File Nos. 33-69712/811-08052

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-4
REGISTRATION STATEMENT
UNDER
THE SECURITIES ACT OF 1933	X
Pre-Effective Amendment No.
Post-Effective Amendment No. 41	X
REGISTRATION STATEMENT
UNDER
THE INVESTMENT COMPANY ACT OF 1940	X
Amendment No. 92	X

(Check appropriate box or boxes.)

SYMETRA SEPARATE ACCOUNT C

(Exact Name of Registrant)

Symetra Life Insurance Company

(Name of Depositor)

777 108th Ave NE, Suite 1200, Bellevue, WA	98004
(Address of Depositor’s Principal Executive Offices)	(Zip Code)

Depositor’s Telephone Number, including Area Code (425) 256-8000

Name and Address of Agent for Service

Rachel Dobrow Stone

777 108th Ave NE, Suite 1200

Bellevue, Washington 98004

Approximate date of Proposed Public Offering:

As Soon as Practicable after Effective Date of this registration statement

     It is proposed that this filing will become effective:

	Immediately upon filing pursuant to paragraph (b) of Rule 485
X	On May 1, 2021, pursuant to paragraph (b) of Rule 485
	60 days after filing pursuant to paragraph (a) of Rule 485
	On ___________ pursuant to paragraph (a) of Rule 485 filing

If appropriate, check the following:

X this post-effective amendment designates a new effective date for a previously filed post-effective amendment.

Spinnaker® Variable Annuity

Individual Flexible Premium Deferred Variable Annuity Contract

Issued By:

SYMETRA LIFE INSURANCE COMPANY

and

SYMETRA SEPARATE ACCOUNT C

Prospectus Dated: May 1, 2021

This prospectus describes the Spinnaker Variable Annuity Contract and contains important information. Please read it before investing and keep it on file for future reference. This prospectus does not constitute an offering in any jurisdiction in which the Contract may not lawfully be sold. The Contract is no longer offered for sale. Owners may, however, continue to make Purchase Payments under existing Contracts.

Beginning on January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the shareholder reports for the Portfolios available under your Contract will no longer be sent by mail, unless you specifically request paper copies of the reports from us. Instead, the reports will be made available on a website, and you will be notified by mail each time a report is posted and provided with a website link to access the report. If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. You may elect to receive shareholder reports and other communications from us electronically by logging into your account through symetra.com. You may elect to receive all future reports in paper free of charge. You can inform us that you wish to continue receiving paper copies of your shareholder reports by calling 1-800-796-3872. Your election to receive reports in paper will apply to all Portfolios available under your Contract.

To learn more about the Spinnaker Variable Annuity Contract, you can obtain a copy of the Statement of Additional Information (“SAI”) dated May 1, 2021. The SAI is incorporated by reference, has been filed with the SEC and is legally part of the prospectus. You may request a free copy of the SAI, a paper copy of this prospectus, or a prospectus for any of the underlying Portfolios, by calling us at 1-800-796-3872, writing us at: P.O. Box 305156, Nashville, TN 37230-5156 or on the Internet at www.symetra.com/regulatoryreports.

Additional information about certain investment products, including variable annuities, has been prepared by the SEC’s staff and is available at Investor.gov.

Investment in a variable annuity contract is subject to risks, including the possible loss of principal. The Contracts are not deposits or obligations of, or guaranteed or endorsed by, any financial institution; and are not insured or guaranteed by the Federal Deposit Insurance Corporation, or any other government agency. Neither the Securities Exchange Commission ("SEC") nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is accurate or complete. Any representation to the contrary is a criminal offense.

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TABLE OF CONTENTS	Page
DEFINED TERMS	4
KEY INFORMATION	5
OVERVIEW OF THE CONTRACT	8
FEE TABLE	10
EXAMPLES	12
PRINCIPAL RISKS OF INVESTING IN THE CONTRACT	13
SYMETRA LIFE, SEPARATE ACCOUNT C & THE GENERAL ACCOUNT	14
INVESTMENT OPTIONS	14
CHARGES AND EXPENSES	16
GENERAL DESCRIPTION OF THE CONTRACT	19
PURCHASE PAYMENTS	21
ANNUITY PAYMENTS (INCOME PHASE)	22
BENEFITS AVAILABLE UNDER THE CONTRACT	25
TRANSFERS	29
ACCESS TO YOUR MONEY	33
TAXES	35
OTHER INFORMATION	42
APPENDIX A: PORTFOLIO AVAILABLE UNDER THE CONTRACT	A-1
APPENDIX B:   CALCULATION OF DEATH BENEFIT OPTIONS	B-1
APPENDIX C:   STATE VARIATIONS	C-1

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DEFINED TERMS

We have used simple, clear language as much as possible in this prospectus. However, by the very nature of the Contracts certain technical words or terms are unavoidable. We have identified the following as some of these words or terms.

Accumulation Phase	The period between the date we allocate your first Purchase Payment and the Annuity Date. During this phase, you can invest money in your Contract.
Accumulation Unit	A unit of measure we use to calculate the value in a Sub-account during the Accumulation Phase.
Annuitant	The natural person on whose life annuity payments for this Contract are based. You are the Annuitant unless you designate someone else before the Annuity Date.
Annuity Date	The date annuity payments begin under an annuity option. This date must be before the maximum annuitization date specified in your Contract.
Annuity Unit	A unit of measure we use to calculate the value of variable annuity payments during the Income Phase.
Beneficiary	The person or entity designated to receive any Contract benefits upon the Owner’s death.
Business Day	Any day the New York Stock Exchange is open for regular trading.
Contract	The Spinnaker Variable Annuity Contract.
Contract Date	The Business Day your initial Purchase Payment and all required information are received at Symetra Life.
Contract Value	The sum of the value of the Sub-accounts attributable to your Contract plus any amount held in the Symetra Fixed Account.
Contract Year	A 12-month period starting on the Contract Date and each anniversary of that date.
General Account	All of Symetra Life’s assets other than those attributable to the Separate Account or other Symetra Life separate accounts.
Income Phase	The period beginning on the Annuity Date during which the payee receives annuity payments.
NYSE	The New York Stock Exchange.
Net Investment Factor	A unit of measure we use in calculating the daily change in Accumulation Unit value for each Sub-account.
Owner, you, your	The person or legal entity entitled to exercise all rights and privileges under the Contract. If there are joint Owners, the signatures of both Owners are needed to exercise rights under the Contract. Any reference to Owner in this prospectus includes any joint Owner.
Portfolios	The variable investment options in which the corresponding Sub-accounts invest.
Purchase Payment	An amount paid to Symetra Life for allocation under the Contract, less any premium tax due at the time the payment is made.
Separate Account	Symetra Separate Account C, a segregated asset account.
Sub-account	A division of the Separate Account for which Accumulation Units and Annuity Units are separately maintained. Each Sub-account invests exclusively in a particular Portfolio. Your Contract generally refers to “Portfolios” when referring to Sub-accounts.
Symetra Fixed Account	The investment option in this Contract that provides for guaranteed interest and is part of Symetra Life’s General Account.

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KEY INFORMATION

Important information you should consider about the Contract

FEES AND EXPENSES
Charges for Early Withdrawals	If you take more than 10% of your Contract Value out in a Contract Year, you may be assessed a contingent deferred sales charge. The amount of this charge depends upon the age of your Contract, not on the age of each Purchase Payment. The charge is based upon the amount withdrawn and starts at 8% in the first Contract Year and decreases one percent each Contract Year until the ninth and later Contract Years when there is no charge. For example, assume you have already made withdrawals exceeding the 10% free withdrawal amount for the year and you request an additional withdrawal of $30,000 on a $100,000 Contract Value, you would pay a contingent deferred sales charge of $2,400 ($30,000 x 8%). In addition, a Withdrawal Charge of $25 or 2% withdrawn whichever is less will be assessed for each withdrawal after the first in a Contract Year.	For more information, see CHARGES AND EXPENSES
Transaction Charges	A Transfer Charge of $10 will apply upon each transfer in excess of 12 transfers in a Contract Year.	For more information, see CHARGES AND EXPENSES

Ongoing Fees and Expenses (annual charges)	The table below describes the fees and expenses that you may pay each year, depending on the options you choose. Please refer to your Contract data page for information about the specific fees you will pay each year based on the options you have elected.			For more information, see CHARGES AND EXPENSES
	Annual Fee	Minimum	Maximum
	Base Contract (1)	1.90%	3.24%
	Investment options (Portfolio fees and expenses) (2)	0.47%	1.81%
	Optional benefits available for an additional charge (for a single optional benefit, if elected)	0.15% (3)	0.20% (4)
	(1) Base Contract fees are expressed as a percentage of Separate Account assets, and include mortality and expense risk fees, which are charged as a percentage of Contract Value, and the annual Contract fee, which is a fixed dollar amount. (2) Portfolio fees and expenses are expressed as percentage the Portfolio’s net asset value and include management fees, distribution and/or service 12b-1 fees, and other expenses (before any waivers or expense reimbursement). (3) As a percentage of the average daily Contract Value invested in the Sub-accounts and in the Symetra Fixed Account (4) As a percentage of the average daily Contract Value invested in the Sub-accounts

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Because your Contract is customizable, the choices you make affect how much you will pay. To help you understand the cost of owning your Contract, the following table shows the lowest and highest cost you could pay each year, based on current charges. This estimate assumes that you do not take withdrawals from the Contract, which could add surrender charges that substantially increase costs.
Lowest Annual Cost: $1,711	Highest Annual Cost: $2,941
The Lowest Annual Cost shown above assumes the following: •Investment of $100,000 •5% annual appreciation •Least expensive combination of Contract Classes and Portfolio Company fees and expenses •No optional benefits •No sales charges •No additional purchase payments, transfers or withdrawals	The Highest Annual Cost shown above assumes the following: •Investment of $100,000 •5% annual appreciation •Most expensive combination of Contract Classes, optional benefits and Portfolio Company fees and expenses •No sales charges •No additional purchase payments, transfers or withdrawals

RISKS
Risk of Loss	You may lose money by investing in the Contract.	For more information, see PRINCIPAL RISKS OF INVESTING IN THE CONTRACT
Not a Short-Term Investment	The Contract is not a short-term investment and is not appropriate if you need ready access to cash. Withdrawal charges will reduce the value of your Contract if you withdraw money during the Accumulation Phase. The benefits of tax deferral and living benefit protections also mean the Contract is more beneficial to investors with a long time horizon. Tax penalties may apply to withdrawals taken before age 59 ½. Transfer limits and fees designed to deter marketing timing may apply under policies designed to deter frequent trading and market timing.	For more information, see PRINCIPAL RISKS OF INVESTING IN THE CONTRACT
Risks Associated with Investment Options	Investment in the Contract is subject to the risk of poor investment performance and can vary depending on the performance of the Portfolios available under the Contract. Each Portfolio has its own unique risks. You should review these Portfolios before making an investment decision.	For more information, see PRINCIPAL RISKS OF INVESTING IN THE CONTRACT
Insurance Company Risks	Investment in the Contract is subject to the risks related to Symetra Life Insurance Company. Any obligations, including obligations related to the Symetra Fixed Account, guarantees, and benefits provided for under the Contract are subject to our financial strength and claims-paying ability. More information about us, including our financial strength ratings, is available upon request by calling 1-800-796-3872, or visiting us at www.symetra.com/regulatoryreports.	For more information, see PRINCIPAL RISKS OF INVESTING IN THE CONTRACT

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RESTRICTIONS
Investments	You may allocate amounts under the Contract to one or more of the Sub-accounts available to you. Certain Sub-accounts are closed to new investors and only available to Contract Owners who have been continuously invested in them as of a certain date. Once a Contract Owner has transferred the entire value out of one of these closed Sub-accounts, the Sub-account is no longer available to the Contract Owner for investment. A transfer charge may apply for each transfer in excess of 12 transfers in a Contract Year. You may also allocate money to the Symetra Fixed Account, which credits guaranteed interest rates. We reserve the right to add, combine, restrict or remove any Sub-account available as an investment option under your Contract. We further reserve the right to restrict or remove the Symetra Fixed Account as an investment option available under the Contract.	For more information see INVESTMENT OPTIONS
Optional Benefits	The Guaranteed Minimum Death Benefit Annual Reset Rider (“GMDB - Annual Reset”) was only available for Contracts purchased between April 30, 2004, and April 30, 2010. The Earnings Enhancement Benefit Rider (“EEB”) was available only for non-qualified Contracts purchased between April 30, 2004, and April 30, 2010. For Contracts purchased on or after April 30, 2004, the maximum amount that we will add to your Contract to satisfy the guaranteed minimum death benefit, GMDB - Annual Reset, and EEB is limited to a total of $1 million.	For more information, see BENEFITS AVAILABLE UNDER THE CONTRACT

TAXES
Tax Implications	You should consult a competent tax professional about your individual circumstances to determine the tax implications of an investment in and purchase payments received under the Contract. There is no additional tax benefit if you purchased the Contract through a tax-qualified plan or individual retirement account (IRA). Access to amounts held in a qualified Contract may be restricted or prohibited. All distributions other than death benefits, including surrenders, withdrawals and loans taken or secured by the Contract will be subject to ordinary income tax, and may be subject to tax penalties.	For more information, see TAXES

CONFLICTS OF INTEREST
Investment Professional Compensation	Investment professionals who solicited sales of the Contracts receive a portion of the commission payable to the broker-dealer firm, depending on the agreement between the broker-dealer and the investment professional. We pay commissions as a percentage of Purchase Payments invested in the Contract. An investment professional may receive different compensation for selling different investment products and may have a financial incentive to offer or recommend one investment product over another.	For more information, see DISTRIBUTION
Exchanges	An investment professional may have a financial incentive to offer you a new contract in the place of a contract you already own. You should not exchange this Contract for a new one unless you determine, after comparing the features fees and risks of both contracts, that the exchange is preferable for you.	For more information, see DISTRIBUTION

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OVERVIEW OF THE CONTRACT

PURPOSE

The Contract is designed to assist individuals with their long-term retirement planning or other long-term needs through tax-deferred investments in a variety of investment options during the Accumulation Period. The Contract also provides for a guaranteed income or a death benefit. Through the annuitization feature, the Contract can supplement your retirement income by providing a stream of Income Payments. This Contract may be appropriate if you have a long investment time horizon. It is not intended for people who may need to make early or frequent withdrawals or intend to engage in frequent trading in the Portfolios.

Like many annuities, the Contract has an Accumulation Phase and an Income Phase. During the Accumulation Phase, you invest money in your Contract. During the Income Phase, the payee (you or someone you choose) will receive payments from your annuity. The amount of money you are able to accumulate in your Contract during the Accumulation Phase will determine the amount of payments during the Income Phase.

ACCUMULATION PHASE

During the Accumulation Phase, to help you accumulate assets, you can invest your money in:

•a variety of Sub-accounts. Each Sub-account purchases shares of a corresponding (mutual fund) Portfolio, each of which has its own investment strategies, investment adviser(s), expense ratios, and returns; and

•Symetra Fixed Account, which offers a guaranteed fixed interest rate.

Additional information about each of the Portfolios available under the Contract is provided in APPENDIX A: PORTFOLIOS AVAILABLE UNDER THE CONTRACT.

ANNUITY PAYMENTS (INCOME PHASE)

You can elect to annuitize your Contract and receive a fixed stream of Income Payments (sometimes called annuity payments) beginning on the Annuity Date. You can select from one of six payment options described in the section titled Annuity Payments. Switching to the Income Phase is irrevocable. Once you begin receiving annuity payments, you cannot switch back to the Accumulation Phase. During the Income Phase, you cannot add Purchase Payments, change or add an Annuitant, change the annuity option, or change between fixed and variable annuity payments.

Please note that if you annuitize, you may no longer withdraw money at will from your Contract. Also, during the Income Phase, all benefits, including the GMDB-Annual Reset rider and the EEB rider, will terminate and there will generally be no death benefit.

CONTRACT FEATURE

Withdrawals. You may withdraw money at any time during the Accumulation Phase unless you are restricted by requirements of a retirement plan. Each Contract Year, you can take up to 10% of the Contract Value without paying a contingent deferred sales charge. Amounts in excess of 10% may be subject to a contingent deferred sales charge. This charge varies based on the age of your Contract, not on the age of particular Purchase Payments. The charge is based upon the amount withdrawn and starts at 8% in the first Contract Year and decreases one percent each Contract Year until the ninth and later Contract Years when there is no charge. A separate withdrawal charge equal to the lesser of $25 or 2% of the amount withdrawn may apply to each withdrawal after the first in a Contract Year. You may have to pay income taxes and tax penalties on any money you take out.

Transfers. You can transfer between investment options up to 12 times per Contract Year free of a transfer charge. Your transfers may be limited, however, by market timing and excessive trading policies and procedures. A transfer charge equal to the lesser of $10 or 2% of the amount being transferred may apply to each additional transfer.

Transactions.  Under the following strategies, you can initiate transfers or withdrawals as desired or schedule them in advance. These are available at no additional charge.

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•Dollar Cost Averaging: You may elect to automatically transfer a set amount from any Sub-account or the Symetra Fixed Account to any of the other Sub-accounts monthly or quarterly. This feature attempts to achieve a lower average cost per unit over time.

•Appreciation or Interest Sweep: If your Contract Value exceeds $10,000, you may elect to have interest from the Symetra Fixed Account or earnings from the Fidelity VIP Government Money Market Portfolio automatically swept monthly, quarterly, or annually into any other Sub-account of your choice.

•Sub-account Rebalancing: If your Contract Value exceeds $10,000, you may elect to have each Sub-account rebalanced quarterly, semi-annually, or annually to maintain your specified allocation percentages. The minimum Contract Value requirement is waived if a Symetra Life approved asset allocation program was used for Sub-account rebalancing.

•Repetitive Withdrawals: You may elect to receive monthly, quarterly, or annual checks during the Accumulation Phase. Any money you receive may result in Contract charges, income taxes, and tax penalties.

Loans. Loans may be available for certain qualified Contracts. For any loans taken against the Contract Value, the loan net interest rate is an annual rate of 2.5% of the loan amount.

Death Benefit. If you die before moving to the Income Phase, we will pay a death benefit as described in the section titled Death Benefit. If available in your state and your Contract was purchased between April 30, 2004, and April 30, 2010, there were two optional death benefits available for selection. You may have elected none, one or both benefits at the time you purchased your Contract.

Guaranteed Minimum Death Benefit - Annual Reset Rider (“GMDB - Annual Reset”) resets the guaranteed minimum death benefit annually each Contract anniversary until the oldest Owner attains age 75. This rider was not available for Tax Sheltered Annuities or Deferred Compensation Plans.

Earnings Enhancement Benefit Rider (“EEB”) may add 25% or 40% (depending on the age of the oldest Owner on the issue date of the Contract) of your Contract’s earnings, if any, to the death benefit payable at your death. This rider was available only for non-qualified Contracts.

If you elected one or more of these optional death benefit riders, we will deduct an additional charge. This charge will vary depending upon which optional death benefit rider(s) you elected. If you elected the GMDB - Annual Reset rider, we will deduct an additional charge which is equal, on an annual basis, to 0.20% of the average daily net assets of each Sub-account. If you elected the EEB rider, we will deduct an additional charge which is equal, on an annual basis, to 0.15% of the average daily net assets of each Sub-account and the Symetra Fixed Account.

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FEE TABLE

The following tables describe the fees and expenses you will pay when owning and surrendering or making withdrawals from the Contract. Please refer to your Contract data page for information about the specific fees you will pay each year based on the options you have elected.

The first table describes the fees and expenses that you will pay at the time that you surrender or make withdrawals from the Contract, or transfer Contract Value between investment options. State premium taxes may also be deducted.

TRANSACTION EXPENSES	MAXIMUM AMOUNT DEDUCTED	CURRENT AMOUNT DEDUCTED
CONTINGENT DEFERRED SALES CHARGE (1) (As a percentage of the amount withdrawn)	8%	Year 1 ...........................   8% Year 2 ........................... 7% Year 3 ...........................   6% Year 4 ...........................   5% Year 5 ...........................   4% Year 6 ...........................   3% Year 7 ...........................   2% Year 8 ...........................   1% Year 9+..........................   0%
WITHDRAWAL CHARGE (2) (Assessed for each withdrawal after the first withdrawal in a Contract Year)	$25	$25 or 2% of amount withdrawn whichever is less
TRANSFER CHARGE (Assessed for each transfer in excess of 12 transfers in a Contract Year)	$10	$10 or 2% of amount transferred whichever is less
)

(1) We eliminate this charge for individual retirement annuities purchased with rollovers of $1,000 or more from employer-sponsored plans that own group variable annuities issued by us.

(2) The withdrawal charge is assessed in addition to any applicable contingent deferred sales charge.

The next table describes the fees and expenses that you will pay each year during the time that you own the Contract (not including Portfolio Company fees and expenses). If you chose to purchase an optional benefit, you pay additional charges, as shown below.

ANNUAL CONTRACT CHARGES	AMOUNT DEDUCTED
(Not Including Portfolio Operating Fees And Expenses)	MAXIMUM GUARANTEED CHARGE	CURRENT CHARGE
ADMINISTRATIVE EXPENSES (1)	$50 (2)	$30
BASE CONTRACT CHARGES (As a percentage of average daily net assets of each Sub-Account)	1.40%	1.40%
CHARGES FOR OPTIONAL FEATURES (For Contracts Purchased Prior to May 1, 2010)
GUARANTEED MINIMUM DEATH BENEFIT – ANNUAL RESET (As a percentage of the average daily Contract Value invested in the Sub-accounts)	0.20%	0.20%
EARNINGS ENHANCEMENT BENEFIT (As a percentage of the average daily Contract Value invested in the Sub-accounts and in the Symetra Fixed Account)	0.15%	0.15%

(1) We do not deduct this charge if the Contract Value is at least $50,000 when the deduction is to be made.

(2) The maximum guaranteed charge for Contracts issued in 2005 and earlier may be $35 depending on your state of residence. Please see your Contract for more information.

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The Total Annual Portfolio Operating Expenses table shows the lowest and highest total operating expenses charged by the Portfolio companies that you may pay periodically during the time you own the Contract. A complete list of Portfolios available under the Contract, including annual expenses may be found under APPENDIX A: PORTFOLIOS AVAILABLE UNDER THE CONTRACT.

ANNUAL PORTFOLIO COMPANY EXPENSES	Minimum	Maximum
Expenses deducted from Portfolio Company assets, including management fees, distribution and/or service (12b-1) fees, and other expenses,	0.47%	1.81%

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EXAMPLES

These examples are intended to help you compare the cost of investing in the Contract with the cost of investing in other variable annuity contracts. These costs include transaction expenses, annual Contract expenses, and Annual Portfolio Company expenses.

The Example assumes that you invest $100,000 in the Contract for the time periods indicated. The Example also assumes that your investment has a 5% return each year and assumes the most expensive combination of Annual Portfolio Expenses and optional benefits available for an additional charge. Although your actual costs may be higher or lower, based on these assumptions your costs would be:

	If You Surrender Your Contract At The End of Each Time Period				If The Contract Is Not Surrendered or Is Annuitized
	1 Year	3 Years	5 Years	10 Years	1 Year	3 Years	5 Years	10 Years
With All Riders	$11,714(1)	$17,209(1)	$22,794(1)	$38,291(1)	$3,610	$10,972	$18,527	$38,291

(1) The Riders were only available for Contracts purchased between April 30, 2004, and April 30, 2010. Those Contracts are out of the Surrender Charge Period.

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PRINCIPAL RISKS OF INVESTING IN THE CONTRACT

The variable annuity Contract described in this prospectus is no longer available for sale. However, we do continue to administer the Contracts and you may continue making Purchase Payments to your existing Contract.

Risk of Loss. Variable annuities involve risks, including possible loss of principal. Your losses could be significant. This Contract is not a deposit or obligation of, or guaranteed or endorsed by, any bank. This Contract is not federally insured by the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other agency.

Short-Term Investment Risk. The Contract is not suitable if you are looking for a short-term investment or if you cannot accept the risk of getting back less money than you put in. The Contract is designed to help you invest on a tax-deferred basis and meet long-term financial goals, such as retirement funding. The Contract provides for guaranteed income and death benefits, subject to applicable terms and conditions.

Risk of Limited Access to Contract Value. This Contract may not be the right one for you if you need to withdraw money for short-term needs, because withdrawal charges and tax penalties for early withdrawal may apply. A contingent deferred sales charge may be assessed on withdrawals, including partial withdrawals, in excess of your free withdrawal amount. In addition, we may deduct a separate withdrawal charge equal to $25 or 2% of the amount withdrawn whichever is less, for each withdrawal after the first withdrawal in a Contract Year. All distributions other than death benefits, including surrenders, withdrawals and loans taken or secured by the Contract will be subject to ordinary income tax, and may be subject to tax penalties. You should consult your tax professional to determine whether the use of the Contract within a qualified retirement plan is an appropriate investment for you. Access to amounts held in a qualified Contract may be restricted or prohibited.

Investment Risk. The Contract is called a variable annuity because you can choose among the available Sub-accounts. Each Sub-account invests in a corresponding Portfolio. Depending upon market conditions, You can make or lose Contract Value in any of these Sub-accounts; your Contract Value will increase or decrease as a result of investment performance. If investment performance is very poor, you could lose everything that you invest. The investment performance of the Sub-account(s) you select also affects the amount of the annuity payments available at the time of annuitization and any variable annuity payments.

The value of your Contract will vary up or down depending upon the investment performance of the Sub-accounts you choose. Past performance is not a guarantee of future results.

Election of Optional Benefit Risk . There were two optional benefits available to you when you purchased the Contract. There is a risk that you may not have chosen the benefit or benefits that are best suited for you based on your present or future needs and circumstances. In addition, if you elected an optional benefit and do not use it, or if the contingencies upon which the benefit depend never occur, you will have paid for a benefit that did not provide a financial return. There is also a risk that any financial return of an optional benefit, if any, will ultimately be less than the amount you paid for the benefit.

Risk of Limits Imposed on Transfers. We currently charge $10 or 2% of the amount transferred whichever is less per transfer. We have adopted procedures to limit excessive transfer activity. In addition, each Portfolio may restrict or refuse certain transfers among, or purchases of shares in their Portfolios as a result of certain market timing activities. You should read each Portfolio’s prospectus for more details. The minimum amount you can transfer out of any investment option at one time is $500, or the entire value of the investment option if less. If a transfer will result in the remaining balance in an investment option being less than $500, you must transfer the entire amount out of the investment option. The minimum you can transfer into any investment option is $50. In addition to this $500 minimum, transfers out of the Symetra Fixed Account are limited to a maximum of 10% of the Symetra Fixed Account value per Contract Year.

Risks Associated with Symetra Life. Investment in the Policy is subject to the risks related to Symetra Life. Any obligations, including obligations related to the Symetra Fixed Account, guarantees, and benefits provided for under the Policy are subject to Our financial strength and claims paying ability. The assets of Our General Account support Our insurance and annuity obligations and are subject to Our general liabilities from business operations and to claims by Our creditors. Policy Value in the Fixed Account, plus any guarantees under the Policy that exceed Your Policy Value (such as those that may be associated with the Death Benefit), are paid from Our General Account. We maintain a minimum amount of capital in excess of assets that offset reserves, which acts as a cushion in the event that we suffer financial impairment, based on certain risks in Our operations. For the Company, such risks include those associated with losses that We may incur as the result of defaults

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on the payment of interest or principal on assets held in Our General Account, which include bonds, loans secured by mortgages, and equity securities, as well as the loss in value of these investments resulting from a loss in their market value.

Risk of Adverse Tax Consequences. You should consult your tax professional to determine whether the use of the Contract within a qualified retirement plan is an appropriate investment for you. Access to amounts held in a qualified Contract may be restricted or prohibited.

All distributions other than death benefits, including surrenders, withdrawals and loans taken or secured by the Contract will be subject to ordinary income tax, and may be subject to tax penalties.

SYMETRA LIFE, SYMETRA SEPARATE ACCOUNT C & THE GENERAL ACCOUNT

SYMETRA LIFE

Symetra Life Insurance Company, 777 108th Ave NE, Suite 1200, Bellevue, WA, is the depositor of Symetra Separate Account C.

SEPARATE ACCOUNT

We established Symetra Separate Account C (“Separate Account”) to hold the assets that underlie Contract Values invested in the Sub-accounts. The Separate Account was registered with the SEC as a unit investment trust under the Investment Company Act of 1940, as amended on January 28, 1994.

The assets in the Separate Account are the property of Symetra Life. However, assets in the Separate Account that are attributable to Contracts are not chargeable with liabilities arising out of any other business we may conduct. Income, gains and losses (realized and unrealized), resulting from assets in the Separate Account are credited to or charged against the Separate Account without regard to other income, gains or losses of Symetra Life. Promises we make in the Contract are general corporate obligations of Symetra Life and are not dependent on assets in the Separate Account.

We reserve the right to combine the Separate Account with one or more of our other separate accounts or to deregister the Separate Account under the 1940 Act if such registration is no longer required.

CHANGES TO THE SEPARATE ACCOUNT

Where permitted by applicable law, we reserve the right to make certain changes to the structure and operation of the Separate Account. We will not make any such changes without receiving any necessary approval of the SEC and applicable state insurance departments. We will notify you of any changes in writing. These changes include, among others, the right to:

•Transfer assets supporting the Contracts from one Sub-account to another or from the Separate Account to another separate account;

•Combine the Separate Account with other separate accounts, and/or create new separate accounts;

•Deregister the Separate Account, or operate the Separate Account as a management investment company, or as any other form permitted by law;

•Manage the Separate Account under the direction of a committee at any time;

•Make any changes required by applicable law or regulation; and

•Modify the provisions of the Contract to reflect changes to the Sub-accounts and the Separate Account and to comply with applicable law.

Some, but not all, of these future changes may be the result of changes in applicable laws or interpretations of law. We reserve the right to make other structural and operational changes affecting the Separate Account.

INVESTMENT OPTIONS

SYMETRA FIXED ACCOUNT

The Contract offers a fixed account which credits interest rates that are set and guaranteed by Symetra Life. At the time you purchased the Contract, you could have chosen to allocate your Purchase Payment to any of the following Initial Guaranteed

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Interest Periods: 1-year, 3-year and 5-year. Different interest rates may apply to each of the initial guaranteed periods. Only initial Purchase Payments of $1,000 or more could be made to the 3-year and 5-year Initial Guaranteed Interest Periods.

Each Purchase Payment will be credited with the interest rate established for the date that we receive the Purchase Payment. This rate will apply to the Purchase Payment on the date we receive it and continue for the guaranteed period chosen. If you make additional Purchase Payments to the 1-year Initial Guaranteed Interest Period, each will be credited with the applicable interest rate from the date we receive it to the end of the guaranteed period. Once the guaranteed period is over, we can adjust the interest rate. Adjusted rates will apply to Purchase Payments and their credited interest for at least 12 months, when the rate can be adjusted again.

Different interest rates may apply to each of your Purchase Payments depending on the interest rate established for the date we receive the Purchase Payment and any subsequent rate adjustments. Annual effective interest rates will never be less than the rate guaranteed in your Contract or state non-forfeiture law at the time we issue the Contract. You bear the risk that they will never be greater than the guaranteed amount. We reserve the right to change the guaranteed minimum interest rate for newly issued Contracts subject to applicable state law.

Payments from the Symetra Fixed Account are also subject to minimum amounts required by state law. These minimum amounts only apply upon annuitization from the Symetra Fixed Account, payment of a death benefit upon death of the Owner, or a total withdrawal from the Symetra Fixed Account. We guarantee that if one of these events occurs, then the proceeds from the Symetra Fixed Account (the amount applied to annuity payments or paid for a total withdrawal or death benefit) will be at least equal to the minimums required by state law. If necessary to meet this minimum, charges will be waived.

We are not required to register the Symetra Fixed Account or any interests therein, with the SEC. For this reason, SEC staff has not reviewed disclosure relating to the Symetra Fixed Account.

For more information regarding the Symetra Fixed Account, please see your Contract. For more information regarding the limitations on transfers to and from the Symetra Fixed Account, please see the section titled “Transfers.”

VARIABLE INVESTMENT OPTIONS

Each Sub-account purchases the shares of one underlying Portfolio that has its own investment objective. The Portfolios are not offered directly to the public but are available to life insurance companies as investment options for variable annuity and variable life insurance Contracts. Symetra Life is not recommending a particular Portfolio or offering investment advice.

A description of the Portfolios available under the Contract, including each Portfolio’s name, type, investment advisor and any sub-advisor, current expenses and performance is available under APPENDIX A: PORTFOLIOS AVAILABLE UNDER THE CONTRACT.

You can also find more detailed information about the Portfolios in the Portfolio prospectuses. You can obtain free copies of the Portfolio prospectuses by contacting us at 1-800-796-3872 or online at www.symetra.com/regulatoryreports. You should read the Portfolio prospectuses carefully.

AVAILABILITY OF THE SUB-ACCOUNTS

Certain Sub-accounts are closed to new investors and only available to Contract Owners who have been continuously invested in them as of a certain date. Once a Contract Owner has transferred the entire value out of one of these closed Sub-accounts, the Sub-account is no longer available to the Contract Owner for investment.

CHANGES TO THE INVESTMENT OPTIONS

We reserve the right to add, combine, restrict, or remove any Sub-account as an investment option under your Contract. If any shares of the Sub-accounts are no longer available, or if in our view no longer meet the purpose of the Contract, it may be necessary to substitute shares of another Sub-account. New or substitute Sub-accounts may have different fees and expenses and their availability may be limited to certain classes of purchasers. It may also be necessary to close Sub-accounts to allocations of new Purchase Payments by existing or new Contract Owners and we reserve the right to do so at any time and in our discretion. We further reserve the right to restrict or remove the Symetra Fixed Account as an investment option available under the Contract. We will seek prior approval of the SEC (to the extent required by law) and give you notice before making any changes to the investment options.

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VOTING RIGHTS

We are the legal owner of the Portfolios’ shares. However, when a Portfolio solicits proxies in connection with a shareholder vote, we are required to ask you for instructions as to how to vote those shares. The Portfolio shares are voted in accordance with the instructions we receive from you. We vote Portfolio shares for which no timely instructions are received in proportion to the voting instructions that are received with respect to the Separate Account. For this reason, a small number of contract owners may control the outcome of a vote. Should we determine that we are no longer required to comply with the above, we will vote the shares in our own right.

You have no voting rights with respect to values in the Symetra Fixed Account.

CHARGES AND EXPENSES

There are charges and other expenses associated with the Contract that reduce the return on your investment in the Contract. These charges and expenses are:

INSURANCE CHARGES

Each day we make deductions for our insurance charges. We do this as part of our calculation of the value of Accumulation Units and Annuity Units. Insurance charges include the mortality and expense risk charge and the asset related administration charge and the optional benefit charges described below.

Mortality and Expense Risk Charge.  This charge is equal, on an annual basis, to 1.25% of the average daily net assets of each Sub-account you are invested in. This charge compensates us for the mortality and expense risks we have under all Spinnaker Contracts. Our mortality risk arises from our obligations to make annuity payments for the life of the Annuitant and to pay death benefits prior to the Annuity Date. Our expense risks under the Contracts include the risk that the current charges will not be sufficient in the future to cover the cost of administering the Contract. If the charges under the Contract are not sufficient, then we will bear the loss. If the charges are more than sufficient, we will retain the excess and may use it for any purpose, including additional distribution expenses. We expect to profit from this charge. The rate of the mortality and expense risk charge will not be increased for the life of the Contract.

Asset Related Administration Charge.  This charge is equal, on an annual basis, to 0.15% of the average daily net assets of each Sub-account. Since this charge is an asset-based charge, the amount of the charge associated with your particular Contract may have no relationship to the administrative costs actually incurred. This charge, together with the annual administration maintenance charge (see below), is for all the expenses associated with Contract administration. Some of these expenses are: confirmations and statements; maintenance of Contract records; personnel costs; legal and accounting fees; filing fees; and computer and system costs. If this charge and the annual administration maintenance charge are not enough to cover the costs of the Contract in the future, we will bear the loss. The rate of the asset related administration charge will not be increased for the life of the Contract.

OPTIONAL BENEFIT CHARGES

If your Contract was purchased between April 30, 2004 and April 30, 2010, you may have elected optional benefits which require additional charges. Those optional benefits are GMDB-Annual Reset and EEB.

Guaranteed Minimum Death Benefit - Annual Reset.  If you elected the GMDB - Annual Reset rider, we will deduct an additional charge which is equal, on an annual basis, to 0.20% of the average daily net assets of each Sub-account you are invested in. This charge is for the cost and risk associated with offering the GMDB - Annual Reset rider. We stop deducting this charge on the date you switch to the Income Phase or when the death benefit is paid, whichever occurs first. GMDB - Annual Reset was only available for non-qualified Contracts, IRAs, and Roth IRAs. This benefit was available only between April 30, 2004 and April 30, 2010 and its election is irrevocable.

Earnings Enhancement Benefit.  If you elected the EEB rider, we will deduct an additional charge which is equal, on an annual basis, to 0.15% of the average daily net assets of each Sub-account and the Symetra Fixed Account. The charge is for the cost and risk associated with offering the EEB option. We stop deducting this charge on the date you switch to the Income Phase or when the death benefit is paid, whichever occurs first. EEB was only available for non-qualified Contracts. This benefit was available only between April 30, 2004 and April 30, 2010 and its election is irrevocable.

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ANNUAL ADMINISTRATION MAINTENANCE CHARGE

During the Accumulation Phase, we will deduct a $30 annual administration maintenance charge from your Contract on the last day of each Contract Year and if you withdraw the entire Contract Value. This charge is for administrative expenses and may be changed but may never exceed $50 per Contract Year. If your Contract was purchased in 2005 or earlier, the maximum charge may be $35 per Contract Year. Please see your Contract for more information. We will not deduct this charge if your Contract Value is at least $50,000 when the deduction is to be made.

During the Income Phase we will not deduct this charge unless you have chosen Payments Based on a Number of Years as your annuity option and your Contract Value was less than $50,000 when annuity payments began.

LOAN INTEREST RATES

The loan interest spread is the difference between the amount of interest we charge you for a loan and the amount of interest we credit to your loan amount. This results in a net loan interest rate of 2.5% of the loan amount.

CONTINGENT DEFERRED SALES CHARGE

A contingent deferred sales charge may be assessed on withdrawals, including partial withdrawals, in excess of your free withdrawal amount that is described under the section titled “Access to Your Money.” This charge is for expenses incurred in connection with the promotion, sale, and distribution of the Contracts. If the contingent deferred sales charge is insufficient, excess amounts resulting from the mortality and expense risk charge may be used to recover these expenses.

The Contract bases the contingent deferred sales charge on the age of your Contract, not on the length of time each Purchase Payment is in your Contract. Subsequent Purchase Payments do not begin a new contingent deferred sales charge period. The contingent deferred sales charge (“CDSC” in the table below) is stated as a percentage of the amount withdrawn. It starts at 8% in the first Contract Year and declines one percent each Contract Year as follows:

Contract Year	1	2	3	4	5	6	7	8	9+
CDSC	8%	7%	6%	5%	4%	3%	2%	1%	0%

Unless you tell us otherwise, when you make a partial withdrawal the contingent deferred sales charge is deducted from the remaining Contract Value.

We will not assess the contingent deferred sales charge for:

•annuity payments;

•repetitive withdrawals taken over life expectancy;

•eligible healthcare confinement withdrawals;

•death benefits; and

•premium taxes.

We eliminated the contingent deferred sales charge for individual retirement annuity Contracts purchased with rollovers of $1,000 or more from employer-sponsored plans that own group variable annuities issued by us. We may have reduced or eliminated the amount of the contingent deferred sales charge when the Contract was sold under other circumstances which reduced our sales expense. See the section titled “Other Information.”

FREE WITHDRAWAL AMOUNT

Your Contract has a free withdrawal amount. There is no contingent deferred sales charge on the first 10% of your Contract Value withdrawn in a Contract Year. We determine whether you have withdrawn more than 10% of the Contract Value at the time of withdrawal. If you take more than one withdrawal in a Contract Year, all previous withdrawals in the Contract Year are added to the current Contract Value to determine whether more than 10% of the Contract Value has been withdrawn in that year. In addition, there is no withdrawal charge on the first withdrawal you make in a Contract Year, but the contingent deferred sales charge may apply.

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WAIVER OF SURRENDER CHARGES UPON HEALTHCARE CONFINEMENT

If approved in your state, there is no contingent deferred sales charge on withdrawals you make while you are confined in an eligible healthcare facility or within 60 days after your release. In order to be eligible for this waiver, we must receive proof that your confinement has continued for 30 or more consecutive days (60 or more consecutive days for Contracts issued prior to April 30, 2004, if approved in your state) and that your confinement began after your Contract Date. If you were confined to a healthcare facility on the Contract Date, you are not eligible for this waiver of contingent deferred sales charges until after the first Contract Year. Please see your Contract for more information.

WITHDRAWAL CHARGE

We may deduct a separate withdrawal charge equal to $25 or 2% of the amount withdrawn whichever is less, for each withdrawal after the first withdrawal in a Contract Year. Unless you tell us otherwise, this charge is deducted from the remaining Contract Value.

We will not deduct this charge for annuity payments, repetitive withdrawals, or if you withdraw the entire Contract Value. See the section titled “Access To Your Money” for a discussion of repetitive withdrawals.

TRANSFER CHARGE

You can make 12 free transfers every Contract Year. If you make more than 12 transfers in a Contract Year, we may deduct a transfer charge equal to $10 or 2% of the amount that is transferred whichever is less. The transfer charge is deducted from the Sub-account that you transfer your funds from. If you transfer the entire balance from an investment option, the transfer fee is deducted from the amount transferred.

If the transfer is part of dollar cost averaging, appreciation sweep, interest sweep, or Sub-account rebalancing, it will not be counted as part of your 12 free transfers.

PREMIUM TAXES

States and other governmental entities (e.g., municipalities) may charge premium taxes. These taxes generally range from 0% to 3.5%, depending on the state, and are subject to change. Some states charge for these taxes at the time each Purchase Payment is made. In this case, Purchase Payments, as discussed in this prospectus, may reflect a deduction for the premium tax. Other states charge for these taxes when annuity payments begin. We may make a deduction from your Contract for the payment of the premium taxes assessed in connection with your Contract as stated in your Contract.

INCOME OR OTHER TAXES

Currently we do not pay income or other taxes on earnings attributable to your Contract. However, if we ever incur such taxes, we reserve the right to deduct them from your Contract. If we choose to deduct these income or other taxes, we will notify you in writing.

PORTFOLIO EXPENSES

There are deductions from and expenses paid out of the assets of the various Portfolios for investment management fees and other operating expenses the Portfolios incur. These expenses are summarized in the fee table of this prospectus. For more detailed information, you should refer to the Portfolio prospectuses, which, if not accompanying this prospectus, are available upon request.

REDUCTION OF CHARGES OR ADDITIONAL AMOUNTS CREDITED

Under some circumstances we expected to experience lower costs or higher revenues associated with issuing and administering certain Contracts. For example, sales expenses are expected to be less when Contracts are sold to a large group of individuals. In these situations, we may have lowered the administrative costs due to the ability to centralize communications with one large group rather than individualized communications. Thus, administrative tasks, such as the processing forms and handling of Purchase Payments, withdrawals and surrenders may be administered more efficiently. Under such circumstances we may pass a portion of these anticipated savings on to you by reducing Owner transaction charges (including the contingent deferred sales charge) or crediting additional Symetra Fixed Account interest. Any reduction of these charges or credit of additional interest was determined by us after examination of all the relevant factors such as the size and type of group to which sales were to be made, the total amount of Purchase Payments to be received, any prior or existing relationship with us, and other circumstances which reduced our sales and other expenses.

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We may also have taken such action in connection with Contracts sold to our officers, directors, and employees and their family members, employees of our affiliates and their family members, and registered representatives and employees of broker-dealers that had a current selling agreement with us when the Contract was issued. In each circumstance such actions were reasonably related to the savings or revenues anticipated and were applied in a non-discriminatory manner. These actions may be withdrawn or modified by us at any time.

COMMISSIONS PAID TO BROKER DEALERS

Registered representatives who solicited sales of the Contracts may receive a portion of the commission payable to the broker-dealer firm, depending on the agreement between the broker-dealer and the registered representative. If you would like information about what your registered representative and his or her broker-dealer received in connection with the purchase of your Contract, please ask your registered representative.

We generally pay commissions as a percentage of Purchase Payments invested in the Contract. At the option of the broker-dealer, we may pay lower compensation on Purchase Payments but pay a periodic asset-based commission beginning after the first Contract Year. The amount and timing of the commission may differ depending on the agreement between us and the broker-dealer but is not expected to be more than 6.5% of Purchase Payments and up to 0.50% annually of the average Contract Value (if asset-based commissions are paid to the broker-dealer). We may also pay additional commission if you choose to receive your Contract Value in the form of an annuity option. We pay a commission of up to 1.25% of the Contract Value applied to purchase a fixed annuitization option. In addition, allowances, and bonuses may be paid to broker-dealers and/or other distributors of the Contracts, and we may also provide non-cash compensation, including conferences and seminars, and items of small value, such as promotional gifts, meals or tickets to sporting or entertainment events. A bonus dependent upon persistency is one type of bonus that may be paid.

GENERAL DESCRIPTION OF THE CONTRACT

OWNER

The Owner (“you”) is as shown on the Contract application, unless changed. You, as the Owner, may exercise all ownership rights under the Contract. The Contract must be issued prior to the Owner reaching the maximum issue age as stated in the Contract. In certain situations, we may preserve a younger age on your Contract.

A non-qualified Contract can be owned by joint Owners. Each joint Owner has equal ownership rights and must exercise those rights jointly, unless both joint Owners direct us otherwise in writing. Naming joint Owners can have a negative impact on the death benefit. See the Section titled “Death Benefit” for more information.

An Owner who is a non-natural person (e.g., a corporation or a trust) may not name a joint Owner. You may change the Owner or joint Owner by sending us a signed and dated request. If you designate someone else as Owner, that person must not have been older than the maximum issue age on the Contract Date. Unless you specify otherwise, a change in ownership is effective as of the date you signed the notice of change, subject to any payments made or actions we may take prior to receipt of the notice.

Use care when naming joint Owners and Beneficiaries and consult your agent or other advisor if you have questions.

ANNUITANT

The Annuitant(s) is/are the person(s) on whose life/lives annuity payments are based. You are the Annuitant unless you designate someone else before the Annuity Date. If you designate someone else as Annuitant, that person must not be older than the maximum issue age as stated in the Contract on the Contract Date. Owners who are non-natural persons (e.g., corporations or trusts) may not change the Annuitant.

BENEFICIARY

The Beneficiary is the person or entity that is entitled to receive a benefit as described in the section titled “Death Benefit.” You initially name the Beneficiary on your Contract application. You may change the Beneficiary at any time by sending us a signed and dated request. You may designate an irrevocable Beneficiary on your Contract. An irrevocable Beneficiary must consent in writing to any change. A new Beneficiary designation revokes any prior designation and is effective when signed by you. We are not responsible for the validity of any Beneficiary designation nor for any actions we may take prior to receiving and recording a Beneficiary change. In the case of certain Contracts issued in connection with retirement plans, the retirement plan

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may prescribe certain limitations on the designation of a Beneficiary. Since Beneficiaries have no rights under your Contract until your death, they should notify us of a death as promptly as possible.

MINIMUM VALUE REQUIREMENTS

If, after taking a withdrawal, the remaining Contract value would be less than the minimum Contract Value (if any) stated in your Contract, you will be forced to withdrawal the entire remaining Contract Value and your Contract will terminate. However, negative investment performance alone will not cause a forced withdrawal. We may waive this minimum balance for Contracts issued in connection with employer sponsored retirement plans.

ASSIGNMENT

You can assign the Contract unless restricted by applicable law; however, the new Owner cannot be older than the maximum issue age on the Contract Date. Assignments may result in current taxation and, if you are under age 591/2, a 10% tax penalty. If this Contract is assigned, we will treat it as a change of ownership and all rights will be transferred. We are not bound by any assignments unless in writing. Assignments are effective on the date you sign the notice of assignment, subject to all payments made and actions we take before we receive a signed copy of the assignment form at our Account Maintenance address. We are not liable for payments made prior to receipt of an effective assignment. We are not responsible for the validity of any assignments, tax consequences, or actions we may take based on an assignment later determined to be invalid.

If your Contract is an IRA or otherwise issued in connection with a tax-qualified retirement plan, your ability to assign the Contract may be limited.

EXCHANGES

A registered representative may have a financial incentive to offer you a new contract in the place of one you already own. You should carefully consider whether an exchange is appropriate for you by comparing the features and other guarantees that are provided by the contract you currently own to the benefits and guarantees provided by the new contract being offered. You should also compare the fees and charges of your current contract to the new contract being offered as they may be higher than your current contract.

GENERAL ACCOUNT

The Fixed Account is part of Symetra Life’s General Account. The General Account is made up of all of Symetra Life’s assets other than those attributable to separate accounts. Symetra Life exercises sole discretion over the investment of General Account assets and bears the associated investment risk. You will not share in the investment experience of General Account assets.All of the assets of the General Account are chargeable with the claims of any of our contract owners as well as our creditors and are subject to the liabilities arising from any of our other business. Any guarantees provided for under the Contract are backed by our financial strength and claims paying ability. You must look to the strength of the insurance company with regard to such guarantees.

The assets of our General Account support our insurance and annuity obligations and are subject to our general liabilities from business operations and to claims by our creditors. Contract Value in the Fixed Account, plus any guarantees under the Contract that exceed your Contract Value (such as those that may be associated with the Death Benefit), are paid from our General Account. Symetra Life complies with State insurance laws and regulations require that life insurance companies, including us, to hold assets in its General Account equal to a special liability called “reserves” which, under such laws and regulations, are considered by the insurance regulators to be sufficient for Symetra Life to meet its contractual obligations to contract owners. State insurance regulators also require life insurance companies to maintain a minimum amount of capital in excess of assets that offset reserves, which acts as a cushion in the event that the insurer suffers financial impairment, based on the specific risks in the insurer’s operations. For Symetra Life, such risks include those associated with losses that we may incur as the result of defaults on the payment of interest or principal on assets held in our General Account, which include bonds, loans secured by mortgages, and equity securities, as well as the loss in value of these investments resulting from a loss in their market value.

We are not required to register the Symetra Fixed Account or any interests therein, with the SEC. For this reason, SEC staff has not reviewed disclosure relating to the Symetra Fixed Account.

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PURCHASE PAYMENTS

We no longer sell the Spinnaker Variable Annuity. However, we do continue to administer the Contracts and you may continue making additional Purchase Payments to your existing Contract. Any single Purchase Payment in excess of $1 million requires our prior approval.

ADDITIONAL PURCHASE PAYMENTS

Additional Purchase Payments of $250 or more may be made at any time during the Accumulation Phase by sending them to our Account Maintenance address and should include your account number. Each non-qualified Purchase Payment made through Systematic Investing must be at least $100. If you purchased a qualified Contract, any subsequent Purchase Payments must be $30 or more, unless your retirement plan has a different requirement. Additional Purchase Payments made by check, mailed to our Account Maintenance address and received with all the information we need to process them are credited to your Contract on the same Business Day as received by us. However, if your Purchase Payment is received at Symetra Life after the close of the NYSE, any portion to be allocated to the Sub-accounts will be credited the next Business Day.

Processing of Purchase Payments may be delayed by circumstances outside our control - for example, if your registered representative does not forward your Purchase Payments to us promptly. In addition, if your Purchase Payment is received without the necessary information we need to process it, processing delays will occur as we attempt to contact you to get the necessary information. If we cannot get all the required information within five Business Days, we will either return your Purchase Payment or get your or your registered representative’s permission to keep it until we have received the necessary information. However, if the necessary information is not received after 15 Business Days, we will return the Purchase Payment. In addition, if we receive a Purchase Payment that is to be allocated to the Symetra Fixed Account and we are not able to invest the money such that we can credit at least the minimum guaranteed interest rate, we reserve the right to reject the portion of the Purchase Payment that was to be allocated to the Symetra Fixed Account.

We will not deem Purchase Payments sent to any other office besides our Account Maintenance address as received by us until such Purchase Payments reach our Account Maintenance address and are picked up and delivered to our processing office.

We reserve the right to refuse any Purchase Payment that is over $1 million dollars; that does not meet our minimum requirements; that is received without the necessary information to process the payment; that is made for market timing purposes; or is otherwise contrary to law for Symetra Life to accept. If we refuse a Purchase Payment, we will return it to you within five Business Days.

ALLOCATION OF PURCHASE PAYMENTS

You told us how to apply your initial Purchase Payment by specifying your desired allocations on the Contract application. Unless you tell us otherwise, subsequent Purchase Payments will be allocated in the same proportion as your most recent Purchase Payment (unless that was a Purchase Payment you directed us to allocate on a one-time-only basis). You may change the way subsequent Purchase Payments are allocated by providing us with written instructions, by telephoning us, or, if available, electronically by the Internet if we have your written authorization to accept telephone or Internet instructions. See the Section titled “Transfers.”

Once we receive a Purchase Payment, the portion to be allocated to the Symetra Fixed Account is credited as of the day it is received. The portion to be allocated to the Sub-accounts is effective and valued as of the next close of the NYSE. This is usually 4:00 p.m. Eastern time. If for any reason the NYSE is closed when we receive your Purchase Payment, it will be valued as of the close of the NYSE on its next regular Business Day.

ACCUMULATION UNITS

The value of the variable portion of your Contract will go up or down depending upon the investment performance of the Sub-account(s) you choose. In order to keep track of this, we use a unit of measure called an Accumulation Unit. During the Income Phase, we call the units of measure Annuity Units.

We calculate the value of an Accumulation Unit for each Sub-account as of the time the NYSE closes each day. To determine the current Accumulation Unit value, we take the prior day’s Accumulation Unit value and multiply it by the Net Investment Factor for the current day. Changes in the Accumulation Unit value reflect the investment performance of each Sub-account as

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well as the deductions for insurance and other charges. The value of an Accumulation Unit will usually go up or down from day to day.

The Net Investment Factor is used to measure the daily change in Accumulation Unit value for each Sub-account. The Net Investment Factor equals:

1.the net asset value per share of the applicable Portfolio at the end of the current day plus the per share amount of any dividend or income distributions made by the Portfolio that day; divided by

2.the net asset value per share of the Portfolio at the end of the prior day plus the per share amount of any dividend or income distributions made by the Portfolio that day; minus

3.the daily insurance charges and any taxes Symetra Life may incur on earnings attributable to the applicable Contracts, expressed as a percentage of the total net assets of the Sub-account.

When you make Purchase Payments or transfers into a Sub-account, we credit your Contract with Accumulation Units. We determine the number of Accumulation Units to credit by dividing the amount of the Purchase Payment or amount transferred into a Sub-account by the value of the Accumulation Unit for that particular Sub-account. Similarly, when you request a withdrawal or a transfer of money from a Sub-account, we deduct from your Contract Accumulation Units representing the withdrawal amount.

Example: Assume that on Monday we receive a $1,000 Purchase Payment from you before the NYSE closes. You have told us you want this to go to the Fidelity VIP Growth & Income Portfolio. When the NYSE closes on that Monday, we determine that the value of an Accumulation Unit for the Fidelity VIP Growth & Income Portfolio is $34.12. We then divide $1,000 by $34.12 and credit your Contract on Monday night with 29.31 Accumulation Units for the Fidelity VIP Growth & Income Portfolio.

ASSET ALLOCATION MODELS

Symetra Life no longer makes asset allocation models available for use by Contract Owners. However, in the past, you may have chosen an asset allocation model then available for use. Pursuant to an agreement with Symetra Life, a third party determined the composition of each model and was compensated by Symetra Life for doing so. When you elected a model, your Contract Value was reallocated to match the allocation percentages of the model. Unless you tell us otherwise, any future Purchase Payments will also be allocated to match the allocation percentages of the model. If you desire, you can also enroll in a rebalancing program to periodically rebalance your Contract Value to the model’s original allocation percentages. New allocation models will not be made available. An election to change investments under your current model must be communicated to us in writing to our Account Maintenance address in accordance with our administrative form. If you change your election, you may be subject to short-term trading fees applied by the Portfolio companies and the transfer will count as a “transfer event” as specified under the Section titled “Investment Options.”

Because Symetra Life does not provide investment advice, you should consult your financial professional to help you determine whether the model you are invested in currently, if any, is appropriate based on your financial needs, time horizon, and willingness to accept investment risk. You should also consult your financial professional periodically while you own the Contract to determine that your original model’s allocation still meets your needs.

STATE VARIATIONS

This prospectus describes the material rights, benefits and obligations under the Contract. Certain provisions of the Contract may be different from the general description in this prospectus because of variations required by state law. For example, the state in which your Contract was issued governs whether certain riders, options, charges or fees are available or will vary under Your Contract. Please see APPENDIX C: STATE VARIATIONS for a listing of state variations as well as your Contract for any state specific variations applicable to you. Any such state variations will be included in your Contract or in endorsements or riders attached to your Contract. You should refer to your Contract for specific variations applicable to you.

ANNUITY PAYMENTS (INCOME PHASE)

You can switch to the Income Phase at any time after the Contract has been in effect for one year (eight years for the Payments Based on a Number of Years annuity option), by notifying us in writing at least 30 calendar days prior to the date that you want annuity payments to begin. For Contracts issued before April 30, 2004, you can switch to the Income Phase at any time. For all

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Contracts, however, the Income Phase will start no later than the maximum annuitization age shown on your Contract or earlier if required by law and certain restrictions may apply under some retirement plans.

During the Income Phase, the payee (you or someone you choose) will receive annuity payments beginning on the Annuity Date. You name the payee when you elect an annuity option and you may change the payee designation at any time by writing to us. You may select or change an annuity option at any time prior to switching to the Income Phase by completing an election form that you can request in writing or by phone from us at any time or by downloading the form from our web site. Some retirement plans and/or Contract versions require that the Annuitant be the Owner and payee once annuity payments begin.

Switching to the Income Phase is irrevocable. Once you begin receiving annuity payments, you cannot switch back to the Accumulation Phase. During the Income Phase, you cannot add Purchase Payments, change or add an Annuitant, change the annuity option, or change between fixed and variable annuity payments. You may not make withdrawals during the Income Phase. When the Contract switches to the Income Phase, the GMDB-Annual Reset rider and the EEB rider will no longer be applicable and there will generally be no death benefit. If you transfer the right to receive annuity payments to someone else, there may be gift and income tax consequences.

Annuity payments will begin on the earlier of:

•the first available payment date after you elect to begin annuity payments;

•the latest Annuity Date specified in your Contract; or

•a different Annuity Date if required by law.

PAYMENT OPTIONS

Other than the Period Certain annuity options, you may choose whether annuity payments will be made on a fixed basis, variable basis, or both. Period Certain annuity options are available only on a fixed basis. Annuity options made on a variable basis convert Accumulation Units to Annuity Units on the date you switch to the Income Phase. Once annuity payments under a life annuity option are started, they cannot be exchanged for a lump sum. See the SAI for additional information.

ANNUITY OPTIONS

You may choose one of the options listed below. The amount of each annuity payment depends on many factors including the guarantees, if any, under the annuity option you choose, the frequency of annuity payments, the investment performance if

you choose variable annuity payments, the Annuitant’s age at the time you switch to the Income Phase and under some Contracts, the Annuitant’s sex. If you choose a life annuity option, the number of annuity payments the payee receives depends on how long the Annuitant lives, not the Annuitant’s life expectancy.

Life Annuity.  The payee receives annuity payments as long as the Annuitant is living. Annuity payments stop when the Annuitant dies. There is no minimum number of payments with this option.

Life Annuity with Guaranteed Period.  The payee receives annuity payments for the longer of the Annuitant’s life or a guaranteed period of five or more years, as selected by you and agreed to by us. Annuity payments stop on the later of the date the Annuitant dies or the date the last guaranteed payment is made. The amount of the annuity payments may be affected by the length of the guaranteed period you select. A shorter guaranteed period will result in higher annuity payments during the Annuitant’s life and fewer or no remaining guaranteed payments to the Beneficiary. A longer guaranteed period will result in lower annuity payments. If the Annuitant dies before the guaranteed payments have been made, the remaining payments will be made to the payee. As an alternative to monthly payments, the payee may elect to have the variable payments remaining commuted at the assumed interest rate of 4% and paid in a single lump sum. This alternative is not available for fixed payments.

Joint and Survivor Life Annuity.  The payee receives annuity payments as long as the Annuitant is living. After either Annuitant dies, the payee receives a specified percentage of each annuity payment as long as the other Annuitant is living. Annuity payments stop the later of the date the Annuitant dies or the date the second Annuitant dies. You name the joint Annuitant and payment percentage at the time you elect this option and they cannot be changed once the Income Phase begins. Choosing a lower percentage amount to be paid after the death of either Annuitant results in higher payments while both Annuitants are living.

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Joint and Survivor Life Annuity with Guaranteed Period.  The payee receives annuity payments for the longer of the Annuitant’s life, the joint Annuitant’s life or a guaranteed period of five or more years, as selected by you and agreed to by us. The full benefit amount will continue to be paid to the payee until the later of the first death of either the Annuitant or joint Annuitant and the end of the guaranteed period. If only one Annuitant is alive when the guaranteed period ends, a percentage of the payment amount will continue to be paid to the payee. You name the joint Annuitant, payee and payment percentage at the time you elect this option and they cannot be changed once the Income Phase begins. Choosing a lower percentage amount to be paid after the death of either Annuitant results in higher payments while both Annuitants are living. Annuity payments stop the later of the date the Annuitant dies, the joint Annuitant dies or the date the last guaranteed payment is made.

Payments Based on a Number of Years.  This annuity option is only available after the eighth Contract Year and if your Contract Value is $25,000 or more at the time this option is selected. The payee receives annuity payments based on a number of years as selected by you and agreed to by us. You must select a period of at least five years. In general, your Contract Value is amortized over a specific term and Accumulation Units and/or the value of the Symetra Fixed Account is liquidated as each payment is made. Therefore, each annuity payment reduces the number of Accumulation Units and/or value of the Symetra Fixed Account. Please see the SAI for a more detailed discussion of how this annuity option is calculated. Annuity payments continue until the entire value in the Sub-accounts and/or Symetra Fixed Account has been paid out. You can stop these annuity payments at any time and receive a lump sum equal to the remaining Contract Value. There may be tax consequences and penalties for stopping these annuity payments. However, this feature may be important to you if you do not have other sources of funds for emergencies or other financial needs that may arise. This option does not promise to make payments for the Annuitant’s life. If the Owner dies before all annuity payments have been made, we will pay a death benefit equal to the Contract Value as of the date we receive proof of death and the Beneficiary election form.

