[Federal Register Volume 68, Number 223 (Wednesday, November 19, 2003)]
[Notices]
[Pages 65323-65328]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 03-28849]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. IC-26253; File No. 812-12962]


Principal Life Insurance Company, et al., Notice of Application

November 13, 2003.
AGENCY: Securities and Exchange Commission (``SEC'' or ``Commission'').

ACTION: Notice of application for an order pursuant to section 26(c) of 
the Investment Company Act of 1940 (the ``Act'') approving the 
substitution of securities.

-----------------------------------------------------------------------

Applicants:  Principal Life Insurance Company (``Principal Life''), 
Principal Life Insurance Company Variable Life VL Separate Account 
(``VL Separate Account''), and Principal Life Insurance Company 
Separate Account B (``Separate Account B'').

Summary of Application:  Applicants seek an order to permit, under the 
specific circumstances identified in the application, the substitution 
of shares of the LargeCap Growth Equity Account of Principal Variable 
Contracts Fund, Inc. (``Principal Fund'') for shares of the LargeCap 
Growth Account of Principal Fund; shares of the LargeCap Stock Index 
Account of Principal Fund for shares of the Blue Chip Account of 
Principal Fund; shares of the MidCap Growth Account of Principal Fund 
for shares of the MidCap Growth Equity Account of Principal Fund; 
shares of the Asset Allocation Account of Principal Fund for shares of 
the Putnam VT Global Asset Allocation Fund of Putnam Variable Trust 
(``Putnam Trust''); and shares of the Equity Growth Account of 
Principal Fund for shares of the Putnam VT Vista Fund of Putnam Trust. 
The shares are currently held by VL Separate Account and Separate 
Account B.

Filing Date:  The application was filed on April 18, 2003, and amended 
on November 10, 2003.

Hearing or Notification of Hearing:  An order granting the application 
will be issued unless the SEC orders a hearing. Interested persons may 
request a hearing by writing to the SEC's Secretary and serving 
Applicants with a copy of the request, personally or by mail. Hearing 
requests should be received by the SEC by 5:30 on December 4, 2003 and 
should be accompanied by proof of service on Applicants, in the form of 
an affidavit or, for lawyers, a certificate of service. Hearing 
requests should state the nature of the writer's interest, the reason 
for the request, and the issues contested. Persons who wish to be 
notified of a hearing may request notification by writing to the SEC's 
Secretary.

ADDRESSES: Secretary, SEC, 450 5th Street, NW., Washington, DC 20549. 
Applicants, c/o John W. Blouch, Esq., Jones & Blouch LLP, 1025 Thomas 
Jefferson Street, NW., Washington, DC 20007-5254; copy to Michael D. 
Roughton, Esq., Principal Financial Group, Inc., 711 High Street, Des 
Moines, Iowa 50392-0200.

FOR FURTHER INFORMATION CONTACT: Rebecca A. Marquigny, Senior Counsel, 
or Zandra Y. Bailes, Branch Chief, Office of Insurance Products, 
Division of Investment Management, at (202) 942-0670.

SUPPLEMENTARY INFORMATION: Following is a summary of the application; 
the complete application is available for a fee from the SEC's Public 
Reference Branch, 450 Fifth Street, NW., Washington, DC 20549-0102 
(telephone (202) 942-8090).

Applicants' Representations

    1. Principal Life is a stock life insurance company organized under 
the laws of Iowa in 1879. It is authorized to transact life insurance 
and annuity business in all of the United States and the District of 
Columbia.
    2. VL Separate Account was established in 1987 by Principal Life as 
a separate account under Iowa law for the purpose of funding variable 
life contracts issued by Principal Life (File No. 811-05118). Separate 
Account B was established in 1970 by Principal Life as a separate 
account under Iowa law for the purpose of funding variable annuity 
contracts issued by Principal Life (File No. 811-02091).
    3. There are nine variable insurance contracts affected by the 
application (the ``Contracts''). Six of the Contracts are flexible 
premium variable life insurance policies (collectively, the ``VL 
Contracts''); three are variable annuity contracts, two individual 
deferred contracts and one group annuity contract (collectively, the 
``VA Contracts''). Purchase payments for the VL Contracts are allocated 
to VL Separate Account. Purchase payments for the VA Contracts are 
allocated to Separate Account B.
    4. Purchase payments for the Contracts are allocated to one or more 
subaccounts (``Divisions'') of VL Separate Account or Separate Account 
B. Each Division invests in shares of an underlying mutual fund 
(``Underlying Fund''), including Principal Fund, an open-end management 
investment company registered under the Act (File Nos. 811-1944 and 
002-35570), and Putnam Trust, an open-end management investment company 
registered under the Act (File Nos. 811-05346 and 033-17486). The 
Contracts permit transfers of accumulated value from one Division to 
another.
    5. The following table (i) identifies each Contract affected by the 
application, (ii) sets forth the total number of Divisions available 
under each Contract and the number of those Divisions that invest in 
either the Principal Fund or the Putnam Trust, and (iii) summarizes the 
transfer rights under each Contract.

