December 5, 2023
Mark Cowan
Senior Counsel\Disclosure Review and Accounting Office
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E. (Mail Stop 5-6)
Washington, D.C. 20549
RE: | RiverSource Life of New York Account 8 (“Registrant”) |
RiverSource Life Insurance Co. of NY (“Company”)
Post-Effective Amendment No. 12 on Form N-6
File Nos. 333-227507 / 811-05213
RiverSource Variable Universal Life 6 Insurance
Dear Mr. Cowan:
On behalf of RiverSource Life Insurance Co. of NY (the “Company”), we are responding to the comments of the Securities and Exchange Commission provided to us on December 1, 2023, with regard to the Registration Statement referenced above. Along with this letter, we are filing the revised supplement, which reflects conforming edits.
Comments and responses are outlined below.
Comment: If changes in this supplement apply only to new investors, in the introductory paragraph, change “your current variable insurance product statutory and initial summary prospectus” to “the current variable insurance product statutory and initial summary prospectus.”
Response: Revised as requested.
Comment: Please clarify, under I., that the Cost of Insurance and Administrative Charges apply to policies with an application date on or after 1/13/2024 and add that all other Policy fees and charges are as stated in the Fee Table.
Response: Revised as requested.
Comment: If all changes are applicable to policies issued on or after 1/13/2024, the supplement should include only changes for policies issued on or after 1/13/2024 and all references to policies with application dates before 1/13/2024 removed. The supplement should be delivered just to new investors.
Response: Revised as requested.
1
Comment: Under II. Funds available under policy, all items referring to existing investors should be removed.
Response: Revised as requested.
Comment: Please clarify if all listed funds are available fund offerings for new policies on or after 1/13/24 or just additional ones. To avoid confusion and for purposes of clarity as to what funds will be available after 1/13/2024, the table below should list all funds available after 1/13/2024.
Response: The table has been revised to include all funds available for policies with applications dated on or after 1/13/2024.
Comment: Please include in the supplement any changes in the KIT or Annual Portfolio Company Expenses Minimum Maximum table, if any of the fund lineup changes affect those disclosures.
Response: The KIT and Annual Portfolio Company Expenses Minimum and Maximum Table have been revised and added to the supplement to reflect the fund lineup changes.
If you have any questions concerning responses to the comments, please contact me at (612) 678-5337.
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Sincerely, |
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/s/ Nicole D. Wood |
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Nicole D. Wood |
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Assistant General Counsel and |
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Assistant Secretary |
2
Supplement dated December XX, 2023 to Statutory Prospectus and initial Summary Prospectus dated April 26, 2023 |
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RiverSource® Variable Universal Life 6 Insurance | PRO9089_12_B01_(05/23) ISP9089_12_B01_(05/23) |
The information in this supplement updates and amends certain information contained in the current variable life insurance product statutory and initial summary prospectus (together, the “prospectus”). Please read it carefully and keep it with your variable life insurance product prospectus for future reference. Except as modified in this supplement, all other terms and information contained in the prospectus remain in effect and unchanged. The terms we use in this supplement have the same meaning as in the prospectus.
I. Effective 1/13/2024, the Cost of Insurance Charge and Administrative Charge descriptions in the “Fee Table – Periodic Charges Other than Annual Fund Expenses” are deleted and replaced with the following information, for policies with application dates on or after 1/13/2024. All other policy fees and charges are as stated in the Fee Table.
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Cost of Insurance Charge(a) For policies with application dates on or after 1/13/2024. | | Monthly rate per $1,000 of Net Amount at Risk: |
Minimum: $0.005 — Female, Standard Nontobacco, Insurance Age 0, Duration 5. |
Maximum: $57.6325 – Male, Standard Tobacco, Insurance Age 85, Duration 28. |
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Representative Insureds: $0.0125 – Female, $500,000 Specified Amount, Super Preferred Nontobacco, Insurance Age 40, Duration 1. |
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Administrative Charge(a) For policies with application dates on or after 1/13/2024. | | Monthly Rate per $1,000 of initial Specified Amount: |
Minimum: $0.098 — Female, Standard Nontobacco, Insurance Age 0, Duration 1. |
Maximum: $2.979 — Male, Standard Tobacco, Insurance Age 85, Duration 1. |
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Representative Insured: $0.148 Female, Super Preferred Nontobacco, Insurance Age 40, Duration 1. |
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(a) This charge varies based on individual characteristics. The charges shown in the table may not be representative of the charge you will pay. For information about the charge you would pay, contact your sales representative or RiverSource Life of NY at the address or telephone number shown on the first page of this prospectus.
