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Christopher J. Madin Vice President and Corporate Counsel
The Prudential Insurance Company of America 280 Trumbull Street Hartford, CT 06103 Tel 860-534-6087 christopher.madin@prudential.com
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June 5, 2020
Alberto H. Zapata, Esq.
Senior Counsel
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
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Re: | Pruco Life Variable Universal Account |
Pruco Life of New Jersey Variable Appreciable Account
Pruco Life Insurance Company
Pruco Life Insurance Company of New Jersey
Initial Registration Statements on Form N-6
File Nos. 333-237296, 333-237297
Dear Mr. Zapata:
The purpose of this correspondence is to respond to Staff comments received on May 19, 2020. The Staff’s comments (with specific page number references) relate to the prospectus that was filed on March 20, 2020, for Pruco Life Insurance Company’s PruLife® SVUL Protector® N-6 registration statement (File No. 333-237297). We are responding to these comments with the understanding that the same comments and responses apply to corresponding portions of the registration statement under file number 333-237296, filed on the same date by Pruco Life Insurance Company of New Jersey.
Upon satisfaction of our revisions and/or further comment, we plan to file pre-effective amendments for the N-6 registration statements that will include revised disclosures, required exhibits, company and separate account financial statements, and a letter requesting acceleration of the effective date of these registration statements.
Our target effective date for these registrations is June 30, 2020. If the Staff has any further comments, we would appreciate if those could be provided by Monday, June 15, 2020.
The Staff’s comments and our responses are below.
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1. | Summary of the Contract and Contract Benefits (p. 1) |
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a. | Death Benefit Protection. Please correct the typographical error in the following sentence: “The Rider to Provide Lapse Protection can protect your Contract starting in the 11st Contract year.” |
Response: This error has been corrected, as follows:
The Rider to Provide Lapse Protection can protect your Contract starting in the 11th Contract Year.
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b. | Surrendering the Contract. Please consider adding a surrender charge schedule or provide a cross-reference to a schedule. |
Response: The Company has updated this section to refer specifically to a surrender charge, as follows:
Surrendering the Contract - A Contract may be surrendered for its Cash Surrender Value while at least one insured is living. A surrender charge may apply.
Several of the other items listed in the Summary of the Contract and Contract Benefits also state that charges may or will apply, and in order to keep this summary concise and readable we do not describe the charges for Riders, Loans, Withdrawals, or Surrenders here. The Summary of Charges and Expenses on the following page provides a table of all charges, including the Surrender charge, and the preamble to the Summary sections points investors here by noting that additional detail can be found in “subsequent sections of the prospectus”. The section “Charges and Expenses” also has a subsection called “Surrender Charge” that provides a table and a more detailed description of this charge. We feel that adding charge information for each of the items listed in this summary would be redundant and unnecessarily lengthy, and adding charge information only for Surrendering the Contract could be confusing to policyholders.
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2. | Summary of Contract Risks (p. 2) |
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a. | Surrender of the Contract. Please provide a surrender charge schedule or provide a cross-reference to a schedule. |
Response: As noted in the previous response, the preamble to the Summary sections points policyholders to subsequent sections of the prospectus for detailed information on the items discussed in the Summaries. We have chosen not to discuss specific charges or costs that may be associated with the various items discussed in this summary (including but not limited to changes in Contract Values, Increases in Charges, Risk of Contract Lapse, Withdrawals, Contract Loans, and Surrenders) because the emphasis of this section is to provide a general overview of the types of risks of which investors should be aware. Correspondingly, the Summary of Charges on the next page and the Charges and Expenses sections both provide detailed information on the charges and costs that may be associated with all of the items in the Summary of Contract Risks. We feel that adding specific references to the charges associated with some or all of these items would be redundant and unnecessarily lengthy, or confusing.
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b. | The prospectus states that insurance benefits, including the Death Benefit, and all guarantees, including those related to the Fixed Rate Option, are general account obligations that are subject to the financial strength and claims paying ability of Pruco Life. Given the significant market events that have occurred as a result of the COVID-19 pandemic since these registration statements were filed, please consider whether this disclosure should be revised based on how these events could affect the Pruco Life’s financial strength and claims-paying ability, including the ability to timely process claims. If Pruco Life believes that no additional disclosure is warranted, please explain supplementally why such disclosure is not necessary. |
Response: The Company has updated its Statement of Additional Information to provide additional disclosures with respect to COVID-19 and other matters under the section entitled Cyber Security and Business Continuity Risks, as follows:
The Company is also subject to risks related to disasters and other events, such as storms, earthquakes, fires, outbreaks of infectious diseases (such as COVID-19), utility failures, terrorist acts, political and social developments, and military and governmental actions. These risks are often collectively referred to as “business continuity” risks. These events could adversely affect the Company and our ability to conduct business and process transactions. Although the Company has business continuity plans, it is possible that the plans may not operate as intended or required and that the Company may not be able to provide required services, process transactions, deliver documents or calculate values. It is also possible that service levels may decline as a result of such events.
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3. | Summary of Charges and Expenses (p. 2) |
Please confirm that the representative insureds noted in the fee tables represent the age or classification with the greatest number of expected contracts. See Form N-6, Item 3, instr. 3(b)(i).
Response: The Company hereby confirms that the representative insured noted in the fee tables represent the age or classification with the greatest number of expected contracts.
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4. | Charges For Rider Coverage - Survivorship BenefitAccess Rider (p. 14) |
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a. | The terms Chronically Ill and Terminally Ill are defined in the glossary on page 35. To promote plain English disclosure, the essence of the definition should appear as part of its first use in the rider section: noting that Chronically Ill means, among other things, being unable to perform at least two specified activities of daily living, and referring the reader to the glossary section for the complete definition of the terms and for the complete listing of those specified activities. |
Response: The Company has updated the language in this section to direct investors to the Definitions of Special Terms Used In This Prospectus. We do not provide definitions of terms or qualifying conditions in this Charges For Rider Coverage section because its purpose is to provide investors with concise and clear disclosures regarding the amount and calculation of charges that may apply to their contracts. We believe that including definitions for the Survivor BenefitAccess Rider will be unnecessarily duplicative of the information that is already in the prospectus and may be confusing to investors.
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b. | The disclosure in this subsection states that the 2% and 4% Monthly Benefit Percentage ranges from $0.00 to $8.67 per $1,000 of rider Net Amount At Risk. The fee table on page four provides a corresponding range of $0.00007 to $12.42 per $1,000. Please reconcile. |
Response: One of these sections describes current charges, and the other describes maximum charges. Specifically, the section cited above describes “[t]he current charge for both the 2% and 4% Monthly Benefit Percentages”, while the table on Page 3 describes the “maximum Contract fees and expenses”.
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5. | Survivorship BenefitAccess Rider - Conditions for Eligibility of Benefit Payments (p. 17) |
According to the listed “Conditions for Eligibility of Benefit Payments,” one of the conditions to receiving a benefit acceleration under the Chronic Illness Option when the other insured is not Chronically Ill is that the other insured is “approved under the Terminal Illness Option.” In the first paragraph after the conditions, however, the prospectus states that benefits will be paid “[i]f one insured is Chronically Ill and the other Insured is simultaneously Terminally Ill and all conditions of eligibility for each option have been met . . . .” Please clarify supplementally whether the approval noted in the list of conditions is anything more than a certification by the issuer that the listed conditions have been met. If so, please revise the prospectus to note all conditions required for that certification and, if not, revise these two sentences for consistency.
