Lighthouse Financial Services Company — The five conditions attached to the GO WITH CONDITIONS decision at Gate 1 on 11 June 2026. This is a live document, maintained by the Chair between gates and tabled at Gate 2 on 01 April 2027. Status as at 16 October 2026.
1. The register at a glance
| ID | Condition | Owner | Addresses | Status |
|---|---|---|---|---|
| GC-01 | Reduce launch crediting strategies from five to three | D. Falkner | Feasibility (scored 3); I-02 illustration engine limitation | Closed 21 Jul 2026 |
| GC-02 | Remove New York from launch scope and issue a deferral memorandum | A. Nkemelu | The GC/CCO abstention recorded at the gate | Closed 03 Jul 2026 |
| GC-03 | Independent external actuarial peer review of GLWB rider pricing before Gate 2 | S. Ravichandran | Competitive position and financial return (both scored 3); R-06 | Open · due 26 Feb 2027 |
| GC-04 | Re-validate distribution volume assumptions with the three largest IMO partners | R. Castellanos | Distribution commitment (scored 3); the U rating at the first convening | Closed 14 Aug 2026 |
| GC-05 | Present a hedging readiness plan with ISDA execution milestones at Gate 2 | M. Delacroix | Feasibility (scored 3); R-05 hedging readiness lagging launch | At risk · due 12 Mar 2027 |
All five were issued at the same gate and all five fall due before Gate 2 — that is a rule, not a coincidence. A condition that cannot be verified before the next gate has no enforcement point and is a recommendation wearing a condition's clothing.
2. GC-01 — Reduce launch crediting strategies from five to three
GC-01 Closed 21 Jul 2026
Condition as issued
Reduce the launch crediting strategy set from five to three, and confirm the reduced set with Actuarial before Stage 2 development of the illustration configuration begins.
Why it was issued
Feasibility scored 3. Issue I-02 had established that the incumbent illustration engine cannot produce compliant hypothetical performance for two of the five proposed structures, and building that capability was not justified by their forecast contribution.
Verification method (as recorded at issue)
Revised product specification accepted in writing by Actuarial.
Evidence and closure
Revised specification issued and accepted; the launch set is the fixed account, a one-year point-to-point on the Calder Balanced 5 Index with a cap, and a one-year performance-triggered strategy. Recorded as decision D-03.
Post-closure efficacy
Effective. The condition removed a dependency rather than deferring it — the two strategies are out of scope, not postponed, and their build allocation returned to the reserve. It also created a second-order consequence the Board was told about: concentration risk in the remaining indexed strategy, raised as dissent at Gate 1 and carried as risk R-12.
3. GC-02 — Remove New York from launch scope
GC-02 Closed 03 Jul 2026
Condition as issued
Remove New York from launch scope and issue a deferral memorandum recording the basis for the exclusion and the conditions under which it would be revisited.
Why it was issued
The General Counsel & Chief Compliance Officer abstained at the gate pending this memorandum. New York is not a Compact member and imposes distinct product and conduct requirements; carrying it inside a first launch would have added a workstream the business case did not fund.
Verification method (as recorded at issue)
Memorandum filed with Legal; the program scope statement updated to match.
Evidence and closure
Memorandum filed and scope statement updated. Recorded as assumption A-03 and decision D-02. Closed fastest of the five, and the abstention was resolved by its closure.
Post-closure efficacy
Effective. The exclusion is now load-bearing rather than assumed: the filing plan, distribution footprint and Stage 4 training scope all derive from it. The deferral memorandum also means a future New York decision starts from a recorded rationale rather than from an argument about what was originally intended.
4. GC-03 — Independent external actuarial peer review
GC-03 Open · due 26 Feb 2027
Condition as issued
Commission an independent external actuarial peer review of the guaranteed lifetime withdrawal benefit pricing basis, and table the signed opinion at Gate 2.
Why it was issued
Competitive position and financial return both scored 3, and the return had already moved 120 basis points between the two convenings of Gate 1. The rider is the source of the guarantee exposure and of most of the product's fee income, and its pricing rests on behavioural assumptions the carrier has modelled rather than observed. Risk R-06.
Verification method (as recorded at issue)
A signed external opinion, with its assumptions stated, tabled at Gate 2. An opinion in preparation does not satisfy the evidence standard.
Status at 16 October 2026
On track. Ardmore Actuarial Partners engaged; engagement letter executed and the reserve draw of $180,000 authorised at Gate 1. Data room populated with the pricing basis, assumption documentation and experience data. Fieldwork begins in November, reporting ahead of the 26 February 2027 due date with margin before Gate 2.
5. GC-04 — Re-validate distribution volumes
GC-04 Closed 14 Aug 2026
Condition as issued
Re-validate the Year 1 volume assumption with the three largest IMO partners and obtain written indications of intended production.
Why it was issued
This is the condition that carries the first convening forward. Distribution commitment was rated U on 30 April 2026 because the forecast rested on internal modelling with no written partner evidence — the finding that produced the recycle.
