Pruco Life Inurance Co Of New Jersey FLXBL Prmium Var Ann Ac
Filed: 6 Sep 07, 12:00am
3
September 6, 2007
Ms. Sally Samuel, Esq.
Office of Insurance Products
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE: Post-effective amendments to certain Form N-4 and S-3 registration statements
Dear Ms. Samuel:
We are responding to your comments on certain post-effective amendments filed under Rule 485(a) and Rule 424, and asking the Staff to
accelerate the effective date of those filings to September 11, 2007 or as soon as possible thereafter. In addition, we are filing
herewith post-effective amendments under Rule 424 to the Form S-3 registration statements that share a common prospectus with certain
of the Form N-4s, and seeking effectiveness of those filings on September 11, 2007 or as soon as possible thereafter.
A summary of your comments and our responses follows:
1. Pruco Life Insurance Company of New Jersey ("PLNJ") Prudential Premier Series (333-131035 and 333-144657); PLNJ Strategic
Partners Annuity One 3 and Strategic Partners Plus 3 (333-49230).
o As we discussed by telephone, due to a revised product strategy, we have eliminated the section of each supplement entitled
"Changes to Lifetime Five and Spousal Lifetime Five."
o With respect to each supplement, you asked that the following sentences not appear: "The Highest Daily Lifetime Five
program described below is only being offered in those jurisdictions where we have received regulatory approval and
will be offered subsequently in other jurisdictions when we receive regulatory approval in those jurisdictions.
Certain terms and conditions may differ between jurisdictions once approved." You also suggested that a statement be
added to each supplement, noting that the "Permitted Sub-accounts" are identified in the annuity application. We have
made those changes.
o With respect to the supplement for Prudential Premier Series only, you asked that the formula under which asset transfers
under the Highest Daily Lifetime Five benefit are made be set forth in the supplement. We have made that change.
o With respect to the supplement for Strategic Partners Annuity One 3/Strategic Partners Plus 3 only, you (a) identified
several instances in which the reference to "Liability Ratio" should be changed to "Target Ratio" and (b) asked that
certain section headings be made more prominent. We have made those changes.
The changes discussed above are reflected in correspondence filings that we are making herewith. In addition, we are filing
herewith a post-effective amendment under Rule 424 to the Form S-3 that offers the companion MVA option to Strategic
Partners Annuity One 3/Strategic Partners Plus 3 (333-103473). That post-effective amendment contains a prospectus
supplement reflecting the above changes.
Along with this letter, we are including acceleration requests, seeking effectiveness of the Form N-4 filings (including the
SAI supplements) and S-3 filing on September 11, 2007.
1. Strategic Partners Horizon of PLNJ and Pruco Life Insurance Company ("Pruco Life") (333-100713 and 333-104036). You had no
comments on this prospectus supplement. Therefore, we are simply requesting acceleration of the effective date of each filing
to September 11, 2007 or as soon as possible thereafter.
2. Strategic Partners Select of PLNJ and Pruco Life (333-62238 and 333-52754). You had no comments on this prospectus
supplement. Therefore, we are simply requesting acceleration of the effective date of each filing (including the SAI
supplement) to September 11, 2007 or as soon as possible thereafter. In addition, we are filing herewith post-effective
amendments under Rule 424 to each Form S-3 offering the companion MVA option (333-62246 and 333-61143). Each post-effective
amendment contains a prospectus supplement reflecting the same changes as were set forth in the Form N-4 filings.
We represent and acknowledge that:
o the depositor and the registrant are responsible for the adequacy and accuracy of the disclosure in the instant filings; and
o staff comments, or changes to disclosure in response to staff comments in the filings reviewed by the staff, do not
foreclose the Commission from taking any action with respect to the instant filings; and
o the depositor and the registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.
We appreciate your attention to these filings.
Sincerely,
/s/C. Christopher Sprague
C. Christopher Sprague
Pruco Life Insurance Company Of New Jersey
Prudential Premier Series Annuity
Prudential Premier Bb Series Annuity
Supplement to Prospectuses Dated May 1, 2007
Supplement dated November 19, 2007
This Supplement should be read and retained with the current Prospectus for your annuity. This Supplement is intended to update
certain information in the Prospectus for the variable annuity you own, and is not intended to be a prospectus or offer for any
other variable annuity listed here that you do not own. If you would like another copy of the current Prospectus, please contact
us at 1-888-PRU-2888.
In this supplement, we describe a new lifetime guaranteed withdrawal benefit called the Highest Daily Lifetime Five Income
Benefit. We set forth one additional Advanced Series Trust portfolio that is being offered as a new variable investment option.
Finally, we describe a change to the Annuity Date provision and introduce a new principal underwriter of the Annuities.
I. TABLE OF CONTENTS
o As a new entry within the line item entitled "Living Benefit Programs", immediately after the line item for Spousal Lifetime
Five, we add a line item entitled "Highest Daily Lifetime FiveSM Income Benefit (Highest Daily Lifetime Five)".
II. GLOSSARY OF TERMS
o We add a definition for Benefit Fixed Rate Account, that reads as follows: "An investment option offered as part of this
Annuity that is used only if you have elected the Highest Daily Lifetime Five Benefit. Amounts allocated to the Benefit
Fixed Rate Account earn a fixed rate of interest, and are held within our general account. You may not allocate purchase
payments to the Benefit Fixed Rate Account. Rather, Account Value is transferred to the Benefit Fixed Rate Account only
under the asset transfer feature of each benefit."
o We add a definition for Highest Daily Lifetime Five Benefit that reads as follows: "An optional feature available for an
additional cost that guarantees your ability to withdraw amounts equal to a percentage of a principal value called the
Protected Withdrawal Value. Subject to our rules regarding the timing and amount of withdrawals, we guarantee these
withdrawal amounts, regardless of the impact of market performance on your Account Value."
III. SUMMARY OF CONTRACT FEES AND CHARGES
o In the Summary of Contract Fees and Charges section, under Your Optional Benefit Fees and Charges, we add the following
(immediately after the entry for Spousal Lifetime Five Income Benefit), to reflect the charge for Highest Daily Lifetime
Five:
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YOUR OPTIONAL BENEFIT FEES AND CHARGES
TOTAL TOTAL TOTAL TOTAL
OPTIONAL ANNUAL ANNUAL ANNUAL ANNUAL
BENEFIT CHARGE[1] CHARGE[1] CHARGE[1] CHARGE[1]
OPTIONAL BENEFIT FEE/ for for for for
CHARGE B Series L Series X Series Bb Series
------------------- ----------------- ----------------- ----------------- ----------------- -----------------
-------------------------------------------------------------------------------------------------------------
HIGHEST DAILY LIFETIME FIVE
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------------------- ----------------- ----------------- ----------------- ----------------- -----------------
1.75% 2.10% 2.15% 1.55%
1.50% maximum[2]
0.60% current
charge
------------------- ----------------- ----------------- ----------------- ----------------- -----------------
1 The Total Annual Charge includes the Insurance Charge and Distribution Charge (if applicable) assessed against the average daily
net assets allocated to the Sub-accounts. If you elect more than one optional benefit, the Total Annual Charge would be increased to
include the charge for each optional benefit. With respect to GMIB only, the 0.50% current charge is assessed against the average
GMIB Protected Income Value, and not against the value of the Sub-accounts. These optional benefits are not available under the
Beneficiary Continuation Option.
2 We have the right to increase the charge for each benefit up to the indicated maximum charge upon a step-up or for a new election
of the benefit, or upon a reset of the benefit, if permitted. However, we have no present intention of increasing the charge to that
maximum level.
IV. NEW BENEFIT
o In the Living Benefits Programs section, under the heading "Do you offer programs designed to provide investment protection
for owners while they are alive?", we revise the first sentence immediately following the 4th bullet to state:
"The "living benefits" that Pruco Life of New Jersey offers are the Guaranteed Minimum Income Benefit (GMIB), the Lifetime Five
Income Benefit, the Spousal Lifetime Five Income Benefit, and the Highest Daily Lifetime Five Income Benefit."
o The following description of the new optional living benefit is added immediately after the section for Spousal Lifetime
Five in the "Living Benefit Programs" in the Prospectus:
HIGHEST DAILY LIFETIME FIVE INCOME BENEFIT (HIGHEST DAILY LIFETIME FIVE)
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Highest Daily Lifetime Five is offered as an alternative to Lifetime Five and Spousal Lifetime Five. Currently, if you elect Highest
Daily Lifetime Five and subsequently terminate the benefit, you will not be able to re-elect Highest Daily Lifetime Five, and will
have a waiting period until you can elect Spousal Lifetime Five or Lifetime Five. See "Election of and Designations under the
Program" below for details. The income benefit under Highest Daily Lifetime Five currently is based on a single "designated life" who
is at least 55 years old on the date that the benefit is acquired. The Highest Daily Lifetime Five Benefit is not available if you
elect any other optional living benefit, although you may elect any optional death benefit (other than the Highest Daily Value Death
Benefit). As long as your Highest Daily Lifetime Five Benefit is in effect, you must allocate your Account Value in accordance with
the then permitted and available investment option(s) with this program.
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We offer a benefit that guarantees until the death of the single designated life the ability to withdraw an annual amount (the "Total
Annual Income Amount") equal to a percentage of an initial principal value (the "Total Protected Withdrawal Value") regardless of the
impact of market performance on the Account Value, subject to our program rules regarding the timing and amount of withdrawals. The
benefit may be appropriate if you intend to make periodic withdrawals from your Annuity, and wish to ensure that market performance
will not affect your ability to receive annual payments. You are not required to make withdrawals as part of the program--the
guarantees are not lost if you withdraw less than the maximum allowable amount each year under the rules of the benefit. As discussed
below, we require that you participate in our asset transfer program in order to participate in Highest Daily Lifetime Five, and in
the Appendices to this prospectus, we set forth the formula under which we make those asset transfers.
As discussed below, a key component of Highest Daily Lifetime Five is the Total Protected Withdrawal Value, which is an amount that
is distinct from Account Value. Because each of the Total Protected Withdrawal Value and Total Annual Income Amount is determined in
a way that is not solely related to Account Value, it is possible for the Account Value to fall to zero, even though the Total Annual
Income Amount remains. You are guaranteed to be able to withdraw the Total Annual Income Amount for the rest of your life, provided
that you have not made "excess withdrawals." Excess withdrawals, as discussed below, will reduce your Total Annual Income Amount.
Thus, you could experience a scenario in which your Account Value was zero, and, due to your excess withdrawals, your Total Annual
Income Amount also was reduced to zero. In that scenario, no further amount would be payable under Highest Daily Lifetime Five.
KEY FEATURE--Total Protected Withdrawal Value
The Total Protected Withdrawal Value is used to determine the amount of the annual payments under Highest Daily Lifetime Five. The
Total Protected Withdrawal Value is equal to the greater of the Protected Withdrawal Value and any Enhanced Protected Withdrawal
Value that may exist. We describe how we determine Enhanced Protected Withdrawal Value, and when we begin to calculate it, below. If
you do not meet the conditions described below for obtaining Enhanced Protected Withdrawal Value then Total Protected Withdrawal
Value is simply equal to Protected Withdrawal Value.
The Protected Withdrawal Value initially is equal to the Account Value on the date that you elect Highest Daily Lifetime Five. On
each Valuation Day thereafter, until the earlier of the first withdrawal or ten years after the date of your election of the benefit,
we recalculate the Protected Withdrawal Value. Specifically, on each such Valuation Day (the "Current Valuation Day"), the Protected
Withdrawal Value is equal to the greater of:
o the Protected Withdrawal Value for the immediately preceding Valuation Day (the "Prior Valuation Day"), appreciated at the
daily equivalent of 5% annually during the calendar day(s) between the Prior Valuation Day and the Current Valuation Day
(i.e., one day for successive Valuation Days, but more than one calendar day for Valuation Days that are separated by
weekends and/or holidays), plus the amount of any Purchase Payment (including any associated Credit) made on the Current
Valuation Day; and
o the Account Value.
If you have not made a withdrawal prior to the tenth anniversary of the date you elected Highest Daily Lifetime Five (which we refer
to as the "Tenth Anniversary"), we will continue to calculate a Protected Withdrawal Value. On or after the Tenth Anniversary and up
until the date of the first withdrawal, your Protected Withdrawal Value is equal to the greater of the Protected Withdrawal Value on
the Tenth Anniversary or your Account Value.
