false 9876543210 9876543210 2024-09-30 2024-09-30 9876543210 vip:CapRateReturnLimitMember 2024-09-30 2024-09-30 9876543210 vip:ParticipationRateReturnLimitMember 2024-09-30 2024-09-30 9876543210 vip:BufferRateReturnLimitMember 2024-09-30 2024-09-30 9876543210 rila00:IndexGuardStrategyMember 2024-09-30 2024-09-30 9876543210 vip:NotShortTermInvestmentRiskMember 2024-09-30 2024-09-30 9876543210 vip:EarlyWithdrawalRiskMember 2024-09-30 2024-09-30 9876543210 vip:MarketRiskMember 2024-09-30 2024-09-30 9876543210 vip:InvestmentOptionsRiskMember 2024-09-30 2024-09-30 9876543210 rila00:Shield10OptionMember 2024-09-30 2024-09-30 9876543210 rila00:Shield15OptionMember 2024-09-30 2024-09-30 iso4217:USD xbrli:shares iso4217:USD xbrli:shares xbrli:pure utr:Y

Form N-4

OSD Test Company #1

THIS DOCUMENT IS A TECHNICAL ILLUSTRATION OF HOW CERTAIN DISCLOSURES IN SEC FILINGS ARE TO BE TAGGED. IT DOES NOT INDICATE WHICH PARTICULAR DISCLOSURES MUST BE INCLUDED AND/OR TAGGED IN COMMISSION FILINGS, AND IT DOES NOT CONSTITUTE LEGAL GUIDANCE OF ANY SORT.

9/30/2024

Item 2(b)(2)/2(d)

(b) Phases of Contract. Briefly describe the accumulation (savings) phase and annuity (income) phase of the Contract.

(2) With respect to any Index-Linked Option currently offered under the Contract, include the following information.

The Accumulation Phase

You should consider the following important features of the accumulation phase:

| • |  | Index-Linked and Fixed Interest Investment Options. To help you accumulate assets during the accumulation phase, you can invest your premium payments in (and at certain times transfer Policy Value among) the Policy’s available investment options. The available investment options currently include certain index-linked investment options (“Index Account Options”) and a fixed interest option (“Fixed Account Option”) (together “Allocation Accounts”). The performance of your Policy will vary depending on the performance of the Allocation Accounts that you choose. Each Allocation Account has its own unique risks.

If you invest in an Index Account Option, the Index Account Option’s downside protection may not fully protect you from loss. Your losses could be significant.

See AVAILABLE ALLOCATION ACCOUNTS for information about the Allocation Accounts that are currently available for investment. See also SELECTING ALLOCATION ACCOUNTS FOR INVESTMENT for important information about how to obtain current upside rates for the Allocation Accounts.

| • |  | Crediting Periods. Each Allocation Account has an investment term, expressed in years, representing the duration of an investment in that Allocation Account (a “Crediting Period”).

| • |  | For an Index Account Option, gain or loss is generally applied to your Policy at the end of the Crediting Period. See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – INDEX ACCOUNT OPTION VALUE.

| • |  | Also for an Index Account Option, gain or loss will be applied when any of the following transactions are performed before the end of the Crediting Period: (i) Surrender of the Policy; (ii) any type of withdrawal from that Index Account Option (including an automatic withdrawal, advisory fee withdrawal, minimum required distribution, surrender charge-free withdrawal, or any other withdrawal); (iii) exercise of Performance Lock; (iv) annuitization of the Policy; (v) payment of the death benefit; or (vi) deduction of a fee or charge from that Index Account Option (including the service charge, a GMDB rider fee, or a Credit Advantage Fee, except Accrued Credit Advantage Fees). Such interim gain and loss calculations are based on Interim Values.

Interim Values fluctuate daily, positively or negatively. Depending on market conditions, Interim Values could be unfavorable to you because they could reflect significantly less gain or more loss than would be applied at the end of a Crediting Period. There could be significantly less money available to you for any transaction that is processed based on an Interim Value, which could significantly reduce the values received under the Policy.

See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – INTERIM VALUES and APPENDIX A: INTERIM VALUE CALCULATIONS AND EXAMPLES.

| • |  | For the Fixed Account Option, interest is credited to your Policy each day until the end of the Crediting Period. See TYPES OF ACCOUNTS – FIXED ACCOUNT OPTION.

At the end of the Crediting Period for an Allocation Account, you may choose to reinvest in the same Allocation Account for another Crediting Period if it is available for investment at that time. You may also choose to transfer Policy Value in that Allocation Account to any other Allocation Account that is available for investment at that time. In the absence of instructions, your Policy Value in the expiring Allocation Account will be automatically reinvested in the same Allocation Account for another Crediting Period. If the expiring Allocation Account is no longer available for investment, your Policy Value in the expiring Allocation Account will be transferred to the Default Option. Currently, the Default Option is the Fixed Account Option, with the annual interest rate that we have declared for new Crediting Periods. See SELECTING ALLOCATION ACCOUNTS FOR INVESTMENT.

Please note that if you invest in an Allocation Account for which you already have an ongoing Crediting Period, you will have multiple ongoing Crediting Periods for the same Allocation Account. Under such circumstances, each ongoing Crediting Period for the same Allocation Account will be treated as a separate investment under the Policy.

Index Account Options

Generally. When you invest in an Index Account Option, your investment begins on the first day of the Crediting Period and generally ends on the last day of the Crediting Period. There are certain events that could end your investment before the last day of the Crediting Period, such as if you take a full withdrawal from that Index Account Option, Surrender the Policy, or annuitize the Policy, or if the death benefit becomes payable, or if you exercise Performance Lock, before the end of the Crediting Period.

At the end of the Crediting Period, we apply gain or loss to your Policy based on how the Index Account Option performed. The Index Account Option’s performance is linked to the performance of a specific market index or exchange-traded fund (the “Index”). The Index’s performance is measured by calculating the net percentage change in the value of the Index (the “Index Change”) between the first day of the Crediting Period (the “Initial Index Value”) and the last day of the Crediting Period (the “Final Index Value”). For example, regardless of how the Index otherwise performed between the beginning and end of the Crediting Period:

| • | If the Initial Index Value is 1000 and the Final Index Value is 1100, the Index Change would be +10% (i.e., (1100/1000) – 1 = 10%).

| • | Likewise, if the Initial Index Value is 1000 and the Final Index Value is 900, the Index Change would be -10% (i.e., (900/1000) – 1 = -10%).

The amount of gain or loss applied to your investment at the end of the Crediting Period will depend on the Index Change and the Index Account Option’s upside and downside features, as described below.

Positive Index Change. When the Index Change at the end of the Crediting Period is positive, your Policy gains value. The extent to which you participate in the positive Index performance depends on the Index Account Option’s “Growth Opportunity Type.”

| • |  | Cap – If you select an Index Account Option with Cap, you will participate in positive Index performance up to the Cap Rate, but no positive Index performance beyond the Cap Rate. For instance, if you select an Index Account Option with a Cap Rate of 10%, and at the end of the Crediting Period the Index Change is 5%, your Index Credit Rate (i.e., your Index rate of return) would be +5%. If the Index Change were 15%, your Index Credit Rate would be limited to +10%. A Cap Rate for a particular Crediting Period may be higher or lower than the Cap Rates for previous or future Crediting Periods. In no event will we set a Cap Rate for any Index-Linked Interest Strategy at less than [2.00]% during the surrender charge period or less than [1.00]% thereafter.

You will not participate in any Index performance beyond the Cap Rate. The Cap Rate limits the upside potential of your investment. The Cap is measured over the life of the Crediting Period, which can be more than one year. In cases where a Crediting Period is more than one year, the Cap Rate for that Crediting Period would be less if measured on an annual basis.

For additional information and examples for Cap, see AVAILABLE ALLOCATION ACCOUNTS – GROWTH OPPORTUNITY TYPE: CALCULATING GAIN USING CAP later in this prospectus.

| • |  | Participation – If you select an Index Account Option with Participation, you will participate in a percentage of positive Index performance, and that percentage will be the Participation Rate. For instance, if you select an Index Account Option with Participation and a Participation Rate of 80%, and at the end of the Crediting Period the Index Change is 10%, your Index Credit Rate would be +8%. Please note:

| • |  | A Participation Rate equal to 100% means that you will fully participate in positive Index performance.

| • |  | A Participation Rate less than 100% means that you will not fully participate in positive Index performance.

| • |  | We may declare Participation Rates greater than 100%, which would have the effect of increasing your gains relative to the Index Change.

If the Participation Rate is less than 100%, you will not fully participate in positive Index performance, limiting the upside potential of your investment.

Currently, all Index Account Options with Participation are designated as “Credit Advantage,” which means an additional charge will apply for any Index Account Option with Participation that you select.

For additional information and examples for Participation, see AVAILABLE ALLOCATION ACCOUNTS – GROWTH OPPORTUNITY TYPE: CALCULATING GAIN USING PARTICIPATION later in this prospectus.

Negative Index Change (Applying the Buffer). When the Index Change at the end of the Crediting Period is negative, your Policy will lose value only to the extent that the Index Account Option’s downside protection does not protect you from loss. The downside protection provided by an Index Account Option will depend on its “Downside Protection Type.”

We currently only offer Index Account Options with Buffer as the Downside Protection Type. Due to the operation of the Buffer, your investment will incur loss for negative Index performance beyond the Buffer Rate. The Buffer Rate represents the percentage of your investment that is protected from loss.

For instance, assuming a Buffer Rate of 10%, it is possible that you could lose 90% of your investment as a result of negative Index performance. A Buffer absorbs the impact of negative Index performance before the negative Index performance impacts your investment.

If the negative Index performance does not go beyond the Buffer Rate, you will not incur loss as a result of that negative Index performance. For example, if you select an Index Account Option with a Buffer and a Buffer Rate of 10%, and at the end of the Crediting Period the Index Change is -5%, your Index Credit Rate would be 0% (i.e., no loss due to negative Index performance).

If the negative Index performance goes beyond the Buffer Rate, your investment will incur loss. Your Index Credit Rate will be a percentage equal to the excess Index Change over the Buffer Rate. Under these circumstances, the Buffer would provide only partial protection from loss related to the negative Index performance. For example, if you select an Index Account Option with a Buffer and a Buffer Rate of 10%, and at the end of the Crediting Period the Index Change is -15%, your Index Credit Rate would be -5% and you would incur loss.

The Buffer provides limited downside protection. You assume the risk of loss for negative Index performance in excess of the Buffer Rate. Your losses could be significant. The Buffer is measured over the life of the Crediting Period, which can be more than one year. In cases where a Crediting Period is more than one year, the Buffer for that Crediting Period is the total Buffer for the life of the Crediting Period.

For additional information and examples of how we calculate your Index Credit Rate using Buffer, see AVAILABLE ALLOCATION ACCOUNTS – DOWNSIDE PROTECTION TYPE: CALCULATING LOSS USING THE BUFFER.

Item 3 Key Information

There is an implicit ongoing fee on Index-Linked Options to the extent that your participation in Index gains is limited by the Insurance Company through the use of a cap, participation rate, or some other rate or measure, which means that your returns may be lower than the Index’s returns. In return for accepting this limit on Index gains, you will receive some protection from Index losses; and this implicit ongoing fee is not reflected in the tables below.

