"[T]he variable non-registered group annuity contract.... can, if so designed, serve merely as an efficient investment platform, or serve as a complete package of financial and administrative services, with flexible pricing and compensation. Most of these contracts have within them the fixed account, which typically has enhanced guaranteed returns of the sort never available out of money market funds or the non-insurance 'stable value' funds.... These contracts, however, ... have a number of moving pieces, which can make them a challenge to review for 408b2 purposes. And many of the insurance company disclosures ... are far more complicated than need be. So [here is a] list for these who need to look at the disclosure related to these products under 408(b)(2)[.]"

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