SECOND Variable Products Compliance and Accounting Agreement
Exhibit k
SECOND Variable Products Compliance and Accounting Agreement
This SECOND Variable Products Compliance and Accounting Agreement is made and executed by
and between EquiTrust Investment Management Services, Inc. (“EquiTrust”), a Delaware corporation
having its principal offices at 0000 Xxxxxxxxxx Xxxxxx, Xxxx Xxx Xxxxxx, Xxxx; and CC Services,
Inc. (“CCSI”), an Illinois corporation with its principal offices at 0000 Xxxxxxx Xxx.,
Xxxxxxxxxxx, Xxxxxxxx 00000.
Recital
CC Services, Inc. provides and obtains services on behalf of its affiliated insurer, COUNTRY
Investors Life Assurance Company (“CILAC”) (CCSI and CILAC collectively referred to herein as
“COUNTRY”).
EquiTrust has provided COUNTRY accounting and compliance services, pursuant to a Variable Products
and Compliance and Accounting Agreement originally dated January 1, 2004 and as subsequently
amended (the “Prior Agreement’), with respect to CILAC’s variable annuity contracts and
variable life insurance contracts which are underwritten and sold by COUNTRY.
COUNTRY and Equitrust desire to execute a new Variable Products Compliance and Accounting Agreement
to adequately cover the change in the business relationship between the parties, since COUNTRY
plans to cease writing new variable products.
NOW THEREFORE, in consideration of the mutual covenants and obligations hereinafter expressed and
for the consideration recited herein, CCSI and EquiTrust hereby covenant, stipulate and agree as
follows:
Part 1 — SERVICES
1.1 Scope of Services. From and after the date of this Agreement, EquiTrust agrees to provide to
COUNTRY certain compliance and accounting functions with respect to the variable annuity contracts
and variable life insurance contracts issued by CILAC, as identified and listed in the schedule of
contracts annexed hereto as Schedule A. Such compliance and accounting functions shall consist of
the activities set forth and described in the Description of Services and Fees annexed hereto and
incorporated herein as Schedule B. Schedule A may be amended from time to time by mutual written
agreement of CCSI and EquiTrust. If COUNTRY determines that services described in the Description
of Services in Schedule B are no longer required as a result of ceasing sales of new variable
products then Schedule B will be amended to reflect the removal of such services/hours to perform
the required services.
1.2 Reduced or Additional Services. EquiTrust shall review any reduced or additional compliance or
accounting requirements at the request of COUNTRY and EquiTrust will provide COUNTRY with a written
proposal to include specific services to be provided, an implementation schedule and any associated
fees and expenses.
1.3 Compensation. In consideration of the services provided under this Agreement for and on
behalf of COUNTRY, CCSI will pay EquiTrust the Total Compliance & Accounting amount shown on
Schedule B, in quarterly installments, plus any additional hourly expenses required by Schedule B.
EquiTrust agrees that the compensation payable pursuant to Schedule B shall be accepted by
EquiTrust as full compensation from COUNTRY for the services described in Schedule B for such year.
If services are no longer required as result of COUNTRY ceasing the
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sales of new variable products and the Total Compliance & Accounting amount is reduced accordingly
then the remaining quarterly payments will be reduced accordingly to reflect the Total Compliance &
Accounting amount for the annual term.
EquiTrust may adjust the expenses in Schedule B once annually at the anniversary of the Effective
Date (each a “Fee Adjustment”) by sending a new schedule of the fee charges ten (10) days prior to
such anniversary. Each Fee Adjustment is limited to the lesser of: 1) seven (7%) percent or 2) The
Fee Adjustment Cap (as defined below).
1.4 Fee Adjustment Cap. The Fee Adjustment Cap shall be equal to the percentage change from Base
CPI-U (as defined below) to the Current CPI-U (as defined below). For Purposes of this section:
“CPI-U” is the Consumer Price Index, All Urban Consumers, U.S. City Average, All Items
prepared by the United States Department of Labor Bureau of Labor Statistics.
“Current CPI-U” is the most recently published monthly CPI-U at the time of the then current
Fee Adjustment.
