Spread earnings are prospective, variable and unpredictable. Unlike the fees associated with products such as variable annuities or mutual funds, which do not offer a guaranteed rate or assume the risks previously outlined, guaranteed insurance account spreads are not flat, fixed or scalable. In fee parlance, there can even be situations of ‘negative’ fees should there be sustained investment defaults, poor performance, or if cash flows are significantly adverse. In addition, spread also varies based on the insurer’s specific structure of underlying assets, contract terms, and capital requirements. For these reasons, measurement and disclosure of guaranteed insurance account spreads do not provide the ability to perform any meaningful product or insurer comparisons.