Subject: File No. S7-23-18
From: Christopher Viscomi

December 4, 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 : information most relevant to the consumer, particularly if standardized to compare annuities
g. Additional Information About Fees : Most Useful : high fees often negate benefit of annuity

3. The sample summary prospectus includes a section named Overview of the Variable Annuity Contract. Does that section provide clear information?
No
If no, what other information would make this clearer? : plain English lists of costs, including fund fees and commissions

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?

B. Does the sample summary prospectus describe the extra fees associated with these optional benefits clearly?

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?

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 :
Standard death benefit:
Optional insurance features (also called optional benefits or riders) :
Fees (how much the variable annuity costs) :
Mechanics of how a variable annuity works (how to purchase, accessing money, annuitization, etc.) :

9. Is the length of the document:
Too short
If the length is not appropriate, why not?

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?
I think it is critical to know the exact conflicts of interest of the salesperson. Exactly how much commission and exactly what additional incentives. This allows me insight into specific recommendations the salesperson makes to see if they seem to reflect fiduciary or self-serving behavior.