N-4
May 01, 2026
USD ($)
yr
Contracts
Dec. 31, 2025
Dec. 31, 2024
Dec. 31, 2023
Dec. 31, 2022
Dec. 31, 2021
Dec. 31, 2020
Dec. 31, 2019
Dec. 31, 2018
Dec. 31, 2017
Dec. 31, 2016
Positive returns are credited based on a
“Crediting Strategy” that may limit or enhance your returns on the Term End Date. An IPCS may also
include a Performance Lock feature that allows you to lock in the value of the IPCS before the end of
the Strategy Term.
You could lose a significant amount of money if the Index
declines in value.
The Buffer Protection Strategy absorbs negative Index Performance
by protecting against losses up to the Buffer Rate on the Term End Date. The Buffer Rate is the
maximum loss we will protect you from at the end of the Strategy Term.
For
example, if the Index return is -25% and the Buffer Rate is -10%, we will credit -15% (the amount
that exceeds the Buffer Rate) at the end of the Strategy Term, meaning the amount you invested in
the IPCS will decrease by 15%.
| FEES, EXPENSES, AND ADJUSTMENTS |
LOCATION IN THE PROSPECTUS | |
| Are There Charges or Adjustments for Early Withdrawals? |
Yes. If you withdraw money from your Contract within 6 years following Contract issuance, you may be assessed a surrender charge of up to 8% of the amount withdrawn in excess of the free withdrawal amount. The free withdrawal amount is the greater of (i) 10% of your Contract Value as of the most recent Contract Anniversary (or, in the first Contract Year, 10% of your premium payment) or (ii) your RMD under our automatic RMD program. For example, if you take an early withdrawal, you could pay a surrender charge of up to $7,200 on a $100,000 investment, assuming your Contract Value is $100,000 at the time of the withdrawal. This loss will be greater if there is a negative Interim Value adjustment, taxes, or tax penalties. If all or a portion of your Contract Value is removed from an IPCS prior to the end of the Strategy Term, it will be subject to an adjustment due to the Interim Value, which may be negative. A negative Interim Value adjustment could result in losses as high as 100%. The maximum loss could occur in extreme circumstances due to a negative Interim Value adjustment.. For example, if you allocate $100,000 to an IPCS with a 3 year Strategy Term and later withdraw the entire amount before the 3 years have ended, you could lose up to $100,000 of your investment. This loss will be greater if you also have to pay a surrender charge, taxes, and tax penalties. Transactions that are subject to an Interim Value adjustment include (i) taking a withdrawal or surrendering your Contract, including the deduction of applicable surrender charges and/or premium taxes, (ii) exercising the Performance Lock feature (if available), (iii) annuitization, (iv) the payment of the Standard Death Benefit, and (v) exercising your right to return the Contract (unless the return of premium is greater). |
Fee Tables Charges and Adjustments |
| Are There Transaction Charges? |
No. Other than surrender charges and any negative Interim Value adjustments, there are no charges for other Contract transactions. |
|
| Are There Ongoing Fees and Expenses? |
Yes . Although we do not charge you a direct fee to invest in the IPCS options, there is an implicit ongoing fee associated with the IPCS because the amount you can earn on an IPCS will be limited to the extent the Index return exceeds (i) the Cap Rate (if any) under the Cap with Par Crediting Strategy or the Cap with Par & Spread Crediting Strategy, or (ii) the Trigger Rate under the Trigger Rate Crediting Strategy. Your returns will also be reduced by the Spread under the Cap with Par & Spread Crediting Strategy. The application of the Crediting Strategy may cause your returns under the IPCS to be lower than the Index’s returns. In return for accepting this limit on Index gains, you receive some protection from Index losses through the Protection Strategy. Your returns could be limited if the Participation Rate is below 100%. |
Investment Strategies – Crediting Strategies. |
Yes.
If you withdraw money from your Contract within 6 years following Contract
issuance, you may be assessed a surrender charge of up to 8% of the amount
withdrawn in excess of the free withdrawal amount. The free withdrawal
amount is the greater of (i) 10% of your Contract Value as of the most recent
Contract Anniversary (or, in the first Contract Year, 10% of your premium
payment) or (ii) your RMD under our automatic RMD program.
For example, if you take an early withdrawal, you could pay a surrender charge
of up to $7,200 on a $100,000 investment, assuming your Contract Value is
$100,000 at the time of the withdrawal. This loss will be greater if there is a
negative Interim Value adjustment, taxes, or tax penalties.
If all or a portion of your Contract Value is removed from an IPCS prior to the
end of the Strategy Term, it will be subject to an adjustment due to the Interim
Value, which may be negative. A negative Interim Value adjustment could
result in losses as high as 100%. The maximum loss could occur in extreme
circumstances due to a negative Interim Value adjustment.. For example, if you
allocate $100,000 to an IPCS with a 3 year Strategy Term and later withdraw
the entire amount before the 3 years have ended, you could lose up to $100,000
of your investment. This loss will be greater if you also have to pay a surrender
charge, taxes, and tax penalties. Transactions that are subject to an Interim
Value adjustment include (i) taking a withdrawal or surrendering your Contract,
including the deduction of applicable surrender charges and/or premium taxes,
(ii) exercising the Performance Lock feature (if available), (iii) annuitization,
(iv) the payment of the Standard Death Benefit, and (v) exercising your right to
return the Contract (unless the return of premium is greater).
allocate $100,000 to an IPCS with a 3 year Strategy Term and later withdraw
the entire amount before the 3 years have ended, you could lose up to $100,000
No.
Other than surrender charges and any negative Interim Value adjustments, there
are no charges for other Contract transactions.
Yes
.
Although we do not charge you a direct fee to invest in the IPCS options,
there is an implicit ongoing fee associated with the IPCS because the
amount you can earn on an IPCS will be limited to the extent the Index
return exceeds (i) the Cap Rate (if any) under the Cap with Par Crediting
Strategy or the Cap with Par & Spread Crediting Strategy, or (ii) the
Trigger Rate under the Trigger Rate Crediting Strategy. Your returns will
also be reduced by the Spread under the Cap with Par & Spread Crediting
Strategy. The application of the Crediting Strategy may cause your returns
under the IPCS to be lower than the Index’s returns. In return for
accepting this limit on Index gains, you receive some protection from Index
losses through the Protection Strategy. Your returns could be limited if the
Participation Rate is below 100%.
Although we do not charge you a direct fee to invest in the IPCS options,
there is an implicit ongoing fee associated with the IPCS because the
amount you can earn on an IPCS will be limited to the extent the Index
return exceeds (i) the Cap Rate (if any) under the Cap with Par Crediting
Strategy or the Cap with Par & Spread Crediting Strategy, or (ii) the
Trigger Rate under the Trigger Rate Crediting Strategy. Your returns will
also be reduced by the Spread under the Cap with Par & Spread Crediting
Strategy. The application of the Crediting Strategy may cause your returns
under the IPCS to be lower than the Index’s returns. In return for
accepting this limit on Index gains, you receive some protection from Index
losses through the Protection Strategy. Your returns could be limited if the
Participation Rate is below 100%.
This Contract is not a short-term investment and is not appropriate for an
investor who needs ready access to cash. Withdrawals could result in surrender
charges during the first six years you own the Contract, and may be subject to
taxes and tax penalties (including a 10% tax penalty before age 59
1
∕
2
).
In addition, amounts removed from an IPCS prior to the end of the Strategy
Term may be subject to a negative Interim Value adjustment, which could result
in a loss that is greater than the level of protection the Protection Strategy
would provide on the Term End Date, or a gain that is lower than the return the
Crediting Strategy would provide on the Term End Date. The calculation of the
Interim Value in connection with a withdrawal could result in the loss of
principal and previously credited earnings, even if the Index is performing
positively, and such losses could be substantial.
Contract Value that is allocated to an IPCS may only be reallocated on the
Term End Date (which is also a Contract Anniversary) unless you exercise the
Performance Lock feature (if available). Contract Value that is allocated to the
FRS and any locked-in Index Strategy Value pursuant to the exercise of the
Performance Lock feature may be reallocated on the next Contract Anniversary.
If we do not receive your reallocation instructions at our Customer Service
Office by the close of business on the date the reallocation will be effected,
your Contract Value will be automatically reinvested in the same Investment
Strategies, if available (i.e., the Fixed Rate Strategy Value will be reinvested in
the FRS, the Index Strategy Value will be reinvested in the same IPCS), subject
to the new crediting rates. If the same IPCS is not available, the amount will be
automatically reallocated to an IPCS with the same Strategy Term, Index,
Protection Strategy, and Crediting Strategy, if available (i.e., only the
availability of the Performance Lock feature is different). If such an IPCS is
not available, the amount will be automatically reallocated to the 1-Year
Strategy Term / -10% Buffer / S&P 500 Index / Cap with Par / with or without
Performance Lock (depending on availability). Any reallocation absent your
instruction may not be satisfactory to you.
Yes
.
Contract Value that is allocated to an IPCS may only be reallocated on the
Term End Date (which is also a Contract Anniversary), unless you exercise the
Performance Lock feature (if available). Contract Value that is allocated to the
FRS and any locked-in Index Strategy Value pursuant to the exercise of the
Performance Lock feature may be reallocated on the next Contract Anniversary.
●
Currently all IPCS options and Contract features are available through
financial professionals selling the Contract. Your financial professional
may not recommend certain IPCS options. You may obtain information
about the IPCS options that are available to you by contacting your
financial professional or our Customer Service Office.
●
Certain IPCS or Contract features may not be available in your state. See
Appendix B for state variations that may apply.
●
You may not allocate Contract Value to an IPCS if the Term End Date
would occur after the latest Annuity Commencement Date (i.e., the
Contract Anniversary immediately following the Annuitant’s 100th
birthday).