Period Certain Annuity.  The payee receives annuity payments for a specific period of time, usually 5, 10, 15, or 20 years. This guaranteed period may not exceed the Annuitant’s life expectancy. This option does not guarantee payments for the rest of the Annuitant’s life. This payout option is available only as a fixed annuity. If your Contract is a qualified Contract, period certain payments without a life contingency may not satisfy required minimum distribution rules. Annuity payments stop at the end of the guaranteed period. Consult a tax professional before electing this option.

If you do not choose an annuity option at least 30 calendar days before the latest Annuity Date specified in your Contract, we will make annuity payments under the Payments Based on a Number of Years annuity option unless your Contract states otherwise. The number of years will be equal to the Annuitant’s life expectancy. If your Contract Value is less than $25,000, we will make annuity payments under the Life Annuity with Guaranteed Period using a guaranteed period of 10 years. You may choose to have annuity payments made on a monthly, quarterly, semi-annual or annual basis. If the amount applied to an annuity option is less than $5,000, we may pay you in a lump sum where permitted by state law. We reserve the right to

change the payment frequency if payment amounts would be less than $250. You may elect to have payments delivered by mail or electronically transferred to a bank account.

Proof of Age or Sex.  We may require proof of age or sex before beginning annuity payments that are based on life or life expectancy. If the age or sex of any Annuitant has been misstated, annuity payments will be based on the corrected information. Underpayments will be made up in a lump sum with the next scheduled payment. Overpayments will be deducted from future payments until the total is repaid. We will not credit interest on underpayments or charge interest on overpayments. We may require evidence satisfactory to us that an Annuitant is living before we make any payment.

Variable Annuity Payments.  Any portion of annuity payments based on investment in the Sub-accounts will vary in amount depending on investment performance. Unless you tell us otherwise, annuity payments will be based on the investment allocations in place on the date you switch to the Income Phase.

If you choose to have any portion of annuity payments based on investment in the Sub-accounts, the dollar amount of each payment will depend on:

1.the value of your Contract (minus any outstanding loan amount) in the Sub-accounts as of the first close of the NYSE on or after the 15th day of the month preceding the Annuity Date (if the NYSE is not open on that date, the calculation will be made on the next Business Day);

2.an assumed investment return; and

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3.the investment performance of the Sub-accounts you selected.

Your Contract contains a Variable Annuity Purchase Rate Table that we use to determine the amount of the first annuity payment under your Contract. The tables are based on an annual investment return of 4% and the Annuity 2000 Mortality Table. The amount of the first annuity payment is generally determined on the basis of the annuity option selected, the annuity purchase rate (as shown in your Contract’s Variable Annuity Purchase Rate Table), the age and sex of the Annuitant, and the Annuity Date. If actual investment performance of the Sub-accounts exceeds the assumed investment return of 4%, the value of Annuity Units increases and the next variable annuity payment will be larger. Similarly, if the actual investment performance is less than the assumed investment return, the value of Annuity Units decreases and the next variable annuity payment will be smaller. Under any variable annuity option, actual investment performance of the Sub-accounts will affect the amount of annuity payments. For more information, please see the SAI.

Fixed Annuity Payments.  The dollar amount of fixed annuity payments does not vary with investment performance, therefore, each payment amount will stay the same. Annuity payments under all life annuity options will be determined by applying the Contract Value or a portion of the Contract Value (minus any outstanding loan amount) to purchase fixed annuity payments to the Fixed Annuity Purchase Rate Table shown in your Contract, or the current rates at that time if more favorable to you. The amount of fixed annuity payments under the Payments Based on a Number of Years annuity option is determined by taking the value of the Contract over the term chosen at the minimum interest rate guaranteed under the Contract.

CHANGING SUB-ACCOUNTS DURING THE INCOME PHASE

After you switch to the Income Phase, you may request to change Sub-account elections only once a month if you are taking variable annuity payments. Transfers are not allowed to or from the Symetra Fixed Account. Changes will affect the number of units used to calculate annuity payments. See the SAI for more information.

BENEFITS AVAILABLE UNDER THE CONTRACT

The following table summarizes the information about the benefits available under the Contract.

Name of Benefit	Purpose	Standard or Optional	Maximum Fee	Descriptions of Restrictions or Limitations
Basic Death Benefit	To provide your Beneficiary with a payment upon your death.	Standard	None	Only available if the GMDB-Annual Reset or EEB are not elected.
GMDB-Annual Reset (1)	The GMDB- Annual Reset Rider resets the guaranteed minimum death benefit annually each Contract anniversary until the oldest Owner attains age 75.	Optional	0.20% As a percentage of the average daily Contract Value invested in the Sub-accounts.	This rider was not available for Tax Sheltered Annuities or Deferred Compensation Plans. Certain ownership changes may result in automatic termination of the GMDB-Annual Reset. This benefit was only available at the time of purchase for Contracts issued between April 30, 2004 and April 30, 2010.
EEB (1)	The EEB Rider may add 25% or 40% (depending on the age of the oldest Owner on the issue date of the Contract) of your Contract’s earnings, if any, to the death benefit payable at your death.	Optional	0.15% As a percentage of the average daily Contract Value invested in the Sub-accounts and the Symetra Fixed Account.	This rider was available only for non-qualified Contracts. Certain ownership changes may result in automatic termination of the EEB.  This benefit was only available at the time of purchase for Contracts issued between April 30, 2004 and April 30, 2010.

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The death benefit paid will be the basic death benefit unless you have selected the GMDB-Annual Reset rider and/or the EEB rider. The death benefit provisions may be different for Contracts issued prior to April 30, 2004. Please refer to your Contract for variations.

DEATH DURING THE ACCUMULATION PHASE

If any Owner dies during the Accumulation Phase, the death benefit is payable to the:

•surviving Owner; or if none, then

•the surviving primary Beneficiary; or if none, then

•the surviving contingent Beneficiary; or if none, then

•the estate of the last Owner to die.

If the Owner is a non-natural person (e.g., a corporation or trust), the death of any Annuitant is treated as the death of the

Owner. Therefore, a joint Annuitant on a Contract owned by a non-natural person may not receive any benefits upon the death of the first Annuitant.

If an Annuitant is not the Owner and dies during the Accumulation Phase, the Owner must designate a new Annuitant. If an Annuitant is not designated within 30 days after we are notified of the Annuitant’s death, the Owner will be named as an Annuitant.

Calculation of Death Benefit

We will determine the amount of and pay the death benefit upon receipt at our Account Maintenance address of the following:

•proof of death acceptable to us, such as a certified copy of a death certificate;

•written direction from at least one eligible recipient of the death benefit proceeds regarding how to pay the death benefit payment; and

•any other documents, forms or information we need.

If we receive due proof of death acceptable to us and written direction from at least one eligible recipient of the death benefit regarding how to pay the death benefit payment within 6 months of the date of death and the guaranteed minimum death benefit exceeds the Contract Value, we will add money to your Contract in order to satisfy the guaranteed minimum death benefit. The money added will be allocated to the investment options, in the same manner as Purchase Payments. For limitations on the amount we will add, please see “Limitations on Death Benefit” described below.

Payment of Death Benefit

The death benefit is subject to investment performance and applicable Contract charges until the date payment is made. This value will usually go up or down. Thus, Beneficiaries should notify us of a death as promptly as possible to limit the risk of a decline in benefit value. The amount of the death benefit will include any interest required by state law. In all cases, any outstanding loan amount will be deducted from the death benefit proceeds.

Under a non-qualified Contract, the death benefit may be paid as:

1) a lump sum payment or series of withdrawals that are completed within five years from the date of death; or

2) annuity payments made over the Beneficiary's life or life expectancy. To receive annuity payments, the Beneficiary must make the election within 60 days from our receipt of proof of death. Annuity payments must begin within one year after the date of death. Once annuity payments begin they cannot be changed.

Under a qualified Contract, the death benefit must generally be completed within ten years after the date of death unless payable to an “eligible designated beneficiary” as defined in the Code. Eligible designated beneficiaries include, spouses, minor children (until they reach the age of majority), beneficiaries who are disabled or chronically ill or individuals not more than 10 years younger than the original owner.

In some cases, a spouse who is entitled to receive a death benefit may have the option to continue the Contract instead. If you entered into a civil union your rights to continue the Contract may be limited under federal laws. See the Section titled

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“Taxes” for more information. If this spouse is also the oldest joint Owner, the guaranteed minimum death benefit will apply on the death of this spouse. Otherwise, the benefit on the death of your spouse will be the Contract Value.

If there is no surviving joint Owner, or the Contract is owned by a single Owner, the right to receive the death benefit or to change the payee for remaining annuity payments will pass to the Beneficiary as elected on the Contract application (or Beneficiary designated on our records, if changed by you at a later date).

If the age of the Annuitant or Contract Owner has been misstated on the Contract application, the amount of any death benefit payable shall be determined based upon the correct age of the Annuitant or Contract Owner.

DEATH DURING THE INCOME PHASE

If an Owner dies during the Income Phase, then any amounts paid after an Owner’s death will depend on which annuity option was selected. Under the Payments Based on a Number of Years annuity option, if an Owner dies before the entire Contact Value has been paid out, we will pay a death benefit equal to the Contract Value as of the date we receive proof of death and an election of how to take the death benefit payment. If an Owner dies while annuity payments are being paid under another annuity option, we will pay the remaining annuity payments, if any, in accordance with that option. If the Annuitant is not the Owner and dies after the Annuity Date, then we will continue paying any remaining annuity payments to the payee designated by the Owner. The death benefit or remaining annuity payments will be distributed at least as rapidly as under the annuity option then in effect. See the Section titled “Annuity Payments” for more information.

The right to receive the death benefit under Payments Based on a Number of Years or to change the payee for remaining annuity payments under another annuity option is determined as follows:

•surviving Owner; or if none, then

•the surviving primary Beneficiary; or if none, then

•the surviving contingent Beneficiary; or if none, then

•the estate of the last Owner to die.

BASIC DEATH BENEFIT

This is the standard death benefit under the Contract. The basic death benefit is the higher of:

1) your current Contract Value (as of the date indicated below); or

2) if you are a sole Owner or the oldest joint Owner, the guaranteed minimum death benefit.

The basic guaranteed minimum death benefit is initially equal to your first Purchase Payment and is immediately increased by additional Purchase Payments and adjusted downward for withdrawals. For more detailed information regarding the adjustment calculations, please refer to your Contract. The guaranteed minimum death benefit is reset on each 8-year Contract anniversary until the oldest Owner attains age 72. The reset benefit is equal to the immediately preceding guaranteed minimum death benefit or is “stepped up” to your Contract Value on that date, if higher.

OPTIONAL DEATH BENEFITS

If your Contract was purchased between April 30, 2004 and April 30, 2010, you may have elected none, one or both optional benefits available at the time you purchased the Contract. The optional death benefits were only available for certain Contracts as discussed below.

Guaranteed Minimum Death Benefit - Annual Reset (“GMDB - Annual Reset”).  The GMDB - Annual Reset rider was only available for non-qualified Contracts, IRAs, and Roth IRAs. It was not available for TSA and 457 Contracts. This benefit was only available between April 30, 2004 and April 30, 2010.  If you were under age 75 at the issue date of the Contract, you may have elected the GMDB - Annual Reset rider. If you elected the GMDB - Annual Reset rider, it will replace the basic guaranteed minimum death benefit described above. If the Contract is owned by joint Owners, both Owners must have been under age 75 as of the issue date of the Contract to elect this rider. If you elected this rider, we will deduct a charge. Once you have elected the benefit, you cannot cancel it, and the 0.20% annual charge will continue to be deducted, even during periods when the GMDB-Annual Reset would provide no benefit.

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If you elected this rider, the guaranteed minimum death benefit will be reset annually each Contract anniversary until the oldest Owner attains age 75. The reset benefit is equal to the immediately preceding guaranteed minimum death benefit or the Contract Value on that date, if higher. Withdrawals reduce your Contract Value, which may in turn impact the reset benefit.

The GMDB - Annual Reset rider terminates and the charge is no longer deducted if:

1.the Contract enters the Income Phase prior to your death; or

2.a spouse continues the Contract after the death of the sole Owner or oldest joint Owner.

If the surviving spouse is the oldest joint Owner and continues the Contract after the death of the youngest spouse, the benefit will remain in effect and the charge will continue to be deducted.

If the age of any Owner is misstated so that the Owner would not have been eligible to purchase the benefit, the rider is terminated.

Earnings Enhancement Benefit (“EEB”).  The EEB rider was only available for non-qualified Contracts and was only available between April 30, 2004 and April 30, 2010. If you were under age 76 on the issue date of the Contract, you may have elected the EEB rider. If the Contract is owned by joint Owners, both Owners must have been under age 76 as of the issue date of the Contract to elect this rider. If you elected this rider, we will deduct a charge. Once you have elected the benefit, you cannot cancel it. The EEB is payable upon the sole Owner’s or oldest joint Owner’s death and will be added to the basic or GMDB-Annual Reset death benefit that is described above.

If the oldest Owner was age 69 or under when you purchased your Contract, the EEB is equal to 40% of the earnings remaining in the Contract.

If the oldest Owner was age 70 through 75 when you purchased your Contract, the EEB is equal to 25% of the earnings remaining in the Contract.

However, the maximum EEB benefit is one million dollars, less any amount paid to satisfy the guaranteed minimum death benefit.

For purposes of this benefit, we define “earnings” as the amount by which the Contract Value (when the death benefit is calculated) exceeds the total amount of Purchase Payments received prior to the date of death, less withdrawals and charges. For this purpose, earnings are deemed to be withdrawn before Purchase Payments. If any Purchase Payments are the result of a transfer or rollover, when we calculate earnings we do not include any gain accrued while the money was invested elsewhere. Earnings also do not include the stepped-up portion of the death benefit that results if the guaranteed minimum death benefit or GMDB-Annual Reset exceeds the Contract Value.

Your earnings for this purpose are limited to a maximum of 250% of the total value of your Purchase Payments, less withdrawals and charges, excluding any Purchase Payments made 12 months prior to the date of death (other than Purchase Payments made during the first Contract Year if death occurs in the first Contract Year) or after death. Withdrawals are considered to come from earnings first. If there are no earnings in your Contract, the EEB will be zero. However, the 0.15% annual charge will be deducted even if there are no earnings. This means you may be paying for a benefit you may not receive.

The EEB rider terminates and the charge is no longer deducted if:

1.the Contract enters the Income Phase prior to your death; or

2.a spouse continues the Contract after the death of the sole Owner or oldest joint Owner.

If the surviving spouse is the oldest joint Owner and continues the Contract after the death of the youngest spouse, the benefit will remain in effect and the charge will continue to be deducted.

If the age of any Owner is misstated so that the Owner would not have been eligible to purchase the benefit, the rider is terminated.

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For examples on how the Basic Death Benefit, GMDB-Annual Reset, and EEB death benefit works, see APPENDIX B: CALCULATION OF BASIC DEATH BENEFIT, GMDB-ANNUAL RESET, AND EEB OPTIONAL DEATH BENEFIT.

Effects of Ownership Changes.  Certain ownership changes may result in automatic termination of the optional death benefits. If the Contract is owned by one Owner, the following ownership changes will result in termination of the rider:

1.A change in ownership to another individual; or

2.A change in ownership to a trust or other entity and the original Owner is not the sole Annuitant; or

3.A second individual is added as an Owner and the new Owner is older than the original Owner.

If the Contract is owned by joint Owners, the rider will terminate if a change in ownership results in the oldest Owner no longer being an Owner.

The guaranteed minimum death benefit is always calculated on the life of the oldest original Owner, as shown on the original application for this Contract. The amount payable on the death of any Owner other than the oldest original Owner will be the current Contract Value. If the oldest original Owner ceases to be an Owner of the Contract, the guaranteed minimum death benefit will be terminated. Therefore, ownership changes will have an impact on your Contract and you should consult your agent or other advisor if you have questions.

LIMITATION ON DEATH BENEFIT

At most, one guaranteed minimum death benefit or if elected, GMDB - Annual Reset benefit and one EEB will be paid during the life of the Contract. In addition, for Contracts purchased on or after April 30, 2004, the maximum amount that we will add to your Contract in order to satisfy the guaranteed minimum death benefit, (or if selected GMDB - Annual Reset benefit), and EEB is limited to a total of $1 million. All annuity Contracts subsequently purchased by you from us will be aggregated for this $1 million limit if your death triggers a payment. The guaranteed minimum death benefit will only be paid upon the death of the oldest original Owner. Therefore, ownership changes will have an impact on your Contract and you should consult your agent or other advisor if you have questions.

TRANSFERS

TRANSFERS AMONG SUB-ACCOUNTS AND THE SYMETRA FIXED ACCOUNT

During the Accumulation Phase you can transfer money among the Sub-accounts and the Symetra Fixed Account 12 times per Contract Year free of a transfer charge. We measure a Contract Year from the anniversary of your Contract Date. Each additional transfer in a Contract Year may have a charge of $10 or 2% of the amount transferred whichever is less.

The minimum amount you can transfer out of any investment option at one time is $500, or the entire value of the investment option if less. If a transfer will result in the remaining balance in an investment option being less than $500, you must transfer the entire amount out of the investment option. The minimum you can transfer into any investment option is $50. In addition to this $500 minimum, transfers out of the Symetra Fixed Account are limited to a maximum of 10% of the Symetra Fixed Account value per Contract Year. We may waive this 10% limitation upon written notice to you. If we waive it, we reserve the right to reinstate the 10% limitation upon written notice. We determine whether you have transferred more than 10% of the Symetra Fixed Account value at the time of the transfer. If you make more than one transfer from the Symetra Fixed Account in a Contract Year, the amounts of all previous transfers from the Symetra Fixed Account in the Contract Year are subtracted from the current 10% amount to determine the amount available for transfer.

Transfer requests received by us with all information we need to process the request will be effective and valued as of the next close of the NYSE. This is usually 4:00 p.m. Eastern Time. If for any reason the NYSE is closed when we receive your transfer request, it will be valued as of the close of the NYSE on its next regular Business Day.

TRANSFER TRANSACTIONS AVAILABLE

We may accept transfers by signed written request or at our discretion, by telephone, or, if available, electronically by the Internet. Each transfer must identify:

•your Contract;

•the amount of the transfer; and

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•which investment options are affected.

We cannot process your transfer request until we have received the request at our Account Maintenance address. Transfer requests received by us with all the information we need to process the request will be effective and valued as of the next close of the NYSE. This is usually 4:00 p.m. Eastern Time. If for any reason the NYSE is closed when we receive your transfer request, it will be valued as of the close of the NYSE on its next Business Day.

Transfers by telephone will be accepted if we have properly signed authorization on record. You may authorize someone else to make transfers by telephone on your behalf. Symetra Life will not be liable for any failure to question or challenge such request for transfer as long as there is a valid signed authorization on record at Symetra Life.

Transfers by Internet will be accepted if you provide us with certain identification information, including a personal identification number (“PIN”). However, we do not accept transfer requests sent by e-mail. Transfer instructions you send electronically through the Internet are considered to be received by us at the time and date stated on the electronic acknowledgment we return to you. If you do not receive an electronic acknowledgment, you should telephone us as soon as possible.

Although we use reasonable procedures, including recording all telephone instructions and requiring certain personal information to prevent unauthorized account access, we cannot assure you that telephone or Internet activity will be completely secure or free of delays or malfunctions. If you choose to make transfers by telephone or Internet, you must be willing to assume the risk of loss that may occur despite our reasonable efforts to verify identity. We are not responsible for the negligence or wrongful acts of third parties.

We cannot guarantee that telephone transactions will always be available. In addition, if the volume of calls is unusually high, we may not have someone immediately available to receive your order. Likewise, we cannot guarantee that on-line transactions processed via the Internet will always be possible. Telephone and computer systems, whether yours, your Internet service provider’s, your Symetra Life registered representative’s, or Symetra Life’s, can experience outages or slowdowns for a variety of reasons. These outages or slowdowns may prevent or delay our receipt of your request.

You also should protect your PIN because self-service options will be available to anyone who provides your PIN. We will not be able to verify that the person using your PIN and providing instructions is you or a person authorized by you.

We reserve the right to modify, suspend, or terminate transfer privileges at any time for some or all Contract Owners. In addition, if we receive a transfer request that is to be allocated to the Symetra Fixed Account and we are not able to invest the money such that we can credit at least the minimum guaranteed interest rate, we reserve the right to reject the portion of the transfer request that was to be allocated to the Symetra Fixed Account.

SCHEDULED TRANSFERS

During the Accumulation Phase, you can choose among several investment strategies that are available at no charge. We refer to any transfer made using these strategies as “scheduled transfers” and they will not count against your 12 free transfers. We may impose restrictions on the number of scheduled transfers that can be initiated during each Contract Year or on the investment options available for scheduled transfers. If such restriction is imposed or we change the Sub-accounts available, we will notify you in writing. Once started, dollar cost averaging and appreciation or interest sweep scheduled transfers will continue until you instruct us to stop or all money has been transferred out of the investment option designated as the source of the scheduled transfer. If you make a transfer or withdrawal outside of either the dollar cost averaging or appreciation or interest sweep strategy and that transfer or withdrawal is from the investment option you have designated as the source for these strategies, your scheduled transfers will stop. Scheduled transfers will not count against your 12 free transfers and are available at no charge.

Dollar Cost Averaging.  This strategy is designed to achieve a lower average cost per unit over time. It does not assure a profit or protect against a loss. Investing should continue at a consistent level in both market ups and downs. You can systematically transfer set amounts of at least $50 each month or quarter from any Sub-account or the Symetra Fixed Account to any of the other Sub-accounts. If you choose to transfer amounts among more than one Sub-account, transfers into each Sub-account must be at least $50. If a transfer will result in the remaining balance in a Sub-account being less than $500, you must transfer the entire amount out of the Sub-account.

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Dollar cost averaging transfers from the Symetra Fixed Account are limited to 4% per quarter (1.33% monthly) of your value in the Symetra Fixed Account as of the date of the initial transfer. By choosing to have the transfer limit recalculated annually, the limit is raised to 4.5% per quarter (1.5% monthly). There are no percentage limits on transfers out of the Sub-accounts.

Appreciation or Interest Sweep.  If your Contract Value is at least $10,000, you can instruct us to automatically transfer earnings up to 10% each Contract Year from the Fidelity VIP Government Money Market Portfolio and earned interest up to 10% from the Symetra Fixed Account to the other Sub-accounts monthly, quarterly, or annually. Appreciation or interest sweep cannot be used to transfer money to the Symetra Fixed Account or to the Fidelity VIP Government Money Market Portfolio.

Sub-account Rebalancing.  After your money has been invested, the investment performance of the Sub-accounts may cause the percentage in each Sub-account to change from your original allocations. If your Contract Value is at least $10,000, you can instruct us to adjust your investment in the Sub-accounts to maintain a predetermined mix quarterly, semi-annually, or annually. Sub-account rebalancing can be used with dollar cost averaging and appreciation or interest sweep; however, it is not available for the Symetra Fixed Account. The $10,000 minimum Contract Value requirement is waived if a Symetra Life approved asset allocation program is currently being used for Sub-account rebalancing.

LIMITS ON EXCESSIVE TRANSFERS AND MARKET TIMING ACTIVITY

Effects of Excessive Transfers and Market Timing Activity.  The Contract and the Portfolios are not designed for excessive short-term trading or professional market timing, or for organizations or other persons that make large, or frequent transfers. Frequent transfers between and among the Sub-accounts may be disruptive to Portfolio management strategies by causing forced and unplanned Portfolio turnover, and increased trading and transaction costs. In addition, these activities may require a Portfolio to maintain liquid assets rather than investing them for growth, resulting in lost opportunity costs that must be indirectly borne by Contract owners. These disruptive activities may increase expenses and adversely affect Portfolio performance, thereby negatively impacting long-term Contract owners.

Detection and Deterrence.  Symetra Life discourages and does not accommodate frequent transfers or market timing activity. Due to the potential adverse consequences to Contract Owners, Portfolios, Portfolio shareholders, and the Separate Account, we have established certain policies and procedures to aid us in detecting and deterring Contract Owners that may be engaging in frequent trading and/or market timing activities. These policies and procedures may restrict or eliminate the right to make transfers among Sub-accounts if such trades are executed by you, a market timing firm or other third party authorized to initiate transfers or exchange transactions on your behalf.

In general, our market timing procedures detect market timing by identifying transfer activity in which the transfers exceed a certain dollar amount and a certain number of transfers involving the same Sub-accounts within a specific time period. We regularly review transaction reports in an attempt to identify transfers that exceed our established parameters. We do not include Symetra Life approved investment strategies such as dollar-cost averaging, Sub-account rebalancing, and other approved systematic transactions, such as asset allocation programs, if available, when monitoring for market timing.

In general, we monitor for "roundtrip" transfers of the same Sub-account within a thirty-day period. We also monitor for “inter-Sub-account” transfers between any two Sub-accounts within a sixty-day period. The following transactions will generally be reviewed for market timing activity:

1.Any two roundtrip transfers in any rolling ninety-day period; and

2.Any four inter-Sub-account transfers occurring within a sixty-day period.

We will particularly scrutinize transactions involving those Sub-accounts that are subject to abuse by market timing strategies, such as those Portfolios that have an international investment profile. For example, if you transfer from American Century VP International Fund to Fidelity VIP Government Money Market Portfolio followed by a transfer from Fidelity VIP Government Money Market Portfolio to American Century VP International Fund within ten Business Days, we may conclude that you are engaging in market timing. We may aggregate transfers made in two or more Contracts that we believe are connected in applying the procedures we employ to deter market timing.

In addition, our procedures include reviewing trading volumes every day in each Sub-account offered in your Contract. We will note large or unusual trading volumes and determine if a pattern of frequent transfers is being made in particular Sub-accounts by particular Contract Owners.

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If we conclude that market timing or other disruptive trading patterns are being transacted by you, we will limit you to one transfer in each 30-day period starting from the date of the transfer that we determined was a market timing transfer and continuing for six months thereafter. If, after the six-month limitation is lifted, the market timing activity resumes, we will limit you to one transfer in each 30-day period starting from the date of the transfer that we determined was a market timing transfer and continuing for twelve months thereafter. In addition, we will require you to submit transfer requests via U.S. mail during that 12-month period. If transfer instructions are inadvertently accepted from you after you have been identified as a market timer, we will reverse the transaction within one to two Business Days.

In our sole discretion, we may revise our procedures at any time without prior notice to better detect and deter market timing or other disruptive trading to comply with regulatory requirements and/or to impose additional or alternate restrictions such as imposing dollar or percentage limits on transfers or requiring transfers be submitted via U.S. mail. If we modify our procedures, they will be applied uniformly to all contract owners.

If a transfer request is rejected or your transfer privileges have been restricted for any reason, we will attempt to inform you or your authorized agent by phone the next Business Day. If we do not succeed in reaching you or your authorized agent by phone, we will send a letter to your address of record. Our policies regarding transfer restrictions and rejections are applied uniformly, and we do not make exceptions for particular Contract Owners.

We will use our best efforts to prevent market timing and other abusive trading practices, but the determination of whether market timing is occurring is subjective. We may not be able to detect all market timers or short-term traders, and we may not be able to prevent transfers by those we do detect. In addition, the terms of the Contract may also limit our ability to restrict or deter harmful transfers. If we are unable to detect or prevent market timing, the effect of such market timing may result in additional transaction costs for the Portfolios and dilution of long-term Sub-account owners’ returns. Thus, your Contract Value may be lower due to lower returns in your Sub-account investments.

Underlying Portfolio Frequent Trading Policies.  The Portfolio managers to whom we submit purchase and redemption orders may also detect large or unusual patterns of trades submitted by us on behalf of all our variable annuity contract owners and variable life policy owners. Those Portfolio managers may require us to investigate whether any of our contract owners are engaged in market timing or other similar activity and to cooperate with them to discourage such activity. If the Portfolio managers believe you are engaged in market timing activity they may block you from making transfers or purchases to their Portfolios. In addition, federal regulations may require us to provide individual transaction and Contract Owner information to the Portfolio managers when requested.

The Portfolios to which we submit purchase and redemption orders may adopt unique policies and procedures designed to deter excessive trading or market timing. Those policies and procedures, when applicable, are described in the prospectuses for each of the Portfolios available for investment by you. We have entered into a written agreement, as required by SEC regulation, with each underlying Portfolio or its principal underwriter. These agreements obligate us to promptly provide to the underlying Portfolio upon request certain information about the trading activity of individual Contract owners. The Portfolios may require us to execute their instructions to restrict or prohibit further purchases or transfers by specific Contract owners who violate the frequent trading policies established by the underlying Portfolio.

In cases of large or frequent transfers, the Portfolio managers or Symetra Life may reject trades that are determined to be detrimental to other Portfolio shareholders or violate the Portfolios’ policies and procedures. Therefore, we reserve the right to reject, without prior notice, any transfer request to a Sub-account if the Portfolio manager rejects such trade or the trade violates a Portfolio’s policies and procedures. If a Portfolio refuses to accept a transfer request we have already processed, we will reverse the transaction within one to two Business Days. We will notify you or your authorized agent in writing or by phone if your transfer has been rejected or reversed. We further reserve the right to implement, administer, and charge you for any fee or restriction, including redemption fees, imposed by any underlying Portfolio. Redemption fees, transfer limits, and other procedures or restrictions may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading. You should read the prospectus of each Portfolio for more information about its ability to refuse or restrict purchases or redemptions of its shares and to impose redemption fees.

Omnibus Order.  Contract Owners and other persons with material rights under the Contracts also should be aware that the purchase and redemption orders received by the underlying Portfolios generally are “omnibus” orders from intermediaries such as retirement plans and separate accounts funding variable Contracts. The omnibus orders reflect the aggregation and netting of

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multiple orders from individual retirement plan participants and individual owners of variable Contracts. The omnibus nature of these orders may limit the underlying Portfolios’ ability to apply their respective frequent trading policies and procedures. We cannot guarantee that the underlying Portfolios will not be harmed by transfer activity relating to the retirement plans or other insurance companies that may invest in the underlying Portfolios. These other insurance companies are responsible for their own policies and procedures regarding frequent transfer activity. If their policies and procedures fail to successfully discourage frequent transfer activity, it will affect other owners of underlying Portfolio shares, as well as the owners of all of the variable annuity Contracts (or variable life policies), including ours, whose variable investment options correspond to the affected underlying Portfolios. In addition, if an underlying Portfolio believes that an omnibus order we submit may reflect one or more transfer requests from owners engaged in frequent transfer activity, the underlying Portfolio may reject the entire omnibus order and thereby delay or prevent us from implementing your request. If an underlying Portfolio rejects an omnibus order, we will notify you of the actions taken that affect your request.

ACCESS TO YOUR MONEY

Under your Contract, money may be accessed:

•by taking partial withdrawals during the Accumulation Phase;

•by surrendering your Contract during the Accumulation Phase;

•by taking repetitive withdrawals (described below);

•by taking a loan (403(b) Contracts only);

•by receiving payments during the Income Phase (see the Section titled “Annuity Payments”); or

•when a death benefit is paid to your Beneficiary (see the Section titled “Death Benefit”).

PARTIAL WITHDRAWALS

During the Accumulation Phase, you can make partial withdrawals from the Contract Value by writing to us at our Account Maintenance address. The withdrawal request must be accompanied with all the information we need to process it. Partial withdrawals must be at least $250 ($100 if withdrawals are made by electronic funds transfer), unless the Contract Value is less, in which case the entire Contract Value will be withdrawn. If you take a partial withdrawal, you must tell us from which investment options we are to take the withdrawal. If you do not provide us with instructions, we will take the withdrawal pro-rata from the Sub-accounts in which you are invested at the time of the partial withdrawal request. Once we receive your request, withdrawals from the Sub-accounts will be effective as of the next close of the NYSE. Partial withdrawals are payable within seven calendar days.

Withdrawals reduce your Contract Value by the amount of the requested withdrawal plus any applicable charges. A withdrawal may have a contingent deferred sales charge, a withdrawal charge, and, if you withdraw the entire Contract Value, an annual administration maintenance charge. There are situations where all or some of these charges don’t apply. See the Section titled “Charges and Expenses” for a discussion of the applicable charges. Withdrawals may be restricted or prohibited by the terms of qualified Contracts.

SURRENDERING YOUR CONTRACT

You can surrender your Contract for its Contract Value at any time before you begin to receive annuity payments. You may not surrender your Contract during the Income Phase. For a surrender to be effective, we must receive your written request at our Account Maintenance address. All benefits will terminate as of the date we receive the required information to process your surrender request. We will determine your surrender value as of the next close of the NYSE after we have received the required information to process your request. We will pay you the surrender value within seven calendar days.

The surrender value will be equal to your Contract Value minus any applicable contingent deferred sales charge, withdrawal charge, annual administration maintenance charge, and loan amount.

REPETITIVE WITHDRAWALS

Repetitive withdrawals allow you to automatically withdraw payments of a pre-determined dollar amount or fixed percentage of Contract Value that you request from a specified Sub-account monthly, quarterly, semi-annually or annually. The minimum amount for each withdrawal is $500, or the Contract Value if less. You may request repetitive withdrawals by completing the appropriate form and sending it to our Account Maintenance address. Repetitive withdrawals may be used to avoid tax penalties for premature withdrawals or to satisfy distribution requirements of certain retirement plans. To do this they must be a series of substantially equal withdrawals made at least annually and based on:

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•your life expectancy; or

•the joint life expectancy of you and your Beneficiary.

You may begin repetitive withdrawals based on life expectancy by providing us with verification of age in order for us to calculate the monthly, quarterly, or annual withdrawal amount. We calculate the amount of a repetitive withdrawal based on life expectancy by dividing the Contract Value by the life expectancy of the Owner as determined by using the IRS single life table. If it is a joint life expectancy, then we divide the Contract Value by the life expectancy of the Owner and joint Owner (or Beneficiary) by the IRS joint life table.

Example One:  Assume that the Contract Value is equal to $100,000 and the Owner requests a repetitive withdrawal and is age 55. Based on the IRS single life table, the life expectancy of an Owner age 55 is 29.6 years. The first repetitive withdrawal amount is equal to $100,000 divided by 29.6 which equals an annual payment of $3,378.38.

Example Two:  Assume that in one year, when the Contract Owner is age 56, the Contract Value is equal to $101,453. The life expectancy of the Owner is 28.7 years. The repetitive withdrawal amount is equal to $101,453 divided by 28.7 which equals an annual payment of $3,534.95.

Repetitive withdrawals that are based on life expectancy may allow you to avoid the early withdrawal tax penalty of 10% that you would otherwise pay for taking withdrawals prior to age 591/2. If you take additional withdrawals or otherwise modify or stop these repetitive withdrawals, a withdrawal charge may apply and there may be tax consequences and penalties. You should talk to your tax professional for more information on taking repetitive withdrawals to avoid the 10% tax penalty. If you make repetitive withdrawals that are not based on life expectancy, the same restrictions, income taxes, and tax penalties that apply to random withdrawals also apply to repetitive withdrawals.

LOANS

Subject to your TSA employer’s plan, you may take a loan against your Contract Value. If permitted, you may request a loan from us using your Contract Value as the security for the loan if:

•your Contract is issued under Section 403(b) of the Code;

•you are permitted to take loans under the plan; and

•you do not have an existing loan in default status.

The amounts and terms of a loan may be subject to state restrictions, plan requirements, Section 72(p) of the Code, and our approval. You must complete our loan application and sign a loan agreement. Loans require that a minimum collateral balance is held in the Symetra Fixed Account. If necessary, we will transfer money from the Sub-accounts (as selected by you on your loan application) to the Symetra Fixed Account to reach the required minimum collateral balance. Any amounts borrowed under your Contract and any amounts transferred to the Symetra Fixed Account to satisfy the required minimum collateral balance will not participate in the investment experience of the Sub-accounts. We will also charge interest on the outstanding loan balance. The loan interest spread is 2.5%, which is the difference between the rate charged and the rate credited on loans under your Contract. We will not offer loans that will exceed a rate charged of 8%. If the interest charged will exceed 8%, we will not issue the loan. Loan repayments must be made at least quarterly, but may be made more frequently, if desired. Loan repayments made in addition to the regularly scheduled repayments will be applied first to the interest accrued since the last repayment and then to reduce principal.

If a loan is outstanding when you request a full annuitization of your Contract Value, we will subtract any outstanding loan amount from your Contract Value. The amount available to annuitize will be the Contract Value after the outstanding loan amount has been repaid.

If a loan is outstanding when you die, we will subtract any outstanding loan amount from the death benefit prior to making payment to your Beneficiary.

You should consult a tax professional and read your loan agreement before taking a loan. We reserve the right to stop issuing loans and will provide written notice if we exercise this right.

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WITHDRAWAL RESTRICTIONS ON TSA CONTRACTS

Your right to make withdrawals or surrenders is subject to any restrictions imposed by applicable law or retirement plans.

There are certain restrictions imposed on withdrawals from Contracts used as funding vehicles for 403(b) retirement plans (“TSAs”). Withdrawals attributable to salary reduction contributions to TSAs for years after 1988 and any earnings accrued after 1988, cannot be taken out unless:

•you attain age 591/2;

•you leave your job;

•you die or become disabled as defined by the Code;

•the withdrawal is in connection with a qualifying birth or adoption;

•you experience a qualifying hardship (applies to contributions only);

•you divorce and a distribution to your former spouse is permitted under a Qualified Domestic Relations Order; or

•you are a member of the National Guard Reserves, are called to active duty and request a qualified reservist distribution.

Also, for 403(b) Contracts, amounts attributable to employer contributions that were made on or after January 1, 2009, are subject to restrictions on withdrawals specified in your employer’s 403(b) plan, in order to comply with tax regulations. Amounts transferred to a 403(b) Contract from other 403(b) Contracts or accounts are generally subject to the same restrictions on withdrawals applicable under the prior Contract or account.

In the case of all qualified Contracts, tax penalties may apply to withdrawals. There may also be restrictions on the form and manner in which benefits may be paid. For example, spousal consent may be needed in certain instances before a distribution may be made. However, these restrictions on withdrawals do not affect rollovers or transfers between certain retirement plans.

MINIMUM VALUE REQUIREMENTS

You must withdraw the entire amount out of an investment option if, after a withdrawal, the remaining value in the investment option would be less than $500. Similarly, you must withdraw the entire Contract Value and your Contract will terminate if, after a withdrawal, the remaining Contract Value would be less than the minimum, if any, stated in your Contract. However, negative investment performance alone will not cause a forced withdrawal. We may waive this minimum balance for Contracts issued in connection with employer sponsored retirement plans.

Withdrawals, including any deductions for charges, reduce the number of Accumulation Units and/or the value of the Symetra Fixed Account as well as the death benefit. Income taxes, tax penalties and certain restrictions may also apply. See the Section titled “Taxes.”

SIGNATURE GUARANTEES

As a protection against fraud, we require a signature guarantee for certain transaction requests. When required, we must receive the original signature guarantee and will not accept copies or faxes of the signature guarantee. You may obtain a signature guarantee at most banks, financial institutions or credit unions. A notary public cannot provide a signature guarantee. For more information on our signature guarantee requirements, please contact us.

TRANSACTION AUTHORITY

Certain transactions may be permitted by telephone and electronically on the Internet and may require that we have properly signed authorization for your Contract on record.  In addition, you may authorize someone else to make transactions by telephone, and if available on the Internet, on your behalf.  Symetra Life will not be liable for any failure to question or challenge such requests as long as there is a valid signed authorization on record at Symetra Life.  Transactions submitted by Internet will require certain identification information, such as a password or personal identification information.

Although we use reasonable procedures, including recording all telephone instructions and requiring certain personal identification information to prevent unauthorized account access, we cannot assure you that telephone or Internet activity will be completely secure or free of delays or malfunctions. If you choose to make transactions by telephone or Internet, you must be willing to assume the risk of loss that may occur despite our reasonable efforts to verify identity. We are not responsible for the negligence or wrongful acts of third parties.

TAXES

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This section and additional information in the SAI discuss how federal income tax applies to annuities in general. This information is not complete and is not intended as tax advice. Tax laws and their interpretations are complex and subject to change. No attempt is made to discuss state or other tax laws. Symetra Life does not guarantee the tax treatment of any Contract or any transaction involving a Contract. You should consult a competent tax professional about your individual circumstances.

ANNUITY CONTRACTS IN GENERAL

Under the Code, you generally do not pay tax on Contract earnings until received. Different tax rules apply to Purchase Payments and distributions depending on how you take money out and whether your Contract is qualified or non-qualified.

Earnings for corporate owned Contracts and other Contracts not owned for the benefit of natural persons are generally taxed as ordinary income in the current year. Exceptions may apply. For example, Contracts by a trust which holds the Contract as an agent for a natural person, and Contracts held for qualified retirement plans may be able to defer tax on earnings until money is withdrawn from the Contract.

DEATH BENEFITS

Neither of the optional death benefits paid under the Contract to the Beneficiary will be tax-exempt life insurance benefits. The rules governing taxation of payments from an annuity Contract generally apply to the payment of death benefits and depend on whether the death benefits are paid as lump sum or annuity payments. Estate or gift taxes may also apply.

QUALIFIED CONTRACTS

Contracts purchased as an IRA, Roth IRA, TSA, Roth TSA, 457, or other retirement plan, are referred to as qualified Contracts because they are qualified under the Code to provide tax deferral for retirement purposes. You do not have to purchase an annuity Contract to qualify for the tax deferral offered by these retirement plans. There may be other investment vehicles that can be purchased for your retirement plan. However, an annuity Contract has features and benefits other than tax deferral that may make it an appropriate investment for your retirement plan. If the Contract is purchased as part of your employer’s retirement plan, we are not responsible for determining if your employer’s plan or arrangement satisfies the requirements of the Code and/or the Employee Retirement Income Security Act of 1974 (“ERISA”). You should consult your tax professional regarding these features and benefits before you buy a qualified Contract.

Qualified Contracts are subject to special rules and limits on Purchase Payments and distributions that vary according to the type of retirement plan. Ineligible or excess contributions to certain retirement plans can result in substantial penalties and possible loss of the Contract’s or retirement plan’s qualified status. Tax penalties of 10% or more, may apply to certain distributions; for example if you are under age 591/2 or not disabled as defined by the Code. Temporary relief from these penalties may be available. Please see "Temporary Rules Under the CARES Act" below.

You may be able to make a direct transfer or rollover from other qualified plans and Contracts to this Contract. If certain requirements are met, you may be able to transfer amounts in your Contract to another eligible retirement plan or IRA.

Generally, qualified Contracts (except for Roth IRAs) are subject to lifetime required minimum distributions. For TSAs and 457 plans you must begin receiving required minimum distributions no later than April 1 of the year following the later of attainment of age 70 1/2 or the date you sever employment with the employer sponsoring the plan. For IRAs, you must begin receiving required minimum distributions by April 1 of the year following the year in which you reach age 70 1/2. There may be substantial penalties if you fail to take required minimum distributions. Distributions from a Roth IRA may be deferred until the death of the Owner.

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the “Secure Act”) increases the beginning date for required minimum distributions from 70 ½ to 72. This change only applies if you will attain age 70 1/2 on or after January 1, 2020. All other requirements for the timing and calculation of required minimum distributions remain the same. If you reached the age of 70 ½ prior to January 1, 2020, you are still required to use age 70 ½ as the beginning date for required minimum distributions.

A rollover from or conversion of an IRA to a Roth IRA is generally subject to tax. The Owner may wish to consult a tax professional before combining any converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years. SEP IRAs and SIMPLE IRAs are subject to different rules.

Furthermore, under final regulations issued by the Internal Revenue Service (“IRS”), the value of “other benefits” provided under qualified annuity Contracts are included for purposes of calculating required minimum distributions. These other benefits include the value of any guaranteed minimum death benefits provided under your Contract. These benefits will be considered in

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calculating required minimum distributions and do impact the amount of your required minimum distribution. If you are purchasing a qualified Contract, you should consult a tax professional.

To the extent Purchase Payments have a zero cost basis (were made with pre-tax dollars), distributions will be taxed as ordinary income. Under some circumstances, you may be able to make “after-tax” Purchase Payments and distributions will be allocated between the "after-tax" payments and earnings and only the portion representing earnings will be taxed. In some cases, you must satisfy retirement plan or Code requirements before you take money out. For example, the Code restricts certain withdrawals from TSAs.

When this Contract is issued in connection with a qualified plan, we will amend the Contract as necessary to conform to the requirements of the plan. However, you are cautioned that the rights of any person to benefits under the retirement plan may be subject to the terms and conditions of the plan, regardless of the terms and conditions of the Contract. In addition, we will not be bound by the terms and conditions of a retirement plan to the extent such terms and conditions contradict the Contract, unless we consent.

TEMPORARY RELIEF UNDER THE CARES ACT

The Coronavirus Aid, Relief and Economic Security (CARES) Act waives the required minimum distribution rules for calendar year 2020 for (1) plans (including 401(k) plans) qualified under Code Section 401, (2) defined contribution plans described in Code Sections 403(a) and 403(b), (3) eligible governmental defined contribution plans described in Code Section 457(b) and (4) Individual Retirement Accounts and Individual Retirement Annuities described in Code Section 408. In addition, distributions which are required to be made in calendar year 2020 by reason of a required beginning date occurring in such calendar year and such distribution not having been made before January 1, 2020 are also waived. Similar penalties are imposed on premature distributions from qualified annuity Contracts. You should consult a competent tax and/or legal professional for more details regarding this penalty tax and other exemptions that may be applicable, including those related to COVID-19, and before taking or failing to take any actions related to the CARES Act.

DISTRIBUTIONS AT DEATH - QUALIFIED CONTRACTS

The Secure Act provides that in order to be treated as an annuity Contract for tax purposes, a qualified Contract must provide for owners who die after January 1, 2020 that any designated beneficiary who is not an “eligible designated beneficiary” must withdraw the entire account value by the end of the tenth year following the year of death. This rule applies regardless of whether required minimum distributions have begun. Eligible designated beneficiaries can withdraw the account value over their lives or a period not exceeding their life expectancies. Eligible designated beneficiaries include (1) the surviving spouse of the owner; (2) a child who has not reached majority (any remaining portion of the account value must be distributed within 10 years after the date the child reaches majority); (3) a disabled beneficiary; (d) a chronically ill individual; and (e) any individual not described above who is not more than 10 years younger than the employee.

TAX SHELTERED ANNUITIES - 403(b) CONTRACTS

TSAs are available to eligible employees of public school systems and organizations that are tax exempt under Section 501(c)(3) of the Code. These qualifying employers may make contributions to the Contracts for the benefit of their employees. Such contributions are not includable in the gross income of the employees until the employees receive distributions from the Contracts. Effective on January 1, 2009, Department of Treasury 403(b) regulations went into effect. The regulations generally require employers offering 403(b) plans to maintain those plans pursuant to a written plan document and to coordinate administration of the various Contracts funding such plans. Depending on the employer’s written plan, there may be restrictions on the availability of loans, distributions, transfers and exchanges. Purchase Payments made on a Contract may be subject to FICA (social security) tax.

If your Contract is issued pursuant to a 403(b) plan, we generally are required to confirm with your 403(b) plan sponsor that your Purchase Payments to, or surrender, withdrawals, transfers or loans from your Contract comply with applicable tax requirements before we process those transactions and to decline Purchase Payments or requests that are not in compliance. These transactions cannot be processed until all information required under the tax law is received. By directing Purchase Payments to the Contract or requesting any one of these payments, you consent to the sharing of confidential information about you, the Contract, and any other 403(b) Contracts or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

As a general matter, all Contracts that have received plan contributions after 2004 are required to be included in the 403(b) written plan and subject to your employer’s administration. The rules are complex, and this discussion is not intended as tax

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advice. The IRS continues to issue guidance and clarification regarding the rules. Some rules may be subject to different interpretations. You should consult your own tax professional or your employer to discuss the regulations.

WITHDRAWALS FROM ROTH IRAS AND ROTH TSAS

Qualified distributions from Roth IRA and Roth TSA annuities are entirely federal income tax free. A qualified distribution requires that the individual has held the Roth IRA or Roth TSA for at least five years and, in addition, that the distribution is made after the individual reaches age 591/2, on account of the individual’s death or disability, or, for Roth IRAs only, as a qualified first-time home purchase, subject to $10,000 lifetime maximum, for the individual, or for a spouse, child, grandchild, or ancestor.

WITHDRAWALS FOR INVESTMENT ADVISOR FEES

The IRS has held in private letter rulings that the payment of investment advisor fees from a non-qualified annuity Contract or a tax-qualified Contract need not be considered a distribution for income tax purposes if certain requirements are met. You should consult a competent tax professional for details.

OPTIONAL BENEFIT RIDERS - NON-QUALIFIED CONTRACTS

It is possible that the IRS may take the position that fees deducted for certain optional benefit riders are deemed to be taxable distributions to you. In particular, the IRS may treat fees deducted for the optional benefits as taxable withdrawals, which might also be subject to a tax penalty if withdrawn prior to age 591/2. Although we do not believe that the fees associated with any optional benefit provided under the Contract should be treated as taxable withdrawals, you should consult your tax professional prior to selecting any optional benefit under the Contract.

NON-QUALIFIED CONTRACTS

Contracts purchased with after-tax money and not part of an IRA, Roth IRA, TSA, Roth TSA, 457, or other retirement plan, are referred to as non-qualified Contracts and receive different tax treatment than qualified Contracts. Individuals may purchase non-qualified annuity Contracts without any Purchase Payment limits imposed under the Code. Your cost basis equals the total amount of the after-tax Purchase Payments remaining in the Contract. Under the Code, you generally do not pay tax on Contract earnings until received.

The Code generally treats distributions as coming first from earnings (also referred to in the Code as “income on the Contract”) and then from Purchase Payments. If the Contract Value exceeds the aggregate Purchase Payments made to the Contract, any amount withdrawn will generally be treated as coming first from income on the Contract and then, only after the income portion is exhausted, as coming from Purchase Payments. Full surrenders are treated as taxable income to the extent the amount received exceeds the investment in the Contract.

Non-qualified deferred annuity Contracts issued by the same insurer to the same Owner in the same year are treated as one Contract for tax purposes. Distributions from non-qualified Contracts are taxed as ordinary income to the extent they are attributable to earnings. Since you have already been taxed on the cost basis, distributions attributable to Purchase Payments are generally not taxed.

Under Revenue Ruling 61-201, an ordinary loss deduction may be available upon the full surrender of a Contract if the proceeds of the surrender are less than the investment in the Contract. However, the deduction will be subject to the limitation on itemized deductions. You should consult your tax professional before deducting any loss resulting from the surrender of a non-qualified annuity Contract.

In addition to ordinary income tax, withdrawals from the Contract may be subject to a ten percent (10%) penalty applied to the income portion of any premature withdrawals. The penalty is not imposed on amounts received: (a) after the taxpayer reaches age 591/2; (b) after the death of the Owner; (c) if the taxpayer is totally disabled (for this purpose disability is as defined in Section 72(m)(7) of the Code); (d) as a series of substantially equal periodic payments made not less frequently than annually for the life (or life expectancy) of the taxpayer or for the joint lives (or joint life expectancies) of the taxpayer and his or her beneficiary; or (e) which are allocable to Purchase Payments made prior to August 14, 1982. With respect to (d) above, if the series of substantially equal periodic payments is modified before the later of your attaining age 591/2 or five years from the date of the first periodic payment, then the tax for the year of the modification is increased by an amount equal to the tax which would have been imposed but for the exception, plus interest for the tax years in which the exception was used.

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If the Contract’s Income Phase occurs at a time when the Annuitant has reached an advanced age (e.g., past age 95), it is possible that the Contract would not be treated as an annuity for federal income tax purposes. In that event, gains under the Contract could be currently includable in your income.

DISTRIBUTIONS AT DEATH - NON-QUALIFIED CONTRACTS

In order to be treated as an annuity Contract for tax purposes, a non-qualified Contract must provide that:

1.If the Owner dies before annuity payments begin, the entire interest in the Contract must be distributed within five years after the date of the Owner’s death. If payable to a designated beneficiary, the distributions may be paid over the life or life expectancy of that designated beneficiary, so long as the payouts begin within one year of the Owner’s death. If the sole designated beneficiary is the spouse of the Owner, the Contract may be continued in the name of the spouse as Owner; or

2.If the Owner dies on or after annuity payments begin, the remainder of any interest in the Contract must be distributed at least as rapidly as that provided for in the method in effect on the date of death.

If the Owner is not a natural person, then for purposes of these distribution rules, the Primary Annuitant is considered the Owner. In addition, when the Owner is not a natural person, a change in the Annuitant is treated as the death of the Owner.

TAXATION OF ANNUITY PAYMENTS

Although tax consequences may vary depending on the payout option elected under an annuity Contract, a portion of each annuity payment is generally not taxed and the remainder is taxed as ordinary income. The non-taxable portion of an annuity payment is generally determined in a manner that is designed to allow you to recover your after-tax investment in the Contract. For qualified Contracts, the after-tax investment may be zero. The exclusion ratio is determined when annuity payments start. It is applied to each annuity payment over the expected stream of annuity payments, so that each annuity payment is taxable in part and tax-free in part. Once your investment in the Contract has been fully recovered, however, the full amount of each annuity payment is subject to tax as ordinary income.

EFFECT OF CIVIL UNIONS AND DOMESTIC PARTNERSHIPS

For non-qualified and qualified annuities, there may be certain distribution options or elections available under federal tax law to beneficiaries who are “spouses” as defined under federal tax law. For federal tax law purposes, a "spouse" is a person recognized as a "spouse" in the state where the couple was legally married. The term does not include a party to a registered domestic partnership, civil union, or similar formal relationship recognized under state law that is not denominated a marriage under the state's law. Accordingly, these same options are not available to surviving beneficiaries who are “civil union partners,” “domestic partners” or other similar relationships as recognized under the laws of certain states. The administration of spousal rights and the related tax reporting for the Contract will be done in a manner consistent with federal tax law requirements. The rights and benefits of civil union, domestic partnerships and other similar relationships under federal law are complex. Therefore, you should contact an attorney to discuss the availability of options and elections available to your surviving partner.

EXCHANGES

Generally you can exchange one non-qualified Contract for another in a tax-free exchange under Section 1035 of the Code. In addition, if your Contract is a qualified Contract, then it will generally qualify as a tax free rollover or transfer.

Beginning in 2015, 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 your 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 and rollovers from traditional to Roth IRAs are not limited.

If you exchanged part of an existing Contract for this Contract, and within 180 days of the exchange you receive a payment (e.g., you make a withdrawal) from either Contract, the exchange may not be treated as a tax-free exchange. Rather, the exchange may be treated as if you had made a taxable withdrawal from the existing Contract and then purchased this Contract. Subject to certain exceptions, some or all of the amount exchanged into this Contract could be includible in your income and subject to the 10% tax described in the “Non-Qualified Contracts” section of this prospectus.

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If you are considering a partial exchange of an annuity Contract, you should consider the conditions described by Revenue Procedure 2011-38, effective for transfers that are completed on or after October 24, 2011. Under Revenue Procedure 2011-38: (1) the period of time after which cash can be withdrawn from either Contract is 180 days beginning on the date of the transfer and (2) annuity payments that satisfy the newly enacted partial annuitization rule under Section 72(a)(2) of the Code will not be treated as a distribution from either the old or new Contract. We do not allow partial annuitizations for this Contract.

In a private letter ruling, the IRS allowed the beneficiary of a series of several fixed and variable non-qualified inherited annuities to complete an exchange under Section 1035 of the Code of those Contracts into a new variable annuity so long as the technical requirements for the exchange under Section 1035 of the Code were honored, and the beneficiary committed to taking post-death distributions from the new annuity at least as rapidly as were occurring under the old Contract. Private letter rulings only apply to the taxpayer who requested the ruling, therefore, a beneficiary contemplating an exchange under Section 1035 of the Code of an inherited annuity Contract should consult with their tax professional.

Before making an exchange, you should compare both Contracts carefully. You may have to pay a surrender charge on your existing annuity Contract; other charges may be higher (or lower) and the benefits may be different. You should not make an exchange unless you determine, after knowing all the facts, that the exchange is in your best interest.

A transfer or assignment of ownership of a Contract, the designation of an Annuitant, the selection of certain maturity dates, or the exchange of a Contract may result in certain tax consequences to you that are not discussed here. An Owner contemplating any such transfer, assignment or exchange, should consult a tax professional as to the tax consequences.

DIVERSIFICATION/OWNERSHIP

Non-qualified variable annuity Contracts are treated as annuities for tax purposes and receive tax deferral as long as the Sub-accounts meet diversification standards set by the Code and applicable regulations. This favorable tax treatment allows you to select and make transfers among Sub-accounts without paying income tax until you take money out.

The diversification standards generally require each Sub-account to meet certain investment tests so that the concentration of the Portfolio’s underlying investments does not exceed certain percentages. The diversification requirements do not apply to IRA annuities or annuities issued to other qualified plans. If a Sub-account failed to comply with these diversification requirements, a non-qualified Contract would not be treated as an annuity for federal income tax purposes and the Owner would be currently taxed on the excess of the Contract Value over the investment in the Contract. We intend that the Portfolios of the corresponding Sub-accounts offered under the Contract be managed to comply with existing diversification standards. However, you bear the risk that the non-qualified Contract could be disqualified as an annuity due to the failure of a Portfolio or Sub-account to be deemed to be adequately diversified.

In certain circumstances, a variable contract owner may be considered the owner of the assets of a segregated account, such as the Separate Account, if the IRS deems the owner to possess “ownership” in those assets, such as the ability to exercise investment control over the assets. If the contract owner is deemed to have "investor control" over the underlying Portfolios, then the contract owner will be taxed currently on income and recognized gains under the Contract. Under this Contract, you have the option to invest in a number of Sub-accounts. To date, neither Treasury Regulations nor the Code give specific guidance as to the circumstances under which your Contract might lose its tax favored status as an annuity because of the number and type of Sub-accounts you can select from, and the extent to which you can make transfers. If issued, such guidance could be applied either prospectively or retroactively and result in you being treated as the Owner of the Separate Account investments, thereby resulting in the loss of the favorable tax treatment as an annuity Contract. The IRS issued Revenue Ruling 2003-91, which provides a safe harbor whereby the owner of a variable Contract will not be treated as the owner of the underlying assets, and up to 20 investment options and 12 free transfers per year are allowed. Due to the uncertainty in this area, we reserve the right to modify the Contract in an attempt to maintain favorable tax treatment. However, there is no assurance that such modifications would be successful.

TAX WITHHOLDING

Generally, federal income tax is withheld from the taxable portion of withdrawals at a rate of 10%. Withholding on periodic payments as defined by the Code is at the same rate as wages. Typically, you may elect not to have income taxes withheld or to have withholding done at a different rate. Certain “eligible rollover distributions” from qualified retirement 403(b) and governmental 457 plans, which are not directly rolled over to another eligible retirement plan or IRA, are subject to a mandatory 20% withholding. For this purpose, an eligible rollover distribution is any distribution to an employee from such a plan, except (i) a series of substantially equal payments made at least annually for the life or life expectancy of the participant or

40

joint and last survivor expectancy of the participant and a designated beneficiary; (ii) distributions for a specified period of 10 years or more; (iii) distributions which are required minimum distributions; (iv) the portion of distributions not includable in gross income (i.e. returns of after-tax contributions); (v) hardship distributions; or (vi) corrective distributions. It also does not apply if (i) the employee (or employee’s spouse or former spouse as beneficiary or alternate payee) chooses a “direct rollover” from the plan to a tax-qualified plan, IRA, Roth IRA or TSA or to a governmental 457 plan that agrees to separately account for rollover contributions; or (ii) a non-spouse Beneficiary chooses a “direct rollover” from the plan to an IRA established by the direct rollover. Special withholding rules apply to United States citizens residing outside the United States and to non-resident aliens. You should consult your own tax counsel or other tax professional regarding income tax withholding.

FEDERAL ESTATE TAXES

While no attempt is being made to discuss the federal estate tax implications of the Contract, you should keep in mind that the value of an annuity Contract owned by a decedent and payable to a beneficiary by virtue of surviving the decedent is included in the decedent’s gross estate. Depending on the terms of the annuity Contract, the value of the annuity included in the gross estate may be the value of the lump sum payment payable to the designated beneficiary or the actuarial value of the payments to be received by the beneficiary. Consult an estate planning professional for more information.

GENERATION-SKIPPING TRANSFER TAX

Under certain circumstances, the Code may impose a “generation skipping transfer tax” when all or part of an annuity Contract is transferred to, or a death benefit is paid to, an individual two or more generations younger than the Owner. Regulations issued under the Code may require us to deduct the tax from your Contract, or from any applicable payment, and pay it directly to the IRS.

AMERICAN TAXPAYER RELIEF ACT OF 2012

The American Taxpayer Relief Act: (1) permanently provides for a maximum federal estate tax rate, gift tax rate and generation skipping transfer tax rate of 40% with an inflation-adjusted $5 million lifetime unified estate and gift tax exclusion and a $5 million generation skipping transfer exclusion; (2) makes permanent “portability” between spouses which allows the estate of a decedent who is survived by a spouse to permit the surviving spouse to use the decedent’s unused $5 million lifetime exclusion; and (3) extends a number of generation skipping transfer provisions. The Tax Cuts and Jobs Act temporarily doubles the exemption amount, indexed for inflation, for estate, gift and generation-skipping taxes from the $5 million base set in 2011, to a new $10 million base, good for years 2018 through 2025.

MEDICARE TAX

Distributions from non-qualified annuity Contracts will be considered “investment income” for purposes of the 3.8% Medicare tax on investment income. Thus, in certain circumstances, this tax will be applied to some or all of the taxable portion of distributions (e.g. earnings) to individuals whose income exceeds certain threshold amounts. Please consult a tax professional for more information.

ANNUITY PURCHASES BY NONRESIDENT ALIENS AND FOREIGN CORPORATIONS

The discussion above provides general information regarding U.S. federal income tax consequences to annuity purchasers that are U.S. citizens or residents. If you are not a U.S. citizen or resident, you will generally be subject to U.S. federal withholding tax on taxable distributions from annuity Contracts at a 30% rate, unless a lower treaty rate applies. In addition, you may be subject to state and/or municipal taxes and taxes that may be imposed by your country of citizenship or residence. You should consult with a qualified tax professional regarding U.S. state, and foreign taxation with respect to an annuity Contract purchase.

