Variable Contracts Rule 498A

As of March 2020, the SEC adopted a new final rule, 498A, and form amendments which intend to modernize disclosure requirements and allow investors to make more informed decisions about variable annuity and variable life insurance contracts.

Core components

1. Option to adopt a summary prospectus: Must be sent to investors for every annual and semi-annual report, within 70 calendar days of the end of the reporting period.
2. Variable contract regulatory material online: If adopting the summary prospectus in lieu of delivering the statutory prospectus annually, a variable contract’s statutory prospectus and SAI must be:
   • Made available online at a publicly accessible website; and
   • provided in paper, upon request, at no cost.
3. Underlying investment option regulatory material online: Variable contracts can now satisfy delivery requirements for underlying investment option documents by:
   • Linking or posting related regulatory material on the variable contract’s website; and
   • Providing in paper, upon request, at no cost.
4. Updates to Forms N-3, N-4, and N-6. Registration statement forms are being amended to improve content and format of disclosure.
5. Inline XBRL: Similar to other investment products, inline XBRL will be required for certain prospectus disclosure.

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Compliance dates

• July 1, 2020: Summary prospectus option available (provided applicable Form amendments adopted)
• January 1, 2022: Registration statements on Forms N-3, N-4, and N-6 must comply with the new disclosure requirements
• January 1, 2023: Inline XBRL required for the submission of certain required disclosures

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FilePoint’s Solution

Any of our services are available à la carte or as a complete, integrated solution.

Key Impacts	How FilePoint Can Help
Decrease in recurring printed material, causing an increase in for print-on-demand requests	Fulfillment Our proprietary online platform to facilitate the requesting, fulfilling, and tracking of printed regulatory documents.
Increase in regulatory website material, resulting in a need for streamlined web posting process	FundDocs FilePoint can host all documents for the variable contract on a customized webpage with links to view, download, and request printed copies. Our solution incorporates all linking and layering requirements and can also be used for incorporating underlying investment options. We can also automate posting for any documents produced by FilePoint.
Summary document generation, creating need for efficiency producing summary prospectus documents	AutoDocs With AutoDocs, we offer custom solutions to facilitate the document management process by aggregating data and content between regulatory document and automating document output.
Structured data requirements, generating a new workflow component for incorporating the application of new technical requirements.	AutoIXBRL We can simplify the inline XBRL conversion process with our proprietary platform to automate the tagging, eliminating extra steps, time, and cost.