Form 497VPSUB Files Dataset

The Form 497VPSUB Files Dataset is a curated collection of EDGAR submissions of form type 497VPSUB — the prospectus supplements that registered variable annuity and variable life insurance separate accounts file under Rule 497 of the Securities Act when an underlying fund inside a contract is being replaced under Section 26(c) of the Investment Company Act of 1940. One record corresponds to one EDGAR accession: a single filing that bundles the structured EDGAR header (metadata.json) with the primary HTML supplement document (*497vpsub.htm) carrying the substitutions table, effective-date callout, operational mechanics, and contract-holder disclosure. Filings are produced by life insurance company depositors on behalf of their N-3, N-4, and N-6 separate-account registrants, triggered by an SEC-approved fund substitution rather than a calendar deadline. The dataset covers every 497VPSUB submission since the form type was introduced in EDGAR Release 22.1 in March 2022, packaged as monthly ZIP containers of HTML and JSON files.

Update Frequency
Daily
Updated at
2026-05-02
Earliest Sample Date
2022-03-01
Total Size
4.0 MB
Total Records
848
Container Format
ZIP
Content Types
HTML, JSON
Form Types
497VPSUB

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Dataset Index JSON API

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Dataset Files

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2023-03.zip349.1 KB86 records
2022-09.zip230.8 KB42 records
2022-07.zip142.6 KB30 records
2022-05.zip13.2 KB4 records
2022-04.zip12.8 KB3 records
2022-03.zip112.6 KB30 records

What This Dataset Contains

The dataset captures the full public population of Form 497VPSUB submissions on EDGAR — the narrowly scoped, event-driven prospectus supplements through which insurance company separate accounts notify variable-contract owners that one underlying investment option is being replaced with another. Form 497VPSUB is a comparatively young EDGAR submissions type, introduced in EDGAR Release 22.1 in March 2022 and dedicated to substitution-related supplements and correspondence for variable insurance contracts. It satisfies the prospectus-supplement filing obligation that arises whenever a registrant of a variable annuity or variable life separate account replaces one underlying investment option (typically a "fund of funds" subaccount portfolio) with another, after the underlying substitution application has been processed under Section 26(c) of the Investment Company Act of 1940.

Functionally, a 497VPSUB filing is the public-facing notice to existing variable-contract owners that an underlying portfolio is being swapped, on a stated effective date, for a designated replacement portfolio, with disclosure of the operational mechanics, tax treatment, expense allocation, and contract-holder rights surrounding the substitution. In form, the filing is a prospectus supplement: a styled HTML document keyed off, and intended to be read alongside, the existing prospectus(es) of the affected variable products. 497VPSUB filings are not XBRL-tagged and carry no financial-data files; they are narrative legal-disclosure documents anchored by one or more substitution tables.

Each record is materialized as one accession-named folder inside a monthly ZIP container located at <datasetId>/<year>/<year>-<month>.zip. The folder name is the 18-digit zero-padded EDGAR accession number with no dashes (for example, 000119312525152192) and contains exactly two artifact types: a metadata.json describing the filing in structured form, and one or more HTML documents carrying the prospectus supplement, named with a 497vpsub.htm suffix.

Content Structure of a Single Record

What one record represents

One record in the Form 497VPSUB Files Dataset corresponds to a single EDGAR submission of form type 497VPSUB: one accession number filed by the registrant of a variable-annuity or variable-life separate account under Rule 497 of the Securities Act of 1933, in connection with the Commission Statement on Insurance Product Fund Substitution Applications. The record bundles the structured filing metadata together with the public narrative documents attached to that accession; image-type attachments are deliberately excluded from the payload.

The record unit is the filing, not the individual supplement narrative, the individual fund-substitution event, the individual series, nor the individual contract. A single 497VPSUB accession can, and frequently does, name multiple separate-account series and dozens of class/contract identifiers under one umbrella supplement. Conversely, a coordinated substitution that spans multiple separate accounts may surface as several near-identical records filed on the same day under different accession numbers and CIKs.

