485APOS

                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                    FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

Pre-Effective Amendment No. _____________                                    [ ]

Post-Effective Amendment No. 55 (File No. 333-79311)                         [X]

                                     and/or

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940

Amendment No. 56 (File No. 811-07355)                                        [X]

                        (Check appropriate box or boxes)

                         RIVERSOURCE VARIABLE ACCOUNT 10
                    (previously IDS LIFE VARIABLE ACCOUNT 10)
                           (Exact Name of Registrant)

                       RiverSource Life Insurance Company
                     (previously IDS Life Insurance Company)
                               (Name of Depositor)

            70100 Ameriprise Financial Center, Minneapolis, MN 55474
         (Address of Depositor's Principal Executive Offices) (Zip Code)

        Depositor's Telephone Number, including Area Code (612) 671-2237

   Rodney J. Vessels, 50605 Ameriprise Financial Center, Minneapolis, MN 55474
                     (Name and Address of Agent for Service)

It is proposed that this filing will become effective (check appropriate box)

[ ]  immediately upon filing pursuant to paragraph (b) of Rule 485

[ ]  on [date] pursuant to paragraph (b) of Rule 485

[X]  60 days after filing pursuant to paragraph (a)(1) of Rule 485

[ ]  on [date] pursuant to paragraph (a)(1) of Rule 485

If appropriate, check the following box:

[ ]  this post-effective amendment designates a new effective date for a
     previously filed post-effective amendment.


PROSPECTUS


APRIL 30, 2010


RIVERSOURCE

RETIREMENT ADVISOR 4 ADVANTAGE(R) VARIABLE ANNUITY
RETIREMENT ADVISOR 4 SELECT(R) VARIABLE ANNUITY
RETIREMENT ADVISOR 4 ACCESS(R) VARIABLE ANNUITY

INDIVIDUAL FLEXIBLE PREMIUM DEFERRED COMBINATION FIXED/VARIABLE ANNUITIES

ISSUED BY: RIVERSOURCE LIFE INSURANCE COMPANY (RIVERSOURCE LIFE)

          70100 Ameriprise Financial Center
          Minneapolis, MN 55474
          Telephone: (800) 862-7919
          ameriprise.com/variableannuities
          RIVERSOURCE VARIABLE ACCOUNT 10/RIVERSOURCE ACCOUNT MGA

This prospectus contains information that you should know before investing in
the RiverSource Retirement Advisor 4 Advantage Variable Annuity (RAVA 4
Advantage), the RiverSource Retirement Advisor 4 Select Variable Annuity (RAVA 4
Select), or the RiverSource Retirement Advisor 4 Access Variable Annuity (RAVA 4
Access). The information in this prospectus applies to all contracts unless
stated otherwise.

Prospectuses are also available for:

     -    AIM Variable Insurance Funds

     -    AllianceBernstein Variable Products Series Fund, Inc.

     -    American Century Variable Portfolios, Inc

     -    Columbia Funds Variable Insurance Trust

     -    Credit Suisse Trust

     -    Dreyfus Variable Investment Fund

     -    Eaton Vance Variable Trust

     -    Evergreen Variable Annuity Trust

     -    Fidelity(R) Variable Insurance Products - Service Class 2

     -    Franklin(R) Templeton(R) Variable Insurance Products Trust (FTVIPT) -
          Class 2

     -    Goldman Sachs Variable Insurance Trust (VIT)

     -    Janus Aspen Series: Service Shares

     -    Legg Mason Variable Portfolios I, Inc.

     -    MFS(R) Variable Insurance Trust(SM)

RIVERSOURCE RAVA 4 ADVANTAGE / RAVA 4 SELECT / RAVA 4 ACCESS VARIABLE ANNUITY --
PROSPECTUS



     -    Neuberger Berman Advisers Management Trust

     -    Oppenheimer Variable Account Funds - Service Shares

     -    PIMCO Variable Investment Trust (VIT)

     -    RiverSource Variable Series Trust (RVST)

     -    The Universal Institutional Funds, Inc. Van Kampen Life Investment
          Trust

     -    Wanger Advisors Trust

     -    Wells Fargo Variable Trust

Please read the prospectuses carefully and keep them for future reference.

The contracts provide for purchase payment credits which we may reverse under
certain circumstances. Expenses may be higher and surrender charges may be
higher and longer for contracts with purchase payment credits than for contracts
without such credits. The amount of the credit may be more than offset by
additional charges associated with the credit.

THE SECURITIES AND EXCHANGE COMMISSION (SEC) HAS NOT APPROVED OR DISAPPROVED
THESE SECURITIES OR PASSED UPON THE ACCURACY OR ADEQUACY OF THIS PROSPECTUS. ANY
REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE.

AN INVESTMENT IN THIS CONTRACT IS NOT A DEPOSIT OF A BANK OR FINANCIAL
INSTITUTION AND IS NOT INSURED OR GUARANTEED BY THE FEDERAL DEPOSIT INSURANCE
CORPORATION (FDIC) OR ANY OTHER GOVERNMENT AGENCY. AN INVESTMENT IN THIS
CONTRACT INVOLVES INVESTMENT RISK INCLUDING THE POSSIBLE LOSS OF PRINCIPAL.

A Statement of Additional Information (SAI), dated the same date as this
prospectus, is incorporated by reference into this prospectus. It is filed with
the SEC and is available without charge by contacting RiverSource Life at the
telephone number and address listed above. The table of contents of the SAI is
on the last page of this prospectus. The SEC maintains an Internet site. This
prospectus, the SAI and other information about the product are available on the
EDGAR Database on the SEC's Internet site at (http://www.sec.gov).

Variable annuities are insurance products that are complex investment vehicles.
Before you invest, be sure to ask your financial advisor about the contract
features, benefits, risks and fees, and whether the contract is appropriate for
you, based upon your financial situation and objectives.



The contracts and/or certain optional benefits described in this prospectus may
not be available in all jurisdictions. This prospectus constitutes an offering
or solicitation only in those jurisdictions where such offering or solicitation
may lawfully be made. State variations are covered in a special contract form
used in that state. This prospectus provides a general description of the
contracts. Your actual contract and any riders or endorsements are the
controlling documents.

RiverSource Life has not authorized any person to give any information or to
make any representations regarding the contracts other than those contained in
this prospectus or the fund prospectuses.

RiverSource Life offers several different annuities which your financial advisor
may or may not be authorized to offer to you. Each annuity has different
features and benefits that may be appropriate for you based on your financial
situation and needs, your age and how you intend to use the annuity. The
different features and benefits may include the investment and fund manager
options, variations in interest rate amount and guarantees, credits, surrender
charge schedules and access to your annuity account values. The fees and charges
you will pay when buying, owning and surrendering money from the contracts we
describe in this prospectus may be more or less than the fees and charges of
other variable annuities we and our affiliates issue. You should ask your
financial advisor about his or her ability to offer you other variable annuities
we issue (which might have lower fees and charges than the contracts described
in this prospectus).

TABLE OF CONTENTS

                                                                          
KEY TERMS.................................................................
THE CONTRACT IN BRIEF.....................................................
EXPENSE SUMMARY...........................................................
CONDENSED FINANCIAL INFORMATION...........................................
FINANCIAL STATEMENTS......................................................
THE VARIABLE ACCOUNT AND THE FUNDS........................................
GUARANTEE PERIOD ACCOUNTS (GPAS)..........................................
THE FIXED ACCOUNT.........................................................
BUYING YOUR CONTRACT......................................................
CHARGES...................................................................
VALUING YOUR INVESTMENT...................................................
MAKING THE MOST OF YOUR CONTRACT..........................................
SURRENDERS................................................................
TSA -- SPECIAL PROVISIONS.................................................
CHANGING OWNERSHIP........................................................
BENEFITS IN CASE OF DEATH -- STANDARD DEATH BENEFIT.......................
OPTIONAL BENEFITS.........................................................
THE ANNUITY PAYOUT PERIOD.................................................
TAXES.....................................................................
VOTING RIGHTS.............................................................
SUBSTITUTION OF INVESTMENTS...............................................
ABOUT THE SERVICE PROVIDERS...............................................
ADDITIONAL INFORMATION....................................................
APPENDIX A: THE FUNDS.....................................................
APPENDIX B: EXAMPLE -- MARKET VALUE ADJUSTMENT (MVA)......................
APPENDIX C: EXAMPLE -- SURRENDER CHARGES..................................
APPENDIX D: EXAMPLE -- OPTIONAL DEATH BENEFITS............................
APPENDIX E: EXAMPLE -- OPTIONAL LIVING BENEFITS...........................
APPENDIX F: ADDITIONAL RMD DISCLOSURE.....................................
APPENDIX G: GUARANTOR WITHDRAWAL BENEFIT FOR LIFE RIDER DISCLOSURE........
APPENDIX H: CONDENSED FINANCIAL INFORMATION (UNAUDITED)...................
TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION..............





KEY TERMS

These terms can help you understand details about your contract.

ACCUMULATION UNIT: A measure of the value of each subaccount before annuity
payouts begin.

ANNUITANT: The person on whose life or life expectancy the annuity payouts are
based.

ANNUITY PAYOUTS: An amount paid at regular intervals under one of several plans.

ASSUMED INVESTMENT RATE: The rate of return we assume your investments will earn
when we calculate your initial annuity payout amount using the annuity table in
your contract. The standard assumed investment rate we use is 5% but you may
request we substitute an assumed investment rate of 3.5%.

BAND 3 ANNUITIES: RAVA 4 Advantage and RAVA 4 Select contracts that are
available for:

-    current or retired employees of Ameriprise Financial, Inc. or its
     subsidiaries and their spouses or domestic partners (employees),

-    current or retired Ameriprise financial advisors and their spouses or
     domestic partners (advisors), or

-    individuals investing an initial purchase payment of $1 million or more,
     with our approval (other individuals).

BENEFICIARY: The person you designate to receive benefits in case of your death
while the contract is in force.

CLOSE OF BUSINESS: The time the New York Stock Exchange (NYSE) closes (4 p.m.
Eastern time unless the NYSE closes earlier).

CODE: The Internal Revenue Code of 1986, as amended.

CONTRACT: A deferred annuity contract that permits you to accumulate money for
retirement by making one or more purchase payments. It provides for lifetime or
other forms of payouts beginning at a specified time in the future.

CONTRACT VALUE: The total value of your contract before we deduct any applicable
charges.

CONTRACT YEAR: A period of 12 months, starting on the effective date of your
contract and on each anniversary of the effective date.

ENHANCED EARNINGS DEATH BENEFIT (EEB) AND ENHANCED EARNINGS PLUS DEATH BENEFIT
(EEP): These are optional benefits you can add to your contract for an
additional charge. Each is intended to provide an additional benefit to your
beneficiary to help offset expenses after your death such as funeral expenses or
federal and state taxes. You can elect to purchase either the EEB or the EEP,
subject to certain restrictions.

FIXED ACCOUNT: Our general account which includes the Regular Fixed account and
the Special DCA fixed account. Amounts you allocate to this account earn
interest at rates that we declare periodically.

FUNDS: Investment options under your contract. Unless an asset allocation
program is in effect, you may allocate your purchase payments into subaccounts
investing in shares of any or all of these funds.

GOOD ORDER: We cannot process your transaction request relating to the contract
until we have received the request in good order at our corporate office. "Good
order" means the actual receipt of the requested transaction in writing, along
with all information and supporting legal documentation necessary to effect the
transaction. This information and documentation generally includes your
completed request; the contract number; the transaction amount (in dollars); the
names of and allocations to and/or from the subaccounts and the fixed account
affected by the requested transaction; the signatures of all contract owners,
exactly as registered on the contract, if necessary; Social Security Number or
Taxpayer Identification Number; and any other information or supporting
documentation that we may require. With respect to purchase requests, "good
order" also generally includes receipt of sufficient payment by us to effect the
purchase. We may, in our sole discretion, determine whether any particular
transaction request is in good order, and we reserve the right to change or
waive any good order requirements at any time.



GUARANTEE PERIOD: The number of successive 12-month periods that a guaranteed
interest rate is credited.

GUARANTEE PERIOD ACCOUNTS (GPAS): A nonunitized separate account to which you
may allocate purchase payments and purchase payment credits or transfer contract
value of at least $1,000. These accounts have guaranteed interest rates for
guarantee periods we declare when you allocate purchase payments and purchase
payment credits or transfer contract value to a GPA. These guaranteed rates and
periods of time may vary by state. Unless an exception applies, transfers or
surrenders from a GPA done more than 30 days before the end of the guarantee
period will receive a Market Value Adjustment, which may result in a gain or
loss of principal.


GUARANTEED MINIMUM ACCUMULATION BENEFIT RIDER (ACCUMULATION BENEFIT): This is an
optional benefit that you can add to your contract for an additional charge. It
is intended to provide you with a guaranteed contract value at the end of a
specified waiting period regardless of the volatility inherent in the
investments in the subaccounts. This rider requires participation in the
Portfolio Navigator Program. This rider is not available for RAVA 4 Access.



GUARANTOR WITHDRAWAL BENEFIT FOR LIFE(R) RIDER (GWB FOR LIFE(R)): This is an
optional benefit you can add to your contract for an additional charge. It is
intended to provide a guaranteed withdrawal up to a certain amount each year
from the contract, regardless of the investment performance of your contract
before the annuity payments begin, until you have recovered at a minimum, all of
your purchase payments plus any purchase payment credits. Under certain limited
circumstances, it gives you the right to take limited withdrawals in each
contract year until death. This rider requires participation in the Portfolio
Navigator Program. This rider is not available for RAVA 4 Access. This rider is
no longer available for sale.


MARKET VALUE ADJUSTMENT (MVA): A positive or negative adjustment assessed if any
portion of a Guarantee Period Account is surrendered or transferred more than 30
days before the end of its guarantee period.

MAXIMUM ANNIVERSARY VALUE DEATH BENEFIT (MAV) AND MAXIMUM FIVE-YEAR ANNIVERSARY
VALUE DEATH BENEFIT (5-YEAR MAV): These are optional benefits you can add to
your contract for an additional charge. Each is intended to provide additional
death benefit protection in the event of fluctuating fund values. You can elect
to purchase either the MAV or the 5-Year MAV, subject to certain restrictions.

OWNER (YOU, YOUR): A person or persons who control the contract (decides on
investment allocations, transfers, payout options, etc.). Usually, but not
always, the owner is also the annuitant. The owner is responsible for taxes,
regardless of whether he or she receives the contract's benefits. If the
contract has a nonnatural person as the owner, "you, your, and owner" means the
annuitant where contract provisions are based on the age or life of the owner.


PORTFOLIO NAVIGATOR PROGRAM (PN PROGRAM): This is a program in which you are
required to participate through the choice of a PN program model asset
allocation portfolio or investment option if you select the optional
Accumulation Benefit rider, the optional GWB for Life rider or the optional
SecureSource rider. If you do not select the Accumulation Benefit rider, the GWB
for Life rider or the optional SecureSource rider, you may elect to participate
in the PN program at no additional charge. If you purchase your contract on or
after May 10, 2010, only the PN program investment options (and not the model
portfolios described in this prospectus) will be available to you.


PURCHASE PAYMENT CREDITS: An addition we make to your contract value. We base
the amount of the credit on the surrender charge schedule you elect and/or total
purchase payments. Purchase payment credits are not available under RAVA 4
Access contracts.

QUALIFIED ANNUITY: A contract that you purchase to fund one of the following
tax-deferred retirement plans that is subject to applicable federal law and any
rules of the plan itself:

-    Individual Retirement Annuities (IRAs) under Section 408(b) of the Code

-    Roth IRAs under Section 408A of the Code

-    SIMPLE IRAs under Section 408(p) of the Code

-    Simplified Employee Pension IRA (SEP) plans under Section 408(k) of the
     Code

-    Custodial and investment only accounts maintained for qualified retirement
     plans under Section 401(a) of the Code



-    Tax-Sheltered Annuities (TSAs) under Section 403(b) of the Code

A qualified annuity will not provide any necessary or additional tax deferral if
it is used to fund a retirement plan that is already tax-deferred.

All other contracts are considered NONQUALIFIED ANNUITIES.

RETURN OF PURCHASE PAYMENTS DEATH BENEFIT (ROPP): This is an optional benefit
that you can add to your contract for an additional charge if you are age 76 or
older at contract issue that is intended to provide additional death benefit
protection in the event of fluctuating fund values. ROPP is included in the
standard death benefit for contract owners age 75 and under on the contract
effective date at no additional cost.

RIDER: You receive a rider to your contract when you purchase the EEB, EEP, MAV,
5-Year MAV, ROPP, Accumulation Benefit, GWB for Life and/or SecureSource rider.
The rider adds the terms of the optional benefit to your contract.

RIDER EFFECTIVE DATE: The date a rider becomes effective as stated in the rider.

RIVERSOURCE LIFE: In this prospectus, "we," "us," "our" and "RiverSource Life"
refer to RiverSource Life Insurance Company.


SECURESOURCE(R) RIDERS: This is an optional benefit that you can add to your
contract for an additional charge. SecureSource -- Single Life covers one
person. SecureSource -- Joint Life covers two spouses jointly. The benefit is
intended to provide guaranteed withdrawals up to a certain amount each year from
the contract, regardless of the investment performance of your contract before
the annuity payments begin until you have recovered, at a minimum, all of your
purchase payments plus any purchase payment credits. Under certain limited
circumstances, it gives you the right to take limited withdrawals in each
contract year until death. These riders require participation in the Portfolio
Navigator program. These riders are not available for RAVA 4 Access.


SETTLEMENT DATE: The date when annuity payouts are scheduled to begin.

SPECIAL DOLLAR-COST AVERAGING (SPECIAL DCA) FIXED ACCOUNT: An account to which
you may allocate new purchase payments of at least $10,000. Amounts you allocate
to this account earn interest at rates that we declare periodically and will
transfer into your specified subaccount allocations in six monthly transfers.

SURRENDER VALUE: The amount you are entitled to receive if you make a full
surrender from your contract. It is the contract value minus any applicable
charges.

VALUATION DATE: Any normal business day, Monday through Friday, on which the
NYSE is open, up to the close of business. At the close of business, the next
valuation date begins. We calculate the accumulation unit value of each
subaccount on each valuation date. If we receive your purchase payment or any
transaction request (such as a transfer or surrender request) in good order at
our corporate office before the close of business, we will process your payment
or transaction using the accumulation unit value we calculate on the valuation
date we received your payment or transaction request. On the other hand, if we
receive your purchase payment or transaction request in good order at our
corporate office at or after the close of business, we will process your payment
or transaction using the accumulation unit value we calculate on the next
valuation date. If you make a transaction request by telephone (including by
fax), you must have completed your transaction by the close of business in order
for us to process it using the accumulation unit value we calculate on that
valuation date. If you were not able to complete your transaction before the
close of business for any reason, including telephone service interruptions or
delays due to high call volume, we will process your transaction using the
accumulation unit value we calculate on the next valuation date.

VARIABLE ACCOUNT: Separate subaccounts to which you may allocate purchase
payments; each invests in shares of one fund. The value of your investment in
each subaccount changes with the performance of the particular fund.



THE CONTRACT IN BRIEF

This prospectus describes three contracts. Each contract has different expenses.
RAVA 4 Access does not have surrender charges, but it has the highest mortality
and expense risk fees of the three contracts. RAVA 4 Select has a three-year
surrender charge schedule and has lower mortality and expense risk fees than
RAVA 4 Access. RAVA 4 Advantage offers a choice of a seven-year or a ten-year
surrender charge schedule, and has the lowest mortality and expense risk fees of
the three contracts. RAVA 4 Advantage and RAVA 4 Select include the option to
purchase living benefit riders; living benefit riders are not currently
available under RAVA 4 Access. Your financial advisor can help you determine
which contract is best suited to your needs based on factors such as your
investment goals and how long you intend to keep your contract. The information
in this prospectus applies to all contracts unless stated otherwise.

PURPOSE: The purpose of each contract is to allow you to accumulate money for
retirement or a similar long-term goal. You do this by making one or more
purchase payments. You may allocate your purchase payments to the GPAs, regular
fixed account, subaccounts and/or Special DCA fixed account under the contract;
however, you risk losing amounts you invest in the subaccounts of the variable
account. These accounts, in turn, may earn returns that increase the value of
the contract. You may be able to purchase an optional benefit to reduce the
investment risk you assume under your contract. Beginning at a specified time in
the future called the settlement date, the contract provides lifetime or other
forms of payouts of your contract value (less any applicable premium tax).

BUYING A CONTRACT: There are many factors to consider carefully before you buy a
variable annuity and any optional benefit rider. Variable annuities -- with or
without optional benefit riders -- are not right for everyone. MAKE SURE YOU
HAVE ALL THE FACTS YOU NEED BEFORE YOU PURCHASE A VARIABLE ANNUITY OR CHOOSE AN
OPTIONAL BENEFIT RIDER. Some of the factors you may wish to consider include:

-    "Tax Free" Exchanges: It may not be advantageous for you to purchase this
     contract in exchange for, or in addition to, an existing annuity or life
     insurance policy. Generally, you can exchange one annuity for another in a
     "tax-free" exchange under Section 1035 of the Code. You can also do a
     partial exchange from one annuity contract to another annuity contract,
     subject to IRS rules. You also generally can exchange a life insurance
     policy for an annuity. However, before making an exchange, you should
     compare both contracts carefully because the features and benefits may be
     different. Fees and charges may be higher or lower on your old contract
     than on this contract. You may have to pay a surrender charge when you
     exchange out of your old contract and a new surrender charge period will
     begin when you exchange into this contract. If the exchange does not
     qualify for Section 1035 treatment, you also may have to pay federal income
     tax on the distribution. You should not exchange your old contract for this
     contract, or buy this contract in addition to your old contract, unless you
     determine it is in your best interest. (See "Taxes -- 1035 Exchanges.")

-    Tax-deferred retirement plans: Most annuities have a tax-deferred feature.
     So do many retirement plans under the Code. As a result, when you use a
     qualified annuity to fund a retirement plan that is tax-deferred, your
     contract will not provide any necessary or additional tax deferral for that
     retirement plan. A qualified annuity has features other than tax deferral
     that may help you reach your retirement goals. In addition, the Code
     subjects retirement plans to required withdrawals triggered at a certain
     age. These mandatory withdrawals are called required minimum distributions
     ("RMDs"). RMDs may reduce the value of certain death benefits and optional
     riders (see "Taxes -- Qualified Annuities -- Required Minimum
     Distributions"). You should consult your tax advisor before you purchase
     the contract as a qualified annuity for an explanation of the tax
     implications to you.

-    Taxes: Generally, income earned on your contract value grows tax-deferred
     until you make withdrawals or begin to receive payouts. (Under certain
     circumstances, IRS penalty taxes may apply.) The tax treatment of qualified
     and nonqualified annuities differs. Even if you direct payouts to someone
     else, you will be taxed on the income if you are the owner. (see "Taxes")

-    Your age: If you are an older person, you may not necessarily have a need
     for tax deferral, retirement income or a death benefit. Older persons who
     are considering buying a contract including any optional benefits may find
     it helpful to consult with or include a family member, friend or other
     trusted advisor in the decision making process before buying a contract.

-    How long you plan to keep your contract: variable annuities are not
     short-term liquid investments. RAVA 4 Advantage and RAVA 4 Select contracts
     have surrender charges. RAVA 4 Access contract does not have a surrender
     charge schedule, but it has a higher mortality and expense risk fee than
     RAVA 4 Advantage and RAVA 4 Select. All contracts offer an annuity payout
     plan called Annuity Payout Plan E, which imposes a surrender charge only if
     you elect to surrender remaining variable payouts available under Annuity
     Payout Plan E. (see "Annuity Payout Plans -- Plan E") Does the contract
     meet your current and anticipated future needs for liquidity?

-    If you can afford the contract: are your annual income and assets adequate
     to buy the contract and any optional benefit riders you may choose?

-    The fees and expenses you will pay when buying, owning and withdrawing
     money from this contract. (see "Charges")



-    How and when you plan to take money from the contract: under current tax
     law, withdrawals, including withdrawals made under optional benefit riders,
     are taxed differently than annuity payouts. In addition, certain
     withdrawals may be subject to a federal income tax penalty. (see
     "Surrenders")

-    Your investment objectives, how much experience you have in managing
     investments and how much risk you are you willing to accept.

-    Short-term trading: if you plan to manage your investment in the contract
     by frequent or short-term trading, this contract is not suitable for you
     and you should not buy it. (see "Making the Most of Your Contract --
     Transferring Among Accounts")

FREE LOOK PERIOD: You may return your contract to your financial advisor or to
our corporate office within the time stated on the first page of your contract
and receive a full refund of the contract value less the amounts of any purchase
payment credits, subject to market value adjustment. We will not deduct any
contract charges or fees. However, you bear the investment risk from the time of
purchase until you return the contract; the refund amount may be more or less
than the payment you made. (EXCEPTION: If the law requires, we will refund all
of your purchase payments.)

ACCOUNTS: Generally, you may allocate your purchase payments among the:

-    the subaccounts of the variable account, each of which invests in a fund
     with a particular investment objective. The value of each subaccount varies
     with the performance of the particular fund in which it invests. We cannot
     guarantee that the value at the settlement date will equal or exceed the
     total purchase payments you allocate to the subaccounts. (see "The Variable
     Account and the Funds")

-    the GPAs which earn interest at rates declared when you make an allocation
     to that account. The required minimum investment in each GPA is $1,000.
     These accounts may not be available in all states. (see "Guarantee Period
     Accounts (GPAs)")


-    the regular fixed account, which earns interest at rates that we adjust
     periodically. Purchase payment allocations to the regular fixed account may
     be subject to special restrictions. For RAVA 4 Access contracts, you cannot
     select the regular fixed account unless it is included in the PN program
     model portfolio you selected. (see "The Fixed Account")


-    the Special DCA fixed account, when available. (see "The Fixed Account --
     The Special DCA Fixed Account")

TRANSFERS: Subject to certain restrictions, you currently may redistribute your
contract value among the subaccounts until annuity payouts begin, and once per
contract year after annuity payouts begin. Transfers out of the GPAs done more
than 30 days before the end of the Guarantee Period will be subject to an MVA,
unless an exception applies. You may establish automated transfers among the
accounts. You may not transfer existing amounts to the Special DCA fixed
account. GPAs and regular fixed account transfers are subject to special
restrictions. (see "Making the Most of Your Contract -- Transferring Among
Accounts")

SURRENDERS: You may surrender all or part of your contract value at any time
before the settlement date. You also may establish automated partial surrenders.
Surrenders may be subject to charges and income taxes (including an IRS penalty
if you surrender prior to your reaching age 59 1/2) and may have other tax
consequences; also, certain restrictions apply. (see "Surrenders")

BENEFITS IN CASE OF DEATH: If you die before annuity payouts begin, we will pay
the beneficiary an amount at least equal to the contract value, except in the
case of a purchase payment credit reversal. (see "Benefits in Case of Death --
Standard Death Benefit")


OPTIONAL BENEFITS: These contracts offer optional features that are available
for additional charges if you meet certain criteria. Optional benefits may
require the use of a PN program model portfolio or investment option which may
limit transfers and allocations; may limit the timing, amount and allocation of
purchase payments; and may limit the amount of partial surrenders that can be
taken under the optional benefit during a contract year. (see "Optional
Benefits")


ANNUITY PAYOUTS: You can apply your contract value to an annuity payout plan
that begins on the settlement date. You may choose from a variety of plans to
make sure that payouts continue as long as you like. If you purchased a
qualified annuity, the payout schedule must meet IRS requirements. We can make
payouts on a fixed or variable basis, or both. Total monthly payouts may include
amounts from each subaccount and the regular fixed account. During the annuity
payout period, you cannot be invested in more than five subaccounts at any one
time unless we agree otherwise. (see "The Annuity Payout Period")



EXPENSE SUMMARY

THE FOLLOWING TABLES DESCRIBE THE FEES AND EXPENSES THAT YOU WILL PAY WHEN
BUYING, OWNING AND SURRENDERING THE CONTRACT. THE FIRST TABLE DESCRIBES THE FEES
AND EXPENSES THAT YOU WILL PAY AT THE TIME THAT YOU BUY THE CONTRACT OR
SURRENDER THE CONTRACT. STATE PREMIUM TAXES ALSO MAY BE DEDUCTED.

CONTRACT OWNER TRANSACTION EXPENSES

SURRENDER CHARGE FOR RAVA 4 ADVANTAGE:

(Contingent deferred sales load as a percentage of purchase payment surrendered)

You select either a seven-year or ten-year surrender charge schedule at the time
of application.*



            SEVEN-YEAR SCHEDULE                          TEN-YEAR SCHEDULE*
------------------------------------------   ------------------------------------------
  NUMBER OF COMPLETED                          NUMBER OF COMPLETED
YEARS FROM DATE OF EACH   SURRENDER CHARGE   YEARS FROM DATE OF EACH   SURRENDER CHARGE
   PURCHASE PAYMENT          PERCENTAGE         PURCHASE PAYMENT          PERCENTAGE
-----------------------   ----------------   -----------------------   ----------------
                                                              
           0                      7%                     0                     8%
           1                      7                      1                     8
           2                      7                      2                     8
           3                      6                      3                     7
           4                      5                      4                     7
           5                      4                      5                     6
           6                      2                      6                     5
           7+                     0                      7                     4
                                                         8                     3
                                                         9                     2
                                                        10+                    0


*    In certain states the ten-year surrender charge schedule is 8% for years
     0-2, 7% for year 3 and declining by 1% each year thereafter until it is 0%
     for years 10+. For contracts issued in Alabama and Massachusetts, surrender
     charges are waived after the tenth contract anniversary.

SURRENDER CHARGE FOR RAVA 4 SELECT (EXCEPT TEXAS):

(Contingent deferred sales load as a percentage of purchase payment surrendered)



  YEARS FROM    SURRENDER CHARGE
CONTRACT DATE      PERCENTAGE
-------------   ----------------
             
      1                 7%
      2                 7
      3                 7
  Thereafter            0


SURRENDER CHARGE FOR RAVA 4 SELECT IN TEXAS:

(Contingent deferred sales load as a percentage of purchase payment surrendered)



  NUMBER OF COMPLETED
YEARS FROM DATE OF EACH   SURRENDER CHARGE
    PURCHASE PAYMENT         PERCENTAGE
-----------------------   ----------------
                       
           0                      8%
           1                      7
           2                      6
       Thereafter                 0




There are no surrender charges after the third contract anniversary.

SURRENDER CHARGE FOR RAVA 4 ACCESS: 0%

SURRENDER CHARGE UNDER ANNUITY PAYOUT PLAN E -- PAYOUTS FOR A SPECIFIED PERIOD:
Under this annuity payout plan, you can choose to take surrender. The amount
that you can surrender is the present value of any remaining variable payouts.
The discount rate we use in the calculation will be 5.17% if the assumed
investment rate is 3.5% and 6.67% if the assumed investment rate is 5%. The
surrender charge equals the present value of the remaining payouts using the
assumed investment rate minus the present value of the remaining payouts using
the discount rate. (See "Charges -- Surrender Charge" and "The Annuity Payout
Period -- Annuity Payout Plans.")

THE NEXT TABLES DESCRIBE THE FEES AND EXPENSES THAT YOU WILL PAY PERIODICALLY
DURING THE TIME THAT YOU OWN THE CONTRACT, NOT INCLUDING FUND FEES AND EXPENSES.

ANNUAL CONTRACT ADMINISTRATIVE CHARGE

Maximum: $50*
Current: $30

(We will waive this $30 charge when your contract value, or total purchase
payments less any payments surrendered, is $50,000 or more on the current
contract anniversary, except at full surrender.)

*    In certain states and for certain contracts we have waived our right to
     increase the contract administrative charge.

ANNUAL VARIABLE ACCOUNT EXPENSES

(Total annual variable account expenses as a percentage of average daily
subaccount value)



                                  RAVA 4 ADVANTAGE   RAVA 4 SELECT   RAVA 4 ACCESS
                                  ----------------   -------------   -------------
                                                            
MORTALITY AND EXPENSE RISK FEE:
   FOR NONQUALIFIED ANNUITIES           1.05%             1.30%           1.45%
   FOR QUALIFIED ANNUITIES               .85%             1.10%           1.25%


OPTIONAL RIDER FEES

OPTIONAL DEATH BENEFITS

(As a percentage of contract value charged annually at the contract anniversary.
The fee applies only if you elect the optional rider.)

                                  
ROPP RIDER FEE         MAXIMUM: 0.30%   CURRENT: 0.20%
MAV RIDER FEE          MAXIMUM: 0.35%   CURRENT: 0.25%
5-YEAR MAV RIDER FEE   MAXIMUM: 0.20%   CURRENT: 0.10%
EEB RIDER FEE          MAXIMUM: 0.40%   CURRENT: 0.30%
EEP RIDER FEE          MAXIMUM: 0.50%   CURRENT: 0.40%



OPTIONAL LIVING BENEFITS

                                            
ACCUMULATION BENEFIT RIDER FEE   MAXIMUM: 2.50%   CURRENT: 0.80%(1)



(1)  For contracts purchased prior to Jan. 26, 2009, the current charge is
     0.60%.

(Charged annually as a percentage of contract value or the minimum contract
accumulation value, whichever is greater. The fee applies only if you elect the
optional rider.)

                                    
GWB FOR LIFE RIDER FEE   MAXIMUM: 1.50%   CURRENT: 0.65%





(Charged annually at the contract anniversary as a percentage of contract value
or the total Remaining Benefit Amount, whichever is greater. The fee applies
only if you elect the optional rider.)

                                                     
SECURESOURCE - SINGLE LIFE RIDER FEE(2)   MAXIMUM: 2.00%   CURRENT: 0.90%
SECURESOURCE - JOINT LIFE RIDER FEE(2)    MAXIMUM: 2.50%   CURRENT: 1.15%



(Charged annually at the contract anniversary as a percentage of contract value
or the total Remaining Benefit Amount, whichever is greater. The fee applies
only if you elect the optional rider.)

(2)  For contracts purchased prior to Jan. 26, 2009, the following charges
     apply:

     -    the current charge for Single Life rider is 0.65% and for Joint Life
          rider is 0.85%, and

     -    the maximum charge for Single Life rider is 1.50% and for Joint Life
          rider is 1.75%.



ANNUAL OPERATING EXPENSES OF THE FUNDS


THE NEXT TWO TABLES DESCRIBE THE OPERATING EXPENSES OF THE FUNDS THAT YOU MAY
PAY PERIODICALLY DURING THE TIME THAT YOU OWN THE CONTRACT. THESE OPERATING
EXPENSES ARE FOR THE FISCAL YEAR ENDED DEC. 31, 2009, UNLESS OTHERWISE NOTED.
THE FIRST TABLE SHOWS THE MINIMUM AND MAXIMUM TOTAL OPERATING EXPENSES CHARGED
BY THE FUNDS. THE SECOND TABLE SHOWS THE FEES AND EXPENSES CHARGED BY EACH FUND.
MORE DETAIL CONCERNING EACH FUND'S FEES AND EXPENSES IS CONTAINED IN THE
PROSPECTUS.


MINIMUM AND MAXIMUM TOTAL ANNUAL OPERATING EXPENSES FOR THE FUNDS(A)

(Including management fee, distribution and/or service (12b-1) fees and other
expenses)




                                                                  MINIMUM   MAXIMUM
                                                                  -------   -------
                                                                      
Total expenses before fee waivers and/or expense reimbursements      __%       __%



(a)  Each fund deducts management fees and other expenses from fund assets. Fund
     assets include amounts you allocate to a particular fund. Funds may also
     charge 12b-1 fees that are used to finance any activity that is primarily
     intended to result in the sale of fund shares. Because 12b-1 fees are paid
     out of fund assets on an on-going basis, you may pay more if you select
     subaccounts investing in funds that have adopted 12b-1 plans than if you
     select subaccounts investing in funds that have not adopted 12b-1 plans.
     The fund or the fund's affiliates may pay us or our affiliates for
     promoting and supporting the offer, sale and servicing of fund shares. In
     addition, the fund's distributor and/or investment adviser, transfer agent
     or their affiliates may pay us or our affiliates for various services we or
     our affiliates provide. The amount of these payments will vary by fund and
     may be significant. See "The Variable Accounts and the Funds" for
     additional information, including potential conflicts of interest these
     payments may create. For a more complete description of each fund's fees
     and expenses and important disclosure regarding payments the fund and/or
     its affiliates make, please review the fund's prospectus and SAI.

TOTAL ANNUAL OPERATING EXPENSES FOR EACH FUND UNDERLYING RAVA 4 ADVANTAGE, RAVA
4 SELECT AND RAVA 4 ACCESS*

(Before fee waivers and/or expense reimbursements, if applicable, as a
percentage of average daily net assets)










[to be filed by amendment]


EXAMPLES

THESE EXAMPLES ARE INTENDED TO HELP YOU COMPARE THE COST OF INVESTING IN THESE
CONTRACTS WITH THE COST OF INVESTING IN OTHER VARIABLE ANNUITY CONTRACTS. THESE
COSTS INCLUDE YOUR TRANSACTION EXPENSES, CONTRACT ADMINISTRATIVE CHARGES(1),
VARIABLE ACCOUNT ANNUAL EXPENSES AND FUND FEES AND EXPENSES.

THESE EXAMPLES ASSUME THAT YOU INVEST $10,000 IN THE CONTRACT FOR THE TIME
PERIODS INDICATED. THESE EXAMPLES ALSO ASSUME THAT YOUR INVESTMENT HAS A 5%
RETURN EACH YEAR.

MAXIMUM EXPENSES. These examples assume the most expensive combination of
contract features and benefits and the maximum fees and expenses of any of the
funds. They assume that you select the optional MAV, EEP and Accumulation
Benefit or SecureSource - Joint Life(2), if available. Although your actual
costs may be higher or lower, based on these assumptions your costs would be:




                                                                                     IF YOU DO NOT SURRENDER YOUR
                                                                                      CONTRACT OR IF YOU SELECT
                                        IF YOU SURRENDER YOUR CONTRACT AT THE       AN ANNUITY PAYOUT PLAN AT THE
                                          END OF THE APPLICABLE TIME PERIOD:      END OF THE APPLICABLE TIME PERIOD:
                                        -------------------------------------   -------------------------------------
                                        1 YEAR   3 YEARS   5 YEARS   10 YEARS   1 YEAR   3 YEARS   5 YEARS   10 YEARS
                                        ------   -------   -------   --------   ------   -------   -------   --------
                                                                                     
NONQUALIFIED ANNUITY
   RAVA 4 ADVANTAGE
   With a ten-year surrender charge
      schedule(3)
   RAVA 4 ADVANTAGE
   With a seven-year surrender charge
      schedule
   RAVA 4 SELECT
   RAVA 4 SELECT - TEXAS
   RAVA 4 ACCESS








                                                                                     IF YOU DO NOT SURRENDER YOUR
                                                                                      CONTRACT OR IF YOU SELECT
                                        IF YOU SURRENDER YOUR CONTRACT AT THE       AN ANNUITY PAYOUT PLAN AT THE
                                          END OF THE APPLICABLE TIME PERIOD:      END OF THE APPLICABLE TIME PERIOD:
                                        -------------------------------------   -------------------------------------
                                        1 YEAR   3 YEARS   5 YEARS   10 YEARS   1 YEAR   3 YEARS   5 YEARS   10 YEARS
                                        ------   -------   -------   --------   ------   -------   -------   --------
                                                                                     
QUALIFIED ANNUITY
   RAVA 4 ADVANTAGE
   With a ten-year surrender charge
      schedule(3)
   RAVA 4 ADVANTAGE
   With a seven-year surrender charge
      schedule
   RAVA 4 SELECT
   RAVA 4 SELECT - TEXAS
   RAVA 4 ACCESS



MINIMUM EXPENSES. These examples assume the least expensive combination of
contract features and benefits and the minimum fees and expenses of any of the
funds. They assume that you do not select any optional benefits. Although your
actual costs may be higher or lower, based on these assumptions your costs would
be:




                                                                                     IF YOU DO NOT SURRENDER YOUR
                                                                                      CONTRACT OR IF YOU SELECT
                                        IF YOU SURRENDER YOUR CONTRACT AT THE       AN ANNUITY PAYOUT PLAN AT THE
                                          END OF THE APPLICABLE TIME PERIOD:      END OF THE APPLICABLE TIME PERIOD:
                                        -------------------------------------   -------------------------------------
                                        1 YEAR   3 YEARS   5 YEARS   10 YEARS   1 YEAR   3 YEARS   5 YEARS   10 YEARS
                                        ------   -------   -------   --------   ------   -------   -------   --------
                                                                                     
NONQUALIFIED ANNUITY
   RAVA 4 ADVANTAGE
   With a ten-year surrender charge
      schedule(3)
   RAVA 4 ADVANTAGE
   With a seven-year surrender charge
      schedule
   RAVA 4 SELECT
   RAVA 4 SELECT - TEXAS
   RAVA 4 ACCESS






                                                                                     IF YOU DO NOT SURRENDER YOUR
                                                                                      CONTRACT OR IF YOU SELECT
                                        IF YOU SURRENDER YOUR CONTRACT AT THE       AN ANNUITY PAYOUT PLAN AT THE
                                          END OF THE APPLICABLE TIME PERIOD:      END OF THE APPLICABLE TIME PERIOD:
                                        -------------------------------------   -------------------------------------
                                        1 YEAR   3 YEARS   5 YEARS   10 YEARS   1 YEAR   3 YEARS   5 YEARS   10 YEARS
                                        ------   -------   -------   --------   ------   -------   -------   --------
                                                                                     
QUALIFIED ANNUITY
   RAVA 4 ADVANTAGE
   With a ten-year surrender charge
      schedule(3)
   RAVA 4 ADVANTAGE
   With a seven-year surrender charge
      schedule
   RAVA 4 SELECT
   RAVA 4 SELECT - TEXAS
   RAVA 4 ACCESS




(1)  In these examples, the contract administrative charge is approximated as a
     % charge for RAVA 4 Advantage, a % charge for RAVA 4 Select, a % for RAVA 4
     Select - Texas, and % for RAVA 4 Access. These percentages were determined
     by dividing the total amount of the contract administrative charges
     collected during the year that are attributable to each contract by the
     total average net assets that are attributable to that contract.


(2)  Because these examples are intended to illustrate the most expensive
     combination of contract features, the maximum annual fee for each optional
     rider is reflected rather than the fee that is currently being charged.

(3)  In certain states, your expenses would be slightly lower due to the
     modified ten-year surrender charge schedule.



CONDENSED FINANCIAL INFORMATION

You can find unaudited condensed financial information for the subaccounts in
Appendix H.

We do not include any condensed financial information for subaccounts that are
new and did not have any activity as of the financial statement date.

FINANCIAL STATEMENTS

You can find our audited financial statements and the audited financial
statements of the subaccounts with history in the SAI. The SAI does not include
audited financial statements for subaccounts that are new and have no activity
as of the financial statement date.

THE VARIABLE ACCOUNT AND THE FUNDS

THE VARIABLE ACCOUNT: The variable account was established under Minnesota law
on Aug. 23, 1995, and the subaccounts are registered together as a single unit
investment trust under the Investment Company Act of 1940 (the 1940 Act). This
registration does not involve any supervision of our management or investment
practices and policies by the SEC. All obligations arising under the contracts
are general obligations of RiverSource Life.

The variable account meets the definition of a separate account under federal
securities laws. We credit or charge income, capital gains and capital losses of
each subaccount only to that subaccount. State insurance law prohibits us from
charging a subaccount with liabilities of any other subaccount or of our general
business. The variable account includes other subaccounts that are available
under contracts that are not described in this prospectus.

Although the Internal Revenue Service (IRS) has issued some guidance on investor
control, the U.S. Treasury and the IRS may continue to examine this aspect of
variable contracts and provide additional guidance on investor control. Their
concern involves how many investment choices (subaccounts) may be offered by an
insurance company and how many exchanges among those subaccounts may be allowed
before the contract owner would be currently taxed on income earned within the
contract. At this time, we do not know what the additional guidance will be or
when action will be taken. We reserve the right to modify the contract, as
necessary, so that the owner will not be subject to current taxation as the
owner of the subaccount assets.

We intend to comply with all federal tax laws so that the contract continues to
qualify as an annuity for federal income tax purposes. We reserve the right to
modify the contract as necessary to comply with any new tax laws.

THE FUNDS: The contracts currently offer subaccounts investing in shares of the
funds. For a list of underlying funds with a summary of investment objectives,
investment advisers and subadvisers, please see Appendix A.

-    INVESTMENT OBJECTIVES: The investment managers and advisers cannot
     guarantee that the funds will meet their investment objectives. Please read
     the funds' prospectuses for facts you should know before investing. These
     prospectuses are available by contacting us at the address or telephone
     number on the first page of this prospectus.

-    FUND NAME AND MANAGEMENT: A fund underlying your contract in which a
     subaccount invests may have a name, portfolio manager, objectives,
     strategies and characteristics that are the same or substantially similar
     to those of a publicly-traded retail mutual fund. Despite these
     similarities, an underlying fund is not the same as any publicly-traded
     retail mutual fund. Each underlying fund will have its own unique portfolio
     holdings, fees, operating expenses and operating results. The results of
     each underlying fund may differ significantly from any publicly-traded
     retail mutual fund.

-    ELIGIBLE PURCHASERS: All funds are available to serve as the underlying
     investments for variable annuities and variable life insurance policies.
     The funds are not available to the public (see "Fund name and management"
     above). Some funds also are available to serve as investment options for
     tax-deferred retirement plans. It is possible that in the future for tax,
     regulatory or other reasons, it may be disadvantageous for variable annuity
     accounts and variable life insurance accounts and/or tax-deferred
     retirement plans to invest in the available funds simultaneously. Although
     we and the funds do not currently foresee any such disadvantages, the
     boards of directors or trustees of each fund will monitor events in order
     to identify any material conflicts between annuity owners, policy owners
     and tax-deferred retirement plans and to determine what action, if any,
     should be taken in response to a conflict. If a board were to conclude that
     it should establish separate funds for the variable annuity, variable life
     insurance and tax-deferred retirement plan accounts, you would not bear any
     expenses associated with establishing separate funds. Please refer to the
     funds' prospectuses



     for risk disclosure regarding simultaneous investments by variable annuity,
     variable life insurance and tax-deferred retirement plan accounts. Each
     fund intends to comply with the diversification requirements under Section
     817(h) of the Code.


-    ASSET ALLOCATION PROGRAMS MAY IMPACT FUND PERFORMANCE: Asset allocation
     programs in general may negatively impact the performance of an underlying
     fund. Even if you do not participate in an asset allocation program, a fund
     in which your subaccount invests may be impacted if it is included in an
     asset allocation program. Rebalancing or reallocation under the terms of
     the asset allocation program may cause a fund to lose money if it must sell
     large amounts of securities to meet a redemption request. These losses can
     be greater if the fund holds securities that are not as liquid as others;
     for example, various types of bonds, shares of smaller companies and
     securities of foreign issuers. A fund may also experience higher expenses
     because it must sell or buy securities more frequently than it otherwise
     might in the absence of asset allocation program rebalancing or
     reallocations. Because asset allocation programs include periodic
     rebalancing and may also include reallocation, these effects may occur
     under the asset allocation program we offer (see "Making the Most of Your
     Contract -- Portfolio Navigator Program") or under asset allocation
     programs used in conjunction with the contracts and plans of other eligible
     purchasers of the funds.


-    FUNDS AVAILABLE UNDER THE CONTRACT: We seek to provide a broad array of
     underlying funds taking into account the fees and charges imposed by each
     fund and the contract charges we impose. We select the underlying funds in
     which the subaccounts initially invest and when there is substitution (see
     "Substitution of Investments"). We also make all decisions regarding which
     funds to retain in a contract, which funds to add to a contract and which
     funds will no longer be offered in a contract. In making these decisions,
     we may consider various objective and subjective factors. Objective factors
     include, but are not limited to fund performance, fund expenses, classes of
     fund shares available, size of the fund and investment objectives and
     investing style of the fund. Subjective factors include, but are not
     limited to, investment sub-styles and process, management skill and history
     at other funds and portfolio concentration and sector weightings. We also
     consider the levels and types of revenue, including but not limited to
     expense payments and non-cash compensation a fund, its distributor,
     investment adviser, subadviser, transfer agent or their affiliates pay us
     and our affiliates. This revenue includes, but is not limited to
     compensation for administrative services provided with respect to the fund
     and support of marketing and distribution expenses incurred with respect to
     the fund.


-    REVENUE WE RECEIVE FROM THE FUNDS MAY CREATE POTENTIAL CONFLICTS OF
     INTEREST: We or our affiliates receive from each of the funds, or the
     funds' affiliates, varying levels and types of revenue including but not
     limited to expense payments and non-cash compensation. The amount of this
     revenue and how it is computed varies by fund, may be significant and may
     create potential conflicts of interest. The greatest amount and percentage
     of revenue we and our affiliates receive comes from assets allocated to
     subaccounts investing in the RiverSource Variable Series Trust funds
     (affiliated funds) that are managed by RiverSource Investments, LLC
     (RiverSource Investments), one of our affiliates. RiverSource Variable
     Series Trust funds include the RiverSource Variable Portfolio funds,
     RiverSource Partners Variable Portfolio funds, Threadneedle Variable
     Portfolio funds and Disciplined Asset Allocation Portfolio funds. Employee
     compensation and operating goals at all levels are tied to the success of
     Ameriprise Financial, Inc. and its affiliates, including us. Certain
     employees may receive higher compensation and other benefits based, in
     part, on contract values that are invested in the RiverSource Variable
     Series Trust funds. We or our affiliates receive revenue which ranges up to
     0.60% of the average daily net assets invested in the non-RiverSource
     Variable Series Trust funds (unaffiliated funds) through this and other
     contracts we and our affiliate issue. We or our affiliates may also receive
     revenue which ranges up to 0.04% of aggregate, net or anticipated sales of
     unaffiliated funds through this and other contracts we and our affiliate
     issue. Please see the SAI for a table that ranks the unaffiliated funds
     according to total dollar amounts they and their affiliates paid us or our
     affiliates in the prior calendar year.


     Expense payments, non-cash compensation and other forms of revenue may
     influence recommendations your investment professional makes regarding
     whether you should invest in the contract, and whether you should allocate
     purchase payments or contract value to a subaccount that invests in a
     particular fund (see "About the Service Providers").

     The revenue we or our affiliates receive from a fund or its affiliates is
     in addition to revenue we receive from the charges you pay when buying,
     owning and surrendering the contract (see "Expense Summary"). However, the
     revenue we or our affiliates receive from a fund or its affiliates may
     come, at least in part, from the fund's fees and expenses you pay
     indirectly when you allocate contract value to the subaccount that invests
     in that fund.

-    WHY REVENUES ARE PAID TO US: In accordance with applicable laws,
     regulations and the terms of the agreements under which such revenue is
     paid, we or our affiliates may receive these revenues including but not
     limited to expense payments and non-cash compensation for various purposes:

-    Compensating, training and educating financial advisors who sell the
     contracts.



-    Granting access to our employees whose job it is to promote sales of the
     contracts by authorized selling firms and their financial advisors, and
     granting access to financial advisors of our affiliated selling firms.

-    Activities or services we or our affiliates provide that assist in the
     promotion and distribution of the contracts including promoting the funds
     available under the contracts to prospective and existing contract owners,
     authorized selling firms and financial advisors.

-    Providing sub-transfer agency and shareholder servicing to contract owners.

-    Promoting, including and/or retaining the fund's investment portfolios as
     underlying investment options in the contracts.

-    Advertising, printing and mailing sales literature, and printing and
     distributing prospectuses and reports.

-    Furnishing personal services to contract owners, including education of
     contract owners, answering routine inquiries regarding a fund, maintaining
     accounts or providing such other services eligible for service fees as
     defined under the rules of the Financial Industry Regulatory Authority
     (FINRA).

-    Subaccounting, transaction processing, recordkeeping and administration.

-    SOURCES OF REVENUE RECEIVED FROM AFFILIATED FUNDS: The affiliated funds are
     managed by RiverSource Investments. The sources of revenue we receive from
     these affiliated funds, or from affiliates of these funds, may include, but
     are not necessarily limited to, the following:

-    Assets of the fund's adviser and transfer agent or an affiliate of these.
     The revenue resulting from these sources may be based either on a
     percentage of average daily net assets of the fund or on the actual cost of
     certain services we provide with respect to the fund. We may receive this
     revenue either in the form of a cash payment or it may be allocated to us.

-    Compensation paid out of 12b-1 fees that are deducted from fund assets and
     disclosed in the "12b-1 fees" column of the "Annual Operating Expenses of
     the Funds" table.

-    SOURCES OF REVENUE RECEIVED FROM UNAFFILIATED FUNDS: The unaffiliated funds
     are not managed by an affiliate of ours. The sources of revenue we receive
     from these unaffiliated funds, or the funds' affiliates, may include, but
     are not necessarily limited to, the following:

-    Assets of the fund's adviser, subadviser, transfer agent or an affiliate of
     these and assets of the fund's distributor or an affiliate. The revenue
     resulting from these sources usually is based on a percentage of average
     daily net assets of the fund but there may be other types of payment
     arrangements.

-    Compensation paid out of 12b-1 fees that are deducted from fund assets and
     disclosed in the "12b-1 fees" column of the "Annual Operating Expenses of
     the Funds" table.

GUARANTEE PERIOD ACCOUNTS (GPAS)

The GPAs may not be available for contracts in some states. GPAs are not
available if the GWB for Life, SecureSource, or Accumulation Benefit is
selected.

Currently, unless the PN program is in effect, you may allocate purchase
payments and purchase payment credits to one or more of the GPAs with guarantee
periods declared by us. The required minimum investment in each GPA is $1,000.
(Exception: if a model portfolio includes one or more GPAs, the required minimum
does not apply.) These accounts are not offered after annuity payouts begin.

Each GPA pays an interest rate that is declared when you make an allocation to
that account. That interest rate is then fixed for the guarantee period that you
chose. We will periodically change the declared interest rate for any future
allocations to these accounts, but we will not change the rate paid on money
currently in a GPA. The GPA interests under the contracts are registered with
the SEC. The SEC staff reviews the disclosures in this prospectus on the GPA
interests.

The interest rates that we will declare as guaranteed rates in the future are
determined by us at our discretion (future rates).



We will determine future rates based on various factors including, but not
limited to, the interest rate environment, returns earned on investments in the
nonunitized separate account we have established for the GPAs, the rates
currently in effect for new and existing RiverSource Life annuities, product
design, competition and RiverSource Life's revenues and other expenses. Interest
rates offered may vary by state, but will not be lower than state law allows. WE
CANNOT PREDICT NOR CAN WE GUARANTEE WHAT FUTURE RATES WILL BE.

We hold amounts you allocate to the GPAs in a "nonunitized" separate account.
This separate account provides an additional measure of assurance that we will
make full payment of amounts due under the GPAs. State insurance law prohibits
us from charging this separate account with liabilities of any other separate
account or of our general business. We own the assets of this separate account
as well as any favorable investment performance of those assets. You do not
participate in the performance of the assets held in this separate account. We
guarantee all benefits relating to your value in the GPAs. This guarantee is
based on the continued claims-paying ability of the company's general account.
You should be aware that our general account is exposed to the risks normally
associated with a portfolio of fixed-income securities, including interest rate,
option, liquidity and credit risk. The financial statements contained in the SAI
include a further discussion of the risks inherent within the investments of the
general account.

We intend to construct and manage the investment portfolio relating to the
separate account in such a way as to minimize the impact of fluctuations in
interest rates. We achieve this by constructing a portfolio of assets with a
price sensitivity to interest rate changes (i.e., price duration) that is
similar to the price duration of the corresponding portfolio of liabilities.

We must invest this portfolio of assets in accordance with requirements
established by applicable state laws regarding the nature and quality of
investments that life insurance companies may make and the percentage of their
assets that they may commit to any particular type of investment. Our investment
strategy will incorporate the use of a variety of debt instruments having price
durations tending to match the applicable guarantee periods. These instruments
include, but are not necessarily limited to, the following:

-    Securities issued by the U.S. government or its agencies or
     instrumentalities, which issues may or may not be guaranteed by the U.S.
     government;

-    Debt securities that have an investment grade, at the time of purchase,
     within the four highest grades assigned by any of three nationally
     recognized rating agencies -- Standard & Poor's, Moody's Investors Service
     or Fitch -- or are rated in the two highest grades by the National
     Association of Insurance Commissioners;

-    Debt instruments that are unrated, but which are deemed by RiverSource Life
     to have an investment quality within the four highest grades;

-    Other debt instruments which are unrated or rated below investment grade,
     limited to 15% of assets at the time of purchase; and

-    Real estate mortgages, limited to 30% of portfolio assets at the time of
     acquisition.

