Sec Form N3 - Registration Statement Under The Securities Act Of 1933 And/or Registration Statement Under The Investment Company Act Of 1940 Page 12

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11. The portfolio turnover rate to be shown at caption 10 shall be calculated as follows:
a.
The rate of portfolio turnover shall be calculated by dividing (A) the lesser of purchases or sales of portfolio
securities for the particular fiscal year by (B) the monthly average of the value of the portfolio securities owned by
the Registrant during the particular fiscal year. Such monthly average shall be calculated by totaling the values of the
portfolio securities as of the beginning and end of the first month of the particular fiscal year and as of the end of each
of the succeeding eleven months, and dividing the sum by 13.
b.
For the purposes of this Item, exclude from both the numerator and the denominator all securities, including options
whose maturities or expiration dates at the time of acquisition were one year or less. All long-term securities,
including United States Government securities, should be included. Purchases shall include any cash paid upon the
conversion of one portfolio security into another. Purchases shall also include the cost of rights or warrants purchased.
Sales shall include the net proceeds of the sale of rights or warrants. Sales shall also include the net proceeds of
portfolio securities which have been called, or for which payment has been made through redemption or maturity.
c.
If during the fiscal year the Registrant acquired the assets of another separate account in exchange for its own
accumulation units, it shall exclude from purchases the value of securities so acquired, and from sales all sales of
such securities made following a purchase-of-assets transaction to realign the Registrant’s portfolio. In such event,
the Registrant shall also make appropriate adjustment in the denominator of the portfolio turnover computation. The
Registrant must disclose such exclusions and adjustments in its answer to this Item.
d.
Short sales which the Registrant intends to maintain for more than one year and put and call options where the
expiration date is more than one year from date of acquisition are included in purchases and sales for purposes of this
Item. The proceeds from a short sale should be included in the value of the portfolio securities which the Registrant
sold during the reporting period and the cost of covering a short sale should be included in the value of the portfolio
securities which the Registrant purchased during the period. The premiums paid to purchase options should be
included in the value of the portfolio securities which the Registrant purchased during the reporting period and the
premiums received from the sale of options should be included in the value of the portfolio securities which the
Registrant sold during the period.
e.
A registrant that holds itself out as a money market fund is not required to provide a portfolio turnover rate in
response to this Item.
12. The number of accumulation units outstanding at the end of each period may be shown to the nearest thousand (000
omitted), provided it is indicated that such has been done.
(b) Give the following information as of the end of each of the Registrant’s last ten fiscal years for each class of senior securities
(including bank loans) of the Registrant. If consolidated statements were prepared as of any of the dates specified, the information
shall be furnished on a consolidated basis:
(1)
(2)
(3)
(4)
(5)
Total Amount
Average Market Value
Outstanding Exclusive
Asset Coverage
Involuntary Liquidating
Per Unit
Year
of Treasury Securities
Per Unit
Preference Per Unit
(Exclude Bank Loans)
Instructions
1.
Instructions 2, 3, and 6 to Item 4(a) also apply here.
2.
The method used to determine the averages shown above (e.g., weighted, monthly, daily, etc.) must be described.
3.
Column 5 is derived by dividing the amount shown in column 3 by the number shown in column 4.
(c) If all the required financial statements of the Registrant and the Insurance Company (see Item 28) are not in the prospectus, state,
under a separate caption, where the financial statements may be found. Briefly explain how any financial statements not in the
Statement of Additional Information may be obtained.
Item 5.
General Description of Registrant and Insurance Company
Concisely discuss the organization and operation or proposed operation of the Registrant. Include the information specified below.
(a) Briefly describe the Insurance Company including:
(i) its name, address, and a description of the general nature of its business;
Instruction
The description of the Insurance Company’s business should be short and need not list all of the businesses in which the Insurance
Company engages or identify the jurisdictions where it does business, if a general description (e.g., “life insurance” or “reinsurance”)
is provided.
7
SEC 2124 (5/15)

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