Fees, Expenses and Adjustments
Are There Charges or Adjustments for Early Withdrawals? | If you withdraw money from the Contract within six years of your last Purchase Payment, you will be assessed a withdrawal charge of up to 8.5% of the Purchase Payment withdrawn, declining to 0% over that time period. For example, if you invest $100,000 in the Contract and make an early withdrawal, you could pay a withdrawal charge of up to $8,500. In addition, if you take a full or partial withdrawal (including financial adviser fees that you choose to have us pay from this Contract) from an Index Option on a date other than the Term End Date, a Daily Adjustment will apply to the Index Option Value that is available for withdrawal. The Daily Adjustment also applies if before the Term End Date you execute a Performance Lock, annuitize the Contract, we pay a death benefit, or we deduct Contract fees and expenses. The Daily Adjustment may be negative depending on the applicable Crediting Method. You will lose money if the Daily Adjustment is negative. • Index Dual Precision Strategy, Index Precision Strategy, Index Guard Strategy, and Index Performance Strategy. Daily Adjustments under these Crediting Methods may be positive, negative, or equal to zero. A negative Daily Adjustment will result in a loss. In extreme circumstances, a negative Daily Adjustment could result in a loss beyond the protection of the 10%, 20%, or 30% Buffer; or -10% Floor, as applicable. The maximum potential loss from a negative Daily Adjustment is: -99% for the Index Dual Precision Strategy, Index Precision Strategy, and Index Performance Strategy; and -35% for the Index Guard Strategy. • Index Protection Strategy with Trigger. Daily Adjustments under this Crediting Method may be positive or equal to zero, but cannot be negative. For example, if you allocate $100,000 to the Index Guard Strategy with a 3-year Crediting Period and later withdraw the entire amount before the 3 years have ended, you could lose up to $35,000 of your investment. This loss will be greater if you also have to pay a surrender charge, taxes, and tax penalties.
Not a Short-Term Investment | This Contract is not a short-term investment and is not appropriate if you need ready access to cash. • Considering the benefits of tax deferral and long-term income, the Contract is generally more beneficial to investors with a long investment time horizon. • Withdrawals are subject to income taxes, and may also be subject to a 10% additional federal tax for amounts withdrawn before age 59 ½. • If within six years after we receive a Purchase Payment you take a full or partial withdrawal (including financial adviser fees that you choose to have us pay from this Contract), withdrawal charges will apply. A withdrawal charge will reduce your Contract Value or the amount of money that you actually receive. Withdrawals may reduce or end Contract guarantees. • Amounts invested in an Index Option must be held in the Index Option for the full Term before they can receive a Performance Credit. We apply a Daily Adjustment if before the Term End Date you take a full or partial withdrawal (including financial adviser fees that you choose to have us pay from this Contract), annuitize the Contract, execute a Performance Lock, we pay a death benefit, or we deduct Contract fees and expenses. • The Traditional Death Benefit may not be modified, but it will terminate if you take withdrawals that reduce both the Contract Value and Guaranteed Death Benefit Value to zero. Withdrawals may reduce the Traditional Death Benefit’s Guaranteed Death Benefit Value by more than the value withdrawn and could end the Traditional Death Benefit.
Risks Associated with Investment Options | • An investment in the Contract is subject to the risk of poor investment performance and can vary depending on the performance of the AZL Government Money Market Fund and the Index Options available under the Contract. • The AZL Government Money Market Fund and each Index Option has its own unique risks. • You should review the AZL Government Money Market Fund prospectus and disclosures, including risk factors, before making an investment decision.
Shield Option | We currently offer different levels of protection: Shield 10 — A Shield Rate where negative Index Performance of up to 10% of your Investment Amount is absorbed by us at the Term End Date, which would leave you to absorb any remaining negative Index Performance of up to 90% of your Investment Amount. Shield 15 — A Shield Rate where negative Index Performance of up to 15% of your Investment Amount is absorbed by us at the Term End Date, which would leave you to absorb any remaining negative Index Performance of up to 85% of your Investment Amount. Your selling firm may limit the Shield Options available through that firm when your Contract is issued or at Term End Date. Additionally, we may stop selling certain Shield Options. We are not obligated to offer any one particular Shield Option, but after your Contract is issued, there will always be one Shield Option available, although it may not be substantially similar to one of the currently available Shield Options.
Investments | • Certain Index Options may not be available under your Contract. • You cannot allocate Purchase Payments to the AZL Government Money Market Fund. The sole purpose of the AZL Government Money Market Fund is to hold Purchase Payments until they are transferred to your selected Index Options. • We restrict additional Purchase Payments during the Accumulation Phase. Each Index Year, you cannot add more than your initial amount (i.e., all Purchase Payments received before the first Quarterly Contract Anniversary of the first Contract Year) without our prior approval. • We do not accept additional Purchase Payments during the Annuity Phase. • We typically only allow assets to move into the Index Options on the Index Effective Date and on subsequent Index Anniversaries as discussed in section 3, Purchasing the Contract – Allocation of Purchase Payments and Contract Value Transfers. However, if you execute a Performance Lock and request Early Reallocation, we will move assets into an Index Option on the Business Day we receive your Early Reallocation request in Good Order. • You can typically transfer Index Option Value only on Term End Dates. However, you can transfer assets out of an Index Option Value before the Term End Date by executing a Performance Lock as discussed in section 4, Valuing Your Contract – Performance Locks. • We do not allow assets to move into an established Index Option until the Term End Date. If you request to allocate a Purchase Payment into an established Index Option on an Index Anniversary that is not a Term End Date, we will allocate those assets to the same Index Option with a new Term Start Date. • We reserve the right to discontinue accepting new allocations into specific Index Options and to substitute Indexes either on a Term Start Date or during a Term. We also reserve the right to decline any or all Purchase Payments at any time on a nondiscriminatory basis.
Crediting Type | A Shield Option can only have one associated Rate Crediting Type: either Cap Rate, or Step Rate. The Cap Rate is the maximum rate that may be credited at the Term End ate based on Index Performance. The Step Rate is the rate credited at the Term End Date if the Index Performance is equal to or greater than zero. The Cap Rate is the maximum rate that may be credited at the Term End Date based on Index Performance. For example, a 15% Index Performance with a 10% Cap Rate will result in a 10% Performance Rate; or, a 5% Index Performance with a 10% Cap Rate will result in a 5% Performance Rate. The Step Rate is the rate credited at the Term End Date if the Index Performance is equal to or greater than zero. For example, a 15% Index Performance with a 8% Step Rate will result in a 8% Performance Rate; or, a 5% Index Performance with a 8% Step Rate will result in a 8% Performance Rate. In deciding whether to purchase a Shield Option with a Cap Rate versus a Step Rate or Step Rate Edge, you should consider the following: Step Rates and Edge Rates are generally lower than Cap Rates. For example, if Index Performance is equal to or greater than zero but less than the Step Rate, and you chose a Cap Rate for your Shield Option, your Performance Rate Adjustment will be lower than it otherwise would be had you chosen a Step Rate. Alternatively, if Index Performance is positive and exceeds the Step Rate, and you chose a Step Rate for your Shield Option, your Performance Rate Adjustment will be lower than it otherwise would be had you chosen a Cap Rate. For example, if you chose a Shield Option with a 10% Cap Rate and there is a 15% Index Performance, your Performance Rate is 10%; however, if instead you were to choose a Shield Option with an 8% Step Rate, your Performance Rate would instead be 8%.

Item 4 Fee Table

Adjustments[1]
Contract Adjustment Maximum Potential Loss (as a percentage of Contract value at the start of the Crediting Period or amount withdrawn, as applicable) | -35%

Example

This Example is intended to help you compare the cost of investing in the Variable Options with the cost of investing in other annuity contracts that offer variable options. These costs include transaction expenses, annual Contract expenses, and Annual Portfolio Company Expenses.

The Example assumes all Contract value is allocated to the Variable Options. The Example does not reflect the Contract Adjustment. Your costs could differ from those shown below if you invest in Index-Linked Options or Fixed Options.

The Example assumes that you invest $100,000 in the Variable Options for the time periods indicated. The Example also assumes that your investment has a 5% return each year and assumes the most expensive combination of Annual Portfolio Company Expenses and optional benefits available for an additional charge. Although your actual costs may be higher or lower, based on these assumptions, your costs would be:

| 1 year | 3 years | 5 years | 10 years
If you surrender your Contract at the end of the applicable time period: | $9,599 | $10,435 | $10,958 | $13,270
If you annuitize at the end of the applicable time period: | $N/A | $ 3,435 | $ 5,968 | $13,270
If you do not surrender your Contract: | $1,099 | $3,435 | $5,968 | $13,270

Item 5 Principal Risks of Investing in the Contract

PRODUCT RISK FACTORS

RISK OF LOSS

An investment in this Policy is subject to the risk of loss. You may lose money, including your principal investment and previously credited earnings. Your losses may be significant.

ALLOCATION ACCOUNT AVAILABILITY RISK

We reserve the right to add and remove Allocation Accounts as available investment options. Allocation Accounts will only be added or removed through an amendment to this prospectus. We also reserve the right to make different Allocation Accounts available for investment in connection with only new premium payments (i.e., initial or additional premium payments) as opposed to at the end of a Crediting Period. There is no guarantee that an Allocation Account that you select for investment will always be available to you in the future or available with the same current upside rates.

Our only guarantee regarding the availability of Allocation Accounts is that we will always offer at least the following Basic Index Account Option for investment: S&P 500® Index, 1-Year Crediting Period, Buffer (Buffer Rate: 10%), Cap (Cap Rate: No lower than 2.00%), and no Credit Advantage Fee. Please note the Index for that Index Account Option remains subject to our right of substitution. See INDEX SUBSTITUTION RISK below.

If we remove an Allocation Account, it will be closed such that no new premiums, reinvestments, or transfers will be allowed into that Allocation Account. If you are currently invested in an Allocation Account and it is removed, you may remain in that Allocation Account until the end of the Crediting Period.

If you are not comfortable with the risk that we may not offer Allocation Accounts in the future that are attractive to you based on your personal preferences, risk tolerances, or time horizon, or with the risk that we may offer only a single Index Account Option in the future, this Policy is not appropriate for you. You may Surrender your Policy (i.e., take a full withdrawal) if there are no Allocations Accounts that you wish to select, but the Surrender may be subject to surrender charges, will be based on an Interim Value if taken before the end of a Crediting Period for an Index Account Option, may be subject to taxes (including a 10% federal penalty tax if taken before age 591⁄2), and your Policy will terminate.

BUFFER RISK

Buffers do not provide complete protection from loss related to negative Index performance. You assume the risk that you will incur losses to the extent that an Index Account Option’s Buffer does not protect you from negative Index performance. The following table shows the maximum potential loss due to negative Index performance at the end of a Crediting Period for each Buffer Rate that we currently offer. Please note the maximum loss at the end of a Crediting Period could be greater due to fees and charges.

Buffer Rate |  | Maximum Potential Loss Due to Negative Index Performance at End of Crediting Period (before fees and charges) |
10% |  |  | 90 | %
15% |  |  | 85 | %
20% |  |  | 80 | %

The limits on loss are for the duration of a single Crediting Period. If you invest in the same Index Account Option for multiple Crediting Periods, losses over multiple Crediting Periods may be larger than the stated limit for a single Crediting Period.

The maximum potential loss due to the application of an Interim Value is greater than the maximum potential loss at the end of a Crediting Period. In extreme circumstances, it is possible to lose 100% of your investment in any Index Account Option due to the application of an Interim Value (i.e., a complete loss of your principal and any prior earnings).

In general, depending on applicable rates, an Index Account Option with relatively more downside protection based on its Buffer Rate is likely to have relatively less upside potential based on its Cap Rate or Participation Rate. Conversely, depending on applicable rates, an Index Account Option with relatively less downside protection based on its Buffer Rate is likely to have more upside potential based on its Cap Rate or Participation Rate.

