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For indexed annuity contracts that include a fixed account option, sometimes referred to as a declared rate option, it is important to remember that any fixed account or declared rate option is subject to the INDIVIDUAL DEFERRED NON-VARIABLE ANNUITY CONTRACT STANDARDS (IIPRC-A-02-I).  This means the base contract actuarial memorandum should include the information relative to the fixed account option or declared rate option based on the applicable provisions from these base contract standards.  This is true even if the fixed account option or declared rate option is added to the contract by a separate form, such as a rider.

Regardless of how the fixed account option is provided as part of the contract, a full actuarial memorandum for the base contract that includes discussion of the fixed account option or declared rate option must be provided.  It is not acceptable to file an actuarial addendum or memorandum that only describes the fixed account option or declared rate option.  If this occurs, a compliance issue will be generated requesting that the base contract actuarial memorandum that incorporates discussion of the fixed account option or declared rate option be submitted for review.