----------------------------------------------------------------------------------------------------------------
                                                                          Divisions              Transfers
                                                                   ---------------------------------------------
                  Contracts/File Nos.                      Total    Principal    Putnam     Minimum
                                                                       fund      trust       amount       Fee
----------------------------------------------------------------------------------------------------------------
VL Contracts:
    Flex Variable Life (File No. 33-13481).............         49         27          3     $250        \1\ $25
    Prinflex Life (File No. 333-00101).................         49         27          3      100           None
    Survivorship Variable Life (File No. 333-71521)....         49         27          3      100           None
    Principal Variable Universal Life Accumulator (File         49         27          3      100           None
     No. 333-65690)....................................
    Principal Executive Variable Universal Minimum Life         73         21          0    (\3\)           None
     (File No. 333-81714)..............................
    Principal Benefit Variable Universal Minimum Life           73         21          0    (\3\)           None
     (File No. 333-89446)..............................

[[Page 65324]]

 
VA Contracts:
    Flexible Variable Annuity (File No. 33-74232)......         42         27          0      100         \2\ 30
    Freedom Variable Annuity (File No. 333-63401)......         17         15          0       50           None
    Premier Variable Annuity (File No. 33-44670).......         25         25          0    (\3\)           None
----------------------------------------------------------------------------------------------------------------
\1\ Imposed on each transfer exceeding four per policy year.
\2\ Imposed on each transfer exceeding twelve per policy year.
\3\ No minimum.

    6. The only Divisions affected by the application are those 
identified in the following table. Each of those Divisions invests 
solely in the Principal Fund Account or the Putnam Trust Fund as 
indicated in this table.

------------------------------------------------------------------------
Division of each of VL separate account
         and separate account B                   Principal fund
------------------------------------------------------------------------
LargeCap Growth........................  LargeCap Growth Account
LargeCap Growth Equity.................  LargeCap Growth Equity Account
Blue Chip \4\..........................  Blue Chip Account
LargeCap Stock Index...................  LargeCap Stock Index Account
MidCap Growth Equity...................  MidCap Growth Equity Account
MidCap Growth..........................  MidCap Growth Account
Asset Allocation.......................  Asset Allocation Account
Equity Growth..........................  Equity Growth Account
                                        --------------------------------
                                          Putnam Trust
                                        --------------------------------
Putnam VT Global Asset Allocation......  Putnam VT Global Asset
                                          Allocation Fund
Putnam VT Vista........................  Putnam VT Vista Fund
------------------------------------------------------------------------
\4\ Separate Account B has a Blue Chip Division; VL Separate Account
  does not have a Blue Chip Division.

    The Principal Fund Accounts and the Putnam Trust Funds indicated in 
the table above are referred to herein collectively as the ``Principal 
Funds'' and the ``Putnam Funds,'' respectively. Principal Funds and 
Putnam Funds are referred to herein collectively as the ``Funds.''
    7. Principal Funds are managed by Principal Management Corporation 
(``PMC''), a registered investment adviser under the Investment 
Advisers Act of 1940, as amended (``Advisers Act'') and an indirect, 
wholly-owned subsidiary of Principal Financial Group, Inc. The 
following table identifies the sub-adviser for each of the Principal 
Funds and indicates its affiliation, if any, with Principal Financial 
Group, Inc.

