AG 49-A in plain English: how IUL illustrated rates are limited
Updated 2026-11-10. For licensed agents; not legal or tax advice.
Actuarial Guideline 49 (AG 49) is the NAIC rule that limits how indexed universal life illustrations are built. It took effect for illustrations from 2015 and was revised as AG 49-A for policies sold from December 14, 2020, with a further revision for policies sold from May 1, 2023. Knowing what it limits explains why two carriers' illustrations can't be compared at face value.
What it limits
- The maximum illustrated rate. Each carrier defines a benchmark index account and calculates a maximum rate from a long historical lookback of that index with the carrier's current cap and participation rate. Other index accounts can't be illustrated above what the benchmark supports.
- Bonuses and multipliers. Since AG 49-A, an illustration can't show more benefit from a bonus or multiplier than the carrier's hedge budget supports, so these features no longer raise illustrated values the way they did before 2020.
- Volatility-controlled indexes. The 2023 revision closed a gap that let some newer indexes illustrate higher values than the benchmark.
- Loan arbitrage. The illustrated rate credited to borrowed funds can exceed the illustrated loan charge by at most 0.5 percentage points.
Disclosures you'll see
Illustrations subject to AG 49-A include an alternate scale (values at a lower rate, shown with equal prominence) and tables of historical index performance. Read those pages before you rely on the main ledger.
What it means when you compare carriers
Because each carrier's maximum rate comes from its own index terms, a higher illustrated rate is not a better forecast. When you compare, show each illustrated rate next to the values, compare the guaranteed and alternate-scale columns too, and ask carriers for illustrations at the same lower rate if you want a like-for-like view. This guide is a summary for agents, not legal advice; the guideline text and your carriers' compliance guides control.