Nov. 22, 2023
SEC, Please clarify or consider the following. 1. Do all the new RILA disclosure requirements apply to unregistered indexed options (including disclosure of current rates). 2. Will the SEC staff apply the new RILA disclosure requirements to unregistered and registered products associated with variable life insurance? If so, consider amending N-6 as you do N-4. 3. Given recent cyber events affecting several insurance companies, please subject insurers to either the new cyber requirements for operating companies or the proposed requirements for investment companies. Thank you, Holly