The Enhanced Protected Withdrawal Value is only calculated if you do not take a withdrawal prior to the Tenth Anniversary. Thus, if
you do take a withdrawal prior to the Tenth Anniversary, you are not eligible to receive Enhanced Protected Withdrawal Value. If so,
then on or after the Tenth Anniversary up until the date of the first withdrawal, the Enhanced Protected Withdrawal Value is
equal to the sum of:
(a) 200% of the Account Value on the date you elected Highest Daily Lifetime Five;
(b) 200% of all Purchase Payments (and any associated Credits) made during the one-year period after the date you elected
Highest Daily Lifetime Five; and
(c) 100% of all Purchase Payments (and any associated Credits) made more than one year after the date you elected Highest Daily
Lifetime Five, but prior to the date of your first withdrawal.
We cease these daily calculations of the Protected Withdrawal Value and Enhanced Protected Withdrawal Value (and therefore, the Total
Protected Withdrawal Value) when you make your first withdrawal. However, as discussed below, subsequent Purchase Payments (and any
associated Credits) will increase the Total Annual Income Amount, while "excess" withdrawals (as described below) may decrease the
Total Annual Income Amount.
KEY FEATURE--Total Annual Income Amount under the Highest Daily Lifetime Five Benefit
The initial Total Annual Income Amount is equal to 5% of the Total Protected Withdrawal Value. For purposes of the asset transfer
formula described below, we also calculate a Highest Daily Annual Income Amount, which is initially equal to 5% of the Protected
Withdrawal Value. Under the Highest Daily Lifetime Five benefit, if your cumulative withdrawals in an Annuity Year are less than or
equal to the Total Annual Income Amount, they will not reduce your Total Annual Income Amount in subsequent Annuity Years, but any
such withdrawals will reduce the Total Annual Income Amount on a dollar-for-dollar basis in that Annuity Year. If your cumulative
withdrawals are in excess of the Total Annual Income Amount ("Excess Income"), your Total Annual Income Amount in subsequent years
will be reduced (except with regard to required minimum distributions) by the result of the ratio of the Excess Income to the Account
Value immediately prior to such withdrawal (see examples of this calculation below). Reductions include the actual amount of the
withdrawal, including any CDSC that may apply. A Purchase Payment that you make will increase the then-existing Total Annual Income
Amount and Highest Daily Annual Income Amount by an amount equal to 5% of the Purchase Payment (including the amount of any
associated Credits).
An automatic step-up feature ("Highest Quarterly Auto Step-Up") is included as part of this benefit. As detailed in this paragraph,
the Highest Quarterly Auto Step-Up feature can result in a larger Total Annual Income Amount if your Account Value increases
subsequent to your first withdrawal. We begin examining the Account Value for purposes of this feature starting with the anniversary
of the Issue Date of the Annuity (the "Annuity Anniversary") immediately after your first withdrawal under the benefit. Specifically,
upon the first such Annuity Anniversary, we identify the Account Value on the Valuation Days corresponding to the end of each quarter
that (i) is based on your Annuity Year, rather than a calendar year; (ii) is subsequent to the first withdrawal; and (iii) falls
within the immediately preceding Annuity Year. If the end of any such quarter falls on a holiday or a weekend, we use the next
Valuation Day. We multiply each of those quarterly Account Values by 5%, adjust each such quarterly value for subsequent withdrawals
and Purchase Payments, and then select the highest of those values. If the highest of those values exceeds the existing Total Annual
Income Amount, we replace the existing amount with the new, higher amount. Otherwise, we leave the existing Total Annual Income
Amount intact. In later years, (i.e., after the first Annuity Anniversary after the first withdrawal) we determine whether an
automatic step-up should occur on each Annuity Anniversary, by performing a similar examination of the Account Values on the end of
the four immediately preceding quarters. If, on the date that we implement a Highest Quarterly Auto Step-Up to your Total Annual
Income Amount, the charge for Highest Daily Lifetime Five has changed for new purchasers, you may be subject to the new charge at the
time of such step-up. Prior to increasing your charge for Highest Daily Lifetime Five upon a step-up, we would notify you, and give
you the opportunity to cancel the automatic step-up feature. If you receive notice of a proposed step-up and accompanying fee
increase, you should carefully evaluate whether the amount of the step-up justifies the increased fee to which you will be subject.
The Highest Daily Lifetime Five program does not affect your ability to make withdrawals under your annuity, or limit your ability to
request withdrawals that exceed the Total Annual Income Amount. Under Highest Daily Lifetime Five, if your cumulative withdrawals in
an Annuity Year are less than or equal to the Total Annual Income Amount, they will not reduce your Total Annual Income Amount in
subsequent Annuity Years, but any such withdrawals will reduce the Total Annual Income Amount on a dollar-for-dollar basis in that
Annuity Year.
If, cumulatively, you withdraw an amount less than the Total Annual Income Amount in any Annuity Year, you cannot carry-over the
unused portion of the Total Annual Income Amount to subsequent Annuity Years. Examples of dollar-for-dollar and proportional
reductions, and the Highest Quarterly Auto Step-Up are set forth below. The values depicted here are purely hypothetical, and do not
reflect the charges for the Highest Daily Lifetime Five benefit or any other fees and charges. Assume the following for all three
examples:
? The Issue Date is December 1, 2006
? The Highest Daily Lifetime Five benefit is elected on March 5, 2007.
Dollar-for-dollar reductions
On May 2, 2007, the Total Protected Withdrawal Value is $120,000, resulting in a Total Annual Income Amount of $6,000 (5% of
$120,000). Assuming $2,500 is withdrawn from the Annuity on this date, the remaining Total Annual Income Amount for that Annuity Year
(up to and including December 1, 2007) is $3,500. This is the result of a dollar-for-dollar reduction of the Total
Annual Income Amount - $6,000 less $2,500 = $3,500.
Proportional reductions
Continuing the previous example, assume an additional withdrawal of $5,000 occurs on August 6, 2007 and the Account Value at the time
of this withdrawal is $110,000. The first $3,500 of this withdrawal reduces the Total Annual Income Amount for that Annuity Year to
$0. The remaining withdrawal amount - $1,500 - reduces the Total Annual Income Amount in future Annuity Years on a proportional basis
based on the ratio of the excess withdrawal to the Account Value immediately prior to the excess withdrawal. (Note that if there were
other withdrawals in that Annuity Year, each would result in another proportional reduction to the Total Annual Income Amount).
Here is the calculation:
Account Value before withdrawal $110,000.00
Less amount of "non" excess withdrawal -$3,500.00
Account Value immediately before excess withdrawal of $1,500 $106,500.00
Excess withdrawal amount $1,500.00
Divided by Account Value immediately before excess withdrawal $106,500.00
Ratio 1.41%
Total Annual Income Amount $6,000.00
Less ratio of 1.41% -$84.51
Total Annual Income Amount for future Annuity Years $5,915.49
Highest Quarterly Auto Step-Up
On each Annuity Anniversary date, the Total Annual Income Amount is stepped-up if 5% of the highest quarterly value since your first
withdrawal (or last Annuity Anniversary in subsequent years), adjusted for withdrawals and additional Purchase Payments, is higher
than the Total Annual Income Amount, adjusted for excess withdrawals and additional Purchase Payments.
Continuing the same example as above, the Total Annual Income Amount for this Annuity Year is $6,000. However, the excess withdrawal
on August 6 reduces this amount to $5,915.49 for future years (see above). For the next Annuity Year, the Total Annual Income Amount
will be stepped-up if 5% of the highest quarterly Account Value, adjusted for withdrawals, is higher than $5,915.49. Here are the
calculations for determining the quarterly values. Only the June 1 value is being adjusted for excess withdrawals as the September 1
and December 1 Valuation Days occur after the excess withdrawal on August 6.
Highest Quarterly
Value (adjusted with Adjusted Total Annual
withdrawal and Income Amount (5% of the
Date* Account value Purchase Payments)** Highest Quarterly Value)
June 1, 2007 $118,000.00 $118,000.00 $5,900.00
August 6, 2007 $120,000.00 $112,885.55 $5,644.28
September 1, 2007 $112,000.00 $112,885.55 $5,644.28
December 1, 2007 $119,000.00 $119,000.00 $5,950.00
* In this example, the Annuity Anniversary date is December 1. The quarterly valuation dates are every three months thereafter--March
1, June 1, September 1, and December 1. In this example, we do not use the March 1 date as the first withdrawal took place after
March 1. The Annuity Anniversary Date of December 1 is considered the fourth and final quarterly valuation date for the year.
** In this example, the first quarterly value after the first withdrawal is $118,000 on June 1, yielding an adjusted Total Annual
Income Amount of $5,900.00. This amount is adjusted on August 6 to reflect the $5,000 withdrawal. The calculations for the
adjustments are:
o The Account Value of $118,000 on June 1 is first reduced dollar-for-dollar by $3,500 ($3,500 is the remaining Total Annual
Income Amount for the Annuity Year), resulting in an adjusted Account Value of $114,500 before the excess withdrawal.
o This amount ($114,500) is further reduced by 1.41% (this is the ratio in the above example which is the excess withdrawal
divided by the Account Value immediately preceding the excess withdrawal) resulting in a Highest Quarterly Value of
$112,885.55.
The adjusted Total Annual Income Amount is carried forward to the next quarterly anniversary date of September 1. At this time, we
compare this amount to 5% of the Account Value on September 1. Since the June 1 adjusted Total Annual Income Amount of $5,644.28 is
higher than $5,600.00 (5% of $112,000), we continue to carry $5,644.28 forward to the next and final quarterly anniversary date of
December 1. The Account Value on December 1 is $119,000 and 5% of this amount is $5,950. Since this is higher than $5,644.28, the
adjusted Total Annual Income Amount is reset to $5,950.00.
In this example, 5% of the December 1 value yields the highest amount of $ 5,950.00. Since this amount is higher than the current
year's Total Annual Income Amount of $5,915.49 adjusted for excess withdrawals, the Total Annual Income Amount for the next Annuity
Year, starting on December 2, 2007 and continuing through December 1, 2008, will be stepped-up to $5,950.00.
BENEFITS UNDER THE HIGHEST DAILY LIFETIME FIVE PROGRAM
o To the extent that your Account Value was reduced to zero as a result of cumulative withdrawals that are equal to or less
than the Total Annual Income Amount and amounts are still payable under Highest Daily Lifetime Five, we will make an
additional payment, if any, for that Annuity Year equal to the remaining Total Annual Income Amount for the Annuity Year.
Thus, in that scenario, the remaining Total Annual Income Amount would be payable even though your Account Value was reduced
to zero. In subsequent Annuity Years we make payments that equal the Total Annual Income Amount as described in this
section. We will make payments until the death of the single designated life. To the extent that cumulative withdrawals in
the current Annuity Year that reduced your Account Value to zero are more than the Total Annual Income Amount, the Highest
Daily Lifetime Five benefit terminates, and no additional payments will be made.
o If Annuity payments are to begin under the terms of your Annuity, or if you decide to begin receiving Annuity payments and
there is a Total Annual Income Amount due in subsequent Annuity Years, you can elect one of the following two options:
(1) apply your Account Value to any Annuity option available; or
(2) request that, as of the date Annuity payments are to begin, we make Annuity payments each year equal to the Total Annual
Income Amount. We will make payments until the death of the single designated life.
We must receive your request in a form acceptable to us at our office.
In the absence of an election when mandatory annuity payments are to begin, we will make annual annuity payments in the form of a
single life fixed annuity with ten payments certain, by applying the greater of the annuity rates then currently available or the
annuity rates guaranteed in your Annuity. The amount that will be applied to provide such Annuity payments will be the greater of:
(1) the present value of the future Total Annual Income Amount payments. Such present value will be calculated using the greater of
the single life fixed annuity rates then currently available or the single life fixed annuity rates guaranteed in your Annuity; and
(2) the Account Value.
o If no withdrawal was ever taken, we will calculate the Total Annual Income Amount as if you made your first withdrawal on
the date the annuity payments are to begin.
o Please note that payments that we make under this benefit after the Annuity Anniversary coinciding with or next following
the annuitant's 95th birthday will be treated as annuity payments.