----------------------------------------------------------------------------------------------------------------
                    Fund                                                  Sub-adviser
----------------------------------------------------------------------------------------------------------------
LargeCap Growth Account.....................  Janus Capital Management LLC (``Janus''), a registered investment
                                               adviser under the Advisers Act (File No. 801-13991).
LargeCap Growth Equity Account..............  Putnam Investment Management LLC (``Putnam''), a registered
                                               investment adviser under the Advisers Act (File No. 801-7974).
Blue Chip Account...........................  Principal Global Investors, LLC (``PGI''), an indirect, wholly-
                                               owned subsidiary of Principal Life and a registered investment
                                               adviser under the Advisers Act (File No. 801-55959)
LargeCap Stock Index Account................  PGI.
MidCap Growth Equity Account................  Turner Investment Partners, Inc. (``Turner''), a registered
                                               investment adviser under the Advisers Act (File No. 801-36220).
MidCap Growth Account.......................  The Dreyfus Service Corporation (``Dreyfus''), a registered
                                               investment adviser under the Advisers Act (File No. 801-54739).
Asset Allocation Account....................  Morgan Stanley Investment Management, Inc. (``Morgan Stanley''), a
                                               registered investment adviser under the Advisers Act (File No.
                                               801-15757).
Equity Growth Account.......................  Morgan Stanley.
----------------------------------------------------------------------------------------------------------------

    8. Putnam Funds are managed by Putnam.
    9. Applicants seek an order permitting each the following 
substitutions (``Substitutions''):

------------------------------------------------------------------------
                               Replaced fund/sub-   Substituted fund/sub-
        Substitution                 adviser               adviser
------------------------------------------------------------------------
One.........................  LargeCap Growth       LargeCap Growth
                               Account (Janus).      Equity Account
                                                     (Putnam).
Two.........................  Blue Chip Account     LargeCap Stock Index
                               (PGI).                Account (PGI).
Three.......................  MidCap Growth Equity  MidCap Growth
                               Account (Turner).     Account (Dreyfus).
Four........................  Putnam VT Global      Asset Allocation
                               Asset Allocation      (Morgan Stanley).
                               Fund Account
                               (Putnam).

[[Page 65325]]

 
Five........................  Putnam VT Vista Fund  Equity Growth
                               (Putnam).             Account (Morgan
                                                     Stanley)
------------------------------------------------------------------------

