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Ohio National Financial Services
One Financial Way
Cincinnati, Ohio 45242
VIA EDGAR CORRESPONDENCE
December 20, 2016
Ms. Jaea Hahn
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F. Street, N.E.
Washington, D.C. 20549-0506
| Re: | Ohio National Variable Account A |
ONcore Premier II Individual Variable Annuity
Post-Effective Amendment No. 21
File Nos. 811-01978 & 333-164070
Dear Ms. Hahn:
This letter responds to comments of the staff of the Securities and Exchange Commission (“Commission”) on the above-referenced post-effective amendment (the “Post-Effective Amendment”), which you communicated to me by telephone on December 12, 2016. Registrant filed the Post-Effective Amendment with the Commission on October 27, 2016 pursuant to Rule 485(a) under the Securities Act of 1933 (“1933 Act”). Registrant filed 17 other post-effective amendments with the Commission on October 27, 2016 pursuant to Rule 485(a) under the 1933 Act (collectively, along with the Post-Effective Amendment, the “ONLIC filings”).
For convenience, each of Registrant’s responses below is preceded by the applicable Staff comment. Capitalized terms used herein have the meanings given to them in the Post-Effective Amendment. Registrant will give effect to disclosure changes made in response to Staff comments by means of post-effective amendments filed pursuant to Rule 485(b) under the 1933 Act.
Comments
1. General Comment – Please respond to the comments via EDGAR Correspondence. Please confirm that all missing or bracketed information, including financial information and exhibits, will be included in a following post-effective amendment.
Response: Registrant confirms that any missing or bracketed information, including financial information and exhibits, will be included in the 485(b) post-effective amendment.
Ms. Hahn
December 20, 2016
Page 2 of 15
2. Company Acknowledgement – In lieu of the “Tandy” representation, the Staff reminds the Registrant and Depositor and their management that they are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
Response: We acknowledge that the Securities and Exchange Commission has reminded us that Registrant and Depositor and their management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
3. Specific Comments on Filings – The comments are given as to ONcore Premier II. To the extent any comments apply to the other filings, please make them in those filings.
Response:To the extent such comments apply to the following post-effective amendment filings by Registrant, Ohio National Variable Account A, our responses are applicable to each such filing and changes will be made to each applicable filing:
Product filing | 40 Act File No. | 33 Act File No. | ||
| ONcore Premier (sold before October 1, 2012), Post-Effective Amendment No. 53 | 811-01978 | 333-43515 | ||
| ONcore Value (sold before October 1, 2012), Post-Effective Amendment No. 56 | 811-01978 | 333-43513 | ||
| ONcore Xtra (sold before October 1, 2012), Post-Effective Amendment No. 47 | 811-01978 | 333-86603 | ||
| ONcore Lite, Post-Effective Amendment No. 44 | 811-01978 | 333-52006 | ||
| ONcore Flex, Post-Effective Amendment No. 50 | 811-01978 | 333-43511 | ||
| ONcore Ultra, Post-Effective Amendment No. 26 | 811-01978 | 333-134288 | ||
| ONcore Wrap, Post-Effective Amendment No. 33 | 811-01978 | 333-134982 | ||
| ONcore Lite II, Post-Effective Amendment No. 25 | 811-01978 | 333-156430 | ||
| ONcore Ultra II, Post-Effective Amendment No. 28 | 811-01978 | 333-156432 | ||
| ONcore Premier (sold on or after October 1, 2012), Post-Effective Amendment No. 10 | 811-01978 | 333-182250 | ||
| ONcore Value (sold on or after October 1, 2012), Post-Effective Amendment No. 10 | 811-01978 | 333-182248 | ||
| ONcore Xtra (sold on or after October 1, 2012), Post-Effective Amendment No. 9 | 811-01978 | 333-182249 | ||
| ONcore Wrap, Post-Effective Amendment No. 31 | 811-01978 | 333-134982 | ||
| ONcore Ultra II, Post-Effective Amendment No. 26 | 811-01978 | 333-156432 | ||
| ONcore Lite III, Post-Effective Amendment No. 21 | 811-01978 | 333-164075 | ||
| ONcore Xtra II, Post-Effective Amendment No. 20 | 811-01978 | 333-164073 | ||
| ONcore Flex II, Post-Effective Amendment No. 18 | 811-01978 | 333-164069 | ||
| ONcore Wealth Foundation, Post-Effective Amendment No. 18 | 811-01978 | 333-171785 | ||
| ONcore Select, Post-Effective Amendment No. 1 | 811-01978 | 333-212677 | ||
Ms. Hahn
December 20, 2016
Page 3 of 15
4. Optional Asset Allocation Models Heading – Please consider highlighting in bold the heading “Important Information Concerning the….” on page 1.
