Transamerica Financial Life Insurance Co.

08/18/2025 | Press release | Distributed by Public on 08/18/2025 12:42

Post-Effective Amendment to Registration Statement by Investment Company (Form 485BPOS)

File No. 333-281598

As filed with the Securities and Exchange Commission on August 18, 2025

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, DC 20549

Form N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

Pre-Effective Amendment No. _
Post-Effective Amendment No. 4

(Check Appropriate Box or Boxes)

Transamerica Financial Life Insurance Company

(Name of Insurance Company)

6400 C Street SW

Cedar Rapids, IA 52499

(Address of Insurance Company's Principal Executive Offices) (Zip Code)

Insurance Company's Telephone Number, including Area Code: (319) 355-8511

Brian Stallworth, Esq.

Transamerica Financial Life Insurance Company

c/o Office of the General Counsel

6400 C Street SW

Cedar Rapids, IA 52499-4240

Telephone Number: (319) 355-8511

(Name, Address, including zip code, and telephone number, including area code, of Agent for Service)

Approximate Date of Proposed Public Offering: Continuously after the registration statement becomes effective.

It is proposed that this filing will become effective:

☐ immediately upon filing pursuant to paragraph (b)

☒ on August 18, 2025 pursuant to paragraph (b)

☐ 60 days after filing pursuant to paragraph (a)(1)

☐ on (date) pursuant to paragraph (a)(1) of Rule 485 under the Securities Act of 1933 ("Securities Act").

If appropriate, check the following box:

☐ This post-effective amendment designates a new effective date for a previously filed post-effective amendment.

Check each box that appropriately characterizes the Registrant:

☐ New Registrant (as applicable, a Registered Separate Account or Insurance Company that has not filed a Securities Act registration statement or amendment thereto within 3 years preceding this filing)

☐ Emerging Growth Company (as defined by Rule 12b-2 under the Securities Exchange Act of 1934 ("Exchange Act"))

☐ If an Emerging Growth Company, indicate by check mark if the Registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 7(a)(2)(B) of Securities Act.

☒ Insurance Company relying on Rule 12h-7 under the Exchange Act

☐ Smaller reporting company (as defined by Rule 12b-2 under the Exchange Act)

Explanatory Note

Registrant is filing this post-effective amendment (the "Amendment") for the sole purpose of supplementing the prospectus and Statement of Additional Information dated May 1, 2025 for the Transamerica Structured Index Advantage Annuity NY Registration Statement. The Amendment is not intended to amend or delete any part of Part A or Part B to the Registration Statement, except as specifically noted herein. Parts A and B included in Post-Effective Amendment No. 1 to the Registration Statement (File No. 333-281598) are hereby incorporated by reference to the extent required by applicable law. A new Part C is included in the Amendment.

TRANSAMERICA STRUCTURED INDEX ADVANTAGE® ANNUITY NY

An Individual Flexible Premium Deferred Index-Linked Annuity Policy

Issued by

Transamerica Financial Life Insurance Company

Supplement dated August 18, 2025

to the

Prospectus dated May 1, 2025

This supplement updates certain information contained in the prospectus. Please read this supplement carefully and retain it for future reference. Capitalized terms not defined in this supplement have the same meanings as in the prospectus.

CHANGES TO THE POLICY

NEW INDEX ACCOUNT OPTIONS

Beginning August 18, 2025, three new Index Account Options will be available under the Policy. We refer to these new Index Account Options as "Triple Edge Advantage" or "Dual Direction" in the Policy form and our marketing materials. Each is linked to the performance of the S&P 500® Index (price return); has a Crediting Period of 1, 2, or 6 years; has Buffer as the Downside Protection Type (with a Buffer Rate of 10%); and a new Growth Opportunity Type: Edge and Edge+. The Edge and Edge+ Growth Opportunity Type has an associated Edge Rate and Edge+ Rate.

The new Index Account Options provide for investment gain at the end of a Crediting Period if the Index Change is positive, zero, or to a limited extent, negative. A negative Index Change in excess of the Buffer Rate will result in loss.

•

If the Index Change is positive or zero, the Index Credit will be positive. The Index Credit Rate will equal the Edge+ Rate.

•

If the Index Change is negative, but does not exceed the Buffer Rate, the Index Credit will be positive. The Index Credit Rate will equal the Edge Rate.

•

If the Index Change is negative, and does exceed the Buffer Rate, the Index Credit will be negative. The Index Credit Rate will equal the negative Index Change in excess of the Buffer Rate.

Under the new Index Account Options, the Edge Rate and Edge+ Rate represent a fixed potential return. In no event will a positive Index Credit Rate, if any, differ from the Edge Rate or Edge+ Rate, as applicable. This may result in you earning less than the Index's return. Edge Rates and Edge+ Rates under the new Index Account Options will vary from one Crediting Period to the next, subject to guaranteed minimums. The lowest Edge Rate and Edge+ Rate that may be established under the Policy is 3%.

You should understand that while the Edge and Edge+ Growth Opportunity Type may provide for a positive Index Credit in the event of negative Index performance, there is no guarantee of investment gain. A negative Index Change in excess of the Buffer Rate will result in loss, which could be significant. At the end of a Crediting Period for any of the new Index Account Options, the maximum amount of loss that you could experience from negative Index performance is 90%.

Please see "Revisions to the Prospectus" below for additional information about the new Index Account Options, including examples.

GUARANTEED MINIMUM DEATH BENEFIT (GMDB RIDER)

For Policies with both (i) an application signed on or after August 18, 2025, and (ii) an Annuitant who is younger than age 81 as of the application date, a guaranteed minimum death benefit ("GMDB") rider will be automatically added to the Policy for no additional charge. The GMDB rider is not available under any other Policies. The Policy Value death benefit will apply (for no additional charge) to any Policy that is ineligible for the GMDB rider.

The GMDB rider provides for a guaranteed minimum death benefit equal to total premium payments, reduced for withdrawals. Withdrawals may result in reductions to the benefit that are greater than the amount withdrawn. If the GMDB rider is in effect upon the death of the Annuitant during the accumulation phase, the death benefit will equal the greater of (a) Policy Value and (b) the guaranteed minimum death benefit. If an Owner who is not also the Annuitant pre-deceases the Annuitant during the accumulation phase, the death benefit will be equal to the Policy Value (there will be no guaranteed minimum death benefit).

Please see "Revisions to the Prospectus" below for additional information about the GMDB rider.

REVISIONS TO THE PROSPECTUS

Each of the prospectus revisions below are effective August 18, 2025.

I. Cover Page

The third paragraph of the bullet labeled "Index Account Options" (including the associated sub-bullets) is replaced with the following:

Each available Index Account Option also has either a (i) Cap or (ii) Edge and Edge+ upside feature, which will be used to calculate any positive Index rate of return that may be credited to your investment at the end of a Crediting Period. Cap Rates, and Edge Rates and Edge+ Rates, vary by Index Account Option and generally change from one Crediting Period to the next, subject to guaranteed minimums.

o

We will limit the amount you can earn on an Index Account Option based on the Cap Rate or Edge Rate and Edge+ Rate that we declare for the Crediting Period.

o

The lowest Cap Rate that may be established under the Policy is 3%.

o

The lowest Edge Rate and Edge+ Rate that may be established under the Policy is 3%.

II. Glossary of Terms

The following new special terms are added to the glossary:

Edge and Edge+ - A Growth Opportunity Type. If you select an Index Account Option with Edge and Edge+, at the end of the Crediting Period:

•

If the Index Change is positive or zero, the Index Credit will be positive. The Index Credit Rate (i.e., your Index rate of return) will equal the Edge+ Rate.

•

If the Index Change is negative, but does not exceed the Buffer Rate, the Index Credit will be positive. The Index Credit Rate will equal the Edge Rate.

•

If the Index Change is negative, and does exceed the Buffer Rate, the Index Credit will be negative. The Index Credit Rate will equal the negative Index Change in excess of the Buffer Rate.

Edge Rate - For an Index Account Option with the Edge and Edge+ Growth Opportunity Type, the percentage used to calculate the Index Credit Rate if the Index Change is negative, but not in excess of the Buffer Rate.

Edge+ Rate - For an Index Account Option with the Edge and Edge+ Growth Opportunity Type, the percentage used to calculate the Index Credit Rate if the Index Change is positive or zero.

Guaranteed Minimum Death Benefit (guaranteed minimum death benefit) - The minimum death benefit provided by the Guaranteed Minimum Death Benefit (GMDB) rider. The guaranteed minimum death benefit will equal 100% of the Policy Value as of the rider effective date. Thereafter, over the life of the rider, the guaranteed minimum death benefit will increase dollar-for-dollar for subsequent premium payments and will be reduced by withdrawals. Withdrawals may result in proportionate reductions to the benefit that are greater than the amount withdrawn.

GMDB Benefit Base - The GMDB Benefit Base equals the guaranteed minimum death benefit under the GMDB rider (including any increases for additional premium payments and reductions for withdrawals).

The definitions of the existing special terms listed below are replaced as follows:

Buffer - The Downside Protection Type for the available Index Account Options. If you select an Index Account Option, your investment will incur loss at the end of the Crediting Period for negative Index performance beyond the Buffer Rate. For example, if you select an Index Account Option with a Buffer Rate of 10%, and at the end of the Crediting Period the Index Change is -15%, your Index Credit Rate (i.e., your Index rate of return) would be -5%. If the negative Index performance does not go beyond the Buffer Rate, you will not incur loss as a result of that negative Index performance.

Cap - A Growth Opportunity Type. If you select an Index Account Option with Cap, you will participate in positive Index performance at the end of the Crediting Period up to the Cap Rate, but no positive Index performance beyond the Cap Rate. For instance, if you select an Index Account Option with a Cap Rate of 10%, and at the end of the Crediting Period the Index Change is 5%, your Index Credit Rate (i.e., your Index rate of return) would be +5%. If the Index Change were 15%, your Index Credit Rate would be limited to +10%.

Cap Rate - For an Index Account Option with Cap, the percentage used to calculate the Index Credit Rate if the Index Change is positive.

Death Benefit - The amount payable upon the death of the Annuitant or Owner during the accumulation phase.

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Growth Opportunity Type - A feature of an Index Account Option that determines whether and the extent to which a positive Index Credit will apply at the end of a Crediting Period.

III. Overview of the Policy

On page 5, the fourth paragraph (but not the associated bullet) under the subsection "Phases of the Policy - The Accumulation Phase" is replaced with the following:

We may limit the positive Index Change used in calculating Index Credit for an Index Account Option at the end of its Crediting Period. Each Index Account Option has a Growth Opportunity Type that may limit your positive Index returns. The only Growth Opportunity Types that we currently offer are (i) Cap, with an associated Cap Rate and (ii) Edge and Edge+, with an associated Edge Rate and Edge+ Rate. These Growth Opportunity Types may limit positive Index returns in the following manner:

Under the same paragraph, the following is added as a new bullet:

•

Edge and Edge+ - If you select an Index Account Option with Edge and Edge+, a positive Index Credit will apply at the end of the Crediting Period if the Index Change is positive, zero, or to a limited extent, negative.

o

If the Index Change is positive or zero, the Index Credit Rate will be positive, equal to the Edge+ Rate. For example, if you select an Index Account Option with an Edge Rate of 5% and an Edge+ Rate of 7%, and at the end of the Crediting Period the Index Change is 10%, your Index Credit Rate would be +7% (i.e., the Edge+ Rate).

o

If the Index Change is negative, but does not exceed the Buffer Rate, the Index Credit Rate will be positive, equal the Edge Rate. For example, if you select an Index Account Option with a Buffer Rate of 10%, an Edge Rate of 5%, and an Edge+ Rate of 7%, and at the end of the Crediting Period the Index Change is -6%, your Index Credit Rate would be +5% (i.e., the Edge Rate).

o

If the Index Change is negative, and does exceed the Buffer Rate, your Index Credit Rate will be negative. The negative Index Credit Rate will equal the negative Index Change in excess of the Buffer Rate.

The lowest Edge Rate and Edge+ Rate that may be established under the Policy is 3%.