In addition, options and futures contracts on fixed income securities will be
used from time to time to achieve and maintain appropriate investment and
liquidity characteristics on the overall asset portfolio.

While this information generally describes our investment strategy, we are not
obligated to follow any particular strategy except as may be required by federal
law and Minnesota and other state insurance laws.

MARKET VALUE ADJUSTMENT (MVA)

We will not apply an MVA to contract value you transfer or surrender out of the
GPAs within 30 days before the end of the guarantee period. During this 30 day
window you may choose to start a new guarantee period of the same length,
transfer the contract value to a GPA of another length, transfer the contract
value to any of the subaccounts or the regular fixed account, or surrender the
contract value (subject to applicable surrender provisions). If we do not
receive any instructions at the end of your guarantee period, our current
practice is to automatically transfer the contract value to the one year GPA.
Any new GPA, whether it is one you choose or an automatic transfer to a one year
GPA, will be subject to an MVA as described below.



We guarantee the contract value allocated to the GPAs, including interest
credited, if you do not make any transfers or surrenders from the GPAs prior to
30 days before the end of the guarantee period (30-day rule). At all other
times, and unless one of the exceptions to the 30-day rule described below
applies, we will apply an MVA if you surrender or transfer contract value from a
GPA including withdrawals under the GWB for Life rider, SecureSource rider or
you elect an annuity payout plan while you have contract value invested in a
GPA. We will refer to these transactions as "early surrenders." The application
of an MVA may result in either a gain or loss of principal.

The 30-day rule does not apply and no MVA will apply to:

-    amounts surrendered under contract provisions that waive surrender charges
     for Hospital or Nursing Home Confinement and Terminal Illness Disability
     Diagnosis;

-    amounts surrendered from the GPA within 30 days prior to the end of the
     Guarantee Period;

-    automatic rebalancing under any PN program model portfolio we offer which
     includes one or more GPAs. However, an MVA may apply if you transfer to a
     new PN program model portfolio;

-    amounts applied to an annuity payout plan while a PN program model
     portfolio including one or more GPAs is in effect;


-    reallocation of your contract value according to an updated PN program
     model portfolio or investment option;

-    amounts surrendered for fees and charges; and


-    amounts we pay as death claims.

When you request an early surrender, we adjust the early surrender amount by an
MVA formula. The early surrender amount reflects the relationship between the
guaranteed interest rate you are earning in your current GPA and the interest
rate we are crediting on new GPAs that end at the same time as your current GPA.

The MVA is sensitive to changes in current interest rates. The magnitude of any
applicable MVA will depend on our current schedule of guaranteed interest rates
at the time of the surrender, the time remaining in your guarantee period and
your guaranteed interest rate. The MVA is negative, zero or positive depending
on how the guaranteed interest rate on your GPA compares to the interest rate of
a new GPA for the same number of years as the guarantee period remaining on your
GPA. This is summarized in the following table:



         IF YOUR GPA RATE IS:           THE MVA IS:
-------------------------------------   -----------
                                     
Less than the new GPA rate + 0.10%      Negative
Equal to the new GPA rate + 0.10%       Zero
Greater than the new GPA rate + 0.10%   Positive


For an example, see Appendix B.

THE FIXED ACCOUNT

Amounts allocated to the fixed account become part of our general account. The
fixed account includes the regular fixed account and the Special DCA fixed
account. We credit interest on amounts you allocate to the fixed account at
rates we determine from time to time in our discretion. These rates will be
based on various factors including, but not limited to, the interest rate
environment, returns we earn on our general account investments, the rates
currently in effect for new and existing RiverSource Life annuities, product
design, competition, and RiverSource Life's revenues and expenses. The
guaranteed minimum interest rate on amounts invested in the fixed account may
vary by state but will not be lower than state law allows. We back the principal
and interest guarantees relating to the fixed account. These guarantees are
based on the continued claims-paying ability of RiverSource Life. You should be
aware that our general account is exposed to the risks normally associated with
a portfolio of fixed-income securities, including interest rate, option,
liquidity and credit risk. The financial statements contained in the SAI include
a further discussion of the risks inherent within the investments of the general
account.

The fixed account is not required to be registered with the SEC. The SEC staff
does not review the disclosures in this prospectus on the fixed account,
however, disclosures regarding the fixed account may be subject to certain
generally applicable provisions of the federal securities laws relating to the
accuracy and completeness of statements made in prospectuses.



THE REGULAR FIXED ACCOUNT

For RAVA 4 Advantage and RAVA 4 Select, unless the PN program is in effect, you
also may allocate purchase payments and purchase payment credits or transfer
contract value to the regular fixed account. For RAVA 4 Access contracts, you
cannot allocate purchase payments to the regular fixed account unless it is
included in the PN program model portfolio you selected. The value of the
regular fixed account increases as we credit interest to the account. We credit
and compound interest daily based on a 365-day year so as to produce the annual
effective rate which we declare. We do not credit interest on leap days (Feb.
29). The interest rate we apply to each purchase payment or transfer to the
regular fixed account is guaranteed for one year. Thereafter, we will change the
rates from time to time at our discretion. Subject to state limitations, we
reserve the right to limit purchase payment allocations to the regular fixed
account if the interest rate we are then currently crediting to the regular
fixed account is equal to the minimum interest rate stated in the contract. (See
"Making the Most of Your Contract -- Transfer policies" for restrictions on
transfers involving the regular fixed account.)

THE SPECIAL DCA FIXED ACCOUNT

You also may allocate purchase payments and purchase payment credits to the
Special DCA fixed account, when available. The Special DCA fixed account is
available for new purchase payments. The value of the Special DCA fixed account
increases as we credit interest to the account. We credit and compound interest
daily based on a 365-day year so as to produce the annual effective rate which
we declare. We do not credit interest on leap days (Feb. 29). The interest rate
we apply to each purchase payment is guaranteed for the period of time money
remains in the Special DCA fixed account. (See "Making the Most of Your Contract
-- Special Dollar Cost Averaging Program" for more information on the Special
DCA fixed account.)

BUYING YOUR CONTRACT

You can fill out an application and send it along with your initial purchase
payment to our corporate office. You may buy RAVA 4 Advantage, RAVA 4 Select or
RAVA 4 Access. Each contract has different mortality and expense risk fees. RAVA
4 Access does not have surrender charges, but it has the highest mortality and
expense risk fees of the three contracts. RAVA 4 Select has a three-year
surrender charge schedule and lower mortality and expense risk fees then RAVA 4
Access. RAVA 4 Advantage offers a choice of a seven-year or ten-year surrender
charge schedule and the lowest mortality and expense risk fees of the three
contracts; additionally, optional living benefit riders are not available under
RAVA 4 Access. We are required by law to obtain personal information from you
which we will use to verify your identity. If you do not provide this
information we reserve the right to refuse to issue your contract or take other
steps we deem reasonable. As the owner, you have all rights and may receive all
benefits under the contract. You can own a nonqualified annuity in joint tenancy
with rights of survivorship only in spousal situations. You cannot own a
qualified annuity in joint tenancy. You can buy a contract if you and the
annuitant are 90 or younger.

When you apply, you may select among the following (if available in your state):

-    GPAs, the regular fixed account(1), subaccounts and/or the Special DCA
     fixed account in which you want to invest;

-    how you want to make purchase payments;

-    a beneficiary;

-    under RAVA 4 Advantage, the length of the surrender charge period (seven or
     ten years)(2);

-    the optional PN program;

-    one of the following optional death benefits:

     -    ROPP Death Benefit(3);

     -    MAV Death Benefit(3);

     -    5-Year MAV Death Benefit(3);

     -    EEB Death Benefit(3);



     -    EEP Death Benefit(3); and

-    under RAVA 4 Advantage and RAVA 4 Select, one of the following optional
     living benefits that require the use of the PN program:

     -    Accumulation Benefit rider(4); or

     -    SecureSource rider(4).

(1)  For RAVA 4 Access contracts, you cannot select the regular fixed account
     unless it is included in a PN program model portfolio you selected.

(2)  In certain states, the ten-year surrender charge schedule is 8% for years
     0-2, 7% for year 3 and declining by 1% each year thereafter until it is 0%
     for years 10+. For contracts issued in Alabama and Massachusetts, we waive
     surrender charges after the tenth contract anniversary.

(3)  You may select any one of the ROPP, MAV, 5-Year MAV, EEB or EEP riders or
     certain combinations thereof. You may select the MAV and either the EEB or
     the EEP. You may select the 5-Year MAV and either the EEB or the EEP. You
     cannot select both the EEB and EEP. You cannot select both the MAV and
     5-Year MAV. The MAV, EEB, EEP and 5-Year MAV are only available if you are
     75 or younger at the rider effective date. EEP is only available on
     contracts purchased through a transfer or exchange. ROPP is only available
     if you are 76 or older at the rider effective date. ROPP is included in the
     standard death benefit if you are 75 or younger.

(4)  You may select either the Accumulation Benefit or SecureSource rider. The
     Accumulation Benefit and SecureSource - Single Life riders are only
     available if you are 80 or younger at the rider effective date.
     SecureSource - Joint Life rider is available if both covered spouses are 80
     or younger.

The contracts provide for allocation of purchase payments and purchase payment
credits to the subaccounts of the variable account, to the GPAs, to the regular
fixed account and/or to the Special DCA fixed account (when available) in even
1% increments subject to the $1,000 required minimum investment for the GPAs.
There may be certain restrictions on the amount you may allocate to the regular
fixed account. For RAVA 4 Access contracts, purchase payment credits are not
available and you cannot allocate purchase payments to the regular fixed account
unless it is included in a PN program model portfolio you selected. (See
"Purchase Payments.")

If your application is complete, we will process it and apply your purchase
payment and purchase payment credits to the GPAs, the regular fixed account, the
Special DCA fixed account and/or subaccounts you selected within two business
days after we receive it at our corporate office. If we accept your application,
we will send you a contract. If your application is not complete, you must give
us the information to complete it within five business days. If we cannot accept
your application within five business days, we will decline it and return your
payment unless you specifically ask us to keep the payment and apply it once
your application is complete.

We will credit additional purchase payments you make to your accounts on the
valuation date we receive them. If we receive an additional purchase payment at
our corporate office before the close of business, we will credit any portion of
that payment allocated to the subaccounts using the accumulation unit value we
calculate on the valuation date we received the payment. If we receive an
additional purchase payment at our corporate office at or after the close of
business, we will credit any portion of that payment allocated to the
subaccounts using the accumulation unit value we calculate on the next valuation
date after we received the payment.

THE SETTLEMENT DATE

Annuity payouts are scheduled to begin on the settlement date. When we process
your application, we will establish the settlement date as the maximum age (or
contract anniversary, if applicable) for nonqualified annuities and Roth IRAs
and the date specified below for qualified annuities. You can also select a date
within the maximum limits. Your selected date can align with your actual
retirement from a job, or it can be a different date, depending on your needs
and goals and on certain restrictions. You also can change the settlement date,
provided you send us written instructions at least 30 days before annuity
payouts begin.

FOR NONQUALIFIED ANNUITIES AND ROTH IRAS, the settlement date must be:

-    no earlier than the 60th day after the contract's effective date; and



-    no later than the annuitant's 90th birthday or the tenth contract
     anniversary, if purchased after age 80, or a date that has been otherwise
     agreed to by us.

FOR QUALIFIED ANNUITIES EXCEPT ROTH IRAS, to comply with IRS regulations, the
settlement date generally must be:

-    for IRAs, by April 1 of the year following the calendar year when you reach
     age 70 1/2; or

-    for all other qualified annuities, by April 1 of the year following the
     calendar year when you reach age 70 1/2, or, if later, retire (except that
     5% business owners may not select a settlement date that is later than
     April 1 of the year following the calendar year when they reach age 70
     1/2).

If you satisfy your RMDs in the form of partial surrenders from this contract,
annuity payouts can start as late as the annuitant's 90th birthday or the tenth
contract anniversary, if later, or a date that has been otherwise agreed to by
us.

Contract owners of IRAs and TSAs may also be able to satisfy required minimum
distributions using other IRAs or TSAs, and in that case, may delay the annuity
payout start date for these contracts.

BENEFICIARY

If death benefits become payable before the settlement date while the contract
is in force and before annuity payouts begin, we will pay the death benefit to
your named beneficiary. If there is more than one beneficiary we will pay each
beneficiary's designated share when we receive their completed claim. A
beneficiary will bear the investment risk of the variable account until we
receive the beneficiary's completed claim. If there is no named beneficiary,
then the default provisions of your contract will apply. (See "Benefits in Case
of Death" for more about beneficiaries.)

If you select the SecureSource - Joint Life rider, please consider carefully
whether or not you wish to change the beneficiary of your annuity contract. The
rider will terminate if the surviving covered spouse can not utilize the spousal
continuation provision of the contract when the death benefit is payable.

PURCHASE PAYMENTS*

MINIMUM ALLOWABLE PURCHASE PAYMENTS**

If paying by installments under a scheduled payment plan:

$23.08 biweekly, or

$50 per month



                                                RAVA 4 ADVANTAGE   RAVA 4 SELECT   RAVA 4 ACCESS
                                                ----------------   -------------   -------------
                                                                          
If paying by any other method:
   initial payment for qualified annuities           $1,000           $ 2,000         $ 2,000
   initial payment for nonqualified annuities         2,000            10,000          10,000
   for any additional payments                           50                50              50


*    RAVA 4 ADVANTAGE AND RAVA 4 SELECT BAND 3 ANNUITIES SOLD TO INDIVIDUALS
     OTHER THAN ADVISORS AND EMPLOYEES: Require a minimum $1,000,000 initial
     purchase payment and corporate office approval. Contracts already approved
     may make payments in subsequent years up to $100,000 if your age on the
     effective date of the contract is age 85 or younger and $50,000 if your age
     on the effective date of the contract is age 86 to 90.

**   Installments must total at least $600 in the first year. If you do not make
     any purchase payments for 24 months, and your previous payments total $600
     or less, we have the right to give you 30 days' written notice and pay you
     the total value of your contract in a lump sum. This right does not apply
     to contracts in Illinois, Massachusetts and New Jersey.



MAXIMUM ALLOWABLE PURCHASE PAYMENTS*** (without corporate office approval) based
on your age on the effective date of the contract:



                            RAVA 4 ADVANTAGE   RAVA 4 SELECT   RAVA 4 ACCESS
                            ----------------   -------------   -------------
                                                      
For the first year:
   through age 85               $999,999          $999,999        $999,999
   for ages 86 to 90             100,000           100,000         100,000
For each subsequent year:
   through age 85                100,000           100,000         100,000
   for ages 86 to 90              50,000            50,000          50,000


***  These limits apply in total to all RiverSource Life annuities you own.
     These limits do not apply to contracts in New Jersey. We reserve the right
     to increase maximum limits. For qualified annuities, the Code's limits on
     annual contributions also apply. For the Accumulation Benefit rider,
     additional purchase payments are restricted during the waiting period after
     the first 180 days immediately following the effective date and each
     elective step up.

EFFECTIVE JAN. 26, 2009, NO ADDITIONAL PURCHASE PAYMENTS ARE ALLOWED FOR
CONTRACTS WITH THE GWB FOR LIFE OR SECURESOURCE RIDERS, SUBJECT TO STATE
RESTRICTIONS.

For contracts issued in all states except those listed below, certain exceptions
apply and the following additional purchase payments will be allowed on/after
Jan. 26, 2009:

a.   Tax Free Exchanges, rollovers, and transfers listed on the annuity
     application and received within 180 days from the contract issue date.

b.   Current tax year contributions for TSAs up to the annual limit set by the
     IRS.

c.   Prior and current tax year contributions up to a cumulative annual maximum
     of $6,000(1) for any Qualified Accounts except TSAs. This maximum applies
     to IRAs, Roth IRAs, SIMPLE IRAs, and SEP plans.

(1)  The maximum amount is subject to change in later years and is based on the
     limit set by the IRS for individual IRAs (including the catch-up
     provision).

For Contracts Issued in Florida, New Jersey, and Oregon:

For contracts with GWB for Life rider or SecureSource riders issued in Florida,
New Jersey, and Oregon, additional purchase payments to your variable annuity
contract will be limited to $100,000 for the life of your contract. The limit
does not apply to Tax Free Exchanges, rollovers and transfers listed on the
annuity application and received within 180 days from the contract issue date.

We reserve the right to change these current rules at any time, subject to state
restrictions.

Purchase payment amounts and purchase payment timing may vary by state and may
be limited under the terms of your contract.

Subject to state regulatory requirements, we reserve the right to not accept
purchase payments allocated to the regular fixed account for twelve months
following either:

1.   a partial surrender from the regular fixed account; or

2.   a lump sum transfer from the regular fixed account to a subaccount.



HOW TO MAKE PURCHASE PAYMENTS

1 BY LETTER

Send your check along with your name and contract number to:

RIVERSOURCE LIFE INSURANCE COMPANY 70200 AMERIPRISE FINANCIAL CENTER

MINNEAPOLIS, MN 55474

2 BY SCHEDULED PAYMENT PLAN

We can help you set up:

-    an automatic payroll deduction, salary reduction or other group billing
     arrangement; or

-    a bank authorization.

PURCHASE PAYMENT CREDITS

PURCHASE PAYMENT CREDITS ARE NOT AVAILABLE FOR RAVA 4 ACCESS.

FOR RAVA 4 ADVANTAGE: we add a credit to your contract in the amount of:

-    1% of each purchase payment received:

     -    if you elect the ten-year surrender charge schedule for your contract
          and the initial purchase payment is under $100,000; or

     -    if you elect the seven-year surrender charge schedule for your
          contract and your initial purchase payment to the contract is at least
          $100,000 but less than $1,000,000.

-    2% of each purchase payment received if you elect the ten-year surrender
     charge schedule for your contract and your initial purchase payment to the
     contract is at least $100,000 but less than $1,000,000.

FOR RAVA 4 ADVANTAGE - BAND 3: we add a credit to your contract in the amount
of:

-    2% of each purchase payment received:

     -    if you elect the seven-year surrender charge schedule for your
          contract.

-    3% of each purchase payment received

     -    if you elect the ten-year surrender charge schedule for your contract.

Surrender charges under RAVA 4 Advantage and RAVA 4 Advantage - Band 3 may be
higher and longer than those for contracts that do not have purchase payment
credits. The amount of the credits may be more than offset by the additional
charges associated with them. Because of higher charges, there could be
circumstances where you may be worse off purchasing one of these contracts with
the credits than purchasing other contracts. All things being equal (such as
fund performance and availability), this may occur if you select the ten-year
surrender charge and you make a full surrender before year ten. We pay for the
credits under RAVA 4 Advantage and RAVA 4 Advantage - Band 3 primarily through
revenue from a higher and longer surrender charge schedule and through lower
costs associated with larger sized contracts, including lower compensation paid
on the sales of these contracts.

FOR RAVA 4 SELECT: we add a credit to your contract in the amount of 1% of each
purchase payment received in the first contract year if your initial purchase
payment to the contract is at least $250,000 but less than $1,000,000.



FOR RAVA 4 SELECT - BAND 3: we add a credit to your contract in the amount of 2%
of each purchase payment received in the first contract year.

Expenses under RAVA 4 Select and RAVA 4 Select - Band 3 may be higher than those
for contracts that do not have purchase payment credits. The amount of the
credits may be more than offset by the additional charges associated with them.
Because of higher charges, you may be worse off purchasing one of these
contracts with the credits than purchasing other contracts. We pay for the
credits under RAVA 4 Select and RAVA 4 Select - Band 3 primarily through lower
costs associated with larger sized contracts, including lower compensation paid
on the sales of these contracts.

We fund all credits from our general account. We do not consider credits to be
"investments" for income tax purposes. (See "Taxes.")

We allocate each credit to your contract value when the applicable purchase
payment is applied to your contract value. We allocate such credits to your
contract value according to allocation instructions in effect for your purchase
payments.

We will reverse credits from the contract value for any purchase payment that is
not honored. The amount returned to you under the free look provision also will
not include any credits applied to your contract. (See "The Contract in Brief --
Free look period.")

We will assess a charge, similar to a surrender charge, equal to the amount of
the purchase payment credits to the extent a death benefit, surrender payment,
or your settlement under an annuity payout plan includes purchase payment
credits applied within twelve months preceding: (1) the date of death that
results in a death benefit payment under this contract; (2) a request for
surrender charge waiver due to Hospital or Nursing Home Confinement or Terminal
Illness Disability Diagnosis; or (3) your settlement of the contract under an
annuity payout plan.*

We reserve the right to increase the amount of the credit for certain groups of
contract owners. The increase will not be greater than 8% of total net purchase
payments. We would pay for increases in credit amounts primarily through reduced
expenses expected from such groups.

*    For contracts purchased in Oregon, we will assess a charge, similar to a
     surrender charge, equal to the amount of the purchase payment credits to
     the extent a death benefit, includes purchase payment credits applied
     within twelve months preceding the date of death.

LIMITATIONS ON USE OF CONTRACTS

If mandated by applicable law, including but not limited to, federal anti-money
laundering laws, we may be required to reject a purchase payment. We may also be
required to block an owner's access to contract values and satisfy other
statutory obligations. Under these circumstances, we may refuse to implement
requests for transfers, surrenders or death benefits until instructions are
received from the appropriate governmental authority or court of competent
jurisdiction.

CHARGES

CONTRACT ADMINISTRATIVE CHARGE

We charge this fee for establishing and maintaining your records. Currently, we
deduct $30 from your contract value on your contract anniversary at the end of
each contract year. Subject to state regulatory requirements, we prorate this
charge among the subaccounts and the regular fixed account in the same
proportion your interest in each account bears to your total contract value,
less amounts invested in the GPAs and the Special DCA fixed account. The
contract administrative charge is only deducted from GPAs and any Special DCA
fixed account if insufficient amounts are available in the regular fixed account
and the subaccounts. We reserve the right to increase this charge after the
first contract anniversary to a maximum of $50.*

We will waive $30 of this charge when your contract value, or total purchase
payments less any payments surrendered, is $50,000 or more on the current
contract anniversary.

If you surrender your contract, we will deduct the full charge at the time of
surrender regardless of the contract value or purchase payments made. This
charge does not apply after annuity payouts begin or when we pay death benefits.

*    In certain states and for certain contracts we have waived our right to
     increase the contract administrative charge.



MORTALITY AND EXPENSE RISK FEE

We charge this fee daily to the subaccounts. The unit values of your subaccounts
reflect this fee, which is a percentage of their average daily net assets, on an
annual basis as follows:



                             RAVA 4 ADVANTAGE   RAVA 4 SELECT   RAVA 4 ACCESS
                             ----------------   -------------   -------------
                                                       
For nonqualified annuities         1.05%             1.30%           1.45%
For qualified annuities             .85%             1.10%           1.25%


This fee covers the mortality and expense risk that we assume. This fee does not
apply to the GPAs, the regular fixed account or the Special DCA fixed account.

Mortality risk arises because of our guarantee to pay a death benefit and our
guarantee to make annuity payouts according to the terms of the contract, no
matter how long a specific owner or annuitant lives and no matter how long our
entire group of owners or annuitants live. If, as a group, owners or annuitants
outlive the life expectancy we assumed in our actuarial tables, we must take
money from our general assets to meet our obligations. If, as a group, owners or
annuitants do not live as long as expected, we could profit from the mortality
risk fee. We deduct the mortality risk fee from the subaccounts during the
annuity payout period even if the annuity payout plan does not involve a life
contingency.

Expense risk arises because we cannot increase the contract administrative
charge more than $20.00 per contract and this charge may not cover our expenses.
We would have to make up any deficit from our general assets. We could profit
from the expense risk fee if future expenses are less than expected.

The subaccounts pay us the mortality and expense risk fee they accrued as
follows:

-    first, to the extent possible, the subaccounts pay this fee from any
     dividends distributed from the funds in which they invest;

-    then, if necessary, the funds redeem shares to cover any remaining fees
     payable.

We may use any profits we realize from the subaccounts' payment to us of the
mortality and expense risk fee for any proper corporate purpose, including,
among others, payment of distribution (selling) expenses. We do not expect that
the surrender charge for RAVA 4 Advantage or RAVA 4 Select, discussed in the
following paragraphs, will cover sales and distribution expenses.

SURRENDER CHARGE

If you surrender all or part of your contract, you may be subject to a surrender
charge. For RAVA 4 Advantage, a surrender charge applies if all or part of the
surrender amount is from purchase payments we received within seven or ten years
before surrender. You select the surrender charge period at the time of your
application for the contract. For RAVA 4 Select, a surrender charge applies if
you surrender all or part of your purchase payments in the first three contract
years. There is no surrender charge for RAVA 4 Access. The surrender charge
percentages that apply to you are shown in your contract.

You may surrender an amount during any contract year without a surrender charge.
We call this amount the Total Free Amount (TFA). The TFA varies depending on
whether your contract includes the GWB for Life rider or SecureSource rider:

CONTRACTS WITHOUT GWB FOR LIFE RIDER OR SECURESOURCE RIDER

The TFA is the greater of:

-    10% of the contract value on the prior contract anniversary*; or

-    current contract earnings.



CONTRACTS WITH GWB FOR LIFE RIDER OR SECURESOURCE RIDER

The TFA is the greatest of:

-    10% of the contract value on the prior contract anniversary*;

-    current contract earnings;

-    the Remaining Benefit Payment; or

-    the Remaining Annual Lifetime Payment.

*    We consider all purchase payments received and any purchase payment credit
     applied prior to your surrender request to be the prior contract
     anniversary's contract value during the first contract year.

NOTE: We determine current contract earnings by looking at the entire contract
value, not the earnings of any particular subaccount, GPA, the regular fixed
account or the Special DCA fixed account.

Amounts surrendered in excess of the TFA may be subject to a surrender charge as
described below.

SURRENDER CHARGE UNDER RAVA 4 ADVANTAGE:

For purposes of calculating any surrender charge under RAVA 4 Advantage, we
treat amounts surrendered from your contract value in the following order:

1.   First, we surrender the TFA. We do not assess a surrender charge on the
     TFA.

2.   Next we surrender purchase payments received prior to the surrender charge
     period you selected and shown in your contract. We do not assess a
     surrender charge on these purchase payments.

3.   Finally, if necessary, we surrender purchase payments received that are
     still within the surrender charge period you selected and shown in your
     contract. We surrender these payments on a first-in, first-out (FIFO)
     basis. We do assess a surrender charge on these payments.

We determine your surrender charge by multiplying each of your payments
surrendered by the applicable surrender charge percentage, and then adding the
total surrender charges.

The surrender charge percentage depends on the number of years since you made
the payments that are surrendered, depending on the schedule you selected*:



            SEVEN-YEAR SCHEDULE                           TEN-YEAR SCHEDULE*
-------------------------------------------   ------------------------------------------
  NUMBER OF COMPLETED                           NUMBER OF COMPLETED
YEARS FROM DATE OF EACH    SURRENDER CHARGE   YEARS FROM DATE OF EACH   SURRENDER CHARGE
   PURCHASE PAYMENT           PERCENTAGE         PURCHASE PAYMENT          PERCENTAGE
-----------------------    ----------------   -----------------------   ----------------
                                                               
           0                       7%                     0                     8%
           1                       7                      1                     8
           2                       7                      2                     8
           3                       6                      3                     7
           4                       5                      4                     7
           5                       4                      5                     6
           6                       2                      6                     5
           7+                      0                      7                     4
                                                          8                     3
                                                          9                     2
                                                         10+                    0


*    In certain states the ten-year surrender charge schedule is 8% for years
     0-2, 7% for year 3 and declining by 1% each year thereafter until it is 0%
     for years 10+. For contracts issued in Alabama and Massachusetts, we waive
     surrender charges after the tenth contract anniversary. Surrender charges
     may vary by state based on your age at contract issue.



SURRENDER CHARGE UNDER RAVA 4 SELECT (EXCEPT TEXAS):

For purposes of calculating any surrender charge under RAVA 4 Select, we treat
amounts surrendered from your contract value in the following order:

1.   First, we surrender the TFA. We do not assess a surrender charge on the
     TFA.

2.   Next, if necessary, we surrender purchase payments. We do assess a
     surrender charge on these payments during the first three contract years as
     follows:



CONTRACT YEAR   SURRENDER CHARGE PERCENTAGE
-------------   ---------------------------
             
      1                      7%
      2                      7
      3                      7
  Thereafter                 0


SURRENDER CHARGE UNDER RAVA 4 SELECT IN TEXAS:

For purposes of calculating any surrender charge under RAVA 4 Select in Texas,
we treat amounts surrendered from your contract value in the following order:

1.   First, we surrender the TFA. We do not assess a surrender charge on the
     TFA.

2.   Next, if necessary, we surrender purchase payments. We surrender amounts
     from the oldest purchase payments first. We do assess a surrender charge on
     these payments during the first three contract years as follows:



     NUMBER OF COMPLETED YEARS
FROM DATE OF EACH PURCHASE PAYMENT   SURRENDER CHARGE PERCENTAGE
----------------------------------   ---------------------------
                                  
                 0                                8%
                 1                                7
                 2                                6
            Thereafter                            0


3.   There are no surrender charges after the third contract anniversary.

SURRENDER CHARGE UNDER RAVA 4 ACCESS:

There is no surrender charge if you surrender all or part of your contract.

PARTIAL SURRENDERS:

For a partial surrender that is subject to a surrender charge, the amount we
actually deduct from your contract value will be the amount you request plus any
applicable surrender charge, plus or minus any applicable MVA.

For an example, see Appendix C.

SURRENDER CHARGE UNDER ANNUITY PAYOUT PLAN E -- PAYOUTS FOR A SPECIFIED PERIOD:
Under this annuity payout plan, you can choose to take a surrender. The amount
that you can surrender is the present value of any remaining variable payouts.
The discount rate we use in the calculation will be 5.17% if the assumed
investment rate is 3.5% and 6.67% if the assumed investment rate is 5%. The
surrender charge equals the present value of the remaining payouts using the
assumed investment rate minus the present value of the remaining payouts using
the discount rate.

WAIVER OF SURRENDER CHARGES

We do not assess surrender charges for:



-    surrenders of any contract earnings;

-    surrenders of amounts totaling up to 10% of the contract value on the prior
     contract anniversary to the extent it exceeds contract earnings;

-    if you elected the GWB for Life or SecureSource rider, the greater of your
     contract's Remaining Benefit Payment or Remaining Annual Lifetime Payment
     to the extent it exceeds the greater of contract earnings or 10% of the
     contract value on the prior contract anniversary;

-    amounts surrendered after the tenth contract anniversary in Alabama and
     Massachusetts;

-    required minimum distributions from a qualified annuity provided the amount
     is no greater than the RMD amount calculated under your specific contract,
     currently in force;

-    contracts settled using an annuity payout plan*, unless an Annuity Payout
     Plan E is later surrendered;

-    amounts we refund to you during the free look period*;

-    death benefits*;

-    surrenders you make under your contract's "Waiver of Surrender Charges for
     Hospital or Nursing Home Confinement" provision*. To the extent permitted
     by state law, this provision applies when you are under age 76 on the date
     that we issue the contract. Under this provision, we will waive surrender
     charges that we normally assess upon full or partial surrender. You must
     provide proof satisfactory to us that, as of the date you request the
     surrender, you or your spouse are confined to a nursing home or hospital
     and have been for 60 straight days and the confinement began after the
     contract date. (See your contract for additional conditions and
     restrictions on this waiver.); and

-    surrenders you make under your contract's "Waiver of Surrender Charges for
     Terminal Illness Disability Diagnosis" provision.* To the extent permitted
     by state law, this provision applies when you are under age 76 on the date
     we issue the contract. Under this provision, we will waive surrender
     charges that we normally assess for surrenders you make if you are
     diagnosed after the contract issue date as disabled with a medical
     condition that with reasonable medical certainty will result in death
     within 12 months or less from the date of a licensed physician's statement.
     You must provide us with a licensed physician's statement containing the
     terminal illness diagnosis and the date the terminal illness was initially
     diagnosed. (See your contract for additional conditions and restrictions on
     this waiver.)

*    However, we will reverse certain purchase payment credits. (See "Buying
     your contract -- Purchase payment credits.")

OTHER INFORMATION ON CHARGES: Ameriprise Financial, Inc. makes certain custodial
services available to some profit sharing, money purchase and target benefit
plans funded by our annuities. Fees for these services start at $30 per calendar
year per participant. Ameriprise Financial, Inc. will charge a termination fee
for owners under age 59 1/2 (fee waived in case of death or disability).

POSSIBLE GROUP REDUCTIONS: In some cases we may incur lower sales and
administrative expenses due to the size of the group, the average contribution
and the use of group enrollment procedures. In such cases, we may be able to
reduce or eliminate certain charges such as the contract administrative and
surrender charges. However, we expect this to occur infrequently.

ACCUMULATION BENEFIT RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.80%(2) of the greater of your contract value or the
minimum contract accumulation value on your contract anniversary. We prorate
this fee among the subaccounts and the regular fixed account (if applicable) in
the same proportion as your interest in each bears to your total contract value,
less any amounts invested in the Special DCA fixed account. Such fee is only
deducted from any Special DCA fixed account if insufficient amounts are
available in the regular fixed account and the subaccounts. The fee will only be
deducted from the subaccounts in Washington. We will modify this prorated
approach to comply with state regulations where necessary.



Once you elect the Accumulation Benefit rider, you may not cancel it and the fee
will continue to be deducted through the end of the waiting period or when
annuity payouts begin. If the contract is terminated for any reason or when
annuity payouts begin, we will deduct the fee, adjusted for the number of
calendar days coverage was in place since we last deducted the fee.


Currently, the Accumulation Benefit rider charge does not vary with the PN
program model portfolio or investment option selected; however, we reserve the
right to increase this charge and/or charge a separate rider fee for each model
portfolio or investment option. The Accumulation Benefit rider fee will not
exceed a maximum charge of 2.50%.


We will not change the Accumulation Benefit rider charge after the rider
effective date unless:

(a)  you choose the annual Elective Step Up after we have exercised our rights
     to increase the rider charge;

(b)  you choose the elective spousal continuation step up after we have
     exercised our rights to increase the rider charge;


(c)  you change your PN program investment option (or change from a model
     portfolio to an investment option under the PN program) after we have
     exercised our rights to increase the rider charge;



(d)  you change your PN program investment option (or change from a model
     portfolio to an investment option under the PN program)after we have
     exercised our rights to charge a separate rider charge for each model
     portfolio or investment option.



If you elect to change your PN program investment option (or change from a model
portfolio to an investment option) after we have exercised our right to increase
the fee we charge for this rider, or after we have exercised our right to
establish fees for this rider which vary by model portfolio or investment
option, the increase in fees we charge for this rider will become effective on
the contract anniversary following your change of model portfolio or investment
option. Any model portfolio or investment option changes on the contract
anniversary will have the new charge effective on that contract anniversary.
Also, in the event you change your model portfolio or investment option twice in
the same contract year (see "Portfolio Navigator Program"), the fee we charge
for this rider will be the greatest fee applicable to any investment option
which you have selected during the contract year.



If you choose the Elective Step Up, the elective spousal continuation step up,
or change your model portfolio or investment option after we have exercised our
rights to increase the rider charge as described above, you will pay the charge
that is in effect on the valuation date we receive your written request to step
up or change your model portfolio or investment option. For Elective Step Ups
and elective spousal continuation step ups, this change will be in effect for
the entire contract year.


The fee does not apply after annuity payouts begin.


(1)  Available if you are 80 or younger at the rider effective date. You must
     select a PN program model portfolio or investment option with this rider
     (see "Portfolio Navigator Program"). Not available with GWB for Life or
     SecureSource riders.


(2)  For contracts purchased prior to Jan. 26, 2009, the current charge is
     0.60%.

GWB FOR LIFE RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.65% of the greater of the contract anniversary
value or the remaining benefit amount (RBA). We prorate this fee among the
subaccounts and the regular fixed account (if applicable) in the same proportion
as your interest in each bears to your total contract value, less any amounts
invested in the GPAs and in the Special DCA fixed account. Such fee is only
deducted from GPAs and any Special DCA fixed account if insufficient amounts are
available in the regular fixed account and the subaccounts. The fee will only be
deducted from the subaccounts in Washington. We will modify this prorated
approach to comply with state regulations where necessary.

(1)  The GWB for Life rider is no longer available for sale.



Once you elect the GWB for Life rider, you may not cancel it and the fee will
continue to be deducted until the contract is terminated, the contract value
reduces to zero or annuity payouts begin. If the contract is terminated for any
reason or when annuity payouts begin, we will deduct the fee, adjusted for the
number of calendar days coverage was in place since we last deducted the fee. If
the RBA goes to zero but the contract value has not been depleted, you will
continue to be charged.


Currently, the GWB for Life rider charge does not vary with the PN program model
portfolio or investment option selected; however, we reserve the right to
increase this charge and/or charge a separate rider charge for each model
portfolio or investment option. The GWB for Life rider charge will not exceed a
maximum charge of 1.50%.


We will not change the GWB for Life rider charge after the rider effective date
unless:

(a)  you choose the annual elective step up after we have exercised our rights
     to increase the rider charge;

(b)  you choose the elective spousal continuation step up after we have
     exercised our rights to increase the rider charge;


(c)  you elect to change your PN program investment option (or change from a
     model portfolio to an investment option under the PN program) after we have
     exercised our rights to increase the rider charge;



(d)  you elect to change your PN program investment option (or change from a
     model portfolio to an investment option under the PN program) after we have
     exercised our rights to charge a separate rider charge for each model
     portfolio or investment option.



If you chose the elective spousal continuation step up or change your investment
option (or change from a model portfolio to an investment option) after we have
exercised our right to increase the fee we charge for this rider, or after we
have exercised our right to establish fees for this rider which vary by model
portfolio or investment option, the increase in fees we charge for this rider
will become effective on the contract anniversary following your change. Any
changes on the contract anniversary will have the new fee effective on that
contract anniversary. Also, in the event you change your model portfolio or
investment option more than once in the same contract year (see "Portfolio
Navigator Program"), the fee we charge for this rider will be the greatest fee
applicable to any investment option which you have selected during the contract
year.



If you chose the elective step up, you will pay the fee in effect on the
valuation date we receive your written request to step up. If you chose an
elective step up on the first contract anniversary, any increase in fees we
charge for this rider for the step up will not become effective until the third
contract year. In the event of more than one change in model portfolio or
investment option and/or elective step up occurring in the same contract year,
the fee we charge for this rider will be the highest fee applicable to any of
these changes.


The fee does not apply after annuity payouts begin.

SECURESOURCE RIDER FEE

We charge an annual fee based on the greater of the contract anniversary value
or the total Remaining Benefit Amount (RBA)(1) for this optional feature only if
you select it(2) as follows:

-    SecureSource -- Single Life rider, 0.90%(3);

-    SecureSource -- Joint Life rider, 1.15%(3)

We deduct the fee from your contract value on your contract anniversary. We
prorate this fee among the subaccounts and the regular fixed account (if
applicable) in the same proportion as your interest in each bears to your total
contract value, less any amounts invested in the GPAs and in the Special DCA
fixed account. Such fee is only deducted from GPAs and any Special DCA fixed
account if insufficient amounts are available in the regular fixed account and
the subaccounts. The fee will only be deducted from the subaccounts in
Washington. We will modify this approach to comply with state regulations where
necessary.

Once you elect the SecureSource rider, you may not cancel it and the fee will
continue to be deducted until the contract or rider is terminated, or the
contract value reduces to zero. If the contract or rider is terminated for any
reason, we will deduct the fee, adjusted for the number of calendar days
coverage was in place since we last deducted the fee. If the RBA reduces to zero
but the contract value has not been depleted, you will continue to be charged.


Currently the SecureSource rider charge does not vary with the PN model
portfolio or investment option selected; however, we reserve the right to
increase this charge and/or charge a separate rider charge for each model
portfolio or investment option.




The SecureSource -- Single Life rider charge will not exceed a maximum charge of
2.00%(3). The SecureSource -- Joint Life rider charge will not exceed a maximum
charge of 2.50%(3).

We will not change the SecureSource rider charge after the rider effective date
unless:


(a)  you choose the annual elective step up after we have exercised our rights
     to increase the rider charge. However, if you choose to exercise the annual
     elective step up before the end of the waiting period, the SecureSource
     rider charge will not change until the end of the waiting period. The
     charge will be based on the charge in effect on the valuation date we
     received your last written request to exercise the elective annual step up
     or to elect to change your PNN model portfolio or investment option;


(b)  you choose the elective spousal continuation step up after we have
     exercised our rights to increase the rider charge;


(c)  you elect to change your PN program investment option (or change from a
     model portfolio to an investment option under the PN program) after we have
     exercised our rights to increase the rider charge;



(d)  you elect to change your PN program investment option (or change from a
     model portfolio to an investment option under the PN program) after we have
     exercised our rights to charge a separate rider charge for each model
     portfolio or investment option.



If you choose the elective step up, choose the elective spousal continuation
step up, change your PN program investment option, or change from a model
portfolio to an investment option as described above, you will pay the charge
that is in effect on the valuation date we receive your written request to step
up or change your PN model portfolio or investment option. On the next contract
anniversary, we will calculate an average rider charge, for the preceding
contract year only, that reflects the various different charges that were in
effect that year, adjusted for the number of calendar days each charge was in
effect.


The fee does not apply after annuity payouts begin.

(1)  In Washington, the fee is based on the greater of the variable account
     contract value or the RBA less amounts invested in the fixed account.


(2)  For Single Life, available if you are 80 or younger at the rider effective
     date. For Joint Life, available if you and your spouse are 80 or younger at
     the rider effective date. You must select or have selected a PN program
     model portfolio or investment option with this rider (see "Portfolio
     Navigator Program"). Not available with the Accumulation Benefit rider.


(3)  For contracts purchased prior to Jan. 26, 2009, the following charges
     apply:

     -    the current charge for Single Life rider is 0.65% and for Joint Life
          rider is 0.85%, and

     -    the maximum charge for Single Life rider is 1.50% and for Joint Life
          rider is 1.75%.

ROPP RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.20% of your contract value on your contract
anniversary at the end of each contract year. We prorate this fee among the
subaccounts and regular fixed account in the same proportion your interest in
each account bears to your total contract value, less amounts invested in the
GPAs and the Special DCA fixed account. Such fee is only deducted from GPAs and
any Special DCA fixed account if insufficient amounts are available in the
regular fixed account and the subaccounts. In this case, we prorate the fee
among all accounts in the same proportion your interest in each account bears to
your total contract value. We reserve the right to increase the fee for this
rider after the tenth rider anniversary to a maximum of 0.30%.

If the contract is terminated for any reason, we will deduct the charge from
your contract value at that time, adjusted for the number of calendar days
coverage was in effect during the year.



(1)  Available if you are 76 or older at the rider effective date. ROPP is
     included in the standard death benefit if you are age 75 or younger on the
     contract effective date at no additional cost.

MAV RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.25% of your contract value on your contract
anniversary at the end of each contract year. We prorate this fee among the
subaccounts and regular fixed account in the same proportion your interest in
each account bears to your total contract value, less amounts invested in the
GPAs and the Special DCA fixed account. Such fee is only deducted from GPAs and
any Special DCA fixed account if insufficient amounts are available in the
regular fixed account and the subaccounts. In this case, we prorate the fee
among all accounts in the same proportion your interest in each account bears to
your total contract value. We reserve the right to increase the fee for this
rider after the tenth rider anniversary to a maximum of 0.35%.

If the contract is terminated for any reason, we will deduct the charge from
your contract value at that time, adjusted for the number of calendar days
coverage was in effect during the year.

(1)  Available if you are 75 or younger at the rider effective date. Not
     available with the 5-Year MAV.

5-YEAR MAV RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.10% of your contract value on your contract
anniversary at the end of each contract year. We prorate this fee among the
subaccounts and regular fixed account in the same proportion your interest in
each account bears to your total contract value, less amounts invested in the
GPAs and the Special DCA fixed account. Such fee is only deducted from GPAs and
any Special DCA fixed account if insufficient amounts are available in the
regular fixed account and the subaccounts. In this case, we prorate the fee
among all accounts in the same proportion your interest in each account bears to
your total contract value. We reserve the right to increase the fee for this
rider after the tenth rider anniversary to a maximum of 0.20%.

If the contract is terminated for any reason, we will deduct the charge from
your contract value at that time, adjusted for the number of calendar days
coverage was in effect during the year.

(1)  Available if you are 75 or younger at the rider effective date. Not
     available with the MAV.

EEB RIDER FEE

We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.30% of your contract value on your contract
anniversary at the end of each contract year. We prorate this fee among the
subaccounts and regular fixed accounts in the same proportion your interest in
each account bears to your total contract value, less amounts invested in the
GPAs and the Special DCA fixed account. Such fee is only deducted from GPAs and
any Special DCA fixed account if insufficient amounts are available in the
regular fixed account and the subaccounts. In this case, we prorate the fee
among all accounts in the same proportion your interest in each account bears to
your total contract value. We reserve the right to increase the fee for this
rider after the tenth rider anniversary to a maximum of 0.40%.

If the contract is terminated for any reason, we will deduct the charge from
your contract value at that time, adjusted for the number of calendar days
coverage was in effect during the year.

(1)  Available if you are 75 or younger at the rider effective date. Not
     available with EEP. May not be available in all states.

EEP RIDER FEE



We charge a fee for this optional feature only if you select it.(1) If selected,
we deduct an annual fee of 0.40% of your contract value on your contract
anniversary at the end of each contract year. We prorate this fee among the
subaccounts and regular fixed accounts in the same proportion your interest in
each account bears to your total contract value, less amounts invested in the
GPAs and the Special DCA fixed account. Such fee is only deducted from GPAs and
any Special DCA fixed account if insufficient amounts are available in the
regular fixed account and the subaccounts. In this case, we prorate the fee
among all accounts in the same proportion your interest in each account bears to
your total contract value. We reserve the right to increase the fee for this
rider after the tenth rider anniversary to a maximum of 0.50%.

If the contract is terminated for any reason, we will deduct the charge from
your contract value at that time, adjusted for the number of calendar days
coverage was in effect during the year.

(1)  Available if you are 75 or younger at the rider effective date. Not
     available with EEB. May not be available in all states. EEP is only
     available on contracts purchased through a direct transfer or exchange of
     another annuity or a life insurance policy.

RIDER COMBINATION DISCOUNT

A fee discount of 0.05% applies if you purchase the 5-Year MAV with either the
EEB or EEP. A fee discount of 0.10% applies if you purchase the MAV with either
the EEB or EEP.

FUND FEES AND EXPENSES

There are deductions from and expenses paid out of the assets of the funds that
are described in the prospectuses for those funds. (See "Annual Operating
Expenses of the Funds.")

PREMIUM TAXES

Certain state and local governments impose premium taxes on us (up to 3.5%).
These taxes depend upon your state of residence or the state in which the
contract was sold. Currently, we deduct any applicable premium tax when annuity
payouts begin, but we reserve the right to deduct this tax at other times such
as when you surrender your contract.

VALUING YOUR INVESTMENT

We value your accounts as follows:

GPA

We value the amounts you allocate to the GPA directly in dollars. The GPA value
equals:

-    the sum of your purchase payments and purchase payment credits allocated to
     the GPA;

-    plus any amounts transferred to the GPA from the regular fixed account or
     subaccounts;

-    plus interest credited;

-    minus any amounts transferred from the GPA to the regular fixed account or
     any subaccount;

-    minus any amounts deducted for charges or surrenders;

-    plus or minus any applicable MVA; and/or

-    minus any remaining portion of fees where the values of the regular fixed
     account and the subaccounts are insufficient to cover those fees.

REGULAR FIXED ACCOUNT



We value the amounts you allocate to the regular fixed account directly in
dollars. The regular fixed account value equals:

-    the sum of your purchase payments and purchase payment credits and transfer
     amounts allocated to the regular fixed account;

-    plus interest credited;

-    minus the sum of amounts surrendered (including any applicable surrender
     charges) and amounts transferred out;

-    minus any prorated portion of the contract administrative charge;

-    minus any prorated portion of the ROPP rider fee (if selected);

-    minus any prorated portion of the MAV rider fee (if selected);

-    minus any prorated portion of the 5-Year MAV rider fee (if selected);

-    minus any prorated portion of the EEB rider fee (if selected);

-    minus any prorated portion of the EEP rider fee (if selected);

-    minus any prorated portion of the Accumulation Benefit rider fee (if
     selected)*;

-    minus any prorated portion of the GWB for Life rider fee (if selected)*;
     and

-    minus any prorated portion of the SecureSource rider fee (if selected)*.

*    The fee can only be deducted from the subaccounts in Washington.

SPECIAL DCA FIXED ACCOUNT

We value the amounts you allocate to the Special DCA fixed account directly in
dollars. The Special DCA fixed account value equals:

-    the sum of your purchase payments and purchase payment credits allocated to
     the Special DCA fixed account;

-    plus interest credited;

-    minus the sum of amounts surrendered (including any applicable surrender
     charges);

-    minus amounts transferred out; and

-    minus any remaining portion of fees where the values of the regular fixed
     account and the subaccounts are insufficient to cover those fees.

SUBACCOUNTS

We convert amounts you allocated to the subaccounts into accumulation units.
Each time you make a purchase payment or transfer amounts into one of the
subaccounts or we apply any purchase payment credits to a subaccount, we credit
a certain number of accumulation units to your contract for that subaccount.
Conversely, we subtract a certain number of accumulation units from your
contract each time you take a partial surrender, transfer amounts out of a
subaccount, or we assess a contract administrative charge, a surrender charge or
fee for any optional riders with annual charges (if applicable).

The accumulation units are the true measure of investment value in each
subaccount during the accumulation period. They are related to, but not the same
as, the net asset value of the fund in which the subaccount invests. The dollar
value of each accumulation unit can rise or fall daily depending on the variable
account expenses, performance of the fund and on certain fund expenses. Here is
how we calculate accumulation unit values:



NUMBER OF UNITS: to calculate the number of accumulation units for a particular
subaccount we divide your investment by the current accumulation unit value.

ACCUMULATION UNIT VALUE: the current accumulation unit value for each subaccount
equals the last value times the subaccount's current net investment factor.

WE DETERMINE THE NET INVESTMENT FACTOR BY:

-    adding the fund's current net asset value per share, plus the per share
     amount of any accrued income or capital gain dividends to obtain a current
     adjusted net asset value per share; then

-    dividing that sum by the previous adjusted net asset value per share; and

-    subtracting the percentage factor representing the mortality and expense
     risk fee from the result.

Because the net asset value of the fund may fluctuate, the accumulation unit
value may increase or decrease. You bear all the investment risk in a
subaccount.



FACTORS THAT AFFECT SUBACCOUNT ACCUMULATION UNITS: accumulation units may change
in two ways -- in number and in value.

The number of accumulation units you own may fluctuate due to:

-    additional purchase payments you allocate to the subaccounts;

-    any purchase payment credits allocated to the subaccounts;

-    transfers into or out of the subaccounts;

-    partial surrenders;

-    surrender charges;

and a deduction of a prorated portion of:

-    the contract administrative charge;

-    the ROPP rider fee (if selected);

-    the MAV rider fee (if selected);

-    the 5-Year MAV rider fee (if selected);

-    the EEB rider fee (if selected);

-    the EEP rider fee (if selected);

-    the Accumulation Benefit rider fee (if selected);

-    the GWB for Life rider fee (if selected); and/or

-    the SecureSource rider fee (if selected).

Accumulation unit values will fluctuate due to:

-    changes in fund net asset value;

-    fund dividends distributed to the subaccounts;

-    fund capital gains or losses;

-    fund operating expenses; and/or

-    mortality and expense risk fees.

MAKING THE MOST OF YOUR CONTRACT

AUTOMATED DOLLAR-COST AVERAGING

Currently, you can use automated transfers to take advantage of dollar-cost
averaging (investing a fixed amount at regular intervals). For example, you
might transfer a set amount monthly from a relatively conservative subaccount to
a more aggressive one, or to several others, or from the regular fixed account
to one or more subaccounts. Automated transfers from the regular fixed account
to the subaccounts under automated dollar-cost averaging may not exceed an
amount that, if continued, would deplete the regular fixed account within 12
months. You may not set up an automated transfer to or from the GPAs. You may
not set up an automated transfer to the regular fixed account or the Special DCA
fixed account. You may not set up an automated transfer if the GWB for Life,
SecureSource, Accumulation Benefit, or PN program is selected. There is no
charge for dollar-cost averaging.



This systematic approach can help you benefit from fluctuations in accumulation
unit values caused by fluctuations in the market values of the funds. Since you
invest the same amount each period, you automatically acquire more units when
the market value falls and fewer units when it rises. The potential effect is to
lower your average cost per unit.

HOW DOLLAR-COST AVERAGING WORKS



                                                                           NUMBER
BY INVESTING AN EQUAL NUMBER                     AMOUNT    ACCUMULATION   OF UNITS
OF DOLLARS EACH MONTH ...               MONTH   INVESTED    UNIT VALUE    PURCHASED
----------------------------            -----   --------   ------------   ---------
                                                           
                                        Jan      $  100       $  20         5.00
                                        Feb         100          18         5.56
you automatically buy                   Mar         100          17         5.88
more units when the            (ARROW)  Apr         100          15         6.67
per unit market price is low            May         100          16         6.25
                                        June        100          18         5.56
                                        July        100          17         5.88
and fewer units                         Aug         100          19         5.26
when the per unit              (ARROW)  Sept        100          21         4.76
market price is high.                   Oct         100          20         5.00


You paid an average price of $17.91 per unit over the 10 months, while the
average market price actually was $18.10.

Dollar-cost averaging does not guarantee that any subaccount will gain in value
nor will it protect against a decline in value if market prices fall. Because
dollar-cost averaging involves continuous investing, your success will depend
upon your willingness to continue to invest regularly through periods of low
price levels. Dollar-cost averaging can be an effective way to help meet your
long-term goals. For specific features contact your financial advisor.

SPECIAL DOLLAR-COST AVERAGING (SPECIAL DCA) PROGRAM

If your purchase payment is at least $10,000, you can choose to participate in
the Special DCA program (if available). There is no charge for the Special DCA
program. Under the Special DCA program, you can allocate a new purchase payment
and any applicable purchase payment credit to a six-month Special DCA fixed
account according to the following rules:

-    You may only allocate a new purchase payment of at least $10,000 to a
     Special DCA fixed account.

-    You cannot transfer existing contract values into a Special DCA fixed
     account.

-    Each Special DCA arrangement consists of six monthly transfers that begin
     seven days after we receive your purchase payment.


-    We make monthly transfers of your Special DCA fixed account value into the
     subaccounts or PN program model portfolio you have selected.


-    You may not use the regular fixed account, GPA account, or the Special DCA
     fixed account as a destination for the Special DCA monthly transfer.
     (Exception: if a PN program is in effect, and the model portfolio you have
     selected includes the regular fixed account, amounts will be transferred
     from the Special DCA fixed account to the regular fixed account according
     to the allocation percentage established for the model portfolio you have
     selected.)

-    We will change the interest rate on each Special DCA fixed account from
     time to time at our discretion based on factors that include the
     competition and the interest rate we are crediting to the regular fixed
     account at the time of the change. From time to time, we may credit
     interest to the Special DCA fixed account at promotional rates that are
     higher than those we credit to the regular fixed account.

-    We credit each Special DCA fixed account with the current guaranteed annual
     rate that is in effect on the date we receive your purchase payment.
     However, we credit this annual rate over the length of the Special DCA
     arrangement on the balance remaining in your Special DCA fixed account.
     Therefore, the net effective interest rate you receive is less than the
     stated annual rate.

-    We do not credit this interest after we transfer the value out of the
     Special DCA fixed account into the accounts you selected.



-    Once you establish a Special DCA fixed account, you cannot allocate
     additional purchase payments to it. However, you may establish another new
     Special DCA fixed account and allocate new purchase payments to it.

-    Fundings from multiple sources are treated as individual purchase payments
     and a new Special DCA fixed account is opened for each payment (if the
     Special DCA fixed accounts are available on the valuation date we receive
     your payment).


-    You may terminate your participation in the Special DCA program at any
     time. If you do, for RAVA 4 Advantage and RAVA 4 Select, we will transfer
     the remaining balance from your Special DCA fixed account to the regular
     fixed account, if no other specification is made. Interest will be credited
     according to the rates in effect on the regular fixed account and not the
     rate that was in effect on the Special DCA fixed account. For RAVA 4
     Access, we will transfer the remaining balance from your Special DCA fixed
     account to variable subaccounts you specified in your termination request,
     or if no specification is made, according to your current purchase payment
     allocation. (Exception: if you have selected a PN program model portfolio
     when you elect to end your participation in the Special DCA program, we
     will transfer the remaining balance to the model portfolio you have
     selected).


-    We can modify the terms of the Special DCA program at any time. Any
     modifications will not affect any purchase payments that are already in a
     Special DCA fixed account. For more information on the Special DCA program,
     contact your financial advisor.