Response: Registrant will ensure that the heading is in bold in the typeset, printed copy and to increase its prominence, has increased the font size of the heading.
5. Optional Asset Allocation Models Description – Please consider adding a brief description of the current dynamic Asset Allocation Models after the first paragraph including the following:
a. Describe how the current Asset Allocation Models invest in a set percentage of underlying funds.
b. Explain what’s meant by periodic update (ie whether they involve changes to just the percentage of underlying funds or changes to the makeup of the underlying funds).
c. Clarify what quarterly rebalancing of account values entails and how it differs from rebalancing of portfolio investments.
d. Clarify where investors can find the most recent model allocation before they become static.
Response: Registrant has added the following disclosure as the second paragraph of this section:
The Asset Allocation Models are designed to provide diversification among various investment classes and fund managers. Each Model offers a blend of equity and fixed investments, designed to fit different investment needs, by investing in a combination of the contract’s available Funds. ONII sets the makeup of each Model, allocating percentages to the underlying Funds. At the end of each quarter, variable account values allocated within each Model are rebalanced to maintain the mix of underlying Funds in the proportions established for each Model. Periodically, typically annually, ONII assesses the makeup of each of the Asset Allocation Models to determine if they continue to maintain the optimal level of investment return balanced against the designated risk tolerance for the model. If ONII determines changes to the Models are appropriate, it may change the underlying Funds in the Models or may change the percentage of the Models allocated to the underlying Funds. Please see Appendix C — Asset Allocation Models of your prospectus or contact us at 888.925.6446 or your registered representative for more detailed information on the Models, including the current makeup of the Models.
6. Optional Asset Allocation Models Subheadings – Please consider adding a subheading before the paragraph discussing the Managed Volatility Model and one before the discussion of the other Asset Allocation Models.
Response: Registrant has added the requested subheadings.
7. Optional Asset Allocation Models – Managed Volatility Model Paragraph – Please consider revising sentence “The Model will remain invested” to clarify the potential consequences to investors, such as the model will remain invested in same portfolios and same percentages over time which may fail to optimize returns.
Ms. Hahn
December 20, 2016
Page 4 of 15
Response: Registrant has added the following as the second sentence of the paragraph:
That means the Model will remain invested in the same underlying Funds and in the same percentages among the Funds over time, which may fail to optimize returns since underperforming Funds will not be replaced within the Model and the underlying percentages will not be updated.
8. Effect of New Investment Restrictions – In each applicable section of the supplement, please clarify, if true, that if a contractowner adds new premium payments or requests a transfer that he/she must be in compliance with the new investment restrictions.
Response: The requested disclosure has been added to those sections where it is applicable.
9. Optional Asset Allocation Models – Model Portfolios – Please revise third paragraph to include the following:
a. Explain what a fund-of-funds Model portfolio is and how it differs from the current AAM
b. State who will determine the initial composition of the five fund model portfolios
c. Will any changes be made to fund-of-fund Model portfolios over time or will they remain static
d. When will contractowners be given information regarding what the Model portfolio composition will be and will the differences between the current AAM and the FoF be explained before March 2017.
