Subject: File No. S7-23-18
From: Yassi Abdullah

December 31, 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 : the standard death benefit isn't such a big deal under my contract.
d. Other Benefits Available Under the 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?
No
If no, how could we make this clearer?
It should tell me the amount of the nenefit.

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 : Unlikely
Standard death benefit: Unlikely
Optional insurance features (also called optional benefits or riders) : Likely
Fees (how much the variable annuity costs) : Neither Likely Nor 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:
About right

10. How would you prefer to receive/read a document like the sample summary prospectus?
A combination of paper and digital

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?
Keep it simple, but do a better job of explaining the features. This should not be too hard in 15 pages.

I also think the sample product is overly simple. Good for illustrative purposes, but not representatives of the number of options available through the annuities considered.