“Base CPI-U” is the CPI-U published twelve (12) months prior to the month of the Current
CPI-U.
The method of calculating the Fee Adjustment Cap shall be as follows:
Base CPI-U is substracted from Current CPI-U, then divided by the Base CPI-U. The resulting
number is multipled by 100 and then rounded to the nearest tenth to equal the annual Fee
Adjustment Cap.
Using hypothetical numbers for an example of a Fee Adjustment in 2012:
Current CPI-U for August 2012 |
136.0 | |||
Base CPI-U for August 2011 |
129.9 | |||
Index Point Change |
6.1 | |||
Index Point Change divided by Base CPI-U Index (6.1/129.9) |
0.047 | |||
Result Multiplied by 100 |
4.7 | % |
1.5 COUNTRY Directives. EquiTrust shall, in all cases and at all times, to the extent there is
reasonable notice thereof, observe and obey the rules, regulations, instructions and directives of
COUNTRY as COUNTRY may, from time to time, promulgate for its operations, and shall not bind
COUNTRY in contravention of any such rules, regulations, instructions or directives. EquiTrust
shall not, however, upon reasonable prior notice to COUNTRY, be responsible for observing or
obeying any rule, regulation, instruction or directive of COUNTRY, if in so doing, EquiTrust, in
the opinion of its counsel, would be in violation of any statute, rule or regulation promulgated by
any governmental authority with jurisdiction thereover.
1.6 Referral of Communications. EquiTrust shall handle all correspondence of a routine nature and
other general functions necessary to provide compliance and accounting services pursuant to this
Agreement and shall maintain files relative thereto. EquiTrust shall immediately forward to
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COUNTRY copies of all attorney letters or other communications notifying EquiTrust of threatened or
actual litigation against EquiTrust or COUNTRY. COUNTRY shall forward to EquiTrust, immediately
upon receipt, all complaints and inquiries, and all attorney letters containing complaints received
by COUNTRY but appropriate for EquiTrust response. EquiTrust will dispatch responses within a
reasonable period or as required by appropriate law, whichever is sooner, and will copy COUNTRY on
such responses to all complaints. COUNTRY shall have an opportunity to review EquiTrust’s response
to all attorney letters and EquiTrust will not mail or otherwise transmit any such written
responses to such attorney letters without the prior approval of COUNTRY.
1.7 Investment Authority. Any Officer or appointed Accounting Personnel of EquiTrust as defined in
EquiTrust’s Authorities & Titles document at the transaction date is authorized to purchase or
sell, using COUNTRY authorized bank accounts, CILAC Variable Universal Life Account shares and
CILAC Variable Annuity Account shares in mutual funds with which COUNTRY has Participation
Agreements.
Part 2 — STANDARDS OF PERFORMANCE
2.1 Licensure. EquiTrust will be properly licensed with each state or other jurisdiction as
required in order to provide the services covered by this Agreement.
2.2 General Standard. All services to be provided by EquiTrust under this Agreement shall be
performed in a professional manner consistent with both industry standards and the practices of a
company rated “A” or better as determined by A.M. Best and in accordance with all applicable laws
and regulations. COUNTRY will monitor, oversee and audit the services of EquiTrust as provided
herein in accordance with COUNTRY’s duties to comply with Rule 38a-1 of the Investment Company Act.
EquiTrust agrees to provide documentation, data and access as necessary for COUNTRY to fulfill its
Rule 38a-1 obligations related to the services described in Schedule B. EquiTrust agrees to
maintain a compliance program for services provided hereunder and agrees to adopt and implement
written policies and procedures reasonably designed to prevent violations of federal securities law
and violations of state insurance laws.
2.3 Reservation of Management Authority. Services as are rendered by EquiTrust are subject to
the express limitation that they shall in no way constitute a relinquishment of the management
responsibility of COUNTRY, which shall not be relieved of any obligation or liability to which it
would otherwise be subject by law as a result of these services being rendered. The authority
granted and delegated in Schedule B can be removed by terminating this Agreement pursuant to
section 3.2 or amended, in the sole discretion of CCSI.
