On its own, Voya ICAR represents a new way of illustrating ever-greater leverage and performance out of an Indexed UL product. But ICAR also has some profound and far-reaching implications for illustrating non-S&P 500 accounts in Indexed UL products - in Voya's case, the 2 and 5 Year Global accounts. The Global crediting strategy references 3 equity indices and credits interest based on 75% of the best performer and 25% of the 2nd best performer and without AG49 restrictions could easily illustrate at rates over 12%.