Other Important Considerations
o Withdrawals under the Highest Daily Lifetime Five benefit are subject to all of the terms and conditions of the Annuity,
including any CDSC.
o Withdrawals made while the Highest Daily Lifetime Five Benefit is in effect will be treated, for tax purposes, in the same
way as any other withdrawals under the Annuity. The Highest Daily Lifetime Five Benefit does not directly affect the Account
Value or surrender value, but any withdrawal will decrease the Account Value by the amount of the withdrawal (plus any
applicable CDSC). If you surrender your Annuity you will receive the current surrender value.
o You can make withdrawals from your Annuity while your Account Value is greater than zero without purchasing the Highest
Daily Lifetime Five benefit. The Highest Daily Lifetime Five benefit provides a guarantee that if your Account Value
declines due to market performance, you will be able to receive your Total Annual Income Amount in the form of periodic
benefit payments.
o Upon inception of the benefit, 100% of your Account Value must be allocated to the permitted sub-accounts. However, the
asset transfer component of the benefit as described below may transfer Account Value to the Benefit Fixed Rate Account as
of the effective date of the benefit in some circumstances.
o You cannot allocate Purchase Payments or transfer Account Value to a Fixed Rate Option if you elect this benefit.
o Transfers to and from the Sub-accounts and the Benefit Fixed Rate Option triggered by the asset transfer component of the
benefit will not count toward the maximum number of free transfers allowable under an Annuity.
o In general, you must allocate your Account Value in accordance with the then available investment option(s) that we may
prescribe in order to elect and maintain the Highest Daily Lifetime Five benefit. If, subsequent to your election of the
benefit, we change our requirements for how Account Value must be allocated under the benefit, the new requirement will
apply only to new elections of the benefit, and we will not compel you to re-allocate your Account Value in accordance with
our newly adopted requirements. Subsequent to any change in requirements, transfers of Account Value and allocation of
additional Purchase Payments may be subject to the new investment limitations.
Election of and Designations under the Program
For Highest Daily Lifetime Five, there must be either a single Owner who is the same as the Annuitant, or if the Annuity is entity
owned, there must be a single natural person Annuitant. In either case, the Annuitant must be at least 55 years old.
Any change of the Annuitant under the Annuity will result in cancellation of Highest Daily Lifetime Five. Similarly, any change of
Owner will result in cancellation of Highest Daily Lifetime Five, except if (a) the new Owner has the same taxpayer identification
number as the previous owner (b) both the new Owner and previous Owner are entities or (c) the previous Owner is a natural person and
the new Owner is an entity.
Highest Daily Lifetime Five can be elected at the time that you purchase your Annuity or after the Issue Date, subject to our
eligibility rules and restrictions.
Currently, if you terminate the Highest Daily Lifetime Five benefit, you will (a) not be permitted to re-elect the benefit and (b)
will be allowed to elect the Spousal Lifetime Five Benefit or the Lifetime Five Income Benefit on any anniversary of the Issue Date
that is at least 90 calendar days from the date the Highest Daily Lifetime Five Benefit was terminated. We reserve the right to
further limit the election frequency in the future. Before making any such change to the election frequency, we will provide prior
notice to Owners who have an effective Highest Daily Lifetime Five Benefit.
Termination of the Program
You may terminate the benefit at any time by notifying us. If you terminate the benefit, any guarantee provided by the benefit will
terminate as of the date the termination is effective, and certain restrictions on re-election will apply as described above. The
benefit terminates: (i) upon your termination of the benefit (ii) upon your surrender of the Annuity (iii) upon your election to
begin receiving annuity payments (iv) upon the death of the Annuitant (v) if both the Account Value and Total Annual Income Amount
equal zero or (vi) if you fail to meet our requirements for issuing the benefit.
Upon termination of Highest Daily Lifetime Five, we cease deducting the charge for the benefit. With regard to your investment
allocations, upon termination we will: (i) leave intact amounts that are held in the variable investment options, and (ii) transfer
all amounts held in the Benefit Fixed Rate Account (as defined below) to your variable investment options, based on your existing
allocation instructions or (in the absence of such existing instructions) pro rata (i.e. in the same proportion as the current
balances in your variable investment options). Upon termination, we may limit or prohibit investment in the Fixed Rate Options.
Return of Principal Guarantee
If you have not made a withdrawal before the Tenth Anniversary, we will increase your Account Value on that Tenth Anniversary (or the
next Valuation Day, if that anniversary is not a Valuation Day), if the requirements set forth in this paragraph are met. On the
Tenth Anniversary, we add:
(a) your Account Value on the day that you elected Highest Daily Lifetime Five; and
(b) the sum of each Purchase Payment you made (including any Credits with respect to the X series) during the one-year period
after you elected the benefit.
If the sum of (a) and (b) is greater than your Account Value on the Tenth Anniversary, we increase your Account Value to equal the
sum of (a) and (b), by contributing funds from our general account. If the sum of (a) and (b) is less than or equal to your Account
Value on the Tenth Anniversary, we make no such adjustment. The amount that we add to your Account Value under this provision will be
allocated to each of your variable investment options and the Benefit Fixed Rate Account (described below), in the same proportion
that each such investment option bears to your total Account Value, immediately prior to the application of the amount. Any such
amount will not be considered a Purchase Payment when calculating your Total Protected Withdrawal Value, your death benefit, or the
amount of any other or optional benefit that you may have selected, and therefore will have no direct impact on such values at the
time we add this amount. This potential addition to Account Value is available only if you have elected Highest Daily Lifetime Five
and if you meet the conditions set forth in this paragraph. Thus, if you take a withdrawal prior to the Tenth Anniversary, you are
not eligible to receive the Return of Principal Guarantee.
Asset Transfer Component of Highest Daily Lifetime Five
As indicated above, we limit the Sub-accounts to which you may allocate Account Value if you elect Highest Daily Lifetime Five. For
purposes of this benefit, we refer to those permitted Sub-accounts as the "Permitted Sub-accounts". The permitted sub-accounts are
identified in the Annuity application. As a requirement of participating in Highest Daily Lifetime Five, we require that you
participate in our specialized asset transfer program, under which we may transfer Account Value between the Permitted Sub-accounts
and a fixed interest rate account that is part of our general account (the "Benefit Fixed Rate Account"). We determine whether to
make a transfer, and the amount of any transfer, under a non-discretionary formula, discussed below. The Benefit Fixed Rate Account
is available only with this benefit, and thus you may not allocate Purchase Payments to the Benefit Fixed Rate Account. The interest
rate that we pay with respect to the Benefit Fixed Rate Account is reduced by an amount that corresponds generally to the charge that
we assess against your variable Sub-accounts for Highest Daily Lifetime Five. The Benefit Fixed Rate Account is not subject to the
Investment Company Act of 1940 or the Securities Act of 1933.
Under the asset transfer component of Highest Daily Lifetime Five, we monitor your Account Value daily and, if necessary,
systematically transfer amounts between the Permitted Sub-accounts you have chosen and the Benefit Fixed Rate Account. Any transfer
would be made in accordance with a formula, which is set forth in the schedule supplement to the endorsement for this benefit (and
also appears in the Appendices to this prospectus). Speaking generally, the formula, which we apply each Valuation Day, operates as
follows. The formula starts by identifying your Protected Withdrawal Value for that day and then multiplies that figure by 5%, to
produce a projected (i.e., hypothetical) Highest Daily Annual Income Amount. Then, using our actuarial tables, we produce an estimate
of the total amount we would target in our allocation model, based on the projected Highest Daily Annual Income Amount each year for
the rest of your life. In the formula, we refer to that value as the "Target Value" or "L". If you have already made a withdrawal,
your projected Highest Daily Annual Income Amount (and thus your Target Value) would take into account any automatic step-up that was
scheduled to occur according to the step-up formula described above. Next, the formula subtracts from the Target Value the amount
held within the Benefit Fixed Rate Account on that day, and divides that difference by the amount held within the Permitted
Sub-accounts. That ratio, which essentially isolates the amount of your Target Value that is not offset by amounts held within the
Benefit Fixed Rate Account, is called the "Target Ratio" or "r". If the Target Ratio exceeds a certain percentage (currently 83%), it
means essentially that too much Target Value is not offset by assets within the Benefit Fixed Rate Account, and therefore we will
transfer an amount from your Permitted Sub-accounts to the Benefit Fixed Rate Account. Conversely, if the Target Ratio falls below a
certain percentage (currently 77%), then a transfer from the Benefit Fixed Rate Account to the Permitted Sub-accounts would occur.
Note that the formula is calculated with reference to the Highest Daily Annual Income Amount, rather than with reference to the Total
Annual Income Amount.
As you can glean from the formula, a downturn in the securities markets (i.e., a reduction in the amount held within the Permitted
Sub-accounts) may cause us to transfer some of your variable Account Value to the Benefit Fixed Rate Account, because such a
reduction will tend to increase the Target Ratio. Moreover, certain market return scenarios involving "flat" returns over a period of
time also could result in the transfer of money to the Benefit Fixed Rate Account. In deciding how much to transfer, we use another
formula, which essentially seeks to re-balance amounts held in the Permitted Sub-accounts and the Benefit Fixed Rate Account so that
the Target Ratio meets a specified target, which currently is equal to 80%. Once you elect Highest Daily Lifetime Five, the ratios we
use will be fixed. For newly issued Annuities that elect Highest Daily Lifetime Five and existing Annuities that elect Highest Daily
Lifetime Five, however, we reserve the right to change the ratios.
While you are not notified when your Annuity reaches a reallocation trigger, you will receive a confirmation statement indicating the
transfer of a portion of your Account Value either to or from the Benefit Fixed Rate Account. The formula by which the reallocation
triggers operate is designed primarily to mitigate the financial risks that we incur in providing the guarantee under Highest Daily
Lifetime Five.
Depending on the results of the calculation relative to the reallocation triggers, we may, on any day:
o Not make any transfer; or
o If a portion of your Account Value was previously allocated to the Benefit Fixed Rate Account, transfer all or a portion of
those amounts to the Permitted Sub-accounts, based on your existing allocation instructions or (in the absence of such
existing instructions) pro rata (i.e., in the same proportion as the current balances in your variable investment options).
Amounts taken out of the Benefit Fixed Rate Account will be withdrawn for this purpose on a last-in, first-out basis (an
amount renewed into a new guarantee period under the Benefit Fixed Rate Account will be deemed a new investment for purposes
of this last-in, first-out rule); or
o Transfer all or a portion of your Account Value in the Permitted Sub-accounts pro-rata to the Benefit Fixed Rate Account.
The interest that you earn on such transferred amount will be equal to the annual rate that we have set for that day, and we
will credit the daily equivalent of that annual interest until the earlier of one year from the date of the transfer or the
date that such amount in the Benefit Fixed Rate Account is transferred back to the Permitted Sub-accounts.
If a significant amount of your Account Value is systematically transferred to the Benefit Fixed Rate Account during periods of
market declines or low interest rates, less of your Account Value may be available to participate in the investment experience of the
Permitted Sub-accounts if there is a subsequent market recovery. Under the reallocation formula that we employ, it is possible that a
significant portion of your Account Value may be allocated to the Benefit Fixed Rate Account. Note that if your entire Account Value
is transferred to the Benefit Fixed Rate Account, then based on the way the formula operates, that value would remain in the Benefit
Fixed Rate Account unless you made additional Purchase Payments to the Permitted Sub-Accounts, which could cause Account Value to
transfer out of the Benefit Fixed Rate Account.
Additional Tax Considerations
If you purchase an annuity as an investment vehicle for "qualified" investments, including an IRA, SEP-IRA, Tax Sheltered Annuity (or
403(b)) or employer plan under Code Section 401(a), the Required Minimum Distribution rules under the Code provide that you begin
receiving periodic amounts from your annuity beginning after age 70 1/2. For a Tax Sheltered Annuity or a 401(a) plan for which the
participant is not a greater than five (5) percent owner of the employer, this required beginning date can generally be deferred to
retirement, if later. Roth IRAs are not subject to these rules during the owner's lifetime. The amount required under the Code may
exceed the Total Annual Income Amount, which will cause us to increase the Total Annual Income Amount in any Annuity Year that
Required Minimum Distributions due from your Annuity that are greater than such amounts. In addition, the amount and duration of
payments under the annuity payment and death benefit provisions may be adjusted so that the payments do not trigger any penalty or
excise taxes due to tax considerations such as Required Minimum Distribution provisions under the tax law. Please note, however, that
any withdrawal you take prior to the Tenth Anniversary, even if withdrawn to satisfy required minimum distribution rules, will cause
you to lose the ability to receive Enhanced Protected Withdrawal Value and an amount under the Return of Principal Guarantee.
As indicated, withdrawals made while this Benefit is in effect will be treated, for tax purposes, in the same way as any other
withdrawals under the Annuity. Please see the Tax Considerations section of the prospectus for a detailed discussion of the tax
treatment of withdrawals. We do not address each potential tax scenario that could arise with respect to this Benefit here. However,
we do note that if you participate in Highest Daily Lifetime Five through a non-qualified annuity, and your annuity has received
Enhanced Protected Withdrawal Value and/or an additional amount under the Return of Principal Guarantee, as with all withdrawals,
once all Purchase Payments are returned under the Annuity, all subsequent withdrawal amounts will be taxed as ordinary income.
