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Table of Contents 1. Executive Summary 2. The Contingent Annuity Product and Value to Consumers and the Public 3. Classification of the Contingent Annuity: an Annuity or Financial Guaranty Product 4. Classification of the Contingent Annuity: Life Insurance or Casualty Insurance 5. Comparison to Other Products under the Existing Life Insurance Regulatory Framework 6. Need for the Product  Basic Consumer Need  How Basic Consumer Needs are Served 7. Product Structure and Costs  Contractual Structure  Holder of Invested Assets  Types of Investment Options  Costs 8. Consumer Issues  Tax Treatment  Securities and Exchange Commission Treatment  Nonforfeiture Treatment  Portability  State Guaranty Fund Coverage  Suitability 9. Reserves, Capital, and Other Risk Management Considerations 10. Conclusion

Appendices A: B: C: D: E:

Analysis of Market and Longevity Risk of Contingent Annuities Contingent Annuity Product Comparison Chart Tax Law Treatment of Variable Annuity Minimum Living Benefits, Contingent Annuities and Financial Guaranty Insurance Federal Securities Law Treatment of Variable Annuity Living Benefits and Contingent Annuities Contingent Annuity Nonforfeiture Considerations 3

CAWG_final_comment_Letter_to_A_Committee_111028_0  
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