Layered structure of a record

A record contains two layered structures:

  1. Structured filing metadata (metadata.json) — a JSON document mirroring the EDGAR header for the submission, listing every document EDGAR knows about (including those excluded from the dataset payload), every filer/subject entity, and the variable-insurance series-and-contract taxonomy attached to the filing.
  2. Primary supplement document (*497vpsub.htm) — a single HTML file wrapped in EDGAR's SGML <DOCUMENT> envelope, containing the prospectus-supplement narrative, the substitutions table, and the operational and boilerplate disclosure.

There is no separate cover page, signature page, exhibit list, or financial-statement section: the supplement is self-contained. The metadata.json plays the role of EDGAR header and EDGAR filing index; the HTML file carries the entire substantive disclosure.

metadata.json

The metadata file is the structured representation of the EDGAR submission header and filing index. Top-level fields include:

  • formType — fixed at "497VPSUB".
  • accessionNo — the canonical dashed EDGAR accession number, e.g. "0001193125-25-152192".
  • filedAt — ISO-8601 timestamp of submission with EDGAR's Eastern-time offset.
  • effectivenessDate — the effectiveness date declared on the EDGAR header (YYYY-MM-DD); for Rule 497 supplements this is typically the same day as filing and is not the same as the substitution's effective date stated in the body of the supplement.
  • description — the short EDGAR description string, generally "Form 497VPSUB -".
  • linkToFilingDetails, linkToHtml, linkToTxt, linkToXbrl — direct URLs to the primary HTML document, the EDGAR filing index page, the complete-submission text bundle, and (where applicable) an XBRL viewer. For 497VPSUB the XBRL link is empty because the form is not tagged.
  • id — a 32-character hexadecimal internal record identifier, distinct from the accession number.
  • dataFiles — present but empty: 497VPSUB filings carry no XBRL or financial data files.
  • documentFormatFiles[] — an array of every document EDGAR lists in the filing index. Each element carries sequence (EDGAR sequence number, with "1" denoting the primary 497VPSUB document and trailing whitespace-sequenced entries describing the complete-submission text bundle), documentUrl, description, type (such as 497VPSUB or GRAPHIC), and size in bytes (string-typed). Image entries (typically GRAPHIC .jpg logos and similar) are listed here for completeness, but the binary files themselves are not packaged in the dataset.
  • entities[] — one element per filer or subject entity drawn from the EDGAR header, with companyName (suffixed with the entity role, e.g. "... (Filer)"), cik, irsNo, fileNo, filmNo, formType, act (the Securities Act of 1933 number, e.g. "33"), stateOfIncorporation, and fiscalYearEnd formatted as MMDD.
  • seriesAndClassesContractsInformation[] — the variable-product taxonomy that distinguishes insurance-product EDGAR filings from ordinary corporate filings. Each element identifies one separate-account series by its EDGAR Series ID (S000XXXXXXX) and name, and lists classesContracts[] — an array of contract entries, each with a classContract (EDGAR Contract ID C000XXXXXXX) and a name corresponding to the marketing label of the variable product (for example, "CorpExec VUL Plus" or "Corporate Executive Accumulator Variable Universal Life"). A single 497VPSUB record can name multiple series and dozens of class/contract identifiers when a substitution sweeps across an entire VUL or VA product line.

Primary supplement HTML document

The *497vpsub.htm file carries the substantive disclosure. It is not a plain HTML document; it is wrapped in the legacy EDGAR SGML <DOCUMENT> envelope, which prefixes the HTML body with header pseudo-tags such as <DOCUMENT>, <TYPE>497VPSUB, <SEQUENCE>1, <FILENAME>, <DESCRIPTION>, and <TEXT>, and closes with </TEXT></DOCUMENT>. The HTML body itself sits inside this envelope and is a self-contained styled document with inline CSS, legacy <font> and <div> styling, HTML entity references for typographic punctuation (&#8220;/&#8221; for smart quotes, &#8211; for en-dashes), no JavaScript, no external stylesheets, and no inline images.