Response: The relevant paragraph has been revised to read as follows:
In March 2017, ONII will be updating the remaining Asset Allocation Models so that each Model will consist of a single fund-of-funds model portfolio that has a substantially similar investment objective. Each Model Portfolio, itself a Fund, will invest in multiple other funds of various asset classes to maintain the optimal level of investment return balanced against the risk tolerance for the Model. ONII will determine the initial composition of each Model Portfolio. Thereafter, an Asset Allocation Committee of ONII will manage the Model Portfolios, evaluating assets on a frequent basis and making changes to the investments of the Model Portfolios as deemed necessary. The Model Portfolios differ from the existing Models in that each Model Portfolio is a single Fund that actively invests in other funds, as opposed to an allocation of set percentages of Funds available in your contract. Additionally, the Model Portfolios will be evaluated on a more frequent basis. If you have values allocated to an existing Model, you will receive a prospectus for the corresponding Model Portfolio which will contain detailed information about the Model Portfolio once the conversion occurs. The following shows the updates to be made to the Models, including the anticipated timing:
10. Investment Restrictions for Certain Optional Riders – On page 3, please revise the last sentence in the language about the GLWB (2012) to clarify that contractowners must comply with (1) or (2).
Response: The requested change has been made.
Ms. Hahn
December 20, 2016
Page 5 of 15
11. GLWB Preferred I.S. – Please consider revising the last two sentences to clarify that termination means that the contractowner’s rider will be canceled by the company.
Response: The last two sentences have been revised as follows:
If you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders,” we will cancel your GLWB Preferred I.S. rider. If the rider is so canceled, a prorated annual rider charge will be assessed.
Additionally, similar changes have been made to all similar sentences in other sections.
12. Optional Guaranteed Principal Access (“GPA”) – Please clarify the effect of the changes on contractowners who are in a static model and whether they can continue to make purchase payments.
Response: The following has been added as the fourth sentence in the section:
If (i) your variable account values were allocated to a static Model prior to March 17, 2017, (ii) your account values were allocated to the Managed Volatility Model, or (iii) you opted out of the conversion of one of the other Models, you may make purchase payments into your static Model even after March 17, 2017.
Additionally, the same language has been added to the “Optional Guaranteed Principal Protection (‘GPP’)” section.
A marked copy of the supplement for ONcore Premier II has been included in this response as Exhibit A.
Please contact me at (513) 794-6278 should you have any questions.
| Sincerely, |
| /s/ Kimberly A. Plante |
| Kimberly A. Plante |
| Second Vice President and Counsel |
Ms. Hahn
December 20, 2016
Page 6 of 15
Exhibit A
The Ohio National Life Insurance Company
Ohio National Variable Account A
ONcore Premier II • ONcore Lite III • ONcore Flex II
Supplement dated December 30, 2016
to the Prospectuses dated May 1, 2016
The following supplements and amends the prospectuses dated May 1, 2016, as previously supplemented:
The following supplements “Optional Asset Allocation Models” in the prospectus.
Optional Asset Allocation Models
Important Information Concerning the Asset Allocation Models after March 2017
Ohio National Investments, Inc. (“ONII”), an affiliate of ours, has served as your investment adviser for the limited purpose of developing and updating the Asset Allocation Models. If you chose an Asset Allocation Model, ONII entered into an investment advisory agreement with you for this limited purpose. ONII’s role as investment adviser for development of and periodic updates to the Asset Allocation Models will terminate on March 31, 2017.
The Asset Allocation Models are designed to provide diversification among various investment classes and fund managers. Each Model offers a blend of equity and fixed investments, designed to fit different investment needs, by investing in a combination of the contract’s available Funds. ONII sets the makeup of each Model, allocating percentages to the underlying Funds. At the end of each quarter, variable account values allocated within each Model are rebalanced to maintain the mix of underlying Funds in the proportions established for each Model. Periodically, typically annually, ONII assesses the makeup of each of the Asset Allocation Models to determine if they continue to maintain the optimal level of investment return balanced against the designated risk tolerance for the model. If ONII determines changes to the Models are appropriate, it may change the underlying Funds in the Models or may change the percentage of the Models allocated to the underlying Funds. Please see Appendix C — Asset Allocation Models of your prospectus or contact us at 888.925.6446 or your registered representative for more detailed information on the Models, including the current makeup of the Models.