In addition, we reserve the right to:
●
Add or remove IPCS options;
●
Limit the availability of certain IPCS options to new Contract purchases;
●
Not include a Performance Lock feature in the future on certain or any
IPCS options;
●
Declare new Cap Rates, Participation Rates and Trigger Rates for each
new Strategy Term, subject to the stated minimum guaranteed rates for that
IPCS option;
We may not declare a Cap Rate for a particular Cap with Par and Spread
Strategy Term. For any such Strategy Term which we do declare a Cap Rate
the Participation Rate will always equal 100% (which means it will never be
greater than the minimum guaranteed rate of 100%).
●
Stop offering or replace a reference Index (including during a Strategy
Term) if it is discontinued, if the Index is substantially changed, if the
Index Values become unavailable, if we no longer have a license
agreement with the publishers of the Index, or if hedging instruments
become difficult to acquire or the cost of hedging becomes excessive. If
we replace an Index, we will attempt to select a new Index that has a
similar investment objective and risk profile to the original Index. The
replacement Index we select may not be satisfactory to you; and
●
Limit the number of IPCS options offered to one. We always intend to
offer the 1-Year / -10% Buffer / S&P 500 Index / Cap with Par IPCS
option, subject to our right to substitute the Index with one that is
substantially similar, which means we will always offer a strategy with a
-10% Buffer. If we exercise our right to offer only this IPCS option and
you are not satisfied, you may invest in the FRS or surrender the Contract,
but the surrender may incur surrender charges, may be subject to taxes
(including a 10% tax penalty before age 59
1
∕
2
) and, with respect to
amounts surrendered from an IPCS that has not been locked in prior to the
Term End Date, will be subject to an Interim Value adjustment.
The availability of IPCS may vary depending on the broker-dealer through
which the contract is sold.
Yes
.
The Performance Lock feature may not be available in the future on certain or
any IPCS options.
The Return of Premium Payment Death Benefit is subject to withdrawal
adjustments (including any applicable surrender charges), which may be more,
even significantly more, then the dollar amount withdrawn.
Although you may request a withdrawal at any time, withdrawals will always
be taken first from the FRS, then proportionally from locked-in IPCS options,
then proportionally from IPCS options that are at the Term End Date, and
finally proportionally from IPCS options that are not at the Term End Date.
You may not request a partial withdrawal to be withdrawn from a particular
Investment Strategy. This means that if you wish to withdraw money from a
specific IPCS without the Performance Lock feature before the Term End Date,
your only option will be to surrender the Contract, which may incur surrender
charges, may be subject to taxes (including a 10% additional tax before age
59
1
∕
2
), and, with respect to amounts surrendered from an IPCS prior to the
Term End Date, will be subject to an Interim Value adjustment.
The availability of IPCS options may vary depending on the broker-dealer
through which the contract is sold.
You should consult with a tax professional to determine the tax implications of
an investment in, withdrawals from, and payments received under the Contract.
There is no tax penalty benefit if you purchase the Contract through a
Traditional IRA or Roth IRA. Withdrawals are subject to ordinary income tax,
and you may be subject to a 10% tax penalty if you withdraw money before
age 59
1
∕
2
.
Your financial professional may receive compensation for selling the Contract
to you in the form of commissions and non-cash compensation. This
compensation may influence your financial professional to recommend the
Contract over another investment.
Some financial professionals may have a financial incentive to offer you a new
contract in place of the one you own. You should only exchange your contract
if you determine, after comparing the features, fees and risks of both contracts,
and any fees or penalties to terminate the existing contract, that it is better for
you to purchase the new contract rather than continue to own your existing
FEE TABLES
The following tables describe the fees, expenses, and adjustments that you will pay when buying, owning,
and surrendering or making withdrawals from an IPCS or from the Contract. Please refer to your
Contract specifications page for information about the specific fees you will pay each year based on the
options you have elected.
The first table describes the fees and expenses that you will pay at the time that you surrender or make
withdrawals from the Contract. State premium taxes may also be deducted.
Transaction Expenses
Surrender Charge (as a percentage of amount surrendered) 1 |
8% |
1
The surrender charge will be imposed when you take a partial withdrawal or surrender your Contract during the first six Contract
Years, unless an exception applies. Each year during the first six Contract Years, however, you may take withdrawals up to the “free
withdrawal amount” without incurring a surrender charge. The free withdrawal amount is the greater of (i) 10% of your Contract Value
as of the most recent Contract Anniversary (or, in the first Contract Year, 10% of your total premiums paid) or (ii) your RMD under
our automatic RMD program.
The surrender charge grades to 0% according to the following schedule:
Contract Year |
1 |
2 |
3 |
4 |
5 |
6 |
7+ |
Surrender Charge Percentage |
8% |
8% |
7% |
6% |
5% |
4% |
0% |
See
"
Charges and Adjustments
"
for more information.
The next table describes the adjustments, in addition to any transaction expenses, that apply if all or a
portion of the Contract Value is removed from an IPCS before the end of the Strategy Term.
Adjustments
Interim Value Adjustment Maximum Potential Loss (as a percentage of Contract Value ) 1 |
100% |
1
The maximum loss could occur in extreme circumstances due to a negative Interim Value adjustment. Transactions that are subject to
an Interim Value adjustment include (i) taking a withdrawal or surrendering your Contract, including the deduction of applicable
surrender charges and/or premium taxes, (ii) exercising the Performance Lock feature (if available), (iii) annuitization, (iv) the
payment of the Standard Death Benefit, and (v) exercising your right to return the Contract (unless the return of premium is greater).
See “Charges and Adjustments” for more information.
In addition to the fees described above, the amount you can earn on an IPCS will be limited to the extent
the Index return exceeds the Cap Rate (if any) under the Cap with Par Crediting Strategy or the Cap with
Par & Spread Crediting Strategy or the Trigger Rate under the Trigger Rate Crediting Strategy. Your
returns will also be reduced by the Spread under the Cap with Par & Spread Crediting Strategy. The
application of the Crediting Strategy may cause your returns under the IPCS to be lower than the Index’s
returns. In return for accepting this limit on Index gains, you will receive some protection from Index
losses through the Protection Strategy.
Transaction Expenses
Surrender Charge (as a percentage of amount surrendered) 1 |
8% |
1
The surrender charge will be imposed when you take a partial withdrawal or surrender your Contract during the first six Contract
Years, unless an exception applies. Each year during the first six Contract Years, however, you may take withdrawals up to the “free
withdrawal amount” without incurring a surrender charge. The free withdrawal amount is the greater of (i) 10% of your Contract Value
as of the most recent Contract Anniversary (or, in the first Contract Year, 10% of your total premiums paid) or (ii) your RMD under
our automatic RMD program.
The maximum loss could occur in extreme circumstances due to a negative Interim Value adjustment. Transactions that are subject to
an Interim Value adjustment include (i) taking a withdrawal or surrendering your Contract, including the deduction of applicable
surrender charges and/or premium taxes, (ii) exercising the Performance Lock feature (if available), (iii) annuitization, (iv) the
payment of the Standard Death Benefit, and (v) exercising your right to return the Contract (unless the return of premium is greater).
See “Charges and Adjustments” for more information.
The surrender charge grades to 0% according to the following schedule:
Contract Year |
1 |
2 |
3 |
4 |
5 |
6 |
7+ |
Surrender Charge Percentage |
8% |
8% |
7% |
6% |
5% |
4% |
0% |
PRINCIPAL RISKS
An investment in the Contract involves certain risks that you should consider prior to purchasing the Contract or
making investment decisions.
Market Risk
There is a risk of loss of principal and previously-credited earnings due to poor investment performance, and
such losses may be substantial. In recent years, the financial markets have experienced periods of significant
volatility and negative returns, contributing to an uncertain and evolving economic environment. Financial
markets have been impacted by several interrelating factors, including (but not limited to) pandemics,
geopolitical turmoil, rising inflation, economic recessions, interest rate fluctuations, and actions by governmental
authorities. Depending on the Investment Strategies you select and the timing of transactions you request (e.g.,
reallocations, withdrawals, exercise of the Performance Lock feature), you may experience significant negative
returns under the Contract.
Index – Linked Option Risks
Protection Strategies
The Protection Strategies provide downside protection from negative Index performance only on the Term End
Date, so your risk of loss is greater on any other date during the Strategy Term. For multi-year Strategy Terms,
the Protection Strategies are
not
applied on an annual basis; any negative Index Performance is measured from
the Term Start Date to the Term End Date. In other words, the limits on downside loss provided by the Protection
Strategy are applied to the Index Performance at the end of the Strategy Term, not during the Strategy Term or
over the life of the Contract.
If you invest in an IPCS, you will bear the portion of loss that exceeds your
Buffer Rate. If you invest in an IPCS with the lowest level of protection currently offered (the -10%
Buffer), you could experience losses up to 90% at the end of the Strategy Term due to negative Index
Performance. We always intend to offer the 1-Year / -10% Buffer / S&P 500 Index / Cap with Par IPCS
option, subject to our right to substitute the Index with one that is substantially similar, which means we
will always offer a strategy with a -10% Buffer.
If you reinvest your money in the same IPCS over the course
of multiple Strategy Terms, you may incur greater losses than the protection level provided by that IPCS over the
course of a single Strategy Term.
Crediting Strategies
The Crediting Strategies determine how positive Index performance is credited on the Term End Date, and may
limit or enhance your returns under the IPCS. The amount you can earn on an IPCS will be limited to the extent
the Index return exceeds (i) the Cap Rate (if any) under the Cap with Par Crediting Strategy or the Cap with Par
& and Spread Crediting Strategy, or (ii) the Trigger Rate under the Trigger Rate Crediting Strategy. Your returns
will also be reduced by the Spread under the Cap with Par & Spread Crediting Strategy. The application of the
Crediting Strategy may cause your returns under the IPCS to be lower than the Index’s returns. For multi-year
Strategy Terms, the Crediting Strategies are
not
applied on an annual basis; any positive Index Performance is
measured from the Term Start Date to the Term End Date. In other words, the Crediting Strategy will be applied
to the Index Performance at the end of the Strategy Term, not during the Strategy Term or over the life of the
Contract. Your investment in an IPCS is not an investment in the Index or the securities tracked by the Index.