For any new Index Account Option that we offer in the future, we will set the rate(s) for its Downside Protection Type in our discretion.

GROWTH OPPORTUNITY TYPE RISK

When you invest in an Index Account Option, the upside potential of your investment may be limited by its Growth Opportunity Type. For Cap, the Cap Rate may limit the upside potential of your investment by capping your participation in positive Index performance. Likewise, for Participation, a Participation Rate of less than 100% will limit the upside potential of your investment by limiting your participation in positive Index performance. In either case, Index Credit Rate used to calculate gains will be lower than the Index Change.

In general, depending on applicable rates, an Index Account Option with relatively more upside potential based on its Cap Rate or Participation Rate is likely to have relatively less downside protection based on its Buffer Rate. Conversely, depending on applicable rates, an Index Account Option with relatively less upside potential based on its Cap Rate or Participation Rate is likely to have more downside protection based on its Buffer Rate.

We may declare new Cap Rates and Participation Rates for the available Index Account Options for new Crediting Periods. We set these rates in our discretion, within any guaranteed limits to which we are subject as described in this prospectus. You bear the risk that the rate(s) we declare for a new Crediting Period will not be any more or less favorable to you than any guaranteed limits to which we are subject.

WITHDRAWAL AND SURRENDER RISK

You should fully understand the risks associated with any withdrawal or Surrender before you purchase the Policy and before you decide to take a withdrawal or Surrender. You should consult with your financial and tax professionals before you purchase the Policy or take a withdrawal or Surrender.

| • |  | A Surrender will terminate the Policy and all its benefits, including the death benefit. See ACCESS TO YOUR MONEY.

| • |  | Charges may be deducted when you take a withdrawal or Surrender, including surrender charges. These charges may be significant. See FEES AND CHARGES.

| • |  | Any type of withdrawal or a Surrender taken before the end of a Crediting Period for an Index Account Option will be processed based on an Interim Value for that Index Account Option, which may reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. There could be significantly less money available to you for a withdrawal or Surrender that is processed based on an Interim Value. The application of an Interim Value may result in a loss to an Owner even if the reference Index at the time of withdrawal or Surrender is higher than at the beginning of the Crediting Period. See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – INTERIM VALUES. Any type of withdrawal taken before the end of a Crediting Period for an Index Account Option will result in a negative adjustment to your Index Base for that Index Account Option, which may reduce your gains or contribute to losses at the end of the Crediting Period and will reduce Interim Values for the remainder of the Crediting Period. A negative adjustment to your Index Base may be greater than the amount withdrawn. See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – NEGATIVE ADJUSTMENTS TO INDEX BASE. Interim Values for an Index Account Option generally reflect less upside potential and less downside protection than would otherwise apply at the end of the Crediting Period. As such, when a transaction is processed based on an Interim Value, the Interim Value could reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. This means that there could be significantly less money available under your Policy for fees and charges, withdrawals, a Surrender, annuitization, and the death benefit. In extreme circumstances, it is possible to lose 100% of your investment in any Index Account Option due to the application of an Interim Value (i.e., a complete loss of your principal and any prior earnings). • Any withdrawal you take will reduce the Policy Value (because you are taking money out of your Policy) and the amount of the death benefit, including the guaranteed minimum death benefit (perhaps significantly) if the GMDB rider has been elected. The guaranteed minimum death benefit will be reduced in the same proportion that a gross withdrawal reduces your Policy Value, and this reduction may be more than the dollar amount withdrawn. See POLICY VALUE AND CASH VALUE and DEATH BENEFIT. • If you are receiving investment advice from a financial professional who charges you investment advisory fees for their services, you may be able to pay investment advisory fees directly from this Policy via advisory fee withdrawals. Investment advisory fees are in addition to and separate from the Policy’s fees and charges. Advisory fee withdrawals will reduce your Policy Value and will be subject to the same risks and consequences of withdrawals, including applicable surrender charges, Interim Value adjustments, negative adjustments, and taxes (including a 10% federal penalty tax if taken before age 591⁄2) and proportionate reductions to the death benefit. For tax-qualified Policies issued as an IRA or in connection with certain tax-qualified retirement plans, there is no maximum limit on advisory fee withdrawals. For non-qualified Policies, advisory fee withdrawals are subject to a maximum limit of 1.5% of the Policy’s cash value (determined without regard to any surrender charges) each Policy Year. We will not permit advisory fee withdrawals to be taken in excess of the maximum limit. If you attempt to take advisory fee withdrawals in excess of the maximum limit, we will notify you. We will not report advisory fee withdrawals as taxable distributions to the IRS; therefore, they may not be subject to federal income tax. However, regardless of how Transamerica treats advisory fee withdrawals for tax reporting purposes, federal and/or state taxing authorities could determine that advisory fee withdrawals should be treated as taxable withdrawals from your Policy, in which case the amount of the advisory fees deducted from your Policy could be subject to income tax, and a 10% federal penalty tax could apply if the advisory fee withdrawal was taken before you attained age 591⁄2. You should consult with a tax professional. See ACCESS TO YOUR MONEY – ADVISORY FEE WITHDRAWALS and TAX INFORMATION – Special Rules for Advisory Fee Payments. • Automatic withdrawals under the systematic payout option, minimum required distributions, and regular advisory fee withdrawals will repeatedly expose you to the risks and consequences of withdrawals, including applicable surrender charges, Interim Value adjustments, negative adjustments, and income taxes and tax penalties and proportionate reductions to the death benefit. See ACCESS TO YOUR MONEY – SYSTEMATIC PAYOUT OPTION for information about the systematic payout option.

LIQUIDITY RISK

We designed the Policy to be a long-term investment. If you are not a long-term investor, this Policy may not be appropriate for you.

| • |  | Transfer Limitations. The Policy restricts transfers between investment options, which will limit your ability to reallocate your Policy Value in response to changes in market conditions or your personal circumstances. You may transfer Policy Value invested in an Allocation Account only at the end of that Allocation Account’s Crediting Period (or on the next Allocation Anniversary, if you exercised Performance Lock).

| • |  | Withdrawal and Surrender Consequences. You may take a withdrawal or a Surrender at any time during the accumulation phase; however, there may be significant risks and negative consequences associated with any such withdrawal or Surrender, including potential surrender charges, taxes and tax penalties, and negative impacts to the value of your investment. See WITHDRAWAL AND SURRENDER RISK.

| • |  | Interim Values. There may be long periods of time when you cannot perform a transaction under the Policy that is not based on one or more Interim Values. For as long as you have multiple ongoing Crediting Periods for Index Account Options, there may be no time that any such transaction can be performed without the application of at least one Interim Value. See INTERIM VALUE RISK.

| • |  | Taxes. Income taxes and certain tax restrictions may apply to any withdrawal or Surrender. If taken before age 591⁄2, a withdrawal or Surrender may also be subject to a 10% federal penalty tax.

| • |  | Delays in Payment. We generally make payment of any amount due from the Policy within seven days from the date we receive in good order all required information. When permitted by law, however, we may defer payment of any withdrawal or Surrender proceeds for up to six months from the date we receive your request.

INDEX PERFORMANCE RISK

The following risks related to Index performance apply when you invest in an Index Account Option:

| • |  | Negative Index Performance Could Result in Loss. The performance of any Index may fluctuate, sometimes rapidly and unpredictably. Both short-term and sustained negative Index performance, over one or multiple Crediting Periods, may cause you to lose principal or previous earnings. The historical performance of an Index does not guarantee future results. It is impossible to predict whether an Index will perform positively or negatively over the course of a Crediting Period or multiple Crediting Periods.

| • |  | Exposure to Investment Risks. When you invest in an Index Account Option, you are indirectly exposed to the investment risks associated with the linked Index. When the Index is a market index, you are indirectly exposed to the investment risks that could cause the stocks or other assets that make-up the Index to decrease in value. When the Index is an ETF, you are indirectly exposed to the investment risks associated with the ETF’s investment objective and strategies, as well as its market trading risks, all of which could cause the market price for the ETF’s shares to decrease in value. The Indexes are subject to a variety of investment risks, many of which are complicated and interrelated and all of which may adversely affect the performance of the Index. If you invest in an Index Account Option with an Index that exposes you to higher investment risks, your risk of loss may be higher depending on the Index Account Option’s downside protection.

The specific investment risks associated with the market indexes and ETFs serving as Indexes are discussed under “Investment Risks for the Market Indexes” and “Investments Risks for the Exchange Traded Funds (ETFs)” respectively below.

• |  | Point-to-Point Index Change Calculations. We calculate Index Changes by comparing the value of the Index between two specific points in time, which means the performance of the Index may be negative or flat even if the Index performed positively for certain time periods between those two specific points in time. This is true even for Index Account Options with Crediting Periods that are multiple years in length.

| • |  | Dividends Excluded From Index Values. Index Values do not include income from any dividends or other distributions paid by a market index’s component companies or by an ETF. The exclusion of dividends and other distributions from Index Values negatively impacts an Index’s performance.

| • |  | No Rights in the Index. When the Index is a market index, you are not investing in the Index (which is impossible) and you have no rights with respect to the index, the index provider, or any aspect of the index or any companies whose securities comprise the index. When the Index is an ETF, you are not a shareholder in the ETF and you have no voting, dividend, liquidation, or other rights that belong to shareholders in the ETF.

| • |  | Evolving and Uncertain Economic Environment. In recent years, the financial markets have experienced periods of significant volatility and negative returns, contributing to an uncertain and evolving economic environment. The performance of the markets has been impacted by several interrelating factors such as, but not limited to, the COVID-19 pandemic, geopolitical turmoil, rising inflation, changes in interest rates, and actions by governmental authorities. It is not possible to predict future performance of the markets. Depending on your individual circumstances, you may experience (perhaps significant) negative returns under the Policy. You should consult with a financial professional about how market conditions may impact your investment decisions under the Policy.

| • |  | Investment Risks for the Market Indexes

The following Indexes are market indexes: S&P 500® Index and Fantasist World Leaders Index 0.5% AR. Each market index that may serve as an Index is subject to the following risks:

| • |  | Market Risk. Each market index could decrease in value over short periods due to short-term market movements and over longer periods during more prolonged market downturns. Negative fluctuations in the value of a market index may be significant and unpredictable.

| • |  | Equity Risk. Each market index is comprised of equity securities. Equity securities are subject to changes in value, and their values may be more volatile than those of other asset classes. Equity securities may underperform in comparison to the general financial markets, a particular financial market, or other asset classes.

| • |  | Issuer Risk. The performance of each market index depends on the performance of individual securities that make-up the index. Changes in the financial condition or credit rating of an issuer of those securities may cause the value of the securities to decline.

| • |  | Large-Cap Risk. Large-capitalization companies may be less able than smaller capitalization companies to adapt to changing market conditions. Large-capitalization companies may be more mature and subject to more limited growth potential compared with smaller capitalization companies. During different market cycles, the performance of large-capitalization companies has trailed the overall performance of the broader securities markets.

INDEX SUBSTITUTION RISK

During a Crediting Period, if a market index serving as an Index is discontinued or if the calculation of the index is substantially changed by the index provider, or if Index Values should become unavailable for any reason, or if an ETF that is serving as an Index is liquidated or otherwise no longer exists or if its investment objectives, strategies, or risks substantially change, we may substitute the Index with a new Index, once we obtain all necessary regulatory approvals. We will notify you of any such substitution in writing.

