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Regulatory Filing Plan

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Lighthouse Financial Services Company — How Beacon Index Advantage reaches 46 states through three separate routes against one fixed launch date of 06 March 2028. Status as at 16 October 2026; no submission has been lodged, because Stage 3 is not funded.

46
Target states
3
Filing routes
44
Covered by one Compact filing
$415,000
Filing fees & outside counsel
Contents
  1. The One Plan That Cannot Be Compressed
  2. Three Routes, One Launch Date
  3. Filing Sequence
  4. What Counts as Enough States to Launch?
  5. What Can Go Wrong
  6. Cost and Gate Dependencies
  7. Gaps

1. The One Plan That Cannot Be Compressed

Every other schedule risk on this program can be worked. Configuration can be resourced harder. Testing can run in parallel. A vendor can mobilize faster. The Gate 1 recycle cost six weeks and the program absorbed it by compressing Stage 2 from 46 weeks to 40.

A state insurance department's review clock cannot be accelerated by anything the carrier does. That is dependency DEP-01 in one line, and this plan is what it means in practice. If the program arrives at Stage 3 having spent its float, the filing route is where that shows up — and it will show up as a launch date, not as a variance.

The consequence runs through the rest of this document: the program can commit to submission quality and to nothing else. Approval is not a deliverable it can promise. So the plan measures itself on readiness to file — forms cleared, actuarial memorandum complete, rate support assembled — and treats approval dates as forecasts belonging to somebody else.

This is also why Gate 3's must-meet is worded the way it is. It requires “Compact approval obtained, or a dated approval path confirmed in writing — a criterion that can be satisfied by evidence the program can actually produce. A must-meet demanding approval outright would make the gate hostage to a third party, and a gate nobody can pass is not a control.

2. Three Routes, One Launch Date

IIPRC — the Compact 44 states

Mechanism
One filing, uniform standards
Owner
P. Hollingsworth
Register
DEP-01

A single submission against the Compact's uniform standards for individual annuity products. Approval applies across every member state that has adopted the relevant standard. This is the route Decision D-06 puts first, and it is the reason the filing plan is one filing rather than forty-four.

SERFF — California 1 state

Mechanism
Separate filing, own review clock
Owner
P. Hollingsworth
Register
DEP-02

California is not a Compact member for this product class and reviews on its own terms and its own timetable. It is also one of the two largest annuity markets in the launch footprint, which is why its timing drives §4 rather than sitting in a footnote.

SERFF — Florida 1 state

Mechanism
Separate filing, own review clock
Owner
P. Hollingsworth
Register
DEP-02

Filed separately for the same reason and on the same basis. Florida's annuity market skews older and more rider-sensitive, so a Florida delay bites the GLWB election assumption specifically rather than volume generally.

New York excluded

Mechanism
Not filed
Owner
A. Nkemelu
Register
A-03 / D-02

Out of launch scope entirely. 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. Closed under GC-02 with a deferral memorandum recording the conditions under which it would be revisited.

Filing through the Compact first, with California and Florida in parallel rather than sequentially is Decision D-06. Sequential filing would have been simpler to manage and would have added the non-Compact review clocks to the end of the Compact clock rather than running them alongside it. On a fixed launch date that is not a scheduling preference — it is the difference between launching and not.

3. Filing Sequence

#StepStageNoteState at 16 Oct 2026
1Contract forms cleared by outside counselStage 2Prerequisite to any submissionIn progress — third GLWB redraft with counsel (I-05)
2Actuarial memorandum and rate support finalizedStage 2Prerequisite; depends on GC-03Awaiting the external peer review opinion
3Compact submission lodgedStage 3, earlyStarts the IIPRC review clock (DEP-01)Not started — Stage 3 is unfunded
4California and Florida SERFF submissions lodgedStage 3, early — in parallelDeliberately parallel, not sequential (D-06)Not started
5Objection and response cyclesStage 3, ongoingDuration not within the program's controlNot started
6Compact approval receivedStage 3, lateGate 3 must-meetForecast only
7Non-Compact approvals received or dated in writingStage 3 late / Stage 4Gate 3 must-meet, with a written path acceptable in lieuForecast only
8State-by-state activation on the admin platformStage 4Follows each approvalNot started

Steps 1 and 2 are Stage 2 work and are the only steps the program currently has funding to perform. Everything from step 3 onward sits inside Stage 3, whose tranche of $7,450,000 is not released — so the filing plan is fully specified and entirely unstarted, which is the correct position at this point in a stage-gate program.

