Product Specification#
Status: Draft, 2026-08-03.
Scope note: This is a standardized composite specification assembled for reference
liability-model implementation. It does not describe any single insurer’s product. Facts
carry source tags: [S#]/[R#] refer to the sources catalogued in sources.md (extraction
provenance in _research/indexed-ul.md); [REG-R#] refers to the cross-product
reference library (references/regulatory-and-actuarial-references.md; research
provenance in _research/regulatory-actuarial.md, same R-numbering). std marks a
standardization introduced for the reference implementation (choice among observed carrier
practices, or a placeholder where carrier values are not public); every std table row
has a footnote giving the rationale and the observed range. Items the research notes flag
as unverified remain flagged here. All “current” (non-guaranteed) rates are snapshots as
of each source document’s print date and change frequently [S3] [S4].
Product overview and market role#
Indexed universal life (IUL) is a flexible-premium universal life chassis in which cash
value allocated to indexed accounts earns interest “based in part on the performance of
market-based indexes”; the policy is not directly invested in the market [S1]. The NAIC
Valuation Manual defines an IUL policy as “any universal life (UL) insurance policy where
the interest credits are linked to an external reference” R3. Some carriers brand the
identical design “fixed index universal life” (FIUL) [S8]. Mechanically, IUL is
current-assumption UL plus one or more indexed accounts: all premium, charge, death
benefit, loan, and lapse provisions follow the UL pattern (base chassis:
products/universal_life/product-spec.md and the technical notes in that
directory); only the interest-crediting engine differs.
IUL is sold primarily for cash-value accumulation and distribution (policy loans in retirement); one carrier states a target market of ages 30–55 [S5]. Competition centers on illustrated performance: current illustrated rates for S&P 500-style accounts across 16 carriers ranged 5.61%–7.38% in a 3/2026 benchmarking snapshot [S6]. IUL policies are state-regulated fixed products; none of the five carriers researched references an SEC prospectus, and IUL products are generally not SEC-registered (unverified as a general proposition — EDGAR was not searched for product documents) [see research notes, Gaps].
The representative baseline below is deliberately the AG 49-A Benchmark Index Account (BIA) design — 1-year S&P 500 point-to-point, annual cap, 0% floor, 100% participation, no multipliers/bonuses/enhancements R1 — because it is the one account design every researched carrier offers [S2] [S3] [S5] [S6] and the regulatory canonical form R1.
Representative specification#
Table 1 — Chassis and coverage#
Parameter |
Representative value |
Basis |
|---|---|---|
Policy type |
Flexible-premium indexed universal life |
[S1] [S3] R3 |
Issue ages |
0–85 |
[S3] |
Age basis |
Age nearest birthday (ANB) |
std (F1) |
Minimum face amount |
$100,000 |
[S5] [S7] (F2) |
Underwriting classes |
Preferred Elite / Preferred Plus / Preferred / Non-Tobacco / Preferred Tobacco / Tobacco / Juvenile (0–17) |
[S3] |
Death benefit options |
A (level), B (increasing = face + account value) |
[S3] [S5] [S7] (F3) |
DB option changes |
Allowed after policy year 3, once per year, not after age 95 |
[S3] |
Tax qualification test |
Guideline Premium Test + cash value corridor (§7702) |
std (F4) |
Corridor factors |
250% at attained ages 0–40 grading to 100% at ages 90–95 |
|
Maturity age |
Attained age 121; policy continues in force, no further charges unverified |
std (F5) |
No-lapse guarantee |
Cumulative-premium test; no-lapse period by issue age: 0–45: 20 yrs; 46–60: to age 65; 61+: 5 yrs |
[S3] (F6) |
Grace period |
61 days |
[S3] |
Reinstatement |
Within 3 years of lapse, evidence of insurability; lapsed time does not count toward surrender-charge period |
[S3] |
Face increases |
After year 1, to age 85, min $25,000, underwritten; new charge/surrender layers |
[S3] |
Face decreases |
After year 3, min $25,000, ≤20% p.a. before later of age 65 / end of surrender period, subject to §7702 |
[S3] |
Footnotes:
F1 std: Observed both ways — one carrier uses age last birthday [S3], another age nearest birthday [S7]. ANB chosen because the 2017 CSO / 2015 VBT table families publish ANB variants directly usable for guaranteed and best-estimate mortality REG-R17 REG-R18.
