Lighthouse Financial Services Company — Every risk, assumption, issue, dependency and decision carried by the Beacon Index Advantage program, with a 2-digit ID assigned in the fact pack before the first artifact was written, so nothing in this suite ever needed to invent a register entry after the fact. Status current as at 16 October 2026.
Risk Register (R-01..12)
| ID | Risk | Owner | Gate 1 | Now | Status | Response |
|---|---|---|---|---|---|---|
| R-01 | IIPRC review extends past the standard clock over a non-standard GLWB rider feature | P. Hollingsworth | 12 | 12 → | Open | Monitor |
| R-02 | Non-Compact state approvals (CA, FL) land later than Compact states, forcing a phased rollout | P. Hollingsworth | 9 | 9 → | Open | Monitor |
| R-03 | Option budget compresses if index option costs rise, pushing the illustrated cap below competitive | S. Ravichandran | 12 | 12 → | Open | Monitor |
| R-04 | Cordelane cannot support the participation-rate strategy without custom development | V. Sandoval | 9 | 1 ↓ | Closed by scope cut | Retired — absorbed into GC-01 / D-03 |
| R-05 | Hedging readiness (ISDA, derivatives ops, daily rebalance) lags launch | M. Delacroix | 15 | 20 ↑ | Open — elevated | Active — drives GC-05 |
| R-06 | Pricing assumptions (lapse, GLWB utilization) prove unsupportable under external peer review | S. Ravichandran | 15 | 15 → | Open | Active — drives GC-03 |
| R-07 | Distribution partners deprioritize against competitor launches in the same quarter | R. Castellanos | 12 | 16 ↑ | Open — elevated | Active — linked to I-06 |
| R-08 | Illustration engine cannot produce compliant hypothetical illustrations inside the filing window | E. Kowalczyk | 16 | 8 ↓ | Open — reduced | Active, lower severity after GC-01 scope cut |
| R-09 | Statutory reserve and capital treatment is heavier than modeled, degrading product IRR | T. Brennan | 8 | 8 → | Open | Monitor |
| R-10 | Single credentialed pricing actuary sits on the critical path | S. Ravichandran | 16 | 4 ↓ | Realized, closed | Realized as I-03; vacancy filled 08 Sep 2026 |
| R-11 | Advisor appointment/licensing throughput limits producing agents at launch | H. Kirkpatrick | 6 | 6 → | Open | Monitor |
| R-12 | Post-launch sales concentrate in one crediting strategy, creating hedging concentration | M. Delacroix | 9 | 9 → | Open | Monitor — raised as dissent at Gate 1 |
Assumptions (A-01..08)
| ID | Assumption | Owner |
|---|---|---|
| A-01 | Licensed and in good standing across all 46 target states through launch | P. Hollingsworth |
| A-02 | The Compact accepts the product under existing uniform standards; no new standard needed | P. Hollingsworth |
| A-03 | New York is out of launch scope | A. Nkemelu |
| A-04 | The existing admin platform is extended, not replaced | V. Sandoval |
| A-05 | Distribution runs through existing IMO/broker-dealer relationships; no new channel | R. Castellanos |
| A-06 | Hedging is executed by the in-house Investments desk | M. Delacroix |
| A-07 | Rates stay inside the Gate 1 pricing corridor | S. Ravichandran |
| A-08 | No competing internal launch draws the same actuarial and IT people in 2027 | G. Marchetti |
Issue Log (I-01..06)
| ID | Issue | Owner | Status | Resolution / Note |
|---|---|---|---|---|
| I-01 | Gate 1 recycled 30 Apr 2026 — distribution volume assumptions never validated with the wholesaler channel, and the hurdle-rate calc used a superseded capital charge | C. Tyrrell | Closed | 6-week loop, $232,000; see Gate 1 Recycle Memorandum |
| I-02 | Brightpath's hypothetical-performance module can't support 2 of the 5 proposed crediting strategies | E. Kowalczyk | Closed by scope cut | Resolved via GC-01 / D-03 — 2 strategies removed, not built around |
| I-03 | Lead pricing actuary vacancy — 11 weeks open | G. Marchetti | Closed | Filled 08 Sep 2026 (realization of R-10) |
