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When preparing a Compact individual non-variable annuity filing that contains a guaranteed living benefit feature, filers should be aware of the uniform standard treatment of unused guaranteed income withdrawals.  The GLB Standards permit unused guaranteed income amounts to be used toward future withdrawals of guaranteed income amounts.  However, if the benefit form provides that the guaranteed income withdrawals not taken by the owner can be accumulated and subsequently used to provide amounts upon surrender that exceed the account value or provide death benefit amounts that exceed the account value, the Additional Standards for Bonus Benefits and/or the Additional Standards for Incidental Guaranteed Minimum Death Benefits for Individual Deferred Non-Variable Annuities will be applicable.  When drafting GLB benefit forms that provide an increased account value or death benefit based on unused accumulated guaranteed income amounts under a GLB form, ensure all requirements, including actuarial requirements, are satisfied under these additional Uniform Standards.  Filers should be aware that any feature under GLB forms that have the potential to impact base contract values (other than rider charges), such as account values, cash surrender values and death benefits, could implicate additional Uniform Standards.  If your forms have these features, best practice is to submit a Pre-Filing Communication Form for the Compact's consideration.