Response: Other than the requirements set forth in this section, there are no other certifications or conditions required for a Terminally Ill individual when a Chronic Illness claim is received. The language that reads “[i]f one insured is Chronically Ill and the other Insured is simultaneously Terminally Ill and all conditions of eligibility for each option have been met....” simply reflects the requirement that the Company must receive “due proof of Chronic Illness and Written Certification from a Licensed Health Care Practitioner” for the Chronically Ill insured, and must receive “due proof of Terminal Illness and Written Certification from a Licensed Physician(s)” for the Terminally Ill insured, and that both insureds’ conditions must be occurring at the same time, as set forth in the preceding paragraphs of this section. Regardless of whether it is a Terminal Illness claim or a Chronic Illness claim, the process described in the prospectus is always the same: the Company receives the required documents and makes a determination that the insureds have satisfied the requirements set forth in this section.
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6. | Survivorship BenefitAccess Rider - Benefit Payments - Terminal Illness Options (p. 18) |
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a. | This section does not discuss any periodic payment options. For clarity, please note at the beginning of the section that no such option is available. |
Response: Periodic payments only apply to the Chronic Illness Option, which is discussed after this section. A negative reference to a periodic payment option that does not exist may be confusing to investors. We prefer to keep the existing language because the first paragraph of this section makes it clear that the only payment options are one or two lump sums: “You have the option to accelerate all or a partial amount of the Death Benefit… Also, if you accelerate a partial amount you may only make one additional acceleration, which must be for the full remaining Death Benefit. Accelerated Death Benefit payments under the Terminal Illness Option are made as a single lump sum Benefit Payment only.”
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b. | In the discussion of benefit payments under the Terminally Ill option, the prospectus notes that a lump sum accelerated payment of even a portion of the Death Benefit will disqualify the insured from any further payments under the Chronically Ill option. Since it appears unlikely that a Terminally Ill investor would want to later choose a Chronically Ill option, please make this explicit, i.e., that a Terminally Ill investor who accelerates all or part of the benefit could not later choose a Chronically Ill benefit. |
Response: The Company makes this explicit in the section Benefit Payments, Terminal Illness Option, which explains in the third paragraph that “If you accelerate all or a portion of the Death Benefit under this option, you will no longer be eligible for the Chronic Illness Option and any Benefit Payments you may be receiving under that option will end.” The Company also makes this explicit in Conditions for Eligibility of Benefit Payments, Chronic Illness Option, which states that “You are eligible to receive accelerated benefits under this option subject to the following conditions:…(b) You must not have received a Benefit Payment under the Terminal Illness Option.”
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c. | The prospectus notes how the amount of a lump sum payment of the Death Benefit is calculated. Please provide an example of the calculation. |
Response: The Company has updated the Impact of Rider Benefits On Contract And Riders subsection Terminal Illness Option example to include an example of the lump sum Death Benefit calculation, and has updated the Benefit Payments subsection Terminal Illness Option to provide clarification, as follows:
If you choose to accelerate all or part of the Death Benefit, we will make a Benefit Payment of the present value of the amount of the Death Benefit accelerated based on the following factors: (1) the amount of the Death Benefit; (2) the insured’s life expectancy of six months; and (3) a discount factor no greater than the greater of (a) the yield on 90-day federal treasury bills as of the date of payment, and (b) the maximum statutory adjustable contract loan interest rate as of the date of payment. We will make this determination based on information current as of the time we approve your request for accelerated payments. Payment will be made subject to the conditions of eligibility described above and after we have approved the claim.
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7. | Survivorship BenefitAccess Rider - Benefit Payments - Chronic Illness Options (p. 19) |
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a. | [i] The prospectus states in the beginning of the section the maximum amount that can be accelerated. This section should clarify how the amount that is received is actually determined (e.g., present value). |
Response: The Lifetime Benefit Amount is equal to the Contract’s Death Benefit at the time the initial claim is made and there is no calculation necessary to determine the maximum amount that can be accelerated. The subsequent paragraphs of this section explain how payment amounts are calculated, and the prospectus refers investors to the Chronic Illness Option example which demonstrates how benefit payments are actually determined.
[ii] In addition, please clarify in the beginning of the section that both a lump sum and a periodic payment options are available.
Response: There is no lump sum option available for the Chronic Illness Option.
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b. | Please clarify whether a Chronically Ill investor who has accelerated a part of the benefit can later choose to take a periodic payment of the remainder of the benefit or can later choose to accelerate the |
remainder of the benefit under the Terminally Ill option (so long as the investor qualifies under the Chronically Ill option).
Response: A Chronically Ill investor may not accelerate a part of the benefit via lump sum option. The section Benefit Payments, Terminal Illness Option states that an investor who has been receiving benefits under the Chronically Ill option and subsequently qualifies as Terminally Ill may take the remainder of their benefit in a lump sum under the Terminal Illness Option: “If you accelerate all or a portion of the Death Benefit under this option, you will no longer be eligible for the Chronic Illness Option and any Benefit Payments you may be receiving under that option will end.”
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c. | [i] The prospectus states that the Maximum Monthly Benefit Payment may be limited by a calculation involving the Initial Daily Benefit Limit. It is unclear both here and in the glossary on page 36 what this limit would be for a representative contract. |
Response: The Initial Daily Benefit Limit is calculated based on the per diem amount (which is set by the Internal Revenue Service and is currently $380) as of the Contract date multiplied by the Daily Benefit Limit Compound Rate of 4% annually, and does not vary by insured characteristics. The hypothetical Initial Daily Benefit Limit would be the same for all insureds, and the prospectus has been updated as follows:
The Monthly Benefit Percent, Initial Daily Benefit Limit, and the Daily Benefit Limit Compound Rate that apply to your Contract can be found in the Contract’s data pages.
[ii] Please provide an additional example of how the Maximum Monthly Benefit Payment is calculated showing how the Initial Daily Benefit Limit would operate to lower the Maximum Month Benefit Payment that would otherwise apply.
Response: As described in the prospectus and the example, the Maximum Month Benefit Payment is always the lowest of (a) the Lifetime Benefit Amount multiplied by the Monthly Benefit Percent, (b) the IRS per diem amount as of the current year, and (c) the Initial Daily Benefit Limit, which is the IRS per diem amount as of the Contact date compounded annually at 4%. Because the IRS typically increases the per diem amount approximately 2% per year, item (c) will not typically be the lowest value of items (a), (b), and (c) and will not typically operate to lower the Maximum Monthly Benefit Payment. The purpose of this example is to show how the Chronic Illness Benefit is calculated, and we feel that adding further examples illustrating unusual scenarios would be unhelpful and confusing to investors.
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d. | The prospectus notes that the annual Benefit Payment will be the present value of all such payments over the course of a Benefit Year. For clarity, please preface this disclosure by noting an annual payment will be less than the sum of those payments over the course of a year. |
Response: The Company has added the requested language, as follows:
If you choose to receive your Benefit Payments on an annual basis, the annual Benefit Payment will equal the sum of the present value of each Maximum Monthly Benefit Payment for the Benefit Year. The annual Benefit Payment will therefore be less than the amount of the Maximum Monthly Benefit Payment times 12. The discount factor used to determine the present value will be the one in effect on the Benefit Year start date and will not exceed the greater of (1) the yield on 90-day federal treasury bills as of the date of payment, or (2) the maximum statutory adjustable contract loan interest rate as of the date of payment.