II. For policies with application dates on or after 1/13/2024, Ongoing fees and Expenses in the Key Information Table – Information You Should Consider About the Policy, is deleted and replaced in its entirety with the following:
Key Information Table
Important Information You Should Consider About the Policy
| | Location in Statutory Prospectus |
Ongoing Fees and Expenses (annual charges) | In addition to surrender charges and transaction charges, an investment in the policy is subject to certain ongoing fees and expenses, including fees and expenses covering the cost of insurance under the policy and the cost of the following riders if elected as optional benefits available under the policy: Accounting Value Increase Rider, Accidental Death Benefit Rider, Children's Insurance Rider, Waiver of Monthly Deduction Rider, Waiver of Premium Rider and the AdvanceSource Accelerated Benefit for CI if they are elected as optional benefits available under the policy. Such fees and expenses are set based on various factors such as the Insured’s Risk Classification, Insurance Age, sex and the number of years the policy is in force. You should review the rates, fees and charges under the Policy Data page of your policy. You will also bear expenses associated with the Funds offered under the policy, as shown in the following table: | Fee Tables Transaction Fees Base Policy Charges |
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Underlying Fund options (Funds fees and expenses)(1) | | |
(1) As a percentage of Fund assets. |
III. For policies with application dates on or after 1/13/2024, Total Annual Operating Expenses of the Funds in the Fee Tables section of the prospectus is deleted and replaced in its entirety with the following:
Total Annual Operating Expenses of the Funds
The next table provides the minimum and maximum total operating expenses charged by the underlying Funds(1) that you may pay periodically during the time that you own the policy. A complete list of Funds available under the policy, including their annual expenses, may be found in Appendix A: Funds Available Under the Policy.
Total Annual Fund Expenses | | |
(expenses deducted from the Fund assets, including management fees and other expenses) | | |
(1)
Total annual Fund operating expenses are deducted from amounts that are allocated to the Fund. They include management fees and other expenses. Other expenses may include service fees that may be used to compensate service providers, including us and our affiliates, for administrative and contract owner services provided on behalf of the Fund. The amount of these payments will vary by Fund and may be significant. See “The Variable Account and the Funds” for additional information, including potential conflicts of interest these payments may create. For a more complete description of each Fund’s fees and expenses and important disclosure regarding payments the Fund and/or its affiliates make, please review the Fund’s prospectus and SAI.
IV. Funds available under the policy.
For policies with application dates on or after 1/13/2024, the Section in the prospectus titled “Appendix A: Funds Available Under the Contract” is replaced with the following.
Appendix A: Funds Available Under the Contract
The following is a list of funds available under the contract. More information about the funds is available in the prospectuses for the funds, which may be amended from time to time and can be found online at riversource.com/insurance. You can also request this information at no cost by calling 1-800-862-7919 or by sending an email request to riversourceannuityservice@ampf.com.
The current expenses and performance information below reflects fee and expenses of the funds, but do not reflect the other fees and expenses that your contract may charge. Expenses would be higher and performance would be lower if these other charges were included. Each fund’s past performance is not necessarily an indication of future performance.
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks long-term growth of capital | AB VPS Large Cap Growth Portfolio (Class A) AllianceBernstein L.P. | | | | |
Seeks long-term capital appreciation. | Allspring VT Small Cap Growth Fund - Class 1 Allspring Funds Management, LLC, adviser; Allspring Global Investments, LLC, sub-adviser. | | | | |
The Portfolio seeks investment results that correspond (before fees and expenses) generally to the price and yield performance of its underlying index, the Alerian Midstream Energy Select Index (the "Index"). | ALPS | Alerian Energy Infrastructure Portfolio: Class I ALPS Advisors, Inc. | | | | |
Seeks long-term capital growth. Income is a secondary objective. | American Century VP Mid Cap Value, Class I American Century Investment Management, Inc. | | | | |
Seeks long-term capital growth. Income is a secondary objective. | American Century VP Value, Class I American Century Investment Management, Inc. | | | | |
Seeks high total investment return. | BlackRock Global Allocation V.I. Fund (Class I) BlackRock Advisors, LLC, adviser; BlackRock (Singapore) Limited, sub-adviser. | | | | |
Seeks investment results that correspond to the total return performance of common stocks as represented by the MSCI EAFE Index. | Calvert VP EAFE International Index Portfolio - Class I Calvert Research and Management | | | | |
Seeks investment results that correspond to the investment performance of U.S. common stocks, as represented by the NASDAQ 100 Index. | Calvert VP Nasdaq 100 Index Portfolio - Class I Calvert Research and Management, adviser; Ameritas Investment Partners, Inc, subadviser. | | | | |