V. We add the following as Appendix C:
Appendix C
Asset Transfer Formula Under Highest Daily Lifetime Five Benefit
We set out below the current formula under which we may transfer amounts between the variable investment options and the Benefit
Fixed Rate Account. Upon your election of Highest Daily Lifetime Five, we will not alter the asset transfer formula that applies to
your contract. However, we reserve the right to modify this formula with respect to those who elect Highest Daily Lifetime Five in
the future.
Terms and Definitions referenced in the calculation formula:
o Cu - the upper target is established on the effective date of the Highest Daily Lifetime Five benefit (the "Effective Date")
and is not changed for the life of the guarantee. Currently, it is 83%.
o Ct - the target is established on the Effective Date and is not changed for the life of the guarantee. Currently, it is 80%.
o Cl - the lower target is established on the Effective Date and is not changed for the life of the guarantee. Currently, it
is 77%.
o L - the target value as of the current business day.
o r - the target ratio.
o a - the factors used in calculating the target value. These factors are established on the Effective Date and are not
changed for the life of the guarantee. The factors that we use currently are derived from the a2000 Individual Annuity
Mortality Table with an assumed interest rate of 3%. Each number in the table "a" factors (which appears below) represents a
factor, which when multiplied by the Highest Daily Annual Income Amount, projects our total liability for the purpose of asset
transfers under the guarantee.
o Q - age based factors used in calculating the target value. These factors are established on the Effective Date and are not
changed for the life of the guarantee The factor is currently set equal to 1.
o V - the total value of all Permitted Sub-accounts in the annuity.
o F - the total value of all Benefit Fixed Rate Account allocations.
o I - the income value prior to the first withdrawal. The income value is equal to what the Highest Daily Annual Income
Amount would be if the first withdrawal were taken on the date of calculation. After the first withdrawal the income value
equals the greater of the Highest Daily Annual Income Amount, the quarterly step-up amount times the annual income percentage,
and the Account Value times the annual income percentage.
o T - the amount of a transfer into or out of the Benefit Fixed Rate Account.
o I% - annual income amount percentage. This factor is established on the Effective Date and is not changed for the life of
the guarantee. Currently, this percentage is equal to 5%.
Target Value Calculation:
On each Valuation Day, a target value (L) is calculated, according to the following formula. If the variable Account Value (V) is
equal to zero, no calculation is necessary.
L = I * Q * a
Transfer Calculation:
The following formula, which is set on the Effective Date and is not changed for the life of the guarantee, determines when a
transfer is required:
Target Ratio r = (L - F) / V.
o If r > Cu, assets in the Permitted Sub-accounts are transferred to Benefit Fixed Rate Account.
o If r < Cl, and there are currently assets in the Benefit Fixed Rate Account (F > 0), assets in the Benefit Fixed Rate
Account are transferred to the Permitted Sub-accounts.
The following formula, which is set on the Effective Date and is not changed for the life of the guarantee, determines the transfer
amount:
T ={Min(V, [L - F - V * Ct] / (1-Ct))} T>0, Money moving from the Permitted Sub-accounts to the Benefit
Fixed Rate Account
T ={Min(F, [L - F - V * Ct] / (1-Ct))} T<0, Money moving from the Benefit Fixed Rate Account to the
Permitted Sub-accounts]
Example:
Male age 65 contributes $100,000 into the Permitted Sub accounts and the value drops to $92,300 during year one, end of day one. A
table of values for "a" appears below.
Target Value Calculation:
L = I * Q * a
= 5000.67 * 1 * 15.34
= 76,710.28
Target Ratio:
r = (L - F) / V
= (76,710.28 - 0) / 92,300.00
= 83.11%
Since r > Cu ( because 83.11% > 83%) a transfer into the Benefit Fixed rate Account occurs.
T = { Min ( V, [ L - F - V * Ct] / ( 1 - Ct))}
= { Min ( 92,300.00, [ 76,710.28 - 0 - 92,300.00 * 0.80] / ( 1 - 0.80))}
= { Min ( 92,300.00, 14,351.40 )}
= 14,351.40
Age 65 "a" Factors for Liability Calculations
(in Years and Months since Benefit Effective Date)*
Months
Years 1 2 3 4 5 6 7 8 9 10 11 12
1 15.34 15.31 15.27 15.23 15.20 15.16 15.13 15.09 15.05 15.02 14.98 14.95
2 14.91 14.87 14.84 14.80 14.76 14.73 14.69 14.66 14.62 14.58 14.55 14.51
3 14.47 14.44 14.40 14.36 14.33 14.29 14.26 14.22 14.18 14.15 14.11 14.07
4 14.04 14.00 13.96 13.93 13.89 13.85 13.82 13.78 13.74 13.71 13.67 13.63
5 13.60 13.56 13.52 13.48 13.45 13.41 13.37 13.34 13.30 13.26 13.23 13.19
6 13.15 13.12 13.08 13.04 13.00 12.97 12.93 12.89 12.86 12.82 12.78 12.75
7 12.71 12.67 12.63 12.60 12.56 12.52 12.49 12.45 12.41 12.38 12.34 12.30
8 12.26 12.23 12.19 12.15 12.12 12.08 12.04 12.01 11.97 11.93 11.90 11.86
9 11.82 11.78 11.75 11.71 11.67 11.64 11.60 11.56 11.53 11.49 11.45 11.42
10 11.38 11.34 11.31 11.27 11.23 11.20 11.16 11.12 11.09 11.05 11.01 10.98
11 10.94 10.90 10.87 10.83 10.79 10.76 10.72 10.69 10.65 10.61 10.58 10.54
12 10.50 10.47 10.43 10.40 10.36 10.32 10.29 10.25 10.21 10.18 10.14 10.11
13 10.07 10.04 10.00 9.96 9.93 9.89 9.86 9.82 9.79 9.75 9.71 9.68
14 9.64 9.61 9.57 9.54 9.50 9.47 9.43 9.40 9.36 9.33 9.29 9.26
15 9.22 9.19 9.15 9.12 9.08 9.05 9.02 8.98 8.95 8.91 8.88 8.84
16 8.81 8.77 8.74 8.71 8.67 8.64 8.60 8.57 8.54 8.50 8.47 8.44
17 8.40 8.37 8.34 8.30 8.27 8.24 8.20 8.17 8.14 8.10 8.07 8.04
18 8.00 7.97 7.94 7.91 7.88 7.84 7.81 7.78 7.75 7.71 7.68 7.65
19 7.62 7.59 7.55 7.52 7.49 7.46 7.43 7.40 7.37 7.33 7.30 7.27
20 7.24 7.21 7.18 7.15 7.12 7.09 7.06 7.03 7.00 6.97 6.94 6.91
21 6.88 6.85 6.82 6.79 6.76 6.73 6.70 6.67 6.64 6.61 6.58 6.55
22 6.52 6.50 6.47 6.44 6.41 6.38 6.36 6.33 6.30 6.27 6.24 6.22
23 6.19 6.16 6.13 6.11 6.08 6.05 6.03 6.00 5.97 5.94 5.92 5.89
24 5.86 5.84 5.81 5.79 5.76 5.74 5.71 5.69 5.66 5.63 5.61 5.58
25 5.56 5.53 5.51 5.48 5.46 5.44 5.41 5.39 5.36 5.34 5.32 5.29
26 5.27 5.24 5.22 5.20 5.18 5.15 5.13 5.11 5.08 5.06 5.04 5.01
27 4.99 4.97 4.95 4.93 4.91 4.88 4.86 4.84 4.82 4.80 4.78 4.75
28 4.73 4.71 4.69 4.67 4.65 4.63 4.61 4.59 4.57 4.55 4.53 4.51
29 4.49 4.47 4.45 4.43 4.41 4.39 4.37 4.35 4.33 4.32 4.30 4.28
30 4.26 4.24 4.22 4.20 4.18 4.17 4.15 4.13 4.11 4.09 4.07 4.06
31 4.04 4.02 4.00 3.98 3.97 3.95 3.93 3.91 3.90 3.88 3.86 3.84
32 3.83 3.81 3.79 3.78 3.76 3.74 3.72 3.71 3.69 3.67 3.66 3.64
33 3.62 3.61 3.59 3.57 3.55 3.54 3.52 3.50 3.49 3.47 3.45 3.44
34 3.42 3.40 3.39 3.37 3.35 3.34 3.32 3.30 3.29 3.27 3.25 3.24
35 3.22 3.20 3.18 3.17 3.15 3.13 3.12 3.10 3.08 3.07 3.05 3.03
36 3.02 3.00 2.98 2.96 2.95 2.93 2.91 2.90 2.88 2.86 2.85 2.83
37 2.81 2.79 2.78 2.76 2.74 2.73 2.71 2.69 2.68 2.66 2.64 2.62
38 2.61 2.59 2.57 2.56 2.54 2.52 2.51 2.49 2.47 2.45 2.44 2.42
39 2.40 2.39 2.37 2.35 2.34 2.32 2.30 2.29 2.27 2.25 2.24 2.22
40 2.20 2.19 2.17 2.15 2.14 2.12 2.11 2.09 2.07 2.06 2.04 2.02
41 2.01 1.84 1.67 1.51 1.34 1.17 1.00 0.84 0.67 0.50 0.33 0.17
* The values set forth in this table are applied to all ages.
VI. NEW SUB-ACCOUNT
Effective November 19, 2007, the underlying portfolio listed below is being offered as a new Sub-account under your annuity. In
order to reflect this addition:
In the section of each Prospectus entitled "Summary of Contract Expenses", sub-section "Underlying Mutual Fund Portfolio Annual
Expenses", under the heading "Advanced Series Trust", the following portfolio has been added:
--------------------------------------------------------------------------------------------------------------------------------------
UNDERLYING MUTUAL FUND PORTFOLIO ANNUAL EXPENSES
(as a percentage of the average net assets of the underlying Portfolios)
--------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
Acquired Total Annual
Management Other Portfolio
UNDERLYING PORTFOLIO Fees Expenses 12b-1 Fees & Portfolio Operating
Advanced Series Trust: Fees Expenses
Expenses
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
AST Western Asset Core Plus Bond 0.70% 0.12% 0.00% 0.00% 0.82%
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
The following is being added to the chart in each Prospectus in the section entitled "Investment Options":
----------------------- ----------------------------------------------------------------------------------- -------------------------
STYLE/ INVESTMENT OBJECTIVES/POLICIES PORTFOLIO
TYPE ADVISOR/
SUB-ADVISOR
----------------------------------------------------------------------------------- -------------------------
-------------------------------------------------------------------------------------------------------------------------------------
AST FUNDS
-------------------------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------------------------------
Fixed Income AST Western Asset Core Plus Bond Portfolio: seeks to maximize total return, Western Asset Management
consistent with prudent investment management and liquidity needs, by investing to Company
obtain its average specified duration. The Portfolio's current target average
duration is generally 2.5 to 7 years. The Portfolio pursues this objective by
investing in all major fixed income sectors with a bias towards non-Treasuries.
-------------------------------------------------------------------------------------------------------------------------------------
VII. CHANGE TO ANNUITY DATE PROVISION
In the "ACCESS TO ACCOUNT VALUE" section of each prospectus, under the heading entitled "What types of Annuity Options are Available"
we revise the first sentence of the second paragraph to read "You may choose an Annuity Date, an annuity option and the frequency of
annuity payments." We also revise the fourth sentence to read "Your Annuity Date must be no later than the first day of the month
next following the Annuitant's 95th birthday (unless we agree to another date)."
VIII. NEW PRINCIPAL UNDERWRITER
In the General Information section of the prospectus, under the heading entitled "Who Distributes Annuities . . .", we identify
Prudential Investment Management Services LLC (PIMS) as the principal underwriter and distributor of the Annuities. Effective on
November 19, 2007, PIMS has been replaced by Prudential Annuities Distributors, Inc. ("PAD"). Accordingly, we replace the first four
sentences under "Who Distributes Annuities Offered By. . " with the following, and in the remainder of that section, replace
references to PIMS with PAD:
"Prudential Annuities Distributors, Inc. (PAD) (formerly, American Skandia Marketing, Incorporated), a wholly-owned subsidiary of
Prudential Annuities, Inc., is the distributor and principal underwriter of the Annuities offered through this prospectus. PAD acts
as the distributor of a number of annuity and life insurance products, and is the co-distributor of the Advanced Series Trust. PAD's
principal business address is One Corporate Drive, Shelton, Connecticut 06484. PAD is registered as a broker-dealer under the
Securities Exchange Act of 1934 (Exchange Act), and is a member of the National Association of Securities Dealers, Inc. (NASD)."
