Annual Contract Expenses

The applicable fee percentage will not change for the life of the rider. The fee will be calculated and deducted quarterly, on the same day of the month as the rider effective date.

The Policy is unsuitable as a short-term savings vehicle. We designed the Policy to be a long-term investment. If you are not a long-term investor, this Policy may not be appropriate for you.

The following risks related to Index performance apply when you invest in an Index Account Option:

The specific investment risks associated with the market indexes and ETFs serving as Indexes are discussed under “Additional Investment Risks for the Market Indexes” and “Additional Investments Risks for the Exchange Traded Funds (ETFs)” respectively below.

Additional Investment Risks for the Market Indexes

The following Indexes are market indexes: S&P 500^® Index, Fidelity World Factor Leaders Index^SM 0.5% AR, and First Trust Equity Edge Index^TM. Each market index that may serve as an Index is subject to the following risks:

Additional Investment Risks Related to the Fidelity World Factor Leaders Index^SM 0.5% AR. In addition to the risks identified above that apply to each of the market indexes that may serve as an Index, the Fidelity World Factor Leaders Index^SM 0.5% AR is associated with additional investment risks, such as the following:

Additional Investment Risks Related to the First Trust Equity Edge Index^TM. In addition to the risks identified above that apply to each of the market indexes that may serve as an Index, the First Trust Equity Edge Index^TM is associated with additional investment risks, such as the following:

Additional Investments Risks for the Exchange Traded Funds (ETFs)

The following Indexes are ETFs: iShares^® Russell 2000 ETF and iShares^® U.S. Technology ETF. Each ETF that may serve as an Index is subject to the following risks:

Additional Investment Risks Related to the iShares^® Russell 2000 ETF. In addition to the risks identified above that apply to each of the ETFs that may serve as an Index, this ETF is subject to additional investment risks, such as the following:

Additional Investment Risks Related to the iShares^® U.S. Technology ETF. In addition to the risks identified above that apply to each of the ETFs that may serve as an Index, this ETF is subject to additional investment risks, such as the following:

You should fully understand the risks associated with any withdrawal or Surrender before you purchase the Policy and before you decide to take a withdrawal or Surrender. You should consult with your financial and tax professionals before you purchase the Policy or take a withdrawal or Surrender.

You should not purchase the Policy if the Guaranteed Lifetime Withdrawal Benefit is not appropriate for you. The GLWB is designed to help protect against the risk of poor investment performance and the risk of outliving your Policy Value. However, there is no guarantee that the GLWB will be sufficient to meet your future income needs, and there is no guarantee that you will realize any financial benefit from the GLWB. You should carefully weigh the benefits of the GLWB (and the additional ongoing charge for the optional step-up benefit) in light of the market downside protections that are already provided by the Index Account Options.

The GLWB guarantees the ability to take withdrawals up to at least a certain percentage of your Withdrawal Base each Rider Year beginning on the Income Declaration Date, regardless of investment performance, so long as you do not take Excess Withdrawals and other conditions are met. You decide when the Income Declaration Date will be by providing us notice in Good Order; however, the Income Declaration Date cannot be earlier than the Rider Anniversary after the Annuitant (or younger of the Annuitant or Annuitant’s spouse, for the joint life option) attains the Minimum Benefit Age. It could be several years before you can begin taking withdrawals of the Rider Withdrawal Amount.

All withdrawals under the GLWB – i.e., withdrawals of the Rider Withdrawal Amount and Excess Withdrawals – may result in surrender charges, negative Interim Value adjustments, taxes and tax penalties, as well as other negative consequences (e.g., reductions to your death benefit and proportionate reductions to the Index Bases for your Index Account Options). In addition, Excess Withdrawals will reduce the guarantee of your GLWB, perhaps significantly. The reduction to the guarantee will be greater than the amount withdrawn whenever your Withdrawal Base is subject to a proportionate reduction. If an Excess Withdrawal reduces your Policy Value to zero, the GLWB and the Policy will immediately terminate. Excess Withdrawals include (i) all gross withdrawals prior to the Income Declaration Date, and (ii) after the Income Declaration Date, gross withdrawals during a Rider Year in excess of the Rider Withdrawal Amount for that Rider Year. Surrender charges deducted from Policy Value upon withdrawal, if any, will count against your remaining Rider Withdrawal Amount for a Rider Year and may be deemed Excess Withdrawals.

