As filed with the Securities and Exchange Commission on April 28, 2011

Registration No. 333-83957

811-09503

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. 32

and

REGISTRATION STATEMENT

UNDER

THE INVESTMENT COMPANY ACT OF 1940

Amendment No. 34

Separate Account VA C

(Exact Name of Registrant)

TRANSAMERICA LIFE INSURANCE COMPANY

(Name of Depositor)

4333 Edgewood Road N.E. Cedar Rapids, IA 52499-0001

(Address of Depositor’s Principal Executive Offices)

Depositor’s Telephone Number:

(319) 355-8330

Darin D. Smith, Esq.

Transamerica Life Insurance Company

4333 Edgewood Road, N.E.

Cedar Rapids, IA 52499-4520

(Name and Address of Agent for Service)

Copy to:

Frederick R. Bellamy, Esq.

Sutherland Asbill and Brennan LLP

1275 Pennsylvania Avenue, N.W.

Washington, D.C. 20004-2415

Title of Securities Being Registered:

Flexible Premium Variable Annuity Policies

It is proposed that this filing will become effective:

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

x on May 1, 2011 pursuant to paragraph (b) of Rule 485

¨ 60 days after filing pursuant to paragraph (a) (1) of Rule 485

¨ on                      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.

TRANSAMERICA EXTRA^SM VARIABLE ANNUITY

Issued Through

SEPARATE ACCOUNT VA C

By

TRANSAMERICA LIFE INSURANCE COMPANY

Prospectus

May 1, 2011

This flexible premium deferred annuity policy has many investment choices. There is a separate account that currently provides a means of investing in various underlying fund portfolios. There is also a fixed account, which offers interest at rates that are guaranteed by Transamerica Life Insurance Company. You can choose any combination of these investment choices. You bear the entire investment risk for all amounts you put in the separate account.

The Company will add a credit to your policy value for each premium payment that you make. Generally, an annuity with a premium enhancement will have higher overall expenses than a similar annuity without a premium enhancement; the amount credited under the premium enhancement may be more than offset by the additional fees and charges associated with the premium enhancement. You should always consider the expenses along with the features and enhancements to be sure that any annuity meets your financial needs and goals.

This prospectus and the underlying fund prospectuses give you important information about the policies and the underlying fund portfolios. Please read them carefully before you invest and keep them for future reference.

If you would like more information about the Transamerica Extra^SM Variable Annuity, you can obtain a free copy of the Statement of Additional Information (SAI) dated May 1, 2011. Please call us at (800) 525-6205 or write us at: Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001. A registration statement, including the SAI, has been filed with the Securities and Exchange Commission (SEC) and the SAI is incorporated herein by reference. More information about the variable annuity can be reviewed and copied at the SEC’s Public Reference Room in Washington, D.C. You may obtain information about the operation of the public reference room by calling the SEC at 1-800-732-0330. The SEC also maintains a web site (http://www.sec.gov) that contains the prospectus, the SAI, material incorporated by reference, and other information. The table of contents of the SAI is included at the end of this prospectus.

For each premium payment you make, Transamerica will add an additional amount to your policy value, referred to as a premium enhancement.

Please note that the policies and the separate account investment choices:

• are not bank deposits

• are not federally insured

• are not endorsed by any bank or government agency

• are not guaranteed to achieve their goal

• are subject to risks, including loss of premium

The Securities and Exchange Commission has not approved or disapproved these securities, or passed upon the adequacy of this prospectus. Any representation to the contrary is a criminal offense.

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PORTFOLIOS ASSOCIATED WITH THE SUBACCOUNTS

AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS)

Managed by Invesco Advisers, Inc.

Invesco V.I. Basic Value Fund – Series II Shares

Invesco V.I. Capital Appreciation Fund – Series II Shares

ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.

Managed by AllianceBernstein L.P.

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

AllianceBernstein Growth and Income Portfolio – Class B

AllianceBernstein Large Cap Growth Portfolio – Class B

AMERICAN FUNDS INSURANCE SERIES^® TRUST

Managed by Capital Research and Management Company^SM

American Funds – Asset Allocation Fund – Class 2

American Funds – Bond Fund – Class 2

American Funds – Growth Fund – Class 2

American Funds – Growth-Income Fund – Class 2

American Funds – International Fund – Class 2

FIDELITY^® VARIABLE INSURANCE PRODUCTS FUND

Managed by Fidelity Management & Research Company

Fidelity VIP Balanced Portfolio – Service Class 2

Fidelity VIP Contrafund^® Portfolio – Service Class 2

Fidelity VIP Equity-Income Portfolio – Service Class 2

Fidelity VIP Growth Portfolio – Service Class 2

Fidelity VIP Mid Cap Portfolio – Service Class 2

Fidelity VIP Value Strategies Portfolio – Service Class 2

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Managed by Franklin Advisers, Inc.

Franklin Income Securities Fund – Class 2

Managed by Franklin Mutual Advisers, LLC

Mutual Shares Securities Fund – Class 2

Managed by Templeton Investment Counsel LLC

Templeton Foreign Securities Fund – Class 2

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Fund Administrator: Franklin Templeton Services, LLC

Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

GE INVESTMENTS FUNDS, INC.

Managed by GE Asset Management, Inc.

GE Investments Total Return Fund – Class 3

JANUS ASPEN SERIES

Managed by Janus Capital Management LLC

Janus Aspen – Enterprise Portfolio – Service Shares

Janus Aspen – Worldwide Portfolio – Service Shares

MFS^® VARIABLE INSURANCE TRUST

Managed by MFS^® Investment Management

MFS^® New Discovery Series – Service Class

MFS^® Total Return Series – Service Class

TRANSAMERICA SERIES TRUST

Portfolio Construction Manager: Morningstar Associates, LLC

Transamerica Asset Allocation – Conservative VP – Service Class

Transamerica Asset Allocation – Growth VP – Service Class

Transamerica Asset Allocation – Moderate VP – Service Class

Transamerica Asset Allocation – Moderate Growth VP – Service Class

Transamerica International Moderate Growth VP – Service Class

Subadvised by AEGON USA Investment Management, LLC

Transamerica AEGON Active Asset Allocation – ConservativeVP – Service Class

Transamerica AEGON Active Asset Allocation – Moderate VP – Service Class

Transamerica AEGON Active Asset Allocation – Moderate Growth VP – Service Class

Transamerica AEGON High Yield Bond VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Efficient Markets VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Index 75 VP – Service Class

Transamerica Index 100 VP – Service Class

Subadvised by Alliance Bernstein L.P.

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Subadvised by BlackRock Financial Management, Inc.

Transamerica BlackRock Tactical Allocation VP – Service Class

Subadvised by BlackRock Investment Management, LLC

Transamerica BlackRock Large Cap Value VP – Service Class

Subadvised by Foxhall Capital Management, Inc.

Transamerica Foxhall Emerging Markets/Pacific Rim VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Foxhall Global Growth VP – Service Class

Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class

Subadvised by Hanlon Investment Management, Inc.

Transamerica Hanlon Balanced VP – Service Class

Transamerica Hanlon Growth VP – Service Class

Transamerica Hanlon Growth and Income VP – Service Class

Transamerica Hanlon Managed Income VP – Service Class

Subadvised by ING Clarion Real Estate Securities, LLC

Transamerica Clarion Global Real Estate Securities VP – Service Class

Subadvised by J.P. Morgan Investment Management Inc.

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Enhanced Index VP – Service Class

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Transamerica JPMorgan Mid Cap Value VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Subadvised by J.P. Morgan Investment Management Inc. and BlackRock

Financial Management, Inc.

Transamerica Multi-Managed Balanced VP – Service Class

Subadvised by Jennison Associates LLC

Transamerica Jennison Growth VP– Service Class

Subadvised by MFS^® Investment Management

Transamerica MFS International Equity VP – Service Class

Subadvised by Morgan Stanley Investment Management Inc.

Transamerica Morgan Stanley Active International AllocationVP – Service Class

Transamerica Morgan Stanley Capital Growth VP – Service Class

Transamerica Morgan Stanley Growth Opportunities VP – Service Class

Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class

Transamerica Multi Managed Large Cap Core VP – Service Class

Subadvised by Pacific Investment Management Company LLC

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Subadvised by Systematic Financial Management L.P.

Transamerica Systematic Small/Mid Cap Value VP – Service Class

Subadvised by T. Rowe Price Associates, Inc.

Transamerica T. Rowe Price Small Cap VP – Service Class

Advised by Transamerica Asset Management, Inc.

Transamerica BlackRock Global Allocation VP – Service Class

Subadvised by Wellington Management Company, LLP

Transamerica WMC Diversified Equity VP – Service Class

Transamerica WMC Diversified Growth VP – Service Class

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TABLE OF CONTENTS

GLOSSARY OF TERMS		7
SUMMARY		9
ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES		16
1.	THE ANNUITY POLICY	22
2.	PURCHASE	22
	Policy Issue Requirements	22
	Premium Payments	23
	Initial Premium Requirements	23
	Additional Premium Payments	23
	Maximum Total Premium Payments	23
	Allocation of Premium Payments	24
	Policy Value	24
	Premium Enhancement	24
3.	INVESTMENT CHOICES	25
	The Separate Account	25
	Selection of Underlying Portfolios	29
	Addition, Deletion, or Substitution of Investments	30
	Static Allocation Models	31
	The Fixed Account	31
	Transfers	32
	Market Timing and Disruptive Trading	32
4.	PERFORMANCE	36
5.	EXPENSES	36
	Surrender Charges	36
	Excess Interest Adjustment	37
	Mortality and Expense Risk Fees	38
	Premium Taxes	38
	Federal, State and Local Taxes	38
	Special Service Fees	38
	Transfer Fee	38
	Administrative Charges	38
	Initial Payment Guarantee	39
	Fund Facilitation Fee	39
	Additional Death Distribution	39
	Additional Death Distribution+	39
	Living Benefits Rider	39
	Retirement Income Choice® 1.2 Rider and Additional Options Fees	39
	Retirement Income Choice® 1.4 Rider and Additional Options Fees - This Rider is No Longer Available for New Sales	40
	Income Link® Rider Fee	40
	Retirement Income MaxSM Rider Fees	40
	Portfolio Fees and Expenses	41
	Revenue We Receive	41
6.	ACCESS TO YOUR MONEY	43
	Surrenders	43
	Delay of Payment and Transfers	44
	Excess Interest Adjustment	44
	Signature Guarantee	45
7.	ANNUITY PAYMENTS (THE INCOME PHASE)	45
	Annuity Payment Options	46
8.	DEATH BENEFIT	48
	When We Pay A Death Benefit	49
	When We Do Not Pay A Death Benefit	49
	Deaths After the Annuity Commencement Date	49
	Succession of Ownership	49
	Amount of Death Benefit	49
	Guaranteed Minimum Death Benefit	50
	Adjusted Partial Surrender	50
9.	TAXES	51
	Annuity Policies in General	51
	Qualified and Nonqualified Policies	51
	Surrenders-Qualified Policies Generally	52
	Surrenders-403(b) Policies	53
	Surrenders-Nonqualified Policies	53
	Taxation of Death Benefit Proceeds	54
	Annuity Payments	54
	Partial Annuitization	55
	Medicare Tax	55
	Diversification and Distribution Requirements	55
	Federal Defense of Marriage Act	55
	Federal Estate Taxes	55
	Generation-Skipping Transfer Tax	56

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TABLE OF CONTENTS continued

	Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010	56
	Annuity Purchases by Residents of Puerto Rico	56
	Annuity Policies Purchased by Nonresident Aliens and Foreign Corporations	56
	Transfers, Assignments or Exchanges of Policies	56
	Possible Tax Law Changes	57
	Separate Account Charges	57
	Foreign Tax Credits	57
	Guaranteed Lifetime Withdrawal Benefits	57
10.	ADDITIONAL FEATURES	57
	Systematic Payout Option	57
	Income Benefit Programs	58
	Initial Payment Guarantee	58
	Additional Death Distribution	59
	Additional Death Distribution+	60
	Nursing Care and Terminal Condition Withdrawal Option	61
	Unemployment Waiver	62
	Telephone Transactions	62
	Dollar Cost Averaging Program	62
	Asset Rebalancing	64
	Guaranteed Lifetime Withdrawal Benefits	64
	Living Benefits Rider	64
	Retirement Income Choice® 1.2 Rider	72
	Retirement Income Choice® 1.4 Rider - This Rider is No Longer Available for New Sales	84
	Income Link® Rider	93
	Retirement Income MaxSM Rider	101
11.	OTHER INFORMATION	107
	Ownership	107
	Beneficiary	107
	Right to Cancel Period	108
	Assignment	108
	Sending Forms and Transaction Requests in Good Order	108
	Mixed and Shared Funding	108
	Exchanges and Reinstatements	109
	Voting Rights	109
	Legal Proceedings	109
	Transamerica Life Insurance Company	110
	Financial Condition of the Company	110
	The Separate Account	111
	Distribution of the Policies	111
TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION		114
APPENDIX
	CONDENSED FINANCIAL INFORMATION	115
APPENDIX
	POLICY VARIATIONS	126
APPENDIX
	EXCESS INTEREST ADJUSTMENT EXAMPLES	131
APPENDIX
	DEATH BENEFIT	135
APPENDIX
	ADDITIONAL DEATH DISTRIBUTION RIDER — ADDITIONAL INFORMATION	138
APPENDIX
	ADDITIONAL DEATH DISTRIBUTION+ RIDER — ADDITIONAL INFORMATION	139
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT COMPARISON TABLE	140
APPENDIX
	LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS	144
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME CHOICE® 1.2 RIDER AND RETIREMENT INCOME CHOICE® 1.4 RIDER (RETIREMENT INCOME CHOICE® 1.4 - NO LONGER AVAILABLE FOR NEW SALES)	151

5

TABLE OF CONTENTS continued

APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS – INCOME LINK® RIDER	157
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS – RETIREMENT INCOME MAXSM RIDER	159
APPENDIX
	HYPOTHETICAL EXAMPLE OF THE WITHDRAWAL BASE CALCULATION – RETIREMENT INCOME MAXSM RIDER	162

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GLOSSARY OF TERMS

Accumulation Unit — An accounting unit of measure used in calculating the policy value in the separate account before the annuity commencement date.

Adjusted Policy Value — The policy value increased or decreased by any excess interest adjustment.

Administrative and Service Office — Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001, (800) 525-6205.

Annuitant — The person on whose life any annuity payments involving life contingencies will be based.

Annuitize (Annuitization) — When you switch from the accumulation phase to the income phase and we begin to make annuity payments to you (or your designee).

Annuity Commencement Date — The date upon which annuity payments are to commence. This date may be any date after the policy date and may not be later than the last day of the policy month following the month after the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy. The annuity commencement date may have to be earlier for qualified policies and may be earlier if required by state law.

Annuity Payment Option — A method of receiving a stream of annuity payments selected by the owner.

Assumed Investment Return or AIR — The annual effective rate shown in the contract specifications section of the contract that is used in the calculation of each variable annuity payment.

Cash Value — The adjusted policy value less any applicable surrender charge and rider fees (imposed upon surrender).

Excess Interest Adjustment — A positive or negative adjustment to amounts surrendered (both partial or full surrenders and transfers) or applied to annuity payment options from the fixed account guaranteed period options prior to the end of the guaranteed period. The adjustment reflects changes in the interest rates declared by the Company since the date any payment was received by, or an amount was transferred to, the guaranteed period option. The excess interest adjustment can either decrease or increase the amount to be received by the owner upon full surrender or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively.

Fixed Account — One or more investment choices under the policy that are part of the Company’s general assets and are not in the separate account.

Free Amount — The amount that can be withdrawn each year without incurring any surrender charge or excess interest adjustment.

Guaranteed Lifetime Withdrawal Benefit — Any optional benefit under the policy that provides a guaranteed minimum withdrawal benefit, including the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider.

Guaranteed Period Options — The various guaranteed interest rate periods of the fixed account which the Company may offer and into which premium payments may be paid or amounts transferred.

Owner (You, Your) — The person who may exercise all rights and privileges under the policy. The owner during the lifetime of the annuitant and before the annuity commencement date is the person designated as the owner in the information that we require to issue a policy.

Policy Date — The date shown on the policy data page attached to the policy and the date on which the policy becomes effective.

Policy Value — On or before the annuity commencement date, the policy value is equal to the owner’s:

• premium payments; minus

• gross partial surrenders (partial surrenders minus excess interest adjustments plus the surrender charge on the portion of the requested partial surrender that is subject to the surrender charge); plus

• interest credited in the fixed account; plus

• accumulated gains in the separate account; minus

• accumulated losses in the separate account; minus

7

• service charges, rider fees, premium taxes, transfer fees, and other charges, if any.

Policy Year — A policy year begins on the policy date and on each anniversary thereof.

Separate Account — Separate Account VA C, a separate account established and registered as a unit investment trust under the Investment Company Act of 1940, as amended (the “1940 Act”), to which premium payments under the policies may be allocated.

Separate Account Value — The portion of the policy value that is invested in the separate account.

Subaccount — A subdivision within the separate account, the assets of which are invested in a specified underlying fund portfolio.

Valuation Period — The period of time from one determination of accumulation unit values and annuity unit values to the next subsequent determination of those values. Such determination shall be made on each business day.

Written Notice — Written notice, signed by the owner, that gives the Company the information it requires and is received in good order at the Administrative and Service Office. For some transactions, the Company may accept an electronic notice such as telephone instructions. Such electronic notice must meet the requirements for good order that the Company establishes for such notices.

You (Your) — the owner of the policy.

8

SUMMARY

The sections in this summary correspond to sections in this prospectus, which discuss the topics in more detail.

1. THE ANNUITY POLICY

The flexible premium deferred variable annuity policy offered by Transamerica Life Insurance Company (the Company, we, us, or our) provides a way for you to invest on a tax-deferred basis in the following investment choices: various subaccounts of the separate account and the fixed account of the Company. The policy is intended to accumulate money for retirement or other long-term investment purposes.

This policy currently offers subaccounts that are listed under “Investment Choices” in this prospectus. Each subaccount invests exclusively in shares of one of the underlying fund portfolios. The policy value may depend on the investment experience of the selected subaccounts. Therefore, you bear the entire investment risk with respect to all policy value in any subaccount. You could lose the amount that you invest.

The fixed account offers an interest rate that the Company guarantees.

The policy, like all deferred annuity policies, has two phases: the “accumulation phase” and the “income phase.” During the accumulation phase, earnings accumulate on a tax-deferred basis and are taxed as ordinary income when you take them out of the policy. The income phase occurs when you annuitize and begin receiving regular annuity payments from your policy. The money you can accumulate during the accumulation phase will largely determine the payments you receive during the income phase.

2. PURCHASE

The initial premium payment for nonqualified policies must be at least $5,000 or more, and at least $1,000 for qualified policies, under most circumstances. You must obtain prior Company approval to purchase a policy with an amount less than the stated minimum. You can generally add as little as $50 at any time during the accumulation phase.

3. INVESTMENT CHOICES

You can allocate your premium payments to one of several underlying fund portfolios listed under Investment Choices in this prospectus and described in the underlying fund prospectuses. Depending upon their investment performance, you can make or lose money in any of the subaccounts.

You can also allocate your premium payments to the fixed account.

We currently allow you to transfer money between any of the investment choices during the accumulation phase. We reserve the right to impose a $10 fee for each transfer in excess of 12 transfers per policy year and to impose restrictions and limitations on transfers.

9

4. PERFORMANCE

The value of the policy will vary up or down depending upon the investment performance of the subaccounts you choose.

5. EXPENSES

Note: The following section on expenses and the Annuity Policy Fee Table and expense examples only apply to policies issued after the date of this prospectus. See “Appendix – Policy Variations” for information about older policies.

No deductions are made from premium payments at the time you buy the policy so that the full amount of each premium payment is invested in one or more of your investment choices.

We may deduct a surrender charge of up to 9% of premium payments surrendered within nine years after the premium is paid. We will calculate surrender charges by taking the earnings, if any, out before premium payments. If you select the Life with Emergency Cash^® annuity payment option, then you can surrender your policy after annuity payments have begun. A surrender charge of up to 4% of adjusted policy value will apply during the first four years after the annuity commencement date.

Full surrenders, partial surrenders, and transfers from a guaranteed period option of the fixed account may also be subject to an excess interest adjustment, which may increase or decrease the amount you receive. This adjustment may also apply to amounts applied to an annuity payment option from a guaranteed period option of the fixed account prior to the end of the guaranteed period option.

We deduct daily mortality and expense risk fees and administrative charges from the assets in each subaccount during the accumulation phase, at an annual rate (as a percentage of the subaccount’s value) that depend on the death benefit option that you select, as follows:

• 1.65% if you choose the Return of Premium Death Benefit

• 1.85% if you choose the Annual Step-Up Death Benefit

During the accumulation phase, we deduct an annual service charge of no more than $35 from the policy value The charge is waived if either the policy value or the sum of all premium payments, minus all partial surrenders, is at least $100,000.

Upon full surrender, payment of a death benefit, or when annuity payments begin, we will deduct state premium taxes, if applicable. State premium taxes currently range from 0% to 3.50%, depending on the state.

If you elect the Initial Payment Guarantee feature when you annuitize, then there is a daily fee (during the income phase) currently equal to an annual rate of 1.25% of the daily net asset value in the subaccounts.

We deduct a daily fund facilitation fee from the assets in certain investment choices at an annual rate (as a percentage of the subaccount’s value) as follows:

• 0.30% if you choose the American Funds – Asset Allocation Fund – Class 2

• 0.30% if you choose the American Funds – Bond Fund – Class 2

• 0.30% if you choose the American Funds – Growth Fund – Class 2

• 0.30% if you choose the American Funds – Growth-Income Fund – Class 2

• 0.30% if you choose the American Funds – International Fund – Class 2

• 0.20% if you choose the AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

10

• 0.20% if you choose the GE Investments Total Return Fund – Class 3

• 0.15% if you choose the Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

• 0.10 % if you choose the Transamerica BlackRock Global Allocation VP – Service Class

If you elect the Additional Death Distribution (“ADD”), then there is an annual rider fee during the accumulation phase of 0.25% of the policy value.

If you elect the Additional Death Distribution+ (“ADD+”), then there is an annual rider fee during the accumulation phase of 0.55% of the policy value.

If you elect the Living Benefits Rider, then there is an annual rider fee during the accumulation phase of 0.90% of the “principal back” total withdrawal base on each anniversary (“rider anniversary”) of the date the rider was elected.

If you elect the Retirement Income Choice^® 1.2 Rider, there is an annual rider fee during the accumulation phase of 1.20% (of the withdrawal base charged quarterly) if you elect the Open Allocation option, and 0.45% to 1.40% if you elect the Designated Allocation option depending on what designated investment options you choose. For each additional option you elect with the rider, you will be charged a quarterly fee during the accumulation phase that is also a percentage of the withdrawal base; this fee is in addition to the rider fee for the base benefit.

If you elect the Income Link^® Rider, there is a rider fee during the accumulation phase of 0.90% (on an annual basis) of the withdrawal base charged quarterly.

If you elect the Retirement Income Max^SM Rider, there is a quarterly rider fee during the accumulation phase of 1.00% annually.

The value of the net assets of the subaccounts will reflect the management fee and other expenses incurred by the underlying fund portfolios.

6. ACCESS TO YOUR MONEY

You can generally take out $500 or more anytime during the accumulation phase (except under certain qualified policies).

You may generally take out up to the free amount free of surrender charges. Amounts surrendered in excess of this free amount may be subject to a surrender charge and an excess interest adjustment. You may have to pay income tax and a tax penalty on any money you take out.

If you have policy value in the fixed account, you may take out any cumulative interest credited free of excess interest adjustments.

Access to amounts held in qualified policies may be restricted or prohibited by law or regulation or the terms of the policy.

Surrenders are not generally permitted during the income phase unless you elect the Life with Emergency Cash^® annuity payment option.

Partial surrenders will reduce your policy value. Depending on its amount and timing, a partial surrender may considerably reduce or eliminate some of the benefits and guarantees provided by your Contract. You should carefully consider whether a partial surrender under a particular circumstance will have a negative impact to your benefits or guarantees. The impact of partial and full surrenders (generally) on your benefits and guarantees is discussed in the corresponding sections of the prospectus describing such benefits and guarantees.

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7. ANNUITY PAYMENTS (THE INCOME PHASE)

The policy allows you to receive income under one of several annuity payment options. You may choose from fixed payment options, variable payment options, or a combination of both. If you select a variable payment option, then the dollar amount of your annuity payments may go up or down. However, the Initial Payment Guarantee is available for an extra fee and it guarantees a minimum amount for each variable annuity payment.

8. DEATH BENEFIT

If the sole annuitant dies before the income phase begins, then the beneficiary will generally receive a death benefit. If the owner is not the annuitant, then no death benefit is paid if the owner dies; however required distribution rules require that the policy value be distributed upon the death of any owner.

Naming different persons as owner and annuitant can affect to whom and whether amounts will be paid. Use care when naming owners, annuitants and beneficiaries, and consult your agent if you have questions.

When you purchase a policy you may generally choose an optional guaranteed minimum death benefit:

• Annual Step-Up Death Benefit

Charges are lower if you do not choose an optional guaranteed minimum death benefit.

After the policy is issued, a guaranteed minimum death benefit cannot be added, and the death benefit cannot be changed.

9. TAXES

Earnings, if any, are generally not taxed until taken out. If you take money out of a nonqualified policy during the accumulation phase, earnings come out first for federal tax purposes, and are taxed as ordinary income. For nonqualified and certain qualified policies, payments during the income phase may be considered partly a return of your original investment so that part of each payment may not be taxable as income. For qualified policies, payments during the income phase are, in many cases, considered as all taxable income. If you are younger than 59 ¹/2 when you take money out, you may incur a 10% federal penalty tax on the taxable earnings.

10. ADDITIONAL FEATURES

This policy has additional features that might interest you. These features may not be available for all policies, may vary for certain policies, may not each be available in combination with other optional benefits under the policy, and may not be suitable for your particular situation.

These features include, but are not limited to, the following:

• You can arrange to have money automatically sent to you monthly, quarterly, semi-annually or annually while your policy is in the accumulation phase. This feature is referred to as the “Systematic Payout Option” (“SPO”). Amounts you receive may be included in your gross income, and in certain circumstances, may be subject to penalty taxes.

• You can elect an optional feature at the time of annuitization that guarantees your variable annuity payments will never be less than a percentage of the initial variable annuity

12

payment. This feature is called the “Initial Payment Guarantee” (“IPG”). There is an extra charge for this feature.

• You may elect one of two optional riders that might pay an additional amount on top of the policy death benefit, in certain circumstances. These features are called the “Additional Death Distribution” (“ADD”) and “Additional Death Distribution+” (“ADD+”). There is an extra charge for these riders.

• Under certain medically related circumstances, you may surrender all or part of the policy value without any surrender charge or excess interest adjustment. This feature is called the “Nursing Care and Terminal Condition Withdrawal Option.”

• Under certain unemployment circumstances, you may surrender all or a portion of the policy value free of any surrender charge or excess interest adjustment. This feature is called the “Unemployment Waiver.”

• You may generally make transfers and/or change the allocation of additional premium payments by telephone. We may restrict or eliminate this feature.

• You can arrange to automatically transfer money (at least $500 per transfer) monthly or quarterly from certain investment choices into one or more subaccounts. This feature is known as “Dollar Cost Averaging.”

• We will, upon your request, automatically transfer amounts among the subaccounts on a regular basis to maintain a desired allocation of the policy value among the various subaccounts. This feature is called “Asset Rebalancing.”

• You may elect to purchase an optional rider which provides you with a guaranteed minimum accumulation benefit and a guaranteed lifetime withdrawal benefit. This feature is called the “Living Benefits Rider.” If you elect this rider, we will monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts back and forth between investment choices that we designate and the variable investment choices that you have selected. You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit. This feature is called the “Retirement Income Choice^® 1.2 Rider.” If you elect the Retirement Income Choice^® 1.2 Rider, you must allocate 100% of your policy value according to either the Designated Allocation option or the Open Allocation option and meet other conditions. (See “Retirement Income Choice^® 1.2 – Allocation Options and Restrictions”.) You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit that uses a higher withdrawal percentage for a defined period of time and then resets to a lower percentage. This feature is called the “Income Link^® Rider.” If you elect the Income Link^® Rider, you must allocate 100% of your policy value to one or more “designated investment option(s).” (See “Income Link^® Rider - Designated Investment Options”.) You may lose the benefit of this rider if you take non-Income Link^® rider systematic withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit. This feature is called the “Retirement Income Max^SM Rider.” If you elect the Retirement Income Max^SM Rider, you must allocate 100% of your policy value to one or more “designated investment option(s).” (See “Retirement Income Max^SM – Designated Investment Options”.) The designated investment options differ from the designated

13

investment options for the other guaranteed lifetime withdrawal benefits. You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

11. OTHER INFORMATION

Right to Cancel Period. You may return your policy for a refund, but only if you return it within a prescribed period, which is generally 10 days (after you receive the policy), or whatever longer time may be required by state law. The amount of the refund will generally be the premiums paid plus or minus accumulated gains or losses in the separate account; if state law requires, we will refund your original premium payment(s). The policy will then be deemed void.

No Probate. Usually, the person receiving the death benefit under this policy will not have to go through probate. State laws vary on how the amount that may be paid is treated for estate tax purposes.

Who should purchase the Policy? This policy is designed for people seeking long-term tax-deferred accumulation of assets, generally for retirement or other long-term purposes; and for persons who have maximized their use of other retirement savings methods, such as 401(k) plans. The tax-deferred feature is most attractive to people in high federal and state tax brackets. The tax deferral features of variable annuities are unnecessary when purchased to fund a qualified plan. You should not buy this policy if you are looking for a short-term investment, market timing, or if you cannot take the risk of losing money that you put in.

There are various fees and charges associated with variable annuities. You should consider whether the features and benefits of this policy, unique to variable annuities, such as the opportunity for lifetime income payments, a guaranteed death benefit, the guaranteed level of certain charges, and additional features, make this policy appropriate for your needs.

State Variations. Policies issued in your state may provide different features and benefits from, and impose different costs than, those described in this prospectus because of state law variations. These differences include, among other things, free look rights, issue age limitations, and the general availability of riders. This prospectus describes the material rights and obligations of a policy owner, and the maximum fees and charges for all policy features and benefits are set forth in the fee table of this prospectus. See your policy for specific variations because any such state variations will be included in your policy or in riders or endorsements attached to your policy. See your agent or contact us for specific information that is applicable to your state.

Old Policies. This prospectus generally describes policies issued after the date of this prospectus. See “Appendix - Policy Variations” for information on how older policies have different features and requirements, and sometimes different fees and deductions.

Financial Statements. Financial Statements for the Company and the subaccounts are in the SAI. Condensed financial information for the subaccounts (those in operation by year end December 31, 2010, if any) are in “Appendix – Condensed Financial Information” to this prospectus.

12. INQUIRIES

If you need more information or want to make a transaction, please contact us at:

Transamerica Life Insurance Company

Administrative and Service Office

Attention: Customer Care Group

14

4333 Edgewood Road NE

Cedar Rapids, IA 52499-0001

(800) 525-6205

You may check your policy at www.transamericaannuities.com. Follow the logon procedures. You will need your pre-assigned Personal Identification Number (“PIN”) to access information about your policy. We cannot guarantee that you will be able to access this site.

You should protect your PIN, because on-line (or telephone) options may be available and could be made by anyone who knows your PIN. We may not be able to verify that the person providing instructions using your PIN is you or someone authorized by you.

15

ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES

The following describes the fees and expenses that you will pay when buying, owning, and surrendering the policy. Please be certain to review the notes following the fee table and expense examples for further information about the fees and charges presented. The order of the notes follows the order in which the fees and charges under the policy are presented in the fee tables and the expense examples.

The first section describes the fees and expenses that you will pay at the time that you buy the policy, surrender the policy, or transfer cash value between investment choices. State premium taxes may also be deducted. Excess interest adjustments may be made to amounts surrendered or applied to annuity payment options from cash value from the fixed account. (All fees are maximum for purchases made while this prospectus is effective unless otherwise noted.)

Policy Owner Transaction Expenses:

Sales Load On Purchase Payments		0	%
Maximum Surrender Charge (as a % of premium payments surrendered)
Base Policy		9	%
Transfer Fee	$	0 - $10
Special Service Fee	$	0 - $25

The next section describes the fees and expenses that you will pay periodically during the time that you own the policy, not including portfolio fees and expenses. (All fees are maximum for purchases made while this prospectus is effective unless otherwise noted.)

Annual Service Charge	$	0 – $35 per policy
Separate Account Annual Expenses (as a percentage, annually, of average separate account value):
Base Separate Account Expenses:
Mortality and Expense Risk Fee		1.50	%
Administrative Charge		0.15	%
Total Base Separate Account Annual Expenses		1.65	%
Optional Separate Account Expenses:
Annual Step-Up Death Benefit		0.20	%
Fund Facilitation Fee		0.30	%
Total Separate Account Annual Expenses with Highest Optional Separate Account Expenses		2.15	%
Optional Rider Fees:
Additional Death Distribution (annual charge based on policy value)		0.25	%
Additional Death Distribution+ (annual charge based on policy value)		0.55	%
Living Benefits Rider (annual charge, a % of Total Withdrawal Base)		0.90	%
Retirement Income Choice® 1.2 Rider (annual charge, a % of withdrawal base):
Base Benefit Open Allocation Option (Maximum)		1.95	%
Base Benefit Open Allocation Option (Current)		1.20	%
Base Benefit Designated Allocation Group A (Maximum)		2.15	%
Base Benefit Designated Allocation Group A (Current)		1.40	%

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Base Benefit Designated Allocation Group B (Maximum)	1.75	%
Base Benefit Designated Allocation Group B (Current)	1.00	%
Base Benefit Designated Allocation Group C (Maximum)	1.20	%
Base Benefit Designated Allocation Group C (Current)	0.45	%
Additional Benefits available with the Retirement Income Choice® 1.2 Rider:
Death Benefit (Single Life Option)	0.25	%
Death Benefit (Joint Life Option)	0.20	%
Income Enhancement Benefit (Single Life Option)	0.15	%
Income Enhancement Benefit (Joint Life Option)	0.30	%
Maximum Total Retirement Income Choice® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits	2.65	%
Current Total Retirement Income Choice® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits	1.90	%

Retirement Income Choice^® 1.4 Rider (annual charge, a % of withdrawal base):

This Rider is No Longer Available for New Sales

Base Benefit Designated Allocation Group A (Maximum)	2.15	%
Base Benefit Designated Allocation Group A (Current)	1.40	%
Base Benefit Designated Allocation Group B (Maximum)	1.75	%
Base Benefit Designated Allocation Group B (Current)	1.00	%
Base Benefit Designated Allocation Group C (Maximum)	1.20	%
Base Benefit Designated Allocation Group C (Current)	0.45	%
Additional Benefits available with the Retirement Income Choice® 1.4 Rider:
Death Benefit (Single Life Option)	0.25	%
Death Benefit (Joint Life Option)	0.20	%
Income Enhancement Benefit (Single Life Option)	0.15	%
Income Enhancement Benefit (Joint Life Option)	0.30	%
Maximum Total Retirement Income Choice® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits	2.65	%
Current Total Retirement Income Choice® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits.	1.90	%
Income Link® Rider (annual charge a - % of withdrawal base):
Base Benefit (Maximum)	1.65	%
Base Benefit (Current)	0.90	%
Retirement Income MaxSM Rider (annual charge a % of withdrawal base):
Base Benefit (Maximum)	1.75	%
Base Benefit (Current)	1.00	%

The next section shows the lowest and highest total operating expenses charged by the underlying fund portfolios for the year ended December 31, 2010 (before any fee waiver or expense reimbursements). Expenses may be higher or lower in future years. More detail concerning each portfolio’s fees and expenses is contained in the prospectus for each portfolio.

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Total Portfolio Annual Operating Expenses (Expenses that are deducted from portfolio assets, including management fees, distribution and/or service 12b-1 fees, and other expenses):

Lowest Gross	0.54	%
Highest Gross	1.78	%

The following Example is intended to help you compare the cost of investing in the policy with the cost of investing in other variable annuity policies. These costs include policy owner transaction expenses, policy fees, separate account annual expenses, and portfolio fees and expenses.

The Example assumes that you invest $10,000 in the policy for the time periods indicated. The Example also assumes that your investment has a 5% return each year, the highest fees and expenses of any of the portfolios for the year ended December 31, 2010, and the base policy with the combination of available optional features or riders with the highest fees and expenses, including the Highest Fund Facilitation Fee, Annual Step-Up Death Benefit, Additional Death Distribution+ Rider, and Retirement Income Choice^® 1.2 Rider - Joint Life with additional Death Benefit and Income Enhancement options. Although your actual costs may be higher or lower, based on these assumptions, your costs would be:

Expense Examples:

If the policy is surrendered at the end of the applicable time period:

1 Year	$	1464
3 Years	$	2600
5 Years	$	3750
10 Years	$	6678

If the policy is annuitized at the end of the applicable time period or if you do not surrender your policy:

1 Year	$	654
3 Years	$	1970
5 Years	$	3300
10 Years	$	6678

Please remember that the Example is an illustration and does not represent past or future expenses. Your actual expenses may be lower or higher than those reflected in the Example. Similarly, your rate of return may be more or less than the 5% assumed in the Example.

For information concerning compensation paid for the sale of the policies, see “Distributor of the Policies.”

NOTES TO FEE TABLE AND EXPENSE EXAMPLES

Annuity Policy Fee Table and Expense Examples: The fee table applies only to the accumulation phase and reflects the maximum charges unless otherwise noted. During the income phase the fees may be different than those described in the Fee Table. See section “5. Expenses”.

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Policy Owner Transaction Expenses:

Maximum Surrender Charge: The surrender charge, if any is imposed, applies to each premium, regardless of how policy value is allocated among the investment choices. The surrender charge decreases based on the number of years since the premium payment was made.

If you select the Life with Emergency Cash^® annuity payment option, you will be subject to a surrender charge after the annuity commencement date. See section “5. Expenses”.

Transfer Fee: The transfer fee, if any is imposed, applies to each policy, regardless of how policy value is allocated among the investment choices. There is no fee for the first 12 transfers per policy year. For additional transfers, the Company may charge a fee of $10 per transfer.

Special Service Fees: We may deduct a charge for special services, such as overnight delivery.

Annual Service Charge:

Annual Service Charge: The annual service charge is assessed on each policy anniversary and at surrender. The charge is waived if your policy value, or the sum of your premiums less all partial surrenders, is at least $100,000.

Separate Account Annual Expenses:

Mortality and Expense Risk Fee: The mortality and expense risk fee shown is for the accumulation phase with the base death benefit.

Optional Separate Account Expenses: Any optional separate account expense is in addition to the mortality and expense risk and administrative fees.

Fund Facilitation Fee: This daily fee is applied only to policy value in the subaccounts invested in the American Funds - Asset Allocation Fund - Class 2 (0.30%), American Funds - Bond Fund - Class 2 (0.30%), American Funds - Growth Fund - Class 2 (0.30%), American Funds - Growth-Income Fund - Class 2 (0.30%), American Funds -International Fund - Class 2 (0.30%), AllianceBernstein Balanced Wealth Strategy Portfolio - Class B (0.20%), GE Investments Total Return Fund - Class 3 (0.20%), the Franklin Templeton VIP Founding Funds Allocation Fund -Class 4 (0.15%), and the Transamerica BlackRock Global Allocation VP - Service Class (0.10%). See section “5. Expenses”.

Total Separate Account Annual Expenses with Highest Optional Separate Account Expenses: This reflects the base separate account expenses, the Annual Step-Up Death Benefit fee, plus the Fund Facilitation fee, but does not include any annual optional rider fees. The death benefits are mutually exclusive.