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8. | Survivorship BenefitAccess Rider (p. 21) |
The prospectus states that, if the rider is selected and exercised for a contract with a fixed Death Benefit, the Basic Insurance Amounts is changed to that fixed Death Benefit (if not already set at that Death Benefit). Please clarify supplementally the circumstances where this would not be the case.
Response: A contract may be been over-funded to such an extent that it would fail the definition of life insurance test set forth under Section 7702 of the Internal Revenue Code. In that case the fixed Death Benefit will be increased so that the contract continues to meet the definition of life insurance, resulting in the Death Benefit exceeding the Basic Insurance Amount.
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9. | Financial Statements, Exhibits, and Other Information |
Please provide any financial statements, exhibits, consents, and other required disclosure not included in the filings.
Response: Financial statements will be included in Part B - Statement of Additional Information, which will be filed, along with any other exhibits or required disclosure required in Part C, in a pre-effective amendment to the registration statements.
If you have any questions, please contact me at 860-534-6087.
Respectfully yours,
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/s/ Christopher J. Madin | | 6/5/2020 |
Christopher J. Madin Vice President and Corporate Counsel Pruco Life Insurance Company | | Date |
Enclosures
via EDGAR
STATEMENT OF ADDITIONAL INFORMATION
The date of this statement of additional information and of the related prospectus is June 30, 2020.
Pruco Life Variable Universal Account (the "Account")
Pruco Life Insurance Company
PruLife® SVUL Protector®
SURVIVORSHIP VARIABLE UNIVERSAL LIFE INSURANCE CONTRACTS
This statement of additional information is not a prospectus. Please review the PruLife® SVUL Protector® prospectus (the “prospectus”), which contains information concerning the Contracts described above. You may obtain a copy of the prospectus without charge by calling us at 800-944-8786. You can also view the statement of additional information located with the prospectus at www.prudential.com/eprospectus, or request a copy by writing to us.
The defined terms used in this statement of additional information are as defined in the prospectus.
Pruco Life Insurance Company
213 Washington Street
Newark, New Jersey 07102
TABLE OF CONTENTS
Page
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GENERAL INFORMATION AND HISTORY | |
Description Of Pruco Life Insurance Company | |
Control Of Pruco Life Insurance Company | |
State Regulation | |
Records | |
Services And Third Party Administration Agreements | |
Cyber Security And Business Continuity Risks | |
INITIAL PREMIUM PROCESSING | |
ADDITIONAL INFORMATION ABOUT OPERATION OF CONTRACTS | |
Legal Considerations Relating To Sex-Distinct Premiums And Benefits | |
Contract's Death Benefit Types | |
How a Type A (Fixed) Contract's Death Benefit Will Vary | |
How a Type B (Variable) Contract's Death Benefit Will Vary | |
How a Type C (Return of Premium) Contract’s Death Benefit Will Vary | |
Reports To Contract Owners | |
ADDITIONAL INFORMATION ABOUT CHARGES | |
Underwriting Procedures | |
ADDITIONAL INFORMATION ABOUT CONTRACTS IN DEFAULT | |
DISTRIBUTION AND COMPENSATION | |
EXPERTS | |
PERFORMANCE DATA | |
Average Annual Total Return | |
Non-Standard Total Return | |
Money Market Yield | |
FINANCIAL STATEMENTS | |
GENERAL INFORMATION AND HISTORY
Description Of Pruco Life Insurance Company
Pruco Life Insurance Company ("Pruco Life", “us”, “we”, or “our”) is a stock life insurance company founded on December 23, 1971, under the laws of the state of Arizona. It is licensed to sell life insurance and annuities in the District of Columbia, Guam, and in all states except New York.
Control Of Pruco Life Insurance Company
Pruco Life is a wholly-owned subsidiary of The Prudential Insurance Company of America (“Prudential”), a stock life insurance company founded on October 13, 1875, under the laws of the state of New Jersey. Prudential is a wholly-owned subsidiary of Prudential Financial, Inc. (“Prudential Financial”), a New Jersey insurance holding company for financial services businesses offering wide range of insurance, investment management, and other financial products and services. The principal executive office of each of Prudential and Prudential Financial is Prudential Plaza, 751 Broad Street, Newark, New Jersey 07102.
Pruco Life Insurance Company of New Jersey (“Pruco Life of New Jersey”) is a wholly-owned subsidiary of Pruco Life. Pruco Life and Pruco Life of New Jersey’s principal executive office is 213 Washington Street, Newark, New Jersey 07102.
As Pruco Life’s ultimate parent, Prudential Financial exercises significant influence over the operations and capital structure of Pruco Life and Prudential. However, neither Prudential Financial, Prudential, nor any other related company has any legal responsibility to pay amounts that Pruco Life may owe under the Contract.
State Regulation
Pruco Life is subject to regulation and supervision by the Department of Insurance of the state of Arizona, which periodically examines its operations and financial condition. It is also subject to the insurance laws and regulations of all jurisdictions in which it is authorized to do business.
Pruco Life is required to submit annual statements of its operations, including financial statements, to the insurance departments of the various jurisdictions in which it does business to determine solvency and compliance with local insurance laws and regulations.
In addition to the annual statements referred to above, Pruco Life is required to file with Arizona and other jurisdictions, a separate statement with respect to the operations of all of its variable contract accounts, in a form promulgated by the National Association of Insurance Commissioners.
Records
We maintain all records and accounts relating to the Account at our principal executive office. As presently required by the Investment Company Act of 1940, as amended, and regulations promulgated thereunder, reports containing such information as may be required under the Act or by any other applicable law or regulation will be sent to you semi-annually at your last address known to us.
Services And Third Party Administration Agreements
Pruco Life and Prudential have entered into a Service Agreement pursuant to which Prudential furnishes to Pruco Life various services, including preparation, maintenance, and filing of accounts, books, records, and other documents required under federal or state law, and various other accounting, administrative, and legal services, which are customarily performed by the officers and employees of Prudential. Pruco Life reimburses Prudential for its costs in providing such services. Under this Agreement, Pruco Life has reimbursed Prudential $168,014,543 in 2019, $149,138,200 in 2018, $147,398,553 in 2017, $134,323,229 in 2016, and $115,795,950 in 2015, of which the life business accounted for $48,407,131, $45,679,723, $43,943,282, $40,178,302, and $35,996,482, respectively.
Prudential furnishes Pruco Life the same administrative support services that it provides in the operation of its own business with regard to the payment of death claim proceeds by way of Prudential’s Alliance Account. As soon as the Pruco Life death claim is processed, the beneficiaries are furnished with an information kit that describes the settlement option and a check book on which they may write checks.
Our individual life reinsurance treaties covering PruLife® SVUL Protector® Contracts provide for the reinsurance of a portion of the related mortality risk on a yearly renewable term basis. Pruco Life or its affiliates retain any such mortality risk that is not ceded under these treaties.
TransCentra, Inc. ("TransCentra") is a billing and payment services provider for Prudential, Pruco Life, and Pruco Life of New Jersey. TransCentra received $1,150,422 in 2019, $1,292,465 in 2018, and $1,394,460 in 2017 from Prudential for services rendered. TransCentra's principal business address is 4855 Peachtree Industrial Blvd, STE 245, Norcross, GA 30092.