F2: Observed range $25,000 (band 1 of one carrier) [S3] to $100,000 (two other carriers) [S5] [S7]. $100,000 chosen as the modal modern accumulation-IUL minimum; also the threshold for preferred classes at the $25,000-minimum carrier [S3].
F3: A Graded option (increasing to 70, grading level at 95) [S3] and a Return of Premium option [S5] exist; excluded from baseline as minority designs.
F4 std: §7702 allows CVAT or GPT+corridor R4. GPT chosen because one carrier’s Overloan Protection Rider attaches only to GPT non-MEC policies [S3], indicating GPT as the operative accumulation-IUL administration basis; CVAT documented as a variation.
F5 std: No retrieved document states maturity mechanics explicitly; age 121 is inferred (unverified) from charges running to age 120 and a rider (Additional Insured) terminating at base insured age 121 [S3]. Confirm against specimen policy forms before relying on it.
F6: Structure and periods from one carrier’s Minimum Monthly No-Lapse Premium (MNLP) design: no lapse during the no-lapse period while cumulative premiums less loans/withdrawals ≥ cumulative MNLP [S3] [S4]. Comparators: 20 yrs (issue ages 0–55) / (75 − issue age) yrs (56–69) / 5 yrs (70+) at a second carrier [S5]; an age-90 NLG rider plus an optional lifetime-duration rider at a third [S1].
Table 2 — Accounts and index crediting (baseline = AG 49-A Benchmark Index Account design R1)#
Parameter |
Representative value |
Basis |
|---|---|---|
Fixed account, current rate |
4.50% (first-year rate locked) |
[S2] (F7) |
Fixed account, guaranteed minimum |
1.00% |
[S2] (F7) |
Indexed account: index |
S&P 500 price return (dividends excluded) |
[S2] [S3] [S5] R1 |
Crediting method |
Annual point-to-point (1-year segment term) |
[S2] [S3] [S5] R1 |
Participation rate |
100%, guaranteed |
[S2] R1 |
Current cap |
10.00% (snapshot, 11/2024 print; caps are redeclared at each segment start and highly variable) |
[S2] (F8) |
Guaranteed minimum cap |
2.00% |
[S2] (F8) |
Floor |
0% annual, guaranteed |
[S2] [S5] [S6] [S8] R1 (F9) |
Segment starts (sweep dates) |
Monthly, on the policy monthiversary |
std (F10) |
Segment term / max segments |
12 months; up to 12 concurrent segments per account |
[S3] [S4] |
Holding (interim) account |
Net premium held in the fixed account and credited at fixed-account rates until the next sweep date |
[S1] std (F10) |
Matured segment value |
Rolls into a new segment per standing allocation instructions |
[S3] std (F11) |
Mid-segment values |
Death benefit/CSV reflect segment balance without unrealized index credit; amounts leaving a segment mid-term receive no index credit |
[S3] (F9) |
Footnotes:
F7: Fixed-account guarantees observed 1.00% [S2] [S5] to 2.00% [S3] [S4]; currents 4.25% [S5] to 4.50% [S2]. The [S2] pair (4.50%/1.00%) is used as the internally consistent snapshot.
F8: Current caps observed for 1-yr S&P 500 PTP accounts: 10.00% [S2], 10.25% [S5], 10.50% [S7], 12.00%–13.75% (same product, two print dates — caps fell between prints) [S3] [S4]. Guaranteed minimum caps observed 0.25% [S8] to 4.00% on a charge-funded high-cap account [S2]; one carrier instead guarantees the cap never below its current declared-account rate [S3] [S4]. Treat any current cap as a calibration snapshot, not a fixed parameter.
