INDIVIDUAL FLEXIBLE PREMIUM VARIABLE UNIVERSAL LIFE INSURANCE POLICY

Exhibit 99.4(a)

AB

Protective Life Insurance Company
State of Domicile – Tennessee
A Stock Company
xxx.xxxxxxxxxx.xxx Home Office: P. O. Box 2606;
Xxxxxxxxxx, Xxxxxxx 00000
0-000-000-0000
Administrative Office: P. O. BOX 292;
Xxxxxxxxxx, XX 00000-0000
0-000-000-0000

INDIVIDUAL FLEXIBLE PREMIUM VARIABLE UNIVERSAL LIFE
INSURANCE POLICY

INSURED:

POLICY NUMBER:

This is a legal contract (the “Policy”) between the Owner (also referred to as “you” or “your”) and Protective Life Insurance Company (also referred to as the “Company”, “we”, “us”, or “our”).  Please read it carefully.

This Policy is a legal contract between the Owner and the Company. PLEASE READ THIS POLICY CAREFULLY.

THE OWNER HAS THE RIGHT TO CANCEL THIS POLICY.

There is a 10 day right to cancel period that starts on the date the Owner receives this Policy. If the Policy is issued as a replacement of existing life insurance or annuity coverage, the right to cancel period is extended to 30 days from the date of receiving it. If you are not satisfied with the Policy, return it to the Administrative Office [P.O. Xxx 000 Xxxxxxxxxx, XX 00000-0000] or an agent of the Company. The Policy will be void from the start, and the Company will refund the Policy Value Account plus any fees and charges.  Owner bears the investment risk during the right to cancel period.

Signed for the Company on the Issue date.

Xxxxxxx X. Xxxxxx	Xxxxx X. Xxxxxxxx
President	Secretary

ADJUSTABLE DEATH BENEFIT. Proceeds payable at death are subject to Policy provisions. Please refer to the “Death Benefit” section of this Policy for a description of the Death Benefit. Flexible Premiums are payable while the Insured is alive. If no Premiums are paid after the first Premium, or if subsequent Premiums prove to be insufficient, this coverage may cease prior to age 121. PAYMENTS AND VALUES ARE BASED ON THE INVESTMENT EXPERIENCE OF THE SUB-ACCOUNTS AND ARE VARIABLE, MAY INCREASE OR DECREASE ACCORDINGLY, AND ARE NOT GUARANTEED AS TO AN AMOUNT. Non-Participating. Does not pay dividends.

ICC20-V17-J355X

TABLE OF CONTENTS
POLICY SPECIFICATIONS	S1
DEFINITIONS	1
OWNERSHIP PROVISIONS	3
GENERAL PROVISIONS	4
DEATH BENEFIT PROVISIONS	7
FEES AND CHARGES	8
POLICY VALUES, LOANS AND NONFORFEITURE PROVISIONS	9
TRANSFER PROVISIONS	13

DEFINITIONS

Administrative Office:   The location where administrative services for this Policy are performed as shown on the face page of this Policy.

Attained Age: The age of the Insured, nearest birthday, as of the Policy Date and each Policy Anniversary thereafter.

Beneficiary: The person(s) named by the Owner to receive the Death Benefit Proceeds upon the death of the Insured. The primary Beneficiary(ies) is the person(s) or class of person designated to receive the proceeds of this Policy upon the death of the Insured. The Owner may designate a contingent Beneficiary(ies) to receive the proceeds if there is no primary Beneficiary(ies) living at the time of the Insured’s death.

Cash Surrender Value: Calculated on the effective date of the surrender is equal to:

(a) The Cash Value (on the effective date of the surrender); less

(b) Outstanding Policy loans and accrued loan interest, if any.

Cash Value: Is equal to the Policy Value Account plus the Return of Expense Charge Benefit if any.

Code: The Internal Revenue Code of 1986 as amended.

Death Benefit/Death Benefit Proceeds: The amount payable upon the Insured’s death.  A full description of the Death Benefit is described in the “Death Benefit” provision.

Evidence of Insurability: Information about an Insured which is used to approve or reinstate this Policy or any additional benefit.

Face Amount/Total Face Amount:   Total Face Amount is the sum of the Base Policy Face Amount (life insurance coverage) as shown on the Policy Schedule plus any endorsements or riders attached to the Policy that provide additional life insurance coverage on the Insured, if applicable as shown on the Policy Schedule.

Fixed Account: An investment option that provides for guaranteed interest and is part of the Company’s General Account. Policy Value Account includes any amount invested in the Fixed Account.

Fund(s): An underlying mutual fund in which a Sub-Account invests. Each Fund is an investment company registered with the SEC or a separate investment series of a registered investment company.

General Account:  The assets of the Company other than those allocated to the Variable Account or another separate account of the Company.

Insured: The person named on the Policy Schedule as the Insured.

Issue Date: The date from which the incontestability and suicide exclusions are measured shown on the Policy Schedule.

Loan Account: All outstanding Policy loans plus interest credited on the portion of the Policy Value Account being used as collateral for the outstanding Policy loans. The Loan Account is held in the General Account of the Company. The Loan Account is not part of the Variable Account.

Loan Account Value: The value of the Loan Account credited to the Owner under the Policy Value Account.

Loan Interest Credit Spread: An amount deducted from the loan interest rate to determine the interest credited on the portion of the Policy Value Account being used as collateral for a Policy loan. The maximum Loan Interest Credit Spread is shown on the Policy Schedule.

Money Market Sub-Account: A fund which seeks a high level of current income as is consistent with the preservation of capital and liquidity and investing in short term, high quality, liquid debt and monetary instruments.

Monthly Anniversary: Occurs on the same numerical day of the month as the Policy Date shown on the Policy

Schedule in each subsequent Policy Month this Policy remains in force.

Owner: The person, persons or entity named on the Policy Schedule as the Owner. The Owner is entitled to all the rights under this Policy while the Insured is living.

Policy Date: The effective date of coverage under this Policy. The Policy Months, Policy Years and Policy Anniversaries are measured from the Policy Date shown on the Policy Schedule.

Policy Month/Policy Year/Policy Anniversary: Policy Months, Policy Years and Policy Anniversaries are measured from the Policy Date shown on the Policy Schedule.

Policy Value Account: The sum of the Sub-Account Value, Fixed Account value, and Loan Account value.

Premiums: Amounts received and allocated to the Sub-Account(s) and the Fixed Account prior to any deductions.

Request: Any instruction in a form, written, telephoned, or electronic or computerized, as may be applicable, satisfactory to the Company and received at the Administrative Office from the Owner or an assignee of record, as specified in a form acceptable to the Company and which may be required in writing, or the Beneficiary (as applicable) as required by any provision of this Policy or as required by the Company. The Request is subject to any action taken or payment made by the Company before it was processed. In addition, subject to the Company’s administrative requirements as they may exist from time to time and to any requirements that may be imposed by the Funds or other investments, the Company reserves the right to require advance written notice from the Owner for any of the following:

· Allocation of Premiums or Policy loan repayments; and

· Requests for surrenders, partial withdrawals, Policy loans or Transfers.

Return of Expense Charge Benefit: Where applicable, the Company will calculate and return a percentage of the expense charge. The Return of Expense Charge Benefit calculation is based on a percentage of the Policy Value Account, and is only payable upon a complete surrender of the Policy. The percentage and duration of the Return of Expense Charge Benefit, in addition to the limitations and requirements, are described in the “Return of Expense Charge Benefit” provision.

Sub-Account(s): Sub-division(s) of the Variable Account that invest in Fund(s). The Fixed Account is not a Sub-Account.