Managed Volatility Model
On and after March 3, 2017, the Managed Volatility Model will become “static” (meaning it will no longer undergo periodic updates).That means the Model will remain invested in the same underlying Funds and in the same percentages among the Funds over time, which may fail to optimize returns since underperforming Funds will not be replaced within the Model and the underlying percentages will not be updated.The investment advisory agreement you have previously entered into with ONII will terminate, and ONII will no longer make updates to the Managed Volatility Model. You will receive notice of the termination
Ms. Hahn
December 20, 2016
Page 7 of 15
of the investment advisory agreement and additional notice that the Managed Volatility Model is becoming static. The Model will remain invested in accordance with the most recent model allocation. Your variable account values allocated to the Managed Volatility Model will continue to rebalance quarterly.You will not be required to take any action if you wish to continue participating in the static model. However, if you have a rider that requires you to comply with investment restrictions and you make an additional purchase payment or wish to transfer out of the static model, you must comply with the investment restrictions for your rider in effect at the time of the payment or transfer. Please see “Investment Restrictions for Certain Optional Riders” below.
Other Asset Allocation Models
In March 2017, ONII will be updating the remaining Asset Allocation Models so that each Model will consist of a single fund-of-funds model portfolio that has a substantially similar investment objective.Each Model Portfolio, itself a Fund, will invest in multiple other funds of various asset classes to maintain the optimal level of investment return balanced against the risk tolerance for the Model. ONII will determine the initial composition of each Model Portfolio. Thereafter, an Asset Allocation Committee of ONII will manage the Model Portfolios, evaluating assets on a frequent basis and making changes to the investments of the Model Portfolios as deemed necessary. The Model Portfolios differ from the existing Models in that each Model Portfolio is a single Fund that actively invests in other funds, as opposed to an allocation of set percentages of Funds available in your contract. Additionally, the Model Portfolios will be evaluated on a more frequent basis. If you have values allocated to an existing Model, you will receive a prospectus for the corresponding Model Portfolio which will contain detailed information about the Model Portfolio once the conversion occurs.The following shows the updates to be made to the Models, including the anticipated timing:
| Existing Model | Makeup of New Model | Conversion Date | ||
Model 1 – Conservative | ON Conservative Model Portfolio | March 3, 2017 | ||
Model 2 – Moderately Conservative | ON Moderately Conservative Model Portfolio | March 3, 2017 | ||
Model 3 – Balanced | ON Balanced Model Portfolio | March 10, 2017 | ||
Model 4 – Moderate Growth | ON Moderate GrowthModelPortfolio | March 17, 2017 | ||
Model 5 – Growth | ON Growth Model Portfolio | March 3, 2017 | ||
You will not be required to take any action if you wish to participate in the update to the Models.
After the updates are complete, the investment advisory agreement you have previously entered into with ONII will terminate, and ONII will no longer make updates to the Asset Allocation Models. You will receive notice of the termination of the investment advisory agreement
Ms. Hahn
December 20, 2016
Page 8 of 15
and additional notice concerning the updates to the Models. If you choose to opt out of the update to your Model, your Model will become static. The Model will remain invested in accordance with the most recent model allocation. Your variable account values allocated to the Model will continue to rebalance quarterly.
If you have the GPP rider, you may remain invested in a static model and keep your rider. If you wish to transfer out of the static model, you must transfer into one of the Models available for the rider at the time of the payment or transfer. If you have any GLWB or GPP (2012), you may remain invested in a static model and keep your rider, unless you make an additional purchase payment. If you wish to make an additional purchase payment or you wish to transfer out of the static model, you must comply with the investment restrictions for your rider in effect at the time of the payment or transfer.
The following supplements “Investment Restrictions for Certain Optional Riders” in the prospectus.
