Market Value Adjustment Factor
We compute the market value adjustment for each of your Guarantee Periods by multiplying the applicable amount surrendered, withdrawn, transferred, or applied to an Annuity Option, by the market value adjustment factor. The market value adjustment factor is calculated as the larger of formulas (a) and (b):
(a) [(1+a)/(1+b)]^{(n/12) }

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where:
"a" is the treasury rate for the initial number of years in your Guarantee Period;
"b" is the treasury rate for a period equal to the time remaining (rounded up to the next whole number of 12month periods) to the expiration of your Guarantee Period; and
"n" is the number of complete Guarantee Period Months remaining before the expiration of your Guarantee Period.
(b) [(1.03)/(1+i)]^{(y+d/#)}1
where:
"i" is the guaranteed interest rate for your Guarantee Period;
"y" is the number of complete 12month periods that have elapsed in your Guarantee Period;
"d" is the number of calendar days since the end of the last complete 12month period in your Guarantee Period or, if "y" is zero, the number of calendar days since the start of your Guarantee Period; and
"#" is the number of calendar days in the current 12month period of your Guarantee Period, which is generally 365 days.
As stated above, the formula (b) amount will apply only if it is greater than the formula (a) amount. This will occur only when the formula (a) amount is negative and the formula (b) amount is a smaller negative number. Under these conditions, formula (a)'s full (normal) negative market value adjustment will be limited to the extent that adjustment would decrease your Guarantee Period's Fixed Account Value below the following amount:
(i)
the amount allocated to your Guarantee Period; less
(ii)
any prior systematic or partial withdrawal amounts and amounts transferred; less
(iii)
interest on the above items (i) and (ii) credited annually at a rate of 3% per year.
Treasury Rates
The treasury rate for a Guarantee Period is the interest rate in the Treasury Constant Maturity Series, as published by the Federal Reserve Board, for a maturity equal to the number of years specified in "a" and "b" in formula (a) above. Weekly series are published at the beginning of the following week. The Determination Dates are the last business day before the 1st and 15th of each calendar month.
To determine the "a" treasury rate, we use the weekly series first published on or after the most recent Determination Date that occurs on or before the Start Date for the Guarantee Period. If the Start Date is the same as the Determination Date or the date of publication, or any date in between, we instead use the weekly series first published after the prior Determination Date. To determine the "b" treasury rate, we use the weekly series first published on or after the most recent Determination Date that occurs on or before the date on which the market value adjustment factor is calculated. If the calculation date is the same as the Determination Date or the date of publication, or any date in between, we will instead use the weekly series first published after the prior Determination Date.
If the number of years and or 12month periods specified in "a" or "b" is not equal to a maturity in the Treasury Constant Maturity Series, we determine the treasury rate by straight line interpolation between the interest rates of
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