Within the HTML body, a 497VPSUB supplement typically follows a recognisable structure:

  • Title block — a header line of the form SUPPLEMENT DATED <date>, the name of the issuing insurance company (for example, New York Life Insurance and Annuity Corporation / NYLIAC), and the affected variable products listed by their marketing acronyms (for example, CEVUL II-V, CEVUL VI, CEVUL Plus, CEAVUL). When the supplement amends multiple existing prospectuses simultaneously, all affected prospectus dates are enumerated here.
  • Effective-date callout — a prominent paragraph stating the substitution's effective date, often phrased "on or about <Month Day, Year>". This date is typically a future date relative to the filing date.
  • Substitutions table — the core disclosure, mapping each Existing Portfolio (the underlying fund being removed) to the corresponding Replacement Portfolio (the fund taking its place). Each row identifies the portfolio name and class designation on both sides — for example, Victory RS Small Cap Growth Equity VIP Series – Class I mapped to ClearBridge Variable Small Cap Growth Portfolio – Class I. A single supplement may contain a one-row substitution or a many-row swap of an entire fund lineup.
  • Prior to / On / After the Effective Date sections — three narrative blocks describing the operational mechanics. The "Prior to" block typically explains contract-holder transfer rights and notice provisions; the "On the Effective Date" block describes the mechanical conversion of accumulation units, the share-for-share replacement, and treatment of any sweep, redemption, or in-kind exchange; the "After the Effective Date" block explains free-transfer counting, the new prospectus references, and any time-limited transfer privileges.
  • Boilerplate disclosure — standard language confirming that all expenses associated with the substitution will be borne by the insurer or its affiliate (not the contract holder), that the substitution will not result in a taxable event for contract owners, and that the supplement should be read in conjunction with the underlying product prospectus(es).

The document does not generally carry separate signature blocks, exhibit indices, or auditor consents. Those legal artifacts attach to the underlying registration statement and the Section 26(c) substitution application, not to the prospectus-supplement notice.

Included content

Every record includes the structured metadata.json and the primary *497vpsub.htm supplement document. Where an EDGAR submission contained multiple narrative documents (for example, separate supplements for distinct product families filed under the same accession), all such non-image documents are included. The record additionally captures, by reference within metadata.json, the complete EDGAR document inventory, the series/contract taxonomy, the filing-entity roster, and direct URLs back to the EDGAR sources of truth.

Excluded or separate content

Image attachments — typically GRAPHIC-typed .jpg company logos and similar binary assets listed in documentFormatFiles[] — are intentionally excluded from the ZIP payload. Their existence is preserved in the metadata listing (with original document URL, description, type, and size), but the binary files themselves are not retained.

The dataset also does not include:

  • the underlying product prospectus(es) that the supplement amends — these are separate filings (typically N-4, N-6, N-VPFS, or related forms) under their own accessions;
  • the Section 26(c) substitution application that authorised the swap (typically routed through an exemptive application filed under Form N-14 or an equivalent vehicle);
  • any subsequent supplements or amendments — each is a distinct EDGAR submission with its own accession.

Records do not contain XBRL exhibits, financial statements, or auditor reports because the form does not carry such content.

Stability of required content over time

Form 497VPSUB is a comparatively young EDGAR submission type — it was introduced in EDGAR Release 22.1, with the earliest filings dating from March 2022 — and the structural and disclosure expectations have remained stable across the entire dataset coverage window. There has been no migration of required Items, no introduction of new mandatory disclosure blocks, and no change in the legal anchor (Rule 497 of the Securities Act, in conjunction with the Commission Statement on Insurance Product Fund Substitution Applications). The substitutions table, the effective-date callout, the prior/on/after operational disclosure, and the expense and tax-treatment boilerplate have been the recurring backbone of these supplements since inception.

Stability of data format over time

Because the form was introduced after EDGAR's full transition to HTML-based submissions, every 497VPSUB filing in the dataset is delivered as styled HTML wrapped in the SGML <DOCUMENT> envelope. There is no ASCII-only legacy era to account for, no XBRL or inline-XBRL transition (the form does not carry tagged data), and no historical change in the metadata schema for series-and-contract identifiers. HTML payloads vary in styling conventions across filers — some use modern CSS classes, others rely on legacy inline <font> styling — but the structural envelope and the metadata layout are consistent across the coverage period.

