Equitable Investment Management Group, Llc

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT AXA EQUITABLE LIFE INSURANCE COMPANY VIOLATED NEW YORK INSURANCE LAW SECTION 4240(E) BY FILING PLANS OF OPERATION WITH RESPECT TO CERTAIN OF ITS SEPARATE ACCOUNTS WITH THE NEW YORK STATE INSURANCE DEPARTMENT AND NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (COLLECTIVELY, THE "DEPARTMENT") WITHOUT ADEQUATELY INFORMING AND EXPLAINING TO THE DEPARTMENT THE SIGNIFICANCE OF THE IMPLEMENTATION OF THE AXA TACTICAL MANAGER STRATEGY. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY CONSENTED TO THE IMPOSITION OF A CIVIL PENALTY ON MARCH 17, 2014 IN THE SUM OF $20,000,000, WHICH WAS PAID ON MARCH 13, 2014 AND AGREED TO SEEK ALL NECESSARY APPROVALS WITH REGARD TO NEW YORK INSURANCE LAW SECTION 4240(E) AND AGREED TO PROVIDE DEPARTMENT-APPROVED COMMUNICATIONS TO POLICYHOLDERS WHEN AXA EQUITABLE LIFE INSURANCE COMPANY IS REVISING FUND CHOICES IN CONNECTION WITH THE AXA TACTICAL MANAGER STRATEGY AND TO COMPLY WITH ANY OTHER CONDITIONS PLACED ON SUCH APPROVALS. AXA EQUITABLE LIFE INSURANCE COMPANY ALSO AGREED TO ISSUE A WRITTEN REPORT TO THE DEPARTMENT CONCERNING CHANGES TO THE PLAN OF OPERATIONS FOR CERTAIN OF ITS SEPARATE ACCOUNTS ON A QUARTERLY BASIS FOR A PERIOD OF FIVE YEARS FROM MARCH 17, 2014. Summary: THE MATTER WAS SETTLED ON MARCH 17, 2014, THE DATE AXA EQUITABLE LIFE INSURANCE COMPANY ENTERED INTO A CONSENT ORDER WITH THE DEPARTMENT CONSENTING TO THE SANCTIONS LISTED ABOVE.

Allegations: THE STATE OF KANSAS INSURANCE DEPARTMENT CONDUCTED A TARGET MARKET CONDUCT EXAMINATION COVERING COMPLAINT HANDLING PRACTICES OF AXA EQUITABLE LIFE INSURANCE COMPANY COVERING THE TIME PERIOD FROM JANUARY 1, 2010 THROUGH DECEMBER 31, 2012. THE STATE ALLEGED THAT DURING THE EXAMINATION, AXA EQUITABLE LIFE INSURANCE COMPANY FAILED TO RESPOND TIMELY TO PROPER INQUIRY BY THE DEPARTMENT. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY WAS FINED $1000.00 AND PAID THE FINE ON JULY 29, 2014. Summary: THE MATTER WAS SETTLED ON JULY 7, 2014 VIA FINAL ORDER FROM THE STATE OF KANSAS INSURANCE DEPARTMENT.

Allegations: THE MARYLAND INSURANCE COMMISSIONER CONDUCTED A MARKET CONDUCT EXAMINATION OF AXA EQUITABLE LIFE INSURANCE COMPANY COVERING THE TIME PERIOD FROM DECEMBER 1, 2011, THROUGH NOVEMBER 30, 2012. THE STATE ALLEGED THAT DURING THE EXAMINATION, AXA EQUITABLE LIFE INSURANCE COMPANY FAILED TO MAINTAIN SUFFICIENT PROCEDURES RELATED TO REPLACEMENTS AND POLICY ADMINISTRATION. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY WAS FINED $4,600.00, WHICH WAS PAID ON OCTOBER 8, 2014 AND AGREED TO PROVIDE THE INSURANCE COMMISSIONER WITH A SUMMARY OF THE ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN THE MARKET CONDUCT REPORT. Summary: THE MATTER WAS SETTLED ON OCTOBER 17, 2014 VIA CONSENT ORDER FROM THE STATE OF MARYLAND INSURANCE COMMISSIONER.

Allegations: THE COMMONWEALTH OF PENNSYLVANIA INSURANCE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION OF AXA EQUITABLE LIFE INSURANCE COMPANY COVERING THE TIME PERIOD FROM JANUARY 1, 2010 THROUGH DECEMBER 31, 2011. THE COMMONWEALTH ALLEGED THAT AXA EQUITABLE LIFE INSURANCE COMPANY FAILED TO MAINTAIN SUFFICIENT PROCEDURES RELATED TO PRODUCER APPOINTMENTS, DISCLOSURES ON CERTAIN FORMS, CLAIMS AND RECORDKEEPING. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY WAS FINED $60,000.00 AND PAID THE FINE ON JUNE 16, 2014. Summary: THE MATTER WAS SETTLED ON JULY 7, 2014 VIA CONSENT ORDER FROM THE COMMONWEALTH OF PENNSYLVANIA INSURANCE DEPARTMENT.

