485BPOS 1 natvrm485b.htm 485BPOS NAT VRM 485(B)

National Integrity VAROOM
As filed with the Securities and Exchange Commission on April 16, 2021
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: 12    [ x]

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940
Amendment Number: 140    [ 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.
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
xon May 1, 2021 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, 2021

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, 2021, 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.

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.

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.
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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® 5-10 Investment Grade 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 Contract10
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 Account12
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 Options14
The Fund Families and the Funds
Static Asset Allocation Models16
The Fixed Account
Part 4 – Deductions and Charges17
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
Filing Death Claims
Maturity Date and Annuity Option
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Annuity Payments
How You Make Requests and Give Instructions
Abandoned or Unclaimed Property28
Part 6 – Optional Benefits
Guaranteed Lifetime Withdrawal Benefit
Lifetime Payout Amount (LPA)
Nonguaranteed Withdrawal30
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 Death34
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 Rights36
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)
Inherited IRAs
Compliance with the SECURE Act
40
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 ChargeCurrent Charge
Mortality and Expense Risk Charge1.00%1.00%
Administration Charge0.75%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%
_________________________________________________________
1 The withdrawal charge decreases over time and is eliminated for each premium after it reaches five years old. See Part 4.
2 Assessed daily on the Account Value in the Subaccounts.
3 You 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.

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: 0.03% Maximum: 0.49%

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

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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, 3
0.03%None0.00%0.00%0.03%
iShares Core S&P Mid-Cap ETF 2, 3
0.05%None0.00%0.00%0.05%
iShares Core S&P Small-Cap ETF 2, 3
0.06%None0.00%0.00%0.06%
iShares S&P 500 Growth ETF 2
0.18%None0.00%0.00%0.18%
iShares S&P 500 Value ETF 2
0.18%None0.00%0.00%0.18%
Vanguard Dividend Appreciation Index Fund, ETF Shares0.05%None0.01%0.00%0.06%
Vanguard Large-Cap Index Fund, ETF Shares0.03%None0.01%0.00%0.04%
Vanguard Mega Cap Index Fund, ETF Shares0.06%None0.01%0.00%0.07%

Fixed Income Subaccounts:
Fidelity VIP Government Money Market Portfolio, Initial Class
0.16%None0.08%0.00%0.24%
iShares Core U.S. Aggregate Bond ETF 2, 3
0.04%None0.00%0.00%0.04%
iShares iBoxx $ High Yield Corporate Bond ETF 2
0.49%None0.00%0.00%0.49%
iShares 5-10 Year Investment Grade Corporate Bond ETF 2
0.06%None0.00%0.00%0.06%
iShares TIPS Bond ETF 2
0.19%None0.00%0.00%0.19%
Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares0.04%None0.01%0.00%0.05%
Vanguard Short-Term Bond Index Fund, ETF Shares
0.04%None0.01%0.00%0.05%
Vanguard Total Bond Market Index Fund, ETF Shares0.03%None0.01%0.00%0.04%

International and Alternative Subaccounts:
iShares International Treasury Bond ETF 2
0.35%None0.00%0.00%0.35%
Vanguard Developed Markets Index Fund, ETF Shares0.04%None0.01%0.00%0.05%
Vanguard Emerging Markets Stock Index Fund, ETF Shares0.07%None0.03%0.00%0.10%
Vanguard Real Estate Index Fund, ETF Shares0.11%None0.01%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.


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.

_________________________________________________________
4 This contract requires a minimum initial premium of $25,000.
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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 year3 years5 years10 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 year3 years5 years10 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 year3 years5 years10 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 year3 years5 years10 years
$234$722$1,235$2,644

Accumulation Unit Values

See Appendix A


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.

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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.

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
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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, pandemics 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. Some of the Subaccounts may be exposed to a greater extent to certain industries or sectors, such as the real estate sector. To the extent a Subaccount may be more exposed to a particular industry or sector, it is more susceptible to the risks associated with that industry or sector.

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 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.


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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.

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
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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 1-800-433-1778.

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.

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.

iShares Core S&P Mid-Cap ETF
The Fund seeks to track the 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-adjusted market value of their outstanding shares.

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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.

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.

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.

Vanguard Dividend Appreciation Index Fund, ETF Shares
The Fund seeks 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.

Vanguard Large-Cap Index Fund, ETF Shares
The Fund seeks 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.

Vanguard Mega Cap Index Fund, ETF Shares
The Fund seeks to track the performance of the CRSP US Mega Cap Index, which is a float-adjusted, market-capitalization-weighted index designed to measure equity market performance of mega-capitalization stocks in the United States.

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.

iShares Core U.S. Aggregate Bond ETF
The Fund seeks to track the 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 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 the 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%.

iShares 5-10 Year Investment Grade Corporate Bond ETF
The Fund seeks to track the investment results of the ICE BofA 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
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equal to five years and less than ten years, and have $250 million or more of outstanding face value. 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.” 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.

Vanguard Intermediate-Term Corporate Bond Index Fund, ETF Shares
The Fund seeks to track the performance of the Bloomberg Barclays U.S. 5-10 Year Corporate Bond Index, which includes U.S. dollar-denominated, investment-grade, fixed-rate, taxable securities issued by industrial, utility, and financial companies, with maturities between 5 and 10 years.

Vanguard Short-Term Bond Index Fund, ETF Shares
The Fund seeks to track the performance of the Bloomberg Barclays U.S. 1-5 Year Government/Credit Float Adjusted Index, which 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.

Vanguard Total Bond Market Index Fund, ETF Shares
The Fund seeks to track the performance of the Bloomberg Barclays U.S. Aggregate Float Adjusted Index, which measures the performance of 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.

International and Alternative Funds:

iShares International Treasury Bond ETF
The Fund seeks to track the investment results of the FTSE World Government Bond Index – Developed Markets Capped Select Index, which measures the performance of fixed-rate, local currency, investment-grade, sovereign bonds from certain developed markets, excluding the United States.

Vanguard Developed Markets Index Fund, ETF Shares
The Fund seeks to track the performance of the FTSE Developed All Cap ex US Index, a market-capitalization-weighted index that is made up of common stocks of large-, mid-, and small-cap companies located in Canada and the major markets of Europe and the Pacific region.

Vanguard Emerging Markets Stock Index Fund, ETF Shares
The Fund seeks to track the performance of the FTSE Emerging Markets All Cap China A Inclusion Index, a market-capitalization-weighted index that is made up of common stocks of large-, mid-, and small-cap companies located in emerging markets around the world.

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 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 real estate investment trusts (REITs), including specialized REITs, and real estate management and development companies.


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
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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 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%.
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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 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
17%
27%
36%
45%
54%
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
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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 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 American Portfolios Financial Services, Inc., BBVA Securities, Inc., BOK Financial Securities, Inc., Cadaret, Grant & Co., Inc., Cetera Investment Services LLC, Commerce Brokerage Services, Inc., CUNA Mutual Insurance Agency, CUSO Financial Services, LP, Fifth Third Securities, Inc., Frost Brokerage Services, Inc., Hancock Investment Services, Inc., Huntington Securities, Inc., Infinex 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.
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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 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
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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."

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.

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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 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.
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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.

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 the 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.

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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."

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.

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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
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.

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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 5 or 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 or ten 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.

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.

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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.

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
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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).

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.



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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:
◦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
60-644.00%
65-694.50%
70-745.00%
75 and above5.50%

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*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 DateFirst-Year Deferral Percentage
January 1-March 310.075%
April 1-June 300.050%
July 1-September 300.025%
October 1-December 310.000%

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.

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
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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 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%).

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•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 ChargeCurrent GLWB Charge with Total Separate Account Expenses
Strategy 1 – Basic Allocation0.60%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.

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.
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SubaccountModel 1 - GrowthModel 2 - BlendModel 3 - Value
iShares Core S&P 500 ETF 30%40%30%
iShares Core S&P Mid-Cap ETF10%10%10%
iShares Core S&P Small-Cap ETF5%5%5%
iShares International Treasury Bond ETF5%5%5%
iShares S&P 500 Growth ETF 10%
iShares S&P 500 Value ETF10%
Vanguard Developed Markets Index Fund, ETF Shares
5%5%5%
Vanguard Total Bond Market Index Fund, ETF Shares35%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.

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 5-10 Year Investment Grade Corporate Bond ETF
Vanguard Dividend Appreciation Index Fund, ETF Shares
iShares TIPS Bond ETF
iShares Core S&P Small-Cap ETFVanguard 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 ETFVanguard Emerging Markets Stock Index Fund, ETF Shares
 

Vanguard Short-Term Bond Index Fund, ETF Shares
iShares S&P 500 Value ETFVanguard 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.

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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.

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
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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).

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.
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•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.

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
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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 Funds. 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.

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 2021 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.

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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 ($58,000 for 2021, 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 2021 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.

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.

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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.

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

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.

Compliance with the SECURE Act

The Setting Every Community Up for Retirement Enhancement Act of 2019, as amended (the “SECURE Act”) substantially changes the tax rules that allowed inherited IRA owners to stretch distributions from their inherited IRAs over their life expectancies. Pursuant to the SECURE Act, notwithstanding any provision in the contract to the contrary, beginning with an owner’s death in 2020, an inherited IRA owner will generally be required to distribute the entire IRA balance within 10 years of the owner’s death.

Under the new rule, an inherited IRA owner who is not an “eligible designated beneficiary” under the Tax Rules, generally must receive the entire death benefit within 10 years of the annuity owner’s death. Eligible designated beneficiaries may still elect to take distributions over their life expectancy or over a period not extending beyond their life expectancy, but the 10-year requirement applies when they die. Eligible designated beneficiaries include: (1) the owner’s surviving spouse, (2) the owner’s minor child (until the child reaches the age of majority, at which time the 10-year rule begins to apply), (3) a disabled person, (4) a chronically ill person, or (5) an individual who is not more than 10 years younger than the owner. The inherited IRA owner’s status as an eligible designated beneficiary is determined on the date of the owner’s death. The five-year rule still applies to non-designated beneficiaries (i.e., beneficiaries that are not human beings).

National Integrity Life does not provide tax advice. Please consult your personal financial or tax advisor if you have any questions regarding the impact of the SECURE Act on your designation of beneficiary(ies) and any death benefit paid under this contract.

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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:
Death of OwnerSpouseOther Eligible Designated BeneficiaryNon-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 or ten 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.

VN-41

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 contract transactions, including the processing of orders with the underlying Funds; cause the release and possible destruction of confidential customer or business information;
VN-42

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.

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
VN-43

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.

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.

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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........................................................................................................................6

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, 2021
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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		2020201920182017
2016
2015
2014
2013
2012
2011		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


$65.80
$76.52
1,370

$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

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



$62.26
$71.96
8,977


$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

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



$61.12
$70.50
190


$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

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


$55.15
$61.52
405

$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

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




$52.18
$57.86
3,240



$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

12-21-10
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Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$51.22
$56.68
164


$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

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
$58.31
$63.73
206

$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

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
$55.17
$59.94
1,598


$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

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
$54.16
$58.72
164


$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

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
$28.74
$30.35
407

$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

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
$27.19
$28.54
0


$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

12-21-10
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Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$26.69
$27.96
0


$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

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
$34.94
$35.86
0


$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

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
$33.06
$33.72
0


$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

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
$32.46
$33.03
0


$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

12-21-10
iShares 5-10 Year Investment Grade Corporate Bond ETF (3711)
Unit value at beginning of period
Unit value at end of period
Units outstanding at end of period
$30.66
$33.02
0

$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

12-21-10
iShares 5-10 Year Investment Grade 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
$29.01
$31.06
0


$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

12-21-10
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Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		Value and Inception Date
iShares 5-10 Year Investment Grade 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
$28.48
$30.42
415


$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

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
$23.82
$25.95
423

$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

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
$22.54
$24.41
3,654


$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

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
$22.13
$23.91
0


$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

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
$72.17
$94.47
242

$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

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
$68.29
$88.84
913


$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

12-21-10
VN-49


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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



$67.04
$87.04
0


$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

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


$57.82
$57.47
0

$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

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



$54.71
$54.05
89


$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

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



$53.71
$52.95
0


$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

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


$27.60
$30.06
0

$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

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



$26.12
$28.27
0


$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

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



$25.64
$27.69
0


$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

12-21-10
VN-50


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$34.57
$37.26
321


$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

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
$32.71
$35.04
2,660


$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

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
$32.11
$34.32
140


$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

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
$60.95
$69.09
0


$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

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
$57.67
$64.98
0


$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

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
$56.61
$63.66
305


$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

12-21-10
VN-51


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$25.74
$29.13
0


$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

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
$24.36
$27.40
0



$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

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
$23.91
$26.84
327



$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

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
$34.14
$36.72
401


$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

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
$32.30
$34.53
0



$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

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
$31.71
$33.83
0



$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

12-21-10
VN-52


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$65.13
$77.42
0


$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

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
$61.63
$72.81
0


$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

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
$60.50
$71.33
182


$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

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
$66.98
$79.98
461


$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

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
$63.38
$75.21
0


$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

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
$62.22
$73.68
59


$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

12-21-10
VN-53


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$52.38
$49.11
0

$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

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
$49.56
$46.19
0


$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

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
$48.66
$45.25
92


$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

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
$24.71
$25.42
0


$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
$23.57
$24.10
0


$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
$23.21
$23.68
0


$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-54


Subaccount		2020201920182017
2016
2015
2014
2013
2012
2011		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
$28.83
30.51
2,429


$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

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
$27.28
$28.69
21,299


$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

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
$26.78
$28.11
1,111


$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

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
$9.86
$9.72
0


$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
$9.66
$9.47
0


$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
$9.60
$9.38
0


$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-55

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-56

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.

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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 YearCovered Person's AgeWithdrawal
Percentage		Benefit
 Base		LPAAdditional
Premium		Benefit Base after Additional PremiumHypothetical Account Value (E)Benefit Base after Step-UpHypothetical Account Value (E)Annual WithdrawalAdjusted 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
2614.050%(G)$100,000$4,050$10,000 (H)$110,000$112,614$112,614 (I)$112,485$0$0$112,614
3624.150% (J)$112,614$4,673$0$112,614$116,985$116,985$117,755$0$0$116,985
4634.250% (J)$116,985$4,972$0$116,985$121,300$121,300$122,188$0$0$121,300
5644.350% (J)$121,300$5,277$0$121,300$119,745$121,300$120,719$0$0$121,300
6654.950% (K)$121,300$6,004$0$121,300$120,719$121,300$120,123$6,004$0$121,300
7664.950%$121,300$6,004$0$121,300$109,554$121,300$110,171$6,004$0$121,300
8674.950%$121,300$6,004$0$121,300$106,250$121,300$105,343$6,004$0$121,300
9684.950%$121,300$6,004$0$121,300$99,338(L)$121,300$99,982$6,004(L)$0$121,300
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As of January 1 (A)As of February 10 (B)As of June 27 (C)As of October 8 (D)
Calendar YearCovered Person's AgeWithdrawal
Percentage		Benefit
 Base		LPAAdditional
Premium		Benefit Base after Additional PremiumHypothetical Account Value (E)Benefit Base after Step-UpHypothetical Account Value (E)Annual WithdrawalAdjusted Non-
Guaranteed
Withdrawal		Benefit Base After Withdrawal
10694.950%$121,300$6,004$10,000(L)$121,300$102,098(L)$121,300$102,181$6,004$0$121,300
11704.950%$121,300$6,004$0$121,300$97,138$121,300$97,727$6,004$0$121,300
12714.950%$121,300$6,004$0$121,300$88,053$121,300$88,553$6,004$0$121,300
13724.950%$121,300$6,004$0$121,300$84,200$121,300$83,647$6,004$0$121,300
14734.950%$121,300$6,004$0$121,300$78,419$121,300$78,981$6,780 (M)$1,290 (M)$120,010(M)
15744.950%$120,010$5,940$0$120,010$72,923$120,010$73,461$5,940$0$120,010
16754.950%$120,010$5,940$0$120,010$70,221$120,010$70,531$5,940$0$120,010
17764.950%$120,010$5,940$0$120,010$65,236$120,010$65,375$5,940$0$120,010
18774.950%$120,010$5,940$0$120,010$58,246$120,010$58,752$5,940$0$120,010
19784.950%$120,010$5,940$0$120,010$50,171$120,010$49,888$5,940$0$120,010
20794.950%$120,010$5,940$0$120,010$45,705$120,010$45,702$5,940$0$120,010
21804.950%$120,010$5,940$0$120,010$39,364$120,010$38,972$5,940$0$120,010
22814.950%$120,010$5,940$0$120,010$34,022$120,010$34,012$5,940$0$120,010
23824.950%$120,010$5,940$0$120,010$28,914$120,010$29,175$5,940$0$120,010
24834.950%$120,010$5,940$0$120,010$22,305$120,010$22,391$5,940$0$120,010
25844.950%$120,010$5,940$0$120,010$15,628$120,010$15,559$5,940$0$120,010
26854.950%$120,010$5,940$0$120,010$9,330$120,010$9,298$5,940$0$120,010
27864.950%$120,010$5,940$0$120,010$3,525$120,010$3,554$5,940 (N)$0$120,010
28874.950%$120,010$5,940$0$120,010$0$120,010$0$5,940$0$120,010
29884.950%$120,010$5,940$0$120,010$0$120,010$0$5,940$0$120,010
30894.950%$120,010$5,940$0$120,010$0$120,010$0$5,940$0$120,010
31+904.950%$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.

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(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).

VN-60

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:
VN-61

•    $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.

VN-62

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 YearCovered Persons' AgesWithdrawal
Percentage		Benefit BaseLPAHypothetical Account Value (D)Benefit Base after Step-UpHypothetical Account Value (D)Annual WithdrawalAdjusted Nonguaranteed WithdrawalBenefit Base After Withdrawal
OwnerSpouse
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
26158N/A$100,000N/A$103,610$103,610(F)$103,492$0$0$103,610
36259N/A$103,610N/A$106,597$106,597$107,299$10,000 (G)$10,000 (G)$96,597 (G)
463604.125% (H)$96,597$3,586(H)$95,353$96,597$96,051$3,586$0$96,597
564614.125%$96,597$3,586$90,616$96,597$91,354$3,586$0$96,597
665624.125%$96,597$3,586$87,767$96,597$87,334$3,586$0$96,597
766634.125%$96,597$3,586$80,398$96,597$80,850$3,586$0$96,597
867644.125%$96,597$3,586$78,809$96,597$78,137$3,586$0$96,597
968654.125%$96,597$3,586$74,550$96,597$75,033$3,586$0$96,597
1069664.125%$96,597$3,586$70,018$96,597$70,075$3,586$0$96,597
1170674.125%$96,597$3,586$67,154$96,597$67,561$3,586$0$96,597
1271684.125%$96,597$3,586$61,415$96,597$61,764$3,586$0$96,597
1372694.125%$96,597$3,586$59,341$96,597$58,952$3,586$0$96,597
1473704.125%$96,597$3,586$55,919$96,597$56,320$56,320 (I)N/A$0
157471N/A$0$0$0$0$0$0$0$0
(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.
VN-63


(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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THIS PAGE INTENTIONALLY LEFT BLANK
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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, 2021, remove this page and mail it to us at the Administrative Office listed in the Glossary.


Name:____________________________

Phone:____________________________

Address:______________________________

______________________________________


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STATEMENT OF ADDITIONAL INFORMATION

May 1, 2021

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, 2021.

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 ContentsPage
General Information and History..............................................................................................................
Administration and Distribution of the Contracts.....................................................................................
Performance Data and Illustrations.........................................................................................................
Distributions from Tax-Favored Retirement Programs............................................................................
Financial Statements...............................................................................................................................6

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 $1,799,873 in 2020, $2,229,165 in 2019, and $2,265,535 in 2018. 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 Portfolios Financial Services, Inc.LPL Financial LLC


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. 

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.

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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.

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:

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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;
11)    distributions made on account of an IRS levy upon a qualified contract; and
12)    distributions from an eligible retirement plan (including an IRA) of up to $5,000 made to you with respect to any qualified birth or adoption.

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 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.

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
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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, 2020, 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, 2020 and 2019 and for each of the three years in the period ended December 31, 2020, and the statutory-basis financial statements of The Western and Southern Life Insurance Company (WSLIC) as of December 31, 2020 and 2019 and for each of the three years in the period ended December 31, 2020, 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.

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FINANCIAL STATEMENTS

Separate Account I of National Integrity Life Insurance Company
Year Ended December 31, 2020
With Report of Independent Registered
Public Accounting Firm





Separate Account I
of
National Integrity Life Insurance Company

Financial Statements

Year Ended December 31, 2020



Contents
Report of Independent Registered Public Accounting Firm
Financial Statements
Statements of Assets and Liabilities as of December 31, 2020
Statements of Operations for the Year ended December 31, 2020
Statements of Changes in Net Assets for the Year ended December 31, 2020
Statements of Changes in Net Assets for the Year ended December 31, 2019
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, 2020, 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, 2020, 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, 2020, 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 13, 2021
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Appendix A

Subaccounts comprising Separate Account I of National Integrity Life Insurance Company
SubaccountsStatement of operationsStatements of changes in net assets
American Funds Insurance Series
Non-Affiliated Class 2For the year ended December 31, 2020For each of the two years in the period ended December 31, 2020
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


Appendix A (continued)
SubaccountsStatement of operationsStatements of changes in net assets
Non-Affiliated Initial Class (continued):For the year ended December 31, 2020For each of the two years in the period ended December 31, 2020
Fidelity VIP Investment Grade Bond Portfolio
Fidelity VIP Government Money Market
Non-Affiliated Service Class:
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


Appendix A (continued)
SubaccountsStatement of operationsStatements of changes in net assets
iShares TrustFor the year ended December 31, 2020For each of the two years in the period ended December 31, 2020
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® 5-10 Year Investment Grade Corporate Bond ETF (formerly 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
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


Appendix A (continued)
SubaccountsStatement of operationsStatements of changes in net assets
Northern Lights Variable TrustFor the year ended December 31, 2020For each of the two years in the period ended December 31, 2020
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
Invesco (AIM) Variable Insurance FundsFor the period from April 30, 2020 (commencement of operations) through December 31, 2020
Non-Affiliated Class 2:
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II
Invesco (AIM) Variable Insurance FundsFor the period from January 1, 2020 through April 29, 2020For the year ended December 31, 2019 and the period from January 1, 2020 through April 29, 2020
Non-Affiliated Class 2:
Invesco V.I. Mid Cap Growth Fund
Touchstone Variable Series TrustFor the year ended December 31, 2020For the year ended December
31, 2020 and the period from July 12, 2019 through December 31, 2019
Affiliated Service Class:
Touchstone VST Bond Fund
Touchstone VST Common Stock Fund
Fidelity Variable Insurance ProductsFor the year ended December 31, 2020For the year ended December 31, 2020 and the period from July 12, 2019 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


Separate Account I
of
National Integrity Life Insurance Company
Statement of Assets and Liabilities
December 31, 2020
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$5,979,306 $9 $5,979,315 $19.98 to$29.89 240,237 
Touchstone VST Bond Fund2,281,020 (5)2,281,015 10.96 to11.07 207,507 
Touchstone VST Common Stock Fund 20,755,242 — 20,755,242 13.09 to13.22 1,579,555 
Touchstone VST Conservative ETF Fund5,279,719 4 5,279,723 16.01 to20.04 286,301 
Touchstone VST Moderate ETF Fund6,966,790 (15)6,966,775 18.26 to23.13 349,730 
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio2,152,834 — 2,152,834 25.02 to40.75 66,786 
Fidelity VIP Overseas Portfolio1,330,316 (5)1,330,311 13.43 to54.21 33,589 
Fidelity VIP Equity-Income Portfolio7,699,668 (1)7,699,667 32.93 to116.16 87,507 
Fidelity VIP Growth Portfolio6,921,053 2 6,921,055 258.15 26,810 
Fidelity VIP High Income Portfolio1,680,489 — 1,680,489 31.42 53,488 
Fidelity VIP Asset Manager Portfolio3,064,332 (1)3,064,331 68.77 44,561 
Fidelity VIP Contrafund® Portfolio15,608,584 (2)15,608,582 64.40 to126.77 157,376 
Fidelity VIP Index 500 Portfolio5,032,612 — 5,032,612 27.19 to96.85 90,441 
Fidelity VIP Investment Grade Bond Portfolio1,401,974 1 1,401,975 13.41 to41.95 68,480 
Fidelity VIP Government Money Market4,344,897 (2)4,344,895 9.30 to9.91 447,593 
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio385,617 (4)385,613 37.57 10,265 
Fidelity VIP Mid Cap Portfolio3,113,992 (3)3,113,989 80.30 to84.32 38,241 
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio1,226,481 (7)1,226,474 17.36 to25.01 64,373 
Fidelity VIP Balanced Portfolio12,864,778 — 12,864,778 22.75 to33.83 512,782 
Fidelity VIP Bond Index Portfolio 353,653 — 353,653 10.72 to10.78 32,964 
Fidelity VIP Contrafund® Portfolio19,354,970 1 19,354,971 27.68 to52.74 565,338 
Fidelity VIP Disciplined Small Cap Portfolio1,602,264 4 1,602,268 20.16 to26.91 76,033 
Fidelity VIP Equity-Income Portfolio3,357,522 (6)3,357,516 16.37 to27.56 169,766 
Fidelity VIP Extended Market Index Portfolio59,393 1 59,394 12.07 to12.11 4,917 
Fidelity VIP Freedom 2010 Portfolio420,441 5 420,446 16.64 to17.63 24,822 
Fidelity VIP Freedom 2015 Portfolio456,176 2 456,178 17.23 to18.62 25,987 
Fidelity VIP Freedom 2020 Portfolio613,135 1 613,136 17.45 to18.64 34,962 
Fidelity VIP Freedom 2025 Portfolio2,274,395 (2)2,274,393 18.59 to19.88 121,709 
Fidelity VIP Freedom 2030 Portfolio353,110 4 353,114 18.78 to20.12 18,321 
Fidelity VIP Growth Portfolio5,173,503 (4)5,173,499 32.47 to48.67 128,654 
Fidelity VIP High Income Portfolio6,779,352 (5)6,779,347 15.00 to27.05 331,095 
Fidelity VIP Index 500 Portfolio32,419,790 — 32,419,790 25.42 to37.55 1,223,483 
Fidelity VIP International Index Portfolio 57,315 2 57,317 11.55 to11.62 4,951 
Fidelity VIP Investment Grade Bond Portfolio15,438,763 6 15,438,769 13.08 to20.14 1,018,836 
Fidelity VIP Mid Cap Portfolio8,707,567 (5)8,707,562 22.28 to53.30 286,593 
Fidelity VIP Overseas Portfolio2,616,552 (1)2,616,551 12.76 to25.09 166,231 
Fidelity VIP Target Volatility Portfolio499,341 — 499,341 14.29 to14.71 34,830 
Fidelity VIP Total Market Index Portfolio82,212 (1)82,211 12.72 to12.79 6,433 
Non-Affiliated Class 1:
Columbia VP – Select Mid Cap Value Fund1,441,587 (5)1,441,582 19.89 to20.78 70,853 
Franklin Growth and Income VIP Fund1,599,568 2 1,599,570 32.06 to32.06 49,887 
Franklin Income VIP Fund2,599,251 (3)2,599,248 28.58 to29.23 90,892 
JP Morgan IT Mid Cap Value547,980 (2)547,978 25.65 to38.85 15,368 
Morgan Stanley VIF Emerging Markets Debt Portfolio103,630 1 103,631 28.78 to36.55 3,011 
Morgan Stanley VIF U.S. Real Estate Portfolio480,347 1 480,348 13.83 to40.80 13,984 
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund2,214,857 3 2,214,860 13.71 to14.26 161,174 
Columbia VP – Small Cap Value Fund1,738,135 (1)1,738,134 21.84 to30.68 59,283 
Franklin Growth and Income VIP Fund4,443,584 3 4,443,587 18.07 to32.65 184,091 
Franklin Income VIP Fund12,555,895 (3)12,555,892 14.99 to29.10 727,913 
Franklin Large Cap Growth VIP Fund6,183,060 — 6,183,060 30.24 to50.29 147,431 
Franklin Mutual Shares VIP Fund9,422,867 (4)9,422,863 13.32 to27.17 607,454 
Franklin Small Cap Value VIP Fund1,075,993 8 1,076,001 19.32 to24.24 54,141 
Invesco V.I. American Franchise Fund460,109 3 460,112 35.80 to53.47 10,886 
Invesco V.I. American Value Fund6,770,828 3 6,770,831 18.54 to20.89 354,779 
Invesco V.I. Comstock Fund3,514,897 (2)3,514,895 16.74 to33.26 183,319 
Invesco V.I. International Growth Fund2,103,181 (3)2,103,178 14.62 to15.27 141,566 
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II (b)676,241 — 676,241 14.81 to14.85 45,631 
Templeton Foreign VIP Fund4,044,977 — 4,044,977 9.63 to22.10 354,961 
Templeton Global Bond VIP Fund333,045 (1)333,044 8.78 to9.06 37,544 
Templeton Growth VIP Fund1,068,164 2 1,068,166 11.40 to24.43 59,778 
Morgan Stanley VIF Emerging Markets Debt Portfolio869,826 (1)869,825 13.54 to27.65 51,822 
Morgan Stanley VIF Emerging Markets Equity Portfolio2,034,474 2 2,034,476 10.42 to45.28 117,993 
Morgan Stanley VIF U.S. Real Estate Portfolio2,130,161 1 2,130,162 10.53 to32.27 175,671 

(a) Name Change. See Note 1.
5
(b) New Underlying Fund. See Note 1

Separate Account I
of
National Integrity Life Insurance Company
Statement of Assets and Liabilities (continued)
December 31, 2020
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$4,150,203 $(6)$4,150,197 $32.25 to$33.71 126,275 
BlackRock Global Allocation V.I. Fund622,594 2 622,596 15.19 to16.11 40,504 
BlackRock High Yield V.I. Fund230,410 3 230,413 12.74 to12.99 18,018 
BlackRock Total Return V.I. Fund373,902 (4)373,898 11.23 to11.33 33,305 
TOPS® Managed Risk Moderate Growth ETF Portfolio1,177,600 2 1,177,602 12.42 to12.81 94,677 
Non-Affiliated Class 4:
American Funds I.S. Bond Fund1,175,904 3 1,175,907 11.27 to11.49 103,904 
American Funds I.S. Capital Income Builder Fund2,925,593 (2)2,925,591 11.43 to11.80 253,378 
American Funds I.S. Global Growth Fund2,876,824 4 2,876,828 21.36 to22.05 132,235 
American Funds I.S. Growth Fund4,000,650 — 4,000,650 29.69 to30.55 133,800 
American Funds I.S. Growth-Income Fund3,851,272 4 3,851,276 19.74 to20.39 192,823 
American Funds I.S. New World Fund1,061,523 (1)1,061,522 15.15 to15.59 69,216 
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund429,266 5 429,271 39.52 to41.67 10,531 
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund1,741,943 — 1,741,943 21.77 to37.88 67,307 
Advisor Class:
PIMCO VIT All Asset Portfolio1,367,668 (5)1,367,663 13.80 to15.48 92,416 
PIMCO VIT International Bond Portfolio (US Dollar Hedged)48,948 1 48,949 11.38 to11.59 4,265 
PIMCO VIT CommodityRealReturn® Strategy Portfolio1,236,801 (4)1,236,797 3.94 to5.46 308,589 
PIMCO VIT Long-Term U.S. Government Portfolio275,317 7 275,324 13.04 to13.50 20,694 
PIMCO VIT Low Duration Portfolio2,456,932 (3)2,456,929 10.45 to12.14 216,585 
PIMCO VIT Real Return Portfolio935,157 1 935,158 12.09 to14.03 69,485 
PIMCO VIT Total Return Portfolio19,908,326 5 19,908,331 12.71 to15.94 1,315,138 
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund151,059 3 151,062 6.23 to7.87 23,894 
Guggenheim VT Multi-Hedge Strategies Fund313,214 6 313,220 8.92 to11.44 34,129 
Guggenheim VT Long Short Equity Fund59,050 2 59,052 10.21 to12.38 5,661 
ETF Shares:
iShares® Core S&P 500 ETF17,460,394 1 17,460,395 70.26 to76.52 243,492 
iShares® Core S&P Mid-Cap ETF5,332,217 (3)5,332,214 56.68 to63.03 89,761 
iShares® Core S&P Small-Cap ETF2,891,436 (1)2,891,435 58.72 to65.18 47,081 
iShares® Core U.S. Aggregate Bond ETF586,112 7 586,119 26.28 to30.35 22,128 
iShares® iBoxx $ High Yield Corporate Bond ETF70,729 2 70,731 32.24 to34.89 2,113 
iShares® 5-10 Year Investment Grade Corporate Bond ETF (a)777,895 2 777,897 29.21 to31.62 26,543 
iShares® International Treasury Bond ETF2,235,492 — 2,235,492 23.65 to25.95 92,564 
iShares® S&P 500 Growth ETF2,444,125 — 2,444,125 84.37 to94.47 28,265 
iShares® S&P 500 Value ETF519,834 2 519,836 54.05 to58.77 9,315 
iShares® TIPS Bond ETF77,588 1 77,589 24.46 to26.47 3,102 
Vanguard® Developed Markets Index Fund, ETF Shares2,538,730 3 2,538,733 34.32 to41.56 65,231 
Vanguard® Dividend Appreciation Index Fund, ETF Shares1,017,309 — 1,017,309 61.24 to66.27 16,365 
Vanguard® Emerging Markets Stock Index Fund, ETF Shares246,823 4 246,827 26.84 to33.68 7,809 
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares67,981 (1)67,980 31.67 to36.72 1,976 
Vanguard® Large-Cap Index Fund, ETF Shares814,861 1 814,862 71.33 to77.43 11,148 
Vanguard® Mega Cap Index Fund, ETF Shares157,165 4 157,169 73.23 to79.98 2,086 
Vanguard® Real Estate Index Fund, ETF Shares260,925 — 260,925 43.39 to46.96 5,929 
Vanguard® Short-Term Bond Index Fund, ETF Shares22,595 1 22,596 23.26 to25.08 952 
Vanguard® Total Bond Market Index Fund, ETF Shares16,392,868 7 16,392,875 26.34 to30.51 609,023 
(a) Name Change. See Note 1.
6
(b) New Underlying Fund. See Note 1