Liquidity and Early Withdrawal Risk
The Contract is not designed to be a short-term investment, and it is not appropriate for an investor who intends
to take early or frequent withdrawals.
●
Surrender Charges.
If you take withdrawals or surrender your Contract during the first six Contract
Years, a surrender charge will apply to amounts that exceed the free withdrawal amount, unless an
exception applies
●
Negative Interim Value Adjustments.
If you withdraw money from an IPCS prior to the Term End Date,
the amount available for withdrawal from that IPCS is the Interim Value.
●
We calculate the Interim Value based on the value of a hypothetical portfolio of financial
instruments designed to replicate the Maturity Value (which is the Index Strategy Value on the
Term End Date). The Interim Value could be less than your investment even if the Index is
performing positively.
●
If you take a withdrawal, the calculation of the Interim Value could result in the loss of principal
and previously-credited earnings, and such losses could be substantial. A negative Interim Value
adjustment could result in losses as high as 100%. The maximum loss could occur in extreme
circumstances due to a negative Interim Value adjustment. Extreme circumstances causing a
negative Interim Value Adjustment can be connected to several factors, including but not limited to
trading costs and market price changes.
●
Partial withdrawals (including systematic withdrawals, RMDs, and any associated charges
deducted) from an IPCS that has not been locked in pursuant to exercise of the Performance Lock
feature on any day during the Strategy Term other than the Term Start Date and the Term End Date
will reduce the Strategy Value Base for the IPCS (which is the base amount that is used to
calculate the Interim Value prior to the Term End Date and the Maturity Value on the Term End
Date) by the same percentage that the withdrawal reduced the Index Strategy Value for that IPCS,
which may be more, even significantly more, than the dollar amount withdrawn. This means that if
you take a withdrawal at a time when the Interim Value is less than the Strategy Value Base, the
Strategy Value Base will be reduced by more than the amount withdrawn.
●
Because surrender charges are imposed when withdrawals are taken during the surrender charge
period and adjustments associated with the Interim Value calculation are applied when withdrawals
are taken prior to the Term End Date, these withdrawals can result in a loss of principal and
previously-credited earnings even if the Index has been performing positively.
●
In addition, the Interim Value calculation could result in a loss that is greater than the level of
protection the Protection Strategy would provide on the Term End Date, or a gain that is lower
than the return the Crediting Strategy would provide on the Term End Date.
●
The Interim Value is also the amount available from an IPCS if you surrender or annuitize the
Contract, exercise of the Performance Lock feature (if available) or your right to return the
Contract (unless the return of premium is greater), or if a Standard Death Benefit is paid prior to
the Term End Date.
●
Strategy Value Base.
●
Partial withdrawals (including systematic withdrawals, RMDs, and any associated charges deducted)
from an IPCS that has not been locked in pursuant to exercise of the Performance Lock feature on any
day during the Strategy Term other than the Term Start Date and the Term End Date will reduce the
Strategy Value Base for the IPCS by the same percentage that the withdrawal reduced the Index
Strategy Value for that IPCS. Such a reduction could be more, even significantly more, than the dollar
amount withdrawn.
●
The proportional reduction in your Strategy Value Base could be greater than the dollar amount of the
withdrawal depending on whether the Interim Value of the IPCS is higher or lower than the Strategy
Value Base of that IPCS at the time of the withdrawal. When the Interim Value is less than the Strategy
Value Base at the time of the withdrawal, the proportional reduction will always be greater than the
dollar amount withdrawn.
●
Withdrawals may have more of an adverse impact on the remaining Interim Value the earlier in the
Strategy Term a withdrawal is taken.
●
A lower Strategy Value Base will reduce any credit amount that may be applied on the Term End Date.
●
You cannot reallocate Contract Value into the IPCS to increase your Strategy Value Base during the
Strategy Term.
●
Death Benefit.
●
Withdrawals will reduce the Standard Death Benefit on a dollar-for-dollar basis.
●
The Return of Premium Payment Death Benefit is subject to withdrawal adjustments (including any
applicable surrender charges), which may be more, even significantly more, than the dollar amount
withdrawn. (See “Benefits Available Under the Contract – Death Benefit.”)
●
Withdrawal Limitation.
Amounts are withdrawn from the Investment Strategies in the order described in the
“Reallocations and Withdrawals” section. You may not request a partial withdrawal be withdrawn from a
particular Investment Strategy. This means that if you wish to withdraw money from a specific IPCS without
the Performance Lock feature before the Term End Date, your only option will be to surrender the Contract,
which may incur surrender charges, may be subject to taxes (including a 10% tax penalty before age 59
1
∕
2
),
and, with respect to any amounts surrendered from an IPCS prior to the Term End Date, will be based on the
Interim Value. The Interim Value could be less than your investment in the IPCS even if the Index is
performing positively. See “Charges and Adjustments – Interim Value Adjustment” for more information
about the calculation of the Interim Value.
●
Taxes.
Withdrawals and surrenders may result in adverse tax consequences, including a 10% tax penalty
before age 59
1
∕
2
.
●
Minimum Account Value.
If you take a withdrawal that would cause your Contract Value to fall below
$2,000, we may terminate your Contract.
Reallocation Restrictions
Contract Value that is allocated to an IPCS may only be reallocated on the Term End Date, unless (1) you
exercise the Performance Lock feature (if available) or (2) the IPCS is matured early and its value reallocated to
the FRS due to discontinuation of an Index. Contract Value that is allocated to the FRS and any locked-in Index
Strategy Value pursuant to the exercise of the Performance Lock feature may only be reallocated on the next
Contract Anniversary. Because of these restrictions, you may not be able to change your investment selections in
response to changes in market conditions during the investment term.
If you do not want to remain invested in your current allocations until these dates, you may surrender the Contract, which may incur surrender charges,
may be subject to taxes (including a 10% tax penalty before age 59
1
∕
2
), and, with respect to any amounts
surrendered from an IPCS prior to the Term End Date, will be based on the Interim Value. The Interim Value
could be less than your investment in the IPCS even if the Index is performing positively. See “Charges and
Adjustments – Interim Value Adjustment” for more information about the calculation of the Interim Value.
If we do not receive reallocation instructions in Good Order by the close of business on the Term End Date, your
current allocations will be reinvested for a new term (in the same IPCS, if available) using the new crediting
rates. If the Term End Date is a non-Business Day, reallocation instructions must be received in Good Order no
later than the close of business on the Business Day prior to the Term End Date. If the same IPCS is not
available, the amount will be automatically reallocated to an IPCS with the same Strategy Term, Index,
Protection Strategy, and Crediting Strategy, if available (i.e., only the availability of the Performance Lock
feature will differ). If such an IPCS is not available, the amount will be automatically reallocated to the 1-Year
Strategy Term / -10% Buffer / S&P 500 Index / Cap with Par / with or without the Performance Lock feature
(depending on availability). This reallocation may not be satisfactory to you.
Availability of IPCS Options
We reserve the right to add or remove IPCS investment options. We also reserve the right to limit the availability
of certain IPCS to new Contract purchases. An IPCS that is currently available may not be available for
reallocations or reinvestment at the end of the Strategy Term (or the next Contract Anniversary after you exercise
the Performance Lock feature, if applicable). Certain IPCS may not be available through your financial
professional. You may obtain information about the IPCS options that are available to you by contacting your
financial professional or our Customer Service Office.
We may limit the number of IPCS options offered to one. We intend always to offer the 1-Year / -10% Buffer /
S&P 500 Index / Cap with Par / with or without the Performance Lock feature (depending on availability),
subject to our right to substitute the Index, which means we will always offer a strategy with a -10% Buffer. This
means that it is possible that we may not offer IPCS options in the future that are attractive to you based on your
personal preferences, risk tolerances, or time horizon. If there are no investment options you wish to select, you
may surrender the Contract, but the surrender may incur surrender charges, may be subject to taxes (including a
10% tax penalty before age 59
1
∕
2
), and, with respect to any amounts surrendered from an IPCS prior to the Term
End Date, will be based on the Interim Value. The Interim Value could be less than your investment in the IPCS
even if the Index is performing positively. See “Charges and Adjustments – Interim Value Adjustment” for more
information about the calculation of the Interim Value.
Crediting Rates
We set crediting rates (including Cap Rates, Participation Rates and Trigger Rates, and the FRS interest rate) at
our discretion. The crediting rates for new Strategy Terms may be lower than your initial crediting rates, subject
to guaranteed minimums. You assume the risk that the crediting rates we set will be less favorable than you find
acceptable. Crediting rates for new Contract purchases may be more favorable than the crediting rates for
reallocations. We may declare different crediting rates for reallocations based on your Contract Date.
Performance Lock Risk
You may only exercise the Performance Lock feature once during a Strategy Term for each IPCS. After you
exercise the Performance Lock feature, your locked-in Index Strategy Value will not increase under any
circumstances (even if the Index Performance is positive), and your decision to exercise the Performance Lock
feature cannot be revoked. Withdrawals and charges deducted from a locked-in IPCS will reduce the locked-in
Index Strategy Value by the amount withdrawn or charge assessed, including any applicable surrender charge.
You will not know the Interim Value used to lock in your Index Strategy Value in advance. We use the Interim
Value calculated at the end of the Business Day on which we receive your request. You assume the risk that the
Interim Value that gets locked in will be lower than the Interim Value you last obtained. Reallocations are only
permitted on Contract Anniversaries. Depending on when you exercised the Performance Lock feature, your
investment might not participate in Index Performance for as long as one year. There may not be an optimal time
to exercise the Performance Lock feature. Your Maturity Value may be higher if you do not exercise the
Performance Lock feature. If the Performance Lock feature is exercised for an IPCS, no Crediting or Protection
Strategy is applied to the IPCS
at any time
, including at the time you exercise the Performance Lock feature, on
the next Contract Anniversary when the locked-in value will be reallocated or on its Term End Date.
