Equitable Holdings, Inc.

Good morning, and thank you for standing by. Welcome to the Equitable Holdings Second Quarter Earnings Conference Call. At this time, all participant lines are in listen-only mode. After the speaker's presentation, we will have a question-and-answer session. To ask a question during the session, you will need to press star then 1 on your telephone keypad. Please be advised that today's conference is being recorded. If you require operator assistance, please press star 0. Now, I would like to hand today's conference over to Head of Investor Relations, Isil Mugerasolu. Please go ahead.

Thank you. Good morning and welcome to Equitable Holdings' second quarter 2021 earnings call. Materials for today's call can be found on our website at ir.equitableholdings.com. Before we begin, I would like to note that some of the information we present today is forward-looking and subject to certain SEC rules and regulations regarding disclosure. Our results may materially differ from those expressed in or indicated by such forward-looking statements. So I'd like to refer you to the Safe Harbor language on slide two of our presentation for additional information. Joining me on today's call is Mark Pearson, President and Chief Executive Officer of Equitable Holdings, Robin Raju, our Chief Financial Officer, Nick Lane, President of Equitable Financial, and Ali Dibaj, Alliance Bernstein's Chief Financial Officer and Head of Strategy. During this call, we will be discussing certain financial measures that are not based on generally accepted accounting principles, also known as non-GAAP measures. Reconciliation of these non-GAAP measures to the most directly comparable GAAP measures and related definitions may be found on the investor relations portion of our website in our earnings release, slide presentation, and financial supplement. I would now like to turn the call over to Mark and Robin for their prepared remarks.

