The complete form behind each entry in the Change Control Log. Status date 16 October 2026.
Jump to: CR-001 · CR-002 · CR-003 · CR-004 · CR-005 · CR-006 · CR-007 · CR-008
Why each form states both outcomes. A change request that records only
what happens if it is approved has assessed one branch of a two-branch decision. The
If not approved column is the do-nothing option made concrete — and on this program it
is where the more interesting reasoning sits, because three of the eight requests were not approved.
Change request forms
CR-001 · Scope reduction · Priority: High
Reduce launch crediting strategies from five to three Approved
Requested by: D. Falkner, VP Product Development ·
Submitted: 2026-06-24 · Decided: 2026-07-02 ·
Authority: Gate Review Board (out-of-cycle, delegated to Chair + CPO)
Summary. Cut the launch crediting-strategy line-up from five to three to fit the illustration engine's verified capability.
Description. The Gate 1 package assumed five crediting strategies at launch. Issue I-02 established that the illustration engine can validate three within the Stage 2 window; the remaining two would require a vendor release that is not on Cordelane's roadmap before filing. This request removes the two unvalidated strategies from launch scope and places them in a post-launch enhancement backlog.
Justification. Gate condition GC-01 required the reduction as a condition of the Gate 1 GO. The change request is the instrument that executes the condition against the scope baseline — the condition obliges the program to act, but it does not itself amend scope.
| Impact area | Assessment |
|---|---|
| Scope | Launch line-up reduced from five strategies to three. Two strategies moved to a post-launch backlog; no contractual commitment made to deliver them. |
| Schedule | 0 days. Protects the Gate 2 date rather than moving it. |
| Cost | Cost-neutral at the program level. Reduced configuration effort is absorbed inside the Stage 2 tranche; no contingency drawn. |
| Quality | Improves it. Three strategies can be fully illustration-validated before filing; five could not. |
| Risk | Retires the launch-blocking element of I-02. Introduces a competitive-position risk that the reduced line-up is read as a thinner product — referred to R-06. |
If approved
Filing proceeds on a three-strategy line-up. The illustration engine is validated inside Stage 2, and GC-01 can be verified and closed before its 31 Jul due date.
Filing proceeds on a three-strategy line-up. The illustration engine is validated inside Stage 2, and GC-01 can be verified and closed before its 31 Jul due date.
If not approved
Filing would proceed on a line-up the illustration engine cannot validate. Either the filing slips until the vendor releases the capability, or the product files with two strategies whose illustrations are unverified — a market-conduct exposure the General Counsel would not accept.
Filing would proceed on a line-up the illustration engine cannot validate. Either the filing slips until the vendor releases the capability, or the product files with two strategies whose illustrations are unverified — a market-conduct exposure the General Counsel would not accept.
Alternatives considered. (a) Retain five strategies and slip Gate 2 to await the vendor release — rejected, the release is not on the roadmap and the slip is unbounded. (b) Retain five and file with unvalidated illustrations — rejected outright by the GC/CCO. (c) Reduce to four — rejected, the fourth strategy shares the engine limitation.
Recommendation. Approve. The condition is already binding; the only question is whether scope is amended formally or allowed to drift.
Decision: Approved, 2026-07-02.
Related documents. Gate Conditions Register — GC-01 · RAIDD Log — I-02 · Product Requirements Document
CR-002 · Scope reduction · Priority: High
Remove New York from launch-state scope Approved
Requested by: A. Nkemelu, Senior Counsel — Product ·
Submitted: 2026-06-19 · Decided: 2026-06-30 ·
Authority: Gate Review Board (out-of-cycle, delegated to Chair + GC/CCO)
Summary. Withdraw New York from the launch filing set and issue a deferral memorandum.
Description. New York's Regulation 187 suitability standard and its separate contract-form requirements would add a filing track running materially longer than the other launch states, with a distinct actuarial memorandum. The state was carried in the Gate 1 package without that track being costed.
Justification. Executes gate condition GC-02, which was attached specifically to resolve the GC/CCO abstention recorded at the Gate 1 second convening. The abstention cannot be cleared while New York remains in launch scope.
| Impact area | Assessment |
|---|---|
| Scope | New York removed from the launch filing set. A deferral memorandum commits the program to a post-launch re-entry assessment, with no date committed. |
| Schedule | 0 days to Gate 2. Removes a filing track that was the binding constraint on the Gate 3 filing-approval date. |
| Cost | Reduces external filing counsel spend inside the Stage 2 non-labor envelope. Not re-baselined — the saving is retained in the envelope rather than released. |
| Quality | Neutral to the launch product. Improves filing quality by removing a track the program had not resourced. |
| Risk | Retires the filing-timeline element of the GC/CCO abstention. Adds a distribution risk: two Tier-1 IMO partners write meaningful New York volume — referred to I-06 and R-07. |
If approved
The GC/CCO abstention is resolved and GC-02 closes. The filing set is one the program can actually resource, and Gate 3 is no longer gated on a New York actuarial memorandum.
