March 15, 2009
Volume I, Issue 4
Inside this issue:
Longevity Markets 2
Commentary
Trade Data 3
Insurable Interest 4
Yield to LE 5
Longevity Market 8 Trade Report
Spreads
Credit Watch 9
Editor & Publisher
Brian C. Dorr
Contributing Editors
Anne K. Zand
Keith M. Feldman
Carline B. Gele
Managing Editor and
Writer
David C. Dorr
LIFE-EXCHANGE trade
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on the fifteenth of each
month. Subscription rate
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$2,750 for the whole year.
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construed to be recom-
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mentioned or advertised.
No fees are accepted for
publishing any editorial
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EXCHANGE, its subsidi-
aries, and its employees
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purchase, own, or sell
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ment products of the
companies discussed or
advertised in this publica-
tion.
Copyright @2009 Life-Exchange, Inc. All rights reserved.
Longevity Markets Commentary
Investment in any asset class re-
quires the investor to understand as best as
possible both the reward and the risk of a
potential investment. Anytime you have an
emerging market, which is how we would
classify life settlements, you have to be
aware of the risks that are known and accept
that the probability of unknown risks yet to
be discovered is high. One of the goal’s of
this publication is to help highlight risk as it
relates to life settlements and hopefully to
steer market participants around those risks
so they may make more informed invest-
ment decisions. In this month’s Trade Re-
port we focus on some of the legal risks that
relate to our market such as determining
insurable interest and vetting new programs
that involve the beneficial interests of trusts
that own life insurance policies. We will
discuss momentarily some of the confusion
that surrounds beneficial interest trades and
in addition we have a special section with an
update on relevant court decisions that in-
volve insurable interest that has been written
by Dan Passage and Francisco Flores, both
of O’Melveny & Myers LLP. Insurable in-
terest is of course the cornerstone upon
which many life settlement investment deci-
sions are determined so it is timely to cover
this topic as we enter a year where more
premium finance and beneficial interest pro-
grams than ever before will require vetting
as they enter the market for sale in 2009.
For those not familiar with benefi-
cial interest trades a quick primer is in order.
A plain vanilla life settlement transaction
involves the sale of a policy from an individ-
ual, a corporation, or a trust. As most par-
ticipants are aware the state of residence,
25 23
20
15 14
15
10 8
5
0
Feb.       Feb.       Feb.      Feb.     
2‐6 9‐13 16‐20 23‐27
Total Policies Closed and Funded
domicile, or situs will usually but not always
determine the regulation that will apply to the
transaction. If the state is a regulated state
than most often a licensed life settlement
provider will have to be a party to the transac-
tion. Additionally as the policy is sold from
the current owner to the provider a change of
ownership and beneficiary form must be filed
with the carrier. This type of transaction re-
quires licensing, time, and involves the car-
rier’s participation or perhaps more accurately
the carriers cooperation.
A beneficial interest trade is struc-
turally much more elegant. In a beneficial
interest transaction the policy is owned by a
trust usually with a situs in a non regulated
state like Delaware. Delaware in particular
also has favorable trust laws as it relates to
insurable interest.
Continued on Next Page