F9: Floor-design variation: one carrier credits a guaranteed 0.75% during the segment and nets it out of excess index interest [S3]; another expresses its guarantee as a 2% cumulative average tested at death or termination [S7]. The 0% annual floor is the dominant design [S2] [S5] [S6] [S8] and the BIA definition R1; the retrospective cumulative guarantee is documented under Variations.
F10 std: Carrier practice varies: one carrier sweeps on the 15th of each month [S1]; another creates segments on monthly policy dates, transfers into index accounts only on the first day of a policy month [S3]. Baseline standardizes sweep = policy monthiversary so segment dates align with monthly processing. A third carrier’s minimum required fixed-interest strategy allocation (an estimate of the coming year’s charges held back in the fixed strategy) [S5] is documented as a variation, not baseline.
F11 std: Automatic re-entry per standing instructions per [S3] (its automatic transfer rule). Baseline: 100% of matured value rolls into a new segment of the same account; reallocation to the fixed account is a policyholder option.
Table 3 — Charges#
Parameter |
Representative value |
Basis |
|---|---|---|
Premium load |
5.00% of each premium, all years, current; 8.00% guaranteed maximum |
std (F12) |
Monthly policy fee |
$10.00/month current; $15.00 guaranteed maximum |
[S3] [S5] / std (F13) |
Per-unit (per-$1,000) charge |
$0.30 per $1,000 of face per month, policy years 1–10 current (re-starts on face increases); guaranteed maximum $0.40 payable all years |
structure [S3] [S5]; amounts std (F14) |
Cost of insurance (COI) |
Monthly rate × net amount at risk / 1,000; varies by age, sex, class, duration, band; guaranteed maximum = 2017 CSO ANB smoker-distinct ultimate; current = 65% of guaranteed |
structure [S3]; guaranteed basis std/REG-R17; current ratio std (F15) |
Indexed-account asset charge |
None in baseline (BIA has no charge-funded enhancement) |
R1 (F16) |
Surrender charge |
Per $1,000 of initial face (and of each increase layer), 10-year period; initial $25.00 per $1,000 declining linearly to 0 at year 11 |
period [S1] [S5] [S7]; scale std (F17) |
Withdrawal fee |
$25 per withdrawal; minimum withdrawal $500; CSV may not fall below $500 |
[S3] |
Footnotes:
F12 std: Observed at three carriers: 4% current all years / 6% guaranteed (6%/8% Puerto Rico) [S3]; 8% year 1, 6% years 2+ current / 10% guaranteed [S5]; a load of undisclosed amount [S1]. A level 5% current / 8% guaranteed is a mid-range standardization avoiding year-shape complexity.
F13: $10/month current is common to [S3] [S5]. Guaranteed maxima observed $12 [S3] and $20 [S5]; $15 std is a rounded mid-range value.
F14 std: Structure (currently charged years 1–10, guaranteed for all years, varying by issue age/sex/band/tobacco, re-start on face increases) is sourced [S3] [S5]; the dollar scales live in policy data pages and are not public (research notes, Gaps), so the level is a modeling placeholder chosen to be a realistic secondary expense charge; calibrate to pricing targets in use.
F15 std: COI structure and re-rating discipline (changeable up to guaranteed maximums, changes must be based on expectations of future cost factors) are sourced [S3]; NGE re-determination practice is governed by ASOP 2 REG-R26. Carrier COI tables are not public (research notes, Gaps). Guaranteed = 2017 CSO (the statutory valuation/nonforfeiture basis for new issues REG-R17) is the conventional guaranteed ceiling std; the 65% current-to-guaranteed ratio is a placeholder std — replace with a scale calibrated to 2015 VBT / ILEC experience plus margin REG-R18 REG-R19.