The Special DCA program does not guarantee that any subaccount will gain in
value nor will it protect against a decline in value if market prices fall.
Because dollar-cost averaging involves continuous investing, your success will
depend upon your willingness to continue to invest regularly through periods of
low price levels. Dollar-cost averaging can be an effective way to help meet
your long-term goals.

ASSET REBALANCING

You can ask us in writing to have the variable subaccount portion of your
contract value allocated according to the percentages (in tenth of a percent
amounts) that you choose. We automatically will rebalance the variable
subaccount portion of your contract value either quarterly, semi-annually, or
annually. The period you select will start to run on the date we record your
request. On the first valuation date of each of these periods, we automatically
will rebalance your contract value so that the value in each subaccount matches
your current subaccount percentage allocations. These percentage allocations
must be in numbers with no more than one digit past the decimal. Asset
rebalancing does not apply to the GPAs, regular fixed account or the Special DCA
fixed account. There is no charge for asset rebalancing. The contract value must
be at least $2,000.

You can change your percentage allocations or your rebalancing period at any
time by contacting us in writing. We will restart the rebalancing period you
selected as of the date we record your change. You also can ask us in writing or
by any other method acceptable to us, to stop rebalancing your contract value.
You must allow 30 days for us to change any instructions that currently are in
place. For more information on asset rebalancing, contact your financial
advisor.


Different rules apply to asset rebalancing under the Portfolio Navigator program
(see "Portfolio Navigator Program" below).



PORTFOLIO NAVIGATOR PROGRAM (PN PROGRAM)



THE FOLLOWING INFORMATION ABOUT THE PN PROGRAM APPLIES TO ALL CONTRACTS. FOR
ADDITIONAL INFORMATION ABOUT THE PN PROGRAM FOR CONTRACTS PURCHASED BEFORE MAY
10, 2010, ALSO SEE BELOW "PORTFOLIO NAVIGATOR PROGRAM (PN PROGRAM) FOR CONTRACTS
PURCHASED BEFORE MAY 10, 2010."



The PN program is available for nonqualified annuities and for qualified
annuities. The PN program allows you to allocate your contract value to a PN
program investment option. The PN program investment options are currently five
funds of funds, each of which has a particular investment objective and invests
in underlying funds. The PN program also allows those who participated in the PN
program and who exercised an "opt-out" right applicable through April 23, 2010
(to be in this group, you must have purchased your contract on or before April
23, 2010) to remain invested in a "static" PN program model portfolio (not
subject to further updating or reallocation, as described under "Portfolio
Navigator Program (PN program) for contracts purchased before May 10, 2010").




You are required to participate in the PN program if your contract includes an
optional Accumulation Benefit rider, GWB for Life or SecureSource rider. If your
contract does not include one of these riders, you also may elect to participate
in the PN program at no additional charge. You should review any PN program
information, including the terms of the PN program, carefully. Your financial
advisor can provide you with additional information and can answer questions you
may have on the PN program.


Each of the PN program fund of funds investment options has the investment
objective of seeking a high level of total return consistent with a certain
level of risk by investing in various underlying funds. RiverSource Investments
is the investment adviser of each of the PN program investment options, but does
not serve as investment adviser under the PN program (regardless of whether you
have selected a PN program investment option or remained in a model portfolio).
Morningstar Associates, LLC serves as an independent consultant to RiverSource
Investments to provide recommendations regarding portfolio construction and
ongoing analysis of the PN program investment options, but does not provide any
services in connection with the model portfolios. RiverSource Investments or an
affiliate will serve as investment adviser for all of the underlying funds in
which the investment options invest. However, some of the underlying funds will
be managed on a day-to-day basis directly by RiverSource Investments and some
will be managed by one or more affiliated or unaffiliated sub-advisers, subject
to the oversight of RiverSource Investments and the fund's board of trustees.
The new funds of funds have objectives ranging from Conservative to Aggressive,
and are managed within asset class allocation targets and with a broad
multi-manager approach.



Below are the asset allocation weights (between equity and fixed income/cash
underlying funds) for each of the funds of funds:



1. Variable Portfolio - Aggressive Portfolio: 80% Equity / 20% Fixed Income



2. Variable Portfolio - Moderately Aggressive Portfolio: 65% Equity / 35% Fixed
Income



3. Variable Portfolio - Moderate Portfolio: 50% Equity / 50% Fixed Income



4. Variable Portfolio - Moderately Conservative Portfolio: 35% Equity / 65%
Fixed Income



5. Variable Portfolio - Conservative Portfolio: 20% Equity / 80% Fixed Income



POTENTIAL CONFLICTS OF INTEREST. In identifying the universe of investment
options and providing investment advisory services for the PN program investment
options and certain of the funds underlying the investment options and model
portfolios, RiverSource Investments is, together with its affiliates, including
us, subject to competing interests that may influence its decisions. These
competing interests typically arise because RiverSource Investments or one of
its affiliates serves as the investment adviser to the underlying funds invested
in by the investment options and to certain underlying funds to which assets are
allocated under the model portfolios, because we or an affiliate of ours may
provide other services in connection with such underling funds, and because the
compensation we and our affiliates receive for providing these investment
advisory and other services varies depending on the underlying fund. For
additional information about the conflicts of interest which RiverSource
Investments and its affiliates are subject to in connection with a PN program
investment option, see the prospectus for such investment option. For additional
information about the conflicts of interest which RiverSource Investments and
its affiliates are subject to in connection with a PN program model portfolio,
see "Portfolio Navigator Program (PN program) for contracts purchased before May
10, 2010."



PARTICIPATING IN THE PN PROGRAM. If you choose or are required to participate in
the PN program, you are responsible for determining which investment option is
best for you or whether to remain in a model portfolio or investment option.
Your financial advisor can help you make this determination. In addition, your
financial advisor may provide you with an investor questionnaire, a tool to help
define your investing style which is based on factors such as your investment
goals, your tolerance for risk and how long you intend to invest. Your responses
to the investor questionnaire can help you determine which model portfolio or
investment option most closely matches your investing style. While the scoring
of the investor questionnaire is objective, there is no guarantee that your
responses to the investor questionnaire accurately reflect your tolerance for
risk. Similarly, there is no guarantee that the investment option (or the asset
mix reflected in the model portfolio, if applicable) you select or selected
after completing the investor questionnaire is appropriate to your ability to
withstand investment risk. RiverSource Life is not responsible for your decision
to participate in the PN program, your selection of a specific investment option
or model portfolio, if applicable, or your decision to change to a different
investment option.



Currently, there are five PN program investment options, and five model
portfolios, ranging from conservative to aggressive. You may not use more than
investment option or model portfolio at a time. Each investment option is a fund
of funds. Each model portfolio





consists of subaccounts, the regular fixed account and/or any GPAs (if included)
according to the allocation percentages stated for the model portfolio. If you
are participating in the PN program in a model portfolio, you also instruct us
to automatically rebalance your contract value quarterly in order to maintain
alignment with these allocation percentages.



Special rules apply to the GPAs if they are included in a model portfolio. Under
these rules:



-    no MVA will apply when rebalancing occurs within a specific model portfolio
     (but an MVA may apply if you elect to transfer to a new investment option);



-    no MVA will apply when you elect an annuity payout plan while your contract
     value is invested in a model portfolio. (See "Guarantee Period Accounts --
     Market Value Adjustment.")



If you initially allocate qualifying purchase payments and applicable purchase
payment credits to the Special DCA fixed account, when available (see "The
Special DCA Fixed Account"), and you are participating in the PN program, we
will make monthly transfers in accordance with your instructions from the
Special DCA fixed account (and subaccounts we may choose to allow for DCA
arrangements which are not part of a model portfolio -- "excluded accounts")
into the investment option or model portfolio you have chosen.



You may request a change to your investment option (or a transfer from your
model portfolio to an investment option) up to twice per contract year by
written request on an authorized form or by another method agreed to by us. If
your contract includes an optional Accumulation Benefit, GWB for Life rider or
SecureSource rider and you make such a change, we may charge you a higher fee
for your rider. If your contract includes a Secure Source rider, we reserve the
right to limit the number of changes if required to comply with the written
instructions of a Fund (see "Market Timing"). If your contract includes the GWB
for Life rider or SecureSource rider, we reserve the right to limit the number
of investment options from which you can select, subject to state restrictions.



We reserve the right to change the terms and conditions of the PN program upon
written notice to you. This includes but is not limited to the right to:



-    limit your choice of investment options based on the amount of your initial
     purchase payment we accept or when you take a withdrawal;



-    cancel required participation in the program after 30 days written notice;



-    substitute a fund of funds for your model portfolio if permitted under
     applicable securities law; and



-    discontinue the PN program. We will give you 30 days' written notice of any
     such change.



RISKS. Asset allocation through the PN program does not guarantee that your
contract will increase in value nor will it protect against a decline in value
if market prices fall. By investment in a PN program investment option or in
accordance with a model portfolio, you may be able to reduce the volatility in
your contract value, but there is no guarantee that this will happen. For
additional information about the risks of investing in a PN program investment
option, see the prospectus for such investment option. For additional
information about the risks of investing in accordance with a PN program model
portfolio, see "Portfolio Navigator Program (PN program) for Contracts Purchased
before May 10, 2010" below.





PN PROGRAM UNDER THE ACCUMULATION BENEFIT RIDER, GWB FOR LIFE RIDER OR
SECURESOURCE RIDER



If you purchase the optional Accumulation Benefit rider, the optional GWB for
Life rider or the optional SecureSource rider, you are required to participate
in the PN program under the terms of each rider.



-    ACCUMULATION BENEFIT RIDER: You cannot terminate the Accumulation Benefit
     rider. As long as the Accumulation Benefit rider is in effect, your
     contract value must be invested in one of the investment options or model
     portfolios. For contracts purchased on or after Jan. 26, 2009, you cannot
     select the Aggressive investment option or model portfolio, or transfer to
     the Aggressive investment option while the rider is in effect. The
     Accumulation Benefit rider automatically ends at the end of the waiting
     period and you then have the option to cancel your participation in the PN
     program. At all other times, if you do not want to invest in any of the PN
     program investment options or invest in accordance with any of the model
     portfolios, you must terminate your contract by requesting a full
     surrender. Surrender charges and tax penalties may apply. THEREFORE, YOU
     SHOULD NOT SELECT THE ACCUMULATION BENEFIT RIDER IF YOU DO NOT INTEND TO
     CONTINUE PARTICIPATING IN THE PN PROGRAM (AS IT NOW EXISTS OR AS WE MAY
     MODIFY IT IN THE FUTURE) UNTIL THE END OF THE WAITING PERIOD.



-    GWB FOR LIFE OR SECURESOURCE RIDER: The GWB for Life or SecureSource rider
     requires that your contract value be invested in one of the investment
     options or model portfolios for the life of the contract. Subject to state
     restrictions, we reserve the right to limit the number of investment
     options or model portfolios from which you can select based on the dollar
     amount of purchase payments you make. Because you cannot terminate the GWB
     for Life or SecureSource rider once you have selected it, you must
     terminate your contract by requesting a full surrender if you do not want
     to invest in any of the PN program investment options or invest in
     accordance with any of the model portfolios. Surrender charges and tax
     penalties may apply. THEREFORE, YOU SHOULD NOT SELECT THE GWB FOR LIFE OR
     SECURESOURCE RIDER IF YOU DO NOT INTEND TO CONTINUE PARTICIPATING IN THE PN
     PROGRAM (AS IT NOW EXISTS OR AS WE MAY MODIFY IT IN THE FUTURE) FOR THE
     LIFE OF THE CONTRACT.



OPTIONAL PN PROGRAM



If you do not select the optional Accumulation Benefit rider, the optional GWB
for Life rider or an optional SecureSource rider with your contract, you may
elect to participate in the PN program by adding the optional PN program to your
contract at no additional charge. You can elect to participate in the PN program
at any time, and you may transfer all or part of your assets from a PN program
investment option or transfer your contract assets so that they are not invested
in accordance with a model portfolio at any time. If you transfer contract
assets so that they are no longer invested in accordance with a PN program model
portfolio or investment option, automated rebalancing associated with the model
portfolio or investment option will end.



PORTFOLIO NAVIGATOR PROGRAM (PN PROGRAM) FOR CONTRACTS PURCHASED BEFORE MAY 10,
2010



As of the Transfer Date (defined below), your contract assets invested in
accordance with a model portfolio under the PN program will be transferred based
on the recommendation of RiverSource Investments, LLC ("RiverSource
Investments"), the investment adviser under the PN program, to a fund of funds
investment option that corresponds to your model portfolio unless you informed
us on or before April 23, 2010 that you did not want your assets so transferred
(unless you "opt out"). The actual date of transfer to the fund of funds or the
date upon which your opt out becomes effective (the "Transfer Date") will occur
no earlier than May 7, 2010 and no later than June 30, 2010, and will depend on
the contract you own and the month that you purchased your contract. If you opt
out of the transfer, you will remain invested in accordance with the asset
allocation currently specified for your model portfolio and you will not receive
any further reallocation recommendations from RiverSource Investments (although
your assets will be rebalanced back to the current allocation quarterly). As of
the Transfer Date, RiverSource Investments will no longer review the model
portfolios or make changes to them as part of the PN program, and the investment
advisory agreement you have previously entered into with RiverSource Investments
will terminate.



If you have chosen to remain invested in a "static" PN program model portfolio,
your assets will remain invested in accordance with your current model
portfolio, and you will not be provided with any future updates to the model
portfolio or reallocation recommendations. If you own a contract with a living
benefit rider which requires you to participate in the PN program and have
chosen to remain in a PN program model portfolio, you may in the future transfer
the assets in your contract only to one of the new fund of funds investment
options. If you begin taking income from your contract and have living benefit
rider that requires a move to a certain model portfolio or investment option
once you begin taking income, you will be transferred to a fund of funds that
corresponds to that model portfolio.



RiverSource Investments and its affiliates have committed to a two-year cap on
PN program investment option expenses for contract owners who purchased a
contract before May 10, 2010, as set forth in disclosure previously sent to such
contract owners. Specifically,





expense waivers and reimbursements will be applied to the PN program investment
options and to the underlying funds so that total fees and expenses paid by
investors in the PN program investment options will approximate the total fees
and expenses of the underlying funds borne by participants in the corresponding
PN program model portfolio, based on 2009 fiscal year end expenses. After two
years these expense caps will no longer be in place and total expenses will
likely be higher.



SERVICE PROVIDERS IN CONNECTION WITH THE PN PROGRAM MODEL PORTFOLIOS.
RiverSource Investments, an affiliate of ours, has served as non-discretionary
investment adviser for PN program model portfolio participants solely in
connection with the development of the model portfolios and periodic updates of
the model portfolios. In this regard, RiverSource Investments has entered into
an investment advisory agreement with each contract owner participating in the
PN program prior to the program changes described in this prospectus. In its
role as investment adviser to the PN program, RiverSource Investments relied
upon the recommendations of a third party service provider. In developing and
updating the model portfolios, RiverSource Investments reviewed the
recommendations, and the third party's rationale for the recommendations, with
the third party service provider. RiverSource Investments also conducted
periodic due diligence and provided ongoing oversight with respect to the
process utilized by the third party service provider. For more information on
RiverSource Investment's role as investment adviser for the PN program, please
see the Portfolio Navigator Asset Allocation Program Investment Adviser
Disclosure Document, which is based on Part II of RiverSource Investment's Form
ADV, the SEC investment adviser registration form. The Disclosure Document was
delivered to contract owners enrolled in the PN program prior to May 10, 2010 at
or before the time they enrolled.



The PN program model portfolios were designed and periodically updated for
RiverSource Investments by Morningstar Associates, LLC, a registered investment
adviser and wholly-owned subsidiary of Morningstar, Inc.



The criteria used in developing and updating the model portfolios do not
guarantee or predict future performance. Neither Morningstar Associates nor
RiverSource Investments, in connection with their respective roles, provided or
provides any individualized investment advice to contract owners regarding the
application of a particular model portfolio to his or her circumstances.
Contract owners are solely responsible for determining whether any model
portfolio is appropriate.



We identified to Morningstar Associates the universe of allocation options that
could be included in the model portfolios (the universe of allocation options).
Once we identified this universe of allocation options to Morningstar
Associates, neither RiverSource Investments, nor any of its affiliates,
including us, dictated to Morningstar Associates the number of allocation
options that should be included in a model portfolio, the percentage that any
allocation option represents in a model portfolio, or whether a particular
allocation option may be included in a model portfolio. However, as described
below under "Potential conflict of interest", there are certain conflicts of
interest associated with RiverSource Investments and its affiliates' influence
over the development and updating of the model portfolios.



POTENTIAL CONFLICT OF INTEREST. Although RiverSource Investment will no longer
maintain the models portfolios on an ongoing basis, the asset allocations in the
current model portfolios may have been affected by the following conflicts of
interest.



In identifying the universe of allocation options for a model portfolio, we and
our affiliates, including RiverSource Investments, were subject to competing
interests that may have influenced the allocation options we proposed. These
competing interests involve compensation that RiverSource Investments or its
affiliates may receive as the investment adviser to certain underlying funds in
the model portfolios as well as compensation we or an affiliate of ours may
receive for providing services in connection with such underlying funds or their
corresponding sub-accounts. These competing interests also involve compensation
we or an affiliate of ours receive if certain funds that RiverSource Investments
does not advise were included as underlying funds in model portfolios. The
inclusion of funds that pay compensation to RiverSource Investments or an
affiliate may have a positive or negative impact on performance.



As an affiliate of RiverSource Investments, we had an incentive to identify the
RiverSource Variable Series Trust funds for





consideration as part of a model portfolio over unaffiliated funds. In addition,
RiverSource Investments, in its capacity as investment adviser to the
RiverSource Variable Series Trust funds, monitors the performance of the
RiverSource Variable Series Trust funds. In this role RiverSource Investments
may, from time to time, have recommended certain changes to the board of
directors of the RiverSource Variable Series Trust funds. These changes may have
included a change in portfolio management or fund strategy or the closure or
merger of a RiverSource Variable Series Trust fund. RiverSource Investments also
may have believed that certain RiverSource Variable Series Trust funds would
have benefited from additional assets or could have been harmed by redemptions.
All of these factors may have impacted RiverSource Investment's view regarding
the composition and allocation of a model portfolio.



RiverSource Investments' role as investment adviser to the PN program in
connection with the development and updating of the model portfolios, and our
identification of the universe of allocation options to Morningstar Associates
for consideration, may have influenced the allocation of assets to or away from
allocation options that are affiliated with, or managed or advised by
RiverSource Investments or its affiliates.



We, RiverSource Investments, or another affiliate of ours may receive higher
compensation from certain unaffiliated funds that RiverSource Investments does
not advise or manage. (See "Expense Summary -- Annual Operating Expenses of the
Funds" and "The Variable Account and the Funds -- The Funds.") Therefore, we may
have had an incentive to identify these unaffiliated funds to Morningstar
Associates for inclusion in the model portfolios. In addition, we or an
affiliate of ours may receive higher compensation from certain GPAs or the
regular fixed account than from other allocation options. We therefore may have
had an incentive to identify these allocation options to Morningstar Associates
for inclusion in the model portfolios.



Some officers and employees of RiverSource Investments are also officers or
employees of us or our affiliates which may be involved in, and/or benefit from,
your participation in the PN program. These officers and employees may had have
an incentive to make recommendations, or take actions, that benefit one or more
of the entities they represent, rather than participants in the PN program.






MODEL PORTFOLIO RISKS. Asset allocation through a PN program model portfolio
does not guarantee that your contract will increase in value nor will it protect
against a decline in value if market prices fall.


By spreading your contract value among various allocation options under the PN
program, you may be able to reduce the volatility in your contract value, but
there is no guarantee that this will happen. Although each model portfolio is
intended to optimize returns given various levels of risk tolerance, a model
portfolio may not perform as intended. A model portfolio, the allocation options
and market performance may differ in the future from historical performance and
from the assumptions upon which the model portfolio is based, which could cause
the model portfolio to be ineffective or less effective in reducing volatility.




In the future, the model portfolios will not be updated periodically, and the
investments and investment styles and policies of the current allocation options
may change. Accordingly, your model portfolio may change so that it is no longer
appropriate for your needs. Furthermore, the absence of periodic updating means
that existing allocation options will not be replaced as may be appropriate due
to poor performance, changes in management personnel, or other factors.


Investment performance of your contract value could be better or worse by
participating in the PN program than if you had not participated. A model
portfolio may perform better or worse than any single fund or allocation option
or any other combination of funds or allocation options. The performance of a
model portfolio depends on the performance of the component funds. In addition,
the timing of your investment and automatic rebalancing may affect performance.


Quarterly rebalancing of the model portfolios can cause their component funds to
incur transactional expenses to raise cash for money flowing out of the funds or
to buy securities with money flowing into the funds. Moreover, a large outflow
of money from the funds may increase the expenses attributable to the assets
remaining in the funds. These expenses can adversely affect the performance of
the relevant funds and of the model portfolios. In addition, when a particular
fund needs to buy or sell securities due to quarterly rebalancing of a model
portfolio, it may hold a large cash position. A large cash position could
detract from the achievement of the fund's investment objective in a period of
rising market prices; conversely, a large cash position would reduce the fund's
magnitude of loss in the event of falling market prices and provide the fund
with liquidity to make additional investments or to meet redemptions. (See also
the description of competing interests in the section titled "Service Providers
to the PN Program" above.) For additional information regarding the risks of
investing in a particular fund, see that fund's prospectus.







TRANSFERRING AMONG ACCOUNTS


The transfer rights discussed in this section do not apply while a PN model
portfolio or investment option is in effect.


You may transfer contract value from any one subaccount, GPAs or the regular
fixed account, to another subaccount before annuity payouts begin. For RAVA 4
Advantage and RAVA 4 Select contracts, certain restrictions apply to transfers
involving the GPAs and the regular fixed account. For RAVA 4 Access contracts,
you cannot transfer to the regular fixed account unless it is included in the PN
program model portfolio that you selected.

When your request to transfer will be processed depends on when we receive it:

-    If we receive your transfer request at our corporate office in good order
     before the close of business, we will process your transfer using the
     accumulation unit value we calculate on the valuation date we received your
     transfer request.

-    If we receive your transfer request at our corporate office in good order
     at or after the close of business, we will process your transfer using the
     accumulation unit value we calculate on the next valuation date after we
     received your transfer request.

There is no charge for transfers. Before making a transfer, you should consider
the risks involved in changing investments. Transfers out of the GPAs will be
subject to an MVA if done more than 30 days before the end of the guarantee
period.

We may suspend or modify transfer privileges at any time, subject to state
regulatory requirements.

For information on transfers after annuity payouts begin, see "Transfer
policies" below.



TRANSFER POLICIES
FOR RAVA 4 ADVANTAGE AND RAVA 4 SELECT

-    Before annuity payouts begin, you may transfer contract values between the
     subaccounts, or from the subaccounts to the GPAs and regular fixed account
     at any time. The amount transferred to any GPA must be at least $1,000.
     However, if you made a transfer from the regular fixed account to the
     subaccounts or the GPAs, you may not make a transfer from any subaccount or
     GPA back to the regular fixed account until the next contract anniversary.
     We reserve the right to limit transfers to the regular fixed account if the
     interest rate we are then currently crediting to the regular fixed account
     is equal to the minimum interest rate stated in the contract.

-    You may transfer contract values from the regular fixed account to the
     subaccounts or the GPAs once a year during a 31-day transfer period
     starting on each contract anniversary (except for automated transfers,
     which can be set up at any time for certain transfer periods subject to
     certain minimums). Transfers from the regular fixed account are not subject
     to an MVA. Currently, transfers out of the regular fixed account are
     limited to the greater of: a) 30% of the regular fixed account value at the
     beginning of the contract year, or b) the amount transferred out of the
     regular fixed account in the previous contract year, excluding any
     automated transfer amounts. If an automated dollar-cost averaging
     arrangement is established within 30 days of contract issue, the 30%
     limitation does not apply to transfers made from the regular fixed account
     to the subaccounts for the duration of this initial arrangement.

-    You may transfer contract values from any GPA to the subaccounts, regular
     fixed account or other GPA any time after 60 days of transfer or payment
     allocation into such GPA. Transfers made more than 30 days before the end
     of the guarantee period will receive an MVA, which may result in a gain or
     loss of contract value, unless an exception applies (see "The Guarantee
     Period Accounts (GPAs) -- Market Value Adjustment (MVA)").

-    If we receive your request within 30 days before the contract anniversary
     date, the transfer from the regular fixed account to the subaccounts will
     be effective on the anniversary.

-    If we receive your request on or within 30 days after the contract
     anniversary date, the transfer from the regular fixed account to the
     subaccounts or GPAs will be effective on the valuation date we receive it.

-    We will not accept requests for transfers from the regular fixed account at
     any other time.

-    You may not make a transfer to the Special DCA fixed account.

-    Once annuity payouts begin, you may not make transfers to or from the GPAs
     or the regular fixed account, but you may make transfers once per contract
     year among the subaccounts. During the annuity payout period, you cannot
     invest in more than five subaccounts at any one time unless we agree
     otherwise. When annuity payments begin, you must transfer all contract
     value out of any GPAs and Special DCA fixed account.

FOR RAVA 4 ACCESS

-    Before annuity payouts begin, you may transfer contract values between the
     subaccounts, or from the subaccounts to the GPAs at any time. The amount
     transferred to any GPA must be at least $1,000.


-    You may not make a transfer to the regular fixed account unless it is part
     of a model portfolio in which you have elected to participate.


-    You may transfer contract values from any GPA to the subaccounts, or other
     GPA any time after 60 days of transfer or payment allocation into such GPA.
     Transfers made more than 30 days before the end of the guarantee period
     will receive an MVA, which may result in a gain or loss of contract value,
     unless an exception applies (see "The Guarantee Period Accounts (GPAs) --
     Market Value Adjustment (MVA)").

-    You may not make a transfer to the Special DCA fixed account.



-    Once annuity payouts begin, you may not make transfers to or from the GPAs,
     but you may make transfers once per contract year among the subaccounts.
     During the annuity payout period, you cannot invest in more than five
     subaccounts at any one time unless we agree otherwise. When annuity
     payments begin, you must transfer all contract value out of any GPAs and
     Special DCA fixed account.

MARKET TIMING

Market timing can reduce the value of your investment in the contract. If market
timing causes the returns of an underlying fund to suffer, contract value you
have allocated to a subaccount that invests in that underlying fund will be
lower, too. Market timing can cause you, any joint owner of the contract and
your beneficiary(ies) under the contract a financial loss.

WE SEEK TO PREVENT MARKET TIMING. MARKET TIMING IS FREQUENT OR SHORT-TERM
TRADING ACTIVITY. WE DO NOT ACCOMMODATE SHORT-TERM TRADING ACTIVITIES. DO NOT
BUY A CONTRACT IF YOU WISH TO USE SHORT-TERM TRADING STRATEGIES TO MANAGE YOUR
INVESTMENT. THE MARKET TIMING POLICIES AND PROCEDURES DESCRIBED BELOW APPLY TO
TRANSFERS AMONG THE SUBACCOUNTS WITHIN THE CONTRACT. THE UNDERLYING FUNDS IN
WHICH THE SUBACCOUNTS INVEST HAVE THEIR OWN MARKET TIMING POLICIES AND
PROCEDURES. THE MARKET TIMING POLICIES OF THE UNDERLYING FUNDS MAY BE MORE
RESTRICTIVE THAN THE MARKET TIMING POLICIES AND PROCEDURES WE APPLY TO TRANSFERS
AMONG THE SUBACCOUNTS OF THE CONTRACT, AND MAY INCLUDE REDEMPTION FEES. WE
RESERVE THE RIGHT TO MODIFY OUR MARKET TIMING POLICIES AND PROCEDURES AT ANY
TIME WITHOUT PRIOR NOTICE TO YOU.

Market timing may hurt the performance of an underlying fund in which a
subaccount invests in several ways, including but not necessarily limited to:

-    diluting the value of an investment in an underlying fund in which a
     subaccount invests;

-    increasing the transaction costs and expenses of an underlying fund in
     which a subaccount invests; and

-    preventing the investment adviser(s) of an underlying fund in which a
     subaccount invests from fully investing the assets of the fund in
     accordance with the fund's investment objectives.

Funds available as investment options under the contract that invest in
securities that trade in overseas securities markets may be at greater risk of
loss from market timing, as market timers may seek to take advantage of changes
in the values of securities between the close of overseas markets and the close
of U.S. markets. Also, the risks of market timing may be greater for underlying
funds that invest in securities such as small cap stocks, high yield bonds, or
municipal securities, that may be traded infrequently.

IN ORDER TO HELP PROTECT YOU AND THE UNDERLYING FUNDS FROM THE POTENTIALLY
HARMFUL EFFECTS OF MARKET TIMING ACTIVITY, WE APPLY THE FOLLOWING MARKET TIMING
POLICY TO DISCOURAGE FREQUENT TRANSFERS OF CONTRACT VALUE AMONG THE SUBACCOUNTS
OF THE VARIABLE ACCOUNT:

We try to distinguish market timing from transfers that we believe are not
harmful, such as periodic rebalancing for purposes of an asset allocation,
dollar-cost averaging and asset rebalancing program that may be described in
this prospectus. There is no set number of transfers that constitutes market
timing. Even one transfer in related accounts may be market timing. We seek to
restrict the transfer privileges of a contract owner who makes more than three
subaccount transfers in any 90 day period. We also reserve the right to refuse
any transfer request, if, in our sole judgment, the dollar amount of the
transfer request would adversely affect unit values.

If we determine, in our sole judgment, that your transfer activity constitutes
market timing, we may modify, restrict or suspend your transfer privileges to
the extent permitted by applicable law, which may vary based on the state law
that applies to your contract and the terms of your contract. These restrictions
or modifications may include, but not be limited to:

-    requiring transfer requests to be submitted only by first-class U.S. mail;

-    not accepting hand-delivered transfer requests or requests made by
     overnight mail;

-    not accepting telephone or electronic transfer requests;

-    requiring a minimum time period between each transfer;



-    not accepting transfer requests of an agent acting under power of attorney;

-    limiting the dollar amount that you may transfer at any one time;

-    suspending the transfer privilege; or

-    modifying instructions under an automated transfer program to exclude a
     restricted fund if you do not provide new instructions.

Subject to applicable state law and the terms of each contract, we will apply
the policy described above to all contract owners uniformly in all cases. We
will notify you in writing after we impose any modification, restriction or
suspension of your transfer rights.

We cannot guarantee that we will be able to identify and restrict all market
timing activity. Because we exercise discretion in applying the restrictions
described above, we cannot guarantee that we will be able to restrict all market
timing activity. In addition, state law and the terms of some contracts may
prevent us from stopping certain market timing activity. Market timing activity
that we are unable to identify and/or restrict may impact the performance of the
underlying funds and may result in lower contract values.

IN ADDITION TO THE MARKET TIMING POLICY DESCRIBED ABOVE, WHICH APPLIES TO
TRANSFERS AMONG THE SUBACCOUNTS WITHIN YOUR CONTRACT, YOU SHOULD CAREFULLY
REVIEW THE MARKET TIMING POLICIES AND PROCEDURES OF THE UNDERLYING FUNDS. THE
MARKET TIMING POLICIES AND PROCEDURES OF THE UNDERLYING FUNDS MAY BE MATERIALLY
DIFFERENT THAN THOSE WE IMPOSE ON TRANSFERS AMONG THE SUBACCOUNTS WITHIN YOUR
CONTRACT AND MAY INCLUDE MANDATORY REDEMPTION FEES AS WELL AS OTHER MEASURES TO
DISCOURAGE FREQUENT TRANSFERS. AS AN INTERMEDIARY FOR THE UNDERLYING FUNDS, WE
ARE REQUIRED TO ASSIST THEM IN APPLYING THEIR MARKET TIMING POLICIES AND
PROCEDURES TO TRANSACTIONS INVOLVING THE PURCHASE AND EXCHANGE OF FUND SHARES.
THIS ASSISTANCE MAY INCLUDE BUT NOT BE LIMITED TO PROVIDING THE UNDERLYING FUND
UPON REQUEST WITH YOUR SOCIAL SECURITY NUMBER, TAXPAYER IDENTIFICATION NUMBER OR
OTHER UNITED STATES GOVERNMENT-ISSUED IDENTIFIER AND THE DETAILS OF YOUR
CONTRACT TRANSACTIONS INVOLVING THE UNDERLYING FUND. AN UNDERLYING FUND, IN ITS
SOLE DISCRETION, MAY INSTRUCT US AT ANY TIME TO PROHIBIT YOU FROM MAKING FURTHER
TRANSFERS OF CONTRACT VALUE TO OR FROM THE UNDERLYING FUND, AND WE MUST FOLLOW
THIS INSTRUCTION. WE RESERVE THE RIGHT TO ADMINISTER AND COLLECT ON BEHALF OF AN
UNDERLYING FUND ANY REDEMPTION FEE IMPOSED BY AN UNDERLYING FUND. MARKET TIMING
POLICIES AND PROCEDURES ADOPTED BY UNDERLYING FUNDS MAY AFFECT YOUR INVESTMENT
IN THE CONTRACT IN SEVERAL WAYS, INCLUDING BUT NOT LIMITED TO:

-    Each fund may restrict or refuse trading activity that the fund determines,
     in its sole discretion, represents market timing.

-    Even if we determine that your transfer activity does not constitute market
     timing under the market timing policies described above which we apply to
     transfers you make under the contract, it is possible that the underlying
     fund's market timing policies and procedures, including instructions we
     receive from a fund, may require us to reject your transfer request. For
     example, while we disregard transfers permitted under any asset allocation,
     dollar-cost averaging and asset rebalancing programs that may be described
     in this prospectus, we cannot guarantee that an underlying fund's market
     timing policies and procedures will do so. Orders we place to purchase fund
     shares for the variable accounts are subject to acceptance by the fund. We
     reserve the right to reject without prior notice to you any transfer
     request if the fund does not accept our order.

-    Each underlying fund is responsible for its own market timing policies, and
     we cannot guarantee that we will be able to implement specific market
     timing policies and procedures that a fund has adopted. As a result, a
     fund's returns might be adversely affected, and a fund might terminate our
     right to offer its shares through the variable account.

-    Funds that are available as investment options under the contract may also
     be offered to other intermediaries who are eligible to purchase and hold
     shares of the fund, including without limitation, separate accounts of
     other insurance companies and certain retirement plans. Even if we are able
     to implement a fund's market timing policies, we cannot guarantee that
     other intermediaries purchasing that same fund's shares will do so, and the
     returns of that fund could be adversely affected as a result.

FOR MORE INFORMATION ABOUT THE MARKET TIMING POLICIES AND PROCEDURES OF AN
UNDERLYING FUND, THE RISKS THAT MARKET TIMING POSE TO THAT FUND, AND TO
DETERMINE WHETHER AN UNDERLYING FUND HAS ADOPTED A REDEMPTION FEE, SEE THAT
FUND'S PROSPECTUS.



HOW TO REQUEST A TRANSFER OR SURRENDER

1 BY LETTER

Send your name, contract number, Social Security Number or Taxpayer
Identification Number* and signed request for a transfer or surrender to:

RIVERSOURCE LIFE INSURANCE COMPANY

70100 AMERIPRISE FINANCIAL CENTER

MINNEAPOLIS, MN 55474

MINIMUM AMOUNT

Transfers or surrenders:   $250 or entire account balance

MAXIMUM AMOUNT

Transfers or surrenders: Contract value or entire account balance

*    Failure to provide your Social Security Number or Taxpayer Identification
     Number may result in mandatory tax withholding on the taxable portion of
     the distribution.

2 BY AUTOMATED TRANSFERS AND AUTOMATED PARTIAL SURRENDERS

Your financial advisor can help you set up automated transfers or partial
surrenders among your subaccounts or regular fixed account (if available).

You can start or stop this service by written request or other method acceptable
to us. You must allow 30 days for us to change any instructions that are
currently in place.

-    Automated transfers to the GPAs, the regular fixed account or the Special
     DCA fixed account are not allowed.

-    Automated transfers from the regular fixed account to the subaccounts under
     an automated dollar-cost averaging arrangement may not exceed an amount
     that, if continued, would deplete the regular fixed account within 12
     months.

-    Automated surrenders may be restricted by applicable law under some
     contracts.

-    You may not make additional purchase payments if automated partial
     surrenders are in effect.

-    Automated partial surrenders may result in IRS taxes and penalties on all
     or part of the amount surrendered.

-    The balance in any account from which you make an automated transfer or
     automated partial surrender must be sufficient to satisfy your
     instructions. If not, we will suspend your entire automated arrangement
     until the balance is adequate.

-    If we must suspend your automated transfer or automated partial surrender
     arrangement for six months, we reserve the right to discontinue the
     arrangement in its entirety.

-    If a PN program is in effect, you are not allowed to set up automated
     transfers except in connection with a Special DCA fixed account.

MINIMUM AMOUNT

Transfers or surrenders: $50



MAXIMUM AMOUNT

Transfers or surrenders: None (except for automated transfers from the regular
fixed account)

3 BY TELEPHONE

Call between 7 a.m. and 7 p.m. Central time:

(800) 862-7919

TTY service for the hearing impaired:

(800) 285-8846
MINIMUM AMOUNT

Transfers or surrenders: $250 or entire account balance

MAXIMUM AMOUNT

Transfers:    Contract value or entire account balance
Surrenders:   $100,000

We answer telephone requests promptly, but you may experience delays when the
call volume is unusually high. If you are unable to get through, use the mail
procedure as an alternative.

We will honor any telephone transfer or surrender requests that we believe are
authentic and we will use reasonable procedures to confirm that they are. This
includes asking identifying questions and recording calls. We will not allow
telephone surrender within 30 days of a phoned-in address change. As long as we
follow the procedures, we (and our affiliates) will not be liable for any loss
resulting from fraudulent requests.

Telephone transfers or surrenders are automatically available. You may request
that telephone transfers or surrenders not be authorized from your account by
writing to us.

SURRENDERS

You may surrender all or part of your contract at any time before annuity
payouts begin by sending us a written request or calling us. We will process
your surrender request on the valuation date we receive it. If we receive your
surrender request in good order at our corporate office before the close of
business, we will process your surrender using the accumulation unit value we
calculate on the valuation date we received your surrender request. If we
receive your surrender request at our corporate office at or after the close of
business, we will process your surrender using the accumulation unit value we
calculate on the next valuation date after we received your surrender request.
We may ask you to return the contract. You may have to pay contract
administrative charges, surrender charges, or any applicable optional rider
charges (see "Charges") and IRS taxes and penalties (see "Taxes"). You cannot
make surrenders after annuity payouts begin except under Plan E (see "The
Annuity Payout Period -- Annuity Payout Plans").

Any partial surrenders you take under the contract will reduce your contract
value. As a result, the value of your death benefit or any optional benefits you
have elected also will be reduced. If you have elected the GWB for Life rider or
SecureSource(SM) rider and your partial surrenders in any contract year exceed
the permitted surrender amount under the terms of the GWB for Life rider or
SecureSource rider, your benefits under the rider may be reduced (see "Optional
Benefits"). In addition, surrenders you are required to take to satisfy the RMDs
under the Code may reduce the value of certain death benefits and optional
benefits (see "Taxes -- Qualified Annuities -- Required Minimum Distributions").

SURRENDER POLICIES

If you have a balance in more than one account and you request a partial
surrender, we will withdraw money from all your subaccounts and/or the regular
fixed account, in the same proportion as your value in each account correlates
to your total contract value, less any GPA or Special DCA fixed account, unless
you request otherwise. We will not withdraw money for a partial surrender from
any GPAs or Special DCA fixed account you may have, unless insufficient amounts
are available from your subaccounts and/or regular fixed account. However, you
may request specifically surrender from a GPA or Special DCA fixed account. The
minimum contract value after partial surrender is $600. If you elected a
SecureSource rider, the minimum contract value after partial surrender is zero
and you do not have the option to request from which account to surrender.



RECEIVING PAYMENT

1 BY REGULAR OR EXPRESS MAIL

-    payable to you;

-    mailed to address of record.

NOTE: We will charge you a fee if you request express mail delivery.

2 BY WIRE

-    request that payment be wired to your bank;

-    bank account must be in the same ownership as your contract; and

-    pre-authorization required.

NOTE: We will charge you a fee if you request that payment be wired to your
bank. For instructions, please contact your financial advisor.

Normally, we will send the payment within seven days after receiving your
request in good order. However, we may postpone the payment if:

     -    the surrender amount includes a purchase payment check that has not
          cleared;

     -    the NYSE is closed, except for normal holiday and weekend closings;

     -    trading on the NYSE is restricted, according to SEC rules;

     -    an emergency, as defined by SEC rules, makes it impractical to sell
          securities or value the net assets of the accounts; or

     -    the SEC permits us to delay payment for the protection of security
          holders.

TSA -- SPECIAL PROVISIONS

PARTICIPANTS IN TAX-SHELTERED ANNUITIES

If the contract is intended to be used in connection with an employer sponsored
403(b) plan, additional rules relating to this contract can be found in the
annuity endorsement for tax sheltered 403(b) annuities. Unless we have made
special arrangements with your employer, the contract is not intended for use in
connection with an employer sponsored 403(b) plan that is subject to the
Employee Retirement Income Security Act of 1974, as amended ("ERISA"). In the
event that the employer either by affirmative election or inadvertent action
causes contributions under a plan that is subject to ERISA to be made to this
contract, we will not be responsible for any obligations and requirements under
ERISA and the regulations thereunder, unless we have prior written agreement
with the employer. You should consult with your employer to determine whether
your 403(b) plan is subject to ERISA.

In the event we have a written agreement with your employer to administer the
plan pursuant to ERISA, special rules apply as set forth in the TSA endorsement.

The employer must comply with certain nondiscrimination requirements for certain
types of contributions under a TSA contract to be excluded from taxable income.
You should consult your employer to determine whether the nondiscrimination
rules apply to you.

The Code imposes certain restrictions on your right to receive early
distributions from a TSA:



-    Distributions attributable to salary reduction contributions (plus
     earnings) made after Dec. 31, 1988, or to transfers or rollovers from other
     contracts, may be made from the TSA only if:

     -    you are at least age 59 1/2;

     -    you are disabled as defined in the Code;

     -    you severed employment with the employer who purchased the contract;

     -    the distribution is because of your death;

     -    effective Jan. 1, 2009, the distribution is due to plan termination;
          or

     -    effective Jan. 1, 2009, you are a military reservist.

-    If you encounter a financial hardship (as provided by the Code), you may be
     eligible to receive a distribution of all contract values attributable to
     salary reduction contributions made after Dec. 31, 1988, but not the
     earnings on them.

-    Even though a distribution may be permitted under the above rules, it may
     be subject to IRS taxes and penalties (see "Taxes").

-    The above restrictions on distributions do not affect the availability of
     the amount credited to the contract as of Dec. 31, 1988. The restrictions
     also do not apply to transfers or exchanges of contract value within the
     contract, or to another registered variable annuity contract or investment
     vehicle available through the employer.

-    If the contract has a loan provision, the right to receive a loan is
     described in detail in your contract. Loans will not be available if you
     have selected the GWB for Life, SecureSource or Accumulation Benefit rider.

CHANGING OWNERSHIP

You may change ownership of your nonqualified annuity at any time by completing
a change of ownership form we approve and sending it to our corporate office. If
you are a natural person and you own a nonqualified annuity, you may change the
annuitant or successor annuitant if the request is made before annuity payments
begin and while the existing annuitant is living. The change will become binding
on us when we receive and record it. We will honor any change of ownership
request received in good order that we believe is authentic and we will use
reasonable procedures to confirm authenticity. If we follow these procedures, we
will not take any responsibility for the validity of the change.

Please consider carefully whether or not you wish to change ownership of your
nonqualified annuity if you have elected the ROPP, MAV, 5-Year MAV, EEB, EEP,
Accumulation Benefit, GWB for Life or SecureSource. If you change ownership of
your contract, we will terminate the ROPP and EEP. This includes both the EEP
Part I benefits and the EEP Part II benefits. (See the description of these
terms in "Optional Benefits".) In addition, the terms of the EEB, the MAV and
the 5-Year MAV will change due to a change of ownership. If the new owner is
older than age 75, the EEB will terminate. Otherwise, the EEB will effectively
"start over." We will treat the EEB as if it is issued on the day the change of
ownership is made, using the attained age of the new owner as the "issue age" to
determine the benefit levels. The account value on the date of the ownership
change will be treated as a "purchase payment" in determining future values of
"earnings at death" under the EEB. If the new owner is older than age 75, the
MAV and the 5-Year MAV will terminate. If the MAV or the 5-Year MAV on the date
of ownership change is greater than the account value on the date of the
ownership change, we will set the MAV or the 5-Year MAV equal to the account
value. Otherwise, the MAV or the 5-Year MAV value will not change due to a
change in ownership. The Accumulation Benefit rider, the GWB for Life rider and
SecureSource -- Single Life rider will continue upon change of ownership. The
SecureSource -- Joint Life rider, if selected, only allows transfer of the
ownership of the annuity contract between covered spouses or their revocable
trust(s). If ownership is transferred from a covered spouse to their revocable
trust(s), the annuitant must be one of the covered spouses. No other ownership
changes are allowed while this rider is in force. Please see the descriptions of
these riders in "Optional Benefits."

The rider charges described in "Charges" will be assessed at the next contract
anniversary (and all future anniversaries when the rider is in force) for any
rider that continues after a change of ownership. We reserve the right to assess
charges for the number of days the rider was in force for any rider that is
terminated due to a change of ownership.



If you have a nonqualified annuity, you may incur income tax liability by
transferring, assigning or pledging any part of it. (See "Taxes.")

If you have a qualified annuity, you may not sell, assign, transfer, discount or
pledge your contract as collateral for a loan, or as security for the
performance of an obligation or for any other purpose except as required or
permitted by the Code.

However, if the owner is a trust or custodian, or an employer acting in similar
capacity, ownership of the contract may be transferred to the annuitant.

BENEFITS IN CASE OF DEATH -- STANDARD DEATH BENEFIT

We will pay the death benefit to your beneficiary upon your death. If a contract
has more than one person as the owner, we will pay benefits upon the first to
die of any owner. If you die before annuity payouts begin while this contract is
in force, we will pay the beneficiary as follows:

If you are age 75 or younger on the date we issue the contract, the beneficiary
receives the greater of:

-    contract value, less any purchase payment credits subject to reversal, less
     any applicable rider charges; or

-    purchase payments minus adjusted partial surrenders.

If you are age 76 or older on the date we issue the contract, the beneficiary
receives the contract value, less any purchase payment credits subject to
reversal, less any applicable rider charges.

ADJUSTED PARTIAL SURRENDERS

                                     PS X DB
                                 --------------
                                       CV

     PS = amount by which the contract value is reduced as a result of the
          partial surrender.

     DB = the death benefit on the date of (but prior to) the partial surrender.

     CV = the contract value on the date of (but prior to) the partial
          surrender.

EXAMPLE OF STANDARD DEATH BENEFIT CALCULATION WHEN YOU ARE AGE 75 OR YOUNGER ON
THE CONTRACT EFFECTIVE DATE:

-    You purchase the contract with a payment of $20,000

-    During the second contract year the contract value falls to $18,000, at
     which point you take a $1,500 partial surrender, leaving a contract value
     of $16,500.

                                                                     
We calculate the death benefit as follows:
The total purchase payments minus adjustments for partial surrenders:
Total purchase payments                                                 $20,000
minus adjusted partial surrenders, calculated as:
$1,500 x $20,000
---------------- =
     $18,000                                                             -1,667
                                                                        -------
for a standard death benefit of:                                        $18,333
since this is greater than your contract value of $16,500.





IF YOU DIE BEFORE YOUR SETTLEMENT DATE

When paying the beneficiary, we will process the death claim on the valuation
date that our death claim requirements are fulfilled. We will determine the
contract's value using the accumulation unit value we calculate on that
valuation date. We pay interest, if any, at a rate no less than required by law.
If requested, we will mail payment to the beneficiary within seven days after
our death claim requirements are fulfilled.

NONQUALIFIED ANNUITIES

If your spouse is sole beneficiary and you die before the settlement date, your
spouse may keep the contract as owner with the contract value equal to the death
benefit that would otherwise have been paid. To do this your spouse must, on the
date our death claim requirements are fulfilled, give us written instructions to
keep the contract in force. If your spouse elects to keep the contract as owner,
the following describes the standard death benefit:

-    If your spouse was age 75 or younger as of the date we issued the contract,
     the beneficiary of your spouse's contract receives the greater of:

     -    contract value, less any purchase payment credits subject to reversal,
          less any applicable rider charges; or

     -    purchase payments minus adjusted partial surrenders.

If your spouse was age 76 or older as of the date we issued the contract, the
beneficiary of your spouse's contract receives the contract value, less any
purchase payment credits subject to reversal, less any applicable rider charges.

If you elected any optional contract features or riders, your spouse and the new
annuitant (if applicable) will be subject to all limitations and/or restrictions
of those features or riders. The SecureSource -- Joint Life rider, if selected,
will continue only if the spouse electing the spousal continuation provision of
the contract is a covered spouse and continues the contract as the new owner.

If your beneficiary is not your spouse, we will pay the beneficiary in a lump
sum unless you give us other written instructions. Generally, we must fully
distribute the death benefit within five years of your death. However, the
beneficiary may receive payouts under any annuity payout plan available under
this contract if:

-    the beneficiary asks us in writing within 60 days after our death claim
     requirements are fulfilled; and

-    payouts begin no later than one year after your death, or other date as
     permitted by the IRS; and

-    the payout period does not extend beyond the beneficiary's life or life
     expectancy.

Additionally, the optional SecureSource rider, if selected, will terminate.

QUALIFIED ANNUITIES

-    SPOUSE BENEFICIARY: If you have not elected an annuity payout plan, and if
     your spouse is the sole beneficiary, your spouse may either elect to treat
     the contract as his/her own with the contract value equal to the death
     benefit that would otherwise have been paid, or elect an annuity payout
     plan or another plan agreed to by us. If your spouse elects to treat the
     contract as his/her own, the following describes the standard death
     benefit:

-    If your spouse was age 75 or younger as of the date we issued the contract,
     the beneficiary of your spouse's contract receives the greater of:

-    contract value, less any purchase payment credits subject to reversal, less
     any applicable rider charges; or

-    purchase payments minus adjusted partial surrenders.

If your spouse was age 76 or older as of the date we issued the contract, the
beneficiary of your spouse's contract receives the contract value, less any
purchase payment credits subject to reversal, less any applicable rider charges.



If your spouse elects a payout plan, the payouts must begin no later than the
year in which you would have reached age 70 1/2. If you attained age 70 1/2 at
the time of death, payouts must begin no later than Dec. 31 of the year
following the year of your death.

If you elected any optional contract features or riders, your spouse and the new
annuitant (if applicable) will be subject to all limitations and/or restrictions
of those features or riders. The SecureSource -- Joint Life rider, if selected,
will continue only if the spouse electing the spousal continuation provision of
the contract is a covered spouse and continues the contract as the new owner.

-    NON-SPOUSE BENEFICIARY: If you have not elected an annuity payout plan, and
     if death occurs prior to the year you would have attained age 70 1/2, the
     beneficiary may elect to receive payouts from the contract over a five year
     period. If your beneficiary does not elect a five year payout, or if your
     death occurs after attaining age 70 1/2, we will pay the beneficiary in a
     lump sum unless the beneficiary elects to receive payouts under any payout
     plan available under this contract if:

-    the beneficiary asks us in writing within 60 days after our death claim
     requirements are fulfilled; and

-    payouts begin no later than one year following the year of your death; and

-    the payout period does not extend beyond the beneficiary's life or life
     expectancy.

Additionally, the optional SecureSource rider, if selected, will terminate.

-    ANNUITY PAYOUT PLAN: If you elect an annuity payout plan, the payouts to
     your beneficiary will continue pursuant to the annuity payout plan you
     elect.

DEATH BENEFIT PAYMENT IN A LUMP SUM: We may pay all or part of the death benefit
to your beneficiary in a lump sum under either a nonqualified or qualified
annuity. We will pay the death benefit by check unless your beneficiary has
chosen to have the death benefit payment directly deposited into a checking
account. We pay all proceeds by check (unless the beneficiary has chosen to have
death benefit proceeds directly deposited into another Ameriprise Financial,
Inc. account). If the beneficiary chooses the checking account option, the
proceeds will be deposited into an interest bearing checking account issued by
Ameriprise Bank, FSB, member FDIC, unless the beneficiary fails to meet the
requirements of using this option.

OPTIONAL BENEFITS

The assets held in our general account support the guarantees under your
contract, including optional death benefits and optional living benefits. To the
extent that we are required to pay you amounts in addition to your contract
value under these benefits, such amounts will come from our general account
assets. You should be aware that our general account is exposed to the risks
normally associated with a portfolio of fixed-income securities, including
interest rate, option, liquidity and credit risk. The financial statements
contained in the SAI include a further discussion of the risks inherent within
the investments of the general account.

OPTIONAL DEATH BENEFITS
RETURN OF PURCHASE PAYMENTS DEATH BENEFIT (ROPP)

The ROPP is intended to provide additional death benefit protection in the event
of fluctuating fund values. This is an optional benefit that you may select for
an additional annual charge (see "Charges"). If you die before annuity payouts
begin while this contract is in force, we will pay the beneficiary the greater
of:

-    contract value, less any purchase payment credits subject to reversal, less
     any applicable rider charges; or

-    purchase payments minus adjusted partial surrenders.

If you are age 76 or older at contract issue, you may choose to add the ROPP to
your contract. Generally, you must elect the ROPP at the time you purchase your
contract and your rider effective date will be the contract issue date. In some
instances the rider effective date for the ROPP may be after we issue the
contract according to terms determined by us and at our sole discretion. We
reserve the right to discontinue offering the ROPP for new contracts.

When annuity payouts begin, or if you terminate the contract for any reason
other than death, this rider will terminate.



TERMINATING THE ROPP

-    You may terminate the ROPP rider within 30 days of the first rider
     anniversary.

-    You may terminate the ROPP rider within 30 days of any rider anniversary
     beginning with the seventh rider anniversary.

-    The ROPP rider will terminate when you make a full surrender from the
     contract or when annuity payouts begin.

If you terminate the ROPP, the standard death benefit applies thereafter.

For an example, see Appendix D.

IF YOUR SPOUSE IS THE SOLE BENEFICIARY, he or she may keep the contract as owner
with the contract value equal to the death benefit that would otherwise have
been paid under the ROPP. To do this your spouse must, on the date our death
claim requirements are fulfilled, give us written instructions to keep the
contract in force. IF YOUR SPOUSE WAS AGE 76 OR OLDER AS OF THE DATE WE ISSUED
THE CONTRACT, he or she may choose to continue the ROPP. In that case, the ROPP
rider charges described in "Charges -- ROPP Rider Fee" will be assessed at the
next contract anniversary (and all future anniversaries when the rider is in
force). These charges will be based on the total contract value on the
anniversary. Your spouse also has the option of discontinuing the ROPP rider
within 30 days of the date he or she elects to continue the contract. If your
spouse is age 75 or younger as of the date we issued the contract, the ROPP will
terminate.

NOTE: For special tax considerations associated with the ROPP, see "Taxes."

MAXIMUM ANNIVERSARY VALUE DEATH BENEFIT (MAV)

The MAV is intended to provide additional death benefit protection in the event
of fluctuating fund values. This is an optional benefit that you may select for
an additional annual charge (see "Charges"). The MAV does not provide any
additional benefit before the first contract anniversary after the rider
effective date. The MAV may be of less value if you are older since we stop
resetting the maximum anniversary value at age 81. Although we stop resetting
the maximum anniversary value at age 81, the MAV rider fee continues to apply
until the rider terminates. In addition, the MAV does not provide any additional
benefit with respect to the GPAs, regular fixed account or Special DCA fixed
account values during the time you have amounts allocated to these accounts. Be
sure to discuss with your financial advisor whether or not the MAV is
appropriate for your situation.

If you are age 75 or younger at contract issue, you may choose to add the MAV to
your contract. Generally, you must elect the MAV at the time you purchase your
contract and your rider effective date will be the contract issue date. In some
instances the rider effective date for the MAV may be after we issue the
contract according to terms determined by us and at our sole discretion. We
reserve the right to discontinue offering the MAV for new contracts.

On the first contract anniversary after the rider effective date we set the
maximum anniversary value equal to the highest of your (a) current contract
value, or (b) total purchase payments minus adjusted partial surrenders.
Thereafter, we increase the maximum anniversary value by any additional purchase
payments and reduce it by adjusted partial surrenders. Every contract
anniversary after that prior to your 81st birthday, we compare the maximum
anniversary value to the current contract value and we reset the maximum
anniversary value to the higher amount.