IV. Policy Features

On page 7, the subsection "Death Benefit" is replaced with the following:

Death Benefit. The Policy has either (a) a guaranteed minimum death benefit under the GMDB rider or (b) a Policy Value death benefit. If your Policy does not have the GMDB rider, the Policy Value death benefit will apply. Once your Policy is issued, your death benefit cannot be changed.

•

Guaranteed Minimum Death Benefit (GMDB Rider). For Policies with both (i) an application signed on or after August 18, 2025, and (ii) an Annuitant who is younger than age 81 as of the application date, the GMDB rider will be automatically added to the Policy for no additional charge. The GMDB rider is not available under any other Policies (under limited circumstances, the GMDB rider may be re-elected after termination of the rider following the death of the Owner or Annuitant).

The GMDB rider provides for a guaranteed minimum death benefit equal to total premium payments, reduced for withdrawals. Withdrawals may result in reductions to the benefit that are greater than the amount withdrawn. If the GMDB rider is in effect upon the death of the Annuitant during the accumulation phase, the death benefit will equal the greater of (a) Policy Value or (b) the guaranteed minimum death benefit. If an Owner who is not also the Annuitant pre-deceases the Annuitant during the accumulation phase, the death benefit will be equal to the Policy Value (there will be no guaranteed minimum death benefit).

•

Policy Value Death Benefit. If the GMDB rider is not issued with your Policy, your Policy includes a Policy Value death benefit for no additional charge. Upon the death of the Annuitant (or Owner who is not also the Annuitant) during the accumulation phase, the death benefit will be equal to the Policy Value.

V. Important Information You Should Consider About the Policy

On page 8, in the middle column of the row "Are There Ongoing Fees and Expenses?", the first sentence of the first full paragraph is replaced with the following:

There is an implicit ongoing fee on the Index Account Options to the extent that your participation in Index gains is limited by either a Cap Rate or an Edge Rate or Edge+ Rate.

3

On page 10, in the middle column of the row "Is this a Short-Term Investment?", the second sentence of the last bullet is replaced with the following:

In the absence of such instructions, Policy Value in the matured Allocation Account will be automatically reinvested in the same Allocation Account for another Crediting Period (with the Cap Rate, Edge Rate and Edge+ Rate, or annual interest rate applicable to a new Crediting Period).

On page 10, in the middle column of the row "What are the Risks Associated with the Investment Options?", the third bullet (including the associated sub-bullet) is replaced with the following:

•

The Cap Rate or Edge Rate and Edge+ Rate for an Index Account Option, as applicable, may limit positive Index returns (e.g., limited upside). This limit may result in you earning less than the Index's return. For example:

o

If the Index Change is 12% and the Cap Rate is 4%, we will apply an Index Credit equal to +4% at the end of the Crediting Period.

o

If the Index Change is 12% and the Edge+ Rate is 5%, we will apply an Index Credit equal to +5% at the end of the Crediting Period.

•

While the Edge and Edge+ Growth Opportunity Type may provide for a positive Index Credit in the event of negative Index performance, there is no guarantee of investment gain. Like any other Index Account Option, a negative Index Change in excess of the Buffer Rate will result in loss, which could be significant.

On page 11, in the middle column of the row "Are There Restrictions on the Investment Options?", the fifth bullet is replaced with the following:

•

We may change the features of an Index Account Option from one Crediting Period to the next, including the Index and the current limit on Index gain (i.e., the Cap Rate or Edge Rate and Edge+ Rate, subject to minimum guarantees).

On page 11, in the middle column of the row "Are There any Restrictions on Policy Benefits?," the following is added as the fourth bullet:

•

If your Policy has the GMDB rider, any withdrawal will reduce the guaranteed minimum death benefit. Withdrawals may result in reductions to the benefit that are greater than the amount withdrawn.

VI. Principal Risks of Investing in the Policy

On page 14, under "Allocation Account Availability Risk," the first sentence of the fourth paragraph is replaced with the following:

We may change the features of an Index Account Option from one Crediting Period to the next, including the Index and the current limit on Index gain (i.e., the Cap Rate or Edge Rate and Edge+ Rate, subject to minimum guarantees).

On page 15, under "Liquidity Risk," the second sentence of the bullet labeled "Maturity" is replaced with the following:

In the absence of such instructions, Policy Value in the matured Allocation Account will be automatically reinvested in the same Allocation Account for another Crediting Period (with the Cap Rate, Edge Rate and Edge+ Rate, or annual interest rate applicable to a new Crediting Period).

On page 17, under "Withdrawal and Surrender Risk," the last bullet is deleted and the third-to-last bullet is replaced with the following:

•

Any withdrawal you take will reduce the Policy Value (because you are taking money out of your Policy) and the amount of the death benefit, including the guaranteed minimum death benefit (perhaps significantly) if the GMDB rider is in effect. Withdrawals may result in reductions to the guaranteed minimum death benefit that are greater than the amount withdrawn. See POLICY VALUE AND CASH VALUE and DEATH BENEFIT.

On page 18, the risk factor "Growth Opportunity Type Risk" is replaced with the following:

GROWTH OPPORTUNITY TYPE RISK

When you invest in an Index Account Option, the upside potential of your investment may be limited by its Growth Opportunity Type. For Cap, the Cap Rate may limit the upside potential of your investment by capping your participation in positive Index performance. For Edge and Edge+, the Edge Rate and Edge+ Rate are fixed rates of potential return (in no event will a positive Index Credit Rate, if any, differ from the Edge Rate or Edge+ Rate, as applicable). In either case, the Index Credit Rate used to calculate gains may be lower than the Index Change. The risk of investment loss could be significantly greater than the potential

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for investment gain.

Although Index Account Options with Edge and Edge+ may provide for a positive Index Credit in the event of negative Index performance, like every other Index Account Option, they do not guarantee a positive Index Credit, and they are subject to risk of loss as described under "Buffer Risk."

In general, depending on applicable rates, an Index Account Option with relatively more upside potential based on its Cap Rate is likely to have relatively less downside protection based on its Buffer Rate. Conversely, depending on applicable rates, an Index Account Option with relatively less upside potential based on its Cap Rate is likely to have more downside protection based on its Buffer Rate. Currently, all Index Account Options with Edge and Edge+ have the same Buffer Rate.

We may declare new Cap Rates, or Edge Rates and Edge+ Rates, for the available Index Account Options for new Crediting Periods. We set these rates in our discretion, within any guaranteed limits to which we are subject as described in this prospectus. You bear the risk that the rate(s) we declare for a new Crediting Period will not be any more or less favorable to you than any guaranteed limits to which we are subject.

VII. Index Account Options

On page 29, under the subsection "Index Credit Rate and Index Credit," the second sentence of the second paragraph is replaced with the following:

The Index Credit Rate is determined by applying the Index Change to either the Downside Protection Type or Growth Opportunity Type, as applicable.

On page 30, the third paragraph (including its associated bullets) under the subsection "Limits on Index Losses: Calculating Losses Using the Downside Protection Type" is replaced with the following:

We calculate your Index Credit Rate using the Buffer as follows:

•

If the Index Change is not in excess of the Buffer Rate, your Index Credit Rate will equal 0% (if you selected an Index Account Option with Cap) or the Edge Rate (if you selected an Index Account Option with Edge and Edge+). In either case, you will not experience any loss as a result of the negative Index performance.

•

If the Index Change exceeds the Buffer Rate, your Index Credit Rate will be negative, and you will experience loss as a result of the negative Index performance. The percentage loss will be equal to the Index Change in excess of the Buffer Rate.

On page 30, the second sentence of the fifth paragraph under the same subsection is replaced with the following:

Each example assumes that you selected an Index Account Option with a Buffer Rate of 10% (and Cap as the Growth Opportunity Type).

On page 31, under the subsection "Limits on Index Gains: Calculating Gains Using the Growth Opportunity Type," the first four paragraphs are replaced with the following:

At the end of a Crediting Period for an Index Account Option, we may limit the positive Index return used in calculating Index Credits by applying the designated Growth Opportunity Type. The Growth Opportunity Types that we currently offer are (i) Cap and (ii) Edge and Edge+.

The Cap Rate, or Edge Rate and Edge+ Rate, for an Index Account Option will not change during a Crediting Period but may change from one Crediting Period to the next, subject to the guaranteed minimum(s) applicable to that Index Account Option. The guaranteed minimum Cap Rate, or guaranteed minimum Edge Rate and Edge+ Rate, vary by Index Account Option.

•

The lowest Cap Rate that may be established under the Policy is 3%.

•

The lowest Edge Rate and Edge+ Rate that may be established under the Policy is 3%.

For each Index Account Option available for investment, the Cap Rate or Edge Rate and Edge+ Rate that we are currently offering for a new Crediting Period will be published at the following website address before rates take effect: cdn.bfldr.com/86JM1UOD/as/3h58nk8ws67pfph7xktm3f4/Transamerica_TSIA_NY_Rate_Change_Flyer.pdf. The Cap Rates and Edge Rates and Edge+ Rates posted on that website address are incorporated by reference into the prospectus. You may also obtain the posted rates by contacting your financial professional or the Company at our Administrative Office.

We determine Cap Rates, or Edge Rates and Edge+ Rates, for each new Crediting Period at our discretion, subject to applicable guaranteed minimums. We consider a number of factors when declaring these rates. Generally, we seek to manage our risk associated

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with our obligations, in part, by trading derivative and fixed income instruments. The costs and value of these instruments impact the rates we declare, and those costs and values can be impacted by market conditions and forces. We also consider factors such as sales commissions, administrative expenses, regulatory and tax requirements, general economic trends, and competitive factors. You bear the risk that we may declare lower rates for future Crediting Periods, and that such rates could be as low as the applicable guaranteed minimum(s). Rates offered for new Crediting Periods may be different from those offered to new investors or offered to you at Policy issuance.

The following new subsection is added under "Limits on Index Gains: Calculating Gains Using the Growth Opportunity Type":

Edge and Edge+

Index Account Options with the Edge and Edge+ Growth Opportunity Type (also called "Triple Edge Advantage" or "Dual Direction" in the Policy form and our marketing materials) provide for positive Index Credit at the end of a Crediting Period if the Index Change is positive, zero, or to a limited extent, negative.

•

If the Index Change is positive or zero, the Index Credit Rate will be positive, equal to the Edge+ Rate.

•

If the Index Change is negative, but does not exceed the Buffer Rate, the Index Credit Rate will be positive, equal the Edge Rate.

•

If the Index Change is negative, and does exceed the Buffer Rate, the Index Credit will be negative. The negative Index Credit Rate will equal the negative Index Change in excess of the Buffer Rate. See LIMITS ON INDEX LOSSES: CALCULATING LOSSES USING THE DOWNSIDE PROTECTION TYPE.

For instance, assume you select an Index Account Option with an Edge Rate of 5%, Edge+ Rate of 7%, and Buffer Rate of 10%. If, at the end of the Crediting Period, the Index Change is 10%, your Index Credit Rate would be +7% (i.e., the Edge+ Rate). If instead the Index Change is -8%, your Index Credit Rate would be +5% (i.e., the Edge Rate). If instead the Index Change is -15%, your Index Credit Rate would be -5% (i.e., the negative Index Change in excess of the Buffer Rate).

The Edge Rate and Edge+ Rate are fixed rates of potential return. In no event will a positive Index Credit Rate, if any, differ from the Edge Rate or Edge+ Rate, as applicable. The Edge Rate and Edge+ Rate therefore limit the upside potential of your investment. The Edge Rate and Edge+ Rate are measured over the life of the Crediting Period, which can be more than one year. In cases where a Crediting Period is more than one year, the Edge Rate and Edge+ Rate for that Crediting Period would be less if measured on an annual basis.

Currently, for any Index Account Option with Edge and Edge+, the Edge Rate and Edge+ Rate are subject to the same guaranteed minimum. The declared Edge+ Rate may be higher, lower, or equal to the declared Edge Rate (and vice versa). The only guarantee in that regard is that both the declared Edge Rate and the Edge+ Rate will satisfy the guaranteed minimum.

