Congratulations. I'm not sure that this would work in US jurisdictions due to rules regarding discretionary clauses. See here:
In addition to clearing that hurdle, I have some questions as it pertains to policyholders in the US and custody of funds issues. Specifically rule 206(4)-2. See here:
I have however solved both of these issues with my architecture. If you need help resolving these issues I'm more than happy to discuss.