If you die before annuity payouts begin while this contract is in force, we will
pay the beneficiary the greatest of:

-    contract value, less any purchase payment credits subject to reversal, less
     any applicable rider charges; or

-    purchase payments minus adjusted partial surrenders; or

-    the maximum anniversary value.



TERMINATING THE MAV

-    You may terminate the MAV rider within 30 days of the first rider
     anniversary.

-    You may terminate the MAV rider within 30 days of any rider anniversary
     beginning with the seventh rider anniversary.

-    The MAV rider will terminate when you make a full surrender from the
     contract or when annuity payouts begin.

-    The MAV rider will terminate in the case of spousal continuation or
     ownership change if the new owner is age 76 or older.

If you terminate the MAV, the standard death benefit applies thereafter.

For an example, see Appendix D.

IN GENERAL, IF YOUR SPOUSE IS THE SOLE BENEFICIARY, your spouse may choose to
continue the contract as the contract owner. The contract value will be equal to
the death benefit that would otherwise have been paid under the MAV. To do this
your spouse must, on the date our death claim requirements are fulfilled, give
us written instructions to keep the contract in force. If your spouse has
reached age 76 at the time he or she elects to continue the contract, the MAV
rider will terminate. If your spouse has not yet reached age 76 at the time he
or she elects to continue the contract, he or she may choose to continue the MAV
rider. In this case, the rider charges described in "Charges" will be assessed
at the next contract anniversary (and all future anniversaries when the rider is
in force). These charges will be based on the total contract value on the
anniversary, including the additional amounts paid into the contract under the
MAV rider. If, at the time he or she elects to continue the contract, your
spouse has not yet reached age 76 and chooses not to continue the MAV rider, the
contract value will be increased to the MAV death benefit amount if it is
greater than the contract value on the death benefit valuation date.

MAXIMUM FIVE YEAR ANNIVERSARY VALUE DEATH BENEFIT (5-YEAR MAV)

The 5-Year MAV is intended to provide additional death benefit protection in the
event of fluctuating fund values. This is an optional benefit that you may
select for an additional annual charge (see "Charges"). The 5-Year MAV does not
provide any additional benefit before the fifth contract anniversary after the
rider effective date. The 5-Year MAV may be of less value if you are older since
we stop resetting the maximum five year anniversary value at age 81. Although we
stop resetting the maximum five year anniversary value at age 81, the 5-Year MAV
rider fee continues to apply until the rider terminates. In addition, the 5-Year
MAV does not provide any additional benefit with respect to the GPAs, regular
fixed account or Special DCA fixed account values during the time you have
amounts allocated to these accounts. Be sure to discuss with your financial
advisor whether or not the 5-Year MAV is appropriate for your situation.

If you are age 75 or younger at contract issue, you may choose to add the 5-Year
MAV to your contract. Generally, you must elect the 5-Year MAV at the time you
purchase your contract and your rider effective date will be the contract issue
date. In some instances the rider effective date for the 5-Year MAV may be after
we issue the contract according to terms determined by us and at our sole
discretion. We reserve the right to discontinue offering the 5-Year MAV for new
contracts.

On the fifth contract anniversary after the rider effective date we set the
maximum five year anniversary value equal to the highest of your (a) current
contract value, or (b) total purchase payments minus adjusted partial
surrenders. Thereafter, we increase the maximum anniversary value by any
additional purchase payments and reduce it by adjusted partial surrenders. Every
fifth contract anniversary after that, through age 80, we compare the maximum
five year anniversary value to the current contract value and we reset the
maximum five year anniversary value to the higher amount.

If you die before annuity payouts begin while this contract is in force, we will
pay the beneficiary the greatest of:

-    contract value, less any purchase payment credits subject to reversal, less
     any applicable rider charges; or

-    purchase payments minus adjusted partial surrenders; or

-    the maximum five year anniversary value.



TERMINATING THE 5-YEAR MAV

-    You may terminate the 5-Year MAV rider within 30 days of the first rider
     anniversary.

-    You may terminate the 5-Year MAV rider within 30 days of any rider
     anniversary beginning with the seventh rider anniversary.

-    The 5-Year MAV rider will terminate when you make a full surrender from the
     contract or when annuity payouts begin.

-    The 5-Year MAV rider will terminate in the case of spousal continuation or
     ownership change if the new owner is age 76 or older.

If you terminate the 5-Year MAV, the standard death benefit applies thereafter.

For an example, see Appendix D.

IN GENERAL, IF YOUR SPOUSE IS THE SOLE BENEFICIARY, your spouse may choose to
continue the contract as the contract owner. The contract value will be equal to
the death benefit that would otherwise have been paid under the 5-Year MAV. To
do this your spouse must, on the date our death claim requirements are
fulfilled, give us written instructions to keep the contract in force. If your
spouse has reached age 76 at the time he or she elects to continue the contract,
the 5-Year MAV rider will terminate. If your spouse has not yet reached age 76
at the time he or she elects to continue the contract, he or she may choose to
continue the 5-Year MAV rider. In this case, the rider charges described in
"Charges" will be assessed at the next contract anniversary (and all future
anniversaries when the rider is in force). These charges will be based on the
total contract value on the anniversary, including the additional amounts paid
into the contract under the 5-Year MAV rider. If, at the time he or she elects
to continue the contract, your spouse has not yet reached age 76 and chooses not
to continue the 5-Year MAV rider, the contract value will be increased to the
5-Year MAV death benefit amount if it is greater than the contract value on the
death benefit valuation date.

ENHANCED EARNINGS DEATH BENEFIT (EEB)

The EEB is intended to provide an additional benefit to your beneficiary to help
offset expenses after your death such as funeral expenses or federal and state
taxes. This is an optional benefit that you may select for an additional annual
charge (see "Charges"). The EEB provides for reduced benefits if you are age 70
or older at the rider effective date and it does not provide any additional
benefit before the first rider anniversary. The EEB also may result in reduced
benefits if you take RMDs (see "Taxes -- Qualified Annuities -- Required Minimum
Distributions") from your qualified annuity or any partial surrenders during the
life of your contract, both of which may reduce contract earnings. This is
because the benefit paid by the EEB is determined by the amount of earnings at
death. Be sure to discuss with your financial advisor and your tax advisor
whether or not the EEB is appropriate for your situation.

If this EEB rider is available in your state and you are age 75 or younger at
the rider effective date, you may choose to add the EEB to your contract.
Generally, you must elect the EEB at the time you purchase your contract and
your rider effective date will be the contract issue date. In some instances the
rider effective date for the EEB may be after we issue the contract according to
terms determined by us and at our sole discretion. You may not select this rider
if you select the EEP. We reserve the right to discontinue offering the EEB for
new contracts.

The EEB provides that if you die after the first rider anniversary, but before
annuity payouts begin, and while this contract is in force, we will pay the
beneficiary:

-    the standard death benefit amount (see "Benefits in Case of Death --
     Standard Benefit"), the MAV death benefit amount, if applicable, or the
     5-Year MAV death benefit amount, if applicable,

PLUS

-    40% of your earnings at death if you were under age 70 on the rider
     effective date; or

-    15% of your earnings at death if you were age 70 or older on the rider
     effective date.

Additional death benefits payable under the EEB are not included in the adjusted
partial surrender calculation.



EARNINGS AT DEATH FOR THE EEB AND EEP: If the rider effective date for the EEB
or EEP is the contract issue date, earnings at death is an amount equal to:

-    the standard death benefit amount, the MAV death benefit amount, or the
     5-Year MAV death benefit amount if applicable (the "death benefit amount")

-    MINUS purchase payments not previously surrendered.

The earnings at death may not be less than zero and may not be more than 250% of
the purchase payments not previously surrendered that are one or more years old.

If the rider effective date for the EEB is AFTER the contract issue date,
earnings at death is an amount equal to the death benefit amount

-    MINUS the greater of:

     a)   the contract value as of the EEB rider effective date (determined
          before we apply any purchase payment or purchase payment credit), less
          any surrenders of that contract value since that rider effective date;
          or

     b)   an amount equal to the death benefit amount as of the EEB rider
          effective date (determined before we apply any purchase payment or
          purchase payment credit), less any surrenders of that death benefit
          amount since that rider effective date

-    PLUS any purchase payments made on or after the EEB rider effective date
     not previously surrendered.

The earnings at death may not be less than zero and may not be more than 250%
multiplied by:

-    the greater of:

     a)   the contract value as of the EEB rider effective date (determined
          before we apply any purchase payment or purchase payment credit), less
          any surrenders of that contract value since that rider effective date;
          or

     b)   an amount equal to the death benefit amount as of the EEB rider
          effective date (determined before we apply any purchase payment or
          purchase payment credit), less any surrenders of that death benefit
          amount since that rider effective date

-    PLUS any purchase payments made on or after the EEB rider effective date
     not previously surrendered that are one or more years old.

TERMINATING THE EEB

-    You may terminate the EEB rider within 30 days of the first rider
     anniversary.

-    You may terminate the EEB rider within 30 days of any rider anniversary
     beginning with the seventh rider anniversary.

-    The EEB rider will terminate when you make a full surrender from the
     contract or when annuity payouts begin.

-    The EEB rider will terminate in the case of spousal continuation or
     ownership change if the new owner is age 76 or older.

For an example, see Appendix D.

IN GENERAL, IF YOUR SPOUSE IS THE SOLE BENEFICIARY, and your spouse chooses to
continue the contract as the contract owner, we will pay an amount into the
contract so that the contract value equals the total death benefit payable under
the EEB. If your spouse is age 76 or older at the time he or she elects to
continue the contract, then the EEB rider will terminate. If your spouse is less
than age 76 at the time he or she elects to continue the contract, he or she may
choose to continue the EEB. In this case, the following conditions will apply:

-    the EEB rider will continue, but we will treat the new contract value on
     the date the ownership of the contract changes to your spouse (after the
     additional amount is paid into the contract) as if it is a purchase payment
     in calculating future values of "earnings at death."

-    the percentages of "earnings at death" payable will be based on your
     spouse's age at the time he or she elects to continue the contract.



-    the EEB rider charges described in "Charges -- EEB Rider Fee" will be
     assessed at the next contract anniversary (and all future anniversaries
     when the rider is in force). These charges will be based on the total
     contract value on the anniversary, including the additional amounts paid
     into the contract under the EEB rider.

NOTE: For special tax considerations associated with the EEB, see "Taxes."

ENHANCED EARNINGS PLUS DEATH BENEFIT (EEP)

The EEP is intended to provide an additional benefit to your beneficiary to help
offset expenses after your death such as funeral expenses or federal and state
taxes. This is an optional benefit that you may select for an additional annual
charge (see "Charges"). The EEP provides for reduced benefits if you are age 70
or older at the rider effective date. It does not provide any additional benefit
before the first rider anniversary and it does not provide any benefit beyond
what is offered under the EEB during the second rider year. The EEP also may
result in reduced benefits if you take RMDs (see "Taxes -- Qualified Annuities
-- Required Minimum Distributions") from your qualified annuity or any partial
surrenders during the life of your contract, both of which may reduce contract
earnings. This is because part of the benefit paid by the EEP is determined by
the amount of earnings at death. Be sure to discuss with your financial advisor
and your tax advisor whether or not the EEP is appropriate for your situation.

If this EEP rider is available in your state and you are age 75 or younger at
contract issue, you may choose to add the EEP to your contract. You must elect
the EEP at the time you purchase your contract and your rider effective date
will be the contract issue date. THIS RIDER IS ONLY AVAILABLE UNDER ANNUITIES
PURCHASED THROUGH AN EXCHANGE OR DIRECT TRANSFER FROM ANOTHER ANNUITY OR A LIFE
INSURANCE POLICY. You may not select this rider if you select the EEB. We
reserve the right to discontinue offering the EEP for new contracts.

The EEP provides that if you die after the first rider anniversary, but before
annuity payouts begin, and while this contract is in force, we will pay the
beneficiary:

-    EEP Part I benefits, which equal the benefits payable under the EEB
     described above;

PLUS

-    EEP Part II benefits, which equal a percentage of exchange purchase
     payments identified at issue not previously surrendered as follows:



                              PERCENTAGE IF YOU ARE                     PERCENTAGE IF YOU ARE
RIDER YEAR          UNDER AGE 70 ON THE RIDER EFFECTIVE DATE   70 OR OLDER ON THE RIDER EFFECTIVE DATE
                    ----------------------------------------   ---------------------------------------
                                                         
   One and Two                          0%                                          0%
   Three and Four                      10%                                       3.75%
   Five or more                        20%                                        7.5%


Additional death benefits payable under the EEP are not included in the adjusted
partial surrender calculation.

If after 6 months, no exchange purchase payments have been received, we will
contact you and you will have an additional 30 days to follow-up on exchange
purchase payments identified at issue but not received by us. If after these 30
days we have not received any exchange purchase payments, we will convert the
EEP rider into an EEB.

Another way to describe the benefits payable under the EEP rider is as follows:

-    the standard death benefit amount (see "Benefits in Case of Death --
     Standard Death Benefit"), the MAV death benefit amount, or 5-Year MAV death
     benefit amount, if applicable,

PLUS



             IF YOU ARE UNDER AGE 70                IF YOU ARE AGE 70
RIDER YEAR   ON THE RIDER EFFECTIVE DATE, ADD ...   OR OLDER ON THE RIDER EFFECTIVE DATE, ADD ...
----------   ------------------------------------   ---------------------------------------------
                                              
      1      Zero                                   Zero
      2      40% x earnings at death (see above)    15% x earnings at death




                                              
  3 & 4      40% x (earnings at death + 25% of      15% x (earnings at death + 25% of exchange
                exchange purchase payment*)            purchase payment*)
     5+      40% x (earnings at death + 50% of      15% x (earnings at death + 50% of exchange
                exchange purchase payment*)            purchase payment*)



*    Exchange purchase payments are purchase payments exchanged from another
     annuity or policy that are identified at issue and not previously
     surrendered.

We are not responsible for identifying exchange purchase payments if we did not
receive proper notification from the company from which the purchase payments
are exchanged.

TERMINATING THE EEP

-    You may terminate the EEP rider within 30 days of the first rider
     anniversary after the rider effective date.

-    You may terminate the EEP rider within 30 days of any rider anniversary
     beginning with the seventh rider anniversary.

-    The EEP rider will terminate when you make a full surrender from the
     contract or when annuity payouts begin.

-    The EEP rider will terminate in the case of an ownership change.

-    The EEP rider will terminate in the case of the spousal continuation if the
     new owner is age 76 or older.

For an example, see Appendix D.

IN GENERAL, IF YOUR SPOUSE IS THE SOLE BENEFICIARY, and your spouse chooses to
continue the contract as the contract owner, we will pay an amount into the
contract so that the contract value equals the total death benefit payable under
the EEP. If your spouse has reached age 76 at the time he or she elects to
continue the contract, the EEP rider will terminate. If your spouse has not yet
reached age 76 at the time he or she elects to continue the contract, he or she
cannot continue the EEP. However, he or she may choose to convert the EEP rider
into an EEB. In this case, the following conditions will apply:

-    the EEB rider will treat the new contract value on the date the ownership
     of the contract changes to your spouse (after the additional amount is paid
     into the contract) as if it is a purchase payment in calculating future
     values of "earnings at death."

-    the percentages of "earnings at death" payable will be based on your
     spouse's age at the time he or she elects to continue the contract.

-    the EEB rider charges described in "Charges -- EEB Rider Fee" will be
     assessed at the next contract anniversary (and all future anniversaries
     when the EEB rider is in force). These charges will be based on the total
     contract value on the anniversary, including the additional amounts paid
     into the contract under the EEP rider.

If your spouse chooses not to convert the EEP rider into an EEB, the standard
death benefit amount (or the MAV or 5-Year MAV death benefit amount, if
applicable,) will apply.

NOTE: For special tax considerations associated with the EEP, see "Taxes."



OPTIONAL LIVING BENEFITS -- CURRENTLY OFFERED

SECURESOURCE RIDERS

THE SECURESOURCE RIDERS ARE NOT AVAILABLE FOR RAVA4 ACCESS.

There are two optional SecureSource riders available under your contract:

-    SecureSource -- Single Life; or

-    SecureSource -- Joint Life.

The information in this section applies to both SecureSource riders, unless
otherwise noted.

The SecureSource -- Single Life rider covers one person. The SecureSource --
Joint Life Rider covers two spouses jointly who are named at contract issue. You
may elect only the SecureSource -- Single Life rider or the SecureSource --
Joint Life rider, not both, and you may not switch riders later.

The SecureSource rider is an optional benefit that you may select for an
additional annual charge if(1):

-    SINGLE LIFE: you are 80 or younger on the contract issue date, or , if an
     owner is a nonnatural person, then the annuitant is age 80 or younger on
     the contract issue date ; or

-    JOINT LIFE: you and your spouse are 80 or younger on the contract issue
     date.

(1)  The SecureSource rider is not available under an inherited qualified
     annuity.

You must elect the rider when you purchase your contract. The rider effective
date will be the contract issue date.

The SecureSource rider guarantees (unless the rider is terminated. See "Rider
Termination" heading below.) that regardless of the investment performance of
your contract you will be able to withdraw up to a certain amount each year from
the contract before the annuity payouts begin until:

-    SINGLE LIFE: you have recovered at minimum all of your purchase payments
     plus any purchase payment credit or, if later, until death (see "At Death"
     heading below) -- even if the contract value is zero.

-    JOINT LIFE: you have recovered at minimum all of your purchase payments
     plus any purchase payment credit or, if later, until the death of the last
     surviving covered spouse (see "Joint Life only: Covered Spouses" and "At
     Death" headings below) -- even if the contract value is zero.

Your contract provides for annuity payouts to begin on the settlement date (see
"Buying Your Contract -- Settlement Date"). Before the settlement date, you have
the right to surrender some or all of your contract value, less applicable
administrative, surrender and rider charges imposed under the contract at the
time of the surrender (see "Making the Most of Your Contract -- Surrenders").
Because your contract value will fluctuate depending on the performance of the
underlying funds in which the subaccounts invest, the contract itself does not
guarantee that you will be able to take a certain surrender amount each year
before the annuity payouts begin, nor does it guarantee the length of time over
which such surrenders can be made before the annuity payouts begin.

For the purposes of this rider, the term "withdrawal" is equal to the term
"surrender" in the contract or any other riders. Withdrawals will adjust
contract values and benefits in the same manner as surrenders.

The SecureSource rider may be appropriate for you if you intend to make periodic
withdrawals from your annuity contract and wish to ensure that market
performance will not adversely affect your ability to withdraw your principal
over time.



Under the terms of the SecureSource rider, the calculation of the amount which
can be withdrawn in each contract year varies depending on several factors,
including but not limited to the waiting period (see "Waiting period" heading
below) and whether or not the lifetime withdrawal benefit has become effective:

(1)  The basic withdrawal benefit gives you the right to take limited
     withdrawals in each contract year until the lifetime withdrawal benefit
     becomes effective and guarantees that over time the withdrawals will total
     an amount equal to, at minimum, your purchase payments plus any purchase
     payment credits (unless the rider is terminated. See "Rider Termination"
     heading below). Key terms associated with the basic withdrawal benefit are
     "Guaranteed Benefit Payment (GBP)", "Remaining Benefit Payment (RBP)",
     "Guaranteed Benefit Amount (GBA)" and "Remaining Benefit Amount (RBA)." See
     these headings below for more information.

(2)  The lifetime withdrawal benefit gives you the right, under certain limited
     circumstances defined in the rider, to take limited withdrawals until the
     later of:

-    SINGLE LIFE: death (see "At Death" heading below) or until the RBA (under
     the basic withdrawal benefit) is reduced to zero (unless the rider is
     terminated. See "Rider Termination" heading below);

-    JOINT LIFE: death of the last surviving covered spouse (see "At Death"
     heading below) or until the RBA (under the basic withdrawal benefit) is
     reduced to zero (unless the rider is terminated. See "Rider Termination"
     heading below).

Key terms associated with the lifetime withdrawal benefit are "Annual Lifetime
Payment (ALP)", "Remaining Annual Lifetime Payment (RALP)", "Single Life only:
Covered Person", "Joint Life only: Covered Spouses" and "Annual Lifetime Payment
Attained Age (ALPAA)." See these headings below for more information.

Only the basic withdrawal benefit will be in effect prior to the date that the
lifetime withdrawal benefit becomes effective. The lifetime withdrawal benefit
becomes effective automatically on the rider anniversary date after the:

-    SINGLE LIFE: covered person reaches age 65, or the rider effective date if
     the covered person is age 65 or older on the rider effective date (see
     "Annual Lifetime Payment Attained Age (ALPAA)" heading below);

-    JOINT LIFE: younger covered spouse reaches age 65, or the rider effective
     date if the younger covered spouse is age 65 or older on the rider
     effective date (see "Annual Lifetime Payment Attained Age (ALPAA)" and
     "Annual Lifetime Payment (ALP)" headings below).

Provided annuity payouts have not begun, the SecureSource rider guarantees that
you may take the following withdrawal amounts each contract year:

-    Before the establishment of the ALP, the rider guarantees that each year
     you have the option to cumulatively withdraw an amount equal to the value
     of the RBP at the beginning of the contract year;

-    After the establishment of the ALP, the rider guarantees that each year you
     have the option to cumulatively withdraw an amount equal to the value of
     the RALP or the RBP at the beginning of the contract year, but the rider
     does not guarantee withdrawal of the sum of both the RALP and the RBP in a
     contract year.

If you withdraw less than the allowed withdrawal amount in a contract year, the
unused portion cannot be carried over to the next contract year. As long as your
withdrawals in each contract year do not exceed the allowed annual withdrawal
amount under the rider:

-    SINGLE LIFE: and there has not been a contract ownership change or spousal
     continuation of the contract, the guaranteed amounts available for
     withdrawal will not decrease;

-    JOINT LIFE: the guaranteed amounts available for withdrawal will not
     decrease.

If you withdraw more than the allowed annual withdrawal amount in a contract
year, we call this an "excess withdrawal" under the rider. Excess withdrawals
trigger an adjustment of a benefit's guaranteed amount, which may cause it to be
reduced (see "GBA Excess Withdrawal Processing," "RBA Excess Withdrawal
Processing," and "ALP Excess Withdrawal Processing" headings below).



Please note that basic withdrawal benefit and lifetime withdrawal benefit each
has its own definition of the allowed annual withdrawal amount. Therefore a
withdrawal may be considered an excess withdrawal for purposes of the lifetime
withdrawal benefit only, the basic withdrawal benefit only, or both.

If your withdrawals exceed the greater of the RBP or the RALP, surrender charges
under the terms of the contract may apply (see "Charges -- Surrender Charges").
The amount we actually deduct from your contract value will be the amount you
request plus any applicable surrender charge. Market value adjustments, if
applicable, will also be made (see "Guarantee Period Accounts (GPAs) -- Market
Value Adjustment"). We pay you the amount you request. Any withdrawals you take
under the contract will reduce the value of the death benefits (see "Benefits in
Case of Death"). Upon full surrender of the contract, you will receive the
remaining contract value less any applicable charges (see "Making the Most of
Your Contract -- Surrenders").


The rider's guaranteed amounts can be increased at the specified intervals if
your contract value has increased. An annual step up feature is available at
each contract anniversary, subject to certain conditions, and may be applied
automatically to your contract or may require you to elect the step up (see
"Annual Step Up" heading below). If you exercise the annual step up election,
the spousal continuation step up election (see "Spousal Continuation Step Up"
heading below), change your PN program model portfolio or investment option, or
change from a PN program model portfolio to a fund of funds investment option,
the rider charge may change (see "Charges").


If you take withdrawals during the waiting period, any prior steps ups applied
will be reversed and step ups will not be available until the end of the waiting
period. You may take withdrawals after the waiting period without reversal of
prior step ups.

You should consider whether a SecureSource rider is appropriate for you because:

-    LIFETIME WITHDRAWAL BENEFIT LIMITATIONS: The lifetime withdrawal benefit is
     subject to certain limitations, including but not limited to:

(a)  SINGLE LIFE: Once the contract value equals zero, payments are made for as
     long as the oldest owner or, if an owner is a nonnatural person, the oldest
     annuitant is living (see "If Contract Value Reduces to Zero" heading
     below). However, if the contract value is greater than zero, the lifetime
     withdrawal benefit terminates when a death benefit becomes payable (see "At
     Death" heading below). Therefore, if there are multiple contract owners,
     the rider may terminate or the lifetime withdrawal benefit may be reduced
     when one of the contract owners dies the benefit terminates even though
     other contract owners are still living (except if the contract is continued
     under the spousal continuation provision of the contract).

     JOINT LIFE: Once the contract value equals zero, payments are made for as
     long as either covered spouse is living (see "If Contract Value Reduces to
     Zero" heading below). However, if the contract value is greater than zero,
     the lifetime withdrawal benefit terminates at the death of the last
     surviving covered spouse (see "At Death" heading below).

(b)  Excess withdrawals can reduce the ALP to zero even though the GBA, RBA, GBP
     and/or RBP values are greater than zero. If the both the ALP and the
     contract value are zero, the lifetime withdrawal benefit will terminate.

(c)  When the lifetime withdrawal benefit is first established, the initial ALP
     is based on

     (i)  SINGLE LIFE: the basic withdrawal benefit's RBA at that time (see
          "Annual Lifetime Payment (ALP)" heading below), unless there has been
          a spousal continuation or ownership change; or

     (ii) JOINT LIFE: the basic withdrawal benefit's RBA at that time (see
          "Annual Lifetime Payment (ALP)" heading below).

     Any withdrawal you take before the ALP is established reduces the RBA and
     therefore may result in a lower amount of lifetime withdrawals you are
     allowed to take.

(d)  Withdrawals can reduce both the contract value and the RBA to zero prior to
     the establishment of the ALP. If this happens, the contract and the rider
     will terminate.


-    USE OF PORTFOLIO NAVIGATOR PROGRAM REQUIRED: You must be invested in one of
     the available PN program model portfolios or investment options of the
     Portfolio Navigator. This requirement limits your choice of subaccounts,
     regular fixed account and GPAs (if available) to the PN program investment
     options or those that are in the model portfolio (if applicable) you have
     selected. This means you will not be able to allocate contract value to all
     of the subaccounts, GPAs or the regular fixed account that are available
     under the contract to contract owners who do not elect the rider. (See
     "Making the Most of Your Contract





     -- Portfolio Navigator Program.") You may allocate qualifying purchase
     payments and applicable purchase payment credits to the Special DCA fixed
     account, when available (see "The Special DCA Fixed Account"), and we will
     make monthly transfers into the model portfolio or investment option you
     have chosen. You may make two elective model portfolio or investment option
     changes per contract year; we reserve the right to limit elective model
     portfolio or investment option changes if required to comply with the
     written instructions of a fund (see "Market Timing").



     You can allocate your contract value to any available investment option
     during the following times: (1) prior to your first withdrawal and (2)
     following a benefit reset as described below but prior to any subsequent
     withdrawal. During these accumulation phases, you may request to change
     your model portfolio or investment option to any available investment
     option.



     Immediately following a withdrawal your contract value will be reallocated
     to the target investment option as shown in your contract if your current
     model portfolio or investment option is more aggressive than the target
     model portfolio or investment option. If you are in a static model
     portfolio this reallocation will be made to the applicable fund of funds
     investment option. This automatic reallocation is not included in the total
     number of allowed model changes per contract year and will not cause your
     rider fee to increase. The target investment option is currently the
     Moderate investment option. We reserve the right to change the target
     investment option to an investment option that is more aggressive than the
     current target investment option after 30 days written notice.



After you have taken a withdrawal and prior to any benefit reset as described
below, you are in a withdrawal phase. During withdrawal phases you may request
to change your model portfolio or investment option to the target investment
option or any model portfolio or investment option that is more conservative
than the target investment option without a benefit reset as described below. If
you are in a withdrawal phase and you choose to allocate your contract value to
an investment option that is more aggressive than the target investment option,
your rider benefit will be reset as follows:


(a)  the total GBA will be reset to the lesser of its current value or the
     contract value; and

(b)  the total RBA will be reset to the lesser of its current value or the
     contract value; and

(c)  the ALP, if established, will be reset to the lesser of its current value
     or 6% of the contract value; and

(d)  the GBP will be recalculated as described below, based on the reset GBA and
     RBA; and

(e)  the RBP will be recalculated as the reset GBP less all prior withdrawals
     made during the current contract year, but not less than zero; and

(f)  the RALP will be recalculated as the reset ALP less all prior withdrawals
     made during the current contract year, but not less than zero.


You may request to change your investment option (or change from a model
portfolio to an investment option) by written request on an authorized form or
by another method agreed to by us.


-    LIMITATIONS ON PURCHASE OF OTHER RIDERS UNDER YOUR CONTRACT: You may elect
     only the SecureSource -- Single Life rider or the SecureSource -- Joint
     Life rider. If you elect the SecureSource rider, you may not elect the
     Accumulation Benefit rider.

-    NON-CANCELABLE: Once elected, the SecureSource rider may not be cancelled
     (except as provided under "Rider Termination" heading below) and the fee
     will continue to be deducted until the contract or rider is terminated or
     the contract value reduces to zero (described below). Dissolution of
     marriage does not terminate the SecureSource -- Joint Life rider and will
     not reduce the fee we charge for this rider. The benefit under the
     SecureSource -- Joint Life rider continues for the covered spouse who is
     the owner of the contract (or annuitant in the case of nonnatural
     ownership). The rider will terminate at the death of the contract owner (or
     annuitant in the case of nonnatural ownership) because the original spouse
     will be unable to elect the spousal continuation provision of the contract
     (see "Joint Life only: Covered Spouses" below).

-    JOINT LIFE: LIMITATIONS ON CONTRACT OWNERS, ANNUITANTS AND BENEFICIARIES:
     Since the joint life benefit will terminate unless the surviving covered
     spouse continues the contract under the spousal continuation provision of
     the contract upon the owner's death, only ownership arrangements that
     permit such continuation are allowed at rider issue. In general, the
     covered spouses should be joint owners, or one covered spouse should be the
     owner and the other covered spouse should be named as the sole primary
     beneficiary.



     For non-natural ownership arrangements that allow for spousal continuation
     one covered spouse should be the annuitant and the other covered spouse
     should be the sole primary beneficiary. For revocable trust ownerships, the
     grantor of the trust must be the annuitant and the beneficiary must either
     be the annuitant's spouse or a trust that names the annuitant's spouse as
     the sole primary beneficiary. You are responsible for establishing
     ownership arrangements that will allow for spousal continuation.

If you select the SecureSource -- Joint Life rider, please consider carefully
whether or not you wish to change the beneficiary of your annuity contract. The
rider will terminate if the surviving covered spouse can not utilize the spousal
continuation provision of the contract when the death benefit is payable.

-    LIMITATIONS ON PURCHASE PAYMENTS: We reserve the right to limit the
     cumulative amount of purchase payments, subject to state restrictions. For
     current limitations, see "Buying Your Contract -- Purchase Payments."

-    INTERACTION WITH TOTAL FREE AMOUNT (TFA) CONTRACT PROVISION: The TFA is the
     amount you are allowed to surrender from the contract in each contract year
     without incurring a surrender charge (see "Charges -- Surrender Charge").
     The TFA may be greater than the RBP or RALP under this rider. Any amount
     you withdraw in a contract year under the contract's TFA provision that
     exceeds the RBP or RALP is subject to the excess withdrawal processing
     described below for the GBA, RBA and ALP.

You should consult your tax advisor before you select this optional rider if you
have any questions about the use of the rider in your tax situation because:

-    TAX CONSIDERATIONS FOR NONQUALIFIED ANNUITIES: Under current federal income
     tax law, withdrawals under nonqualified annuities, including withdrawals
     taken from the contract under the terms of the rider, are treated less
     favorably than amounts received as annuity payments under the contract (see
     "Taxes -- Nonqualified Annuities"). Also, withdrawals before age 59 1/2 may
     incur a 10% IRS early withdrawal penalty and may be considered taxable
     income. You should consult your tax advisor before you select this optional
     rider if you have any questions about the use of the rider in your tax
     situation.

-    TAX CONSIDERATIONS FOR QUALIFIED ANNUITIES: Qualified annuities have
     minimum distribution rules that govern the timing and amount of
     distributions from the annuity contract (see "Taxes -- Qualified Annuities
     -- Required Minimum Distributions"). If you have a qualified annuity, you
     may need to take an RMD that exceeds the guaranteed amount of withdrawal
     available under the rider and such withdrawals may reduce future benefits
     guaranteed under the rider. While the rider permits certain excess
     withdrawals to be made for the purpose of satisfying RMD requirements for
     your contract alone without reducing future benefits guaranteed under the
     rider, there can be no guarantee that changes in the federal income tax law
     after the effective date of the rider will not require a larger RMD to be
     taken, in which case, future guaranteed withdrawals under the rider could
     be reduced. See Appendix F for additional information.

-    LIMITATIONS ON TSAS: Your right to take withdrawals is restricted if your
     contract is a TSA (see "TSA -- Special Provisions"). Therefore, a
     SecureSource rider may be of limited value to you.

KEY TERMS AND PROVISIONS OF THE SECURESOURCE RIDER ARE DESCRIBED BELOW:

WITHDRAWAL: The amount by which your contract value is reduced as a result of
any withdrawal request. It may differ from the amount of your request due to any
surrender charge and any market value adjustment.

WAITING PERIOD: The period of time starting on the rider effective date during
which the annual step up is not available if you take withdrawals. The current
waiting period is three years.

GUARANTEED BENEFIT AMOUNT (GBA): The total cumulative withdrawals guaranteed by
the rider under the basic benefit. The maximum GBA is $5,000,000. The GBA cannot
be withdrawn and is not payable as a death benefit. It is an interim value used
to calculate the amount available for withdrawals each year under the basic
withdrawal benefit (see "Guaranteed Benefit Payment" below). At any time, the
total GBA is the sum of the individual GBAs associated with each purchase
payment.

THE GBA IS DETERMINED AT THE FOLLOWING TIMES, CALCULATED AS DESCRIBED:

-    At contract issue -- the GBA is equal to the initial purchase payment, plus
     any purchase payment credit.



-    When you make additional purchase payments -- each additional purchase
     payment has its own GBA equal to the amount of the purchase payment, plus
     any purchase payment credit.

-    At step up -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    When an individual RBA is reduced to zero -- the GBA that is associated
     with that RBA will also be set to zero.



-    When you make a withdrawal during the waiting period and after a step up --
     Any prior annual step ups will be reversed. Step up reversal means that the
     GBA associated with each purchase payment will be reset to the amount of
     that purchase payment, plus any purchase payment credit. The step up
     reversal will only happen once during the waiting period, when the first
     withdrawal is made.

-    When you make a withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the GBA remains unchanged. If
          there have been multiple purchase payments, both the total GBA and
          each payment's GBA remain unchanged.

     (b)  is greater than the total RBP -- GBA EXCESS WITHDRAWAL PROCESSING WILL
          BE APPLIED TO THE GBA. If the withdrawal is made during the waiting
          period, the excess withdrawal processing is applied AFTER any
          previously applied annual step ups have been reversed.

GBA EXCESS WITHDRAWAL PROCESSING

The total GBA will automatically be reset to the lesser of (a) the total GBA
immediately prior to the withdrawal; or (b) the contract value immediately
following the withdrawal. If there have been multiple purchase payments, each
payment's GBA after the withdrawal will be reset to equal that payment's RBA
after the withdrawal plus (a) times (b), where:

(a)  is the ratio of the total GBA after the withdrawal less the total RBA after
     the withdrawal to the total GBA before the withdrawal less the total RBA
     after the withdrawal; and

(b)  is each payment's GBA before the withdrawal less that payment's RBA after
     the withdrawal.

REMAINING BENEFIT AMOUNT (RBA): Each withdrawal you make reduces the amount that
is guaranteed by the rider as future withdrawals. At any point in time, the RBA
equals the amount of GBA that remains available for withdrawals for the
remainder of the contract's life, and total RBA is the sum of the individual
RBAs associated with each purchase payment. The maximum RBA is $5,000,000.

THE RBA IS DETERMINED AT THE FOLLOWING TIMES, CALCULATED AS DESCRIBED:

-    At contract issue -- the RBA is equal to the initial purchase payment plus
     any purchase payment credit.

-    When you make additional purchase payments -- each additional purchase
     payment has its own RBA initially set equal to that payment's GBA (the
     amount of the purchase payment, plus any purchase payment credit).

-    At step up -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    When you make a withdrawal during the waiting period and after a step up --
     Any prior annual step ups will be reversed. Step up reversal means that the
     RBA associated with each purchase payment will be reset to the amount of
     that purchase payment, plus any purchase payment credit. The step up
     reversal will only happen once during the waiting period, when the first
     withdrawal is made.

-    When you make a withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the total RBA is reduced by the
          amount of the withdrawal. If there have been multiple purchase
          payments, each payment's RBA is reduced in proportion to its RBP.

     (b)  is greater than the total RBP -- RBA EXCESS WITHDRAWAL PROCESSING WILL
          BE APPLIED TO THE RBA. Please note that if the withdrawal is made
          during the waiting period, the excess withdrawal processing is applied
          AFTER any previously applied annual step ups have been reversed.

RBA EXCESS WITHDRAWAL PROCESSING

The total RBA will automatically be reset to the lesser of (a) the contract
value immediately following the withdrawal, or (b) the total RBA immediately
prior to the withdrawal, less the amount of the withdrawal.



If there have been multiple purchase payments, both the total RBA and each
payment's RBA will be reset. The total RBA will be reset according to the excess
withdrawal processing described above. Each payment's RBA will be reset in the
following manner:

     1.   The withdrawal amount up to the total RBP is taken out of each RBA
          bucket in proportion to its individual RBP at the time of the
          withdrawal; and

     2.   The withdrawal amount above the total RBP and any amount determined by
          the excess withdrawal processing are taken out of each RBA bucket in
          proportion to its RBA at the time of the withdrawal.

GUARANTEED BENEFIT PAYMENT (GBP): At any time, the amount available for
withdrawal in each contract year after the waiting period, until the RBA is
reduced to zero, under the basic withdrawal benefit. At any point in time, each
purchase payment has its own GBP, which is equal to the lesser of that payment's
RBA or 7% of that payment's GBA, and the total GBP is the sum of the individual
GBPs.

During the waiting period, the guaranteed annual withdrawal amount may be less
than the GBP due to the limitations the waiting period imposes on your ability
to utilize both annual step-ups and withdrawals (see "Waiting Period" heading
above). The guaranteed annual withdrawal amount during the waiting period is
equal to the value of the RBP at the beginning of the contract year.

THE GBP IS DETERMINED AT THE FOLLOWING TIMES, CALCULATED AS DESCRIBED:

-    At contract issue -- the GBP is established as 7% of the GBA value.

-    At each contract anniversary -- each payment's GBP is reset to the lesser
     of that payment's RBA or 7% of that payment's GBA value.

-    When you make additional purchase payments -- each additional purchase
     payment has its own GBP equal to the purchase payment amount, plus any
     purchase payment credit multiplied by 7%.

-    At step up -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    When an individual RBA is reduced to zero -- the GBP associated with that
     RBA will also be reset to zero.

-    When you make a withdrawal during the waiting period and after a step up --
     Any prior annual step ups will be reversed. Step up reversal means that the
     GBA and the RBA associated with each purchase payment will be reset to the
     amount of that purchase payment plus any purchase payment credit. Each
     payment's GBP will be reset to 7% of the sum of purchase payment and any
     purchase payment credit. The step up reversal will only happen once during
     the waiting period, when the first withdrawal is made.

-    When you make a withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the GBP remains unchanged.

     (b)  is greater than the total RBP -- each payment's GBP is reset to the
          lesser of that payment's RBA or 7% of that payment's GBA value, based
          on the RBA and GBA after the withdrawal. If the withdrawal is made
          during the waiting period, the excess withdrawal processing is applied
          AFTER any previously applied annual step ups have been reversed.

REMAINING BENEFIT PAYMENT (RBP): The amount available for withdrawal for the
remainder of the contract year under the basic withdrawal benefit. At any point
in time, the total RBP is the sum of the RBPs for each purchase payment. During
the waiting period, when the guaranteed amount may be less than the GBP, the
value of the RBP at the beginning of the contract year will be that amount that
is actually guaranteed each contract year.



THE RBP IS DETERMINED AT THE FOLLOWING TIMES, CALCULATED AS DESCRIBED:

-    At the beginning of each contract year during the waiting period and prior
     to any withdrawal -- the RBP for each purchase payment is set equal to that
     purchase payment plus any purchase payment credit, multiplied by 7%.

-    At the beginning of any other contract year -- the RBP for each purchase
     payment is set equal to that purchase payment's GBP.

-    When you make additional purchase payments -- each additional purchase
     payment has its own RBP equal to that payment's GBP.

-    At step up -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    At spousal continuation -- (see "Spousal Option to Continue the Contract"
     heading below).

-    When an individual RBA is reduced to zero -- the RBP associated with that
     RBA will also be reset to zero.

-    When you make any withdrawal -- the total RBP is reset to equal the total
     RBP immediately prior to the withdrawal less the amount of the withdrawal,
     but not less than zero. If there have been multiple purchase payments, each
     payment's RBP is reduced proportionately. IF YOU WITHDRAW AN AMOUNT GREATER
     THAN THE RBP, GBA EXCESS WITHDRAWAL PROCESSING AND RBA EXCESS WITHDRAWAL
     PROCESSING ARE APPLIED and the amount available for future withdrawals for
     the remainder of the contract's life may be reduced by more than the amount
     of withdrawal. When determining if a withdrawal will result in the excess
     withdrawal processing, the applicable RBP will not yet reflect the amount
     of the current withdrawal.

SINGLE LIFE ONLY: COVERED PERSON: The person whose life is used to determine
when the ALP is established, and the duration of the ALP payments (see "Annual
Lifetime Payment (ALP)" heading below). The covered person is the oldest
contract owner. If the owner is a nonnatural person, e.g., a trust or
corporation, the covered person is the oldest annuitant. A spousal continuation
or a change of contract ownership may reduce the amount of the lifetime
withdrawal benefit and may change the covered person.

JOINT LIFE ONLY: COVERED SPOUSES: The contract owner and his or her legally
married spouse as defined under federal law, as named on the application and as
shown in the contract for as long as the marriage is valid and in effect. If the
contract owner is a nonnatural person (e.g., a revocable trust), the covered
spouses are the annuitant and the legally married spouse of the annuitant. The
covered spouses lives are used to determine when the ALP is established, and the
duration of the ALP payments (see "Annual Lifetime Payment (ALP)" heading
below). The covered spouses are established on the rider effective date and
cannot be changed.

ANNUAL LIFETIME PAYMENT ATTAINED AGE (ALPAA):

-    SINGLE LIFE: The covered person's age after which time the lifetime benefit
     can be established. Currently, the lifetime benefit can be established on
     the later of the contract effective date or the contract anniversary date
     on/following the date the covered person reaches age 65.

-    JOINT LIFE: The age of the younger covered spouse at which time the
     lifetime benefit is established.

ANNUAL LIFETIME PAYMENT (ALP): Once established, the ALP under the lifetime
withdrawal benefit is at any time the amount available for withdrawals in each
contract year after the waiting period until the later of:

-    SINGLE LIFE: death; or

-    JOINT LIFE: death of the last surviving covered spouse; or

-    the RBA is reduced to zero.

The maximum ALP is $300,000. Prior to establishment of the ALP, the lifetime
withdrawal benefit is not in effect and the ALP is zero.



During the waiting period, the guaranteed annual lifetime withdrawal amount may
be less than the ALP due to the limitations the waiting period imposes on your
ability to utilize both annual step-ups and withdrawals (see "Waiting Period"
heading above). The guaranteed annual lifetime withdrawal amount during the
waiting period is equal to the value of the RALP at the beginning of the
contract year.

THE ALP IS DETERMINED AT THE FOLLOWING TIMES:

-    SINGLE LIFE: The later of the contract effective date or the contract
     anniversary date on/following the date the covered person reaches age 65 --
     the ALP is established as 6% of the total RBA.

-    JOINT LIFE: The ALP is established as 6% of the total RBA on the earliest
     of the following dates:

     (a)  the rider effective date if the younger covered spouse has already
          reached age 65.

     (b)  the rider anniversary on/following the date the younger covered spouse
          reaches age 65.

     (c)  upon the first death of a covered spouse, then

          (1) the date we receive written request when the death benefit is not
          payable and the surviving covered spouse has already reached age 65;
          or

          (2) the date spousal continuation is effective when the death benefit
          is payable and the surviving covered spouse has already reached age
          65; or

          (3) the rider anniversary on/following the date the surviving covered
          spouse reaches age 65.

     (d)  Following dissolution of marriage of the covered spouses,

          (1) the date we receive written request if the remaining covered
          spouse who is the owner (or annuitant in the case of nonnatural
          ownership) has already reached age 65; or

          (2) the rider anniversary on/following the date the remaining covered
          spouse who is the owner (or annuitant in the case of nonnatural
          ownership) reaches age 65.

-    When you make additional purchase payments -- each additional purchase
     payment increases the ALP by 6% of the sum of the purchase payment plus any
     purchase payment credits.

-    At step ups -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    SINGLE LIFE: At spousal continuation or contract ownership change -- (see
     "Spousal Option to Continue the Contract" and "Contract Ownership Change"
     headings below).

-    When you make a withdrawal during the waiting period and after a step up --
     Any prior annual step ups will be reversed. Step up reversal means that the
     ALP will be reset to equal total purchase payments plus any purchase
     payment credit, multiplied by 6%. The step up reversal will only happen
     once during the waiting period, when the first withdrawal is made.

-    When you make a withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the RALP -- the ALP remains unchanged.

     (b)  is greater than the RALP -- ALP EXCESS WITHDRAWAL PROCESSING WILL BE
          APPLIED TO THE ALP. If the withdrawal is made during the waiting
          period, the excess withdrawal processing is applied AFTER any
          previously applied annual step ups have been reversed.



ALP EXCESS WITHDRAWAL PROCESSING

The ALP is reset to the lesser of the ALP immediately prior to the withdrawal,
or 6% of the contract value immediately following the withdrawal.

REMAINING ANNUAL LIFETIME PAYMENT (RALP): The amount available for withdrawal
for the remainder of the contract year under the lifetime withdrawal benefit.
During the waiting period, when the guaranteed annual withdrawal amount may be
less than the ALP, the value of the RALP at the beginning of the contract year
will be the amount that is actually guaranteed each contract year. Prior to
establishment of the ALP, the lifetime withdrawal benefit is not in effect and
the RALP is zero.

-    THE RALP IS DETERMINED AT THE FOLLOWING TIMES:

-    The RALP is established at the same time as the ALP, and:

     (a)  During the waiting period and prior to any withdrawals -- the RALP is
     established equal to the purchase payments, plus purchase payment credit,
     multiplied by 6%.

     (b)  At any other time -- the RALP is established equal to the ALP less all
     prior withdrawals made in the contract year but not less than zero.

-    At the beginning of each contract year during the waiting period and prior
     to any withdrawals -- the RALP is set equal to the total purchase payments
     plus any purchase payment credit, multiplied by 6%.

-    At the beginning of any other contract year -- the RALP is set equal to
     ALP.

-    When you make additional purchase payments -- each additional purchase
     payment increases the RALP by 6% of the sum of the purchase payment amount
     plus any purchase payment credit.

-    At step ups -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    When you make any withdrawal -- the RALP equals the RALP immediately prior
     to the withdrawal less the amount of the withdrawal but not less than zero.
     IF YOU WITHDRAW AN AMOUNT GREATER THAN THE RALP, ALP EXCESS WITHDRAWAL
     PROCESSING is APPLIED and may reduce the amount available for future
     withdrawals. When determining if a withdrawal will result in excess
     withdrawal processing, the applicable RALP will not yet reflect the amount
     of the current withdrawal.

REQUIRED MINIMUM DISTRIBUTIONS (RMD): If you are taking RMDs from your contract
and the RMD calculated separately for your contract is greater than the RBP or
the RALP on the most recent contract anniversary, the portion of the RMD that
exceeds the RBP or RALP on the most recent rider anniversary will not be subject
to excess withdrawal processing provided that the following conditions are met:

-    The RMD is for your contract alone;

-    The RMD is based on your recalculated life expectancy taken from the
     Uniform Lifetime Table under the Code; and

-    The RMD amount is otherwise based on the requirements of section 401(a)
     (9), related Code provisions and regulations there under that were in
     effect on the effective date of the rider.

RMD rules follow the calendar year which most likely does not coincide with your
contract year and therefore may limit when you can take your RMD and not be
subject to excess withdrawal processing.

Withdrawal amounts greater than the RBP or RALP on the contract anniversary date
that do not meet these conditions will result in excess withdrawal processing as
described above. See Appendix F for additional information.

STEP UP DATE: The date any step up becomes effective, and depends on the type of
step up being applied (see "Annual Step Up" and "Spousal Continuation Step Up"
headings below).



ANNUAL STEP UP: Beginning with the first contract anniversary, an increase of
the GBA, RBA, GBP, RBP, ALP and/or RALP values may be available. A step up does
not create contract value, guarantee the performance of any investment option,
or provide a benefit that can be withdrawn or paid upon death. Rather, a step up
determines the current values of the GBA, RBA, GBP, RBP, ALP and RALP, and may
extend the payment period or increase the allowable payment.

The annual step up may be available as described below, subject to the following
rules:

-    The annual step up is effective on the step up date.

-    Only one step up is allowed each contract year.

-    If you take any withdrawals during the waiting period, any previously
     applied step ups will be reversed and the Annual step up will not be
     available until the end of the waiting period.

-    On any rider anniversary where the RBA or, if established, the ALP would
     increase and the application of the step up would not increase the rider
     charge, the annual step up will be automatically applied to your contract,
     and the step up date is the contract anniversary date.

-    If the application of the step up would increase the rider charge, the
     annual step up is not automatically applied. Instead, you have the option
     to step up for 30 days after the contract anniversary as long as either the
     contract value is greater than the total RBA or 6% of the contract value is
     greater than the ALP, if established, on the step-up date. If you exercise
     the elective annual step up option, you will pay the rider charge in effect
     on the step up date. If you wish to exercise the elective annual step up
     option, we must receive a request from you or your financial advisor. The
     step up date is the date we receive your request to step up. If your
     request is received after the close of business, the step up date will be
     the next valuation day.

-    The ALP and RALP are not eligible for step ups until they are established.
     Prior to being established, the ALP and RALP values are both zero.

-    Please note it is possible for the ALP to step up even if the RBA or GBA do
     not step up, and it is also possible for the RBA and GBA to step up even if
     the ALP does not step up.

The annual step up resets the GBA, RBA, GBP, RBP, ALP and RALP values as
follows:

-    The total RBA will be reset to the greater of the total RBA immediately
     prior to the step up date or the contract value on the step up date.

-    The total GBA will be reset to the greater of the total GBA immediately
     prior to the step up date or the contract value on the step up date.

-    The total GBP will be reset using the calculation as described above based
     on the increased GBA and RBA.

-    The total RBP will be reset as follows:

     (a)  During the waiting period and prior to any withdrawals, the RBP will
          not be affected by the step up.

     (b)  At any other time, the RBP will be reset to the increased GBP less all
          prior withdrawals made in the current contract year, but not less than
          zero.

-    The ALP will be reset to the greater of the ALP immediately prior to the
     step up date or 6% of the contract value on the step up date.

-    The RALP will be reset as follows:

     (a)  During the waiting period and prior to any withdrawals, the RALP will
          not be affected by the step up.

     (b)  At any other time, the RALP will be reset to the increased ALP less
          all prior withdrawals made in the current contract year, but not less
          than zero.



SPOUSAL OPTION TO CONTINUE THE CONTRACT UPON OWNER'S DEATH:

SINGLE LIFE: If a surviving spouse elects to continue the contract and continues
the contract as the new owner under the spousal continuation provision of the
contract, the SecureSource -- Single Life rider also continues. When the spouse
elects to continue the contract, any remaining waiting period is cancelled and
any waiting period limitations on withdrawals and step-ups terminate; if the
covered person changes due to a spousal continuation the GBA, RBA, GBP, RBP, ALP
and RALP values are affected as follows:

-    The GBA, RBA and GBP values remain unchanged.

-    The RBP is automatically reset to the GBP less all prior withdrawals made
     in the current contract year, but not less than zero.

-    If the ALP has not yet been established and the new covered person has not
     yet reached age 65 as of the date of continuation -- the ALP will be
     established on the contract anniversary following the date the covered
     person reaches age 65 as the lesser of the RBA or the contract anniversary
     value, multiplied by 6%. The RALP will be established on the same date
     equal to the ALP.

-    If the ALP has not yet been established but the new covered person is age
     65 or older as of the date of continuation -- the ALP will be established
     on the date of continuation as the lesser of the RBA or the contract value,
     multiplied by 6%. The RALP will be established on the same date in an
     amount equal to the ALP less all prior withdrawals made in the current
     contract year, but not less than zero.

-    If the ALP has been established but the new covered person has not yet
     reached age 65 as of the date of continuation -- the ALP and RALP will be
     automatically reset to zero for the period of time beginning with the date
     of continuation and ending with the contract anniversary following the date
     the covered person reaches age 65. At the end of this time period, the ALP
     will be reset to the lesser of the RBA or the anniversary contract value,
     multiplied by 6%, and the RALP will be reset to the ALP.

-    If the ALP has been established and the new covered person is age 65 or
     older as of the date of continuation -- the ALP will be automatically reset
     to the lesser of the current ALP or 6% of the contract value on the date of
     continuation. The RALP will be reset to the ALP less all prior withdrawals
     made in the current contract year, but not less than zero.

Please note that the lifetime withdrawal benefit amount may be reduced as a
result of the spousal continuation.

JOINT LIFE: If a surviving spouse is a covered spouse and elects the spousal
continuation provision of the contract as the new owner, the SecureSource --
Joint Life rider also continues. When the spouse elects to continue the
contract, any remaining waiting period is cancelled and any waiting period
limitations on withdrawals and step-ups terminate. The surviving covered spouse
can name a new beneficiary; however, a new covered spouse cannot be added to the
rider.

SPOUSAL CONTINUATION STEP UP: At the time of spousal continuation, a step-up may
be available. All annual step-up rules (see "Annual Step-Up" heading above),
other than those that apply to the waiting period, also apply to the spousal
continuation step-up. If the spousal continuation step-up is processed
automatically, the step-up date is the valuation date spousal continuation is
effective. If not, the spouse must elect the step up and must do so within 30
days of the spousal continuation date. If the spouse elects the spousal
continuation step up, the step-up date is the valuation date we receive the
spouse's written request to step-up if we receive the request by the close of
business on that day, otherwise the next valuation date.

RULES FOR SURRENDER PROVISION OF YOUR CONTRACT: Minimum contract values
following surrender no longer apply to your contract. For surrenders, the
surrender will be made from the variable subaccounts, and the Regular Fixed
Account (if applicable) in the same proportion as your interest in each bears to
the contract value less amounts in any Special DCA fixed account. You cannot
specify from which accounts the surrender is to be made.

IF CONTRACT VALUE REDUCES TO ZERO: If the contract value reduces to zero and the
total RBA remains greater than zero, you will be paid in the following
scenarios:

1)   The ALP has not yet been established and the contract value is reduced to
     zero as a result of fees or charges or a withdrawal that is less than or
     equal to the RBP. In this scenario, you can choose to:

     (a)  receive the remaining schedule of GBPs until the RBA equals zero; or



     (b)  SINGLE LIFE: wait until the rider anniversary on/following the date
          the covered person reaches age 65, and then receive the ALP annually
          until the latter of (i) the death of the covered person, or (ii) the
          RBA is reduced to zero; or

     (c)  JOINT LIFE: wait until the rider anniversary on/following the date the
          younger covered spouse reaches age 65, and then receive the ALP
          annually until the latter of (i) the death of the last surviving
          covered spouse, or (ii) the RBA is reduced to zero.

We will notify you of this option. If no election is made, the ALP will be paid.

2)   The ALP has been established and the contract value reduces to zero as a
     result of fees or charges, or a withdrawal that is less than or equal to
     both the RBP and the RALP. In this scenario, you can choose to receive:

     (a)  the remaining schedule of GBPs until the RBA equals zero; or

     (b)  SINGLE LIFE: the ALP annually until the latter of (i) the death of the
          covered person, or (ii) the RBA is reduced to zero; or.

     (c)  JOINT LIFE: the ALP annually until the latter of (i) the death of the
          last surviving covered spouse, or (ii) the RBA is reduced to zero.

We will notify you of this option. If no election is made, the ALP will be paid.

3)   The ALP has been established and the contract value falls to zero as a
     result of a withdrawal that is greater than the RALP but less than or equal
     to the RBP. In this scenario, the remaining schedule of GBPs will be paid
     until the RBA equals zero.

