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Gate 1 — Business Case Package

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Harborline
Aug 2025
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Feb 2026
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Stage 1
Business case
Gate 1
Apr 2026
Recycled
Gate 1
Jun 2026
Go w/ conditions
Stage 2
Development
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Apr 2027
Gate 3
Oct 2027
Gate 4
Feb 2028
Launch
Mar 2028
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Sep 2028
Product at a glance · Beacon Index AdvantageFull product definition →
Structure
Single-premium deferred fixed indexed annuity
Crediting
Three strategies — fixed · 1-yr point-to-point (Calder Balanced 5, capped) · performance-triggered
Income rider
Optional Guaranteed Lifetime Withdrawal Benefit (D-05)
Surrender
Seven-year declining surrender charge
Regulatory
State-filed — a fixed indexed annuity, not a RILA (D-01); no SEC/FINRA registration

Lighthouse Financial Services Company — The decision package tabled at the second convening of Gate 1 on Jun 11, 2026, seeking release of the Stage 2 development tranche for Beacon Index Advantage. This is the package as it went to the Gate Review Board, including the record of what changed after the first convening was recycled on April 30, 2026, and including the dissenting analysis tabled alongside the recommendation.

Recommendation & the decision sought

Recommendation: release the Stage 2 tranche of $11,640,000 to develop Beacon Index Advantage for launch on March 6, 2028, subject to the conditions the Board considers necessary on the weaknesses identified in this package.

Tranche requested
$11,640,000
5-year premium
$1,875,000,000
Product IRR
13.4%
Hurdle
11.0%

Prepared by C. Tyrrell, NPD Program Manager. Issued to the Board ten business days before the gate under the Governance Model §7.

Table of Contents

Part I — The Ask
  1. Recommendation & Decision Sought
  2. What Changed Since the First Convening
  3. Must-Meet Certification
Part II — Product & Market
  1. Product Concept & Structure
  2. Target Market
  3. Competitive Position
  4. Distribution Plan & Written Commitments
Part III — Economics
  1. Volume Forecast
  2. Capital & Return Against Hurdle
  3. Development Cost & the Stage 2 Ask
  4. Sensitivities & the Downside Case
Part IV — Delivery, Regulation & Risk
  1. Stage 2 Scope & Approach
  2. Regulatory Route
  3. Risk Position at Gate 1
  4. Assumptions on Which This Case Rests
Part V — The Decision
  1. Dissent Tabled With This Package
  2. Scored Assessment & Outcome
  3. Conditions Issued
  4. Document Control
Part I — The Ask

1. Recommendation & Decision Sought

The Board is asked to release $11,640,000 to build, price and prepare for filing a fixed indexed annuity with an optional guaranteed lifetime withdrawal benefit rider, for launch on March 6, 2028. On the corrected capital charge the product returns 13.4% against an 11.0% hurdle — a margin of 240 basis points, which is positive but not comfortable, and this package does not present it as comfortable.

Three things about this recommendation should be read together. The return clears the hurdle. It clears it by less than the first version of this package claimed. And it depends on volume assumptions of which 90.8% are now supported by written channel commitments, leaving $17,000,000 of Year 1 premium resting on channel expansion that has not yet been secured.

2. What Changed Since the First Convening

Gate 1 was first convened on April 30, 2026 and recycled. Under the Gate Decision Framework the package was not scored, because two should-meet criteria were rated U — unscoreable on the evidence presented. The Board did not form a view on the product. It declined to form one on that evidence.

Change 1 — Distribution commitment: rated U, now evidenced

The first package built its volume forecast from internal channel modeling. No written commitment from any distribution partner was included, and the evidence standard does not accept a relationship manager's confidence in place of one.

Remediated: written Year 1 indications now held from three IMO partners totaling $168,000,000, or 90.8% of the Year 1 target — §7. The residual $17,000,000 gap is disclosed rather than closed, and is the subject of tabled dissent at §16.

Change 2 — Financial return: rated U, now recomputed

The return in the first package was computed on a capital charge that had been superseded. The output was of an admissible kind; its input was not current.

Remediated: recomputed on the current charge. The product IRR falls from 14.6% to 13.4%. The case still clears the hurdle, but by 240 basis points rather than 360.