Sub-Account Value: The sum of the values of the Sub-Accounts credited to the Owner under the Policy Value Account. The Sub-Account Value is credited with a return based upon the investment experience of the Sub-Accounts selected by the Owner and will increase or decrease accordingly.

Transaction Date: The date on which any Premium payment or Request   from   the Owner   will   be processed by the Company.  Premium payments and Requests received after 4:00 p.m. EST/EDT will be deemed to have been received on the next business day.   Requests will be processed and the Sub- Account Value will be valued on each date that the New York Stock Exchange (“NYSE”) is open for trading. The Company may delay such processing pursuant to restrictions described in this Policy.

Transfer: The transfer of Sub-Account Value from one Sub-Account to one or more Sub-Account(s) or a transfer from the Sub-Account(s) into the Fixed Account or transfer from the Fixed Account to one or more Sub-Accounts.

Unit: A unit of measure used to calculate the Sub-Account Value.

Valuation Date: The date on which the net asset value of each Fund is determined.  Evaluation date is each day that the NYSE is open for regular business.  The value of a Sub-Account’s assets is determined at the end of each Valuation Date.  To determine the value of an asset on a day that is not a Valuation Date, the value of that asset as of the end of the previous Valuation Date will be used.

Valuation Period: The period between two successive Valuation Dates, starting at the close of the NYSE on one Valuation Date and ending at the close of the NYSE on the next succeeding Valuation Date.

Variable Account:  One of the accounts into which Premiums may be paid under this Policy, net of Policy fees and charges described herein. The account is a segregated investment account established by the Company and a separate account under Tennessee law designated the Protective COLI VUL Separate Account.  The Company owns the assets in the Variable Account. The investments held in the Variable Account provide variable life insurance benefits under this Policy. This account is kept separate from the General Account and other separate accounts the Company may have. The Variable Account is registered with the Securities and Exchange Commission (“SEC”) under the Investment Company Act of 1940, as amended.

OWNERSHIP PROVISIONS

Rights of Owner: While the Insured is living, all benefits and rights under this Policy belong to the Owner; however, the Owner’s rights are subject to the rights of any assignee or irrevocably named Beneficiary.

Assignments/Transfers: The Owner may assign this Policy subject to applicable laws and regulations and while the Insured is living.  An assignment will take effect the date when signed, unless otherwise specified by the Owner and subject to any payments made or actions taken by the Company prior to receipt. When filed, the Owner’s rights and those of the Beneficiary are subject to the assignment. The Company is not responsible for the validity of any assignment.

When recorded by the Company, a transfer of ownership will revoke any designation of a Secondary Owner. It will not change a Beneficiary.  All benefits and rights under this Policy will belong to the new Owner, subject to the terms and conditions of the Policy and the interest of any recorded assignee.

Beneficiary: While the Insured is living, the Owner may change the Beneficiary by Request unless a previous designation was indicated as being irrevocable. Any change is subject to any existing assignment of this Policy. A recorded change of Beneficiary will take effect as of the date the Request was signed. However, the change will not affect any payment made or actions taken by the Company before it received a Request for a change of Beneficiary.

The Company may rely on an affidavit by any responsible person to identify a Beneficiary or verify the non-existence of a Beneficiary not identified by name.

Variable Account: The Company has absolute ownership of the assets of the Variable Account.  The portion of the assets of the Variable Account equal to the reserves and other contract liabilities with respect to the Variable Account are not chargeable with liabilities arising out of any other business the Company may conduct. The assets of the Variable Account are divided into a series of Sub-Accounts that are listed in the current Policy prospectus. Each Sub-Account invests exclusively in shares of a corresponding Fund. Any amounts of income, dividends, and gains distributed from the shares of a Fund will be reinvested in additional shares of that Fund at its Net Asset Value Per Share.

When permitted by law, the Company may:

1) Create new Variable Accounts;

2) Combine Variable Accounts

3) Restrict Premium Payments or Transfers into any Sub-Account;

4) Transfer assets of one Variable Account to another Variable Account;

5) Add new Sub-Account to or remove existing Sub-Accounts from the Variable Account or combine Sub-Accounts;

6) Make new Sub-Accounts or other Sub-Accounts available to such classes of policies as the Company may determine;

7) Close certain Sub-Accounts to allocations or Premium Payments or Transfers of Policy Value;

8) Add new Funds or remove existing Funds;

9) Substitute a different Fund for any existing Fund if shares of a Fund are no longer available for investment or if the Company determines that investment in a Fund is no longer appropriate in light of the purpose of the Variable Account;

10) Deregister the Variable Account under the Investment Company Act of 1940 if such registration is no longer required’

11) Operate the Variable Account as a management Investment Company under the Investment Company Act of 1940 or in any other form permitted by law; and

12) Make any changes ot the Variable Account or its operations as may be required by the Investment Company Act of 1940 or other applicable law or regulations.

The investment policy of the Variable Account will not be changed without approval pursuant to the insurance laws of the Company’s state of domicile. If required, approval of or change of investment policy will be filed with the insurance department of the state where this Policy is delivered.

The values and benefits of this Policy provided by the Variable Account depend on the investment performance of the Funds in which the Owner’s selected Sub-Accounts are invested. The Company does not guarantee the investment performance of the Funds. The Owner bears the full investment risk for Net Premiums allocated or Policy Value transferred to the Sub-Accounts.

Valuation of Assets: Assets of Funds held by each Sub-Account will be valued at their Net Asset Value Per Share on each Valuation Day. Each Fund’s prospectus defines the Net Asset Value Per Share of the Funds and describes each Fund.

Ownership of Fixed Account: The Company has absolute ownership of the assets of the Fixed Account.  Except as limited by law, the Company has sole control over the investment of the General Account assets.  The Owner does not share in the investment experience of the General Account, but is allowed to allocate and Transfer Policy Value into the Fixed Account.

GENERAL PROVISIONS

Entire Contract: This Policy, any endorsements, any riders, and the application form the entire contract.  After issue, amendments or changes in writing and agreed to by the Company are part of the contract. All statements in the application, in the absence of fraud, are considered representations and not warranties. Only statements in the application will be used to defend a claim or to cancel the Policy for misrepresentation.

Only the President or the Secretary of the Company has the authority to change or waive any provisions of the Policy. No agent or broker has the authority to change any term of this Policy or to make any agreements binding to the Company.

Interstate Insurance Product Regulation Commission: This Policy was approved under the authority of the Interstate Insurance Product Regulation Commission and issued under the Commission standards. Any provision of the Policy that on the provision’s effective date is in conflict with Interstate Insurance Product Regulation Commission standards for this product type is hereby amended to conform to the Interstate Insurance Product Regulation Commission standards for this product type as of the provision’s effective date.

Policy Modification: Upon notice to the Owner, the Company may modify this Policy if such modification (1) is necessary to make the Policy  or the Variable Account comply with any law or regulation issued by a governmental agency to which the Company or the Variable Account is subject; (2) is necessary to assure continued qualification of the Policy under the Code or other federal or state laws as a life insurance policy; (3) is necessary to reflect a change in the operation of the Variable Account or of a Sub-Account; or (4) adds, deletes or otherwise changes the Variable Account or the available Sub-Accounts. The Company also reserves the right to modify certain provisions of this Policy as stated in those provisions. In the event of any such modification, the Company may make appropriate amendments to this Policy to reflect such modification.

