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The Committee * recommends that the timing and mechanics of the delivery of the point of sale disclosure be more completely described in the definition of "point of sale" for the various types of variable annuity transactions. In addition, given the complexity of the sales process, the Committee suggests that only the hypothetical $10,000 investment be used as the basis for the point of sale disclosure, and not the mini- illustration described above.

Furthermore, the Committee strongly recommends that only the initial purchase of a variable annuity contract should trigger an obligation on the Selling Firm to provide a point of sale disclosure document; no point of sale disclosure should be required when additional amounts are invested in a variable annuity contract after the initial purchase.

CONCLUSION The Committee appreciates the time and resources that the Commission and its staff have devoted to this important initiative, and this opportunity to provide our views to the Commission.

The Committee also notes that state mandated free look rights are available for variable annuity contract purchasers. All investors will receive both the confirmation and the prospectus prior to the conclusion of the free look right. In some states, the purchaser can receive a refund of premium during the free look period. As a result, the need for customer specific point of sale disclosure should be lessened

* THE COMMITTEE OF ANNUITY INSURERS
Allmerica Financial Company Allstate Financial American International Group, Inc. AmerUs Annuity Group Co. Equitable Life Assurance Society of the United States F & G Life Insurance Fidelity Investments Life Insurance Company GE Financial Assurance Great American Life Insurance Co. Hartford Life Insurance Company DIG North America Insurance Corporation Jackson National Life Insurance Company Life Insurance Company of the Southwest Lincoln Financial Group ManuLife Financial Merrill Lynch Life Insurance Company Metropolitan Life Insurance Company Mutual of Omaha Companies Nationwide Life Insurance Companies New York Life Insurance Company Northwestern Mutual Life Insurance Company Ohio National Financial Services Pacific Life Insurance Company The Phoenix Life Insurance Company Protective Life Insurance Company Prudential Insurance Company of America Sun Life of Canada Travelers Insurance Companies USAA Life Insurance Company Zurich Kemper Life Insurance Companies

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