4)   The ALP has been established and the contract value falls to zero as a
     result of a withdrawal that is greater than the RBP but less than or equal
     to the RALP. In this scenario, the ALP will be paid annually until the
     death of the:

-    SINGLE LIFE: covered person;

-    JOINT LIFE: last surviving covered spouse.

Under any of these scenarios:

-    The annualized amounts will be paid to you in the frequency you elect. You
     may elect a frequency offered by us at the time payments begin. Available
     payment frequencies will be no less frequent than annually;

-    We will no longer accept additional purchase payments;

-    You will no longer be charged for the rider;

-    Any attached death benefit riders will terminate; and

-    SINGLE LIFE: The death benefit becomes the remaining payments, if any,
     until the RBA is reduced to zero.

-    JOINT LIFE: If the owner had been receiving the ALP, upon the first death
     the ALP will continue to be paid annually until the later of: 1) the death
     of the last surviving covered spouse or 2) the RBA is reduced to zero. In
     all other situations the death benefit becomes the remaining payments, if
     any, until the RBA is reduced to zero.

The SecureSource rider and the contract will terminate under either of the
following two scenarios:

-    If the contract value falls to zero as a result of a withdrawal that is
     greater than both the RALP and the RBP. This is full surrender of the
     contract value.

-    If the contract value falls to zero as a result of a withdrawal that is
     greater than the RALP but less than or equal to the RBP, and the total RBA
     is reduced to zero.

AT DEATH:



SINGLE LIFE: If the contract value is greater than zero when the death benefit
becomes payable, the beneficiary may: 1) elect to take the death benefit under
the terms of the contract, 2) take the fixed payout option available under this
rider, or 3) continue the contract under the spousal continuation provision of
the contract above.

If the contract value equals zero and the death benefit becomes payable, the
following will occur:

-    If the RBA is greater than zero and the owner has been receiving the GBP
     each year, the GBP will continue to be paid to the beneficiary until the
     RBA equals zero.

-    If the covered person dies and the RBA is greater than zero and the owner
     has been receiving the ALP each year, the ALP will continue to be paid to
     the beneficiary until the RBA equals zero.

-    If the covered person is still alive and the RBA is greater than zero and
     the owner has been receiving the ALP each year, the ALP will continue to be
     paid to the beneficiary until the later of the death of the covered person
     or the RBA equals zero.

-    If the covered person is still alive and the RBA equals zero and the owner
     has been receiving the ALP each year, the ALP will continue to be paid to
     the beneficiary until the death of the covered person.

-    If the covered person dies and the RBA equals zero, the benefit terminates.
     No further payments will be made.

JOINT LIFE: If the death benefit becomes payable at the death of a covered
spouse, the surviving covered spouse must utilize the spousal continuation
provision of the contract and continue the contract as the new owner to continue
the joint benefit. If spousal continuation is not available under the terms of
the contract, the rider terminates. The lifetime benefit of this rider ends at
the death of the last surviving covered spouse.

If the contract value is greater than zero when the death benefit becomes
payable, the beneficiary may: 1) elect to take the death benefit under the terms
of the contract, 2) take the fixed payout option available under this rider, or
3) continue the contract under the spousal continuation provision of the
contract above.

If the contract value equals zero at the first death of a covered spouse, the
ALP will continue to be paid annually until the later of: 1) the death of the
last surviving covered spouse or 2) the RBA is reduced to zero.

If the contract value equals zero at the death of the last surviving covered
spouse, the following will occur:

-    If the RBA is greater than zero and the owner has been receiving the GBP
     each year, the GBP will continue to be paid to the beneficiary until the
     RBA equals zero.

-    If the RBA is greater than zero and the owner has been receiving the ALP
     each year, the ALP will continue to be paid to the beneficiary until the
     RBA equals zero.

-    If the RBA equals zero, the benefit terminates. No further payments will be
     made.

CONTRACT OWNERSHIP CHANGE:

SINGLE LIFE: If the contract changes ownership (see "Changing Ownership"), the
GBA, RBA, GBP, RBP values will remain unchanged and the ALP and RALP will be
reset as follows. Our current administrative practice is to only reset the ALP
and RALP if the covered person changes due to the ownership change.

-    If the ALP has not yet been established and the new covered person has not
     yet reached age 65 as of the ownership change date -- the ALP and the RALP
     will be established on the contract anniversary following the date the
     covered person reaches age 65. The ALP will be set equal to the lesser of
     the RBA or the anniversary contract value, multiplied by 6%. If the
     anniversary date occurs during the waiting period and prior to a
     withdrawal, the RALP will be set equal to the lesser of the ALP or total
     purchase payments plus any purchase payment credits, multiplied by 6%. If
     the anniversary date occurs at any other time, the RALP will be set equal
     to the ALP.



-    If the ALP has not yet been established but the new covered person is age
     65 or older as of the ownership change date -- the ALP and the RALP will be
     established on the ownership change date. The ALP will be set equal to the
     lesser of the RBA or the contract value, multiplied by 6%. If the ownership
     change date occurs during the waiting period and prior to a withdrawal, the
     RALP will be set to the lesser of the ALP or total purchase payments plus
     any purchase payment credits multiplied by 6%. If the ownership change date
     occurs at any other time, the RALP will be set to the ALP less all prior
     withdrawals made in the current contract year but not less than zero.

-    If the ALP has been established but the new covered person has not yet
     reached age 65 as of the ownership change date -- the ALP and the RALP will
     be reset to zero for the period of time beginning with the ownership change
     date and ending with the contract anniversary following the date the
     covered person reaches age 65. At the end of this time period, the ALP will
     be reset to the lesser of the RBA or the anniversary contract value,
     multiplied by 6%. If the time period ends during the waiting period and
     prior to any withdrawals, the RALP will be reset to the lesser of the ALP
     or total purchase payments plus any purchase payment credits, multiplied by
     6%. If the time period ends at any other time, the RALP will be reset to
     the ALP.

-    If the ALP has been established and the new covered person is age 65 or
     older as of the ownership change date -- the ALP and the RALP will be reset
     on the ownership change date. The ALP will be reset to the lesser of the
     current ALP or 6% of the contract value. If the ownership change date
     occurs during the waiting period and prior to a withdrawal, the RALP will
     be reset to the lesser of the ALP or total purchase payments plus any
     purchase payment credits multiplied by 6%. If the ownership change date
     occurs at any other time, the RALP will be reset to the ALP less all prior
     withdrawals made in the current contract year but not less than zero.

Please note that the lifetime withdrawal benefit amount may be reduced as a
result of the ownership change.

JOINT LIFE: Ownership changes are only allowed between the covered spouses or
their revocable trust(s). No other ownership changes are allowed as long as the
rider is in force.

REMAINING BENEFIT AMOUNT (RBA) PAYOUT OPTION: Several annuity payout plans are
available under the contract. As an alternative to these annuity payout plans, a
fixed annuity payout option is available under the SecureSource riders.

Under this option the amount payable each year will be equal to the remaining
schedule of GBPs, but the total amount paid over the life of the annuity will
not exceed the current total RBA at the time you begin this fixed annuity payout
option. These annualized amounts will be paid in the frequency that you elect.
The frequencies will be among those offered by us at that time but will be no
less frequent than annually. If, at the death of the owner, total payouts have
been made for less than the RBA, the remaining payouts will be paid to the
beneficiary (see "The Annuity Payout Period" and "Taxes").

This option may not be available if the contract is issued to qualify under
section 403 or 408 of the Code, as amended. For such contracts, this option will
be available only if the guaranteed payment period is less than the life
expectancy of the owner at the time the option becomes effective. Such life
expectancy will be computed using a life expectancy table published by the IRS.

This annuity payout option may also be elected by the beneficiary of a contract
as a settlement option. Whenever multiple beneficiaries are designated under the
contract, each such beneficiary's share of the proceeds if they elect this
option will be in proportion to their applicable designated beneficiary
percentage. Beneficiaries of nonqualified contracts may elect this settlement
option subject to the distribution requirements of the contract. We reserve the
right to adjust the remaining schedule of GBPs if necessary to comply with the
Code.

RIDER TERMINATION

The SecureSource rider cannot be terminated either by you or us except as
follows:

1.   SINGLE LIFE: After the death benefit is payable the rider will terminate
     if:

     (a)  any one other than your spouse continues the contract, or

     (b)  your spouse does not use the spousal continuation provision of the
          contract to continue the contract.

2.   JOINT LIFE: After the death benefit is payable the rider will terminate if:



     (a)  any one other than a covered spouse continues the contract, or

     (b)  a covered spouse does not use the spousal continuation provision of
          the contract to continue the contract.

3.   Annuity payouts under an annuity payout plan will terminate the rider.

4.   Termination of the contract for any reason will terminate the rider.

GUARANTEED MINIMUM ACCUMULATION BENEFIT (ACCUMULATION BENEFIT) RIDER

THE ACCUMULATION BENEFIT RIDER IS NOT AVAILABLE FOR RAVA 4 ACCESS.

The Accumulation Benefit rider is an optional benefit that you may select for an
additional charge. It is available for nonqualified annuities and qualified
annuities except under 401(a) plans. The Accumulation Benefit rider specifies a
waiting period that ends on the benefit date. The Accumulation Benefit rider
provides a one-time adjustment to your contract value on the benefit date if
your contract value is less than the Minimum Contract Accumulation Value
(defined below) on that benefit date. On the benefit date, if the contract value
is equal to or greater than the Minimum Contract Accumulation Value, as
determined under the Accumulation Benefit rider, the Accumulation Benefit rider
ends without value and no benefit is payable.

If the contract value falls to zero as the result of adverse market performance
or the deduction of fees and/or charges at any time during the waiting period
and before the benefit date, the contract and all riders, including the
Accumulation Benefit rider will terminate without value and no benefits will be
paid. EXCEPTION: if you are still living on the benefit date, we will pay you an
amount equal to the Minimum Contract Accumulation Value as determined under the
Accumulation Benefit rider on the valuation date your contract value reached
zero.

If you are (or if the owner is a non-natural person, then the annuitant is) 80
or younger at contract issue and this rider is available in your state, you may
elect the Accumulation Benefit rider at the time you purchase your contract and
the rider effective date will be the contract issue date. The Accumulation
Benefit rider may not be terminated once you have elected it except as described
in the "Terminating the Rider" section below. An additional charge for the
Accumulation Benefit rider will be assessed annually during the waiting period.
The rider ends when the waiting period expires and no further benefit will be
payable and no further charges for the rider will be deducted. The Accumulation
Benefit rider may not be purchased with the optional GWB for Life rider or
SecureSource rider. When the rider ends, you may be able to purchase another
optional rider we then offer by written request received within 30 days of that
contract anniversary date.

You should consider whether an Accumulation Benefit rider is appropriate for you
because:


-    you must participate in the PN program and you must be invested in one of
     the available model portfolios or investment options. This requirement
     limits your choice of subaccounts, regular fixed account and GPAs (if
     available) to the PN program investment options or those that are in the
     model portfolio (if applicable) you have selected. This means you will not
     be able to allocate contract value to all of the subaccounts, GPAs or the
     regular fixed account that are available under the contract to other
     contract owners who do not elect this rider. You may allocate qualifying
     purchase payments and applicable purchase payment credits to the Special
     DCA fixed account, when available (see "The Special DCA Fixed Account"),
     and we will make monthly transfers into the model portfolio or investment
     option you have chosen. (See "Making the Most of Your Contract -- Portfolio
     Navigator Program");


-    you may not make additional purchase payments to your contract during the
     waiting period after the first 180 days immediately following the effective
     date of the Accumulation Benefit rider. Some exceptions apply (see
     "Additional Purchase Payments with Elective Step Up" below);

-    if you purchase this contract as a qualified annuity, for example, an IRA,
     you may need to take partial surrenders from your contract to satisfy the
     RMDs under the Code. Partial surrenders, including those used to satisfy
     RMDs, will reduce any potential benefit that the Accumulation Benefit rider
     provides. You should consult your tax advisor if you have any questions
     about the use of this rider in your tax situation;

-    if you think you may surrender all of your contract value before you have
     held your contract with this benefit rider attached for 10 years, or you
     are considering selecting an annuity payout option within 10 years of the
     effective date of your contract, you should



     consider whether this optional benefit is right for you. You must hold the
     contract a minimum of 10 years from the effective date of the Accumulation
     Benefit rider, which is the length of the waiting period under the
     Accumulation Benefit rider, in order to receive the benefit, if any,
     provided by the Accumulation Benefit rider. In some cases, as described
     below, you may need to hold the contract longer than 10 years in order to
     qualify for any benefit the Accumulation Benefit rider may provide;

-    the 10 year waiting period under the Accumulation Benefit rider will
     restart if you exercise the Elective Step-Up Option (described below) or
     your surviving spouse exercises the spousal continuation Elective Step-Up
     (described below); and


-    the 10 year waiting period under the Accumulation Benefit rider may be
     restarted if you elect to change your PN program model portfolio or
     investment option to one that causes the Accumulation Benefit rider charge
     to increase (see "Charges").


Be sure to discuss with your financial advisor whether an Accumulation Benefit
rider is appropriate for your situation.

HERE ARE SOME GENERAL TERMS THAT ARE USED TO DESCRIBE THE OPERATION OF THE
ACCUMULATION BENEFIT:

BENEFIT DATE: This is the first valuation date immediately following the
expiration of the waiting period.

MINIMUM CONTRACT ACCUMULATION VALUE (MCAV): An amount calculated under the
Accumulation Benefit rider. The contract value will be increased to equal the
MCAV on the benefit date if the contract value on the benefit date is less than
the MCAV on the benefit date.

ADJUSTMENTS FOR PARTIAL SURRENDERS: The adjustment made for each partial
surrender from the contract is equal to the amount derived from multiplying (a)
and (b) where:

(a)  is 1 minus the ratio of the contract value on the date of (but immediately
     after) the partial surrender to the contract value on the date of (but
     immediately prior to) the partial surrender; and

(b)  is the MCAV on the date of (but immediately prior to) the partial
     surrender.

WAITING PERIOD: The waiting period for the rider is 10 years.


We reserve the right to restart the waiting period on the latest contract
anniversary if you change your PN program investment option (or change from a PN
program model portfolio to an investment option) after we have exercised our
rights to increase the rider fee.


Your initial MCAV is equal to your initial purchase payment and any purchase
payment credit. It is increased by the amount of any subsequent purchase
payments and purchase payment credits received within the first 180 days that
the rider is effective. It is reduced by any adjustments for partial surrenders
made during the waiting period.

AUTOMATIC STEP UP

On each contract anniversary after the effective date of the rider, the MCAV
will be set to the greater of:

1. 80% of the contract value on the contract anniversary; or

2. the MCAV immediately prior to the automatic step up.

The automatic step up does not create contract value, guarantee the performance
of any investment option, or provide a benefit that can be surrendered or paid
upon death. Rather, the Automatic Step Up is an interim calculation used to
arrive at the final MCAV, which is used to determine whether a benefit will be
paid under the rider on the benefit date.

The automatic step up of the MCAV does not restart the waiting period or
increase the charge (although the total fee for the rider may increase).



ELECTIVE STEP UP OPTION

Within thirty days following each contract anniversary after the rider effective
date, but prior to the benefit date, you may notify us in writing that you wish
to exercise the annual elective step up option. You may exercise this elective
step up option only once per contract year during this 30 day period. If your
contract value on the valuation date we receive your written request to step up
is greater than the MCAV on that date, your MCAV will increase to 100% of that
contract value.

When you exercise the annual elective step up, we may be charging more for the
Accumulation Benefit rider at that time. If your MCAV is increased as a result
of the elective step up and we have increased the charge for the Accumulation
Benefit rider, you will pay the charge that is in effect on the valuation date
we receive your written request to step up for the entire contract year. In
addition, the waiting period will restart as of the most recent contract
anniversary. Failure to exercise this elective step up in subsequent years will
not reinstate any prior waiting period. Rather, the waiting period under the
rider will always commence from the most recent anniversary for which the
elective step up option was exercised.

The elective step up does not create contract value, guarantee the performance
of any investment option or provide any benefit that can be surrendered or paid
upon death. Rather the elective step up is an interim calculation used to arrive
at the final MCAV, which is used to determine whether a benefit will be paid
under the rider on the benefit date.

The elective step up option is not available to non-spouse beneficiaries that
continue the contract during the waiting period.

ADDITIONAL PURCHASE PAYMENTS WITH ANNUAL ELECTIVE STEP UPS

If your MCAV is increased as a result of Elective Step Up, you have 180 days
from the latest contract anniversary to make additional purchase payments, if
allowed under the base contract. The MCAV will include the amount of any
additional purchase payments and purchase payment credits (if applicable)
received during this period.

SPOUSAL CONTINUATION

If a spouse chooses to continue the contract under the spousal continuation
provision, the rider will continue as part of the contract. Once, within the
thirty days following the date of spousal continuation, the spouse may choose to
exercise an elective step up. The spousal continuation elective step up is in
addition to the annual elective step up. If the contract value on the valuation
date we receive the written request to exercise this option is greater than the
MCAV on that date, we will increase the MCAV to that contract value. If the MCAV
is increased as a result of the elective step up and we have increased the
charge for the Accumulation Benefit rider, the spouse will pay the charge that
is in effect on the valuation date we receive their written request to step up
for the entire contract year. In addition, the waiting period will restart as of
the most recent contract anniversary.

TERMINATING THE RIDER

The rider will terminate under the following conditions:

     The rider will terminate before the benefit date without paying a benefit
     on the date:

-    you take a full surrender; or

-    annuitization begins; or

-    the contract terminates as a result of the death benefit being paid.

     The rider will terminate on the benefit date.

For an example, see Appendix E.



OPTIONAL LIVING BENEFITS -- PREVIOUSLY OFFERED

GUARANTOR WITHDRAWAL BENEFIT FOR LIFE (GWB FOR LIFE) RIDER

Disclosure for GWB for Life rider may be found in the Appendix G.

THE ANNUITY PAYOUT PERIOD

As owner of the contract, you have the right to decide how and to whom annuity
payouts will be made starting at the settlement date. You may select one of the
annuity payout plans outlined below, or we may mutually agree on other payout
arrangements. We do not deduct any surrender charges under the payout plans
listed below except under Plan E.

You also decide whether we will make annuity payouts on a fixed or variable
basis, or a combination of fixed and variable. The amount available to purchase
payouts under the plan you select is the contract value on your settlement date,
plus or minus any applicable MVA on GPAs and less any applicable premium tax.
During the annuity payout period, you cannot invest in more than five
subaccounts at any one time unless we agree otherwise.

AMOUNTS OF FIXED AND VARIABLE PAYOUTS DEPEND ON:

-   the annuity payout plan you select;

-    your age and, in most cases, sex;

-    the annuity table in the contract; and

-    the amounts you allocated to the accounts at settlement.

In addition, for variable payouts only, amounts depend on the investment
performance of the subaccounts you select. These payouts will vary from month to
month because the performance of the funds will fluctuate. Fixed payouts remain
the same from month to month.

For information with respect to transfers between accounts after annuity payouts
begin, see "Making the Most of Your Contract -- Transfer policies."

ANNUITY TABLES

The annuity tables in your contract (Table A and Table B) show the amount of the
monthly payout for each $1,000 of contract value according to your age and, when
applicable, your sex. (Where required by law, we will use a unisex table of
settlement rates.)

Table A shows the amount of the first variable payout assuming that the contract
value is invested at the beginning of the annuity payout period and earns a 5%
rate of return, which is reinvested and helps to support future payouts. If you
ask us at least 30 days before the settlement date, we will substitute an
annuity table based on an assumed 3.5% investment rate for the 5% Table A in the
contract. The assumed investment rate affects both the amount of the first
payout and the extent to which subsequent payouts increase or decrease. For
example, annuity payouts will increase if the investment return is above the
assumed investment rate and payouts will decrease if the return is below the
assumed investment rate. Using the 5% assumed interest rate results in a higher
initial payout but later payouts will increase more slowly when annuity unit
values rise and decrease more rapidly when they decline.

Table B shows the minimum amount of each fixed payout. Amounts in Table B are
based on the guaranteed annual effective interest rate shown in your contract.
We declare current payout rates that we use in determining the actual amount of
your fixed payout. The current payout rates will equal or exceed the guaranteed
payout rates shown in Table B. We will furnish these rates to you upon request.



ANNUITY PAYOUT PLANS

You may choose any one of these annuity payout plans by giving us written
instructions at least 30 days before contract value is used to purchase the
payout plan:

-    PLAN A: LIFE ANNUITY -- NO REFUND: We make monthly payouts until the
     annuitant's death. Payouts end with the last payout before the annuitant's
     death. We will not make any further payouts. This means that if the
     annuitant dies after we made only ONE monthly payout, we will not make any
     more payouts.

-    PLAN B: LIFE ANNUITY WITH FIVE, TEN, 15, OR 20 YEARS CERTAIN: We make
     monthly payouts for a guaranteed payout period of five, ten, 15, or 20
     years that you elect. This election will determine the length of the payout
     period to the beneficiary if the annuitant should die before the elected
     period expires. We calculate the guaranteed payout period from the
     settlement date. If the annuitant outlives the elected guaranteed payout
     period, we will continue to make payouts until the annuitant's death.

-    PLAN C: LIFE ANNUITY -- INSTALLMENT REFUND: We make monthly payouts until
     the annuitant's death, with our guarantee that payouts will continue for
     some period of time. We will make payouts for at least the number of months
     determined by dividing the amount applied under this option by the first
     monthly payout, whether or not the annuitant is living.

-    PLAN D: JOINT AND LAST SURVIVOR LIFE ANNUITY -- NO REFUND: We make monthly
     payouts while both the annuitant and a joint annuitant are living. If
     either annuitant dies, we will continue to make monthly payouts at the full
     amount until the death of the surviving owner. Payouts end with the death
     of the second annuitant.

-    PLAN E: PAYOUTS FOR A SPECIFIED PERIOD: We make monthly payouts for a
     specific payout period of ten to 30 years that you elect. We will make
     payouts only for the number of years specified whether the annuitant is
     living or not. Depending on the selected time period, it is foreseeable
     that the annuitant can outlive the payout period selected. During the
     payout period, you can elect to have us determine the present value of any
     remaining variable payouts and pay it to you in a lump sum. We determine
     the present value of the remaining annuity payouts which are assumed to
     remain level at the amount of the payout that would have been made 7 days
     prior to the date we determine the present value. The discount rate we use
     in the calculation will be either 5.17% or 6.67%, depending on the
     applicable assumed investment rate. (See "Charges -- Surrender charge under
     Annuity Payout Plan E.") You can also take a portion of the discounted
     value once a year. If you do so, your monthly payouts will be reduced by
     the proportion of your surrender to the full discounted value. A 10% IRS
     penalty tax could apply if you take surrender. (See "Taxes.")

-    RBA PAYOUT OPTION: If you have a GWB for Life or SecureSource rider under
     your contract, you may elect the Withdrawal Benefit RBA payout option as an
     alternative to the above annuity payout plans. This option may not be
     available if the contract is issued to qualify under Sections 403 or 408 of
     the Code. For such contracts, this option will be available only if the
     guaranteed payment period is less than the life expectancy of the owner at
     the time the option becomes effective. Such life expectancy will be
     computed using life expectancy tables published by IRS. Under this option,
     the amount payable each year will be equal to the remaining schedule of
     GBPs, but the total amount paid over the life of the annuity will not
     exceed the total RBA at the time you begin this fixed payout option (see
     "Optional Benefits"). These annualized amounts will be paid in the
     frequency that you elect. The frequencies will be among those offered by us
     at the time but will be no less frequent than annually. If, at the death of
     the owner, total payouts have been made for less than the RBA, the
     remaining payouts will be paid to the beneficiary.

ANNUITY PAYOUT PLAN REQUIREMENTS FOR QUALIFIED ANNUITIES: If your contract is a
qualified annuity, you must select a payout plan as of the settlement date set
forth in your contract. You have the responsibility for electing a payout plan
under your contract that complies with applicable law. Your contract describes
your payout plan options. The options will generally meet certain IRS
regulations governing RMDs if the payout plan meets the incidental distribution
benefit requirements, if any, and the payouts are made:

-    in equal or substantially equal payments over a period not longer than your
     life or over the joint life of you and your designated beneficiary; or

-    in equal or substantially equal payments over a period not longer than your
     life expectancy or over the joint life expectancy of you and your
     designated beneficiary; or

-    over a period certain not longer than your life expectancy or over the life
     expectancy of you and your designated beneficiary.



WRITTEN INSTRUCTIONS: You must give us written instructions for the annuity
payouts at least 30 days before the settlement date. Contract values that you
allocated to the regular fixed account will provide fixed dollar payouts and
contract values that you allocated among the subaccounts will provide variable
annuity payouts.

IF MONTHLY PAYOUTS WOULD BE LESS THAN $20: We will calculate the amount of
monthly payouts at the time the contract value is used to purchase a payout
plan. If the calculations show that monthly payouts would be less than $20, we
have the right to pay the contract value to the owner in a lump sum or to change
the frequency of the payouts.

DEATH AFTER ANNUITY PAYOUTS BEGIN: If you die after annuity payouts begin, we
will pay any amount payable to the beneficiary as provided in the annuity payout
plan in effect.

TAXES

Under current law, your contract has a tax-deferral feature. Generally, this
means you do not pay federal income tax until there is a distribution (or deemed
distribution) from the contract. Certain exceptions apply. We will send a tax
information reporting form for any year in which we made a distribution
according to our records.

NONQUALIFIED ANNUITIES

Generally, only the increase in the value of a non-qualified annuity contract
over the investment in the contract is taxable. Certain exceptions apply. Tax
law requires that all nonqualified deferred annuity contracts issued by the same
company (and possibly its affiliates) to the same owner during a calendar year
be taxed as a single, unified contract when distributions are taken from any one
of those contracts.

ANNUITY PAYOUTS: Generally, unlike surrenders, the taxation of annuity payouts
is subject to exclusion ratios, i.e. a portion of each payout will be ordinary
income and subject to tax, and a portion of each payout will be considered a
return of part of your investment in the contract and will not be taxed. All
amounts you receive after your investment in the contract is fully recovered
will be subject to tax. Under Annuity Payout Plan A: Life annuity -- no refund,
where the annuitant dies before your investment in the contract is fully
recovered, the remaining portion of the unrecovered investment may be available
as a federal income tax deduction to the owner for the last taxable year. Under
all other annuity payout plans, where the annuity payouts end before your
investment in the contract is fully recovered, the remaining portion of the
unrecovered investment may be available as a federal income tax deduction to the
taxpayer for the tax year in which the payouts end. (See "The Annuity Payout
Period -- Annuity Payout Plans.")

SURRENDERS: Generally, if you surrender all or part of your nonqualified annuity
before your annuity payouts begin, including withdrawals under any optional
withdrawal benefit rider, your surrender will be taxed to the extent that the
contract value immediately before the surrender exceeds the investment in the
contract. Different rules may apply if you exchange another contract into this
contract.

You also may have to pay a 10% IRS penalty for surrenders of taxable income you
make before reaching age 59 1/2 unless certain exceptions apply.

WITHHOLDING: If you receive taxable income as a result of an annuity payout or
surrender, including surrenders under any optional withdrawal benefit rider, we
may deduct federal, and in some cases state withholding against the payment. Any
withholding represents a prepayment of your tax due for the year. You take
credit for these amounts on your annual income tax return. As long as you have
provided us with a valid Social Security Number or Taxpayer Identification
Number, and you have a valid U.S. address, you may be able to elect not to have
any withholding occur.

If the payment is part of an annuity payout plan, we generally compute the
amount of withholding using payroll tables. You may provide us with a statement
of how many exemptions to use in calculating the withholding. If the
distribution is any other type of payment (such as partial or full surrender) we
compute withholding using 10% of the taxable portion.

The withholding requirements differ if we deliver payment outside the United
States and/or you are a non-resident alien.

Some states also may impose withholding requirements similar to the federal
withholding described above. If this should be the case, we may deduct state
withholding from the payment.



DEATH BENEFITS TO BENEFICIARIES: The death benefit under a nonqualified contract
is not exempt from estate (federal or state) or income taxes. In addition, any
amount your beneficiary receives that exceeds the investment in the contract is
taxable as ordinary income to the beneficiary in the year he or she receives the
payments.

ANNUITIES OWNED BY CORPORATIONS, PARTNERSHIPS OR IRREVOCABLE TRUSTS: For
nonqualified annuities, any annual increase in the value of annuities held by
such entities (nonnatural persons) generally will be treated as ordinary income
received during that year. However, if the trust was set up for the benefit of a
natural person only, the income will generally remain tax-deferred.

PENALTIES: If you receive amounts from your nonqualified annuity before reaching
age 59 1/2, you may have to pay a 10% IRS penalty on the amount includable in
your ordinary income. However, this penalty will not apply to any amount
received:

-    because of your death or in the event of nonnatural ownership, the death of
     the annuitant;

-    because you become disabled (as defined in the Code);

-    if the distribution is part of a series of substantially equal periodic
     payments, made at least annually, over your life or life expectancy (or
     joint lives or life expectancies of you and your beneficiary);

-    if it is allocable to an investment before Aug. 14, 1982; or

-    if annuity payouts are made under immediate annuities as defined by the
     Code.

TRANSFER OF OWNERSHIP: Generally, if you transfer ownership of a nonqualified
annuity without receiving adequate consideration, the transfer may be treated as
a surrender for federal income tax purposes. If the transfer is a currently
taxable event for income tax purposes, the original owner will be taxed on the
amount of deferred earnings at the time of the transfer and also may be subject
to the 10% IRS penalty discussed earlier. In this case, the new owner's
investment in the contract will be the value of the contract at the time of the
transfer. In general, this rule does not apply to transfers between spouses or
former spouses. Please consult your tax advisor for further details.

1035 EXCHANGES: Section 1035 of the Code permits nontaxable exchanges of certain
insurance policies and annuity contracts, while providing for continued tax
deferral of earnings. In addition, Section 1035 permits the carryover of the
cost basis from the old policy or contract to the new policy or contract. A 1035
exchange is a transfer from one policy or contract to another policy or
contract. The following are nontaxable exchanges: (1) the exchange of a life
insurance policy for another life insurance policy or for an endowment or
annuity contract, (2) the exchange of an endowment contract for an annuity
contract, or for an endowment contract under which payments will begin no later
than payments would have begun under the contract exchanged, (3) the exchange of
an annuity contract for another annuity contract. Depending on the issue date of
your original policy or contract, there may be tax or other benefits that are
given up to gain the benefits of the new policy or contract. Consider whether
the features and benefits of the new policy or contract outweigh any tax or
other benefits of the old contract.

For exchanges after 2009, a life insurance policy, annuity or endowment contract
or a qualified long-term care insurance contract may be exchanged for a
qualified long-term care insurance contract.

For a partial exchange of an annuity contract for another annuity contract, the
1035 exchange is generally tax-free. The investment in the original contract and
the earnings on the contract will be allocated proportionately between the
original and new contracts. However, IRS Revenue Procedure 2008-24 states if
withdrawals are taken from either contract within a 12 month period following a
partial exchange, the 1035 exchange may be invalidated. In that case, the
following will occur 1) the tax-free nature of the partial exchange can be lost,
2) the exchange will be retroactively treated as a taxable surrender on the
lesser of the earnings in the original contract or the amount exchanged and 3)
the entire amount of the exchange will be treated as a purchase into the second
contract. (If certain life events occur between the date of the partial exchange
and the date of the withdrawal in the first 12 months, the partial exchange
could remain valid.) You should consult your tax advisor before taking any
surrender from either contract.

ASSIGNMENT: If you assign or pledge your contract as collateral for a loan,
earnings on purchase payments you made after Aug. 13, 1982 will be taxed to you
like a surrender and you may have to pay a 10% IRS penalty.



QUALIFIED ANNUITIES

Adverse tax consequences may result if you do not ensure that contributions,
distributions and other transactions under the contract comply with the law.
Qualified annuities have minimum distribution rules that govern the timing and
amount of distributions. You should refer to your retirement plan's Summary Plan
Description, your IRA disclosure statement, or consult a tax advisor for
additional information about the distribution rules applicable to your
situation.

When you use your contract to fund a retirement plan or IRA that is already
tax-deferred under the Code, the contract will not provide any necessary or
additional tax deferral. If your contract is used to fund an employer sponsored
plan, your right to benefits may be subject to the terms and conditions of the
plan regardless of the terms of the contract.

ANNUITY PAYOUTS: Under a qualified annuity, except a Roth IRA, Roth 401(k) or
Roth 403(b), the entire payout generally is includable as ordinary income and is
subject to tax unless: (1) the contract is an IRA to which you made
non-deductible contributions; or (2) you rolled after-tax dollars from a
retirement plan into your IRA; or (3) the contract is used to fund a retirement
plan and you or your employer have contributed after-tax dollars.

ANNUITY PAYOUTS FROM ROTH IRAS: In general, the entire payout from a Roth IRA
can be free from income and penalty taxes if you have attained age 59 1/2 and
meet the five year holding period.

SURRENDERS: Under a qualified annuity, except a Roth IRA, Roth 401(k) or Roth
403(b), the entire surrender will generally be includable as ordinary income and
is subject to tax unless: (1) the contract is an IRA to which you made
non-deductible contributions; or (2) you rolled after-tax dollars from a
retirement plan into your IRA; or (3) the contract is used to fund a retirement
plan and you or your employer have contributed after-tax dollars.

SURRENDERS FROM ROTH IRAS: In general, the entire payout from a Roth IRA can be
free from income and penalty taxes if you have attained age 59 1/2 and meet the
five year holding period.

REQUIRED MINIMUM DISTRIBUTIONS: Retirement plans (except for Roth IRAs) are
subject to required surrenders called required minimum distributions ("RMDs")
beginning at age 70 1/2. RMDs are based on the fair market value of your
contract at year-end divided by life expectancy factor. Certain death benefits
and optional riders may be considered in determining the fair market value of
your contract for RMD purposes. This may cause your RMD to be higher. You should
consult your tax advisor prior to making a purchase for an explanation of the
potential tax implications to you.

WITHHOLDING FOR IRAS, ROTH IRAS, SEPS AND SIMPLE IRAS: If you receive taxable
income as a result of an annuity payout or a surrender, including surrenders
under any optional withdrawal benefit rider, we may deduct withholding against
the payment. Any withholding represents a prepayment of your tax due for the
year. You take credit for these amounts on your annual income tax return. As
long as you have provided us with a valid Social Security Number or Taxpayer
Identification Number, you can elect not to have any withholding occur.

If the payment is part of an annuity payout plan, we generally compute the
amount of withholding using payroll tables. You may provide us with a statement
of how many exemptions to use in calculating the withholding. If the
distribution is any other type of payment (such as a partial or full surrender)
we compute withholding using 10% of the taxable portion.

The withholding requirements differ if we deliver payment outside the United
States and/or you are a non-resident alien.

Some states also may impose withholding requirements similar to the federal
withholding described above. If this should be the case, we may deduct state
withholding from the payment.

WITHHOLDING FOR ALL OTHER QUALIFIED ANNUITIES: If you receive directly all or
part of the contract value from a qualified annuity, mandatory 20% federal
income tax withholding (and possibly state income tax withholding) generally
will be imposed at the time the payout is made from the plan. Any withholding
represents a prepayment of your tax due for the year. You take credit for these
amounts on your annual income tax return. This mandatory withholding will not be
imposed if instead of receiving the distribution check, you elect to have the
distribution rolled over directly to an IRA or another eligible plan. Payments
made to a surviving spouse instead of being directly rolled over to an IRA are
also subject to mandatory 20% income tax withholding.



In the below situations, the distribution is subject to an optional 10%
withholding instead of the mandatory 20% withholding. We will withhold 10% of
the distribution amount unless you elect otherwise.

-    the payout is one in a series of substantially equal periodic payouts, made
     at least annually, over your life or life expectancy (or the joint lives or
     life expectancies of you and your designated beneficiary) or over a
     specified period of 10 years or more;

-    the payout is a RMD as defined under the Code;

-    the payout is made on account of an eligible hardship; or

-    the payout is a corrective distribution.

State withholding also may be imposed on taxable distributions.

PENALTIES: If you receive amounts from your qualified contract before reaching
age 59 1/2, you may have to pay a 10% IRS penalty on the amount includable in
your ordinary income. However, this penalty generally will not apply to any
amount received:

-    because of your death;

-    because you become disabled (as defined in the Code);

-    if the distribution is part of a series of substantially equal periodic
     payments made at least annually, over your life or life expectancy (or
     joint lives or life expectancies of you and your beneficiary);

-    if the distribution is made following severance from employment during the
     calendar year in which you attain age 55 (TSAs and annuities funding 401(a)
     plans only); or

-    to pay certain medical or education expenses (IRAs only).

DEATH BENEFITS TO BENEFICIARIES: The entire death benefit generally is taxable
as ordinary income to the beneficiary in the year he/she receives the payments
from the qualified annuity. If you made non-deductible contributions to a
traditional IRA, the portion of any distribution from the contract that
represents after-tax contributions is not taxable as ordinary income to your
beneficiary. You are responsible for keeping all records tracking your
non-deductible contributions to an IRA. Death benefits under a Roth IRA
generally are not taxable as ordinary income to the beneficiary if certain
distribution requirements are met.

ASSIGNMENT: You may not assign or pledge your qualified contract as collateral
for a loan.

OTHER

PURCHASE PAYMENT CREDITS: These are considered earnings and are taxed
accordingly when surrendered or paid out.

SPECIAL CONSIDERATIONS IF YOU SELECT ANY OPTIONAL RIDER: As of the date of this
prospectus, we believe that charges related to these riders are not subject to
current taxation. Therefore, we will not report these charges as partial
surrenders from your contract. However, the IRS may determine that these charges
should be treated as partial surrenders subject to taxation to the extent of any
gain as well as the 10% tax penalty for surrenders before the age of 59 1/2, if
applicable.

We reserve the right to report charges for these riders as partial surrenders if
we, as a withholding and reporting agent, believe that we are required to report
them. In addition, we will report any benefits attributable to these riders on
the death of you or the annuitant as an annuity death benefit distribution, not
as proceeds from life insurance.

IMPORTANT: Our discussion of federal tax laws is based upon our understanding of
current interpretations of these laws. Federal tax laws or current
interpretations of them may change. For this reason and because tax consequences
are complex and highly individual and cannot always be anticipated, you should
consult a tax advisor if you have any questions about taxation of your contract.



RIVERSOURCE LIFE'S TAX STATUS: We are taxed as a life insurance company under
the Code. For federal income tax purposes, the subaccounts are considered a part
of our company, although their operations are treated separately in accounting
and financial statements. Investment income is reinvested in the fund in which
each subaccount invests and becomes part of that subaccount's value. This
investment income, including realized capital gains, is not taxed to us, and
therefore no charge is made against the subaccounts for federal income taxes and
there is no withholding. We reserve the right to make such a charge in the
future if there is a change in the tax treatment of variable annuities.

TAX QUALIFICATION: We intend that the contract qualify as an annuity for federal
income tax purposes. To that end, the provisions of the contract are to be
interpreted to ensure or maintain such tax qualification, in spite of any other
provisions of the contract. We reserve the right to amend the contract to
reflect any clarifications that may be needed or are appropriate to maintain
such qualification or to conform the contract to any applicable changes in the
tax qualification requirements. We will send you a copy of any amendments.

VOTING RIGHTS

As a contract owner with investments in the subaccounts, you may vote on
important fund policies until annuity payouts begin. Once they begin, the person
receiving them has voting rights. We will vote fund shares according to the
instructions of the person with voting rights.

Before annuity payouts begin, the number of votes you have is determined by
applying your percentage interest in each subaccount to the total number of
votes allowed to the subaccount.

After annuity payouts begin, the number of votes you have is equal to:

-    the reserve held in each subaccount for your contract; divided by

-    the net asset value of one share of the applicable fund.

As we make annuity payouts, the reserve for the contract decreases; therefore,
the number of votes also will decrease.

We calculate votes separately for each subaccount. We will send notice of
shareholders' meetings, proxy materials and a statement of the number of votes
to which the voter is entitled. We will vote shares for which we have not
received instructions in the same proportion as the votes for which we received
instructions. We also will vote the shares for which we have voting rights in
the same proportion as the votes for which we received instructions.

SUBSTITUTION OF INVESTMENTS

We may substitute the funds in which the subaccounts invest if:

-    laws or regulations change;

-    the existing funds become unavailable; or

-    in our judgment, the funds no longer are suitable (or no longer the most
     suitable) for the subaccounts.

If any of these situations occur, and if we believe it is in the best interest
of persons having voting rights under the contract, we have the right to
substitute a fund currently listed in this prospectus (existing fund) for
another fund (new fund). The new fund may have higher fees and/or operating
expenses than the existing fund. Also, the new fund may have investment
objectives and policies and/or investment advisers which differ from the
existing fund.

We may also:

-    add new subaccounts;

-    combine any two or more subaccounts;

-    transfer assets to and from the subaccounts or the variable account; and

-    eliminate or close any subaccounts.



We will notify you of any substitution or change. If we notify you that a
subaccount will be eliminated or closed, you will have a certain period of time
to tell us where to reallocate purchase payments or contract value currently
allocated to that subaccount. If we do not receive your reallocation
instructions by the due date, we automatically will reallocate to the subaccount
investing in the RiverSource Variable Portfolio -- Cash Management Fund. You may
then transfer this reallocated amount in accordance with the transfer provisions
of your contract (see "Transferring Between Accounts" above).

In the event of substitution or any of these changes, we may amend the contract
and take whatever action is necessary and appropriate without your consent or
approval. However, we will not make any substitution or change without the
necessary approval of the SEC and state insurance departments.

ABOUT THE SERVICE PROVIDERS

PRINCIPAL UNDERWRITER

RiverSource Distributors, Inc. (RiverSource Distributors), our affiliate, serves
as the principal underwriter and general distributor of the contract. Its
offices are located at 70100 Ameriprise Financial Center, Minneapolis, MN 55474.
RiverSource Distributors is a wholly-owned subsidiary of Ameriprise Financial,
Inc.

SALES OF THE CONTRACT

-    Only securities broker-dealers ("selling firms") registered with the SEC
     and members of the FINRA may sell the contract.

-    The contracts are continuously offered to the public through authorized
     selling firms. We and RiverSource Distributors have a sales agreement with
     the selling firm. The sales agreement authorizes the selling firm to offer
     the contracts to the public. RiverSource Distributors pays the selling firm
     (or an affiliated insurance agency) for contracts its financial advisors
     sell. The selling firm may be required to return sales commissions under
     certain circumstances including but not limited to when contracts are
     returned under the free look period.

PAYMENTS TO SELLING FIRMS

-    We may use compensation plans which vary by selling firm. For example, some
     of these plans pay selling firms a commission of up to 6.00% each time you
     make a purchase payment. We may also pay ongoing trail commissions of up to
     1.25% of the contract value. We do not pay or withhold payment of
     commissions based on which investment options you select.

-    We may pay selling firms a temporary additional sales commission of up to
     1% of purchase payments for a period of time we select. For example, we may
     offer to pay a temporary additional sales commission to get selling firms
     to market a new or enhanced contract or to increase sales during the
     period.

-    In addition to commissions, we may, in order to promote sales of the
     contracts, and as permitted by applicable laws and regulations, pay or
     provide selling firms with other promotional incentives in cash, credit or
     other compensation. We generally (but may not) offer these promotional
     incentives to all selling firms. The terms of such arrangements differ
     between selling firms. These promotional incentives may include but are not
     limited to:

-    sponsorship of marketing, educational, due diligence and compliance
     meetings and conferences we or the selling firm may conduct for financial
     advisors, including subsidy of travel, meal, lodging, entertainment and
     other expenses related to these meetings;

-    marketing support related to sales of the contract including for example,
     the creation of marketing materials, advertising and newsletters;

-    providing service to contract owners; and

-    funding other events sponsored by a selling firm that may encourage the
     selling firm's financial advisors to sell the contract.



These promotional incentives or reimbursements may be calculated as a percentage
of the selling firm's aggregate, net or anticipated sales and/or total assets
attributable to sales of the contract, and/or may be a fixed dollar amount. As
noted below this additional compensation may cause the selling firm and its
financial advisors to favor the contracts.

SOURCES OF PAYMENTS TO SELLING FIRMS

We pay the commissions and other compensation described above from our assets.
Our assets may include:

-    revenues we receive from fees and expenses that you will pay when buying,
     owning and surrendering the contract (see "Expense Summary");

-    compensation we or an affiliate receive from the underlying funds in the
     form of distribution and services fees (see "The Variable Account and the
     Funds -- The funds");

-    compensation we or an affiliate receive from a fund's investment adviser,
     subadviser, distributor or an affiliate of any of these (see "The Variable
     Account and the Funds -- The funds"); and

-    revenues we receive from other contracts and policies we sell that are not
     securities and other businesses we conduct.

You do not directly pay the commissions and other compensation described above
as the result of a specific charge or deduction under the contract. However, you
may pay part or all of the commissions and other compensation described above
indirectly through:

-    fees and expenses we collect from contract owners, including surrender
     charges; and

-    fees and expenses charged by the underlying funds in which the subaccounts
     you select invest, to the extent we or one of our affiliates receive
     revenue from the funds or an affiliated person.

POTENTIAL CONFLICTS OF INTEREST

Compensation payment arrangements with selling firms can potentially:

-    give selling firms a heightened financial incentive to sell the contract
     offered in this prospectus over another investment with lower compensation
     to the selling firm.

-    cause selling firms to encourage their financial advisors to sell you the
     contract offered in this prospectus instead of selling you other
     alternative investments that may result in lower compensation to the
     selling firm.

-    cause selling firms to grant us access to its financial advisors to promote
     sales of the contract offered in this prospectus, while denying that access
     to other firms offering similar contracts or other alternative investments
     which may pay lower compensation to the selling firm.

PAYMENTS TO FINANCIAL ADVISORS

-    The selling firm pays its financial advisors. The selling firm decides the
     compensation and benefits it will pay its financial advisors.

-    To inform yourself of any potential conflicts of interest, ask your
     financial advisor before you buy how the selling firm and its financial
     advisors are being compensated and the amount of the compensation that each
     will receive if you buy the contract.

ISSUER

We issue the contracts. We are a stock life insurance company organized in 1957
under the laws of the state of Minnesota and are located at 70100 Ameriprise
Financial Center, Minneapolis, MN 55474. We are a wholly-owned subsidiary of
Ameriprise Financial, Inc.

We conduct a conventional life insurance business. We are licensed to do
business in 49 states, the District of Columbia and American Samoa. Our primary
products currently include fixed and variable annuity contracts and life
insurance policies.



LEGAL PROCEEDINGS

RiverSource Life is involved in the normal course of business in legal and
regulatory proceedings, or regulatory requests for information, concerning
matters arising in connection with the conduct of our general business
activities as well as generally applicable to business practices in the
insurance industry. From time to time, we receive requests for information from,
or have been subject to examination by, the SEC, the Financial Industry
Regulatory Authority, commonly referred to as FINRA, and several state
authorities concerning our business activities and practices. These requests
generally include suitability, late trading, market timing, compensation and
disclosure of revenue sharing arrangements with respect to our annuity and
insurance products. We have cooperated with and will continue to cooperate with
the applicable regulators regarding their inquiries and examinations.

RiverSource Life is involved in other proceedings concerning matters arising in
connection with the conduct of its business activities. RiverSource Life
believes that it is not a party to, nor are any of its properties the subject
of, any pending legal, arbitration or regulatory proceedings that would have a
material adverse effect on its consolidated financial condition, results of
operations or liquidity. However, it is possible that the outcome of any such
proceedings could have a material adverse impact on results of operations in any
particular reporting period as the proceedings are resolved.

ADDITIONAL INFORMATION

INCORPORATION OF CERTAIN DOCUMENTS BY REFERENCE

To the extent and only to the extent that any statement in a document
incorporated by reference into this prospectus is modified or superseded by a
statement in this prospectus or in a later-filed document, such statement is
hereby deemed so modified or superseded and not part of this prospectus. The
Annual Report on Form 10-K of RiverSource Life Insurance Company for the year
ended Dec. 31, 2008 that we previously filed with the SEC under the Securities
Exchange Act of 1934 (1934 Act) is incorporated by reference into this
prospectus. To access these documents, see "SEC Filings" under "Investors
Relations" on our website at www.ameriprise.com.

RiverSource Life will furnish you without charge a copy of any or all of the
documents incorporated by reference into this prospectus, including any exhibits
to such documents which have been specifically incorporated by reference. We
will do so upon receipt of your written or oral request. You can contact
RiverSource Life at the telephone number and address listed on the first page of
this prospectus.

AVAILABLE INFORMATION

This prospectus is part of a registration statement we file with the SEC.
Additional information on RiverSource Life and on this offering is available in
the registration statement and other materials we file. You can obtain copies of
these materials at the SEC's Public Reference Room at 100 F Street, N.E.,
Washington, D.C. 20549. You can obtain information on the operation of the
Public Reference Room by calling the SEC at 1-800-SEC-0330. The SEC also
maintains an Internet site that contains reports, proxy and information
statements and other information regarding issuers that file electronically with
the SEC. This prospectus, other information about the contract and other
information incorporated by reference are available on the EDGAR Database on the
SEC's Internet site at (http://www.sec.gov).

INDEMNIFICATION

Insofar as indemnification for liabilities arising under the Securities Act of
1933 (1933 Act) may be permitted to directors and officers or persons
controlling RiverSource Life pursuant to the foregoing provisions, we have been
informed that in the opinion of the SEC such indemnification is against public
policy as expressed in the 1933 Act and is therefore unenforceable.



APPENDIX A: THE FUNDS

UNLESS AN ASSET ALLOCATION PROGRAM IS IN EFFECT, YOU MAY ALLOCATE PURCHASE
PAYMENTS AND TRANSFERS TO ANY OR ALL OF THE SUBACCOUNTS OF THE VARIABLE ACCOUNT
THAT INVEST IN SHARES OF THE FOLLOWING FUNDS:



INVESTING IN                           INVESTMENT OBJECTIVE AND POLICIES                         INVESTMENT ADVISER
------------                     ---------------------------------------------   ----------------------------------------------
                                                                           
AIM V.I. Capital Appreciation    Seeks growth of capital.                        Invesco Aim Advisors, Inc. adviser, advisory
Fund, Series II Shares                                                           entities affiliated with Invesco Aim Advisors,
                                                                                 Inc., subadvisers.

                                                                                 On or about Aug. 1, 2009, the business of
                                                                                 Invesco Aim Advisors, Inc. and Invesco Global
                                                                                 Asset Management, Inc. will be combined into
                                                                                 Invesco Institutional, which will be renamed
                                                                                 Invesco Advisers, Inc. and will serve as the
                                                                                 Fund's investment adviser.

AIM V.I. Capital Development     Seeks long-term growth of capital.              Invesco Aim Advisors, Inc. adviser, advisory
Fund, Series II Shares                                                           entities affiliated with Invesco Aim Advisors,
                                                                                 Inc., subadvisers.

                                                                                 On or about Aug. 1, 2009, the business of
                                                                                 Invesco Aim Advisors, Inc. and Invesco Global
                                                                                 Asset Management, Inc. will be combined into
                                                                                 Invesco Institutional, which will be renamed
                                                                                 Invesco Advisers, Inc. and will serve as the
                                                                                 Fund's investment adviser.

AIM V.I. Financial Services      Seeks capital growth.                           Invesco Aim Advisors, Inc. adviser, advisory
Fund, Series II Shares                                                           entities affiliated with Invesco Aim Advisors,
                                                                                 Inc., subadvisers.

                                                                                 On or about Aug. 1, 2009, the business of
                                                                                 Invesco Aim Advisors, Inc. and Invesco Global
                                                                                 Asset Management, Inc. will be combined into
                                                                                 Invesco Institutional, which will be renamed
                                                                                 Invesco Advisers, Inc. and will serve as the
                                                                                 Fund's investment adviser.

AIM V.I. Global Health Care      Seeks capital growth.                           Invesco Aim Advisors, Inc. adviser, advisory
Fund, Series II Shares                                                           entities affiliated with Invesco Aim Advisors,
                                                                                 Inc., subadvisers.

                                                                                 On or about Aug. 1, 2009, the business of
                                                                                 Invesco Aim Advisors, Inc. and Invesco Global
                                                                                 Asset Management, Inc. will be combined into
                                                                                 Invesco Institutional, which will be renamed
                                                                                 Invesco Advisers, Inc. and will serve as the
                                                                                 Fund's investment adviser.

AIM V.I. International Growth    Seeks long-term growth of capital.              Invesco Aim Advisors, Inc. adviser, advisory
Fund, Series II Shares                                                           entities affiliated with Invesco Aim Advisors,
                                                                                 Inc., subadvisers.

                                                                                 On or about Aug. 1, 2009, the business of
                                                                                 Invesco Aim Advisors, Inc. and Invesco Global
                                                                                 Asset Management, Inc. will be combined into
                                                                                 Invesco Institutional, which will be renamed
                                                                                 Invesco Advisers, Inc. and will serve as the
                                                                                 Fund's investment adviser.




                                                                           
AllianceBernstein VPS Global     Seeks long-term growth of capital.              AllianceBernstein L.P.
Technology Portfolio (Class B)

AllianceBernstein VPS Growth     Seeks long-term growth of capital.              AllianceBernstein L.P.
and Income Portfolio (Class B)

AllianceBernstein VPS            Seeks long-term growth of capital.              AllianceBernstein L.P.
International Value Portfolio
(Class B)

AllianceBernstein VPS Large      Seeks long-term growth of capital.              AllianceBernstein L.P.
Cap Growth Portfolio (Class B)

American Century VP Mid Cap      Seeks long-term capital growth. Income is a     American Century Investment Management, Inc.
Value, Class II                  secondary objective.

American Century VP Ultra(R),    Seeks long-term capital growth.                 American Century Investment Management, Inc.
Class II

American Century VP Value,       Seeks long-term capital growth. Income is a     American Century Investment Management, Inc.
Class II                         secondary objective.

Columbia High Yield Fund,        Seeks total return, consisting of a high        Columbia Management Advisors, LLC, advisor;
Variable Series, Class B         level of income and capital appreciation.       MacKay Shields LLC, subadviser.

Columbia Marsico Growth Fund,    Seeks long-term growth of capital.              Columbia Management Advisors, LLC, adviser;
Variable Series, Class A                                                         Marsico Capital Management, LLC, sub-adviser.

Columbia Marsico                 Seeks long-term growth of capital.              Columbia Management Advisors, LLC, adviser;
International Opportunities                                                      Marsico Capital Management, LLC, sub-adviser.
Fund, Variable Series, Class B

Credit Suisse Trust -            Seeks total return.                             Credit Suisse Asset Management, LLC
Commodity Return Strategy
Portfolio

Dreyfus Variable Investment      Seeks capital growth.                           The Dreyfus Corporation; Newton Capital
Fund International Equity                                                        Management Limited, sub-adviser
Portfolio, Service Shares

Eaton Vance VT Floating-Rate     Seeks high level of current income.             Eaton Vance Management
Income Fund

Evergreen VA Fundamental         Seeks capital growth with the potential for     Evergreen Investment Management Company, LLC
Large Cap Fund - Class 2         current income.

Evergreen VA International       Seeks long-term capital growth and              Evergreen Investment Management Company, LLC
Equity Fund - Class 2            secondarily, modest income.





                                                                           
Fidelity(R) VIP Contrafund(R)    Seeks long-term capital appreciation.           Fidelity Management & Research Company (FMR),
Portfolio Service Class 2        Normally invests primarily in common stocks.    investment manager; FMR U.K. and FMR Far East,
                                 Invests in securities of companies whose        sub-advisers.
                                 value it believes is not fully recognized by
                                 the public. Invests in either "growth" stocks
                                 or "value" stocks or both. The fund invests
                                 in domestic and foreign issuers.

Fidelity(R) VIP Mid Cap          Seeks long-term growth of capital. Normally     FMR, investment manager; FMR U.K., FMR Far
Portfolio Service Class 2        invests primarily in common stocks. Normally    East, sub-advisers.
                                 invests at least 80% of assets in securities
                                 of companies with medium market
                                 capitalizations. May invest in companies with
                                 smaller or larger market capitalizations.
                                 Invests in domestic and foreign issuers. The
                                 Fund invests in either "growth" or "value"
                                 common stocks or both.

Fidelity(R) VIP Overseas         Seeks long-term growth of capital. Normally     FMR, investment manager; FMR U.K., FMR Far
Portfolio Service Class 2        invests primarily in common stocks allocating   East, Fidelity International Investment
                                 investments across different countries and      Advisors (FIIA) and FIIA U.K., sub-advisers.
                                 regions. Normally invests at least 80% of
                                 assets in non-U.S. securities.

