Subject: File No. S7-23-18
From: Jeremy Topolski

November 16, 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 : Most Useful :
e. Buying Your Contract : Least Useful :
f. Surrendering Your Contract or Making Withdrawals: Accessing the Money in Your Contract : Least Useful :
g. Additional Information About Fees : Most Useful :

3. The sample summary prospectus includes a section named Overview of the Variable Annuity Contract. Does that section provide clear information?
Yes
If no, what other information would make this clearer? :

4. The section named Important Information You Should Consider About the Contract includes a table. Do you think the table is clear?
Yes
If no, what other information would make this clearer? Would you prefer to see the information in a different format (other than a table)?

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
If no, what other information would make this clearer?

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?
Yes
If no, what other information would make this clearer?

B. Does the sample summary prospectus describe the extra fees associated with these optional benefits clearly?
Yes
If no, how could we make this clearer?

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
If no, what other information would make this clearer? Would you prefer to see the information in a different format (other than a table)?

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 : Very Likely
Standard death benefit: Likely
Optional insurance features (also called optional benefits or riders) : Likely
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:
About right

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?
This is a good start. The current disclosure is way more information than is needed or is useful. More needs to be done to improve the full length prospectus. As it is, a great deal of information is provided but there is so much, it's discarded and does not serve the intended purpose. Get rid of all the many years of fund prices in the back. It's not helpful. Re-work the information that is included in annual and semi-annual reports and Statement of Additional Information. The information that is here is unable to be understood by a person who isn't either an accountant or an actuary. Stick to what is relevant to an average consumer and nothing more.I don't need years of financial data around what investments are held in the general account or that back the various benefits. It's not helpful in making an investment decision and most people don't read it.