Updating Summary Prospectus (Form 497VPU)

Yes , there are limits on the Investment Options.

• Certain Index Options may not be available under your Contract (see Appendix A).

• The availability of Investment Options may vary depending on the broker-dealer through

which the Contract is sold (see Appendix H).

• We can add new Index Options to your Contract in the future.

• You cannot allocate Purchase Payments to the Variable Option. The sole purpose of the

Variable Option is to hold Purchase Payments until they are transferred to your selected

Index Options.

• We restrict additional Purchase Payments during the Accumulation Phase. Each Index

Year before the Income Period, you cannot add more than your initial amount (i.e., the

total of all Purchase Payments received before the first Quarterly Contract Anniversary of

the first Contract Year) without our prior approval.

• We do not accept additional Purchase Payments during the Income Period (which is part

of the Accumulation Phase) or the Annuity Phase.

• We typically only allow assets to move into the Index Options on the Index Effective Date

and on subsequent Index Anniversaries as discussed in section 3, Purchasing the

Contract - Allocation of Purchase Payments and Contract Value Transfers. However, if

you execute an Early Reallocation, we will move assets into an Index Option on the

Business Day we receive your Early Reallocation request in Good Order.

• You can typically transfer Index Option Value only on Term End Dates. However, you can

transfer assets out of an Index Option before the Term End Date by first executing a

Performance Lock and then either requesting an Early Reallocation with new allocation

instructions or changing your allocation instructions before the next Index Anniversary.

For more information, see section 6, Valuing Your Contract - Performance Locks and

Early Reallocations.

• We do not allow assets to move into an established Index Option until the Term End Date.

If you request to allocate a Purchase Payment into an established Index Option on an

Index Anniversary that is not a Term End Date, we will allocate those assets to the same

Index Option with a new Term Start Date.

• We reserve the right to substitute the Fund in which the Variable Option invests. We also

reserve the right to close Index Options to new Purchase Payments and transfers, and to

substitute Indexes either on a Term Start Date or during a Term.

• We may terminate your ability to make additional Purchase Payments during the

Accumulation Phase because we reserve the right to decline any or all Purchase

Payments at any time on a nondiscriminatory basis.

• Caps, Trigger Rates, and Participation Rates will change from one Term to the next

subject to their contractual minimum guarantees.

• The 10%, 20%, and 30% Buffers, and -10% Floors for the currently available Index

Options do not change. However, if we add a new Index Option to your Contract after the

Issue Date, we establish the Buffer or Floor for it on the date we add the Index Option to

your Contract. For a new Index Option, the minimum Buffer is 5% and the minimum Floor

is -25%.