After the Income Declaration Date, we guarantee that the Rider Withdrawal Amount for a Rider Year will never be less than the Withdrawal Base multiplied by the Withdrawal Percentage. Under the base GLWB (i.e., without the optional step-up benefit), the Rider Withdrawal Amount will never decrease from one Rider Year to the next, provided that you do not take any Excess Withdrawals. However, if you elect the optional step-up benefit, the Rider Withdrawal Amount may decrease, even if you never take an Excess Withdrawal. Under a GLWB with the optional step-up benefit, the Rider Withdrawal Amount will be calculated based on the greater of your Withdrawal Base and Policy Value. If your Policy Value is higher than your Withdrawal Base at the start of a Rider Year, withdrawals of the Rider Withdrawal Amount, fees and charges, negative Interim Value adjustments, and negative Index Credits may cause your Rider Withdrawal Amount for future Rider Years to be lower, even if you do not take an Excess Withdrawal. The optional step-up benefit is not appropriate for you if you want a guaranteed lifetime withdrawal benefit where the annual withdrawal amount is guaranteed not to decrease in the absence of excess withdrawals.

If the Policy is annuitized, all benefits from the accumulation phase terminate, including the GLWB. You do not get to keep any remaining Policy Value on the Annuity Commencement Date, as your remaining Policy Value will be applied to a fixed income option upon annuitization. If you elect to annuitize prior to the latest Annuity Commencement Date, there will be no fixed income option that allows you to continue the income stream provided by the GLWB. The income stream during the income phase will differ based on the fixed income option you select. Generally, you should not elect to annuitize the Policy before the latest Annuity Commencement Date unless the annual amount of your annuity payments would be greater than your annual Rider Withdrawal Amount. If the Policy reaches the latest Annuity Commencement Date, your Policy will automatically enter the income phase. Your GLWB will be terminated; however, in that situation, you may choose to continue the income stream provided by the GLWB by applying your remaining Policy Value to a fixed income option that provides for annual payments at least equal to your Rider Withdrawal Amount until the death of the Annuitant (single life) or later of the Annuitant and Annuitant’s spouse (joint life). Before annuitizing or selecting a fixed income option, you should consult with a financial professional and contact us for a comparison of the different payout options based on your Policy.  

If you elect the optional step-up benefit, which is available for an additional ongoing charge, you will begin accruing Guaranteed Lifetime Withdrawal Rider Fees immediately. You could end up paying these fees for many years before you can take withdrawals of the Rider Withdrawal Amount. You should consider that each time the fee is deducted from an Index Account Option before the end of the Crediting Period – and the fee is deducted quarterly – the deduction will result in an Interim Value adjustment, which may be negative, and a proportionate reduction to your Index Base. As such, the deduction could result in loss, perhaps significant and perhaps greater than the amount of the fee. You cannot terminate the step-up benefit (and stop paying the additional ongoing charge) without Surrendering or annuitizing the Policy (which will also terminate your GLWB).

The optional step-up benefit provides for the possibility of a step-up to the Withdrawal Base on the Income Declaration Date. A step-up will occur only if your Policy Value on the Income Declaration Date is greater than your Withdrawal Base. There is no guarantee that a step-up will occur on the Income Declaration Date, or that the benefit of a step-up will be more valuable than the Guaranteed Lifetime Withdrawal Rider Fees you incur. Withdrawals, negative Interim Value adjustments, proportionate reductions to your Index Bases, fees and charges, Index losses, and limits on Index gains may significantly reduce the possibility of a step-up. If your Income Declaration Date is before the end of any ongoing Crediting Period for an Index Account Option, a step-up may be significantly less likely, as your Policy Value as of the Income Declaration Date will be based on one or more Interim Values. You will continue paying rider fees after the Income Declaration Date, even if a step-up did not occur. If a step-up occurs after the third (3^rd  Rider Year, your Guaranteed Lifetime Withdrawal Rider Fees may be increased up to the maximum charge of 2.50%. You can reject any charge increase within 30 days following the Income Declaration Date, but you will forfeit the step-up and will continue to pay rider fees based on the original Guaranteed Lifetime Withdrawal Rider Fee Percentage.