Investment Restrictions for Certain Optional Riders
Beginning March 3, 2017, for any GLWB or GPP (2012) riders applied for on or after October 1, 2012, your purchase payments and Contract Value must be allocated in accordance with the restrictions specified below. The revised investment restrictions will apply to new purchases of one of these riders, future purchase payments and transfer requests. If you purchased one of these riders prior to March 3, 2017 and you do not make any additional purchase payments or transfer requests after the change in investment restrictions, the revised investment restrictions will not apply to you. The Fixed Accumulation Account is not an available investment option with any GLWB or GPP (2012). Your purchase payments and Contract Value must be allocated in compliance with the restrictions specified below:
| (1) | at least 50% must be allocated to investment options included in Category 1; provided, however, that you may not allocate more than 50% of your total purchase payments or Contract Value to any one investment option within Category 1; and |
| (2) | no more than 50% may be allocated to investment options included in Category 2; provided, however, that you may not allocate more than 25% of your total purchase payments or Contract Value to any one investment option within Category 2. |
The investment options available in each Category for any GLWB or GPP (2012) riders applied for on or after October 1, 2012 are:
INVESTMENT OPTIONS
| CATEGORY 1 | Ohio National Fund, Inc. Risk Managed Balanced Portfolio
AB Variable Product Series Fund, Inc. AB VPS Global Risk Allocation-Moderate Portfolio
Federated Insurance Series Federated Managed Tail Risk Fund II
Franklin Templeton Variable Insurance Products Trust Franklin VolSmart Allocation VIP Fund | Legg Mason Partners Variable Equity Trust QS Legg Mason Dynamic Multi-Strategy VIT Portfolio
Northern Lights Variable Trust TOPS® Managed Risk Balanced ETF Portfolio TOPS® Managed Risk Moderate Growth ETF Portfolio
PIMCO Variable Insurance Trust PIMCO Global Diversified Allocation Portfolio |
Ms. Hahn
December 20, 2016
Page 9 of 15
CATEGORY 2 | Ohio National Fund, Inc. Balanced Portfolio
AIM Variable Insurance Funds Invesco V.I. Balanced-Risk Allocation Fund
AB Variable Products Series Fund, Inc. AB VPS Dynamic Asset Allocation Portfolio
Federated Insurance Series Federated Managed Volatility Fund II | Fidelity® Variable Insurance Products Fund Fidelity® VIP Target Volatility Portfolio
Goldman Sachs Variable Insurance Trust Goldman Sachs Global Trends Allocation Fund
Janus Aspen Series INTECH U.S. Low Volatility Portfolio
Lazard Retirement Series Lazard Retirement Global Dynamic Multi Asset Portfolio
Northern Lights Variable Trust TOPS® Managed Risk Growth ETF Portfolio |
Beginning March 3, 2017, if you applied for the GLWB Plus, Joint GLWB Plus or GPP (2012) before October 1, 2012, your purchase payments and Contract Value must be allocated in accordance with the restrictions specified below. The revised investment restrictions will apply to future purchase payments and transfer requests. If you do not make any additional purchase payments or transfer requests after the change in investment restrictions, the revised investment restrictions will not apply to you. The Fixed Accumulation Account is not an available investment option with the GLWB Plus, Joint GLWB Plus or GPP (2012) applied for before October 1, 2012. Your purchase payments and Contract Value must be allocated in compliance with the restrictions specified below:
| (1) | at least 50% must be allocated to investment options included in Category 1; and |
| (2) | no more than 50% may be allocated to investment options included in Category 2. |