Pruco Life Insurance Company Of New Jersey
Strategic Partners Annuity One 3
Strategic Partners Plus 3
Supplement, dated November 19, 2007
To
Prospectuses, dated May 1, 2007
This Supplement should be read and retained with the current Prospectus for your annuity. This Supplement is intended to update
certain information in the Prospectus for the variable annuity you own, and is not intended to be a prospectus or offer for any
other variable annuity listed here that you do not own. If you would like another copy of the current Prospectus, please contact
us at 1-888-PRU-2888.
We are issuing this supplement to announce the addition of a new living benefit called the Highest Daily Lifetime Five Income
Benefit, a sub-advisor change, a new fund option and identify a new principal underwriter.
I. TABLE OF CONTENTS
In the Table of Contents, immediately after the entry for Spousal Lifetime Five Income Benefit (Spousal Lifetime Five), we
add a new line item entitled "Highest Daily Lifetime Five Income Benefit (Highest Daily Lifetime Five)."
II. GLOSSARY OF TERMS
In the Glossary of Terms of each prospectus, we add the following new definitions:
Benefit Fixed Rate Account: An investment option offered as part of this Annuity that is used only if you have elected the Highest
Daily Lifetime Five Income Benefit. Amounts allocated to the Benefit Fixed Rate Account earn a fixed rate of interest, and are held
within our general account. You may not allocate purchase payments to the Benefit Fixed Rate Account. Rather, Contract Value is
transferred to the Benefit Fixed Rate Account only under the asset transfer feature of this benefit.
Highest Daily Lifetime Five Benefit: An optional feature for an additional charge that guarantees your ability to withdraw amounts
equal to a percentage of a principal value called the Total Protected Withdrawal Value. Subject to our rules regarding the timing
and amount of withdrawals, we guarantee these withdrawal amounts, regardless of the impact of market performance on your Contract
Value.
We revise the following Glossary definitions:
Annual Income Amount
Under the terms of the Lifetime Five Income Benefit, an amount that you can withdraw each year as long as the annuitant lives. For
the Highest Daily Lifetime Five Benefit only, we refer to an amount that you can withdraw each year as long as the annuitant lives as
the "Total Annual Income Amount." The Total Annual Income Amount may reflect the inclusion of an additional sum, if you have made no
withdrawal during the first ten years that the Highest Daily Lifetime Five Benefit is in effect. The annual income amount is set
initially as a percentage of the Protected Withdrawal Value, but will be adjusted to reflect subsequent purchase payments,
withdrawals, and any step-up. Under the Spousal Lifetime Five Income Benefit, the annual income amount is paid until the later death
of two natural persons who are each other's spouses at the time of election and at the first death of one of them.
Protected Withdrawal Value
Under the Lifetime Five Income Benefit and Spousal Lifetime Five Income Benefit, an amount that we guarantee regardless of the
investment performance of your Contract Value. For the Highest Daily Lifetime Five Benefit only, we refer to an amount that we
guarantee regardless of the investment performance of your Contract Value as the "Total Protected Withdrawal Value". Total Protected
Withdrawal Value may reflect the inclusion of an additional sum, if you have made no withdrawal during the first ten years that the
Highest Daily Lifetime Five Benefit is in effect
III. NEW SUB-ACCOUNT
Effective November 19, 2007, the underlying portfolio listed below is being offered as a new Sub-account under your annuity. In
order to reflect this addition:
In the section of each Prospectus entitled "Summary of Contract Expenses", sub-section "Underlying Mutual Fund Portfolio Annual
Expenses", under the heading "Advanced Series Trust", the following portfolio has been added:
--------------------------------------------------------------------------------------------------------------------------------------
UNDERLYING MUTUAL FUND PORTFOLIO ANNUAL EXPENSES
(as a percentage of the average net assets of the underlying Portfolios)
--------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
Acquired Total Annual
Management Other 12b-1 Fees Portfolio Fees & Portfolio Operating
UNDERLYING PORTFOLIO Fees Expenses Expenses Expenses
Advanced Series Trust:
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
AST Western Asset Core Plus Bond 0.70% 0.12% 0.00% 0.00% 0.82%
------------------------------------------ ---------------- ------------- ------------ ------------------- ---------------------------
Effective November 19, 2007, the underlying portfolio listed below is being offered as a new Sub-account under your annuity. In
order to reflect this addition, the following is being added to the chart in each Prospectus in the section entitled "What Investment
Options Can I Choose? /Variable Investment Options":
-------------------- ------------------------------------------------------------------------------------------------ ----------------------
STYLE/ INVESTMENT OBJECTIVES/POLICIES PORTFOLIO
TYPE ADVISOR/
SUB-ADVISOR
------------------------------------------------------------------------------------------------ ----------------------
--------------------------------------------------------------------------------------------------------------------------------------------
AST FUNDS
--------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------
Fixed Income AST Western Asset Core Plus Bond Portfolio: seeks to maximize total return, consistent with Western Asset
prudent investment management and liquidity needs, by investing to obtain its average specified Management
duration. The Portfolio's current target average duration is generally 2.5 to 7 years. The Company/Western Asset
Portfolio pursues this objective by investing in all major fixed income sectors with a bias Management Company
towards non-Treasuries. Limited
--------------------------------------------------------------------------------------------------------------------------------------------
Also, in the same section of each prospectus, we make the following change to the chart setting forth a brief description of the
variable investment options, to reflect a sub-adviser change:
o Effective November 19, 2007, Neuberger Berman Management Inc. will become sub-advisor of the SP Mid-Cap Growth Portfolio.
Prior to November 19, 2007, Calamos Advisors LLC was the sub-advisor.
We add a parenthetical after the name of the SP Mid Cap Growth Portfolio as follows, to indicate that we no longer permit purchases
or transfers into the Portfolio by those who are not already invested in the Portfolio:
SP Mid Cap Growth Portfolio (closed to new investments):
IV. SUMMARY OF CONTRACT EXPENSES
o In the "Summary of Expenses" section, under "Insurance and Administrative Expenses", we add the following immediately after
the entry for Lifetime Five Income Benefit.
-----------------------------------------------------------------------------------------------------------------------------------------
INSURANCE AND ADMINISTRATIVE EXPENSES WITH THE INDICATED BENEFITS
(as a percentage of the average Contract Value in variable investment options)
-----------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------- -------------------------------------------- --------------------------------------------
Contract with Credit Contract without Credit
----------------------------------------------- -------------------------------------------- --------------------------------------------
----------------------------------------------- -------------------------------------------- --------------------------------------------
Maximum charge for Highest Daily Lifetime 1.50% 1.50%
Five Income Benefit *
----------------------------------------------- -------------------------------------------- --------------------------------------------
----------------------------------------------- -------------------------------------------- --------------------------------------------
Highest Daily Lifetime Five Income Benefit 0.60% 0.60%
(current charge)
----------------------------------------------- -------------------------------------------- --------------------------------------------
*We reserve the right to increase the charge up to the maximum indicated upon a step-up or for a new election. However, we have no
present intention of doing so.
V. HIGHEST DAILY LIFETIME FIVE INCOME BENEFIT (Highest Daily Lifetime Five)
Highest Daily Lifetime Five is offered as an alternative to Lifetime Five and Spousal Lifetime Five. Currently, if you elect Highest
Daily Lifetime Five and subsequently terminate the benefit, you will not be able to re-elect Highest Daily Lifetime Five, and will
have a waiting period until you can elect Spousal Lifetime Five or Lifetime Five. Specifically, you will be permitted to elect
Lifetime Five or Spousal Lifetime Five only on an anniversary of the contract date that is at least 90 calendar days from the date
that Highest Daily Lifetime Five was terminated. We reserve the right to further limit the election frequency in the future. The
income benefit under Highest Daily Lifetime Five currently is based on a single "designated life" who is at least 55 years old on the
date that the benefit is acquired. The Highest Daily Lifetime Five Benefit is not available if you elect any other optional living
benefit, although you may elect any optional death benefit (other than the Highest Daily Value Death Benefit). As long as your
Highest Daily Lifetime Five Benefit is in effect, you must allocate your Contract Value in accordance with the then-permitted and
available investment option(s) with this program.
We offer a benefit that guarantees until the death of the single designated life the ability to withdraw an annual amount (the "Total
Annual Income Amount") equal to a percentage of an initial principal value (the "Total Protected Withdrawal Value") regardless of the
impact of market performance on the Contract Value, subject to our program rules regarding the timing and amount of withdrawals. The
benefit may be appropriate if you intend to make periodic withdrawals from your Contract, and wish to ensure that market performance
will not affect your ability to receive annual payments. You are not required to make withdrawals as part of the program - the
guarantees are not lost if you withdraw less than the maximum allowable amount each year under the rules of the benefit. We discuss
Highest Daily Lifetime Five in greater detail immediately below. In addition, please see the Glossary section of this prospectus for
definitions of some of the key terms used with this benefit. As discussed below, we require that you participate in our asset
transfer program in order to participate in Highest Daily Lifetime Five, and in the Appendices to this prospectus, we set forth the
formula under which we make those asset transfers.
As discussed below, a key component of Highest Daily Lifetime Five is the Total Protected Withdrawal Value, which is an amount that
is distinct from Contract Value. Because each of the Total Protected Withdrawal Value and Total Annual Income Amount is determined in
a way that is not solely related to Contract Value, it is possible for the Contract Value to fall to zero, even though the Total
Annual Income Amount remains. You are guaranteed to be able to withdraw the Total Annual Income Amount for the rest of your life,
provided that you have not made "excess withdrawals." Excess withdrawals, as discussed below, will reduce your Total Annual Income
Amount. Thus, you could experience a scenario in which your Contract Value was zero, and, due to your excess withdrawals, your Total
Annual Income Amount also was reduced to zero. In that scenario, no further amount would be payable under Highest Daily Lifetime Five.
KEY FEATURE - Total Protected Withdrawal Value
The Total Protected Withdrawal Value is used to determine the amount of the annual payments under Highest Daily Lifetime Five. The
Total Protected Withdrawal Value is equal to the greater of the Protected Withdrawal Value and any Enhanced Protected Withdrawal
Value that may exist. We describe how we determine Enhanced Protected Withdrawal Value, and when we begin to calculate it, below. If
you do not meet the conditions described below for obtaining Enhanced Protected Withdrawal Value, then Total Protected Withdrawal
Value is simply equal to Protected Withdrawal Value.
The Protected Withdrawal Value initially is equal to the Contract Value on the date that you elect Highest Daily Lifetime Five. On
each business day thereafter, until the earlier of the first withdrawal or ten years after the date of your election of the benefit,
we recalculate the Protected Withdrawal Value. Specifically, on each such business day (the "Current Business Day"), the Protected
Withdrawal Value is equal to the greater of:
o the Protected Withdrawal Value for the immediately preceding business day (the "Prior Business Day "), appreciated at the
daily equivalent of 5% annually during the calendar day(s) between the Prior Business Day and the Current Business Day
(i.e., one day for successive business days , but more than one calendar day for business days that are separated by
weekends and/or holidays), plus the amount of any Purchase Payment (including any associated Credit) made on the Current
Business Day; and
o the Contract Value.
If you have not made a withdrawal prior to the tenth anniversary of the date you elected Highest Daily Lifetime Five (which we refer
to as the "Tenth Anniversary"), we will continue to calculate a Protected Withdrawal Value. On or after the Tenth Anniversary and up
until the date of the first withdrawal, your Protected Withdrawal Value is equal to the greater of the Protected Withdrawal Value on
the Tenth Anniversary or your Contract Value.
The Enhanced Protected Withdrawal Value is only calculated if you do not take a withdrawal prior to the Tenth Anniversary. Thus, if
you do take a withdrawal prior to the Tenth Anniversary, you are not eligible to receive Enhanced Protected Withdrawal Value. If no
such withdrawal is taken, then on or after the Tenth Anniversary up until the date of the first withdrawal, the Enhanced Protected
Withdrawal Value is equal to the sum of:
(a) 200% of the Contract Value on the date you elected Highest Daily Lifetime Five;
(b) 200% of all Purchase Payments (and any associated Credits) made during the one-year period after the date you elected
Highest Daily Lifetime Five; and
(c) 100% of all Purchase Payments (and any associated Credits) made more than one year after the date you elected Highest
Daily Lifetime Five, but prior to the date of your first withdrawal.
We cease these daily calculations of the Protected Withdrawal Value and Enhanced Protected Withdrawal Value (and therefore, the Total
Protected Withdrawal Value) when you make your first withdrawal. However, as discussed below, subsequent Purchase Payments (and any
associated Credits) will increase the Total Annual Income Amount, while "excess" withdrawals (as described below) may decrease the
Total Annual Income Amount.
