Form N-6 - United States Securities And Exchange Commission (Page 15 of 29) in pdf

(b) Portfolio Company Charges. State that charges are deducted from and expenses paid out of the assets of the Portfolio Companies

that are described in the prospectuses for those companies.

(c) Incidental Insurance Charges. If incidental insurance benefits (as defined in Rules 6e-2 and 6e-3(T) [17 CFR 270.6e-2, 17 CFR

270.6e-3(T)]) are offered along with the Contract, state that charges also will be made for those benefits.

Item 6. General Description of Contracts

(a) Contract Rights. Identify the person or persons (e.g., the Contractowner, insured, or beneficiary) who have material rights under

the Contracts, and the nature of those rights.

(b) Contract Limitations. Briefly describe any provisions for and limitations on:

(1) allocation of premiums among sub-accounts of the Registrant;

(2) transfer of Contract values between sub-accounts of the Registrant; and

(3) conversion or exchange of Contracts for another contract, including a fixed or variable annuity or life insurance contract.

Instruction. In discussing conversion or exchange of Contracts, the Registrant should include any time limits on conversion

or exchange, the name of the company issuing the other contract and whether that company is affiliated with the issuer of the

Contract, and how the cash value of the Contract will be affected by the conversion or exchange.

(c) Contract or Registrant Changes. Briefly describe the changes that can be made in the Contracts or the operations of the Registrant

by the Registrant or the Depositor, including:

(1) why a change may be made (e.g., changes in applicable law or interpretations of law);

(2) who, if anyone, must approve any change (e.g., the Contractowner or the Commission); and

(3) who, if anyone, must be notified of any change.

Instruction. Describe only those changes that would be material to a purchaser of the Contracts, such as a reservation of the

right to deregister the Registrant under the Investment Company Act. Do not describe possible non-material changes, such as

changing the time of day at which Contract values are determined.

(d) Other Benefits. Identify any other material incidental benefits in the Contracts.

(e) Class of Purchasers. Disclose any limitations on the class or classes of purchasers to whom the Contracts are being offered.

(f) Frequent Transfers among Sub-accounts of the Registrant.

(1) Describe the risks, if any, that frequent transfers of Contract value among sub-accounts of the Registrant may present for

other Contractowners and other persons (e.g., the insured or beneficiaries) who have material rights under the Contract.

(2) State whether or not the Registrant or Depositor has policies and procedures with respect to frequent transfers of Contract

value among sub-accounts of the Registrant.

(3) If neither the Registrant nor the Depositor has any such policies and procedures, provide a statement of the specific basis for

the view of the Depositor that it is appropriate for the Registrant and Depositor not to have such policies and procedures.

(4) If the Registrant or Depositor has any such policies and procedures, describe those policies and procedures, including:

(i) whether or not the Registrant or Depositor discourages frequent transfers of Contract value among sub-accounts of the

Registrant;

(ii) whether or not the Registrant or Depositor accommodates frequent transfers of Contract value among sub-accounts of

the Registrant; and

(iii) any policies and procedures of the Registrant or Depositor for deterring frequent transfers of Contract value among

sub-accounts of the Registrant, including any restrictions imposed by the Registrant or Depositor to prevent or minimize

Form N-6 - United States Securities And Exchange Commission Page 15