Cyber Security And Business Continuity Risks
With the increasing use of technology and computer systems in general and, in particular, the internet to conduct necessary business functions, we are susceptible to operational, information security and related risks. These risks, which are often collectively referred to as “cyber security” risks, may include deliberate or malicious attacks, as well as unintentional events and occurrences. These risks are heightened by our offering of products with certain features, including those with automatic asset transfer or re-allocation strategies, and by our employment of complex investment, trading and hedging programs. Cyber security is generally defined as the technology, operations and related protocol surrounding and protecting a user’s computer hardware, network, systems and applications and the data transmitted and stored therewith. These measures ensure the reliability of a user’s systems, as well as the security, availability, integrity, and confidentiality of data assets.
Deliberate cyber attacks can include, but are not limited to, gaining unauthorized access (including physical break-ins and attempts to fraudulently induce employees, customers or other users of these systems to disclose sensitive information in order to gain access) to computer systems in order to misappropriate and/or disclose sensitive or confidential information; deleting, corrupting or modifying data; and causing operational disruptions. Cyber attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (in order to prevent access to computer networks). In addition to deliberate breaches engineered by external actors, cyber security risks can also result from the conduct of malicious, exploited or careless insiders, whose actions may result in the destruction, release or disclosure of confidential or proprietary information stored on an organization’s systems.
The Company is also subject to risks related to disasters and other events, such as storms, earthquakes, fires, outbreaks of infectious diseases (such as COVID-19), utility failures, terrorist acts, political and social developments, and military and governmental actions. These risks are often collectively referred to as “business continuity” risks. These events could adversely affect the Company and our ability to conduct business and process transactions. Although the Company has business continuity plans, it is possible that the plans may not operate as intended or required and that the Company may not be able to provide required services, process transactions, deliver documents or calculate values. It is also possible that service levels may decline as a result of such events.
Cyber security events, disasters, and similar events, whether deliberate or unintentional, that could impact us and our Contract Owners could arise not only in connection with our own administration of the Contract, but also with entities operating the Contract’s underlying funds and with third-party service providers to us. Cyber security and other events affecting any of the entities involved with the offering and administration of the Contract may cause significant disruptions in the business operations related to the Contract. Potential impacts may include, but are not limited to, potential financial losses under the Contract, your inability to conduct transactions under the Contract and/or with respect to an underlying fund, an inability to calculate unit values with respect to the Contract and/or the net asset value ("NAV") with respect to an underlying fund, and disclosures of your personal or confidential account information.
In addition to direct impacts to you, cyber security and other events described above may result in adverse impacts to us, including regulatory inquiries, regulatory proceedings, regulatory and/or legal and litigation costs, and reputational damage. Costs incurred by us may include reimbursement and other expenses, including the costs of litigation and litigation settlements and additional compliance costs. Considerable expenses also may be incurred by us in enhancing and upgrading computer systems and systems security following a cyber security failure or responding to a disaster or similar event.
The rapid proliferation of technologies, as well as the increased sophistication and activities of organized crime, hackers, terrorists, hostile foreign governments, and others continue to pose new and significant cyber security threats. In addition, the global spread of COVID-19 has caused the Company and its service providers to implement business continuity plans, including widespread use of work-from-home arrangements. Although we, our service providers, and the underlying funds offered under the Contract may have established business continuity plans and risk management systems to mitigate risks, there can be no guarantee or assurance that such plans or systems will be effective, or that all risks that exist, or may develop in the future, have been completely anticipated and identified or can be protected against. Furthermore, we cannot control or assure the efficacy of the cyber security and business continuity plans and systems implemented by third-party service providers, the underlying funds, and the issuers in which the underlying funds invest.
INITIAL PREMIUM PROCESSING
In general, the invested portion of the minimum initial premium will be placed in the Contract Fund as of the later of the Contract Date and the date we receive the premium in Good Order.
Upon receipt of a request for life insurance from a prospective Contract Owner, Pruco Life will follow certain insurance underwriting (i.e., evaluation of risk) procedures designed to determine whether each proposed insured is insurable. The process may involve such verification procedures as medical examinations and may require that further information be provided by one or both of the proposed insureds before a determination can be made. A Contract cannot be issued, (i.e., physically issued through Pruco Life’s computerized issue system) until this underwriting procedure has been completed.
Since a Contract cannot be issued until after the underwriting process has been completed, we use a Limited Insurance Agreement to provide temporary life insurance coverage to prospective Contract Owners who pay the minimum initial premium at the time the request for coverage is submitted. This coverage is for the total Death Benefit applied for, up to the maximum described by the Limited Insurance Agreement, and is subject to the other terms of the Limited Insurance Agreement.
The Contract Date is the date specified in the Contract. This date is used to determine the insurance age of each proposed insured. It represents the first day of the Contract Year and therefore determines the Contract Anniversary and Monthly Dates. It also represents the commencement of the suicide and contestable periods for purposes of the Basic Insurance Amount.
If the minimum initial premium is paid with the application and no medical examination is required, the Contract Date will ordinarily be the date of the application. If a delay is encountered (e.g., if a request for further information is not met promptly), generally, the Contract Date will be 21 days prior to the date on which the Contract is physically issued. If a medical examination is required, the Contract Date will ordinarily be the date the examination is completed, subject to the same qualification as that noted above.
If the premium paid with the application is less than the minimum initial premium, the Contract Date will be determined as described above. The balance of the minimum initial premium amount will be applied as of the later of the Contract Date and the date premiums were received in Good Order.
If no premium is paid with the application, the Contract Date will be the Contract Date stated in the Contract, which will generally be the date the minimum initial premium is received in Good Order from the Contract Owner and the Contract is delivered.
There is one principal variation from the foregoing procedure. If permitted by the insurance laws of the state in which the Contract is issued, the Contract may be backdated up to six months.
In situations where the Contract Date precedes the date that the minimum initial premium is received, charges due prior to the initial premium receipt date will be deducted immediately after the net premium has been applied to the Contract Fund.
ADDITIONAL INFORMATION ABOUT OPERATION OF CONTRACTS
Legal Considerations Relating To Sex-Distinct Premiums And Benefits
The Contract generally employs mortality tables that distinguish between males and females. Thus, premiums and benefits differ under Contracts issued on males and females of the same age. However, in those states that have adopted regulations prohibiting sex-distinct insurance rates, premiums and cost of insurance charges will be based on male rates, whether the insureds are male or female. In addition, employers and employee organizations considering purchase of a Contract should consult their legal advisers to determine whether purchase of a Contract based on sex-distinct actuarial tables is consistent with Title VII of the Civil Rights Act of 1964 or other applicable law.
Contract's Death Benefit Types
There are three types of Death Benefit available under the Contract: (1) Type A, a generally fixed Death Benefit; (2) Type B, a variable Death Benefit; and (3) Type C, a return of premium Death Benefit. A Type C (return of premium) Death Benefit generally varies by the amount of premiums paid, a Type B (variable) Death Benefit varies with investment performance, and a Type A (fixed) Death Benefit does not vary unless it must be increased to comply with the Internal Revenue Code's definition of life insurance.
How a Type A (Fixed) Contract's Death Benefit Will Vary
Under the Type A (fixed) Contract, the Death Benefit is generally equal to the Basic Insurance Amount, before the reduction of any Contract Debt. If the Contract is kept in force for several years, depending on how much premium you pay, and/or if investment performance is reasonably favorable, the Contract Fund may grow to the point where we will increase the Death Benefit in order to ensure that the Contract will satisfy the Internal Revenue Code's definition of life insurance.
