December 14, 2007

VIA EDGAR

Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549

ATTN: Document Control - Edgar

RE:   Post-Effective Amendment No. 47 on Form N-4
      RiverSource Variable Account 10
      File Nos. 333-79311 and 811-07355
      RiverSource Retirement Advisor Advantage Plus Variable Annuity
      RiverSource Retirement Advisor Select Plus Variable Annuity

Dear Commissioners:

On behalf of RiverSource Variable Account 10 ("Registrant"), RiverSource Life
Insurance Company is filing electronically Registrant's Post-Effective Amendment
No. 47 ("Amendment No. 47") on Form N-4 pursuant to Rule 485(b) of the
Securities Act of 1933. The supplement to the prospectus has been marked to show
changes from Registrant's Post-Effective Amendment No. 46 filed under Rule
485(a)(1) on or about October 15, 2007 under this Registration Statement as a
template filing to add enhanced version of Guaranteed Minimum Withdrawal Benefit
Rider. Registrant received comments on or about December 4, 2007. Registrant
replied to Staff's comments via correspondence filed on or about December 13,
2007. Staff had no further comments at that time.

This Amendment No. 47 does not contain disclosures that would render it
ineligible to become effective pursuant to paragraph (b) of Rule 485.

The Prospectus and combined Statement of Additional Information relating to the
above-listed supplement, filed electronically as Post-Effective Amendment No. 42
to Registration Statement 333-79311 on or about April 24, 2007 are incorporated
by reference.

If you have any questions, please contact me at 612-678-0175 or Boba Selimovic
at 612-671-7449.

Sincerely,


/s/ Elisabeth A. Dahl
------------------------------------
Elisabeth A. Dahl
Assistant General Counsel and
Assistant Secretary
RiverSource Life Insurance Company