4. What Counts as Enough States to Launch?

This is the decision the plan exists to force, and it has not yet been taken.

“Approved” is not binary. The Compact filing either clears or does not, but California and Florida run their own clocks, and objection cycles resolve state by state. What the program will actually have on 06 March 2028 is a footprint — some number of states, of some particular composition. Somebody has to decide in advance what footprint is worth launching on, because deciding it afterwards means deciding it under pressure with a sales force already trained.

OptionThresholdConsequence
Full footprintAll 46 states approvedCleanest, and hostage to the single slowest reviewer. One state can move the launch date.
Proposed threshold≥ 38 of 46 states, and at least one of California or FloridaLaunches on the Compact block plus one large non-Compact market; remaining states activate as approvals land.
Compact only44 Compact states, neither CA nor FLTechnically launchable and commercially weak — it removes two of the largest annuity markets from a Year 1 forecast already 9% short on written commitments.
The Compact-only option is the one to be honest about. It looks like a safe fallback and it is not. Year 1 volume is already the program's most exposed assumption — written commitments stand at $168,000,000 against a $185,000,000 target (issue I-06, risk R-07) — and launching without either large non-Compact market would compound a volume problem the business case can survive only so much of. The Benefits Realization Plan puts the tolerance at a 23% shortfall before the case fails its hurdle.

Recommendation: the Chair proposes the threshold above be tabled for decision at Gate 3 on 28 October 2027, not at Gate 4. A launch-footprint rule decided at Gate 4 is decided six weeks before launch, when the only available answer is whichever one avoids moving the date.

5. What Can Go Wrong

IDRiskEffect on this plan
R-01IIPRC review extends past the standard clock over the non-standard GLWB rider featureDelays the Compact block — 44 of 46 states at once. The single largest schedule exposure in the program, and entirely outside its control.
R-02Non-Compact approvals land later than Compact, forcing a phased rolloutExactly the scenario §4 exists to pre-decide. A phased rollout is workable; an unplanned phased rollout is a distribution and training problem discovered late.
A-02Assumes the Compact accepts the product under existing uniform standards, with no new standard neededCannot be tested until the submission is lodged. If it fails, the route itself changes and the plan is rewritten rather than adjusted.
I-05GLWB contract form language returned twice by outside counselUpstream of every route. Nothing can be filed until forms clear, so this is currently the binding constraint on step 1.
A-02 is the assumption with the worst risk profile in the program. It cannot be validated before Stage 3, it is binary, and if it fails it invalidates the filing route rather than delaying it. The RAIDD log records it as untested for exactly this reason — it is one of the two assumptions that cannot be tested before the gate that depends on them.

6. Cost and Gate Dependencies

ItemDetail
Budget line$415,000 — filing fees across the Compact and non-Compact states, plus outside insurance counsel. Program Budget §4.
Gate 2 relevanceContract forms complete and cleared by outside counsel is a Gate 2 must-meet. Filing readiness is a should-meet criterion at 25% weight — the heaviest single weighting at that gate.
Gate 3 relevanceCompact approval obtained or a dated path confirmed, and non-Compact approvals obtained or scheduled within the launch window, are both Gate 3 must-meets.
Gate 4 relevanceState activation completeness feeds launch readiness. The footprint decision at §4 should already be made by this point.

7. Gaps

IDGap
FG-01The launch-footprint threshold is proposed, not agreed. Until a gate adopts it, the program has no pre-committed answer to the question it is most likely to face, and §4's warning about deciding under pressure stands.
FG-02No filing has been lodged, so every duration in this plan is an estimate from published review targets rather than from this carrier's experience with this product. The estimates are reasonable and they are not evidence.
FG-03Objection-cycle volume is unmodeled. The plan assumes a normal number of objection rounds. A rider feature the Compact has not seen before — which is precisely what R-01 describes — can generate several, and each round is measured in weeks.
FG-04New York's exclusion has no revisit trigger. The deferral memorandum records the conditions under which New York would be reconsidered, but nothing in the program's governance schedules that reconsideration. It will happen when somebody remembers to raise it.

Maintained by P. Hollingsworth, Manager — Product Filing, under B. Lindqvist, General Counsel & Chief Compliance Officer. Related: Methodology Guide §4 · Gate Decision Framework §9–10 · RAIDD Log (R-01, R-02, A-02, DEP-01, DEP-02, I-05) · Benefits Realization Plan.