Common use of Rule 38a-1 Compliance Clause in Contracts

Rule 38a-1 Compliance. (1) Distributor shall provide to NW its adopted written compliance policies and procedures as required by Rule 38a-1 under the 1940 Act for review and approval by NW, as depositor for the Variable Accounts. Such written compliance policies and procedures: (i) shall be reasonably designed to prevent violations of the federal securities laws, as such laws are defined in Rule 38a-1 under the 1940 Act and relate to Distributor's duties under this Agreement as principal underwriter for the Contracts and the Variable Accounts; and (ii) shall include Distributor's policies and procedures with regard to compliance with the SEC's pricing rules for Variable Accounts, including but not limited to Rule 22c-1 under the 1940 Act, and with regard to NW's Disruptive Trading policy as that policy is disclosed in the Prospectuses for the Contracts (the "Rule 38a-1 policies and procedures").

Rule 38a-1 Compliance. (1) Distributor shall provide to NW FNWL its adopted written compliance policies and procedures as required by Rule 38a-1 under the 1940 Act for review and approval by NWFNWL, as depositor for the Variable Accounts. Such written compliance policies and procedures: (i) shall be reasonably designed to prevent violations of the federal securities laws, as such laws are defined in Rule 38a-1 under the 1940 Act and relate to Distributor's ’s duties under this Agreement as principal underwriter for the Contracts and the Variable Accounts; and (ii) shall include Distributor's ’s policies and procedures with regard to compliance with the SEC's ’s pricing rules for Variable Accounts, including but not limited to Rule 22c-1 under the 1940 Act, and with regard to NW's FNWL’s Disruptive Trading policy as that policy is disclosed in the Prospectuses for the Contracts (the "“Rule 38a-1 policies and procedures"”).

Rule 38a-1 Compliance. (1) Distributor shall provide to NW JNLIC-NY its adopted written compliance policies and procedures as required by Rule 38a-1 under the 1940 Act for review and approval by NWJNLIC-NY, as depositor for the Variable Accounts. Such written compliance policies and procedures: (i) shall be reasonably designed to prevent violations of the federal securities laws, as such laws are defined in Rule 38a-1 under the 1940 Act and relate to Distributor's ’s duties under this Agreement as principal underwriter for the Contracts and the Variable Accounts; and (ii) shall include Distributor's ’s policies and procedures with regard to compliance with the SEC's ’s pricing rules for Variable Accounts, including but not limited to Rule 22c-1 under the 1940 Act, and with regard to NW's JNLIC-NY’s Disruptive Trading policy as that policy is disclosed in the Prospectuses for the Contracts (the "“Rule 38a-1 policies and procedures"”).