The Company may terminate a Sub-Account or Fund. In that event, the Owner by Request may change the Owner’s Premium allocation instructions. If no Request is made by the date of termination, future Premium payments will be allocated to the Money Market Sub-Account. Any modification will not affect the terms, provisions or conditions, which are, or may be, applicable to Premium payments previously made to any such Sub-Account.

Incontestability: Except for nonpayment of Premiums, this Policy will not be contested on the basis of misrepresentation after it has been in force during the Insured’s lifetime for 2 years from the Issue Date. If this Policy is reinstated, it will not be contested after it has been in force during the Insured’s lifetime for 2 years following the date of reinstatement. If the Face Amount is increased, the amount of the increase will in like manner be incontestable after it has been in force during the Insured’s lifetime for 2 years from the effective date of the

increase.

Suicide Exclusion: If the Insured commits suicide, while sane or insane, within 2 years from the Issue Date the proceeds payable under this Policy will be limited to an amount equal to all Premiums paid on this Policy less outstanding Policy loans and accrued loan interest, partial withdrawals and the cost for any riders or endorsements. Payment will be made to the Beneficiary.

If the Face Amount is increased and if the Insured commits suicide, while sane or insane, within 2 years from the effective date of any increase, the Company will pay only that portion of the Policy Value Account associated with the amount of the increase and the cost of insurance paid for the amount of increase. The Face Amount of the Policy will be reduced to the Face Amount that was in effect prior to the increase. The Company reserves the right to request and obtain evidence as to the manner and/or cause of the Insured’s death.

Currency: All amounts to be paid to or by the Company will be in the currency of the United States of America.

Misstatement of Age and/or Sex: If the Insured’s age and/or sex on the Policy Date has been misstated, the benefits payable under this Policy will be the amount of insurance that the cost of insurance (deducted from the Policy Value Account at the beginning of the month in which death occurred) would have purchased for the correct age and/or sex on the Policy Date. The applicable factor used in determining the Death Benefit shall be the factor required by Section 7702 of the Code reflecting the Insured’s correct age and/or sex.

If the age and/or sex of the Insured or any other person covered under a rider has been misstated on the Policy Date, the benefits payable under the rider will be the benefit that the amount charged would have purchased for the correct age and/or sex on the Policy Date.  If the age is misstated in such a way that the Insured was not eligible for coverage under the Policy, a mortality charge and benefit will be extrapolated.

Payment of Premiums: The first Premium is due on or before the Policy Date shown on the Policy Schedule. The Company will mail the Owner a billing notice 30 days in advance of a Premium due date. All Premiums after the first are to be made payable in advance to the Company at the Administrative Office and will be due on the Monthly Anniversary on which the cost of insurance exceeds the Policy Value Account less any outstanding Policy loans and accrued loan interest. Subject to limitations as provided in this Policy, Premiums paid after the first may be paid in any amount and at any time before the Insured attains the age of 121. Confirmation will be sent upon receipt of each Premium.

Allocation of Premiums:  Premiums (less Expense Charges) will be allocated among the available Sub-Account(s) or the Fixed Account selected by the Owner. To the extent a selected Sub-Account is not available, the Company will allocate that portion of the Premium payment to the Money Market Sub-Account until receipt of further allocation instructions from the Owner. The Owner will be bound by the investment experience of such Sub-Account(s) and the Fund(s) in which such Sub-Account invests. The Company is not responsible for any tax consequences, liability or effect which may result due to Premiums being invested in any Sub-Accounts during the right to cancel period. Where state laws provide for the Company to refund the Premium if the Policy is cancelled during the right to cancel period, the Company reserves the right to allocate the Premium to the Money Market Fund during the right to cancel period.

Grace Period: The Monthly Anniversary is the due date for any Premium required to keep the Policy in force for that month. Except for the first Premium, if the amount in the Policy Value Account, less any Policy loan and accrued interest, on the last day of a Policy Month is not sufficient to cover the monthly deduction for the cost of insurance for the next Policy Month, a grace period of 61 days from the due date will be allowed for the payment of an amount sufficient to cover the monthly cost of insurance for the next 2 months. Coverage will remain in force during the grace period. If the Premium due is not paid within the grace period, all coverage under this Policy will cease at the end of the 61-day period. Notice of such Premium due will be mailed to the last known address of the Owner and any assignee of record at least 31 days prior to the date coverage will cease. If the Insured dies during the grace period, any cost of insurance charges due and unpaid will be deducted from the Death Benefit Proceeds.

Periodic Premium Amounts: The Company may recommend a periodic Premium amount. The actual amount of Premium needed may change, depending on the number of Premium payments made, changes in coverage, investment experience, monthly risk rate, and partial withdrawals and Policy loans made.

Additional Premium Payments: The Owner may make additional Premium payments as described below prior

to reaching Attained Age 121. Additional Premium payments may be limited to amounts that will not cause the Policy to become a modified endowment contract under Section 7702A of the Code.

The minimum additional Premium that will be accepted at one time is as set out in the Policy Schedule. The Company reserves the right to restrict or refuse additional Premium payments that exceed the initial periodic Premium amount shown on the Policy Schedule. No Premium will be refused if it is necessary to continue coverage of the Policy. The Company is not responsible for any unintended tax consequences of any additional Premium payments and nothing contained herein is to be construed as the giving of tax advice.

Reinstatement: This Policy may be reinstated within 3 years after the coverage ceased, unless it has been surrendered. For the Policy to be reinstated, the Company must receive:

· A Request from the Owner;

· Evidence of insurability for the Insured and any other person covered by any rider or endorsement, at the Owner’s expense;

· Payment of the cost of insurance for the grace period;

· Payment of an amount equal to 3 months’ cost of insurance and other Expense Charges. Such payment less the Expense Charges will be credited to the Policy Value Account as of the date of Reinstatement; and

· Payment or reinstatement of any Policy loan(s) and accrued loan interest which was outstanding as of the date the coverage ceased, including interest thereon. Interest will be the maximum loan interest rate per year and will be compounded annually to the date of the Policy reinstatement.

Reinstatement will become effective on the date the application for reinstatement is approved by the Company.

Annual Statement: At least annually after each Policy Anniversary, the Company will send the Owner a statement, without charge, and reflecting information as of a date not more than four months prior to the date of mailing, showing:

· The Policy Value Account, if any, from the beginning of the current report period and at the end of the current report period;

· The beginning and end dates of the current report period;

· All amounts credited and debited;

· The current Death Benefit at the end of the current report period on each life covered;

· Premiums paid and investment experience since the last statement;

· Partial withdrawals and charges since the last statement;

· Outstanding policy loans and loan interest paid since the last statement;

· The current allocation in each of the Sub-Accounts; and

· Current allocation in the Fixed Account; and

· Any other information required by federal and/or state laws.

If the Policy’s Cash Surrender Value less any Return of Expense Charge Benefit, if applicable, will not maintain the Policy in force until the next reporting period unless further payments are made, a notice to this effect will be included in the report.

Projection of Benefits and Values: The Owner may at any time request from the Company a projection of future benefits and values. The first projection provided during a Policy Year will be at no charge. Each additional projection during that Policy Year will be subject to a maximum fee of the amount shown on the Policy Schedule and payable at the time of the Request for the additional projection of benefits and values.

The projection of benefits and values will be based on:

· The current Policy Value Account;

· Assumed investment experience;

· Coverage amounts and the Death Benefit option elected;

· Recommended periodic premium amounts; and

· Current monthly risk rates.

DEATH BENEFIT PROVISIONS

Death Benefit Options: The Death Benefit option for this Policy as of the Issue Date is shown on the Policy Schedule.  The Death Benefit is determined by the option in effect at the Insured’s date of death.