Longevity Markets Commentary Cont.
Rather than transfer the
ownership of the policy from the
trust to the new owner the beneficial
interests in the trust are sold instead.
Since the trust rather than the policy
is being effectively sold there is no
need to file change of ownership
and beneficiary forms with the car-
rier. This speeds up the transaction
and keeps it more private. So struc-
turally this makes a lot of sense but
there are of course some drawbacks.
One such drawback was the way in
which this technique was pushed to
the limit.
What happened was a
clever investment bank and several
hedge funds started looking at the
legal risks of their life settlement
investments, in particular as it re-
lated to insurable interest risk, and
the contestability and suicide period
which usually exists for the first two
years after a policy is issued. What
they discovered was a rather unique
misconception held by the majority
of the life settlement market. First
they discovered that if a carrier felt
there was an issue with insurable
interest they could challenge the
original issuance of the policy and
potentially rescind it. Many market
participants have mistakenly be-
lieved that past the 24 month mark
you’re completely safe from a carrier
rescission. Turns out this is not the
case. The second thing they looked
at was the C&S period. If someone
claims they are not a smoker and it
turns out they are and the carrier
catches it within the C&S period the
carrier may rescind. Everyone is
aware of this. And last but not least
if the insured commits suicide
within the first two years of policy
issuance the death claim will likely
be denied. Everyone knows this too.
Copyright @2009 Life-Exchange, Inc │ 2001 Biscayne Boulevard Suite 2102, Miami, Florida 33137 │ (866) 907-9766
Well after much thought (or
maybe not enough thought) the invest-
ment banks and hedge funds felt that
all these factors could be properly
mitigated and if so it would allow them
to buy policies that had been issued
less than 24 months and thus achieve
an IRR 300-500bps higher than the
regular market. Here is how their the-
ory worked. First statistically high net
worth seniors do not often commit
suicide so the risk of suicide within 24
months of issuance was extremely
slim. Second medical fraud was rather
easy to detect because although an
insured may lie on a carrier application
to appear healthier than possible when
it comes to a life settlement they want
to appear as unhealthy as possible so
discrepancies are usually picked up
quickly. Last but not least, if insurable
interest is essentially a risk pre and
post the 24 month mark then you
might as well be compensated with
higher IRR’s buy purchasing policies
pre 24 months. The problem in this
rationale was not that it was necessarily
incorrect but that it took these as-
sumptions to extremes and overlooked
some other important transactional
elements. To visualize this error in
thinking take a look at the chart on
this page. The thought basically was
hey if we are
comfortable
buying at 18
months why not
12 months?
And then ulti-
mately why not
the day after it
was put in force?
J u s t
like anything else
some funds ac-
tually crossed
the limit and
Page 2
outright solicited insured to put poli-
cies in force for the sole purpose of a
sale. This is what kicked off the
STOLI controversy. Unfortunately
other errors were made such as re-
viewing whether or not the insured
could properly justify the amount of
face value they were having issued on
them. This one factor alone has con-
tributed to an entire New York City
zip code being banned by several life
settlement buyers because of financial
misrepresentations by the insured and
their agents. All that said there are
numerous portfolios of beneficial
interests that are available in the mar-
ket and no two portfolios are exactly
alike. The portfolios present oppor-
tunities and land mines. Just like in
the premium finance market where
we have seen programs range from
excellent legal structures to question-
able legal structures the same exists
with beneficial interest portfolios.
The devil is in the details and funds
enticed by IRR’s and looking to
gather large blocks of policies should
be encouraged to retain experienced
legal counsel to do proper due dili-
gence on these portfolios to mitigate
their risk and maximize their reward.
 Page 3

Number of Avg Purchase

Cases Gender Avg Age of Avg Cash Suren- Price as % of
State Closed Male Female Insured Total Face Value Avg Face Value der Value Face
Alabama 2 1 1 75 $2,000,000 $1,000,000 $45,625 13.2%
Alaska 0
Arizona 0
Arkansas 1 1 0 77 $800,000 $800,000 $0 15.4%
California 5 3 2 76 $10,500,000 $2,100,000 $38,704 11.8%
Colorado 0
Connecticut 2 1 1 75 $2,500,000 $1,250,000 $64,250 15.1%
Delaware
Dist. of Columbia 2 1 1 73 $16,000,000 $8,000,000 $0 4.9%
Florida 8 4 4 74 $18,250,000 $2,281,250 $103,545 13.3%
Georgia 2 2 0 71 $16,000,000 $8,000,000 $32,000 8.1%
Hawaii 0
Idaho
Trade Data February 2009