Optional Rider Fees:

Optional Rider Fees: In some cases, riders to the policy are available that provide optional benefits. There are additional fees (each year) for those riders.

Additional Death Distribution Rider and Additional Death Distribution+ Rider: This annual fee is a percentage of the policy value and is only deducted during the accumulation phase.

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Living Benefits Rider: The annual fee is a percentage of the “principal back” Total Withdrawal Base. The “principal back” Total Withdrawal Base on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the “principal back” Total Withdrawal Base is equal to: the “principal back” Total Withdrawal Base on the rider date; plus subsequent premium payments; less subsequent “principal back” adjusted partial withdrawals.

Retirement Income Choice^® 1.2 Rider, Retirement Income Choice^® 1.4 Rider, Income Link^® and Retirement Income Max^SM Rider - base benefit: The fee is a percentage of the Withdrawal Base. The Withdrawal Base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the Withdrawal Base is equal to the Withdrawal Base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent Withdrawal Base adjustments.

Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider - Additional Benefits (Single Life and Joint Life Options): You may elect the Retirement Income Choice^® 1.2 Rider or the Retirement Income Choice^® 1.4 Rider with one or more of the following options - Death Benefit or Income Enhancement Benefit. The charge for each of these options is a percentage of the Withdrawal Base and is in addition to the base benefit fee.

Maximum Total Retirement Income Choice^® 1.2 Rider and Maximum Total Retirement Income Choice^® 1.4 Rider Fees with Highest Combination of Benefits: After the fifth rider anniversary, the base benefit rider fees can increase when there is an automatic step-up. These fee totals reflect the maximum fee increase resulting from an automatic step-up of the Withdrawal Base while the rider is in effect.

Maximum Total Retirement Income Choice^® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Maximum), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Current Total Retirement Income Choice^® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Current), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Maximum Total Retirement Income Choice^® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Maximum), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Current Total Retirement Income Choice^® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Current), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Maximum Total Income Link^® Rider and Retirement Income Max^SM Rider Fees: After the first rider anniversary, the base benefit rider fees can increase when there is an automatic step-up. This fee total reflects the maximum fee increase resulting from an automatic step-up of the Withdrawal Base while the rider is in effect.

Total Portfolio Annual Operating Expenses:

Total Portfolio Annual Operating Expenses: The fee table information relating to the underlying fund portfolios was provided to the Company by the underlying fund portfolios, their investment advisors or managers, and the Company has not and cannot independently verify the accuracy or completeness of such information. Actual future

20

expenses of the portfolios may be greater or less than those shown in the Table. “Gross” expense figures do not reflect any fee waivers or expense reimbursements. Actual expenses may have been lower than those shown in the Table.

Expense Examples:

Expense Examples: The Example does not reflect premium tax charges or transfer fees. Different fees and expenses not reflected in the Example may be assessed during the income phase of the policy.

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1. THE ANNUITY POLICY

This prospectus describes the Transamerica Extra^SM Variable Annuity policy offered by the Company. This prospectus generally describes policies issued on or after the date of this prospectus. Policies issued before that date may have different features (such as different death benefits or annuity payment options) and different charges. See “Appendix - Policy Variations” for information about older policies.

An annuity is a contract between you, the owner, and an insurance company (in this case the Company), where the insurance company promises to pay you an income in the form of annuity payments. These payments begin on a designated date, referred to as the annuity commencement date. Until the annuity commencement date, your annuity is in the accumulation phase and the earnings (if any) are tax deferred. Tax deferral means you generally are not taxed until you take money out of your annuity. After you annuitize, your annuity switches to the income phase.

The policy is a flexible premium deferred variable annuity. You can use the policy to accumulate funds for retirement or other long-term financial planning purposes. Your individual investment and your rights are determined primarily by your own policy.

The policy is a “flexible premium” annuity because after you purchase it, you can generally make additional investments of $50 or more until the annuity commencement date. You are not required to make any additional investments.

The policy is a “variable” annuity because the value of your investments can go up or down based on the performance of your investment choices. If you invest in the separate account, the amount of money you are able to accumulate in your policy during the accumulation phase depends upon the performance of your investment choices. You could lose the amount you allocate to the separate account. The amount of annuity payments you receive during the income phase from the separate account also depends upon the investment performance of your investment choices for the income phase. However, if you annuitize under the Initial Payment Guarantee feature, then you will receive stabilized annuity payments that will never be less than a percentage of your initial variable annuity payment. There is an extra charge for this feature.

The policy also contains a fixed account. The fixed account offers interest at rates that we guarantee will not decrease during the selected guaranteed period. There may be different interest rates for each different guaranteed period that you select.

Do not purchase this policy if you plan to use it, or any of its riders, for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme. Your contract is not intended or designed to be traded on any stock exchange or secondary market. By purchasing this contract, you represent and warrant that you are not using the contract, or any of its riders for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme.

2. PURCHASE

Policy Issue Requirements

The Company will not issue a policy unless:

• the Company receives in good order (at our Administrative and Service Office) all information needed to issue the policy;

• the Company receives in good order (at our Administrative and Service Office) a minimum initial premium payment; and

• the annuitant, owner, and any joint owner are age 85 or younger (the limit may be lower for qualified policies).

We reserve the right to reject any application or premium payment.

22

Premium Payments

You should make checks for premium payments payable only to Transamerica Life Insurance Company and send them to the Administrative and Service Office. Your check must be honored in order for us to pay any associated payments and benefits due under the policy.

We do not accept cash. We reserve the right to not accept third party checks. A third party check is a check that is made payable to one person who endorses it and offers it as payment to a second person. Checks should normally be payable to Transamerica Life Insurance Company, however, in some circumstances, at our discretion we may accept third party checks that are from a rollover or transfer from other financial institutions. Any third party checks not accepted by our company will be returned.

We reserve the right to reject or accept any form of payment. Any unacceptable forms of payment will be returned.

Initial Premium Requirements

The initial premium payment for nonqualified policies must be at least $5,000, and at least $1,000 for qualified policies. You must obtain prior company approval to purchase a policy with an amount less than the stated minimum. There is generally no minimum initial premium payment for policies issued under section 403(b) of the Internal Revenue Code; however, your premium must be received within 90 days of the policy date or your policy will be canceled. We will credit your initial premium payment to your policy within two business days after the day we receive it and your complete policy information at our administrative and service office. If we are unable to credit your initial premium payment, we will contact you within five business days and explain why. We will also return your initial premium payment at that time unless you let us keep it and credit it as soon as possible.

The date on which we credit your initial premium payment to your policy is generally the policy date. The policy date is used to determine policy years, policy months and policy anniversaries.

There may be delays in our receipt of applications that are outside of our control (for example, because of the failure of the selling broker/dealer or sales agent to forward the application to us promptly, or because of delays in determining whether the policy is suitable for you). Any such delays will affect when your policy can be issued and your premium allocated among your investment choices.

Additional Premium Payments

You are not required to make any additional premium payments. However, you can generally make additional premium payments as often as you like during the accumulation phase. Additional premium payments must be at least $50. We will credit additional premium payments to your policy as of the business day we receive your premium and required information in good order at our Administrative and Service Office. Additional premium payments must be received before the close of a regular business session of the New York Stock Exchange (usually 4:00 p.m. Eastern time) to get same-day pricing of the additional premium payment.

Maximum Total Premium Payments

For issue ages 0-80, we reserve the right to reject cumulative premium payments over $1,000,000 (this includes subsequent premium payments) for policies with the same owner or same annuitant issued by us or an affiliate. For issue ages over 80, we reserve the right to reject cumulative premium payments over

23

$500,000 (this includes subsequent premium payments) for policies with the same owner or same annuitant issued by us or an affiliate.

Allocation of Premium Payments

When you purchase a policy, we will allocate your premium payment to the investment choices you select. Your allocation must be in whole percentages and must total 100%. We will allocate additional premium payments the same way, unless you request a different allocation.

If you allocate premium payments to the Dollar Cost Averaging program, you must give us instructions regarding the subaccount(s) to which transfers are to be made or we cannot accept your premium payment.

You may change allocations for future additional premium payments by sending written instructions to our Administrative and Service Office, or by telephone, subject to the limitations described under “Telephone Transactions”. The allocation change will apply to premium payments received on or after the date we receive the change request in good order.

You could lose the amount you allocate to the variable subaccounts.

The Company reserves the right to restrict or refuse any premium payment.

Policy Value

You should expect your policy value to change from valuation period to valuation period. A valuation period begins at the close of regular trading on the New York Stock Exchange on each business day and ends at the close of regular trading on the next succeeding business day. A business day is each day that the New York Stock Exchange is open. The New York Stock Exchange generally closes at 4:00 p.m. Eastern time. Holidays are generally not business days.

Premium Enhancement

An amount equal to the applicable percentage (as set forth below) of the initial premium payment will be added to the policy value. The amount of the premium enhancement is not considered a premium payment and therefore may not be included in the calculation of certain policy features (such as certain death benefits or living benefits) or in the calculation of fees and charges that are based on premium payments made. The premium enhancement percentage may vary from premium to premium on subsequent premium payments, but will never be less than 0.25% nor more than 7%. A confirmation will be sent advising the owner of the amount of premium enhancement applicable to each subsequent premium payment. No premium enhancement will apply if the policy is canceled pursuant to the right to cancel provision.

The premium enhancement percentage is determined by the annuitant’s age at the time of each premium payment. The percentage will decrease as the annuitant’s attained age increases. The following schedule shows the current premium enhancement percentages:

Annuitant’s Age	Premium Enhancement Percentage
0-59		5.5	%
60-69		5.0	%
70-79		4.0	%
80+		2.0	%

These percentages are not guaranteed: As noted above, these percentages may change to as little as 0.25%.

24

Generally, an annuity with a premium enhancement may have higher expenses than a similar annuity without a premium enhancement. Accordingly, you should always consider the expenses along with the features and enhancements to be sure any annuity meets your financial needs and goals.

There is no specific charge for the premium enhancement. Transamerica expects to use a portion of the mortality and expense risk fee, administrative charge and/or the surrender charge to pay the premium enhancement.

Transamerica may take back or “recapture” the full dollar amount of any premium enhancement upon the occurrence of any of the following events:

• exercise of the right to cancel option;

• exercise of the Nursing Care and Terminal Condition Withdrawal Option or the Unemployment Waiver within one year from the time we apply the premium enhancement;

• a death benefit is payable within one year from the time we apply the premium enhancement; or

• annuitization within one year from the time we apply the premium enhancement.

In certain unusual circumstances, you might be worse off because of the premium enhancement. This could happen if we recapture the dollar amount of the premium enhancement and the overall investment performance of your policy was negative (if the overall investment performance of your policy was positive you would be better off).

The Internal Revenue Code generally requires that interests in a qualified policy be nonforfeitable, and it is unclear whether the premium enhancement feature is consistent with those requirements. Consult a tax advisor before purchasing this policy as a qualified policy.

The premium enhancement may vary for certain policies and may not be available for all policies.

3. INVESTMENT CHOICES

The Separate Account

The following variable subaccounts are available under the policy for new investors, but may not be available for all policies. The subaccounts invest in shares of the various underlying fund portfolios. The companies that provide investment advice and administrative services for the underlying fund portfolios offered through this policy are listed below. The following variable investment choices are currently offered through this policy. Please be certain to review the notes following the list of variable investment choices.

Note: If you received a summary prospectus for any of the portfolios listed below, please follow the instructions on the first page of the summary prospectus to obtain a copy of the full fund prospectus.

AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS)

Managed by Invesco Advisers, Inc.

Invesco V.I. Basic Value Fund – Series II Shares

Invesco V.I. Capital Appreciation Fund – Series II Shares

ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.

Managed by AllianceBernstein L.P.

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

AllianceBernstein Growth and Income Portfolio – Class B

AllianceBernstein Large Cap Growth Portfolio – Class B

AMERICAN FUNDS INSURANCE SERIES^® TRUST

Managed by Capital Research and Management Company^SM

American Funds - Asset Allocation Fund – Class 2

25

American Funds – Bond Fund – Class 2

American Funds – Growth Fund – Class 2

American Funds – Growth-Income Fund – Class 2

American Funds – International Fund – Class 2

FIDELITY^® VARIABLE INSURANCE PRODUCTS FUND

Managed by Fidelity Management & Research Company

Fidelity VIP Balanced Portfolio – Service Class 2

Fidelity VIP Contrafund^® Portfolio – Service Class 2

Fidelity VIP Equity-Income Portfolio – Service Class 2

Fidelity VIP Growth Portfolio – Service Class 2

Fidelity VIP Mid Cap Portfolio – Service Class 2

Fidelity VIP Value Strategies Portfolio – Service Class 2

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Managed by Franklin Advisers, Inc.

Franklin Income Securities Fund – Class 2

Managed by Franklin Mutual Advisers, LLC

Mutual Shares Securities Fund – Class 2

Managed by Templeton Investment Counsel LLC

Templeton Foreign Securities Fund – Class 2

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Fund Administrator: Franklin Templeton Services, LLC

Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

GE INVESTMENTS FUNDS, INC.

Managed by GE Asset Management, Inc.

GE Investments Total Return Fund – Class 3

JANUS ASPEN SERIES

Managed by Janus Capital Management LLC

Janus Aspen – Enterprise Portfolio – Service Shares

Janus Aspen – Worldwide Portfolio – Service Shares

MFS^® VARIABLE INSURANCE TRUST

Managed by MFS^® Investment Management

MFS^® New Discovery Series – Service Class

MFS^® Total Return Series – Service Class

TRANSAMERICA SERIES TRUST

Portfolio Construction Manager: Morningstar Associates, LLC

Transamerica Asset Allocation – Conservative VP – Service Class

Transamerica Asset Allocation – Growth VP – Service Class

Transamerica Asset Allocation – Moderate VP – Service Class

Transamerica Asset Allocation – Moderate Growth VP – Service Class

Transamerica International Moderate Growth VP – Service Class

Subadvised by AEGON USA Investment Management, LLC

Transamerica AEGON Active Asset Allocation -Conservative VP – Service Class

Transamerica AEGON Active Asset Allocation -Moderate VP – Service Class

Transamerica AEGON Active Asset Allocation -Moderate Growth VP – Service Class

Transamerica AEGON High Yield Bond VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Efficient Markets VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Index 75 VP – Service Class

Transamerica Index 100 VP – Service Class

Subadvised by Alliance Bernstein L.P.

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Subadvised by BlackRock Financial Management, Inc.

Transamerica BlackRock Tactical Allocation VP – Service Class

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Subadvised by BlackRock Investment Management, LLC

Transamerica BlackRock Large Cap Value VP – Service Class

Subadvised by Foxhall Capital Management, Inc.

Transamerica Foxhall Emerging Markets/Pacific Rim VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Foxhall Global Growth VP – Service Class

Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class

Subadvised by Hanlon Investment Management, Inc.

Transamerica Hanlon Balanced VP – Service Class

Transamerica Hanlon Growth VP – Service Class

Transamerica Hanlon Growth and Income VP – Service Class

Transamerica Hanlon Managed Income VP – Service Class

Subadvised by ING Clarion Real Estate Securities, LLC

Transamerica Clarion Global Real Estate Securities VP – Service Class

Subadvised by J.P. Morgan Investment Management Inc.

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Enhanced Index VP – Service Class

Transamerica JPMorgan Mid Cap Value VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Subadvised by J.P. Morgan Investment Management Inc. and BlackRock Financial Management, Inc.

Transamerica Multi-Managed Balanced VP – Service Class

Subadvised by Jennison Associates LLC

Transamerica Jennison Growth VP– Service Class

Subadvised by MFS^® Investment Management

Transamerica MFS International Equity VP – Service Class

Subadvised by Morgan Stanley Investment Management Inc.

Transamerica Morgan Stanley Active International Allocation VP – Service Class

Transamerica Morgan Stanley Capital Growth VP – Service Class

Transamerica Morgan Stanley Growth Opportunities VP – Service Class

Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class

Transamerica Multi Managed Large Cap Core VP – Service Class

Subadvised by Pacific Investment Management Company LLC

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Subadvised by Systematic Financial Management L.P.

Transamerica Systematic Small/Mid Cap Value VP – Service Class

Subadvised by T. Rowe Price Associates, Inc.

Transamerica T. Rowe Price Small Cap VP – Service Class

Advised by Transamerica Asset Management, Inc.

Transamerica BlackRock Global Allocation VP – Service Class

Subadvised by Wellington Management Company, LLP

Transamerica WMC Diversified Equity VP – Service Class

Transamerica WMC Diversified Growth VP – Service Class

NOTES TO VARIABLE INVESTMENT CHOICES

Some subaccounts may be available for certain policies and may not be available for all policies. You should work with your registered representative to decide which subaccount(s) may be appropriate for you based on a thorough analysis of your particular insurance needs, financial objectives, investment goals, time horizons, and risk tolerance.

There can be no assurance that the Transamerica AEGON Money Market VP – Service Class portfolio will be able to

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maintain a stable net asset value per share. During extended periods of low interest rates, and partly as a result of policy charges, the yield on the Transamerica AEGON Money Market VP – Service Class subaccount may become extremely low and possibly negative.

Transamerica Series Trust – Service Class – As of May 1, 2003, new policyholders may only invest in the Service Class subaccounts. The Initial Class subaccounts are only available to policyholders that purchased the policy before May 1, 2003.

Transamerica AEGON Money Market VP formerly known as Transamerica Money Market VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica AEGON U.S. Government Securities VP formerly known as Transamerica U.S. Government Securities VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica AllianceBernstein Dynamic Allocation VP formerly known as Transamerica Convertible Securities VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica Foxhall Global Commodities & Hard Assets VP was formerly known as Transamerica Foxhall Global Hard Assets VP.

Transamerica Multi-Managed Balanced VP formerly known as Transamerica Balanced VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica Morgan Stanley Capital Growth VP, formerly known as Transamerica Focus and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica Morgan Stanley Growth Opportunities VP formerly known as Transamerica Growth Opportunities VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica Morgan Stanley Mid-Cap Growth VP was formerly subadvised by Van Kampen Asset Management.

Invesco Advisors has been added as a subadviser with Morgan Stanley Investment Management Inc for Transamerica Multi-Managed Large Cap Core VP.

Transamerica Systematic Small/Mid Cap Value VP formerly known as Transamerica Small/Mid Cap Value VP and formerly subadvised by Transamerica Investment Management, LLC.

Transamerica WMC Diversified Equity VP formerly known as Transamerica Diversified Equity VP and formerly subadvised by Transamerica Investment Management, LLC.

The following subaccounts are only available to owners that held an investment in those subaccounts on May 1, 2002. However, if any such owner surrenders all of his or her money from these subaccounts after May 1, 2002, that owner may not reinvest in those subaccounts.

JANUS ASPEN SERIES

Managed by Janus Capital Management LLC

Janus Aspen – Perkins Mid Cap Value Portfolio – Service Shares

FIDELITY^® VARIABLE INSURANCE PRODUCTS FUND

Managed by Fidelity Management & Research Company

Fidelity VIP Growth Opportunities Portfolio – Service Class 2

The following subaccount is only available to owners that held an investment in this subaccount on July 1, 2002. However, if any such owner surrenders all of his or her money from this subaccount after July 1, 2002, that owner may not reinvest in this subaccount.

TRANSAMERICA SERIES TRUST

Subadvised by Transamerica Investment Management, LLC

Transamerica Systematic Small/Mid Cap Value VP – Initial Class

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The general public may not purchase shares of any of these underlying fund portfolios. The names and investment objectives and policies may be similar to other portfolios managed by the same investment advisor or manager that are sold directly to the public. You should not expect the investment results of the underlying fund portfolios to be the same as those of other portfolios.

More detailed information, including an explanation of the portfolios’ fees and investment objectives, may be found in the current prospectuses for the underlying fund portfolios, which accompany this prospectus. You should read the prospectuses for the underlying fund portfolios carefully before you invest.

Selection of Underlying Portfolios

The underlying fund portfolios offered through this product are selected by the Company, and the Company may consider various factors, including, but not limited to, asset class coverage, the strength of the adviser’s or sub-adviser’s reputation and tenure, brand recognition, performance, and the capability and qualification of each investment firm. Another factor that we may consider is whether the underlying fund portfolio or its service providers (e.g., the investment adviser or sub-advisers) or its affiliates will make payments to us or our affiliates. For additional information about these arrangements, see “Revenue We Receive.” We review the portfolios periodically and may remove a portfolio, or limit its availability to new premiums and/or transfers of cash value if we determine that a portfolio no longer satisfies one or more of the selection criteria, and/or if the portfolio has not attracted significant allocations from owners. We have included the Transamerica Series Trust (“TST”) underlying fund portfolios at least in part because they are managed by one of our affiliates, Transamerica Asset Management, Inc. (“TAM”).

We have developed this variable annuity product in cooperation with one or more distributors, and have included certain underlying fund portfolios based on their recommendations; their selection criteria may differ from our selection criteria.

You are responsible for choosing the subaccounts which invest in the underlying fund portfolios, and the amounts allocated to each, that are appropriate for your own individual circumstances and your investment goals, financial situation, and risk tolerance. Because investment risk is borne by you, decisions regarding investment allocations should be carefully considered.

In making your investment selections, we encourage you to thoroughly investigate all of the information regarding the underlying fund portfolios that are available to you, including each underlying fund portfolio’s prospectus, statement of additional information and annual and semi-annual reports. Other sources such as the Fund’s website or newspapers and financial and other magazines provide more current information, including information about any regulatory actions or investigations relating to a Fund or underlying fund portfolio. After you select underlying fund portfolios for your initial premium, you should monitor and periodically re-evaluate your allocations to determine if they are still appropriate.

You bear the risk of any decline in the cash value of your policy resulting from the performance of the underlying fund portfolios you have chosen.

We do not recommend or endorse any particular underlying fund portfolio and we do not provide investment advice.

We do not guarantee that any of the subaccounts will always be available for premium payments, allocations, or transfers. We reserve the right, subject to compliance with applicable law, to make certain changes to the separate account and its investments.

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We reserve the right to add new portfolios [or portfolio classes], close existing portfolios [or portfolio classes], or substitute portfolio shares that are held by any subaccount for shares of a different portfolio. We will not add, delete or substitute any underlying fund portfolio shares attributable to your interest in a subaccount without notice to you and prior approval of the SEC, to the extent required by the 1940 Act or other applicable law.

We reserve the right to limit the number of subaccounts you are invested in at any one time.

Addition, Deletion, or Substitution of Investments

The Company cannot and does not guarantee that any of the subaccounts will always be available for premium payments, allocations, or transfers. The Company retains the right, subject to any applicable law, to make certain changes in the separate account and its investments. The Company reserves the right to eliminate the shares of any portfolio held by a subaccount and to substitute shares of another portfolio of the underlying fund portfolios, or of another registered open-end management investment company for the shares of any portfolio, if the shares of the portfolio are no longer available for investment or if, in the Company’s judgment, investment in any portfolio would be inappropriate in view of the purposes of the separate account. To the extent required by the 1940 Act, as amended, substitutions of shares attributable to your interest in a subaccount will not be made without prior notice to you and the prior approval of the Securities and Exchange Commission (“SEC”). Nothing contained herein shall prevent the separate account from purchasing other securities for other series or classes of variable annuity policies, or from affecting an exchange between series or classes of variable annuity policies on the basis of your requests.

New subaccounts may be established when, in the sole discretion of the Company, marketing, tax, investment or other conditions warrant. Any new subaccounts may be made available to existing owners on a basis to be determined by the Company. Each additional subaccount will purchase shares in a mutual fund portfolio, or other investment vehicle. The Company may also eliminate one or more subaccounts if, in its sole discretion, marketing, tax, investment or other conditions warrant such change. In the event any subaccount is eliminated, the Company will notify you and request a reallocation of the amounts invested in the eliminated subaccount.

Similarly, the Company may, at its discretion, close a subaccount to new investment (either transfers or premium payments). Any amounts that would otherwise be invested in a closed subaccount (for premium allocations, portfolio rebalancing, dollar cost averaging, automatic checking account or payroll deductions for period premiums, etc.) will, if you do not provide instructions for a new allocation be invested in the subaccount that invests in a portfolio of money market instruments. If a portfolio of money market instruments is unavailable, the Company will reinvest the amounts in another subaccount, or in the fixed account, if appropriate.

In the event of any such substitution or change, the Company may, by appropriate endorsement, make such changes in the policies as may be necessary or appropriate to reflect such substitution or change. Furthermore, if deemed to be in the best interests of persons having voting rights under the policies, the separate account may be (1) operated as a management company under the 1940 Act or any other form permitted by law, (2) deregistered under the 1940 Act in the event such registration is no longer required or (3) combined with one or more other separate accounts. To the extent permitted by applicable law, the Company also may (1) transfer the assets of the separate account associated with the policies to another account or accounts, (2) restrict or

30

eliminate any voting rights of owners or other persons who have voting rights as to the separate account, (3) create new separate accounts, (4) add new subaccounts to or remove existing subaccounts from the separate account, or combine subaccounts, or (5) add new underlying fund portfolios, or substitute a new fund for an existing fund.

Static Allocation Models

A Static Allocation Model is an allocation strategy comprised of two or more underlying fund portfolios that together provide a unique allocation mix not available as a single underlying fund portfolio. Policy owners that elect a Static Allocation Model directly own subaccount units of the underlying fund portfolios that comprise a particular model. In other words, a Static Allocation Model is not a group of underlying fund portfolios with one accumulation/annuity unit value, but rather, direct investment in a certain allocation of subaccounts. There is no additional charge associated with investing in a Static Allocation Model.

Each of the Static Allocation Models is just that: static. The allocations or “split” between one or more subaccounts is not monitored and adjusted to reflect changing market conditions. However, a policy owner’s investment in a Static Allocation Model will be rebalanced annually to ensure that the assets are allocated to the percentages in the same proportion that they were allocated at the time of election.

Only one Static Allocation Model may be elected at any one time. Additionally, the entire policy value must be allocated to the elected model.

You may request to transfer from one model to another, or transfer from a model to any other investment option. Each transfer into or out of a Static Allocation Model is considered one transfer.

The Fixed Account

Premium payments allocated and amounts transferred to the fixed account become part of the Company’s general account. Interests in the general account have not been registered under the Securities Act of 1933 (the “1933 Act”), nor is the general account registered as an investment company under the 1940 Act. Accordingly, neither the general account nor any interests therein are generally subject to the provisions of the 1933 or 1940 Acts. Disclosures relating to interests in the general account may, however, be subject to certain generally applicable provisions of the federal securities laws relating to the accuracy of statements made in a registration statement.

While we do not guarantee that the fixed account will always be available for investment, we do guarantee that the interest credited to the fixed account will not be less than the guaranteed minimum effective annual interest rate shown on your policy (the “guaranteed minimum”). We determine credited rates, which are guaranteed for at least one year, in our sole discretion. You bear the risk that we will not credit interest greater than the guaranteed minimum. At the end of the guaranteed period option you selected, the value in that guaranteed period option will automatically be transferred into a new guaranteed period option of the same length (or the next shorter period if the same period is no longer offered) at the current interest rate for that period. You can transfer to another investment choice by giving us notice within 30 days before the end of the expiring guaranteed period.

Full and partial surrenders and transfers from a guaranteed period option of the fixed account are generally subject to an excess interest adjustment (except at the end of the guaranteed period). This adjustment will also be made to amounts that you apply to an annuity payment option. This

31

adjustment may increase or decrease the amount of interest credited to your policy. The excess interest adjustment will not decrease the interest credited to your policy below the guaranteed minimum.

We also guarantee that upon full surrender your cash value attributable to the fixed account will not be less than the amount required by the applicable nonforfeiture law at the time the policy is issued.

If you select the fixed account, your money will be placed with the Company’s other general assets. The amount of money you are able to accumulate in the fixed account during the accumulation phase depends upon the total interest credited. The amount of each annuity payment you receive during the income phase from the fixed portion of your policy will remain level for the entire income phase.

We reserve the right to refuse any premium payment or transfer to the fixed account.

Transfers

During the accumulation phase, you may make transfers to or from any investment choice within certain limitations.

Transfers out of a guaranteed period option of the fixed account are limited to the following:

• Transfers at the end of a guaranteed period. No excess interest adjustment will apply.

• Transfers of amounts equal to interest credited. This may affect your overall interest-crediting rate, because transfers are deemed to come from the oldest premium payment first.

• Other than at the end of a guaranteed period, transfers of amounts from the guaranteed period option in excess of amounts equal to interest credited, are subject to an excess interest adjustment. If it is a negative adjustment, the maximum amount you can transfer in any one policy year is 25% of the amount in that guaranteed period option, less any previous transfers during the current policy year. If it is a positive adjustment, we do not limit the amount that you can transfer.

Each transfer must be at least $500, or the entire subaccount value. Transfers of interest from a guaranteed period option of the fixed account must be at least $50. If less than $500 remains as a result of the transfer, then we reserve the right to include that amount in the transfer. Transfer requests must be received in good order at our Administrative and Service Office while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction.

The number of transfers permitted may be limited and a $10 charge for each transfer in excess of 12 in any policy year may apply. We reserve the right to prohibit transfers to the fixed account.

During the income phase, you may transfer values out of any subaccount; however, you cannot transfer values out of the fixed account. The minimum amount that can be transferred during this phase is the lesser of $10 of monthly income, or the entire monthly income of the annuity units in the subaccount from which the transfer is being made.

Transfers made by telephone are subject to the limitations described below under “Telephone Transactions.”

Market Timing and Disruptive Trading

Statement of Policy. This variable insurance product was not designed for the use of market timers or frequent or disruptive traders. (Frequent transfers are considered to be disruptive.) Such transfers may be harmful to the underlying fund portfolios and increase transaction costs.

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Market timing and disruptive trading among the subaccounts or between the subaccounts and the fixed account can cause risks with adverse effects for other policy owners (and beneficiaries and underlying fund portfolios). These risks and harmful effects include:

(1) dilution of the interests of long-term investors in a subaccount if purchases or transfers into or out of an underlying fund portfolio are made at prices that do not reflect an accurate value for the underlying fund portfolio’s investments (some market timers attempt to do this through methods known as “time-zone arbitrage” and “liquidity arbitrage”);

(2) an adverse effect on portfolio management, such as:

(a) impeding a portfolio manager’s ability to sustain an investment objective;

(b) causing the underlying fund portfolio to maintain a higher level of cash than would otherwise be the case; or

(c) causing an underlying fund portfolio to liquidate investments prematurely (or otherwise at an inopportune time) in order to pay withdrawals or transfers out of the underlying fund portfolio; and

(3) increased brokerage and administrative expenses.

These costs are borne by all policy owners invested in those subaccounts, not just those making the transfers.

We have developed policies and procedures with respect to market timing and disruptive trading (which vary for certain subaccounts at the request of the corresponding underlying fund portfolios) and we do not make special arrangements or grant exceptions to accommodate market timing or potentially disruptive trading. As discussed herein, we cannot detect or deter all market timing or potentially disruptive trading. Do not invest with us if you intend to conduct market timing or potentially disruptive trading.

Detection. We employ various means in an attempt to detect and deter market timing and disruptive trading. However, despite our monitoring we may not be able to detect nor halt all harmful trading. In addition, because other insurance companies (and retirement plans) with different policies and procedures may invest in the underlying fund portfolios, we cannot guarantee that all harmful trading will be detected or that an underlying fund portfolio will not suffer harm from market timing and disruptive trading among subaccounts of variable products issued by these other insurance companies or retirement plans.

Deterrence. If we determine you are engaged in market timing or disruptive trading, we may take one or more actions in an attempt to halt such trading. Your ability to make transfers is subject to modification or restriction if we determine, in our sole opinion, that your exercise of the transfer privilege may disadvantage or potentially harm the rights or interests of other policy owners (or others having an interest in the variable insurance products). As described below, restrictions may take various forms, but under our current policies and procedures will include loss of expedited transfer privileges. We consider transfers by telephone, fax, overnight mail, or the Internet to be “expedited” transfers. This means that we would accept only written transfer requests with an original signature transmitted to us only by U.S. mail. We may also restrict the transfer privileges of others acting on your behalf, including your registered representative or an asset allocation or investment advisory service.

We reserve the right to reject any premium payment or transfer request from any person without prior notice, if, in our judgment, (1) the payment or transfer, or series of transfers, would have a negative impact on an underlying fund portfolio’s operations, or (2) if an underlying fund portfolio would reject or has rejected our purchase order or has instructed us not to allow that purchase or transfer, or (3) because of a history of market timing or disruptive trading.

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We may impose other restrictions on transfers, or even prohibit transfers for any owner who, in our view, has abused, or appears likely to abuse, the transfer privilege on a case-by-case basis. We may, at any time and without prior notice, discontinue transfer privileges, modify our procedures, impose holding period requirements or limit the number, size, frequency, manner, or timing of transfers we permit. Because determining whether to impose any such special restrictions depends on our judgement and discretion, it is possible that some policy owners could engage in disruptive trading that is not permitted for others. We also reserve the right to reverse a potentially harmful transfer if an underlying fund portfolio refuses or reverses our order; in such instances some policy owners may be treated differently than others in that some transfers may be reversed and others allowed. For all of these purposes, we may aggregate two or more variable insurance products that we believe are connected.

Please note: If you engage a third party investment advisor for asset allocation services, then you may be subject to these transfer restrictions because of the actions of your investment advisor in providing these services.

In addition to our internal policies and procedures, we will administer your variable insurance product to comply with any applicable state, federal, and other regulatory requirements concerning transfers. We reserve the right to implement, administer, and charge you for any fee or restriction, including redemption fees, imposed by any underlying fund portfolio. To the extent permitted by law, we also reserve the right to defer the transfer privilege at any time that we are unable to purchase or redeem shares of any of the underlying fund portfolios.

Under our current policies and procedures, we do not:

• impose redemption fees on transfers; or

• expressly limit the number or size of transfers in a given period except for certain subaccounts where an underlying fund portfolio has advised us to prohibit certain transfers that exceed a certain size; or

• provide a certain number of allowable transfers in a given period.

Redemption fees, transfer limits, and other procedures or restrictions may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading.

In the absence of a prophylactic transfer restriction (e.g., expressly limiting the number of trades within a given period or limiting trades by their size), it is likely that some level of market timing and disruptive trading will occur before it is detected and steps taken to deter it (although some level of market timing and disruptive trading can occur even with a prophylactic transfer restriction). As noted above, we do not impose a prophylactic transfer restriction and, therefore, it is likely that some level of market timing and disruptive trading will occur before we are able to detect it and take steps in an attempt to deter it.

Please note that the limits and restrictions described herein are subject to our ability to monitor transfer activity. Our ability to detect market timing or disruptive trading may be limited by operational and technological systems, as well as by our ability to predict strategies employed by policy owners (or those acting on their behalf) to avoid detection. As a result, despite our efforts to prevent harmful trading activity among the variable investment choices available under this variable insurance product, there is no assurance that we will be able to detect or deter market timing or disruptive trading by such policy owners or intermediaries acting on their behalf. Moreover, our ability to discourage and restrict market timing or disruptive trading may be limited by decisions of state regulatory bodies and court orders that we cannot predict.

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Furthermore, we may revise our policies and procedures in our sole discretion at any time and without prior notice, as we deem necessary or appropriate (1) to better detect and deter harmful trading that may adversely affect other policy owners, other persons with material rights under the variable insurance products, or underlying fund shareholders generally, (2) to comply with state or federal regulatory requirements, or (3) to impose additional or alternative restrictions on owners engaging in market timing or disruptive trading among the investment choices under the variable insurance product. In addition, we may not honor transfer requests if any variable investment choice that would be affected by the transfer is unable to purchase or redeem shares of its corresponding underlying fund portfolio.

Underlying Fund Portfolio Frequent Trading Policies. The underlying fund portfolios may have adopted their own policies and procedures with respect to frequent purchases and redemptions of their respective shares. Underlying fund portfolios may, for example, assess a redemption fee (which we reserve the right to collect) on shares held for less than a certain period of time. The prospectuses for the underlying fund portfolios describe any such policies and procedures. The frequent trading policies and procedures of an underlying fund portfolio may be different, and more or less restrictive, than the frequent trading policies and procedures of other underlying fund portfolios and the policies and procedures we have adopted for our variable insurance products to discourage market timing and disruptive trading. Policy owners should be aware that we may not have the contractual ability or the operational capacity to monitor policy owners’ transfer requests and apply the frequent trading policies and procedures of the respective underlying funds that would be affected by the transfers. Accordingly, policy owners and other persons who have material rights under our variable insurance products should assume that any protection they may have against potential harm from market timing and disruptive trading is the protection, if any, provided by the policies and procedures we have adopted for our variable insurance products to discourage market timing and disruptive trading in certain subaccounts.

Policy owners should be aware that we are required to provide to an underlying fund portfolio or its designee, promptly upon request, certain information about the trading activity of individual policy owners, and to restrict or prohibit further purchases or transfers by specific policy owners identified by an underlying fund portfolio as violating the frequent trading policies established for the portfolio.

Omnibus Orders. Policy owners and other persons with material rights under the variable insurance products also should be aware that the purchase and redemption orders received by the underlying fund portfolios generally are “omnibus” orders from intermediaries such as retirement plans and separate accounts funding variable insurance products. The omnibus orders reflect the aggregation and netting of multiple orders from individual retirement plan participants and individual owners of variable insurance products. The omnibus nature of these orders may limit the underlying fund portfolios’ ability to apply their respective frequent trading policies and procedures. We cannot guarantee that the underlying fund portfolios will not be harmed by transfer activity relating to the retirement plans or other insurance companies that may invest in the underlying fund portfolios. These other insurance companies are responsible for their own policies and procedures regarding frequent transfer activity. If their policies and procedures fail to successfully discourage harmful transfer activity, it will affect other owners of underlying fund portfolio shares, as well as the owners of all of the variable annuity or life insurance policies, including ours, whose variable investment choices correspond to the affected underlying fund portfolios. In addition, if an underlying fund portfolio believes that an omnibus order we submit may reflect one or more transfer requests from owners engaged in market timing and

35

disruptive trading, the underlying fund portfolio may reject the entire omnibus order and thereby delay or prevent us from implementing your request.

4. PERFORMANCE

The Company periodically advertises performance of the various subaccounts. Performance figures might not reflect charges for options, riders, or endorsements. We may disclose at least three different kinds of non-standard performance. First, we may calculate performance by determining the percentage change in the value of an accumulation unit by dividing the increase (decrease) for that unit by the value of the accumulation unit at the beginning of the period. This performance number reflects the deduction of the mortality and expense risk fees and administrative charges. It does not reflect the deduction of any applicable premium taxes, surrender charges, or fees for any optional riders or endorsements. Any such deduction would reduce the percentage increase or make greater any percentage decrease.

Second, advertisements may also include total return figures, which reflect the deduction of the mortality and expense risk fees and administrative charges. These figures may also include or exclude surrender charges. These figures may also reflect the premium enhancement, if any.

Third, for certain investment portfolios, performance may be shown for the period commencing from the inception date of the investment portfolio (i.e., before commencement of subaccount operations). These figures should not be interpreted to reflect actual historical performance of the subaccounts.

Not all types of performance data presented reflect all of the fees and charges that may be deducted (such as fees for optional benefits); performance figures would be lower if these charges were included.

5. EXPENSES

Note: The following section on expenses and the Annuity Policy Fee Table and Expense Examples only apply to policies issued after the date of this prospectus. See “Appendix - Policy Variations” for information about older policies.

There are charges and expenses associated with your policy that reduce the return on your investment in the policy.

Surrender Charges

During the accumulation phase, you can surrender part or all of the cash value (restrictions may apply to qualified policies). We may apply a surrender charge to compensate us for expenses relating to sales, including commissions to registered representatives and other promotional expenses.

You can surrender up to the greater of (i) 10% of your premium payments or (ii) any gains in the policy once each year free of surrender charges. This amount is referred to as the free amount and is determined at the time of surrender. (The free amount is not cumulative, so not surrendering anything in one year does not increase the surrender charge free amount in subsequent years.) If the surrender is in excess of this free amount, you might have to pay a surrender charge, which is a contingent deferred sales charge, on the excess amount.