FOREIGN TAX CREDITS

We may benefit from any foreign tax credits attributable to taxes paid by certain Portfolios to foreign jurisdictions to the extent permitted under federal tax law.

POSSIBLE TAX LAW CHANGES

Although the likelihood of legislative changes is uncertain, there is always the possibility that the tax treatment of the Contract could change by legislation or otherwise. Consult a tax professional with respect to legislative developments and their effect on the Contract.

We have the right to modify the Contract in response to legislative changes that could otherwise diminish the favorable tax treatment that annuity contract owners currently receive. We make no guarantee regarding the tax status of any contact and do not intend the above discussion as tax advice.

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OTHER INFORMATION

DISTRIBUTION (PRINCIPAL UNDERWRITER)

The Contracts are no longer for sale. While the Contracts were offered for sale, they were distributed by Symetra Securities, Inc. (“SSI”) and sold by individuals who, in addition to being licensed to sell variable annuity Contracts for Symetra Life, were also registered representatives of broker-dealers who entered into a sales agreement with SSI and Symetra Life. SSI is an affiliate of Symetra Life and is located at 777 108th Avenue NE, Suite 1200, Bellevue, Washington 98004. It is registered as a broker-dealer with the SEC under the Securities Act of 1934 and is a member of the Financial Industry Regulatory Authority (“FINRA”). No amounts are retained by SSI for acting as principal underwriter for Symetra Life variable products.

While the Contracts were offered for sale, we may have Contracted with firms to act as wholesalers for us and assist us in offering and selling our Contracts to broker-dealers and their registered representatives. Wholesalers may also be called “independent marketing organizations” and provide training, marketing and other sales-related functions. Wholesalers may also provide administrative services to us in connection with the Contracts. Wholesalers may be paid commissions and overrides.

To the extent permitted by FINRA rules, promotional incentives or payments may have been provided to broker-dealers and wholesalers based on sales volumes, the assumption of wholesaling functions or other sales-related criteria. Other payments may have been made for other services that do not directly involve the sale of the Contracts. These services may include the recruitment and training of personnel, production of promotional literature, and similar services.

These additional incentives or payments are calculated in different ways and are not offered to all broker-dealer firms. They may be based on assets under management, Purchase Payments received, or other criteria. These additional incentives or payments could create an incentive for your registered representative, and the broker-dealer with which they are associated to recommend products that pay them more than others. You should only exchange a variable annuity Contract for a new one if you determine, after comparing the features, fees and risks of both Contracts, that it is in your best interest to purchase a new Contract rather than continue to own the existing Contract.

This Contract does not assess a front-end sales charge. You indirectly pay for commissions and other sales expenses primarily, but not exclusively, through: the contingent deferred sales charge; the mortality and expense risk charge; and investment earnings on amounts allocated under the Contract to the Symetra Fixed Account. We may also pay for sales and distribution expenses out of any payments we receive from the underlying Portfolios for providing administrative, distribution and other services to the Portfolios.

COMPENSATION WE RECEIVE FROM PORTFOLIOS

We have agreements with each of the Portfolio advisors or their affiliates that describe the administrative practices and responsibilities of the parties. We receive compensation from some or all of the Portfolios or their investment advisors, administrators, and/or distributors (or their affiliates) in connection with administrative or other services provided with respect to the Portfolios. We may use this compensation for any purpose, including paying expenses that we incur in promoting, issuing, distributing and administering the Contract. We also receive this compensation for providing services to Contract Owners invested in the Portfolios on behalf of the Portfolios. The amounts we receive, if any, may be different for different Portfolios, and usually depend on how much we have invested in the applicable Portfolio. The compensation amount is typically determined by multiplying a specified annual percentage rate by the average net assets held in that Portfolio for the variable annuity Contracts and variable life insurance policies issued by us that offer that particular Portfolio. Currently, the maximum percentage rate we receive for any Portfolio offered under this Contract is 0.30%. Some advisors may pay us less; some do not pay us any such compensation.

The compensation we receive is paid by the advisor or its affiliate out of profits which may include fees the advisor deducted from fund assets or from the advisor’s (or its affiliate’s) other sources of revenue. You will bear the costs of these fees indirectly through your investment in the Sub-accounts that invest in these Portfolios. You may obtain a list of such fees that we receive by contacting us at our Account Maintenance address. The compensation that we receive may be significant and we may profit from this compensation.

In addition, some of the Portfolios may make payments to us or our affiliates pursuant to a distribution and/or servicing plan adopted by the Portfolio pursuant to Rule 12b-1 under the Investment Company Act of 1940. The 12b-1 fees are for distribution and/or servicing that we perform on behalf of the Portfolios. Such distribution and/or servicing fee is disclosed in the prospectus

42

for each Portfolio and is paid directly out of Portfolio assets. Currently, the maximum percentage rate we receive for any Portfolio is 0.25%. Some advisors may pay us less; some do not pay us any such compensation.

When determining which Portfolios to offer in our variable Contracts, we consider the Portfolios’ name recognition, investment objective, performance, and reputation. We also consider the amount of compensation that we receive from the Portfolios, their advisors, or their distributors. We review our Portfolios periodically. Based upon our review, we may remove or restrict allocation of additional Purchase Payments and/or transfers of Contract Value to a Portfolio if the Portfolio no longer meets one or more of the criteria. We do not recommend any particular Portfolio, and we do not provide investment advice.

Although the compensation we receive may be used indirectly for distribution of the Contracts, compensation for selling the Contracts is set by Symetra Life and paid directly by us to the broker-dealer selling you this Contract.

REPORTS TO OWNERS

We will send you an immediate confirmation of certain non-systematic transactions, such as Purchase Payments made, loans, loan repayments, withdrawals, transfers among Sub-accounts, death benefit payments and any changes to your Sub-account allocations. We will also send you a quarterly statement which will show (as of quarter end), any purchase and sale transactions, your current Sub-account allocations, and any earnings or losses for the quarter. The quarterly statement will also include confirmations of your transactions under scheduled transfer options such as Dollar Cost Averaging, Appreciation or Interest Sweep, and Sub-account Rebalancing. Your fourth quarter statement will contain annual information about your Contract Value and transactions. On request, we will send you a current statement with the information described above.

AMENDMENTS TO THE CONTRACT

We reserve the right to amend the Contract to meet the requirements of applicable federal or state laws or regulations. You will be notified in writing of any changes, modifications or waivers.

LEGAL PROCEEDINGS

There are no legal proceedings to which the Separate Account or SSI is a party. In the ordinary course of business, Symetra Life is engaged in various kinds of litigation, including class action and other lawsuits, or in arbitration. In some class action and other lawsuits involving insurance companies and other financial service providers, substantial damages have been sought and material settlement payments have been made. Although the outcome of any litigation cannot be predicted with certainty, at the present time it appears that there are no pending or threatened lawsuits that are likely to have a material adverse effect on the Separate Account, on Symetra Life’s ability to meet its obligations under the Contract, or on SSI’s ability to perform under its principal underwriting agreement.

RIGHT TO SUSPEND ANNUITY PAYMENTS, TRANSFERS, OR WITHDRAWALS

We may be required to suspend or postpone payment of annuity payments, transfers, or withdrawals from the Sub-accounts for any period of time when:

•the NYSE is closed (other than customary weekend or holiday closings);

•trading on the NYSE is restricted;

•an emergency exists such that disposal of or determination of the value of the Sub-account shares is not reasonably practicable; or

•the SEC, by order, so permits for your protection.

Additionally, we reserve the right to defer payment of transfers or withdrawals from the Symetra Fixed Account for the period permitted by law, but not for more than six months.

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” your Contract. If these laws apply in a particular situation, we would not be allowed to process any request for withdrawals, surrenders, or death benefits, make transfers, or continue making payments under an annuity payment option. We may also be required to provide additional information about you or your Contract to government regulators.

FINANCIAL STATEMENTS

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The financial statements of Symetra Life Insurance Company and Symetra Separate Account C are included in the Statement of Additional Information.

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APPENDIX A: PORTFOLIOS AVAILABLE UNDER THE CONTRACT

The following is a list of Portfolios available under the Contract. More information about the Portfolios is available in the prospectuses for the Portfolios, which may be amended from time to time and can be found online at www.symetra.com/regulatoryreports. You can also request this information at no cost by calling 1-800-796-3872 or by sending an email request to regulatoryreports@symetra.com.

The current expense and performance information below reflects fees and expenses of the Portfolios, but do not reflect the other fees and expenses that your Contract may charge. Expenses would be higher and performance would be lower if these other charges were included. Each Portfolio’s past performance is not necessarily an indication of future performance.

TYPE	FUND NAME AND ADVISOR	CURRENT EXPENSES (As of 12/31/2020)	AVERAGE ANNUAL TOTAL RETURN (As of 12/31/2020)
			1 Year	5 Year	10 Year
Asset Allocation	American Century VP Balanced Fund Class I American Century Investment Management, Inc.	0.86% **	12.53%	9.58%	8.86%
Taxable Bond	American Century VP Inflation Protection Fund Class II American Century Investment Management, Inc.	0.72%	9.55%	4.64%	3.33%
International Equity	American Century VP International Fund Class I American Century Investment Management, Inc.	1.00% **	25.88%	11.17%	7.75%
U.S. Equity	American Century VP Large Company Value Fund Class II American Century Investment Management, Inc.	0.89% **	2.49%	8.85%	9.78%
U.S. Equity	American Century VP Ultra® Fund Class I (1) (2) American Century Investment Management, Inc.	0.8% **	49.85%	22.89%	17.86%
U.S. Equity	American Century VP Ultra®Fund Class II (2) American Century Investment Management, Inc.	0.95% **	49.55%	22.72%	17.68%
U.S. Equity	American Century VP Value Fund Class I American Century Investment Management, Inc.	0.73% **	0.98%	8.82%	9.72%
U.S. Equity	BNY Mellon Investment Portfolios MidCap Stock Portfolio - Initial Shares (3) BNY Mellon Investment Advisors, Inc.	0.87%	8.11%	7.90%	10.02%
Sector Equity	BNY Mellon Investment Portfolios Technology Growth Portfolio - Initial Shares BNY Mellon Investment Advisors, Inc.	0.78%	69.92%	25.89%	17.64%
U.S. Equity	BNY Mellon Stock Index Fund, Inc. - Service Shares BNY Mellon Investment Advisors, Inc.	0.52%	17.71%	14.63%	13.31%
U.S. Equity	BNY Mellon Sustainable U.S. Equity Portfolio, Inc. - Initial Shares BNY Mellon Investment Advisors, Inc.	0.68%	24.14%	15.21%	12.96%
U.S. Equity	BNY Mellon Variable Investment Fund Appreciation Portfolio - Initial Shares (3) BNY Mellon Investment Advisors, Inc.	0.81%	23.69%	16.59%	12.72%
International Equity	Calvert VP EAFE International Index Portfolio - Class F Calvert Research and Management	0.68% **	7.56%	6.94%	4.65%
Taxable Bond	Calvert VP Investment Grade Bond Index Portfolio - Class I Calvert Research and Management	0.32% **	7.34%	4.24%	3.62%
U.S. Equity	Calvert VP Nasdaq - 100 Index Portfolio - Class I Calvert Research and Management	0.48% **	48.22%	23.61%	19.93%
U.S. Equity	Calvert VP Russell 2000 Small Cap Index Portfolio - Class F Calvert Research and Management	0.59% **	19.40%	12.66%	10.38%
U.S. Equity	Calvert VP S&P MidCap 400 Index Portfolio - Class F Calvert Research and Management	0.53% **	13.10%	11.72%	10.78%
Asset Allocation	Calvert VP SRI Balanced Portfolio - Class I Calvert Research and Management	0.63%	15.26%	10.94%	9.40%
U.S. Equity	DWS Capital Growth VIP - Class B DWS Investment Management Americas, Inc.	0.75%	38.70%	19.52%	15.97%
International Equity	DWS CROCI® International VIP - Class A DWS Investment Management Americas, Inc.	0.88% **	2.61%	5.62%	2.85%
Asset Allocation	DWS Global Income Builder VIP - Class A (4) DWS Investment Management Americas, Inc.	0.64%	8.28%	8.38%	7.11%

A-1

TYPE	FUND NAME AND ADVISOR	CURRENT EXPENSES (As of 12/31/2020)	AVERAGE ANNUAL TOTAL RETURN (As of 12/31/2020)
			1 Year	5 Year	10 Year
International Equity	DWS Global Small Cap VIP - Class B DWS Investment Management Americas, Inc.	1.10% **	16.94%	6.34%	6.30%
International Equity	DWS International Growth VIP - Class B DWS Investment Management Americas, Inc.	1.17% **	22.29%	11.47%	7.56%
Taxable Bond	Federated Hermes High Income Bond Fund II - Primary Shares (3) Federated Investment Management Company	0.81% **	5.59%	7.51%	6.37%
Asset Allocation	Federated Hermes Managed Volatility Fund II - Primary Shares (5) Federated Global Investment Management Corp. ("Fed Global")Federated Investment Management Company ("FIMCO") and Federated Equity Management Company of Pennsylvania ("FEMCOPA")	0.96%	0.93%	7.15%	6.99%
Asset Allocation	Fidelity® VIP Asset Manager Portfolio - Initial Class (5) Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.60%	14.87%	8.62%	7.35%
U.S. Equity	Fidelity® VIP Contrafund® Portfolio - Initial Class Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.61%	30.57%	16.19%	13.52%
U.S. Equity	Fidelity® VIP Equity-Income Portfolio℠ - Initial Class Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.53%	6.69%	10.69%	10.17%
Target Date	Fidelity® VIP Freedom 2010 Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.70%	12.24%	8.10%	6.77%
Target Date	Fidelity® VIP Freedom 2015 Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.74%	13.56%	8.99%	7.34%
Target Date	Fidelity® VIP Freedom 2020 Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.78%	14.72%	9.70%	7.88%
Target Date	Fidelity® VIP Freedom 2025 Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.81%	15.68%	10.30%	8.62%
Target Date	Fidelity® VIP Freedom 2030 Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.84%	16.64%	11.31%	9.24%
Target Date	Fidelity® VIP Freedom Income Portfolio℠ - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. (*)	0.64%	10.29%	6.31%	4.71%
Money Market	Fidelity® VIP Government Money Market Portfolio - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.49%	0.24%	0.77%	0.39%
U.S. Equity	Fidelity® VIP Growth Opportunities Portfolio - Initial Class (4) Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.64%	68.66%	29.24%	21.84%
U.S. Equity	Fidelity® VIP Growth Portfolio - Initial Class (3) Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.62%	43.89%	21.32%	17.25%
U.S. Equity	Fidelity® VIP Growth & Income Portfolio - Initial Class Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.54%	7.85%	11.62%	11.66%
U.S. Equity	Fidelity® VIP Mid Cap Portfolio - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK and FMR Japan serve as sub-advisers for the fund. (*)	0.87%	17.87%	10.79%	9.22%
International Equity	Fidelity® VIP Overseas Portfolio - Service Class 2 Fidelity Management & Research Company (FMR) is the fund's Investment Advisor. FMR UK, FMR HK, FMR Japan, FIA FIA(UK) and FIJ serve as sub-advisers for the fund. (*)	1.04%	15.33%	8.98%	6.56%
Asset Allocation	Franklin Allocation VIP Fund - Class 2 Franklin Advisers, Inc. Sub-advised by Franklin Templeton Institutional, LLC and Templeton Global Advisors Limited	0.82% **	11.74%	8.93%	7.59%
U.S. Equity	Franklin DynaTech VIP Fund - Class 2 Franklin Advisers, Inc.	0.94%	44.88%	19.30%	14.36%
Asset Allocation	Franklin Income VIP Fund - Class 2 Franklin Advisers, Inc.	0.72% **	0.69%	6.94%	5.98%

A-2

TYPE	FUND NAME AND ADVISOR	CURRENT EXPENSES (As of 12/31/2020)	AVERAGE ANNUAL TOTAL RETURN (As of 12/31/2020)
			1 Year	5 Year	10 Year
Asset Allocation	Franklin Mutual Shares VIP Fund - Class 2 Franklin Mutual Advisers, LLC	0.98%	(5.04)%	5.88%	6.99%
U.S. Equity	Franklin Small Cap Value VIP Fund - Class 2 Franklin Mutual Advisers, LLC	0.93%	5.19%	10.77%	9.20%
U.S. Equity	Franklin Small-Mid Cap Growth VIP Fund - Class 2 Franklin Advisers, Inc.	1.10% **	55.09%	19.52%	14.04%
Taxable Bond	Franklin U.S. Government Securities VIP Fund - Class 2 Franklin Advisers, Inc.	0.78%	3.83%	2.26%	2.03%
U.S. Equity	Invesco V.I. Discovery Mid Cap Growth Fund - Series I (2) Invesco Advisers, Inc.	0.80% **	40.69%	19.40%	15.92%
U.S. Equity	Invesco V.I. Discovery Mid Cap Growth Fund - Series II (2) (6) Invesco Advisers, Inc.	1.05% **	40.24%	19.09%	15.62%
U.S. Equity	Invesco V.I. American Franchise Fund - Series I (2) (3) Invesco Advisers, Inc.	0.86%	42.35%	19.56%	15.32%
U.S. Equity	Invesco V.I. American Franchise Fund - Series II Invesco Advisers, Inc.	1.11%	41.99%	19.26%	15.03%
Sector Equity	Invesco V.I. Global Real Estate Fund - Series I (3) Invesco Advisers, Inc. Sub-advised by Invesco Asset Management Limited	1.04%	(12.32)%	3.15%	4.96%
Sector Equity	Invesco V.I. Health Care Fund - Series I (5) Invesco Advisers, Inc.	0.98%	14.46%	9.43%	13.09%
International Equity	Invesco V.I. International Growth Fund - Series I (2) (6) Invesco Advisers, Inc.	0.92%	14.00%	8.82%	6.72%
International Equity	Invesco V.I. International Growth Fund - Series II (2) Invesco Advisers, Inc.	1.17%	13.74%	8.55%	6.46%
U.S. Equity	Invesco V.I. Small Cap Equity Fund - Series II Invesco Advisers, Inc.	1.21%	26.87%	11.55%	9.87%
U.S. Equity	JPMorgan Insurance Trust Mid Cap Value Portfolio - Class 1 Shares J.P. Morgan Investment Management Inc.	0.77%	0.37%	7.92%	10.31%
U.S. Equity	JPMorgan Insurance Trust U.S. Equity Portfolio - Class 1 Shares(4) J.P. Morgan Investment Management Inc.	0.76%	25.26%	16.01%	14.27%
Asset Allocation	Morningstar Aggressive Growth ETF Asset Allocation Portfolio - Class II ALPS Advisors, Inc. Sub-Advised by Morningstar Investment Management LLC	0.91% **	9.96%	10.17%	7.75%
Asset Allocation	Morningstar Balanced ETF Asset Allocation Portfolio - Class II ALPS Advisors, Inc. Sub-Advised by Morningstar Investment Management LLC	0.88%	9.12%	7.90%	6.26%
Asset Allocation	Morningstar Conservative ETF Asset Allocation Portfolio - Class II ALPS Advisors, Inc. Sub-Advised by Morningstar Investment Management LLC	0.86% **	6.49%	4.82%	3.64%
Asset Allocation	Morningstar Growth ETF Asset Allocation Portfolio - Class II ALPS Advisors, Inc. Sub-Advised by Morningstar Investment Management LLC	0.89%	10.01%	9.29%	7.25%
Asset Allocation	Morningstar Income and Growth ETF Asset Allocation Portfolio - Class II ALPS Advisors, Inc. Sub-Advised by Morningstar Investment Management LLC	0.87% **	8.43%	6.51%	5.00%
U.S. Equity	Neuberger Berman AMT Mid Cap Growth Portfolio - Class S Neuberger Berman Investment Advisers LLC	1.11% **	39.71%	17.54%	13.72%
U.S. Equity	Neuberger Berman AMT Mid Cap Intrinsic Value Portfolio - Class S Neuberger Berman Investment Advisers LLC	1.26% **	(2.83)%	5.23%	7.03%
U.S. Equity	Neuberger Berman AMT Sustainable Equity Portfolio - Class S Neuberger Berman Investment Advisers LLC	1.18%	19.28%	12.78%	11.40%
Asset Allocation	PIMCO All Asset Portfolio - Advisor Class Pacific Investment Management Company LLC	1.38%	7.91%	7.85%	4.54%
Commodities	PIMCO CommodityRealReturn® Strategy Portfolio - Administrative Class Pacific Investment Management Company LLC	1.24% **	1.35%	2.67%	(5.39)%
Bond	Pioneer Bond VCT Portfolio - Class I Shares (7) Amundi Asset Management US, Inc.	0.65%	8.70%	4.98%	4.63%

A-3

TYPE	FUND NAME AND ADVISOR	CURRENT EXPENSES (As of 12/31/2020)	AVERAGE ANNUAL TOTAL RETURN (As of 12/31/2020)
			1 Year	5 Year	10 Year
U.S. Equity	Pioneer Equity Income VCT Portfolio - Class II Shares Amundi Asset Management US, Inc.	1.05%	(0.26)%	9.42%	10.26%
U.S. Equity	Pioneer Fund VCT Portfolio - Class I Shares (7) Amundi Asset Management US, Inc.	0.79%	24.28%	16.53%	12.86%
Taxable Bond	Pioneer High Yield VCT Portfolio - Class II Shares Amundi Asset Management US, Inc.	1.16% **	1.98%	6.39%	5.13%
U.S. Equity	Pioneer Mid Cap Value VCT Portfolio - Class I Shares (7) Amundi Asset Management US, Inc.	0.74%	2.14%	6.90%	7.72%
Sector Equity	Pioneer Real Estate Shares VCT Portfolio - Class II Shares Amundi Asset Management US, Inc.	1.71%	(7.62)%	3.61%	7.74%
U.S. Equity	Pioneer Select Mid Cap Growth VCT Portfolio - Class I Shares (7) Amundi Asset Management US, Inc.	0.89%	39.17%	18.50%	14.50%
Taxable Bond	Pioneer Strategic Income VCT Portfolio - Class II Shares Amundi Asset Management US, Inc.	1.04% **	7.37%	5.33%	4.20%
International Equity	Templeton Developing Markets VIP Fund - Class 2 Templeton Asset Management Ltd. Sub-advised by Franklin Templeton Investment Management Limited	1.44%	17.18%	15.57%	3.56%
Taxable Bond	Templeton Global Bond VIP Fund - Class 2 Franklin Advisers, Inc.	0.74% **	(4.92)%	0.66%	1.56%
International Equity	Templeton Growth VIP Fund - Class 2 Templeton Global Advisors Limited	1.16%	5.80%	6.15%	6.08%
International Equity	Voya Global High Dividend Low Volatility Portfolio - Class S (5) Voya Investments, LLC	0.85% **	(1.09)%	7.34%	6.24%
International Equity	VY JPMorgan Emerging Markets Equity Portfolio - Class I (8) Voya Investments, LLC Sub-Advised by J.P. Morgan Investment Management, Inc.	1.25%	33.52%	19.07%	6.56%

We do not guarantee that each Portfolio will be available for investment through the Contract.

1. This portfolio is only available if you have continuously invested in it since March 15, 2007

2. If Class I/Series I shares are available to a contract Owner, we will allocated investments to the Class I/Series I fund

3. This portfolio is only available if you have continuously invested in it since April 30, 2006

4. This portfolio is only available if you have continuously invested in it since April 30, 2003

5. This portfolio is only available if you have continuously invested in it since April 28, 2005

6. This portfolio is only available if you have continuously invested in it since March 14, 2006

7. This portfolio is only available if you have continuously invested in it since November 30, 2004

8. This portfolio is only available if you have continuously invested in it since April 30, 2000

* Fidelity, the Fidelity Investments Logo, Contrafund, Equity Income, VIP Freedom 2010 Portfolio, VIP Freedom 2015 Portfolio, VIP Freedom 2020 Portfolio, VIP Freedom 2025 Portfolio, VIP Freedom 2030 Portfolio, VIP Freedom Income Portfolio are registered service marks of FMR LLC.  Used with permission.

** Annual expenses reflect temporary fee reductions.

A-4

APPENDIX B: CALCULATION OF BASIC DEATH BENEFIT, GMDB-ANNUAL RESET,
AND EEB OPTIONAL DEATH BENEFIT

CALCULATION OF BASIC DEATH BENEFIT

EXAMPLE 1:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract is currently in year 5. On the day we calculate the death benefit, the Contract Value is $45,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$45,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000)	=	$24,000
Initial guaranteed minimum death benefit (purchase payment)	=	$24,000
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit	=	$45,000

EXAMPLE 2:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract is currently in year 10. On the day we calculate the death benefit, the Contract Value is $45,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$45,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000)	=	$24,000
Initial guaranteed minimum death benefit (purchase payment)	=	$24,000
Contract Value on the 8th contract anniversary	=	$46,000
“Stepped-up” Guaranteed Minimum Death benefit	=	$46,000
TOTAL DEATH BENEFIT Equals the “Stepped-up” Guaranteed Minimum Death Benefit	=	$46,000

EXAMPLE 3:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000. Assume there is a $21,000 subsequent Purchase Payment made to the contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract is currently in year 7. On the day we calculate the death benefit, the Contract Value is $40,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$40,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000 + Subsequent Purchase Payment of $21,000)	=	$45,000
Guaranteed minimum death benefit (total purchase payments)	=	$45,000
TOTAL DEATH BENEFIT Equals the Guaranteed minimum death benefit on the date we calculate the benefit	=	$45,000

EXAMPLE 4:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000. Assume there is a $21,000 subsequent Purchase Payment made to the contract. Assume that there is a $10,000 withdrawal made during the life of the Contract and the Contract is currently in year 10. On the day we calculate the death benefit, the Contract Value is $115,000.

B-1

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$115,000
Total amount of Purchase Payments ($24,000 + $21,000)	=	$45,000
Withdrawals	=	-$10,000
Guaranteed Minimum Death Benefit (total Purchase Payments less proportional withdrawals) Contract Value after withdrawals ($37,000) / Contract Value prior to withdrawal ($47,000) = .7872 Initial Guaranteed Minimum Death benefit ($45,000) x .7872 = $35,424	=	$35,424
Contract Value on 8th contract anniversary	=	$90,000
“Stepped-up” Guaranteed Minimum Death Benefit	=	$90,000
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit	=	$115,000

CALCULATION OF DEATH BENEFIT UNDER GMDB-ANNUAL RESET RIDER

Each example assumes that the EEB Rider was not elected.

EXAMPLE 1:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract is currently in year 3. On the day we calculate the death benefit, the Contract Value is $45,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$45,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000)	=	$24,000
Initial guaranteed minimum death benefit (purchase payment)	=	$24,000
Contract Value on 1st contract anniversary	=	$30,000
“Stepped-up” Guaranteed Minimum Death benefit (after 1st contract Anniversary)	=	$30,000
Contract Value on 2nd contract anniversary	=	$35,000
“Stepped-up” Guaranteed Minimum Death benefit (after 2nd contract Anniversary)	=	$35,000
Contract Value on 3rd contract anniversary	=	$38,000
“Stepped-up” Guaranteed Minimum Death benefit (after 3rd contract Anniversary)	=	$38,000
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit	=	$45,000

EXAMPLE 2:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000. Assume there is a $21,000 subsequent Purchase Payment made to the contract. Assume that there is a $10,000 withdrawal made during the life of the Contract and the Contract is currently in year 5. On the day we calculate the death benefit, the Contract Value is $58,000.

B-2

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$58,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000+$21,000)	=	$45,000
Withdrawals	=	-$10,000
Initial guaranteed minimum death benefit (purchase payments less proportional withdrawals) Guaranteed Minimum Death Benefit (total Purchase Payments less proportional withdrawals) Contract Value after withdrawals ($40,000) / Contract Value prior to withdrawal ($50,000) = .80 Initial Guaranteed Minimum Death benefit ($45,000) x .80 = $36,000	=	$36,000
Contract Value on 1st contract anniversary	=	$47,000
“Stepped-up” Guaranteed Minimum Death benefit (after 1st contract Anniversary)	=	$47,000
Contract Value on 2nd contract anniversary	=	$43,000
Guaranteed Minimum Death benefit (after 2nd contract Anniversary)	=	$47,000
Contract Value on 3rd contract anniversary	=	$50,000
“Stepped-up” Guaranteed Minimum Death benefit (after 3rd contract Anniversary)	=	$50,000
Contract Value on 4th contract anniversary	=	$48,000
Guaranteed Minimum Death benefit (after 4th contract Anniversary)	=	$50,000
Contract Value on 5th contract anniversary	=	$60,000
“Stepped-up” Guaranteed Minimum Death benefit (after 5th contract Anniversary)	=	$60,000
TOTAL DEATH BENEFIT Equals the “Stepped up” Guaranteed Minimum Death Benefit on the date we calculate the benefit	=	$60,000

CALCULATION OF EEB OPTIONAL DEATH BENEFIT

Each example assumes that the GMDB-Annual Reset Rider was not elected.

EXAMPLE 1:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract was issued prior to the Owner’s 70th birthday. On the day we calculate the death benefit, the Contract Value is $45,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$45,000
Total amount of Purchase Payments (initial Purchase Payment of $24,000)	=	$24,000
Earnings equal to the Contract Value minus total amount of Purchase Payments ($45,000 - $24,000)	=	$21,000
Maximum allowable Earning of 250% of total Purchase Payments excluding any Purchase Payments made in the 12 months prior to calculation of benefit or after the date of death (2.50 x $24,000)	=	$60,000
40% of your Earnings ($21,000 x 40%)	=	$8,400
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit plus 40% of your Earnings ($45,000 + $8,400)	=	$53,400

B-3

EXAMPLE 2:

Assume that the Contract is purchased prior to the Owner’s 70th birthday with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there is a $21,000 withdrawal made during the life of the Contract. Assume that the account value prior to the withdrawal was equal to or greater than $45,000. Thus, the withdrawal consisted entirely of Contract earnings and did not impact the Purchase Payment made to the Contract. On the day we calculate the death benefit, the Contract Value is $24,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$24,000
Total amount of Purchase Payments (Initial Purchase payment of $24,000)	=	$24,000
Earnings equal to the Contract Value minus total amount of Purchase Payments ($24,000 - $24,000)	=	$0
Maximum allowable Earning of 250% of total Purchase Payments excluding any Purchase Payments made in the 12 months prior to calculation of benefit or after the date of death (2.50 x $24,000)	=	$60,000
40% of your Earnings ($0 x 40%)	=	$0
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit plus 40% of your Earnings ($24,000 + $0.00)	=	$24,000

EXAMPLE 3:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract was issued prior to the Owner’s 70th birthday. On the day we calculate the death benefit, the Contract Value is $91,500.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$91,500
Total amount of Purchase Payments (initial Purchase Payment of $24,000)	=	$24,000
Earnings equal to the Contract Value minus total amount of Purchase Payments ($91,500 - $24,000)	=	$67,500
Maximum allowable Earning of 250% of total Purchase Payments excluding any Purchase Payments made in the 12 months prior to calculation of benefit or after the date of death (2.50 x $24,000)	=	$60,000
40% of your maximum allowable Earnings ($60,000 x 40%)	=	$24,000
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit plus 40% of your maximum allowable earnings ($91,500 + $24,000)	=	$115,500

EXAMPLE 4:

Assume that the Contract is purchased prior to the Owner’s 70th birthday with an initial Purchase Payment of $24,000. Assume that there is a $21,000 subsequent Purchase Payment made to the Contract in the 12 months prior to the calculation of the death benefit. On the day we calculate the death benefit, the Contract Value is $91,500.

B-4

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$91,500
Total amount of Purchase Payments ($24,000 + $21,000)	=	$45,000
Earnings equal to the Contract Value minus total amount of Purchase Payments ($91,500 - $45,000)	=	$46,500
Maximum allowable Earning of 250% of total Purchase Payments excluding any Purchase Payments made in the 12 months prior to calculation of benefit or after the date of death (2.50 x $24,000)	=	$60,000
40% of your Earnings ($46,500 x 40%)	=	$18,600
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit plus 40% of your Earnings ($91,500 + $18,600)	=	$110,100

EXAMPLE 5:

Assume that the Contract is purchased with an initial Purchase Payment of $24,000 and no subsequent Purchase Payments are made to the Contract. Assume that there have been no withdrawals made during the life of the Contract and the Contract was issued when the Owner was age 72. On the day we calculate the death benefit, the Contract Value is $45,000.

Based upon the assumptions above, the following shows how we would do the calculation.
Contract Value on the date we calculate benefit	=	$45,000
Total amount of Purchase Payments (Initial Purchase Payment of $24,000)	=	$24,000
Earnings equal to the Contract Value minus total amount of Purchase Payments ($45,000 - $24,000)	=	$21,000
Maximum allowable Earning of 250% of total Purchase Payments excluding any Purchase Payments made in the 12 months prior to calculation of benefit or after the date of death (2.50 x $24,000)	=	$60,000
25% of your Earnings ($21,000 x 25%)	=	$5,250
TOTAL DEATH BENEFIT Equals the Contract Value on the date we calculate the benefit plus 25% of your Earnings ($45,000 + $5,250)	=	$50,250

B-5

APPENDIX C: STATE VARIATIONS

The following information is a summary of the states where the Spinnaker Contract or certain features and/or benefits vary from the Contract’s features and benefits as previously described in this prospectus. Certain provisions of the Contract may be different from the description in this prospectus due to variations required by state law. The state in which your Contract was issued also governs whether or not certain riders, options, charges or fees are available or will vary under your Contract. Any state variations will be included in your Contract or in riders attached to your Contract.

STATE	FEATURE OR BENEFIT	VARIATION OR AVAILABILITY
California	See “Owner” under the section titled “General Description of the Contract”.	The Owner and any joint Owner are shown on the contract application and cannot be changed.
	See “Annuity Options” under the section titled “Annuity Payments (Income Phase)”.	If you do not choose an annuity option at least 30 calendar days before the latest Annuity Date specified in your Contract, we will make annuity payments under the Life Annuity with Guaranteed Period annuity option. The guaranteed period will be equal to 10 years, unless a shorter period is otherwise required.
Florida	See “Owner” under the section titled “General Description of the Contract”.	The Owner and any joint Owner are shown on the contract application and cannot be changed.
	See “Annuity Options” under the section titled “Annuity Payments (Income Phase)”.	If you do not choose an annuity option at least 30 calendar days before the latest Annuity Date specified in your Contract, we will make annuity payments under the Life Annuity with Guaranteed Period annuity option. The guaranteed period will be equal to 10 years, unless a shorter period is otherwise required.
Oregon	See “Annuity Options” under the section titled “Annuity Payments (Income Phase)”.	If you do not choose an annuity option at least 30 calendar days before the latest Annuity Date specified in your Contract, we will make annuity payments under the Life Annuity with Guaranteed Period annuity option. The guaranteed period will be equal to 60 months.
Texas	See “Owner” under the section titled “General Description of the Contract”.	The Owner and any joint Owner are shown on the contract application and cannot be changed.
	See “Annuity Options” under the section titled “Annuity Payments (Income Phase)”.	If you do not choose an annuity option at least 30 calendar days before the latest Annuity Date specified in your Contract, we will make annuity payments under the Life Annuity with Guaranteed Period annuity option. The guaranteed period will be equal to 10 years, unless a shorter period is otherwise required.

C-1

PROSPECTUS BACK COVER

INQUIRIES

Symetra Life’s principal place of business is located at 777 108th Avenue NE, Suite 1200, Bellevue, Washington 98004. All communications to Symetra Life should be directed as follows:

Account Maintenance: For general correspondence, all written communications, including additional Purchase Payments, and other transactional inquiries, please contact us at:

Symetra Life Insurance Company    

P.O. Box 305156

Nashville, TN 37230-5156

We will not deem correspondence, including transactional inquiries and Purchase Payments, sent to any other address as received by us until they are picked up at the addresses listed above and delivered to our processing office.

For overnight mail:

Symetra Life Insurance Company

100 Centerview Drive, Suite 100

Nashville, TN 37214-3439

By Phone: 1-800-796-3872

On the Internet: www.symetra.com/regulatoryreports

Statement of Additional Information (SAI). The SAI provides more detailed information about Symetra Separate Account C. The current SAI is on file with the SEC, and is incorporated into this prospectus by reference and is legally considered part of this prospectus.

You can make inquiries regarding your Contract, request additional information and get a free copy of the SAI or discuss your questions about your Contract by contacting us at our Account Maintenance address listed above.

To download an electronic version of this prospectus and the SAI:https://www.symetra.com/regulatoryreports.

Reports and other information about the Contract and the Registrant are available on the SEC’s Web site at https://www.sec.gov. You can also get copies, for a fee, by electronic request at the following email address: publicinfo@sec.gov.

EDGAR Contract Identifier: C000003366

SPINNAKER® VARIABLE ANNUITY

STATEMENT OF ADDITIONAL INFORMATION

INDIVIDUAL FLEXIBLE PREMIUM DEFERRED VARIABLE ANNUITY CONTRACT

issued by

SYMETRA SEPARATE ACCOUNT C

and

SYMETRA LIFE INSURANCE COMPANY

This Statement of Additional Information (“SAI”) is not a prospectus and should be read in conjunction with the prospectus for the Spinnaker Individual Flexible Premium Deferred Variable Annuity Contract.

The prospectus concisely sets forth information that a prospective investor should know before investing. For a copy of the prospectus, call 1-800-796-3872 or write to Symetra Life Insurance Company, P.O. Box 305156 Nashville, TN 37230-5156.

This SAI and the prospectus are both dated May 1, 2021.

TABLE OF CONTENTS

	Page
GENERAL INFORMATION AND HISTORY INFORMATION	1
NON-PRINCIPAL RISKS	1
SERVICES	1
UNDERWRITER	2
ADDITIONAL TAX INFORMATION	2
ANNUITY PROVISIONS	6
FINANCIAL STATEMENTS	8

GENERAL INFORMATION

Terms and phrases used in this SAI have the meaning given to them in the prospectus.

Symetra Life Insurance Company (“Symetra Life”, “we”, and “us”), is a wholly-owned subsidiary of Symetra Financial Corporation, which, in turn, is a wholly owned subsidiary of Sumitomo Life Insurance Company, a Japanese mutual life insurer (sougo kaisha) with its headquarters in Tokyo, Japan. Symetra Financial Corporation is a holding company, the subsidiaries of which are engaged primarily in insurance and financial services businesses. Symetra Life was incorporated as a stock life insurance company under Washington State law on January 23, 1957. Effective July 1, 2014, Symetra Life Insurance Company changed its state of domicile from Washington to Iowa and became an Iowa stock life insurance company. We provide individual and group life, accident and health insurance, and annuity products and are licensed to do business in the District of Columbia and all states except New York.

We established Symetra Separate Account C (“the Separate Account”) on September 14, 1993 to hold assets that underlie Contract values invested in a number of different variable annuity Contracts. The Separate Account meets the definition of “separate account” under Iowa State law and under the federal securities laws. The Separate Account is registered with the Securities and Exchange Commission (“SEC”) as a unit investment trust under the Investment Company Act of 1940, as amended. We maintain records of all Separate Account purchases and redemptions of the shares of the Sub-accounts.

Accumulation Units and variable annuity payments will reflect the investment performance of the Separate Account with respect to amounts allocated to it. Since the Separate Account is always fully invested in the shares of the Sub-accounts, its investment performance reflects the investment performance of those entities. The values of such shares held by the Separate Account fluctuate and are subject to the risks of changing economic conditions. The Contract Owner bears the entire investment risk. There can be no assurance that the aggregate value in the Contract and amount of variable annuity payments will equal or exceed the Purchase Payments made under the Contract.

NON-PRINCIPAL RISKS

Cyber Security Risk: 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 (hardware and software malfunctions) and cyber-attacks. These risks include, among other things, the theft, misuse, corruption and destruction of data maintained on-line or digitally, and unauthorized release of confidential customer information. For instance, cyber-attacks may: interfere with our processing of Contract transactions, including the processing of orders from our website or with the Portfolios; cause the release and possible destruction of confidential customer or business information; impede order processing; 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 Portfolios.

Delays in Contract Administration : Delays in Contract administration may occur in the event of severe weather, natural disasters, a public health crisis, pandemic or the closure of one or more of our offices, or in the event of interruptions in mail delivery, telephone communications, or other electronic communications beyond our control.

SERVICES

Independent Registered Public Accountant

The SAI of the Registration Statement includes the statutory-basis financial statements of Symetra Life Insurance 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, and the financial statements of Symetra Separate Account C as of December 31, 2020, and for each of the two years in the period ended December 31, 2020.

The financial statements as of and for the years or periods ended December 31, 2020 have been audited by KPMG LLP, Independent Registered Public Accounting Firm, as set forth in their reports thereon appearing elsewhere herein, and are included in reliance upon such reports given on the authority of such firm as experts in accounting and auditing. The principal business address of KPMG LLP is 1918 Eighth Avenue, Suite 2900, Seattle, WA 98101.

1

The financial statements as of and for the years or periods ended December 31, 2019 and December 31, 2018 have been audited by Ernst & Young LLP, Independent Registered Public Accounting Firm, as set forth in their reports thereon appearing elsewhere herein, and are included in reliance upon such reports given on the authority of such firm as experts in accounting and auditing. The principal business address of Ernst & Young LLP is 920 Fifth Avenue, Suite 900, Seattle, WA 98104.

Auditor Update

Symetra Financial Corporation has made the decision to change accounting firms for the annual independent audit of Symetra Life Insurance Company and its registered separate accounts. On May 29, 2019, Symetra Financial Corporation, notified Ernst & Young LLP (“EY”) that its services as Independent Registered Public Accounting Firm will cease upon completion of the annual audits for Symetra Financial Corporation, its subsidiaries and their separate accounts for the fiscal year ending December 31, 2019. On the same day, Symetra Financial Corporation’s Audit Committee appointed KPMG LLP (“KPMG”) as its independent auditor to audit the financial statements of Symetra Financial Corporation and its subsidiaries and their separate accounts for the fiscal year ending December 31, 2020.

With regard to Symetra Life Insurance Company, no disagreements arose during the twenty-four (24) months preceding the termination of EY or during any subsequent period relating to any matter of accounting principles or practices, financial statement disclosure, auditing scope or procedure, or compliance with applicable rules of the Securities and Exchange Commission (SEC), which issues, if not resolved to the satisfaction of EY, would have caused EY to make reference to the disagreements in its reports for the fiscal years ended December 31, 2019, 2018 and 2017. EY’s reports for the fiscal years ended December 31, 2019, 2018 and 2017 did not contain any adverse opinions or a disclaimer of opinions and were not qualified or modified as to uncertainties, audit scope, or accounting principles. In addition, there were no reportable events within the meaning set forth in Item 304(a)(1)(v) of Regulation S-K during fiscal years ended December 31, 2019, 2018 and 2017 and the subsequent interim period.

Symetra Life Insurance Company provided a copy of this disclosure, or similar disclosure, to EY for its review and requested that EY provide Symetra Life Insurance Company with a letter addressed to the SEC stating whether EY agrees with the statements made by Symetra Life Insurance Company in the Auditor Update section of Symetra Life Insurance Company’s Form S-1 (No. 333-225314) filed on March 27, 2020. A copy of that letter is filed as Exhibit 16 to that registration statement.

For the two most recent fiscal years, and any subsequent interim period prior to engaging KPMG, Symetra Life Insurance Company did not consult with KPMG regarding (i) the application of accounting principles to a specified transaction, either completed or proposed, or the type of audit opinion that might be rendered on the financial statements of Symetra Life Insurance Company and its registered separate accounts, and KPMG did not provide either a written report or oral advice to Symetra Life Insurance Company that was an important factor considered by Symetra Financial Corporation in reaching a decision as to any accounting, auditing, or financial reporting issue, or (ii) any matter that was either the subject of a disagreement (as defined in Item 304(a)(1)(iv) of Regulation S-K and the related instructions) or a reportable event (as defined in Item 304(a)(1)(v) of Regulation S-K).

UNDERWRITER

Symetra Securities, Inc. (“SSI”) acts as the principal underwriter for the Contracts pursuant to an underwriter’s agreement with us. SSI and Symetra Life are affiliates under common control. SSI is located at 777 108th Avenue NE, Suite 1200, Bellevue, WA 98004. The Contracts issued by the Separate Account are offered on a continuous basis. For the years ended December 31, 2020, 2019, and 2018, SSI received $1,095,625, $1,162,611 and $1,363,674, in commissions for the distribution of all annuity Contracts funded through the Separate Account. SSI does not retain any portion of the commissions.

ADDITIONAL TAX INFORMATION

Note

The following description is based upon Symetra Life’s understanding of current federal income tax law applicable to annuities in general. Tax laws are complex and subject to change. We cannot predict the probability that any changes in the interpretation of the laws, or the laws themselves, will occur. Contract Owners are cautioned to seek competent tax advice regarding the possibility of such changes. We do not guarantee the tax status of the Contracts. Contract Owners bear the complete risk that the Contracts may not be treated as “annuity Contracts” under federal income tax laws. It should be further understood that the following discussion is not exhaustive and that special rules not described in this SAI or the prospectus may be applicable in certain situations. Moreover, no attempt has been made to consider any applicable state or other tax laws.

General

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Table of Contents - SAI

Section 72 of the Internal Revenue Code of 1986, as amended, (“the Code”) governs taxation of annuities in general. An Owner is generally not taxed on increases in the value of a Contract until distribution occurs, either in the form of a lump sum payment, a withdrawal, or as annuity payments under the option elected. For a lump sum payment received as a total surrender (total redemption), the recipient is generally taxed on the portion of the payment that exceeds the cost basis in the Contract. For a partial withdrawal payment, the recipient is taxed as if earnings are withdrawn first before the cost basis of the Contract is withdrawn. The cost basis is generally the amount of non-deductible Purchase Payments which for qualified Contracts may be zero. The taxable portion of the lump sum payment is taxed at ordinary income tax rates. Tax penalties may also apply.

For annuity payments, a portion of each payment in excess of an exclusion amount is includable in taxable income. The exclusion amount for payments based on a fixed annuity is determined by multiplying the payment by the ratio that the cost basis of the Contract (adjusted for any period certain or refund feature) bears to the expected return under the Contract. The exclusion amount for payments based on a variable annuity is determined by dividing the cost basis of the Contract (adjusted for any period certain or refund guarantee) by the number of years over which the annuity is expected to be paid. Payments received after the investment in the Contract has been recovered (i.e. when the total of the excludable amounts equals the investment in the Contract) are generally fully taxable. For certain types of retirement plans there may be no cost basis in the Contract within the meaning of Section 72 of the Code resulting in the annuity payments being fully includable in taxable income. Owners, payees and Beneficiaries under the Contracts should seek competent financial advice about the tax consequences of any distributions.

Qualified Contracts

The following describes Contracts offered to individual Contract Owners in order to allow individuals to accumulate savings for retirement. If your Contract is issued as an Individual Retirement Annuity (“IRA”) or Roth Individual Retirement Annuity (“Roth IRA”), then we will issue the Contract with language intended to qualify the Contract as an IRA or Roth IRA. We will also provide the necessary administrative procedures to administer the IRAs and Roth IRAs in accordance with IRS requirements governing the sponsors of IRAs and Roth IRAs subject to the accuracy and completeness of the information you provide us. For SEP IRAs and SIMPLE IRAs, certain IRS requirements and administrative procedures will be provided by your employer, and your Contract may be subject to the terms of the SEP IRA or SIMPLE IRA plan. Contracts issued in connection with SEP IRAs and SIMPLE IRAs may include special provisions that may restrict or modify the Contract provisions and administrative services in the prospectus. There are generally maximum amounts that can be contributed each year to IRAs. IRA Owners age 50 or older may be able to make additional “catch-up” Purchase Payments each year. If contributions are being made under a SEP or SIMPLE IRA, additional amounts may be contributed as permitted by the Code and the terms of the employer’s plan. Generally, rollovers and direct transfers will not be subject to such limitations.

Individual Retirement Annuities

Section 408 of the Code permits eligible individuals to contribute to an individual retirement program known as a traditional IRA. Under applicable limitations, certain amounts may be contributed to an IRA which will be deductible from the individual’s gross income. These IRAs are subject to limitations on eligibility, contributions, transferability and distributions. See IRS Publication 590 for additional details. Traditional IRAs include the SEP IRA and SIMPLE IRA. An employer can establish a SEP IRA or SIMPLE IRA for its employees. Under an employer’s SEP IRA or SIMPLE IRA, contributions for each eligible employee can be made under a Contract issued as an IRA. Under certain conditions, distributions from other IRAs and other retirement plans may be rolled over or transferred on a tax deferred basis into an IRA. Sales of Contracts for use with IRAs are subject to special requirements imposed by the Code, including the requirement that certain informational disclosure be given to persons desiring to establish an IRA. Purchasers of IRAs should obtain competent tax advice as to the tax treatment and suitability of such an investment.

Roth Individual Retirement Annuities

Section 408A of the Code permits eligible individuals to make nondeductible contributions to Roth IRAs. Section 408A includes limits on how much you may contribute to a Roth IRA and when distributions may commence. Qualified distributions from Roth IRAs are excluded from taxable gross income. Non-qualified distributions are includable in taxable gross income only to the extent that they exceed the contributions made to the Roth IRA. The taxable portion of a non-qualified distribution may be subject to the 10% penalty tax.

You may convert a traditional IRA to a Roth IRA. You will be required to include the taxable portion of the conversion in your taxable gross income, but you will not be required to pay the 10% penalty tax. However, a 10% penalty tax may apply to a conversion from an IRA if distributions occur during the five taxable years beginning with the year in which the conversion was made. You may wish to consult a tax professional before combining any

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converted amounts with any other Roth IRA contributions, including any other conversion amounts from other tax years.

The following describes Contracts offered to participants of employer-sponsored retirement plans. Owners, Annuitants and Beneficiaries are cautioned that benefits under a retirement plan may be subject to the terms and conditions of the plan regardless of the terms and conditions of the Contracts issued pursuant to the plan. Some retirement plans are subject to distribution and other requirements that are not incorporated into Symetra Life’s administrative procedures. Contract Owners, participants and Beneficiaries are responsible for determining that contributions, distributions and other transactions with respect to the Contract comply with applicable law. Contracts issued in connection with retirement plans include special provisions that may restrict or modify the Contract provisions and administrative services described in the prospectus. Generally, Contracts issued pursuant to retirement plans are not transferable except upon surrender or annuitization. The tax rules regarding retirement plans are very complex and will have differing applications depending on individual facts and circumstances.

On July 6, 1983, the Supreme Court decided in Arizona Governing Committee v. Norris that optional annuity benefits provided under an employer’s deferred compensation plan could not, under Title VII of the Civil Rights Act of 1964, vary between men and women. The Contracts sold by Symetra Life in connection with retirement plans will utilize annuity purchase rate tables which do not differentiate on the basis of sex. Such annuity purchase rate tables will also be available for use in connection with certain non-qualified deferred compensation plans.

Roth TSAs

Section 402A of the Code permits an employee to designate their contributions to their TSAs as Roth TSA contributions if Roth TSA contributions are permitted by the employer. Many of the federal rules pertaining to Roth TSAs have not yet been finalized. The IRS has not issued guidance regarding issues that may arise with respect to allocation of Contract income, expenses, gains and losses. It has also not issued guidance with regard to the allocation of certain charges for guarantees under annuity Contracts. Both you and your employer should consult their own tax and legal professionals prior to making or permitting contributions to be made to a Roth TSA. Roth TSA contributions are includable in gross income and are subject to the TSA limits discussed above. Non-qualified distributions are includable in taxable gross income only to the extent that they exceed the contributions made to the Roth TSA. The taxable portion of a non-qualified distribution may be subject to the 10% penalty tax. Roth TSA contributions are also subject to the same distribution restrictions and required minimum distributions as all other contributions in the plan. A 403(b) plan may allow amounts in non-Roth accounts that are eligible for distribution to be converted to Roth TSA accounts. In addition, plans may also allow conversion of amounts that are not eligible for distribution. Amounts converted to a Roth TSA are taxable as ordinary income in the year of conversion.

Deferred Compensation Plans (457 Plans)

Section 457 of the Code permits governmental and certain other tax exempt employers to establish deferred compensation plans for the benefit of their employees. The Code establishes limitations and restrictions on eligibility, contributions and distributions. Under these plans, contributions made for the benefit of the employees will not be includable in the employees’ gross income until distributed or otherwise made available (for non-governmental 457(b) plans) from the plan. Generally, because contributions are on a before-tax basis, withdrawals are subject to income tax. Your employer may allow loans under governmental Section 457 plans. Special rules apply to deferred compensation plans. Owners should consult their own tax counsel or other tax professional regarding any distributions.

Tax Treatment of Withdrawals - Qualified Contracts

In addition to ordinary income tax, Section 72(t) of the Code imposes a 10% penalty tax on the taxable portion of any distribution from certain retirement plans, including Contracts issued and qualified under Code Sections 403(b) (Tax Sheltered Annuities and Roth Tax Sheltered annuities), 408 (Individual Retirement Annuities), and 408A (Roth Individual Retirement Annuities). To the extent amounts are not includable in gross income because they have been rolled over to an IRA or to another eligible plan, no tax penalty will be imposed.

The tax penalty will not apply to the following distributions: (a) if distribution is made on or after the date on which the Owner reaches age 59 1/2; (b) distributions following the death or disability of the Owner (for this purpose disability is as defined in Section 72(m)(7) of the Code); (c) after separation from service, distributions that are part of substantially equal periodic payments made not less frequently than annually for the life (or life expectancy) of the Owner or the joint lives (or joint life expectancies) of such Owner and his or her designated Beneficiary; (d) distributions made to the Owner who has separated

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from service after he or she has attained age 55; (e) distributions made to the Owner to the extent such distributions do not exceed the amount allowable as a deduction under Code Section 213 to the Owner for amounts paid during the taxable year for medical care; (f) distributions made to an alternate payee pursuant to qualified domestic relations order; (g) distributions made to pay health insurance premiums for an unemployed Owner; (h) distributions made to pay qualified higher education expenses; (i) distributions made to an Owner for first home purchases; (j) distributions due to an IRS levy; (k) “qualified reservist distributions” as defined by the Code; and (l) distributions to qualified public safety employees from a governmental defined benefit plan after attaining age 50 and separating from service. The exceptions stated in (d), and (f) above do not apply in the case of an IRA or Roth IRA. The exception stated in (c) above applies to an IRA and Roth IRA without the requirement that there be a separation from service. The exceptions stated in (g), (h), and (i) above do not apply in the case of a TSA or Roth TSA.

The penalty tax does not apply to conversions of traditional IRAs or other eligible retirement plans to Roth IRAs and to most distributions from 457(b) plans. However, the penalty tax will apply if converted amounts are distributed during the five-year period beginning with the year of conversion.

The Secure Act increases the beginning date for required minimum distributions from 70 ½ to 72. This change only applies if you will attain age 72 on or after January 1, 2020. All other requirements for the timing and calculation of required minimum distributions remain the same. If you reached the age of 70 ½ prior to January 1, 2020, you are still required to use age 70 ½ as the triggering age for beginning required minimum distributions.

Such distributions (including distributions from Roth TSAs) must include the present value of any optional benefits you have purchased under the Contract. If the required minimum distributions are not made, a 50% penalty tax is imposed as to the amount not distributed. If your spouse is your Beneficiary and your Contract permits, your spouse may delay the start of required minimum distribution until December 31 of the year in which you would have reached age 72. Or, if your spouse is your sole Beneficiary and the Contract is an IRA, then he or she may elect to roll over the death proceeds into his or her own IRA (or a Roth IRA and pay tax on the taxable portion of the death proceeds) and treat the IRA (or Roth IRA) as his or her own. Your spouse may also be able to roll over the death proceeds into the spouse’s eligible retirement plan. Your plan may also offer non-spouse rollovers beginning in 2010. Contact your retirement plan for details.

Non-spouse Beneficiaries may be able to rollover death proceeds to inherited IRAs. If you die after required distributions have begun, payments of your entire remaining interest are subject to the new Secure Act rules.

Diversification

Section 817(h) of the Code imposes certain diversification standards on the underlying assets of variable annuity Contracts. The Code provides that a variable annuity Contract will not be treated as an annuity Contract for any period (and any subsequent period) for which the investments are not, in accordance with regulations prescribed by the United States Treasury Department (“Treasury Department”), adequately diversified, as of the end of each quarter (or within 30 days after such last day). Disqualification of the Contract as an annuity Contract would result in imposition of federal income tax to the Owner with respect to earnings allocable to the Contract prior to the receipt of payments under the Contract. The Code contains a safe harbor provision which provides that annuity Contracts (such as the Contracts) meet the diversification requirements if the underlying assets meet the diversification standards for a regulated investment company and no more than fifty-five percent (55%) of the total assets consist of cash, cash items, U.S. Government securities and securities of other regulated investment companies.

The Treasury Department has issued Regulations (Treas. Reg. 1.817-5), which establish diversification requirements for the portfolios underlying variable Contracts such as those described in the prospectus. The Regulations amplify the diversification requirements for variable Contracts set forth in the Code and provide an alternative to the safe harbor provision described above. Under the Regulations, an investment portfolio will be deemed adequately diversified if: (1) no more than 55% of the value of the total assets of the portfolio is represented by any one investment; (2) no more than 70% of the value of the total assets of the portfolio is represented by any two investments; (3) no more than 80% of the value of the total assets of the portfolio is represented by any three investments; and (4) no more than 90% of the value of the total assets of the portfolio is represented by any four investments.

The Code provides that, for purposes of determining whether or not the diversification standards imposed on the underlying assets of variable Contracts by Section 817(h) of the Code have been met, “each United States government agency or instrumentality shall be treated as a separate issuer.”

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In certain circumstances, a variable contract owner may be considered the owner of the assets of a segregated account, such as the Separate Account, if the IRS deems the owner to possess “ownership” in those assets, such as the ability to exercise investment control over the assets. If the contract owner is deemed to have "investor control" over the underlying Portfolios, then the contract owner will be taxed currently on income and recognized gains under the Contract. The application of the investor control doctrine is subject to some uncertainty. The amount of owner control which may be exercised under the Contract is different in some respects from the situations addressed in published rulings issued by the IRS in which it was held that the contract owner was not the owner of the assets of the separate account. It is unknown whether these differences, such as your ability to transfer among Sub-accounts or the number and type of Sub-accounts available, would cause you to be considered the owner of the assets of the Separate Account resulting in the imposition of federal income tax with respect to earnings allocable to the Contract prior to receipt of payments under the Contract.

We believe that the design of our Contracts and the relationship between our Contracts and the Portfolios is such that the investor control doctrine should not apply. In the event any forthcoming guidance or ruling is considered to set forth a new position, such guidance or ruling will generally be applied only prospectively. However, if such ruling or guidance was not considered to set forth a new position, it may be applied retroactively resulting in the contract owner being retroactively determined to be the owner of the assets of the Separate Account.

ANNUITY PROVISIONS

Annuity Unit Value

The value of an Annuity Unit for each Sub-account on any date varies to reflect the investment experience of the Sub-account, the assumed investment return of 4% on which the applicable Variable Annuity Purchase Rate Table is based, and the deduction for charges assessed and imposed by Symetra Life, including a mortality and expense risk charge, asset related administration charge, and, if applicable, a charge for premium taxes.

For any valuation period the value of an Annuity Unit is determined by multiplying the value of an Annuity Unit for each Sub-account, as of the immediately preceding valuation period by the Net Investment Factor(s) for the valuation period for which the value is being calculated, and dividing the result by the Assumed Investment Factor to adjust for the assumed investment return of 4% used in calculating the applicable Variable Annuity Purchase Rate Table.

The Net Investment Factor is a number that represents the change in the Accumulation Unit value of a Sub-account on successive days when the NYSE is open for regular trading. The Net Investment Factor for any Sub-account for any valuation day is determined by taking the Accumulation Unit value of the Sub-account as of the current valuation day, and dividing it by the Accumulation Unit value for the preceding day. The Net Investment Factor will likely be different from the Assumed Investment Factor, and therefore the Annuity Unit value will usually increase or decrease.

The Assumed Investment Factor for a one day valuation period is 1.00010746. This factor neutralizes the assumed investment return of 4% in the Variable Annuity Purchase Rate Table in the Contract.

Variable Annuity Payments

The amount of the first annuity payment is based on the annuity option selected, the annuity purchase rate, the age and sex of the Annuitant, the investment performance of the Sub-accounts you selected, and the Annuity Date. The amount of the first payment is the sum of the payments from each Sub-account. We use the Variable Annuity Purchase Rate Table to determine the variable annuity payment based on the value of each Sub-account. We determine the value (after deduction for premium taxes, if applicable) on the 15th day of the preceding month. The Variable Annuity Purchase Rate Table is contained in the Contract and is guaranteed for the duration of the Contract.

The number of Annuity Units attributed to a Sub-account is the amount of the first annuity payment attributable to that Sub-account, divided by the value of the applicable Annuity Unit for that Sub-account. This determination is made as of the 15th day of the month preceding the Annuity Date. The number of Annuity Units attributed to the variable annuity payment each month remains constant unless the Owner changes Sub-account elections. The value of an Annuity Unit will usually increase or decrease from one month to the next.

The dollar amount of each variable annuity payment after the first is the sum of the payments from each Sub-account, which are determined by multiplying the number of Annuity Units credited for that Sub-account by the Annuity Unit value of that Sub-

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account as of the 15th day of the month preceding the annuity payment. If the NYSE is closed on that date, the calculation will be made on the next Business Day. If premium taxes are required by state law, these taxes will be deducted before they annuity payment is calculated.

To illustrate the manner in which variable annuity payments are determined we have provided the following example. Item (4) in the example shows the applicable monthly payment rate (which varies depending on the Variable Annuity Purchase Rate Table used in the Contract) for an Annuitant with an adjusted age 63, where an Owner has elected a variable life annuity with a guaranteed period of 10 years with the assumed investment return of 4%. (The “Life Annuity with Guaranteed Period” option is described in the prospectus).

(1)	Assumed number of Accumulation Units in a Sub-account on maturity date	25,000
(2)	Assumed value of an Accumulation Unit in a Sub-account at maturity	$12.50
(3)	Cash value of Contract at maturity, (1) x (2)	$312,500
(4)	Consideration required to purchase $1 of monthly annuity from Variable Annuity Purchase Rate Table	$200.20
(5)	Amount of first payment from a Sub-account, (3) divided by (4)	$1,560.94
(6)	Assumed value of Annuity Unit in a Sub-account at maturity	$13.00
(7)	Number of Annuity Units attributed to a Sub-account, (5) divided by (6)	120.072

The $312,500 value at maturity provides a first payment from the Sub-account of $1,560.94, and payments thereafter of the varying dollar value of 120.072 Annuity Units. The amount of subsequent payments from the Sub-account is determined by multiplying 120.072 units by the value of an Annuity Unit in the Sub-account on the applicable valuation date. For example, if that unit value is $13.25, the monthly payment from the Sub-account will be 120.072 multiplied by $13.25, or $1,590.95.