0
Illinois 3 1 2 79 $3,000,000 $1,000,000 $46,242 18.1%
Indiana 0
Iowa 2 1 1 80 $1,500,000 $750,000 $9,872 23.5%
Kansas 1 1 0 77 $1,000,000 $1,000,000 $0 15.0%
Kentucky 0
Louisiana 0
Maine 0
Maryland 4 4 0 77 $14,500,000 $3,625,000 $218,082 15.7%
Massachusetts 2 1 1 75 $1,150,000 $575,000 $21,925 14.9%
Michigan 2 2 0 75 $2,500,000 $1,250,000 $23,546 13.1%
Minnesota 1 1 0 76 $5,000,000 $5,000,000 $72,350 11.0%
Mississippi 0
Missouri 1 0 1 72 $750,000 $750,000 $0 12.0%
Montana 0
Nebraska 0
Nevada 0
New Hampshire 0
New Jersey 4 3 1 75 $6,000,000 $1,500,000 $18,746 17.5%
New Mexico 0
New York 4 2 2 79 $9,000,000 $2,250,000 $81,909 20.7%
North Carolina 0
North Dakota 0
Ohio 0
Oklahoma 0
Oregon 1 1 0 82 $2,000,000 $2,000,000 $0 28.0%
Pennsylvania 2 2 0 77 $18,000,000 $9,000,000 $316,632 7.5%
Peuerto Rico 0
Rhode Island 0
South Carolina 1 1 0 78 $800,000 $800,000 $2,336 10.0%
South Dakota 3 2 1 80 $10,000,000 $3,333,333 $51,640 14.2%
Tennessee 2 1 1 74 $1,800,000 $900,000 $0 10.0%
Texas 2 2 0 75 $200,000 $1,000,000 $124,971 21.7%
Utah 0
Vermont 0
Virginia 0
Washington 3 2 1 78 $4,000,000 $1,333,333 $18,021 17.4%
West Virginia 0
Wisconsin 0
Wyoming 0
Totals 60 40 20 76.25 $147,250,000 $59,497,916 $1,290,396 14.7%
Note- All gray highlighted rows are non-regulated states. The information contained herein is made available to the public by Life-Exchange,
Inc.