The following schedule shows the surrender charges that apply during the nine years following payment of each premium payment:

Number of Years Since Premium Payment Date	Surrender Charge (as a percentage of premium surrendered)
0 – 1		9	%
1 – 2		8	%
2 – 3		7	%
3 – 4		6	%
4 – 5		5	%

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5 – 6	4	%
6 – 7	3	%
7 – 8	2	%
8 – 9	1	%
more than 9	0	%

For example, assume your premium is $100,000 and your policy value is $106,000 at the beginning of the second policy year and you surrender $30,000. Since that amount is more than your free amount ($10,000), you would pay a surrender charge of $1,600 on the remaining $20,000 [8% of ($30,000 - $10,000)].

Likewise, assume your policy value is $80,000 (premium payments $100,000) at the beginning of the second policy year and you surrender your policy. You would pay a surrender charge of $7,200 [8% of ($100,000 - ($100,000 x 10%))].

You can generally choose to receive the full amount of a requested partial surrender by directing us to deduct any applicable surrender charge (and any applicable excess interest adjustment) from your remaining policy value. You receive your cash value upon full surrender.

For surrender charge purposes, earnings are considered to be surrendered first, then the oldest premium is considered to be surrendered next.

Surrender charges are waived if you surrender money under the Nursing Care and Terminal Condition Withdrawal Option or the Unemployment Waiver.

Keep in mind that surrenders may be taxable and, if made before age 59½, may be subject to a 10% federal penalty tax. For tax purposes, surrenders from nonqualified policies are considered to come from taxable earnings first.

Life with Emergency Cash^® Surrender Charge

If you select the Life with Emergency Cash^® annuity payment option, then you can surrender your policy even after annuity payments have begun. However, there is a surrender charge during the first four years after the annuity commencement date (no matter which policy or variation thereof you previously purchased). The following schedule shows the current surrender charge:

Number of Years Since Annuity Commencement Date	Surrender Charge (as a percentage of adjusted policy value)
0 – 1		4	%
1 – 2		3	%
2 – 3		2	%
3 – 4		1	%
more than 4		0	%

We can change the surrender charge, and you will be subject to whatever surrender schedule is in effect at the time you annuitize under the Life with Emergency Cash^® annuity payment option.

Note carefully the following three things about this surrender charge:

• this surrender charge is measured from the annuity commencement date and not from the premium payment date;

• this surrender charge is a percentage of the adjusted policy value applied to the Life with Emergency Cash^® annuity payment option, and not a percentage of premium; and

• under this payment option, there is no surrender charge free amount.

Excess Interest Adjustment

Surrenders and transfers from the fixed account may be subject to an excess interest adjustment. This adjustment could retroactively reduce the interest credited in the fixed account to the guaranteed minimum or increase the amount credited. This adjustment may also apply to amounts applied to an

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annuity payment option. Please see “Appendix – Excess Interest Adjustment Examples” for an example showing the effect of a hypothetical excess interest adjustment calculation.

Mortality and Expense Risk Fees

We charge a fee as compensation for bearing certain mortality and expense risks under the policy. This fee is assessed daily based on the net asset value of each subaccount. Examples of such risks include a guarantee of annuity rates, the death benefit, certain expenses of the policy, and assuming the risk that the current charges will be insufficient in the future to cover costs of administering the policy. We may also pay distribution expenses out of this charge.

During the accumulation phase:

• For the Return of Premium Death Benefit, the daily mortality and expense risk fee is at an annual rate of 1.50%.

• For the Annual Step-Up Death Benefit, the daily mortality and expense risk fee is at an annual rate of 1.70%.

During the income phase, the mortality and expense risk fee is at an annual rate of 1.10%.

If this charge does not cover our actual costs, we absorb the loss. Conversely, if the charge more than covers actual costs, the excess is added to our surplus. We expect to profit from this charge. We may use any profit for any proper purpose, including distribution expenses.

Premium Taxes

Some states assess premium taxes on the premium payments you make. We currently do not deduct for these taxes at the time you make a premium payment. However, we will deduct the total amount of premium taxes, if any, from the policy value when:

• you begin receiving annuity payments;

• you surrender the policy; or

• a death benefit is paid.

State premium taxes currently range from 0% to 3.50%, depending on the state.

Federal, State and Local Taxes

We may in the future deduct charges from the policy for any taxes we incur because of the policy. However, no deductions are being made at the present time.

Special Service Fees

We will deduct a charge for special services, such as overnight delivery, up to $25 per service provided.

Transfer Fee

You are generally allowed to make 12 free transfers per policy year before the annuity commencement date. If you make more than 12 transfers per year, we reserve the right to charge $10 for each additional transfer. Premium payments, Asset Rebalancing, and Dollar Cost Averaging transfers do not count as one of your free transfers. All transfer requests made at the same time are treated as a single transfer.

Administrative Charges

We deduct a daily administrative charge to cover the costs of administering the policy (including certain distribution-related expenses). This charge is equal to an annual rate of 0.15% of the daily net asset value of each subaccount during both the accumulation phase and the income phase.

In addition, during the accumulation phase, an annual service charge of $35 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.

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Initial Payment Guarantee

If you elect the Initial Payment Guarantee feature at the time of annuitization, there is a fee (during the income phase) currently at an annual rate of 1.25% of the daily net asset value. This fee may be higher or lower at the time you annuitize and elect the feature.

Fund Facilitation Fee

We charge a fund facilitation fee in order to make certain funds available as investment choices under the policies. We apply the fee to funds that do not provide us with the amount of revenue we require in order for us to meet our expenses and revenue targets. This fee is assessed daily based on the net asset value of subaccounts that we specify. The fund facilitation fee, expressed as an annual rate is:

• 0.30% if you choose the American Funds – Asset Allocation Fund – Class 2

• 0.30% if you choose the American Funds – Bond Fund – Class 2

• 0.30% if you choose the American Funds – Growth Fund – Class 2

• 0.30% if you choose the American Funds – Growth-Income Fund – Class 2

• 0.30% if you choose the American Funds – International Fund – Class 2

• 0.20% if you choose the AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

• 0.20% if you choose the GE Investments Total Return Fund – Class 3

• 0.15% if you choose the Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

• 0.10% if you choose the Transamerica BlackRock Global Allocation VP – Service Class

Additional Death Distribution

If you elect the Additional Death Distribution, there is an annual rider fee during the accumulation phase of 0.25% of the policy value. The rider fee will be deducted on each rider anniversary and upon termination of the rider during the accumulation phase. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Additional Death Distribution+

If you elect the Additional Death Distribution+, there is an annual rider fee during the accumulation phase of 0.55% of the policy value. The rider fee will be deducted on each rider anniversary and upon termination of the rider during the accumulation phase. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Living Benefits Rider

If you elect the Living Benefits Rider, there is an annual rider fee of 0.90% of the “principal back” total withdrawal base on each rider anniversary before annuitization. We will also deduct the rider fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice. Generally, the rider fee is deducted even if your policy value exceeds your total withdrawal base.

We will continue to calculate the rider fee using the “principal back” total withdrawal base even after the “principal back” minimum remaining withdrawal amount reaches zero. The “principal back” total withdrawal base is always greater than or equal to the “for life” total withdrawal base.

Retirement Income Choice^® 1.2 Rider and Additional Options Fees

If you elect the Retirement Income Choice^® 1.2 rider, then the rider fee, which is charged quarterly before annuitization, depends on the allocation option that you choose. If you choose the Open Allocation option, then the fee for the base benefit (for either single or joint life) is 1.20% (on an

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annual basis) of the withdrawal base. If you choose the Designated Investment option, then the fee for the base benefit (for single or joint life) is 1.40%, 1.00%, and 0.45% (on an annual basis) of the withdrawal base for allocating 100% of your policy value in Designated Allocation Allocation Group A, Designated Allocation Group B, or Designated Allocation Group C, respectively. If you elect a combination of designated investment options among various classes, then your fee will be based on a weighted average of your choices. If you elect options with the Retirement Income Choice^® 1.2 rider, then for each option you elect, you will be charged a fee that is a percentage of the withdrawal base on each rider quarter before annuitization, and is in addition to the rider fee for the base benefit. The additional fees, on an annual basis, are as follows:

Options	Single Life Option			Joint Life Option
Death Benefit		0.25	%		0.20	%
Income Enhancement Benefit		0.15	%		0.30	%

We will also deduct any rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Retirement Income Choice^® 1.4 Rider and Additional Options Fees - This Rider is No Longer Available for New Sales

If you elect the Retirement Income Choice^® 1.4 rider, then the rider fee, which is charged quarterly before annuitization, is 1.40%, 1.00%, and 0.45% (on an annual basis) of the withdrawal base for allocating 100% of your policy value in Designated Allocation Allocation Group A, Designated Allocation Group B, or Designated Allocation Group C, respectively. If you elect a combination of designated investment options among various classes, then your fee will be based on a weighted average of your choices. If you elect options with the Retirement Income Choice^® 1.4 rider, then for each option you elect, you will be charged a fee that is a percentage of the withdrawal base on each rider quarter before annuitization, and is in addition to the rider fee for the base benefit. The additional fees, on an annual basis, are as follows:

Options	Single Life Option			Joint Life Option
Death Benefit		0.25	%		0.20	%
Income Enhancement Benefit		0.15	%		0.30	%

We will also deduct any rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Income Link^® Rider Fee

If you elect the Income Link^® rider, then the rider fee, which is charged quarterly before annuitization, is 0.90% (on an annual basis) of the withdrawal base.

We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Retirement Income Max^SM Rider Fees

If you elect the Retirement Income Max^SM rider, then the rider fee, which is charged quarterly before annuitization, is 1.00% (on an annual basis) of the withdrawal base. We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

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Portfolio Fees and Expenses

The value of the assets in each subaccount will reflect the fees and expenses paid by the underlying fund portfolios. The lowest and highest fund expenses for the previous calendar year are found in the Annuity Policy Fee Table section of this prospectus. See the prospectuses for the underlying fund portfolios for more information.

Revenue We Receive

This prospectus describes generally the payments that we (and/or our affiliates) may directly or indirectly receive from the underlying fund portfolios, their advisers, subadvisers, distributors or affiliates thereof, in connection with certain administrative, marketing and other support services we (and/or our affiliates) provide and expenses we incur in offering and selling our variable insurance products. These arrangements are sometimes referred to as “revenue sharing” arrangements and are described further below. While only certain of the types of payments described below may be made in connection with your particular policy, all such payments may nonetheless influence or impact actions we (and/or our affiliates) take, and recommendations we (and our affiliates) make, regarding each of the variable insurance products that we (and our affiliates) offer, including your policy.

We (and/or our affiliates) may receive some or all of the following types of payments:

• Rule 12b-1 Fees. Our affiliate Transamerica Capital, Inc. (“TCI”) is the principal underwriter for the policies and directly or indirectly receives some or all of the 12b-1 fees from the funds available as investment choices under our variable insurance products. Any 12b-1 fees received by TCI that are attributable to our variable insurance products are then credited to us. These fees range from 0.00% to 0.25% of the average daily assets of the certain underlying fund portfolios attributable to the policies and to certain other variable insurance products that we and our affiliates issue.

• Administrative, Marketing and Support Service Fees (“Support Fees”). As noted above, an investment adviser, sub-adviser, administrator and/or distributor (or affiliates thereof) of the underlying fund portfolios may make payments to us and/or our affiliates, including TCI. These payments may be derived, in whole or in part, from the profits the investment advisor or sub-adviser realized on the advisory fee deducted from underlying fund portfolio assets. Policy owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees (see the prospectuses for the underlying funds for more information). The amount of the payments we (or our affiliates) receive is generally based on a percentage of the assets of the particular underlying fund portfolios attributable to the policy and to certain other variable insurance products that our affiliates and we issue. These percentages differ and the amounts may be significant. Some advisers or sub-advisers (or other affiliates) pay us more than others.

The following chart provides the maximum combined percentages of 12b-1 fees and Support Fees that we anticipate will be paid to us on an annual basis. Please note: Some of the underlying funds listed in the chart below may not currently be available under your policy:

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Incoming Payments to the Company and/or TCI

Fund	Maximum Fee % of assets
TRANSAMERICA SERIES TRUST		0.25	%
AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS)		0.50	%
ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.		0.45	%
AMERICAN FUNDS INSURANCE SERIES® TRUST		0.25	%
FIDELITY® VARIABLE INSURANCE PRODUCTS FUND		0.35	%
FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST		0.50	%
GE INVESTMENTS FUNDS, INC.		0.45	%
JANUS ASPEN SERIES		0.35	%
MFS® VARIABLE INSURANCE TRUST		0.45	%

NOTES TO INCOMING PAYMENTS TABLE:

Maximum Fee % of assets: Payments are based on a percentage of the average assets of each underlying fund portfolio owned by the subaccounts available under this policy and under certain other variable insurance products offered by our affiliates and us. We and/or TCI may continue to receive 12b-1 fees and administrative fees on subaccounts that are closed to new investments, depending on the terms of the agreements supporting those payments and on the services we and TCI provide.

Transamerica Series Trust (“TST”): Because TST is managed by Transamerica Asset Management, Inc. (“TAM”), an affiliate of ours, there are additional benefits to us and our affiliates for amounts you allocate to the TST underlying fund portfolios, in terms of our and our affiliates’ overall profitability. These additional benefits may be significant. Payments or other benefits may be received from TAM. Such payments or benefits may be entered into for a variety of purposes, such as to allocate resources to us to provide administrative services to the policyholders who invest in the TST underlying fund portfolios. These payments or benefits may take the form of internal credits, recognition, or cash payments. A variety of financial and accounting methods may be used to allocate resources and profits to us. Additionally, if a TST portfolio is sub-advised by an entity that is affiliated with us, we may retain more revenue than on those TST portfolios that are sub-advised by non-affiliated entities. During 2010 we received $72,069,379 in benefits from TAM pursuant to these arrangements. This includes the 0.25% amount in the above chart. We anticipate receiving comparable amounts in the future.

Fidelity^® Variable Insurance Products Fund: We receive this percentage once $100 million in fund shares are held by the subaccounts of the Company and its affiliates.

• Other Payments. TCI also serves as the wholesale distributor for the policies, and in that capacity directly or indirectly receives additional amounts or different percentages of assets under management from certain advisers and sub-advisers to the underlying fund portfolios (or their affiliates) with regard to variable insurance products and/or mutual funds that are issued by us and our affiliates. These amounts may be derived, in whole or in part, from the profits the investment adviser or sub-adviser receives from the advisory fee deducted from underlying fund portfolio assets. Policy owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees. Certain advisers and sub-advisers of the underlying fund portfolios (or their affiliates):

• may each directly or indirectly pay TCI amounts up to $75,000 per year to participate in a “preferred sponsor” program that provides such advisers and sub-advisers with access to TCI’s wholesalers at TCI’s national and regional sales conferences as well as internal and external meetings and events that are attended by TCI’s wholesalers and/or other TCI employees.

• may provide our affiliates and/or selling firms with wholesaling services to assist us in the distribution of the policies.

• may provide us and/or certain affiliates and/or selling firms with occasional gifts, meals, tickets or other compensation as an incentive to market the underlying fund portfolios and to assist with their promotional efforts. The amounts may be significant and these arrangements provide the adviser or subadviser (or other affiliates) with increased access to us and to our affiliates involved in the distribution of the policies.

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For the calendar year ended December 31, 2010, TCI or its affiliates received total revenue sharing payments in the amount of $1,769,559 from the following Fund managers and/or sub-advisers to participate in TCI’s events: Alliance Bernstein Investments, American Funds, BlackRock Investment Management, LLC., BNY Melon, , Federated Equity Management Co, of PA, Fidelity Investments, Foxhall Capital Management, Franklin Templeton Investments, GE Asset Management, Hanlon Investment Management Inc., ING Clarion Real Estate Securities, Invesco AIM, Janus Capital, Jennison Associates, JPMorgan Investment Management, Loomis, Sayles & Company, MFS Investment Management, Neuberger Berman Management, Oppenheimer Funds, Pacific Investment Management Company, Putnam, Schroder Investment Management North America, Transamerica Investment Management, Van Kampen Investments, Vanguard, Wellington Management Company. Please note some of the aforementioned managers and/or subadvisors may not be associated with underlying fund portfolios currently available in this product.

Proceeds from certain of these payments by the underlying fund portfolios, the advisers, the sub-advisers and/or their affiliates may be used for any corporate purpose, including payment of expenses (1) that we and our affiliates incur in promoting, marketing, and administering the policy, and (2) that we incur, in our role as intermediary, in promoting, marketing, and administering the underlying fund portfolios. We and our affiliates may profit from these payments.

For further details about the compensation payments we make in connection with the sale of the policies, see “Distribution of the Policies” in this prospectus.

6. ACCESS TO YOUR MONEY

During the accumulation phase, you can have access to the money in your policy in the following ways:

• by making a surrender (either a full or partial surrender); or

• by taking systematic payouts (See “Section 10, Systematic Payout Option” for more details).

Surrenders

If you take a full surrender, you will receive your cash value.

If you want to take a partial surrender, in most cases it must be for at least $500. Unless you tell us otherwise, we will take the surrender from each of the investment choices in proportion to the policy value.

You may elect to take up to the free amount once each policy year without incurring a surrender charge. Remember that any surrender you take will reduce the policy value, and the amount of the death benefit. See “Section 8, Death Benefit”, for more details. A partial surrender also may have a negative impact on certain other benefits and guarantees of your Contract.

Surrenders from qualified policies may be restricted or prohibited.

Surrenders may be subject to a surrender charge. Surrenders from the fixed account may be subject to an excess interest adjustment. Income taxes, federal tax penalties and certain restrictions may apply to any surrenders you make.

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During the income phase, you will receive annuity payments under the annuity payment option you select; however, you generally may not take any other surrenders, either full or partial, unless you elect a Life with Emergency Cash^® payment option.

If your policy was issued pursuant to a 403(b) plan, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders, loans or transfers you request comply with applicable tax requirements and to decline requests that are not in compliance. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender, loan or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) contracts or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Delay of Payment and Transfers

Payment of any amount due from the separate account for a surrender, a death benefit, or the death of the owner of a nonqualified policy, will generally occur within seven days from the date we receive in good order all required information at our Administrative and Service Office. We may defer such payment from the separate account if:

• the New York Stock Exchange is closed other than for usual weekends or holidays or trading on the Exchange is otherwise restricted;

• an emergency exists as defined by the SEC or the SEC requires that trading be restricted; or

• the SEC permits a delay for the protection of owners.

Transfers of amounts from the subaccounts also may be deferred under these circumstances. In addition, if, pursuant to SEC rules, the Transamerica AEGON Money Market VP portfolio suspends payment of redemption proceeds in connection with a liquidation of the portfolio, then we may delay payment of any transfer, partial withdrawal, surrender, loan, or death benefit from the Transamerica AEGON Money Market VP portfolio until the portfolio is liquidated.

Any payment or transfer request which is not in good order will cause a delay.

Federal laws designed to counter terrorism and prevent money laundering by criminals might in certain circumstances require us to reject a premium payment and/or “freeze” a policy owner’s account. If these laws apply in a particular situation, we would not be allowed to pay any request for withdrawals, surrenders, or death benefits, make transfers, or continue making annuity payments absent instructions from the appropriate federal regulator. We may also be required to provide information about you and your policy to government agencies or departments.

Pursuant to the requirements of certain state laws, we reserve the right to defer payment of the cash value from the fixed account for up to six months. We may defer payment of any amount until your premium payment check has cleared your bank.

Excess Interest Adjustment

Money that you transfer out of or surrender from a guaranteed period option of the fixed account before the end of its guaranteed period (the number of years you specified the money would remain in the guaranteed period option) may be subject to an excess interest adjustment. At the time you request a transfer or surrender (either full or partial), if interest rates set by the Company have risen since the date of the initial guarantee, the excess interest adjustment will result in a lower cash value on surrender or transfer. However, if interest rates have fallen since the date of the initial guarantee, the excess interest adjustment will result in a higher cash value on surrender or transfer. Please see “Appendix - Excess

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Interest Adjustment Examples” to see how the excess interest adjustment is calculated and illustrative examples using hypothetical values.

Any amount surrendered in excess of the cumulative interest credited is generally subject to an excess interest adjustment. An excess interest adjustment may also be made on amounts applied to an annuity payment option.

There will be no excess interest adjustment on any of the following:

• surrenders of cumulative interest credited;

• Nursing Care and Terminal Condition Withdrawal Option surrenders;

• Unemployment Waiver surrenders;

• surrenders to satisfy any minimum distribution requirements; and

• Systematic Payout Option payments, which do not exceed cumulative interest credited at the time of payment.

Please note that in these circumstances you will not receive a higher cash value if interest rates have fallen nor will you receive a lower cash value if interest rates have risen.

The excess interest adjustment may vary for certain policies and may not be applicable for all policies.

Signature Guarantee

As a protection against fraud, we require a signature guarantee (i.e., Medallion Signature Guarantee or Notary Public Stamp as required by us) for the following transaction requests:

• Any surrenders over $250,000;

• Certain surrenders on or within 15 days of an address change;

• Any disbursement request made on or within 15 days of an ownership change;

• Any surrender when the Company has been directed to send proceeds to a different personal address from the address of record for that contract owner’s account. PLEASE NOTE: This requirement will not apply to requests made in connection with exchanges of one annuity for another with the same owner in a “tax-free exchange”;

• Any surrender when the Company does not have an originating or guaranteed signature on file;

• Any other transaction where we require.

We may change the specific requirements listed above, or add signature guarantees in other circumstances, in our discretion if we deem it necessary or appropriate to help protect against fraud. For current requirements, please refer to the requirements listed on the appropriate form or call us at (800) 552-6205.

You can obtain a Medallion signature guarantee from more than 7,000 financial institutions across the United States and Canada that participate in a Medallion signature guarantee program. This includes many:

• National and state banks;

• Savings banks and savings and loan associations;

• Securities brokers and dealers; and

• Credit Unions.

The best source of a Medallion signature guarantee is a bank, savings and loan association, brokerage firm, or credit union with which you do business. Guarantor firms may, but frequently do not, charge a fee for their services.

A notary public cannot provide a Medallion signature guarantee. Notarization will not substitute for a Medallion signature guarantee.

7. ANNUITY PAYMENTS (THE INCOME PHASE)

You choose the annuity commencement date. You can change this date by giving us notice with the information we need. New annuity commencement

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dates less than 30 days after we receive notice of the change require prior approval. The latest maximum annuity commencement date generally cannot be after the policy month following the month in which the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy.

Before the annuity commencement date, if the annuitant is alive, you may choose an annuity payment option or change your election. If the annuitant dies before the annuity commencement date, the death benefit is payable in a lump sum or under one of the annuity payment options (unless the surviving spouse continues the policy).

Unless you specify otherwise, the annuitant will receive the annuity payments. After the annuitant’s death, the beneficiary you designate at annuitization will receive any remaining guaranteed payments.

Annuity Payment Options

The policy provides several annuity payment options that are described below. You may choose any combination of annuity payment options. We will use your adjusted policy value to provide these annuity payments. If the adjusted policy value on the annuity commencement date is less than $2,000, we reserve the right to pay it in one lump sum in lieu of applying it under an annuity payment option. You can receive annuity payments monthly, quarterly, semi-annually, or annually. (We reserve the right to change the frequency if payments would be less than $50.)

If you choose to receive fixed payments, then the amount of each payment will be set on the annuity commencement date and will not change. You may, however, choose to receive variable payments. The dollar amount of the first variable payment will be determined in accordance with the annuity payment rates set forth in the applicable table contained in the policy. The dollar amount of additional variable payments will vary based on the investment performance of the subaccount(s) you select. The dollar amount of each variable payment after the first may increase, decrease, or remain constant. If the actual investment performance (net of fees and expenses) exactly matched the assumed investment return of 5% at all times, the amount of each variable annuity payment would remain constant. If actual investment performance (net of fees and expenses) exceeds the assumed investment return, the amount of the variable annuity payments would increase. Conversely, if actual investment performance (net of fees and expenses) is lower than the assumed investment return, the amount of the variable annuity payments would decrease. Please note that these changes only occur annually under the Initial Payment Guarantee.

A charge for premium taxes and an excess interest adjustment may be made when annuity payments begin.

The annuity payment options are explained below. Some options are fixed only and some can be fixed or variable.

Income for a Specified Period (fixed only). We will make level payments only for a fixed period. No funds will remain at the end of the period.

If your policy is a qualified policy, this payment option may not satisfy minimum required distribution rules. Consult a tax advisor before electing this option.

Income of a Specified Amount (fixed only). Payments are made for any specified amount until the amount applied to this option, with interest, is exhausted. This will be a series of level payments followed by a smaller final payment.

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If your policy is a qualified policy, this payment option may not satisfy minimum required distribution rules. Consult a tax advisor before electing this option.

Life Income. You may choose between:

• No Period Certain (fixed or variable)-Payments will be made only during the annuitant’s lifetime.

• 10 Years Certain (fixed or variable)-Payments will be made for the longer of the annuitant’s lifetime or ten years.

• Guaranteed Return of Policy Proceeds (fixed only)-Payments will be made for the longer of the annuitant’s lifetime or until the total dollar amount of payments we made to you equals the annuitized amount.

• Life with Emergency Cash^® (fixed or variable)-Payments will be made during the annuitant’s lifetime. With the Life with Emergency Cash^® feature, you are able to surrender all or a portion of the Life with Emergency Cash^® benefit. The amount you surrender must be at least $2,500. We will provide you with a Life with Emergency Cash^® benefit schedule that will assist you in estimating the amount you have available to surrender. A partial surrender will reduce all future payments pro rata. A surrender charge may apply and there may be tax consequences (consult a tax advisor before requesting a full or partial surrender). The maximum surrender charge is 4% of the annuitized amount (see “Expenses” for the surrender charge schedule). You will be subject to whatever surrender schedule is in effect at the time you annuitize under this annuity payment option. The Life with Emergency Cash^® benefit will continue through age 100 of the annuitant.

The Life with Emergency Cash^® benefit is also a death benefit that is paid upon the death of the annuitant and is generally equal to the surrender value without any surrender charges. For qualified policies the death benefit ceases on the date the annuitant reaches the IRS age limitation.

Joint and Survivor Annuity. You may choose:

• No Period Certain (fixed or variable)-Payments are made during the joint lifetime of the annuitant and a joint annuitant of your selection. Payments will be made as long as either person is living.

• Life with Emergency Cash^® (fixed or variable)-Payments will be made during the joint lifetime of the annuitant and a joint annuitant of your selection. Payments will be made as long as either person is living. With the Life with Emergency Cash^® feature, you are able to surrender all or a portion of the Life with Emergency Cash^® benefit. The amount you surrender must be at least $2,500. We will provide you with a Life with Emergency Cash^® benefit schedule that will assist you in estimating the amount you have available to surrender. A partial surrender will reduce all future payments pro rata. A surrender charge may apply and there may be tax consequences (consult a tax advisor before requesting a full or partial surrender). The maximum surrender charge is 4% of the annuitized amount (see “Expenses” for the surrender charge schedule). You will be subject to whatever surrender schedule is in effect at the time you annuitize under this annuity payment option. The Life with Emergency Cash^® benefit will continue through age 100 of the surviving joint annuitant.

The Life with Emergency Cash^® benefit is also a death benefit that is paid upon the death of the surviving joint annuitant and is generally equal to the surrender value without any surrender charges. For qualified policies the death benefit ceases on the date the surviving joint annuitant reaches the IRS joint age limitation.

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Other annuity payment options may be arranged by agreement with the Company. Some annuity payment options may not be available for all policies.

NOTE CAREFULLY

IF:

• you choose Life Income with No Period Certain or a Joint and Survivor Annuity with No Period Certain; and

• the annuitant dies (or both joint annuitants die) before the due date of the second (third, fourth, etc.) annuity payment;

THEN:

• we may make only one (two, three, etc.) annuity payments.

IF:

• you choose Income for a Specified Period, Life Income with 10 Years Certain, Life Income with Guaranteed Return of Policy Proceeds, or Income of a Specified Amount; and

• the person receiving payments dies prior to the end of the guaranteed period;

THEN:

• the remaining guaranteed payments will be continued to a new payee, or their present value may be paid in a single sum.

However, IF:

• you choose Life with Emergency Cash^® ; and

• the annuitant dies (if both joint annuitants die) before age 101;

THEN:

• a Life with Emergency Cash^® death benefit will be paid.

We will not pay interest on amounts represented by uncashed annuity payment checks if the postal or other delivery service is unable to deliver checks to the payee’s address of record. The person receiving payments is responsible for keeping the Company informed of his/her current address.

You must annuitize your policy no later than the maximum annuity commencement date specified in your policy (earlier for certain distribution channels). If you do not elect an annuity payment option, the default option will be Life with 10 Years Certain option. Please note, all optional benefits (including guaranteed minimum death benefits and living benefits) terminate upon annuitization.

8. DEATH BENEFIT

We will pay a death benefit to your beneficiary, under certain circumstances, if the annuitant dies during the accumulation phase. If there is a surviving owner(s) when the annuitant dies, the surviving owner(s) will receive the death benefit instead of the listed beneficiary. The person receiving the death benefit may choose an annuity payment option, or may choose to receive a lump sum.

We will determine the amount of and pay the death benefit proceeds, if any are payable on a policy, upon receipt at our Administrative and Service Office of satisfactory proof of the annuitant’s death, written directions from each eligible recipient of death benefit proceeds regarding how to pay the death benefit, and any other documents, forms and information that we need (collectively referred to as “due proof of death”).

Please Note: Such due proof of death must be submitted in good order to avoid a delay in processing the death benefit claim.

The death benefit proceeds remain invested in the separate account in accordance with the allocations made by the policy owner until the beneficiary has provided us with due proof of death. Once the Company receives due proof of death, then investments in the separate account may be reallocated in accordance with the beneficiary’s instructions. The Company may permit the beneficiary to give a “one-time” instruction to reallocate the investments in the separate account to

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the money market fund after the death of the annuitant but before receiving due proof of death. If there is more than one beneficiary, all beneficiaries must agree to the reallocation instructions.

When We Pay A Death Benefit

We will pay a death benefit IF:

• you are both the annuitant and sole owner of the policy; and

• you die before the annuity commencement date.

We will pay a death benefit to you (owner) IF:

• you are not the annuitant; and

• the annuitant dies before the annuity commencement date.

If the only person receiving the death benefit is the surviving spouse, then he or she may elect to continue the policy as the new annuitant and owner, instead of receiving the death benefit. All surrender charges will be waived.

When We Do Not Pay A Death Benefit

We will not pay a death benefit IF:

• you are not the annuitant; and

• you die prior to the annuity commencement date.

Please note the new owner (unless it is the deceased owner’s spouse) must generally surrender the policy within five years of your death.

Distribution requirements apply to the policy value upon the death of any owner. These distribution requirements are detailed in the SAI.

Deaths After the Annuity Commencement Date

The death benefit payable, if any, on or after the annuity commencement date depends on the annuity payment option selected.

IF:

• you are not the annuitant; and

• you die on or after the annuity commencement date; and

• the entire interest in the policy has not been paid;

THEN:

• the remaining portion of such interest in the policy will continue to be distributed at least as rapidly as under the method of distribution being used as of the date of your death.

IF:

• annuity payments are being made under the Life with Emergency Cash^®; and

• the annuitant dies before age 101 (or earlier, if a qualified policy);

THEN:

• a Life with Emergency Cash^® death benefit will be paid.

Succession of Ownership

If an owner dies during the accumulation phase, the person or entity first listed below who is alive or in existence on the date of that death will become the new owner:

• any surviving owner;

• primary beneficiary;

• contingent beneficiary; or

• owner’s estate.

Amount of Death Benefit

Death benefit provisions may differ from state to state. The death benefit may be paid as a lump sum or as annuity payments. The amount of the death benefit depends on the guaranteed minimum death benefit option, if any, you choose when you buy the policy. The “base policy” death benefit will generally be the greatest of:

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• the policy value on the date we receive the required information in good order at our Administrative and Service Office;

• the cash value on the date we receive the required information in good order at our Administrative and Service Office (this will be more than the policy value if there is a positive excess interest adjustment);

• and the guaranteed minimum death benefit (discussed below), plus premium payments (after the date of death), less adjusted partial surrenders, from the date of death to the date the death benefit is paid. Please see “Appendix - Death Benefit” for illustrative examples regarding Death Benefit calculations.

Please note, the death benefit terminates upon annuitization and there is a maximum annuity commencement date.

Guaranteed Minimum Death Benefit

NOTE: The following generally applies, depending on the state of issue, to policies issued after the date of this prospectus. See “Appendix - Policy Variations” for information about older policies.

Annual Step-Up Death Benefit

Under this option, on each policy anniversary prior to your 81st birthday, a new “stepped-up” death benefit is determined and becomes the guaranteed minimum death benefit for that policy year. This “step-up” death benefit is equal to:

• the largest policy value on the policy date or on any policy anniversary prior to the earlier of the annuitant’s date of death or the annuitant’s 81st birthday; plus

• any premium payments since the date of any policy anniversary with the largest policy value; minus

• any adjusted partial surrenders since the date of the policy anniversary with the largest policy value.

The Annual Step-Up Death Benefit is not available if you or the annuitant is 76 or older on the policy date. There is an extra charge for this death benefit of 0.20% annually.

Return of Premium Death Benefit

The Return of Premium Death Benefit is equal to:

• total premium payments; less

• any adjusted partial surrenders as of the date of death.

This benefit is not available if you or the annuitant is 91 or older on the policy date. The Return of Premium Death Benefit will be in effect if you do not choose another death benefit option when you purchase your policy.

Please note: You will not receive an optional guaranteed minimum death benefit if you do not choose one when you purchase your policy.

The Guaranteed Minimum Death Benefit may vary for certain policies and may not be available for all policies. This disclosure explains the material features of the Guaranteed Minimum Death Benefit. The application and operation of the Guaranteed Minimum Death Benefit are governed by the terms and conditions of the policy form and riders.

Adjusted Partial Surrender

When you request a partial surrender, your guaranteed minimum death benefit will be reduced by an amount called the adjusted partial surrender. Under certain circumstances, the adjusted partial surrender may be more than the dollar amount of your surrender request. This will generally be the case if the guaranteed minimum death benefit exceeds the policy value at the time of surrender. It is also

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possible that if a death benefit is paid after you have made a partial surrender, then the total amount paid could be less than the total premium payments. We have included a detailed explanation of this adjustment in the “Appendix - Death Benefit.” This is referred to as “adjusted partial surrender” in your policy. If you have a qualified policy, minimum required distributions rules may require you to request a partial surrender.

9. TAXES

NOTE: We have prepared the following information on federal income taxes as a general discussion of the subject. It is not intended as tax advice to any individual. No attempt is made to consider any applicable state or other income tax laws, any state and local estate or inheritance tax, or other tax consequences of ownership or receipt of distributions under the policy. You should consult your own tax adviser about your own circumstances. We have included an additional discussion regarding taxes in the SAI.

Annuity Policies in General

Deferred annuity policies are a way of setting aside money for future needs like retirement. Congress recognized how important saving for retirement is and provided special rules in the Internal Revenue Code for annuities.

Simply stated, these rules generally provide that individuals will not be taxed on the earnings, if any, on the money held in an annuity policy until taken out. This is referred to as tax deferral. When a non-natural person (e.g., corporation or certain other entities other than tax-qualified trusts) owns a nonqualified policy, the policy will generally not be treated as an annuity for tax purposes.

There are different rules as to how you will be taxed depending on how you take the money out and the type of policy-qualified or nonqualified.

You will generally not be taxed on increases in the value of your policy until a distribution occurs (either as a surrender or as annuity payments).

Qualified and Nonqualified Policies

If you purchase the policy under an individual retirement annuity, a 403(b) plan, a pension plan, or specially sponsored program, your policy is referred to as a qualified policy.

Qualified policies are issued in connection with the following:

• Individual Retirement Annuity (IRA): A traditional IRA allows individuals to make contributions, which may be deductible, to the policy. A Roth IRA also allows individuals to make contributions to the policy, but it does not allow a deduction for contributions, and distributions may be tax-free if the owner meets certain rules.

• Tax-Sheltered Annuity (403(b) Plan): A 403(b) Plan may be made available to employees of certain public school systems and tax-exempt organizations and permits contributions to the policy on a pre-tax basis. Pursuant to new tax regulations, starting January 1, 2009 the policy is not available for purchase under a 403(b) plan and we do not accept additional premiums or transfers to existing 403(b) policies. We generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders, loans or transfers you request from an existing 403(b) policy comply with applicable tax requirements before we process your request.

• Corporate Pension and Profit-Sharing and H.R. 10 Plan: Employers and self-employed individuals can establish pension or profit-sharing plans for their employees or themselves and make contributions to the policy on a pre-tax basis.

• Deferred Compensation Plan (457 Plan): Certain governmental and tax-exempt

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organizations can establish a plan to defer compensation on behalf of their employees through contributions to the policy.

There is no additional tax deferral benefit derived from placing qualified funds into a variable annuity. Features other than tax deferral should be considered in the purchase of a qualified policy. There are limits on the amount of contributions you can make to a qualified policy. Other restrictions may apply including terms of the plan in which you participate.

Optional death benefit features in some cases may exceed the greater of the premium payments or the policy value. Such a death benefit could be characterized as an incidental benefit, the amount of which is limited in any pension or profit-sharing plan or 403(b) plan. Because an optional death benefit may exceed this limitation, anyone using the policy in connection with such plans should consult their tax adviser before purchasing an optional death benefit. The Internal Revenue Service has not reviewed the policy for qualification as an IRA, and has not addressed in a ruling of general applicability whether the death benefit options and riders available, with the policy, if any, comport with IRA qualification requirements. The value of death benefit options and riders elected may need to be considered in calculating minimum required distributions.

If you purchase the policy as an individual and not under an individual retirement annuity, 403(b) plan, 457 plan, or pension or profit sharing plan, your policy is referred to as a nonqualified policy.

Surrenders-Qualified Policies Generally

There are special rules that govern qualified policies. Generally, these rules restrict:

• the amount that can be contributed to the policy during any year;

• the time when amounts can be paid from the policy; and

• the amount of any death benefit that may be allowed.

In the case of a withdrawal under a qualified policy, a pro rata portion of the amount you receive is taxable, generally based on the ratio of your “investment in the contract” to your total account balance or accrued benefit under the retirement plan. Your “investment in the contract” generally equals the amount of any non-deductible purchase payments made by you or on your behalf. In some cases, your “investment in the contract” can be zero.

In addition, a penalty tax may be assessed on amounts surrendered from the policy prior to the date you reach age 59 ¹/2, unless you meet one of the exceptions to this rule. You may also be required to begin taking minimum distributions from the policy by a certain date. The terms of the plan may limit the rights otherwise available to you under the policy. We have provided more information in the SAI.

We may make available under the policy certain guaranteed lifetime withdrawal and other optional benefits. The tax rules for qualified policies may limit the value of these optional benefits. For example, if you elect a guaranteed lifetime withdrawal benefit and your minimum required distribution amount exceeds your guaranteed withdrawal amount, you will have to withdraw more than the guaranteed withdrawal amount to avoid imposition of a 50% excise tax. It is not clear whether guaranteed lifetime withdrawal benefit payments made during the settlement phase will be taxed as withdrawals or as annuity payments. In view of this uncertainty, we will apply the non-annuity rules for determining minimum required distributions, meaning that a percentage of the value of all benefits under the policy will need to be withdrawn each year. The value may have to include the value of enhanced death benefits and other optional policy provisions such as the guaranteed lifetime withdrawal benefit rider itself.