See INCOME ADVANTAGE RIDER – GUARANTEED LIFETIME WITHDRAWAL BENEFIT.

Buffers do not provide complete protection from loss related to negative Index performance. You assume the risk that you will incur losses to the extent that an Index Account Option’s Buffer does not protect you from negative Index performance. The following table shows the maximum potential loss due to negative Index performance at the end of a Crediting Period for each Buffer Rate that we currently offer. Please note the maximum loss at the end of a Crediting Period could be greater due to fees and charges.

We may change index options in the future, but an Index Account Option with a 10% Buffer Rate will always be available under the Policy.

The limits on loss are for the duration of a single Crediting Period. If you invest in the same Index Account Option for multiple Crediting Periods, losses over multiple Crediting Periods may be larger than the stated limit for a single Crediting Period.

The maximum potential loss due to the application of a negative Interim Value adjustment is greater than the maximum potential loss at the end of a Crediting Period. In extreme circumstances, it is possible to lose 100% of your investment in any Index Account Option due to the application of a negative Interim Value adjustment (i.e., a complete loss of your principal and any prior earnings). Our Interim Value calculation methodology may result in values that are higher or lower than those obtained from using other methodologies or models. Our Interim Value calculation may be higher or lower than actual market prices of similar or identical derivatives. As a result, the Interim Value you receive may be higher or lower than what other methodologies or models would produce.

In general, depending on applicable rates, an Index Account Option with relatively more downside protection based on its Buffer Rate is likely to have relatively less upside potential based on its Cap Rate, Participation Rate, or Edge Rate and Edge+ Rate. Conversely, depending on applicable rates, an Index Account Option with relatively less downside protection based on its Buffer Rate is likely to have more upside potential based on its Cap Rate, Participation Rate, or Edge Rate and Edge+ Rate.

For any new Index Account Option that we offer in the future, we will set the rate(s) for its Downside Protection Type in our discretion, subject to any guaranteed limits to which we are subject as described in the prospectus.

Some Index Account Options are subject to a Credit Advantage Fee. If you select one for investment, you will pay an additional annualized fee of 1.25%. The additional fee will increase any losses or decrease any gains.

When you invest in an Index Account Option, the upside potential of your investment may be limited by its Growth Opportunity Type. For Cap, the Cap Rate may limit the upside potential of your investment by capping your participation in positive Index performance. For Participation, a Participation Rate of less than 100% will limit the upside potential of your investment by limiting your participation in positive Index performance. For Edge and Edge+, the Edge Rate and Edge+ Rate are fixed rates of potential return (in no event will a positive Index Credit Rate, if any, differ from the Edge Rate or Edge+ Rate, as applicable). In either case, the Index Credit Rate used to calculate gains may be lower than the Index Change. The risk of investment loss could be significantly greater than the potential for investment gain.

Although Index Account Options with Edge and Edge+ may provide for a positive Index Credit in the event of negative Index performance, like every other Index Account Option, they do not guarantee a positive Index Credit, and they are subject to risk of loss as described under “Buffer Risk.”

In general, depending on applicable rates, an Index Account Option with relatively more upside potential based on its Cap Rate or Participation Rate is likely to have relatively less downside protection based on its Buffer Rate. Conversely, depending on applicable rates, an Index Account Option with relatively less upside potential based on its Cap Rate or Participation Rate is likely to have more downside protection based on its Buffer Rate. Currently, all Index Account Options with Edge and Edge+ have the same Buffer Rate.

We may declare new Cap Rates, Participation Rates, or Edge Rates and Edge+ Rates for the available Index Account Options for new Crediting Periods. We set these rates in our discretion, within any guaranteed limits to which we are subject as described in this prospectus. You bear the risk that the rate(s) we declare for a new Crediting Period will not be any more or less favorable to you than any guaranteed limits to which we are subject.

Some Index Account Options are subject to a Credit Advantage Fee. If you select one for investment, you will pay an additional annualized fee of 1.25%. The additional fee will increase any losses or decrease any gains.