The GC/CCO abstention is resolved and GC-02 closes. The filing set is one the program can actually resource, and Gate 3 is no longer gated on a New York actuarial memorandum.
If not approved
New York stays in scope with no funded filing track. The most likely outcome is that it becomes the reason Gate 3 slips, discovered late, with the same decision taken then under schedule pressure and with less negotiating room with the IMO partners.
New York stays in scope with no funded filing track. The most likely outcome is that it becomes the reason Gate 3 slips, discovered late, with the same decision taken then under schedule pressure and with less negotiating room with the IMO partners.
Alternatives considered. (a) Fund a New York filing track from contingency — rejected, contingency at 9% is thin and the board declined to commit it to a state that can be added post-launch. (b) File New York simultaneously on the same forms — not available; New York requires distinct forms. (c) Delay the whole launch to align — rejected, forfeits the 2028 selling season.
Recommendation. Approve, and issue the deferral memorandum at the same time so the decision is visible to distribution rather than discovered by them.
Decision: Approved, 2026-06-30.
Related documents. Gate Conditions Register — GC-02 · Regulatory Filing Plan · Gate 1 Recycle Memorandum
CR-003 · Cost — contingency draw · Priority: High
Commission an independent external actuarial peer review of GLWB rider pricing Approved
Requested by: S. Ravichandran, Lead Pricing Actuary, FSA ·
Submitted: 2026-07-06 · Decided: 2026-07-16 ·
Authority: Gate Review Board — CFO concurrence required for contingency release
Summary. Draw $180,000 from contingency to fund an external peer review of the GLWB rider before Gate 2.
Description. The guaranteed lifetime withdrawal benefit rider carries the program's largest single pricing uncertainty: the election-rate assumption of 62% drives both the capital strain and the return. The board scored both competitive position and financial return at 3 at Gate 1 and attached GC-03 requiring independent review before Gate 2.
Justification. A pricing assumption reviewed only by the team that set it is not independently verified, and the Gate 2 decision turns on it. External review is the only mechanism that produces evidence the board did not itself author.
| Impact area | Assessment |
|---|---|
| Scope | Engagement of an external consulting actuary to review rider pricing, election-rate assumption, and capital strain. No change to product scope. |
| Schedule | 0 days. Review completes 26 Feb 2027, before the Gate 2 date of 01 Apr 2027. |
| Cost | $180,000 drawn from the $2,304,000 contingency reserve. Second of two draws to date. |
| Quality | Directly improves the evidentiary quality of the Gate 2 package. |
| Risk | Addresses R-06. Carries the real possibility that the review disagrees with the current pricing — which is the point of commissioning it. |
If approved
Gate 2 receives an independently reviewed rider price. If the review disagrees, the program learns before filing, when re-pricing is still cheap.
Gate 2 receives an independently reviewed rider price. If the review disagrees, the program learns before filing, when re-pricing is still cheap.
If not approved
GC-03 cannot be verified, and the Gate 2 board is asked to approve filing on a rider price reviewed only internally. On the board's own Gate 1 scoring that is the assumption most likely to be wrong, and the cheapest moment to find out has passed.
GC-03 cannot be verified, and the Gate 2 board is asked to approve filing on a rider price reviewed only internally. On the board's own Gate 1 scoring that is the assumption most likely to be wrong, and the cheapest moment to find out has passed.
Alternatives considered. (a) Internal peer review by the corporate actuarial function — rejected, it reports through the same Chief Actuary who sits on the board; it is not independent of the decision. (b) Defer review until after filing — rejected, re-pricing after filing means re-filing. (c) Reduce scope to the election-rate assumption alone — considered, and rejected as a false economy at this cost.
Recommendation. Approve and release the contingency.
Decision: Approved, 2026-07-16.
CR-004 · Cost — contingency draw · Priority: Critical
Fund the Gate 1 recycle loop and re-work of the business case Approved
Requested by: C. Tyrrell, NPD Program Manager, Chair ·
Submitted: 2026-05-04 · Decided: 2026-05-08 ·
Authority: Gate Review Board — CFO concurrence required for contingency release
Summary. Draw $232,000 to fund six weeks of re-work after the Gate 1 RECYCLE decision.