However, the value of the Annuity Unit depends on the investment experience of the Sub-account. Thus in the example above, if the Net Investment Factor for the following month was less than the assumed investment return of 4%, the Annuity Unit would decline in value. If the Annuity Unit value declined to $12.75 the succeeding monthly payment would then be 120.072 x $12.75, or $1,530.92.

For the sake of simplicity the foregoing example assumes that all of the Annuity Units are in one Sub-account. If there are Annuity Units in two or more Sub-accounts, the annuity payment from each Sub-account is calculated separately, in the manner illustrated, and the total monthly payment is the sum of the payments from the Sub-accounts.

Payments Based on a Number of Years

This option is designed so that payments from the Contract will meet the IRS definition of “amounts received as an annuity” and will have an exclusion ratio (for fixed interest annuities) or an excludable amount (for variable annuities) applied to each payment. The exclusion ratio (or excludable amount) determines which part of the payment is a return of after-tax investment in the Contract and which part is a taxable distribution of earnings. In order for payments from a nonqualified annuity to be treated as “an amount received as an annuity,” the following requirements must be met:

Fixed Payments

•The amount of each payment must be determinable on the Annuity Date for the specified term. We calculate Payments Based on a Number of Years by amortizing the Contract Value on the Annuity Date at 3% (or the Contract minimum interest guarantee, if less) over a term selected by the Contract Owner, but not less than 5 years nor more than the number of years to the Annuitant’s age 100. The expected return is the calculated payment amount times the number of payments (term times payment frequency). The exclusion ratio is the cost basis divided by the expected return.

•If the Contract earns more than the Contract’s minimum guaranteed interest rate, then payments will continue beyond the specified term until the account is exhausted.

Variable Payments

•Because the annuity value of variable annuities is, by definition, variable over time, the amount of future payments cannot be determinable on the Annuity Date for the term specified by the Owner. The IRS requires payments to be made over the term but allows payments to fluctuate from year to year to reflect gains or losses in excess of the original return assumption. For the first full year of payments under the Payments Based on a Number of Years annuity option, we calculate payment(s) by amortizing the Contract Value on the Annuity Date

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using interest rates ranging from 3% to 120% of the applicable federal mid-term rate (AFR). At the beginning of each subsequent year, we recalculate the payment by amortizing the end of year Contract Value over the remaining term using the original interest rate assumption. This annual recalculation causes the value of the Sub-accounts to be exhausted by the end of the specified term. The excludable amount is the cost basis (after-tax investment in the Contract) divided by the expected number of payments (the term in years times the number of payments per year).

To illustrate how the Payments Based on a Number of Years annuity option for the variable portion of the Contract is calculated, assume that Contract Owner A elects the Payments Based on a Number of Years annuity option and:

•Accumulation Unit values for all Sub-accounts on the annuity starting date equal $100,000;

•Assumed investment return is 4%; and

•Contract Owner A elects to receive annual payments at the beginning of the year for 20 years.

Under this scenario, Contract Owner A’s first annual payment is $7,075.17. This is determined by calculating the payment amount which would reduce the present $100,000 accumulation value to zero over 20 years assuming an investment return of 4%. We then liquidate Accumulation Unit values equal to $7,075.17 for the first annual payment. Now assume that the $92,924.83 remaining balance in one year grows with investment gains to $100,000.

Contract Owner A’s second annual payment is $7,321.02. This is determined by calculating the new payment amount that would reduce the present $100,000 accumulation value to zero over the remaining 19 years, assuming an investment return of 4%.

In the third year, assume that the $92,678.98 remaining balance, after another year, declines with investment losses to $90,000. Contract Owner A’s third annual payment is $6,835.96. This is determined by calculating the amount that would reduce the present $90,000 accumulation value to zero over the remaining 18 years, assuming an investment return of 4%. We then liquidate Accumulation Unit values equal to $6,835.96 to make the third payment.

This annual recalculation process continues until the Accumulation Units are exhausted.

FINANCIAL STATEMENTS

The audited financial statements of Symetra Separate Account C and Symetra Life are included herein. The financial statements of Symetra Life should be considered only as bearing upon the ability of Symetra Life to meet its obligations under the Contract. They should not be considered as bearing upon the investment experience of the Separate Account or its Sub-accounts.

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Annual Report

December 31, 2020

Symetra Separate Account C

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	Page
Report of Independent Registered Public Accounting Firm	1
Report of Ernst & Young LLP, Independent Registered Public Accounting Firm	6
Statements of Assets and Liabilities	1
Statements of Operations and Changes in Net Assets	2
Notes to Financial Statements:
Note 1. Organization	8
Note 2. Significant Accounting Policies	1
Note 3. Expenses and Related Party Transactions	9
Note 4. Investment Transactions	10
Note 5. Changes in Accumulation Units Outstanding	31
Note 6. Accumulation Unit Values	35
Note 7. Subsequent Events	51

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Symetra Separate Account C

Report of Independent Registered Public Accounting Firm

To the Board of Directors of Symetra Life Insurance Company and the Contract Owners of Symetra Separate Account C:

Opinion on the Financial Statements

We have audited the accompanying statements of assets and liabilities of the sub-accounts listed in the Appendix, that comprise Symetra Separate Account C (the Separate Account), as of December 31, 2020, the related statements of operations and changes in net assets for the year then ended, and the related notes (collectively, the financial statements) and the accumulation unit values in Note 6 (the financial highlights) for the year then ended. In our opinion, the financial statements and financial highlights present fairly, in all material respects, the financial position of the Separate Account as of December 31, 2020, the results of its operations and the changes in its net assets for the year then ended, and the financial highlights for the year then ended, in conformity with U.S. generally accepted accounting principles.

The statements of operations and changes in net assets for the year ended December 31, 2019 and the financial highlights for each of the years in the four-year period ended December 31, 2019, were audited by other independent registered public accountants whose report, dated April 30, 2020 expressed an unqualified opinion on those financial statements and financial highlights.

Basis for Opinion

These financial statements and financial highlights are the responsibility of the Separate Account’s management. Our responsibility is to express an opinion on these financial statements and financial highlights based on our audit. 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 Company 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 audit 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 and financial highlights are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements and financial highlights, 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 and financial highlights. Such procedures also included confirmation of securities owned as of December 31, 2020, by correspondence with the fund companies or their transfer agents, as applicable. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements and financial highlights. We believe that our audit provides a reasonable basis for our opinion.

/s/ KPMG LLP

We have served as the auditor of the Separate Account since 2020.

Seattle, Washington

April 23, 2021

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Symetra Separate Account C

Report of Independent Registered Public Accounting Firm (Continued)

Appendix

American Century Balanced

American Century Inflation Protection II

American Century International

American Century Large Company Value II

American Century Ultra I

American Century Ultra II

American Century Value

BNY Mellon Appreciation

BNY Mellon MidCap Stock

BNY Mellon Stock Index

BNY Mellon Sustainable U.S. Equity

BNY Mellon Technology Growth

Calvert EAFE International Index F Class

Calvert Investment Grade Bond Index

Calvert Nasdaq 100 Index

Calvert Russell 2000 Small Cap Index F Class

Calvert S&P MidCap 400 Index F Class

Calvert SRI Balanced

Columbia VP Select Mid Cap Value Fund – Class 1

DWS Capital Growth VIP B

DWS CROCI International VIP – Class A

DWS Global Income Builder VIP A

DWS Global Small Cap VIP B

DWS International Growth VIP B Share

DWS Small Cap Index A Share

Federated Hermes High Income Bond (1)

Federated Hermes Managed Volatility II (1)

Fidelity Asset Manager

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Symetra Separate Account C

Report of Independent Registered Public Accounting Firm (Continued)

Fidelity Contrafund

Fidelity Contrafund II

Fidelity Equity-Income

Fidelity Freedom Funds 2010 II

Fidelity Freedom Funds 2015 II

Fidelity Freedom Funds 2020 II

Fidelity Freedom Funds 2025 II

Fidelity Freedom Funds 2030 II

Fidelity Freedom Funds 2050 II

Fidelity Freedom Income Fund II

Fidelity Government Money Market Portfolio – Initial Class

Fidelity Government Money Market Portfolio – Service Class II

Fidelity Growth

Fidelity Growth & Income

Fidelity Growth Opportunities

Fidelity Index 500

Fidelity Mid Cap II

Fidelity Overseas II

Franklin Allocation VIP Fund – Class 2

Franklin Flex Cap Growth VIP Fund – Class 2

Franklin Income VIP Fund – Class 2

Franklin Mutual Shares VIP Fund – Class 2

Frankklin Small Cap Value VIP Fund – Class 2

Franklin Small-Mid Cap Growth VIP Fund – Class 2

Franklin U.S. Government Securities VIP Fund – Class 2

Invesco American Franchise Fund I

Invesco American Franchise Fund II

Invesco Global Real Estate

Invesco Health Care

3

Symetra Separate Account C

Report of Independent Registered Public Accounting Firm (Continued)

Invesco International Growth I

Invesco International Growth II

Invesco Oppenheimer Discovery Mid Cap Growth Fund I (1)

Invesco Oppenheimer Discovery Mid Cap Growth Fund II (1)

Invesco Small Cap Equity II

JP Morgan Insurance Trust Mid Cap Value I

JP Morgan Insurance Trust U.S. Equity I

Morningstar Aggressive Growth ETF Asset Allocation Class I

Morningstar Aggressive Growth ETF Asset Allocation Class II

Morningstar Balanced ETF Asset Allocation Class I

Morningstar Balanced ETF Asset Allocation Class II

Morningstar Conservative ETF Asset Allocation Class I

Morningstar Conservative ETF Asset Allocation Class II

Morningstar Growth ETF Asset Allocation Class I

Morningstar Growth ETF Asset Allocation Class II

Morningstar Income & Growth ETF Asset Allocation Class I

Morningstar Income & Growth ETF Asset Allocation Class II

Neuberger Berman AMT Mid Cap Growth Class S

Neuberger Berman AMT Mid Cap Intrinsic Value Class S

Neuberger Berman AMT Sustainable Equity Class S

PIMCO All Asset Portfolio Advisor

PIMCO CommodityRealReturn Strat. Administrative Class

PIMCO Total Return Portfolio Advisor

Pioneer Bond VCT Class I

Pioneer Equity Income VCT Class II

Pioneer Fund VCT Class I

Pioneer High Yield VCT Class II

Pioneer Mid Cap Value VCT Class I

Pioneer Real Estate VCT Class II

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Symetra Separate Account C

Report of Independent Registered Public Accounting Firm (Continued)

Pioneer Select Mid Cap Growth VCT Class I

Pioneer Strategic Income VCT Class II

Templeton Developing Markets VIP Fund – Class 2

Templeton Global Bond VIP Fund – Class 2

Templeton Growth VIP Fund – Class 2

Vanguard Balanced

Vanguard High Yield Bond

Vanguard International

Vanguard Mid-Cap Index

Vanguard Real Estate Index

Vanguard Total Bond Market Index

Vanguard Total Stock Market Index

Voya Global High Dividend Low Volatility Portfolio – Class S (1)

VY JPMorgan Emerging Markets Equity Portfolio Initial

Wanger USA

The following subaccount had varying audited periods defined in the table below:

Subaccount	Statements of Assets and Liabilities	Statements of Operations and Changes in Net Assets
BNY Mellon Quality Bond	N/A – the fund ceased to be available as an investment option to contract owners during 2020	For the period from January 1, 2020 through April 30, 2020 (date of liquidation)
Invesco Mid Cap Growth Fund I	N/A – the fund ceased to be available as an investment option to contract owners during 2020	For the period from January 1, 2020 through April 30, 2020 (date of consolidation)
Invesco Oppenheimer Discovery Mid Cap Growth Fund I	As of December 31, 2020	For the period from April 30, 2020 through December 31, 2020
Invesco Mid Cap Growth Fund II	N/A – the fund ceased to be available as an investment option to contract owners during 2020	For the period from January 1, 2020 through April 30, 2020 (date of consolidation)
Invesco Oppenheimer Discovery Mid Cap Growth Fund II	As of December 31, 2020	For the period from April 30, 2020 through December 31, 2020

(1) See Note 1 of the financial statements for the former name of the sub-account

5

Symetra Separate Account C

Report of Independent Registered Public Accounting Firm

Report of Ernst & Young LLP, Independent Registered Public Accounting Firm

To the Board of Directors of Symetra Life Insurance Company and Contract Owners of Symetra Separate Account C

Opinion on the Financial Statements

We have audited the accompanying statements of operations and changes in net assets for each of the subaccounts that comprise Symetra Separate Account C (the Separate Account) for each of the periods ended December 31, 2019 indicated in the Appendix, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the results of operations and changes in net assets of each subaccount for each of the periods ended December 31, 2019 indicated in the Appendix, 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 Account 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 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 served as the Separate Account’s auditor from 1994 to 2020.

Seattle, Washington

April 30, 2020

1

Symetra Separate Account C

Report of Independent Registered Public Accounting Firm

Appendix – Subaccounts comprising Symetra Separate Account C

The following subaccounts were audited for the year ended December 31, 2019:

American Century Balanced                Franklin Small Cap Value VIP Fund - Class 2

American Century Inflation Protection II            Franklin Small-Mid Cap Growth VIP Fund - Class 2

American Century International                Franklin U.S. Government Securities VIP Fund - Class 2

American Century Large Company Value II            Invesco American Franchise Fund I

American Century Ultra I                    Invesco American Franchise Fund II

American Century Ultra II                    Invesco Global Real Estate

American Century Value                    Invesco Health Care

BNY Mellon Appreciation                    Invesco International Growth I

BNY Mellon MidCap Stock                Invesco International Growth II

BNY Mellon Quality Bond                Invesco Mid Cap Growth Fund I

BNY Mellon Stock Index                    Invesco Mid Cap Growth Fund II

BNY Mellon Sustainable U.S. Equity            Invesco Small Cap Equity II

BNY Mellon Technology Growth                JP Morgan Insurance Trust Mid Cap Value I

Calvert EAFE International Index F Class            JP Morgan Insurance Trust U.S. Equity I

Calvert Investment Grade Bond Index            Morningstar Aggressive Growth ETF Asset Allocation Class I

Calvert Nasdaq 100 Index                    Morningstar Aggressive Growth ETF Asset Allocation Class II

Calvert Russell 2000 Small Cap Index F Class        Morningstar Balanced ETF Asset Allocation Class I

Calvert S&P MidCap 400 Index F Class            Morningstar Balanced ETF Asset Allocation Class II

Calvert SRI Balanced                    Morningstar Conservative ETF Asset Allocation Class I

Columbia VP Select Mid Cap Value Fund - Class 1        Morningstar Conservative ETF Asset Allocation Class II

DWS Capital Growth VIP B                Morningstar Growth ETF Asset Allocation Class I

DWS CROCI International VIP - Class A            Morningstar Growth ETF Asset Allocation Class II

DWS Global Income Builder VIP A            Morningstar Income & Growth ETF Asset Allocation Class I

DWS Global Small Cap VIP B                Morningstar Income & Growth ETF Asset Allocation Class II

DWS International Growth VIP B Share            Neuberger Berman AMT Mid Cap Growth Class S

DWS Small Cap Index A Share                Neuberger Berman AMT Mid Cap Intrinsic Value Class S

Federated High Income Bond                PIMCO All Asset Portfolio Advisor

Federated Managed Volatility II                PIMCO CommodityRealReturn Strat. Administrative Class

Fidelity Asset Manager                    PIMCO Total Return Portfolio Advisor

Fidelity Contrafund                    Pioneer Bond VCT Class I

Fidelity Contrafund II                    Pioneer Equity Income VCT Class II

Fidelity Equity-Income                    Pioneer Fund VCT Class I

Fidelity Freedom Funds 2010 II                Pioneer High Yield VCT Class II

Fidelity Freedom Funds 2015 II                Pioneer Mid Cap Value VCT Class I

Fidelity Freedom Funds 2020 II                Pioneer Real Estate VCT Class II

Fidelity Freedom Funds 2025 II                Pioneer Select Mid Cap Growth VCT Class I

Fidelity Freedom Funds 2030 II                Pioneer Strategic Income VCT Class II

Fidelity Freedom Funds 2050 II                Templeton Developing Markets VIP Fund - Class 2

Fidelity Freedom Income Fund II                Templeton Global Bond VIP Fund - Class 2

Fidelity Government Money Market Portfolio - Initial Class    Templeton Growth VIP Fund - Class 2

Fidelity Government Money Market Portfolio - Service

Class II                            Vanguard Balanced

Fidelity Growth                        Vanguard High Yield Bond

Fidelity Growth & Income                    Vanguard International

Fidelity Growth Opportunities                Vanguard Mid-Cap Index

Fidelity Index 500                     Vanguard Real Estate Index

Fidelity Mid Cap II                    Vanguard Total Bond Market Index

Fidelity Overseas II                    Vanguard Total Stock Market Index

Franklin Allocation VIP Fund - Class 2            Voya Global Equity Portfolio - Class S

Franklin Flex Cap Growth VIP Fund - Class 2        VY JPMorgan Emerging Markets Equity Portfolio Initial

Franklin Income VIP Fund - Class 2            Wanger USA

Franklin Mutual Shares VIP Fund - Class 2    

2

Symetra Separate Account C

Report of Independent Registered Public Accounting Firm

The following subaccount had varying audited periods defined in the table below:

Subaccount	Statements of Operations and Changes in Net Assets
Neuberger Berman AMT Guardian Class S	For the period from January 1, 2019 through April 30, 2019 (date of consolidation)
Neuberger Berman AMT Sustainable Equity Class S	For the period from April 30, 2019 through December 31, 2019

3

Symetra Separate Account C

Statements of Assets and Liabilities

As of December 31, 2020

Sub-Account	Number of Shares Owned	Investments at Cost		Investments at Fair Value		Net Assets		Accumulation Units Outstanding
American Century Balanced	901,989	$	6,584,682	$	7,874,353	$	7,874,353	300,616
American Century Inflation Protection II	241,794	2,454,628		2,681,490		2,681,490		189,130
American Century International	484,418	4,975,957		6,830,302		6,830,302		353,297
American Century Large Company Value II	21,693	311,640		358,381		358,381		16,267
American Century Ultra I	16,782	257,643		461,163		461,163		7,936
American Century Ultra II	22,855	399,739		611,387		611,387		13,056
American Century Value	235,023	2,276,688		2,625,186		2,625,186		88,554
BNY Mellon Appreciation	79,781	3,163,979		3,764,084		3,764,084		123,064
BNY Mellon MidCap Stock	314,506	5,921,010		6,268,108		6,268,108		205,588
BNY Mellon Stock Index	147,347	6,828,980		9,484,699		9,484,699		226,188
BNY Mellon Sustainable U.S. Equity	55,688	1,964,242		2,630,663		2,630,663		129,185
BNY Mellon Technology Growth	126,306	2,482,919		4,632,904		4,632,904		206,399
Calvert EAFE International Index F Class	3,135	258,107		293,447		293,447		27,607
Calvert Investment Grade Bond Index	48,577	2,714,091		2,820,837		2,820,837		203,232
Calvert Nasdaq 100 Index	31,674	2,060,968		3,885,296		3,885,296		64,930
Calvert Russell 2000 Small Cap Index F Class	9,694	741,145		868,196		868,196		34,645
Calvert S&P MidCap 400 Index F Class	6,291	679,586		761,199		761,199		29,590
Calvert SRI Balanced	203,407	435,865		512,584		512,584		23,654
Columbia VP Select Mid Cap Value Fund - Class 1	208	2,141		5,805		5,805		205
DWS Capital Growth VIP B	36,603	1,031,589		1,543,899		1,543,899		41,732
DWS CROCI International VIP - Class A	218,261	1,588,516		1,580,215		1,580,215		84,248
DWS Global Income Builder VIP A	263,186	6,165,822		6,598,060		6,598,060		177,146
DWS Global Small Cap VIP B	9,110	98,503		103,766		103,766		6,755
DWS International Growth VIP B Share	5,134	70,047		90,718		90,718		5,992
DWS Small Cap Index A Share	18,641	287,463		324,163		324,163		11,828
Federated Hermes High Income Bond1	232,672	1,510,630		1,491,426		1,491,426		45,633
Federated Hermes Managed Volatility II1	46,122	448,625		511,498		511,498		17,654
Fidelity Asset Manager	6,861	106,193		116,909		116,909		4,563
Fidelity Contrafund	609,178	19,909,456		29,344,223		29,344,223		517,569
Fidelity Contrafund II	165	4,521		7,689		7,689		213
Fidelity Equity-Income	161,191	3,341,959		3,852,454		3,852,454		119,227

SEE NOTES TO FINANCIAL STATEMENTS

4

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2020

Sub-Account	Number of Shares Owned	Investments at Cost		Investments at Fair Value		Net Assets		Accumulation Units Outstanding
Fidelity Freedom Funds 2010 II	23,748	$	317,884	$	336,512	$	336,512	19,535
Fidelity Freedom Funds 2015 II	10,747	133,171		150,888		150,888		8,412
Fidelity Freedom Funds 2020 II	42,735	561,623		637,624		637,624		34,846
Fidelity Freedom Funds 2025 II	64,385	852,810		1,074,599		1,074,599		54,918
Fidelity Freedom Funds 2030 II	109,436	1,501,537		1,830,866		1,830,866		91,743
Fidelity Freedom Funds 2050 II	1,111	18,356		25,919		25,919		952
Fidelity Freedom Income Fund II	14,368	160,510		182,174		182,174		12,486
Fidelity Government Money Market Portfolio - Initial Class	22,160	22,160		22,160		22,160		2,354
Fidelity Government Money Market Portfolio - Service Class II	6,370,522	6,370,522		6,370,522		6,370,522		660,525
Fidelity Growth	172,096	10,285,929		17,725,931		17,725,931		583,153
Fidelity Growth & Income	202,357	3,869,151		4,524,711		4,524,711		175,639
Fidelity Growth Opportunities	84,618	2,635,768		6,561,153		6,561,153		120,294
Fidelity Index 500	3,240	759,595		1,203,862		1,203,862		44,602
Fidelity Mid Cap II	110,105	3,417,064		4,105,808		4,105,808		122,477
Fidelity Overseas II	14,853	317,512		389,894		389,894		29,339
Franklin Allocation VIP Fund - Class 2	80,195	489,820		435,455		435,455		25,930
Franklin Flex Cap Growth VIP Fund - Class 2	62,595	474,043		683,550		683,550		16,311
Franklin Income VIP Fund - Class 2	228,698	3,399,515		3,439,598		3,439,598		175,385
Franklin Mutual Shares VIP Fund - Class 2	218,988	4,110,364		3,633,025		3,633,025		166,862
Franklin Small Cap Value VIP Fund - Class 2	323,433	5,004,429		4,689,782		4,689,782		166,052
Franklin Small-Mid Cap Growth VIP Fund - Class 2	191,684	3,257,946		4,429,856		4,429,856		151,122
Franklin U.S. Government Securities VIP Fund - Class 2	452,399	5,547,243		5,464,967		5,464,967		343,768
Invesco American Franchise Fund I	69,973	3,689,722		6,234,553		6,234,553		210,971
Invesco American Franchise Fund II	10,509	624,133		885,968		885,968		25,117
Invesco Global Real Estate	152,385	2,462,057		2,238,534		2,238,534		64,995
Invesco Health Care	10,030	258,542		337,884		337,884		8,059
Invesco International Growth I	13,451	475,917		571,874		571,874		15,196
Invesco International Growth II	133,509	4,579,695		5,591,308		5,591,308		299,492
Invesco Oppenheimer Discovery Mid Cap Growth Fund I1	1,614	129,691		172,589		172,590		3,403
Invesco Oppenheimer Discovery Mid Cap Growth Fund II1	2,773	242,311		271,859		271,858		9,515

SEE NOTES TO FINANCIAL STATEMENTS

5

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2020

Sub-Account	Number of Shares Owned	Investments at Cost		Investments at Fair Value		Net Assets		Accumulation Units Outstanding
Invesco Small Cap Equity II	14,795	$	251,488	$	283,925	$	283,925	11,911
JP Morgan Insurance Trust Mid Cap Value I	396,653	4,091,590		4,319,531		4,319,531		101,880
JP Morgan Insurance Trust U.S. Equity I	68,605	1,707,711		2,565,836		2,565,836		91,419
Morningstar Aggressive Growth ETF Asset Allocation Class I	10,333	127,508		135,689		135,689		8,227
Morningstar Aggressive Growth ETF Asset Allocation Class II	125,937	1,477,732		1,634,661		1,634,661		95,314
Morningstar Balanced ETF Asset Allocation Class I	63,067	701,287		700,043		700,043		43,202
Morningstar Balanced ETF Asset Allocation Class II	341,284	3,676,198		3,836,036		3,836,036		242,662
Morningstar Conservative ETF Asset Allocation Class I	44,449	490,541		517,825		517,825		36,843
Morningstar Conservative ETF Asset Allocation Class II	10,428	114,589		120,857		120,857		9,400
Morningstar Growth ETF Asset Allocation Class I	9,307	102,134		108,792		108,792		6,584
Morningstar Growth ETF Asset Allocation Class II	252,445	2,749,283		2,893,026		2,893,026		171,952
Morningstar Income & Growth ETF Asset Allocation Class I	10,333	102,827		107,256		107,256		7,172
Morningstar Income & Growth ETF Asset Allocation Class II	60,989	644,154		672,093		672,093		46,818
Neuberger Berman AMT Mid Cap Growth Class S	14,480	346,077		522,186		522,186		16,288
Neuberger Berman AMT Mid Cap Intrinsic Value Class S	1,573	29,694		28,357		28,357		1,661
Neuberger Berman AMT Sustainable Equity Class S	4,738	151,357		145,836		145,836		5,633
PIMCO All Asset Portfolio Advisor	34,734	357,243		389,385		389,385		22,669
PIMCO CommodityRealReturn Strat. Administrative Class	170,024	1,136,355		1,028,652		1,028,652		170,676
PIMCO Total Return Portfolio Advisor	29,039	331,787		336,553		336,553		24,611
Pioneer Bond VCT Class I	180,550	2,013,204		2,126,892		2,126,892		50,373
Pioneer Equity Income VCT Class II	315,312	6,070,207		4,978,801		4,978,801		187,564
Pioneer Fund VCT Class I	2,412,580	38,683,593		40,603,711		40,603,711		255,858
Pioneer High Yield VCT Class II	167,378	1,533,738		1,534,871		1,534,871		81,880
Pioneer Mid Cap Value VCT Class I	287,082	5,540,577		5,158,869		5,158,869		116,844
Pioneer Real Estate VCT Class II	215,314	2,325,374		1,651,463		1,651,463		93,143
Pioneer Select Mid Cap Growth VCT Class I	1,248,505	33,841,000		46,843,906		46,843,906		281,608
Pioneer Strategic Income VCT Class II	362,324	3,674,195		3,866,009		3,866,009		215,812
Templeton Developing Markets VIP Fund - Class 2	151,708	1,301,924		1,765,879		1,765,879		57,398
Templeton Global Bond VIP Fund - Class 2	224,908	3,626,646		3,108,252		3,108,252		185,962
Templeton Growth VIP Fund - Class 2	299,297	3,726,349		3,343,134		3,343,134		177,612

SEE NOTES TO FINANCIAL STATEMENTS

6

Symetra Separate Account C

Statements of Assets and Liabilities (continued)

As of December 31, 2020

Sub-Account	Number of Shares Owned	Investments at Cost		Investments at Fair Value		Net Assets		Accumulation Units Outstanding
Vanguard Balanced	9,455	$	216,609	$	242,810	$	242,810	10,556
Vanguard High Yield Bond	73,074	557,465		593,351		593,351		32,504
Vanguard International	41,406	1,000,708		1,804,092		1,804,092		70,949
Vanguard Mid-Cap Index	45,472	942,647		1,171,792		1,171,792		45,834
Vanguard Real Estate Index	21,138	249,809		262,741		262,741		16,358
Vanguard Total Bond Market Index	71,401	841,258		914,655		914,655		59,772
Vanguard Total Stock Market Index	67,661	2,430,137		3,285,582		3,285,582		118,403
Voya Global High Dividend Low Volatility Portfolio - Class S1	42,690	419,071		447,805		447,805		11,944
VY JPMorgan Emerging Markets Equity Portfolio Initial	25,027	471,851		690,009		690,009		15,820
Wanger USA	2,698	58,526		66,449		66,449		464

1Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

SEE NOTES TO FINANCIAL STATEMENTS

7

Symetra Separate Account C

Statements of Operations and Changes in Net Assets

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
American Century Balanced	$	7,695,737	$	121,436	$	(98,988)	$	(12,475)	$	9,973	$	22,138	$	178,746	$	1,109,800	$	1,310,684	$	1,320,657	$	363,662	$	(1,624,618)	$	(1,260,956)	$	59,701	$	7,755,438
American Century Inflation Protection II	3,425,094		73,901		(40,648)		(5,076)		28,177		(42,099)		—		250,399		208,300		236,477		134,897		(896,028)		(761,131)		(524,654)		2,900,440
American Century International	5,659,417		55,101		(78,333)		(9,698)		(32,930)		76,678		330,956		1,080,187		1,487,821		1,454,891		251,557		(883,066)		(631,509)		823,382		6,482,799
American Century Large Company Value II	276,520		5,986		(3,936)		(490)		1,560		1,415		7,480		60,078		68,973		70,533		15,605		(17,228)		(1,623)		68,910		345,430
American Century Ultra I	298,726		—		(4,309)		(547)		(4,856)		17,296		36,519		46,495		100,310		95,454		8,896		(38,782)		(29,886)		65,568		364,294
American Century Ultra II	602,574		—		(8,921)		(1,074)		(9,995)		37,405		81,441		81,695		200,541		190,546		86,904		(191,137)		(104,233)		86,313		688,887
American Century Value	2,708,809		57,906		(34,390)		(4,259)		19,257		116,099		164,990		316,739		597,828		617,085		94,369		(637,547)		(543,178)		73,907		2,782,716
BNY Mellon Appreciation	2,679,743		35,407		(38,266)		(4,698)		(7,557)		5,305		334,835		552,116		892,256		884,699		42,159		(299,663)		(257,504)		627,195		3,306,938
BNY Mellon MidCap Stock	6,678,013		46,799		(88,057)		(11,317)		(52,575)		62,472		517,994		648,684		1,229,150		1,176,575		153,172		(1,208,299)		(1,055,127)		121,448		6,799,461
BNY Mellon Quality Bond1	1,674,416		31,344		(20,269)		(2,594)		8,481		(10,232)		—		105,118		94,886		103,367		40,947		(251,462)		(210,515)		(107,148)		1,567,268
BNY Mellon Stock Index	8,925,227		140,552		(121,675)		(15,798)		3,079		552,474		500,886		1,393,289		2,446,649		2,449,728		397,170		(1,968,517)		(1,571,347)		878,381		9,803,608
BNY Mellon Sustainable U.S. Equity	2,285,181		37,223		(30,753)		(3,808)		2,662		(98,567)		82,374		700,154		683,961		686,623		40,572		(433,064)		(392,492)		294,131		2,579,312
BNY Mellon Technology Growth	3,105,332		—		(42,306)		(5,415)		(47,721)		213,895		393,434		168,645		775,974		728,253		59,933		(464,316)		(404,383)		323,870		3,429,202
Calvert EAFE International Index F Class	228,778		6,914		(3,209)		(465)		3,240		855		—		40,526		41,381		44,621		18,447		(12,493)		5,954		50,575		279,353

SEE NOTES TO FINANCIAL STATEMENTS

8

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Calvert Investment Grade Bond Index	$	3,127,857	$	92,794	$	(37,536)	$	(4,559)	$	50,699	$	92	$	—	$	154,754	$	154,846	$	205,545	$	237,609	$	(853,556)	$	(615,947)	$	(410,402)	$	2,717,455
Calvert Nasdaq 100 Index	2,873,099		16,170		(41,110)		(5,169)		(30,109)		251,544		78,117		707,496		1,037,157		1,007,048		198,130		(659,653)		(461,523)		545,525		3,418,624
Calvert Russell 2000 Small Cap Index F Class	838,101		7,805		(11,369)		(1,452)		(5,016)		2,997		64,461		115,281		182,739		177,723		53,585		(201,151)		(147,566)		30,157		868,258
Calvert S&P MidCap 400 Index F Class	734,158		8,015		(9,665)		(1,237)		(2,887)		25,033		48,053		89,081		162,167		159,280		56,122		(259,128)		(203,006)		(43,726)		690,432
Calvert SRI Balanced	260,458		5,427		(4,381)		(526)		520		1,975		12,493		53,354		67,822		68,342		146,356		(34,540)		111,816		180,158		440,616
Columbia VP Select Mid Cap Value Fund - Class 1	4,206		—		(62)		—		(62)		36		—		1,288		1,324		1,262		—		—		—		1,262		5,468
DWS Capital Growth VIP B	1,367,699		2,460		(18,187)		(2,209)		(17,936)		64,595		167,527		225,215		457,337		439,401		75,693		(497,140)		(421,447)		17,954		1,385,653
DWS CROCI International VIP - Class A	1,520,683		48,885		(20,121)		(2,425)		26,339		504		—		267,299		267,803		294,142		20,282		(144,457)		(124,175)		169,967		1,690,650
DWS Global Income Builder VIP A	6,372,643		258,908		(84,736)		(10,375)		163,797		81,012		7,738		883,649		972,399		1,136,196		58,396		(681,011)		(622,615)		513,581		6,886,224
DWS Global Small Cap VIP B	95,111		—		(1,235)		(149)		(1,384)		(9,746)		6,062		21,532		17,848		16,464		7,922		(25,827)		(17,905)		(1,441)		93,670
DWS International Growth VIP B Share	60,550		711		(881)		(106)		(276)		943		1,063		15,571		17,577		17,301		1,361		(5,029)		(3,668)		13,633		74,183
DWS Small Cap Index A Share	426,061		3,626		(3,156)		(623)		(153)		8,632		29,855		45,924		84,411		84,258		32,823		(232,021)		(199,198)		(114,940)		311,121
Federated Hermes High Income Bond1	1,486,822		96,107		(19,487)		(2,397)		74,223		(8,031)		—		121,986		113,955		188,178		24,269		(137,312)		(113,043)		75,135		1,561,957
Federated Hermes Managed Volatility II1	511,909		11,509		(6,839)		(821)		3,849		6,450		—		82,079		88,529		92,378		1,699		(39,914)		(38,215)		54,163		566,072

SEE NOTES TO FINANCIAL STATEMENTS

9

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Fidelity Asset Manager	$	122,866	$	2,050	$	(1,519)	$	(182)	$	349	$	(2,082)	$	5,480	$	15,285	$	18,683	$	19,032	$	337	$	(22,240)	$	(21,903)	$	(2,871)	$	119,995
Fidelity Contrafund	24,150,691		114,889		(326,315)		(40,012)		(251,438)		(54,238)		3,057,552		3,938,752		6,942,066		6,690,628		654,832		(5,446,848)		(4,792,016)		1,898,612		26,049,303
Fidelity Contrafund II	4,612		12		(68)		—		(56)		21		605		799		1,425		1,369		—		—		—		1,369		5,981
Fidelity Equity-Income	3,882,557		83,256		(52,804)		(6,512)		23,940		(46,489)		270,348		704,661		928,520		952,460		98,579		(543,021)		(444,442)		508,018		4,390,575
Fidelity Freedom Funds 2010 II	3,829		114		(64)		(8)		42		19		182		397		598		640		2,180		(690)		1,490		2,130		5,959
Fidelity Freedom Funds 2015 II	130,781		2,458		(1,697)		(204)		557		476		9,687		9,721		19,884		20,441		—		(9,881)		(9,881)		10,560		141,341
Fidelity Freedom Funds 2020 II	682,815		11,159		(8,009)		(1,049)		2,101		12,417		37,796		56,171		106,384		108,485		113,313		(257,648)		(144,335)		(35,850)		646,965
Fidelity Freedom Funds 2025 II	811,860		16,690		(11,004)		(1,406)		4,280		6,332		25,231		123,050		154,613		158,893		83,105		(69,430)		13,675		172,568		984,428
Fidelity Freedom Funds 2030 II	1,350,188		26,421		(17,988)		(2,158)		6,275		21,903		51,450		212,815		286,168		292,443		178,737		(216,865)		(38,128)		254,315		1,604,503
Fidelity Freedom Funds 2050 II	17,275		315		(250)		—		65		48		609		3,908		4,565		4,630		150		—		150		4,780		22,055
Fidelity Freedom Income Fund II	129,059		2,626		(1,732)		(238)		656		119		2,875		9,456		12,450		13,106		3,371		(138)		3,233		16,339		145,398
Fidelity Government Money Market Portfolio - Initial Class	156,286		1,164		(524)		(200)		440		—		—		—		—		440		1,721		(135,470)		(133,749)		(133,309)		22,977
Fidelity Government Money Market Portfolio - Service Class II	7,003,609		114,339		(81,211)		(9,720)		23,408		—		—		—		—		23,408		1,116,196		(2,350,764)		(1,234,568)		(1,211,160)		5,792,449
Fidelity Growth	11,540,602		33,748		(162,293)		(19,919)		(148,464)		842,012		808,381		2,083,599		3,733,992		3,585,528		171,047		(1,529,116)		(1,358,069)		2,227,459		13,768,061

SEE NOTES TO FINANCIAL STATEMENTS

10

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Fidelity Growth & Income	$	4,406,674	$	171,952	$	(59,669)	$	(7,631)	$	104,652	$	142,920	$	414,397	$	520,043	$	1,077,360	$	1,182,012	$	84,517	$	(661,024)	$	(576,507)	$	605,505	$	5,012,179
Fidelity Growth Opportunities	3,525,066		6,016		(51,554)		(6,322)		(51,860)		462,802		340,512		560,278		1,363,592		1,311,732		27,539		(611,852)		(584,313)		727,419		4,252,485
Fidelity Index 500	811,062		18,625		(9,511)		(2,661)		6,453		33,185		13,753		186,178		233,116		239,569		72,273		(82,099)		(9,826)		229,743		1,040,805
Fidelity Mid Cap II	4,412,794		28,607		(55,455)		(7,031)		(33,879)		(164,327)		529,464		546,255		911,392		877,513		80,697		(1,102,980)		(1,022,283)		(144,770)		4,268,024
Fidelity Overseas II	320,247		4,939		(4,108)		(495)		336		2,409		14,318		60,878		77,605		77,941		45,399		(95,912)		(50,513)		27,428		347,675
Franklin Allocation VIP Fund - Class 2	411,206		15,162		(5,396)		(648)		9,118		(6,851)		27,952		41,947		63,048		72,166		20,676		(61,031)		(40,355)		31,811		443,017
Franklin Flex Cap Growth VIP Fund - Class 2	331,796		—		(5,143)		(617)		(5,760)		809		20,313		83,609		104,731		98,971		23,390		(15,785)		7,605		106,576		438,372
Franklin Income VIP Fund - Class 2	4,168,007		226,349		(52,167)		(6,541)		167,641		(36,110)		68,411		366,190		398,491		566,132		230,680		(930,630)		(699,950)		(133,818)		4,034,189
Franklin Mutual Shares VIP Fund - Class 2	4,083,528		76,136		(53,252)		(6,497)		16,387		(74,889)		407,107		459,397		791,615		808,002		98,853		(585,368)		(486,515)		321,487		4,405,015
Franklin Small Cap Value VIP Fund - Class 2	4,982,783		56,131		(65,684)		(8,218)		(17,771)		(343,967)		894,190		614,952		1,165,175		1,147,404		189,332		(1,138,027)		(948,695)		198,709		5,181,492
Franklin Small-Mid Cap Growth VIP Fund - Class 2	3,143,476		—		(44,416)		(5,410)		(49,826)		(200,052)		505,646		634,851		940,445		890,619		120,681		(736,775)		(616,094)		274,525		3,418,001
Franklin U.S. Government Securities VIP Fund - Class 2	6,641,094		178,538		(75,799)		(9,826)		92,913		(125,461)		—		265,820		140,359		233,272		350,541		(1,839,438)		(1,488,897)		(1,255,625)		5,385,469
Invesco American Franchise Fund I	3,886,740		—		(55,464)		(6,731)		(62,195)		234,661		630,323		500,854		1,365,838		1,303,643		78,163		(496,777)		(418,614)		885,029		4,771,769
Invesco American Franchise Fund II	719,287		—		(10,017)		(1,209)		(11,226)		19,430		114,648		112,901		246,979		235,753		38,629		(149,523)		(110,894)		124,859		844,146

SEE NOTES TO FINANCIAL STATEMENTS

11

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Invesco Global Real Estate	$	2,940,091	$	137,599	$	(39,735)	$	(5,077)	$	92,787	$	158,955	$	3,518	$	347,015	$	509,488	$	602,275	$	43,017	$	(474,332)	$	(431,315)	$	170,960	$	3,111,051
Invesco Health Care	246,498		120		(3,445)		(442)		(3,767)		5,903		6,710		65,756		78,369		74,602		3,040		(9,624)		(6,584)		68,018		314,516
Invesco International Growth I	609,452		9,341		(8,065)		(978)		298		47,171		37,731		61,449		146,351		146,649		14,438		(208,656)		(194,218)		(47,569)		561,883
Invesco International Growth II	6,145,384		78,120		(78,748)		(9,596)		(10,224)		135,753		392,640		965,349		1,493,742		1,483,518		238,356		(1,878,280)		(1,639,924)		(156,406)		5,988,978
Invesco Mid Cap Growth Fund I1	113,219		—		(1,731)		(210)		(1,941)		1,078		20,961		16,775		38,814		36,873		1,405		(626)		779		37,652		150,871
Invesco Mid Cap Growth Fund II1	225,112		—		(3,097)		(381)		(3,478)		(3,576)		37,865		36,732		71,021		67,543		18,612		(63,651)		(45,039)		22,504		247,616
Invesco Small Cap Equity II	303,877		—		(3,130)		(392)		(3,522)		(27,411)		29,632		63,300		65,521		61,999		21,543		(144,700)		(123,157)		(61,158)		242,719
JP Morgan Insurance Trust Mid Cap Value I	4,405,684		77,106		(59,909)		(7,413)		9,784		74,167		320,154		645,498		1,039,819		1,049,603		154,077		(894,648)		(740,571)		309,032		4,714,716
JP Morgan Insurance Trust U.S. Equity I	2,166,445		20,702		(29,475)		(4,075)		(12,848)		210,541		169,832		240,494		620,867		608,019		42,141		(380,058)		(337,917)		270,102		2,436,547
Morningstar Aggressive Growth ETF Asset Allocation Class I	117,472		2,297		(1,231)		(514)		552		3,983		4,529		14,951		23,463		24,015		48,876		(53,202)		(4,326)		19,689		137,161
Morningstar Aggressive Growth ETF Asset Allocation Class II	1,554,524		24,276		(20,572)		(2,469)		1,235		19,809		55,694		225,151		300,654		301,889		36,929		(221,522)		(184,593)		117,296		1,671,820
Morningstar Balanced ETF Asset Allocation Class I	748,283		14,891		(6,253)		(2,046)		6,592		(19,222)		13,056		97,181		91,015		97,607		892		(181,503)		(180,611)		(83,004)		665,279
Morningstar Balanced ETF Asset Allocation Class II	4,902,232		84,019		(57,314)		(7,033)		19,672		(90,854)		84,024		634,184		627,354		647,026		78,179		(1,360,658)		(1,282,479)		(635,453)		4,266,779
Morningstar Conservative ETF Asset Allocation Class I	460,473		10,818		(4,536)		(1,552)		4,730		(723)		3,762		30,303		33,342		38,072		111		(5,983)		(5,872)		32,200		492,673

SEE NOTES TO FINANCIAL STATEMENTS

12

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Morningstar Conservative ETF Asset Allocation Class II	$	212,955	$	2,990	$	(2,162)	$	(268)	$	560	$	(3,536)	$	1,169	$	15,749	$	13,382	$	13,942	$	2,956	$	(80,503)	$	(77,547)	$	(63,605)	$	149,350
Morningstar Growth ETF Asset Allocation Class I	87,100		1,956		(912)		(384)		660		5		4,380		11,064		15,449		16,109		—		(472)		(472)		15,637		102,737
Morningstar Growth ETF Asset Allocation Class II	3,348,631		54,125		(41,953)		(5,034)		7,138		(19,019)		139,172		430,610		550,763		557,901		42,573		(757,032)		(714,459)		(156,558)		3,192,073
Morningstar Income & Growth ETF Asset Allocation Class I	113,346		2,722		(1,082)		(401)		1,239		1,256		2,678		7,478		11,412		12,651		—		(13,661)		(13,661)		(1,010)		112,336
Morningstar Income & Growth ETF Asset Allocation Class II	797,988		14,869		(9,227)		(1,147)		4,495		(18,757)		16,563		78,494		76,300		80,795		41,369		(177,012)		(135,643)		(54,848)		743,140
Neuberger Berman AMT Mid Cap Growth Class S	589,712		—		(8,413)		(1,019)		(9,432)		10,373		49,445		124,731		184,549		175,117		27,535		(123,833)		(96,298)		78,819		668,531
Neuberger Berman AMT Mid Cap Intrinsic Value Class S	47,919		87		(579)		(70)		(562)		(414)		3,902		4,027		7,515		6,953		2,816		(17,922)		(15,106)		(8,153)		39,766
Neuberger Berman AMT Sustainable Equity Class S	—		356		(1,005)		(120)		(769)		(6,450)		6,835		(24,974)		(24,589)		(25,358)		167,673		(20,944)		146,729		121,371		121,371
PIMCO All Asset Portfolio Advisor	549,735		12,852		(6,078)		(730)		6,044		(8,573)		—		50,188		41,615		47,659		9,016		(235,891)		(226,875)		(179,216)		370,519
PIMCO CommodityRealReturn Strat. Administrative Class	1,234,594		55,266		(15,555)		(1,904)		37,807		(52,377)		—		131,804		79,427		117,234		109,204		(296,780)		(187,576)		(70,342)		1,164,252
PIMCO Total Return Portfolio Advisor	—		5,019		(2,186)		—		2,833		189		—		7,285		7,474		10,307		260,865		(5,314)		255,551		265,858		265,858
Pioneer Bond VCT Class I	2,281,525		75,849		(29,005)		(3,588)		43,256		(34,232)		—		165,768		131,536		174,792		195,328		(424,840)		(229,512)		(54,720)		2,226,805
Pioneer Equity Income VCT Class II	6,200,552		146,405		(77,808)		(9,441)		59,156		(893,076)		2,628,161		(474,039)		1,261,046		1,320,202		188,623		(1,755,835)		(1,567,212)		(247,010)		5,953,542
Pioneer Fund VCT Class I	$	30,173,367	$	339,146	$	(419,056)	$	(50,360)	$	(130,270)	$	(1,958,228)	$	5,122,143	$	5,510,134	$	8,674,049	$	8,543,779	$	252,980	$	(3,288,228)	$	(3,035,248)	$	5,508,531	$	35,681,898

SEE NOTES TO FINANCIAL STATEMENTS

13

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2019
Pioneer High Yield VCT Class II	1,841,312		84,364		(22,665)		(3,042)		58,657		(26,578)		—		185,659		159,081		217,738		33,706		(345,684)		(311,978)		(94,240)		1,747,072
Pioneer Mid Cap Value VCT Class I	4,865,357		71,186		(67,760)		(8,185)		(4,759)		159,908		336,932		755,486		1,252,326		1,247,567		85,255		(650,046)		(564,791)		682,776		5,548,133
Pioneer Real Estate VCT Class II	2,296,454		45,444		(30,155)		(3,809)		11,480		(354,658)		711,155		196,104		552,601		564,081		68,944		(728,305)		(659,361)		(95,280)		2,201,174
Pioneer Select Mid Cap Growth VCT Class I	31,681,425		—		(458,260)		(55,261)		(513,521)		1,648,348		4,532,139		3,902,020		10,082,507		9,568,986		258,938		(3,919,273)		(3,660,335)		5,908,651		37,590,076
Pioneer Strategic Income VCT Class II	5,355,627		155,070		(62,722)		(7,916)		84,432		(37,116)		—		340,619		303,503		387,935		220,147		(1,478,099)		(1,257,952)		(870,017)		4,485,610
Templeton Developing Markets VIP Fund - Class 2	1,633,271		17,413		(21,202)		(2,602)		(6,391)		10,717		—		368,873		379,590		373,199		41,047		(340,283)		(299,236)		73,963		1,707,234
Templeton Global Bond VIP Fund - Class 2	4,565,851		300,084		(52,769)		(6,679)		240,636		(113,627)		—		(94,953)		(208,580)		32,056		166,194		(964,820)		(798,626)		(766,570)		3,799,281
Templeton Growth VIP Fund - Class 2	3,653,293		102,382		(45,380)		(5,471)		51,531		(203,859)		703,321		(91,612)		407,850		459,381		175,204		(694,258)		(519,054)		(59,673)		3,593,620
Vanguard Balanced	499,157		14,774		(4,533)		(1,354)		8,887		10,293		29,707		35,562		75,562		84,449		847		(325,502)		(324,655)		(240,206)		258,951
Vanguard High Yield Bond	842,797		51,785		(12,498)		(2,825)		36,462		1,074		—		90,742		91,816		128,278		957,105		(738,167)		218,938		347,216		1,190,013
Vanguard International	1,697,455		20,109		(12,797)		(2,683)		4,629		101,749		43,847		241,111		386,707		391,336		124,928		(871,019)		(746,091)		(354,755)		1,342,700
Vanguard Mid-Cap Index	1,337,353		17,970		(11,427)		(3,138)		3,405		67,509		92,623		162,611		322,743		326,148		212,759		(728,746)		(515,987)		(189,839)		1,147,514
Vanguard Real Estate Index	346,791		8,707		(3,141)		(851)		4,715		4,942		15,737		55,956		76,635		81,350		48,953		(181,967)		(133,014)		(51,664)		295,127
Vanguard Total Bond Market Index	$	1,661,392	$	31,926	$	(10,940)	$	(2,718)	$	18,268	$	1,102	$	—	$	64,468	$	65,570	$	83,838	$	101,472	$	(901,424)	$	(799,952)	$	(716,114)	$	945,278

SEE NOTES TO FINANCIAL STATEMENTS

14

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2019

Sub-Account	Net Assets as of January 1, 2019	Dividends	Mortality and Expense Risk Charge	Asset-Related Administration Charge	Net Investment Income (Loss)	Realized Gain (Loss) on Investments	Net Realized Capital Gain Distributions Received	Net Change in Unrealized Appreciation/Depreciation	Net Gain (Loss) on Investments	Net Increase (Decrease) in Net Assets Resulting from Operations	Contract Purchase Payments and Transfers In	Contract Terminations, Transfers and Maintenance Charges	Increase (Decrease) in Net Assets from Contract Transactions	Total Increase (Decrease) In Net Assets	Net Assets  as of December 31,  2019
Vanguard Total Stock Market Index	4,731,419	58,015	(32,597)	(6,409)	19,009	345,063	103,872	533,284	982,219	1,001,228	270,427	(2,862,854)	(2,592,427)	(1,591,199)	3,140,220
Voya Global High Dividend Low Volatility Portfolio - Class S1	478,856	13,223	(6,516)	(789)	5,918	91	25,647	60,737	86,475	92,393	1,355	(37,551)	(36,196)	56,197	535,053
VY JPMorgan Emerging Markets Equity Portfolio Initial	455,452	723	(6,594)	(791)	(6,662)	1,836	29,885	110,901	142,622	135,960	3,176	(22,526)	(19,350)	116,610	572,062
Wanger USA	87,471	266	(1,287)	(155)	(1,176)	(2,021)	18,008	10,780	26,767	25,591	130	(1,939)	(1,809)	23,782	111,253

1Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

SEE NOTES TO FINANCIAL STATEMENTS

15

Symetra Separate Account C

Statements of Operations and Changes in Net Assets

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
American Century Balanced	$	7,755,438	$	86,379	$	(92,946)	$	(11,698)	$	(18,265)	$	63,817	$	252,841	$	462,967	$	779,625	$	761,360	$	326,546	$	(968,991)	$	(642,445)	$	118,915	$	7,874,353
American Century Inflation Protection II	2,900,440		36,625		(34,991)		(4,333)		(2,699)		11,868		—		200,243		212,111		209,412		217,889		(646,251)		(428,362)		(218,950)		2,681,490
American Century International	6,482,799		29,985		(77,073)		(9,505)		(56,593)		140,186		90,436		1,170,752		1,401,374		1,344,781		256,092		(1,253,370)		(997,278)		347,503		6,830,302
American Century Large Company Value II	345,430		5,068		(4,053)		(508)		507		5,408		3,361		7,804		16,573		17,080		89,905		(94,034)		(4,129)		12,951		358,381
American Century Ultra I	364,294		—		(4,957)		(633)		(5,590)		27,963		35,914		102,696		166,573		160,983		2,722		(66,836)		(64,114)		96,869		461,163
American Century Ultra II	688,887		—		(7,465)		(906)		(8,371)		58,393		69,656		94,430		222,479		214,108		39,438		(331,046)		(291,608)		(77,500)		611,387
American Century Value	2,782,716		54,747		(29,515)		(3,674)		21,558		24,553		60,927		(115,594)		(30,114)		(8,556)		120,292		(269,266)		(148,974)		(157,530)		2,625,186
BNY Mellon Appreciation	3,306,938		26,274		(41,650)		(5,093)		(20,469)		1,701		274,087		437,049		712,837		692,368		46,552		(281,774)		(235,222)		457,146		3,764,084
BNY Mellon MidCap Stock	6,799,461		47,947		(70,630)		(9,055)		(31,738)		(292,645)		—		614,901		322,256		290,518		171,942		(993,813)		(821,871)		(531,353)		6,268,108
BNY Mellon Quality Bond1	1,567,268		9,206		(6,015)		(766)		2,425		40,197		—		(15,304)		24,893		27,318		25,530		(1,620,116)		(1,594,586)		(1,567,268)		—
BNY Mellon Stock Index	9,803,608		117,657		(112,466)		(14,521)		(9,330)		507,606		566,878		296,123		1,370,607		1,361,277		387,410		(2,067,596)		(1,680,186)		(318,909)		9,484,699
BNY Mellon Sustainable U.S. Equity	2,579,312		28,433		(30,130)		(3,668)		(5,365)		(29,799)		30,856		461,755		462,812		457,447		132,400		(538,496)		(406,096)		51,351		2,630,663
BNY Mellon Technology Growth	3,429,202		10,165		(48,983)		(6,265)		(45,083)		455,379		405,658		1,263,386		2,124,423		2,079,340		186,713		(1,062,351)		(875,638)		1,203,702		4,632,904
Calvert EAFE International Index F Class	279,353		8,773		(3,208)		(465)		5,100		(1,132)		—		12,807		11,675		16,775		14,208		(16,889)		(2,681)		14,094		293,447

SEE NOTES TO FINANCIAL STATEMENTS

16

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020	Dividends	Mortality and Expense Risk Charge	Asset-Related Administration Charge	Net Investment Income (Loss)	Realized Gain (Loss) on Investments	Net Realized Capital Gain Distributions Received	Net Change in Unrealized Appreciation/Depreciation	Net Gain (Loss) on Investments	Net Increase (Decrease) in Net Assets Resulting from Operations	Contract Purchase Payments and Transfers In	Contract Terminations, Transfers and Maintenance Charges	Increase (Decrease) in Net Assets from Contract Transactions	Total Increase (Decrease) In Net Assets	Net Assets  as of December 31,  2020
Calvert Investment Grade Bond Index	2,717,455	85,172	(35,993)	(4,354)	44,825	28,692	—	90,852	119,544	164,369	635,005	(695,992)	(60,987)	103,382	2,820,837
Calvert Nasdaq 100 Index	3,418,624	15,236	(44,999)	(5,607)	(35,370)	651,335	118,425	668,577	1,438,337	1,402,967	230,382	(1,166,677)	(936,295)	466,672	3,885,296
Calvert Russell 2000 Small Cap Index F Class	868,258	7,730	(9,055)	(1,166)	(2,491)	11,656	43,231	86,311	141,198	138,707	52,772	(191,541)	(138,769)	(62)	868,196
Calvert S&P MidCap 400 Index F Class	690,432	7,730	(7,780)	(1,015)	(1,065)	421	22,683	56,550	79,654	78,589	45,207	(53,029)	(7,822)	70,767	761,199
Calvert SRI Balanced	440,616	6,938	(5,640)	(679)	619	711	14,319	44,855	59,885	60,504	22,900	(11,436)	11,464	71,968	512,584
Columbia VP Select Mid Cap Value Fund - Class 1	5,468	—	(60)	—	(60)	34	—	363	397	337	—	—	—	337	5,805
DWS Capital Growth VIP B	1,385,653	3,923	(17,822)	(2,162)	(16,061)	102,426	98,655	273,174	474,255	458,194	31,383	(331,331)	(299,948)	158,246	1,543,899
DWS CROCI International VIP - Class A	1,690,650	50,763	(18,111)	(2,184)	30,468	(30,037)	—	6,804	(23,233)	7,235	9,351	(127,021)	(117,670)	(110,435)	1,580,215
DWS Global Income Builder VIP A	6,886,224	201,115	(78,621)	(9,634)	112,860	34,921	148,109	94,738	277,768	390,628	55,271	(734,063)	(678,792)	(288,164)	6,598,060
DWS Global Small Cap VIP B	93,670	519	(1,096)	(132)	(709)	(1,824)	—	17,265	15,441	14,732	7,185	(11,821)	(4,636)	10,096	103,766
DWS International Growth VIP B Share	74,183	903	(938)	(112)	(147)	304	—	15,595	15,899	15,752	1,708	(925)	783	16,535	90,718
DWS Small Cap Index A Share	311,121	2,634	(2,513)	(503)	(382)	(14,039)	24,367	32,634	42,962	42,580	35,076	(64,614)	(29,538)	13,042	324,163
Federated Hermes High Income Bond1	1,561,957	87,159	(18,165)	(2,238)	66,756	(19,411)	—	9,120	(10,291)	56,465	23,029	(150,025)	(126,996)	(70,531)	1,491,426
Federated Hermes Managed Volatility II1	566,072	13,262	(6,296)	(756)	6,210	5,727	—	(18,569)	(12,842)	(6,632)	3,476	(51,418)	(47,942)	(54,574)	511,498

SEE NOTES TO FINANCIAL STATEMENTS

17

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
Fidelity Asset Manager	$	119,995	$	1,622	$	(1,442)	$	(173)	$	7	$	(1,486)	$	1,467	$	14,352	$	14,333	$	14,340	$	358	$	(17,784)	$	(17,426)	$	(3,086)	$	116,909
Fidelity Contrafund	26,049,303		65,994		(335,087)		(41,126)		(310,219)		509,749		139,184		6,576,033		7,224,966		6,914,747		412,044		(4,031,871)		(3,619,827)		3,294,920		29,344,223
Fidelity Contrafund II	5,981		5		(82)		—		(77)		33		34		1,718		1,785		1,708		—		—		—		1,708		7,689
Fidelity Equity-Income	4,390,575		64,678		(46,556)		(5,731)		12,391		(40,844)		179,814		(16,071)		122,899		135,290		135,302		(808,713)		(673,411)		(538,121)		3,852,454
Fidelity Freedom Funds 2010 II	5,959		3,303		(1,796)		(215)		1,292		252		1,393		18,441		20,086		21,378		312,705		(3,530)		309,175		330,553		336,512
Fidelity Freedom Funds 2015 II	141,341		1,451		(1,721)		(207)		(477)		624		6,752		9,274		16,650		16,173		—		(6,626)		(6,626)		9,547		150,888
Fidelity Freedom Funds 2020 II	646,965		6,034		(7,627)		(1,013)		(2,606)		12,935		35,293		31,834		80,062		77,456		20,495		(107,292)		(86,797)		(9,341)		637,624
Fidelity Freedom Funds 2025 II	984,428		9,899		(12,372)		(1,577)		(4,050)		17,428		43,251		80,633		141,312		137,262		39,332		(86,423)		(47,091)		90,171		1,074,599
Fidelity Freedom Funds 2030 II	1,604,503		16,091		(20,006)		(2,401)		(6,316)		16,096		78,225		149,969		244,290		237,974		215,548		(227,159)		(11,611)		226,363		1,830,866
Fidelity Freedom Funds 2050 II	22,055		168		(272)		—		(104)		78		947		2,943		3,968		3,864		—		—		—		3,864		25,919
Fidelity Freedom Income Fund II	145,398		1,868		(2,044)		(277)		(453)		299		2,714		12,200		15,213		14,760		22,874		(858)		22,016		36,776		182,174
Fidelity Government Money Market Portfolio - Initial Class	22,977		74		(216)		(86)		(228)		—		—		—		—		(228)		2,688		(3,277)		(589)		(817)		22,160
Fidelity Government Money Market Portfolio - Service Class II	5,792,449		13,838		(81,448)		(9,621)		(77,231)		—		—		—		—		(77,231)		3,940,509		(3,285,205)		655,304		578,073		6,370,522
Fidelity Growth	13,768,061		11,231		(188,710)		(23,095)		(200,574)		981,049		1,425,235		3,261,129		5,667,413		5,466,839		136,284		(1,645,253)		(1,508,969)		3,957,870		17,725,931