KEY FEATURE - Total Annual Income Amount under the Highest Daily Lifetime Five Benefit
The initial Total Annual Income Amount is equal to 5% of the Total Protected Withdrawal Value. For purposes of the asset transfer
formula described below, we also calculate a Highest Daily Annual Income Amount, which is initially equal to 5% of the Protected
Withdrawal Value. Under the Highest Daily Lifetime Five Benefit, if your cumulative withdrawals in a Contract Year are less than or
equal to the Total Annual Income Amount, they will not reduce your Total Annual Income Amount in subsequent Contract Years, but any
such withdrawals will reduce the Total Annual Income Amount on a dollar-for-dollar basis in that Contract Year. If your cumulative
withdrawals are in excess of the Total Annual Income Amount ("Excess Income"), your Total Annual Income Amount in subsequent years
will be reduced (except with regard to required minimum distributions) by the result of the ratio of the Excess Income to the
Contract Value immediately prior to such withdrawal (see examples of this calculation below). Reductions include the actual amount of
the withdrawal, including any withdrawal charge that may apply. A Purchase Payment that you make will increase the then-existing
Total Annual Income Amount and Highest Daily Annual Income Amount by an amount equal to 5% of the Purchase Payment (including the
amount of any associated Credits).
An automatic step-up feature ("Highest Quarterly Auto Step-Up") is included as part of this benefit. As detailed in this paragraph,
the Highest Quarterly Auto Step-Up feature can result in a larger Total Annual Income Amount if your Contract Value increases
subsequent to your first withdrawal. We begin examining the Contract Value for purposes of this feature starting with the anniversary
of the Contract Date (the "Contract Anniversary") immediately after your first withdrawal under the benefit. Specifically, upon the
first such Contract Anniversary, we identify the Contract Value on the business days corresponding to the end of each quarter that
(i) is based on your Contract Year, rather than a calendar year; (ii) is subsequent to the first withdrawal; and (iii) falls within
the immediately preceding Contract Year. If the end of any such quarter falls on a holiday or a weekend, we use the next business
day. We multiply each of those quarterly Contract Values by 5%, adjust each such quarterly value for subsequent withdrawals and
Purchase Payments, and then select the highest of those values. If the highest of those values exceeds the existing Total Annual
Income Amount, we replace the existing amount with the new, higher amount. Otherwise, we leave the existing Total Annual Income
Amount intact. In later years, (i.e., after the first Contract Anniversary after the first withdrawal) we determine whether an
automatic step-up should occur on each Contract Anniversary, by performing a similar examination of the Contract Values on the end of
the four immediately preceding quarters. If, on the date that we implement a Highest Quarterly Auto Step-Up to your Total Annual
Income Amount, the charge for Highest Daily Lifetime Five has changed for new purchasers, you may be subject to the new charge at the
time of such step-up. Prior to increasing your charge for Highest Daily Lifetime Five upon a step-up, we would notify you, and give
you the opportunity to cancel the automatic step-up feature. If you receive notice of a proposed step-up and accompanying fee
increase, you should carefully evaluate whether the amount of the step-up justifies the increased fee to which you will be subject.
The Highest Daily Lifetime Five program does not affect your ability to make withdrawals under your contract, or limit your ability
to request withdrawals that exceed the Total Annual Income Amount. Under Highest Daily Lifetime Five, if your cumulative withdrawals
in a Contract Year are less than or equal to the Total Annual Income Amount, they will not reduce your Total Annual Income Amount in
subsequent Contract Years, but any such withdrawals will reduce the Total Annual Income Amount on a dollar-for-dollar basis in that
Contract Year.
If, cumulatively, you withdraw an amount less than the Total Annual Income Amount in any Contract Year, you cannot carry-over the
unused portion of the Total Annual Income Amount to subsequent Contract Years.
Examples of dollar-for-dollar and proportional reductions and the Highest Quarterly Auto Step-Up are set forth below. The values
depicted here are purely hypothetical, and do not reflect the charges for the Highest Daily Lifetime Five benefit or any other fees
and charges. Assume the following for all three examples:
o The Contract Date is December 1, 2006.
o The Highest Daily Lifetime Five benefit is elected on March 5, 2007.
Dollar-for-dollar reductions
On May 2, 2007, the Total Protected Withdrawal Value is $120,000, resulting in a Total Annual Income Amount of $6,000 (5% of
$120,000). Assuming $2,500 is withdrawn from the Contract on this date, the remaining Total Annual Income Amount for that Contract
Year (up to and including December 1, 2007) is $3,500. This is the result of a dollar-for-dollar reduction of the Total Annual Income
Amount - $6,000 less $2,500 = $3,500.
Proportional reductions
Continuing the previous example, assume an additional withdrawal of $5,000 occurs on August 6, 2007 and the Contract Value at the
time of this withdrawal is $110,000. The first $3,500 of this withdrawal reduces the Total Annual Income Amount for that Contract
Year to $0. The remaining withdrawal amount - $1,500 - reduces the Total Annual Income Amount in future Contract Years on a
proportional basis based on the ratio of the excess withdrawal to the Contract Value immediately prior to the excess withdrawal.
(Note that if there were other withdrawals in that Contract Year, each would result in another proportional reduction to the Total
Annual Income Amount).
Here is the calculation:
Contract Value before withdrawal $110,000.00
Less amount of "non" excess withdrawal -$ 3,500.00
Contract Value immediately before excess withdrawal of $1,500 $106,500.00
Excess withdrawal amount $ 1,500.00
Divided by Contract Value immediately before excess withdrawal $106,500.00
Ratio 1.41%
Total Annual Income Amount $ 6,000.00
Less ratio of 1.41% -$ 84.51
Total Annual Income Amount for future Contract Years $ 5,915.49
Highest Quarterly Auto Step-Up
On each Contract Anniversary date, the Total Annual Income Amount is stepped-up if 5% of the highest quarterly value since your first
withdrawal (or last Contract Anniversary in subsequent years), adjusted for excess withdrawals and additional Purchase Payments, is
higher than the Total Annual Income Amount, adjusted for excess withdrawals and additional Purchase Payments.
Continuing the same example as above, the Total Annual Income Amount for this Contract Year is $6,000. However, the excess withdrawal
on August 6 reduces this amount to $5,915.49 for future years (see above). For the next Contract Year, the Total Annual Income Amount
will be stepped-up if 5% of the highest quarterly Contract Value, adjusted for withdrawals, is higher than $5,915.49. Here are the
calculations for determining the quarterly values. Only the June 1 value is being adjusted for excess withdrawals as the September 1
and December 1 Business Days occur after the excess withdrawal on August 6.
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
Highest Quarterly
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
Value (adjusted with Adjusted Total Annual
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
withdrawal and Income Amount (5% of the
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
Date* Contract Value Purchase Payments)** Highest Quarterly Value)
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
June 1, 2007 $118,000.00 $118,000.00 $5,900.00
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
August 6, 2007 $120,000.00 $112,885.55 $5,644.28
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
September 1, 2007 $112,000.00 $112,885.55 $5,644.28
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
December 1, 2007 $119,000.00 $119,000.00 $5,950.00
----------------------------------- --------------------------------- -------------------------------- ---------------------------------
* In this example, the Contract Anniversary date is December 1. The quarterly valuation dates are every three months thereafter -
March 1, June 1, September 1, and December 1. In this example, we do not use the March 1 date as the first withdrawal took place
after March 1. The Contract Anniversary Date of December 1 is considered the fourth and final quarterly valuation date for the year.
** In this example, the first quarterly value after the first withdrawal is $118,000 on June 1, yielding an adjusted Total Annual
Income Amount of $5,900.00. This amount is adjusted on August 6 to reflect the $5,000 withdrawal. The calculations for the
adjustments are:
o The Contract Value of $118,000 on June 1 is first reduced dollar-for-dollar by $3,500 ($3,500 is the remaining Total Annual
Income Amount for the Contract Year), resulting in an adjusted Contract Value of $114,500 before the excess withdrawal.
o This amount ($114,500) is further reduced by 1.41% (this is the ratio in the above example which is the excess withdrawal
divided by the Contract Value immediately preceding the excess withdrawal) resulting in a Highest Quarterly Value of
$112,885.55.
The adjusted Total Annual Income Amount is carried forward to the next quarterly anniversary date of September 1. At this time, we
compare this amount to 5% of the Contract Value on September 1. Since the June 1 adjusted Total Annual Income Amount of $5,644.28 is
higher than $5,600.00 (5% of $112,000), we continue to carry $5,644.28 forward to the next and final quarterly anniversary date of
December 1. The Contract Value on December 1 is $119,000 and 5% of this amount is $5,950. Since this is higher than $5,644.28, the
adjusted Total Annual Income Amount is reset to $5,950.00.
In this example, 5% of the December 1 value yields the highest amount of $5,950.00. Since this amount is higher than the current
year's Total Annual Income Amount of $5,915.49 adjusted for excess withdrawals, the Total Annual Income Amount for the next Contract
Year, starting on December 2, 2007 and continuing through December 1, 2008, will be stepped-up to $5,950.00.
Benefits Under the Highest Daily Lifetime Five Program.
To the extent that your Contract Value was reduced to zero as a result of cumulative withdrawals that are equal to or less than the
Total Annual Income Amount and amounts are still payable under Highest Daily Lifetime Five, we will make an additional payment, if
any, for that Contract Year equal to the remaining Total Annual Income Amount for the Contract Year. Thus, in that scenario, the
remaining Total Annual Income Amount would be payable even though your Contract Value was reduced to zero. In subsequent Contract
Years we make payments that equal the Total Annual Income Amount as described in this section. We will make payments until the death
of the single designated life. To the extent that cumulative withdrawals in the current Contract Year that reduced your Contract
Value to zero are more than the Total Annual Income Amount, the Highest Daily Lifetime Five benefit terminates, and no additional
payments will be made.
If annuity payments are to begin under the terms of your Contract, or if you decide to begin receiving annuity payments and there is
a Total Annual Income Amount due in subsequent Contract Years, you can elect one of the following two options:
(1) apply your Contract Value to any annuity option available; or
(2) request that, as of the date annuity payments are to begin, we make annuity payments each year equal to the Total Annual Income
Amount. We will make payments until the death of the single designated life.
We must receive your request in a form acceptable to us at our office.
In the absence of an election when mandatory annuity payments are to begin, we will make annual annuity payments in the form of a
single life fixed annuity with ten payments certain, by applying the greater of the annuity rates then currently available or the
annuity rates guaranteed in your Contract. The amount that will be applied to provide such annuity payments will be the greater of:
(1) the present value of the future Total Annual Income Amount payments. Such present value will be calculated using the greater of
the single life fixed annuity rates then currently available or the single life fixed annuity rates guaranteed in your Contract; and
(2) the Contract Value.
o If no withdrawal was ever taken, we will calculate the Total Annual Income Amount as if you made your first withdrawal on
the date that annuity payments are to begin.
o Please note that payments that we make under this benefit after the contract anniversary coinciding with or next following
the annuitant's 95th birthday will be treated as annuity payments.
Other Important Considerations
o Withdrawals under the Highest Daily Lifetime Five Benefit are subject to all of the terms and conditions of the Contract,
including any withdrawal charge.
o Withdrawals made while the Highest Daily Lifetime Five Benefit is in effect will be treated, for tax purposes, in the same
way as any other withdrawals under the Contract. The Highest Daily Lifetime Five Benefit does not directly affect the
Contract Value or surrender value, but any withdrawal will decrease the Contract Value by the amount of the withdrawal (plus
any applicable withdrawal charge). If you surrender your Contract, you will receive the current surrender value.
o You can make withdrawals from your Contract while your Contract Value is greater than zero without purchasing the Highest
Daily Lifetime Five Benefit. The Highest Daily Lifetime Five Benefit provides a guarantee that if your Contract Value
declines due to market performance, you will be able to receive your Total Annual Income Amount in the form of periodic
benefit payments. Please note that the payments that we make under this benefit after the contract anniversary coinciding
with or next following the Annuitant's 95/th birthday will be treated as annuity payments.
o Upon inception of the benefit, 100% of your Contract Value must be allocated to the permitted Sub-accounts. However, the
asset transfer component of the benefit as described below may transfer Contract Value to the Benefit Fixed Rate Account as
of the effective date of the benefit in some circumstances.
o You cannot allocate Purchase Payments or transfer Contract Value to a Fixed Interest Rate Option if you elect Highest Daily
Lifetime Five.
o Transfers to and from the Sub-accounts and the Benefit Fixed Rate Account triggered by the asset transfer component of the
benefit will not count toward the maximum number of free transfers allowable under the Contract.
o In general, you must allocate your Contract Value in accordance with the then available investment option(s) that we may
prescribe in order to elect and maintain the Highest Daily Lifetime Five benefit. If, subsequent to your election of the
benefit, we change our requirements for how Contract Value must be allocated under the benefit, the new requirement will
apply only to new elections of the benefit, and we will not compel you to re-allocate your Contract Value in accordance with
our newly-adopted requirements. Subsequent to any change in requirements, transfers of Contract Value and allocation of
additional Purchase Payments may be subject to the new investment limitations.