We calculate the Interim Value of your investment in an Index Account Option each Business Day between the first and last day of the Crediting Period. The Interim Value on any such Business Day determines the value of that Index Account Option for withdrawals, Surrender, annuitization, the death benefit, and Performance Lock, and to pay fees and charges.

On any Business Day between the first and last day of a Crediting Period, the Interim Value for an Index Account Option will not impact your Policy unless one of the following transactions occurs on that Business Day:

In any of those circumstances—including the deduction of a periodic fee or charge—the transaction will be processed based on the Interim Value for that Index Account Option on that Business Day, and an Interim Value adjustment will apply. An Interim Value adjustment (i.e., the interim rate of return) may be positive, negative, or equal to zero. The application of a negative Interim Value adjustment will result in loss, which may be significant.   

In extreme circumstances, it is possible to lose 100% of your investment in any Index Account Option due to the application of a negative Interim Value adjustment (i.e., a complete loss of your principal and any prior earnings).

If you have multiple ongoing Crediting Periods for Index Account Options that end at different times, any of the transactions listed above will be based on an Interim Value for some or all of your Index Account Options. For as long as you have multiple ongoing Crediting Periods for Index Account Options, there may be no time that any such transaction can be performed without the application of at least one Interim Value.

The Interim Value for an Index Account Option will generally change each Business Day, and the change may be positive or negative compared to the last Business Day, even when the Index has increased in value. Interim Values are not calculated based on Index performance, and an Index Account Option’s limit on Index gains and losses for the end of the Crediting Period does not apply to the calculation of Interim Value. As such, when a transaction is processed based on an Interim Value, the Interim Value could reflect less gain or more loss (perhaps significantly less gain or more loss) than would be applied at the end of the Crediting Period. This means that there could be significantly less money available under your Policy for fees and charges, withdrawals, a Surrender, annuitization, and the death benefit. If you use the Performance Lock feature to lock-in an Interim Value (less any Remaining Credit Advantage Fees and any other applicable charges) that is lower than the amount you invested in that Index Account Option on the Crediting Period start date, you may be locking-in a loss.

See INDEX ACCOUNT OPTIONS – INTERIM VALUE and EXPENSES AND ADJUSTMENTS – INTERIM VALUE ADJUSTMENT.

On the first day of the Crediting Period, your Index Base equals the dollar amount that you allocated to that Index Account Option. Your Index Base for that Index Account Option will not change unless a fee or charge is deducted from that Index Account Option, or if you take any type of withdrawal from that Index Account Option (including an automatic withdrawal, minimum required distribution, surrender charge-free withdrawal, a withdrawal of the Rider Withdrawal Amount, an Excess Withdrawal, or any other withdrawal), before the end of the Crediting Period, in which case your Index Base will be subject to a reduction at that time. The reduction is proportionate. It is derived by reducing your Index Base by the same percentage as the percentage reduction to your Interim Value due to the amount of the withdrawal or the fee or charge deducted (which is deducted from the Interim Value on a dollar for dollar basis).

A reduction to your Index Base could result in less gain (if any) or more loss at the end of a Crediting Period, perhaps significantly less gain or more loss, because the Index Credit Rate will be applied to a lower Index Base. All withdrawals taken, and fees and charges deducted, from an Index Account Option before the end of a Crediting Period will trigger a reduction to your Index Base, even fees and charges that are periodically deducted from your Policy. A reduction to your Index Base may be greater than the amount withdrawn or the fee or charge deducted. A reduction will also result in lower Interim Values for the remainder of the Crediting Period (because the interim rate of return will be applied to a smaller Index Base).

Once your Index Base for an Index Account Option has been reduced, there is no way to increase your Index Base for the remainder of the Crediting Period, and therefore no way to reverse or offset the negative impact of a reduction to your Index Base.

Reductions to your Index Base may have long-term, adverse impacts on your Policy. By reducing the potential gains under your Policy, and potentially resulting in more loss under your Policy, such reductions will ultimately reduce the amount available for withdrawal or Surrender throughout the accumulation phase, the amount payable as a death benefit during the accumulation phase, the likelihood of a step-up to your Withdrawal Base (if you select the optional step-up benefit for the GLWB) and the amount paid out during the income phase after annuitization.