SEE NOTES TO FINANCIAL STATEMENTS

18

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
Fidelity Growth & Income	$	5,012,179	$	88,249	$	(53,126)	$	(6,791)	$	28,332	$	62,331	$	229,991	$	(95,323)	$	196,999	$	225,331	$	99,321	$	(812,120)	$	(712,799)	$	(487,468)	$	4,524,711
Fidelity Growth Opportunities	4,252,485		691		(62,826)		(7,722)		(69,857)		331,992		288,446		2,141,789		2,762,227		2,692,370		23,274		(406,976)		(383,702)		2,308,668		6,561,153
Fidelity Index 500	1,040,805		18,147		(10,428)		(2,917)		4,802		8,653		3,589		154,484		166,726		171,528		76,459		(84,930)		(8,471)		163,057		1,203,862
Fidelity Mid Cap II	4,268,024		14,329		(44,340)		(5,577)		(35,588)		(150,031)		—		633,589		483,558		447,970		137,507		(747,693)		(610,186)		(162,216)		4,105,808
Fidelity Overseas II	347,675		755		(4,213)		(508)		(3,966)		3,214		1,443		46,706		51,363		47,397		7,485		(12,663)		(5,178)		42,219		389,894
Franklin Allocation VIP Fund - Class 2	443,017		6,523		(5,391)		(647)		485		(31,028)		116,225		(43,590)		41,607		42,092		19,003		(68,657)		(49,654)		(7,562)		435,455
Franklin Flex Cap Growth VIP Fund - Class 2	438,372		—		(6,569)		(787)		(7,356)		20,765		29,397		149,177		199,339		191,983		144,130		(90,935)		53,195		245,178		683,550
Franklin Income VIP Fund - Class 2	4,034,189		199,825		(42,670)		(5,303)		151,852		(105,268)		2,831		(153,132)		(255,569)		(103,717)		133,278		(624,152)		(490,874)		(594,591)		3,439,598
Franklin Mutual Shares VIP Fund - Class 2	4,405,015		96,451		(43,176)		(5,262)		48,013		(274,219)		134,092		(267,613)		(407,740)		(359,727)		115,299		(527,562)		(412,263)		(771,990)		3,633,025
Franklin Small Cap Value VIP Fund - Class 2	5,181,492		63,231		(51,949)		(6,465)		4,817		(320,952)		268,939		169,661		117,648		122,465		235,537		(849,712)		(614,175)		(491,710)		4,689,782
Franklin Small-Mid Cap Growth VIP Fund - Class 2	3,418,001		—		(46,352)		(5,591)		(51,943)		(39,520)		495,622		1,237,494		1,693,596		1,641,653		75,387		(705,185)		(629,798)		1,011,855		4,429,856
Franklin U.S. Government Securities VIP Fund - Class 2	5,385,469		183,077		(67,560)		(8,402)		107,115		(42,101)		—		61,833		19,732		126,847		1,407,436		(1,454,785)		(47,349)		79,498		5,464,967
Invesco American Franchise Fund I	4,771,769		3,711		(64,766)		(7,863)		(68,918)		250,707		387,210		1,271,444		1,909,361		1,840,443		57,049		(434,708)		(377,659)		1,462,784		6,234,553
Invesco American Franchise Fund II	844,146		—		(10,349)		(1,251)		(11,600)		70,001		59,243		165,508		294,752		283,152		18,948		(260,278)		(241,330)		41,822		885,968

SEE NOTES TO FINANCIAL STATEMENTS

19

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
Invesco Global Real Estate	$	3,111,051	$	113,962	$	(29,539)	$	(3,761)	$	80,662	$	(9,063)	$	63,654	$	(571,250)	$	(516,659)	$	(435,997)	$	73,750	$	(510,270)	$	(436,520)	$	(872,517)	$	2,238,534
Invesco Health Care	314,516		957		(3,751)		(478)		(3,272)		11,932		7,286		22,578		41,796		38,524		4,240		(19,396)		(15,156)		23,368		337,884
Invesco International Growth I	561,883		11,968		(6,496)		(791)		4,681		13,200		11,531		36,114		60,845		65,526		28,225		(83,760)		(55,535)		9,991		571,874
Invesco International Growth II	5,988,978		108,331		(65,916)		(8,021)		34,394		101,062		118,086		350,069		569,217		603,611		267,274		(1,268,555)		(1,001,281)		(397,670)		5,591,308
Invesco Mid Cap Growth Fund I1	150,871		—		(570)		(69)		(639)		6,235		39,037		(38,210)		7,062		6,423		150		(157,444)		(157,294)		(150,871)		—
Invesco Mid Cap Growth Fund II1	247,616		—		(977)		(121)		(1,098)		(1,257)		71,351		(8,761)		61,333		60,235		10,433		(318,284)		(307,851)		(247,616)		—
Invesco Oppenheimer Discovery Mid Cap Growth Fund I1	—		—		(1,309)		(159)		(1,468)		2,215		—		42,899		45,114		43,646		148,853		(19,909)		128,944		172,590		172,590
Invesco Oppenheimer Discovery Mid Cap Growth Fund II1	—		—		(2,144)		(264)		(2,408)		(5,235)		—		29,547		24,312		21,904		345,978		(96,024)		249,954		271,858		271,858
Invesco Small Cap Equity II	242,719		61		(2,632)		(322)		(2,893)		(6,254)		21,918		40,720		56,384		53,491		66,374		(78,659)		(12,285)		41,206		283,925
JP Morgan Insurance Trust Mid Cap Value I	4,714,716		58,240		(49,495)		(6,102)		2,643		(97,646)		242,996		(219,631)		(74,281)		(71,638)		280,568		(604,115)		(323,547)		(395,185)		4,319,531
JP Morgan Insurance Trust U.S. Equity I	2,436,547		17,815		(28,712)		(3,924)		(14,821)		173,712		143,663		162,016		479,391		464,570		21,061		(356,342)		(335,281)		129,289		2,565,836
Morningstar Aggressive Growth ETF Asset Allocation Class I	137,161		2,459		(1,119)		(447)		893		918		2,413		6,844		10,175		11,068		—		(12,540)		(12,540)		(1,472)		135,689
Morningstar Aggressive Growth ETF Asset Allocation Class II	1,671,820		26,535		(18,701)		(2,244)		5,590		6,875		29,440		78,097		114,412		120,002		29,207		(186,368)		(157,161)		(37,159)		1,634,661
Morningstar Balanced ETF Asset Allocation Class I	665,279		14,925		(5,968)		(1,919)		7,038		(1,766)		8,458		38,450		45,142		52,180		2,158		(19,574)		(17,416)		34,764		700,043

SEE NOTES TO FINANCIAL STATEMENTS

20

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
Morningstar Balanced ETF Asset Allocation Class II	$	4,266,779	$	71,786	$	(46,219)	$	(5,661)	$	19,906	$	(75,131)	$	45,959	$	268,081	$	238,909	$	258,815	$	138,637	$	(828,195)	$	(689,558)	$	(430,743)	$	3,836,036
Morningstar Conservative ETF Asset Allocation Class I	492,673		9,736		(4,686)		(1,601)		3,449		(159)		2,745		20,702		23,288		26,737		760		(2,345)		(1,585)		25,152		517,825
Morningstar Conservative ETF Asset Allocation Class II	149,350		2,017		(1,858)		(233)		(74)		2,204		645		3,582		6,431		6,357		40,197		(75,047)		(34,850)		(28,493)		120,857
Morningstar Growth ETF Asset Allocation Class I	102,737		2,212		(906)		(382)		924		(38)		2,794		5,089		7,845		8,769		—		(2,714)		(2,714)		6,055		108,792
Morningstar Growth ETF Asset Allocation Class II	3,192,073		52,229		(34,935)		(4,192)		13,102		(30,408)		74,720		152,844		197,156		210,258		73,964		(583,269)		(509,305)		(299,047)		2,893,026
Morningstar Income & Growth ETF Asset Allocation Class I	112,336		2,553		(996)		(377)		1,180		(1,483)		1,269		6,163		5,949		7,129		97,592		(109,801)		(12,209)		(5,080)		107,256
Morningstar Income & Growth ETF Asset Allocation Class II	743,140		13,276		(8,758)		(1,084)		3,434		(9,811)		7,455		45,325		42,969		46,403		62,504		(179,954)		(117,450)		(71,047)		672,093
Neuberger Berman AMT Mid Cap Growth Class S	668,531		—		(6,401)		(775)		(7,176)		95,142		23,929		55,082		174,153		166,977		13,948		(327,270)		(313,322)		(146,345)		522,186
Neuberger Berman AMT Mid Cap Intrinsic Value Class S	39,766		182		(348)		(42)		(208)		(2,570)		—		(757)		(3,327)		(3,535)		2,182		(10,056)		(7,874)		(11,409)		28,357
Neuberger Berman AMT Sustainable Equity Class S	121,371		479		(1,521)		(184)		(1,226)		(716)		5,277		19,452		24,013		22,787		4,648		(2,970)		1,678		24,465		145,836
PIMCO All Asset Portfolio Advisor	370,519		17,293		(4,438)		(526)		12,329		141		—		11,844		11,985		24,314		12,468		(17,916)		(5,448)		18,866		389,385
PIMCO CommodityRealReturn Strat. Administrative Class	1,164,252		64,459		(12,385)		(1,517)		50,557		(71,481)		—		15,132		(56,349)		(5,792)		98,825		(228,633)		(129,808)		(135,600)		1,028,652
PIMCO Total Return Portfolio Advisor	265,858		6,873		(4,427)		—		2,446		10,923		5,840		(2,521)		14,242		16,688		645,566		(591,559)		54,007		70,695		336,553
Pioneer Bond VCT Class I	$	2,226,805	$	64,527	$	(26,592)	$	(3,285)	$	34,650	$	(17,913)	$	—	$	124,973	$	107,060	$	141,710	$	36,444	$	(278,067)	$	(241,623)	$	(99,913)	$	2,126,892

SEE NOTES TO FINANCIAL STATEMENTS

21

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020		Dividends		Mortality and Expense Risk Charge		Asset-Related Administration Charge		Net Investment Income (Loss)		Realized Gain (Loss) on Investments		Net Realized Capital Gain Distributions Received		Net Change in Unrealized Appreciation/Depreciation		Net Gain (Loss) on Investments		Net Increase (Decrease) in Net Assets Resulting from Operations		Contract Purchase Payments and Transfers In		Contract Terminations, Transfers and Maintenance Charges		Increase (Decrease) in Net Assets from Contract Transactions		Total Increase (Decrease) In Net Assets		Net Assets  as of December 31,  2020
Pioneer Equity Income VCT Class II	5,953,542		117,017		(61,403)		(7,415)		48,199		(1,119,888)		196,385		727,743		(195,760)		(147,561)		332,667		(1,159,847)		(827,180)		(974,741)		4,978,801
Pioneer Fund VCT Class I	35,681,898		273,355		(445,581)		(53,513)		(225,739)		(1,974,790)		2,992,623		6,785,094		7,802,927		7,577,188		168,168		(2,823,543)		(2,655,375)		4,921,813		40,603,711
Pioneer High Yield VCT Class II	1,747,072		78,125		(19,074)		(2,543)		56,508		(30,505)		—		(22,381)		(52,886)		3,622		68,916		(284,739)		(215,823)		(212,201)		1,534,871
Pioneer Mid Cap Value VCT Class I	5,548,133		57,203		(58,712)		(7,097)		(8,606)		(680)		152,417		(146,421)		5,316		(3,290)		52,731		(438,705)		(385,974)		(389,264)		5,158,869
Pioneer Real Estate VCT Class II	2,201,174		26,940		(22,438)		(2,804)		1,698		(495,220)		453,930		(175,256)		(216,546)		(214,848)		144,562		(479,425)		(334,863)		(549,711)		1,651,463
Pioneer Select Mid Cap Growth VCT Class I	37,590,076		—		(476,618)		(57,312)		(533,930)		666,093		2,724,788		10,071,002		13,461,883		12,927,953		205,546		(3,879,669)		(3,674,123)		9,253,830		46,843,906
Pioneer Strategic Income VCT Class II	4,485,610		133,590		(51,420)		(6,419)		75,751		5,449		13,004		106,662		125,115		200,866		229,990		(1,050,457)		(820,467)		(619,601)		3,866,009
Templeton Developing Markets VIP Fund - Class 2	1,707,234		63,555		(19,109)		(2,338)		42,108		52,494		39,885		100,738		193,117		235,225		36,239		(212,819)		(176,580)		58,645		1,765,879
Templeton Global Bond VIP Fund - Class 2	3,799,281		294,603		(43,139)		(5,444)		246,020		(137,296)		—		(356,615)		(493,911)		(247,891)		191,685		(634,823)		(443,138)		(691,029)		3,108,252
Templeton Growth VIP Fund - Class 2	3,593,620		91,886		(38,673)		(4,666)		48,547		(246,492)		—		286,765		40,273		88,820		112,084		(451,390)		(339,306)		(250,486)		3,343,134
Vanguard Balanced	258,951		6,818		(2,458)		(596)		3,764		(3,321)		8,313		8,313		13,305		17,069		—		(33,210)		(33,210)		(16,141)		242,810
Vanguard High Yield Bond	1,190,013		13,447		(7,874)		(1,902)		3,671		(24,804)		—		(30,096)		(54,900)		(51,229)		567,213		(1,112,646)		(545,433)		(596,662)		593,351
Vanguard International	1,342,700		16,169		(13,066)		(2,804)		299		53,632		29,551		558,511		641,694		641,993		84,011		(264,612)		(180,601)		461,392		1,804,092
Vanguard Mid-Cap Index	$	1,147,514	$	14,666	$	(9,685)	$	(2,717)	$	2,264	$	(31,906)	$	54,909	$	122,610	$	145,613	$	147,877	$	92,799	$	(216,398)	$	(123,599)	$	24,278	$	1,171,792

SEE NOTES TO FINANCIAL STATEMENTS

22

Symetra Separate Account C

Statements of Operations and Changes in Net Assets (continued)

Year Ended December 31, 2020

Sub-Account	Net Assets as of January 1, 2020	Dividends	Mortality and Expense Risk Charge	Asset-Related Administration Charge	Net Investment Income (Loss)	Realized Gain (Loss) on Investments	Net Realized Capital Gain Distributions Received	Net Change in Unrealized Appreciation/Depreciation	Net Gain (Loss) on Investments	Net Increase (Decrease) in Net Assets Resulting from Operations	Contract Purchase Payments and Transfers In	Contract Terminations, Transfers and Maintenance Charges	Increase (Decrease) in Net Assets from Contract Transactions	Total Increase (Decrease) In Net Assets	Net Assets  as of December 31,  2020
Vanguard Real Estate Index	295,127	6,570	(2,551)	(660)	3,359	(16,271)	4,131	(13,252)	(25,392)	(22,033)	47,712	(58,065)	(10,353)	(32,386)	262,741
Vanguard Total Bond Market Index	945,278	21,879	(8,841)	(2,192)	10,846	11,434	—	32,551	43,985	54,831	102,294	(187,748)	(85,454)	(30,623)	914,655
Vanguard Total Stock Market Index	3,140,220	44,069	(27,223)	(5,524)	11,322	81,414	85,020	329,211	495,645	506,967	240,283	(601,888)	(361,605)	145,362	3,285,582
Voya Global High Dividend Low Volatility Portfolio - Class S1	535,053	9,957	(5,524)	(669)	3,764	(5,545)	—	(17,471)	(23,016)	(19,252)	248	(68,244)	(67,996)	(87,248)	447,805
VY JPMorgan Emerging Markets Equity Portfolio Initial	572,062	3,326	(6,903)	(828)	(4,405)	1,948	36,241	131,478	169,667	165,262	3,152	(50,467)	(47,315)	117,947	690,009
Wanger USA	111,253	—	(1,263)	(152)	(1,415)	(14,575)	11,386	25,146	21,957	20,542	154	(65,500)	(65,346)	(44,804)	66,449

1Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

SEE NOTES TO FINANCIAL STATEMENTS

23

Symetra Separate Account C

Notes to Financial Statements

1.   ORGANIZATION

Symetra Separate Account C (the "Separate Account") is registered under the Investment Company Act of 1940, as amended, as a segregated unit investment trust of Symetra Life Insurance Company ("Symetra Life"), a wholly-owned subsidiary of Symetra Financial Corporation. Purchasers of various Symetra Life variable annuity products direct their investment to one or more of the sub-accounts of the Separate Account through the purchase of accumulation units ("Units"). Under the terms of the registration, the Separate Account is authorized to issue an unlimited number of Units. Each sub-account invests in shares of a designated portfolio of open-ended registered investment companies ("Mutual Funds") as indicated below. Not all sub-accounts are available in all Symetra Life variable annuity products. The performance of the underlying portfolios may differ substantially from publicly traded Mutual Funds with similar names and objectives.

Under applicable insurance law, the assets of the Separate Account are legally segregated and are not subject to claims that arise out of Symetra Life's or Symetra Financial Corporation's other business activities.

The Statements of Operations and Changes in Net Assets are reported for the years ended December 31, 2019 and December 31, 2020 for the following sub-accounts, except as noted in the footnote 7 to the table below.

Following are the sub-accounts and related Mutual Funds.

Sub-Account	Mutual Fund
	American Century Variable Portfolios, Inc.
American Century Balanced		VP Balanced Fund
American Century Inflation Protection II		VP Inflation Protection Class II Fund
American Century International		VP International Fund
American Century International II7		VP International Class II Fund
American Century Large Company Value II		VP Large Company Value Class II Fund
American Century Ultra I		VP Ultra Class I Fund
American Century Ultra II		VP Ultra Class II Fund
American Century Value		VP Value Fund
	BNY Mellon Variable Investment Fund
BNY Mellon Appreciation		BNY Mellon VIF Appreciation Portfolio — Initial Shares
BNY Mellon Quality Bond3		BNY Mellon VIF Quality Bond Portfolio — Initial Shares
	BNY Mellon Investment Portfolios
BNY Mellon MidCap Stock		BNY Mellon IP MidCap Stock Portfolio — Initial Shares
BNY Mellon Technology Growth		BNY Mellon IP Technology Growth Portfolio — Initial Shares
	BNY Mellon Stock Index Fund, Inc.
BNY Mellon Stock Index		BNY Mellon Stock Index Fund, Inc. — Service Shares
	BNY Mellon Sustainable U.S. Equity Portfolio, Inc.
BNY Mellon Sustainable U.S. Equity		BNY Mellon Sustainable U.S. Equity Portfolio Inc. — Initial Shares
	Calvert Variable Series, Inc.
Calvert EAFE International Index F Class		Calvert VP EAFE International Index Portfolio — Class F
Calvert Investment Grade Bond Index		Calvert VP Investment Grade Bond Index Portfolio
Calvert Nasdaq 100 Index		Calvert VP Nasdaq — 100 Index Portfolio
Calvert Russell 2000 Small Cap Index F Class		Calvert VP Russell 2000 Small Cap Index Portfolio — Class F
Calvert S&P MidCap 400 Index F Class		Calvert VP S&P MidCap 400 Index Portfolio — Class F
Calvert SRI Balanced		Calvert VP SRI Balanced Portfolio
	Columbia Funds Variable Insurance Trust
Columbia VP Select Mid Cap Value Fund - Class 1		Columbia VP Select Mid Cap Value Fund — Class 1

24

Symetra Separate Account C

Notes to Financial Statements

1.ORGANIZATION (continued)

Sub-Account	Mutual Fund
	DWS Variable Series I and II
DWS Capital Growth VIP B		DWS Capital Growth VIP — Class B Shares
DWS CROCI International VIP - Class A		DWS CROCI International VIP — Class A Shares
DWS Global Income Builder VIP A		DWS Global Income Builder VIP — Class A Shares
DWS Global Small Cap VIP B		DWS Global Small Cap VIP — Class B Shares
DWS International Growth VIP B Share		DWS International Growth VIP — Class B Shares
DWS Small Cap Index A Share		DWS Small Cap Index VIP — Class A Shares
DWS Small Mid Cap Value VIP Class B7		DWS Small Mid Cap Value VIP — Class B Shares
	Federated Insurance Series
Federated Hermes High Income Bond1		Federated Hermes High Income Bond Fund II
Federated Hermes Managed Volatility II2		Federated Hermes Managed Volatility Fund II
	Fidelity Variable Insurance Products Fund 1 (VIP)
Fidelity Asset Manager		VIP Asset Manager Portfolio — Initial Class
Fidelity Contrafund		VIP Contrafund® Portfolio — Initial Class
Fidelity Contrafund II		VIP Contrafund® Portfolio — Service Class 2
Fidelity Equity-Income		VIP Equity-Income Portfolio — Initial Class
Fidelity Freedom Funds 2010 II		VIP Freedom Funds 2010 Portfolio — Service Class 2
Fidelity Freedom Funds 2015 II		VIP Freedom Funds 2015 Portfolio — Service Class 2
Fidelity Freedom Funds 2020 II		VIP Freedom Funds 2020 Portfolio — Service Class 2
Fidelity Freedom Funds 2025 II		VIP Freedom Funds 2025 Portfolio — Service Class 2
Fidelity Freedom Funds 2030 II		VIP Freedom Funds 2030 Portfolio — Service Class 2
Fidelity Freedom Funds 2050 II		VIP Freedom Funds 2050 Portfolio — Service Class 2
Fidelity Freedom Income Fund II		VIP Freedom Income Portfolio — Service Class 2
Fidelity Government Money Market Portfolio - Initial Class		VIP Government Money Market Portfolio — Initial Class
Fidelity Government Money Market Portfolio - Service Class II		VIP Government Money Market Portfolio — Service Class II
Fidelity Growth		VIP Growth Portfolio — Initial Class
Fidelity Growth & Income		VIP Growth & Income Portfolio — Initial Class
Fidelity Growth Opportunities		VIP Growth Opportunities Portfolio — Initial Class
Fidelity Index 500		VIP Index 500 Portfolio — Initial Class
Fidelity Mid Cap II		VIP Mid Cap Portfolio — Service Class II
Fidelity Overseas II		VIP Overseas Portfolio — Service Class 2
	Franklin Templeton Variable Insurance Products Trust
Franklin Allocation VIP Fund - Class 2		Franklin Allocation VIP Fund - Class 2
Franklin Flex Cap Growth VIP Fund - Class 2		Franklin Flex Cap Growth VIP Fund - Class 2
Franklin Income VIP Fund - Class 2		Franklin Income VIP Fund - Class 2
Franklin Mutual Shares VIP Fund - Class 2		Franklin Mutual shares VIP Fund - Class 2
Franklin Small Cap Value VIP Fund - Class 2		Franklin Small Cap Value VIP Fund - Class 2
Franklin Small-Mid Cap Growth VIP Fund - Class 2		Franklin Small-Mid Cap Growth VIP Fund - Class 2
Franklin U.S. Government Securities VIP Fund - Class 2		Franklin U.S. Government Securities VIP Fund - Class 2

25

Symetra Separate Account C

Notes to Financial Statements

1.ORGANIZATION (continued)

Sub-Account	Mutual Fund
	AIM Variable Insurance Funds, Inc (Invesco Variable Insurance Funds)
Invesco American Franchise Fund I		Invesco V.I. American Franchise Fund - Series I
Invesco American Franchise Fund II		Invesco V.I. American Franchise Fund - Series II
Invesco Global Real Estate		Invesco V.I. Global Real Estate Fund - Series I
Invesco Health Care		Invesco V.I. Health Care Fund - Series I
Invesco International Growth I		Invesco V.I. International Growth Fund - Series I
Invesco International Growth II		Invesco V.I. International Growth Fund - Series II
Invesco Mid Cap Growth Fund I4		Invesco V.I. Mid Cap Growth Fund - Series I
Invesco Mid Cap Growth Fund II5		Invesco V.I. Mid Cap Growth Fund - Series II
Invesco Oppenheimer Discovery Mid Cap Growth Fund I4		Invesco V.I. Oppenheimer Discovery Mid Cap Growth Fund - Series I
Invesco Oppenheimer Discovery Mid Cap Growth Fund II5		Invesco V.I. Oppenheimer Discovery Mid Cap Growth Fund - Series II
Invesco Small Cap Equity II		Invesco V.I. Small Cap Equity Fund - Series II
	JP Morgan Insurance Trust
JP Morgan Insurance Trust Mid Cap Value I		JP Morgan Insurance Trust Mid Cap Value Portfolio
JP Morgan Insurance Trust U.S. Equity I		JP Morgan Insurance Trust U.S. Equity Portfolio
	ALPS Variable Investment Trust
Morningstar Aggressive Growth ETF Asset Allocation Class I		Morningstar Aggressive Growth ETF Asset Allocation Portfolio — Class I
Morningstar Aggressive Growth ETF Asset Allocation Class II		Morningstar Aggressive Growth ETF Asset Allocation Portfolio — Class II
Morningstar Balanced ETF Asset Allocation Class I		Morningstar Balanced ETF Asset Allocation Portfolio — Class I
Morningstar Balanced ETF Asset Allocation Class II		Morningstar Balanced ETF Asset Allocation Portfolio — Class II
Morningstar Conservative ETF Asset Allocation Class I		Morningstar Conservative ETF Asset Allocation Portfolio — Class I
Morningstar Conservative ETF Asset Allocation Class II		Morningstar Conservative ETF Asset Allocation Portfolio — Class II
Morningstar Growth ETF Asset Allocation Class I		Morningstar Growth ETF Asset Allocation Portfolio — Class I
Morningstar Growth ETF Asset Allocation Class II		Morningstar Growth ETF Asset Allocation Portfolio — Class II
Morningstar Income & Growth ETF Asset Allocation Class I		Morningstar Income & Growth ETF Asset Allocation Portfolio — Class I
Morningstar Income & Growth ETF Asset Allocation Class II		Morningstar Income & Growth ETF Asset Allocation Portfolio — Class II
	Neuberger Berman Advisers Management Trust
Neuberger Berman AMT Mid Cap Growth Class S		Neuberger Berman AMT Mid Cap Growth Portfolio — Class S
Neuberger Berman AMT Mid Cap Intrinsic Value Class S		Neuberger Berman AMT Mid Cap Intrinsic Value Portfolio — Class S
Neuberger Berman AMT Sustainable Equity Class S		Neuberger Berman AMT Sustainable Equity Portfolio — Class S
	PIMCO Variable Insurance Trust
PIMCO All Asset Portfolio Advisor		PIMCO All Asset Portfolio — Advisor Class Shares
PIMCO CommodityRealReturn Strat.		PIMCO CommodityRealReturn® Strategy Portfolio —
Administrative Class		Administrative Class Shares
PIMCO Total Return Portfolio Advisor		PIMCO Total Return Portfolio — Advisor Class Shares

26

Symetra Separate Account C

Notes to Financial Statements

1.ORGANIZATION (continued)

Sub-Account	Mutual Fund
	Pioneer Variable Contracts Trust
Pioneer Bond VCT Class I		Pioneer Bond VCT Portfolio — Class I
Pioneer Equity Income VCT Class II		Pioneer Equity Income VCT Portfolio — Class II
Pioneer Fund VCT Class I		Pioneer Fund VCT Portfolio — Class I
Pioneer High Yield VCT Class II		Pioneer High Yield VCT Portfolio — Class II
Pioneer Mid Cap Value VCT Class I		Pioneer Mid Cap Value VCT Portfolio — Class I
Pioneer Real Estate VCT Class II		Pioneer Real Estate VCT Portfolio — Class II
Pioneer Select Mid Cap Growth VCT Class I		Pioneer Select Mid Cap Growth VCT Portfolio — Class I
Pioneer Strategic Income VCT Class II		Pioneer Strategic Income VCT Portfolio — Class II
	Franklin Templeton Variable Insurance Products Trust
Templeton Developing Markets VIP Fund - Class 2		Templeton Developing Markets VIP Fund - Class 2
Templeton Global Bond VIP Fund - Class 2		Templeton Global Bond VIP Fund - Class 2
Templeton Growth VIP Fund - Class 2		Templeton Growth VIP Fund - Class 2
	Vanguard Variable Insurance Fund Portfolios
Vanguard Balanced		Vanguard VIF — Balanced Portfolio
Vanguard High Yield Bond		Vanguard VIF — High Yield Bond Portfolio
Vanguard International		Vanguard VIF — International Portfolio
Vanguard Mid-Cap Index		Vanguard VIF — Mid-Cap Index Portfolio
Vanguard Real Estate Index		Vanguard VIF — Real Estate Index Portfolio
Vanguard Total Bond Market Index		Vanguard VIF — Total Bond Market Index Portfolio
Vanguard Total Stock Market Index		Vanguard VIF — Total Stock Market Index Portfolio
	Voya VP Natural Resource Trust
Voya Global High Dividend Low Volatility Portfolio - Class S6		Voya Global High Dividend Low Volatility Portfolio - Class S
	Voya Investors Trust
VY JPMorgan Emerging Markets Equity Portfolio Initial		VY JPMorgan Emerging Markets Equity Portfolio Class I
	Wanger Advisors Trust
Wanger USA		Wanger USA
Retail Mutual Funds available to the public outside of variable annuity contracts:
	Neuberger Berman Advisers Management Trust
Neuberger Berman Genesis Advisor7		Neuberger Berman Genesis Fund — Advisor Class

1 Federated Hermes High Income Bond was known as Federated High Income Bond prior to April 28, 2020.

2 Federated Hermes Managed Volatility II was known as Federated Managed Volatility II prior to April 28, 2020.

3 Effective April 30, 2020 BNY Mellon Quality Bond was liquidated and no longer available for sale.

4 Invesco Mid Cap Growth Fund I was reorganized with Invesco Oppenheimer Discovery Mid Cap Growth Fund I on April 30, 2020.

5 Invesco Mid Cap Growth Fund II was reorganized with Invesco Oppenheimer Discovery Mid Cap Growth Fund II on April 30, 2020.

6 Voya Global High Dividend Low Volatility Portfolio – Class S was known as Voya Global Equity Portfolio – Class S prior to April 30, 2020.

7 There was no activity in the current year and the prior year and no net asset balance to report on the Statements of Assets and Liabilities as of December 31,

2020.

27

Symetra Separate Account C

Notes to Financial Statements

2.SIGNIFICANT ACCOUNTING POLICIES

BASIS OF PRESENTATION AND USE OF ESTIMATES — The financial statements have been prepared in conformity with U.S. generally accepted accounting principles (GAAP), including the rules and regulations of the Securities and Exchange Commission (SEC).

INVESTMENT VALUATION — Investments in portfolio shares are valued at fair value based on the net asset value (NAV) as reported by the underlying Mutual Fund on the last trading day of the year.

The Separate Account determines the fair value of its financial instruments based on the fair value hierarchy, which requires an entity to maximize its use of observable inputs and minimize the use of unobservable inputs when measuring fair value. This fair value hierarchy prioritizes fair value measurements into the three levels based on the nature of the inputs. Quoted prices in active markets for identical assets or liabilities have the highest priority ("Level 1"), followed by significant observable inputs other than quoted market prices, including prices for similar but not identical assets or liabilities ("Level 2") and significant unobservable inputs, including the reporting entity's estimates of the assumptions that market participants would use, having the lowest priority ("Level 3").

The availability of observable market information is the principal factor in determining the level to which the Separate Account's investments are assigned in the fair value hierarchy. As such, all Separate Account investments have been classified as Level 1 in the fair value hierarchy.

INVESTMENT TRANSACTIONS — Investment transactions are recorded on the trade date. Realized gains and losses on investment transactions are determined using the first-in-first-out (FIFO) method.

INCOME RECOGNITION — Dividend income and realized capital gain distributions are recorded on the ex-dividend date.

DISTRIBUTIONS — The net investment income and realized capital gains of the Separate Account are not distributed, but are retained and reinvested for the benefit of unit owners.

FEDERAL INCOME TAX — Operations of the Separate Account are included in the federal income tax return of Symetra Life, which is taxed as a "Life Insurance Company" under the provisions of the Internal Revenue Code. Under current federal income tax law, no income taxes are payable with respect to the operations of the Separate Account to the extent the earnings are reinvested.

3.     EXPENSES AND RELATED PARTY TRANSACTIONS

Symetra Life assumes mortality and expense ("M&E") risks and incurs asset-related administrative expenses related to the operations of the Separate Account. Optional benefit charges may be elected for a guaranteed minimum death benefit ("GMDB") and an earnings enhancement benefit ("EEB") for certain products. Symetra Life deducts a daily charge from the assets of the Separate Account to cover these expenses. These charges are included in net investment income (loss) in the accompanying Statements of Operations and Changes in Net Assets. Symetra Life also deducts annual contract maintenance charges which are reflected as a contract maintenance charge in the accompanying Statements of Operations and Changes in Net Assets. The table below describes the maximum charges for the fees and expenses charged by product.

Annual Periodic Charges	Mortality and expense risk1	Asset-related administrative1	Optional (GMDB)1	Optional (EEB)1	Contract Maintenance
Spinnaker & Mainsail	1.25%	0.15%	0.20%	0.15%	$30
Spinnaker Advisor	1.25%	0.20%	Not Available	Not Available	$30
Spinnaker Choice	1.40%	0.15%	0.20%	0.15%	No Charge
Focus	0.95%	0.40%	0.10%	Not Available	$40
Retirement Passport	1.25%	No Charge	Not Available	Not Available	$30
Retirement Passport — Calvert sub accounts	1.25%	0.10%	Not Available	Not Available	$30
Retirement Passport — Vanguard sub accounts	1.25%	0.25%	Not Available	Not Available	$30

1 As a percentage of average daily net assets of each sub-account deducted daily.

A withdrawal charge of $25 or 2.00 percent of the withdrawal amount, whichever is less, may be imposed on the owner of the policy for the second and each subsequent withdrawal in any one year. A transfer charge of $10 or 2.00 percent of the amount transferred, whichever is less, may be imposed on transfers that exceed the number of free transfers allowed each year. These charges are reflected as contract maintenance charges in the accompanying Statements of Operations and Changes in Net Assets. A surrender charge may be applicable in the first eight years on withdrawals that

28

Symetra Separate Account C

Notes to Financial Statements

3.     EXPENSES AND RELATED PARTY TRANSACTIONS (continued)

exceed the free withdrawal amount. The surrender charge is reflected as transfers out in the accompanying Statements of Operations and Changes in Net Assets. These charges do not apply to all products and may vary by contract year and other factors as described in the product prospectuses.

The Retirement Passport product may allow the owner of the policy to take a loan against their account value. A loan application charge of $50 or 2.50 percent of the loan amount, whichever is less, will be deducted from the sub-account with the highest balance at the time the loan is approved. An annual loan maintenance charge of $35 or 2.50 percent of the loan amount, whichever is less, will be deducted from the sub-account with the highest balance. These charges are reflected as transfers out in the accompanying Statements of Operations and Changes in Net Assets.

4.INVESTMENT TRANSACTIONS

The following table summarizes investment purchases and proceeds from sales activity by sub-account for the year ended December 31, 2020.

Sub-Account	Purchases		Proceeds From Sales
American Century Balanced	$	566,949	$	974,819
American Century Inflation Protection II	209,164		640,223
American Century International	322,571		1,286,005
American Century Large Company Value II	95,179		95,440
American Century Ultra I	37,233		71,023
American Century Ultra II	102,106		332,429
American Century Value	203,787		270,275
BNY Mellon Appreciation	324,510		306,116
BNY Mellon MidCap Stock	166,408		1,020,016
BNY Mellon Quality Bond1	29,778		1,621,939
BNY Mellon Stock Index	946,551		2,069,187
BNY Mellon Sustainable U.S. Equity	171,471		552,076
BNY Mellon Technology Growth	577,944		1,093,009
Calvert EAFE International Index F Class	21,801		19,380
Calvert Investment Grade Bond Index	655,334		671,499
Calvert Nasdaq 100 Index	335,961		1,189,198
Calvert Russell 2000 Small Cap Index F Class	99,284		197,314
Calvert S&P MidCap 400 Index F Class	63,586		49,789
Calvert SRI Balanced	42,398		15,993
Columbia VP Select Mid Cap Value Fund - Class 1	—		60
DWS Capital Growth VIP B	118,709		336,061
DWS CROCI International VIP - Class A	52,374		139,577
DWS Global Income Builder VIP A	367,346		785,169
DWS Global Small Cap VIP B	7,053		12,397
DWS International Growth VIP B Share	2,369		1,733
DWS Small Cap Index A Share	62,067		67,625
Federated Hermes High Income Bond1	103,929		164,167
Federated Hermes Managed Volatility II1	15,643		57,374
Fidelity Asset Manager	3,283		19,235
Fidelity Contrafund	350,491		4,141,352
Fidelity Contrafund II	39		82
Fidelity Equity-Income	335,389		816,595
Fidelity Freedom Funds 2010 II	317,080		5,219

29

Symetra Separate Account C

Notes to Financial Statements

4. INVESTMENT TRANSACTIONS (continued)

Sub-Account	Purchases		Proceeds From Sales
Fidelity Freedom Funds 2015 II	$	8,202	$	8,553
Fidelity Freedom Funds 2020 II	60,519		114,627
Fidelity Freedom Funds 2025 II	86,596		94,484
Fidelity Freedom Funds 2030 II	156,179		95,879
Fidelity Freedom Funds 2050 II	1,114		272
Fidelity Freedom Income Fund II	27,033		2,754
Fidelity Government Money Market Portfolio - Initial Class	2,759		3,579
Fidelity Government Money Market Portfolio - Service Class II	3,419,804		2,841,729
Fidelity Growth	1,468,984		1,753,290
Fidelity Growth & Income	390,967		845,443
Fidelity Growth Opportunities	292,179		457,293
Fidelity Index 500	98,139		98,226
Fidelity Mid Cap II	119,743		765,513
Fidelity Overseas II	8,015		15,713
Franklin Allocation VIP Fund - Class 2	138,007		70,950
Franklin Flex Cap Growth VIP Fund - Class 2	169,168		93,934
Franklin Income VIP Fund - Class 2	283,340		619,529
Franklin Mutual Shares VIP Fund - Class 2	297,054		527,211
Franklin Small Cap Value VIP Fund - Class 2	499,823		840,242
Franklin Small-Mid Cap Growth VIP Fund - Class 2	538,901		725,018
Franklin U.S. Government Securities VIP Fund - Class 2	1,257,610		1,197,846
Invesco American Franchise Fund I	419,187		478,553
Invesco American Franchise Fund II	71,066		264,752
Invesco Global Real Estate	228,635		520,841
Invesco Health Care	11,534		22,676
Invesco International Growth I	48,816		88,142
Invesco International Growth II	415,407		1,264,206
Invesco Mid Cap Growth Fund I1	39,160		158,054
Invesco Mid Cap Growth Fund II1	80,990		318,590
Invesco Oppenheimer Discovery Mid Cap Growth Fund I1	148,816		21,340
Invesco Oppenheimer Discovery Mid Cap Growth Fund II1	343,983		96,437
Invesco Small Cap Equity II	87,025		80,282
JP Morgan Insurance Trust Mid Cap Value I	526,516		604,420
JP Morgan Insurance Trust U.S. Equity I	176,106		382,545
Morningstar Aggressive Growth ETF Asset Allocation Class I	4,872		14,106
Morningstar Aggressive Growth ETF Asset Allocation Class II	76,373		198,502
Morningstar Balanced ETF Asset Allocation Class I	25,228		27,141
Morningstar Balanced ETF Asset Allocation Class II	240,596		864,291
Morningstar Conservative ETF Asset Allocation Class I	13,218		8,608
Morningstar Conservative ETF Asset Allocation Class II	42,347		76,628
Morningstar Growth ETF Asset Allocation Class I	5,006		4,001
Morningstar Growth ETF Asset Allocation Class II	188,921		610,403
Morningstar Income & Growth ETF Asset Allocation Class I	101,414		111,172
Morningstar Income & Growth ETF Asset Allocation Class II	80,471		187,034
Neuberger Berman AMT Mid Cap Growth Class S	33,020		329,588
Neuberger Berman AMT Mid Cap Intrinsic Value Class S	2,276		10,360

30

Symetra Separate Account C

Notes to Financial Statements

4. INVESTMENT TRANSACTIONS (continued)

Sub-Account	Purchases		Proceeds From Sales
Neuberger Berman AMT Sustainable Equity Class S	$	9,945	$	4,216
PIMCO All Asset Portfolio Advisor	26,817		19,935
PIMCO CommodityRealReturn Strat. Administrative Class	148,206		227,459
PIMCO Total Return Portfolio Advisor	410,389		348,097
Pioneer Bond VCT Class I	88,332		295,303
Pioneer Equity Income VCT Class II	549,925		1,132,522
Pioneer Fund VCT Class I	3,280,057		3,168,548
Pioneer High Yield VCT Class II	130,157		289,470
Pioneer Mid Cap Value VCT Class I	224,982		467,141
Pioneer Real Estate VCT Class II	598,540		477,773
Pioneer Select Mid Cap Growth VCT Class I	2,774,054		4,257,319
Pioneer Strategic Income VCT Class II	278,815		1,010,529
Templeton Developing Markets VIP Fund - Class 2	127,158		221,744
Templeton Global Bond VIP Fund - Class 2	426,249		623,366
Templeton Growth VIP Fund - Class 2	147,532		438,291
Vanguard Balanced	15,131		36,263
Vanguard High Yield Bond	576,400		1,118,164
Vanguard International	129,708		280,457
Vanguard Mid-Cap Index	162,188		228,615
Vanguard Real Estate Index	58,367		61,228
Vanguard Total Bond Market Index	123,905		198,515
Vanguard Total Stock Market Index	369,121		634,379
Voya Global High Dividend Low Volatility Portfolio - Class S1	10,118		74,349
VY JPMorgan Emerging Markets Equity Portfolio Initial	41,676		57,154
Wanger USA	11,535		66,910

1 Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

5.CHANGES IN ACCUMULATION UNITS OUTSTANDING

The changes in Units outstanding for the years ended December 31, 2020, and 2019 were as follows:

	2020			2019
Sub-Account	Units Issued	Units Redeemed	Increase (Decrease) in Units	Units Issued	Units Redeemed	Increase (Decrease) in Units
American Century Balanced	13,815	(41,810)	(27,995)	17,765	(72,788)	(55,023)
American Century Inflation Protection II	16,120	(47,981)	(31,861)	10,614	(69,877)	(59,263)
American Century International	18,487	(83,160)	(64,673)	18,537	(62,210)	(43,673)
American Century Large Company Value II	5,774	(5,354)	420	794	(872)	(78)
American Century Ultra I	67	(1,388)	(1,321)	263	(1,076)	(813)
American Century Ultra II	1,197	(9,830)	(8,633)	3,258	(6,724)	(3,466)
American Century Value	5,255	(10,151)	(4,896)	3,596	(24,091)	(20,495)
BNY Mellon Appreciation	1,802	(10,686)	(8,884)	1,925	(13,523)	(11,598)
BNY Mellon MidCap Stock	8,238	(40,508)	(32,270)	5,889	(45,231)	(39,342)
BNY Mellon Quality Bond1	1,436	(90,499)	(89,063)	2,397	(14,689)	(12,292)
BNY Mellon Stock Index	11,977	(57,184)	(45,207)	13,012	(60,403)	(47,391)
BNY Mellon Sustainable U.S. Equity	7,687	(34,379)	(26,692)	2,884	(29,702)	(26,818)
BNY Mellon Technology Growth	10,745	(59,846)	(49,101)	4,694	(35,775)	(31,081)

31

Symetra Separate Account C

Notes to Financial Statements

5. CHANGES IN ACCUMULATION UNITS OUTSTANDING (continued)

	2020			2019
Sub-Account	Units Issued	Units Redeemed	Increase (Decrease) in Units	Units Issued	Units Redeemed	Increase (Decrease) in Units
Calvert EAFE International Index F Class	1,619	(1,879)	(260)	1,993	(1,349)	644
Calvert Investment Grade Bond Index	46,918	(50,922)	(4,004)	18,842	(66,612)	(47,770)
Calvert Nasdaq 100 Index	5,076	(23,668)	(18,592)	5,793	(18,329)	(12,536)
Calvert Russell 2000 Small Cap Index F Class	3,293	(9,433)	(6,140)	2,788	(10,442)	(7,654)
Calvert S&P MidCap 400 Index F Class	2,436	(2,770)	(334)	2,664	(12,117)	(9,453)
Calvert SRI Balanced	1,195	(650)	545	8,228	(1,877)	6,351
DWS Capital Growth VIP B	1,086	(10,582)	(9,496)	3,493	(20,467)	(16,974)
DWS CROCI International VIP - Class A	563	(7,401)	(6,838)	1,520	(8,384)	(6,864)
DWS Global Income Builder VIP A	1,713	(20,979)	(19,266)	1,942	(21,637)	(19,695)
DWS Global Small Cap VIP B	622	(899)	(277)	651	(2,146)	(1,495)
DWS International Growth VIP B Share	155	(72)	83	121	(435)	(314)
DWS Small Cap Index A Share	2,001	(3,551)	(1,550)	1,547	(10,721)	(9,174)
Federated Hermes High Income Bond1	845	(4,913)	(4,068)	791	(4,520)	(3,729)
Federated Hermes Managed Volatility II1	130	(1,921)	(1,791)	63	(1,465)	(1,402)
Fidelity Asset Manager	16	(758)	(742)	16	(1,045)	(1,029)
Fidelity Contrafund	8,946	(82,874)	(73,928)	17,211	(137,137)	(119,926)
Fidelity Equity-Income	5,386	(29,129)	(23,743)	3,642	(19,543)	(15,901)
Fidelity Freedom Funds 2010 II	19,378	(226)	19,152	147	(45)	102
Fidelity Freedom Funds 2015 II	—	(412)	(412)	—	(674)	(674)
Fidelity Freedom Funds 2020 II	1,222	(6,360)	(5,138)	7,419	(17,279)	(9,860)
Fidelity Freedom Funds 2025 II	2,295	(4,756)	(2,461)	5,139	(4,458)	681
Fidelity Freedom Funds 2030 II	13,793	(14,528)	(735)	11,301	(14,065)	(2,764)
Fidelity Freedom Funds 2050 II	—	—	—	8	—	8
Fidelity Freedom Income Fund II	1,710	(63)	1,647	260	(10)	250
Fidelity Government Money Market Portfolio - Initial Class	283	(345)	(62)	181	(14,265)	(14,084)
Fidelity Government Money Market Portfolio - Service Class II	414,788	(346,740)	68,048	115,239	(245,124)	(129,885)
Fidelity Growth	5,865	(65,481)	(59,616)	9,213	(80,226)	(71,013)
Fidelity Growth & Income	4,708	(35,891)	(31,183)	4,071	(30,400)	(26,329)
Fidelity Growth Opportunities	603	(9,906)	(9,303)	954	(20,418)	(19,464)
Fidelity Index 500	3,806	(4,194)	(388)	3,618	(4,111)	(493)
Fidelity Mid Cap II	5,085	(30,593)	(25,508)	3,081	(40,944)	(37,863)
Fidelity Overseas II	678	(1,092)	(414)	4,691	(9,395)	(4,704)
Franklin Allocation VIP Fund - Class 21	1,273	(4,411)	(3,138)	1,452	(4,273)	(2,821)
Franklin Flex Cap Growth VIP Fund - Class 2	3,969	(2,603)	1,366	895	(581)	314
Franklin Income VIP Fund - Class 2	7,442	(36,333)	(28,891)	12,321	(49,604)	(37,283)
Franklin Mutual Shares VIP Fund - Class 2	6,293	(28,871)	(22,578)	4,638	(27,442)	(22,804)
Franklin Small Cap Value VIP Fund - Class 2	12,404	(36,650)	(24,246)	8,003	(45,697)	(37,694)
Franklin Small-Mid Cap Growth VIP Fund - Class 2	3,452	(30,624)	(27,172)	6,753	(41,826)	(35,073)
Franklin U.S. Government Securities VIP Fund - Class 2	106,883	(99,792)	7,091	22,138	(116,384)	(94,246)
Invesco American Franchise Fund I	2,363	(18,056)	(15,693)	4,267	(26,569)	(22,302)
Invesco American Franchise Fund II	780	(9,171)	(8,391)	1,918	(6,823)	(4,905)
Invesco Global Real Estate	2,430	(15,536)	(13,106)	1,145	(12,594)	(11,449)
Invesco Health Care	117	(526)	(409)	98	(301)	(203)

32

Symetra Separate Account C

Notes to Financial Statements

5. CHANGES IN ACCUMULATION UNITS OUTSTANDING (continued)

	2020			2019
Sub-Account	Units Issued	Units Redeemed	Increase (Decrease) in Units	Units Issued	Units Redeemed	Increase (Decrease) in Units
Invesco International Growth I	924	(2,509)	(1,585)	475	(6,731)	(6,256)
Invesco International Growth II	18,967	(79,257)	(60,290)	16,513	(123,566)	(107,053)
Invesco Mid Cap Growth Fund I1	4	(4,114)	(4,110)	42	(18)	24
Invesco Mid Cap Growth Fund II1	538	(12,496)	(11,958)	1,026	(3,432)	(2,406)
Invesco Oppenheimer Discovery Mid Cap Growth Fund I1	3,882	(479)	3,403	—	—	—
Invesco Oppenheimer Discovery Mid Cap Growth Fund II1	13,833	(4,318)	9,515	—	—	—
Invesco Small Cap Equity II	3,524	(4,363)	(839)	1,254	(8,381)	(7,127)
JP Morgan Insurance Trust Mid Cap Value I	8,352	(16,459)	(8,107)	4,089	(22,474)	(18,385)
JP Morgan Insurance Trust U.S. Equity I	988	(16,991)	(16,003)	2,094	(18,771)	(16,677)
Morningstar Aggressive Growth ETF Asset Allocation Class I	—	(830)	(830)	3,370	(3,705)	(335)
Morningstar Aggressive Growth ETF Asset Allocation Class II	2,015	(12,399)	(10,384)	2,515	(15,217)	(12,702)
Morningstar Balanced ETF Asset Allocation Class I	150	(1,321)	(1,171)	64	(13,232)	(13,168)
Morningstar Balanced ETF Asset Allocation Class II	10,688	(58,437)	(47,749)	5,630	(97,868)	(92,238)
Morningstar Conservative ETF Asset Allocation Class I	57	(176)	(119)	9	(483)	(474)
Morningstar Conservative ETF Asset Allocation Class II	3,290	(6,083)	(2,793)	249	(6,829)	(6,580)
Morningstar Growth ETF Asset Allocation Class I	—	(180)	(180)	—	(33)	(33)
Morningstar Growth ETF Asset Allocation Class II	4,783	(38,639)	(33,856)	2,959	(52,135)	(49,176)
Morningstar Income & Growth ETF Asset Allocation Class I	7,044	(7,881)	(837)	—	(1,020)	(1,020)
Morningstar Income & Growth ETF Asset Allocation Class II	4,676	(13,201)	(8,525)	3,221	(14,080)	(10,859)
Neuberger Berman AMT Guardian Class S	—	—	—	41	(6,206)	(6,165)
Neuberger Berman AMT Mid Cap Growth Class S	603	(13,049)	(12,446)	1,372	(5,749)	(4,377)
Neuberger Berman AMT Mid Cap Intrinsic Value Class S	158	(729)	(571)	168	(1,024)	(856)
Neuberger Berman AMT Sustainable Equity Class S	241	(122)	119	6,539	(1,025)	5,514
PIMCO All Asset Portfolio Advisor	826	(1,110)	(284)	583	(15,158)	(14,575)
PIMCO CommodityRealReturn Strat. Administrative Class	20,863	(43,241)	(22,378)	18,873	(50,762)	(31,889)
PIMCO Total Return Portfolio Advisor	49,219	(45,448)	3,771	21,259	(419)	20,840
Pioneer Bond VCT Class I	841	(7,050)	(6,209)	4,692	(10,413)	(5,721)
Pioneer Equity Income VCT Class II	15,516	(48,534)	(33,018)	8,020	(71,187)	(63,167)
Pioneer Fund VCT Class I	1,250	(20,893)	(19,643)	2,153	(30,413)	(28,260)
Pioneer High Yield VCT Class II	4,185	(16,010)	(11,825)	1,915	(19,454)	(17,539)
Pioneer Mid Cap Value VCT Class I	1,339	(10,726)	(9,387)	2,047	(15,577)	(13,530)
Pioneer Real Estate VCT Class II	8,741	(28,731)	(19,990)	3,852	(39,574)	(35,722)
Pioneer Select Mid Cap Growth VCT Class I	1,575	(31,788)	(30,213)	2,259	(38,775)	(36,516)
Pioneer Strategic Income VCT Class II	13,828	(63,050)	(49,222)	13,494	(90,108)	(76,614)
Templeton Developing Markets VIP Fund - Class 2	1,502	(8,197)	(6,695)	1,753	(14,279)	(12,526)
Templeton Global Bond VIP Fund - Class 2	11,214	(37,475)	(26,261)	9,170	(53,441)	(44,271)
Templeton Growth VIP Fund - Class 2	7,019	(28,585)	(21,566)	10,303	(41,047)	(30,744)

33

Symetra Separate Account C

Notes to Financial Statements

5. CHANGES IN ACCUMULATION UNITS OUTSTANDING (continued)

	2020			2019
Sub-Account	Units Issued	Units Redeemed	Increase (Decrease) in Units	Units Issued	Units Redeemed	Increase (Decrease) in Units
Vanguard Balanced	—	(1,764)	(1,764)	45	(16,456)	(16,411)
Vanguard High Yield Bond	33,481	(69,326)	(35,845)	57,920	(44,509)	13,411
Vanguard International	6,381	(17,660)	(11,279)	8,653	(61,009)	(52,356)
Vanguard Mid-Cap Index	5,939	(12,426)	(6,487)	10,369	(36,494)	(26,125)
Vanguard Real Estate Index	3,865	(4,775)	(910)	2,900	(11,382)	(8,482)
Vanguard Total Bond Market Index	6,919	(12,755)	(5,836)	7,147	(64,929)	(57,782)
Vanguard Total Stock Market Index	12,281	(28,680)	(16,399)	12,826	(140,602)	(127,776)
Voya Global High Dividend Low Volatility Portfolio - Class S1	8	(1,974)	(1,966)	38	(1,027)	(989)
VY JPMorgan Emerging Markets Equity Portfolio Initial	98	(1,575)	(1,477)	108	(752)	(644)
Wanger USA	1	(489)	(488)	1	(17)	(16)

1  Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

34

Symetra Separate Account C

Notes to Financial Statements

6.ACCUMULATION UNIT VALUES

The following table summarizes the Unit values and Units outstanding for sub-accounts by net investment income ratios, and expense ratios, excluding expenses of the underlying Mutual Funds, and total returns for each of the five years in the period ended December 31, 2020.