The Performance Lock feature may not be available in the future on certain or any IPCS options. There is a risk
that the Performance Lock feature will not be available for a new Strategy Term of the same IPCS option when
your current Strategy Term ends and your money is eligible for reinvestment or reallocation. We will send you a
notice 30 calendar days in advance of your Contract Anniversary that explains the investment options available
to you, including the availability of the Performance Lock feature. You may also contact us at
1-888-GUARDIAN (1-888-482-7342) for information about the investment options available to you. If we do
not receive your reallocation instructions at our Customer Service Office by the close of business on the date
reallocation will be effected, the amount will be automatically reinvested for a new Strategy Term in the same
IPCS, if available, subject to new crediting rates that we declare for the applicable Crediting Strategy. If the
Term End Date is a non-Business Day, reallocation instructions must be received in Good Order no later than the
close of business on the prior Business Day. If the same IPCS is not available, the amount will be automatically
reallocated to an IPCS with the same Strategy Term, Index, Protection Strategy, and Crediting Strategy, if
available (i.e., only the availability of the Performance Lock feature will differ).
This means that if you do not
provide reallocation instructions, your money could be reinvested into a new Strategy Term (up to 6 years,
depending on your investment selections)
without the Performance Lock feature
. Amounts are withdrawn
from the Investment Strategies in the order described in the “Reallocations and Withdrawals” section.
You may not request a partial withdrawal be withdrawn from a particular Investment Strategy. This
means that if you wish to withdraw money from a specific IPCS without the Performance Lock feature
before the Term End Date, your only option will be to surrender the Contract, which may incur surrender
charges, may be subject to taxes (including a 10% tax penalty before age 59
1
∕
2
), and, with respect to any
amounts surrendered from an IPCS prior to the Term End Date, will be based on the Interim Value.
Risks Related to the Indices
An investment in the Contract is subject to risks related to the reference Indices, such as:
●
Discontinuation or Substitution.
An Index may not be available the entire time you own your Contract.
If an Index is discontinued or substantially changed, or if the Index Values become unavailable, or if we
no longer have a license agreement with the publishers of the Index, or if hedging instruments become
difficult to acquire or the cost of hedging becomes excessive, we may substitute the Index with a new
Index. If we replace an Index, we will attempt to select a new Index that has a similar investment
objective and risk profile to the original Index. Such replacement Index may not be satisfactory to you.
An Index substitution will not affect the Protection Strategy or Crediting Strategy for the IPCS.
However, the performance of the new Index may differ from the original Index. This may negatively
affect the amount credited to the IPCS at the end of the Strategy Term or the Interim Value available for
Performance Lock. Because reallocations are only permitted at the end of the Strategy Term, if you do
not want to remain invested in the IPCS for the remainder of the Strategy Term or exercise the
Performance Lock feature (if available) after we substitute the Index, you may surrender the Contract,
which may incur surrender charges, may be subject to taxes (including a 10% tax penalty before age
59
1
∕
2
), and, with respect to any amounts surrendered from an IPCS prior to the Term End Date, will be
based on the Interim Value. The Interim Value could be less than your investment in the IPCS even if
the Index is performing positively. See “Charges and Adjustments – Interim Value Adjustment” for
more information about the calculation of the Interim Value.
●
Index Performance.
The value of each IPCS depends, in part, on the performance of a reference Index.
The performance of each Index is based on the value of its component securities, which are subject to a
variety of complex and interrelated investment risks that you are indirectly exposed to. These risks may
impact financial markets generally, specific market segments, or specific issuers. The historical
performance of an Index does not guarantee future results. Because we measure Index Performance
from the Term Start Date to the Term End Date, there is a risk that the Index Performance may be
negative or zero even if the Index performed positively at times during the Strategy Term.
●
S&P 500® Price Return Index.
This Index is comprised of equity securities issued by large-capitalization U.S. companies. In
general, it is more difficult for large-capitalization companies to change their strategies quickly in
response to changes in their industries. Large-capitalization companies are typically more
well-established and have lower growth rates than small-capitalization companies.
●
Nasdaq-100® Price Return Index.
This Index is comprised of equity securities issued by large-capitalization U.S. and non-U.S.
companies, excluding financial companies. In general, it is more difficult for large-capitalization
companies to change their strategies quickly in response to changes in their industries.
Large-capitalization companies are typically more well-established and have lower growth rates
than small-capitalization companies. Political, social and economic developments abroad and
differences between the regulations and reporting standards and practices to which foreign issuers
are subject as compared to U.S. issuers may affect the Index Performance. In addition, to the extent
the component securities are denominated in foreign currencies, their values may be subject to
risks related to changes in currency exchange rates. Finally, companies in a particular sector may
not perform as well as companies in other sectors or the market as a whole.
●
MSCI EAFE Price Return Index
This Index is designed to follow the performance of large- and mid-capitalization companies across
21 developed markets around the world but excluding the U.S. and Canada. Political, social and
economic developments abroad and differences between the regulations and reporting standards
and practices to which foreign issuers are subject as compared to U.S. issuers may affect the Index
Performance. In addition, to the extent the component securities are denominated in foreign
currencies, their values may be subject to risks related to changes in currency exchange rates. Risks
of investing in foreign securities are generally increased by investing in emerging market countries.
●
SG Smart Climate Index.
This Index provides investment exposure to the performance of large-capitalization U.S. stocks
through its underlying index, the SG Climate Transition Risk Index (the “Underlying SG Index”).
These stocks are selected based on proprietary climate risk preparedness scores and certain
environmental, social, and governance (“ESG”) filters. In general, it is more difficult for
large-capitalization companies to change their strategies quickly in response to changes in their
industries. Large-capitalization companies are typically more well-established and have lower
growth rates than small-capitalization companies. This Index is also subject to several unique risks,
including:
●
ESG Methodology.
The Underlying SG Index is composed of stocks that are selected based on
an ESG methodology that includes climate risk scores and ESG exclusion filters. Investors’
views about ESG matters vary, and the Underlying SG Index’s ESG methodology may not
reflect your beliefs or values. There is no guarantee that the ESG methodology will ultimately
enhance the performance of the Index. Companies with lower ESG ratings may perform better
than companies with higher ESG ratings over the short or long term. Due to the inherent
difficulty of forecasting within complex systems and the general unpredictability of future
events, there is no guarantee that the predictive climate risk models used by the Underlying
SG Index will identify stocks that will perform well if climate events occur.
●
Performance Drag.
The performance of the Index will always be worse than the performance
of the Underlying SG Index. The Index reflects deductions that reduce performance, including
a 1.50% negative performance adjustment and 0.50% fixed replication costs, each as an
annualized percentage of Index Value. In addition, the performance of the Index is reduced by
assumed costs of borrowing equal to the U.S. Federal Funds Rate. As of October 6, 2025, the
U.S. Federal Funds Rate was 4.09%. The U.S. Federal Funds Rate will fluctuate over time,
and may be higher or lower in the future. Without these deductions, the performance of the
Index over any one year period would be higher. While these deductions are not charges under
the Contract, they result in lower Index Values and may therefore negatively impact the
performance of your investment.
●
Index Disruption.
Disruptive and extraordinary events could impair the operation of the Index
or the Underlying SG Index. For example, these events could relate to the unavailability of
necessary data to apply the ESG methodology, an insufficient number of eligible stocks, or the
termination or breach of a third-party licensing agreement. Should a disruptive or
extraordinary event occur, the Index publisher may take any actions permitted by the Index
rules, such as postponing calculations or rebalances, adjusting the terms of the Index to
preserve its economic characteristics, restating Index Values, or discontinuing the Index.
●
New Index.
The Index and the Underlying SG Index have limited performance histories.
Generally, there is less publicly available information about the Index and the Underlying SG
Index compared to more established market indices.
●
In addition, although the SG Smart Climate seeks to track the performance of companies with
ESG characteristics, amounts invested in an IPCS linked to this Index are not an investment in
the Index, the Underlying SG Index, or the component companies of the Underlying SG
Index. Amounts you invest in the Contract become assets of the Company. The Company’s
assets that support its payment obligations under the Contract are not invested based on ESG
considerations.
●
No Dividends.
The Index Value of a price return index generally does not include income from
dividends or other distributions paid by the Index’s component companies, and therefore the Index
Value does not fully reflect the performance of the securities that compose the Index. If dividends
and other distributions were included, the Index Value would be higher. As a result, a price return
Index will underperform similar portfolios from which dividends are reinvested. The SG Smart
Climate Index Value reflects a negative performance adjustment, in the form of a “synthetic
dividend,” intended to replicate the impact that an annual dividend would have on the Index Value.
If this “synthetic dividend” was not applied, the Index Value would be higher. This deduction
results in performance drag that will cause the Index to underperform a direct investment in the
securities that compose the Index.
●
Rights in the Index.
An investment in an IPCS is not an investment in the Index or any of its
component companies. You have no voting, dividend, liquidation, or other rights with respect to
the Index, its publisher, or any of the component companies.
For more information about the Indices, see Appendix C.
Risks Related to the Company
An investment in the Contract is subject to risks related to the Company, such as:
●
Financial Strength and Claims-Paying Ability.
Any obligations (including under the FRS), guarantees
or benefits of the Contract are subject to our financial strength and claims-paying ability. Our
obligations under the Contract are supported by the assets of our general account and the separate
account, both of which are subject to the claims of our creditors. You may obtain information about our
financial condition by reviewing our financial statements included in the Statement of Additional
Information.
●
Cybersecurity and Business Continuity.
