8.4. Public Communications Regarding Variable Annuities and Life Insurance

In addition to the rules about advertising and other public communication to be described in Chapter Eleven, public communication about variable life insurance and variable annuities must follow these requirements:

• Unless the name of the product is unambiguous (such as “XYZ Variable Annuity”), the communication must clearly identify whether the product is a variable life insurance policy or variable annuity. Care must be taken not to imply that the policy or the separate account is a mutual fund.

• Communications may not create the impression that the product is a short-term or liquid investment. Any discussion of these issues must be accompanied by “clear language describing the negative impact of early redemptions.” For variable life insurance, this description must include the effect of loans and withdrawals on the cash value of the policy, and how this will affect the policy’s death benefits.

• Any guaranteed minimums for a variable insurance product (for e