VA/VUL Rule 498A becomes effective July 1, 2020
By Toppan Merrill
1 min read | Industry Insights Insights Home


Recently, the Securities and Exchange Commission adopted Rule 498A, including form amendments, which intend to modernize disclosure requirements and allow investors to make more informed decisions about variable annuity and variable life insurance contracts.

According to the Commission, the changes leverage both technology and a layered disclosure approach to improve the ability of investors to understand and evaluate variable contracts.

"With today's technology and the benefits of layered disclosure, investors should not have to work through hundreds of pages of disclosure to understand these products’ risks, fees, and features in order to make informed investment decisions," said SEC Chairman Jay Clayton.1

Part of this new rule, which the SEC Chairman is referring to becomes effective July 1, 2020, and permits options to help institutions meet their current prospectus delivery requirements, they include:

  • Variable contracts can provide the summary prospectus to satisfy the prospectus delivery obligation.
  • Variable contracts can make the prospectuses and related documents for underlying mutual funds available online to satisfy the prospectus delivery obligation.

What Does this mean for Financial Institutions?

Variable contract prospectuses have become far too lengthy and difficult for investors to navigate. Some financial institutions offer 100 or more such funds for their variable contracts. As a result, today’s variable contract prospectus packages have become so voluminous that they are often humorously referred to as “phonebooks.”

The overriding principle is that financial institutions and their IT organizations are continually preparing for change — and where information in digital formats come first. For this to happen, legacy IT systems are consistently being tasked with add-ons and fixes. It may appear logical to continue to support core mainframe systems, given the potential disruption and perceived cost of transition to something different. But if the existing platform could be replicated at half the cost, would the logic still apply? What about the cost of training or hiring additional personnel to accommodate ongoing regulation requirement? 

In today’s ever-evolving environment of securities regulation, more time and attention is required than ever before, as such, companies these days are actively looking for support to complement not only IT resources but also reduce the burden on work management and human capital resources.

Toppan Merrill can help with Web Posting & Summary Prospectus Delivery

Toppan Merrill’s Publishing Center, supporting website document posting since 2009, can present your entire document library in a single website location allowing you to easily manage your information and provide your customers with an overall positive experience.

  • Intuitively designed linking and layering
  • Variable product to underlying fund association
  • Customizable branding and functionality
  • Solution meets SEC compliance required guidelines 

Reach out to us today to learn how we can support your efforts as you incorporate new Rule 498A into your regulatory and compliance work management and communication processes. 


Toppan Merrill Rule VA/VUL Rule 498A Services Recent '40 Act Regulations
Rule 498A


Recent 1940 Act Regulations-1








Toppan Merrill

Toppan Merrill, a leader in financial printing and communication solutions, is part of the Toppan Printing Co., Ltd., the world's leading printing group, headquartered in Tokyo with approximately US$14 billion in annual sales. Toppan Merrill has been a pioneer and trusted partner to the financial, legal and corporate communities for five decades, providing secure, innovative solutions to complex content and communications requirements. Through proactive partnerships, unparalleled expertise, continuous innovation and unmatched service, Toppan Merrill delivers a hassle-free experience for mission-critical content for capital markets transactions, financial reporting and regulatory disclosure filings, and marketing and communications solutions for regulated and non-regulated industries. With global expertise in major capital markets, Toppan Merrill delivers unmatched service around the world.

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