Verification method (as recorded at issue)
Written indications from three named partners, with the aggregate stated against the Year 1 target and any shortfall disclosed rather than closed by assumption.
Evidence and closure
Written Year 1 indications held from Northgate Financial Group, Sentinel Advisory Network and Copperfield Insurance Marketing, totalling $168,000,000 against a Year 1 target of $185,000,000. Verified against the method and closed.
This entry is the reason the register carries an efficacy finding at all. A condition can be verified, closed on time, and leave the risk it was issued against entirely intact. Recording only the closure date would have made this look like a resolved item.
6. GC-05 — Hedging readiness plan with ISDA milestones
GC-05 At risk · due 12 Mar 2027
Condition as issued
Present a hedging readiness plan at Gate 2, with dated ISDA execution milestones, accepted by the Chief Financial Officer and the Chief Risk Officer.
Why it was issued
The guarantee cannot be sold if it cannot be hedged, and the must-meet certification at Gate 1 was given on in-house capability with a readiness plan to follow. Risk R-05.
Verification method (as recorded at issue)
Plan accepted in writing by the CFO and the CRO. Acceptance of the plan, not completion of the milestones — the milestones themselves run into Stage 3.
Status at 16 October 2026
At risk. The plan is drafted and the target operating model is agreed. Counterparty onboarding is where it is exposed: of the two derivatives counterparties required under DEP-06, one is at executed term sheet and the second has not begun negotiation.
Escalation
Raised at the monthly program review on the September cycle. If the second counterparty has not entered negotiation by the January review, the Chair will table it as a standing Gate 2 agenda item with a recommendation that the gate consider a condition re-issue with a hard date rather than a closure.
7. Tracking cadence and verification protocol
| When | What happens | Who |
|---|---|---|
| Monthly program review | Every open condition reviewed against its due date and evidence trajectory; at-risk assessments set or cleared | Chair with condition owners |
| On owner request | Evidence submitted against the recorded verification method | Owner |
| Within five business days of submission | Chair verifies against the method as issued — not against a method renegotiated at closure | Chair |
| On closure | Closure date, evidence and an efficacy finding recorded in this register | Chair |
| Ten business days before Gate 2 | Register tabled in the gate package with all statuses current | Chair |
Owners cannot close their own conditions, and the verification method cannot be varied by agreement between the owner and the Chair. Varying it requires a Board decision, minuted — because a method that can be relaxed at closure is not a method, it is an aspiration.
8. What happens at Gate 2 if a condition is open
An open condition at the next gate is an automatic agenda item under Governance Model §9 and may itself trigger a recycle. The Board's options are:
- Verify and close — evidence satisfies the method as issued.
- Re-issue with a new date — the condition stands, the deadline moves, and the re-issue is minuted with reasons. Available only where the delay does not compound.
- Recycle the gate — where the open condition prevents the gate's must-meet criteria from being certified. GC-03 sits in this category: the Gate 2 must-meet list requires pricing "supported by the independent external review required under GC-03."
- Escalate to a cancel consideration — where the condition is open because the underlying problem has proved unsolvable rather than merely late.
9. The standing efficacy question
Every closed condition in this register carries a finding on whether closing it changed anything. This is not commentary; it is a control, and it feeds Gate 5.
| ID | Closed | Did closure change the underlying position? |
|---|---|---|
| GC-01 | 21 Jul 2026 | Yes — scope permanently reduced, dependency removed, allocation returned to reserve |
| GC-02 | 03 Jul 2026 | Yes — exclusion now load-bearing across filing, distribution and training scope |
| GC-04 | 14 Aug 2026 | Partially — evidence obtained, but $17,000,000 of Year 1 premium remains uncommitted; the risk is unchanged and now sits with I-06 and R-07 |
Gate 5 reviews whether the conditions issued at Gate 1 achieved what they were issued to achieve. On the current record, two did and one produced evidence without producing a remedy. That is a finding about the condition mechanism, not about the owner: GC-04 was well specified and correctly verified. It simply could not, by itself, make partners commit volume they had not committed.
10. Document control
| Version | Date | Change |
|---|---|---|
| 1.0 | 11 Jun 2026 | Register opened at the Gate 1 second convening with five conditions. |
| 1.1 | 03 Jul 2026 | GC-02 verified and closed; GC/CCO abstention resolved. |
| 1.2 | 21 Jul 2026 | GC-01 verified and closed; D-03 recorded. |
| 1.3 | 14 Aug 2026 | GC-04 verified and closed. Efficacy finding added — $17,000,000 uncommitted premium disclosed and referred to I-06 and R-07. |
| 1.4 | 16 Oct 2026 | GC-05 assessed at risk following the September program review. Efficacy question formalised at §9. |
Maintained by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Stage-Gate Governance Model §11 · Gate Decision Framework · Gate 1 Business Case Package · Gate 1 Recycle Memorandum.