2.4 Representations. EquiTrust represents and warrants that it will perform its duties hereunder
in compliance with all applicable federal, state, and local laws and that any regulatory filings
made by EquiTrust on behalf of COUNTRY shall conform in all material respects to the requirements
of applicable laws and regulations. This representation shall not apply to any statement or
omission made in reliance upon and in conformity with information furnished in writing to EquiTrust
by COUNTRY. Further, this representation shall not apply to any non-compliance resulting from
COUNTRY’s action or inaction.
Part 3 — EFFECTIVE DATE, TERM; TERMINATION
3.1 Effective Date; Term. This Agreement shall become effective on the first day of the month
following the month in which COUNTRY notifies EquiTrust in writing that COUNTRY has
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ceased writing new Variable Product business. Upon the effective date of this Agreement, the Prior
Agreement shall be deemed to be terminated and of no force and effect except to the extent the
agreement contains provisions that are specifically noted as surviving the agreement. This new
Agreement shall, unless sooner terminated pursuant to §3.2 hereof, continue in full force for sixty
(60) months (the “Initial Term”); provided, however, after the Initial Term, this Agreement, and
all of its terms and provisions, as the same may have previously been amended by the parties, shall
be automatically renewed and reconducted for successive 12 month renewal terms. In no event,
however, shall this Agreement apply to any new Variable Product business written by COUNTRY after
the effective date of this Agreement.
3.2 Termination. After the conclusion of the Initial or any renewed or extended term, this
Agreement may be terminated:
| a. | by either party, upon one year prior written notice to the other party; | ||
| b. | by CCSI, upon written notice to EquiTrust in the event of the bankruptcy, insolvency, or material financial instability of EquiTrust Life Insurance Company or if EquiTrust Life Insurance Company’s Risk-Based Capital Ratio of Total Adjusted Capital to Company Action Level Risk Based Capital equals or falls below 300%; or | ||
| c. | by either party upon prior written notice to the other party specifying the other party’s breach or default in the performance of any material covenant or obligation of this Agreement and failure to cure or remedy such breach or non-performance within 30 days of the date on which notice of such breach or default is received, or such longer period as may be permitted by the party giving notice. |
Prior to the completion of the Initial Term of this Agreement, this Agreement may be terminated
only for the reasons stated in subparagraphs “b” or “c” above, or by the express written agreement
of the parties. Notwithstanding the foregoing, if the Second Administrative Services Agreement
entered into by the parties is terminated for any reason, this Agreement shall also be terminated
as of the termination date of the Second Administrative Services Agreement.
3.3 Rights and Obligations Upon Termination. Upon the termination of this Agreement, EquiTrust
shall supply COUNTRY with all information and data necessary to provide the compliance and
accounting services related to the business covered by this Agreement, including data
electronically stored.
Part 4 — INDEMNIFICATION
4.1 Mutual Indemnification. EquiTrust agrees to indemnify and hold COUNTRY harmless from any
liability, damages or losses which COUNTRY may incur as a result of any claims, actions or
judgments, negligent or intentional, in connection with EquiTrust’s provision of services to
COUNTRY; provided, however, EquiTrust shall not be responsible for decisions made by COUNTRY or for
actions as directed by COUNTRY in writing. COUNTRY similarly agrees to indemnify and hold EquiTrust
harmless for decisions made by COUNTRY or actions as directed by COUNTRY in writing. Each party
warrants to the other that its services and obligations as performed under this Agreement,
including, but not limited to the materials used therein, will not infringe upon the proprietary
interests or rights of third parties and each party will further indemnify, hold harmless and
defend the other party, its directors, officers, agents and employees, against any infringement
liability, claim or action as a result of the actions of the indemnifying party.
