Lighthouse Financial Services Company — The record of a product development programme this Gate Review Board cancelled. The Harborline Buffer Series, a registered index-linked annuity concept, passed Gate 0 in March 2025 and was stopped at Gate 1 on 07 August 2025. This document records the grounds, the vote, the execution of the cancellation protocol and the final accounting. It exists because a governance record containing only approvals is a record of nothing.
| Programme | Harborline Buffer Series — registered index-linked annuity (RILA) concept |
| Gate 0 | 06 March 2025 — GO |
| Gate 1 | 07 August 2025 — CANCEL, carried 1-4 |
| Funding released | $1,140,000 (Stage 1 only) |
| Funding spent | $868,000 |
| Returned to capital | $272,000 |
| Final accounting filed | 04 September 2025 |
| Chair | C. Tyrrell, NPD Programme Manager (non-voting) |
1. The concept
Harborline was a registered index-linked annuity: a contract crediting index-linked interest with a defined buffer absorbing a first tranche of index loss, and the contract owner exposed to loss beyond it. That downside participation is what makes a RILA a registered product. It brings the contract inside securities registration and brings its distribution inside broker-dealer licensing.
The strategic case was straightforward and, on the demand side, correct: RILA sales across the industry were growing faster than fixed indexed annuity sales, the carrier had no participant in that segment, and distribution partners were asking for one.
2. Why it was stopped
Three grounds were recorded. The first two are causes; the third is their consequence.
Ground 1 — The registration and distribution burden was not carried by the case
A registered product requires securities registration, prospectus delivery, and distribution through broker-dealer channels with licensing and supervision obligations the carrier's existing independent-agent distribution does not carry. Stage 1 costed that burden properly for the first time — which is what Stage 1 is for — and it was materially larger in both cost and elapsed time than the Gate 0 screening had assumed.
The Gate 0 assessment had scored feasibility on the carrier's ability to build the product. It had not adequately weighted the carrier's ability to distribute one through a channel it did not operate in.
Ground 2 — The buffered structure exceeded in-house hedging capability
Hedging a buffer requires an options strategy materially different from the capped-upside structures the Investments desk runs against the existing annuity block. The assessment concluded the capability could be acquired, but only by outsourcing execution — which contradicted the carrier's ALM operating model and added recurring cost to a product whose margin was already under pressure from Ground 1.
Recorded at the time: a guarantee the organisation cannot hedge with its own hands is a guarantee it does not fully control.
Ground 3 — Under Grounds 1 and 2 the product did not clear the hurdle
Loaded with the registration and distribution costs and the outsourced hedging cost, the projected return fell below the carrier's hurdle rate. No repriced structure tested during Stage 1 cleared it while remaining competitive on buffer level and cap.
The Board did not treat this as a pricing problem to be solved in Stage 2. It treated it as the arithmetic consequence of two structural facts that Stage 2 spending would not change.
3. The vote
| Seat | Vote | Recorded position |
|---|---|---|
| Chief Product Officer — Executive Sponsor | Cancel | Segment remains strategically attractive; this structure is not the way in |
| Chief Actuary | Cancel | No tested structure clears the hurdle at a competitive buffer and cap |
| General Counsel & Chief Compliance Officer | Cancel | Registration and supervision obligations exceed the compliance operating model |
| Chief Financial Officer | Cancel | Capital better deployed against a product the carrier can distribute today |
| Head of Distribution | Continue | Channel demand is real and unmet; recommended re-scoping rather than cancelling |
| Carried 1-4 | Cancel | |
4. Execution of the cancellation protocol
Governance Model §13 sets out seven steps on a cancel. All seven were executed and are recorded here.
5. Final accounting
| Concept and product design - structure, buffer levels, rider | $284,000 |
| Actuarial pricing and capital modelling | $246,000 |
| Registration and distribution licensing assessment (external counsel) | $198,000 |
| Hedging capability assessment | $88,000 |
| Program management | $52,000 |
| Total spent | $868,000 |
| Stage 1 tranche released at Gate 0 | $1,140,000 |
| Returned to the capital pool | $272,000 |
The single largest line is the registration and distribution licensing assessment. That is the correct shape for a Stage 1 that did its job: the money went into establishing the fact that cancelled the programme, and it was spent before the far larger development tranche was committed.
6. Work product preserved
Indexed and retained under step 5, available to any subsequent concept on the same terms as any other internal research:
- Market sizing and segment analysis for index-linked products.
- Distribution appetite research, including the partner conversations behind Distribution's dissenting vote.
- The registration and licensing assessment — the most durable output, and the one that made the successor's Gate 0 case straightforward to frame.
- The hedging capability assessment, including what the desk can and cannot execute in-house.
- Actuarial pricing models for index-linked structures, with assumptions documented and dated.
What was not preserved: the programme. No team, no funding, no schedule and no approvals carried forward. Preserved research is an input available to anyone; it is not a running programme in suspension.
7. Why the successor is a new programme and not a restart
The distinction is procedural and auditable, and it is set out here so that it can be checked rather than asserted.
| Test | Harborline | Beacon Index Advantage |
|---|---|---|
| Programme status | Closed 07 Aug 2025; final accounting filed | New programme, screened at Gate 0 on 05 Feb 2026 |
| Funding | Cancelled; $272,000 returned | New Stage 1 tranche earned at its own Gate 0 |
| Entry point | — | Gate 0, not Gate 1. Nothing was resumed |
| Business case | Rejected at Gate 1 | Written new; recycled once at its own Gate 1 before carrying |
| Team | Released and reassigned | Staffed independently |
| Product structure | Registered, buffered, downside participation | Non-registered, capped, principal protected — a different product |
| Elapsed between them | 182 days between the cancel and the successor's Gate 0 | |
The two programmes are connected by a lesson, not by a ledger. Harborline established that the registration burden — not the product idea, not the market — was the binding constraint. Beacon Index Advantage is a fixed indexed annuity precisely because of that finding, which is recorded as decision D-01. The successor serves the same demand from the non-registered side of the line, where the carrier's existing distribution, compliance model and hedging desk all already operate.
Stated plainly: this programme exists in the form it does because the Board cancelled the previous version of it.
8. What the Board changed as a result
| Finding | Change |
|---|---|
| Gate 0 scored feasibility on the ability to build, not to distribute | Gate 0 must-meet criteria now include that the concept does not require a capability the organisation has already decided not to build; distribution appetite became a scored criterion in its own right |
| Hedging capability was assessed late in Stage 1 | Hedgeability with in-house capability became a Gate 1 must-meet on the successor programme, certified by name |
| The strategic case outran the economics for two quarters | Cancellation thresholds are now published in advance for each gate rather than debated in the room (Governance Model §13.1) |
These are the reason the successor's Gate 1 must-meet list reads as it does. A governance model that produces the same failure twice has not learned anything from producing it once.
9. Document control
| Version | Date | Change |
|---|---|---|
| 1.0 | 07 Aug 2025 | Filed on the day of the decision. Grounds, vote and protocol steps 1, 3, 4 and 7. |
| 1.1 | 04 Sep 2025 | Final accounting added (§5); work product index completed (§6). Record closed. |
| 1.2 | 05 Feb 2026 | Reopened once, on the successor's Gate 0, to add §7 and §8 — the new-programme test and the governance changes. No figures altered. |
Filed by C. Tyrrell, NPD Programme Manager and Chair of the Gate Review Board. Related: Stage-Gate Governance Model §13 and §18 · Gate Decision Framework §7.