payment must be at least $100. If the minimum monthly payment under a guaranteed Annuity Option would be less than $20, we will pay you a lump sum of your Account Value instead. All Annuity Options are funded through our General Account.

The amount applied toward the purchase of a guaranteed Annuity Option under the contract will be the Account Value less any premium tax. The guaranteed Annuity Options are single life and ten years certain or joint life and ten years certain. These options provide a fixed life income annuity with 10 years of payments guaranteed.

We will also use the Account Value less any premium tax to determine your annuity payments if you select a nonguaranteed Annuity Option with either (i) life contingencies, or (ii) a period certain that provides for fixed payments over ten or more years. If you select any other nonguaranteed Annuity Option, the amount applied to determine your annuity payments will be the Surrender Value, or if this Contract is issued in New York, the amount applied to determine your annuity payments under (ii) above will be the greater of the Surrender Value or 95% of your Account Value.

We currently offer additional Annuity Options listed below; however, we may eliminate or change the non-guaranteed options available at any time:

period-certain annuity, which provides for fixed payments for a fixed period. The fixed periods available may vary from time to time and the fixed period selected may not extend past your life expectancy. The amount is determined by the period you select. If the Annuitant dies before the end of the period selected, the beneficiary will receive the remaining periodic payments.
period-certain life annuity, which provides for fixed payments for at least the period selected and after that for the life of the Annuitant or the lives of the Annuitant and any joint Annuitant under a joint and survivor annuity. The fixed periods available may vary from time to time. If the Annuitant (or the Annuitant and the joint Annuitant under a joint and survivor annuity) dies before the fixed period selected ends, the remaining payments in the fixed period will go to the beneficiary.
life only annuity, which provides fixed payments for the life of the Annuitant, or until the Annuitant and joint Annuitant both die under a joint and survivor annuity. Once the Annuitant (or last joint Annuitant) dies, no further payments will be made and no value remains for any beneficiaries.

If you have not already selected a form of Annuity Option, we will contact you prior to your Maturity Date. You can tell us at that time if you would like a lump sum payment, or select the type of annuity you want. If we do not receive your election on or before your Maturity Date, you will automatically receive the single life and ten-year certain Annuity Option guaranteed under the contract.

Annuity Payments

Once payments begin under an Annuity Option, payments will not change. The size of payments will depend on the amount applied to the Annuity Option, the form of Annuity Option you chose and, in the case of an Annuity Option with life contingencies, on the Annuitant's age and sex (where permissible).


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If the age or sex of an Annuitant has been misstated, you will receive the benefits that would have been purchased at the correct age and gender. Any overpayments or underpayments made by us will not be charged or credited with interest, unless required by your state. If we have made overpayments because of incorrect information about age or gender, we will deduct the overpayment from the next payment or payments due. We add underpayments to the next payment.

How You Make Requests and Give Instructions

When you write to our Administrative Office, use the address listed in the Glossary of this prospectus. We cannot honor your requests unless they are in proper and complete form. Whenever possible, use one of our printed forms, which may be obtained from our Administrative Office.

Abandoned or Unclaimed Property

Every state has laws that generally provide for payment to the state of unclaimed property, including proceeds of annuity contracts, under various circumstances.  This is called escheatment.  In addition to the state unclaimed property laws, we may be required to escheat property pursuant to regulatory demand, finding, agreement or settlement. To help prevent escheatment, it is important that you keep your contact information on file with us up to date, including the names, addresses, phone numbers, social security numbers and dates of birth for owners, annuitants, beneficiaries and other payees.  Such updates must be communicated in Good Order to our Administrative Office.

Part 6 – Optional Benefits

You may purchase one of the optional GLWB Riders offered with this contract, which provides additional benefits for an additional charge. You may only elect a Rider at the time of application. Benefits under a Rider will replace or supplement the standard contract benefits. Charges for an optional benefit Rider are in addition to the standard contract charges. Be sure you understand the charges. Carefully consider whether you need the benefit and whether it is appropriate for your particular circumstances. Also consider whether you can buy the benefit more cheaply as part of the variable annuity or with a separate contract.

Guaranteed Lifetime Withdrawal Benefit

Each Guaranteed Lifetime Withdrawal Benefit (GLWB) is an optional Rider you may purchase for an additional charge. You may select the Individual GLWB Rider or the Spousal GLWB Rider.

The GLWB Rider guarantees lifetime payments for you (or you and your covered spouse if you elect the Spousal GLWB Rider) regardless of how your investments perform, as long as the Rider is in effect. You are the covered person under the Individual GLWB Rider. You and your spouse are the covered persons under the Spousal GLWB Rider. If you take Nonguaranteed Withdrawals, as explained below, your Benefit Base will decrease immediately, your lifetime payments may decrease and the Rider may terminate.

Lifetime Payout Amount (LPA)
The LPA is the amount we guarantee you can receive each calendar year for your lifetime (or for as long as either you or your covered spouse is alive if you elect the Spousal GLWB Rider). You are eligible to begin receiving your LPA on the LPA Eligibility Date.

For the Individual GLWB Rider, the LPA Eligibility Date is the earlier of the following:
January 1st after the calendar year in which you turn age 60 (if you turn age 60 on January 1st, your LPA will be available beginning on that day); or
the Contract Date, if you are age 60 or older at the time you purchase your contract. The LPA available during the calendar year in which you purchase your contract will be prorated for the portion of the calendar year remaining.

For the Spousal GLWB Rider, the LPA Eligibility Date is the earlier of the following:

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January 1st after the calendar year in which the younger of you or your spouse turns age 60 (if the younger of you or your spouse turns age 60 on January 1st, your LPA will be available beginning on that day); or
the Contract Date, if the younger of you or your spouse is age 60 or older at the time you purchase your contract. The LPA available during the calendar year in which you purchase your contract will be prorated for the portion of the calendar year remaining.

The LPA is equal to the applicable Withdrawal Percentage multiplied by the Benefit Base on January 1st each year on or after the LPA Eligibility Date. For the Spousal GLWB Rider, that amount is then multiplied by 90% (this 90% is called the Spousal Factor).

Withdrawal Percentage - The applicable Withdrawal Percentage is determined by the following formula:

A + B + C, where:

(A)
is the Age Based Percentage stated on the chart below:
Age*
Age Based Percentage
60-64
4.00%
65-69
4.50%
70-74
5.00%
75 and above
5.50%

*The Age Based Percentage is determined by your age (or the age of the younger of you or your spouse if you have elected the Spousal GLWB Rider). The Age Based Percentage is locked in on the date of the first withdrawal from the contract on or after the LPA Eligibility Date.

(B)
is the cumulative Deferral Percentage. The cumulative Deferral Percentage begins at zero and increases by 0.10% for each complete calendar year that you do not take a withdrawal.

(C)
is a First-Year Deferral Percentage stated on the chart below:
Contract Date
First-Year Deferral Percentage
January 1-March 31
0.075%
April 1-June 30
0.050%
July 1-September 30
0.025%
October 1-December 31
0.000%

The First-Year Deferral Percentage is a one time addition to your Withdrawal Percentage that varies based on your Contract Date, provided you do not take a withdrawal in the calendar year containing the Contract Date.

Benefit Base - Your initial Benefit Base is equal to your initial premium received by us on the Contract Date. Your Benefit Base will be adjusted as follows:

1.
On each Contract Anniversary, your Benefit Base will be compared to your Account Value and if the Account Value is greater than the Benefit Base, we will step up your Benefit Base to equal the Account Value.
2.
If you take a Nonguaranteed Withdrawal, we will immediately decrease your Benefit Base as described in the section titled “Nonguaranteed Withdrawal” below.
3.
On the date we receive an additional premium during the first Contract Year, we will immediately increase your Benefit Base by the amount of the additional premium. Additional premiums received after the first Contract Year will not increase your Benefit Base. They will, however, increase the Account Value, which is used to determine if a step up applies on the next Contract Anniversary.

The Benefit Base is used only to calculate the LPA and Rider charge. The Benefit Base is not available for withdrawal or payable as a death benefit.


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If you (or the younger of you and your spouse if you have elected the Spousal GLWB Rider) have reached the LPA Eligibility Date on the Contract Date, your LPA for the calendar year that contains the Contract Date will be prorated for the portion of the calendar year remaining. The factor used to prorate the LPA is the number of days remaining in the calendar year (not including the Contract Date) divided by the number of days in the calendar year.

If you withdraw less than the LPA in any calendar year, you cannot carry over or add the remaining LPA to withdrawals made in future years.

If your RMD is greater than the LPA for any calendar year, the LPA will be set equal to the RMD for that calendar year as long as calendar year withdrawals are limited to the RMD.

Nonguaranteed Withdrawal
Before your LPA Eligibility Date, a Nonguaranteed Withdrawal is the total amount of any withdrawal, including any withdrawal charge.

On or after your LPA Eligibility Date, a Nonguaranteed Withdrawal is all or a portion of any withdrawal, including any withdrawal charge, that, when combined with your total withdrawals for that calendar year, exceeds your LPA.

If you take a Nonguaranteed Withdrawal, your Benefit Base will immediately decrease by the adjusted Nonguaranteed Withdrawal amount. The adjusted Nonguaranteed Withdrawal amount is defined as the Nonguaranteed Withdrawal amount multiplied by the greater of 1.0 and the ratio of Benefit Base to Account Value (Benefit Base divided by Account Value), where both values are determined immediately before the Nonguaranteed Withdrawal. The Account Value immediately before the Nonguaranteed Withdrawal means that the Account Value will be reduced by any remaining LPA prior to the calculation.
Taking Nonguaranteed Withdrawals could reduce your future benefits by more than the dollar amount of the Nonguaranteed Withdrawals.

The example below demonstrates how a Nonguaranteed Withdrawal affects the Benefit Base, using the following assumptions:

Individual GLWB in effect
Benefit Base = $100,000
Account Value = $85,000
LPA = $5,000
One withdrawal is taken during the calendar year = $7,000
Withdrawal taken after LPA Eligibility Date
No withdrawal charge applies.

The Nonguaranteed Withdrawal amount is $2,000, which is equal to your total calendar year withdrawals ($7,000) minus your LPA ($5,000). The adjusted Nonguaranteed Withdrawal is $2,500:

$2,500 = $2,000 (Nonguaranteed Withdrawal amount) x the greater of 1.0 or [$100,000 (Benefit Base immediately before the Nonguaranteed Withdrawal) / $80,000 (Account Value immediately before the Nonguaranteed Withdrawal)]

Your Benefit Base will be reduced by $2,500 to $97,500.

Other Important Facts about Withdrawals

You will not receive the intended benefit of this Rider if you take Nonguaranteed Withdrawals. Nonguaranteed Withdrawals can have a significant negative effect on your Benefit Base and your LPA.

A withdrawal charge may apply. If you withdraw more than your Free Withdrawal Amount (10% of the Account Value in any Contract Year) but the withdrawal does not exceed your LPA, any applicable withdrawal charge will be waived. If you withdraw more than the Free Withdrawal Amount and any portion of the

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withdrawal is a Nonguaranteed Withdrawal, a withdrawal charge, if any, will be applied on the entire amount that is greater than the Free Withdrawal Amount. See Part 4, “Withdrawal Charge” and Part 5, “Withdrawals." Following is an example of how a withdrawal charge may apply:

Assume:
Individual GLWB in effect
Premium:                        $40,000
Account Value before withdrawal:            $18,000
Withdrawal charge percentage applicable to premium:    6%
Lifetime Payment Amount:                $ 2,000

Case 1: Owner requests withdrawal of $2,000 (LPA)
The Free Withdrawal Amount is calculated as $18,000 x 10% = $1,800. The $2,000 requested withdrawal is greater than the remaining Free Withdrawal Amount; however, it does not exceed the LPA. No withdrawal charge will apply.

Case 2: Owner requests withdrawal of $2,500
The Free Withdrawal Amount is $1,800. Since the requested withdrawal exceeds the LPA, withdrawal charges will apply. After applying the withdrawal first to the Free Withdrawal Amount, this leaves $700 ($2,500 - $1,800), which will be subject to a withdrawal charge of $42 ($700 x 6%).

Withdrawals must be taken pro rata from your Investment Options. You cannot make a withdrawal from specific Investment Options.

You may not take a withdrawal on your Contract Date.

If you request a withdrawal, we will withdraw the total amount you requested from your Account Value, however the amount you receive will be net of tax withholding and withdrawal charge, if applicable.

You must use our withdrawal form to request withdrawals. Contact our Administrative Office to obtain the form.

GLWB Rider Charge
The GLWB Rider charge is a daily charge taken from the Account Value in your Subaccounts. The charge is in addition to the separate account charges for the contract and reduces your Unit Values. The charge varies depending on which GLWB Investment Strategy you choose. The following table shows the effective annual rates for the Rider charge:

GLWB Investment Strategy
Current GLWB Charge
Current GLWB Charge with Total Separate Account Expenses
Strategy 1 – Basic Allocation
0.60%
2.35%
Strategy 2 – Self Style Allocation
0.80%
2.55%

We may increase the annual charge for the GLWB Rider up to the maximum of 1.50%. The maximum GLWB charge with total separate account charges is 3.25% for either GLWB Investment Strategy.

If we do increase the charge, we will give you prior written notice of each increase. If you do not wish to accept an increase, you may elect to either

cancel the Rider; or
continue the Rider with a reduction in the Withdrawal Percentage as determined by us, effective at the time of the Rider charge increase. The maximum reduction in the Withdrawal Percentage is 1.00%, regardless of the number of Rider charge increases.

We do not deduct the Rider charge during the Guaranteed Payment Phase.


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The GLWB Rider charge is the same for the Individual GLWB Rider and the Spousal GLWB Rider. The LPA is adjusted downward – by the Spousal Factor of 90% – for the Spousal GLWB Rider instead of an additional charge.

GLWB Investment Strategies
If you purchase a GLWB Rider, you must allocate your premium to only one of the two GLWB Investment Strategies described below. Once you select a GLWB Investment Strategy, you cannot switch to another GLWB Investment Strategy. As a result of the GLWB Rider investment restrictions, you will always have some degree of exposure to the market. You cannot eliminate this exposure even during periods of market volatility. These GLWB Investment Strategies are designed for long-term investors seeking withdrawal guarantees. (Note that the Subaccounts available in the GLWB Investment Strategies are also available without the Rider.)

The GLWB Investment Strategies are intended in part to reduce the risk of investment losses that could require us to use our own assets to make payments under the GLWB Rider. The GLWB Investment Strategies are designed to lower the volatility of returns from your Subaccounts. Subaccounts that are available without limitation (if the GLWB Rider is not selected) may offer the potential for higher returns. Before you select the GLWB Rider, you and your financial representative should carefully consider whether the GLWB Investment Strategies available with the Rider meet your investment objectives and risk tolerance.

GLWB Investment Strategy 1 Basic Allocation
You must allocate your premium according to one of the three models: Blend, Growth or Value. You may reallocate from one model to another, as discussed below.

Subaccount
Model 1 - Growth
Model 2 - Blend
Model 3 - Value
iShares Core S&P 500 ETF
30%
40%
30%
iShares Core S&P Mid-Cap ETF
10%
10%
10%
iShares Core S&P Small-Cap ETF
5%
5%
5%
iShares International Treasury Bond ETF
5%
5%
5%
iShares S&P 500 Growth ETF
10%
 
 
iShares S&P 500 Value ETF
 
 
10%
Vanguard Developed Markets Index Fund, ETF Shares
5%
5%
5%
Vanguard Total Bond Market Index Fund, ETF Shares
35%
35%
35%

GLWB Investment Strategy 2 Self Style Allocation
You may select one or more of the Subaccounts in two or more groups, as long as your allocations add up to 100% and are within the minimum and maximum allocation percentages indicated for each group.


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Group 1
Core Fixed Income

Group 2
Core Equity

Group 3
Non-Core Fixed Income

Group 4
Non-Core Equity

Group 5
International/Alternative


Minimum 35%
Maximum 65%
Minimum 35%
Maximum 65%
Minimum 0%
Maximum 30%
Minimum 0%
Maximum 30%
Minimum 0%
Maximum 15%
iShares Core U.S. Aggregate Bond ETF
iShares Core S&P 500 ETF
iShares iBoxx $ High Yield Corporate Bond ETF
iShares Core S&P Mid-Cap ETF

iShares International Treasury Bond ETF
iShares Intermediate-Term Corporate Bond ETF
Vanguard Dividend Appreciation Index Fund, ETF Shares
iShares TIPS Bond ETF
iShares Core S&P Small-Cap ETF
Vanguard Developed Markets Index Fund, ETF Shares
Vanguard Total Bond Market Index Fund, ETF Shares
Vanguard Large-Cap Index Fund, ETF Shares
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares
iShares S&P 500 Growth ETF
Vanguard Emerging Markets Stock Index Fund, ETF Shares
 
 

Vanguard Short-Term Bond Index Fund, ETF Shares
iShares S&P 500 Value ETF
Vanguard Real Estate Index Fund, ETF Shares
 
 
Fidelity VIP Government Money Market Portfolio
Vanguard Mega Cap Index Fund, ETF Shares
 

For more information about these Subaccounts, including information relating to their investment objectives and policies, and the risks of investing, see Part 3, as well as the Fund prospectuses. You can obtain a copy of the Fund prospectuses by contacting our Administrative Office listed in the Glossary. You should read the Fund prospectuses carefully before investing.
 
In addition to your allocation to one of the two GLWB Investment Strategies, you may invest some or all of your initial premium received by us on the Contract Date in the STO. Transfers from the STO to the Subaccounts must be according to GLWB Investment Strategy and allocation you have selected. See Part 3, section titled “The Fixed Account” for more information about the STO.

Subject to required approvals by federal and state authorities, we may add, remove, change, close, substitute or limit investment in the GLWB Investment Strategies or the Subaccounts at any time.

Allocations and Transfers for the GLWB
In addition to the allocation and transfer rules under the contract (See Part 5, section titled "Allocations and Transfers"), the following additional rules and limitations apply to your allocations and transfers:

Your one allocation allowed on the contract must meet the requirements of one of the two GLWB Investment Strategies.
Your Account Value will be automatically rebalanced to your allocation percentages each contract quarter.
You cannot move from one GLWB Investment Strategy to another.
In GLWB Investment Strategy 1, you can reallocate your Account Value invested in one model to another model. The reallocation will reset your Account Value to the required percentages for the new model. Each reallocation triggers the 60-day waiting period before you can make another reallocation.
In GLWB Investment Strategy 2, you can reallocate your Account Value invested in Strategy 2 as long as your new allocation is within the minimum and maximum allocation percentages for each group. Each reallocation triggers the 60-day waiting period before you can make another reallocation.

Your financial professional or a third party may have offered you asset allocation or investment advisory services related to this annuity contract or Rider for an additional fee to be deducted from your contract. Such fees are considered withdrawals and could cause a Nonguaranteed Withdrawal. Therefore, if you purchase a GLWB Rider, we do not recommend using this annuity contract to pay for such services.

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Withdrawal Protection for Required Minimum Distributions
If your contract is a traditional IRA or a SEP IRA, you may be required to withdraw money in order to satisfy minimum distribution requirements imposed by the Tax Code after you reach the qualified age under IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72).

We will calculate the RMD for this annuity contract based on its prior calendar year-end fair market value. We do not consider your other assets or distributions in making this calculation. This is the RMD protected under the GLWB Riders except if you elect the spousal Rider, and your spouse is more than 10 years younger than you. In that case, due to your age difference, you will be required to take your RMD for this annuity contract before the LPA Eligibility Date; if you take your RMD from this contract’s Account Value, each withdrawal will be a Nonguaranteed Withdrawal until the LPA Eligibility Date is reached. You are solely responsible for meeting all requirements of the Tax Code.

After the LPA Eligibility Date, you may take the greater of your LPA or your RMD each calendar year. In the year you turn the qualified age the Tax Code provides that you may take your first RMD prior to April 1st of the following calendar year; however, with a GLWB Rider, you must take your first annual RMD in the calendar year you turn the qualified age in order to avoid a potential Nonguaranteed Withdrawal.

We may make any changes we deem necessary to comply with the tax laws. We are not liable for any tax consequences you incur arising from this contract or your obligations under the Tax Code. You should discuss these matters with your tax advisor prior to electing a GLWB Rider.

Continuation of the Spousal GLWB at Owner’s Death
Married spouses – If your covered spouse is recognized under the Tax Code, including same-sex spouses, he or she will have the option to continue the contract and the GLWB Rider at the time of your death. Your covered spouse will become the owner and Annuitant of the contract and all terms and conditions of the contract continue to apply. See Part 5, section titled “Spousal Continuation.”

Civil Union or Domestic Partners – for civil union or domestic partners as defined by state law, the covered partner may continue to receive the LPA under the terms of the Rider. Due to federal tax laws, however, not all terms of the contract can be applied. If the covered partner wishes to continue receiving the LPA, he or she must elect to treat the contract as an inherited IRA. See Part 5, section titled “Death Benefit.” All provisions of the contract and the GLWB Rider still apply, except (i) the covered partner must take at least the RMD each calendar year (caution: this may cause a Nonguaranteed Withdrawal if the LPA Eligibility Date has not been reached); (ii) the covered partner cannot add premium to the contract; (iii) the Death Benefit available to the beneficiary of the covered partner is limited to the Account Value on the Death Benefit Date; and (iv) the beneficiary of the covered partner will be required to receive the remaining Account Value either in a lump sum, over five years or over the life expectancy of the covered partner as determined by the Tax Code. These restrictions are required by the Tax Code.

Guaranteed Payment Phase
The Guaranteed Payment Phase begins on or after the LPA Eligibility Date if either:
Before the Maturity Date, the Account Value reduces to zero (other than as a result of a Nonguaranteed Withdrawal or the voluntary election of an Annuity Option).
On the Maturity Date, you elect to continue to receive annual payments equal to the then current LPA through a life only Annuity Option (or joint life if you have elected the Spousal GLWB Rider and both you and your covered spouse are still living.) If you do not elect the LPA Annuity Option, you will automatically receive a single life and 10-year certain Annuity Option under your Contract.

When the contract begins the Guaranteed Payment Phase, we will send you a written notice and any remaining LPA that you have not taken during the current calendar year. (If your contract enters the Guaranteed Payment Phase on the Maturity Date, we will set your Account Value to zero.) Beginning the next calendar year, and in each calendar year during the Guaranteed Payment Phase, you will receive your LPA. The Guaranteed Payment Phase will continue until the death of the owner (or owner and covered spouse if the Spousal GLWB is elected).


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Once the Guaranteed Payment Phase begins, all other rights, benefits, values and charges under the contract and the GLWB Rider will terminate, except those described in this section and in the "Cancellation and Termination of Rider" section below. The Guaranteed Payment Phase will end if the Rider terminates. See "Cancellation and Termination of Rider" section below. We should be notified immediately upon the death of the owner (or covered spouse if the Spousal GLWB is elected).

Cancellation and Termination of Rider
You may cancel the Rider during the first 45 days of each Contract Year beginning on the fifth Contract Anniversary. Upon termination of the Rider, the Rider charge will no longer be assessed. All other charges will remain in effect.

This Rider will terminate automatically on the earliest of the following dates:
1.
for the Individual GLWB Rider, the date you die, and for the Spousal GLWB Rider, the date the later of you or your covered spouse dies;
2.
the date the Account Value equals zero due to a Nonguaranteed Withdrawal;
3.
the date that ownership of the contract or Rider is transferred or the contract, Rider or any benefits under the contract or Rider are assigned unless: in New York, the new owner is a covered person; in New Hampshire and Vermont the new owner assumes full ownership of the contract and is essentially the same person as the current owner (e.g. a change to a court appointed guardian representing the owner during the owner’s lifetime) or the new owner is a covered person;
4.
on the Maturity Date, unless you elect to receive your LPA through a life only Annuity Option, or joint life only Annuity Option if you have elected the Spousal GLWB Rider and your covered spouse is still living;
5.
the date you voluntarily elect an Annuity Option under the contract;
6.
the date you cancel the GLWB Rider; or
7.
the date you surrender the contract.

Once cancelled or terminated, this Rider may not be reinstated.

Additional Rules
The following additional rules apply if you elect a GLWB Rider:

You must be between 45 and 80 years old on the Contract Date in order to elect the Individual GLWB Rider. In order to elect the Spousal GLWB Rider, the younger of you or your spouse must be at least 45 years old and the older of you or your spouse must be no more than 80 years old on the Contract Date.
The Company may refuse to accept additional premiums on a nondiscriminatory basis at any time.
We may require proof that you (or your covered spouse) are living at any time.
You cannot switch from an Individual GLWB Rider to a Spousal GLWB Rider or vice versa.
Income Plus Withdrawal Program is not available.
Choices Plus Required Minimum Distribution Program is not available.
Customized Asset Rebalancing Program is not available.
Systematic withdrawal of RMD only is not available.

Additional Rules that Apply to the Spousal GLWB Rider
1.
Only your legal spouse (as defined by applicable state law) on the Contract Date may be named as a covered person under the Spousal GLWB Rider.
2.
You must name your spouse as your sole primary beneficiary.
3.
You cannot add or change a spouse as a covered person.
4.
If your marriage is terminated (such as by divorce or dissolution) or your spouse dies, your spouse is automatically removed as a covered person. If you subsequently remarry, you cannot add the new spouse.
5.
You must provide us with notice of the divorce or termination of marriage.
6.
Once the spouse is removed as a covered person, lifetime withdrawals under the Spousal GLWB Rider are no longer guaranteed for the lives of both you and your spouse. (If a spouse is removed, you can name a new beneficiary to receive the Death Benefit.)
7.
If a spouse is removed and is no longer a covered person, the LPA Eligibility Date and the Age Based Percentage are still based on the younger of you or your (now removed) spouse.
8.
If a spouse is removed and is no longer a covered person, the Spousal Factor of 90% will continue to apply to your LPA calculation.


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Should You Purchase the GLWB Rider?
The addition of a GLWB Rider to your annuity contract may not be right for you. For example:

if you are purchasing the GLWB Rider to meet income needs, you should consider whether an immediate annuity is better suited to your situation;
if you do not expect to take withdrawals while this Rider is in effect, you do not need a GLWB Rider because the benefit is accessed through withdrawals; or
if you are likely to need to take withdrawals prior to your LPA Eligibility Date or in an amount that is greater than the LPA or RMD for this contract only, you should carefully evaluate whether a GLWB Rider is appropriate, due to the negative effect of Nonguaranteed Withdrawals on your Benefit Base.
If your spouse is 10 or more years younger than you, the Spousal GLWB Rider may not be suitable for you.

Benefits paid may not exceed the charges associated with the Rider depending on how long the covered person lives.

You should consult with your tax advisor and financial representative and carefully consider your alternatives before deciding if a GLWB Rider is suitable for your needs.

Examples
Please see Appendix C for hypothetical examples that illustrate how the GLWB Riders work.

Part 7 – Voting Rights

How Fund Shares Are Voted

National Integrity Life is the legal owner of the Fund shares held by the Separate Account. As a shareholder, we have the right to vote on certain matters with respect to the Funds. Among other things, we may vote to elect the Fund’s Board of Directors, to ratify the selection of independent auditors, and on any other matters described in a current prospectus or statement of additional information for each Fund, or any matter requiring a vote by shareholders under the 1940 Act.

Whenever a shareholder vote is taken, we will give you the opportunity to tell us how to vote the number of shares attributable to the Units in your contract. We will send you proxy materials and a form for giving us voting instructions.

If we do not receive instructions in time from all contract owners, we will vote shares for which we have not received instructions in the same proportion as we vote shares for which we have received instructions. As a result of this proportional voting, the vote of a small number of contract owners may determine the outcome of a proposal. We may vote any shares that we are entitled to vote directly, because of amounts we have accumulated in our Separate Account, as we deem appropriate. If the federal securities laws or regulations or interpretations of them change so that we are permitted to vote shares in our own right or to restrict contract owner voting, we may do so.

Fund shares are sold to investors other than us. Therefore, the shares voted by all shareholders will dilute the effect of voting instructions received by us from our contract owners.

How We Determine Your Voting Shares

You vote only on matters concerning the Funds that correspond to the Subaccounts in which you are invested on the record date set by the Trust. We determine the number of shares you vote by dividing your Account Value in each Subaccount by the total value of assets in the Subaccount multiplied by the number of shares in the Subaccount.


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Part 8 – Tax Aspects of the Contract

Tax Status of the Contract

This contract is only available as a traditional IRA, Roth IRA, or SEP IRA. If you were able to purchase this contract as other than an IRA, the contract would not satisfy the diversification requirements under federal tax law to be treated as an annuity contract for federal income tax purposes, and you would be currently taxed on your investment and gain.

Variable annuity contracts (other than certain pension and qualified retirement plan contracts, including IRAs) are generally not treated as annuities for federal income tax purposes, and thus lose their tax-deferred character, if they do not satisfy certain diversification requirements set forth in Section 817(h) of the Tax Code. Investing in the ETF shares that are "publicly available," i.e., that can be purchased directly without purchasing a variable annuity or life insurance contract, is incompatible with these requirements. Accordingly, standing alone, the contract would not be treated as an annuity contract for federal income tax purposes. However, we believe that an individual purchasing a contract as an IRA will not be taxed currently on the investment and gain.

Contracts that qualify as IRAs are not subject to restrictions against investing in publicly available investments if the contracts meet certain requirements set forth by the IRS. We believe this contract will meet those requirements, although there is no guarantee that this will be the case. If this contract is not maintained as an IRA, the taxes on the contributions and any income or gain on the investments will not be deferred (or for a Roth IRA, taxes on the income and gain will not be free from federal income tax) and the tax treatment will be uncertain.

Types of IRAs

Traditional IRAs
Section 408 of the Tax Code permits eligible individuals to contribute to an individual retirement program known as an IRA. An IRA can be in the form of a trust or custodial account or an annuity. An individual may make annual contributions to an IRA of up to the lesser of the limit specified in the Tax Code ($6,000 for 2019 and subject to annual cost-of-living adjustments for later years) or 100% of compensation includible in the individual's gross income. For an individual age 50 or older, the limit is increased by $1,000. The contributions may be deductible in whole or in part, depending on the individual's income and whether the individual or spouse participates in an employer sponsored retirement plan. Contribution limits set by the Tax Code are cumulative limits that apply to all traditional and Roth IRAs owned by an individual. Distributions from another IRA or certain eligible employer plans may be transferred or "rolled over" into an IRA on a tax-deferred basis without regard to these limits. Amounts in the IRA are taxed when distributed from the IRA at ordinary income tax rates. A 10% penalty tax (discussed below) generally applies to distributions made before age 59½, subject to certain exceptions. IRAs have minimum distribution rules (also discussed below) that govern the timing and amount of required distributions from traditional IRAs.

SEP IRAs
Section 408 of the Tax Code permits SEP IRAs, which are a type of IRAs that allows employers to contribute to IRAs on behalf of their employees. Employer contributions made to an employee's SEP IRA cannot exceed the lesser of (1) 25% of the employee's compensation, and (2) a limit specified in the Tax Code ($56,000 for 2019, subject to annual cost-of-living adjustments for later years). Distributions from SEP IRAs are subject to the same restrictions and rules that apply to IRA distributions.

Roth IRAs
Section 408A of the Tax Code permits certain eligible individuals to make non-deductible contributions to a Roth IRA in cash or as a rollover or transfer from another Roth IRA or other IRA. Only individuals with income below certain amounts specified in the Tax Code may contribute to a Roth IRA. An eligible individual may make annual contributions to a Roth IRA of up to the lesser of the limit specified in the Tax Code ($6,000 for 2019 and subject to annual cost-of-living adjustments for later years) or 100% of compensation includible in the individual's gross income. For an individual age 50 or older, the limit is increased by $1,000. Contribution limits set by the Tax Code are cumulative limits that apply to all traditional and Roth IRAs owned by an individual. A rollover from, or conversion of, an IRA to a Roth IRA is generally subject to tax on the full amount rolled over or converted.

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You should consult a tax advisor before converting amounts to a Roth IRA or combining any converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years.

Distributions from a Roth IRA generally are not taxed, except that, once aggregate distributions exceed contributions to the Roth IRA, income tax and a 10% penalty tax (discussed below) may apply to distributions made (1) before age 59 1/2 (subject to certain exceptions), or (2) during the five taxable years starting with the year in which the first contribution is made to the Roth IRA or, in general, any other Roth IRA.

Rollovers and Transfers

In many circumstances you may move money tax-free from one IRA to another IRA or from other qualified plans, such as a 401(k) plan or 403(b) tax sheltered annuities, to an IRA by means of a direct rollover or a transfer. You may roll over, directly or indirectly, any eligible rollover distribution. An eligible rollover distribution is defined generally as any distribution of all or part of the balance from a qualified plan, except you cannot roll over the following taxable distributions from a plan or IRA:
any distribution that is part of a series of substantially equal payments made over your life expectancy;
any distribution made for a specified period of 10 years or more;
any distribution that is an RMD; or
any hardship distribution.

Also, you cannot roll over from a SIMPLE IRA during the first two years of participation in the SIMPLE IRA and a roll over of an after-tax contribution that had been made to a Roth IRA may be a taxable event.

You can make only one rollover from an IRA to another (or the same) IRA in any 12-month period, regardless of the number of IRAs you own. The limit will apply by aggregating all of an individual’s IRAs, including SEP and SIMPLE IRAs as well as traditional and Roth IRAs, effectively treating them as one IRA for purposes of the limit. Trustee-to-trustee transfers between IRAs are not limited. Rollovers from traditional IRAs to Roth IRAs (“conversions”) are not limited.

Tax laws are complex and your individual situation is unique. You should always consult a tax advisor before you move or attempt to move assets between any IRA or qualified plan and another qualified contract or plan.

Early Distributions

Premature distributions are subject to an additional penalty tax equal to 10% of the amount of any payment from your IRA that is includible in your income. This penalty is in addition to ordinary income tax.

Some distributions will be exempt from the additional federal tax. There is an exception to this 10% additional federal tax for:

1) distributions made on or after the date you (or the Annuitant as applicable) reach age 59 ½;
2)
distributions following your death or disability (or the Annuitant as applicable) (for this purpose “disability” is defined in Code Section 72(m)(7));
3)
distributions paid in series of substantially equal payments made annually (or more frequently) for your life (or life expectancy) or joint lives (or life expectancies) of you and designated beneficiary;
4) distributions made to you after separation from service after attaining age 55 (does not apply to IRAs);
5)
distributions made to you to the extent such distributions do not exceed the amount allowable as a deduction under Code Section 213 to you for amounts paid during the taxable year for medical care (determined without regard to whether you itemize deductions for such taxable year);
6)
distributions to an alternate payee pursuant to a qualified domestic relations order (within the meaning of Code Section 414(p)(1));
7)
distributions from an IRA for the health insurance (as described in Code Section 213)(d)(1)(D)) for you and your spouse and dependents if you have received unemployment compensation for at least 12 weeks (this exception will no longer apply after you have been re-employed for at least 60 days);

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8)
distributions from an IRA made to you, to the extent such distributions do not exceed your qualified higher education expenses (as defined in Code Section 72(t)(7)) for the tax year;
9)
distributions from an IRA which are qualified first-time homebuyer distributions (as defined in Code Section 72(t)(8));
10)
distributions made to a reservist called to active duty after September 11, 2001, for a period in excess of 179 days (or for an indefinite period), from IRAs or amounts attributable to elective deferrals under a 401(k) plan made during such active period; and
11)
distributions made on account of an IRS levy upon a qualified contract.

With respect to 3) above, if the series of substantially equal periodic payments is modified (other than by reason of death or disability) before the close of the 5-year period beginning with the date of the first payment and after you attain age 59 ½, or before you attain age 59 ½, then the tax for the year of the modification is increased by the 10% additional federal tax, plus interest for the tax years in which the exception was used. You should consult with your tax adviser before taking any partial withdrawals from your Contract.

Required Minimum Distributions (RMD)

For traditional and SEP IRAs, RMDs generally must commence no later than April 1 of the calendar year following the calendar year in which the owner reaches the qualified age under IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72). The distribution required by April 1 is the distribution required for the year in which the owner actually turns the qualified age. Unless an exemption is otherwise available, you must take distributions for each calendar year after the year the owner turns the qualified age by December 31 of that year. The amount of the RMD is based on the prior year-end fair market value of your contract.

If your contract provides an additional benefit, such as the optional GLWB Rider, the fair market value of your contract may increase by the actuarial present value of the benefit. Therefore, the amount of the RMD you must take may increase.

If you have more than one IRA, the distributions required by the Tax Code for all IRAs in the aggregate may be met by taking distributions from one or more of your IRAs. Please note, however, that only the RMD as defined in the Glossary (for this contract only one time each Contract Year) is protected from a withdrawal charge (see Part 5, section titled “Free Withdrawal Amount”) and from being a Nonguaranteed Withdrawal if you have a GLWB Rider (See Part 6, section titled “Withdrawal Protection for Required Minimum Distributions.)

Failure to comply with the RMD rules applicable to qualified contracts may result in the imposition of an excise tax. This excise tax generally equals 50% of the amount by which an RMD exceeds the actual distribution from the contract.

Roth IRAs do not require distributions at any time prior to the owner's death.

CARES Act

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which was enacted on March 27, 2020, contains provisions relaxing certain requirements applicable to distributions from certain retirement plans, individual retirement accounts and individual retirement annuities. Among other things, it waives RMD payments for 2020 from certain types of retirement plans. The CARES Act also waives certain early withdrawal penalties on withdrawals of up to $100,000 by participants in certain types of retirement plans, who meet applicable eligibility requirements (generally that an individual, or an individual’s spouse or dependents has been diagnosed with coronavirus, or the individual has otherwise experienced adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus, among other things). You should consult your financial or tax advisor for more information about the effect of the CARES Act and for assistance in determining whether you qualify to rely on any of these provisions in connection with your contract.


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Inherited IRAs

The death benefit paid under this contract may be extended as an inherited IRA. This occurs if, after the death of the owner, the owner's beneficiary directs that the death proceeds be titled as an inherited IRA. See Part 5, section titled “Death Benefit.” The owner's beneficiary of the original IRA contract will become the inherited IRA owner and may name his or her own beneficiary in the event of death.

The inherited IRA owner may invest in the Subaccounts then available under the contract. Separate account charges will continue to apply. The inherited IRA owner must take RMDs beginning on or before December 31 of the calendar year after the original owner’s death. If the beneficiary is a spouse and has elected this option, distributions may begin at the end of the calendar year in which the owner would have reached the qualified age for purposes of IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72), if later.

Prior to January 1, 2020, the following rules apply to inherited IRA owners who were beneficiaries designated by the original owner. If the original owner died before the Required Beginning Date, the inherited IRA owner must take RMDs over his or her life expectancy as defined by the Tax Code.  If the owner died after the Required Beginning Date, the inherited IRA owner may choose the longer of his or her life expectancy or the deceased owner’s life expectancy, both as defined by the Tax Code.  (For Roth IRAs, the owner is presumed to have died before the Required Beginning Date.) Separate rules apply for non-designated beneficiaries.

The following chart summarizes the date when RMDs must begin and the life used to measure the RMDs under the rules in effect prior to January 1, 2020:
Death of Owner
Spouse
Nonspouse
Before Required Beginning Date
Distributions must begin by the later of (i) 12/31 of year after the calendar year of owner’s death, or (ii) 12/31 of the year when the deceased owner would have reached the qualified age under IRS regulations

RMD based on beneficiary life expectancy.

Distributions must begin by 12/31 of year after the calendar year of owner’s death.




RMD based on beneficiary life expectancy.

After Required Beginning Date (Traditional and SEP IRAs only)
Distributions must begin by 12/31 of year after the calendar year of owner’s death

RMD may be based on longer of the owner’s or beneficiary’s life expectancy.
Distributions must begin by 12/31 of year after the calendar year of owner’s death

RMD may be based on longer of the owner’s or beneficiary’s life expectancy.

On or after January 1, 2020, the Setting Every Community Up for Retirement Enhancement Act of 2019 (“SECURE”) changed the RMD rules, dividing the category of designated beneficiaries into two categories - “eligible designated beneficiaries” and non-eligible designated beneficiaries. Inherited IRA owners who are eligible designated beneficiaries are subject to the same rules that were in effect prior to January 1, 2020 as described above. Inherited IRA owners who are non-eligible designated beneficiaries must take RMDs within 10 years of the death of the original owner. An “eligible designated beneficiary” is the owner’s surviving spouse, minor child (until the child reaches the age of majority, at which time the 10-year rule begins to apply), or an individual who is disabled, chronically ill, or not more than 10 years younger than the IRA owner. Separate rules apply for non-designated beneficiaries.


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The following chart summarizes the date when RMDs must begin and the life used to measure the RMDs under the rules in effect for designated beneficiaries on and after January 1, 2020:
Death of Owner
Spouse
Other Eligible Designated Beneficiary
Non-Eligible Designated Beneficiary
Before Required Beginning Date
Distributions must begin by the later of (i) 12/31 of the year after the calendar year of owner’s death, or (ii) 12/31 of the year when the deceased owner would have reached the qualified age under IRS regulations.

RMD based on beneficiary life expectancy.
Distributions must begin by 12/31 of the year after the calendar year of owner’s death.

RMD based on beneficiary life expectancy.
Distributions must begin by 12/31 of the year after the calendar year of owner’s death.

RMD based on a maximum 10-year period.
After Required Beginning Date (Traditional and SEP IRAs only)
Distributions must begin by 12/31 of the year after the calendar year of owner’s death

RMD may be based on longer of the owner’s or beneficiary’s life expectancy.
Distributions must begin by 12/31 of the year after the calendar year of owner’s death

RMD may be based on longer of the owner’s or beneficiary’s life expectancy.
Distributions must begin by 12/31 of the year after the calendar year of owner’s death

RMD based on a maximum 10-year period.

The following restrictions apply to the inherited IRA contract: (i) the inherited IRA owner may not add premium to the contract; (ii) the Death Benefit available to the beneficiary of the inherited IRA owner is the Account Value on the Death Benefit Date after the death of the inherited IRA owner; (iii) the beneficiary of the inherited IRA owner will be required to receive the remaining Account Value either in a lump sum, over five years or over the life expectancy of the inherited IRA owner as determined by the Tax Code.

A tax penalty applies if the inherited IRA owner fails to take the RMD. The tax penalty equals 50% of the excess of the RMD over the amount actually withdrawn from the inherited IRA during the calendar year.

For more information on inherited IRAs, see IRS Publication 590. Seek independent tax advice.

Federal and State Income Tax Withholding

We may be required to withhold federal income taxes on all distributions unless the eligible recipients elect not to have any amounts withheld and properly notify us of that election.

Certain states have indicated that pension and annuity withholding will apply to payments made to their residents. Generally, an election out of federal withholding will also be considered an election out of state withholding. For more information concerning a particular state, call our Administrative Office listed in the Glossary.

Tax Status of the Company

Under existing federal income tax laws, we do not pay tax on investment income and realized capital gains of the Separate Account. We do not anticipate that we will incur any federal income tax liability on the income and gains earned by the Separate Account. The Company, therefore, does not impose a charge for federal income taxes. If federal income tax law changes and we must pay tax on some or all of the income and gains earned by the Separate Account, we may impose a charge against the Separate Account to pay the taxes. We can also set up reserves for taxes. We receive a tax deduction for dividends received by the Funds.

Transfers among Subaccounts

There will not be any current tax liability if you transfer any part of the Account Value among the Subaccounts of your contract.

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Seek Tax Advice

National Integrity Life does not act as your tax or legal advisor. This discussion of the federal income tax treatment of the contract is not designed to cover all situations and is not intended to be tax advice. It is based upon our understanding of the present federal income tax laws as currently interpreted by the IRS and various courts. The IRS or the courts may change their views on the treatment of these contracts. Future legislation may have a negative effect on annuity contracts or IRAs. Also, we have not attempted to consider any applicable state or other tax laws.

Because of the complexity of the tax laws and the fact that tax results will vary according to the particular circumstances, anyone considering buying a contract, selecting an Annuity Option under the contract, or receiving annuity payments under a contract should consult a qualified tax advisor.

You should carefully consider the advantages and disadvantages of owning a variable annuity as an IRA or tax-qualified plan, as well as the costs and benefits of the contract (including the death benefits, income benefits and other non-tax-related benefits), before you purchase the contract as an IRA.

This contract includes an enhanced death benefit and offers an optional living benefit. The IRS requires an actuarial present value of enhanced benefits to be added to the Account Value for purposes of calculating the fair market value of the annuity and determining the RMD.

The IRS has not reviewed the contract for qualification as an IRA and we make no guarantees that the contract will so qualify. National Integrity Life does not guarantee the tax status, federal, state, or local, of any contract or any transaction involving the contracts.

Part 9 – Additional Information

Systematic Withdrawal Program

We offer a program that allows you to pre-authorize periodic withdrawals from your contract prior to your Annuity Date. You can choose to have withdrawals made monthly, quarterly, semi-annually or annually and can specify the day of the month (other than the 29th, 30th or 31st) on which the withdrawal is to be made. If you do not select how often you want to receive withdrawals, we will make them on a monthly basis. You may specify a dollar amount or an annual percentage to be withdrawn, such as the Free Withdrawal Amount. The minimum Systematic Withdrawal is $100. If you do not have enough Account Value to make the withdrawal you have specified, no withdrawal will be made and your enrollment in the program will end. You may specify an account for direct deposit of your Systematic Withdrawals. Direct deposit is required for monthly withdrawals. Withdrawals under this program are subject to withdrawal charges, if any (see Part 4, section titled "Withdrawal Charge") and to income tax and a 10% tax penalty if you are under age 59½. See Part 8.

To enroll in our Systematic Withdrawal Program, send the appropriate form to our Administrative Office. You may terminate your participation in the program upon prior written notice. We may terminate or change the Systematic Withdrawal Program at any time.

Cyber Security and Certain Business Continuity Risks
We rely heavily on interconnected computer systems and digital data to conduct our variable product business activities. Because our variable product business is highly dependent upon the effective operation of our computer systems and those of our business partners, our business is potentially vulnerable to disruptions from utility outages and other problems, and susceptible to operational and information security risks resulting from information systems failure, including hardware and software malfunctions and cyber-attacks. These risks include, among other things, the theft, misuse, corruption and destruction of data maintained online or digitally, interference with or denial of service attacks on websites and other operational disruption and unauthorized release of confidential customer information. Such systems failures and cyber-attacks affecting us, the underlying funds, the principal underwriter and other affiliated or third-party service providers may adversely affect us and your Contract Value. For instance, cyber-attacks may interfere with our processing of policy transactions, including the processing of orders with the

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underlying funds; cause the release and possible destruction of confidential customer or business information; subject us and/or our service providers and intermediaries to regulatory fines and financial losses; and/or cause reputational damage. Cyber security risks may also affect the issuers of securities in which the underlying funds invest, which may cause the underlying funds to lose value. There can be no assurance that we, the underlying funds or our service providers will avoid losses affecting your Contract that result from cyber-attacks or information security breaches in the future. In addition to cyber security risks, we are subject to business interruption risks caused by catastrophes, both natural and man-made, including those associated with pandemics, terrorist attacks, fires or inclement weather events. Such events may cause systems upon which we rely to be inaccessible to our employees, customers, service providers or intermediaries for an extended period of time, causing a negative impact on our ability to provide services and products. These risks also apply to other insurance and financial services companies and businesses.
Anti-Money Laundering
Federal laws designed to counter terrorism and prevent money laundering by criminals might in certain circumstances require us to reject a premium payment and/or “freeze” an owner’s account. If these laws apply in a particular situation, we would not be allowed to pay any request for surrenders (either full or partial), or death benefits, make transfers, or continue making annuity payments absent instructions from the appropriate federal regulator. We may also be required to provide information about you and your Contract to government agencies or departments.

Income Plus Withdrawal Program

We offer an Income Plus Withdrawal Program that allows you to pre-authorize substantially equal periodic withdrawals, based on your life expectancy as defined by the Tax Code, from your contract anytime before you reach age 59½. You will not have to pay a tax penalty for these withdrawals, but they will be subject to ordinary income tax. See Part 8. Once you begin receiving your withdrawals under this program, you should not change or stop the withdrawals until the later of:
the date you reach age 59½; and
five years from the date of the first withdrawal under the program.

If you change or stop the withdrawals or take an additional withdrawal, you may have to pay a 10% penalty tax that would have been due on all prior withdrawals made under the Income Plus Withdrawal Program before you reached the date described above, plus interest.

You may choose to have withdrawals made monthly, quarterly, semi-annually or annually and may specify the day of the month (other than the 29th, 30th or 31st) on which the withdrawal is made. You may specify an account for direct deposit of your withdrawals. Direct deposit is required for monthly withdrawals. We will calculate the amount of the withdrawal, subject to a $100 minimum. We are not responsible for any tax or other liability you may incur if our good faith calculations are not correct. You should consult with your tax advisor to ensure these withdrawals are appropriate to your situation.

If on any withdrawal date you do not have enough Account Value to make the withdrawals you specified, no withdrawal will be made and your enrollment in the program will end.

To enroll in our Income Plus Withdrawal Program, send the appropriate form to our Administrative Office. You may end your participation in the program upon prior written notice. We may terminate or change the Income Plus Withdrawal Program at any time. This program is not available in connection with the Systematic Withdrawal Program. Withdrawals under this program are subject to a withdrawal charge, if any. See Part 4, section titled "Withdrawal Charge."

This program is not available with a GLWB Rider. See Part 6.


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Choices Plus Required Minimum Distribution (RMD) Program

We offer a Choices Plus RMD Program that allows you to pre-authorize withdrawals from your IRA after you attain the qualified age under IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72). The Tax Code requires that you take minimum distributions beginning on or before April 1 of the calendar year following the calendar year in which you turn the qualified age. The distribution required by April 1 is the distribution required for the year you actually turn the qualified age. Unless an exemption is otherwise available, you must take distributions for each calendar year after the year you turn the qualified age by December 31 of that year. These withdrawals are subject to ordinary income tax. See Part 8.

You can choose the Choices Plus RMD Program at any time you have reached the qualified age for purposes of IRS regulations by sending the election form to our Administrative Office. You can choose to have withdrawals made monthly, quarterly, semi-annually, or annually and can specify the day of the month (other than the 29th, 30th, or 31st) on which the withdrawal is made. You may specify an account for direct deposit of your withdrawals. Direct deposit is required for monthly withdrawals. As a convenience, we will calculate the amount of the withdrawals. We are not responsible for any tax or other liability you may incur if our good faith calculations are not correct. You should consult with your tax advisor to ensure these withdrawals are appropriate to your situation.

Withdrawals of Account Value that are made as part of the Choices Plus program are not subject to a withdrawal charge, as long as you do not take additional withdrawals. You may end your participation in the program upon prior written notice. We may terminate or change the Choices Plus RMD Program at any time.

This program is not available with a GLWB Rider. See Part 6, section titled "Withdrawal Protection for Required Minimum Distributions."

Systematic Transfer Program

We offer a Systematic Transfer Program where we accept new premiums into a Systematic Transfer Option (STO), which is a Fixed Account, and make transfers out of the STO to one or more Subaccounts on a monthly or quarterly basis. We will transfer your STO premiums in approximately equal installments of at least $1,000 monthly over a six-month or monthly or quarterly over a one-year period, depending on the options you select. You can only invest in either the six-month or one-year STO at any one time, but not both. If you do not have enough Account Value in the STO to transfer to each Subaccount specified, a final transfer will be made on a pro rata basis and your enrollment in the program will end. All interest accrued and any Account Value remaining in the STO at the end of the period during which transfers are scheduled to be made will be transferred at the end of that period on a pro rata basis to the Subaccounts you chose for this program. You cannot transfer Account Value into the STO.

Transfers made under our Systematic Transfer Program do not trigger a 60-day waiting period. See Part 4, section titled “Allocations and Transfers.”

To enroll in our Systematic Transfer Program, send the appropriate form to our Administrative Office. We can end the Systematic Transfer Program in whole or in part, or restrict premiums to the program.

This program is available with a GLWB Rider only for the initial premium we received on the Contract Date. See Part 6.

Customized Asset Rebalancing Program

Asset rebalancing allows you to maintain a diversified investment mix that is appropriate for your goals and risk tolerance. Because your different Subaccounts will experience different gains and losses at different times, your asset allocation may shift from your preferred mix. Asset rebalancing periodically resets your investments to your original allocations, ensuring that your asset mix stays in line with your investment strategy.

We offer a Customized Asset Rebalancing Program that allows you to have your investments rebalanced to your allocation percentages periodically. You can choose to rebalance quarterly, semi-annually or annually.


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The Account Value in the currently available Subaccounts will automatically be rebalanced back to your allocation percentages by selling all existing Units subject to rebalancing and repurchasing Units according to your allocation. You will receive a confirmation notice after each rebalancing. Subaccounts that are closed to new purchases, and the Fixed Account, are not included in the Customized Asset Rebalancing Program.

Transfers under our Customized Asset Rebalancing Program do not trigger a 60-day waiting period. See Part 4, section titled “Allocations and Transfers.”

To enroll in our Customized Asset Rebalancing Program, send the appropriate form to our Administrative Office. You may terminate your participation in the program upon prior written notice. We may end or change the Customized Asset Rebalancing Program at any time. We recommend you consult with your financial professional when establishing your allocation.

This program is not available with a GLWB Rider because quarterly rebalancing is required. See Part 6.

Legal Proceedings

National Integrity Life is a party to litigation and arbitration proceedings in the ordinary course of its business. None of these matters is expected to have a material adverse effect on National Integrity Life.


Table of Contents of Statement of Additional Information
 
Page
General Information and History......................................................................................................
1
Administration and Distribution of the Contracts..............................................................................
1
Performance Data and Illustrations..................................................................................................
2
Distributions from Tax Favored Retirement Programs.....................................................................
4
Financial Statements........................................................................................................................
5

If you would like to receive a copy of the Statement of Additional Information, please write:

Administrative Office
National Integrity Life Insurance Company
400 Broadway
Cincinnati, Ohio 45202-3341
ATTN: Request SAI for National Integrity Life VAROOM dated May 1, 2020

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Appendix A

Financial Information for Separate Account I of National Integrity Life

The table below shows the following data for the Subaccounts currently offered: Unit Value at inception; the number of Units outstanding at December 31 of each year since inception; and the Unit Value at the beginning and end of each period since inception.


Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date

iShares Core S&P 500 ETF (3715)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$51.03
$65.80
1,458


$54.37
$51.03
1,494


$45.45
$54.37
1,942


$41.24
$45.45
2,255


$41.45
$41.24
2,492


$37.14
$41.45
2,642


$28.45
$37.14
1,588


$25.05
$28.45
1,631


$24.95
$25.05
1,670


$25.00
$24.95
0


$25.00

12-21-10

iShares Core S&P 500 ETF – GLWB Investment Strategy 1 (3715E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$48.58
$62.26
10,700



$52.08
$48.58
15,868



$43.80
$52.08
18,183



$39.99
$43.80
21,445



$40.44
$39.99
24,023



$36.46
$40.44
24,800



$28.09
$36.46
29,031



$24.89
$28.09
33,270



$24.95
$24.89
30,066



$25.00
$24.95
0



$25.00

12-21-10

iShares Core S&P 500 ETF – GLWB Investment Strategy 2 (3715E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$47.79
$61.12
201



$51.34
$47.79
208



$43.27
$51.34
645



$39.58
$43.27
688



$40.10
$39.58
698



$36.23
$40.10
765



$27.98
$36.23
1,078



$24.84
$27.98
1,392



$24.95
$24.84
1,265



$25.00
$24.95
0



$25.00

12-21-10

iShares Core S&P Mid-Cap ETF (3717)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$44.51
$55.15
373


$51.01
$44.51
1,113


$44.66
$51.01
1,231


$37.66
$44.66
1,256


$39.23
$37.66
1,321


$36.40
$39.23
1,365


$27.71
$36.40
970


$23.89
$27.71
970


$24.87
$23.89
970


$25.00
$24.87
0


$25.00

12-21-10

iShares Core S&P Mid-Cap ETF – GLWB Investment Strategy 1 (3717E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period




$42.38
$52.18
3,646




$48.86
$42.38
5,284




$43.04
$48.86
5,688




$36.52
$43.04
6,569




$38.27
$36.52
7,762




$35.73
$38.27
7,868




$27.37
$35.73
8,796




$23.74
$27.37
10,282




$24.87
$23.74
9,462




$25.00
$24.87
0



$25.00

12-21-10

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Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date
iShares Core S&P Mid-Cap ETF – GLWB Investment Strategy 2 (3717E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$41.69
$51.22
157



$48.16
$41.69
153



$42.51
$48.16
687



$36.15
$42.51
2,353



$37.96
$36.15
2,358



$35.51
$37.96
2,472



$27.26
$35.51
2,728



$23.69
$27.26
2,899



$24.87
$23.69
791



$25.00
$24.87
0



$25.00

12-21-10
iShares Core S&P Small-Cap ETF (3718)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$48.32
$58.31
179


$53.75
$48.32
742


$48.34
$53.75
807


$38.86
$48.34
823


$40.39
$38.86
861


$38.86
$40.39
888


$27.87
$38.86
690


$24.47
$27.87
690


$24.74
$24.47
690


$25.00
$24.74
0


$25.00

12-21-10
iShares Core S&P Small-Cap ETF – GLWB Investment Strategy 1 (3718E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$46.00
$55.17
1,731



$51.49
$46.00
2,416



$46.59
$51.49
2,685



$37.68
$46.59
3,098



$39.40
$37.68
3,753



$38.15
$39.40
3,869



$27.52
$38.15
4,132



$24.32
$27.52
5,132



$24.73
$24.32
4,692



$25.00
$24.73
0



$25.00

12-21-10
iShares Core S&P Small-Cap ETF – GLWB Investment Strategy 2 (3718E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$45.25
$54.16
149



$50.75
$45.25
138



$46.01
$50.75
396



$37.30
$46.01
1,223



$39.08
$37.30
1,227



$37.91
$39.08
1,274



$27.41
$37.91
1,274



$24.27
$27.41
1,369



$24.73
$24.27
291



$25.00
$24.73
0



$25.00

12-21-10
iShares Core U.S. Aggregate Bond ETF (3710)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$26.97
$28.74
450


$27.43
$26.97
497


$26.96
$27.43
539


$26.79
$26.96
575


$27.14
$26.79
600


$26.06
$27.14
626


$27.06
$26.06
657


$26.55
$27.06
684


$25.10
$26.55
714


$25.00
$25.10
0


$25.00

12-21-10
iShares Core U.S. Aggregate Bond ETF – GLWB Investment Strategy 1 (3710E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.68
$27.19
0



$26.27
$25.68
0



$25.98
$26.27
0



$25.98
$25.98
0



$26.47
$25.98
0



$25.58
$26.47
0



$26.73
$25.58
0



$26.38
$26.73
0



$25.09
$26.38
0



$25.00
$25.09
0



$25.00

12-21-10

VN-49



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date
iShares Core U.S. Aggregate Bond ETF – GLWB Investment Strategy 2 (3710E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.26
$26.69
0



$25.90
$25.26
0



$25.66
$25.90
1,509



$25.71
$25.66
1,443



$26.26
$25.71
1,457



$25.42
$26.26
1,483



$26.62
$25.42
1,488



$26.33
$26.62
1,355



$25.09
$26.33
1,309



$25.00
$25.09
0



$25.00

12-21-10

iShares iBoxx $ High Yield Corporate Bond ETF (3713)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$31.17
$34.94
0



$32.38
$31.17
0



$31.06
$32.38
0



$27.88
$31.06
192



$29.88
$27.88
202



$29.85
$29.88
212



$28.69
$29.85
223



$26.19
$28.69
235



$25.27
$26.19
240



$25.00
$25.27
0



$25.00

12-21-10
iShares iBoxx $ High Yield Corporate Bond ETF – GLWB Investment Strategy 1 (3713E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$29.67
$33.06
0



$31.01
$29.67
0



$29.94
$31.01
0



$27.03
$29.94
0



$29.15
$27.03
0



$29.30
$29.15
0



$28.34
$29.30
0



$26.03
$28.34
0



$25.27
$26.03
0



$25.00
$25.27
0



$25.00

12-21-10
iShares iBoxx $ High Yield Corporate Bond ETF – GLWB Investment Strategy 2 (3713E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$29.19
$32.46
0



$30.57
$29.19
0



$29.57
$30.57
390



$26.76
$29.57
1,405



$28.91
$26.76
1,418



$29.12
$28.91
1,370



$28.22
$29.12
1,428



$25.97
$28.22
1,200



$25.27
$25.97
193



$25.00
$25.27
0



$25.00

12-21-10
iShares Intermediate-Term Corporate Bond ETF (3711)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$27.23
$30.66
0


$27.92
$27.23
0


$27.45
$27.92
0


$27.04
$27.45
0


$27.37
$27.04
0


$26.83
$27.37
0


$27.40
26.83
0


$26.05
$27.40
0


$25.06
$26.05
0


$25.00
$25.06
0


$25.00

12-21-10
iShares Intermediate-Term Corporate Bond ETF – GLWB Investment Strategy 1 (3711E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.92
$29.01
0



$26.75
$25.92
0



$26.45
$26.75
0



$26.22
$26.45
0



$26.71
$26.22
0



$26.34
$26.71
0



$27.06
$26.34
0



$25.89
$27.06
0



$25.05
$25.89
0



$25.00
$25.05
0



$25.00

12-21-10

VN-50



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date
iShares Intermediate-Term Corporate Bond ETF – GLWB Investment Strategy 2 (3711E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.50
$28.48
397



$26.36
$25.50
400



$26.13
$26.36
410



$25.95
$26.13
400



$26.49
$25.95
417



$26.17
$26.49
454



$26.95
$26.17
465



$25.84
$26.95
398



$25.05
$25.84
394



$25.00
$25.05
0



$25.00

12-21-10
iShares International Treasury Bond ETF (3719)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$23.37
$23.82
392


$24.42
$23.37
776


$22.30
$24.42
787


$22.50
$22.30
745


$24.69
$22.50
778


$25.83
$24.69
761


$26.58
$25.83
477


$25.64
$26.58
477


$25.72
$25.64
477


$25.00
$25.72
0


$25.00

12-21-10
iShares International Treasury Bond ETF – GLWB Investment Strategy 1 (3719E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$22.25
$22.54
4,086



$23.39
$22.25
5,396



$21.49
$23.39
5,904



$21.82
$21.49
6,150



$24.09
$21.82
6,670



$25.36
$24.09
6,124



$26.25
$25.36
6,042



$25.48
$26.25
5,277



$25.72
$25.48
4,407



$25.00
$25.72
0



$25.00

12-31-10
iShares International Treasury Bond ETF – GLWB Investment Strategy 2 (3719E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$21.88
$22.13
0



$23.06
$21.88
0



$21.22
$23.06
0



$21.60
$21.22
0



$23.89
$21.60
0



$25.20
$23.89
48



$26.14
$25.20
287



$25.43
$26.14
359



$25.72
$25.43
376



$25.00
$25.72
0



$25.00

12-21-10

iShares S&P 500 Growth ETF (3714)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$56.17
$72.17
285



$57.29
$56.17
867



$45.83
$57.29
1,013


$43.67
$45.83
1,038


$42.18
$43.67
1,102


$37.44
$42.18
1,150


$28.67
$37.44
789


$25.60
$28.67
789


$24.96
$25.60
789


$25.00
$24.96
0


$25.00

12-21-10

iShares S&P 500 Growth ETF – GLWB Investment Strategy 1 (3714E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$53.48
$68.29
1,393



$54.88
$53.48
2,626



$44.17
$54.88
2,989



$42.35
$44.17
3,296



$41.16
$42.35
3,334



$36.76
$41.16
3,479



$28.31
$36.76
4,275



$25.44
$28.31
4,574



$24.96
$25.44
5,102



$25.00
$24.96
0



$25.00

12-21-10

VN-51



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date

iShares S&P 500 Growth ETF – GLWB Investment Strategy 2 (3714E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$52.61
$67.04
0



$54.09
$52.61
0



$43.63
$54.09
201



$41.91
$43.63
224



$40.82
$41.91
220



$36.53
$40.82
236



$28.20
$36.53
259



$25.39
$28.20
299



$24.96
$25.39
191



$25.00
$24.96
0



$25.00

12-21-10

iShares S&P 500 Value ETF (3716)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$44.71
$57.82
0


$50.12
$44.71
0


$44.25
$50.12
0


$38.40
$44.25
0


$40.41
$38.40
0


$36.66
$40.41
0


$28.36
$36.66
0


$24.56
$28.36
0


$25.04
$24.56
0


$25.00
$25.04
0


$25.00

12-21-10

iShares S&P 500 Value ETF – GLWB Investment Strategy 1 (3716E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$42.57
$54.71
78



$48.01
$42.57
85



$42.65
$48.01
82



$37.23
$42.65
685



$39.42
$37.23
1,277



$35.99
$39.42
1,271



$28.01
$35.99
1,326



$24.41
$28.01
1,471



$25.03
$24.41
1,223



$25.00
$25.03
0



$25.00

12-21-10

iShares S&P 500 Value ETF – GLWB Investment Strategy 2 (3716E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$41.87
$53.71
0



$47.32
$41.87
0



$42.13
$47.32
236



$36.85
$42.13
237



$39.10
$36.85
251



$35.77
$39.10
249



$27.89
$35.77
261



$24.36
$27.89
311



$25.03
$24.36
203



$25.00
$25.03
0



$25.00

12-21-10

iShares TIPS Bond ETF (3712)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$25.93
$27.60
0


$26.78
$25.93
0


$26.48
$26.78
0


$25.75
$26.48
0


$26.67
$25.75
0


$26.21
$26.67
0


$29.13
$26.21
0


$27.88
$29.13
0


$25.05
$27.88
0


$25.00
$25.05
0


$25.00

12-21-10

iShares TIPS Bond ETF – GLWB Investment Strategy 1 (3712E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$24.69
$26.12
0



$25.65
$24.69
0



$25.52
$25.65
0



$24.96
$25.52
0



$26.02
$24.96
0



$25.72
$26.02
0



$28.77
$25.72
0



$27.71
$28.77
0



$25.05
$27.71
0



$25.00
$25.05
0



$25.00

12-21-10

iShares TIPS Bond ETF– GLWB Investment Strategy 2 (3712E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$24.28
$25.64
0



$25.28
$24.28
0



$25.20
$25.28
849



$24.71
$25.20
770



$25.81
$24.71
754



$25.56
$25.81
746



$28.65
$25.56
703



$27.65
$28.65
589



$25.05
$27.65
330



$25.00
$25.05
0



$25.00

12-21-10

VN-52



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date

Vanguard Developed Markets Index Fund, ETF Shares (3722)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$28.70
$34.57
300



$34.27
$28.70
874



$27.59
$34.27
911



$27.36
$27.59
929



$27.95
$27.36
946



$30.26
$27.95
950



$25.22
$30.26
698



$21.03
$25.22
698



$25.25
$21.03
698



$25.00
$25.25
0



$25.00

12-21-10
Vanguard Developed Markets Index Fund, ETF Shares – GLWB Investment Strategy 1 (3722E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$27.32
$32.71
2,910



$32.83
$27.32
4,197



$26.59
$32.83
4,234



$26.53
$26.59
5,186



$27.26
$26.53
5,377



$29.70
$27.26
5,301



$24.91
$29.70
5,276



$20.90
$24.91
5,763



$25.25
$20.90
5,169



$25.00
$25.25
0



$25.00

12-21-10
Vanguard Developed Markets Index Fund, ETF Shares – GLWB Investment Strategy 2 (3722E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$26.88
$32.11
129



$32.36
$26.88
128



$26.26
$32.36
116



$26.26
$26.26
124



$27.04
$26.26
117



$29.52
$27.04
134



$24.81
$29.52
226



$20.85
$24.81
309



$25.24
$20.85
320



$25.00
$25.24
0



$25.00

12-21-10

Vanguard Dividend Appreciation Index Fund, ETF Shares (3720)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$47.86
$60.95
0



