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LGilmore said:"The Annuity has a 100% guaranteed return of Premium rider, so there would be no surrender charges"
You might want to read that rider as it may apply to her death or after a surrender window. I could be wrong but I don't see any annuity company staying in business that offers full refunds at any time.
Read more: Qualified Money into a Life Insurance Policy??
He is right about the GAFRI Safe Return offering a return of premium. It is not all that unique as other carriers offer similiar riders.