Investment Manager Report

• SEC adopts new registration form for insurance company separate accounts registered as unit investment trusts that offer variable life insurance policies:
The SEC has adopted a new registration form for insurance company separate accounts that are registered as unit investment trusts ("UITs") and that offer variable life insurance policies. The new Form N-6 is to be used by these separate accounts to both register under the Investment Company Act of 1940 (the "1940 Act") and to offer their securities under the Securities Act of 1933 (the "1933 Act").

Variable life separate accounts, as UITs, are currently required to register on Form N-8B-2 under the 1940 Act and to register their securities on Form S-6 under the 1933 Act. The SEC commented that these forms were designed for non-separate account UITs and were adopted before the establishment of the first separate accounts used to fund variable