FTVIPT Franklin Global Real      Seeks high total return.                        Franklin Templeton Institutional, LLC
Estate Securities Fund -
Class 2

FTVIPT Franklin Small Cap        Seeks long-term total return.                   Franklin Advisory Services, LLC
Value Securities Fund -
Class 2

FTVIPT Mutual Shares             Seeks capital appreciation, with income as a    Franklin Mutual Advisers, LLC
Securities Fund - Class 2        secondary goal.

Goldman Sachs VIT Structured     Seeks long-term growth of capital and           Goldman Sachs Asset Management, L.P.
U.S. Equity Fund -               dividend income.
Institutional Shares

Janus Aspen Series Janus         Seeks long-term growth of capital in a manner   Janus Capital Management LLC
Portfolio: Service Shares        consistent with the preservation of capital.
(previously Janus Aspen
Series Large Cap Growth
Portfolio: Service Shares)

Legg Mason Partners Variable     Seeks long-term growth of capital.              Legg Mason Partners Fund Advisor, LLC,
Small Cap Growth Portfolio,                                                      adviser; ClearBridge Advisors, LLC,
Class I                                                                          sub-adviser.

MFS(R) Investors Growth Stock    Seeks capital appreciation.                     MFS Investment Management(R)
Series - Service Class

MFS(R) Utilities Series -        Seeks total return.                             MFS Investment Management(R)
Service Class





                                                                           
Neuberger Berman Advisers        Seeks long-term growth of capital by            Neuberger Berman Management Inc.
Management Trust                 investing primarily in common stocks of
International Portfolio          foreign companies.
(Class S)

Neuberger Berman Advisers        Seeks long-term growth of capital by            Neuberger Berman Management Inc.
Management Trust Socially        investing primarily in securities of
Responsive Portfolio (Class S)   companies that meet the Fund's financial
                                 criteria and social policy.

Oppenheimer Global Securities    Seeks long-term capital appreciation.           OppenheimerFunds, Inc.
Fund/VA, Service Shares

Oppenheimer Main Street Small    Seeks capital appreciation.                     OppenheimerFunds, Inc.
Cap Fund/VA, Service Shares

Oppenheimer Strategic Bond       Seeks high level of current income              OppenheimerFunds, Inc.
Fund/VA, Service Shares          principally derived from interest on debt
                                 securities.

Oppenheimer Value Fund/VA,       Seeks high level of current income              OppenheimerFunds, Inc.
Service Shares                   principally derived from interest on debt
                                 securities.

PIMCO VIT All Asset              Seeks maximum real return consistent with       Pacific Investment Management Company LLC
Portfolio, Advisor Share Class   preservation of real capital and prudent
                                 investment management period.

RVST Disciplined Asset           Seeks high level of total return that is        RiverSource Investments, LLC
Allocation Portfolios -          consistent with an aggressive level of risk.
Aggressive                       This is a "fund of funds" and seeks to
                                 achieve its objective by investing in a
                                 combination of underlying funds for which
                                 RiverSource Investments acts as investment
                                 manager or an affiliate acts as principal
                                 underwriter. By investing in several
                                 underlying funds, the Fund seeks to minimize
                                 the risks inherent in investing in a single
                                 fund.

RVST Disciplined Asset           Seeks high level of total return that is        RiverSource Investments, LLC
Allocation Portfolios -          consistent with a conservative level of risk.
Conservative                     This is a "fund of funds" and seeks to
                                 achieve its objective by investing in a
                                 combination of underlying funds for which
                                 RiverSource Investments acts as investment
                                 manager or an affiliate acts as principal
                                 underwriter. By investing in several
                                 underlying funds, the Fund seeks to minimize
                                 the risks inherent in investing in a single
                                 fund.





                                                                           
RVST Disciplined Asset           Seeks high level of total return that is        RiverSource Investments, LLC
Allocation Portfolios -          consistent with a moderate level of risk.
Moderate                         This is a "fund of funds" and seeks to
                                 achieve its objective by investing in a
                                 combination of underlying funds for which
                                 RiverSource Investments acts as investment
                                 manager or an affiliate acts as principal
                                 underwriter. By investing in several
                                 underlying funds, the Fund seeks to minimize
                                 the risks inherent in investing in a single
                                 fund.

RVST Disciplined Asset           Seeks high level of total return that is        RiverSource Investments, LLC
Allocation Portfolios -          consistent with a moderate aggressive level
Moderately Aggressive            of risk. This is a "fund of funds" and seeks
                                 to achieve its objective by investing in a
                                 combination of underlying funds for which
                                 RiverSource Investments acts as investment
                                 manager or an affiliate acts as principal
                                 underwriter. By investing in several
                                 underlying funds, the Fund seeks to minimize
                                 the risks inherent in investing in a single
                                 fund.

RVST Disciplined Asset           Seeks high level of total return that is        RiverSource Investments, LLC
Allocation Portfolios -          consistent with a moderate conservative level
Moderately Conservative          of risk. This is a "fund of funds" and seeks
                                 to achieve its objective by investing in a
                                 combination of underlying funds for which
                                 RiverSource Investments acts as investment
                                 manager or an affiliate acts as principal
                                 underwriter. By investing in several
                                 underlying funds, the Fund seeks to minimize
                                 the risks inherent in investing in a single
                                 fund.

RVST RiverSource Partners        Seeks long-term capital growth.                 RiverSource Investments, LLC, adviser; Davis
Variable Portfolio -                                                             Selected Advisers, L.P., subadviser.
Fundamental Value Fund

RVST RiverSource Partners        Seeks long-term growth of capital.              RiverSource Investments, LLC, adviser;
Variable Portfolio - Select                                                      Systematic Financial Management, L.P. and
Value Fund                                                                       WEDGE Capital Management L.L.P., sub-advisers.

RVST RiverSource Partners        Seeks long-term capital appreciation.           RiverSource Investments, LLC, adviser; Barrow,
Variable Portfolio - Small                                                       Hanley, Mewhinney & Strauss, Inc., Denver
Cap Value Fund                                                                   Investment Advisors LLC, Donald Smith & Co.,
                                                                                 Inc., River Road Asset Management, LLC and
                                                                                 Turner Investment Partners, Inc., subadvisers.

RVST RiverSource Variable        Seeks maximum total investment return through   RiverSource Investments, LLC
Portfolio - Balanced Fund        a combination of capital growth and current
                                 income.

RVST RiverSource Variable        Seeks maximum current income consistent with    RiverSource Investments, LLC
Portfolio - Cash Management      liquidity and stability of principal.
Fund





                                                                           
RVST RiverSource Variable        Seeks high level of current income while        RiverSource Investments, LLC
Portfolio - Diversified Bond     attempting to conserve the value of the
Fund                             investment for the longest period of time.

RVST RiverSource Variable        Seeks high level of current income and, as a    RiverSource Investments, LLC
Portfolio - Diversified          secondary goal, steady growth of capital.
Equity Income Fund

RVST RiverSource Variable        Seeks capital appreciation.                     RiverSource Investments, LLC
Portfolio - Dynamic Equity
Fund (previously RVST
RiverSource Variable
Portfolio - Large Cap Equity
Fund)

RVST RiverSource Variable        Non-diversified fund that seeks high total      RiverSource Investments, LLC
Portfolio - Global Bond Fund     return through income and growth of capital.

RVST RiverSource Variable        Non-diversified fund that seeks total return    RiverSource Investments, LLC
Portfolio - Global Inflation     that exceeds the rate of inflation over the
Protected Securities Fund        long-term.

RVST RiverSource Variable        Seeks high current income, with capital         RiverSource Investments, LLC
Portfolio - High Yield Bond      growth as a secondary objective.
Fund

RVST RiverSource Variable        Seeks high total return through current         RiverSource Investments, LLC
Portfolio - Income               income and capital appreciation.
Opportunities Fund

RVST RiverSource Variable        Seeks growth of capital.                        RiverSource Investments, LLC
Portfolio - Mid Cap Growth
Fund

RVST RiverSource Variable        Seeks long-term growth of capital.              RiverSource Investments, LLC
Portfolio - Mid Cap Value Fund

RVST RiverSource Variable        Seeks long-term capital appreciation.           RiverSource Investments, LLC
Portfolio - S&P 500 Index Fund

RVST RiverSource Variable        Seeks high level of current income and safety   RiverSource Investments, LLC
Portfolio - Short Duration       of principal consistent with investment in
U.S. Government Fund             U.S. government and government agency
                                 securities.

RVST Seligman Variable           Seeks long-term capital growth.                 RiverSource Investments, LLC
Portfolio - Growth Fund
(previously RVST RiverSource
Variable Portfolio - Growth
Fund)

RVST Seligman Variable           Seeks long-term growth of capital.              RiverSource Investments, LLC
Portfolio - Larger-Cap Value
Fund (previously RVST
RiverSource Variable
Portfolio - Large Cap Value
Fund)





                                                                           
RVST Seligman Variable           Seeks long-term capital growth.                 RiverSource Investments, LLC, adviser; Kenwood
Portfolio - Smaller-Cap Value                                                    Capital Management LLC, sub-adviser.
Fund (previously RVST
RiverSource Variable
Portfolio - Small Cap
Advantage Fund)

RVST Threadneedle Variable       Seeks long-term capital growth.                 RiverSource Investments, LLC, adviser;
Portfolio - Emerging Markets                                                     Threadneedle International Limited, an
Fund                                                                             indirect wholly-owned subsidiary of Ameriprise
                                                                                 Financial, sub-adviser.

RVST Threadneedle Variable       Seeks capital appreciation.                     RiverSource Investments, LLC, adviser;
Portfolio - International                                                        Threadneedle International Limited, an
Opportunity Fund                                                                 indirect wholly-owned subsidiary of Ameriprise
                                                                                 Financial, sub-adviser.

Van Kampen Life Investment       Seeks capital growth and income through         Van Kampen Asset Management
Trust Comstock Portfolio,        investments in equity securities, including
Class II Shares                  common stocks, preferred stocks and
                                 securities convertible into common and
                                 preferred stocks.

Van Kampen UIF Global Real       Seeks current income and capital appreciation.  Morgan Stanley Investment Management Inc.,
Estate Portfolio, Class II                                                       doing business as Van Kampen, adviser; Morgan
Shares                                                                           Stanley Investment Management Limited and
                                                                                 Morgan Stanley Investment Management Company,
                                                                                 sub-advisers.

Van Kampen UIF Mid Cap Growth    Seeks long-term capital growth.                 Morgan Stanley Investment Management Inc.,
Portfolio, Class II Shares                                                       doing business as Van Kampen.

Wanger International             Seeks long-term growth of capital.              Columbia Wanger Asset Management, L.P.

Wanger USA                       Seeks long-term capital appreciation.           Columbia Wanger Asset Management, L.P.

Wells Fargo Advantage VT         Seeks long-term total return, consisting of     Wells Fargo Funds Management, LLC, adviser;
Opportunity Fund                 capital appreciation and current income.        Wells Capital Management Incorporated,
                                                                                 sub-adviser.

Wells Fargo Advantage VT         Seeks long-term total return, consisting of     Wells Fargo Funds Management, LLC, adviser;
Small Cap Growth Fund            capital appreciation and current income.        Wells Capital Management Incorporated,
                                                                                 sub-adviser.




APPENDIX B: EXAMPLE -- MARKET VALUE ADJUSTMENT (MVA)

AS THE EXAMPLES BELOW DEMONSTRATE, THE APPLICATION OF AN MVA MAY RESULT IN
EITHER A GAIN OR A LOSS OF PRINCIPAL. WE REFER TO ALL OF THE TRANSACTIONS
DESCRIBED BELOW AS "EARLY SURRENDERS." THE EXAMPLES MAY SHOW HYPOTHETICAL
CONTRACT VALUES. THESE CONTRACT VALUES DO NOT REPRESENT PAST OR FUTURE
PERFORMANCE. ACTUAL CONTRACT VALUES MAY BE MORE OR LESS THAN THOSE SHOWN AND
WILL DEPEND ON A NUMBER OF FACTORS, INCLUDING BUT NOT LIMITED TO THE INVESTMENT
EXPERIENCE OF THE SUBACCOUNTS, GPAS, SPECIAL DCA FIXED ACCOUNT, REGULAR FIXED
ACCOUNT AND THE FEES AND CHARGES THAT APPLY TO YOUR CONTRACT.

GENERAL EXAMPLES

ASSUMPTIONS:

-    You purchase a contract and allocate part of your purchase payment to the
     ten-year GPA; and

-    we guarantee an interest rate of 3.0% annually for your ten-year Guarantee
     Period; and

-    after three years, you decide to make a surrender from your GPA. In other
     words, there are seven years left in your guarantee period.

Remember that the MVA depends partly on the interest rate of a new GPA for the
same number of years as the Guarantee Period remaining on your GPA. In this
case, that is seven years.

EXAMPLE 1: Remember that your GPA is earning 3.0%. Assume at the time of your
surrender new GPAs that we offer with a seven-year Guarantee Period are earning
3.5%. We add 0.10% to the 3.5% rate to get 3.6%. Your GPA's 3.0% rate is less
than the 3.6% rate so the MVA will be negative.

EXAMPLE 2: Remember again that your GPA is earning 3.0%, and assume that new
GPAs that we offer with a seven-year Guarantee Period are earning 2.5%. We add
0.10% to the 2.5% rate to get 2.6%. In this example, since your GPA's 3.0% rate
is greater than the 2.6% rate, the MVA will be positive. To determine that
adjustment precisely, you will have to use the formula described below.

SAMPLE MVA CALCULATIONS

The precise MVA formula we apply is as follows:

                                         [(   1 + i    )(n/12)   ]
               EARLY WITHDRAWAL AMOUNT X [(------------)   -   1 ] = MVA
                                         [(1 + J + .001)         ]

     Where i = rate earned in the GPA from which amounts are being transferred
               or surrendered.

           j = current rate for a new Guaranteed Period equal to the remaining
               term in the current Guarantee Period (rounded up to the next
               year).

           n = number of months remaining in the current Guarantee Period
               (rounded up to the next month).

EXAMPLES -- MVA

Using assumptions similar to those we used in the examples above:

-    You purchase a contract and allocate part of your purchase payment to the
     ten-year GPA; and

-    we guarantee an interest rate of 3.0% annually for your ten-year Guarantee
     Period; and



-    after three years, you decide to make a $1,000 surrender from your GPA. In
     other words, there are seven years left in your guarantee period.

EXAMPLE 1: You request an early surrender of $1,000 from your ten-year GPA
earning a guaranteed interest rate of 3.0%. Assume at the time of your surrender
new GPAs that we offer with a seven-year Guarantee Period are earning 3.5%.
Using the formula above, we determine the MVA as follows:

                              [(     1.030     )(84/12)   ]
                     $1,000 X [(---------------)    -   1 ] = -$39.84
                              [(1 + .035 + .001)          ]

In this example, the MVA is a negative $39.84.

EXAMPLE 2: You request an early surrender of $1,000 from your ten-year GPA
earning a guaranteed interest rate of 3.0%. Assume at the time of your surrender
new GPAs that we offer with a seven-year Guarantee Period are earning 2.5%.
Using the formula above, we determine the MVA as follows:

                                [(     1.030     )(84/12)  ]
                       $1,000 X [(---------------)    -  1 ] = -$27.61
                                [(1 + .025 + .001)         ]

In this example, the MVA is a positive $27.61.

We do not apply MVAs to the amounts we deduct for surrender charges, so we would
deduct the surrender charge from your early surrender after we applied the MVA.
Also note that when you request an early surrender, we surrender an amount from
your GPA that will give you the net amount you requested after we apply the MVA
and any applicable surrender charge, unless you request otherwise.

The current interest rate we offer on the GPA will change periodically at our
discretion. It is the rate we are then paying on purchase payments, renewals and
transfers paid under this class of contracts for Guarantee Period durations
equaling the remaining Guarantee Period of the GPA to which the formula is being
applied.



APPENDIX C: EXAMPLE -- SURRENDER CHARGES

THE PURPOSE OF THIS APPENDIX IS TO ILLUSTRATE THE VARIOUS SURRENDER CHARGE
CALCULATIONS. THE EXAMPLES MAY SHOW HYPOTHETICAL CONTRACT VALUES. THESE CONTRACT
VALUES DO NOT REPRESENT PAST OR FUTURE PERFORMANCE. ACTUAL CONTRACT VALUES MAY
BE MORE OR LESS THAN THOSE SHOWN AND WILL DEPEND ON A NUMBER OF FACTORS,
INCLUDING BUT NOT LIMITED TO THE INVESTMENT EXPERIENCE OF THE SUBACCOUNTS, GPAS,
SPECIAL DCA FIXED ACCOUNT, REGULAR FIXED ACCOUNT AND THE FEES AND CHARGES THAT
APPLY TO YOUR CONTRACT.

FULL SURRENDER CHARGE CALCULATION -- TEN-YEAR SURRENDER CHARGE SCHEDULE:

This is an example of how we calculate the surrender charge for a full surrender
on a RAVA 4 Advantage contract with a ten-year surrender charge schedule with
the following history:

-    we receive a single $100,000 purchase payment; and

-    you surrender the contract for its total value during the fourth contract
     year. The surrender charge percentage is 7.0%; and

-    you have made no prior partial surrenders.

WE WILL LOOK AT TWO SITUATIONS, ONE WHERE THE CONTRACT HAS A GAIN AND ANOTHER
WHERE THERE IS A LOSS:



                                                             CONTRACT         CONTRACT
                                                            WITH GAIN         WITH LOSS
                                                          --------------   --------------
                                                                     
        Contract Value at time of full surrender:         $   120,000.00   $    80,000.00
        Contract Value on prior anniversary:                  115,000.00        85,000.00
STEP 1. We determine the Total Free Amount (TFA)
           available in the contract as the greatest of
           the earnings or 10% of the prior anniversary
           value:
        Earnings in the contract:
        10% of the prior anniversary's contract value:         20,000.00             0.00
                                                               11,500.00         8,500.00
                                                          --------------   --------------
              Total Free Amount:                               20,000.00         8,500.00

STEP 2. We determine the TFA that is from Purchase
        Payments:
              Total Free Amount:                               20,000.00         8,500.00
        Earnings in the contract:                              20,000.00             0.00
        Purchase Payments being Surrendered Free (PPF):
                                                                    0.00         8,500.00

STEP 3. We calculate the Premium Ratio (PR):
        PR = [WD - TFA] / [CV - TFA]
           WD =                                               120,000.00        80,000.00   = the amount of the surrender
           TFA =                                               20,000.00         8,500.00   = the total free amount, step 1
           CV =                                               120,000.00        80,000.00   = the contract value at the time of
                                                                                              the surrender
           PR =                                                     100%              100%  = the premium ratio

STEP 4. We calculate Chargeable Purchase Payments
           being Surrendered (CPP):
        CPP = PR x (PP - PPF)
           PR =                                                      100%             100%  = premium ratio, step 3
           PP =                                               100,000.00       100,000.00   = purchase payments not previously
                                                                                              surrendered
           PPF =                                                    0.00         8,500.00   = purchase payments being
                                                                                              surrendered free, step 2
           CPP =                                              100,000.00        91,500.00
STEP 5. We calculate the Surrender Charges:




                                                                     
        Chargeable Purchase Payments:                         100,000.00        91,500.00
        Surrender Charge Percentage:                                   7%               7%
        Surrender Charge:                                       7,000.00         6,405.00





                                                                     
STEP 6. We calculate the Net Surrender Value:                 120,000.00        80,000.00
        Contract Value Surrendered:
        Contract Charge (assessed upon full surrender):        (7,000.00)       (6,405.00)
                                                                  (30.00)          (30.00)
           Net Full Surrender Proceeds:                       112,970.00        73,565.00



PARTIAL SURRENDER CHARGE CALCULATION -- TEN-YEAR SURRENDER CHARGE SCHEDULE:

This is an example of how we calculate the surrender charge for a partial
surrender on a RAVA 4 Advantage contract with a ten-year surrender charge
schedule with the following history:

-    we receive a single $100,000 purchase payment; and

-    you request a gross partial surrender of $50,000 during the fourth contract
     year. The surrender charge percentage is 7.0%; and

-    you have made no prior partial surrenders.

WE WILL LOOK AT TWO SITUATIONS, ONE WHERE THE CONTRACT HAS A GAIN AND ANOTHER
WHERE THERE IS A LOSS:



                                                             CONTRACT         CONTRACT
                                                             WITH GAIN        WITH LOSS
                                                          --------------   --------------
                                                                       
        Contract Value at time of partial surrender:      $   120,000.00   $    80,000.00
        Contract Value on prior anniversary:                  115,000.00        85,000.00

STEP 1. We determine the Total Free Amount (TFA)
           available in the contract as the greatest of
           the earnings or 10% of the prior anniversary
           value:
        Earnings in the contract:                              20,000.00             0.00
        10% of the prior anniversary's contract value:         11,500.00         8,500.00
                                                          --------------   --------------
           Total Free Amount:                                  20,000.00         8,500.00

STEP 2. We determine the TFA that is from Purchase
        Payments:
           Total Free Amount:                                  20,000.00         8,500.00
        Earnings in the contract:                              20,000.00             0.00
        Purchase Payments being Surrendered Free
           (PPF):                                                   0.00         8,500.00

STEP 3. We calculate the Premium Ratio (PR):
        PR = [WD - TFA] / [CV - TFA]
           WD =                                                50,000.00        50,000.00   = the amount of the surrender
           TFA =                                               20,000.00         8,500.00   = the total free amount, step 1
           CV =                                               120,000.00        80,000.00   = the contract value at the time
                                                                                              of surrender
           PR =                                                       30%              58%  = the premium ratio

STEP 4. We calculate the Chargeable Purchase Payments
           being Surrendered (CPP):
           CPP = PR x (PP - PPF)
           PR =                                                       30%              58%  = premium ratio, step 3
           PP =                                               100,000.00       100,000.00   = purchase payments not
                                                                                              previously surrendered
           PPF =                                                    0.00         8,500.00   = purchase payments being
                                                                                              surrendered free, step 2
           CPP =                                               30,000.00        53,108.39   = chargeable purchase payments
                                                                                              being surrendered

STEP 5. We calculate the Surrender Charges:
        Chargeable Purchase Payments:                          30,000.00        53,108.39
        Surrender Charge Percentage:                                   7%               7%
        Surrender Charge:                                          2,100            3,718




                                                                     
STEP 6. We calculate the Net Surrender Value:
        Contract Value Surrendered:                            50,000.00        50,000.00
        Surrender Charge:                                      (2,100.00)       (3,717.59)
        Net Partial Surrender Proceeds:                        47,900.00        46,282.41



FULL SURRENDER CHARGE CALCULATION -- THREE-YEAR SURRENDER CHARGE SCHEDULE:

This is an example of how we calculate the surrender charge for a full surrender
on a RAVA 4 Select contract with a three-year surrender charge schedule with the
following history:

-    we receive a single $100,000 purchase payment; and

-    you surrender the contract for its total value during the second contract
     year. The surrender charge percentage is 7.0%; and

-    you have made no prior partial surrenders.

WE WILL LOOK AT TWO SITUATIONS, ONE WHERE THE CONTRACT HAS A GAIN AND ANOTHER
WHERE THERE IS A LOSS:



                                                             CONTRACT         CONTRACT
                                                             WITH GAIN       WITH LOSS
                                                          --------------   --------------
                                                                     
        Contract Value at time of full surrender:         $   120,000.00   $    80,000.00
        Contract Value on prior anniversary:                  115,000.00        85,000.00

STEP 1. We determine the Total Free Amount (TFA)
           available in the contract as the greatest
           of the earnings or 10% of the prior
           anniversary value:
        Earnings in the Contract:                              20,000.00             0.00
        10% of the prior anniversary's contract
           value:
                                                               11,500.00         8,500.00
                                                          --------------   --------------
           Total Free Amount:                                  20,000.00         8,500.00

STEP 2. We determine the TFA and Amount Free that
           is from Purchase Payments:
           Total Free Amount:                                  20,000.00         8,500.00
        Earnings in the contract:                              20,000.00             0.00
        Purchase Payments being Surrendered Free
           (PPF):
                                                                    0.00         8,500.00

STEP 3. We calculate the Premium Ratio (PR):
        PR = [WD - TFA] / [CV - TFA]
           WD =                                               120,000.00        80,000.00   = the amount of the surrender
           TFA =                                               20,000.00         8,500.00   = the total free amount, step 1
           CV =                                               120,000.00        80,000.00   = the contract value at the time
                                                                                              of the surrender
           PR =                                                      100%             100%

STEP 4. We calculate Chargeable Purchase Payments
           being Surrendered (CPP):
        CPP = PR x (PP - PPF)
           PR =                                                      100%             100%  = premium ratio, step 3
           PP =                                               100,000.00       100,000.00   = purchase payments not previously
                                                                                              surrendered
           PPF =                                                    0.00         8,500.00   = purchase payments being
                                                                                              surrendered free, step 2
           CPP =                                              100,000.00        91,500.00

STEP 5. We calculate the Surrender Charges:
        Chargeable Purchase Payments:                         100,000.00        91,500.00
        Surrender Charge Percentage:                                   7%               7%
        Surrender Charge:                                       7,000.00         6,405.00




                                                                     
STEP 6. We calculate the Net Surrender Value:                 120,000.00        80,000.00
        Contract Value Surrendered:                            (7,000.00)       (6,405.00)
        Contract Charge (assessed upon full
           surrender):
                                                                  (30.00)          (30.00)
           Net Full Surrender Proceeds:                       112,970.00        73,565.00



PARTIAL SURRENDER CHARGE CALCULATION -- THREE-YEAR SURRENDER CHARGE SCHEDULE:

This is an example of how we calculate the surrender charge for a partial
surrender on a RAVA 4 Select contract with a three-year surrender charge
schedule with the following history:

-    we receive a single $100,000 purchase payment; and

-    you request a gross partial surrender of $50,000 during the second contract
     year. The surrender charge percentage is 7.0%; and

-    you have made no prior partial surrenders.

WE WILL LOOK AT TWO SITUATIONS, ONE WHERE THE CONTRACT HAS A GAIN AND ANOTHER
WHERE THERE IS A LOSS:



                                                             CONTRACT         CONTRACT
                                                             WITH GAIN        WITH LOSS
                                                          --------------   --------------
                                                                     
        Contract Value at time of partial surrender:      $   120,000.00   $    80,000.00
        Contract Value on prior anniversary:                  115,000.00        85,000.00

STEP 1. We determine the Total Free Amount (TFA)
           available in the contract as the greatest of
           the earnings or 10% of the prior anniversary
           value:
        Earnings in the contract:                              20,000.00             0.00
        10% of the prior anniversary's contract value:
                                                               11,500.00         8,500.00
                                                          --------------   --------------
           Total Free Amount:                                  20,000.00         8,500.00

STEP 2. We determine the Amount Free that is from
        Purchase Payments:
           Total Free Amount:                                  20,000.00         8,500.00
        Earnings in the contract:                              20,000.00             0.00
        Purchase Payments being Surrendered Free
           (PPF):                                                   0.00         8,500.00

STEP 3. We calculate the Premium Ratio (PR):
        PR = [WD - TFA] / [CV - TFA]
           WD =                                                50,000.00        50,000.00   = the amount of the surrender
           TFA =                                               20,000.00         8,500.00   = the total free amount, step 1
           CV =                                               120,000.00        80,000.00   = the contract value at the time of
                                                                                              surrender
           PR =                                                       30%              58%  = the premium ratio

STEP 4. We calculate the Chargeable Purchase Payments
           being Surrendered (CPP):
           CPP = PR x (PP - PPF)
           PR =                                                       30%              58%  = premium ratio, step 3
           PP =                                               100,000.00       100,000.00   = purchase payments not previously
                                                                                              surrendered
           PPF =                                                    0.00         8,500.00   = purchase payments being
                                                                                              surrendered free, step 2
           CPP =                                               30,000.00        53,108.39   = chargeable purchase payments
                                                                                              being surrendered

STEP 5. We calculate the Surrender Charges:
        Chargeable Purchase Payments:                          30,000.00        53,108.39
        Surrender Charge Percentage:                                   7%               7%
        Surrender Charge:                                          2,100            3,718




                                                                     
STEP 6. We calculate the Net Surrender Value:
        Contract Value Surrendered:                             50,000.00        50,000.00
        Surrender Charge:                                       (2,100.00)       (3,717.00)
        Net Partial Surrender Proceeds:                         47,900.00        46,282.41




APPENDIX D: EXAMPLE -- OPTIONAL DEATH BENEFITS

THE PURPOSE OF THIS APPENDIX IS TO ILLUSTRATE THE OPERATION OF VARIOUS OPTIONAL
DEATH BENEFIT RIDERS.

IN ORDER TO DEMONSTRATE THESE CONTRACT RIDERS, AN EXAMPLE MAY SHOW HYPOTHETICAL
CONTRACT VALUES. THESE CONTRACT VALUES DO NOT REPRESENT PAST OR FUTURE
PERFORMANCE. ACTUAL CONTRACT VALUES MAY BE MORE OR LESS THAN THOSE SHOWN AND
WILL DEPEND ON a NUMBER OF FACTORS, INCLUDING BUT NOT LIMITED TO THE INVESTMENT
EXPERIENCE OF THE SUBACCOUNTS, GPAS, SPECIAL DCA FIXED ACCOUNT, REGULAR FIXED
ACCOUNT AND THE FEES AND CHARGES THAT APPLY TO YOUR CONTRACT.

THE EXAMPLES OF THE OPTIONAL DEATH BENEFITS IN APPENDIX INCLUDE PARTIAL
SURRENDERS TO ILLUSTRATE THE EFFECT OF PARTIAL SURRENDERS ON THE PARTICULAR
BENEFIT. THESE EXAMPLES ARE INTENDED TO SHOW HOW THE OPTIONAL DEATH BENEFITS
OPERATE, AND DO NOT TAKE INTO ACCOUNT WHETHER A PARTICULAR OPTIONAL DEATH
BENEFIT IS PART OF A QUALIFIED ANNUITY. QUALIFIED ANNUITIES ARE SUBJECT TO RMDS
AT CERTAIN AGES (SEE "TAXES -- QUALIFIED ANNUITIES -- REQUIRED MINIMUM
DISTRIBUTIONS") WHICH MAY REQUIRE YOU TO TAKE PARTIAL SURRENDERS FROM THE
CONTRACT. IF YOU ARE CONSIDERING THE ADDITION OF CERTAIN DEATH BENEFITS TO A
QUALIFIED ANNUITY, YOU SHOULD CONSULT YOUR TAX ADVISOR PRIOR TO MAKING A
PURCHASE FOR AN EXPLANATION OF THE POTENTIAL TAX IMPLICATION TO YOU.

EXAMPLE -- ROPP DEATH BENEFIT

-    You purchase the contract (with the ROPP rider) with a payment of $20,000.

-    The contract value falls to $18,000, at which point you take a $1,500
     partial surrender, leaving a contract value of $16,500.

     We calculate the death benefit as follows:

     The total purchase payments minus adjustments for partial surrenders:

                                                                      
Total purchase payments                                                  $20,000
minus adjusted partial surrenders, calculated as:
$1,500 x $20,000                                                          -1,667
---------------- =                                                       -------
     $18,000
for a death benefit of:                                                  $18,333
                                                                         =======



EXAMPLE -- MAV DEATH BENEFIT

-    You purchase the contract (with the MAV rider) with a payment of $20,000.

-    On the first contract anniversary the contract value grows to $24,000.

-    During the second contract year the contract value falls to $22,000, at
     which point you take a $1,500 partial surrender, leaving a contract value
     of $20,500.

     We calculate the death benefit as follows:

     The maximum anniversary value immediately preceding the date of death plus
     any payments made since that anniversary minus adjusted partial surrenders:

                                                                      
Greatest of your contract anniversary contract values:                   $24,000
plus purchase payments made since that anniversary:                           +0
minus adjusted partial surrenders, calculated as:
$1,500 x $24,000                                                          -1,636
---------------- =                                                       -------
     $22,000
for a death benefit of:                                                  $22,364
                                                                         =======





EXAMPLE -- 5-YEAR MAV DEATH BENEFIT

-    You purchase the contract (with the 5-Year MAV rider) with a payment of
     $20,000.

-    On the fifth contract anniversary the contract value grows to $30,000.

-    During the sixth contract year the contract value falls to $25,000, at
     which point you take a $1,500 partial surrender, leaving a contract value
     of $23,500.

     We calculate the death benefit as follows:

     The maximum 5-year anniversary value immediately preceding the date of
     death plus any payments made since that anniversary minus adjusted partial
     surrenders:

                                                                      
Greatest of your 5-year contract anniversary contract values:            $30,000
plus purchase payments made since that anniversary:                           +0
minus adjusted partial surrenders, calculated as:
$1,500 x $30,000                                                          -1,800
---------------- =                                                       -------
     $25,000
for a death benefit of:                                                  $28,200
                                                                         =======



EXAMPLE -- EEB DEATH BENEFIT

-    You purchase the contract with a payment of $100,000 and you are under age
     70. You select the seven-year surrender charge schedule, the MAV and the
     EEB.

-    During the first contract year the contract value grows to $105,000. The
     death benefit equals the standard death benefit, which is the contract
     value less purchase payment credits reversed, or $104,000. You have not
     reached the first contract anniversary so the EEB does not provide any
     additional benefit at this time.

-    On the first contract anniversary the contract value grows to $110,000. The
     death benefit equals:

                                                                     
MAV death benefit amount (contract value):                              $110,000
plus the EEB which equals 40% of earnings at death (MAV death benefit
   amount minus payments not previously surrendered):                     +4,000
                                                                        --------
   0.40 x  ($110,000 - $100,000) =
Total death benefit of:                                                 $114,000
                                                                        ========



-    On the second contract anniversary the contract value falls to $105,000.
     The death benefit equals:

                                                                     
MAV death benefit amount (maximum anniversary value):                   $110,000
plus the EEB (40% of earnings at death):                                  +4,000
                                                                        --------
    0.40 x ($110,000 - $100,000) =
Total death benefit of:                                                 $114,000
                                                                        ========



-    During the third contract year the contract value remains at $105,000 and
     you request a partial surrender, including the applicable 7% surrender
     charge, of $50,000. We will surrender $10,500 from your contract value free
     of charge (10% of your prior anniversary's contract value). The remainder
     of the surrender is subject to a 7% surrender charge because your purchase
     payment is two years old, so we will surrender $39,500 ($36,735 + $2,765 in
     surrender charges) from your contract value. Altogether, we will surrender
     $50,000 and pay you $48,025. We calculate purchase payments not previously
     surrendered as $100,000 - $45,000 = $55,000 (remember that $5,000 of the
     partial surrender is contract earnings). The death benefit equals:



     MAV death benefit amount (maximum anniversary value adjusted for partial
     surrenders):

                                                                      
$110,000 - ($50,000 x $110,000)                                          $57,619
           -------------------- =
                 $105,000
plus the EEB (40% of earnings at death):
   0.40 x ($57,619 - $55,000) =                                           +1,048
                                                                         -------
Total death benefit of:                                                  $58,667
                                                                         =======



-    On the third contract anniversary the contract value falls by $40,000. The
     death benefit remains at $58,667. The reduction in contract value has no
     effect.

-    On the ninth contract anniversary the contract value grows to a new high of
     $200,000. Earnings at death reaches its maximum of 250% of purchase
     payments not previously surrendered that are one or more years old. The
     death benefit equals:

                                                                     
MAV death benefit amount (contract value):                              $200,000
plus the EEB (40% of earnings at death)
   0.40 x 2.50 x ($55,000) =                                             +55,000
                                                                        --------
Total death benefit of:                                                 $255,000
                                                                        ========



-    During the tenth contract year you make an additional purchase payment of
     $50,000 and your contract value grows to $250,500. The new purchase payment
     is less than one year old and so it has no effect on the EEB. The death
     benefit equals:

                                                                     
MAV death benefit amount (contract value less purchase payment
   credits reversed):                                                   $250,000
plus the EEB (40% of earnings at death)
   0.40 x 2.50 x ($55,000) =                                             +55,000
                                                                        --------
Total death benefit of:                                                 $305,000
                                                                        ========



-    During the eleventh contract year the contract value remains $250,500 and
     the "new" purchase payment is now one year old. The value of the EEB
     changes. The death benefit equals:

                                                                     
MAV death benefit amount (contract value):                              $250,500
plus the EEB which equals 40% of earnings at death (the standard
   death benefit amount minus payments not previously
   surrendered):
   0.40 x ($250,500 - $105,000) =                                        +58,200
                                                                        --------
Total death benefit of:                                                 $308,700
                                                                        ========



EXAMPLE -- EEP DEATH BENEFIT

-    You purchase the contract with an exchange purchase payment of $100,000 and
     you are under age 70. You select the seven-year surrender charge schedule,
     the MAV and the EEP.

-    During the first contract year the contract value grows to $105,000. The
     death benefit on equals the standard death benefit amount, which is the
     contract value less purchase payment credits reversed, or $104,000. You
     have not reached the first contract anniversary so neither the EEP Part I
     nor Part II provides any additional benefit at this time.

-    On the first contract anniversary the contract value grows to $110,000. You
     have not reached the second contract anniversary so the EEP Part II does
     not provide any additional benefit at this time. The death benefit equals:

                                                                     
MAV death benefit amount (contract value):                              $110,000
plus the EEP Part I which equals 40% of earnings at death (the MAV
   death benefit amount minus purchase payments not previously
   surrendered):
   0.40 x ($110,000 - $100,000) =                                         +4,000
                                                                        --------
Total death benefit of:                                                 $114,000
                                                                        ========





-    On the second contract anniversary the contract value falls to $105,000.
     The death benefit equals:

                                                                     
MAV death benefit amount (maximum anniversary value):                   $110,000
plus the EEP Part I (40% of earnings at death):
   0.40 x ($110,000 - $100,000) =                                         +4,000
plus the EEP Part II which in the third contract year equals 10% of
   exchange purchase payments identified at issue and not previously
   surrendered:
   0.10 x $100,000 =                                                     +10,000
                                                                        --------
Total death benefit of:                                                 $124,000
                                                                        ========



-    During the third contract year the contract value remains at $105,000 and
     you request a partial surrender, including the applicable 7% surrender
     charge, of $50,000. We will surrender $10,500 from your contract value free
     of charge (10% of your prior anniversary's contract value). The remainder
     of the surrender is subject to a 7% surrender charge because your purchase
     payment is two years old, so we will surrender $39,500 ($36,735 + $2,765 in
     surrender charges) from your contract value.

     Altogether, we will surrender $50,000 and pay you $47,235. We calculate
     purchase payments not previously surrendered as $100,000 - $45,000 =
     $55,000 (remember that $5,000 of the partial surrender is contract
     earnings). The death benefit equals:

                                                                     
MAV death benefit amount (maximum anniversary value adjusted for
   partial surrenders):
 $110,000 - ($50,000 x $110,000)                                         $57,619
            -------------------- =
                  $105,000
plus the EEP Part I (40% of earnings at death):
   0.40 x ($57,619 - $55,000) =                                           +1,048
plus the EEP Part II which in the third contract year equals 10% of
   exchange purchase payments identified at issue and not previously
   surrendered:                                                           +5,500
   0.10 x $55,000 =                                                     --------
Total death benefit of:                                                 $ 64,167
                                                                        ========



-    On the third contract anniversary the contract value falls by $40,000. The
     death benefit remains at $64,167. The reduction in contract value has no
     effect.

-    On the ninth contract anniversary the contract value grows to a new high of
     $200,000. Earnings at death reaches its maximum of 250% of purchase
     payments not previously surrendered that are one or more years old. Because
     we are beyond the fourth contract anniversary the EEP also reaches its
     maximum of 20%. The death benefit equals:

                                                                     
MAV death benefit amount (contract value):                              $200,000
plus the EEP Part I (40% of earnings at death)
   .40  x (2.50 x $55,000) =                                             +55,000
plus the EEP Part II which after the fourth contract year equals 20%
   of exchange purchase payments identified at issue and not
   previously surrendered:
   0.20 x $55,000 =                                                      +11,000
                                                                        --------
Total death benefit of:                                                 $266,000
                                                                        ========



-    During the tenth contract year you make an additional purchase payment of
     $50,000 and your contract value grows to $250,500. The new purchase payment
     is less than one year old and so it has no effect on either the EEP Part I
     or EEP Part II. The death benefit equals:

                                                                     
MAV death benefit amount (contract value less purchase payment
   credits reversed):                                                   $250,000
plus the EEP Part I (40% of earnings at death)
   .40 x (2.50 x $55,000) =                                              +55,000
plus the EEP Part II, which after the fourth contract year equals 20%
   of exchange purchase payments identified at issue and not
   previously surrendered:
   0.20 x $55,000 =                                                      +11,000
                                                                        --------
Total death benefit of:                                                 $316,000
                                                                        ========



-    During the eleventh contract year the contract value remains $250,500 and
     the "new" purchase payment is now one year old. The value of the EEP Part I
     changes but the value of the EEP Part II remains constant. The death
     benefit equals:



                                                                     
MAV death benefit amount (contract value):                              $250,500
plus the EEP Part I which equals 40% of earnings at death (the MAV
   death benefit minus payments not previously surrendered):
   0.40 x ($250,500 - $105,000) =                                        +58,200
plus the EEP Part II, which after the fourth contract year equals 20%
   of exchange purchase payments identified at issue and not
   previously surrendered: 0.20 x $55,000 =                              +11,000
                                                                        --------
Total death benefit of:                                                 $319,700
                                                                        ========




APPENDIX E: EXAMPLE -- OPTIONAL LIVING BENEFITS

THE PURPOSE OF THIS APPENDIX IS TO ILLUSTRATE THE OPERATION OF VARIOUS OPTIONAL
LIVING BENEFIT RIDERS.

IN ORDER TO DEMONSTRATE THESE CONTRACT RIDERS, AN EXAMPLE MAY SHOW HYPOTHETICAL
CONTRACT VALUES. THESE CONTRACT VALUES DO NOT REPRESENT PAST OR FUTURE
PERFORMANCE. ACTUAL CONTRACT VALUES MAY BE MORE OR LESS THAN THOSE SHOWN AND
WILL DEPEND ON a NUMBER OF FACTORS, INCLUDING BUT NOT LIMITED TO THE INVESTMENT
EXPERIENCE OF THE SUBACCOUNTS, GPAS, SPECIAL DCA FIXED ACCOUNT, REGULAR FIXED
ACCOUNT AND THE FEES AND CHARGES THAT APPLY TO YOUR CONTRACT.

THESE EXAMPLES ARE INTENDED TO SHOW HOW THE OPTIONAL RIDERS OPERATE, AND DO NOT
TAKE INTO ACCOUNT WHETHER A PARTICULAR OPTIONAL RIDER IS PART OF A QUALIFIED
ANNUITY. QUALIFIED ANNUITIES ARE SUBJECT TO RMDS AT CERTAIN AGES (SEE "TAXES --
QUALIFIED ANNUITIES -- REQUIRED MINIMUM DISTRIBUTIONS") WHICH MAY REQUIRE YOU TO
TAKE PARTIAL SURRENDERS FROM THE CONTRACT. IF YOU ARE CONSIDERING THE ADDITION
OF CERTAIN OPTIONAL RIDERS TO A QUALIFIED ANNUITY, YOU SHOULD CONSULT YOUR TAX
ADVISOR PRIOR TO MAKING A PURCHASE FOR AN EXPLANATION OF THE POTENTIAL TAX
IMPLICATION TO YOU.

EXAMPLE -- ACCUMULATION BENEFIT

The following example shows how the Accumulation Benefit rider works based on
hypothetical values. It is not intended to depict investment performance of the
contract.

The example assumes:

-    You purchase the contract (with the Accumulation Benefit rider) with a
     payment of $100,000. No purchase payment credit applies.

-    You make no additional purchase payments.

-    You do not exercise the Elective Step-up option

-    The Accumulation Benefit rider fee is 0.80%.



                         ASSUMED NET    PARTIAL SURRENDER       ADJUSTED                 ACCUMULATION
 END OF CONTRACT YEAR  RATE OF RETURN  (BEGINNING OF YEAR)  PARTIAL SURRENDER    MCAV   BENEFIT AMOUNT  CONTRACT VALUE
---------------------  --------------  -------------------  -----------------  -------  --------------  --------------
                                                                                      
          1                  12%                   0                  0        100,000           0         111,104
          2                  15%                   0                  0        101,398           0         126,747
          3                   3%                   0                  0        103,604           0         129,505
          4                  -8%                   0                  0        103,604           0         118,192
          5                 -15%                   0                  0        103,604           0          99,634
          6                  20%               2,000              2,080        101,525           0         116,224
          7                  15%                   0                  0        106,071           0         132,588
          8                 -10%                   0                  0        106,071           0         118,375
          9                 -20%               5,000              4,480        101,590           0          89,851
         10                 -12%                   0                  0        101,590      23,334          78,256


EXAMPLE -- SECURESOURCE RIDERS

EXAMPLE #1: SINGLE LIFE BENEFIT: COVERED PERSON HAS NOT REACHED AGE 65 AT THE
TIME THE CONTRACT AND RIDER ARE PURCHASED.

ASSUMPTIONS:

-    You purchase the contract with a payment of $100,000 and make no additional
     payments to the contract.

-    You are the sole owner and also the annuitant. You are age 60.

-    Automatic Annual Step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied Annual Step-ups are indicated in
     BOLD.




-    You have elected the PN program Moderate model portfolio or investment
     option at issue. On the 1st contract anniversary, you elect to change to
     the Moderately Aggressive investment option. The target investment option
     under the contract is the Moderate investment option.




                                                                                            LIFETIME
                                 HYPOTHETICAL                                              WITHDRAWAL
CONTRACT                           ASSUMED             BASIC WITHDRAWAL BENEFIT             BENEFIT
DURATION  PURCHASE    PARTIAL      CONTRACT    ---------------------------------------  ----------------
IN YEARS  PAYMENTS  WITHDRAWALS     VALUE         GBA         RBA        GBP    RBP       ALP      RALP
--------  --------  -----------  ------------  --------    --------    ------  -------  ------    ------
                                                                       
At Issue  $100,000    $   N/A      $100,000    $100,000    $100,000    $7,000  $ 7,000  $  N/A    $  N/A
0.5              0      5,000        92,000     100,000      95,000     7,000    2,000     N/A       N/A
1                0          0        90,000      90,000(1)   90,000(1)  6,300    6,300     N/A       N/A
2                0          0        81,000      90,000      90,000     6,300    6,300     N/A       N/A
5                0          0        75,000      90,000      90,000     6,300    6,300   5,400(2)  5,400(2)
5.5              0      5,400        70,000      90,000      84,600     6,300      900   5,400         0
6                0          0        69,000      90,000      84,600     6,300    6,300   5,400     5,400
6.5              0      6,300        62,000      90,000      78,300     6,300        0   3,720(3)      0
7                0          0        64,000      90,000      78,300     6,300    6,300   3,840     3,840
7.5              0     10,000        51,000      51,000(4)   51,000(4)  3,570        0   3,060(4)      0
8                0          0        55,000      55,000      55,000     3,850    3,850   3,300     3,300



At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, spousal continuation, contract ownership change, or PN
program model portfolio or investment option changes), you can continue to
withdraw up to either the GBP of $3,850 each year until the RBA is reduced to
zero, or the ALP of $3,300 each year until the later of your death or the RBA is
reduced to zero.



(1)  Allocation to the PN program Moderately Aggressive model portfolio or
     investment option during a withdrawal phase will reset the benefit. The GBA
     is reset to the lesser of the prior GBA or the contract value. The RBA is
     reset to the lesser of the prior RBA or the contract value. The ALP (if
     established) is reset to the lesser of the prior ALP or 6% of the contract
     value. Any future withdrawals will reallocate your contract value to the
     Moderate model portfolio or investment option if you are invested more
     aggressively than the Moderate model portfolio or investment option.


(2)  The ALP and RALP are established on the contract anniversary date following
     the date the Covered Person reaches age 65 as 6% of the RBA.

(3)  The $6,300 withdrawal is greater than the $5,400 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(4)  The $10,000 withdrawal is greater than both the $6,300 RBP allowed under
     the basic withdrawal benefit and the $3,840 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.

EXAMPLE #2: SINGLE LIFE BENEFIT: COVERED PERSON HAS REACHED 65 AT THE TIME THE
CONTRACT AND RIDER ARE PURCHASED.

ASSUMPTIONS:

-    You purchase the contract with a payment of $100,000 and make no additional
     payments to the contract.

-    You are the sole owner and also the annuitant. You are age 65.

-    Automatic Annual Step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied Annual Step-ups are indicated in
     BOLD.



-    Your death occurs after 6 1/2 contract years and your spouse continues the
     contract and rider. Your spouse is over age 65 and is the new Covered
     Person.



                                                                                             LIFETIME
                                 HYPOTHETICAL                                               WITHDRAWAL
CONTRACT                           ASSUMED            BASIC WITHDRAWAL BENEFIT               BENEFIT
DURATION  PURCHASE    PARTIAL      CONTRACT    --------------------------------------    ----------------
IN YEARS  PAYMENTS  WITHDRAWALS     VALUE         GBA         RBA        GBP     RBP       ALP      RALP
--------  --------  -----------  ------------  --------    --------    ------  ------    ------    ------
                                                                        
At Issue  $100,000    $   N/A      $100,000    $100,000    $100,000    $7,000  $7,000    $6,000    $6,000
1                0          0       105,000     105,000     105,000     7,350   7,000(1)  6,300     6,000(1)
2                0          0       110,000     110,000     110,000     7,700   7,000(1)  6,600     6,000(1)
3                0          0       110,000     110,000     110,000     7,700   7,700(2)  6,600     6,600(2)
3.5              0      6,600       110,000     110,000     103,400     7,700   1,100     6,600         0
4                0          0       115,000     115,000     115,000     8,050   8,050     6,900     6,900
4.5              0      8,050       116,000     115,000     106,950     8,050       0     6,900(3)      0
5                0          0       120,000     120,000     120,000     8,400   8,400     7,200     7,200
5.5              0     10,000       122,000     120,000(4)  110,000(4)  8,400       0     7,200(4)      0
6                0          0       125,000     125,000     125,000     8,750   8,750     7,500     7,500
6.5              0          0       110,000     125,000     125,000     8,750   8,750     6,600(5)  6,600(5)
7                0          0       105,000     125,000     125,000     8,750   8,750     6,600     6,600



At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, contract ownership change, or PN program model portfolio or
investment option changes), your spouse can continue to withdraw up to either
the GBP of $8,750 each year until the RBA is reduced to zero, or the ALP of
$6,600 each year until the later of your spouse's death or the RBA is reduced to
zero.


(1)  The Annual Step-up has not been applied to the RBP or RALP because any
     withdrawal after step up during the Waiting Period would reverse any prior
     step ups prior to determining if the withdrawal is excess. Therefore,
     during the Waiting Period, the RBP is the amount you can withdraw without
     incurring the GBA and RBA excess withdrawal processing, and the RALP is the
     amount you can withdraw without incurring the ALP excess withdrawal
     processing.

(2)  On the third anniversary (after the end of the Waiting Period), the RBP and
     RALP are set equal to the GBP and ALP, respectively.

(3)  The $8,050 withdrawal is greater than the $6,900 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(4)  The $10,000 withdrawal is greater than both the $8,400 RBP allowed under
     the basic withdrawal benefit and the $7,200 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.

(5)  At spousal continuation, the ALP is reset to the lesser of the prior ALP or
     6% of the contract value and the RALP is reset to the ALP.

EXAMPLE #3: JOINT LIFE BENEFIT: YOUNGER COVERED SPOUSE HAS NOT REACHED 65 AT THE
TIME THE CONTRACT AND RIDER ARE PURCHASED.

ASSUMPTIONS:

-    You purchase the contract with a payment of $100,000 and make no additional
     payments to the contract.

-    You are age 59 and your spouse is age 60.

-    Automatic Annual Step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied Annual Step-ups are indicated in
     BOLD.




-    You have elected the PN program Moderate model portfolio or investment
     option at issue. On the 1st contract anniversary, you elect to change to
     the Moderately Aggressive investment option. The target model investment
     option under the contract is the Moderate investment option.


-    Your death occurs after 9 1/2 contract years and your spouse continues the
     contract and rider; the lifetime benefit is not reset.



                                                                                             LIFETIME
                                 HYPOTHETICAL                                               WITHDRAWAL
CONTRACT                           ASSUMED            BASIC WITHDRAWAL BENEFIT               BENEFIT
DURATION  PURCHASE    PARTIAL      CONTRACT    --------------------------------------    ----------------
IN YEARS  PAYMENTS  WITHDRAWALS     VALUE         GBA         RBA        GBP     RBP       ALP      RALP
--------  --------  -----------  ------------  --------    --------    ------  ------    ------    ------
                                                                        
At Issue  $100,000    $   N/A      $100,000    $100,000    $100,000    $7,000  $7,000    $  N/A    $  N/A
0.5              0      5,000        92,000     100,000      95,000     7,000   2,000       N/A       N/A
1                0          0        90,000      90,000(1)   90,000(1)  6,300   6,300       N/A       N/A
2                0          0        81,000      90,000      90,000     6,300   6,300       N/A       N/A
6                0          0        75,000      90,000      90,000     6,300   6,300     5,400(2)  5,400(2)
6.5              0      5,400        70,000      90,000      84,600     6,300     900     5,400         0
7                0          0        69,000      90,000      84,600     6,300   6,300     5,400     5,400
7.5              0      6,300        62,000      90,000      78,300     6,300       0     3,720(3)      0
8                0          0        64,000      90,000      78,300     6,300   6,300     3,840     3,840
8.5              0     10,000        51,000      51,000(4)   51,000(4)  3,570       0     3,060(4)      0
9                0          0        55,000      55,000      55,000     3,850   3,850     3,300     3,300
9.5              0          0        54,000      55,000      55,000     3,850   3,850     3,300     3,300
10               0          0        52,000      55,000      55,000     3,850   3,850     3,300     3,300



At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, or PN program model portfolio or investment option changes),
your spouse can continue to withdraw up to either the GBP of $3,850 each year
until the RBA is reduced to zero, or the ALP of $3,300 each year until the later
of your spouse's death or the RBA is reduced to zero.


(1)  The ALP and RALP are established on the contract anniversary date following
     the date the younger Covered Spouse reaches age 65 as 6% of the RBA.


(2)  Allocation to the PN program Moderately Aggressive model portfolio or
     investment option during a withdrawal phase will reset the benefit. The GBA
     is reset to the lesser of the prior GBA or the contract value. The RBA is
     reset to the lesser of the prior RBA or the contract value. The ALP is
     reset to the lesser of the prior ALP or 6% of the contract value. Any
     future withdrawals will reallocate your contract value to the Moderate
     model portfolio or investment opton if you are invested more aggressively
     than the Moderate model portfolio or investment option.


(3)  The $6,300 withdrawal is greater than the $5,400 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(4)  The $10,000 withdrawal is greater than both the $6,300 RBP allowed under
     the basic withdrawal benefit and the $3,840 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.

EXAMPLE #4: JOINT LIFE BENEFIT: YOUNGER COVERED SPOUSE HAS REACHED 65 AT THE
TIME THE CONTRACT AND RIDER ARE PURCHASED.

ASSUMPTIONS:

-    You purchase the contract with a payment of $100,000 and make no additional
     payments to the contract

-    You are age 71 and your spouse is age 70.

-    Automatic Annual Step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied Annual Step-ups are indicated in
     BOLD.



-    Your death occurs after 6 1/2 contract years and your spouse continues the
     contract and rider; the lifetime benefit is not reset.



                                                                                             LIFETIME
                                 HYPOTHETICAL                                               WITHDRAWAL
CONTRACT                           ASSUMED            BASIC WITHDRAWAL BENEFIT               BENEFIT
DURATION  PURCHASE    PARTIAL      CONTRACT    --------------------------------------    ----------------
IN YEARS  PAYMENTS  WITHDRAWALS     VALUE         GBA         RBA        GBP     RBP       ALP      RALP
--------  --------  -----------  ------------  --------    --------    ------  ------    ------    ------
                                                                        
At Issue  $100,000    $   N/A      $100,000    $100,000    $100,000    $7,000  $7,000    $6,000    $6,000
1                0          0       105,000     105,000     105,000     7,350   7,000(1)  6,300     6,000(1)
2                0          0       110,000     110,000     110,000     7,700   7,000(1)  6,600     6,000(1)
3                0          0       110,000     110,000     110,000     7,700   7,700(2)  6,600     6,600(2)
3.5              0      6,600       110,000     110,000     103,400     7,700   1,100     6,600         0
4                0          0       115,000     115,000     115,000     8,050   8,050     6,900     6,900
4.5              0      8,050       116,000     115,000     106,950     8,050       0     6,900(3)      0
5                0          0       120,000     120,000     120,000     8,400   8,400     7,200     7,200
5.5              0     10,000       122,000     120,000(4)  110,000(4)  8,400       0     7,200(4)      0
6                0          0       125,000     125,000     125,000     8,750   8,750     7,500     7,500
6.5              0          0       110,000     125,000     125,000     8,750   8,750     7,500     7,500
7                0          0       105,000     125,000     125,000     8,750   8,750     7,500     7,500



At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, or PN program model portfolio or investment option changes),
your spouse can continue to withdraw up to either the GBP of $8,750 each year
until the RBA is reduced to zero, or the ALP of $7,500 each year until the later
of your spouse's death or the RBA is reduced to zero.