Separate Account I
of
National Integrity Life Insurance Company
Statement of Operations
For the Year Ended December 31, 2020
Investment
 IncomeExpensesRealized 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 Aggressive ETF Fund$96,812 $75,454 $21,358 $77,215 $103,058 $356,862 $537,135 $558,493 
Touchstone VST Bond Fund38,012 31,796 6,216 14,094 — 137,034 151,128 157,344 
Touchstone VST Common Stock Fund 112,207 263,944 (151,737)290,831 576,625 3,085,505 3,952,961 3,801,224 
Touchstone VST Conservative ETF Fund134,541 79,216 55,325 (14,427)143,275 228,235 357,083 412,408 
Touchstone VST Moderate ETF Fund143,656 92,192 51,464 (112,804)204,233 424,027 515,456 566,920 
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio27,893 26,573 1,320 50,058 28,563 285,244 363,865 365,185 
Fidelity VIP Overseas Portfolio5,169 15,784 (10,615)12,577 5,249 150,721 168,547 157,932 
Fidelity VIP Equity-Income Portfolio126,153 94,130 32,023 3,097 323,935 (23,940)303,092 335,115 
Fidelity VIP Growth Portfolio4,280 77,758 (73,478)243,730 543,894 1,348,837 2,136,461 2,062,983 
Fidelity VIP High Income Portfolio81,117 21,095 60,022 (42,664)— 12,796 (29,868)30,154 
Fidelity VIP Asset Manager Portfolio42,302 37,694 4,608 13,907 36,689 308,293 358,889 363,497 
Fidelity VIP Contrafund® Portfolio34,843 189,170 (154,327)649,372 73,365 2,929,594 3,652,331 3,498,004 
Fidelity VIP Index 500 Portfolio78,390 61,320 17,070 256,227 15,138 434,816 706,181 723,251 
Fidelity VIP Investment Grade Bond Portfolio30,645 19,786 10,859 12,229 530 86,144 98,903 109,762 
Fidelity VIP Government Money Market21,831 102,005 (80,174)— — — — (80,174)
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio216 4,852 (4,636)46,962 33,000 54,217 134,179 129,543 
Fidelity VIP Mid Cap Portfolio14,398 35,235 (20,837)13,488 — 436,126 449,614 428,777 
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio14,473 16,279 (1,806)(1,422)15,074 126,171 139,823 138,017 
Fidelity VIP Balanced Portfolio138,191 152,739 (14,548)245,016 153,003 1,695,233 2,093,252 2,078,704 
Fidelity VIP Bond Index Portfolio 3,208 2,344 864 308 917 3,273 4,498 5,362 
Fidelity VIP Contrafund® Portfolio14,436 259,833 (245,397)572,805 97,300 4,086,570 4,756,675 4,511,278 
Fidelity VIP Disciplined Small Cap Portfolio7,577 18,401 (10,824)(28,311)— 258,258 229,947 219,123 
Fidelity VIP Equity-Income Portfolio49,698 43,577 6,121 (8,948)145,999 (5,010)132,041 138,162 
Fidelity VIP Extended Market Index Portfolio612 566 46 (2)— 7,735 7,733 7,779 
Fidelity VIP Freedom 2010 Portfolio4,196 5,772 (1,576)3,672 17,081 21,026 41,779 40,203 
Fidelity VIP Freedom 2015 Portfolio4,386 6,411 (2,025)753 20,497 29,001 50,251 48,226 
Fidelity VIP Freedom 2020 Portfolio5,823 9,077 (3,254)(856)37,336 32,767 69,247 65,993 
Fidelity VIP Freedom 2025 Portfolio20,234 30,941 (10,707)7,434 86,775 195,848 290,057 279,350 
Fidelity VIP Freedom 2030 Portfolio3,106 4,229 (1,123)12,775 17,042 4,282 34,099 32,976 
Fidelity VIP Growth Portfolio1,745 59,557 (57,812)232,718 405,338 973,040 1,611,096 1,553,284 
Fidelity VIP High Income Portfolio280,624 60,359 220,265 107,154 — (29,247)77,907 298,172 
Fidelity VIP Index 500 Portfolio444,177 410,072 34,105 1,791,129 97,363 2,525,676 4,414,168 4,448,273 
Fidelity VIP International Index Portfolio 693 236 457 30 — 7,744 7,774 8,231 
(a) Name Change. See Note 1.
7
(b) New Underlying Fund. See Note 1.
(c) Merger. See Note 1.

Separate Account I
of
National Integrity Life Insurance Company
Statement of Operations (continued)
For the Year Ended December 31, 2020
Investment
 IncomeExpensesRealized 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$308,352 $221,059 $87,293 $137,251 $5,848 $835,622 $978,721 $1,066,014 
Fidelity VIP Mid Cap Portfolio29,912 105,419 (75,507)(183,684)— 1,407,152 1,223,468 1,147,961 
Fidelity VIP Overseas Portfolio5,165 34,904 (29,739)77,171 10,997 256,405 344,573 314,834 
Fidelity VIP Target Volatility Portfolio5,918 6,991 (1,073)2,418 10,943 21,601 34,962 33,889 
Fidelity VIP Total Market Index Portfolio917 503 414 662 — 18,445 19,107 19,521 
Non-Affiliated Class 1:
Columbia VP – Select Mid Cap Value Fund— 17,303 (17,303)31,801 — 40,610 72,411 55,108 
Franklin Growth and Income VIP Fund58,031 20,305 37,726 89,879 316,357 (387,697)18,539 56,265 
Franklin Income VIP Fund161,382 36,623 124,759 8,190 2,178 (179,439)(169,071)(44,312)
JP Morgan IT Mid Cap Value7,716 7,391 325 7,637 32,199 (56,330)(16,494)(16,169)
Morgan Stanley VIF Emerging Markets Debt Portfolio4,460 1,353 3,107 (1,861)— 2,215 354 3,461 
Morgan Stanley VIF U.S. Real Estate Portfolio13,128 6,960 6,168 55,625 13,034 (196,291)(127,632)(121,464)
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund31,062 31,647 (585)10,342 80,888 91 91,321 90,736 
Columbia VP – Small Cap Value Fund5,027 21,404 (16,377)(133,618)64,585 201,592 132,559 116,182 
Franklin Growth and Income VIP Fund166,395 62,169 104,226 (145,815)972,720 (785,506)41,399 145,625 
Franklin Income VIP Fund735,305 187,639 547,666 (413,267)10,417 (472,137)(874,987)(327,321)
Franklin Large Cap Growth VIP Fund— 76,027 (76,027)171,012 535,853 1,361,400 2,068,265 1,992,238 
Franklin Mutual Shares VIP Fund249,844 126,392 123,452 (391,504)347,356 (608,286)(652,434)(528,982)
Franklin Small Cap Value VIP Fund13,830 13,507 323 (118,734)58,825 80,506 20,597 20,920 
Invesco V.I. American Franchise Fund— 5,347 (5,347)25,886 29,541 82,639 138,066 132,719 
Invesco V.I. American Value Fund38,749 85,368 (46,619)(464,575)59,131 371,928 (33,516)(80,135)
Invesco V.I. Comstock Fund69,828 45,666 24,162 (160,794)86,826 (19,123)(93,091)(68,929)
Invesco V.I. International Growth Fund40,576 28,031 12,545 18,323 44,227 147,238 209,788 222,333 
Invesco V.I. Mid Cap Growth Fund (c)— 1,429 (1,429)(102,598)86,444 1,398 (14,756)(16,185)
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II (b)— 5,364 (5,364)21,705 — 185,249 206,954 201,590 
Templeton Foreign VIP Fund127,521 53,689 73,832 (241,655)— 62,726 (178,929)(105,097)
Templeton Global Bond VIP Fund38,493 6,406 32,087 (46,315)— (19,527)(65,842)(33,755)
Templeton Growth VIP Fund31,447 15,132 16,315 (81,933)— 83,194 1,261 17,576 
Morgan Stanley VIF Emerging Markets Debt Portfolio41,442 13,418 28,024 (10,495)— 18,402 7,907 35,931 
Morgan Stanley VIF Emerging Markets Equity Portfolio24,692 28,201 (3,509)(10,099)31,227 166,244 187,372 183,863 
Morgan Stanley VIF U.S. Real Estate Portfolio52,558 29,659 22,899 (51,561)58,608 (462,864)(455,817)(432,918)
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund— 49,752 (49,752)11,621 375,091 889,298 1,276,010 1,226,258 
BlackRock Global Allocation V.I. Fund7,126 8,415 (1,289)(8,373)34,813 66,332 92,772 91,483 
BlackRock High Yield V.I. Fund10,555 3,100 7,455 (44)— 4,693 4,649 12,104 
BlackRock Total Return V.I. Fund6,532 5,454 1,078 733 17,964 2,666 21,363 22,441 
TOPS® Managed Risk Moderate Growth ETF Portfolio23,560 16,748 6,812 1,155 9,322 29,262 39,739 46,551 
Non-Affiliated Class 4:
American Funds I.S. Bond Fund20,891 13,321 7,570 7,417 7,442 39,701 54,560 62,130 
American Funds I.S. Capital Income Builder Fund68,934 34,339 34,595 (9,589)— (14,674)(24,263)10,332 
(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
Statement of Operations (continued)
For the Year Ended December 31, 2020
Investment
 IncomeExpensesRealized 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$3,840 $32,815 $(28,975)$61,389 $68,076 $558,731 $688,196 $659,221 
American Funds I.S. Growth Fund6,158 44,246 (38,088)68,526 71,654 1,217,894 1,358,074 1,319,986 
American Funds I.S. Growth-Income Fund39,116 46,582 (7,466)16,517 82,232 327,643 426,392 418,926 
American Funds I.S. New World Fund352 12,568 (12,216)30,819 9,874 163,284 203,977 191,761 
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund4,299 5,115 (816)(9,181)39,777 36,874 67,470 66,654 
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund13,546 20,223 (6,677)(40,219)154,312 156,844 270,937 264,260 
Advisor Class:
PIMCO VIT All Asset Portfolio66,704 19,765 46,939 (5,193)— 37,384 32,191 79,130 
PIMCO VIT International Bond Portfolio (US Dollar Hedged)2,518 600 1,918 (13)— (233)(246)1,672 
PIMCO VIT CommodityRealReturn® Strategy Portfolio71,752 17,222 54,530 (187,061)— 137,231 (49,830)4,700 
PIMCO VIT Long-Term U.S. Government Portfolio3,774 3,125 649 4,704 1,860 22,846 29,410 30,059 
PIMCO VIT Low Duration Portfolio25,045 34,323 (9,278)(5,536)— 45,161 39,625 30,347 
PIMCO VIT Real Return Portfolio12,255 13,264 (1,009)804 — 89,298 90,102 89,093 
PIMCO VIT Total Return Portfolio398,293 291,983 106,310 67,494 213,193 904,821 1,185,508 1,291,818 
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund6,200 2,440 3,760 (6,640)909 3,506 (2,225)1,535 
Guggenheim VT Multi-Hedge Strategies Fund4,232 4,818 (586)6,610 — 13,151 19,761 19,175 
Guggenheim VT Long Short Equity Fund533 924 (391)(919)— 2,887 1,968 1,577 
ETF Shares:
iShares® Core S&P 500 ETF304,268 433,918 (129,650)2,312,607 — 361,801 2,674,408 2,544,758 
iShares® Core S&P Mid-Cap ETF77,196 126,249 (49,053)541,364 — 191,787 733,151 684,098 
iShares® Core S&P Small-Cap ETF36,658 66,766 (30,108)279,780 — 98,512 378,292 348,184 
iShares® Core U.S. Aggregate Bond ETF12,610 15,787 (3,177)20,431 — 7,864 28,295 25,118 
iShares® iBoxx $ High Yield Corporate Bond ETF3,150 1,442 1,708 (304)— (1,184)(1,488)220 
iShares® 5-10 Year Investment Grade Corporate Bond ETF (a)20,118 19,470 648 5,701 — 35,512 41,213 41,861 
iShares® International Treasury Bond ETF— 56,076 (56,076)4,249 — 218,501 222,750 166,674 
iShares® S&P 500 Growth ETF22,283 58,252 (35,969)374,436 — 289,192 663,628 627,659 
iShares® S&P 500 Value ETF12,737 12,074 663 20,517 — (17,939)2,578 3,241 
iShares® TIPS Bond ETF1,553 3,327 (1,774)8,875 — 1,635 10,510 8,736 
Vanguard® Developed Markets Index Fund, ETF Shares55,013 61,052 (6,039)58,962 — 150,212 209,174 203,135 
Vanguard® Dividend Appreciation Index Fund, ETF Shares17,716 25,728 (8,012)87,526 — 33,764 121,290 113,278 
Vanguard® Emerging Markets Stock Index Fund, ETF Shares4,682 5,331 (649)10,749 — 17,105 27,854 27,205 
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares1,618 1,145 473 1,834 139 1,868 3,841 4,314 
Vanguard® Large-Cap Index Fund, ETF Shares11,751 18,014 (6,263)59,435 — 67,113 126,548 120,285 
Vanguard® Mega Cap Index Fund, ETF Shares2,298 3,282 (984)9,993 — 15,175 25,168 24,184 
Vanguard® Real Estate Index Fund, ETF Shares9,704 6,121 3,583 1,297 — (17,756)(16,459)(12,876)
Vanguard® Short-Term Bond Index Fund, ETF Shares275 362 (87)42 — 376 418 331 
Vanguard® Total Bond Market Index Fund, ETF Shares368,304 424,093 (55,789)659,525 26,315 172,666 858,506 802,717 
(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 Changes in Net Assets
For the Year Ended December 31, 2020
 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 Aggressive ETF Fund$21,358 $180,273 $356,862 $558,493 $35,038 $(241,310)$7,510 $(8,835)$(207,597)$350,896 $5,628,419 $5,979,315 3,892 (13,417)(9,525)
Touchstone VST Bond Fund6,216 14,094 137,034 157,344 45,845 (253,772)216,447 (13,906)(5,386)151,958 2,129,057 2,281,015 35,609 (37,322)(1,713)
Touchstone VST Common Stock Fund (151,737)867,456 3,085,505 3,801,224 176,084 (1,687,586)(1,298,878)(24,652)(2,835,032)966,192 19,789,050 20,755,242 23,773 (277,932)(254,159)
Touchstone VST Conservative ETF Fund55,325 128,848 228,235 412,408 58,593 (701,036)(99,967)(9,708)(752,118)(339,710)5,619,433 5,279,723 7,356 (51,899)(44,543)
Touchstone VST Moderate ETF Fund51,464 91,429 424,027 566,920 7,251 (518,545)64,947 (8,547)(454,894)112,026 6,854,749 6,966,775 12,368 (38,356)(25,988)
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio1,320 78,621 285,244 365,185 — (148,347)(86,136)(412)(234,895)130,290 2,022,544 2,152,834 6 (9,035)(9,029)
Fidelity VIP Overseas Portfolio(10,615)17,826 150,721 157,932 — (37,557)(12,505)(306)(50,368)107,564 1,222,747 1,330,311 — (2,700)(2,700)
Fidelity VIP Equity-Income Portfolio32,023 327,032 (23,940)335,115 336,147 (719,558)(60,950)(1,101)(445,462)(110,347)7,810,014 7,699,667 633 (5,725)(5,092)
Fidelity VIP Growth Portfolio(73,478)787,624 1,348,837 2,062,983 — (328,925)(39,280)(1,013)(369,218)1,693,765 5,227,290 6,921,055 1 (1,934)(1,933)
Fidelity VIP High Income Portfolio60,022 (42,664)12,796 30,154 880 (84,567)(8,461)(317)(92,465)(62,311)1,742,800 1,680,489 39,616 (42,353)(2,737)
Fidelity VIP Asset Manager Portfolio4,608 50,596 308,293 363,497 14,786 (90,640)667 (744)(75,931)287,566 2,776,765 3,064,331 154 (1,350)(1,196)
Fidelity VIP Contrafund® Portfolio(154,327)722,737 2,929,594 3,498,004 655,049 (1,677,618)(415,270)(2,421)(1,440,260)2,057,744 13,550,838 15,608,582 971 (21,462)(20,491)
Fidelity VIP Index 500 Portfolio17,070 271,365 434,816 723,251 — (376,062)(3,411)(814)(380,287)342,964 4,689,648 5,032,612 190 (10,650)(10,460)
Fidelity VIP Investment Grade Bond Portfolio10,859 12,759 86,144 109,762 — (131,810)(1,620)(538)(133,968)(24,206)1,426,181 1,401,975 27 (7,106)(7,079)
Fidelity VIP Government Money Market(80,174)— — (80,174)26,158 (1,426,906)2,460,489 (4,045)1,055,696 975,522 3,369,373 4,344,895 3,613,128 (3,509,470)103,658 
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio(4,636)79,962 54,217 129,543 — (67,037)— (94)(67,131)62,412 323,201 385,613 1 (1,936)(1,935)
Fidelity VIP Mid Cap Portfolio(20,837)13,488 436,126 428,777 — (198,470)(8,032)(340)(206,842)221,935 2,892,054 3,113,989 — (3,097)(3,097)
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio(1,806)13,652 126,171 138,017 13,888 (91,852)66,102 (2,801)(14,663)123,354 1,103,120 1,226,474 4,322 (4,821)(499)
Fidelity VIP Balanced Portfolio(14,548)398,019 1,695,233 2,078,704 598,260 (835,296)472,855 (9,434)226,385 2,305,089 10,559,689 12,864,778 102,758 (88,115)14,643 
Fidelity VIP Bond Index Portfolio 864 1,225 3,273 5,362 219,775 (7,499)52,481 (1,394)263,363 268,725 84,928 353,653 26,184 (1,589)24,595 
Fidelity VIP Contrafund® Portfolio(245,397)670,105 4,086,570 4,511,278 303,880 (1,980,495)(1,071,873)(53,358)(2,801,846)1,709,432 17,645,539 19,354,971 14,769 (116,573)(101,804)
Fidelity VIP Disciplined Small Cap Portfolio(10,824)(28,311)258,258 219,123 21,439 (62,945)(116,520)(5,233)(163,259)55,864 1,546,404 1,602,268 14,233 (24,725)(10,492)
Fidelity VIP Equity-Income Portfolio6,121 137,051 (5,010)138,162 116,786 (321,146)71,665 (4,200)(136,895)1,267 3,356,249 3,357,516 15,647 (22,215)(6,568)
Fidelity VIP Extended Market Index Portfolio46 (2)7,735 7,779 — — 15,040 — 15,040 22,819 36,575 59,394 1,450 — 1,450 
Fidelity VIP Freedom 2010 Portfolio(1,576)20,753 21,026 40,203 — (24,286)8,713 (871)(16,444)23,759 396,687 420,446 911 (2,037)(1,126)
Fidelity VIP Freedom 2015 Portfolio(2,025)21,250 29,001 48,226 — (5,401)2 (148)(5,547)42,679 413,499 456,178 — (345)(345)
Fidelity VIP Freedom 2020 Portfolio(3,254)36,480 32,767 65,993 225 (98,076)(2,947)(4,604)(105,402)(39,409)652,545 613,136 523 (7,546)(7,023)
Fidelity VIP Freedom 2025 Portfolio(10,707)94,209 195,848 279,350 — (8,977)58,141 (22,699)26,465 305,815 1,968,578 2,274,393 3,671 (1,962)1,709 
Fidelity VIP Freedom 2030 Portfolio(1,123)29,817 4,282 32,976 102,301 (213,549)68,385 (117)(42,980)(10,004)363,118 353,114 9,225 (12,665)(3,440)
Fidelity VIP Growth Portfolio(57,812)638,056 973,040 1,553,284 126,175 (412,353)15,652 (9,287)(279,813)1,273,471 3,900,028 5,173,499 14,397 (21,752)(7,355)
Fidelity VIP High Income Portfolio220,265 107,154 (29,247)298,172 71,089 (259,446)(134,905)(2,852)(326,114)(27,942)6,807,289 6,779,347 1,524,918 (1,530,144)(5,226)
Fidelity VIP Index 500 Portfolio34,105 1,888,492 2,525,676 4,448,273 1,384,320 (2,541,027)51,975 (89,908)(1,194,640)3,253,633 29,166,157 32,419,790 194,421 (244,399)(49,978)
Fidelity VIP International Index Portfolio 457 30 7,744 8,231 40,507 (9)7,225 (149)47,574 55,805 1,512 57,317 4,877 (68)4,809 
Fidelity VIP Investment Grade Bond Portfolio87,293 143,099 835,622 1,066,014 563,107 (1,213,665)152,960 (134,342)(631,940)434,074 15,004,695 15,438,769 124,056 (170,617)(46,561)
Fidelity VIP Mid Cap Portfolio(75,507)(183,684)1,407,152 1,147,961 42,278 (766,956)(419,480)(11,954)(1,156,112)(8,151)8,715,713 8,707,562 17,836 (66,542)(48,706)
Fidelity VIP Overseas Portfolio(29,739)88,168 256,405 314,834 12,292 (366,709)(11,720)(5,033)(371,170)(56,336)2,672,887 2,616,551 6,456 (36,279)(29,823)
Fidelity VIP Target Volatility Portfolio(1,073)13,361 21,601 33,889 11,250 (15,444)(10,079)(6,073)(20,346)13,543 485,798 499,341 944 (2,489)(1,545)
Fidelity VIP Total Market Index Portfolio414 662 18,445 19,521 61,014 (974)2,793 (143)62,690 82,211 — 82,211 6,674 (241)6,433 
Non-Affiliated Class 1:
Columbia VP – Select Mid Cap Value Fund(17,303)31,801 40,610 55,108 39,935 (142,960)(48,193)(1,125)(152,343)(97,235)1,538,817 1,441,582 4,787 (14,070)(9,283)
Franklin Growth and Income VIP Fund37,726 406,236 (387,697)56,265 — (207,102)2 (408)(207,508)(151,243)1,750,813 1,599,570 — (7,107)(7,107)
Franklin Income VIP Fund124,759 10,368 (179,439)(44,312)100,139 (537,747)28,967 (660)(409,301)(453,613)3,052,861 2,599,248 1,939 (17,399)(15,460)
JP Morgan IT Mid Cap Value325 39,836 (56,330)(16,169)— (36,382)(29,192)(184)(65,758)(81,927)629,905 547,978 — (2,389)(2,389)
Morgan Stanley VIF Emerging Markets Debt Portfolio3,107 (1,861)2,215 3,461 — (5,543)(1,403)(48)(6,994)(3,533)107,164 103,631 3 (251)(248)
Morgan Stanley VIF U.S. Real Estate Portfolio6,168 68,659 (196,291)(121,464)4,886 (72,350)(44,599)(170)(112,233)(233,697)714,045 480,348 224 (3,418)(3,194)
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund(585)91,230 91 90,736 13,500 (77,157)51,373 (12,025)(24,309)66,427 2,148,433 2,214,860 7,124 (8,904)(1,780)
Columbia VP – Small Cap Value Fund(16,377)(69,033)201,592 116,182 22,061 (152,872)9,345 (7,257)(128,723)(12,541)1,750,675 1,738,134 8,492 (13,771)(5,279)
Franklin Growth and Income VIP Fund104,226 826,905 (785,506)145,625 85,534 (534,417)(231,672)(4,682)(685,237)(539,612)4,983,199 4,443,587 10,756 (41,625)(30,869)



(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 (continued)
For the Year Ended December 31, 2020
 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$547,666 $(402,850)$(472,137)$(327,321)$366,114 $(1,028,050)$(963,914)$(3,826)$(1,629,676)$(1,956,997)$14,512,889 $12,555,892 39,985 (153,810)(113,825)
Franklin Large Cap Growth VIP Fund(76,027)706,865 1,361,400 1,992,238 85,235 (705,480)(185,998)(6,053)(812,296)1,179,942 5,003,118 6,183,060 13,461 (35,693)(22,232)
Franklin Mutual Shares VIP Fund123,452 (44,148)(608,286)(528,982)268,297 (861,572)682,592 (56,821)32,496 (496,486)9,919,349 9,422,863 91,743 (76,889)14,854 
Franklin Small Cap Value VIP Fund323 (59,909)80,506 20,920 19,200 (84,175)17,787 (1,316)(48,504)(27,584)1,103,585 1,076,001 7,713 (11,143)(3,430)
Invesco V.I. American Franchise Fund(5,347)55,427 82,639 132,719 — (21,348)(6,143)(1,203)(28,694)104,025 356,087 460,112 2,030 (2,723)(693)
Invesco V.I. American Value Fund(46,619)(405,444)371,928 (80,135)189,445 (593,876)(124,002)(26,938)(555,371)(635,506)7,406,337 6,770,831 39,640 (70,904)(31,264)
Invesco V.I. Comstock Fund24,162 (73,968)(19,123)(68,929)122,683 (351,202)113,842 (23,154)(137,831)(206,760)3,721,655 3,514,895 30,911 (35,576)(4,665)
Invesco V.I. International Growth Fund12,545 62,550 147,238 222,333 58,132 (243,838)(65,191)(13,972)(264,869)(42,536)2,145,714 2,103,178 11,142 (31,448)(20,306)
Invesco V.I. Mid Cap Growth Fund (c)(1,429)(16,154)1,398 (16,185)959 (2,309)(287,677)(135)(289,162)(305,347)305,347 — 581 (20,673)(20,092)
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II (b)(5,364)21,705 185,249 201,590 22,052 (5,793)459,008 (616)474,651 676,241 — 676,241 51,120 (5,489)45,631 
Templeton Foreign VIP Fund73,832 (241,655)62,726 (105,097)91,515 (497,003)243,496 (24,242)(186,234)(291,331)4,336,308 4,044,977 44,858 (55,711)(10,853)
Templeton Global Bond VIP Fund32,087 (46,315)(19,527)(33,755)10,396 (139,001)(89,703)(130)(218,438)(252,193)585,237 333,044 14,081 (38,203)(24,122)
Templeton Growth VIP Fund16,315 (81,933)83,194 17,576 13,688 (187,886)(7,303)(1,687)(183,188)(165,612)1,233,778 1,068,166 3,138 (18,767)(15,629)
Morgan Stanley VIF Emerging Markets Debt Portfolio28,024 (10,495)18,402 35,931 14,521 (56,080)(76,119)(1,488)(119,166)(83,235)953,060 869,825 4,297 (12,214)(7,917)
Morgan Stanley VIF Emerging Markets Equity Portfolio(3,509)21,128 166,244 183,863 27,807 (216,121)(280,462)(3,410)(472,186)(288,323)2,322,799 2,034,476 11,864 (39,852)(27,988)
Morgan Stanley VIF U.S. Real Estate Portfolio22,899 7,047 (462,864)(432,918)30,228 (184,359)199,110 (8,282)36,697 (396,221)2,526,383 2,130,162 29,665 (23,082)6,583 
 Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund(49,752)386,712 889,298 1,226,258 115,020 (263,919)(77,690)(13,451)(240,040)986,218 3,163,979 4,150,197 14,463 (22,552)(8,089)
BlackRock Global Allocation V.I. Fund(1,289)26,440 66,332 91,483 440 (23,275)(56,252)(2,343)(81,430)10,053 612,543 622,596 159 (7,048)(6,889)
BlackRock High Yield V.I. Fund7,455 (44)4,693 12,104 2,000 (1,775)8,023 (238)8,010 20,114 210,299 230,413 864 (187)677 
BlackRock Total Return V.I. Fund1,078 18,697 2,666 22,441 40,507 (9,620)20,599 (2,694)48,792 71,233 302,665 373,898 6,588 (2,094)4,494 
TOPS® Managed Risk Moderate Growth ETF Portfolio6,812 10,477 29,262 46,551 20,250 (41,988)9,057 (8,940)(21,621)24,930 1,152,672 1,177,602 2,301 (4,262)(1,961)
 Non-Affiliated Class 4:
American Funds I.S. Bond Fund7,570 14,859 39,701 62,130 247,169 (822)194,598 (6,839)434,106 496,236 679,671 1,175,907 47,974 (8,906)39,068 
American Funds I.S. Capital Income Builder Fund34,595 (9,589)(14,674)10,332 323,191 (65,226)(368,432)(5,774)(116,241)(105,909)3,031,500 2,925,591 125,805 (141,963)(16,158)
American Funds I.S. Global Growth Fund(28,975)129,465 558,731 659,221 84,955 (99,652)(15,726)(6,616)(37,039)622,182 2,254,646 2,876,828 14,076 (14,953)(877)
American Funds I.S. Growth Fund(38,088)140,180 1,217,894 1,319,986 122,382 (72,387)66,051 (2,654)113,392 1,433,378 2,567,272 4,000,650 13,209 (7,797)5,412 
American Funds I.S. Growth-Income Fund(7,466)98,749 327,643 418,926 215,325 (75,152)288,371 (9,050)419,494 838,420 3,012,856 3,851,276 34,710 (10,441)24,269 
American Funds I.S. New World Fund(12,216)40,693 163,284 191,761 54,809 (90,166)(26,647)(5,199)(67,203)124,558 936,964 1,061,522 5,384 (10,472)(5,088)
 Non-Affiliated Class A:
DWS Small Cap Index VIP Fund(816)30,596 36,874 66,654 5,898 (74,506)(94)(67)(68,769)(2,115)431,386 429,271 13 (1,953)(1,940)
 Non-Affiliated Class B:
DWS Small Cap Index VIP Fund(6,677)114,093 156,844 264,260 24,690 (181,149)(42,302)(1,209)(199,970)64,290 1,677,653 1,741,943 6,204 (13,943)(7,739)
 Advisor Class:
PIMCO VIT All Asset Portfolio46,939 (5,193)37,384 79,130 22,652 (49,049)(216,446)(1,127)(243,970)(164,840)1,532,503 1,367,663 5,157 (22,694)(17,537)
PIMCO VIT International Bond Portfolio (US Dollar Hedged)1,918 (13)(233)1,672 — (432)7,500 (3)7,065 8,737 40,212 48,949 654 (39)615 
PIMCO VIT CommodityRealReturn® Strategy Portfolio54,530 (187,061)137,231 4,700 8,662 (116,883)67,116 (6,942)(48,047)(43,347)1,280,144 1,236,797 39,142 (48,841)(9,699)
PIMCO VIT Long-Term U.S. Government Portfolio649 6,564 22,846 30,059 2,383 (3,395)46,428 (500)44,916 74,975 200,349 275,324 4,904 (1,572)3,332 
PIMCO VIT Low Duration Portfolio(9,278)(5,536)45,161 30,347 83,767 (222,669)448,161 (7,468)301,791 332,138 2,124,791 2,456,929 49,765 (22,425)27,340 
PIMCO VIT Real Return Portfolio(1,009)804 89,298 89,093 12,384 (91,212)20,228 (1,183)(59,783)29,310 905,848 935,158 3,019 (7,622)(4,603)
PIMCO VIT Total Return Portfolio106,310 280,687 904,821 1,291,818 1,074,713 (2,234,124)425,425 (143,151)(877,137)414,681 19,493,650 19,908,331 178,634 (239,257)(60,623)
 Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund3,760 (5,731)3,506 1,535 304 (21,741)4,028 (912)(18,321)(16,786)167,848 151,062 2,321 (5,200)(2,879)
Guggenheim VT Multi-Hedge Strategies Fund(586)6,610 13,151 19,175 — (47,081)(2,701)(936)(50,718)(31,543)344,763 313,220 1,360 (7,037)(5,677)
Guggenheim VT Long Short Equity Fund(391)(919)2,887 1,577 — (14,036)2 (75)(14,109)(12,532)71,584 59,052 3 (1,401)(1,398)
 ETF Shares:
iShares® Core S&P 500 ETF(129,650)2,312,607 361,801 2,544,758 97,150 (3,038,740)(764,782)— (3,706,372)(1,161,614)18,622,009 17,460,395 15,069 (71,217)(56,148)
iShares® Core S&P Mid-Cap ETF(49,053)541,364 191,787 684,098 65,110 (864,866)48,550 — (751,206)(67,108)5,399,322 5,332,214 17,927 (28,836)(10,909)
iShares® Core S&P Small-Cap ETF(30,108)279,780 98,512 348,184 23,812 (441,029)90,632 — (326,585)21,599 2,869,836 2,891,435 11,636 (15,241)(3,605)
iShares® Core U.S. Aggregate Bond ETF(3,177)20,431 7,864 25,118 17,713 (29,531)(9,119)— (20,937)4,181 581,938 586,119 4,219 (5,066)(847)
iShares® iBoxx $ High Yield Corporate Bond ETF1,708 (304)(1,184)220 350 (14,799)10,683 — (3,766)(3,546)74,277 70,731 360 (512)(152)
iShares® 5-10 Year Investment Grade Corporate Bond ETF (a)648 5,701 35,512 41,861 6,370 (48,166)61,994 — 20,198 62,059 715,838 777,897 4,465 (3,968)497 
iShares® International Treasury Bond ETF(56,076)4,249 218,501 166,674 26,626 (397,491)114,049 — (256,816)(90,142)2,325,634 2,235,492 12,711 (24,287)(11,576)
iShares® S&P 500 Growth ETF(35,969)374,436 289,192 627,659 39,319 (248,166)(313,962)— (522,809)104,850 2,339,275 2,444,125 1,394 (8,327)(6,933)
iShares® S&P 500 Value ETF663 20,517 (17,939)3,241 17,386 (21,350)792 — (3,172)69 519,767 519,836 1,475 (1,355)120 


