Subject: File No. S7-23-18
From: Jill Lydos

January 2, 2019

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 :
e. Buying Your Contract : Least Useful : My financial planner and the application walk me through this.
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 : Neither Likely Nor Unlikely
Standard death benefit: Very Unlikely
Optional insurance features (also called optional benefits or riders) : Neither Likely Nor Unlikely
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?
Other (explain)
If other (explain)
email and a website
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?
Yes, I think there are other important risks not picked up by the sample summary prospectus:
If you own a joint contract and get a divorce, many of the insurance benefits are rendered worthless. With divorce rates exceeding 50%, that is a big deal.
If you own a qualified contract with a withdrawal benefit, the withdrawal amount may not be sufficient to cover RMDs, and if you take RMDs, the insurance benefits will be hurt.

For variable life contracts, there is usually an exclusion for suicide.
For contracts with long-term care, disability, or accelerated death benefits, like all disability claims, the insurance company will deny your first request and you are likely not in the best spot (since you are dying) to pick a fight.