Requirements Traceability Matrix — Beacon Index Advantage

Program timeline · status 16 Oct 2026Read the full story →

Harborline

Aug 2025

Cancelled

Gate 0

Feb 2026

Stage 1

Business case

Gate 1

Apr 2026

Recycled

Gate 1

Jun 2026

Go w/ conditions

Stage 2

Development

You are here

Gate 2

Apr 2027

Gate 3

Oct 2027

Gate 4

Feb 2028

Launch

Mar 2028

Gate 5

Sep 2028

Lighthouse Financial Services Company — Every product, regulatory and operational requirement for Beacon Index Advantage, traced to the gate that authorized it and the gate that will verify it. Status as at 16 October 2026.

Requirements traced

Active

Withdrawn, still traceable

Excluded by decision

Contents

Why This Matrix Traces to Gates, Not Just to Tests
Active Requirements
Withdrawn and Excluded — Kept Traceable on Purpose
Forward Trace
Verification Coverage by Gate
Traceability Gaps
Document Control

1. Why This Matrix Traces to Gates, Not Just to Tests

A conventional traceability matrix runs one direction: requirement → design → build → test case → result. That is necessary here too, and §4 carries it. But it is not sufficient in a stage-gate program, because a requirement in this program has two decision endpoints, not one.

Authorized at a gate. No requirement exists because someone wrote it down. It exists because a gate released the funding for the stage that builds it. PR-04 through PR-06 were authorized at Gate 1; PR-01 through PR-03 predate it and were authorized at Gate 0.
Verified at a gate. Test evidence is tabled to a specific gate as part of a must-meet certification. A requirement whose verification does not land at a gate is a requirement nobody is obliged to check.

The practical consequence: a requirement can be traced to the exact decision that created it and the exact decision that will close it. That is a stronger claim than "it has a test case," and it is the claim a gate actually needs — because at a gate the question is not "was this tested?" but "is the Board entitled to rely on this being done?"

2. Active Requirements

ID	Requirement	Source	Auth.	Verified	Status
PR-01	Single-premium deferred fixed indexed annuity chassis	Gate 0 concept · D-01	G0	G3	Active
PR-02	Seven-year declining surrender-charge schedule	Gate 0 concept	G0	G3	Active
PR-03	Optional GLWB rider (not embedded)	D-05	G0	G3	Active
PR-04	Fixed account crediting strategy	D-03 launch set	G1	G2	Active
PR-05	One-year point-to-point on the Calder Balanced 5, capped	D-03 launch set · DEP-04	G1	G2	Active
PR-06	One-year performance-triggered crediting strategy	D-03 launch set	G1	G2	Active
PR-09	Compact-route filing across member states	D-06 · A-02	G1	G3	Active
PR-10	Separate SERFF filings for California and Florida	D-06 · DEP-02	G1	G3	Active
PR-12	Compliant hypothetical performance illustrations	NAIC #275 · R-08	G1	G2	Active
PR-13	Suitability and best-interest advisor training	NAIC Model Reg #275	G1	G4	Active
PR-15	Extension of the incumbent admin platform (no new system)	D-07 · A-04	G1	G2	Active
PR-16	GLWB risk transfer via reinsurance	DEP-05	G1	G3	Active
PR-17	New business issue and policyholder servicing capability	Gate 1 scope	G1	G4	Active
PR-18	Distribution through existing IMO/BD relationships only	A-05	G1	G4	Active
PR-14	In-house hedging of the GLWB guarantee	D-08 · A-06	G1	G4	At risk

PR-14 is the only active requirement carrying an at-risk trace. In-house hedging of the GLWB guarantee runs through GC-05 to ISDA execution under DEP-06, where one of two counterparties has not begun negotiation. The requirement is authorized, the design exists, and the verification chain is incomplete at a point outside the program's control. Every other document in this suite flags the same item from a different angle — which is the register agreement you want, not duplication.

3. Withdrawn and Excluded — Kept Traceable on Purpose

Two crediting strategies were cut at Gate 1 under GC-01, recorded as decision D-03. They remain in this matrix as withdrawn rows rather than being deleted from it.

ID	Requirement	Source	Auth.	Verified	Status
PR-07	Participation-rate crediting strategy	Gate 0 concept (5-strategy set)	G0	—	Withdrawn
PR-08	Monthly-averaged crediting strategy	Gate 0 concept (5-strategy set)	G0	—	Withdrawn
PR-11	New York excluded from launch scope	A-03 · D-02 · GC-02	G1	—	Excluded by decision

An RTM that deletes cut requirements cannot answer the most common question asked of a launched product: “why doesn't it do X?” With PR-07 and PR-08 retained, the answer is a citation rather than an argument: withdrawn at Gate 1 on 11 June 2026 under GC-01, recorded as D-03, because the incumbent platform and illustration engine could not support them (R-04, I-02) and their forecast contribution did not justify building the capability. The build allocation returned to reserve.

