Common use of Policy Recordkeeping Clause in Contracts

Policy Recordkeeping. (i) The Agent shall maintain records for the Accounts and for the Policy owners reflecting all shares of the VVIF Portfolios purchased and redeemed by the Accounts based on Policy owner-level transactions (including the date and price for all transactions and share balances) and all re-investments by the Accounts of dividends and capital gains distributions paid by the VVIF Portfolios; provided however that the parties acknowledge that Agent maintains records for the Accounts of all re-investment of dividends and capital gains distributions, but does not maintain Policy owner-level records of re-investment of dividends and capital gains distributions. The Agent shall reconcile on each day that the New York Stock Exchange is open for trading (a “Business Day”) all transactions by the Accounts involving shares of the VVIF Portfolios (including purchases, redemptions, and reinvestments of dividends and capital gains distributions) with the corresponding Policy owner-level transactions on the Agent’s record-keeping system. It is understood that the Agent’s maintenance of Policy owner-level account records for an Account is done as the agent for the Account and not as the agent for Vanguard or any of its affiliates. (ii) The Agent shall promptly notify Vanguard if the Agent experiences difficulty in maintaining Policy owner-level records described above in an accurate and complete manner. The Agent agrees to furnish Vanguard with such information as Vanguard may reasonably request from time to time in order for Vanguard to verify the Agent’s compliance with the terms of this Agreement (including, without limitation, periodic certifications confirming the provision of the Agent’s record-keeping services to the Accounts in a manner consistent with the terms of this Agreement).