(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, 2020
 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$(1,774)$8,875 $1,635 $8,736 $9,329 $(1,818)$(65,334)$— $(57,823)$(49,087)$126,676 $77,589 816 (3,231)(2,415)
Vanguard® Developed Markets Index Fund, ETF Shares(6,039)58,962 150,212 203,135 12,347 (399,247)119,422 — (267,478)(64,343)2,603,076 2,538,733 9,230 (15,475)(6,245)
Vanguard® Dividend Appreciation Index Fund, ETF Shares(8,012)87,526 33,764 113,278 20,138 (99,280)(65,372)— (144,514)(31,236)1,048,545 1,017,309 885 (3,509)(2,624)
Vanguard® Emerging Markets Stock Index Fund, ETF Shares(649)10,749 17,105 27,205 15,038 (27,702)10,212 — (2,452)24,753 222,074 246,827 1,702 (1,827)(125)
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares473 1,973 1,868 4,314 — (5,818)8,423 — 2,605 6,919 61,061 67,980 270 (176)94 
Vanguard® Large-Cap Index Fund, ETF Shares(6,263)59,435 67,113 120,285 54,365 (79,485)(7,857)— (32,977)87,308 727,554 814,862 1,729 (2,406)(677)
Vanguard® Mega Cap Index Fund, ETF Shares(984)9,993 15,175 24,184 — (8,464)1,255 — (7,209)16,975 140,194 157,169 171 (286)(115)
Vanguard® Real Estate Index Fund, ETF Shares3,583 1,297 (17,756)(12,876)3,720 (11,678)37,791 — 29,833 16,957 243,968 260,925 1,180 (399)781 
Vanguard® Short-Term Bond Index Fund, ETF Shares(87)42 376 331 — (1,270)8,960 — 7,690 8,021 14,575 22,596 411 (77)334 
Vanguard® Total Bond Market Index Fund, ETF Shares(55,789)685,840 172,666 802,717 110,460 (2,906,726)802,370 — (1,993,896)(1,191,179)17,584,054 16,392,875 94,440 (171,321)(76,881)

(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
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 redeemedIncrease
(decrease) in
units
Affiliated:
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 Fund59,849 (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 Moderate ETF Fund42,498 140,526 963,493 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 Portfolio7,047 110,021 269,782 386,850 — (79,948)(2)(441)(80,391)306,459 1,716,085 2,022,544 6 3,030 (3,024)
Fidelity VIP Overseas Portfolio3,650 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 Portfolio46,606 562,441 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 Portfolio65,591 349 129,837 195,777 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 Portfolio10,792 111,437 291,287 413,516 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 Portfolio25,056 357,301 762,756 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 Portfolio18,506 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 Market34,918 — — 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 Portfolio2,522 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 Portfolio18,740 539,231 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 Portfolio13,672 209,439 468,016 691,127 309,494 (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 Portfolio1,378 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 Portfolio704 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 Portfolio1,574 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 Portfolio5,613 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 Portfolio266,766 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 Portfolio75,813 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 Portfolio161,053 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 Fund19,569 159,836 188,599 368,004 — (197,144)349 (440)(197,235)170,769 1,580,044 1,750,813 360 7,320 (6,960)
Franklin Income VIP Fund137,122 107,202 204,103 448,427 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 Value1,923 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 Portfolio4,459 (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 Portfolio3,134 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 Fund16,447 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 Fund39,887 386,018 607,438 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)
Franklin Income VIP Fund558,813 216,927 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 Fund34,651 978,794 784,056 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 

(a) Name Change. See Note 1.
13
(b) New Underlying Fund. 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 redeemedIncrease
(decrease) in
units
Non-Affiliated Class 2 (continued):
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 Fund9,948 435,317 260,690 705,955 261,718 (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 Fund9,556 (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 Fund24,839 (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 Fund16,386 230,803 (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 Portfolio36,758 (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 Portfolio4,238 164,455 207,516 376,209 157,894 (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. Fund6,175 (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. Fund2,420 993 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 Portfolio6,483 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 Fund6,549 (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 Fund30,954 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 Fund564 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 Portfolio20,376 (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 Portfolio36,772 (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 Portfolio1,307 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 Portfolio23,407 (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 Portfolio837 (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 Portfolio280,633 (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 Fund3,020 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 ETF183 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 ETF2,917 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 ETF5,555 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)
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 Shares15,601 106,747 358,799 481,147 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 Shares1,770 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 Shares965 1,352 4,558 6,875 — (8,391)(5)— (8,396)(1,521)62,582 61,061 — 279 (279)


(a) Name Change. See Note 1.
14
(b) New Underlying Fund. 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 redeemedIncrease
(decrease) in
units
ETF Shares (continued):
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 Shares2,199 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 Shares3 (26)485 462 — (4,520)533 — (3,987)(3,525)18,100 14,575 24 186 (162)
Vanguard® Total Bond Market Index Fund, ETF Shares35,552 592,851 528,124 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.
15
(b) New Underlying Fund. See Note 1.

Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements
December 31, 2020
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 SeriesColumbia Funds Variable Portfolios
Non-Affiliated Class 2Non-Affiliated Class 1
American Funds I.S. Managed Risk Asset Allocation Fund
Columbia VP – Select Mid Cap Value Fund
Non-Affiliated Class 4Non-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
16
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)
1. Organization and Nature of Operations (continued)
Fidelity Variable Insurance ProductsFranklin 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 PortfolioiShares® 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 PortfolioiShares® 5-10 Year Investment Grade 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 PortfolioInvesco 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 Oppenheimer V.I. Discovery Mid Cap Growth
Fidelity VIP Target Volatility Portfolio
Fidelity VIP Total Market Index PortfolioJPMorgan Insurance Trust
Franklin Templeton VIP TrustNon-Affiliated Class 1:
Non-Affiliated Class 1:JP Morgan IT Mid Cap Value
Franklin Growth and Income VIP Fund
Franklin Income VIP FundMorgan 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
17
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 Aggressive ETF Fund
Morgan Stanley VIF Emerging Markets Equity Portfolio
Touchstone VST Bond Fund
Morgan Stanley VIF U.S. Real Estate Portfolio
Touchstone VST Common Stock Fund
Touchstone VST Conservative ETF Fund
Pimco Variable Insurance TrustTouchstone VST Moderate ETF Fund
Advisor Class:
PIMCO VIT All Asset Portfolio
The Vanguard Index Funds
PIMCO VIT International Bond Portfolio (US Dollar Hedged)ETF Shares:
PIMCO VIT CommodityRealReturn® Strategy Portfolio
Vanguard® Developed Markets Index Fund, ETF Shares
PIMCO VIT Long-Term U.S. Government Portfolio
Vanguard® Dividend Appreciation Index Fund, ETF Shares
PIMCO VIT Low Duration Portfolio
Vanguard® Emerging Markets Stock Index Fund, ETF Shares
PIMCO VIT Real Return Portfolio
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares
PIMCO VIT Total Return Portfolio
Vanguard® Large-Cap Index Fund, ETF Shares
Vanguard® Mega Cap Index Fund, ETF Shares
Northern Lights Variable TrustVanguard® Real Estate Index Fund, ETF Shares
Non-Affiliated Class 3:Vanguard® Short-Term Bond Index Fund, ETF Shares
TOPS® Managed Risk Moderate Growth ETF Portfolio
Vanguard® Total Bond Market Index Fund, ETF Shares















18
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, 2020, the following Underlying Funds had name changes that were made effective:
Date:New Name:Old Name:
9/30/2020iShares® 5-10 Year Investment Grade Corporate Bond ETFiShares® Intermediate-Term Corporate Bond ETF
During the year ended December 31, 2019, the following Underlying Funds had name changes that were made effective:
Date:New Name:Old Name:
5/1/2019Columbia VP - Select Mid Cap Value Class 1Columbia 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, 2020 except for the following Underlying Funds:
Period:Underlying Fund:
1/1/2020 - 4/29/2020Invesco V.I. Mid Cap Growth Fund
4/30/2020 - 12/31/2020Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II
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, 2020 and December 31, 2019 with the exception of the following Underlying Funds:
Period:Underlying Fund:
1/1/2020 - 4/29/2020Invesco V.I. Mid Cap Growth Fund
4/30/2020 - 12/31/2020Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II
7/12/2019 - 12/31/2019Touchstone VST Bond Fund
7/12/2019 - 12/31/2019Touchstone VST Common Stock Fund
7/12/2019 - 12/31/2019Fidelity VIP Bond Index Portfolio
7/12/2019 - 12/31/2019Fidelity VIP International Index Portfolio
7/12/2019 - 12/31/2019Fidelity VIP Extended Market Index Portfolio
All of the Underlying Funds had activity during the year ended December 31, 2020. All of the Underlying Funds had activity during the year ended December 31, 2019 except for the following Underlying Fund:
Fidelity VIP Total Market Index Portfolio*
* The Underlying Fund commenced operations on July 12, 2019
19
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)
1. Organization and Nature of Operations (continued)
As a result of restructuring in 2020 or 2019, 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:
4/30/2020Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series IIInvesco V.I. Mid Cap Growth Fund
7/12/2019Touchstone VST Bond FundTouchstone VST Active Bond Fund
7/12/2019Touchstone VST Common Stock FundTouchstone VST Focused Fund
7/12/2019Touchstone VST Common Stock FundTouchstone VST Large Cap Core Equity Fund

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 104 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, 2020. The difference between cost and fair value is reflected as unrealized appreciation or depreciation of investments.


20
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

2. Summary of Significant Accounting Policies (continued)

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 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.

21
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

2. Summary of Significant Accounting Policies (continued)

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.

Risks and Uncertainties

The Company is exposed to risk associated with the ongoing outbreak 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 continues to evolve. 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 Separate Account; and disruptions of product marketing and sales efforts. The Separate Account has business continuity plans in place to mitigate the risks posed to business operations by disruptive incidents such as these.

Subsequent Events

Management has evaluated subsequent events though the issuance of these financial statements and
determined that no additional disclosures are required.



22
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, 2020 and the cost of investments held at December 31, 2020, for each subaccount, were as follows:
Subaccount Purchases  Sales  Cost
Affiliated:
Touchstone VST Aggressive ETF Fund$285,622 $(368,807)$4,797,662 
Touchstone VST Bond Fund417,927 (417,095)2,117,224 
Touchstone VST Common Stock Fund 928,878 (3,339,017)16,503,523 
Touchstone VST Conservative ETF Fund401,721 (955,238)5,104,640 
Touchstone VST Moderate ETF Fund564,896 (764,087)7,017,427 
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio56,625 (261,637)1,517,404 
Fidelity VIP Overseas Portfolio10,419 (66,154)847,313 
Fidelity VIP Equity-Income Portfolio500,012 (589,515)6,771,600 
Fidelity VIP Growth Portfolio548,180 (446,982)3,526,398 
Fidelity VIP High Income Portfolio1,245,982 (1,278,425)1,653,764 
Fidelity VIP Asset Manager Portfolio88,726 (123,360)2,596,549 
Fidelity VIP Contrafund® Portfolio167,959 (1,689,180)10,131,370 
Fidelity VIP Index 500 Portfolio109,273 (457,352)2,119,982 
Fidelity VIP Investment Grade Bond Portfolio31,555 (154,134)1,278,614 
Fidelity VIP Government Money Market35,191,669 (34,216,148)4,344,896 
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio33,217 (71,984)212,118 
Fidelity VIP Mid Cap Portfolio14,408 (242,087)2,609,182 
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio100,581 (101,974)1,091,743 
Fidelity VIP Balanced Portfolio2,501,847 (2,137,010)10,120,408 
Fidelity VIP Bond Index Portfolio 284,135 (18,991)352,130 
Fidelity VIP Contrafund® Portfolio524,568 (3,474,513)13,255,289 
Fidelity VIP Disciplined Small Cap Portfolio251,808 (425,896)1,347,662 
Fidelity VIP Equity-Income Portfolio447,204 (431,979)2,980,113 
Fidelity VIP Extended Market Index Portfolio15,651 (566)49,036 
Fidelity VIP Freedom 2010 Portfolio36,388 (37,326)354,243 
Fidelity VIP Freedom 2015 Portfolio24,888 (11,963)385,330 
Fidelity VIP Freedom 2020 Portfolio50,806 (122,126)514,159 
Fidelity VIP Freedom 2025 Portfolio166,044 (63,510)1,897,589 
Fidelity VIP Freedom 2030 Portfolio185,084 (212,144)279,649 
Fidelity VIP Growth Portfolio857,620 (789,905)3,384,104 
Fidelity VIP High Income Portfolio30,005,263 (30,111,111)6,905,578 
Fidelity VIP Index 500 Portfolio5,045,382 (6,108,554)22,247,768 
Fidelity VIP International Index Portfolio 48,987 (958)49,543 
Fidelity VIP Investment Grade Bond Portfolio2,139,180 (2,677,979)14,188,014 
Fidelity VIP Mid Cap Portfolio348,089 (1,579,709)7,314,080 
Fidelity VIP Overseas Portfolio89,812 (479,723)1,950,342 
Fidelity VIP Target Volatility Portfolio29,540 (40,017)430,119 
Fidelity VIP Total Market Index Portfolio66,345 (3,241)63,767 



(a) Name Change. See Note 1.
23
(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$72,646 $(242,295)$1,056,892 
Franklin Growth and Income VIP Fund374,390 (227,814)1,581,515 
Franklin Income VIP Fund218,992 (501,356)2,588,168 
JP Morgan IT Mid Cap Value39,919 (73,153)447,659 
Morgan Stanley VIF Emerging Markets Debt Portfolio4,561 (8,447)107,302 
Morgan Stanley VIF U.S. Real Estate Portfolio34,381 (127,415)472,525 
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund203,161 (147,166)2,002,431 
Columbia VP – Small Cap Value Fund236,075 (316,587)1,725,401 
Franklin Growth and Income VIP Fund1,316,618 (924,911)4,659,023 
Franklin Income VIP Fund1,391,226 (2,462,819)12,779,606 
Franklin Large Cap Growth VIP Fund945,204 (1,297,677)4,589,219 
Franklin Mutual Shares VIP Fund1,706,328 (1,203,025)10,383,482 
Franklin Small Cap Value VIP Fund193,080 (182,439)1,114,104 
Invesco V.I. American Franchise Fund96,318 (100,821)324,643 
Invesco V.I. American Value Fund685,002 (1,227,864)7,226,176 
Invesco V.I. Comstock Fund582,959 (609,801)3,649,723 
Invesco V.I. International Growth Fund215,097 (423,193)1,801,416 
Invesco V.I. Mid Cap Growth Fund (c)94,227 (298,373)— 
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II (b)550,583 (81,297)490,992 
Templeton Foreign VIP Fund521,643 (634,048)4,177,398 
Templeton Global Bond VIP Fund166,855 (353,205)374,470 
Templeton Growth VIP Fund68,960 (235,831)1,139,950 
Morgan Stanley VIF Emerging Markets Debt Portfolio105,999 (197,140)865,527 
Morgan Stanley VIF Emerging Markets Equity Portfolio203,988 (648,455)1,794,836 
Morgan Stanley VIF U.S. Real Estate Portfolio429,495 (311,287)2,401,469 
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund754,564 (669,265)3,582,827 
BlackRock Global Allocation V.I. Fund43,881 (91,787)539,192 
BlackRock High Yield V.I. Fund20,822 (5,358)220,315 
BlackRock Total Return V.I. Fund95,819 (27,984)364,649 
TOPS® Managed Risk Moderate Growth ETF Portfolio59,500 (64,989)1,109,922 
Non-Affiliated Class 4:
American Funds I.S. Bond Fund560,496 (111,380)1,121,823 
American Funds I.S. Capital Income Builder Fund1,412,117 (1,493,762)2,731,453 
American Funds I.S. Global Growth Fund314,795 (312,731)2,048,988 
American Funds I.S. Growth Fund388,040 (241,081)2,533,302 
American Funds I.S. Growth-Income Fund733,728 (239,467)3,361,943 
American Funds I.S. New World Fund72,173 (141,716)776,550 
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund44,406 (74,216)377,122 
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund269,939 (322,271)1,521,618 
Advisor Class:
PIMCO VIT All Asset Portfolio133,365 (330,396)1,289,301 
PIMCO VIT International Bond Portfolio (US Dollar Hedged)10,017 (1,035)48,490 
PIMCO VIT CommodityRealReturn® Strategy Portfolio195,770 (189,286)1,425,391 
PIMCO VIT Long-Term U.S. Government Portfolio71,926 (24,502)238,619 
PIMCO VIT Low Duration Portfolio580,705 (288,189)2,439,244 
PIMCO VIT Real Return Portfolio50,852 (111,641)855,428 
(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
Advisor Class (continued):
PIMCO VIT Total Return Portfolio$3,248,910 $(3,806,546)$18,900,739 
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund21,574 (35,229)165,393 
Guggenheim VT Multi-Hedge Strategies Fund16,237 (67,540)278,176 
Guggenheim VT Long Short Equity Fund534 (15,036)59,550 
ETF Shares:
iShares® Core S&P 500 ETF1,087,421 (4,923,444)11,628,830 
iShares® Core S&P Mid-Cap ETF794,078 (1,594,336)3,881,346 
iShares® Core S&P Small-Cap ETF501,066 (857,758)2,122,982 
iShares® Core U.S. Aggregate Bond ETF123,090 (147,202)595,910 
iShares® iBoxx $ High Yield Corporate Bond ETF14,449 (16,507)125,989 
iShares® 5-10 Year Investment Grade Corporate Bond ETF (a)148,257 (127,412)735,359 
iShares® International Treasury Bond ETF290,730 (603,622)1,935,995 
iShares® S&P 500 Growth ETF119,018 (677,796)1,322,100 
iShares® S&P 500 Value ETF79,127 (81,637)453,636 
iShares® TIPS Bond ETF20,944 (80,540)76,876 
Vanguard® Developed Markets Index Fund, ETF Shares319,994 (593,511)2,326,455 
Vanguard® Dividend Appreciation Index Fund, ETF Shares62,404 (214,929)737,509 
Vanguard® Emerging Markets Stock Index Fund, ETF Shares49,546 (52,648)231,301 
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares10,182 (6,965)70,117 
Vanguard® Large-Cap Index Fund, ETF Shares120,770 (160,009)566,745 
Vanguard® Mega Cap Index Fund, ETF Shares13,542 (21,735)94,412 
Vanguard® Real Estate Index Fund, ETF Shares55,849 (22,433)278,300 
Vanguard® Short-Term Bond Index Fund, ETF Shares9,826 (2,224)25,452 
Vanguard® Total Bond Market Index Fund, ETF Shares2,923,447 (4,946,820)17,089,052 
(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)
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:
ContractsMortality andAnnual Administration
Expense %Fee
1GrandMaster1.35 $30 
2GrandMaster flex31.55 $50 
3IQ1.35 $30 
4IQ31.45 $30 
5IQ Advisor - Standard0.60 N/A
IQ Advisor - Enhanced0.80 N/A
6AnnuiChoice1.00 $30 
7AnnuiChoice II1.15 $30 
AnnuiChoice II - GMAB Rider1.75 $30 
8Pinnacle Plus1.67 $40 
Pinnacle Plus- Reduced M&E1.15 $40 
9Pinnacle1.35 $30 
Pinnacle-Reduced M&E1.10 $30 
10Pinnacle IV1.45 $30 
Pinnacle IV - GMAB2.05 $30 
11Pinnacle V1.55 $30 
Pinnacle V - GMAB2.15 $30 
12AdvantEdge1.60 $50 
13Varoom1.75 N/A
Varoom - Standard option2.35 N/A
Varoom - Self Styled Option2.55 N/A
14Varoom II1.90 N/A
Varoom II - Standard Option2.55 N/A
Varoom II - Self Styled Option2.75 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.

26
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.

27
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. The financial highlights include historical highlights for funds that may no longer be offered in the current year statements.

** 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. Therefore, the Investment Income Ratio is greatly affected by the amount of subaccount assets that are present on specific dividend record dates.

*** 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.


28
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)