    10. The investment objective of LargeCap Growth Account (``LargeCap 
Growth'') is to seek long-term growth of capital. It invests primarily 
in equity securities of growth companies. Under normal market 
conditions, LargeCap Growth invests at least 80% of its assets in 
equity securities of companies with large market capitalizations (those 
with market capitalizations similar to companies in the Russell 1000 
Growth Index) at the time of purchase. (The market capitalization of 
companies included in the Russell 1000 Growth Index as of June 30, 
2003, ranged approximately from $1.3 billion to $310 billion.) The 
Account may invest up to 25% of its assets in securities of foreign 
companies. The investment objective of LargeCap Growth Equity Account 
(``LCGE'') is to seek long-term growth of capital. It invests primarily 
in common stocks of U.S. companies, with a focus on growth stocks. 
Under normal market conditions, LCGE invests at least 80% of its assets 
in common stocks of companies with large market capitalizations (those 
with market capitalizations similar to companies in the Russell 1000 
Growth Index) at the time of purchase. LCGE may invest up to 25% of its 
assets in securities of foreign issuers. Applicants believe that the 
substitution will serve the interests of the owners of the contracts 
because it will permit them to continue to pursue their current 
investment objective (long-term growth of capital) through investments 
in the same kinds of securities while paying a lower advisory fee and 
lower overall expense ratio.
    11. The investment objective of Blue Chip Account (``BC Account'') 
is to seek long-term growth of capital. BC Account invests primarily by 
investing in common stocks of well-established large capitalization 
companies. Under normal market conditions, BC Account invests at least 
80% of its assets in common stocks of companies with large market 
capitalizations (similar to companies in the S&P 500 Index) at the time 
of purchase. Blue chip companies have market capitalizations of at 
least $1 billion. BC Account may invest up to 20% of its Account assets 
in foreign securities. The investment objective of LargeCap Stock Index 
Account (``LCSI'') is to seek long-term growth of capital. Under normal 
market conditions, LCSI invests at least 80% of its assets in common 
stocks of companies that compose the S&P 500 Index, an unmanaged index 
of 500 common stocks chosen to reflect the industries of the U.S. 
economy. Applicants believe that the substitution will serve the 
interest of owners of the contracts because it will provide those 
owners with an investment option that is comparable in terms of 
pursuing long-term investment goals and has a lower expense ratio.
    12. The investment objective of MidCap Growth Equity Account 
(``MCGE'') is to seek long-term growth of capital by investing 
primarily in medium capitalization U.S. companies with strong earnings 
growth potential. Under normal market conditions, MCGE invests at least 
80% of its assets in common stocks of companies with medium market 
capitalizations (those with market capitalizations similar to companies 
in the Russell MidCap Growth Index) at the time of purchase. (The 
market capitalization of companies included in the Russell MidCap 
Growth Index as of June 30, 2003 ranged approximately from $1.3 billion 
to $10.8 billion.) MCGE may invest up to 10% of its assets in 
securities of foreign issuers. The investment objective of MidCap 
Growth Account (``MidCap Growth'') is to seek long-term growth of 
capital. Under normal market conditions, MidCap Growth invests at least 
80% of its assets in common stocks of companies with medium market 
capitalizations (those with market capitalizations similar to companies 
in the Russell MidCap Growth Index) at the time of purchase. MidCap 
Growth may invest up to 10% of its assets in securities of foreign 
issuers. Applicants believe that the substitution will serve the 
interests of owners of the contracts because it will provide those 
owners with an investment option that is comparable in terms of 
pursuing long-term investment goals and has a lower expense ratio.
    13. The investment objective of Putnam VT Global Asset Allocation 
Fund (``Putnam GAAF'') is to seek a high level of long-term total 
return consistent with preservation of capital. Putnam GAAF invests in 
a wide variety of equity and fixed-income securities of both U.S. and 
foreign issuers of any size. Putnam GAAF invests in growth and value 
stocks of domestic and foreign corporations and in domestic and foreign 
fixed income securities. The investment objective of Asset Allocation 
Account (``AAA'') is to generate a total investment return consistent 
with preservation of capital. AAA invests in a wide variety of equity 
and fixed-income securities of both U.S. and foreign issuers of any 
size. AAA invests in growth and value stocks of domestic and foreign 
corporations and in domestic fixed-income securities and may invest in 
foreign fixed-income securities. Applicants believe that the 
substitution will serve the interest of owners of the contracts because 
it will provide those owners with an investment option that is 
comparable in terms of pursuing long-term investment goals and has a 
lower expense ratio.
    14. The investment objective of Putnam VT Vista Fund (``Vista'') is 
to seek capital appreciation. Vista invests mainly in common stocks of 
U.S. companies, with a focus on growth stocks. Vista invests mainly in 
mid-sized companies. The Fund uses the Russell MidCap Growth Index for 
comparison purposes. The investment objective of Equity Growth Account 
(``Equity Growth'') is to provide long-term capital appreciation by 
investing primarily in equity securities. Equity Growth seeks to 
maximize long-term capital appreciation by investing primarily in 
growth-oriented equity securities of U.S. and, to a limited extent, 
foreign companies that are listed on U.S. exchanges or traded in U.S. 
markets. It invests at least 80% of its assets in equity securities and 
invests primarily in companies with market capitalizations of $10 
billion or more. Although Equity Growth may invest up to 25% of its 
assets in investments in foreign companies that are traded in foreign 
markets, it is considered to be a domestic stock fund and, therefore, 
will generally limit its foreign stock holdings to 10% of its assets 
and generally invests only in securities of foreign companies that are 
traded in the U.S. Applicants represent that the substitution will 
serve the interest of owners of the contracts because it will provide 
those owners with an investment option that is comparable in terms of 
pursuing long-term investment goals and has a lower expense ratio.
    15. The annual operating expenses of each replaced fund and each 
substituting fund as a percentage of average daily net assets are as 
follows:

[[Page 65326]]



                                                  [In percent]
----------------------------------------------------------------------------------------------------------------
                                                                                                       Total
                                                                                        Total         expenses
                                                                                       expenses      (after fee
                                              Management  Distribution     Other       (before      waivers and/
                                                  fee      and service   expenses   reimbursement        or
                                                           fee (12b-1)                and/or fee   reimbursement
                                                                                      waivers if         if
                                                                                     applicable)    applicable)
----------------------------------------------------------------------------------------------------------------
Replaced Fund: LargeCap Growth..............        1.10          N/A         0.04          1.14           1.14
Substituting Fund: LCGE.....................        1.00          N/A         0.09          1.09           1.09
Replaced Fund: BC Account...................        0.60          N/A         0.23          0.83           0.83
Substituting Fund: LCSI.....................        0.35          N/A         0.04          0.39           0.39
Replaced Fund: MCGE.........................        1.00          N/A         0.13          1.13           1.10
Substituting Fund: MidCap Growth............        0.90          N/A         0.02          0.92           0.92
Replaced Fund: Putnam GAAF..................        0.67         0.25         0.17          1.09           1.09
Substituting Fund: AAA......................        0.80          N/A         0.04          0.84           0.84
Replaced Fund: Vista........................        0.61         0.25         0.06          0.92           0.92
Substituting Fund: Equity Growth............        0.75          N/A         0.02          0.77          0.77
----------------------------------------------------------------------------------------------------------------
 Note: The expenses shown above are for the year ended December 31, 2002.

