Subject: File No. S7-23-18
From: Betsy Nedar

November 6, 2018

VARIABLE ANNUITY SUMMARY PROSPECTUS

1. Have you ever considered purchasing a variable annuity? : yes

2. The sample summary prospectus is divided into eight sections. Please indicate which two sections you found to be the most useful, and which two sections you found to be the least useful, in describing the variable annuity
a. Overview of the Variable Annuity Contract : Least Useful :
b. Important Information You Should Consider About the Contract : Most Useful :
c. Standard Death Benefit : Least Useful :
h. Portfolio Companies Available Under Your Contract : Most Useful :

3. The sample summary prospectus includes a section named Overview of the Variable Annuity Contract. Does that section provide clear information?
Yes

4. The section named Important Information You Should Consider About the Contract includes a table. Do you think the table is clear?
Yes

5. The sample summary prospectus describes what you would pay for the variable annuity, including upfront fees and future fees. Was this description clear?
Yes

6. Variable annuities may offer optional insurance benefits that you can purchase for extra fees. The sample summary prospectus describes these optional benefits.
A. Does the sample summary prospectus describe these optional benefits clearly?
No
If no, what other information would make this clearer?
Investors should be told more about the benefit, like that you can withdraw 6% each year for the rest of your life.
B. Does the sample summary prospectus describe the extra fees associated with these optional benefits clearly?
No
If no, how could we make this clearer?
Are the fees current fees or maximum fees? These fees can change. It sees odd that the optional fees are show 3 times in what is supposed to be a summary document (in the key information section, in the optional features section, and in the fee table).

7. When you purchase a variable annuity, you decide how to invest your money by selecting one or more available mutual funds. The sample summary prospectus includes a table of mutual funds that are available as investment options. Does this table provide the information that you would want to consider when choosing mutual funds?
Yes

8. After reading the sample summary prospectus, how likely would you be to request the full prospectus for more information on the following topics?
Investment options (mutual funds) offered under the variable annuity : Likely
Standard death benefit: Neither Likely Nor Unlikely
Optional insurance features (also called optional benefits or riders) : Neither Likely Nor Unlikely
Fees (how much the variable annuity costs) : Likely
Mechanics of how a variable annuity works (how to purchase, accessing money, annuitization, etc.) : Neither Likely Nor Unlikely

9. Is the length of the document:
Too short
If the length is not appropriate, why not?
Tell me a little more about the various benefits such as, how much is the benefit.

10. How would you prefer to receive/read a document like the sample summary prospectus?
A combination of paper and digital

11. Do you have any additional suggestions for improving the summary prospectus? Is there anything else you would like to tell us about your experience with variable annuities?
Annuitizing your contract is a separate investment decision you make many years down the road. If you want to annuitize you should compare the payouts offered under your annuity verse other annuities (single premium immediate annuities) that are on the market. The rates vary considerably and change over time.

Your summary prospectus, and your investor.gov document should describe this.