| I-04 | Config environment shared with an in-flight servicing release → test-window contention | V. Sandoval | Open | Being scheduled around in Stage 3 planning |
| I-05 | GLWB contract form language returned twice by outside counsel over free-look / death-benefit interaction | A. Nkemelu | Open | Third redraft with counsel; see Gate 2 Readiness Assessment |
| I-06 | Plan assumed 6 field wholesalers; Distribution can commit 4 at launch | R. Castellanos | Open | Linked to the GC-04 efficacy finding and the $17,000,000 uncommitted Year 1 gap |
Dependency Log (DEP-01..07)
| ID | Dependency | Owner | Status |
|---|---|---|---|
| DEP-01 | IIPRC review clock — external regulator, cannot be compressed | P. Hollingsworth | Ongoing |
| DEP-02 | California and Florida department review, separate SERFF filings | P. Hollingsworth | Ongoing |
| DEP-03 | Cordelane's quarterly configuration windows | V. Sandoval | Ongoing |
| DEP-04 | Calder index licensing agreement | D. Falkner | Executed |
| DEP-05 | Halverson Re term sheet for GLWB risk transfer | M. Delacroix | Executed |
| DEP-06 | ISDA/CSA execution with two derivatives counterparties | M. Delacroix | One executed, one not yet begun — drives GC-05 |
| DEP-07 | Corporate Actuarial's annual assumption refresh, feeds Gate 2 re-pricing | T. Brennan | Scheduled |
Decision Log (D-01..11)
| ID | Decision | Decided By | Date |
|---|---|---|---|
| D-01 | FIA, not a RILA — keeps the product out of SEC/FINRA and in the state filing lane | Gate Review Board | 05 Feb 2026 |
| D-02 | New York excluded from launch scope (GC-02) | B. Lindqvist | 11 Jun 2026 |
| D-03 | Launch with 3 crediting strategies, not 5 (GC-01) | D. Falkner | 21 Jul 2026 |
| D-04 | Configure the incumbent illustration vendor rather than procure new; 2 strategies deferred | D. Falkner | 21 Jul 2026 |
| D-05 | GLWB offered as an optional rider, not embedded | G. Marchetti | 05 Feb 2026 |
| D-06 | File through the Compact first, with CA/FL in parallel rather than sequentially | B. Lindqvist | 05 Feb 2026 |
| D-07 | Extend the existing admin platform rather than stand up a new product-line system | V. Sandoval | 05 Feb 2026 |
| D-08 | Hedging executed in-house by Investments | M. Delacroix | 05 Feb 2026 |
| D-09 | Contingency is held by the Gate Review Board; release requires a gate decision | Gate Review Board | 05 Feb 2026 |
| D-10 | No full-program EVM baseline; performance reported within the released tranche | J. Whitmore | 05 Feb 2026 |
| D-11 | The gate chair facilitates and does not vote; the five voting seats are functional executives | Gate Review Board | 05 Feb 2026 |
Gate Conditions Summary (GC-01..05)
Gate Conditions carry their own full register — owner, verification method, evidence and a post-closure efficacy finding — because a condition is a binding obligation with a due date, not a tracked item like the five categories above. This log carries only a status summary so a reader does not have to leave the RAIDD log to see whether a condition is open; the Gate Conditions Register is the sole source of truth for condition detail.
| ID | Condition | Owner | Status |
|---|---|---|---|
| GC-01 | Reduce launch crediting strategies from five to three | D. Falkner | closed |
| GC-02 | Remove New York from launch scope and issue a deferral memorandum | A. Nkemelu | closed |
| GC-03 | Independent external actuarial peer review of GLWB rider pricing before Gate 2 | S. Ravichandran | open |
| GC-04 | Re-validate distribution volume assumptions with the three largest IMO partners | R. Castellanos | closed |
| GC-05 | Present a hedging readiness plan with ISDA execution milestones at Gate 2 | M. Delacroix | at-risk |
What the register says when you read it sideways
A register is only a control if somebody reads across it. Five findings fall out of the tables above that none of the individual rows state.