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4.2 Notice of Claim. If any claim is made by a party which would give rise to a right of
indemnification under §4.1, the party entitled to indemnification (the “Indemnified Party”)
promptly will give notice of the claim to the party required to provide indemnification (the
“Indemnifying Party”). The Indemnified Party will permit the Indemnifying Party to participate in
such defense at the Indemnifying Party’s expense. The Indemnifying Party will not, in the defense
of any such claim or litigation, consent to entry or any judgment or enter into any settlement
without the written consent of the Indemnified Party which will not be withheld unreasonably. The
Indemnified Party shall cooperate fully with the Indemnifying Party and make available to the
Indemnifying Party all pertinent information under its control relating thereto.
Part 5 — GENERAL PROVISIONS
5.1 Authorized Officers. CCSI represents that the CILAC officers identified in Schedule C,
attached hereto and incorporated herein by reference (hereinafter referred to as “Authorized
Officers”), are authorized within the scope of the officers’ authority as described in Schedule C,
to: (i) coordinate communications with EquiTrust with respect to this Agreement; (ii) provide to
EquiTrust written requests and instructions with respect to the services provided for herein; and
(iii) clarify with EquiTrust the specific scope and timing of records maintained, reports prepared
and other services performed by EquiTrust. CILAC’s Senior Vice President Life/Health Operations is
authorized to agree in writing with EquiTrust on changes in the compensation payable by COUNTRY to
EquiTrust to reflect changes in the scope and timing of the services. If EquiTrust receives any
letter or other writing from an Authorized Officer of COUNTRY authorizing an officer of COUNTRY to
sign documents on behalf of COUNTRY, then such officer shall be considered an Authorized Officer
for purposes of this Agreement and Schedule C shall be considered amended accordingly. CCSI may
amend Schedule C from time to time by giving notice to EquiTrust of the amendment.
5.2 Confidential Information. In performing the obligations arising under this Agreement, each
party may have access to and receive disclosure of certain confidential or proprietary information
of the other party (hereinafter “Confidential Information”). Each party shall take all reasonable
steps necessary to protect the confidential and proprietary nature of all Confidential Information
of the other party by affording thereto the same types of protection which the party in possession
of Confidential Information of the other party affords its own confidential and proprietary
information. Each party has adopted reasonable business practices to limit access and unauthorized
disclosure of Confidential Information. The parties will only disclose Confidential Information
with those having a sufficient reason to know such information and shall limit employee, vendor,
agent and other third party access in accordance with the terms of this Agreement. Except as
provided in this Agreement or as reasonably required to perform the services referenced herein,
neither party shall, directly or indirectly, disclose or make available to any third party, or use
for any purpose, any Confidential Information belonging to the other party. Notwithstanding the
foregoing, Confidential Information shall not include: (i) any information which is or becomes
generally available to the public or the insurance industry, other than as a result of a breach of
this Agreement by the party obtaining the Confidential Information; (ii) any information which is
lawfully obtained by the party from a third party, provided that the third party is not, to the
knowledge of the party obtaining the information, bound by a nondisclosure agreement with respect
thereto; or (iii) any information which subsequently develops from independent sources.
5.3 Anti-Money Laundering and Security Breach Notifications. The parties agree to cooperate in
order to ensure compliance with the USA PATRIOT Act and any and all other
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related laws and regulations related to money laundering and financing of terrorism, including
without limitation customer identification, and filing suspicious activity reports. Based upon
their respective duties under this Agreement, the parties will coordinate in the development,
implementation and monitoring of policies and procedures to comply with such requirements in the
sale of the variable products described in this Agreement.
5.4 Underlying Funds. In the performance of its duties under this Agreement and the Administration
Services Agreement, EquiTrust shall perform its services in such a manner that it will not cause
COUNTRY to breach any Participation Agreement that COUNTRY has entered into with any of the
underlying funds in COUNTRY’s variable products, so long as COUNTRY has notified EquiTrust in
writing of the requirements under the Participation Agreement(s) and EquiTrust is reasonably able
to comply with such requirements.