Description. The first Gate 1 convening returned RECYCLE, not GO. The business case had been built on a capital charge that produced an IRR of 14.6%; corrected, it is 13.4% against a hurdle of 11.0%. Re-work spanned pricing, capital and distribution assumptions and required the team to be held together through a period in which no tranche was released.
Justification. A recycle is a defined and legitimate gate outcome, but the stage-gate funding model releases money at gates. A recycled gate therefore creates a funding gap by design: the work required to answer the board is real, and no tranche covers it.
| Impact area | Assessment |
|---|---|
| Scope | No change to product scope. Funds re-work of the Gate 1 package only. |
| Schedule | 42 days between the first and second Gate 1 convenings. Absorbed without moving Gate 2. |
| Cost | $232,000 drawn from contingency. First of two draws to date. |
| Quality | The re-worked case corrected a capital-charge error that the original package carried into a board decision. |
| Risk | Retires I-01. Establishes the precedent that a recycle has a funded path, which the board noted approvingly. |
If approved
The team stays assembled, the case is corrected, and Gate 1 reconvenes six weeks later on evidence the board can act on.
The team stays assembled, the case is corrected, and Gate 1 reconvenes six weeks later on evidence the board can act on.
If not approved
The recycle has no funded path. In practice the team would disperse to other work and the re-work would be done slowly by whoever remained — turning a six-week loop into a quarter, and making RECYCLE a decision the board learns not to take.
The recycle has no funded path. In practice the team would disperse to other work and the re-work would be done slowly by whoever remained — turning a six-week loop into a quarter, and making RECYCLE a decision the board learns not to take.
Alternatives considered. (a) Absorb the re-work in the Stage 1 tranche — not available; Stage 1 actuals ($2,412,000) had already exceeded the Stage 1 tranche ($2,180,000). (b) Release the Stage 2 tranche early to cover it — rejected, that would pre-empt the gate decision the re-work exists to inform. (c) Cancel and re-propose — rejected as disproportionate to a correctable error.
Recommendation. Approve. The alternative is a governance model in which the board's own recycle option is unfundable.
Decision: Approved, 2026-05-08.
CR-005 · Product pricing · Priority: Medium
Increase the illustrated cap rate from 9.25% to 9.75% to lead the peer set Declined
Requested by: R. Castellanos, Head of Distribution ·
Submitted: 2026-08-27 · Decided: 2026-09-10 ·
Authority: Gate Review Board — Chief Actuary and CFO joint refusal
Summary. Raise the illustrated cap on the Calder Balanced 5 one-year point-to-point from 9.25% to 9.75% to take a visible lead over the peer set.
Description. Distribution reported that IMO partners rank the line-up by illustrated cap and that a leading cap would materially ease the volume conversation. The current illustrated cap is 9.25% against a peer set at 9.00% and a competitive floor of 8.50% agreed at Gate 1.
Justification. Offered as a remedy for the uncommitted premium disclosed when GC-04 closed, and for the wholesaler shortfall recorded at I-06.
| Impact area | Assessment |
|---|---|
| Scope | No change to scope. A pricing parameter change with product-wide effect. |
| Schedule | 0 days. |
| Cost | Not a spend. The cap increase consumes option budget: at 4.2% new-business strain, the additional 50 basis points moves the program IRR below the 11.0% hurdle on the plan volume case, and materially below it on the downside case (10.1% before any increase). |
| Quality | Neutral. |
| Risk | Would introduce a pricing-adequacy risk of the exact kind the Gate 1 recycle was called over. |
If approved
The product leads the peer set on the single metric distribution is ranked by, and volume conversations become easier. The program would then be selling a product whose return is below the hurdle its own board set — and the board would have approved that knowingly, eight months after recycling the gate for an IRR error.
The product leads the peer set on the single metric distribution is ranked by, and volume conversations become easier. The program would then be selling a product whose return is below the hurdle its own board set — and the board would have approved that knowingly, eight months after recycling the gate for an IRR error.
If not approved
Distribution goes to market with a cap 25 basis points above the peer set rather than 75, and the uncommitted premium gap stays open. That gap is real and remains referred to I-06 and R-07 — declining this request does not solve it, and the board recorded that plainly.
Distribution goes to market with a cap 25 basis points above the peer set rather than 75, and the uncommitted premium gap stays open. That gap is real and remains referred to I-06 and R-07 — declining this request does not solve it, and the board recorded that plainly.
