The New York State Insurance Department has issued reserving guidelines for guaranteed minimum living benefits offered through variable annuities. The Department sent out a letter at the end of October regarding the application of Regulation 128 to those guarantees.

The state only intends for variable annuity carriers to conform with Regulation 128 as a stop gap measure until the National Association of Insurance Commissioners "adopts a permanent solution for reserves that considers the risks in such product designs."

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