F16: Charge-funded high-cap/multiplier accounts exist across carriers — ongoing asset charges of 0.72%/yr [S3] or 0.80%/yr [S2], or up-front strategy charges of 0.65%–1.0% at segment creation [S5] — and fund a Supplemental Hedge Budget under AG 49-A R1. Excluded from baseline; see Variations.
F17 std: Period: 10 years is modal [S1] [S5] [S7] (15 years at one carrier [S3]); re-starts on face increases [S3] [S7]. Dollar scales are not public (research notes, Gaps); the $25/$1,000 linear-decline scale is a placeholder of realistic magnitude.
Table 4 — Loans and withdrawals#
Parameter |
Representative value |
Basis |
|---|---|---|
Standard (declared-rate) loan — charged |
3.00% effective annual, in arrears, all years |
std (F18) |
Standard loan — credited on collateral |
2.00% years 1–10; 3.00% (wash) years 11+ |
std (F18) |
Participating (indexed) loan — charged |
5.00% current; 8.00% guaranteed maximum |
[S5] [S7] (F19) |
Participating loan — credited |
Loaned value remains credited at indexed-account rates |
[S5] (F19) |
Loan sourcing |
Fixed account first, then pro rata across index accounts/segments |
[S3] |
Minimum loan |
$500 |
[S3] |
Withdrawals |
After free-look; pro rata across unloaned accounts; $500 minimum; $25 fee |
[S3] |
Illustration constraint |
Illustrated loan credited rate ≤ illustrated loan charged rate + 50 bps |
Footnotes:
F18 std: Observed declared-rate designs at three carriers: charged 2.75% current / 3% guaranteed, credited 2%, preferred loans years 11+ charged 2% current / 2.25% max on gains [S3] [S4]; charged 3.90% years 1–10, 3.00% years 11+ (0% net from year 11), credited 3.00% current / 1.00% guaranteed [S5]; charged 4%, credited 3% years 1–10 / 4% years 11+ [S7]. The standardization keeps the universal pattern (net loan spread ~1% early, →0% “wash” after year 10) with round numbers. The baseline liability model uses standard loans only std; participating loans are a variation.
F19: One carrier’s alternative loan: charged 5% current / 8% guaranteed max, credited at indexed strategy rates, may be mixed or switched [S5]; a second carrier’s indexed loans charged 5% [S7]; a third routes loaned value to a dedicated lower-par volatility-control account via rider (current par 160%, guaranteed min 20%) [S2]. At that second carrier a fixed-rate loan triggers a 12-month lockout on fixed-to-indexed transfers [S6]; short-term loans are interest-free if repaid within 90 days [S7].
Contractual mechanics#
Death benefit provisions#
Option A: DB = max(Face, corridor factor × account value). Option B: DB = Face + account value, similarly corridor-tested [S3] R4.
Corridor factors per §7702(d): 250% at attained ages 0–40 grading to 100% at 90–95 R4.
Death proceeds are reduced by outstanding loan balance and any unpaid monthly deductions std (universal UL practice; loan-netting implicit in loan design [S3] [S5]).
During a segment, the death benefit reflects the segment balance without unrealized index credit [S3] (0%-floor baseline: segments simply carry no interim interest, F9).
Account value mechanics#
Account value = fixed account + sum of active segment balances + loan collateral account
std (decomposition; components per [S1] [S2] [S3] [S5]). On each monthiversary, in the
processing order specified in technical-notes.md: premiums are received net of load;
monthly deductions (policy fee + per-unit charge + COI + rider charges) are taken from the
fixed account first, then pro rata from active segments std (sourcing convention;
carrier practice varies — one carrier sources loans fixed-first/pro-rata [S3] and adjusts
the index-credit base for mid-segment deductions [S3]); eligible fixed-account balance is
swept into a new 12-month segment [S3] std.