If we substitute an Index, we will select a new Index that we determine in our judgment is comparable to the old Index. We may look at factors that include, but are not limited to, asset class, index composition, strategy, and index liquidity. You will have no right to reject the substitution of an Index. The performance of the new Index may differ significantly from the performance of the old Index. If we substitute the Index for an Index Account Option in which you are invested, your investment in the Policy is subject to the same terms and conditions as any other investment in an Allocation Account under the Policy. For example, you will not be permitted to transfer Policy Value prior to the end of a Crediting Period if a substitution occurs.

If we substitute an Index during a Crediting Period, we will calculate the Index Change using the original Index up until the substitution date. After the substitution date, we will calculate the Index Change using the replacement Index, but with a revised Initial Index Value for the replacement Index. The revised Initial Index Value for the replacement Index will reflect the Index Change for the original Index from the start of the Crediting Period to the substitution date. We will use a similar process if multiple substitutions occur during a Crediting Period. The substitution of an Index will have no impact on the Index Account Option’s Crediting Period, Growth Opportunity Type, Downside Protection Type, or any other features or rates for that Index Account Option other than the Index to which the Index Account Option is linked.

See VALUING YOUR INVESTMENT IN AN INDEX ACCOUNT OPTION – INDEX SUBSTITUTIONS.

FEES AND CHARGES

There are fees and charges associated with the Policy that may reduce the return on your investment. Please note that if a fee or charge is deducted from an Index Account Option before the end of a Crediting Period for an Index Account Option (including a periodic fee or charge), the deduction will be from the Interim Value of your investment in that Index Account Option. As discussed, when a transaction is processed based on an Interim Value, the Interim Value could reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. This means that there could be significantly less money available under your Policy for fees and charges and could cause you to incur significant loss. The deduction would also result in a negative adjustment to your Index Base, which will result in lower Interim Values for the remainder of the Crediting Period and could result in less gain (if any) or more loss at the end of the Crediting Period.

FINANCIAL STRENGTH AND CLAIMS-PAYING ABILITY

An investment in the Policy is subject to the risks related to us, Transamerica Life Insurance Company. Any obligations (including under the Index Account Options, the Fixed Account Option, the Fixed Holding Account, and the Performance Lock Account), guarantees, and benefits under the Policy are subject to our financial strength and claims-paying ability. If we experience financial distress, we may be permitted by law to delay payments to you for up to six months, and we ultimately may not be able to meet our obligations to you.

Item 6(a) Insurance Company

Insurer ABC

Washington DC 20549

(123) 456-7890

(Address, including zip code, and telephone number, including area code, of Principal Executive Offices)

Insurer ABC, Inc. is the principal underwriter for the Policy. We make Annuity Payments and pay death benefits from our general account. Our general account assets are subject to claims by our creditors, and any payment we make from our general account is subject to our financial strength and claims-paying ability.

Insurer ABC is relying on the exemption provided by Rule 12h-7 under the Securities Exchange Act of 1934 ("1934 Act"). In reliance on the exemption provided by Rule 12h-7, we do not file periodic reports as that we would otherwise be required to file under the 1934 Act.

Item 6(d) Index-Linked Options

(1) Describe the Index-Linked Options currently offered under the Contract, . . .:

INDEX-LINKED INTEREST STRATEGIES

Each Index-Linked Interest Strategy credits an amount of Index-Linked Interest at the end of each Crediting Period determined by the performance of a particular Index or Indices and the applicable Crediting Method. Each Crediting Method measures the net performance of the applicable Index between the beginning and end of a Crediting Period (i.e., “Point to Point”) or each Contract Year during the Crediting Period (i.e., “Annual Lock”) subject to either the Cap Rate or Performance Trigger Rate, and either the Floor or the Buffer. Cap Rates, Performance Trigger Rates, Floors and Buffers apply to an entire Crediting Period for Point to Point Index-Linked Interest Strategies and apply to each Contract Year in a Crediting Period for Annual Lock Index-Linked Interest Strategies.

There are currently 30 Index-Linked Interest Strategies available under the Contract. The table below lists the Index, Crediting Method and Crediting Period for each of the 30 Index-Linked Interest Strategies.

Additional information about the operation of the Index-Linked Interest Strategies is provided under “Additional Information about the Index-Linked Interest Strategies” immediately below.

1 Year Crediting Period
Crediting Method |  | Protection Option |  | S&P 500® Index |  | Russell 2000® Index |  | Nasdaq- 100® Index |  | MSCI EAFE Index
Cap |  | 10% Buffer |  | ✓ |  | ✓ |  | ✓ |  | ✓
| 20% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓
| -10% Floor |  | ✓ |  | ✓ |  | ✓ |  | ✓
Performance Trigger |  | 10% Buffer |  | ✓ |  | ✓ |  | ✓ |  | ✓
3 Year Crediting Period
Cap |  | 10% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓
| 20% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓
6 Year Crediting Period
Cap |  | 10% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓
| 20% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓
Annual Lock |  | 10% Buffer |  | ✓ |  | ✓ |  | N/A |  | ✓

ADDITIONAL INFORMATION ABOUT THE INDEX-LINKED INTEREST STRATEGIES

INDEXES

Currently, each Index-Linked Interest Strategy credits interest based on the performance of one of the following Indexes, each covering different asset classes.

S&P 500® Index (SPX). Widely regarded as the best gauge of the U.S. stock market, this world-renowned index tracks the performance of 500 large companies in leading industries of the U.S. economy.

Russell 2000® Index (RTY). The Russell 2000® Index measures the performance of the small-cap segment of the U.S. equity universe. It is a subset of the Russell 3000® Index and includes approximately 2,000 of the smallest securities based on a combination of their market cap and current index membership.

Nasdaq-100 Index® (NDX). The Nasdaq-100 Index includes 100 of the largest domestic and international non-financial companies listed on the Nasdaq Stock Market based on market capitalization. The Index reflects companies across major industry groups including computer hardware and software, telecommunications, retail/wholesale trade and biotechnology.

MSCI EAFE Index (MXEA). MSCI EAFE Index is an equity index that captures large and mid-cap representation across 21 developed markets around the world, including Europe, Australasia and the Far East, excluding the United States and Canada. The Index covers approximately 85% of the free float-adjusted market capitalization in each of the 21 countries

We reserve the right to add, remove or replace any Index-Linked Interest Strategy, Index, or Crediting Method in the future, subject to any necessary regulatory approvals. If we replace an Index, this will not cause a change in the Cap Rate, Performance Trigger Rate, Floor or Buffer for the current Crediting Period. Adding or removing an Index does not cause a change in the Floor or Buffer because those elements do not change for the life of your Contract. Any Index-Linked Interest Strategies based on the performance of a newly added Index will have a new Cap Rate or Performance Trigger Rate. Changes to the Cap Rates or Performance Trigger Rates, if any, occur at the start of the next Crediting Period. If we add or remove an Index (as opposed to replacing an Index with another Index), the changes will not be effective for your Contract until the start of the next Crediting Period.

We may replace an Index if it is discontinued, or the Index is no longer available to us or if the Index’s calculation changes substantially. Additionally, we may replace an Index if hedging instruments become difficult to acquire or the cost of hedging becomes excessive. We may do so at the end of a Crediting Period or during a Crediting Period. We will notify you in writing at least 30 days before we replace an Index.

If we replace an Index, we will attempt to select a new Index that is similar to the old Index. In making this evaluation, we will look at factors such as asset class, Index composition, strategy or methodology inherent to the Index and Index liquidity. If we replace an Index during a Crediting Period, we will calculate the Index Change using the old Index up until the replacement date. After the replacement date, we will calculate the Index Change using the new Index, but with a modified start of Crediting Period value for the new Index. The modified start of Crediting Period value for the new Index will reflect the Index Change for the old Index from the start of the Crediting Period to the replacement date.

Additional Index information, including disclaimers, may be found in Appendix C. The investment risks associated with the Indexes are discussed under the section titled “Index Risk.”

An investment in the Contract is not an investment in the companies that comprise the Indexes. You should understand that you will have no voting rights, no rights to receive cash dividends or other distributions, and no other rights with respect to the companies that comprise the Indexes.

Index-linked and variable annuity contracts are complex insurance and investment vehicles. You may lose money, including your principal investment and previously credited earnings. Contract fees and expenses could cause your losses to be greater than the downside protection of the Index-Linked Strategy Option. Your losses may be significant.

INDEX-LINKED INTEREST

For each Index-Linked Interest Strategy to which you allocate Account Value, at the end of the Crediting Period, we will credit your Strategy Base Value with Index-Linked Interest. Index-Linked Interest may be positive, negative, or equal to zero.

| • |  | If the Index-Linked Interest is positive, your Strategy Base Value will increase by a dollar amount equal to the positive Index-Linked Interest.

| • |  | If the Index-Linked Interest is negative, your Strategy Base Value will decrease by a dollar amount equal to the negative Index-Linked Interest.

| • |  | If the Index-Linked Interest is equal to zero, no interest will be credited, and your Strategy Base Value will not change.

If you allocate Account Value to more than one Index-Linked Interest Strategy, the Index-Linked Indexed Strategies in which you invest will credit separate Index-Linked Interest at the end of their respective Crediting Periods. Even if you receive positive Index-Linked Interest for one or more Index-Linked Interest Strategies for a Crediting Period, your overall gain for that Crediting Period will be reduced by any negative Index-Linked Interest you receive for any other Index-Linked Interest Strategies for that Crediting Period, and the negative Index-Linked Interest may cause you to incur an overall loss during that Crediting Period.

(2)(i) Limits on Index Losses

CREDITING METHODS

To determine the Index-Linked Interest credited to an Index-Linked Interest Strategy at the end of a Crediting Period, we calculate the Adjusted Index Change for that Index-Linked Interest Strategy. We calculate the Adjusted Index Change by applying the applicable Crediting Method. The Contract provides for four Crediting Methods: (1) Point to Point Cap Rate with Buffer; (2) Point to Point Cap Rate with Floor; (3) Point to Point Performance Trigger Rate with Buffer; and (4) Annual Lock Cap Rate with Buffer.

Each Crediting Method includes the following elements:

| • |  | The Crediting Period;

| • |  | The Index Change (either “Point to Point,” from the beginning of the Crediting Period to the Crediting Date, or “Annual Lock” for each Contract Year in the Crediting Period);

| • |  | Either the Cap Rate or the Performance Trigger Rate (applied from the beginning of the Crediting Period to the Crediting Date for Point to Point Index-Linked Interest Strategies, or for each Contract Year in the Crediting Period for Annual Lock index-Linked Interest Strategies); and

| • |  | Either the Floor or the Buffer (applied from the beginning of the Crediting Period to the Crediting Date for Point to Point Index-Linked Interest Strategies, or for each Contract Year in the Crediting Period for Annual Lock Index-Linked Interest Strategies).

Each of these elements and each of the Crediting Methods is explained below, along with examples of how the Adjusted Index Change is determined for each Crediting Method in the case of both positive and negative Index Changes.

Crediting Period. The Crediting Period for an Index-Linked Interest Strategy is either one, three or six years. Crediting Periods begin on your Contract’s Anniversary Date.

Index Change. To calculate the Adjusted Index Change, we first calculate the Index Change. The Index Change for a Point to Point Index-Linked Interest Strategy is the net change percentage in the Index Value from the start of a Crediting Period to the end of the Crediting Period, before any applicable adjustment for either the Cap Rate or Performance Trigger Rate and either the Floor or Buffer. The Index Change for an Annual Lock Index-Linked Interest Strategy is determined from the start of each Contract Year to the end of each Contract Year in a Crediting Period, before any applicable adjustment for the Cap Rate and the Buffer.