Seeks investment results that correspond to the investment performance of U.S. common stocks, as represented by the Russell 2000® Index. | Calvert VP Russell 2000® Small Cap Index Portfolio - Class I Calvert Research and Management, adviser; Ameritas Investment Partners, Inc, subadviser. | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks to achieve a competitive total return through an actively managed portfolio of stocks, bonds and money market instruments which offer income and capital growth opportunity. | Calvert VP SRI Balanced Portfolio - Class I Calvert Research and Management | | | | |
Seeks maximum total investment return through a combination of capital growth and current income. | Columbia Variable Portfolio - Balanced Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with total return. | Columbia Variable Portfolio - Commodity Strategy Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks total return, consisting of long-term capital appreciation and current income. | Columbia Variable Portfolio - Contrarian Core Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with capital appreciation. | Columbia Variable Portfolio - Disciplined Core Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a high level of current income and, as a secondary objective, steady growth of capital. | Columbia Variable Portfolio - Dividend Opportunity Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Non-diversified fund that seeks to provide shareholders with high total return through current income and, secondarily, through capital appreciation. | Columbia Variable Portfolio - Emerging Markets Bond Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term capital growth. | Columbia Variable Portfolio - Emerging Markets Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with high total return through income and growth of capital. | Columbia Variable Portfolio - Global Strategic Income Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks to provide shareholders with maximum current income consistent with liquidity and stability of principal. | Columbia Variable Portfolio - Government Money Market Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with high current income as its primary objective and, as its secondary objective, capital growth. | Columbia Variable Portfolio - High Yield Bond Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a high total return through current income and capital appreciation. | Columbia Variable Portfolio - Income Opportunities Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a high level of current income while attempting to conserve the value of the investment for the longest period of time. | Columbia Variable Portfolio - Intermediate Bond Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term capital growth. | Columbia Variable Portfolio - Large Cap Growth Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term capital appreciation. | Columbia Variable Portfolio - Large Cap Index Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a level of current income consistent with preservation of capital. | Columbia Variable Portfolio - Limited Duration Credit Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks total return, consisting of current income and capital appreciation. | Columbia Variable Portfolio - Long Government/Credit Bond Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with capital appreciation. | Columbia Variable Portfolio - Overseas Core Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term growth of capital. | Columbia Variable Portfolio - Select Large Cap Value Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks to provide shareholders with growth of capital. | Columbia Variable Portfolio - Select Mid Cap Growth Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term growth of capital. | Columbia Variable Portfolio - Select Mid Cap Value Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term capital growth. | Columbia Variable Portfolio - Select Small Cap Value Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with long-term capital appreciation. | Columbia Variable Portfolio - Seligman Global Technology Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks total return, consisting of current income and capital appreciation. | Columbia Variable Portfolio - Strategic Income Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with current income as its primary objective and, as its secondary objective, preservation of capital. | Columbia Variable Portfolio - U.S. Government Mortgage Fund (Class 1) Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a high level of current income. | CTIVP® - American Century Diversified Bond Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; American Century Investment Management, Inc., subadviser. | | | | |
Non-diversified fund that seeks to provide shareholders with total return that exceeds the rate of inflation over the long term. | CTIVP® - BlackRock Global Inflation-Protected Securities Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; BlackRock Financial Management, Inc., subadviser; BlackRock International Limited, sub-subadviser. | | | | |
Seeks to provide shareholders with current income and capital appreciation. | CTIVP® - CenterSquare Real Estate Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; CenterSquare Investment Management LLC, subadviser. | | | | |
Seeks to provide shareholders with long-term capital growth. | CTIVP® - MFS® Value Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Massachusetts Financial Services Company, subadviser. | | | | |
Seeks to provide shareholders with long-term capital growth. | CTIVP® - Morgan Stanley Advantage Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Morgan Stanley Investment Management Inc., subadviser. | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks to provide shareholders with long-term capital growth. | CTIVP® - Principal Blue Chip Growth Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Principal Global Investors, LLC, subadviser. | | | | |