Our business is highly dependent on the effective operation of
our computer systems and those of our service providers and intermediaries. We are vulnerable to
disruptions from utility outages, systems failures (e.g., hardware and software malfunctions) and
cyberattacks (including ransomware and malware attacks). Cyberattacks may be systemic (e.g.,
affecting the internet, cloud services, or other infrastructure) or targeted (e.g., failures in or breach of
our systems or those of third parties on whom we rely). The risk of cyberattacks may be higher during
periods of geopolitical turmoil, and the continuing use of remote or flexible work arrangements, remote
access tools, and mobile technology have expanded potential cyberattack surfaces. Due to the increasing
sophistication of cyberattacks, such cybersecurity incidents could occur and persist for an extended
period of time without detection
Cybersecurity incidents may result in the loss, theft, misuse, release,
corruption, and destruction of data (including confidential customer or business information),
interference with or denial of service, interfere with our ability to process Contract-related transactions
(including our ability to calculate Contract Values), and may subject us to regulatory fines, litigation,
and financial losses or cause reputational damage
.
We have established robust and tested plans,
procedures and controls to identify potential threats and protect our operations. However, there can be
no assurance that we or our service providers and intermediaries will be able to prevent cybersecurity
risks from affecting your Contract.
We are also exposed to the risk of natural or man-made disasters, including (but not limited to) storms, fires,
floods, earthquakes, public health crises, pandemics (e.g., COVID-19), malicious acts, and terrorist acts, any
of which could disrupt our operations and interfere with our ability to administer the Contract.
Contract Value that is allocated to an IPCS may only be reallocated on the Term End Date, unless (1) you
exercise the Performance Lock feature (if available) or (2) the IPCS is matured early and its value reallocated to
the FRS due to discontinuation of an Index. Contract Value that is allocated to the FRS and any locked-in Index
Strategy Value pursuant to the exercise of the Performance Lock feature may only be reallocated on the next
Contract Anniversary. Because of these restrictions, you may not be able to change your investment selections in
response to changes in market conditions during the investment term.
The value of each IPCS depends, in part, on the performance of a reference Index.
The performance of each Index is based on the value of its component securities, which are subject to a
variety of complex and interrelated investment risks that you are indirectly exposed to. These risks may
impact financial markets generally, specific market segments, or specific issuers. The historical
performance of an Index does not guarantee future results. Because we measure Index Performance
from the Term Start Date to the Term End Date, there is a risk that the Index Performance may be
negative or zero even if the Index performed positively at times during the Strategy Term.
BENEFITS AVAILABLE UNDER THE CONTRACT
The following table summarizes information about the standard benefits available under the Contract.
The availability of standard benefits may vary depending on the broker-dealer through which the
Contract is sold. See Distributions- Broker-Dealer Contract Versions.
Name of Benefit |
Purpose |
Maximum Fee |
Brief Description of Restrictions/Limitations |
Performance Lock |
Locks in the Interim Value of an IPCS during the Strategy Term. Locked in value may be reallocated among the available Investment Strategies on the next Contract Anniversary. |
No Charge |
● May not be available in the future on certain or any IPCS options. ● May not be exercised on the Term Start Date or the Term End Date. ● May only be exercised once during a Strategy Term for each IPCS with the Performance Lock feature, and cannot be revoked once exercised. ● Locked-in Index Strategy Value will no longer participate in any Index Performance (positive or negative). ● No Crediting or Protection Strategy will be applied to the locked-in IPCS at any time. ● Locked-in Index Strategy Value will remain in the locked-in IPCS and may not be reallocated or reinvested until the next Contract Anniversary. ● Locked-in Index Strategy Value is calculated at the end of the Business Day on which we receive your request, and therefore may be higher or lower than the Interim Value you last obtained. You will not know the Interim Value used to lock in your Index Strategy Value in advance. ● Automatic trigger of Performance Lock is not available for IPCS with a Trigger Rate Crediting Strategy. |
Standard Death Benefit |
Pays a death benefit to your designated Beneficiaries equal to the Contract Value, subject to the FRS Guaranteed Surrender Value. |
No Charge |
● Owner must be 76 or older on the date the application is signed. |
Return of Premium Death Benefit |
Pays a death benefit to your designated Beneficiaries equal to the greater of (i) the Standard Death Benefit described above or (ii) the premium payment, subject to withdrawal adjustments. |
No Charge |
● Owner must be younger than 76 years old on the date the application is signed. ● Withdrawals may reduce the benefit by more, even significantly more, than the dollar amount withdrawn. |
The following table summarizes information about the standard benefits available under the Contract.
The availability of standard benefits may vary depending on the broker-dealer through which the
Contract is sold. See Distributions- Broker-Dealer Contract Versions.
Name of Benefit |
Purpose |
Maximum Fee |
Brief Description of Restrictions/Limitations |
Performance Lock |
Locks in the Interim Value of an IPCS during the Strategy Term. Locked in value may be reallocated among the available Investment Strategies on the next Contract Anniversary. |
No Charge |
● May not be available in the future on certain or any IPCS options. ● May not be exercised on the Term Start Date or the Term End Date. ● May only be exercised once during a Strategy Term for each IPCS with the Performance Lock feature, and cannot be revoked once exercised. ● Locked-in Index Strategy Value will no longer participate in any Index Performance (positive or negative). ● No Crediting or Protection Strategy will be applied to the locked-in IPCS at any time. ● Locked-in Index Strategy Value will remain in the locked-in IPCS and may not be reallocated or reinvested until the next Contract Anniversary. ● Locked-in Index Strategy Value is calculated at the end of the Business Day on which we receive your request, and therefore may be higher or lower than the Interim Value you last obtained. You will not know the Interim Value used to lock in your Index Strategy Value in advance. ● Automatic trigger of Performance Lock is not available for IPCS with a Trigger Rate Crediting Strategy. |
Standard Death Benefit |
Pays a death benefit to your designated Beneficiaries equal to the Contract Value, subject to the FRS Guaranteed Surrender Value. |
No Charge |
● Owner must be 76 or older on the date the application is signed. |
Return of Premium Death Benefit |
Pays a death benefit to your designated Beneficiaries equal to the greater of (i) the Standard Death Benefit described above or (ii) the premium payment, subject to withdrawal adjustments. |
No Charge |
● Owner must be younger than 76 years old on the date the application is signed. ● Withdrawals may reduce the benefit by more, even significantly more, than the dollar amount withdrawn. |
Index Protection and Crediting Strategies
The following is a list of IPCS currently available under the Contract. We may change the features of the IPCS
listed below (including the Index and the current limits on Index gains and losses), offer new IPCS, and
terminate existing IPCS. We will provide you with written notice before making any changes other than changes
to current limits on Index gains. Information about current limits on Index gains is available at
www.guardianlife.com/annuities/rates. See “Investment Strategies – Index Protection and Crediting Strategies
(“IPCS”)” in the prospectus for more information about the features of the IPCS.
The availability of IPCS may vary depending on the broker-dealer through which the contract is sold. See
Distribution – Broker-Dealer Contract Variations.
Note: If amounts are removed from an IPCS before the end of its Strategy Term, we will apply an Interim
Value adjustment. This may result in a significant reduction in your Contract Value that could exceed any
protection from Index loss that would be in place if you held the option until the end of the Strategy Term.
See “Charges and Adjustments – Interim Value Adjustment” in the prospectus for more information
about Interim Value adjustments.
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
One Year |
Cap with Par & Spread |
-10% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
S&P 500® Price Return Index 1;5 |
U.S. Large Cap Equities |
One Year |
Step-Up Trigger Rate |
-10% Buffer |
1.00% Trigger |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
One Year |
Cap with Par & Spread |
-20% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
S&P 500® Price Return Index 1;5 |
U.S. Large Cap Equities |
One Year |
Trigger Rate |
-20% Buffer |
1.00% Trigger |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Three Year |
Cap with Par |
-10% Buffer |
5.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Three Year |
Cap with Par & Spread |
-10% Buffer |
5.00% Cap 100% Participation 3.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Three Year |
Cap with Par |
-20% Buffer |
5.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Three Year |
Cap with Par & Spread |
-20% Buffer |
5.00% Cap 100% Participation 3.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-10% Buffer |
10.00% Cap 100% Participation |
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-10% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-20% Buffer |
10.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-20% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-30% Buffer |
10.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-30% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par & Spread |
-10% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
Nasdaq-100® Price Return Index 1 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par & Spread |
-20% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par |
-10% Buffer |
5% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par & Spread |
-10% Buffer |
5% Cap 100% Participation 3.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par |
-20% Buffer |
5% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par & Spread |
-20% Buffer |
5% Cap 100% Participation 3.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-10% Buffer |
10% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-10% Buffer |
10% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-20% Buffer |
10% Cap 100% Participation |
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-20% Buffer |
10% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-30% Buffer |
10% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-30% Buffer |
10% Cap 100% Participation 6.00% Spread |
MSCI EAFE Price Return Index 1 |
International Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
MSCI EAFE Price Return Index 1 |
International Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Three Year |
Cap with Par |
-10% Buffer |
5.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Three Year |
Cap with Par |
-20% Buffer |
5.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-10% Buffer |
10.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-20% Buffer |
10.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-30% Buffer |
10.00% Cap 100% Participation |
1
The Index is a “price return” index, not a “total return” index, and therefore the performance of the Index does not reflect dividends
declared by any of the companies included in the Index, reducing the Index return. As a result, the Index will underperform a direct
investment in the securities composing the Index.
2
The Index deducts fees and costs when calculating the Index return, reducing the Index return. As a result, the Index will
underperform a direct investment in the securities composing the Index.
3
This IPCS is not available under Contracts issued in the state of New York.
4
This IPCS is only available for Contracts issued in conjunction with applications signed on or after May 1, 2025.
5
This IPCS is only available for Contracts issued in conjunction with applications signed on or after December 8, 2025.
We always intend to offer the 1-Year / -10% Buffer / S&P 500 Index / Cap with Par IPCS option, subject
to our right to substitute the Index with one that is substantially similar, which means we will always offer
a strategy with a -10% Buffer.
