Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: This article discusses a number of product variations seen in the market with respect to Universal Life products with secondary death benefit guarantees, factors leading to those designs and considerations regarding the adequacy of reserves that emerge under AXXX formulas. This article also identifies a series of factors that authors believe will make it difficult to quickly and equitably resolve these issues through formula-based changes.