Allegations: THE STATE OF ILLINOIS INSURANCE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION OF AXA EQUITABLE LIFE INSURANCE COMPANY COVERING THE TIME PERIOD FROM JULY 1, 2011 THROUGH JUNE 30, 2012. THE STATE ALLEGED THAT DURING THE EXAMINATION, AXA EQUITABLE LIFE INSURANCE COMPANY FAILED TO MAINTAIN SUFFICIENT PROCEDURES RELATED TO NOTICES TO POLICYHOLDERS. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY WAS FINED $7,000.00, WHICH WAS PAID ON JUNE 12, 2014 AND AGREED TO PROVIDE THE INSURANCE COMMISSIONER WITH A SUMMARY OF THE ACTIONS TAKEN TO COMPLY WITH THE RECOMMENDATIONS IN THE MARKET CONDUCT REPORT. Summary: THE MATTER WAS SETTLED ON MAY 22, 2014 VIA CONSENT ORDER FROM THE STATE OF ILLINOIS INSURANCE DEPARTMENT.

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES CONDUCTED A STANDARD QUINQUENNIAL EXAMINATION OF THE MARKET CONDUCT ACTIVITIES OF AXA EQUITABLE LIFE INSURANCE COMPANY FOR THE PERIOD JANUARY 1, 2006 THROUGH DECEMBER 31, 2010. THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT AXA EQUITABLE LIFE INSURANCE COMPANY VIOLATED CERTAIN PROVISIONS OF THE INSURANCE LAW AND/OR DEPARTMENT REGULATIONS DURING THE PERIOD JANUARY 1, 2006 THROUGH DECEMBER 31, 2010 IN CONNECTION WITH CERTAIN CASES INVOLVING THE REPLACEMENT OF LIFE INSURANCE POLICIES OR ANNUITY CONTRACTS, AND CERTAIN OTHER NEW YORK INSURANCE LAWS AND REGULATIONS. Status: Final Sanction Detail: AXA EQUITABLE LIFE INSURANCE COMPANY PAID $300,000 FINE ON OCTOBER 11, 2016 AND AGREED TO TAKE ALL STEPS NECESSARY TO COMPLY WITH THE NEW YORK INSURANCE LAW AND REGULATIONS WITH RESPECT TO ITS INSURANCE PRODUCTS. Summary: AXA EQUITABLE LIFE INSURANCE COMPANY CONSENTED TO THE IMPOSITION OF A CIVIL PENALTY IN THE SUM OF $300,000.00, STATED IN MITIGATION THAT THE VIOLATIONS WERE NOT THE RESULT OF ANY CONSCIOUS COMPANY POLICY TO EVADE THE REQUIREMENTS OF THE INSURANCE LAW AND DEPARTMENT REGULATIONS, AND AGREED TO TAKE ALL STEPS NECESSARY TO COMPLY WITH NEW YORK INSURANCE LAW AND DEPARTMENT REGULATIONS WITH RESPECT TO ITS INSURANCE PRODUCTS IN THE FUTURE. THE CIVIL PENALTY IN THE AMOUNT OF $300,000.00 WAS PAID ON OCTOBER 11, 2016.

Allegations: THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION, DIVISION OF INSURANCE ("SDDOI") INVESTIGATED AXA EQUITABLE LIFE INSURANCE COMPANY AND U.S. FINANCIAL LIFE INSURANCE COMPANY (TOGETHER, THE "COMPANIES") AND ALLEGED THAT THE COMPANIES VIOLATED CERTAIN PROVISIONS OF THE INSURANCE LAW AND/OR DEPARTMENT REGULATIONS IN CONNECTION WITH MAKING CERTAIN PAYMENTS, RESPONSES TO INQUIRIES, AND PROVIDING INFORMATION REGARDING FOR CAUSE TERMINATIONS. Status: Final Sanction Detail: A CIVIL PENALTY IN THE AMOUNT OF $500 WAS ASSESSED, A CHECK IN THE AMOUNT OF $500 WAS SENT ON AUGUST 23, 2017 AND RECEIVED BY THE SOUTH DAKOTA DEPARTMENT OF LABOR AND REGULATION, DIVISION OF INSURANCE ON AUGUST 24, 2017. Summary: THE COMPANIES CONSENT TO THE IMPOSITION OF A CIVIL PENALTY IN THE SUM OF $500.