If you invest in an IPCS with the Cap with Par Crediting Strategy, we guarantee that the Participation
Rate will never be less than 100%, and the Cap Rate will never be less than 1.50% for any IPCS with a
1 year Strategy Term, 5.00% for any IPCS with a 3 year Strategy Term, and 10.00% for any IPCS with a
6 year Strategy Term. If you invest in an IPCS with the Cap with Par & Spread Crediting Strategy, we
guarantee that (i) the Participation Rate will never be less than 100%; (ii) the Cap Rate will never be less
than 1.50% for any IPCS with a 1 year Strategy Term, 5.00% for any IPCS with a 3 year Strategy Term,
and 10.00% for any IPCS with a 6 year Strategy Term; and (iii) the Spread will never be greater than
1.00% for any IPCS with a 1 year Strategy Term. If you invest in an IPCS with the Trigger
Rate Crediting Strategy, we guarantee that the Trigger Rate will never be less than 1.00% for any IPCS
with a 1 year Strategy Term.
See Appendix B for state variations that may apply.
Fixed Rate Strategy
The following describes the Fixed Rate Strategy currently available under the Contract. We may change the
features of the FRS, offer new FRS options, and terminate the existing FRS. We will provide you with written
notice before doing so.
Name |
Term |
Minimum Guaranteed Interest Rate |
Fixed Rate Strategy |
One Year |
0.15% |
The Fixed Rate Strategy is not registered
under the 1933 Act nor is it registered as an investment company under the 1940 Act. The fixed rate strategy disclosures are subject to generally applicable provisions of the federal
securities laws regarding the accuracy and completeness of disclosures.
The following is a list of IPCS currently available under the Contract. We may change the features of the IPCS
listed below (including the Index and the current limits on Index gains and losses), offer new IPCS, and
terminate existing IPCS. We will provide you with written notice before making any changes other than changes
to current limits on Index gains. Information about current limits on Index gains is available at
www.guardianlife.com/annuities/rates. See “Investment Strategies – Index Protection and Crediting Strategies
(“IPCS”)” in the prospectus for more information about the features of the IPCS.
The availability of IPCS may vary depending on the broker-dealer through which the contract is sold. See
Distribution – Broker-Dealer Contract Variations.
Note: If amounts are removed from an IPCS before the end of its Strategy Term, we will apply an Interim
Value adjustment. This may result in a significant reduction in your Contract Value that could exceed any
protection from Index loss that would be in place if you held the option until the end of the Strategy Term.
See “Charges and Adjustments – Interim Value Adjustment” in the prospectus for more information
about Interim Value adjustments.
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
One Year |
Cap with Par & Spread |
-10% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
S&P 500® Price Return Index 1;5 |
U.S. Large Cap Equities |
One Year |
Step-Up Trigger Rate |
-10% Buffer |
1.00% Trigger |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
One Year |
Cap with Par & Spread |
-20% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
S&P 500® Price Return Index 1;5 |
U.S. Large Cap Equities |
One Year |
Trigger Rate |
-20% Buffer |
1.00% Trigger |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Three Year |
Cap with Par |
-10% Buffer |
5.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Three Year |
Cap with Par & Spread |
-10% Buffer |
5.00% Cap 100% Participation 3.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Three Year |
Cap with Par |
-20% Buffer |
5.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Three Year |
Cap with Par & Spread |
-20% Buffer |
5.00% Cap 100% Participation 3.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-10% Buffer |
10.00% Cap 100% Participation |
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-10% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-20% Buffer |
10.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-20% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
S&P 500® Price Return Index 1 |
U.S. Large Cap Equities |
Six Year |
Cap with Par |
-30% Buffer |
10.00% Cap 100% Participation |
S&P 500® Price Return Index 1;3;5 |
U.S. Large Cap Equities |
Six Year |
Cap with Par & Spread |
-30% Buffer |
10.00% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par & Spread |
-10% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
Nasdaq-100® Price Return Index 1 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
One Year |
Cap with Par & Spread |
-20% Buffer |
1.50% Cap 100% Participation 1.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par |
-10% Buffer |
5% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par & Spread |
-10% Buffer |
5% Cap 100% Participation 3.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par |
-20% Buffer |
5% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Three Year |
Cap with Par & Spread |
-20% Buffer |
5% Cap 100% Participation 3.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-10% Buffer |
10% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-10% Buffer |
10% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-20% Buffer |
10% Cap 100% Participation |
Index |
Type of Index |
Strategy Term |
Crediting Strategy |
Current Protection Strategy Rates (if held until end of Strategy Term) |
Minimum Crediting Strategy Rates (for the life of the IPCS) |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-20% Buffer |
10% Cap 100% Participation 6.00% Spread |
Nasdaq-100® Price Return Index 1;4 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par |
-30% Buffer |
10% Cap 100% Participation |
Nasdaq-100® Price Return Index 1;3;5 |
Non-Financial Large Cap Equities |
Six Year |
Cap with Par & Spread |
-30% Buffer |
10% Cap 100% Participation 6.00% Spread |
MSCI EAFE Price Return Index 1 |
International Equities |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
MSCI EAFE Price Return Index 1 |
International Equities |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
One Year |
Cap with Par |
-10% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
One Year |
Cap with Par |
-20% Buffer |
1.50% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Three Year |
Cap with Par |
-10% Buffer |
5.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Three Year |
Cap with Par |
-20% Buffer |
5.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-10% Buffer |
10.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-20% Buffer |
10.00% Cap 100% Participation |
SG Smart Climate Index 2;3 |
U.S. Large Cap Equities with ESG Characteristics |
Six Year |
Cap with Par |
-30% Buffer |
10.00% Cap 100% Participation |
1
The Index is a “price return” index, not a “total return” index, and therefore the performance of the Index does not reflect dividends
declared by any of the companies included in the Index, reducing the Index return. As a result, the Index will underperform a direct
investment in the securities composing the Index.
2
The Index deducts fees and costs when calculating the Index return, reducing the Index return. As a result, the Index will
underperform a direct investment in the securities composing the Index.
3
This IPCS is not available under Contracts issued in the state of New York.
4
This IPCS is only available for Contracts issued in conjunction with applications signed on or after May 1, 2025.
5
This IPCS is only available for Contracts issued in conjunction with applications signed on or after December 8, 2025.
1
The Index is a “price return” index, not a “total return” index, and therefore the performance of the Index does not reflect dividends
declared by any of the companies included in the Index, reducing the Index return. As a result, the Index will underperform a direct
investment in the securities composing the Index.
2
The Index deducts fees and costs when calculating the Index return, reducing the Index return. As a result, the Index will
underperform a direct investment in the securities composing the Index.
3
This IPCS is not available under Contracts issued in the state of New York.
4
This IPCS is only available for Contracts issued in conjunction with applications signed on or after May 1, 2025.
5
This IPCS is only available for Contracts issued in conjunction with applications signed on or after December 8, 2025.
Item 31A.
Information about Contracts with Index-Linked Options and Fixed Options Subject to a Contract Adjustment
Name of Contract |
Number of Contracts Outstanding |
Total Value Attributable to the Index and/ or Fixed Option subject to a Contract Adjustment |
Number of Contracts Sold During the Prior Calendar Year |
Gross Premiums Received During the Prior Calendar Year |
Amount of Contract Value Redeemed During the Prior Calendar Year |
Combination Contract (Yes/No) |
Guardian MarketPerform® |
1723 |
$338,699,678.61 |
1214 |
$228,787,968.25 |
$649,216.05 |
No |
Standard
Death
Benefit
Pays a death benefit to
your designated
Beneficiaries equal to
the Contract Value,
subject to the FRS
Guaranteed Surrender
Value.
●
Owner must be 76 or older on the
date the application is signed.
Standard
Death
Benefit
Performance
Lock
Locks in the Interim Value of
an IPCS during the Strategy
Term. Locked in value may
be reallocated among the
available Investment
Strategies on the next
Contract Anniversary.
●
May not be available in the future on
certain or any IPCS options.
●
May not be exercised on the Term
Start Date or the Term End Date.
●
May only be exercised once during a
Strategy Term for each IPCS with
the Performance Lock feature, and
cannot be revoked once exercised.
●
Locked-in Index Strategy Value will
no longer participate in any Index
Performance (positive or negative).
●
No Crediting or Protection Strategy
will be applied to the locked-in IPCS
at any time.
●
Locked-in Index Strategy Value will
remain in the locked-in IPCS and
may not be reallocated or reinvested
until the next Contract Anniversary.
●
Locked-in Index Strategy Value is
calculated at the end of the Business
Day on which we receive your
request, and therefore may be higher
or lower than the Interim Value you
last obtained. You will not know the
Interim Value used to lock in your
Index Strategy Value in advance.
●
Automatic trigger of Performance
Lock is not available for IPCS with a
Trigger Rate Crediting Strategy.
Performance
Lock
Return of
Premium
Death
Benefit
Pays a death benefit to
your designated
Beneficiaries equal to
the greater of (i) the
Standard Death Benefit
described above or (ii)
the premium payment,
subject to withdrawal
●
Owner must be younger than 76
years old on the date the application
is signed.
●
Withdrawals may reduce the benefit
by more, even significantly more,
than the dollar amount withdrawn.
Return of
Premium
Death
Benefit
The surrender charge will be imposed when you take a partial withdrawal or surrender your Contract during the first six Contract
Years, unless an exception applies. Each year during the first six Contract Years, however, you may take withdrawals up to the “free
withdrawal amount” without incurring a surrender charge. The free withdrawal amount is the greater of (i) 10% of your Contract Value
as of the most recent Contract Anniversary (or, in the first Contract Year, 10% of your total premiums paid) or (ii) your RMD under
our automatic RMD program.
Yes
.
You can lose money by investing in the Contract, including the loss of
principal and previously credited earnings.
If you invest in an IPCS with the
lowest level of protection currently offered (the -10% Buffer), you could
experience losses up to 90% at the end of the Strategy Term. We always
intend to offer the 1-Year / -10% Buffer / S&P 500 Index / Cap with Par
IPCS option, subject to our right to substitute the Index with one that is
substantially similar, which means we will always offer a strategy with a
-10% Buffer.
No.
This Contract is not a short-term investment and is not appropriate for an
investor who needs ready access to cash. Withdrawals could result in surrender
charges during the first six years you own the Contract, and may be subject to
taxes and tax penalties (including a 10% tax penalty before age 59
1
∕
2
).