Example: Assume that you allocate Account Value to a Point to Point Index-Linked Interest Strategy using the S&P 500® Index and between the beginning and end of the Crediting Period, the value of the securities comprising the S&P 500® increases by 5%. The Index Change for that Index-Linked Interest Strategy would be 5%. If instead the S&P 500® decreased by 5%, the Index Change for the Index-Linked Interest Strategy would be -5%.

After the Index Change is calculated, we next calculate the Adjusted Index Change. The Adjusted Index Change reflects any applicable adjustments for either the Cap Rate or the Performance Trigger Rate and either the Floor or the Buffer. Index-Linked Interest will be credited to the Strategy Base Value at a rate equal to the Adjusted Index Change.

Floor. If the Crediting Method for an Index-Linked Interest Strategy includes a Floor, the Floor is the maximum negative Adjusted Index Change for that Index-Linked Interest Strategy for a given Crediting Period. The Floor represents the most negative Index-Linked Interest that you can be credited under an Index-Linked Interest Strategy for a Crediting Period.

For those Crediting Methods with a Floor, the Floor is always set at a loss of 10%. This may also be expressed as a floor equal to negative 10% (-10%).

Example 1: Assume that you allocate Account Value to an Index-Linked Interest Strategy with a Crediting Method that includes a Floor and, at the end of the Crediting Period, the Index Change is -6%. In this case, to calculate the Adjusted Index Change, we would compare the Floor of -10% to the Index Change of -5%. Because the Floor (-10%) is less (more negative) than the Index Change (-5%), the Adjusted Index Change would be -5%. As a result, we would credit Index-Linked Interest to your Strategy Base Value at the Adjusted Index Change of -5%. In this example, the Floor did not provide any downside protection.

Example 2: Assume that you allocate Account Value to an Index-Linked Interest Strategy with a Crediting Method that includes a Floor and, at the end of the Crediting Period, the Index Change is -15%. In this case, to calculate the Adjusted Index Change, we would compare the Floor of -10% to the Index Change of -15%. Because the Floor (-10%) is higher (less negative) than the Index Change (-15%), the Adjusted Index Change would be -10%. As a result, we would credit Index-Linked Interest to your Strategy Base Value at the Adjusted Index Change of -10%. In this example, the Floor provided downside protection by limiting your loss.

The -10% Floor will apply to every Index-Linked Interest Strategy with a Floor and will not change for the life of your Contract. It is possible that we will change the Floors for Contracts issued in the future and that future Contracts may have different Floors for different Index-Linked Interest Strategies.

The Floor provides only limited protection against downside risk up to the current limit of -10%. You should understand that the Floor does not provide absolute protection against negative Index-Linked Interest and the Insurance Company does not guarantee that your Contract will always offer a Floor for a particular Index-Linked Interest Strategy. You may lose money.

Every Index-Linked Interest Strategy has its own Strategy Account Value. Any portion of your Account Value that is not allocated to an Index-Linked Interest Strategy with a Crediting Method that includes a Floor will not benefit from the downside protection provided by the Floor.

Buffer. If the Crediting Method for an Index-Linked Interest Strategy includes a Buffer, the Buffer represents the amount of negative Index Change that may occur before you are credited with a negative Index-Linked Interest for a Point to Point Index-Linked Interest Strategy, or a negative Adjusted Index Change applies for a Contract Year in a Crediting Period for an Annual Lock Index-Linked Interest Strategy.

Each Index-Linked Interest Strategy will specify the Buffer for that strategy. Depending on which Index-Linked Interest Strategy you select, the Buffer will provide protection from a negative Index Change of up to 10% or up to 20%,.

Example 1: Assume that you allocate Account Value to a Point to Point Index-Linked Interest Strategy with a Crediting Method that includes a Buffer of 10% and, at the end of the Crediting Period, the Index Change is -8%. In this case, to calculate the Adjusted Index Change, we would compare the Buffer of 10% to the Index Change of -8%. Because the negative Index Change (-8%) does not exceed the Buffer of 10%, the Adjusted Index Change would be 0%. As a result, we would not credit any Index-Linked Interest to your Strategy Base Value because the Adjusted Index Change equaled 0%. In this example, the Buffer provided complete downside protection by preventing you from being credited with negative Index-Linked Interest.

Example 2: Assume that you allocate Account Value to an Index-Linked Interest Strategy with a Crediting Method that includes a Buffer of 10% and, at the end of the Crediting Period, the Index Change is -15%. In this case, to calculate the Adjusted Index Change, we would compare the Buffer of 10% to the Index Change of -15%. Because the negative Index Change (-15%) exceeds the Buffer of 10%, the Adjusted Index Change would be -5% (i.e., -15% reduced by the Buffer of 10%). As a result, we would credit Index-Linked Interest to your Strategy Base Value based on an Adjusted Index Change of -5%. In this example, the Buffer provided downside protection because it did limit your loss from -15% to -5%, but it did not provide complete downside protection.

See “ANNUAL LOCK INDEX-LINKED INTEREST STRATEGIES” for examples for an Annual Lock Index-Linked Interest Strategy.

The Buffer for an Index-Linked Interest Strategy will not change for the life of your Contract. It is possible that we will change the Buffers for Contracts issued in the future, and that future Contracts may have different Buffers for different Index-Linked Interest Strategies.

The Buffer provides only limited protection from downside risk. You should understand that the Buffer does not provide absolute protection against negative Index-Linked Interest. You may lose money.

Every Index-Linked Interest Strategy has its own Strategy Account Value. Any portion of your Account Value that is not allocated to an Index-Linked Interest Strategy with a Crediting Method that includes a Buffer will not benefit from the protection afforded by the Buffer.

If you withdraw Account Value allocated to an Index-Linked Interest Strategy during a Crediting Period or on a Crediting Date, the withdrawal will cause a reduction to your Strategy Base Value. Your Strategy Base Value will be immediately reduced in a proportion equal to the reduction in your Strategy Account Value (which will be the Strategy Interim Value). You should fully understand how a withdrawal from an Index-Linked Interest Strategy reduces your Strategy Base Value, because reductions in your Strategy Base Value always result in reductions (perhaps significant reductions) to your Strategy Account Value for the remainder of the current and subsequent Crediting Periods. A withdrawal from an Annual Lock Index-Linked Interest Strategy will also result in the Annual Lock Value being immediately reduced in a proportion equal to the reduction in your Strategy Account Value.

Reductions to your Strategy Base Value will negatively impact your Strategy Account Value in three ways.

| • |  | First, a reduction in your Strategy Base Value may cause your Strategy Interim Values for the remainder of the Crediting Period to be lower than if you did not take the withdrawal. Because your Strategy Account Value is set equal to your Strategy Interim Value on any given Business Day, lower Strategy Interim Values will result in lower Strategy Account Values.

| • |  | Second, at the end of the Crediting Period, any positive Index-Linked Interest credited to you will be lower than if you did not take the withdrawal. This is because the Adjusted Index Change is applied to your Strategy Base Value in order to calculate your Index-Linked Interest, and a withdrawal reduces your Strategy Base Value.

| • |  | Third, your Strategy Base Value for successive crediting periods will be lower than if you did not take a withdrawal (unless you transfer additional Account Value to the Index-Linked Crediting Strategy). Before selecting a Buffer or Floor Rate, the Insurance Company will take into consideration market trends, its ability to meet insurance needs of policy holders, and other factors at its own discretion. Before selecting an Index-Linked Interest Strategy, you should consider your time horizon and insurance needs and whether protection from sustained losses over time in future years is more important (via protection from a Buffer) than protecting yourself from large losses (via protection from a Floor).

(2)(ii) Limits on Index Gains

Cap Rate. If the Crediting Method for an Index-Linked Interest Strategy includes a Cap Rate, the Cap Rate represents the maximum positive Adjusted Index Change for a given Crediting Period for a Point to Point Index-Linked Interest Strategy or for a Contract Year during a Crediting Period for an Annual Lock Index-Linked Interest Strategy. We set the Cap Rate for each Index-Linked Interest Strategy prior to the beginning of a Crediting Period, and the Cap Rate may vary between Index-Linked Interest Strategies. A Cap Rate for a Crediting Period may be higher or lower than the Cap Rates for previous or future Crediting Period. In no event will a Cap Rate be lower than the guaranteed minimum of [2.00% during the surrender charge period or less than 1.00% thereafter]. The Cap Rates for your initial Crediting Periods will be set forth in your Contract. Prior to the beginning of each subsequent Crediting Period, we will mail to you a 30-day advance written notice indicating how you may obtain the Cap Rates for the next Crediting Period.

Example 1: Assume that you allocate Account Value to a Point to Point Index-Linked Interest Strategy for a Crediting Period with a Cap Rate of 6%. Also assume that at the end of the Crediting Period, the Index Change is 5%. In this case, to calculate the Adjusted Index Change, we would compare the Cap Rate of 6% to the Index Change of 5%. Because the Index Change (5%) is less than the Cap Rate (6%), the Adjusted Index Change would be 5%. As a result, we would credit Index-Linked Interest to your Strategy Base Value at the Adjusted Index Change of 5%. In this example, the Cap Rate did not limit your potential gain.

Example 2: Assume that you allocate Account Value to a Point to Point Index-Linked Interest Strategy for a Crediting Period with a Cap Rate of 6%. Also assume that at the end of the Crediting Period, the Index Change is 12%. In this case, to calculate the Adjusted Index Change, we would compare the Cap Rate of 6% to the Index Change of 12%. Because the Index Change (12%) is higher than the Cap Rate (6%), the Adjusted Index Change would be 6%. As a result, we would credit Index Linked Interest to your Strategy Base Value at the Adjusted Index Change of 6%. In this example, the Cap Rate limited your potential gain.

See “ANNUAL LOCK INDEX-LINKED INTEREST STRATEGIES” for examples for an Annual Lock Index-Linked Interest Strategy. The Cap Rates do not guarantee a certain amount of Index-Linked Interest. The Cap Rates benefit us because they limit the amount of positive Index-Linked Interest that we may be obligated to credit for any Crediting Period. We set the Cap Rates at our discretion. You bear the risk that we will not set the Cap Rates higher than [2.00% during the surrender charge period and 1.00% thereafter].

Performance Trigger Rate. If the Crediting Method for an Index-Linked Interest Strategy includes a Performance Trigger Rate, the Performance Trigger Rate represents the positive Adjusted Index Change for a given Crediting Period if the Index Change for the Crediting Period is zero or greater. We set the Performance Trigger Rate for each Index-Linked Interest Strategy prior to the beginning of a Crediting Period, and the Performance Trigger Rate may vary between Index-Linked Interest Strategies. A Performance Trigger Rate for a Crediting Period may be higher or lower than the Performance Trigger Rates for previous or future Crediting Periods. In no event will a Performance Trigger Rate be lower than the guaranteed minimum of [2.00% during the surrender charge period or less than 1.00% thereafter]. The Performance Trigger Rates for your initial Crediting Periods will be set forth in your Contract. Prior to the beginning of each subsequent Crediting Period, we will mail to you a 30-day advance written notice indicating how you may obtain the Performance Trigger Rates for the next Crediting Period.

Example 1: Assume that you allocate Account Value to an Index-Linked Interest Strategy for a Crediting Period with a Performance Trigger Rate of 6%. Also assume that at the end of the Crediting Period, the Index Change is 3%. Because the Index Change is zero or greater (3%), the Adjusted Index Change will equal the Performance Trigger Rate (6%). As a result, we would credit Index-Linked Interest to your Strategy Base Value at the Adjusted Index Change of 6%. In this example, the Performance Trigger Rate was greater than the Index Change.