The following is added under the subsection "Examples of Crediting Methodology" beginning on page 32:

For each scenario below, assume an Index Account Option with a 1-year Crediting Period, Buffer (Buffer Rate 10%), and Edge and Edge+ (Edge Rate 5% and Edge+ Rate 10%).

Scenario Starting
Index Base
Initial
Index Value
Final Index
Value
Index
Change
Index
Credit Rate
Ending
Index Base
Index
Credit
Index Account
Option Value

1

1000 100 120 +20% +10% 1000 +$100 $1,100

2

1000 100 105 +5% +10% 1000 +$100 $1,100

3

1000 100 100 0% +10% 1000 +$100 $1,100

4

1000 100 95 -5% +5% 1000 +$50 $1,050

5

1000 100 80 -20% -10% 1000 -$100 $900

VIII. Access to Your Money

On page 44, the following bullet is added to the list of bullets:

•

If your Policy has the GMDB rider, any withdrawal will reduce the guaranteed minimum death benefit. Withdrawals may result in reductions to the benefit that are greater than the amount withdrawn.

IX. Surrenders and Withdrawals

On page 46, under the subsection "Involuntary Cashout," the following is added as the last paragraph:

We will not invoke the Involuntary Cashout provision if the GMDB rider is in-force and has a death benefit amount of $2,000 or

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greater. If the Involuntary Cashout provision is invoked when the death benefit amount under the GMDB rider is less than $2,000, we will pay the greater of the Policy Value or the guaranteed minimum death benefit.

X. Benefits Available Under the Policy

On page 47, a row for the GMDB rider is added to the table, as follows:

Name of Benefit Purpose Standard or
Optional
Maximum Fee

Brief Description of

Restrictions/Limitations

Guaranteed Minimum Death Benefit Rider Provides for a guaranteed minimum death benefit equal to total premium payments, reduced for withdrawals, payable upon death of the Annuitant. Upon the death of the Owner (who is not also the Annuitant), pays a death benefit equal to Policy Value. Standard No Charge

•   Available only at Policy purchase and, under limited circumstances, may be re-elected after death.

•   Automatically included with Policy if Policy application is signed on or after August 18, 2025, and the Annuitant as of the application date is younger than age 81. Not available under any other Policies.

•   Terminates upon Annuitization.

•   All withdrawals under the Policy will reduce the benefit. Withdrawals may result in reductions to the benefit that are greater than the amount withdrawn.

•   Benefit may be subject to an Interim Value adjustment, which may be negative.

XI. DEATH BENEFIT

On page 49, under the subsection "General," the first paragraph is replaced with the following:

The Policy has either (i) a guaranteed minimum death benefit under the GMDB rider or (ii) a Policy Value death benefit. If your Policy does not include the GMDB rider, the Policy Value death benefit will apply to your Policy. Once your Policy is issued, your death benefit cannot be changed. Neither death benefit has an additional charge.

For Policies with both (i) an application signed on or after August 18, 2025, and (ii) an Annuitant who is younger than age 81 as of the application date, the GMDB rider will be automatically added to the Policy. The GMDB rider is not available under any other Policies.

The following summarizes the death benefit that may be payable under the Policy:

•

Guaranteed Minimum Death Benefit (GMDB Rider). The GMDB rider provides for a guaranteed minimum death benefit. The guaranteed minimum death benefit under the GMDB rider is payable only upon the death of the Annuitant during the accumulation phase. This means:

o

If the Annuitant and the Owner under the Policy are the same person, then upon the death of such person during the accumulation phase, the death benefit will be the greater of the guaranteed minimum death benefit and the Policy Value.

o

If the Annuitant and Owner under the Policy are not the same person:

Upon the death of the Annuitant during the accumulation phase, the death benefit will equal the greater of the guaranteed minimum death benefit and the Policy Value.

If the Owner pre-deceases the Annuitant during the accumulation phase, the death benefit will equal the Policy Value. The guaranteed minimum death benefit would not be payable.

•

Policy Value Death Benefit. If the Policy Value death benefit applies to your Policy, upon the death of the Annuitant (or an Owner who is not also the Annuitant) during the accumulation phase, the death benefit will equal the Policy Value.

The following table reflects the death benefit that may be payable under the Policy as described above.

GMDB Rider Death Benefit

- Owner & Annuitant are

GMDB Rider Death Benefit -

Owner & Annuitant are

Policy Value Death Benefit

- Owner & Annuitant are

Policy Value Death Benefit -

Owner & Annuitant are

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Same Person Different People Same Person Different People
Owner Dies During Accumulation Phase Greater of Policy Value and guaranteed minimum death benefit Policy Value Policy Value Policy Value
Annuitant Dies During Accumulation Phase Greater of Policy Value and guaranteed minimum death benefit Greater of Policy Value and guaranteed minimum death benefit Policy Value Policy Value

On page 50, after the subsection "Beneficiaries," the following new subsection is added:

GUARANTEED MINIMUM DEATH BENEFIT (GMDB) RIDER

For Policies with both (i) an application signed on or after August 18, 2025, and (ii) an Annuitant who is younger than age 81 as of the application date, the GMDB rider will be automatically added to the Policy. The GMDB rider is not otherwise available. The rider may vary for certain Policies and may not be available for all Policies at all times. Once you elect a death benefit and your Policy is issued, your death benefit cannot be changed, and you will not be impacted if we decide to stop offering the rider.

The GMDB rider, if in effect, provides for a guaranteed minimum death benefit upon the death of the Annuitant during the accumulation phase. The guaranteed minimum death benefit will equal 100% of the Policy Value as of the rider effective date. Thereafter, over the life of the rider, the guaranteed minimum death benefit will increase dollar for dollar for subsequent premium payments and will be reduced by any adjusted withdrawals (as described further below).

Upon the death during the accumulation phase of the Annuitant, if the GMDB rider is in effect, the death benefit will equal either (a) the guaranteed minimum death benefit under the rider or (b) the Policy Value, whichever is greater. Because the GMDB rider includes a guaranteed minimum death benefit that could be greater than Policy Value, the GMDB rider may increase the amount payable compared to the Policy Value death benefit. However, if the Policy Value is greater than the guaranteed minimum death benefit at the time that the death benefit becomes payable, the death benefit under the GMDB rider will be the Policy Value, same as the Policy Value death benefit.

When you take any type of withdrawal (including an automatic withdrawal, minimum required distribution, surrender charge- free withdrawal, or any other withdrawal), your guaranteed minimum death benefit will be reduced by an amount called the "adjusted withdrawal."

The adjusted withdrawal may be more than the dollar amount of your withdrawal request. This will be the case if the guaranteed minimum death benefit exceeds the Policy Value at the time of withdrawal. If you have a qualified Policy, minimum required distributions rules may require you to request a withdrawal.

The formula used to calculate the adjusted withdrawal amount is AW = DP x (GW/PV) where:

AW = Adjusted withdrawal

DP = Greater of PV or GMDB

GW = Gross withdrawal

PV = Policy Value prior to the withdrawal

GMDB = Guaranteed minimum death benefit prior to the withdrawal

We have included a detailed explanation of this adjustment with examples in APPENDIX C - REDUCTION TO GUARANTEED MINIMUM DEATH BENEFIT FOR WITHDRAWALS UNDER GMDB RIDER.

The GMDB rider will terminate upon the earliest of:

•

The Annuity Commencement Date;

•

Upon the death of the Annuitant;

•

Upon the death of the Owner;

•

Surrender of the Policy; or

•

Other termination of the Policy.

Under limited circumstances, the GMDB rider may be re-elected after termination of the rider, following the death of the Owner or Annuitant. See BENEFICIARY CONTINUATION - Re-Election of GMDB Rider Upon Continuation.

You cannot choose to terminate the GMDB rider unless you Surrender the Policy.

On page 50, under "The Death Benefit Amount," the first three subsections are replaced as follows:

Death of Person who is both the Annuitant and an Owner Before the Annuity Commencement Date

The death benefit becomes payable if:

8

•

You are both the Annuitant and the Owner (or joint Owner) of the Policy; and

•

You die before the Annuity Commencement Date.

Under these circumstances, the death benefit will equal the greatest of:

1.

The Policy Value (which will already reflect any applicable fluctuations of the Interim Value) on the date we receive due proof of death and an election of method of settlement.

or

2.

If the GMDB rider is in effect, the guaranteed minimum death benefit on the date of death (plus any additional premium payments received, less any gross withdrawals, after the date of death to the date of payment of death proceeds on a dollar-for-dollar basis). See GUARANTEED MINIMUM DEATH BENEFIT (GMDB) RIDER above for information about how the guaranteed minimum death benefit is calculated.

If an Owner is not also the Annuitant, in the event of simultaneous deaths of the Owner and the Annuitant, the death proceeds equal the amount described in this subsection.

Death of Person who is an Owner but not the Annuitant

The death benefit becomes payable if:

•

You are the Owner (or joint Owner) of the Policy but not also the Annuitant; and

•

You die before the Annuity Commencement Date.

Under these circumstances, the death benefit will equal the Policy Value (which will already reflect any applicable fluctuations of the Interim Value) on the date we receive due proof of death and an election of method settlement.

For purposes of this section, if the Owner is not an individual, then the death of the Annuitant will be treated as the death of the Owner who is also the Annuitant, as described under "Death of Person who is both the Annuitant and an Owner" above.

Death of Annuitant Who is Not an Owner Before the Annuity Commencement Date

If the Annuitant dies before the Annuity Commencement Date, the Annuitant is not the Owner, and the Owner is a natural person:

•

The Owner shall become the Annuitant or, in the case of joint Owners where neither is the deceased Annuitant, the younger Owner shall become the Annuitant; and

•

The Policy Value will be adjusted to equal the greatest of:

1.

The Policy Value on the date we receive due proof of death and an election of method of settlement; or

2.

If the GMDB rider is in effect, the guaranteed minimum death benefit on the date of death (plus any additional premium payments received, less any gross withdrawals, after the date of death on a dollar-for-dollar basis). See GUARANTEED MINIMUM DEATH BENEFIT (GMDB) RIDER above for information about how the guaranteed minimum death benefit is calculated.

This is a one-time only Policy Value adjustment applied at the time the Owner becomes the Annuitant.

If the GMDB rider is in effect, the rider will terminate at the time of due proof of death. The GMDB rider may be re-elected by the Owner within 30 days of our receipt of due proof of death provided that the rider's age eligibility requirements are satisfied, and we are still offering the rider.

If the GMDB rider is re-elected, the Policy Value used to determine the initial guaranteed minimum death benefit under the re-elected rider will be the Policy Value at time of re-election. If re-elected at time of continuation, this would be the Policy Value immediately following the one-time adjustment described above.

At the time of the one-time adjustment described above, the Policy Value invested in any Allocation Account will remain invested in that Allocation Account in accordance with the general terms of the Policy as described in this prospectus. Any Policy Value added to the Policy as a result of the adjustment will be held in the Fixed Holding Account pending our receipt of new allocation instructions. If we receive allocation instructions within 30 days of continuation, this portion of the Policy Value will be allocated in accordance with those instructions on the next upcoming 1st, 8th, 15th, or 22nd calendar day of any month, whichever occurs first, and the Crediting Period(s) will begin on that day. If we do not receive allocation instructions within 30 days of continuation, this portion of the Policy Value will be automatically allocated to the Default Option.

After the adjustment, the Policy's death benefit may then become payable at a later date prior to the Annuity Commencement Date as

9

set forth under Death of Owner Before the Annuity Commencement Date above.

Under "Beneficiary Continuation" beginning on page 51, the following new subsection is added:

Re-Election of GMDB Rider Upon Continuation

If a Policy has a GMDB rider when the death benefit becomes payable or a one-time adjustment to the Policy Value as described in this section occurs, the rider will terminate upon our receipt of due proof of death of the decedent.

When the Policy is continued by a surviving spouse upon payment of a death benefit, the surviving spouse may re-elect the GMDB rider under the Policy, if the rider is available at that time. The initial guaranteed minimum death benefit under the re-elected rider will be the Policy Value at time of re-election. If re-elected at time of continuation, this would be the Policy Value immediately following the one-time adjustment described above. A non-spouse beneficiary who continues the Policy upon payment of the death benefit cannot re-elect the GMDB rider.