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If you are attempting to satisfy minimum required distribution rules through partial surrenders, the value of any enhanced death benefit or other optional rider may need to be included in calculating the amount required to be distributed.

The Internal Revenue Code generally requires that interests in a qualified policy be nonforfeitable. If your policy contains a bonus rider with a recapture, forfeiture, or “vesting” feature, it may not be consistent with those requirements. Consult a tax advisor before purchasing a bonus rider as part of a qualified policy.

You should consult your legal counsel or tax adviser if you are considering purchasing an enhanced death benefit or other optional rider, or if you are considering purchasing a policy for use with any qualified retirement plan or arrangement.

Surrenders-403(b) Policies

The rules described above for qualified policies generally apply to 403(b) policies. However, specific rules apply to surrenders from certain 403(b) policies. Partial withdrawals and surrenders can generally only be made when an owner:

• reaches age 59 ¹/2;

• leaves his/her job;

• dies;

• becomes disabled (as that term is defined in the Internal Revenue Code); or

• declares hardship. However, in the case of hardship, the owner can only surrender the premium payments and not any earnings.

Please Note: In some instances the signature of the employer may be required. For policies issued after 2008, amounts attributable to nonelective contributions may be subject to distribution restrictions specified in the employer’s section 403(b) plan.

Pursuant to new tax regulations, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders or transfers you request from a 403(b) policy comply with applicable tax requirements before we process your request. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) policies or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Defaulted loans from Code Section 403(b) arrangements, and pledges and assignments of qualified policies generally are taxed in the same manner as surrenders from such policies. Please refer to the SAI for further information applicable to distributions from 403(b) policies. Please note that a defaulted loan may stop the growth on a guaranteed lifetime withdrawal benefit.

Surrenders-Nonqualified Policies

The information above describing the taxation of qualified policies does not apply to nonqualified policies. If you take a partial withdrawal or surrender (including systematic payouts and payouts under an optional feature, if any) from a nonqualified policy before the annuity commencement date, the Internal Revenue Code treats that surrender as first coming from earnings and then from your premium payments. If your policy contains an excess interest adjustment feature (also known as a market value adjustment), then your account value immediately before the surrender may have to be increased by any positive excess interest adjustments that result from the surrender. There is, however, no definitive guidance on the proper tax treatment of excess interest adjustments, and you may want to discuss the potential tax consequences of an excess interest adjustment with your tax advisor.

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When you make a surrender you are taxed on the amount of the surrender that is earnings. If you make a surrender, you are generally taxed on the amount that your surrender proceeds exceeds the “investment in the contract,” which is generally your premiums paid (adjusted for any prior surrenders or portions thereof that were not taxable). In general, loans, pledges, and assignments are taxed in the same manner as partial withdrawals and surrenders. Different rules apply for annuity payments. See “Annuity Payments” below.

The Internal Revenue Code also provides that surrendered earnings may be subject to a penalty tax. The amount of the penalty tax is equal to 10% of the amount that is includable in income. Some surrenders will be exempt from the penalty tax. They include, among others, any amounts:

• paid on or after the taxpayer reaches age 59 ¹/2;

• paid after an owner dies;

• paid if the taxpayer becomes disabled (as that term is defined in the Internal Revenue Code);

• paid in a series of substantially equal payments made annually (or more frequently) under a lifetime annuity;

• paid under an immediate annuity; or

• which come from premium payments made prior to August 14, 1982.

If your nonqualified policy contains a guaranteed lifetime withdrawal benefit rider, certain rules may apply. It is not clear whether guaranteed lifetime withdrawal benefit payments made during the settlement or income (payout) phase may be taxed as either withdrawals or annuities. In view of this uncertainty, we intend to adopt a conservative approach and treat guaranteed lifetime withdrawal payments during the settlement phase under nonqualified policies as withdrawals. Consult a tax advisor before purchasing a guaranteed lifetime withdrawal benefit rider or option.

All nonqualified deferred annuity policies that are issued by us (or our affiliates) to the same owner during any calendar year are treated as one annuity for purposes of determining the amount includable in the owner’s income when a taxable distribution occurs.

Taxation of Death Benefit Proceeds

Amounts may be distributed from the policy because of the death of the annuitant. Generally, such amounts should be includable in the income of the recipient:

• if distributed in a lump sum, these amounts are taxed in the same manner as a surrender; or

• if distributed under an annuity payment option, these amounts are taxed in the same manner as annuity payments.

Annuity Payments

Although the tax consequences may vary depending on the annuity payment option you select, in general, for nonqualified and certain qualified policies, only a portion of the annuity payments you receive will be includable in your gross income.

In general, the excludable portion of each annuity payment you receive will be determined as follows:

• Fixed payments-by dividing the “investment in the contract” on the annuity commencement date by the total expected value of the annuity payments for the term of the payments. This is the percentage of each annuity payment that is excludable.

• Variable payments-by dividing the “investment in the contract” on the annuity commencement date by the total number of expected periodic payments. This is the amount of each annuity payment that is excludable.

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The remainder of each annuity payment is includable in gross income. Once the “investment in the contract” has been fully recovered, the full amount of any additional annuity payments is includable in gross income and taxed as ordinary income.

If you select more than one annuity payment option, special rules govern the allocation of the policy’s entire “investment in the contract” to each such option, for purposes of determining the excludable amount of each payment received under that option. We advise you to consult a competent tax adviser as to the potential tax effects of allocating amounts to any particular annuity payment option.

If, after the annuity commencement date, annuity payments stop because an annuitant died, the excess (if any) of the “investment in the contract” as of the annuity commencement date over the aggregate amount of annuity payments received that was excluded from gross income may possibly be allowable as a deduction in your tax return.

You should consult a tax advisor before electing the Initial Payment Guarantee or a feature with stabilized payments.

Partial Annuitization

Under a new tax provision enacted in 2010, if part of an annuity policy’s value is applied to an annuity option that provides payments for one or more lives and for a period of at least ten years, those payments may be taxed as annuity payments instead of withdrawals. None of the payment options under the policy is intended to qualify for this “partial annuitization” treatment and, if you apply only part of the value of the policy to a payment option, we will treat those payments as withdrawals for tax purposes.

Medicare Tax

Beginning in 2013, distributions from nonqualified annuity policies will be considered “investment income” for purposes of the newly enacted Medicare tax on investment income. Thus, in certain circumstances, a 3.8% tax may be applied to some or all of the taxable portion of distributions (e.g. earnings) to individuals whose income exceeds certain threshold amounts ($200,000 for filing single, $250,000 for married filing jointly and $125,000 for married filing separately). Please consult a tax advisor for more information.

Diversification and Distribution Requirements

The Internal Revenue Code provides that the underlying investments for a variable annuity must satisfy certain diversification requirements in order to be treated as an annuity. The policy must also meet certain distribution requirements at the death of an owner in order to be treated as an annuity. These diversification and distribution requirements are discussed in the SAI. We may modify the policy to attempt to maintain favorable tax treatment.

Federal Defense of Marriage Act

The Federal Defense of Marriage Act currently does not recognize same-sex marriages or civil unions, even those that are permitted under individual state laws. Therefore, exercise of the spousal continuation provisions of this policy by persons who do not meet the definition “spouse” under federal law—e.g., civil union partners or same-sex marriage spouses—may have adverse tax consequences. Consult a tax advisor for more information on this subject.

Federal Estate Taxes

While no attempt is being made to discuss the Federal estate tax implications of the Policy, a purchaser should keep in mind that the value of an annuity policy owned by a decedent and payable to a

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beneficiary by virtue of surviving the decedent is included in the decedent’s gross estate. Depending on the terms of the annuity policy, the value of the annuity included in the gross estate may be the value of the lump sum payment payable to the designated beneficiary or the actuarial value of the payments to be received by the beneficiary. Consult an estate planning advisor for more information.

Generation-Skipping Transfer Tax

Under certain circumstances, the Internal Revenue Code may impose a “generation skipping transfer tax” when all or part of an annuity policy is transferred to, or a death benefit is paid to, an individual two or more generations younger than the Owner. Regulations issued under the Internal Revenue Code may require us to deduct the tax from your policy, or from any applicable payment, and pay it directly to the IRS.

Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “2010 Act”) increases the federal estate tax exemption to $5,000,000 and reduces the federal estate tax rate to 35%; increases the Federal gift tax exemption to $5,000,000 and retains the federal gift tax rate at 35%; and increases the generation-skipping transfer tax exemption to $5,000,000 and reduces the generation-skipping transfer tax rate to 35%. Commencing in 2012, these exemption amounts will be indexed for inflation.

The estate, gift, and generation-skipping transfer provisions of the 2010 Act are only effective until December 31, 2012; thereafter, the provisions will sunset, and the federal estate, gift and generation-skipping transfer taxes will return to their pre-2001 levels, resulting in significantly lower exemptions and significantly higher tax rates. Between now and the end of 2012, Congress may

make these provisions of the 2010 Act permanent, or they may do nothing and allow these 2010 Act provisions to sunset, or they may alter the exemptions and/or applicable tax rates.

The uncertainty as to how the current law might be modified in coming years underscores the importance of seeking guidance from a qualified adviser to help ensure that your estate plan adequately addresses your needs and that of your beneficiaries under all possible scenarios.

Annuity Purchases by Residents of Puerto Rico

The Internal Revenue Service recently announced that income received by residents of Puerto Rico under life insurance or annuity policies issued by a Puerto Rico branch of a United States life insurance company is U.S.-source income that is generally subject to United States federal income tax.

Annuity Policies Purchased by Nonresident Aliens and Foreign Corporations

The discussion above provided general information (but not tax advice) regarding U.S. federal income tax consequences to annuity owners that are U.S. persons. Taxable distributions made to owners who are not U.S. persons will generally be subject to U.S. federal income tax withholding at a 30% rate, unless a lower treaty rate applies. In addition, distributions may be subject to state and/or municipal taxes and taxes that may be imposed by the owner’s country of citizenship or residence. Prospective foreign owners are advised to consult with a qualified tax adviser regarding U.S., state, and foreign taxation for any annuity policy purchase.

Transfers, Assignments or Exchanges of Policies

A transfer of ownership or assignment of a policy, the designation of an annuitant or payee or other beneficiary who is not also the owner, the selection of certain annuity commencement dates, the exchange

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of a policy and certain other transactions, or a change of annuitant other than the owner, may result in certain income or gift tax consequences to the owner that are beyond the scope of this discussion. An owner contemplating any such transfer, assignment, selection, exchange or change should contact a competent tax adviser with respect to the potential tax effects of such a transaction.

Possible Tax Law Changes

Although the likelihood of legislative or regulatory changes is uncertain, there is always the possibility that the tax treatment of the policy could change by legislation, regulation, or otherwise. You should consult a tax adviser with respect to legal or regulatory developments and their effect on the policy.

We have the right to modify the policy to meet the requirements of any applicable laws or regulations, including legislative changes that could otherwise diminish the favorable tax treatment that annuity policy owners currently receive.

Separate Account Charges

It is possible that the Internal Revenue Service may take a position that fees for certain optional benefits (e.g., death benefits other than the Return of Premium death benefit) are deemed to be taxable distributions to you. In particular, the Internal Revenue Service may treat fees associated with certain optional benefits as a taxable surrender, which might also be subject to a tax penalty if the surrender occurs prior to age 59 ¹/2. Although we do not believe that the fees associated with any optional benefit provided under the policy should be treated as taxable surrenders, the tax rules associated with these benefits are unclear, and we advise that you consult your tax advisor prior to selecting any optional benefit under the policy.

Foreign Tax Credits

We may benefit from any foreign tax credits attributable to taxes paid by certain underlying funds to foreign jurisdictions to the extent permitted under federal tax law.

Guaranteed Lifetime Withdrawal Benefits

We may make available, as options under the policy, certain guaranteed lifetime withdrawal and other optional benefits. If your policy contains a guaranteed lifetime withdrawal benefit rider the application of certain tax rules, particularly those rules relating to distributions from your policy, are not entirely clear. The tax rules for qualified policies may limit the value of these optional benefits. In view of this uncertainty, you should consult a tax advisor before purchasing a guaranteed lifetime withdrawal benefit rider for a qualified policy.

10. ADDITIONAL FEATURES

Systematic Payout Option

You can select at any time (during the accumulation phase) to receive regular withdrawals (i.e., partial surrenders) from your policy by using the Systematic Payout Option. Under this option, you can receive the greater of (1) or (2), divided by the number of withdrawals made per year, where: (1) up to 10% of your premium payments (reduced by prior withdrawals in that policy year); and (2) is any gains in the policy. For amounts greater than 10% of your premium payments, you must receive prior Company approval.

This amount may be taken free of surrender charges. Any payment in excess of the cumulative interest credited at the time of the payment may be subject to an excess interest adjustment.

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Systematic withdrawals can be made monthly, quarterly, semi-annually, or annually. Each withdrawal must be at least $50. Monthly and quarterly withdrawals must generally be made by electronic funds transfer directly to your checking or savings account.

If you request an additional withdrawal while a Systematic Payout Option is in effect, then the Systematic Payout Option will terminate.

Keep in mind that partial withdrawals under the Systematic Payout Option may be taxable, and if made before age 59 ¹/2, may be subject to a 10% federal penalty tax.

Please note, if you elect certain features (e.g. living benefit riders) your Systematic Payout Option may be different for the first year.

There is no charge for this benefit.

Income Benefit Programs

The Family Income Protector and Managed Annuity Programs are no longer available for new sales, but if you have previously elected one of these benefits you can still upgrade. If you upgrade your minimum annuitization value or minimum income base, you will generally receive the Managed Annuity Program II.

Initial Payment Guarantee

You may only elect to purchase the Initial Payment Guarantee at the time you annuitize your policy. You cannot terminate this payment guarantee (or eliminate the charge for it) after you have elected it. The guarantee only applies to variable annuity payments. There is an additional charge for this guarantee.

The Initial Payment Guarantee does not establish or guarantee the performance of any subaccount.

Under the Initial Payment Guarantee, you receive annuity payments that are stabilized—that is, held level throughout each policy year—and are guaranteed to never be less than a percentage of the initial payment. The guaranteed percentage is subject to change from time to time; however once you annuitize, the guaranteed percentage will not change during the life of the Initial Payment Guarantee. Contact us for the current guaranteed percentage.

The payment amount is adjusted once each year (on the anniversary of your annuity commencement date) to reflect the investment performance of your selected investment choice(s) over the preceding year (but your payment will not be less than the guaranteed minimum).

Fee. There is a charge for the Initial Payment Guarantee, which is in addition to the base product mortality and expense risk fee and administrative charge. This fee is reflected in the amount of the annuity payments that you receive if you select the Initial Payment Guarantee. It is reflected in the calculation of the annuity unit values.

The Initial Payment Guarantee fee is currently equal to an annual rate of 1.25% of the daily net asset value in the subaccounts. We can change the fee, and you pay whatever the fee is when you annuitize.

Other Terms and Conditions. The Initial Payment Guarantee uses a 5% assumed investment return to calculate your annuity payments. This means that the dollar amount of the annuity payments will remain level if the investment return (net of fees and expenses) exactly equals 5%. The payments will increase if actual investment performance (net of fees and expenses) exceeds the assumed investment return, and decrease if actual performance is below the assumed investment return (but not below the guaranteed level).

Termination. The Initial Payment Guarantee is irrevocable.

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The Initial Payment Guarantee may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Initial Payment Guarantee. The application and operation of the Initial Payment Guarantee are governed by the terms and conditions of the policy itself.

Additional Death Distribution

The optional Additional Death Distribution rider pays an additional amount (based on earnings, if any, since the rider was issued) when a death benefit is payable during the accumulation phase under your policy, in certain circumstances. The Additional Death Distribution is only available for issue ages through age 80.

Additional Death Distribution Benefit Amount. The Additional Death Distribution is payable only if you elected the rider prior to the death triggering the payment of the policy death benefit and a death benefit is payable under the policy. The Additional Death Distribution is equal to:

• the Additional Death Distribution factor (see below); multiplied by

• the rider earnings, if any, on the date the death benefit is calculated.

Rider earnings equal:

• the policy value on the date the death benefit is determined; minus

• policy value on the rider date; minus

• premium payments after the rider date; plus

• surrenders after the rider date that exceed the rider earnings on the date of the surrender.

No benefit is payable under the Additional Death Distribution rider if there are no rider earnings on the date the death benefit is calculated.

If you purchase your policy as part of a 1035 exchange or add the Additional Death Distribution rider after you purchase the policy, rider earnings do not include any gains before the 1035 exchange or the date the Additional Death Distribution is added to your policy.

The Additional Death Distribution factor is currently 40% for issue ages under 71 and 25% for issue ages 71-80, based on the annuitant’s age.

No benefit is paid under the rider unless (a) the rider is in force, (b) a death benefit is payable on the policy, and (c) there are rider earnings when the death benefit is calculated.

For purposes of computing taxable gains, both the death benefit payable under the policy and the Additional Death Distribution will be considered.

Please see “Appendix – Additional Death Distribution—Additional Information” for an example which illustrates the Additional Death Distribution payable as well as the effect of a partial surrender on the Additional Death Distribution benefit amount.

Spousal Continuation. If a spouse, as the new owner of the policy, elects to continue the policy instead of receiving a death benefit and Additional Death Distribution, the spouse will receive a one-time policy value increase equal to the Additional Death Distribution. At this time the rider will terminate. The spouse will have the option of immediately re-electing the rider through age 80. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

Rider Fee. A rider fee, 0.25% of the policy value, is deducted annually on each rider anniversary prior to annuitization. We will also deduct this fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted pro rata from each

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investment choice. The fee is deducted even during periods when the Additional Death Distribution would not pay any benefit (because there are no rider earnings).

Termination. The rider will remain in effect until:

• you cancel it by notifying our Administrative and Service Office in writing,

• the policy is annuitized or surrendered, or

• the Additional Death Distribution is paid or added to the policy value under a spousal continuation.

Once terminated, the Additional Death Distribution may be re-elected; however, a new rider will be issued and the additional death benefit will be re-determined. Please note that if the rider is terminated and then re-elected, it will only cover gains, if any, since it was re-elected and the terms of the new rider may be different than the terminated rider.

The tax consequences associated with this rider are not clear. This rider may violate the requirements of certain qualified plans and IRAs. Consult a tax advisor before electing this rider for any qualified plan or IRA.

Please note: This feature terminates upon annuitization and there is a mandatory annuitization date.

The Additional Death Distribution may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Additional Death Distribution. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Additional Death Distribution+

The optional Additional Death Distribution+ rider pays an additional death benefit amount when a death benefit is payable during the accumultion phase under your policy, in certain circumstances. The Additional Death Distribution+ is only available for issue ages through age 75.

Additional Death Distribution+ Benefit Amount. An additional death benefit is only payable if a death benefit is paid on the base policy to which the rider is attached. The amount of the additional benefit is dependent on the amount of time that has passed since the rider date as follows:

• If a death benefit is payable within the first five years after the rider date, the additional benefit amount will be equal to the sum of all rider fees paid since the rider date.

• If a death benefit is payable after five years following the rider date, the additional benefit will be equal to the rider benefit base multiplied by the rider benefit percentage.

The rider benefit base at any time is equal to the policy value less any premiums added after the rider date.

The rider benefit percentage may vary but currently equals 30% for issue ages 0 - 70 and 20% for issue ages 71 - 75, based on the annuitant’s age.

No benefit is payable under the Additional Death Distribution+ if the policy value on the date the death benefit is paid is less than the premium payments after the rider date.

For purposes of computing taxable gains, both the death benefit payable under the policy and the additional benefit will be considered.

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Please see “Appendix – Additional Death Distribution+—Additional Information” for an example that illustrates the additional death benefit payable as well as the effect of a partial surrender on the Additional Death Distribution+ benefit amount.

Spousal Continuation. If a spouse, as the new owner of the policy, elects to continue the policy instead of receiving the death benefit and Additional Death Distribution+, then the spouse will receive a one-time policy value increase equal to the Additional Death Distribution+. At this time the rider will terminate. The spouse will have the option of immediately re-electing the rider through age 75. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

Rider Fee. A rider fee, currently 0.55% of the policy value, is deducted annually on each rider anniversary prior to annuitization. We will also deduct this fee upon full surrender of the policy or other termination of the rider.

Please note: the rider fee is deducted pro rata from each investment choice. The fee is deducted even during periods when the rider would not pay any benefits.

Termination. The rider will remain in effect until:

• you cancel it by notifying our Administrative and Service Office in writing in good order,

• the policy is annuitized or surrendered, or

• the additional death benefit is paid or added to the policy value under a spousal continuation.

Once terminated, the Additional Death Distribution+ may not be re-elected for one year.

The tax consequences associated with this rider are not clear. This rider may violate the requirements of certain qualified plans and IRAs. Consult a tax adviser before electing this rider for any qualified plan or IRA.

Please note: This feature terminates upon annuitization and there is a maximum annuiity commencement date.

The Additional Death Distribution+ may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Additional Death Distribution+. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Nursing Care and Terminal Condition Withdrawal Option

No surrender charges or excess interest adjustment will apply if you make a surrender ($1,000 minimum), under certain circumstances, because you or your spouse has been:

• confined in a hospital or nursing facility for 30 days in a row after the policy issue date; or

• diagnosed with a terminal condition after the policy issue date (usually a life expectancy of 12 months or less).

This benefit is also available to the annuitant or annuitant’s spouse if the owner is not a natural person.

You may exercise this benefit at any time (during the accumulation phase). There is no charge for this benefit.

There is no restriction on the maximum amount you may surrender under this benefit.

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This benefit may vary for certain policies, may not be available for all policies, and may not be available in all states.

Unemployment Waiver

No surrender charges or excess interest adjustment will apply to surrenders after you or your spouse become unemployed in certain circumstances, because you were terminated, laid off, or otherwise lost your job involuntarily. In order to qualify, you (or your spouse, whichever is applicable) must have been:

• employed full time for at least two years prior to becoming unemployed;

• employed full time on the policy date;

• unemployed for at least 60 days in a row at the time of surrender;

• must have a minimum cash value at the time of surrender of $5,000; and

• you (or your spouse) must be receiving unemployment benefits.

You must provide written proof from your State’s Department of Labor, which verifies that you qualify for and are receiving unemployment benefits at the time of surrender.

You may select this benefit at any time (during the accumulation phase) and there is no charge for this benefit.

This benefit is also available to the annuitant or annuitant’s spouse if the owner is not a natural person. There is no charge for this benefit.

There is no restricion on the maximum amount you may surrender under this benefit.

This benefit may vary for certain policies, may not be available for all policies, and may not be available in all states.

Telephone Transactions

You may generally make certain transactions by telephone upon our receipt of the appropriate authorization.

You will be required to provide certain information for identification purposes when requesting a transaction by telephone and we may record your telephone call. We may also require written confirmation of your request. We will not be liable for losses resulting from telephone requests that we believe are genuine. We reserve the right to revoke your telephone transaction privileges at any time without revoking all owners’ telephone transfer privileges.

Telephone requests must be received while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. We may discontinue this option at any time.

We may deny the telephone transaction privileges to market timers and frequent or disruptive traders.

We cannot guarantee that telephone transactions will always be available. For example, our offices may be closed during severe circumstances or other emergencies. There may be interruptions in service beyond our control, and if the volume of calls is unusually high, we might not have anyone available, or lines available, to take your call. Although we have taken precautions to help our systems handle heavy use, we cannot promise complete reliability in all circumstances.

Dollar Cost Averaging Program

During the accumulation phase, you may instruct us to automatically make transfers into one or more variable subaccounts in accordance with your allocation instructions. This is known as Dollar Cost Averaging. While Dollar Cost Averaging buys more accumulation units when prices are low and fewer

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accumulation units when prices are high, it does not guarantee profits or assure that you will not experience a loss.

There are two Dollar Cost Averaging programs available under your policy:

• Traditional—You may specify the dollar amount to be transferred or the number of transfers.

• Transfers will begin as soon as the program is started.

• Special—You may only elect either a six or twelve month program. Transfers will begin as soon as the program is started. You cannot transfer from another investment choice into a Special Dollar Cost Averaging program. This program is only available for new premium, requires transfers from a fixed source, and may credit a higher or lower interest rate than a traditional program.

A minimum of $500 per transfer is required. A minimum of $3,000 is required to start a 6-month program and $6,000 is required to start a 12-month program. The minimum number of transfers is 6 monthly or 4 quarterly, and the maximum is 24 monthly or 8 quarterly.

You can elect to transfer from one of the fixed or variable sources listed on the Dollar Cost Averaging election form (only fixed sources are available for special Dollar Cost Averaging programs).

A Dollar Cost Averaging program will begin once we have received in good order all necessary information and the minimum required amount. Please note: Dollar Cost Averaging programs will not begin on the 29th, 30th, or 31st. If a program would have started on one of those dates, it will start on the 1st business day of the following month. If we receive additional premium payments while a Dollar Cost Averaging program is running, absent new instructions to the contrary, the amount of the Dollar Cost Averaging transfers will increase, but the length of the Dollar Cost Averaging program will not.

NOTE CAREFULLY:

IF:

• we do not receive all necessary information to begin an initial Dollar Cost Averaging program within 30 days of allocating the minimum required amount to a Dollar Cost Averaging program; or

• we do not receive the minimum required amount to begin an initial Dollar Cost Averaging program within 30 days of allocating an insufficient amount;

THEN:

• any amount in a fixed source will be transferred to the money market investment choice; and

• any amount in a variable source will remain in that variable investment choice; and

• new instructions will be required to begin a Dollar Cost Averaging program.

IF:

• we receive additional premium payments after a Dollar Cost Averaging program is completed and the additional premium meets the minimum requirements to start a Dollar Cost Averaging program;

THEN:

• we will, absent new instructions to the contrary, start a new Dollar Cost Averaging program using the previous instructions.

IF:

• we receive additional premium payments after a Dollar Cost Averaging program is completed, and the additional premium does not meet the minimum requirements to start a Dollar Cost Averaging program;

THEN:

• we will, absent new instructions to the contrary, allocate the additional premium as identified in the previous Dollar Cost Averaging program.

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IF:

• you discontinue a Dollar Cost Averaging program before its completion;

THEN:

• we will, absent new instructions to the contrary, transfer any remaining balance directly into the subaccounts in the Dollar Cost Averaging instructions.

You should consider your ability to continue a Dollar Cost Averaging program during all economic conditions.

There is no charge for this benefit.

The Dollar Cost Averaging Program may vary for certain policies, may not be available for all policies, and may not be available in all states. See your policy for availability of the fixed account options.

Asset Rebalancing

During the accumulation phase you can instruct us to automatically rebalance the amounts in your subaccounts to maintain your desired asset allocation. This feature is called Asset Rebalancing and can be started and stopped at any time. However, we will not rebalance if you are in the Dollar Cost Averaging program or if any other transfer is requested. If a transfer is requested, we will honor the requested transfer and discontinue Asset Rebalancing. New instructions are required to start Asset Rebalancing. Asset Rebalancing ignores amounts in the fixed account. You can choose to rebalance monthly, quarterly, semi-annually, or annually.

There is no charge for this benefit.

Guaranteed Lifetime Withdrawal Benefits

You may elect one of the following optional riders under the policy that offers guaranteed lifetime withdrawal benefits - the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income MaxSM Rider. Important aspects of each of these riders are summarized in the “Appendix - Guaranteed Lifetime Withdrawal benefit Comparison Table” and are described in more detail below. You should consult with tax and financial professionals to determine which of these riders is appropriate for you.

The following benefits are no longer available for new sales, but if you have previously elected one of these riders you can still upgrade:

• 5 for Life Rider

• 5 for Life with Growth Rider

• Income Select for Life Rider

• Retirement Income Choice^® Rider

• Retirement Income Choice^® with Double Withdrawal Base Benefit Rider

• Retirement Income Choice^® 1.4 Rider

Living Benefits Rider

You may elect to purchase the optional Living Benefits Rider which provides you with a guaranteed minimum accumulation benefit and a guaranteed minimum withdrawal benefit. The Living Benefits Rider is only available during the accumulation phase. The Living Benefits Rider is only available for annuitant issue ages through age 80. The maximum issue age may be lower if required by state law.

You should view the Living Benefits Rider as a way to permit you to invest in variable investment choices while still having your policy value and liquidity protected to the extent provided by the Living Benefits Rider.

Please note:

• Certain protections under the rider are available only if you hold the rider for ten years.

• If you elect the rider, we will monitor your policy value and we may transfer amounts back and forth between specified investment choices under the policy (including guaranteed period options in the fixed account) and the variable

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investment choices you choose, according to a mathematical model that we will use to assist us in managing portfolio risk and supporting the guarantees under the rider. See “Portfolio Allocation Method” below.

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider for you to take withdrawals each rider year that are less than or equal to the maximum annual withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the maximum annual withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• Because the guaranteed minimum withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the maximum annual withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take the maximum advantage of the tax deferral aspect of the policy.

• The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Living Benefits Rider for a qualified policy.

• Any such transfers out of a guaranteed period option may be subject to an excess interest adjustment. We intend to include among the specified investment choices fixed account options to which excess interest adjustments do not apply. (See “Portfolio Allocation Method,” below.)

Guaranteed Minimum Accumulation Benefit

If you elect the Living Benefits Rider, we will provide a guaranteed future value. This benefit is intended to provide a level of protection regardless of the performance of the variable investment choices you select.

Guaranteed Future Value. We guarantee that, on the guaranteed future value date (ten years after you elect the rider), your policy value will at least equal your guaranteed future value. The guaranteed future value on the rider date (i.e., the date the rider is added to the policy) is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date and before the guaranteed future value date, the guaranteed future value is equal to:

• the guaranteed future value on the rider date; plus

• a percentage of subsequent premium payments (as described below); less

• subsequent adjusted partial withdrawals (as described below).

After the guaranteed future value date, the guaranteed future value equals zero.

Subsequent Premium Payments. The percentage of subsequent premium payments that will be added to the guaranteed future value is as follows:

Rider Year	Percent of subsequent premium payments added to guaranteed future value
1	100%
2	90%
3	80%
4	70%
5	60%
6	50%
7	50%
8	50%
9	50%
10	0%

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Guaranteed Future Value Adjusted Partial Withdrawals. If you take a partial withdrawal, it will reduce your guaranteed future value. The amount of the reduction is referred to as the adjusted partial withdrawal amount, which will be equal to the greater of:

• the guaranteed future value immediately prior to the withdrawal multiplied by the percentage reduction in the policy value resulting from the gross partial withdrawal; or

• the gross partial withdrawal amount.

(The gross partial withdrawal amount is the amount you request, plus any surrender charges or excess interest adjustment that may be applicable.)

In other words, if your policy value is greater than the guaranteed future value at the time you make a partial withdrawal, then your guaranteed future value is reduced by the same amount we reduce your policy value. However, if your policy value is less than the guaranteed future value at the time you make a partial withdrawal, then your guaranteed future value will be reduced by more than the amount we reduce your policy value.

See the “Appendix—Living Benefits Rider Adjusted Partial Withdrawals” to this prospectus for examples showing the effect of hypothetical withdrawals in more detail, including withdrawals that reduce the guaranteed future value by more than the amount of the gross partial withdrawal.

Guaranteed Minimum Accumulation Benefit. On the guaranteed future value date (ten years after you elect the rider), if the policy value is less than the guaranteed future value, we will add an amount equal to the difference to your policy value. After the guaranteed future value date, the guaranteed minimum accumulation benefit will terminate.

Example. Assume you make a single premium payment of $100,000 and you do not make any withdrawals or additional premium payments. If, on the guaranteed future value date, your policy value has declined to $90,000 because of negative investment performance, then we will add $10,000 ($100,000 – $90,000) to your policy value.

Please note: You do not have any protection under the guaranteed minimum accumulation benefit unless you hold the policy with the rider for ten years. If you think that you may terminate the policy or elect to start receiving annuity payments (or if you must begin taking required minimum distributions) before the guaranteed future value date, electing the rider may not be in your best interests.

Guaranteed Minimum Withdrawal Benefit

If you elect the Living Benefits Rider, (first as withdrawals from your policy value or, if necessary, as payments from us) we will provide a maximum annual withdrawal amount regardless of your policy value. This benefit is intended to provide a level of benefits regardless of the performance of the variable investment choices you select.

Withdrawal Guarantees. We account for the withdrawals you take under the rider by applying two different withdrawal guarantees:

• “principal back,” for withdrawals of up to 7% of your total withdrawal base.

• “for life,” for withdrawals of up to 5% of your total withdrawal base.

When you make a withdrawal, you do not need to specify it as being under either withdrawal guarantee. Any withdrawals that you take while the rider is in effect could have different impacts under each of the withdrawal guarantees - on your maximum annual withdrawal amount, on your total withdrawal base, and on your minimum remaining withdrawal amount. For example, withdrawals that are compliant with the “principal back” maximum withdrawal amount could result in excess withdrawals under the “for life” withdrawal guarantee and, consequently, would reduce the maximum annual withdrawal

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amount, the total withdrawal base, and the minimum remaining withdrawal amount under the “for life” withdrawal guarantee. (See “Adjusted Partial Withdrawals” below.)

Your ability to change the frequency or amount of your withdrawals ceases if your policy value reaches zero.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion. See “Appendix - Living Benefits Rider Adjusted Partial Withdrawals,” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the total withdrawal base by a pro rata amount.

Please note:

• Any amount withdrawn in a rider year (including any surrender charge or excess interest adjustment) in excess of the maximum withdrawal amount is an excess withdrawal.

• The amount of your excess withdrawal will impact the maximum annual withdrawal amount, total withdrawal base, and minimum remaining withdrawal amount under each guarantee on a greater than dollar-for-dollar basis. (See “Maximum Annual Withdrawal Benefit,” “Total Withdrawal Base,” and “Minimum Remaining Withdrawal Amount,” below.)

Withdrawals under the guaranteed minimum withdrawal benefit also:

• reduce your policy value;

• reduce your death benefit and other benefits;

• may be subject to any surrender charge or excess interest adjustment; and

• may be subject to income taxes and federal tax penalties (See “Section 9. Taxes”).

Maximum Annual Withdrawal Amount. Under this benefit:

• you can withdraw up to 7% of your “principal back” total withdrawal base each rider year until your “principal back” minimum remaining withdrawal amount reaches zero;

Example. Assume you make a single premium payment of $100,000 and that you do not make any withdrawals or additional premium payments. Assume that after five years, your policy value has declined to $70,000 solely because of negative investment performance. You could still receive up to $7,000 (7% of $100,000) each rider year for the next fourteen years and $2,000 in the year immediately thereafter so you would get back your full $100,000 (assuming that you do not withdraw more than $7,000 in any one rider year).

• or, you can withdraw up to 5% of your “for life” total withdrawal base each rider year starting with the rider anniversary immediately following the annuitant’s 59th birthday and lasting until the annuitant’s death, unless your “for life” minimum remaining withdrawal amount reaches zero because of “excess withdrawals” (see “Adjusted Partial Withdrawals,” below). A penalty tax may be assessed on amounts surrendered from the policy before the annuitant reaches age 59 ¹/2.

Example. Assume you are the owner and annuitant and you make a single premium payment of $100,000 when you are 55 years old. Assume you do not make any withdrawals or additional premium payments. Assume that after five years, your policy value has declined to $70,000 solely because of negative investment performance. You could still receive up to $5,000 (5% of $100,000) each rider year for the rest of your life (assuming that you do not withdraw more than $5,000 in any one rider year).

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You can receive up to the maximum annual withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us) under this rider regardless of your policy value; however, once your policy value reaches zero you cannot make premium payments, and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to continue withdrawals under this rider after your policy value reaches zero, you must select an amount and frequency of future withdrawals. Once selected, the amount and frequency of future withdrawals after your policy value reaches zero cannot be changed.

Please note:

• Withdrawals under the 5% “for life” guarantee cannot begin until after the rider anniversary following the annuitant’s 59th birthday.

• Any withdrawal before the rider anniversary following the annuitant’s 59th birthday will reduce the benefits under the 5% “for life” guarantee.

• The maximum annual withdrawal amounts described above (the 7% “principal back” and 5% “for life”) are based on rider years, not calendar or policy years (if different from rider years).

• You cannot carry over any portion of your maximum annual withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the maximum annual withdrawal amount during a rider year, you cannot take more than the maximum annual withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• If you have a qualified policy, minimum required distribution rules may force you to take excess withdrawals to avoid the imposition of a 50% excise tax. Further, some qualified policies have withdrawal restrictions that may (with limited exceptions) prevent you from taking withdrawals before age 59 ¹/2. You should consult a tax advisor before purchasing this rider with a qualified policy.

Total Withdrawal Base. We use the total withdrawal base to calculate the maximum annual withdrawal amount. The total withdrawal base on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the total withdrawal base is equal to:

• the total withdrawal base on the rider date; plus

• subsequent premium payments; less

• subsequent adjusted partial withdrawals (as described below).

We will calculate separate total withdrawal bases for the “principal back” and “for life” guarantees.

Please note: We determine the total withdrawal base solely to calculate the maximum annual withdrawal amount. Your total withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

Minimum Remaining Withdrawal Amount. The minimum remaining withdrawal amount represents the total amount of guaranteed withdrawals still available under the rider. The minimum remaining withdrawal amount on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the minimum remaining withdrawal amount is equal to:

• the minimum remaining withdrawal amount on the rider date; plus

• subsequent premium payments; less

• subsequent adjusted partial withdrawals (as described below).

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We will calculate separate minimum remaining withdrawal amounts for the “principal back” and “for life” guarantees.

Adjusted Partial Withdrawals. Each rider year, for each withdrawal guarantee (i.e., “principal back” and “for life”), gross partial withdrawals (the amount that you request be withdrawn, plus any surrender charge or excess interest adjustment that may be applicable) up to the maximum annual withdrawal amount for that withdrawal guarantee, will reduce the minimum remaining withdrawal amount for that withdrawal guarantee on a dollar-for-dollar basis, but will not reduce the total withdrawal base for that withdrawal guarantee. For each withdrawal guarantee, gross partial withdrawals in excess of the maximum annual withdrawal amount for that withdrawal guarantee will reduce the total withdrawal base and minimum remaining withdrawal amount for that withdrawal guarantee by a pro rata amount (possibly to zero). See “Appendix - Living Benefits Rider Adjusted Partial Withdrawals,” which provides examples showing the effect of a withdrawal. Excess withdrawals may cause you to lose the withdrawal guarantees under this rider.

Please note: Gross partial withdrawals that are compliant with the “principal back” withdrawal guarantee (i.e., withdrawals of the “principal back” maximum annual withdrawal amount) and any partial withdrawal before the rider anniversary following the annuitant’s 59th birthday, will result in an excess partial withdrawal under the “for life” guarantee, and will reduce the “for life” maximum annual withdrawal amount, the “for life” total withdrawal base, and the “for life” minimum remaining withdrawal amount. Such reduction may be on a greater than dollar-for-dollar basis.

Rider Fee. A rider fee, 0.90% of the “principal back” total withdrawal base on each rider anniversary, is charged annually before annuitization. We will also deduct the rider fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice. Generally, the rider fee is deducted regardless of your values (i.e., even if your policy value exceeds your total withdrawal base).

We will continue to calculate the rider fee using the “principal back” total withdrawal base even after the “principal back” minimum remaining withdrawal amount reaches zero. The “principal back” total withdrawal base is always greater than or equal to the “for life” total withdrawal base.

Please note: Because the rider fee is a percentage of your “principal back” total withdrawal base on each rider anniversary, the fee can be substantially more than 0.90% of your policy value if that total withdrawal base is higher than your policy value.