(1)  The Annual Step-up has not been applied to the RBP or RALP because any
     withdrawal after step up during the Waiting Period would reverse any prior
     step ups prior to determining if the withdrawal is excess. Therefore,
     during the Waiting Period, the RBP is the amount you can withdraw without
     incurring the GBA and RBA excess withdrawal processing, and the RALP is the
     amount you can withdraw without incurring the ALP excess withdrawal
     processing.

(2)  On the third anniversary (after the end of the Waiting Period), the RBP and
     RALP are set equal to the GBP and ALP, respectively.

(3)  The $8,050 withdrawal is greater than the $6,900 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(4)  The $10,000 withdrawal is greater than both the $8,400 RBP allowed under
     the basic withdrawal benefit and the $7,200 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.


APPENDIX F: ADDITIONAL RMD DISCLOSURE

This appendix describes our current administrative practice for determining the
amount of withdrawals in any contract year which an owner may take under the
SecureSource rider or GWB for Life rider to satisfy the RMD rules under
401(a)(9) of the Code without application of the excess withdrawal processing
described in the rider. We reserve the right to modify this administrative
practice at any time upon 30 days' written notice to you.

For contract holders subject to annual RMD rules under the Section 401(a)(9) of
the Code, amounts you withdraw each year from this contract to satisfy these
rules are not subject to excess withdrawal processing under the terms of the
rider, subject to the following rules and our current administrative practice:

(1)  If on the date we calculated your Annual Life Expectancy Required Minimum
     Distribution Amount (ALERMDA), it is greater than the RBP from the
     beginning of the current contract year,

     -    A Basic Additional Benefit Amount (BABA) will be set equal to that
          portion of your ALERMDA that exceeds the value of the RBP from the
          beginning of the current contract year.

     -    Any withdrawals taken in a contract year will count first against and
          reduce the RBP for that contract year.

     -    Once the RBP for the current contract year has been depleted, any
          additional amounts withdrawn will count against and reduce the BABA.
          These withdrawals will not be considered excess withdrawals with
          regard to the GBA and RBA as long as they do not exceed the remaining
          BABA.

     -    Once the BABA has been depleted, any additional withdrawal amounts
          will be considered excess withdrawals with regard to the GBA and RBA
          and will subject them all to the excess withdrawal processing
          described by the SecureSource(SM) rider or GWB for Life rider.

(2)  If on the date we calculated your ALERMDA, it is greater than the RALP from
     the beginning of the current contract year,

     -    A Lifetime Additional Benefit Amount (LABA) will be set equal to that
          portion of your ALERMDA that exceeds the value of RALP from the
          beginning of the current contract year.

     -    Any withdrawals taken in a contract year will count first against and
          reduce the RALP for that contract year.

     -    Once the RALP for the current contract year has been depleted, any
          additional amounts withdrawn will count against and reduce the LABA.
          These withdrawals will not be considered excess withdrawals with
          regard to the ALP as long as they do not exceed the remaining LABA.

     -    Once the LABA has been depleted, any additional withdrawal amounts
          will be considered excess withdrawals with regard to the ALP and will
          subject the ALP to the excess withdrawal processing described by the
          SecureSource or GWB for Life rider.

(3)  If the ALP is established on a contract anniversary where your current
     ALERMDA is greater than the new RALP,

     -    An initial LABA will be set equal to that portion of your ALERMDA that
          exceeds the new RALP.

     -    This new LABA will be immediately reduced by the amount that total
          withdrawals in the current calendar year exceed the new RALP, but
          shall not be reduced to less than zero.

The ALERMDA is:

(1)  determined by us each calendar year;

(2)  based on the value of this contract alone on the date it is determined;

(3)  based on recalculated life expectancy taken from the Uniform Lifetime Table
     under the Code (applicable only to SecureSource riders); and



(4)  based on the company's understanding and interpretation of the requirements
     for life expectancy distributions intended to satisfy the required minimum
     distribution rules under Code Section 401(a)(9) and the Treasury
     Regulations promulgated thereunder as applicable on the effective date of
     this prospectus, to:

     1.   IRAs under Section 408(b) of the Code;

     2.   Roth IRAs under Section 408A of the Code;

     3.   SIMPLE IRAs under Section 408(p) of the Code;

     4.   Simplified Employee Pension IRA (SEP) plans under Section 408(k) of
          the Code;

     5.   Custodial and investment only plans under Section 401(a) of the Code;

     6.   TSAs under Section 403(b) of the Code.

In the future, the requirements under tax law for such distributions may change
and the life expectancy amount calculation provided under your SecureSource
rider or GWB for Life rider may not be sufficient to satisfy the requirements
under the tax law for these types of distributions. In such a situation, amounts
withdrawn to satisfy such distribution requirements will exceed your available
RBP or RALP amount and may result in the reduction of your GBA, RBA, and/or ALP
as described under the excess withdrawal provision of the rider.

In cases where the Code does not allow the life expectancy of a natural person
to be used to calculate the required minimum distribution amount (e.g., some
ownerships by trusts and charities), we will calculate the life expectancy RMD
amount as zero in all years. The life expectancy required minimum distribution
amount calculated by us will also equal zero in all years.

Please consult your tax advisor about the impact of these rules prior to
purchasing the SecureSource rider.



APPENDIX G: GUARANTOR WITHDRAWAL BENEFIT FOR LIFE RIDER DISCLOSURE

GUARANTOR WITHDRAWAL BENEFIT FOR LIFE (GWB FOR LIFE) RIDER

THE GWB FOR LIFE RIDER IS NO LONGER AVAILABLE FOR SALE.

The GWB for Life rider is an optional benefit that you may select for an
additional annual charge if(1):

-    the rider is available in your state; and

-    you are age 80 or younger on the contract issue date; or, if an owner is a
     nonnatural person, then the annuitant is age 80 or younger on the contract
     issue date.

(1)  The GWB for Life rider is not available under an inherited qualified
     annuity.

You must have elected the GWB for Life rider when you purchased your contract.
The rider effective date will be the contract issue date. It is available for
nonqualified annuities and qualified annuities except under 401(a) plans.

The GWB for Life rider guarantees that you will be able to withdraw up to a
certain amount each year from the contract, regardless of the investment
performance of your contract before the annuity payments begin, until you have
recovered at minimum all of your purchase payments plus any purchase payment
credits. And, under certain limited circumstances defined in the rider, you have
the right to take a specified amount of partial withdrawals in each contract
year until death (see "At Death" heading below) -- even if the contract value is
zero.

Your contract provides for annuity payouts to begin on the settlement date (see
"Buying Your Contract -- Settlement Date"). Before the settlement date, you have
the right to surrender some or all of your contract value, less applicable
administrative, surrender and rider charges imposed under the contract at the
time of the surrender (see "Surrenders"). Because your contract value will
fluctuate depending on the performance of the underlying funds in which the
subaccounts invest, the contract itself does not guarantee that you will be able
to take a certain surrender amount each year before the annuity payouts begin,
nor does it guarantee the length of time over which such surrenders can be made
before the annuity payouts begin.

The GWB for Life rider may be appropriate for you if you intend to make periodic
withdrawals from your annuity contract and wish to ensure that market
performance will not adversely affect your ability to withdraw your principal
over time.

Under the terms of the GWB for Life rider, the calculation of the amount which
can be withdrawn in each contract year varies depending on several factors,
including but not limited to the waiting period (see "Waiting period" heading
below) and whether or not the lifetime withdrawal benefit has become effective:

(1)  The basic withdrawal benefit gives you the right to take limited partial
     withdrawals in each contract year and guarantees that over time the
     withdrawals will total an amount equal to, at minimum, your purchase
     payments plus any purchase payment credits. Key terms associated with the
     basic withdrawal benefit are "Guaranteed Benefit Payment (GBP)," "Remaining
     Benefit Payment (RBP)," "Guaranteed Benefit Amount (GBA)," and "Remaining
     Benefit Amount (RBA)." See these headings below for more information.

(2)  The lifetime withdrawal benefit gives you the right, under certain limited
     circumstances defined in the rider, to take limited partial withdrawals
     until the later of death (see "At Death" heading below) or until the RBA
     (under the basic withdrawal benefit)is reduced to zero. Key terms
     associated with the lifetime withdrawal benefit are "Annual Lifetime
     Payment (ALP)," "Remaining Annual Lifetime Payment (RALP)," "Covered
     Person," and "Annual Lifetime Payment Attained Age (ALPAA)." See these
     headings below for more information.

Only the basic withdrawal benefit will be in effect prior to the date that the
lifetime withdrawal benefit becomes effective. The lifetime withdrawal benefit
becomes effective automatically on the rider anniversary date after the covered
person reaches age 65 or the rider effective date if the covered person is age
65 or older on the rider effective date (see "Annual Lifetime Payment Attained
Age (ALPAA)" heading below).



Provided the annuity payouts have not begun, the GWB for Life rider guarantees
that you may take the following partial withdrawal amounts each contract year:

-    After the waiting period and before the establishment of the ALP, the rider
     guarantees that each contract year you can cumulatively withdraw an amount
     equal to the GBP;

-    During the waiting period and before the establishment of the ALP, the
     rider guarantees that each contract year you can cumulatively withdraw an
     amount equal to the value of the RBP at the beginning of the contract year;

-    After the waiting period and after the establishment of the ALP, the rider
     guarantees that each contract year you have the option to cumulatively
     withdraw an amount equal to the ALP or the GBP, but the rider does not
     guarantee withdrawals of the sum of both the ALP and the GBP in a contract
     year;

-    During the waiting period and after the establishment of the ALP, the rider
     guarantees that each contract year you have the option to cumulatively
     withdraw an amount equal to the value of the RALP or the RBP at the
     beginning of the contract year, but the rider does not guarantee
     withdrawals of the sum of both the RALP and the RBP in a contract year.

If you withdraw less than the allowed partial withdrawal amount in a contract
year, the unused portion cannot be carried over to the next contract year. As
long as your partial withdrawals in each contract year do not exceed the annual
partial withdrawal amount allowed under the rider, and there has not been a
contract ownership change or spousal continuation of the contract, the
guaranteed amounts available for partial withdrawals are protected (i.e., will
not decrease).

If you withdraw more than the allowed partial withdrawal amount in a contract
year, we call this an "excess withdrawal" under the rider. Excess withdrawals
trigger an adjustment of a benefit's guaranteed amount, which may cause it to be
reduced (see "GBA Excess Withdrawal Processing", "RBA Excess Withdrawal
Processing", and "ALP Excess Withdrawal Processing" headings below).

Please note that each of the two benefits has its own definition of the allowed
annual withdrawal amount. Therefore, a partial withdrawal may be considered an
excess withdrawal for purposes of the lifetime withdrawal benefit only, basic
benefit only, or both.

If your withdrawals exceed the greater of the RBP or the RALP, surrender charges
under the terms of the contract may apply (see "Charges -- Surrender Charges").
The amount we actually deduct from your contract value will be the amount you
request plus any applicable surrender charge. Market value adjustments, if
applicable, will also be made (see "Guarantee Period Accounts (GPAs) -- Market
Value Adjustment"). We pay you the amount you request. Any partial withdrawals
you take under the contract will reduce the value of the death benefits. (see
"Benefits in Case of Death" and "Optional Benefits"). Upon full surrender of the
contract, you will receive the remaining contract value less any applicable
charges (see "Surrenders").


The rider's guaranteed amounts can be increased at the specified intervals if
your contract value has increased. An annual step up feature is available at
each contract anniversary, subject to certain conditions, and may be applied
automatically to your contract or may require you to elect the step up (see
"Annual Step Up" heading below). If you exercise the annual step up election,
the spousal continuation step up election (see "Spousal Continuation Step Up"
heading below) or change your PN program investment option (or change from a PN
program model portfolio to an investment option), the rider charge may increase
(see "Charges").


If you take withdrawals during the waiting period, any prior steps ups applied
will be reversed and step ups will not be available until the end of waiting
period. You may take withdrawals after the waiting period without reversal of
prior step ups.

You should consider whether the GWB for Life rider is appropriate for you
because:

-    LIFETIME WITHDRAWAL BENEFIT LIMITATIONS: The lifetime withdrawal benefit is
     subject to certain limitations, including but not limited to:

     (a)  Once the contract value is less than $600*, payments are made for as
          long as the oldest owner or, if an owner is a nonnatural person, the
          oldest annuitant, is living (see "If Contract Value Reduces to Less
          than $600" heading below). However, if the contract value is $600 or
          greater, the lifetime withdrawal benefit terminates when a death
          benefit becomes payable (see "At Death" heading below). Therefore, if
          there are multiple contract owners, the rider may terminate or the
          lifetime benefit may be



          reduced. When one of the contract owners dies the benefit terminates
          even though other contract owners are still living (except, if the
          contract is continued under the spousal continuation provision of the
          contract).

          *    Under our current administrative practice, we allow the minimum
               contract value to be $0. Therefore, these limitations will only
               apply when the contract value is reduced to zero.

     (b)  Excess withdrawals can reduce the ALP to zero even though the GBA,
          RBA, GBP and/or RBP values are greater than zero. If the both the ALP
          and the contract value are zero, the lifetime withdrawal benefit will
          terminate.

     (c)  When the lifetime withdrawal benefit is first established, the initial
          ALP is based on the basic withdrawal benefit's RBA at that time (see
          "Annual Lifetime Payment (ALP)" heading below), unless there has been
          a spousal continuation or ownership change. Any withdrawal you take
          before the ALP is established reduces the RBA and therefore may result
          in a lower amount of lifetime withdrawals you are allowed to take.

     (d)  Withdrawals can reduce both the contract value and the RBA to zero
          prior to the establishment of the ALP. If this happens, the contract
          and the GWB for Life rider will terminate.


-    USE OF THE PORTFOLIO NAVIGATOR PROGRAM IS REQUIRED: You must be invested in
     one of the model portfolios or investment options of the PN program. This
     requirement limits your choice of subaccounts, regular fixed account and
     GPAs (if available) to the PN program investment option or those that are
     in the model portfolio (if applicable) you have selected. You may allocate
     qualifying purchase payments and applicable purchase payment credits to the
     Special DCA fixed account, when available (see "The Special DCA Fixed
     Account"), and we will make monthly transfers into the model portfolio or
     investment options you have chosen. This means you will not be able to
     allocate contract value to all of the subaccounts, GPAs or the regular
     fixed account that are available under the contract to contract owners who
     do not elect this rider. (See "Making the Most of Your Contract --
     Portfolio Navigator Program".) Subject to state restrictions, we reserve
     the right to limit the number of model portfolios or investment options
     from which you can select based on the dollar amount of purchase payments
     you make.


-    LIMITATIONS ON PURCHASE PAYMENTS: We reserve the right to limit the
     cumulative amount of purchase payments, subject to state restrictions. For
     current limitation, see "Buying Your Contract -- Purchase Payments".

-    LIMITATIONS ON PURCHASE OF OTHER RIDERS UNDER THIS CONTRACT: If you select
     the GWB for Life rider, you may not elect the Accumulation Benefit rider.

-    NON-CANCELABLE: Once elected, the GWB for Life rider may not be cancelled
     and the fee will continue to be deducted until the contract is terminated,
     the contract value reduces to zero (described below) or annuity payouts
     begin.

-    INTERACTION WITH TOTAL FREE AMOUNT (TFA) CONTRACT PROVISION: The TFA is the
     amount you are allowed to withdraw from the contract in each contract year
     without incurring a surrender charge (see "Charges -- Surrender Charge").
     The TFA may be greater than the RBP or RALP under this rider. Any amount
     you withdraw under the contract's TFA provision that exceeds the RBP or
     RALP is subject to the excess withdrawal processing described below for the
     GBA, RBA and ALP.

     You should consult your tax advisor before you select this optional rider
     if you have any questions about the use of this rider in your tax
     situation:

-    TAX CONSIDERATIONS FOR NONQUALIFIED ANNUITIES: Under current federal income
     tax law, withdrawals under nonqualified annuities, including partial
     withdrawals taken from the contract under the terms of this rider, are
     treated less favorably than amounts received as annuity payments under the
     contract. (See "Taxes -- Nonqualified Annuities".) Also, withdrawals before
     age 59 1/2 may incur a 10% IRS early withdrawal penalty and may be
     considered taxable income. You should consult your tax advisor before you
     select this optional rider if you have any questions about the use of this
     rider in your tax situation.

-    TAX CONSIDERATIONS FOR QUALIFIED ANNUITIES: Qualified annuities have
     minimum distribution rules that govern the timing and amount of
     distributions from the annuity contract (see "Taxes -- Qualified Annuities
     -- Required Minimum Distributions.") If you have a qualified annuity, you
     may need to take an RMD that exceeds the guaranteed amount of withdrawal
     available under the rider and such withdrawals may reduce future benefits
     guaranteed under the rider. While the rider permits certain excess
     withdrawals to be made for the purpose of satisfying RMD requirements for
     this contract alone without reducing future benefits guaranteed under the
     rider, there can be no guarantee that changes in the federal income tax law
     after the effective date of the rider will not require a larger



     RMD to be taken, in which case, future guaranteed withdrawals under the
     rider could be reduced. You should consult your tax advisor before you
     select this optional rider if you have any questions about the use of this
     rider in your tax situation.

     See Appendix F for additional information.

-    TAX CONSIDERATIONS FOR TSAS: If your contract is a TSA, your right to take
     a surrender is restricted (see "TSA -- Special Provisions"), so the rider
     may be of limited value to you. You should consult your tax advisor before
     you select this optional rider if you have any questions about the use of
     this rider in your tax situation.

KEY TERMS AND PROVISIONS OF THE GWB FOR LIFE RIDER ARE DESCRIBED BELOW:

WITHDRAWAL: For the purposes of this rider, the term "withdrawal" is equal to
the term "surrender" in the contract or any other riders. Withdrawals will
adjust contract values and benefits in the same manner as surrenders.

PARTIAL WITHDRAWALS: A withdrawal of an amount that does not result in a
surrender of the contract. The partial withdrawal amount is a gross amount and
will include any surrender charge and any market value adjustment.

WAITING PERIOD: The period of time starting on the rider effective date during
which the annual step up is not available if you take withdrawals. The current
waiting period is three years.

GUARANTEED BENEFIT AMOUNT (GBA): The total cumulative amount available for
partial withdrawals over the life of the rider under the basic withdrawal
benefit. The maximum GBA is $5,000,000. The GBA cannot be withdrawn and is not
payable as a death benefit. Rather, the GBA is an interim value used to
calculate the amount available for withdrawals each year under the basic
withdrawal benefit (see "Guaranteed Benefit Payment" below). At any time, the
total GBA is the sum of the individual GBAs associated with each purchase
payment.

The GBA is determined at the following times, calculated as described:

-    At contract issue -- the GBA is equal to the initial purchase payment, plus
     any purchase payment credit;

-    When you make additional purchase payments -- each additional purchase
     payment has its own GBA equal to the amount of the purchase payment plus
     any purchase payment credit.

-    At step up -- (see "Annual Step Up," and "Spousal Continuation Step Up"
     headings below).

-    When an individual RBA is reduced to zero -- the GBA that is associated
     with that RBA will also be set to zero.

-    When you make a partial withdrawal during the waiting period and after a
     step-up -- Any prior annual step-ups will be reversed. Step up reversal
     means that the GBA associated with each purchase payment will be reset to
     the amount of that purchase payment plus any purchase payment credit. The
     step up reversal will only happen once during the waiting period, when the
     first partial withdrawal is made.

-    When you make a partial withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the GBA remains unchanged. If
          there have been multiple purchase payments, both the total GBA and
          each payment's GBA remain unchanged.

     (b)  is greater than the total RBP -- GBA EXCESS WITHDRAWAL PROCESSING WILL
          BE APPLIED TO THE GBA. If the partial withdrawal is made during the
          waiting period, the excess withdrawal processing is applied AFTER any
          previously applied annual step ups have been reversed.

GBA EXCESS WITHDRAWAL PROCESSING

The total GBA will automatically be reset to the lesser of (a) the total GBA
immediately prior to the excess withdrawal; or (b) the contract value
immediately following the withdrawal.



If there have been multiple purchase payments, each payment's GBA after the
withdrawal will be reset to equal that payment's RBA after the withdrawal plus
(a) times (b), where:

     (a)  is the ratio of the total GBA after the withdrawal less the total RBA
          after the withdrawal to the total GBA before the withdrawal less the
          total RBA after the withdrawal; and

     (b)  is each payment's GBA before the withdrawal less that payment's RBA
          after the withdrawal.

REMAINING BENEFIT AMOUNT (RBA): Each withdrawal you make reduces the amount of
GBA that is guaranteed by this rider as future withdrawals. At any point in
time, the RBA equals the amount of GBA that remains available for withdrawals
for the remainder of the contract's life, and total RBA is the sum of the
individual RBAs associated with each purchase payment. The maximum RBA is
$5,000,000.

The RBA is determined at the following times, calculated as described:

-    At contract issue -- the RBA is equal to the initial purchase payment plus
     any purchase payment credit.

-    When you make additional purchase payments -- each additional purchase
     payment has its own RBA initially set equal to that payment's GBA (the
     amount of the purchase payment plus any purchase payment credit).

-    At step up -- (see "Annual Step Up," and "Spousal Continuation Step Up"
     headings below).

-    When you make a partial withdrawal during the waiting period and after a
     step up -- Any prior annual step ups will be reversed. Step up reversal
     means that the RBA associated with each purchase payment will be reset to
     the amount of that purchase payment plus any purchase payment credit. The
     step up reversal will only happen once during the waiting period, when the
     first partial withdrawal is made.

-    When you make a partial withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the total RBA is reduced by the
          amount of the withdrawal. If there have been multiple purchase
          payments, each payment's RBA is reduced in proportion to its RBP.

     (b)  is greater than the total RBP -- RBA EXCESS WITHDRAWAL PROCESSING WILL
          BE APPLIED TO THE RBA. If the partial withdrawal is made during the
          waiting period, the excess withdrawal processing is applied AFTER any
          previously applied annual step ups have been reversed.

RBA EXCESS WITHDRAWAL PROCESSING

The total RBA will automatically be reset to the lesser of (a) the contract
value immediately following the withdrawal, or (b) the total RBA immediately
prior to the withdrawal, less the amount of the withdrawal.

If there have been multiple purchase payments, both the total RBA and each
payment's RBA will be reset. The total RBA will be reset according to the excess
withdrawal processing described above. Each payment's RBA will be reset in the
following manner:

1.   The withdrawal amount up to the total RBP is taken out of each RBA bucket
     in proportion to its individual RBP at the time of the withdrawal; and

2.   The withdrawal amount above the total RBP and any amount determined by the
     excess withdrawal processing are taken out of each RBA bucket in proportion
     to its RBA at the time of the withdrawal.

GUARANTEED BENEFIT PAYMENT (GBP): At any time, the amount available for partial
withdrawals in each contract year after the waiting period, until the RBA is
reduced to zero, under the basic withdrawal benefit. At any point in time, each
purchase payment has its own GBP, which is equal to the lesser of that payment's
RBA or 7% of that payment's GBA, and the total GBP is the sum of the individual
GBPs.



During the waiting period, the guaranteed annual withdrawal amount may be less
than the GBP due to the limitations the waiting period imposes on your ability
to utilize both annual step ups and withdrawals (see "Waiting Period" heading
above). The guaranteed annual withdrawal amount during the waiting period is
equal to the value of the RBP at the beginning of the contract year.

The GBP is determined at the following times, calculated as described:

-    At contract issue -- the GBP is established as 7% of the GBA value.

-    At each contract anniversary -- each payment's GBP is reset to the lesser
     of that payment's RBA or 7% of that payment's GBA value.

-    When you make additional purchase payments -- each additional purchase
     payment has its own GBP equal to that purchase payment amount plus any
     purchase payment credit, multiplied by 7%.

-    At step up -- (see "Annual Step Up," and "Spousal Continuation Step Up"
     headings below).

-    When an individual RBA is reduced to zero -- the GBP associated with that
     RBA will also be reset to zero.

-    When you make a partial withdrawal during the waiting period and after a
     step up -- Any prior annual step ups will be reversed. Step up reversal
     means that the GBA and the RBA associated with each purchase payment will
     be reset to the amount of that purchase payment. Each payment's GBP will be
     reset to the sum of that purchase payment and any purchase payment credit,
     multiplied by 7%. The step up reversal will only happen once during the
     waiting period, when the first partial withdrawal is made.

-    When you make a partial withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the total RBP -- the GBP remains unchanged.

     (b)  is greater than the total RBP -- each payment's GBP is reset to the
          lesser of that payment's RBA or 7% of that payment's GBA value, based
          on the RBA and GBA after the withdrawal. If the partial withdrawal is
          made during the waiting period, these calculations are done AFTER any
          previously applied annual step ups have been reversed.

REMAINING BENEFIT PAYMENT (RBP): The amount available for partial withdrawals
for the remainder of the contract year under the basic withdrawal benefit. At
any point in time, the total RBP is the sum of the RBPs for each purchase
payment. During the waiting period, when the guaranteed amount may be less than
the GBP, the value of the RBP at the beginning of the contract year will be that
amount that is actually guaranteed each contract year.

The RBP is determined at the following times, calculated as described:

-    At the beginning of each contract year during the waiting period and prior
     to any withdrawal -- the RBP for each purchase payment is set equal to that
     purchase payment plus any purchase payment credit, multiplied by 7%.

-    At the beginning of any other contract year -- the RBP for each purchase
     payment is set equal to that purchase payment's GBP.

-    When you make additional purchase payments -- each additional purchase
     payment has its own RBP equal to that payment's GBP.

-    At step up -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    At spousal continuation -- See "Spousal Option to Continue the Contract"
     heading below.

-    When an individual RBA is reduced to zero -- the RBP associated with that
     RBA will also be reset to zero.

-    When you make any partial withdrawal -- the total RBP is reset to equal the
     total RBP immediately prior to the partial withdrawal less the amount of
     the partial withdrawal, but not less than zero. If there have been multiple
     purchase payments, each payment's RBP is reduced proportionately. IF YOU
     WITHDRAW AN AMOUNT GREATER THAN THE RBP, GBA EXCESS WITHDRAWAL PROCESSING
     AND RBA EXCESS WITHDRAWAL PROCESSING ARE APPLIED and the amount available
     for the future partial withdrawals for the remainder of the



     contract's life may be reduced by more than the amount of withdrawal. When
     determining if a withdrawal will result in the excess withdrawal
     processing, the applicable RBP will not yet reflect the amount of the
     current withdrawal.

COVERED PERSON: The person whose life is used to determine when the ALP is
established, and the duration of the ALP payments. The covered person is the
oldest contract owner unless otherwise specified on your contract data page. If
an owner is a nonnatural person (i.e. trust or corporation), the covered person
is the oldest annuitant. A spousal continuation or a change of contract
ownership may reduce the amount of the lifetime withdrawal benefit and may
change the covered person.

ANNUAL LIFETIME PAYMENT ATTAINED AGE (ALPAA): The covered person's age after
which time the lifetime benefit can be established. Currently, the lifetime
benefit can be established on the later of the contract effective date or the
contract anniversary date on/following the date the covered person reaches age
65.

ANNUAL LIFETIME PAYMENT (ALP): Once established, the ALP at any time is the
amount available for withdrawals in each contract year after the waiting period
until the later of death (see "At Death" heading below), or the RBA is reduced
to zero, under the lifetime withdrawal benefit. The maximum ALP is $300,000.
Prior to establishment of the ALP, the lifetime withdrawal benefit is not in
effect and the ALP is zero.

During the waiting period, the guaranteed annual lifetime withdrawal amount may
be less than the ALP due to the limitations the waiting period imposes on your
ability to utilize both annual step-ups and withdrawals (see "Waiting Period"
heading above). The guaranteed annual lifetime withdrawal amount during the
waiting period is equal to the value of the RALP at the beginning of the
contract year.

The ALP is determined at the following times:

-    The later of the contract effective date or the contract anniversary date
     on/following the date the covered person reaches age 65 -- the ALP is
     established as 6% of the total RBA.

-    When you make additional purchase payments -- each additional purchase
     payment increases the ALP by the amount of the purchase payment plus any
     purchase payment credit, multiplied by 6%.

-    At step ups -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    At contract ownership change -- (see "Spousal Option to Continue the
     Contract" and "Contract Ownership Change" headings below).

-    When you make a partial withdrawal during the waiting period and after a
     step up -- Any prior annual step ups will be reversed. Step up reversal
     means that the ALP will be reset to equal total purchase payments plus any
     purchase payment credits, multiplied by 6%. The step up reversal will only
     happen once during the waiting period, when the first partial withdrawal is
     made.

-    When you make a partial withdrawal at any time and the amount withdrawn is:

     (a)  less than or equal to the RALP -- the ALP remains unchanged.

     (b)  is greater than the RALP -- ALP EXCESS WITHDRAWAL PROCESSING WILL BE
          APPLIED TO THE ALP. Please note that if the partial withdrawal is made
          during the waiting period, the excess withdrawal processing is applied
          AFTER any previously applied annual step ups have been reversed.

ALP EXCESS WITHDRAWAL PROCESSING

The ALP is reset to the lesser of the ALP immediately prior to the withdrawal,
or 6% of the contract value immediately following the withdrawal.

REMAINING ANNUAL LIFETIME PAYMENT (RALP): The amount available for partial
withdrawals for the remainder of the contract year under the lifetime withdrawal
benefit. During the waiting period, when the guaranteed annual withdrawal amount
may be less than the ALP, the value of the RALP at the beginning of the contract
year will be the amount that is actually guaranteed each contract year. Prior to
establishment of the ALP, the lifetime withdrawal benefit is not in effect and
the RALP is zero.



THE RALP IS DETERMINED AT THE FOLLOWING TIMES:

-    The later of the contract effective date or the contract anniversary date
     following the date the covered person reaches age 65, and:

     (a)  During the waiting period and Prior to any withdrawals -- the RALP is
          established equal to the sum of purchase payments and purchase payment
          credits, multiplied by 6%.

     (b)  At any other time -- the RALP is established equal to the ALP.

-    At the beginning of each contract year during the waiting period and prior
     to any withdrawals -- the RALP is set equal to the total purchase payments
     plus any purchase payment credits, multiplied by 6%.

-    At the beginning of any other contract year -- the RALP is set equal to
     ALP.

-    At step ups -- (see "Annual Step Up" and "Spousal Continuation Step Up"
     headings below).

-    When you make additional purchase payments -- each additional purchase
     payment increases the RALP by the sum of the purchase payment and any
     purchase payment credit, multiplied by 6%.

-    When you make any partial withdrawal -- the RALP equals the RALP
     immediately prior to the partial withdrawal less the amount of the partial
     withdrawal, but not less than zero. IF YOU WITHDRAW AN AMOUNT GREATER THAN
     THE RALP, ALP EXCESS WITHDRAWAL PROCESSING IS APPLIED and the amount
     available for future partial withdrawals for the remainder of the
     contract's life may be reduced by more than the amount of withdrawal. When
     determining if a withdrawal will result in excess withdrawal processing,
     the applicable RALP will not yet reflect the amount of the current
     withdrawal.

REQUIRED MINIMUM DISTRIBUTIONS (RMD): If you are taking RMDs from this contract
and the RMD calculated separately for this contract is greater than the RBP or
the RALP on the most recent contract anniversary, the portion of the RMD that
exceeds the RBP or RALP will not be subject to excess withdrawal processing
provided that the following conditions are met:

-    The RMD is the life expectancy RMD for this contract alone; and

-    The RMD amount is based on the requirements of the Code section 401(a) (9),
     related Code provisions and regulations thereunder that were in effect on
     the effective date of this rider.

RMD rules follow the calendar year which most likely does not coincide with your
contract year and therefore may limit when you can take your RMD and not be
subject to excess withdrawal processing.

Withdrawal amounts greater than the RBP or RALP on the contract anniversary date
that do not meet these conditions will result in excess withdrawal processing as
described above.

See Appendix F for additional information.

STEP UP DATE: The date any step up becomes effective, and depends on the type of
step up being applied (see "Annual Step Up" and "Spousal Continuation Step Up"
headings below).

ANNUAL STEP UP: Beginning with the first contract anniversary, an increase of
the GBA, RBA, GBP, RBP, ALP, and/or RALP values may be available. A step up does
not create contract value, guarantee the performance of any investment option,
or provide a benefit that can be withdrawn or paid upon death. Rather, a step up
determines the current values of the GBA, RBA, GBP, RBP, ALP, and RALP, and may
extend the payment period or increase the allowable payment.

The annual step up is subject to the following rules:

-    The annual step up is available when the RBA, or if established, the ALP,
     would increase on the step up date.

-    Only one step up is allowed each contract year.



-    If you take any withdrawals during the waiting period, any previously
     applied step ups will be reversed and the annual step up will not be
     available until the end of the waiting period.

-    If the application of the step up does not increase the rider charge, the
     annual step up will be automatically applied to your contract, and the step
     up date is the contract anniversary date.

-    If the application of the step up would increase the rider charge, the
     annual step up is not automatically applied. Instead, you have the option
     to step up for 30 days after the contract anniversary. If you exercise the
     elective annual step up option, you will pay the rider charge in effect on
     the step up date. If you wish to exercise the elective annual step up
     option, we must receive a request from you or your financial advisor. The
     step up date is the date we receive your request to step up. If your
     request is received after the close of business, the step up date will be
     the next valuation day.

-    The ALP and RALP are not eligible for step ups until they are established.
     Prior to being established, the ALP and RALP values are both zero.

-    Please note it is possible for the ALP to step up even if the RBA or GBA do
     not step up and it is also possible for the RBA and GBA to step up even if
     the ALP does not step up.

The annual step up resets the GBA, RBA, GBP, RBP, ALP and RALP values as
follows:

-    The total RBA will be reset to the greater of the total RBA immediately
     prior to the step up date or the contract value on the step up date.

-    The total GBA will be reset to the greater of the total GBA immediately
     prior to the step up date or the contract value on the step up date.

-    The total GBP will be reset using the calculation as described above based
     on the increased GBA and RBA.

-    The total RBP will be reset as follows:

     (a)  During the waiting period and prior to any withdrawals, the RBP will
          not be affected by the step up.

     (b)  At any other time, the RBP will be reset as the increased GBP less all
          prior withdrawals made in the current contract year, but not less than
          zero.

-    The ALP will be reset to the greater of the ALP immediately prior to the
     step up date or 6% of the contract value on the step up date.

-    The RALP will be reset as follows:

     (a)  During the waiting period and prior to any withdrawals, the RALP will
          not be affected by the step up.

     (b)  At any other time, the RALP will be reset as the increased ALP less
          all prior withdrawals made in the current contract year, but not less
          than zero.

SPOUSAL OPTION TO CONTINUE THE CONTRACT: If a surviving spouse elects to
continue the contract and continues the contract as the new owner under the
spousal continuation provision of the contract, the GWB for Life rider also
continues. When the spouse elects to continue the contract, any remaining
waiting period is cancelled; the covered person will be re-determined and is the
covered person referred to below; and the GBA, RBA, GBP, RBP, ALP and RALP
values are affected as follows:

-    The GBA, RBA, and GBP values remain unchanged.

-    The RBP is automatically reset to the GBP less all prior withdrawals made
     in the current contract year, but not less than zero.

-    If the ALP has not yet been established and the new covered person has not
     yet reached age 65 as of the date of continuation -- the ALP will be
     established on the contract anniversary following the date the covered
     person reaches age 65 as the lesser of the RBA or the anniversary contract
     value, multiplied by 6%. The RALP will be established on the same date
     equal to the ALP.



-    If the ALP has not yet been established but the new covered person is age
     65 or older as of the date of continuation -- the ALP will be established
     on the date of continuation as the lesser of the RBA or the contract value,
     multiplied by 6%. The RALP will be established on the same date in an
     amount equal to the ALP less all prior partial withdrawals made in the
     current contract year, but will never be less than zero.

-    If the ALP has been established but the new covered person has not yet
     reached age 65 as of the date of continuation -- the ALP and RALP will be
     automatically reset to zero for the period of time beginning with the date
     of continuation and ending with the contract anniversary following the date
     the covered person reaches age 65. At the end of this time period, the ALP
     will be reset to the lesser of the RBA or the anniversary contract value,
     multiplied by 6%, and the RALP will be reset to the ALP.

-    If the ALP has been established and the new covered person is age 65 or
     older as of the date of continuation -- the ALP will be automatically reset
     to the lesser of the current ALP or 6% of the contract value on the date of
     continuation. The RALP will be reset to the ALP less all prior withdrawals
     made in the current contract year, but not less than zero.

Please note that the lifetime withdrawal benefit amount may be reduced as a
result of the spousal continuation.

SPOUSAL CONTINUATION STEP UP: If a surviving spouse elects to continue the
contract, another elective step up option becomes available. To exercise the
step up, the spouse or the spouse's financial advisor must submit a request
within 30 days of the date of continuation. The step up date is the date we
receive the spouse's request to step up. If the request is received after the
close of business, the step up date will be the next valuation day. The GBA,
RBA, GBP, RBP, ALP and RALP will be reset in the same fashion as the annual step
up.

If the spousal continuation step up option is exercised and we have increased
the charge for the rider, the spouse will pay the charge that is in effect on
the step up date.

It is our current administrative practice to process the spousal continuation
step up as described in the next paragraph; however, we reserve the right to
discontinue the administrative practice and will give you 30 days' written
notice of any such change.

At the time of spousal continuation, a step-up may be available. All annual
step-up rules (see "Annual Step-Up" heading above), other than those that apply
to the waiting period, also apply to the spousal continuation step-up. If the
spousal continuation step-up is processed automatically, the step-up date is the
valuation date the spousal continuation is effective. If not, the spouse must
elect the step up and must do so within 30 days of the spousal continuation
date. If the spouse elects the spousal continuation step up, the step-up date is
the valuation date we receive the spouse's written request to step up if we
receive the request by the close of business on that day, otherwise the next
valuation date.

IF CONTRACT VALUE REDUCES TO LESS THAN $600*: If the contract value reduces to
less than $600 and the total RBA remains greater than zero, you will be paid in
the following scenarios:

1)   The ALP has not yet been established and the contract value is reduced to
     less than $600 for any reason other than full or partial surrender of more
     than the RBP. In this scenario, you can choose to:

     (a)  receive the remaining schedule of GBPs until the RBA equals zero; or

     (b)  wait until the rider anniversary on/following the date the covered
          person reaches age 65, and then receive the ALP annually until the
          latter of (i) the death of the covered person, or (ii) the RBA is
          reduced to zero.

We will notify you of this option. If no election is made, the ALP will be paid.

2)   The ALP has been established and the contract value reduces to less than
     $600 as a result of fees or charges, or a withdrawal that is less than or
     equal to both the RBP and the RALP. In this scenario, you can choose to
     receive:

     (a)  the remaining schedule of GBPs until the RBA equals zero; or

     (b)  the ALP annually until the latter of (i) the death of the covered
          person, or (ii) the RBA is reduced to zero.

We will notify you of this option. If no election is made, the ALP will be paid.


3)   The ALP has been established and the contract value falls to zero as a
     result of a withdrawal that is greater than the RALP but less than or equal
     to the RBP. In this scenario, the remaining schedule of GBPs will be paid
     until the RBA equals zero.

4)   The ALP has been established and the contract value falls to zero as a
     result of a partial withdrawal that is greater than the RBP but less than
     or equal to the RALP. In this scenario, the ALP will be paid annually until
     the death of the Covered Person.

Under any of these scenarios:

-    The annualized amounts will be paid to you in the frequency you elect. You
     may elect a frequency offered by us at the time payments begin. Available
     payment frequencies will be no less frequent than annually.

-    We will no longer accept additional purchase payments;

-    You will no longer be charged for the rider;

-    Any attached death benefit riders will terminate; and

-    The death benefit becomes the remaining payments, if any, until the RBA is
     reduced to zero.

The GWB for Life rider and the contract will terminate under either of the
following two scenarios:

-    If the contract value falls to zero as a result of a withdrawal that is
     greater than the RBP and RALP. This is full surrender of the contract.

-    If the contract value falls to zero as a result of a withdrawal that is
     greater than the RALP but less than or equal to the RBP, and the total RBA
     is reduced to zero.

*    Under the current administrative practice, we allow the minimum contract
     value to be $0. Therefore, these scenarios will only apply when the
     contract value is reduced to zero.

AT DEATH: If the contract value is greater than zero when the death benefit
becomes payable, the beneficiary may elect to take the death benefit as a lump
sum under the terms of the contract (see "Benefits in Case of Death") or the
annuity payout option (see "Remaining Benefit Amount Payout Option" heading
below).

If the contract value equals zero and the death benefit becomes payable, the
following will occur:

-    If the RBA is greater than zero and the owner has been receiving the GBP
     each year, the GBP will continue to be paid to the beneficiary until the
     RBA equals zero.

-    If the covered person dies and the RBA is greater than zero and the owner
     has been receiving the ALP each year, the ALP will continue to be paid to
     the beneficiary until the RBA equals zero.

-    If the covered person is still alive and the RBA is greater than zero and
     the owner has been receiving the ALP each year, the ALP will continue to be
     paid to the beneficiary until the later of the death of the covered person
     or the RBA equals zero.

-    If the covered person is still alive and the RBA equals zero and the owner
     has been receiving the ALP each year, the ALP will continue to be paid to
     the beneficiary until the death of the covered person.

-    If the covered person dies and the RBA equals zero, the benefit terminates.
     No further payments will be made.

CONTRACT OWNERSHIP CHANGE: If the contract changes ownership (see "Changing
Ownership"), the covered person will be redetermined and is the covered person
referred to below. The GBA, RBA, GBP, RBP values will remain unchanged. The ALP
and RALP will be reset as follows. Our current administrative practice is to
only reset the ALP and RALP if the covered person changes due to the ownership
change.



-    If the ALP has not yet been established and the new covered person has not
     yet reached age 65 as of the ownership change date -- the ALP and the RALP
     will be established on the contract anniversary following the date the
     covered person reaches age 65. The ALP will be set equal to the lesser of
     the RBA or the anniversary contract value, multiplied by 6%. If the
     anniversary date occurs during the waiting period and prior to a
     withdrawal, the RALP will be set equal to the lesser of the ALP or total
     purchase payments plus purchase payment credits, multiplied by 6%. If the
     anniversary date occurs at any other time, the RALP will be set to the ALP.

-    If the ALP has not yet been established but the new covered person is age
     65 or older as of the ownership change date -- the ALP and the RALP will be
     established on the ownership change date. The ALP will be set equal to the
     lesser of the RBA or the contract value, multiplied by 6%. If the ownership
     change date occurs during the waiting period and prior to a withdrawal, the
     RALP will be set to the lesser of the ALP or total purchase payments plus
     purchase payment credits, multiplied by 6%. If the ownership change date
     occurs at any other time, the RALP will be set equal to the ALP less all
     prior withdrawals made in the current contract year but not less than zero.

-    If the ALP has been established but the new covered person has not yet
     reached age 65 as of the ownership change date -- the ALP and the RALP will
     be reset to zero for the period of time beginning with the ownership change
     date and ending with the contract anniversary following the date the
     covered person reaches age 65. At the end of this time period, the ALP will
     be reset to the lesser of the RBA or the anniversary contract value,
     multiplied by 6%. If the time period ends during the waiting period and
     prior to any withdrawals, the RALP will be reset to the lesser of the ALP
     or total purchase payments plus any purchase payment credits, multiplied by
     6%. If the time period ends at any other time, the RALP will be reset to
     the ALP.

-    If the ALP has been established and the new covered person is age 65 or
     older as of the ownership change date -- the ALP and the RALP will be reset
     on the ownership change date. The ALP will be reset to the lesser of the
     current ALP or 6% of the contract value. If the ownership change date
     occurs during the waiting period and prior to a withdrawal, the RALP will
     be reset to the lesser of the ALP or total purchase payments plus purchase
     payment credits, multiplied by 6%. If the ownership change date occurs at
     any other time, the RALP will be reset to the ALP less all prior
     withdrawals made in the current contract year but not less than zero.

Please note that the lifetime withdrawal benefit amount may be reduced as a
result of the ownership change.

REMAINING BENEFIT AMOUNT PAYOUT OPTION: Several annuity payout plans are
available under the contract. As an alternative to these annuity payout plans, a
fixed annuity payout option is available under the GWB for Life rider.

Under this option the amount payable each year will be equal to the remaining
schedule of GBPs, but the total amount paid over the life of the annuity will
not exceed the current total RBA at the time you begin this fixed annuity payout
option. These annualized amounts will be paid in the frequency that you elect.
The frequencies will be among those offered by us at that time but will be no
less frequent than annually. If, at the death of the owner, total payments have
been made for less than the RBA, the remaining payments will be paid to the
beneficiary (see "The Annuity Payout Period" and "Taxes").

This option may not be available if the contract is issued to qualify under
Section 403 or 408 of the Code. For such contracts, this option will be
available only if the number of years it will take to deplete the RBA by paying
the GBP each year is less than the life expectancy of the owner at the time the
option becomes effective. Such life expectancy will be computed using a life
expectancy table published by the IRS.

This annuity payout option may also be elected by the beneficiary of a contract
as a settlement option. Whenever multiple beneficiaries are designated under the
contract, each such beneficiary's share of the proceeds if they elect this
option will be in proportion to their applicable designated beneficiary
percentage. Beneficiaries of nonqualified contracts may elect this settlement
option subject to the distribution requirements of the contract. We reserve the
right to adjust the future schedule of GBPs if necessary to comply with the
Code.

RIDER TERMINATION

The GWB for Life rider cannot be terminated either by you or us except as
follows:

1. Annuity payouts under an annuity payout plan will terminate the rider.

2. Termination of the contract for any reason will terminate the rider.



EXAMPLE -- GWB FOR LIFE RIDER

EXAMPLE #1: COVERED PERSON HAS NOT REACHED AGE 65 AT THE TIME THE CONTRACT AND
RIDER ARE PURCHASED.

ASSUMPTIONS:

-    You purchase the RAVA 4 Select contract with a payment of $100,000.

-    You are the sole owner and also the annuitant. You are age 60.

-    You make no additional payments to the contract.

-    Automatic annual step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied annual step-ups are indicated in
     BOLD.



                                    HYPOTHETICAL                                               LIFETIME WITHDRAWAL
CONTRACT                               ASSUMED              BASIC WITHDRAWAL BENEFIT                 BENEFIT
DURATION   PURCHASE     PARTIAL       CONTRACT     -----------------------------------------   ------------------
IN YEARS   PAYMENTS   WITHDRAWALS       VALUE         GBA          RBA         GBP      RBP       ALP        RALP
--------   --------   -----------   ------------   --------     --------     ------   ------    ------     -------
                                                                                
At Issue   $100,000     $   N/A       $100,000     $100,000     $100,000     $7,000   $7,000    $  N/A     $  N/A

     0.5          0       7,000         92,000      100,000       93,000      7,000        0       N/A        N/A
       1          0           0         91,000      100,000       93,000      7,000    7,000       N/A        N/A
     1.5          0       7,000         83,000      100,000       86,000      7,000        0       N/A        N/A
       2          0           0         81,000      100,000       86,000      7,000    7,000       N/A        N/A
       5          0           0         75,000      100,000       86,000      7,000    7,000     5,160(1)   5,160(1)
     5.5          0       5,160         70,000      100,000       80,840      7,000    1,840     5,160          0
       6          0           0         69,000      100,000       80,840      7,000    7,000     5,160      5,160
     6.5          0       7,000         62,000      100,000       73,840      7,000        0     3,720(2)       0
       7          0           0         70,000      100,000       73,840      7,000    7,000     4,200      4,200
     7.5          0      10,000         51,000       51,000(3)    51,000(3)   3,570        0     3,060(3)       0
       8          0           0         55,000       55,000       55,000      3,850    3,850     3,300      3,300


At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, spousal continuation or contract ownership change), you can
continue to withdraw up to either the GBP of $3,850 each year until the RBA is
reduced to zero, or the ALP of $3,300 each year until the later of your death or
the RBA is reduced to zero.

(1)  The ALP and RALP are established on the contract anniversary date following
     the date the covered person reaches age 65.

(2)  The $7,000 withdrawal is greater than the $5,160 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(3)  The $10,000 withdrawal is greater than both the $7,000 RBP allowed under
     the basic withdrawal benefit and the $4,200 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.

EXAMPLE #2: COVERED PERSON HAS REACHED 65 AT THE TIME THE CONTRACT AND RIDER ARE
PURCHASED.

ASSUMPTIONS:

-    You purchase the RAVA 4 Select contract with a payment of $100,000.



-    You are the sole owner and also the annuitant. You are age 65.

-    You make no additional payments to the contract.

-    Automatic annual step-ups are applied each anniversary when available,
     where the contract value is greater than the RBA and/or 6% of the contract
     value is greater than the ALP. Applied annual step-ups are indicated in
     BOLD.



                                    HYPOTHETICAL                                                 LIFETIME WITHDRAWAL
CONTRACT                               ASSUMED              BASIC WITHDRAWAL BENEFIT                   BENEFIT
DURATION   PURCHASE     PARTIAL       CONTRACT     -----------------------------------------     -------------------
IN YEARS   PAYMENTS   WITHDRAWALS       VALUE         GBA          RBA         GBP      RBP        ALP       RALP
--------   --------   -----------   ------------   --------     --------     ------   ------     ------     ------
                                                                                 
At Issue   $100,000     $   N/A       $100,000     $100,000     $100,000     $7,000   $7,000     $6,000     $6,000
       1          0           0        105,000      105,000      105,000      7,350    7,000(1)   6,300      6,000(1)
       2          0           0        110,000      110,000      110,000      7,700    7,000(1)   6,600      6,000(1)
       3          0           0        110,000      110,000      110,000      7,700    7,700(2)   6,600      6,600(2)
     3.5          0       6,600        110,000      110,000      103,400      7,700    1,100      6,600          0
       4          0           0        115,000      115,000      115,000      8,050    8,050      6,900      6,900
     4.5          0       8,050        116,000      115,000      106,950      8,050        0      6,900(3)       0
       5          0           0        120,000      120,000      120,000      8,400    8,400      7,200      7,200
     5.5          0      10,000        122,000      120,000(4)   110,000(4)   8,400        0      7,200(4)       0
       6          0           0        125,000      125,000      125,000      8,750    8,750      7,500      7,500


At this point, assuming no additional activity (step ups, excess withdrawals,
purchase payments, spousal continuation or contract ownership change), you can
continue to withdraw up to either the GBP of $8,750 each year until the RBA is
reduced to zero, or the ALP of $7,500 each year until the later of your death or
the RBA is reduced to zero.

(1)  The annual step-up has not been applied to the RBP or RALP because any
     withdrawal after step up during the waiting period would reverse any prior
     step ups prior to determining if the withdrawal is excess. Therefore,
     during the waiting period, the RBP is the amount you can withdraw without
     incurring the GBA and RBA excess withdrawal processing, and the RALP is the
     amount you can withdraw without incurring the ALP excess withdrawal
     processing.

(2)  On the third anniversary (after the end of the waiting period), the RBP and
     RALP are set equal to the GBP and ALP, respectively.

(3)  The $8,050 withdrawal is greater than the $6,900 RALP allowed under the
     lifetime withdrawal benefit and therefore the excess withdrawal processing
     is applied to the ALP, resetting the ALP to the lesser of the prior ALP or
     6% of the contract value following the withdrawal.

(4)  The $10,000 withdrawal is greater than both the $8,400 RBP allowed under
     the basic withdrawal benefit and the $7,200 RALP allowed under the lifetime
     withdrawal benefit and therefore the excess withdrawal processing is
     applied to the GBA, RBA, and ALP. The GBA is reset to the lesser of the
     prior GBA or the contract value following the withdrawal. The RBA is reset
     to the lesser of the prior RBA less the withdrawal or the contract value
     following the withdrawal. The ALP is reset to the lesser of the prior ALP
     or 6% of the contract value following the withdrawal.



APPENDIX H: CONDENSED FINANCIAL INFORMATION

(Unaudited)

The following tables give per-unit information about the financial history of
each subaccount. The date in which operations commenced in each price level is
noted in parenthesis.





[TO BE FILED BY AMENDMENT]








TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION


                                                                           
Calculating Annuity Payouts................................................   p.
Rating Agencies............................................................   p.
Revenues Received During Calendar Year 2009................................   p.
Principal Underwriter......................................................   p.
Independent Registered Public Accounting Firm..............................   p.
Financial Statements






                       THIS PAGE LEFT BLANK INTENTIONALLY



(RIVERSOURCE ANNUITIES LOGO)

RiverSource Life Insurance Company
70100 Ameriprise Financial Center
Minneapolis, MN 55474
1 (800) 862-7919

   RiverSource Distributors, Inc. (Distributor), Member FINRA. Insurance and
    annuity products are issued by RiverSource Life Insurance Company. Both
       companies are affiliated with Ameriprise Financial Services, Inc.

      (C)2008-2009 RiverSource Life Insurance Company. All rights reserved.


H G (4/10)



                       STATEMENT OF ADDITIONAL INFORMATION

                                       FOR


               RIVERSOURCE RETIREMENT ADVISOR VARIABLE ANNUITY(R)


                         RIVERSOURCE RETIREMENT ADVISOR

                          VARIABLE ANNUITY(R) - BAND 3


                   RIVERSOURCE RETIREMENT ADVISOR ADVANTAGE(R)

                                VARIABLE ANNUITY


                    RIVERSOURCE RETIREMENT ADVISOR SELECT(R)

                                VARIABLE ANNUITY


                   RIVERSOURCE RETIREMENT ADVISOR ADVANTAGE(R)

                            VARIABLE ANNUITY - BAND 3


                RIVERSOURCE RETIREMENT ADVISOR ADVANTAGE PLUS(R)

                                VARIABLE ANNUITY


                  RIVERSOURCE RETIREMENT ADVISOR SELECT PLUS(R)

                                VARIABLE ANNUITY


                  RIVERSOURCE RETIREMENT ADVISOR 4 ADVANTAGE(R)

                                VARIABLE ANNUITY


                   RIVERSOURCE RETIREMENT ADVISOR 4 SELECT(R)

                                VARIABLE ANNUITY


                   RIVERSOURCE RETIREMENT ADVISOR 4 ACCESS(R)

                                VARIABLE ANNUITY


                    RIVERSOURCE(R) FLEXIBLE PORTFOLIO ANNUITY

                         RIVERSOURCE VARIABLE ACCOUNT 10

                    (previously IDS Life Variable Account 10)


                                 April 30, 2010


RiverSource Variable Account 10 is a separate account of RiverSource Life
Insurance Company (RiverSource Life).

This Statement of Additional Information (SAI) is not a prospectus. It should be
read together with the prospectus dated the same date as this SAI, which may be
obtained from your sales representative, or by writing or calling us at the
address and telephone number below.

This SAI contains financial information for all the subaccounts of RiverSource
Variable Account 10. Not all subaccounts of RiverSource Variable Account 10
apply to your specific contract.

RiverSource Life Insurance Company
70100 Ameriprise Financial Center
Minneapolis, MN 55474
(800) 862-7919


S-6325 H (4/10)




TABLE OF CONTENTS


                                                                                
Calculating Annuity Payouts.....................................................   p.  3
Rating Agencies ................................................................   p.  4
Revenues Received During Calendar Year 2009.....................................   p.  4
Principal Underwriter...........................................................   p.  5
Independent Registered Public Accounting Firm...................................   p.  5
Financial Statements





 2    RIVERSOURCE VARIABLE ACCOUNT 10



CALCULATING ANNUITY PAYOUTS

THE VARIABLE ACCOUNT
We do the following calculations separately for each of the subaccounts of the
variable account. The separate monthly payouts, added together, make up your
total variable annuity payout.

INITIAL PAYOUT: To compute your first monthly payout, we:

-  determine the dollar value of your contract on the valuation date and deduct
   any applicable premium tax; then

-  apply the result to the annuity table contained in the contract or another
   table at least as favorable.

The annuity table shows the amount of the first monthly payout for each $1,000
of value which depends on factors built into the table, as described below.

ANNUITY UNITS: We then convert the value of your subaccount to annuity units. To
compute the number of units credited to you, we divide the first monthly payout
by the annuity unit value (see below) on the valuation date. The number of units
in your subaccount is fixed. The value of the units fluctuates with the
performance of the underlying fund.