$49.75
$47.86
0



$41.43
$49.75
0



$37.65
$41.43
196



$39.07
$37.65
206



$36.13
$39.07
217



$28.40
$36.13
228



$26.03
$28.40
240



$25.00
$26.03
245



$25.00
$25.00
0



$25.00

12-21-10
Vanguard Dividend Appreciation Index Fund, ETF Shares – GLWB Investment Strategy 1 (3720E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$45.57
$57.67
0



$47.66
$45.57
0





$39.93
$47.66
0



$36.51
$39.93
0



$38.12
$36.51
0



$35.47
$38.12
0



$28.05
$35.47
0



$25.87
$28.05
0



$24.99
$25.87
0



$25.00
$24.99
0



$25.00

12-21-10
Vanguard Dividend Appreciation Index Fund, ETF Shares – GLWB Investment Strategy 2 (3720E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$44.82
$56.61
314



$46.98
$44.82
765



$39.44
$46.98
3,975



$36.14
$39.44
7,480



$37.81
$36.14
7,682



$35.25
$37.81
7,835



$27.93
$35.25
8,223



$25.81
$27.93
8,572



$24.99
$25.81
3,929



$25.00
$24.99
0



$25.00

12-21-10

VN-53



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date

Vanguard Emerging Markets Stock Index Fund, ETF Shares (3721)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$21.70
$25.74
0



$25.91
$21.70
1,005



$20.06
$25.91
1,005



$18.20
$20.06
1,005



$22.00
$18.20
1,005



$22.40
$22.00
1,005



$23.94
$22.40
1,005



$20.03
$23.94
1,005



$25.67
$20.03
1,005



$25.00
$25.67
0



$25.00

12-21-10

Vanguard Emerging Markets Stock Index Fund, ETF Shares – GLWB Investment Strategy 1 (3721E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period




$20.66
$24.36
0


$24.82
$20.66
0



$19.33
$24.82
0



$17.64
$19.33
0



$21.46
$17.64
0



$21.99
$21.46
0



$23.65
$21.99
0



$19.91
$23.65
0



$25.67
$19.91
0



$25.00
$25.67
0



$25.00

12-21-10

Vanguard Emerging Markets Stock Index Fund, ETF Shares – GLWB Investment Strategy 2 (3721E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period




$20.32
$23.91
335













$24.46
$20.32
471



$19.09
$24.46
1,859



$17.46
$19.09
3,689



$21.29
$17.46
3,836



$21.86
$21.29
3,329



$23.55
$21.86
3,275



$19.86
$23.55
2,727



$25.67
$19.86
1,105



$25.00
$25.67
-



$25.00

12-21-10
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares (3723)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$30.46
$34.14
443



$31.55
$30.46
489



$30.49
$31.55
531



$29.49
$30.49
566



$29.74
$29.49
591



$28.12
$29.74
616



$29.23
$28.12
647



$26.88
$29.23
674



$25.11
$26.88
703



$25.00
$25.11
0



$25.00

12-21-10
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares – GLWB Investment Strategy 1 (3723E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period




$28.99
$32.30
0




$30.22
$28.99
0




$29.39
$30.22
0




$28.59
$29.39
0




$29.01
$28.59
0




$27.60
$29.01
0




$28.87
$27.60
0




$26.71
$28.87
0




$25.10
$26.71
0




$25.00
$25.10
0




$25.00

12-21-10
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares – GLWB Investment Strategy 2 (3723E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period




$28.52
$31.71
0




$29.79
$28.52
0




$29.03
$29.79
1,101




$28.30
$29.03
1,046




$28.78
$28.30
1,056




$27.43
$28.78
1,051




$28.75
$27.43
1,049




$26.66
$28.75
961




$25.10
$26.66
987




$25.00
$25.10
0




$25.00

12-21-10

VN-54



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date
Vanguard Large-Cap Index Fund, ETF Shares (3724)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$50.51
$65.13
0



$53.81
$50.51
0






$44.88
$53.81
0



$40.87
$44.88
202



$41.17
$40.87
212



$36.96
$41.17
223



$28.24
$36.96
235



$24.85
$28.24
247



$25.07
$24.85
252



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Large-Cap Index Fund, ETF Shares – GLWB Investment Strategy 1 (3724E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$48.09
$61.63
0



$51.55
$48.09
0



$43.25
$51.55
0



$39.63
$43.25
0



$40.17
$39.63
0



$36.28
$40.17
0



$27.89
$36.28
0



$24.70
$27.89
0



$25.07
$24.70
0



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Large-Cap Index Fund, ETF Shares – GLWB Investment Strategy 2 (3724E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$47.31
$60.50
194



$50.81
$47.31
198



$42.72
$50.81
959



$39.22
$42.72
3,315



$39.84
$39.22
3,269



$36.06
$39.84
3,448



$27.78
$36.06
3,889



$24.64
$27.78
3,914



$25.07
$24.64
864



$25.00
$25.07
0



$25.00

12-21-10

Vanguard Mega Cap Index Fund, ETF Shares (3725)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$51.98
$66.98
510



$54.80
$51.98
563



$45.49
$54.80
612



$41.37
$45.49
651



$41.52
$41.37
680



$37.28
$41.52
710



$28.59
$37.28
745



$25.20
$28.59
776



$25.07
$25.20
809



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Mega Cap Index Fund, ETF Shares – GLWB Investment Strategy 1 (3725E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$49.49
$63.38
0



$52.50
$49.49
0



$43.84
$52.50
0



$40.12
$43.84
0



$40.50
$40.12
0



$36.60
$40.50
0



$28.23
$36.60
0



$25.04
$28.23
0



$25.07
$25.04
0



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Mega Cap Index Fund, ETF Shares – GLWB Investment Strategy 2 (3725E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$48.68
$62.22
63



$51.75
$48.68
296




$43.31
$51.75
301



$39.71
$43.31
321



$40.17
$39.71
331



$36.37
$40.17
341



$28.12
$36.37
356



$24.99
$28.12
403



$25.07
$24.99
425



$25.00
$25.07
0



$25.00

12-21-10

VN-55



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date
Vanguard Real Estate Index Fund, ETF Shares (3726)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period


$41.38
$52.38
0


$44.82
$41.38
0


$43.49
$44.82
0


$40.75
$43.49
0


$40.49
$40.75
0


$31.62
$40.49
0


$31.40
$31.62
0


$27.25
$31.40
0


$25.54
$27.25
0


$25.00
$25.54
0


$25.00

12-21-10
Vanguard Real Estate Index Fund, ETF Shares – GLWB Investment Strategy 1 (3726E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$39.39
$49.56
0



$42.93
$39.39
0



$41.91
$42.93
0



$39.51
$41.91
0



$39.51
$39.51
0



$31.04
$39.51
0



$31.01
$31.04
0



$27.08
$31.01
0



$25.54
$27.08
0



$25.00
$25.54
0



$25.00

12-21-10
Vanguard Real Estate Index Fund, ETF Shares – GLWB Investment Strategy 2 (3726E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$38.75
$48.66
78



$42.32
$38.75
153



$41.40
$42.32
434



$39.11
$41.40
1,188



$39.18
$39.11
1,153



$30.85
$39.18
1,196



$30.88
$30.85
1,315



$27.02
$30.88
1,101



$25.54
$27.02
167



$25.00
$25.54
0



$25.00

12-21-10

Vanguard Short-Term Bond Index Fund, ETF Shares (3729)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$23.95
$24.71
0



$24.06
$23.95
0



$24.19
$24.06
0



$24.30
$24.19
0



$24.50
$24.30
0



$24.60
$24.50
0



$25.01
$24.60
0



$10.00
$25.01
0



-



-



$25.00

5-1-12

Vanguard Short-Term Bond Index Fund, ETF Shares (3729E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$22.99
$23.57
0



$23.23
$22.99
0



$23.51
$23.23
0



$23.76
$23.51
0



$24.10
$23.76
0



$24.35
$24.10
0



$24.90
$24.35
0



$10.00
$24.90
0



-



-



$25.00

5-1-12

Vanguard Short-Term Bond Index Fund, ETF Shares (3729E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$22.68
$23.21
0



$22.97
$22.68
0



$23.28
$22.97
0



$23.58
$23.28
0



$23.97
$23.58
0



$24.27
$23.97
0



$24.87
$24.27
0



$10.00
$24.87
0



-



-



$25.00

5-1-12

VN-56



Subaccount
2019
2018
2017

2016

2015

2014

2013

2012

2011

2010
Value and Inception Date

Vanguard Total Bond Market Index Fund, ETF Shares (3727)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$26.96
$28.83
2,280



$27.47
$26.96
2,419



$27.00
$27.47
2,567



$26.80
$27.00
2,333



$27.13
$26.80
2,485



$26.07
$27.13
2,603



$27.13
$26.07
717



$26.58
$27.13
717



$25.07
$26.58
717



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Total Bond Market Index Fund, ETF Shares – GLWB Investment Strategy 1 (3727E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.67
$27.28
23,597



$26.32
$25.67
32,763



$26.02
$26.32
36,387



$25.99
$26.02
36,348



$26.47
$25.99
39,085



$25.59
$26.47
39,404



$26.79
$25.59
41,522



$26.42
$26.79
35,986



$25.07
$26.42
29,650



$25.00
$25.07
0



$25.00

12-21-10
Vanguard Total Bond Market Index Fund, ETF Shares – GLWB Investment Strategy 2 (3727E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$25.25
$26.78
1,079



$25.94
$25.25
1,881



$25.70
$25.94
8,010



$25.73
$25.70
15,209



$26.25
$25.73
15,162



$25.44
$26.25
15,391



$26.68
$25.44
15,668



$26.36
$26.68
12,545



$25.07
$26.36
4,069



$25.00
$25.07
0



$25.00

12-21-10

Fidelity VIP Government Money Market Portfolio, Initial Class (3730)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$9.84
$9.86
0



$9.85
$9.84
0



$9.96
$9.85
0



$10.00
$9.96
0



-



-



-



-



-



-



$10.00

9-20-16
Fidelity VIP Government Money Market Portfolio, Initial Class – GLWB Investment Strategy 1 (3730E02)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$9.70
$9.66
0



$9.77
$9.70
0



$9.94
$9.77
0



$10.00
$9.94
0



-



-



-



-



-



-



$10.00

9-20-16
Fidelity VIP Government Money Market Portfolio, Initial Class – GLWB Investment Strategy 2 (3730E03)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period



$9.66
$9.60
0



$9.75
$9.66
0



$9.94
$9.75
0



$10.00
$9.94
0



-



-



-



-



-



-



$10.00

9-20-16


VN-57


Appendix B – Withdrawal Charge Examples

We allow two ways for you to request withdrawals. In the first method, you receive the amount requested, and any withdrawal charge is taken from the Account Value. This reduces your Account Value by the amount of the withdrawal charge in addition to the amount you requested. This is the method used unless you request otherwise or unless you have elected one of the GLWB Riders. In the second method, you receive less than you requested if a withdrawal charge applies because the Account Value is reduced by the amount of the requested withdrawal and any withdrawal charge is taken from that amount.

For both methods, withdrawals are attributed to amounts in the following order:
1.
any Free Withdrawal Amount (except in the case of a surrender);
2.
premiums that are no longer subject to a withdrawal charge and have not yet been withdrawn (premiums are withdrawn from oldest to youngest);
3.
premiums subject to a withdrawal charge that have not yet been withdrawn (premiums are withdrawn from oldest to youngest);
4.
any gain, interest or other amount that is not considered a premium

Example Assumptions
Assume one premium is paid, no previous withdrawals have been taken, and the Account Value at the time of the withdrawal is higher than the Account Value on the most recent Contract Anniversary:
Premium:                             $50,000
Account Value before withdrawal:                $60,000
Requested withdrawal:                        $16,000
Withdrawal charge percentage applicable to the premium:    6%

Taxes are not considered in this example.

Using the First Method
The Free Withdrawal Amount is calculated as:

$6,000 = $60,000 (Account Value on the date of the withdrawal) x 10% (free withdrawal percentage) - $0 (previous partial withdrawals during the current Contract Year).

After first applying the withdrawal to the Free Withdrawal Amount, the amount of the withdrawal still to be applied is:

$10,000 = $16,000 (requested withdrawal) - $6,000 (Free Withdrawal Amount).

There are no premiums that are no longer subject to a withdrawal charge, so the withdrawal is next applied to the premium subject to a withdrawal charge. The withdrawal charge for this method is calculated as:
    
$638.30 = $10,000 (portion of the withdrawal still to be attributed) x 6% (withdrawal charge percentage) / (1 – 6%) (one minus the withdrawal charge percentage).

Using this method, you will receive $16,000; however, the total Account Value withdrawn is:

$16,638.30 = $16,000 (requested withdrawal) + $638.30 (withdrawal charge).

The amount of premium still subject to a withdrawal charge is:

$39,361.70 = $50,000 (premium) - $10,638.30 (portion of withdrawal attributed to premium including the withdrawal charge).

Note, the withdrawal charge does not just apply to the premium withdrawn ($10,000 x 6%). It also applies to the withdrawal charge itself as indicated by the (1- 6%) factor in the withdrawal charge formula.



VN-58


Using the Second Method
The Free Withdrawal Amount is calculated as:

$6,000 = $60,000 (Account Value on the date of the withdrawal) x 10% (free withdrawal percentage) - $0 (previous partial withdrawals during the current Contract Year).

After first applying the withdrawal to the Free Withdrawal Amount, the amount of the withdrawal still to be attributed is:

$10,000 = $16,000 (requested withdrawal) - $6,000 (Free Withdrawal Amount).

There are no premiums that are no longer subject to a withdrawal charge, so the withdrawal is next applied to the premium subject to a withdrawal charge. The withdrawal charge for this method is calculated as:

$600 = $10,000 (portion of the withdrawal still to be attributed) x 6% (withdrawal charge percentage).

Using this method, the total Account Value withdrawn is $16,000; however, you will receive:

$15,400 = $16,000 (requested withdrawal) - $600 (withdrawal charge).

The amount of premium still subject to a withdrawal charge is:

$40,000 = $50,000 (premium) - $10,000 (portion of withdrawal attributed to premium including the withdrawal charge).

Note the second method will produce the same withdrawal charge as the first method if the requested withdrawal under the second method is the same as the total Account Value withdrawn in the first method. For example, a requested withdrawal of $16,638.30 using the second method produces the same $638.30 withdrawal charge as shown in the first method above.


This example is for illustrative purposes only and does not predict results.


VN-59


Appendix C

Illustrations of Guaranteed Lifetime Withdrawal Benefit

The following examples demonstrate how the GLWB Riders work, based on the stated assumptions. These examples are for illustration only, and do not predict future investment results.

Example #1
This example illustrates the Individual GLWB Rider where withdrawals equal to the Lifetime Payout Amount (LPA), as well as a Nonguaranteed Withdrawal, have been taken, additional premiums have been added and increases to the Withdrawal Percentage and step-ups have been applied. It also illustrates payments for the life of the covered person even though the Account Value has been reduced to zero. All amounts in the table are rounded to the nearest $1.00 in this example.

Assumptions:
The Contract Date is June 27.
The Owner's age on Contract Date is 60 years.
The Initial premium was $100,000; additional premiums of $10,000 were paid in calendar years 2 and 10.
A Nonguaranteed Withdrawal equal to $776 is taken in calendar year 14.
Withdrawals equal to LPA are taken in calendar years 6-13, and calendar years 15+.
No withdrawals are taken that would result in withdrawal charges under the contract.
The RMD is not higher than the LPA in any calendar year.
The Rider remains in effect during the period covered in this example.
 
 
As of January 1 (A)
 
As of February 10 (B)
 
As of June 27 (C)
 
As of October 8 (D)
Calendar Year
 
Covered Person's Age
Withdrawal
Percentage
Benefit
Base
LPA
 
Additional
Premium
Benefit Base after Additional Premium
 
Hypothetical Account Value (E)
Benefit Base after Step-Up
 
Hypothetical Account Value (E)
Annual Withdrawal
Adjusted Non-
Guaranteed
Withdrawal
Benefit Base After Withdrawal
1 (F)
 
60 (F)
4.000% (F)
$100,000 (F)
$2,049 (F)
 
$100,000 (F)
$100,000 (F)
 
$100,000(F)
$100,000(F)
 
$99,625
$0
$0
$100,000
2
 
61
4.050%(G)
$100,000
$4,050
 
$10,000 (H)
$110,000
 
$112,614
$112,614 (I)
 
$112,485
$0
$0
$112,614
3
 
62
4.150% (J)
$112,614
$4,673
 
$0
$112,614
 
$116,985
$116,985
 
$117,755
$0
$0
$116,985
4
 
63
4.250% (J)
$116,985
$4,972
 
$0
$116,985
 
$121,300
$121,300
 
$122,188
$0
$0
$121,300
5
 
64
4.350% (J)
$121,300
$5,277
 
$0
$121,300
 
$119,745
$121,300
 
$120,719
$0
$0
$121,300
6
 
65
4.950% (K)
$121,300
$6,004
 
$0
$121,300
 
$120,719
$121,300
 
$120,123
$6,004
$0
$121,300
7
 
66
4.950%
$121,300
$6,004
 
$0
$121,300
 
$109,554
$121,300
 
$110,171
$6,004
$0
$121,300
8
 
67
4.950%
$121,300
$6,004
 
$0
$121,300
 
$106,250
$121,300
 
$105,343
$6,004
$0
$121,300
9
 
68
4.950%
$121,300
$6,004
 
$0
$121,300
 
$99,338(L)
$121,300
 
$99,982
$6,004(L)
$0
$121,300
 
 
 
 
 
 
 
 
 

VN-60


 
 
As of January 1 (A)
 
As of February 10 (B)
 
As of June 27 (C)
 
As of October 8 (D)
Calendar Year
 
Covered Person's Age
Withdrawal
Percentage
Benefit
Base
LPA
 
Additional
Premium
Benefit Base after Additional Premium
 
Hypothetical Account Value (E)
Benefit Base after Step-Up
 
Hypothetical Account Value (E)
Annual Withdrawal
Adjusted Non-
Guaranteed
Withdrawal
Benefit Base After Withdrawal
10
 
69
4.950%
$121,300
$6,004
 
$10,000(L)
$121,300
 
$102,098(L)
$121,300
 
$102,181
$6,004
$0
$121,300
11
 
70
4.950%
$121,300
$6,004
 
$0
$121,300
 
$97,138
$121,300
 
$97,727
$6,004
$0
$121,300
12
 
71
4.950%
$121,300
$6,004
 
$0
$121,300
 
$88,053
$121,300
 
$88,553
$6,004
$0
$121,300
13
 
72
4.950%
$121,300
$6,004
 
$0
$121,300
 
$84,200
$121,300
 
$83,647
$6,004
$0
$121,300
14
 
73
4.950%
$121,300
$6,004
 
$0
$121,300
 
$78,419
$121,300
 
$78,981
$6,780 (M)
$1,290 (M)
$120,010(M)
15
 
74
4.950%
$120,010
$5,940
 
$0
$120,010
 
$72,923
$120,010
 
$73,461
$5,940
$0
$120,010
16
 
75
4.950%
$120,010
$5,940
 
$0
$120,010
 
$70,221
$120,010
 
$70,531
$5,940
$0
$120,010
17
 
76
4.950%
$120,010
$5,940
 
$0
$120,010
 
$65,236
$120,010
 
$65,375
$5,940
$0
$120,010
18
 
77
4.950%
$120,010
$5,940
 
$0
$120,010
 
$58,246
$120,010
 
$58,752
$5,940
$0
$120,010
19
 
78
4.950%
$120,010
$5,940
 
$0
$120,010
 
$50,171
$120,010
 
$49,888
$5,940
$0
$120,010
20
 
79
4.950%
$120,010
$5,940
 
$0
$120,010
 
$45,705
$120,010
 
$45,702
$5,940
$0
$120,010
21
 
80
4.950%
$120,010
$5,940
 
$0
$120,010
 
$39,364
$120,010
 
$38,972
$5,940
$0
$120,010
22
 
81
4.950%
$120,010
$5,940
 
$0
$120,010
 
$34,022
$120,010
 
$34,012
$5,940
$0
$120,010
23
 
82
4.950%
$120,010
$5,940
 
$0
$120,010
 
$28,914
$120,010
 
$29,175
$5,940
$0
$120,010
24
 
83
4.950%
$120,010
$5,940
 
$0
$120,010
 
$22,305
$120,010
 
$22,391
$5,940
$0
$120,010
25
 
84
4.950%
$120,010
$5,940
 
$0
$120,010
 
$15,628
$120,010
 
$15,559
$5,940
$0
$120,010
26
 
85
4.950%
$120,010
$5,940
 
$0
$120,010
 
$9,330
$120,010
 
$9,298
$5,940
$0
$120,010
27
 
86
4.950%
$120,010
$5,940
 
$0
$120,010
 
$3,525
$120,010
 
$3,554
$5,940 (N)
$0
$120,010
28
 
87
4.950%
$120,010
$5,940
 
$0
$120,010
 
$0
$120,010
 
$0
$5,940
$0
$120,010
29
 
88
4.950%
$120,010
$5,940
 
$0
$120,010
 
$0
$120,010
 
$0
$5,940
$0
$120,010
30
 
89
4.950%
$120,010
$5,940
 
$0
$120,010
 
$0
$120,010
 
$0
$5,940
$0
$120,010
31+
 
90
4.950%
$120,010
$5,940
 
$0
$120,010
 
$0
$120,010
 
$0
$5,940
$0
$120,010

(A)
The covered person's age for each year is as of January 1. Also, on each January 1, the LPA is equal to the applicable Withdrawal Percentage multiplied by the Benefit Base.

(B)
In any year that an additional premium is added, it is assumed to be added on February 10. For purposes of this example, we selected February 10 as the assumed date of additional premium payments. Since premiums may be paid throughout the year, we hoped to accurately demonstrate the effect on the contract values by using a date other than the Contract Anniversary and January 1, which are the two key dates in the GLWB Rider calculations.

(C)
Any step-up is applied on the Contract Anniversary, which is June 27 of each year.


VN-61


(D)
Any withdrawal is assumed to occur one time per year on October 8. For purposes of this example, we selected October 8 as the assumed date of withdrawals. Since withdrawals may be made throughout the year, we hoped to accurately demonstrate the effect on the contract values by using a random date other than the Contract Anniversary and January 1, which are the two key dates in the GLWB Rider calculations.

(E)
The hypothetical Account Value on the Contract Anniversary and on the date of the withdrawal includes deduction of all separate account charges and is before any withdrawal.

(F)
The first calendar year begins on June 27, the Contract Date. On this day, the Benefit Base ($100,000) is set equal to the initial premium ($100,000).
The Withdrawal Percentage (4.00%) is equal to the Age Based Percentage (4.00%) plus the cumulative Deferral Percentage (0%) plus the First Year Deferral Percentage (0%).

Since the covered person is at least age 60 on the date the Rider is issued, the LPA is available. It is calculated as the Withdrawal Percentage multiplied by the Benefit Base:
4.0% (Withdrawal Percentage) x $100,000 (Benefit Base) = $4,000 (LPA).

Since this is the first calendar year, the LPA is multiplied by a pro rata portion of the calendar year that remains. The pro rata factor is the number of days remaining in the calendar year divided by the total number of days in the calendar year:
187 (Days remaining in calendar year) / 365 (Total days in calendar year assuming a non-leap year) x $4,000 (LPA) = $2,049 (1st Year LPA).

(G)
Since no withdrawal was taken in calendar year 1 and since the Contract Date was June 27, the First Year Deferral Percentage is determined as 0.050%. The Withdrawal Percentage (4.050%) is equal to the Age Based Percentage (4.00%) plus the cumulative Deferral Percentage (0%) plus the First Year Deferral Percentage (0.050%).
The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base:
4.050% (Withdrawal Percentage) x $100,000 (Benefit Base) = $4,050 (LPA).

(H)
An additional premium of $10,000 is made during calendar year 2. Since this premium is during the first Contract Year, the Benefit Base is increased by the amount of the premium.
$100,000 (Benefit Base) + $10,000 (additional premium amount) = $110,000 Benefit Base after the additional premium.

(I)
In calendar year 2, the Benefit Base increases to $112,614 because the hypothetical Account Value on the Contract Anniversary ($112,614) is larger than the Benefit Base ($110,000). In calendar years 3 and 4, the Benefit Base again increases to the Account Value, because the Account Value on the Contract Anniversary is larger than the Benefit Base. In calendar years 5 and later, the Benefit Base is always larger than the Account Value on the Contract Anniversary, and thus is not stepped up.

(J)
Since no withdrawal was taken in calendar year 2, the cumulative Deferral Percentage is increased by 0.10%. The Withdrawal Percentage (4.150%) in calendar year 3 is equal to the Age Based Percentage (4.00%) plus the cumulative Deferral Percentage (0.10%) plus the First Year Deferral Percentage (0.050%).
The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base:
4.150% (Withdrawal Percentage) x $112,614 (Benefit Base) = $4,673 (LPA).


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Since no withdrawal was taken in calendar year 3, the cumulative Deferral Percentage is again increased by 0.10%. The Withdrawal Percentage (4.250%) in calendar year 4 is equal to the Age Based Percentage (4.00%) plus the cumulative Deferral Percentage (0.20%) plus the First Year Deferral Percentage (0.050%).
The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base:
4.250% (Withdrawal Percentage) x $116,985 (Benefit Base) = $4,972 (LPA).

Since no withdrawal was taken in calendar year 4, the cumulative Deferral Percentage is again increased by 0.10%. The Withdrawal Percentage (4.350%) in calendar year 5 is equal to the Age Based Percentage (4.00%) plus the cumulative Deferral Percentage (0.30%) plus the First Year Deferral Percentage (0.050%).
The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base:
4.350% (Withdrawal Percentage) x $121,300 (Benefit Base) = $5,277 (LPA).

(K)
Since no withdrawal was taken in calendar year 5, the cumulative Deferral Percentage is again increased by 0.10%. The Age Based Percentage has changed to 4.50% because the covered person is now 65. The Withdrawal Percentage (4.950%) in calendar year 6 is equal to the Age Based Percentage (4.50%) plus the cumulative Deferral Percentage (0.40%) plus the First Year Deferral Percentage (0.050%).
The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base:
4.95% (Withdrawal Percentage) x $121,300 (Benefit Base) = $6,004 (LPA).

Because there is a withdrawal during calendar year 6, the Age Based Percentage is locked at 4.50%.

(L)
An additional premium of $10,000 is made during calendar year 10. Since this premium is paid after the first Contract Year, the premium has no impact on the Benefit Base. All premiums received are immediately applied to the Account Value. For this example, we have used hypothetical Account Values in an effort to reflect market fluctuations between -6% and +6% annually. In the case of this $10,000 additional premium in Contract Year 10, the premium was applied to the Account Value, but because the hypothetical Account Value also reflects market losses, the $10,000 additional premium, assumed to be made on February 10, had declined in value by the Contract Anniversary on June 27.
The evolution of the hypothetical Account Value can be seen by tracking the Account Value from June 27 of year 9 to year 10. The Account Value goes from $99,338 to $102,098 throughout the year, an increase of $2,760. During that Contract Year, there is a $6,004 withdrawal taken on October 8 and a $10,000 premium applied the following February 10; the premium is $3,996 larger than the withdrawal. That means the market experience resulted in a downward movement of $1,236 ($3,996 - $2,760) throughout the year.
  $99,338          Account Value on June 27 of year 9
-   $6,004          Withdrawal on October 8
+$10,000          Premium on February 10
-   $1,236          Market experience
= $102,098       Account Value on June 27 of year 10

(M)
In calendar year 14, a Nonguaranteed Withdrawal in the amount of $776 ($6,780 amount withdrawn - $6,004 LPA) is taken. The Adjusted Nonguaranteed Withdrawal amount is the Nonguaranteed Withdrawal amount multiplied by the greater of 1.0 and the ratio of the Benefit Base to the Account Value, where both values are calculated immediately before the Nonguaranteed Withdrawal. For this calculation, the Account Value before the Nonguaranteed Withdrawal is $72,977, equal to the Account Value before any withdrawal ($78,981) minus the LPA ($6,004).It is calculated as follows:

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$776 (Nonguaranteed Withdrawal amount) x the greater of 1.0 and 1.6622 ($121,300 Benefit Base divided by $72,977 Account Value) = $1,290 (Adjusted Nonguaranteed Withdrawal amount).

The Benefit Base is reduced by the Adjusted Nonguaranteed Withdrawal amount:
$121,300 (Benefit Base) - $1,290 (Adjusted Nonguaranteed Withdrawal amount) = $120,010 Benefit Base after the Nonguaranteed Withdrawal.

(N)
In calendar year 27, the Account Value is reduced to zero after the withdrawal; however, the Benefit Base is greater than zero. Therefore, the Rider enters Guaranteed Payment Phase and payments of the LPA continue.


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Example #2

This example illustrates the Spousal GLWB Rider where withdrawals equal to the LPA as well as Nonguaranteed Withdrawals have been taken and increases to the Withdrawal Percentage have been applied. It also illustrates the termination of the Rider if the Account Value is reduced to zero by a Nonguaranteed Withdrawal. All amounts in the table are rounded to the nearest $1.00 in this example.

Assumptions:

•    The Contract Date is August 8.
•    The covered persons' ages on Contract Date are: owner is 60 and spouse is 57.
•    The Initial premium is $100,000; no additional premiums are paid.
    Withdrawals equal to LPA are taken in calendar years 4-13.
•    A Nonguaranteed Withdrawal equal to $10,000 in calendar year 3.
• Full Account Value is withdrawn in calendar year 14.
•     No withdrawals are taken that would result in withdrawal charges under the contract.
    The RMD is not higher than the LPA in any calendar year.
•    The Rider remains in effect during the period covered in this example.
 
 
As of January 1 (A)
 
As of August 8 (B)
 
As of October 8 (C)
Calendar Year
 
Covered Persons' Ages
Withdrawal
Percentage
Benefit Base
LPA
 
Hypothetical Account Value (D)
Benefit Base after Step-Up
 
Hypothetical Account Value (D)
Annual Withdrawal
Adjusted Nonguaranteed Withdrawal
Benefit Base After Withdrawal
Owner
Spouse
1 (E)
 
60 (E)
57 (E)
N/A
$100,000 (E)
N/A
 
$100,000(E)
$100,000(E)
 
$99,625
$0
$0

$100,000
2
 
61
58
N/A
$100,000
N/A
 
$103,610
$103,610(F)
 
$103,492
$0
$0
$103,610
3
 
62
59
N/A
$103,610
N/A
 
$106,597
$106,597
 
$107,299
$10,000 (G)
$10,000 (G)
$96,597 (G)
4
 
63
60
4.125% (H)
$96,597
$3,586(H)
 
$95,353
$96,597
 
$96,051
$3,586
$0
$96,597
5
 
64
61
4.125%
$96,597
$3,586
 
$90,616
$96,597
 
$91,354
$3,586
$0
$96,597
6
 
65
62
4.125%
$96,597
$3,586
 
$87,767
$96,597
 
$87,334
$3,586
$0
$96,597
7
 
66
63
4.125%
$96,597
$3,586
 
$80,398
$96,597
 
$80,850
$3,586
$0
$96,597
8
 
67
64
4.125%
$96,597
$3,586
 
$78,809
$96,597
 
$78,137
$3,586
$0
$96,597
9
 
68
65
4.125%
$96,597
$3,586
 
$74,550
$96,597
 
$75,033
$3,586
$0
$96,597
10
 
69
66
4.125%
$96,597
$3,586
 
$70,018
$96,597
 
$70,075
$3,586
$0
$96,597
11
 
70
67
4.125%
$96,597
$3,586
 
$67,154
$96,597
 
$67,561
$3,586
$0
$96,597
12
 
71
68
4.125%
$96,597
$3,586
 
$61,415
$96,597
 
$61,764
$3,586
$0
$96,597
13
 
72
69
4.125%
$96,597
$3,586
 
$59,341
$96,597
 
$58,952
$3,586
$0
$96,597
14
 
73
70
4.125%
$96,597
$3,586
 
$55,919
$96,597
 
$56,320
$56,320 (I)
N/A
$0
15
 
74
71
N/A
$0
$0
 
$0
$0
 
$0
$0
$0
$0

VN-65


(A)
The covered persons' ages for each year are as of January 1. Also, each January 1 on or after the LPA Eligibility Date, the LPA is equal to the applicable Withdrawal Percentage multiplied by the Benefit Base.

(B)
Any applicable step-up is applied on the Contract Anniversary, which is August 8 of each year.

(C)
Any applicable withdrawal is assumed to occur one time per year on October 8. For purposes of this example, we selected October 8 as the assumed date of withdrawals. Since withdrawals may be made throughout the year, we hoped to accurately demonstrate the effect on the contract values by using a random date other than the Contract Anniversary and January 1t, which are the two key dates in the GLWB Rider calculations.

(D)
The hypothetical Account Value on the Contract Anniversary and on the date of the withdrawal includes deduction of all separate account charges and is before any withdrawal.

(E)
The first calendar year begins on August 8, the Contract Date. On this day, the Benefit Base ($100,000) is set equal to the initial premium ($100,000). Since the LPA is not available until the LPA Eligibility Date, the Withdrawal Percentage and the LPA are not applicable.

(F)
In calendar year 2, the Benefit Base increases to $103,610 because the hypothetical Account Value on the Contract Anniversary ($103,610) is larger than the Benefit Base ($100,000). In calendar year 3, the Benefit Base again increases to the Account Value, because the Account Value on the Contract Anniversary is larger than the Benefit Base. In calendar years 4 and later, the Benefit Base is always larger than the Account Value on the Contract Anniversary, and thus is not stepped up.

(G)
In calendar year 3, a Nonguaranteed Withdrawal in the amount of $10,000 is taken. The Adjusted Nonguaranteed Withdrawal amount is the Nonguaranteed Withdrawal amount multiplied by the greater of 1.0 or the ratio of the Benefit Base to the Account Value, where both values are calculated immediately before the Nonguaranteed Withdrawal. It is calculated as follows:

$10,000 (Nonguaranteed Withdrawal amount) x the greater of 1.0 and 0.9935 ($106,597 Benefit Base divided by $107,299 Account Value) = $10,000 (Adjusted Nonguaranteed Withdrawal amount).

The Benefit Base is reduced by the Adjusted Nonguaranteed Withdrawal amount:
$106,597 (Benefit Base) - $10,000 (Adjusted Nonguaranteed Withdrawal amount) =$96,597 Benefit Base after the Nonguaranteed Withdrawal.

(H)
January 1 of calendar year 4 is the LPA Eligibility Date; thus, the LPA is now available. Since no withdrawal was taken in calendar year 1 and since the Contract Date was August 8, the First Year Deferral Percentage is 0.025%. Since no withdrawal was taken in calendar year 2, the cumulative Deferral Percentage is 0.10%. The Age Based Percentage (4.00%) is based on the age of the younger covered person. The Withdrawal Percentage (4.125%) is equal to the Age Based Percentage (4.00%) plus the Cumulative Deferral Percentage (0.10%) plus the First Year Deferral Percentage (0.025%).

The LPA is determined as the Withdrawal Percentage multiplied by the Benefit Base multiplied by the Spousal Factor:
4.125% (Withdrawal Percentage) x $96,597 (Benefit Base) x 90% (Spousal Factor) = $3,586 (LPA).

Because there is a withdrawal during calendar year 4, the Age Based Percentage is locked at 4.0%.

(I)
A Nonguaranteed Withdrawal reduces the Account Value to zero in calendar year 14 and the Rider and annuity contract terminate.

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To request a copy of the Statement of Additional Information for the National Integrity Life VAROOM variable annuity dated May 1, 2020, remove this page and mail it to us at the Administrative Office listed in the Glossary.


Name:____________________________

Phone:____________________________

Address:______________________________

______________________________________



VN-68

STATEMENT OF ADDITIONAL INFORMATION

May 1, 2020

VAROOM and VAROOM® II Deferred Flexible Premium Variable Annuities
Issued By National Integrity Life Insurance Company
Through Separate Account I of National Integrity Life Insurance Company


This Statement of Additional Information (SAI) is not a prospectus. It should be read in conjunction with the applicable variable annuity prospectus dated May 1, 2020.

A copy of the prospectuses to which this SAI relates is available at no charge by writing the Administrative Office at National Integrity Life Insurance Company, PO Box 5720 Cincinnati, Ohio 45201-5720, or by calling 1-800-433-1778.

Table of Contents
Page
General Information and History..............................................................................................................
Administration and Distribution of the Contracts.....................................................................................
Performance Data and Illustrations.........................................................................................................
Distributions from Tax-Favored Retirement Programs............................................................................
Financial Statements...............................................................................................................................

General Information and History

National Integrity Life Insurance Company (National Integrity) is a New York life insurance company organized on November 22, 1968. The administrative office is located at 400 Broadway, Cincinnati, Ohio 45202. National Integrity, the depositor of Separate Account I, is a wholly owned subsidiary of Integrity Life Insurance Company (Integrity), an Ohio life insurance company, which is a wholly owned subsidiary of The Western and Southern Life Insurance Company (WSLIC), an Ohio life insurance company organized on February 23, 1888. WSLIC is a wholly owned subsidiary of Western & Southern Financial Group, Inc., an Ohio corporation, which is wholly owned by Western & Southern Mutual Holding Company, an Ohio mutual insurance holding company.

Administration and Distribution of the Contracts

Administration
National Integrity has responsibility for administration of Separate Account I (the Separate Account) and the variable annuity contracts issued through the Separate Account (Contracts). National Integrity has entered into Service Agreements with Integrity and WSLIC to provide certain services, including administrative services for the Separate Account and the Contracts. Compensation for these services, which is paid by National Integrity, is based on the charges and expenses incurred by the service provider, and will reflect actual costs to the extent reasonably possible.

Custodian
Mid Atlantic Trust Company (MATC), 330 South Poplar, Suite 103, Pierre, SD 57501, is the custodian for the exchange-traded funds (ETFs) held by the Subaccounts. MATC provides certain services to the Separate Account, including custody of and accounting services for the ETFs owned by the Separate Account. MATC also facilitates execution of the purchase and sale of the ETFs through broker-dealers.

Underwriter
Touchstone Securities, Inc. (Touchstone Securities), 400 Broadway, Cincinnati, Ohio 45202, an indirect subsidiary of WSLIC and an affiliate of National Integrity, is the principal underwriter of the Contracts. Touchstone Securities is registered under the Securities Exchange Act of 1934 as a broker-dealer and is a member in good standing of the Financial Industry Regulatory Authority (FINRA). The Contracts are offered through Touchstone Securities on a continuous basis. The amount of distribution allowances paid to Touchstone Securities, the principal underwriter, for all variable annuity contracts issued by National Integrity was $2,229,165 in 2019, $2,265,535 in 2018, $1,945,802 in 2017. Touchstone Securities did not retain distribution allowances during these years.




Sales
The Contracts are sold by insurance agents licensed in the states where the Contracts may be lawfully sold.  The agents are also registered representatives of broker-dealers, which are registered under the Securities Exchange Act of 1934 and are members of FINRA.
 
We make payments to the broker-dealer firms that distribute our variable annuity contracts in the form of commissions and other incentives. We may make payments in the form of expense reimbursements or marketing allowances to the broker-dealers that distribute our Contracts in exchange for privileges, including additional or special access to broker-dealers' sales staff, opportunities to provide and attend training and other conferences, and marketing enhancements of our Contracts. The method for calculating any additional compensation may include consideration of the level of sales or assets attributable to the firm. Not all broker-dealers receive additional compensation and the amount of compensation varies by firm. These payments could be significant to a firm, and could create a conflict of interest between the firm or representative and the customer. These payments could provide incentive to a firm or representative to recommend a Contract that is not in a customer’s best interest. We generally choose to compensate broker-dealers that have a strong capability to distribute the Contracts and that are willing to cooperate with our promotional efforts.

The following list includes the names of firms that received expense reimbursement or marketing allowance payments of more than $5,000 with respect to variable annuities sold for National Integrity and its parent company, Integrity Life Insurance Company, during the last calendar year.
American Portfolio Financial Services
Huntington Investment Company, Inc.


Ann Arbor Annuity Exchange, Inc.
Infinex Investments, Inc.



  Arvest Investments, Inc.
LPL Financial LLC



  Ash Brokerage

  M&T Securities, Inc.

  BMO Harris
PNC Investments, LLC


  Cetera Investment Services
The Marketing Alliance, Inc.


  Commerce Brokerage Services, Inc.
Zenith Marketing Group


  Crump Life Insurance Services, Inc.



  Cuso Financial Services




  Fifth Third Securities, Inc.



Financial Independence Group, Inc.




Performance Data and Illustrations

We may provide performance information and illustrations using performance information. Performance information may be based on historical returns of the subaccounts. At any time in the future, performance will likely be higher or lower than in the past. Historical performance does not predict future results.

Performance Data
In advertisements or in information furnished to you, we may provide the average annual total return and the cumulative total return of the units of the subaccounts. The money market option may also from time to time include the yield and effective yield of its units. Performance information is computed separately for each subaccount in accordance with the formulas described below.

Total return reflects all aspects of the return of a subaccount, including the automatic reinvestment of all distributions and the deduction of all charges that apply on an annual basis. Performance represents annualized percentage change in net assets of a subaccount, based on a hypothetical $1,000 investment, the performance of the underlying portfolios and the charges that would have been made during the periods shown. Premium taxes, if applicable, are not reflected.

Average annual total returns are calculated by determining the growth or decline in value of a hypothetical investment in the subaccount over certain periods, including 1, 3, 5, and 10 years and then calculating the annually compounded percentage rate that would have produced the same result if the rate of growth or decline in value had been constant over the period. 

2



Investors should realize that a subaccount's performance is not constant over time, but changes from year to year, and that the average annual returns represent the averages of historical periods as opposed to the actual historical performance of a subaccount during any portion of the period shown. Average annual returns are calculated using this formula:

P (1+T)n = ERV, where P is a hypothetical initial payment of $1,000, T is the average annual total return, n is the number of years, and ERV is the redeemable value at the end of the period.

Standardized returns are average annual total returns calculated from the subaccount inception date, which represents the date the subaccount was available in the Contract. Standardized returns reflect the deduction of all Contract expenses, including underlying fund expenses, the annual separate account charges and the withdrawal charge. The cost of the optional guaranteed lifetime withdrawal benefit rider is not included. If the cost of the rider were included, the returns would be lower.

Non-standardized returns are calculated from the fund inception date, which represents the inception date of the underlying fund, rather than the date it was included in the Contract. Performance that predates the inclusion in the Contract is hypothetical and has been adjusted to include Contract expenses. Two sets of non-standardized returns may be presented, each reflecting the deduction of underlying fund expenses and the annual separate account charge. One set also reflects the withdrawal charge. The cost of the guaranteed lifetime withdrawal benefit rider is not included. If the cost of the rider were included, the returns would be lower.

Cumulative total returns are unaveraged and reflect the simple percentage change in the value of a hypothetical investment in the subaccount over a stated period of time. In addition to the period since inception, cumulative total returns may be calculated on a year-to-date basis at the end of each calendar month in the current calendar year. The last day of the period for year-to-date returns is the last day of the most recent calendar month at the time of publication.

Yields quoted in advertising reflect the change in value of a hypothetical investment in a subaccount over a stated period of time, not taking into account capital gains or losses, or any withdrawal charge. Yields are annualized and stated as a percentage.

Current yield and effective yield are calculated for the money market option. Current yield is based on the change in the value of a hypothetical investment (exclusive of capital changes) over a particular 7-day period, less Contract charges that would have applied during the period (the base period), and stated as a percentage of the investment at the start of the base period (the base period return). The base period return is then annualized by multiplying by 365/7, with the resulting yield figure carried to at least the nearest hundredth of one percent.

Effective yield assumes that all dividends received during an annual period have been reinvested. This compounding effect causes effective yield to be higher than current yield. Calculation of effective yield begins with the same base period return used in the calculation of current yield, which is then annualized to reflect weekly compounding pursuant to the following formula:    

Effective Yield = [(Base Period Return + 1)365/7] – 1

Individualized Illustrations
National Integrity may provide computer-generated illustrations using programs available through third party firms to provide registered representatives and existing or potential Contracts owners with individualized hypothetical illustrations. The illustrations may include contract values and returns for some or all of the subaccounts. Such illustrations may include graphs, bar charts and other types of formats.

Hypothetical values may be based on: (i) the results of a hypothetical contribution to a Contract invested in a single or multiple subaccounts using standardized and non-standardized average annual returns; or (ii) the results of a hypothetical contribution to a Contract using either static or variable assumed rates of return, as allowed by law.


3


Distributions From Tax-Favored Qualified Retirement Programs

Distributions from qualified plans are subject to ordinary income tax. Special rules may apply to withdrawals from certain types of qualified plans, including Roth IRAs. You should consult with your tax adviser to determine how these rules affect the distribution of your benefits.

Section 72(t) of the Internal Revenue Code provides that any amount received under a qualified contract, which is included in income, may be subject to an additional federal tax. The amount of the additional federal tax is equal to 10% of the amount that is included in income. Some distributions will be exempt from the additional federal tax. There is an exception to this 10% additional federal tax for:

1) distributions made on or after the date you (or the Annuitant as applicable) reach age 59 ½;
2)
distributions following your death or disability (or the Annuitant as applicable) (for this purpose “disability” is defined in Code Section 72(m)(7);
3)
distributions paid in series of substantially equal payments made annually (or more frequently) for your life (or life expectancy) or joint lives (or life expectancies) of you and designated beneficiary;
4) distributions made to you after separation from service after attaining age 55 (does not apply to IRAs);
5)
distributions made to you to the extent such distributions do not exceed the amount allowable as a deduction under Code Section 213 to you for amounts paid during the taxable year for medical care (determined without regard to whether you itemize deductions for such taxable year);
6)
distributions to an alternate payee pursuant to a qualified domestic relations order (within the meaning of Code Section 414(p)(1));
7)
distributions from an IRA for the health insurance (as described in Code Section 213(d)(1)(D)) for you and your spouse and dependents if you have received unemployment compensation for at least 12 weeks (this exception will no longer apply after you have been re-employed for at least 60 days);
8)
distributions from an IRA made to you, to the extent such distributions do not exceed your qualified higher education expenses (as defined in Code Section 72(t)(7)) for the tax year;
9)
distributions from an IRA which are qualified first-time homebuyer distributions (as defined in Code Section 72(t)(8));
10)
distributions made to a reservist called to active duty after September 11, 2001, for a period in excess of 179 days (or for an indefinite period), from IRAs or amounts attributable to elective deferrals under a 401(k) plan made during such active period; and
11)
distributions made on account of an IRS levy upon a qualified contract.

With respect to 3) above, if the series of substantially equal periodic payments is modified (other than by reason of death or disability) before the close of the 5-year period beginning with the date of the first payment and after you attain age 59 ½, or before you attain age 59 ½, then the tax for the year of the modification is increased by the 10% additional federal tax, plus interest for the tax years in which the exception was used. You should consult with your tax adviser before taking any partial withdrawals from your Contract.

Participants in qualified plans (other than IRAs), with the exception of five-percent owners, must begin receiving distributions by April 1 of the calendar year following the later of either (i) the year in which the participant reaches the qualified age under IRS regulations (for an owner that reached age 70½ on or before December 31, 2019, age 70½, and for an owner that reaches age 70½ on or after January 1, 2020, age 72) or (ii) the calendar year in which the participant retires. Owners of traditional IRAs and 5% owners of qualified plans must begin receiving distributions by April 1 of the calendar year following the year in which the owner or participant reaches the qualified age under IRS regulations. Owners of Roth IRAs are not required to take distributions during their lifetime. Distributions from certain TSA plans can be deferred until age 75. After death, distribution rules apply to traditional and Roth IRAs. If you do not take mandatory distributions, you may owe a 50% penalty tax on any difference between the required distribution amount and the amount distributed.

Distributions from qualified plans (other than traditional IRAs) in the form of a lump sum settlement, partial withdrawal, or periodic annuity payments for a fixed period of fewer than 10 years, are subject to mandatory federal income tax withholding of 20% of the taxable amount of the distribution, unless (i) the payee directs the transfer of such amounts to another qualified plan or traditional IRA; or (ii) the payment is a minimum distribution required under the Internal Revenue Code. The taxable amount is the amount of the distribution less the amount

4


allocable to after-tax contributions. All other types of taxable distributions are subject to a 10% federal income tax withholding unless the payee elects not to have withholding apply.

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which was enacted on March 27, 2020, contains provisions relaxing certain requirements applicable to distributions from certain retirement plans, individual retirement accounts and individual retirement annuities. Among other things, it waives required minimum distribution payments for 2020 from certain types of retirement plans.  The CARES Act also waives certain early withdrawal penalties on withdrawals of up to $100,000 by participants in certain types of retirement plans, who meet applicable eligibility requirements (generally that an individual, or an individual’s spouse or dependents has been diagnosed with coronavirus, or the individual has otherwise experienced adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus, among other things).

We are not permitted to make distributions from a Contract unless a request has been made. It is therefore your responsibility to comply with the minimum distribution rules. You should consult your tax adviser regarding these rules and their proper application.

The above description of the minimum distribution requirements and the federal income tax consequences of distributions from tax-favored retirement plans, which may be funded by the Contract, is only a brief summary and is not intended as tax advice. The rules governing the provisions of plans are extremely complex and often difficult to comprehend. If you do not fully comply with all rules, which are subject to change, you may suffer adverse tax consequences. You should consult a qualified and competent tax adviser prior to adopting a plan or purchasing a Contract in connection with a tax-favored plan.

Financial Statements

The financial statements of Separate Account I of National Integrity Life Insurance Company as of December 31, 2019, and for the periods indicated in the financial statements, included in this Statement of Additional Information have been audited by Ernst & Young LLP, 221 East 4th Street, Suite 2900, Cincinnati, Ohio 45202, independent registered public accounting firm, as set forth in their reports included thereon. These financial statements are included in this registration statement in reliance on the reports of Ernst & Young LLP given on the authority of such firm as experts in accounting and auditing.

The statutory-basis financial statements of National Integrity Life Insurance Company as of December 31, 2019 and 2018 and for each of the three years in the period ended December 31, 2019, and the statutory-basis financial statements of The Western and Southern Life Insurance Company (WSLIC) as of December 31, 2019 and 2018 and for each of the three years in the period ended December 31, 2019, included in this Statement of Additional Information have been audited by Ernst & Young LLP, 221 East 4th Street, Suite 2900, Cincinnati, Ohio 45202, independent auditors, as set forth in their reports included thereon. These financial statements are included in this registration statement in reliance on the reports of Ernst & Young LLP given on the authority of such firm as experts in accounting and auditing.

You should distinguish the statutory-basis financial statements of National Integrity from the financial statements of the Separate Account and consider the National Integrity statutory-basis financial statements only as they relate to the ability of National Integrity to meet its obligations under the Contracts. You should consider the statutory-basis financial statements of WSLIC as bearing only on the ability of WSLIC to meet its obligations under its guarantee to National Integrity policyholders dated March 3, 2000. You should not consider the National Integrity or WSLIC statutory-basis financial statements as relating to the investment performance of the assets held in the Separate Account.


5


FINANCIAL STATEMENTS

Separate Account I of National Integrity Life Insurance Company
Year Ended December 31, 2019
With Report of Independent Registered
Public Accounting Firm






Separate Account I
of
National Integrity Life Insurance Company

Financial Statements

Year Ended December 31, 2019




Contents
 
 
Report of Independent Registered Public Accounting Firm
 
 
Financial Statements
 
 
 
Statements of Assets and Liabilities as of December 31, 2019
Statements of Operations for the Year ended December 31, 2019
Statements of Changes in Net Assets for the Year ended December 31, 2019
Statements of Changes in Net Assets for the Year ended December 31, 2018
Notes to Financial Statements    



Report of Independent Registered Public Accounting Firm

The Board of Directors of National Integrity Life Insurance Company and
The Contract Owners of Separate Account I of National Integrity Life Insurance Company

Opinion on the Financial Statements
We have audited the accompanying statements of assets and liabilities of each of the subaccounts listed in Appendix A that comprise Separate Account I of National Integrity Life Insurance Company (the Separate Account), as of December 31, 2019, the related statements of operations and the statements of changes in net assets for each the periods indicated in Appendix A, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of each subaccount as of December 31, 2019, the results of its operations and changes in its net assets for each of the periods indicated in Appendix A, in conformity with U.S. generally accepted accounting principles.
Basis for Opinion
These financial statements are the responsibility of the Separate Account’s management. Our responsibility is to express an opinion on each of the subaccounts’ financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Separate Accounts in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of December 31, 2019, by correspondence with the fund companies or their transfer agents, as applicable. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.


/s/ Ernst & Young LLP
We have served as the Separate Account’s auditor since 1993.
Cincinnati, Ohio
April 20, 2020



1


Appendix A
Subaccounts comprising Separate Account I of National Integrity Life Insurance Company
Subaccounts
Statement of operations
Statement of change in net assets
American Funds Insurance Series
 


Non-Affiliated Class 2
For the year ended December 31, 2019
For each of the two years in the period ended December 31, 2019

American Funds I.S. Managed Risk Asset Allocation Fund
Non-Affiliated Class 4
American Funds I.S. Bond Fund
 
 
American Funds I.S. Capital Income Builder Fund
 
 
American Funds I.S. Global Growth Fund
 
 
American Funds I.S. Growth Fund
 
 
American Funds I.S. Growth-Income Fund
 
 
American Funds I.S. New World Fund
 
 
 
 
 
BlackRock Variable Series Funds
 
 
Non-Affiliated Class 3
 
 
BlackRock Capital Appreciation V.I. Fund
 
 
BlackRock Global Allocation V.I. Fund
 
 
BlackRock High Yield V.I. Fund
 
 
BlackRock Total Return V.I. Fund
 
 
 
 
 
Columbia Funds Variable Portfolios
 
 
Non-Affiliated Class 1
 
 
Columbia VP - Select Mid Cap Value Fund
 
 
Non-Affiliated Class 2
 
 
Columbia VP - Small Cap Value Fund
 
 
 
 
 
DWS Investments VIT Funds
 
 
Non-Affiliated Class A:
 
 
DWS Small Cap Index VIP Fund
 
 
Non-Affiliated Class B:
 
 
DWS Small Cap Index VIP Fund
 
 
 
 
 
Fidelity Variable Insurance Products
 
 
Non-Affiliated Initial Class:
 
 
Fidelity VIP Balanced Portfolio
 
 
Fidelity VIP Overseas Portfolio
 
 
Fidelity VIP Equity-Income Portfolio
 
 
Fidelity VIP Growth Portfolio
 
 
Fidelity VIP High Income Portfolio
 
 
Fidelity VIP Asset Manager Portfolio
 
 
Fidelity VIP Contrafund® Portfolio
 
 
Fidelity VIP Index 500 Portfolio
 
 
Fidelity VIP Investment Grade Bond Portfolio
 
 
Fidelity VIP Government Money Market
 
 

2


Non-Affiliated Service Class:
For the year ended December 31, 2019
For each of the two years in the period ended December 31, 2019
Fidelity VIP Growth Portfolio
Fidelity VIP Mid Cap Portfolio
Non-Affiliated Service Class 2:
 
 
Fidelity VIP Asset Manager Portfolio
 
 
Fidelity VIP Balanced Portfolio
 
 
Fidelity VIP Contrafund® Portfolio
 
 
Fidelity VIP Disciplined Small Cap Portfolio
 
 
Fidelity VIP Equity-Income Portfolio
 
 
Fidelity VIP Freedom 2010 Portfolio
 
 
Fidelity VIP Freedom 2015 Portfolio
 
 
Fidelity VIP Freedom 2020 Portfolio
 
 
Fidelity VIP Freedom 2025 Portfolio
 
 
Fidelity VIP Freedom 2030 Portfolio
 
 
Fidelity VIP Growth Portfolio
 
 
Fidelity VIP High Income Portfolio
 
 
Fidelity VIP Index 500 Portfolio
 
 
Fidelity VIP Investment Grade Bond Portfolio
 
 
Fidelity VIP Mid Cap Portfolio
 
 
Fidelity VIP Overseas Portfolio
 
 
Fidelity VIP Target Volatility Portfolio
 
 
 
 
 
Franklin Templeton VIP Trust
 
 
Non-Affiliated Class 1:
 
 
Franklin Growth and Income VIP Fund
 
 
Franklin Income VIP Fund
 
 
Non-Affiliated Class 2:
 
 
Franklin Growth and Income VIP Fund
 
 
Franklin Income VIP Fund
 
 
Franklin Large Cap Growth VIP Fund
 
 
Franklin Mutual Shares VIP Fund
 
 
Franklin Small Cap Value VIP Fund
 
 
Templeton Foreign VIP Fund
 
 
Templeton Global Bond VIP Fund
 
 
Templeton Growth VIP Fund
 
 
 
 
 
Rydex Variable Trust (Guggenheim Variable Insurance Funds)
 
 
Investor Class:
 
 
Guggenheim VT Global Managed Futures Strategy Fund
 
 
Guggenheim VT Multi-Hedge Strategies Fund
 
 
Guggenheim VT Long Short Equity Fund
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

3


iShares Trust
For the year ended December 31, 2019
For each of the two years in the period ended December 31, 2019
ETF Shares:
iShares® Core S&P 500 ETF
iShares® Core S&P Mid-Cap ETF
 
 
iShares® Core S&P Small-Cap ETF
 
 
iShares® Core U.S. Aggregate Bond ETF
 
 
iShares® iBoxx $ High Yield Corporate Bond ETF
 
 
iShares® Intermediate-Term Corporate Bond ETF
 
 
iShares® International Treasury Bond ETF
 
 
iShares® S&P 500 Growth ETF
 
 
iShares® S&P 500 Value ETF
 
 
iShares® TIPS Bond ETF
 
 
 
 
 
Invesco (AIM) Variable Insurance Funds
 
 
Non-Affiliated Class 2:
 
 
Invesco V.I. American Franchise Fund
 
 
Invesco V.I. American Value Fund
 
 
Invesco V.I. Comstock Fund
 
 
Invesco V.I. International Growth Fund
 
 
Invesco V.I. Mid Cap Growth Fund
 
 
 
 
 
JPMorgan Insurance Trust
 
 
Non-Affiliated Class 1:
 
 
JP Morgan IT Mid Cap Value
 
 
 
 
 
Morgan Stanley Variable Insurance Funds, Inc.
 
 
Non-Affiliated Class 1:
 
 
Morgan Stanley VIF Emerging Markets Debt Portfolio
 
 
Morgan Stanley VIF U.S. Real Estate Portfolio
 
 
Non-Affiliated Class 2:
 
 
Morgan Stanley VIF Emerging Markets Debt Portfolio
 
 
Morgan Stanley VIF Emerging Markets Equity Portfolio
 
 
Morgan Stanley VIF U.S. Real Estate Portfolio
 
 
 
 
 
Pimco Variable Insurance Trust
 
 
Advisor Class:
 
 
PIMCO VIT All Asset Portfolio
 
 
PIMCO VIT International Bond Portfolio (US Dollar Hedged)
 
 
PIMCO VIT CommodityRealReturn® Strategy Portfolio
 
 
PIMCO VIT Long-Term U.S. Government Portfolio
 
 
PIMCO VIT Low Duration Portfolio
 
 
PIMCO VIT Real Return Portfolio
 
 
PIMCO VIT Total Return Portfolio
 
 
 
 
 
 
 
 
 
 
 

4


Northern Lights Variable Trust
For the year ended December 31, 2019
For each of the two years in the period ended December 31, 2019
Non-Affiliated Class 3:
TOPS® Managed Risk Moderate Growth ETF Portfolio
 
 
 
Touchstone Variable Series Trust
 
 
Affiliated (*Service Class):
 
 
*Touchstone VST Aggressive ETF Fund
 
 
*Touchstone VST Conservative ETF Fund
 
 
*Touchstone VST Moderate ETF Fund
 
 
 
 
 
The Vanguard Index Funds
 
 
ETF Shares:
 
 
Vanguard® Developed Markets Index Fund, ETF Shares
 
 
Vanguard® Dividend Appreciation Index Fund, ETF Shares
 
 
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
 
 
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
 
 
Vanguard® Large-Cap Index Fund, ETF Shares
 
 
Vanguard® Mega Cap Index Fund, ETF Shares
 
 
Vanguard® Real Estate Index Fund, ETF Shares
 
 
Vanguard® Short-Term Bond Index Fund, ETF Shares
 
 
Vanguard® Total Bond Market Index Fund, ETF Shares
 
 
Fidelity Variable Insurance Products
For the period from July 12, 2019 (commencement of operations) through December 31, 2019

Non-Affiliated Service Class 2:
Fidelity VIP Bond Index Portfolio
Fidelity VIP Extended Market Index Portfolio
Fidelity VIP International Index Portfolio
Fidelity VIP Total Market Index Portfolio
 
 
 
 
 
Touchstone Variable Series Trust
For the period from January 1, 2019 through July 11, 2019

For the year ended December 31, 2018 and the period from January 1, 2019 through July 11, 2019

Affiliated:
Touchstone VST Active Bond Fund
Touchstone VST Focused Fund
Touchstone VST Large Cap Core Equity Fund
Touchstone Variable Series Trust
For the period from July 12, 2019 (commencement of operations) through December 31, 2019

Affiliated (*Service Class):
*Touchstone VST Bond Fund
*Touchstone VST Common Stock Fund
 
 
 



5


Separate Account I
of
National Integrity Life Insurance Company
Statements of Assets and Liabilities
December 31, 2019
Subaccount
 Investments
at fair value
 
 Receivable from
 (payable to)
 the general account
 of National Integrity
 Net Assets
 
 Unit Value Range
(Lowest to Highest)
 Units Outstanding
Affiliated:
 
 
 
 
 
 
 
 
 
Touchstone VST Aggressive ETF Fund
$
5,628,414


$
5

$
5,628,419


$
18.15

to
$
27.04

249,762

Touchstone VST Bond Fund (b)
2,129,061

 
(4
)
2,129,057

 
10.17

to
10.20

209,220

Touchstone VST Common Stock Fund (b)
19,789,047

 
3

19,789,050

 
10.78

to
10.81

1,833,714

Touchstone VST Conservative ETF Fund
5,619,430


3

5,619,433


14.74

to
18.42

330,844

Touchstone VST Moderate ETF Fund
6,854,757


(8
)
6,854,749


16.70

to
21.04

375,718

Non-Affiliated Initial Class:
 
 
 
 
 



 
Fidelity VIP Balanced Portfolio
2,022,544



2,022,544


20.72

to
33.75

75,815

Fidelity VIP Overseas Portfolio
1,222,753


(6
)
1,222,747


11.80

to
47.53

36,289

Fidelity VIP Equity-Income Portfolio
7,810,013


1

7,810,014


31.28

to
110.36

92,599

Fidelity VIP Growth Portfolio
5,227,289


1

5,227,290





181.86

28,743

Fidelity VIP High Income Portfolio
1,742,800



1,742,800





31.00

56,225

Fidelity VIP Asset Manager Portfolio
2,776,765



2,776,765





60.68

45,757

Fidelity VIP Contrafund® Portfolio
13,550,838



13,550,838


50.00

to
98.42

177,867

Fidelity VIP Index 500 Portfolio
4,689,645


3

4,689,648


23.34

to
83.03

100,901

Fidelity VIP Investment Grade Bond Portfolio
1,426,180


1

1,426,181


12.41

to
38.87

75,559

Fidelity VIP Government Money Market
3,369,377


(4
)
3,369,373


9.53

to
9.98

343,935

Non-Affiliated Service Class:
 
 
 
 
 



 
Fidelity VIP Growth Portfolio
323,204


(3
)
323,201





26.49

12,200

Fidelity VIP Mid Cap Portfolio
2,892,056


(2
)
2,892,054


68.96

to
72.23

41,338

Non-Affiliated Service Class 2:
 
 
 
 
 





 
Fidelity VIP Asset Manager Portfolio
1,103,127


(7
)
1,103,120


15.40

to
22.06

64,872

Fidelity VIP Balanced Portfolio
10,559,692


(3
)
10,559,689


18.93

to
27.98

498,139

Fidelity VIP Bond Index Portfolio (b)
84,928

 

84,928

 
10.15

to
10.15

8,369

Fidelity VIP Contrafund® Portfolio
17,645,539



17,645,539


21.59

to
40.90

667,142

Fidelity VIP Disciplined Small Cap Portfolio
1,546,404



1,546,404


17.07

to
23.05

86,525

Fidelity VIP Equity-Income Portfolio
3,356,255


(6
)
3,356,249


15.62

to
26.16

176,334

Fidelity VIP Extended Market Index Portfolio (b)
36,575

 

36,575

 
10.55

to
10.55

3,467

Fidelity VIP Freedom 2010 Portfolio
396,680


7

396,687


14.94

to
15.56

25,948

Fidelity VIP Freedom 2015 Portfolio
413,497


2

413,499


15.41

to
16.59

26,332

Fidelity VIP Freedom 2020 Portfolio
652,544


1

652,545


15.45

to
16.44

41,985

Fidelity VIP Freedom 2025 Portfolio
1,968,579


(1
)
1,968,578


16.32

to
17.38

120,000

Fidelity VIP Freedom 2030 Portfolio
363,113


5

363,118


16.32

to
19.60

21,761

Fidelity VIP Growth Portfolio
3,900,030


(2
)
3,900,028


22.95

to
34.46

136,009

Fidelity VIP High Income Portfolio
6,807,295


(6
)
6,807,289


14.81

to
26.68

336,321

Fidelity VIP Index 500 Portfolio
29,166,158


(1
)
29,166,157


21.89

to
32.38

1,273,461

Fidelity VIP International Index Portfolio (b)
1,511

 
1

1,512

 
10.65

to
10.65

142

Fidelity VIP Investment Grade Bond Portfolio
15,004,688


7

15,004,695


12.12

to
18.64

1,065,397

Fidelity VIP Mid Cap Portfolio
8,715,718


(5
)
8,715,713


19.17

to
45.68

335,299

Fidelity VIP Overseas Portfolio
2,672,888


(1
)
2,672,887


11.24

to
22.72

196,054

Fidelity VIP Target Volatility Portfolio
485,798



485,798


13.32

to
13.65

36,375

Non-Affiliated Class 1:
 
 
 
 
 





 
Columbia VP – Select Mid Cap Value Fund (a)
1,538,826


(9
)
1,538,817


18.69

to
19.56

80,136

Franklin Growth and Income VIP Fund
1,750,810


3

1,750,813


30.72

to
30.72

56,994

Franklin Income VIP Fund
3,052,864


(3
)
3,052,861


28.69

to
29.27

106,352

JP Morgan IT Mid Cap Value
629,908


(3
)
629,905


25.85

to
39.09

17,757

Morgan Stanley VIF Emerging Markets Debt Portfolio
107,162


2

107,164


27.67

to
35.02

3,259

Morgan Stanley VIF U.S. Real Estate Portfolio
714,048


(3
)
714,045


16.83

to
49.74

17,178

Non-Affiliated Class 2:
 
 
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
2,148,429


4

2,148,433


13.15

to
13.61

162,954

Columbia VP – Small Cap Value Fund
1,750,674


1

1,750,675


20.35

to
28.58

64,562

Franklin Growth and Income VIP Fund
4,983,198


1

4,983,199


17.39

to
31.25

214,960

Franklin Income VIP Fund
14,512,892


(3
)
14,512,889


15.12

to
29.19

841,738

Franklin Large Cap Growth VIP Fund
5,003,122


(4
)
5,003,118


21.24

to
35.12

169,663

Franklin Mutual Shares VIP Fund
9,919,352


(3
)
9,919,349


14.25

to
28.91

592,600

Franklin Small Cap Value VIP Fund
1,103,579


6

1,103,585


18.42

to
23.32

57,571

Invesco V.I. American Franchise Fund
356,087

 

356,087

 
25.61

to
38.17

11,579

Invesco V.I. American Value Fund
7,406,337



7,406,337


18.52

to
20.96

386,043

Invesco V.I. Comstock Fund
3,721,654


1

3,721,655


17.19

to
33.97

187,984

Invesco V.I. International Growth Fund
2,145,714



2,145,714


13.06

to
13.59

161,872

Invesco V.I. Mid Cap Growth Fund
305,347



305,347


15.17

to
15.40

20,092

Templeton Foreign VIP Fund
4,336,311


(3
)
4,336,308


9.90

to
22.58

365,814

Templeton Global Bond VIP Fund
585,240


(3
)
585,237


9.42

to
9.68

61,666

Templeton Growth VIP Fund
1,233,773


5

1,233,778


10.94

to
23.32

75,407

Morgan Stanley VIF Emerging Markets Debt Portfolio
953,060



953,060


12.98

to
26.56

59,739

Morgan Stanley VIF Emerging Markets Equity Portfolio
2,322,799



2,322,799


9.26

to
39.99

145,981

Morgan Stanley VIF U.S. Real Estate Portfolio
2,526,380


3

2,526,383


12.90

to
39.45

169,088

 



(a) Name Change. See Note 1.
 