Seeks to provide shareholders with long-term growth of capital and income. | CTIVP® - T. Rowe Price Large Cap Value Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; T. Rowe Price Associates, Inc., subadviser. | | | | |
Seeks to provide shareholders with total return through current income and capital appreciation. | CTIVP® - TCW Core Plus Bond Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; TCW Investment Management Company LLC, subadviser. | | | | |
Seeks to provide shareholders with long-term growth of capital. | CTIVP® - Victory Sycamore Established Value Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Victory Capital Management Inc., subadviser. | | | | |
Seeks to provide shareholders with long-term capital growth. | CTIVP® - Westfield Mid Cap Growth Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Westfield Capital Management Company, L.P., subadviser. | | | | |
Seeks to provide total return. | Delaware Ivy VIP Asset Strategy, Class I Delaware Management Company | | | | |
Seeks long-term capital growth. | Delaware VIP® International Series - Standard Class Delaware Management Company, adviser; Macquarie Funds Management HK Ltd., Macquarie Investment Management Global Limited, subadvisers. | | | | |
Seeks capital appreciation. | DWS Alternative Asset Allocation VIP, DWS Investment Management Americas Inc., adviser; RREEF America L.L.C., subadvisor. | | | | |
Seeks high level of current income. | Eaton Vance VT Floating-Rate Income Fund - Institutional Class Eaton Vance Management | | | | |
Seeks long-term capital appreciation. | Fidelity® VIP Contrafund® Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, subadvisers. | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks capital appreciation. | Fidelity® VIP Emerging Markets Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, FIL Investment Advisers, FIL Investment Advisers (UK) Limited and FIL Investments (Japan) Limited, subadvisers. | | | | |
Seeks capital appreciation. | Fidelity® VIP Energy Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, subadvisers. | | | | |
Seeks to provide capital growth. | Fidelity® VIP Growth Opportunities Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, subadvisers. | | | | |
Seeks as high level of current income as is consistent with the preservation of capital. | Fidelity® VIP Investment Grade Bond Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, subadvisers. | | | | |
Seeks long-term growth of capital. | Fidelity® VIP Mid Cap Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, subadvisers. | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks a high level of current income and may also seek capital appreciation. | Fidelity® VIP Strategic Income Portfolio Initial Class Fidelity Management & Research Company (the Adviser) is the fund’s manager. Fidelity Management & Research Company (UK) Limited, Fidelity Management & Research Company (Hong Kong) Limited, Fidelity Management & Research Company (Japan) Limited, FIL Investment Advisers, FIL Investment Advisers (UK) Limited and FIL Investments (Japan) Limited, subadvisers. | | | | |
Seeks to maximize income while maintaining prospects for capital appreciation. Under normal market conditions, the fund invests in a diversified portfolio of equity and debt securities. | Franklin Income VIP Fund - Class 1 Franklin Advisers, Inc. | | | | |
Seeks long-term total return. Under normal market conditions, the fund invests at least 80% of its net assets in investments of small capitalization companies. | Franklin Small Cap Value VIP Fund - Class 1 Franklin Mutual Advisers, LLC | | | | |
Seeks total return with a low to moderate correlation to traditional financial market indices. | Invesco V.I. Balanced-Risk Allocation Fund, Series I Shares Invesco Advisers, Inc. | | | | |
Seeks capital appreciation. | Invesco V.I. Main Street Small Cap Fund®, Series I Shares Invesco Advisers, Inc. | | | | |
Seeks long-term growth of capital. | Invesco V.I. Technology Fund, Series I Shares Invesco Advisers, Inc. | | | | |
Seeks long-term capital growth, consistent with preservation of capital and balanced by current income. | Janus Henderson VIT Balanced Portfolio: Institutional Shares Janus Henderson Investors US LLC | | | | |
Seeks to obtain maximum total return, consistent with preservation of capital. | Janus Henderson VIT Flexible Bond Portfolio: Institutional Shares Janus Henderson Investors US LLC | | | | |
Seeks high current income and the opportunity for capital appreciation to produce a high total return. | Lord Abbett Series Fund Bond Debenture Portfolio - Class VC Lord, Abbett & Co LLC | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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| MFS® Global Real Estate Portfolio - Initial Class Massachusetts Financial Services Company | | | | |
Seeks capital appreciation. | MFS® International Growth Portfolio - Initial Class Massachusetts Financial Services Company | | | | |
| MFS® Utilities Series - Initial Class Massachusetts Financial Services Company | | | | |
Seeks maximum total return, consistent with preservation of capital and prudent investment management. | PIMCO VIT Total Return Portfolio, Institutional Class Pacific Investment Management Company LLC (PIMCO) | | | | |
Seeks to provide shareholders with long-term capital appreciation. | Putnam VT Global Health Care Fund - Class IA Shares Putnam Investment Management, LLC. Though the investment advisor has retained the services of both Putnam Investments Limited (PIL) and the Putnam Advisory Company, LLC (PAC), PIL and PAC do not currently manage any assets of the fund. | | | | |