Allegations: THE DELAWARE DEPARTMENT OF INSURANCE CONDUCTED A MARKET CONDUCT EXAMINATION OF AXA EQUITABLE LIFE INSURANCE COMPANY AND ALLEGED THAT THE COMPANY VIOLATED CERTAIN PROVISIONS OF THE INSURANCE LAW AND/OR DEPARTMENT REGULATIONS IN CONNECTION WITH ANNUITY REPLACEMENTS. Status: Final Sanction Detail: A CIVIL PENALTY IN THE AMOUNT OF $5000 WAS ASSESSED, A CHECK IN THE AMOUNT OF $5000 WAS SENT ON SEPTEMBER 26, 2018 AND RECEIVED BY THE DELAWARE DEPARTMENT OF INSURANCE ON SEPTEMBER 27, 2018. Summary: THE COMPANY CONSENTED TO THE IMPOSITION OF A CIVIL PENALTY IN THE SUM OF $5000.

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NYDFS") CONDUCTED A STANDARD QUINQUENNIAL EXAMINATION OF AXA EQUITABLE LIFE INSURANCE COMPANY FOR THE PERIOD JANUARY 1, 2011 THROUGH DECEMBER 31, 2015. THE NYDFS ALLEGED THAT AXA EQUITABLE LIFE INSURANCE COMPANY VIOLATED CERTAIN PROVISIONS OF THE INSURANCE LAW AND/OR DEPARTMENT REGULATIONS DURING THE PERIOD JANUARY 1, 2011 THROUGH DECEMBER 31, 2015 IN CONNECTION WITH CERTAIN CASES INVOLVING THE REPLACEMENT OF LIFE INSURANCE POLICIES OR ANNUITY CONTRACTS, AND CERTAIN OTHER NEW YORK INSURANCE LAWS AND REGULATIONS. Status: Final Sanction Detail: AXA EQUITABLE PAID A FINE OF $3,788,289 ON MAY 10, 2017 AND AGREED TO IMPLEMENT REMEDIATION PLANS TO PROVIDE RESTITUTION TO AFFECTED POLICYHOLDERS OR THEIR BENEFICIARIES. Summary: AXA EQUITABLE LIFE INSURANCE COMPANY CONSENTED TO THE IMPOSITION OF A CIVIL PENALTY IN THE SUM OF $3,788,289.00, STATED IN MITIGATION THAT THE VIOLATIONS WERE NOT THE RESULT OF ANY CONSCIOUS COMPANY POLICY TO EVADE THE REQUIREMENTS OF THE INSURANCE LAW AND DEPARTMENT REGULATIONS, AND AGREED TO IMPLEMENT REMEDIATION PLANS TO PROVIDE RESTITUTION TO AFFECTED POLICYHOLDERS OR THEIR BENEFICIARIES.

Allegations: THE SEC ALLEGED THAT SINCE AT LEAST 2016, EQUITABLE FINANCIAL LIFE INSURANCE COMPANY ("EQUITABLE") PROVIDED QUARTERLY ACCOUNT STATEMENTS THAT INCLUDED MISLEADING STATEMENTS AND OMISSIONS CONCERNING FEES PAID IN CONNECTION WITH ITS EQUI-VEST VARIABLE ANNUITY PRODUCT, WHICH WAS SOLD PREDOMINANTLY IN THE 403(B) AND 457(B) DEFINED CONTRIBUTION PLAN SPACE. WHILE THOSE FEES WERE DESCRIBED IN DETAIL IN THE PROSPECTUS, THE ACCOUNT STATEMENTS CONTAINED NO CLARIFYING LANGUAGE OR REFERENCE TO THE PROSPECTUS. THE SEC ALLEGED THAT THE ACCOUNT STATEMENTS LISTED ONLY CERTAIN TYPES OF ADMINISTRATIVE, TRANSACTION, AND PLAN OPERATING FEES BUT OMITTED SIGNIFICANT DAILY FEES CAPTURED IN NET PERFORMANCE FIGURES BUT ONLY DESCRIBED IN THE PROSPECTUS. AS A RESULT, THE SEC ALLEGED THAT EQUITABLE VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. Status: Final Sanction Detail: EQUITABLE FINANCIAL LIFE INSURANCE COMPANY WAS ORDERED TO PAY A MONETARY FINE OF $50,000,000.00. Summary: WHILE NEITHER ADMITTING OR DENYING THE ALLEGATIONS, EQUITABLE FINANCIAL LIFE INSURANCE COMPANY AGREED TO ENHANCE EQUI-VEST QUARTERLY ACCOUNT STATEMENTS TO EXPLICITLY REFER TO THE COMPLETE DISCLOSURES IN THE PROSPECTUS AND TO SUPPLEMENT ACCOUNT STATEMENTS' DESCRIPTION OF RELATED TERMS. IN ADDITION, EQUITABLE AGREED TO PAY A CIVIL MONETARY PENALTY OF $50 MILLION, TO BE DISTRIBUTED TO CURRENT AND FORMER CLIENTS WHO INVESTED IN EQUI-VEST CONTRACTS SINCE AT LEAST 2016.