6
(b) New Underlying Fund. See Note 1
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Assets and Liabilities (continued)
December 31, 2019
Subaccount
 Investments
at fair value
 
 Receivable from
 (payable to)
 the general account
 of National Integrity
 Net Assets
 
 Unit Value Range
(Lowest to Highest)
 Units Outstanding
Non-Affiliated Class 3:
 
 
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
$
3,163,985


$
(6
)
$
3,163,979


$
23.16

to
$
24.09

134,364

BlackRock Global Allocation V.I. Fund
612,543



612,543


12.79

to
13.48

47,393

BlackRock High Yield V.I. Fund
210,299



210,299


12.09

to
12.27

17,341

BlackRock Total Return V.I. Fund
302,668


(3
)
302,665


10.50

to
10.58

28,811

TOPS® Managed Risk Moderate Growth ETF Portfolio
1,152,671


1

1,152,672


11.91

to
12.24

96,638

Non-Affiliated Class 4:
 
 
 
 
 





 
American Funds I.S. Bond Fund
679,668


3

679,671


10.47

to
10.62

64,836

American Funds I.S. Capital Income Builder Fund
3,031,500



3,031,500


11.16

to
11.45

269,536

American Funds I.S. Global Growth Fund
2,254,642


4

2,254,646


16.67

to
17.14

133,112

American Funds I.S. Growth Fund
2,567,271


1

2,567,272


19.82

to
20.37

128,388

American Funds I.S. Growth-Income Fund
3,012,851


5

3,012,856


17.72

to
18.21

168,554

American Funds I.S. New World Fund
936,963


1

936,964


12.48

to
12.79

74,304

Non-Affiliated Class A:
 
 
 
 
 





 
DWS Small Cap Index VIP Fund
431,383


3

431,386


33.58

to
35.28

12,471

Non-Affiliated Class B:
 
 
 
 
 





 
DWS Small Cap Index VIP Fund
1,677,648


5

1,677,653


18.57

to
32.13

75,046

Advisor Class:
 
 
 
 
 





 
PIMCO VIT All Asset Portfolio
1,532,510


(7
)
1,532,503


12.94

to
14.52

109,953

PIMCO VIT International Bond Portfolio (US Dollar Hedged)
40,211


1

40,212


10.96

to
11.12

3,650

PIMCO VIT CommodityRealReturn® Strategy Portfolio
1,280,147


(3
)
1,280,144


3.90

to
5.46

318,288

PIMCO VIT Long-Term U.S. Government Portfolio
200,343


6

200,349


11.30

to
11.65

17,362

PIMCO VIT Low Duration Portfolio
2,124,795


(4
)
2,124,791


10.28

to
11.92

189,245

PIMCO VIT Real Return Portfolio
905,845


3

905,848


10.96

to
12.72

74,088

PIMCO VIT Total Return Portfolio
19,493,645


5

19,493,650


11.85

to
14.84

1,375,761

Investor Class:
 
 
 
 
 





 
Guggenheim VT Global Managed Futures Strategy Fund
167,848



167,848


6.17

to
7.76

26,773

Guggenheim VT Multi-Hedge Strategies Fund
344,756


7

344,763


8.43

to
10.77

39,806

Guggenheim VT Long Short Equity Fund
71,584



71,584


9.87

to
11.94

7,059

ETF Shares:
 
 
 
 
 





 
iShares® Core S&P 500 ETF
18,622,010


(1
)
18,622,009


61.04

to
65.80

299,640

iShares® Core S&P Mid-Cap ETF
5,399,323


(1
)
5,399,322


51.22

to
56.58

100,670

iShares® Core S&P Small-Cap ETF
2,869,836



2,869,836


54.16

to
59.73

50,686

iShares® Core U.S. Aggregate Bond ETF
581,931


7

581,938


25.15

to
28.74

22,975

iShares® iBoxx $ High Yield Corporate Bond ETF
74,275


2

74,277


31.74

to
34.05

2,265

iShares® Intermediate-Term Corporate Bond ETF
715,836


2

715,838


27.40

to
29.40

26,046

iShares® International Treasury Bond ETF
2,325,631


3

2,325,634


21.93

to
23.82

104,140

iShares® S&P 500 Growth ETF
2,339,276


(1
)
2,339,275


65.12

to
72.17

35,198

iShares® S&P 500 Value ETF
519,766


1

519,767


54.71

to
59.22

9,195

iShares® TIPS Bond ETF
126,674


2

126,676


22.69

to
24.35

5,517

Vanguard® Developed Markets Index Fund, ETF Shares
2,603,073


3

2,603,076


32.11

to
38.62

71,476

Vanguard® Dividend Appreciation Index Fund, ETF Shares
1,048,545



1,048,545


54.58

to
58.55

18,989

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
222,072


2

222,074


23.91

to
29.81

7,934

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
61,060


1

61,061


31.92

to
34.14

1,882

Vanguard® Large-Cap Index Fund, ETF Shares
727,554



727,554


60.50

to
65.24

11,825

Vanguard® Mega Cap Index Fund, ETF Shares
140,191


3

140,194


61.96

to
66.98

2,201

Vanguard® Real Estate Index Fund, ETF Shares
243,969


(1
)
243,968


46.76

to
50.17

5,148

Vanguard® Short-Term Bond Index Fund, ETF Shares
14,575



14,575


22.84

to
24.42

618

Vanguard® Total Bond Market Index Fund, ETF Shares
17,584,050


4

17,584,054


25.15

to
28.83

685,904

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 


(a) Name Change. See Note 1.
 
7
(b) New Underlying Fund. See Note 1
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Operations
For the Year Ended December 31, 2019
 
Investment
 
 
 
 
 
 
 
 
 Income
Expenses
 
Realized and unrealized gain (loss) on investments
 
Subaccount
 Reinvested
dividends
Mortality and
expense risk and
administrative
charges
Net investment
income (loss)
Realized gain (loss)
on sales of
investments
Realized gain
distributions
Change in net unrealized
appreciation
(depreciation)
during the period
Net realized and
unrealized gain (loss)
on investments
Net increase
(decrease) in net
assets resulting from
operations
Affiliated:
 
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund (c)
$
86,409

$
19,138

$
67,271

$
(8,760
)
$

$
83,981

$
75,221

$
142,492

Touchstone VST Aggressive ETF Fund
92,037

78,605

13,432

179,469

302,255

538,594

1,020,318

1,033,750

Touchstone VST Bond Fund (b)
27,618

15,417

12,201

5,407


26,762

32,169

44,370

Touchstone VST Common Stock Fund (b)
103,101

124,922

(21,821
)
(9,030
)
213,008

1,166,216

1,370,194

1,348,373

Touchstone VST Conservative ETF Fund
149,865

90,016

59,849

(47,938
)
30,835

737,935

720,832

780,681

Touchstone VST Focused Fund (c)
104,395

116,885

(12,490
)
282,833

656,494

1,493,513

2,432,840

2,420,350

Touchstone VST Large Cap Core Equity Fund (c)
42,339

25,826

16,513

394,901

579,998

(501,489
)
473,410

489,923

Touchstone VST Moderate ETF Fund
145,251

102,753

42,498

(208,678
)
349,204

963,493

1,104,019

1,146,517

Non-Affiliated Initial Class:
















Fidelity VIP Balanced Portfolio
33,024

25,977

7,047

22,419

87,602

269,782

379,803

386,850

Fidelity VIP Overseas Portfolio
19,727

16,077

3,650

20,343

42,525

202,304

265,172

268,822

Fidelity VIP Equity-Income Portfolio
147,382

100,776

46,606

86,879

475,562

1,070,784

1,633,225

1,679,831

Fidelity VIP Growth Portfolio
12,736

66,588

(53,852
)
332,913

302,192

779,023

1,414,128

1,360,276

Fidelity VIP High Income Portfolio
88,082

22,491

65,591

349


129,837

130,186

195,777

Fidelity VIP Asset Manager Portfolio
47,446

36,654

10,792

(3,007
)
114,444

291,287

402,724

413,516

Fidelity VIP Contrafund® Portfolio
58,756

177,546

(118,790
)
751,307

1,487,661

1,228,908

3,467,876

3,349,086

Fidelity VIP Index 500 Portfolio
86,002

60,946

25,056

290,696

66,605

762,756

1,120,057

1,145,113

Fidelity VIP Investment Grade Bond Portfolio
38,688

20,182

18,506

2,838


94,004

96,842

115,348

Fidelity VIP Government Money Market
115,969

81,051

34,918





34,918

Non-Affiliated Service Class:
















Fidelity VIP Growth Portfolio
536

4,650

(4,114
)
43,919

22,000

31,912

97,831

93,717

Fidelity VIP Mid Cap Portfolio
22,258

38,710

(16,452
)
49,020

318,333

207,075

574,428

557,976

Non-Affiliated Service Class 2:
















Fidelity VIP Asset Manager Portfolio
16,917

14,395

2,522

(16,068
)
40,284

119,471

143,687

146,209

Fidelity VIP Balanced Portfolio
149,808

131,068

18,740

117,376

421,855

1,279,052

1,818,283

1,837,023

Fidelity VIP Bond Index Portfolio (b)
1,300

250

1,050

(6
)
251

(1,749
)
(1,504
)
(454
)
Fidelity VIP Contrafund® Portfolio
36,537

254,374

(217,837
)
498,701

2,042,138

2,070,548

4,611,387

4,393,550

Fidelity VIP Disciplined Small Cap Portfolio
11,579

20,038

(8,459
)
(24,822
)
116,123

186,289

277,590

269,131

Fidelity VIP Equity-Income Portfolio
58,087

44,415

13,672

9,875

199,564

468,016

677,455

691,127

Fidelity VIP Extended Market Index Portfolio (b)
321

194

127

7

347

2,622

2,976

3,103

Fidelity VIP Freedom 2010 Portfolio
7,508

6,130

1,378

8,626

18,991

27,011

54,628

56,006

Fidelity VIP Freedom 2015 Portfolio
7,200

6,496

704

2,099

30,287

29,412

61,798

62,502

Fidelity VIP Freedom 2020 Portfolio
11,284

9,710

1,574

7,655

34,457

60,875

102,987

104,561

Fidelity VIP Freedom 2025 Portfolio
33,508

27,895

5,613

5,510

50,868

255,525

311,903

317,516

Fidelity VIP Freedom 2030 Portfolio
5,984

6,862

(878
)
52,091

20,566

20,929

93,586

92,708

Fidelity VIP Growth Portfolio
1,847

48,683

(46,836
)
91,572

210,372

692,311

994,255

947,419

Fidelity VIP High Income Portfolio
342,353

75,587

266,766

96,722


(33,801
)
62,921

329,687

Fidelity VIP Index 500 Portfolio
473,144

397,331

75,813

1,227,831

398,652

5,073,245

6,699,728

6,775,541

Fidelity VIP International Index Portfolio (b)
30

1

29


3

28

31

60



(a) Name Change. See Note 1.
 
8
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Operations (continued)
For the Year Ended December 31, 2019
 
Investment
 
 
 
 
 
 
 
 
 Income
Expenses
 
Realized and unrealized gain (loss) on investments
 
Subaccount
 Reinvested
dividends
Mortality and
expense risk and
administrative
charges
Net investment
income (loss)
Realized gain (loss)
on sales of
investments
Realized gain
distributions
Change in net unrealized
appreciation
(depreciation)
during the period
Net realized and
unrealized gain (loss)
on investments
Net increase
(decrease) in net
assets resulting from
operations
Non-Affiliated Service Class 2 (continued):
 
 
 
 
 
 
 
 
Fidelity VIP Investment Grade Bond Portfolio
$
376,328

$
215,275

$
161,053

$
22,450

$

$
904,085

$
926,535

$
1,087,588

Fidelity VIP Mid Cap Portfolio
54,881

110,394

(55,513
)
(96,039
)
754,618

765,703

1,424,282

1,368,769

Fidelity VIP Overseas Portfolio
38,120

46,219

(8,099
)
237,667

159,068

399,899

796,634

788,535

Fidelity VIP Target Volatility Portfolio
6,333

7,034

(701
)
888

11,092

59,831

71,811

71,110

Non-Affiliated Class 1:
















Columbia VP – Select Mid Cap Value Fund (a)

18,946

(18,946
)
39,277


324,583

363,860

344,914

Franklin Growth and Income VIP Fund
42,738

23,169

19,569

68,816

91,020

188,599

348,435

368,004

Franklin Income VIP Fund
180,748

43,626

137,122

55,211

51,991

204,103

311,305

448,427

JP Morgan IT Mid Cap Value
11,176

9,253

1,923

42,608

46,400

51,354

140,362

142,285

Morgan Stanley VIF Emerging Markets Debt Portfolio
5,973

1,514

4,459

(3,218
)

12,686

9,468

13,927

Morgan Stanley VIF U.S. Real Estate Portfolio
13,573

10,439

3,134

32,268

26,984

52,569

111,821

114,955

Non-Affiliated Class 2:
















American Funds I.S. Managed Risk Asset Allocation Fund
46,647

30,200

16,447

5,788

85,603

187,362

278,753

295,200

Columbia VP – Small Cap Value Fund
4,688

24,983

(20,295
)
(57,504
)
153,127

212,051

307,674

287,379

Franklin Growth and Income VIP Fund
108,172

68,285

39,887

128,849

257,169

607,438

993,456

1,033,343

Franklin Income VIP Fund
774,872

216,059

558,813

(17,270
)
234,197

1,101,237

1,318,164

1,876,977

Franklin Large Cap Growth VIP Fund

68,632

(68,632
)
54,764

619,392

735,649

1,409,805

1,341,173

Franklin Mutual Shares VIP Fund
176,931

142,280

34,651

32,761

946,033

784,056

1,762,850

1,797,501

Franklin Small Cap Value VIP Fund
10,932

15,156

(4,224
)
(61,285
)
174,179

112,871

225,765

221,541

Invesco V.I. American Franchise Fund

3,895

(3,895
)
9,978

39,765

35,680

85,423

81,528

Invesco V.I. American Value Fund
30,039

96,475

(66,436
)
(135,424
)
533,804

1,039,346

1,437,726

1,371,290

Invesco V.I. Comstock Fund
59,407

49,459

9,948

(18,301
)
453,618

260,690

696,007

705,955

Invesco V.I. International Growth Fund
25,780

27,767

(1,987
)
11,804

129,584

297,474

438,862

436,875

Invesco V.I. Mid Cap Growth Fund

3,741

(3,741
)
(1,793
)
41,377

22,100

61,684

57,943

Templeton Foreign VIP Fund
68,692

59,136

9,556

(96,388
)
41,000

479,921

424,533

434,089

Templeton Global Bond VIP Fund
32,247

7,408

24,839

(12,541
)

(6,895
)
(19,436
)
5,403

Templeton Growth VIP Fund
34,513

18,127

16,386

(6,286
)
237,089

(92,789
)
138,014

154,400

Morgan Stanley VIF Emerging Markets Debt Portfolio
50,423

13,665

36,758

(9,699
)

80,016

70,317

107,075

Morgan Stanley VIF Emerging Markets Equity Portfolio
21,977

31,689

(9,712
)
17,633

149,704

201,278

368,615

358,903

Morgan Stanley VIF U.S. Real Estate Portfolio
39,680

35,442

4,238

72,247

92,208

207,516

371,971

376,209

Non-Affiliated Class 3:
















BlackRock Capital Appreciation V.I. Fund

40,875

(40,875
)
(58,191
)
530,672

286,750

759,231

718,356

BlackRock Global Allocation V.I. Fund
7,549

9,226

(1,677
)
(4,245
)
24,011

72,658

92,424

90,747

BlackRock High Yield V.I. Fund
8,617

2,442

6,175

(24
)

12,522

12,498

18,673

BlackRock Total Return V.I. Fund
6,060

3,640

2,420

(43
)
1,036

11,954

12,947

15,367

TOPS® Managed Risk Moderate Growth ETF Portfolio
23,822

17,339

6,483

4,673

48,646

88,995

142,314

148,797

Non-Affiliated Class 4:
 
 
 
 
 
 
 
 
American Funds I.S. Bond Fund
15,506

8,957

6,549

(1,114
)

33,974

32,860

39,409

American Funds I.S. Capital Income Builder Fund
61,045

30,091

30,954

5,969


288,047

294,016

324,970

 
 
 
 
 
 
 
 
 

(a) Name Change. See Note 1.
 
9
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 




Separate Account I
of
National Integrity Life Insurance Company
Statements of Operations (continued)
For the Year Ended December 31, 2019
 
Investment
 
 
 
 
 
 
 
 
 Income
Expenses
 
Realized and unrealized gain (loss) on investments
 
Subaccount
 Reinvested
dividends
Mortality and
expense risk and
administrative
charges
Net investment
income (loss)
Realized gain (loss)
on sales of
investments
Realized gain
distributions
Change in net unrealized
appreciation
(depreciation)
during the period
Net realized and
unrealized gain (loss)
on investments
Net increase
(decrease) in net
assets resulting from
operations
Non-Affiliated Class 4 (continued):
 
 
 
 
 
 
 
 
American Funds I.S. Global Growth Fund
$
19,095

$
25,737

$
(6,642
)
$
19,021

$
102,249

$
422,807

$
544,077

$
537,435

American Funds I.S. Growth Fund
12,641

30,234

(17,593
)
9,145

214,748

305,865

529,758

512,165

American Funds I.S. Growth-Income Fund
41,795

41,231

564

14,189

281,585

289,581

585,355

585,919

American Funds I.S. New World Fund
6,500

11,126

(4,626
)
12,173

29,674

147,771

189,618

184,992

Non-Affiliated Class A:
















DWS Small Cap Index VIP Fund
4,606

5,757

(1,151
)
(3,801
)
37,912

54,311

88,422

87,271

Non-Affiliated Class B:
















DWS Small Cap Index VIP Fund
11,129

19,774

(8,645
)
8,227

123,259

180,863

312,349

303,704

Advisor Class:
















PIMCO VIT All Asset Portfolio
42,113

21,737

20,376

(9,244
)

137,252

128,008

148,384

PIMCO VIT International Bond Portfolio (US Dollar Hedged)
479

399

80

8

126

856

990

1,070

PIMCO VIT CommodityRealReturn® Strategy Portfolio
56,813

20,041

36,772

(237,080
)

317,729

80,649

117,421

PIMCO VIT Long-Term U.S. Government Portfolio
3,891

2,584

1,307

2,567


18,774

21,341

22,648

PIMCO VIT Low Duration Portfolio
52,781

29,374

23,407

(3,601
)

26,239

22,638

46,045

PIMCO VIT Real Return Portfolio
19,331

18,494

837

(58,400
)

139,424

81,024

81,861

PIMCO VIT Total Return Portfolio
575,681

295,048

280,633

(128,415
)

1,131,174

1,002,759

1,283,392

Investor Class:
















Guggenheim VT Global Managed Futures Strategy Fund
2,246

3,586

(1,340
)
(14,765
)

32,488

17,723

16,383

Guggenheim VT Multi-Hedge Strategies Fund
8,505

5,485

3,020

4,720


5,411

10,131

13,151

Guggenheim VT Long Short Equity Fund
442

1,116

(674
)
(1,364
)

4,876

3,512

2,838

ETF Shares:
















iShares® Core S&P 500 ETF
438,050

500,948

(62,898
)
2,752,485


2,111,580

4,864,065

4,801,167

iShares® Core S&P Mid-Cap ETF
96,212

144,321

(48,109
)
562,468


644,681

1,207,149

1,159,040

iShares® Core S&P Small-Cap ETF
44,851

76,219

(31,368
)
271,765


288,672

560,437

529,069

iShares® Core U.S. Aggregate Bond ETF
17,281

17,098

183

19,904


15,078

34,982

35,165

iShares® iBoxx $ High Yield Corporate Bond ETF
5,767

2,850

2,917

4,902


4,717

9,619

12,536

iShares® Intermediate-Term Corporate Bond ETF
24,569

19,014

5,555

6,255


62,519

68,774

74,329

iShares® International Treasury Bond ETF
5,580

63,793

(58,213
)
(11,455
)

104,171

92,716

34,503

iShares® S&P 500 Growth ETF
40,567

59,282

(18,715
)
255,784


327,518

583,302

564,587

iShares® S&P 500 Value ETF
11,334

12,216

(882
)
26,817


95,831

122,648

121,766

iShares® TIPS Bond ETF
2,211

3,166

(955
)
395


6,868

7,263

6,308

Vanguard® Developed Markets Index Fund, ETF Shares
85,324

69,723

15,601

106,747


358,799

465,546

481,147

Vanguard® Dividend Appreciation Index Fund, ETF Shares
19,938

28,786

(8,848
)
102,401


155,265

257,666

248,818

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
8,472

6,702

1,770

7,959


29,962

37,921

39,691

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
2,109

1,144

965

1,352


4,558

5,910

6,875

Vanguard® Large-Cap Index Fund, ETF Shares
13,486

17,950

(4,464
)
29,364


139,806

169,170

164,706

Vanguard® Mega Cap Index Fund, ETF Shares
2,682

3,317

(635
)
14,118


19,627

33,745

33,110

Vanguard® Real Estate Index Fund, ETF Shares
9,433

7,234

2,199

15,315


45,377

60,692

62,891

Vanguard® Short-Term Bond Index Fund, ETF Shares
376

373

3

(26
)

485

459

462

Vanguard® Total Bond Market Index Fund, ETF Shares
523,310

487,758

35,552

592,851


528,124

1,120,975

1,156,527


(a) Name Change. See Note 1.
 
10
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets
For the Year Ended December 31, 2019
 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment income (loss)
 Realized gain (loss)
 Change in net unrealized appreciation (depreciation) during the period
 Net increase (decrease) in net assets resulting from operations
 
 Contributions from contract holders
 Contract terminations and benefits
 Net transfers among investment options
 Contract maintenance charges
 Net increase (decrease) in net assets from contract related transactions
 
 Increase (decrease) in net assets
 Net assets, beginning of period
 Net assets, end of period
 
 Units purchased
 Units redeemed
 Increase (decrease) in units
Affiliated:


















Touchstone VST Active Bond Fund (c)
$
67,271

$
(8,760
)
$
83,981

$
142,492


$
1,625

$
(404,189
)
$
(2,193,194
)
$
(7,101
)
$
(2,602,859
)

$
(2,460,367
)
$
2,460,367

$


7,554

193,716

(186,162
)
Touchstone VST Aggressive ETF Fund
13,432

481,724

538,594

1,033,750


138,189

(648,419
)
(148,398
)
(8,982
)
(667,610
)

366,140

5,262,279

5,628,419


4,839

38,377

(33,538
)
Touchstone VST Bond Fund (b)
12,201

5,407

26,762

44,370

 
40,735

(162,268
)
2,212,784

(6,564
)
2,084,687

 
2,129,057


2,129,057

 
234,133

24,913

209,220

Touchstone VST Common Stock Fund (b)
(21,821
)
203,978

1,166,216

1,348,373

 
20,309

(1,041,391
)
19,474,212

(12,453
)
18,440,677

 
19,789,050


19,789,050

 
1,971,207

137,493

1,833,714

Touchstone VST Conservative ETF Fund
59,849

(17,103
)
737,935

780,681


155,043

(1,283,976
)
(60,291
)
(10,252
)
(1,199,476
)

(418,795
)
6,038,228

5,619,433


5,109

79,505

(74,396
)
Touchstone VST Focused Fund (c)
(12,490
)
939,327

1,493,513

2,420,350


57,744

(898,095
)
(16,125,422
)
(9,400
)
(16,975,173
)

(14,554,823
)
14,554,823



6,600

572,289

(565,689
)
Touchstone VST Large Cap Core Equity Fund (c)
16,513

974,899

(501,489
)
489,923


31,925

(166,160
)
(3,537,357
)
(4,446
)
(3,676,038
)

(3,186,115
)
3,186,115



9,272

175,326

(166,054
)
Touchstone VST Moderate ETF Fund
42,498

140,526

963,493

1,146,517


51,437

(1,664,471
)
(3,124
)
(12,109
)
(1,628,267
)

(481,750
)
7,336,499

6,854,749


11,813

110,967

(99,154
)
Non-Affiliated Initial Class:

































Fidelity VIP Balanced Portfolio
7,047

110,021

269,782

386,850



(79,948
)
(2
)
(441
)
(80,391
)

306,459

1,716,085

2,022,544


6

3,030

(3,024
)
Fidelity VIP Overseas Portfolio
3,650

62,868

202,304

268,822



(122,176
)
(4,364
)
(364
)
(126,904
)

141,918

1,080,829

1,222,747


10

6,591

(6,581
)
Fidelity VIP Equity-Income Portfolio
46,606

562,441

1,070,784

1,679,831


146,328

(676,232
)
(119,742
)
(1,331
)
(650,977
)

1,028,854

6,781,160

7,810,014


1,418

9,780

(8,362
)
Fidelity VIP Growth Portfolio
(53,852
)
635,105

779,023

1,360,276



(399,154
)
(112,708
)
(1,162
)
(513,024
)

847,252

4,380,038

5,227,290


384

3,554

(3,170
)
Fidelity VIP High Income Portfolio
65,591

349

129,837

195,777


3,514

(98,662
)
248,388

(322
)
152,918


348,695

1,394,105

1,742,800


25,766

20,613

5,153

Fidelity VIP Asset Manager Portfolio
10,792

111,437

291,287

413,516


3,890

(256,276
)
(57,886
)
(838
)
(311,110
)

102,406

2,674,359

2,776,765


72

5,724

(5,652
)
Fidelity VIP Contrafund® Portfolio
(118,790
)
2,238,968

1,228,908

3,349,086


169,068

(1,645,492
)
(28,538
)
(2,601
)
(1,507,563
)

1,841,523

11,709,315

13,550,838


1,367

24,756

(23,389
)
Fidelity VIP Index 500 Portfolio
25,056

357,301

762,756

1,145,113



(469,823
)
(20
)
(907
)
(470,750
)

674,363

4,015,285

4,689,648


2

13,392

(13,390
)
Fidelity VIP Investment Grade Bond Portfolio
18,506

2,838

94,004

115,348



(105,546
)
(57,180
)
(605
)
(163,331
)

(47,983
)
1,474,164

1,426,181


704

10,444

(9,740
)
Fidelity VIP Government Money Market
34,918



34,918


16,004

(1,385,480
)
(5,828,238
)
(3,831
)
(7,201,545
)

(7,166,627
)
10,536,000

3,369,373


1,375,796

2,115,550

(739,754
)
Non-Affiliated Service Class:

































Fidelity VIP Growth Portfolio
(4,114
)
65,919

31,912

93,717



(84,646
)
(1
)
(111
)
(84,758
)

8,959

314,242

323,201



3,503

(3,503
)
Fidelity VIP Mid Cap Portfolio
(16,452
)
367,353

207,075

557,976



(322,964
)
454

(382
)
(322,892
)

235,084

2,656,970

2,892,054


230

5,095

(4,865
)
Non-Affiliated Service Class 2:

































Fidelity VIP Asset Manager Portfolio
2,522

24,216

119,471

146,209


127,397

(152,915
)
133,536

(3,223
)
104,795


251,004

852,116

1,103,120


13,228

5,745

7,483

Fidelity VIP Balanced Portfolio
18,740

539,231

1,279,052

1,837,023


921,377

(1,442,976
)
1,295,324

(8,054
)
765,671


2,602,694

7,956,995

10,559,689


143,040

88,083

54,957

Fidelity VIP Bond Index Portfolio (b)
1,050

245

(1,749
)
(454
)
 
51,272


34,272

(162
)
85,382

 
84,928


84,928

 
8,385

16

8,369

Fidelity VIP Contrafund® Portfolio
(217,837
)
2,540,839

2,070,548

4,393,550


314,877

(2,481,950
)
(143,896
)
(53,059
)
(2,364,028
)

2,029,522

15,616,017

17,645,539


22,981

121,909

(98,928
)
Fidelity VIP Disciplined Small Cap Portfolio
(8,459
)
91,301

186,289

269,131


117,781

(122,180
)
57,009

(4,783
)
47,827


316,958

1,229,446

1,546,404


13,580

11,189

2,391

Fidelity VIP Equity-Income Portfolio
13,672

209,439

468,016

691,127


309,494

(569,561
)
183,527

(4,734
)
(81,274
)

609,853

2,746,396

3,356,249


35,930

34,519

1,411

Fidelity VIP Extended Market Index Portfolio (b)
127

354

2,622

3,103

 
33,472




33,472

 
36,575


36,575

 
3,467


3,467

Fidelity VIP Freedom 2010 Portfolio
1,378

27,617

27,011

56,006



(106,051
)
(94
)
(936
)
(107,081
)

(51,075
)
447,762

396,687


2

7,521

(7,519
)
Fidelity VIP Freedom 2015 Portfolio
704

32,386

29,412

62,502


2,000

(47,771
)
(9,531
)
(218
)
(55,520
)

6,982

406,517

413,499


139

3,911

(3,772
)
Fidelity VIP Freedom 2020 Portfolio
1,574

42,112

60,875

104,561


75

(37,712
)
55

(4,464
)
(42,046
)

62,515

590,030

652,545


15

2,864

(2,849
)
Fidelity VIP Freedom 2025 Portfolio
5,613

56,378

255,525

317,516


129,512


17,996

(21,415
)
126,093


443,609

1,524,969

1,968,578


9,685

1,400

8,285

Fidelity VIP Freedom 2030 Portfolio
(878
)
72,657

20,929

92,708



(273,214
)
77

(101
)
(273,238
)

(180,530
)
543,648

363,118


1,123

19,616

(18,493
)
Fidelity VIP Growth Portfolio
(46,836
)
301,944

692,311

947,419


217,604

(264,344
)
99,734

(8,261
)
44,733


992,152

2,907,876

3,900,028


20,612

17,240

3,372

Fidelity VIP High Income Portfolio
266,766

96,722

(33,801
)
329,687


166,523

(316,133
)
5,844,716

(3,058
)
5,692,048


6,021,735

785,554

6,807,289


903,597

616,314

287,283

Fidelity VIP Index 500 Portfolio
75,813

1,626,483

5,073,245

6,775,541


1,347,905

(3,038,903
)
1,029,979

(86,549
)
(747,568
)

6,027,973

23,138,184

29,166,157


163,249

185,079

(21,830
)
Fidelity VIP International Index Portfolio (b)
29

3

28

60

 


1,452


1,452

 
1,512


1,512

 
142


142

Fidelity VIP Investment Grade Bond Portfolio
161,053

22,450

904,085

1,087,588


988,556

(1,145,472
)
223,911

(126,384
)
(59,389
)

1,028,199

13,976,496

15,004,695


112,432

118,505

(6,073
)
Fidelity VIP Mid Cap Portfolio
(55,513
)
658,579

765,703

1,368,769


119,759

(764,202
)
1,895,166

(12,161
)
1,238,562


2,607,331

6,108,382

8,715,713


79,822

40,777

39,045

Fidelity VIP Overseas Portfolio
(8,099
)
396,735

399,899

788,535


20,567

(460,296
)
(1,652,157
)
(6,578
)
(2,098,464
)

(1,309,929
)
3,982,816

2,672,887


8,928

163,681

(154,753
)
Fidelity VIP Target Volatility Portfolio
(701
)
11,980

59,831

71,110


8,145

(9,427
)
(683
)
(5,937
)
(7,902
)

63,208

422,590

485,798


802

1,413

(611
)
Non-Affiliated Class 1:

































Columbia VP – Select Mid Cap Value Fund (a)
(18,946
)
39,277

324,583

344,914


115,642

(82,714
)
49,332

(1,362
)
80,898


425,812

1,113,005

1,538,817


12,353

7,479

4,874

Franklin Growth and Income VIP Fund
19,569

159,836

188,599

368,004



(197,144
)
349

(440
)
(197,235
)

170,769

1,580,044

1,750,813


360

7,320

(6,960
)
Franklin Income VIP Fund
137,122

107,202

204,103

448,427


36,610

(606,687
)
614

(683
)
(570,146
)

(121,719
)
3,174,580

3,052,861


305

20,906

(20,601
)
JP Morgan IT Mid Cap Value
1,923

89,008

51,354

142,285



(123,460
)
(3
)
(271
)
(123,734
)

18,551

611,354

629,905



4,257

(4,257
)
Morgan Stanley VIF Emerging Markets Debt Portfolio
4,459

(3,218
)
12,686

13,927


2,605

(27,335
)
(716
)
(50
)
(25,496
)

(11,569
)
118,733

107,164


4

792

(788
)
Morgan Stanley VIF U.S. Real Estate Portfolio
3,134

59,252

52,569

114,955


4,254

(81,498
)
(4,737
)
(198
)
(82,179
)

32,776

681,269

714,045


444

2,551

(2,107
)
Non-Affiliated Class 2:

































American Funds I.S. Managed Risk Asset Allocation Fund
16,447

91,391

187,362

295,200


110,389

(43,730
)
17,444

(11,826
)
72,277


367,477

1,780,956

2,148,433


10,493

4,498

5,995

Columbia VP – Small Cap Value Fund
(20,295
)
95,623

212,051

287,379


98,245

(101,248
)
(18,660
)
(7,481
)
(29,144
)

258,235

1,492,440

1,750,675


14,895

15,520

(625
)
Franklin Growth and Income VIP Fund
39,887

386,018

607,438

1,033,343


9,512

(675,255
)
29,866

(5,145
)
(641,022
)

392,321

4,590,878

4,983,199


13,480

42,237

(28,757
)


(a) Name Change. See Note 1.
 
11
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets (continued)
For the Year Ended December 31, 2019
 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment income (loss)
 Realized gain (loss)
 Change in net unrealized appreciation (depreciation) during the period
 Net increase (decrease) in net assets resulting from operations
 
 Contributions from contract holders
 Contract terminations and benefits
 Net transfers among investment options
 Contract maintenance charges
 Net increase (decrease) in net assets from contract related transactions
 
 Increase (decrease) in net assets
 Net assets, beginning of period
 Net assets, end of period
 
 Units purchased
 Units redeemed
 Increase (decrease) in units
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Franklin Income VIP Fund
$
558,813

$
216,927

$
1,101,237

$
1,876,977

 
$
480,832

$
(1,706,975
)
$
541,829

$
(4,203
)
$
(688,517
)
 
$
1,188,460

$
13,324,429

$
14,512,889

 
60,696

102,200

(41,504
)
Franklin Large Cap Growth VIP Fund
(68,632
)
674,156

735,649

1,341,173

 
100,510

(552,699
)
(108,685
)
(6,634
)
(567,508
)
 
773,665

4,229,453

5,003,118

 
5,555

26,663

(21,108
)
Franklin Mutual Shares VIP Fund
34,651

978,794

784,056

1,797,501

 
442,353

(1,050,055
)
51,602

(57,624
)
(613,724
)
 
1,183,777

8,735,572

9,919,349

 
45,921

78,970

(33,049
)
Franklin Small Cap Value VIP Fund
(4,224
)
112,894

112,871

221,541

 
129,801

(167,574
)
17,067

(1,261
)
(21,967
)
 
199,574

904,011

1,103,585

 
9,565

10,686

(1,121
)
Invesco V.I. American Franchise Fund
(3,895
)
49,743

35,680

81,528

 
32,770

(14,730
)
19,681

(781
)
36,940

 
118,468

237,619

356,087

 
3,250

1,638

1,612

Invesco V.I. American Value Fund
(66,436
)
398,380

1,039,346

1,371,290


917,798

(583,955
)
(28,450
)
(26,476
)
278,917


1,650,207

5,756,130

7,406,337


59,663

42,401

17,262

Invesco V.I. Comstock Fund
9,948

435,317

260,690

705,955


261,718

(251,607
)
34,853

(23,384
)
21,580


727,535

2,994,120

3,721,655


23,707

21,387

2,320

Invesco V.I. International Growth Fund
(1,987
)
141,388

297,474

436,875


161,487

(97,727
)
51,295

(13,415
)
101,640


538,515

1,607,199

2,145,714


25,934

17,269

8,665

Invesco V.I. Mid Cap Growth Fund
(3,741
)
39,584

22,100

57,943


15,654

(828
)
87,560

(563
)
101,823


159,766

145,581

305,347


10,125

2,669

7,456

Templeton Foreign VIP Fund
9,556

(55,388
)
479,921

434,089


350,622

(331,667
)
126,049

(23,645
)
121,359


555,448

3,780,860

4,336,308


55,027

37,775

17,252

Templeton Global Bond VIP Fund
24,839

(12,541
)
(6,895
)
5,403



(33,521
)
14,432

(175
)
(19,264
)

(13,861
)
599,098

585,237


15,743

17,252

(1,509
)
Templeton Growth VIP Fund
16,386

230,803

(92,789
)
154,400


14,786

(146,160
)
13,146

(2,117
)
(120,345
)

34,055

1,199,723

1,233,778


4,849

11,833

(6,984
)
Morgan Stanley VIF Emerging Markets Debt Portfolio
36,758

(9,699
)
80,016

107,075


101,520

(113,112
)
16,140

(1,832
)
2,716


109,791

843,269

953,060


7,304

6,104

1,200

Morgan Stanley VIF Emerging Markets Equity Portfolio
(9,712
)
167,337

201,278

358,903


133,291

(304,343
)
80,458

(3,955
)
(94,549
)

264,354

2,058,445

2,322,799


18,404

17,426

978

Morgan Stanley VIF U.S. Real Estate Portfolio
4,238

164,455

207,516

376,209


157,894

(260,429
)
43,166

(8,496
)
(67,865
)

308,344

2,218,039

2,526,383


21,263

21,250

13

 Non-Affiliated Class 3:

































BlackRock Capital Appreciation V.I. Fund
(40,875
)
472,481

286,750

718,356


289,196

(352,801
)
150,025

(11,129
)
75,291


793,647

2,370,332

3,163,979


25,003

21,257

3,746

BlackRock Global Allocation V.I. Fund
(1,677
)
19,766

72,658

90,747


10,874

(69,268
)
(10,304
)
(2,313
)
(71,011
)

19,736

592,807

612,543


2,775

8,555

(5,780
)
BlackRock High Yield V.I. Fund
6,175

(24
)
12,522

18,673


3,900

(2,176
)
67,563

(224
)
69,063


87,736

122,563

210,299


6,238

320

5,918

BlackRock Total Return V.I. Fund
2,420

993

11,954

15,367


49,473

(5,514
)
81,878

(1,928
)
123,909


139,276

163,389

302,665


13,153

1,055

12,098

TOPS® Managed Risk Moderate Growth ETF Portfolio
6,483

53,319

88,995

148,797


40,721

(75,838
)
2,281

(8,602
)
(41,438
)

107,359

1,045,313

1,152,672


4,113

7,733

(3,620
)
 Non-Affiliated Class 4:

































American Funds I.S. Bond Fund
6,549

(1,114
)
33,974

39,409


75

(3,836
)
152,777

(5,476
)
143,540


182,949

496,722

679,671


16,818

2,875

13,943

American Funds I.S. Capital Income Builder Fund
30,954

5,969

288,047

324,970


182,209

(33,498
)
1,024,410

(4,084
)
1,169,037


1,494,007

1,537,493

3,031,500


116,482

5,120

111,362

American Funds I.S. Global Growth Fund
(6,642
)
121,270

422,807

537,435


199,256

(120,943
)
91,965

(5,227
)
165,051


702,486

1,552,160

2,254,646


24,629

13,269

11,360

American Funds I.S. Growth Fund
(17,593
)
223,893

305,865

512,165


333,196

(54,051
)
202,254

(2,178
)
479,221


991,386

1,575,886

2,567,272


32,489

5,282

27,207

American Funds I.S. Growth-Income Fund
564

295,774

289,581

585,919


241,486

(202,392
)
(25,995
)
(7,429
)
5,670


591,589

2,421,267

3,012,856


21,192

20,670

522

American Funds I.S. New World Fund
(4,626
)
41,847

147,771

184,992


118,689

(32,267
)
17,544

(4,568
)
99,398


284,390

652,574

936,964


15,006

6,391

8,615

 Non-Affiliated Class A:

































DWS Small Cap Index VIP Fund
(1,151
)
34,111

54,311

87,271



(28,976
)
(11,824
)
(82
)
(40,882
)

46,389

384,997

431,386


13

1,292

(1,279
)
 Non-Affiliated Class B:

































DWS Small Cap Index VIP Fund
(8,645
)
131,486

180,863

303,704


6,202

(47,212
)
120,194

(1,170
)
78,014


381,718

1,295,935

1,677,653


14,573

8,910

5,663

 Advisor Class:

































PIMCO VIT All Asset Portfolio
20,376

(9,244
)
137,252

148,384


18,000

(146,530
)
(38,599
)
(1,278
)
(168,407
)

(20,023
)
1,552,526

1,532,503


5,445

18,085

(12,640
)
PIMCO VIT International Bond Portfolio (US Dollar Hedged)
80

134

856

1,070




21,370

(3
)
21,367


22,437

17,775

40,212


1,957


1,957

PIMCO VIT CommodityRealReturn® Strategy Portfolio
36,772

(237,080
)
317,729

117,421


36,044

(181,031
)
51,923

(7,027
)
(100,091
)

17,330

1,262,814

1,280,144


34,132

60,754

(26,622
)
PIMCO VIT Long-Term U.S. Government Portfolio
1,307

2,567

18,774

22,648


315

(4,910
)
(2,026
)
(512
)
(7,133
)

15,515

184,834

200,349


1,552

2,113

(561
)
PIMCO VIT Low Duration Portfolio
23,407

(3,601
)
26,239

46,045


111,661

(55,771
)
222,164

(6,788
)
271,266


317,311

1,807,480

2,124,791


30,950

6,424

24,526

PIMCO VIT Real Return Portfolio
837

(58,400
)
139,424

81,861


4,831

(464,701
)
3,390

(1,187
)
(457,667
)

(375,806
)
1,281,654

905,848


5,103

42,962

(37,859
)
PIMCO VIT Total Return Portfolio
280,633

(128,415
)
1,131,174

1,283,392


1,107,365

(2,685,549
)
324,082

(136,015
)
(1,390,117
)

(106,725
)
19,600,375

19,493,650


119,844

220,216

(100,372
)
 Investor Class:

































Guggenheim VT Global Managed Futures Strategy Fund
(1,340
)
(14,765
)
32,488

16,383


2,852

(84,499
)
3,210

(1,364
)
(79,801
)

(63,418
)
231,266

167,848


2,264

14,911

(12,647
)
Guggenheim VT Multi-Hedge Strategies Fund
3,020

4,720

5,411

13,151



(58,266
)
5,755

(1,103
)
(53,614
)

(40,463
)
385,226

344,763


880

7,095

(6,215
)
Guggenheim VT Long Short Equity Fund
(674
)
(1,364
)
4,876

2,838



(11,899
)
2

(102
)
(11,999
)

(9,161
)
80,745

71,584


38

1,271

(1,233
)
 ETF Shares:

































iShares® Core S&P 500 ETF
(62,898
)
2,752,485

2,111,580

4,801,167


127,776

(4,438,855
)
(723,137
)

(5,034,216
)

(233,049
)
18,855,058

18,622,009


8,249

96,741

(88,492
)
iShares® Core S&P Mid-Cap ETF
(48,109
)
562,468

644,681

1,159,040


36,654

(1,209,981
)
73,018


(1,100,309
)

58,731

5,340,591

5,399,322


5,330

27,044

(21,714
)
iShares® Core S&P Small-Cap ETF
(31,368
)
271,765

288,672

529,069


19,849

(644,696
)
163,875


(460,972
)

68,097

2,801,739

2,869,836


4,277

12,828

(8,551
)
iShares® Core U.S. Aggregate Bond ETF
183

19,904

15,078

35,165


16,374

(106,054
)
16,359


(73,321
)

(38,156
)
620,094

581,938


2,284

5,157

(2,873
)
iShares® iBoxx $ High Yield Corporate Bond ETF
2,917

4,902

4,717

12,536


325

(65,784
)
2,818


(62,641
)

(50,105
)
124,382

74,277


109

2,106

(1,997
)
iShares® Intermediate-Term Corporate Bond ETF
5,555

6,255

62,519

74,329


12,512

(23,049
)
(993
)

(11,530
)

62,799

653,039

715,838


1,552

1,990

(438
)
iShares® International Treasury Bond ETF
(58,213
)
(11,455
)
104,171

34,503


16,569

(547,886
)
187,057


(344,260
)

(309,757
)
2,635,391

2,325,634


10,236

25,399

(15,163
)
iShares® S&P 500 Growth ETF
(18,715
)
255,784

327,518

564,587


15,835

(327,950
)
(70,510
)

(382,625
)

181,962

2,157,313

2,339,275


1,188

7,300

(6,112
)
iShares® S&P 500 Value ETF
(882
)
26,817

95,831

121,766


6,476

(53,287
)
(2,914
)

(49,725
)

72,041

447,726

519,767


520

1,492

(972
)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 



(a) Name Change. See Note 1.
 
12
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 



Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets (continued)
For the Year Ended December 31, 2019

 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment income (loss)
 Realized gain (loss)
 Change in net unrealized appreciation (depreciation) during the period
 Net increase (decrease) in net assets resulting from operations
 
 Contributions from contract holders
 Contract terminations and benefits
 Net transfers among investment options
 Contract maintenance charges
 Net increase (decrease) in net assets from contract related transactions
 
 Increase (decrease) in net assets
 Net assets, beginning of period
 Net assets, end of period
 
 Units purchased
 Units redeemed
 Increase (decrease) in units
 ETF Shares (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
iShares® TIPS Bond ETF
$
(955
)
$
395

$
6,868

$
6,308

 
$
10,461

$
(2,711
)
$
4,600

$

$
12,350

 
$
18,658

$
108,018

$
126,676

 
731

167

564

Vanguard® Developed Markets Index Fund, ETF Shares
15,601

106,747

358,799

481,147

 
17,503

(575,583
)
29,149


(528,931
)
 
(47,784
)
2,650,860

2,603,076

 
3,357

18,919

(15,562
)
Vanguard® Dividend Appreciation Index Fund, ETF Shares
(8,848
)
102,401

155,265

248,818

 
18,358

(176,638
)
(37,435
)

(195,715
)
 
53,103

995,442

1,048,545

 
532

4,293

(3,761
)
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
1,770

7,959

29,962

39,691

 
947

(80,739
)
1,998


(77,794
)
 
(38,103
)
260,177

222,074

 
610

3,720

(3,110
)
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
965

1,352

4,558

6,875

 

(8,391
)
(5
)

(8,396
)
 
(1,521
)
62,582

61,061

 

279

(279
)
Vanguard® Large-Cap Index Fund, ETF Shares
(4,464
)
29,364

139,806

164,706

 
8,668

(37,858
)
(14,231
)

(43,421
)
 
121,285

606,269

727,554

 
345

1,108

(763
)
Vanguard® Mega Cap Index Fund, ETF Shares
(635
)
14,118

19,627

33,110

 
1,245

(17,071
)
(246
)

(16,072
)
 
17,038

123,156

140,194

 
80

356

(276
)
Vanguard® Real Estate Index Fund, ETF Shares
2,199

15,315

45,377

62,891

 
2,561

(60,500
)
(12,858
)

(70,797
)
 
(7,906
)
251,874

243,968

 
152

1,688

(1,536
)
Vanguard® Short-Term Bond Index Fund, ETF Shares
3

(26
)
485

462

 

(4,520
)
533


(3,987
)
 
(3,525
)
18,100

14,575

 
24

186

(162
)
Vanguard® Total Bond Market Index Fund, ETF Shares
35,552

592,851

528,124

1,156,527

 
123,551

(4,090,322
)
545,757


(3,421,014
)
 
(2,264,487
)
19,848,541

17,584,054

 
45,657

180,598

(134,941
)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 



(a) Name Change. See Note 1.
 
13
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets
For the Year Ended December 31, 2018
 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment
income (loss)
 Realized gain
(loss)
Change in net
unrealized
appreciation
(depreciation) during
the period
Net increase
(decrease) in net
assets resulting from
operations
 
Contributions from
contract holders
Contract
terminations and
benefits
 Net transfers among
investment options
Contract
maintenance
charges
Net increase (decrease)
in net assets from
contract related
transactions
 
Increase
(decrease) in net
assets
Net assets,
beginning of period
 Net assets, end of
period
 
 Units purchased
 Units redeemed
Increase
(decrease) in
units
Affiliated:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund (c)
$
12,189

$
(13,692
)
$
(97,439
)
$
(98,942
)

$
12,128

$
(798,708
)
$
873

$
(18,210
)
$
(803,917
)

$
(902,859
)
$
3,363,226

$
2,460,367


16,596

72,645

(56,049
)
Touchstone VST Aggressive ETF Fund
13,535

501,419

(1,039,834
)
(524,880
)

55,373

(653,271
)
(212,688
)
(12,543
)
(823,129
)

(1,348,009
)
6,610,288

5,262,279


14,223

56,094

(41,871
)
Touchstone VST Conservative ETF Fund
15,633

35,404

(406,319
)
(355,282
)

70,632

(934,943
)
113,651

(13,555
)
(764,215
)

(1,119,497
)
7,157,725

6,038,228


27,264

76,276

(49,012
)
Touchstone VST Focused Fund (c)
(165,294
)
314,532

(1,574,627
)
(1,425,389
)

110,147

(2,115,456
)
(128,574
)
(21,881
)
(2,155,764
)

(3,581,153
)
18,135,976

14,554,823


19,443

93,369

(73,926
)
Touchstone VST Large Cap Core Equity Fund (c)
(31,001
)
349,253

(580,768
)
(262,516
)

60,277

(469,054
)
(37,148
)
(10,745
)
(456,670
)

(719,186
)
3,905,301

3,186,115


8,411

29,320

(20,909
)
Touchstone VST Moderate ETF Fund
36,783

203,957

(817,838
)
(577,098
)

192,171

(1,054,471
)
(594
)
(20,361
)
(883,255
)

(1,460,353
)
8,796,852

7,336,499


37,195

84,288

(47,093
)
Non-Affiliated Initial Class:

































Fidelity VIP Balanced Portfolio
784

163,302

(257,769
)
(93,683
)


(231,457
)
(26,037
)
(556
)
(258,050
)

(351,733
)
2,067,818

1,716,085


1

11,031

(11,030
)
Fidelity VIP Overseas Portfolio
1,565

24,917

(235,308
)
(208,826
)


(100,497
)
(47,354
)
(437
)
(148,288
)

(357,114
)
1,437,943

1,080,829



7,176

(7,176
)
Fidelity VIP Equity-Income Portfolio
60,886

1,050,896

(1,751,381
)
(639,599
)

182,352

(1,215,610
)
(1,603,944
)
(1,588
)
(2,638,790
)

(3,278,389
)
10,059,549

6,781,160


177

36,825

(36,648
)
Fidelity VIP Growth Portfolio
(58,182
)
1,068,471

(1,035,430
)
(25,141
)


(528,112
)
(44,972
)
(1,243
)
(574,327
)

(599,468
)
4,979,506

4,380,038


7

3,822

(3,815
)
Fidelity VIP High Income Portfolio
74,584

2,485

(160,787
)
(83,718
)

37,162

(228,739
)
65,674

(371
)
(126,274
)

(209,992
)
1,604,097

1,394,105


30,951

35,942

(4,991
)
Fidelity VIP Asset Manager Portfolio
8,336

85,944

(282,647
)
(188,367
)

109,020

(445,012
)
(77,441
)
(954
)
(414,387
)

(602,754
)
3,277,113

2,674,359


20

7,428

(7,408
)
Fidelity VIP Contrafund® Portfolio
(92,379
)
2,119,945

(2,972,424
)
(944,858
)

408,964

(1,537,905
)
(183,815
)
(2,885
)
(1,315,641
)

(2,260,499
)
13,969,814

11,709,315


4,286

26,890

(22,604
)
Fidelity VIP Index 500 Portfolio
20,758

364,610

(618,983
)
(233,615
)


(523,456
)
(29,906
)
(1,118
)
(554,480
)

(788,095
)
4,803,380

4,015,285


33

14,681

(14,648
)
Fidelity VIP Investment Grade Bond Portfolio
14,900

19,336

(73,715
)
(39,479
)


(187,907
)
(309,915
)
(736
)
(498,558
)

(538,037
)
2,012,201

1,474,164


2

18,158

(18,156
)
Fidelity VIP Government Money Market
10,604



10,604


378,813

(924,615
)
20,796

(4,688
)
(529,694
)

(519,090
)
11,055,090

10,536,000


2,292,316

2,347,892

(55,576
)
Non-Affiliated Service Class:

































Fidelity VIP Growth Portfolio
(4,600
)
76,115

(73,198
)
(1,683
)


(42,622
)

(137
)
(42,759
)

(44,442
)
358,684

314,242



1,929

(1,929
)
Fidelity VIP Mid Cap Portfolio
(28,605
)
418,567

(882,568
)
(492,606
)


(437,242
)
(64
)
(498
)
(437,804
)

(930,410
)
3,587,380

2,656,970


2

6,348

(6,346
)
Non-Affiliated Service Class 2:

































Fidelity VIP Asset Manager Portfolio
302

23,402

(85,141
)
(61,437
)

11,278

(128,307
)
29,855

(4,174
)
(91,348
)

(152,785
)
1,004,901

852,116


3,421

8,571

(5,150
)
Fidelity VIP Balanced Portfolio
(7,470
)
538,174

(1,035,327
)
(504,623
)

66,223

(1,019,073
)
1,451,577

(10,062
)
488,665


(15,958
)
7,972,953

7,956,995


107,258

73,662

33,596

Fidelity VIP Contrafund® Portfolio
(188,588
)
2,535,766

(3,628,628
)
(1,281,450
)

154,252

(2,055,860
)
(43,424
)
(66,322
)
(2,011,354
)

(3,292,804
)
18,908,821

15,616,017


28,758

111,187

(82,429
)
Fidelity VIP Disciplined Small Cap Portfolio
(12,247
)
226,596

(383,361
)
(169,012
)

97,485

(162,048
)
(543,131
)
(4,449
)
(612,143
)

(781,155
)
2,010,601

1,229,446


19,990

53,483

(33,493
)
Fidelity VIP Equity-Income Portfolio
14,495

724,264

(943,902
)
(205,143
)

53,220

(654,251
)
(1,889,231
)
(7,202
)
(2,497,464
)

(2,702,607
)
5,449,003

2,746,396


10,850

123,664

(112,814
)
Fidelity VIP Freedom 2010 Portfolio
(645
)
24,478

(51,323
)
(27,490
)


(51,305
)
73

(1,134
)
(52,366
)

(79,856
)
527,618

447,762


12

3,738

(3,726
)
Fidelity VIP Freedom 2015 Portfolio
(968
)
21,248

(50,182
)
(29,902
)

2,000

(21,066
)
2

(246
)
(19,310
)

(49,212
)
455,729

406,517


1,599

3,061

(1,462
)
Fidelity VIP Freedom 2020 Portfolio
(960
)
27,282

(71,691
)
(45,369
)

30

(34,898
)
56,067

(5,378
)
15,821


(29,548
)
619,578

590,030


4,042

2,774

1,268

Fidelity VIP Freedom 2025 Portfolio
(1,105
)
18,121

(147,412
)
(130,396
)

778,237


209,548

(18,696
)
969,089


838,693

686,276

1,524,969


66,727

1,128

65,599

Fidelity VIP Freedom 2030 Portfolio
(2,728
)
20,943

(75,493
)
(57,278
)


(33,327
)

(101
)
(33,428
)

(90,706
)
634,354

543,648



2,280

(2,280
)
Fidelity VIP Growth Portfolio
(44,087
)
991,496

(886,819
)
60,590


253,667

(530,876
)
(1,029,053
)
(8,294
)
(1,314,556
)

(1,253,966
)
4,161,842

2,907,876


21,889

72,523

(50,634
)
Fidelity VIP High Income Portfolio
317,611

(646,772
)
(56,837
)
(385,998
)

19,207

(565,764
)
457,244

(3,249
)
(92,562
)

(478,560
)
1,264,114

785,554


1,000,399

1,021,150

(20,751
)
Fidelity VIP Index 500 Portfolio
24,109

1,522,805

(2,947,879
)
(1,400,965
)

1,663,342

(2,031,629
)
(750,747
)
(101,287
)
(1,220,321
)

(2,621,286
)
25,759,470

23,138,184


157,878

209,735

(51,857
)
Fidelity VIP Investment Grade Bond Portfolio
115,642

(15,630
)
(421,923
)
(321,911
)

1,358,096

(1,268,078
)
195,154

(143,309
)
141,863


(180,048
)
14,156,544

13,976,496


144,703

133,947

10,756

Fidelity VIP Mid Cap Portfolio
(76,877
)
1,011,094

(1,984,035
)
(1,049,818
)

127,590

(955,027
)
(977,942
)
(14,654
)
(1,820,033
)

(2,869,851
)
8,978,233

6,108,382


26,985

79,163

(52,178
)
Fidelity VIP Overseas Portfolio
(5,774
)
145,033

(916,610
)
(777,351
)

36,952

(405,336
)
6,719

(8,850
)
(370,515
)

(1,147,866
)
5,130,682

3,982,816


21,651

45,805

(24,154
)
Fidelity VIP Target Volatility Portfolio
153

14,361

(48,438
)
(33,924
)

28,290

(1,896
)
(3,233
)
(6,838
)
16,323


(17,601
)
440,191

422,590


2,385

1,073

1,312

Non-Affiliated Class 1:

































Columbia VP – Select Mid Cap Value Fund (a)
(17,873
)
34,919

(206,994
)
(189,948
)

39,863

(53,989
)
(11,293
)
(1,771
)
(27,190
)

(217,138
)
1,330,143

1,113,005


7,300

9,056

(1,756
)
Franklin Growth and Income VIP Fund
22,923

86,322

(204,823
)
(95,578
)


(156,313
)
(14,425
)
(474
)
(171,212
)

(266,790
)
1,846,834

1,580,044


1

6,561

(6,560
)
Franklin Income VIP Fund
130,422

53,103

(367,239
)
(183,714
)

66,591

(440,927
)
(23,802
)
(870
)
(399,008
)

(582,722
)
3,757,302

3,174,580


104

15,316

(15,212
)
JP Morgan IT Mid Cap Value
(3,157
)
89,086

(179,087
)
(93,158
)


(127,724
)
(23,799
)
(391
)
(151,914
)

(245,072
)
856,426

611,354


1

5,015

(5,014
)
Morgan Stanley VIF Emerging Markets Debt Portfolio
5,249

(824
)
(15,456
)
(11,031
)

10,652

(16,395
)
(4,685
)
(56
)
(10,484
)

(21,515
)
140,248

118,733


28

388

(360
)
Morgan Stanley VIF U.S. Real Estate Portfolio
9,348

33,123

(117,845
)
(75,374
)

300

(121,199
)
(38,908
)
(247
)
(160,054
)

(235,428
)
916,697

681,269


243

4,188

(3,945
)
Non-Affiliated Class 2:

































American Funds I.S. Managed Risk Asset Allocation Fund
(3,731
)
93,243

(209,898
)
(120,386
)

30,790

(95,396
)
(7,961
)
(13,671
)
(86,238
)

(206,624
)
1,987,580

1,780,956


4,345

11,477

(7,132
)
Columbia VP – Small Cap Value Fund
(21,782
)
271,343

(593,532
)
(343,971
)

118,847

(142,878
)
184,930

(8,970
)
151,929


(192,042
)
1,684,482

1,492,440


18,572

12,260

6,312

Franklin Growth and Income VIP Fund
56,944

416,197

(756,767
)
(283,626
)

65,785

(1,084,575
)
52,344

(6,729
)
(973,175
)

(1,256,801
)
5,847,679

4,590,878


9,071

54,576

(45,505
)
Franklin Income VIP Fund
477,294

58,778

(1,340,075
)
(804,003
)

277,239

(1,349,302
)
538,833

(5,397
)
(538,627
)

(1,342,630
)
14,667,059

13,324,429


69,512

87,238

(17,726
)
Franklin Large Cap Growth VIP Fund
(66,588
)
482,698

(704,536
)
(288,426
)

26,673

(651,101
)
2,841,765

(8,514
)
2,208,823


1,920,397

2,309,056

4,229,453


115,022

33,885

81,137

Franklin Mutual Shares VIP Fund
84,596

675,069

(1,759,600
)
(999,935
)

609,842

(1,291,042
)
6,132

(64,468
)
(739,536
)

(1,739,471
)
10,475,043

8,735,572


53,343

87,698

(34,355
)
Franklin Small Cap Value VIP Fund
(6,709
)
134,685

(276,675
)
(148,699
)

21,564

(202,857
)
28,330

(3,303
)
(156,266
)

(304,965
)
1,208,976

904,011


4,520

13,226

(8,706
)
Invesco V.I. American Franchise Fund
(3,919
)
30,761

(37,942
)
(11,100
)

100

(33,753
)
31,935

(779
)
(2,497
)

(13,597
)
251,216

237,619


1,279

1,664

(385
)


(a) Name Change. See Note 1.
 
14
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets (continued)
For the Year Ended December 31, 2018

 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment
income (loss)
 Realized gain
(loss)
Change in net
unrealized
appreciation
(depreciation) during
the period
Net increase
(decrease) in net
assets resulting from
operations
 
Contributions from
contract holders
Contract
terminations and
benefits
 Net transfers among
investment options
Contract
maintenance
charges
Net increase (decrease)
in net assets from
contract related
transactions
 
Increase
(decrease) in net
assets
Net assets,
beginning of period
 Net assets, end of
period
 
 Units purchased
 Units redeemed
Increase
(decrease) in
units
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Invesco V.I. American Value Fund
$
(74,874
)
$
925,089

$
(2,033,000
)
$
(1,182,785
)

$
852,565

$
(518,018
)
$
4,459,431

$
(24,471
)
$
4,769,507


$
3,586,722

$
2,169,408

$
5,756,130


286,822

38,120

248,702

Invesco V.I. Comstock Fund
(656
)
411,264

(872,048
)
(461,440
)

362,316

(310,295
)
(70,493
)
(25,469
)
(43,941
)

(505,381
)
3,499,501

2,994,120


24,983

25,911

(928
)
Invesco V.I. International Growth Fund
6,246

33,415

(339,677
)
(300,016
)

196,545

(172,777
)
101,728

(13,365
)
112,131


(187,885
)
1,795,084

1,607,199


33,787

23,655

10,132

Invesco V.I. Mid Cap Growth Fund
(1,739
)
13,570

(26,005
)
(14,174
)

23,133

(639
)
76,582

(646
)
98,430


84,256

61,325

145,581


7,997

293

7,704

Templeton Foreign VIP Fund
50,359

(8,245
)
(772,257
)
(730,143
)

494,938

(632,420
)
199,332

(24,330
)
37,520


(692,623
)
4,473,483

3,780,860


58,716

41,610

17,106

Templeton Global Bond VIP Fund
(8,624
)
(10,685
)
22,862

3,553


56,520

(86,232
)
(19,337
)
(174
)
(49,223
)

(45,670
)
644,768

599,098


6,907

12,000

(5,093
)
Templeton Growth VIP Fund
8,753

276,056

(525,856
)
(241,047
)

6,644

(356,264
)
(70,190
)
(2,620
)
(422,430
)

(663,477
)
1,863,200

1,199,723


2,157

24,410

(22,253
)
Morgan Stanley VIF Emerging Markets Debt Portfolio
33,215

(20,826
)
(82,415
)
(70,026
)

53,453

(117,824
)
80,582

(2,408
)
13,803


(56,223
)
899,492

843,269


15,604

13,011

2,593

Morgan Stanley VIF Emerging Markets Equity Portfolio
(24,478
)
82,499

(580,398
)
(522,377
)

16,957

(272,167
)
814,944

(5,217
)
554,517


32,140

2,026,305

2,058,445


45,807

23,187

22,620

Morgan Stanley VIF U.S. Real Estate Portfolio
24,670

94,295

(348,329
)
(229,364
)

191,871

(294,486
)
(75,586
)
(9,706
)
(187,907
)

(417,271
)
2,635,310

2,218,039


27,199

37,344

(10,145
)
Non-Affiliated Class 3:

































BlackRock Capital Appreciation V.I. Fund
(35,701
)
804,633

(772,478
)
(3,546
)

285,691

(260,446
)
143,682

(10,215
)
158,712


155,166

2,215,166

2,370,332


30,079

22,514

7,565

BlackRock Global Allocation V.I. Fund
(5,684
)
12,751

(70,784
)
(63,717
)

25,395

(145,855
)
(36,715
)
(3,144
)
(160,319
)

(224,036
)
816,843

592,807


5,322

18,890

(13,568
)
BlackRock High Yield V.I. Fund
3,125

(86
)
(8,073
)
(5,034
)

25,810

(1,319
)
50,704

(184
)
75,011


69,977

52,586

122,563


6,896

171

6,725

BlackRock Total Return V.I. Fund
1,678

(3,343
)
(2,856
)
(4,521
)

16,902

(2,048
)
(42,663
)
(2,123
)
(29,932
)

(34,453
)
197,842

163,389


3,262

6,327

(3,065
)
TOPS® Managed Risk Moderate Growth ETF Portfolio
2,261

58,152

(160,018
)
(99,605
)

237,142

(21,673
)
4,531

(9,944
)
210,056


110,451

934,862

1,045,313


21,268

2,779

18,489

Non-Affiliated Class 4:

































American Funds I.S. Bond Fund
3,778

(4,621
)
(11,968
)
(12,811
)

6,398


(836
)
(6,390
)
(828
)

(13,639
)
510,361

496,722


7,111

7,241

(130
)
American Funds I.S. Capital Income Builder Fund
22,855

7,554

(173,784
)
(143,375
)

218,245

(35,910
)
(48,515
)
(4,280
)
129,540


(13,835
)
1,551,328

1,537,493


44,183

31,840

12,343

American Funds I.S. Global Growth Fund
(12,999
)
128,608

(303,137
)
(187,528
)

109,298

(112,713
)
288,359

(5,622
)
279,322


91,794

1,460,366

1,552,160


30,398

11,069

19,329

American Funds I.S. Growth Fund
(17,429
)
163,786

(194,410
)
(48,053
)

163,486

(57,882
)
248,279

(2,280
)
351,603


303,550

1,272,336

1,575,886


26,830

5,721

21,109

American Funds I.S. Growth-Income Fund
(2,393
)
144,276

(257,014
)
(115,131
)

500,152

(163,314
)
201,699

(7,899
)
530,638


415,507

2,005,760

2,421,267


46,078

12,303

33,775

American Funds I.S. New World Fund
(3,879
)
22,790

(127,386
)
(108,475
)

182,128

(22,911
)
78,937

(4,070
)
234,084


125,609

526,965

652,574


24,333

3,446

20,887

Non-Affiliated Class A:

































DWS Small Cap Index VIP Fund
(2,174
)
41,646

(94,596
)
(55,124
)


(117,217
)
282

(108
)
(117,043
)

(172,167
)
557,164

384,997


267

3,941

(3,674
)
Non-Affiliated Class B:

































DWS Small Cap Index VIP Fund
(9,700
)
112,951

(294,378
)
(191,127
)

9,025

(53,248
)
69,457

(1,391
)
23,843


(167,284
)
1,463,219

1,295,935


10,892

8,906

1,986

Advisor Class:

































PIMCO VIT All Asset Portfolio
26,192

(5,687
)
(132,146
)
(111,641
)

43,309

(102,027
)
125,630

(2,388
)
64,524


(47,117
)
1,599,643

1,552,526


14,072

9,241

4,831

PIMCO VIT International Bond Portfolio (US Dollar Hedged)
(6
)
54

3

51


13,690



(3
)
13,687


13,738

4,037

17,775


1,304


1,304

PIMCO VIT CommodityRealReturn® Strategy Portfolio
6,816

(299,193
)
59,849

(232,528
)

19,813

(217,547
)
(27,324
)
(9,185
)
(234,243
)

(466,771
)
1,729,585

1,262,814


14,519

69,275

(54,756
)
PIMCO VIT Long-Term U.S. Government Portfolio
1,817

(1,709
)
(8,355
)
(8,247
)

570

(19,132
)
4,891

(698
)
(14,369
)

(22,616
)
207,450

184,834


2,343

3,782

(1,439
)
PIMCO VIT Low Duration Portfolio
5,810

(10,388
)
(17,591
)
(22,169
)

132,238

(120,880
)
(15,324
)
(6,479
)
(10,445
)

(32,614
)
1,840,094

1,807,480


20,651

21,599

(948
)
PIMCO VIT Real Return Portfolio
11,820

(19,863
)
(44,691
)
(52,734
)

290

(96,566
)
(29,756
)
(1,569
)
(127,601
)

(180,335
)
1,461,989

1,281,654


1,665

12,563

(10,898
)
PIMCO VIT Total Return Portfolio
191,370

(8,675
)
(652,104
)
(469,409
)

1,075,376

(2,599,919
)
(109,368
)
(169,885
)
(1,803,796
)

(2,273,205
)
21,873,580

19,600,375


116,220

252,778

(136,558
)
Investor Class:

































Guggenheim VT Global Managed Futures Strategy Fund
(4,058
)
(5,952
)
(17,604
)
(27,614
)

1,774

(34,090
)
1,160

(1,812
)
(32,968
)

(60,582
)
291,848

231,266


1,549

6,662

(5,113
)
Guggenheim VT Multi-Hedge Strategies Fund
(6,594
)
8,288

(35,001
)
(33,307
)

4,882

(104,008
)
(23,596
)
(1,617
)
(124,339
)

(157,646
)
542,872

385,226


1,655

16,017

(14,362
)
Guggenheim VT Long Short Equity Fund
(1,326
)
13,920

(26,058
)
(13,464
)


(3,934
)
(5,826
)
(130
)
(9,890
)

(23,354
)
104,099

80,745



866

(866
)
ETF Shares:

































iShares® Core S&P 500 ETF
(159,335
)
2,141,624

(3,244,778
)
(1,262,489
)

290,336

(2,851,133
)
(850,045
)

(3,410,842
)

(4,673,331
)
23,528,389

18,855,058


14,941

77,820

(62,879
)
iShares® Core S&P Mid-Cap ETF
(69,396
)
470,030

(1,200,318
)
(799,684
)

85,237

(776,019
)
96,674


(594,108
)

(1,393,792
)
6,734,383

5,340,591


9,031

20,310

(11,279
)
iShares® Core S&P Small-Cap ETF
(42,065
)
352,866

(604,110
)
(293,309
)

51,455

(416,530
)
(91,352
)

(456,427
)

(749,736
)
3,551,475

2,801,739


5,439

13,203

(7,764
)
iShares® Core U.S. Aggregate Bond ETF
(12
)
8,881

(27,017
)
(18,148
)

12,368

(57,875
)
12,802


(32,705
)

(50,853
)
670,947

620,094


2,357

3,661

(1,304
)
iShares® iBoxx $ High Yield Corporate Bond ETF
5,763

21,121

(33,429
)
(6,545
)

325

(128,197
)
9,865


(118,007
)

(124,552
)
248,934

124,382


412

4,269

(3,857
)
iShares® Intermediate-Term Corporate Bond ETF
4,306

14,408

(46,851
)
(28,137
)

39,312

(127,920
)
19,240


(69,368
)

(97,505
)
750,544

653,039


7,292

10,201

(2,909
)
iShares® International Treasury Bond ETF
(64,187
)
21,540

(99,667
)
(142,314
)

33,440

(342,667
)
94,553


(214,674
)

(356,988
)
2,992,379

2,635,391


11,983

21,278

(9,295
)
iShares® S&P 500 Growth ETF
(34,875
)
244,709

(244,061
)
(34,227
)

37,576

(122,033
)
(261,530
)

(345,987
)

(380,214
)
2,537,527

2,157,313


2,102

8,076

(5,974
)
iShares® S&P 500 Value ETF
(64
)
35,810

(90,599
)
(54,853
)

7,341

(49,380
)
64,616


22,577


(32,276
)
480,002

447,726


2,331

1,824

507

iShares® TIPS Bond ETF
124

613

(6,007
)
(5,270
)

9,162

(23,424
)
3,162


(11,100
)

(16,370
)
124,388

108,018


664

1,082

(418
)
Vanguard® Developed Markets Index Fund, ETF Shares
8,236

98,791

(636,765
)
(529,738
)

50,878

(351,747
)
267,711


(33,158
)

(562,896
)
3,213,756

2,650,860


8,932

9,554

(622
)
Vanguard® Dividend Appreciation Index Fund, ETF Shares
(9,754
)
227,633

(254,357
)
(36,478
)

41,475

(374,120
)
(55,713
)

(388,358
)

(424,836
)
1,420,278

995,442


2,156

10,227

(8,071
)
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
(10
)
20,378

(85,665
)
(65,297
)

17,424

(122,406
)
38,116


(66,866
)

(132,163
)
392,340

260,177


2,935

5,839

(2,904
)
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
1,089

7,600

(12,620
)
(3,931
)


(41,242
)
1,569


(39,673
)

(43,604
)
106,186

62,582


53

1,438

(1,385
)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 


(a) Name Change. See Note 1.
 
