Contingent Annuity Issues Work Group comment letter to the NAIC Life Insurance and Annuities (A) Committee regarding significant issues associated with contingent annuity products.

Contingent Annuity Work Group presentation to the NAIC's Contingent Deferred Annuity (A) Subgroup on contingent annuities, submitted to the NAIC on October 28, 2011.

Contingent Annuity Issues Work Group analysis assisting the National Association of Insurance Commissioners in its work involving contingent annuities.

Contingent Annuity Issues Work Group presentation to the NAIC Contingent Deferred Annuity (A) Subgroup comparing two different investment arrangements: typical contingent annuity design vs. self insurance.

Comment letter to the NAIC’s Contingent Deferred Annuity (A) Subgroup with an analysis comparing market returns for contingent deferred annuities and self insurance.