5.5 COUNTRY Property. All contract and policy forms, records and supplies furnished by COUNTRY to
EquiTrust, shall remain the property of COUNTRY and shall be turned over to COUNTRY promptly on
demand. All other contract and policy forms or other supplies, and all underwriting files or other
files pertaining to an annuitant’s or insured’s coverage, whether retained by COUNTRY or EquiTrust,
shall be copied upon request and said copies provided to the other party. All licenses and other
materials relating to government licensing or authorizations of COUNTRY with respect to this
Agreement shall be and remain the property of COUNTRY and shall be turned over to COUNTRY by
EquiTrust promptly upon demand.
5.6 Inspection of Books and Records. COUNTRY, or others on its behalf, shall have the right at any
reasonable time to inspect all books and documents relating to the services provided pursuant to
this Agreement. EquiTrust shall provide any and all information concerning the services provided
hereunder which may be required in order to administer this Agreement and to permit COUNTRY to
comply with governmental regulations, examinations, audits and inspections.
5.7 Corporate Authority. EquiTrust and CCSI expressly represent and warrant that each has the
authority to enter into this Agreement and that each is not or will not be, by virtue of entering
into this Agreement or otherwise, in breach of any other agreement with any other company,
association, firm, person or corporation.
5.8 Officer Authority. The officers signing this Agreement on behalf of CCSI and EquiTrust
represent and warrant that they are authorized to execute this document on behalf of such
corporations pursuant to their bylaws or a resolution of their boards of directors.
5.9 Independent Contractor. EquiTrust is an independent contractor. Nothing contained in this
Agreement shall be construed to create the relationship of employer and employee between COUNTRY
and EquiTrust, nor shall EquiTrust’s employees be considered employees of COUNTRY for any purposes.
5.10 Arbitration. In the event of any dispute arising between EquiTrust and COUNTRY with reference
to the rights or liabilities of either party under this Agreement, the dispute shall be referred to
three arbitrators (other than present or former officers or employees of EquiTrust, COUNTRY, any
affiliated company or any company with a monetary interest in the dispute) familiar with the
business of insurance. One of the arbitrators shall be chosen by EquiTrust, another by COUNTRY and
a third by the first two. The decision of the arbitrators shall be binding and final. The standards
to be used in the proceedings will be the Commercial Arbitration Rules of the American Arbitration
Association. Each party shall initially pay the costs and fees of the arbitrator it selects, and
the costs and fees of the third arbitrator shall be divided equally by the parties; provided,
however, that the prevailing party in any arbitration proceeding conducted pursuant to this Section
shall be entitled to recover from the other party
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any costs or expenses incurred by the prevailing party in connection with the arbitration,
including the fees of arbitrators and the reasonable fees of attorneys, actuaries, accountants and
other experts.
5.11 Assignment. Neither party may assign or delegate all or any part of its rights and duties
under this Agreement without the prior written consent by an Authorized Officer of the granting
party. Notwithstanding anything herein to the contrary, this Agreement and the rights, benefits
and obligations hereunder may be transferred as part of the complete acquisition of COUNTRY or
EquiTrust by a third party or an affiliate by virtue of a purchase of ownership interests, sale of
assets, merger, consolidation, or other business combination without the consent of the other
party.
5.12 Non-Waiver. The waiver of any breach of any term, covenant or condition of this Agreement
shall not be deemed a waiver of any subsequent breach of the same or any other term, covenant or
condition. No term, covenant or condition of this Agreement shall be deemed to have been waived
unless such waiver is in writing and signed by the party charged therewith.
5.13 Notices. Any notice required or permitted under this Agreement shall be deemed sufficiently
given and effective five (5) business days after deposit with the United States Postal Service,
postage-prepaid, registered or certified, return-receipt-requested, by facsimile or other
electronic transmission or upon receipt if delivered personally. Such notice shall be directed as
follows:
EquiTrust Investment Management
|
CC Services, Inc. | |
Services, Inc. |
||
Xxxxxxx X. Xxxxxx
|
Xxxxxxx X. Xxxxxx | |
President
|
Chief Operating Officer | |
0000 Xxxxxxxxxx Xxxxxx
|
0000 Xxxxxxx Xxx. | |
Xxxx Xxx Xxxxxx, Xxxx 00000
|
Xxxxxxxxxxx, Xxxxxxxx 00000 | |
| With a Copy to: | ||
| Xxxxx X. Xxxxxx | ||
| Secretary & General Counsel | ||
| 0000 X. Xxxxxxx Xxxxxx | ||
| Xxxxxxxxxxx, Xxxxxxxx 00000 |
5.14 Titles and Headings. The titles and headings appearing in this Agreement are included for
convenience only and shall not be taken into account in the interpretation, construction or
application of this Agreement.