Portfolio Allocation Method

If you elect the Living Benefits Rider, the Portfolio Allocation Method (“PAM”) will automatically be in effect. PAM is designed to help manage portfolio risk and support the guarantees under the Living Benefits Rider. Using PAM, we will monitor your policy value and may transfer amounts back and forth between the PAM Transamerica AEGON U.S. Government Securities VP—Service Class subaccount (which invests in the Transamerica AEGON U.S. Government Securities VP—Service Class portfolio of the Transamerica Series Trust) or certain guaranteed period options of the fixed account (each a “PAM investment choice” and collectively, the “PAM investment choices”) and the variable investment choices you choose. You should read the underlying fund prospectus for the variable PAM investment choice(s) carefully before you elect the Living Benefits Rider. We will transfer amounts from your variable investment choices to the PAM investment choices to the extent we deem, at our sole discretion, necessary to support the guarantees under the rider. We will transfer amounts to the PAM investment choices proportionally from all your

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variable investment choices. Currently, PAM transfers are being made to the PAM Transamerica AEGON U.S. Government Securities VP—Service Class subaccount.

PAM is designed to help reduce portfolio risk associated with negative performance. Using PAM, we will transfer amounts from your variable investment choices to the PAM investment choices to the extent we deem, in our sole discretion, necessary to help manage portfolio risk and support the guarantees under the Living Benefits Rider. You should not view the Living Benefits Rider nor PAM as a “market timing” or other type of investment program designed to enhance your policy value. If you choose this rider, it may result in a lower policy value in certain situations. If policy value is transferred from your chosen variable investment choices to the PAM investment choices, less of your policy value may be available to participate in any future positive investment performance of your variable investment choices. This may potentially provide a lower policy value than if you did not select the Living Benefits Rider.

Under PAM, the mathematical model compares a number of interrelated factors including your policy value and the guarantees under the rider to be provided in the future. The mathematical model also uses assumptions for interest rates, the duration of the policy and stock market volatility. The following table sets forth the most influential of these factors and indicates how each one (assuming all other factors remain constant) could trigger a transfer into or out of the PAM subaccounts.

Factor	Direction of Transfer
Policy Value Increases	Transfer to the investment options
Policy Value Decreases	Transfer to the PAM subaccounts
Interest Rates Increase	Transfer to the investment options
Volatility Increases	Transfer to the PAM subaccounts

The amount of the transfer will vary depending on the magnitude and direction of the change in these factors. We may transfer some or all of your policy value to or from the PAM investment choices.

Transactions you make also affect the number of PAM transfers including:

• additional premium payments; and

• excess withdrawals.

These transactions will change the policy value relative to the guarantees under the rider and may result in additional PAM transfers.

You may not allocate premium payments to, nor transfer policy value into or out of, the PAM investment choices. PAM transfers are not subject to any transfer fee and do not count against the number of any free transfers we allow. Transfers out of a fixed account PAM investment choice are at our discretion and may be subject to an excess interest adjustment if the transfer occurs before the end of a guarantee period. Any transfer to your variable investment choices will be allocated into your variable investment choices in proportion to the amount of policy value in each variable investment choice.

Generally, transfers to the PAM investment choices first occur when the policy value drops by a cumulative amount of 3% to 5% over any period of time, although we may make transfers to the PAM investment choices when the policy value drops by a cumulative amount of less than 3% in relation to the guarantees. If the policy value continues to fall, more transfers to the PAM investment choices will occur. When a transfer occurs, the transferred policy value is allocated to the PAM investment choice(s) we deem appropriate. The policy value allocated to the PAM investment choices will remain there unless the performance of your chosen investment choices recovers sufficiently to enable us to transfer amounts back to your investment choices while maintaining the guarantees under the Living Benefits Rider. This

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generally occurs when the policy value increases by 5% to 10% in relation to the guarantees, although we may require a larger increase before transferring amounts back to your investment options.

The Daily Rebalancing Formula Under the Mathematical Model: As noted above, to limit our exposure under the rider, we transfer policy value from your investment options to the PAM subaccounts, to the extent called for by a mathematical model that will not change once you purchase the policy. We do this in order to minimize the need to provide payments (for example, when your policy value goes to zero by other than an excess withdrawal), or to extend the time before any payment is required. When payments become more likely (because your policy value is approaching zero), the mathematical model will tend to allocate more policy value to the PAM subaccounts. If, on the other hand, the policy value is much higher than the guarantees under the rider, then payments may not be necessary, and therefore, the mathematical model will tend to allocate more policy value to the investment options.

Each business day the mathematical model computes a “target allocation,” which is the portion of the policy value that is to be allocated to the investment options.

The target allocation depends on several factors, including the policy value as compared to the guarantees under the rider, the time until payments are likely required, and interest rates. However, as time passes, these factors change. Therefore, the target allocation changes from one business day to the next.

See “Appendix—PAM Method Transfers” in the SAI for more detail regarding the workings of the mathematical model, including the formula used to compute the allocation on a daily basis.

Upgrades

Prior to the annuitant’s 86th birthday and after the third rider anniversary, you can upgrade the total withdrawal base and guaranteed future value to the policy value by sending us written notice. The minimum remaining withdrawal amounts will also be upgraded to the policy value and the maximum annual withdrawal amounts will be recalculated.

If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, guaranteed future value date, and its own rider fee percentage (which may be higher than your current rider fee percentage). The “principal back” and “for life” withdrawal percentages will not change. The new rider date will be the date the Company receives all necessary information.

Annuitization

If you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments equal to your 5% “for life” maximum annual withdrawal amount.

Termination

The Living Benefits Rider will terminate upon the earliest of the following:

• the date we receive written notice from you in good order requesting termination of the Living Benefits Rider (you may not terminate the rider before the third rider anniversary);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your 5% “for life” maximum annual withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

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• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This feature terminates upon annuitization and there is a maximum annuity commencement date.

The Living Benefits Rider may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Living Benefits Rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Retirement Income Choice^® 1.2 Rider

You may elect to purchase the optional Retirement Income Choice^® 1.2 Rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value according to either the designated allocation option or open allocation option both of which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Choice^® 1.2 rider for a qualified policy.

Retirement Income Choice^® 1.2 – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments and Rider Death Benefit Adjustments, below). A rider year begins on the rider date (the date the rider becomes effective) and thereafter on each anniversary of that date.

Example. Assume you are the owner and annuitant and you make a single premium payment of $100,000 when you are 66 years old. Further assume that you do not make any withdrawals or additional premium payments, no automatic step-ups occurred, but that after five years your policy value has declined to $90,000 solely because of negative investment performance. With an annual growth rate percentage of 5.0%, after 5 years the withdrawal base is equal to $127,628 ($100,000 x 1.05⁵). You could receive up to $6,381 which is the applicable withdrawal percentage of 5.0% for the single life option multiplied by the withdrawal base of $127,628, each rider year for the rest of your life (assuming that you take your first withdrawal when you are age 71, that you do not withdraw more than the rider withdrawal amount in any one year and there are no future automatic step-ups.)

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

Example continued. Assume the same facts as above, but you withdraw $10,000 when you are 71 years old. That excess withdrawal decreases your future rider withdrawal amount to $6,105.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider “ for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid

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under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated according to the Designated Allocation option or the Open Allocation option. You should consult with your registered representative to assist you in determining whether the investment restrictions attributable to each option are suited for your financial needs and risk tolerance.

• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base, and rider death benefit (if applicable) on a greater than dollar-for-dollar basis.

• Any withdrawal will reduce your rider death benefit (if applicable).

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Choice^® 1.2 rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” and “Rider Death Benefit Adjustments” below.

The rider withdrawal amount is zero if the annuitant is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

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For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider.

If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated according to either the Designated Allocation option or the Open Allocation option. (See “Allocation Options and Restrictions.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse’s age if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse’s if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage— Single Life Option			Withdrawal Percentage— Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.0	%		3.5	%
65-74		5.0	%		4.5	%
³75		6.0	%		5.5	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus

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subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• Current withdrawal base;

• The withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

• The policy value on any monthiversary^SM , including the current rider anniversary (see “Automatic Step-Up” below).

Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary^SM during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the

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policy value when the policy value is less than the withdrawal base), possibly to zero. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider “ for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

Allocation Options and Restrictions. If you elect this rider, you must allocate 100% of your policy value according to either the Designated Allocation option or the Open Allocation option. Transfers will be permitted between the Designated Allocation option and the Open Allocation option at any time.

Designated Allocation Option. Under the Designated Allocation option, you must designate 100% of your policy value into one or more of the designated investment options in the following designated allocation groups:

Designated Allocation Group A

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

American Funds – Asset Allocation Fund – Class 2

Fidelity VIP Balanced Portfolio – Service Class 2

Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

Transamerica AEGON Active Asset Allocation – Moderate Growth VP – Service Class

Transamerica Asset Allocation – Moderate Growth VP – Service Class

Transamerica International Moderate Growth VP – Service Class

Transamerica Multi-Managed Balanced VP – Service Class

Transamerica Efficient Markets VP – Service Class

Transamerica Index 75 VP – Service Class

GE Investments Total Return Fund – Class 3

Designated Allocation Group B

Transamerica AEGON Active Asset Allocation – Moderate VP – Service Class

Transamerica Asset Allocation – Moderate VP – Service Class

Transamerica BlackRock Global Allocation VP – Service Class

Transamerica BlackRock Tactical Allocation VP – Service Class

Transamerica Index 50 VP – Service Class

Designated Allocation Group C

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Transamerica AEGON Active Asset Allocation – Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Asset Allocation – Conservative VP – Service Class

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

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Transamerica Index 35 VP – Service Class

American Funds – Bond Fund – Class 2

Fixed Account

Transfers between the designated investment options in the Designated Allocation option are allowed as permitted under the policy; however, transfers as provided for in the policy from a designated investment option to a non-designated investment option are not permitted unless you change your allocation option to the Open Allocation option.

Open Allocation Option. Under the Open Allocation option, you may allocate to any investment options available under the policy.

If you elect the Open Allocation option, the OA Method will automatically be in effect. The OA Method uses a mathematical model which is designed to help the Company manage portfolio risk and support the guarantees under the rider. Under the OA Method, the mathematical model monitors your policy value and guarantees under the rider and transfers amounts back and forth between the OA Transamerica ProFund UltraBear VP subaccount or certain other subaccounts we choose (each an “OA subaccount” and collectively, the “OA subaccounts”) and the variable investment options you choose to the extent necessary to support the benefit guarantees. You will still have complete discretion over the selection of, and allocation to, the variable investment options for any portion of your policy value that the OA Method does not allocate to the OA subaccounts. You should read the underlying fund prospectus for the variable OA subaccounts carefully before you elect the Open Allocation option.

Transfers to the OA subaccounts according to the mathematical model will be proportionally from all your variable investment options. This mathematical model will not change once you purchase the rider, but we may use a different model for riders issued in the future.

The OA Method is designed to help manage the Company’s portfolio risk associated with negative performance and support the guarantees under the rider. You should not view the rider nor the OA Method as a “market timing” or other type of investment program designed to enhance your policy value. If you choose the Open Allocation option, it may result in a lower policy value in certain situations. If policy value is transferred from your chosen variable investment options to the OA subaccounts, less of your policy value may be available to participate in any future positive investment performance of your variable investment options. This may potentially provide a lower policy value than if you did not select the Open Allocation option.

Under the OA Method, the mathematical model compares a number of interrelated factors including your policy value and the guarantees under the rider to be provided in the future. The mathematical model also uses assumptions for interest rates, the duration of the policy and stock market volatility. The following table sets forth the most influential of these factors and indicates how each one (assuming all other factors remain constant) could trigger a transfer into or out of the OA subaccounts.

Factor	Direction of Transfer
Policy Value Increases	Transfer to the investment options
Policy Value Decreases	Transfer to the OA subaccounts
Interest Rates Increase	Transfer to the investment options
Volatility Increases	Transfer to the OA subaccounts

The amount of the transfer will vary depending on the magnitude and direction of the change in these factors.

Transactions you make also affect the number of OA transfers including:

• additional premium payments; and

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• excess withdrawals.

These transactions will change the policy value relative to the guarantees under the rider and may result in additional OA transfers.

You may not allocate premium payments to, nor transfer policy value into or out of, the OA subaccounts. OA Method transfers are not subject to any transfer fee and do not count against the number of any free transfers we allow. Any transfer to your variable investment options will be allocated into your variable investment options in proportion to the amount of policy value in each variable investment option.

Generally, transfers to the OA subaccounts first occur when the policy value drops by a cumulative amount of 2% to 5% over any period of time in relation to the guarantees, although the mathematical model may make transfers to the OA subaccounts when the policy value drops by a cumulative amount of less than 3%. The mathematical model will not transfer more than 20% of the policy value to the OA subaccounts. If the policy value continues to fall, no more transfers to the OA subaccounts will occur. However, up to 30% of the policy value could be in the OA subaccounts due to negative performance of the investment options. If negative investment performance causes the percentage of the policy value in the OA subaccounts to exceed 30% then the mathematical model will transfer the excess policy value back into your investment options. The policy value allocated to the OA subaccounts will remain there unless your policy value recovers sufficiently to enable us to transfer amounts back to your investment options while maintaining the guarantees under the rider. This generally occurs when the policy value increases by 2.5% to 10% in relation to the guarantees under the rider, although the mathematical model may require a larger increase before transferring amounts back to your investment options.

The Daily Rebalancing Formula Under the Mathematical Model: As noted above, to limit our exposure under the rider, we transfer policy value from your investment options to the OA subaccounts, to the extent called for by a mathematical model that will not change once you purchase the policy. We do this in order to minimize the need to provide payments (for example, when your policy value goes to zero by other than an excess withdrawal), or to extend the time before any payment is required. When payments become more likely (because your policy value is approaching zero), the mathematical model will tend to allocate more policy value to the OA subaccounts. If, on the other hand, the policy value is much higher than the guarantees under the rider, then payments may not be necessary, and therefore, the mathematical model will tend to allocate more policy value to the investment options.

Each business day the mathematical model computes a “target allocation,” which is the portion of the policy value that is to be allocated to the investment options.

The target allocation depends on several factors, including the policy value as compared to the guarantees under the rider, the time until payments are likely required, and interest rates. However, as time passes, these factors change. Therefore, the target allocation changes from one business day to the next.

See “Appendix—OA Method Transfers” in the SAI for more detail regarding the workings of the mathematical model, including the formula used to compute the allocation on a daily basis.

Please Note: The OA Transamerica ProFunds UltraBear VP subaccount invests in the Transamerica ProFunds UltraBear VP portfolio which is designed to seek daily investment results, before fees and expenses that correspond to twice (200%) the inverse (opposite) of the daily performance of the S&P 500

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Index. Please read the prospectus for the Transamerica ProFunds UltraBear VP portfolio to understand how its investment objective may affect your policy value if OA Method transfers occur to the OA Transamerica ProFunds UltraBear VP subaccount.

You cannot allocate premium payments or transfers to the OA subaccounts.

Please note:

• If you no longer want to be subject to an allocation option, you will be required to terminate the rider. If you terminate the rider you will lose all of its benefits.

• We can change a designated allocation group or eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Manual Upgrades. You can upgrade the withdrawal base to the policy value during the 30-day period following each successive fifth rider anniversary by sending us written notice in a form acceptable to us, as long as the rider issue requirements for a new rider are met. At this time the rider withdrawal amount and, if applicable, the rider death benefit will be recalculated. If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, its own rider fee percentage (which may be higher or lower than your current rider fee percentage) and its own terms and benefits (which may not be as advantageous as the current rider); and any options you elect to change or add. The new rider date will be the date the Company receives all necessary information in good order. You cannot elect a manual upgrade if the annuitant (or the annuitant’s spouse if younger and the joint option is elected) is 86 or older.

Retirement Income Choice^® 1.2 – Additional Options

You may elect the following options with this rider (the options are not mutually exclusive):

• Death Benefit;

• Joint Life; and

• Income Enhancement.

There is an additional fee if you elect the Death Benefit and/or the Income Enhancement Benefit option(s) under the rider. If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower. Furthermore, if you elect the Joint Life option in combination with the Death Benefit and/or the Income Enhancement Benefit option(s), then the fee for each of those additional options will be different than under the Single Life option. See “Retirement Income Choice^® 1.2 Rider and Additional Option Fees”.

1. Death Benefit. If you elect this rider, you can also elect to add an additional amount to the death benefit payable under the base policy, upon the death of the annuitant (or if the joint life option is selected, the annuitant’s spouse). The additional amount will be equal to the excess, if any, of the rider death benefit over the greater of any optional guaranteed minimum death benefit or the base policy death benefit. The additional amount can be zero. See “Section 8. Death Benefit.”

Rider Death Benefit. The rider death benefit on the rider date is the policy value (less any premium enhancement if the rider is added in the first policy year). After the rider date, the rider death benefit is equal to:

• the rider death benefit on the rider date; plus

• subsequent premium payments; less

• adjustments for withdrawals (as described under “Rider Death Benefit Adjustments,” below).

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Rider Death Benefit Adjustments. Gross partial withdrawals up to the rider withdrawal amount in a rider year will reduce the rider death benefit on a dollar-for-dollar basis. Gross partial withdrawals in excess of the rider withdrawal amount in a rider year will reduce the rider death benefit by the greater of the dollar amount of the excess withdrawal or a pro rata amount (in proportion to the reduction in policy value), and possibly to zero. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider “ for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that results in pro rata adjustments. Rider death benefit adjustments occur immediately following all withdrawals.

Please note:

• No additional death benefit is payable if the base policy death benefit (including the guaranteed minimum death benefit) exceeds the rider death benefit. The greater the death benefit payable under the guaranteed minimum death benefit selected, the more likely it is that an additional amount will not be payable under the rider death benefit option.

• Excess withdrawals may eliminate the additional death benefit available with this rider. You will continue to pay the fee for this option, even if the additional death benefit available under the rider is $0.

• Manual upgrades to the withdrawal base will result in a recalculation of the rider death benefit. However, automatic step-ups will not reset the rider death benefit.

• If an owner who is not the annuitant dies and the surviving spouse continues the policy, then no additional amount is payable. If the policy is not continued, then the surviving owner (who is also the sole beneficiary) may elect to receive lifetime annuity payments equal to the rider withdrawal amount divided by the number of payments each year instead of receiving the policy’s cash value. Please note that under federal tax law, upon the death of an owner, only a “spouse,” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

The additional death benefit payment option may be referred to as “minimum remaining withdrawal amount” on your policy statement and other documents.

2. Joint Life Benefit. If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

Please note:

• The withdrawal percentage for each “age at the time of first withdrawal” is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The rider death benefit is not payable until the death of the surviving spouse, if you elect this option.

• You cannot elect a manual upgrade if the annuitant or annuitant’s spouse is 86 or older (lower if required by state law).

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3. Income Enhancement Option. If you elect this rider, you can also elect to have your withdrawal percentage double if either the annuitant (or the annuitant’s spouse if the joint life option is elected) is confined, due to a medical necessity in a hospital or nursing facility due to physical or cognitive ailments. Benefits from this option are not available unless the rider has been in effect for 12 months (the “waiting period”) and confinement must meet the elimination period of 180 days within the last 365 days. The elimination period and waiting period can, but do not need to, run concurrently.

Please note:

• You cannot elect the Income Enhancement Option if the qualifying person or persons is/are already admitted to a hospital or already reside in a nursing facility.

• Confinement must be prescribed by a physician based on the individual’s inability to sustain themselves outside of a hospital or nursing facility due to physical or cognitive ailments.

• The increase to the withdrawal percentage stops when the qualifying person or persons is/are no longer confined as described above.

• The hospital and/or nursing facility must meet the criteria listed below to qualify for the benefit.

• You cannot elect the Income Enhancement Option if you are confined in an assisted living facility or a residential care facility.

A Qualifying Hospital must meet the following criteria:

• It is operated pursuant to the laws of the jurisdiction in which it is located;

• It is operated primarily for the care and treatment of sick and injured persons on an inpatient basis;

• It provides 24-hour nursing service by or under the supervision of registered graduate professional nurses;

• It is supervised by a staff of one or more licensed physicians; and

• It has medical, surgical and diagnostic facilities or access to such facilities.

A Qualifying Nursing Facility must meet the following criteria:

• It is operated pursuant to the laws and regulations of the state in which it is located as a nursing facility or Alzheimer’s disease facility;

• It provides care performed or supervised by a registered graduate nurse;

• It provides room and board accommodations; and

• Will provide 24-hour nursing services, 7 days a week by an on-site Registered Nurse and related services on a continuing inpatient basis.

• It has a planned program of policies and procedures developed with the advice of, and periodically reviewed by, at least one physician; and

• It maintains a clinical record of each patient.

A Qualifying Nursing Facility does not include:

• Assisted living facilities or residential care facilities;

• A place primarily for treatment of mental or nervous disorders, drug addiction or alcoholism;

• A home for the aged, a rest home, community living center or a place that provides domestic, resident, retirement or educational care;

• Personal care homes, personal care boarding homes, residential or domiciliary care homes;

• A rehabilitation hospital or basic care facilities;

• Adult foster care facilities, congregate care facilities, family and group living assisted living facilities; or

• Other facilities similar to those described above.

We will require confirmation of confinement in a qualifying hospital or a qualifying nursing facility while benefit payouts are being received. Confirmation of that confinement will be attained and approved by completing our “Income Enhancement Election and Proof of Confinement Questionnaire” form. This form requires additional

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proof of confinement which may be a physician’s statement, a statement from a hospital or nursing facility administrator, or any other information satisfactory to us which may include information from third party or company interviews and/or visits of the facility. If it is determined that the qualifying individual was not confined in an eligible facility as defined above and has received payments under the Income Enhancement Option, those payments could be considered an excess withdrawal and have a negative effect on the rider values. If confinement ceases, you may re-qualify by satisfying another 180-day elimination period requirement.

Retirement Income Choice^® 1.2 Fees

Retirement Income Choice^® 1.2 Base Rider Fee. The base rider fee is calculated on the rider date and at the beginning of each rider quarter. The base rider fee will be adjusted for any premium additions, excess withdrawals, transfers between designated investment groups, or changes to other allocation options during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the base rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The Open Allocation option base quarterly fee is calculated by multiplying (A) by (B) by (C), where:

(A) is the withdrawal base;

(B) is the rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

The Designated Allocation option base quarterly fee is calculated by multiplying (A) by (B) divided by (C) multiplied by (D), where:

(A) is the withdrawal base;

(B) is the sum of each designated investment group’s rider fee percentage multiplied by the applicable designated investment group’s value;

(C) is the total policy value; and

(D) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the base rider fee:

• Because the base rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the base rider fee is a percentage of the withdrawal base, the amount of the base rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

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• If you make a transfer from one designated allocation group to another designated allocation group that has a higher rider fee percentage, then the resulting rider fee will be higher.

Base Rider Fee Adjustment for Transfers. For transfers that you make between different designated investment options in different designated allocation groups or different allocation options on other than the first business day of a rider quarter, a “rider fee adjustment” will be applied. This adjustment is necessary because of differences in the rider fee percentages. The adjustment in the rider fee percentage will ensure that you are charged the correct overall rider fee. The base rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated.

Base Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will also be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. As with the rider fee adjustments calculated for transfers, the rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

Additional Option Fees. If you elect options with this rider, then you will be charged a fee for each option you elect that is in addition to the rider fee for the base benefit (see the Fee Table). Each additional fee is charged quarterly before annuitization and is a percentage of the withdrawal base on each rider anniversary.

We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

Retirement Income Choice^® 1.2 Rider Issue Requirements

The Company will not issue the Retirement Income Choice^® 1.2 rider unless:

• the annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Choice^® 1.2 rider and any additional options will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or if the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

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• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Choice^® 1.2 rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Choice^® 1.2 rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Retirement Income Choice^® 1.4 Rider – This Rider is No Longer Available for New Sales

You may elect to purchase the optional Retirement Income Choice^® 1.4 rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Choice^® 1.4 rider for a qualified policy.

Retirement Income Choice^® 1.4 – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments and Rider Death Benefit Adjustments, below). A rider year begins on the rider date (the date the rider becomes effective) and thereafter on each anniversary of that date.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making

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withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you in determining whether these certain investment options are suited for your financial needs and risk tolerance.

• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base, and rider death benefit (if applicable) on a greater than dollar-for-dollar basis.

• Any withdrawal will reduce your rider death benefit (if applicable).

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Choice^® 1.4 rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” and “Rider Death Benefit Adjustments” below.

The rider withdrawal amount is zero if the annuitant is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and therafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined

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as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider.

If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage— Single Life Option			Withdrawal Percentage— Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.0	%		3.5	%
65-74		5.0	%		4.5	%
³75		6.0	%		5.5	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• Current withdrawal base;

• The withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

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• The policy value on any monthiversary, including the current rider anniversary (see “Automatic Step-Up” below).

Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base. See the “Appendix - Guaranteed Lifetime Benefit Adjustment Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect hypothetical excess withdrawals in more detail.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

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Designated Investment Options.

If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options in the following designated allocation groups:

Designated Allocation Group A

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

American Funds – Asset Allocation Fund – Class 2

Fidelity VIP Balanced Portfolio – Service Class 2

Franklin Templeton VIP Founding Funds Allocation Fund – Class 4

Transamerica AEGON Active Asset Allocation – Moderate Growth VP – Service Class

Transamerica Asset Allocation – Moderate Growth VP – Service Class

Transamerica International Moderate Growth VP – Service Class

Transamerica Multi-Managed Balanced VP – Service Class

Transamerica Efficient Markets VP – Service Class

Transamerica Index 75 VP – Service Class

GE Investments Total Return Fund – Class 3

Designated Allocation Group B

Transamerica AEGON Active Asset Allocation – Moderate VP – Service Class

Transamerica Asset Allocation – Moderate VP – Service Class

Transamerica BlackRock Global Allocation VP – Service Class

Transamerica BlackRock Tactical Allocation VP – Service Class

Transamerica Index 50 VP – Service Class

Designated Allocation Group C

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Transamerica AEGON Active Asset Allocation – Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Asset Allocation – Conservative VP – Service Class

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Index 35 VP – Service Class American Funds – Bond Fund – Class 2

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Within 30 days following the fifth rider anniversary (and each successive fifth rider anniversary), you can terminate this rider. Starting the next business day, you may transfer (or allocate premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can change a designated allocation group or eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected

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designated investment options to other designated investment options that meet the allocation requirements.

Manual Upgrades. You can upgrade the withdrawal base to the policy value during the 30-day period following each successive fifth rider anniversary by sending us written notice in a form acceptable to us, as long as the rider issue requirements for a new rider are met. At this time the rider withdrawal amount and, if applicable, the rider death benefit will be recalculated. If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, its own rider fee percentage (which may be higher or lower than your current rider fee percentage) and its own terms and benefits (which may not be as advantageous as the current rider); and any options you elect to change or add. The new rider date will be the date the Company receives all necessary information in good order. You cannot elect a manual upgrade if the annuitant (or the annuitant’s spouse if younger and the joint option is elected) is 86 or older.

Retirement Income Choice^® 1.4 – Additional Options

You may elect the following options with this rider (the options are not mutually exclusive):

• Death Benefit;

• Joint Life; and

• Income Enhancement.

There is an additional fee if you elect the Death Benefit and/or the Income Enhancement Benefit option(s) under the rider. If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower. Furthermore, if you elect the Joint Life option in combination with the Death Benefit and/or the Income Enhancement Benefit option(s), then the fee for each of those additional options will be different than under the Single Life option. See “Retirement Income Choice^® 1.4 Rider and Additional Option Fees”.

1. Death Benefit. If you elect this rider, you can also elect to add an additional amount to the death benefit payable under the base policy, upon the death of the annuitant (or if the joint life option is selected, the annuitant’s spouse). The additional amount will be equal to the excess, if any, of the rider death benefit over the greater of any optional guaranteed minimum death benefit or the base policy death benefit. The additional amount can be zero. See “Section 8. Death Benefit.”

Rider Death Benefit. The rider death benefit on the rider date is the policy value (less any premium enhancement if the rider is added in the first policy year). After the rider date, the rider death benefit is equal to:

• the rider death benefit on the rider date; plus

• subsequent premium payments; less

• adjustments for withdrawals (as described under “Rider Death Benefit Adjustments,” below).

Rider Death Benefit Adjustments. Gross partial withdrawals up to the rider withdrawal amount in a rider year will reduce the rider death benefit on a dollar-for-dollar basis. Gross partial withdrawals in excess of the rider withdrawal amount in a rider year will reduce the rider death benefit by the greater of the dollar amount of the excess withdrawal or a pro rata amount (in proportion to the reduction in policy value), and possibly to zero. See “Appendix -Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that results in pro rata adjustments. Rider death benefit adjustments occur immediately following all withdrawals.

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Please note:

• No additional death benefit is payable if the base policy death benefit (including the guaranteed minimum death benefit) exceeds the rider death benefit. The greater the death benefit payable under the guaranteed minimum death benefit selected, the more likely it is that an additional amount will not be payable under the rider death benefit option.

• Excess withdrawals may eliminate the additional death benefit available with this rider. You will continue to pay the fee for this option, even if the additional death benefit available under the rider is $0.

• Manual upgrades to the withdrawal base will result in a recalculation of the rider death benefit. However, automatic step-ups will not reset the rider death benefit.

• If an owner who is not the annuitant dies and the surviving spouse continues the policy, then no additional amount is payable. If the policy is not continued, then the surviving owner (who is also the sole beneficiary) may elect to receive lifetime annuity payments equal to the rider withdrawal amount divided by the number of payments each year instead of receiving the policy’s cash value. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

The additional death benefit payment option may be referred to as “minimum remaining withdrawal amount” on your policy statement and other documents.

2. Joint Life Benefit. If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

Please note:

• The withdrawal percentage for each “age at the time of first withdrawal” is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The rider death benefit is not payable until the death of the surviving spouse, if you elect this option.

• You cannot elect a manual upgrade if the annuitant or annuitant’s spouse is 86 or older (lower if required by state law).

3. Income Enhancement Option. If you elect this rider, you can also elect to have your withdrawal percentage double if either the annuitant (or the annuitant’s spouse if the joint life option is elected) is confined, due to a medical necessity in a hospital or nursing facility due to physical or cognitive ailments. Benefits from this option are not available unless the rider has been in effect for 12 months (the “waiting period”) and confinement must meet the elimination period of 180 days within the last 365 days. The elimination period and waiting period can, but do not need to, run concurrently.

Please note:

• You cannot elect the Income Enhancement Option if the individual(s) is/are already confined in a hospital or nursing facility.

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• Confinement must be prescribed by a physician based on the individual’s inability to sustain themselves outside of a hospital or nursing facility due to physical or cognitive ailments.

• The increase to the withdrawal percentage stops when the qualifying person or persons is/are no longer confined as described above.

• The hospital and/or nursing facility must meet the criteria listed below to qualify for the benefit.

• You cannot elect the Income Enhancement Option if you are confined in an assisted living facility or a residential care facility.

A Qualifying Hospital must meet the following criteria:

• It is operated pursuant to the laws of the jurisdiction in which it is located;

• It is operated primarily for the care and treatment of sick and injured persons on an inpatient basis;

• It provides 24-hour nursing service by or under the supervision of registered graduate professional nurses;

• It is supervised by a staff of one or more licensed physicians; and

• It has medical, surgical and diagnostic facilities or access to such facilities.

A Qualifying Nursing Facility must meet the following criteria:

• It is operated pursuant to the laws and regulations of the state in which it is located as a nursing facility or Alzheimer’s disease facility;

• It provides care performed or supervised by a registered graduate nurse;

• It provides room and board accommodations; and

• Will provide 24-hour nursing services, 7 days a week by an on-site Registered Nurse and related services on a continuing inpatient basis.

• It has a planned program of policies and procedures developed with the advice of, and periodically reviewed by, at least one physician; and

• It maintains a clinical record of each patient.

A Qualifying Nursing Facility does not include:

• Assisted living facilities or residential care facilities;

• A place primarily for treatment of mental or nervous disorders, drug addiction or alcoholism;

• A home for the aged, a rest home, community living center or a place that provides domestic, resident, retirement or educational care;

• Personal care homes, personal care boarding homes, residential or domiciliary care homes;

• A rehabilitation hospital or basic care facilities;

• Adult foster care facilities, congregate care facilities, family and group living assisted living facilities; or

• Other facilities similar to those described above.

We will require confirmation of confinement in a qualifying hospital or a qualifying nursing facility while benefit payouts are being received. Confirmation of that confinement will be attained and approved by completing our “Income Enhancement Election and Proof of Confinement Questionnaire” form. This form requires additional proof of confinement which may be a physician’s statement, a statement from a hospital or nursing facility administrator, or any other information satisfactory to us which may include information from third party or company interviews and/or visits of the facility. If it is determined that the qualifying individual was not confined in an eligible facility as defined above and has received payments under the Income Enhancement Option, those payments could be considered an excess withdrawal and have a negative effect on the rider values. If confinement ceases, you may re-qualify by satisfying another 180-day elimination period requirement.

Retirement Income Choice^® 1.4 Fees

Retirement Income Choice^® 1.4 Base Rider Fee. The base rider fee is calculated on the rider date and at the beginning of each rider quarter. The base rider fee

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will be adjusted for any premium additions, excess withdrawals, or transfers between designated investment groups during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the base rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The base quarterly fee is calculated by multiplying (A) by (B) divided by (C) multiplied by (D), where:

(A) is the withdrawal base;

(B) is the sum of each designated investment group’s rider fee percentage multiplied by the applicable designated investment group’s value;

(C) is the total policy value; and

(D) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the base rider fee:

• Because the base rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the base rider fee is a percentage of the withdrawal base, the amount of the base rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

• If you make a transfer from one designated allocation group to another designated allocation group that has a higher rider fee percentage, then the resulting rider fee will be higher.

Base Rider Fee Adjustment for Transfers. For transfers that you make between different designated investment options in different designated allocation groups on other than the first business day of a rider quarter, a “rider fee adjustment” will be applied. This adjustment is necessary because of differences in the rider fee percentages. The adjustment in the rider fee percentage will ensure that you are charged the correct overall rider fee. The base rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated.

Base Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will also be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. As with the rider fee adjustments calculated for transfers, the rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

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Additional Option Fees. If you elect options with this rider, then you will be charged a fee for each option you elect that is in addition to the rider fee for the base benefit (see the Fee Table). Each additional fee is charged quarterly before annuitization and is a percentage of the withdrawal base on each rider anniversary.

We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

Retirement Income Choice^® 1.4 Rider Issue Requirements

The Company will not issue the Retirement Income Choice^® 1.4 rider unless:

• the annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Choice^® 1.4 rider and any additional options will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Choice^® 1.4 rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Choice^® 1.4 rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Income Link^® Rider

You may elect to purchase the optional Income Link^® rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit that uses a higher withdrawal percentage for a defined period of time and then resets to a lower percentage (see the “Withdrawal Options and Percentages” section); and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified

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policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Income Link^® rider for a qualified policy. The date this rider is added to your policy is the “rider date.” You choose the date of the first Income Link^® rider systematic withdrawal, which is the Income Link^® rider start date. If you elect the Income Link^® rider you cannot elect another GLWB.

Income Link^® Rider – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each Income Link^® rider withdrawal year (first as systematic withdrawals from your policy value and, if necessary, as systematic payments from us), beginning on the Income Link^® rider start date and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of a non-Income Link^® rider systematic withdrawal; see Withdrawal Base Adjustments below). The first Income Link^® rider withdrawal year begins on the Income Link^® rider start date and each successive Income Link^® rider withdrawal year begins thereafter on each anniversary of that date.

Income Link^® Rider – Systematic Withdrawals. In order to begin receiving Income Link^® rider systematic withdrawals, you must elect the withdrawal option and frequency (monthly, quarterly, semi-annually or annually) through which you will receive the Income Link^® rider systematic withdrawals (for qualified policies you will also have to elect whether or not to receive your minimum required distribution amount as calculated herein). Any change to the frequency of your Income Link^® rider systematic withdrawals will take effect at the beginning of the next Income Link^® rider withdrawal year. Any other withdrawal, regardless of amount or timing, is a non-Income Link^® rider systematic withdrawal. See “Withdrawal Base Adjustments”.

Of course, you can always withdraw any amount up to your cash value pursuant to your rights under the policy at your discretion however, withdrawals other than Income Link^® rider systematic withdrawals (and certain minimum required distributions) will reduce the withdrawal base. See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Income Link^® Rider” for an example showing the effect of a hypothetical withdrawal in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for Income Link^® rider systematic withdrawals from your policy value each Income Link^® rider withdrawal year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount or on a non-systematic basis, because such withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• Depending on which withdrawal option you elect, your withdrawal percentage will decrease after second, third, fourth, fifth, sixth or seventh withdrawal year.

• The longer you wait to start taking Income Link^® rider systematic withdrawals under the rider, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular Income Link^® rider systematic withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need

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for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you in determining whether these certain investment options are suited for your financial needs and risk tolerance.

• Any withdrawal that is not an Income Link^® rider systematic withdrawal (or certain minimum required distributions) will decrease the withdrawal base; the impact may be on a greater than dollar-for-dollar basis.

• During any Income Link^® rider withdrawal year, if there is a withdrawal base adjustment, the remaining rider withdrawal amount and the Income Link^® rider systematic withdrawal amount will increase or decrease by the same percentage as the withdrawal base.

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Income Link^® rider terminates and all benefits thereunder cease.

• The only way to receive withdrawals (either Income Link^® rider systematic withdrawals or minimum required distributions) without causing an adjustment to the withdrawal base is to use the Income Link^® rider systematic withdrawal programs.

Like all withdrawals, Income Link^® rider systematic withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce the amount you can withdraw “adjustment free” as a minimum required distribution;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount systematically each Income Link^® rider withdrawal year from your policy value without causing an adjustment. See “Withdrawal Base Adjustments” below. You must use a systematic withdrawal program to withdraw your rider withdrawal amount. Such withdrawals are Income Link^® rider systematic withdrawals. Any withdrawal other than an Income Link^® rider systematic withdrawal is considered a non-Income Link^® rider systematic withdrawal and will result in a withdrawal base adjustment (except for certain minimum required distributions, see “Minimum Required Distribution”).

The annual rider withdrawal amount is zero until Income Link^® rider start date. On the Income Link^® rider start date and at the beginning of each Income Link^® rider withdrawal year thereafter, the annual rider withdrawal amount is equal to the applicable withdrawal percentage (based on the withdrawal option you elect) multiplied by the withdrawal base. During any Income Link^® rider withdrawal year, the rider withdrawal amount and Income Link^® rider systematic withdrawal amount may be adjusted up or down as described in the Withdrawal Base Adjustment section.

Minimum Required Distribution: Prior to the Income Link^® rider start date, the systematic withdrawal of the minimum required distribution amount (determined as set forth below) will not cause an adjustment. After the Income Link^® rider start date, the withdrawal of the minimum required distribution amount (determined as set forth below) will not cause an adjustment to the withdrawal base; however, it must be withdrawn pursuant to an Income Link^® rider systematic withdrawal program whereby you will receive your Income Link^® rider systematic withdrawals and any remaining minimum required

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distribution amount as calculated herein distributed at the end of the applicable calendar year (not at the end of the applicable rider year).

If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, you can withdraw via a systematic withdrawal option, an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years). Minimum required distribution amounts calculated as set forth above and taken via a systematic withdrawal option will not cause an adjustment under this provision of the rider. Any withdrawal during a calendar year will reduce the withdrawal base adjustment free minimum required distribution amount for that year.

Please note: If you want to change the mode of the systematic withdrawal through which you are receiving your “adjustment free” minimum required distribution, your change will not take effect until the next anniversary of your systematic withdrawal program. Likewise, if you stop a systematic withdrawal program you cannot restart a new systematic program until the date that would have been the anniversary of the systematic withdrawal program you stopped. (For example, if you started a monthly systematic withdrawal program to receive your “adjustment free” minimum required distribution amount on August 19, 2010, and stopped it on December 21, 2010, you could not restart a new systematic withdrawal program until August 19, 2011.)

