Caution: SEC seems likely to sweep Index UL into the securities/separate account side by proposed EIA rules.
Index UL also seems to violate a part of the Standard Nonforfeiture Law called the "Smoothness Test." Most states focus on the part of that law that sets minimum cash values, so they don't check "smoothness." However, ROP
Term was a recent focus of an interpretation of the Smoothness Test, resulting in stronger NAIC guidelines.