Assuming no Contract Debt or riders, the Death Benefit of a Type A (fixed) Contract will always be the greater of:
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(1) | the Basic Insurance Amount; and |
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(2) | the Contract Fund before the deduction of any monthly charges due on that date, multiplied by the younger insured’s Attained Age factor that applies. |
A listing of Attained Age factors can be found on your Contract's data pages. The latter provision ensures that the Contract will always have a Death Benefit large enough so that the Contract will be treated as life insurance for tax purposes under current law. Before the Contract is issued, the Contract Owner may choose between two methods that we use to determine the tax treatment of the Contract.
The following table illustrates at different ages how the Attained Age factor affects the Death Benefit for different Contract Fund amounts. The table assumes a $1,000,000 Type A Contract was issued when the younger insured was age 35, and there is no Contract Debt.
Type A (Fixed) Death Benefit
|
| | | | |
If | Then |
The younger insured is age | and the Contract Fund is | the Attained Age factor is** | the Contract Fund multiplied by the Attained Age factor is | and the Death Benefit is |
40 40 40 | $100,000 $200,000 $300,000 | 7.15 7.15 7.15 | 715,000 1,430,000 2,145,000 | $1,000,000 $1,430,000* $2,145,000* |
60 60 60 | $300,000 $400,000 $600,000 | 3.28 3.28 3.28 | 984,000 1,312,000 1,968,000 | $1,000,000 $1,312,000* $1,968,000* |
80 80 80 | $600,000 $700,000 $800,000 | 1.58 1.58 1.58 | 948,000 1,106,000 1,264,000 | $1,000,000 $1,106,000* $1,264,000* |
* Note that the Death Benefit has been increased to comply with the Internal Revenue Code’s definition of life insurance. ** Assumes the Contract Owner selected the Cash Value Accumulation Test. These figures are based on the 2017 Commissioner's Standard Ordinary ("CSO") Mortality Tables. |
This means, for example, that if the younger insured has reached the age of 60, and the Contract Fund is $600,000, the Death Benefit will be $1,968,000, even though the Basic Insurance Amount is $1,000,000. In this situation, for every $1 increase in the Contract Fund, the Death Benefit will be increased by $3.28. We reserve the right to refuse to accept any premium payment that increases the Death Benefit by more than it increases the Contract Fund. If we exercise this right, in certain situations it may result in the loss of the No-Lapse Guarantee.
How a Type B (Variable) Contract's Death Benefit Will Vary
Under the Type B (variable) Contract, while the Contract is in force, the Death Benefit will never be less than the Basic Insurance Amount, before the reduction of any Contract Debt, but will also vary immediately after it is issued, with the investment results of the selected
Variable Investment Options. The Death Benefit may be increased to ensure that the Contract will satisfy the Internal Revenue Code's definition of life insurance.
Assuming no Contract Debt or riders, the Death Benefit of a Type B (variable) Contract will always be the greater of:
| |
(1) | the Basic Insurance Amount plus the Contract Fund before the deduction of any monthly charges due on that date; and |
| |
(2) | the Contract Fund before the deduction of any monthly charges due on that date, multiplied by the younger insured’s Attained Age factor that applies. |
For purposes of computing the Death Benefit, if the Contract Fund is less than zero, we will consider it to be zero. A listing of Attained Age factors can be found on your Contract's data pages. The latter provision ensures that the Contract will always have a Death Benefit large enough so that the Contract will be treated as life insurance for tax purposes under current law. Before the Contract is issued, the Contract Owner may choose between two methods that we use to determine the tax treatment of the Contract.
The following table illustrates various Attained Age factors and Contract Funds and the corresponding Death Benefits. The table assumes a $1,000,000 Type B (variable) Contract was issued when the younger insured was age 35, and there is no Contract Debt.
Type B (Variable) Death Benefit
|
| | | | |
If | Then |
The younger insured is age | and the Contract Fund is | the Attained Age factor is** | the Contract Fund multiplied by the Attained Age factor is | and the Death Benefit is |
40 40 40 | $100,000 $200,000 $300,000 | 7.15 7.15 7.15 | 715,000 1,430,000 2,145,000 | $1,100,000 $1,430,000* $2,145,000* |
60 60 60 | $300,000 $400,000 $600,000 | 3.28 3.28 3.28 | 984,000 1,312,000 1,968,000 | $1,300,000 $1,400,000 $1,968,000* |
80 80 80 | $600,000 $700,000 $800,000 | 1.58 1.58 1.58 | 948,000 1,106,000 1,264,000 | $1,600,000 $1,700,000 $1,800,000 |
* Note that the Death Benefit has been increased to comply with the Internal Revenue Code’s definition of life insurance. ** Assumes the Contract Owner selected the Cash Value Accumulation Test. These figures are based on the 2017 Commissioner's Standard Ordinary ("CSO") Mortality Tables. |
This means, for example, that if the younger insured has reached the age of 60, and the Contract Fund is $600,000, the Death Benefit will be $1,968,000, even though the Basic Insurance Amount plus the Contract Fund is $1,600,000. In this situation, for every $1 increase in the Contract Fund, the Death Benefit will be increased by $3.28. We reserve the right to refuse to accept any premium payment that increases the Death Benefit by more than it increases the Contract Fund. If we exercise this right, in certain situations it may result in the loss of the No-Lapse Guarantee.
How a Type C (Return of Premium) Contract’s Death Benefit Will Vary
Under the Type C (return of premium) Contract, while the Contract is in force, the Death Benefit will vary by the amount of premiums paid, less any withdrawals. The Death Benefit on a Type C Contract is limited to the Basic Insurance Amount plus an amount equal to: the Contract Fund plus the Type C Limiting Amount multiplied by the Type C Death Benefit Factor, both located in the Contract Limitations section of your Contract. The Death Benefit may be increased to ensure that the Contract will satisfy the Internal Revenue Code’s definition of life insurance. Unlike Type A and Type B Contracts, the Death Benefit of a Type C Contract may be less than the Basic Insurance Amount in the event total withdrawals are greater than total premiums paid.
Assuming no Contract Debt, the Death Benefit of a Type C (return of premium) Contract will always be the lesser of:
| |
(1) | the Basic Insurance Amount plus the total premiums paid into the Contract less any withdrawals; and |
| |
(2) | the Basic Insurance Amount plus the Contract Fund before deduction of any monthly charges due on that date plus the product of the Type C Limiting Amount multiplied by the Type C Death Benefit Factor, both found in the Contract Limitations section of the Contract data pages. |
However, if the product of the Contract Fund, before any monthly charges, multiplied by the Attained Age factor is greater than either (1) or (2), described above, then it will become the Death Benefit.
A listing of Attained Age factors can be found on your Contract's data pages. The latter provision ensures that the Contract will always have a Death Benefit large enough so that the Contract will be treated as life insurance for tax purposes under current law. Before the Contract is issued, the Contract Owner may choose between two methods that we use to determine the tax treatment of the Contract.
The following table illustrates various Attained Age factors and Contract Funds and the corresponding Death Benefits. The table assumes a $1,000,000 Type C (return of premium) Contract was issued when the younger insured was age 35, and there is no Contract Debt.