Thank you, Michelle. Good morning, and thank you for joining our second quarter earnings call. While there have been some signs of returning to normalcy, of course this pandemic is not over. And we all know we need to be vigilant and especially watch the Delta variant. That said, the consistently strong results we have delivered over the last 18 months, including those of the second quarter we will present today, were made possible by the extraordinary efforts of our equitable team and our continued economic management of the business. Turning to slide three, there are four points which highlight our results for the quarter. Firstly, strong results reported by robust net flows. Our second quarter non-GAAP operating earnings of $758 million, or $1.71 per share, were up 74% on a year-over-year share basis, driven by strong performance from both Equitable and Alliance Bernstein. Assets under management increased 22% year-over-year, $869 billion, driven by strong net flows of $6.1 billion, attributable to robust first-year premiums, and another quarter of strong inflows at Alliance Bernstein, as well as positive equity markets. These comparisons to a year ago are flattering because we were in the middle of the COVID lockdown this time last year. Perhaps it is more meaningful to look at the momentum from Q1 this year. Operating earnings are up 26% quarter over quarter, and assets under management are up 6% this quarter. Second highlight, we continue to optimize shareholder returns. We were very pleased to announce the close of our landlocked variable annuity reinsurance transaction with Venerable in June. As a reminder, this transaction significantly de-risked our balance sheet, reducing CTE 98 capital by more than 64%, and unlocking $1 billion of economic value. Our relationship with Alliance Bernstein also provides us with an opportunity to optimize risk-adjusted returns. We have committed a further $10 billion of our general account to AB's Liquid platform to help them build out private placement bonds and private alternative investments. This provides a number of benefits. First, additional yield for the general account, which will boost EQH earnings. And second, AB will receive incremental uplift in fee revenue and will use this capital to attract other third-party investors and build higher multiple businesses for shareholders. Thirdly, Regulation 213. Understandably, we have received questions on the impact of this regulation. At Equitable, our economic risk management framework remains the cornerstone of how we manage the business. Reg 213 does not impact the economic solvency of the business at all. However, RBC solvency ratio and the amount of dividend we can return to shareholders is driven by statutory reserving. And as we are domiciled in New York, Reg 213 applies to these measures and could have the unintended consequence of requiring us to hold redundant reserves that would not be required if we were domiciled outside of New York State. We've been working closely with the New York DFS. They've been very responsive to address this issue, and I'm pleased to tell you we have received a permitted practice. The permitted practice defers the impact over five years. Our RBC at the end of the second quarter, allowing for this permitted practice and net of management actions like corporate restructuring stands at approximately 450%. And combined with further management actions we can take in the future and our strong capital position of $2.5 billion in holdings, we can maintain cash flows and continue to deliver on our 50 to 60% payout ratio during this five-year permitted practice period. This period enables us to continue to work with the DFS and take other management actions such as reinsurance to permanently reduce redundant reserves. I want to emphasize any actions we pursue on Reg 213 will not impair our economic balance sheet to solve this uneconomic statutory accounting issue. And we will continue to manage the business on an economic fair value basis. Robin will provide more details shortly. And the final highlight is our announcement of new targets to drive long-term value. With our agile workforce, and technology-enabled capabilities, we feel comfortable to deliver an incremental $80 million of expense savings by 2023. With the move to more illiquid asset classes in AB, we target an additional $180 million of incremental investment income by 2023. These new targets, combined with our shift towards a more capital-resilient business mix and leveraging synergies with AB, give us confidence in our ability to achieve 8% to 10% EPS growth while delivering on our mission to help clients secure their financial well-being so they can pursue long and fulfilling lives. Turning to slide four, I would like to highlight our main strategic initiatives and differentiators that give us confidence that we can continue to drive long-term shareholder value. The strength of our distribution model more than 4,000 equitable advisors and over 1,000 third-party relationships, continues to distinguish us as a leader in target markets where we have competitive advantages. As the number two variable annuity provider, we continue to focus on bridging the retirement gap and are the number one RILA provider, posting record SES first-year premiums of $1.9 billion in the second quarter. as clients continue to look to the Buffett annuity market for accumulation solutions. In our group retirement business, we are the number one provider of supplemental retirement solution in the educators K through 12 market. And our business now has $45.9 billion of assets. Gross premiums were $928 million in line with pre-pandemic levels. as our advisors continue to leverage digital capabilities to engage with teachers and other clients in this remote environment. In addition to its contributions as a strategic partner, AB continues to produce solid results with another strong quarter of positive flows, including its 17th consecutive quarter of positive active equity net flows in their retail channel. Second quarter net flows were $6.2 billion, positive in each channel, driven primarily by retail of $5.2 billion, institutional of $0.9 billion, and private wealth of $0.1 billion. Net flows were primarily driven by active equities, multi-assets, and municipals. Importantly, 70% of AB's U.S.-rated assets and 54% of Luxembourg-rated assets were four- or five-star rated by Morningstar. We also continue to focus on growing our nascent businesses, and I would like to highlight the continued momentum in our wealth management business this quarter. Assets Under Advice is up 41%, supported by positive net flows and equity markets, and we continue to see strong engagement between our advisors and their clients as they seek financial planning and advice. As I referenced last quarter, we believe a critical component of delivering shareholder value is bridging profits with purpose. In July, we announced the close of our inaugural sustainable financing transaction. This offering allows us to strengthen the impact of our investment portfolio on society delivering additional yield for our investment portfolio and contributes to the work our teams are doing to ensure that equitable remains a force for good. Turning to slide five, I would like to take a few moments to talk about our synergies with Alliance Bernstein. Managing $121 billion of the separate account and general account assets, equitable and AB create opportunity for each other, ultimately driving enhanced value for shareholders. At the time of our IPO, we announced a target of $160 million of incremental income as we shifted our portfolio from U.S. treasuries to public corporates to better align with our U.S. peers. We achieved this target ahead of schedule in 2019 with an additional $80 million achieved in 2020. as we opportunistically manage the portfolio during the market dislocation we saw last year. We continue to utilize our economic risk management framework to further optimize our investment portfolio. Leveraging AB's investment capabilities, we look to capture a liquidity premium by shifting from public corporates to private credit, structured assets, and alternatives without sacrificing the quality of our book. As a result of these efforts, we are targeting $180 million of incremental income by 2023 to further general account optimization and FABN issuances. In addition, we are committing $10 billion of general account assets to help build out AB's higher multiple businesses and attract additional third-party capital, in turn driving greater earnings potential for AB and EQH. As evidenced by an initial commitment of $5 billion, which has since grown four times to over $21 billion today, AB has a proven track record of growing its private alternatives platform. Looking ahead, we will continue to leverage the unique synergies of our AB relationship to drive value for shareholders. I'll now pass it to Robin to walk through our second quarter results. Robin?