5.15 Amendment. Any amendment to this Agreement shall be in writing and signed by authorized
representatives of both parties.
5.16 Entire Agreement. This Agreement, together with the several Schedules appended hereto and
incorporated herein, constitutes the entire agreement between the parties relative to the subject
matter hereof, superseding any and all prior understandings or agreements between the parties and
any subsidiary, parent or affiliated company and may not be amended except by written instrument
executed by the parties.
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In witness whereof, EquiTrust and CCSI have caused this Agreement to be subscribed and
executed, in duplicate original, by their undersigned officers, duly authorized hereunto, on the
dates hereinafter indicated.
EquiTrust Investment Management Services, Inc. |
CC Services, Inc. | |
By: /s/ Xxxxxxx X. Xxxxxx
|
By: /s/ Xxxxxxx X. Xxxxxx | |
Xxxxxxx X. Xxxxxx
|
Xxxxxxx X. Xxxxxx | |
President
|
Chief Operating Officer | |
Date: 11/04/10
|
Date: |
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Schedule A
SCHEDULE OF CONTRACTS
| Description | SEC File Number | |||
Flexible Premium Variable Life Insurance Policy |
333-106757 | |||
Flexible Premium Variable Life Insurance Policy |
811-21394 | |||
Flexible Premium Deferred Variable Annuity Contracts |
333-104424 | |||
Flexible Premium Deferred Variable Annuity Contracts |
811-21330 | |||
and any and all applicable riders, endorsements, applications and state specific variations of
these forms and policies.
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Schedule B
| Annual | ||||||||||||||||
| Compliance | Hours | Units | Rate | Annual | ||||||||||||
Form N-6 VUL Prospectus preparation Rule 485-b filing (1) |
150 | 2 | 125.53 | 18,829 | ||||||||||||
Form N-4 VA Prospectus preparation Rule 485-b filing (1) |
150 | 2 | 125.53 | 18,829 | ||||||||||||
VSO tables prepared |
15 | 2 | 167.36 | 2,510 | ||||||||||||
Preparation Semi-Annual Reports |
8 | 2 | 125.53 | 1,004 | ||||||||||||
Preparation Annual Reports |
8 | 2 | 125.53 | 1,004 | ||||||||||||
VA Separate
Account Financial Statements & SAI Financial Statements |
50 | 2 | 83.69 | 4,185 | ||||||||||||
VUL Separate
Account Financial Statements & SAI Financial Statements |
50 | 2 | 83.69 | 4,185 | ||||||||||||
Form N-SAR VUL preparation (2) |
20 | 2 | 125.53 | 2,511 | ||||||||||||
Form N-SAR VA preparation (2) |
20 | 2 | 125.53 | 2,511 | ||||||||||||
Rule 24f-2 Notice VUL |
20 | 2 | 125.53 | 2,511 | ||||||||||||
Rule 24f-2 Notice VA |
20 | 2 | 125.53 | 2,511 | ||||||||||||
Rule 22c-2 requests |
Varies | 1 | 1,500 | 1,500 | ||||||||||||
Proxy & Proxy Solicitation — to be negotiated
SEC Examination
Will be billed on a per hour basis depending on the area and level of expertise needed to provide the
required information. Generally the areas involved in a SEC examination are Compliance, Operations,
Accounting and Information Technology.