The distinction between withdrawn and excluded is deliberate and is not cosmetic. PR-07 and PR-08 were in scope and were removed. PR-11 — New York — was never in launch scope; it is an exclusion with a deferral memorandum recording the conditions under which it would be revisited. Collapsing the two would make a considered scope decision look like a cut, and a cut look like a considered scope decision.

4. Forward Trace

The conventional chain, requirement through to the evidence that closes it.

ID	Trace
PR-01	Product spec → contract form filing → Compact submission → issue testing
PR-02	Product spec → contract form → illustration engine → admin platform config
PR-03	Rider spec → pricing basis → GC-03 external review → contract form → hedging
PR-04	Product spec → admin platform config → illustration validation
PR-05	Index license → pricing → illustration validation → hedging instrument selection
PR-06	Product spec → admin platform config → illustration validation
PR-07	Withdrawn at Gate 1 under GC-01 (D-03). Platform could not support it without custom development (R-04); build allocation returned to reserve. Not deferred — out of scope.
PR-08	Withdrawn at Gate 1 under GC-01 (D-03). Illustration engine could not produce compliant hypothetical performance (I-02). Not deferred — out of scope.
PR-09	Filing plan → IIPRC submission (DEP-01) → approval → state activation
PR-10	Filing plan → SERFF submissions → department review → state activation
PR-11	Scope exclusion, closed under GC-02. Deferral memorandum filed; filing plan, distribution footprint and Stage 4 training scope all derive from it.
PR-12	Illustration spec → Brightpath build → validation vs filed methodology
PR-13	Training spec → enablement build → delivery → completion records at Gate 4
PR-14	Hedging design → GC-05 readiness plan → ISDA execution (DEP-06) → live shadow book
PR-15	Cordelane SOW → configuration (DEP-03) → issue and servicing testing
PR-16	Halverson Re term sheet → treaty → capital treatment confirmation
PR-17	Ops design → process build → end-to-end test with trained staff at Gate 4
PR-18	Channel plan → GC-04 written commitments → appointment and licensing pipeline

5. Verification Coverage by Gate

Verifying gate	Requirements	IDs
G2	5	PR-04, PR-05, PR-06, PR-12, PR-15
G3	6	PR-01, PR-02, PR-03, PR-09, PR-10, PR-16
G4	4	PR-13, PR-14, PR-17, PR-18
— (no verifying gate)	3	PR-07, PR-08, PR-11

Verification load concentrates at Gate 3 — regulatory approval, reserve adequacy and final rates all land together — and at Gate 4, where operational and distribution readiness is demonstrated rather than planned. Gate 2's share is smaller than it looks: three of its requirements were made materially easier by the GC-01 scope reduction, since the two strategies the illustration engine could not support are no longer in the set it must validate.

6. Traceability Gaps

ID	Gap
TG-01	No requirement traces to a benefit. The matrix traces requirements to gates and to test evidence, but nothing links PR-05 (the capped indexed strategy) to BEN-05 (crediting mix), or PR-18 (channel) to BEN-01 (volume). A product can therefore satisfy every requirement and still miss its business case, and this matrix would show full coverage throughout. The Benefits Realization Plan carries the benefit side; the two documents are not joined.
TG-02	Two requirements are verified by parties outside the program. PR-09 and PR-10 close only when regulators approve (DEP-01, DEP-02). The program can evidence submission quality and nothing further; the requirement's closure is not within its gift.
TG-03	PR-13 verification is a completion record, not an effectiveness measure. Advisor training under NAIC #275 is verified at Gate 4 by delivery and completion records. Whether the training changed advisor behavior is a market-conduct question no gate in this program asks.
TG-04	No requirement covers the post-launch window. Every row verifies at or before Gate 4. Gate 5 reviews outcomes, not requirements — so nothing in this matrix has a verification point after 06 Mar 2028.

7. Document Control

Version	Date	Change
1.0	05 Feb 2026	Opened at Gate 0 with the concept requirement set, including the five proposed crediting strategies.
1.1	11 Jun 2026	Gate 1 authorizations recorded. PR-07 and PR-08 moved to withdrawn under GC-01 / D-03; PR-11 recorded as excluded under GC-02 / D-02. No row deleted.
1.2	16 Oct 2026	PR-14 trace marked at risk following the September program review (GC-05 / DEP-06). Traceability gaps TG-01..TG-04 formalized.

Maintained by C. Tyrrell, NPD Program Manager and Chair of the Gate Review Board. Related: Gate Decision Framework · Gate Conditions Register · RAIDD Log · Benefits Realization Plan (see TG-01).