Subject: File No. S7-23-18
From: Lisa LeRoy

November 9, 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
b. Important Information You Should Consider About the Contract : Most Useful :
c. Standard Death Benefit : Least Useful :
d. Other Benefits Available Under the Contract : 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?
No
If no, what other information would make this clearer?
Fees often change over time. I am not sure that comes across. I also do not k kw whether certain charges or the current charges or max charges (like in the optional benefits table).

Not sure how certain charges, like fund facilitation fees would show up in the up front summary table.

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?
If does not help you differentiate multiple similar riders. They may sound exactly the same.
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 they current or max fees. Should explain that as contract value is reduced, the fee increases exponentially.

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 : Neither Likely Nor Unlikely
Standard death benefit: Unlikely
Optional insurance features (also called optional benefits or riders) : Neither Likely Nor Unlikely
Fees (how much the variable annuity costs) : Unlikely
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?
Needs a little more info about the optional benefits and funds.

10. How would you prefer to receive/read a document like the sample summary prospectus?
In an email

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?
Make it web friendly. Tabs on a website for each item, not a long PDF.

The posting requirements are long and rigid. It should be a page and principles based.