Upon the death of an Annuitant who is not an Owner, the surviving Owner may re-elect the GMDB rider under the Policy following the one-time adjustment to Policy Value, if the rider is available at that time. The initial guaranteed minimum death benefit under the re-elected rider will be the Policy Value at time of re-election. If re-elected at time of continuation, this would be the Policy Value immediately following the one-time adjustment described above.

Re-election is available only if the Annuitant has not reached the age of 81 at the time of the re-election.

XII. Appendix A - Investment Options Available Under the Policy

On page A-1, rows for the new Index Account Options with Edge and Edge+ are added to the Index Account Options table, as follows:

Index Type of Index

Crediting

Period

Current Limit on

Index Loss

(if held until end of

Crediting Period)

Minimum Limit 

on Index Gain 

(for the life of the 

Index Account Option) 

S&P 500® Index1

U.S. Large-Cap Equities 1-Year Buffer
Buffer Rate: 10%

Edge and Edge+ Rates: 

No lower than 5.00% 

S&P 500® Index1

U.S. Large-Cap Equities 2-Year Buffer
Buffer Rate: 10%

Edge and Edge+ Rates: 

No lower than 10.00% 

S&P 500® Index1

U.S. Large-Cap Equities 6-Year Buffer
Buffer Rate: 10%

Edge and Edge+ Rates: 

No lower than 30.00% 

1

This Index is a "price return" index, not a "total return" index, and therefore does not reflect the dividends paid on the securities composing the Index, which will reduce the Index return and may cause the Index to underperform a direct investment in the securities composing the Index.

On page A-1, the third paragraph (and associated bullet) and fourth paragraph under the Index Account Options table are replaced with the following:

In the future, if we offer a new Index Account Option and:

•

the Growth Opportunity Type is Cap, the guaranteed minimum Cap Rate will be no lower than 3.00%.

•

the Growth Opportunity Type is Edge and Edge+, the guaranteed minimum Edge Rate and Edge+ Rate will be no lower than 3.00%.

We reserve the right to offer new Index Account Options with different Downside Protection Types or Growth Opportunity Types in the future.

XIII. New Appendix C

The following appendix is added to the prospectus:

APPENDIX C

REDUCTION TO GUARANTEED MINIMUM DEATH BENEFIT FOR WITHDRAWALS UNDER GMDB RIDER

Adjusted Withdrawals. If the GMDB rider is part of your Policy, and you take a withdrawal, then your guaranteed minimum death benefit is reduced by an amount called the adjusted withdrawal. The amount of the reduction depends on the relationship between your death proceeds and Policy Value. The adjusted withdrawal is equal to the gross withdrawal multiplied by the death proceeds immediately prior to the withdrawal divided by the Policy Value immediately prior to the withdrawal.

10

The formula is AW = DP x (GW/PV) where:

AW is the adjusted withdrawal

DP is the death proceeds prior to the withdrawal = greater of PV or GMDB

GW is the gross withdrawal

PV is the Policy Value prior to the withdrawal

GMDB is the guaranteed minimum death benefit prior to the withdrawal

The following examples describe the effect of a withdrawal on the guaranteed minimum death benefit and Policy Value.

Example 1: Death Proceeds Greater than Policy Value

Assumptions:

GMDB = $75,000

PV = $50,000

DP = $75,000

GW = $15,494

AW = $75,000 x ($15,494 /$50,000) = $23,241

 Reduction in guaranteed minimum death benefit

= $ 23,241 

 Summary:

 Reduction in Policy Value

= $ 15,494 

 New guaranteed minimum death benefit amount

= $ 51,759 

 New Policy Value (after withdrawal)

= $ 34,506 

The guaranteed minimum death benefit is reduced more than the Policy Value because the guaranteed minimum death benefit was greater than the Policy Value immediately prior to the withdrawal.

Example 2: Death Proceeds Equal to Policy Value

Assumptions:

GMDB = $50,000

PV = $75,000

DP = $75,000

GW = $15,494

AW = $75,000 x ($15,494 /$75,000) = $15,494

 Reduction in guaranteed minimum death benefit

= $ 15,494 

 Summary:

 Reduction in Policy Value

= $ 15,494 

 New guaranteed minimum death benefit amount

= $ 34,506 

 New Policy Value (after withdrawal)

= $ 59,506 

The guaranteed minimum death benefit and Policy Value are reduced by the same amount because the Policy Value was greater than the guaranteed minimum death benefit immediately prior to the withdrawal.

These examples are for illustrative purposes only. The purpose of these illustrations is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

11

TRANSAMERICA STRUCTURED INDEX ADVANTAGE® ANNUITY NY

An Individual Flexible Premium Deferred Index-Linked Annuity Policy

Issued by

Transamerica Financial Life Insurance Company

Supplement dated August 18, 2025

to the

Statement of Additional Information dated May 1, 2025

This supplement updates certain information contained in the Statement of Additional Information ("SAI"). Please read this supplement carefully and retain it for future reference. Capitalized terms not defined in this supplement have the same meanings as in the SAI.

Beginning August 18, 2025, three new Index Account Options will be available under the Policy, as described in the prospectus supplement dated August 18, 2025. We refer to these new Index Account Options, which have a new Edge and Edge+ Growth Opportunity Type and Buffer as the Downside Protection Type, as "Triple Edge Advantage" or "Dual Direction" Index Account Options in the Policy and in our marketing materials.

Each of the SAI revisions below are effective August 18, 2025.

I. Additional Information About Interim Value Adjustments

On page 7, the following is added to the end of the subsection "Calculating Option Value":

For an Index Account Option with Edge and Edge+ and Buffer, the Option Value can be decomposed into two binary call options and one put option. The binary call options value the potential for Index gains based on the Edge Rate and Edge+ Rate, while the put option values the protection the Buffer provides. The fair value is calculated as:

Fair Value = (in-the-money binary call) * Edge Rate + (at-the-money binary call) * (Edge+ Rate - Edge Rate) - (out-of-the-money put)

On page 7, the following definition is added to the end of the subsection "Derivative Descriptions":

At-the-money binary call: An option granting a fixed payoff if the final Index Value is greater than or equal to the initial Index Value. A payoff of 0 is received if the final Index Value is less than the initial Index Value.

In-the-money binary call: An option granting a fixed payoff if the final Index Value is greater than or equal to the strike price where the strike price is less than the Initial Index Value. A payoff of 0 is received if the final Index Value is less than the strike price.

On page 10, the following is added to the end of the subsection "Additional Examples of Interim Value Adjustments":

4. TRIPLE EDGE ADVANTAGE INDEX ACCOUNT OPTION IN RISING AND FALLING MARKET

These examples are intended to show you Index Account Option values at the end of a one-year Crediting Period assuming a positive Index change or negative Index change less than the Buffer Rate to illustrate when an Edge+ or Edge rate is applied, and a negative Index change in excess of the Buffer Rate to illustrate when a Buffer is applied. These examples assume that you allocate $100,000 to a Triple Edge Advantage Index Account Option with an Edge+ Rate of 15%, Edge Rate of 10% and a Buffer Rate of 10%. They assume there have been no withdrawals. All illustrated values are hypothetical.

Edge+ Edge Buffer
Initial Index Value 1,000 1,000 1,000
Interim Value Index Credit Rate at 6 months 5% 5% 5%
Interim Value at 6 months $100,000.00 * (1 + 5%) = $105,000.00 $100,000.00 * (1 + 5%) = $105,000.00 $100,000.00 * (1 + 5%) = $105,000.00
Final Index Value 1,100 950 800
Index Change (1100 / 1000) - 1 = +10% (950 / 1000) - 1 = -5% (800/1000) - 1 = -20%
Applicable Growth Opportunity Type Rate 15% Edge+ Rate 10% Edge Rate
Growth Opportunity Rate Applied +15% +10%
Applicable Buffer Rate 10%
Buffer Rate Applied -20% + 10% = -10%
Interest Credited

$100,000 * +15% =

+$15,000.00

$100,000 * +10% =

+$10,000.00

$100,000.00 * -10% =

-$10,000.00

Index Account Option Value at the end of a 1-year Crediting Period $100,000.00 + $15,000.00 = $115,000.00 $100,000.00 + $10,000.00 = $110,000.00

$100,000.00 - $10,000.00=

$90,000.00

PART C

OTHER INFORMATION

Item 27. Exhibits

(a) Board of Directors Resolution. Not applicable.
(b) Custodian Agreements. Not applicable.
(c) Underwriting Agreements
(i) Form of Selling Agreement. Note 1.
(ii) Amended and Restated Principal Underwriting Agreement by and between Transamerica Financial Life Insurance Company and Transamerica Capital, Inc. Note 1.
(d) Contracts
(i) Individual Flexible Premium Deferred Index-Linked Annuity Contract. Note 1.
(ii) Guaranteed Minimum Death Benefit Rider. Note 4.
(iii) Dual Direction Index Account Rider. Note 4.
(e) Application. Note 3.
(f) Insurance Company's Certificate of Incorporation and By-Laws
(i) Articles of Incorporation of Transamerica Financial Life Insurance Company. Note 1.
(ii) Bylaws of Transamerica Financial Life Insurance Company. Note 1.
(g) Reinsurance Contracts. Not applicable.
(h) Participation Agreements. Not applicable.
(i) Administrative Contracts. Not applicable.
(j) Other Material Contracts. Not applicable.
(k) Opinion re Legality. Note 5.
(l) Other Opinions
(i)  Consent of Independent Registered Public Accounting Firm. Note 5.
(ii) Consent of Independent Auditors. Note 5.
(m) Omitted Financial Statements. Not Applicable.
(n) Initial Capital Agreements. Not Applicable.
(o) Form of Initial Summary Prospectus. N/A
(p) (i)  Powers of Attorney. Note 5.
(ii) Resolution of the Board of Directors Authorizing the Principal Executive Officer to sign on behalf of Transamerica Financial Life Insurance Company pursuant to power of attorney. Note 3.
(q) Letter re Change in Auditor. Note 2.
(r) Historical Limits on Index Gains. Note 3.
Note 1. Incorporated herein by reference from Initial Filing of S-1 Registration Statement (File no. 333- 281598) filed on August 16, 2024.
Note 2. Incorporated herein by reference from Pre-Effective Amendment No. 1 to S-1 Registration Statement (File no. 333-281598) filed November 4, 2024.
Note 3. Incorporated herein by reference from Post-Effective Amendment No 1. of N-4 Registration Statement (File no. 333-281598) filed on April 28, 2025.
Note 4. Incorporated herein by reference from Post-Effective Amendment No 2. of N-4 Registration Statement (File no. 333-281598) filed on May 15, 2025.
Note 5. Filed Herewith

Item 28. Directors and Officers of the Insurance Company (Transamerica Financial Life Insurance Company)

Name and Principal Business Address Positions and Offices with Insurance Company

Jamie Ohl

1801 California St. Suite 5200

Denver, CO 80202

Director and President

Bonnie T. Gerst

6400 C Street SW

Cedar Rapids, Iowa 52404

Director, Chairman of the Board and Senior Vice President, Financial Assets

Maurice Perkins

100 Light Street

Baltimore, MD 21202

Director and Chief Corporate Affairs Officer

Andrew S. Williams

100 Light Street

Baltimore, MD 21202

Director, General Counsel, Secretary and Senior Vice President

Matt Keppler

100 Light Street

Baltimore, MD 21202

Chief Financial Officer, Executive Vice President and Treasurer

Chris Giovanni

100 Light Street

Baltimore, MD 21202

Director, Chief Strategy & Development Officer and Senior Vice President
Wendy E. Cooper Director
249 East 93rd Street
New York, NY 10128
Anne C. Kronenberg Director
187 Guard Hill Road
Bedford Corner, NY 10549
June Yuson Director
245 East 93rd Street
New York, NY 10128

Item 29. Persons Controlled by or under Common Control with the Insurance Company

As of December 31, 2024, the following pages shows all corporations directly or indirectly controlled or under common control, with the Depositor, showing the state or other sovereign power under the laws of which each is organized and the percentage owner ship of voting securities giving rise to the control relationship.