Option 1: Level Death

The Death Benefit will be the greater of:

a)  The Total Face Amount shown on the Policy Schedule, less any partial withdrawals; or

b)  The Cash Value on the Insured’s date of death multiplied by the applicable factor shown on the Policy Schedule for the Insured’s age at date of death.

Option 2: Coverage Plus

The Death Benefit will be the greater of:

(a) The Total Face Amount shown on the Policy Schedule, plus the Policy Value Account on the Insured’s date of death; or

(b) The Cash Value on the Insured’s date of death multiplied by the applicable factor shown on the Policy Schedule for the Insured’s age at date of death.

Death Benefit Payment: The Death Benefit payable will be reduced by outstanding Policy loans and accrued loan interest.  Subject to the provisions of any rider or endorsement, the Death Benefit payable on the Insured’s death will be paid in a lump sum unless the Owner elects to receive all or a portion of the Death Benefit Proceeds under a settlement option that the Company is then offering.

The Company will pay interest on the Death Benefit Proceeds from the date of death, to the date of settlement at the rate applicable to proceeds of life insurance left on deposit with the Company.  Interest will accrue at an additional interest rate of 10% annually beginning 31 calendar days from the latest of the following dates:

(a) The date that the Company receives due proof of the death of the Insured, which may include receipt of a certified copy of the death certificate and proof of any Beneficiary or claimant’s interest;

(b) The date the Company receives sufficient information to determine its liability, the extent of the liability, and the appropriate payee legally entitled to the proceeds; or

(c) The date that legal impediments to payment of proceeds that depend on the action of parties other than the Company are resolved and sufficient evidence of the same is provided to the Company. Legal impediments to payment include, but are not limited to:

i. The establishment of guardianships and conservatorships;

ii. The appointment and qualification of trustees, executors and administrators; and

iii. The submission of information required to satisfy state and federal reporting requirements.

Change of Death Benefit Option: After the first Policy Year, but not more than once each Policy Year and subject to the Company’s approval, the Owner may change the Death Benefit option by Request. Any change will be effective on the Monthly Anniversary following the date the Company approves the Request. A fee of a maximum amount shown on the Policy Schedule will be deducted from the Policy Value Account for each change.

A change in the Death Benefit option is subject to the following conditions:

· At the time of a change from Option 1 to Option 2, the new Total Face Amount, at the time of the change, will equal the existing (prior to change) Total Face Amount less the Policy Value Account. Evidence of Insurability may be required.

· At the time of a change from Option 2 to Option 1, the new Total Face Amount, at the time of the change, will equal the existing (prior to change) Total Face Amount plus the Policy Value Account.

Change of Total Face Amount: By Request, and subject to the Company’s approval, the Owner may at any time increase or decrease the Total Face Amount provided by this Policy.

For a decrease in Total Face Amount:

· The Company must receive a Request;

· The decrease will become effective on the Monthly Anniversary following approval of the Request;

· The decrease will apply first to the most recent increase or increases in Total Face Amount for purposes of the “Incontestability” provision; and

· The minimum decrease amount is at least equal to that amount required and shown on the Policy Schedule.

The Total Face Amount may not be decreased below the amount shown on Policy Schedule unless prior approval is obtained from the Company. Any decrease in the Face Amount may affect the Cash Value.

For an increase in Total Face Amount:

· The Company must receive a Request;

· The increase will be subject to Evidence of Insurability satisfactory to the Company;

· The increase will be effective on the Monthly Anniversary following the approval of the Request for the increase, subject to the deduction of the first month’s cost of insurance from the Policy Value Account; and

· The minimum increase amount is at least equal to that amount required and shown on the Policy Schedule.

FEES AND CHARGES

Deduction of Fees and Charges: Unless otherwise stated, fees and charges will be deducted from the Policy Value Account on a pro-rata basis from the Sub-Accounts and/or Fixed Account, where applicable.  The Owner may Request that fees and charges be deducted from specific Sub-Accounts and/or Fixed Account, where applicable or designate a specific Sub-Account for this purpose.

Any such request is subject to the provisions or restrictions of any riders or endorsements or any Sub-Accounts and the available value in the Sub-Accounts or Fixed Account where applicable.

If there is insufficient value in a selected Sub-Account(s) or Fixed Account, then the Company may deduct any fees and charges or the remainder of such fees and charges on a pro-rata basis from the Sub-Account(s) or Fixed Account where applicable. The Owner may be required to maintain in any designated Sub-Account(s) amounts sufficient to cover estimated Policy fees and charges for specified periods. The Company reserves the right to transfer Sub-Account Value from any Sub-Account or Fixed Account to the Money Market Sub-Account in amounts sufficient to cover estimated Policy fees and charges for specified periods.

Cost of Insurance: An amount will be deducted on each Monthly Anniversary from the Policy Value Account to pay the cost of insurance for that Policy Month. The cost of insurance is calculated on the Monthly Anniversary and is equal to:

(a) The Death Benefit divided by the death benefit interest rate factor as shown on the Policy Schedule, less the Policy Value Account on each Monthly Anniversary, multiplied by the current monthly risk rate for the Insured’s Attained Age; plus

(b) The extra Premium for any rated Premium class; plus

(c) The monthly Administration Charge; plus

(d) The cost of insurance for any riders or endorsements.

If there has been an increase or decrease in Death Benefit during the Policy Year, the cost of insurance calculation will be adjusted accordingly to reflect the change.

Monthly Risk Rate: The maximum monthly risk rate is shown on the Policy Schedule. The Company may charge a lower monthly risk rate. The maximum risk rates shown are based on the Mortality Tables as shown on the Policy Schedule, age nearest birthday. The Company reserves the right to change the monthly risk rate based on the Company’s expectations of future mortality, investment earnings, persistency, capital and reserve requirements, reinsurance cost and expenses (including taxes) subject to the maximum risk rates.  Any change in the monthly risk rate will not discriminate unfairly within any class of Owners or Insureds.

Expense Charge: The maximum expense charge for this Policy is shown on the Policy Schedule. The Company may asses an expense charge less than the maximum expense charge, but it will never exceed the maximum expense charge. The expense charge will be deducted from each Premium paid.  This would include any Premium paid to reinstate the Policy.

Administration Charge: The maximum administration charge for this Policy is shown on the Policy Schedule. The Company may asses an administration charge less than the maximum administration charge, but it will never exceed the maximum administration charge. This charge is deducted from the Policy Value Account on the Monthly Anniversary.

Mortality and Expense Charges: This charge is accrued on a daily basis based on an annual percentage of the net asset value of each Fund and is deducted on the Monthly Anniversary from the Sub-Accounts.  The actual mortality and expense charge (“M&E Charge”) is determined by the Company, but may not exceed the annual guaranteed maximum M&E Charge as shown on the Policy Schedule.

Transaction Charges: The Company reserves the right to charge a transaction fee for processing transactions not specifically detailed elsewhere in the Policy The maximum amount of such transaction charge is as shown on the Policy Schedule.

POLICY VALUES, LOANS AND NONFORFEITURE PROVISIONS

Policy Value Account: The Policy Value Account is the sum of the Sub-Account Value, the Fixed Account value, and the Loan Account value. Each Premium less any expense charge will be credited to the Policy Value Account on the date received at the Administrative Office.  On the Monthly Anniversary a deduction will be made from this account for the cost of insurance as stated in the “Cost of Insurance” provision and any other charges specified in the Policy as being deducted from the Policy Value Account.