Index crediting#
For a segment created at time m with index level I(m):
index change r = I(m+12) / I(m) − 1 (price return, dividends excluded) [S2] [S3]
credited rate = max(floor, min(cap, par × r)) = max(0%, min(10.00%, 100% × r)) [S2] [S3]
index credit = credited rate × segment balance at maturity (after all deductions) **[std]**
The credit-base convention is standardized: the credit applies to the actual remaining segment balance at maturity, i.e., amounts withdrawn, borrowed (standard loans), or deducted mid-segment earn no index credit (withdrawal/loan forfeiture [S3]; extension to mid-segment deductions std). One carrier’s contractual variant instead credits (adjusted index change %) × (adjusted beginning value) − (interest already credited at the guaranteed minimum during the segment), where the adjusted beginning value subtracts withdrawals, loan transfers, and one-half of monthly deductions and index-account charges taken during the segment [S3] — documented as a variation because it presumes an in-segment guaranteed rate (0.75% [S3]) the baseline does not have.
Caps (and, on other designs, participation rates and spreads) are non-guaranteed elements
declared at each segment start [S3] [S4] [S8], subject to contractual guaranteed minima
(Table 2), and economically set by the option budget — see technical-notes.md,
option-budget section R1 R6.
Charges and credits#
Monthly deduction = policy fee + per-unit charge + COI on net amount at risk + rider charges (+ indexed-account asset charges on enhanced accounts, not in baseline) [S1] [S3] [S5]. COI rates may be re-rated up to guaranteed maximums based on expectations of future mortality, interest, persistency, expense, reinsurance, and tax experience [S3]; ASOP 2 governs the re-determination discipline REG-R26. The fixed account is credited monthly at the declared rate (guaranteed minimum 1.00% [S2]); segments receive their index credit only at maturity [S3].
Loans#
Standard loans move loaned value into a loan collateral account credited at a fixed rate while the loan accrues at the charged rate (Table 4) std/[S3] [S5]; the net cost grades to ~0% (“wash”) after year 10 [S3] [S5] [S7]. Participating loans leave loaned value exposed to indexed crediting while charging a fixed rate [S5] [S7] — positive expected spread, negative in 0%-floor years; baseline models standard loans only std (F18). Loans reduce the death benefit and, if unpaid, accrue against the account; an Overloan Protection Rider can convert the policy to paid-up status to prevent loan-induced lapse and tax recognition (one-time charge on exercise: 5% of policy value at ages 75–90 grading to 1% at 94–120) [S3].
Withdrawals#
Partial withdrawals after free-look, pro rata across unloaned accounts, $500 minimum, $25 fee [S3]; mid-segment withdrawals forfeit index credit on the withdrawn amount [S3]. Withdrawals reduce Option A death benefit dollar-for-dollar std (standard UL practice; not explicit in retrieved brochures). Withdrawals within the first 15 policy years associated with benefit reductions can be taxable under §7702(f)(7)(B) [S1].
Grace, lapse, reinstatement#
If cash surrender value cannot cover the monthly deduction and the no-lapse test fails, a 61-day grace period begins [S3]; the policy lapses if the required premium is unpaid at grace end. No-lapse test: cumulative premiums less loans/withdrawals ≥ cumulative minimum monthly no-lapse premium during the no-lapse period [S3] [S4] (representative MNLP rate: male non-tobacco issue age 45, band 1: $20.80 per $1,000 face annually [S3]). Reinstatement within 3 years with evidence of insurability [S3].
Renewal / conversion / maturity#
No renewal or conversion mechanics (permanent policy). Maturity at attained age 121 std, unverified inference (F5): charges cease at age 120 (one carrier’s index account monthly charge runs to age 120 [S3]) and coverage continues.
Riders#
In scope for the reference model:
No-lapse guarantee (integral or rider): age-banded no-lapse period with cumulative premium test [S3] [S5]; one carrier implements it as an automatically issued age-90 NLG rider (issue ages ≤79, DB options A/B) plus an optional flexible-duration NLG to lifetime [S1]. Modeled: the baseline MNLP test (Table 1, F6).