| (1) | A Rule 485-b filing is used when there are no material changes and no SEC review is required. Rule 485-a filings are done when there are material changes and an SEC review is required. The additional hours required in a 485-a filing will be billed on a per hour basis as incurred. | |
| (2) | Includes accounting, review, Edgarizing & filing |
| Accounting | ||||||||||||||||
| Mutual Fund Accounting Area: | Annual | |||||||||||||||
| Daily Accounting Functions: | Hours | Units | Rate | Annual | ||||||||||||
Daily Wires |
510 | 112 | 50.23 | 25,617 | ||||||||||||
Review and sign wires |
55 | 112 | 125.53 | 6,904 | ||||||||||||
Check UITs to Supersheets |
250 | 112 | 50.23 | 12,557 | ||||||||||||
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| Accounting | ||||||||||||||||
| Mutual Fund Accounting Area: | Annual | |||||||||||||||
| Daily Accounting Functions: | Hours | Units | Rate | Annual | ||||||||||||
MasterCalc — Start new day process |
63 | 1 | 50.23 | 3,164 | ||||||||||||
Filing |
125 | 112 | 50.23 | 6,279 | ||||||||||||
Nightly Upload A715 |
375 | 1 | 50.23 | 18,836 | ||||||||||||
Supervisory and Review |
||||||||||||||||
Staff review, check audit schedules
maintenance of Mastercalc, etc. |
266 | 112 | 125.53 | 33,390 | ||||||||||||
Weekly Functions: |
||||||||||||||||
Check confirmations & adj if needed |
125 | 112 | 50.23 | 6,279 | ||||||||||||
File confirmations |
50 | 112 | 50.23 | 2,511 | ||||||||||||
Quarterly Functions: |
||||||||||||||||
Review Units outstanding &
cost basis diary |
25 | 112 | 83.69 | 2,092 | ||||||||||||
| Annual | ||||||||||||||||
| Performance Calculations | Hours | Units | Rate | Annual | ||||||||||||
Prepare each VA |
70 | 112 | 83.69 | 5,858 | ||||||||||||
Prepare each VUL |
70 | 112 | 83.69 | 5,858 | ||||||||||||
Review each VA |
60 | 112 | 83.69 | 5,021 | ||||||||||||
Review each VUL |
60 | 112 | 83.69 | 5,021 | ||||||||||||
Separate Account Annual Report |
||||||||||||||||
Preparation of Financial Statements |
30 | 1 | 83.69 | 2,511 | ||||||||||||
Review of Financial Statements |
20 | 1 | 125.53 | 2,511 | ||||||||||||
Investment Accounting Area: |
||||||||||||||||
Subaccount Reconciliation |
||||||||||||||||
Reconciliation |
466 | 112 | 50.23 | 23,403 | ||||||||||||
Staff Review |
59 | 112 | 125.53 | 7,451 | ||||||||||||
Corporate Accounting Area: |
||||||||||||||||
Prepare & process JE’s (Life side) |
248 | 112 | 50.23 | 12,433 | ||||||||||||
Prepare & process JE’s (Sep Acct side) |
248 | 112 | 50.23 | 12,433 | ||||||||||||
Punching all JE’s |
248 | 112 | 50.23 | 12,433 | ||||||||||||
Monthly balancing-Super sheet adj & recon |
745 | 112 | 50.23 | 37,411 | ||||||||||||
Financial Statements & JE’s |
223 | 112 | 50.23 | 11,195 | ||||||||||||
Monthly Balancing & Reporting |
715 | 112 | 58.56 | 41,845 | ||||||||||||
Annual Statement Green Book |
74 | 112 | 58.56 | 4,329 | ||||||||||||
Review & correspondence |
119 | 112 | 125.53 | 14,902 | ||||||||||||
Freedom licensing |
970 | |||||||||||||||
Actuarial Review and input |
5 | 1 | 167.36 | 823 | ||||||||||||
Total Compliance & Accounting |
$ | 386,125 | ||||||||||||||
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Schedule C
CILAC AUTHORIZED OFFICERS
CEO, COO, CFO, Senior Vice President, Life/Health Operations
Vice President and Chief Life/Health Actuary, Appointed Actuary & Illustration Actuary
Vice President, Life/Health Administration
Controller
Vice President and Chief Life/Health Actuary, Appointed Actuary & Illustration Actuary
Vice President, Life/Health Administration
Controller
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