The recycle changed the answer, not just the paperwork. A 120 basis point reduction in projected return is not a presentational correction. Had the first package been scored on its stated numbers it would have cleared the conditions band and released $11,640,000 on a return that was overstated and a volume forecast that no partner had confirmed. The loop cost six weeks and $232,000, recorded as issue I-01.

3. Must-Meet Certification

All five Gate 1 must-meet criteria are certified. Each is answered by a named accountable party.

Must-meetCertified byStatus
Product can be filed in the assumed regulatory laneB. Lindqvist, GC & CCOYes — non-registered, Compact route (§13)
A pricing basis exists that clears the hurdle on a current capital chargeN. Adeyemi, Chief ActuaryYes — 13.4% vs 11.0%
The guarantee can be hedged with in-house capabilityM. Delacroix, Director ALM & HedgingYes — with readiness plan due at Gate 2
Written distribution appetite from at least three partnersR. Castellanos, Head of DistributionYes — three IMOs, $168,000,000
Required capital available without displacing a committed useJ. Whitmore, CFOYes — $7,770,000 Year 1
Part II — Product & Market

4. Product Concept & Structure

Beacon Index Advantage is a single-premium deferred fixed indexed annuity. The contract credits interest linked to the performance of an external index subject to a cap, with principal protected against index loss. It is not a registered product: the contract owner has no direct exposure to a securities account and no negative index participation, which keeps the product outside securities registration and inside the state insurance filing lane (D-01).

4.1 Structure at launch

ElementAt launch
PremiumSingle premium; minimum consistent with the existing annuity line
Surrender charge periodSeven years, declining
Crediting strategiesThree — fixed account, one-year point-to-point on the Calder Balanced 5 Index with a cap, and a one-year performance-triggered strategy (D-03, condition GC-01)
Guaranteed lifetime withdrawal benefitOptional rider for an explicit charge, not embedded in the base contract (D-05)
Illustrated cap at pricing9.2% on the indexed point-to-point strategy
Why three strategies and not five. The concept carried five at Gate 0. Two were removed before this package because the illustration engine cannot produce compliant hypothetical performance for the structures they required (I-02), and building that capability was not justified by their forecast contribution. This is a scope cancel, recorded as D-03 and carried as condition GC-01 — the two strategies are not deferred, they are out.

5. Target Market

The product targets pre-retirees and early retirees between roughly 55 and 70 holding qualified and non-qualified savings, seeking principal protection with some participation in index growth, and — for the rider cohort — a contractual income floor they cannot outlive.

Average case size is modeled at $118,000, consistent with the carrier's existing annuity block. Rider election is modeled at 62.0%, which materially affects both pricing and hedging: the rider cohort is the source of the guarantee exposure and of most of the product's fee income.

6. Competitive Position

MeasureBeacon Index AdvantagePeer set medianFloor agreed at this gate
Illustrated cap, 1-year point-to-point9.2%9.0%8.5%

The product prices marginally above the peer median at current option costs. That margin is thin and it is not durable: the cap is funded by the option budget, and the option budget moves with rates and volatility between now and launch, twenty-one months out.

The Board is asked to fix a competitive floor at this gate. The recommendation is 8.5%: if the illustrated cap cannot be supported at or above that level when Gate 2 convenes, the product should be re-priced or stopped rather than launched into the third quartile. Fixing the floor now, before anyone is attached to the launch date, is the point — see risk R-03.

7. Distribution Plan & Written Commitments

Distribution is through existing independent marketing organization relationships. No new channel is being stood up (A-05).

PartnerRelationshipYear 1 written indication
Northgate Financial GroupExisting, top-three producer on the current annuity lineWritten
Sentinel Advisory NetworkExistingWritten
Copperfield Insurance MarketingExistingWritten
Combined Year 1 indication$168,000,000 — 90.8% of the Year 1 target

These commitments are the direct remediation of the first convening (§2) and are the evidence behind condition GC-04. They are indications of intended production, not contractual minimums; no IMO commits to a volume it cannot withdraw from.

The unclosed gap is $17,000,000. The plan closes it through channel expansion during Stage 3 and Stage 4. That plan is not evidenced at this gate and is the subject of dissent at §16.