Example 2: Assume that you allocate Account Value to an Index-Linked Interest Strategy for a Crediting Period with a Performance Trigger Rate of 6%. Also assume that at the end of the Crediting Period, the Index Change is 10%. Because the Index Change is zero or greater (10%), the Adjusted Index Change will equal the Performance Trigger Rate (6%). As a result, we would credit Index-Linked Interest to your Strategy Base Value at the Adjusted Index Change of 6%. In this example, the Performance Trigger Rate limited your potential gain.

The Performance Trigger Rates do not guarantee a certain amount of Index-Linked Interest unless the applicable Index Change is zero or greater. The Performance Trigger Rates benefit us because they limit the amount of positive Index-Linked Interest that we may be obligated to credit for any Crediting Period. The Performance Trigger Rate will not change during the Crediting Period. We set the Performance Trigger Rates at our discretion. You bear the risk that we will not set the Performance Trigger Rates higher than [2.00% during the surrender charge period and 1.00% thereafter].

Before selecting a Cap or Performance Trigger the Insurance Company will take into consideration market trends, its ability to meet insurance needs of policy holders, and other factors at its own discretion.

Before selecting an Index-Linked Interest Strategy, you should consider your time horizon and insurance needs and whether tax-deferred growth potential and protection from losses justifies the reduced upside in participation in Index Growth under the Cap.

(2)(iii) Crediting Period

CREDITING PERIOD

The Crediting Period for an Indexed-Linked Interest Strategy may be one, three or six years. The initial Crediting Period begins on your Contract’s Effective Date. Each subsequent Crediting Period begins at the end of the prior Crediting Period. If any beginning/ending date of a Crediting Period is not a Business Day, the beginning/ending date will be the next Business Day. In extended periods of moderate to large negative market performance, 3-year and 6-year Crediting Period may provide less protection than the 1-year Terms because, in part, the Buffer is applied over a longer period of time.

Before the end of a Crediting Period for an Index Account Option, if you take any type of partial withdrawal, or if a fee or charge is deducted from that Index Account, your investment base will be proportionately reduced. This negative adjustment could be greater than the amount withdrawn or deducted and could negatively impact your gains or losses significantly.

All withdrawals taken, and fees and charges deducted (including fees and charges that are periodically deducted from your Policy), before the end of a Crediting Period will trigger a negative adjustment to your Index Base. A negative adjustment to your Index Base may be greater than the reduction in your Interim Value. See APPENDIX B: ADDITIONAL EXAMPLES FOR INDEX ACCOUNT OPTIONS for examples of how your Index Base could be negative adjusted as a result of a fee or withdrawal.

(2)(iv) Methodology and Examples

CALCULATING YOUR INVESTMENT AMOUNT ON A TERM END DATE

The Performance Rate can be positive, zero or negative and is determined as follows:

Shield Option type: | If Index Performance is: | Performance Rate will equal:
Shield Options with a Cap Rate | less than or equal to zero greater than zero and less than the Cap Rate greater than zero and equals or exceeds the Cap Rate | the lesser of: zero or the Index Performance increased by the Shield Rate (For example: a -15% Index Performance with Shield 10 will result in a -5% Performance Rate. The Performance Rate can never be greater than zero if the Index Performance is negative.) the Index Performance the Cap Rate
Shield Options with a Step Rate | less than zero equal to or greater than zero | the lesser of: zero or the Index Performance increased by the Shield Rate (For example: a -15% Index Performance with Shield 10 will result in a -5% Performance Rate. The Performance Rate can never be greater than zero if the Index Performance is negative). the Step Rate

Annual Return for last 10 years: Shield Option with 10% Cap Rate and 10% Buffer

The performance below is NOT the performance of any Index-Linked Option. Your performance under the Contract will differ, perhaps significantly. The performance below may reflect a different return calculation, time period, and limit on Index gains and losses than the Index-Linked Options, and does not reflect Contract fees and charges, including surrender charges and the Contract Adjustment, which reduce performance.

Year 1: The Index Change for the Contract Year is 13%. Due to the 10% Cap Rate, the Adjusted Index Change locked in for that Contract Year is 10%.

Year 2: The Index Change for the Contract Year is -5%. Although the Index Change was negative, it was still within the 10% Buffer amount, so all of the negative return is absorbed by the 10% buffer and the Adjusted Index Change locked in for that Contract Year is 0%.

Year 3: The Index Change for the Contract Year is 10%. Since the Index Change was positive but did not exceed the Cap Rate, the full 10% Index Change is locked in for that Contract Year.

Year 4: The Index Change for the Contract Year is -12%. Since the negative Index Change exceeds the 10% Buffer, you are partially protected from loss up to the 10% Buffer and the Adjusted Index Change locked in for that Contract Year is the remaining 2% loss.

Example 1A—Shield Option with Cap Rate:

Owner 1 allocates her $50,000 Purchase Payment into a 1-Year Term / Shield 10 / S&P 500® Index with a Cap Rate of 10% and lets it renew year after year for five years. The following example illustrates how her initial $50,000 Purchase Payment could perform over a five-year period given fluctuating Index Values. For renewals into the same Shield Option a new Cap Rate would be declared and go into effect on the Contract Anniversary that coincides with the beginning of the new Shield Option. In some cases, we may declare a Cap Rate for a Shield Option as “uncapped” in which case the Performance Rate that can be received is equal to the Index Performance, subject to the Shield Rate. The example assumes no withdrawals.

Contract Year | 1 | 2 | 3 | 4 | 5
Term Start Date
Investment Amount(1) | $50,000 | $55,000 | $57,750 | $57,750 | $57,750
Index Value | 1,000 | 1,200 | 1,260 | 1,260 | 1,197
Term End Date
Index Value | 1,200 | 1,260 | 1,260 | 1,197 | 1,017
Index Performance(2) | 20% | 5% | 0% | -5% | -15%
Cap Rate | 10% | 10% | 10% | 10% | 10%
Shield Rate | 10% | 10% | 10% | 10% | 10%
Performance Rate (one year)(3) | 10% | 5% | 0% | 0% | -5%
Performance Rate Adjustment(4) | $5,000 | $2,750 | $0 | $0 | -$2,888
Investment Amount(5) | $55,000 | $57,750 | $57,750 | $57,750 | $54,862

Footnote 1: The Index Return above is a “price return index” and not a “total return index”, which means that the return does not reflect any dividends paid on the assets composing the Index, which will reduce the Index return and cause the Index to underperform a direct investment in the securities composing the Index.

Footnote 2: The underlying Index deducts fees and expenses when calculating the Index return, which reduces your return and will cause the Index to underperform a direct investment in the securities composing the Index.

(2)(v) Indexes

INDEXES

Currently, each Index-Linked Interest Strategy credits interest based on the performance of one of the following Indexes, each covering different asset classes.

S&P 500® Index (SPX). Widely regarded as the best gauge of the U.S. stock market, this world-renowned index tracks the performance of 500 large companies in leading industries of the U.S. economy.

Russell 2000® Index (RTY). The Russell 2000® Index measures the performance of the small-cap segment of the U.S. equity universe. It is a subset of the Russell 3000® Index and includes approximately 2,000 of the smallest securities based on a combination of their market cap and current index membership.

Nasdaq-100 Index® (NDX). The Nasdaq-100 Index includes 100 of the largest domestic and international non-financial companies listed on the Nasdaq Stock Market based on market capitalization. The Index reflects companies across major industry groups including computer hardware and software, telecommunications, retail/wholesale trade and biotechnology.

MSCI EAFE Index (MXEA). MSCI EAFE Index is an equity index that captures large and mid-cap representation across 21 developed markets around the world, including Europe, Australasia and the Far East, excluding the United States and Canada. The Index covers approximately 85% of the free float-adjusted market capitalization in each of the 21 countries

iShares® Russell 2000 ETF. The iShares® Russell 2000 ETF (NYSE Arca: IWM) (SEC file number 333-92935) seeks to track the investment results of the Russell 2000® Index, an index composed of small-capitalization U.S. equities. The Russell 2000® Index measures the performance of the small capitalization sector of the U.S. equity market, as defined by FTSE Russell.

We reserve the right to add, remove or replace any Index-Linked Interest Strategy, Index, or Crediting Method in the future, subject to any necessary regulatory approvals. If we replace an Index, this will not cause a change in the Cap Rate, Performance Trigger Rate, Floor or Buffer for the current Crediting Period. Adding or removing an Index does not cause a change in the Floor or Buffer because those elements do not change for the life of your Contract. Any Index-Linked Interest Strategies based on the performance of a newly added Index will have a new Cap Rate or Performance Trigger Rate. Changes to the Cap Rates or Performance Trigger Rates, if any, occur at the start of the next Crediting Period. If we add or remove an Index (as opposed to replacing an Index with another Index), the changes will not be effective for your Contract until the start of the next Crediting Period.

We may replace an Index if it is discontinued or the Index is no longer available to us or if the Index’s calculation changes substantially. Additionally, we may replace an Index if hedging instruments become difficult to acquire or the cost of hedging becomes excessive. We may do so at the end of a Crediting Period or during a Crediting Period. We will notify you in writing at least 30 days before we replace an Index.

If we replace an Index, we will attempt to select a new Index that is similar to the old Index. In making this evaluation, we will look at factors such as asset class, Index composition, strategy, or methodology inherent to the Index and Index liquidity. If we replace an Index during a Crediting Period, we will calculate the Index Change using the old Index up until the replacement date. After the replacement date, we will calculate the Index Change using the new Index, but with a modified start of Crediting Period value for the new Index. The modified start of Crediting Period value for the new Index will reflect the Index Change for the old Index from the start of the Crediting Period to the replacement date.

The value of an Index at the end of a day. When the Index is a market index, the Index Value at the end of a day is the closing value of the Index for that day. When the Index is an exchange-traded fund, the Index Value at the end of a day is the closing share price of the fund for that day on the fund’s primary stock exchange. The Index Value on any day that is not a Business Day is the value of the Index at the end of the next Business Day. The Company relies on the Index Values reported by a third-party. By using closing share price instead of the total return, your Index may perform worse than a direct investment in the underlying ETF itself.

Index Values do not include income from any dividends or other distributions paid by a market index’s component companies or by an ETF. The exclusion of dividends and other distributions from Index Values negatively impacts an Index’s performance.

Additional Index information, including disclaimers, may be found in Appendix C. The investment risks associated with the Indexes are discussed under the section titled “Index Risk.”

(2)(vi) Maturity

End of a Crediting Period. If you are coming to the end of a Crediting Period, we will send you a Renewal Letter (which will include current upside rates) at least 21 days before the end of the Crediting Period. We must receive your instructions at least one Business Day before the end of the Crediting Period. In the absence of instructions, your Policy Value in the expiring Allocation Account will be automatically reinvested in the same Allocation Account for another Crediting Period. If the expiring Allocation Account is no longer available for investment, your Policy Value in the expiring Allocation Account will be transferred to the Default Option.