1. In stage-gate, a RAIDD log is gate evidence — not a management tool
On a conventional program the register is an internal tracking artifact; nobody outside the PMO reads it. Here it is tabled at every gate and the Board scores feasibility and residual risk position partly from it. That changes what belongs in it: an entry exists to be defensible in front of five executives who can cancel the program, not to reassure the team. It is the reason every risk above carries a named individual rather than a function, and the reason the closed entries stay visible instead of being archived — a Board that cannot see what was closed cannot judge whether closing it was right.
2. Two risks realized, and the register shows what each cost
| Risk | Became | Outcome |
|---|---|---|
| R-10 single credentialed pricing actuary on the critical path | I-03 | 11-week vacancy, filled 08 Sep 2026. Score fell 16 → 4: the impact is unchanged, only the probability collapsed once the seat was filled. |
| R-04 platform cannot support the participation-rate strategy | Retired by D-03 | Score fell 9 → 1 — not mitigated, removed. The scope containing it was cut under GC-01, which is the cheapest way a risk ever leaves a register. |
Both movements are downward for structurally different reasons, and the distinction matters at a gate: one was solved, the other was deleted. Only the second reduces the program's future exposure permanently.
3. The register got riskier in exactly two places, and both are Gate 2 blockers
R-05 (hedging readiness) rose 15 → 20 and R-07 (distribution deprioritization) rose 12 → 16. Every other open risk is flat. That is not a coincidence: those two are the risks behind the only two Gate Conditions still open, GC-05 and the residue of GC-04. The register and the conditions register are telling the same story from opposite ends — which is what you want, and would be a defect if they disagreed.
4. Ownership concentrates, and that is itself unmanaged
Twelve risks sit with eight owners, but the two highest-scoring open risks (R-05 at 20, R-06 at 15) both trace to functions with a single credentialed decision maker — the Director of ALM & Hedging and the Lead Pricing Actuary. R-10 was the generic version of that exposure and it realized. The register does not currently carry a successor-risk for the hedging seat, and the Chair's position is that it should before Gate 2.
5. A decision is not a full stop — D-03 created R-12
Cutting from five crediting strategies to three (D-03, under GC-01) closed I-02 and retired R-04. It also concentrated future sales into fewer strategies, which is R-12 — a risk that did not exist before the decision that resolved two others. It was raised as a formal dissent at Gate 1 rather than discovered later. Registers that only record what a decision closed, and never what it opened, drift toward looking like every choice was free.
Assumption validity at the status date
Assumptions are the entries most likely to rot quietly, because nothing forces a re-read. All eight are re-tested at each gate; this is their position at 16 October 2026.
| ID | Still safe? | Basis |
|---|---|---|
| A-01 | Holding | Licensing confirmed across the 46-state target footprint; no adverse change. |
| A-02 | Untested | Cannot be confirmed until the Compact filing is actually submitted in Stage 3. Carried as R-01. |
| A-03 | Converted | No longer an assumption — became decision D-02 when GC-02 closed. Kept visible so its origin is traceable. |
| A-04 | Holding | Platform extension proceeding; the one strategy that would have broken it was cut (D-03). |
| A-05 | Strained | Holds structurally, but the channel is delivering below plan — see I-06. |
| A-06 | At risk | In-house hedging is assumed, and readiness is the program's highest-scoring open risk (R-05). |
| A-07 | Monitored | Rates inside the Gate 1 corridor at the status date; re-tested at Gate 2 re-pricing via DEP-07. |
| A-08 | Untested | Concerns 2027 resource contention; cannot be validated from inside 2026. |
Maintained by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Program Charter §16–19 · Gate Conditions Register · Gate 2 Readiness Assessment.