Insurable Interest Update
Daniel F. Passage, Partner, O’Melveny & Myers LLP
Francisco Flores, Counsel, O’Melveny & Myers LLP
A number of recent judicial
decisions have been rendered in
cases involving carrier efforts to
rescind policies. We focus on four
of these decisions because of what
they tell us about the development
of the insurable interest doctrine,
material misrepresentations suffi-
cient to rescind or void a policy and
issues ahead for insurance compa-
nies that are over-zealous in their
efforts to rescind policies.
First Penn-Pacific Life v. Evans
In an unpublished Febru-
ary 26 decision, the U.S. Court of
Appeals for the Fourth Circuit af-
firmed a lower court’s grant of sum-
mary judgment in favor of a policy
owner (and against rescission), rul-
ing that the “[insured/original
owner - Stanley Moore - who had
settled the policy] had an insurable
interest under Arizona law despite
his plan ‘to sell all or most of his life
insurance policies at the time he
applied for them.’” The court
treated as undisputed fact that Mr.
Moore set out to defraud the viatical
settlement industry by buying multi-
ple policies then reselling them while
claiming to be terminally ill, and that
Mr. Moore made material misrepre-
sentations to the insurer by not dis-
closing his existing and pending
other policies when he applied for
the particular policy in question.
Importantly, the insured did not
meet with settlement brokers until
after (albeit shortly after) the issu-
ance of the life insurance policy in
question. The court ruled that
“Despite Moore’s intent to transfer
the policy [at the time he applied for
Copyright @2009 Life-Exchange, Inc │ 2001 Biscayne Boulevard Suite 2102, Miami, Florida 33137 │ (866) 907-9766
it], we agree with the district court that
Moore had an insurable interest when
he obtained it, preventing the policy
from being void ab initio.” The court
stated that Moore’s unilateral intent to
sell did not defeat his insurable interest
“where ‘[t]here is no evidence that
anyone other than Moore was a par-
ticipant in the scheme at the time
Moore obtained the First Penn policy”
and characterized this principle as the
rule being followed by a majority of
courts. This case represents an impor-
tant affirmation of the principle ex-
pressed in the Sun Life v. Paulson case
by a federal district court in Minnesota
and in the Life Products v. Angel by a
federal district court in New York. We
expect that this principle really is and
will be the majority rule as cases are
decided nationwide.
First Penn-Pacific Life Ins. Co. v. William
R. Evans, Chtd., Case No. 07-2020 (4th
Cir. Feb. 26, 2009), on appeal from
Case No. 1:05-cv-00444-AMD, 2007
U.S. Dist. LEXIS 45112 (D. Md. June
21, 2007).
Lincoln National v. Calhoun
On January 27, the Federal
District Court for the District of New
Jersey denied the request of policy
owners for a motion to dismiss against
rescission on insurable interest and
material misrepresentation grounds.
The policy had been premium fi-
nanced. The insurer is seeking to re-
scind the policy, alleging that (i) the
insured had made material misrepre-
sentations (by allegedly falsely answer-
ing “no” to the question whether he
had engaged in conversations with any
Page 4
life settlement, viatical or secondary
market provider” and (ii) there was
lack of insurable interest in the policy.
The policy owners had requested
summary judgment on the grounds
that (i) the insurer had only alleged
“intent to sell” (had not alleged that
an actual arrangement to sell was in
place) and that as a matter of law the
mere unilateral intent to sell does not
invalidate an otherwise valid insurable
interest and (ii) it cannot be a material
misrepresentation to conceal one’s
intent to exercise lawful rights (e.g. to
eventually sell a policy, since life set-
tlements are a lawful activity). The
court denied this motion for sum-
mary judgment. Stating that this was
an issue of first impression for the
courts of the Third Circuit and the
State of New Jersey, and after consid-
ering the Paulson and Angel deci-
sions, this court ruled that it was pre-
mature to dismiss the complaint on
summary judgment because the in-
surer in fact had alleged that at the
time the policy was issued the insured
both intended to sell and had “either
contracted or arranged to sell the
policy to a third party investor.” The
court also noted that important policy
questions were at stake in the issue
whether unilateral intent is sufficient
or whether mutual intent (i.e. agree-
ment or arrangement) is necessary for
rescission on insurable interest
grounds to be appropriate.
Continued on Page 6
 Page 5

Yield to Life Expectancy

When we see policies traded in the secondary market we often see new buyers forget to take into account the
premium (in yield not payments to keep policies in force) that should be received for longer investment horizons i.e.
longer life expectancies. There are 4 reasons we think this should be taken into consideration. 1. The most obvious is
naturally the time value of money. 2. The historical trend of mortality improvements as evidenced by recent revisions
to the industry’s most widely used underwriting tables. 3. The credit risk that exists over longer periods vs. shorter
periods. 4. The currency risk associated with the long term potential decline of US dollar denominated contracts/
assets.
You can see by looking at the chart below that the yield curve flattens out in the longer life expectancy ranges.
Buyers active in the life settlement space also know that competition is limited in policies where insured’s have LE’s
beyond 14yrs so this would be an additional factor suggesting that the yield curve should steepen significantly from
where it currently is today.

Comparative Yields to Life-Expectancy Chart

February 2009 Comparitive Yields‐to‐life‐expectancy
17

16

15

14
AVS
Yield/IRR

13
Fasano
12 21st Services
ISC
11
EMSI
10

8
24
36
48
60
72
84
96
108
120
132
144
156
168
180
192
204
216
228
240

As expected the EMSI trend line has moved down to be more inline with the rest of the life expectancy com-
panies. IRR’s on each of the other LE companies have not changed this month. We believe this is because the life set-
tlement industry is beginning to rebound from the credit crisis and LE table changes that occurred at the end of 2008.
It seems as if the market has corrected to a degree and investors are comfortable with the new guidelines. In the future
we expect the average IRR to decrease across the board however We don’t believe that will happen until more capital is
allocated to the purchasing side and the life settlement industry gradually moves back to a sellers market.