Thank you, Mark. Turning to slide six, I will review our consolidated results for the second quarter before providing more detail on segment results, the Capital Management Program, and updates to Reg 213. Non-GAAP operating earnings were $758 million for the second quarter, up 68% from $451 million in the prior year quarter. Non-GAAP operating earnings per share increased by 74% to $1.71 per share, primarily driven by strong net investment income attributable to strong performance from our alternative investments, higher prepayments, increased fee revenue on higher assets, and share repurchases from our buyback program. The strong performance for the quarter reflects notable positive one-time impact of $100 million, or 23 cents per share, resulting from prepayments and alternatives. The strong performance for the quarter reflects notable positive one-time impact of $100 million, or 23 cents per share, resulting from prepayments and alternatives. normalizing for these items non-gap operating earnings were 658 million in the second quarter or 1.48 per share benefiting from strong new business flows growth in our general account and continued focus on expense management keep in mind going forward we will have an annual impact of 180 million per annum resulting from the venerable deal or approximately 45 million per quarter which we expect to decrease over time due to the claims patterns of the business. The venerable deal unlocked $1 billion in economic value for us, but it has a negative short-term impact on GAAP. AUM in the quarter increased to $869 billion, supported by strong equity markets and positive net flows of $6.1 billion, increasing 22% versus the prior year quarter. Moving to GAAP results, we reported $123 million gain in the quarter, which was primarily driven by the asymmetry in accounting between our economic hedging and GAAP liabilities. With the close of our legacy variable annuity reinsurance transaction, we expect a reduction in this asymmetry from hedging of $300 million annually, to a range of $700 million to $1 billion per annum. Additionally, our options budget related to our static hedge program decreased by $50 million to approximately $150 to $200 million per annum. In the quarter, our hedging program performed as expected with 95% effectiveness. As a reminder, we manage on a fair value basis, which means we did not take bets on interest rates and hedge to our full economic liabilities. Moving to the business segment, I'll begin with individual retirement on slide seven. Non-GAAP operating earnings of $414 million were up 18% versus the prior year quarter, driven by the higher net investment income from prepayments and alternatives and higher fee revenue on higher account value. This is slightly offset by the lower earnings resulting from the Venable transaction, which closed on June 1st. While there is limited impact to this quarter, we expect $180 million of earnings impact per annum related to the transaction, as I mentioned earlier. The higher guidance is driven by stronger equity markets observed over the last year. In the segment, first-year premiums improved 69% versus the prior year quarter, driven by record sales of $1.9 billion in structured capital strategies. This is our strongest quarter of first-year premiums for the segment in over a decade, reflecting the breadth and depth of our distribution and continuous innovation. Net inflows of $762 million on our current product offerings, attributable to record sales, were offset by expected outflows from our capital-intensive fixed-rate block of $940 million. which is in line with our expectations, and further de-risk are enforced. On an annual basis, we expect net flows to improve by approximately $1.3 billion following the venerable transaction. The venerable transaction validated our economic reserving and should give investors comfort on the quality of earnings in this segment. Combined with our differentiated distribution, we remain well positioned deliver protected equity and secure income solutions for our clients. Turning to group retirement on slide 8, we reported operating earnings of $171 million, up 90% versus the prior year quarter, driven by higher net investment income from prepayments and alternatives and higher fee revenue on higher account values. Account values increased by approximately $8.9 billion year-over-year due to market appreciation. Net flows increased to $68 million, led by continued positive net inflows in our 403 business, an improvement from net outflows experienced in the first quarter. Gross premiums remained strong at $928 million, in line with pre-pandemic levels, highlighting the resilience of our business model. We continue to see an increase in renewal contributions of 9% year-over-year, demonstrating the strength of our advisor relationships with our clients. Now turning to the line, Bernstein, on slide nine. In the second quarter, operating earnings were $126 million, up 37% year-over-year, primarily driven by higher base fees on higher average AUM, a 1% year-over-year increase in the fee rate, and lower operating expenses. AB generated net flows of $6.2 billion in the quarter, attributable to positive flows across all three distribution channels, including $6.7 billion of active net inflows and gross sales of $45 billion. This will be AB's seventh straight quarter of positive active equity net inflows. Strong net inflows were led by the retail channel, which reported the second-strongest sales quarter to date with $5.2 billion of net inflows and the 17th consecutive quarter of active equity net inflows in the channel. In AB's institutional channel, the pipeline grew to record $17.8 billion, up 17% sequentially, primarily driven by a large $8 