For Year Ended 2020UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Affiliated:
Touchstone VST Aggressive ETF Fund240 $19.98 to$25.30 $5,979 1.81 %1.00 %to1.60 %10.05 %to10.72 %
Touchstone VST Bond Fund208 10.96 to11.07 2,281 1.77 %1.00 %to1.67 %7.79 %to8.53 %
Touchstone VST Common Stock Fund 1,580 13.09 to13.22 20,755 0.60 %1.00 %to1.67 %21.42 %to22.25 %
Touchstone VST Conservative ETF Fund286 16.25 to20.04 5,280 2.52 %1.00 %to1.60 %8.15 %to8.81 %
Touchstone VST Moderate ETF Fund350 22.20 to23.13 6,967 2.22 %1.00 %to2.05 %8.79 %to9.96 %
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio67 25.02to40.752,153 1.43 %1.35 %to1.35 %20.74 %to20.74 %
Fidelity VIP Overseas Portfolio34 13.43to17.881,330 0.45 %1.15 %to1.55 %13.82 %to14.28 %
Fidelity VIP Equity-Income Portfolio88 32.93to33.677,700 1.82 %1.10 %to1.35 %5.25 %to5.52 %
Fidelity VIP Growth Portfolio27 258.15to258.156,921 0.07 %1.35 %to1.35 %41.95 %to41.95 %
Fidelity VIP High Income Portfolio53 31.421,680 5.23 %1.35 %1.36 %
Fidelity VIP Asset Manager Portfolio45 68.773,064 1.53 %1.35 %13.32 %
Fidelity VIP Contrafund® Portfolio157 64.40to65.8615,609 0.25 %1.10 %to1.35 %28.80 %to29.13 %
Fidelity VIP Index 500 Portfolio90 27.19to28.205,033 1.74 %1.10 %to1.45 %16.52 %to16.94 %
Fidelity VIP Investment Grade Bond Portfolio68 15.30to16.511,402 2.14 %1.00 %to1.55 %7.70 %to8.30 %
Fidelity VIP Government Money Market448 9.30to9.914,345 0.31 %1.00 %to2.75 %(2.44)%to(0.68)%
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio10 37.57to37.57386 0.06 %1.35 %to1.35 %41.81 %to41.81 %
Fidelity VIP Mid Cap Portfolio38 80.30to84.323,114 0.56 %1.10 %to1.35 %16.45 %to16.74 %
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio64 17.36to25.011,226 1.32 %1.00 %to1.60 %12.70 %to13.39 %
Fidelity VIP Balanced Portfolio513 24.05to33.8312,865 1.29 %1.00 %to1.60 %20.17 %to20.91 %
Fidelity VIP Bond Index Portfolio 33 10.72to10.78354 2.03 %1.15 %to1.55 %5.60 %to6.03 %
Fidelity VIP Contrafund® Portfolio565 46.75to52.7419,355 0.08 %1.00 %to1.67 %28.06 %to28.93 %
Fidelity VIP Disciplined Small Cap Portfolio76 20.16to21.761,602 0.57 %1.00 %to1.55 %16.29 %to16.94 %
Fidelity VIP Equity-Income Portfolio170 26.67to27.563,358 1.63 %1.00 %to1.67 %4.66 %to5.38 %
Fidelity VIP Extended Market Index Portfolio5 12.07to12.1159 1.67 %1.35 %to1.55 %14.39 %to14.62 %
Fidelity VIP Freedom 2010 Portfolio25 17.02to17.63420 1.07 %1.15 %to1.60 %10.44 %to10.95 %
Fidelity VIP Freedom 2015 Portfolio26 17.76to18.62456 1.05 %1.15 %to1.60 %11.75 %to12.26 %
Fidelity VIP Freedom 2020 Portfolio35 18.20to18.64613 0.98 %1.15 %to1.60 %12.89 %to13.40 %
Fidelity VIP Freedom 2025 Portfolio122 19.47to19.882,274 1.00 %1.15 %to1.60 %13.83 %to14.35 %
Fidelity VIP Freedom 2030 Portfolio18 18.78to20.12353 1.04 %1.15 %to1.55 %14.84 %to15.30 %
Fidelity VIP Growth Portfolio129 36.00to44.895,173 0.04 %1.00 %to1.60 %41.25 %to42.11 %
Fidelity VIP High Income Portfolio331 17.12to27.056,779 6.88 %1.00 %to1.60 %0.78 %to1.40 %
Fidelity VIP Index 500 Portfolio1223 37.55to35.1932,420 1.56 %1.00 %to1.67 %15.98 %to16.77 %
Fidelity VIP International Index Portfolio 5 11.55to11.6257 3.86 %1.15 %to1.55 %8.63 %to9.07 %
Fidelity VIP Investment Grade Bond Portfolio1019 14.53to20.1415,439 2.05 %1.00 %to1.60 %7.42 %to8.07 %
Fidelity VIP Mid Cap Portfolio287 22.90to53.308,708 0.40 %1.00 %to1.60 %15.98 %to16.69 %
Fidelity VIP Overseas Portfolio166 13.39to25.092,617 0.22 %1.00 %to1.60 %13.49 %to14.18 %
Fidelity VIP Target Volatility Portfolio35 14.29to14.71499 1.29 %1.15 %to1.55 %7.30 %to7.74 %
Fidelity VIP Total Market Index Portfolio6 12.72to12.7982 2.17 %1.15 %to1.55 %18.12 %to18.60 %
Non-Affiliated Class 1:
Columbia VP – Select Mid Cap Value Fund71 19.89to20.781,442 — %1.15 %to1.60 %5.76 %to6.25 %
Franklin Growth and Income VIP Fund50 32.06to32.061,600 3.89 %1.35 %to1.35 %4.38 %to4.38 %
Franklin Income VIP Fund91 28.58to29.232,599 5.97 %1.10 %to1.35 %(0.39)%to(0.14)%
JP Morgan IT Mid Cap Value15 36.40to38.85548 1.49 %1.00 %to1.55 %(1.19)%to(0.63)%
Morgan Stanley VIF Emerging Markets Debt Portfolio3 28.78to36.55104 4.47 %1.10 %to1.45 %4.01 %to4.38 %
Morgan Stanley VIF U.S. Real Estate Portfolio14 29.76to33.15480 2.69 %1.00 %to1.55 %(18.14)%to(17.68)%
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund161 13.71to14.262,215 1.50 %1.00 %to1.55 %4.24 %to4.82 %
Columbia VP – Small Cap Value Fund59 29.09to30.681,738 0.34 %1.15 %to1.60 %6.85 %to7.34 %
Franklin Growth and Income VIP Fund184 21.45to32.654,444 3.78 %1.00 %to1.60 %3.83 %to4.47 %
Franklin Income VIP Fund728 16.22to29.1012,556 5.88 %1.00 %to1.60 %(0.92)%to(0.31)%
Franklin Large Cap Growth VIP Fund147 33.81to50.296,183 — %1.00 %to1.60 %42.32 %to43.19 %
Franklin Mutual Shares VIP Fund607 15.07to27.179,423 2.92 %1.00 %to1.60 %(6.56)%to(5.99)%
Franklin Small Cap Value VIP Fund54 22.66to24.241,076 1.51 %1.15 %to1.60 %3.51 %to3.98 %
(a) Name Change. See Note 1.
29
(b) New Underlying Fund. See Note 1
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2020UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Non-Affiliated Class 2 (continued):
Invesco V.I. American Franchise Fund11 $37.03 to$38.53 $460 — %1.15 %to1.60 %39.73 %to40.36 %
Invesco V.I. American Value Fund355 18.54to20.026,771 0.64 %1.00 %to1.60 %(0.76)%to(0.15)%
Invesco V.I. Comstock Fund183 19.57to33.263,515 2.20 %1.00 %to1.60 %(2.67)%to(2.08)%
Invesco V.I. International Growth Fund142 14.62to15.272,103 2.09 %1.15 %to1.60 %11.92 %to12.43 %
Invesco Oppenheimer V.I. Discovery Mid Cap Growth Series II (b)46 14.81to14.85676 — %1.15 %to1.55 %48.06 %to48.47 %
Templeton Foreign VIP Fund355 10.09to22.104,045 3.44 %1.00 %to1.60 %(2.74)%to(2.15)%
Templeton Global Bond VIP Fund38 8.78to9.06333 8.64 %1.15 %to1.55 %(6.75)%to(6.37)%
Templeton Growth VIP Fund60 13.22to24.431,068 3.06 %1.00 %to1.60 %4.11 %to4.74 %
Morgan Stanley VIF Emerging Markets Debt Portfolio52 15.67to13.54870 4.51 %1.15 %to1.60 %3.84 %to4.32 %
Morgan Stanley VIF Emerging Markets Equity Portfolio118 10.42to45.282,034 1.28 %1.00 %to1.60 %12.53 %to13.22 %
Morgan Stanley VIF U.S. Real Estate Portfolio176 13.72to15.002,130 2.56 %1.15 %to1.60 %(18.43)%to(18.05)%
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund126 32.25to33.714,150 — %1.15 %to1.60 %39.25 %to39.89 %
BlackRock Global Allocation V.I. Fund41 15.19to16.11623 1.26 %1.00 %to1.60 %18.78 %to19.50 %
BlackRock High Yield V.I. Fund18 12.74to12.99230 5.05 %1.15 %to1.55 %5.38 %to5.80 %
BlackRock Total Return V.I. Fund33 11.23to11.33374 1.87 %1.35 %to1.55 %6.87 %to7.09 %
TOPS® Managed Risk Moderate Growth ETF Portfolio95 12.42to12.811,178 2.17 %1.15 %to1.55 %4.26 %to4.68 %
Non-Affiliated Class 4:
American Funds I.S. Bond Fund104 11.27to11.491,176 2.33 %1.15 %to1.55 %7.68 %to8.12 %
American Funds I.S. Capital Income Builder Fund253 11.43to11.802,926 2.75 %1.00 %to1.55 %2.50 %to3.07 %
American Funds I.S. Global Growth Fund132 21.36to22.052,877 0.16 %1.15 %to1.60 %28.08 %to28.67 %
American Funds I.S. Growth Fund134 29.69to30.554,001 0.20 %1.15 %to1.55 %49.36 %to49.97 %
American Funds I.S. Growth-Income Fund193 19.74to20.393,851 1.22 %1.15 %to1.60 %11.44 %to11.95 %
American Funds I.S. New World Fund69 15.15to15.591,062 0.04 %1.15 %to1.55 %21.38 %to21.88 %
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund11 39.52to41.67429 1.14 %1.10 %to1.45 %17.70 %to18.12 %
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund67 21.77to37.881,742 0.91 %1.00 %to1.55 %17.24 %to17.90 %
Advisor Class:
PIMCO VIT All Asset Portfolio92 14.60to13.801,368 4.87 %1.15 %to1.60 %6.18 %to6.67 %
PIMCO VIT International Bond Portfolio (US Dollar Hedged)4 11.38to11.5949 5.88 %1.15 %to1.55 %3.82 %to4.24 %
PIMCO VIT CommodityRealReturn® Strategy Portfolio309 3.95to4.231,237 6.32 %1.00 %to1.60 %(0.39)%to0.22 %
PIMCO VIT Long-Term U.S. Government Portfolio21 13.04to13.50275 1.59 %1.15 %to1.60 %15.40 %to15.93 %
PIMCO VIT Low Duration Portfolio217 11.20to12.142,457 1.07 %1.00 %to1.60 %1.24 %to1.86 %
PIMCO VIT Real Return Portfolio69 13.23to12.09935 1.32 %1.15 %to1.60 %9.82 %to10.32 %
PIMCO VIT Total Return Portfolio1315 14.96to15.9419,908 2.03 %1.00 %to1.60 %6.80 %to7.45 %
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund24 6.23to6.71151 3.85 %1.00 %to1.60 %0.96 %to1.57 %
Guggenheim VT Multi-Hedge Strategies Fund34 8.97to9.57313 1.28 %1.00 %to1.60 %5.67 %to6.31 %
Guggenheim VT Long Short Equity Fund6 10.30to10.8259 0.83 %1.00 %to1.60 %3.25 %to3.88 %
ETF Shares:
iShares® Core S&P 500 ETF243 70.26to76.5217,460 1.79 %1.75 %to2.75 %15.10 %to16.28 %
iShares® Core S&P Mid-Cap ETF90 58.24to61.525,332 1.56 %1.75 %to2.75 %10.43 %to11.56 %
iShares® Core S&P Small-Cap ETF47 60.23to63.732,891 1.40 %1.75 %to2.75 %8.19 %to9.30 %
iShares® Core U.S. Aggregate Bond ETF22 26.28to30.35586 2.16 %1.75 %to2.75 %4.52 %to5.60 %
iShares® iBoxx $ High Yield Corporate Bond ETF2 32.24to34.8971 5.07 %1.90 %to2.75 %1.57 %to2.46 %
iShares® 5-10 Year Investment Grade Corporate Bond ETF (a)27 29.21to31.62778 2.85 %1.90 %to2.75 %6.62 %to7.55 %
iShares® International Treasury Bond ETF93 23.65to25.952,235 — %1.75 %to2.75 %7.83 %to8.94 %
iShares® S&P 500 Growth ETF28 84.37to94.472,444 0.97 %1.75 %to2.75 %29.57 %to30.90 %
iShares® S&P 500 Value ETF9 54.30to58.77520 2.63 %1.90 %to2.75 %(1.62)%to(0.76)%
iShares® TIPS Bond ETF3 24.46to26.4778 1.23 %1.90 %to2.75 %7.78 %to8.73 %
Vanguard® Developed Markets Index Fund, ETF Shares65 38.40to37.262,539 2.32 %1.75 %to2.75 %6.67 %to7.77 %
(a) Name Change. See Note 1.
30
(b) New Underlying Fund. See Note 1
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2020UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
ETF Shares (continued):
Vanguard® Dividend Appreciation Index Fund, ETF Shares16 $61.24 to$66.27 $1,017 1.81 %1.90 %to2.75 %12.21 %to13.19 %
Vanguard® Emerging Markets Stock Index Fund, ETF Shares8 31.12to33.68247 2.27 %1.90 %to2.75 %12.02 %to13.00 %
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares2 31.67to36.7268 2.68 %1.75 %to2.75 %6.45 %to7.55 %
Vanguard® Large-Cap Index Fund, ETF Shares11 71.55to77.43815 1.70 %1.90 %to2.75 %17.66 %to18.69 %
Vanguard® Mega Cap Index Fund, ETF Shares2 73.23to79.98157 1.70 %1.75 %to2.75 %18.19 %to19.40 %
Vanguard® Real Estate Index Fund, ETF Shares6 43.39to46.96261 4.16 %1.90 %to2.75 %(7.20)%to(6.39)%
Vanguard® Short-Term Bond Index Fund, ETF Shares1 23.26to25.0823 1.82 %1.90 %to2.75 %1.82 %to2.71 %
Vanguard® Total Bond Market Index Fund, ETF Shares609 26.34to30.5116,393 2.23 %1.75 %to2.75 %4.75 %to5.83 %
(a) Name Change. See Note 1.
31
(b) New Underlying Fund. See Note 1
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2019UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Affiliated:
Touchstone VST Aggressive ETF Fund250 $20.62 to$22.85 $5,628 1.65 %1.00 %to1.67 %20.34 %to21.16%
Touchstone VST Bond Fund (July 12, 2019)209 10.17 to10.20 2,129 1.26 %1.00 %to1.67 %1.67 %to2.00%
Touchstone VST Common Stock Fund (July 12, 2019)1,834 10.78 to10.81 19,789 0.55 %1.00 %to1.67 %7.77 %to8.12%
Touchstone VST Conservative ETF Fund331 15.03 to18.42 5,619 2.47 %1.00 %to1.60 %13.62 %to14.31%
Touchstone VST Moderate ETF Fund376 20.40 to21.04 6,855 2.03 %1.00 %to2.05 %16.53 %to17.77%
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio76 20.72 to33.75 2,023 1.73 %1.35 %to1.35 %22.83 %to22.83%
Fidelity VIP Overseas Portfolio36 11.80 to15.65 1,223 1.68 %1.15 %to1.55 %25.79 %to26.30%
Fidelity VIP Equity-Income Portfolio93 31.28 to31.91 7,810 1.98 %1.10 %to1.35 %25.72 %to26.04%
Fidelity VIP Growth Portfolio29 181.86 to181.86 5,227 0.26 %1.35 %to1.35 %32.50 %to32.50%
Fidelity VIP High Income Portfolio56 31.00 to31.00 1,743 5.31 %1.35 %to1.35 %13.55 %to13.55%
Fidelity VIP Asset Manager Portfolio46 60.68 to60.68 2,777 1.76 %1.35 %to1.35 %16.65 %to16.65%
Fidelity VIP Contrafund® Portfolio178 50.00 to51.00 13,551 0.45 %1.10 %to1.35 %29.80 %to30.13%
Fidelity VIP Index 500 Portfolio101 23.34 to24.11 4,690 1.91 %1.10 %to1.45 %29.45 %to29.91%
Fidelity VIP Investment Grade Bond Portfolio76 14.20 to15.24 1,426 2.65 %1.00 %to1.55 %7.97 %to8.57%
Fidelity VIP Government Money Market344 9.53 to9.98 3,369 2.06 %1.00 %to2.75 %(0.79)%to1.00%
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio12 26.49 to26.49 323 0.16 %1.35 %to1.35 %32.37 %to32.37%
Fidelity VIP Mid Cap Portfolio41 68.96 to72.23 2,892 0.78 %1.10 %to1.35 %21.68 %to21.99%
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio65 19.42 to22.06 1,103 1.72 %1.00 %to1.67 %16.04 %to16.83%
Fidelity VIP Balanced Portfolio498 24.59 to27.98 10,560 1.62 %1.00 %to1.67 %22.04 %to22.88%
Fidelity VIP Bond Index Portfolio (July 12, 2019)8 10.15 to10.15 85 3.77 %1.55 %to1.55 %1.48 %to1.48%
Fidelity VIP Contrafund® Portfolio667 36.51 to40.90 17,646 0.21 %1.00 %to1.67 %29.08 %to29.96%
Fidelity VIP Disciplined Small Cap Portfolio87 17.07 to18.61 1,546 0.81 %1.00 %to1.67 %21.31 %to22.14%
Fidelity VIP Equity-Income Portfolio176 25.48 to26.16 3,356 1.87 %1.00 %to1.67 %24.99 %to25.84%
Fidelity VIP Extended Market Index Portfolio (July 12, 2019)3 10.55 to10.55 37 1.20 %1.55 %to1.55 %5.51 %to5.51%
Fidelity VIP Freedom 2010 Portfolio26 14.94 to15.56 397 1.81 %1.35 %to1.67 %13.82 %to14.19%
Fidelity VIP Freedom 2015 Portfolio26 15.89 to16.59 413 1.70 %1.15 %to1.60 %16.09 %to16.62%
Fidelity VIP Freedom 2020 Portfolio42 16.12 to16.44 653 1.78 %1.15 %to1.60 %17.96 %to18.50%
Fidelity VIP Freedom 2025 Portfolio120 17.11 to17.38 1,969 1.84 %1.15 %to1.60 %19.57 %to20.12%
Fidelity VIP Freedom 2030 Portfolio22 16.32 to19.60 363 1.33 %1.15 %to1.67 %22.04 %to22.69%
Fidelity VIP Growth Portfolio136 34.46 to31.59 3,900 0.05 %1.00 %to1.67 %31.74 %to32.64%
Fidelity VIP High Income Portfolio336 20.77 to26.68 6,807 6.67 %1.00 %to1.67 %12.85 %to13.62%
Fidelity VIP Index 500 Portfolio1,273 32.38 to30.14 29,166 1.73 %1.00 %to1.67 %28.83 %to29.71%
Fidelity VIP International Index Portfolio (July 12, 2019)*-10.65 to10.65 2 12.35 %1.15 %to1.15 %6.52 %to6.52%
Fidelity VIP Investment Grade Bond Portfolio1,065 14.42 to18.64 15,005 2.58 %1.00 %to1.67 %7.58 %to8.31%
Fidelity VIP Mid Cap Portfolio335 39.52 to45.68 8,716 0.70 %1.00 %to1.67 %21.12 %to21.94%
Fidelity VIP Overseas Portfolio196 22.72 to21.97 2,673 1.20 %1.00 %to1.67 %25.37 %to26.23%
Fidelity VIP Target Volatility Portfolio36 13.32 to13.65 486 1.37 %1.15 %to1.55 %16.81 %to17.28%
Non-Affiliated Class 1:
Columbia VP – Select Mid Cap Value Fund (a)80 18.69 to19.56 1,539 — %1.15 %to1.67 %29.43 %to30.11%
Franklin Growth and Income VIP Fund57 30.72 to30.72 1,751 2.50 %1.35 %to1.35 %24.35 %to24.35%
Franklin Income VIP Fund106 28.69 to29.27 3,053 5.59 %1.10 %to1.35 %14.85 %to15.14%
JP Morgan IT Mid Cap Value18 36.84 to39.09 630 1.70 %1.00 %to1.55 %24.80 %to25.49%
Morgan Stanley VIF Emerging Markets Debt Portfolio3 27.81 to35.02 107 5.33 %1.10 %to1.55 %12.48 %to13.00%
Morgan Stanley VIF U.S. Real Estate Portfolio17 36.36 to40.27 714 1.86 %1.00 %to1.55 %17.10 %to17.75%
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund163 13.15 to13.61 2,148 2.35 %1.00 %to1.55 %16.16 %to16.81%
Columbia VP – Small Cap Value Fund65 27.02 to28.58 1,751 0.27 %1.15 %to1.67 %18.97 %to19.59%
Franklin Growth and Income VIP Fund215 26.69 to31.25 4,983 2.23 %1.00 %to1.67 %23.56 %to24.40%
Franklin Income VIP Fund842 23.13 to29.19 14,513 5.40 %1.00 %to1.67 %14.12 %to14.90%
Franklin Large Cap Growth VIP Fund170 28.58 to35.12 5,003 — %1.00 %to1.67 %32.33 %to33.23%
Franklin Mutual Shares VIP Fund593 23.70 to28.91 9,919 1.84 %1.00 %to1.67 %20.53 %to21.35%
Franklin Small Cap Value VIP Fund58 18.42 to23.32 1,104 1.06 %1.15 %to1.67 %24.24 %to24.90%
Invesco V.I. American Franchise Fund12 32.03 to27.45 356 — %1.15 %to1.67 %34.15 %to34.86%
(a) Name Change. See Note 1.
32
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2019UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Non-Affiliated Class 2 (continued):
Invesco V.I. American Value Fund386 $18.52 to$20.05 $7,406 0.44 %1.00 %to1.67 %22.63 %to23.46%
Invesco V.I. Comstock Fund188 27.73 to33.97 3,722 1.74 %1.00 %to1.67 %22.86 %to23.69%
Invesco V.I. International Growth Fund162 13.06 to13.59 2,146 1.33 %1.15 %to1.60 %26.19 %to26.77%
Invesco V.I. Mid Cap Growth Fund20 15.17 to15.40 305 — %1.15 %to1.55 %31.93 %to32.46%
Templeton Foreign VIP Fund366 18.71 to22.58 4,336 1.69 %1.00 %to1.67 %10.65 %to11.40%
Templeton Global Bond VIP Fund62 9.42 to9.68 585 6.16 %1.15 %to1.55 %0.43 %to0.84%
Templeton Growth VIP Fund75 19.23 to23.32 1,234 2.80 %1.00 %to1.67 %13.23 %to14.00%
Morgan Stanley VIF Emerging Markets Debt Portfolio60 22.19 to12.98 953 5.39 %1.15 %to1.67 %12.26 %to12.86%
Morgan Stanley VIF Emerging Markets Equity Portfolio146 31.30 to39.99 2,323 1.01 %1.00 %to1.67 %17.52 %to18.32%
Morgan Stanley VIF U.S. Real Estate Portfolio169 32.21 to18.31 2,526 1.61 %1.15 %to1.67 %16.69 %to17.31%
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund134 23.16 to24.09 3,164 — %1.15 %to1.60 %29.45 %to30.04%
BlackRock Global Allocation V.I. Fund47 12.79 to13.48 613 1.22 %1.00 %to1.60 %15.87 %to16.58%
BlackRock High Yield V.I. Fund17 12.09 to12.27 210 5.15 %1.15 %to1.55 %13.08 %to13.54%
BlackRock Total Return V.I. Fund29 10.50 to10.58 303 2.59 %1.35 %to1.55 %7.46 %to7.67%
TOPS® Managed Risk Moderate Growth ETF Portfolio97 11.91 to12.24 1,153 2.12 %1.15 %to1.55 %14.36 %to14.83%
Non-Affiliated Class 4:
American Funds I.S. Bond Fund65 10.47 to10.62 680 2.61 %1.15 %to1.55 %7.39 %to7.83%
American Funds I.S. Capital Income Builder Fund270 11.16 to11.45 3,032 2.77 %1.00 %to1.55 %15.80 %to16.44%
American Funds I.S. Global Growth Fund133 16.67 to17.14 2,255 0.99 %1.15 %to1.60 %32.72 %to33.33%
American Funds I.S. Growth Fund128 19.82 to20.37 2,567 0.61 %1.15 %to1.60 %28.35 %to28.94%
American Funds I.S. Growth-Income Fund169 17.72 to18.21 3,013 1.49 %1.15 %to1.60 %23.84 %to24.41%
American Funds I.S. New World Fund74 12.48 to12.79 937 0.81 %1.15 %to1.55 %26.82 %to27.34%
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund12 33.58 to35.28 431 1.08 %1.10 %to1.45 %23.41 %to23.85%
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund75 29.93 to32.13 1,678 0.75 %1.00 %to1.67 %22.79 %to23.62%
Advisor Class:
PIMCO VIT All Asset Portfolio110 13.53 to12.94 1,533 2.79 %1.15 %to1.67 %9.88 %to10.46%
PIMCO VIT International Bond Portfolio (US Dollar Hedged)4 10.96 to11.12 40 1.63 %1.15 %to1.55 %5.25 %to5.68%
PIMCO VIT CommodityRealReturn® Strategy Portfolio318 3.90 to5.46 1,280 4.29 %1.15 %to1.67 %9.49 %to10.07%
PIMCO VIT Long-Term U.S. Government Portfolio17 11.30 to11.65 200 1.97 %1.15 %to1.60 %11.40 %to11.91%
PIMCO VIT Low Duration Portfolio189 11.01 to11.92 2,125 2.66 %1.00 %to1.67 %2.19 %to2.88%
PIMCO VIT Real Return Portfolio74 11.97 to10.96 906 1.54 %1.15 %to1.67 %6.52 %to7.08%
PIMCO VIT Total Return Portfolio1,376 13.71 to14.84 19,494 2.92 %1.00 %to1.67 %6.44 %to7.17%
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund27 6.17 to6.60 168 0.96 %1.00 %to1.60 %6.41 %to7.06%
Guggenheim VT Multi-Hedge Strategies Fund40 8.49 to9.00 345 2.28 %1.00 %to1.60 %3.33 %to3.96%
Guggenheim VT Long Short Equity Fund7 9.97 to10.41 72 0.58 %1.00 %to1.60 %3.85 %to4.48%
ETF Shares:
iShares® Core S&P 500 ETF300 61.04 to65.80 18,622 2.24 %1.75 %to2.75 %27.64 %to28.95%
iShares® Core S&P Mid-Cap ETF101 52.74 to55.15 5,399 1.70 %1.75 %to2.75 %22.63 %to23.89%
iShares® Core S&P Small-Cap ETF51 55.67 to58.31 2,870 1.50 %1.75 %to2.75 %19.44 %to20.67%
iShares® Core U.S. Aggregate Bond ETF23 25.15 to28.74 582 2.74 %1.75 %to2.75 %5.47 %to6.56%
iShares® iBoxx $ High Yield Corporate Bond ETF2 31.74 to34.05 74 5.04 %1.90 %to2.75 %10.96 %to11.93%
iShares® Intermediate-Term Corporate Bond ETF26 27.40 to29.40 716 3.55 %1.90 %to2.75 %11.44 %to12.42%
iShares® International Treasury Bond ETF104 21.93 to23.82 2,326 0.22 %1.75 %to2.75 %0.91 %to1.95%
iShares® S&P 500 Growth ETF35 65.12 to72.17 2,339 1.73 %1.75 %to2.75 %27.17 %to28.47%
iShares® S&P 500 Value ETF9 55.20 to59.22 520 2.31 %1.90 %to2.75 %28.00 %to29.12%
iShares® TIPS Bond ETF6 22.69 to24.35 127 1.83 %1.90 %to2.75 %5.37 %to6.29%
Vanguard® Developed Markets Index Fund, ETF Shares71 36.00 to34.57 2,603 3.14 %1.75 %to2.75 %19.22 %to20.45%
(a) Name Change. See Note 1.
33
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2019UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
ETF Shares (continued):
Vanguard® Dividend Appreciation Index Fund, ETF Shares19 $54.58 to$58.55 $1,049 1.83 %1.90 %to2.75 %26.04 %to27.14%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares8 27.78 to29.81 222 3.24 %1.90 %to2.75 %17.42 %to18.44%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares2 31.92 to34.14 61 3.47 %1.75 %to1.90 %11.92 %to12.09%
Vanguard® Large-Cap Index Fund, ETF Shares12 60.81 to65.24 728 1.98 %1.90 %to2.75 %27.62 %to28.74%
Vanguard® Mega Cap Index Fund, ETF Shares2 61.96 to66.98 140 1.96 %1.75 %to2.75 %27.55 %to28.86%
Vanguard® Real Estate Index Fund, ETF Shares5 46.76 to50.17 244 3.44 %1.90 %to2.75 %25.31 %to26.41%
Vanguard® Short-Term Bond Index Fund, ETF Shares1 22.84 to24.42 15 2.31 %1.90 %to2.75 %2.11 %to3.01%
Vanguard® Total Bond Market Index Fund, ETF Shares686 25.15 to28.83 17,584 2.76 %1.75 %to2.75 %5.84 %to6.93%
(a) Name Change. See Note 1.
34
-*Less than 500.
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2018UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Affiliated:
Touchstone VST Active Bond Fund186 $13.20 to$16.19 $2,460 1.95 %1.00%to1.67%(3.27)%to(2.60)%
Touchstone VST Aggressive ETF Fund283 17.14 to18.86 5,262 1.64 %1.00%to1.67%(9.39)%to(8.77)%
Touchstone VST Conservative ETF Fund405 14.64 to16.11 6,038 1.74 %1.00%to1.67%(5.63)%to(4.99)%
Touchstone VST Focused Fund566 30.76 to34.67 14,555 0.45 %1.00%to1.67%(9.52)%to(8.90)%
Touchstone VST Large Cap Core Equity Fund166 21.94 to21.61 3,186 0.57 %1.00%to1.67%(8.06)%to(7.43)%
Touchstone VST Moderate ETF Fund475 17.51 to17.86 7,336 1.89 %1.00%to2.05%(7.96)%to(6.97)%
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio79 16.87 to27.48 1,716 1.41 %1.35%to1.35%(5.52)%to(5.52)%
Fidelity VIP Overseas Portfolio43 9.38 to12.39 1,081 1.50 %1.15%to1.55%(16.14)%to(15.79)%
Fidelity VIP Equity-Income Portfolio101 24.88 to25.32 6,781 2.12 %1.10%to1.35%(9.54)%to(9.31)%
Fidelity VIP Growth Portfolio32 137.25 to137.25 4,380 0.24 %1.35%to1.35%(1.52)%to(1.52)%
Fidelity VIP High Income Portfolio51 27.30 to27.30 1,394 5.65 %1.35%to1.35%(4.60)%to(4.60)%
Fidelity VIP Asset Manager Portfolio51 52.02 to52.02 2,674 1.65 %1.35%to1.35%(6.63)%to(6.63)%
Fidelity VIP Contrafund® Portfolio201 38.52 to39.19 11,709 0.69 %1.10%to1.35%(7.65)%to(7.41)%
Fidelity VIP Index 500 Portfolio114 18.03 to18.56 4,015 1.80 %1.10%to1.45%(5.88)%to(5.55)%
Fidelity VIP Investment Grade Bond Portfolio85 13.15 to14.04 1,474 2.31 %1.00%to1.55%(2.08)%to(1.53)%
Fidelity VIP Government Money Market1,084 9.61 to9.88 10,536 1.62 %1.00%to2.75%(1.16)%to0.63%
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio16 20.01 to20.01 314 0.14 %1.35%to1.35%(1.63)%to(1.63)%
Fidelity VIP Mid Cap Portfolio46 56.67 to59.21 2,657 0.53 %1.10%to1.35%(15.80)%to(15.58)%
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio57 16.73 to18.88 852 1.47 %1.00%to1.67%(7.20)%to(6.56)%
Fidelity VIP Balanced Portfolio443 20.15 to22.77 7,957 1.34 %1.00%to1.67%(6.04)%to(5.40)%
Fidelity VIP Contrafund® Portfolio766 28.28 to31.47 15,616 0.43 %1.00%to1.67%(8.21)%to(7.58)%
Fidelity VIP Disciplined Small Cap Portfolio84 14.07 to15.24 1,229 0.59 %1.00%to1.67%(14.75)%to(14.17)%
Fidelity VIP Equity-Income Portfolio175 20.39 to20.79 2,746 1.86 %1.00%to1.67%(10.07)%to(9.46)%
Fidelity VIP Freedom 2010 Portfolio33 13.12 to13.63 448 1.36 %1.35%to1.67%(5.87)%to(5.56)%
Fidelity VIP Freedom 2015 Portfolio30 13.69 to14.22 407 1.35 %1.15%to1.60%(6.80)%to(6.38)%
Fidelity VIP Freedom 2020 Portfolio45 13.67 to13.87 590 1.38 %1.15%to1.60%(7.59)%to(7.16)%
Fidelity VIP Freedom 2025 Portfolio112 14.31 to14.13 1,525 1.48 %1.35%to1.60%(8.28)%to(8.04)%
Fidelity VIP Freedom 2030 Portfolio40 13.38 to14.23 544 1.12 %1.15%to1.67%(9.60)%to(9.12)%
Fidelity VIP Growth Portfolio133 26.16 to23.82 2,908 0.04 %1.00%to1.67%(2.10)%to(1.43)%
Fidelity VIP High Income Portfolio49 18.40 to23.48 786 7.35 %1.00%to1.67%(5.24)%to(4.60)%
Fidelity VIP Index 500 Portfolio1,295 25.13 to23.23 23,138 1.56 %1.00%to1.67%(6.33)%to(5.69)%
Fidelity VIP Investment Grade Bond Portfolio1,071 13.40 to17.21 13,976 2.30 %1.00%to1.67%(2.45)%to(1.78)%
Fidelity VIP Mid Cap Portfolio296 32.63 to37.46 6,108 0.39 %1.00%to1.67%(16.20)%to(15.63)%
Fidelity VIP Overseas Portfolio351 18.12 to17.41 3,983 1.31 %1.00%to1.67%(16.48)%to(15.91)%
Fidelity VIP Target Volatility Portfolio37 11.40 to11.64 423 1.57 %1.15%to1.55%(7.46)%to(7.08)%
Non-Affiliated Class 1:
Columbia VP – Mid Cap Value Fund75 14.44 to15.03 1,113 — %1.15%to1.67%(14.75)%to(14.30)%
Franklin Growth and Income VIP Fund64 24.70 to25.14 1,580 2.66 %1.10%to1.35%(5.67)%to(5.43)%
Franklin Income VIP Fund127 24.98 to25.42 3,175 4.95 %1.10%to1.35%(5.39)%to(5.15)%
JP Morgan IT Mid Cap Value22 29.52 to31.15 611 0.99 %1.00%to1.55%(13.21)%to(12.72)%
Morgan Stanley VIF Emerging Markets Debt Portfolio4 24.72 to30.99 119 5.53 %1.10%to1.55%(8.39)%to(7.97)%
Morgan Stanley VIF U.S. Real Estate Portfolio19 31.05 to34.20 681 2.67 %1.00%to1.55%(9.15)%to(8.64)%
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund157 11.32 to11.65 1,781 1.34 %1.00%to1.55%(6.38)%to(5.85)%
Columbia VP –Small Cap Value Fund65 22.71 to23.90 1,492 0.17 %1.15%to1.67%(19.54)%to(19.11)%
Franklin Growth and Income VIP Fund244 21.60 to25.12 4,591 2.49 %1.00%to1.67%(6.18)%to(5.54)%
Franklin Income VIP Fund883 20.27 to25.41 13,324 4.84 %1.00%to1.67%(5.91)%to(5.27)%
Franklin Large Cap Growth VIP Fund191 21.59 to26.36 4,229 — %1.00%to1.67%(3.12)%to(2.46)%
Franklin Mutual Shares VIP Fund626 19.66 to23.82 8,736 2.33 %1.00%to1.67%(10.59)%to(9.98)%
Franklin Small Cap Value VIP Fund59 14.82 to15.76 904 0.88 %1.15%to1.67%(14.34)%to(13.88)%
Invesco V.I. American Franchise Fund10 23.88 to20.35 238 — %1.15%to1.67%(5.50)%to(5.00)%
Invesco V.I. American Value Fund369 15.11 to16.24 5,756 0.21 %1.00%to1.67%(14.33)%to(13.74)%
35
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2018UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Non-Affiliated Class 2 (continued):
Invesco V.I. Comstock Fund186 $22.57 to$27.46 $2,994 1.44 %1.00%to1.67%(13.84)%to(13.25)%
Invesco V.I. International Growth Fund153 10.35 to10.72 1,607 1.80 %1.15%to1.60%(16.57)%to(16.19)%
Invesco V.I. Mid Cap Growth Fund13 11.50 to11.63 146 — %1.15%to1.55%(7.34)%to(6.96)%
Templeton Foreign VIP Fund349 16.91 to20.27 3,781 2.67 %1.00%to1.67%(16.86)%to(16.29)%
Templeton Global Bond VIP Fund63 9.38 to9.59 599 — %1.15%to1.55%0.35%to0.76%
Templeton Growth VIP Fund82 16.98 to20.46 1,200 2.03 %1.00%to1.67%(16.28)%to(15.71)%
Morgan Stanley VIF Emerging Markets Debt Portfolio59 19.77 to11.50 843 5.55 %1.15%to1.67%(8.60)%to(8.12)%
Morgan Stanley VIF Emerging Markets Equity Portfolio145 26.64 to33.80 2,058 0.41 %1.00%to1.67%(18.90)%to(18.34)%
Morgan Stanley VIF U.S. Real Estate Portfolio169 27.60 to11.79 2,218 2.48 %1.00%to1.67%(9.51)%to(8.89)%
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund131 17.89 to18.75 2,370 — %1.00%to1.60%0.49%to1.10%
BlackRock Global Allocation V.I. Fund53 11.04 to11.57 593 0.75 %1.00%to1.60%(9.06)%to(8.51)%
BlackRock High Yield V.I. Fund11 10.69 to10.81 123 5.26 %1.15%to1.55%(4.41)%to(4.02)%
BlackRock Total Return V.I. Fund17 9.78 to9.83 163 2.46 %1.35%to1.55%(2.27)%to(2.27)%
TOPS® Managed Risk Moderate Growth ETF Portfolio100 10.42 to10.66 1,045 1.78 %1.15%to1.55%(8.82)%to(8.45)%
Non-Affiliated Class 4:
American Funds I.S. Bond Fund51 9.75 to9.85 497 2.23 %1.15%to1.55%(2.43)%to(2.03)%
American Funds I.S. Capital Income Builder Fund158 9.63 to9.83 1,537 2.73 %1.00%to1.55%(8.69)%to(8.32)%
American Funds I.S. Global Growth Fund122 12.56 to12.86 1,552 0.53 %1.15%to1.60%(10.70)%to(10.29)%
American Funds I.S. Growth Fund101 15.44 to15.80 1,576 0.28 %1.15%to1.60%(2.10)%to(1.65)%
American Funds I.S. Growth-Income Fund168 14.31 to14.64 2,421 1.36 %1.15%to1.60%(3.58)%to(3.19)%
American Funds I.S. New World Fund66 9.84 to10.04 653 0.75 %1.15%to1.55%(15.59)%to(15.24)%
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund14 27.21 to28.49 385 0.97 %1.10%to1.45%(12.52)%to(12.21)%
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund69 24.37 to25.99 1,296 0.68 %1.00%to1.67%(12.91)%to(12.31)%
Advisor Class:
PIMCO VIT All Asset Portfolio123 12.32 to11.71 1,553 3.09 %1.15%to1.67%(7.03)%to(6.54)%
PIMCO VIT International Bond Portfolio (US Dollar Hedged)2 10.41 to10.53 18 1.31 %1.15%to1.55%0.43%to0.43%
PIMCO VIT CommodityRealReturn® Strategy Portfolio345 3.56 to4.96 1,263 1.97 %1.15%to1.67%(15.64)%to(15.19)%
PIMCO VIT Long-Term U.S. Government Portfolio18 10.14 to10.41 185 2.30 %1.15%to1.60%(4.05)%to(3.61)%
PIMCO VIT Low Duration Portfolio165 10.77 to11.58 1,807 1.81 %1.00%to1.67%(1.45)%to(0.77)%
PIMCO VIT Real Return Portfolio112 11.24 to10.23 1,282 2.37 %1.15%to1.67%(3.95)%to(3.44)%
PIMCO VIT Total Return Portfolio1,476 12.88 to13.84 19,600 2.43 %1.00%to1.67%(2.31)%to(1.64)%
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund39 5.76 to6.17 231 — %1.00%to1.67%(10.55)%to(9.94)%
Guggenheim VT Multi-Hedge Strategies Fund46 8.05 to8.66 385 — %1.00%to1.67%(6.67)%to(6.03)%
Guggenheim VT Long Short Equity Fund8 9.27 to9.97 81 — %1.00%to1.67%(14.40)%to(13.81)%
ETF Shares:
iShares® Core S&P 500 ETF388 47.82 to51.03 18,855 1.85 %1.75%to2.75%(7.11)%to(6.15)%
iShares® Core S&P Mid-Cap ETF122 43.01 to44.51 5,341 1.47 %1.75%to2.75%(13.63)%to(12.73)%
iShares® Core S&P Small-Cap ETF59 46.61 to48.32 2,802 1.32 %1.75%to2.75%(11.02)%to(10.10)%
iShares® Core U.S. Aggregate Bond ETF26 23.84 to26.97 620 2.72 %1.75%to2.75%(2.67)%to(1.66)%
iShares® iBoxx $ High Yield Corporate Bond ETF4 28.60 to30.42 124 5.18 %1.90%to2.75%(4.71)%to(3.87)%
iShares® Intermediate-Term Corporate Bond ETF26 24.59 to26.15 653 3.33 %1.90%to2.75%(3.48)%to(2.63)%
iShares® International Treasury Bond ETF119 21.74 to23.37 2,635 0.30 %1.75%to2.75%(5.29)%to(4.31)%
iShares® S&P 500 Growth ETF41 51.20 to56.17 2,157 1.16 %1.75%to2.75%(2.95)%to(1.95)%
iShares® S&P 500 Value ETF10 43.12 to45.86 448 2.48 %1.90%to2.75%(11.70)%to(10.92)%
iShares® TIPS Bond ETF5 21.54 to22.91 108 2.71 %1.90%to2.75%(4.15)%to(3.31)%
36
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2018UnitNetInvestmentExpenseTotal
 UnitsValueAssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
ETF Shares (continued):
Vanguard® Developed Markets Index Fund, ETF Shares87 $30.20 to$28.70 $2,651 2.85 %1.75%to2.75%(17.11)%to(16.25)%
Vanguard® Dividend Appreciation Index Fund, ETF Shares23 43.30 to46.05 995 1.88 %1.90%to2.75%(4.78)%to(3.94)%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares11 23.66 to21.70 260 2.52 %1.75%to2.75%(17.11)%to(16.25)%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares2 28.52 to30.46 63 3.45 %1.75%to1.90%(3.61)%to(3.46)%
Vanguard® Large-Cap Index Fund, ETF Shares13 47.65 to50.67 606 1.84 %1.90%to2.75%(7.09)%to(6.27)%
Vanguard® Mega Cap Index Fund, ETF Shares2 48.58 to51.98 123 1.93 %1.75%to2.75%(6.12)%to(5.15)%
Vanguard® Real Estate Index Fund, ETF Shares7 37.32 to39.69 252 4.38 %1.90%to2.75%(8.62)%to(7.82)%
Vanguard® Short-Term Bond Index Fund, ETF Shares1 22.37 to23.71 18 1.94 %1.90%to2.75%(1.45)%to(0.59)%
Vanguard® Total Bond Market Index Fund, ETF Shares821 23.76 to26.96 19,849 2.78 %1.75%to2.75%(2.87)%to(1.87)%
37
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2017UnitInvestmentExpenseTotal
 UnitsValue Net AssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Affiliated:
Touchstone VST Active Bond Fund242  $13.64 to $16.63 $3,363 2.37 %1.00% to 1.67%1.81% to 2.51%
Touchstone VST Aggressive ETF Fund325  22.46 to 20.686,610 1.68 % 1.00% to 2.15%14.78% to 16.13%
Touchstone VST Conservative ETF Fund454  14.98 to 16.967,158 2.04 % 1.00% to 2.15%7.70% to 8.96%
Touchstone VST Focused Fund640  34.00 to 38.0618,136 0.51 %1.00% to 1.67%11.75% to 12.51%
Touchstone VST Large Cap Core Equity Fund187  23.86 to 23.353,905 0.67 %1.00% to 1.67%19.30% to 20.11%
Touchstone VST Moderate ETF Fund522  18.85 to 19.208,797 1.94 % 1.00% to 2.15%11.22% to 12.52%
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio90  17.86 to 29.08 2,068 1.42 %1.35 %14.86 %
Fidelity VIP Overseas Portfolio50  11.19 to 11.871,438 1.40 % 1.00% to 1.55%28.27% to 28.99%
Fidelity VIP Equity-Income Portfolio138  27.50 to 27.9210,060 1.68 % 1.10% to 1.35%11.38% to 11.66%
Fidelity VIP Growth Portfolio36 139.37 4,980 0.22 %1.35 %33.32 %
Fidelity VIP High Income Portfolio56 28.61 1,604 4.56 %1.35 %5.50 %
Fidelity VIP Asset Manager Portfolio59 55.72 3,277 1.86 %1.35 %12.57 %
Fidelity VIP Contrafund® Portfolio224  41.71 to 42.33 13,970 0.98 % 1.10% to 1.35%20.24% to 20.54%
Fidelity VIP Index 500 Portfolio129  19.15 to 19.654,803 1.77 % 1.10% to 1.45%19.96% to 20.38%
Fidelity VIP Investment Grade Bond Portfolio103  13.43 to 14.262,012 2.31 % 1.00% to 1.55%2.61% to 3.18%
Fidelity VIP Government Money Market1,139  9.72 to 9.8211,055 0.67 % 1.00% to 2.75%(2.08)% to (0.33)%
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio18 20.34 359 0.13 %1.35 %33.19 %
Fidelity VIP Mid Cap Portfolio53  67.30 to 70.143,587 0.61 % 1.10% to 1.35%19.08% to 19.38%
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio63  18.03 to 20.201,005 1.55 %1.00% to 1.67%11.85% to 12.61%
Fidelity VIP Balanced Portfolio410  21.45 to 24.087,973 1.30 %1.00% to 1.67%14.18% to 14.96%
Fidelity VIP Contrafund® Portfolio848  30.81 to 34.0518,909 0.77 %1.00% to 1.67%19.56% to 20.38%
Fidelity VIP Disciplined Small Cap Portfolio118  16.51 to 17.752,011 0.55 %1.00% to 1.67%5.01% to 5.73%
Fidelity VIP Equity-Income Portfolio288  22.67 to 22.965,449 1.43 %1.00% to 1.67%10.78% to 11.53%
Fidelity VIP Freedom 2010 Portfolio37  13.94 to 14.43528 0.98 % 1.35% to 1.67%10.92% to 11.28%
Fidelity VIP Freedom 2015 Portfolio32  14.17 to 15.19 456 1.04 % 1.15% to 1.67%12.89% to 13.48%
Fidelity VIP Freedom 2020 Portfolio44  14.79 to 14.94 620 1.26 % 1.15% to 1.60%14.41% to 14.93%
Fidelity VIP Freedom 2025 Portfolio46  15.60 to 15.37 686 1.24 % 1.35% to 1.60%15.69% to 15.99%
Fidelity VIP Freedom 2030 Portfolio43  14.80 to 15.65 634 0.67 % 1.15% to 1.67%18.69% to 19.31%
Fidelity VIP Growth Portfolio183  26.72 to 24.16 4,162 0.09 %1.00% to 1.67%32.57% to 33.47%
Fidelity VIP High Income Portfolio70  19.42 to 24.61 1,264 1.48 %1.00% to 1.67%5.13% to 5.85%
Fidelity VIP Index 500 Portfolio1,347  26.83 to 24.64 25,759 1.61 %1.00% to 1.67%19.39% to 20.20%
Fidelity VIP Investment Grade Bond Portfolio1,061  13.74 to 17.52 14,157 2.27 %1.00% to 1.67%2.26% to 2.96%
Fidelity VIP Mid Cap Portfolio348  38.94 to 44.408,978 0.50 %1.00% to 1.67%18.53% to 19.34%
Fidelity VIP Overseas Portfolio375  21.69 to 20.705,131 1.27 %1.00% to 1.67%27.83% to 28.69%
Fidelity VIP Target Volatility Portfolio36  12.32 to 12.53440 1.14 % 1.15% to 1.55%14.50% to 14.96%
Non-Affiliated Class 1:
Columbia VP – Mid Cap Value Fund77  16.94 to 17.541,330 — % 1.15% to 1.67%11.65% to 12.24%
Franklin Growth and Income VIP Fund71  26.19 to 26.581,847 5.98 % 1.10% to 1.35%14.59% to 14.87%
Franklin Income VIP Fund142  26.41 to 26.80 3,757 4.30 % 1.10% to 1.35%8.46% to 8.74%
JP Morgan IT Mid Cap Value27  34.01 to 35.69856 0.79 % 1.00% to 1.55%12.01% to 12.63%
Morgan Stanley VIF Emerging Markets Debt Portfolio4  26.98 to 33.67140 5.48 % 1.10% to 1.55%8.02% to 8.51%
Morgan Stanley VIF U.S. Real Estate Portfolio23  34.18 to 37.43917 1.58 % 1.00% to 1.55%1.52% to 2.08%
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund164  12.07 to 12.371,988 0.78 % 1.00% to 1.60%12.97% to 13.66%
Columbia VP –Small Cap Value Fund59  28.23 to 29.551,684 0.32 % 1.15% to 1.67%12.09% to 12.68%
Franklin Growth and Income VIP Fund289  23.03 to 26.59 5,848 5.81 %1.00% to 1.67%13.93% to 14.70%
Franklin Income VIP Fund901  21.54 to 26.8214,667 4.12 %1.00% to 1.67%7.85% to 8.58%
Franklin Large Cap Growth VIP Fund110  22.29 to 27.022,309 0.62 %1.00% to 1.67%25.98% to 26.83%
Franklin Mutual Shares VIP Fund660  21.99 to 26.4610,475 2.25 %1.00% to 1.67%6.54% to 7.27%
Franklin Small Cap Value VIP Fund67  17.30 to 18.311,209 0.51 % 1.15% to 1.67%8.81% to 9.38%
Invesco V.I. American Franchise Fund10  25.27 to 21.42251 — % 1.15% to 1.67%24.91% to 25.57%
Invesco V.I. American Value Fund120  17.63 to 18.83 2,169 0.60 %1.00% to 1.67%7.86% to 8.59%
Invesco V.I. Comstock Fund187  26.20 to 31.663,500 1.99 %1.00% to 1.67%15.62% to 16.40%
38
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2017UnitInvestmentExpenseTotal
 UnitsValue Net AssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Non-Affiliated Class 2 (continued):
Invesco V.I. International Growth Fund143  $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 Fund5  12.41 to 12.4961 — % 1.15% to 1.55%20.26% to 20.74%
Templeton Foreign VIP Fund331  20.34 to 24.224,473 2.55 %1.00% to 1.67%14.75% to 15.53%
Templeton Global Bond VIP Fund68  9.34 to 9.52645 — % 1.15% to 1.55%0.35% to 0.76%
Templeton Growth VIP Fund105  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 Portfolio56  21.63 to 15.86899 5.60 %1.00% to 1.67%7.76% to 8.49%
Morgan Stanley VIF Emerging Markets Equity Portfolio122  32.84 to 41.392,026 0.66 %1.00% to 1.67%32.82% to 33.72%
Morgan Stanley VIF U.S. Real Estate Portfolio179  30.50 to 12.942,635 1.29 %1.00% to 1.67%1.16% to 1.84%
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund123  17.80 to 18.542,215 — %1.00% to 1.60%30.83% to 31.62%
BlackRock Global Allocation V.I. Fund67  12.14 to 12.64817 1.29 %1.00% to 1.60%11.90% to 12.58%
BlackRock High Yield V.I. Fund5  11.19 to 11.2653 4.90 % 1.15% to 1.55%5.41% to 5.84%
BlackRock Total Return V.I. Fund20  10.00 to 10.02198 2.22 % 1.45% to 1.55%1.61% to 1.71%
TOPS® Managed Risk Moderate Growth ETF Portfolio82  11.43 to 11.64935 1.58 % 1.15% to 1.55%12.08% to 12.53%
Non-Affiliated Class 4:
American Funds I.S. Bond Fund51  9.99 to 10.06510 2.35 % 1.15% to 1.55%1.70% to 2.11%
American Funds I.S. Capital Income Builder Fund146  10.55 to 10.671,551 2.62 % 1.15% to 1.55%10.91% to 11.36%
American Funds I.S. Global Growth Fund102  14.07 to 14.331,460 0.63 % 1.15% to 1.60%29.03% to 29.61%
American Funds I.S. Growth Fund80  15.77 to 16.061,272 0.48 % 1.15% to 1.60%25.95% to 26.52%
American Funds I.S. Growth-Income Fund134  14.88 to 15.122,006 1.40 % 1.15% to 1.55%20.19% to 20.68%
American Funds I.S. New World Fund45  11.66 to 11.85527 0.84 % 1.15% to 1.55%27.07% to 27.58%
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund17  31.10 to 32.45557 0.96 % 1.10% to 1.45%12.68% to 13.08%
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund67  27.99 to 29.641,463 0.71 %1.00% to 1.67%12.14% to 12.90%
Advisor Class:
PIMCO VIT All Asset Portfolio118  13.25 to 12.531,600 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 Portfolio400  4.22 to 5.851,730 11.07 % 1.15% to 1.67%0.35% to 0.88%
PIMCO VIT Long-Term U.S. Government Portfolio19  10.57 to 10.80207 2.08 % 1.15% to 1.60%7.11% to 7.60%
PIMCO VIT Low Duration Portfolio166  10.93 to 11.671,840 1.25 %1.00% to 1.67%(0.44)% to 0.24%
PIMCO VIT Real Return Portfolio123  11.70 to 10.601,462 2.27 % 1.15% to 1.67%1.83% to 2.36%
PIMCO VIT Total Return Portfolio1,613  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 Fund45  6.44 to 6.85 292 1.42 %1.00% to 1.67%6.90% to 7.63%
Guggenheim VT Multi-Hedge Strategies Fund60  8.63 to 9.21543 — %1.00% to 1.67%1.95% to 2.64%
Guggenheim VT Long Short Equity Fund9  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 ETF451  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 ETF134  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 ETF67  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 ETF27  24.49 to 27.43 671 2.32 % 1.75% to 2.75%0.71% to 1.74%
iShares® iBoxx $ High Yield Corporate Bond ETF8  30.02 to 32.38 249 5.05 % 1.75% to 2.75%3.17% to 4.23%
iShares® Intermediate-Term Corporate Bond ETF29  25.47 to 26.86751 2.48 % 1.90% to 2.75%0.70% to 1.57%
iShares® International Treasury Bond ETF129  22.95 to 24.422,992 0.20 % 1.75% to 2.75%8.42% to 9.53%
iShares® S&P 500 Growth ETF47  52.76 to 57.292,538 1.43 % 1.75% to 2.75%23.74% to 25.00%
iShares® S&P 500 Value ETF10  48.84 to 51.49480 2.17 % 1.90% to 2.75%12.11% to 13.08%
iShares® TIPS Bond ETF5  22.47 to 23.69124 2.13 % 1.90% to 2.75%0.10% to 0.97%
Vanguard® Developed Markets Index Fund, ETF Shares88  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 Shares31  45.47 to 47.941,420 1.99 % 1.90% to 2.75%18.88% to 19.92%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares14  28.54 to 25.91392 2.41 % 1.75% to 2.75%27.87% to 29.18%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares4  29.79 to 31.55106 3.21 % 1.75% to 2.55%2.63% to 3.47%
Vanguard® Large-Cap Index Fund, ETF Shares15  51.28 to 54.06755 1.89 % 1.90% to 2.75%18.69% to 19.73%
Vanguard® Mega Cap Index Fund, ETF Shares2  51.74 to 54.80129 1.94 % 1.75% to 2.75%19.24% to 20.47%
Vanguard® Real Estate Index Fund, ETF Shares7  40.84 to 43.05 306 4.15 % 1.90% to 2.75%2.01% to 2.90%
39
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2017UnitInvestmentExpenseTotal
 UnitsValue Net AssetsIncomeRatioReturn
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
ETF Shares (continued):
Vanguard® Short-Term Bond Index Fund, ETF Shares3  $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 Shares905  24.46 to 27.4722,485 2.54 % 1.75% to 2.75%0.73% to 1.76%
* - Less than 500.
40
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2016Investment
 Units Unit Value Net AssetsIncomeExpense RatioTotal Return
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Affiliated:
Touchstone VST Active Bond Fund280  $13.40 to $16.22$3,834 1.95 % 1.00% to 1.67%4.21% to 4.92%
Touchstone VST Aggressive ETF Fund383  19.57 to 17.806,731 1.51 % 1.00% to 2.15%5.64% to 6.88%
Touchstone VST Conservative ETF Fund532  13.91 to 15.567,728 1.42 % 1.00% to 2.15%3.31% to 4.53%
Touchstone VST Focused Fund735  30.43 to 33.8318,604 — % 1.00% to 1.67%11.22% to 11.98%
Touchstone VST Large Cap Core Equity Fund209  20.00 to 19.443,650 0.81 % 1.00% to 1.67%7.02% to 7.75%
Touchstone VST Moderate ETF Fund630  16.95 to 17.069,571 1.54 % 1.00% to 2.15%4.56% to 5.78%
Non-Affiliated Initial Class:
Fidelity VIP Balanced Portfolio104  15.55 to 25.322,072 1.29 %1.35 %5.82 %
Fidelity VIP Overseas Portfolio53  8.62 to 9.201,218 1.31 % 1.00% to 1.67%(6.65)% to (6.01)%
Fidelity VIP Equity-Income Portfolio142  24.70 to 25.009,839 2.30 % 1.10% to 1.35%16.43% to 16.72%
Fidelity VIP Growth Portfolio39 104.54 4,048 0.04 %1.35 %(0.56)%
Fidelity VIP High Income Portfolio72 27.12 1,949 5.34 %1.35 %13.06 %
Fidelity VIP Asset Manager Portfolio63 49.50 3,137 1.46 %1.35 %1.68 %
Fidelity VIP Contrafund® Portfolio251  34.69 to 35.1212,933 0.79 % 1.10% to 1.35%6.55% to 6.82%
Fidelity VIP Index 500 Portfolio150  15.97 to 16.334,467 1.36 % 1.10% to 1.45%10.24% to 10.63%
Fidelity VIP Investment Grade Bond Portfolio121  13.09 to 13.822,194 2.21 % 1.00% to 1.55%3.12% to 3.69%
Fidelity VIP Government Money Market823  9.74 to 9.858,041 0.19 % 1.00% to 1.67%(1.47)% to (0.80)%
Non-Affiliated Service Class:
Fidelity VIP Growth Portfolio21 15.27 324 — %1.35 %(0.64)%
Fidelity VIP Mid Cap Portfolio59  56.52 to 58.753,366 0.41 % 1.10% to 1.35%10.60% to 10.88%
Non-Affiliated Service Class 2:
Fidelity VIP Asset Manager Portfolio70  16.12 to 17.941,005 1.28 % 1.00% to 1.67%1.12% to 1.81%
Fidelity VIP Balanced Portfolio363  18.78 to 20.946,178 1.25 % 1.00% to 1.67%5.19% to 5.91%
Fidelity VIP Contrafund® Portfolio966  25.77 to 25.9118,020 0.59 % 0.60% to 1.67%5.93% to 7.08%
Fidelity VIP Disciplined Small Cap Portfolio65  15.72 to 16.791,054 0.62 % 1.00% to 1.67%20.27% to 21.09%
Fidelity VIP Equity-Income Portfolio339  20.47 to 20.585,800 2.17 % 1.00% to 1.67%15.75% to 16.53%
Fidelity VIP Freedom 2010 Portfolio56  12.94 to 13.23711 1.03 % 1.15% to 1.60%3.55% to 4.02%
Fidelity VIP Freedom 2015 Portfolio51  12.55 to 13.39643 1.05 % 1.15% to 1.67%3.82% to 4.36%
Fidelity VIP Freedom 2020 Portfolio46  12.93 to 13.00576 1.47 % 1.15% to 1.60%4.11% to 4.59%
Fidelity VIP Freedom 2025 Portfolio61  13.48 to 13.12784 1.63 % 1.45% to 1.60%4.29% to 4.45%
Fidelity VIP Freedom 2030 Portfolio98  12.47 to 13.121,224 1.24 % 1.15% to 1.67%4.60% to 5.15%
Fidelity VIP Growth Portfolio238  20.15 to 18.104,080 — % 1.00% to 1.67%(1.13)% to (0.45)%
Fidelity VIP High Income Portfolio462  18.47 to 23.258,364 5.85 % 1.00% to 1.67%12.26% to 13.03%
Fidelity VIP Index 500 Portfolio1,373  22.47 to 20.5022,106 1.49 % 1.00% to 1.67%9.72% to 10.47%
Fidelity VIP Investment Grade Bond Portfolio1,002  13.44 to 17.0213,063 2.21 % 1.00% to 1.67%2.73% to 3.43%
Fidelity VIP Mid Cap Portfolio340  32.85 to 37.207,257 0.30 % 1.00% to 1.67%10.06% to 10.80%
Fidelity VIP Overseas Portfolio344  16.97 to 16.093,643 1.24 % 1.00% to 1.67%(6.85)% to (6.21)%
Fidelity VIP Target Volatility Portfolio35  10.76 to 10.90381 1.15 % 1.15% to 1.55%3.43% to 3.85%
Non-Affiliated Class 1:
Columbia VP – Mid Cap Value Fund80  15.17 to 15.761,226 — % 1.00% to 1.67%12.24% to 13.01%
Franklin Growth and Income VIP Fund82  22.86 to 23.141,877 2.83 % 1.10% to 1.35%10.35% to 10.63%
Franklin Income VIP Fund173  24.35 to 24.654,217 5.05 % 1.10% to 1.35%12.79% to 13.08%
JP Morgan IT Mid Cap Value35  30.36 to 31.69980 0.91 % 1.00% to 1.55%12.92% to 13.55%
Morgan Stanley VIF Emerging Markets Debt Portfolio5  24.98 to 31.03140 5.94 % 1.10% to 1.55%8.84% to 9.34%
Morgan Stanley VIF U.S. Real Estate Portfolio30  33.67 to 36.671,170 1.35 % 1.00% to 1.55%5.16% to 5.75%
Non-Affiliated Class 2:
American Funds I.S. Managed Risk Asset Allocation Fund168  10.68 to 10.881,804 1.37 % 1.00% to 1.60%5.56% to 6.20%
Columbia VP – Small Cap Value Fund49  25.19 to 26.231,259 0.39 % 1.15% to 1.67%30.53% to 31.22%
Franklin Growth and Income VIP Fund343  20.21 to 23.186,054 2.59 % 1.00% to 1.67%9.76% to 10.51%
Franklin Income VIP Fund925  19.98 to 24.7014,189 4.95 % 1.00% to 1.67%12.12% to 12.88%
Franklin Large Cap Growth VIP Fund134  17.69 to 21.312,190 — % 1.00% to 1.67%(3.43)% to (2.77)%
Franklin Mutual Shares VIP Fund676  20.64 to 21.1010,106 2.00 % 0.60% to 1.67%14.12% to 15.36%
Franklin Small Cap Value VIP Fund77  15.90 to 19.821,280 0.80 % 1.15% to 1.67%28.02% to 28.69%
Invesco V.I. American Franchise Fund14  20.23 to 17.06284 — % 1.15% to 1.67%0.31% to 0.84%
Invesco V.I. American Value Fund113  16.35 to 17.341,881 0.12 % 1.00% to 1.67%13.30% to 14.07%
41
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2016Investment
 Units Unit Value Net AssetsIncomeExpense RatioTotal Return
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
Non-Affiliated Class 2 (continued):
Invesco V.I. Comstock Fund190  $22.66 to $27.19$3,086 1.34 % 1.00% to 1.67%15.04% to 15.82%
Invesco V.I. International Growth Fund127  10.42 to 10.541,316 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 Fund337  17.73 to 20.964,039 1.94 % 1.00% to 1.67%5.39% to 6.10%
Templeton Global Bond VIP Fund73  9.35 to 9.45683 — % 1.15% to 1.55%1.45% to 1.76%
Templeton Growth VIP Fund135  17.40 to 16.981,979 2.04 % 0.60% to 1.67%7.79% to 8.96%
Morgan Stanley VIF Emerging Markets Debt Portfolio72  20.07 to 14.621,064 5.53 % 1.00% to 1.67%8.74% to 9.48%
Morgan Stanley VIF Emerging Markets Equity Portfolio164  24.73 to 30.962,230 0.45 % 1.00% to 1.67%4.84% to 5.56%
Morgan Stanley VIF U.S. Real Estate Portfolio183  30.15 to 12.702,708 1.06 % 1.00% to 1.67%4.77% to 5.48%
Non-Affiliated Class 3:
BlackRock Capital Appreciation V.I. Fund120  13.61 to 14.091,648 — % 1.00% to 1.60%(1.73)% to (1.13)%
BlackRock Global Allocation V.I. Fund69  10.85 to 11.23757 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 Portfolio83  10.19 to 10.35843 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 9.85199 3.40 % 1.15% to 1.55%(1.79)% to (1.52)%
American Funds I.S. Capital Income Builder Fund83  9.51 to 9.58796 3.20 % 1.15% to 1.55%2.18% to 2.59%
American Funds I.S. Global Growth Fund87  10.90 to 11.06958 0.68 % 1.15% to 1.60%(1.24)% to (0.78)%
American Funds I.S. Growth Fund62  12.54 to 12.52775 1.07 % 1.15% to 1.55%7.53% to 7.47%
American Funds I.S. Growth-Income Fund118  12.38 to 12.531,465 1.32 % 1.15% to 1.55%9.53% to 9.98%
American Funds I.S. New World Fund41  9.17 to 9.29376 0.58 % 1.15% to 1.55%3.42% to 3.84%
Non-Affiliated Class A:
DWS Small Cap Index VIP Fund19  27.60 to 28.70525 1.09 % 1.10% to 1.45%19.27% to 19.70%
Non-Affiliated Class B:
DWS Small Cap Index VIP Fund68  24.96 to 26.251,332 0.82 % 1.00% to 1.67%18.69% to 19.50%
Advisor Class:
PIMCO VIT All Asset Portfolio130  11.88 to 12.601,582 2.43 % 1.00% to 1.67%11.02% to 11.78%
PIMCO VIT CommodityRealReturn® Strategy Portfolio405  4.21 to 5.791,741 1.01 % 1.15% to 1.67%12.96% to 13.55%
PIMCO VIT Long-Term U.S. Government Portfolio18  9.87 to 10.04179 1.88 % 1.15% to 1.67%(1.03)% to (0.58)%
PIMCO VIT Low Duration Portfolio196  10.98 to 11.642,186 1.44 % 1.00% to 1.67%(0.39)% to 0.29%
PIMCO VIT Real Return Portfolio144  11.49 to 12.191,689 2.18 % 1.00% to 1.67%3.34% to 4.04%
PIMCO VIT Total Return Portfolio1,679  12.79 to 13.5622,051 1.98 % 1.00% to 1.67%0.86% to 1.55%
Investor Class:
Guggenheim VT Global Managed Futures Strategy Fund50  6.02 to 6.36306 3.68 % 1.00% to 1.67%(16.19)% to (15.62)%
Guggenheim VT Multi-Hedge Strategies Fund64  8.46 to 8.97560 0.10 % 1.00% to 1.67%(2.14)% to (1.48)%
Guggenheim VT Long Short Equity Fund17  9.59 to 10.17175 — % 1.00% to 1.67%(1.02)% to (0.35)%
ETF Shares:
iShares® Core S&P 500 ETF517  43.47 to 45.4522,723 2.23 % 1.75% to 2.75%9.07% to 10.19%
iShares® Core S&P Mid-Cap ETF149  44.04 to 44.666,627 1.76 % 1.75% to 2.75%17.36% to 18.57%
iShares® Core S&P Small-Cap ETF75  47.59 to 48.343,593 1.41 % 1.75% to 2.75%23.13% to 24.39%
iShares® Core U.S. Aggregate Bond ETF24  24.32 to 26.96586 2.34 % 1.75% to 2.75%(0.40)% to 0.62%
iShares® iBoxx $ High Yield Corporate Bond ETF10  29.09 to 31.06301 5.43 % 1.75% to 2.75%10.29% to 11.42%
iShares® Intermediate-Term Corporate Bond ETF32  25.30 to 26.44821 2.44 % 1.90% to 2.75%0.47% to 1.35%
iShares® International Treasury Bond ETF129  21.17 to 22.302,764 0.66 % 1.75% to 2.75%(1.92)% to (0.91)%
iShares® S&P 500 Growth ETF50  42.64 to 45.832,162 1.58 % 1.75% to 2.75%3.88% to 4.95%
iShares® S&P 500 Value ETF13  43.56 to 45.53582 2.47 % 1.90% to 2.75%14.09% to 15.08%
iShares® TIPS Bond ETF5  22.45 to 23.46109 1.53 % 1.90% to 2.75%1.80% to 2.69%
Vanguard® Developed Markets Index Fund, ETF Shares103  29.63 to 27.593,057 3.10 % 1.75% to 2.75%(0.17)% to 0.85%
Vanguard® Dividend Appreciation Index Fund, ETF Shares              39  38.25 to 41.431,5002.23 % 1.75% to 2.75%8.91% to 10.03%
Vanguard® Emerging Markets Stock Index Fund, ETF Shares18  22.32 to 20.06387 2.55 % 1.75% to 2.75%9.10% to 10.22%
Vanguard® Intermediate-Term Corporate Bond Index Fund, ETF Shares4  27.40 to 30.49118 3.24 % 1.75% to 2.75%2.36% to 3.41%
Vanguard® Large-Cap Index Fund, ETF Shares16  43.20 to 44.88700 2.11 % 1.75% to 2.75%8.70% to 9.81%
Vanguard® Mega Cap Index Fund, ETF Shares3  43.39 to 45.49126 2.27 % 1.75% to 2.75%8.84% to 9.95%
Vanguard® Real Estate Index Fund, ETF Shares9  40.03 to 41.84378 4.86 % 1.90% to 2.75%5.64% to 6.56%
42
Separate Account I
of
National Integrity Life Insurance Company
Notes to Financial Statements (continued)