See INDEX ACCOUNT OPTIONS – REDUCTION TO INDEX BASE.

On any Business Day between the first and last day of the Crediting Period for an Index Account Option, you may exercise the Performance Lock feature. If you exercise Performance Lock, your Interim Value for that Index Account Option (less any Remaining Credit Advantage Fees and any other applicable charges) on the Performance Lock Date is “locked-in” and transferred to the Performance Lock Account, where it will remain until the next Allocation Anniversary unless (a) earlier withdrawn or annuitized or (b) Early Re-Entry is exercised. The amount held in the Performance Lock Account will be credited compound interest daily based on the annual interest rate in effect on that day and will be reduced on a dollar for dollar basis for any fees, charges, or withdrawals deducted from the Performance Lock Account. You should consult with a financial professional prior to exercising Performance Lock.

The Performance Lock feature is subject to the following risks:

See INDEX ACCOUNT OPTIONS – PERFORMANCE LOCK+.

Early Re-Entry (currently not available with "Best Entry" Enhanced Index Account Options) allows you to reallocate into a previously locked Index Account Option for the remaining Crediting Period. By exercising Early Re-Entry, you will be re-exposing your investment to the possibility of Index losses, negative Interim Value adjustments, and reductions to your Index Base, as well any applicable Credit Advantage Fees. Given the abbreviated length of a remaining Crediting Period upon re-entry, the value of your investment could be more susceptible to loss from short-term negative Index performance. Early Re-Entry, once exercised, is irrevocable. You should consult with a financial professional before exercising Early Re-Entry, including consideration of your individual circumstances, as well as market conditions, index performance, time remaining in the crediting period, and all applicable rates. See EARLY RE-ENTRY for more information.

The original Buffer Rate will apply to the remaining Crediting Period; however, the Cap Rate, Participation Rate, or Edge and Edge+ Rate will be reset. The reset rate(s) for Early Re-Entry will be declared by us prior to each Allocation Monthiversary. The reset rate(s) will be lower than the original rate(s) for the Crediting Period. We expect that the reset rate(s) that we declare for Early Re-Entry will typically represent a proration of the original rate(s) for a Crediting Period based on the time remaining in the Crediting Period upon re-entry. However, you should understand that we reserve the right to declare reset Cap Rates, Participation Rates, and Edge and Edge+ Rates in our discretion, subject to the guaranteed minimum of 0.10%. You may obtain the current Re-Entry rates online at https://www.transamerica.com/rila-rate-center or upon request by contacting our Administrative Office or your financial intermediary.  Depending on the reset rate(s), the opportunity for Index gains for the remaining Crediting Period could be minimal. If the remaining Crediting Period is for an Index Account Option designated as Credit Advantage, you will be charged Credit Advantage Fees for that remaining Crediting Period. Exercising Early Re-Entry for an Index Account Option designated as Credit Advantage may cause you to incur substantial Credit Advantage Fees, in addition to the Credit Advantage Fees that you paid in full when you exercised Performance Lock. The Credit Advantage Fees paid prior to and upon the last exercise of Performance Lock will not be credited toward the Credit Advantage Fees owed for the remaining Crediting Period. The risk of incurring substantial Credit Advantage Fees is further magnified if you exercise Early Re-Entry multiple times during a single Crediting Period or over the life of the Policy.

We will not provide advice or notify you regarding whether you should exercise Early Re-Entry or the optimal time for doing so. We will not warn you if you exercise Early Re-Entry at a sub-optimal time. We are not responsible for any losses or additional fees incurred in relation to your decision to exercise Early Re-Entry. It may be better for you if you do not exercise Early Re-Entry.

See INDEX ACCOUNT OPTIONS – PERFORMANCE LOCK+.