Interpretation and extraction notes

Several nuances matter when extracting and interpreting these records:

  • SGML envelope handling. The primary HTML file is wrapped in the EDGAR <DOCUMENT> envelope; naive HTML parsers must either skip everything before <HTML> or strip the <DOCUMENT>, <TYPE>, <SEQUENCE>, <FILENAME>, <DESCRIPTION>, and <TEXT> lines explicitly, then close the corresponding </TEXT></DOCUMENT> trailer.
  • Series and contract fan-out. A single accession can name many series and many class/contract identifiers, so analysts joining 497VPSUB records to series-level or contract-level reference data must explode seriesAndClassesContractsInformation[] rather than treating each filing as a single-series event.
  • Filing-as-record vs. event-as-record. Because the dataset record unit is the filing, a substitution affecting an entire VUL product family appears as one record even though it economically affects many contracts. A coordinated substitution across multiple separate accounts may instead appear as several near-identical records on the same day under different accession numbers and CIKs.
  • Broken image references. Image references inside the HTML, where they exist, point to assets that are deliberately omitted from the dataset payload; downstream rendering will produce broken image links and should treat that as expected behaviour rather than corruption.
  • Substitutions-table extraction. The substitutions table is the single most extraction-relevant block. Portfolio names and class designations vary in punctuation (smart quotes, en-dashes, parenthetical class qualifiers) and in capitalisation across filers; disambiguation against fund identifiers (CIK, Series ID, Contract ID) generally requires fuzzy matching against the EDGAR series-and-class registry.
  • Two distinct effective dates. The effectivenessDate field in metadata.json reflects the EDGAR header's declared effectiveness for the supplement filing itself, and is typically the filing date. It is not the substitution's effective date — which is the operationally meaningful date for contract holders, is generally a future date, and must be parsed from the body text of the supplement when needed.

Who Files or Publishes This Dataset, and When

Who files the record

Each Form 497VPSUB record is filed by a registered insurance company separate account that issues variable annuity contracts or variable life insurance policies, acting through its life insurance company depositor as the operational filer on EDGAR.

The legal filer is the separate account itself, registered as an investment company on:

  • Form N-4 — variable annuity contracts funded through a unit investment trust separate account,
  • Form N-3 — variable annuity contracts funded through a managed separate account, or
  • Form N-6 — variable life insurance policies.

The depositor is the state-regulated life insurer (for example, a NYLIAC, Lincoln, Prudential, or Jackson subsidiary) that established and funds the separate account. Underwriting and distribution affiliates may appear in the EDGAR header, but the registrant of record is the separate account.

Operating insurance holding companies, mutual fund complexes (Form N-1A), closed-end funds, ETFs, business development companies, and ordinary Exchange Act registrants do not file 497VPSUB. The form is restricted to registered variable insurance product separate accounts that are executing a fund substitution within their underlying-fund menu.

What triggers the filing

The filing is event-driven, not periodic. The trigger is a fund substitution under Section 26(c) of the Investment Company Act of 1940: the depositor replaces shares of one underlying fund held by the separate account (a subaccount investment option offered to contract owners) with shares of a different underlying fund.

Common reasons for a substitution include:

  • consolidating overlapping options after an insurer acquisition or product reorganization,
  • replacing an underperforming or higher-cost fund with a cheaper or affiliated alternative,
  • moving assets from a third-party-managed fund to an affiliated fund (or vice versa),
  • terminating a fund whose adviser or sub-adviser has resigned, or
  • pruning the menu of an aging or closed-block product.

A substitution is a structural change to the contract's investment menu imposed by the insurer. It is not a routine portfolio rebalancing and not a contract-owner-initiated transfer, which is why Section 26(c) requires Commission approval before it can be effected.

Timing and sequence

Filing timing is anchored to the Section 26(c) substitution order, not to a calendar:

  1. The depositor files a Section 26(c) substitution application (often paired with Section 17 relief for affiliated transactions). The Commission staff publishes a notice and, absent a hearing request, issues an order.
  2. After the order, the insurer prepares a prospectus supplement identifying the replaced fund, the replacement fund, the effective date, the NAV-based mechanics, expense protections, and contract owners' free-transfer rights.
  3. The supplement is filed on EDGAR as Form 497VPSUB shortly before the effective date, typically alongside the contract-owner notice mailing.
  4. A single substitution often produces multiple 497VPSUB filings — pre-effective notice supplements, an effective-date supplement, and post-substitution updates — so the dataset contains several records per event.