15
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Statements of Changes in Net Assets (continued)
For the Year Ended December 31, 2018

 
 Inccrease (deccrease) in net assets from operations
 
 Increase (decrease) in net assets from contract related transactions
 
 
 
 
 
 Unit Transactions
Subaccount
 Net investment
income (loss)
 Realized gain
(loss)
Change in net
unrealized
appreciation
(depreciation) during
the period
Net increase
(decrease) in net
assets resulting from
operations
 
Contributions from
contract holders
Contract
terminations and
benefits
 Net transfers among
investment options
Contract
maintenance
charges
Net increase (decrease)
in net assets from
contract related
transactions
 
Increase
(decrease) in net
assets
Net assets,
beginning of period
 Net assets, end of
period
 
 Units purchased
 Units redeemed
Increase
(decrease) in
units
ETF Shares (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vanguard® Large-Cap Index Fund, ETF Shares
$
(5,903
)
$
88,446

$
(125,305
)
$
(42,762
)

$
17,231

$
(119,022
)
$
(3,839
)
$

$
(105,630
)

$
(148,392
)
$
754,661

$
606,269


1,583

3,626

(2,043
)
Vanguard® Mega Cap Index Fund, ETF Shares
(668
)
6,677

(13,320
)
(7,311
)

260

(3,682
)
5,254


1,832


(5,479
)
128,635

123,156


216

182

34

Vanguard® Real Estate Index Fund, ETF Shares
4,906

18,183

(47,032
)
(23,943
)

650

(36,200
)
5,807


(29,743
)

(53,686
)
305,560

251,874


729

1,460

(731
)
Vanguard® Short-Term Bond Index Fund, ETF Shares
(58
)
1,831

(2,728
)
(955
)


(46,788
)
(78
)

(46,866
)

(47,821
)
65,921

18,100


12

2,011

(1,999
)
Vanguard® Total Bond Market Index Fund, ETF Shares
42,842

354,962

(1,025,490
)
(627,686
)

294,709

(2,808,318
)
505,241


(2,008,368
)

(2,636,054
)
22,484,595

19,848,541


67,529

151,484

(83,955
)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 



(a) Name Change. See Note 1.
 
16
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements
December 31, 2019
1. Organization and Nature of Operations

National Integrity Life Insurance Company Separate Account I (”the Separate Account”) is a unit investment trust registered under the Investment Company Act of 1940 (the “1940 Act”), established by the National Integrity Life Insurance Company (the “Company”), a life insurance company that is a wholly-owned subsidiary of Integrity Life Insurance Company (“Integrity”), which is a wholly-owned subsidiary of The Western and Southern Life Insurance Company. The Separate Account was established on May 19, 1986, under the insurance laws of the State of New York, for the purpose of issuing variable annuity contracts (“Contracts”).

Contract holders may allocate or transfer their account values to one or more of the Separate Account’s investment subaccounts, or for certain contract holders, to one or more fixed guarantee rate options of the Company’s Separate Account Guaranteed Principal Option (“GPO”). Options in the Separate Account GPO include fixed guaranteed rate options over various maturity periods that are subject to a market value adjustment (“MVA”). In addition, certain contract holders may also allocate or transfer their account values to options held in the Company’s general account. Such options include a guaranteed interest division, a quarterly rate option or a Systematic Transfer Option (“STO”). All STO contributions must be transferred to other investment divisions or to a guaranteed rate option within either six months or one year of the contribution.
 
Each subaccount invests all its investible assets in shares of corresponding investment portfolios (“Underlying Funds”) of the investment companies listed below:
American Funds Insurance Series
 
Columbia Funds Variable Portfolios
Non-Affiliated Class 2
 
Non-Affiliated Class 1
American Funds I.S. Managed Risk Asset Allocation Fund
 
Columbia VP – Select Mid Cap Value Fund
Non-Affiliated Class 4
 
Non-Affiliated Class 2
American Funds I.S. Bond Fund
 
Columbia VP – Small Cap Value Fund
American Funds I.S. Capital Income Builder Fund
 
 
American Funds I.S. Global Growth Fund
 
DWS Investments VIT Funds
American Funds I.S. Growth Fund
 
Non-Affiliated Class A:
American Funds I.S. Growth-Income Fund
 
DWS Small Cap Index VIP Fund
American Funds I.S. New World Fund
 
Non-Affiliated Class B:
 
 
DWS Small Cap Index VIP Fund
BlackRock Variable Series Funds
 
 
Non-Affiliated Class 3
 
 
BlackRock Capital Appreciation V.I. Fund
 
 
BlackRock Global Allocation V.I. Fund
 
 
BlackRock High Yield V.I. Fund
 
 
BlackRock Total Return V.I. Fund
 
 


17

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

1. Organization and Nature of Operations (continued)
Fidelity Variable Insurance Products
 
Franklin Templeton VIP Trust (continued)
Non-Affiliated Initial Class:
 
Non-Affiliated Class 2 (continued):
Fidelity VIP Balanced Portfolio
 
Franklin Large Cap Growth VIP Fund
Fidelity VIP Overseas Portfolio
 
Franklin Mutual Shares VIP Fund
Fidelity VIP Equity-Income Portfolio
 
Franklin Small Cap Value VIP Fund
Fidelity VIP Growth Portfolio
 
Templeton Foreign VIP Fund
Fidelity VIP High Income Portfolio
 
Templeton Global Bond VIP Fund
Fidelity VIP Asset Manager Portfolio
 
Templeton Growth VIP Fund
Fidelity VIP Contrafund® Portfolio
 
 
Fidelity VIP Index 500 Portfolio
 
Rydex Variable Trust (Guggenheim Variable Insurance Funds)
Fidelity VIP Investment Grade Bond Portfolio
 
Investor Class:
Fidelity VIP Government Money Market
 
Guggenheim VT Global Managed Futures Strategy Fund
Non-Affiliated Service Class:
 
Guggenheim VT Multi-Hedge Strategies Fund
Fidelity VIP Growth Portfolio
 
Guggenheim VT Long Short Equity Fund
Fidelity VIP Mid Cap Portfolio
 
 
Non-Affiliated Service Class 2:
 
iShares Trust
Fidelity VIP Asset Manager Portfolio
 
ETF Shares:
Fidelity VIP Balanced Portfolio
 
iShares® Core S&P 500 ETF
Fidelity VIP Bond Index Portfolio
 
iShares® Core S&P Mid-Cap ETF
Fidelity VIP Contrafund® Portfolio
 
iShares® Core S&P Small-Cap ETF
Fidelity VIP Disciplined Small Cap Portfolio
 
iShares® Core U.S. Aggregate Bond ETF
Fidelity VIP Equity-Income Portfolio
 
iShares® iBoxx $ High Yield Corporate Bond ETF
Fidelity VIP Extended Market Index Portfolio
 
iShares® Intermediate-Term Corporate Bond ETF
Fidelity VIP Freedom 2010 Portfolio
 
iShares® International Treasury Bond ETF
Fidelity VIP Freedom 2015 Portfolio
 
iShares® S&P 500 Growth ETF
Fidelity VIP Freedom 2020 Portfolio
 
iShares® S&P 500 Value ETF
Fidelity VIP Freedom 2025 Portfolio
 
iShares® TIPS Bond ETF
Fidelity VIP Freedom 2030 Portfolio
 
 
Fidelity VIP Growth Portfolio
 
Invesco (AIM) Variable Insurance Funds
Fidelity VIP High Income Portfolio
 
Non-Affiliated Class 2:
Fidelity VIP Index 500 Portfolio
 
Invesco V.I. American Franchise Fund
Fidelity VIP International Index Portfolio
 
Invesco V.I. American Value Fund
Fidelity VIP Investment Grade Bond Portfolio
 
Invesco V.I. Comstock Fund
Fidelity VIP Mid Cap Portfolio
 
Invesco V.I. International Growth Fund
Fidelity VIP Overseas Portfolio
 
Invesco V.I. Mid Cap Growth Fund
Fidelity VIP Target Volatility Portfolio
 
 
Fidelity VIP Total Market Index Portfolio
 
JPMorgan Insurance Trust
Franklin Templeton VIP Trust
 
Non-Affiliated Class 1:
Non-Affiliated Class 1:
 
JP Morgan IT Mid Cap Value
Franklin Growth and Income VIP Fund
 
 
Franklin Income VIP Fund
 
Morgan Stanley Variable Insurance Funds, Inc.
Non-Affiliated Class 2:
 
Non-Affiliated Class 1:
Franklin Growth and Income VIP Fund
 
Morgan Stanley VIF Emerging Markets Debt Portfolio
Franklin Income VIP Fund
 
Morgan Stanley VIF U.S. Real Estate Portfolio

18

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

1. Organization and Nature of Operations (continued)
Morgan Stanley Variable Insurance Funds, Inc.
 
Touchstone Variable Series Trust
Non-Affiliated Class 2:
 
Affiliated (*Service Class):
Morgan Stanley VIF Emerging Markets Debt Portfolio
 
Touchstone VST Active Bond Fund
Morgan Stanley VIF Emerging Markets Equity Portfolio
 
*Touchstone VST Aggressive ETF Fund
Morgan Stanley VIF U.S. Real Estate Portfolio
 
*Touchstone VST Bond Fund
 
 
*Touchstone VST Common Stock Fund
Pimco Variable Insurance Trust
 
*Touchstone VST Conservative ETF Fund
Advisor Class:
 
Touchstone VST Focused Fund
PIMCO VIT All Asset Portfolio
 
Touchstone VST Large Cap Core Equity Fund
PIMCO VIT International Bond Portfolio (US Dollar Hedged)
 
*Touchstone VST Moderate ETF Fund
PIMCO VIT CommodityRealReturn® Strategy Portfolio
 
 
PIMCO VIT Long-Term U.S. Government Portfolio
 
The Vanguard Index Funds
PIMCO VIT Low Duration Portfolio
 
ETF Shares:
PIMCO VIT Real Return Portfolio
 
Vanguard® Developed Markets Index Fund, ETF Shares
PIMCO VIT Total Return Portfolio
 
Vanguard® Dividend Appreciation Index Fund, ETF Shares

 
 
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
Northern Lights Variable Trust
 
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares

Non-Affiliated Class 3:
 
Vanguard® Large-Cap Index Fund, ETF Shares
TOPS® Managed Risk Moderate Growth ETF Portfolio
 
Vanguard® Mega Cap Index Fund, ETF Shares
 
 
Vanguard® Real Estate Index Fund, ETF Shares
 
 
Vanguard® Short-Term Bond Index Fund, ETF Shares
 
 
Vanguard® Total Bond Market Index Fund, ETF Shares


















19

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

1. Organization and Nature of Operations (continued)
During the year ended December 31, 2019, the following Underlying Funds had name changes that were made effective:
Date:
 
New Name:
 
Old Name:
5/1/2019
 
Columbia VP - Select Mid Cap Value Class 1
 
Columbia VP - Mid Cap Value Class 1
 
 
 
 
 
The statement of operations for all of the Underlying Funds are presented in the financial statements for the year ended December 31, 2019 except for the following Underlying Funds:
Period:
 
Underlying Fund:
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Active Bond Fund
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Focused Fund
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Large Cap Core Equity Fund
 
 
7/12/2019 - 12/31/2019
 
Touchstone VST Bond Fund
 
 
7/12/2019 - 12/31/2019
 
Touchstone VST Common Stock Fund
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP Bond Index Portfolio
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP International Index Portfolio
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP Extended Market Index Portfolio
 
 
 
 
 
 
 
The statements of changes in net assets for all of the Underlying Funds are presented in the financial statements for the year ended December 31, 2019 and December 31, 2018 with the exception of the following Underlying Funds:
Period:
 
Underlying Fund:
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Active Bond Fund
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Focused Fund
 
 
1/1/2019 - 7/11/2019
 
Touchstone VST Large Cap Core Equity Fund
 
 
7/12/2019 - 12/31/2019
 
Touchstone VST Bond Fund
 
 
7/12/2019 - 12/31/2019
 
Touchstone VST Common Stock Fund
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP Bond Index Portfolio
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP International Index Portfolio
 
 
7/12/2019 - 12/31/2019
 
Fidelity VIP Extended Market Index Portfolio
 
 
 
 
 
 
 
All of the Underlying Funds had activity during the year ended December 31, 2019 and December 31, 2018 except for the following Underlying Funds:
Underlying Fund:
 
2019 2018
 
 
Fidelity VIP Total Market Index Portfolio* X N/A
 
 
 
 
 
 
 
* The Underlying Fund commenced operations on July 12, 2019
 
 
 
 
 
As a result of restructuring, the following Underlying Fund that was previously offered is no longer available as an investment option to our contract holders. Any contract holder allocations that remained in this fund were redeemed and used to purchase shares of the surviving funds as indicated:
Date:
 
Surviving Underlying Fund:
 
Closed Underlying Fund:
7/12/2019
 
Touchstone VST Bond Fund
 
Touchstone VST Active Bond Fund
7/12/2019
 
Touchstone VST Common Stock Fund
 
Touchstone VST Focused Fund
7/12/2019
 
Touchstone VST Common Stock Fund
 
Touchstone VST Large Cap Core Equity Fund

20

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

1. Organization and Nature of Operations (continued)

Mid Atlantic Trust Company (“MATC”), a South Dakota registered non-depository trust company, is the custodian for the Vanguard ETFs and the iShares ETFs held by the subaccounts.

The contract holder’s account value in a subaccount will vary depending on the performance of the corresponding Underlying Fund. The Separate Account currently has 107 investment subaccounts available. The investment objective of each subaccount is to invest in the corresponding Underlying Fund. Refer to each Underlying Fund’s prospectus for a description of investment objectives.

Under applicable insurance law, the assets and liabilities of the Separate Account are clearly identified and distinguished from the Company’s other assets and liabilities. The portion of the Separate Account’s assets applicable to contract holders’ accounts is not chargeable with liabilities arising out of any other business the Company may conduct.

2. Summary of Significant Accounting Policies

Basis of Presentation

The accompanying financial statements have been prepared in accordance with U.S. generally accepted accounting principles (“US GAAP”).

Investments

Investments in shares of the Underlying Funds are valued at fair value as determined by the closing net asset value per share on December 31, 2019. The difference between cost and fair value is reflected as unrealized appreciation or depreciation of investments.

Share transactions are recorded on the trade date. Realized gains and losses on sales of the Underlying Funds’ shares of the Funds are determined based on identified cost basis.

Capital gain distributions are included in the realized gain distributions line on the Statements of Operations. Dividends are included in the reinvested dividends line on the Statements of Operations. Dividends and capital gain distributions are recorded on the ex-dividend date. Dividends and capital gain distributions from
the Underlying Funds’ are reinvested in the respective Underlying Funds and are reflected in the unit values of the subaccounts.

The Separate Account’s investments are held at fair value. Fair value is the price that the Separate Account would receive to sell an asset or pay to transfer a liability in an orderly transaction between market participants at the measurement date. Fair Value is established using a three-level hierarchy based upon the transparency of inputs to the valuation of an asset or liability. Inputs may be observable or unobservable and refer broadly to the assumptions that market participants would use in pricing the asset or liability. Observable inputs reflect the assumptions market participants would use in pricing the asset or liability based on market data obtained

21

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

2. Summary of Significant Accounting Policies (continued)

from sources independent of the reporting entity. Unobservable inputs reflect the reporting entity’s own assessment regarding the assumptions market participants would use in pricing the asset or liability and are developed based on the best information available in the circumstances. The Separate Account’s investments are assigned a level based upon the observability of the inputs that are significant to the overall valuation. The three-tier hierarchy of inputs is summarized below.

Level 1 - inputs to the valuation methodology are quoted prices in active markets.
Level 2 - inputs to the valuation methodology are observable, directly or indirectly.
Level 3 - inputs to the valuation methodology are unobservable and reflect assumptions on the part of the reporting entity.

The Separate Account’s investments are valued as Level 1. There were no transfers between levels 1, 2, and 3 during the year. The Separate Account’s policy is to recognize the transfers in and transfers out of levels at the beginning of the annual reporting period.

Unit Value

Unit values for the subaccounts are computed at the end of each business day. The unit value is equal to the unit value for the preceding business day multiplied by a net investment factor. This net investment factor is determined based on the net asset value of the Underlying Fund, reinvested dividends and capital gains, and the daily asset charge for the mortality and expense risk and certain administrative charges, as applicable.

Taxes

Operations of the Separate Account are included in the income tax return of the Company, which is taxed as a life insurance company under the Internal Revenue Code (“IRC”). The Separate Account is not taxed as a regulated investment company under Subchapter M of the IRC. Under the provisions of the policies, the Company has the right to charge the Separate Account for federal income tax attributable to the Separate Account. No charge is currently being made against the Separate Account for such tax since, under current tax law, the Company pays no tax on investment income and capital gains reflected in variable life insurance policy reserves. However, the Company retains the right to charge for any federal income tax incurred, which
is attributable to the Separate Account if the law is changed. Charges for state and local taxes, if any, attributable to the Separate Account may also be made.

Use of Estimates

The preparation of financial statements in accordance with the US GAAP requires management to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates.


22

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

2. Summary of Significant Accounting Policies (continued)

Subsequent Events

Management has evaluated subsequent events though the issuance of these financial statements and
determined that no additional disclosures are required.

The extent of the impact of the coronavirus (“COVID-19”) outbreak on the financial performance of the Underlying Funds will depend on future developments, including the duration and spread of the outbreak and related advisories and restrictions and the impact of COVID-19 on the financial markets and the overall economy, all of which are highly uncertain and cannot be predicted. If the financial markets and/or the overall economy are impacted for an extended period, the Underlying Funds' investment results may be materially affected.

No additional events were identified requiring further disclosure in these financial statements.







23

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

3. Investments

The aggregate cost of Underlying Fund shares purchased and proceeds from Underlying Fund shares sold during the period ended December 31, 2019 and the cost of investments held at December 31, 2019, for each subaccount, were as follows:

Subaccount
 Purchases
 Sales
 Cost
Affiliated:
 
 
 
Touchstone VST Active Bond Fund (c)
$
196,084

$
2,731,682

$

Touchstone VST Aggressive ETF Fund
507,604

859,528

4,803,633

Touchstone VST Bond Fund (b)
2,365,361

268,470

2,102,299

Touchstone VST Common Stock Fund (b)
20,126,855

1,494,991

18,622,832

Touchstone VST Conservative ETF Fund
261,916

1,370,710

5,672,585

Touchstone VST Focused Fund (c)
908,358

17,239,530


Touchstone VST Large Cap Core Equity Fund (c)
778,334

3,857,861


Touchstone VST Moderate ETF Fund
683,232

1,919,792

7,329,422

Non-Affiliated Initial Class:






Fidelity VIP Balanced Portfolio
120,803

106,545

1,672,358

Fidelity VIP Overseas Portfolio
62,661

143,389

890,470

Fidelity VIP Equity-Income Portfolio
717,430

846,238

6,858,006

Fidelity VIP Growth Portfolio
370,916

635,600

3,181,470

Fidelity VIP High Income Portfolio
850,543

632,035

1,728,871

Fidelity VIP Asset Manager Portfolio
166,001

351,876

2,617,275

Fidelity VIP Contrafund® Portfolio
1,620,344

1,759,036

11,003,218

Fidelity VIP Index 500 Portfolio
152,609

531,697

2,211,832

Fidelity VIP Investment Grade Bond Portfolio
48,415

193,241

1,388,963

Fidelity VIP Government Money Market
13,523,797

20,690,421

3,369,376

Non-Affiliated Service Class:






Fidelity VIP Growth Portfolio
22,536

89,407

203,922

Fidelity VIP Mid Cap Portfolio
356,342

377,352

2,823,373

Non-Affiliated Service Class 2:






Fidelity VIP Asset Manager Portfolio
254,613

107,009

1,094,559

Fidelity VIP Balanced Portfolio
3,172,657

1,966,392

9,510,556

Fidelity VIP Bond Index Portfolio (b)
87,095

412

86,677

Fidelity VIP Contrafund® Portfolio
2,567,917

3,107,648

15,632,427

Fidelity VIP Disciplined Small Cap Portfolio
358,994

203,502

1,550,059

Fidelity VIP Equity-Income Portfolio
814,206

682,238

2,973,837

Fidelity VIP Extended Market Index Portfolio (b)
34,140

194

33,953

Fidelity VIP Freedom 2010 Portfolio
26,526

113,242

351,508

Fidelity VIP Freedom 2015 Portfolio
39,489

64,018

371,652

Fidelity VIP Freedom 2020 Portfolio
45,947

51,962

586,336

Fidelity VIP Freedom 2025 Portfolio
232,256

49,681

1,787,620

Fidelity VIP Freedom 2030 Portfolio
45,773

299,324

293,933

Fidelity VIP Growth Portfolio
709,219

500,949

3,083,672

Fidelity VIP High Income Portfolio
18,137,502

12,178,687

6,904,273

Fidelity VIP Index 500 Portfolio
4,155,793

4,428,893

21,519,811

Fidelity VIP International Index Portfolio (b)
1,485

1

1,484

Fidelity VIP Investment Grade Bond Portfolio
1,933,112

1,831,450

14,589,561

Fidelity VIP Mid Cap Portfolio
2,950,550

1,012,882

8,729,384

Fidelity VIP Overseas Portfolio
298,160

2,245,655

2,263,082

Fidelity VIP Target Volatility Portfolio
27,404

24,914

438,177




(a) Name Change. See Note 1.
 
24
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

3. Investments



Subaccount
 Purchases
 Sales
 Cost
Non-Affiliated Class 1:
 
 
 
Columbia VP – Select Mid Cap Value Fund (a)
$
212,769

$
150,817

$
1,194,740

Franklin Growth and Income VIP Fund
143,758

230,406

1,345,060

Franklin Income VIP Fund
241,044

622,076

2,862,343

JP Morgan IT Mid Cap Value
57,587

132,999

473,258

Morgan Stanley VIF Emerging Markets Debt Portfolio
6,058

27,096

113,049

Morgan Stanley VIF U.S. Real Estate Portfolio
61,744

113,803

509,934

Non-Affiliated Class 2:






American Funds I.S. Managed Risk Asset Allocation Fund
259,759

85,431

1,936,095

Columbia VP – Small Cap Value Fund
529,459

425,771

1,939,531

Franklin Growth and Income VIP Fund
615,000

958,964

4,413,132

Franklin Income VIP Fund
1,923,860

1,819,368

14,264,466

Franklin Large Cap Growth VIP Fund
747,083

763,828

4,770,679

Franklin Mutual Shares VIP Fund
1,778,325

1,411,366

10,271,683

Franklin Small Cap Value VIP Fund
343,228

195,240

1,222,195

Invesco V.I. American Franchise Fund
124,768

51,957

303,259

Invesco V.I. American Value Fund
1,606,021

859,735

8,233,612

Invesco V.I. Comstock Fund
914,108

428,962

3,837,358

Invesco V.I. International Growth Fund
466,429

237,191

1,991,188

Invesco V.I. Mid Cap Growth Fund
179,204

39,745

306,744

Templeton Foreign VIP Fund
668,704

496,786

4,531,457

Templeton Global Bond VIP Fund
182,375

176,798

607,136

Templeton Growth VIP Fund
333,761

200,630

1,388,754

Morgan Stanley VIF Emerging Markets Debt Portfolio
153,256

113,784

967,163

Morgan Stanley VIF Emerging Markets Equity Portfolio
360,761

315,315

2,249,404

Morgan Stanley VIF U.S. Real Estate Portfolio
434,086

405,506

2,334,822

Non-Affiliated Class 3:






BlackRock Capital Appreciation V.I. Fund
1,064,936

499,847

3,485,908

BlackRock Global Allocation V.I. Fund
64,660

113,336

595,472

BlackRock High Yield V.I. Fund
81,386

6,146

204,896

BlackRock Total Return V.I. Fund
141,985

14,620

296,081

TOPS® Managed Risk Moderate Growth ETF Portfolio
118,874

105,184

1,114,256

Non-Affiliated Class 4:






American Funds I.S. Bond Fund
188,283

38,193

665,289

American Funds I.S. Capital Income Builder Fund
1,283,729

83,736

2,822,686

American Funds I.S. Global Growth Fund
489,321

228,664

1,985,535

American Funds I.S. Growth Fund
799,337

122,961

2,317,816

American Funds I.S. Growth-Income Fund
671,323

383,506

2,851,164

American Funds I.S. New World Fund
208,765

84,319

815,274

Non-Affiliated Class A:






DWS Small Cap Index VIP Fund
42,922

47,043

416,113

Non-Affiliated Class B:






DWS Small Cap Index VIP Fund
387,477

194,846

1,614,167

Advisor Class:






PIMCO VIT All Asset Portfolio
113,122

261,154

1,491,525

PIMCO VIT International Bond Portfolio (US Dollar Hedged)
21,974

403

39,520

PIMCO VIT CommodityRealReturn® Strategy Portfolio
191,002

254,323

1,605,968

PIMCO VIT Long-Term U.S. Government Portfolio
21,290

27,117

186,491

PIMCO VIT Low Duration Portfolio
395,408

100,735

2,152,266

PIMCO VIT Real Return Portfolio
75,848

532,681

915,413


 
 
 

(a) Name Change. See Note 1.
 
25
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

3. Investments

Subaccount
 Purchases
 Sales
 Cost
 
 
 
 
Advisor Class (continued):
 
 
 
PIMCO VIT Total Return Portfolio
$
2,239,276

$
3,348,762

$
19,390,878

Investor Class:






Guggenheim VT Global Managed Futures Strategy Fund
15,900

97,041

185,689

Guggenheim VT Multi-Hedge Strategies Fund
16,109

66,701

322,867

Guggenheim VT Long Short Equity Fund
888

13,561

74,972

ETF Shares:






iShares® Core S&P 500 ETF
889,832

5,986,945

13,152,229

iShares® Core S&P Mid-Cap ETF
357,435

1,505,855

4,140,228

iShares® Core S&P Small-Cap ETF
266,212

758,552

2,199,858

iShares® Core U.S. Aggregate Bond ETF
73,077

146,215

599,589

iShares® iBoxx $ High Yield Corporate Bond ETF
9,126

68,851

128,346

iShares® Intermediate-Term Corporate Bond ETF
65,488

71,465

708,997

iShares® International Treasury Bond ETF
233,478

635,951

2,244,644

iShares® S&P 500 Growth ETF
110,314

511,654

1,506,441

iShares® S&P 500 Value ETF
37,319

87,927

435,631

iShares® TIPS Bond ETF
18,371

6,976

127,603

Vanguard® Developed Markets Index Fund, ETF Shares
197,530

710,860

2,536,539

Vanguard® Dividend Appreciation Index Fund, ETF Shares
45,432

249,995

802,509

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
23,851

99,875

222,662

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
2,109

9,540

65,068

Vanguard® Large-Cap Index Fund, ETF Shares
31,894

79,780

546,545

Vanguard® Mega Cap Index Fund, ETF Shares
7,045

23,752

92,600

Vanguard® Real Estate Index Fund, ETF Shares
16,285

84,883

243,762

Vanguard® Short-Term Bond Index Fund, ETF Shares
912

4,896

17,810

Vanguard® Total Bond Market Index Fund, ETF Shares
1,672,064

5,057,526

18,453,009



(a) Name Change. See Note 1.
 
26
(b) New Underlying Fund. See Note 1.
 
(c) Merger. See Note 1.
 
 


Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

4. Expenses and Related Party Transactions

The Company assumes mortality and expense risks and incurs certain administrative expenses related to the operations of the Separate Account. All charges listed below are under “Mortality and Expense %” are the annual rates deducted as a daily charge, thus affecting the unit values. All other charges, including the annual administration fee, some optional benefit fees (those not listed under “Mortality and Expense %”), withdrawal charges and transfer charges, if any, are taken from the contract’s account value by redeeming units. Fourteen contracts are currently included in the Separate Account. The products are stated in the table below, along with the mortality and expense charges and the annual administration fee:
 
Contracts
Mortality and
Annual Administration
Expense %
Fee
1
GrandMaster
1.35

$30

2
GrandMaster flex3
1.55

$50

3
IQ
1.35

$30

4
IQ3
1.45

$30

5
IQ Advisor - Standard
0.60
N/A

 
IQ Advisor - Enhanced
0.80
N/A

6
AnnuiChoice
1.00

$30

7
AnnuiChoice II
1.15

$30

 
AnnuiChoice II - GMAB Rider
1.75

$30

8
Pinnacle Plus
1.67

$40

 
Pinnacle Plus- Reduced M&E
1.15

$40

9
Pinnacle
1.35

$30

 
Pinnacle-Reduced M&E
1.10

$30

10
Pinnacle IV
1.45

$30

 
Pinnacle IV - GMAB
2.05

$30

11
Pinnacle V
1.55

$30

 
Pinnacle V - GMAB
2.15

$30

12
AdvantEdge
1.60

$50

13
Varoom
1.75
N/A

 
Varoom - Standard option
2.35
N/A

 
Varoom - Self Styled Option
2.55
N/A

14
Varoom II
1.90
N/A

 
Varoom II - Standard Option
2.55
N/A

 
Varoom II - Self Styled Option
2.75
N/A


For optional benefits that are not included in the daily mortality and expense charge, the Company deducts an amount either quarterly or annually, depending on the benefit, to cover the cost of the additional benefits elected.

27

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

4. Expenses and Related Party Transactions (continued)


For charges that are dependent on contract owner actions, e.g., withdrawal charges and transfer fees, the Company deducts an amount at the time of the transaction to cover the cost. In both situations (ongoing benefit charges and transaction charges), the fees are deducted from the account value by redeeming units.

Touchstone Advisors Inc., which is affiliated with the Company, advises each of the Touchstone Variable Series Trust offered through the Company’s variable products.


28

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights

A summary of net assets, unit values and units outstanding for variable annuity contracts, investment income and expense ratios, excluding expenses of the underlying funds and total returns are presented for each period ended December 31. The ranges of lowest to highest unit values and total return are based on the product groupings that represent lowest and highest expense ratio amounts. The first unit value presented in the range of each subaccount within the table corresponds to the highest expense ratio for each subaccount presented within the table. The first total return presented in the range of each subaccount within the table corresponds to the highest expense ratio for each subaccount presented within the table. Therefore, some individual contract ratios are not within the ranges presented.

** Investment income ratio amounts represent the dividends, excluding distributions of capital gains, received by the subaccount from the Underlying Fund net of management fees assessed by the fund manager, divided by the average net assets. These ratios exclude those expenses, such as mortality and expense risk and administrative charges, that result in direct reductions in the unit values. The recognition of investment income by the subaccount is affected by the timing of the declaration of dividends by the Underlying Fund in which the subaccounts invest.

*** Expense ratio amounts represent the annualized contract expenses of the subaccount, consisting primarily of mortality and expense risk and administrative charges, for each period indicated. The ratios include only those expenses that result in a direct reduction to unit values. Charges made directly to contract owner accounts through the redemption of units and expenses of the underlying fund are excluded.

**** Total return amounts represent the total return for the periods indicated, including changes in the fair value of the Underlying Fund, which includes expenses assessed through the reduction of unit values. The ratio does not include any expenses assessed through the redemption of units. Subaccounts with a date notation indicate the effective date of that investment option in the variable account. The total return is calculated for the period indicated or from the effective date through the end of the reporting period.



29

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2019
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
Affiliated:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Touchstone VST Aggressive ETF Fund
250

$
20.62

to
$
22.85

$
5,628

1.65
%

1.00
%
to
1.67
%

20.34
 %
to
21.16%
Touchstone VST Bond Fund (b)
209

10.17

to
10.20

2,129

1.26
%
 
1.00
%
to
1.67
%
 
1.67
 %
to
2.00%
Touchstone VST Common Stock Fund (b)
1,834

10.78

to
10.81

19,789

0.55
%
 
1.00
%
to
1.67
%
 
7.77
 %
to
8.12%
Touchstone VST Conservative ETF Fund
331

15.03

to
18.42

5,619

2.47
%

1.00
%
to
1.60
%

13.62
 %
to
14.31%
Touchstone VST Moderate ETF Fund
376

20.40

to
21.04

6,855

2.03
%

1.00
%
to
2.05
%

16.53
 %
to
17.77%
Non-Affiliated Initial Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Balanced Portfolio
76

20.72

to
33.75

2,023

1.73
%

1.35
%
to
1.35
%

22.83
 %
to
22.83%
Fidelity VIP Overseas Portfolio
36

11.80

to
15.65

1,223

1.68
%

1.15
%
to
1.55
%

25.79
 %
to
26.30%
Fidelity VIP Equity-Income Portfolio
93

31.28

to
31.91

7,810

1.98
%

1.10
%
to
1.35
%

25.72
 %
to
26.04%
Fidelity VIP Growth Portfolio
29

181.86

to
181.86

5,227

0.26
%

1.35
%
to
1.35
%

32.50
 %
to
32.50%
Fidelity VIP High Income Portfolio
56

31.00

to
31.00

1,743

5.31
%

1.35
%
to
1.35
%

13.55
 %
to
13.55%
Fidelity VIP Asset Manager Portfolio
46

60.68

to
60.68

2,777

1.76
%

1.35
%
to
1.35
%

16.65
 %
to
16.65%
Fidelity VIP Contrafund® Portfolio
178

50.00

to
51.00

13,551

0.45
%

1.10
%
to
1.35
%

29.80
 %
to
30.13%
Fidelity VIP Index 500 Portfolio
101

23.34

to
24.11

4,690

1.91
%

1.10
%
to
1.45
%

29.45
 %
to
29.91%
Fidelity VIP Investment Grade Bond Portfolio
76

14.20

to
15.24

1,426

2.65
%

1.00
%
to
1.55
%

7.97
 %
to
8.57%
Fidelity VIP Government Money Market
344

9.53

to
9.98

3,369

2.06
%

1.00
%
to
2.75
%

(0.79
)%
to
1.00%
Non-Affiliated Service Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Growth Portfolio
12

26.49

to
26.49

323

0.16
%

1.35
%
to
1.35
%

32.37
 %
to
32.37%
Fidelity VIP Mid Cap Portfolio
41

68.96

to
72.23

2,892

0.78
%

1.10
%
to
1.35
%

21.68
 %
to
21.99%
Non-Affiliated Service Class 2:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Asset Manager Portfolio
65

19.42

to
22.06

1,103

1.72
%

1.00
%
to
1.67
%

16.04
 %
to
16.83%
Fidelity VIP Balanced Portfolio
498

24.59

to
27.98

10,560

1.62
%

1.00
%
to
1.67
%

22.04
 %
to
22.88%
Fidelity VIP Bond Index Portfolio (b)
8

10.15

to
10.15

85

3.77
%
 
1.55
%
to
1.55
%
 
1.48
 %
to
1.48%
Fidelity VIP Contrafund® Portfolio
667

36.51

to
40.90

17,646

0.21
%

1.00
%
to
1.67
%

29.08
 %
to
29.96%
Fidelity VIP Disciplined Small Cap Portfolio
87

17.07

to
18.61

1,546

0.81
%

1.00
%
to
1.67
%

21.31
 %
to
22.14%
Fidelity VIP Equity-Income Portfolio
176

25.48

to
26.16

3,356

1.87
%

1.00
%
to
1.67
%

24.99
 %
to
25.84%
Fidelity VIP Extended Market Index Portfolio (b)
3

10.55

to
10.55

37

1.20
%
 
1.55
%
to
1.55
%
 
5.51
 %
to
5.51%
Fidelity VIP Freedom 2010 Portfolio
26

14.94

to
15.56

397

1.81
%

1.35
%
to
1.67
%

13.82
 %
to
14.19%
Fidelity VIP Freedom 2015 Portfolio
26

15.89

to
16.59

413

1.70
%

1.15
%
to
1.60
%

16.09
 %
to
16.62%
Fidelity VIP Freedom 2020 Portfolio
42

16.12

to
16.44

653

1.78
%

1.15
%
to
1.60
%

17.96
 %
to
18.50%
Fidelity VIP Freedom 2025 Portfolio
120

17.11

to
17.38

1,969

1.84
%

1.15
%
to
1.60
%

19.57
 %
to
20.12%
Fidelity VIP Freedom 2030 Portfolio
22

16.32

to
19.60

363

1.33
%

1.15
%
to
1.67
%

22.04
 %
to
22.69%
Fidelity VIP Growth Portfolio
136

34.46

to
31.59

3,900

0.05
%

1.00
%
to
1.67
%

31.74
 %
to
32.64%
Fidelity VIP High Income Portfolio
336

20.77

to
26.68

6,807

6.67
%

1.00
%
to
1.67
%

12.85
 %
to
13.62%
Fidelity VIP Index 500 Portfolio
1,273

32.38

to
30.14

29,166

1.73
%

1.00
%
to
1.67
%

28.83
 %
to
29.71%
Fidelity VIP International Index Portfolio (b)
*-

10.65

to
10.65

2

12.35
%
 
1.15
%
to
1.15
%
 
6.52
 %
to
6.52%
Fidelity VIP Investment Grade Bond Portfolio
1,065

14.42

to
18.64

15,005

2.58
%

1.00
%
to
1.67
%

7.58
 %
to
8.31%
Fidelity VIP Mid Cap Portfolio
335

39.52

to
45.68

8,716

0.70
%

1.00
%
to
1.67
%

21.12
 %
to
21.94%
Fidelity VIP Overseas Portfolio
196

22.72

to
21.97

2,673

1.20
%

1.00
%
to
1.67
%

25.37
 %
to
26.23%
Fidelity VIP Target Volatility Portfolio
36

13.32

to
13.65

486

1.37
%

1.15
%
to
1.55
%

16.81
 %
to
17.28%
Non-Affiliated Class 1:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Columbia VP – Select Mid Cap Value Fund (a)
80

18.69

to
19.56

1,539

%

1.15
%
to
1.67
%

29.43
 %
to
30.11%
Franklin Growth and Income VIP Fund
57

30.72

to
30.72

1,751

2.50
%

1.35
%
to
1.35
%

24.35
 %
to
24.35%
Franklin Income VIP Fund
106

28.69

to
29.27

3,053

5.59
%

1.10
%
to
1.35
%

14.85
 %
to
15.14%
JP Morgan IT Mid Cap Value
18

36.84

to
39.09

630

1.70
%

1.00
%
to
1.55
%

24.80
 %
to
25.49%
Morgan Stanley VIF Emerging Markets Debt Portfolio
3

27.81

to
35.02

107

5.33
%

1.10
%
to
1.55
%

12.48
 %
to
13.00%
Morgan Stanley VIF U.S. Real Estate Portfolio
17

36.36

to
40.27

714

1.86
%

1.00
%
to
1.55
%

17.10
 %
to
17.75%
Non-Affiliated Class 2:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
163

13.15

to
13.61

2,148

2.35
%

1.00
%
to
1.55
%

16.16
 %
to
16.81%
Columbia VP – Small Cap Value Fund
65

27.02

to
28.58

1,751

0.27
%

1.15
%
to
1.67
%

18.97
 %
to
19.59%
Franklin Growth and Income VIP Fund
215

26.69

to
31.25

4,983

2.23
%

1.00
%
to
1.67
%

23.56
 %
to
24.40%
Franklin Income VIP Fund
842

23.13

to
29.19

14,513

5.40
%

1.00
%
to
1.67
%

14.12
 %
to
14.90%
Franklin Large Cap Growth VIP Fund
170

28.58

to
35.12

5,003

%

1.00
%
to
1.67
%

32.33
 %
to
33.23%
Franklin Mutual Shares VIP Fund
593

23.70

to
28.91

9,919

1.84
%

1.00
%
to
1.67
%

20.53
 %
to
21.35%
Franklin Small Cap Value VIP Fund
58

18.42

to
23.32

1,104

1.06
%

1.15
%
to
1.67
%

24.24
 %
to
24.90%
Invesco V.I. American Franchise Fund
12

32.03

to
27.45

356

%

1.15
%
to
1.67
%

34.15
 %
to
34.86%

(a) Name Change. See Note 1.
 
30
(b) New Underlying Fund. See Note 1
 

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2019
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Invesco V.I. American Value Fund
386

$
18.52

to
$
20.05

$
7,406

0.44
%

1.00
%
to
1.67
%

22.63
 %
to
23.46%
Invesco V.I. Comstock Fund
188

27.73

to
33.97

3,722

1.74
%

1.00
%
to
1.67
%

22.86
 %
to
23.69%
Invesco V.I. International Growth Fund
162

13.06

to
13.59

2,146

1.33
%

1.15
%
to
1.60
%

26.19
 %
to
26.77%
Invesco V.I. Mid Cap Growth Fund
20

15.17

to
15.40

305

%

1.15
%
to
1.55
%

31.93
 %
to
32.46%
Templeton Foreign VIP Fund
366

18.71

to
22.58

4,336

1.69
%

1.00
%
to
1.67
%

10.65
 %
to
11.40%
Templeton Global Bond VIP Fund
62

9.42

to
9.68

585

6.16
%

1.15
%
to
1.55
%

0.43
 %
to
0.84%
Templeton Growth VIP Fund
75

19.23

to
23.32

1,234

2.80
%

1.00
%
to
1.67
%

13.23
 %
to
14.00%
Morgan Stanley VIF Emerging Markets Debt Portfolio
60

22.19

to
12.98

953

5.39
%

1.15
%
to
1.67
%

12.26
 %
to
12.86%
Morgan Stanley VIF Emerging Markets Equity Portfolio
146

31.30

to
39.99

2,323

1.01
%

1.00
%
to
1.67
%

17.52
 %
to
18.32%
Morgan Stanley VIF U.S. Real Estate Portfolio
169

32.21

to
18.31

2,526

1.61
%

1.15
%
to
1.67
%

16.69
 %
to
17.31%
Non-Affiliated Class 3:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
134

23.16

to
24.09

3,164

%

1.15
%
to
1.60
%

29.45
 %
to
30.04%
BlackRock Global Allocation V.I. Fund
47

12.79

to
13.48

613

1.22
%

1.00
%
to
1.60
%

15.87
 %
to
16.58%
BlackRock High Yield V.I. Fund
17

12.09

to
12.27

210

5.15
%

1.15
%
to
1.55
%

13.08
 %
to
13.54%
BlackRock Total Return V.I. Fund
29

10.50

to
10.58

303

2.59
%

1.35
%
to
1.55
%

7.46
 %
to
7.67%
TOPS® Managed Risk Moderate Growth ETF Portfolio
97

11.91

to
12.24

1,153

2.12
%

1.15
%
to
1.55
%

14.36
 %
to
14.83%
Non-Affiliated Class 4:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
American Funds I.S. Bond Fund
65

10.47

to
10.62

680

2.61
%

1.15
%
to
1.55
%

7.39
 %
to
7.83%
American Funds I.S. Capital Income Builder Fund
270

11.16

to
11.45

3,032

2.77
%

1.00
%
to
1.55
%

15.80
 %
to
16.44%
American Funds I.S. Global Growth Fund
133

16.67

to
17.14

2,255

0.99
%

1.15
%
to
1.60
%

32.72
 %
to
33.33%
American Funds I.S. Growth Fund
128

19.82

to
20.37

2,567

0.61
%

1.15
%
to
1.60
%

28.35
 %
to
28.94%
American Funds I.S. Growth-Income Fund
169

17.72

to
18.21

3,013

1.49
%

1.15
%
to
1.60
%

23.84
 %
to
24.41%
American Funds I.S. New World Fund
74

12.48

to
12.79

937

0.81
%

1.15
%
to
1.55
%

26.82
 %
to
27.34%
Non-Affiliated Class A:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
12

33.58

to
35.28

431

1.08
%

1.10
%
to
1.45
%

23.41
 %
to
23.85%
Non-Affiliated Class B:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
75

29.93

to
32.13

1,678

0.75
%

1.00
%
to
1.67
%

22.79
 %
to
23.62%
Advisor Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PIMCO VIT All Asset Portfolio
110

13.53

to
12.94

1,533

2.79
%

1.15
%
to
1.67
%

9.88
 %
to
10.46%
PIMCO VIT International Bond Portfolio (US Dollar Hedged)
4

10.96

to
11.12

40

1.63
%

1.15
%
to
1.55
%

5.25
 %
to
5.68%
PIMCO VIT CommodityRealReturn® Strategy Portfolio
318

3.90

to
5.46

1,280

4.29
%

1.15
%
to
1.67
%

9.49
 %
to
10.07%
PIMCO VIT Long-Term U.S. Government Portfolio
17

11.30

to
11.65

200

1.97
%

1.15
%
to
1.60
%

11.40
 %
to
11.91%
PIMCO VIT Low Duration Portfolio
189

11.01

to
11.92

2,125

2.66
%

1.00
%
to
1.67
%

2.19
 %
to
2.88%
PIMCO VIT Real Return Portfolio
74

11.97

to
10.96

906

1.54
%

1.15
%
to
1.67
%

6.52
 %
to
7.08%
PIMCO VIT Total Return Portfolio
1,376

13.71

to
14.84

19,494

2.92
%

1.00
%
to
1.67
%

6.44
 %
to
7.17%
Investor Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Guggenheim VT Global Managed Futures Strategy Fund
27

6.17

to
6.60

168

0.96
%

1.00
%
to
1.60
%

6.41
 %
to
7.06%
Guggenheim VT Multi-Hedge Strategies Fund
40

8.49

to
9.00

345

2.28
%

1.00
%
to
1.60
%

3.33
 %
to
3.96%
Guggenheim VT Long Short Equity Fund
7

9.97

to
10.41

72

0.58
%

1.00
%
to
1.60
%

3.85
 %
to
4.48%
ETF Shares:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
iShares® Core S&P 500 ETF
300

61.04

to
65.80

18,622

2.24
%

1.75
%
to
2.75
%

27.64
 %
to
28.95%
iShares® Core S&P Mid-Cap ETF
101

52.74

to
55.15

5,399

1.70
%

1.75
%
to
2.75
%

22.63
 %
to
23.89%
iShares® Core S&P Small-Cap ETF
51

55.67

to
58.31

2,870

1.50
%

1.75
%
to
2.75
%

19.44
 %
to
20.67%
iShares® Core U.S. Aggregate Bond ETF
23

25.15

to
28.74

582

2.74
%

1.75
%
to
2.75
%

5.47
 %
to
6.56%
iShares® iBoxx $ High Yield Corporate Bond ETF
2

31.74

to
34.05

74

5.04
%

1.90
%
to
2.75
%

10.96
 %
to
11.93%
iShares® Intermediate-Term Corporate Bond ETF
26

27.40

to
29.40

716

3.55
%

1.90
%
to
2.75
%

11.44
 %
to
12.42%
iShares® International Treasury Bond ETF
104

21.93

to
23.82

2,326

0.22
%

1.75
%
to
2.75
%

0.91
 %
to
1.95%
iShares® S&P 500 Growth ETF
35

65.12

to
72.17

2,339

1.73
%

1.75
%
to
2.75
%

27.17
 %
to
28.47%
iShares® S&P 500 Value ETF
9

55.20

to
59.22

520

2.31
%

1.90
%
to
2.75
%

28.00
 %
to
29.12%
iShares® TIPS Bond ETF
6

22.69

to
24.35

127

1.83
%

1.90
%
to
2.75
%

5.37
 %
to
6.29%
Vanguard® Developed Markets Index Fund, ETF Shares
71

36.00

to
34.57

2,603

3.14
%

1.75
%
to
2.75
%

19.22
 %
to
20.45%

(a) Name Change. See Note 1.
 
31
(b) New Underlying Fund. See Note 1
 

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2019
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
ETF Shares (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vanguard® Dividend Appreciation Index Fund, ETF Shares
19

$
54.58

to
$
58.55

$
1,049

1.83
%

1.90
%
to
2.75
%

26.04
 %
to
27.14%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
8

27.78

to
29.81

222

3.24
%

1.90
%
to
2.75
%

17.42
 %
to
18.44%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
2

31.92

to
34.14

61

3.47
%

1.75
%
to
1.90
%

11.92
 %
to
12.09%
Vanguard® Large-Cap Index Fund, ETF Shares
12

60.81

to
65.24

728

1.98
%

1.90
%
to
2.75
%

27.62
 %
to
28.74%
Vanguard® Mega Cap Index Fund, ETF Shares
2

61.96

to
66.98

140

1.96
%

1.75
%
to
2.75
%

27.55
 %
to
28.86%
Vanguard® Real Estate Index Fund, ETF Shares
5

46.76

to
50.17

244

3.44
%

1.90
%
to
2.75
%

25.31
 %
to
26.41%
Vanguard® Short-Term Bond Index Fund, ETF Shares
1

22.84

to
24.42

15

2.31
%

1.90
%
to
2.75
%

2.11
 %
to
3.01%
Vanguard® Total Bond Market Index Fund, ETF Shares
686

25.15

to
28.83

17,584

2.76
%

1.75
%
to
2.75
%

5.84
 %
to
6.93%

(a) Name Change. See Note 1.
 
32
(b) New Underlying Fund. See Note 1
 

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2018
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
Affiliated:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund
186

$
13.20

to
$
16.19

$
2,460

1.95
%
 
1.00%
to
1.67%
 
(3.27)%
to
(2.60)%
Touchstone VST Aggressive ETF Fund
283

17.14

to
18.86

5,262

1.64
%
 
1.00%
to
1.67%
 
(9.39)%
to
(8.77)%
Touchstone VST Conservative ETF Fund
405

14.64

to
16.11

6,038

1.74
%
 
1.00%
to
1.67%
 
(5.63)%
to
(4.99)%
Touchstone VST Focused Fund
566

30.76

to
34.67

14,555

0.45
%
 
1.00%
to
1.67%
 
(9.52)%
to
(8.90)%
Touchstone VST Large Cap Core Equity Fund
166

21.94

to
21.61

3,186

0.57
%
 
1.00%
to
1.67%
 
(8.06)%
to
(7.43)%
Touchstone VST Moderate ETF Fund
475

17.51

to
17.86

7,336

1.89
%
 
1.00%
to
2.05%
 
(7.96)%
to
(6.97)%
Non-Affiliated Initial Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Balanced Portfolio
79

16.87

to
27.48

1,716

1.41
%
 
1.35%
to
1.35%
 
(5.52)%
to
(5.52)%
Fidelity VIP Overseas Portfolio
43

9.38

to
12.39

1,081

1.50
%
 
1.15%
to
1.55%
 
(16.14)%
to
(15.79)%
Fidelity VIP Equity-Income Portfolio
101

24.88

to
25.32

6,781

2.12
%
 
1.10%
to
1.35%
 
(9.54)%
to
(9.31)%
Fidelity VIP Growth Portfolio
32

137.25

to
137.25

4,380

0.24
%
 
1.35%
to
1.35%
 
(1.52)%
to
(1.52)%
Fidelity VIP High Income Portfolio
51

27.30

to
27.30

1,394

5.65
%
 
1.35%
to
1.35%
 
(4.60)%
to
(4.60)%
Fidelity VIP Asset Manager Portfolio
51

52.02

to
52.02

2,674

1.65
%
 
1.35%
to
1.35%
 
(6.63)%
to
(6.63)%
Fidelity VIP Contrafund® Portfolio
201

38.52

to
39.19

11,709

0.69
%
 
1.10%
to
1.35%
 
(7.65)%
to
(7.41)%
Fidelity VIP Index 500 Portfolio
114

18.03

to
18.56

4,015

1.80
%
 
1.10%
to
1.45%
 
(5.88)%
to
(5.55)%
Fidelity VIP Investment Grade Bond Portfolio
85

13.15

to
14.04

1,474

2.31
%
 
1.00%
to
1.55%
 
(2.08)%
to
(1.53)%
Fidelity VIP Government Money Market
1,084

9.61

to
9.88

10,536

1.62
%
 
1.00%
to
2.75%
 
(1.16)%
to
0.63%
Non-Affiliated Service Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Growth Portfolio
16

20.01

to
20.01

314

0.14
%
 
1.35%
to
1.35%
 
(1.63)%
to
(1.63)%
Fidelity VIP Mid Cap Portfolio
46

56.67

to
59.21

2,657

0.53
%
 
1.10%
to
1.35%
 
(15.80)%
to
(15.58)%
Non-Affiliated Service Class 2:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fidelity VIP Asset Manager Portfolio
57

16.73

to
18.88

852

1.47
%
 
1.00%
to
1.67%
 
(7.20)%
to
(6.56)%
Fidelity VIP Balanced Portfolio
443

20.15

to
22.77

7,957

1.34
%
 
1.00%
to
1.67%
 
(6.04)%
to
(5.40)%
Fidelity VIP Contrafund® Portfolio
766

28.28

to
31.47

15,616

0.43
%
 
1.00%
to
1.67%
 
(8.21)%
to
(7.58)%
Fidelity VIP Disciplined Small Cap Portfolio
84

14.07

to
15.24

1,229

0.59
%
 
1.00%
to
1.67%
 
(14.75)%
to
(14.17)%
Fidelity VIP Equity-Income Portfolio
175

20.39

to
20.79

2,746

1.86
%
 
1.00%
to
1.67%
 
(10.07)%
to
(9.46)%
Fidelity VIP Freedom 2010 Portfolio
33

13.12

to
13.63

448

1.36
%
 
1.35%
to
1.67%
 
(5.87)%
to
(5.56)%
Fidelity VIP Freedom 2015 Portfolio
30

13.69

to
14.22

407

1.35
%
 
1.15%
to
1.60%
 
(6.80)%
to
(6.38)%
Fidelity VIP Freedom 2020 Portfolio
45

13.67

to
13.87

590

1.38
%
 
1.15%
to
1.60%
 
(7.59)%
to
(7.16)%
Fidelity VIP Freedom 2025 Portfolio
112

14.31

to
14.13

1,525

1.48
%
 
1.35%
to
1.60%
 
(8.28)%
to
(8.04)%
Fidelity VIP Freedom 2030 Portfolio
40

13.38

to
14.23

544

1.12
%
 
1.15%
to
1.67%
 
(9.60)%
to
(9.12)%
Fidelity VIP Growth Portfolio
133

26.16

to
23.82

2,908

0.04
%
 
1.00%
to
1.67%
 
(2.10)%
to
(1.43)%
Fidelity VIP High Income Portfolio
49

18.40

to
23.48

786

7.35
%
 
1.00%
to
1.67%
 
(5.24)%
to
(4.60)%
Fidelity VIP Index 500 Portfolio
1,295

25.13

to
23.23

23,138

1.56
%
 
1.00%
to
1.67%
 
(6.33)%
to
(5.69)%
Fidelity VIP Investment Grade Bond Portfolio
1,071

13.40

to
17.21

13,976

2.30
%
 
1.00%
to
1.67%
 
(2.45)%
to
(1.78)%
Fidelity VIP Mid Cap Portfolio
296

32.63

to
37.46

6,108

0.39
%
 
1.00%
to
1.67%
 
(16.20)%
to
(15.63)%
Fidelity VIP Overseas Portfolio
351

18.12

to
17.41

3,983

1.31
%
 
1.00%
to
1.67%
 
(16.48)%
to
(15.91)%
Fidelity VIP Target Volatility Portfolio
37

11.40

to
11.64

423

1.57
%
 
1.15%
to
1.55%
 
(7.46)%
to
(7.08)%
Non-Affiliated Class 1:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Columbia VP – Mid Cap Value Fund
75

14.44

to
15.03

1,113

%
 
1.15%
to
1.67%
 
(14.75)%
to
(14.30)%
Franklin Growth and Income VIP Fund
64

24.70

to
25.14

1,580

2.66
%
 
1.10%
to
1.35%
 
(5.67)%
to
(5.43)%
Franklin Income VIP Fund
127

24.98

to
25.42

3,175

4.95
%
 
1.10%
to
1.35%
 
(5.39)%
to
(5.15)%
JP Morgan IT Mid Cap Value
22

29.52

to
31.15

611

0.99
%
 
1.00%
to
1.55%
 
(13.21)%
to
(12.72)%
Morgan Stanley VIF Emerging Markets Debt Portfolio
4

24.72

to
30.99

119

5.53
%
 
1.10%
to
1.55%
 
(8.39)%
to
(7.97)%
Morgan Stanley VIF U.S. Real Estate Portfolio
19

31.05

to
34.20

681

2.67
%
 
1.00%
to
1.55%
 
(9.15)%
to
(8.64)%
Non-Affiliated Class 2:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
157

11.32

to
11.65

1,781

1.34
%
 
1.00%
to
1.55%
 
(6.38)%
to
(5.85)%
Columbia VP –Small Cap Value Fund
65

22.71

to
23.90

1,492

0.17
%
 
1.15%
to
1.67%
 
(19.54)%
to
(19.11)%
Franklin Growth and Income VIP Fund
244

21.60

to
25.12

4,591

2.49
%
 
1.00%
to
1.67%
 
(6.18)%
to
(5.54)%
Franklin Income VIP Fund
883

20.27

to
25.41

13,324

4.84
%
 
1.00%
to
1.67%
 
(5.91)%
to
(5.27)%
Franklin Large Cap Growth VIP Fund
191

21.59

to
26.36

4,229

%
 
1.00%
to
1.67%
 
(3.12)%
to
(2.46)%
Franklin Mutual Shares VIP Fund
626

19.66

to
23.82

8,736

2.33
%
 
1.00%
to
1.67%
 
(10.59)%
to
(9.98)%
Franklin Small Cap Value VIP Fund
59

14.82

to
15.76

904

0.88
%
 
1.15%
to
1.67%
 
(14.34)%
to
(13.88)%
Invesco V.I. American Franchise Fund
10

23.88

to
20.35

238

%
 
1.15%
to
1.67%
 
(5.50)%
to
(5.00)%
Invesco V.I. American Value Fund
369

15.11

to
16.24

5,756

0.21
%
 
1.00%
to
1.67%
 
(14.33)%
to
(13.74)%

33

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2018
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Invesco V.I. Comstock Fund
186

$
22.57

to
$
27.46

$
2,994

1.44
%
 
1.00%
to
1.67%
 
(13.84)%
to
(13.25)%
Invesco V.I. International Growth Fund
153

10.35

to
10.72

1,607

1.80
%
 
1.15%
to
1.60%
 
(16.57)%
to
(16.19)%
Invesco V.I. Mid Cap Growth Fund
13

11.50

to
11.63

146

%
 
1.15%
to
1.55%
 
(7.34)%
to
(6.96)%
Templeton Foreign VIP Fund
349

16.91

to
20.27

3,781

2.67
%
 
1.00%
to
1.67%
 
(16.86)%
to
(16.29)%
Templeton Global Bond VIP Fund
63

9.38

to
9.59

599

%
 
1.15%
to
1.55%
 
0.35%
to
0.76%
Templeton Growth VIP Fund
82

16.98

to
20.46

1,200

2.03
%
 
1.00%
to
1.67%
 
(16.28)%
to
(15.71)%
Morgan Stanley VIF Emerging Markets Debt Portfolio
59

19.77

to
11.50

843

5.55
%
 
1.15%
to
1.67%
 
(8.60)%
to
(8.12)%
Morgan Stanley VIF Emerging Markets Equity Portfolio
145

26.64

to
33.80

2,058

0.41
%
 
1.00%
to
1.67%
 
(18.90)%
to
(18.34)%
Morgan Stanley VIF U.S. Real Estate Portfolio
169

27.60

to
11.79

2,218

2.48
%
 
1.00%
to
1.67%
 
(9.51)%
to
(8.89)%
Non-Affiliated Class 3:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
131

17.89

to
18.75

2,370

%
 
1.00%
to
1.60%
 
0.49%
to
1.10%
BlackRock Global Allocation V.I. Fund
53

11.04

to
11.57

593

0.75
%
 
1.00%
to
1.60%
 
(9.06)%
to
(8.51)%
BlackRock High Yield V.I. Fund
11

10.69

to
10.81

123

5.26
%
 
1.15%
to
1.55%
 
(4.41)%
to
(4.02)%
BlackRock Total Return V.I. Fund
17

9.78

to
9.83

163

2.46
%
 
1.35%
to
1.55%
 
(2.27)%
to
(2.27)%
TOPS® Managed Risk Moderate Growth ETF Portfolio
100

10.42

to
10.66

1,045

1.78
%
 
1.15%
to
1.55%
 
(8.82)%
to
(8.45)%
Non-Affiliated Class 4:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
American Funds I.S. Bond Fund
51

9.75

to
9.85

497

2.23
%
 
1.15%
to
1.55%
 
(2.43)%
to
(2.03)%
American Funds I.S. Capital Income Builder Fund
158

9.63

to
9.83

1,537

2.73
%
 
1.00%
to
1.55%
 
(8.69)%
to
(8.32)%
American Funds I.S. Global Growth Fund
122

12.56

to
12.86

1,552

0.53
%
 
1.15%
to
1.60%
 
(10.70)%
to
(10.29)%
American Funds I.S. Growth Fund
101

15.44

to
15.80

1,576

0.28
%
 
1.15%
to
1.60%
 
(2.10)%
to
(1.65)%
American Funds I.S. Growth-Income Fund
168

14.31

to
14.64

2,421

1.36
%
 
1.15%
to
1.60%
 
(3.58)%
to
(3.19)%
American Funds I.S. New World Fund
66

9.84

to
10.04

653

0.75
%
 
1.15%
to
1.55%
 
(15.59)%
to
(15.24)%
Non-Affiliated Class A:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
14

27.21

to
28.49

385

0.97
%
 
1.10%
to
1.45%
 
(12.52)%
to
(12.21)%
Non-Affiliated Class B:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
69

24.37

to
25.99

1,296

0.68
%
 
1.00%
to
1.67%
 
(12.91)%
to
(12.31)%
Advisor Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PIMCO VIT All Asset Portfolio
123

12.32

to
11.71

1,553

3.09
%
 
1.15%
to
1.67%
 
(7.03)%
to
(6.54)%
PIMCO VIT International Bond Portfolio (US Dollar Hedged)
2

10.41

to
10.53

18

1.31
%
 
1.15%
to
1.55%
 
0.43%
to
0.43%
PIMCO VIT CommodityRealReturn® Strategy Portfolio
345

3.56

to
4.96

1,263

1.97
%
 
1.15%
to
1.67%
 
(15.64)%
to
(15.19)%
PIMCO VIT Long-Term U.S. Government Portfolio
18

10.14

to
10.41

185

2.30
%
 
1.15%
to
1.60%
 
(4.05)%
to
(3.61)%
PIMCO VIT Low Duration Portfolio
165

10.77

to
11.58

1,807

1.81
%
 
1.00%
to
1.67%
 
(1.45)%
to
(0.77)%
PIMCO VIT Real Return Portfolio
112

11.24

to
10.23

1,282

2.37
%
 
1.15%
to
1.67%
 
(3.95)%
to
(3.44)%
PIMCO VIT Total Return Portfolio
1,476

12.88

to
13.84

19,600

2.43
%
 
1.00%
to
1.67%
 
(2.31)%
to
(1.64)%
Investor Class:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Guggenheim VT Global Managed Futures Strategy Fund
39

