December 13, 2007

Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E. (Mail Stop 5-6)
Washington, D.C. 20549

ATTN: Document Control - Edgar

RE:   Post-Effective Amendment No. 46 on Form N-4
      RiverSource Variable Account 10 ("Registrant")
      File Nos. 333-79311 and 811-07355
      RiverSource Retirement Advisor Advantage Plus Variable Annuity
      RiverSource Retirement Advisor Select Plus Variable Annuity

Dear Mr. Cowan:

This letter is in response to Staff's comments received on or about December 4,
2007 for the above-referenced Post-Effective Amendment ("Template Filing") filed
on or about October 15, 2007. Comments and responses for the Template Filing are
outlined below.

COMMENT 1. The disclosure states on the first page that "As long as your
withdrawals in each contract year do not exceed the allowed amount, you will not
be assessed a withdrawal charge." Do you mean surrender charge, which is the
term used on the following page (the terms used should also be consistent with
those used in the fee table)?

RESPONSE: We have changed "withdrawal charge" to "surrender charge."

COMMENT 2. The previous prospectus disclosure indicated that an MVA charge may
be applicable if an excess withdrawal is made. Is the MVA charge no longer
applicable?

RESPONSE: The MVA charge may be applicable if an excess withdrawal is made and
the following sentence is added:

     Market value adjustments, if applicable, will also be made (see the "Market
     Value Adjustment" provision in the prospectus).

COMMENT 3. With respect to the Elective Step Up under the original rider, a
withdrawal taken prior to the third contract anniversary will be considered an
excess withdrawal. Such a withdrawal will be considered an excess withdrawal
subject to the GBA and RBA excess withdrawal processing discussed under the
"Guaranteed Benefit Amount" and "Remaining Benefit Amount" headings. Will it
also be subject to a surrender charge?

RESPONSE: If a withdrawal amount is greater than the Total Free Amount (TFA),
then surrender charges would apply. This would apply to both the original and
enhanced rider. We have added "and to surrender charges" to the sentence in
question.



COMMENT 4. With respect to the Annual Step Up under the enhanced rider, please
explain how it is determined whether the application of the step up will
increase the rider charge.

RESPONSE: The explanation about increase of the rider fee when Annual Step Up is
chosen is included in the "Withdrawal Benefit Rider Fee" section of the
prospectus on page 37, and the following is stated:

     We reserve the right to change the fee for this rider up to maximum of
     2.50%. However, any change to the rider fee will only apply to existing
     contract owners if:

          a)   You choose the Annual Elective Step Up after we have exercised
               our rights to increase the rider charge;

This explanation is applicable to both the original and enhanced rider. The only
difference is that for enhanced rider, if there would not be a fee increase,
then the Step Up would be Automatic.

We have made the following revision (revision in italics):

     -    If the application of the step up does not increase the rider charge
          (see the "Withdrawal Benefit Rider Fee" provision in the prospectus),
          the annual step up will be automatically applied to your contract and
          the step up date is the contract anniversary date.

     In addition to the comments listed above, Staff has requested that we make
the following representations on behalf of the Registrant. In connection with
the Post-Effective Amendment listed above, RiverSource Life Insurance Company,
(the "Company") on behalf of the Registrant, hereby acknowledges the following:

     The disclosures in the filing are the responsibility of the Company and the
     Company is fully responsible for the adequacy and accuracy of the
     disclosures in this filing. The Company represents to the Commission that
     comments made by the Commission, or the staff acting pursuant to delegated
     authority, or changes to disclosure in response to staff comments in the
     filing reviewed by the staff, do not foreclosure the Commission from taking
     any action with respect to the filing, and the Company represents that it
     will not assert this action as a defense in any proceeding initiated by the
     Commission or any person, under the federal securities laws of the United
     States.

Please note that a separate 485(b) (1) (vii) request will be submitted for the
New York version of this product which is adding the same feature. If you have
any questions concerning this filing, please contact me at (612) 678-0175, or
Boba Selimovic at (612) 671-7449.

Sincerely,


/s/ Elisabeth A. Dahl
- ------------------------------------
Elisabeth A. Dahl
Counsel
RiverSource Life Insurance Company