If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• The rider withdrawal amount will be zero until the Income Link^® rider start date, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during an Income Link^® rider withdrawal year for withdrawal in a future Income Link^® rider withdrawal year. This means that if you do not take the entire rider withdrawal amount during an Income Link^® rider withdrawal year, you cannot take more than the rider withdrawal amount in the next Income Link^® rider withdrawal year and maintain the rider’s guarantees.

• Non-Income Link^® rider systematic withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Options and Percentages. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the withdrawal option you select. The withdrawal percentages, categorized by withdrawal option, are as follows:

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Withdrawal Option— number years at increased rate	Withdrawal Percentage— Single Life Option	Withdrawal Percentage— Joint Life Option
7 years	5% for 7 years and 4% thereafter	4.5% for 7 years and 3.5% thereafter
6 years	6% for 6 years and 4% thereafter	5.5% for 6 years and 3.5% thereafter
5 years	7% for 5 years and 4% thereafter	6.5% for 5 years and 3.5% thereafter
4 years	8% for 4 years and 4% thereafter	7.5% for 4 years and 3.5% thereafter
3 years	9% for 3 years and 4% thereafter	8.5% for 3 years and 3.5% thereafter
2 years	10% for 2 years and 4% thereafter	9.5% for 2 years and 3.5% thereafter

Please note, once established, the withdrawal percentage will not increase.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to non-Income Link^® rider systematic withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greater of:

• current withdrawal base or;

• the Automatic Step-up amount (see “Automatic Step-Up” below).

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary^SM during the preceding rider year, if no non-Income Link^® rider systematic withdrawal occurred, or (2) the policy value on the rider anniversary.

The rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Please note:

• The withdrawal base “steps-up” on rider anniversaries whereas a Income Link^® rider withdrawal year begins on the Income Link^® rider start date and each anniversary thereof.

• If an automatic step-up occurs, your remaining rider withdrawal amount and Income Link^® rider systematic withdrawal amount is proportionally increased for the remainder of that Income Link^® rider withdrawal year.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up

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occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Premium additions will increase the withdrawal base on a dollar-for-dollar basis. See “Automatic Step-Up” for a description of how automatic step-ups increase the withdrawal base.

Income Link^® rider systematic withdrawals up to the rider withdrawal amount will not reduce the withdrawal base. Non-Income Link^® rider systematic withdrawals will reduce the withdrawal base, however, by the greater of the dollar amount of the withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Income Link^® Rider” for examples showing the effect of hypothetical withdrawals in more detail. The effect of a negative adjustment is amplified if the policy value is less than the withdrawal base. See the “Appendix - Guaranteed Lifetime Benefit Adjustment Partial Surrenders - Income Link^® Rider” for examples showing the effect of hypothetical non-Income Link^® rider systematic withdrawals in more detail, including a non-Income Link^® rider systematic withdrawal that reduces the withdrawal base by a pro rata amount. Withdrawal base adjustments occur immediately following premium additions or non-Income Link^® rider systematic withdrawals. If you take a non-Income Link^® rider systematic withdrawal that reduces your policy value (and withdrawal base) to zero, then the Income Link^® rider will terminate and you will lose all its benefits.

Please Note: We do not monitor for non-Income Link^® rider systematic withdrawals or notify you of withdrawal base adjustments. If you take a non-Income Link^® rider systematic withdrawal please note your Income Link^® rider systematic withdrawal amount will be reduced.

Designated Investment Options. If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options:

Transamerica AEGON Active Asset Allocation – Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Transamerica Asset Allocation – Conservative VP – Service Class

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Index 35 VP – Service Class

American Funds – Bond Fund – Class 2

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Following the fifth rider anniversary you can terminate this rider. Starting the next business day, you may transfer (or allocate

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premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Income Link^® Rider – Joint Life Option

If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower.

Please note:

• The withdrawal percentage for each withdrawal option is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

Income Link^® Rider Fees

Income Link^® Rider Fee. The rider fee is calculated on the rider date and at the beginning of each rider quarter. The rider fee will be adjusted for any premium additions and non-Income Link^® rider systematic withdrawals during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The quarterly fee is calculated by multiplying (A) by (B) by (C), where:

(A) is the withdrawal base;

(B) rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the first rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

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Please note regarding the rider fee:

• Because the rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the rider fee is a percentage of the withdrawal base, the amount of the rider fee we deduct will increase if the withdrawal base increases (although the percentage will remain the same).

Rider Fee Adjustment for Withdrawal Base Adjustments. A rider fee adjustment will also be calculated for subsequent premium payments and non-Income Link^® rider systematic withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider.

Income Link^® Rider Issue Requirements

The Company will not issue the Income Link^® rider unless:

• the annuitant is at least 55 years old and not yet 81 years old (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is at least 55 years old and not yet 81 years old (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Income Link^® rider will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us following the fifth rider anniversary;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Income Link^® rider may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Income Link^® rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

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Retirement Income Max^SM Rider

You may elect to purchase the optional Retirement Income Max^SM rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Max^SM rider for a qualified policy. If you elect the Retirement Income Max^SM rider you cannot elect another GLWB.

Retirement Income Max^SM – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary because your policy value goes to zero by other than an excess withdrawal, as payments from us for life), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s (or surviving spouse’s if the joint life option is elected) death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments, below). A rider year begins on the rider date and thereafter on each anniversary of that date.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Max^SM Rider” for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever.

We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantee provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you in determining whether these certain investment options are suited for your financial needs and risk tolerance.

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• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base on a greater than dollar-for-dollar basis.

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Max^SM rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” below.

The rider withdrawal amount is zero if the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s (or the annuitant’s spouse’s if younger and the joint life option is elected) 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Max^SM Rider” for an example showing the effect of a minimum required distribution amount.

If your policy value reaches zero:

• due to a non-excess withdrawal, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, (i.e., payments of the rider withdrawal amount for life) you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

• due to an excess withdrawal, then this rider terminates (as does the policy).

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Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse’s age if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse’s if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage— Single Life Option			Withdrawal Percentage— Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.5	%		4.10	%
65-74		5.5	%		5.10	%
³75		6.5	%		6.10	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• current withdrawal base;

• the withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

• the policy value on any monthiversary^SM , (the same day of the month as the rider date, or the next business day if our Administrative Office or the New York Stock Exchange are closed) including the current rider anniversary (see “Automatic Step-Up” below).

See “Appendix – Hypothetical Example of the Withdrawal Base Calculation – Retirement Income Max^SM Rider” which illustrates the hypothetical example of the withdrawal base calculation.

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Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary^SM during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

On each rider anniversary the rider fee percentage may increase (or decrease) up to 75 basis points (0.75%) at the time of any automatic step-up (but will not exceed the maximum rider fee percentage in the fee table), i.e., the rider fee percentage is reset to the rider fee percentage then associated with newly issued riders.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. If an excess withdrawal reduces the policy value to zero, this rider will terminate. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Retirement Income Max^SM Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

Designated Investment Options. If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options:

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American Funds – Bond Fund – Class 2

Transamerica AEGON Active Asset Allocation -Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Transamerica Asset Allocation – Conservative VP –Service Class

Transamerica Asset Allocation – Moderate VP –Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica JPMorgan Core Bond VP – Service Class

Transamerica JPMorgan Tactical Allocation VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Within 30 days following the fifth rider anniversary (and each successive fifth rider anniversary), you can terminate this rider. Starting the next business day, you may transfer (or allocate premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Retirement Income Max^SM – Joint Life Option

If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy). If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower.

Please note:

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The withdrawal percentage for each “age at the time of the first withdrawal” is lower if you elect this option.

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Retirement Income Max^SM Rider Fees

Retirement Income Max^SM. The rider fee is calculated on the rider date and at the beginning of each rider quarter. The rider fee will be adjusted for any premium additions and excess withdrawals. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the rider fee is the “rider fee percentage” (see the Fee Table) times the withdrawal base. Specifically, the quarterly fee is calculated by multiplying (A) by (B) multiplied by (C), where:

(A) is the withdrawal base;

(B) is the rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

Example 1: Calculation at rider issue for first quarter rider fee assuming an initial withdrawal base of $100,000.

=100,000*0.01(91/365)

=1,000*(91/365)

=$249.32

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

On each rider anniversary the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up results in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the rider fee:

• Because the rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the rider fee is a percentage of the withdrawal base, the amount of the rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

Example 2: Calculation for first quarter fee assuming initial withdrawal base from Example 1 above, plus adjustment for additional premium payment of $10,000 made with 20 days remaining in the first rider quarter. The withdrawal base change equals $10,000. Fee adjustment as follows:

=10,000*0.01(20/365)

=100*(20/365)

=$5.48

Total fee assessed at the end of the first rider quarter (assuming no further rider fee adjustments):

=5.48 + 249.32

=$254.80

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We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

Retirement Income Max^SM Rider Issue Requirements

The Company will not issue the Retirement Income Max^SM rider unless:

• The annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Max^SM rider will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or if the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Max^SM rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Max^SM rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

11. OTHER INFORMATION

Ownership

You, as owner of the policy, exercise all rights under the policy. You can change the owner at any time by notifying us in writing at our Administrative and Service Office. An ownership change may be a taxable event.

Beneficiary

The beneficiary designation will remain in effect until changed. The owner may change the designated beneficiary by sending written notice to the Company. The beneficiary’s consent to such change is not required unless the beneficiary was irrevocably designated or law requires consent. (If an irrevocable beneficiary dies, the owner may then designate a new beneficiary.) The change will take effect as of the date the owner signs the written notice, whether or not the owner is living when the notice is received by the Company. The Company will not be liable for any payment made before the written notice is received. If more than one beneficiary is designated, and the

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owner fails to specifiy their interests, they will share equally. If, upon the death of the annuitant, there is a surviving owner(s), then the surviving owner(s) automatically takes the place of any beneficiary designation.

Right to Cancel Period

You may return your policy for a refund, but only if you return it within a prescribed period, which is generally 10 days (after you receive the policy), or whatever longer time may be required by state law. The amount of the refund will generally be the premiums paid plus or minus accumulated gains or losses in the separate account. You bear the risk of any decline in policy value during the right to cancel period. However, if state law requires, we will refund your original premium payment(s). We will pay the refund within seven days after we receive in good order within the applicable period at our Administrative and Service Office, written notice of cancellation and the returned policy. The policy will then be deemed void.

Assignment

You can also generally assign the policy any time during your lifetime. We will not be bound by the assignment until we receive written notice of the assignment in good order at our Administrative and Service Office and approve it. We reserve the right, except to the extent prohibited by applicable laws, regulations, or actions of the State insurance commissioner, to require that an assignment will be effective only upon acceptance by us, and to refuse assignments or transfers at any time on a non-discriminatory basis. We will not be liable for any payment or other action we take in accordance with the policy before we approve the assignment. There may be limitations on your ability to assign a qualified policy. An assignment may have tax consequences.

Sending Forms and Transaction Requests in Good Order

We cannot process your requests for transactions relating to the policy until we have received them in good order at our Administrative and Service Office. “good order” means the actual receipt by us of the instructions relating to the requested transaction in writing (or, when appropriate, by telephone or electronically, along with all forms, information and supporting legal documentation necessary to effect the transaction. This information and documentation generally includes, to the extend applicable to the transaction: your completed application; the policy number; the transaction amount (in dollars or percentage terms); the names and allocations to and/or from the Subaccounts affected by the requested transaction; the signatures of all policy owners (exactly as registered on the Policy) if necessary; Social Security Number or Taxpayer I.D.; and any other information or supporting documentation that we may require, including any spousal or joint owner’s consents. With respect to purchase requests, “good order” also generally includes receipt (by us) of sufficient funds 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.

Mixed and Shared Funding

Before making a decision concerning the allocation of premium payments to a particular subaccount, please read the prospectuses for the underlying fund portfolios. The underlying fund portfolios are not limited to selling their shares to this separate account and can accept investments from any insurance company separate account or qualified retirement plan. Since the underlying fund portfolios are available to registered separate accounts offering variable annuity products of the Company, as well as variable annuity and variable life products of other insurance companies, and qualified retirement plans,

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there is a possibility that a material conflict may arise between the interests of this separate account and one or more of the other separate accounts of another participating insurance company. In the event of a material conflict, the affected insurance companies, including the Company, agree to take any necessary steps to resolve the matter. This may include removing their separate accounts from the underlying fund portfolios. See the underlying fund portfolios prospectuses for more details.

Exchanges and Reinstatements

You can generally exchange one annuity policy for another in a “tax-free exchange” under Section 1035 of the Internal Revenue Code. Before making an exchange, you should compare both annuities carefully. Remember that if you exchange another annuity for the one described in this prospectus, then you may pay a surrender charge on the other annuity, and there will be a new surrender charge period under this annuity and other charges may be higher (or lower) and the benefits under this annuity may be different. You should not exchange another annuity for this one unless you determine, after knowing all the facts, that the exchange is in your best interest and not just better for the person trying to sell you this policy (that person will generally earn a commission if you buy this policy through an exchange or otherwise).

You may surrender your policy and transfer your money directly to another life insurance company (sometimes referred to as a 1035 Exchange or a trustee-to-trustee transfer). You may also ask us to reinstate your policy after such a transfer and in certain limited circumstances we will allow you to do so by returning the same total dollar amount of funds to the applicable investment choices. The dollar amount will be used to purchase new accumulation units at the then current price. Because of changes in market value, your new accumulation units may be worth more or less than the units you previously owned. We recommend that you consult a tax professional to explain the possible tax consequences of exchanges and/or reinstatements.

Voting Rights

To the extent required by law, the Company will vote all shares of the underlying fund portfolios held in the separate account in accordance with instructions we receive from you and other owners that have voting interests in the portfolios. We will send you and other owners requests for instructions on how to vote those shares. When we receive those instructions, we will vote all of the shares in proportion to those instructions. Accordingly, it is possible for a small number of policy owners (assuming there is a quorum) to determine the outcome of a vote, especially if they have large policy values. If, however, we determine that we are permitted to vote the shares in our own right, we may do so.

Each person having a voting interest will receive proxy material, reports, and other materials relating to the appropriate portfolio.

Legal Proceedings

There are no legal proceedings to which the separate account is a party or to which the assets of the separate account are subject. The Company, like other life insurance companies, is involved in lawsuits. In some class action and other lawsuits involving other insurers, substantial damages have been sought and/or material settlement payments have been made. Although the outcome of any litigation cannot be predicted with certainty, the Company believes that at the present time there are no pending or threatened lawsuits that are reasonably likely to have a material adverse impact on the separate account, on the ability of Transamerica Capital, Inc., to perform under its principal underwriting agreement, or on the ability of the Company to meet its obligations under the policy.

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Transamerica Life Insurance Company

Transamerica Life Insurance Company was incorporated under the laws of the State of Iowa on April 19, 1961 as NN Investors Life Insurance Company, Inc. It is engaged in the sale of life and health insurance and annuity policies. The Company is a wholly-owned indirect subsidiary of Transamerica Corporation which conducts most of its operations through subsidiary companies engaged in the insurance business or in providing non-insurance financial services. All of the stock of Transamerica Corporation is indirectly owned by AEGON N.V. of The Netherlands, the securities of which are publicly traded. AEGON N.V., a holding company, conducts its business through subsidiary companies engaged primarily in the insurance business. The Company is licensed in the District of Columbia, Guam, Puerto Rico, the U.S. Virgin Islands, and all states except New York.

All obligations arising under the policies, including the promise to make annuity payments, are general corporate obligations of the Company. Accordingly, no financial institution, brokerage firm or insurance agency is responsible for the financial obligations of the Company arising under the policies.

Financial Condition of the Company

We pay benefits under your Contract from our general account assets and/or from your policy value held in the separate account. It is important that you understand that payments of the benefits depend upon certain factors discussed below.

Assets in the Separate Account.You assume all of the investment risk for your policy value that is allocated to the subaccounts of the separate account. Your policy value in those subaccounts constitutes a portion of the assets of the separate account. These assets are segregated and insulated from our general account, and may not be charged with liabilities arising from any other business that we may conduct.

Assets in the General Account. You also may be permitted to make allocations to guaranteed period options of the fixed account, which are supported by the assets in our general account. Any guarantees under a policy that exceed policy value, such as those associated with any lifetime withdrawal benefit riders and any optional death benefits, are paid from our general account (and not the separate account). Therefore, any amounts that we may be obligated to pay under the policy in excess of policy value are subject to our financial strength and claims-paying ability and our long-term ability to make such payments. The assets of the separate account, however, are also available to cover the liabilities of our general account, but only to the extent that the separate account assets exceed the separate account liabilities arising under the policies supported by it.

We issue other types of insurance policies and financial products as well, and we also pay our obligations under these products from our assets in the general account.

Our Financial Condition. As an insurance company, we are required by state insurance regulation to hold a specified amount of reserves in order to meet all the contractual obligations of our general account. In order to meet our claims-paying obligation we monitor our reserves so that we hold sufficient amounts to cover actual or expected policy and claims payments. However, it is important to note that there are risks to purchasing any insurance product.

State insurance regulators also require insurance companies to maintain a minimum amount of capital, which acts as a cushion in the event that the insurer suffers a financial impairment, based on the inherent risks in the insurer’s operations. These risks include those associated with losses that we may incur as the result of defaults on the payment of interest or principal on our general account assets,

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which include bonds, mortgages, general real estate investments, and stocks, as well as the loss in market value of these investments.

How to Obtain More Information. We encourage both existing and prospective policy owners to read and understand our financial statements. We prepare our financial statements on a statutory basis. Our financial statements, which are presented in conformity with accounting practices prescribed or permitted by the Iowa Department of Commerce, Insurance Division as well as the financial statements of the separate account—are located in the statement of Additional Information (SAI). For a free copy of the SAI, simply call or write us at the phone number or address of our Administrative and Service Office referenced in this prospectus. In addition, the SAI’s available on the SEC;s website at http://www.sec.gov. Our financial strength can be found on our website.

The Separate Account

The Company established a separate account, called Separate Account VA C, under the laws of the State of Iowa on February 20, 1997. The separate account receives and invests the premium payments that are allocated to it for investment in shares of the underlying fund portfolios.

The separate account is registered with the SEC as a unit investment trust under the 1940 Act. However, the SEC does not supervise the management, the investment practices, or the policies of the separate account or the Company. Income, gains and losses (whether or not realized), from assets allocated to the separate account are, in accordance with the policies, credited to or charged against the separate account without regard to the Company’s other income, gains or losses.

The assets of the separate account are held in the Company’s name on behalf of the separate account and belong to the Company. However, those assets that underlie the policies are not chargeable with liabilities arising out of any other business the Company may conduct. The separate account may include other subaccounts that are not available under these policies.

Distribution of the Policies

Distribution and Principal Underwriting Agreement. We have entered into a principal underwriting agreement with our affiliate, Transamerica Capital, Inc. (TCI), for the distribution and sale of the policies. We pay commissions to TCI which are passed through to selling firms. (See below). We also pay TCI an “override” that is a percentage of total commissions paid on sales of our policies which is not passed through to the selling firms and we may reimburse TCI for certain expenses it incurs in order to pay for the distribution of the policies. TCI markets the policies through bank affiliated firms, national brokerage firms, regional and independent broker-dealers and independent financial planners.

Compensation to Broker-Dealers Selling the Policies. The policies are offered to the public through broker-dealers (“selling firms”) that are licensed under the federal securities laws; the selling firm and/or its affiliates are also licensed under state insurance laws. The selling firms have entered into written selling agreements with us and with TCI as principal underwriter for the policies. We pay commissions through TCI to the selling firms for their sales of the policies.

A limited number of affiliated and unaffiliated broker-dealers may also be paid commissions and overrides to “wholesale” the policies, that is, to provide sales support and training to sales representatives at the selling firms. We also provide compensation to a limited number of broker-dealers for providing ongoing service in relation to the policies that have already been purchased.

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The selling firms that have selling agreements with us and TCI are paid commissions for the promotion and sale of the policies according to one or more schedules. The amount and timing of commissions may vary depending on the selling agreement, but the maximum commission is 6% of premiums (additional amounts may be paid as overrides to wholesalers).

To the extent permitted by Financial Industry Regulatory Authority (FINRA) rules, TCI may pay (or allow other broker-dealers to provide) promotional incentives or payments in the form of cash or non-cash compensation or reimbursement to some, but not all, selling firms and their sales representatives. These arrangements are sometimes referred to as “revenue sharing” arrangements and are described further below.

The sales representative who sells you the policy typically receives a portion of the compensation we (and our affiliates) pay to the selling firms, depending on the agreement between the selling firm and its registered representative and the firm’s internal compensation program. These programs may include other types of cash and non-cash compensation and other benefits. Ask your sales representative for further information about the compensation your sales representative, and the selling firm that employs your sales representative, may receive in connection with your purchase of a policy. Also inquire about any revenue sharing arrangements that we and our affiliates may have with the selling firm, including the conflicts of interests that such arrangements may create.

You should be aware that a selling firm or its sales representatives may receive different compensation or incentives for selling one product over another. In some cases, these differences may create an incentive for the selling firm or its sales representatives to recommend or sell this policy to you. You may wish to take such incentives into account when considering and evaluating any recommendation relating to the policies.

Special Compensation Paid to Affiliated Firms.

We and/or our affiliates provide paid-in capital to TCI and pay the cost of TCI’s operating and other expenses, including costs for facilities, legal and accounting services, and other internal administrative functions. We and/or our affiliates also provide TCI with a percentage of total commissions paid on sales of our policies and provide TCI with capital payments that are not contingent on sales.

TCI’s registered representatives and supervisors may receive non-cash compensation, such as attendance at conferences, seminars and trips (such as travel, lodging and meals in connection therewith), entertainment, merchandise and other similar items, payments, loans, loan forgiveness or loan guaranties.

Additional Compensation That We, TCI and/or Our Affiliates Pay to Selected Selling Firms. TCI, in connection with the sales of the policies, may pay certain selling firms additional cash amounts for “preferred product” treatment of the policies in their marketing programs in order to receive enhanced marketing services and increased access to their sales representatives. In exchange for providing TCI with access to their distribution network, such selling firms may receive additional compensation or reimbursement for, among other things, the hiring and training of sales personnel, marketing, sponsoring of conferences, meetings, seminars, events, and/or other services they provide to us and our affiliates. To the extent permitted by applicable law, TCI and other parties may provide the selling firms with occasional gifts, meals, tickets or other non-cash compensation as an incentive to sell the policies. These special compensation arrangements are not offered to all selling firms and the terms of such arrangements may differ among selling firms.

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Special compensation arrangements are calculated in different ways by different selling firms and may be based on past or anticipated sales of the policies and other criteria. For instance, in 2010, TCI, in connection with the sales of our policies, made flat fee payments to several selling firms ranging from $6,350 to $500,000, and payments of between 0.10% and 1.32% on new sales. TCI also paid selling firms special fees based on new sales and/or assets under management.

During 2010, we and/or TCI had such “preferred product” arrangements with the following selling firms:

AXA

Carillon Financial

Centarus Financial

CFD Investments

Citizens Bank

Compass Bank

Equity Services

Financial Advisors of America

Financial Network

Fintegra

Genworth Financial

Girard Securities

Hantz Financial

Huntington Bank

Independent Financial Group

Invest Financial Corporation

James T. Borello

Kovack Securities

LPL Financial

M&T Bank

Merrill Lynch

Money Concepts

Morgan Stanley Smith Barney

Multi Family Securities Corp

Multi Financial

National Planning Corporation

Newbridge Securities

NEXT Financial Group

Park Avenue Securities

Primevest

ProEquities

Raymond James and Associates

Raymond James Financial Group

Sigma Financial

Signator Investments

SII Investments

Summit Equities

Suntrust Bank

TFS Securities, Inc.

The Planners Network

Transamerica Financial Advisors

UBS Financial

UnionBanc Investment Services LLC

US Bancorp

Valmark Securities

Wells Fargo/Wachovia

World Equity Group

Word Group Securities

During 2010, in conjunction with TCI, we paid the following amounts (in addition to sales commissions) to the top 10 selling firms (in terms of amounts paid):

Name of Firm	Amount Paid in 2010
Wells Fargo/Wachovia	$	1,327,561
LPL Financial	$	1,170,949
Morgan Stanley Smith Barney	$	1,122,219
Merrill Lynch	$	810,000
Transamerica Financial Advisors	$	750,789
UBS Financial	$	485,097
Raymond James Financial Services	$	426,264
World Group Securities	$	412,219
National Planning Corporation	$	315,904
Citizens Bank	$	270,113

No specific charge is assessed directly to policy owners or the separate account to cover commissions, non-cash compensation, and other incentives or

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payments described above. We do intend to recoup commissions and other sales expenses and incentives we pay, however, through fees and charges deducted under the policy and other corporate revenue.

TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION

Glossary of Terms

The Policy - General Provisions

Certain Federal Income Tax Consequences

Investment Experience

Historical Performance Data

Published Ratings

State Regulation of Transamerica Life Insurance Company

Administration

Records and Reports

Distribution of the Policies

Voting Rights

Other Products

Custody of Assets

Legal Matters

Independent Registered Public Accounting Firm

Other Information

Financial Statements

Appendix - Condensed Financial Information

Appendix - OA Method Transfers

Appendix - PAM Method Transfers

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APPENDIX

CONDENSED FINANCIAL INFORMATION

The following tables list the accumulation unit value information for accumulation units outstanding for policies with the highest total separate account expenses and policies with the lowest total separate account expenses available on December 31, 2010. Should the total separate account expense applicable to your policy fall between the highest and lowest charges, AND you wish to see a copy of the Condensed Financial Information applicable to your policy, such information is contained in the SAI. You can obtain a copy of the SAI FREE OF CHARGE by contacting us at:

calling:	(800) 525-6205
writing:	Transamerica Life Insurance Company
	4333 Edgewood Road NE
	Cedar Rapids, IA 52499-0001

	Year		2.30%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation - Conservative VP – Service Class Subaccount Inception Date May 1, 2002		2010 2009 2008	$ $ $	0.966309 0.791431 1.000000	$ $ $	1.026829 0.966309 0.791431		1,894,026.276 1,265,314.746 563,870.227
Transamerica Asset Allocation - Moderate VP – Service Class Subaccount Inception Date May 1, 2002		2010 2009 2008	$ $ $	0.940237 0.762186 1.000000	$ $ $	1.012278 0.940237 0.762186		2,164,608.656 2,160,857.065 947,916.482
Transamerica Asset Allocation - Moderate Growth VP – Service Class Subaccount Inception Date May 1, 2002		2010 2009 2008	$ $ $	0.892151 0.713754 1.000000	$ $ $	0.980279 0.892151 0.713754		2,049,109.618 2,362,317.497 1,546,176.982
Transamerica Foxhall Global Conservative VP – Service Class Subaccount Inception Date November 19, 2009		2010 2009	$ $	0.982701 0.995050	$ $	0.902049 0.982701		0.000 0.000
Transamerica International Moderate Growth VP – Service Class Subaccount Inception Date May 1, 2006		2010 2009 2008	$ $ $	0.862757 0.682446 1.000000	$ $ $	0.929740 0.862757 0.682446		1,023,139.890 800,529.083 421,387.192
Transamerica PIMCO Total Return VP – Service Class Subaccount Inception Date May 1, 2002		2010 2009 2008	$ $ $	1.035311 0.914994 1.000000	$ $ $	1.082220 1.035311 0.914994		1,808,308.185 471,475.370 72,995.997
Transamerica Efficient Markets VP – Service Class Subaccount Inception Date November 10, 2008		2010 2009 2008	$ $ $	1.193244 1.035705 1.000000	$ $ $	1.310801 1.193244 1.035705		19,458.844 12,080.282 0.000
Transamerica Multi-Managed Balanced VP – Service Class(1) Subaccount Inception Date May 1, 2002		2010 2009 2008	$ $ $	0.899500 0.730662 1.000000	$ $ $	1.089299 0.899500 0.730662		78,690.849 21,305.971 16,101.843
Transamerica AEGON Money Market VP – Service Class(2) Subaccount Inception Date December 13, 1999		2010 2009 2008	$ $ $	0.975272 0.997589 1.000000	$ $ $	0.953394 0.975272 0.997589		11,889.609 996,690.791 1,357,986.981
Transamerica AEGON U.S. Government Securities VP – Service Class(3) Subaccount Inception Date December 13, 1999		2010 2009 2008	$ $ $	1.046062 1.027019 1.000000	$ $ $	1.065731 1.046062 1.027019		112,033.779 207,171.653 395,944.485
Transamerica Index 35 VP – Service Class Subaccount Inception Date November 19, 2009		2010 2009	$ $	0.997328 0.999938	$ $	1.066785 0.997328		5,707.464 0.000

115

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		2.30%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Index 50 VP – Service Class Subaccount Inception Date May 1, 2008		2010 2009 2008	$ $ $	0.926675 0.813516 1.000000	$ $ $	1.002699 0.926675 0.813516		677,849.205 682,438.411 0.000
Transamerica Index 75 VP – Service Class Subaccount Inception Date May 1, 2008		2010 2009 2008	$ $ $	0.864525 0.717974 1.000000	$ $ $	0.954989 0.864525 0.717974		522,204.389 475,568.355 0.000
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B Subaccount Inception Date Novemeber 10, 2008		2010 2009 2008	$ $ $	1.228584 1.011883 1.000000	$ $ $	1.322043 1.228584 1.011883		275,391.472 27,825.950 0.000
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class (4) Subaccount Inception Date August 16, 2010		2010	$	1.000000	$	1.046195		0.000
American Funds - Asset Allocation Fund – Class 2 Subaccount Inception Date November 19, 2009		2010 2009	$ $	1.007237 0.989760	$ $	1.104500 1.007237		5,496.902 0.000
American Funds - Bond Fund – Class 2 Subaccount Inception Date November 19, 2009		2010 2009	$ $	0.992961 1.000881	$ $	1.030171 0.992961		0.000 0.000
Fidelity VIP Balanced Portfolio – Service Class 2 Subaccount Inception Date May 1, 2008		2010 2009 2008	$ $ $	0.895254 0.662108 1.000000	$ $ $	1.030532 0.895254 0.662108		148,852.626 478,687.414 0.000
Franklin Templeton VIP Founding Funds Allocation Fund – Class 4 Subaccount Inception Date November 10, 2008		2010 2009 2008	$ $ $	1.255873 0.989224 1.000000	$ $ $	1.351386 1.255873 0.989224		232,607.216 198,272.238 0.000
GE Investments Total Return Fund – Class 3 Subaccount Inception Date November 19, 2009		2010 2009	$ $	1.002880 0.988792	$ $	1.070072 1.002880		936.608 0.000

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation – Conservative VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.311504 1.063539 1.370333 1.308178 1.213762 1.171794 1.084641 0.896108 1.000000	$ $ $ $ $ $ $ $ $	1.406840 1.311504 1.063539 1.370333 1.308178 1.213762 1.171794 1.084641 0.896108		2,275,557.711 45,002.562 26,869.950 29,587.249 204,064.232 0.000 228,564.376 315,412.392 119,764.901
Transamerica Asset Allocation – Growth VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.182285 0.924844 1.555945 1.466466 1.287977 1.165251 1.036347 0.804600 1.000000	$ $ $ $ $ $ $ $ $	1.338317 1.182285 0.924844 1.555945 1.466466 1.287977 1.165251 1.036347 0.804600		4,261,574.327 61,344.854 84,805.080 93,704.023 85,317.958 93,689.817 93,961.322 45,928.750 174.81

116

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation – Moderate VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.311197 1.053395 1.444964 1.359333 1.238214 1.170234 1.066862 0.867636 1.000000	$ $ $ $ $ $ $ $ $	1.425170 1.311197 1.053395 1.444964 1.359333 1.238214 1.170234 1.066862 0.867636		3,850,644.854 273,350.542 310,318.177 300,983.353 127,310.594 134,300.445 241,302.481 116,942.124 99.89
Transamerica Asset Allocation – Moderate Growth VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.264418 1.001893 1.513286 1.425519 1.271629 1.174845 1.050773 0.839081 1.000000	$ $ $ $ $ $ $ $ $	1.403599 1.264418 1.001893 1.513286 1.425519 1.271629 1.174845 1.050773 0.839081		4,929,986.894 122,122.339 138,904.100 137,170.026 254,339.275 211,079.827 247,111.638 264,074.877 187,026.692
Transamerica International Moderate Growth VP – Service Class Subaccount Inception Date May 1, 2006		2010 2009 2008 2007 2006	$ $ $ $ $	0.879106 0.690284 1.100802 1.030435 1.000000	$ $ $ $ $	0.954359 0.879106 0.690284 1.100802 1.030435		188,522.923 15,043.256 79,356.005 81,135.694 0.000
Transamerica BlackRock Large Cap Value VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.174261 1.046107 1.606977 1.559685 1.354580 1.186405 1.018118 0.796637 0.943003 1.000000	$ $ $ $ $ $ $ $ $ $	1.277119 1.174261 1.046107 1.606977 1.559685 1.354580 1.186405 1.018118 0.796637 0.943003		6,618,554.023 22,601.082 30,887.685 57,467.103 40,039.099 48,947.675 52,492.353 63,136.781 176,528.167 108,846.802
Transamerica BlackRock Tactical Allocation VP – Service Class Subaccount Inception Date May 1, 2009		2010 2009	$ $	1.003130 0.993363	$ $	1.098884 1.003130		239,561.723 0.000
Transamerica Clarion Global Real Estate Securities VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.742145 1.326025 2.337148 2.544168 1.815856 1.624970 1.242059 0.929213 1.000000	$ $ $ $ $ $ $ $ $	1.984355 1.742145 1.326025 2.337148 2.544168 1.815856 1.624970 1.242059 0.929213		507,387.272 28,810.718 21,356.723 19,126.450 23,753.763 25,340.630 1,583.126 0.000 27,593.023
Transamerica Index 35 VP – Service Class Subaccount Inception Date November 19, 2009		2010 2009	$ $	0.998190 0.999958	$ $	1.075590 0.998190		11,517.449 0.000
Transamerica Index 50 VP – Service Class Subaccount Inception Date May 1, 2008		2010 2009	$ $	0.996117 0.991642	$ $	1.085798 0.996117		0.000 0.000

117

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Index 75 VP – Service Class Subaccount Inception Date May 1, 2008		2010 2009	$ $	0.999308 0.988772	$ $	1.112020 0.999308		0.000 0.000
Transamerica Index 100 VP – Service Class Subaccount Inception Date November 19, 2009		2010 2009	$ $	1.024147 0.999958	$ $	1.153818 1.024147		13,579.893 0.000
Transamerica JPMorgan Enhanced Index VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	0.867071 0.679456 1.101409 1.070028 0.942288 0.924871 0.846025 0.666282 0.897283 1.000000	$ $ $ $ $ $ $ $ $ $	0.983426 0.867071 0.679456 1.101409 1.070028 0.942288 0.924871 0.846025 0.666282 0.897283		893,333.970 32,839.314 36,038.078 99,646.892 103,756.955 106,292.400 111,064.953 261,994.931 125,360.672 55,879.243
Transamerica JPMorgan Mid Cap Value VP – Service Class Subaccount Inception Date November 19, 2009		2010 2009	$ $	1.029587 0.985157	$ $	1.245265 1.029587		125,465.611 0.000
Transamerica Jennison Growth VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	0.861605 0.620523 1.000404 0.911090 0.907366 0.809746 0.753552 0.594247 0.871348 1.000000	$ $ $ $ $ $ $ $ $ $	0.952491 0.861605 0.620523 1.000404 0.911090 0.907366 0.809746 0.753552 0.594247 0.871348		2,042,902.950 0.000 0.000 64,713.714 104,636.353 109,866.924 112,217.423 132,398.534 151,808.208 47,415.782
Transamerica Morgan Stanley Capital Growth VP – Initial Class(5) Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	0.940772 0.746900 1.192002 1.198165 1.026242 1.001272 0.931671 0.700028 0.944258 1.000000	$ $ $ $ $ $ $ $ $ $	1.180595 0.940772 0.746900 1.192002 1.198165 1.026242 1.001272 0.931671 0.700028 0.944258		2,740,881.423 53,936.120 58,765.279 93,204.669 115,162.357 169,179.072 173,787.963 180,259.408 229,142.2322 73,305.802
Transamerica AEGON High Yield Bond VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.446340 0.997541 1.354337 1.350404 1.235967 1.232722 1.140477 0.983646 0.978607 1.000000	$ $ $ $ $ $ $ $ $ $	1.601420 1.446340 0.997541 1.354337 1.350404 1.235967 1.232722 1.140477 0.983646 0.978607		1,910,700.926 51,556.168 58,145.551 82,864.697 85,452.834 94,255.252 96,144.530 117,636.817 153,982.191 72,409.466

118

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica MFS International Equity VP – Initial Class Subaccount Inception Date May 1, 2001		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.070292 0.819162 1.285611 1.196166 0.986968 0.887981 0.788649 0.639197 0.832379 1.000000	$ $ $ $ $ $ $ $ $ $	1.164590 1.070292 0.819162 1.285611 1.196166 0.986968 0.887981 0.788649 0.639197 0.832379		1,089,756.584 542.187 24,420.537 29,936.315 4,312.190 4,540.364 21,162.965 68,802.504 29,251.177 26,567.211
Transamerica PIMCO Total Return VP – Initial Class Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.355748 1.186501 1.239554 1.155465 1.125921 1.117299 1.085852 1.051137 1.000000	$ $ $ $ $ $ $ $ $	1.431103 1.355748 1.186501 1.239554 1.155465 1.125921 1.117299 1.085852 1.051137		2,606,768.225 90,298.069 76,256.240 81,646.518 100,871.964 106,254.623 89,921.168 90,351.146 106,777.025
Transamerica T. Rowe Price Small Cap VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.054538 0.772071 1.229984 1.139640 1.117184 1.025631 0.943746 0.682575 0.954095 1.000000	$ $ $ $ $ $ $ $ $ $	1.395945 1.054538 0.772071 1.229984 1.139640 1.117184 1.025631 0.943746 0.682575 0.954095		887,604.387 248.350 197.148 22,090.270 21,916.378 21,916.378 21,916.378 39,498.278 998.912 1000.000
Transamerica WMC Diversified Equity VP – Initial Class(6) Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004	$ $ $ $ $ $ $	0.941858 0.745369 1.343904 1.184292 1.012369 0.956578 1.000000	$ $ $ $ $ $ $	1.083730 0.941858 0.745369 1.343904 1.184292 1.012369 0.956578		1,785,802.773 45,627.856 2,319.487 1,005.180 0.000 0.000 0.000
Transamerica Multi-Managed Balanced VP – Initial Class(1) Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.220025 0.980965 1.473732 1.317444 1.225959 1.153085 1.053487 0.939281 1.000000	$ $ $ $ $ $ $ $ $	1.491197 1.220025 0.980965 1.473732 1.317444 1.225959 1.153085 1.053487 0.939281		255,603.946 0.000 0.000 2,183.902 3,212.590 8,325.102 2,108.559 2,420.719 99.890