billion customized retirement mandate in addition to concentrated global growth and global core mandates. AB continues to deliver strong performance, with two-thirds or more of fixed income and equity assets outperforming on a three- and five-year basis. Total assets under management at the end of the second quarter were $738 billion, up 23% from the prior year quarter, attributable to strong market performance and positive net flows. Both of these factors contributed to a strong adjusted operating margin in the quarter of 31.7%. As Mark mentioned, we like the synergies between the insurance company and the asset management company, as we commit $10 billion of capital to grow AB's higher multiple businesses and deliver better risk-adjusted general account yields for equitable. Moving to protection solutions on slide 10. We reported operating earnings of $63 million, up from a $12 million loss in the prior year quarter, primarily driven by higher net investment income and higher fee revenue on higher account value. We had improved mortality experience compared to the prior year, with limited impact related to COVID-19 in the quarter. We continue to monitor conditions, though, as they evolve, particularly in light of the Delta variant. and maintain our prior guidance of $30 to $60 million per 100,000 U.S. debt. Growth premiums increased to $748 million, up 8% from the prior year quarter. This was primarily driven by strong growth in our employee benefits business, up 34% year-over-year, and our variable universal life product, which was up 20% year-over-year, highlighting our shifts to less interest-sensitive products. We continue to see strong growth in our employee benefits business, with year-to-date sold premiums already exceeding full-year 2020 results and approximately 536,000 enrollees. Further, average premium per enrolled employee is up 13% year-over-year, to $413 per employee. compared to $366 per employee in the prior year quarter. While we expect some volatility in this segment, we continue to dive towards approximately $50 million in operating earnings per quarter. Turning to slide 11, we remain in a strong capital position. We closed the quarter with $2.5 billion of cash and liquid assets at the holding company. well above our $500 million minimum target. As a reminder, the reinsurance transaction with Venerable, which closed on June 1st, significantly de-risked our balance sheet and unlocked approximately $1 billion of economic value. Also, as part of the transaction, we acquired a 9% equity stake in Venerable's parent holding company for a purchase price of $185 million. which allows us to have a seat on the venerable board. We continue to return capital to shareholders, and in this quarter, we have returned $355 million, including $240 million of residual shares held by AXA after the settlement of their mandatory exchangeable bond in May. Additionally, we accelerated $300 million of share purchases in July. We remain on track to deliver our 50% to 60% payout ratio target this year, plus the additional $500 million as part of the Venable transaction. As Mark said earlier, we have received the permitted practice from the New York EFS on Reg 213 redundant reserves, which allows us to continue delivering on our target payout ratio. I'll share more detail on the final slide. Finally, we closed the second quarter with a combined RBC ratio of approximately 450%, inclusive of the initial Reg 213 impact, which is above our minimum target range of 375% to 400%. Turning to slide 12, I would like to provide an update on our plan to mitigate the uneconomic impacts of Reg 213. An unintended impact of the regulation creates the need for us to hold redundant reserves that would not be required if we're domiciled outside of New York State. This has no economic impact on our business, and it's purely a statutory redundant reserve. We received a permitted practice from the New York DFS that offsets the initial impact and allows us to phase in approximately $2 billion of redundant reserves over five years. thus mitigating impacts to our dividend capacity from our operating subsidiaries. As a result, there is a minimal impact in the second quarter from Ride 213, and with our strong tax position of $2.5 billion at the holdings, we have sufficient capital to maintain our payout ratio through 2022 without any management actions. Looking ahead, we have begun internal restructuring. targeting an increase of unregulated cash flows from 35% up to approximately 50% by year end, which will decrease our reliance on dividends from our New York subsidiary. To date, about half of the internal restructuring is complete, with an increase in unregulated cash flows of approximately $100 million per annum through internal financing. So currently, we are working on internal and external reinsurance solutions that we can implement over the next few years, which will accelerate the release of redundant reserves. We are also utilizing our non-New York insurance entities to distribute business outside of New York, with a target of approximately 90% of products sold through this 49-1 structure by the end of 2022. mitigating any impact of Regulation 213 going forward on our new business. Although we are not pleased with the redundant reserves the New York DFS requires, we are pleased that the Department reacted quickly to our needs for a permitted process as we continue to advocate for a more economic reserving framework. As we work towards additional management actions, our core principles remain unchanged. we will continue to manage the business on an economic basis, deliver on our 50% to 60% payout ratio to shareholders, and focus on long-term economic value generation. I'll now pass it back to Mark.

