ASOP 2
(NONGUARANTEED ELEMENTS FOR LIFE INSURANCE AND ANNUITY PRODUCTS)
SECTION to Section 2
COMMENTS & RESPONSES ON SECTION 2 OF THE EXPOSURE DRAFT

Commentary on Section 3

ASOP 2 | Commentary Section 2.1 | COMMENT ON SECTION 2.1

Section 2.1, Anticipated Experience Factor

Comment	Response
One commentator suggested adding “may include but are not limited to” before the list of examples.	The reviewers note that examples are illustrative, not exhaustive, and made no change.
One commentator suggested clarifying whether “rates of” applies to investment income only or the entire list.	The reviewers believe the language is appropriate and made no change.
One commentator suggested modifying the example to reference policyholder elections.	The reviewers disagree and made no change.

ASOP 2 | Commentary Section 2.3 | COMMENT ON SECTION 2.3

Section 2.3, Guaranteed Element

Comment	Response
One commentator suggested adding “typically” before “specified in the policy” and in the example sentence.	The reviewers believe the language is appropriate and made no change.

ASOP 2 | Commentary Section 2.4 | COMMENT ON SECTION 2.4

Section 2.4, Nonguaranteed Element

Comment	Response
One commentator suggested rewording the second sentence for clarity.	The reviewers agree and clarified the language accordingly.
One commentator suggested changing “can be changed at the discretion of the insurer” to “may be changed...”	The reviewers disagree and made no change.

ASOP 2 | Commentary Section 2.6 | COMMENT ON SECTION 2.6

Section 2.6, NGE Scale

Comment	Response
One commentator suggested either deleting NGE scale as a defined term or referencing anticipated experience factors in the definition.	The reviewers disagree with the suggestion but clarified the language and added examples.

ASOP 2 | Commentary Section 2.9 | COMMENT ON SECTION 2.9

Section 2.9, Profitability Metric

Comment	Response
One commentator suggested revising the language to replace “a product’s expected level of financial results” with “projected profitability.”	The reviewers changed “expected” to “projected” based on this comment.