Among the available Index Account Options, we currently offer certain Index Account Options with Growth Opportunity Types that are designated as “Credit Advantage.” You will pay an additional fee if you select one of these Index Account Options for investment. In exchange for the additional fee, these Index Account Options provide more upside potential, based on the rates we declare for their Growth Opportunity Types, than would be provided if their Growth Opportunity Types were not designated as “Credit Advantage.” There is no guarantee that the increased upside potential of a Credit Advantage Growth Opportunity Type will result in gains at least equal to the additional fee or any gains at all, or that an Index Account Option with a Credit Advantage Growth Opportunity Type will outperform an Index Account Option without a Credit Advantage Growth Opportunity Type. The additional fee will increase your losses or decrease your gains. Exercising Early Re-Entry for an Index Account Option designated as Credit Advantage may cause you to incur substantial Credit Advantage Fees, in addition to the Credit Advantage Fees that you paid in full when you exercised Performance Lock, especially if you exercise Early Re-Entry multiple times during a single Crediting Period or over the life of the Policy.

See EXPENSES AND ADJUSTMENTS – CREDIT ADVANTAGE FEE.

Each Best Entry option includes an Initial Index Value reset feature that may increase your gains or decrease your losses, but there is no guarantee that it will actually increase your gains or decrease your losses. It is possible that the Initial Index Value will not reset because the contingencies upon which the reset depends may not occur. Under such circumstances, the reset feature will ultimately have no impact on your gains or losses. Even if a reset occurs, the Best Entry option is still subject to the same risks associated with the Cap and the Buffer.

See INDEX ACCOUNT OPTIONS – ENHANCED INDEX ACCOUNT OPTIONS: BEST ENTRY.

When purchasing the Policy, you may have to decide whether to elect the GMDB rider for an additional charge. The GMDB rider may be added to your Policy at the time of purchase, provided that the Annuitant is younger than age 81 as of the date that the Policy application is signed.

The GMDB rider may be a standard or optional benefit depending on the Annuitant’s age as of the date that the Policy application is signed. If the Annuitant is younger than age 71, the GMDB rider is a standard benefit that is automatically added to your Policy for no additional charge. If the Annuitant is age 71 to 80, the GMDB rider is an optional benefit, which if elected, is subject to an additional ongoing charge. If the GMDB rider is optional and you choose not to elect it, the Policy Value / cash value death benefit will apply to your Policy for no additional charge.

If you are considering whether to elect the GMDB rider for an additional charge, the rider will not be appropriate for you if both (i) the Annuitant and Owner under your Policy will not be the same person and (ii) death benefit coverage on the Owner’s life is more important to you than death benefit coverage on the Annuitant’s life. The Policy’s death benefit is primarily designed to provide death benefit coverage upon the death of the Annuitant. Upon death during the accumulation phase of an Owner who is not also the Annuitant, there is only one possible death benefit amount: the Policy’s cash value (i.e., the Policy Value less any applicable surrender charges). The rider’s guaranteed minimum death benefit would not be payable because it only becomes payable upon the death of the Annuitant. If you elected the GMDB rider for an additional charge, you will have paid an additional fee for an optional feature that provided no financial benefit.

Before electing the GMDB rider, you should consider that each time the GMDB fee is deducted from an Index Account Option before the end of the Crediting Period – and the GMDB fee is deducted quarterly – the deduction will result in an Interim Value adjustment, which may be negative, and there will be a proportionate reduction to your Index Base. As such, the deduction could result in loss, perhaps significant and perhaps greater than the amount of the fee.

The GMDB rider is designed to provide a minimum death benefit, not necessarily an enhanced death benefit. The guaranteed minimum death benefit equals total premium payments reduced for withdrawals (including automatic withdrawals, minimum required distributions, withdrawals under the GLWB, and any other withdrawal). Even if you elected the GMDB rider, upon death during the accumulation phase of the Annuitant, if the Policy Value (i.e., the total value of your investment in the Accounts, with no deduction for any surrender charges) is greater than the guaranteed minimum death benefit under the GMDB rider, the death benefit will be the Policy Value, same as the alternative Policy Value / cash value death benefit. If you elected the GMDB rider for an additional charge, you will have paid an additional fee for an optional feature that provided no financial benefit.

See DEATH BENEFIT for additional information.

The optional Additional Death Benefit makes an additional amount payable as an additional death benefit only if the Annuitant dies during the accumulation phase. There is no guarantee that the additional death benefit will become payable. If the additional death benefit does not become payable, you will have paid additional fees for an optional feature that provided no financial benefit. Withdrawals will reduce the additional death benefit, perhaps significantly.