(2)(vii) Other Material Features

Standard Benefits (No Additional Charge) |
Name of Benefit | Purpose | Brief Description of Restrictions/Limitations |
Free Withdrawal Privilege | Allows you to withdraw up to 10% of your total Purchase Payments each Contract Year without incurring a withdrawal charge. | • Only available during the Accumulation Phase. • Not available upon a full withdrawal. • Unused free withdrawal amounts not available in future years. • Program withdrawals may be subject to negative Daily Adjustments. • Program withdrawals are subject to income taxes, and may also be subject to a 10% additional federal tax for amounts withdrawn before age 59 1∕2. |
Minimum Distribution Program | Allows you to automatically take withdrawals to satisfy the minimum distribution requirements (RMD) imposed by the Internal Revenue Code. | • Only available during the Accumulation Phase. • Only available to IRA or SEP IRA Contracts. • Generally required for Inherited IRA and Inherited Roth IRA Contracts. • Program withdrawals count against free withdrawal privilege. • Program withdrawals may be subject to negative Daily Adjustments. • Program withdrawals are subject to income taxes. • Program withdrawals may be monthly, quarterly, semi-annual or annual, unless you have less than $25,000 in Contract Value, in which case only annual payments are available. • We reserve the right to discontinue or modify the program subject to the requirements of law. |
Waiver of Withdrawal Charge Benefit | Waives withdrawal charges if you are confined for care, or are unable to perform at least two out of six activities of daily living (ADLs). | • Only available during the Accumulation Phase. • Confinement must begin after the first Contract Anniversary, be for at least 90 days in a 120-day period, and requires proof of stay. • Inability to perform two ADLs must be for at least 90 consecutive days and may require an exam or tests by a physician. • Not available on the Issue Date if any Owner was confined to an eligible facility, or unable to perform all six ADLs. • Program withdrawals count against free withdrawal privilege. • Program withdrawals may be subject to negative Daily Adjustments. • Program withdrawals are not subject to withdrawal charges, but are subject to income taxes, and may also be subject to a 10% additional federal tax for amounts withdrawn before age 59 1∕2. • State variations may apply.

Traditional Death Benefit | Provides a death benefit equal to the greater of the Contract Value, or Guaranteed Death Benefit Value. The Guaranteed Death Benefit Value is total Purchase Payments adjusted for withdrawals. An example of the death benefit provided by the Traditional Death Benefit is included in section 10, Death Benefit. An example of how deduction of financial adviser fees impact the death benefit is included in section 1. | • Benefit only available during the Accumulation Phase. • Withdrawals, including any negative Daily Adjustments, may significantly reduce the benefit as indicated in section 1, Financial Adviser Fee Deduction Example. • Restrictions on Purchase Payments may limit the benefit. • Annuitizing the Contract will end the benefit.
Financial Adviser Fees | If you have a financial adviser and want to pay their financial adviser fees from this Contract, you can instruct us to withdraw the fee from your Contract and pay it to your Financial Professional or Financial Professional’s firm as instructed. | • Only available during the Accumulation Phase. • Financial adviser fees are in addition to the Contract’s fees and expenses. • Deductions for financial adviser fees are treated as withdrawals under the Contract. • Program withdrawals count against free withdrawal privilege. • Program withdrawals may be subject to negative Daily Adjustments. • Program withdrawals are subject to withdrawal charges and income taxes, and may also be subject to a 10% additional federal tax for amounts withdrawn before age 59 1∕2. • We reserve the right to discontinue or modify the program. • See section 1 for an example of how deduction of financial adviser fees impact the Contract.

Item 6(e) Fixed Options

FIXED INTEREST STRATEGY

The Fixed Interest Strategy credits compound interest based on rates that are set and guaranteed by us. Any portion of your Account Value allocated to the Fixed Interest Strategy for a Crediting Period will be credited with the interest rate established for that Crediting Period, which will apply for the entire Crediting Period. Once a Crediting Period is over, we will declare a new interest rate for the next Crediting Period.

The interest rate for the Fixed Interest Strategy for the initial Crediting Period will be set forth in your Contract. Prior to the beginning of each subsequent Crediting Period, we will mail to you a 30-day advance written notice indicating how you may obtain the interest rate for the Fixed Interest Strategy for the next Crediting Period.

The effective annual interest rate for any Crediting Period will never be lower than the guaranteed minimum interest rate of [1%]. This rate is guaranteed to be a rate not less than the minimum interest rate allowed by state law. The effective annual interest rate represents the rate of daily compounded interest over a 12-month period. You bear the risk that we will never declare an interest rate for the Fixed Interest Strategy higher than the guaranteed minimum interest rate.

Payments from the Fixed Interest Strategy are also subject to minimum amounts required by state law. These minimum amounts only apply upon annuitization from the Fixed Interest Strategy, payment of a death benefit upon death of the Owner, or a full withdrawal from the Fixed Interest Strategy. We guarantee that if one of these events occurs, then the proceeds from the Fixed Interest Strategy (the amount applied to annuity payments or paid for a full withdrawal or death benefit) will be at least equal to the minimums required by state law. If necessary to meet this minimum, charges will be waived.

The Contract provides that you must allocate your Premium payment among the available investment options on the Effective Date for the initial Crediting Period. You may reallocate your Account Value in any investment option among the available investment options for subsequent Crediting Periods following the end of a Crediting Period by providing new allocation instructions to us, as discussed under the section titled “Transfers.” You may not reallocate your Account Value in the Fixed Interest Strategy or any Index-Linked Interest Strategy until the end of the Crediting Period applicable to the Fixed Interest Strategy or the Index-Linked Interest Strategy.

How do withdrawals affect my Fixed Interest Strategy Value and Strategy Account Values? When you take a withdrawal from your Fixed Interest Strategy, your Fixed Interest Strategy Value is reduced by the dollar amount of the withdrawal, including any applicable surrender charges. When you take a withdrawal from an Index-Linked Interest Strategy, the applicable Strategy Account Value is reduced in the same manner. However, if you take a withdrawal from an Index-Linked Interest Strategy, the withdrawal will also cause a proportional reduction (perhaps significant reduction) to your Strategy Base Value. A reduction in your Strategy Base Value negatively impacts your Strategy Account Value. Overall, withdrawals may result in a loss of principal due to adjustments and charges that may be imposed even if Index Performance has been positive.

Item 7(e) Contract Adjustment.

DAILY ADJUSTMENT

The Daily Adjustment is how we calculate Index Option Values on Business Days other than the Term Start Date or Term End Date. This is because there is always some risk that the Index Option Value would have declined by the Term End Date such that you would suffer a loss if you had not withdrawn.

The Daily Adjustment can affect the amounts available for withdrawal, Performance Locks, annuitization, payment of the death benefit, and the Contract Value used to determine the RMD payments, Charge Base, and contract maintenance charge. The Daily Adjustment can be positive or negative. When the Daily Adjustment is positive, your Index Option Value has increased since the Term Start Date. When it is negative, your Index Option Value has decreased (excluding the effect of the deduction of Contract expenses or any partial withdrawal). The Daily Adjustment for the Index Protection Strategy with Trigger cannot be negative.

We calculate the Daily Adjustment for a given Business Day before we deduct any Contract fees or expenses or process any partial withdrawal on that Business Day, including Penalty-Free Withdrawals, and any financial adviser fees that you choose to have us pay from this Contract. The Daily Adjustment does not change the Contract fee or expense deducted, or the withdrawal amount; it only changes the Index Option Value from which we deduct the Contract fee or expense, or withdrawal.

The Daily Adjustment approximates the Index Option Value that will be available on the Term End Date. It is the estimated present value of the future Performance Credit that we will apply on the Term End Date. The Daily Adjustment takes into account:

i. any Index gains during the Term subject to the applicable Trigger Rate, Cap, and/or Participation Rate,

| ii. | for the Index Dual Precision Strategy, any Index losses less than or equal to the 10% Buffer,

| iii. | either any Index losses greater than the 10%, 20%, or 30% Buffer, or Index losses down to the -10% Floor (not applicable to the Index Protection Strategy with Trigger), and

iv. the number of days until the Term End Date.

The Daily Adjustment does this by using the hypothetical value of a Proxy Investment (Proxy Value) each Business Day, other than the Term Start Date or Term End Date, based on the formulas described in Appendix B. The Proxy Investment provides a current estimated present value of what the Performance Credit will be on the Term End Date taking into account the applicable Buffer, Floor, Trigger Rate, Cap, and/or Participation Rate. The Daily Adjustment is not the actual Index return on the day of the calculation, and the estimated present value Performance Credit is not guaranteed. Therefore, the Daily Adjustment could result in a loss beyond the protection of the Buffer or Floor. In extreme circumstances the Daily Adjustment could result in a loss beyond the protection of the 10%, 20%, or 30% Buffer; or -10% Floor. The maximum potential loss from a negative Daily Adjustment is: -99% for the Index Dual Precision Strategy, Index Precision Strategy, and Index Performance Strategy; and -35% for the Index Guard Strategy. Such losses will be greater if the amount withdrawn (including any financial adviser fees that you choose to have us pay from this Contract) is also subject to a withdrawal charge, or is a deduction of Contract fees and expenses.

A withdrawal taken during the Term may not receive the full benefit of the Buffer or Floor because the Daily Adjustment takes into account what may potentially happen between the withdrawal date and the Term End Date. All other factors being equal, even if the current Index return during the Term is greater than the Cap, or the Trigger Rate for the Index Dual Precision Strategy or Index Precision Strategy, the Daily Adjustment will usually be lower than the Cap or Trigger Rate. For the Index Protection Strategy with Trigger and Index Precision Strategy, even if the current Index return during the Term is greater than or equal to zero, the Daily Adjustment will usually be lower than the Trigger Rate. For the Index Dual Precision Strategy, even if the Index return is greater than -10%, the Daily Adjustment will usually be lower than the Trigger Rate. This is because there is a possibility that the Index return could decrease before the Term End Date. Similarly, even though a negative Index return may be within the 10%, 20%, or 30% Buffer for the Index Dual Precision Strategy, Index Precision Strategy, and Index Performance Strategy, you still may receive a negative Daily Adjustment because there is a possibility that the Index Return could decrease before the Term End Date. The Daily Adjustment for Index Options with a Term length of more than 1-year may be more negatively impacted by changes in the expected volatility of Index prices than 1-year Term Index Options due to the difference in Term length. Also, the risk of a negative Daily Adjustment is greater for Index Options with a Term length of more than 1-year than for 1-year Term Index Options due to the Term length. 3-year and 6-year Term Index Options with a Participation Rate above 100% may also have larger fluctuations in

the Daily Adjustment than Index Options either without a Participation Rate, or with a Participation Rate equal to 100%. Finally, a negative Index return for the Index Guard Strategy may result in you receiving a Daily Adjustment lower than the -10% Floor, because the Daily Adjustment reflects the present value of the Floor and you will not receive the full benefit of the -10% Floor until the Term End Date. A negative Daily Adjustment may cause you to realize loss of principal and previous earnings.

The Contract Adjustment applies to your Index Option Value before any deductions are made for withdrawal or surrender fees. Accordingly, the final amount you receive upon a withdrawal or surrender value may be reduced below the Index Option Value after applying the Contract Adjustment.

To obtain information about the current value of a Contract Adjustment, visit our website at InsurerABC.com. The Contract Adjustment can fluctuate daily, and the current value quoted on the website may differ from the actual value calculated at the time of the adjustment.

Item 17. Investment Options Available Under the Contract

(a)

Type/Investment Objective | Portfolio Company and Adviser/ Subadviser | Current Expenses | Average Annual Total Returns (as of 12/31/23)
1 year | 5 year | 10 year
S&P 500® Index | Fantasist, LLC | .05% | 10% | 6% | 7%
iShares® MSCI Emerging Markets ETF | BlackRock Investments, LLC | 1.20% | 8% | 7% | 8%
iShares® U.S. Technology ETF | BlackRock Investments, LLC | .95% | 12% | 7% | 9%

(b) Index-Linked Options

The following is a list of Index-Linked Options currently available under the Contract. We may change the features of the Index Linked Options listed below (including the Index and the current limits on Index gains and losses), offer new Index-Linked Options, and terminate existing Index-Linked Options. We will provide you with written notice before making any changes other than changes to current limits on Index gains. Information about current limits on Index gains is available at [website address].