5. Financial Highlights (continued)
For Year Ended 2016Investment
 Units Unit Value Net AssetsIncomeExpense RatioTotal Return
Subaccount (000s)Range (000s)Ratio (**)Range (***)Range (****)
ETF Share (continued):
Vanguard® Short-Term Bond Index Fund, ETF Shares4  $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 Shares882  24.28 to 27.0021,719 2.41 % 1.75% to 2.75%(0.30)% to 0.73%
43
 









STATUTORY-BASIS FINANCIAL STATEMENTS

National Integrity Life Insurance Company
Years Ended December 31, 2020, 2019 and 2018
With Report of Independent Auditors


National Integrity Life Insurance Company

Statutory-Basis Financial Statements

Years Ended December 31, 2020, 2019 and 2018



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, 2020 and 2019, 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, 2020, 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 of America. 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, 2020 and 2019, or the results of its operations or its cash flows for each of the three years in the period ended December 31, 2020.

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, 2020 and 2019, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2020, on the basis of accounting described in Note 1.


/s/ Ernst & Young LLP

Cincinnati, Ohio
April 13, 2021

2
National Integrity Life Insurance Company
Balance Sheets (Statutory-Basis)


December 31
20202019
Admitted assets(In Thousands)
Cash and invested assets:
Debt securities$2,549,774 $2,495,289 
Preferred and common stocks19,876 19,954 
Mortgage loans198,909 172,483 
Policy loans48,021 50,483 
Cash, cash equivalents and short-term investments24,628 74,495 
Receivable for securities1,546 2,629 
Securities lending reinvested collateral assets52,376 40,713 
Other invested assets109,740 106,235 
Total cash and invested assets3,004,870 2,962,281 
Investment income due and accrued23,252 23,784 
Net deferred income tax asset11,300 9,291 
Other admitted assets1,366 1,676 
Separate account assets1,440,568 1,487,072 
Total admitted assets$4,481,356 $4,484,104 
Liabilities and capital and surplus
Liabilities:
Policy and contract liabilities:
Life and annuity reserves2,469,410 $2,389,263 
Liability for deposit-type contracts128,646 155,431 
Policy and contract claims996 602 
Total policy and contract liabilities
2,599,052 2,545,296 
General expense due and accrued69 24 
Current federal income taxes payable5,276 1,657 
Transfer to (from) separate accounts due and accrued, net(17,954)(18,790)
Asset valuation reserve40,648 41,172 
Interest maintenance reserve10,281 1,319 
Other liabilities7,364 8,502 
Payable for securities lending52,376 40,713 
Separate account liabilities1,440,568 1,487,072 
Total liabilities4,137,680 4,106,965 
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 surplus29,448 62,911 
Total capital and surplus343,676 377,139 
Total liabilities and capital and surplus$4,481,356 $4,484,104 
See accompanying notes.
3
National Integrity Life Insurance Company
Statements of Operations (Statutory-Basis)


Year Ended December 31
202020192018
(In Thousands)
Premiums and other revenues:
Premiums and annuity considerations $179,712 $209,917 $249,174 
Net investment income 114,273 133,567 119,199 
Considerations for supplementary contracts with life contingencies
5,097 7,134 8,332 
Amortization of the interest maintenance reserve 820 (878)(550)
Fees from management of separate accounts6,904 7,057 7,477 
Other revenues 982 1,092 1,183 
Total premiums and other revenues 307,788 357,889 384,815 
Benefits paid or provided:
Death benefits 9,838 4,758 4,569 
Annuity benefits 120,338 122,658 125,848 
Surrender benefits 229,687 340,401 355,911 
Payments on supplementary contracts with life contingencies
9,915 9,787 9,708 
Increase (decrease) in policy reserves and other policyholders’ funds
82,661 (29,009)9,747 
Total benefits paid or provided 452,439 448,595 505,783 
Insurance expenses and other deductions:
Commissions 8,953 11,214 12,227 
General expenses 14,770 16,626 17,836 
Net transfers to (from) separate accounts(144,233)(167,395)(183,274)
Other deductions 685 605 438 
Total insurance expenses and other deductions (119,825)(138,950)(152,773)
    
Gain (loss) from operations before federal income tax expense and net realized capital gains (losses)
(24,826)48,244 31,805 
Federal income tax expense (benefit), excluding tax on capital gains
7,412 10,163 9,148 
Gain (loss) from operations before net realized capital gains (losses)
(32,238)38,081 22,657 
Net realized capital gains (losses) (excluding gains (losses) transferred to IMR and capital gains tax)
(10,122)(2,485)2,746 
Net income (loss) $(42,360)$35,596 $25,403 
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, 2018$2,000 $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, 20192,000 312,228 62,911 377,139 
Net income (loss) — — (42,360)(42,360)
Change in net deferred income tax — — 14,684 14,684 
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of $630)— — 2,380 2,380 
Net change in nonadmitted assets and related items
— — (8,680)(8,680)
Change in asset valuation reserve — — 524 524 
Change in surplus in separate accounts— — (11)(11)
Balance, December 31, 2020$2,000 $312,228 $29,448 $343,676 
See accompanying notes.
5
National Integrity Life Insurance Company
Statements of Cash Flow (Statutory-Basis)


Year Ended December 31
202020192018
(In Thousands)
Operating activities
Premiums collected net of reinsurance$184,809 $217,051 $257,506 
Net investment income received118,484 121,153 123,530 
Benefits paid(371,957)(483,269)(499,131)
Net transfers from (to) separate accounts148,424 177,631 169,401 
Commissions and expense paid(24,286)(27,959)(29,901)
Federal income taxes recovered (paid)(6,382)(9,654)(13,507)
Other, net 7,886 8,149 8,659 
Net cash from (for) operations56,978 3,102 16,557 
Investing activities
Proceeds from investments sold, matured or repaid:
Debt securities704,490 500,259 485,704 
Preferred and common stocks1,711 10,222 46,524 
Mortgage loans6,874 2,585 31,437 
Other invested assets6,592 21,530 4,068 
Net gains (losses) on cash, cash equivalents and short-term investments— 19 12 
Miscellaneous proceeds1,083 390 — 
Net proceeds from investments sold, matured or repaid720,750 535,005 567,745 
Cost of investments acquired:
Debt securities(761,430)(395,913)(533,287)
Preferred and common stocks(2,159)(10,162)(2,940)
Mortgage loans(33,301)(38,620)(9,000)
Other invested assets(5,490)(32,851)(6,687)
Miscellaneous applications(11,838)(40,912)(1,979)
Total cost of investments acquired(814,218)(518,458)(553,893)
Net change in policy and other loans2,461 (157)(2,816)
Net cash from (for) investments(91,007)16,390 11,036 
Financing and miscellaneous activities
Net deposits on deposit-type contract funds and other insurance liabilities(26,786)(11,121)(13,052)
Other cash provided (applied)10,948 44,641 (1,140)
Net cash from (for) financing and miscellaneous sources(15,838)33,520 (14,192)
Net change in cash, cash equivalents and short-term investments(49,867)53,012 13,401 
Cash, cash equivalents and short-term investments:
Beginning of year74,495 21,483 8,082 
End of year$24,628 $74,495 $21,483 
See accompanying notes.