Important distinctions

  • Submission type history. The 497VPSUB submission tag was introduced in EDGAR Release 22.1 (March 2022). Earlier substitution supplements were filed under generic 497-family tags (497, 497J, 497K) and are not in this dataset. The Section 26(c) substitution regime itself dates to the 1970 amendments to the 1940 Act.
  • 497VPSUB versus other Rule 497 filings. Rule 497 covers all prospectus and supplement filings by registered investment companies. 497VPSUB is reserved for substitution-related supplements produced pursuant to the Commission's Statement on Insurance Product Fund Substitution Applications. Sticker supplements covering fee changes, sub-adviser changes, or other contract-term updates continue to use the generic 497 types.
  • Filer versus affected funds. The replaced fund and the replacement fund are not filers on 497VPSUB. They are separate registrants (typically insurance-dedicated series of open-end funds) that make their own filings on Form N-1A and under their own Rule 497 submissions.
  • Holding company versus separate account. A publicly traded life insurance parent files 10-K, 10-Q, and 8-K under the Exchange Act. Its registered separate-account subsidiary is a distinct registrant under the 1940 Act/Securities Act regime and is the entity that files 497VPSUB.
  • Out of scope. Private placement variable annuities (relying on Section 3(c)(7) and Regulation D), foreign-issuer variable products, and any unregistered separate accounts fall outside Section 26(c) and do not appear in this dataset.

How This Dataset Differs From Similar Datasets or Filings

Form 497VPSUB sits at the intersection of three regimes: Rule 497 prospectus supplements, variable-contract registration, and Section 26(c) substitution proceedings. Several nearby form types share filers, content, or legal context with 497VPSUB but are not interchangeable with it.

Plain Form 497 (Rule 497 supplements)

Form 497 is the umbrella submission type for any definitive prospectus, sticker, or supplement filed under Rule 497, covering open-end funds, closed-end funds, ETFs, and variable separate accounts. 497VPSUB is technically a Rule 497 filing, but EDGAR carves it out so that substitution-related supplements for variable insurance products can be isolated from the much larger general 497 stream. A plain 497 may carry fee changes, manager changes, risk additions, or NAV restatements across the full fund universe; 497VPSUB is restricted to variable-contract separate accounts and to the underlying-fund-substitution use case.

Form 497K (summary prospectus)

Filed under Rule 498 and used for the summary prospectus of open-end mutual funds. It is recurring, standardized, and investor-disclosure oriented. Variable products use a parallel summary-prospectus regime under Rule 498A, not Form 497K. The contrast with 497VPSUB is functional: 497K describes a fund's current summary state; 497VPSUB documents a discrete substitution event affecting a variable contract's underlying menu.

Form 497J (certification of no material change)

A short certification under Rule 497(j) asserting that the definitive prospectus does not differ materially from the most recent post-effective amendment. It is procedural, not substantive. Form 497J signals "nothing changed"; 497VPSUB signals a specific material change — an underlying-fund replacement — that requires updated contract-holder disclosure. Functionally opposite signals within the same Rule 497 family.

Variable-contract registration forms: N-3, N-4, N-6

  • N-3 — variable annuity separate accounts organized as management investment companies.
  • N-4 — variable annuity separate accounts organized as unit investment trusts (the dominant structure).
  • N-6 — variable life insurance separate accounts.

These are the foundational, periodic registration statements that establish the contract prospectus and SAI, including the lineup of underlying investment options. 497VPSUB amends a single dimension (fund identity) of an already-effective N-3, N-4, or N-6 prospectus. The registration forms are broad and structural; 497VPSUB is event-driven and narrow. A complete substitution history requires both.

485APOS / 485BPOS post-effective amendments

These are the standard vehicles for amending an effective N-3, N-4, or N-6 registration — used for annual updates, fee-table refreshes, fund-lineup expansions, and other substantive changes that warrant a new prospectus. 497VPSUB is not an amendment to the registration statement; it is a supplement filed under Rule 497 to deliver substitution-specific disclosure between or alongside such amendments. A registrant choosing 485BPOS is restating the prospectus; one choosing 497VPSUB is sticking the existing prospectus with substitution language.

Form N-VPFS (variable product financial statements)

Carries audited separate-account financial statements for variable insurance products. Same filer population as 497VPSUB but a fundamentally different artifact: tabular financial reporting rather than narrative prospectus disclosure, periodic rather than event-driven, and silent on fund-substitution mechanics.