Alternatives considered. (a) Increase the cap only on the two-year point-to-point, where the option cost is lower — referred to pricing for assessment at Gate 2; not decided here. (b) Hold the cap and increase wholesaler coverage instead — became CR-006. (c) Hold the cap and improve the commission schedule — rejected, transfers the same margin with less competitive visibility.
Recommendation. Decline. The request is well founded as a commercial observation and wrong as a pricing decision. The cap is already above peer; the gap distribution is describing is one of coverage, not of price.
Decision: Declined, 2026-09-10.
CR-006 · Resource / cost increase · Priority: Medium
Add two wholesalers to close the coverage gap ahead of launch Deferred
Requested by: R. Castellanos, Head of Distribution ·
Submitted: 2026-09-14 · Decided: 2026-10-01 ·
Authority: Gate Review Board
Summary. Recruit the 2 wholesalers still uncommitted against the plan of 6, funded ahead of the Gate 2 tranche release.
Description. The business case assumed 6 wholesalers at launch; 4 are committed (I-06). Recruitment lead time for an experienced annuity wholesaler runs two to three quarters, so distribution argued that waiting for Gate 2 makes the launch date unachievable for the missing coverage.
Justification. The coverage shortfall is the most credible single explanation for the uncommitted premium disclosed at GC-04 closure.
| Impact area | Assessment |
|---|---|
| Scope | No product scope change. Increases the distribution team envelope. |
| Schedule | Recruitment lead time is the binding constraint, not the funding date. Deferral costs roughly one quarter of coverage at launch. |
| Cost | Sits inside the Stage 3 team envelope, which the board has not released. Funding it now means releasing part of a tranche ahead of the gate that authorizes it. |
| Quality | Neutral. |
| Risk | Deferral leaves R-07 open and unmitigated through Gate 2. |
If approved
Coverage is in place for launch, and the volume assumption becomes defensible. The board would have released Stage 3 money before the Gate 2 decision that authorizes Stage 3 — which is the one discipline the funding model exists to enforce.
Coverage is in place for launch, and the volume assumption becomes defensible. The board would have released Stage 3 money before the Gate 2 decision that authorizes Stage 3 — which is the one discipline the funding model exists to enforce.
If not approved
If declined outright, the launch proceeds on four wholesalers against a plan of six, and the volume assumption is knowingly unsupported.
If declined outright, the launch proceeds on four wholesalers against a plan of six, and the volume assumption is knowingly unsupported.
Alternatives considered. (a) Approve now from contingency — rejected; contingency is a risk reserve, not an early tranche, and two of nine percentage points are already drawn. (b) Contract interim third-party wholesaling capacity, which is cancellable and does not require a tranche release — directed to be costed and brought to Gate 2. (c) Reduce the volume assumption in the business case to match four wholesalers — referred to pricing; would be the honest alternative if coverage is not resolved.
Recommendation. Defer to Gate 2 with the interim-capacity option costed in the meantime. The board was explicit that this is a deferral and not a refusal, and that arriving at Gate 2 without option (b) priced would itself be a finding.
Decision: Deferred to Gate 2, 2026-10-01.
Related documents. Gate Conditions Register — GC-04 · Distribution & Advisor Enablement Plan · RAIDD Log — I-06, R-07
CR-007 · Cost increase · Priority: High
Engage external derivatives counsel to accelerate the second ISDA execution Declined
Requested by: M. Delacroix, Director, ALM & Hedging ·
Submitted: 2026-09-22 · Decided: 2026-10-08 ·
Authority: Gate Review Board — Chair and Chief Risk Officer
Summary. Fund external derivatives counsel to accelerate ISDA execution with the second hedging counterparty, which has not begun (DEP-06).
Description. GC-05 requires a hedging readiness plan with ISDA execution milestones at Gate 2, and is currently assessed at risk because execution with the second counterparty has not started. The request proposed external counsel to run the negotiation in parallel with in-house legal.
Justification. Hedging readiness lagging the launch schedule is R-05, and the second counterparty is the program's only mitigation for single-counterparty concentration.
| Impact area | Assessment |
|---|---|
| Scope | No scope change. Adds external legal capacity. |
| Schedule | Assessed as 0 days of genuine acceleration — see the recommendation. |
| Cost | Would require a third contingency draw. |
| Quality | Neutral. |
| Risk | Does not reduce R-05. Declining leaves GC-05 at risk, which is recorded and carried to Gate 2. |
If approved
The program spends contingency and gains external drafting capacity it does not currently lack.