    16. Applicants represent that the Substitutions will take place at 
the relative net asset values determined on the date of the 
Substitution in accordance with section 22 of the Act and Rule 22c-1 
thereunder. Applicants represent that there will be no financial impact 
to any contractowner.
    17. Each of the Substitutions will be effected by having each 
Division that invests in a Replaced Fund redeem its shares of that fund 
for cash at the net asset value calculated on the date of the 
Substitution and purchase shares of the Substituted Fund for cash at 
net asset value on the same date. In connection with the completion of 
each of the Substitutions, Principal Life will withdraw its seed money 
from each of the Principal Funds in which it has seed money (LargeCap 
Growth, BC Account, and MCGE) and terminate those funds. In addition, 
Principal Life will combine each Division of each of the Separate 
Accounts that invests in a Replaced Fund with the Division of that 
Separate Account that invests in the Substituted Fund.
    18. Applicants agree that: (a) For each fiscal period (not to 
exceed a fiscal quarter) during the 24 months following the date of 
Substitution into LCSI, AAA and Equity Growth, Principal Life will 
adjust the Contract values invested in the Substituted Fund as a result 
of the Substitution, to the extent necessary to effectively reimburse 
the affected owners for their proportionate share of any amount by 
which the annual rate of the Substituted Fund's total operating 
expenses (after any expense waivers or reimbursements) for that fiscal 
period, as a percentage of the Fund's average daily net assets, plus 
the annual rate of any asset-based charges (excluding any such charges 
that are for premium taxes) deducted under the terms of the owner's 
Contract for that fiscal period, exceed the sum of: the annualized rate 
of the corresponding Replaced Fund's total operating expenses, as a 
percentage of such replaced Fund's average daily net assets, for the 
twelve months ended December 31, 2002; plus the annual rate of any 
asset-based charges (excluding any such charges that are for premium 
taxes) deducted under that Contract for such twelve months; and (b) for 
each fiscal period (not to exceed a fiscal quarter) during the 24 
months following the date of Substitution into LCGE and MidCap Growth, 
Principal Life will, with respect to all Contracts outstanding on the 
date of the Substitution, adjust the Contract values invested in the 
Substituted Fund, to the extent necessary to effectively reimburse the 
owners of those Contracts for their proportionate share of any amount 
by which the annual rate of the Substituted Fund's total operating 
expenses (after any expense waivers or reimbursements) for that fiscal 
period, as a percentage of the Fund's average daily net assets, plus 
the annual rate of any asset-based charges (excluding any such charges 
that are for premium taxes) deducted under the terms of the owner's 
Contract for that fiscal period, exceed the sum of: the annualized rate 
of the corresponding Replaced Fund's total operating expenses, as a 
percentage of such replaced Fund's average daily net assets, for the 
twelve months ended December 31, 2002; plus the annual rate of any 
asset-based charges (excluding any such charges that are for premium 
taxes) deducted under that Contract for such twelve months.
    19. Applicants represent that each of the Substitutions has been 
described in the annual post-effective amendments to the registration 
statements for the Contracts which became effective on May 1, 2003. The 
post-effective amendments mailed to contractowners gave them notice of 
each of the Substitutions and described the reasons for engaging in 
each of the Substitutions. The post-effective amendments also informed 
existing contractowners that no amounts may be transferred to the 
Replaced Funds on or after May 19, 2003. In addition, the post-
effective amendments informed affected contractowners that they will 
have an opportunity to reallocate accumulation value prior to each 
Substitution or for 60 days after each Substitution (``Free Transfer 
Right'') from each Division investing in a Replaced Fund to another 
Division available under the Contracts, without the imposition of any 
transfer charge or limitation and without counting the transfer as one 
of the annual free transfers.
    20. Each contractowner has been provided a prospectus for each of 
the Substituted Funds. Applicants represent that, within five days 
after a Substitution, Principal Life will send to affected 
contractowners written confirmation that the Substitution has occurred.
    21. Applicants represent that the cost of each of the 
Substitutions, including legal, accounting, brokerage commissions and 
other fees and expenses, will be borne by Principal Life and will not 
be borne by the Funds or the contractowners either directly or 
indirectly. Applicants represent that each of the Substitutions will 
have no impact on the insurance benefits that Principal Life is 
obligated to provide under the Contracts or on the other rights of 
contractowners and other obligations of Principal Life under the 
Contracts. Applicants represent that each of the Substitutions will not 
cause