Seeks capital growth. Current income is a secondary objective. | Putnam VT International Value Fund - Class IA Shares Putnam Investment Management, LLC, investment advisor. Though the investment advisor has retained the services of both Putnam Investments Limited (PIL) and The Putnam Advisory Company, LLC (PAC), PIL and PAC do not currently manage any assets of the fund. | | | | |
Seeks capital growth and current income. | Putnam VT Large Cap Value Fund - Class IA Shares Putnam Investment Management, LLC, investment advisor. Though the investment advisor has retained the services of Putnam Investments Limited (PIL), PIL does not currently manage any assets. | | | | |
Seeks to provide a high level of total return that is consistent with an aggressive level of risk. | Variable Portfolio - Aggressive Portfolio Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide a high level of total return that is consistent with a conservative level of risk. | Variable Portfolio - Conservative Portfolio Columbia Management Investment Advisers, LLC | | | | |
Pursues total return while seeking to manage the Fund's exposure to equity market volatility. | Variable Portfolio - Managed Volatility Growth Columbia Management Investment Advisers, LLC | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Pursues total return while seeking to manage the Fund's exposure to equity market volatility. | Variable Portfolio - Managed Volatility Moderate Growth Fund (Class 1)2,3 Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide a high level of total return that is consistent with a moderate level of risk. | Variable Portfolio - Moderate Portfolio Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide a high level of total return that is consistent with a moderately aggressive level of risk. | Variable Portfolio - Moderately Aggressive Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide a high level of total return that is consistent with a moderately conservative level of risk. | Variable Portfolio - Moderately Conservative Columbia Management Investment Advisers, LLC | | | | |
Seeks to provide shareholders with a high level of current income while conserving the value of the investment for the longest period of time. | Variable Portfolio - Partners Core Bond Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; J.P. Morgan Investment Management Inc. and Allspring Global Investments, LLC, subadvisers. | | | | |
Seeks to provide shareholders with long-term capital growth. | Variable Portfolio - Partners Core Equity Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; J.P. Morgan Investment Management Inc. and T. Rowe Price Associates, Inc., subadvisers. | | | | |
Seeks to provide shareholders with long-term growth of capital. | Variable Portfolio - Partners International Core Equity Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Schroder Investment Management North America Inc., subadviser; Schroder Investment Management North America Limited, sub-subadviser. | | | | |
Seeks to provide shareholders with long-term capital growth. | Variable Portfolio - Partners International Growth Fund (Class 1) Columbia Management Investment Advisers LLC, adviser; William Blair Investment Management, LLC and Walter Scott & Partners Limited, subadvisers. | | | | |
Seeks to provide shareholders with long-term capital growth. | Variable Portfolio - Partners International Value Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Pzena Investment Management, LLC and Thompson, Siegel & Walmsley LLC, subadvisers. | | | | |
| Fund and Adviser/Sub-Adviser | Current Expenses Ratio [NET] | Average Annual Total Returns (as of 12/31/2022) |
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Seeks to provide shareholders with long-term capital growth. | Variable Portfolio - Partners Small Cap Growth Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Scout Investments, Inc. and Allspring Global Investments, LLC, subadvisers. | | | | |
Seeks to provide shareholders with long-term capital appreciation. | Variable Portfolio - Partners Small Cap Value Fund (Class 1) Columbia Management Investment Advisers, LLC, adviser; Segall Bryant & Hamill, LLC and William Blair Investment Management, LLC, subadvisers. | | | | |
Pursues total return while seeking to manage the Fund's exposure to equity market volatility. | Variable Portfolio - U.S. Flexible Growth Fund Columbia Management Investment Advisers, LLC | | | | |
Pursues total return while seeking to manage the Fund's exposure to equity market volatility. | Variable Portfolio - U.S. Flexible Moderate Columbia Management Investment Advisers, LLC | | | | |
Seeks to maximize total return. | Western Asset Variable Global High Yield Bond Portfolio - Class I Legg Mason Partners Fund Adviser, LLC; Western Asset Management Company, LLC, Western Asset Management Company Limited & Western Asset Management Pte. Ltd., sub-advisors. | | | | |
1
This Fund and its investment adviser and/or affiliates have entered into a temporary expense reimbursement arrangement and/or fee waiver. The Fund’s annual expenses reflect temporary fee reductions. Please see the Fund’s prospectus for additional information.
2
This Fund is a fund of funds and invests substantially all of its assets in other underlying funds. Because the Fund invests in other funds, it will bear its pro rata portion of the operating expenses of those underlying funds, including management fees.
3
This Fund is managed in a way that is intended to minimize volatility of returns. See “Principal Risks of Investing in the Contract.”
THIS SUPPLEMENT SHOULD BE READ AND RETAINED FOR FUTURE REFERENCE.
SUP9089-0001_(01/24)