Thank you, Robin. Before opening up the line for your questions, I would like to reiterate some highlights from our second quarter results. First, we have delivered another strong quarter driven by solid performance and new business flows.

Second,

in alignment with our strategic priority to optimize shareholder returns. We are proud to have closed our landmark VA reinsurance transaction, which meaningfully strengthens our balance sheet. We all continue to build upon synergies between Equitable and Lyons Bernstein, with a further $10 billion commitment to AB to drive higher earnings potential for both companies. Third, The permissive practice for Reg 230 and redundant reserves, along with our strong capital position and management actions, allows us to reaffirm our target payout ratio. And lastly, we are continuing to execute on our strategy to drive long-term growth, supported by our shift to capital resilient businesses and new GA and expense targets. With that, I'd like to open the line for your questions.

Thank you. And as a reminder, if you would like to ask a question, please press star then one on your telephone keypad. Once again, let's star one to come into our question queue. And our first question will come from the line of Elise Greenspan with Wells Fargo.

Hi, thanks. Good morning. My first question is on the capital side. So I just wanted to get an update. You guys have also, since the Venable deal, spoken about looking at M&A as well. Just an update on what you're seeing on the Dell Steel side of things over the last quarter or so.

Good morning, Elise. It's Mark Pearson. Thank you for the question. Obviously, a lot of activity in the marketplace is behind your question. We like the possibility of both on deals as a way to accelerate growth and add capabilities. So we remain open to M&A, but consistent with our strategy. Areas of interest for us would be employee benefits and wealth management, and obviously supporting the build out of alternatives on the AB side. So we continue to look. We have no Nothing to brief you on today, but always with us. I think you can be assured it would need to complement our existing strategy, make economic sense, and most importantly, provide long-term value creation for our shareholders. That's really our position.

And then I was hoping to get just some additional color, just the SDS sales were really strong in the quarter. Just what are you seeing from the competitive environment there? And just how do you think sales should trend over the balance of the year and even initial thoughts on 2022 as well?

Nick, do you want to take that?

Sure. Thank you. As Mark and Robin stated, we saw record sales in the quarter led by our 1.9 billion of SES sales. We continue to see strong consumer demand out there. We expect the pie to continue to grow. We believe competitors entering the space is a net positive because it validates the asset class demand for advisors. And given our strong distribution network, we continue to be well-positioned, and it allows us to focus on profitable growth going forward.

Okay. Thanks for the color.

And our next question will come from the line of Nigel Dolly with Morgan Stanley.