If you elect the optional Additional Death Benefit, you will be subject to additional ongoing charges. Before electing the Additional Death Benefit, you should consider that each time the additional fees are deducted from an Index Account Option before the end of the Crediting Period – and their fees are deducted quarterly – the deduction will result in an Interim Value adjustment, which may be negative, and there will be a proportionate reduction to your Index Base. As such, the fee deductions could result in loss, perhaps significant and perhaps greater than the amount of the fee.

See INCOME ADVANTAGE RIDER – ADDITIONAL DEATH BENEFIT.

Following the sixth (6^th) Rider Anniversary and every Rider Anniversary thereafter during the accumulation phase, you may be eligible to reset the terms of your Income Advantage Rider by performing a Rider Reset. Upon performing a Rider Reset, your existing Income Advantage Rider will be terminated, and a new Income Advantage Rider will be immediately added to your Policy. If you choose to perform a Rider Reset, your new Income Advantage Rider will be subject to the terms that we are offering on the date that we receive your Rider Reset request in good order, as disclosed in the Rate Sheet Supplement then in effect. Your Income Advantage Rider benefits (and fees, if any) will be subject to recalculation based on the terms of your new Income Advantage Rider.  

Your Income Advantage Rider elections cannot be changed in connection with a Rider Reset. You will not be eligible for a Rider Reset unless all applicable Issue Age restrictions are satisfied. There is no guarantee that electing a Rider Reset will be financially advantageous. A Rider Reset could ultimately result in higher fees or lower benefits. No fees paid for the prior Income Advantage Rider, if any, will be returned. You should elect a Rider Reset only if you determine, based on a comparison of terms applicable to your existing benefit(s) and the new benefit(s), that it is better for you to perform a Rider Reset. You should consult with a financial professional prior to exercising a Rider Reset.  

See RIDER RESET for additional information, including factors you should consider when deciding whether to perform a Rider Reset.

During a Crediting Period, if a market index serving as an Index is discontinued or if the calculation of the index is substantially changed by the index provider, or if Index Values should become unavailable for any reason, or if an ETF that is serving as an Index is liquidated or otherwise no longer exists or if its investment objectives, strategies, or risks substantially change, we may substitute the Index with a new Index, once we obtain all necessary regulatory approvals. We will notify you of any such substitution in writing.

If we substitute an Index, we will select a new Index that we determine in our judgment is comparable to the old Index. We may look at factors that include, but are not limited to, asset class, index composition, strategy, and index liquidity. You will have no right to reject the substitution of an Index. The performance of the new Index may differ significantly from the performance of the old Index. If we substitute the Index for an Index Account Option in which you are invested, your investment in the Policy is subject to the same terms and conditions as any other investment in an Allocation Account under the Policy. For example, you will not be permitted to transfer Policy Value prior to the end of a Crediting Period if a substitution occurs.

If we substitute an Index during a Crediting Period, we will calculate the Index Change using the original Index up until the substitution date. After the substitution date, we will calculate the Index Change using the replacement Index, but with a revised Initial Index Value for the replacement Index. The revised Initial Index Value for the replacement Index will reflect the Index Change for the original Index from the start of the Crediting Period to the substitution date. We will use a similar process if multiple substitutions occur during a Crediting Period. The substitution of an Index will have no impact on the Index Account Option’s Crediting Period, Growth Opportunity Type, Downside Protection Type, or any other features or rates for that Index Account Option other than the Index to which the Index Account Option is linked.

See INDEX ACCOUNT OPTIONS – INDEXES – Index Substitutions.

You may cancel your Policy after you purchase it, but only if you cancel it within the prescribed period, which is generally 10 days after you receive the Policy (or 30 days for replacement Policies) but could vary by state. Upon cancellation, the amount refunded will generally be the return of premium payments less prior withdrawals unless a different amount is required by law. If you invest in an Index Account Option when you purchase the Policy, you will be subject to risk of loss during the right to cancel period because the amount refunded upon cancellation (Policy Value) will be subject to an Interim Value adjustment, which may be negative, if your Policy Value is allocated to an Index Account Option. See INTERIM VALUE RISK above. State variations may apply to your right to cancel period. See APPENDIX D - STATE VARIATIONS.