6
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018

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, 2020, approximately 93.7% 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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
Restricted Assets
The Company has assets pledged as collateral, or otherwise not exclusively under control of the Company, totaling $173.7 million and $162.8 million as of December 31, 2020 and 2019, 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, 2020 and 2019, the Company owned $9.5 million and $9.5 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, 2020, 2019 and 2018
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.
For policies issued in 2020 or after, life insurance reserves are developed using principle-based policyholder and asset assumptions with margins and floored at formulaic reserves based upon published tables using statutorily specified interest rates and valuation methods.

12
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
Variable annuities are reserved under VM-21 and are based on principle-based policyholder and asset assumptions with margins and floored at cash values and additional prescribed NY Regulation 213 methods and assumptions.
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.
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, 2020, 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 $51.2 million and $15.6 million in the general and separate account, respectively. 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. The Company maintains effective control over all loaned securities and, therefore, continues to report such securities as invested assets in the balance sheets.
13
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020 and 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, 2020 and 2019, total collateral, which approximated $68.4 million and $47.8 million, respectively, was invested in cash equivalents and was included in securities lending reinvested collateral assets on the balance sheet.
At December 31, 2020, the collateral for all securities on loan could be requested to be returned on demand by the borrower. At December 31, 2020 and 2019, the fair value of the total collateral in the general account was $52.4 million and $40.7 million. The fair value of the total collateral in the separate account was $16.0 million and $7.1 million at December 31, 2020 and 2019, respectively, which was all managed by an unaffiliated agent.
The aggregate collateral broken out by maturity date is as follows at December 31, 2020:
Amortized CostFair
Value
(In Thousands)
Open$— $— 
30 days or less68,338 68,338 
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$68,338 $68,338 
At December 31, 2020, 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 $52.4 million and $16.0 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.
14
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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 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 2020, 2019, or 2018.
Risks and Uncertainties
The Company is exposed to risk associated with the ongoing outbreak 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 continues to evolve. 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
15
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
product marketing and sales efforts. The Company has business continuity plans in place to mitigate the risks posed to business operations by disruptive incidents such as these.
Subsequent Events
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 13, 2021.

16
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$3,126 $354 $(95)$3,385 
Debt securities issued by states of the U.S. and political subdivisions of the states
1,678 474 — 2,152 
Non-U.S. government securities
40,532 3,616 — 44,148 
Corporate securities
1,746,505 192,036 (2,529)1,936,012 
Commercial mortgage-backed securities
180,607 6,918 (701)186,824 
Residential mortgage-backed securities
254,887 12,856 (307)267,436 
Asset-backed securities
322,439 13,437 (795)335,081 
Total$2,549,774 $229,691 $(4,427)$2,775,038 
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, 2020 and 2019, the Company held unrated or below-investment-grade corporate debt securities with a book/adjusted carrying value of $225.3 million and $170.1 million, respectively, and an aggregate fair value of $239.4 million and $176.8 million, respectively. As of December 31, 2020 and 2019, such holdings amount to 8.8% and 6.8%, respectively, of the Company’s investment in debt securities and 5.0% and 3.8%, 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, 2020, 2019 and 2018
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, 2020:
Preferred stocks$1,755 $91 $— $1,846 
Common stocks, unaffiliated$18,422 $625 $(926)$18,121 
At December 31, 2019:
Preferred stocks$3,371 $135 $— $3,506 
Common stocks, unaffiliated$16,263 $320 $— $16,583 

18
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$(95)$1,994 $— $— 
Debt securities issued by states of the U.S. and political subdivisions of the states
— — — — 
Non-U.S. government securities
— — — — 
Corporate securities(1,492)26,550 (1,037)9,871 
Commercial mortgage-backed securities(1)
(10)9,100 (691)6,373 
Residential mortgage-backed securities(1)
(262)33,852 (45)350 
Asset-backed securities(1)
(741)45,315 (54)9,946 
Total$(2,600)$116,811 $(1,827)$26,540 
Preferred stocks$— $— $— $— 
Common stocks, unaffiliated$(926)$5,994 $— $— 
(1) Amounts relate to securities subject to SSAP 43R.
19
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
Investments that are impaired at December 31, 2020 and 2019, 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 3.5% and 3.4% of the carrying value of securities considered temporarily impaired at December 31, 2020 and 2019, respectively. At December 31, 2020, there were a total of 58 securities held that are considered temporarily impaired, of which 14 have been impaired for 12 months or longer. 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. The Company recorded other-than-temporary impairments on securities of $10.1 million, $1.3 million, and $1.3 million for the years ended December 31, 2020, 2019 and 2018, respectively.
20
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The following is a list of each loan-backed security held at December 31, 2020, with a recognized other-than-temporary impairment (OTTI) for the year ended December 31, 2020, 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, 2020:
61749W-AK-3$183 $181 $2 $181 $181 6/30/2020
059469-AF-3169 165 4 165 165 9/30/2020
12667G-BD-4474 472 2 472 472 9/30/2020
760985-7P-0118 109 9 109 109 12/31/2020
TotalXXXXXX$17 XXXXXX
The Company had no OTTI on loan-backed securities for the year ended December 31, 2020, 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, 2020, 2019 and 2018
A summary of the cost or amortized cost and fair value of the Company’s debt securities at December 31, 2020, by contractual maturity, is as follows:
Book/Adjusted Carrying ValueFair
Value
(In Thousands)
Years to maturity:
One or less$133,560 $135,507 
After one through five614,009 662,171 
After five through ten681,668 753,823 
After ten362,604 434,196 
Mortgage-backed securities/asset-backed securities757,933 789,341 
Total$2,549,774 $2,775,038 
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 2020, 2019 and 2018 were $312.9 million, $199.4 million, and $124.5 million; gross gains of $12.5 million, $3.6 million, and $0.9 million and gross losses of $1.8 million, $0.9 million, and $1.1 million were realized on these sales in 2020, 2019, and 2018, respectively.
Proceeds from the sales of investments in equity securities during 2020, 2019 and 2018 were $1.7 million, $0.0 million, and $46.2 million; gross gains of $0.1 million, $0.0 million, and $8.9 million and gross losses of $0.0 million, $0.0 million, and $0.0 million were realized on these sales in 2020, 2019 and 2018, 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:
202020192018
(In Thousands)
Realized capital gains (losses)$2,251 $500 $5,987 
Less amount transferred to (from) IMR (net of related taxes (benefits) of $2,600 in 2020, $471 in 2019, and ($137) in 2018)9,783 1,771 (516)
Less federal income tax expense (benefit) of realized capital gains (losses)
2,590 1,214 3,757 
Net realized capital gains (losses)$(10,122)$(2,485)$2,746 
22
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Net investment income was generated from the following for the years ended December 31:
202020192018
(In Thousands)
Debt securities$102,788 $108,033 $107,231 
Equity securities850 1,213 1,987 
Mortgage loans8,125 6,293 6,141 
Policy loans2,644 3,100 3,712 
Cash, cash equivalents and short-term investments185 389 474 
Other invested assets2,151 16,400 1,515 
Other(92)370 351 
Gross investment income116,651 135,798 121,411 
Investment expenses2,378 2,231 2,212 
Net investment income$114,273 $133,567 $119,199 
The Company’s investments in mortgage loans principally involve commercial real estate. At December 31, 2020, 29.0% of such mortgages, or $57.8 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 $24.5 million. During 2020, the respective minimum and maximum lending rates for mortgage loans issued were 3.58% and 4.125%. 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 2020, 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, 2020, 2019 and 2018
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, NAIC 6 industrial and miscellaneous bonds, and initially rated NAIC 6 residential mortgage-backed securities representing senior and subordinated tranches in securitization trusts containing residential mortgage loans, including those 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.
24
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The investment can be sold or transferred with prior consent from the corporation. The NAV for this investment is $14.97. 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.
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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
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, 2020
Assets:
Bonds, industrial & misc.
$1,580 $— $1,580 $— $— 
Residential mortgage-backed securities
61 — 61 — — 
Common stocks, unaffiliated
8,609 6,692 — — 1,917 
Separate account assets*
419,965 383,981 35,984 — — 
Total assets$430,215 $390,673 $37,625 $— $1,917 
* 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, 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.
The Company did not have any significant assets or liabilities measured at fair value on a nonrecurring basis as of December 31, 2020 and 2019.
27
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The carrying amounts and fair values of the Company’s significant financial instruments follow:
December 31, 2020
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds
$2,549,774 $2,775,038 $3,385 $2,770,864 $789 $— 
Common stock, unaffiliated**
18,121 18,121 16,204 — — 1,917 
Preferred stock
1,755 1,846 — 1,846 — — 
Mortgage loans
198,909 211,530 — — 211,530 — 
Cash, cash equivalents and short-term investments
24,628 24,627 24,627 — — — 
Other invested assets, surplus notes
3,098 3,970 — 3,970 — — 
Securities lending reinvested collateral assets
52,376 52,376 52,376 — — — 
Separate account assets
1,440,568 1,539,583 401,066 1,086,628 51,889 — 
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(1,635,950)$(1,781,032)$— $— $(1,781,032)$— 
Securities lending liability(52,376)(52,376)— (52,376)— — 
Separate account liabilities*(990,638)(1,126,592)— — (1,126,592)— 
* 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.
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, 2020, 2019 and 2018
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.
At December 31, 2020 and 2019, the Company had $69.5 million and $65.3 million respectively, invested in various private debt funds managed by Fort Washington.
The Company did not have any amounts receivable from parent, subsidiaries and affiliates as of December 31, 2020 and 2019, respectively. The Company had $1.5 million and $1.7 million payable to parent, subsidiaries and affiliates as of December 31, 2020 and 2019, 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:
202020192018
(In Thousands)
Direct premiums$181,073 $211,024 $250,112 
Assumed premiums:
Affiliates— — — 
Nonaffiliates— — — 
Ceded premiums:
Affiliates— — — 
Nonaffiliates(1,361)(1,107)(938)
Net premiums$179,712 $209,917 $249,174 
29
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The Company’s ceded reinsurance arrangements impacted certain other items in the accompanying financial statements by the following amounts as of and for the years ended December 31:
202020192018
(In Thousands)
Policy and contract claims:
Affiliates$— $— $— 
Nonaffiliates711 906 323 
Policy and contract liabilities:
Affiliates— — — 
Nonaffiliates1,464 1,248 1,036 
Amounts recoverable on reinsurance contracts:
Affiliates— — — 
Nonaffiliates98 19 45 
In 2020, 2019 and 2018, 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, 2020, 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.
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, 2020, 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, 2020, 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 $(5.3) million and $(1.7) million at December 31, 2020 and 2019, respectively. The tax years 2014 through 2019 remain subject to examination by major tax jurisdictions.
30
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The amount of federal income taxes incurred that will be available for recoupment at December 31, 2020; in the event of future capital losses is $3.8 million, $4.4 million, and $6.1 million from 2020, 2019 and 2018, respectively.
The components of the net deferred tax asset (liability) at December 31 are as follows:
12/31/2020
(In Thousands)
(1)(2)(3)
  (Col 1+2)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$39,221 $5,553 $44,774 
(b)Statutory valuation allowance adjustments— — — 
(c)Adjusted gross deferred tax assets (a - b)39,221 5,553 44,774 
(d)Deferred tax assets nonadmitted28,714 — 28,714 
(e)Subtotal net admitted deferred tax assets (c - d)10,507 5,553 16,060 
(f)Deferred tax liabilities4,193 567 4,760 
(g)
Net admitted deferred tax asset/(net deferred tax liability) (e - f)
$6,314 $4,986 $11,300 
12/31/2019
(In Thousands)
(4)(5)(6)
  (Col 4+5)
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 

31
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$13,459 $1,691 $15,150 
(b)Statutory valuation allowance adjustments— — — 
(c)Adjusted gross deferred tax assets (a - b)13,459 1,691 15,150 
(d)Deferred tax assets nonadmitted12,045 — 12,045 
(e)Subtotal net admitted deferred tax assets (c - d)1,414 1,691 3,105 
(f)Deferred tax liabilities1,108 (12)1,096 
(g)
Net admitted deferred tax asset/(net deferred tax liability) (e - f)
$306 $1,703 $2,009 
12/31/2020
(In Thousands)
(1)(2)(3)
  (Col 1+2)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss carrybacks$— $5,553 $5,553 
(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)
5,747 — 5,747 
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date.
5,747 — 5,747 
2. Adjusted gross deferred tax assets allowed per limitation threshold.
 XXX XXX57,852 
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
4,760 — 4,760 
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$10,507 $5,553 $16,060 

32
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
12/31/2019
(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$— $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.XXXXXX48,727 
(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 $12,955 
Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
Admission Calculation Components SSAP No. 101OrdinaryCapitalTotal
(a)Federal income taxes paid in prior years recoverable through loss$— $1,712 $1,712 
(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)
297 — 297 
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date.297 — 297 
2. Adjusted gross deferred tax assets allowed per limitation threshold.XXXXXX9,125 
(c)
Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities
1,117 (21)1,096 
(d)
Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))
$1,414 $1,691 $3,105 



33
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
20202019
(a)Ratio percentage used to determine recovery period and threshold limitation amount822%953%
12/31/2020
(1)(2)
  
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$39,221$5,553
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%12.35%
(c)Net admitted adjusted gross DTAs amount$10,507$5,553
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%34.44%
12/31/2019
(3)(4)
  
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%
Change
(5)(6)
(Col 1-3) (Col 2-4)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$13,459$1,691
(b)
Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%(0.62)%
(c)Net admitted adjusted gross DTAs amount$1,414$1,691
(d)
Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies.
0.00%4.79%
The Company's tax planning strategies do not include the use of reinsurance.


34
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Current income taxes incurred consist of the following major components:
12/31/202012/31/201912/31/2018
(1)Current income tax(In Thousands)
(a)Federal$7,412 $10,163 $9,148 
(b)Foreign— — — 
(c)Subtotal7,412 10,163 9,148 
(d)Federal income tax on net capital gains2,590 1,214 3,757 
(e)Utilization of capital loss carryforwards— — — 
(f)Other— — — 
(g)Federal and foreign income taxes incurred$10,002 $11,377 $12,905 
(1)(2)(3)
  (Col 1-2)
(2)Deferred tax assets:12/31/202012/31/2019Change
(a)Ordinary(In Thousands)
(1) Discounting of unpaid losses$— $— $— 
(2) Unearned premium revenue— — — 
(3) Policyholder reserves34,945 21,258 13,687 
(4) Investments31 404 (373)
(5) Deferred acquisition costs4,242 4,096 146 
(6) Policyholder dividends accrual— — — 
(7) Fixed assets— — — 
(8) Compensation and benefits accrual— — — 
(9) Pension accrual— — — 
(10) Receivables - nonadmitted3 4 (1)
(11) Net operating loss carryforward— — — 
(12) Tax credit carryforward— — — 
(13) Other— — — 
         (99) Subtotal39,221 25,762 13,459 
(b)Statutory valuation allowance adjustment— — — 
(c)Nonadmitted28,714 16,669 12,045 
(d)Admitted ordinary deferred tax assets (2a99 - 2b - 2c)10,507 9,093 1,414 
(e)Capital
(1) Investments5,553 3,862 1,691 
(2) Net capital loss carryforward— — — 
(3) Real estate— — — 
(4) Other— — — 
       (99) Subtotal5,553 3,862 1,691 
(f)Statutory valuation allowance adjustment— — — 
(g)Nonadmitted— — — 
(h)Admitted capital deferred tax assets (2e99- 2f - 2g)5,553 3,862 1,691 
(i)Admitted deferred tax assets (2d + 2h)$16,060 $12,955 $3,105 

35
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
(1)(2)(3)
  (Col 1-2)
12/31/202012/31/2019Change
(3)Deferred tax liabilities:(In Thousands)
(a)Ordinary
(1) Investments$3,771 $2,579 $1,192 
(2) Fixed assets— — — 
(3) Deferred and uncollected premium— — — 
(4) Policyholder reserves422 506 (84)
(5) Other1 — 1 
         (99) Subtotal4,194 3,085 1,109 
(b)Capital
(1) Investments566 579 (13)
(2) Real estate— — — 
(3) Other— — — 
         (99) Subtotal566 579 (13)
(c)Deferred tax liabilities (3a99 + 3b99)$4,760 $3,664 $1,096 
(4)Net deferred tax assets/liabilities (2i - 3c) $11,300 $9,291 $2,009 
Among the more significant book-to-tax adjustments were the following:
12/31/2020Effective
Tax Rate		12/31/2019Effective
Tax Rate		12/31/2018Effective
Tax Rate
(In Thousands)(In Thousands)(In Thousands)
 Provision computed at statutory rate $(6,795)21.00 %$10,236 21.00 %$7,936 21.00 %
 Dividends received deduction (353)1.09 (229)(0.47)(377)(1.00)
 Tax credits (46)0.14 (101)(0.21)(210)(0.56)
 IMR adjustments2,556 (7.90)— — — — 
 Change in federal tax rate
— — — — 660 1.75 
 Other $(44)— %$483 0.99 %5 0.01 
Total statutory income taxes$(4,682)14.47 %$10,389 21.31 %$8,014 21.20 %
 Federal taxes incurred $10,002 (30.91)%$11,377 23.34 %$12,905 34.15 %
 Change in net deferred income taxes (14,684)45.38 (988)(2.03)(4,891)(12.95)
Total statutory income taxes$(4,682)14.47 %$10,389 21.31 %$8,014 21.20 %
At December 31, 2020, the Company had $0.0 million of net operating loss carryforwards, net capital loss carryforwards and tax credit carry forwards; the company had $0.0 million of deferred tax liabilities that are not recognized.

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, 2020 and 2019, 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
36
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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. Based on these limitations, the Company is unable to pay dividends in 2021 without seeking prior regulatory approval due to having a net loss from operations for the year ended December 31, 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, 2020, the Company does not have any material lease agreements for office space or equipment.
At December 31, 2020 the Company has future commitments to provide additional capital contributions of $6.9 million to investments in joint ventures, limited partnerships and limited liability companies.
37
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
9. Life and Annuity Reserves and Deposit-Type Contract Liabilities
At December 31, 2020, 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 market value adjustment$20,701 $990,638 $— $1,011,339 29.1 %
At book value less current surrender charge of 5% or more
676,733 — — 676,733 19.4 
At fair value— — 378,745 378,745 10.9 
Total with adjustment or at fair value
697,434 990,638 378,745 2,066,817 59.4 
Subject to discretionary withdrawal at book value without adjustment (minimal or no charge or adjustment)
811,159 — — 811,159 23.3 
Not subject to discretionary withdrawal
602,665 — — 602,665 17.3 
Total individual annuity reserves (before reinsurance)
2,111,258 990,638 378,745 3,480,641 100.0 %
Reinsurance ceded
— — — — 
Net individual annuity reserves
$2,111,258 $990,638 $378,745 $3,480,641 
Amount subject to greater than a 5% surrender charge that will be subject to minimal or no surrender charge after the statement date
$36,267 $— $— $36,267 
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)
$758 $— $— $758 0.6 %
Not subject to discretionary withdrawal
127,888 — — 127,888 99.4 
Total deposit-type contract liability (before reinsurance)
128,646 — — 128,646 100.0 %
Reinsurance ceded
— — — — 
Total deposit-type contract liability
$128,646 $— $— $128,646 
Interest rate changes may have temporary effects on the sale and profitability of annuity products offered by the Company. Although the rates offered by the Company are adjustable in the long-term, in the short-term they may be subject to contractual and competitive restrictions, which may prevent timely adjustment. The Company’s management constantly monitors interest rates with respect to a spectrum of product durations and sells annuities that permit flexible responses to interest rate changes as part of the
38
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Company’s management of interest spreads. However, adverse changes in investment yields on invested assets will affect the earnings on those products with a guaranteed return.
At December 31, 2020, the Company's general and separate account life insurance account values, cash value, and reserves for policies subject to discretionary withdrawal, not subject to discretionary withdrawal, or with no cash value are summarized as follows:
General AccountSeparate Account - Nonguaranteed
Account ValueCash ValueReserveAccount ValueCash ValueReserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value$— $— $— $— $— $— 
Universal life221,578 235,375 254,181 — — — 
Universal life with secondary guarantees
— — — — — — 
Indexed universal life— — — — — — 
Indexed universal life with secondary guarantees
— — — — — — 
Indexed life— — — — — — 
Other permanent cash value life insurance
— 180 189 — — — 
Variable life— — — — — — 
Variable universal life37,900 37,900 37,900 
Miscellaneous reserves— — — — — — 
Not subject to discretionary withdrawal or no cash values:
Term policies without cash valueXXXXXX— XXXXXX— 
Accidental death benefitsXXXXXX— XXXXXX— 
Disability - active livesXXXXXX— XXXXXX— 
Disability - disabled livesXXXXXX— XXXXXX— 
Miscellaneous reservesXXXXXX105,000 XXXXXX— 
Total life reserves (before reinsurance)221,578 235,555 359,370 37,900 37,900 37,900 
Reinsurance Ceded— — 1,217 — — — 
Net life reserves$221,578 $235,555 $358,153 $37,900 $37,900 $37,900 
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 $95.0 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.
39
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
December 31
20202019
(In Thousands)
Membership stock - Class A (not eligible for redemption)$7,175 $7,188 
Membership stock - Class B— — 
Activity stock2,003 2,323 
Excess stock334 — 
Aggregate total$9,512 $9,511 
Actual or estimated borrowing capacity as determined by the insurer$95,000 $110,000 

Collateral Pledged to FHLB – General Account:
20202019
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
$101,291 $95,578 $44,500 XXX$108,686 $105,184 $70,600 XXX
Maximum during reporting period
$116,589 $111,703 XXX$70,100 $122,216 $121,485 XXX$81,550 

Borrowing from FHLB - General Account:
20202019
At Reporting DateReserves Established at Reporting DateMaximum Amount During PeriodAt Reporting DateReserves Established at Reporting Date
(In Thousands)
Funding agreements$44,500 $44,509 $70,100 $70,600 $70,690 
Debt— XXX— — XXX
Aggregate total$44,500 $44,509 $70,100 $70,600 $70,690 

The Company does not have any prepayment obligations under these FHLB borrowing arrangements.
40
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, $1.2 million, $1.4 million, $1.1 million and $0.9 million in 2020, 2019, 2018, 2017, and 2016, respectively. The Company’s general account paid $0.1 million, $0.0 million, $0.2 million, $0.1 million and $0.1 million towards separate account guarantees in 2020, 2019, 2018, 2017, and 2016, respectively.
41
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Information regarding the separate accounts of the Company as of and for the year ended December 31, 2020, 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$26,043 $867 $8,819 $35,729 
Reserves for separate accounts with assets at:
Fair value$— $— $416,645 $416,645 
Amortized cost989,041 1,597 — 990,638 
Total reserves$989,041 $1,597 $416,645 $1,407,283 
Reserves for separate accounts by withdrawal characteristics:
Subject to discretionary withdrawal:
With fair value adjustment$989,041 $1,597 $— $990,638 
At book value without fair value adjustment and with current surrender charge of 5% or more
— — — — 
At fair value— — 416,645 416,645 
At book value without fair value adjustment and with current surrender charge of less than 5%
— — — — 
Subtotal989,041 1,597 416,645 1,407,283 
Not subject to discretionary withdrawal— — — — 
Total separate accounts reserves$989,041 $1,597 $416,645 $1,407,283 
42
National Integrity Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
A reconciliation of the amounts transferred to and from the separate accounts for the year ended December 31, 2020, is presented below:
2020
(In Thousands)
Transfers as reported in the Summary of Operations of the Separate Accounts Statement:
Transfers to separate accounts$35,729 
Transfers from separate accounts180,122 
Net transfers to (from) separate accounts(144,393)
Reconciling adjustments:
Policy deductions and other expenses78 
Other changes in surplus in separate account statement— 
Other account adjustments82 
Transfers as reported in the Summary of Operations of the Company$(144,233)

43
 









STATUTORY-BASIS FINANCIAL STATEMENTS

The Western and Southern Life Insurance Company
Years Ended December 31, 2020, 2019 and 2018
With Report of Independent Auditors



The Western and Southern Life Insurance Company

Statutory-Basis Financial Statements

Years Ended December 31, 2020, 2019 and 2018



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, 2020 and 2019, 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, 2020, 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 of America. 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, 2020 and 2019, or the results of its operations or its cash flows for each of the three years in the period ended December 31, 2020.

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, 2020 and 2019, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2020, on the basis of accounting described in Note 1.


/s/ Ernst & Young LLP
Cincinnati, Ohio
April 13, 2021
2
The Western and Southern Life Insurance Company
Balance Sheets (Statutory-Basis)


December 31
20202019
Admitted assets(In Thousands)
Cash and invested assets:
Debt securities$2,762,637 $2,831,739 
Preferred and common stocks681,774 918,600 
Investments in common stocks of subsidiaries3,782,745 3,594,940 
Mortgage loans57,917 68,898 
Policy loans152,310 158,711 
Real estate:
Properties held for the production of income2,426 2,888 
Properties occupied by the Company19,870 21,718 
Cash, cash equivalents and short-term investments326,127 77,542 
Receivable for securities551 1,429 
Derivatives 4,401 7,820 
Receivable for collateral on derivatives34,220 41,680 
Securities lending reinvested collateral assets42,791 27,635 
Other invested assets1,863,693 1,778,070 
Total cash and invested assets9,731,462 9,531,670 
Investment income due and accrued38,180 38,569 
Premiums deferred and uncollected49,315 49,759 
Current federal income taxes recoverable32,092 — 
Net deferred income tax asset86,574 94,540 
Receivables from parent, subsidiaries and affiliates29,728 33,220 
Other admitted assets15,419 13,763 
Separate account assets1,197,356 1,141,599 
Total admitted assets$11,180,126 $10,903,120 
Liabilities and capital and surplus
Liabilities:
Policy and contract liabilities:
Life and annuity reserves$2,737,207 $2,717,714 
Accident and health reserves271,342 267,615 
Liability for deposit-type contracts197,565 204,659 
Policy and contract claims55,728 44,662 
Dividends payable to policyholders36,833 40,505 
Premiums received in advance3,918 4,026 
Total policy and contract liabilities3,302,593 3,279,181 
General expense due and accrued25,782 38,151 
Current federal income taxes payable— 9,601 
Transfer to (from) separate accounts due and accrued, net(18)(15)
Asset valuation reserve245,411 324,838 
Interest maintenance reserve64,915 59,151 
Other liabilities379,396 304,372 
Pension liability36,646 23,536 
Liability for postretirement benefits other than pensions161,650 166,887 
Derivatives 41,108 48,246 
Payable for securities lending67,547 79,589 
Separate account liabilities1,197,356 1,141,599 
Total liabilities5,522,386 5,475,136 
Capital and surplus:
Common stock, $1 par value, authorized 2,500 shares,
     issued and outstanding 2,500 shares		2,500 2,500 
Surplus Notes497,604 497,519 
Paid-in surplus417,103 372,103 
Accumulated surplus4,740,533 4,555,862 
Total capital and surplus5,657,740 5,427,984 
Total liabilities and capital and surplus$11,180,126 $10,903,120 
See accompanying notes.
3
The Western and Southern Life Insurance Company
Statements of Operations (Statutory-Basis)


Year Ended December 31
202020192018
(In Thousands)
Premiums and other revenues:
Premiums and annuity considerations$226,232 $231,773 $237,054 
Net investment income332,996 479,104 466,221 
Considerations for supplementary contracts with life contingencies54 9 — 
Amortization of the interest maintenance reserve5,885 5,906 5,728 
Commissions and expenses on reinsurance ceded1,071 1,029 981 
Miscellaneous income adjustment - termination of reinsurance agreement
— — (694,579)
Other revenues— 2,042 153 
Total premiums and other revenues566,238 719,863 15,558 
Benefits paid or provided:
Death benefits154,116 143,563 145,842 
Annuity benefits89,657 50,066 79,245 
Disability and accident and health benefits15,384 15,580 18,298 
Surrender benefits49,337 53,256 64,673 
Payments on supplementary contracts with life contingencies311 350 393 
Other benefits3,450 4,619 5,047 
Increase in policy reserves and other policyholders’ funds29,300 28,128 28,129 
Total benefits paid or provided341,555 295,562 341,627 
Insurance expenses and other deductions:
Commissions18,044 19,811 20,400 
Commissions and expenses on reinsurance assumed— — 878 
General expenses146,416 157,130 134,141 
Net transfers to (from) separate account(89,609)(50,204)(49,514)
Reserve adjustments on reinsurance assumed(87)(103)(43,412)
Miscellaneous expense adjustment - termination of reinsurance agreement
— — (694,579)
Other deductions32,322 60,564 3,973 
Total insurance expenses and other deductions107,086 187,198 (628,113)
Gain (loss) from operations before dividends to policyholders, federal income tax expense, and net realized capital gains (losses)
117,597 237,103 302,044 
Dividends to policyholders47,249 54,964 52,121 
Gain (loss) from operations before federal income tax expense and net realized capital gains (losses)
70,348 182,139 249,923 
Federal income tax expense (benefit), excluding tax on capital gains
(21,345)25,523 39,879 
Gain (loss) from operations before net realized capital gains (losses)
91,693 156,616 210,044 
Net realized capital gains (losses) (excluding gains (losses) transferred to IMR and capital gains tax)
8,870 2,229 205,080 
Net income (loss)$100,563 $158,845 $415,124 
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, 2018$1,000 $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, 20192,500 869,622 4,555,862 5,427,984 
Net income (loss)— — 100,563 100,563 
Change in net deferred income tax— — (26,657)(26,657)
Net change in unrealized gains (losses) on investments (net of deferred tax expense (benefit) of ($24,444))— — (78,402)(78,402)
Change in net unrealized foreign exchange capital gain (loss)
— — 808 808 
Change in surplus notes— 85 — 85 
Net change in nonadmitted assets and related items— — 122,778 122,778 
Change in asset valuation reserve— — 79,427 79,427 
Change in unrecognized post retirement benefit obligation
— — (13,846)(13,846)
Capital contribution
— 45,000 — 45,000 
Balance, December 31, 2020$2,500 $914,707 $4,740,533 $5,657,740 
See accompanying notes.
5
The Western and Southern Life Insurance Company
Statements of Cash Flow (Statutory-Basis)


Year Ended December 31
202020192018
(In Thousands)
Operating activities
Premiums collected net of reinsurance$227,381 $233,959 $239,541 
Net investment income received220,270 314,302 412,553 
Benefits paid(307,163)(268,636)(334,477)
Net transfers from (to) separate accounts89,607 50,214 49,504 
Commissions and expense paid(158,658)(169,848)(89,719)
Dividends paid to policyholders(50,922)(52,655)(52,582)
Federal income taxes recovered (paid)(24,905)(60,149)(32,434)
Other, net1,071 1,071 1,032 
Net cash from (for) operations(3,319)48,258 193,418 
Investing activities
Proceeds from investments sold, matured or repaid:
Debt securities304,543 321,508 2,285,224 
Preferred and common stocks697,505 553,991 1,152,289 
Mortgage loans18,381 1,041 11,323 
Real estate725 1,400 — 
Other invested assets274,324 460,664 337,964 
Net gains (losses) on cash, cash equivalents and short-term investments
24 37 90 
Miscellaneous proceeds8,338 26,770 8,357 
Net proceeds from investments sold, matured or repaid1,303,840 1,365,411 3,795,247 
Cost of investments acquired:
Debt securities(223,910)(309,030)(1,660,008)
Preferred and common stocks(477,124)(710,369)(2,047,721)
Mortgage loans(7,400)(10,793)(21,240)
Real estate(314)(1,121)(678)
Other invested assets(291,864)(517,164)(265,138)
Miscellaneous applications(42,824)(70,541)(15,608)
Total cost of investments acquired(1,043,436)(1,619,018)(4,010,393)
Net change in policy and other loans6,401 2,512 3,483 
Net cash from (for) investments266,805 (251,095)(211,663)
Financing activities
Surplus notes, capital notes— 497,435 — 
Capital and paid in surplus, less treasury stock45,000 — 261,500 
Net deposits on deposit-type contract funds and other insurance liabilities
(7,094)(8,920)(11,020)
Dividends paid to stockholder
— (260,000)— 
Other cash provided (applied)(52,807)(36,049)(375,272)
Net cash from (for) financing and miscellaneous sources(14,901)192,466 (124,792)
Net change in cash, cash equivalents and short-term investments248,585 (10,371)(143,037)
Cash, cash equivalents and short-term investments:
Beginning of year77,542 87,913 230,950 
End of year$326,127 $77,542 $87,913 
Cash flow information for noncash transactions:
Contribution to Columbus Life Insurance Company in the form of common stock$— $(29,962)$— 
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, 2020, 2019 and 2018

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, 2020, approximately 68.7% 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 $1,979.7 million and $1,993.5 million were allocated to the Closed Block as of December 31, 2020 and 2019, 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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
•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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
Restricted Assets
The Company has assets pledged as collateral, or otherwise not exclusively under control of the Company, totaling $132.6 million and $181.0 million as of December 31, 2020 and 2019, 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, 2020, 2019 and 2018
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, 2020, 2019 and 2018
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.
For policies issued in 2020 or after, life insurance reserves are developed using principle-based policyholder and asset assumptions with margins and floored at formulaic reserves based upon published tables using statutorily specified interest rates and valuation methods.