Type C (Return of Premium) Death Benefit
|
| | | | | |
If | Then |
The younger insured is age | and the Contract Fund is | and the premium paid less any withdrawals is | the Attained Age factor is** | the Contract Fund multiplied by the Attained Age factor is | and the Death Benefit is |
40 40 40 | $100,000 $200,000 $300,000 | $80,000 $160,000 $270,000 | 7.15 7.15 7.15 | 715,000 1,430,000 2,145,000 | $1,080,000 $1,430,000* $2,145,000* |
60 60 60 | $300,000 $400,000 $600,000 | $240,000 $320,000 $480,000 | 3.28 3.28 3.28 | 984,000 1,312,000 1,968,000 | $1,240,000 $1,320,000 $1,968,000* |
80 80 80 | $600,000 $700,000 $800,000 | $480,000 $560,000 $640,000 | 1.58 1.58 1.58 | 948,000 1,106,000 1,264,000 | $1,480,000 $1,560,000 $1,640,000 |
* Note that the Death Benefit has been increased to comply with the Internal Revenue Code’s definition of life insurance. ** Assumes the Contract Owner selected the Cash Value Accumulation Test. These figures are based on the 2017 Commissioner's Standard Ordinary ("CSO") Mortality Tables. |
This means, for example, that if the younger insured has reached the age of 60, and the Contract Fund is $600,000, the Death Benefit will be $1,968,000, even though the Basic Insurance Amount plus total premiums paid less withdrawals is $1,480,000. In this situation, for every $1 increase in the Contract Fund, the Death Benefit will be increased by $3.28. We reserve the right to refuse to accept any premium payment that increases the Death Benefit by more than it increases the Contract Fund. If we exercise this right, in certain situations it may result in the loss of the No-Lapse Guarantee.
Reports To Contract Owners
Once each year, we will send you a statement that provides certain information pertinent to your Contract. This statement will detail values, transactions made, and specific Contract data that apply only to your particular Contract.
We also make available annual and semi-annual reports of the Funds showing the financial condition of the Funds and the investments held in each Fund. The most recent annual and semi-annual reports are available at www.prudential.com/eprospectus or by calling 800-944-8786.
ADDITIONAL INFORMATION ABOUT CHARGES
Underwriting Procedures
When you express interest in obtaining a Contract from us, you may apply for coverage through either (1) a long form application or (2) our worksheet process. When using the long form application, a registered representative completes a full application and submits it to us to commence the underwriting process. A registered representative may be an agent/broker who is a representative of Pruco Securities, a broker-dealer affiliate of Prudential, or in some cases, a broker-dealer not directly affiliated with Prudential. When using the worksheet process, a registered representative typically collects enough information to start the underwriting process. The remaining information is obtained directly from the proposed insureds.
Regardless of the underwriting process followed, once we receive the necessary information, which may include physicians' statements, medical examinations from physicians or paramedical vendors, test results, and other information, we will make a decision regarding our willingness to accept the risk, and the price at which we will accept the risk. We will issue the Contract when the risk has been accepted and priced.
ADDITIONAL INFORMATION ABOUT CONTRACTS IN DEFAULT
When your Contract is in default, no part of your Contract Fund is available to you. Consequently, you are not able to take any loans, partial withdrawals or surrenders, or make any transfers among the investment options. In addition, during any period in which your Contract is in default, you may not change the way in which subsequent premiums are allocated.
DISTRIBUTION AND COMPENSATION
In an effort to promote the sale of our variable products (which may include the placement of our Contracts on a preferred or recommended company or product list and/or access to a broker-dealer’s registered representatives), we or Pruco Securities may enter into compensation arrangements with certain broker-dealer firms authorized by Pruco Securities to sell the Contract, or branches of such firms, with respect to certain or all registered representatives of such firms under which such firms may receive separate compensation or reimbursement for, among other things, training of sales personnel, marketing and / or administrative and / or other services they provide to us or our affiliates.
To the extent permitted by applicable rules, laws, and regulations, Pruco Securities may pay or allow other promotional incentives or payments in the form of cash or non-cash compensation. These arrangements may not be offered to all firms, and the terms of such arrangements may differ between firms. You should note that firms and individual registered representatives and branch managers
within some firms participating in one of these compensation arrangements might receive greater compensation for selling the Contract than for selling a different Contract that is not eligible for these compensation arrangements.
Pruco Life makes these promotional payments directly to or in sponsorship of the firm (or its affiliated broker/dealers). Examples of arrangements under which such payments may be made currently include, but are not limited to, sponsorships, conferences (national, regional and top producer), speaker fees, promotional items and reimbursements to firms for marketing activities or services paid by the firms and/or their individual representatives. The amount of these payments varies widely because some payments may encompass only a single event, such as a conference, and others have a much broader scope.
The list below provides the names of the firms (or their affiliated broker/dealers) that we are aware of (as of December 31, 2019) that received payment or accrued a payment amount with respect to variable product business during 2019. The least amount paid or accrued and the greatest amount paid or accrued during 2019 were $0.38 and $41,809,941.64, respectively.
Names of Firms:
1ST GLOBAL CAPITAL CORPORATION, 1ST GLOBAL INS SVS INC, 1ST GLOBAL INSURANCE AGENCY OF MA INC, AGENCY SERVICES OF AR INC, ALLSTATE FINANCIAL SERVICES LLC, AMERIAN GENERAL INS AGCY INC, AMERICAN EXPRESS INS AGENCY OF MA INC, AMERICAN EXPRESS INS AGENCY OF TX, AMERICAN INDEPENDENT SECURITIES GROUP LLC, AMERICAN INVESTORS CO, AMERICAN PORTFOLIOS FIN SVCS INC, AMERIPRISE FINANCIAL CENTER, AMERITAS INVESTMENT CORP, AON CONSULTING INC, APW CAPITAL INC, ARETE INSURANCE AGENCY LLC, ARLINGTON SECURITIES INC, ARVEST INSURANCE INC, AURORA INSURANCE SERVICES INC, AUSDAL FINANCIAL PARTNERS INC, AVANTAX INSURANCE SERVICES INC, AVANTAX INSURANCE SERVICES INC (MA), AVISEN SECURITIES INC, AXA NETWORK LLC, AYCO SERVICES AGENCY LP, AYCO SERVICES INS AGCY INC (K OSTER), B RILEY WEALTH MANAGEMENT INC, BAIRD INS SERVICES INC, BBVA COMPASS INSURANCE AGENCY, BCG SECURITIES INC, BENEFIT FUNDING SERVICES LLC, BENJAMIN F EDWARDS & COMPANY INC, BERTHEL FISHER & CO FIN SVCS INC, BOK FINANCIAL SECURITIES INC, BROKERS INTERNATIONAL FINANCIAL SERVICES, BROOKLIGHT PLACE SECURITIES INC, CADARET GRANT & CO INC, CALTON & ASSOCIATES INC, CAMBRIDGE INVESTMENT RESEARCH INC, CAMBRIDGE INVESTMENT RESEARCH INC, CAPFINANCIAL SECURITIES LLC, CAPITAL FINANCIAL SERVICES INC, CAPITAL INVESTMENT GROUP INC, CAPITAL SYNERGY PARTNERS INC, CAROLINAS INVESTMENT CONSULTING LLC, CBIZ BENEFITS & INS SVS INC, CC SERVICES INC, CENTARA CAPITAL SECURITIES INC, CENTAURUS FINANCIAL INC, CENTAURUS TEXAS INC, CES INSURANCE AGENCY INC, CETERA ADVISOR NETWORK LLC, CETERA ADVISOR NETWORK LLC, CETERA ADVISORS INSURANCE SERVICES LLC, CETERA ADVISORS LLC, CETERA FINANCIAL SPECIALIST LLC, CETERA INVESTMENT SERVICES LLC, CFD INVESTMENTS INC, CFS INSURANCE AND TECHNOLOGY SERVICES LLC, CHALICE CAPITAL PARTNERS LLC, CHAPIN DAVIS INSURANCE INC, CHASE INSURANCE AGENCY, CIG RISK MANAGEMENT INC, CITIGROUP LIFE AGENCY LLC, CITIZENS SECURITIES INC, CLIENT ONE SECURITIES LLC, COMMUNITYAMERICA FINANCIAL SOLUTIONS LLC, CONCORDE INVESTMENT SERVICES LLC, COORDINATED CAPITAL SECURITIES, CPS FINANCIAL & INSURANCE SERVICES INC, CROWN CAPITAL INS AGENCY OF NV INC, CROWN CAPITAL INSURANCE AGENCY LLC, CROWN CAPITAL SECURITIES LP, CRUMP LIFE INS SERVICES INC, CUTTER & COMPANY BROKERAGE INC, DEMPSEY FIN NETWORK INC, DEMPSEY LORD SMITH LLC, DORSEY & COMPANY INC, EDWARD D JONES & CO LP, EDWARD JONES INS AGCY OF CA LLC, EDWARD JONES INS AGCY OF MA LLC, EDWARD JONES INS AGCY OF NM LLC, ENTERPRISE GENERAL INS AGENCY INC, ENTERPRISE SECURITIES COMPANY, EQUITY SERVICES INC, ESTATE INSURANCE SERVICES LTD, EXECUTIVE INS AGENCY INC, FARMERS FINANCIAL SOLUTIONS, FASI OF TX INC, FBL MARKETING SERVICES LLC, FIFTH THIRD INSURANCE AGENCY INC, FIFTH THIRD SECURITIES INC, FINANCIAL TELESIS INC, FIRST ALLIED SECURITIES , FIRST CITIZENS INVESTOR SERVICES INC, FIRST HEARTLAND CAPITAL INC, FIRST PALLADIUM LLC, FIRST STATE FINANCIAL MGMT INC, FNBB CAPITAL MARKETS LLC, FORTUNE FINANCIAL SERVICES INC, FORTUNE SECURITIES INC, FOUNDERS FINANCIAL SECURITIES LLC, FSC AGENCY INC, G A REPPLE & COMPANY, GENEOS WEALTH MANAGEMENT INC, GLOBALINK SECURITIES INC, GRADIENT SECURITIES LLC, GRB FINANCIAL LLC, GWN SECURITIES INC, H BECK INC, H&R BLOCK FINANCIAL ADVISORS INC, HANCOCK SECURITIES GROUP LLC, HANTZ AGENCY LLC, HANTZ AGENCY LLC, HANTZ FINANCIAL SERVICES INC, HARBOR FINANCIAL SERVICES LLC, HARBOR INVESTMENT ADVISORY LLC, HARBOUR INVESTMENTS INC, HAZLETT BURT AND WATSON INC, HEFREN TILLOTSON INC, HEREFORD INSURANCE AGENCY INC, HIGHTOWER SECURITIES LLC, HORAN SECURITIES INC, HORNOR TOWNSEND & KENT, HUNTINGTON INVESTMENT COMPANY, HUNTLEIGH SECURITIES CORP (K JACKSON), HWG INS AGENCY INC, ICC INSURANCE AGCY INC, IFP INSURANCE GROUP LLC, IMS INSURANCE AGENCY INC , IMS SECURITIES INC, INDEPENDENT FINANCIAL GROUP INC, INFINEX INVESTMENTS INC, INNOVATION PARTNERS LLC, INSIGHT SECURITIES INC, INTERCONTINENTAL AGENCY LLC, INTERLINK SECURITIES CORP, INTERNATIONAL ASSETS ADVISORY LLC, INTERSECURITIES INSURANCE AGENCY , INTERVEST INTERNATIONAL INC, INTERVEST INTERNAT'L EQUITIES CORP, INVERNESS SECURITIES LLC, INVESTACORP INC, INVESTACORP INC, INVESTMENT CENTER INC, INVESTMENT PLANNERS INC, ISI INSURANCE AGENCY INC (R SIMARD), J J B HILLIARD W L LYONS LLC, J W COLE FINANCIAL INC, JANNEY MONTGOMERY SCOTT LLC, JJB HILLIARD W L LYONS INC, JK FINANCIAL SERVICES INC, JW COLE FINANCIAL INC, KCD FINANCIAL, KCL SERVICE COMPANY OF TEXAS, KESTRA INVESTMENT SERVICES LLC, KESTRA INVESTMENT SERVICES, LLC, KEYCORP INSURANCE AGENCY USA INC, KFG ENTERPRISES INC, KINGSBURY CAPITAL INC, KMS FINANCIAL SERVICES, KOVACK SECURITIES INC, L M KOHN & CO, LARSON FINANCIAL GROUP LLC, LASALLE ST SECURITIES LLC, LEADERS GROUP, LFA LIMITED LIABILITY COMPANY, LIFEMARK SECURITIES CORP, LINCOLN FIN ADVISORS CORP, LINCOLN FINANCIAL SEC CORP, LINCOLN INVESTMENT PLANNING LLC, LINCOLN NATIONAL INS ASSOC INC, LINSCO PRIVATE LEDGER INS ASSOC INC, LION STREET FINANCIAL LLC, LPA INSURANCE AGENCY INC, LPL FINANCIAL CORPORATION, M FINANCIAL SECURITIES MARKETING INC , M HOLDINGS SECURITES INC, M&T SECURITIES INC, MARINER INSURANCE RESOURCES LLC, MB SCHOEN & ASSOCIATES INC, MCG SECURITIES LLC, MERCAP SECURITIES LLC, MERCER HEALTH & BENEFITS ADMINISTRATION LLC, MERRILL LYNCH LIFE AGCY INC, MERRILL LYNCH LIFE AGCY INC, MERRILL LYNCH LIFE AGCY INC, MMC SECURITIES LLC, MML INS AGCY INC, MML INS AGCY INC, MONEY CONCEPTS CAPITAL, MOORS & CABOT INC, MORGAN STANLEY DEAN WITTER INS SVCS INC, MSC OF TX INC, MUTUAL TRUST CO OF AMERICA SECURITIES, MWA FINANCIAL SERVICES INC, MWAGIA INC, NATIONAL SECURITIES CORP, NAVY FEDERAL BROKERAGE SERVICES LLC, NETWORK AGENCY INC, NETWORK AGENCY OF OHIO INC, NEW PENFACS INS AGENCY INC, NEWPORT GROUP SEC INC, NEXT FINANCIAL GROUP, NEXT FINANCIAL GROUP, NORTHLAND SECURITIES INC, NORTHWESTERN MUTUAL INVEST SVCS, NPB FINANCIAL GROUP LLC, NYLIFE INSURANCE AGENCY INC, O N EQUITY SALES COMPANY, OFG FINANCIAL SERVICES INC, OHIO NATIONAL INS AGENCY INC, OHIO NATIONAL INS AGENCY INC, ONEAMERICA SECURITIES INC, OPPENHEIMER & CO INC, PACKERLAND BROKERAGE SERVICES, PARK AVENUE SECURITIES, PARKLAND SECURITIES LLC, PEOPLES SECURITIES INC, PJ ROBB VARIABLE CORP, PLUS AGENCY LLC, PNC INSURANCE SERVICES INC, PREFERRED MARKETING SERVICES INC (M ROTHSCHILD), PRINCIPAL SECURITIES INC, PRIVATE CLIENT SERVICES LLC, PRIVATE LEDGER INS AGCY OF OH INC (P CALFEE), PROEQUITIES INC, PRUDENTIAL DIRECT INC, PURSHE KAPLAN STERLING INS INV, QUEST CAPITAL STRATEGIES INC, QUESTAR AGENCY