Election of and Designations Under the Program
For Highest Daily Lifetime Five, there must be either a single Owner who is the same as the Annuitant, or if the Contract is
entity-owned, there must be a single natural person Annuitant. In either case, the Annuitant must be at least 55 years old.
Any change of the Annuitant under the Contract will result in cancellation of Highest Daily Lifetime Five. Similarly, any change of
Owner will result in cancellation of Highest Daily Lifetime Five, except if (a) the new Owner has the same taxpayer identification
number as the previous owner (b) both the new Owner and previous Owner are entities or (c) the previous Owner is a natural person and
the new Owner is an entity.
Currently, if you terminate the Highest Daily Lifetime Five benefit, you will (a) not be permitted to re-elect the benefit and (b)
will be allowed to elect the Spousal Lifetime Five Benefit or the Lifetime Five Income Benefit on any anniversary of the Contract
Date that is at least 90 calendar days from the date the Highest Daily Lifetime Five Benefit was terminated. We reserve the right to
further limit the election frequency in the future. Before making any such change to the election frequency, we will provide prior
notice to Owners who have an effective Highest Daily Lifetime Five benefit.
Termination of the Program
You may terminate the benefit at any time by notifying us. If you terminate the benefit, any guarantee provided by the benefit will
terminate as of the date the termination is effective, and certain restrictions on re-election will apply as described above. The
benefit terminates: (i) upon your termination of the benefit (ii) upon your surrender of the Contract (iii) upon your election to
begin receiving annuity payments (iv) upon the death of the Annuitant (v) if both the Contract Value and Total Annual Income Amount
equal zero or (vi) if you fail to meet our requirements for issuing the benefit.
Upon termination of Highest Daily Lifetime Five, we cease deducting the charge for the benefit. With regard to your investment
allocations, upon termination we will: (i) leave intact amounts that are held in the variable investment options, and (ii) transfer
all amounts held in the Benefit Fixed Rate Account (as defined below) to your variable investment options, based on your existing
allocation instructions or (in the absence of such existing instructions) pro rata (i.e. in the same proportion as the current
balances in your variable investment options).
Return of Principal Guarantee
If you have not made a withdrawal before the Tenth Anniversary, we will increase your Contract Value on that Tenth Anniversary (or
the next business day, if that anniversary is not a business day), if the requirements set forth in this paragraph are met. On the
Tenth Anniversary, we add:
(a) your Contract Value on the day that you elected Highest Daily Lifetime Five; and
(b) the sum of each Purchase Payment you made (including any Credits) during the one-year period after you elected the benefit.
If the sum of (a) and (b) is greater than your Contract Value on the Tenth Anniversary, we increase your Contract Value to equal the
sum of (a) and (b), by contributing funds from our general account. If the sum of (a) and (b) is less than or equal to your Contract
Value on the Tenth Anniversary, we make no such adjustment. The amount that we add to your Contract Value under this provision will
be allocated to each of your variable investment options and the Benefit Fixed Rate Account (described below), in the same proportion
that each such investment option bears to your total Contract Value, immediately prior to the application of the amount. Any such
amount will not be considered a purchase payment when calculating your Total Protected Withdrawal Value, your death benefit, or the
amount of any other optional benefit that you may have selected, and therefore will have no direct impact on any such values at the
time we add this amount. This potential addition to Contract Value is available only if you have elected Highest Daily Lifetime Five
and if you meet the conditions set forth in this paragraph. Thus, if you take a withdrawal prior to the Tenth Anniversary, you are
not eligible to receive the Return of Principal Guarantee.
Upon termination, we may limit or prohibit investment in the fixed interest rate options.
Asset Transfer Component of Highest Daily Lifetime Five
As indicated above, we limit the sub-accounts to which you may allocate Contract Value if you elect Highest Daily Lifetime Five. For
purposes of this benefit, we refer to those permitted sub-accounts as the "Permitted Sub-accounts". The Permitted Sub-accounts are
identified in the contract application. As a requirement of participating in Highest Daily Lifetime Five, we require that you
participate in our specialized asset transfer program, under which we may transfer Contract Value between the Permitted Sub-accounts
and a fixed interest rate account that is part of our general account (the "Benefit Fixed Rate Account"). We determine whether to
make a transfer, and the amount of any transfer, under a non-discretionary formula, discussed below. The Benefit Fixed Rate Account
is available only with this benefit, and thus you may not allocate Purchase Payments to that Account. The interest rate that we pay
with respect to the Benefit Fixed Rate Account is reduced by an amount that corresponds generally to the charge that we assess
against your variable sub-accounts for Highest Daily Lifetime Five. The Benefit Fixed Rate Account is not subject to the Investment
Company Act of 1940 or the Securities Act of 1933.
Under the asset transfer component of Highest Daily Lifetime Five, we monitor your Contract Value daily and, if necessary,
systematically transfer amounts between the Permitted Sub-accounts you have chosen and the Benefit Fixed Rate Account. Any transfer
would be made in accordance with a formula, which is set forth in the schedule supplement to the endorsement for this benefit (and
also appears in the Appendices to this prospectus). Speaking generally, the formula, which we apply each business day, operates as
follows. The formula starts by identifying your Protected Withdrawal Value for that day and then multiplies that figure by 5%, to
produce a projected (i.e., hypothetical) Highest Daily Annual Income Amount. Then, using our actuarial tables, we produce an estimate
of the total amount we would target in our allocation model, based on the projected Highest Daily Annual Income Amount each year for
the rest of your life. In the formula, we refer to that value as the "Target Value" or "L". If you have already made a withdrawal,
your projected Highest Daily Annual Income Amount (and thus your Target Value) would take into account any automatic step-up that was
scheduled to occur according to the step-up formula described above. Next, the formula subtracts from the Target Value the amount
held within the Benefit Fixed Rate Account on that day, and divides that difference by the amount held within the Permitted
Sub-accounts. That ratio, which essentially isolates the amount of your Target Value that is not offset by amounts held within the
Benefit Fixed Rate Account, is called the "Target Ratio" or "r". If the Target Ratio exceeds a certain percentage (currently 83%), it
means essentially that too much Target Value is not offset by assets within the Benefit Fixed Rate Account, and therefore we will
transfer an amount from your Permitted Sub-accounts to the Benefit Fixed Rate Account. Conversely, if the Target Ratio falls below a
certain percentage (currently 77%), then a transfer from the Benefit Fixed Rate Account to the Permitted Sub-accounts would occur.
Note that the formula is calculated with reference to the Highest Daily Annual Income Amount, rather than with reference to the Total
Annual Income Amount.
As you can glean from the formula, a downturn in the securities markets (i.e., a reduction in the amount held within the Permitted
Sub-accounts) may cause us to transfer some of your variable Contract Value to the Benefit Fixed Rate Account, because such a
reduction will tend to increase the Target Ratio. Moreover, certain market return scenarios involving "flat" returns over a period of
time also could result in the transfer of money to the Benefit Fixed Rate Account. In deciding how much to transfer, we use another
formula, which essentially seeks to rebalance amounts held in the Permitted Sub-accounts and the Benefit Fixed Rate Account so that
the Target Ratio meets a specified target, which currently is equal to 80%. Once you elect Highest Daily Lifetime Five, the ratios we
use will be fixed. For new elections in the future, however, we reserve the right to change the ratios.
While you are not notified when your Contract reaches a reallocation trigger, you will receive a confirmation statement indicating
the transfer of a portion of your Contract Value either to or from the Benefit Fixed Rate Account. The formula by which the
reallocation triggers operate is designed primarily to mitigate the financial risks that we incur in providing the guarantee under
Highest Daily Lifetime Five.
Depending on the results of the calculation relative to the reallocation triggers, we may, on any day:
o Not make any transfer; or
o If a portion of your Contract Value was previously allocated to the Benefit Fixed Rate Account, transfer all or a portion of
those amounts to the Permitted Sub-accounts, based on your existing allocation instructions or (in the absence of such
existing instructions) pro rata (i.e., in the same proportion as the current balances in your variable investment options).
Amounts taken out of the Benefit Fixed Rate Account will be withdrawn for this purpose on a last-in, first-out basis (an
amount renewed into a new guarantee period under the Benefit Fixed Rate Account will be deemed a new investment for purposes
of this last-in, first-out rule); or
o Transfer all or a portion of your Contract Value in the Permitted Sub-accounts pro-rata to the Benefit Fixed Rate Account.
The interest that you earn on such transferred amount will be equal to the annual rate that we have set for that day, and we
will credit the daily equivalent of that annual interest until the earlier of one year from the date of the transfer or the
date that such amount in the Benefit Fixed Rate Account is transferred back to the Permitted Sub-accounts.
If a significant amount of your Contract Value is systematically transferred to the Benefit Fixed Rate Account during periods of
market declines or low interest rates, less of your Contract Value may be available to participate in the investment experience of
the Permitted Sub-accounts if there is a subsequent market recovery. Under the reallocation formula that we employ, it is possible
that over time a significant portion, and under certain circumstances all, of your Contract Value may be allocated to the Benefit
Fixed Rate Account. Note that if your entire Contract Value is transferred to the Benefit Fixed Rate Account, then based on the way
the formula operates, that value would remain in the Benefit Fixed Rate Account unless you made additional purchase payments to the
Permitted Sub-accounts, which could cause Contract Value to transfer out of the Benefit Fixed Rate Account.
Additional Tax Considerations
If you purchase a contract as an investment vehicle for "qualified" investments, including an IRA, SEP-IRA, Tax Sheltered Annuity (or
403(b)) or employer plan under Code Section 401(a), the minimum distribution rules under the Code require that you begin receiving
periodic amounts from your contract beginning after age 70 1/2. For a Tax Sheltered Annuity or a 401(a) plan for which the
participant is not a greater than 5 percent owner of the employer, this required beginning date can generally be deferred to
retirement, if later. Roth IRAs are not subject to these rules during the owner's lifetime. The amount required under the Code may
exceed the Total Annual Income Amount, which will cause us to increase the Total Annual Income Amount in any Contract Year that
required minimum distributions due from your Contract are greater than such amounts. In addition, the amount and duration of payments
under the contract payment and death benefit provisions may be adjusted so that the payments do not trigger any penalty or excise
taxes due to tax considerations such as required minimum distribution under the tax law. Please note, however, that any withdrawal
you take prior to the Tenth Anniversary, even if withdrawn to satisfy required minimum distribution rules, will cause you to lose the
ability to receive Enhanced Protected Withdrawal Value and an amount under the Return of Principal Guarantee.
As indicated, withdrawals made while the Highest Daily Lifetime Five Benefit is in effect will be treated, for tax purposes, in the
same way as any other withdrawals under the contract. Please see the Tax Considerations section of the prospectus for a detailed
discussion of the tax treatment of withdrawals. We do not address each potential tax scenario that could arise with respect to this
Benefit here. However, we do note that if you participate in Highest Daily Lifetime Five through a non-qualified annuity, and your
annuity has received Enhanced Protected Withdrawal Value and/or an additional amount under the Return of Principal Guarantee, as with
all withdrawals, once all purchase payments are returned under the contract, all subsequent withdrawal amounts will be taxed as
ordinary income.
VI. THE FOLLOWING IS ADDED AS APPENDIX C:
Appendix C
Asset Transfer Formula Under Highest Daily Lifetime Five Benefit
We set out below the current formula under which we may transfer amounts between the variable investment options and the Benefit
Fixed Rate Account. Upon your election of Highest Daily Lifetime Five, we will not alter the asset transfer formula that applies to
your contract. However, we reserve the right to modify this formula with respect to those who elect Highest Daily Lifetime Five in
the future.
