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B-1 STATEMENT OF ADDITIONAL INFORMATION Dated May 1 ...

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including individual and institutional investors, intermediaries, third-party service providers, rating andranking organizations and affiliated persons of the Fund. Once specific holdings information of aPortfolio is disclosed in this manner, it is considered readily accessible and publicly available forpurposes of the Holdings Disclosure Policy and Procedures.The Holdings Disclosure Policy and Procedures provide that the Fund and its service providers maydisclose all or part of a Portfolio’s holdings at any time after the information is publicly available orreadily accessible, provided that:• the information disclosed is accurate and presented in a manner that is not deceptive ormisleading;• the information disclosed is limited to the holdings information contained in a filing with theSEC or posted on the Fund’s website; and• no fees or other compensation are received by the Fund, its service providers or any of theiremployees from recipients of the holdings data as compensation for the disclosure of theholdings information.In addition to disclosing holdings information in SEC filings and on the Fund’s website as describedabove, the Fund is authorized to disclose or cause to be disclosed all or a portion of a Portfolio’s publiclyavailable or readily accessible holdings information to rating agencies and other informationorganizations that rate or rank investment companies or that collect and report other statistical data oninvestment companies, in marketing and sales literature, marketing presentations and the Fund’s website,and in communications to individual and institutional investors, regardless of the size of their account,including shareholders, contract owners, participants, annuitants and beneficiaries.Disclosure of Non-Public Holdings InformationDisclosure of a Portfolio’s material holdings prior to the holdings information becoming publiclyavailable is limited to the situations described below. The Holdings Disclosure Policy and Proceduresprohibit the Fund, its service providers and their employees from receiving compensation for thedisclosure of holdings information from recipients of the holdings data. The Holdings Disclosure Policyand Procedures authorize the following disclosures of Fund holdings information that is not publiclyavailable.Service Providers. Holdings data may be disclosed to and utilized by the Fund’s and Mason StreetAdvisors’ service providers (the “Service Providers”) as necessary for them to provide the services thatthey have agreed directly or indirectly to provide, provided that there is a reasonable belief based onwritten confidentiality provisions, rules of their profession, or other circumstances, that the recipientorganizations will keep the information confidential (i.e. not disclose it to third parties) and use it only forthe purposes for which it was provided. The frequency with which holdings information may be disclosedto Service Providers, and the length of the lag, if any, between the date of the information and the date ofthe disclosure, is determined by the Fund based on the needs of the Service Provider for such informationand the risk of harm to the Fund and its shareholders. As of December 31, 2008, the Service Providersincluded those listed on Appendix G.Holdings data of the Mid Cap Value Portfolio may also be disclosed by American CenturyInvestment Management, Inc., the sub-adviser for the Portfolio, to RiskMetrics Group (formerlyInstitutional Shareholder Services, Inc.) in its capacity as proxy service provider. Holdings data of theMid Cap Value Portfolio may also be disclosed by American Century Investment Management, Inc. toFactSet Research Systems, Inc. in connection with conducting attribution analyses on the Portfolio.Holdings data of the Domestic Equity Portfolio may also be disclosed by Capital Guardian TrustCompany, the sub-adviser for the Portfolio, to Vestek Systems, Inc. in connection with conductingattribution analyses on the Portfolio and to Plexus Group, Inc. in connection with evaluating the qualityB-59

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