Great. Thanks. Good morning. So with the uncertainty of Reg 213 now resolved, or at least in the process of being addressed, the natural question is why not be more aggressive with buybacks? It seems like you're still sitting on a large amount of excess capital, yet the incremental buybacks is only half of the economic capital which you released from the Venable transaction. Wouldn't it make sense to return a little more of that back to shareholders now that Reg 213 uncertainty has been resolved?

Thank you, Nigel, for your question. It's Robin here. You know, most importantly for us is continue to manage on an economic basis and consistently deliver 50 to 60 percent payout to shareholders. As you know, this year we committed on top of our normal 50 to 60 percent payout, 500 million more on top of that as a result of the venerable deal. And over time, as capital gets freed up, we'll continue to return capital to shareholders.

I guess just to follow up on that, getting the permitted practice is encouraging, but the best outcome would have been a change in the regulation. Is that still a possibility, or are there, I guess, fundamental differences in your view of economic capital relative to DFS? That's what are appropriate reserves for UVA block.

Sure. You know, I think we think the DFS was well-intentioned with Reg 213. However, it clearly has unintended consequences and isn't economic. And we don't see any other reserve that's comparable in any other state. Overall, the relationship with the DFS is good. It proved a venerable deal and it's permitted practice all through a health pandemic. They have indicated to us at the staff level that they don't intend to turn Reg 213 now, so we'll continue to work with them on a more economic reserving framework in the future. But I think most importantly, with the $2.5 billion in cash, the 450 RBC, and the permitted practice, this enables us to keep our payout ratio for shareholders over short, medium, and long term. That's great. Thanks, Robin.

And our next question will come from the line of Jimmy Buehler with J.P. Morgan.

Hi, good morning. So I had a question on the group retirement business. And I think through most of the last few years, your flows have actually been much more stable and healthier than most of your peers. And I understand the makeup of the business is different given the teachers' exposure. But they've been fairly weak this year, and they're down significantly. through both quarters of the year versus last year. So I think last quarter you mentioned you'd seen some weakness because of small businesses. But just if you could talk about what's going on there and what your outlook is for the business.

Great. Thanks, Jimmy. This is Nick. As we reported, we saw $119 million improvement in net flows in Group A. group retirement quarter to quarter. In our tax-exempt business, which is our teacher, we saw strong renewals up 9%. That sector continues to be resilient. Teachers are busier than ever. And I think we're well-positioned, given our investment in remote technologies, to continue to go deeper and broader across our 800-plus thousand clients. In the corporate segment, which is our SME, we did see an improvement in surrenders last quarter. We had some expected plan B conversions, and we saw improvement there. So, you know, we look at our business. I think our core tax exempt is strong. We see digital as giving us an opportunity for the future, and we're continuing to penetrate the SME space.

Okay. And on the 213 resolution with New York, the initial impact that you're talking about faced in over the next few years, is that on the overall in force? And should that impact increase as you're still selling some business through New York? Or is that already taken into account?

Hey, Jimmy, yes, that's already taken into account. But as I mentioned, IN THE PRESENTATION, WE HAVE PLANS IN PLACE TO WRITE ABOUT 90% OF OUR BUSINESS OUTSIDE OF NEW YORK BY THE END OF 2022. SO WE REMAIN WELL POSITIONED ON A NEW BUSINESS PERSPECTIVE AND ON THE INCOURSE, AS I MENTIONED EARLIER, THE PERMITTED PRACTICE ALONG WITH OUR STRONG CAPITAL POSITION SETS US UP HERE TO CONTINUE TO DELIVER CAPITAL TO SHAREHOLDERS.

And some capital obviously still is tied up because of it, and then it increases over time. But if you are able to find a solution, then that gets released. But barring a solution, then more capital gets tied up because of the differences in regulations between states. That's right. Okay. Thank you.

And our next question comes on the line of Sunit Kamath with Citi.