Terms and Definitions referenced in the calculation formula:
o Cu - the upper target is established on the effective date of the Highest Daily Lifetime Five benefit (the "Effective Date")
and is not changed for the life of the guarantee. Currently, it is 83%.
o Ct - the target is established on the Effective Date and is not changed for the life of the guarantee. Currently, it is 80%.
o Cl - the lower target is established on the Effective Date and is not changed for the life of the guarantee. Currently, it
is 77%.
o L - the target value as of the current Valuation Day.
o r - the target ratio.
o a - the factors used in calculating the target value. These factors are established on the Effective Date and are not
changed for the life of the guarantee. The factors that we use currently are derived from the a2000 Individual Annuity
Mortality Table with an assumed interest rate of 3%. Each number in the table "a" factors (which appears below) represents a
factor, which when multiplied by the Highest Daily Annual Income Amount, projects our total liability for the purpose of asset
transfers under the guarantee.
o Q - age based factors used in calculating the target value. These factors are established on the Effective Date and are not
changed for the life of the guarantee. The factor is currently set equal to 1.
o V - the total value of all Permitted Sub-accounts in the contract.
o F - the total value of all Benefit Fixed Rate Account allocations.
o I - the income value prior to the first withdrawal. The income value is equal to what the Highest Daily Annual Income
Amount would be if the first withdrawal were taken on the date of calculation. After the first withdrawal the income value
equals the greater of the Highest Daily Annual Income Amount, the quarterly step-up amount times the annual income percentage,
and the contract value times the annual income percentage.
o T - the amount of a transfer into or out of the Benefit Fixed Rate Account.
o I% - annual income amount percentage. This factor is established on the Effective Date and is not changed for the life of
the guarantee. Currently, it is 5%
Target Value Calculation:
On each Valuation Day, a target value (L) is calculated, according to the following formula. If the variable Contract Value (V) is
equal to zero, no calculation is necessary.
L = I * Q * a
Transfer Calculation:
The following formula, which is set on the Effective Date and is not changed for the life of the guarantee, determines when a
transfer is required:
Target Ratio r = (L - F) / V.
o If r > Cu, assets in the Permitted Sub-accounts are transferred to Benefit Fixed Rate Account.
o If r < Cl, and there are currently assets in the Benefit Fixed Rate Account (F > 0), assets in the Benefit Fixed Rate
Account are transferred to the Permitted Sub-accounts.
The following formula, which is set on the Effective Date and is not changed for the life of the guarantee, determines the transfer
amount:
T ={Min(V, [L - F - V * Ct] / (1-Ct))} T>0, Money moving from the Permitted Sub-accounts to the Benefit
Fixed Rate Account
T ={Min(F, [L - F - V * Ct] / (1-Ct))} T<0, Money moving from the Benefit Fixed Rate Account to the
Permitted Sub-accounts]
Example:
Male age 65 contributes $100,000 into the Permitted Sub accounts and the value drops to $92,300 during year one, end of day one. A
table of values for "a" appears below.
Target Value Calculation:
L = I * Q * a
= 5000.67 * 1 * 15.34
= 76,710.28
Target Ratio:
r = (L - F) / V
= (76,710.28 - 0) / 92,300.00
= 83.11%
Since r > Cu ( because 83.11% > 83%) a transfer into the Benefit Fixed rate Account occurs.
T = { Min ( V, [ L - F - V * Ct] / ( 1 - Ct))}
= { Min ( 92,300.00, [ 76,710.28 - 0 - 92,300.00 * 0.80] / ( 1 - 0.80))}
= { Min ( 92,300.00, 14,351.40 )}
= 14,351.40
Age 65 "a" Factors for Liability Calculations
(in Years and Months since Benefit Effective Date)*
Months
Years 1 2 3 4 5 6 7 8 9 10 11 12
1 15.34 15.31 15.27 15.23 15.20 15.16 15.13 15.09 15.05 15.02 14.98 14.95
2 14.91 14.87 14.84 14.80 14.76 14.73 14.69 14.66 14.62 14.58 14.55 14.51
3 14.47 14.44 14.40 14.36 14.33 14.29 14.26 14.22 14.18 14.15 14.11 14.07
4 14.04 14.00 13.96 13.93 13.89 13.85 13.82 13.78 13.74 13.71 13.67 13.63
5 13.60 13.56 13.52 13.48 13.45 13.41 13.37 13.34 13.30 13.26 13.23 13.19
6 13.15 13.12 13.08 13.04 13.00 12.97 12.93 12.89 12.86 12.82 12.78 12.75
7 12.71 12.67 12.63 12.60 12.56 12.52 12.49 12.45 12.41 12.38 12.34 12.30
8 12.26 12.23 12.19 12.15 12.12 12.08 12.04 12.01 11.97 11.93 11.90 11.86
9 11.82 11.78 11.75 11.71 11.67 11.64 11.60 11.56 11.53 11.49 11.45 11.42
10 11.38 11.34 11.31 11.27 11.23 11.20 11.16 11.12 11.09 11.05 11.01 10.98
11 10.94 10.90 10.87 10.83 10.79 10.76 10.72 10.69 10.65 10.61 10.58 10.54
12 10.50 10.47 10.43 10.40 10.36 10.32 10.29 10.25 10.21 10.18 10.14 10.11
13 10.07 10.04 10.00 9.96 9.93 9.89 9.86 9.82 9.79 9.75 9.71 9.68
14 9.64 9.61 9.57 9.54 9.50 9.47 9.43 9.40 9.36 9.33 9.29 9.26
15 9.22 9.19 9.15 9.12 9.08 9.05 9.02 8.98 8.95 8.91 8.88 8.84
16 8.81 8.77 8.74 8.71 8.67 8.64 8.60 8.57 8.54 8.50 8.47 8.44
17 8.40 8.37 8.34 8.30 8.27 8.24 8.20 8.17 8.14 8.10 8.07 8.04
18 8.00 7.97 7.94 7.91 7.88 7.84 7.81 7.78 7.75 7.71 7.68 7.65
19 7.62 7.59 7.55 7.52 7.49 7.46 7.43 7.40 7.37 7.33 7.30 7.27
20 7.24 7.21 7.18 7.15 7.12 7.09 7.06 7.03 7.00 6.97 6.94 6.91
21 6.88 6.85 6.82 6.79 6.76 6.73 6.70 6.67 6.64 6.61 6.58 6.55
22 6.52 6.50 6.47 6.44 6.41 6.38 6.36 6.33 6.30 6.27 6.24 6.22
23 6.19 6.16 6.13 6.11 6.08 6.05 6.03 6.00 5.97 5.94 5.92 5.89
24 5.86 5.84 5.81 5.79 5.76 5.74 5.71 5.69 5.66 5.63 5.61 5.58
25 5.56 5.53 5.51 5.48 5.46 5.44 5.41 5.39 5.36 5.34 5.32 5.29
26 5.27 5.24 5.22 5.20 5.18 5.15 5.13 5.11 5.08 5.06 5.04 5.01
27 4.99 4.97 4.95 4.93 4.91 4.88 4.86 4.84 4.82 4.80 4.78 4.75
28 4.73 4.71 4.69 4.67 4.65 4.63 4.61 4.59 4.57 4.55 4.53 4.51
29 4.49 4.47 4.45 4.43 4.41 4.39 4.37 4.35 4.33 4.32 4.30 4.28
30 4.26 4.24 4.22 4.20 4.18 4.17 4.15 4.13 4.11 4.09 4.07 4.06
31 4.04 4.02 4.00 3.98 3.97 3.95 3.93 3.91 3.90 3.88 3.86 3.84
32 3.83 3.81 3.79 3.78 3.76 3.74 3.72 3.71 3.69 3.67 3.66 3.64
33 3.62 3.61 3.59 3.57 3.55 3.54 3.52 3.50 3.49 3.47 3.45 3.44
34 3.42 3.40 3.39 3.37 3.35 3.34 3.32 3.30 3.29 3.27 3.25 3.24
35 3.22 3.20 3.18 3.17 3.15 3.13 3.12 3.10 3.08 3.07 3.05 3.03
36 3.02 3.00 2.98 2.96 2.95 2.93 2.91 2.90 2.88 2.86 2.85 2.83
37 2.81 2.79 2.78 2.76 2.74 2.73 2.71 2.69 2.68 2.66 2.64 2.62
38 2.61 2.59 2.57 2.56 2.54 2.52 2.51 2.49 2.47 2.45 2.44 2.42
39 2.40 2.39 2.37 2.35 2.34 2.32 2.30 2.29 2.27 2.25 2.24 2.22
40 2.20 2.19 2.17 2.15 2.14 2.12 2.11 2.09 2.07 2.06 2.04 2.02
41 2.01 1.84 1.67 1.51 1.34 1.17 1.00 0.84 0.67 0.50 0.33 0.17
* The values set forth in this table are applied to all ages.
VII. NEW PRINCIPAL UNDERWRITER
In the "Other Information" section of each prospectus, under the heading entitled "Sales and Distribution of the Contract", we
identify Prudential Investment Management Services LLC (PIMS) as the principal underwriter and distributor of the annuities.
Beginning as of the date of this supplement, PIMS has been replaced by an affiliated broker-dealer called Prudential Annuities
Distributors, Inc. ("PAD"). Accordingly, we replace the first two paragraphs under "Sales and Distribution of the Contract" with the
following, and in the remainder of that section, replace references to PIMS with PAD:
"Prudential Annuities Distributors, Inc. (PAD), a wholly-owned subsidiary of Prudential Annuities, Inc., is the distributor and
principal underwriter of the annuities offered through this prospectus. PAD acts as the distributor of a number of annuity and life
insurance products, and is the co-distributor of the Advanced Series Trust. PAD's principal business address is One Corporate Drive,
Shelton, Connecticut 06484. PAD is registered as a broker-dealer under the Securities Exchange Act of 1934 (Exchange Act), and is a
member of the National Association of Securities Dealers, Inc. (NASD)."
September 6, 2007
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pruco Life Insurance Company of New Jersey
Pruco Life of New Jersey Flexible Premium Variable Annuity Account
Post-Effective Amendment No. 11 on Form N-4, Registration No. 333-62238
Dear Sir/Madam:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned respectfully request that the effective date of the
Registration Statement referenced above be accelerated so the same may become effective on September 11, 2007.
It would be appreciated if, as soon as the Registration Statement has become effective, you would so inform C. Christopher
Sprague, Esq. by telephone at (973) 802-6997.
Sincerely,
Pruco Life Insurance Company of New Jersey
Pruco Life of New Jersey Flexible Premium Variable Annuity Account
(Registrant)
/s/Daniel Kane
________________________________________
Daniel Kane
Vice President
Prudential Investment Management Services, LLC
(Principal Underwriter)
/s/Bruce Ferris
__________________________________________
Bruce Ferris
Vice President
September 6, 2007
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pruco Life Insurance Company of New Jersey
Post-Effective Amendment No. 7 on Form S-3, Registration No. 333-100713
Dear Sir/Madam:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned respectfully request that the effective
date of the Registration Statement referenced above be accelerated so the same may become effective on September 11, 2007.
It would be appreciated if, as soon as the Registration Statement has become effective, you would so inform C.
Christopher Sprague, Esq. by telephone at (973) 802-6997.
Sincerely,
Pruco Life Insurance Company of New Jersey
(Registrant)
/s/Daniel Kane
________________________________________
Daniel Kane
Vice President
Prudential Investment Management Services, LLC
(Principal Underwriter)
/s/Bruce Ferris
__________________________________________
Bruce Ferris
Vice President
September 6, 2007
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pruco Life Insurance Company of New Jersey
Pruco Life Flexible of New Jersey Premium Variable Annuity Account
Post-Effective Amendment No. 5 on Form N-4, Registration No. 333-131035
Dear Sir/Madam:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned respectfully request that the effective
date of the Registration Statement referenced above be accelerated so the same may become effective on September 11, 2007.
It would be appreciated if, as soon as the Registration Statement has become effective, you would so inform C.
Christopher Sprague, Esq. by telephone at (973) 802-6997.
Sincerely,
Pruco Life Insurance Company
Pruco Life Flexible Premium Variable Annuity Account
(Registrant)
/s/Daniel Kane
________________________________________
Daniel Kane
Vice President
Prudential Investment Management Services, LLC
(Principal Underwriter)
/s/Bruce Ferris
__________________________________________
Bruce Ferris
Vice President
September 6, 2007
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pruco Life Insurance Company of New Jersey
Pruco Life of New Jersey Flexible Premium Variable Annuity Account
Post-Effective Amendment No. 1 on Form N-4, Registration No. 333-144657
Dear Sir/Madam:
Pursuant to Rule 461 under the Securities Act of 1933, the undersigned respectfully request that the effective
date of the Registration Statement referenced above be accelerated so the same may become effective on September 11, 2007.
It would be appreciated if, as soon as the Registration Statement has become effective, you would so inform C.
Christopher Sprague, Esq. by telephone at (973) 802-6997.
Sincerely,
Pruco Life Insurance Company of New Jersey
Pruco Life of New Jersey Flexible Premium Variable Annuity Account
(Registrant)
/s/Daniel Kane
________________________________________
Daniel Kane
Vice President
Prudential Investment Management Services, LLC
(Principal Underwriter)
/s/Bruce Ferris
__________________________________________
Bruce Ferris
Vice President