The program spends contingency and gains external drafting capacity it does not currently lack.
If not approved
GC-05 remains at risk into Gate 2 and the board must decide there whether hedging readiness is sufficient to release Stage 3. That is the correct place for the decision, and it is now visibly on the Gate 2 agenda rather than quietly resolved by spending.
GC-05 remains at risk into Gate 2 and the board must decide there whether hedging readiness is sufficient to release Stage 3. That is the correct place for the decision, and it is now visibly on the Gate 2 agenda rather than quietly resolved by spending.
Alternatives considered. (a) Escalate counterparty-side through the CFO's relationship with the institution — adopted instead, at no cost. (b) Proceed to launch on a single counterparty — rejected by the CRO on concentration grounds. (c) Substitute a third institution already through credit review — directed to be assessed as a fallback before Gate 2.
Recommendation. Decline. The constraint is the counterparty's own credit-committee calendar, not drafting capacity on our side — in-house counsel is not the bottleneck and adding counsel would not move the date. ⚠ This is the distinction the request turned on: money can accelerate work that is resource-limited, and cannot accelerate work that is waiting on somebody else's committee.
Decision: Declined, 2026-10-08.
Related documents. Gate Conditions Register — GC-05 · RAIDD Log — R-05, DEP-06 · Stage-Gate Governance Model
CR-008 · Vendor scope · Priority: Medium
Add a second administration platform environment to Cordelane WP-1 Approved w/ mod
Requested by: Cordelane Systems (via vendor manager), Vendor-initiated ·
Submitted: 2026-09-30 · Decided: 2026-10-14 ·
Authority: Chair, under delegated vendor change authority
Summary. Vendor request to add a separate performance-test environment to Stage 2 work package WP-1.
Description. Cordelane proposed a dedicated performance-test environment alongside the build environment in WP-1 ($1,680,000), arguing that sharing one environment between configuration and performance testing would serialize Stage 3 test support.
Justification. Accepted in principle. The serialization risk is real and would surface in Stage 3, where the test-support work package is the smallest of the three.
| Impact area | Assessment |
|---|---|
| Scope | A performance-test environment is added, provisioned for the Stage 3 test window only rather than from Stage 2 as requested. |
| Schedule | 0 days. Removes a serialization risk from the Stage 3 critical path. |
| Cost | Absorbed within the authorized WP-1 value of $1,680,000 by deferring provisioning to the Stage 3 window. No increase to the Cordelane SOW and no contingency draw. |
| Quality | Improves Stage 3 test throughput. |
| Risk | Retires a Stage 3 scheduling risk before it is on the critical path. |
If approved
The environment exists when Stage 3 testing needs it, at no increase to the authorized SOW value.
The environment exists when Stage 3 testing needs it, at no increase to the authorized SOW value.
If not approved
Configuration and performance testing share one environment, and Stage 3 test support — already the smallest work package — absorbs the serialization. The most likely consequence is a Stage 3 change request for the same environment, at a worse moment and with less negotiating room.
Configuration and performance testing share one environment, and Stage 3 test support — already the smallest work package — absorbs the serialization. The most likely consequence is a Stage 3 change request for the same environment, at a worse moment and with less negotiating room.
Alternatives considered. (a) Approve as submitted, provisioned from Stage 2 — rejected; the environment would sit idle for two quarters at full cost. (b) Decline and manage by scheduling — rejected; the vendor's serialization analysis was accepted. (c) Provision in the corporate shared environment pool — rejected; the pool has no annuity-platform capacity in the Stage 3 window.
Recommendation. Approve with the provisioning date moved to the Stage 3 window. ⚠ Note that this is a vendor-initiated change accepted on the vendor's own analysis — recorded as such, because a register in which every request originates inside the program is not recording the vendor relationship.
Decision: Approved with modification, 2026-10-14.
Reading the register as a whole
Eight requests over eight months on a program of 90 people is a low volume, and the reason is structural rather than a sign of a stable baseline: on a stage-gate program much of what would elsewhere be a change request is instead a gate decision. Scope that would be added by change control on a baselined program is here simply not funded until a board releases the tranche that pays for it.
What the register does show is a board that distinguishes between the merits of a request and its timing. CR-006 was accepted on the merits and deferred on the funding; CR-007 was refused on the merits despite being cheap and well argued, because the money would not have moved the date. Those are different refusals, and a register that recorded both as simply “not approved” would lose the distinction that matters.
Maintained by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Change Control Log · Gate Conditions Register · RAIDD Log.