Aegon Ltd. Subsidiaries Under Common Control (as of 12/31/24)
Company Name

 Immediate Parent 

Ownership %

Parent State/Country
239 West 20th Street, LLC 100% Yarra Rapids, LLC DE, USA
25 East 38th Street, LLC 100% Yarra Rapids, LLC DE, USA
313 East 95th Street, LLC 100% Yarra Rapids, LLC DE, USA
319 East 95th Street, LLC 100% Yarra Rapids, LLC DE, USA
Administrative Group, LLC 100% AUSA Holding, LLC IA, USA
ADMS Global Services (Thailand) Limited 47.37% AEGON DMS Holding B.V. Thailand
AEGON Administracion y Servicios Aie Other Manner of Control Aegon Iberia Holding BV, Sucursal en España Spain
AEGON Administracion y Servicios Aie 100% AEGON España, S.A.U. de Seguros y Reaseguros Spain
AEGON Administracion y Servicios Aie Other Manner of Control Aegon Mediacion S.L.U. Spain
AEGON Administracion y Servicios Aie Other Manner of Control SANTANDER GENERALES SEGUROS Y REASEGUROS, S.A. Spain
AEGON Administracion y Servicios Aie Other Manner of Control SANTANDER VIDA SEGUROS Y REASEGUROS, S.A. Spain
AEGON Administracion y Servicios Aie Other Manner of Control Serenitas, S.L.U. Spain
AEGON Administracion y Servicios Aie Other Manner of Control AEGON SANTANDER PORTUGAL NÃO VIDA -COMPANHIA DE SEGUROS S.A. Spain
AEGON Administracion y Servicios Aie Other Manner of Control AEGON SANTANDER PORTUGAL VIDA -COMPANHIA DE SEGUROS DE VIDA S.A. Spain
AEGON Affordable Housing Debt Fund I, LLC Other Manner of Control AHDF Manager I, LLC DE, USA
AEGON Affordable Housing Debt Fund I, LLC 5% Transamerica Life Insurance Company DE, USA
AEGON AM Funds, LLC 100% AEGON USA Investment Management, LLC DE, USA
Aegon AM Private Equity Partners I, LLC 100% AEGON USA Investment Management, LLC DE, USA

Aegon AM Private Equity Partners II, LLC

100% AEGON USA Investment Management, LLC DE, USA

AEGON Asia B.V.

100% AEGON International B.V. Netherlands

Aegon Asset Management (Asia) Limited

100% AEGON Asset Management Holding B.V. Hong Kong

AEGON Asset Management Holding B.V.

100% Aegon Ltd. Netherlands

AEGON Asset Management Hungary B.V.

100% AEGON Asset Management Holding B.V. Netherlands

Aegon Asset Management Limited

100% Aegon Asset Management UK plc United Kingdom

Aegon Asset Management Pan-Europe B.V.

100% AEGON Asset Management Holding B.V. Netherlands

Aegon Asset Management UK Holdings Limited

100% AEGON Asset Management Holding B.V. United Kingdom

Aegon Asset Management UK plc

100% Aegon Asset Management UK Holdings Limited United Kingdom

AEGON Brazil Holding B.V.

100% AEGON International B.V. Netherlands

AEGON Brazil Holding II B.V.

100% AEGON International B.V. Netherlands

AEGON CEE B.V.

100% Aegon Ltd. Netherlands

Aegon Community Investments 50, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 51, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 52, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 53, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 54, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 55, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 56, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 57, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 58, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 59, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 60, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 61, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 62, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 63, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 64, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 65, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 66, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 67, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 68, LLC

100% Transamerica Life Insurance Company DE, USA

Aegon Community Investments 69, LLC

100% Transamerica Life Insurance Company DE, USA

AEGON Corporate Center B.V.

100% Aegon Ltd. Netherlands

AEGON Custody B.V.

100% AEGON Asset Management Holding B.V. Netherlands

AEGON Derivatives N.V.

100% Aegon Ltd. Netherlands

AEGON Digital Investments Holding B.V.

100% Aegon Ltd. Netherlands

AEGON Direct Marketing Services International, LLC

100% AUSA Holding, LLC MD, USA

AEGON Direct Marketing Services Mexico Servicios, S.A. de C.V.

Other Manner of Control AEGON DMS Holding B.V. Mexico

AEGON Direct Marketing Services Mexico Servicios, S.A. de C.V.

100% AEGON Mexico Holding B.V. Mexico

AEGON Direct Marketing Services Mexico, S.A. de C.V.

5.82% AEGON DMS Holding B.V. Mexico

AEGON Direct Marketing Services Mexico, S.A. de C.V.

92.96% AEGON Mexico Holding B.V. Mexico

AEGON Direct Marketing Services, Inc.

100% Transamerica Life Insurance Company MD, USA

AEGON DMS Holding B.V.

100% AEGON International B.V. Netherlands

AEGON EDC Limited

100% Aegon Ltd. United Kingdom

Aegon Employees Netherlands B.V.

100% AEGON Europe Holding B.V. Netherlands

Aegon Energy Management, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AEGON España, S.A.U. de Seguros y Reaseguros

100% Aegon Iberia Holding BV, Sucursal en España Spain

AEGON Europe Holding B.V.

100% Aegon Ltd. Netherlands

AEGON Financial Services Group, Inc.

100% Transamerica Life Insurance Company MN, USA

AEGON Funding Company LLC

100% Transamerica Corporation DE, USA

Aegon Global Services, LLC

100% Commonwealth General Corporation IA, USA

AEGON Growth Capital Fund I C.V.

100% AEGON Growth Capital Fund I GP B.V. Netherlands

AEGON Growth Capital Fund I GP B.V.

100% AEGON Digital Investments Holding B.V. Netherlands

AEGON Growth Capital Management B.V.

100% Aegon Ltd. Netherlands

AEGON Iberia Holding B.V.

100% Aegon Ltd. Netherlands

Aegon Iberia Holding BV, Sucursal en España

100% AEGON Iberia Holding B.V. Spain

AEGON India Holding B.V.

100% AEGON International B.V. Netherlands

Aegon Insights (Thailand) Limited

Other Manner of Control Aegon Insights Limited Thailand

Aegon Insights (Thailand) Limited

100% Transamerica International Direct Marketing Consultants, LLC Thailand

Aegon Insights Australia Pty Limited

100% Transamerica Direct Marketing Asia Pacific Pty. Ltd. Australia

Aegon Insights Limited

100% AEGON DMS Holding B.V. Hong Kong

AEGON Institutional Markets, Inc.

100% Commonwealth General Corporation DE, USA

AEGON International B.V.

100% Aegon Ltd. Netherlands

AEGON Investment Management B.V.

100% AEGON Asset Management Holding B.V. Netherlands

AEGON Investment Solutions - Nominee 1 (Gross) Ltd.

100% AEGON UK plc United Kingdom

AEGON Investment Solutions - Nominee 2 (Net) Ltd.

100% AEGON UK plc United Kingdom

AEGON Investment Solutions - Nominee 3 (ISA) Ltd.

100% AEGON UK plc United Kingdom

AEGON Investment Solutions Ltd.

100% Aegon UK Investment Holdings Limited United Kingdom

Aegon Investments Limited

100% Aegon UK Investment Holdings Limited United Kingdom

Aegon LIHTC Fund 50, LLC

51.01% Aegon LIHTC Fund 63, LLC DE, USA

Aegon LIHTC Fund 51, LLC

0.01% Aegon Community Investments 51, LLC DE, USA

Aegon LIHTC Fund 52, LLC

0.01% Aegon Community Investments 52, LLC DE, USA

Aegon LIHTC Fund 52, LLC

1% Transamerica Life Insurance Company DE, USA

Aegon LIHTC Fund 52, LLC

10.81% Transamerica Financial Life Insurance Company DE, USA

Aegon LIHTC Fund 54, LLC

Other Manner of Control Aegon Community Investments 54, LLC DE, USA

Aegon LIHTC Fund 55, LLC

2.82% Transamerica Life Insurance Company DE, USA

Aegon LIHTC Fund 57, LLC

0.01% Aegon Community Investments 57, LLC DE, USA

Aegon LIHTC Fund 58, LLC

0.01% Aegon Community Investments 58, LLC DE, USA

Aegon LIHTC Fund 58, LLC

2.92% Transamerica Life Insurance Company DE, USA

Aegon LIHTC Fund 60, LLC

Other Manner of Control Aegon Community Investments 60, LLC DE, USA

Aegon LIHTC Fund 62, LLC

0.01% Aegon Community Investments 62, LLC DE, USA

Aegon LIHTC Fund 63, LLC

Other Manner of Control Aegon Community Investments 63, LLC DE, USA

Aegon LIHTC Fund 64, LLC

Other Manner of Control Aegon Community Investments 64, LLC DE, USA

Aegon LIHTC Fund 65, LLC

0.01% Aegon Community Investments 65, LLC DE, USA

Aegon LIHTC Fund 66, LLC

0.01% Aegon Community Investments 66, LLC DE, USA

Aegon LIHTC Fund 67, LLC

Other Manner of Control Aegon Community Investments 67, LLC DE, USA

Aegon LIHTC Fund 68, LLC

100% Aegon Community Investments 68, LLC DE, USA

Aegon LIHTC Fund 69, LLC

100% Aegon Community Investments 69, LLC DE, USA

AEGON Managed Enhanced Cash, LLC

62.09% Transamerica Life Insurance Company DE, USA

AEGON Managed Enhanced Cash, LLC

37.90% Transamerica Life Insurance Company DE, USA

AEGON Management Company

100% Transamerica Corporation IN, USA

Aegon Mediacion S.L.U.

100% AEGON España, S.A.U. de Seguros y Reaseguros Spain

AEGON Mexico Holding B.V.

100% AEGON DMS Holding B.V. Netherlands

Aegon Opportunity Zone Fund Joint Venture 1, LP

0.16% Aegon OZF Investments 1, LLC DE, USA

Aegon OZF Investments 1, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AEGON Pension Trustee Limited

100% AEGON UK plc United Kingdom

AEGON SANTANDER PORTUGAL NÃO VIDA -COMPANHIA DE SEGUROS S.A.

51% AEGON Iberia Holding B.V. Portugal

AEGON SANTANDER PORTUGAL VIDA -COMPANHIA DE SEGUROS DE VIDA S.A.

51% AEGON Iberia Holding B.V. Portugal

AEGON SIPP GUARANTEE NOMINEE LIMITED

100% AEGON UK plc United Kingdom

Aegon SIPP Nominee 2 Ltd.

100% AEGON UK plc United Kingdom

AEGON SIPP Nominee Ltd.

100% AEGON UK plc United Kingdom

AEGON Taiwan Holding B.V.

100% AEGON International B.V. Netherlands

Aegon THTF Life Insurance Co., Ltd.

50% AEGON International B.V. China

AEGON Treasury Investments B.V.

100% Aegon Ltd. Netherlands

AEGON UK Corporate Services Limited

100% AEGON UK plc United Kingdom

Aegon UK Investment Holdings Limited

100% AEGON UK plc United Kingdom

AEGON UK plc

100% AEGON Europe Holding B.V. United Kingdom

AEGON UK Property Fund Limited

100% AEGON UK plc United Kingdom

Aegon Upstream Energy Fund, LLC

100% Aegon Energy Management, LLC DE, USA

AEGON USA Asset Management Holding, LLC

100% AUSA Holding, LLC IA, USA

AEGON USA Investment Management, LLC

100% AEGON USA Asset Management Holding, LLC IA, USA

AEGON USA Real Estate Services, Inc.

100% AEGON USA Realty Advisors, LLC DE, USA

AEGON USA Realty Advisors of California, Inc.