Formulaic 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
20202019
Life insurance:
1941 Commissioners Standard Ordinary, 2-1/4% - 3-1/2%7.0 %7.4 %
1941 Standard Industrial, 2-1/2% - 3-1/2%9.4 9.9 
1958 Commissioners Standard Ordinary, 2-1/2% - 6%18.0 18.9 
1980 Commissioners Standard Ordinary, 4% - 6%40.0 39.8 
2001 Commissioners Standard Ordinary, 3-1/2% - 4-1/2%20.0 18.2 
2017 Commissioners Standard Ordinary, 3-1/2%— — 
Other, 2-1/2% - 6%4.4 4.5 
98.8 98.7 
Other benefits (including annuities):
Various, 2-1/2% - 8-1/4%1.2 1.3 
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.
14
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
As of December 31, 2020 and 2019, reserves of $17.2 million and $20.8 million, respectively, were recorded on in-force amounts of $961.2 million and $1,033.8 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.
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, 2020 and 2019. 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.
15
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Securities Lending
At December 31, 2020, 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 $66.0 million and $24.6 million in the general and separate account, respectively. 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. 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.
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, 2020 and 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 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 $24.6 million and $51.7 million at December 31, 2020 and 2019, 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, 2020 and 2019, collateral managed by an unaffiliated agent, which approximated $42.8 million and $27.7 million respectively, was invested in cash equivalents and was included in securities lending reinvested collateral assets on the balance sheet.
At December 31, 2020, the collateral for all securities on loan could be requested to be returned on demand by the borrower. At December 31, 2020 and 2019, the fair value of the total collateral in the general account was $67.4 million and $79.4 million, respectively. The fair value of the total collateral in the separate account was $25.1 million and $54.2 million at December 31, 2020 and 2019, respectively, which was all managed by an unaffiliated agent.
The aggregate collateral broken out by maturity date is as follows at December 31, 2020:
16
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Amortized CostFair
Value
(In Thousands)
Open$— $— 
30 days or less71,662 71,662 
31 to 60 days100 100 
61 to 90 days799 797 
91 to 120 days1,997 1,996 
121 to 180 days2,902 2,898 
181 to 365 days1,599 1,600 
1 to 2 years6,700 6,706 
2 to 3 years— — 
Greater than 3 years6,776 6,776 
Total collateral$92,535 $92,535 
At December 31, 2020, 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 $67.5 million and $25.1 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.
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.
17
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
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.
18
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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 PeriodBook Value of AcquisitionAdmitted Goodwill as a % of Admitted Acquisition
(In thousands)
2020$1,257,274 $528,082 $487,082 $94,555 $998,917 48.8 %
20191,257,274 528,082 478,525 94,555 990,641 48.3 

20202019
(In Thousands)
Company Surplus as of September 30$5,452,970 $5,350,110 
Less September 30 electronic data processing10,235 5,078 
Less September 30 net deferred tax assets94,783 88,391 
Less September 30 net positive goodwill477,127 471,388 
Adjusted Company surplus as of September 30$4,870,825 $4,785,253 
Admitted goodwill as a percentage of adjusted surplus10.0 %10.0 %

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.
19
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Risks and Uncertainties
The Company is exposed to risk associated with the ongoing outbreak 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 continues to evolve. 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 mitigate the risks posed to business operations by disruptive incidents such as these.
Subsequent Events
On March 22, 2021, the Company contributed $100.0 million in cash to Columbus Life.
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 13, 2021.

20
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
U.S. Treasury securities and obligations of U.S. government corporation and agencies
$21,713 $2,637 $— $24,350 
Debt securities issued by states of the U.S. and political subdivisions of the states
15,997 3,201 — 19,198 
Non-U.S. government securities
57,015 11,581 — 68,596 
Corporate securities
2,354,780 673,092 (2,066)3,025,806 
Commercial mortgage-backed securities
30,201 1,430 (19)31,612 
Residential mortgage-backed securities
169,530 18,859 (38)188,351 
Asset-backed securities
113,401 16,654 (121)129,934 
Total$2,762,637 $727,454 $(2,244)$3,487,847 
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, 2020 and 2019, the Company held unrated or below-investment-grade corporate debt securities with a book/adjusted carrying value of $106.4 million and $57.1 million, respectively, and an aggregate fair value of $119.1 million and $59.4 million, respectively. As of December 31, 2020 and 2019, such holdings amounted to 3.9% and 2.0%, respectively, of the Company’s investments in debt securities and 1.0% and 0.5%, 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.
21
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
Preferred stocks$19,271 $1,914 $(434)$20,751 
Common stocks, unaffiliated$333,714 $182,395 $(7,473)$508,636 
Common stocks, mutual funds141,597 13,381 (726)154,252 
Common stocks, subsidiaries3,043,359 882,226 (142,840)3,782,745 
$3,518,670 $1,078,002 $(151,039)$4,445,633 

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 
22
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
U.S. Treasury securities and obligations of U.S. government corporations and agencies
$— $— $— $— 
Debt securities issued by states of the U.S. and political subdivisions of the states
— — — — 
Non-U.S. government securities
— — — — 
Corporate securities
(1,174)40,620 (892)8,221 
Commercial mortgage-backed securities(1)
(19)3,279 — — 
Residential mortgage-backed securities(1)
(14)821 (24)619 
Asset-backed securities(1)
(33)5,376 (88)23,112 
Total$(1,240)$50,096 $(1,004)$31,952 
Preferred stocks$(434)$1,945 $— $— 
Common stocks, unaffiliated$(7,473)$41,708 $— $— 
Common stocks, mutual funds(726)34,212 — — 
Total$(8,199)$75,920 $— $— 
(1) Amounts relate to securities subject to SSAP 43R.
23
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
Investments that are impaired at December 31, 2020 and 2019, 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 6.4% and 5.5% of the carrying value of securities considered temporarily impaired at December 31, 2020 and 2019, respectively. At December 31, 2020, there were a total of 76 securities held that are considered temporarily impaired, 9 of which have been impaired for 12 months or longer. At December 31, 2019, there were a total of 99 securities held that were considered temporarily impaired, 13 of which had been impaired for 12 months or longer. The Company recorded other-than-temporary impairments on securities of $4.8 million, $17.1 million and $19.1 million for the years ended December 31, 2020, 2019 and 2018, respectively.
The following is a list of each loan-backed security held at December 31, 2020, with a recognized other-than-temporary impairment (OTTI) for the year ended December 31, 2020, where the present value of future cash flows expected to be collected was less than the amortized cost basis of the securities.
24
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
CUSIPBook/Adj Carrying Value Amortized Cost Before Current Period OTTIPresent Value of Future Cash FlowsRecognized Other-
Than- Temporary Impairment		Amortized Cost After Other-Than-Temporary ImpairmentFair
Value		Date of Other-Than-Temporary Impairment
(In Thousands)
For the year ended, December 31, 2020:
466247-ZQ-9$2,889 $2,872 $17 $2,872 $2,873 06/30/2020
Total              XXX        XXX$17            XXX       XXXXXX
The Company had no OTTI on loan-backed securities for the year ended December 31, 2020, 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.
A summary of the cost or amortized cost and fair value of the Company’s debt securities at December 31, 2020, by contractual maturity, is as follows:
Book/Adjusted Carrying ValueFair
Value
(In Thousands)
Years to maturity:
One or less$33,544 $33,966 
After one through five151,946 170,813 
After five through ten555,635 702,669 
After ten1,708,380 2,230,502 
Mortgage-backed securities/asset-backed securities313,132 349,897 
Total$2,762,637 $3,487,847 
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 2020, 2019 and 2018 were $114.5 million, $63.4 million, and $1,385.4 million; gross gains of $2.5 million, $1.5 million, and $25.8 million and gross losses of $0.4 million, $0.3 million, and $6.0 million were realized on these sales in 2020, 2019 and 2018, respectively.
Proceeds from the sales of investments in equity securities during 2020, 2019 and 2018 were $655.6 million, $476.7 million, and $1,092.8 million; gross gains of $154.6 million, $42.2 million, and $230.8 million and gross losses of $84.4 million, $30.2 million, and $38.9 million were realized on these sales in 2020, 2019 and 2018, respectively.
25
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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:
202020192018
(In Thousands)
Realized capital gains (losses)$25,075 $6,135 $282,807 
Less amount transferred to IMR (net of related taxes (benefits) of $3,097 in 2020, $1,658 in 2019, and $3,425 in 2018)11,649 6,009 12,886 
Less federal income tax expense (benefit) of realized capital gains (losses)
4,556 (2,103)64,841 
Net realized capital gains (losses)$8,870 $2,229 $205,080 
Net investment income was generated from the following for the years ended December 31:
202020192018
(In Thousands)
Debt securities$144,132 $148,923 $182,497 
Equity securities24,798 30,807 44,065 
Mortgage loans6,281 2,716 1,963 
Real estate10,514 13,175 13,071 
Policy loans11,546 11,827 11,965 
Cash, cash equivalents and short-term investments357 2,148 4,967 
Other invested assets181,415 318,696 229,089 
Other605 1,106 1,361 
Gross investment income379,648 529,398 488,978 
Investment expenses46,652 50,294 22,757 
Net investment income$332,996 $479,104 $466,221 
The Company’s investments in mortgage loans principally involve commercial real estate. At December 31, 2020, 78.2% of such mortgages, or $45.3 million, involved properties located in Ohio, 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 2020, the respective minimum and maximum lending rates for mortgage loans issued were 3.70% and 3.70%. 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 2020, the Company did not reduce interest rates on any outstanding mortgages.
26
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Derivative Instruments
The Company entered into an equity hedge program designed to hedge the market value risks associated with the broad equity market. 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 $(0.7) million, $(49.8) million, and $0.0 million for the years ended December 31, 2020, 2019, and 2018, respectively. The net gain/(loss) recognized through net income within realized gains and losses was $(58.8) million,$0.0 million, and $81.3 million for the years ended December 31, 2020, 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, 2020 and 2019, $34.2 million and $41.7 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:

20202019
(In Thousands)
Derivative assets:
Gross amount of recognized assets$4,401 $7,820 
Gross amounts offset— — 
Net amount of assets$4,401 $7,820 
Derivative liabilities:
Gross amount of recognized liabilities$(41,108)$(48,246)
Gross amounts offset— — 
Net amount of liabilities$(41,108)$(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
27
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
•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 $18.8 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 $12.07. The Company does not intend to sell any investments utilizing NAV.
28
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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. 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.
29
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
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.
30
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020
Assets:
Bonds, industrial and misc.$641 $— $641 $— $— 
Bonds, exchange traded funds6,288 6,288 — — — 
Common stocks, unaffiliated508,636 505,760 — — 2,876 
Common stocks, mutual funds154,252 154,252 — — — 
Preferred stocks511 — 365 146 — 
Derivative assets4,401 — 4,401 — — 
Separate account assets1,197,356 754,464 140,685 21,296 280,911 
Total assets$1,872,085 $1,420,764 $146,092 $21,442 $283,787 
Liabilities:
Derivative liabilities$(41,108)$— $(41,108)$— $— 

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:
$(48,246)$— $(48,246)$— 

31
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020 are as follows:
Beginning Asset/(Liability) as of January 1, 2020Total 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,
2020
Net IncomeSurplusOther
(In Thousands)
Assets:
Preferred stocks
$— $— $(8)$— $8 $146 $— $146 
Separate account assets
19,844 — — 1,452 — — — 21,296 
Total assets$19,844 $— $(8)$1,452 $8 $146 $— $21,442 
* 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, 2020, are as follows:
PurchasesIssuancesSalesSettlementsNet Purchases, Issuances, Sales and Settlements
(In Thousands)
Assets:
Preferred stocks$8 $— $— $— $8 
Separate account assets— — — — — 
Total assets$8 $— $— $— $8 
32
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, is 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)$19,844 
* Gains and losses for assets held in separate accounts do not impact net income or surplus as the change in value of assets held in separate accounts is offset by a change in value of liabilities related to separate accounts.
** Transfers into Level 3 are due to changes in the price source
*** Transfers out of Level 3 are due to utilizing net asset value.
The gross purchases, issuances, sales and settlements included in the reconciliation for all assets and liabilities measured at fair value on a recurring basis using significant unobservable inputs (Level 3) for the year ended December 31, 2019, are as follows:
PurchasesIssuancesSalesSettlementsNet Purchases, Issuances, Sales and Settlements
(In Thousands)
Assets:
Preferred stocks$— $—$—$— $— 
Separate account assets— ——(604)(604)
Total Assets$— $—$—$(604)$(604)

The Company did not have any significant assets or liabilities measured at fair value on a nonrecurring basis as of December 31, 2020 and 2019.
33
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The carrying amounts and fair values of the Company’s significant financial instruments follow:
December 31, 2020
Carrying AmountFair ValueLevel 1Level 2Level 3NAV
(In Thousands)
Assets:
Bonds$2,762,637 $3,487,847 $24,822 $3,461,840 $1,185 $— 
Common stock:
Unaffiliated508,636 508,636 505,760 — — 2,876 
Mutual funds154,252 154,252 154,252 — — — 
Preferred stock18,886 20,751 — 19,593 1,158 — 
Mortgage loans57,917 60,387 — — 60,387 — 
Cash, cash equivalents and short-term investments
326,127 326,077 326,077 — — — 
Other invested assets, surplus notes
33,914 47,116 — 47,116 — — 
Securities lending reinvested collateral assets
42,791 42,791 42,791 — — — 
Derivative assets4,401 4,401 — 4,401 — — 
Cash collateral receivable34,220 34,220 — 34,220 — — 
Separate account assets1,197,356 1,197,356 754,464 140,685 21,296 280,911 
Liabilities:
Life and annuity reserves for investment-type contracts and deposit fund liabilities
$(3,729)$(4,065)$— $— $(4,065)$— 
Derivative liabilities(41,108)(41,108)— (41,108)— — 
Securities lending liability(67,547)(67,547)— (67,547)— — 
34
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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 loans69,898 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)— — 

35
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020, are $1.3 billion and $1.2 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:

20202019
(In Thousands)
Integrity:
Admitted Assets$9,814,722 $9,914,360 
Liabilities8,512,424 8,643,016 
Statutory Surplus$1,302,298 $1,271,344 
Net Income$86,341 $13,125 
WSLAC:
Admitted Assets$17,043,484 $14,808,181 
Liabilities15,846,683 13,739,451 
Statutory Surplus$1,196,801 $1,068,730 
Net Income$82,260 $81,627 
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 $14.9 million, $23.8 million, and $16.5 million in 2020, 2019 and 2018, respectively. The principal balance of the mortgage financing arrangements with subsidiaries was $297.7 million and $303.1 million at December 31, 2020 and 2019, respectively.
At December 31, 2020 and 2019, the Company had $103.9 million and $131.9 million, respectively, invested, in the Touchstone Funds, which are mutual funds administered by Touchstone Advisors, Inc., an indirect subsidiary of the Company.
36
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
At December 31, 2020 and 2019, the Company had $560.2 million and $509.4 million respectively, invested in various private equity and private debt funds managed by Fort Washington Investment Advisors, Inc., an indirect subsidiary of the Company.
At December 31, 2020 and 2019, the Company had $888.6 million and $897.6 million respectively, invested in WS Real Estate Holdings, LLC, which is a holding company managed by Eagle Realty Group, LLC, an indirect subsidiary of the Company.
In September 2020, the Company entered into a Pension Risk Transfer agreement with its subsidiary, WSLAC. Refer to Note 10 for more detail.
In December 2020, the Company paid a $50.0 million capital contribution to its subsidiary, Columbus Life. The contribution was in the form of cash.
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.
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.
37
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The Company had $29.7 million and $33.2 million receivable from parent, subsidiaries and affiliates as of December 31, 2020 and 2019, respectively. The Company did not have any amounts payable to parent, subsidiaries and affiliates as of December 31, 2020 or 2019. 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.

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 $478.1 million and $493.5 million at December 31, 2020 and 2019, 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 $0.8 million and $0.9 million at December 31, 2020 and 2019, 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).
38
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The effects of reinsurance on premiums, annuity considerations and deposit-type funds are as follows for the years ended December 31:
202020192018
(In Thousands)
Direct premiums$231,552 $237,084 $241,297 
Assumed premiums:
Affiliates1,285 1,111 2,176 
Nonaffiliates— — — 
Ceded premiums:
Affiliates— — — 
Nonaffiliates(6,605)(6,422)(6,419)
Net premiums$226,232 $231,773 $237,054 
The Company’s ceded reinsurance arrangements impacted certain other items in the accompanying financial statements by the following amounts as of and for the years ended December 31:
202020192018
(In Thousands)
Policy and contract claims:
Affiliates$— $— $— 
Nonaffiliates4,856 2,936 4,225 
Policy and contract liabilities:
Affiliates478,114 468,882 488,266 
Nonaffiliates26,517 50,472 50,796 
Amounts recoverable on reinsurance contracts:
Affiliates— — — 
Nonaffiliates126 227 382 
In 2020, 2019 and 2018, 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, 2020, 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.
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, 2020, there are no reinsurance agreements in effect such that the amount of losses paid or accrued exceed the total direct premium
39
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020, 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 $32.1 million and $(9.6) million at December 31, 2020 and 2019, respectively. The tax years 2014 through 2019 remain subject to examination by major tax jurisdictions.
The amount of federal income taxes incurred that will be available for recoupment at December 31, 2020, in the event of future capital losses is $15.9 million, $3.8 million, and $100.9 million from 2020, 2019 and 2018, respectively.
The aggregate amount of deposits admitted under Section 6603 of the Internal Revenue Service Code is $0.0 million and $32.3 million in 2020 and 2019, respectively.
The components of the net deferred tax asset (liability) at December 31 are as follows:
12/31/2020
(In Thousands)
(1)(2)(3)
  (Col 1+2)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$260,350 $9,142 $269,492 
(b)Statutory valuation allowance adjustments— — — 
(c)Adjusted gross deferred tax assets (a - b)260,350 9,142 269,492 
(d)Deferred tax assets nonadmitted30,028 — 30,028 
(e)Subtotal net admitted deferred tax assets (c - d)230,322 9,142 239,464 
(f)Deferred tax liabilities120,664 32,226 152,890 
(g)Net admitted deferred tax asset/(net deferred tax liability) (e - f)$109,658 $(23,084)$86,574 

40
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
12/31/2019
(In Thousands)
(4)(5)(6)
  (Col 4+5)
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 

Change
(In Thousands)
(7)(8)(9)
  (Col 7+8)
OrdinaryCapitalTotal
(a)Gross deferred tax assets$14,349 $(1,201)$13,148 
(b)Statutory valuation allowance adjustments— — — 
(c)Adjusted gross deferred tax assets (a - b)14,349 (1,201)13,148 
(d)Deferred tax assets nonadmitted9,454 — 9,454 
(e)Subtotal net admitted deferred tax assets (c - d)4,895 (1,201)3,694 
(f)Deferred tax liabilities19,526 (7,866)11,660 
(g)Net admitted deferred tax asset/(net deferred tax liability) (e - f)$(14,631)$6,665 $(7,966)

12/31/2020
(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$— $9,142 $9,142 
(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)77,432 — 77,432 
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date77,432 — 77,432 
2. Adjusted gross deferred tax assets allowed per limitation threshold. XXX XXX730,625 
(c)Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities152,890 — 152,890 
(d)Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))$230,322 $9,142 $239,464 

41
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
12/31/2019
(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$— $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 XXX716,334 
(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 

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$— $(792)$(792)
(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)(7,174)— (7,174)
1. Adjusted gross deferred tax assets expected to be realized following the balance sheet date(7,174)— (7,174)
2. Adjusted gross deferred tax assets allowed per limitation threshold. XXX XXX14,291 
(c)Adjusted gross deferred tax assets (excluding the amount of deferred tax assets from (a) and (b) above) offset by gross deferred tax liabilities12,069 (409)11,660 
(d)Deferred tax assets admitted as the result of application of SSAP No. 101 Total ((a) + (b) + (c))$4,895 $(1,201)$3,694 

20202019
Ratio percentage used to determine recovery period and threshold limitation amount912%932%

42
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
12/31/2020
(1)(2)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$260,350$9,142
(b)Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies15.46%3.39%
(c)Net admitted adjusted gross DTAs amount$230,322$9,142
(d)Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies17.39%3.82%

12/31/2019
(3)(4)
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%

Change
(5)(6)
Impact of tax planning strategiesOrdinaryCapital
(In Thousands)
(a)Adjusted gross DTAs amount$14,349$(1,201)
(b)Percentage of adjusted gross DTAs by tax character attributable to the impact of tax planning strategies(4.15)%(0.49)%
(c)Net admitted adjusted gross DTAs amount$4,895$(1,201)
(d)Percentage of net admitted adjusted gross DTAs by tax character attributable to the impact of tax planning strategies(3.93)%(0.39)%
The Company's tax planning strategies include the use of reinsurance.
43
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Current income taxes incurred consist of the following major components:
12/31/202012/31/201912/31/2018
(In Thousands)
(1)Current income tax
(a)Federal$(21,594)$25,236 $39,452 
(b)Foreign249 287 427 
(c)Subtotal(21,345)25,523 39,879 
(d)Federal income tax on net capital gains4,556 (2,103)64,841 
(e)Utilization of capital loss carryforwards— — — 
(f)Other— — — 
(g)Federal and foreign income taxes incurred$(16,789)$23,420 $104,720 

(1)(2)(3)
  (Col 1-2)
(2)Deferred tax assets:12/31/202012/31/2019Change
(a)Ordinary(In Thousands)
(1) Discounting of unpaid losses$— $— $— 
(2) Unearned premium revenue— — — 
(3) Policyholder reserves55,662 51,727 3,935 
(4) Investments34,704 38,325 (3,621)
(5) Deferred acquisition costs18,160 17,845 315 
(6) Policyholder dividends accrual7,693 4,746 2,947 
(7) Fixed assets— — — 
(8) Compensation and benefits accrual113,404 102,259 11,145 
(9) Pension accrual— — — 
(10) Receivables - nonadmitted26,307 26,927 (620)
(11) Net operating loss carryforward— — — 
(12) Tax credit carryforward— — — 
(13) Other4,420 4,172 248 
(99) Subtotal260,350 246,001 14,349 
(b)Statutory valuation allowance adjustment— — — 
(c)Nonadmitted30,028 20,574 9,454 
(d)Admitted ordinary deferred tax assets (2a99 - 2b - 2c)230,322 225,427 4,895 
(e)Capital
(1) Investments9,142 10,343 (1,201)
(2) Net capital loss carryforward— — — 
(3) Real estate— — — 
(4) Other— — — 
(99) Subtotal9,142 10,343 (1,201)
(f)Statutory valuation allowance adjustment— — — 
(g)Nonadmitted— — — 
(h)Admitted capital deferred tax assets (2e99- 2f - 2g)9,142 10,343 (1,201)
(i)Admitted deferred tax assets (2d + 2h)$239,464 $235,770 $3,694 

44
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
(1)(2)(3)
  (Col 1-2)
12/31/202012/31/2019Change
(3)Deferred tax liabilities:(In Thousands)
(a)Ordinary
(1) Investments$109,136 $88,395 $20,741 
(2) Fixed assets372 77 295 
(3) Deferred and uncollected premium8,057 8,353 (296)
(4) Policyholder reserves3,099 4,286 (1,187)
(5) Other— 27 (27)
(99) Subtotal120,664 101,138 19,526 
(b)Capital
(1) Investments32,226 40,092 (7,866)
(2) Real estate— — — 
(3) Other— — — 
(99) Subtotal32,226 40,092 (7,866)
(c)Deferred tax liabilities (3a99 + 3b99)152,890 141,230 11,660 
(4)Net deferred tax assets/liabilities (2i - 3c) $86,574 $94,540 $(7,966)
Among the more significant book-to-tax adjustments were the following:
12/31/2020Effective
Tax Rate		12/31/2019Effective
Tax Rate		12/31/2018Effective
Tax Rate
(In Thousands)(In Thousands)(In Thousands)
Provision computed at statutory rate
$20,039 21.00 %$39,544 21.00 %$111,878 21.00 %
Dividends received deduction
(1,062)(1.11)(1,879)(1.00)(1,990)(0.37)
Tax credits(1,447)(1.52)(2,832)(1.50)(10,205)(1.92)
Other invested assets and nonadmitted change
2,403 2.52 125,349 66.57 (156,090)(29.30)
Uncertain tax positions— — — — 3,876 0.73 
Other(10,065)(10.54)(5,385)(2.86)(454)(0.09)
Change in federal tax rate— — — — (7,813)(1.47)
Total statutory income taxes$9,868 10.35 %$154,797 82.21 %$(60,798)(11.42)%
Federal and foreign taxes incurred
$(16,789)(17.59)%$23,420 12.44 %$104,720 19.66 %
Change in net deferred income taxes
26,657 27.94 131,377 69.77 (165,518)(31.08)
Total statutory income taxes$9,868 10.35 %$154,797 82.21 %$(60,798)(11.42)%
At December 31, 2020, the Company had $0.0 million of net operating loss carryforwards, net capital loss carryforwards and tax credit carry forwards; the company had $0.0 million of deferred tax liabilities that are not recognized.
45
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
As of December 31, 2020, the Company had a liability for federal tax loss contingencies of $2.9 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, 2021, 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, 2020 and 2019, 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 $565.8 million by the end of 2021 without seeking prior regulatory approval based on capital and surplus of $5,657.7 million at December 31, 2020.
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.
46
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Carrying Value of NoteCurrent Year Interest Expense RecognizedTotal Interest Expense RecognizedTotal Principal Paid
(In Thousands)
As of December 31, 2020$497,604 $25,750 $50,928 $— 
As of December 31, 2019$497,519 

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.
At December 31, 2020, the Company does not have any material lease agreements as a lessee for office space or equipment.
47
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
At December 31, 2020, the Company has future commitments to provide additional capital contributions of $401.8 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 $26.6 million for Canal Senate Apartments, LLC, and $14.4 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, 2020, was approximately $48.5 million and $26.6 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 $9.2 million and $14.7 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, 2020, was approximately $6.7 million and $7.9 million. These loans mature in October 2021 and January 2024, respectively.

48
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
9. Life and Annuity Reserves and Deposit-Type Contract Liabilities
At December 31, 2020, 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)
$74,913 $— $— $74,913 95.9 %
Not subject to discretionary withdrawal
3,203 — — 3,203 4.1 
Total individual annuity reserves (before reinsurance)
78,116 — — 78,116 100.0 %
Reinsurance ceded
72,198 — — 72,198 
Net individual annuity reserves
$5,918 $— $— $5,918 
Group AnnuitiesGeneral AccountSeparate Account
With Guarantees		Separate Account
Non-guaranteed		TotalPercent
(In Thousands)
Not subject to discretionary withdrawal
$2,836 $— $1,172,208 $1,175,044 100.0 %
Total group annuity reserves (before reinsurance)
2,836 — 1,172,208 1,175,044 100.0 %
Reinsurance ceded
2,836 — — 2,836 
Net group annuity reserves
$— $— $1,172,208 $1,172,208 
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)
$221,452 $— $— $221,452 100.0 %
Not subject to discretionary withdrawal
— — — — — 
Total deposit-type contract liability (before reinsurance)
221,452 — — 221,452 100.0 %
Reinsurance ceded
23,887 — — 23,887 
Total deposit-type contract liability
$197,565 $— $— $197,565 
Interest rate changes may have temporary effects on the sale and profitability of annuity products offered by the Company. Although the rates offered by the Company are adjustable in the long-term, in the short-term they may be subject to contractual and competitive restrictions, which may prevent timely adjustment. The Company’s management constantly monitors interest rates with respect to a spectrum of
49
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
product durations and sells annuities that permit flexible responses to interest rate changes as part of the Company’s management of interest spreads. However, adverse changes in investment yields on invested assets will affect the earnings on those products with a guaranteed return.
At December 31, 2020, the Company's general and separate account life insurance account values, cash value, and reserves for policies subject to discretionary withdrawal, not subject to discretionary withdrawal, or with no cash value are summarized as follows:
General AccountSeparate Account - Guaranteed and Nonguaranteed
Account ValueCash ValueReserveAccount ValueCash ValueReserve
(In Thousands)
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value$— $— $— $— $— $— 
Universal life— — — — — — 
Universal life with secondary guarantees
— — — — — — 
Indexed universal life— — — — — — 
Indexed universal life with secondary guarantees
— — — — — — 
Indexed life— — — — — — 
Other permanent cash value life insurance
— 2,719,259 3,080,869 — — — 
Variable life— — — — — — 
Variable universal life— — — — — — 
Miscellaneous reserves— — — — — — 
Not subject to discretionary withdrawal or no cash values:
Term policies without cash valueXXXXXX— XXXXXX— 
Accidental death benefitsXXXXXX3,425 XXXXXX— 
Disability - active livesXXXXXX4,841 XXXXXX— 
Disability - disabled livesXXXXXX21,890 XXXXXX— 
Miscellaneous reservesXXXXXX— XXXXXX— 
Total life reserves (before reinsurance)— 2,719,259 3,111,025 — — — 
Reinsurance Ceded— — 379,736 — — — 
Net life reserves$— $2,719,259 $2,731,289 $— $— $— 

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.
50
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
A summary of assets, obligations and assumptions of the pension and other postretirement benefit plans at December 31, are as follows:
Pension BenefitsPostretirement Medical
2020201920202019
(In Thousands)
Change in benefit obligation:
Benefit obligation at beginning of year$1,110,682 $964,649 $166,887 $155,942 
Service cost29,439 23,989 286 308 
Interest cost32,478 38,479 4,344 6,044 
Contribution by plan participants— — 4,871 4,805 
Actuarial (gain) loss125,954 133,588 (2,710)12,288 
Benefits paid(51,000)(50,023)(12,028)(12,500)
Plan amendments— — — — 
Settlements(38,699)— — — 
Benefit obligation at end of year$1,208,854 $1,110,682 $161,650 $166,887 
Change in plan assets:
Fair value of plan assets at beginning of year
$1,087,146 $933,756 $— $— 
Actual return on plan assets174,761 203,413 — — 
Employer contribution— — 7,157 7,695 
Plan participants’ contributions— — 4,871 4,805 
Benefits paid(51,000)(50,023)(12,028)(12,500)
Settlements(38,699)— — — 
Fair value of plan assets at end of year$1,172,208 $1,087,146 $— $— 

Pension BenefitsPostretirement Medical
2020201920202019
(In Thousands)
Funded status:
Overfunded (underfunded) obligation$(36,646)$(23,536)$(161,650)$(166,887)
Unrecognized net (gain) or loss— — — — 
Unrecognized prior service cost— — — — 
Net amount recognized*$(36,646)$(23,536)$(161,650)$(166,887)
Accumulated benefit obligation for vested employees and partially vested employees to the extent vested
$1,102,467 $1,026,764 $161,650 $166,887 
*Nonadmitted if overfunded

51
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Pension Benefits
202020192018
(In Thousands)
Components of net periodic benefit cost:
Service cost$29,439 $23,989 $22,511 
Interest cost32,478 38,479 34,022 
Expected return on plan assets(76,904)(68,093)(72,592)
Amount of recognized gains and losses22,085 25,564 27,655 
Amount of prior service cost recognized(4,625)(4,625)(4,620)
Total net periodic benefit cost (benefit)$2,473 $15,314 $6,976 

Postretirement Medical
202020192018
(In Thousands)
Components of net periodic benefit cost:
Service cost$286 $308 $404 
Interest cost4,344 6,044 5,419 
Amount of recognized gains and losses(3,387)(3,841)(2,138)
Amount of prior service cost recognized(1,392)(1,392)(2,633)
Total net periodic benefit cost (benefit)$(149)$1,119 $1,052 

Pension BenefitsPostretirement Medical
2020201920202019
(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
$343,789 $366,459 $(29,522)$(47,044)
Net transition asset or obligation recognized
— — — — 
Net prior service cost or credit arising during the period
— — — — 
Net prior service cost or credit recognized
4,625 4,625 1,392 1,392 
Net gain and loss arising during the period
28,097 (1,731)(2,711)12,289 
Net gain and loss recognized
(22,085)(25,564)3,387 3,841 
Items not yet recognized as a component of net periodic cost - current year
$354,426 $343,789 $(27,454)$(29,522)

52
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Pension BenefitsPostretirement Medical
2020201920202019
(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)
2,850 (1,775)(2,783)(4,175)
Net recognized gains and (losses)
351,574 345,563 (24,671)(25,348)

Assumptions used to determine net periodic benefit cost for the year ended December 31:
Pension BenefitsPostretirement Medical
2020201920202019
Discount rate3.44%4.39%3.31%4.34%
Rate of compensation increase4.60%4.60%N/AN/A
Expected long-term rate of return on plan assets
7.25%7.50%N/AN/A

Assumptions used to determine the benefit obligation at December 31:
Pension BenefitsPostretirement Medical
2020201920202019
Discount rate2.80%3.44%2.60%3.32%
Rate of compensation increase4.60%4.60%N/AN/A
The Company’s pension liability was $36.6 million and $23.5 million at December 31, 2020 and 2019, 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 3.44% at December 31, 2019, to 2.80% at December 31, 2020. This resulted in a $114.0 million increase in the pension benefit obligation in 2020. 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 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.
53
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
The asset allocation for the defined benefit pension plan at the end of 2020 and 2019, and the target allocation for 2020 by asset category, are as follows:
Target Allocation PercentagePercentage of
Plan Assets
202020202019
Asset category:
Equity securities
55 %64 %63 %
Fixed income securities
15 12 13 
Short-term investments
5 — — 
Other
25 24 24 
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.
54
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
55
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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, 2020:
Debt securities:
Debt securities issued by states of the U.S. and political subdivisions of the states
$2,973 $— $2,973 $— 
Corporate securities
119,940 — 119,940 — 
Residential mortgage-backed securities
1,597 — 1,597 — 
Asset-backed securities
10,523 — 10,523 — 
Equity securities:
Common equity
519,209 470,415 48,794 — 
Mutual funds
235,822 235,822 — — 
Other invested assets:
Private equity and fixed income funds
232,117 — 232,117 — 
Surplus notes
4,096 — 4,096 — 
Real estate
21,296 — — 21,296 
Other assets
49,783 48,227 1,556 — 
Total plan assets
$1,197,356 $754,464 $421,596 $21,296 
* Includes investments using net asset value (NAV) as a practical expedient.