119

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica AllianceBernstein Dynamic Allocation VP – Initial Class(4) Subaccount Inception Date May 1, 2002		2010 2009 2008 2007 2006 2005 2004 2003 2002	$ $ $ $ $ $ $ $ $	1.313104 1.015596 1.633852 1.398675 1.280730 1.251920 1.123331 0.922464 1.000000	$ $ $ $ $ $ $ $ $	1.413194 1.313104 1.015596 1.633852 1.398675 1.280730 1.251920 1.123331 0.922464		195,338.952 0.000 32,464.298 34,305.500 34,100.448 32,713.061 0.000 0.000 99.890
Transamerica WMC Diversified Growth VP – Initial Class Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	0.935035 0.734955 1.382371 1.207305 1.127697 0.982633 0.861695 0.666828 0.870883 1.000000	$ $ $ $ $ $ $ $ $ $	1.084767 0.935035 0.734955 1.382371 1.207305 1.127697 0.982633 0.861695 0.666828 0.870883		3,715,646.119 56,680.813 147,192.042 188,967.895 214,253.892 158,220.548 169,660.200 190,538.067 226,311.413 118,422.035
Transamerica Morgan Stanley Growth Opportunities VP – Initial Class(7) Subaccount Inception Date May 1, 2001		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.560035 1.157534 1.989306 1.641377 1.585844 1.385499 1.206427 0.933694 1.106549 1.000000	$ $ $ $ $ $ $ $ $ $	2.084095 1.560035 1.157534 1.989306 1.641377 1.585844 1.385499 1.206427 0.933694 1.106549		375,930.727 1,980.541 1,778.436 1,783.167 2,149.874 9,104.621 10,194.638 14,035.568 41,634.474 42,498.296
Transamerica AEGON Money Market VP – Initial Class(2) Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003	$ $ $ $ $ $ $ $	1.067022 1.082161 1.073301 1.037829 1.006269 0.993185 0.998585 1.000000	$ $ $ $ $ $ $ $	1.050789 1.067022 1.082161 1.073301 1.037829 1.006269 0.993185 0.998585		1,798,430.510 0.000 326.568 9,853.813 182,969.109 190,499.757 9,601.684 534.587
Transamerica Systematic Small/Mid Cap Value VP – Initial Class(8) Subaccount Inception Date December 13, 1999		2010 2009 2008 2007 2006 2005 2004 2003 2002 2001	$ $ $ $ $ $ $ $ $ $	1.644130 1.165827 2.002212 1.630121 1.402172 1.253809 1.094395 0.582372 0.976962 1.000000	$ $ $ $ $ $ $ $ $ $	2.111477 1.644130 1.165827 2.002212 1.630121 1.402172 1.253809 1.094395 0.582372 0.976962		2,211,773.925 52,086.099 128,735.856 241,688.250 275,763.581 513,355.956 532,172.496 514,636.128 577,620.892 200,821.027

120

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica AEGON U.S. Government Securities VP – Initial Class(3)		2010	$	1.271074	$	1.306783		2,023,065.744
Subaccount Inception Date December 13, 1999		2009	$	1.235573	$	1.271074		67,193.705
		2008	$	1.165487	$	1.235573		87,694.910
		2007	$	1.116132	$	1.165487		34,097.380
		2006	$	1.097485	$	1.116132		36,316.991
		2005	$	1.090132	$	1.097485		57,449.028
		2004	$	1.071750	$	1.090132		102,051.991
		2003	$	1.057207	$	1.071750		126,779.085
		2002	$	1.014592	$	1.057207		374,800.397
		2001	$	1.000000	$	1.014592		327,040.329
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.179574	$	1.210634		33,873.578
Subaccount Inception Date December 13, 1999		2009	$	1.149598	$	1.179574		0.000
		2008	$	1.086878	$	1.149598		0.000
		2007	$	1.043482	$	1.086878		0.000
		2006	$	1.028154	$	1.043482		0.000
		2005	$	1.023764	$	1.028154		0.000
		2004	$	1.010345	$	1.023764		0.000
		2003	$	1.000000	$	1.010345		0.000
Transamerica Morgan Stanley Active International Allocation VP – Initial Class Subaccount Inception Date December 13, 1999		2010	$	1.172768	$	1.252794		714,746.362
		2009	$	0.946077	$	1.172768		25,092.857
		2008	$	1.570765	$	0.946077		35,689.765
		2007	$	1.379911	$	1.570765		36,582.814
		2006	$	1.134538	$	1.379911		32,697.516
		2005	$	1.012440	$	1.134538		45,016.129
		2004	$	0.886038	$	1.012440		47,063.728
		2003	$	0.677481	$	0.886038		49,151.481
		2002	$	0.828616	$	0.677481		127,231.249
		2001	$	1.000000	$	0.828616		82,418.958
Transamerica Multi Managed Large Cap Core VP – Initial Class		2010	$	1.079484	$	1.266819		2,123,022.739
Subaccount Inception Date December 13, 1999		2009	$	0.753873	$	1.079484		86,162.636
		2008	$	1.321903	$	0.753873		101,301.030
		2007	$	1.228845	$	1.321903		131,555.271
		2006	$	1.130969	$	1.228845		154,077.224
		2005	$	1.049636	$	1.130969		244,819.390
		2004	$	0.945384	$	1.049636		309,842.128
		2003	$	0.792879	$	0.945384		337,550.121
		2002	$	0.962911	$	0.792879		390,514.516
		2001	$	1.000000	$	0.962911		41,968.536
Transamerica Morgan Stanley Mid-Cap Growth VP – Initial Class		2010	$	0.817385	$	1.077792		850,565.949
Subaccount Inception Date May 1, 2001		2009	$	0.516977	$	0.817385		21,201.333
		2008	$	0.977513	$	0.516977		21,346.952
		2007	$	0.810185	$	0.977513		23,311.957
		2006	$	0.748559	$	0.810185		39,170.879
		2005	$	0.706779	$	0.748559		40,327.195
		2004	$	0.669908	$	0.706779		52,300.306
		2003	$	0.530826	$	0.669908		50,579.297
		2002	$	0.805310	$	0.530826		52,969.144
		2001	$	1.000000	$	0.805310		15,552.750

121

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.861770	$	0.907557		279,233.038
Subaccount Inception Date May 1, 2002		2009	$	0.592358	$	0.861770		0.000
		2008	$	1.250803	$	0.592358		72.933
		2007	$	1.253207	$	1.250803		52.236
		2006	$	1.126766	$	1.253207		0.000
		2005	$	1.085273	$	1.126766		0.000
		2004	$	0.994356	$	1.085273		0.000
		2003	$	0.757548	$	0.994356		0.000
		2002	$	1.000000	$	0.757548		0.000
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.871300	$	0.988477		5,385.612
Subaccount Inception Date May 1, 2002		2009	$	0.732952	$	0.871300		0.000
		2008	$	1.297388	$	0.732952		0.000
		2007	$	1.179248	$	1.297388		0.000
		2006	$	1.129078	$	1.179248		0.000
		2005	$	1.055944	$	1.129078		0.000
		2004	$	1.008489	$	1.055944		0.000
		2003	$	0.792764	$	1.008489		0.000
		2002	$	1.000000	$	0.792764		99.890
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.855967	$	0.950792		1,685,482.846
Subaccount Inception Date May 1, 2001		2009	$	0.722264	$	0.855967		97,266.825
		2008	$	1.236841	$	0.722264		187,228.610
		2007	$	1.197896	$	1.236841		280,029.890
		2006	$	1.039808	$	1.197896		297,924.629
		2005	$	1.009478	$	1.039808		333,770.239
		2004	$	0.921732	$	1.009478		446,236.516
		2003	$	0.708109	$	0.921732		483,774.313
		2002	$	0.925071	$	0.708109		631,692.556
		2001	$	1.000000	$	0.925071		198,836.774
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.746965	$	0.807891		954,314.753
Subaccount Inception Date May 1, 2001		2009	$	0.553250	$	0.746965		0.000
		2008	$	0.933656	$	0.553250		83,080.529
		2007	$	0.834587	$	0.933656		92,567.930
		2006	$	0.852963	$	0.834587		97,790.445
		2005	$	0.754200	$	0.852963		103,745.905
		2004	$	0.706925	$	0.754200		110,949.221
		2003	$	0.581903	$	0.706925		118,632.568
		2002	$	0.854462	$	0.581903		141,728.704
		2001	$	1.000000	$	0.854462		87,415.361
Fidelity VIP Contrafund® Portfolio – Service Class 2		2010	$	1.320272	$	1.520198		1,755,002.271
Subaccount Inception Date May 1, 2000		2009	$	0.989701	$	1.320272		50,707.914
		2008	$	1.753860	$	0.989701		76,861.361
		2007	$	1.518462	$	1.753860		63,440.236
		2006	$	1.383752	$	1.518462		31,843.153
		2005	$	1.204608	$	1.383752		30,360.745
		2004	$	1.062289	$	1.204608		0.000
		2003	$	0.841480	$	1.062289		0.000
		2002	$	0.945328	$	0.841480		43,976.847
		2001	$	1.000000	$	0.945328		11,260.971

122

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	0.944282	$	1.068581		1,428,547.330
Subaccount Inception Date May 1, 2000		2009	$	0.738290	$	0.944282		29,391.663
		2008	$	1.311118	$	0.738290		32,372.172
		2007	$	1.314819	$	1.311118		65,079.487
		2006	$	1.113273	$	1.314819		131,771.939
		2005	$	1.070829	$	1.113273		141,970.581
		2004	$	0.977653	$	1.070829		160,638.800
		2003	$	0.763516	$	0.977653		161,139.795
		2002	$	0.935892	$	0.763516		231,085.767
		2001	$	1.000000	$	0.935892		58,950.541
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.701231	$	0.855314		743,577.375
Subaccount Inception Date May 1, 2001		2009	$	0.556480	$	0.701231		1,747.672
		2008	$	1.072563	$	0.556480		0.000
		2007	$	0.860003	$	1.072563		0.000
		2006	$	0.819443	$	0.860003		0.000
		2005	$	0.788705	$	0.819443		0.000
		2004	$	0.776712	$	0.788705		18,757.625
		2003	$	0.595094	$	0.776712		18,816.610
		2002	$	0.867001	$	0.595094		48,655.770
		2001	$	1.000000	$	0.867001		1,000.000
Fidelity VIP Growth Opportunities Portfolio – Service Class 2		2010	$	0.796624	$	0.968615		98,185.709
Subaccount Inception Date May 1, 2000		2009	$	0.556143	$	0.796624		0.000
		2008	$	1.258957	$	0.556143		0.000
		2007	$	1.040290	$	1.258957		0.000
		2006	$	1.004935	$	1.040290		0.000
		2005	$	0.938993	$	1.004935		0.000
		2004	$	0.892116	$	0.938993		0.000
		2003	$	0.700088	$	0.892116		0.000
		2002	$	0.911567	$	0.700088		998.915
		2001	$	1.000000	$	0.911567		8,487.477
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	1.818522	$	2.302437		1,737,071.764
Subaccount Inception Date May 1, 2000		2009	$	1.321413	$	1.818522		55,802.128
		2008	$	2.222083	$	1.321413		68,010.444
		2007	$	1.956606	$	2.222083		140,991.919
		2006	$	1.767617	$	1.956606		162,904.304
		2005	$	1.520914	$	1.767617		194,908.573
		2004	$	1.239038	$	1.520914		213,253.272
		2003	$	0.910103	$	1.239038		256,755.139
		2002	$	1.027192	$	0.910103		315,453.564
		2001	$	1.000000	$	1.027192		66,684.529
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	1.153874	$	1.435540		499,067.792
Subaccount Inception Date May 1, 2002		2009	$	0.745622	$	1.153874		0.000
		2008	$	1.554448	$	0.745622		10,475.209
		2007	$	1.497211	$	1.554448		11,246.783
		2006	$	1.310560	$	1.497211		11,856.139
		2005	$	1.299278	$	1.310560		12,545.279
		2004	$	1.159068	$	1.299278		13,333.769
		2003	$	0.747954	$	1.159068		14,206.022
		2002	$	1.000000	$	0.747954		15,478.691

123

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Franklin Income Securities Fund – Class 2		2010	$	0.896617	$	0.994830		882,331.732
Subaccount Inception Date May 1, 2007		2009	$	0.671488	$	0.896617		807.217
		2008	$	0.969437	$	0.671488		0.000
		2007	$	1.000000	$	0.969437		0.000
Mutual Shares Securities Fund – Class 2		2010	$	0.740603	$	0.810942		214,528.584
Subaccount Inception Date May 1, 2007		2009	$	0.596665	$	0.740603		0.000
		2008	$	0.963492	$	0.596665		0.000
		2007	$	1.000000	$	0.963492		0.000
Templeton Foreign Securities Fund – Class 2		2010	$	0.846164	$	0.903305		305,296.421
Subaccount Inception Date May 1, 2007		2009	$	0.627021	$	0.846164		0.000
		2008	$	1.068021	$	0.627021		0.000
		2007	$	1.000000	$	1.068021		0.000
Janus Aspen - Enterprise Portfolio – Service Shares		2010	$	0.993891	$	1.228503		469,106.876
Subaccount Inception Date October 9, 2000		2009	$	0.698738	$	0.993891		0.000
		2008	$	1.263968	$	0.698738		0.000
		2007	$	1.054417	$	1.263968		33,083.812
		2006	$	0.944988	$	1.054417		36,026.489
		2005	$	0.856564	$	0.944988		39,050.027
		2004	$	0.722029	$	0.856564		42,322.781
		2003	$	0.544079	$	0.722029		55,410.836
		2002	$	0.768654	$	0.544079		62,830.493
		2001	$	1.000000	$	0.768654		1000.000
Janus Aspen - Perkins Mid Cap Value Portfolio – Service Shares		2010	$	1.325201	$	1.505480		253,722.921
Subaccount Inception Date October 9, 2000		2009	$	1.012444	$	1.325201		21,876.985
		2008	$	1.425989	$	1.012444		21,997.649
		2007	$	1.351312	$	1.425989		22,060.190
		2006	$	1.192545	$	1.351312		22,118.720
		2005	$	1.100856	$	1.192545		31,645.868
		2004	$	0.949036	$	1.100856		45,013.571
		2003	$	0.682460	$	0.949036		45,158.079
		2002	$	0.905027	$	0.682460		46,363.612
		2001	$	1.000000	$	0.905027		1000.000
Janus Aspen - Worldwide Portfolio – Service Shares		2010	$	0.732523	$	0.833299		1,110,311.736
Subaccount Inception Date October 9, 2000		2009	$	0.541386	$	0.732523		0.000
		2008	$	0.996184	$	0.541386		0.000
		2007	$	0.925085	$	0.996184		0.000
		2006	$	0.796510	$	0.925085		2,991.444
		2005	$	0.766160	$	0.796510		4,083.602
		2004	$	0.744370	$	0.766160		5,757.542
		2003	$	0.611173	$	0.744370		7,536.922
		2002	$	0.835427	$	0.611173		10,273.679
		2001	$	1.000000	$	0.835427		1000.000
MFS® New Discovery Series – Service Class		2010	$	1.135251	$	1.519723		186,530.330
Subaccount Inception Date May 1, 2002		2009	$	0.707617	$	1.135251		0.000
		2008	$	1.188222	$	0.707617		10,246.140
		2007	$	1.180187	$	1.188222		11,000.863
		2006	$	1.061215	$	1.180187		11,596.900
		2005	$	1.025998	$	1.061215		12,270.995
		2004	$	0.981034	$	1.025998		13,042.228
		2003	$	0.746621	$	0.981034		13,895.388
		2002	$	1.000000	$	0.746621		15,142.427

124

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
MFS® Total Return Series – Service Class		2010	$	1.154449	$	1.246334		559,735.920
Subaccount Inception Date May 1, 2002		2009	$	0.995840	$	1.154449		0.000
		2008	$	1.301938	$	0.995840		0.000
		2007	$	1.272166	$	1.301938		0.000
		2006	$	1.157309	$	1.272166		0.000
		2005	$	1.145445	$	1.157309		0.000
		2004	$	1.047708	$	1.145445		0.000
		2003	$	0.917149	$	1.047708		0.000
		2002	$	1.000000	$	0.917149		99.890

⁽¹⁾  Formerly known as Transamerica Balanced VP.

⁽²⁾  Formerly known as Transamerica Money Market VP.

⁽³⁾  Formerly known as Transamerica U.S. Government Securities VP.

⁽⁴⁾  Formerly known as Transamerica Convertible Securities VP.

⁽⁵⁾  Formerly known as Transamerica Focus VP.

⁽⁶⁾  Formerly known as Transamerica Diversified Equity VP.

⁽⁷⁾  Formerly known as Transamerica Growth Opportunities VP.

⁽⁸⁾  Formerly known as Transamerica Small/Mid Cap Value VP.

Transamerica AEGON Active Asset Allocation - Conservative VP, Transamerica AEGON Active Asset Allocation -Moderate VP, Transamerica AEGON Active Asset Allocation - Moderate Growth VP, Transamerica JPMorgan Core Bond VP, Transamerica JPMorgan Tactical Allocation VP, and Transamerica PIMCO Real Return TIPS VP had not commenced operations as of December 31, 2010, therefore, comparable data is not available.

125

APPENDIX

POLICY VARIATIONS

The dates shown below are the approximate first issue dates of the various versions of the policy. These dates will vary by state in many cases. This Appendix describes certain of the more significant differences in features of the various versions of the policy. There may be additional variations. Please see your actual policy and any attachments for determining your specific coverage.

		Approximate First Issue Date
Policy Form Number	AV464 101 121 799	December 1999
	AV630 101 138 101	May 2001
	AV710 101 147 102	May 2002
	AV950 101 175 603	November 2003
Policy Endorsement Form Number	AE 1225 604 (ROP)	July 2006
	AE 1288 0608	June 2008

Product Feature	ExtraSM Form Number: – AV464 101 121 799 – RGMI 1 798	ExtraSM 2001 Form Number: – AV630 101 138 101 – RGMI 1 798	ExtraSM 2002 Form Number: – AV710 101 147 102 – RGMI 1 798
Guaranteed Minimum Death Benefit Option(s)	Annual Step-Up Death Benefit— the largest policy value on the policy date or on any policy anniversary before you reach age 76; plus any premium payments you have made since then; minus any adjusted partial surrenders (discussed below) we have paid to you since then. Option is available if owner or annuitant is 74 or younger.	Annual Step-Up Death Benefit— the largest policy value on the policy date or on any policy anniversary before you reach age 81; plus any premium payments you have made since then; minus any adjusted partial surrenders (discussed below) we have paid to you since then. Option is available if owner or annuitant is 79 or younger.	A.Double Enhanced Death Benefit - greater of 1) 6% Annually Compounding through age 80 2) monthly step-up through age 80 B.Return of Premium Option A is available if both owner and annuitant are under age 81. Option B is available if both owner and annuitant are under age 84.
Double Enhanced Death Benefit Designated Funds	N/A	N/A	N/A
Death Proceeds	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	•        1.75% for Annual Step-Up.	•        1.75% for Annual Step-Up - first 10 Policy Years. •        1.55% for Annual Step-Up - after first 10 Policy Years.	•        1.75% for Return of Premium - for first 10 Policy Years. •        1.30% for Return of Premium - after 10 Policy Years. •        2.00% for Double Enhanced - for first 10 Policy Years. •        1.55% for Double Enhanced - after first 10 Policy Years.
Is Mortality & Expense Risk Fee and Administrative Charge different after the annuity commencement date?	Yes - 1.55%	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee	No	No	No

126

Product Feature	ExtraSM Form Number: – AV464 101 121 799 – RGMI 1 798	ExtraSM 2001 Form Number: – AV630 101 138 101 – RGMI 1 798	ExtraSM 2002 Form Number: – AV710 101 147 102 – RGMI 1 798
Premium Enhancement	Yes Up to 5% for ages 0-69 Up to 4% for ages 70+	Yes Up to 5% for ages 0-69 Up to 4% for ages 70+	Yes Up to 5% for ages 0-69 Up to 4% for ages 70+.
Guaranteed Period Options (available in the fixed account) Annual Contract Charge (Service Charge)	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value is at least $100,000 or if the sum of your premiums, less all partial surrenders, is at least $100,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value is at least $100,000 or if the sum of your premiums, less all partial surrenders, is at least $100,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $50,000.
Optional Riders	•        5 for Life 2005 •        Family Income Protector •        Managed Annuity Program •        Managed Annuity Program II •        Living Benefit Rider 2003 •        Living Benefit Rider 2005 •        Taxpayer •        Taxpayer Plus 2 •        Taxpayer 2003	•        5 for Life 2005 •        Family Income Protector •        Managed Annuity Program •        Managed Annuity Program II •        Living Benefit Rider 2003 •        Living Benefit Rider 2005 •        Taxpayer •        Taxpayer Plus 2 •        Taxpayer 2003	•        5 for Life 2005 •        Family Income Protector •        Managed Annuity Program •        Managed Annuity Program II •        Living Benefit Rider 2003 •        Living Benefit Rider 2005 •        Taxpayer •        Taxpayer Plus 2 •        Taxpayer 2003
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing Option	Yes	Yes	Yes
Dollar Cost Averaging Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes	Yes	Yes
Unemployment Waiver	Yes	Yes	Yes
Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Death Proceeds	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.	Greatest of: 1) policy value 2) cash value 3) guaranteed minimum death benefit.
Guaranteed Minimum Death Benefit Option(s)	Return of Premium Death Benefit (available if owner and annuitant are age 84 or younger).	Return of Premium Death Benefit (RGMD 8 0603) available if owner and annuitant are age 84 or younger.	A. Return of Premium Death Benefit (RGMD 8 0603) B. Modal Step Up (RGMD 5 0103) C. Double Enhanced (RGMD 15 0108) Option A is available if owner and annuitant are age 90 or younger. Option B and Option C are available if owner and annuitant are age 75 or younger.

127

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Double Enhanced Death Benefit Designated Funds	N/A	N/A	•        AllianceBernstein Balanced Wealth Strategy Portfolio - Class B •        American Funds - Asset Allocation Fund - Class 2 •        American Funds - Bond Fund - Class 2 •        Fidelity VIP Balanced Portfolio – Service Class 2 •        Franklin Templeton VIP Founding Funds Allocation Fund - Class 4 •        GE Investments Total Return Fund – Class 3 •        Transamerica Asset Allocation - Conservative VP – Service Class •        Transamerica Asset Allocation - Moderate VP – Service Class •        Transamerica Asset Allocation - Moderate Growth VP – Service Class •        Transamerica International Moderate Growth VP – Service Class •        Transamerica Multi-Managed Balanced VP – Service Class •        Transamerica BlackRock Global Allocation VP - Service Class •        Transamerica BlackRock Tactical Allocation VP - Service Class •        Transamerica Efficient Markets VP - Service Class •        Transamerica Foxhall Global Conservative VP – Service Class •        Transamerica Index 35 VP – Service Class •        Transamerica Index 50 VP – Service Class •        Transamerica Index 75 VP – Service Class •        Transamerica AEGON Money Market VP – Service Class •        Transamerica PIMCO Total Return VP – Service Class •        Transamerica AEGON U.S. Government Securities VP – Service Class

128

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	•         1.75% for Return of Premium - for first 10 Policy Years. •         1.30% for Return of Premium - after 10 Policy Years.	•         1.75% for Return of Premium - for first 10 Policy Years. •         1.30% for Return of Premium - after 10 Policy Years.	•         1.65% for Return of Premium. •         1.85% for Annual Step-Up. •         2.30% for Double Enhanced.
Is Mortality & Expense Risk Fee and Administrative Charge different after the annuity commencement date?	Yes - 1.25%	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee	No	Yes -	Yes -
		•         0.30% if you choose American Funds - Asset Allocation Fund, American Funds - Bond Fund, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. •         0.20% if you choose AllianceBernstein Balanced Wealth Strategy Portfolio or GE Investments Total Return Fund. •         0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund. •         0.10% if you choose Transamerica BlackRock Global Allocation VP.	•       0.30% if you choose American Funds - Asset Allocation Fund, American Funds - Bond Fund, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. •         0.20% if you choose AllianceBernstein Balanced Wealth Strategy Portfolio or GE Investments Total Return Fund. •       0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund. •       0.10% if you choose Transamerica BlackRock Global Allocation VP.
Premium Enhancement	Yes – 4%	Yes – 4% - 5.5%	Yes – Based on Attained Age
			Age 0-59 = 5.5%
			Age 60-69 = 5%
			Age 70-79 = 4%
			Age 80+ = 2%
Guaranteed Period Options (available in the fixed account) Annual Contract Charge (Service Charge)	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $50,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge currently of $35 (can charge up to $40, but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.

129

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Optional Riders	•         5 for Life 2005 •         5 for Life with Growth •         5 for Life Growth with Death Benefit •         Living Benefit Rider 2003 •         Living Benefit Rider 2005 •         Tax Payer 2003 •         Taxpayer Plus 2	•         Living Benefit Rider 2003 •         Living Benefit Rider 2005 •         5 for Life 2005 •         Income Select for Life •         Retirement Income Choice® •         Retirement® Income Choice 2008 (with Double Withdrawal Base Benefit) •         Retirement® Income Choice 1.2 •         Retirement Income® Choice 1.4 •         Retirement Income MaxSM •         Taxpayer 2003 •         Taxpayer Plus 2	•         Living Benefit Rider 2005 •         Retirement® Income Choice •         Retirement® Income Choice 2008 (with Double Withdrawal Base Benefit) •         Retirement Income Choice® 1.2 •         Retirement® Income Choice 1.4® •         Income Link® •         Retirement Income MaxSM •         Taxpayer 2003 •         Taxpayer Plus 2
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing Option	Yes	Yes	Yes
Dollar Cost Averaging Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes	Yes	Yes
Unemployment Waiver	Yes	Yes	Yes

130

APPENDIX

EXCESS INTEREST ADJUSTMENT EXAMPLES

Money that you surrender from, transfer out of, or apply to an annuity payment option, from a guaranteed period option of the fixed account before the end of its guaranteed period (the number of years you specified the money would remain in the guaranteed period option) may be subject to an excess interest adjustment (“EIA”). At the time you request a surrender, if interest rates set by the Company have risen since the date of the initial guarantee, the excess interest adjustment will result in a lower cash value. However, if interest rates have fallen since the date of the initial guarantee, the excess interest adjustment will result in a higher cash value.

Excess interest adjustments will not reduce the adjusted policy value for a guaranteed period option below the premium payments and transfers to that guaranteed period option, less any prior partial surrenders and transfers from the guaranteed period option, plus interest at the policy’s minimum guaranteed effective annual interest rate. This is referred to as the excess interest adjustment floor.

The formula that will be used to determine the excess interest adjustment is:

S* (G-C)* (M/12)

S	=	Gross amount being surrendered that is subject to the excess
		interest adjustment
G	=	Guaranteed interest rate in effect for the policy
C	=	Current guaranteed interest rate then being offered on new premiums for the next longer option period than “M”. If this policy form or such an option period is no longer offered, “C” will be the U.S. Treasury rate for the next longer maturity (in whole years) than “M” on the 25th day of the previous calendar month, plus up to 2%.
M	=	Number of months remaining in the current option period,
		rounded up to the next higher whole number of months.
*	=	multiplication
^	=	exponentiation

The following examples are for illustrative purposes only and ore calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

131

Excess Interest Adjustment Examples — (Continued)

Example 1 (Full Surrender, rates increase by 3%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Surrender:	Middle of policy year 2
Cumulative Earnings	= 54,181.21 - 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Amount subject to excess interest adjustment	= 54,181.21 - 4,181.21 = 50,000.00
Excess interest adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess interest adjustment
G = .055
C = .085
M = 42
Excess interest adjustment	= S* (G - C)* (M/12)
	= 50,000.00 * (.055 - .085) * (42/12)
	= -5,250.00, but excess interest adjustment cannot cause the adjusted policy value to fall below the excess interest adjustment floor, so the adjustment is limited to 51,129.21 - 54,181.21 = -3,052.00
Adjusted policy value	= policy value + excess interest adjustment
	= 54,181.21 + (-3,052.00) = 51,129.21

Upon full surrender of the policy, the net surrender value (adjusted policy value less any surrender charge) will never be less than that required by the non-forfeiture laws of your state.

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

132

Excess Interest Adjustment Examples — (Continued)

Example 2 (Full Surrender, rates decrease by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Surrender:	Middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 - 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Amount subject to excess interest adjustment	= 54,181.21 - 4,181.21 = 50,000.00
Excess interest adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess interest adjustment
G = .055
C = .045
M = 42
Excess interest adjustment	= S* (G - C)* (M/12)
	= 50,000.00 * (.055 - .045) * (42/12) = 1,750.00
Adjusted policy value	= 54,181.21 + 1,750.00 = 55,931.21

Upon full surrender of the policy, the net surrender value will never by less than that required by the non-forfeiture laws of your state. For the purpose of these illustrations no surrender charges are assumed.

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

On a partial surrender, the Company will pay the policyholder the full amount of surrender requested (as long as the policy value is sufficient). Amounts surrendered will reduce the policy value by an amount equal to:

R - E + SC

R	=	the requested partial surrender;
E	=	the excess interest adjustment; and
SC	=	the surrender charges on (EPW - E); where
EPW	=	the excess partial withdrawal amount.

133

Excess Interest Adjustment Examples — (Continued)

Example 3 (Partial Surrender, rates increase by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Partial surrender:	$20,000; middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 - 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Excess interest adjustment
S = 20,000 - 4,181.21 = 15,818.79
G = .055
C = .065
M = 42
E = 15,818.79 * (.055 - .065) * (42/12) = -553.66	= 54,181.21 - (R - E + surrender charge)
Remaining policy value at middle of policy year 2	= 54,181.21 - (20,000.00 - (-553.66) + 0.00) = 33,627.55

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

Example 4 (Partial Surrender, rates decrease by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Partial surrender:	$20,000; middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 - 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Excess interest adjustment
S = 20,000 - 4,181.21 = 15,818.79
G = .055
C = .045
M = 42
E = 15,818.79 * (.055 - .045)* (42/12) = 553.66	= 54,181.21 - (R - E + surrender charge)
Remaining policy value at middle of policy year 2	= 54,181.21 - (20,000.00 – 553.66 + 0.00) = 34,734.87

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

134

APPENDIX

DEATH BENEFIT

Adjusted Partial Surrender. If you make a partial surrender (withdrawal), then your guaranteed minimum death benefit is reduced by an amount called the adjusted partial surrender. The amount of the reduction depends on the relationship between your death benefit and policy value. The adjusted partial surrender is equal to (1) multiplied by (2) divided by (3), where:

(1) is the amount of the gross partial surrender;

(2) is the value of the current death proceeds immedicately prior to the gross partial surrender;

(3) is the policy value immediately prior to the gross partial surrender.

The following examples describe the effect of a surrender on the guaranteed minimum death benefit and policy value.

Example 1 (Assumed Facts for Example)

Current guaranteed minimum death benefit before surrender	$	75,000
Current policy value before surrender	$	50,000
Current death proceeds	$	75,000
Total Gross Partial Surrender	$	15,494
Adjusted partial surrender = 15,494 * 75,000 / 50,000	$	23,241
New guaranteed minimum death benefit (after surrender) = 75,000 - 23,241	$	51,759
New policy value (after surrender) = 50,000 - 15,494	$	34,506

Summary:
Reduction in guaranteed minimum death benefit	= $	23,241
Reduction in policy value	= $	15,494

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

** The guaranteed minimum death benefit is reduced more than the policy value because the guaranteed minimum death benefit was greater than the policy value just prior to the surrender.

135

Death Benefit — (Continued)

Example 2 (Assumed Facts for Example)

Current guaranteed minimum death benefit before surrender	$	50,000
Current policy value before surrender	$	75,000
Current death proceeds	$	75,000
Total Gross Partial Surrender	$	15,556
Adjusted partial surrender = 15,556 * 75,000 / 75,000	$	15,556
New guaranteed minimum death benefit (after surrender) = 50,000 - 15,556	$	34,444
New policy value (after surrender) = 75,000 - 15,556	$	59,444

Summary:
Reduction in guaranteed minimum death benefit	= $	15,556
Reduction in policy value	= $	15,556

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

** The guaranteed minimum death benefit and policy value are reduced by the same amount because the policy value was higher than the guaranteed minimum death benefit just prior to the surrender.

136

Death Benefit — (Continued)

Hypothetical Example

In this example, certain death benefit values at various points in time are depicted based on hypothetical assumed rates of performance. This example is for illustrative purposes only and assumes a single $100,000 premium payment by a sole owner and annuitant who is age 50. It further assumes no subsequent premium payments or withdrawals.

End of Year	Net Rate of Return for Fund*			Return of Premium		Annual Step-Up
Issue		N/A		$	100,000	$	100,000
1		-4	%	$	100,000	$	100,000
2		18	%	$	100,000	$	110,093
3		15	%	$	100,000	$	124,955
4		-7	%	$	100,000	$	124,955
5		2	%	$	100,000	$	124,955
6		10	%	$	100,000	$	124,955
7		14	%	$	100,000	$	140,257
8		-3	%	$	100,000	$	140,257
9		17	%	$	100,000	$	154,706
10		6	%	$	100,000	$	161,668

* The assumed rate does reflect the deduction of a hypothetical fund fee but does not reflect the deduction of any other fees, charges or taxes. The death benefit values do reflect the deduction of hypothetical base policy fees and hypothetical death benefit fees. Different hypothetical returns and fees would produce different results.

137

APPENDIX

ADDITIONAL DEATH DISTRIBUTION RIDER — ADDITIONAL INFORMATION

The following example illustrates the Additional Death Distribution additional death benefit payable by this rider as well as the effect of a partial surrender on the Additional Death Distribution benefit amount. The annuitant is less than age 71 on the Rider Date.

Example 1

Policy Value on the Rider Date:	$	100,000
Premiums paid after the Rider Date before Surrender:	$	25,000
Gross Partial Surrenders after the Rider Date:	$	30,000
Policy Value on date of Surrender:	$	150,000
Rider Earnings on Date of Surrender (Policy Value on date of surrender – Policy Value on Rider Date – Premiums paid after Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $150,000 - $100,000 - $25,000 + 0):	$	25,000
Amount of Surrender that exceeds Rider Earnings ($30,000 - $25,000):	$	5,000
Base Policy Death Benefit on the date of Death Benefit Calculation:	$	200,000
Policy Value on the date of Death Benefit Calculations:	$	175,000
Rider Earnings (= Policy Value on date of Death Benefit Calculations – policy value on Rider Date – Premiums since Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $175,000 - $100,000 - $25,000 + $5,000):	$	55,000
Additional Death Benefit Amount (= Additional Death Benefit Factor * Rider Earnings = 40%* $55,000):	$	22,000
Total Death Benefit paid (= Base policy death benefit plus Additional Death Benefit Amount):	$	222,000
Example 2
Policy Value on the Rider Date:	$	100,000
Premiums paid after the Rider Date before Surrender:	$	0
Gross Partial Surrenders after the Rider Date:	$	0
Base Policy Death Benefit on the date of Death Benefit Calculation:	$	100,000
Policy Value on the date of Death Benefit Calculations:	$	75,000
Rider Earnings (= Policy Value on date of death benefit calculations – policy value on Rider Date – Premiums since Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $75,000 - $100,000 - $0 + $0):	$	0
Additional Death Benefit Amount (= Additional Death Benefit Factor * Rider Earnings = 40%* $0):	$	0
Total Death Benefit paid (= Base policy death benefit plus Additional Death Benefit Amount):	$	100,000

138

APPENDIX

ADDITIONAL DEATH DISTRIBUTION+ RIDER – ADDITIONAL INFORMATION

Assume the Additional Death Distribution+ is added to a new policy opened with $100,000 initial premium. The annuitant is less than age 71 on the Rider Date. On the first and second Rider Anniversaries, the Policy Value is $110,000 and $95,000 respectively when the Rider Fees are deducted. The annuitant adds $25,000 premium in the 3rd Rider Year when the Policy Value is equal to $115,000 and then takes a withdrawal of $35,000 during the 4th Rider Year when the Policy Value is equal to $145,000. After 5 years, the Policy Value is equal to $130,000 and the death proceeds are equal to $145,000.

Example 1

Account Value on Rider Date (equals initial policy value since new policy)	$	100,000
Additional Death Benefit during first Rider Year	$	0
Rider Fee on first Rider Anniversary (= Rider Fee * Policy Value = 0.55% * $110,000)	$	605
Additional Death Benefit during 2nd Rider Year (= sum of total Rider Fees paid)	$	605
Rider Fee on second Rider Anniversary (= Rider Fee * Policy Value = 0.55% * $95,000)	$	522.50
Additional Death Benefit during 3rd Rider Year (= sum of total Rider Fees paid = $605 + $522.50)	$	1,127.50
Rider Benefit Base in 3rd Rider Year prior to Premium addition (= Account Value less premiums added since Rider Date = $115,000 - $0)	$	115,000
Rider Benefit Base in 3rd Rider Year after Premium addition (= $140,000 - $25,000)	$	115,000
Rider Benefit Base in 4th Rider Year prior to withdrawal (= Account Value less premiums added since Rider Date = $145,000 - $25,000)	$	120,000
Rider Benefit Base in 4th Rider Year after withdrawal = (Account Value less premiums added since Rider Date =$110,000 - $25,000)	$	85,000
Rider Benefit Base in 5th Rider Year (= $130,000 - $25,000)	$	105,000
Additional Death Benefit = Rider Benefit Percentage * Rider Benefit Base = 30% * $105,000	$	31,500
Total Death Proceeds in 5th Rider Year (= base policy Death Proceeds + Additional Death Benefit Amount = $145,000 + $31,500)	$	176,500

139

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT COMPARISON TABLE

Important aspects of the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider are summararized in the following chart.

Note: The Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider and any additional options available under these riders, may vary for certain policies and may not be available for all policies; the Guaranteed Lifetime Withdrawal Benefit Riders may not be available in all states. You should consult with tax and financial professionals to determine which of these riders is appropriate for you.

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
Benefit: •        Provides: (1) Guaranteed Minimum Accumulation Benefit (“GMAB”)—Ten years after you elect the rider (“guaranteed future value date”), your policy value will equal your guaranteed future value (calculated as described below). After that date, the guaranteed future value equals zero. (2) Guaranteed Minimum Withdrawal Benefit (“GMWB”)—a maximum annual withdrawal amount (calculated as described below) regardless of your policy value; we account for withdrawals you take under the rider by applying two different withdrawal guarantees, “principal back,” for withdrawals of up to 7% of your total withdrawal base, or “for life,” for withdrawals up to 5% of your total withdrawal base.	Benefit: •        Provides (1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a level of cash withdrawals (and payments from us, if necessary) regardless of the performance of the Designated Investment Option or the Open Allocation Option that you select. (2) Growth—On each of the first 10 rider anniversaries, we add an annual growth credit (5% of the withdrawal base immediately before the rider anniversary) to the withdrawal base if no withdrawals have occurred during the preceding rider year. (3) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.	Benefit: •        Provides: (1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a series of cash withdrawals (and payments from us, if necessary), which are based on a withdrawal percentage that is higher for a defined period and lower thereafter, regardless of the Designated Investment Option that you select. (2) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.	Benefit: •        Provides: (1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a level of cash withdrawals (and payments from us, if necessary) regardless of the performance of the designated investment choices that you select – if you invest in certain designated investment choices. (2) Growth—On each of the first 10 rider anniversaries, we add an annual growth credit (5% of the withdrawal base immediately before the rider anniversary) to the withdrawal base if no withdrawals have occurred during the preceding rider year. (3) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.

140

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
•        Upgrades: (1) Before the annuitant’s 86th birthday, you can upgrade the total withdrawal base (for GMWB) and the guaranteed future value (for GMAB) by sending us written notice. (2) If you upgrade, the current rider terminates and a new rider is issued (which may have a higher rider fee).	•        Upgrades: You may request by sending us written notice. If you upgrade, the current rider terminates and a new rider is issued (which may have a higher rider fee). If you have elected the joint life option under the rider, you cannot elect a manual upgrade if the annuitant or an annuitant’s spouse is 86 or older (unless state law requires a lower maximum age).

