Subject: File No. S7-23-18
From: Anonymous Anonymous

December 28, 2018

I support your efforts to streamline the variable annuity summary prospectus. I have the following additional thoughts:

I think there need to be more disclosure about the available optional benefits such as how much I can withdraw each year under those riders. In addition, it would be nice if insurers had programs that let me withdraw the most I can under a rider while maintaining the rider. One was the SEC can force this is to require disclosure about such programs, or if the insurance company does not offer one, have them explain why the do not. That is, shame them into good practices.

Why do variable annuity investors get less fund information delivered to them about a fund investment than a direct investor in the fund? I do not disagree with the approach or disclosures (it is similar to what I get with my 401K). However, I do not know why you are taking such an approach. Is this the first step and retail mutual funds are next?

Do not be so prescriptive with web posting requirements. Instead, take a principles-based approach.

Do not be so prescriptive about the format of contents. The disclosure requirements appear to be paper-based. Instead permit flexibility, such as a website with tabs for each section instead of a serial document. In addition, amend rule 497 so that products can make prospectuses more interactive and personalized without the need to fie every single variation on EDGAR.

Take greater efforts to plain English the form. For instance: State the commissions paid to dealers as a percentage of purchase payments is not plain English. I do not know what a 'dealer' is. Instead ask how selling firms and financial professionals are compensated. Also, do not limit the disclosure to a percentage of purchase payments. There should be disclosure about upfront and trail commissions as well as other methods of compensations such as competitions, prized, bonuses, vacations, etc..

The release stresses that 97% of investors purchase a variable annuity through a financial professional and this supports the idea that less disclosure may be necessary. However, younger investors are increasingly moving away from financial professionals. In addition, certain insurance companies (like Ohio National) are dumping their financial professional network and leaving investors without the help they need to understand the mechanics of these products. As such, it is important that the SEC make it as easy as possible for investors to make financial decisions and not rely so heavily on that 97% figure.

I also question the merits of any XBRL proposal. I believe the release insufficiently describes what the Commission has in kind with respect to any XBRL requirements. The release mentions sections that should be tagged, but makes no mention of how detailed that tagging would be. There is no taxonomy in existence and it would be exceptionally difficult to develop a taxonomy for these products with their bespoke features. In addition, XBRL is hardly used in the fund context so it would be odd to include such a requirement for variable products.

Finally, and on another point, the Commission should provide more guidance on how insurance companies should comply with the requirements of Form N-CEN. The industry has been seeking guidance with respect to items F.13 and F.14 of Form N-CEN for more than 8 months. It is unclear how insurance products should respond to these questions. For example, how should item F.14 treat amounts allocated to the fixed account or moved between the variable and fixed accounts.