Sub-Account Value: The Sub-Account Value is the total dollar amount of all Units credited to the Owner’s Policy under each of the Sub-Accounts, excluding the Fixed Account, if applicable. Each Sub-Account’s Value is equal to the sum of:

· The net asset value of the Fund(s) in the Sub-Account at the last Valuation Date;

· Any Premium, less Expense Charges deducted from Premiums received during the current Valuation Period which is allocated to the Sub-Account;

· Any policy loan repayment amount allocated to the Sub-Account;

· All values transferred to the Sub-Account; and

· Any net investment return allocated to the Sub-Account.

MINUS the following:

· All values transferred to another Sub-Account, the Fixed Account and Loan Account taken from the Sub-Account during the current Valuation Period;

· All partial withdrawals from the Sub-Account during the current Valuation Period;

· An amount representing the M&E Charge. This charge is accrued on a daily basis based on an annual percentage of the net asset value of each Fund and is deducted on the Monthly Anniversary from the Sub-Accounts;

· An amount for the cost of insurance (as defined in the “Cost of Insurance” provision) deducted from the Sub-Accounts on the Monthly Anniversary; and

· An amount for transaction charges, Transfer fees and change of death benefit option fee if these fees are deducted from the Sub-Accounts.

Amounts allocated or transferred to a Sub-Account are used to purchase Units in the Sub-Account. The number of Units to be credited will be determined by dividing the amount allocated or transferred to the Sub-Account by the value of a Unit in that Sub-Account.  The value of a Unit at the end of every Valuation Period is the value of the Unit at the end of the previous Valuation Period times the Net Investment Factor, as described below. The Sub-Account Value for a Policy is determined on any day by multiplying the number of Units attributable to the Policy in that Sub-Account by the Unit value for that Sub-Account on that day.  Units for the initial Premium will be credited to the Sub-Accounts selected and Units for subsequent Premium payments will be credited at the end of the Valuation Period during which the Company receives the Premium.

In addition, whenever a Valuation Period includes a Monthly Anniversary, the value of each Sub-Account at the end of such period is reduced by the portion of any accrued policy fees or charges as are described in the Policy as being allocated to the Sub-Account.

Net Investment Factor: The Unit value for each Sub-Account for any Valuation Period is determined by the Net Investment Factor. The Net Investment Factor is an index applied to measure the investment performance of a Sub-Account from one Valuation Period to the next. The Net Investment Factor for a Sub-Account for any Valuation Period is determined by dividing (a) by (b) where

(a)         is the net result of:

i. the Net Asset Value Per Share of the Fund held in the Sub-Account, determined at the end of the current Valuation Period; plus

ii. the per share amount of any dividend or capital gain distributions made by the Fund to the Sub-Account, if the “ex-dividend” date occurs during the current Valuation Period; plus or minus

iii. a per share charge or credit for any taxes reserved for, which is determined by the Company to have resulted from the operations of the Sub-Account.

(b)         is the net result of:

i. Net Asset Value Per Share of the Fund held in the Sub-Account, determined at the end of the last Valuation Period.

The Company will deduct from the assets of the Sub-Account(s) all fees and expenses incurred in connection with the operation of the Sub-Account(s).

Fixed Account Value: The Fixed Account value is equal to the sum of:

· Premiums, less Expense Charges, allocated to the Fixed Account;

· Sub-Account Value transferred to the Fixed Account; and

· Interest credited to the Fixed Account.

MINUS the following

· The portion of any accrued Policy fees and charges allocated to the Fixed Account;

· An amount for the cost of insurance (as defined in the “Cost of Insurance” provision of the Policy) deducted from the Fixed Account on the Monthly Anniversary;

· An amount for transaction charges, Transfer fees and change of death benefit option fee deducted from the Fixed Account;

· Partial withdrawals from the Fixed Account including any applicable partial withdrawal charges;

and

· Transfers from the Fixed Account.

During any Policy Month the Fixed Account value will be calculated on a consistent basis. For purposes of crediting interest, Policy value deducted, transferred or withdrawn from the Fixed Account is accounted for on a first in first out basis.

Fixed Account Interest: The interest rate credited to the Policy Value Account in the Fixed Account is set by the Company, but is guaranteed to be at least the minimum guaranteed interest rate shown on the Policy Schedule. The Company may credit interest at rates higher than the guaranteed interest rate at its discretion.

The Company will review the interest crediting rate monthly and may credit interest at rates higher than the guaranteed interest rate but this is at the Company’s discretion. The Company may reset the interest rate monthly.

Policy Loan: While this Policy is in force, the Owner by Request may obtain a Policy loan from the Company on the security of the Policy. The minimum loan amount is as set out in Policy Schedule. The total amount of Policy loans cannot be more than the maximum described in the “Loan Value” provision. Policy loan amounts will be withdrawn first on a pro rata basis from the Sub-Accounts and Fixed Account, unless the Company, at its discretion, allows the Owner to specify such Sub-Accounts or Fixed Account.

Effect of a Loan: When a Policy loan is made, funds are transferred out of the Variable Account and Fixed Account and into the Loan Account.

A Policy loan, whether or not repaid, will have a permanent effect on the Cash Surrender Value and on the Death Benefit, as described in this Policy. If not repaid, the outstanding Policy loan and accrued loan interest will reduce the amount of Death Benefit Proceeds and the amount available upon surrender of this Policy.

Loan Value: The maximum Policy loan value is equal to:

· 90% of the Policy Value Account at the time of the Policy loan; less

· The current cost of insurance remaining for the balance of the Policy Year; less

· Interest on the Policy loan to the next Policy Anniversary date.

Loan Interest: The loan interest rate is used to determine the amount of any accrued loan interest on the outstanding Policy loan. Loan interest is due and payable on each Policy Anniversary. Interest not paid when due will be added to the outstanding Policy loan and will bear interest at the loan interest rate.

Interest credited on the portion of the Policy Value Account being used as collateral for a Policy loan is the loan interest rate less an amount not to exceed the maximum Loan Interest Credit Spread as shown on the Policy Schedule. This interest credited will not exceed 4%.

Loan Interest Rate: The loan interest rate will be determined annually at the beginning of each Policy Year. It is guaranteed for that Policy Year and applies to all Policy loans outstanding during that Policy Year. Interest is due and payable on each Policy Anniversary. Interest not paid when due will be added to the Policy loan and will bear interest at the loan interest rate.

The maximum loan interest rate for Policy loans is based on a Published Monthly Average for the calendar month ending two (2) months before the date on which the rate is determined. That average is:

(a) The Xxxxx’x Corporate Bond Yield Average - Monthly Average Corporates as published by Xxxxx’x Investors Service, Inc. or any successor thereto; or

(b) In the event that the Moody’s Corporate Bond Yield Average - Monthly Average Corporates is no longer published, a substantially similar average, established by regulation issued by the Commissioner.

The Company must reduce the loan interest rate if the maximum loan interest rate is lower than the loan interest rate for the previous Policy Year by one-half of one percent or more. Any increase to the loan interest rate must be at least one-half of one percent. No increase may be made if the loan interest rate would exceed the maximum loan interest rate. The Company will send to the Owner and any assignee of record advance notice of any increase in the rate.

Loan Repayment: The Owner must specify that any payment made is to be applied to repay a Policy loan. The Expense Charge will not apply to repayments of Policy loans. The Owner may allocate Policy loan repayments among the Sub-Accounts and/or Fixed Account on a pro rata basis.

Surrender Benefit: The   Owner   may   surrender this   Policy for   the surrender benefit. The surrender benefit is the Cash Surrender Value less any monthly cost of insurance charges on the date of surrender. All coverage will end on the effective date of surrender of the Policy. No Death Benefits will be paid after the effective date of surrender of the Policy.

