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I do believe Dividends are impacted by the actual carrier mortality experience & expenses being currently incurred at the time, not just the worst case guaranteed mortality & expenses built into their guaranteed policy assumptions.
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A lot of the impact is from investment returns for the carrier, but some carriers are indeed having much higher expenses than originally priced into the policy design & in some rare cases worse mortality experience.
I believe you are correct for most carriers. Perhaps some use a "modified" method for calculating carrier M&E. Im not sure if any of the major carriers do that or not. Maybe someone around here knows of one that does or can share some more insight into this.
Thankfully for comparison purposes, all that really matters is the net result, which is the Dividend History.