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.
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.
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.
2. Three Routes, One Launch Date
IIPRC — the Compact 44 states
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
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
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
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.
3. Filing Sequence
| # | Step | Stage | Note | State at 16 Oct 2026 |
|---|---|---|---|---|
| 1 | Contract forms cleared by outside counsel | Stage 2 | Prerequisite to any submission | In progress — third GLWB redraft with counsel (I-05) |
| 2 | Actuarial memorandum and rate support finalized | Stage 2 | Prerequisite; depends on GC-03 | Awaiting the external peer review opinion |
| 3 | Compact submission lodged | Stage 3, early | Starts the IIPRC review clock (DEP-01) | Not started — Stage 3 is unfunded |
| 4 | California and Florida SERFF submissions lodged | Stage 3, early — in parallel | Deliberately parallel, not sequential (D-06) | Not started |
| 5 | Objection and response cycles | Stage 3, ongoing | Duration not within the program's control | Not started |
| 6 | Compact approval received | Stage 3, late | Gate 3 must-meet | Forecast only |
| 7 | Non-Compact approvals received or dated in writing | Stage 3 late / Stage 4 | Gate 3 must-meet, with a written path acceptable in lieu | Forecast only |
| 8 | State-by-state activation on the admin platform | Stage 4 | Follows each approval | Not 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.
| Option | Threshold | Consequence |
|---|---|---|
| Full footprint | All 46 states approved | Cleanest, 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 Florida | Launches on the Compact block plus one large non-Compact market; remaining states activate as approvals land. |
| Compact only | 44 Compact states, neither CA nor FL | Technically launchable and commercially weak — it removes two of the largest annuity markets from a Year 1 forecast already 9% short on written commitments. |
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
| ID | Risk | Effect on this plan |
|---|---|---|
| R-01 | IIPRC review extends past the standard clock over the non-standard GLWB rider feature | Delays the Compact block — 44 of 46 states at once. The single largest schedule exposure in the program, and entirely outside its control. |
| R-02 | Non-Compact approvals land later than Compact, forcing a phased rollout | Exactly 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-02 | Assumes the Compact accepts the product under existing uniform standards, with no new standard needed | Cannot be tested until the submission is lodged. If it fails, the route itself changes and the plan is rewritten rather than adjusted. |
| I-05 | GLWB contract form language returned twice by outside counsel | Upstream of every route. Nothing can be filed until forms clear, so this is currently the binding constraint on step 1. |
6. Cost and Gate Dependencies
| Item | Detail |
|---|---|
| Budget line | $415,000 — filing fees across the Compact and non-Compact states, plus outside insurance counsel. Program Budget §4. |
| Gate 2 relevance | Contract 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 relevance | Compact 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 relevance | State activation completeness feeds launch readiness. The footprint decision at §4 should already be made by this point. |
7. Gaps
| ID | Gap |
|---|---|
| FG-01 | The 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-02 | No 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-03 | Objection-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-04 | New 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.