5.76

to
6.17

231

%
 
1.00%
to
1.67%
 
(10.55)%
to
(9.94)%
Guggenheim VT Multi-Hedge Strategies Fund
46

8.05

to
8.66

385

%
 
1.00%
to
1.67%
 
(6.67)%
to
(6.03)%
Guggenheim VT Long Short Equity Fund
8

9.27

to
9.97

81

%
 
1.00%
to
1.67%
 
(14.40)%
to
(13.81)%
ETF Shares:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
iShares® Core S&P 500 ETF
388

47.82

to
51.03

18,855

1.85
%
 
1.75%
to
2.75%
 
(7.11)%
to
(6.15)%
iShares® Core S&P Mid-Cap ETF
122

43.01

to
44.51

5,341

1.47
%
 
1.75%
to
2.75%
 
(13.63)%
to
(12.73)%
iShares® Core S&P Small-Cap ETF
59

46.61

to
48.32

2,802

1.32
%
 
1.75%
to
2.75%
 
(11.02)%
to
(10.10)%
iShares® Core U.S. Aggregate Bond ETF
26

23.84

to
26.97

620

2.72
%
 
1.75%
to
2.75%
 
(2.67)%
to
(1.66)%
iShares® iBoxx $ High Yield Corporate Bond ETF
4

28.60

to
30.42

124

5.18
%
 
1.90%
to
2.75%
 
(4.71)%
to
(3.87)%
iShares® Intermediate-Term Corporate Bond ETF
26

24.59

to
26.15

653

3.33
%
 
1.90%
to
2.75%
 
(3.48)%
to
(2.63)%
iShares® International Treasury Bond ETF
119

21.74

to
23.37

2,635

0.30
%
 
1.75%
to
2.75%
 
(5.29)%
to
(4.31)%
iShares® S&P 500 Growth ETF
41

51.20

to
56.17

2,157

1.16
%
 
1.75%
to
2.75%
 
(2.95)%
to
(1.95)%
iShares® S&P 500 Value ETF
10

43.12

to
45.86

448

2.48
%
 
1.90%
to
2.75%
 
(11.70)%
to
(10.92)%
iShares® TIPS Bond ETF
5

21.54

to
22.91

108

2.71
%
 
1.90%
to
2.75%
 
(4.15)%
to
(3.31)%

34

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2018
 
Unit
Net
Investment
 
Expense
 
Total
 
 Units
Value
Assets
Income
 
Ratio
 
Return
Subaccount
 (000s)
Range
 (000s)
Ratio (**)
 
Range (***)
 
Range (****)
ETF Shares (continued):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vanguard® Developed Markets Index Fund, ETF Shares
87

$
30.20

to
$
28.70

$
2,651

2.85
%
 
1.75%
to
2.75%
 
(17.11)%
to
(16.25)%
Vanguard® Dividend Appreciation Index Fund, ETF Shares
23

43.30

to
46.05

995

1.88
%
 
1.90%
to
2.75%
 
(4.78)%
to
(3.94)%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
11

23.66

to
21.70

260

2.52
%
 
1.75%
to
2.75%
 
(17.11)%
to
(16.25)%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
2

28.52

to
30.46

63

3.45
%
 
1.75%
to
1.90%
 
(3.61)%
to
(3.46)%
Vanguard® Large-Cap Index Fund, ETF Shares
13

47.65

to
50.67

606

1.84
%
 
1.90%
to
2.75%
 
(7.09)%
to
(6.27)%
Vanguard® Mega Cap Index Fund, ETF Shares
2

48.58

to
51.98

123

1.93
%
 
1.75%
to
2.75%
 
(6.12)%
to
(5.15)%
Vanguard® Real Estate Index Fund, ETF Shares
7

37.32

to
39.69

252

4.38
%
 
1.90%
to
2.75%
 
(8.62)%
to
(7.82)%
Vanguard® Short-Term Bond Index Fund, ETF Shares
1

22.37

to
23.71

18

1.94
%
 
1.90%
to
2.75%
 
(1.45)%
to
(0.59)%
Vanguard® Total Bond Market Index Fund, ETF Shares
821

23.76

to
26.96

19,849

2.78
%
 
1.75%
to
2.75%
 
(2.87)%
to
(1.87)%
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 


35

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2017
 
Unit
 
 
Investment
Expense
Total
 
 Units
Value
 
 Net Assets
Income
Ratio
Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Affiliated:
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund
242

 $13.64 to $16.63

 
$
3,363

2.37
%
1.00% to 1.67%

1.81% to 2.51%

Touchstone VST Aggressive ETF Fund
325

 22.46 to 20.68

 
6,610

1.68
%
 1.00% to 2.15%

14.78% to 16.13%

Touchstone VST Conservative ETF Fund
454

 14.98 to 16.96

 
7,158

2.04
%
 1.00% to 2.15%

7.70% to 8.96%

Touchstone VST Focused Fund
640

 34.00 to 38.06

 
18,136

0.51
%
1.00% to 1.67%

11.75% to 12.51%

Touchstone VST Large Cap Core Equity Fund
187

 23.86 to 23.35

 
3,905

0.67
%
1.00% to 1.67%

19.30% to 20.11%

Touchstone VST Moderate ETF Fund
522

 18.85 to 19.20

 
8,797

1.94
%
 1.00% to 2.15%

11.22% to 12.52%

Non-Affiliated Initial Class:
 
 
 
 
 
 
 
Fidelity VIP Balanced Portfolio
90

 17.86 to 29.08

 
2,068

1.42
%
1.35
%
14.86
%
Fidelity VIP Overseas Portfolio
50

 11.19 to 11.87

 
1,438

1.40
%
 1.00% to 1.55%

28.27% to 28.99%

Fidelity VIP Equity-Income Portfolio
138

 27.50 to 27.92

 
10,060

1.68
%
 1.10% to 1.35%

11.38% to 11.66%

Fidelity VIP Growth Portfolio
36

139.37

 
4,980

0.22
%
1.35
%
33.32
%
Fidelity VIP High Income Portfolio
56

28.61

 
1,604

4.56
%
1.35
%
5.50
%
Fidelity VIP Asset Manager Portfolio
59

55.72

 
3,277

1.86
%
1.35
%
12.57
%
Fidelity VIP Contrafund® Portfolio
224

 41.71 to 42.33

 
13,970

0.98
%
 1.10% to 1.35%

20.24% to 20.54%

Fidelity VIP Index 500 Portfolio
129

 19.15 to 19.65

 
4,803

1.77
%
 1.10% to 1.45%

19.96% to 20.38%

Fidelity VIP Investment Grade Bond Portfolio
103

 13.43 to 14.26

 
2,012

2.31
%
 1.00% to 1.55%

2.61% to 3.18%

Fidelity VIP Government Money Market
1,139

 9.72 to 9.82

 
11,055

0.67
%
 1.00% to 2.75%

(2.08)% to (0.33)%

Non-Affiliated Service Class:
 
 
 
 
 
 
 
Fidelity VIP Growth Portfolio
18

20.34

 
359

0.13
%
1.35
%
33.19
%
Fidelity VIP Mid Cap Portfolio
53

 67.30 to 70.14

 
3,587

0.61
%
 1.10% to 1.35%

19.08% to 19.38%

Non-Affiliated Service Class 2:
 
 
 
 
 
 
 
Fidelity VIP Asset Manager Portfolio
63

 18.03 to 20.20


1,005

1.55
%
1.00% to 1.67%

11.85% to 12.61%

Fidelity VIP Balanced Portfolio
410

 21.45 to 24.08


7,973

1.30
%
1.00% to 1.67%

14.18% to 14.96%

Fidelity VIP Contrafund® Portfolio
848

 30.81 to 34.05


18,909

0.77
%
1.00% to 1.67%

19.56% to 20.38%

Fidelity VIP Disciplined Small Cap Portfolio
118

 16.51 to 17.75


2,011

0.55
%
1.00% to 1.67%

5.01% to 5.73%

Fidelity VIP Equity-Income Portfolio
288

 22.67 to 22.96


5,449

1.43
%
1.00% to 1.67%

10.78% to 11.53%

Fidelity VIP Freedom 2010 Portfolio
37

 13.94 to 14.43


528

0.98
%
 1.35% to 1.67%

10.92% to 11.28%

Fidelity VIP Freedom 2015 Portfolio
32

 14.17 to 15.19


456

1.04
%
 1.15% to 1.67%

12.89% to 13.48%

Fidelity VIP Freedom 2020 Portfolio
44

 14.79 to 14.94


620

1.26
%
 1.15% to 1.60%

14.41% to 14.93%

Fidelity VIP Freedom 2025 Portfolio
46

 15.60 to 15.37


686

1.24
%
 1.35% to 1.60%

15.69% to 15.99%

Fidelity VIP Freedom 2030 Portfolio
43

 14.80 to 15.65


634

0.67
%
 1.15% to 1.67%

18.69% to 19.31%

Fidelity VIP Growth Portfolio
183

 26.72 to 24.16


4,162

0.09
%
1.00% to 1.67%

32.57% to 33.47%

Fidelity VIP High Income Portfolio
70

 19.42 to 24.61


1,264

1.48
%
1.00% to 1.67%

5.13% to 5.85%

Fidelity VIP Index 500 Portfolio
1,347

 26.83 to 24.64


25,759

1.61
%
1.00% to 1.67%

19.39% to 20.20%

Fidelity VIP Investment Grade Bond Portfolio
1,061

 13.74 to 17.52


14,157

2.27
%
1.00% to 1.67%

2.26% to 2.96%

Fidelity VIP Mid Cap Portfolio
348

 38.94 to 44.40


8,978

0.50
%
1.00% to 1.67%

18.53% to 19.34%

Fidelity VIP Overseas Portfolio
375

 21.69 to 20.70


5,131

1.27
%
1.00% to 1.67%

27.83% to 28.69%

Fidelity VIP Target Volatility Portfolio
36

 12.32 to 12.53


440

1.14
%
 1.15% to 1.55%

14.50% to 14.96%

Non-Affiliated Class 1:
 
 
 
 
 
 
 
Columbia VP – Mid Cap Value Fund
77

 16.94 to 17.54


1,330

%
 1.15% to 1.67%

11.65% to 12.24%

Franklin Growth and Income VIP Fund
71

 26.19 to 26.58


1,847

5.98
%
 1.10% to 1.35%

14.59% to 14.87%

Franklin Income VIP Fund
142

 26.41 to 26.80


3,757

4.30
%
 1.10% to 1.35%

8.46% to 8.74%

JP Morgan IT Mid Cap Value
27

 34.01 to 35.69


856

0.79
%
 1.00% to 1.55%

12.01% to 12.63%

Morgan Stanley VIF Emerging Markets Debt Portfolio
4

 26.98 to 33.67


140

5.48
%
 1.10% to 1.55%

8.02% to 8.51%

Morgan Stanley VIF U.S. Real Estate Portfolio
23

 34.18 to 37.43


917

1.58
%
 1.00% to 1.55%

1.52% to 2.08%

Non-Affiliated Class 2:
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
164

 12.07 to 12.37


1,988

0.78
%
 1.00% to 1.60%

12.97% to 13.66%

Columbia VP –Small Cap Value Fund
59

 28.23 to 29.55


1,684

0.32
%
 1.15% to 1.67%

12.09% to 12.68%

Franklin Growth and Income VIP Fund
289

 23.03 to 26.59


5,848

5.81
%
1.00% to 1.67%

13.93% to 14.70%

Franklin Income VIP Fund
901

 21.54 to 26.82


14,667

4.12
%
1.00% to 1.67%

7.85% to 8.58%

Franklin Large Cap Growth VIP Fund
110

 22.29 to 27.02


2,309

0.62
%
1.00% to 1.67%

25.98% to 26.83%

Franklin Mutual Shares VIP Fund
660

 21.99 to 26.46


10,475

2.25
%
1.00% to 1.67%

6.54% to 7.27%

Franklin Small Cap Value VIP Fund
67

 17.30 to 18.31


1,209

0.51
%
 1.15% to 1.67%

8.81% to 9.38%

Invesco V.I. American Franchise Fund
10

 25.27 to 21.42


251

%
 1.15% to 1.67%

24.91% to 25.57%

Invesco V.I. American Value Fund
120

 17.63 to 18.83


2,169

0.60
%
1.00% to 1.67%

7.86% to 8.59%

Invesco V.I. Comstock Fund
187

 26.20 to 31.66


3,500

1.99
%
1.00% to 1.67%

15.62% to 16.40%


36

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2017
 
Unit
 
 
Investment
Expense
Total
 
 Units
Value
 
 Net Assets
Income
Ratio
Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
Invesco V.I. International Growth Fund
143

 $12.40 to $12.79


$
1,795

1.27
%
 1.15% to 1.60%

20.77% to 21.32%

Invesco V.I. Mid Cap Growth Fund
5

 12.41 to 12.49


61

%
 1.15% to 1.55%

20.26% to 20.74%

Templeton Foreign VIP Fund
331

 20.34 to 24.22


4,473

2.55
%
1.00% to 1.67%

14.75% to 15.53%

Templeton Global Bond VIP Fund
68

 9.34 to 9.52


645

%
 1.15% to 1.55%

0.35% to 0.76%

Templeton Growth VIP Fund
105

 20.28 to 24.27


1,863

1.63
%
1.00% to 1.67%

16.53% to 17.32%

Morgan Stanley VIF Emerging Markets Debt Portfolio
56

 21.63 to 15.86


899

5.60
%
1.00% to 1.67%

7.76% to 8.49%

Morgan Stanley VIF Emerging Markets Equity Portfolio
122

 32.84 to 41.39


2,026

0.66
%
1.00% to 1.67%

32.82% to 33.72%

Morgan Stanley VIF U.S. Real Estate Portfolio
179

 30.50 to 12.94


2,635

1.29
%
1.00% to 1.67%

1.16% to 1.84%

Non-Affiliated Class 3:
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
123

 17.80 to 18.54


2,215

%
1.00% to 1.60%

30.83% to 31.62%

BlackRock Global Allocation V.I. Fund
67

 12.14 to 12.64


817

1.29
%
1.00% to 1.60%

11.90% to 12.58%

BlackRock High Yield V.I. Fund
5

 11.19 to 11.26


53

4.90
%
 1.15% to 1.55%

5.41% to 5.84%

BlackRock Total Return V.I. Fund
20

 10.00 to 10.02


198

2.22
%
 1.45% to 1.55%

1.61% to 1.71%

TOPS® Managed Risk Moderate Growth ETF Portfolio
82

 11.43 to 11.64


935

1.58
%
 1.15% to 1.55%

12.08% to 12.53%

Non-Affiliated Class 4:
 
 
 
 
 
 
 
American Funds I.S. Bond Fund
51

 9.99 to 10.06


510

2.35
%
 1.15% to 1.55%

1.70% to 2.11%

American Funds I.S. Capital Income Builder Fund
146

 10.55 to 10.67


1,551

2.62
%
 1.15% to 1.55%

10.91% to 11.36%

American Funds I.S. Global Growth Fund
102

 14.07 to 14.33


1,460

0.63
%
 1.15% to 1.60%

29.03% to 29.61%

American Funds I.S. Growth Fund
80

 15.77 to 16.06


1,272

0.48
%
 1.15% to 1.60%

25.95% to 26.52%

American Funds I.S. Growth-Income Fund
134

 14.88 to 15.12


2,006

1.40
%
 1.15% to 1.55%

20.19% to 20.68%

American Funds I.S. New World Fund
45

 11.66 to 11.85


527

0.84
%
 1.15% to 1.55%

27.07% to 27.58%

Non-Affiliated Class A:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
17

 31.10 to 32.45


557

0.96
%
 1.10% to 1.45%

12.68% to 13.08%

Non-Affiliated Class B:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
67

 27.99 to 29.64


1,463

0.71
%
1.00% to 1.67%

12.14% to 12.90%

Advisor Class:
 
 
 
 
 
 
 
PIMCO VIT All Asset Portfolio
118

 13.25 to 12.53


1,600

4.46
%
 1.15% to 1.67%

11.49% to 12.08%

PIMCO VIT International Bond Portfolio (US Dollar Hedged)
*-

10.37


4

28.25
%
1.55
%
1.08
%
PIMCO VIT CommodityRealReturn® Strategy Portfolio
400

 4.22 to 5.85


1,730

11.07
%
 1.15% to 1.67%

0.35% to 0.88%

PIMCO VIT Long-Term U.S. Government Portfolio
19

 10.57 to 10.80


207

2.08
%
 1.15% to 1.60%

7.11% to 7.60%

PIMCO VIT Low Duration Portfolio
166

 10.93 to 11.67


1,840

1.25
%
1.00% to 1.67%

(0.44)% to 0.24%

PIMCO VIT Real Return Portfolio
123

 11.70 to 10.60


1,462

2.27
%
 1.15% to 1.67%

1.83% to 2.36%

PIMCO VIT Total Return Portfolio
1,613

 13.18 to 14.08


21,874

1.92
%
1.00% to 1.67%

3.07% to 3.77%

Investor Class:
 
 
 
 
 
 
 
Guggenheim VT Global Managed Futures Strategy Fund
45

 6.44 to 6.85


292

1.42
%
1.00% to 1.67%

6.90% to 7.63%

Guggenheim VT Multi-Hedge Strategies Fund
60

 8.63 to 9.21


543

%
1.00% to 1.67%

1.95% to 2.64%

Guggenheim VT Long Short Equity Fund
9

 10.83 to 11.56


104

0.37
%
1.00% to 1.67%

12.94% to 13.71%

ETF Shares:
 
 
 
 
 
 
 
iShares® Core S&P 500 ETF
451

 51.48 to 54.37


23,528

1.88
%
 1.75% to 2.75%

18.42% to 19.63%

iShares® Core S&P Mid-Cap ETF
134

 49.80 to 51.01


6,734

1.28
%
 1.75% to 2.75%

13.07% to 14.23%

iShares® Core S&P Small-Cap ETF
67

 52.38 to 53.75


3,551

1.28
%
 1.75% to 2.75%

10.07% to 11.19%

iShares® Core U.S. Aggregate Bond ETF
27

 24.49 to 27.43


671

2.32
%
 1.75% to 2.75%

0.71% to 1.74%

iShares® iBoxx $ High Yield Corporate Bond ETF
8

 30.02 to 32.38


249

5.05
%
 1.75% to 2.75%

3.17% to 4.23%

iShares® Intermediate-Term Corporate Bond ETF
29

 25.47 to 26.86


751

2.48
%
 1.90% to 2.75%

0.70% to 1.57%

iShares® International Treasury Bond ETF
129

 22.95 to 24.42


2,992

0.20
%
 1.75% to 2.75%

8.42% to 9.53%

iShares® S&P 500 Growth ETF
47

 52.76 to 57.29


2,538

1.43
%
 1.75% to 2.75%

23.74% to 25.00%

iShares® S&P 500 Value ETF
10

 48.84 to 51.49


480

2.17
%
 1.90% to 2.75%

12.11% to 13.08%

iShares® TIPS Bond ETF
5

 22.47 to 23.69


124

2.13
%
 1.90% to 2.75%

0.10% to 0.97%

Vanguard® Developed Markets Index Fund, ETF Shares
88

 36.43 to 34.27


3,214

2.91
%
 1.75% to 2.75%

22.94% to 24.20%

Vanguard® Dividend Appreciation Index Fund, ETF Shares
31

 45.47 to 47.94


1,420

1.99
%
 1.90% to 2.75%

18.88% to 19.92%

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
14

 28.54 to 25.91


392

2.41
%
 1.75% to 2.75%

27.87% to 29.18%

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
4

 29.79 to 31.55


106

3.21
%
 1.75% to 2.55%

2.63% to 3.47%

Vanguard® Large-Cap Index Fund, ETF Shares
15

 51.28 to 54.06


755

1.89
%
 1.90% to 2.75%

18.69% to 19.73%

Vanguard® Mega Cap Index Fund, ETF Shares
2

 51.74 to 54.80


129

1.94
%
 1.75% to 2.75%

19.24% to 20.47%

Vanguard® Real Estate Index Fund, ETF Shares
7

 40.84 to 43.05


306

4.15
%
 1.90% to 2.75%

2.01% to 2.90%


37

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2017
 
Unit
 
 
Investment
Expense
Total
 
 Units
Value
 
 Net Assets
Income
Ratio
Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
ETF Shares (continued):
 
 
 
 
 
 
 
Vanguard® Short-Term Bond Index Fund, ETF Shares
3

 $22.70 to $23.85


$
66

1.63
%
 1.90% to 2.75%

(1.57)% to (0.71)%

Vanguard® Total Bond Market Index Fund, ETF Shares
905

 24.46 to 27.47


22,485

2.54
%
 1.75% to 2.75%

0.73% to 1.76%

* - Less than 500.

38

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2016
 
 
 
 
Investment
 
 
 
 Units
 Unit Value
 
 Net Assets
Income
Expense Ratio
Total Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Affiliated:
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund
280

 $13.40 to $16.22


$
3,834

1.95
%
 1.00% to 1.67%

4.21% to 4.92%

Touchstone VST Aggressive ETF Fund
383

 19.57 to 17.80


6,731

1.51
%
 1.00% to 2.15%

5.64% to 6.88%

Touchstone VST Conservative ETF Fund
532

 13.91 to 15.56


7,728

1.42
%
 1.00% to 2.15%

3.31% to 4.53%

Touchstone VST Focused Fund
735

 30.43 to 33.83


18,604

%
 1.00% to 1.67%

11.22% to 11.98%

Touchstone VST Large Cap Core Equity Fund
209

 20.00 to 19.44


3,650

0.81
%
 1.00% to 1.67%

7.02% to 7.75%

Touchstone VST Moderate ETF Fund
630

 16.95 to 17.06


9,571

1.54
%
 1.00% to 2.15%

4.56% to 5.78%

Non-Affiliated Initial Class:
 
 
 
 
 
 
 
Fidelity VIP Balanced Portfolio
104

 15.55 to 25.32


2,072

1.29
%
1.35
%
5.82
 %
Fidelity VIP Overseas Portfolio
53

 8.62 to 9.20


1,218

1.31
%
 1.00% to 1.67%

(6.65)% to (6.01)%

Fidelity VIP Equity-Income Portfolio
142

 24.70 to 25.00


9,839

2.30
%
 1.10% to 1.35%

16.43% to 16.72%

Fidelity VIP Growth Portfolio
39

104.54


4,048

0.04
%
1.35
%
(0.56
)%
Fidelity VIP High Income Portfolio
72

27.12


1,949

5.34
%
1.35
%
13.06
 %
Fidelity VIP Asset Manager Portfolio
63

49.50


3,137

1.46
%
1.35
%
1.68
 %
Fidelity VIP Contrafund® Portfolio
251

 34.69 to 35.12


12,933

0.79
%
 1.10% to 1.35%

6.55% to 6.82%

Fidelity VIP Index 500 Portfolio
150

 15.97 to 16.33


4,467

1.36
%
 1.10% to 1.45%

10.24% to 10.63%

Fidelity VIP Investment Grade Bond Portfolio
121

 13.09 to 13.82


2,194

2.21
%
 1.00% to 1.55%

3.12% to 3.69%

Fidelity VIP Government Money Market
823

 9.74 to 9.85


8,041

0.19
%
 1.00% to 1.67%

(1.47)% to (0.80)%

Non-Affiliated Service Class:
 
 
 
 
 
 
 
Fidelity VIP Growth Portfolio
21

15.27


324

%
1.35
%
(0.64
)%
Fidelity VIP Mid Cap Portfolio
59

 56.52 to 58.75


3,366

0.41
%
 1.10% to 1.35%

10.60% to 10.88%

Non-Affiliated Service Class 2:
 
 
 
 
 
 
 
Fidelity VIP Asset Manager Portfolio
70

 16.12 to 17.94


1,005

1.28
%
 1.00% to 1.67%

1.12% to 1.81%

Fidelity VIP Balanced Portfolio
363

 18.78 to 20.94


6,178

1.25
%
 1.00% to 1.67%

5.19% to 5.91%

Fidelity VIP Contrafund® Portfolio
966

 25.77 to 25.91


18,020

0.59
%
 0.60% to 1.67%

5.93% to 7.08%

Fidelity VIP Disciplined Small Cap Portfolio
65

 15.72 to 16.79


1,054

0.62
%
 1.00% to 1.67%

20.27% to 21.09%

Fidelity VIP Equity-Income Portfolio
339

 20.47 to 20.58


5,800

2.17
%
 1.00% to 1.67%

15.75% to 16.53%

Fidelity VIP Freedom 2010 Portfolio
56

 12.94 to 13.23


711

1.03
%
 1.15% to 1.60%

3.55% to 4.02%

Fidelity VIP Freedom 2015 Portfolio
51

 12.55 to 13.39


643

1.05
%
 1.15% to 1.67%

3.82% to 4.36%

Fidelity VIP Freedom 2020 Portfolio
46

 12.93 to 13.00


576

1.47
%
 1.15% to 1.60%

4.11% to 4.59%

Fidelity VIP Freedom 2025 Portfolio
61

 13.48 to 13.12


784

1.63
%
 1.45% to 1.60%

4.29% to 4.45%

Fidelity VIP Freedom 2030 Portfolio
98

 12.47 to 13.12


1,224

1.24
%
 1.15% to 1.67%

4.60% to 5.15%

Fidelity VIP Growth Portfolio
238

 20.15 to 18.10


4,080

%
 1.00% to 1.67%

(1.13)% to (0.45)%

Fidelity VIP High Income Portfolio
462

 18.47 to 23.25


8,364

5.85
%
 1.00% to 1.67%

12.26% to 13.03%

Fidelity VIP Index 500 Portfolio
1,373

 22.47 to 20.50


22,106

1.49
%
 1.00% to 1.67%

9.72% to 10.47%

Fidelity VIP Investment Grade Bond Portfolio
1,002

 13.44 to 17.02


13,063

2.21
%
 1.00% to 1.67%

2.73% to 3.43%

Fidelity VIP Mid Cap Portfolio
340

 32.85 to 37.20


7,257

0.30
%
 1.00% to 1.67%

10.06% to 10.80%

Fidelity VIP Overseas Portfolio
344

 16.97 to 16.09


3,643

1.24
%
 1.00% to 1.67%

(6.85)% to (6.21)%

Fidelity VIP Target Volatility Portfolio
35

 10.76 to 10.90


381

1.15
%
 1.15% to 1.55%

3.43% to 3.85%

Non-Affiliated Class 1:
 
 
 
 
 
 
 
Columbia VP – Mid Cap Value Fund
80

 15.17 to 15.76


1,226

%
 1.00% to 1.67%

12.24% to 13.01%

Franklin Growth and Income VIP Fund
82

 22.86 to 23.14


1,877

2.83
%
 1.10% to 1.35%

10.35% to 10.63%

Franklin Income VIP Fund
173

 24.35 to 24.65


4,217

5.05
%
 1.10% to 1.35%

12.79% to 13.08%

JP Morgan IT Mid Cap Value
35

 30.36 to 31.69


980

0.91
%
 1.00% to 1.55%

12.92% to 13.55%

Morgan Stanley VIF Emerging Markets Debt Portfolio
5

 24.98 to 31.03


140

5.94
%
 1.10% to 1.55%

8.84% to 9.34%

Morgan Stanley VIF U.S. Real Estate Portfolio
30

 33.67 to 36.67


1,170

1.35
%
 1.00% to 1.55%

5.16% to 5.75%

Non-Affiliated Class 2:
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
168

 10.68 to 10.88


1,804

1.37
%
 1.00% to 1.60%

5.56% to 6.20%

Columbia VP – Small Cap Value Fund
49

 25.19 to 26.23


1,259

0.39
%
 1.15% to 1.67%

30.53% to 31.22%

Franklin Growth and Income VIP Fund
343

 20.21 to 23.18


6,054

2.59
%
 1.00% to 1.67%

9.76% to 10.51%

Franklin Income VIP Fund
925

 19.98 to 24.70


14,189

4.95
%
 1.00% to 1.67%

12.12% to 12.88%

Franklin Large Cap Growth VIP Fund
134

 17.69 to 21.31


2,190

%
 1.00% to 1.67%

(3.43)% to (2.77)%

Franklin Mutual Shares VIP Fund
676

 20.64 to 21.10


10,106

2.00
%
 0.60% to 1.67%

14.12% to 15.36%

Franklin Small Cap Value VIP Fund
77

 15.90 to 19.82


1,280

0.80
%
 1.15% to 1.67%

28.02% to 28.69%

Invesco V.I. American Franchise Fund
14

 20.23 to 17.06


284

%
 1.15% to 1.67%

0.31% to 0.84%

Invesco V.I. American Value Fund
113

 16.35 to 17.34


1,881

0.12
%
 1.00% to 1.67%

13.30% to 14.07%

 
 
 
 
 
 
 
 

39

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2016
 
 
 
 
Investment
 
 
 
 Units
 Unit Value
 
 Net Assets
Income
Expense Ratio
Total Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
Invesco V.I. Comstock Fund
190

 $22.66 to $27.19


$
3,086

1.34
%
 1.00% to 1.67%

15.04% to 15.82%

Invesco V.I. International Growth Fund
127

 10.42 to 10.54


1,316

1.18
%
 0.80% to 1.67%

(2.04)% to (1.84)%

Invesco V.I. Mid Cap Growth Fund (April 29. 2016)
3

10.32


34

%
1.55
%
3.20
 %
Templeton Foreign VIP Fund
337

 17.73 to 20.96


4,039

1.94
%
 1.00% to 1.67%

5.39% to 6.10%

Templeton Global Bond VIP Fund
73

 9.35 to 9.45


683

%
 1.15% to 1.55%

1.45% to 1.76%

Templeton Growth VIP Fund
135

 17.40 to 16.98


1,979

2.04
%
 0.60% to 1.67%

7.79% to 8.96%

Morgan Stanley VIF Emerging Markets Debt Portfolio
72

 20.07 to 14.62


1,064

5.53
%
 1.00% to 1.67%

8.74% to 9.48%

Morgan Stanley VIF Emerging Markets Equity Portfolio
164

 24.73 to 30.96


2,230

0.45
%
 1.00% to 1.67%

4.84% to 5.56%

Morgan Stanley VIF U.S. Real Estate Portfolio
183

 30.15 to 12.70


2,708

1.06
%
 1.00% to 1.67%

4.77% to 5.48%

Non-Affiliated Class 3:
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
120

 13.61 to 14.09


1,648

%
 1.00% to 1.60%

(1.73)% to (1.13)%

BlackRock Global Allocation V.I. Fund
69

 10.85 to 11.23


757

1.01
%
 1.00% to 1.60%

2.15% to 2.77%

BlackRock High Yield V.I. Fund (April 29, 2016)
3

10.61


33

5.18
%
1.55
%
6.12
 %
BlackRock Total Return V.I. Fund (April 29, 2016)
19

9.84


183

1.84
%
1.55
%
(1.55
)%
TOPS® Managed Risk Moderate Growth ETF Portfolio
83

 10.19 to 10.35


843

2.17
%
 1.35% to 1.45%

4.50% to 4.92%

Non-Affiliated Class 4:
 
 
 
 
 
 
 
American Funds I.S. Bond Fund (April 29, 2016)
20

 9.82 to 9.85


199

3.40
%
 1.15% to 1.55%

(1.79)% to (1.52)%

American Funds I.S. Capital Income Builder Fund
83

 9.51 to 9.58


796

3.20
%
 1.15% to 1.55%

2.18% to 2.59%

American Funds I.S. Global Growth Fund
87

 10.90 to 11.06


958

0.68
%
 1.15% to 1.60%

(1.24)% to (0.78)%

American Funds I.S. Growth Fund
62

 12.54 to 12.52


775

1.07
%
 1.15% to 1.55%

7.53% to 7.47%

American Funds I.S. Growth-Income Fund
118

 12.38 to 12.53


1,465

1.32
%
 1.15% to 1.55%

9.53% to 9.98%

American Funds I.S. New World Fund
41

 9.17 to 9.29


376

0.58
%
 1.15% to 1.55%

3.42% to 3.84%

Non-Affiliated Class A:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
19

 27.60 to 28.70


525

1.09
%
 1.10% to 1.45%

19.27% to 19.70%

Non-Affiliated Class B:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
68

 24.96 to 26.25


1,332

0.82
%
 1.00% to 1.67%

18.69% to 19.50%

Advisor Class:
 
 
 
 
 
 
 
PIMCO VIT All Asset Portfolio
130

 11.88 to 12.60


1,582

2.43
%
 1.00% to 1.67%

11.02% to 11.78%

PIMCO VIT CommodityRealReturn® Strategy Portfolio
405

 4.21 to 5.79


1,741

1.01
%
 1.15% to 1.67%

12.96% to 13.55%

PIMCO VIT Long-Term U.S. Government Portfolio
18

 9.87 to 10.04


179

1.88
%
 1.15% to 1.67%

(1.03)% to (0.58)%

PIMCO VIT Low Duration Portfolio
196

 10.98 to 11.64


2,186

1.44
%
 1.00% to 1.67%

(0.39)% to 0.29%

PIMCO VIT Real Return Portfolio
144

 11.49 to 12.19


1,689

2.18
%
 1.00% to 1.67%

3.34% to 4.04%

PIMCO VIT Total Return Portfolio
1,679

 12.79 to 13.56


22,051

1.98
%
 1.00% to 1.67%

0.86% to 1.55%

Investor Class:
 
 
 
 
 
 
 
Guggenheim VT Global Managed Futures Strategy Fund
50

 6.02 to 6.36


306

3.68
%
 1.00% to 1.67%

(16.19)% to (15.62)%

Guggenheim VT Multi-Hedge Strategies Fund
64

 8.46 to 8.97


560

0.10
%
 1.00% to 1.67%

(2.14)% to (1.48)%

Guggenheim VT Long Short Equity Fund
17

 9.59 to 10.17


175

%
 1.00% to 1.67%

(1.02)% to (0.35)%

ETF Shares:
 
 
 
 
 
 
 
iShares® Core S&P 500 ETF
517

 43.47 to 45.45


22,723

2.23
%
 1.75% to 2.75%

9.07% to 10.19%

iShares® Core S&P Mid-Cap ETF
149

 44.04 to 44.66


6,627

1.76
%
 1.75% to 2.75%

17.36% to 18.57%

iShares® Core S&P Small-Cap ETF
75

 47.59 to 48.34


3,593

1.41
%
 1.75% to 2.75%

23.13% to 24.39%

iShares® Core U.S. Aggregate Bond ETF
24

 24.32 to 26.96


586

2.34
%
 1.75% to 2.75%

(0.40)% to 0.62%

iShares® iBoxx $ High Yield Corporate Bond ETF
10

 29.09 to 31.06


301

5.43
%
 1.75% to 2.75%

10.29% to 11.42%

iShares® Intermediate-Term Corporate Bond ETF
32

 25.30 to 26.44


821

2.44
%
 1.90% to 2.75%

0.47% to 1.35%

iShares® International Treasury Bond ETF
129

 21.17 to 22.30


2,764

0.66
%
 1.75% to 2.75%

(1.92)% to (0.91)%

iShares® S&P 500 Growth ETF
50

 42.64 to 45.83


2,162

1.58
%
 1.75% to 2.75%

3.88% to 4.95%

iShares® S&P 500 Value ETF
13

 43.56 to 45.53


582

2.47
%
 1.90% to 2.75%

14.09% to 15.08%

iShares® TIPS Bond ETF
5

 22.45 to 23.46


109

1.53
%
 1.90% to 2.75%

1.80% to 2.69%

Vanguard® Developed Markets Index Fund, ETF Shares
103

 29.63 to 27.59


3,057

3.10
%
 1.75% to 2.75%

(0.17)% to 0.85%

Vanguard® Dividend Appreciation Index Fund, ETF Shares
              39

 38.25 to 41.43


1,500

2.23
%
 1.75% to 2.75%

8.91% to 10.03%

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
18

 22.32 to 20.06


387

2.55
%
 1.75% to 2.75%

9.10% to 10.22%

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
4

 27.40 to 30.49


118

3.24
%
 1.75% to 2.75%

2.36% to 3.41%

Vanguard® Large-Cap Index Fund, ETF Shares
16

 43.20 to 44.88


700

2.11
%
 1.75% to 2.75%

8.70% to 9.81%

Vanguard® Mega Cap Index Fund, ETF Shares
3

 43.39 to 45.49


126

2.27
%
 1.75% to 2.75%

8.84% to 9.95%

Vanguard® Real Estate Index Fund, ETF Shares
9

 40.03 to 41.84


378

4.86
%
 1.90% to 2.75%

5.64% to 6.56%


40

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2016
 
 
 
 
Investment
 
 
 
 Units
 Unit Value
 
 Net Assets
Income
Expense Ratio
Total Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
ETF Shares:
 
 
 
 
 
 
 
Vanguard® Short-Term Bond Index Fund, ETF Shares
4

 $23.06 to $24.02


$
98

1.46
%
 1.90% to 2.75%

(1.45)% to (0.59)%

Vanguard® Total Bond Market Index Fund, ETF Shares
882

 24.28 to 27.00


21,719

2.41
%
 1.75% to 2.75%

(0.30)% to 0.73%


41

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2015
 
 
 
 
Investment
 
 
 
 Units
 Unit Value
 
 Net Assets
Income
Expense Ratio
Total Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Affiliated:
 
 
 
 
 
 
 
Touchstone VST Active Bond Fund
317

 $12.86 to $15.46


$
4,188

3.21
%
 1.00% to 1.67%

(2.92)% to (2.26)%

Touchstone VST Aggressive ETF Fund
426

 18.53 to 16.66


7,073

1.56
%
 1.00% to 2.15%

(2.25)% to (1.10)%

Touchstone VST Conservative ETF Fund
634

 13.46 to 14.89


8,846

1.40
%
 1.00% to 2.15%

(2.38)% to (1.24)%

Touchstone VST Focused Fund
1,042

 27.36 to 30.21


24,687

%
 1.00% to 1.67%

0.27% to 0.95%

Touchstone VST Large Cap Core Equity Fund
228

 18.69 to 18.04


3,758

1.55
%
 1.00% to 1.67%

(5.61)% to (4.97)%

Touchstone VST Moderate ETF Fund
785

 16.21 to 16.13


11,451

1.78
%
 1.00% to 2.15%

(2.33)% to (1.18)%

Non-Affiliated Initial Class:
 
 
 
 
 
 
 
Fidelity VIP Balanced Portfolio
119

 14.69 to 23.93


2,226

1.45
%
1.35
%
(0.77
)%
Fidelity VIP Overseas Portfolio
73

 9.23 to 9.79


1,712

1.29
%
 1.00% to 1.67%

1.90% to 2.59%

Fidelity VIP Equity-Income Portfolio
146

 21.21 to 21.42


8,281

3.04
%
 1.10% to 1.35%

(5.26)% to (5.02)%

Fidelity VIP Growth Portfolio
42

105.13


4,400

0.25
%
1.35
%
5.73
 %
Fidelity VIP High Income Portfolio
65

23.99


1,553

6.12
%
1.35
%
(4.93
)%
Fidelity VIP Asset Manager Portfolio
69

48.68


3,373

1.56
%
1.35
%
(1.21
)%
Fidelity VIP Contrafund® Portfolio
292

 32.55 to 32.87


14,233

0.99
%
 1.10% to 1.35%

(0.69)% to (0.44)%

Fidelity VIP Index 500 Portfolio
195

 14.49 to 14.76


5,153

1.86
%
 1.10% to 1.45%

(0.13)% to 0.22%

Fidelity VIP Investment Grade Bond Portfolio
150

 12.70 to 13.33


2,543

2.25
%
 1.00% to 1.55%

(2.13)% to (1.59)%

Fidelity VIP Government Money Market
1,427

 9.89 to 9.93


14,126

0.03
%
 1.00% to 1.67%

(1.13)% to (0.67)%

Non-Affiliated Service Class:
 
 
 
 
 
 
 
Fidelity VIP Growth Portfolio
26

15.37


394

0.15
%
1.35
%
5.61
 %
Fidelity VIP Mid Cap Portfolio
69

 51.10 to 52.99


3,556

0.39
%
 1.10% to 1.35%

(2.83)% to (2.58)%

Non-Affiliated Service Class 2:
 
 
 
 
 
 
 
Fidelity VIP Asset Manager Portfolio
71

 15.94 to 17.62


1,040

1.14
%
 1.00% to 1.67%

(1.73)% to (1.06)%

Fidelity VIP Balanced Portfolio
343

 17.85 to 19.77


5,575

1.31
%
 1.00% to 1.67%

(1.31)% to (0.64)%

Fidelity VIP Contrafund® Portfolio
1,253

 24.33 to 24.20


23,589

0.91
%
 0.60% to 1.67%

(1.26)% to (0.19)%

Fidelity VIP Disciplined Small Cap Portfolio
44

 13.07 to 13.86


586

0.39
%
 1.00% to 1.67%

(3.81)% to (3.16)%

Fidelity VIP Equity-Income Portfolio
285

 17.68 to 17.66


4,013

2.78
%
 1.00% to 1.67%

(5.84)% to (5.20)%

Fidelity VIP Freedom 2010 Portfolio
84

 12.49 to 12.72


1,032

1.30
%
 1.15% to 1.60%

(2.12)% to (1.67)%

Fidelity VIP Freedom 2015 Portfolio
70

 12.09 to 12.66


853

1.37
%
 1.15% to 1.67%

(2.17)% to (1.65)%

Fidelity VIP Freedom 2020 Portfolio
32

 12.42 to 12.43


382

1.30
%
 1.15% to 1.60%

(2.05)% to (1.60)%

Fidelity VIP Freedom 2025 Portfolio
41

 12.93 to 12.56


504

2.06
%
 1.45% to 1.60%

(2.10)% to (1.95)%

Fidelity VIP Freedom 2030 Portfolio
96

 11.92 to 12.48


1,140

0.13
%
 1.15% to 1.67%

(2.19)% to (1.67)%

Fidelity VIP Growth Portfolio
178

 20.38 to 18.19


3,069

0.03
%
 1.00% to 1.67%

5.12% to 5.84%

Fidelity VIP High Income Portfolio
86

 16.46 to 20.57


1,333

2.00
%
 1.00% to 1.67%

(5.47)% to (4.83)%

Fidelity VIP Index 500 Portfolio
1,248

 20.48 to 18.55


18,202

1.87
%
 1.00% to 1.67%

(0.60)% to 0.07%

Fidelity VIP Investment Grade Bond Portfolio
1,264

 13.08 to 16.45


16,162

3.32
%
 1.00% to 1.67%

(2.50)% to (1.84)%

Fidelity VIP Mid Cap Portfolio
389

 29.85 to 33.57


7,472

0.24
%
 1.00% to 1.67%

(3.27)% to (2.61)%

Fidelity VIP Overseas Portfolio
286

 18.22 to 17.15


3,311

1.09
%
 1.00% to 1.67%

1.57% to 2.26%

Fidelity VIP Target Volatility Portfolio
23

 10.41 to 10.49


238

1.40
%
 1.15% to 1.55%

(2.87)% to (2.47)%

Non-Affiliated Class 1:
 
 
 
 
 
 
 
Columbia VP – Mid Cap Value Fund
72

 13.51 to 13.95


989

%
 1.00% to 1.67%

(6.57)% to (5.94)%

Franklin Growth and Income VIP Fund
98

 20.71 to 20.92


2,033

3.61
%
 1.10% to 1.35%

(1.96)% to (1.71)%

Franklin Income VIP Fund
199

 21.58 to 21.80


4,305

4.77
%
 1.10% to 1.35%

(8.09)% to (7.86)%

JP Morgan IT Mid Cap Value
45

 26.89 to 27.91


1,125

0.99
%
 1.00% to 1.55%

(4.16)% to (3.63)%

Morgan Stanley VIF Emerging Markets Debt Portfolio
9

 22.95 to 28.38


226

5.86
%
 1.10% to 1.55%

(2.65)% to (2.20)%

Morgan Stanley VIF U.S. Real Estate Portfolio
40

 32.01 to 34.68


1,444

1.33
%
 1.00% to 1.55%

0.59% to 1.15%

Non-Affiliated Class 2:
 
 
 
 
 
 
 
American Funds I.S. Managed Risk Asset Allocation Fund
152

 10.12 to 10.25


1,542

1.57
%
 1.00% to 1.60%

(2.65)% to (2.06)%

Columbia VP – Small Cap Value Fund
51

 19.30 to 19.99


996

0.59
%
 1.15% to 1.67%

(7.88)% to (7.39)%

Franklin Growth and Income VIP Fund
375

 18.42 to 20.98


6,110

3.41
%
 1.00% to 1.67%

(2.56)% to (1.90)%

Franklin Income VIP Fund
995

 17.82 to 21.88


13,802

4.66
%
 1.00% to 1.67%

(8.61)% to (7.98)%

Franklin Large Cap Growth VIP Fund
164

 18.32 to 21.91


2,690

0.28
%
 1.00% to 1.67%

3.86% to 4.57%

Franklin Mutual Shares VIP Fund
724

 18.09 to 18.29


9,629

3.13
%
 0.60% to 1.67%

(6.52)% to (5.51)%

Franklin Small Cap Value VIP Fund
72

 12.42 to 15.40


926

0.67
%
 1.15% to 1.67%

(8.93)% to (8.45)%

Invesco V.I. American Franchise Fund
16

 20.17 to 19.20


321

%
 1.15% to 1.67%

3.00% to 3.55%

Invesco V.I. American Value Fund
105

 14.43 to 15.20


1,541

0.01
%
 1.00% to 1.67%

(10.87)% to (10.26)%

Invesco V.I. Comstock Fund
187

 19.70 to 23.48


2,670

1.76
%
 1.00% to 1.67%

(7.76)% to (7.13)%


42

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2015
 
 
 
 
Investment
 
 
 
 Units
 Unit Value
 
 Net Assets
Income
Expense Ratio
Total Return
Subaccount
 (000s)
Range
 
 (000s)
Ratio (**)
Range (***)
Range (****)
Non-Affiliated Class 2 (continued):
 
 
 
 
 
 
 
Invesco V.I. International Growth Fund
106

 $10.64 to $10.74


$
1,123

1.43
%
 0.80% to 1.67%

(3.93)% to (3.73)%

Templeton Foreign VIP Fund
366

 16.82 to 19.75


4,269

3.21
%
 1.00% to 1.67%

(8.05)% to (7.43)%

Templeton Global Bond VIP Fund
84

 9.21 to 9.29


773

7.59
%
 1.15% to 1.55%

(5.69)% to (5.40)%

Templeton Growth VIP Fund
166

 16.15 to 15.59


2,296

2.60
%
 0.60% to 1.67%

(8.05)% to (7.05)%

Morgan Stanley VIF Emerging Markets Debt Portfolio
82

 18.46 to 13.36


1,109

5.20
%
 1.00% to 1.67%

(2.82)% to (2.16)%

Morgan Stanley VIF Emerging Markets Equity Portfolio
187

 23.59 to 29.33


2,271

0.75
%
 1.00% to 1.67%

(12.20)% to (11.60)%

Morgan Stanley VIF U.S. Real Estate Portfolio
202

 28.78 to 12.04


2,878

1.16
%
 1.00% to 1.67%

0.22% to 0.90%

Non-Affiliated Class 3:
 
 
 
 
 
 
 
BlackRock Capital Appreciation V.I. Fund
111

 13.85 to 14.25


1,539

%
 1.00% to 1.60%

4.91% to 5.54%

BlackRock Global Allocation V.I. Fund
102

 10.62 to 10.93


1,093

1.02
%
 1.00% to 1.60%

(2.58)% to (1.99)%

TOPS® Managed Risk Moderate Growth ETF Portfolio
13

 9.76 to 9.86


131

1.29
%
 1.35% to 1.45%

(7.91)% to (7.54)%

Non-Affiliated Class 4:
 
 
 
 
 
 
 
American Funds I.S. Capital Income Builder Fund (April 23, 2015)
30

 9.32 to 9.31


278

3.19
%
 1.15% to 1.45%

(6.83)% to (6.90)%

American Funds I.S. Global Growth Fund
131

 11.04 to 11.14


1,454

2.27
%
 1.15% to 1.60%

4.98% to 5.46%

American Funds I.S. Growth Fund
14

 11.66 to 11.76


168

1.00
%
 1.15% to 1.55%

4.93% to 5.36%

American Funds I.S. Growth-Income Fund
108

 11.30 to 11.39


1,221

1.40
%
 1.15% to 1.55%

(0.36)% to 0.05%

American Funds I.S. New World Fund
63

 8.87 to 8.95


558

0.80
%
 1.15% to 1.55%

(4.87)% to (4.48)%

Non-Affiliated Class A:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
21

 23.14 to 23.98


488

1.09
%
 1.10% to 1.45%

(5.98)% to (5.64)%

Non-Affiliated Class B:
 
 
 
 
 
 
 
DWS Small Cap Index VIP Fund
67

 21.03 to 21.97


1,108

0.84
%
 1.00% to 1.67%

(6.44)% to (5.81)%

Advisor Class:
 
 
 
 
 
 
 
PIMCO VIT All Asset Portfolio
144

 10.70 to 11.28


1,579

2.90
%
 1.00% to 1.67%

(10.70)% to (10.10)%

PIMCO VIT CommodityRealReturn® Strategy Portfolio
426

 3.73 to 5.10


1,619

4.41
%
 1.15% to 1.67%

(26.90)% to (26.52)%

PIMCO VIT Long-Term U.S. Government Portfolio
9

10.1


94

2.02
%
1.15
%
(2.60
)%
PIMCO VIT Low Duration Portfolio
189

 11.02 to 11.61


2,113

3.26
%
 1.00% to 1.67%

(1.45)% to (0.78)%

PIMCO VIT Real Return Portfolio
144

 11.12 to 11.71


1,627

3.72
%
 1.00% to 1.67%

(4.42)% to (3.77)%

PIMCO VIT Total Return Portfolio
1,719

 12.68 to 13.36


22,333

4.94
%
 1.00% to 1.67%

(1.31)% to (0.63)%

Investor Class:
 
 
 
 
 
 
 
Guggenheim VT Global Managed Futures Strategy Fund
62

 7.19 to 7.54


451

2.08
%
 1.00% to 1.67%

(3.19)% to (2.53)%

Guggenheim VT Multi-Hedge Strategies Fund
71

 8.65 to 9.11


640

0.61
%
 1.00% to 1.67%

0.15% to 0.83%

Guggenheim VT Long Short Equity Fund
19

 9.69 to 10.21


192

%
 1.00% to 1.67%

(0.43)% to 0.25%

ETF Shares:
 
 
 
 
 
 
 
iShares® Core S&P 500 ETF
529

 39.86 to 41.24


21,252

2.15
%
 1.75% to 2.75%

(1.50)% to (0.49)%

iShares® Core S&P Mid-Cap ETF
157

 37.53 to 37.66


5,946

1.49
%
 1.75% to 2.75%

(4.97)% to (4.00)%

iShares® Core S&P Small-Cap ETF
80

 38.65 to 38.86


3,127

1.43
%
 1.75% to 2.75%

(4.76)% to (3.78)%

iShares® Core U.S. Aggregate Bond ETF
25

 24.42 to 26.79


621

2.27
%
 1.75% to 2.75%

(2.28)% to (1.27)%

iShares® iBoxx $ High Yield Corporate Bond ETF
11

 26.38 to 27.88


291

5.43
%
 1.75% to 2.75%

(7.64)% to (6.69)%

iShares® Intermediate-Term Corporate Bond ETF
21

 25.18 to 26.09


531

2.48
%
 1.90% to 2.75%

(2.22)% to (1.37)%

iShares® International Treasury Bond ETF
126

 21.58 to 22.50


2,750

0.12
%
 1.75% to 2.75%

(9.79)% to (8.86)%

iShares® S&P 500 Growth ETF
46

 41.05 to 43.67


1,906

1.56
%
 1.75% to 2.75%

2.47% to 3.52%

iShares® S&P 500 Value ETF
14

 38.18 to 39.56


558

2.36
%
 1.90% to 2.75%

(5.94)% to (5.12)%

iShares® TIPS Bond ETF
6

 22.05 to 22.85


135

0.33
%
 1.90% to 2.75%

(4.46)% to (3.62)%

Vanguard® Developed Markets Index Fund, ETF Shares
97

 29.68 to 27.36


2,875

2.73
%
 1.75% to 2.75%

(3.10)% to (2.10)%

Vanguard® Dividend Appreciation Index Fund, ETF Shares
40

 35.12 to 37.65


1,408

2.30
%
 1.75% to 2.75%

(4.62)% to (3.64)%

Vanguard® Emerging Markets Stock Index Fund, ETF Shares
17

 20.46 to 18.20


345

2.79
%
 1.75% to 2.75%

(18.14)% to (17.29)%

Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
3

 26.77 to 29.49


94

3.27
%
 1.75% to 2.75%

(1.86)% to (0.85)%

Vanguard® Large-Cap Index Fund, ETF Shares
15

 39.75 to 40.87


591

1.95
%
 1.75% to 2.75%

(1.75)% to (0.74)%

Vanguard® Mega Cap Index Fund, ETF Shares
3

 39.87 to 41.37


124

2.07
%
 1.75% to 2.75%

(1.36)% to (0.34)%

Vanguard® Real Estate Index Fund, ETF Shares
8

 37.90 to 39.27


306

3.97
%
 1.90% to 2.75%

(0.39)% to 0.48%

Vanguard® Short-Term Bond Index Fund, ETF Shares
4

 23.40 to 24.16


90

1.30
%
 1.90% to 2.75%

(1.85)% to (0.99)%

Vanguard® Total Bond Market Index Fund, ETF Shares
853

 24.36 to 26.80


21,034

2.44
%
 1.75% to 2.75%

(2.20)% to (1.19)%


43










STATUTORY-BASIS FINANCIAL STATEMENTS

National Integrity Life Insurance Company
Years Ended December 31, 2019, 2018 and 2017
With Report of Independent Auditors



National Integrity Life Insurance Company

Statutory-Basis Financial Statements

Years Ended December 31, 2019, 2018 and 2017



Contents
Report of Independent Auditors
Financial Statements
Balance Sheets (Statutory-Basis)
Statements of Operations (Statutory-Basis)
Statements of Changes in Capital and Surplus (Statutory-Basis)
Statements of Cash Flow (Statutory-Basis)
Notes to Financial Statements (Statutory-Basis)








Report of Independent Auditors

The Board of Directors
National Integrity Life Insurance Company

We have audited the accompanying statutory-basis financial statements of National Integrity Life Insurance Company (the Company), which comprise the balance sheets as of December 31, 2019 and 2018, and the related statements of operations, changes in capital and surplus, and cash flow for each of the three years in the period ended December 31, 2019, and the related notes to the financial statements.

Management’s Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these financial statements in conformity with accounting practices prescribed or permitted by the New York Department of Financial Services, Division of Insurance. Management also is responsible for the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free of material misstatement, whether due to fraud or error.

Auditor’s Responsibility
Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits in accordance with auditing standards generally accepted in the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.





1


Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles
As described in Note 1 to the statutory-basis financial statements, the Company prepared these financial statements using accounting practices prescribed or permitted by the New York Department of Financial Services, Division of Insurance, which is a basis of accounting other than U.S. generally accepted accounting principles. The variances between such practices and U.S. generally accepted accounting principles and the effects on the accompanying financial statements are described in Note 1.

Adverse Opinion on U.S. Generally Accepted Accounting Principles
In our opinion, because of the significance of the matter described in the Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles paragraph, the statutory-basis financial statements referred to above do not present fairly, in conformity with U.S. generally accepted accounting principles, the financial position of the Company at December 31, 2019 and 2018, or the results of its operations or its cash flows for each of the three years in the period ended December 31, 2019.

Opinion on Statutory-Basis of Accounting
In our opinion, the statutory-basis financial statements referred to above present fairly, in all material respects, the financial position of the Company at December 31, 2019 and 2018, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2019, on the basis of accounting described in Note 1.


/s/ Ernst & Young LLP

Cincinnati, Ohio
April 20, 2020

2

National Integrity Life Insurance Company
Balance Sheets (Statutory-Basis)


December 31
20192018
Admitted assets(In Thousands)
Cash and invested assets:
Debt securities$2,495,289  $2,601,505  
Preferred and common stocks19,954  19,710  
Mortgage loans172,483  136,448  
Policy loans50,483  50,325  
Cash, cash equivalents and short-term investments74,495  21,483  
Receivable for securities2,629  3,019  
Securities lending reinvested collateral assets40,713  —  
Other invested assets106,235  84,799  
Total cash and invested assets2,962,281  2,917,289  
Investment income due and accrued23,784  24,442  
Current federal income taxes recoverable—  66  
Net deferred income tax asset9,291  4,892  
Other admitted assets1,676  2,688  
Separate account assets1,487,072  1,543,190  
Total admitted assets$4,484,104  $4,492,567  
Liabilities and capital and surplus
Liabilities:
Policy and contract liabilities:
Life and annuity reserves2,389,263  $2,423,092  
Liability for deposit-type contracts155,431  166,552  
Policy and contract claims602  1,496  
Total policy and contract liabilities
2,545,296  2,591,140  
General expense due and accrued24  11  
Current federal income taxes payable1,657  —  
Transfer to (from) separate accounts due and accrued, net(18,790) (26,194) 
Asset valuation reserve41,172  40,180  
Interest maintenance reserve1,319  —  
Other liabilities8,502  5,235  
Payable for securities lending40,713  —  
Separate account liabilities1,487,072  1,543,190  
Total liabilities4,106,965  4,153,562  
Capital and surplus:
Common stock, $10 par value, authorized 200 shares, issued and outstanding 200 shares
2,000  2,000  
Paid-in surplus312,228  312,228  
Accumulated surplus62,911  24,777  
Total capital and surplus377,139  339,005  
Total liabilities and capital and surplus$4,484,104  $4,492,567  
See accompanying notes.
3

National Integrity Life Insurance Company
Statements of Operations (Statutory-Basis)


Year Ended December 31
201920182017
(In Thousands)
Premiums and other revenues:
Premiums and annuity considerations $209,917  $249,174  $224,438  
Net investment income 133,567  119,199  120,672  
Considerations for supplementary contracts with life contingencies
7,134  8,332  7,870  
Amortization of the interest maintenance reserve (878) (550) (542) 
Fees from management of separate accounts7,057  7,477  7,320  
Other revenues 1,092  1,183  981  
Total premiums and other revenues 357,889  384,815  360,739  
Benefits paid or provided:
Death benefits 4,758  4,569  6,118  
Annuity benefits 122,658  125,848  112,903  
Surrender benefits 340,401  355,911  323,875  
Payments on supplementary contracts with life contingencies
9,787  9,708  8,814  
Increase (decrease) in policy reserves and other policyholders’ funds
(29,009) 9,747  34,921  
Total benefits paid or provided 448,595  505,783  486,631  
Insurance expenses and other deductions:
Commissions 11,214  12,227  11,684  
General expenses 16,626  17,836  17,728  
Net transfers to (from) separate accounts(167,395) (183,274) (162,037) 
Other deductions 605  438  563  
Total insurance expenses and other deductions (138,950) (152,773) (132,062) 
    
Gain (loss) from operations before federal income tax expense and net realized capital gains (losses)
48,244  31,805  6,170  
Federal income tax expense (benefit), excluding tax on capital gains
10,163  9,148  16,485  
Gain (loss) from operations before net realized capital gains (losses)
38,081  22,657  (10,315) 
Net realized capital gains (losses) (excluding gains (losses) transferred to IMR and capital gains tax)
(2,485) 2,746  (3,753) 
Net income (loss) $35,596  $25,403  $(14,068) 
See accompanying notes.

4

National Integrity Life Insurance Company
Statements of Changes in Capital and Surplus (Statutory-Basis)


Common
Stock
Paid-In
Surplus
Accumulated SurplusTotal Capital
and Surplus
(In Thousands)
Balance, January 1, 2017$2,000  $312,228  $45,034  $359,262  
Net income (loss)—  —  (14,068) (14,068) 
Change in net deferred income tax—  —  2,020  2,020  
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($716))
—  —  7,515  7,515  
Net change in nonadmitted assets and related items
—  —  (2,547) (2,547) 
Change in asset valuation reserve—  —  (2,446) (2,446) 
Change in surplus in separate accounts—  —  193  193  
Dividends to stockholder—  —  (34,000) (34,000) 
Balance, December 31, 20172,000  312,228  1,701  315,929  
Net income (loss) —  —  25,403  25,403  
Change in net deferred income tax —  —  4,892  4,892  
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($2,295))
—  —  (8,633) (8,633) 
Net change in nonadmitted assets and related items
—  —  (6,204) (6,204) 
Change in asset valuation reserve—  —  7,618  7,618  
Balance, December 31, 20182,000  312,228  24,777  339,005  
Net income (loss) —  —  35,596  35,596  
Change in net deferred income tax —  —  988  988  
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($1,054))
—  —  (3,964) (3,964) 
Net change in nonadmitted assets and related items
—  —  6,253  6,253  
Change in asset valuation reserve —  —  (992) (992) 
Cumulative effect of changes in accounting principles—  —  253  253  
Balance, December 31, 2019$2,000  $312,228  $62,911  $377,139  
See accompanying notes.
5

National Integrity Life Insurance Company
Statements of Cash Flow (Statutory-Basis)


Year Ended December 31
201920182017
(In Thousands)
Operating activities
Premiums collected net of reinsurance$217,051  $257,506  $232,308  
Net investment income received121,153  123,530  128,377  
Benefits paid(483,269) (499,131) (454,405) 
Net transfers from (to) separate accounts177,631  169,401  168,906  
Commissions and expense paid(27,959) (29,901) (29,520) 
Federal income taxes recovered (paid)(9,654) (13,507) (20,643) 
Other, net 8,149  8,659  8,302  
Net cash from (for) operations3,102  16,557  33,325  
Investing activities
Proceeds from investments sold, matured or repaid:
Debt securities500,259  485,704  409,614  
Preferred and common stocks10,222  46,524  450  
Mortgage loans2,585  31,437  5,454  
Other invested assets21,530  4,068  4,776  
Net gains (losses) on cash, cash equivalents and short-term investments19  12  —  
Miscellaneous proceeds390  —  52,798  
Net proceeds from investments sold, matured or repaid535,005  567,745  473,092  
Cost of investments acquired:
Debt securities(395,913) (533,287) (460,423) 
Preferred and common stocks(10,162) (2,940) (30,932) 
Mortgage loans(38,620) (9,000) (29,850) 
Other invested assets(32,851) (6,687) (13,215) 
Miscellaneous applications(40,912) (1,979) —  
Total cost of investments acquired(518,458) (553,893) (534,420) 
Net change in policy and other loans(157) (2,816) (96) 
Net cash from (for) investments16,390  11,036  (61,424) 
Financing and miscellaneous activities
Net deposits on deposit-type contract funds and other insurance liabilities(11,121) (13,052) 95,666  
Dividends paid to stockholder—  —  (34,000) 
Other cash provided (applied)44,641  (1,140) (48,767) 
Net cash from (for) financing and miscellaneous sources33,520  (14,192) 12,899  
Net change in cash, cash equivalents and short-term investments53,012  13,401  (15,200) 
Cash, cash equivalents and short-term investments:
Beginning of year21,483  8,082  23,282  
End of year$74,495  $21,483  $8,082  
See accompanying notes.

