Mr. Sonny Oh
July 9, 2021
Page 2
Annuity (“6-Year Annuity”); and (3) Brighthouse Shield® Level Select 3-Year Annuity (“3-Year Annuity”), individual single premium deferred index-linked separate account annuity contracts (each a “Contract” and collectively, the “Contracts”).
Capitalized terms used but not otherwise defined herein have the meanings set forth in the Supplements.
To facilitate the Staff’s review, we previously provided courtesy copies of each of the Supplements as well as the corresponding Prospectus for each of the Contracts. Unless indicated otherwise, page references herein are to the courtesy copy of the 6-Year Annuity Supplement provided to the Staff.
For ease of reference, each of the comments of the Staff is set forth below, followed by the Registrant’s response. In cases where the Registrant’s response indicates that the Registrant has proposed revised disclosure to the Supplements, the pages of the Supplements, as so revised, are filed herewith.
1. | General—Applicability of Staff Comments to Each Supplement |
Comment: Each of the Staff’s comments to the 6-Year Annuity should be assumed to apply to each of the other Supplements (i.e., for each of the Advisory Annuity and 3-Year Annuity).
Response: The Registrant acknowledges the foregoing and has assumed that each of the Staff’s comments apply to all of the Supplements and, to the extent a disclosure revision has been made to one Supplement, a conforming revision has been made to all Supplements, unless specifically noted otherwise.
2. | General—Conforming Revisions |
Comment: Each of the Staff’s comments to particular disclosure should be assumed to apply to similar disclosure throughout each Supplement.
Response: The Registrant acknowledges the foregoing and, to the extent a disclosure revision has been made in one instance, conforming revisions were made elsewhere in the Supplement, as applicable.
3. | Introductory Portion of Supplement; Availability of Performance Lock |
a. Comment: The Staff notes that, as described in correspondence dated June 17, 2021 (the “Initial Response Letter”), the Registrant added explanatory disclosure to the introductory paragraph to provide Owners with a simple example of the Performance Lock—in response to the Staff’s initial comments on the Supplements provided via telephone on May 21, 2021, and specifically comment 4(a), as identified in the Initial Response Letter. Although the Staff believes that the additional disclosure is helpful, the Staff recommends that the Registrant provide more general information regarding the availability of the Performance Lock in the introductory paragraph, particularly since the “SHIELD OPTIONS” table is included towards the end of the Supplement. Please refer to the Staff’s prior comment 16(a), advising that