Part III — Economics

8. Volume Forecast

PeriodPremiumPolicies at $118,000 averageCapital strain at 4.2%
Year 1 (2028)$185,000,0001,568$7,770,000
Year 2$310,000,0002,627$13,020,000
Year 3$420,000,0003,559$17,640,000
Year 4$480,000,0004,068$20,160,000
Year 5$480,000,0004,068$20,160,000
Five-year total$1,875,000,00015,890$78,750,000

Year 1 is a partial year: launch is March 6, 2028, giving roughly ten selling months and 1,568 policies. The curve reflects the shape the carrier has observed on prior annuity launches — a slow first two quarters while producers are appointed and trained, then acceleration as the product enters standing recommendation sets.

9. Capital & Return Against Hurdle

New business consumes capital before it produces earnings. Strain is modeled at 4.2% of premium, requiring $7,770,000 in Year 1 and $78,750,000 across five years of sales.

Product IRR
13.4%
Hurdle rate
11.0%
Margin
+240 bps
As first tabled
14.6%

The margin over hurdle is 240 basis points. On a product whose economics are driven by an option budget that moves with markets and by a rider cohort whose behavior is modeled rather than observed, that is a real but modest margin, and the Board should weigh it as such. The sensitivities at §11 are the more informative view.

10. Development Cost & the Stage 2 Ask

Total authorized program cost is $27,904,000 — a base of $25,600,000 plus a 9.0% gate contingency reserve of $2,304,000 held by the Board. Under the funding model, the Board is not being asked to commit that amount today.

Released atStageAmountStatus at this gate
Gate 0Stage 1 — Business Case$2,180,000Spent; closed at $2,412,000
Gate 1 — this decisionStage 2 — Development$11,640,000Requested
Gate 2Stage 3 — Testing & Validation$7,450,000Not requested
Gate 3Stage 4 — Launch Readiness$4,330,000Not requested

Stage 1 closed $232,000 over its tranche. The overrun is the cost of the recycle loop and was met by an authorized contingency draw rather than absorbed into this request — folding it into the Stage 2 ask would have concealed the cost of the recycle inside development spend.

11. Sensitivities & the Downside Case

ScenarioEffectIRRAgainst hurdle
PlanAs presented13.4%Clears by 240 bps
Volumes 30% below planFixed development cost spread over less premium; slower scale in servicing10.1%Fails by 90 bps
Cap falls to the 8.5% floorCompetitive position moves from above median to below; volume risk rather than margin riskModeled through the volume sensitivity above
Rider election materially above 62.0%More fee income, more guarantee exposure and more hedging costBroadly neutral to modestly positive
The downside case does not clear the hurdle. At 30% below plan the product returns 10.1% against 11.0%. Given that $17,000,000 of Year 1 premium is not covered by written commitment, this is the scenario the Board should treat as live rather than remote. It is presented here as the reason a volume condition is warranted, not as an argument that the case is unsound.
Part IV — Delivery, Regulation & Risk

12. Stage 2 Scope & Approach

Stage 2 runs Jun 15, 2026 to Mar 26, 2027 and delivers a product that is built, priced and fit to file. Its scope is bounded by what Gate 2 must be able to certify.

Stage 2 explicitly does not include filing submission, pilot selling, or advisor training. Those sit in Stages 3 and 4 behind gates that have not been passed.

13. Regulatory Route

The product is filed as an individual deferred non-variable annuity through the Interstate Insurance Product Regulation Commission — the Compact — giving a single submission against uniform standards for member states. States that are not Compact members are filed separately through SERFF.

RouteScopeDependency
Compact submissionMember states — the substantial majority of the launch footprintDEP-01 — the review clock is the regulator's, not ours
Separate SERFF filingsCalifornia, FloridaDEP-02 — independent review timelines (R-02)
New York — excludedNot in launch scopeA-03 / D-02, condition GC-02

Suitability and best-interest obligations under the NAIC model regulation as adopted by each state drive advisor training and disclosure scope in Stage 4. They are a real cost of launch and are carried in the program budget rather than treated as a compliance afterthought.

