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Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments

On July 1, 2024, the SEC adopted amendments to provide a tailored form to register the offerings of registered index-linked annuities. The new rule and amendments to the form are intended to help investors make informed decisions about non-variable annuities. Amendments include: 

  • Mandating that offerings of Registered Index-Linked Annuities (RILAS) and registered Market Value Adjustment (MVA) annuities be registered on Form N-4;  
  • Providing investors with specific disclosures and essential information about these complex products;  
  • Improving and modernizing the registration, filing, and disclosure processes for non-variable annuities;   
  • Applying a current SEC rule to non-variable annuity advertisements and sales literature; and 
  • Updating forms for all offerings, including variable annuities, and implementing technical amendments to other insurance product registration forms.  

Affected Forms/Rules Include 

  • N-3 
  • N-4 
  • N-6 
  • Form 24F-2 
  • Rule 156 

Amendments to Form N-4 apply to all issuers that use the form. Registered index-linked annuities must register offerings on the form as well. 

Non-variable annuity issuers will be required to:  

  • Follow the follow the same rules to update their registration statements. 
  • Utilize the summary prospectuses framework available to variable annuity registrants on Form N-4 to file prospectuses.  
  • Tag certain information in the form using Inline XBRL. 
  • Pay securities registration fees in sums unpaid on Form 24F-2.  

Non-variable annuity issuers will follow the same rules to update their registration statements. They will be required to utilize the summary prospectus framework available to variable annuity registrants on Form N-4 to file prospectuses, including the requirement to tag certain information in the form using Inline XBRL. These amendments will also require non-variable annuity issuers to pay securities registration fees in sums unpaid on Form 24F-2. 

Additionally, the SEC is adopting technical amendments to Forms N-6 and N-3. 

Important Dates 

The compliance date for the amendments to Form N-4 and related rule will be May 1, 2026. The compliance date for rule 156 is the effective date. The amendments will be effective 60 days after publication in the Federal Register.