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Prudential Premier Retirement Variable Annuities

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variable life contracts that are issued by Pruco Life as well as other insurance companies that have the same underlying mutual<br />

fund portfolios available to them. Since some contract Owners are not subject to the same transfer restrictions, unfavorable<br />

consequences associated with such frequent trading within the underlying mutual fund (e.g., greater portfolio turnover, higher<br />

transaction costs, or performance or tax issues) may affect all contract Owners. Similarly, while contracts managed by a Financial<br />

Professional are subject to the restrictions on transfers between Investment Options that are discussed above, if the Financial<br />

Professional manages a number of contracts in the same fashion unfavorable consequences may be associated with management<br />

activity since it may involve the movement of a substantial portion of an underlying mutual fund's assets which may affect all<br />

contract Owners invested in the affected options. Apart from jurisdiction-specific and contract differences in transfer restrictions,<br />

we will apply these rules uniformly (including contracts managed by a Financial Professional) and will not waive a transfer<br />

restriction for any Owner.<br />

Although our transfer restrictions are designed to prevent excessive transfers, they are not capable of preventing every<br />

potential occurrence of excessive transfer activity. The portfolios have adopted their own policies and procedures with respect to<br />

excessive trading of their respective shares, and we reserve the right to enforce any such current or future policies and procedures.<br />

The prospectuses for the portfolios describe any such policies and procedures, which may be more or less restrictive than the<br />

policies and procedures we have adopted. Under SEC rules, we are required to: (1) enter into a written agreement with each<br />

portfolio or its principal underwriter or its transfer agent that obligates us to provide to the portfolio promptly upon request certain<br />

information about the trading activity of individual contract Owners (including an Annuity Owner’s TIN number), and (2) execute<br />

instructions from the portfolio to restrict or prohibit further purchases or transfers by specific contract Owners who violate the<br />

excessive trading policies established by the portfolio. In addition, you should be aware that some portfolios may receive<br />

“omnibus” purchase and redemption orders from other insurance companies or intermediaries such as retirement plans. The<br />

omnibus orders reflect the aggregation and netting of multiple orders from individual Owners of variable insurance contracts and/or<br />

individual retirement plan participants. The omnibus nature of these orders may limit the portfolios in their ability to apply their<br />

excessive trading policies and procedures. In addition, the other insurance companies and/or retirement plans may have different<br />

policies and procedures or may not have any such policies and procedures because of contractual limitations. For these reasons, we<br />

cannot guarantee that the portfolios (and thus contract Owners) will not be harmed by transfer activity relating to other insurance<br />

companies and/or retirement plans that may invest in the portfolios.<br />

A portfolio also may assess a short-term trading fee (redemption fee) in connection with a transfer out of the Sub-account investing<br />

in that portfolio that occurs within a certain number of days following the date of allocation to the Sub-account. Each portfolio<br />

determines the amount of the short-term trading fee and when the fee is imposed. The fee is retained by or paid to the portfolio and<br />

is not retained by us. The fee will be deducted from your Account Value, to the extent allowed by law. At present, no portfolio has<br />

adopted a short-term trading fee.<br />

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