Note: If amounts are removed from an Index-Linked Option before the end of its Crediting Period, we [may/will] apply a Contract Adjustment. This may result in a significant reduction in your Contract value that could exceed any protection from Index loss that would be in place if you held the option until the end of the Crediting Period.

Depending on the optional benefits you choose, you may notbe able to invest in certain Investment Options, as noted below.

Index | Type of Index | Crediting Period | Index Crediting Methodology | Current Limit on Index Loss (if held until end of Crediting Period) | Minimum Limit on Index Gain (for the life of the Index-Linked Option)
S&P 500 Index | Index seeks to track the S&P 500[2] | 1 Year | Cap/Buffer | -10% Buffer | Cap Rate: No lower than 2.00%
iShares® U.S. Technology ETF | ETF | 1 Year | Cap Rate/Floor | -10% | Cap Rate: No lower than 3%
Fantasist World Factor Leaders Index | Market Index | 3 Years | Participation Rate | N/A | N/A[3]

(c) Fixed Options

The following is a list of Fixed Options currently available under the Contract. We may change the features of the Fixed Options listed below, offer new Fixed Options, and terminate existing Fixed Options. We will provide you with written notice before doing so.

Note: If amounts are withdrawn from a Fixed Option before the end of its term, we [may/will] apply a Contract Adjustment. This may result in a significant reduction in your Contract value.

FIXED ACCOUNT OPTION

The table below shows the Fixed Account Option that we currently offer. We may offer other Fixed Account Options in the future.

FIXED ACCOUNT OPTION CURRENTLY AVAILABLE FOR INVESTMENT
Crediting Period |  | Guaranteed Minimum Effective Annual Interest Rate
1-Year |  | 0.25%

(d) Restrictions

Investment Option | Minimum Distribution Program | Financial Advisor Fees | Traditional Death Benefit | Waiver of Withdrawal Charge Benefit
S&P 500 Index | þ | þ | þ | þ
iShares® U.S. Technology ETF | þ | þ | þ |
Fantasist World Leaders Index | þ | þ |  |

Item 26(c) Changes in and Disagreements with Accountants.

Sample 1

CHANGE IN CERTIFYING ACCOUNTANT

(a) Dismissal of Independent Registered Public Accounting Firm

Deloitte & Touche LLP, or Deloitte, served as our independent registered public accounting firm prior to completion of the Merger. On March 25, 2024, following the completion of the Merger, Deloitte was dismissed as our independent registered public accounting firm. The decision to dismiss Deloitte was approved by the Audit Committee of the Board.

The reports of Deloitte on our consolidated financial statements for the fiscal years ended December 31, 2023 and 2022 did not contain an adverse opinion or disclaimer of opinion and were not qualified or modified as to uncertainty, audit scope or accounting principles, or other similar opinion as defined in Item 304(a)(1)(ii) of Regulation S-K (17 CFR § 229.304(a)(1)(ii) except for an explanatory paragraph regarding existence of substantial doubt about the Company’s ability to continue as a going concern in the report for the year ended December 31, 2023.

During our two most recent fiscal years and the subsequent period from January 1, 2024 to March 25, 2024, there were (i) no disagreements (as defined in Item 304(a)(1)(iv) of Regulation S-K and the related instructions thereto) with Deloitte on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedure, which disagreement, if not resolved to the satisfaction of Deloitte, would have caused it to make reference to the subject matter of the disagreement in connection with its report and (ii) no reportable events (as described in Item 304(a)(1)(v) of Regulation S-K).

We provided Deloitte with a copy of the disclosures made above and requested Deloitte to furnish us with a letter addressed to the SEC stating whether it agrees with the statements made by us and, if not, stating the respects in which it does not agree. A copy of Deloitte’s letter to the SEC dated March 26, 2024 regarding these statements is filed as Exhibit 16.1 hereto.

Sample 2

On August 15, 2019, Saturna Group Chartered Professional Accountants LLP (“Saturna Group”) provided notice that they could no longer provide audit services to the Company.

The reports of Saturna Group on our financial statements for the fiscal years ended July 31, 2018 and July 31, 2017 did not contain an adverse opinion or a disclaimer of opinion, nor were such reports qualified or modified as to uncertainty, audit scope or accounting principles, except that the accountant’s reports of Saturna Group on our financial statements as of and for the fiscal years ended July 31, 2017 and 2018 stated that we have suffered losses from operations and have a working capital deficit, and that these conditions raise substantial doubt about our ability to continue as a going concern.

During our fiscal years ended July 31, 2017 and 2018 and the subsequent interim period through August 15, 2019, the date of the notice from Saturna Group, we did not have any disagreement with Saturna Group on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedure.

During that time, there were no “reportable events” as set forth in Item 304(a)(1) of Regulation S-K adopted by the Securities and Exchange Commission, except that (i) the accountant’s reports of Saturna Group on our financial statements as of and for the fiscal years ended July 31, 2017 and 2018 stated that we have suffered losses from operations and have a working capital deficit, and that these conditions raise substantial doubt about our ability to continue as a going concern, (ii) our disclosure controls and procedures were not effective for the fiscal years ended July 31, 2017 and 2018, as reported in our annual reports on Form 10-K for the fiscal years ended July 31, 2017 and 2018, and (iii) our management identified material weaknesses in our internal control over financial reporting for the fiscal years ended July 31, 2017 and 2018, as reported in our annual reports on Form 10-K for the fiscal years ended July 31, 2017 and 2018. The material weaknesses included weaknesses in procedures for control evaluation, a lack of an audit committee, insufficient documentation of review procedures, and insufficient information technology procedures. Our board of directors have discussed these matters with Saturna Group, and we authorized Saturna Group to respond fully to the inquiries of our successor accountant, M&K CPAs, concerning these matters.

New independent registered public accounting firm

On September 9, 2019, we engaged M&K CPAs as our independent registered public accounting firm for our fiscal year ended July 31, 2019. The decision to engage M&K CPAs as our independent registered public accounting firm was approved by our board of directors.

During the two most recent fiscal years and through September 9, 2019, we have not consulted with M&K CPAs regarding either of the following:

| 1. | the application of accounting principles to any specified transaction, either completed or proposed, or the type of audit opinion that might be rendered on our financial statements, and neither a written report was provided to us nor oral advice was provided that M&K CPAs concluded was an important factor considered by us in reaching a decision as to the accounting, auditing or financial reporting issue; or

| 2. | any matter that was either the subject of a disagreement (as defined in paragraph (a)(1)(iv) of Item 304 of Regulation S-K and the related instructions thereto) or a reportable event (as described in paragraph (a)(1)(v) of Item 304 of Regulation S-K).

Sample 3

CHANGE IN AUDITOR

On November 29, 2022, Marcum was terminated as the Company’s independent registered public accounting firm. The Audit Committee of the Board of Directors of the Company and the entire Board of Directors of the Company approved the termination of Marcum.

On January 26, 2023, Deloitte LLP (“Deloitte”) was engaged as the Company’s independent registered public accounting firm to audit the Company’s consolidated financial statements for the year ended November 30, 2022. The Audit Committee of the Board of Directors of the Company and the entire Board of Directors of the Company approved the hiring of Deloitte.

Marcum’s report of independent registered public accounting firm, dated November 3, 2022, on the Company’s balance sheets as of November 30, 2021 and 2020 and the related accompanying statements of operations, changes in stockholder’s equity (deficit) and cash flows for the years ended November 30, 2021 and 2020, and the related notes did not contain any adverse opinion or disclaimer of opinion, nor were they qualified or modified as to uncertainty, audit scope or accounting principles.

During the period from December 1, 2020 through November 29, 2022 (the date of Marcum’s termination), there were no: (i) disagreements with Marcum on any matter of accounting principles or practices, financial statement disclosures or audited scope or procedures, which disagreements if not resolved to Marcum’s satisfaction would have caused Marcum to make reference to the subject matter of the disagreement in connection with its report or (ii) reportable events as defined in Item 304(a)(1)(v) of Regulation S-K under the Exchange Act, except, for the years ended November 30, 2020 and November 30, 2021, a material weakness associated with controls related to accounting for (i) the carve-out allocation process, (ii) the royalty transaction with GoldMining Inc., (iii) a past stock split, (iv) asset retirement costs, and (v) classification of related party liabilities.

During the period from December 1, 2020 through November 30, 2022, and the subsequent period through January 26, 2023 (the date Deloitte was engaged by the Company), the Company did not consult Deloitte with respect to either (i) the application of accounting principles to a specified transaction, either completed or proposed, or the type of audit opinion that might be rendered on the Company’s financial statements, and no written report or oral advice was provided to the Company by Deloitte that Deloitte concluded was an important factor considered by the Company in reaching a decision as to the accounting, auditing or financial reporting issue; or (ii) any matter that was either the subject of a disagreement, as that term is described in Item 304(a)(1)(iv) of Regulation S-K under the Exchange Act and the related instructions to Item 304 of Regulation S-K under the Exchange Act, or a reportable event, as that term is defined in Item 304(a)(1)(v) of Regulation S-K under the Exchange Act.

The Company has provided Marcum with a copy of the foregoing disclosures pursuant to Item 304(a) of Regulation S-K under the Exchange Act and has requested that Marcum furnish the Company with a letter addressed to the SEC stating whether it agrees with the statements herein made by the registrant set forth above. A letter from Marcum is filed as Exhibit 16.1 to the registration statement of which this prospectus forms a part.

Item 31A. Information about Contracts with Index-Linked Options and Fixed Options Subject to a Contract Adjustment

(a) For any Contract with Index-Linked Options and/or Fixed Options subject to a Contract Adjustment offered through this registration statement, provide the information required by the following table as of December 31 of the prior calendar year:

(b) For any Contract with Index-Linked Options offered through this registration statement that posts current limits on Index gains on a website in accordance with Instruction 1 to Item 6(d)(2)(ii)(B), provide the current limits on Index gains in effect for each Index-Linked Option during the twelve months ending on December 31 of the prior year.

Instruction. The information called for in this paragraph may be provided in an exhibit to the registration statement

Name of the Contract | Number of Contracts outstanding | Total value attributable to the Index-Linked Option and/or Fixed Option subject to a Contract Adjustment | Number of Contracts sold during the prior calendar year | Gross premiums received during the prior calendar year | Amount of Contract value redeemed during the prior calendar year | Combination Contract (Yes/No
RILA Index Performance w/ Buffer[4] | 100 | $250,000 | 10 | $10,000 | $16,000 | Yes
RILA Index Performance w/ Floor[5] | 200 | $500,000 | 30 | $20,000 | $27,000 | Yes
Fixed Income Option | 300 | $1,200,000 | 40 | $30,000 | $40,000 | No

[1] If before the Term End Date you take a full or partial withdrawal (including any financial adviser fees that you choose to have us pay from this Contract), execute a Performance Lock, annuitize the Contract, we pay a death benefit, or when we deduct Contract fees and expenses, we calculate the Index Option Value by applying the Daily Adjustment.

[2] Index does not include dividends paid, and the return reflects management fees deducted from the return. Accordingly, the Index will underperform a direct investment in the securities comprising the Index.

[3] Insurer does not guarantee that the Contract will always offer Index-Linked Options that limit index losses.

[4] Current limit on Index Gain for the 12 months ending Dec. 31, 2024: 3.00%

[5] Current limit on Index Gain for the 12 months ending Dec. 31, 2024: 2.00%