6

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017

1. Nature of Operations and Significant Accounting Policies
National Integrity Life Insurance Company (the Company) is a wholly-owned subsidiary of Integrity Life Insurance Company (Integrity), which is a wholly-owned subsidiary of The Western and Southern Life Insurance Company (Western and Southern). The Company, domiciled in the state of New York and currently licensed in eight states and the District of Columbia, specializes in the asset accumulation business with particular emphasis on retirement savings and investment products. The Company also offers interest-sensitive life insurance products. For the year ended December 31, 2019, approximately 95.3% of the gross premiums and annuity considerations for the Company were derived from New York. Fort Washington Investment Advisors, Inc. (Fort Washington), a registered investment adviser, is a nonlife insurance subsidiary of Western and Southern and is the investment manager for the Company.
State regulatory authorities have powers relating to granting and revoking licenses to transact business, the licensing of agents, the regulation of premium rates and trade practices, the form and content of insurance policies, the content of advertising material, financial statements and the nature of permitted practices.
Use of Estimates
The preparation of statutory-basis financial statements requires management to make estimates and assumptions that affect amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates.
Basis of Presentation
The accompanying financial statements of the Company have been prepared in conformity with accounting practices prescribed or permitted by the New York Department of Financial Services, Division of Insurance (the Department). The National Association of Insurance Commissioners’ (NAIC) Accounting Practices and Procedures Manual (NAIC SAP or SSAP) has been adopted as a component of prescribed or permitted practices by the State of New York. These practices differ in some respects from U.S. generally accepted accounting principles (GAAP). The more significant differences follow.
Investments
Investments in debt securities and mandatory redeemable preferred stocks are reported at amortized cost or fair value based on the NAIC rating; for GAAP, such fixed maturity investments are designated at purchase as held-to-maturity, trading or available-for-sale. Held-to-maturity fixed investments are reported at amortized cost, and the remaining fixed maturity investments are reported at fair value with unrealized holding gains and losses reported in the statement of operations for those designated as trading and as a separate component of other comprehensive income (loss) for those designated as available-for-sale.
7

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
All single-class and multiclass mortgage-backed/asset-backed securities (e.g., CMOs) are adjusted for the effects of changes in prepayment assumptions on the related accretion of discount or amortization of premium of such securities using the retrospective method. The prospective method is used to determine amortized cost for securities that experience a decline that is deemed to be other-than-temporary. Securities that are in an unrealized loss position which the Company intends to sell, or does not have the intent and ability to hold until recovery, are written down to fair value as a realized loss. Securities that are in an unrealized loss position which the Company has the intent and ability to hold until recovery are written down to the extent the present value of expected future cash flows using the security’s effective yield is lower than the amortized cost. For GAAP purposes, all securities, purchased or retained, that represent beneficial interests in securitized assets (e.g., CMO, CBO, CDO, CLO, MBS and ABS securities), other than high credit quality securities, are adjusted using the prospective method when there is a change in estimated future cash flows. If it is determined that a decline in fair value is other-than-temporary, the cost basis of the security is written down to the extent the present value of expected future cash flows using the security’s effective yield is lower than the amortized cost. If high credit quality securities are adjusted, the retrospective method is used.
The Company monitors other investments to determine if there has been an other-than-temporary decline in fair value. Factors that management considers for each identified security include the following:
The extent and length of time the fair value has been below the book/adjusted carrying value;
The reasons for the decline in value;
Specific credit issues related to the issuer and current economic conditions, including the current and future impact of any specific events;
For structured investments (e.g., residential mortgage-backed securities, commercial mortgage-backed securities, asset-backed securities and other structured investments), factors such as overall deal structure and the Company’s position within the structure, quality of underlying collateral, delinquencies and defaults, loss severities, recoveries, prepayments and cumulative loss projections are considered;
For all equity securities and other debt securities with credit-related declines in fair value, the Company’s intent and ability to hold the security long enough for it to recover its value to book/adjusted carrying value; and
For all other debt securities with interest-related declines in fair value, the Company’s intent to sell the security before recovery of its book/adjusted carrying value.
If the decline is judged to be other-than-temporary, an impairment charge to fair value is recorded as a net realized capital loss in the period the determination is made. Under GAAP, if the decline is judged to be other-than-temporary because the Company has the intent to sell the debt security or is more likely than not to be required to sell the debt security before its anticipated recovery, an impairment charge to fair value is recorded as a net realized capital loss. If the decline is judged to be other-than-temporary because the Company does not expect to recover the entire amortized cost basis of the security due to expected credit losses, an impairment charge is recorded to net realized capital loss as the difference between amortized cost and the net present value of expected future cash flows discounted at the effective interest rate implicit in the debt security prior to impairment.
8

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Under a formula prescribed by the NAIC, the Company defers the portion of realized capital gains and losses on sales of fixed income investments, principally debt securities and mortgage loans, attributable to changes in the general level of interest rates and amortizes those deferrals over the remaining period to maturity of the individual security sold using the seriatim method. The net deferral is reported as the interest maintenance reserve (IMR) in the accompanying balance sheets. Realized capital gains and losses are reported in income net of federal income tax and transfers to the IMR. Under GAAP, realized capital gains and losses are reported in the the statements of operations on a pretax basis in the period that the assets giving rise to the gains or losses are sold.
The asset valuation reserve (AVR) provides a valuation allowance for invested assets. The AVR is determined by an NAIC prescribed formula with changes reflected directly in capital and surplus. AVR is not recognized for GAAP.
Policy Acquisition Costs
The costs of acquiring and renewing business are expensed when incurred. Under GAAP, policy acquisition costs, related to traditional life insurance and certain long-duration accident and health insurance policies sold, to the extent recoverable from future policy revenues, would be deferred and amortized over the premium-paying period of the related policies using assumptions consistent with those used in computing policy benefit reserves; for universal life insurance and investment products, to the extent recoverable from future gross profits, deferred policy acquisition costs are amortized generally in proportion to the present value of expected gross profits from surrender charges and investments, mortality, and expense margins.
Nonadmitted Assets
Certain assets designated as “nonadmitted” (principally a portion of deferred tax assets), and other assets not specifically identified as admitted assets within the NAIC’s Accounting Practices and Procedures Manual, are excluded from the accompanying balance sheets and are charged directly to accumulated surplus. Under GAAP, such assets are included in the balance sheets.
Premiums and Benefits
Revenues for universal life and annuity policies with mortality or morbidity risk, except for guaranteed interest and group annuity contracts, consist of the entire premium received, and benefits incurred represent the total of death benefits paid and the change in policy reserves. Premiums received for annuity policies without mortality or morbidity risk and for guaranteed interest and group annuity contracts are recorded using deposit accounting, and credited directly to an appropriate policy reserve account, without recognizing premium income. Under GAAP, premiums received in excess of policy charges would not be recognized as premium revenue and benefits would represent the excess of benefits paid over the policy account value and interest credited to the account values.
Benefit Reserves
Certain policy reserves are calculated using statutorily prescribed interest and mortality assumptions rather than on estimated expected experience or actual account balances as would be required under GAAP.
9

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Reinsurance
A liability for reinsurance balances is required to be provided for unsecured policy reserves ceded to reinsurers not authorized to assume such business. Changes to those amounts are credited or charged directly to capital and surplus. Under GAAP, an allowance for amounts deemed uncollectible would be established through a charge to earnings.
Policy and contract liabilities ceded to reinsurers have been reported as reductions of the related reserves rather than as assets as would be required under GAAP. Commissions allowed by reinsurers on business ceded are reported as income when incurred rather than being deferred and amortized with policy acquisition costs as required under GAAP.
Deferred Income Taxes
Deferred tax assets are recorded for the amount of gross deferred tax assets expected to be realized in future years, and a valuation allowance is established for deferred tax assets not meeting a more-likely-than-not realization threshold. Deferred tax assets are limited to 1) the amount of federal income taxes paid in prior years that can be recovered through loss carrybacks for existing temporary differences that reverse during a time frame corresponding with Internal Revenue Service (IRS) tax loss carryback provisions, not to exceed three years, including amounts established in accordance with the provision of SSAP No. 5R, plus 2) for entities who meet the required realization threshold in SSAP No. 101, the lesser of the remaining gross deferred tax assets expected to be realized within three years of the balance sheet date or 15% of capital and surplus excluding any net deferred tax assets, electronic data processing equipment and operating software and any net positive goodwill, plus 3) the amount of remaining gross deferred tax assets that can be offset against existing gross deferred tax liabilities. The remaining deferred tax assets are nonadmitted. Under GAAP, a deferred tax asset is recorded for the amount of gross deferred tax assets expected to be realized in all future years, and a valuation allowance is established for deferred tax assets not meeting a more-likely-than-not realization threshold.
Statements of Cash Flow
Cash, cash equivalents and short-term investments in the statements of cash flow represent cash balances and investments with initial maturities of one year or less. Under GAAP, the corresponding captions of cash and cash equivalents include cash balances and investments with initial maturities of three months or less.
Other significant statutory accounting practices follow.
10

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Restricted Assets
The Company has assets pledged as collateral, or otherwise not exclusively under control of the Company, totaling $162.8 million and $130.9 million as of December 31, 2019 and 2018, respectively. These assets are primarily collateral pledged to the Federal Home Loan Bank (FHLB). These restricted assets are discussed in more detail in their relevant section.
Investments
Debt securities, common stocks, preferred stocks, and short-term investments are stated at values prescribed by the NAIC, as follows:
Debt securities not backed by other loans are principally stated at amortized cost using the interest method.
Single-class and multiclass mortgage-backed/asset-backed securities are valued at amortized cost using the interest method including anticipated prepayments. Prepayment assumptions are obtained from Bloomberg and broker-dealer prepayment models or derived from empirical data and are based on the current interest rate and economic environment. The retrospective adjustment method is used to value all such securities except securities that are deemed to be other-than-temporarily impaired and securities that are principal-only or interest-only, which are valued using the prospective method.
Unaffiliated common stocks, other than FHLB stock, are unrestricted and reported at fair value utilizing publicly quoted prices from third-party pricing services and the related unrealized capital gains and losses are reported in capital and surplus along with any adjustment for federal income taxes. FHLB stock is carried at cost and is restricted. At December 31, 2019 and 2018, the Company owned $9.5 million and $7.9 million, of FHLB stock, respectively. The FHLB stock is held in conjunction with the issuance of deposit contracts to the FHLB. See Note 9 for further description.
Redeemable preferred stocks that have characteristics of debt securities and are rated as medium quality or better are reported at cost or amortized cost. All other redeemable preferred stocks are reported at the lower of cost, amortized cost or fair value. Perpetual preferred stocks that have the characteristics of equity securities and are rated as medium quality or better are reported at cost. All other perpetual preferred stocks are reported at the lower of cost or fair value utilizing publicly quoted prices from third-party pricing services and the related unrealized capital gains and losses are reported in capital and surplus along with any adjustment for federal income taxes.
Short-term investments include investments with remaining maturities of one year or less at the date of acquisition and are principally stated at amortized cost, which approximates fair value.
Cash equivalents are short-term highly liquid investments with original maturities of three months or less and are principally stated at amortized cost, which approximates fair value.
Joint ventures, partnerships, and limited liability companies are carried at the Company’s interest in the underlying audited GAAP equity of the investee. Undistributed earnings allocated to the Company are reported in the change in net unrealized capital gains or losses. Distributions from earnings of the
11

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
investees are reported as net investment income when received. Because of the indirect nature of these investments, there is an inherent reduction in transparency and liquidity and increased complexity in valuing the underlying investments. As a result, these investments are actively managed by the Company’s management via detailed evaluation of the investment performance relative to risk.
Mortgage loans are reported at unpaid principal balances, less an allowance for impairment. A mortgage loan is considered to be impaired when, based on current information and events, it is probable that the Company will be unable to collect all principal and interest amounts due according to the contractual terms of the mortgage agreement. When management determines foreclosure is probable, the impairment is other than temporary; the mortgage loan is written down to realizable value and a realized loss is recognized.
Policy loans are reported at unpaid principal balances.
Debt securities and other loan interest are credited to income as it accrues. Dividends are recorded as income on ex-dividend dates. To the extent income is uncertain, due and accrued income is excluded and treated as nonadmitted through surplus.
Realized capital gains and losses are determined using the specific identification method.
Premiums
Life and accident and health premiums are recognized as revenue when due. Premiums for annuity policies with mortality and morbidity risk, except for guaranteed interest and group annuity contracts, are also recognized as revenue when due. Premiums received for annuity policies without mortality or morbidity risk and for guaranteed interest and group annuity contracts are recorded using deposit accounting.
Policy Reserves
Life and annuity reserves are developed by actuarial methods and are determined based on published tables using statutorily specified interest rates and valuation methods that will provide, in the aggregate, reserves that are greater than or equal to the minimum or guaranteed policy cash values or the amounts required by the Department. The Company waives deduction of deferred fractional premiums on the death of life and annuity policy insureds and does not return any premium beyond the date of death. Surrender values on policies do not exceed the corresponding benefit reserves. Policies issued subject to multiple table substandard extra premiums are valued on the standard reserve basis which recognizes the nonlevel incidence of the excess mortality costs. Additional reserves are established when the results of cash flow testing under various interest rate scenarios indicate the need for such reserves, or the net premiums exceed the gross premiums on any insurance in-force.
Contracts issued that do not incorporate mortality or morbidity risk, such as guaranteed interest contracts, are accounted for as deposit-type contracts. Amounts received as payments and amounts withdrawn on deposit-type contracts are recorded directly to the liability for deposit-type contracts.
12

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The mean reserve method is used to adjust the calculated terminal reserve to the appropriate reserve at December 31. Mean reserves are determined by computing the regular mean reserve for the plan at the rated age and holding, in addition, one-half of the extra premium charge for the year. Policies issued after July 1 for substandard lives, are charged an extra premium plus the regular premium for the true age. Mean reserves are based on appropriate multiples of standard rates of mortality. An asset is recorded for deferred premiums net of loading to adjust the reserve for modal premium payments.
For substandard table ratings, mean reserves are based on 125% to 500% of standard mortality rates. For flat extra ratings, mean reserves are based on the standard or substandard mortality rates increased by 1 to 25 deaths per thousand.
Tabular interest, tabular less actual reserves released, and tabular cost have been determined by formula as prescribed by the NAIC. Tabular interest on funds not involving life contingencies was derived from basic data.
The establishment of appropriate reserves is an inherently uncertain process, and there can be no assurance that the ultimate liability will not exceed the Company’s policy reserves and have an adverse effect on the Company’s results of operations and financial condition. Due to the inherent uncertainty of estimating reserves, it has been necessary, and may over time continue to be necessary, to revise estimated future liabilities as reflected in the Company’s policy reserves.
Reinsurance
Reinsurance premiums and benefits paid or provided are accounted for on a basis consistent with those used in accounting for the original policies issued and the terms of the reinsurance contracts.
Securities Lending
At December 31, 2019, the Company had loaned various debt securities, preferred stocks and common stocks as part of a securities lending program administered by Deutsche Bank, of which the fair value was $39.8 million and $7.0 million in the general and separate account, respectively. At December 31, 2018, the Company did not have securities on loan. The general account and separate account collateral is managed by an unaffiliated agent.
The Company requires at the initial transaction that the fair value of the cash collateral received must be equal to 102% of the fair value of the loaned securities. The Company monitors the ratio of the fair value of the collateral to loaned securities to ensure it does not fall below 100%. If the fair value of the collateral falls below 100% of the fair value of the securities loaned, the Company nonadmits that portion of the loaned security. At December 31, 2019, the Company did not nonadmit any portion of the loaned securities.
The Company reports all collateral on the balance sheet with an offsetting liability recognized for the obligation to return the collateral. Collateral for the securities lending program is managed by Deutsche Bank, an unaffiliated agent. At December 31, 2019, total collateral, which approximated $47.8 million, was invested in cash equivalents and was included in securities lending reinvested collateral assets on the balance sheet.
13

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
At December 31, 2019, the collateral for all securities on loan could be requested to be returned on demand by the borrower. At December 31, 2019, the fair value of the total collateral is $40.7 million. The fair value of the total collateral in the separate account was $7.1 million at December 31, 2019, which was all managed by an unaffiliated agent.
The aggregate collateral broken out by maturity date is as follows at December 31, 2019:
Amortized CostFair
Value
(In Thousands)
Open$—  $—  
30 days or less47,837  47,837  
31 to 60 days—  —  
61 to 90 days—  —  
91 to 120 days—  —  
121 to 180 days—  —  
181 to 365 days—  —  
1 to 2 years—  —  
2 to 3 years—  —  
Greater than 3 years—  —  
Total collateral$47,837  $47,837  
At December 31, 2019, all of the collateral held for the securities lending program was invested in tradable securities that could be sold and used to pay for the $40.7 million and $7.1 million in the general and separate accounts, respectively, in collateral calls that could come due under a worst-case scenario where all collateral was called simultaneously.
The Company does not accept collateral that is not permitted by contract or custom to sell or repledge. The Company does not have any securities lending transactions that extend beyond one year from the reporting date.
14

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Separate Accounts
Separate account assets and liabilities reported in the accompanying balance sheets represent funds that are separately administered, principally for nonguaranteed variable annuity contracts and guaranteed market value adjustment annuity contracts. Assets held in the separate account supporting variable annuities are carried at fair value. Assets held in the separate account supporting market value adjusted annuities are carried at the general account basis. These separate account assets are considered legally insulated from the general account. Surrender charges collectible by the general account in the event of annuity contract surrenders are reported as a negative liability rather than an asset. Policy-related activity involving cash flow, such as premiums and benefits, are reported in the accompanying statements of operations in separate line items combined with related general account amounts. Investment income and interest credited on deposits held in guaranteed separate accounts are included in the accompanying statements of operations as a net amount included in net transfers to (from) separate accounts. The Company receives administrative fees for managing the nonguaranteed separate accounts and other fees for assuming mortality and certain expense risks.
Federal Income Taxes
Western and Southern files a consolidated income tax return with its eligible subsidiaries and affiliates, including the Company. The provision for federal income taxes is allocated to the Company using a separate return method based upon a written tax-sharing agreement. The benefits from losses of subsidiaries and affiliates, which are utilized in the consolidated return, will be retained by the subsidiaries and affiliates under the tax-sharing agreement. Western and Southern pays all federal income taxes due for all members of the consolidated group. The Company will then charge or reimburse, as the case may be, the members of the group an amount consistent with the method described in the tax-sharing agreement.
The Company includes interest and penalties in the federal income tax line on the statements of operations.
Accounting Changes
The Company did not have any material accounting changes in 2019, 2018, or 2017.
15

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Subsequent Events
The Company is exposed to potential risk associated with the recent outbreak of a new strain of coronavirus (“COVID-19”) and is actively monitoring developments through governmental briefings and the relevant health authorities. The effects of the outbreak on the Company are uncertain and difficult to predict, as the situation is actively evolving. Risks include (but are not limited to) the disruption of business operations due to changing work environments for employees, agents and distributors, and business partners; potential economic hardship of policyholders and issuers of investments held by the Company; and disruptions of product marketing and sales efforts. The Company has business continuity plans in place to attempt to mitigate the risks posed to business operations by disruptive incidents such as these.
The Company recognizes in the financial statements the effects of all subsequent events that provide additional evidence about conditions that existed at the balance sheet date. For nonrecognized subsequent events that must be disclosed to keep the financial statements from being misleading, the Company is required to disclose the nature of the event as well as an estimate of its financial effect, or a statement that such an estimate cannot be made. Management has evaluated subsequent events through the issuance of these financial statements on April 20, 2020.

16

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
2. Investments
The book/adjusted carrying value and fair value of the Company’s investments in debt securities are summarized as follows:
Book/Adjusted Carrying Value
Gross Unrealized GainsGross Unrealized LossesFair
Value
(In Thousands)
At December 31, 2019:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$3,274  $295  $—  $3,569  
Debt securities issued by states of the U.S. and political subdivisions of the states
1,703  337  —  2,040  
Non-U.S. government securities
29,451  1,720  —  31,171  
Corporate securities
1,778,486  118,119  (4,903) 1,891,702  
Commercial mortgage-backed securities
197,333  4,452  (517) 201,268  
Residential mortgage-backed securities
220,086  11,534  (643) 230,977  
Asset-backed securities
264,956  8,748  (145) 273,559  
Total$2,495,289  $145,205  $(6,208) $2,634,286  
At December 31, 2018:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$3,261  $252  $(35) $3,478  
Debt securities issued by states of the U.S. and political subdivisions of the states
7,727  288  (9) 8,006  
Non-U.S. government securities
29,487  523  (700) 29,310  
Corporate securities
1,794,746  29,004  (34,431) 1,789,319  
Commercial mortgage-backed securities
258,036  1,340  (2,126) 257,250  
Residential mortgage-backed securities
271,185  10,485  (3,469) 278,201  
Asset-backed securities
237,063  2,593  (3,956) 235,700  
Total$2,601,505  $44,485  $(44,726) $2,601,264  
At December 31, 2019 and 2018, the Company held unrated or below-investment-grade corporate debt securities with a book/adjusted carrying value of $170.1 million and $160.6 million, respectively, and an aggregate fair value of $176.8 million and $156.6 million, respectively. As of December 31, 2019 and 2018, such holdings amount to 6.8% and 6.2%, respectively, of the Company’s investment in debt securities and 3.8% and 3.6%, respectively, of the Company’s total admitted assets. The Company performs periodic evaluations of the relative credit standing of the issuers of these debt securities. The Company considers these evaluations in its overall investment strategy.
17

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Unrealized gains and losses on investments in unaffiliated common stocks are reported directly in capital and surplus and do not affect net income. The unrealized gains and unrealized losses on, and the cost and fair value of preferred and common stocks are as follows:
CostGross Unrealized GainsGross Unrealized Losses
Fair Value
(In Thousands)
At December 31, 2019:
Preferred stocks$3,371  $135  $—  $3,506  
Common stocks, unaffiliated$16,263  $320  $—  $16,583  
At December 31, 2018:
Preferred stocks$8,371  $—  $(604) $7,767  
Common stocks, unaffiliated$11,349  $—  $(10) $11,339  

18

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The following table shows unrealized losses and fair values, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position.
Unrealized Losses Less Than 12 MonthsUnrealized Losses Greater Than or Equal to 12 Months
UnrealizedFairUnrealizedFair
LossesValueLossesValue
(In Thousands)
At December 31, 2019:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$—  $—  $—  $—  
Debt securities issued by states of the U.S. and political subdivisions of the states
—  —  —  —  
Non-U.S. government securities
—  —  —  —  
Corporate securities(3,299) 72,202  (1,604) 30,612  
Commercial mortgage-backed securities(1)
(9) 2,491  (508) 8,090  
Residential mortgage-backed securities(1)
(499) 26,661  (144) 6,032  
Asset-backed securities(1)
(72) 23,257  (73) 5,662  
Total$(3,879) $124,611  $(2,329) $50,396  
Preferred stocks$—  $—  $—  $—  
Common stocks, unaffiliated$—  $—  $—  $—  
(1) Amounts relate to securities subject to SSAP 43R.
19

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Unrealized Losses Less Than 12 MonthsUnrealized Losses Greater Than or Equal to 12 Months
UnrealizedFairUnrealizedFair
LossesValueLossesValue
(In Thousands)
At December 31, 2018:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$—  $—  $(35) $2,438  
Debt securities issued by states of the U.S. and political subdivisions of the states
(9) 991  —  —  
Non-U.S. government securities
(384) 10,391  (316) 6,204  
Corporate securities(24,980) 853,433  (9,451) 160,003  
Commercial mortgage-backed securities(1)
(572) 91,735  (1,554) 44,109  
Residential mortgage-backed securities(1)
(1,408) 96,640  (2,061) 60,646  
Asset-backed securities(1)
(2,851) 103,373  (1,105) 40,226  
Total$(30,204) $1,156,563  $(14,522) $313,626  
Preferred stocks$(604) $7,767  $—  $—  
Common stocks, unaffiliated$(10) $3,447  $—  $—  
(1) Amounts relate to securities subject to SSAP 43R.
Investments that are impaired at December 31, 2019 and 2018, for which other-than-temporary impairments have not been recognized, consist mainly of corporate debt securities, asset-backed securities and residential mortgage-backed securities. The aggregated unrealized loss is approximately 3.4% and 3.0% of the carrying value of securities considered temporarily impaired at December 31, 2019 and 2018, respectively. At December 31, 2019, there were a total of 89 securities held that are considered temporarily impaired, of which 24 have been impaired for 12 months or longer. At December 31, 2018, there were a total of 447 securities held that are considered temporarily impaired, of which 100 have been impaired for 12 months or longer. The Company recorded other-than-temporary impairments on securities of $1.3 million, $1.3 million, and $2.7 million for the years ended December 31, 2019, 2018 and 2017, respectively.
20

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The following is a list of each loan-backed security held at December 31, 2019, with a recognized other-than-temporary impairment (OTTI) for the year ended December 31, 2019, where the present value of future cash flows expected to be collected was less than the amortized cost basis of the securities:
CUSIPBook/
Adjusted Carrying Value Amortized Cost Before Current Period OTTI
Present Value of Future Cash FlowsRecognized Other-
Than- Temporary Impairment
Amortized Cost After Other-Than-Temporary ImpairmentFair ValueDate of Other-Than-Temporary Impairment
(In Thousands)
For the year ended, December 31, 2019:
059469-AF-3$220  $214  $ $214  $211  6/30/2019
TotalXXX  XXX  $ XXX  XXX  
The Company had no OTTI on loan-backed securities for the year ended December 31, 2019, due to the intent to sell the security or the inability or lack of intent to retain the investment in the security for a period of time sufficient to recover the amortized cost basis of the security.
21

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
A summary of the cost or amortized cost and fair value of the Company’s debt securities at December 31, 2019, by contractual maturity, is as follows:
Book/Adjusted Carrying ValueFair
Value
(In Thousands)
Years to maturity:
One or less$94,206  $94,747  
After one through five867,415  895,834  
After five through ten550,817  591,261  
After ten300,476  346,640  
Mortgage-backed securities/asset-backed securities682,375  705,804  
Total$2,495,289  $2,634,286  
The expected maturities may differ from the contractual maturities in the foregoing table because certain borrowers have the right to call or prepay obligations with or without call or prepayment penalties and because asset-backed and mortgage-backed securities (including floating-rate securities) provide for periodic payments throughout their lives.
Proceeds from the sales of investments in debt securities during 2019, 2018 and 2017 were $199.4 million, $124.5 million, and $138.5 million; gross gains of $3.6 million, $0.9 million, and $2.9 million and gross losses of $0.9 million, $1.1 million, and $0.4 million were realized on these sales in 2019, 2018, and 2017, respectively.
Proceeds from the sales of investments in equity securities during 2019, 2018 and 2017 were $0.0 million, $46.2 million, and $0.0 million; gross gains of $0.0 million, $8.9 million, and $0.0 million and gross losses of $0.0 million, $0.0 million, and $0.0 million were realized on these sales in 2019, 2018 and 2017, respectively.
Realized capital gains (losses) are reported net of federal income taxes and amounts transferred to the IMR as follows for the years ended December 31:
201920182017
(In Thousands)
Realized capital gains (losses)$500  $5,987  $(1,948) 
Less amount transferred to (from) IMR (net of related taxes (benefits) of $471 in 2019, ($137) in 2018, and $573 in 2017)
1,771  (516) 1,066  
Less federal income tax expense (benefit) of realized capital gains (losses)
1,214  3,757  739  
Net realized capital gains (losses)$(2,485) $2,746  $(3,753) 
22

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Net investment income was generated from the following for the years ended December 31:
201920182017
(In Thousands)
Debt securities$108,033  $107,231  $110,198  
Equity securities1,213  1,987  1,692  
Mortgage loans6,293  6,141  6,149  
Policy loans3,100  3,712  3,757  
Cash, cash equivalents and short-term investments389  474  250  
Other invested assets16,400  1,515  878  
Other370  351  60  
Gross investment income135,798  121,411  122,984  
Investment expenses2,231  2,212  2,312  
Net investment income$133,567  $119,199  $120,672  
The Company’s investments in mortgage loans principally involve commercial real estate. At December 31, 2019, 34.2% of such mortgages, or $59.0 million, involved properties located in Tennessee and Massachusetts. Such investments consist primarily of first-mortgage liens on completed income-producing properties. The aggregate mortgage outstanding to any one borrower does not exceed $25.1 million. During 2019, the respective minimum and maximum lending rates for mortgage loans issued were 3.65% and 4.50%. At the issuance of a loan, the percentage of any one loan to value of security, exclusive of insured, guaranteed or purchase money mortgage did not exceed 80.0%. During 2019, the Company did not reduce interest rates on any outstanding mortgages.
23

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
3. Fair Values of Financial Instruments
Included in various investment-related line items in the financial statements are certain financial instruments carried at fair value. Other financial instruments are periodically measured at fair value such as when impaired or, for certain bonds and preferred stocks, when carried at the lower of cost or market.
The Company uses fair value measurements to record the fair value of certain assets and liabilities and to estimate the fair value of financial instruments not recorded at fair value but required to be disclosed at fair value. Certain financial instruments, particularly policyholder liabilities other than investment-type contracts, are excluded from this fair value discussion.
Fair value is defined as the price that would be received to sell an asset or transfer a liability in an orderly transaction between market participants at the measurement date. The Company’s financial assets and liabilities carried at fair value have been classified, for disclosure purposes, based on the following hierarchy that prioritizes inputs to valuation techniques used to measure fair value into three levels. The Company’s policy is to recognize transfers in and transfers out of levels at the beginning of the quarterly reporting period.
Level 1 - Quoted prices (unadjusted) in active markets for identical assets or liabilities. The Company’s Level 1 assets and liabilities primarily include exchange-traded equity securities and mutual funds, including those which are part of the Company’s separate account assets.
Level 2 - Inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. The Company’s Level 2 assets and liabilities primarily include municipal bonds which are part of the Company's separate account assets. The Company determined fair value through the use of third-party pricing services utilizing market observable inputs.
Level 3 - Significant unobservable inputs for the asset or liability. The Company does not have any significant assets or liabilities carried at fair value that meet the definition of Level 3.
Fair value estimates are made at a specific point in time, based on available market information and judgments about the financial instrument, including discount rates, estimates of timing, amount of expected future cash flows and the credit standing of the issuer. Such estimates do not consider the tax impact of the realization of unrealized gains or losses.
For Level 3 investments, the fair value estimates cannot be substantiated by comparison to independent markets. In addition, the disclosed fair value may not be realized in the immediate settlement of the financial instrument.
Certain investments utilize net asset value (NAV) as a practical expedient for fair value. These investments are reported separately from the hierarchy. Common stock utilizing NAV consists of an investment in a business development corporation as defined by the Investment Company Act of 1940. The investment can be sold or transferred with prior consent from the corporation. The NAV for this investment is $15.00. The Company does not intend to sell any investments utilizing NAV.
24

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
As described below, certain fair values are determined through the use of third-party pricing services. Management does not adjust prices received from third parties; however, the Company does analyze the third-party pricing services’ valuation methodologies and related inputs and performs additional evaluation to determine the appropriate level within the fair value hierarchy. The Company performs annual due diligence of third-party pricing services, which includes assessing the vendor’s valuation qualifications, control environment, analysis of asset class-specific valuation methodologies and understanding of market observable assumptions and unobservable assumptions, if any, employed in the valuation methodology. Care should be exercised in deriving conclusions about the Company’s business, its value or financial position based on the fair value information of financial instruments presented below. The following discussion describes the valuation methodologies utilized by the Company for assets and liabilities measured or disclosed at fair value.
Debt and Equity Securities
The fair values of debt securities and asset/mortgage-backed securities have been determined through the use of third-party pricing services utilizing market observable inputs. Private placement securities trading in less liquid or illiquid markets with limited or no pricing information are valued using either broker quotes or by discounting the expected cash flows using current market-consistent rates applicable to the yield, credit quality and maturity of each security.
The fair values of actively traded equity securities and exchange traded funds (including exchange traded funds with debt like characteristics) have been determined utilizing publicly quoted prices obtained from third-party pricing services. The fair values of certain equity securities for which no publicly quoted prices are available have been determined through the use of third-party pricing services utilizing market observable inputs. Actively traded mutual funds are valued using the net asset values of the funds.
Mortgage Loans
The fair values for mortgage loans, consisting principally of commercial real estate loans, are estimated using discounted cash flow analyses, using interest rates currently being offered for similar loans collateralized by properties with similar investment risk. The fair values for mortgage loans in default are established at the lower of the fair value of the underlying collateral less costs to sell or the carrying amount of the loan.
Cash, Cash Equivalents and Short-Term Investments
The fair values of cash, cash equivalents and short-term investments are based on quoted market prices or stated amounts.
Securities Lending Reinvested Collateral Assets
The fair values of securities lending reinvested collateral assets are determined through the use of third-party sources utilizing publicly quoted prices.
25

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Other Invested Assets
Other invested assets primarily include surplus debentures for which fair values have been determined through the use of third-party pricing services utilizing market observable inputs.
Assets Held in Separate Accounts
Assets held in separate accounts primarily include debt securities, equity securities, mutual funds and mortgage loans. The fair values of these assets have been determined using the same methodologies as similar assets held in the general account.
Life and Annuity Reserves for Investment-Type Contracts and Deposit Fund Liabilities
The fair value of liabilities for investment-type contracts is based on the present value of estimated liability cash flows, which are discounted using rates that incorporate risk-free rates and margins for the Company’s own credit spread and the riskiness of cash flows. Key assumptions to the cash flow model include the timing of policyholder withdrawals and the level of interest credited to contract balances. Fair values for insurance reserves are not required to be disclosed. However, the estimated fair values of all insurance reserves and investment contracts are taken into consideration in the Company’s overall management of interest rate risk.
Securities Lending Liability
The liability represents the Company’s obligation to return collateral related to securities lending transactions. The liability is short-term in nature and therefore, the fair value of the obligation approximates the carrying amount.
Separate Account Liabilities
Certain separate account liabilities are classified as investment contracts and are carried at an amount equal to the related separate account assets. Carrying value is a reasonable estimate of the fair value as it represents the exit value as evidenced by withdrawal transactions between contract holders and the Company.
26

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Assets and liabilities measured at fair value on a recurring basis are outlined below:
Assets/(Liabilities) Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2Level 3NAV
(In Thousands)
At December 31, 2019
Assets:
Common stocks, unaffiliated
$7,071  $5,331  $—  $—  $1,740  
Separate account assets*
402,051  368,819  33,232  —  —  
Total assets$409,122  $374,150  $33,232  $—  $1,740  
* Separate account assets measured at fair value in this table do not include assets backing market value adjusted annuities, which are held at amortized cost, with the exception of securities rated NAIC 6 where the security’s fair value is below amortized cost.
Assets/(Liabilities) Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2Level 3NAV
(In Thousands)
At December 31, 2018
Assets:
Common stocks, unaffiliated
$3,447  $27  $—  $—  $3,420  
Separate account assets*
365,277  334,089  31,188  —  —  
Total assets$368,724  $334,116  $31,188  $—  $3,420  
* Separate account assets measured at fair value in this table do not include assets backing market value adjusted annuities, which are held at amortized cost, with the exception of securities rated NAIC 6 where the security’s fair value is below amortized cost.
27

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2018, are as follows:
Beginning Asset/(Liability) as of January 1, 2018Total Realized/
Unrealized Gains
(Losses) Included in:
Purchases, Sales,
Issuances
and
Settlements
Transfers
Into
Level 3
Transfers
Out of
Level 3*
Ending Asset/(Liability) as of December 31, 2018
Net
Income
Surplus
(In Thousands)
Assets:
Common stocks, unaffiliated
$760  $—  $—  $—  $—  $(760) $—  
* Transfers out of Level 3 are due to utilizing net asset value.
The Company did not have any significant assets or liabilities measured at fair value on a nonrecurring basis as of December 31, 2019 and 2018.

The carrying amounts and fair values of the Company’s significant financial instruments follow:
December 31, 2019
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds
$2,495,289  $2,634,286  $3,569  $2,629,630  $1,087  $—  
Common stock, unaffiliated**
16,583  16,583  14,843  —  —  1,740  
Preferred stock
3,371  3,506  —  3,506  —  —  
Mortgage loans
172,483  180,460  —  —  180,460  —  
Cash, cash equivalents and short-term investments
74,495  74,501  74,501  —  —  —  
Other invested assets, surplus notes
3,100  3,762  —  3,762  —  —  
Securities lending reinvested collateral assets
40,713  40,713  40,713  —  —  —  
Separate account assets
1,487,072  1,548,461  375,112  1,114,480  58,869  —  
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(1,706,514) $(1,748,121) $—  $—  $(1,748,121) $—  
Securities lending liability(40,713) (40,713) —  (40,713) —  —  
Separate account liabilities*(1,064,271) (1,128,839) —  —  (1,128,839) —  
* Variable annuity contracts are considered insurance contracts and therefore, are not included in separate account liabilities for purposes of this disclosure.
** Includes FHLB common stock, which is held at cost.
28

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
December 31, 2018
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds
$2,601,505  $2,601,264  $3,478  $2,593,875  $3,911  $—  
Common stock, unaffiliated**
11,339  11,339  7,919  —  —  3,420  
Preferred stock
8,371  7,767  —  2,800  4,967  —  
Mortgage loans
136,448  135,375  —  —  135,375  —  
Cash, cash equivalents and short-term investments
21,483  21,484  21,484  —  —  —  
Other invested assets, surplus notes
3,118  3,438  —  3,438  —  —  
Securities lending reinvested collateral assets
—  —  —  —  —  —  
Separate account assets
1,543,190  1,539,210  333,342  1,148,808  57,060  —  
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(1,849,521) $(1,769,506) $—  $—  $(1,769,506) $—  
Securities lending liability—  —  —  —  —  —  
Separate account liabilities*(1,154,728) (1,076,708) —  —  (1,076,708) —  
* Variable annuity contracts are considered insurance contracts and therefore, are not included in separate account liabilities for purposes of this disclosure.
** Includes FHLB common stock, which is held at cost.
29

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
4. Related-Party Transactions
In the fourth quarter of 2018, the Company purchased $47.6 million of bonds in exchange for cash from Western and Southern.
The Company paid a $34.0 million ordinary dividend to Integrity in December 2017. The dividend was in the form of cash.
The Company did not have any amounts receivable from parent, subsidiaries and affiliates as of December 31, 2019 and 2018, respectively. The Company had $1.7 million and $2.1 million payable to parent, subsidiaries and affiliates as of December 31, 2019 and 2018, respectively. The terms of the settlement generally require that these amounts be settled in cash within 30 days.
Western and Southern guarantees the payment of the Company’s policyholder obligations. In the unlikely event the guarantee would be triggered, Western and Southern may be permitted to take control of the Company’s assets to recover all or a portion of the amounts paid under the guarantee.

5. Reinsurance
Certain premiums and benefits are ceded to other insurance companies under various reinsurance agreements. The ceded insurance agreements provide the Company with increased capacity to write larger risks and maintain its exposure to loss within its capital resources.
The effects of reinsurance on premiums, annuity considerations and deposit-type funds are as follows for the years ended December 31:
201920182017
(In Thousands)
Direct premiums$211,024  $250,112  $225,146  
Assumed premiums:
Affiliates—  —  —  
Nonaffiliates—  —  —  
Ceded premiums:
Affiliates—  —  —  
Nonaffiliates(1,107) (938) (708) 
Net premiums$209,917  $249,174  $224,438  
30

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The Company’s ceded reinsurance arrangements reduced certain other items in the accompanying financial statements by the following amounts as of and for the years ended December 31:
201920182017
(In Thousands)
Benefits paid or provided:
Affiliates$—  $—  $—  
Nonaffiliates906  323  95  
Policy and contract liabilities:
Affiliates—  —  —  
Nonaffiliates1,248  1,036  1,222  
Amounts recoverable on reinsurance contracts:
Affiliates
Nonaffiliates19  45  19  
In 2019, 2018 and 2017, the Company did not commute any ceded reinsurance nor did it enter into or engage in any agreement that reinsures policies or contracts that were in-force or had existing reserves as of the effective date of such agreements.
At December 31, 2019, the Company has no reserves ceded to unauthorized reinsurers. Amounts payable or recoverable for reinsurance on policy and contract liabilities are not subject to periodic or maximum limits. At December 31, 2019, the Company’s reinsurance recoverables are not material and no individual reinsurer owed the Company an amount that was equal to or greater than 3% of the Company’s capital and surplus.
Neither the Company nor any of its related parties, control directly or indirectly, any reinsurers with whom the Company conducts business. No policies issued by the Company have been reinsured with a foreign company, which is controlled, either directly or indirectly, by a party not primarily engaged in the business of insurance. The Company does not have any reinsurance agreements in effect under which the reinsurer may unilaterally cancel the agreement. At December 31, 2019, there are no reinsurance agreements in effect such that the amount of losses paid or accrued exceed the total direct premium collected. The Company remains obligated for amounts ceded in the event that the reinsurers do not meet their obligations.
There would be no reduction in surplus at December 31, 2019, if all reinsurance agreements were cancelled.

6. Federal Income Taxes
The Company is included in the consolidated federal income tax return of Western and Southern. The Company had a receivable (payable) from (to) Western and Southern in the amount of $(1.7) million and $0.1 million at December 31, 2019 and 2018, respectively. The tax years 2014 through 2019 remain subject to examination by major tax jurisdictions.
31

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The amount of federal income taxes incurred that will be available for recoupment at December 31, 2019; in the event of future capital losses is $1.7 million, $6.1 million, and $1.5 million from 2019, 2018 and 2017, respectively.
The components of the net deferred tax asset (liability) at December 31 are as follows:
12/31/2019
(In Thousands)
(1)(2)(3)
  (Col 1+2)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$25,762  $3,862  $29,624  
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)25,762  3,862  29,624  
(d)Deferred tax assets nonadmitted16,669  —  16,669  
(e)Subtotal net admitted deferred tax assets (c - d)9,093  3,862  12,955  
(f)Deferred tax liabilities3,085  579  3,664  
(g)
Net admitted deferred tax asset/(net deferred tax liability) (e - f)
$6,008  $3,283  $9,291  
12/31/2018
(In Thousands)
(4)(5)(6)
  (Col 4+5)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$23,892  $3,762  $27,654  
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)23,892  3,762  27,654  
(d)Deferred tax assets nonadmitted16,061  2,966  19,027  
(e)Subtotal net admitted deferred tax assets (c - d)7,831  796  8,627  
(f)Deferred tax liabilities2,940  795  3,735  
(g)
Net admitted deferred tax asset/(net deferred tax liability) (e - f)
$4,891  $ $4,892  

32

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$1,870  $100  $1,970  
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)1,870  100  1,970  
(d)Deferred tax assets nonadmitted608  (2,966) (2,358) 
(e)Subtotal net admitted deferred tax assets (c - d)1,262  3,066  4,328  
(f)Deferred tax liabilities145  (216) (71) 
(g)
Net admitted deferred tax asset/(net deferred tax liability) (e - f)
$1,117  $3,282  $4,399  
12/31/2019
(In Thousands)
(1)(2)(3)
  (Col 1+2)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$—  $3,841  $3,841  
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
5,450  —  5,450  
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date.
5,450  —  5,450  
2. Adjusted gross deferred tax assets allowed per limitation threshold.
 XXX   XXX  48,727  
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
3,643  21  3,664  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$9,093  $3,862  $12,955  

33

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
12/31/2018
(In Thousands)
(4)(5)(6)
  (Col 4+5)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$—  $ $ 
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
5,144  —  5,144  
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date.
5,144  —  5,144  
2. Adjusted gross deferred tax assets allowed per limitation threshold.
XXX  XXX  50,117  
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
2,687  795  3,482  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$7,831  $796  $8,627  
Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss$—  $3,840  $3,840  
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
306  —  306  
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date.
306  —  306  
2. Adjusted gross deferred tax assets allowed per limitation threshold.
XXX  XXX  (1,390) 
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
956  (774) 182  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$1,262  $3,066  $4,328  



34

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
20192018
(a)Ratio percentage used to determine recovery period and threshold limitation amount953%893%
12/31/2019
(1)(2)
  
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$25,762$3,862
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%12.97%
(c)Net admitted adjusted gross DTAs amount$9,093$3,862
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%29.65%
12/31/2018
(3)(4)
  
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$23,892$3,762
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%0.00%
(c)Net admitted adjusted gross DTAs amount$7,831$796
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%0.01%
Change
(5)(6)
(Col 1-3) (Col 2-4)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$1,870$100
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%12.97%
(c)Net admitted adjusted gross DTAs amount$1,262$3,066
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%29.64%
The Company's tax planning strategies do not include the use of reinsurance.


35

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Current income taxes incurred consist of the following major components:
12/31/201912/31/201812/31/2017
(1)Current income tax(In Thousands)
(a)Federal$10,163  $9,148  $16,485  
(b)Foreign—  —  —  
(c)Subtotal10,163  9,148  16,485  
(d)Federal income tax on net capital gains1,214  3,757  739  
(e)Utilization of capital loss carryforwards—  —  —  
(f)Other—  —  —  
(g)Federal and foreign income taxes incurred$11,377  $12,905  $17,224  
(1)(2)(3)
  (Col 1-2)
(2)Deferred tax assets:12/31/201912/31/2018Change
(a)Ordinary(In Thousands)
(1) Discounting of unpaid losses$—  $—  $—  
(2) Unearned premium revenue—  —  —  
(3) Policyholder reserves21,258  19,080  2,178  
(4) Investments404  976  (572) 
(5) Deferred acquisition costs4,096  3,836  260  
(6) Policyholder dividends accrual—  —  —  
(7) Fixed assets—  —  —  
(8) Compensation and benefits accrual—  —  —  
(9) Pension accrual—  —  —  
(10) Receivables - nonadmitted —   
(11) Net operating loss carryforward—  —  —  
(12) Tax credit carryforward—  —  —  
(13) Other—  —  —  
         (99) Subtotal25,762  23,892  1,870  
(b)Statutory valuation allowance adjustment—  —  —  
(c)Nonadmitted16,669  16,061  608  
(d)Admitted ordinary deferred tax assets (2a99 - 2b - 2c)9,093  7,831  1,262  
(e)Capital
(1) Investments3,862  3,762  100  
(2) Net capital loss carryforward—  —  —  
(3) Real estate—  —  —  
(4) Other—  —  —  
       (99) Subtotal3,862  3,762  100  
(f)Statutory valuation allowance adjustment—  —  —  
(g)Nonadmitted—  2,966  (2,966) 
(h)Admitted capital deferred tax assets (2e99- 2f - 2g)3,862  796  3,066  
(i)Admitted deferred tax assets (2d + 2h)$12,955  $8,627  $4,328  

36

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
(1)(2)(3)
  (Col 1-2)
12/31/201912/31/2018Change
(3)Deferred tax liabilities:(In Thousands)
(a)Ordinary
(1) Investments$2,579  $2,310  $269  
(2) Fixed assets—  —  —  
(3) Deferred and uncollected premium—  —  —  
(4) Policyholder reserves506  630  (124) 
(5) Other—  —  —  
         (99) Subtotal3,085  2,940  145  
(b)Capital
(1) Investments579  795  (216) 
(2) Real estate—  —  —  
(3) Other—  —  —  
         (99) Subtotal579  795  (216) 
(c)Deferred tax liabilities (3a99 + 3b99)$3,664  $3,735  $(71) 
(4)Net deferred tax assets/liabilities (2i - 3c) $9,291  $4,892  $4,399  
Among the more significant book-to-tax adjustments were the following:
12/31/2019Effective
Tax Rate
12/31/2018Effective
Tax Rate
12/31/2017Effective
Tax Rate
(In Thousands)(In Thousands)(In Thousands)
 Provision computed at statutory rate $10,236  21.00 %$7,936  21.00 %$1,477  35.00 %
 Dividends received deduction (229) (0.47) (377) (1.00) (732) (17.33) 
 Tax credits (101) (0.21) (210) (0.56) (11) (0.27) 
 Other 483  0.99   0.01  152  3.59  
 Change in federal tax rate
—  —  660  1.75  14,318  339.18  
Total statutory income taxes$10,389  21.31 %$8,014  21.20 %$15,204  360.17 %
 Federal taxes incurred $11,377  23.34 %$12,905  34.15 %$17,224  408.03 %
 Change in net deferred income taxes (988) (2.03) (4,891) (12.95) (2,020) (47.86) 
Total statutory income taxes$10,389  21.31 %$8,014  21.20 %$15,204  360.17 %
At December 31, 2019, the Company had $0.0 of net operating loss carryforwards, net capital loss carryforwards and tax credit carry forwards; the company had $0.0 of deferred tax liabilities that are not recognized.
On December 22, 2017, the Tax Cuts and Jobs Act (the Tax Act) was enacted, significantly changing the US income tax law. Among the provisions of the Tax Act were the establishment of a flat corporate income tax rate of 21%, a general repeal of net operating loss carrybacks and a reduction in the maximum deduction for net operating loss carryforwards arising in tax years beginning after 2017, and the elimination or reduction of certain deductions, exclusions and credits.
The Company has recognized the effects of the tax rate change on its deferred tax balances in its December 31, 2017 financial statements. The re-measurement of deferred tax assets and liabilities resulted in a reduction of net deferred tax assets of $11.1 million, of which ($3.2) million and $14.3 million was recorded as an adjustment to the change in net unrealized capital gains (losses) and the change in net deferred income tax, respectively. Upon issuance of the Company’s financial statements for the
37

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
year ended December 31, 2017, the Company’s accounting for certain income tax effects of the Tax Act was incomplete; however, the Company included reasonable estimates of these balances in its re-measurement of deferred tax assets and liabilities. At December 31, 2018, the Company has completed its accounting for all the enactment-date income tax effects of the Tax Act.

7. Capital and Surplus
The Company is required by statutory regulations to meet minimum risk-based capital standards. Risk-based capital is a method of measuring the minimum amount of capital appropriate for an insurance company to support its overall business operations in consideration of its size and risk profile. At December 31, 2019 and 2018, the Company exceeded the minimum risk-based capital.
The ability of the Company to pay dividends is limited by state insurance laws. Under New York insurance laws, the Company may pay dividends, without the approval of the New York Insurance Superintendent, provided those dividends do not exceed (when added to the other dividends paid in the preceding 12 months) the lesser of (i) 10% of the Company's surplus as of the prior December 31, or (ii) the Company's net gain from operations for the immediately preceding calendar year, not including realized capital gains. Dividends are noncumulative. As of December 31, 2019, the Company has $37.7 million eligible for dividends in 2020.

8. Commitments and Contingencies
The Company is named as a defendant in various legal actions arising principally from claims made under insurance policies and contracts. The Company believes the resolution of these actions will not have a material effect on the Company’s financial position or results of operations.
At December 31, 2019, the Company does not have any material lease agreements for office space or equipment.
At December 31, 2019 the Company has future commitments to provide additional capital contributions of $12.3 million to investments in joint ventures, limited partnerships and limited liability companies.
38

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
9. Life and Annuity Reserves and Deposit-Type Contract Liabilities
At December 31, 2019, the Company’s general and separate account annuity reserves and deposit fund liabilities that are subject to discretionary withdrawal (with adjustment), subject to discretionary withdrawal (without adjustment), and not subject to discretionary withdrawal provisions are summarized as follows:
Individual AnnuitiesGeneral AccountSeparate Account
With Guarantees
Separate Account
Non-guaranteed
TotalPercent
(In Thousands)
Subject to discretionary withdrawal:
With fair value adjustment$152  $1,064,271  $—  $1,064,423  30.1 %
At book value less current surrender charge of 5% or more
707,176  —  —  707,176  20.0  
At fair value—  —  363,165  363,165  10.3  
Total with adjustment or at fair value
707,328  1,064,271  363,165  2,134,764  60.4  
Subject to discretionary withdrawal at book value without adjustment (minimal or no charge or adjustment)
845,097  —  —  845,097  23.9  
Not subject to discretionary withdrawal
557,456  —  —  557,456  15.7  
Total individual annuity reserves (before reinsurance)
2,109,881  1,064,271  363,165  3,537,317  100.0 %
Reinsurance ceded
—  —  —  —  
Net individual annuity reserves
$2,109,881  $1,064,271  $363,165  $3,537,317  
Amount subject to greater than a 5% surrender charge that will be subject to minimal or no surrender charge after the statement date
$29,018  $—  $—  $29,018  
Deposit-type contracts (no life contingencies)General AccountSeparate Account
With Guarantees
Separate Account
Non-guaranteed
TotalPercent
(In Thousands)
Subject to discretionary withdrawal at book value without adjustment (minimal or no charge or adjustment)
$1,005  $—  $—  $1,005  0.6 %
Not subject to discretionary withdrawal
154,426  —  —  154,426  99.4  
Total deposit-type contract liability (before reinsurance)
155,431  —  —  155,431  100.0 %
Reinsurance ceded
—  —  —  —  
Total deposit-type contract liability
$155,431  $—  $—  $155,431  
Interest rate changes may have temporary effects on the sale and profitability of annuity products offered by the Company. Although the rates offered by the Company are adjustable in the long-term, in the short-term they may be subject to contractual and competitive restrictions, which may prevent timely adjustment. The Company’s management constantly monitors interest rates with respect to a spectrum of product durations and sells annuities that permit flexible responses to interest rate changes as part of the
39

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Company’s management of interest spreads. However, adverse changes in investment yields on invested assets will affect the earnings on those products with a guaranteed return.
At December 31, 2019, the Company's general and separate account life insurance account values, cash value, and reserves for policies subject to discretionary withdrawal, not subject to discretionary withdrawal, or with no cash value are summarized as follows:
General AccountSeparate Account - Guaranteed and Nonguaranteed
Account ValueCash ValueReserveAccount ValueCash ValueReserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value$—  $—  $—  $—  $—  $—  
Universal life208,677  219,625  235,236  —  —  —  
Universal life with secondary guarantees
—  —  —  —  —  —  
Indexed universal life—  —  —  —  —  —  
Indexed universal life with secondary guarantees
—  —  —  —  —  —  
Indexed life—  —  —  —  —  —  
Other permanent cash value life insurance
—  184  196  —  —  —  
Variable life—  —  —  —  —  —  
Variable universal life34,892  34,892  34,892  
Miscellaneous reserves—  —  —  —  —  —  
Not subject to discretionary withdrawal or no cash values:
Term policies without cash valueXXX  XXX  —  XXX  XXX  —  
Accidental death benefitsXXX  XXX  —  XXX  XXX  —  
Disability - active livesXXX  XXX  —  XXX  XXX  —  
Disability - disabled livesXXX  XXX  —  XXX  XXX  —  
Miscellaneous reservesXXX  XXX  45,000  XXX  XXX  —  
Total life reserves (before reinsurance)208,677  219,809  280,432  34,892  34,892  34,892  
Reinsurance Ceded—  —  1,051  —  —  —  
Net life reserves$208,677  $219,809  $279,381  $34,892  $34,892  $34,892  
Federal Home Loan Bank
The Company is a member of the FHLB of Cincinnati. Through its membership, the Company has the ability to conduct business activity (borrowings) with the FHLB. The Company’s strategy is to utilize FHLB funds to increase profitability. The Company has determined the actual/estimated maximum borrowing capacity as $110.0 million. The Company calculated this amount after a review of its pledgeable assets (both pledged and unpledged) and after applying the respective FHLB borrowing haircuts.
40

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
December 31
20192018
(In Thousands)
Membership stock - Class A (not eligible for redemption)$7,188  $5,569  
Membership stock - Class B—  —  
Activity stock2,323  2,323  
Excess stock—  —  
Aggregate total$9,511  $7,892  
Actual or estimated borrowing capacity as determined by the insurer$110,000  $125,000  

Collateral Pledged to FHLB – General Account:
20192018
Fair ValueCarrying ValueAggregate Total BorrowingBorrowed at Time of Maximum CollateralFair ValueCarrying ValueAggregate Total BorrowingBorrowed at Time of Maximum Collateral
(In Thousands)
Total as of reporting date
$108,686  $105,184  $70,600  XXX  $122,986  $122,815  $81,550  XXX  
Maximum during reporting period
$122,216  $121,485  XXX  $81,550  $142,560  $141,472  XXX  $97,780  

Borrowing from FHLB - General Account:
20192018
At Reporting DateReserves Established at Reporting DateMaximum Amount During PeriodAt Reporting DateReserves Established at Reporting Date
(In Thousands)
Funding agreements$70,600  $70,690  $82,600  $81,550  $81,712  
Debt—  XXX—  —  XXX  
Aggregate total$70,600  $70,690  $82,600  $81,550  $81,712  

The Company does not have any prepayment obligations under these FHLB borrowing arrangements.
41

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
10. Separate Accounts
The Company’s guaranteed separate account consists of non-indexed, guaranteed rate options that include market value adjustments. The guaranteed rate options are sold in fixed annuity products and as investment options within the Company’s variable annuity products. These guaranteed rate options carry a minimum interest guarantee based on the guarantee period selected by the policyholder. The fixed annuity products offered provide a death benefit equal to the account value. The fixed investment options within the Company’s variable annuity products provide the death benefits listed below for variable annuities.
The Company’s nonguaranteed separate accounts consist of subaccounts available through variable annuities and group variable universal life insurance. The net investment experience of each subaccount is credited directly to the policyholder and can be positive or negative. The variable annuities include guaranteed minimum death benefits that vary by product and include optional death benefits available on some products. The death benefits offered by the Company include the following: account value, return of premium paid, a death benefit that is adjusted after seven years to the current account value, and a death benefit that is adjusted annually to the current account value. Some variable annuities also provide living benefits, which include guaranteed accumulation amounts on a date certain, guaranteed minimum withdrawal amounts and guaranteed minimum lifetime withdrawal amounts. The death benefit under the group variable universal life insurance policies may vary with the investment performance of the underlying investments in the separate accounts.
To compensate the general account for risk taken, the separate accounts paid risk charges of $1.2 million, $1.4 million, $1.1 million, $0.9 million and $0.9 million in 2019, 2018, 2017, 2016, and 2015, respectively. The Company’s general account paid $0.0 million, $0.2 million, $0.1 million, $0.1 million and $0.1 million towards separate account guarantees in 2019, 2018, 2017, 2016, and 2015, respectively.
42

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Information regarding the separate accounts of the Company as of and for the year ended December 31, 2019, is as follows:
Separate Accounts With Guarantees
Nonindexed Guaranteed Less Than/ Equal to 4%Nonindexed Guaranteed More
Than 4%
Nonguaranteed Separate AccountsTotal
(In Thousands)
Premiums, considerations or deposits$39,032  $2,334  $12,335  $53,701  
Reserves for separate accounts with assets at:
Fair value$—  $—  $398,056  $398,056  
Amortized cost1,062,057  2,214  —  1,064,271  
Total reserves$1,062,057  $2,214  $398,056  $1,462,327  
Reserves for separate accounts by withdrawal characteristics:
Subject to discretionary withdrawal:
With fair value adjustment$1,062,057  $2,214  $—  $1,064,271  
At book value without fair value adjustment and with current surrender charge of 5% or more
—  —  —  —  
At fair value—  —  398,056  398,056  
At book value without fair value adjustment and with current surrender charge of less than 5%
—  —  —  —  
Subtotal1,062,057  2,214  398,056  1,462,327  
Not subject to discretionary withdrawal—  —  —  —  
Total separate accounts reserves$1,062,057  $2,214  $398,056  $1,462,327  
43

National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
A reconciliation of the amounts transferred to and from the separate accounts for the year ended December 31, 2019, is presented below:
2019
(In Thousands)
Transfers as reported in the Summary of Operations of the Separate Accounts Statement:
Transfers to separate accounts$53,701  
Transfers from separate accounts221,572  
Net transfers to (from) separate accounts(167,871) 
Reconciling adjustments:
Policy deductions and other expenses64  
Other changes in surplus in separate account statement—  
Other account adjustments412  
Transfers as reported in the Summary of Operations of the Company$(167,395) 

44










STATUTORY-BASIS FINANCIAL STATEMENTS

The Western and Southern Life Insurance Company
Years Ended December 31, 2019, 2018 and 2017
With Report of Independent Auditors




The Western and Southern Life Insurance Company

Statutory-Basis Financial Statements

Years Ended December 31, 2019, 2018 and 2017



Contents
Report of Independent Auditors
Financial Statements
Balance Sheets (Statutory-Basis)
Statements of Operations (Statutory-Basis)
Statements of Changes in Capital and Surplus (Statutory-Basis)
Statements of Cash Flow (Statutory-Basis)
Notes to Financial Statements (Statutory-Basis)








Report of Independent Auditors

The Board of Directors
The Western and Southern Life Insurance Company

We have audited the accompanying statutory-basis financial statements of The Western and Southern Life Insurance Company (the Company), which comprise the balance sheets as of December 31, 2019 and 2018, and the related statements of operations, changes in capital and surplus, and cash flow for each of the three years in the period ended December 31, 2019, and the related notes to the financial statements.

Management’s Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these financial statements in conformity with accounting practices prescribed or permitted by the Ohio Department of Insurance. Management also is responsible for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free of material misstatement, whether due to fraud or error.

Auditor’s Responsibility
Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits in accordance with auditing standards generally accepted in the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.




1


Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles
As described in Note 1 to the statutory-basis financial statements, the Company prepared these financial statements using accounting practices prescribed or permitted by the Ohio Department of Insurance, which is a basis of accounting other than U.S. generally accepted accounting principles. The variances between such practices and U.S. generally accepted accounting principles and the effects on the accompanying financial statements are described in Note 1.

Adverse Opinion on U.S. Generally Accepted Accounting Principles
In our opinion, because of the significance of the matter described in the Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles paragraph, the statutory-basis financial statements referred to above do not present fairly, in conformity with U.S. generally accepted accounting principles, the financial position of the Company at December 31, 2019 and 2018, or the results of its operations or its cash flows for each of the three years in the period ended December 31, 2019.

Opinion on Statutory-Basis of Accounting
In our opinion, the statutory-basis financial statements referred to above present fairly, in all material respects, the financial position of the Company at December 31, 2019 and 2018, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2019, on the basis of accounting described in Note 1.


/s/ Ernst & Young LLP
Cincinnati, Ohio
April 20, 2020
2

The Western and Southern Life Insurance Company
Balance Sheets (Statutory-Basis)


December 31
20192018
Admitted assets(In Thousands)
Cash and invested assets:
Debt securities$2,831,739  $2,937,451  
Preferred and common stocks918,600  717,423  
Investments in common stocks of subsidiaries3,594,940  3,193,138  
Mortgage loans68,898  59,146  
Policy loans158,711  161,223  
Real estate:
Properties held for the production of income2,888  3,193  
Properties occupied by the Company21,718  23,729  
Cash, cash equivalents and short-term investments77,542  87,913  
Receivable for securities1,429  1,581  
Derivatives 7,820   
Receivable for collateral on derivatives41,680  —  
Securities lending reinvested collateral assets27,635  54,253  
Other invested assets1,778,070  1,643,940  
Total cash and invested assets9,531,670  8,882,991  
Investment income due and accrued38,569  40,335  
Premiums deferred and uncollected49,759  50,247  
Net deferred income tax asset94,540  139,106  
Receivables from parent, subsidiaries and affiliates33,220  31,061  
Other admitted assets13,763  7,758  
Separate account assets1,141,599  961,136  
Total admitted assets$10,903,120  $10,112,634  
Liabilities and capital and surplus
Liabilities:
Policy and contract liabilities:
Life and annuity reserves$2,717,714  $2,701,370  
Accident and health reserves267,615  262,004  
Liability for deposit-type contracts204,659  213,579  
Policy and contract claims44,662  39,863  
Dividends payable to policyholders40,505  38,196  
Premiums received in advance4,026  3,512  
Total policy and contract liabilities3,279,181  3,258,524  
General expense due and accrued38,151  36,243  
Current federal income taxes payable9,601  45,520  
Transfer to (from) separate accounts due and accrued, net(15) (25) 
Asset valuation reserve324,838  272,020  
Interest maintenance reserve59,151  59,048  
Other liabilities304,372  247,436  
Pension liability23,536  30,893  
Liability for postretirement benefits other than pensions166,887  155,942  
Derivatives 48,246  —  
Payable for securities lending79,589  108,841  
Separate account liabilities1,141,599  961,136  
Total liabilities5,475,136  5,175,578  
Capital and surplus:
Common stock, $1 par value, authorized 2,500 shares,
issued and outstanding 2,500 shares
2,500  2,500  
Surplus Notes497,519  —  
Paid-in surplus372,103  372,103  
Accumulated surplus4,555,862  4,562,453  
Total capital and surplus5,427,984  4,937,056  
Total liabilities and capital and surplus$10,903,120  $10,112,634  
See accompanying notes.
3

The Western and Southern Life Insurance Company
Statements of Operations (Statutory-Basis)


Year Ended December 31
201920182017
(In Thousands)
Premiums and other revenues:
Premiums and annuity considerations$231,773  $237,054  $246,746  
Net investment income479,104  466,221  539,164  
Considerations for supplementary contracts with life contingencies —  —  
Amortization of the interest maintenance reserve5,906  5,728  3,815  
Commissions and expenses on reinsurance ceded1,029  981  932  
Miscellaneous income adjustment - termination of reinsurance agreement
—  (694,579) —  
Other revenues2,042  153  79  
Total premiums and other revenues719,863  15,558  790,736  
Benefits paid or provided:
Death benefits143,563  145,842  143,503  
Annuity benefits50,066  79,245  146,297  
Disability and accident and health benefits15,580  18,298  17,316  
Surrender benefits53,256  64,673  71,352  
Payments on supplementary contracts with life contingencies350  393  441  
Other benefits4,619  5,047  2,916  
Increase in policy reserves and other policyholders’ funds28,128  28,129  39,793  
Total benefits paid or provided295,562  341,627  421,618  
Insurance expenses and other deductions:
Commissions19,811  20,400  23,753  
Commissions and expenses on reinsurance assumed—  878  1,214  
General expenses157,130  134,141  134,399  
Net transfers to (from) separate account(50,204) (49,514) (101,619) 
Reserve adjustments on reinsurance assumed(103) (43,412) (71,901) 
Miscellaneous expense adjustment - termination of reinsurance agreement
—  (694,579) —  
Other deductions60,564  3,973  52,016  
Total insurance expenses and other deductions187,198  (628,113) 37,862  
Gain (loss) from operations before dividends to policyholders, federal income tax expense, and net realized capital gains (losses)
237,103  302,044  331,256  
Dividends to policyholders54,964  52,121  51,964  
Gain (loss) from operations before federal income tax expense and net realized capital gains (losses)
182,139  249,923  279,292  
Federal income tax expense (benefit), excluding tax on capital gains
25,523  39,879  12,111  
Gain (loss) from operations before net realized capital gains (losses)
156,616  210,044  267,181  
Net realized capital gains (losses) (excluding gains (losses) transferred to IMR and capital gains tax)
2,229  205,080  2,557  
Net income (loss)$158,845  $415,124  $269,738  
See accompanying notes.
4

The Western and Southern Life Insurance Company
Statements of Changes in Capital and Surplus (Statutory-Basis)


Common
Stock
Surplus Notes and Paid-In
Surplus
Accumulated SurplusTotal Capital
and Surplus
(In Thousands)
Balance, January 1, 2017$1,000  $55,003  $4,759,528  $4,815,531  
Net income (loss)—  —  269,738  269,738  
Change in net deferred income tax—  —  (103,027) (103,027) 
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($31,715))
—  —  126,689  126,689  
Net change in nonadmitted assets and related items
—  —  (64,589) (64,589) 
Change in asset valuation reserve
—  —  (32,481) (32,481) 
  Change in unrecognized post retirement benefit obligation
—  —  30,991  30,991  
 Capital contribution—  57,100  —  57,100  
Correction of traditional life reserves
—  —  (613) (613) 
Balance, December 31, 20171,000  112,103  4,986,236  5,099,339  
Net income (loss)—  —  415,124  415,124  
Change in net deferred income tax—  —  165,518  165,518  
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($57,122))
—  —  (266,672) (266,672) 
Change in net unrealized foreign exchange capital gain (loss)
—  —  (1,770) (1,770) 
Change in reserve on account of change in valuation basis
—  —  (692) (692) 
Net change in nonadmitted assets and related items—  —  (651,086) (651,086) 
Change in asset valuation reserve—  —  101,848  101,848  
Change in unrecognized post retirement benefit obligation
—  —  11,947  11,947  
Issuance of common stock1,500  —  —  1,500  
Capital contribution
—  260,000  —  260,000  
Trademark license agreement adjustment—  —  (198,000) (198,000) 
Balance, December 31, 20182,500  372,103  4,562,453  4,937,056  
Net income (loss)—  —  158,845  158,845  
Change in net deferred income tax—  —  (131,377) (131,377) 
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($2,224))
—  —  125,187  125,187  
Change in net unrealized foreign exchange capital gain (loss)
—  —  1,562  1,562  
Change in surplus notes—  497,519  —  497,519  
Net change in nonadmitted assets and related items—  —  149,208  149,208  
Change in asset valuation reserve—  —  (52,818) (52,818) 
Cumulative effects of change in accounting principle—  —  2,103  2,103  
Dividends to stockholder—  —  (260,000) (260,000) 
Change in unrecognized post retirement benefit obligation
—  —  699  699  
Balance, December 31, 2019$2,500  $869,622  $4,555,862  $5,427,984  
See accompanying notes.
5

The Western and Southern Life Insurance Company
Statements of Cash Flow (Statutory-Basis)


Year Ended December 31
201920182017
(In Thousands)
Operating activities
Premiums collected net of reinsurance$233,959  $239,541  $249,358  
Net investment income received314,302  412,553  509,990  
Benefits paid(268,636) (334,477) (387,279) 
Net transfers from (to) separate accounts50,214  49,504  101,916  
Commissions and expense paid(169,848) (89,719) (77,257) 
Dividends paid to policyholders(52,655) (52,582) (55,732) 
Federal income taxes recovered (paid)(60,149) (32,434) (52,260) 
Other, net1,071  1,032  1,010  
Net cash from (for) operations48,258  193,418  289,746  
Investing activities
Proceeds from investments sold, matured or repaid:
Debt securities321,508  2,285,224  782,780  
Preferred and common stocks553,991  1,152,289  481,055  
Mortgage loans1,041  11,323  15,501  
Real estate1,400  —  476  
Other invested assets460,664  337,964  245,518  
Net gains (losses) on cash, cash equivalents and short-term investments
37  90  (23) 
Miscellaneous proceeds26,770  8,357  19,962  
Net proceeds from investments sold, matured or repaid1,365,411  3,795,247  1,545,269  
Cost of investments acquired:
Debt securities(309,030) (1,660,008) (885,797) 
Preferred and common stocks(710,369) (2,047,721) (575,188) 
Mortgage loans(10,793) (21,240) (7,076) 
Real estate(1,121) (678) (791) 
Other invested assets(517,164) (265,138) (315,724) 
Miscellaneous applications(70,541) (15,608) (44,456) 
Total cost of investments acquired(1,619,018) (4,010,393) (1,829,032) 
Net change in policy and other loans2,512  3,483  2,298  
Net cash from (for) investments(251,095) (211,663) (281,465) 
Financing activities
Surplus notes, capital notes497,435  —  —  
Capital and paid in surplus, less treasury stock—  261,500  57,100  
Net deposits on deposit-type contract funds and other insurance liabilities
(8,920) (11,020) (6,033) 
Dividends paid to stockholder
260,000  —  —  
Other cash provided (applied)(36,049) (375,272) 22,907  
Net cash from (for) financing and miscellaneous sources192,466  (124,792) 73,974  
Net change in cash, cash equivalents and short-term investments(10,371) (143,037) 82,255  
Cash, cash equivalents and short-term investments:
Beginning of year87,913  230,950  148,695  
End of year$77,542  $87,913  $230,950  
Cash flow information for noncash transactions:
Contribution to Columbus Life Insurance Company in the form of common stock$(29,962) $—  $—  
Contribution to Gerber Life Insurance in the form of debt securities & common stock
(193,759) —  —  
Contribution to Integrity Life Insurance Company in the form of common stock—  (245,700) —  
See accompanying notes.
6