In addition, amounts removed from an IPCS prior to the end of the Strategy
Term may be subject to a negative Interim Value adjustment, which could result
in a loss that is greater than the level of protection the Protection Strategy
would provide on the Term End Date, or a gain that is lower than the return the
Crediting Strategy would provide on the Term End Date. The calculation of the
Interim Value in connection with a withdrawal could result in the loss of
principal and previously credited earnings, even if the Index is performing
positively, and such losses could be substantial.
Contract Value that is allocated to an IPCS may only be reallocated on the
Term End Date (which is also a Contract Anniversary) unless you exercise the
Performance Lock feature (if available). Contract Value that is allocated to the
FRS and any locked-in Index Strategy Value pursuant to the exercise of the
Performance Lock feature may be reallocated on the next Contract Anniversary.
If we do not receive your reallocation instructions at our Customer Service
Office by the close of business on the date the reallocation will be effected,
your Contract Value will be automatically reinvested in the same Investment
Strategies, if available (i.e., the Fixed Rate Strategy Value will be reinvested in
the FRS, the Index Strategy Value will be reinvested in the same IPCS), subject
to the new crediting rates. If the same IPCS is not available, the amount will be
automatically reallocated to an IPCS with the same Strategy Term, Index,
Protection Strategy, and Crediting Strategy, if available (i.e., only the
availability of the Performance Lock feature is different). If such an IPCS is
not available, the amount will be automatically reallocated to the 1-Year
Strategy Term / -10% Buffer / S&P 500 Index / Cap with Par / with or without
Performance Lock (depending on availability). Any reallocation absent your
instruction may not be satisfactory to you.
An investment in the Contract is subject to the risk of poor investment
performance and can vary based on the performance of the Investment
Strategies available under the Contract. Each Investment Strategy (including
the FRS) has its own unique risks. You should review each of the available
Investment Strategies before making an investment decision.
The Crediting Strategy of an IPCS will limit positive Index returns on the Term
End Date.
The application of the Crediting Strategy may cause your
returns under the IPCS to be lower than the Index’s returns.
Under the Cap with Par Crediting Strategy, your return will be limited to the
extent the Index return exceeds the Cap Rate (if any). For example, if the Index
return is 25%, the Cap Rate is 20%, and the Participation Rate is 100%, we
will credit 20% in interest at the end of the Strategy Term, meaning the amount
you invested in the IPCS will increase by 20%. If we do not declare a Cap
Rate for a particular Strategy Term, your return will not be limited. For
example, if the Index return is 25%, we do not declare a Cap Rate, and the
Participation Rate is 125%, we will credit 31.25% in interest at the end of the
Strategy Term, meaning the amount you invested in the IPCS will increase by
31.25%.
Under the Cap with Par & Spread Crediting Strategy, your return will be
reduced by the Spread and will be limited to the extent the Index return
exceeds the Cap Rate (if any). For example, if the Index return is 25%, the Cap
Rate is 20%, the Participation Rate is 100%, and the Spread is 1%, we will
credit 19% in interest at the end of the Strategy Term. If we do not declare a
Cap Rate for a particular Strategy Term, your return will not be limited, but
will still be reduced by the Spread. For example, if the Index return is 25%, we
do not declare a Cap Rate, the Participation Rate is 125%, and the Spread is
1%, we will credit 30% in interest at the end of the Strategy Term.
Under the Trigger Rate Crediting Strategy, your return will be limited to the
extent the Index return exceeds the Trigger Rate. For example, if the Index
return is 25% and the Trigger Rate is 12%, we will credit 12% in interest at the
end of the Strategy Term.
The Protection Strategy of an IPCS will limit negative Index returns on the
Term End Date. Under the Buffer Protection Strategy, if the Index Performance
on the Term End Date is negative, you will be subject to any loss that exceeds
the Buffer Rate. For example, if the Index return is -25% and the Buffer Rate is
-10%, we will credit -15% (the amount that exceeds the Buffer Rate) at the end
of the Strategy Term, meaning the amount you invested in the IPCS will
decrease by 15%.
The Indices, except the SG Smart Climate Index, are “price return” indices, not
“total return” indices, and therefore they do not include income from dividends
or other distributions paid by their component companies. If dividends and
other distributions were included, the Index returns would be higher. The SG
Smart Climate Index Value reflects a negative performance adjustment, in the
form of a “synthetic dividend,” intended to replicate the impact that an annual
dividend would have on the Index return. If this “synthetic dividend” was not
applied, the Index return would be higher. As a result of these calculations, the
Indices will underperform a direct investment in the securities that compose
them.
Market Risk
There is a risk of loss of principal and previously-credited earnings due to poor investment performance, and
such losses may be substantial. In recent years, the financial markets have experienced periods of significant
volatility and negative returns, contributing to an uncertain and evolving economic environment. Financial
markets have been impacted by several interrelating factors, including (but not limited to) pandemics,
geopolitical turmoil, rising inflation, economic recessions, interest rate fluctuations, and actions by governmental
authorities. Depending on the Investment Strategies you select and the timing of transactions you request (e.g.,
reallocations, withdrawals, exercise of the Performance Lock feature), you may experience significant negative
returns under the Contract.
Index – Linked Option Risks
Protection Strategies
The Protection Strategies provide downside protection from negative Index performance only on the Term End
Date, so your risk of loss is greater on any other date during the Strategy Term. For multi-year Strategy Terms,
the Protection Strategies are
not
applied on an annual basis; any negative Index Performance is measured from
the Term Start Date to the Term End Date. In other words, the limits on downside loss provided by the Protection
Strategy are applied to the Index Performance at the end of the Strategy Term, not during the Strategy Term or
over the life of the Contract.
If you invest in an IPCS, you will bear the portion of loss that exceeds your
Buffer Rate. If you invest in an IPCS with the lowest level of protection currently offered (the -10%
Buffer), you could experience losses up to 90% at the end of the Strategy Term due to negative Index
Performance. We always intend to offer the 1-Year / -10% Buffer / S&P 500 Index / Cap with Par IPCS
option, subject to our right to substitute the Index with one that is substantially similar, which means we
will always offer a strategy with a -10% Buffer.
If you reinvest your money in the same IPCS over the course
of multiple Strategy Terms, you may incur greater losses than the protection level provided by that IPCS over the
course of a single Strategy Term.
Crediting Strategies
The Crediting Strategies determine how positive Index performance is credited on the Term End Date, and may
limit or enhance your returns under the IPCS. The amount you can earn on an IPCS will be limited to the extent
the Index return exceeds (i) the Cap Rate (if any) under the Cap with Par Crediting Strategy or the Cap with Par
& and Spread Crediting Strategy, or (ii) the Trigger Rate under the Trigger Rate Crediting Strategy. Your returns
will also be reduced by the Spread under the Cap with Par & Spread Crediting Strategy. The application of the
Crediting Strategy may cause your returns under the IPCS to be lower than the Index’s returns. For multi-year
Strategy Terms, the Crediting Strategies are
not
applied on an annual basis; any positive Index Performance is
measured from the Term Start Date to the Term End Date. In other words, the Crediting Strategy will be applied
to the Index Performance at the end of the Strategy Term, not during the Strategy Term or over the life of the
Contract. Your investment in an IPCS is not an investment in the Index or the securities tracked by the Index.
An investment in the Contract is subject to the risks related to GIAC. Any
obligations (including under the FRS and IPCS), guarantees, and benefits of the
Contract are subject to our claims-paying ability. If we experience financial
distress, we may not be able to meet our obligations to you. More information
about GIAC, including our financial strength ratings, is available by contacting
us at 1-888-GUARDIAN (1-888-482-7342).
Reallocation Restrictions
Contract Value that is allocated to an IPCS may only be reallocated on the Term End Date, unless (1) you
exercise the Performance Lock feature (if available) or (2) the IPCS is matured early and its value reallocated to
the FRS due to discontinuation of an Index. Contract Value that is allocated to the FRS and any locked-in Index
Strategy Value pursuant to the exercise of the Performance Lock feature may only be reallocated on the next
Contract Anniversary. Because of these restrictions, you may not be able to change your investment selections in
response to changes in market conditions during the investment term.
If you do not want to remain invested in your current allocations until these dates, you may surrender the Contract, which may incur surrender charges,
may be subject to taxes (including a 10% tax penalty before age 59
1
∕
2
), and, with respect to any amounts
surrendered from an IPCS prior to the Term End Date, will be based on the Interim Value. The Interim Value
could be less than your investment in the IPCS even if the Index is performing positively. See “Charges and
Adjustments – Interim Value Adjustment” for more information about the calculation of the Interim Value.
If we do not receive reallocation instructions in Good Order by the close of business on the Term End Date, your
current allocations will be reinvested for a new term (in the same IPCS, if available) using the new crediting
rates. If the Term End Date is a non-Business Day, reallocation instructions must be received in Good Order no
later than the close of business on the Business Day prior to the Term End Date. If the same IPCS is not
available, the amount will be automatically reallocated to an IPCS with the same Strategy Term, Index,
Protection Strategy, and Crediting Strategy, if available (i.e., only the availability of the Performance Lock
feature will differ). If such an IPCS is not available, the amount will be automatically reallocated to the 1-Year
Strategy Term / -10% Buffer / S&P 500 Index / Cap with Par / with or without the Performance Lock feature
(depending on availability). This reallocation may not be satisfactory to you.
Availability of IPCS Options
We reserve the right to add or remove IPCS investment options. We also reserve the right to limit the availability
of certain IPCS to new Contract purchases. An IPCS that is currently available may not be available for
reallocations or reinvestment at the end of the Strategy Term (or the next Contract Anniversary after you exercise
the Performance Lock feature, if applicable). Certain IPCS may not be available through your financial
professional. You may obtain information about the IPCS options that are available to you by contacting your
financial professional or our Customer Service Office.