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
American Century Balanced
	2020	$	26.878	to	$	25.997	300,616	$	7,874,353	1.16	%	1.40%	to	1.60%	10.96%	to	10.74%
	2019	24.223		to	23.475		328,611	7,755,438		1.53		1.40	to	1.60	18.19	to	17.95
	2018	20.495		to	19.903		383,635	7,695,737		1.39		1.40	to	1.60	(5.18)	to	(5.36)
	2017	21.614		to	21.031		431,794	9,146,859		1.52		1.40	to	1.60	12.33	to	12.11
	2016	19.241		to	18.760		511,002	9,593,595		1.58		1.40	to	1.60	5.51	to	5.30
American Century Inflation Protection II
	2020	14.193		to	13.863		189,130	2,681,490		1.31		1.40	to	1.55	8.03	to	7.87
	2019	13.138		to	12.852		220,991	2,900,440		2.27		1.40	to	1.55	7.39	to	7.23
	2018	12.234		to	11.986		280,254	3,425,094		2.81		1.40	to	1.55	(4.17)	to	(4.32)
	2017	12.767		to	12.527		309,458	3,947,335		2.49		1.40	to	1.55	2.23	to	2.08
	2016	12.488		to	12.272		395,021	4,928,768		1.85		1.40	to	1.55	2.93	to	2.79
American Century International
	2020	19.683		to	19.037		353,297	6,830,302		0.49		1.40	to	1.60	24.13	to	23.88
	2019	15.857		to	15.367		417,971	6,482,799		0.88		1.40	to	1.60	26.63	to	26.38
	2018	12.522		to	12.159		461,644	5,659,417		1.29		1.40	to	1.60	(16.40)	to	(16.58)
	2017	14.979		to	14.575		527,241	7,733,620		0.91		1.40	to	1.60	29.39	to	29.13
	2016	11.577		to	11.287		694,865	7,904,643		1.10		1.40	to	1.60	(6.81)	to	(7.00)
American Century Large Company Value II
	2020	22.048		to	21.367		16,267	358,381		1.57		1.40	to	1.60	1.06	to	0.86
	2019	21.816		to	21.185		15,848	345,430		1.90		1.40	to	1.60	25.54	to	25.29
	2018	17.378		to	16.909		15,926	276,520		1.55		1.40	to	1.60	(9.47)	to	(9.65)
	2017	19.196		to	18.715		20,955	401,884		1.58		1.40	to	1.60	9.42	to	9.20
	2016	17.543		to	17.139		27,617	483,634		1.96		1.40	to	1.60	13.43	to	13.20
American Century Ultra I
	2020	58.351		to	45.423		7,936	461,163		—		1.40	to	1.75	47.77	to	47.26
	2019	39.487		to	30.846		9,257	364,294		—		1.40	to	1.75	32.71	to	32.24
	2018	29.755		to	23.325		10,070	298,726		0.26		1.40	to	1.75	(0.65)	to	(1.00)
	2017	29.950		to	23.560		11,187	333,930		0.39		1.40	to	1.75	30.39	to	29.94
	2016	22.969		to	18.132		14,677	336,149		0.35		1.40	to	1.75	3.00	to	2.64
American Century Ultra II
	2020	46.844		to	46.522		13,056	611,387		—		1.40	to	1.45	47.47	to	47.40
	2019	31.765		to	31.562		21,688	688,887		—		1.40	to	1.45	32.59	to	32.52
	2018	23.957		to	23.816		25,154	602,574		0.11		1.40	to	1.45	(0.81)	to	(0.86)
	2017	24.152		to	24.022		28,065	677,781		0.24		1.40	to	1.45	30.17	to	30.11
	2016	18.554		to	18.463		28,225	523,692		0.19		1.40	to	1.45	2.91	to	2.85

35

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
American Century Value
	2020	$	29.681	to	$	25.373	88,554	$	2,625,186	2.32	%	1.40%	to	1.55%	(0.43)%	to	(0.58)%
	2019	29.808		to	25.520		93,450	2,782,716		2.10		1.40	to	1.55	25.27	to	25.09
	2018	23.795		to	20.402		113,945	2,708,809		1.63		1.40	to	1.55	(10.42)	to	(10.56)
	2017	26.564		to	22.810		133,184	3,534,326		1.61		1.40	to	1.55	7.24	to	7.08
	2016	24.770		to	21.302		176,854	4,377,222		1.75		1.40	to	1.55	18.81	to	18.63
BNY Mellon Appreciation
	2020	30.670		to	29.664		123,064	3,764,084		0.79		1.40	to	1.60	21.97	to	21.73
	2019	25.145		to	24.369		131,948	3,306,938		1.16		1.40	to	1.60	34.21	to	33.93
	2018	18.736		to	18.195		143,546	2,679,743		1.25		1.40	to	1.60	(8.16)	to	(8.34)
	2017	20.400		to	19.850		154,373	3,136,421		1.32		1.40	to	1.60	25.57	to	25.32
	2016	16.246		to	15.840		203,640	3,294,286		1.62		1.40	to	1.60	6.41	to	6.20
BNY Mellon MidCap Stock
	2020	31.027		to	30.010		205,588	6,268,108		0.85		1.40	to	1.60	6.60	to	6.39
	2019	29.106		to	28.207		237,858	6,799,461		0.66		1.40	to	1.60	18.51	to	18.27
	2018	24.559		to	23.849		277,200	6,678,013		0.58		1.40	to	1.60	(16.67)	to	(16.84)
	2017	29.472		to	28.678		322,002	9,320,219		1.15		1.40	to	1.60	13.77	to	13.55
	2016	25.904		to	25.255		462,806	11,798,432		1.09		1.40	to	1.60	13.87	to	13.64
BNY Mellon Quality Bond1
	2020	18.086		to	17.385		—	—		0.64		1.40	to	1.45	1.95	to	1.93
	2019	17.740		to	17.055		89,063	1,567,268		1.93		1.40	to	1.45	6.55	to	6.50
	2018	16.649		to	16.014		101,355	1,674,416		2.76		1.40	to	1.45	(3.91)	to	(3.96)
	2017	17.326		to	16.674		117,391	2,018,444		2.13		1.40	to	1.45	3.05	to	3.00
	2016	16.813		to	16.189		155,225	2,591,036		1.78		1.40	to	1.45	0.11	to	0.06
BNY Mellon Stock Index
	2020	42.052		to	40.673		226,188	9,484,699		1.31		1.40	to	1.60	16.08	to	15.84
	2019	36.228		to	35.110		271,395	9,803,608		1.44		1.40	to	1.60	29.03	to	28.77
	2018	28.078		to	27.266		318,786	8,925,227		1.38		1.40	to	1.60	(6.18)	to	(6.37)
	2017	29.929		to	29.122		382,877	11,428,321		1.39		1.40	to	1.60	19.53	to	19.29
	2016	25.039		to	24.412		587,423	14,672,605		1.75		1.40	to	1.60	9.90	to	9.68
BNY Mellon Sustainable U.S. Equity
	2020	20.371		to	33.986		129,185	2,630,663		1.18		1.40	to	1.55	22.41	to	22.23
	2019	16.641		to	27.804		155,877	2,579,312		1.51		1.40	to	1.55	32.49	to	32.29
	2018	12.560		to	21.017		182,695	2,285,181		1.83		1.40	to	1.55	(5.73)	to	(5.88)
	2017	13.324		to	22.330		224,275	2,963,588		1.20		1.40	to	1.55	13.73	to	13.56
	2016	11.715		to	19.663		276,476	3,217,334		1.28		1.40	to	1.55	8.84	to	8.68
BNY Mellon Technology Growth
	2020	22.990		to	20.717		206,399	4,632,904		0.26		1.40	to	1.45	67.57	to	67.48
	2019	13.720		to	12.370		255,500	3,429,202		—		1.40	to	1.45	24.06	to	24.01
	2018	11.059		to	9.975		286,581	3,105,332		—		1.40	to	1.45	(2.37)	to	(2.42)
	2017	11.327		to	10.222		331,604	3,686,960		—		1.40	to	1.45	40.67	to	40.59
	2016	8.052		to	7.271		385,254	3,052,626		—		1.40	to	1.45	3.27	to	3.22

36

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Calvert EAFE International Index F Class
	2020	$	10.671	to	$	10.604	27,607	$	293,447	3.42	%	1.40%	to	1.45%	6.06%	to	6.01%
	2019	10.061		to	10.003		27,867	279,353		2.69		1.40	to	1.45	19.32	to	19.27
	2018	8.432		to	8.387		27,223	228,778		3.27		1.40	to	1.45	(15.01)	to	(15.05)
	2017	9.921		to	9.873		27,867	275,663		2.48		1.40	to	1.45	22.72	to	22.66
	2016	8.084		to	8.049		29,730	239,929		2.74		1.40	to	1.45	(1.15)	to	(1.20)
Calvert Investment Grade Bond Index
	2020	13.882		to	13.794		203,232	2,820,837		2.96		1.40	to	1.45	5.85	to	5.79
	2019	13.115		to	13.039		207,236	2,717,455		3.09		1.40	to	1.45	6.90	to	6.85
	2018	12.268		to	12.203		255,006	3,127,857		3.02		1.40	to	1.45	(1.76)	to	(1.81)
	2017	12.488		to	12.428		275,044	3,434,126		2.68		1.40	to	1.45	2.06	to	2.01
	2016	12.236		to	12.183		340,416	4,164,499		2.81		1.40	to	1.45	1.17	to	1.12
Calvert Nasdaq 100 Index
	2020	59.876		to	59.498		64,930	3,885,296		0.42		1.40	to	1.45	46.17	to	46.10
	2019	40.964		to	40.725		83,522	3,418,624		0.49		1.40	to	1.45	36.85	to	36.78
	2018	29.933		to	29.774		96,058	2,873,099		0.55		1.40	to	1.45	(1.86)	to	(1.91)
	2017	30.500		to	30.353		97,726	2,978,593		0.49		1.40	to	1.45	30.51	to	30.45
	2016	23.369		to	23.268		114,963	2,683,339		0.54		1.40	to	1.45	5.11	to	5.07
Calvert Russell 2000 Small Cap Index F Class
	2020	25.098		to	24.940		34,645	868,196		1.07		1.40	to	1.45	17.74	to	17.69
	2019	21.316		to	21.192		40,786	868,258		0.86		1.40	to	1.45	23.09	to	23.02
	2018	17.318		to	17.226		48,440	838,101		0.96		1.40	to	1.45	(12.70)	to	(12.74)
	2017	19.838		to	19.742		63,887	1,265,834		0.73		1.40	to	1.45	12.51	to	12.45
	2016	17.632		to	17.556		89,185	1,570,762		0.41		1.40	to	1.45	18.95	to	18.89
Calvert S&P MidCap 400 Index F Class
	2020	25.769		to	25.607		29,590	761,199		1.24		1.40	to	1.45	11.52	to	11.47
	2019	23.107		to	22.972		29,923	690,432		1.04		1.40	to	1.45	23.82	to	23.75
	2018	18.662		to	18.563		39,377	734,158		1.10		1.40	to	1.45	(12.81)	to	(12.85)
	2017	21.403		to	21.300		43,805	936,540		0.64		1.40	to	1.45	14.02	to	13.96
	2016	18.771		to	18.690		55,148	1,033,875		0.55		1.40	to	1.45	18.30	to	18.24
Calvert SRI Balanced
	2020	21.671		to	21.535		23,654	512,584		1.54		1.40	to	1.45	13.66	to	13.61
	2019	19.067		to	18.956		23,108	440,616		1.55		1.40	to	1.45	22.67	to	22.61
	2018	15.543		to	15.460		16,757	260,458		1.77		1.40	to	1.45	(4.03)	to	(4.08)
	2017	16.195		to	16.117		15,502	251,067		2.05		1.40	to	1.45	10.44	to	10.39
	2016	14.664		to	14.600		16,593	243,348		1.90		1.40	to	1.45	6.36	to	6.31
Columbia VP Select Mid Cap Value Fund - Class 1
	2020	28.361		to	28.361		205	5,805		—		1.25	to	1.25	6.15	to	6.15
	2019	26.719		to	26.719		205	5,468		—		1.25	to	1.25	29.99	to	29.99
	2018	20.555		to	20.555		205	4,206		—		1.25	to	1.25	(14.38)	to	(14.38)
	2017	24.006		to	24.006		205	4,910		—		1.25	to	1.25	12.14	to	12.14
	2016	21.408		to	21.408		205	4,380		—		1.25	to	1.25	12.73	to	12.73

37

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
DWS Capital Growth VIP B
	2020	$	37.004	to	$	36.771	41,732	$	1,543,899	0.27	%	1.40%	to	1.45%	36.77	to	36.71%
	2019	27.055		to	26.898		51,228	1,385,653		0.17		1.40	to	1.45	34.89	to	34.82
	2018	20.057		to	19.951		68,201	1,367,699		0.50		1.40	to	1.45	(3.24)	to	(3.29)
	2017	20.729		to	20.630		93,890	1,946,058		0.50		1.40	to	1.45	24.22	to	24.16
	2016	16.688		to	16.616		146,252	2,440,138		0.53		1.40	to	1.45	2.56	to	2.50
DWS CROCI International VIP - Class A
	2020	19.078		to	8.910		84,248	1,580,215		3.51		1.40	to	1.45	1.19	to	1.14
	2019	18.854		to	8.810		91,086	1,690,650		3.04		1.40	to	1.45	20.08	to	20.03
	2018	15.701		to	7.340		97,950	1,520,683		1.05		1.40	to	1.45	(15.60)	to	(15.64)
	2017	18.602		to	8.701		108,047	1,989,565		6.98		1.40	to	1.45	20.28	to	20.21
	2016	15.466		to	7.238		125,632	1,923,765		10.81		1.40	to	1.45	(0.66)	to	(0.70)
DWS Global Income Builder VIP A
	2020	40.703		to	16.860		177,146	6,598,060		3.20		1.40	to	1.45	6.77	to	6.72
	2019	38.121		to	15.798		196,412	6,886,224		3.82		1.40	to	1.45	18.49	to	18.43
	2018	32.171		to	13.339		216,107	6,372,643		3.81		1.40	to	1.45	(8.95)	to	(9.00)
	2017	35.335		to	14.658		242,509	7,879,478		3.05		1.40	to	1.45	14.92	to	14.87
	2016	30.747		to	12.761		294,890	8,193,073		4.16		1.40	to	1.45	5.33	to	5.28
DWS Global Small Cap VIP B
	2020	15.362		to	15.265		6,755	103,766		0.59		1.40	to	1.45	15.31	to	15.26
	2019	13.322		to	13.244		7,031	93,670		—		1.40	to	1.45	19.39	to	19.34
	2018	11.158		to	11.098		8,526	95,111		—		1.40	to	1.45	(21.85)	to	(21.89)
	2017	14.278		to	14.209		11,820	168,639		—		1.40	to	1.45	17.94	to	17.89
	2016	12.106		to	12.053		17,534	211,955		0.13		1.40	to	1.45	(0.07)	to	(0.12)
DWS International Growth VIP B Share
	2020	15.141		to	15.141		5,992	90,718		1.20		1.40	to	1.40	20.59	to	20.59
	2019	12.556		to	12.556		5,908	74,183		1.01		1.40	to	1.40	29.02	to	29.02
	2018	9.732		to	9.732		6,222	60,550		0.90		1.40	to	1.40	(18.08)	to	(18.08)
	2017	11.880		to	11.880		2,962	35,189		0.08		1.40	to	1.40	23.53	to	23.53
	2016	9.617		to	9.617		2,342	22,525		0.36		1.40	to	1.40	1.94	to	1.94
DWS Small Cap Index A Share
	2020	28.055		to	26.501		11,828	324,163		1.03		1.00	to	1.45	18.25	to	17.71
	2019	23.726		to	22.513		13,378	311,121		1.12		1.00	to	1.45	23.97	to	23.42
	2018	19.138		to	18.241		22,553	426,061		0.91		1.00	to	1.45	(14.54)	to	(12.52)
	2017	22.395		to	20.851		25,387	558,375		0.93		1.00	to	1.45	14.04	to	12.69
	2016	19.637		to	18.503		26,713	514,912		1.08		1.00	to	1.45	20.85	to	19.29
Federated Hermes High Income Bond1
	2020	33.301		to	27.091		45,633	1,491,426		6.00		1.40	to	1.45	4.12	to	4.07
	2019	31.983		to	26.032		49,700	1,561,957		6.16		1.40	to	1.45	12.95	to	12.90
	2018	28.315		to	23.058		53,429	1,486,822		8.15		1.40	to	1.45	(4.64)	to	(4.69)
	2017	29.693		to	24.192		59,244	1,727,266		6.93		1.40	to	1.45	5.46	to	5.40
	2016	28.156		to	22.952		68,568	1,892,296		6.51		1.40	to	1.45	13.23	to	13.18

38

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Federated Hermes Managed Volatility II1
	2020	$	28.974	to	$	17.177	17,654	$	511,498	2.64	%	1.40%	to	1.45%	(0.47)	to	(0.53)%
	2019	29.111		to	17.268		19,445	566,072		2.10		1.40	to	1.45	18.55	to	18.50
	2018	24.555		to	14.572		20,847	511,909		2.96		1.40	to	1.45	(9.77)	to	(9.82)
	2017	27.215		to	16.159		24,415	660,902		4.02		1.40	to	1.45	16.48	to	16.42
	2016	23.365		to	13.880		28,247	656,708		5.02		1.40	to	1.45	6.19	to	6.14
Fidelity Asset Manager
	2020	25.622		to	25.397		4,563	116,909		1.41		1.40	to	1.45	13.27	to	13.22
	2019	22.620		to	22.432		5,305	119,995		1.69		1.40	to	1.45	16.60	to	16.55
	2018	19.399		to	19.247		6,334	122,866		1.67		1.40	to	1.45	(6.67)	to	(6.72)
	2017	20.786		to	20.634		6,674	138,730		1.75		1.40	to	1.45	12.53	to	12.47
	2016	18.472		to	18.347		8,902	164,453		1.44		1.40	to	1.45	1.64	to	1.59
Fidelity Contrafund
	2020	56.875		to	55.010		517,569	29,344,223		0.25		1.40	to	1.60	28.75	to	28.50
	2019	44.174		to	42.811		591,497	26,049,303		0.44		1.40	to	1.60	29.75	to	29.49
	2018	34.046		to	33.061		711,423	24,150,691		0.68		1.40	to	1.60	(7.68)	to	(7.87)
	2017	36.880		to	35.886		818,416	30,074,103		0.95		1.40	to	1.60	20.19	to	19.95
	2016	30.686		to	29.918		1,071,099	32,766,299		0.78		1.40	to	1.60	6.51	to	6.30
Fidelity Contrafund II
	2020	35.968		to	35.968		213	7,689		0.08		1.25	to	1.25	28.62	to	28.62
	2019	27.965		to	27.965		213	5,981		0.22		1.25	to	1.25	29.64	to	29.64
	2018	21.571		to	21.571		213	4,612		0.45		1.25	to	1.25	(7.80)	to	(7.80)
	2017	23.397		to	23.397		213	4,992		0.78		1.25	to	1.25	20.08	to	20.08
	2016	19.485		to	19.485		213	4,144		0.64		1.25	to	1.25	6.40	to	6.40
Fidelity Equity-Income
	2020	32.368		to	31.306		119,227	3,852,454		1.74		1.40	to	1.60	5.21	to	5.00
	2019	30.765		to	29.815		142,969	4,390,575		1.97		1.40	to	1.60	25.67	to	25.42
	2018	24.480		to	23.772		158,871	3,882,557		2.10		1.40	to	1.60	(9.58)	to	(9.76)
	2017	27.073		to	26.342		209,709	5,668,292		1.52		1.40	to	1.60	11.33	to	11.11
	2016	24.317		to	23.709		322,908	7,841,209		2.18		1.40	to	1.60	16.38	to	16.15
Fidelity Freedom Funds 2010 II
	2020	17.226		to	17.118		19,535	336,512		2.28		1.40	to	1.45	10.68	to	10.62
	2019	15.564		to	15.474		383	5,959		2.22		1.40	to	1.45	14.14	to	14.09
	2018	13.636		to	13.563		281	3,829		0.05		1.40	to	1.45	(5.60)	to	(5.65)
	2017	14.445		to	14.375		192	2,775		0.36		1.40	to	1.45	11.24	to	11.18
	2016	12.986		to	12.930		1,329	17,256		0.62		1.40	to	1.45	3.77	to	3.72
Fidelity Freedom Funds 2015 II
	2020	17.937		to	17.823		8,412	150,888		1.05		1.40	to	1.45	11.99	to	11.93
	2019	16.017		to	15.924		8,825	141,341		1.81		1.40	to	1.45	16.33	to	16.28
	2018	13.768		to	13.695		9,499	130,781		1.36		1.40	to	1.45	(6.61)	to	(6.65)
	2017	14.742		to	14.671		10,314	152,046		1.06		1.40	to	1.45	13.21	to	13.15
	2016	13.022		to	12.966		14,160	184,409		0.96		1.40	to	1.45	4.12	to	4.06

39

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Fidelity Freedom Funds 2020 II
	2020	$	18.340	to	$	18.224	34,846	$	637,624	0.99	%	1.40%	to	1.45%	13.13	to	13.07%
	2019	16.212		to	16.117		39,984	646,965		1.74		1.40	to	1.45	18.21	to	18.15
	2018	13.714		to	13.641		49,845	682,815		1.20		1.40	to	1.45	(7.39)	to	(7.44)
	2017	14.809		to	14.737		57,320	848,177		1.26		1.40	to	1.45	14.65	to	14.59
	2016	12.917		to	12.861		69,962	903,316		1.69		1.40	to	1.45	4.34	to	4.29
Fidelity Freedom Funds 2025 II
	2020	19.592		to	19.468		54,918	1,074,599		1.00		1.40	to	1.45	14.07	to	14.01
	2019	17.175		to	17.075		57,380	984,428		1.90		1.40	to	1.45	19.82	to	19.77
	2018	14.334		to	14.257		56,699	811,860		1.28		1.40	to	1.45	(8.08)	to	(8.13)
	2017	15.594		to	15.518		57,550	896,584		0.92		1.40	to	1.45	15.94	to	15.88
	2016	13.450		to	13.392		85,731	1,152,453		1.43		1.40	to	1.45	4.51	to	4.46
Fidelity Freedom Funds 2030 II
	2020	19.956		to	19.830		91,743	1,830,866		1.00		1.40	to	1.45	15.02	to	14.96
	2019	17.350		to	17.249		92,478	1,604,503		1.83		1.40	to	1.45	22.39	to	22.32
	2018	14.176		to	14.101		95,242	1,350,188		1.19		1.40	to	1.45	(9.34)	to	(9.39)
	2017	15.637		to	15.562		77,407	1,210,404		1.04		1.40	to	1.45	19.02	to	18.97
	2016	13.138		to	13.081		98,096	1,288,787		1.34		1.40	to	1.45	4.90	to	4.85
Fidelity Freedom Funds 2050 II
	2020	27.220		to	27.220		952	25,919		0.77		1.25	to	1.25	17.52	to	17.52
	2019	23.162		to	23.162		952	22,055		1.57		1.25	to	1.25	26.62	to	26.62
	2018	18.292		to	18.292		944	17,275		0.98		1.25	to	1.25	(11.25)	to	(11.25)
	2017	20.611		to	20.611		856	17,636		1.07		1.25	to	1.25	21.78	to	21.78
	2016	16.925		to	16.925		761	12,893		1.39		1.25	to	1.25	5.24	to	5.24
Fidelity Freedom Income Fund II
	2020	14.624		to	14.532		12,486	182,174		1.14		1.40	to	1.45	8.75	to	8.70
	2019	13.447		to	13.369		10,839	145,398		1.89		1.40	to	1.45	10.08	to	10.02
	2018	12.216		to	12.151		10,589	129,059		1.49		1.40	to	1.45	(3.64)	to	(3.69)
	2017	12.677		to	12.616		10,912	138,047		1.26		1.40	to	1.45	6.85	to	6.80
	2016	11.864		to	11.813		9,505	112,783		1.29		1.40	to	1.45	2.73	to	2.68
Fidelity Government Money Market Portfolio - Initial Class
	2020	9.710		to	9.259		2,354	22,160		0.33		1.10	to	1.45	(0.78)	to	(1.13)
	2019	9.786		to	9.365		2,416	22,977		2.13		1.10	to	1.45	0.90	to	0.55
	2018	9.699		to	9.314		16,500	156,286		1.55		1.10	to	1.45	0.54	to	0.18
	2017	9.647		to	9.297		46,710	441,661		0.67		1.10	to	1.45	(0.42)	to	(0.77)
	2016	9.688		to	9.369		49,091	466,789		0.21		1.10	to	1.45	(0.89)	to	(1.23)
Fidelity Government Money Market Portfolio - Service Class II
	2020	9.057		to	9.382		660,525	6,370,522		0.21		1.25	to	1.60	(1.01)	to	(1.36)
	2019	9.149		to	9.511		592,477	5,792,449		1.76		1.25	to	1.60	0.49	to	0.15
	2018	9.104		to	9.497		722,363	7,003,609		1.39		1.25	to	1.60	0.13	to	(0.22)
	2017	9.092		to	9.518		726,797	7,094,105		0.40		1.25	to	1.60	(0.82)	to	(1.16)
	2016	9.167		to	9.630		936,131	9,221,875		0.01		1.25	to	1.60	(1.22)	to	(1.57)

40

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Fidelity Growth
	2020	$	30.509	to	$	46.239	583,153	$	17,725,931	0.07	%	1.40%	to	1.75%	41.90	to	41.40%
	2019	21.501		to	32.701		642,769	13,768,061		0.26		1.40	to	1.75	32.44	to	31.98
	2018	16.234		to	24.777		713,782	11,540,602		0.24		1.40	to	1.75	(1.56)	to	(1.91)
	2017	16.492		to	25.259		804,743	13,218,686		0.22		1.40	to	1.75	33.27	to	32.80
	2016	12.375		to	19.021		1,047,500	12,907,830		0.04		1.40	to	1.75	(0.60)	to	(0.94)
Fidelity Growth & Income
	2020	25.995		to	25.143		175,639	4,524,711		2.08		1.40	to	1.60	6.35	to	6.14
	2019	24.444		to	23.689		206,823	5,012,179		3.60		1.40	to	1.60	28.25	to	27.99
	2018	19.060		to	18.509		233,152	4,406,674		0.35		1.40	to	1.60	(10.26)	to	(10.43)
	2017	21.238		to	20.665		277,880	5,856,898		1.18		1.40	to	1.60	15.28	to	15.05
	2016	18.423		to	17.962		374,777	6,854,049		1.68		1.40	to	1.60	14.47	to	14.24
Fidelity Growth Opportunities
	2020	55.080		to	48.683		120,294	6,561,153		0.01		1.40	to	1.45	66.31	to	66.23
	2019	33.118		to	29.286		129,597	4,252,485		0.15		1.40	to	1.45	38.88	to	38.82
	2018	23.846		to	21.097		149,061	3,525,066		0.12		1.40	to	1.45	10.89	to	10.83
	2017	21.504		to	19.035		176,686	3,772,644		0.30		1.40	to	1.45	32.64	to	32.58
	2016	16.212		to	14.357		203,159	3,273,148		0.33		1.40	to	1.45	(1.05)	to	(1.11)
Fidelity Index 500
	2020	27.329		to	26.417		44,602	1,203,862		1.76		1.20	to	1.45	16.83	to	16.54
	2019	23.392		to	22.668		44,990	1,040,805		1.98		1.20	to	1.45	29.78	to	29.46
	2018	18.024		to	17.510		45,483	811,062		1.75		1.20	to	1.45	(5.64)	to	(5.87)
	2017	19.101		to	18.602		55,747	1,054,317		1.78		1.20	to	1.45	20.27	to	19.97
	2016	15.882		to	15.506		60,409	950,868		1.46		1.20	to	1.45	10.53	to	10.25
Fidelity Mid Cap II
	2020	33.565		to	32.529		122,477	4,105,808		0.40		1.40	to	1.60	16.23	to	16.00
	2019	28.879		to	28.043		147,985	4,268,024		0.65		1.40	to	1.60	21.46	to	21.21
	2018	23.776		to	23.135		185,848	4,412,794		0.38		1.40	to	1.60	(15.97)	to	(16.13)
	2017	28.293		to	27.585		228,474	6,455,164		0.46		1.40	to	1.60	18.86	to	18.63
	2016	23.803		to	23.253		342,589	8,145,469		0.29		1.40	to	1.60	10.37	to	10.15
Fidelity Overseas II
	2020	13.291		to	13.207		29,339	389,894		0.22		1.40	to	1.45	13.73	to	13.68
	2019	11.686		to	11.618		29,753	347,675		1.50		1.40	to	1.45	25.72	to	25.67
	2018	9.295		to	9.245		34,457	320,247		1.39		1.40	to	1.45	(16.25)	to	(16.29)
	2017	11.098		to	11.044		27,157	301,351		1.39		1.40	to	1.45	28.20	to	28.12
	2016	8.657		to	8.620		25,019	216,609		1.17		1.40	to	1.45	(6.58)	to	(6.63)
Franklin Allocation VIP Fund - Class 2
	2020	16.794		to	16.794		25,930	435,455		1.51		1.40	to	1.40	10.19	to	10.19
	2019	15.241		to	15.241		29,068	443,017		3.51		1.40	to	1.40	18.19	to	18.19
	2018	12.895		to	12.895		31,890	411,206		3.08		1.40	to	1.40	(10.91)	to	(10.91)
	2017	14.474		to	14.474		32,388	468,785		2.65		1.40	to	1.40	10.42	to	10.42
	2016	13.108		to	13.108		42,555	557,858		3.86		1.40	to	1.40	11.61	to	11.61

41

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Franklin Flex Cap Growth VIP Fund - Class 2
	2020	$	41.908	to	$	40.934	16,311	$	683,550	—	%	1.40%	to	1.55%	42.87	to	42.66%
	2019	29.333		to	28.694		14,946	438,372		—		1.40	to	1.55	29.35	to	29.15
	2018	22.678		to	22.218		14,631	331,796		—		1.40	to	1.55	1.69	to	1.54
	2017	22.301		to	21.881		16,898	376,823		—		1.40	to	1.55	25.18	to	25.00
	2016	17.815		to	17.505		18,181	323,912		—		1.40	to	1.55	(4.23)	to	(4.38)
Franklin Income VIP Fund - Class 2
	2020	19.629		to	19.007		175,385	3,439,598		5.86		1.40	to	1.60	(0.70)	to	(0.91)
	2019	19.768		to	19.181		204,277	4,034,189		5.42		1.40	to	1.60	14.44	to	14.22
	2018	17.273		to	16.793		241,560	4,168,007		4.75		1.40	to	1.60	(5.64)	to	(5.83)
	2017	18.306		to	17.833		274,076	5,012,568		4.04		1.40	to	1.60	8.15	to	7.93
	2016	16.926		to	16.522		368,939	6,239,411		4.94		1.40	to	1.60	12.44	to	12.22
Franklin Mutual Shares VIP Fund - Class 2
	2020	21.786		to	19.989		166,862	3,633,025		2.80		1.40	to	1.55	(6.37)	to	(6.51)
	2019	23.267		to	21.380		189,440	4,405,015		1.79		1.40	to	1.55	20.87	to	20.69
	2018	19.250		to	17.715		212,244	4,083,528		2.35		1.40	to	1.55	(10.34)	to	(10.48)
	2017	21.469		to	19.788		249,557	5,354,810		2.01		1.40	to	1.55	6.84	to	6.69
	2016	20.094		to	18.548		354,338	7,117,283		1.94		1.40	to	1.55	14.45	to	14.28
Franklin Small Cap Value VIP Fund - Class 2
	2020	28.270		to	27.397		166,052	4,689,782		1.52		1.40	to	1.60	3.73	to	3.52
	2019	27.254		to	26.465		190,298	5,181,492		1.07		1.40	to	1.60	24.59	to	24.34
	2018	21.875		to	21.284		227,993	4,982,783		0.88		1.40	to	1.60	(14.09)	to	(14.27)
	2017	25.464		to	24.826		273,048	6,947,392		0.51		1.40	to	1.60	9.12	to	8.90
	2016	23.336		to	22.797		418,611	9,762,213		0.83		1.40	to	1.60	28.38	to	28.12
Franklin Small-Mid Cap Growth VIP Fund - Class 2
	2020	29.332		to	41.765		151,122	4,429,856		—		1.40	to	1.55	52.94	to	52.71
	2019	19.179		to	27.349		178,294	3,418,001		—		1.40	to	1.55	29.61	to	29.41
	2018	14.798		to	21.133		213,367	3,143,476		—		1.40	to	1.55	(6.70)	to	(6.84)
	2017	15.860		to	22.684		246,335	3,884,452		—		1.40	to	1.55	19.72	to	19.54
	2016	13.248		to	18.976		328,106	4,317,717		—		1.40	to	1.55	2.73	to	2.57
Franklin U.S. Government Securities VIP Fund - Class 2
	2020	16.620		to	16.209		343,768	5,464,967		3.39		1.40	to	1.55	2.39	to	2.23
	2019	16.232		to	15.855		336,678	5,385,469		2.95		1.40	to	1.55	3.77	to	3.61
	2018	15.643		to	15.302		430,924	6,641,094		2.72		1.40	to	1.55	(1.06)	to	(1.21)
	2017	15.811		to	15.490		485,673	7,572,017		2.58		1.40	to	1.55	(0.07)	to	(0.22)
	2016	15.822		to	15.524		607,929	9,487,125		2.44		1.40	to	1.55	(0.73)	to	(0.88)
Invesco American Franchise Fund I
	2020	29.559		to	29.343		210,971	6,234,553		0.07		1.40	to	1.45	40.38	to	40.30
	2019	21.057		to	20.914		226,664	4,771,769		—		1.40	to	1.45	34.85	to	34.79
	2018	15.615		to	15.516		248,967	3,886,740		—		1.40	to	1.45	(4.97)	to	(5.02)
	2017	16.432		to	16.336		286,704	4,710,219		0.08		1.40	to	1.45	25.58	to	25.52
	2016	13.085		to	13.015		353,096	4,619,656		—		1.40	to	1.45	0.85	to	0.80

42

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Invesco American Franchise Fund II
	2020	$	35.283	to	$	34.464	25,117	$	885,968	—	%	1.40%	to	1.55%	40.02	to	39.81%
	2019	25.198		to	24.650		33,507	844,146		—		1.40	to	1.55	34.53	to	34.33
	2018	18.730		to	18.350		38,412	719,287		—		1.40	to	1.55	(5.24)	to	(5.38)
	2017	19.765		to	19.393		43,819	865,751		—		1.40	to	1.55	25.27	to	25.08
	2016	15.778		to	15.505		65,793	1,037,799		—		1.40	to	1.55	0.60	to	0.45
Invesco Global Real Estate
	2020	34.793		to	22.251		64,995	2,238,534		4.84		1.40	to	1.75	(13.54)	to	(13.84)
	2019	40.241		to	25.825		78,101	3,111,051		4.33		1.40	to	1.75	21.29	to	20.87
	2018	33.178		to	21.366		89,550	2,940,091		3.70		1.40	to	1.75	(7.46)	to	(7.79)
	2017	35.854		to	23.171		103,558	3,677,292		3.04		1.40	to	1.75	11.48	to	11.09
	2016	32.161		to	20.857		139,715	4,447,623		1.54		1.40	to	1.75	0.63	to	0.27
Invesco Health Care
	2020	41.995		to	41.626		8,059	337,884		0.32		1.40	to	1.45	12.87	to	12.81
	2019	37.207		to	36.898		8,468	314,516		0.04		1.40	to	1.45	30.66	to	30.59
	2018	28.476		to	28.254		8,671	246,498		—		1.40	to	1.45	(0.51)	to	(0.56)
	2017	28.621		to	28.412		9,603	274,380		0.35		1.40	to	1.45	14.22	to	14.16
	2016	25.057		to	24.887		11,336	283,628		—		1.40	to	1.45	(12.69)	to	(12.73)
Invesco International Growth I
	2020	37.975		to	27.872		15,196	571,874		2.31		1.40	to	1.55	12.41	to	12.24
	2019	33.782		to	24.832		16,781	561,883		1.45		1.40	to	1.55	26.79	to	26.60
	2018	26.645		to	19.615		23,037	609,452		1.86		1.40	to	1.55	(16.17)	to	(16.29)
	2017	31.783		to	23.433		29,058	909,354		1.34		1.40	to	1.55	21.30	to	21.11
	2016	26.203		to	19.348		40,569	1,050,126		1.32		1.40	to	1.55	(1.83)	to	(1.98)
Invesco International Growth II
	2020	18.677		to	17.734		299,492	5,591,308		2.06		1.40	to	1.75	12.15	to	11.77
	2019	16.653		to	15.867		359,782	5,988,978		1.24		1.40	to	1.75	26.46	to	26.01
	2018	13.169		to	12.592		466,835	6,145,384		1.73		1.40	to	1.75	(16.39)	to	(16.68)
	2017	15.750		to	15.113		562,136	8,850,889		1.16		1.40	to	1.75	21.02	to	20.60
	2016	13.014		to	12.531		882,578	11,482,898		1.16		1.40	to	1.75	(2.08)	to	(2.42)
Invesco Mid Cap Growth Fund I1
	2020	34.539		to	34.246		—	—		—		1.40	to	1.45	(5.94)	to	(5.96)
	2019	36.721		to	36.416		4,110	150,871		—		1.40	to	1.45	32.48	to	32.41
	2018	27.719		to	27.503		4,086	113,219		—		1.40	to	1.45	(6.91)	to	(6.95)
	2017	29.775		to	29.557		4,540	135,071		—		1.40	to	1.45	20.79	to	20.73
	2016	24.650		to	24.482		4,574	112,664		—		1.40	to	1.45	(0.64)	to	(0.69)
Invesco Mid Cap Growth Fund II1
	2020	19.512		to	19.102		—	—		—		1.40	to	1.55	(5.82)	to	(5.87)
	2019	20.718		to	20.293		11,958	247,616		—		1.40	to	1.55	32.14	to	31.94
	2018	15.679		to	15.380		14,364	225,112		—		1.40	to	1.55	(7.19)	to	(7.33)
	2017	16.893		to	16.597		17,849	301,331		—		1.40	to	1.55	20.45	to	20.27
	2016	14.025		to	13.800		24,274	340,319		—		1.40	to	1.55	(0.83)	to	(0.97)

43

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Invesco Oppenheimer Discovery Mid Cap Growth Fund I1
	2020	$	50.733	to	$	50.286	3,403	$	172,590	—	%	1.40%	to	1.45%	46.89	to	46.84%
Invesco Oppenheimer Discovery Mid Cap Growth Fund II1
	2020	28.591		to	27.757		9,515	271,858		—		1.40	to	1.60	46.53	to	45.31
Invesco Small Cap Equity II
	2020	23.836		to	23.686		11,911	283,925		0.03		1.40	to	1.45	25.10	to	25.04
	2019	19.053		to	18.942		12,750	242,719		—		1.40	to	1.45	24.57	to	24.50
	2018	15.295		to	15.214		19,877	303,877		—		1.40	to	1.45	(16.46)	to	(16.50)
	2017	18.309		to	18.220		26,509	485,173		—		1.40	to	1.45	12.15	to	12.09
	2016	16.325		to	16.255		33,602	548,212		—		1.40	to	1.45	10.29	to	10.23
JP Morgan Insurance Trust Mid Cap Value I
	2020	42.763		to	41.360		101,880	4,319,531		1.48		1.40	to	1.60	(1.03)	to	(1.23)
	2019	43.206		to	41.873		109,986	4,714,716		1.61		1.40	to	1.60	25.00	to	24.75
	2018	34.565		to	33.565		128,372	4,405,684		0.98		1.40	to	1.60	(13.07)	to	(13.24)
	2017	39.762		to	38.689		145,962	5,765,511		0.82		1.40	to	1.60	12.19	to	11.96
	2016	35.442		to	34.555		212,820	7,505,969		0.89		1.40	to	1.60	13.10	to	12.88
JP Morgan Insurance Trust U.S. Equity I
	2020	28.527		to	27.421		91,419	2,565,836		0.78		1.40	to	1.45	23.52	to	23.46
	2019	23.095		to	22.210		107,423	2,436,547		0.88		1.40	to	1.45	29.92	to	29.85
	2018	17.776		to	17.104		124,100	2,166,445		0.83		1.40	to	1.45	(7.47)	to	(7.52)
	2017	19.212		to	18.495		143,495	2,711,654		0.89		1.40	to	1.45	20.63	to	20.58
	2016	15.926		to	15.339		177,983	2,788,817		1.01		1.40	to	1.45	9.40	to	9.35
Morningstar Aggressive Growth ETF Asset Allocation Class I
	2020	16.785		to	16.225		8,227	135,689		2.09		1.20	to	1.45	9.03	to	8.75
	2019	15.395		to	14.919		9,058	137,161		1.77		1.20	to	1.45	20.98	to	20.68
	2018	12.725		to	12.362		9,393	117,472		1.62		1.20	to	1.45	(10.26)	to	(10.49)
	2017	14.180		to	13.810		7,379	102,995		0.49		1.20	to	1.45	18.74	to	18.44
	2016	11.942		to	11.660		24,695	293,686		1.49		1.20	to	1.45	10.13	to	9.85
Morningstar Aggressive Growth ETF Asset Allocation Class II
	2020	17.150		to	17.042		95,314	1,634,661		1.77		1.40	to	1.45	8.43	to	8.38
	2019	15.817		to	15.725		105,697	1,671,820		1.47		1.40	to	1.45	20.47	to	20.41
	2018	13.129		to	13.060		118,399	1,554,524		1.35		1.40	to	1.45	(10.60)	to	(10.64)
	2017	14.686		to	14.615		125,816	1,847,684		1.16		1.40	to	1.45	18.14	to	18.08
	2016	12.431		to	12.377		188,227	2,339,823		1.16		1.40	to	1.45	9.67	to	9.62
Morningstar Balanced ETF Asset Allocation Class I
	2020	16.326		to	15.782		43,202	700,043		2.38		1.20	to	1.45	8.10	to	7.84
	2019	15.102		to	14.635		44,373	665,279		2.26		1.20	to	1.45	15.18	to	14.89
	2018	13.112		to	12.738		57,541	748,283		2.17		1.20	to	1.45	(7.15)	to	(7.39)
	2017	14.122		to	13.754		58,673	821,636		1.69		1.20	to	1.45	12.30	to	12.02
	2016	12.575		to	12.278		72,823	908,647		1.93		1.20	to	1.45	7.40	to	7.13

44

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Morningstar Balanced ETF Asset Allocation Class II
	2020	$	15.814	to	$	15.715	242,662	$	3,836,036	1.94	%	1.40%	to	1.45%	7.60	to	7.56%
	2019	14.697		to	14.611		290,410	4,266,779		1.83		1.40	to	1.45	14.64	to	14.59
	2018	12.820		to	12.751		382,649	4,902,232		1.76		1.40	to	1.45	(7.54)	to	(7.59)
	2017	13.865		to	13.799		452,856	6,275,926		1.37		1.40	to	1.45	11.75	to	11.71
	2016	12.407		to	12.353		738,912	9,164,807		1.70		1.40	to	1.45	6.98	to	6.92
Morningstar Conservative ETF Asset Allocation Class I
	2020	14.198		to	13.725		36,843	517,825		1.97		1.20	to	1.45	5.52	to	5.26
	2019	13.455		to	13.039		36,963	492,673		2.27		1.20	to	1.45	8.44	to	8.17
	2018	12.408		to	12.054		37,437	460,473		2.37		1.20	to	1.45	(3.26)	to	(3.51)
	2017	12.826		to	12.492		40,841	519,604		1.97		1.20	to	1.45	5.18	to	4.92
	2016	12.194		to	11.906		43,923	531,165		1.84		1.20	to	1.45	3.64	to	3.38
Morningstar Conservative ETF Asset Allocation Class II
	2020	12.871		to	12.789		9,400	120,857		1.36		1.40	to	1.45	5.02	to	4.96
	2019	12.256		to	12.185		12,193	149,350		1.73		1.40	to	1.45	8.00	to	7.95
	2018	11.348		to	11.288		18,773	212,955		2.06		1.40	to	1.45	(3.73)	to	(3.78)
	2017	11.788		to	11.731		22,058	259,940		1.69		1.40	to	1.45	4.73	to	4.68
	2016	11.256		to	11.207		24,972	281,054		1.37		1.40	to	1.45	3.16	to	3.11
Morningstar Growth ETF Asset Allocation Class I
	2020	16.863		to	16.300		6,584	108,792		2.32		1.20	to	1.45	8.95	to	8.67
	2019	15.478		to	14.999		6,764	102,737		2.04		1.20	to	1.45	18.71	to	18.41
	2018	13.039		to	12.667		6,797	87,100		0.79		1.20	to	1.45	(8.96)	to	(9.18)
	2017	14.322		to	13.948		32,345	457,643		1.44		1.20	to	1.45	16.28	to	15.99
	2016	12.317		to	12.025		35,831	436,646		1.73		1.20	to	1.45	8.58	to	8.30
Morningstar Growth ETF Asset Allocation Class II
	2020	16.825		to	16.718		171,952	2,893,026		1.87		1.40	to	1.45	8.48	to	8.42
	2019	15.510		to	15.420		205,808	3,192,073		1.61		1.40	to	1.45	18.10	to	18.04
	2018	13.133		to	13.063		254,984	3,348,631		1.54		1.40	to	1.45	(9.32)	to	(9.37)
	2017	14.483		to	14.414		298,474	4,322,905		1.20		1.40	to	1.45	15.67	to	15.62
	2016	12.521		to	12.467		440,946	5,520,975		1.49		1.40	to	1.45	8.17	to	8.12
Morningstar Income & Growth ETF Asset Allocation Class I
	2020	15.264		to	14.754		7,172	107,256		2.44		1.20	to	1.45	7.43	to	7.16
	2019	14.208		to	13.768		8,009	112,336		2.39		1.20	to	1.45	11.84	to	11.56
	2018	12.704		to	12.341		9,029	113,346		2.19		1.20	to	1.45	(5.14)	to	(5.38)
	2017	13.393		to	13.043		11,709	155,370		2.06		1.20	to	1.45	8.82	to	8.54
	2016	12.308		to	12.017		12,855	156,953		2.06		1.20	to	1.45	5.46	to	5.20
Morningstar Income & Growth ETF Asset Allocation Class II
	2020	14.365		to	14.275		46,818	672,093		1.89		1.40	to	1.45	6.92	to	6.87
	2019	13.435		to	13.357		55,343	743,140		2.01		1.40	to	1.45	11.33	to	11.28
	2018	12.068		to	12.003		66,202	797,988		1.77		1.40	to	1.45	(5.59)	to	(5.64)
	2017	12.782		to	12.721		86,927	1,110,316		1.45		1.40	to	1.45	8.41	to	8.37
	2016	11.790		to	11.739		137,474	1,620,164		1.53		1.40	to	1.45	4.90	to	4.85

45

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,					For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio			Units Outstanding	Net Assets	Net Investment Income Ratio2	Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Neuberger Berman AMT Mid Cap Growth Class S
	2020	32.059	to	31.857	16,288	522,186	—	1.40	to	1.45	37.77	to	37.70
	2019	23.270	to	23.135	28,734	668,531	—	1.40	to	1.45	30.63	to	30.57
	2018	17.813	to	17.718	33,111	589,712	—	1.40	to	1.45	(7.86)	to	(7.91)
	2017	19.333	to	19.240	38,378	741,877	—	1.40	to	1.45	22.83	to	22.77
	2016	15.739	to	15.671	48,517	763,436	—	1.40	to	1.45	2.71	to	2.67
Neuberger Berman AMT Mid Cap Intrinsic Value Class S
	2020	17.071	to	16.963	1,661	28,357	0.66	1.40	to	1.45	(4.18)	to	(4.23)
	2019	17.816	to	17.713	2,232	39,766	0.19	1.40	to	1.45	14.82	to	14.76
	2018	15.517	to	15.435	3,088	47,919	0.22	1.40	to	1.45	(16.66)	to	(16.70)
	2017	18.619	to	18.530	4,255	79,219	0.47	1.40	to	1.45	14.73	to	14.68
	2016	16.228	to	16.158	4,634	75,213	0.25	1.40	to	1.45	14.37	to	14.32
Neuberger Berman AMT Sustainable Equity Class S
	2020	25.892	to	25.728	5,633	145,836	0.39	1.40	to	1.45	17.62	to	17.56
	2019	22.013	to	21.885	5,514	121,371	0.30	1.40	to	1.45	28.76	to	28.70
PIMCO All Asset Portfolio Advisor
	2020	15.324	to	16.806	22,669	389,385	4.87	1.25	to	1.55	6.56	to	6.25
	2019	14.380	to	15.817	22,953	370,519	2.64	1.25	to	1.55	10.35	to	10.02
	2018	13.031	to	14.376	37,528	549,735	2.97	1.25	to	1.55	(6.63)	to	(6.91)
	2017	13.956	to	15.443	46,868	736,779	4.35	1.25	to	1.55	11.98	to	11.64
	2016	12.463	to	13.833	57,128	803,528	2.67	1.25	to	1.55	11.51	to	11.17
PIMCO CommodityRealReturn Strat. Administrative Class
	2020	6.031	to	5.891	170,676	1,028,652	6.52	1.40	to	1.55	(0.05)	to	(0.20)
	2019	6.034	to	5.903	193,055	1,164,252	4.44	1.40	to	1.55	9.87	to	9.72
	2018	5.492	to	5.380	224,944	1,234,594	2.09	1.40	to	1.55	(15.33)	to	(15.46)
	2017	6.486	to	6.364	265,774	1,722,884	11.19	1.40	to	1.55	0.73	to	0.58
	2016	6.439	to	6.327	426,870	2,746,308	1.09	1.40	to	1.55	13.56	to	13.39
PIMCO Total Return Portfolio Advisor
	2020	13.675	to	13.675	24,611	336,553	1.94	1.25	to	1.25	7.20	to	7.20
	2019	12.757	to	12.757	20,840	265,858	2.86	1.25	to	1.25	6.91	to	6.91
	2018	11.933	to	11.933	—	—	—	1.25	to	1.25	(1.87)	to	(1.87)
	2017	12.161	to	12.161	—	—	—	1.25	to	1.25	3.52	to	3.52
	2016	11.747	to	11.747	—	—	—	1.25	to	1.25	1.30	to	1.30
Pioneer Bond VCT Class I
	2020	46.097	to	22.434	50,373	2,126,892	3.03	1.40	to	1.45	7.19	to	7.14
	2019	43.004	to	20.939	56,582	2,226,805	3.26	1.40	to	1.45	7.76	to	7.70
	2018	39.909	to	19.442	62,303	2,281,525	3.31	1.40	to	1.45	(2.23)	to	(2.28)
	2017	40.819	to	19.896	69,459	2,587,877	2.85	1.40	to	1.45	2.56	to	2.51
	2016	39.799	to	19.408	77,702	2,798,081	2.77	1.40	to	1.45	2.66	to	2.61

46

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Pioneer Equity Income VCT Class II
	2020	$	26.549	to	$	25.709	187,564	$	4,978,801	2.39	%	1.40%	to	1.60%	(1.65)	to	(1.85)%
	2019	26.995		to	26.193		220,582	5,953,542		2.35		1.40	to	1.60	23.49	to	23.24
	2018	21.860		to	21.253		283,749	6,200,552		2.10		1.40	to	1.60	(10.05)	to	(10.23)
	2017	24.302		to	23.674		334,592	8,128,108		1.43		1.40	to	1.60	13.58	to	13.35
	2016	21.396		to	20.885		470,862	10,070,437		1.82		1.40	to	1.60	17.87	to	17.64
Pioneer Fund VCT Class I
	2020	161.775		to	25.252		255,858	40,603,711		0.77		1.40	to	1.45	22.55	to	22.49
	2019	132.005		to	20.615		275,500	35,681,898		1.01		1.40	to	1.45	29.51	to	29.44
	2018	101.930		to	15.926		303,761	30,173,367		1.12		1.40	to	1.45	(2.89)	to	(2.94)
	2017	104.959		to	16.408		338,900	34,720,453		1.17		1.40	to	1.45	20.03	to	19.97
	2016	87.443		to	13.677		394,846	33,488,341		1.32		1.40	to	1.45	8.29	to	8.24
Pioneer High Yield VCT Class II
	2020	18.807		to	18.359		81,880	1,534,871		5.16		1.40	to	1.55	0.56	to	0.41
	2019	18.702		to	18.284		93,705	1,747,072		4.66		1.40	to	1.55	12.70	to	12.54
	2018	16.594		to	16.247		111,243	1,841,312		4.46		1.40	to	1.55	(5.30)	to	(5.44)
	2017	17.522		to	17.181		120,616	2,108,996		4.32		1.40	to	1.55	5.54	to	5.38
	2016	16.602		to	16.304		149,584	2,479,504		4.68		1.40	to	1.55	12.22	to	12.05
Pioneer Mid Cap Value VCT Class I
	2020	45.699		to	18.012		116,844	5,158,869		1.22		1.40	to	1.45	0.72	to	0.67
	2019	45.374		to	17.893		126,231	5,548,133		1.31		1.40	to	1.45	26.65	to	26.59
	2018	35.825		to	14.135		139,761	4,865,357		0.71		1.40	to	1.45	(20.47)	to	(20.51)
	2017	45.046		to	17.781		157,830	6,918,762		0.85		1.40	to	1.45	11.60	to	11.54
	2016	40.362		to	15.941		176,687	6,901,170		0.75		1.40	to	1.45	14.94	to	14.89
Pioneer Real Estate VCT Class II
	2020	17.745		to	17.358		93,143	1,651,463		1.51		1.40	to	1.55	(8.91)	to	(9.04)
	2019	19.480		to	19.084		113,134	2,201,174		1.88		1.40	to	1.55	26.13	to	25.94
	2018	15.444		to	15.153		148,855	2,296,454		2.40		1.40	to	1.55	(8.83)	to	(8.97)
	2017	16.940		to	16.646		179,016	3,029,533		2.22		1.40	to	1.55	1.87	to	1.72
	2016	16.629		to	16.365		248,614	4,131,372		3.12		1.40	to	1.55	4.35	to	4.20
Pioneer Select Mid Cap Growth VCT Class I
	2020	171.479		to	40.029		281,608	46,843,906		—		1.40	to	1.45	37.24	to	37.17
	2019	124.951		to	29.182		311,821	37,590,076		—		1.40	to	1.45	31.23	to	31.17
	2018	95.214		to	22.248		348,337	31,681,425		—		1.40	to	1.45	(7.79)	to	(7.84)
	2017	103.257		to	24.140		384,221	37,965,371		0.08		1.40	to	1.45	28.23	to	28.17
	2016	80.527		to	18.835		443,583	33,709,555		—		1.40	to	1.45	2.30	to	2.25
Pioneer Strategic Income VCT Class II
	2020	17.962		to	17.534		215,812	3,866,009		3.27		1.40	to	1.55	5.88	to	5.72
	2019	16.964		to	16.585		265,034	4,485,610		3.10		1.40	to	1.55	8.00	to	7.83
	2018	15.708		to	15.380		341,648	5,355,627		3.01		1.40	to	1.55	(3.31)	to	(3.45)
	2017	16.245		to	15.929		412,715	6,693,898		3.36		1.40	to	1.55	3.30	to	3.14
	2016	15.726		to	15.444		563,318	8,847,652		3.26		1.40	to	1.55	5.85	to	5.69

47

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Templeton Developing Markets VIP Fund - Class 2
	2020	$	30.717	to	$	27.407	57,398	$	1,765,879	4.16	%	1.40%	to	1.55%	15.56	to	15.38%
	2019	26.582		to	23.753		64,093	1,707,234		1.03		1.40	to	1.55	24.93	to	24.75
	2018	21.277		to	19.041		76,619	1,633,271		0.87		1.40	to	1.55	(16.97)	to	(17.10)
	2017	25.626		to	22.968		90,501	2,324,483		0.89		1.40	to	1.55	38.46	to	38.25
	2016	18.508		to	16.613		105,478	1,957,855		0.83		1.40	to	1.55	15.81	to	15.64
Templeton Global Bond VIP Fund - Class 2
	2020	16.760		to	15.866		185,962	3,108,252		8.60		1.40	to	1.75	(6.60)	to	(6.92)
	2019	17.944		to	17.046		212,223	3,799,281		7.15		1.40	to	1.75	0.59	to	0.24
	2018	17.838		to	17.005		256,494	4,565,851		—		1.40	to	1.75	0.51	to	0.16
	2017	17.747		to	16.977		284,071	5,032,415		—		1.40	to	1.75	0.51	to	0.16
	2016	17.657		to	16.950		396,355	6,988,032		—		1.40	to	1.75	1.51	to	1.16
Templeton Growth VIP Fund - Class 2
	2020	18.827		to	17.414		177,612	3,343,134		2.97		1.40	to	1.55	4.33	to	4.18
	2019	18.045		to	16.716		199,177	3,593,620		2.82		1.40	to	1.55	13.55	to	13.38
	2018	15.892		to	14.743		229,921	3,653,293		1.98		1.40	to	1.55	(16.04)	to	(16.17)
	2017	18.928		to	17.586		253,711	4,801,519		1.55		1.40	to	1.55	16.86	to	16.68
	2016	16.197		to	15.072		353,553	5,725,468		2.00		1.40	to	1.55	8.10	to	7.94
Vanguard Balanced
	2020	23.242		to	24.110		10,556	242,810		2.94		1.20	to	1.50	9.36	to	9.04
	2019	21.253		to	22.112		12,320	258,951		3.32		1.20	to	1.50	21.02	to	20.66
	2018	17.561		to	18.326		28,731	499,157		2.51		1.20	to	1.50	(4.56)	to	(4.85)
	2017	18.401		to	19.261		35,887	653,604		2.62		1.20	to	1.50	13.35	to	13.01
	2016	16.234		to	17.043		44,501	714,626		2.68		1.20	to	1.50	9.70	to	9.36
Vanguard High Yield Bond
	2020	19.033		to	18.015		32,504	593,351		1.96		1.10	to	1.50	4.51	to	4.10
	2019	18.211		to	17.305		68,349	1,190,013		4.87		1.10	to	1.50	14.41	to	13.95
	2018	15.917		to	15.186		54,938	842,797		4.76		1.10	to	1.50	(3.80)	to	(4.19)
	2017	16.546		to	15.850		105,447	1,684,990		4.79		1.10	to	1.50	5.84	to	5.41
	2016	15.633		to	15.036		107,266	1,626,065		2.63		1.10	to	1.50	10.14	to	9.70
Vanguard International
	2020	25.886		to	30.478		70,949	1,804,092		1.19		1.00	to	1.50	56.01	to	55.24
	2019	16.592		to	19.633		82,229	1,342,700		1.51		1.00	to	1.50	29.91	to	29.27
	2018	12.772		to	15.188		134,584	1,697,455		0.82		1.00	to	1.50	(13.49)	to	(13.92)
	2017	14.763		to	17.645		172,583	2,516,688		1.06		1.00	to	1.50	41.26	to	40.55
	2016	10.451		to	12.554		190,945	1,968,715		1.44		1.00	to	1.50	0.87	to	0.37
Vanguard Mid-Cap Index
	2020	26.428		to	35.082		45,834	1,171,792		1.48		1.00	to	1.50	16.90	to	16.31
	2019	22.608		to	30.162		52,321	1,147,514		1.52		1.00	to	1.50	29.57	to	28.92
	2018	17.448		to	23.395		78,447	1,337,353		1.27		1.00	to	1.50	(10.24)	to	(10.69)
	2017	19.438		to	26.194		96,529	1,833,665		1.24		1.00	to	1.50	17.90	to	17.31
	2016	16.487		to	22.329		121,741	1,960,856		1.40		1.00	to	1.50	10.01	to	9.47

48

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

		As of December 31,								For the Year Ended December 31,
Sub-account	Year Ended	Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Units Outstanding	Net Assets		Net Investment Income Ratio2		Expense Ratio Lowest to Highest3			Total Return Corresponding to Lowest to Highest Expense Ratio4
Vanguard Real Estate Index
	2020	$	16.446	to	$	25.318	16,358	$	262,741	2.63	%	1.10%	to	1.50%	(5.90)	to	(6.27)%
	2019	17.477		to	27.012		17,268	295,127		2.76		1.10	to	1.50	27.40	to	26.89
	2018	13.718		to	21.288		25,750	346,791		3.36		1.10	to	1.50	(6.39)	to	(6.77)
	2017	14.655		to	22.833		35,804	515,771		2.69		1.10	to	1.50	3.63	to	3.22
	2016	14.141		to	22.121		54,962	763,361		2.60		1.10	to	1.50	7.17	to	6.75
Vanguard Total Bond Market Index
	2020	15.782		to	12.874		59,772	914,655		2.39		1.00	to	1.50	6.51	to	5.98
	2019	14.817		to	12.148		65,608	945,278		2.81		1.00	to	1.50	7.60	to	7.06
	2018	13.771		to	11.347		123,390	1,661,392		2.59		1.00	to	1.50	(1.13)	to	(1.62)
	2017	13.928		to	11.534		167,721	2,286,926		2.40		1.00	to	1.50	2.45	to	1.94
	2016	13.595		to	11.314		216,044	2,880,345		2.46		1.00	to	1.50	1.46	to	0.95
Vanguard Total Stock Market Index
	2020	28.146		to	36.038		118,403	3,285,582		1.56		1.00	to	1.50	19.35	to	18.76
	2019	23.582		to	30.345		134,801	3,140,220		1.71		1.00	to	1.50	29.45	to	28.80
	2018	18.217		to	23.559		262,577	4,731,419		1.67		1.00	to	1.50	(6.29)	to	(6.76)
	2017	19.439		to	25.266		352,769	6,777,304		1.91		1.00	to	1.50	19.77	to	19.17
	2016	16.230		to	21.201		382,135	6,115,244		1.47		1.00	to	1.50	11.44	to	10.88
Voya Global High Dividend Low Volatility Portfolio - Class S1
	2020	37.707		to	32.041		11,944	447,805		2.26		1.40	to	1.45	(2.47)	to	(2.52)
	2019	38.661		to	32.868		13,909	535,053		2.54		1.40	to	1.45	19.73	to	19.66
	2018	32.291		to	27.467		14,899	478,856		4.49		1.40	to	1.45	(10.38)	to	(10.43)
	2017	36.033		to	30.665		15,714	563,733		2.09		1.40	to	1.45	21.73	to	21.67
	2016	29.601		to	25.204		16,988	500,767		2.70		1.40	to	1.45	4.29	to	4.24
VY JPMorgan Emerging Markets Equity Portfolio Initial
	2020	43.617		to	43.617		15,820	690,009		0.60		1.40	to	1.40	31.88	to	31.88
	2019	33.072		to	33.072		17,297	572,062		0.14		1.40	to	1.40	30.28	to	30.28
	2018	25.386		to	25.386		17,941	455,452		0.85		1.40	to	1.40	(17.75)	to	(17.75)
	2017	30.865		to	30.865		18,307	565,043		0.67		1.40	to	1.40	41.38	to	41.38
	2016	21.832		to	21.832		20,384	445,068		1.48		1.40	to	1.40	11.69	to	11.69
Wanger USA
	2020	143.206		to	143.206		464	66,449		—		1.40	to	1.40	22.50	to	22.50
	2019	116.901		to	116.901		952	111,253		0.26		1.40	to	1.40	29.28	to	29.28
	2018	90.425		to	90.425		967	87,471		0.09		1.40	to	1.40	(2.84)	to	(2.84)
	2017	93.067		to	93.067		1,173	109,161		—		1.40	to	1.40	17.92	to	17.92
	2016	78.921		to	78.921		1,191	93,995		—		1.40	to	1.40	12.11	to	12.11

1 Reference Note 1 of the financial statements for additional information pertaining to this sub-account.

2These amounts represent the dividends, excluding distributions of capital gains, received by the sub-account from the underlying Mutual Fund, net of management fees assessed by the Mutual Fund manager, divided by the trading days average net assets. These ratios exclude those expenses, such as mortality and expense risk charges, that result in direct reductions in the Unit values. The recognition of investment income by the sub-account is affected by the timing of the declaration of dividends by the underlying Mutual Fund in which the sub-accounts invest.

49

Symetra Separate Account C

Notes to Financial Statements

6. ACCUMULATION UNIT VALUES (Continued)

3These amounts represent the annualized contract expenses of the Separate Account, consisting primarily of mortality and expense risk charges, for the 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 Mutual Fund are excluded.

4These amounts represent the total return for the periods indicated, including changes in the value of the underlying Mutual Funds, and reflect deductions for all items included in the expense ratio with the exception of Mutual Fund reorganization. Mutual Funds that have reorganized during the year present information through the time of the reorganization. The total return ratio does not include any expenses assessed through the redemption of Units; inclusion of these expenses in the calculation would result in a reduction in the total return presented. The total return is calculated for the period indicated or from the effective commencement date through the end of the reporting period.

50

Symetra Separate Account C

Notes to Financial Statements

7.SUBSEQUENT EVENTS

The Separate Account has evaluated subsequent events through April 23, 2021, the date which the Separate Account’s financial statements were available to be issued.

51

SYMETRA LIFE INSURANCE COMPANY

FINANCIAL STATEMENTS – STATUTORY BASIS

Contents
Report of Independent Auditors	1
Report of Ernst & Young LLP, Independent Auditors	3
Financial Statements
Balance Sheets – Statutory Basis	4
Statements of Operations – Statutory Basis	5
Statements of Changes in Capital and Surplus – Statutory Basis	6
Statements of Cash Flow – Statutory Basis	7
Notes to Financial Statements – Statutory Basis	8

52

Independent Auditors' Report

The Board of Directors and Stockholder

Symetra Life Insurance Company:

We have audited the accompanying financial statements of Symetra Life Insurance Company (the Company), which comprise the balance sheet – statutory basis as of December 31, 2020, and the related statements of operations – statutory basis, changes in capital and surplus – statutory basis, and cash flow – statutory basis for the year then ended, and the related notes to the financial statements - statutory basis.

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in accordance with statutory accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa. Management is also responsible for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditors’ Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit 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 from 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 auditors’ 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 opinion.

Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles

As described in Note 2 to the financial statements, the financial statements are prepared by the Company using statutory accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa, which is a basis of accounting other than U.S. generally accepted accounting principles. Accordingly, the financial statements are not intended to be presented in accordance with U.S. generally accepted accounting principles.

The effects on the financial statements of the variances between the statutory accounting practices and U.S. generally accepted accounting principles also are described in Note 2.

Adverse Opinion on U.S. Generally Accepted Accounting Principles

In our opinion, because of the significance of the variances between statutory accounting practices and U.S. generally accepted accounting principles discussed in the Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles paragraph, the financial statements referred to above do not present fairly, in accordance with U.S. generally accepted accounting principles, the financial position of Symetra Life Insurance Company as of December 31, 2020, or the results of its operations or its cash flows for the year then ended.

Opinion on Statutory Basis of Accounting

In our opinion, the financial statements referred to above present fairly, in all material respects, the admitted assets, liabilities, and surplus of Symetra Life Insurance Company as of December 31, 2020, and the results of its operations and its cash flow for the year then ended, in accordance with statutory accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa described in Note 2.

1

Emphasis of Matter

As discussed in Note 2 to the financial statements, in 2020, the Company adopted Iowa Administrative Code 191-97 which allows an alternative accounting treatment for eligible derivative assets and reserves for indexed annuity products. Our opinion is not modified with respect to this matter.

Other Matter

The accompanying financial statements of the Company as of December 31, 2019 and for the years ended December 31, 2019 and 2018 were audited by other auditors whose report thereon, dated March 26, 2020, expressed an adverse opinion on those financial statements with respect to U.S. generally accepted accounting principles and an unmodified opinion with respect to statutory accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa.

/s/ KPMG LLP

Seattle, Washington

March 25, 2021

2

Report of Ernst & Young LLP, Independent Auditors

To the Stockholder and Board of Directors of Symetra Life Insurance Company

We have audited the accompanying statutory-basis financial statements of Symetra Life Insurance Company (the Company), which comprise the balance sheet as of December 31, 2019, and the related statements of operations, changes in capital and surplus and cash flow for each of the two years in the period ended December 31, 2019, and the related notes to the financial statements.

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in conformity with accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa. Management also is responsible for the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free of material misstatement, whether due to fraud or error.

Auditor’s Responsibility

Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits in accordance with auditing standards generally accepted in the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.

Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles

As described in Note 2 to the statutory-basis financial statements, the Company prepared these financial statements using accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa, 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 2.

Adverse Opinion on U.S. Generally Accepted Accounting Principles

In our opinion, because of the significance of the matter described in the Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles paragraph, the statutory-basis financial statements referred to above do not present fairly, in conformity with U.S. generally accepted accounting principles, the financial position of the Company at December 31, 2019, or the results of its operations or its cash flows for each of the two years in the period ended December 31, 2019.

Opinion on Statutory-Basis of Accounting

In our opinion, the statutory-basis financial statements referred to above present fairly, in all material respects, the financial position of the Company at December 31, 2019, and the results of its operations and its cash flows for each of the two years in the period ended December 31, 2019, on the basis of accounting described in Note 2.

/s/ Ernst & Young LLP

Seattle, Washington

March 26, 2020

3

SYMETRA LIFE INSURANCE COMPANY

BALANCE SHEETS – STATUTORY BASIS

(In millions, except share and per share data)

	As of December 31,
	2020		2019
ADMITTED ASSETS
Bonds	$	28,488.9	$	27,312.3
Preferred stocks	102.6		108.0
Common stocks	333.6		345.5
Mortgage loans	6,440.1		6,238.0
Cash and cash equivalents	1,025.6		612.4
Derivatives	243.1		464.9
Other invested assets	534.6		470.2
Total cash and invested assets	37,168.5		35,551.3
Accrued investment income	269.3		281.4
Deferred and uncollected premiums (net of loading of $(12.6) and $(13.6), respectively)	(35.1)		(40.2)
Deferred tax assets, net	110.9		112.8
Current federal income taxes recoverable	8.9		24.2
Other receivables	225.1		255.8
Separate account assets	6,515.8		6,056.6
Total admitted assets	$	44,263.4	$	42,241.9
LIABILITIES AND CAPITAL AND SURPLUS
Life and annuity reserves	$	29,328.8	$	28,275.5
Accident and health reserves	197.6		168.7
Policy and contract claims	189.4		161.6
Liability for deposit-type contracts	3,436.4		3,153.0
Unearned premiums and annuity considerations	4.7		3.4
Total policy and contract liabilities	33,156.9		31,762.2
Cash collateral held	504.0		478.1
Asset valuation reserve	386.4		351.1
Interest maintenance reserve	330.9		218.9
Funds held under coinsurance agreements	795.9		751.4
Other liabilities	434.0		627.8
Separate account liabilities	6,339.2		5,910.8
Total liabilities	41,947.3		40,100.3
Commitments and contingencies (Note 14)
Common stock, $250 par value, 20,000 shares authorized, issued and outstanding	5.0		5.0
Gross paid-in and contributed surplus	964.0		664.0
Unassigned funds	1,347.1		1,472.6
Total capital and surplus	2,316.1		2,141.6
Total liabilities and capital and surplus	$	44,263.4	$	42,241.9

See accompanying notes.