The investment options available in each Category if you applied for the GLWB Plus, Joint GLWB Plus or GPP (2012) before October 1, 2012 are:
INVESTMENT OPTIONS
| CATEGORY 1 | Legg Mason Partners Variable Equity Trust QS Legg Mason Dynamic Multi-Strategy VIT Portfolio
PIMCO Variable Insurance Trust PIMCO Global Diversified Allocation Portfolio | Northern Lights Variable Trust TOPS® Managed Risk Balanced ETF Portfolio TOPS® Managed Risk Moderate Growth ETF Portfolio TOPS® Managed Risk Growth ETF Portfolio | ||
| CATEGORY 2 | Ohio National Fund, Inc. Balanced Portfolio Risk Managed Balanced Portfolio
AIM Variable Insurance Funds (Invesco Variable Insurance Funds) Invesco V.I. Balanced-Risk Allocation Fund | Fidelity® Variable Insurance Products Fund Fidelity® VIP Target Volatility Portfolio
Franklin Templeton Variable Insurance Products Trust Franklin VolSmart Allocation VIP Fund
Goldman Sachs Variable Insurance Trust Goldman Sachs Global Trends Allocation Fund | ||
Ms. Hahn
December 20, 2016
Page 10 of 15
AB Variable Products Series Fund, Inc. AB VPS Dynamic Asset Allocation Portfolio AB VPS Global Risk Allocation-Moderate Portfolio
Federated Insurance Series Federated Managed Volatility Fund II Federated Managed Tail Risk Fund II | Janus Aspen Series INTECH U.S. Low Volatility Portfolio
Lazard Retirement Series Lazard Retirement Global Dynamic Multi Asset Portfolio |
Beginning March 3, 2017, if you selected the GLWB (2012), Joint GLWB (2012), GLWB (2011), Joint GLWB (2011), GLWB or Joint GLWB, your purchase payments and Contract Value must be allocated in accordance with the restrictions specified below. The revised investment restrictions will apply to future purchase payments and transfer requests. If you do not make any additional purchase payments or transfer requests after the change in investment restrictions, the new investment restrictions will not apply to you. The Fixed Accumulation Account is not an available investment option with the GLWB (2012), Joint GLWB (2012), GLWB (2011), Joint GLWB (2011), GLWB or Joint GLWB. Your purchase payments and Contract Value must be allocated in compliance withthe restrictions (1) or (2) specified below:
| (1) | 100% must be allocated to one of the following portfolios: ON Moderately Conservative Model Portfolio, ON Balanced Model Portfolio or ON Moderate Growth Model Portfolio. |
or
| (2) (a) | at least 30% must, but no more than 60% may, be allocated to investment options included in Category 1; |
(b) no more than 70% may be allocated to investment options included in Category 2;
(c) no more than 25% may be allocated to investment options included in Category 3; and
(d) no more than 15% may be allocated to investment options included in Category 4.
Ms. Hahn
December 20, 2016
Page 11 of 15
The investment options available for the GLWB (2012), Joint GLWB (2012), GLWB (2011), Joint GLWB (2011), GLWB or Joint GLWB in each Category are:
INVESTMENT OPTIONS
| CATEGORY 1 | Ohio National Fund, Inc. Bond Portfolio
Fidelity® Variable Insurance Products Fund Fidelity® VIP Government Money Market Portfolio
Janus Aspen Series Flexible Bond Portfolio
Legg Mason Partners Variable Income Trust Western Asset Core Plus VIT Portfolio | PIMCO Variable Insurance Trust PIMCO Real Return Portfolio PIMCO Total Return Portfolio PIMCO Short-Term Portfolio PIMCO Low Duration Portfolio
The Universal Institutional Funds, Inc. Morgan Stanley UIF Core Plus Fixed Income Portfolio |
Ms. Hahn
December 20, 2016
Page 12 of 15
| CATEGORY 2 | Ohio National Fund, Inc. Equity Portfolio Omni Portfolio S&P 500® Index Portfolio Strategic Value Portfolio Nasdaq-100® Index Portfolio Bristol Portfolio Bristol Growth Portfolio Balanced Portfolio