Return of Expense Charge Benefit: If the Policy is surrendered for the surrender benefit within the first 7 years from the Policy Date the Company will return a percentage of the expense charge. The Return of Expense Charge Benefit will be a percentage of the Policy Value Account on the date the surrender Request is received at the Administrative Office. The Return of Expense Charge Benefit will equal the percentage of expense charge paid plus 1% in Policy Year 1, and will then be reduced by a proportional amount in each Policy Year thereafter with it equaling 1% in Policy Year 7. Beginning in Policy Year 8 and all subsequent Policy Years, the Return of Expense Charge Benefit will be 0%.

The Return of Expense Charge Benefit is not available if the Policy is surrendered under the terms of Section 1035 of the Code and is not calculated for a Policy loan, partial withdrawal or when coverage under the Policy ceases.

The Return of Expense Charge Benefit creates a General Account obligation of the Company. The Return of Expense Charge Benefit is payable to the Owner. The Company may reduce or eliminate any Return of Expense Charge Benefit when there is a change of Owner or an assignment of the Policy.

Continuation of Insurance: If Premium payments cease, coverage under this Policy or any attached riders or endorsements will continue until the Policy Value Account, less any outstanding Policy loan and accrued loan interest is insufficient to cover all accrued Policy fees and charges, including charges for any riders or endorsements. When the amount is insufficient, the “Grace Period” provision will go into effect.

Policy Maturity: If the Insured is living and the Policy is in force on the Policy Anniversary at attained age 121 then this Policy will remain in force. The Death Benefit will be equal to the Policy Value Account. No Premium payments will be required. Partial withdrawals and Policy loans will be permitted, subject to the provisions herein, as well as the “Continuation of Insurance” provisions and the provisions of any riders and endorsements attached to the Policy. No further cost of insurance charges will be deducted. This Policy may not qualify as life insurance if it is continued beyond the Policy Anniversary nearest the 121st birthday and may be subject to adverse tax consequences. Please consult a tax advisor prior to continuing coverage beyond that time.

Tax Considerations: This Policy is intended to qualify as life insurance for tax purposes and is designed to meet the requirements of Sections 101 and 7702 of the Code, as they existed on the Issue Date. If the Death Benefit is based on the applicable factor shown on the Policy Schedule, the Company in its sole discretion may refund all or a portion of the Cash Value which causes the Death Benefit to be based on such applicable factor.

This Policy may be purchased as a modified endowment contract. Distributions from modified endowment contracts are subject to different taxation rules than distributions from a life insurance Policy that is not a modified endowment contract. If the Policy is not a modified endowment contract when issued, the payment of excess Premium or a material change in the benefits or terms of the contract, as outlined in Section 7702A of the Code, may cause the Policy to be treated as a new contract and may cause the Policy to become a modified endowment contract. Nothing in this Policy is to be construed as the giving of tax advice.

Partial Withdrawal: The Owner may make a partial withdrawal from the Policy Value Account at any time while the Policy is in force. The minimum amount per withdrawal is the amount shown on the Policy Schedule. The maximum amount that may be withdrawn is 90% of the Policy Value Account less outstanding Policy loans and accrued loan interest.

There is no administrative fee charged for the first partial withdrawal in any Policy Year. A maximum administrative fee shown in the Policy Schedule will be deducted from the Policy Value Account for each

additional partial withdrawal made in the same Policy Year. The partial withdrawal will be effective on the Transaction Date. The Policy Value Account will be reduced by the withdrawal amount, which will be taken from all the Sub-Accounts and the Fixed Account on a pro-rata basis.

If the Policy is in force under Option 1, Level Death Benefit, then the Face Amount also will be reduced by the amount of each withdrawal. Withdrawals may not be repaid directly into the Policy Value Account. Any payments received will be subject to the “Additional Premium Payments” Provision.

Computation of Values: All guaranteed calculations are based on the Mortality Tables shown on the Policy Schedule, age nearest birthday. These computations assume that Death Benefits are to be paid at the end of the Policy Year in which death occurs.  Any net single Premium will be computed on the basis of the Insured’s Attained Age and Premium class. A detailed statement of the method of computing the values of this Policy has been filed with the Interstate Insurance Product Regulation Commission. Any cash values and non-forfeiture benefits available under the Policy are not less than the minimum values and benefits required by or pursuant to the NAIC Variable Life Insurance Regulation, model # 270 using actuarial guidelines XXIV.

Postponement: If the Company receives a Request for surrender, partial withdrawal, or a Policy loan, the Company may generally postpone any payment for up to 7 days. To the extent permitted under applicable law, the Company will also generally defer the determination or payment of amounts payable under the Policy whenever and for so long as it is impractical for the Company to determine the value of the assets of the Variable Account including, without limitation, when the NYSE is closed for trading or when the SEC has determined that a state of emergency exists or redemptions are suspended pursuant to SEC rules or the SEC, by order, permits a delay in payment in order to protect an Owner, or the delay is to effect the liquidation of assets without penalty.

For Sub-Accounts which are not valued on each business day, the Company may postpone payments until the next Valuation Date or the Company may postpone all procedures which require valuation of the Sub-Account until valuation is possible.  During the postponement period, the Sub-Account Value may continue to be subject to the investment experience (gains or losses) of the Fund(s) and all applicable charges.

The Company may defer payment of any withdrawal, surrender, or Policy loan proceeds from the Fixed Account for up to 6 months after a Request is received.  If the Company delays payment of surrender benefits under this Policy, the Company will pay interest at the rate specified under applicable state law as required, if any, at the time of the Request.

Settlement Options: All amounts payable under the Policy, including, but not limited to, Death Benefit Proceeds and any proceeds from any surrender, partial withdrawal or Policy loan will be paid in a lump sum unless the Owner elects by Request to have all or a portion of such amounts paid under a different settlement option that the Company may then be offering.

TRANSFER PROVISIONS

Transfers: At any time while this Policy is in force, the Owner, by Request, may Transfer all or a portion of the Sub- Account Value or the Fixed Account among the available Sub-Accounts or the Fixed Account subject to the provisions set out below. There is no Transfer fee for the number of Transfers made in a calendar year as shown on the Policy Schedule. The Company may charge a Transfer fee, as shown on the Policy Schedule, for each subsequent Transfer. All Transfers made on a single Transaction Date will be aggregated to count as only one Transfer toward the free Transfers.

Sub-Account Transfers: The Company may limit the availability of any Sub-Account with respect to Transfers.

The Company reserves the right to reject Transfers if the Company deems, in its discretion, that the Transfers would disrupt the management of the Variable Account, any Sub-Account, or any Fund.

Fixed Account Transfers: Transfers into the Fixed Account are limited to the period and dollar amount as shown on the Policy Schedule. The Company may decrease or waive these limits. A Transfer out of the Fixed Account may only be made once during a period shown on the Policy Schedule and is limited to the greater of the maximum of the balance of the Fixed Account as shown on the Policy Schedule, or the amount of the Transfer from the previous Transfer period. The Company may decrease or waive these limits. A Policy loan and partial withdrawal will be considered a Transfer from the Fixed Account.

