¹ Statutory financial information of Pacific Life & Annuity Company was prepared in conformity with statutory accounting practices (SAP), which are accounting practices prescribed or permitted by the Insurance Department of the State of Arizona (AZ DOI).  The AZ DOI has adopted the National Association of Insurance Commissioners' Accounting Practices and Procedures Manual, subject to any deviations prescribed or permitted by the AZ DOI.  SAP is a comprehensive basis of accounting that differs in certain significant respects from accounting principles generally accepted in the United States of America (GAAP).