“…Second, when regulatory or economic circumstances change, relying on historical data may be deceptive. For instance, a rise in market interest rates in the 1970s resulted in the so-called disintermediation in the whole life market with drastically more surrenders and policy loans (Black and Skipper, 2000, p. 111); also, misjudgment of exercise of Guaranteed Annuity Options (GAOs) in the face of falling interest rates contributed to the demise of the UK-based life insurer Equitable Life in 2000 (Boyle and Hardy, 2003). Hence, it is necessary to have an understanding of what drives these empirical exercise rules-and, particularly, under which circumstances they may fail.…”