Section 26(c) substitution applications (40-APP) and Form N-14

This is the most important boundary. A fund substitution inside a variable contract is not unilateral: the insurer must obtain an Section 26(c) order under Section 26(c) of the Investment Company Act of 1940, filed as an exemptive application (typically routed through 40-APP-family submission types). Where the substitution is paired with an actual fund merger, a N-14 registration statement covers the reorganization of the funds themselves.

These application filings are pre-event and adversarial-record in nature: they request Commission authority, present the rationale, identify replaced and replacement funds, and argue contract-holder protection. Form 497VPSUB is the post-approval disclosure — the supplement actually delivered to contract holders once the order has been granted and the substitution is being effected. The two are sequential, not duplicative: the application family for the legal proceeding, 497VPSUB for the contract-holder-facing notice.

Key differences at a glance

Dimension497VPSUBClosest neighbor
Subject matterUnderlying-fund substitution onlyPlain 497: any prospectus update
Filer populationVariable annuity / variable life separate accounts497K: open-end mutual funds
TriggerA specific approved substitution event497J: routine no-change certification
Role in pipelinePost-approval contract-holder notice40-APP / N-14: pre-approval legal application
Document typeNarrative prospectus supplementN-VPFS: financial statements; N-3/N-4/N-6: full registration; 485BPOS: post-effective amendment

Boundary summary

Form 497VPSUB is the single-purpose disclosure output sitting at one specific point in the variable-product pipeline: a Rule 497 supplement, attached to an existing N-3, N-4, or N-6 registration, restricted to variable insurance contracts, and limited to substitution events already authorized under Section 26(c). It is not the substitution application, not a fund reorganization registration (N-14), not a base contract prospectus (N-3/N-4/N-6), not a post-effective amendment (485APOS/485BPOS), not separate-account financials (N-VPFS), not a summary prospectus (497K), and not a no-change certification (497J). Its dataset value lies in that narrowness — a small, legally distinct stream of contract-holder-facing substitution notices that would otherwise be buried inside the much larger general-purpose 497 corpus. Adjacent datasets complement it but cannot replace it.

Who Uses This Dataset

Form 497VPSUB filings document fund substitutions inside variable annuity and variable life separate accounts: the replaced fund, the replacement fund, the effective date, and the disclosure delivered to contract holders. The dataset is read by a tightly defined set of insurance-product, fund-distribution, compliance, and oversight roles.

Insurance-product counsel at variable-product issuers

In-house and outside disclosure counsel for variable annuity and variable life issuers use the corpus as a precedent library for substitution supplements. They benchmark how peers articulate the comparison of replaced and replacement funds, summarize Section 26(c) order conditions, and describe free-transfer windows, then calibrate their own draft supplements against staff expectations.

Product managers for variable annuity and variable life lineups

Separate-account product managers track competitor substitution activity to inform menu rationalization decisions: replacing underperformers, consolidating share classes, swapping unaffiliated funds for affiliated ones, or migrating to lower-cost index sleeves. They focus on replaced/replacement fund identity, asset-class mapping, fee differentials, and timing.

Distribution and competitive-intelligence teams at VIT/VIP asset managers

Asset managers running insurance-dedicated funds read substitutions as wins and losses on insurance-platform shelves. Sales coverage prioritizes outreach to issuers where their funds are at risk; competitive intelligence aggregates events to map share shifts and identify which strategies (target-date, low-vol, multi-asset, ESG) are gaining or losing placements.

Broker-dealer compliance teams distributing variable contracts

Compliance officers update due-diligence files on approved contracts when underlying funds change, flag substitutions affecting in-force books so registered reps are prepared for client questions, and confirm that point-of-sale and ongoing-disclosure materials reflect the current sub-account menu.

Financial advisors servicing variable-contract policyholders

Advisors and their service teams use supplements to identify which sub-accounts in a client's contract are changing, the effective date, and any free-transfer or opt-out window. The side-by-side fund descriptions and fee tables drive client communications and post-substitution reallocation decisions.

Transfer-agent and contract-administration operations

Operations groups treat the supplement as the operational source of truth for sub-account mapping changes. They focus on effective dates, fund identifiers, and the mechanics of transferring contract value, then reconcile the legal event against recordkeeping fund tables and confirmation-statement language.