THIS PAGE INTENTIONALLY LEFT BLANK

INDIVIDUAL FLEXIBLE PREMIUM VARIABLE UNIVERSAL LIFE INSURANCE POLICY

ADJUSTABLE DEATH BENEFIT.  Proceeds payable at death are subject to Policy provisions. Please refer to the “Death Benefit” section of this Policy for a description of the Death Benefit. Flexible Premiums are payable while the Insured is alive. If no Premiums are paid after the first Premium, or if subsequent Premiums prove to be insufficient, this coverage may cease prior to age 121.  PAYMENTS AND VALUES BASED ON THE INVESTMENT EXPERIENCE OF THE SUB-ACCOUNTS AND ARE VARIABLE, MAY INCREASE OR DECREASE ACCORDINGLY, AND ARE NOT GUARANTEED AS TO AN AMOUNT. Non-Participating. No dividends payable.

POLICY SCHEDULE

DEATH BENEFIT

[Option 1: Level Death] [Option 2: Coverage Plus]

OWNER/POLICY INFORMATION
Owner:	[XYZ Corporation]
Insured:	[XXXX XXX]
Policy Number:	[1234567]
Policy Date:	[August 1, 2020]
Total Face Amount:	$[250,000]
Issue Date:	[August 1, 2020]
Issue Age/Sex:	[35/ Male]
State of Delivery:	[Alabama/Wyoming]
State Department of Insurance
Telephone Number:	[000-000-0000]
Mortality Table:	2017Loaded Commissioners Standard Ordinary Gender Distinct, Smoker Distinct Ultimate ANB Mortality Tables
PREMIUM, EXPENSE AND POLICY INFORMATION
Premium Class:	[Standard]
Initial Periodic Premium Amount:	$[3,484.89 Per Year]
Minimum Additional Premium Amount:	$[100]
Minimum Decrease/Increase in Total Face Amount:	$[25,000]
Minimum Face Amount:	$[100,000]
Minimum Loan Amount:	$[500]
Minimum Partial Withdrawal Amount:	$[500]
Maximum Loan Interest Credit Spread:	[1.5%]

If no Premiums are paid after the first Premium or if subsequent Premiums prove to be insufficient, this coverage may cease prior to age 121. The Owner may have to pay more than the Premiums shown above to keep this Policy and coverage in force.

FEES AND CHARGES
Maximum Administration Charge:	$[10] per month
Maximum Expense Charge:	[10.00] % of premium
Maximum Mortality & Expense Charge:	[.90%]
Risk Rates:	Shown on Page 2a
Maximum Projection of Future Benefits Fee:	$50
Death Benefit Interest Rate Factor:	1.00327374
Number of Free Transfers per Year:	12
Transfer Fee after Free Transfers:	$10
Maximum Change of Death Benefit Option Fee:	$100
Maximum Partial Withdrawal Fee:	$100
Maximum Transaction Charge:	$150
FIXED ACCOUNT
Maximum Dollar Amount Allowed for Transfer
into Fixed Account	$20,000,000
Transfer Period into Fixed Account	once every 60 days
Guaranteed Interest Rate:	[2%]
Transfer Period out of the Fixed Account:	once every 365 days
Maximum Percentage of Funds Available
for Transfer Out of the Fixed Account:	[25%]

SCHEDULE OF BENEFITS AND PREMIUMS
BENEFITS	FACE AMOUNT	MONTHLY COSTS	PREMIUM PERIOD
Base Policy Face Amount	$[200,000]	See Policy Schedule	To Insured Age 121
[Term Life Rider Face Amount]	$[50,000]	[See Policy Schedule]
Total Face Amount	$[250,000]	See Policy Schedule

ICC20-V17S-J355X Page S[1]

GUARANTEED MAXIMUM MONTHLY RISK RATES

(Based on the Attained Age of the Insured; Premiums are subject to change)

Attained		Non-Smoker				Smoker				Attained		Non-Smoker				Smoker
Age		Male		Female		Male		Female		Age		Male		Female		Male		Female
[20		0.07417		0.02750		0.07500		0.02750		71		1.23333		0.83083		2.92833		2.27333
21		0.07750		0.02750		0.07750		0.02750		72		1.39167		0.93000		3.23333		2.46083
22		0.07417		0.02750		0.08000		0.02750		73		1.57583		1.04500		3.56750		2.66833
23		0.07167		0.02750		0.08250		0.02917		74		1.78583		1.17833		3.91917		2.89250
24		0.07083		0.02750		0.08500		0.03250		75		2.02000		1.33333		4.27750		3.14167
25		0.07083		0.02750		0.08750		0.03417		76		2.27667		1.50917		4.63250		3.41583
26		0.06000		0.02750		0.08750		0.03417		77		2.55917		1.71417		4.98333		3.72417
27		0.05750		0.02917		0.08583		0.03417		78		2.87167		1.95250		5.33250		4.06167
28		0.05250		0.03083		0.08417		0.03500		79		3.22833		2.23667		5.69917		4.43500
29		0.04833		0.03250		0.08333		0.03667		80		3.64000		2.58167		6.09250		4.93167
30		0.04583		0.03417		0.08333		0.04000		81		4.12167		2.98000		6.52667		5.52750
31		0.04750		0.03667		0.08667		0.04250		82		4.66083		3.37333		6.97083		6.20417
32		0.04917		0.04000		0.09250		0.04500		83		5.28833		3.80250		7.65833		6.96167
33		0.05583		0.04583		0.09917		0.04917		84		6.01583		4.31833		8.43500		7.73583
34		0.06500		0.05167		0.10667		0.06500		85		6.86167		5.10917		9.31917		8.43167
35		0.07500		0.05917		0.11417		0.07250		86		7.84083		5.81083		10.32167		9.53333
36		0.08750		0.06667		0.12500		0.08583		87		8.96750		6.59667		11.43917		10.51167
37		0.09833		0.07417		0.13500		0.10250		88		10.24167		7.51833		12.66667		11.58167
38		0.10833		0.08167		0.14750		0.11667		89		11.62417		8.54250		13.95000		12.71833
39		0.11417		0.08417		0.16667		0.12833		90		13.09833		9.66667		15.27250		13.90583
40		0.11917		0.08583		0.18750		0.13833		91		14.61250		10.86417		16.58750		15.09583
41		0.12583		0.08667		0.21000		0.14750		92		16.12667		12.16500		17.86000		16.32417
42		0.13417		0.08667		0.23250		0.15583		93		17.62417		13.56917		19.08833		17.57667
43		0.14167		0.08667		0.25250		0.16500		94		19.03000		14.98417		20.20917		18.73000
44		0.14917		0.08750		0.26750		0.17417		95		20.28333		16.50750		21.17500		19.90417
45		0.15250		0.08750		0.27917		0.18500		96		21.86917		18.39000		22.50750		21.38083
46		0.15917		0.09083		0.29750		0.20250		97		23.55750		20.45917		23.96833		22.92417
47		0.16417		0.09500		0.31583		0.22167		98		25.39250		22.71583		25.61333		24.51833
48		0.17083		0.10000		0.33750		0.24333		99		27.33333		25.12917		27.41250		26.11417
49		0.17833		0.10667		0.36083		0.26667		100		29.34083		27.66583		29.34083		27.66583
50		0.18750		0.11500		0.38750		0.29250		101		31.20583		29.78500		31.20583		29.78500
51		0.20167		0.12583		0.41917		0.32250		102		33.06667		31.88167		33.06667		31.88167
52		0.21917		0.14000		0.45333		0.35500		103		34.88833		33.91917		34.88833		33.91917
53		0.24000		0.15750		0.49250		0.39083		104		36.63750		35.86417		36.63750		35.86417
54		0.26167		0.17667		0.53667		0.43000		105		38.28000		37.68250		38.28000		37.68250
55		0.28333		0.19667		0.58583		0.47417		106		39.78583		39.34167		39.78583		39.34167
56		0.30333		0.21583		0.64250		0.52417		107		41.94333		41.50917		41.94333		41.50917
57		0.32250		0.23417		0.70583		0.58083		108		44.21750		43.79500		44.21750		43.79500
58		0.34250		0.25333		0.77917		0.64417		109		46.61583		46.20667		46.61583		46.20667
59		0.36583		0.27333		0.86167		0.71417		110		49.14333		48.75167		49.14333		48.75167
60		0.39500		0.29583		0.95667		0.79250		111		51.80833		51.43667		51.80833		51.43667
61		0.43417		0.32167		1.06583		0.87917		112		54.61833		54.26917		54.61833		54.26917
62		0.48250		0.35250		1.19000		0.97500		113		57.58000		57.25833		57.58000		57.25833
63		0.53667		0.38750		1.32750		1.08000		114		60.70250		60.41167		60.70250		60.41167
64		0.59750		0.42667		1.47750		1.19417		115		63.99500		63.73917		63.99500		63.73917
65		0.66333		0.46917		1.64500		1.31917		116		67.46500		67.24917		67.46500		67.24917
66		0.73417		0.51417		1.82250		1.45250		117		71.12333		70.95250		71.12333		70.95250
67		0.81000		0.56333		2.00917		1.59583		118		74.98083		74.86083		74.98083		74.86083
68		0.89417		0.61667		2.20583		1.74667		119		79.04667		78.98333		79.04667		78.98333
69		0.98917		0.67750		2.41917		1.90417		120		83.33333		83.33333		83.33333		83.33333]
70		1.10083		0.74750		2.65667		2.07917