4

SYMETRA LIFE INSURANCE COMPANY

STATEMENTS OF OPERATIONS – STATUTORY BASIS

(In millions)

	For the Year Ended December 31,
	2020		2019		2018
Premiums and other revenues:
Premiums and annuity considerations	$	4,234.0	$	4,138.5	$	268.7
Net investment income	1,105.5		1,331.8		1,260.2
Amortization of interest maintenance reserve	40.2		26.5		13.7
Separate account fees and other	105.5		84.8		73.8
Commissions and expense allowances on reinsurance ceded, net	52.1		56.4		(249.0)
Reserve adjustment on reinsurance ceded	(39.8)		(21.2)		3,976.8
Other income	24.9		26.8		26.4
Total premiums and other revenues	5,522.4		5,643.6		5,370.6
Benefits:
Death benefits	284.3		229.6		234.6
Annuity benefits	353.0		349.1		342.6
Surrender and maturity benefits	2,532.5		2,210.8		2,252.5
Accident and health and other benefits	558.5		534.5		676.1
Increase in policy reserves	1,253.3		1,575.5		1,287.7
Total benefits	4,981.6		4,899.5		4,793.5
Insurance expenses and other deductions:
Commissions	358.6		345.6		320.4
General insurance expenses	477.5		464.2		418.9
Net transfers to (from) separate accounts	96.4		69.8		(34.3)
Total insurance expenses and other deductions	932.5		879.6		705.0
Gain (loss) from operations before federal income taxes and net realized capital gains (losses)	(391.7)		(135.5)		(127.9)
Federal income tax expense (benefit)	(125.8)		(69.5)		(12.4)
Gain (loss) from operations before net realized capital gains (losses)	(265.9)		(66.0)		(115.5)
Net realized capital gains (losses) (net of federal income taxes and transfer to interest maintenance reserve)	206.1		236.6		(3.2)
Net income (loss)	$	(59.8)	$	170.6	$	(118.7)

See accompanying notes.

5

SYMETRA LIFE INSURANCE COMPANY

STATEMENTS OF CHANGES IN CAPITAL AND SURPLUS – STATUTORY BASIS

(In millions)

	Common Stock		Gross Paid-In and Contributed Surplus		Unassigned Funds		Total Capital and Surplus
Balances as of January 1, 2018	$	5.0	$	664.0	$	1,549.9	$	2,218.9
Net income (loss)	—		—		(118.7)		(118.7)
Change in net unrealized capital gains (losses), including foreign exchange	—		—		(145.0)		(145.0)
Change in net deferred income taxes	—		—		53.7		53.7
Change in nonadmitted assets	—		—		1.6		1.6
Change in liability for unauthorized reinsurance	—		—		0.1		0.1
Change in reserve on account of change in valuation basis	—		—		0.6		0.6
Change in asset valuation reserve	—		—		104.4		104.4
Change in surplus as a result of reinsurance	—		—		61.0		61.0
Dividends to Parent	—		—		(50.0)		(50.0)
Balances as of December 31, 2018	5.0		664.0		1,457.6		2,126.6
Net income	—		—		170.6		170.6
Change in net unrealized capital gains (losses), including foreign exchange	—		—		4.9		4.9
Change in net deferred income taxes	—		—		1.3		1.3
Change in nonadmitted assets	—		—		(34.5)		(34.5)
Change in liability for unauthorized reinsurance	—		—		4.4		4.4
Change in reserve on account of change in valuation basis	—		—		(20.1)		(20.1)
Change in asset valuation reserve	—		—		(117.4)		(117.4)
Cumulative effect on change in accounting principle	—		—		5.8		5.8
Balances as of December 31, 2019	5.0		664.0		1,472.6		2,141.6
Net income (loss)	—		—		(59.8)		(59.8)
Change in net unrealized capital gains (losses), including foreign exchange	—		—		28.8		28.8
Change in net deferred income taxes	—		—		7.2		7.2
Change in nonadmitted assets	—		—		(20.0)		(20.0)
Change in reserve on account of change in valuation basis	—		—		(16.4)		(16.4)
Change in asset valuation reserve	—		—		(35.2)		(35.2)
Change in surplus in separate accounts	—		—		0.5		0.5
Cumulative effect on change in accounting principle	—		—		(30.6)		(30.6)
Capital contribution from Parent	—		300.0		—		300.0
Balances as of December 31, 2020	$	5.0	$	964.0	$	1,347.1	$	2,316.1

See accompanying notes.

6

SYMETRA LIFE INSURANCE COMPANY

STATEMENTS OF CASH FLOW – STATUTORY BASIS

(In millions)

	For the Year Ended December 31,
	2020		2019		2018
Cash flows from operating activities
Premiums and annuity considerations collected	$	4,214.4	$	4,425.2	$	4,621.2
Net investment income received	1,443.3		1,411.7		1,338.8
Commissions and expense allowance on reinsurance ceded	49.7		38.3		(249.0)
Other income	80.8		118.9		85.9
Net transfers (to) from separate accounts	(83.0)		(70.2)		31.9
Benefits and loss-related payments	(3,908.9)		(3,476.0)		(3,482.0)
Commissions, other expenses, and taxes paid	(799.6)		(763.3)		(712.3)
Federal income taxes received (paid)	28.4		(1.8)		23.4
Net cash provided by operating activities	1,025.1		1,682.8		1,657.9
Cash flows from investing activities
Proceeds from investments sold, matured, or repaid:
Bonds	4,411.7		5,189.3		4,768.3
Mortgage loans	473.2		513.1		538.0
Other invested assets	480.5		331.5		1,208.5
Cost of investments acquired:
Bonds	(5,478.8)		(7,748.2)		(6,724.2)
Mortgage loans	(675.3)		(1,064.5)		(741.9)
Other invested assets	(665.9)		(150.8)		(577.2)
Other, net	(12.7)		0.7		4.4
Net cash used in investing activities	(1,467.3)		(2,928.9)		(1,524.1)
Cash flows from financing activities
Capital contribution from Parent	300.0		—		—
Net deposits (withdrawals) on deposit-type contracts and other insurance liabilities	280.0		1,309.9		(40.0)
Net receipts from (transfers to) Parent, subsidiaries, and affiliates	25.9		(25.0)		2.1
Dividends to Parent	—		—		(50.0)
Other, net	249.5		350.5		(135.1)
Net cash provided by (used in) financing activities	855.4		1,635.4		(223.0)
Net increase (decrease) in cash	413.2		389.3		(89.2)
Cash, beginning of year	612.4		223.1		312.3
Cash, end of year	$	1,025.6	$	612.4	$	223.1

	For the Year Ended December 31,
	2020		2019		2018
Supplemental disclosures of cash flow information
Non-cash transactions during the year:
Amortization of option costs under Iowa Administrative Code 191-97	$	231.8	$	—	$	—
Mortgage loans – refinances	74.8		31.1		44.9
Bonds and stock exchanges	2.4		232.0		1,307.3
Initial premium ceded on reinsurance transactions	—		208.6		4,348.0
Initial funds withheld balance	—		208.6		289.9
Initial commission related to funds withheld reinsurance agreement	—		—		47.8

See accompanying notes.

7

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

1. Description of Business

Symetra Life Insurance Company (the Company) is a stock life insurance company domiciled in the state of Iowa, and a wholly-owned subsidiary of Symetra Financial Corporation (the Parent), a Delaware Corporation. The Company has three wholly-owned subsidiaries: Symetra National Life Insurance Company, First Symetra National Life Insurance Company of New York, and Symetra Reinsurance Corporation. The Company's parent is a wholly-owned subsidiary of Sumitomo Life Insurance Company, a mutual company (sougo kaisha) organized under the laws of Japan.

The Company offers products and services that serve the retirement, employment-based benefits, and life insurance markets. These products and services are marketed through financial institutions, broker-dealers, financial professionals, independent agents, and benefits consultants in 49 states and the District of Columbia. The Company’s principal products include fixed deferred annuities and fixed indexed annuities (FIA), registered index-linked annuities (RILA), single premium immediate annuities (SPIA), medical stop-loss insurance, group life and disability income (DI) insurance, absence management, group voluntary benefits (accident, critical illness, hospital indemnity) and group fixed-payment medical insurance, term life insurance, universal life insurance, including indexed universal life insurance (IUL), and institutional life insurance, including bank-owned life insurance (BOLI) and variable corporate owned life insurance (COLI).

Modco Reinsurance Transaction

In September 2018, the Company, entered into a 100% modified coinsurance agreement with Resolution Re Ltd. (the Modco Reinsurance Transaction) for the Company's in-force block of income annuities, which included all of the Company's structured settlement annuities, and a smaller amount of retail SPIA. The transaction reduced the Company's exposure to long-term interest rate risk associated with the long-tailed nature of the reinsured business.

The Company discontinued selling structured settlements in 2012. Retail SPIA policies issued after September 30, 2017 were not included in this agreement and the Company continues to sell these products as part of its retirement product offerings.

Under terms of the agreement, the Company continues to service the reinsured business and hold the associated invested assets and policyholder liabilities on its balance sheets. Resolution Re Ltd. is responsible for asset management, other than mortgage loans, subject to investment management guidelines. Refer to Note 7 for further discussion.

2. Summary of Significant Accounting Policies

Basis of Presentation and Use of Estimates

The financial statements have been prepared in conformity with statutory accounting practices prescribed or permitted by the Insurance Division, Department of Commerce of the State of Iowa (the Department). Companies domiciled in the state of Iowa prepare their statutory-basis financial statements in accordance with the National Association of Insurance Commissioners’ (NAIC) Accounting Practices and Procedures Manual, subject to any deviations prescribed or permitted by the Department.

Under Iowa Bulletin 07-06, the Department allows insurance companies with approval from the commissioner to use other than market value for assets held in a separate account where general account guarantees are present. The Company, with explicit permission from the Department, is permitted to account for the separate account assets related to its BOLI and RILA business at other than market value. The assets of the BOLI and RILA separate accounts primarily include bonds and commercial mortgage loans that are accounted for in accordance with the guidance otherwise applicable to these assets. Therefore, there is no impact to net income or surplus.

Under Iowa Bulletin 06-01, the Department allows insurance companies to record the change in the fair value of derivative instruments used to economically hedge indexed products in income, consistent with how the change in indexed product reserves is recorded. The Company uses this election for its IUL and RILA products, and for its FIA products prior to 2020. This election has no net impact on surplus.

Under Iowa Administrative Code (IAC) 191-97, the Department allows companies to account for eligible derivative assets using the amortized cost method if the company can demonstrate they meet the criteria for an economic hedge. Furthermore, IAC 191-97 also prescribes the use of a reserve calculation methodology for indexed annuity products that only reflects credited interest on reserves at the conclusion of the index term based on actual index performance. The Company elected to adopt IAC 191-97 effective January 1, 2020, and uses this election for its FIA products. Upon adoption, this election resulted in a net $30.6 reduction in surplus.

Effective January 1, 2020, the Company received explicit permission from the Department to record the change in fair value of equity and equity-type investments held in a segregated portfolio through the statements of operations instead of surplus. The segregated portfolio includes investments supporting a block of structured settlement annuities in connection with the Modco

8

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Reinsurance Transaction. The change in the fair value of these assets is passed to the reinsurer quarterly in accordance with the reinsurance agreement. Prior to January 1, 2020, this created a mismatch between income and surplus which, in turn, resulted in volatility in income. This permitted practice was adopted prospectively and the adoption had no impact on surplus.

The state of Iowa has adopted a prescribed accounting practice that differs from that found in the NAIC statutory accounting principles (SAP) related to the admission of a variable funding note as capital and surplus. Symetra Reinsurance Corporation, a wholly-owned subsidiary of the Company, is entitled to admit as an asset, the value of a variable funding note in conjunction with a reinsurance agreement with the Company. There was no impact to net income. If the Company had not used this prescribed practice, the result would not have triggered a regulatory event at the Company. SRC's statutory surplus under the prescribed practice from the state of Iowa was $29.6 and $13.3 as of December 31, 2020 and 2019. SRC's statutory deficit would have been $27.2 and $43.6 as of December 31, 2020 and 2019 under the SAP.

The impact of the practices described above are summarized as follows:

	For the Year Ended December 31,
	2020		2019		2018
Net income (loss) – Iowa basis	$	(59.8)	$	170.6	$	(118.7)
State prescribed practices:
Iowa Bulletin 06-01	(8.7)		(276.5)		246.0
IAC 191-97 – options	8.0		—		—
IAC 191-97 – reserves	6.5		—		—
State permitted practices:
Equity-type investments	(29.1)		—		—
Net income (loss) – NAIC basis	$	(83.2)	$	(105.9)	$	127.3

	As of December 31,
	2020		2019
Statutory surplus – Iowa basis	$	2,316.1	$	2,141.6
State prescribed practices:
Variable funding note	(56.8)		(57.0)
IAC 191-97 – options	223.4		—
IAC 191-97 – reserves	(181.0)		—
Statutory surplus – NAIC basis	$	2,301.7	$	2,084.6

The preparation of financial statements in conformity with SAP requires the Company to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. The most significant estimates include those used to determine the following: policy and contract liabilities; the identification and measurement of other-than-temporary impairments (OTTI) of investments; and the admissibility of deferred tax assets (DTAs). The recorded amounts reflect management’s best estimates, though actual results could differ from those estimates. Such estimates and assumptions could change in the future as more information becomes available, which could impact the amounts reported and disclosed herein.

Certain reclassifications have been made to prior year financial information to conform to the current period presentation.

The Company continues to actively monitor the current impacts of and response to the Coronavirus Disease 2019 (COVID-19) pandemic and its related risks, and to plan accordingly. Measures taken by the United States to combat the virus led to economic uncertainty and market volatility that may adversely impact the Company's results of operations or financial condition. There is considerable uncertainty regarding to the continued development of the COVID-19 pandemic, including the severity, duration, and frequency of additional waves of the pandemic, the timetable for complete vaccination, and the effectiveness of the vaccines, including their effectiveness with respect to variants of the virus that have emerged or could emerge in the future. Therefore, the Company is unable to reasonably estimate the full extent of the impact at this time. The Company has implemented risk management and business continuity plans, and continue to take preventive measures and other precautions related to the COVID-19 pandemic.

Statutory accounting practices are different in some respects from financial statements prepared in accordance with U.S. generally accepted accounting principles (GAAP). Below is a description of the Company’s significant accounting policies, including the significant variances from GAAP. In 2016, the Company's Parent became a wholly-owned subsidiary of Sumitomo Life Insurance Company, an event which is referred to as the Merger. The Merger was accounted for under the acquisition method of accounting (purchase accounting, or PGAAP). In addition to the differences described, the Company's GAAP-basis

9

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

financial results are also affected by the application of PGAAP, which results in further differences between GAAP and Statutory-basis accounting.

Accounting Pronouncements Newly Adopted

In 2016, the NAIC adopted substantive revisions to SSAP No. 51, Life Contracts to reflect the introduction of Principles Based Reserving (PBR) as an allowable method for reserving. Under PBR, companies hold the higher of a) the reserve using prescribed factors and b) the reserve computed using justified company experience factors, such as mortality, policyholder behavior and expenses, and considering a wide range of future economic conditions. PBR was phased in over a three-year period that began in 2017, with mandatory adoption for policies issued on or after January 1, 2020.

The Company adopted the Valuation Manual Requirements for Principle Based Reserves on January 1, 2020 for the affected universal and term life business issued on January 1, 2020 and thereafter (VM-20). The adoption did not have any impact on the Company's financial statements. In 2020, the Company also adopted Valuation Manual Requirements for Principle Based Reserves for Variable Annuities (VM-21), which resulted in changes to Actuarial Guideline 43. This impacted the Company's variable and registered index-linked annuities written from 1981 to 2019. As a result of this adoption, the Company recorded a change in reserve valuation basis of $0.9 increase to surplus.

Recognition of Premiums and Annuity Considerations

Premiums for universal life policies (UL) and annuity considerations with mortality and morbidity risk are recognized as revenue when received. Premiums for traditional life policies are recognized annually on the policy anniversary, consistent with the statutory reserving process. Amounts received under deposit-type contracts with no life contingencies, including guaranteed interest annuity contracts, are recorded as liabilities when received.

Premiums for medical stop-loss policies, group life and DI policies, absence management, group voluntary benefits (accident, critical illness, hospital indemnity) and group fixed-payment medical insurance policies are recognized when due. Certain of these policies have retrospective rating features that require premium to be paid or refunded based on claims experience. The Company records its estimate for retrospective premiums in accordance with the terms of each contract as an adjustment to earned premium. The following table presents the amount of net premiums subject to retrospective rating features, and its percentage of total net premiums written on the Company's group health business:

	For the Year Ended December 31,
	2020				2019				2018
	Amount		%		Amount		%		Amount		%
Net premiums subject to retrospective rating features	$	197.1	30.5	%	$	286.0	48.3	%	$	274.7	33.4	%

Approximately 61% of 2020 premiums were from fixed deferred annuities and FIA, 11% were from were from UL insurance, 11% were from medical stop-loss insurance. No other products represented more than 10% of premiums. Two financial institutions accounted for approximately 40% of the Company’s total fixed deferred annuities and FIA sales for the year ended December 31, 2020. Fixed deferred annuities and FIA sales represent premiums on new policies, net of first year policy lapses and/or surrenders.

Under GAAP, amounts received for UL policies and annuity contracts are reflected as liabilities rather than revenue when received, while traditional life premiums are recognized as revenue and considered earned when due.

Policy Acquisition Costs

The costs of acquiring and renewing policies are expensed when incurred.

Under GAAP, the Company defers costs that are directly related to the successful acquisition or renewal of insurance contracts. These primarily include commissions, distribution costs directly related to sales, third-party underwriting costs, and the portion of salaries and benefits directly related to processing successful new and renewal contracts. The Company amortizes acquisition costs over the lives of the contracts or policies. Additionally, in conjunction with the Merger, the Company recorded an asset that represented the right to receive future gross profits from cash flows and earnings of the Company's existing business, or value of business acquired (VOBA). The Company amortizes VOBA in the same manner as policy acquisition costs.

10

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Investments

Bonds, Preferred Stocks, and Common Stocks

The Company carries bonds at amortized cost, using the scientific interest method of amortization. Loan-backed securities, including mortgage-backed securities, are stated at amortized cost, and income is recognized using a constant effective yield based on anticipated prepayments and the estimated economic life of the securities. Prepayment assumptions are based on current interest rates and the economic environment. When actual prepayments differ significantly from anticipated prepayments, the effective yield is recalculated to reflect actual payments to date and estimated future payments. The net investment in the security is adjusted to the amount that would have existed had the new effective yield been applied since the acquisition of the security (i.e. the retrospective method). For commercial mortgage-backed interest-only securities, the effective yield is adjusted prospectively for any changes in estimated cash flows. The Company includes any resulting adjustment in net investment income in the current period.

All bonds in or near default are carried at the lower of amortized cost or fair value.

Preferred stocks are carried at cost, amortized cost or fair value based on their NAIC designation. Preferred stocks designated as medium quality or better (designations 1–3) are carried at amortized cost. All other preferred stocks (designations 4–6) are carried at the lower of cost, amortized cost or fair value.

For those bonds and preferred stocks reported at fair value, the related change in net unrealized capital gains (losses) are recorded in unassigned funds, net of related deferred income taxes.

Unaffiliated common stocks are reported at fair value and the related net unrealized capital gains (losses) are recorded in unassigned funds, net of related deferred income taxes. Federal Home Loan Bank of Des Moines common stock are reported at cost, which is presumed to be fair value.

Under GAAP, the Company classifies its investments in fixed maturities (bonds, surplus notes, and redeemable preferred stocks) as available-for-sale or trading securities and carries them at fair value. For available-for-sale securities, unrealized gains (losses) are recorded directly to accumulated other comprehensive income (AOCI), net of related deferred acquisition costs (DAC), VOBA, deferred sales inducements (DSI) adjustments, and deferred income taxes. Changes in the fair value of trading securities are reported as realized gains (losses). The Company carries marketable equity securities (common stock) at fair value with changes in fair value reported as realized gains (losses).

The Company’s investments in its insurance subsidiaries are included in affiliated common stocks and are carried at their underlying statutory equity, which was $180.2 and $167.6 as of December 31, 2020 and 2019, respectively. Changes in the carrying value of subsidiaries are recorded directly to unassigned funds. The Company owns no shares, either directly or indirectly, of the Parent. Under GAAP, the accounts and operations of the subsidiaries are consolidated.

The Company reports interest and dividends earned, including prepayment fees or interest-related make whole payments, in net investment income. Interest income for bonds is recognized using the effective yield method. When the collectibility of interest income for bonds is considered doubtful, any accrued, but uncollectible interest is deducted from investment income in the current period. The Company then places the securities on nonaccrual status, and they are not restored to accrual status until all delinquent interest and principal is paid.

Investments are considered to be impaired when a decline in fair value below a security’s amortized cost is determined to be other-than-temporary. The Company’s review of investment securities for OTTI includes both quantitative and qualitative criteria, and for loan-backed and structured securities, may include identification of the portion related to credit losses. See Note 3 for additional discussion about the Company’s process for identifying and recording OTTI.

Under GAAP, a fixed maturity with fair value below its amortized costs but is not intended to be sold is evaluated to determine whether the decline in fair value has resulted from an expected credit loss or other factors (such as market interest rates). The amount of the expected credit loss equals the difference between amortized cost and recovery value of the security, and is limited by the amount that the fair value is less than the amortized cost basis. The expected credit loss is recorded as an allowance, with the initial recognition and subsequent changes recognized in earnings as a realized loss. Amounts determined uncollectible are written off as a reduction to the amortized cost and removed from the allowance. Any remaining non-credit related unrealized loss is recorded in AOCI.

11

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Mortgage Loans

The Company carries mortgage loans on real estate at outstanding principal balances less any recognized impairment. Loans are specifically evaluated for impairment if the Company considers it probable that amounts due according to the terms of the loan agreement will not be collected, or the loan is modified in a troubled debt restructuring. For mortgage loans that the Company determines to be impaired, the Company charges the difference between the estimated fair value of the collateral and the recorded investment in the mortgage loan as a realized investment loss.

The Company accrues interest income on impaired loans to the extent that it is deemed collectible and the loan continues to perform under its original or restructured terms. Accrued interest income that is over 180 days past due and collectible is reported as a nonadmitted asset. Interest income on non-performing loans, defined generally as those in default, close to being in default, or more than 90 days past due, is recognized upon receipt. Loan origination fees are recorded in income upon receipt and origination costs are expensed when incurred.

Under GAAP, a majority of mortgage loans are carried at outstanding principal balances, adjusted for unamortized deferred fees and costs, net of an allowance for expected credit losses. Loan origination fees and costs are deferred and amortized over the life of the loan. Mortgage loans supporting a block of structured settlement annuities in connection with the Modco Reinsurance Transaction are measured at fair value, with changes in fair value recorded in earnings as realized gains (losses).

In response to the COVID-19 pandemic, two relief bills were signed into law during 2020. On March 27, 2020, Congress enacted the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act provided a temporary suspension of troubled debt restructuring (TDR) accounting for certain COVID-19 related loan modifications through December 31, 2020. Under this provision, companies are not required to classify such loans as past due or nonaccrual during the payment deferral period. Additionally, the Consolidated Appropriations Act (CAA), enacted on December 27, 2020, provided an extension to the temporary suspension of TDR accounting under the CARES Act for an additional year. The NAIC's Statutory Accounting Principles Working Group adopted two interpretations extending the NAIC's accounting methodologies to allow companies to apply the provisions of the CARES Act and CAA for loans modified in relation to the COVID-19 pandemic. During the year ended December 31, 2020, no loans were accounted for under TDR accounting by the Company.

Cash and Cash Equivalents

Cash and cash equivalents are carried at cost, which approximates fair value and are consistent with GAAP. Cash equivalents consist of one money market fund. As of December 31, 2020, $553.5, or 98.9%, of total cash, and $465.8, or 100.0% of cash equivalents were held at one highly rated financial institution.

Derivatives

The Company uses derivative financial instruments to hedge certain portions of its exposure to equity market risk, interest rate risk, and foreign currency exchange risk. Derivative financial instruments currently held consist primarily of equity market contracts, interest rate swaps, and foreign currency swaps.

The accounting for changes in the fair value of derivative instruments depends on whether it qualifies and has been designated for hedge accounting. To qualify for hedge accounting treatment, a derivative must be highly effective in mitigating the designated risk of the hedged item. Effectiveness of the hedge is formally assessed at inception and throughout the life of the hedging relationship. Derivative instruments that qualify and are designated for hedge accounting are valued in a manner consistent with the items being hedged. Interest rate and foreign currency swaps qualify for hedge accounting and are recognized at amortized cost in the balance sheets. Periodic payments and receipts on these derivatives are recorded on an accrual basis within net investment income. Net realized capital gains (losses) are recognized upon termination or maturity of these contracts in a manner consistent with the hedged item, and when subject to the interest maintenance reserve (IMR), are transferred to the IMR, net of taxes.

Pursuant to the accounting elections discussed above, effective January 1, 2020, index options for FIA products are accounted for using the amortized cost method, where the cost is amortized through investment income on the statements of operations. Index options for IUL and RILA products are recorded at fair value, with changes in fair value recorded in realized gains (losses) on the statements of operations. Other derivatives that do not qualify, or are not designated for hedge accounting are recognized at fair value with changes in fair value recorded as net unrealized capital gains (losses) in unassigned funds on the balance sheets.

The maximum length of time over which the Company is hedging its exposure to the variability in future cash flows for forecasted transactions is 25 years, excluding those forecasted transactions related to the payment of variable interest on existing financial instruments.

Under GAAP, derivative instruments are recorded at fair value, and the accounting for changes in the fair value of derivative instruments are reported through earnings unless they qualify and are designated for hedge accounting. When a derivative is

12

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

designated as a cash flow hedge and is determined to be highly effective, changes in its fair value are recorded as a component of AOCI and reclassified into net income in the same period during which the hedged transaction affects net income.

Other Invested Assets

Other invested assets consist primarily of investments in alternative investments and tax credit investments. Tax credit investments are limited partnerships that are established to fund low-income housing projects and other qualifying purposes, where the primary return on investment is in the form of income tax credits.

Alternative investments consist of hedge funds held in a segregated portfolio supporting a block of structured settlement annuities in connection with the Modco Reinsurance Transaction. Pursuant to the accounting election discussed above, the changes in fair value of those alternative investments are recorded in net realized gains (losses) on the statements of operations. Prior to the election, changes in the fair value were recorded in net unrealized capital gains (losses) in surplus.

Tax credit investments are initially recorded at the present value of future contributions, which are considered unconditional and legally binding, and primarily consist of low-income housing tax credits (LIHTC) investments, and a smaller amount of historic and solar investments. Amortization of LIHTC is based on the proportion of tax benefits received in the current year to total estimated tax benefits to be allocated to the Company. Amortization of historic and solar tax credit investments is recorded over time as partnership gains and losses (pass through activity) are allocated to the Company. Write downs are recorded for historic and solar investments when the carrying value of the investment exceeds the present value of remaining benefits. LIHTC investments are written down in a similar manner, but only after it has been determined that future tax benefits will not be received as expected. Write downs are recorded in net realized capital gains (losses).

Under GAAP, tax credit investments are accounted for under the equity method. Typically, the investment is written down over time as partnership losses are allocated to the Company or when the carrying value of the investment exceeds the total amount of remaining benefits. Activity related to these investments is recorded in net realized gains (losses).

Net Realized Capital Gains (Losses)

Net realized capital gains (losses) are determined on a specific-identification basis.

Nonadmitted Assets

Certain assets designated as “nonadmitted” and other assets not specifically identified as an admitted asset are excluded from the balance sheets and are charged directly to unassigned funds. Nonadmitted assets are composed principally of certain uncollected premiums and agents’ balances, DTAs, accounts and notes receivable, and other assets. Under GAAP, such assets are included in the balance sheets to the extent the assets are recoverable.

Reinsurance

The Company accounts for reinsurance premiums, commissions, expense reimbursements, benefits, and reserves related to reinsured business consistent with those used in accounting for the original policies issued and the terms of the reinsurance contracts. Premiums, benefits, and the reserves for policy and contract liabilities are reported net of reinsured amounts. For modified coinsurance agreements, the Company retains the assets and reserves of the underlying business on the balance sheets. Activity related to modified coinsurance agreements is recorded net on the reserve adjustment on reinsurance ceded on the statements of operations. For coinsurance with funds withheld agreements, a funds withheld liability is established initially for the amount of reserves that were ceded. The reserves are remeasured each period and changes are recorded as an adjustment to the funds withheld liability on the balance sheets.

Initial gains on reinsurance of existing in-force blocks of business are recorded as an increase to surplus, net of federal income tax. This increase to surplus is amortized into income, net of tax, as profits are recognized on the underlying business.

Under GAAP, future policy benefit reserves and policy and contract claims liabilities are reported gross of any related reinsurance recoverables, which are reported as assets. Certain reinsurance contracts meeting risk transfer requirements under SAP have been accounted for using traditional reinsurance accounting; whereas, such contracts are accounted for using deposit accounting under GAAP. For modified coinsurance agreements that do not qualify for reinsurance accounting under GAAP, the Company establishes a deposit asset, representing ceded reserves, and funds withheld liability, representing the assets supporting ceded reserves. The Company also recognizes an embedded derivative related to the funds withheld assets.

Refer to Note 7 for further discussion.

13

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Benefit Reserves

Aggregate reserves for payment of future life, health, and annuity benefits are based on published tables in accordance with applicable actuarial standards. The reserves are at least as great as the minimum aggregate amounts required by the Department. Liabilities related to other policyholders' funds left on deposit are equal to the account balances. Surrender values on policies do not exceed the corresponding benefit reserves.

Additional reserves are established if the results of cash flow testing under various interest rate scenarios indicate the need for such reserves, or if the net premiums exceed the gross premiums on any insurance in-force. For substandard lives, either extra premium is charged or the gross premium for a rated age is charged; mean reserves are determined by computing the regular mean reserve for the plan at any rated age and, in addition, holding one-half of any extra premium charge for the year. The Company does not use anticipated investment income as a factor in its premium deficiency calculation.

Tabular interest, tabular reserves less actual reserves released, and tabular cost are determined by formula. Tabular interest on funds not involving life contingencies for each valuation rate of interest are calculated as the change in reserves minus premiums plus benefits.

The Company waives deduction of deferred fractional premiums upon the death of the insured and returns any premium beyond the date of death.

Reserves for deposit-type contracts that do not subject the Company to risks arising from policyholder mortality or morbidity are equal to deposits received and interest credited to the benefit of the contract holders, less surrenders or withdrawals that represent a return to the contract holders.

Under GAAP, policy reserves are calculated based on estimated expected experience or actual account balances. For traditional individual life policies, policy reserves are estimated as the present value of expected future policy benefits less future net premiums. For group long-term disability policies, policy reserves are estimated as the present value of future benefit payments, net of terminations and reinsurance recoverables. Liabilities for fixed deferred annuity contracts, and the fixed account portion of FIA and UL policies are equal to the account value without regard to any surrender fees. The liability for the indexed account portions of contracts with indexed or index-linked features (indexed products) represent the present value of future estimated guaranteed benefits, as well as embedded derivatives related to expected index credits on these contracts and policies. The embedded derivatives are recorded at fair value. Indexed products include FIA, RILA, and Indexed UL.

Policy and Contract Claims

Claims reserves on life, and accident and health policies represent the estimated ultimate cost of all reported and unreported claims, net of reinsurance, as of the balance sheet date. The reserves for reported but unpaid claims incurred are estimated using individual valuations and statistical analyses. The liability held for pending life insurance claims is equal to the face amount of the policy. The Company also provides for claims incurred but not reported (IBNR). For medical stop-loss policies, this is based on expected loss ratios, claims paying completion patterns, historical experience, and includes a provision for adverse deviation. The Company reviews estimates for reported but unpaid claims and IBNR quarterly. Any necessary adjustments are reflected on the statements of operations.

Under GAAP, the liability for pending claims for UL policies, including BOLI and variable COLI products, equals the net amount at risk, which is the face amount of the policy, less the account value. The IBNR claim liability does not include a provision for adverse deviation.

Asset Valuation Reserve

The asset valuation reserve (AVR) provides a valuation allowance for invested assets and is calculated based on a formula prescribed by the NAIC. This reserve acts to mitigate potential credit-related losses on invested assets. Changes in the AVR are reflected directly in unassigned funds. No such reserve exists under GAAP.

Interest Maintenance Reserve

The IMR defers after-tax realized capital gains (losses) resulting from the effect of changes in the general level of interest rates on the disposal or interest related impairment of bonds. These deferrals are based on a formula prescribed by the NAIC and are amortized into income over the approximate remaining life of the investment sold or impaired, using the grouped method. Under GAAP, realized investment gains (losses) from sales and impairments are reported in earnings in the period in which the assets are sold and no such reserve is recorded.

14

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Federal Income Taxes

The Company's federal income tax return is consolidated into a group filing with its wholly-owned insurance companies. The method of allocation of current income taxes between the affiliates is subject to a written agreement approved by each respective company’s board of directors. Income tax expense is allocated to those entities within the group as if each individual entity filed a separate return. Current tax credits are determined on the basis of utilization by the consolidated group. The provision for federal income taxes is based on amounts determined to be payable as a result of current year operations. Intercompany balances are settled quarterly.

Deferred federal income taxes are provided for differences between the book and tax bases of assets and liabilities. In determining admissibility, gross DTAs are subject to a statutory valuation allowance if, based on the weight of available evidence, it is more likely than not that some portion or all of the gross DTAs will not be realized. The gross DTAs remaining after the application of a statutory valuation allowance, if any, are admitted subject to admissibility tests. Remaining DTAs after application of the admissibility tests are nonadmitted. Changes in deferred taxes are recorded directly to unassigned funds.

Under GAAP, DTAs are recognized only to the extent that it is more likely than not they will be realized. A valuation allowance is established when DTAs cannot be recognized. Changes in deferred taxes are reported in earnings or as a component of AOCI.

Separate Accounts

Separate account assets represent segregated funds administered and invested for the exclusive benefit of policyholders. For variable separate account products, the assets of these separate accounts consist of designated underlying funds and are reported at fair value. Investment risks associated with fair value changes are borne by the policyholders. Separate account liabilities represent reserves established to meet withdrawal and future benefit payment provisions of contracts with these policyholders. The separate account assets are not subject to liabilities arising out of any other business the Company may conduct.

The Company also administers separate accounts for BOLI policies. The assets of these accounts include bonds and mortgage loans. Pursuant to the accounting elections discussed above, bonds are held at amortized cost and mortgage loans are held at their outstanding principal loan balance less any recognized impairment. The majority of these assets are legally segregated and are not subject to claims that arise out of the Company’s other business activities. The liabilities of these separate accounts represent reserves established to meet withdrawal and future benefit payment provisions of contracts with the policyholders.

In 2019, the Company began administering separate accounts relating to index-linked funds for RILA contracts. The assets of these accounts include bonds, mortgage loans, and derivatives. Pursuant to the accounting elections discussed above, bonds are held amortized cost, mortgage loans are held at outstanding principal loan balance less any recognized impairment, and derivatives are carried at fair value. Changes in fair value of index options are reported as net realized capital gains (losses) and as a change in surplus for all other derivative types. Except for contracts issued in Texas, Alaska, and Washington, these assets are not legally segregated and are subject to claims that arise out of the Company's other business activities. The liabilities of these separate accounts represent reserves established to equal the policyholder cash surrender value on index-linked funds.

The operations of all separate accounts, excluding investment gains (losses) allocable solely to the policyholders, are combined with the general account of the Company on the statements of operations under the appropriate captions. Transactions such as premium deposits, surrenders, and withdrawals are offset by a corresponding increase or decrease in net transfers to the separate accounts.

Under GAAP, separate account assets are reported at fair value. Separate account liabilities are set equal to separate account assets. Investment activity accrues directly to the policyholders and are not included in the Company’s revenue. Assets and liabilities associated with BOLI policies and RILA contracts do not qualify for separate account treatment under GAAP, as the Company retains the investment risk.

Subsequent Events

The Company has evaluated the effects of events subsequent to December 31, 2020, and the accounting and disclosure requirements related to subsequent events are included in the financial statements. Management has assessed material subsequent events through March 25, 2021, the date the financial statements were available to be issued.

15

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Reconciliation of Statutory-Basis Amounts to GAAP-Basis Amounts

The following tables present a reconciliation of net income and capital and surplus of the Company, as determined in accordance with SAP to amounts determined in accordance with GAAP:

	Net Income (Loss)
	For the Year Ended December 31,
	2020		2019		2018
Statutory-basis net income (loss), as reported	$	(59.8)	$	170.6	$	(118.7)
Add (deduct) adjustments:
Investments	(549.3)		(1,123.4)		(521.0)
Reserves	504.8		565.5		438.5
Policy acquisition costs and VOBA	199.7		161.6		158.3
Goodwill	(56.3)		—		—
Other intangible assets	(83.7)		(83.7)		(83.4)
Federal income taxes	(6.1)		105.0		64.6
Other	(33.5)		(43.9)		15.5
Total adjustments	(24.4)		(418.9)		72.5
GAAP-basis net income (loss)	$	(84.2)	$	(248.3)	$	(46.2)

	Total Capital and Surplus
	As of December 31,
	2020		2019
Statutory-basis total capital and surplus, as reported	$	2,316.1	$	2,141.6
Add (deduct) adjustments:
Investments	3,895.0		2,495.7
Reserves	2,702.6		2,984.0
Policy acquisition costs and VOBA	822.2		821.8
Goodwill	506.7		563.0
Other intangible assets	1,001.2		1,084.9
Federal income taxes	(448.0)		(310.3)
Non-admitted assets	133.2		118.9
Funds held under coinsurance agreements	(5,162.4)		(5,193.1)
Other	46.5		25.8
Total adjustments	3,497.0		2,590.7
GAAP-basis shareholder's equity	$	5,813.1	$	4,732.3

Correction of Errors

There were no corrections of errors for the years ended December 31, 2020, 2019, or 2018.

16

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

3. Investments

The book/adjusted carrying value and fair value of investments in bonds, preferred stocks, and common stocks are as follows:

	As of December 31, 2020
	Book/ Adjusted Carrying Value		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
Bonds:
U.S. government and agencies	$	712.4	$	27.5	$	(0.4)	$	739.5
Foreign governments and agencies	93.6		8.2		—		101.8
States, territories, and possessions	7.5		0.6		—		8.1
Political subdivisions	25.7		4.0		—		29.7
Special revenue and assessments	693.7		56.7		(1.2)		749.2
Industrial and miscellaneous	19,963.7		2,471.4		(10.4)		22,424.7
Hybrid securities	239.6		37.3		(8.6)		268.3
Collateralized loan obligations	3,484.2		8.2		(11.5)		3,480.9
Mortgage and asset-backed securities	3,268.5		128.5		(26.1)		3,370.9
Total bonds	28,488.9		2,742.4		(58.2)		31,173.1
Preferred stocks	102.6		1.9		(2.4)		102.1
Unaffiliated common stocks	151.4		5.3		(3.3)		153.4
Total	$	28,742.9	$	2,749.6	$	(63.9)	$	31,428.6

	As of December 31, 2019
	Book/ Adjusted Carrying Value		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
Bonds:
U.S. government and agencies	$	364.8	$	3.6	$	(1.1)	$	367.3
Foreign governments and agencies	78.5		7.1		(0.1)		85.5
States, territories, and possessions	7.5		0.3		—		7.8
Political subdivisions	30.8		2.3		—		33.1
Special revenue and assessments	665.7		33.8		(1.1)		698.4
Industrial and miscellaneous	20,316.2		1,540.0		(8.2)		21,848.0
Hybrid securities	261.9		41.3		(5.8)		297.4
Collateralized loan obligations	2,741.1		1.6		(11.4)		2,731.3
Mortgage and asset-backed securities	2,845.8		102.6		(4.7)		2,943.7
Total bonds	27,312.3		1,732.6		(32.4)		29,012.5
Preferred stocks	108.0		2.5		(5.9)		104.6
Unaffiliated common stocks	190.5		4.6		(17.2)		177.9
Total	$	27,610.8	$	1,739.7	$	(55.5)	$	29,295.0

17

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The Company maintains a diversified investment portfolio. The following table presents the composition of the Company's bonds, preferred stocks, and common stocks by sector:

	As of December 31,
	2020				2019
	Fair Value		% of Total		Fair Value		% of Total
Financials	$	9,446.0	30.1	%	$	8,363.7	28.5	%
Industrials	3,600.0		11.5		3,193.0		10.9
Energy	3,003.5		9.6		3,148.3		10.7
Utilities	2,773.7		8.8		2,424.2		8.3
Consumer staples	2,579.5		8.2		2,571.1		8.8
Health care	2,257.4		7.2		2,417.0		8.3
Consumer discretionary	2,251.1		7.2		2,169.9		7.4
Communications	1,841.3		5.9		1,880.1		6.4
Other	3,676.1		11.5		3,127.7		10.7
Total	$	31,428.6	100.0	%	29,295.0		100.0	%

The following table summarizes the contractual years to maturity of bonds as of December 31, 2020. Actual maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without penalties.

	Book/ Adjusted Carrying Value		Fair Value
Years to maturity:
One or less	$	1,031.0	$	1,046.1
Over one through five	8,535.6		9,195.6
Over five through ten	7,779.5		8,681.1
Over ten	4,390.1		5,398.5
Total with contractual maturity dates	21,736.2		24,321.3
Collateralized loan obligations	3,484.2		3,480.9
Mortgage and asset-backed securities	3,268.5		3,370.9
Total bonds	$	28,488.9	$	31,173.1

The following table summarizes the Company’s net investment income:

	For the Year Ended December 31,
	2020		2019		2018
Income:
Bonds	$	1,065.9	$	1,068.8	$	1,017.7
Preferred and common stocks	17.1		14.8		17.4
Mortgage loans	308.2		300.9		284.0
Derivatives (1)	(212.0)		5.2		10.8
Limited partnerships	(25.2)		(26.6)		(34.6)
Other	10.4		20.0		12.9
Total investment income	1,164.4		1,383.1		1,308.2
Investment expenses	(58.9)		(51.3)		(48.0)
Net investment income	$	1,105.5	$	1,331.8	$	1,260.2
____________________

(1)For the year ended 2020, the balance included $231.8 of amortization of option costs under IAC 191-97. Refer to Note 2 for further discussion.

For the years ended December 31, 2020, 2019, and 2018, respectively, the Company sold, redeemed, or otherwise disposed of 110, 73, and 68 securities as a result of a callable feature, resulting in $44.4, $17.3, and $11.4 of investment income generated from a prepayment penalty and/or acceleration fee.

18

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The following table summarizes the realized capital gains (losses) from investment sales, dispositions, and write downs:

	For the Year Ended December 31,
	2020		2019		2018
Bonds	$	130.7	$	117.8	$	100.8
Common stocks (1)	(57.0)		(5.2)		190.5
Write downs – limited partnerships	(4.1)		(3.2)		(3.2)
Derivatives and other invested assets	386.0		328.1		(184.2)
Realized capital gains (losses) before federal income taxes and transfer from IMR	455.6		437.5		103.9
Federal income tax benefit (expense)	(97.3)		(90.4)		(20.0)
Amount transferred to the IMR	(152.2)		(110.5)		(87.1)
Net realized capital gains (losses)	$	206.1	$	236.6	$	(3.2)
____________________

(1)Includes $43.9, $0.0, and $0.0 of losses related to OTTI for the years ended December 31, 2020, 2019, and 2018, respectively.

The following table presents the proceeds from sales of bonds (excluding call and maturity proceeds), and the gross gains and losses realized on those sales:

	For the Year Ended December 31,
	2020		2019		2018
Proceeds from sales of bonds	$	2,010.2	$	3,365.3	$	3,892.8
Gross gains	195.5		154.7		151.4
Gross losses	(37.2)		(15.9)		(33.0)

Unrealized Losses and OTTI

The following tables summarize gross unrealized losses and fair values of the Company’s bonds, preferred stocks, and common stocks, presented by length of time that individual securities have been in a continuous loss position:

	As of December 31, 2020
	Less Than 12 Months					12 Months or More
	Fair Value		Gross Unrealized Losses		# of Securities	Fair Value		Gross Unrealized Losses		# of Securities
Bonds:
U.S. government and agencies	$	46.8	$	(0.4)	11	$	—	$	—	—
Foreign governments and agencies	5.0		—		1	—		—		—
Special revenue and assessments	23.6		(1.2)		3	—		—		—
Industrial and miscellaneous	343.5		(10.2)		82	3.5		(0.2)		6
Hybrid securities	15.0		—		1	14.3		(8.6)		2
Collateralized loan obligation	1,085.2		(5.4)		57	587.9		(6.1)		31
Mortgage and asset-backed securities	722.9		(25.3)		130	26.3		(0.8)		7
Total bonds	2,242.0		(42.5)		285	632.0		(15.7)		46
Preferred stocks	—		—		—	41.9		(2.4)		2
Unaffiliated common stocks	11.6		(3.0)		12	0.9		(0.3)		6
Total	$	2,253.6	$	(45.5)	297	$	674.8	$	(18.4)	54

19

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
	Less Than 12 Months					12 Months or More
	Fair Value		Gross Unrealized Losses		# of Securities	Fair Value		Gross Unrealized Losses		# of Securities
Bonds:
U.S. government and agencies	$	256.1	$	(1.1)	9	$	—	$	—	—
Foreign governments and agencies	—		—		—	8.5		(0.1)		1
Special revenue and assessments	49.2		(1.1)		3	—		—		—
Industrial and miscellaneous	966.6		(5.5)		89	64.7		(2.7)		31
Hybrid securities	—		—		—	17.1		(5.8)		2
Mortgage and asset-backed securities	1,231.4		(2.6)		57	524.8		(8.8)		30
Other	499.5		(3.0)		72	27.0		(1.7)		6
Total bonds	3,002.8		(13.3)		230	642.1		(19.1)		70
Preferred stocks	21.4		(0.1)		2	33.4		(5.8)		1
Unaffiliated common stocks	47.1		(10.1)		17	15.5		(7.1)		11
Total	$	3,071.3	$	(23.5)	249	$	691.0	$	(32.0)	82

The Company reviewed its investments with unrealized losses as of December 31, 2020 and 2019 in accordance with its impairment policy. The Company’s evaluation determined, after the recognition of OTTI, that the remaining declines in fair value were temporary and the Company did not intend to sell these securities at an amount below the carrying value prior to maturity (or recovery). For loan-backed bonds and structured securities, the Company expects to recover the entire amortized cost basis.

While all securities are monitored for impairment, the Company’s experience indicates that, under normal market conditions, securities for which the cost or amortized cost exceeds fair value by less than 20% do not typically represent a significant risk of impairment and, often, fair values recover over time as the factors that caused the declines improve. If the estimated fair value has declined and remained below cost or amortized cost by 20% or more for at least six months, the Company further analyzes the decrease in fair value to determine whether it is an other-than-temporary decline. To make this determination for each security, the Company considers, among other factors:

•Extent and duration of the decline in fair value below cost or amortized cost;

•Financial condition and near-term prospects of the issuer of the security, including any specific events that may affect its operations, earnings potential, or compliance with terms and covenants of the security;

•Changes in the financial condition of the security’s underlying collateral;    

•Any downgrades of the security by a rating agency;

•Nonpayment of scheduled interest, or the reduction or elimination of dividends; and

•Other indications that a credit loss has occurred.

For bonds and preferred stocks, the Company concludes an OTTI has occurred if a security is underwater and there is an intent to sell the security, or it is more likely than not that the Company will be required to sell the security prior to recovery of its amortized cost, considering any regulatory developments, prepayment or call notifications, and the Company's liquidity needs. For OTTI on bonds other than loan-backed and structured securities, an impairment loss equal to the difference between the bond’s carrying value and its fair value is recognized within the statements of operations.

Loan-backed and structured securities are considered other-than-temporarily impaired when the Company has concluded it does not have the intent and ability to retain the security for sufficient time to recover the amortized cost basis, it intends to sell the security prior to maturity at an amount below the carrying value, or it does not expect to recover the entire amortized cost basis even if it has the intent and ability to hold.

When an OTTI has occurred due to the Company’s intent to sell the security or the Company has assessed it does not have the intent and ability to retain the security until sufficient time to recover the amortized cost basis, an impairment loss equal to the difference between the bonds carrying value and its fair value is recognized within the statements of operations.

When an OTTI has occurred because the Company does not expect to recover the entire cost basis, even if the Company has the intent and ability to hold the security, an impairment loss is recognized equal to the difference between the security's carrying value and its estimated recovery value is calculated as the present value of cash flows expected to be collected, discounted at the effective rate immediately prior to the recognition of the OTTI.

20

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

To determine the recovery value of a loan-backed or structured security, the Company performs an analysis related to the underlying issuer including, but not limited to, the following:

•Expected cash flows from the security;

•Creditworthiness;

•Delinquency, debt-service coverage, and loan-to-value ratios on the underlying collateral;

•Underlying collateral values, vintage year, and level of subordination;

•Geographical concentrations; and

•Susceptibility to prepayment due to changes in the interest rate environment.

The Company records OTTI charges on bonds, common stock, and preferred stock as net realized capital losses on the statements of operations. The largest write-downs were from investments in the following sectors:

	For the Year Ended December 31,
	2020				2019				2018
	Amount		% of Total		Amount		% of Total		Amount		% of Total
Energy (1)	$	52.2	92.2	%	$	2.1	48.8	%	$	3.4	24.6	%
U.S. government (2)	2.4		4.2	%	0.5		11.6		7.4		53.6
Health care	1.0		1.8	%	0.5		11.6		1.2		8.7
Consumer discretionary	0.8		1.4	%	0.4		9.3		0.3		2.2
Telecommunications	0.1		0.2	%	0.3		7.0		0.7		5.2
Other	0.1		0.2	%	0.5		11.6		0.8		5.8
Impairment losses recognized in earnings	$	56.6	100.0	%	$	4.3	100.0	%	$	13.8	100.0	%
____________________

(1) Primarily related to impairments on non-affiliated common stocks in the energy sector.

(2)Impairments on U.S. Federal Government securities are due to the Company's intent to sell and reflect the impact of interest rate movements.

Based on NAIC ratings as of December 31, 2020 and 2019, the Company held below-investment-grade bonds with fair values of $1,078.5 and $746.6, respectively, and book/adjusted carrying values of $1,036.6 and $716.0, respectively. These holdings amounted to 3.5% and 2.6% of the Company’s investments in bonds at fair value as of December 31, 2020 and 2019, respectively.

Restricted Assets

The table below provides a summary of restricted assets at book/adjusted carrying value:

	As of December 31,
	2020						2019
	Total Pledged & Restricted Assets		% of Total Assets		% of Total Admitted Assets		Total Pledged & Restricted Assets		% of Total Assets		% of Total Admitted Assets
Restricted assets in connection with reinsurance transactions (1)	$	6,061.4	13.7	%	13.7	%	$	6,124.1	14.5	%	14.5	%
Federal Home Loan Bank of Des Moines (FHLB DM) capital stock	85.7		0.2		0.2		69.5		0.2		0.2
State deposits	6.9		—		—		6.9		—		—
Pledged collateral to FHLB DM	3,552.6		8.0		8.0		2,277.6		5.4		5.4
Other pledged collateral	63.3		0.1		0.1		31.4		0.1		0.1
Total restricted assets	$	9,769.9	22.0	%	22.0	%	$	8,509.5	20.1	%	20.1	%
____________________

(1) Includes bonds, stocks, mortgage loans, cash, and other assets contractually restricted to use related to the Company's reinsurance transactions.

21

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Funding Agreements with Federal Home Loan Bank of Des Moines

In August 2018, the Company became a member of the Federal Home Loan Bank of Des Moines (FHLB DM). Membership allows access to the FHLB DM's funding services, which provide an alternative liquidity source, including the ability to obtain loans and issue funding agreements that are collateralized by qualifying assets. The Company has issued funding agreements to the FHLB DM to support an institutional spread program, where the Company earns income primarily from the difference between investment income earned and interest paid on the funding agreements. Maximum borrowing capacity varies based on a percentage of total assets, subject to availability of eligible collateral and internal authorization limits. Eligible collateral includes CMBS, RMBS, government or agency securities, and mortgage loans.

The table below presents amounts related to FHLB DM:

	As of December 31,
	2020		2019
Membership stock – Class B (1)	$	10.0	$	10.0
Activity stock	75.7		59.5
Total	$	85.7	$	69.5
Outstanding funding agreements (2)	$	1,893.2	$	1,488.7
Collateral held at FHLB DM, at carrying value (3)	3,552.6		2,277.6
Actual or estimated borrowing capacity as determined by the Company	3,541.1		2,112.1
____________________

(1)Class B membership stock is eligible for redemption in 1 to less than 3 years.

(2)The outstanding funding agreements as of December 31, 2020 and 2019 represent the total reserves established, which was recorded in liability for deposit-type contracts on the balance sheet. The outstanding funding agreements as of December 31, 2020 and 2019 also represent the maximum amount outstanding during the year ended December 31, 2020 and 2019, respectively. The Company does not have any prepayment obligations related to the outstanding funding agreements.

(3)As of the December 31, 2020 and 2019, the fair value of the Company's collateral held at FHLB DM was $3,762.8 and $2,372.9, respectively. The carrying value and fair value also represent the maximum amount pledged during the year ended December 31, 2020 and 2019, respectively.

Low-Income Housing Tax Credits

The Company held LIHTC investments of $40.5 and $66.2 as of December 31, 2020 and 2019, respectively. As of December 31, 2020, the Company had up to 10 remaining years of unexpired credits related to LIHTC investments. The Company's remaining required holding period for these investments was between 5 and 10 years as of December 31, 2020.

The Company recognized LIHTC tax credits of $34.5 and $72.1 during the years ended December 31, 2020 and 2019, respectively. The Company did not recognize any LITHC tax credits during the year ended December 31, 2018. As of December 31, 2020, the Company had remaining commitments of $2.7 to its LIHTC investments. These properties are not currently subject to any regulatory review.

4. Mortgage Loans

The Company's mortgage loan portfolio is secured by first-mortgage liens on income-producing commercial real estate, primarily in the retail, industrial, and office building sectors. The Company's mortgage loan portfolio is considered a single portfolio segment and class of financing receivables, which is consistent with how the Company assesses and monitors the risk and performance of the portfolio. A large majority of these loans have personal guarantees and all mortgaged properties are inspected annually.

The Company's mortgage loan portfolio is diversified by geographic region, loan size, and scheduled maturity. As of December 31, 2020, the two states with the largest concentrations of the Company's mortgage loans were California and Texas, comprising 27.8% and 9.9%, respectively, of total outstanding principal. Of the loans in California, 39.9% related to properties located in the Los Angeles area.

The maximum and minimum lending rates for mortgage loans issued during 2020, were 4.9% and 2.6%, respectively. The maximum and minimum lending rates for mortgage loans issued during 2019, were 5.4% and 3.5%, respectively. The maximum and minimum lending rates for mortgage loans issued during 2018 were 5.6% and 4.2%, respectively.

Loans are underwritten based on loan-to-value (LTV) ratios and debt-service coverage ratios (DSCR), as well as detailed market, property, and borrower analyses. The LTV and DSCR are used by the Company to determine the internal credit quality of mortgage loans. The LTV ratio compares the carrying value of the loan to the fair value of the underlying collateral. The DSCR compares a property's net operating income to its debt-service payments. Generally, a lower LTV ratio and higher DSCR indicate

22

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

a higher quality loan. The Company updates each loan's LTV ratio every quarter based on the carrying value of the property, while property information (such as property value and income for DSCR) is updated annually, primarily during the third quarter.

The maximum LTV for any one loan was 79.1%, 72.2%, and 74.4% for loans funded during the years ended December 31, 2020, 2019, and 2018, respectively. The weighted average LTV ratio for the Company’s mortgage loan portfolio was 46.9% and 48.0% as of December 31, 2020 and 2019, respectively.

The following table sets forth the Company's mortgage loans by credit quality indicator:

	As of December 31, 2020						As of December 31, 2019
	DSCR (1)						DSCR (1)
LTV ratio	1.50x or Greater		Less Than 1.50x		Total		1.50x or Greater		Less Than 1.50x		Total
Less than 65%	$	5,714.2	$	229.5	$	5,943.7	$	5,500.0	$	289.0	$	5,789.0
Between 65% and 80%	204.2		219.9		424.1		209.1		215.1		424.2
Greater than 80%	—		72.3		72.3		—		24.8		24.8
Total mortgage loans	$	5,918.4	$	521.7	$	6,440.1	$	5,709.1	$	528.9	$	6,238.0
_______________________

(1)Beginning in 2020, the Company modified its calculation of DSCR and applied a normalized amortization period for all mortgage loans. Previously, the amortization period varied by individual loan. Prior period amounts were updated to reflect this change.

Loans are specifically evaluated for impairment if the Company considers it probable that amounts due according to the terms of the loan agreement will not be collected, or the loan is modified in a troubled debt restructuring. As of December 31, 2020, no outstanding loans were determined to be non-performing. As of December 31, 2019, one loan with an outstanding balance of $2.3 was considered non-performing.

5. Derivative Instruments

The Company uses derivative financial instruments to hedge certain portions of its exposure to equity market risk, interest rate risk, and foreign currency exchange risk. Derivative instruments may be exchange-traded or contracted in the over-the-counter (OTC) market. The Company has established policies for managing its derivatives, including prohibitions on derivatives market-making and other speculative derivatives activities.

The following tables present the notional amounts, carrying amounts, and fair values of the Company’s derivative assets and liabilities:

	As of December 31, 2020
			Carrying Amount				Fair Value
	Notional		Assets		Liabilities		Assets		Liabilities
Derivatives designated as cash flow hedges:
Interest rate swaps	$	888.9	$	—	$	—	$	35.1	$	—
Foreign currency swaps	833.2		47.8		32.4		57.2		29.7
Total derivatives designated as hedges	$	1,722.1	$	47.8	$	32.4	$	92.3	$	29.7
Derivatives not designated as hedges:
Index options	$	9,653.7	$	149.9	$	1.1	$	372.4	$	1.2
Interest rate collars	582.3		36.3		—		36.3		—
Other derivatives	15.5		9.1		—		9.2		—
Total derivatives not designated as hedges	10,251.5		195.3		1.1		417.9		1.2
Total derivatives	$	11,973.6	$	243.1	$	33.5	$	510.2	$	30.9

23

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
			Carrying Amount				Fair Value
	Notional		Assets		Liabilities		Assets		Liabilities
Derivatives designated as cash flow hedges:
Interest rate swaps	$	905.9	$	—	$	—	$	9.0	$	—
Foreign currency swaps	928.6		86.2		9.1		91.8		9.1
Total derivatives designated as hedges	$	1,834.5	$	86.2	$	9.1	$	100.8	$	9.1
Derivatives not designated as hedges:
Index Options	$	8,713.1	$	358.9	$	2.3	$	358.9	$	2.3
Interest rate collars	1,164.7		10.8		10.9		10.8		10.9
Other derivatives	101.4		9.0		—		9.0		—
Total derivatives not designated as hedges	9,979.2		378.7		13.2		378.7		13.2
Total derivatives	$	11,813.7	$	464.9	$	22.3	$	479.5	$	22.3

Interest Rate Swaps

The Company uses interest rate swaps as part of its interest rate risk management strategy. In an interest rate swap, the Company agrees with other parties to exchange, at specified intervals, the difference between floating-rate and fixed-rate interest amounts calculated by reference to an agreed upon notional principal amount. The Company primarily uses interest rate swaps to synthetically convert variable rate bonds, including investments in collateralized loan obligations, to fixed rate bonds. Most of these derivatives qualify and are designated as cash flow hedges.

Foreign Currency Contracts

The Company uses foreign currency swaps and forwards as part of its foreign currency risk management strategy to reduce exchange risk with respect to the Company's investments denominated in foreign currencies. In a foreign currency swap transaction, the Company agrees with other parties to exchange, at specified intervals, one currency for another at a specified rate of exchange. Generally, the notional amount of each currency is exchanged at the maturity of the currency swap by each party. These derivatives qualify and are designated as cash flow hedges.

Index Options

The Company uses index call options and futures as part of its equity market risk management strategy. The Company offers indexed and index-linked products that permit the contract holder to allocate all or a portion of their account value to an indexed component that credits interest based on the performance of an index, subject to caps or performance margins set by the Company. The contract holders may elect to rebalance index options at renewal dates, typically annually. As of each renewal date, the Company has the opportunity to re-price the indexed component by establishing revised cap rates or performance margins, subject to contractual guarantees. The Company transacts in index call options according to the portfolio allocation decisions of the contract holders such that the Company is economically hedged with respect to equity returns for the current interest term. These derivatives are not designated for hedge accounting.

Interest Rate Collars

The Company uses interest rate collars as part of its interest rate risk management strategy pertaining to floating-rate investments. The Company will generally take a long position using an interest rate floor option to hedge against the risk of falling reference rates, and may choose to partially or fully finance such floor by taking a short position using an interest rate cap option. When done in combination, the long floor and short cap combination is referred to as a collar. The collar provides protection against reference rates falling below the floor’s strike price, but also results in the Company forfeiting potential gains should the reference rates rise above the cap’s strike price. The Company does not designate these derivatives for hedge accounting.

Collateral Arrangements

The Company’s derivative contracts are typically governed by an International Swaps and Derivatives Association (ISDA) Master Agreement. For each Master Agreement, the Company and the counterparty have also entered into a credit support annex (CSA) to reduce the risk of counterparty default in derivative transactions by requiring the posting of cash collateral or other financial assets. The CSA requires either party to post collateral when net exposures from all derivative contracts between the

24

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

parties exceed pre-determined contractual thresholds, which vary by counterparty. The amount of net exposure is the difference between the derivative contract’s fair value and the fair value of the collateral held for such agreements with each counterparty. Collateral amounts required to be posted or received are determined daily based on the net exposure with each counterparty under a master netting agreement.

The Company does not offset recognized collateral amounts pledged or received against the fair value amounts recognized for derivative contracts. For certain centrally-cleared instruments, the Company is required to post initial margin, which is determined at contract inception, as well as variation margin, which is based on the fair value of the derivative contracts and generally determined on a daily basis. As of December 31, 2020 and 2019, the Company posted initial margin of $26.0 and $23.9, respectively, related to its centrally-cleared derivatives. These amounts are not reflected in collateral presented in the tables below.

In the balance sheets, the Company recognizes cash collateral received in cash and the obligation to return cash collateral as a liability. Non-cash collateral received is not recognized in the balance sheets. In the event of default, the counterparty relinquishes claim to the assets pledged as collateral and the Company recognizes the collateral as its own asset recorded at fair value, or, in the case of cash collateral, derecognizes its obligation to return collateral.