Copyright @2009 Life-Exchange, Inc │ 2001 Biscayne Boulevard Suite 2102, Miami, Florida 33137 │ (866) 907-9766

Insurable Interest Update
Daniel F. Passage, Partner, O’Melveny & Myers LLP
Francisco Flores, Counsel, O’Melveny & Myers LLP
Continued from Page 4
As mentioned on the last
page, our view is that the appropri-
ate test is “mutual intent”, and we
view this court as having in fact
ruled as it did on the summary judg-
ment motion primarily because the
insurer alleged that the discovery
process could or would result in the
production of evidence that a con-
tract or arrangement was in fact in
place. On what appears to us to be
faulty reasoning, the court denied
the motion to dismiss the insurer’s
rescission claim based on material
misrepresentation. The court rea-
soned that since insurers can deny
coverage based on misrepresenta-
tions about lawful conduct such as
skydiving, then it may be reasonable
for an insurance company to deny
coverage based on intent at some
future time to exercise the right to
sell the policy (the court incorrectly
focused on the legality of the activi-
ties at issue, failing to recognize the
difference between legal activities
that increase the risk of mortality
versus legal activities that do not).
The court also asserted that the pol-
icy owner’s motion to dismiss had
misread the question at issue. The
court stated that the question was
whether conversations with provid-
ers had occurred and not about in-
tent to settle. It appears to us that
the court somehow failed to under-
stand what insurers do - that discus-
sions with providers will rarely be
about anything other than possible
settlement, and thus are interesting
precisely because such discussions
can point to the issue of present
intent to settle. We doubt other
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Page 6
courts will make much of this court’s insured’s actual financial condition.
odd disposition of that motion to dis- In addition, the court determined that
miss. language in the policy itself did not
limit the insurer’s statutory right to
rescind the policy (the language did
Lincoln Nat’l Life Ins. Co. v. Calhoun,
not require the insurer to demon-
Case No. 3:08-cv-02917-JAP-TJB,
strate it had actually relied on the
2009 U.S. Dist. LEXIS 5948 (D.N.J.
misrepresented facts, as opposed to
Jan 27, 2009). The authors note that
the facts being objectively relevant
O’Melveny & Myers, LLP represents a
whether or not relied upon). Lastly,
party in this action.
the court also concluded that because
the misrepresentations were objec-
American General v. Schoenthal tively material, there could not be a
Family, LLC triable issue of fact as to whether the
insurer had acted in bad faith in con-
On January 30, the Court of testing the claim - material misrepre-
Appeals for the Eleventh Circuit af- sentations are an inherently reason-
firmed a lower court grant of summary able basis for contest. In our view,
judgment in favor of an insurer seek- although on its face limited to inter-
ing rescission on grounds that the in- pretation of Georgia law and a review
sured made material misrepresenta- for abuse of discretion by the lower
tions in his application for insurance court, this case is interesting for its
regarding his net worth and annual precedential value in pending rescis-
income. This judgment affirmed that, sion cases where this specific type of
as a matter of Georgia law, misrepre- misrepresentation is alleged.
sentations about net worth and income
can be material to insurers. Under Am. Gen. Life Ins. Co. v. Schoenthal Family,
Georgia law, the misrepresentation LLC, No. 08-10749 (11th Cir. Jan. 30,
must be “[m]aterial either to the accep- 2009), on appeal from Case No. 06-00695
-CV-1-WSD (N.D. Ga. June 15, 2007).
tance of the risk or to the hazard as-
sumed by the insurer” and the test for
materiality is the “objective standard of Continued on Next Page...
conduct of a prudent insurer, not a
subjective standard about the actual
conduct of American General.” This
court noted that the district court had
considered two kinds of evidence in
establishing that misrepresentations
about net worth and income were ob-
jectively material, Swiss Re’s under-
writing guidelines, which take net
worth into account, and the testimony
of an expert witness to the effect that
no reasonable insurance company
would issue this policy in light of the