14. Risk Position at Gate 1

IDRiskWhy it matters to this decision
R-03Option budget compresses; illustrated cap falls below the competitive floorDirectly attacks the volume forecast. Mitigated by fixing the floor at this gate (§6)
R-06Pricing assumptions unsupportable under external reviewWould invalidate the return in §9. Argues for an independent review before Gate 2
R-07Distribution partners deprioritize against competitor launchesCombines with the $17,000,000 uncommitted gap to produce the §11 downside
R-05Hedging readiness lags launchCannot sell a guarantee that cannot be hedged. Argues for a dated readiness plan at Gate 2
R-01, R-02Filing review extends; non-Compact states approve lateSchedule risk against a launch date set by the distribution cycle
R-10Single credentialed pricing actuary on the critical pathConcentration in the one role the must-meet certification depends on

15. Assumptions on Which This Case Rests

If any of these fails, the case does not merely weaken — it needs rebuilding.

Part V — The Decision

16. Dissent Tabled With This Package

The Gate Decision Framework requires that material analysis not supporting the recommendation is tabled with it, attributed, and not summarized away. Two items are tabled.

Dissent 1 — Distribution: the wholesaler plan is not funded to the volume forecast

Raised by the Distribution function, Jun 11, 2026.

The volume curve at §8 assumes 6 field wholesalers supporting the launch. Distribution can commit 4. The shortfall is not a resourcing detail: field wholesaler coverage is the principal driver of how quickly a new annuity enters producers' standing recommendation sets, and the Year 2 and Year 3 acceleration in the forecast assumes that entry happens on schedule.

Recorded as issue I-06. The Distribution view is that the forecast should be treated as achievable only if the coverage gap is closed before Stage 4, and that the $17,000,000 uncommitted Year 1 premium should be read alongside it rather than separately.

Dissent 2 — Risk: concentration in a single crediting strategy

Raised by the Chief Risk Officer as observer, Jun 11, 2026.

Reducing from five crediting strategies to three (D-03) was the right call on build cost, but it raises the likelihood that sales concentrate in the indexed point-to-point strategy. A concentrated book is a more concentrated hedging exposure than the pricing assumes, and the effect is not visible in the Year 1 numbers.

Recorded as risk R-12. The CRO does not oppose the recommendation and has not asked for it to be varied; the position is recorded so that the concentration is a known consequence of a decision rather than a discovery at Gate 5.

17. Scored Assessment & Outcome

Assessed against the Gate 1 criteria fixed at Gate 0. Full scoring is in the Gate Decision Framework §8.

TierResult
Must-meet5 of 5 passed (§3)
Weighted should-meet score3.20 — conditions band (3.00–3.49)
OutcomeGO WITH CONDITIONS carried 4–0–1
AbstentionB. Lindqvist, GC & CCO — pending the New York deferral memorandum, subsequently closed as GC-02
Released$11,640,000 — Stage 2

18. Conditions Issued

Four of the five conditions map directly onto criteria that scored 3 — the intended behavior of the framework, in which every weakness supporting a continuation decision leaves the room with an owner attached to it.

IDConditionOwnerDueAddresses
GC-01Reduce launch crediting strategies from five to threeD. FalknerClosed Jul 21, 2026Feasibility; I-02
GC-02Remove New York from launch scope; issue a deferral memorandumA. NkemeluClosed Jul 3, 2026The abstention at §17
GC-03Independent external actuarial peer review of GLWB pricing before Gate 2S. RavichandranFeb 26, 2027Return and competitive position; R-06
GC-04Re-validate volumes with the three largest IMO partnersR. CastellanosClosed Aug 14, 2026Distribution commitment; dissent 1
GC-05Hedging readiness plan with ISDA milestones, presented at Gate 2M. DelacroixMar 12, 2027Feasibility; R-05

The reserve draw of $180,000 funding GC-03 was authorized by the Board at this gate under Governance Model §15.

19. Document Control

VersionDateChange
1.0Apr 30, 2026Tabled at the first convening of Gate 1. Recycled — two criteria unscoreable.
2.0Jun 11, 2026Retabled. Written channel commitments added (§7); return recomputed on the current capital charge (§9); competitive floor proposed (§6); dissent section added (§16). Carried GO WITH CONDITIONS.

Prepared by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Stage-Gate Governance Model · Gate Decision Framework · Gate 1 Recycle Memorandum · Gate Conditions Register.