Life insurance 1035

Hoping you could answer a 1035 exchange question.
Clients have a joint 1st to die policy, both spouses are insured and husband is owner.
If they were to exchange this to a 2nd to die with both insured and same owner, would this qualify as a 1035 exchange. Since insureds are the same and owner would be the same it would seem to meet the qualifications but wanted your input.



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