Insurable Interest Update
Daniel F. Passage, Partner, O’Melveny & Myers LLP
Francisco Flores, Counsel, O’Melveny & Myers LLP
Upcoming Events
03.22.2009-03.24.2009
ACLI Financial and Investment
Roundtable in Amelia Island FL
SEE EVENT
03.30.2009-04.01.2009
ACLI Life Insurance Conference
in Orlando FL
SEE EVENT
05.06.2009-05.08.2009
LISA 15th Annual Spring Confer-
ence in Time Square NY
SEE EVENT
05.20.2009-05.21.2009
The Dealflow Media Life Settle-
ment Conference 2009 at Central
Hall Westminster, London
SEE EVENT
10.26.2009
Fasano 6th Annual Life Settle-
ment Conference in Washington
DC
SEE EVENT
Continued from Page 6
Phoenix Life v. Levinson Trust
On February 19, a Supreme Court
of the The State of New York de-
nied Phoenix’s motion to dismiss a
counterclaim raised by a policy
owner that Phoenix’s efforts to re-
scind a policy (following death of
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Page 7
the insured during the contestability family and household use (not to
period) on insurable interest grounds protect sophisticated parties with
constituted a “deceptive business prac- equal bargaining power). The ruling
tice” under New York General Busi- suggests to us that where an insurer
ness Law Section 349. The court rescinds on insurable interest grounds
noted that most disputes between pol- just because the original policy owner
icy holders and insurance companies is a trust and/or has a premium fi-
are mere private contractual disputes nance product in place, but has not in
over the right to insurance proceeds, fact settled the policy, a Section 349
as opposed to being “consumer ori- claim may be successful. On the
ented” (i.e. relating to broader prac- other hand, the ruling also suggests to
tices of an insurer directed toward us that secondary market players
consumers) and so not covered by should not assume that they will win
Section 349. a Section 349 claim on the merits,
since they are not the intended bene-
ficiaries of the protections of Section
However, an insurance car-
349.
rier’s failure to pay under a standard-
issue policy can constitute a violation
of Section 349, because complaints Phoenix Life Ins. Co. v. Irwin Levinson Ins.
Trust II, Index No. 600985/2008 (N.Y.
about inappropriate denials of cover- Sup. Ct. Feb. 19, 2009).
age under standard-issue policies can
be complaints about issues that have a
broader impact on consumers at large.
If the insurer makes a practice of inor-
dinately delaying and then denying a
claim without reference to the viability
of that claim, or the denial is not an
isolated incident but rather a practice
that affects similarly situated insureds,
then a Section 349 claim can be stated.
In the case at hand, the policy owner
submitted some evidence that Phoenix
has sought rescission of a number of
policies on insurable interest grounds
where standard-issue life policies had
been transferred in life settlements. In
addition, the court concluded that
policy owner had also sufficiently al-
leged that Phoenix’ pattern of attempt-
ing to rescind settled policies com-
prised a deceptive practice. The court
cautioned that Section 349 is there for
the protection of persons who pur-
chase goods and services for personal,
 Page 8

Longevity Market Spreads

This chart shows the relationship between 10yr life settlements* and a comparative index of 10yr investment grade
corporate bonds. There is a natural correlation between the two. The reason is that all life insurance contracts have an
inherent credit risk in them similar to corporate bonds. A life insurance contract is an obligation for a company to pay
a claim in the event of a death and should that carrier become insolvent then there is a risk that they may not be able to
meet that claim. See our Credit Watch section for more on this.

10yr Investment Grade Corporate Bond Yields

20

18

16

14

12

10

0
Feb‐08 Mar‐08 Apr‐08 May‐08 Jun‐08 Jul‐08 Aug‐08 Sep‐08 Oct‐08 Nov‐08 Dec‐08 Jan‐09 Feb‐09

10yr LS 10yr IG Corp 10yr IG Corp/10yr LS

*We use an equally weighted average of 10yr life expectancies with 150% mortality impairment at the 50th percentile
from AVS, Fasano, EMSI, 21st Services, and ISC.