Thanks. Maybe circling back to 2013 to start. So, Robin, can you just talk about the outlook for dividends from your New York sub over the next couple of years? And of those strategies that you mentioned, I guess, on slide 12, how long is it going to take to execute against some of these things? Is this a sort of 2021-22 event, or could it take longer than that? Sure. Thanks, Denis. I think the key is, historically, we've always as a holding company, received $1.5 billion of upstreams from our subsidiaries. We continue to expect that from the subsidiaries, but expect it to be shifted as we'll have more unregulated cash flows as a result of some of the management actions that we're taking. And that should position us well for the future. The management actions from the 35% to 50% or unregulated cash flow should be completed by year end. Any of the reinsurance transactions, if they make economic sense, we'll look at in 2021, 2022 time period. So just to be clear, you're still focused on the $1.5 billion on an annual basis? Correct. Got it. And is there any earnings impact from any of these? actions that you're taking, or is it sort of earnings neutral? No, I mean, the redundant reserve that brought 213 is purely statutory, no impact on GAAP or the economics. And all the actions that we take will not impair any of our management of the balance sheet on an economic basis. Okay, got it. And then my second question, I guess, for either Mark or Ali or both, so clearly you guys have done a lot with the Equitable Alliance Bernstein partnership in terms of managing the general account, but one of the things that you've talked about is trying to scale up Equitable Advisors, and obviously AP has a private client business. Is there any way to sort of think about using those two businesses to scale the wealth management of both operations, or are they just so different that you can't really think about some sort of a combination of the two. Thank you.

Ali, do you want to have a go at that? It would be good to hear from you. Sure. Hey, Sunil.

So, okay, I think there are a couple of things to think about. One is it is a complementary client set on average. There is certainly some overlap, but it is a little bit complementary in terms of what products are being served and what clients are being served. That's one thing. Now, on the one hand, that offers you opportunity to progress a client, perhaps across income levels or life stages, and that's something that we're certainly thinking through and trying to capitalize on. On the other hand, the second point is that the products are also different. So something that you'd offer perhaps an ultra-high-net-worth client, which is a little bit more in tune to what we do at the Alliance First and private wealth side, is going to be different than what might happen on the Equal Advisor side. That doesn't mean there aren't, to meet your point, opportunities there. It's something that the two firms are working more and more cohesively on and thinking through from a client segmentation perspective, from a model of portfolio perspective, et cetera. There are opportunities, but we haven't quite capitalized on those at this point. So the short answer is yes, there's opportunity, but we haven't quite fleshed it out, and it's something we're looking forward to trying to do going forward. Okay, thanks.

Thank you. And our next question comes from the line of Ryan Kruger with KBW.

Hey, good morning. Could you provide any more detail on, I guess, what you're doing specifically to increase the unregulated cash flows?

Sure, Ryan. It's been a key focus for us inside PO on increasing unregulated cash flows. You saw us do it in the past by upstreaming the AB units for the Holdco. And now we're taking that next step and specifically what we're doing, we're providing administrative services for our mutual funds in the insurance separate account from another subsidiary in the Holdco. This enables us to service both the business outside of New York, but also the new business that we'll be selling outside of New York going forward. So specifically, there's service administration contracts that we're providing for the mutual funds underlying our separate accounts, and they were approved by the independent boards of the mutual funds in the second quarter.

Got it. Thanks. And then in terms of potential internal and external reinsurance, would this be more focused on on annuities, or could this be on the life block?

I think anything that we do will be on an economic basis, number one. The second aspect, we're going to look at all blocks from an enforced perspective, life and annuities, and if something makes economic sense that impacts the redundant reserves related to Right 213, we'll take a serious look and consider actions.

Thanks. Just one quick, I may have missed this, but do you suspect corporate segment annual losses to be around $300 million a year?

That's right. That's our expectation. There's obviously some seasonality if you go in this quarter, but $300 million on an annual basis for corporate analysis. Great. Thank you.

And our next question will come from the line of Thomas Gallagher with Evercore.

Good morning, Nate. Just some questions on this 213. So the five-year permitted practice from the NYDFS, that was already, I guess, on the books in early 2021. Is that just you requesting to use the five-year phase-in, or is there something different and apart from that that was granted to Equitable?