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017

1. Nature of Operations and Significant Accounting Policies
The Western and Southern Life Insurance Company (the Company) is a stock life insurance company that offers primarily individual traditional and whole life insurance policies. The Company is licensed in 46 states and the District of Columbia. For the year ended December 31, 2019, approximately 68.6% of the gross premiums and annuity considerations for the Company were derived from California, Illinois, Indiana, North Carolina, Ohio, and Pennslyvania. The Company is domiciled in Ohio. The Company is an indirect, wholly-owned subsidiary of Western & Southern Mutual Holding Company (Mutual Holding), a mutual holding company formed pursuant to the insurance regulations of the State of Ohio. Ohio law requires Mutual Holding to hold at least a majority voting interest in the Company. Currently, Mutual Holding indirectly holds 100% of the voting interest through Western & Southern Financial Group, Inc. (WSFG), its wholly-owned subsidiary. The Company wholly owns the following insurance entities: Western-Southern Life Assurance Company (WSLAC), Columbus Life Insurance Company (Columbus Life), Integrity Life Insurance Company (Integrity) and Gerber Life Insurance Company (Gerber Life). Integrity Life Insurance Company wholly owns National Integrity Life Insurance Company (National).
State regulatory authorities have powers relating to granting and revoking licenses to transact business, the licensing of agents, the regulation of premium rates and trade practices, the form and content of insurance policies, the content of advertising material, financial statements and the nature of permitted practices.
Included within the financial statements, the Company has established and operates a closed block for the benefit of holders of most participating individual ordinary and weekly industrial life insurance policies issued on or before the formation of Mutual Holding in 2000 (the Closed Block). Assets have been allocated to the Closed Block in an amount that is expected to produce cash flows which, together with anticipated revenue from the policies included in the Closed Block, are reasonably expected to be sufficient to support the Closed Block policies, the continuation of policyholder dividends, in aggregate, in accordance with the 2000 dividend scale if the experience underlying such scale continues, and for appropriate adjustments in the dividend scale if the experience changes. Invested assets allocated to the Closed Block consist primarily of high-quality debt securities, mortgage loans, policy loans, short-term investments, other invested assets, and securities lending reinvested collateral. Invested assets of $1,993.5 million and $2,034.6 million were allocated to the Closed Block as of December 31, 2019 and 2018, respectively. The assets allocated to the Closed Block inure solely for the benefit of the Closed Block policyholders and will not revert to the benefit of the Company. The purpose of the Closed Block is to protect the policy dividend expectations of these policies after the formation of Mutual Holding. The Closed Block will continue in effect until the last policy in the Closed Block is no longer in force.
Use of Estimates
The preparation of statutory-basis financial statements requires management to make estimates and assumptions that affect amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates.
7

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Basis of Presentation
The accompanying financial statements of the Company have been prepared in conformity with accounting practices prescribed or permitted by the Ohio Department of Insurance (the Department). The National Association of Insurance Commissioners’ (NAIC) Accounting Practices and Procedures Manual (NAIC SAP or SSAP) has been adopted as a component of prescribed or permitted practices by the State of Ohio. These practices differ in some respects from U.S. generally accepted accounting principles (GAAP). The more significant differences follow.
Investments
Investments in debt securities and mandatory redeemable preferred stocks are reported at amortized cost or fair value based on the NAIC’s rating; for GAAP, such fixed maturity investments are designated at purchase as held-to-maturity, trading or available-for-sale. Held-to-maturity fixed investments are reported at amortized cost, and the remaining fixed maturity investments are reported at fair value with unrealized holding gains and losses reported in the statement of operations for those designated as trading and as a separate component of other comprehensive income (loss) for those designated as available-for-sale.
All single-class and multiclass mortgage-backed/asset-backed securities (e.g., CMOs) are adjusted for the effects of changes in prepayment assumptions on the related accretion of discount or amortization of premium of such securities using the retrospective method. The prospective method is used to determine amortized cost for securities that experience a decline that is deemed to be other-than-temporary. Securities that are in an unrealized loss position which the Company intends to sell, or does not have the intent and ability to hold until recovery, are written down to fair value as a realized loss. Securities that are in an unrealized loss position which the Company has the intent and ability to hold until recovery are written down to the extent the present value of expected future cash flows using the security’s effective yield is lower than the amortized cost. For GAAP purposes, all securities, purchased or retained, that represent beneficial interests in securitized assets (e.g., CMO, CBO, CDO, CLO, MBS and ABS securities), other than high credit quality securities, are adjusted using the prospective method when there is a change in estimated future cash flows. If it is determined that a decline in fair value is other-than-temporary, the cost basis of the security is written down to the extent the present value of expected future cash flows using the security’s effective yield is lower than the amortized cost. If high credit quality securities are adjusted, the retrospective method is used.
The Company monitors other investments to determine if there has been an other-than-temporary decline in fair value. Factors that management considers for each identified security include the following:
The extent and length of time the fair value has been below the book/adjusted carrying value;
The reasons for the decline in value;
Specific credit issues related to the issuer and current economic conditions, including the current and future impact of any specific events;
For structured investments (e.g., residential mortgage-backed securities, commercial mortgage-backed securities, asset-backed securities and other structured investments), factors such as overall deal structure and the Company’s position within the structure, quality of underlying collateral, delinquencies and defaults, loss severities, recoveries, prepayments and cumulative loss projections are considered;
8

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
For all equity securities and other debt securities with credit-related declines in fair value, the Company’s intent and ability to hold the security long enough for it to recover its value to book/adjusted carrying value; and
For all other debt securities with interest-related declines in fair value, the Company’s intent to sell the security before recovery of its book/adjusted carrying value.
If the decline is judged to be other-than-temporary, an impairment charge to fair value is recorded as a net realized capital loss in the period the determination is made. Under GAAP, if the decline is judged to be other-than-temporary because the Company has the intent to sell the debt security or is more likely than not to be required to sell the debt security before its anticipated recovery, an impairment charge to fair value is recorded as a net realized capital loss. If the decline is judged to be other-than-temporary because the Company does not expect to recover the entire amortized cost basis of the security due to expected credit losses, an impairment charge is recorded to net realized capital loss as the difference between amortized cost and the net present value of expected future cash flows discounted at the effective interest rate implicit in the debt security prior to impairment.
Investments in real estate are reported net of required obligations rather than on a gross basis as for GAAP. Real estate owned and occupied by the Company is included in investments rather than reported as an operating asset as under GAAP, and investment income and operating expenses include rent for the Company’s occupancy of those properties.
Under a formula prescribed by the NAIC, the Company defers the portion of realized capital gains and losses on sales of fixed income investments, principally debt securities and mortgage loans, attributable to changes in the general level of interest rates and amortizes those deferrals over the remaining period to maturity based on groupings of individual security sold in five-year bands. The net deferral is reported as the interest maintenance reserve (IMR) in the accompanying balance sheets. Realized capital gains and losses are reported in income net of federal income tax and transfers to the IMR. Under GAAP, realized capital gains and losses are reported in the statement of operations on a pretax basis in the period that the assets giving rise to the gains or losses are sold.
The asset valuation reserve (AVR) provides a valuation allowance for invested assets. The AVR is determined by an NAIC prescribed formula with changes reflected directly in capital and surplus. AVR is not recognized for GAAP.
Subsidiaries
The accounts and operations of the Company’s subsidiaries are not consolidated with the accounts and operations of the Company as would be required under GAAP.
9

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Policy Acquisition Costs
The costs of acquiring and renewing business are expensed when incurred. Under GAAP, policy acquisition costs, related to traditional life insurance and certain long-duration accident and health insurance policies sold, to the extent recoverable from future policy revenues, would be deferred and amortized over the premium-paying period of the related policies using assumptions consistent with those used in computing policy benefit reserves; for universal life insurance and investment products, to the extent recoverable from future gross profits, deferred policy acquisition costs are amortized generally in proportion to the present value of expected gross profits from surrender charges and investments, mortality, and expense margins.
Nonadmitted Assets
Certain assets designated as “nonadmitted” (principally investments in unaudited subsidiaries and controlled and affiliated entities, goodwill in excess of the admission limit, and a trademark license agreement), and other assets not specifically identified as admitted assets within the NAIC’s Accounting Practices and Procedures Manual, are excluded from the accompanying balance sheets and are charged directly to accumulated surplus. Under GAAP, such assets are included in the balance sheets.
Premiums and Benefits
Revenues for universal life and annuity policies with mortality or morbidity risk, except for guaranteed interest and group annuity contracts, consist of the entire premium received, and benefits incurred represent the total of death benefits paid and the change in policy reserves. Premiums received for annuity policies without mortality or morbidity risk and for guaranteed interest and group annuity contracts are recorded using deposit accounting, and credited directly to an appropriate policy reserve account, without recognizing premium income. Under GAAP, premiums received in excess of policy charges would not be recognized as premium revenue and benefits would represent the excess of benefits paid over the policy account value and interest credited to the account values.
Benefit Reserves
Certain policy reserves are calculated using statutorily prescribed interest and mortality assumptions rather than on estimated expected experience or actual account balances as would be required under GAAP.
Reinsurance
A liability for reinsurance balances is required to be provided for unsecured policy reserves ceded to reinsurers not authorized to assume such business. Changes to those amounts are credited or charged directly to capital and surplus. Under GAAP, an allowance for amounts deemed uncollectible would be established through a charge to earnings.
Policy and contract liabilities ceded to reinsurers have been reported as reductions of the related reserves rather than as assets as would be required under GAAP. Commissions allowed by reinsurers on business ceded are reported as income when incurred rather than being deferred and amortized with policy acquisition costs as required under GAAP.
10

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Employee Benefits
For purposes of calculating the Company’s pension and postretirement benefit obligations, vested participants, non-vested participants and current retirees are included in the valuation. The prepaid pension asset resulting from the excess of the fair value of plan assets over the benefit obligation, which is nonadmitted under statutory accounting rules, is included in other comprehensive income under GAAP.
Deferred Income Taxes
Deferred tax assets are recorded for the amount of gross deferred tax assets expected to be realized in future years, and a valuation allowance is established for deferred tax assets not meeting a more-likely-than-not realization threshold. Deferred tax assets are limited to 1) the amount of federal income taxes paid in prior years that can be recovered through loss carrybacks for existing temporary differences that reverse during a time frame corresponding with Internal Revenue Service (IRS) tax loss carryback provisions, not to exceed three years, including amounts established in accordance with the provision of SSAP No. 5R, plus 2) for entities who meet the required realization threshold in SSAP No. 101, the lesser of the remaining gross deferred tax assets expected to be realized within three years of the balance sheet date or 15% of capital and surplus excluding any net deferred tax assets, electronic data processing equipment and operating software and any net positive goodwill, plus 3) the amount of remaining gross deferred tax assets that can be offset against existing gross deferred tax liabilities. The remaining deferred tax assets are nonadmitted. Under GAAP, a deferred tax asset is recorded for the amount of gross deferred tax assets expected to be realized in all future years, and a valuation allowance is established for deferred tax assets not meeting a more-likely-than-not realization threshold.
Policyholder Dividends
Policyholder dividends are recognized when declared rather than over the term of the related policies.
Statements of Cash Flow
Cash, cash equivalents and short-term investments in the statements of cash flow represent cash balances and investments with initial maturities of one year or less. Under GAAP, the corresponding captions of cash and cash equivalents include cash balances and investments with initial maturities of three months or less.
Other significant statutory accounting practices follow.
11

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Restricted Assets
The Company has assets pledged as collateral, or otherwise not exclusively under control of the Company, totaling $181.0 million and $136.8 million as of December 31, 2019 and 2018, respectively. These assets are primarily collateral held in relation to the Company's securities lending program. These restricted assets are discussed in more detail in their relevant section.
Investments
Debt securities, common stocks, preferred stocks, and short-term investments are stated at values prescribed by the NAIC, as follows:
Debt securities not backed by other loans are principally stated at amortized cost using the interest method.
Single-class and multiclass mortgage-backed/asset-backed securities are valued at amortized cost using the interest method including anticipated prepayments. Prepayment assumptions are obtained from Bloomberg and broker-dealer prepayment models or derived from empirical data and are based on the current interest rate and economic environment. The retrospective adjustment method is used to value all such securities except securities that are deemed to be other-than-temporarily impaired and securities that are principal-only or interest-only, which are valued using the prospective method.
Unaffiliated common stocks are reported at fair value utilizing publicly quoted prices from third-party pricing services and the related unrealized capital gains and losses are reported in capital and surplus along with any adjustment for federal income taxes.
Redeemable preferred stocks that have characteristics of debt securities and are rated as medium quality or better are reported at cost or amortized cost. All other redeemable preferred stocks are reported at the lower of cost, amortized cost or fair value. Perpetual preferred stocks that have the characteristics of equity securities and are rated as medium quality or better are reported at cost. All other perpetual preferred stocks are reported at the lower of cost or fair value utilizing publicly quoted prices from third-party pricing services and the related unrealized capital gains and losses are reported in capital and surplus along with any adjustment for federal income taxes.
There are no restrictions on unaffiliated common or preferred stocks.
Short-term investments include investments with remaining maturities of one year or less at the date of acquisition and are principally stated at amortized cost, which approximates fair value.
Cash equivalents are short-term highly liquid investments with original maturities of three months or less and are principally stated at amortized cost, which approximates fair value.
The Company’s insurance subsidiaries are reported at their underlying audited statutory equity. The Company’s noninsurance subsidiaries are reported based on underlying audited GAAP equity. The net change in the subsidiaries’ equity is included in capital and surplus.
12

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Joint ventures, partnerships, and limited liability companies are carried at the Company’s interest in the underlying audited GAAP equity of the investee. Undistributed earnings allocated to the Company are reported in the change in net unrealized capital gains or losses. Distributions from earnings of the investees are reported as net investment income when received. Because of the indirect nature of these investments, there is an inherent reduction in transparency and liquidity and increased complexity in valuing the underlying investments. As a result, these investments are actively managed by the Company’s management via detailed evaluation of the investment performance relative to risk.
Mortgage loans are reported at unpaid principal balances, less an allowance for impairment. A mortgage loan is considered to be impaired when, based on current information and events, it is probable that the Company will be unable to collect all principal and interest amounts due according to the contractual terms of the mortgage agreement. When management determines foreclosure is probable, the impairment is other than temporary; the mortgage loan is written down to realizable value and a realized loss is recognized.
Policy loans are reported at unpaid principal balances.
Real estate occupied by the Company and real estate held for the production of income are reported at depreciated cost net of related obligations. Real estate that the Company has the intent to sell is reported at the lower of depreciated cost or fair value, net of related obligations. Depreciation is computed by the straight-line method over the estimated useful life of the properties.
Property acquired in the satisfaction of debt is recorded at the lower of cost less accumulated depreciation or fair market value.
Debt securities and other loan interest are credited to income as it accrues. Dividends are recorded as income on ex-dividend dates. To the extent income is uncertain, due and accrued income is excluded and treated as nonadmitted through surplus.
The Company utilizes customized call and put options to hedge market volatility related to the S&P 500 index . At the beginning of these contracts, a premium is either paid or received for transferring the related risk. The options are not designated as a hedge for accounting purposes and are carried at fair value on the balance sheet with changes in fair value recorded in surplus. The related gains and losses from terminations or expirations are recorded in realized capital gains and losses.
Realized capital gains and losses are determined using the specific identification method.
Premiums
Life and accident and health premiums are recognized as revenue when due. Premiums for annuity policies with mortality and morbidity risk, except for guaranteed interest and group annuity contracts, are also recognized as revenue when due. Premiums received for annuity policies without mortality or morbidity risk and for guaranteed interest and group annuity contracts are recorded using deposit accounting.
13

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Policy Reserves
Life, annuity and accident and health disability benefit reserves are developed by actuarial methods and are determined based on published tables using statutorily specified interest rates and valuation methods that will provide, in the aggregate, reserves that are greater than or equal to the minimum or guaranteed policy cash values or the amounts required by the Department. The Company waives deduction of deferred fractional premiums on the death of life and annuity policy insureds and does return any premium beyond the date of death. Surrender values on policies do not exceed the corresponding benefit reserves. Policies issued subject to multiple table substandard extra premiums are valued on the standard reserve basis which recognizes the nonlevel incidence of the excess mortality costs. Additional reserves are established when the results of cash flow testing under various interest rate scenarios indicate the need for such reserves, or the net premiums exceed the gross premiums on any insurance in-force.
Policy reserves for life insurance and supplemental benefits are computed on the Commissioner’s Reserve Valuation Method. The following mortality tables and interest rates are used:
Percentage of Reserves
20192018
Life insurance:
1941 Commissioners Standard Ordinary, 2-1/4% - 3-1/2% 7.4 %7.8 %
1941 Standard Industrial, 2-1/2% - 3-1/2%9.9  10.5  
1958 Commissioners Standard Ordinary, 2-1/2% - 6%18.9  19.7  
1980 Commissioners Standard Ordinary, 4% - 6%39.8  39.6  
2001 Commissioners Standard Ordinary, 3-1/2% - 4-1/2%18.2  16.4  
Other, 2-1/2% - 6%4.5  4.6  
98.7  98.6  
Other benefits (including annuities):
Various, 2-1/2% - 8-1/4%1.3  1.4  
100.0 %100.0 %
The mean reserve method is used to adjust the calculated terminal reserve to the appropriate reserve at December 31. Mean reserves are determined by computing the regular mean reserve for the plan at the rated age and holding, in addition, one-half of the extra premium charge for the year. Policies issued after July 1 for substandard lives, are charged an extra premium plus the regular premium for the true age. Mean reserves are based on appropriate multiples of standard rates of mortality. An asset is recorded for deferred premiums net of loading to adjust the reserve for modal premium payments.
For substandard table ratings, mean reserves are based on 125% to 500% of standard mortality rates. For flat extra ratings, mean reserves are based on the standard or substandard mortality rates increased by 1 to 25 deaths per thousand.
As of December 31, 2019 and 2018, reserves of $20.8 million and $22.8 million, respectively, were recorded on in-force amounts of $1,033.8 million and $1,216.2 million, respectively, for which gross premiums are less than the net premiums according to the standard of valuation required by the Department. The Company anticipates investment income as a factor in the premium deficiency calculation for all accident and health contracts.
14

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Tabular interest, tabular less actual reserves released, and tabular cost have been determined by formula. Tabular interest on funds not involving life contingencies is calculated as one-hundredth of the product of such valuation rate of interest times the mean of the amount of funds subject to such valuation rate of interest held at the beginning and end of the year of valuation.
The establishment of appropriate reserves is an inherently uncertain process, and there can be no assurance that the ultimate liability will not exceed the Company’s policy reserves and have an adverse effect on the Company’s results of operations and financial condition. Due to the inherent uncertainty of estimating reserves, it has been necessary, and may over time continue to be necessary, to revise estimated future liabilities as reflected in the Company’s policy reserves.
Policyholders’ Dividends
The amount of policyholders’ dividends to be paid (including those on policies included in the Closed Block) is determined annually by the Company’s Board of Directors. The aggregate amount of policyholders’ dividends is related to actual interest, mortality, morbidity and expense experience for the year and judgment as to the appropriate level of statutory surplus to be retained by the Company.
Policy and Contract Claims
Policy and contract claims in process of settlement represent the estimated ultimate net cost of all reported and unreported claims incurred through December 31, 2019 and 2018. The reserves for unpaid claims are estimated using individual case-basis valuations and statistical analysis. These estimates are subject to the effects of trends in claim severity and frequency. Although considerable variability is inherent in such estimates, management believes that the reserves for claims are adequate. The estimates are continually reviewed and adjusted as necessary as experience develops or new information becomes known; such adjustments are included in current operations.
Reinsurance
Reinsurance premiums and benefits paid or provided are accounted for on a basis consistent with those used in accounting for the original policies issued and the terms of the reinsurance contracts.
Securities Lending
At December 31, 2019, the Company had loaned various debt securities, preferred stocks and common stocks as part of a securities lending program administered by Deutsche Bank, of which the fair value was $77.6 million and $53.0 million in the general and separate account, respectively. At December 31, 2018, the Company had loaned various debt securities, preferred stocks and common stocks as part of a securities lending program administered by Deutsche Bank, of which the fair value was $105.9 million and $21.8 million in the general and separate account, respectively. The Company maintains effective control over all loaned securities and, therefore, continues to report such securities as invested assets in the balance sheets. The general account collateral is managed by both an affiliated and unaffiliated agent. The separate account is managed by an unaffiliated agent.
15

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The Company requires at the initial transaction that the fair value of the cash collateral received must be equal to 102% of the fair value of the loaned securities. The Company monitors the ratio of the fair value of the collateral to loaned securities to ensure it does not fall below 100%. If the fair value of the collateral falls below 100% of the fair value of the securities loaned, the Company nonadmits that portion of the loaned security. At December 31, 2019 and 2018, the Company did not nonadmit any portion of the loaned securities.
The Company reports all collateral on the balance sheet with an offsetting liability recognized for the obligation to return the collateral. Collateral for the securities lending program is either managed by an affiliated agent of the Company or is managed by Deutsche Bank, an unaffiliated agent. Collateral managed by an affiliated agent, which approximated $51.7 million and $54.3 million at December 31, 2019 and 2018, respectively, is invested primarily in investment-grade debt securities and cash equivalents and is included in the applicable amount on the balance sheets because the funds are available for the general use of the Company. At December 31, 2019 and 2018, collateral managed by an unaffiliated agent, which approximated $27.7 million and $54.2 million respectively, was invested in cash equivalents and was included in securities lending reinvested collateral assets on the balance sheet.
At December 31, 2019, the collateral for all securities on loan could be requested to be returned on demand by the borrower. At December 31, 2019 and 2018, the fair value of the total collateral in the general account was $79.4 million and $108.5 million, respectively. The fair value of the total collateral in the separate account was $54.2 million and $22.4 million at December 31, 2019 and 2018, respectively, which was all managed by an unaffiliated agent.
The aggregate collateral broken out by maturity date is as follows at December 31, 2019:
Amortized CostFair
Value
(In Thousands)
Open$—  $—  
30 days or less107,151  107,193  
31 to 60 days—  —  
61 to 90 days1,050  1,050  
91 to 120 days1,600  1,600  
121 to 180 days2,257  2,259  
181 to 365 days8,375  8,373  
1 to 2 years4,549  4,556  
2 to 3 years—  —  
Greater than 3 years8,529  8,529  
Total collateral$133,511  $133,560  
At December 31, 2019, all of the collateral held for the securities lending program was invested in tradable securities that could be sold and used to pay for the $79.6 million and $54.2 million in the general and separate accounts, respectively, in collateral calls that could come due under a worst-case scenario where all collateral was called simultaneously.
16

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The Company does not accept collateral that is not permitted by contract or custom to sell or repledge. The Company does not have any securities lending transactions that extend beyond one year from the reporting date.
Separate Account
The Company maintains a separate account, which holds all of the Company’s pension plan assets. The assets of the separate account consist primarily of marketable securities, which are recorded at fair value. These assets are considered legally insulated from the general accounts.
There are no separate account liabilities that are guaranteed by the general account. (See Note 10 for further discussion on the general account’s responsibility as it relates to the obligations of the Company’s pension plan).
The activity within the separate account, including realized and unrealized gains or losses on its investments, has no effect on net income or capital and surplus of the Company. The Company’s statements of operations reflect annuity payments to pension plan participants and other expenses of the separate account, as well as the reimbursement of such expenses from the separate account.
Federal Income Taxes
The Company files a consolidated income tax return with its eligible subsidiaries and affiliates. The provision for federal income taxes is allocated to the individual companies using a separate return method based upon a written tax-sharing agreement. Under the agreement, the benefits from losses of subsidiaries and affiliates are retained by the subsidiary and affiliated companies. The Company pays all federal income taxes due for all members of the group. The Company then immediately charges or reimburses, as the case may be, the members of the group an amount consistent with the method described in the tax-sharing agreement.
The Company includes interest and penalties in the federal income tax line on the statements of operations.
Postretirement Benefits Other Than Pensions
The Company accounts for its postretirement benefits other than pensions on an accrual basis. The postretirement benefit obligation for current retirees and fully eligible employees is measured by estimating the actuarial present value of benefits expected to be received at retirement using explicit assumptions.
Actuarial and investment gains and losses arising from differences between assumptions and actual experience upon subsequent remeasurement of the obligation may be recognized as a component of the net periodic benefit cost in the current period or amortized. The net gain or loss will be included as a component of net postretirement benefit cost for a year if, as of the beginning of the year, the unrecognized net gain or loss exceeds 10% of the postretirement benefit obligation. That gain or loss, if not recognized immediately, will be amortized over the average life expectancy of the employer’s fully vested and retiree group.
17

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Accounting Changes
Effective January 1, 2019, the Company changed its deferred tax assets admission calculation related to clarification updates to Statement of Statutory Accounting Principles 101 - Income Taxes, Exhibit A - Implementation Question and Answers, in the Accounting Practices & Procedures Manual. The Company has recorded a $2.1 million increase to surplus as a result of the change in application of the admission criteria through cumulative effect of changes in accounting principles on the statements of changes in capital and surplus.
Effective January 1, 2018, the Company updated mortality assumptions on certain traditional life reserves. This resulted in a change of statutory reserve valuation that is required to be recorded directly to surplus rather than as part of the reserve change recognized in the statements of operations. As a result, the Company has recorded a $0.7 million decrease to surplus as a result of the change in valuation bases through the change in reserve on account of change in valuation basis line on the statements of changes in capital and surplus.
Business Combinations
On December 31, 2018, the Company purchased 100% of the common stock of Gerber Life from Nestlé S.A. ("Nestlé") for an aggregate purchase price of $1,565.5 million, including direct acquisition costs of $9.3 million. Included in the aggregate purchase price is a long-term license to use Gerber Life intellectual property in connection with financial services. Gerber Life is an insurer that operates primarily in the juvenile life insurance and medical stop-loss insurance markets. Gerber Life is New York-domiciled and is licensed in 50 states, the District of Columbia, Puerto Rico and certain Canadian provinces. In 2019, the Company received $8.2 million from Nestlé as an adjustment to the purchase price of Gerber Life.
The transaction was accounted for as a statutory purchase and reflects the following:
YearCost of acquired entityOriginal Admitted GoodwillAdmitted Goodwill at Reporting DateGoodwill Amortized in PeriodAdmitted Goodwill as a % of Admitted Acquisition
(In thousands)
2019$1,257,274  $528,082  $478,525  $94,555  48.3 %
20181,265,517  528,082  528,082  —  62.9  

Simultaneously to, and in contemplation of, the purchase of Gerber Life, the Company paid for a long-term license to use Gerber Life intellectual property in connection with financial services. The stated purchase price in the trademark license agreement was $300.0 million. The fair value of the trademark license agreement in isolation was determined to be $102.0 million; as a result, the book value of the asset was reduced by $198.0 million through surplus in the line titled trademark license agreement adjustment on the statements of changes in capital and surplus. The adjustment to the book value of the trademark license agreement had no impact on the Company's total capital and surplus, as the trademark license agreement asset is non-admitted and the change to the book value was offset by a change in the associated non-admitted asset.
18

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Subsequent Events
The Company is exposed to potential risk associated with the recent outbreak of a new strain of coronavirus (“COVID-19”) and is actively monitoring developments through governmental briefings and the relevant health authorities. The effects of the outbreak on the Company are uncertain and difficult to predict, as the situation is actively evolving. Risks include (but are not limited to) the disruption of business operations due to changing work environments for employees, agents and distributors, and business partners; potential economic hardship of policyholders and issuers of investments held by the Company; and disruptions of product marketing and sales efforts. The Company has business continuity plans in place to attempt to mitigate the risks posed to business operations by disruptive incidents such as these.
The Company recognizes in the financial statements the effects of all subsequent events that provide additional evidence about conditions that existed at the balance sheet date. For nonrecognized subsequent events that must be disclosed to keep the financial statements from being misleading, the Company is required to disclose the nature of the event as well as an estimate of its financial effect, or a statement that such an estimate cannot be made. Management has evaluated subsequent events through the issuance of these financial statements on April 20, 2020.

19

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
2. Investments
The book/adjusted carrying value and fair value of the Company’s investments in debt securities are summarized as follows:
Book/ Adjusted Carrying ValueGross Unrealized GainsGross Unrealized LossesFair
Value
(In Thousands)
At December 31, 2019:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$24,088  $1,545  $—  $25,633  
Debt securities issued by states of the U.S. and political subdivisions of the states
15,033  2,328  —  17,361  
Non-U.S. government securities
57,511  7,705  —  65,216  
Corporate securities
2,369,794  467,074  (3,662) 2,833,206  
Commercial mortgage-backed securities
36,817  1,099  (107) 37,809  
Residential mortgage-backed securities
233,130  12,281  (75) 245,336  
Asset-backed securities
95,366  11,881  (332) 106,915  
Total$2,831,739  $503,913  $(4,176) $3,331,476  
At December 31, 2018:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$27,656  $882  $(196) $28,342  
Debt securities issued by states of the U.S. and political subdivisions of the states
15,030  1,680  (47) 16,663  
Non-U.S. government securities
57,986  2,718  (982) 59,722  
Corporate securities
2,449,117  211,540  (66,657) 2,594,000  
Commercial mortgage-backed securities
53,343  273  (466) 53,150  
Residential mortgage-backed securities
240,395  8,933  (1,692) 247,636  
Asset-backed securities
93,924  3,527  (907) 96,544  
Total$2,937,451  $229,553  $(70,947) $3,096,057  
At December 31, 2019 and 2018, the Company held unrated or below-investment-grade corporate debt securities with a book/adjusted carrying value of $57.1 million and $72.0 million, respectively, and an aggregate fair value of $59.4 million and $69.1 million, respectively. As of December 31, 2019 and 2018, such holdings amounted to 2.0% and 2.5%, respectively, of the Company’s investments in debt securities and 0.5% and 0.7%, respectively, of the Company’s total admitted assets. The Company performs periodic evaluations of the relative credit standing of the issuers of these debt securities. The Company considers these evaluations in its overall investment strategy.
20

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Unrealized gains and losses on investments in unaffiliated common stocks, mutual funds and common stocks of subsidiaries are reported directly in capital and surplus and do not affect net income. The unrealized gains and unrealized losses on, and the cost and fair value of those investments and preferred stocks are as follows:



CostGross Unrealized GainsGross Unrealized LossesFair
Value
(In Thousands)
At December 31, 2019:
Preferred stocks$25,531  $1,984  $(202) $27,313  
Common stocks, unaffiliated$478,826  $233,044  $(11,313) $700,557  
Common stocks, mutual funds178,868  14,194  (350) 192,712  
Common stocks, subsidiaries3,014,801  693,483  (113,344) 3,594,940  
$3,672,495  $940,721  $(125,007) $4,488,209  

CostGross Unrealized GainsGross Unrealized LossesFair
Value
(In Thousands)
At December 31, 2018:
Preferred stocks$16,026  $334  $(668) $15,692  
Common stocks, unaffiliated$446,459  $146,776  $(38,660) $554,575  
Common stocks, mutual funds155,207  37  (8,241) 147,003  
Common stocks, subsidiaries2,840,458  418,024  (65,344) 3,193,138  
$3,442,124  $564,837  $(112,245) $3,894,716  
21

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The following table shows unrealized losses and fair values, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position.
Unrealized Losses Less
Than 12 Months
Unrealized Losses Greater Than or Equal to 12 Months
Unrealized Losses
Fair
Value
Unrealized LossesFair
Value
(In Thousands)
At December 31, 2019:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$—  $—  $—  $—  
Debt securities issued by states of the U.S. and political subdivisions of the states
—  —  —  —  
Non-U.S. government securities
—  —  —  —  
Corporate securities
(2,827) 65,853  (835) 28,129  
Commercial mortgage-backed securities(1)
(105) 5,042  (2) 69  
Residential mortgage-backed securities(1)
(32) 18,790  (43) 4,371  
Asset-backed securities(1)
(210) 16,725  (122) 8,878  
Total$(3,174) $106,410  $(1,002) $41,447  
Preferred stocks$(202) $608  $—  $—  
Common stocks, unaffiliated$(11,313) $88,917  $—  $—  
Common stocks, mutual funds(350) 40,004  —  —  
Total$(11,663) $128,921  $—  $—  
(1) Amounts relate to securities subject to SSAP 43R.
22

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Unrealized Losses Less
Than 12 Months
Unrealized Losses Greater Than or Equal to 12 Months
Unrealized Losses
Fair
Value
Unrealized LossesFair
Value
(In Thousands)
At December 31, 2018:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$(122) $5,372  $(74) $7,344  
Debt securities issued by states of the U.S. and political subdivisions of the states
(47) 5,193  —  —  
Non-U.S. government securities
(981) 24,398  —  —  
Corporate securities
(60,616) 886,386  (6,042) 58,244  
Commercial mortgage-backed securities(1)
(185) 18,196  (281) 17,121  
Residential mortgage-backed securities(1)
(858) 56,185  (834) 36,871  
Asset-backed securities(1)
(858) 39,938  (49) 1,804  
Total$(63,667) $1,035,668  $(7,280) $121,384  
Preferred stocks$(668) $5,146  $—  $—  
Common stocks, unaffiliated$(38,660) $169,629  $—  $—  
Common stocks, mutual funds(8,241) 114,637  —  —  
Total$(46,901) $284,266  $—  $—  
(1) Amounts relate to securities subject to SSAP 43R.
Investments that are impaired at December 31, 2019 and 2018, for which other-than-temporary impairments have not been recognized, consist mainly of corporate debt securities, asset-backed securities, residential mortgage-backed securities and unaffiliated common stocks.
The aggregated unrealized loss is approximately 5.5% and 7.6% of the carrying value of securities considered temporarily impaired at December 31, 2019 and 2018, respectively. At December 31, 2019, there were a total of 99 securities held that are considered temporarily impaired, 13 of which have been impaired for 12 months or longer. At December 31, 2018, there were a total of 421 securities held that were considered temporarily impaired, 36 of which had been impaired for 12 months or longer. The Company recorded other-than-temporary impairments on securities of $17.1 million, $19.1 million and $5.0 million for the years ended December 31, 2019, 2018 and 2017, respectively.
The Company had no loan-backed securities held at December 31, 2019, with a recognized other-than-temporary impairment (OTTI) for the year ended December 31, 2019, where the present value of future cash flows expected to be collected was less than the amortized cost basis of the securities.
The Company had no OTTI on loan-backed securities for the year ended December 31, 2019, due to the intent to sell the security or the inability or lack of intent to retain the investment in the security for a period of time sufficient to recover the amortized cost basis of the security.
23

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
A summary of the cost or amortized cost and fair value of the Company’s debt securities at December 31, 2019, by contractual maturity, is as follows:
Book/Adjusted Carrying ValueFair
Value
(In Thousands)
Years to maturity:
One or less$35,516  $35,730  
After one through five184,097  195,118  
After five through ten507,351  600,634  
After ten1,739,462  2,109,934  
Mortgage-backed securities/asset-backed securities365,313  390,060  
Total$2,831,739  $3,331,476  
The expected maturities may differ from contractual maturities in the foregoing table because certain borrowers have the right to call or prepay obligations with or without call or prepayment penalties and because asset-backed and mortgage-backed securities (including floating-rate securities) provide for periodic payments throughout their lives.
Proceeds from sales of investments in debt securities during 2019, 2018 and 2017 were $63.4 million, $1,385.4 million, and $285.0 million; gross gains of $1.5 million, $25.8 million, and $9.2 million and gross losses of $0.3 million, $6.0 million, and $0.5 million were realized on these sales in 2019, 2018 and 2017, respectively.
Proceeds from the sales of investments in equity securities during 2019, 2018 and 2017 were $476.7 million, $1,092.8 million, and $439.0 million; gross gains of $42.2 million, $230.8 million, and $61.4 million and gross losses of $30.2 million, $38.9 million, and $43.7 million were realized on these sales in 2019, 2018 and 2017, respectively.
Realized capital gains (losses) are reported net of federal income taxes and amounts transferred to the IMR as follows for the years ended December 31:
201920182017
(In Thousands)
Realized capital gains (losses)$6,135  $282,807  $11,982  
Less amount transferred to IMR (net of related taxes (benefits) of $1,658 in 2019, $3,425 in 2018, and $2,211 in 2017)
6,009  12,886  4,106  
Less federal income tax expense (benefit) of realized capital gains (losses)
(2,103) 64,841  5,319  
Net realized capital gains (losses)$2,229  $205,080  $2,557  
24

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Net investment income was generated from the following for the years ended December 31:
201920182017
(In Thousands)
Debt securities$148,923  $182,497  $178,001  
Equity securities30,807  44,065  254,309  
Mortgage loans2,716  1,963  3,854  
Real estate13,175  13,071  13,150  
Policy loans11,827  11,965  12,224  
Cash, cash equivalents and short-term investments2,148  4,967  1,265  
Other invested assets318,696  229,089  96,300  
Other1,106  1,361  1,465  
Gross investment income529,398  488,978  560,568  
Investment expenses50,294  22,757  21,404  
Net investment income$479,104  $466,221  $539,164  
The Company’s investments in mortgage loans principally involve commercial real estate. At December 31, 2019, 76.0% of such mortgages, or $52.4 million, involved properties located in Arizona, Washington, and South Carolina. Such investments consist of primarily first-mortgage liens on completed income-producing properties. The aggregate mortgage outstanding to any one borrower does not exceed $21.2 million. During 2019, the respective minimum and maximum lending rates for mortgage loans issued were 4.75% and 5.25%. At the issuance of a loan, the percentage of any one loan to value of security, exclusive of insured, guaranteed or purchase money mortgage did not exceed 80.0%. During 2019, the Company did not reduce interest rates on any outstanding mortgages.
Derivative Instruments
The Company entered into an equity hedge program designed to hedge the market value risks associated with the broad equity market in the third quarter of 2018. Hedging this risk reduces the economic sensitivity to price declines. At the beginning of these contracts, a premium is either paid or received for transferring the related risk. The options are not designated as a hedge for accounting purposes and are carried at fair value on the balance sheet with changes in fair value recorded in surplus. The related gains and losses from terminations or expirations are recorded in realized capital gains and losses. The change in fair value was $(49.8) million and $0.0 million for the years ended December 31, 2019 and 2018, respectively. The net gain/(loss) recognized through net income within realized gains and losses was $0.0 million and $81.3 million for the years ended December 31, 2019 and 2018, respectively.
The Company has entered into a collateral agreement with the counterparty whereby under certain conditions the counterparty is required to post assets on the Company’s behalf. The posted amount is equal to the difference between the net positive fair value of the option and the agreed upon thresholds that are based on the credit rating of the counterparty. Inversely, if the net fair value of the option is negative, then the Company may be required to post assets using similar thresholds. At December 31, 2019 and 2018, $41.7 million and $0.0 million, respectively, of cash collateral has been posted by the Company.
Information related to the Company’s derivative instruments as described above and the effects of offsetting on the balance sheet consisted of the following for the years ended December 31:
25

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017

20192018
(In Thousands)
Derivative assets:
Gross amount of recognized assets$7,820  $—  
Gross amounts offset—  —  
Net amount of assets$7,820  $—  
Derivative liabilities:
Gross amount of recognized liabilities$(48,246) $—  
Gross amounts offset—  —  
Net amount of liabilities$(48,246) $—  

3. Fair Values of Financial Instruments
Included in various investment-related line items in the financial statements are certain financial instruments carried at fair value. Other financial instruments are periodically measured at fair value such as when impaired or, for certain bonds and preferred stocks, when carried at the lower of cost or market.
The Company uses fair value measurements to record the fair value of certain assets and liabilities and to estimate the fair value of financial instruments not recorded at fair value but required to be disclosed at fair value. Certain financial instruments, particularly policyholder liabilities other than investment-type contracts, are excluded from this fair value discussion.
Fair value is defined as the price that would be received to sell an asset or transfer a liability in an orderly transaction between market participants at the measurement date. The Company’s financial assets and liabilities carried at fair value have been classified, for disclosure purposes, based on the following hierarchy that prioritizes inputs to valuation techniques used to measure fair value into three levels. The Company’s policy is to recognize transfers in and transfers out of levels at the beginning of the quarterly reporting period.
Level 1 - Quoted prices (unadjusted) in active markets for identical assets or liabilities. The Company’s Level 1 assets and liabilities primarily include exchange-traded equity securities and mutual funds, including those which are part of the Company’s separate account assets.
Level 2 - Inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. The Company’s Level 2 assets and liabilities primarily include debt securities within the Company’s separate account for which public quotations are not available, but that are priced by third-party pricing services or internal models using observable inputs. Also included in Level 2 assets and liabilities are NAIC 4 rated preferred stock, NAIC 6 rated bonds, options, and stock warrants. The fair value of these instruments is determined through the use of third-party pricing services or models utilizing market observable inputs.
26

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Level 3 - Significant unobservable inputs for the asset or liability. The Company’s Level 3 assets and liabilities primarily include certain debt securities and private equity securities within the Company’s separate account that must be priced using non-binding broker quotes or other valuation techniques that utilize significant unobservable inputs. Also included in Level 3 assets and liabilities are preferred stocks being priced by utilizing recent financing for similar securities.
Fair value estimates are made at a specific point in time, based on available market information and judgments about the financial instrument, including discount rates, estimates of timing, amount of expected future cash flows and the credit standing of the issuer. Such estimates do not consider the tax impact of the realization of unrealized gains or losses.
For Level 3 investments, the fair value estimates cannot be substantiated by comparison to independent markets. In addition, the disclosed fair value may not be realized in the immediate settlement of the financial instrument.
Certain investments utilize net asset value (NAV) as a practical expedient for fair value. These investments are reported separately from the hierarchy. Investments utilizing NAV consist mainly of equity interest in limited partnerships and limited liabilities in the separate account. These investments contain fixed income, common stock, and real estate characteristics. The interests in these partnerships can be sold or transferred with prior consent from the general partner. The average remaining life of the investments is 21.5 years. The Company's unfunded commitment for these investments is $21.2 million. In addition, a collective trust in the separate account utilizing NAV is primarily investing in domestic fixed income securities. Shares in the trust can be redeemed at their net asset value. The NAV for this investment is $10.93. The Company does not intend to sell any investments utilizing NAV.
As described below, certain fair values are determined through the use of third-party pricing services. Management does not adjust prices received from third parties; however, the Company does analyze the third-party pricing services’ valuation methodologies and related inputs and performs additional evaluation to determine the appropriate level within the fair value hierarchy. The Company performs annual due diligence of third-party pricing services, which includes assessing the vendor’s valuation qualifications, control environment, analysis of asset class-specific valuation methodologies and understanding of market observable assumptions and unobservable assumptions, if any, employed in the valuation methodology. Care should be exercised in deriving conclusions about the Company’s business, its value or financial position based on the fair value information of financial instruments presented below. The following discussion describes the valuation methodologies utilized by the Company for assets and liabilities measured or disclosed at fair value.
Debt and Equity Securities
The fair values of debt securities and asset/mortgage-backed securities have been determined through the use of third-party pricing services utilizing market observable inputs. Private placement securities trading in less liquid or illiquid markets with limited or no pricing information are valued using either broker quotes or by discounting the expected cash flows using current market-consistent rates applicable to the yield, credit quality and maturity of each security.
27

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The fair values of actively traded equity securities and exchange traded funds (including exchange traded funds with debt like characteristics) have been determined utilizing publicly quoted prices obtained from third-party pricing services. The fair values of certain equity securities for which no publicly quoted prices are available have been determined through the use of third-party pricing services utilizing market observable inputs. Actively traded mutual funds are valued using the net asset values of the funds. The fair value of equity securities included in Level 3 has been determined by utilizing recent financing for similar securities.
Mortgage Loans
The fair values for mortgage loans, consisting principally of commercial real estate loans, are estimated using discounted cash flow analyses, using interest rates currently being offered for similar loans collateralized by properties with similar investment risk. The fair values for mortgage loans in default are established at the lower of the fair value of the underlying collateral less costs to sell or the carrying amount of the loan.
Cash, Cash Equivalents and Short-Term Investments
The fair values of cash, cash equivalents and short-term investments are based on quoted market prices or stated amounts.
Securities Lending Reinvested Collateral Assets
The fair values of securities lending reinvested collateral assets are determined through the use of third-party sources utilizing publicly quoted prices.
Other Invested Assets
Other invested assets primarily include surplus debentures for which fair values have been determined through the use of third-party pricing services utilizing market observable inputs.
Derivative Instruments
The fair values of free-standing derivative instruments, primarily options and stock warrants, are determined through the use of third-party pricing services or models utilizing market observable inputs.
Cash Collateral Receivable
The receivable represents the obligation to return cash collateral the Company has posted relating to derivative instruments. The fair value is based upon the stated amount.
28

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Assets Held in Separate Accounts
Assets held in separate accounts include debt securities, equity securities, mutual funds, private equity, and private debt fund investments. The fair values of debt securities, equity securities and mutual funds have been determined using the same methodologies as similar assets held in the general account. The fair values of private equity and private debt fund investments have been determined utilizing the net asset values of the funds.
Life and Annuity Reserves for Investment-Type Contracts and Deposit Fund Liabilities
The fair value of liabilities for investment-type contracts is based on the present value of estimated liability cash flows, which are discounted using rates that incorporate risk-free rates and margins for the Company’s own credit spread and the riskiness of cash flows. Key assumptions to the cash flow model include the timing of policyholder withdrawals and the level of interest credited to contract balances. Fair values for insurance reserves are not required to be disclosed. However, the estimated fair values of all insurance reserves and investment contracts are taken into consideration in the Company’s overall management of interest rate risk.
Securities Lending Liability
The liability represents the Company’s obligation to return collateral related to securities lending transactions. The liability is short-term in nature and therefore, the fair value of the obligation approximates the carrying amount.
Assets and liabilities measured at fair value on a recurring basis are outlined below:
Assets/(Liabilities) Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2Level 3NAV
(In Thousands)
At December 31, 2019
Assets:
Bonds, industrial and misc.$1,047  $—  $1,047  $—  $—  
Bonds, exchange traded funds5,868  5,868  —  —  —  
Common stocks, unaffiliated700,557  697,947  —  —  2,610  
Common stocks, mutual funds192,712  192,712  —  —  —  
Derivative assets7,820  —  7,820  —  —  
Separate account assets1,141,599  706,951  140,561  19,844  274,243  
Total assets$2,049,603  $1,603,478  $149,428  $19,844  $276,853  
Liabilities:
Derivative liabilities$(48,246) $—  $(48,246) $—  $—  

29

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Assets/(Liabilities) Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2Level 3NAV
(In Thousands)
At December 31, 2018
Assets:
Bonds, exchange traded funds$4,889  $4,889  $—  $—  $—  
Common stocks, unaffiliated554,575  551,875  —  —  2,700  
Common stocks, mutual funds147,003  147,003  —  —  —  
Preferred stocks866  —  573  293  —  
Separate account assets961,136  561,325  128,292  18,656  252,863  
Total assets$1,668,469  $1,265,092  $128,865  $18,949  $255,563  

The reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2019 are as follows:
Beginning Asset/(Liability) as of January 1, 2019Total Realized/Unrealized Gains (Losses) Included in*:Purchases, Sales, Issuances and SettlementsTransfers Into Level 3**Transfers Out of Level 3**Ending Asset/ (Liability) as of December 31,
2019
Net IncomeSurplusOther
(In Thousands)
Assets:
Preferred stocks
$293  $—  $(200) $—  $—  $200  $(293) $—  
Separate account assets
18,656  —  —  1,792  (604) —  —  19,844  
Total assets$18,949  $—  $(200) $1,792  $(604) $200  $(293) $19,844  
* Gains and losses for assets held in separate accounts do not impact net income or surplus as the change in value of assets held in separate accounts is offset by a change in value of liabilities related to separate accounts.
** Transfers into and out of Level 3 are due to changes resulting from the application of the lower of amortized cost or fair value rules based on the security's NAIC rating
The gross purchases, issuances, sales and settlements included in the reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2019, are as follows:
PurchasesIssuancesSalesSettlementsNet Purchases, Issuances, Sales and Settlements
(In Thousands)
Assets:
Preferred stocks$—  $—  $—  $—  $—  
Separate account assets—  —  —  (604) (604) 
Total assets$—  $—  $—  $(604) $(604) 
30

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2018, is as follows:
Beginning Asset/(Liability )as of January 1, 2018Total Realized/Unrealized Gains (Losses) Included in*:Purchases, Sales, Issuances and SettlementsTransfers Into Level 3**Transfers Out of Level 3***Ending Asset/ (Liability) as of December 31, 2018
Net IncomeSurplusOther
(In Thousands)
Assets:
Common stocks, unaffiliated
$4,902  $(4,389) $(3) $—  $—  $—  $(510) $—  
Preferred stocks—  —  (55) —  —  348  —  293  
Separate account assets
78,597  —  —  1,421  (1,147) 1,757  (61,972) 18,656  
Total assets$83,499  $(4,389) $(58) $1,421  $(1,147) $2,105  $(62,482) $18,949  
* Gains and losses for assets held in separate accounts do not impact net income or surplus as the change in value of assets held in separate accounts is offset by a change in value of liabilities related to separate accounts.
** Transfers into Level 3 are due to changes in the price source
*** Transfers out of Level 3 are due to utilizing net asset value.
The gross purchases, issuances, sales and settlements included in the reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2018, are as follows:
PurchasesIssuancesSalesSettlementsNet Purchases, Issuances, Sales and Settlements
(In Thousands)
Assets:
Common stocks, unaffiliated$—  $—  $—  $—  $—  
Preferred stocks—  —  —  —  —  
Separate account assets—  —  —  (1,147) (1,147) 
Total Assets$—  $—  $—  $(1,147) $(1,147) 

The Company did not have any significant assets or liabilities measured at fair value on a nonrecurring basis as of December 31, 2019 and 2018.
31

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The carrying amounts and fair values of the Company’s significant financial instruments follow:
December 31, 2019
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds$2,831,739  $3,331,476  $23,571  $3,306,905  $1,000  $—  
Common stock:
Unaffiliated700,557  700,557  697,947  —  —  2,610  
Mutual funds192,712  192,712  192,712  —  —  —  
Preferred stock25,331  27,313  —  25,981  1,332  —  
Mortgage loans68,898  71,162  —  —  71,162  —  
Cash, cash equivalents and short-term investments
77,542  77,589  77,589  —  —  —  
Other invested assets, surplus notes
33,945  43,794  —  43,794  —  —  
Securities lending reinvested collateral assets
27,635  27,635  27,635  —  —  —  
Derivative assets7,820  7,820  —  7,820  —  —  
Cash collateral receivable41,680  41,680  —  41,680  —  —  
Separate account assets1,141,599  1,141,599  706,951  140,561  19,844  274,243  
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(4,270) $(4,471) $—  $—  $(4,471) $—  
Derivative liabilities(48,246) (48,246) —  (48,246) —  —  
Securities lending liability(79,589) (79,589) —  (79,589) —  —  
December 31, 2018
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds$2,937,451  $3,096,057  $21,632  $3,071,925  $2,500  $—  
Common stock:
Unaffiliated554,575  554,575  551,875  —  —  2,700  
Mutual funds147,003  147,003  147,003  —  —  —  
Preferred stock15,845  15,692  —  14,182  1,510  —  
Mortgage loans59,146  58,652  —  —  58,652  —  
Cash, cash equivalents and short-term investments
87,913  87,919  87,919  —  —  —  
Other invested assets, surplus notes
33,974  37,988  —  37,988  —  —  
Securities lending reinvested collateral assets
54,253  54,253  54,253  —  —  —  
Separate account assets961,136  961,136  561,325  128,292  18,656  252,863  
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(4,469) $(4,419) $—  $—  $(4,419) $—  
Securities lending liability(108,841) (108,841) —  (108,841) —  —  

32

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
4. Related-Party Transactions
The Company owns a 100% interest in Integrity and WSLAC, whose carrying values based on underlying statutory surplus at December 31, 2019, are $1.3 billion and $1.1 billion, respectively. The accounting policies of Integrity and WSLAC are the same as those of the Company described in Note 1. The summary financial data for Integrity and WSLAC follows:

20192018
(In Thousands)
Integrity:
Admitted Assets$9,914,360  $9,415,090  
Liabilities8,643,016  8,283,823  
Statutory Surplus$1,271,344  $1,131,267  
Net Income$13,125  $59,221  
WSLAC:
Admitted Assets$14,808,181  $13,029,413  
Liabilities13,739,451  12,089,615  
Statutory Surplus$1,068,730  $939,798  
Net Income$81,627  $16,091  
The Company has an equity interest in certain partnerships that made payments of principal and interest under mortgage financing arrangements to subsidiaries in the amount of $23.8 million, $16.5 million, and $3.7 million in 2019, 2018 and 2017, respectively. The principal balance of the mortgage financing arrangements with subsidiaries was $303.1 million and $312.8 million at December 31, 2019 and 2018, respectively.
At December 31, 2019 and 2018, the Company had $131.9 million and $107.4 million, respectively, invested, in the Touchstone Funds, which are mutual funds administered by Touchstone Advisors, Inc., an indirect subsidiary of the Company.
In November 2019, the Company paid a $93.9 million capital contribution to its subsidiary, Gerber Life. The contribution was in the form of common stock.
In November 2019, the Company paid a $30.0 million capital contribution to its subsidiary, Columbus Life. The contribution was in the form of common stock.
In February 2019, the Company paid a $100.0 million capital contribution to its subsidiary, Gerber Life. The contribution was in the form of $99.8 million in bonds and $0.2 million in cash.
33

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The Company issued a short-term loan to its parent, WSFG, as of January 23, 2019, for $260.0 million. This note had a maturity date of March 24, 2019, and bore interest at a rate of 2.68%, compounding monthly. The principal of the loan was forgiven by the Company as of March 7, 2019, and was accounted for as an ordinary dividend from the Company to WSFG. The accrued interest of $0.8 million was paid by WSFG to the Company on March 7, 2019.
The Company received a $260.0 million capital contribution from WSFG in December 2018. The contribution was in the form of cash.
The Company paid a $35.0 million capital contribution to Columbus Life in December 2018. The contribution was in the form of cash.
On November 16, 2018, the Company sold common stock back to its issuer for $74.4 million. A member of the Company's Board of Directors also serves on the Board of Directors of the company that purchased the common stock.
In the fourth quarter of 2018, the Company sold bonds in exchange for cash to WSLAC, Integrity, and National Integrity in the amounts of $294.3 million, $87.0 million, and $47.6 million, respectively.
The Company paid a $250.0 million capital contribution to Integrity in June 2018. The contribution was in the form of $245.7 million in common stocks and $4.3 million in cash.
In October 2017, the Company entered into a Pension Risk Transfer agreement with WSLAC. Refer to Note 10 for more detail.
The Company received a $200.0 million dividend from WSLAC in December 2017. The dividend was $109.3 million ordinary and $90.7 million extraordinary. The dividend was in the form of cash.
The Company received a $57.1 million capital contribution from WSFG in October 2017. The contribution was in the form of cash.
The Company paid a $36.1 million capital contribution to WSLAC in October 2017. The contribution was in the form of cash.
The Company paid a $30.0 million capital contribution to Columbus Life in December 2017, The contribution was in the form of cash.
The Company had $33.2 million and $31.1 million receivable from parent, subsidiaries and affiliates as of December 31, 2019 and 2018, respectively. The Company did not have any amounts payable to parent, subsidiaries and affiliates as of December 31, 2019 or 2018. The terms of the settlement generally require that these amounts be settled in cash within 30 days.
The Company has entered into multiple reinsurance agreements with affiliated entities. See Note 5 for further description.

34

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
5. Reinsurance
Certain premiums and benefits are assumed from and ceded to other insurance companies under various reinsurance agreements. The ceded reinsurance agreements provide the Company with increased capacity to write larger risks and maintain its exposure to loss within its capital resources.
The Company had a modified coinsurance agreement with Integrity until it was recaptured on November 1, 2018. Under the terms of the agreement, the Company assumed structured settlements, guaranteed rate option annuities, and accumulation products written before July 1, 2002, and Integrity retained the reserves and the related assets of this business. At the date of recapture, there was no impact to net income or surplus. The recapture is presented in the statements of operations in lines titled miscellaneous income adjustment - termination of reinsurance agreement and miscellaneous expense adjustment - termination of reinsurance agreement for $694.6 million and $694.6 million, respectively.
The Company has a ceded reinsurance agreement with Columbus Life. Under the reinsurance agreement, Columbus Life reinsures the former liabilities of Columbus Mutual, a former affiliate, which was merged into the Company. Life and accident and health reserves ceded from the Company to Columbus Life totaled $493.5 million and $514.2 million at December 31, 2019 and 2018, respectively.
In 2006, the Company entered into a yearly renewable term reinsurance agreement with Lafayette Life, an affiliated entity, whereby the Company provides reinsurance coverage on certain life products and associated riders as this coverage is recaptured by Lafayette Life from unaffiliated reinsurers. Life reserves ceded from Lafayette Life to the Company under this agreement totaled $0.9 million and $1.0 million at December 31, 2019 and 2018, respectively.
Certain premiums and benefits are ceded to other unaffiliated insurance companies under various reinsurance agreements. The majority of the ceded business is due to ceding substandard business to reinsurers (facultative basis).
The effects of reinsurance on premiums, annuity considerations and deposit-type funds are as follows for the years ended December 31:
201920182017
(In Thousands)
Direct premiums$237,084  $241,297  $251,423  
Assumed premiums:
Affiliates1,111  2,176  1,726  
Nonaffiliates—  —  —  
Ceded premiums:
Affiliates—  —  —  
Nonaffiliates(6,422) (6,419) (6,403) 
Net premiums$231,773  $237,054  $246,746  
35

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The Company’s ceded reinsurance arrangements reduced certain other items in the accompanying financial statements by the following amounts as of and for the years ended December 31:
201920182017
(In Thousands)
Benefits paid or provided:
Affiliates$—  $—  $—  
Nonaffiliates2,936  4,225  3,420  
Policy and contract liabilities:
Affiliates468,882  488,266  506,178  
Nonaffiliates50,472  50,796  50,260  
Amounts recoverable on reinsurance contracts:
Affiliates—  —  —  
Nonaffiliates227  382  199  
In 2019, 2018 and 2017, the Company did not commute any ceded reinsurance nor did it enter into or engage in any agreement that reinsures policies or contracts that were in-force or had existing reserves as of the effective date of such agreements.
At December 31, 2019, the Company has no significant reserves ceded to unauthorized reinsurers. Amounts payable or recoverable for reinsurance on policy and contract liabilities are not subject to periodic or maximum limits. At December 31, 2019, the Company’s reinsurance recoverables are not material and no individual reinsurer owed the Company an amount that was equal to or greater than 3% of the Company’s capital and surplus.
Neither the Company nor any of its related parties, control directly or indirectly, any reinsurers with whom the Company conducts business. No policies issued by the Company have been reinsured with a foreign company, which is controlled, either directly or indirectly, by a party not primarily engaged in the business of insurance. The Company does not have any reinsurance agreements in effect under which the reinsurer may unilaterally cancel the agreement. At December 31, 2019, there are no reinsurance agreements in effect such that the amount of losses paid or accrued exceed the total direct premium collected. The Company remains obligated for amounts ceded in the event that the reinsurers do not meet their obligations.
There would be no reduction in surplus at December 31, 2019, if all reinsurance agreements were cancelled.

6. Federal Income Taxes
The Company and its eligible subsidiaries and affiliates file a consolidated federal income tax return. Amounts due (to)/from the subsidiaries and affiliates for federal income taxes were $(9.6) million and $(45.5) million at December 31, 2019 and 2018, respectively. The tax years 2014 through 2019 remain subject to examination by major tax jurisdictions.
36

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The amount of federal income taxes incurred that will be available for recoupment at December 31, 2019, in the event of future capital losses is $36.9 million, $100.9 million, and $17.8 million from 2019, 2018 and 2017, respectively.
The aggregate amount of deposits admitted under Section 6603 of the Internal Revenue Service Code is $32.3 million and $0.0 million in 2019 and 2018, respectively.
The components of the net deferred tax asset (liability) at December 31 are as follows:
12/31/2019
(In Thousands)
(1)(2)(3)
  (Col 1+2)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$246,001  $10,343  $256,344  
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)246,001  10,343  256,344  
(d)Deferred tax assets nonadmitted20,574  —  20,574  
(e)Subtotal net admitted deferred tax assets (c - d)225,427  10,343  235,770  
(f)Deferred tax liabilities101,138  40,092  141,230  
(g)Net admitted deferred tax asset/(net deferred tax liability) (e - f)$124,289  $(29,749) $94,540  

12/31/2018
(In Thousands)
(4)(5)(6)
  (Col 4+5)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$365,543  $17,219  $382,762  
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)365,543  17,219  382,762  
(d)Deferred tax assets nonadmitted104,536  —  104,536  
(e)Subtotal net admitted deferred tax assets (c - d)261,007  17,219  278,226  
(f)Deferred tax liabilities110,675  28,445  139,120  
(g)Net admitted deferred tax asset/(net deferred tax liability) (e - f)$150,332  $(11,226) $139,106  

37

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$(119,542) $(6,876) $(126,418) 
(b)Statutory valuation allowance adjustments—  —  —  
(c)Adjusted gross deferred tax assets (a - b)(119,542) (6,876) (126,418) 
(d)Deferred tax assets nonadmitted(83,962) —  (83,962) 
(e)Subtotal net admitted deferred tax assets (c - d)(35,580) (6,876) (42,456) 
(f)Deferred tax liabilities(9,537) 11,647  2,110  
(g)Net admitted deferred tax asset/(net deferred tax liability) (e - f)$(26,043) $(18,523) $(44,566) 

12/31/2019
(In Thousands)
(1)(2)(3)
  (Col 1+2)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$—  $9,934  $9,934  
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
84,606  —  84,606  
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date
84,606  —  84,606  
2. Adjusted gross deferred tax assets allowed per limitation threshold. XXX   XXX  716,334  
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
140,821  409  141,230  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$225,427  $10,343  $235,770  

12/31/2018
(In Thousands)
(4)(5)(6)
  (Col 4+5)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$—  $17,219  $17,219  
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
123,991  —  123,991  
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date
123,991  —  123,991  
2. Adjusted gross deferred tax assets allowed per limitation threshold. XXX   XXX  639,639  
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
137,016  —  137,016  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$261,007  $17,219  $278,226  
38

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017

Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$—  $(7,285) $(7,285) 
(b)
Adjusted gross deferred tax assets expected to be realized (excluding the amount of deferred tax assets from (a) above) after application of the threshold limitation (the lesser of (b)1 and (b)2 below)
(39,386) —  (39,385) 
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date
(39,386) —  (39,385) 
2. Adjusted gross deferred tax assets allowed per limitation threshold.
 XXX   XXX  76,695  
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
3,806  409  4,214  
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$(35,580) $(6,876) $(42,456) 

20192018
Ratio percentage used to determine recovery period and threshold limitation amount932%928%

12/31/2019
(1)(2)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$246,001$10,343
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
19.61%3.88%
(c)Net admitted adjusted gross DTAs amount$225,427$10,343
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
21.32%4.21%

12/31/2018
(3)(4)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$365,543$17,219
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
10.99%4.50%
(c)
Net admitted adjusted gross DTAs amount
$261,007$17,219
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
15.12%6.19%

39

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Change
(5)(6)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$(119,542)$(6,876)
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
8.62%(0.62)%
(c)
Net admitted adjusted gross DTAs amount
$(35,580)$(6,876)
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies
6.20%(1.98)%
The Company's tax planning strategies include the use of reinsurance.
Current income taxes incurred consist of the following major components:
12/31/201912/31/201812/31/2017
(In Thousands)
(1) Current income tax
(a)Federal$25,236  $39,452  $11,938  
(b)Foreign287  427  173  
(c)Subtotal25,523  39,879  12,111  
(d)Federal income tax on net capital gains(2,103) 64,841  5,319  
(e)Utilization of capital loss carryforwards—  —  —  
(f)Other—  —  —  
(g)Federal and foreign income taxes incurred$23,420  $104,720  $17,430  

40

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
(1)(2)(3)
  (Col 1-2)
(2)Deferred tax assets:12/31/201912/31/2018Change
(a)Ordinary(In Thousands)
(1) Discounting of unpaid losses$—  $—  $—  
(2) Unearned premium revenue—  —  —  
(3) Policyholder reserves51,727  49,815  1,912  
(4) Investments38,325  40,703  (2,378) 
(5) Deferred acquisition costs17,845  17,533  312  
(6) Policyholder dividends accrual4,746  4,323  423  
(7) Fixed assets—  3,785  (3,785) 
(8) Compensation and benefits accrual102,259  92,711  9,548  
(9) Pension accrual—  —  —  
(10) Receivables - nonadmitted26,927  149,927  (123,000) 
(11) Net operating loss carryforward—  —  —  
(12) Tax credit carryforward—  —  —  
(13) Other4,172  6,746  (2,574) 
(99) Subtotal246,001  365,543  (119,542) 
(b)Statutory valuation allowance adjustment—  —  —  
(c)Nonadmitted20,574  104,536  (83,962) 
(d)Admitted ordinary deferred tax assets (2a99 - 2b - 2c)225,427  261,007  (35,580) 
(e)Capital
(1) Investments10,343  17,219  (6,876) 
(2) Net capital loss carryforward—  —  —  
(3) Real estate—  —  —  
(4) Other—  —  —  
(99) Subtotal10,343  17,219  (6,876) 
(f)Statutory valuation allowance adjustment—  —  —  
(g)Nonadmitted—  —  —  
(h)Admitted capital deferred tax assets (2e99- 2f - 2g)10,343  17,219  (6,876) 
(i)Admitted deferred tax assets (2d + 2h)$235,770  $278,226  $(42,456) 

41

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
(1)(2)(3)
  (Col 1-2)
12/31/201912/31/2018Change
(3)Deferred tax liabilities:(In Thousands)
(a)Ordinary
(1) Investments$88,395  $95,919  $(7,524) 
(2) Fixed assets77  342  (265) 
(3) Deferred and uncollected premium8,353  8,912  (559) 
(4) Policyholder reserves4,286  5,474  (1,188) 
(5) Other27  28  (1) 
(99) Subtotal101,138  110,675  (9,537) 
(b)Capital
(1) Investments40,092  28,445  11,647  
(2) Real estate—  —  —  
(3) Other—  —  —  
(99) Subtotal40,092  28,445  11,647  
(c)Deferred tax liabilities (3a99 + 3b99)141,230  139,120  2,110  
(4)Net deferred tax assets/liabilities (2i - 3c) $94,540  $139,106  $(44,566) 
Among the more significant book-to-tax adjustments were the following:
12/31/2019Effective
Tax Rate
12/31/2018Effective
Tax Rate
12/31/2017Effective
Tax Rate
(In Thousands)(In Thousands)(In Thousands)
Provision computed at statutory rate
$39,544  21.00 %$111,878  21.00 %$101,581  35.00 %
Dividends received deduction
(1,879) (1.00) (1,990) (0.37) (74,721) (25.75) 
Tax credits(2,832) (1.50) (10,205) (1.92) (5,900) (2.03) 
Other invested assets and nonadmitted change
125,349  66.57  (156,090) (29.30) (21,153) (7.29) 
Uncertain tax positions—  —  3,876  0.73  —  —  
Statutory reserve change—  —  —  —  (215) (0.07) 
Other(5,385) (2.86) (454) (0.09) (1,304) (0.45) 
Change in federal tax rate—  —  (7,813) (1.47) 122,169  42.09  
Total statutory income taxes$154,797  82.21 %$(60,798) (11.42)%$120,457  41.50 %
Federal and foreign taxes incurred
$23,420  12.44 %$104,720  19.66 %$17,430  6.01 %
Change in net deferred income taxes
131,377  69.77  (165,518) (31.08) 103,027  35.49  
Total statutory income taxes$154,797  82.21 %$(60,798) (11.42)%$120,457  41.50 %
At December 31, 2019, the Company had $0.0 of net operating loss carryforwards, net capital loss carryforwards and tax credit carry forwards; the company had $0.0 of deferred tax liabilities that are not recognized.
42

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
On December 22, 2017, the Tax Cuts and Jobs Act (the Tax Act) was enacted, significantly changing the US income tax law. Among the provisions of the Tax Act were the establishment of a flat corporate income tax rate of 21%, a general repeal of net operating loss carrybacks and a reduction in the maximum deduction for net operating loss carryforwards arising in tax years beginning after 2017, and the elimination or reduction of certain deductions, exclusions and credits
The Company has recognized the effects of the tax rate change on its deferred tax balances in its December 31, 2017, financial statements. The re-measurement of deferred tax assets and liabilities resulted in a reduction of net deferred tax assets of $16.1 million, of which ($96.0) million and $122.2 million was recorded as an adjustment to the change in net unrealized capital gains (losses) and the change in net deferred income tax, respectively. Upon issuance of the Company’s financial statements for the year ended December 31, 2017, the Company’s accounting for certain income tax effects of the Tax Act was incomplete; however, the Company included reasonable estimates of these balances in its re-measurement of deferred tax assets and liabilities. At December 31, 2018, the Company has completed its accounting for all of the enactment-date tax effects of the Tax Act.
As of December 31, 2019, the Company had a liability for federal tax loss contingencies of $3.6 million. An estimate of the amount of any increase in the Company's liability related to any federal tax loss contingencies during the twelve month period ending December 31, 2020, cannot be made.

