Form N-6 - United States Securities And Exchange Commission (Page 22 of 29) in pdf

Item 20. Underwriters

(a) Identification. Identify each principal underwriter (other than the Depositor) of the Contracts, and state its principal business

address. If the principal underwriter is affiliated with the Registrant, the Depositor, or any affiliated person of the Registrant or

the Depositor, identify how they are affiliated (e.g., the principal underwriter is controlled by the Depositor).

(b) Offering and Commissions. For each principal underwriter distributing Contracts of the Registrant, state:

(1) whether the offering is continuous; and

(2) the aggregate dollar amount of underwriting commissions paid to, and the amount retained by, the principal underwriter

for each of the Registrant’s last three fiscal years.

(c) Other Payments. With respect to any payments made by the Registrant to an underwriter of or dealer in the Contracts during the

Registrant’s last fiscal year, disclose the name and address of the underwriter or dealer, the amount paid and basis for determining

that amount, the circumstances surrounding the payments, and the consideration received by the Registrant. Do not include

information about:

(1) Payments made through deduction from premiums paid at the time of sale of the Contracts; or

(2) Payments made from cash values upon full or partial surrender of the Contracts or from an increase or decrease in the face

amount of the Contracts.

Instructions.

Information need not be given about the service of mailing proxies or periodic reports of the Registrant.

Information need not be given about any service for which total payments of less than $5,000 were made during each

of the Registrant’s last three fiscal years.

Information need not be given about payments made under any contract to act as administrative or servicing agent.

If the payments were made under an arrangement or policy applicable to dealers generally, describe only the arrangement

or policy.

(d) Commissions to Dealers. State the commissions paid to dealers as a percentage of premiums.

Item 21. Additional Information About Charges

(a) Sales Load. Describe the method that will be used to determine the sales load on the Contracts offered by the Registrant.

(b) Special Purchase Plans. Describe any special purchase plans (e.g., group life insurance plans) or methods that reflect scheduled

variations in, or elimination of, any applicable charges (e.g., group discounts, waiver of deferred sales loads for a specified

percentage of cash value, investment of proceeds from another Contract, exchange privileges, employee benefit plans, or the

terms of a merger, acquisition, or exchange offer made pursuant to a plan of reorganization). Identify each class of individuals

or transactions to which the plans or methods apply, including officers, directors, members of the board of managers, or

employees of the Depositor, underwriter, Portfolio Companies, or investment adviser to Portfolio Companies, and the amount

of the reductions, and state from whom additional information may be obtained. For special purchase plans or methods that

reflect variations in, or elimination of, charges other than according to a fixed schedule, describe the basis for the variation or

elimination (e.g., the size of the purchaser, a prior existing relationship with the purchaser, the purchaser’s assumption of certain

administrative functions, or other characteristics that result in differences in costs or services).

(c) Underwriting Procedures. Briefly identify underwriting procedures used in connection with the Contract and any effect of

different types of underwriting on the charges in the Contract. Specify the basis of the mortality charges guaranteed in the

Contracts.

(d) Increases in Face Amount. Describe in more detail the charges assessed on increases in face amount, including the procedures

used following an increase in face amount to allocate cash values and premium payments between the original Contract and

incremental Contracts.

Form N-6 - United States Securities And Exchange Commission Page 22