100% AEGON USA Realty Advisors, LLC IA, USA

AEGON USA Realty Advisors, LLC

100% AEGON USA Asset Management Holding, LLC IA, USA

Aegon Workforce Housing Fund 2 Holding Company B, LLC

100% Aegon Workforce Housing Fund 2, L.P DE, USA

Aegon Workforce Housing Fund 2 Holding Company C, LLC

100% Aegon Workforce Housing Fund 2, L.P DE, USA

Aegon Workforce Housing Fund 2 Holding Company, LLC

100% Aegon Workforce Housing Fund 2, L.P DE, USA

Aegon Workforce Housing Fund 2, L.P

80% Transamerica Life Insurance Company DE, USA

Aegon Workforce Housing Fund 2, L.P

20% Transamerica Financial Life Insurance Company DE, USA

Aegon Workforce Housing Fund 3 Holding Company, LLC

100% Aegon Workforce Housing Fund 3, L.P DE, USA

Aegon Workforce Housing Fund 3, L.P

60% Transamerica Life Insurance Company DE, USA

Aegon Workforce Housing Fund 3, L.P

30% Transamerica Life Insurance Company DE, USA

Aegon Workforce Housing Fund 3, L.P

10% Transamerica Financial Life Insurance Company DE, USA

Aegon Workforce Housing JV 4A, LLC

44.50% Aegon Workforce Housing Fund 2 Holding Company, LLC DE, USA

Aegon Workforce Housing JV 4B, LLC

25% Aegon Workforce Housing Fund 2 Holding Company, LLC DE, USA

Aegon Workforce Housing JV 4C, LLC

10% Aegon Workforce Housing Fund 2 Holding Company, LLC DE, USA

Aegon Workforce Housing Park at Via Rosa REIT, LLC

100% Aegon Workforce Housing Separate Account 1, LLC IA, USA

Aegon Workforce Housing Separate Account 1, LLC

15.83% Transamerica Life Insurance Company IA, USA

Aegon Workforce Housing Separate Account 1, LLC

4.17% Transamerica Life Insurance Company IA, USA

Aegon Workforce Housing Separate Account 1, LLC

5% Transamerica Financial Life Insurance Company IA, USA

AEGON-INDUSTRIAL Capital Management (Shanghai) Co., Ltd.

100% AEGON-INDUSTRIAL Fund Management Co., LTD. China

AEGON-INDUSTRIAL Fund Management Co., LTD.

49% AEGON International B.V. China

AGT Hungary IT Service Korlátolt Felelősségű Társaság

100% AEGON EDC Limited Hungary

AHDF Manager I, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

ALH Properties Eight LLC

100% FGH USA LLC DE, USA

ALH Properties Eleven LLC

100% FGH USA LLC DE, USA

ALH Properties Four LLC

100% FGH USA LLC DE, USA

ALH Properties Nine LLC

100% FGH USA LLC DE, USA

ALH Properties Seven LLC

100% FGH USA LLC DE, USA

ALH Properties Seventeen LLC

100% FGH USA LLC DE, USA

ALH Properties Sixteen LLC

100% FGH USA LLC DE, USA

ALH Properties Ten LLC

100% FGH USA LLC DE, USA

ALH Properties Twelve LLC

100% FGH USA LLC DE, USA

ALH Properties Two LLC

100% FGH USA LLC DE, USA

AMFETF Manager, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AMTAX Holdings 308 LLC

100% TAHP Fund 2, LLC OH, USA

AMTAX Holdings 388 LLC

100% TAHP Fund 2, LLC OH, USA

AMTAX Holdings 483 LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 559, LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 561 LLC

100% TAHP Fund VII, LLC OH, USA

AMTAX Holdings 588 LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 613 LLC

0.15% Cupples State LIHTC Investors, LLC OH, USA

AMTAX Holdings 613 LLC

99.85% Garnet LIHTC Fund VII, LLC OH, USA

AMTAX Holdings 639 LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 649 LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 672 LLC

100% TAHP Fund 1, LLC OH, USA

AMTAX Holdings 713 LLC

100% TAHP Fund 2, LLC OH, USA

Andrews Nominees Limited

100% Cofunds Limited United Kingdom

Apollo Housing Capital Arrowhead Gardens, L.L.C.

100% Garnet LIHTC Fund XXXV, LLC DE, USA

APOP III, LLC

9.84% Transamerica Financial Life Insurance Company DE, USA

APOP III, LLC

88.60% Transamerica Life Insurance Company DE, USA

ASR Nederland N.V.

29.99% Aegon Ltd. Bermuda

AUSA Holding, LLC

100% Transamerica Corporation MD, USA

AUSA Properties, Inc.

100% AEGON USA Realty Advisors, LLC IA, USA

AWHF2 General Partner, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AWHF2 Subsidiary Holding Company C, LLC

100% Aegon Workforce Housing Fund 2 Holding Company C, LLC DE, USA

AWHF3 General Partner, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AWHJV4 Manager, LLC

100% AEGON USA Realty Advisors, LLC DE, USA

AWHSA Manager 1, LLC

100% AEGON USA Realty Advisors, LLC IA, USA

Barfield Ranch Associates, LLC

50% Mitigation Manager LLC FL, USA

Carle Place Leasehold SPE, LLC

100% Transamerica Financial Life Insurance Company DE, USA

Cofunds Limited

100% Aegon UK Investment Holdings Limited United Kingdom

Cofunds Nominees Ltd

100% Cofunds Limited United Kingdom

Commonwealth General Corporation

100% Transamerica Corporation DE, USA

Coöperatieve AEGON Financieringsmaatschappij U.A.

1.51% AEGON International B.V. Netherlands

Coöperatieve AEGON Financieringsmaatschappij U.A.

98.49% Aegon Ltd. Netherlands

Cornerstone International Holdings Ltd.

100% AEGON DMS Holding B.V. United Kingdom

Creditor Resources, Inc.

100% AUSA Holding, LLC MI, USA

CRI Solutions, Inc.

100% Creditor Resources, Inc. MD, USA

Cupples State LIHTC Investors, LLC

22% Transamerica Life Insurance Company DE, USA

Cupples State LIHTC Investors, LLC

15% Transamerica Life Insurance Company DE, USA

Cupples State LIHTC Investors, LLC

63% Transamerica Life Insurance Company DE, USA

Dorset Nominees Limited

100% Cofunds Limited United Kingdom

Equitable AgriFinance, LLC

50% AEGON USA Realty Advisors, LLC DE, USA

Favela Promoção e Vendas Ltda.

100% Mongeral AEGON Holding Ltda. Brazil

FGH Realty Credit LLC

100% FGH USA LLC DE, USA

FGH USA LLC

100% RCC North America LLC DE, USA

Fifth FGP LLC

100% FGH USA LLC DE, USA

Financial Planning Services, Inc.

100% Commonwealth General Corporation D.C., USA

FINANCIERE DE L'ECHIQUIER

100% La Banque Postale Asset Management France

First FGP LLC

100% FGH USA LLC DE, USA

Fourth FGP LLC

100% FGH USA LLC DE, USA

Garnet Assurance Corporation

100% Transamerica Life Insurance Company KY, USA

Garnet Assurance Corporation II

100% Commonwealth General Corporation IA, USA

Garnet Assurance Corporation III

100% Transamerica Life Insurance Company IA, USA

Garnet Community Investments IX, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments V, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments VI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments VII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments VIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments X, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XL, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLIV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLIX, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLVI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLVII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XLVIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XVIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XX, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXIV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXIX, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXVI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXVII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXVIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXIV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXIX, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXV, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXVI, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXVII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet Community Investments XXXVIII, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet Community Investments, LLC

100% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund IX, LLC

99.99% Garnet Community Investments IX, LLC DE, USA

Garnet LIHTC Fund IX, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund V, LLC

99.99% Garnet Community Investments V, LLC DE, USA

Garnet LIHTC Fund V, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund VI, LLC

99.99% Garnet Community Investments VI, LLC DE, USA

Garnet LIHTC Fund VI, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund VII, LLC

99.99% Garnet Community Investments VII, LLC DE, USA

Garnet LIHTC Fund VII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund VIII, LLC

99.99% Garnet Community Investments VIII, LLC DE, USA

Garnet LIHTC Fund VIII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund X, LLC

0.01% Garnet Community Investments X, LLC DE, USA

Garnet LIHTC Fund XI, LLC

99.99% Garnet Community Investments XI, LLC DE, USA

Garnet LIHTC Fund XI, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XII, LLC

0.01% Garnet Community Investments XII, LLC DE, USA

Garnet LIHTC Fund XII, LLC

73.39% Garnet LIHTC Fund XII-A, LLC DE, USA

Garnet LIHTC Fund XII, LLC

13.30% Garnet LIHTC Fund XII-B, LLC DE, USA

Garnet LIHTC Fund XII, LLC

13.30% Garnet LIHTC Fund XII-C, LLC DE, USA

Garnet LIHTC Fund XII-A, LLC

99.99% Garnet Community Investments XII, LLC DE, USA

Garnet LIHTC Fund XII-A, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XII-B, LLC

99.99% Garnet Community Investments XII, LLC DE, USA

Garnet LIHTC Fund XII-B, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XII-C, LLC

99.99% Garnet Community Investments XII, LLC DE, USA

Garnet LIHTC Fund XII-C, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XIII, LLC

0.01% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XIII, LLC

68.10% Garnet LIHTC Fund XIII-A, LLC DE, USA

Garnet LIHTC Fund XIII, LLC

31.89% Garnet LIHTC Fund XIII-B, LLC DE, USA

Garnet LIHTC Fund XIII-A, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XIII-A, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XIII-B, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XIII-B, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XIV, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XIV, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XIX, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XIX, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XL, LLC

0.01% Garnet Community Investments XL, LLC DE, USA

Garnet LIHTC Fund XLI, LLC

0.01% Garnet Community Investments XLI, LLC DE, USA

Garnet LIHTC Fund XLI, LLC

10% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XLII, LLC

0.01% Garnet Community Investments XLII, LLC DE, USA

Garnet LIHTC Fund XLIV-A, LLC

Other Manner of

Control

Garnet Community Investments XLIV, LLC DE, USA

Garnet LIHTC Fund XLIV-B, LLC

Other Manner of

Control

Garnet Community Investments XLIV, LLC DE, USA

Garnet LIHTC Fund XLVI, LLC

Other Manner of

Control

Garnet Community Investments XLVI, LLC DE, USA

Garnet LIHTC Fund XLVII, LLC

1% Garnet Community Investments XLVII, LLC DE, USA

Garnet LIHTC Fund XLVII, LLC

13.99% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XLVIII, LLC

0.01% Garnet Community Investments XLVIII, LLC DE, USA

Garnet LIHTC Fund XLVIII, LLC

75.18% Transamerica Financial Life Insurance Company DE, USA

Garnet LIHTC Fund XV, LLC

0.01% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XV, LLC

99.99% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XVI, LLC

0.01% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XVII, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XVII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XVIII, LLC

0.01% Garnet Community Investments XVIII, LLC DE, USA

Garnet LIHTC Fund XX, LLC

100% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XXII, LLC

0.01% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XXIII, LLC

99.99% Garnet Community Investments, LLC DE, USA

Garnet LIHTC Fund XXIII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXIV, LLC

0.01% Garnet Community Investments XXIV, LLC DE, USA

Garnet LIHTC Fund XXIV, LLC

21.26% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXIX, LLC

0.01% Garnet Community Investments XXIX, LLC DE, USA

Garnet LIHTC Fund XXV, LLC

0.01% Garnet Community Investments XXV, LLC DE, USA

Garnet LIHTC Fund XXV, LLC

1% Garnet LIHTC Fund XXVIII, LLC DE, USA

Garnet LIHTC Fund XXVI, LLC

0.01% Garnet Community Investments XXVI, LLC DE, USA

Garnet LIHTC Fund XXVII, LLC

0.01% Garnet Community Investments XXVII, LLC DE, USA

Garnet LIHTC Fund XXVII, LLC

16.71% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXVIII, LLC

99.99% Garnet Community Investments XXVIII, LLC DE, USA

Garnet LIHTC Fund XXVIII, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXXI, LLC

0.01% Garnet Community Investments XXXI, LLC DE, USA

Garnet LIHTC Fund XXXII, LLC

0.01% Garnet Community Investments XXXII, LLC DE, USA

Garnet LIHTC Fund XXXIII, LLC

0.01% Garnet Community Investments XXXIII, LLC DE, USA

Garnet LIHTC Fund XXXIV, LLC

99.99% Garnet Community Investments XXXIV, LLC DE, USA

Garnet LIHTC Fund XXXIV, LLC

0.01% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXXIX, LLC

1% Garnet Community Investments XXXIX, LLC DE, USA

Garnet LIHTC Fund XXXV, LLC

0.01% Garnet Community Investments XXXV, LLC DE, USA

Garnet LIHTC Fund XXXVI, LLC

1% Garnet Community Investments XXXVI, LLC DE, USA

Garnet LIHTC Fund XXXVII, LLC

0.01% Garnet Community Investments XXXVII, LLC DE, USA

Garnet LIHTC Fund XXXVII, LLC

99.99% Transamerica Life Insurance Company DE, USA

Garnet LIHTC Fund XXXVIII, LLC

Other Manner of

Control

Garnet Community Investments XXXVIII, LLC DE, USA

GoBear (Philippines) Inc.