[[Page 65327]]

the fees and charges under the Contracts currently being paid by 
contractowners to be greater after the Substitution than before the 
Substitution. Applicants also represent that each of the Substitutions 
will not have a tax impact on contractowners.

Applicants' Legal Analysis

    1. Applicants request an order pursuant to section 26(c) of the Act 
approving each of the Substitutions. Section 26(c) of the Act makes it 
unlawful for any depositor or trustee of a registered unit investment 
trust holding the security of a single issuer to substitute another 
security for such security unless the Commission approves the 
substitution. The Commission will approve such a substitution if the 
evidence establishes that it is consistent with the protection of 
investors and the purposes fairly intended by the policy and provisions 
of the Act.
    2. Applicants assert that the purposes, terms and conditions of 
each of the Substitutions are consistent with the principles and 
purposes of section 26(c) and do not entail any of the abuses that 
section 26(c) is designed to prevent. Substitution is an appropriate 
solution to the lack of contractowner interest in and higher relative 
expense of the Replaced Funds. Applicants represent that they do not 
expect that any Substitution will have a significant impact on the 
expense ratio of the Substituted Fund and believe that because of lower 
expense ratios each Substituted Fund will serve contractowner interests 
better than the current fund Applicants seek to replace. Moreover, 
Principal Life has reserved the right to effect substitutions in the 
Contracts and disclosed this reserved right in the prospectuses for the 
Contracts.
    3. Applicants represent that each of the Substitutions will not 
result in the type of costly forced redemption that section 26(c) was 
intended to guard against and, for the following reasons, is consistent 
with the protection of investors and the purposes fairly intended by 
the Act:
    (a) Each of the proposed Substitutions permits contractowners 
continuity of investment objectives and expectations.
    (1) Both LCGE and LargeCap Growth seek long term growth of capital 
primarily by investing in common stocks of companies with large market 
capitalizations. LCGE, with its emphasis on investing in companies with 
large market capitalizations, will afford shareholders of LargeCap 
Growth an opportunity for continued investment exposure to companies 
with market capitalizations within an equivalent large market 
capitalization range.
    (2) BC Account seeks long-term growth of capital and growth of 
income primarily by investing in common stocks of well established 
large capitalization companies (similar to companies in the S&P 500 
Index), and LCSI seeks long-term growth of capital by investing 
primarily in common stocks of companies that compose the S&P 500 Index. 
LCSI, with its emphasis of investing in companies that are components 
of the S&P 500 Index, will afford shareholders of BC Account an 
opportunity for continued investment exposure to the kinds of companies 
in which BC Account may invest.
    (3) Both MidCap Growth and MCGE seek long-term growth of capital 
primarily by investing in common stocks of companies with medium market 
capitalizations. MidCap Growth, with its emphasis on investing in 
companies with medium market capitalizations, will afford shareholders 
of MCGE an opportunity for continued investment exposure to companies 
within the same medium market capitalization range.
    (4) Both AAA and Putnam GAAF seek a high long-term return 
consistent with preservation of capital. AAA, with its emphasis on 
investing in equity and fixed-income securities of domestic and foreign 
issuers, will afford shareholders of Putnam GAAF an opportunity for 
continued investment exposure to equity and fixed-income securities of 
domestic and foreign issuers.
    (5) Both Equity Growth and Vista seek capital appreciation by 
investing primarily in growth stocks of U.S. companies. Equity Growth, 
with its emphasis on investing in growth-oriented equity securities of 
U.S. companies, will afford shareholders of Vista an opportunity for 
continued investment exposure to growth stocks of domestic 
corporations.
    (b) The contractowners will have ample opportunity to consider 
their investment options because they will be given notice prior to the 
Substitutions and will have an opportunity to reallocate accumulation 
value among other available Divisions without the imposition of any 
transfer charge or limitation as a result of the Free Transfer Right.
    (c) The costs of each of the Substitutions, including legal, 
accounting, brokerage commissions and other fees and expenses, will be 
borne by Principal Life and will not be borne by the Funds or the 
contractowners directly or indirectly.
    (d) Each Substitution will be at net asset values of the respective 
shares, without the imposition of any transfer or similar charge and 
with no change in the amount of any contractowner's accumulation value 
under the Contracts.
    (e) The Substitutions will not cause the fees and charges under the 
Contracts currently being paid by contractowners to be greater after 
the Substitutions than before the Substitutions.
    (f) Within five days after a Substitution, Principal Life will send 
to contractowners written confirmation that the Substitution has 
occurred.
    (g) The Substitutions will have no impact on the insurance benefits 
that Principal Life is obligated to provide under the Contracts or on 
the other rights of contractowners and other obligations of Principal 
Life under the Contracts.
    (h) The Substitutions will in no way alter the tax benefits to 
contractowners.
    (j) For each fiscal period (not to exceed a fiscal quarter) during 
the 24 months following the date of Substitution into LCSI, AAA and 
Equity Growth, Principal Life will adjust the Contract values invested 
in the Substituted Fund as a result of the Substitution, to the extent 
necessary to effectively reimburse the affected owners for their 
proportionate share of any amount by which the annual rate of the 
Substituted Fund's total operating expenses (after any expense waivers 
or reimbursements) for that fiscal period, as a percentage of the 
Fund's average daily net assets, plus the annual rate of any asset-
based charges (excluding any such charges that are for premium taxes) 
deducted under the terms of the owner's Contract for that fiscal 
period, exceed the sum of: The annualized rate of the corresponding 
Replaced Fund's total operating expenses, as a percentage of such 
Replaced Fund's average daily net assets, for the twelve months ended 
December 31, 2002; plus the annual rate of any asset-based charges 
(excluding any such charges that are for premium taxes) deducted under 
that Contract for such twelve months; and
    (k) For each fiscal period (not to exceed a fiscal quarter) during 
the 24 months following the date of Substitution into LCGE and MidCap 
Growth, Principal Life will, with respect to all Contracts outstanding 
on the date of the Substitution, adjust the Contract values invested in 
the Substituted Fund, to the extent necessary to effectively reimburse 
the owners of those Contracts for their proportionate share of any 
amount by which the annual rate of the Substituted Fund's total 
operating expenses (after any expense waivers or reimbursements ) for 
that fiscal period, as a percentage of the Fund's average daily net 
assets, plus the annual rate of