[The maximum risk rates shown reflect a flat extra of [.04] for the first [4] Policy years]

[The maximum risk rates reflect a [200%] multiple of the table above]

Page S2a

DEATH BENEFIT FACTORS

Cash Value Accumulation Test

Attained		Non-Smoker				Smoker				Attained		Non-Smoker				Smoker
Age		Male		Female		Male		Female		Age		Male		Female		Male		Female
[20		9.74450		11.39538		7.60801		8.69170		71		1.79318		1.94287		1.57665		1.66005
21		9.44009		10.99323		7.35725		8.37775		72		1.74317		1.88462		1.54505		1.62335
22		9.14577		10.60392		7.11451		8.07433		73		1.69560		1.82890		1.51533		1.58802
23		8.85549		10.22712		6.87949		7.78116		74		1.65044		1.77566		1.48745		1.55403
24		8.57034		9.86253		6.65190		7.49890		75		1.60762		1.72487		1.46127		1.52129
25		8.29178		9.50983		6.43150		7.22799		76		1.56704		1.67648		1.43655		1.48979
26		8.02045		9.16872		6.21801		6.96700		77		1.52853		1.63040		1.41301		1.45947
27		7.74944		8.83888		6.01031		6.71473		78		1.49194		1.58661		1.39038		1.43033
28		7.48473		8.52130		5.80777		6.47096		79		1.45716		1.54507		1.36842		1.40228
29		7.22508		8.21543		5.61039		6.23575		80		1.42413		1.50582		1.34702		1.37527
30		6.97125		7.92078		5.41845		6.00913		81		1.39286		1.46893		1.32609		1.34975
31		6.72423		7.63685		5.23209		5.79130		82		1.36336		1.43438		1.30560		1.32589
32		6.48582		7.36369		5.05206		5.58157		83		1.33552		1.40163		1.28535		1.30372
33		6.25571		7.10121		4.87866		5.37959		84		1.30936		1.37051		1.26614		1.28324
34		6.03540		6.85005		4.71174		5.18545		85		1.28490		1.34109		1.24801		1.26414
35		5.82511		6.60950		4.55112		5.00158		86		1.26214		1.31436		1.23101		1.24574
36		5.62438		6.37956		4.39644		4.82521		87		1.24113		1.28930		1.21521		1.22924
37		5.43323		6.15951		4.24794		4.65710		88		1.22189		1.26580		1.20065		1.21384
38		5.25046		5.94869		4.10510		4.49725		89		1.20441		1.24389		1.18735		1.19952
39		5.07527		5.74650		3.96795		4.34452		90		1.18855		1.22345		1.17516		1.18615
40		4.90618		5.55088		3.83698		4.19800		91		1.17411		1.20427		1.16390		1.17357
41		4.74273		5.36136		3.71192		4.05702		92		1.16078		1.18603		1.15328		1.16143
42		4.58500		5.17755		3.59247		3.92115		93		1.14812		1.16846		1.14288		1.14945
43		4.43302		4.99912		3.47818		3.79001		94		1.13563		1.15117		1.13220		1.13723
44		4.28634		4.82598		3.36841		3.66346		95		1.12250		1.13346		1.12045		1.12395
45		4.14468		4.65819		3.26237		3.54127		96		1.10758		1.11460		1.10652		1.10881
46		4.00720		4.49546		3.15959		3.42338		97		1.09019		1.09395		1.08975		1.09107
47		3.87423		4.33829		3.06042		3.31019		98		1.06858		1.06994		1.06847		1.06902
48		3.74537		4.18659		2.96462		3.20152		99		1.04000		1.04000		1.04000		1.04000
49		3.62066		4.04025		2.87221		3.09724		100		1.04000		1.04000		1.04000		1.04000
50		3.50003		3.89927		2.78306		2.99714		101		1.04000		1.04000		1.04000		1.04000
51		3.38346		3.76360		2.69714		2.90110		102		1.04000		1.04000		1.04000		1.04000
52		3.27121		3.63324		2.61447		2.80905		103		1.04000		1.04000		1.04000		1.04000
53		3.16329		3.50822		2.53490		2.72081		104		1.04000		1.04000		1.04000		1.04000
54		3.05967		3.38851		2.45841		2.63624		105		1.04000		1.04000		1.04000		1.04000
55		2.96010		3.27389		2.38494		2.55519		106		1.04000		1.04000		1.04000		1.04000
56		2.86429		3.16405		2.31440		2.47757		107		1.04000		1.04000		1.04000		1.04000
57		2.77189		3.05858		2.24678		2.40330		108		1.04000		1.04000		1.04000		1.04000
58		2.68263		2.95712		2.18199		2.33233		109		1.04000		1.04000		1.04000		1.04000
59		2.59638		2.85945		2.12004		2.26454		110		1.04000		1.04000		1.04000		1.04000
60		2.51310		2.76540		2.06086		2.19984		111		1.04000		1.04000		1.04000		1.04000
61		2.43285		2.67484		2.00445		2.13812		112		1.04000		1.04000		1.04000		1.04000
62		2.35581		2.58773		1.95079		2.07930		113		1.04000		1.04000		1.04000		1.04000
63		2.28201		2.50403		1.89987		2.02326		114		1.04000		1.04000		1.04000		1.04000
64		2.21136		2.42366		1.85158		1.96989		115		1.04000		1.04000		1.04000		1.04000
65		2.14375		2.34651		1.80580		1.91908		116		1.04000		1.04000		1.04000		1.04000
66		2.07900		2.27242		1.76248		1.87070		117		1.04000		1.04000		1.04000		1.04000
67		2.01695		2.20122		1.72143		1.82460		118		1.04000		1.04000		1.04000		1.04000
68		1.95742		2.13276		1.68245		1.78065		119		1.04000		1.04000		1.04000		1.04000
69		1.90032		2.06692		1.64538		1.73867		120		1.04000		1.04000		1.04000		1.04000]
70		1.84557		2.00364		1.61012		1.69849

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