Subject: File No. S7-23-18
From: anonymous anonynous

December 26, 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 :
d. Other Benefits Available Under the Contract : Least Useful : Need more information about benefits
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?
Yes

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

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 : Very Unlikely
Standard death benefit: Very Unlikely
Optional insurance features (also called optional benefits or riders) : Very Unlikely
Fees (how much the variable annuity costs) : Very Unlikely
Mechanics of how a variable annuity works (how to purchase, accessing money, annuitization, etc.) : Very 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?
Tell us more about the funds. A summary prospectus tells investors about risks, this document does not. For instance, without some risk disclosure, an investor may think an asset-backed security is safer than a corporate bond because it is backed, when that is rarely the case. I realize the mutual fund summary prospectus does not do that great a job, but a measure of the relatie risks would be helpful (such as low, medium, high).

Do not disclose objectives of the fund, instead disclosure the primary asset class. Objectives are nearly always total return and not a good differentiator between funds.