Overloan Protection Rider: on GPT non-MEC policies; converts to paid-up on exercise, preventing loan-induced lapse/taxation; one-time exercise charge 5% of policy value at ages 75–90 grading to 1% at 94–120 [S3]. Described; exercised-state modeling optional.
Out of scope (listed for completeness, all observed in research): term riders on base or additional insureds [S3]; children’s benefit [S3]; guaranteed insurability [S3]; waiver of monthly deductions / waiver of premium [S3]; accidental death benefit [S3]; accelerated death benefits for terminal/critical/chronic illness [S3]; long-term care riders [S1] [S3] [S5]; enhanced performance factor (multiplier) riders [S1]; surrender value enhancement [S5]; change of insured [S5]; income settlement endorsements [S3].
Variations across insurers#
Floor design. 0% annual floor is dominant [S2] [S5] [S6] [S8]; one carrier credits a guaranteed 0.75% during the segment, netted out of excess index interest (its declared account guarantees 2%) [S3]; another guarantees a 2% cumulative average tested retrospectively at death or termination [S7]. Choice: 0% annual floor — dominant practice and the AG 49-A BIA definition R1; the retrospective cumulative guarantee is a documented variation requiring a shadow accumulation in the model.
Index menu. Every carrier offers 1-yr S&P 500 PTP with cap and 100% participation [S2] [S3] [S5] [S6]. Beyond it: multi-index best-performer blends (a global 50/30/20 blend [S3]; a multi-index monthly-average 50/30/20 [S5]; a third such blend [S7]); uncapped S&P 500 with spread (5.75% spread [S5]) or declared participation (a dynamic-participation account, illustrations at 50% par [S2]); multi-year segments (2-yr cap 24%/5-yr par 110%, same carrier [S2]); uncapped volatility-controlled proprietary indexes at high participation (200% [S2], up to 320% [S5], 215% [S7], 160% [S8]). Choice: BIA-style S&P 500 account only — canonical R1, universal, and the post-2023 illustration regime caps other accounts’ illustrated leverage at the BIA’s anyway R1 R6.
Charge-funded enhancements. Ongoing asset charge (0.80%/yr buys cap 12.0% vs 10.0% at one carrier [S2]; 0.72%/yr on all index accounts at another [S3]) vs up-front segment charge (0.65%–1.0% buys cap 25.00%/13.25% vs 14.00%/10.25% at a third [S5]); multiplier riders for a monthly charge [S1]. Persistency bonuses: 0.20% annualized from year 16 (guaranteed if the premium test is met) [S5]; bonus products may carry higher surrender charges or lower caps [S8]. Choice: excluded — the BIA explicitly has no multipliers/bonuses/enhancements R1, and post-AG 49-A these designs cannot illustrate net benefit anyway R6.
Guaranteed crediting minima. Guaranteed minimum caps 0.25% [S8] – 4.00% [S2]; guaranteed participation 5% [S2] [S8] – 105% [S2]; cap floored at declared-account rate [S3]. Choice: 2.00% guaranteed cap, 100% guaranteed par [S2] — from the same source as the baseline current cap.
Premium loads. Level (4%/6% gtd [S3]) vs front-loaded (8%/6%, 10% gtd [S5]). Choice: level 5%/8% std (F12).
Surrender charge period. 10 years [S1] [S5] [S7] vs 15 years [S3]; all re-start on face increases [S3] [S7]. Choice: 10 years (modal).
Loan design. All carriers: declared-rate loan trending to ~0% net cost after ~year 10 plus an indexed/participating loan charged ~5% [S3] [S4] [S5] [S7]; one carrier dedicates a lower-par VC account to loaned value [S2]; another imposes a 12-month fixed→indexed lockout after fixed loans [S6]. Choice: both described; standard loan modeled in baseline std — it decouples loan modeling from index scenarios.