We may limit the number of IPCS options offered to one. We intend always to offer the 1-Year / -10% Buffer /
S&P 500 Index / Cap with Par / with or without the Performance Lock feature (depending on availability),
subject to our right to substitute the Index, which means we will always offer a strategy with a -10% Buffer. This
means that it is possible that we may not offer IPCS options in the future that are attractive to you based on your
personal preferences, risk tolerances, or time horizon. If there are no investment options you wish to select, you
may surrender the Contract, but the surrender may incur surrender charges, may be subject to taxes (including a
10% tax penalty before age 59
1
∕
2
), and, with respect to any amounts surrendered from an IPCS prior to the Term
End Date, will be based on the Interim Value. The Interim Value could be less than your investment in the IPCS
even if the Index is performing positively. See “Charges and Adjustments – Interim Value Adjustment” for more
information about the calculation of the Interim Value.
Crediting Rates
We set crediting rates (including Cap Rates, Participation Rates and Trigger Rates, and the FRS interest rate) at
our discretion. The crediting rates for new Strategy Terms may be lower than your initial crediting rates, subject
to guaranteed minimums. You assume the risk that the crediting rates we set will be less favorable than you find
acceptable. Crediting rates for new Contract purchases may be more favorable than the crediting rates for
reallocations. We may declare different crediting rates for reallocations based on your Contract Date.
Performance Lock Risk
You may only exercise the Performance Lock feature once during a Strategy Term for each IPCS. After you
exercise the Performance Lock feature, your locked-in Index Strategy Value will not increase under any
circumstances (even if the Index Performance is positive), and your decision to exercise the Performance Lock
feature cannot be revoked. Withdrawals and charges deducted from a locked-in IPCS will reduce the locked-in
Index Strategy Value by the amount withdrawn or charge assessed, including any applicable surrender charge.
You will not know the Interim Value used to lock in your Index Strategy Value in advance. We use the Interim
Value calculated at the end of the Business Day on which we receive your request. You assume the risk that the
Interim Value that gets locked in will be lower than the Interim Value you last obtained. Reallocations are only
permitted on Contract Anniversaries. Depending on when you exercised the Performance Lock feature, your
investment might not participate in Index Performance for as long as one year. There may not be an optimal time
to exercise the Performance Lock feature. Your Maturity Value may be higher if you do not exercise the
Performance Lock feature. If the Performance Lock feature is exercised for an IPCS, no Crediting or Protection
Strategy is applied to the IPCS
at any time
, including at the time you exercise the Performance Lock feature, on
the next Contract Anniversary when the locked-in value will be reallocated or on its Term End Date.
The Performance Lock feature may not be available in the future on certain or any IPCS options. There is a risk
that the Performance Lock feature will not be available for a new Strategy Term of the same IPCS option when
your current Strategy Term ends and your money is eligible for reinvestment or reallocation. We will send you a
notice 30 calendar days in advance of your Contract Anniversary that explains the investment options available
to you, including the availability of the Performance Lock feature. You may also contact us at
1-888-GUARDIAN (1-888-482-7342) for information about the investment options available to you. If we do
not receive your reallocation instructions at our Customer Service Office by the close of business on the date
reallocation will be effected, the amount will be automatically reinvested for a new Strategy Term in the same
IPCS, if available, subject to new crediting rates that we declare for the applicable Crediting Strategy. If the
Term End Date is a non-Business Day, reallocation instructions must be received in Good Order no later than the
close of business on the prior Business Day. If the same IPCS is not available, the amount will be automatically
reallocated to an IPCS with the same Strategy Term, Index, Protection Strategy, and Crediting Strategy, if
available (i.e., only the availability of the Performance Lock feature will differ).
This means that if you do not
provide reallocation instructions, your money could be reinvested into a new Strategy Term (up to 6 years,
depending on your investment selections)
without the Performance Lock feature
. Amounts are withdrawn
from the Investment Strategies in the order described in the “Reallocations and Withdrawals” section.
You may not request a partial withdrawal be withdrawn from a particular Investment Strategy. This
means that if you wish to withdraw money from a specific IPCS without the Performance Lock feature
before the Term End Date, your only option will be to surrender the Contract, which may incur surrender
charges, may be subject to taxes (including a 10% tax penalty before age 59
1
∕
2
), and, with respect to any
amounts surrendered from an IPCS prior to the Term End Date, will be based on the Interim Value.
Risks Related to the Company
An investment in the Contract is subject to risks related to the Company, such as:
●
Financial Strength and Claims-Paying Ability.
Any obligations (including under the FRS), guarantees
or benefits of the Contract are subject to our financial strength and claims-paying ability. Our
obligations under the Contract are supported by the assets of our general account and the separate
account, both of which are subject to the claims of our creditors. You may obtain information about our
financial condition by reviewing our financial statements included in the Statement of Additional
Information.
●
Cybersecurity and Business Continuity.
Our business is highly dependent on the effective operation of
our computer systems and those of our service providers and intermediaries. We are vulnerable to
disruptions from utility outages, systems failures (e.g., hardware and software malfunctions) and
cyberattacks (including ransomware and malware attacks). Cyberattacks may be systemic (e.g.,
affecting the internet, cloud services, or other infrastructure) or targeted (e.g., failures in or breach of
our systems or those of third parties on whom we rely). The risk of cyberattacks may be higher during
periods of geopolitical turmoil, and the continuing use of remote or flexible work arrangements, remote
access tools, and mobile technology have expanded potential cyberattack surfaces. Due to the increasing
sophistication of cyberattacks, such cybersecurity incidents could occur and persist for an extended
period of time without detection
Cybersecurity incidents may result in the loss, theft, misuse, release,
corruption, and destruction of data (including confidential customer or business information),
interference with or denial of service, interfere with our ability to process Contract-related transactions
(including our ability to calculate Contract Values), and may subject us to regulatory fines, litigation,
and financial losses or cause reputational damage
.
We have established robust and tested plans,
procedures and controls to identify potential threats and protect our operations. However, there can be
no assurance that we or our service providers and intermediaries will be able to prevent cybersecurity
risks from affecting your Contract.
We are also exposed to the risk of natural or man-made disasters, including (but not limited to) storms, fires,
floods, earthquakes, public health crises, pandemics (e.g., COVID-19), malicious acts, and terrorist acts, any
of which could disrupt our operations and interfere with our ability to administer the Contract.
●
S&P 500® Price Return Index.
The S&P 500 includes 500 large-capitalization stocks from leading companies in leading industries of the U.S. economy.
This Index does not include dividends declared by any of the component companies. As a
result, the Index will underperform a direct investment in the securities composing the Index. Additional
information about the Index can be found at www.spglobal.com.
This Index does not include dividends declared by any of the component companies. As a
result, the Index will underperform a direct investment in the securities composing the Index. Additional
information about the Index can be found at www.spglobal.com.
●
Nasdaq-100® Price Return Index.
The Nasdaq-100 Index® is designed to measure the performance of 100 of the largest Nasdaq-listed
non-financial companies and is home to many companies from sectors like technology, healthcare, consumer goods & services, and industrials.
This Index does not include dividends declared by any of the component
companies. As a result, the Index will underperform a direct investment in the securities composing the
Index. Additional information about the Index can be found at www.nasdaq.com.
This Index does not include dividends declared by any of the component
companies. As a result, the Index will underperform a direct investment in the securities composing the
Index. Additional information about the Index can be found at www.nasdaq.com.
●
MSCI EAFE Price Return Index.
The MSCI EAFE includes large- and mid-capitalization companies across 21 developed markets around the world, including countries in Europe, Australia, and the Far East, but excluding the U.S. and Canada.
This
Index does not include dividends declared by any of the component companies. As a result, the Index will
underperform a direct investment in the securities composing the Index. Additional information about the
Index can be found at www.nasdaq.com.
This
Index does not include dividends declared by any of the component companies. As a result, the Index will
underperform a direct investment in the securities composing the Index. Additional information about the
Index can be found at www.nasdaq.com.
●
SG Smart Climate Index.
The SG Smart Climate provides investment exposure to the performance
of
large-capitalization U.S. stocks through the Underlying SG Index. These stocks are selected based on proprietary climate risk preparedness
scores and certain ESG filters. Climate risk generally refers to the risk of negative impacts on a company’s
business or financial condition due to climate-related conditions around the globe or the transition to a lower
carbon economy. The climate risk models used in connection with the Index seek to identify large U.S.
companies that are more likely to perform well in future climate scenarios. This Index is an “excess return”
Index. Its returns reflect the total return on an investment in the underlying component companies (including
reinvestment of all dividends, interest, and other income) less certain negative adjustments and deductions
that reduce the performance of the Index. As a result, the Index will underperform a direct investment in the
securities composing the Index.
S&P 500® Price
Return Index
1
S&P 500® Price
Return
Index
1;3;5
S&P 500® Price
Return Index
1;5
S&P 500® Price
Return Index
1;5
Nasdaq-100® Price
Return Index
1
Nasdaq-100® Price
Return Index
1;3;5
Nasdaq-100® Price
Return Index
1;4
MSCI EAFE Price
Return Index
1
SG Smart Climate
Index
2;3
| [1] | The maximum loss could occur in extreme circumstances due to a negative Interim Value adjustment. Transactions that are subject to an Interim Value adjustment include (i) taking a withdrawal or surrendering your Contract, including the deduction of applicable surrender charges and/or premium taxes, (ii) exercising the Performance Lock feature (if available), (iii) annuitization, (iv) the payment of the Standard Death Benefit, and (v) exercising your right to return the Contract (unless the return of premium is greater). See “Charges and Adjustments” for more information. |
| [2] | The surrender charge will be imposed when you take a partial withdrawal or surrender your Contract during the first six Contract Years, unless an exception applies. Each year during the first six Contract Years, however, you may take withdrawals up to the “free withdrawal amount” without incurring a surrender charge. The free withdrawal amount is the greater of (i) 10% of your Contract Value as of the most recent Contract Anniversary (or, in the first Contract Year, 10% of your total premiums paid) or (ii) your RMD under our automatic RMD program. |