Regulatory staff in insurance-product oversight

Staff reviewing variable-product disclosure and enforcement matters monitor whether substitutions comply with Section 26(c) order conditions, whether disclosure adequately compares the funds, and whether patterns suggest affiliate favoritism. The corpus supports comment letters, sweep exams, and case selection.

Academic researchers in insurance and investment-company law

Researchers study affiliated-for-unaffiliated swap rates, fee and performance differentials between replaced and replacement funds, and contract-holder welfare effects. Structured fields (fund pair, effective date, fee tables) and qualitative justifications support empirical work on conflicts of interest in insurance-affiliated complexes.

Data vendors maintaining variable-product databases

Analysts at variable-product data providers use 497VPSUB as a primary source for keeping sub-account universes current. Accession-level metadata, fund identifiers, and effective dates feed automated pipelines and historical substitution panels used downstream by advisors and asset managers.

LLM and RAG developers on investment-company filings

The narrow, repeating structure of 497VPSUB content (replaced fund, replacement fund, rationale, effective date, contract-holder rights) makes the corpus a useful benchmark for fine-tuning and evaluating extraction of substitution events and supplement summarization.

Synthesis

The dataset serves the full variable-insurance substitution lifecycle: counsel and product managers who design and document the change, asset-manager distribution teams swapped in or out, broker-dealer and advisor teams who operationalize it for policyholders, administration teams who execute it, regulatory staff who supervise it, and researchers and data vendors who study and track it.

Specific Use Cases

The Form 497VPSUB Files Dataset supports a focused set of operational workflows tied to fund substitutions inside variable annuity and variable life separate accounts.

  • Building a fund-substitution event panel. Parse the substitutions table from each *497vpsub.htm document together with seriesAndClassesContractsInformation[] from metadata.json to produce a row-level panel of (existing portfolio, replacement portfolio, separate-account series, contract IDs, in-body effective date, filing date). The output feeds longitudinal studies of affiliated-for-unaffiliated swaps, share-class migrations, and fee-differential analysis at the fund-pair level.

  • Drafting precedent search for disclosure counsel. Index the supplement HTML by issuer (filer entity in entities[]), affected product names in the title block, and the Prior to / On / After the Effective Date narrative blocks. Counsel preparing a new substitution supplement queries the corpus for peer language on free-transfer windows, expense allocation, and tax-treatment boilerplate, then aligns drafts with prevailing staff expectations.

  • Sub-account menu maintenance for variable-product databases. Run a daily job over new accessions, extract the substitution table and the effectivenessDate plus the in-body "on or about" effective date, and emit change records that update sub-account universes keyed by Contract ID (C000XXXXXXX). Downstream advisor-facing tools and competitive-intelligence dashboards consume the updates without manual re-keying.

  • Distribution shelf-loss and shelf-win monitoring at VIT/VIP asset managers. Match replaced and replacement portfolio names against the manager's own fund roster using fuzzy matching, then aggregate by issuer CIK and filing month to quantify net placements gained or lost across insurance platforms. Sales teams prioritize outreach to issuers where their funds are flagged as the existing portfolio in pending supplements.

  • Operational readiness for transfer-agent and contract-administration teams. Extract the in-body substitution effective date, the per-row class designations, and the operational language describing accumulation-unit conversion to drive recordkeeping table updates, confirmation-statement scripts, and contract-holder notice scheduling. The supplement becomes the source-of-truth artifact reconciled against internal fund-mapping tables.

  • Regulatory pattern detection on affiliate substitutions. Cross-reference replaced and replacement portfolios against fund-complex affiliation data to flag insurer-affiliated swaps, then cluster filings by filer CIK and time window to surface coordinated lineup overhauls. The output supports sweep-exam scoping and comment-letter selection on Section 26(c) order compliance.

  • Benchmark corpus for substitution-event extraction models. Use the dataset's narrow, repeating structure (title block, effective-date callout, substitutions table, prior/on/after sections, boilerplate) as labeled training and evaluation data for LLM extraction of fund-pair substitution tuples and supplement summarization, with metadata.json series and contract identifiers serving as gold-standard linkage targets.

Dataset Access

Dataset Index JSON API: https://api.sec-api.io/datasets/form-497vpsub-files.json Returns dataset-level metadata (name, description, last updated timestamp, earliest sample date, total records and size, form types, container format, and file types) along with the full dataset download URL and a list of monthly container files. Each container entry includes its key, size, record count, updated timestamp, and individual download URL. This endpoint does not require an API key and can be polled to monitor which monthly containers were updated in the most recent refresh, allowing selective day-by-day downloads.