Copyright @2009 Life-Exchange, Inc │ 2001 Biscayne Boulevard Suite 2102, Miami, Florida 33137 │ (866) 907-9766
 Page 9

Credit Watch
Credit Watch is a list of Life Insurance Carrier’s that have been placed on “Credit Watch” by the underlining
Rating Agencies. Credit Watch is when an Insurance Carrier has been downgraded or is being watched for possible
downgrade. The Ratings listed below are the latest data from the two rating agencies. All ratings listed can found on the
public Web site of the underlining rating agencies. This information is the most accurate at the time of publication.

IC R - BEST IC R - S&P State of

Insurance C arrie r Long Te rm Long Te rm FSR - BEST FSR - S&P Domicile
AIG Life Insurance Co a/Negative A+/Negative/-- A/Negative A+/Negative/-- DE
Beneficial Life Insurance Co a/Negative A/Negative/A-1 A/Negative A/Negative/-- UT
CIGNA Life Insurance Co of NY a/Negative A/Negative NY
Cincinnati Life Insurance Co a+/Stable A+/Negative/-- A/Stable A+/Negative/-- OH
Connecticut General Life Ins Co a/Negative A/Negative/-- A/Negative A/Negative/-- CT
Constitution Life Insurance Co bbb-/Stable B+/Stable TX
Farm Bureau Life Insurance Co bbb+/Negative A-/Negative/-- B++/Negative A-/Negative/-- IA
FBL Financial Group Inc bb/Negative BBB-/Negative/-- NR/--/-- IA
First Central National Life Ins Co of NY aa-/Negative A+/Negative NY
First SunAmerica Life Insurance Co a/Negative A+/Negative/-- A/Negative A+/Negative/-- NY
General Fidelity Life Insurance Co a-/Negative A-/Negative SC
Genworth Life and Annuity Ins Co a/Negative AA-/Stable/A-1 A/Negative AA-/Stable/A-1 VA
Genworth Life Insurance Co a/Negative AA-/Stable/A-1 A/Negative AA-/Stable/-- DE
Genworth Life Insurance Co of NY a/Negative A/Stable/-- A/Negative A/Stable/-- NY
Hartford Life and Accident Ins Co a+/Negative A/Negative/-- A/Negative A/Negative/-- CT
Hartford Life and Annuity Ins Co a+/Negative A/Negative/-- A/Negative A/Negative/-- CT
Hartford Life Inc bbb+/Negative BBB/Negative/A-2 CT
Hartford Life Insurance Company a+/Negative A/Negative/A-1 A/Negative A/Negative/A-1 CT
Humana Ins of Puerto Rico Inc bbb-/Negative B+/Negative PR
Liberty Union Life Assurance Co bb/Negative B/Negative MI
Reassure America Life Insurance Co a+/Stable A/Stable IN
Security Benefit Life Insurance Co bb/Negative BB/Negative/B B/Negative BB/Negative/B KS
SunAmerica Life Insurance Co a/Negative A+/Negative/A-1 A/Negative A+/Negative/A-1 AZ
Swiss Re Life & Health America Inc a+/Satble A+/Stable/-- A/Stable A+/Stable/-- CT
T ransamerica Financial Life Ins Co aa/Negative AA/Watch Neg/A-1+A+/Stable AA/Watch Neg/A-1+ NY
T ransamerica Life Insurance Co aa/Negative AA/Watch Neg/A-1+A+/Stable AA/Watch Neg/A-1+ IA
Western Reserve Life Assurance Co of OH aa/Negative AA/Watch Neg/-- A+/Stable AA/Watch Neg/-- OH
* Denotes Ratings Under Review FSR = Financial Strength Rating ICR = Issuer Credit Ratings
BEST = AM BEST S&P = Standard and Poors

The Rating’s listed above are the latest data from the two rating agencies. All ratings listed can found on public Web site of the underlining rating agencies.
This information is the most accurate at the time of publication.

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