100% Woodpecker Asia Tech PTE Ltd. Philippines

GoBear (Vietnam) Co., Ltd.

100% Woodpecker Asia Tech PTE Ltd. Vietnam

Hague Reinsurance Management N.V.

100% AEGON Digital Investments Holding B.V. Netherlands

Horizons Acquisition 5, LLC

100% PSL Acquisitions Operating, LLC FL, USA

Horizons St. Lucie Development, LLC

100% PSL Acquisitions Operating, LLC FL, USA

Hubei Xinhuaxin Insurance Sales Company Limited

12.40% AEGON International B.V. China

Imani FE, L.P.

Other Manner of

Control

TAH Imani Fe GP, LLC CA, USA

Imani FE, L.P.

99.99% Garnet LIHTC Fund XIV, LLC CA, USA

Investors Warranty of America, LLC

100% RCC North America LLC IA, USA

Ironwood Re Corp.

100% Commonwealth General Corporation HI, USA

IZNES SAS

4.31% La Banque Postale Asset Management France

Kognita Lab S.A.

8.74% Mongeral AEGON Holding Ltda. Brazil

La Banque Postale Asset Management

25% AEGON Asset Management Holding B.V. France

La Banque Postale Asset Management

75% La Banque Postale Asset Management France

LBPAM Private Debt GP Lux SARL

100% La Banque Postale Asset Management Luxembourg

LCS Associates, LLC

100% RCC North America LLC DE, USA

Life Investors Alliance LLC

100% Transamerica Life Insurance Company DE, USA

LIHTC Fund 53, LLC

Other Manner of

Control

Aegon Community Investments 53, LLC DE, USA

LIHTC Fund 56, LLC

Other Manner of

Control

Aegon Community Investments 56, LLC DE, USA

LIHTC Fund 59, LLC

Other Manner of

Control

Aegon Community Investments 56, LLC DE, USA

LIHTC Fund XLIX, LLC

Other Manner of

Control

Garnet Community Investments XLIX, LLC DE, USA

LIHTC Fund XLV, LLC

Other Manner of

Control

Garnet Community Investments XLV, LLC DE, USA

LIICA Re II, Inc.

100% Transamerica Life Insurance Company VT, USA

Lochside Nominees Limited

100% Cofunds Limited United Kingdom

Longevity Services Consultoria e Serviços Ltda.

100% Mongeral AEGON Holding Ltda. Brazil

MAG Consultoria de Investimentos Ltda.

100% Mongeral AEGON Holding Ltda. Brazil

MAG Instituição de Pagamento Ltda.

100% Mongeral Aegon Holding Financeira Brazil

MAG Tanure Holding Participações S.A.

50% Mongeral AEGON Holding Ltda. Belo Horizonte, Minas Gerais

Minster Nominees Limited

100% Cofunds Limited United Kingdom

Mitigation Manager LLC

100% RCC North America LLC DE, USA

Momentum Group Limited

100% Aegon UK Investment Holdings Limited United Kingdom

Money Services, Inc.

100% AUSA Holding, LLC DE, USA

Mongeral Aegon Administração de Benefícios LTDA.

100% Mongeral AEGON Holding Ltda. Brazil

Mongeral Aegon Capitalização S.A.

100% Mongeral AEGON Seguros e Previdência SA Brazil

Mongeral Aegon Gestão de Fundos Imobiliários Ltda

20% Mongeral AEGON Investimentos Ltda. Brazil

Mongeral Aegon Holding Financeira

100% Mongeral AEGON Holding Ltda. Brazil

Mongeral AEGON Holding Ltda.

50% AEGON Brazil Holding II B.V. Brazil

Mongeral AEGON Investimentos Ltda.

100% Mongeral AEGON Holding Ltda. Brazil

Mongeral Aegon Renda Variavel Ltda

100% Mongeral AEGON Investimentos Ltda. Brazil

Mongeral AEGON Seguros e Previdência SA

50% AEGON Brazil Holding B.V. Brazil

Monumental General Administrators, Inc.

100% AUSA Holding, LLC MD, USA

MT ADMINISTRADORA E CORRETORA DE SEGUROS LTDA

90% Mongeral AEGON Holding Ltda. Brazil

Natural Resources Alternatives Portfolio 3, LLC

85% Transamerica Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio 3, LLC

15% Transamerica Financial Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio I, LLC

32% Transamerica Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio I, LLC

64% Transamerica Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio I, LLC

4% Transamerica Financial Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio II, LLC

35% Transamerica Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio II, LLC

60% Transamerica Life Insurance Company DE, USA

Natural Resources Alternatives Portfolio II, LLC

5% Transamerica Financial Life Insurance Company DE, USA

NEWCAST PROPERTY DEVELOPMENTS (ONE) LIMITED

100% AEGON UK Property Fund Limited United Kingdom

NEWCAST PROPERTY DEVELOPMENTS (TWO) LIMITED

100% AEGON UK Property Fund Limited United Kingdom

Nomagon Title Grandparent, LLC

100% AEGON USA Asset Management Holding, LLC DE, USA

Nomagon Title Holding 1, LLC

100% Nomagon Title Parent, LLC DE, USA

Nomagon Title Parent, LLC

100% Nomagon Title Grandparent, LLC DE, USA

North Westerly Holding B.V.

100% AEGON Asset Management Holding B.V. Netherlands

Origen Financial Services Limited

100% Momentum Group Limited United Kingdom

Origen Limited

100% Momentum Group Limited United Kingdom

Origen Trustee Services Limited

100% Momentum Group Limited United Kingdom

Osceola Mitigation Partners, LLC

50% Mitigation Manager LLC FL, USA

Pearl Holdings, Inc. I

100% AEGON USA Asset Management Holding, LLC DE, USA

Pearl Holdings, Inc. II

100% AEGON USA Asset Management Holding, LLC DE, USA

Pension Geeks Limited

100% AEGON UK plc United Kingdom

Peoples Benefit Services, LLC

100% Transamerica Life Insurance Company PA, USA

Phinance Spółka Akcyjna

44% AEGON Growth Capital Fund I GP B.V. Poland

Placer 400 Investors, LLC

50% RCC North America LLC CA, USA

PSL Acquisitions Operating, LLC

100% RCC North America LLC IA, USA

PT Futuready Insurance Broker

80% AEGON DMS Holding B.V. Indonesia

PT. Aegon Insights Indonesia

0.84% Aegon Insights Limited Indonesia

PT. Aegon Insights Indonesia

99.16% AEGON DMS Holding B.V. Indonesia

RCC North America LLC

100% Transamerica Corporation DE, USA

Real Estate Alternatives Portfolio 2, L.L.C.

2.25% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 2, L.L.C.

30.75% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 2, L.L.C.

22.25% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 2, L.L.C.

37.25% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 2, L.L.C.

7.50% Transamerica Financial Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 3, L.L.C.

1% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 3, L.L.C.

25.60% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 3, L.L.C.

73.40% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 3A, Inc.

90.60% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 3A, Inc.

9.40% Transamerica Financial Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 HR, LLC

32% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 HR, LLC

64% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 HR, LLC

4% Transamerica Financial Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 MR, LLC

64% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 MR, LLC

32% Transamerica Life Insurance Company DE, USA

Real Estate Alternatives Portfolio 4 MR, LLC

4% Transamerica Financial Life Insurance Company DE, USA

River Ridge Insurance Company

100% AEGON Management Company VT, USA

Rock Springs Drive, LLC

98% Investors Warranty of America, LLC MD, USA

SANTANDER GENERALES SEGUROS Y REASEGUROS, S.A.

51% AEGON España, S.A.U. de Seguros y Reaseguros Spain

SANTANDER VIDA SEGUROS Y REASEGUROS, S.A.

51% AEGON España, S.A.U. de Seguros y Reaseguros Spain

Scottish Equitable (Managed Funds) Limited

Other Manner of Control Scottish Equitable Holdings Limited United Kingdom

Scottish Equitable (Managed Funds) Limited

100% Scottish Equitable plc United Kingdom

Scottish Equitable Holdings Limited

100% AEGON UK plc United Kingdom

Scottish Equitable plc

100% Scottish Equitable Holdings Limited United Kingdom

Scottish Equitable plc

Other Manner of Control AEGON UK plc United Kingdom

Second FGP LLC

100% FGH USA LLC DE, USA

Serenitas, S.L.U.

100% Aegon Iberia Holding BV, Sucursal en España Spain

Seventh FGP LLC

100% FGH USA LLC DE, USA

Sicoob Seguradora de Vida e Previdência S.A.

50% Mongeral AEGON Seguros e Previdência SA Brazil

Simple2u Seguros S.A.

100% Mongeral AEGON Seguros e Previdência SA Brazil

St. Lucie West Development Company, LLC

100% PSL Acquisitions Operating, LLC FL, USA

Stonebridge Benefit Services, Inc.

100% Commonwealth General Corporation DE, USA

TA Private Equity Assets, LLC

100% Transamerica Life Insurance Company DE, USA

TA-APOP I, LLC

100% Transamerica Life Insurance Company DE, USA

TA-APOP I-A, LLC

90% Transamerica Life Insurance Company DE, USA

TA-APOP I-A, LLC

10% Transamerica Financial Life Insurance Company DE, USA

TA-APOP II, LLC

73.19% Transamerica Life Insurance Company DE, USA

TA-APOP II, LLC

24.40% Transamerica Financial Life Insurance Company DE, USA

TABR Realty Services, LLC

100% AUSA Holding, LLC DE, USA

TAH Imani Fe GP, LLC

100% Garnet Assurance Corporation CA, USA

TAH Pentagon Funds, LLC

100% Transamerica Affordable Housing, Inc. IA, USA

TAHP Fund 1, LLC

100% Garnet LIHTC Fund IX, LLC DE, USA

TAHP Fund 2, LLC

100% Garnet LIHTC Fund VIII, LLC DE, USA

TAHP Fund VII, LLC

100% Garnet LIHTC Fund XIX, LLC DE, USA

TAH-Solar SLP, LLC

100% Transamerica Affordable Housing, Inc. IA, USA

Tenet Group Limited (Minority Shareholding)

23.27% AEGON UK plc United Kingdom

THH Acquisitions, LLC

100% Transamerica Life Insurance Company IA, USA

TLIC Oakbrook Reinsurance Inc.

100% Transamerica Life Insurance Company IA, USA

TLIC Watertree Reinsurance Inc.

100% Transamerica Life Insurance Company IA, USA

Tradition Development Company, LLC

100% PSL Acquisitions Operating, LLC FL, USA

Tradition Land Company, LLC

100% RCC North America LLC IA, USA

Transamerica (Bermuda) Services Center, Ltd.

100% AEGON International B.V. Bermuda

Transamerica Affordable Housing, Inc.

100% TABR Realty Services, LLC CA, USA

Transamerica Agency Network, LLC

100% AUSA Holding, LLC IA, USA

Transamerica Asset Holding, LLC

100% AUSA Holding, LLC DE, USA

Transamerica Asset Management, Inc.