Example
1 {
2 "datasetId": "1f13365b-9ae0-69a6-a591-9580db10e6e8",
3 "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-497vpsub-files.zip",
4 "name": "Form 497VPSUB Files Dataset",
5 "updatedAt": "2026-04-15T12:06:40.308Z",
6 "earliestSampleDate": "2022-03-01",
7 "totalRecords": 847,
8 "totalSize": 4036930,
9 "formTypes": ["497VPSUB"],
10 "containerFormat": "ZIP",
11 "fileTypes": ["HTML", "JSON"],
12 "containers": [
13 {
14 "downloadUrl": "https://api.sec-api.io/datasets/form-497vpsub-files/2026/2026-04.zip",
15 "key": "2026/2026-04.zip",
16 "size": 132480,
17 "records": 12,
18 "updatedAt": "2026-04-15T12:06:40.308Z"
19 }
20 ]
21 }

Download Entire Dataset: https://api.sec-api.io/datasets/form-497vpsub-files.zip?token=YOUR_API_KEY Downloads the full archive containing every Form 497VPSUB filing from March 2022 to present in a single ZIP file. This endpoint requires an API key.

Download Single Container: https://api.sec-api.io/datasets/form-497vpsub-files/2026/2026-04.zip?token=YOUR_API_KEY Downloads one monthly container ZIP, keyed as YYYY/YYYY-MM.zip, instead of the full dataset. This endpoint requires an API key.

Frequently Asked Questions

What does one record in the Form 497VPSUB Files Dataset represent?

One record corresponds to a single EDGAR submission of form type 497VPSUB — one accession number filed by a variable annuity or variable life separate-account registrant under Rule 497. The record bundles the structured metadata.json header with the primary HTML supplement document (*497vpsub.htm); image attachments listed in the EDGAR filing index are intentionally excluded from the payload.

Who is required to file Form 497VPSUB?

The legal filer is a registered insurance company separate account that issues variable annuity contracts (registered on Form N-3 or N-4) or variable life insurance policies (registered on Form N-6), acting through its life insurance company depositor. Operating insurance holding companies, mutual fund complexes, ETFs, and ordinary Exchange Act registrants do not file 497VPSUB.

What triggers a 497VPSUB filing?

The trigger is event-driven, not periodic: a fund substitution under Section 26(c) of the Investment Company Act of 1940, where the depositor replaces shares of one underlying subaccount fund with shares of a different fund. The supplement is filed shortly before the substitution's effective date, after the SEC has issued the Section 26(c) order authorizing the swap.

What time period does the dataset cover?

The dataset covers every 497VPSUB filing from March 2022 — when the form type was introduced in EDGAR Release 22.1 — through the present. Earlier substitution supplements that predate the 497VPSUB tag were filed under generic 497-family tags (497, 497J, 497K) and are not included in this dataset.

What file format is the dataset distributed in?

The dataset is distributed as monthly ZIP containers keyed as YYYY/YYYY-MM.zip. Each accession-named folder inside a container holds two artifact types: a metadata.json describing the EDGAR filing header in structured form, and one or more HTML documents named with a 497vpsub.htm suffix that carry the prospectus supplement wrapped in EDGAR's SGML <DOCUMENT> envelope.

How does this dataset differ from the general Form 497 stream?

Plain Form 497 is the umbrella submission type for any definitive prospectus, sticker, or supplement filed under Rule 497, covering open-end funds, closed-end funds, ETFs, and variable separate accounts. 497VPSUB is a deliberate carve-out limited to substitution-related supplements for variable insurance products, isolating a small, legally distinct stream of contract-holder-facing substitution notices that would otherwise be buried inside the much larger general 497 corpus.

Why are there two different "effective dates" associated with one record?

The effectivenessDate field in metadata.json reflects the EDGAR header's declared effectiveness for the supplement filing itself and is typically the filing date. The substitution's operationally meaningful effective date — the day the underlying fund swap actually takes place for contract holders — is generally a future date stated in the body of the supplement (often phrased "on or about <Month Day, Year>") and must be parsed from the HTML when needed.