We use three procedures each month to manage variable annuities:
RISK ANALYSIS
We classify each industry or potential investment (mutual fund, sub-account, or exchange traded fund) available in the account by the volatility relative to the S&P 500 into five sectors:
| Risk Sector A: | Volatility 2x the S&P 500 |
| Risk Sector B: | Volatility 1.5x the S&P 500 |
| Risk Sector C: | V olatility 1.0x the S&P 500 |
| Risk Sector S: | Special funds that have volatility less than the S&P 500 or investments that can short or are inverse of the market |
| Risk Sector F: | Fixed income bond funds |
Once funds are classified by risk characteristics, we can then match the investment with the investment objective of the client.

RISK/REWARD MATRIX
We use our proprietary Risk/Reward Matrix to graphically indicate the probability of investment returns in the current market environment. This is comprised of current market valuation, economic growth, and investor sentiment. The model is composed of 16 economic factors used to evaluate the amount of risk and opportunity in the market, or for a specific investment.

RELATIVE STRENGTH
The last component of our system is relative strength, which we use to make our investment selection. Relative strength is our way of avoiding value traps - investments that look compelling on valuation, but lack investment appeal and are more likely to decline in value. We compare the investment's strength over the last 6-12 months relative to all the other investment options available to us. We will sell an investment if its performance has been poor relative to the other investment options, or the current market environment makes the investment too volatile for the portfolio.