23% AUSA Holding, LLC CO, USA

Transamerica Asset Management, Inc.

77% Transamerica Life Insurance Company CO, USA

Transamerica Bermuda Re, Ltd.

100% Transamerica Life Insurance Company Bermuda

Transamerica Capital, LLC

100% AUSA Holding, LLC CO, USA

Transamerica Casualty Insurance Company

100% Transamerica Corporation IA, USA

Transamerica Corporation

100% AEGON International B.V. DE, USA

Transamerica Corporation

100% Transamerica Corporation OR, USA

Transamerica Direct Marketing Asia Pacific Pty. Ltd.

100% AEGON DMS Holding B.V. Australia

Transamerica Direct Marketing Consultants Private Limited

100% AEGON DMS Holding B.V. India

Transamerica Finance Corporation

100% Transamerica Corporation DE, USA

Transamerica Financial Advisors, LLC

100% AUSA Holding, LLC DE, USA

Transamerica Financial Life Insurance Company

100% Transamerica Corporation NY, USA

Transamerica Fund Services, Inc.

55.87% AUSA Holding, LLC CO, USA

Transamerica Fund Services, Inc.

44.13% Transamerica Life Insurance Company CO, USA

Transamerica Health Savings Solutions, LLC

100% Transamerica Retirement Solutions, LLC DE, USA

Transamerica Insurance Marketing Asia Pacific Pty. Ltd.

100% Transamerica Direct Marketing Asia Pacific Pty. Ltd. Australia

Transamerica International Direct Marketing Consultants, LLC

49% AEGON Direct Marketing Services, Inc. MD, USA

Transamerica Investors Securities, LLC

100% Transamerica Retirement Solutions, LLC DE, USA

Transamerica Life (Bermuda) Ltd.

100% Transamerica Life Insurance Company Bermuda

Transamerica Life Insurance Company

100% Commonwealth General Corporation IA, USA

Transamerica Life International (Bermuda) Ltd

100% AEGON International B.V. Bermuda

Transamerica Pacific Re, Inc.

100% Transamerica Life Insurance Company VT, USA

Transamerica Pyramid Properties, LLC

100% Transamerica Life Insurance Company DE, USA

Transamerica Resources, Inc.

100% Monumental General Administrators, Inc. MD, USA

Transamerica Retirement Advisors, LLC

100% Transamerica Retirement Solutions, LLC DE, USA

Transamerica Retirement Insurance Agency, LLC

100% Transamerica Retirement Solutions, LLC DE, USA

Transamerica Retirement Solutions, LLC

100% AUSA Holding, LLC DE, USA

Transamerica Stable Value Solutions Inc.

100% Commonwealth General Corporation DE, USA

Transamerica Travel and Conference Services, LLC

100% Money Services, Inc. IA, USA

Transamerica Trust Company

100% AUSA Holding, LLC IA, USA

Transamerica Ventures Fund II, LLC

100% AUSA Holding, LLC DE, USA

ULI Funding, LLC

100% AUSA Holding, LLC IA, USA

United Financial Services, Inc.

100% Transamerica Corporation MD, USA

WFG Insurance Agency of Puerto Rico, Inc.

100% World Financial Group Insurance Agency, LLC Puerto Rico

WFG Properties Holdings, LLC

100% World Financial Group, Inc. GA, USA

WFG Securities Inc.

100% World Financial Group Holding Company of Canada Inc. Canada

Winsocial Administradora de Benefícios Ltda.

50.00% AEGON Brazil Holding II B.V. Brazil

Woodpecker Asia Holding I B.V.

100% Woodpecker Holding B.V. Netherlands

Woodpecker Asia Holding II B.V.

100% Woodpecker Holding B.V. Netherlands

Woodpecker Asia Tech PTE Ltd.

100% Woodpecker Holding B.V. Singapore

Woodpecker Holding B.V.

50.00% AEGON International B.V. Netherlands

World Financial Group Holding Company of Canada Inc.

100% Commonwealth General Corporation Canada

World Financial Group Insurance Agency of Canada Inc.

100% World Financial Group Holding Company of Canada Inc. Canada

World Financial Group Insurance Agency of Hawaii, Inc.

100% World Financial Group Insurance Agency, LLC HI, USA

World Financial Group Insurance Agency of Massachusetts, Inc

100% World Financial Group Insurance Agency, LLC MA, USA

World Financial Group Insurance Agency of Wyoming, Inc.

100% World Financial Group Insurance Agency, LLC WY, USA

World Financial Group Insurance Agency, LLC

100% AUSA Holding, LLC CA, USA

World Financial Group, Inc.

100% Transamerica Asset Holding, LLC DE, USA

Yarra Rapids, LLC

49.00% Real Estate Alternatives Portfolio 4 MR, LLC DE, USA

Zahorik Company, Inc.

100% AUSA Holding, LLC CA, USA

Zero Beta Fund, LLC

50.14% Transamerica Life Insurance Company DE, USA

Zero Beta Fund, LLC

33.28% Transamerica Life Insurance Company DE, USA

Zero Beta Fund, LLC

16.58% Transamerica Financial Life Insurance Company DE, USA

Item 30. Indemnification

The New York Code (Sections 721 et. seq.) provides for permissive indemnification in certain situations, mandatory indemnification in other situations, and prohibits indemnification in certain situations. The Code also specifies procedures for determining when indemnification payments can be made.

Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of the Registrant pursuant to the foregoing provisions, or otherwise, the Registrant has been advised that in the opinion of the Securities and Exchange Commission such indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by the Registrant of expenses incurred or paid by a director, officer or controlling person in connection with the securities being registered), the Registrant will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the Act and will be governed by the final adjudication of such issue.

Item 31 Principal Underwriters

(a)

Transamerica Capital, LLC serves as the principal underwriter for the Merrill Lynch Life Variable Annuity Separate Account, Merrill Lynch Life Variable Annuity Separate Account A, Merrill Lynch Life Variable Annuity Separate Account B, Merrill Lynch Life Variable Annuity Separate Account C, Merrill Lynch Life Variable Annuity Separate Account D, Merrill Lynch Variable Life Separate Account, and Merrill Lynch Variable Life Separate Account II, Retirement Builder Variable Annuity Account, Separate Account Fund B, Separate Account Fund C, Separate Account VA AA, Separate Account VA B, Separate Account VA BB, Separate Account VA CC, Separate Account VA DD, Separate Account VA FF, Separate Account VA HH, Separate Account VA Q, Separate Account VA U, Separate Account VA V, Separate Account VA-1, Separate Account VA-2L, Separate Account VA-5, Separate Account VA-6, Separate Account VA-7, Separate Account VA-8, Separate Account VL, Separate Account VL E, Separate Account VUL-A, Separate Account VUL-1; Separate Account VUL-2, Separate Account VUL-3, Separate Account VUL-4, Separate Account VUL-5, Separate Account VUL-6, Transamerica Corporate Separate Account Sixteen, Transamerica Separate Account R3, Variable Life Account A, WRL Series Annuity Account, WRL Series Annuity Account B, WRL Series Life Account, WRL Series Life Account G, and WRL Series Life Corporate Account. These accounts are separate accounts of Transamerica Life Insurance Company.

Transamerica Capital, LLC serves as principal underwriter for ML of New York Variable Annuity Separate Account A, ML of New York Variable Annuity Separate Account B, ML of New York Variable Annuity Separate Account C, ML of New York Variable Annuity Separate Account D, ML of New York Variable Life Separate Account, ML of New York Variable Life Separate Account II, Separate Account VA BNY, Separate Account VA QNY, Separate Account VA-2LNY, Separate Account VA-5NLNY, Separate Account VA-6NY, TFLIC Separate Account B, TFLIC Separate Account C, TFLIC Separate Account VNY, TFLIC Pooled Account No. 44, TFLIC Series Annuity Account, TFLIC Series Life Account, and Transamerica Variable Funds. These accounts are separate accounts of Transamerica Financial Life Insurance Company.

Transamerica Capital, LLC also serves as principal underwriter for Transamerica Series Trust and Transamerica Funds.

(b) Directors and Officers of Transamerica Capital, LLC:

Name Principal Business Address Position and Offices with Underwriter

Brian Beitzel

(2) Manager, Treasurer and Chief Financial Officer

Rob Carney

(3) Manager, Chairman of the Board, Chief Executive Officer and President

Doug Hellerman

(3) Vice President and Chief Compliance Officer

Timothy Ackerman

(3) Manager and Vice President

Mark Halloran

(3) Manager

Jennifer Pearce

(3) Vice President

Daniel Goodman

(1) Secretary

David Cheung

(3) Assistant Secretary

(1) 100 Light Street, Floor B1, Baltimore, MD 21202

(2) 6400 C Street SW, Cedar Rapids, IA 52499-0001

(3) 1801 California Street, Suite 5200, Denver, CO 80202

(c) Compensation to Principal Underwriter:

Name of Principal Underwriter Net Underwriting
Discounts and
Commissions
Compensation on
Redemption
Brokerage
Commissions
Compensation

Transamerica Capital, LLC

$0.00 0.00 0.00 0.00

Item 31A. Information About Contracts with Index-Linked Options and Fixed Options Subject to a Contract Adjustment

(a)
Name of the
Contract
Number of
Contracts
Outstanding
Total Value Attributable
to the Index-Linked
Option and/or Fixed
Option Subject to a
Contract Adjustment
Number of
Contracts Sold
During the
Prior Calendar
Year

Gross

Premiums

Received

During the

Prior

Calendar

Year

Amount of

Contract
Value

Redeemed

During the

Prior
Calendar

Year

Combination
Contract
(Yes/No)
Transamerica Structured Index Advantage® Annuity NY 9 $1,744,756.04 9 $1,445,500.00 $0.00 No
(b)

See Exhibit 27(r).

Item 32. Location of Accounts and Records

Not applicable.

Item 33. Management Services.

All management service contracts, if any, are discussed in Part A or Part B.

Item 34. Undertakings

With regard to Index-Linked Options and/or Fixed Options subject to a Contract Adjustment, the Registrant undertakes:

1.

To file, during any period in which offers or sales are being made, a post-effective amendment to the registration statement to include any prospectus required by section 10(a)(3) of the Securities Act; and

2.

That, for the purpose of determining any liability under the Securities Act, each such post-effective amendment shall be deemed to be a new registration statement relating to the securities offered therein, and the offering of such securities at that time shall be deemed to be the initial bona fide offering thereof.

SIGNATURES

Pursuant to the requirements of the Securities Act of 1933, the registrant certifies that it meets all of the requirements for effectiveness of this registration statement under rule 485(b) under the Securities Act and has duly caused this registration statement to be signed on its behalf by the undersigned, thereunto duly authorized in the City of Dade City, State of Florida, on August 18, 2025.

TRANSAMERICA FINANCIAL LIFE INSURANCE COMPANY

(Registrant)

*

By:

Jamie Ohl

Director and President

(principal executive officer)

Pursuant to the requirements of the Securities Act of 1933, this registration statement has been signed by the following persons in the capacities indicated on August 18, 2025.

Signatures Title

              *

Director and President (principal executive officer)
Jamie Ohl

              *

Director, Chairman of the Board and Senior Vice President, Financial Assets (principal accounting officer)
Bonnie T. Gerst

              *

Director and Chief Corporate Affairs Officer
Maurice Perkins

              *

Director, Secretary, General Counsel and Senior Vice President
Andrew S. Williams

              *

Chief Financial Officer, Executive Vice President and Treasurer (principal financial officer)
Matt Keppler

              *

Director, Chief Strategy & Development Officer and Senior Vice President
Chris Giovanni

              *

Director
Wendy E. Cooper

              *

Director
Anne C. Kronenberg

              *

Director
June Yuson

/s/Brian Stallworth*       

Assistant Secretary
Brian Stallworth

*By: Brian Stallworth - Attorney-in-Fact pursuant to Powers of Attorney filed previously and/or herewith.

Transamerica Financial Life Insurance Co. published this content on August 18, 2025, and is solely responsible for the information contained herein. Distributed via EDGAR on August 18, 2025 at 18:43 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]