The following tables present the potential effect of netting arrangements on the Company's balance sheets:

	As of December 31, 2020
	Fair Value		Financial Instruments(1)		Cash Collateral Received		Net Amount
Counterparty:
Assets:
A	$	78.3	$	(3.6)	$	(74.7)	$	—
B	78.4		—		(36.3)		42.1
C	12.7		—		(12.7)		—
D	47.3		—		(46.7)		0.6
F	73.7		(1.1)		(71.7)		0.9
G	56.8		(3.8)		(52.9)		0.1
H	17.4		(11.0)		(6.1)		0.3
M	58.1		—		(57.1)		1.0
N	76.7		(11.4)		(65.3)		—
Other	10.8		—		(10.8)		—
Total derivative assets	$	510.2	$	(30.9)	$	(434.3)	$	45.0
____________________

(1)Represents amount of offsetting derivative liabilities that are subject to an enforceable master netting agreement or similar agreement that are not netted against the gross derivative assets for presentation on the balance sheet.

25

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
	Fair Value		Financial Instruments(1)		Cash Collateral Received		Net Amount
Counterparty:
Assets:
A	$	93.2	$	(2.6)	$	(90.6)	$	—
B	74.0		—		(60.1)		13.9
C	20.2		—		(20.2)		—
F	46.6		—		(46.0)		0.6
G	33.5		(1.8)		(31.7)		—
H	38.3		(8.3)		(30.0)		—
I	18.5		—		(18.5)		—
M	59.3		(0.8)		(58.5)		—
N	79.5		(8.6)		(70.9)		—
Other	16.4		(0.2)		(16.2)		—
Total derivative assets	$	479.5	$	(22.3)	$	(442.7)	$	14.5
____________________

(1)Represents amount of offsetting derivative liabilities that are subject to an enforceable master netting agreement or similar agreement that are not net against the gross derivative assets for presentation on the balance sheet.

6. Fair Value of Financial Instruments

The Company determines the fair value of its financial instruments based on the fair value hierarchy, which favors the use of observable inputs over the use of unobservable inputs when measuring fair value. The Company uses the same pricing methodology and sources as utilized for obtaining GAAP fair values.

The Company has categorized its financial instruments into the three-level hierarchy, which gives the highest priority to quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The level assigned to a fair value measurement is based on the lowest-level input that is significant to the measurement. The fair value measurements for the Company's financial instruments are categorized as follows:

•    Level 1 – Unadjusted quoted prices in active markets for identical instruments.

•    Level 2 – Quoted prices for similar instruments in active markets and model-derived valuations whose inputs are observable. This category includes those financial instruments that are valued using industry-standard pricing methodologies or models. All significant inputs are observable or derived from observable information in the marketplace.

•    Level 3 – Fair value estimates whose significant inputs are unobservable. This includes financial instruments for which fair value is estimated based on industry-standard pricing methodologies and internally developed models utilizing significant inputs not based on or corroborated by readily available market information. In limited circumstances, this may also utilize estimates based on non-binding broker quotes.

The following tables present financial instruments carried at fair value:

	As of December 31, 2020
Assets at fair value:	Level 1		Level 2		Level 3		Total
Unaffiliated common stocks	$	66.9	$	85.7	$	0.8	$	153.4
Derivatives	9.2		69.8		3.7		82.7
Separate account assets	1,270.3		24.9		7.6		1,302.8
Total assets at fair value (1)	$	1,346.4	$	180.4	$	12.1	$	1,538.9
____________________

(1)Does not include amounts related to alternative investments that are measured using the net asset value (NAV) practical expedient. The fair value of these investments was $348.5. These investments have varying investment strategies, and redemption terms and conditions.

26

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
Assets at fair value:	Level 1		Level 2		Level 3		Total
Bonds	$	—	$	1.3	$	0.2	$	1.5
Unaffiliated common stocks	107.9		69.5		0.5		177.9
Derivatives	9.0		287.1		82.6		378.7
Separate account assets	1,128.9		4.7		2.3		1,135.9
Total assets at fair value (1)	$	1,245.8	$	362.6	$	85.6	$	1,694.0
____________________

(1)Does not include amounts related to alternative investments that are measured using the net asset value (NAV) practical expedient. The fair value of these investments was $233.7. These investments have varying investment strategies, and redemption terms and conditions.

The following tables present the book/adjusted carrying values and corresponding fair values of financial instruments subject to fair value disclosure requirements, categorized by the fair value hierarchy described above:

	As of December 31, 2020
Type of Financial Instrument	Carrying Values		Fair Value		Level 1		Level 2		Level 3
Financial assets:
Bonds	$	28,488.9	$	31,173.1	$	0.6	$	30,682.3	$	490.2
Preferred stocks	102.6		102.1		—		102.1		—
Unaffiliated common stocks	153.4		153.4		66.9		85.7		0.8
Mortgage loans	6,440.1		6,751.4		—		—		6,751.4
Limited partnerships (1)	43.1		50.7		—		—		50.7
Cash and cash equivalents	1,025.6		1,025.6		1,025.6		—		—
Derivatives	243.1		510.2		9.2		428.9		72.2
Separate account assets	6,478.3		7,011.9		1,372.2		5,155.5		484.2
____________________

(1)Does not include amounts related to alternative investments that are measured using the net asset value (NAV) practical expedient. The fair value of these investments was $348.5. These investments have varying investment strategies, and redemption terms and conditions.

	As of December 31, 2019
Type of Financial Instrument	Carrying Values		Fair Value		Level 1		Level 2		Level 3
Financial assets:
Bonds	$	27,312.3	$	29,012.5	$	66.0	$	28,394.9	$	551.6
Preferred stocks	108.0		104.6		—		104.6		—
Unaffiliated common stocks	177.9		177.9		107.9		69.5		0.5
Mortgage loans	6,238.0		6,473.8		—		—		6,473.8
Limited partnerships	74.8		88.3		—		—		88.3
Cash and cash equivalents	612.4		612.4		612.4		—		—
Derivatives	464.9		479.5		9.0		388.0		82.6
Separate account assets	6,024.0		6,317.2		1,207.0		4,655.9		454.2
____________________

(1)Does not include amounts related to alternative investments that are measured using the net asset value (NAV) practical expedient. The fair value of these investments was $233.7. These investments have varying investment strategies, and redemption terms and conditions.

Financial Instruments Measured at Fair Value on a Recurring Basis

Unaffiliated Common Stocks

The Company's unaffiliated common stock primarily include FHLB DM common stock and publicly traded common stocks. The FHLB DM common stock is based on redeemable par value and is classified as a Level 2 measurement. The publicly traded common stocks are based on quoted market prices in active markets for identical assets and are classified as a Level 1 measurement.

27

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Derivatives

Index options consist primarily of Standard & Poor's 500 Index® (S&P 500) options. The fair values of these index options were determined using option pricing models. Significant inputs include index implied volatilities, index dividend yields, index prices, a risk-free rate, option term, and option strike price. As these inputs are observable, most index options are classified as a Level 2 measurement.

Separate Account Assets

Separate account assets related to the Company's variable products are primarily invested in mutual funds with published net asset values (NAVs) and are classified as a Level 1 measurement. Separate account assets related to the Company's RILA include investments in derivatives, which are valued using the same methodologies described above.

Other Financial Instruments Subject to Fair Value Disclosure Requirements

Bonds

Bonds are primarily classified as Level 2 measurements. To make this assessment, the Company determines whether the market for a security is active and if significant pricing inputs are observable. The Company predominately utilizes third-party independent pricing services to assist management in determining the fair value of its bonds.

The majority of industrial and miscellaneous bonds and mortgage- and asset-backed securities classified as Level 2 measurements are priced by independent pricing services utilizing evaluated pricing models. Because many of these bonds do not trade on a daily basis, evaluated pricing models apply available information through processes such as benchmark curves, benchmarking of like securities, sector groupings, and matrix pricing to prepare valuations. The significant inputs for these bond valuations include benchmark yields, reported trades, broker-dealer quotes, issuer spreads, two-sided markets, benchmark securities, bids, offers, and other reference data, including market research publications. In addition, for mortgage- and asset-backed securities, the pricing services use models and processes to develop prepayment and interest rate scenarios. The pricing services monitor market indicators, industry and economic events, and their models take into account market convention.

Preferred Stocks

The fair values of preferred stocks are valued by pricing services utilizing evaluated pricing models. These valuations are created based on benchmark curves using industry standard inputs and exchange prices of underlying securities of the same issuer. As these inputs are considered observable, preferred stocks are classified as a Level 2 measurement.

Mortgage Loans

The fair values of the Company’s mortgage loans are determined by discounting the projected future cash flows using a discount rate equal to the risk-free rate plus a valuation spread. The valuation spread is an unobservable input that includes management's assumptions of the impact of credit risks. Significant increases or decreases in this spread results in significant changes in fair value; therefore, mortgage loans are classified as a Level 3 measurement.

Limited Partnerships

The fair value of the Company's investment in limited partnerships involved in tax credit investments is estimated based on the discounted future economic benefits over the remaining life of each investment, using a market rate of return based on similar investments observed by brokers. The future economic benefits are based on assumptions about the partnerships' future performance and related tax benefits passed through to the Company, net of the Company's obligations to make future investment contributions. Because these estimates utilize significant unobservable inputs, investments in limited partnerships are classified as a Level 3 measurement.

Cash and Cash Equivalents

Cash and Cash equivalents consist of demand bank deposits and short-term high liquid investments with original maturities of three months or less at the time of purchase (including money market funds which have no stated maturity dates). Because cash equivalents are readily convertible to known amounts of cash, carrying value generally approximates fair value. The Company classified cash and cash equivalents as Level 1.

Derivatives

Foreign currency swaps are valued using an income approach. These swaps are priced using a discounted cash flow model. The significant inputs include the projected cash flows, currency spot rates, swap yield curve, and cross currency basis curve. As these inputs are observable, the foreign currency swaps valuation is classified as a Level 2 measurement.

28

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Separate Account Assets

Separate account assets related to the Company's fixed BOLI and RILA products primarily consist of bonds, commercial mortgage loans, and cash that are valued using the same methodologies described above.

Rollforward of Assets and Liabilities Measured and Reported as Level 3

The following table presents additional information about derivatives measured and reported at fair value and for which significant unobservable inputs (Level 3) were utilized to determine fair value:

	For the Year Ended December 31,
	2020		2019
Balance, beginning of period	$	82.6	$	—
Gross transfers into Level 3 (1)	—		0.1
Gross transfers out of level 3 (2)	(81.2)		—
Total gains (losses) included in net income	(0.1)		36.9
Total gains (losses) included in surplus	1.0		—
Purchases	2.4		45.6
Sales	—		—
Settlements	(1.0)		—
Balance, end of period	$	3.7	$	82.6
____________________

(1)Transfers into Level 3 are generally the result of observable market information on a security no longer being available or utilized by pricing vendors.

(2)Transfers out of level 3 are related to the Company's index options for FIA products being accounted using the amortized cost method under the election of IAC 191-97, effective January 1, 2020. Refer to Note 2 for further discussion.

7. Reinsurance

The Company uses reinsurance across its businesses to spread risk and limit losses. The Company remains liable to its policyholders to the extent that counterparties to reinsurance contracts do not meet their obligations. The following summarizes the Company's reinsurance coverage by line of business:

•Medical Stop-Loss. Starting in 2020, the Company reinsures the excess of $3.0 per individual claim; previously, the Company reinsured $2.5 per individual claim.

In 2019, the Company entered into a coinsurance with funds withheld arrangement to manage its risk based capital position on a majority of its stop-loss policies. This agreement does not qualify for GAAP reinsurance accounting.

•Group Life & DI. Starting in 2019, the Company primarily reinsures group life mortality risk in excess of $0.35 per individual and line of coverage; previously, the Company primarily reinsured in excess of $0.25 per individual and line of coverage. The Company reinsures morbidity risk in excess of $8.0 thousand of gross monthly benefit per life. The Company also has catastrophic coverage for group life policies.

•Deferred Annuities. The Company has a reinsurance agreement to manage its statutory capital position related to fixed deferred and fixed indexed annuities that have a guaranteed return of premium feature and were issued beginning in 2017. This agreement does not qualify for reinsurance accounting under GAAP.

•Income Annuities. In 2018, the Company entered into the Modco Reinsurance Transaction to transfer financial responsibility for its in-force block of income annuity contracts, which consists of all of the Company's structured settlements and a smaller block of SPIAs. This agreement does not qualify for reinsurance accounting under GAAP. See further discussion below.

•Individual Life. The Company's reinsurance coverage varies by product, policy issue year, and issue age of the insured. For fully underwritten policies issued subsequent to April 2017, the Company retains up to a maximum of $5.0 per life. For fully underwritten policies issued between March 2013 and April 2017, the Company retains up to a maximum of $3.0 per life.

In 2019, the Company entered into a coinsurance with funds withheld and a yearly renewable term reinsurance arrangement to manage its statutory capital position on a block of UL policies with secondary guarantees largely issued between January 2015 and December 2019. This agreement does not qualify for GAAP reinsurance accounting.

In 2018, the Company entered into a coinsurance with funds withheld arrangement with a third party reinsurer, as well as an excess loss reinsurance agreement with its subsidiary, Symetra National Life Insurance Company, to manage its

29

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

statutory capital position on its survivorship guaranteed universal life policies. This agreement does not qualify for reinsurance accounting under GAAP.

In addition, the Company has a funds withheld reinsurance agreement with its wholly-owned subsidiary, Symetra Reinsurance Corporation. The Company ceded all net policy liabilities related to a block of universal life insurance policies with secondary guarantees issued on or before December 31, 2014. The related reinsurance reserve credit taken was $248.5 and $235.1 as of December 31, 2020 and 2019, respectively. The balance of funds withheld was $191.6 and $178.1 as of December 31, 2020 and 2019, respectively.

Reserve credit taken for all ceded reinsurance was $1,267.9 and $1,201.7 as of December 31, 2020 and 2019, respectively.

The Company evaluates the financial condition of its reinsurers to monitor its exposure to losses from reinsurers’ insolvencies. The Company analyzes reinsurance recoverables, net of assets held in trust and funds withheld required by the related reinsurance agreements, according to the credit ratings and financial health of its reinsurers and is not aware of its major reinsurers currently experiencing financial difficulties. Excluding the Modco Reinsurance Transaction discussed below, as of December 31, 2020, $382.0 of net reinsurance recoverables was related to four reinsurers, representing 73.9% of the total amount due from reinsurers. As of December 31, 2019, $318.3 of net reinsurance recoverables was related to three reinsurers, representing 62.5% of the total amount due from reinsurers. Of the total amounts due from reinsurers, 96.0% and 95.8%, respectively was with reinsurers rated A- or higher by A.M. Best as of December 31, 2020 and 2019. The Company had no write-offs or reserve for uncollectible reinsurance in 2020 or 2019.

Modco Reinsurance Transaction

In September 2018, the Company entered into the Modco Reinsurance Transaction, which was effective as of July 1, 2018, for $5.7 billion of its in-force block of income annuities, consisting of life contingent annuities of $4.0 billion and non-life contingent annuities of $1.7 billion. At inception, the Company recorded a reduction to premiums of $4.0 billion and a corresponding increase to reserve adjustment on reinsurance ceded on the statements of operations.

Associated with the Modco Reinsurance Transaction, the Company paid a ceding commission of $360.0 to the reinsurer at the transaction date, of which $104.0 was recorded as an adjustment to liability for deposit-type contracts on the Company's balance sheets and is amortized over the life of the contracts into benefits expense. The withheld assets supporting the net statutory reserves of the reinsured business are reported as investments on the balance sheets and are legally owned by the Company.

The Company remains liable to its policyholders to the extent that the reinsurer does not meet its contractual obligations. In the event of the reinsurer's insolvency, the Company would reclaim the withheld assets supporting the reserve liabilities. The Company has the ability to offset amounts due to the reinsurer with amounts owed from the reinsurer, as well as access to amounts held in trust, which reduces the risk of loss.

30

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The following table sets forth the effect of reinsurance on premiums and annuity considerations. It is disaggregated by accident and health, and life insurance and annuity products, which are short- and long-duration contracts, respectively.

	For the Year Ended December 31,
	2020			2019			2018
Premiums and annuity considerations
Direct life insurance in-force	$	130,187.8		$	120,614.2		$	110,772.3
Direct:
Accident and health	929.5			958.7			849.2
Life insurance	846.9			799.9			653.9
Annuity	2,866.7			2,991.3			3,230.4
Total direct premiums	4,643.1			4,749.9			4,733.5
Assumed:
Accident and health	0.9			0.8			1.2
Total assumed premiums	0.9			0.8			1.2
Ceded:
Accident and health	(283.9)			(367.5)			(26.7)
Life insurance	(123.7)			(242.4)			(427.0)
Annuity	(2.4)			(2.3)			(4,012.3)
Total ceded premiums	(410.0)			(612.2)			(4,466.0)
Net premiums and annuity considerations	$	4,234.0		$	4,138.5		$	268.7
Percentage of amount assumed to net	0.02		%	0.02		%	0.45		%

Ceded reinsurance reduced the Company’s claims reported on the statements of operations by $374.8, $386.9, and $81.9 for the years ended December 31, 2020, 2019, and 2018, respectively.

8. Life and Annuity Reserves

The following tables present the Company’s annuity reserves and deposit fund liabilities by withdrawal characteristics, including those held in separate account liabilities:

	As of December 31, 2020
Individual Annuities	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	7,091.8	$	—	$	7,091.8	26.6	%
At book value less surrender charge of 5% or more (1)	9,036.2		305.4		9,341.6		35.1
At fair value	—		376.1		376.1		1.4
Total with adjustment or at fair value	16,128.0		681.5		16,809.5		63.1
At book value without adjustment (minimal or no charge or adjustment)	5,559.2		—		5,559.2		20.9
Not subject to discretionary withdrawal	4,257.6		—		4,257.6		16.0
Total gross individual annuity actuarial reserves	25,944.8		681.5		26,626.3		100.0	%
Less: reinsurance ceded	33.4		—		33.4
Total net individual annuity actuarial reserves	$	25,911.4	$	681.5	$	26,592.9
____________________

(1)Includes $492.2 that will have none to minimal charge or adjustments within the next year subsequent to December 31, 2020.

31

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2020
Group Annuities	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	69.6	$	—	$	69.6	9.4	%
At fair value	—		180.1		180.1		24.4
Total with adjustment or at fair value	69.6		180.1		249.7		33.8
At book value without adjustment (minimal or no charge or adjustment)	487.0		—		487.0		66.0
Not subject to discretionary withdrawal	1.3		—		1.3		0.2
Total group annuity actuarial reserves	$	557.9	$	180.1	$	738.0	100.0	%

	As of December 31, 2020
Deposit-type Contracts	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	69.6	$	—	$	69.6	2.0	%
At fair value	—		0.6		0.6		—
Total with adjustment or at fair value	69.6		0.6		70.2		2.0
At book value without adjustment (minimal or no charge or adjustment)	38.2		—		38.2		1.1
Not subject to discretionary withdrawal	3,401.0		—		3,401.0		96.9
Total gross deposit-fund liabilities	3,508.8		0.6		3,509.4		100.0	%
Less: reinsurance ceded	72.4		—		72.4
Total net deposit-fund liabilities	$	3,436.4	$	0.6	$	3,437.0

	As of December 31, 2019
Individual Annuities	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	7,751.9	$	—	$	7,751.9	30.2	%
At book value less surrender charge of 5% or more	8,791.4		—		8,791.4		34.2
At fair value	—		473.0		473.0		1.8
Total with adjustment or at fair value	16,543.3		473.0		17,016.3		66.2
At book value without adjustment (minimal or no charge or adjustment)	4,249.6		—		4,249.6		16.5
Not subject to discretionary withdrawal	4,449.5		—		4,449.5		17.3
Total gross individual annuity actuarial reserves	25,242.4		473.0		25,715.4		100.0	%
Less: reinsurance ceded	39.4		—		39.4
Total net individual annuity actuarial reserves	$	25,203.0	$	473.0	$	25,676.0

32

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
Group Annuities	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	68.5	$	—	$	68.5	9.3	%
At fair value	—		166.4		166.4		22.8
Total with adjustment or at fair value	68.5		166.4		234.9		32.1
At book value without adjustment (minimal or no charge or adjustment)	495.7		—		495.7		67.8
Not subject to discretionary withdrawal	0.8		—		0.8		0.1
Total group annuity actuarial reserves	565.0		166.4		731.4		100.0	%

	As of December 31, 2019
Deposit-type Contracts	General Account		Separate Account NonGuaranteed		Total		% of Total
Subject to discretionary withdrawal:
With fair value adjustment	$	71.4	$	—	$	71.4	2.2	%
At fair value	—		0.5		0.5		—
Total with adjustment or at fair value	71.4		0.5		71.9		2.2
At book value without adjustment (minimal or no charge or adjustment)	34.8		—		34.8		1.1
Not subject to discretionary withdrawal	3,131.9		—		3,131.9		96.7
Total gross deposit-fund liabilities	3,238.1		0.5		3,238.6		100.0	%
Less: reinsurance ceded	85.1		—		85.1
Total net deposit-fund liabilities	$	3,153.0	$	0.5	$	3,153.5

Total annuity actuarial reserves and deposit fund liabilities were as follows:

	As of December 31,
	2020		2019
Annuity reserves	$	26,469.3	$	25,768.0
Liability for deposit-type contracts	3,436.4		3,153.0
Separate account – annuity reserves and liability for deposit-type contracts	862.2		639.9
Total net annuity actuarial reserves and liability for deposit-type contracts	$	30,767.9	$	29,560.9

33

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The following table presents the Company's life reserves by withdrawal characteristics, including those held in separate account liabilities:

	As of December 31, 2020
	General Account
	Account Value		Cash Value		Reserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value	$	—	$	1.6	$	8.3
Universal life	1,127.5		1,128.1		1,244.3
Universal life with secondary guarantees	1,039.2		658.5		1,665.2
Indexed universal life with secondary guarantees	480.5		306.6		323.0
Other permanent cash value life insurance	—		56.8		59.8
Variable universal life	45.8		45.7		52.9
Miscellaneous reserves	—		3.0		3.0
Not subject to discretionary withdrawal or no cash value:
Term policies without cash value	XXX		XXX		399.7
Accidental death benefits	XXX		XXX		0.2
Disability – active lives	XXX		XXX		0.9
Disability – disabled lives	XXX		XXX		33.1
Miscellaneous reserves	XXX		XXX		271.5
Total life insurance reserves	2,693.0		2,200.3		4,061.9
Less: reinsurance ceded	—		—		1,202.5
Total net life insurance reserves	$	2,693.0	$	2,200.3	$	2,859.4

	As of December 31, 2020
	Separate Account with Guarantees						Separate Account Nonguaranteed
	Account Value		Cash Value		Reserve		Account Value		Cash Value		Reserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Universal life	$	4,751.3	$	4,751.3	$	4,751.3	$	—	$	—	$	—
Variable universal life	—		—		—		701.6		692.5		692.5
Total life insurance reserves	$	4,751.3	$	4,751.3	$	4,751.3	$	701.6	$	692.5	$	692.5

34

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	As of December 31, 2019
	General Account
	Account Value		Cash Value		Reserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Term policies with cash value	$	—	$	1.1	$	8.0
Universal life	1,132.2		1,132.0		1,245.7
Universal life with secondary guarantees	960.1		606.1		1,387.0
Indexed universal life with secondary guarantees	228.9		143.0		171.8
Other permanent cash value life insurance	—		59.8		62.9
Variable universal life	30.8		30.8		32.6
Miscellaneous reserves	—		4.7		4.7
Not subject to discretionary withdrawal or no cash value:
Term policies without cash value	XXX		XXX		413.0
Accidental death benefits	XXX		XXX		0.2
Disability – active lives	XXX		XXX		1.0
Disability – disabled lives	XXX		XXX		32.3
Miscellaneous reserves	XXX		XXX		267.6
Total life insurance reserves	2,352.0		1,977.5		3,626.8
Less: reinsurance ceded	—		—		1,127.0
Total net life insurance reserves	$	2,352.0	$	1,977.5	$	2,499.8

	As of December 31, 2019
	Separate Account with Guarantees						Separate Account Nonguaranteed
	Account Value		Cash Value		Reserve		Account Value		Cash Value		Reserve
Subject to discretionary withdrawal, surrender values, or policy loans:
Universal life	$	4,667.3	$	4,667.3	$	4,667.3	$	—	$	—	$	—
Variable universal life	—		—		—		602.9		598.0		598.0
Total life insurance reserves	$	4,667.3	$	4,667.3	$	4,667.3	$	602.9	$	598.0	$	598.0

Total life insurance reserves were as follows:

	As of December 31,
	2020		2019
Life insurance reserves	$	2,708.3	$	2,374.3
Accidental death benefits reserves	0.2		0.2
Disability – active lives reserves	0.9		1.0
Disability – disabled lives reserves	32.2		31.7
Miscellaneous reserves	117.8		92.6
Separate account life insurance reserves	5,443.8		5,265.3
Total net life insurance reserves	$	8,303.2	$	7,765.1

As of December 31, 2020 and 2019, the Company had $8,622.1 and $8,823.7, respectively, of insurance in-force for which the gross premiums were less than the net premiums according to the standard valuation established by the Department. Related reserves of $242.7 and $264.2 as of December 31, 2020 and 2019, respectively, were included in life and annuity reserves.

35

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

9. Liability for Unpaid Claims

The following table provides a reconciliation of the beginning and ending liability balances for unpaid claims, net of reinsurance recoverables:

	For the Year Ended December 31,
	2020		2019		2018
Balance, beginning of the year	$	483.4	$	421.9	$	380.2
Less: reinsurance recoverables (1)	124.6		109.3		61.1
Net balance, beginning of the year	358.8		312.6		319.1
Add provision for claims, net of reinsurance, occurring in:
Current year	765.3		718.4		845.3
Prior years	(18.8)		7.8		(6.6)
Net incurred losses during the year	746.5		726.2		838.7
Deduct payments for claims, net of reinsurance, occurring in:
Current year	499.0		494.7		589.9
Prior years	190.1		185.3		189.8
Net claim payments during the current year	689.1		680.0		779.7
Valuation basis change and corrections	—		—		(7.3)
Net balance, end of year	416.2		358.8		370.8
Add: reinsurance recoverables	133.2		124.6		51.1
Balance, end of year	$	549.4	$	483.4	$	421.9
____________________

(1) The beginning balance for 2019 includes a $58.2 reserve credit taken in connection with the coinsurance with funds withheld arrangement for certain of the Company's medical stop-loss policies, respectively. Refer to Note 7 for further information.

Liabilities for unpaid claims are recorded in policy and contract claims, life and annuity reserves, and accident and health reserves on the balance sheets. The Company uses estimates in determining its liability for unpaid claims. These estimates are primarily based on historical claim payment patterns and expected loss ratios to provide for the inherent variability in claim patterns and severity. For the year ended December 31, 2020, the change in incurred claims related to prior years was primarily due to favorable claims experience on the Company's medical stop-loss policies, partially offset by unfavorable claims experience on the Company's group life and DI policies.

10. Capital and Surplus

The NAIC establishes certain risk-based capital (RBC) requirements for life and health insurance companies. Under those requirements, the amount of capital and surplus maintained by a life and health insurance company is determined based on various risk factors. As of December 31, 2020 and 2019, the Company met the minimum capital and surplus and RBC requirements.

Under Iowa law, the Company may pay dividends only from the earned surplus arising from its business and must receive the prior approval of the Department to pay stockholder dividends or make any other distribution if such distributions would exceed certain statutory limitations. Iowa law gives the Department discretion to disapprove requests for distributions in excess of these limits. Extraordinary dividends include those made within the preceding twelve months that exceed the greater of (i) 10% of statutory policyholder surplus as of the previous year-end or (ii) the statutory net gain from operations from the previous calendar year. Based on December 31, 2020 statutory results, the maximum dividend that may be paid without prior approval in 2021 is $231.6.

During both 2020 and 2019, the Company did not pay dividends to its Parent. During 2018, the Company paid dividends of $50.0 to its Parent.

36

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The following table presents the cumulative increase (reduction) of unassigned funds related to the following items:

	As of December 31,
	2020		2019
Net unrealized gains	$	66.8	$	33.0
Nonadmitted assets	(133.2)		(118.9)
Separate accounts	176.6		145.8
Asset valuation reserve	(386.4)		(351.1)

11. Income Taxes

The components of DTAs and deferred tax liabilities (DTLs) are as follows:

	As of December 31, 2020						As of December 31, 2019						Change
	Ordinary		Capital		Total		Ordinary		Capital		Total		Ordinary		Capital		Total
Gross DTAs	$	277.4	$	9.2	$	286.6	$	270.1	$	25.4	$	295.5	$	7.3	$	(16.2)	$	(8.9)
DTAs nonadmitted	(78.2)		—		(78.2)		(63.1)		(5.1)		(68.2)		(15.1)		5.1		(10.0)
Subtotal admitted DTAs	199.2		9.2		208.4		207.0		20.3		227.3		(7.8)		(11.1)		(18.9)
Less: DTLs	83.3		14.2		97.5		95.4		19.1		114.5		(12.1)		(4.9)		(17.0)
Net admitted DTAs	$	115.9	$	(5.0)	$	110.9	$	111.6	$	1.2	$	112.8	$	4.3	$	(6.2)	$	(1.9)

The admission calculation components are as follows:

	As of December 31, 2020						As of December 31, 2019						Change
	Ordinary		Capital		Total		Ordinary		Capital		Total		Ordinary		Capital		Total
Federal income taxes paid in prior years recoverable through loss carrybacks	$	—	$	1.4	$	1.4	$	—	$	1.2	$	1.2	$	—	$	0.2	$	0.2
(1) Adjusted gross DTAs expected to be realized following the balance sheet date	111.1		—		111.1		113.3		—		113.3		(2.2)		—		(2.2)
(2) Adjusted gross DTAs allowed per limitation threshold	XXX		XXX		391.5		XXX		XXX		359.3		XXX		XXX		32.2
Adjusted gross DTAs expected to be realized after application of the limitation threshold (lessor of (1) and (2))	111.1		—		111.1		113.3		—		113.3		(2.2)		—		(2.2)
Adjusted gross DTAs offset by gross DTLs	88.1		7.8		95.9		93.7		19.1		112.8		(5.6)		(11.3)		(16.9)
DTAs admitted	$	199.2	$	9.2	$	208.4	$	207.0	$	20.3	$	227.3	$	(7.8)	$	(11.1)	$	(18.9)

As of December 31, 2020 and 2019, respectively, the ratio percentage used to determine the recovery period and limitation threshold amount was 810% and 802%. As of December 31, 2020 and 2019, respectively, the amount of adjusted capital and surplus used to determine the recovery period and limitation threshold amounts were $2,610.2 and $2,395.2. The results of this calculation component enable the Company to admit DTAs expected to reverse within three years, if not previously admitted as a carryback.

The admission calculations for 2020 and 2019 were not impacted by tax-planning strategies. The Company had no unrecognized DTLs as of December 31, 2020 or 2019.

37

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

The components of current income tax expense (benefit) are as follows:

	For the Year Ended December 31,
	2020		2019		2018
Federal income tax expense (benefit)	$	(125.8)	$	(69.5)	$	(12.4)
Federal income tax expense (benefit) on net capital gains (losses)	97.3		90.4		20.0
Federal income tax expense (benefit) incurred	$	(28.5)	$	20.9	$	7.6

The main components of deferred tax amounts are as follows:

	As of December 31,
	2020		2019		Change
DTAs
Ordinary:
Policyholder reserves	$	104.9	$	125.1	$	(20.2)
Investments	40.7		17.2		23.5
Deferred acquisition costs	103.8		91.6		12.2
Receivables - nonadmitted	11.6		10.6		1.0
Tax credit carryforward	9.4		17.8		(8.4)
Other	7.0		7.8		(0.8)
Total ordinary DTAs	277.4		270.1		7.3
Total ordinary DTAs – nonadmitted	(78.2)		(63.1)		(15.1)
Net admitted ordinary DTAs	199.2		207.0		(7.8)
Capital:
Investments	9.2		25.4		(16.2)
Nonadmitted	—		(5.1)		5.1
Net admitted capital DTAs	9.2		20.3		(11.1)
Net admitted DTAs	$	208.4	$	227.3	$	(18.9)
DTLs
Ordinary:
Policyholder reserves	$	64.3	$	75.5	$	(11.2)
Other	19.0		19.9		(0.9)
Total ordinary DTLs	83.3		95.4		(12.1)
Capital:
Investments	14.2		19.1		(4.9)
Total capital DTLs	14.2		19.1		(4.9)
Total DTLs	97.5		114.5		(17.0)
Net DTAs/DTLs	$	110.9	$	112.8	$	(1.9)
Net change in DTA/DTL					$	8.1
Surplus adjustments:
Tax effect of change in unrealized capital gains (losses)					8.8
Tax effect on adoption of IAC 191-97					(9.7)
Adjusted change in net deferred income taxes					$	7.2

The Company expects it will fully realize the DTAs and no statutory valuation allowance has been recorded as of December 31, 2020 or 2019.

38

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

Differences between the federal income tax provision and the change in deferred taxes computed by applying the U.S. federal income tax rate of 21% to the net gain (loss) from operations before federal income taxes and the realized capital losses and the actual tax provision are as follows:

	For the Year Ended December 31,
	2020		2019		2018
Ordinary income tax at federal statutory rate	$	(82.3)	$	(28.4)	$	(26.9)
Capital income tax benefit at federal statutory rate	95.7		91.9		21.8
Total expected income tax expense (benefit)	13.4		63.5		(5.1)
Significant statutory to tax adjustments on taxes:
Tax credits	(26.2)		(35.5)		(40.8)
2018 net operating loss carryback – 2020 CARES Act	(13.9)		—		—
Change in valuation basis – statutory reserves	(3.4)		(4.2)		0.1
Adjustment for deferred tax rate change – 2017 Tax Act	—		—		(8.8)
Impact of reinsurance transactions	—		—		13.2
Other	(5.6)		(4.2)		(4.7)
Total federal income tax expense (benefit)	$	(35.7)	$	19.6	$	(46.1)
Federal income tax expense (benefit)	$	(28.5)	$	20.9	$	7.6
Adjusted change in net deferred income taxes	(7.2)		(1.3)		(53.7)
Total statutory income tax expense (benefit)	$	(35.7)	$	19.6	$	(46.1)

The CARES Act was enacted in 2020, and allows companies to carryback net operating losses (NOLs) originated in 2018, 2019, or 2020 for five years. The Company elected to carryback NOLs originated in 2018 to tax years with a corporate tax rate of 35%, instead of carrying forward to tax years with a corporate tax rate of 21%. This led to an increase in benefit for income taxes of $13.9 for the year ended December 31, 2020.

As of December 31, 2020, the Company had no operating loss or capital loss carryforwards to offset against future taxable income. As of December 31, 2020, the Company had an investment tax credit carryforward of $9.4, which originated in 2020 and will expire during 2040.

The amount of federal income taxes incurred that are available for recovery in the event of the carryback of future net capital losses is as follows:

	For the Year Ended December 31,
	2020		2019		2018
Capital gains	$	4.8	$	22.4	$	—

The Company does not have any deposits admitted under Section 6603 of the Internal Revenue Code. The Company has no tax loss contingencies for which it is reasonably possible that the total liability will significantly increase within twelve months of December 31, 2020.

The Company files income tax returns in the U.S. federal and various state jurisdictions. The Company's consolidated life group federal and state income tax returns are open for examination for tax years 2013 through present.

39

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

12. Separate Accounts

Separate account assets are attributed to the following products:

	As of December 31, 2020						As of December 31, 2019
	Legally Insulated		Not Legally Insulated		Total		Legally Insulated		Not Legally Insulated		Total
BOLI (1)	$	4,751.3	$	171.5	$	4,922.8	$	4,667.3	$	129.3	$	4,796.6
RILA (2)	24.3		310.0		334.3		8.6		123.8		132.4
Variable annuities	557.0		—		557.0		524.6		—		524.6
Variable COLI	533.5		—		533.5		475.8		—		475.8
Variable life and UL	168.2		—		168.2		127.2		—		127.2
Total	$	6,034.3	$	481.5	$	6,515.8	$	5,803.5	$	253.1	$	6,056.6
____________________

(1)The Company allows interest income above the required policy account values within the BOLI separate account. The amount accumulated over and above the required policy account values is not considered to be legally insulated.

(2)For RILA, the Company modified its determination of legally insulated in 2020 to include only contracts issued in Texas, Alaska, and Washington, as those states require the full account value to be legally insulated. Previously, the entire amount accumulated over and above the required policy account values or reserves were not considered to be legally insulated. Prior period amounts were updated to reflect this change.

The fair value of BOLI and RILA invested assets not reported at fair value and related net unrealized gains (losses) are as follows:

	As of December 31,
	2020				2019
	Fair Value		Net Unrealized Gains (Losses)		Fair Value		Net Unrealized Gains (Losses)
BOLI	$	5,413.8	$	527.1	$	5,057.0	$	292.4
RILA	295.3		6.4		124.3		0.8

In accordance with contract provisions relating to the Company’s separate account products, some separate account liabilities are guaranteed by the general account. As of December 31, 2020 and 2019, the separate accounts did not owe the Company for accrued fees or expenses.

The following table provides premium and reserve information for the separate accounts of the Company:

	Nonindexed Guaranteed Less Than/ Equal to 4%		Nonindexed Guaranteed More Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, considerations, or deposits for the year ended December 31, 2020	$	—	$	—	$	261.2	$	261.2
Reserves as of December 31, 2020:
For accounts with assets at:
Fair value	$	—	$	—	$	1,249.3	$	1,249.3
Amortized cost	2,243.1		2,508.2		305.4		5,056.7
Total reserves	$	2,243.1	$	2,508.2	$	1,554.7	$	6,306.0
By withdrawal characteristics:
At book value without fair value adjustment and with current surrender charge of 5% or more	$	—	$	—	$	305.4	$	305.4
At fair value	—		—		1,249.3		1,249.3
At book value without fair value adjustment and with current surrender charge less than 5%	2,243.1		2,508.2		—		4,751.3
Total reserves	$	2,243.1	$	2,508.2	$	1,554.7	$	6,306.0

40

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

	Nonindexed Guaranteed Less Than/ Equal to 4%		Nonindexed Guaranteed More Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, considerations or deposits for the year ended December 31, 2019	$	—	$	—	$	251.3	$	251.3
Reserves as of December 31, 2019:
For accounts with assets at:
Fair value	$	—	$	—	$	1,122.2	$	1,122.2
Amortized cost	2,210.1		2,457.2		115.7		4,783.0
Total reserves	$	2,210.1	$	2,457.2	$	1,237.9	$	5,905.2
By withdrawal characteristics:
At book value without fair value adjustment and with current surrender charge of 5% or more	$	—	$	—	$	115.7	$	115.7
At fair value	—		—		1,122.2		1,122.2
At book value without fair value adjustment and with current surrender charge less than 5%	2,210.1		2,457.2		—		4,667.3
Total reserves	$	2,210.1	$	2,457.2	$	1,237.9	$	5,905.2

	Nonindexed Guaranteed Less Than/ Equal to 4%		Nonindexed Guaranteed More Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, considerations or deposits for the year ended December 31, 2018	$	—	$	—	$	111.3	$	111.3

The following table provides a reconciliation of amounts transferred to and from the separate accounts as reported on the statements of operations:

	For the Year Ended December 31,
	2020		2019		2018
Transfers to separate accounts	$	571.6	$	424.7	$	297.1
Transfers from separate accounts	(474.8)		(352.2)		(333.8)
Net transfers to (from) separate accounts	96.8		72.5		(36.7)
Deposits in free look period and other timing differences	(0.4)		(2.7)		2.4
Net transfers to (from) separate accounts as reported on statements of operations	$	96.4	$	69.8	$	(34.3)

13. Related Parties

The following discussion relates to transactions entered into by the Company with related parties and affiliates. Refer to Note 7 for further discussion on reinsurance agreements with related parties.

It is the Company's policy to settle amounts due with affiliated companies within 30 days, except for certain long-term compensation liabilities that are settled when the awards are paid. Transactions with related parties recorded in the Company's financial statements were as follows:

	As of December 31,
	2020		2019
Balances with Parent and affiliates:
Receivables	$	0.7	$	20.8
Payables	(26.2)		(20.3)

The Company's affiliate, Symetra Assigned Benefits Service Company (SABSCO), purchased future payment streams of structured settlement annuity contracts issued by the Company from third-party payees. These contracts were assigned to and

41

SYMETRA LIFE INSURANCE COMPANY

NOTES TO FINANCIAL STATEMENTS – STATUTORY BASIS

(All dollar amounts in millions unless otherwise stated)

owned by SABSCO. The Company issued commutation endorsements to pay SABSCO lump sum amounts in lieu of receiving the future payment streams in the structured settlement annuity contracts and released its reserves related to the contracts.

The Company has entered into various agreements with the Parent and its affiliates for services necessary to conduct its activities. These agreements specify that the parties will provide to and receive from each other certain general services related to sharing common management, personnel, and facilities, and that the related expenses will be shared. These expenses include rent, payroll, benefits, data processing systems, and other charges. General service expenses are allocated among legal entities using various methodologies that management believes to be reasonable to estimate service utilization, including headcount, time studies, or relevant activity levels.

During 2020, the Company entered into an Investment Management Agreement with its affiliate, Symetra Investment Management Company, a subsidiary of Symetra Financial Corporation. The agreement provides for investment advisory services related to the Company’s invested assets, including the Company's mortgage loan portfolio. In addition, the Company paid concessions, general agent fees, administrative, and underwriting fees for services provided by its affiliates, primarily to Symetra Securities, Inc.

During 2020, the Company received a cash capital contribution of $300.0 from its Parent.

	For the Year Ended December 31,
	2020		2019		2018
Transactions with Parent and affiliates:
Payments for investment management services	$	45.2	$	—	$	—
Payments related to commutation endorsements (1)	2.9		5.3		5.6
Shared services expenses (allocated) payments, net (2)	(16.3)		(0.7)		(0.2)
Payments for concessions, general agent fees, administrative, and underwriting fees (3)	16.2		15.3		10.2
___________________

(1)Commutation endorsements paid to SABSCO reduce the reserves reported in life and annuity reserves on the balance sheets and surrender and maturity benefits on the statements of operations, net of related payments.

(2)Reported primarily in general insurance expenses on the statements of operations.

(3)Reported primarily in commissions on the statements of operations.

14. Commitments and Contingencies

Litigation

Because of the nature of its business, the Company is subject to legal actions filed or threatened in the ordinary course of its business operations. The Company establishes liabilities for litigation and regulatory actions when it is probable that a loss has been incurred and the amount of the loss can be reasonably estimated. For matters where a loss is believed to be reasonably possible, but not probable, no liability is established. For such matters, the Company may provide an estimate of the possible loss or range of loss or a statement that such an estimate cannot be made. The Company reviews relevant information with respect to litigation and regulatory matters on a quarterly basis and updates its established liabilities, disclosures, and estimates of reasonably possible losses or range of loss based on such reviews.

Although the Company cannot predict the outcome of any litigation or regulatory action, the Company does not believe that any such matters will have an impact on its financial condition or results of operations that differs materially from the Company’s established liabilities. However, given the inherent difficulty in predicting the outcome of such matters, it is possible that an adverse outcome in certain such matters could be material to the Company’s financial condition or results of operations for any particular reporting period.

Other Commitments

The Company has committed to provide future capital contributions for investments in limited partnerships related to its alternative investments. As of December 31, 2020 and 2019, the amount of these unfunded commitments was $272.1 and $326.5, respectively.

As of December 31, 2020 and 2019, unfunded mortgage loan commitments were $20.0 and $82.2, respectively. The Company had no other material commitments or contingencies as of December 31, 2020 or 2019.

42

SYMETRA SEPARATE ACCOUNT C

PART C

OTHER INFORMATION

Item 27. Exhibits

Exhibit		Description	Reference
a.		Resolution of Board of Directors of Symetra Life authorizing the Separate Account	23/
b.		Not Applicable
c.	(1)	Principal Underwriter's Agreement, As Amended	23/
	(2)	Broker-Dealer Selling Agreement	11/
d.		Individual Flexible Premium Deferred Variable Annuity Contract (05/05)	22/
		Earnings Enhancement Benefit Rider (05/05)	22/
		Guaranteed Minimum Death Benefit – Annual Reset Rider (05/05)	22/
		457 Contract (05/05)	6/
		TSA Endorsement (Loan -08/09)	22/
		TSA Endorsement (No Loan -04/09)	22/
		SEP IRA/Simple IRA/TSA Contract Data Page (05/05)	22/
		Traditional and Roth IRA Contract Data Page (05/05)	22/
		Non-Qualified Contract Data Page (05/05)	22/
		IRA, Roth & SEP Endorsement (12/11)	20/
		Simple IRA Endorsement (12/11)	20/
e.		Application for Annuity Contract (Non-Qualified - 08/10)	22/
		Application for Annuity Contract (457 - 05/09)	22/
		Application for Annuity Contract (TSA - 05/09)	22/
f.	(1)	Amended and Restated Articles of Incorporation of Symetra Life Insurance Company	19/
	(2)	Bylaws of Symetra Life Insurance Company Effective July 1, 2014	19/
g.	(1)	Reinsurance Agreement and Amendments 1-2 (GMDB)	18/
	(2)	Reinsurance Agreement and Amendments 1-3 (GMDB/EEB)	18/
h.	(1)	Participation Agreement (ACVP)	5/
		Amendment No. 1 to Participation Agreement (ACVP)	5/
		Amendment No. 2 to Participation Agreement (ACVP)	5/
		Amendment No. 3 to Participation Agreement (ACVP)	5/
		Amendment No. 4 to Participation Agreement (ACVP)	7/
		Amendment No. 5 to Participation Agreement (ACVP)	9/
		Amendment No. 6 to Participation Agreement (ACVP)	15/
		Amendment No. 7 to Participation Agreement (ACVP)	15/
		Amendment No. 8 to Participation Agreement (ACVP)	15/
		Amendment No. 9 to Participation Agreement (ACVP)	15/
		Amendment No. 10 to Participation Agreement (ACVP)	23/
		Amendment No. 11 to Participation Agreement (ACVP)	1/
	(2)	Participation Agreement (AIM/INVESCO)	5/

1

Exhibit		Description	Reference
		Amendment No. 1 to Participation Agreement (AIM)	7/
		Amendment No. 2 to Participation Agreement (AIM)	18/
		Amendment No. 3 to Participation Agreement (AIM)	18/
		Amendment No. 4 to Participation Agreement (AIM)	6/
		Amendment No. 5 to Participation Agreement (AIM)	6/
	(3)	Participation Agreement and Amendments 1-2 (FIVIT-Morningstar)	1/
	(4)	Participation Agreement (Eaton Vance - CVP)	4/
	(5)	Participation Agreement (Eaton Vance - CVS)	4/
	(6)	Participation Agreement and Amendments 1-5 (Dreyfus)	23/
	(7)	Participation Agreement (Deutsche)	18/
		Amendment No. 1 to Participation Agreement (Deutsche)	23/
		Amendment No. 2 to Participation Agreement (Deutsche)	3/
		Amendment No. 3 to Participation Agreement (Deutsche)	1/
	(8)	Amended and Restated Participation Agreement (Federated)	6/
		Amendment No. 1 to Participation Agreement (Federated)	6/
	(9)	Participation Agreement (Fidelity)	12/
		Amendment No. 1 to Participation Agreement (Fidelity)	17/
		Amendment No. 2 to Participation Agreement (Fidelity)	23/
		Amendment No. 3 to Participation Agreement (Fidelity)	21/
		Amendment No. 4 to Participation Agreement (Fidelity)	20/
		Amendment No. 5 to Participation Agreement (Fidelity)	14/
	(10)	Participation Agreement (Franklin Templeton)	5/
		Amendment No. 1 to Participation Agreement (FRK)	5/
		Amendment No. 2 to Participation Agreement (FRK)	5/
		Amendment No. 3 to Participation Agreement (FRK)	8/
		Amendment No. 4 to Participation Agreement (FRK)	8/
		Amendment No. 5 to Participation Agreement (FRK)	9/
		Amendment No. 6 to Participation Agreement (FRK)	15/
		Amendment No. 7 to Participation Agreement (FRK)	15/
		Amendment No. 8 to Participation Agreement (FRK)	23/
		Amendment No. 9 to Participation Agreement (FRK)	21/
		Amendment No. 10 to Participation Agreement (FRK)	20/
		Amendment No. 11 to Participation Agreement (FRK)	15/
	(11)	Participation Agreement (J.P. Morgan Insurance Trust)	15/
		Amendment No. 1 to Participation Agreement (J.P. Morgan)	20/
		Amendment No. 2 to Participation Agreement (J.P. Morgan)	15/
		Amendment No. 3 to Participation Agreement (J.P. Morgan)	20/
	(12)	Participation Agreement (Neuberger Berman)	18/
	(13)	Participation Agreement (PIMCO)	9/
		Amendment No. 1 to Participation Agreement (PIMCO)	23/

2

Exhibit		Description	Reference
		Amendment No. 2 to Participation Agreement (PIMCO)	13/
		Amendment No. 3 to Participation Agreement (PIMCO)	23/
		Novation to Participation Agreement (PIMCO)	21/
		Amendment No. 4 & 5 to Participation Agreement (PIMCO)	20/
	(14)	Participation Agreement (Pioneer)	23/
		Amendment to Participation Agreement (Pioneer)	10/
		Amendment No. 2 to Participation Agreement (Pioneer)	15/
		Amendment No. 3 to Participation Agreement (Pioneer)	18/
		Amendment No. 4 to Participation Agreement (Pioneer)	15/
		Amendment No. 5 to Participation Agreement (Pioneer)	20/
	(15)	Participation Agreement (Voya)	2/
i.		Not Applicable
j.		Not Applicable
k.		Opinion and Consent of Counsel	23/
l.	(1)	Consent of KPMG LLP, Independent Auditor	Filed Herewith
	(2)	Consent of Ernst & Young LLP	Filed Herewith
m.		Not Applicable
n.		Not Applicable
0.		Not Applicable
Reference		Description
1/		Incorporated by reference to Post-Effective Amendment No. 36 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2018 (File No. 33-69712).
2/		Incorporated by reference to Post-Effective Amendment No. 34 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2016 (File No. 33-69712).
3/		Incorporated by reference to Post-Effective Amendment No. 46 on Form N-4 registration statement of Symetra Resource Variable Account B filed with the SEC on April 30, 2013 (File No. 333-178461).
4/		Incorporated by reference to Post-Effective Amendment No. 35 on Form N-4 registration statement of Registrant filed with the SEC on April 27, 2017 (File No. 33-69712).
5/		Incorporated by reference to Post-Effective Amendment No. 21 on Form S-6 registration statement of Symetra Separate Account SL filed with the SEC on April 30, 2002 (File No. 333-30329).
6/		Incorporated by reference to Post-Effective Amendment No. 31 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2014 (File No. 33-69712).
7/		Incorporated by reference to Post-Effective Amendment No. 26 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on April 30, 2003 (File No. 333-30329).
8/		Incorporated by reference to Post-Effective Amendment No. 17 on Form N-4 registration statement of Registrant filed with the SEC on December 3, 2004 (File No. 33-69712).
9/		Incorporated by reference to Post-Effective Amendment No. 30 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on April 29, 2005 (File No. 333-30329).

3

Exhibit	Description	Reference
10/	Incorporated by reference to Post-Effective Amendment No. 22 on Form N-4 registration statement of Registrant filed with the SEC on March 20, 2006 (File No. 33-69712).
11/	Incorporated by reference to Post-Effective Amendment No. 33 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2015 (File No. 33-69712).
12/	Incorporated by reference to Post-Effective Amendment No. 34 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on April 30, 2007 (File No. 333-30329).
13/	Incorporated by reference to Post-Effective Amendment No. 1 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on April 30, 2007 (File No. 333-136776).
14/	Incorporated by reference to Post-Effective Amendment No. 47 on Form N-4 registration statement of Resource Variable Account B filed with the SEC on April 30, 2014 (File No. 333-178461).
15/	Incorporated by reference to Post-Effective Amendment No. 2 on Form N-6 registration statement of Symetra Separate Account SL filed with the SEC on August 15, 2007 (File No. 333-136776).
16/	Incorporated by reference to Post-Effective Amendment No. 30 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2013 (File No. 33-69712).
17/	Incorporated by reference to Post-Effective Amendment No. 1 on Form N-4 registration statement of Registrant filed with the SEC on January 31, 2008 (File No. 333-137411).
18/	Incorporated by reference to Post-Effective Amendment No. 25 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2008 (File No. 33-69712).
19/	Incorporated by reference to Post-Effective Amendment No. 32 on Form N-4 registration statement of Registrant filed with the SEC on July 2, 2014 (File No. 33-69712).
20/	Incorporated by reference to Post-Effective Amendment No. 29 on Form N-4 registration statement of Registrant filed with the SEC on April 30, 2012 (File No. 33-69712).
21/	Incorporated by reference to Post-Effective Amendment No. 28 on Form N-4 registration statement of Registrant filed with the SEC on April 29, 2011 (File No. 33-69712).
22/	Incorporated by reference to Post-Effective Amendment No. 27 on Form N-4 registration statement of Registrant filed with the SEC on April 29, 2010 (File No. 33-69712).
23/	Incorporated by reference to Post-Effective Amendment No. 38 on Form N-4 registration statement of Registrant filed with the SEC on April 29, 2020 (File No. 33-69712).

Item 28. Directors and Officers of the Depositor

Set forth below is a list of each director and officer of Symetra Life who is engaged in activities relating to Symetra Separate Account C or the variable annuity Contracts offered through Symetra Separate Account C.

Name	Positions with Symetra	Principal Business Address
Ashlock, Dena S.	Senior Vice President, Chief Actuary and Chief Risk Officer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Balkovetz, Chantel L.	Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Bouvier II, Phillippe D.	Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

4

Name	Positions with Symetra	Principal Business Address
Brooks, Tommie D.	Director, Chief Financial Officer and Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Chandler, Darlene K.	Senior Vice President and Associate General Counsel	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Falls, Stephanie A.	Vice President and Deputy Chief Compliance Officer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Fry, Stephanie L.	Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Henderson, Maureen H.	Senior Vice President and Chief Compliance Officer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Herzberg, Keren A.	Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Hunt, Mark E.	Director, Chief Investment Officer and Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Diouf, Anne-Marie	Senior Vice President and Chief Human Resources Officer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Kneisley, Joel C.	Senior Vice President and Chief Information Officer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
LaVoice, Richard G.	Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Meister, Margaret A.	Director and President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Murphy, Colleen M.	Senior Vice President, Controller and Treasurer	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Sasagawa, Muneo	Director	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Sho, Tetsuya	Director	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Smolinksi, Richard P.	Senior Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Stenberg, Jon S.	Director and Executive Vice President	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004
Veneziani, Jacqueline M.	Director, Senior Vice President, General Counsel, Chief Compliance Officer of the Separate Account and Secretary	777 108th Avenue NE, Suite 1200 Bellevue, WA 98004

Item 29. Persons Controlled By or Under Common Control with the Depositor or Registrant

No person is directly or indirectly controlled by Symetra Separate Account C (“Registrant”). Symetra Life established Registrant by resolution of its Board of Directors. Symetra Life is a wholly owned subsidiary of Symetra Financial Corporation. Symetra Financial Corporation is organized under Delaware law and Symetra Life is organized under Iowa law. All subsidiaries are included in the financial statements. Following is the organizational chart of Symetra Financial Corporation.

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Item 30. Indemnification

As more fully set forth in its Bylaws, Symetra Life, to the maximum extent it is empowered by the Iowa Business Corporation Act, Iowa Code Chapter 490, shall indemnify and advance expenses to any person who was or is a party to or is threatened to be made a party to any threatened, pending or completed claim, action, suit or proceeding, whether civil, criminal, administrative or investigative (including a grand jury proceeding) and whether formal or informal, by reason of the fact that such person (a) is or was a director or officer of the corporation, or (b) while a director or officer of the corporation, is or was serving at the request of the corporation as a director, officer, employee, agent, partner or trustee (or in a similar capacity) of another corporation, partnership, joint venture, trust, other enterprise, or employee benefit plan, against reasonable expenses (including attorneys’ fees), judgments, fines, penalties, including an excise tax assessed with respect to an employee benefit plan, and amounts paid in settlement actually and reasonably incurred by such person in connection with such claim, action, suit or proceeding or any appeal thereof.

Under certain Director and Officer Indemnification Agreements (“Agreement(s)”) between Symetra Life’s parent company, Symetra Financial Corporation, and directors and/or certain officers of Symetra Life (“Indemnitees”), Symetra Financial Corporation indemnifies and holds harmless Indemnitees, to the full extent permitted by the laws of the State of Delaware in effect at the time the Agreement is effective or as such laws may from time to time be amended, against all Indemnifiable Losses related to, resulting from or arising out of any Claim (subject to certain exceptions) where:

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1.“Claim” means any threatened, pending or completed action, suit or proceeding, whether civil, criminal, administrative, arbitrative, investigative or other, in which the Indemnitee is a party or reasonably could be made a party, is threatened to be made a party or is involved by reason of the fact that (i) Indemnitee is or was a director, officer, employee or agent of the Company and/or of a subsidiary of the Company, or (ii) Indemnitee is or was serving at the request of the Company as a director, officer, employee or agent of another corporation, partnership, non-profit organization, joint venture, trust or other enterprise. Inclusion of the Indemnitee’s role with such an enterprise (including, for example, service on the board of directors of a non-profit organization) on a list approved from time to time by the Chief Executive Officer or Chief Financial Officer of the Company shall constitute service “at the request of the Company” for purposes of clause (ii) in the preceding sentence.

2.“Expenses” includes all direct and indirect costs and expenses of any type whatsoever (including without limitation all attorneys’ and experts’ fees, expenses and charges) and all other costs, expenses and obligations actually and reasonably paid or incurred by Indemitee in connection with investigating, defending, being a witness in or participating in (including on appeal), or preparing to investigate, defend, be a witness in or participate in, any Claim; and

3.“Indemnifiable Losses” means any and all Expenses, damages, losses, liabilities, judgments, fines, penalties and amounts paid in settlement (including without limitation all interest, assessments and other charges paid or payable in connection with or in respect of any of the foregoing) (collectively, “Losses”) reasonably incurred by Indemnitee relating to, resulting from or arising out of any Claim.

Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of Symetra Life pursuant to such provisions of the bylaws, statutes, agreements, or otherwise, Symetra Life has been advised that in the opinion of the SEC, such indemnification is against public policy as expressed in said Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by Symetra Life or Symetra Financial Corporation of expenses incurred or paid by a director, officer or controlling person of Symetra Life in the successful defense of any such action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the Contracts issued by the Separate Account, Symetra Life will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in said Act and will be governed by the final adjudication of such issue.

Item 31. Principal Underwriters

a.Symetra Securities, Inc., the principal underwriter for the Contracts, also acts as the principal underwriter for other Symetra Life individual variable annuity Contracts, Symetra Life’s group variable annuity Contracts, and Symetra Life's individual flexible premium variable life insurance policies.

b. The following information is provided for each officer and director of the principal underwriter:

Name	Positions and Offices with Underwriter	Principal Business Address
Balkovetz, Chantel L.	Director	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Bodmer, Julie M.	Assistant Secretary	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Brooks, Tommie D.	Director	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Ellis, Courtney L.	Chief Operating Officer	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Farrell, Andrew M.	Chairman of the Board and President	777 108th Ave NE, Suite 1200 Bellevue, WA 98004

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Name	Positions and Offices with Underwriter	Principal Business Address
Hansen Jr., Stewart J.	Assistant Secretary	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Murphy, Colleen M.	Chief Financial Officer, Treasurer and Financial and Operations Principal	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Norberg, Kristin R.	Vice President	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Pessoa, Melissa	Assistant Treasurer	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Rabin, Kevin W.	Director	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Sanders, Barbara	Chief Compliance Officer	777 108th Ave NE, Suite 1200 Bellevue, WA 98004
Veneziani, Jacqueline M.	Secretary	777 108th Ave NE, Suite 1200 Bellevue, WA 98004

c.    During the fiscal year ended December 31, 2020, Symetra Securities, Inc. received $1,095,625 in commissions for the distribution of certain annuity Contracts sold in connection with Registrant of which no payments were retained. Symetra Securities, Inc. did not receive any other compensation in connection with the sale of Registrant's Contracts.

Item 32. Location of Accounts and Records

Symetra Life Insurance Company at 777 108th Avenue NE, Suite 1200, Bellevue, Washington 98004 maintains physical possession of the accounts, books or documents of the Separate Account required to be maintained by Section 31(a) of the Investment Company Act of 1940 and the rules promulgated thereunder.

Item 33. Management Services

Not Applicable

Item 34. Fee Representation

Pursuant to the Investment Company Act of 1940, Symetra Life represents that the fees and charges deducted under the Contract, in the aggregate, are reasonable in relation to the services rendered, the expenses expected to be incurred, and the risks assumed by Symetra Life.

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SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant has duly caused this Registration Statement to be signed on its behalf, in the City of Bellevue and State of Washington, on this 21st day of April, 2021.

Symetra Separate Account C

                        Registrant

                By:    Symetra Life Insurance Company

                By:    Margaret A. Meister

                    Margaret A. Meister, Director

Symetra Life Insurance Company

                        Depositor

                By:    Margaret A. Meister

                    Margaret A. Meister, Director

Pursuant to the requirement of the Securities Act of 1933, this Registration Statement has been signed below by the following persons in the capacities and on the date indicated below.

NAME	TITLE	DATE
Tommie D. Brooks Tommie D. Brooks	Director, Chief Financial Officer,Executive Vice President (Principal Accounting Officer & Principal Financial Officer)	April 21, 2021
Mark E. Hunt Mark E. Hunt	Director, Chief Investment Officer and Executive Vice President	April 21, 2021
Margaret A. Meister Margaret A. Meister	Director and President (Principal Executive Officer)	April 21, 2021
Muneo Sasagawa Muneo Sasagawa	Director	April 21, 2021
Tetsuya Sho Tetsuya Sho	Director	April 21, 2021
Jon S. Stenberg Jon S. Stenberg	Director and Executive Vice President	April 21, 2021
Jacqueline M. Veneziani Jacqueline M. Veneziani	Director, General Counsel, Senior Vice President and Secretary	April 21, 2021

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EXHIBITS

Filed Herewith

Exhibit		Description
l.	(1)	Consent of KPMG LLP, Independent Auditor
	(2)	Consent of Ernst & Young LLP

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