7. Capital and Surplus
The Company is required by statutory regulations to meet minimum risk-based capital standards. Risk-based capital is a method of measuring the minimum amount of capital appropriate for an insurance company to support its overall business operations in consideration of its size and risk profile. At December 31, 2019 and 2018, the Company exceeded the minimum risk-based capital.
Ohio insurance law limits the amount of dividends that can be paid to a parent in a holding company structure without prior approval of the regulators to the greater of 10% of statutory surplus or statutory net income as of the preceding December 31 less any dividends paid in the preceding 12 months, but only to the extent of earned surplus as of the preceding December 31. Based on these limitations, the Company is able to pay dividends of up to $542.8 million by the end of 2020 without seeking prior regulatory approval based on capital and surplus of $5,428.0 million at December 31, 2019.
The Company issued surplus notes ("the Notes") on January 23, 2019, with an aggregate principal amount of $500.0 million, an annual interest rate of 5.15%, and a maturity date of January 15, 2049, in exchange for $497.4 million in cash.
43

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Carrying Value of NoteInterest And/Or Principal Paid Current YearTotal Interest And/Or Principal PaidUnapproved Interest And/Or Principal*
(In Thousands)
As of December 31, 2019$497,519  $12,303  $12,303  $—  
* Pro-rata amount of interest due to be paid at next semi-annual payment date (pending approval) calculated as of the balance sheet date

Interest on the Notes is paid semi-annually on January 15 and July 15 of each year. The Notes were issued pursuant to Rule 144A as defined by the Securities Act of 1933 and are administered by the Bank of New York Mellon.
The Notes are unsecured and subordinated to all present and future indebtedness, policy claims and “prior claims” (those claims referred to in classes 1 through 7 of Section 3903.42 of the Ohio Revised Code) against the Company. Under Ohio insurance laws, the Notes are not part of the legal liabilities of the Company. Each payment of principal of, interest on or redemption price with respect to the Notes, may be made only with the prior approval of the Ohio Director of Insurance (the “Director”), and only out of surplus earnings.
Subject to the approval of the Director, the Company has the option to redeem the Notes (i) in whole within 90 days after the occurrence of a “Tax Event” where the Company receives an opinion of tax counsel that there is a more than insubstantial risk that interest payable on the Notes is not deductible by the Company, at a redemption price equal to the principal amount of the Notes to be redeemed (the ‘‘Par Value Redemption Price’’), (ii) in whole or in part, on or after January 23, 2024 but prior to July 15, 2048, at a redemption price equal to the greater of (a) the Par Value Redemption Price or (b) the sum of the present value of the remaining scheduled principal and interest payments on the Notes from the redemption date to July 15, 2048, discounted to the redemption date on a semi-annual basis at an adjusted treasury rate plus 35 basis points or (iii) in whole or in part, on or after July 15, 2048, at the Par Value Redemption Price, plus, in each case of (i), (ii) and (iii), accrued and unpaid interest payments on the Notes to be redeemed to the redemption date.
In the event the Company was subject to a liquidation event, the Notes would have preference over the common shareholders. No affiliates of the Company hold any of the Notes. As of the closing, Guggenheim Partners was the only holder of more than 10% of the outstanding Notes on record at the Depository Trust Company.

8. Commitments and Contingencies
The Company is named as a defendant in various legal actions arising principally from claims made under insurance policies and contracts. The Company believes the resolution of these actions will not have a material effect on the Company’s financial position or results of operations.
44

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
At December 31, 2019, the Company does not have any material lease agreements as a lessee for office space or equipment.
At December 31, 2019, the Company has future commitments to provide additional capital contributions of $393.7 million to investments in joint ventures, limited partnerships and limited liability companies.
The Company guarantees the payment of all policyholder obligations of each of the following wholly-owned subsidiaries: WSLAC, Columbus Life and Integrity. In addition, the Company guarantees all policyholder obligations of National and The Lafayette Life Insurance Company (Lafayette Life), an affiliated entity which is wholly-owned by the Company’s parent, WSFG. Guarantees on behalf of wholly-owned subsidiaries or on behalf of related parties that are considered to be unlimited (as in the case of the guarantee on behalf of Lafayette Life) are exempt from the initial liability recognition criteria and therefore no liability has been recognized in the financial statements. Due to the unlimited nature of the guarantees, the Company is unable to estimate the maximum potential amount of future payments under the guarantees. In the unlikely event the guarantees would be triggered, the Company may be permitted to take control of the underlying assets to recover all or a portion of the amounts paid under the guarantees.
The Company has guaranteed two mortgage loans in which the borrower is an affiliated limited liability company involved in development of real estate. These guarantees have a maximum exposure to the Company of $27.2 million for Canal Senate Apartments, LLC, and $14.7 million for 506 Phelps Holdings, LLC, in the event the real estate collateral of the affiliated limited liability company is not sufficient to cover the payment of the loan. The fair value of the real estate collateral at December 31, 2019, was approximately $52.3 million and $36.1 million, respectively. These loans mature in August 2022 and February 2024, respectively.
The Company has guaranteed a portion of the payment of mortgage loans made by its wholly-owned subsidiary, WSLAC, to two affiliated limited liability companies, Cranberry NP Hotel Company and Sundance Hotel, LLC, in the amounts of $9.0 million and $14.4 million, respectively. The guarantees have a maximum exposure to the Company of $4.7 million and $6.5 million in the event the real estate collateral of the affiliated limited liability company is not sufficient to cover the payment of the loan. The fair value of the real estate collateral at December 31, 2019, was approximately $9.5 million and $13.8 million. These loans mature in October 2021 and January 2024, respectively.

45

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
9. Life and Annuity Reserves and Deposit-Type Contract Liabilities
At December 31, 2019, the Company’s general and separate account annuity reserves and deposit-type contract liabilities that are subject to discretionary withdrawal (with adjustment), subject to discretionary withdrawal (without adjustment), and not subject to discretionary withdrawal provisions are summarized as follows:
Individual AnnuitiesGeneral AccountSeparate Account
With Guarantees
Separate Account
Non-guaranteed
TotalPercent
(In Thousands)
Subject to discretionary withdrawal at book value without adjustment (minimal or no charge or adjustment)
$78,441  $—  $—  $78,441  95.8 %
Not subject to discretionary withdrawal
3,414  —  —  3,414  4.2  
Total individual annuity reserves (before reinsurance)
81,855  —  —  81,855  100.0 %
Reinsurance ceded
75,085  —  —  75,085  
Net individual annuity reserves
$6,770  $—  $—  $6,770  
Group AnnuitiesGeneral AccountSeparate Account
With Guarantees
Separate Account
Non-guaranteed
TotalPercent
(In Thousands)
Not subject to discretionary withdrawal
$3,136  $—  $1,087,146  $1,090,282  100.0 %
Total group annuity reserves (before reinsurance)
3,136  —  1,087,146  1,090,282  100.0 %
Reinsurance ceded
3,136  —  —  3,136  
Net group annuity reserves
$—  $—  $1,087,146  $1,087,146  
Deposit-type contracts (no life contingencies)General AccountSeparate Account
With Guarantees
Separate Account
Non-guaranteed
TotalPercent
(In Thousands)
Subject to discretionary withdrawal at book value without adjustment (minimal or no charge or adjustment)
$229,291  $—  $—  $229,291  100.0 %
Not subject to discretionary withdrawal
—  —  —  —  —  
Total deposit-type contract liability (before reinsurance)
229,291  —  —  229,291  100.0 %
Reinsurance ceded
24,632  —  —  24,632  
Total deposit-type contract liability
$204,659  $—  $—  $204,659  
Interest rate changes may have temporary effects on the sale and profitability of annuity products offered by the Company. Although the rates offered by the Company are adjustable in the long-term, in the short-term they may be subject to contractual and competitive restrictions, which may prevent timely adjustment. The Company’s management constantly monitors interest rates with respect to a spectrum of
46

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
product durations and sells annuities that permit flexible responses to interest rate changes as part of the Company’s management of interest spreads. However, adverse changes in investment yields on invested assets will affect the earnings on those products with a guaranteed return.
At December 31, 2019, the Company's general and separate account life insurance account values, cash value, and reserves for policies subject to discretionary withdrawal, not subject to discretionary withdrawal, or with no cash value are summarized as follows:
General AccountSeparate Account - Guaranteed and Nonguaranteed
Account ValueCash ValueReserveAccount ValueCash ValueReserve
(In Thousands)
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value$—  $—  $—  $—  $—  $—  
Universal life—  —  —  —  —  —  
Universal life with secondary guarantees
—  —  —  —  —  —  
Indexed universal life—  —  —  —  —  —  
Indexed universal life with secondary guarantees
—  —  —  —  —  —  
Indexed life—  —  —  —  —  —  
Other permanent cash value life insurance
—  2,717,313  3,071,282  —  —  —  
Variable life—  —  —  —  —  —  
Variable universal life—  —  —  —  —  —  
Miscellaneous reserves—  —  —  —  —  —  
Not subject to discretionary withdrawal or no cash values:
Term policies without cash valueXXX  XXX  —  XXX  XXX  —  
Accidental death benefitsXXX  XXX  3,402  XXX  XXX  —  
Disability - active livesXXX  XXX  5,169  XXX  XXX  —  
Disability - disabled livesXXX  XXX  23,402  XXX  XXX  —  
Miscellaneous reservesXXX  XXX  —  XXX  XXX  —  
Total life reserves (before reinsurance)—  2,717,313  3,103,255  —  —  —  
Reinsurance Ceded—  —  392,312  —  —  —  
Net life reserves$—  $2,717,313  $2,710,943  $—  $—  $—  

10. Employee Retirement Benefits
The Company has a noncontributory pension plan under group annuity contracts written by the Company covering substantially all employees and field representatives. In addition, the Company provides certain health care and life insurance benefits for retired employees or their beneficiaries. Substantially all of the Company’s employees and field representatives may become eligible for those benefits when they reach normal retirement age while working for the Company.
The Company uses a December 31 measurement date for all plans.
47

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
A summary of assets, obligations and assumptions of the pension and other postretirement benefit plans at December 31, are as follows:
Pension BenefitsPostretirement Medical
2019201820192018
(In Thousands)
Change in benefit obligation:
Benefit obligation at beginning of year$964,649  $1,026,400  $155,942  $164,700  
Service cost23,989  22,511  308  404  
Interest cost38,479  34,022  6,044  5,419  
Contribution by plan participants—  —  4,805  4,930  
Actuarial (gain) loss133,588  (74,041) 12,288  (6,492) 
Benefits paid(50,023) (49,851) (12,500) (13,019) 
Plan amendments—  5,608  —  —  
Settlements—  —  —  —  
Benefit obligation at end of year$1,110,682  $964,649  $166,887  $155,942  
Change in plan assets:
Fair value of plan assets at beginning of year
$933,756  $993,403  $—  $—  
Actual return on plan assets203,413  (9,796) —  —  
Employer contribution—  —  7,695  8,089  
Plan participants’ contributions—  —  4,805  4,930  
Benefits paid(50,023) (49,851) (12,500) (13,019) 
Settlements—  —  —  —  
Fair value of plan assets at end of year$1,087,146  $933,756  $—  $—  

Pension BenefitsPostretirement Medical
2019201820192018
(In Thousands)
Funded status:
Overfunded (underfunded) obligation$(23,536) $(30,893) $(166,887) $(155,942) 
Unrecognized net (gain) or loss—  —  —  —  
Unrecognized prior service cost—  —  —  —  
Net amount recognized*$(23,536) $(30,893) $(166,887) $(155,942) 
Accumulated benefit obligation for vested employees and partially vested employees to the extent vested
$1,026,764  $904,797  $166,887  $155,942  
*Nonadmitted if overfunded

48

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Pension Benefits
201920182017
(In Thousands)
Components of net periodic benefit cost:
Service cost$23,989  $22,511  $19,990  
Interest cost38,479  34,022  35,792  
Expected return on plan assets(68,093) (72,592) (66,605) 
Amount of recognized gains and losses25,564  27,655  31,765  
Amount of prior service cost recognized(4,625) (4,620) (5,134) 
Total net periodic benefit cost (benefit)$15,314  $6,976  $15,808  

Postretirement Medical
201920182017
(In Thousands)
Components of net periodic benefit cost:
Service cost$308  $404  $483  
Interest cost6,044  5,419  5,688  
Amount of recognized gains and losses(3,841) (2,138) (2,986) 
Amount of prior service cost recognized(1,392) (2,633) (1,503) 
Total net periodic benefit cost (benefit)$1,119  $1,052  $1,682  

Pension BenefitsPostretirement Medical
2019201820192018
(In Thousands)
Amounts in unassigned funds (surplus) recognized as components of net periodic benefit cost:
Items not yet recognized as a component of net periodic cost - prior year
$366,459  $375,539  $(47,044) $(45,288) 
Net transition asset or obligation recognized
—  —  —  —  
Net prior service cost or credit arising during the period
—  5,608  —  —  
Net prior service cost or credit recognized
4,625  4,620  1,392  2,633  
Net gain and loss arising during the period
(1,731) 8,347  12,289  (6,527) 
Net gain and loss recognized
(25,564) (27,655) 3,841  2,138  
Items not yet recognized as a component of net periodic cost - current year
$343,789  $366,459  $(29,522) $(47,044) 

49

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Pension BenefitsPostretirement Medical
2019201820192018
(In Thousands)
Amounts in unassigned funds (surplus) that have not yet been recognized as components of net periodic benefit cost:
Net transition asset or (obligation)
$—  $—  $—  $—  
Net prior sevice cost or (credit)
(1,775) (6,399) (4,175) (5,566) 
Net recognized gains and (losses)
345,563  372,858  (25,348) (41,477) 

Assumptions used to determine net periodic benefit cost for the year ended December 31:
Pension BenefitsPostretirement Medical
2019201820192018
Discount rate4.39%3.78%4.34%3.71%
Rate of compensation increase4.60%4.60%N/AN/A
Expected long-term rate of return on plan assets
7.50%7.50%N/AN/A

Assumptions used to determine the benefit obligation at December 31:
Pension BenefitsPostretirement Medical
2019201820192018
Discount rate3.44%4.39%3.32%4.34%
Rate of compensation increase4.60%4.60%N/AN/A
The Company’s pension liability was $23.5 million and $30.9 million at December 31, 2019 and 2018, respectively.
The Company utilizes a full yield curve approach in the estimation of liabilities, service cost, and interest cost for pension and postretirement benefits by applying the specific spot rates along the yield curve used in the determination of the benefit obligation to the relevant projected cash flows. The yield curve utilized in the cash flow analysis is comprised of highly rated (Aaa or Aa) corporate bonds. The discount rate was decreased from 4.39% at December 31, 2018, to 3.44% at December 31, 2019. This resulted in a $133.3 million increase in the pension benefit obligation in 2019. The discount rate was increased from 3.78% at December 31, 2017, to 4.39% at December 31, 2018. This resulted in a $80.4 million decrease in the pension benefit obligation in 2018.
The Company employs a prospective building block approach in determining the long-term expected rate of return for plan assets. Historical returns are determined by asset class. The historical relationships between equities, fixed income securities, and other assets are reviewed. The Company applies long-term asset return estimates to the plan’s target asset allocation to determine the weighted-average long-term return. The Company’s long-term asset allocation was determined through modeling long-term returns and asset return volatilities and is guided by an investment policy statement created for the plan.
50

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The asset allocation for the defined benefit pension plan at the end of 2019 and 2018, and the target allocation for 2019 by asset category, are as follows:
Target Allocation PercentagePercentage of
Plan Assets
201920192018
Asset category:
Equity securities
55 %63 %59 %
Fixed income securities
15  13  14  
Short-term investments
 —   
Other
25  24  26  
Total100 %100 %100 %
The plan employs a total return investment approach whereby a mix of fixed income and equity investments are used to maximize the long-term return of plan assets for a prudent level of risk. Risk tolerance is established through careful consideration of plan liabilities, plan funded status, and corporate financial condition. The total portfolio is structured with multiple sub-portfolios, each with a specific fixed income or equity asset management discipline. Each sub-portfolio is subject to individual limitations and performance benchmarks as well as limitations at the consolidated portfolio level. Quarterly asset allocation meetings are held to evaluate portfolio asset allocations and to establish the optimal mix of assets given current market conditions and risk tolerance. Investment mix is measured and monitored on an ongoing basis through regular investment reviews, annual liability measurements, and periodic asset/liability studies.
The Company’s pension plan assets consist primarily of debt and equity securities, mutual funds and private equity funds, all of which are carried at fair value.
Fair value is defined as the price that would be received to sell an asset in an orderly transaction between market participants at the measurement date (an exit price). The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three levels.
Level 1 - Quoted prices (unadjusted) in active markets for identical assets or liabilities. The Company’s Level 1 assets primarily include exchange-traded equity securities and mutual funds.
Level 2 - Inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. The Company’s Level 2 assets include certain debt securities for which public price quotations are not available, but that use other market observable inputs from third-party pricing service quotes or internal valuation models using observable inputs. Level 2 assets also include private funds that invest primarily in domestic debt securities where the Company has the right to redeem its interest at net asset values. The underlying debt securities within these funds employ similar valuation methodologies as the Company’s other investments in debt securities.
Level 3 - Significant unobservable inputs for the asset or liability. The Company’s Level 3 assets primarily include private equity fund interests.
51

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Debt Securities
The fair values of actively traded debt securities have been determined through the use of third-party pricing services utilizing market observable inputs.
Equity Securities
The fair values of actively traded equity securities have been determined utilizing publicly quoted prices from third-party pricing services.
Mutual Funds
The fair values of mutual funds have been determined utilizing the net asset values of the funds.
Private Equity and Fixed Income Funds
The fair values of private equity and fixed income funds have been determined utilizing the net asset values of the funds.
Other Assets
Other assets primarily include securities lending reinvested collateral and a group annuity contract. The fair value of securities lending reinvested collateral assets are from third-party sources utilizing publicly quoted prices. The group annuity contract is carried at cash surrender value, which approximates fair value.
52

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
The fair value of the pension plan’s assets by asset category is as follows:
Assets Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2*Level 3
(In Thousands)
At December 31, 2019:
Debt securities:
Debt securities issued by states of the U.S. and political subdivisions of the states
$2,757  $—  $2,757  $—  
Corporate securities
119,339  —  119,339  —  
Residential mortgage-backed securities
2,256  —  2,256  —  
Asset-backed securities
10,920  —  10,920  —  
Equity securities:
Common equity
459,501  415,316  44,185  —  
Mutual funds
221,621  221,621  —  —  
Other invested assets:
Private equity and fixed income funds
230,058  —  230,058  —  
Surplus notes
3,717  —  3,717  —  
Real estate
19,844  —  —  19,844  
Other assets
71,586  70,014  1,572  —  
Total plan assets
$1,141,599  $706,951  $414,804  $19,844  
* Includes investments using net asset value (NAV) as a practical expedient.

53

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Assets Measured at Fair ValueFair Value Hierarchy Level
Level 1Level 2*Level 3
(In Thousands)
At December 31, 2018:
Debt securities:
Debt securities issued by states of the U.S. and political subdivisions of the states
$2,220  $—  $2,220  $—  
Corporate securities
106,423  —  106,423  —  
Residential mortgage-backed securities
4,519  —  4,519  —  
Asset-backed securities
11,149  —  10,545  604  
Equity securities:
Common equity
368,763  328,459  40,304  —  
Mutual funds
179,682  179,682  —  —  
Other invested assets:
Private equity and fixed income funds
212,558  —  212,558  —  
Surplus notes
2,992  —  2,992  —  
Real estate
18,052  —  —  18,052  
Other assets
54,778  53,184  1,594  —  
Total plan assets
$961,136  $561,325  $381,155  $18,656  
* Includes investments using net asset value (NAV) as a practical expedient.
For measurement purposes of the postretirement benefit obligation at December 31, 2019, a 5.425 percent annual rate of increase in the per capita cost of covered health care benefits is assumed for 2020. The rate was assumed to decrease gradually to 4.75 percent for 2029 and remain at that level thereafter.
At December 31, 2019, the assets of the Company’s pension include approximately $105.9 million invested in the Touchstone Family of Funds, which are administered by the Company, and $205.3 million invested in private equity and fixed income funds managed by Fort Washington Investment Advisors, Inc. At December 31, 2018, the assets of the Company’s pension include approximately $85.6 million invested in the Touchstone Family of Funds, which are administered by the Company, $181.0 million invested in private equity and fixed income funds managed by Fort Washington Investment Advisors, Inc.
As of December 31, 2019, future benefit payments for the pension plan are expected as follows (in millions):
2020$53.2  
202154.1  
202255.1  
202356.1  
202457.0  
Five years thereafter299.8  
54

The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2019, 2018 and 2017
Future benefit payments for the postretirement medical plan, net of amounts contributed by plan participants, are expected as follows (in millions):
2020$10.5  
202110.5  
202210.3  
202310.3  
202410.0  
Five years thereafter46.9  
The Company did not make any contributions to the pension plan in 2019 and 2018. The Company does not anticipate a required contribution to the pension plan during 2020.
The Company made contributions to the postretirement medical plan of $7.7 million in 2019 and expects to contribute $98.6 million between 2020 and 2028, inclusive. The Company received no subsidies in 2019. The Company’s postretirement medical plan did not collect the Medicare Part D Subsidy for claims activity occurring after January 1, 2013.
The Company sponsors a contributory employee retirement savings plan covering substantially all eligible, full-time employees. This plan is subject to the provisions of the Employee Retirement Income Security Act of 1974 (ERISA). The Company’s contributions to the plan are based on a combination of the employee’s contributions to the plan and a percentage of the employee’s earnings for the year. The total of the Company’s contributions to the defined contribution plan were $6.2 million, $5.4 million, and $5.1 million for 2019, 2018 and 2017, respectively.

11. Premium and Annuity Considerations Deferred and Uncollected
Deferred and uncollected life insurance premiums and annuity considerations at December 31, 2019, were as follows:
GrossNet of Loading
(In Thousands)
Ordinary new business$4,331  $257  
Ordinary renewal69,162  49,052  
Accident and health renewal345  260  
Assumed investment type-contracts190  190  
Total$74,028  $49,759  


55

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PART C - Other Information

Item 24.
Financial Statements and Exhibits

(a)
Financial Statements:

Financial Statements included in Part A:

Condensed Financial Information for the Portfolios

Financial Statements included in Part B:

Separate Account I of National Integrity Life Insurance Company:
Report of Independent Registered Public Accounting Firm
Statements of Assets and Liabilities as of December 31, 2019
Statements of Operations for the Year Ended December 31, 2019
Statements of Changes in Net Assets for the Years Ended December 31, 2019 and 2018
Notes to Financial Statements

National Integrity Life Insurance Company (Depositor):
Report of Independent Auditors
Balance Sheets (Statutory-Basis) as of December 31, 2019 and 2018
Statements of Operations (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Statements of Changes in Capital and Surplus (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Statements of Cash Flow (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Notes to Financial Statements (Statutory-Basis)

The Western and Southern Life Insurance Company (Guarantor):
Report of Independent Auditors
Balance Sheets (Statutory-Basis) as of December 31, 2019 and 2018
Statements of Operations (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Statements of Changes in Capital and Surplus (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Statements of Cash Flow (Statutory-Basis) for the Years Ended December 31, 2019, 2018 and 2017
Notes to Financial Statements (Statutory-Basis)

(b) Exhibits:

The following exhibits are filed herewith or incorporated by reference as indicated:

1.
Resolutions of the Board of Directors of National Integrity Life Insurance Company (National Integrity) authorizing the establishment of Separate Account I, the Registrant. Incorporated by reference to Exhibit 99.1 to Registrant’s Post-Effective Amendment No. 9 to registration statement on Form N-4 (File No. 333-44892), filed July 19, 2006.
2.
Not Applicable
3.

a.
Form of Selling/General Agent Agreement among National Integrity, Touchstone Securities, Inc. and broker dealers. Incorporated by reference to Exhibit 99.3(A) to Registrant’s initial registration statement on Form N-4 (File No. 333-178439), filed December 12, 2011.
b.
Form of Selling Agreement among W&S Financial Group Distributors, Inc., on behalf of National Integrity, Touchstone Securities, Inc., and broker dealers. Incorporated by reference to Exhibit 99.3(B) to Registrant’s Post-Effective Amendment No. 4 to registration statement on Form N-4 (File No. 333-177618), filed April 25, 2014.
c.
Variable Contract Principal Underwriter Agreement with Touchstone Securities, Inc. dated May 1, 2006. Incorporated by reference to Exhibit 99.3(B) to Registrant’s initial registration statement on Form N-4 (File No. 333-178439), filed December 12, 2011.

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4.

a.
b.
c.
d.
e.
f.
5.

a.
b.
6.

a.
b.
c.
7.
Not applicable.
8.

a.
Amended and Restated Participation Agreement among Variable Insurance Products Funds, Fidelity Distributors Corporation and National Integrity dated August 10, 2007. Incorporated by reference to Exhibit 99.8(A) to Registrant's Post-Effective Amendment No. 1 to registration statement on Form N-4 (File No. 333-177618), filed April 25, 2012.
b.
Amendment No. 1 to Amended and Restated Participation Agreement among Variable Insurance Products Funds, Fidelity Distributors Corporation and Integrity dated August 10, 2007. Incorporated by reference to Exhibit 99.8(B) to Registrant's Post-Effective Amendment No. 1 to registration statement on Form N-4 (File No. 333-177618), filed April 25, 2012.
c.
d.
e.

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April 2020


f.
g.
h.
Amendment 2 to Access Agreement and ETFxChange Authorization between Integrity and Mid Atlantic Trust Company effective February 2, 2015. Incorporated by reference to Exhibit 99.8(H) to Registrant’s Post-Effective Amendment No. 4 to registration statement on Form N-4 (File No. 333-178439), filed April 28, 2015.
i.
9.
Opinion and Consent of Bryan J. Kreyling, Esq. as to the legality of the securities registered, filed herewith.
10.

a.
Consent of Independent Registered Public Accounting Firm, filed herewith.
b.
Consent of Independent Auditors, filed herewith.
11.
Not applicable.
12.
Not applicable.
13.
Powers of Attorney of members of the Board of Directors of The Western and Southern Life Insurance Company (WSLIC), specifically James N. Clark, Jo Ann Davidson, Robert B. Truitt, and Thomas L. Williams, each dated April 16, 2019. Incorporated by reference to Exhibit 99.13 to Registrant's Post-Effective Amendment No. 10 to registration statement on Form N-4 (File No. 333-167372), filed April 26, 2019.
14.
15.
Cover letter, filed herewith.

Item 25.    Directors and Officers of the Depositor

The names, positions and principal business addresses* of the directors and officers of the Depositor are as follows:

Directors:
John F. Barrett
Director, Chairman of the Board
Edward J. Babbitt
Director, Secretary
Jill T. McGruder
Director, President and Chief Executive Officer
Jonathan D. Niemeyer
Director
Donald J. Wuebbling
Director
Daniel J. Downing
Director, Senior Vice President
Eric C. Fast1 
Director
Cameron F. MacRae III2 
Director
Newton Phelps Stokes Merrill3 
Director
George R. Bunn Jr.4 
Director

Officers:
John F. Barrett
Director, Chairman of the Board     
Jill T. McGruder
Director, President and Chief Executive Officer
Edward J. Babbitt    Director, Secretary
Roger M. Lanham    Senior Vice President and Co-Chief Investment Officer
Brendan M. White    Senior Vice President and Co-Chief Investment Officer
Karen A. Chamberlain    Senior Vice President and Chief Information Officer
Kevin L. Howard    Senior Vice President and General Counsel
Daniel W. Harris    Senior Vice President and Chief Actuary
Mark E. Caner    Senior Vice President
Daniel J. Downing    Senior Vice President
Lisa B. Fangman    Senior Vice President

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Phillip E. King    Senior Vice President and Auditor
David T. Henderson    Senior Vice President and Chief Risk Officer
Bradley J. Hunkler    Senior Vice President and Chief Financial Officer
James J. Vance    Senior Vice President and Treasurer
Wade M. Fugate    Vice President and Controller
Bruce W. Maisel    Vice President and Chief Compliance Officer
Michael S. Speas    Vice President and Chief Information Security Officer
Aaron J. Wolf    Vice President and Chief Underwriter
Jay V. Johnson    Vice President and Assistant Treasurer
Terrie A. Wiedenheft    Vice President
Paul M. Kruth    Vice President
Chistopher N. Watford    Vice President
Denise L. Sparks    Vice President
Lindsay M. Connelly    Assistant Vice President, Assistant Treasurer
Benjamin E. Fotsch    Assistant Vice President
Christopher J. Roland    Assistant Vice President
Robert F. Noschang    Assistant Vice President
Brian A. Eichhold    Assistant Vice President
Donald P. Myers     Assistant Vice President
Ryan K. Richey    Assistant Vice President
Andrew P. Shull    Assistant Vice President
Jacob C. Steuber    Assistant Vice President
James R. Murray    Assistant Vice President, Director, Risk Management
John S. Musgrove     Assistant Vice President and Assistant Treasurer
Jason T. Anderson    Assistant Treasurer
Timothy D. Speed    Assistant Treasurer
Sharon A. Cummings    Licensing Officer
Brenda L. Elliott    Manager, Licensing

*The principal business address for the above is 400 Broadway, Cincinnati, Ohio 45202, unless otherwise noted.
1 Principal Business Address: 29 Hillside Road, Greenwich, CT 06830
2 Principal Business Address: 1540 Broadway, New York, NY 10036-4086
3 Principal Business Address: 262 Central Park West, Apt. 12B, New York, NY 10024
4 Principal Business Address: 126 East 56th Street, 12th Floor, New York, NY 10022-3584


Item 26.
Persons Controlled by or Under Common Control with National Integrity or Registrant
Affiliate
State
Entity Abb
Ownership
Type of Business
1373 Lexington Road Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC; 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
2758 South Main SPE, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
ownership and operation of real estate
309 Holding LLC
DE
LLC
97% owned by The Western and Southern Life Insurance Company, 1% owned by W&S Real Estate Holdings, Inc. and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
506 Phelps Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Airport Exchange Hotel Partners
KY
GP
74% owned by WS Airport Exchange GP, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate

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Affiliate
State
Entity Abb
Ownership
Type of Business
Alliant Tax Credit Fund 92 LP
CA
LP
13.4% limited partnership interest owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
Alta Mercer Crossing, LLC
DE
LLC
50% owned by Wood Mercer Crossing, LLC, 49% owned by Mercer Crossing Investor Holdings, LLC, and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Alta Preston Residences, LLC
DE
LLC
100% owned by Alta Preston, LLC
ownership and operation of real estate
Alta Preston, LLC
DE
LLC
100% owned by Alta, 47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Alta Stony Point, LLC
DE
LLC
49% owned by Stony Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Apex Housing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Apex Louisville, LLC
KY
LLC
64% owned by Apex Housing Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Arvada Kipling Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Ascent Plainfield, LLC
IN
LLC
64% owned by Stout Metro Housing Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Axis JV, LLC
KY
LLC
64% owned by 1373 Lexington Road Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Axis Louisville, LLC
KY
LLC
100% owned by Axis JV, LLC
ownership and operation of real estate
Beardsley Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
BP Summerville Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Buckeye Venture Partners, LLC
OH
LLC
60% owned by Fort Washington Investment Advisors, Inc. (FWIA); 40% owned by Peppertree Partners, LLC
private equity fund management
BVP NEO, LLC
OH
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund management
Canal Senate Apartments, LLC
IN
LLC
100% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
Cape Barnstable Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

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Affiliate
State
Entity Abb
Ownership
Type of Business
Carmel Holdings, LLC
OH
LLC
99% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Carmel Hotel Investor, LLC
OH
LLC
100% owned by Carmel Holdings, LLC
real estate ownership entity(ies)
Carmel Hotel, LLC
IN
LLC
99% owned by Carmel Hotel Investor, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Carthage Senior Housing, Ltd.
OH
LLC
98% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
CCA CBD Cincinnati LLC
OH
LLC
100% owned by 309 Holding, LLC
ownership and operation of real estate
Cedar Park Senior Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cenizo Apartments Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Charlotte Park Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Chattanooga Southside Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Chestnut Healthcare Partners, L.P.
DE
LP
20% limited partnership interest owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
Choo Choo Residences, LLC
DE
LLC
49% owned by Chattanooga Southside Apartments Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Cincinnati CBD Holdings, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
Cinnaire Fund for Housing Limited Partnership 31
MI
LP
16.7% limited partnership interest owned by Columbus Life Insurance Company
real estate ownership entity(ies)
Cleveland East Hotel, LLC
OH
LLC
99% owned by WSALD CEH, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Columbus Life Insurance Company
OH
Corp
100% owned by The Western and Southern Life Insurance Company
 
Country Place Associates
OH
GP
90% owned by WS Country Place GP, LLC; 10% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cove Housing Investor Holdings, LLC
OH
LLC
98% W&S Real Estate Holdings, LLC and 2% Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Covington Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

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Affiliate
State
Entity Abb
Ownership
Type of Business
Crabtree Apartments, LLC
TX
LLC
59% owned by Crabtree Commons Apts Investor Holdings, LLC (W&S) and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Crabtree Commons Apts Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cranberry NP Hotel Company, LLC
PA
LLC
99% owned by NP Cranberry Hotel Investor LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Curve Luxury Apartments Investors, LLC
DE
LLC
59% owned by MC Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Curve Luxury Apartments, LLC
AZ
LLC
100% owned by Curve Luxury Apartments Investors, LLC
ownership and operation of real estate
Dallas City Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Day Hill Road Land LLC
CT
LLC
74% owned by W&S Real Estate Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Delco Lofts, LLC
OH
LLC
99% owned by Patterson at First Investor Holdings, LLC
ownership and operation of real estate
Domain at Dunvale, LLC
TX
LLC
49% owned by Dunvale Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Dunvale Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Eagle Realty Capital Partners, LLC
OH
LLC
100% Eagle Realty Group, LLC
investment advisor
Eagle Realty Group, LLC
OH
LLC
100% owned by Western & Southern Investment Holdings, LLC
real estate holding company
Eagle Realty Investments, Inc. (ERI)
OH
Corp
100% owned by Eagle Realty Group, LLC
real estate ownership entity(ies)
Eagle Rose Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Eagle Rose Land Partners, LLC
DE
LLC
24% owned by Eagle Rose Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Eagle Rose Owner, LLC
DE
LLC
100% owned by Eagle Rose Land Partners, LLC
ownership and operation of real estate
Elan Dallas City Lights GP, LLC
DE
LLC
100% owned by Elan Dallas City Lights, LLC
real estate ownership entity(ies)
Elan Dallas City Lights Limited Partner, LP
DE
LLC
100% owned by Elan Dallas City Lights, LLC; 0% owned by Elan Dallas City Lights GP, LLC
real estate ownership entity(ies)

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Affiliate
State
Entity Abb
Ownership
Type of Business
Elan Dallas City Lights Owner, LP
DE
LP
99% owned by Elan Dallas City Lights Limited Partner, LP; 1% owned by Elan Dallas City Lights GP, LLC
ownership and operation of real estate
Elan Dallas City Lights, LLC
DE
LLC
59% owned by Dallas City Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
EMF DT SA, LLC (2017) (Encore River Walk)
DE
LLC
100% owned by EMF River Walk Investments, LLC
ownership and operation of real estate
EMF River Walk Investments, LLC
DE
LLC
54% owned by South Flores Housing Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
EP/WSE Glendale Venture, LLC
DE
LLC
49% owned by Beardsley Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Flats at Springhurst LLC
KY
LLC
100% owned by Springhurst JV, L.L.C.
ownership and operation of real estate
Flats Springhurst Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Forsyth Halcyon AA Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Fort Washington Capital Partners, LLC (FWCP)
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
managing partner for numerous private equity funds
Fort Washington Emerging Market Debt LLC
DE
LLC
Managing Member is Fort Washington Fixed Income LLC
fixed income
Fort Washington Fixed Income LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private fixed income fund
Fort Washington Flexible Income LLC
DE
LLC
Managing Member is Fort Washington Fixed Income LLC
private fixed income fund
Fort Washington Full Discretion Fixed Income LLC
DE
LLC
Managing Member Fort Washington Fixed Income LLC and investors include The Western and Southern Life Insurance Company
managing member for private fixed income fund
Fort Washington High Yield Investors II, LLC
DE
LLC
managing member is FWCP
private fixed income fund
Fort Washington High Yield Investors LLC
DE
LLC
managing member is FWCP
private fixed income fund
Fort Washington Investment Advisors, Inc. (FWIA)
OH
Corp
100% owned by Western & Southern Investment Holdings, LLC
registered investment adviser
Fort Washington Private Equity Investors II, L.P.
DE
LP
general partner is FWCP and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors III, L.P.
DE
LP
general partner is FWCP and investors include The Western and Southern Life Insurance Company
private equity fund

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Affiliate
State
Entity Abb
Ownership
Type of Business
Fort Washington Private Equity Investors IV, L.P.
DE
LP
general partner is FWCP and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors IX, L.P.
DE
LP
general partner is FWPEI IX GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors IX-B, L.P.
DE
LP
General Partner is FWPEI IX GP, LLC and The Western and Southern Life Insurance Company is the sole limited partner
private equity fund
Fort Washington Private Equity Investors IX-K, L.P.
DE
LP
general partner is FWPEI IX GP, LLC
private equity fund
Fort Washington Private Equity Investors V, L.P.
DE
LP
general partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors V-B, L.P.
DE
LP
general partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors VI, L.P.
DE
LP
general partner is FWPEI VI GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors VII, L.P.
DE
LP
general partner is FWPEI VII GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors VIII, L.P.
DE
LP
general partner is FWPEI VIII GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors VIII-B, L.P.
DE
LP
General Partner is FWPEI VIII GP, LLC and The Western and Southern Life Insurance Company is the sole limited partner
private equity fund
Fort Washington Private Equity Investors V-VC, L.P.
DE
LP
general partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors X, L.P.
DE
LP
general partner is FWPEI X GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Fort Washington Private Equity Investors X-B, L.P.
DE
LP
general partner is FWPEI X GP, LLC and The Western and Southern Life Insurance Company is the sole limited partner
private equity fund
Fort Washington Private Equity Opportunities Fund II, L.P.
DE
LP
General Partner is FWPEO II GP, LLC and The Western and Southern Life Insurance Company is an investor
private equity fund
Fort Washington Private Equity Opportunities Fund III, L.P.
DE
LP
General Partner is FWPEO III GP, LLC and The Western and Southern Life Insurance Company is an investor
private equity fund
Fort Washington Private Equity Opportunities Fund III-B, L.P.
DE
LP
General Partner is FWPEO III GP, LLC and The Western and Southern Life Insurance Company is the sole limited partner
private equity fund
Fort Washington Private Equity Small Market Investors X-S, L.P.
DE
LP
general partner is FWPEI X GP, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Frontage Lodging Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

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Affiliate
State
Entity Abb
Ownership
Type of Business
FWPEI IX GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of Fund IX
FWPEI V GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of the three private equity funds
FWPEI VI GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of Fund VI
FWPEI VII GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of Fund VII
FWPEI VIII GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of Fund VIII
FWPEI X GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
general partner of Fund X
FWPEO II GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund management
FWPEO III GP, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund management
Gateway at Arvada Ridge, LLC
DE
LLC
35.39% owned by Arvada Kipling Housing Holdings, LLC and 0.72% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Gerber Life Insurance Company
NY
Corp
100% owned by The Western and Southern Life Insurance Company
 
Glendale Beardsley, LLC
DE
LLC
100% owned by EP/WSE Glendale Venture, LLC (DE)
ownership and operation of real estate
Great Lakes Capital Fund for Housing LP 30
MI
LP
13.5% limited partnership interest owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
GS Lakeline AA Apartments, LLC
DE
LLC
49% owned by Cedar Park Senior Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
GS McFarland AA Apartments, LLC
DE
LLC
49% owned by Forsyth Halcyon AA Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
 
GS Nashville Hotel Owner, LLC
DE
LLC
100% owned by Nashville Hotel JV, LLC
ownership and operation of real estate
GS Short Pump AA Apartments Owner, LLC
DE
LLC
100% owned by GS Short Pump AA Apartments, LLC
ownership and operation of real estate
GS Short Pump AA Apartments, LLC
DE
LLC
49% owned by Three Chopt AA Investor Holdings, LLC; and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Heartis Venice JV, LLC
DE
LLC
49% owned by Tamiami Senior Investor Holdings, LLC (OH) and 1% owned Eagle Realty Investments, Inc.
real estate ownership entity(ies)

10

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Heartis Venice, LLC
DE
LLC
100% owned by Heartis Venice JV, LLC
ownership and operation of real estate
Houston Reverie, LLC
TX
LLC
59% owned by River Hollow Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
IFS Financial Services, Inc. (IFS)
OH
Corp
100% owned by Western-Southern Life Assurance Company (Western-Southern Life Assurance Company)
real estate ownership entity(ies)
Insurance Profillment Solutions, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
insurance marketing services
Integrity Life Insurance Company (ILIC)
OH
Corp
100% owned by The Western and Southern Life Insurance Company
 
IR Mall Associates, Ltd.
FL
LP
49.50% owned by The Western and Southern Life Insurance Company
ownership and operation of real estate
IR Mall Company, L.C.
FL
LLC
50% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
JLB Southpark Apartments LLC
DE
LLC
49% owned by SP Charlotte Apts Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
KCWSE Palmetto Pointe, LLC
DE
LLC
64% owned by Cenizo Apartments Investor Holdings, LLC; and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Keller Hicks Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
LaFrontera Hotel LLC
TX
LLC
100% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
LaFrontera Lodging Partners LP
OH
LP
99% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
Lennox Zionsville Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
LeRoy Glen Investment, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
LLIA, Inc.
OH
Corp
100% owned by The Lafayette Life Insurance Company
general insurance agency
Lookout Corporate Center
KY
JVGP
50% owned by WS Lookout GP, LLC
ownership and operation of real estate
Lorraine Senior Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Lytle Park Inn, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate

11

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Main Hospitality Holdings, LLC
OH
LLC
78.4% owned by W&S Real Estate Holdings, LLC and 1.6% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
MC Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Mercer Crossing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Midtown Park Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Monterosso Apartments JV, LLC
DE
LLC
54% owned by Monterosso Housing Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Monterosso Apartments, LLC
DE
LLC
100% owned by Monterosso Apartments JV, LLC
ownership and operation of real estate
Monterosso Housing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Monterosso Housing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
MP Dallas Development Holdings, LLC
DE
LLC
49% owned by Midtown Park Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
MP Dallas Project Owner, LLC
DE
LLC
100% owned by MP Dallas Development Holdings, LLC
ownership and operation of real estate
Nashville Hotel JV, LLC
DE
LLC
52% owned by W&S REH and 3% by ERI
real estate ownership entity(ies)
NE Emerson Edgewood, LLC
IN
LLC
60% owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
NEO Capital Fund, LP
DE
LP
General Partner is BVP NEO, LLC
private equity fund
North Pittsburgh Hotel LLC
PA
LLC
99% owned by WSALD NPH, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
NP Cranberry Hotel Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC, 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
NP Cranberry Hotel Investor, LLC
OH
LLC
100% owned by NP Cranberry Hotel Holdings, LLC
real estate ownership entity(ies)
OTR Housing Associates, L.P.
OH
LP
98% owned by The Western and Southern Life Insurance Company; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
OTR Redevelopment Group, LLC
OH
LLC
100% owned by OTR Walnut Housing, Ltd.
real estate ownership entity(ies)

12

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
OTR Transitional Housing, L.P.
OH
LP
99% owned by The Western and Southern Life Insurance Company
ownership and operation of real estate
OTR-Walnut Housing, Ltd.
OH
LLC
100% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Patterson at First Investor Holdings, LLC
OH
LLC
100% owned by Integrity Life Insurance Company
real estate ownership entity(ies)
Perimeter Development Holdings, LLC
DE
LLC
49% owned by Perimeter TC Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Perimeter Project Owner, LLC
DE
LLC
100% Perimeter Development Holdings, LLC
ownership and operation of real estate
Perimeter TC Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Pleasanton Hotel Holding Company LLC
DE
LLC
69% owned by Pleasanton Hotel Investor Holdings, 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Pleasanton Hotel Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Pleasanton Project Owner, LLC
DE
LLC
100% owned by Pleasanton Hotel Holding Company LLC
ownership and operation of real estate
Prairie Path Apts Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Price Road Hotel LLC
DE
LLC
64% owned by Price Willis Lodging Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Price Willis Lodging Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Queen City Square Development I, LLC
OH
LLC
100% owned by Eagle Realty Group, LLC
operation of real estate
Queen City Square, LLC
OH
LLC
99.75% owned to The Western and Southern Life Insurance Company; .25% Eagle Realty Investments, Inc.
ownership and operation of real estate
R4 Housing Partners IX LP
DE
LLC
14.7% limited partnership interest owned by The Lafaye Insurance Company
real estate ownership entity(ies)
R4 Housing Partners V LP
DE
LP
9.3% limited partnership interest owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
R4 Housing Partners VI LP
DE
LP
16.7% limited partnership interest owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
Raleigh Hotel Holding Company LLC
DE
LLC
62% owned by W&SREH and 3% owned by ERI
real estate ownership entity(ies)

13

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Raleigh Project Owner LLC
DE
LLC
100% owned by Raleigh Hotel Holding Company, LLC
ownership and operation of real estate
Randolph Tower Affordable Investment Fund, LLC
DE
LLC
99.99% owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
Revel Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Ridge at Robinson Apartments, LLC
DE
LLC
59% owned by Settlers Ridge Robinson Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
River Hollow Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Russell Bay Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Russell Bay Fee Owner LLC
DE
LLC
100% owned by Russell Bay Land Partners LLC
ownership and operation of real estate
Russell Bay Land Partners LLC
DE
LLC
64% owned by Russell Bay Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
San Tan Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Sarasota Property Owner, LLC
DE
LLC
100% owned by Senior Living at Sarasota, LLC
ownership and operation of real estate
Senior Living at Sarasota, LLC
DE
LLC
49% owned by Lorraine Senior Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Settlers Ridge Robinson Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Seventh and Culvert Garage, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
real estate ownership entity(ies)
Sixth and Saratoga NW, LLC
KY
LLC
100% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
South Flores Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
South Kirkman Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
South Kirkman Fee Owner LLC
DE
LLC
100% owned by South Kirkman Land Partners LLC
ownership and operation of real estate
South Kirkman Land Partners LLC
DE
LLC
64% owned by South Kirkman Apartment Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

14

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Southside Tunnel Apartments Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Southside Works City Apartments, LLC
DE
LLC
49% owned by Southside Tunnel Apartments Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
SP Charlotte Apts Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Springhurst JV, L.L.C.
KY
LLC
64% owned by Flats Springhurst Investor Holdings, LLC; and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
SPX Holding LLC
OH
LLC
50% owned by W&SFG
Airplane ownership/leasing
SSW Jet Ltd
OH
LLC
50% owned by W&SFG
Airplane ownership/leasing
Stout Metro Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Sundance Hotel Investor, LLC
OH
LLC
100% owned by Sundance LaFrontera Holdings, LLC
real estate ownership entity(ies)
Sundance Hotel, LLC
DE
LLC
64% owned by Sundance Hotel Investor, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Sundance LaFrontera Holdings, LLC
OH
LLC
98% owned by The Western and Southern Life Insurance Company and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Tamiami Senior Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
The Cove Apartments, LLC
DE
LLC
49% owned by Cove Housing Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
The Cove JV, LLC
DE
LLC
100% owned by The Cove Apartments, LLC
real estate ownership entity(ies)
The Flats at San Tan, LLC
TX
LLC
49% owned by San Tan Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
The Lafayette Life Insurance Company
OH
Corp
100% owned by Western & Southern Financial Group, Inc. (WSFG)
 
The Ohio Capital Fund LLC
OH
LLC
Managed by Buckeye Venture Partners, LLC
state funded private equity fund
The Western and Southern Life Insurance Company (WSLIC)
OH
Corp
100% owned by WSFG
 
Three Chopt AA Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

15

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Timacuan Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Timacuan Fee Owner LLC
DE
LLC
100% owned by Timacuan Land Partners LLC (DE)
ownership and operation of real estate
Timacuan Land Partners LLC
DE
LLC
64% owned by Timacuan Apartment Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Touchstone Advisors, Inc.
OH
Corp
100% owned by IFS Financial Services, Inc.
registered investment adviser
Touchstone Securities, Inc.
NE
Corp
100% owned by IFS Financial Services, Inc. Financial Services, Inc.
securities broker-dealer
Trevi Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Trevi Fee Owner, LLC
DE
LLC
100% Trevi Land Partners, LLC
ownership and operation of real estate
Trevi Land Partners, LLC
DE
LLC
64% Trevi Apartment Holdings, LLC; 1% Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Tri-State Growth Capital Fund I, L.P.
DE
LP
general partner is Tri-State Ventures, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Tri-State Growth Capital Fund II, L.P.
DE
LP
general partner is Tri-State Ventures II, LLC and investors include The Western and Southern Life Insurance Company
private equity fund
Tri-State Ventures II, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund
Tri-State Ventures, LLC
DE
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund
TXFL NNN Office Investor Holdings, LLC
OH
LLC
40.7408% owned by Western-Southern Life Assurance Company, 29.6296% owned by The Lafayette Life Insurance Company, 14.8148% owned by Integrity Life Insurance Company, 14.8148% owned by National Integrity Life Insurance Company
real estate ownership entity(ies)
UGR Holdings, LLC
DE
LLC
49% owned by University Shade Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
University Grove Residences, LLC
DE
LLC
100% owned by UGR Holdings, LLC (DE)
ownership and operation of real estate
University Shade Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Vail Hotel Holdings ESHV, LLC
DE
LLC
74% owned by Frontage Lodging Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Vail Hotel Owner ESHV, LLC
DE
LLC
100% owned by Vail Hotel Holdings ESHV, LLC
ownership and operation of real estate

16

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Vernazza Apartments, LLC
DE
LLC
54% owned by Vernazza Housing Investor Holdings and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Vernazza Housing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Vinings Trace, LLC
IN
LLC
99% owned by The Western and Southern Life Insurance Company, 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
W Apts Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
W Flats Residences, LLC
DE
LLC
66.5% owned by W Apts Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
W&S Brokerage Services, Inc.
OH
Corp
100% owned by Western-Southern Life Assurance Company
investment advisor and broker dealer
W&S Financial Group Distributors, Inc.
OH
Corp
100% owned by Western-Southern Life Assurance Company
general insurance agency
W&S Real Estate Holdings, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
Warm Springs Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Warm Springs Fee Owner LLC
DE
LLC
100% owned by Warm Springs Land Partners LLC
ownership and operation of real estate
Warm Springs Land Partners LLC
DE
LLC
64% owned by Warm Springs Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
West Crescent Venture Partners LLC
DE
LLC
49% owned by Revel Investor Holdings, LLC, and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
WestAd Leasing, LLC
OH
LLC
100% owned by Western & Southern Financial Group, Inc. (WSFG)
Airplane ownership/leasing
Western & Southern Agency, Inc.
OH
Corp
100% owned by The Western and Southern Life Insurance Company
general insurance agency
Western & Southern Financial Fund Inc
OH
NP Corp
 
charitable giving
Western & Southern Financial Group, Inc. (WSFG)
OH
Corp
100% owned by WSMHC
holding company
Western & Southern Investment Holdings, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
Western & Southern Mutual Holding Company (WSMHC)
OH
Corp
Mutual Insurance Holding Company
 

17

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Western-Southern Life Assurance Company (WSLAC)
OH
Corp
100% owned by The Western and Southern Life Insurance Company
 
Westhouse Residences, LLC
DE
LLC
49% owned by Keller Hicks Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
WL Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
WL Houston Parkway, LLC
TX
LLC
55% owned by WL Apartment Holdings and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
WS Airport Exchange GP, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
real estate ownership entity(ies)
WS Country Place GP, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
real estate ownership entity(ies)
WS Lookout JV, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
WSALD CEH, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
real estate ownership entity(ies)
WSALD NPH, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
real estate ownership entity(ies)
WSFG WG Aurora IL, LLC
OH
LLC
100% owned by Country Place Associates
ownership and operation of real estate
WSFG WG Charlotte NC, LLC
OH
LLC
100% owned by Country Place Associates
ownership and operation of real estate
WSFG WG Columbus OH, LLC
OH
LLC
100% owned by Vinings Trace, LLC
ownership and operation of real estate
WSFG WG Holding RI, LLC
OH
LLC
100% owned by Country Place Associates
ownership and operation of real estate
WSFG WG Providence RI, LLC
OH
LLC
100% owned by Country Place Associates
ownership and operation of real estate
WSFG WG Stallings NC, LLC
OH
LLC
100% owned by Vinings Trace, LLC
ownership and operation of real estate
WSL Partners, L.P.
DE
LP
general partner is FWCP and investors include The Western and Southern Life Insurance Company
private equity fund
1373 Lexington Road Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC; 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
2758 South Main SPE, LLC
OH
LLC
100% owned by The Western and Southern Life Insurance Company
ownership and operation of real estate

18

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
309 Holding LLC
DE
LLC
97% owned by The Western and Southern Life Insurance Company, 1% owned by W&S Real Estate Holdings, Inc. and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
506 Phelps Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Airport Exchange Hotel Partners
KY
GP
74% owned by WS Airport Exchange GP, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Alliant Tax Credit Fund 92 LP
CA
LP
13.4% limited partnership interest owned by The Lafayette Life Insurance Company
real estate ownership entity(ies)
Alta Mercer Crossing, LLC
DE
LLC
50% owned by Wood Mercer Crossing, LLC, 49% owned by Mercer Crossing Investor Holdings, LLC, and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Alta Preston Residences, LLC
DE
LLC
100% owned by Alta Preston, LLC
ownership and operation of real estate
Alta Preston, LLC
DE
LLC
100% owned by Alta, 47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Alta Stony Point, LLC
DE
LLC
49% owned by Stony Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Apex Housing Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Apex Louisville, LLC
KY
LLC
64% owned by Apex Housing Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Arvada Kipling Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Ascent Plainfield, LLC
IN
LLC
64% owned by Stout Metro Housing Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Axis JV, LLC
KY
LLC
64% owned by 1373 Lexington Road Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Axis Louisville, LLC
KY
LLC
100% owned by Axis JV, LLC
ownership and operation of real estate
Beardsley Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
BP Summerville Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Buckeye Venture Partners, LLC
OH
LLC
60% owned by Fort Washington Investment Advisors, Inc. (FWIA); 40% owned by Peppertree Partners, LLC
private equity fund management

19

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
BVP NEO, LLC
OH
LLC
100% owned by Fort Washington Investment Advisors, Inc.
private equity fund management
Canal Senate Apartments, LLC
IN
LLC
100% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
Cape Barnstable Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Carmel Holdings, LLC
OH
LLC
99% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Carmel Hotel Investor, LLC
OH
LLC
100% owned by Carmel Holdings, LLC
real estate ownership entity(ies)
Carmel Hotel, LLC
IN
LLC
99% owned by Carmel Hotel Investor, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Carthage Senior Housing, Ltd.
OH
LLC
98% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
CCA CBD Cincinnati LLC
OH
LLC
100% owned by 309 Holding, LLC
ownership and operation of real estate
Cedar Park Senior Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cenizo Apartments Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Charlotte Park Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Chattanooga Southside Housing Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Chestnut Healthcare Partners, L.P.
DE
LP
20% limited partnership interest owned by The Western and Southern Life Insurance Company
real estate ownership entity(ies)
Choo Choo Residences, LLC
DE
LLC
49% owned by Chattanooga Southside Apartments Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Cincinnati CBD Holdings, LLC
OH
LLC
100% owned by W&S Real Estate Holdings, LLC
ownership and operation of real estate
Cinnaire Fund for Housing Limited Partnership 31
MI
LP
16.7% limited partnership interest owned by Columbus Life Insurance Company
real estate ownership entity(ies)
Cleveland East Hotel, LLC
OH
LLC
99% owned by WSALD CEH, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Columbus Life Insurance Company
OH
Corp
100% owned by The Western and Southern Life Insurance Company
 

20

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Country Place Associates
OH
GP
90% owned by WS Country Place GP, LLC; 10% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cove Housing Investor Holdings, LLC
OH
LLC
98% W&S Real Estate Holdings, LLC and 2% Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Covington Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Crabtree Apartments, LLC
TX
LLC
59% owned by Crabtree Commons Apts Investor Holdings, LLC (W&S) and 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Crabtree Commons Apts Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Cranberry NP Hotel Company, LLC
PA
LLC
99% owned by NP Cranberry Hotel Investor LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Curve Luxury Apartments Investors, LLC
DE
LLC
59% owned by MC Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Curve Luxury Apartments, LLC
AZ
LLC
100% owned by Curve Luxury Apartments Investors, LLC
ownership and operation of real estate
Dallas City Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Day Hill Road Land LLC
CT
LLC
74% owned by W&S Real Estate Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Delco Lofts, LLC
OH
LLC
99% owned by Patterson at First Investor Holdings, LLC
ownership and operation of real estate
Domain at Dunvale, LLC
TX
LLC
49% owned by Dunvale Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
ownership and operation of real estate
Dunvale Investor Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Eagle Realty Capital Partners, LLC
OH
LLC
100% Eagle Realty Group, LLC
investment advisor
Eagle Realty Group, LLC
OH
LLC
100% owned by Western & Southern Investment Holdings, LLC
real estate holding company
Eagle Realty Investments, Inc. (ERI)
OH
Corp
100% owned by Eagle Realty Group, LLC
real estate ownership entity(ies)
Eagle Rose Apartment Holdings, LLC
OH
LLC
98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
Eagle Rose Land Partners, LLC
DE
LLC
24% owned by Eagle Rose Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)

21

NAT VAROOM
April 2020


Affiliate
State
Entity Abb
Ownership
Type of Business
Eagle Rose Owner, LLC
DE
LLC
100% owned by Eagle Rose Land Partners, LLC
ownership and operation of real estate
Elan Dallas City Lights GP, LLC
DE
LLC
100% owned by Elan Dallas City Lights, LLC
real estate ownership entity(ies)
Elan Dallas City Lights Limited Partner, LP
DE
LLC
100% owned by Elan Dallas City Lights, LLC; 0% owned by Elan Dallas City Lights GP, LLC
real estate ownership entity(ies)
Elan Dallas City Lights Owner, LP
DE
LP
99% owned by Elan Dallas City Lights Limited Partner, LP; 1% owned by Elan Dallas City Lights GP, LLC
ownership and operation of real estate
Elan Dallas City Lights, LLC
DE
LLC
59% owned by Dallas City Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.
real estate ownership entity(ies)
EMF DT SA, LLC (2017) (Encore River Walk)
DE
LLC
100% owned by EMF River Walk Investments, LLC
ownership and operation of real estate

Item 27.    Number of Contract Owners

As of April 8, 2020, 22 qualified and non-qualified contracts issued pursuant to this registration statement were outstanding.

Item 28.    Indemnification

National Integrity's By-Laws provide, in Article VII, Section 7.1 provides:
To the extent permitted by the laws of the State of New York, subject to all applicable requirements thereof:
(a) any person made or threatened to be made a party to any action or proceeding, whether civil or criminal, by reason of the fact that he, his testator, or intestate, is or was a director, officer, employee or incorporator of the Company shall be indemnified by the Company;
(b) any person made or threatened to be made a party to any action or proceeding, whether civil or criminal, by reason of the fact that he, his testator or intestate serves or served any other organization on any capacity at the request of the Company may be indemnified by the Company; and
(c) the related expenses of any such person in any other of said categories may be advanced by the Company.

Insofar as indemnification for liability arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of the registrant pursuant to the foregoing provisions, or otherwise, the registrant has been advised that in the opinion of the Securities and Exchange Commission such indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by the registrant of expenses incurred or paid by a director, officer or controlling person of the registrant in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities being registered, the registrant will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the Act and will be governed by the final adjudication of such issue.


22

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Item 29.    Principal Underwriters

(a)        Touchstone Securities, Inc. (Touchstone Securities) is the principal underwriter for Separate Account I of National Integrity Life Insurance Company. Touchstone Securities also serves as an underwriter for Separate Accounts I and VUL of Integrity Life Insurance Company, Western-Southern Life Assurance Company’s Separate Account 1, Columbus Life Insurance Company Separate Account I and for the shares of several series of Touchstone Variable Series Trust, Touchstone Strategic Trust, Touchstone Investment Trust, Touchstone Tax-Free Trust, Touchstone Institutional Funds Trust and Touchstone Funds Group Trust, each of which is affiliated with the Depositor.

(b)    The names and principal business addresses* of the officers and directors of, and their positions with, Touchstone Securities, Inc. are as follows:

Directors:
James N. Clark
Director
Jill T. McGruder
Director and Chief Executive Officer
Jonathan D. Niemeyer
Director
Donald J. Wuebbling
Director

Officers:
Steven M. Graziano
President
Jill T. McGruder
Chief Executive Officer
Stephen C. Owen
Senior Vice President
Jay V. Johnson
Vice President and Treasurer
Sharon L. Karp
Vice President
Christopher N. Watford
Vice President
Amy Fisher
Vice President
Timothy S. Stearns
Vice President and Interim Chief Compliance Officer
Terrie A. Wiedenheft
Chief Financial Officer
Lindsay M. Connelly
Assistant Vice President and Assistant Treasurer
John S. Musgrove
Assistant Vice President and Assistant Treasurer
Jason T. Anderson
Assistant Treasurer
Timothy D. Speed
Assistant Treasurer
Sarah Sparks Herron
Secretary


*The principal business address for the above is 303 Broadway, Cincinnati, Ohio 45202, unless otherwise noted.

(c)    Not applicable.

Item 30.    Location of Accounts and Records
The records required to be maintained by Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 to 31a-3 promulgated thereunder, are maintained by National Integrity at 400 Broadway, Cincinnati, Ohio 45202.

Item 31.    Management Services
There are currently no management-related services provided to the Registrant.

Item 32.    Undertakings
The Registrant hereby undertakes:
(a)
to file a post-effective amendment to this registration statement as frequently as is necessary to ensure that the audited financial statements of the Registrant, Depositor and Guarantor in the registration statement are never more than 16 months old for so long as payments under the variable annuity contracts may be accepted;
(b)
to include either (1) as part of any application to purchase a contract offered by the prospectus, a space that an applicant can check to request a Statement of Additional Information, or (2) a postcard or similar written communication affixed to or included in the prospectus that the applicant can remove to send for a Statement of Additional Information;

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NAT VAROOM
April 2020


(c)
to deliver any Statement of Additional Information and any financial statements required to be made available under this Form, including the WSLIC financial statements, promptly upon written or oral request; and
(d)
to update the registration statement if WSLIC terminates its guarantee to National Integrity policyholders.

During any time there are insurance obligations outstanding and covered by its guarantee (Guarantee) issued by WSLIC, filed as an exhibit to this registration statement, National Integrity hereby undertakes to provide notice to contract owners promptly after the happening of significant events related to the Guarantee. These significant events include: (i) termination of the Guarantee that has a material adverse effect on the contract owner's rights under the Guarantee; (ii) a default under the Guarantee that has a material adverse effect on the contract owner's rights under the Guarantee; or (iii) the insolvency of WSLIC.

Pursuant to Section 26(f) of the Investment Company Act of 1940, as amended, National Integrity represents that the aggregate charges under the variable annuity contract described in this Registration Statement are reasonable in relation to the services rendered, the expenses expected to be incurred, and the risks assumed by National Integrity.

National Integrity represents that it recognizes the requirements of Section 17(h) of the Investment Company Act of 1940, specifically that it shall not protect or purport to protect any director or officer of the Registrant or Depositor against any liability to them or to their security holders to which he would otherwise be subject by reason of willful misfeasance, bad faith, gross negligence or reckless disregard of the duties involved in the conduct of his office.


24

NAT VAROOM
April 2020


SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant, the Depositor and the Guarantor, certify that they meet all of the requirements for effectiveness of this post-effective amendment to their Registration Statement pursuant to Rule 485(b) under the Securities Act of 1933 and have duly caused this amendment to the Registration Statement to be signed on their behalf, in the City of Cincinnati and State of Ohio on this April 24, 2020.



SEPARATE ACCOUNT I OF
NATIONAL INTEGRITY LIFE INSURANCE COMPANY
(Registrant)

By: National Integrity Life Insurance Company
(Depositor)


By:
/s/ Jill T. McGruder
 
Jill T. McGruder, President and CEO



NATIONAL INTEGRITY LIFE INSURANCE COMPANY
(Depositor)



By:
/s/ Jill T. McGruder
 
Jill T. McGruder, President and CEO



THE WESTERN AND SOUTHERN LIFE INSURANCE COMPANY
(Guarantor)


By:
/s/ John F. Barrett
 
John F. Barrett, Chairman, President and CEO






NAT VAROOM
April 2020


SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Depositor has duly caused this amendment to the Registration Statement to be signed on its behalf, in the City of Cincinnati and State of Ohio on this April 24, 2020.

NATIONAL INTEGRITY LIFE INSURANCE COMPANY
(Depositor)

By:
/s/ Jill T. McGruder
 
Jill T. McGruder, President and CEO

The following persons, in the capacities and on the dates indicated, have signed this amendment to the Registration Statement as required by the Securities Act of 1933:


PRINCIPAL EXECUTIVE OFFICER:
 
/s/ Jill T. McGruder
 
 
Jill T. McGruder, President and CEO
 
 
April 24, 2020
 
 
 
PRINCIPAL FINANCIAL OFFICER:
 
/s/ Bradley J. Hunkler
 
 
Bradley J. Hunkler, Senior Vice President and Chief Financial Officer
 
 
April 24, 2020
 
 
 
PRINCIPAL ACCOUNTING OFFICER:
 
/s/ Wade M. Fugate
 
 
Wade M. Fugate, Vice President and Controller
 
 
April 24, 2020


DIRECTORS:

/s/ John F. Barrett
 
/s/ Jill T. McGruder
John F. Barrett
 
Jill T. McGruder
April 24, 2020
 
April 24, 2020
/s/ Edward J. Babbitt
 
/s/ Jonathan D. Niemeyer
Edward J. Babbitt
 
Jonathan D. Niemeyer
April 24, 2020
 
April 24, 2020
/s/ Daniel J. Downing
 
/s/ Donald J. Wuebbling
Daniel J. Downing
 
Donald J. Wuebbling
April 24, 2020
 
April 24, 2020









NAT VAROOM
April 2020


SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Guarantor has duly caused this amendment to the Registration Statement to be signed on its behalf, in the City of Cincinnati and State of Ohio on this April 24, 2020.


THE WESTERN AND SOUTHERN LIFE INSURANCE COMPANY
(Guarantor)

By:
/s/ John F. Barrett
 
John F. Barrett, Chairman, President and CEO


PRINCIPAL EXECUTIVE OFFICER:
 
/s/ John F. Barrett
 
 
John F. Barrett, Chairman, President and CEO
 
 
April 24, 2020
 
 
 
PRINCIPAL FINANCIAL OFFICER:
 
/s/ Bradley J. Hunkler
 
 
Bradley J. Hunkler, Senior Vice President and Chief Financial Officer
 
 
April 24, 2020
 
 
 
PRINCIPAL ACCOUNTING OFFICER:
 
/s/ Wade M. Fugate
 
 
Wade M. Fugate, Vice President and Controller
 
 
April 24, 2020

DIRECTORS:

/s/ John F. Barrett
 
/s/ Wade M. Fugate
John F. Barrett
 
Wade M. Fugate, Attorney-in-Fact for
Jo Ann Davidson
April 24, 2020
 
 
 
April 24, 2020
 
 
 
/s/ Wade M. Fugate
 
/s/ Wade M. Fugate
Wade M. Fugate, Attorney-in-Fact for
James N. Clark
 
Wade M. Fugate, Attorney-in-Fact for
Robert B. Truitt
April 24, 2020
 
April 24, 2020
 
 
 
 
 
/s/ Wade M. Fugate
 
 
Wade M. Fugate, Attorney-in-Fact for
Thomas L. Williams
 
 
April 24, 2020