INC, RAYMOND JAMES & ASSOCIATES INC, RAYMOND JAMES & ASSOCIATES INC, RBC CAPITAL MARKETS CORP, REGULUS ADVISOR LLC, REHMANN INSURANCE GROUP LLC, ROBERT SHOR INSURANCE ASSOCIATES INC, ROBERT W BAIRD & CO INC, ROYAL ALLIANCE ASSOCIATES INC, ROYAL ALLIANCE ASSOCIATES INC, ROYAL ALLIANCE INS AGCY OF MA INC, ROYAL ALLIANCE INS AGCY OF OH INC (L WALLER), S B H U LIFE AGENCY INC, SA STONE WEALTH MANAGEMENT INC, SAGEPOINT FINANCIAL INC, SAXONY INSURANCE AGENCY LLC, SAYBRUS EQUITY SERVICES INC, SBS INSURANCE AGENCY OF FLORIDA INC, SBS INSURANCE AGENCY OF LA INC, SCF SECURITIES INC, SECURIAN FINANCIAL SERVICES INC, SECURITIES AMERICA INC, SECURITIES SERVICE NETWORK INC, SFA INSURANCE SERVICES INC, SIGMA FINANCIAL CORP, SIGNAL SECURITIES INC, SIGNATOR INSURANCE AGENCY INC, SII INVESTMENTS INC, SIMMONS FIRST INS SERVICES INC, SMITH BROWN & GROOVER INC, SNOWDEN INSURANCE SERVICES LLC, SORRENTO PACIFIC FINANCIAL LLC , SOUTHERN WEALTH SECURITIES LLC, SOUTHWEST INSURANCE AGENCY INC, SPIRE INSURANCE AGENCY LLC, ST. BERNARD FINANCIAL SERVICES INC, STANLEY LAMAN GROUP SECURITIES LLC, STEPHENS INSURANCE LLC, STIFEL NICHOLAUS & CO INC, STIFEL NICHOLAUS & CO INC, SUMMIT BROKERAGE SERVICES, INC., SUNSET FINANCIAL SERVICES INC, TFS SECURITIES INC, THOROUGHBRED FINANCIAL SERVICES LLC, THRIVENT INSURANCE AGENCY INC, THURSTON SPRINGER MILLER HERD & TITAK INC, TRANSAMERICA FINANCIAL ADVISORS INC, TRIAD ADVISORS INC, TRIAD ADVISORS INC, TRUSTMONT FINANCIAL GROUP INC, U S BANCORP INVESTMENTS INC, UBS FINANCIAL SERVICES, UNIONBANC INVESTMENT SERVICES LLC, UNITED PLANNERS FINANCIAL, UNITED PLANNERS FINANCIAL, US BANCORP INSURANCE SERVICES LLC, USA FINANCIAL SECURITIES CORP, VALMARK SECURITES INC , VANDERBILT SECURITIES LLC, VOYA FINANCIAL ADVISORS INC, WADDELL & REED INC, WELLS FARGO ADVISORS CALIFORNIA INS AGENCY LLC, WELLS FARGO ADVISORS FINANCIAL NETWORK, WELLS FARGO ADVISORS FINANCIAL NETWORK L, WELLS FARGO ADVISORS FINANCIAL NETWORK L, WESTERN EQUITY GROUP INC, WINTRUST INVESTMENTS LLC, WOODBURY FIN SERVICES INC, WOODBURY FINANCIAL AGENCY OH INC, WORLD CAPITAL BROKERAGE INC, WORLD EQUITY GROUP, WORTH FINANCIAL GROUP INC, ZURES CO FIN & INS SVCS (J BAKER)
Your registered representative can provide you with more information about the compensation arrangements that apply upon the sale of the Contract.
EXPERTS
[Auditing and accounting statement to be filed by pre-effective amendment.]
Actuarial matters included in this statement of additional information have been examined by Vy Ho, FSA, MAAA, Vice President and Actuary of Prudential.
PERFORMANCE DATA
Average Annual Total Return
The Account may advertise average annual total return information calculated according to a formula prescribed by the SEC. Average annual total return shows the average annual percentage increase, or decrease, in the value of a hypothetical contribution allocated to a Variable Investment Option from the beginning to the end of each specified period of time. The SEC standardized version of this performance information is based on an assumed contribution of $1,000 allocated to a Variable Investment Option at the beginning of each period and full withdrawal of the value of that amount at the end of each specified period. This method of calculating performance further assumes that (i) a $1,000 contribution was allocated to a Variable Investment Option and (ii) no transfers or additional payments were made. Premium taxes are not included in the term “charges” for purposes of this calculation. Average annual total return is calculated by finding the average annual compounded rates of return of a hypothetical contribution that would compare the Unit Value on the first day of a specified period to the ending redeemable value at the end of the period according to the following formula:
P(1+T)n = ERV
Where T equals average annual total return, where ERV (the ending redeemable value) is the value at the end of the applicable period of a hypothetical contribution of $1,000 made at the beginning of the applicable period, where P equals a hypothetical contribution of $1,000, and where n equals the number of years.
Non-Standard Total Return
In addition to the standardized average annual total return information described above, we may present total return information computed on bases different from that standardized method. The Account may also present aggregate total return figures for various periods, reflecting the cumulative change in value of an investment in the Account for the specified period.
For the periods prior to the date the Variable Investment Options commenced operations, non-standard performance information for the Contracts will be calculated based on the performance of the Funds and the assumption that the Variable Investment Options were in existence for the same periods as those indicated for the Funds, with the level of Contract charges that were in effect at the inception of the Variable Investment Options (this is referred to as “hypothetical performance data”). Standard and non-standard average annual return calculations include the mortality and expense risk charge under the Contract, but do not reflect other life insurance Contract charges (sales, administration, and actual cost of insurance) nor any applicable surrender or lapse charges, which would significantly lower the returns. Information stated for any given period does not indicate or represent future performance.
Money Market Yield
The “total return” figures for the Government Money Market Variable Investment Option are calculated using historical investment returns of the Government Money Market Portfolio of The Prudential Series Fund as if PruLife® SVUL Protector® had been investing in that Variable Investment Option during a specified period. Fees associated with the Series Fund are reflected; however, all fees, expenses, and charges associated with PruLife® SVUL Protector® are not reflected.
The yield is computed by determining the net change, exclusive of capital changes, in the value of a hypothetical pre-existing account having a balance of one accumulation unit of the Government Money Market Variable Investment Option at the beginning of a specified
period, subtracting a hypothetical charge reflecting deductions from Contract Owner accounts, and dividing the difference by the value of the Variable Investment Option at the beginning of the base period to obtain the base period return, and then multiplying the base period return by (365/7), with the resulting figure carried to the nearest ten-thousandth of 1%. The effective yield is obtained by taking the base period return, adding 1, raising the sum to a power equal to 365 divided by 7, and subtracting 1 from the result, according to the following formula: Effective Yield ([base period return + 1]365/7)-1.
The yields on amounts held in the Government Money Market Variable Investment Option will fluctuate on a daily basis. Therefore, the stated yields for any given period are not an indication of future yields.
FINANCIAL STATEMENTS
The financial statements of the Account should be distinguished from the consolidated financial statements of Pruco Life and its subsidiaries, which should be considered only as bearing upon the ability of Pruco Life to meet its obligations under the Contracts.
[To be filed by pre-effective amendment.]