Risk Managed Balanced Portfolio AIM Variable Insurance Funds Invesco V.I. Balanced-Risk Allocation Fund AB Variable Products Series Fund, Inc. AB VPS Dynamic Asset Allocation Portfolio AB VPS Global Risk Allocation-Moderate Portfolio AB VPS Growth & Income Portfolio Dreyfus Variable Investment Fund Appreciation Portfolio Federated Insurance Series Federated Managed Volatility Fund II Federated Managed Tail Risk Fund II Fidelity® Variable Insurance Products Fidelity® VIP Contrafund® Portfolio Fidelity® VIP Growth Portfolio Fidelity® VIP Equity-Income Portfolio Fidelity® VIP Target Volatility Portfolio Franklin Templeton Variable Insurance Products Trust Franklin Income VIP Fund Franklin Flex Cap Growth VIP Fund Franklin Founding Funds Allocation VIP Fund Templeton Foreign VIP Fund Franklin VolSmart Allocation VIP Fund | Goldman Sachs Variable Insurance Trust Goldman Sachs Large Cap Value Fund Goldman Sachs U.S. Equity Insights Fund Goldman Sachs Strategic Growth Fund Goldman Sachs Global Trends Allocation Fund Ivy Variable Insurance Portfolios Ivy VIP Asset Strategy Janus Aspen Series Janus Portfolio Balanced Portfolio INTECH U.S. Low Volatility Portfolio Lazard Retirement Series Lazard Retirement U.S. Strategic Equity Portfolio Lazard Retirement Global Dynamic Multi Asset Portfolio Legg Mason Partners Variable Equity Trust ClearBridge Variable Dividend Strategy Portfolio ClearBridge Variable Large Cap Value Portfolio QS Legg Mason Dynamic Multi-Strategy VIT Portfolio MFS® Variable Insurance Trust MFS® Total Return Series MFS® Variable Insurance Trust II MFS® Massachusetts Investors Growth Stock Portfolio Northern Lights Variable Trust TOPS® Managed Risk Balanced ETF Portfolio TOPS® Managed Risk Moderate Growth ETF Portfolio TOPS® Managed Risk Growth ETF Portfolio PIMCO Variable Insurance Trust PIMCO Global Bond Portfolio (Unhedged) PIMCO Global Diversified Allocation Portfolio The Prudential Series Fund, Inc. Jennison Portfolio Jennison 20/20 Focus Portfolio The Universal Institutional Funds, Inc. Morgan Stanley UIF Growth Portfolio |
Ms. Hahn
December 20, 2016
Page 13 of 15
| CATEGORY 3 | Ohio National Fund, Inc. International Portfolio Aggressive Growth Portfolio High Income Bond Portfolio Capital Appreciation Portfolio Mid Cap Opportunity Portfolio AIM Variable Insurance Funds Invesco V.I. International Growth Fund Federated Insurance Series Federated Kaufmann Fund II Fidelity® Variable Insurance Products Fidelity® VIP Mid Cap Portfolio | JPMorgan Insurance Trust JPMorgan Insurance Trust Mid Cap Value Portfolio Janus Aspen Series Overseas Portfolio Global Research Portfolio Lazard Retirement Series Lazard Retirement International Equity Portfolio MFS® Variable Insurance Trust MFS® Mid Cap Growth Series Neuberger Berman Advisers Management Trust AMT Mid Cap Intrinsic Value Portfolio | ||
| CATEGORY 4 | Ohio National Fund, Inc. International Small-Mid Company Portfolio ClearBridge Small Cap Portfolio Small Cap Growth Portfolio Bryton Growth Portfolio AB Variable Products Series Fund, Inc. AB VPS Small Cap Growth Portfolio Fidelity® Variable Insurance Products Fidelity® VIP Real Estate Portfolio Ivy Variable Insurance Portfolios Ivy VIP Global Natural Resources Ivy VIP Science and Technology JPMorgan Insurance Trust JPMorgan Insurance Trust Small Cap Core Portfolio | Lazard Retirement Series Lazard Retirement U.S. Small-Mid Cap Equity Portfolio Lazard Retirement Emerging Markets Equity Portfolio MFS® Variable Insurance Trust MFS® New Discovery Series PIMCO Variable Insurance Trust PIMCO CommodityRealReturn® Strategy Portfolio Royce Capital Fund Royce Micro-Cap Portfolio Royce Small-Cap Portfolio The Universal Institutional Funds, Inc. Morgan Stanley UIF U.S. Real Estate Portfolio | ||
The following supplements “Optional Guaranteed Lifetime Withdrawal Benefit (‘GLWB’) Riders” in the prospectus.