56
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
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.
For measurement purposes of the postretirement benefit obligation at December 31, 2020, a 5.35 percent annual rate of increase in the per capita cost of covered health care benefits is assumed for 2021. The rate was assumed to decrease gradually to 4.75 percent for 2029 and remain at that level thereafter.
At December 31, 2020, the assets of the Company’s pension include approximately $148.7 million invested in the Touchstone Family of Funds, which are administered by the Company, and $213.9 million invested in private equity and fixed income funds managed by Fort Washington Investment Advisors, Inc. 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, $205.3 million invested in private equity and fixed income funds managed by Fort Washington Investment Advisors, Inc.
As of December 31, 2020, future benefit payments for the pension plan are expected as follows (in millions):
2021$53.2 
202254.1 
202355.1 
202455.9 
202556.7 
Five years thereafter297.2 
57
The Western and Southern Life Insurance Company
Notes to Financial Statements (Statutory-Basis)
December 31, 2020, 2019 and 2018
Future benefit payments for the postretirement medical plan, net of amounts contributed by plan participants, are expected as follows (in millions):
2021$9.7 
20229.5 
20239.5 
20249.2 
20259.0 
Five years thereafter41.9 
The Company did not make any contributions to the pension plan in 2020 and 2019. The Company does not anticipate a required contribution to the pension plan during 2021.
In 2020, the Company entered into a group annuity contract with WSLAC to transfer risk and administration costs associated with their pension benefit obligations. This reduced plan assets and the pension benefit obligation by $38.7 million. Future changes in plan assets and obligations will no longer reflect the participants included in the transfer.
The Company made contributions to the postretirement medical plan of $7.2 million in 2020 and expects to contribute $88.8 million between 2021 and 2028, inclusive. The Company received no subsidies in 2020. 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 $6.8 million, $6.2 million, and $5.4 million for 2020, 2019 and 2018, respectively.

11. Premium and Annuity Considerations Deferred and Uncollected
Deferred and uncollected life insurance premiums and annuity considerations at December 31, 2020, were as follows:
GrossNet of Loading
(In Thousands)
Ordinary new business$3,893 $197 
Ordinary renewal68,165 48,440 
Accident and health renewal376 287 
Assumed investment type-contracts391 391 
Total$72,825 $49,315 

58
 
NAT VAROOM    April 2021

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, 2020
Statements of Operations for the Year Ended December 31, 2020
Statements of Changes in Net Assets for the Years Ended December 31, 2020 and 2019
Notes to Financial Statements

National Integrity Life Insurance Company (Depositor):
Report of Independent Auditors
Balance Sheets (Statutory-Basis) as of December 31, 2020 and 2019
Statements of Operations (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
Statements of Changes in Capital and Surplus (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
Statements of Cash Flow (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
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, 2010 and 2019
Statements of Operations (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
Statements of Changes in Capital and Surplus (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
Statements of Cash Flow (Statutory-Basis) for the Years Ended December 31, 2020, 2019 and 2018
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.
1
NAT VAROOM    April 2021

4.
5.
6.
c.    Certificate of Amendment of the Charter of National Integrity Life Insurance Company, effective December 16, 2013. Incorporated by reference to Exhibit 99.6(C) to Registrant's Post-Effective Amendment No. 4 to registration statement on Form N-4 (File No. 333-177618), filed April 25, 2014.
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.    Rule 22c-2 Agreement between Fidelity Distributors Corporation and National Integrity dated March 26, 2007. Incorporated by reference to Exhibit 99.8(D) to Registrant's Post-Effective Amendment No. 1 to registration statement on Form N-4 (File No. 333-177618), filed April 25, 2012.
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NAT VAROOM    April 2021

g.    ETFxChange Authorization between National Integrity and Mid Atlantic Trust Company effective November 1, 2010. Incorporated by reference to Exhibit 99.8(F) to Registrant’s Pre-Effective Amendment No. 1 to registration statement on Form N-4 (File No. 333-167372), filed December 10, 2010.
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.
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.
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
Cameron F. MacRae III1    Director
Newton Phelps Stokes Merrill2    Director
George R. Bunn Jr.3    Director

Officers:
John F. Barrett    Director, Chairman of the Board     
Jill T. McGruder    Director, President and Chief Executive Officer
Edward J. Babbitt    Director, Secretary
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
Phillip E. King    Senior Vice President and Auditor
David T. Henderson    Senior Vice President and Chief Risk Officer
3
NAT VAROOM    April 2021

Bradley J. Hunkler    Senior Vice President and Chief Financial Officer
James J. Vance    Senior Vice President and Co-Chief Investment Officer
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 Treasurer
Terrie A. Wiedenheft    Vice President
Paul M. Kruth    Vice President
Paul C. Silva    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
Amy M. Retzsch    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
Michael Marchese III    Assistant Treasurer
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: 1540 Broadway, New York, NY 10036-4086
2 Principal Business Address: 262 Central Park West, Apt. 12B, New York, NY 10024
3 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
AffiliateStateEntity AbbOwnershipType of Business
1373 Lexington Road Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC; 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
2758 South Main SPE, LLCOHLLC100% owned by The Western and Southern Life Insurance Companyownership and operation of real estate
309 Holding LLCDELLC97% 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)
505 Courtland Owner, LLCDELLC100% owned by Courtland Apartments, LLCreal estate ownership entity(ies)
506 Phelps Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Alliant Tax Credit Fund 92 LPCALP13.4% limited partnership interest owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
4
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Alta Mercer Crossing, LLCDELLC50% 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, LLCDELLC100% owned by Alta Preston, LLCownership and operation of real estate
Alta Preston, LLCDELLC100% owned by Alta, 47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Arvada Kipling Housing Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Ascent Plainfield, LLCINLLC64% owned by Stout Metro Housing Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Beardsley Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Boston Capital Corporate Tax Credit Fund XLIXDELP25.751% limited partnership interests owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
Buckeye Venture Partners, LLCOHLLC60% owned by Fort Washington Investment Advisors, Inc. (FWIA); 40% owned by Peppertree Partners, LLCprivate equity fund management
BVP NEO, LLCOHLLC100% owned by Fort Washington Investment Advisors, Inc.private equity fund management
Canal Senate Apartments, LLCINLLC100% owned by W&S Real Estate Holdings, LLCownership and operation of real estate
Cape Barnstable Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Carmel Holdings, LLCOHLLC99% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Carmel Hotel Investor, LLCOHLLC100% owned by Carmel Holdings, LLCreal estate ownership entity(ies)
Carmel Hotel, LLCINLLC99% owned by Carmel Hotel Investor, LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Carthage Senior Housing, Ltd.OHLLC98% owned by W&S Real Estate Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
CCA CBD Cincinnati LLCOHLLC100% owned by 309 Holding, LLCownership and operation of real estate
Cedar Park Senior Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
5
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Cenizo Apartments Investor Holdings, LLCOHLLC98% 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, LLCOHLLC98% 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, LLCOHLLC98% 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.DELP20% limited partnership interest owned by The Western and Southern Life Insurance Companyreal estate ownership entity(ies)
Cincinnati CBD Holdings, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCownership and operation of real estate
Cinnaire Fund for Housing Limited Partnership 31MILP16.7% limited partnership interest owned by Columbus Life Insurance Companyreal estate ownership entity(ies)
Cleveland East Hotel, LLCOHLLC99% owned by WSALD CEH, LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Columbus Life Insurance CompanyOHCorp100% owned by The Western and Southern Life Insurance Company
Country Place AssociatesOHGP90% owned by WS Country Place GP, LLC; 10% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Courtland Apartments, LLCDELLC47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Cove Housing Investor Holdings, LLCOHLLC98% W&S Real Estate Holdings, LLC and 2% Eagle Realty Investments, Inc.real estate ownership entity(ies)
Cranberry NP Hotel Company, LLCPALLC99% owned by NP Cranberry Hotel Investor LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Curve Luxury Apartments Investors, LLCDELLC59% owned by MC Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Curve Luxury Apartments, LLCAZLLC100% owned by Curve Luxury Apartments Investors, LLCownership and operation of real estate
Dallas City Investor Holdings, LLCOHLLC98% 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 LLCCTLLC74% owned by W&S Real Estate Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Delco Lofts, LLCOHLLC99% owned by Patterson at First Investor Holdings, LLCownership and operation of real estate
Dunvale Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
6
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Eagle Realty Capital Partners, LLCOHLLC100% Eagle Realty Group, LLCinvestment advisor
Eagle Realty Group, LLCOHLLC100% owned by Western & Southern Investment Holdings, LLCreal estate holding company
Eagle Realty Investments, Inc. (ERI)OHCorp100% owned by Eagle Realty Group, LLCreal estate ownership entity(ies)
Eagle Rose Apartment Holdings, LLCOHLLC98% 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, LLCDELLC24% owned by Eagle Rose Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Eagle Rose Owner, LLCDELLC100% owned by Eagle Rose Land Partners, LLCownership and operation of real estate
Elan Dallas City Lights GP, LLCDELLC100% owned by Elan Dallas City Lights, LLCreal estate ownership entity(ies)
Elan Dallas City Lights Limited Partner, LPDELLC100% owned by Elan Dallas City Lights, LLC; 0% owned by Elan Dallas City Lights GP, LLCreal estate ownership entity(ies)
Elan Dallas City Lights Owner, LPDELP99% owned by Elan Dallas City Lights Limited Partner, LP; 1% owned by Elan Dallas City Lights GP, LLCownership and operation of real estate
Elan Dallas City Lights, LLCDELLC59% 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)DELLC100% owned by EMF River Walk Investments, LLCownership and operation of real estate
EMF River Walk Investments, LLCDELLC54% 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, LLCDELLC49% owned by Beardsley Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Flats at Springhurst LLCKYLLC100% owned by Springhurst JV, L.L.C.ownership and operation of real estate
Flats Springhurst Investor Holdings, LLCOHLLC98% 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, LLCOHLLC98% 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)DELLC100% owned by Fort Washington Investment Advisors, Inc.managing partner for numerous private equity funds
Fort Washington Emerging Market Debt LLCDELLCManaging Member is Fort Washington Fixed Income LLCfixed income
7
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Fort Washington Fixed Income LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.private fixed income fund
Fort Washington Flexible Income LLCDELLCManaging Member is Fort Washington Fixed Income LLCprivate fixed income fund
Fort Washington Full Discretion Fixed Income LLCDELLCManaging Member Fort Washington Fixed Income LLC and investors include The Western and Southern Life Insurance Companymanaging member for private fixed income fund
Fort Washington High Yield Investors II, LLCDELLCmanaging member is FWCPprivate fixed income fund
Fort Washington High Yield Investors LLCDELLCmanaging member is FWCPprivate fixed income fund
Fort Washington Investment Advisors, Inc. (FWIA)OHCorp100% owned by Western & Southern Investment Holdings, LLCregistered investment adviser
Fort Washington Private Equity Investors II, L.P.DELPgeneral partner is FWCP and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors III, L.P.DELPgeneral partner is FWCP and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors IV, L.P. DELPgeneral partner is FWCP and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors IX, L.P.DELPgeneral partner is FWPEI IX GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors IX-B, L.P.DELPGeneral Partner is FWPEI IX GP, LLC and The Western and Southern Life Insurance Company is the sole limited partnerprivate equity fund
Fort Washington Private Equity Investors IX-K, L.P.DELPgeneral partner is FWPEI IX GP, LLCprivate equity fund
Fort Washington Private Equity Investors V, L.P. DELPgeneral partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors V-B, L.P.DELPgeneral partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors VI, L.P.DELPgeneral partner is FWPEI VI GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors VII, L.P.DELPgeneral partner is FWPEI VII GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors VIII, L.P.DELPgeneral partner is FWPEI VIII GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors VIII-B, L.P.DELPGeneral Partner is FWPEI VIII GP, LLC and The Western and Southern Life Insurance Company is the sole limited partnerprivate equity fund
8
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Fort Washington Private Equity Investors V-VC, L.P.DELPgeneral partner is FWPEI V GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors X, L.P.DELPgeneral partner is FWPEI X GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Fort Washington Private Equity Investors X-B, L.P.DELPgeneral partner is FWPEI X GP, LLC and The Western and Southern Life Insurance Company is the sole limited partnerprivate equity fund
Fort Washington Private Equity Opportunities Fund II, L.P.DELPGeneral Partner is FWPEO II GP, LLC and The Western and Southern Life Insurance Company is an investorprivate equity fund
Fort Washington Private Equity Opportunities Fund III, L.P.DELPGeneral Partner is FWPEO III GP, LLC and The Western and Southern Life Insurance Company is an investorprivate equity fund
Fort Washington Private Equity Opportunities Fund III-B, L.P.DELPGeneral Partner is FWPEO III GP, LLC and The Western and Southern Life Insurance Company is the sole limited partnerprivate equity fund
Fort Washington Private Equity Opportunities Fund IV, L.P.DELPGeneral Partner is FWPEO IV GP, LLC and The Western and Southern Life Insurance Company is an investorprivate equity fund
Fort Washington Private Equity Opportunities Fund IV-B, L.P.DELPGeneral Partner is FWPEO IV GP, LLC and The Western and Southern Life Insurance Company is the sole limited partnerprivate equity fund
Fort Washington Private Equity Opportunities Fund IV-Feeder, LLCDELLCGeneral Partner is FWPEO IV GP, LLC and Fort Washington Investment Advisors, Inc. is its Managing Memberprivate equity fund
Fort Washington Private Equity Opportunities Fund IV-K, L.P.DELPGeneral partner is FWPEO IV GP, LLCprivate equity fund
Fort Washington Private Equity Small Market Investors X-S, L.P.DELPGeneral partner is FWPEI X GP, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Frontage Lodging Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
FWPEI IX GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund IX
FWPEI V GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of the three private equity funds
FWPEI VI GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund VI
FWPEI VII GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund VII
FWPEI VIII GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund VIII
FWPEI X GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund X
9
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
FWPEO II GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.private equity fund management
FWPEO III GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.private equity fund management
FWPEO IV GP, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.general partner of Fund IV
Gateway at Arvada Ridge, LLCDELLC35.39% owned by Arvada Kipling Housing Holdings, LLC and 0.72% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Gerber Life Agency, LLCOHLLC100% owned by The Western and Southern Life Insurance Companyinsurance marketing services
Gerber Life Insurance CompanyNYCorp100% owned by The Western and Southern Life Insurance Company
Glendale Beardsley, LLCDELLC100% owned by EP/WSE Glendale Venture, LLC (DE)ownership and operation of real estate
Grand Dunes Senior Holding, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Great Lakes Capital Fund for Housing LP 30MILP13.5% limited partnership interest owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
GS Lakeline AA Apartments, LLCDELLC49% 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, LLCDELLC49% owned by Forsyth Halcyon AA Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.
GS Nashville Hotel Owner, LLCDELLC100% owned by Nashville Hotel JV, LLCownership and operation of real estate
GS Short Pump AA Apartments Owner, LLCDELLC100% owned by GS Short Pump AA Apartments, LLCownership and operation of real estate
GS Short Pump AA Apartments, LLCDELLC49% owned by Three Chopt AA Investor Holdings, LLC; and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Heartis Venice JV, LLCDELLC49% owned by Tamiami Senior Investor Holdings, LLC (OH) and 1% owned Eagle Realty Investments, Inc.real estate ownership entity(ies)
Heartis Venice, LLCDELLC100% owned by Heartis Venice JV, LLCownership and operation of real estate
Houston Reverie, LLCTXLLC59% 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)OHCorp100% owned by Western-Southern Life Assurance Company (Western-Southern Life Assurance Company)real estate ownership entity(ies)
10
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Integrity Life Insurance Company (ILIC)OHCorp100% owned by The Western and Southern Life Insurance Company
JLB Southpark Apartments LLCDELLC49% owned by SP Charlotte Apts Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Jomax Holdings, LLCDELLC47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Jomax Residences, LLCDELLC100% owned by Jomax Holdings, LLCreal estate ownership entity(ies)
KCJA X NNN Industrial Investor Holdings, LLCOHLLC100% owned by Western-Southern Life Assurance Companyreal estate ownership entity(ies)
KCWSE Palmetto Pointe, LLCDELLC64% 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, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
LaFrontera Hotel LLCTXLLC100% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
LaFrontera Lodging Partners LPOHLP99% owned by W&S Real Estate Holdings, LLCownership and operation of real estate
Lennox Zionsville Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
LLIA, Inc.OHCorp100% owned by The Lafayette Life Insurance Companygeneral insurance agency
Lorraine Senior Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Lytle Park Inn, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Main Hospitality Holdings, LLCOHLLC78.4% 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, LLCOHLLC98% 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, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Midtown Park Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Monterosso Apartments JV, LLCDELLC54% owned by Monterosso Housing Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
11
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Monterosso Apartments, LLCDELLC100% owned by Monterosso Apartments JV, LLCownership and operation of real estate
Monterosso Housing Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Monterosso Housing Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
MP Dallas Development Holdings, LLCDELLC49% owned by Midtown Park Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
MP Dallas Project Owner, LLCDELLC100% owned by MP Dallas Development Holdings, LLCownership and operation of real estate
Nashville Hotel JV, LLCDELLC52% owned by W&S REH and 3% by ERIreal estate ownership entity(ies)
NEO Capital Fund, LPDELPGeneral Partner is BVP NEO, LLCprivate equity fund
North Pittsburgh Hotel LLCPALLC99% owned by WSALD NPH, LLC; 1% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
NP Cranberry Hotel Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC, 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
NP Cranberry Hotel Investor, LLCOHLLC100% owned by NP Cranberry Hotel Holdings, LLCreal estate ownership entity(ies)
OTR Housing Associates, L.P.OHLP98% 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, LLCOHLLC100% owned by OTR Walnut Housing, Ltd.real estate ownership entity(ies)
OTR Transitional Housing, L.P.OHLP99% owned by The Western and Southern Life Insurance Companyownership and operation of real estate
OTR-Walnut Housing, Ltd.OHLLC100% owned by Eagle Realty Investments, Inc.ownership and operation of real estate
Park BLVD Holdings, LLCDELLC47% owned by W&S Real Estate Holdings and 3% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Park BLVD Residences, LLCDELLC100% owned by Park Blvd Holdings, LLCreal estate ownership entity(ies)
Patterson at First Investor Holdings, LLCOHLLC100% owned by Integrity Life Insurance Companyreal estate ownership entity(ies)
Pleasanton Hotel Holding Company LLCDELLC69% owned by Pleasanton Hotel Investor Holdings, 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
12
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Pleasanton Hotel Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Pleasanton Project Owner, LLCDELLC100% owned by Pleasanton Hotel Holding Company LLCownership and operation of real estate
Portside Residences, LLCDELLC100% owned by PRLE, LLCreal estate ownership entity(ies)
Prairie Path Apts Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Price Road Hotel LLCDELLC64% 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, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
PRLE, LLCDELLC49% owned by Grand Dunes Senior Holding, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Queen City Square Development I, LLCOHLLC100% owned by Eagle Realty Group, LLCoperation of real estate
Queen City Square, LLCOHLLC99.75% owned to The Western and Southern Life Insurance Company; .25% Eagle Realty Investments, Inc.ownership and operation of real estate
R4 Housing Partners IX LPDELLC14.7% limited partnership interest owned by The Lafaye Insurance Companyreal estate ownership entity(ies)
R4 Housing Partners V LPDELP9.3% limited partnership interest owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
R4 Housing Partners VI LPDELP16.7% limited partnership interest owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
R4 Housing Partners XV LPDELP25.42% limited partnership interests owned by The Lafayette Life Insurance Companyreal estate ownership entity(ies)
Raleigh Hotel Holding Company LLCDELLC62% owned by W&SREH and 3% owned by ERIreal estate ownership entity(ies)
Raleigh Project Owner LLCDELLC100% owned by Raleigh Hotel Holding Company, LLCownership and operation of real estate
Rancho Presidio Fee Owner LLCDELLC100% owned by Rancho Presidio Land Partners LLCreal estate ownership entity(ies)
Rancho Presidio Land Partners LLCDELLC21.14% owned by W&S Real Estate Holdings and 3.86% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Randolph Tower Affordable Investment Fund, LLCDELLC99.99% owned by The Western and Southern Life Insurance Companyreal estate ownership entity(ies)
13
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Raymond James Tax Cred Fund 46 L.L.C.FLLLC28.91% limited partnership interests owned by Columbus Life Insurance Companyreal estate ownership entity(ies)
Revel Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
River Hollow Investor Holdings, LLCOHLLC98% 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, LLCOHLLC98% 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 LLCDELLC100% owned by Russell Bay Land Partners LLCownership and operation of real estate
Russell Bay Land Partners LLCDELLC64% owned by Russell Bay Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
San Tan Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Sarasota Property Owner, LLCDELLC100% owned by Senior Living at Sarasota, LLCownership and operation of real estate
Senior Living at Sarasota, LLCDELLC49% owned by Lorraine Senior Investor Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Seventh and Culvert Garage, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCreal estate ownership entity(ies)
Sixth and Saratoga NW, LLCKYLLC100% owned by W&S Real Estate Holdings, LLCownership and operation of real estate
South Flores Housing Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
South Kirkman Apartment Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
South Kirkman Fee Owner LLCDELLC100% owned by South Kirkman Land Partners LLCownership and operation of real estate
South Kirkman Land Partners LLCDELLC64% owned by South Kirkman Apartment Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Southside Tunnel Apartments Investor Holdings, LLCOHLLC98% 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, LLCDELLC49% 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, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
14
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Springhurst JV, L.L.C.KYLLC64% owned by Flats Springhurst Investor Holdings, LLC; and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
SPX Holding LLCOHLLC50% owned by W&SFGAirplane ownership/leasing
SSW Jet LtdOHLLC50% owned by W&SFGAirplane ownership/leasing
Stout Metro Housing Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Sundance Hotel Investor, LLCOHLLC100% owned by Sundance LaFrontera Holdings, LLCreal estate ownership entity(ies)
Sundance Hotel, LLCDELLC64% owned by Sundance Hotel Investor, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Sundance LaFrontera Holdings, LLCOHLLC98% 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, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
The Lafayette Life Insurance CompanyOHCorp100% owned by Western & Southern Financial Group, Inc. (WSFG)
The Ohio Capital Fund LLCOHLLCManaged by Buckeye Venture Partners, LLCstate funded private equity fund
The Western and Southern Life Insurance Company (WSLIC)OHCorp100% owned by WSFG
Three Chopt AA Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Timacuan Apartment Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Timacuan Fee Owner LLCDELLC100% owned by Timacuan Land Partners LLC (DE)ownership and operation of real estate
Timacuan Land Partners LLCDELLC64% owned by Timacuan Apartment Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Touchstone Advisors, Inc.OHCorp100% owned by IFS Financial Services, Inc.registered investment adviser
Touchstone Securities, Inc.NECorp100% owned by IFS Financial Services, Inc. Financial Services, Inc.securities broker-dealer
Trevi Apartment Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
15
NAT VAROOM    April 2021

AffiliateStateEntity AbbOwnershipType of Business
Trevi Fee Owner, LLCDELLC100% Trevi Land Partners, LLCownership and operation of real estate
Trevi Land Partners, LLCDELLC64% Trevi Apartment Holdings, LLC; 1% Eagle Realty Investments, Inc.real estate ownership entity(ies)
Tri-State Growth Capital Fund I, L.P.DELPgeneral partner is Tri-State Ventures, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Tri-State Growth Capital Fund II, L.P.DELPgeneral partner is Tri-State Ventures II, LLC and investors include The Western and Southern Life Insurance Companyprivate equity fund
Tri-State Ventures II, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.private equity fund
Tri-State Ventures, LLCDELLC100% owned by Fort Washington Investment Advisors, Inc.private equity fund
TXFL NNN Office Investor Holdings, LLCOHLLC40.7408% 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 Companyreal estate ownership entity(ies)
UGR Holdings, LLCDELLC49% owned by University Shade Investor Holdings, LLC (OH) and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
University Grove Residences, LLCDELLC100% owned by UGR Holdings, LLC (DE)ownership and operation of real estate
University Shade Investor Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Vail Hotel Holdings ESHV, LLCDELLC74% owned by Frontage Lodging Investor Holdings, LLC; 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Vail Hotel Owner ESHV, LLCDELLC100% owned by Vail Hotel Holdings ESHV, LLCownership and operation of real estate
Vinings Trace, LLCINLLC99% 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, LLCOHLLC98% owned by W&S Real Estate Holdings, LLC and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
W Flats Residences, LLCDELLC66.5% 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.OHCorp100% owned by Western-Southern Life Assurance Companyinvestment advisor and broker dealer
W&S Financial Group Distributors, Inc.OHCorp100% owned by Western-Southern Life Assurance Companygeneral insurance agency
W&S Real Estate Holdings, LLCOHLLC100% owned by The Western and Southern Life Insurance Companyreal estate ownership entity(ies)
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AffiliateStateEntity AbbOwnershipType of Business
Warm Springs Apartment Holdings, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
Warm Springs Fee Owner LLCDELLC100% owned by Warm Springs Land Partners LLCownership and operation of real estate
Warm Springs Land Partners LLCDELLC64% owned by Warm Springs Apartment Holdings, LLC and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
West Crescent Venture Partners LLCDELLC49% owned by Revel Investor Holdings, LLC, and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
WestAd Leasing, LLCOHLLC100% owned by Western & Southern Financial Group, Inc. (WSFG)Airplane ownership/leasing
Western & Southern Agency, Inc.OHCorp100% owned by The Western and Southern Life Insurance Companygeneral insurance agency
Western & Southern Financial Fund IncOHNP Corpcharitable giving
Western & Southern Financial Group, Inc. (WSFG)OHCorp100% owned by WSMHCholding company
Western & Southern Investment Holdings, LLCOHLLC100% owned by The Western and Southern Life Insurance Companyreal estate ownership entity(ies)
Western & Southern Mutual Holding Company (WSMHC)OHCorpMutual Insurance Holding Company
Western-Southern Life Assurance Company (WSLAC)OHCorp100% owned by The Western and Southern Life Insurance Company
Westhouse Residences, LLCDELLC49% 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, LLCOHLLC98% owned by W&S Real Estate Holdings and 2% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
WL Houston Parkway, LLCTXLLC55% owned by WL Apartment Holdings and 1% owned by Eagle Realty Investments, Inc.real estate ownership entity(ies)
WS Airport Exchange GP, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCreal estate ownership entity(ies)
WS Country Place GP, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCreal estate ownership entity(ies)
WS Lookout JV, LLCOHLLC100% owned by The Western and Southern Life Insurance Companyreal estate ownership entity(ies)
WSALD CEH, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCreal estate ownership entity(ies)
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AffiliateStateEntity AbbOwnershipType of Business
WSALD NPH, LLCOHLLC100% owned by W&S Real Estate Holdings, LLCreal estate ownership entity(ies)
WSFG WG Aurora IL, LLCOHLLC100% owned by Country Place Associatesownership and operation of real estate
WSFG WG Charlotte NC, LLCOHLLC100% owned by Country Place Associatesownership and operation of real estate
WSFG WG Columbus OH, LLCOHLLC100% owned by Vinings Trace, LLCownership and operation of real estate
WSFG WG Holding RI, LLCOHLLC100% owned by Country Place Associatesownership and operation of real estate
WSFG WG Providence RI, LLCOHLLC100% owned by Country Place Associatesownership and operation of real estate
WSFG WG Stallings NC, LLCOHLLC100% owned by Vinings Trace, LLCownership and operation of real estate
WSL Partners, L.P.DELPgeneral partner is FWCP and investors include The Western and Southern Life Insurance Companyprivate equity fund

Item 27.    Number of Contract Owners

As of April 7, 2021, 19 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
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NAT VAROOM    April 2021

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.

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:
E. Blake Moore, Jr.    President and Chief Executive Officer
Mary T. Mock    Sr. Vice President
Timothy J. Costanza    Vice President and Managing Director
Jay V. Johnson    Vice President and Treasurer
Sharon L. Karp    Vice President
Amy Fisher    Vice President
Timothy S. Stearns    Vice President and Interim Chief Compliance Officer
Terrie A. Wiedenheft    Chief Financial Officer
Benjamin J. Alge    Divisional Vice President
Timothy A. Bray    Divisional Vice President
Michael S. Jones    Assistant Vice President
Lindsay M. Connelly    Assistant Vice President and Assistant Treasurer
John S. Musgrove     Assistant Vice President and Assistant Treasurer
Jason T. Anderson    Assistant Treasurer
Michael Marchese III    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.

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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;

(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.

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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 16, 2021.



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 2021

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 16, 2021.

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 16, 2021
PRINCIPAL FINANCIAL OFFICER:
/s/ Bradley J. Hunkler
Bradley J. Hunkler, Senior Vice President and Chief Financial Officer
April 16, 2021
PRINCIPAL ACCOUNTING OFFICER:/s/ Wade M. Fugate
Wade M. Fugate, Vice President and Controller
April 16, 2021


DIRECTORS:

/s/ John F. Barrett/s/ Jill T. McGruder
John F. BarrettJill T. McGruder
April 16, 2021April 16, 2021
/s/ Edward J. Babbitt/s/ Jonathan D. Niemeyer
Edward J. BabbittJonathan D. Niemeyer
April 16, 2021April 16, 2021
/s/ Daniel J. Downing/s/ Donald J. Wuebbling
Daniel J. DowningDonald J. Wuebbling
April 16, 2021April 16, 2021








NAT VAROOM    April 2021

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 16, 2021.


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 16, 2021
PRINCIPAL FINANCIAL OFFICER:
/s/ Bradley J. Hunkler
Bradley J. Hunkler, Senior Vice President and Chief Financial Officer
April 16, 2021
PRINCIPAL ACCOUNTING OFFICER:/s/ Wade M. Fugate
Wade M. Fugate, Vice President and Controller
April 16, 2021

DIRECTORS:

/s/ John F. Barrett/s/ Wade M. Fugate
John F. BarrettWade M. Fugate, Attorney-in-Fact for
Jo Ann Davidson
April 16, 2021
April 16, 2021
/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 16, 2021April 16, 2021
/s/ Wade M. Fugate
Wade M. Fugate, Attorney-in-Fact for
Thomas L. Williams
April 16, 2021