SUBSEQUENT PAYOUTS: To compute later payouts, we multiply:

-  the annuity unit value on the valuation date; by

-  the fixed number of annuity units credited to you.

ANNUITY UNIT VALUES: We originally set this value at $1 for each subaccount. To
calculate later values we multiply the last annuity value by the product of:

-  the net investment factor; and

-  the neutralizing factor.

The purpose of the neutralizing factor is to offset the effect of the assumed
rate built into the annuity table. With an assumed investment rate of 5%, the
neutralizing factor is 0.999866 for a one day valuation period.

NET INVESTMENT FACTOR: We determine the net investment factor by:

-  adding the fund's current net asset value per share plus the per share amount
   of any accrued income or capital gain dividends to obtain a current adjusted
   net asset value per share; then

-  dividing that sum by the previous adjusted net asset value per share; and

-  subtracting the percentage factor representing the mortality and expense risk
   fee from the result.

Because the net asset value of the fund may fluctuate, the net investment factor
may be greater or less than one, and the annuity unit value may increase or
decrease. You bear this investment risk in a subaccount.

THE FIXED ACCOUNT
We guarantee your fixed annuity payout amounts. Once calculated, your payout
will remain the same and never change. To calculate your annuity payouts we:

-  take the value of your fixed account at the retirement/settlement date or the
   date you selected to begin receiving your annuity payouts; then

-  using an annuity table, we apply the value according to the annuity payout
   plan you select.

The annuity payout table we use will be the one in effect at the time you choose
to begin your annuity payouts. The values in the table will be equal to or
greater than the table in your contract.


                                           RIVERSOURCE VARIABLE ACCOUNT 10    3



RATING AGENCIES

We receive ratings from independent rating agencies. These agencies evaluate the
financial soundness and claims-paying ability of insurance companies based on a
number of different factors. The ratings reflect each agency's estimation of our
ability to meet our contractual obligations such as making annuity payouts and
paying death benefits and other distributions. As such, the ratings relate to
our fixed account and not to the subaccounts. This information generally does
not relate to the management or performance of the subaccounts.

For detailed information on the agency ratings given to RiverSource Life, see
"Debt & Ratings Information" under "Investors Relations" on our website at
ameriprise.com or contact your sales representative. You also may view our
current ratings by visiting the agency websites directly at:

                                             
A.M. Best                                                                       www.ambest.com
Fitch                                                                     www.fitchratings.com
Moody's                                                               www.moodys.com/insurance
Standard & Poor's                                                     www.standardandpoors.com




A.M. Best -- Rates insurance companies for their financial strength.

Fitch -- Rates insurance companies for their claims-paying ability.

Moody's -- Rates insurance companies for their financial strength.

Standard & Poor's -- Rates insurance companies for their financial strength.


REVENUES RECEIVED DURING CALENDAR YEAR 2009


The following table shows the unaffiliated funds ranked according to highest to
lowest total dollar amounts the funds and their affiliates paid to us and/or our
affiliates in 2008. Some of these funds may not be available under your contract
or policy. Please see your contract or policy prospectus regarding the
investment options available to you.


(to be filed by amendment)





If the revenue received from affiliated funds were included in the table above,
payment to us or our affiliates by the RiverSource Variable Series Trust Funds
(RVST) or their affiliates would be at the top of the list.


 4    RIVERSOURCE VARIABLE ACCOUNT 10



PRINCIPAL UNDERWRITER

RiverSource Distributors, Inc. (RiverSource Distributors), our affiliate, serves
as principal underwriter for the contracts, which are offered on a continuous
basis. Its offices are located at 70100 Ameriprise Financial Center,
Minneapolis, MN 55474. RiverSource Distributors is registered with the
Securities and Exchange Commission under the Securities Act of 1934 as a broker
dealer and is a member of the Financial Industry Regulartory Authority (FINRA).
The contracts are offered to the public through certain securities broker-
dealers that have entered into sales agreements with us and RiverSource
Distributors and whose personnel are legally authorized to sell annuity and life
insurance products. RiverSource Distributors is a wholly-owned subsidiary of
Ameriprise Financial.

Prior to Jan. 1, 2007, IDS Life Insurance Company (IDS Life) served as the
principal underwriter for the contracts. The aggregate dollar amount of
underwriting commissions paid to IDS Life for the variable account in 2006 was
$290,026,122. IDS Life retained no underwriting commission from the sale of the
contracts.


Effective Jan. 1, 2007, RiverSource Distributors became the principal
underwriter for the contracts. The aggregate dollar amount of underwriting
commissions paid to RiverSource Distributors for the variable account in 2009
was $___________, and in 2008 was $___________. RiverSource Distributors
retained no underwriting commissions from the sale of the contracts.


INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


(to be filed by Amendment)



FINANCIAL STATEMENTS



(to be filed by Amendment)



                                           RIVERSOURCE VARIABLE ACCOUNT 10    5





PART C.

Item 24. Financial Statements and Exhibits

(a)  Financial statements included in Part B of this Registration Statement:

     The audited financial statements of the RiverSource Variable Account 10
     including:

     Report of Independent Registered Public Accounting Firm dated April 24,
     2009.

     Statements of Assets and Liabilities for the year ended Dec. 31, 2008.

     Statements of Operations for the year ended Dec. 31, 2008.

     Statements of Changes and Net Assets for the years ended Dec. 31, 2008 and
     2007.

     Notes to Financial Statements.

     The audited financial statements of the RiverSource Life Insurance Company
     including:

     Report of Independent Registered Public Accounting Firm dated March 27,
     2009.

     Consolidated Balance Sheets as of Dec. 31, 2008 and 2007.

     Consolidated Statements of Income for the years ended Dec. 31, 2008, 2007
     and 2006.

     Consolidated Statements of Cash Flows for the years ended Dec. 31, 2008,
     2007 and 2006.

     Consolidated Statements of Stockholder's Equity for the three years ended
     Dec. 31, 2008, 2007 and 2006.

     Notes to Consolidated Financial Statements.

(b)  Exhibits:

1.1  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing the IDS Life Variable Account 10 dated August 23, 1995, filed
     electronically as Exhibit 1 to Registrant's Initial Registration Statement
     No. 33-62407 is incorporated herein by reference.

1.2  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 105 additional subaccounts within the separate account, filed



     electronically as Exhibit 1.2 to Pre-Effective Amendment No. 1 to
     Registration Statement No. 333-79311 filed on or about Aug. 10, 1999, is
     incorporated herein by reference.

1.3  Resolution of the Board of Directors of IDS life Insurance Company
     establishing 25 additional subaccounts within the separate account, filed
     electronically as Exhibit 1.3 to Registrant's Post-Effective Amendment No.
     2 to Registration Statement No. 333-79311, is incorporated herein by
     reference.

1.4  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 12 additional subaccounts within the separate account, filed
     electronically as Exhibit 1.3 to Registrant's Post-Effective Amendment No.
     3 to Registration Statement No. 333-79311, is incorporated herein by
     reference.

1.5  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 69 additional subaccounts within the separate account, filed
     electronically as Exhibit 1.5 to Registrant's Post-Effective Amendment No.
     6 to Registration Statement No. 333-79311, is incorporated herein by
     reference.

1.6  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 112 additional subaccounts within the separate account, dated
     Feb. 11, 2002, filed electronically as Exhibit 1.6 to Registrant's
     Post-Effective Amendment No. 8 to Registration Statement No. 333-79311, is
     incorporated herein by reference.

1.7  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 3 additional subaccounts within the separate account, dated
     Feb. 28, 2002, filed electronically as Exhibit 1.7 to Registrant's
     Post-Effective Amendment No. 10 to Registration Statement No. 333-79311, is
     incorporated herein by reference.

1.8  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 8 additional subaccounts within the separate account, dated
     January 6, 2004, filed electronically as Exhibit 1.8 to Registrant's
     Post-Effective Amendment No. 21 to Registration Statement No. 333-79311,
     filed on or about Jan. 23, 2004, is incorporated by reference.

1.9  Resolution of the Board of Directors of IDS Life Insurance Company
     establishing 6 additional subaccounts within the separate account, dated
     August 12, 2004 filed electronically as Exhibit 1.9 to Post-Effective
     Amendment No. 32 to Registration Statement No. 333-79311 is incorporated by
     reference.

1.10 Resolution of the Board of Directors of IDS Life Insurance Company
     establishing an additional subaccount within the separate account, dated
     April 27, 2005 filed electronically as Exhibit 1.10 to Post-Effective
     Amendment No. 32 to Registration Statement No. 333-79311 is incorporated by
     reference.

1.11 Resolution of the Board of Directors establishing 18 additional subaccounts
     within the separate accounts dated April 12, 2006 filed electronically as
     Exhibit 1.11 to Registrant's Post-Effective Amendment No. 39 to
     Registration Statement No. 333-79311 is incorporated by reference.



1.12 Unanimous Written Consent of the Board of Directors In Lieu of a Meeting
     for IDS Life Insurance Company, adopted December 8, 2006 for the
     Re-designation of the Separate Accounts to Reflect Entity Consolidation and
     Rebranding filed electronically as Exhibit 27(a)(6) to Post-Effective
     Amendment No. 28 to Registration Statement No. 333-69777 is incorporated by
     reference.

2.   Not applicable.

3.   Form of Principal Underwriter Agreement for RiverSource Life Insurance
     Company Variable Annuities and Variable Life Insurance filed electronically
     as Exhibit 3.1 to the Initial Registration Statement on Form N-4 for
     RiverSource Variable Annuity Account (previously American Enterprise
     Variable Annuity Account), RiverSource Signature(SM) Select Variable
     Annuity and RiverSource Signature(SM) Variable Annuity, on or about Jan. 2,
     2007, is incorporated by reference.

4.1  Form of Deferred Annuity Contract for non-qualified contracts (form 31043)
     filed electronically as Exhibit 4.1 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.2  Form of Deferred Annuity Contract for tax qualified contracts (form 31044)
     filed electronically as Exhibit 4.2 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.3  Form of Deferred Annuity Contract for IRA contracts (form 31045-IRA) filed
     electronically as Exhibit 4.3 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.4  Form of Deferred Annuity Contract for non-qualified contracts (form 31046)
     filed electronically as Exhibit 4.4 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.5  Form of Deferred Annuity Contract for tax qualified contracts (form 31047)
     filed electronically as Exhibit 4.5 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.6  Form of Deferred Annuity Contract for IRA contracts (form 31048-IRA) filed
     electronically as Exhibit 4.6 to Registrant's Initial Registration
     Statement No. 333-79311, filed on or about May 26, 1999, is incorporated
     herein by reference.

4.7  Form of TSA Endorsement (form 31049), filed electronically as Exhibit 4.7
     to Pre-Effective Amendment No. 1 to Registration Statement No. 333-79311
     filed on or about Aug. 10, 1999 is incorporated herein by reference.

4.8  Form of Maximum Anniversary Value Death Benefit Rider, filed electronically
     as Exhibit 4.8 to Post-Effective Amendment No. 4 to Registration Statement
     No. 333-79311, is incorporated herein by reference.



4.9  Form of Enhanced Earnings Death Benefit Rider, filed electronically as
     Exhibit 4.9 to Post-Effective Amendment No. 4 to Registration Statement No.
     333-79311, is incorporated herein by reference.

4.10 Form of Enhanced Earnings Plus Death Benefit Rider, filed electronically as
     Exhibit 4.10 to Post-Effective Amendment No. 4 to Registration Statement
     No. 333-79311, is incorporated herein by reference.

4.11 Form of Traditional IRA or SEP-IRA Annuity Endorsement (form 131061) filed
     electronically as Exhibit 4.11 to Post-Effective Amendment No. 14 to
     Registration Statement No. 333-79311, is incorporated herein by reference.

4.12 Form of Roth IRA Annuity Endorsement (form 131062) filed electronically as
     Exhibit 4.12 to Post-Effective Amendment No. 14 to Registration Statement
     No. 333-79311, is incorporated herein by reference.

4.13 Form of SIMPLE IRA Annuity Endorsement (form 131063) filed electronically
     as Exhibit 4.13 to Post-Effective Amendment No. 14 to Registration
     Statement No. 333-79311, is incorporated herein by reference.

4.14 Form of Deferred Annuity Contract for non-qualified contracts (form 131041)
     filed electronically as Exhibit 4.14 to Post-Effective Amendment No. 14 to
     Registration Statement No. 333-79311, is incorporated herein by reference.

4.15 Form of Deferred Annuity Contract for Retirement Advisor Advantage Plus
     (form 1043 A) filed electronically as Exhibit 4.15 to Post-Effective
     Amendment No. 21 to Registration Statement No. 333-79311, filed on or about
     Jan. 23, 2004, is incorporated by reference.

4.16 Form of Deferred Annuity Contract for Retirement Advisor Select Plus (form
     131041 A) filed electronically as Exhibit 4.16 to Post-Effective Amendment
     No. 21 to Registration Statement No. 333-79311, filed on or about Jan. 23,
     2004, is incorporated by reference.

4.17 Form of Deferred Annuity Contract for RiverSource Retirement Advisor 4
     Advantage Variable Annuity (form 131101), filed electronically as Exhibit
     4.17 to Post-Effective Amendment No. 40 to Registration Statement No.
     333-79311, filed on or about June 5, 2006, is incorporated by reference.

4.18 Form of Deferred Annuity Contract for RiverSource Retirement Advisor 4
     Select Variable Annuity (form 131102), filed electronically as Exhibit 4.18
     to Post-Effective Amendment No. 40 to Registration Statement No. 333-79311,
     filed on or about June 5, 2006, is incorporated by reference.

4.19 Form of Deferred Annuity Contract for RiverSource Retirement Advisor 4
     Access Variable Annuity (form 131103), filed electronically as Exhibit 4.19
     to Post-Effective Amendment No. 40 to Registration Statement No. 333-79311,
     filed on or about June 5, 2006, is incorporated by reference.

4.20 Form of TSA Endorsement (form 131068), filed electronically as Exhibit 4.17
     to Post-Effective Amendment No. 21 to Registration Statement No. 333-79311,
     filed on or about Jan. 23, 2004, is incorporated by reference.

4.21 Form of Return of Purchase Payments Rider (form 131072), filed
     electronically as Exhibit 4.18 to Post-Effective Amendment No. 21 to
     Registration Statement No. 333-79311, filed on or about Jan. 23, 2004, is
     incorporated by reference.



4.22 Form of Maximum Anniversary Value Death Benefit Rider (form 131031), filed
     electronically as Exhibit 4.19 to Post-Effective Amendment No. 21 to
     Registration Statement No. 333-79311, filed on or about Jan. 23, 2004, is
     incorporated by reference.

4.23 Form of 5-Year Maximum Anniversary Value Death Benefit Rider (form 131071),
     filed electronically as Exhibit 4.20 to Post-Effective Amendment No. 21 to
     Registration Statement No. 333-79311, filed on or about Jan. 23, 2004, is
     incorporated by reference.

4.24 Form of Enhanced Earnings Death Benefit Rider (form 131032 A), filed
     electronically as Exhibit 4.21 to Post-Effective Amendment No. 21 to
     Registration Statement No. 333-79311, filed on or about Jan. 23, 2004, is
     incorporated by reference.

4.25 Form of Enhanced Earnings Plus Death Benefit Rider (form 131033 A), filed
     electronically as Exhibit 4.22 to Post-Effective Amendment No. 21 to
     Registration Statement No. 333-79311, filed on or about Jan. 23, 2004, is
     incorporated by reference.

4.26 Form of 401 (a) Annuity Endorsement (form 131069), filed electronically as
     Exhibit 4.23 to Post-Effective Amendment No. 21 to Registration Statement
     No. 333-79311, filed on or about Jan. 23, 2004, is incorporated by
     reference.

4.27 Form of Guarantee Period Accounts Rider filed electronically as Exhibit
     4.24 to Post-Effective Amendment No. 25 to Registration Statement No.
     333-79311, filed on or about June 2, 2004, is incorporated by reference.

4.28 Form of Guaranteed Minimum Withdrawal Benefit Rider (form 131034) filed
     electronically as Exhibit 4.25 to Post-Effective Amendment No. 29 to
     Registration Statement No. 333-79311, filed on or about Oct. 21, 2004, is
     incorporated by reference.

4.29 Form of Guaranteed Minimum Accumulation Benefit Rider (GMAB) (form 131035)
     filed electronically as Exhibit 4.29 to Registrant's Post-Effective
     Amendment No. 39 to Registration Statement No. 333-79311 is incorporated by
     reference.

4.30 Form of Portfolio Navigator Model Portfolio Rider (form 131070C) filed
     electronically as Exhibit 4.30 to Registrant's Post-Effective Amendment No.
     39 to Registration Statement No. 333-79311 is incorporated by reference.

4.31 Form of Guaranteed Minimum Lifetime Withdrawal Benefit Rider (Withdrawal
     Benefit for Life), filed electronically as Exhibit 4.31 to Post-Effective
     Amendment No. 40 to Registration Statement No. 333-79311, filed on or about
     June 5, 2006, is incorporated by reference.

4.32 Copy of Company name change endorsement (form 131115) for RiverSource Life
     Insurance Company, filed electronically as Exhibit 4.32 to Registrant's
     Post-Effective Amendment No. 41 to Registration Statement No. 333-79311
     filed on or about Jan. 2, 2007, is incorporated by reference.

4.33 Form of SecureSource Joint Life rider filed electronically as Exhibit 4.33
     to Registrant's Post-Effective Amendment No. 44 to Registration Statement



     No. 333-79311 is incorporated herein by reference.

4.34 Form of SecureSource Single Life rider filed electronically as Exhibit 4.34
     to Registrant's Post-Effective Amendment No. 44 to Registration Statement
     No. 333-79311 is incorporated herein by reference.

4.35 Form of Guaranteed Minimum Withdrawal Benefit Rider (form 131034-E) filed
     electronically as Exhibit 4.35 to Registrant's Post-Effective Amendment No.
     47 to Registration Statement No. 333-79311 is incorporated herein by
     reference.

4.36 Form of Guaranteed Lifetime Withdrawal Benefit Rider Joint Life
     SecureSource(R) Flex Rider (Form 131184-JT) filed electronically as Exhibit
     4.36 to Registrant's Post-Effective Amendment No. 54 to Registration
     Statement No. 333-79311 is incorporated herein by reference.

4.37 Form of Guaranteed Lifetime Withdrawal Benefit Rider Single Life
     SecureSource(R) Flex Rider (Form 139503-SG) filed electronically as Exhibit
     4.37 to Registrant's Post-Effective Amendment No. 54 to Registration
     Statement No. 333-79311 is incorporated herein by reference.

5.   Form of Variable Annuity Application (form 31063), filed electronically as
     Exhibit 5 to Pre-Effective Amendment No. 1 to Registration Statement No.
     333-79311 filed on or about Aug. 10, 1999 is incorporated herein by
     reference.

6.1  Certificate of Incorporation of IDS Life dated July 24, 1957, filed
     electronically as Exhibit 6.1 to Registrant's Initial Registration
     Statement No. 33-62407 is incorporated herein by reference.

6.2  Copy of Certificate of Amendment of Certificate of Incorporation of IDS
     Life Insurance Company dated June 22, 2006, filed electronically as Exhibit
     27(f)(1) to Post-Effective Amendment No. 22 to Registration Statement No.
     333-44644 is incorporated by reference.

6.3  Copy of Amended and Restated By-Laws of RiverSource Life Insurance Company
     filed electronically as Exhibit 27(f)(2) to Post-Effective Amendment No. 22
     to Registration Statement No. 333-44644 is incorporated by reference.

7.   Not applicable.

8.1  Copy of Amended and Restated Participation Agreement dated April 17, 2006,
     by and among AIM Variable Insurance Funds, AIM Distributors, Inc. American
     Enterprise Life Insurance Company, American Partners Life Insurance
     Company, IDS Life Insurance Company, and Ameriprise Financial Services,
     Inc. filed electronically as Exhibit 27(h) (1) to Post-Effective Amendment
     No. 28 to Registration Statement No. 333-69777 is incorporated herein by
     reference.

8.2  Copy of Amended and Restated Participation Agreement dated August 1, 2006,
     among American Enterprise Life Insurance Company, IDS Life Insurance
     Company, Ameriprise Financial Services, Inc., AllianceBernstein L.P. and
     AllianceBernstein Investments, Inc. filed electronically as Exhibit 27(h)
     (20) to Post-Effective Amendment No. 28 to Registration Statement No.



     333-69777is incorporated herein by reference.

8.3  Copy of Amended and Restated Fund Participation Agreement dated June 1,
     2006, by and among American Centurion Life Assurance Company, American
     Enterprise Life Insurance Company, American Partners Life Insurance
     Company, IDS Life Insurance Company, IDS Life Insurance Company of New
     York, Ameriprise Financial Services, Inc. and American Century Investment
     Services, Inc. filed electronically as Exhibit 27(h)(3) to Post-Effective
     Amendment No. 22 to Registration Statement No. 333-44644 is incorporated
     herein by reference.

8.4  Copy of Amended and Restated Participation Agreement dated June 19, 2006,
     by and among Calvert Variable Series, Inc., Calvert Asset Management
     Company, Inc., Calvert Distributors, Inc. and IDS Life Insurance Company
     filed electronically as Exhibit 27(h)(4) to Post-Effective Amendment No. 28
     to Registration Statement No. 333-69777 is incorporated herein by
     reference.

8.5  Copy of Fund Participation Agreement dated May 1, 2006 among American
     Enterprise Life Insurance Company, IDS Life Insurance Company, Columbia
     Funds Variable Insurance Trust I, Columbia Management Advisors, LLC and
     Columbia Management Distributors, Inc. filed electronically as Exhibit
     27(h) (22) to Post-Effective Amendment No. 28 to Registration Statement No.
     333-69777 is incorporated herein by reference.

8.6  Copy of Amended and Restated Participation Agreement dated May 1, 2006, by
     and among American Enterprise Life Insurance Company, American Partners
     Life Insurance Company, IDS Life Insurance Company, Credit Suisse Trust,
     Credit Suisse Asset Management, LLC. and Credit Suisse Asset Management
     Securities, Inc. filed electronically as Exhibit 8.6 to Post-Effective
     Amendment No. 41 to Registration Statement No. 333-79311 is incorporated
     herein by reference.

8.7  Copy of Fund Participation Agreement dated May 1, 2006, by and among
     American Enterprise Life Insurance Company, IDS Life Insurance Company, The
     Dreyfus Corporation, Dreyfus Variable Investment Fund, and Dreyfus
     Investment Portfolios filed electronically as Exhibit 8.7 to Post-Effective
     Amendment No. 41 to Registration Statement No. 333-79311 is incorporated
     herein by reference.

8.8  Copy of Participation Agreement dated May 1, 2006, among Eaton Vance
     Variable Trust, Eaton Vance Distributors, Inc. and IDS Life Insurance
     Company filed electronically as Exhibit 8.8 to Post-Effective Amendment No.
     41 to Registration Statement No. 333-79311 is incorporated herein by
     reference.

8.9  Copy of Evergreen Variable Annuity Trust Amended and Restated Participation
     Agreement dated June 1, 2006, by and among American Enterprise Life
     Insurance Company, IDS Life Insurance Company and Evergreen Variable
     Annuity Trust filed electronically as Exhibit 27(h) (6) to Post-Effective
     Amendment No. 28 to Registration Statement No. 333-69777 is incorporated
     herein by reference.

8.10 Copy of Amended and Restated Fund Participation Agreement dated January 1,
     2007,among Variable Insurance Products Funds, Fidelity Distributors
     Corporation and RiverSource Life Insurance Co. of New York filed



     electronically as Exhibit 8.16 to RiverSource of New York Variable Annuity
     Account 2's Post-Effective Amendment No. 3 to Registration Statement No.
     333-139764 on or about April 24, 2008 is incorporated by reference herein.

8.11 Copy of Amended and Restated Participation Agreement by and between
     Franklin Templeton Variable Insurance Products Trust, Franklin/Templeton
     Distributors, Inc., American Centurion Life Assurance Company, American
     Enterprise Life Insurance Company, IDS Life Insurance Company, IDS Life
     Insurance Company of New York, Ameriprise Financial Services, Inc.
     (formerly American Express Financial Advisors Inc.), dated August 1, 2005
     filed electronically as Exhibit 8.7 to Registrant's Post-Effective
     Amendment No. 39 to Registration Statement No. 333-79311 is incorporated by
     reference.

8.12 Copy of Amended and Restated Participation Agreement dated June 9, 2006, by
     and among American Enterprise Life Insurance Company, IDS Life Insurance
     Company, Goldman Sachs Variable Insurance Trust and Goldman, Sachs & Co.
     filed electronically as Exhibit 27(h)(24) to Post Effective Amendment No.28
     to Registration Statement No. 333-69777 is incorporated herein by
     reference.

8.13 Copy of Janus Aspen Series Amended and Restated Fund Participation
     Agreement dated September 1, 2006, by and among American Enterprise Life
     Insurance Company, American Partners Life Insurance Company, IDS Life
     Insurance Company and Janus Aspen Series filed electronically as Exhibit
     27(h)(12) to Post-Effective Amendment No. 28 to Registration Statement No.
     333-69777 is incorporated herein by reference.

8.14 Copy of Amended and Restated Participation Agreement by and among IDS Life
     Insurance Company, American Enterprise Life Insurance Company, Ameriprise
     Financial Services, Inc., Lazard Asset Management Securities LLC, and
     Lazard Retirement Series, Inc., dated Oct. 16, 2006, filed electronically
     as Exhibit 8.14 to Post-Effective Amendment No. 42 to Registration
     Statement No. 333-79311 is incorporated by reference.

8.15 Copy of Fund Participation Agreement dated Jan. 1, 2007, by and among
     RiverSource Life Insurance Company, RiverSource Distributors, Inc. and
     Lazard Asset Management Securities LLC and Lazard Retirement Series, Inc.
     filed electronically as Exhibit 8.15 to Post-Effective Amendment No. 42 to
     Registration Statement No. 333-79311 is incorporated by reference.

8.16 Copy of Amended and Restated Participation Agreement dated September 1,
     2006, by and among IDS Life Insurance Company, Legg Mason Partners Variable
     Portfolios I, Inc. (formerly Salomon Brothers Variable Series Fund, Inc.),
     Legg Mason Partners Variable Portfolios II, Inc. (formerly Greenwich Street
     Series Fund, formerly Smith Barney Series Fund, formerly Smith Barney
     Shearson Series Fund, formerly Shearson Series Fund), Legg Mason Partners
     Variable Portfolios III, Inc. (formerly Travelers Series Fund Inc.,
     formerly Smith Barney Travelers Series Fund Inc.) and Legg Mason Investor
     Services, LLC filed electronically as Exhibit 8.15 to Post-Effective
     Amendment No. 41 to Registration Statement No. 333-79311 is incorporated
     herein by reference.

8.17 Copy of Participation Agreement Among MFS Variable Insurance Trust,
     American Enterprise Life Insurance Company, IDS Life Insurance Company and
     Massachusetts Financial Services Company, dated June 9, 2006, filed
     electronically as Exhibit 8.17 to Post-Effective Amendment No. 42 to



     Registration Statement No. 333-79311 is incorporated by reference.

8.18 Copy of Fund Participation Agreement dated March 2, 2006, by and between
     Neuberger Berman Advisers Management Trust, Neuberger Berman Management,
     Inc. and IDS Life Insurance Company filed electronically as Exhibit 8.17 to
     Post-Effective Amendment No. 41 to Registration Statement No. 333-79311 is
     incorporated herein by reference.

8.19 Copy of Amended and Restated Fund Participation Agreement dated March 30,
     2007, among Oppenheimer Variable Account funds, Oppenheimer Funds, Inc. and
     RiverSource Life Insurance Company filed electronically as Exhibit 8.4 to
     RiverSource Variable Annuity Account Post-Effective Amendment No. 2 to
     Registration Statement No. 333-139760 on or about April 24, 2008 is
     incorporated by reference herein.

8.20 Copy of Participation Agreement dated March 1, 2006, among IDS Life
     Insurance Company, PIMCO Variable Insurance Trust and Allianz Global
     Investors Distributors LLC filed electronically as Exhibit 8.19 to
     Post-Effective Amendment No. 41 to Registration Statement No. 333-79311 is
     incorporated herein by reference.

8.21 Copy of Amended and Restated Fund Participation Agreement dated September
     1, 2006, among Pioneer Variable Contracts Trust, IDS Life Insurance
     Company, Pioneer Investment Management, Inc., and Pioneer Funds
     Distributor, Inc. filed electronically as Exhibit 27(h)(15) to
     Post-Effective Amendment No. 28 to Registration Statement No. 333-69777 is
     incorporated herein by reference.

8.22 Copy of Amended and Restated Fund Participation Agreement dated Jan. 1,
     2007, among Riversource Life Insurance Company, Putnam Variable Trust and
     Putnam Retail Management Limited Partnership filed electronically as
     Exhibit 8.2 to RiverSource Variable Annuity Account's Post-Effective
     Amendment No. 2 to Registration Statement No. 333-139760 on or about April
     24, 2008 is incorporated by reference herein.

8.23 Copy of Participation Agreement dated January 1, 2007, by and among
     RiverSource Life Insurance Company, RiverSource Life Insurance Co. of New
     York and RiverSource Distributors, Inc. filed electronically as Exhibit
     8.23 to Post-Effective Amendment No. 42 to Registration Statement No.
     333-79311 is incorporated herein by reference.

8.24 Copy of Participation Agreement by and among Royce Capital Fund and Royce &
     Associates, Inc. and RiverSource Life Insurance Company, dated Jan. 1,
     2007, filed electronically as Exhibit 8.24 to Post-Effective Amendment No.
     42 to Registration Statement No. 333-79311 is incorporated by reference.

8.25 Copy of Amended and Restated Participation Agreement dated May 1, 2006,
     among The Universal Institutional Funds, Inc., Morgan Stanley Investment
     Management Inc., Morgan Stanley Distribution, Inc., American Enterprise
     Life Insurance Company and IDS Life Insurance Company filed electronically
     as Exhibit 8.24 to Post-Effective Amendment No. 41 to Registration
     Statement No. 333-79311 is incorporated herein by reference.

8.26 Copy of Amended and Restated Participation Agreement dated October 12,
     2006, by and among Third Avenue Variable Series Trust, Third Avenue
     Management LLC, American Enterprise Life Insurance Company and IDS Life



     Insurance Company filed electronically as Exhibit 27(h)(18) to
     Post-Effective Amendment No. 28 to Registration Statement No. 333-69777 is
     incorporated herein by reference.

8.27 Copy of Amended and Restated Participation Agreement dated May 1, 2006,
     among Van Kampen Life Investment Trust, Van Kampen Funds Inc., Van Kampen
     Asset Management, American Enterprise Life Insurance Company and IDS Life
     Insurance Company filed electronically as Exhibit 8.26 to Post-Effective
     Amendment No. 41 to Registration Statement No. 333-79311 is incorporated
     herein by reference.

8.28 Copy of Fund Participation Agreement dated April 2, 2007, RiverSource Life
     Insurance Company, Wanger Advisors Trust, Columbia Wanger Asset Management,
     L.P. and Columbia Management Distributors, Inc. filed electronically as
     Exhibit 8.11 to RiverSource Variable Annuity Account Post-Effective
     Amendment No. 2 to Registration Statement No. 333-139760 on or about April
     24, 2008 is incorporated by reference herein.

8.29 Copy of Participation Agreement by and among Wells Fargo Variable Trust and
     RiverSource Life Insurance Company and Wells Fargo Funds Distributors, LLC
     dated Jan. 1, 2007, filed electronically as Exhibit 8.29 to Post-Effective
     Amendment No. 42 to Registration Statement No. 333-79311 is incorporated by
     reference.

9.   Opinion of counsel and consent to its use as the legality of the securities
     being registered will be field by amendment.

10.6 Consent of Independent Registered Public Accounting Firm for RiverSource
     Retirement Advisor 4 Advantage Variable Annuity/ RiverSource Retirement
     Advisor 4 Select Variable Annuity/RiverSource Retirement Advisor 4 Access
     Variable Annuity is filed electronically herewith.

11.  None

12.  Not applicable.

13.  Power of Attorney dated Oct.22, 2008 filed electronically as Exhibit 13 to
     Post-Effective Amendment No. 53, to Registration Statement No. 333-79311
     filed on or about April 24, 2009, is incorporated by reference.

14.  Not applicable.

Item 25.


Item 25. Directors and Officers of the Depositor RiverSource Life Insurance
Company



Name                               Principal Business Address*   Position and Offices With Depositor
----                               ---------------------------   -----------------------------------
                                                           
Lynn Abbott                                                      Vice President - National
                                                                 Accounts and Fund Management

Gumer C. Alvero                                                  Director and Executive
                                                                 Vice President - Annuities

Timothy V. Bechtold                                              Director and President

Kent M. Bergene                                                  Vice President - Affiliated
                                                                 Investments

Walter Stanley Berman                                            Vice President and Treasurer

Richard N. Bush                                                  Senior Vice President -
                                                                 Corporate Tax

Charles R. Caswell                                               Reinsurance Officer

James L Hamalainen                                               Vice President - Investments

Michelle Marie Keeley                                            Vice President - Investments

Timothy J. Masek                                                 Vice President - Investments

Brian Joseph McGrane                                             Director, Executive Vice
                                                                 President and Chief Financial
                                                                 Officer

Thomas W. Murphy                                                 Vice President - Investments

Kevin Palmer                                                     Director, Vice President and
                                                                 Chief Actuary

Bridget Mary Sperl                                               Director, Executive Vice
                                                                 President - Client Service

David Kent Stewart                                               Vice President and Controller

William Frederick "Ted" Truscott                                 Director

John Robert Woerner                                              Director


*    The business address is 70100 Amerprise Financial Center, Minneapolis, MN
     55474.





Item 26.


Item 26. Persons Controlled by or Under Common Control with the Depositor or
Registrant

The following list includes the names of major subsidiaries of Ameriprise
Financial, Inc.



                                                                           Jurisdiction of
Name of Subsidiary                                                          Incorporation
------------------                                                         ---------------
                                                                        
Advisory Capital Strategies Group Inc.                                     Minnesota
AEXP Affordable Housing LLC                                                Delaware
American Enterprise Investment Services Inc.                               Minnesota
American Express Property Casualty Insurance Agency of Pennsylvania,Inc.   Pennsylvania
Ameriprise Advisor Services, Inc.                                          Michigan
Ameriprise Auto & Home Insurance Agency, Inc.                              Wisconsin
Ameriprise Bank, FSB                                                       USA
Ameriprise Captive Insurance Company                                       Vermont
Ameriprise Capital Trusts I-IV                                             Delaware
Ameriprise Certificate Company                                             Delaware
Ameriprise Financial Services,Inc.                                         Delaware
Ameriprise Holdings, Inc.                                                  Delaware
Ameriprise India Private Ltd.                                              India
Ameriprise Insurance Agency of Massachusetts, Inc.                         Massachusetts
Ameriprise Insurance Agency                                                Wisconsin
Ameriprise Trust Company                                                   Minnesota
AMPF Holding Corporation                                                   Michigan
AMPF Property Corporation                                                  Michigan
AMPF Realty Corporation                                                    Michigan
Brecek & Young Advisors, Inc.                                              California
Brecek & Young Financial Group Insurance Agency of Texas, Inc.             Texas
Brecek & Young Financial Services Group of Montana, Inc.                   Montana
Boston Equity General Partner LLC                                          Delaware
4230 W. Green Oaks, Inc.                                                   Michigan
IDS Capital Holdings Inc.                                                  Minnesota
IDS Futures Corporation                                                    Minnesota
IDS Management Corporation                                                 Minnesota
IDS Property Casualty Insurance Company                                    Wisconsin
Investors Syndicate Development Corporation                                Nevada
J. & W. Seligman & Co. Incorporated                                        New York
Kenwood Capital Management LLC (47.7% owned)                               Delaware
Realty Assets Inc.                                                         Nebraska
RiverSource CDO Seed Investments, LLC                                      Minnesota
RiverSource Distributors,Inc.                                              Delaware
RiverSource Fund Distributors, Inc.                                        Delaware
RiverSource Investments,LLC                                                Minnesota
RiverSource Life Insurance Company                                         Minnesota
RiverSource Life Insurance Co. of New York                                 New York
RiverSource REO 1, LLC                                                     Minnesota
RiverSource Service Corporation                                            Minnesota
RiverSource Services, Inc.                                                 Delaware
RiverSource Tax Advantaged Investments, Inc.                               Delaware
Securities America Advisors,Inc.                                           Nebraska
Securities America Financial Corporation                                   Nebraska
Securities America, Inc.                                                   Nebraska
Seligman Asia, Inc.                                                        Delaware
Seligman Focus Partners LLC                                                Delaware




                                                                        
Seligman Health Partners LLC                                               Delaware
Seligman Health Plus Partners LLC                                          Delaware
Seligman Partners LLC                                                      Delaware
Threadneedle Asset Management Holdings SARL                                England



Item 27. Number of Contract owners

     As of Dec. 31, 2009 there were 206,049 non-qualified contract owners and
     437,152 qualified contract owners.

Item 28. Indemnification

The amended and restated By-Laws of the depositor provide that the depositor
will indemnify, to the fullest extent now or hereafter provided for or permitted
by law, each person involved in, or made or threatened to be made a party to,
any action, suit, claim or proceeding, whether civil or criminal, including any
investigative, administrative, legislative, or other proceeding, and including
any action by or in the right of the depositor or any other corporation, or any
partnership, joint venture, trust, employee benefit plan, or other enterprise
(any such entity, other than the depositor, being hereinafter referred to as an
"Enterprise"), and including appeals therein (any such action or process being
hereinafter referred to as a "Proceeding"), by reason of the fact that such
person, such person's testator or intestate (i) is or was a director or officer
of the depositor, or (ii) is or was serving, at the request of the depositor, as
a director, officer, or in any other capacity, or any other Enterprise, against
any and all judgments, amounts paid in settlement, and expenses, including
attorney's fees, actually and reasonably incurred as a result of or in
connection with any Proceeding, except as provided below.

No indemnification will be made to or on behalf of any such person if a judgment
or other final adjudication adverse to such person establishes that such
person's acts were committed in bad faith or were the result of active and
deliberate dishonesty and were material to the cause of action so adjudicated,
or that such person personally gained in fact a financial profit or other
advantage to which such person was not legally entitled. In addition, no
indemnification will be made with respect to any Proceeding initiated by any
such person against the depositor, or a director or officer of the depositor,
other than to enforce the terms of this indemnification provision, unless such
Proceeding was authorized by the Board of Directors of the depositor. Further,
no indemnification will be made with respect to any settlement or compromise of
any Proceeding unless and until the depositor has consented to such settlement
or compromise.

The depositor may, from time to time, with the approval of the Board of
Directors, and to the extent authorized, grant rights to indemnification, and to
the advancement of expenses, to any employee or agent of the depositor or to any
person serving at the request of the depositor as a director or officer, or in
any other capacity, of any other Enterprise, to the fullest extent of the
provisions with respect to the indemnification and advancement of expenses of
directors and officers of the depositor.

Insofar as indemnification for liability arising under the Securities Act of
1933 (the "Act") may be permitted to directors, officers and controlling persons
of the depositor or the registrant pursuant to the foregoing provisions, or
otherwise, the registrant has been advised that in the opinion of the Securities
and Exchange Commission such indemnification is against public policy as
expressed in the Act and is, therefore, unenforceable. In the event that a claim



for indemnification against such liabilities (other than the payment by the
registrant of expenses incurred or paid by a director, officer or controlling
person of the registrant in the successful defense of any action, suit or
proceeding) is asserted by such director, officer or controlling person in
connection with the securities being registered, the registrant will, unless in
the opinion of its counsel the matter has been settled by controlling precedent,
submit to a court of appropriate jurisdiction the question whether such
indemnification by it is against public policy as expressed in the Act and will
be governed by the final adjudication of such issue.

Item 29. Principal Underwriter RiverSource Distributors Inc.


ITEM 29. PRINCIPAL UNDERWRITERS.

(a) RiverSource Distributors Inc. acts as principal underwriter, depositor or
sponsor for:

RiverSource Variable Annuity Account ; RiverSource Account F; RiverSource
Variable Annuity Fund A, RiverSource Variable Annuity Fund B, RiverSource
Variable Account 10; RiverSource Account MGA; RiverSource MVA Account;
RiverSource Variable Life Separate Account; RiverSource Variable Life Account;
RiverSource Life Insurance Company; RiverSource of New York Variable Annuity
Account ; RiverSource of New York Account 8; RiverSource of New York Variable
Annuity Account; RiverSource Bond Series, Inc.; RiverSource California
Tax-Exempt Trust; RiverSource Dimensions Series, Inc.; RiverSource Diversified
Income Series, Inc.; RiverSource Equity Series, Inc.; RiverSource Global Series,
Inc.; RiverSource Government Income Series, Inc.; RiverSource High Yield Income
Series, Inc.; RiverSource Income Series, Inc.; RiverSource International
Managers Series, Inc.; RiverSource International Series, Inc.; RiverSource
Investment Series, Inc.; RiverSource Large Cap Series, Inc.; RiverSource
Managers Series, Inc.; RiverSource Market Advantage Series, Inc.; RiverSource
Money Market Series, Inc.; RiverSource Sector Series, Inc.; RiverSource Selected
Series, Inc.; RiverSource Series Trust; RiverSource Short Term Investments
Series, Inc.; RiverSource Special Tax-Exempt Series Trust; RiverSource Strategic
Allocation Series; Inc., RiverSource Strategy Series, Inc.; RiverSource
Tax-Exempt Income Series, Inc.; RiverSource Tax-Exempt Money Market Series,
Inc.; RiverSource Tax-Exempt Series, Inc.; RiverSource Variable Series Trust.

(b) As to each director, officer or partner of the principal underwriter:



Name and Principal Business Address*   Positions and Offices with Underwriter
------------------------------------   --------------------------------------------------------
                                    
Gumer C. Alvero                        Director and Vice President
Patrick Thomas Bannigan                Director and Vice President
Timothy V. Bechtold                    Director and Vice President
Paul J. Dolan                          Chief Operating Officer and Chief Administrative Officer
Jeffrey P. Fox                         Chief Financial Officer
Bimal Gandhi                           Senior Vice President - Strategic Transformation
Jeffrey McGregor                       President
Thomas R. Moore                        Secretary
Scott Roane Plummer                    Chief Counsel
Julie A. Ruether                       Chief Compliance Officer
William Frederick "Ted" Truscott       Chairman of the Board and Chief Executive Officer


*    Business address is: 50611 Ameriprise Financial Center, Minneapolis, MN
     55474


(c)  RiverSource Distributors Inc., the principal underwriter during
     Registrant's last fiscal year, was paid the following commissions:



NAME OF             NET UNDERWRITING
PRINCIPAL             DISCOUNTS AND    COMPENSATION ON    BROKERAGE
UNDERWRITER            COMMISSIONS        REDEMPTION     COMMISSIONS   COMPENSATION
------------        ----------------   ---------------   -----------   ------------
                                                           
RiverSource
Distributors,Inc.     $383,542,107           None            None          None


Item 30. Location of Accounts and Records

     RiverSource Life Insurance Company
     70100 Ameriprise Financial Center
     Minneapolis, MN 55474

Item 31. Management Services

     Not applicable.

Item 32. Undertakings

(a)  Registrant undertakes to file a post-effective amendment to this
     registration statement as frequently as is necessary to ensure that the
     audited financial statements in the registration statement are never more
     than 16 months old for so long as payments under the variable annuity
     contracts may be accepted.

(b)  Registrant undertakes to include either (1) as part of any application to
     purchase a contract offered by the prospectus, a space that an applicant
     can check to request a Statement of Additional Information, or (2) a post
     card or similar written communication affixed to or included in the
     prospectus that the applicant can remove to send for a Statement of
     Additional Information.



(c)  Registrant undertakes to deliver any Statement of Additional Information
     and any financial statements required to be made available under this Form
     promptly upon written or oral request.

(d)  Registrant represents that it is relying upon the no-action assurance given
     to the American Council of Life Insurance (pub. avail. Nov. 28, 1988).
     Further, Registrant represents that it has complied with the provisions of
     paragraphs (1)-(4) of that no-action letter.

(e)  The sponsoring insurance company represents that the fees and charges
     deducted under the contract, in the aggregate, are reasonable in relation
     to the services rendered, the expenses expected to be incurred, and the
     risks assumed by the insurance company.



                                   SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of
1940, RiverSource Life Insurance Company, on behalf of the Registrant has caused
this Amendment to its Registration Statement to be signed on its behalf by the
undersigned, thereunto duly authorized in the City of Minneapolis, and State of
Minnesota, on the 5th day of February, 2010.

                                        RIVERSOURCE VARIABLE ACCOUNT 10
                                        (Registrant)

                                        By RiverSource Life Insurance Company
                                           (Sponsor)


                                        By /s/ Timothy V. Bechtold*
                                           -------------------------------------
                                           Timothy V. Bechtold
                                           President

As required by the Securities Act of 1933, Amendment to this Registration
Statement has been signed by the following persons in the capacities indicated
on the 5th day of February, 2010.



Signature                                                 Title
---------                                ---------------------------------------
                                      


/s/ Gumer C. Alvero*                     Director and Executive Vice
--------------------------------------   President - Annuities
Gumer C. Alvero


/s/ Timothy V. Bechtold*                 Director, President and Chief Executive
--------------------------------------   Officer
Timothy V. Bechtold


/s/ Richard N. Bush*                     Senior Vice President - Corporate Tax
--------------------------------------
Richard N. Bush


/s/ Brian J. McGrane*                    Director, Executive Vice President and
--------------------------------------   Chief Financial Officer
Brian J. McGrane


/s/ Kevin E. Palmer*                     Director, Vice President and Chief
--------------------------------------   Actuary
Kevin E. Palmer




                                      


/s/ Bridget M. Sperl*                    Executive Vice President -
--------------------------------------   Client Services
Bridget M. Sperl


/s/ David K. Stewart*                    Vice President and Controller
--------------------------------------   (Principal Accounting Officer)
David K. Stewart


/s/ William F. "Ted" Truscott*           Director
--------------------------------------
William F. "Ted" Truscott


/s/ John R. Woerner*                     Director
--------------------------------------
John R. Woerner



*    Signed pursuant to Power of Attorney dated Oct.22, 2008 filed
     electronically as Exhibit 13 to Post-Effective Amendment No. 53, to
     Registration Statement No. 333-79311 filed on or about April 24, 2009,
     incorporated by reference, by:


/s/ Rodney J. Vessels
--------------------------------------
Rodney J. Vessels
Assistant General Counsel and
Assistant Secretary



      CONTENTS OF POST-EFFECTIVE AMENDMENT NO. 55 TO REGISTRATION STATEMENT

This Post-Effective Amendment is comprised of the following papers and
documents:

The Cover Page.

Part A.

The prospectus for RiverSource Retirement Advisor 4 Advantage Variable Annuity,
RiverSource Retirement Advisor 4 Select Variable Annuity and RiverSource
Retirement Advisor 4 Access Variable Annuity

Part B.

The Combined Statement of Additional Information and Financial Statements Part
C.

     Other Information.

     The signatures.

     Exhibits.



Exhibit Index

9.   Opinion of counsel and consent to its use as to the legality of the
     securities being registered.

EX-99.9

February 5, 2010

RiverSource Life Insurance Company
70100 Ameriprise Financial Center
Minneapolis, MN 55474

Re:  RiverSource Variable Account 10

     RiverSource Retirement Advisor 4 Advantage Variable Annuity
     RiverSource Retirement Advisor 4 Select Variable Annuity
     RiverSource Retirement Advisor 4 Access Variable Annuity
     File Nos. 333-79311/811-07355

Ladies and Gentlemen:

I am familiar with the establishment of the RiverSource Variable Account 10
("Account"), which is a separate account of RiverSource Life Insurance Company
("Company") established by the Company's Board of Directors according to
applicable insurance law. I also am familiar with the above-referenced
Registration Statement filed by the Company on behalf of the Account with the
Securities and Exchange Commission.

I have made such examination of law and examined such documents and records as
in my judgment are necessary and appropriate to enable me to give the following
opinion:

1. The Company is duly incorporated, validly existing and in good standing under
applicable state law and is duly licensed or qualified to do business in each
jurisdiction where it transacts business. The Company has all corporate powers
required to carry on its business and to issue the contracts.

2. The Account is a validly created and existing separate account of the Company
and is duly authorized to issue the securities registered.

3. The contracts issued by the Company, when offered and sold in accordance with
the prospectuses contained in the Registration Statement and in compliance with
applicable law, will be legally issued and represent binding obligations of its
Company in accordance with their terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.


Sincerely,


/s/ Rodney J. Vessels
-------------------------------------
Rodney J. Vessels
Assistant General Counsel and
Assistant Secretary

CORRESP

February 5, 2010

VIA EDGAR

Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
ATTN: Document Control - Edgar

RE: Post-Effective Amendment No. 55 on Form N-4
RiverSource Variable Account 10 ("Registrant")
RiverSource Retirement Advisor 4 Advantage Variable Annuity
RiverSource Retirement Advisor 4 Select Variable Annuity
RiverSource Retirement Advisor 4 Access Variable Annuity
File Nos. 333-79311/811-07355

Dear Commissioners:

On behalf of RiverSource Variable Annuity Account ("Registrant"), RiverSource
Life

Insurance Company ("Company") is filing Post-Effective Amendment No.
55("Amendment No. 55") on Form N-4 pursuant to Rule 485(a) of the Securities Act
of 1933 ("1933 Act").

This Amendment No.55 describes new asset allocation program, Portfolio Navigator
program, which will replace existing Portfolio Navigator asset allocation
program.

Registrant requests selective review in accordance with SEC Release No. IC-13768
(Feb. 15, 1984). This selective review request is made because the new
prospectus and Statement of Additional Information included in this Amendment
No.55 are substantially similar to Registrant's Post-Effective Amendment No.53to
Registration Statement No. 333-139763 filed on or about April 24, 2009.
Amendment No.55 has been marked to show all changes. Registrant does not believe
any problem areas exist that would warrant particular attention.

In this Amendment No. 55, the primary changes to the contract include addition
of the new Portfolio Navigator program.

Registrant intends this filing to serve as a Template Filing for the following
product filings which are all filed under Form N-4 or N-6:





                                                                                            LIFE INSURANCE
PRODUCT NAME                               1933 ACT #   1940 ACT #    REGISTRANT NAME        COMPANY NAME
------------                               ----------   ----------  -------------------   -----------------
                                                                              
RiverSource Retirement Advisor             333-79311    811-07355   RiverSource           RiverSource Life
Variable Annuity(R)                                                 Variable Account 10   Insurance Company
RiverSource Retirement Advisor             333-79311    811-07355   RiverSource           RiverSource Life
Variable Annuity(R) - Band 3                                        Variable Account 10   Insurance Company
RiverSource Retirement Advisor             333-79311    811-07355   RiverSource           RiverSource Life
Advantage(R) Variable Annuity                                       Variable Account 10   Insurance Company
/RiverSource Retirement Advisor Select
(R) Variable Annuity
RiverSource Retirement Advisor             333-79311    811-07355   RiverSource           RiverSource Life
Advantage(R) Plus Variable Annuity/                                 Variable Account 10   Insurance Company
RiverSource Retirement Advisor Select
(R) Plus Variable Annuity
RiverSource Retirement Advisor             333-79311    811-07355   RiverSource           RiverSource Life
Advantage(R) Variable Annuity - Band 3                              Variable Account 10   Insurance Company
RiverSource Retirement Advisor             333-91691    811-07623   RiverSource of New    RiverSource Life
Advantage(R) Variable Annuity                                       York Variable         Insurance Co. of
/RiverSource Retirement Advisor Select                              Annuity Account       New York
(R) Variable Annuity
RiverSource Retirement Advisor             333-91691    811-07623   RiverSource of New    RiverSource Life
Advantage(R) Plus Variable Annuity/                                 York Variable         Insurance Co. of
RiverSource Retirement Advisor Select                               Annuity Account       New York
(R) Plus Variable Annuity
RiverSource Retirement Advisor             333-91691    811-07623   RiverSource of New    RiverSource Life
Variable Annuity(R)                                                 York Variable         Insurance Co. of
                                                                    Annuity Account       New York
RiverSource Retirement Advisor 4           333-91691    811-07623   RiverSource of New    RiverSource Life
Advantage(R) Variable                                               York Variable         Insurance Co. of
Annuity/RiverSource Retirement Advisor                              Annuity Account       New York
4 Select(R) Variable Annuity/RiverSource
Retirement Advisor 4 Access(R) Variable
Annuity
RiverSource(R) AccessChoice Select         333-139759   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Builder Select Variable     333-139762   811-7195    RiverSource           RiverSource Life
Annuity                                                             Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Endeavor Select Variable    333-139763   811-7195    RiverSource           RiverSource Life
Annuity                                                             Variable Annuity      Insurance Company
                                                                    Account




                                                                              
RiverSource(R) Endeavor Select Variable    333-139764   811-07511   RiverSource of New    RiverSource Life
Annuity                                                             York Variable         Insurance Co. of
                                                                    Annuity Account 2     New York
RiverSource(R) FlexChoice Select           333-139763   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Innovations Classic         333-139763   811-7195    RiverSource           RiverSource Life
Select Variable Annuity                                             Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Innovations Select          333-139763   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Signature One Select        333-139762   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
RiverSource(R) Signature Select Variable   333-139760   811-7195    RiverSource           RiverSource Life
Annuity                                                             Variable Annuity      Insurance Company
                                                                    Account
Evergreen  New Solutions Select            333-139763   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
Evergreen PathwaysSM Select Variable       333-139759   811-7195    RiverSource           RiverSource Life
Annuity                                                             Variable Annuity      Insurance Company
                                                                    Account
Wells Fargo Advantage ChoiceSM Select      333-139759   811-7195    RiverSource           RiverSource Life
Variable Annuity                                                    Variable Annuity      Insurance Company
                                                                    Account
Wells Fargo Advantage(R) Select Variable   333-139763   811-7195    RiverSource           RiverSource Life
Annuity                                                             Variable Annuity      Insurance Company
                                                                    Account
RiverSource FlexChoice Select Variable     333-144422   811-07511   RiverSource of New    RiverSource Life
Annuity                                                             York Variable         Insurance Co. of
                                                                    Annuity Account 2     New York
RiverSource Innovations Select             333-139764   811-07511   RiverSource of New    RiverSource Life
Variable Annuity NY                                                 York Variable         Insurance Co. of
                                                                    Annuity Account 2     New York
RiverSource(R) Variable Universal Life     333-69777    811-4298    RiverSource           RiverSource Life
IV /RiverSource(R) Variable Universal                               Variable Life         Insurance Company
Life IV-Estate Series                                               Separate Account
RiverSource(R) Variable Universal Life     333-44644    811-5213    RiverSource of New    RiverSource Life
IV /RiverSource(R) Variable Universal                               York Account 8        Insurance Co. of
Life IV-Estate Series                                                                     New York





                                                                              
RiverSource(R) Variable Universal Life     33-11165     811-4298    RiverSource           RiverSource Life
Insurance                                                           Variable Life         Insurance Company
                                                                    Separate Account
RiverSource(R) Variable Universal Life     33-15290     811-5213    RiverSource of New    RiverSource Life
Insurance                                                           York Account 8        Insurance Co. of
                                                                                          New York
RiverSource(R) Variable Universal Life     333-69777    811-4298    RiverSource           RiverSource Life
III                                                                 Variable Life         Insurance Company
                                                                    Separate Account
RiverSource(R) Variable Universal Life     333-44644    811-5213    RiverSource of New    RiverSource Life
III                                                                 York Account 8        Insurance Co. of
                                                                                          New York
RiverSource Succession Select(R)           33-62457     811-4298    RiverSource           RiverSource Life
Variable Life Insurance                                             Variable Life         Insurance Company
                                                                    Separate Account
RiverSource Succession Select(R)           333-42257    811-5213    RiverSource of New    RiverSource Life
Variable Life Insurance                                             York Account 8        Insurance Co. of
                                                                                          New York
RiverSource(R) Variable Second-To-Die      33-62457     811-4298    RiverSource           RiverSource Life
Life Insurance                                                      Variable Life         Insurance Company
                                                                    Separate Account
RiverSource(R) Variable Second-To-Die      333-42257    811-5213    RiverSource of New    RiverSource Life
Life Insurance                                                      York Account 8        Insurance Co. of
                                                                                          New York



Registrant will submit a request in accordance with Rule 485(b)(1)(vii) under
1933 Act, under separate cover.

If there is anything I can do to expedite review of the enclosed Amendment No.
55 or if you have any questions regarding this filing, please contact me at
(612) 671-2237 or Boba Selimovic at (612) 671-7449.

Sincerely,


/s/ Rodney J. Vessels
-------------------------------------
Rodney J. Vessels
Counsel