GLWB Preferred I.S.
Investment Restrictions.
Effective March 3, 2017, in order to have the GLWB Preferred I.S. rider, you must allocate your purchase payments and Contract Value in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” If you purchased the GLWB Preferred I.S. rider prior to March 3, 2017, these revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GLWB Preferred I.S. rider will be terminated if If you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GLWB Preferred I.S. rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
Ms. Hahn
December 20, 2016
Page 14 of 15
GLWB (2012) and GLWB Plus
Investment Restrictions.
Effective March 3, 2017, in order to have the GLWB (2012) rider, you must allocate any variable account portion of your purchase payments and Contract Value to (a) one of ON Moderately Conservative Model Portfolio, ON Balanced Model Portfolio or ON Moderate Growth Model Portfolio or (b) in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” These revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GLWB (2012) rider will be terminated ifIf you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GLWB (2012) rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
Effective March 3, 2017, in order to have the GLWB Plus rider, you must allocate your purchase payments and Contract Value in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” If you purchased the GLWB Plus rider prior to March 3, 2017, these revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GLWB Plus will be terminated ifIf you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GLWB Plus rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
GLWB (2011)
Investment Restrictions.
Effective March 3, 2017, in order to have the GLWB (2011) rider, you must allocate your purchase payments and Contract Value to (a) one of ON Moderately Conservative Model Portfolio, ON Balanced Model Portfolio or ON Moderate Growth Model Portfolio or (b) in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” These revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GLWB (2011) rider will be terminated ifIf you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GLWB (2011) rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
Ms. Hahn
December 20, 2016
Page 15 of 15
Other GLWB Versions
Investment Restrictions.
Effective March 3, 2017, in order to have the GLWB rider, you must allocate any variable account portion of your purchase payments and Contract Value to (a) one of ON Moderately Conservative Model Portfolio, ON Balanced Model Portfolio or ON Moderate Growth Model Portfolio or (b) in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” These revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GLWB rider will be terminated ifIf you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GLWB rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
The following supplements “Optional Guaranteed Principal Protection (‘GPP’)” in the prospectus.
In order to have the GPP rider, you must allocate your variable account values to a Model. In addition to pre-existing Models, effective March 3, 2017, the Models eligible for this rider include: ON Conservative Model Portfolio, ON Moderately Conservative Model Portfolio, ON Balanced Model Portfolio, ON Moderate Growth Model Portfolio and ON Growth Model Portfolio. Any transfer requests after March 3, 2017, must be to one of these Model portfolios. You may make purchase payments into your existing Model prior to March 17, 2017. Effective March 17, 2017, unless you are in a static Model, if you make additional purchase payments, you must allocate your variable account values to one of the Model portfolios listed above.If (i) your variable account values were allocated to a static Model prior to March 17, 2017, (ii) your account values were allocated to the Managed Volatility Model, or (iii) you opted out of the conversion of one of the other Models, you may make purchase payments into your static Model even after March 17, 2017.You may only be in one Model at a time with the GPP rider.The GPP rider will be terminated ifIf you cease to be invested in a Model, we will cancel your GPP rider.
Effective March 3, 2017, in order to have the GPP (2012) rider, you must allocate your purchase payments and Contract Value in accordance with the Fund Category requirements described in “Investment Restrictions for Certain Optional Riders.” If you purchased the GPP (2012) rider prior to March 3, 2017, these revised requirements will only apply to you if you make additional purchase payments or transfer requests. You may not allocate purchase payments or Contract Value to the Fixed Accumulation Account. You may allocate purchase payments to the Enhanced DCA account and transfer amounts in accordance with the investment restrictions.The GPP (2012) rider will be terminated ifIf you cease to comply with the requirements described in “Investment Restrictions for Certain Optional Riders.”,” we will cancel your GPP (2012) rider. If the rider is soterminatedcanceled, a prorated annual rider charge will be assessed.