Interim-account and sweep mechanics. Sweep on the 15th [S1] vs first day of policy month [S3]; charge-holdback in the fixed strategy [S5]. Choice: monthiversary sweep, no holdback std (F10).
Regulatory context#
NAIC UL Model Regulation (Model #585). The UL chassis regulation: valuation, nonforfeiture, mandatory policy provisions, disclosure, annual policyowner statements. Section 10 adds interest-indexed UL requirements: filings describing how the insurer addresses the risk of the indexed rate falling, description of assets held for interest-indexed policies, and an annual Statement of Actuarial Opinion for interest-indexed UL R10 REG-R5. Do not substitute the AP&P Appendix A print for it. Appendix item A-585 has now been read in full and carries the valuation half only — definitions and valuation requirements, with no nonforfeiture provisions, no mandatory policy provisions, no annual-report requirements and no interest-indexed UL section; it names only the Standard Valuation Law (#820) as its relevant model law and does not name Model #585 anywhere, so everything in this bullet stays cited to R10 REG-R5 REG-R155.
NAIC Life Illustrations Model Regulation (Model #582) + AG 49-A. Model 582 defines the disciplined current scale, self-support and lapse-support tests, and the illustration actuary’s annual certification R2. AG 49-A (policies sold on/after 12/14/2020, as revised 2023 — colloquially “AG 49-B”) layers IUL-specific limits: the Benchmark Index Account definition, the maximum illustrated rate (25-year lookback mean capped at 145% of the Annual Net Investment Earnings Rate), illustrated option-leverage of other accounts capped at the BIA’s, the 50 bp loan-spread limit, and alternate-scale disclosure R1 REG-R10. History and design intent per the SOA lineage article R6 REG-R9; practice guidance in the AAA Life Illustrations Practice Note and ASOP No. 24 (current revision Dec. 2024) R8 REG-R30.
Valuation: Standard Valuation Law + VM-20. Statutory reserves for IUL follow the Valuation Manual as a life product under VM-20 (net premium reserve plus deterministic/ stochastic reserves as applicable); VM-01 defines “index credit” broadly (any credit, multiplier, bonus, or charge reduction linked to an index; may be positive or negative); VM-20 requires cash-flow modeling of the assets hedging indexed credits under the clearly-defined-hedging-strategy (CDHS) framework R3 REG-R3; enabling statute Model #820 REG-R1; NLG (secondary-guarantee) designs interact with AG 38 for pre-PBR cohorts REG-R7. The formulaic leg — pre-2017 issues, and the All Other net premium reserve where VM-20 §3.B.6 routes indexed UL with no deterministic or stochastic reserve to VM-A/VM-C — is the A-585 universal life CRVM adaptation, now read at first hand: a guaranteed-maturity-premium / guaranteed-maturity-fund construction, not the §5.A modified-net-premium one, whose GMP is solved on policy guarantees at issue “excluding guarantees linked to an external referent”, i.e. with the index-linked crediting stripped out. That exclusion is the only index-specific reserve rule in the item; every rate, table and factor it uses is delegated to A-820 by year of issue REG-R155 REG-R153 REG-R110. Mechanics, the alternative minimum reserve and the A-830 ULSG branch are read at first hand in
_research/appp-a585-a250-a255-a270.mdand_research/appp-a830.md.Nonguaranteed elements. Caps, participation rates, declared rates, COI rates, and loads are NGEs; determination and revision practice is governed by ASOP No. 2 REG-R26.
Federal tax. §7702 definition of life insurance (CVAT or GPT+corridor; floating “insurance interest rate” replacing fixed 4%/6% for post-2020 issues) R4; §7702A MEC 7-pay test with §72 taxation of MEC distributions R5; tax reserves per IRC §807 (greater of net surrender value and 92.81% of the NAIC-method reserve, capped at statutory) REG-R16.