Sure. So, Tom, as part of the venerable transaction, it unlocked $1 billion of economic value, significantly reduced the risk in the company, but accelerated the Reg. 13 reserve as it wasn't aligned to our economic hedging. So the permitted practice allows us to defer that acceleration and align it better to our interest rate hedging specifically on an economic basis, and that we get to save in those redundant reserves over a five-year period as a result.

Okay, and so, Rob, the 450 RBC would reflect what, 20% of the initial impact of this so far then? Would that be about $400 million of the $2 billion is reflected in your 450 RBC at this point?

Yeah, the minimal impact of the Reg 213 reserves, as of half-year because of the permitted profits that you receive. You do see the increase as a result of the Venable transaction, but minimal impact from Reg 213 as of half-year.

Gotcha. So that's going to be a year-end event when you start to see the impact coming through? Correct. That'll be a part of the $2 billion phase-in. Okay, and then the $1.5 billion of annual dividends from subs that you said you still expect to get, I presume 2021 is going to be only AB, and then would you expect to get the full, be back to $1.5 billion by 2022, or how would you expect the timing of that to look? And is the plan to still just to... to draw down on the access at the holding company for 2021?

That's right. As you remember, last year, we took two dividends out of the Life Company in New York. As a result, this year, the upstreams are mainly coming from Alliance Bernstein. And then going forward in 2022, we still expect upstream about $1.5 billion, but more unregulated cash flows as a result of the management actions that were taken. The existing strong cap position at $2.5 billion is there to support a consistent payout ratio for our shareholders.

But, Robin, do you think you'll be in a position where you're back to getting $1.5 billion up to the holding company? I know the – I guess where they come from is probably going to change based on some of the substructuring. But would you expect normal dividend flows of $1.5 billion or so to be back in 2022, or is it potentially going to take a bit longer?

No, yeah. Under normal market conditions, I would expect to have $1.5 billion in 2022, but more unregulated cash flows to provide more certainty as well.

Gotcha. Thanks. And then just one final one, if I could. The AB announcement, is there anything, when I think about the $10 billion of redeployed investments, Is the way this is going to work that you would potentially sell public corporate bonds and then buy less liquid, higher-yielding securities? And if so, is that going to result in you crystallizing gains on your current portfolio? Will that have any statutory impacts if that's the way it's going to work?

Sure. So as Mark mentioned, and Ali as well, and Dave Yearing's call, we're really pleased with the synergies between the firms, and this is one of the major areas. And it enables us to enhance risk-adjusted returns for the equitable insurance company. And AB goes out and builds higher multiple businesses with this $10 billion that we give them. The majority of the $10 billion is a reallocation from public-corporate into illiquid private credit and also alternatives that AB can build upon with third-party funds as well. And I'd expect that to be completed by 2023. Okay, thanks.

And our last question this morning will come from the line of Tracy Ben-Gigi with Berkeley.

Good morning. Look, your VA enforced, most of that was written out of your New York entity. Can you share with us what percentage of your VA reserves within Equitable Financial Life Insurance Co. is for New York policies versus non-New York policies?

We haven't chaired that split, but the majority in the life company is from non-New York policy that exists today. But we haven't chaired the exact split of that.

Okay. And I guess that dovetails to my next question. I want to make sure I'm thinking about this correctly. You mentioned internal reinsurance. So how feasible is it to reinsure your non-New York policies that was written at New York entity to your Arizona entity under a captive structure?

You know, I think we're looking at both internal and external reinsurance, as I mentioned. You know, I don't want to go into specific details on any one that we're evaluating, but everything that we do will be judged against our economic basis, ensuring that we can deliver long-term shareholder value while addressing these redundant reserves in New York.

Okay. And then I guess just maybe one quick follow-up there, just looking at external reinsurance. Should we think about a block size similar to your Venable deal, or could that differ?

It could be similar. It could differ. It depends always on the economic value that we receive for any block that we cut out.

Thanks for taking my question. Thank you. And with that, we will conclude today's Equitable Holdings Second Quarter Earnings Conference call. We appreciate your participation and ask that you please disconnect. Thank you.