[[Page 65328]]

any asset-based charges (excluding any such charges that are for 
premium taxes) deducted under the terms of the owner's Contract for 
that fiscal period, exceed the sum of: The annualized rate of the 
corresponding Replaced Fund's total operating expenses, as a percentage 
of such replaced Fund's average daily net assets, for the twelve months 
ended December 31, 2002; plus the annual rate of any asset-based 
charges (excluding any such charges that are for premium taxes) 
deducted under that Contract for such twelve months.
    4. Applicants request an order of the Commission pursuant to 
section 26(c) of the Act approving each of the Substitutions. Section 
26(c), in pertinent part, provides that the Commission shall issue an 
order approving a substitution of securities if the evidence 
establishes that it is consistent with the protection of investors and 
the purposes fairly intended by the policy and provisions of the Act.

Conclusion

    Section 6(c) of the Act, in pertinent part, provides that the 
Commission, by order upon application, may conditionally or 
unconditionally exempt any persons, security or transaction, or any 
class or classes of persons, securities or transactions, from any 
provision or provisions of the Act, or any rule or regulation 
thereunder, to the extent that such exemption is necessary or 
appropriate in the public interest and consistent with the protection 
of investors and the purposes fairly intended by the policy and 
provisions of the Act. Applicants submit that, for the reasons stated 
in the application, their exemptive requests meet the standards set out 
in Section 6(c) and that an order should, therefore, be granted.

    For the Commission, by the Division of Investment Management, 
pursuant to delegated authority.
Margaret H. McFarland,
Deputy Secretary.
[FR Doc. 03-28849 Filed 11-18-03; 8:45 am]
BILLING CODE 8010-01-P