141

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
	•        Additional Options: (1) Death Benefit Option—You may add an amount to the death benefit payable under the base policy. (2) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner). (3) Income Enhancement Option—If the rider has been in effect for at least 12 months, then you may elect to have your withdrawal percentage double if either the annuitant or the annuitant’s spouse, if the joint life option is elected, is confined in a hospital or nursing facility because of a medical necessity, and has been so confined for an “elimination period” (i.e., 180 days within the last 365 days). You cannot elect this option if the qualifying person(s) is/are already confined in a hospital or nursing facility when the rider is elected. In addition, the increase to the withdrawal percentage stops when the qualifying person(s) is/are no longer confined.	•        Additional Options: (1) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner).	•        Additional Options: (1) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner).
Availability: •        0 - 80 (unless state law requires a lower maximum issue age	Availability: •        Younger than age 86 (unless state law requires a lower maximum issue age)	Availability: •        At least 55 years old and not yet age 81 (unless state law requires a lower maximum issue age)	Availability: •        Younger than age 86 (unless state law requires a lower maximum issue age)

142

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
Charge: (1) 0.90% of total withdrawal base on each rider anniversary under the “principal back” withdrawal guarantee under the rider.	Charges: (1) for Base Benefit only—0.45% to 1.40% annually (single and joint life) of withdrawal base deducted on each rider quarter; (2) Open Investment Option—1.20% annually (single life and joint life) of withdrawal base deducted on each rider quarter; (3) with Death Benefit Option—0.25% (single life) or 0.20% (joint life) annually of withdrawal base deducted on each rider quarter, in addition to the base benefit fee; (4) with Income Enhancement Option—0.15% (single life) or 0.30% (joint life) annually of withdrawal base deducted on each rider quarter, in addition to the base benefit fee.	Charges: (1) 0.90% annually (single life and joint life) of withdrawal base deducted on each rider quarter.	Charges: (1) 1.00% annually (single life and joint life) of withdrawal base deducted on each rider quarter.
Investment Restrictions: •        Portfolio Allocation Method (“PAM”)—We monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts between investment options that we designate and the variable investment choices that you select.	Investment Restrictions: •        Designated Investment option—You must allocate 100% of your policy value to one or more investment options that we designate. •        Open Investment option (“OA”) – We monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts between investment options that we designate and the variable investment choices that you select.	Investment Restrictions: •        Designated Investment option—You must allocate 100% of your policy value to one or more investment options that we designate.	Investment Restrictions: •        You must allocate 100% of your policy value to one or more investment options that we designate.

143

APPENDIX

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS

The following examples show the effect of withdrawals on the benefits under the Living Benefits Rider.

GUARANTEED MINIMUM ACCUMULATION BENEFIT

Gross partial withdrawals will reduce the guaranteed future value by an amount equal to the greater of:

1) the gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the amount of gross partial withdrawal;

B is the policy value immediately prior to the gross partial withdrawal; and

C is the guaranteed future value immediately prior to the gross partial withdrawal.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under the guaranteed minimum accumulation benefit.

EXAMPLE 1:

Assumptions:

Policy value prior to withdrawal (“PV”) = $90,000

Guaranteed future value prior to withdrawal (“GFV”) = $100,000

Gross withdrawal amount (“WD”) = $10,000

Step One. What is the pro rata value of the amount withdrawn?

1. Formula is (WD / PV) * GFV = pro rata amount

2. ($10,000 / $90,000) * $100,000 = $11,111.11

Step Two. Which is larger, the $10,000 withdrawal or the $11,111.11 pro rata amount?

$11,111.11 pro rata amount

Step Three. After the withdrawal is taken, what will be new guaranteed future value?

$100,000 - $11,111.11 = $88,888.89

Result. If no more withdrawals are taken, the guaranteed future value on the 10th rider anniversary is $88,888.89.

144

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

EXAMPLE 2:

Assumptions:

PV = $120,000

GFV = $100,000

WD = $10,000

Step One. What is the pro rata value of the amount withdrawn?

1. Formula is (WD / PV) * GFV = pro rata amount

2. ($10,000 / $120,000) * $100,000 = $8,333.33

Step Two. Which is larger, the $10,000 withdrawal or the $8,333.33 pro rata amount?

$10,000 withdrawal

Step Three. After the withdrawal is taken, what will be new guaranteed future value?

$100,000 - $10,000 = $90,000

Result. If no more withdrawals are taken, the guaranteed future value on the 10th Rider Anniversary is $90,000.

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

Total Withdrawal Base. Gross partial withdrawals up to the maximum annual withdrawal amount will not reduce the total withdrawal base. Gross partial withdrawals in excess of the maximum annual withdrawal amount will reduce the total withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the total withdrawal base prior to the withdrawal of the excess amount.

Minimum Remaining Withdrawal Amount. Gross partial withdrawals up to the maximum annual withdrawal amount will reduce the minimum remaining withdrawal amount by the same amount (dollar-for-dollar). Gross partial withdrawals in excess of the maximum annual withdrawal amount will reduce the minimum remaining withdrawal amount by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

145

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the minimum remaining withdrawal amount after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under the guaranteed lifetime withdrawal benefit.

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Minimum remaining withdrawal amount (“MRWA”)

2. Total withdrawal base (“TWB”)

3. Maximum annual withdrawal amount (“MAWA”)

EXAMPLE 1 (7% “PRINCIPAL BACK”):

Assumptions:

TWB = $100,000

MRWA = $100,000

7% WD would be $7,000 (7% of the current $100,000 total withdrawal base)

WD = $7,000

Excess withdrawal (“EWD”) = None

PV = $100,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the withdrawal greater than the “principal back” maximum annual withdrawal amount?

No. There is no excess withdrawal under the “principal back” guarantee if no more than $7,000 is withdrawn.

Step Two. What is the minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $7,000 (there is no excess to deduct)

2. $100,000 - $7,000 = $93,000.

Result. In this example, because no portion of the withdrawal was in excess of $7,000, the “principal back” total withdrawal base does not change and the “principal back” minimum remaining withdrawal amount is $93,000.00.

EXAMPLE 2 (7% “PRINCIPAL BACK”):

Assumptions:

TWB = $100,000

146

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

MRWA = $100,000

7% WD would be $7,000 (7% of the current $100,000 total withdrawal base)

WD = $8,000

EWD = $1,000 ($8,000 - $7,000)

PV = $90,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the total withdrawal greater than the maximum annual withdrawal amount?

Yes. $8,000 - $7,000 = $1,000 (the excess withdrawal amount)

Step Two. Calculate how much of the “principal back” minimum remaining withdrawal amount is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 7% WD)) * (MRWA - 7% WD)

2. ($1,000 / ($90,000 - $7,000)) * ($100,000 - $7,000) = $1,120.48

Step Three. Which is larger, the actual $1,000 excess withdrawal amount or the $1,120.48 pro rata amount?

$1,120.48 pro rata amount

Step Four. What is the “principal back” minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $7,000 + $1,120.48 (pro rata excess) = $8,120.48

2. $100,000 - $8,120.48 = $91,879.52

Result. The “principal back” minimum remaining withdrawal amount is $91,879.52.

NOTE. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the total withdrawal base needs to be adjusted as well as a new lower maximum annual withdrawal amount. Had the withdrawal for this example not been more than $7,000, the “principal back” total withdrawal base would remain at $100,000 and the “principal back” maximum annual withdrawal amount would be $7,000. However, because an excess withdrawal has been taken, the total withdrawal base is also changed (this is the amount the 7% is based on).

New “principal back” total withdrawal base:

Step One. The total withdrawal base is only reduced by the excess withdrawal amount or the pro rata amount if greater.

Step Two. Calculate how much the total withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 7% WD)) * TWB before any adjustments

2. ($1,000 / ($90,000 - $7,000)) * $100,000 = $1,204.82

147

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

Step Three. Which is larger, the actual $1,000 excess withdrawal amount or the $1,204.82 pro rata amount?

$1,204.82 pro rata amount.

Step Four. What is the new total withdrawal base upon which the maximum annual withdrawal amount is based?

$100,000 - $1,204.82 = $98,795.18

Result. The new “principal back” total withdrawal base is $98,795.18

New “principal back” maximum annual withdrawal amount:

Because the “principal back” total withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new maximum annual withdrawal amount for the 7% “principal back” guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new “principal back” maximum annual withdrawal amount?

$98,795.18 (the adjusted total withdrawal base) * 7% = $6,915.66

Result. Going forward, the maximum you can take out in a rider year is $6,915.66 without causing an excess withdrawal for the “principal back” guarantee and further reduction of the “principal back” total withdrawal base.

EXAMPLE 3 (5% “FOR LIFE”):

Assumptions:

TWB = $100,000

MRWA = $100,000

5% WD would be $5,000 (5% of the current $100,000 total withdrawal base)

WD = $5,000

Excess withdrawal (“EWD”) = None

PV = $100,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the withdrawal greater than the “for life” maximum annual withdrawal amount?

No. There is no excess withdrawal under the “for life” guarantee if no more than $5,000 is withdrawn.

Step Two. What is the minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $5,000 (there is no excess to deduct).

2. $100,000 - $5,000 = $95,000.

Result. In this example, because no portion of the withdrawal was in excess of $5,000, the “for life” total withdrawal base does not change and the “for life” minimum remaining withdrawal amount is $95,000.00.

148

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

EXAMPLE 4 (5% “FOR LIFE”):

Assumptions:

TWB = $100,000

MRWA = $100,000

5% WD would be $5,000 (5% of the current $100,000 total withdrawal base)

WD = $7,000

EWD = $2,000 ($7,000 - $5,000)

PV = $90,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the total withdrawal greater than the maximum annual withdrawal amount?

Yes. $7,000 - $5,000 = $2,000 (the excess withdrawal amount)

Step Two. Calculate how much of the “for life” minimum remaining withdrawal amount is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 5% WD)) * (MRWA - 5% WD)

2. ($2,000 / ($90,000 - $5,000)) * ($100,000 - $5,000) = $2,235.29

Step Three. Which is larger, the actual $2,000 excess withdrawal amount or the $2,235.29 pro rata amount?

$2,235.29 pro rata amount

Step Four. What is the “for life” minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $5,000 + $2,235.29 (pro rata excess) = $7,235.29

2. $100,000 - $7,235.29 = $92,764.71

Result. The “for life” minimum remaining withdrawal amount is $92,764.71.

NOTE. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the total withdrawal base needs to be adjusted as well as a new lower maximum annual withdrawal amount. Had the withdrawal for this example not been more than $5,000, the “for life” total withdrawal base would remain at $100,000 and the “for life” maximum annual withdrawal amount would be $5,000. However, because an excess withdrawal has been taken, the total withdrawal base is also changed (this is the amount the 5% is based on).

New “for life” total withdrawal base:

Step One. The total withdrawal base is only reduced by the excess withdrawal amount or the pro rata amount if greater.

149

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

Step Two. Calculate how much the total withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 5% WD)) * TWB before any adjustments

2. ($2,000 / ($90,000 - $5,000)) * $100,000 = $2,352.94

Step Three. Which is larger, the actual $2,000 excess withdrawal amount or the $2,352.94 pro rata amount?

$2,352.94 pro rata amount.

Step Four. What is the new total withdrawal base upon which the maximum annual withdrawal amount is based?

$100,000 - $2,352.94 = $97,647.06

Result. The new “for life” total withdrawal base is $97,647.06

New “for life” maximum annual withdrawal amount:

Because the “for life” total withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new maximum annual withdrawal amount for the 5% “for life” guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new “for life” maximum annual withdrawal amount?

$97,647.06 (the adjusted total withdrawal base) * 5% = $4,882.35

Result. Going forward, the maximum you can take out in a rider year is $4,882.35 without causing an excess withdrawal for the “for life” guarantee and further reduction of the “for life” total withdrawal base.

150

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME CHOICE^® 1.2 RIDER

AND RETIREMENT INCOME CHOICE^® 1.4 RIDER (RETIREMENT INCOME

CHOICE^® 1.4 - NO LONGER AVAILABLE FOR NEW SALES)

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

3. Rider Death Benefit (“RDB”)

Withdrawal Base. Gross partial withdrawals in a rider year up to the rider withdrawal amount will not reduce the withdrawal base. Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the withdrawal base prior to the withdrawal of the excess amount.

Rider Death Benefit. Gross partial withdrawals in a rider year up to the rider withdrawal amount will reduce the rider death benefit by the amount withdrawn (dollar-for-dollar). Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the rider death benefit by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the rider death benefit after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Example 1 (Base):

Assumptions:

Withdrawal Base (“WB”) = $100,000

151

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Rider Withdrawal Amount (“RWA”) = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

Gross partial withdrawal (“GPWD”) = $5,000

Excess withdrawal (“EWD”) = None

Policy Value (“PV”) = $100,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee since no more than $5,000 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $5,000, the withdrawal base does not change.

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

RWA = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

GPWD = $7,000

EWD = $2,000 ($7,000 - $5,000)

PV = $90,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5%.

Result. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $5,000, the withdrawal base would remain at $100,000 and the rider withdrawal amount would be $5,000 starting on the next rider anniversary. However, because an excess withdrawal has been taken, the withdrawal base is also reduced (this is the amount the 5% is based on).

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 5% withdrawal)) * WB before any adjustments

2. ($2,000 / ($90,000 - $5,000)) * $100,000 = $2,353

Step Three. Which is larger, the actual $2,000 excess withdrawal or the $2,353 pro rata amount? $2,353 pro rata amount.

152

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based? $100,000 - $2,353 = $97,647

Result. The new withdrawal base is $97,647

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5% guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Question: What is the new rider withdrawal amount?

$97,647 (the adjusted withdrawal base) * 5% = $4,882

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $4,882.

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 8 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 8 = $147,745

RWA = 5% withdrawal beginning 8 years from the rider date would be $7,387 (5% of the then-current $147,745 withdrawal base)

GPWD = $7,387

EWD = None

PV = $90,000 in 8 years

You (if you elected RIC 1.2 or RIC 1.4 ) = owner and annuitant, age 68 on rider issue; age 76 at time withdrawals begin, which means Withdrawal Percentage is 5%

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $7,387 is withdrawn in a rider year.

Result. In this example, because no portion of the withdrawal was in excess of $7,387, the withdrawal base does not change.

153

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Example 4 (Base demonstrating WB growth with Additional Death Payment Option):

Assumptions:

You (if you elected RIC 1.2 or RIC 1.4 ) = owner and annuitant, age 68 on rider issue; age 76 at time withdrawals begin, which means Withdrawal Percentage is 5%

WB at rider issue = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 8 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 8 = $147,745

Rider Death Benefit (“RDB”) (optional additional death benefit for additional cost) = $100,000

RWA = 5% withdrawal beginning 8 years from the rider date would be $7,387 (5% of the then-current $147,745 withdrawal base)

GPWD = $7,387

EWD = None

PV = $90,000 in 8 years

Step One. Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $7,387 is withdrawn.

Step Two. What is the rider death benefit after the withdrawal has been taken?

1. Total to deduct from the rider death benefit is $7,387 (there is no excess to deduct)

2. $100,000 - $7,387 = $92,613.

Result. In this example, because no portion of the withdrawal was in excess of $7,387, the total withdrawal base does not change and the rider death benefit reduces to $92,613.

Example 5 (Base with WB growth with Additional Death Payment Option illustrating excess withdrawal):

Assumptions:

You = owner and annuitant, age 61 on rider issue; age 74 at time withdrawals begin, which means withdrawal percentage is 5%.

WB at rider issue = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 10 years (assuming an annual growth rate percentage of 5.0%) = the greater of $100,000 * (1 + .05) ^ 10 = $162,889.

RDB (optional additional death benefit for additional cost) = $100,000

RWA = 5% withdrawal beginning 10 years from the rider date would be $8,144 (5% of the then-current $162,889 withdrawal base)

GPWD = $15,000

EWD = $6,856 ($15,000 - $8,144)

PV = $90,000 in 10 years

154

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step One. Is any portion of the total withdrawal greater than the rider withdrawal amount?

Yes. $15,000 - $8,144 = $6,856 (the excess withdrawal amount)

Step Two. Calculate how much of the rider death benefit is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 5% withdrawal)) * (RDB - 5% withdrawal)

2. ($6,856 / ($90,000 - $8,144)) * ($100,000 - $8,144) = $7,694

Step Three. Which is larger, the actual $6,856 excess withdrawal amount or the $7,694 pro rata amount?

$7,694 pro rata amount.

Step Four. What is the rider death benefit after the withdrawal has been taken?

1. Total to deduct from the rider death benefit is $8,144 (RWA) + $7,694 (pro rata excess) = $15,838

2. $100,000 - $15,838 = $84,162.

Result. The rider benefit is $84,162.

Note: Because there was an excess withdrawal amount in this example, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $8,144, the withdrawal base would remain at $162,889 and the rider withdrawal amount would be $8,144. However, because an excess withdrawal has been taken, the withdrawal base is also reduced.

New benefit base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD/(PV - 5% withdrawal)) * WB before any adjustments

2. ($6,856 / ($90,000 - $8,144)) * $162,889 = $13,643

Step Three. Which is larger, the actual $6,856 excess withdrawal amount or the $13,643 pro rata amount?

$13,643 pro rata amount.

Step Four. What is the new withdrawalt base upon which the rider withdrawal amount is based?

$162,889 - $13,643 = $149,246

Result. The new benefit base is $149,246

155

Guaranteed Lifetime Withdrawal Benefit — (Continued)

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5% benefit percentage guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new rider withdrawal amount?

$149,246 (the adjusted withdrawal base) * 5% = $7,462

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the benefit base is $7,462.

156

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS - INCOME LINK^® RIDER

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

3. Income Link^® Rider Systematic Withdrawals (“ILSW”)

Withdrawal Base. Income Link^® rider systematic withdrawals (and certain minimum required distributions) will not reduce the withdrawal base. Non-Income Link^® rider systematic withdrawals (and minimum required distributions calculated other than as provided for in the rider or not taken via a systematic withdrawal program) will reduce the withdrawal base by an amount equal to the greater of:

1) the amount of the non-Income Link^® rider systematic withdrawal (or non-qualifying minimum required distribution); and

2) a pro rata amount, the result of (A / B) * C, where:

A is the amount in 1 above;

B is the policy value prior to the withdrawal; and

C is the withdrawal base prior to the withdrawal.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Assumptions:

WB = $100,000

RWA = 6% withdrawal would be $6,000 (6% of the current $100,000 withdrawal base)

ILSW = $500 per month

Non-ILSW = $10,000 (taken after the eighteenth monthly Income Link^® rider systematic withdrawal)

PV = $90,000

Assumes single life withdrawal option of 6% for 6 years and 4% thereafter has been elected. Non-Income Link^® rider systematic withdrawal occurs during the second Income Link^® rider withdrawal year (which means the withdrawal percentage is 6%).

Result. For the guaranteed lifetime withdrawal benefit, because there was a non-Income Link^® rider systematic withdrawal, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount and Income Link^® rider systematic withdrawal amount calculated.

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the amount of the non-Income Link^® rider systematic withdrawal or the pro rata amount, if greater.

157

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step Two. Calculate how much the withdrawal base is affected by the non-Income Link^® rider systematic withdrawal.

1. The formula is (Non-ILSW / (PV before withdrawal)) * WB before any adjustments

2. ($10,000 / ($90,000)) * $100,000 = $11,111

Step Three. Which is larger, the actual $10,000 non-Income Link^® rider systematic withdrawal or the $11,111 pro rata amount?

$11,111 pro rata amount.

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $11,111 = $88,889

Result. The new withdrawal base is $88,889. Please note the percentage reduction in the withdrawal base is used in calculating the revised RWA and ILSW.

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the non-Income Link^® rider systematic withdrawal) we have to calculate a new (remaining) rider withdrawal amount. This calculation assumes no more non-Income Link^® rider systematic withdrawal activity prior to the next Income Link^® rider withdrawal year.

Question: What is the new (remaining) rider withdrawal amount for the remainder of the Income Link^® rider withdrawal year?

$3,000 (the remaining rider withdrawal amount) - ($3000*11.11%) = $2,667

Result. Going forward, the maximum you can take out in a benefit year without causing a negative withdrawal base adjustment and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $5,333.

New Income Link^® rider systematic withdrawal amount:

Because the withdrawal base was adjusted (due to the non-Income Link^® rider systematic withdrawal) we have to calculate a new Income Link^® rider systematic withdrawal amount. This calculation assumes no more non-Income Link^® rider systematic withdrawal activity prior to the next Income Link^® rider withdrawal year.

Question: What is the new Income Link^® rider systematic withdrawal amount?

$500 (the old Income Link^® rider systematic withdrawal amount) - ($500*11.11%) = $444

Result. Going forward (until the seventh Income Link^® rider withdrawal year), the Income Link^® rider systematic withdrawal amount (assuming there are no future automatic step-ups) is $444

158

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME MAX^SM RIDER

When a withdrawal is taken, the following parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

Withdrawal Base. Gross partial withdrawals in a rider year up to the rider withdrawal amount will not reduce the withdrawal base. Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the rider withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the withdrawal base prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Example 1 (Base):

Assumptions:

Withdrawal Base (“WB”) = $100,000

Rider Withdrawal Amount (“RWA”) = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base)

Gross partial withdrawal (“GPWD”) = $5,500

Excess withdrawal (“EWD”) = None

Policy Value (“PV”) = $100,000 (PV after GPWD = $94,500)

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee since no more than $5,500 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $5,500, the withdrawal base does not change.

159

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

RWA = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base)

GPWD = $7,000

EWD = $1,500 ($7,000 - $5,500)

PV = $90,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Result. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $5,500, the withdrawal base would remain at $100,000 and the rider withdrawal amount would be $5,500 starting on the next rider anniversary. However, because an excess withdrawal has been taken, the withdrawal base is also reduced (this is the amount the 5.5% is based on).

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 5.5% withdrawal)) * WB before any adjustments

2. ($1,500 / ($90,000 - $5,500)) * $100,000 = $1,775

Step Three. Which is larger, the actual $1,500 excess withdrawal or the $1,775 pro rata amount?

$1,775 pro rata amount.

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $1,775 = $98,225

Result. The new withdrawal base is $98,225

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5.5% guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Question: What is the new rider withdrawal amount?

$98,225 (the adjusted withdrawal base) * 5.5% = $5,402.38

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $5,402.38.

160

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Automatic step-up never occurs and no withdrawals are taken.

WB in 8 years (assuming an annual growth rate percentage of 5%) = $100,000 * (1 + .05) ^ 8 = $147,746

RWA = 5.5% withdrawal beginning 8 years from the rider date would be $8,126 (5.5% of the then-current $147,746 withdrawal base)

GPWD = $8,126

EWD = None

PV = $90,000 in 8 years

You = owner and annuitant, age 63 on rider issue; age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $8,126 is withdrawn in a rider year.

Result. In this example, because no portion of the withdrawal was in excess of $8,126, the withdrawal base does not change.

Example 4 (Minimum Required Distribution “MRD”):

WB= $100,000

Automatic Step-up and growth never occur.

RWA for rider year beginning July 1, 2010 = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base.

MRD for 2010 = $6,000 (calculated as set forth in the rider)

MRD for 2011 = $6,500 (calculated as set forth in the rider)

GPWD on February 1, 2011 = $6,500 EWD = $500

Question: Is any portion of the withdrawal greater than the rider withdrawal amount or the minimum required withdrawal calculated pursuant to the terms of the rider?

Yes. Because more than $6,000 (the greater of the RWA ($5,500) or MRD for the tax year on that rider anniversary ($6,000) was withdrawn, there is an excess withdrawal of $500 (6,500 - 6,000 = 500). Please note, even though the withdrawal occurred in 2011, the MRD for 2011 does not become part of the RWA calculation until July 1, 2011 (the rider anniversary during that tax year).

Result: Because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower withdrawal amount calculated. See Example 2 (Excess Withdrawal) for an example ofhow the new withdrawal base and new rider withdrawal amount are calculated.

161

APPENDIX

HYPOTHETICAL EXAMPLE OF THE WITHDRAWAL BASE CALCULATION -

RETIREMENT INCOME MAX^SM RIDER

The following table demonstrates, on a purely hypothetical basis, the withdrawal base calculation for the Retirement Income Max^SM rider using an initial premium payment of $100,000 for a Single Life Option rider at an issue age of 80. All values shown are post transaction values.

Rider Year	Hypothetical Policy Value		Subsequent Premium Payment		Withdrawal		Excess WB Adjustment		Growth Amount		High Monthiversary Value		Withdrawal Base			Rider Withdrawal Amount
	$	100,000	$		$		$		$		$	100,000	$	100,000		$	6,500
1	$	102,000	$		$		$		$		$	102,000	$	100,000		$	6,500
1	$	105,060	$		$		$		$		$	105,060	$	100,000		$	6,500
1	$	107,161	$		$		$		$		$	107,161	$	100,000		$	6,500
1	$	110,376	$		$		$		$		$	110,376	$	100,000		$	6,500
1	$	112,584	$		$		$		$		$	112,584	$	100,000		$	6,500
1	$	115,961	$		$		$		$		$	115,961	$	100,000		$	6,500
1	$	118,280	$		$		$		$		$	118,280	$	100,000		$	6,500
1	$	121,829	$		$		$		$		$	121,829	$	100,000		$	6,500
1	$	124,265	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	120,537	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	115,716	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	109,930	$		$		$		$	105,000	$	124,265	$	124,265	1	$	8,077
2	$	112,129	$		$		$		$		$	112,129	$	124,265		$	8,077
2	$	115,492	$		$		$		$		$	115,492	$	124,265		$	8,077
2	$	117,802	$		$		$		$		$	117,802	$	124,265		$	8,077
2	$	121,336	$		$		$		$		$	121,336	$	124,265		$	8,077
2	$	124,976	$		$		$		$		$	124,976	$	124,265		$	8,077
2	$	177,476	$	50,000	$		$		$		$	177,476	$	174,265		$	11,327
2	$	175,701	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	172,187	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	167,022	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	163,681	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	166,955	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	170,294	$		$		$		$	182,979	$	177,476	$	182,979	2	$	11,894
3	$	166,888	$		$		$		$		$	166,888	$	182,979		$	11,894
3	$	171,895	$		$		$		$		$	171,895	$	182,979		$	11,894
3	$	173,614	$		$		$		$		$	173,614	$	182,979		$	11,894
3	$	178,822	$		$		$		$		$	178,822	$	182,979		$	11,894
3	$	175,246	$		$		$		$		$	178,822	$	182,979		$	11,894
3	$	151,741	$		$	20,000	$	9,279	$		$		$	173,699		$
3	$	154,775	$		$		$		$		$		$	173,699		$
3	$	159,419	$		$		$		$		$		$	173,699		$

162

Rider Year	Hypothetical Policy Value		Subsequent Premium Payment	Withdrawal	Excess WB Adjustment	Growth Amount	High Monthiversary Value	Withdrawal Base			Rider Withdrawal Amount
3	$	161,013	$	$	$	$	$	$	173,699		$
3	$	165,843	$	$	$	$	$	$	173,699		$
3	$	174,135	$	$	$	$	$	$	173,699		$
3	$	181,101	$	$	$	$	$	$	181,101	1	$	11,772

⁽¹⁾  Automatic Step Up Applied

⁽²⁾  Growth Applied

163

TRANSAMERICA EXTRA VARIABLE ANNUITY

Issued by

TRANSAMERICA LIFE INSURANCE COMPANY

Supplement Dated May 1, 2011

to the

Prospectus dated May 1, 2011

We will not accept any premium payment that is allocated to the fixed account or the dollar cost averaging fixed account in excess of $5,000. We also will not accept any premium payment or transfer which would result in the aggregate policy value in the fixed account and the dollar cost averaging fixed account exceeding $5,000.

This Prospectus Supplement must be accompanied or preceded

by the Prospectus for the

Transamerica EXTRA Variable Annuity dated May 1, 2011

TRANSAMERICA EXTRA VARIABLE ANNUITY

Issued by

TRANSAMERICA LIFE INSURANCE COMPANY

Supplement Dated May 1, 2011

to the

Prospectus dated May 1, 2011

Some selling firms discourage their clients from purchasing certain optional benefits based solely on the client’s age. You should work with your registered representative to decide whether an optional benefit is appropriate for you based on a thorough analysis of your particular insurance needs, financial objectives, investment goals, time horizons and risk tolerance.

This Prospectus Supplement must be accompanied or preceded

by the Prospectus for the

Transamerica EXTRA Variable Annuity dated May 1, 2011

STATEMENT OF ADDITIONAL INFORMATION

TRANSAMERICA EXTRA^SM VARIABLE ANNUITY

Issued through

SEPARATE ACCOUNT VA C

Offered by

TRANSAMERICA LIFE INSURANCE COMPANY

This Statement of Additional Information expands upon subjects discussed in the current prospectus for the Transamerica Extra^SM Variable Annuity offered by Transamerica Life Insurance Company. You may obtain a copy of the current prospectus, dated May 1, 2011, by calling (800) 525-6205, or write us at: Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001. The prospectus sets forth information that a prospective investor should know before investing in a policy. Terms used in the current prospectus for the policy are incorporated in this Statement of Additional Information.

This Statement of Additional Information (SAI) is not a prospectus and should be read only in conjunction with the prospectuses for the policy and the underlying fund portfolios.

Dated: May 1, 2011

TABLE OF CONTENTS

GLOSSARY OF TERMS	3
THE POLICY — GENERAL PROVISIONS	6
Owner	6
Entire Policy	6
Misstatement of Age or Sex	7
Reallocation of Annuity Units After the Annuity Commencement Date	7
Annuity Payment Options	7
Death Benefit	8
Death of Owner	9
Assignment	9
Evidence of Survival	9
Non-Participating	9
Amendments	9
Employee and Agent Purchases	10
Present Value of Future Variable Payments	10
Stabilized Payments	10
CERTAIN FEDERAL INCOME TAX CONSEQUENCES	11
Tax Status of the Policy	11
Taxation of Annuities	12
Taxation of the Company	15
INVESTMENT EXPERIENCE	15
Accumulation Units	15
Annuity Unit Value and Annuity Payment Rates	17
HISTORICAL PERFORMANCE DATA	19
Money Market Yields	19
Total Returns	21
Other Performance Data	21
Adjusted Historical Performance Data	22
PUBLISHED RATINGS	22
STATE REGULATION OF TRANSAMERICA LIFE INSURANCE COMPANY	22
ADMINISTRATION	22
RECORDS AND REPORTS	22
DISTRIBUTION OF THE POLICIES	23
VOTING RIGHTS	23
OTHER PRODUCTS	24
CUSTODY OF ASSETS	24
LEGAL MATTERS	24
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM	25
OTHER INFORMATION	25
FINANCIAL STATEMENTS	25
APPENDIX
CONDENSED FINANCIAL INFORMATION	26
APPENDIX
OA METHOD TRANSFERS	64
APPENDIX
PAM METHOD TRANSFERS	69

2

GLOSSARY OF TERMS

Accumulation Unit — An accounting unit of measure used in calculating the policy value in the separate account before the annuity commencement date.

Adjusted Policy Value — The policy value increased or decreased by any excess interest adjustment.

Administrative and Service Office — Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001, (800) 525-6205.

Annuitant — The person on whose life any annuity payments involving life contingencies will be based.

Annuity Commencement Date — The date upon which annuity payments are to commence. This date may be any date after the policy date and may not be later than the last day of the policy month following the month after the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy. The annuity commencement date may have to be earlier for qualified policies and may be earlier if required by state law.

Annuity Payment Option — A method of receiving a stream of annuity payments selected by the owner.

Annuity Unit — An accounting unit of measure used in the calculation of the amount of the second and each subsequent variable annuity payment.

Assumed Investment Return or AIR — The annual effective rate shown in the contract specifications section of the contract that is used in the calculation of each variable annuity payment.

Beneficiary — The person who has the right to the death benefit as set forth in the policy.

Business Day — A day when the New York Stock Exchange is open for regular trading.

Cash Value — The adjusted policy value less any applicable surrender charge and rider fees (imposed upon surrender).

Code — The Internal Revenue Code of 1986, as amended.

Enrollment form — A written application, order form, or any other information received electronically or otherwise upon which the policy is issued and/or is reflected on the data or specifications page.

Excess Interest Adjustment — A positive or negative adjustment to amounts surrendered (both partial or full surrenders and transfers) or applied to annuity payment options from the fixed account guaranteed period options prior to the end of the guaranteed period. The adjustment reflects changes in the interest rates declared by the Company since the date any payment was received by, or an amount was transferred to, the guaranteed period option. The excess interest adjustment can either decrease or increase the amount to be received by the owner upon full surrender or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively.

Excess Partial Surrender — The portion of a partial surrender (surrender) that exceeds the free amount.

3

Fixed Account — One or more investment choices under the policy that are part of the Company’s general assets and are not in the separate account.

Free Amount — The amount that can be withdrawn each year without incurring any surrender charge or excess interest adjustment.

Guaranteed Lifetime Withdrawal Benefit — Any optional benefit under the policy that provides a guaranteed minimum withdrawal benefit, including Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider

Guaranteed Period Options — The various guaranteed interest rate periods of the fixed account which the Company may offer and into which premium payments may be paid or amounts transferred.

Nonqualified Policy — A policy other than a qualified policy.

Owner (You, Your) — The person who may exercise all rights and privileges under the policy. The owner during the lifetime of the annuitant and prior to the annuity commencement date is the person designated as the owner in the information provided to us to issue a policy.

Policy Date — The date shown on the policy data page attached to the policy and the date on which the policy becomes effective.

Policy Value — On or before the annuity commencement date, the policy value is equal to the owner’s:

• premium payments; minus

• gross partial surrenders (partial surrenders minus excess interest adjustments plus the surrender charge on the portion of the requested partial surrender that is subject to the surrender charge); plus

• interest credited in the fixed account; plus

• accumulated gains in the separate account; minus

• accumulated losses in the separate account; minus

• service charges, rider fees, premium taxes, transfer fees, and other charges, if any.

Policy Year — A policy year begins on the policy date and on each anniversary thereof.

Premium Payment — An amount paid to the Company by the owner or on the owner’s behalf as consideration for the benefits provided by the policy.

Qualified Policy — A policy issued in connection with retirement plans that qualify for special federal income tax treatment under the Code.

Separate Account — Separate Account VA C, a separate account established and registered as a unit investment trust under the Investment Company Act of 1940, as amended (the “1940 Act”), to which premium payments under the policies may be allocated.

Separate Account Value — The portion of the policy value that is invested in the separate account.

4

Service Charge — An annual charge on each policy anniversary (and a charge at the time of surrender during any policy year) for policy maintenance and related administrative expenses. This annual charge is $35, but will not exceed 2% of the policy value.

Subaccount — A subdivision within the separate account, the assets of which are invested in a specified underlying fund portfolios.

Supportable Payment — The amount equal to the sum of the variable annuity unit values multiplied by the number of variable annuity units in each of the selected subaccounts.

Surrender Charge — A percentage of each premium payment that depends upon the length of time from the date of each premium payment. The surrender charge is assessed on full or partial surrenders from the policy. A surrender charge may also be referred to as a “contingent deferred sales charge.”

Valuation Period — The period of time from one determination of accumulation unit values and annuity unit values to the next subsequent determination of values. Such determination shall be made on each business day.

Variable Annuity Payments — Payments made pursuant to an annuity payment option which fluctuate as to dollar amount or payment term in relation to the investment performance of the specified subaccounts within the separate account.

Written Notice — Written notice, signed by the owner, that gives the Company the information it requires and is received at the administrative and service office. For some transactions, the Company may accept an electronic notice, such as telephone instructions, instead of written notice. Such written or electronic notice must meet the requirements the Company establishes for such notices.

5

In order to supplement the description in the prospectus, the following provides additional information about Transamerica Life Insurance Company (the Company, we, us or our) and the policy, which may be of interest to a prospective purchaser.

THE POLICY — GENERAL PROVISIONS

Owner

The policy shall belong to the owner upon issuance of the policy after completion of an enrollment form and delivery of the initial premium payment. While the annuitant is living, the owner may: (1) assign the policy; (2) surrender the policy; (3) amend or modify the policy with the Company’s consent; (4) receive annuity payments or name a payee to receive the payments; and (5) exercise, receive and enjoy every other right and benefit contained in the policy. The exercise of these rights may be subject to the consent of any assignee or irrevocable beneficiary; and of your spouse in a community or marital property state.

Unless the Company has been notified of a community or marital property interest in the policy, it will rely on its good faith belief that no such interest exists and will assume no responsibility for inquiry.

Note carefully. If the owner predeceases the annuitant and no joint owner, primary beneficiary, or contingent beneficiary is alive or in existence on the date of death, the owner’s estate will become the new owner. If no probate estate is opened because the owner has precluded the opening of a probate estate by means of a trust or other instrument, that trust may not exercise ownership rights to the policy. It may be necessary to open a probate estate in order to exercise ownership rights to the policy.

The owner may change the ownership of the policy in a written notice. When this change takes effect, all rights of ownership in the policy will pass to the new owner. A change of ownership may have tax consequences.

When there is a change of owner, the change will not be effective until it is recorded in our records. Once recorded, it will take effect as of the date the owner signs the written notice, subject to any payment the Company has made or action the Company has taken before recording the change. Changing the owner does not change the designation of the beneficiary or the annuitant.

If ownership is transferred to a new owner (except to the owner’s spouse) because the owner dies before the annuitant, then (a) the cash value generally must be distributed to the new owner within five years of the owner’s death, or (b) annuity payments must be made for a period certain or for the new owner’s lifetime so long as any period certain does not exceed that new owner’s life expectancy, if the first payment begins within one year of your death.

Entire Policy

The policy, any endorsements or riders thereon, the enrollment form, or information provided in lieu thereof, constitute the entire contract between the Company and the owner. All statements in the enrollment form are representations and not warranties. No statement will cause the policy to be void or to be used in defense of a claim unless contained in the enrollment form or information provided in lieu thereof.

6

Misstatement of Age or Sex

If the age or sex of the annuitant or owner has been misstated, the Company will change the annuity benefit payable to that which the premium payments would have purchased for the correct age or sex. The dollar amount of any underpayment made by the Company shall be paid in full with the next payment due such person or the beneficiary. The dollar amount of any overpayment made by the Company due to any misstatement shall be deducted from payments subsequently accruing to such person or beneficiary. Any underpayment or overpayment will include interest at 5% per year, from the date of the wrong payment to the date of the adjustment. The age of the annuitant or owner may be established at any time by the submission of proof satisfactory to the Company.

Reallocation of Annuity Units After the Annuity Commencement Date

After the annuity commencement date, you may reallocate the value of a designated number of annuity units of a subaccount then credited to a policy into an equal value of annuity units of one or more other subaccounts or the fixed account. The reallocation shall be based on the relative value of the annuity units of the account(s) or subaccount(s) at the end of the business day on the next payment date. The minimum amount which may be reallocated is the lesser of (1) $10 of monthly income or (2) the entire monthly income of the annuity units in the account or subaccount from which the transfer is being made. If the monthly income of the annuity units remaining in an account or subaccount after a reallocation is less than $10, the Company reserves the right to include the value of those annuity units as part of the transfer. The request must be in writing to the Company’s administrative and service office. There is no charge assessed in connection with such reallocation. A reallocation of annuity units may be made up to four times in any given policy year.

After the annuity commencement date, no transfers may be made from the fixed account to the separate account.

Annuity Payment Options

Note: Portions of the following discussion do not apply to annuity payments under the Initial Payment Guarantee. See the “Stabilized Payments” section of this SAI.

During the lifetime of the annuitant and before the annuity commencement date, the owner may choose an annuity payment option or change the election, but notice of any election or change of election must be received by the Company in good order at its Administrative and Service Office at least thirty (30) days before the annuity commencement date (elections less than 30 days require prior approval). If no election is made before the annuity commencement date, annuity payments will be made under (1) life income with level (fixed) payments for 10 years certain, using the existing policy value of the fixed account, or (2) life income with variable payments for 10 years certain using the existing policy value of the separate account, or (3) a combination of (1) and (2).

The person who elects an annuity payment option can also name one or more successor payees to receive any unpaid amount the Company has at the death of a payee. Naming these payees cancels any prior choice of a successor payee.

A payee who did not elect the annuity payment option does not have the right to advance or assign payments, take the payments in one sum, or make any other change. However, the payee may be given the right to do one or more of these things if the person who elects the option tells the Company in writing and the Company agrees.

7

Variable Payment Options. The dollar amount of the first variable annuity payment will be determined in accordance with the annuity payment rates set forth in the applicable table contained in the policy. For annuity payments the tables are based on a 5% effective annual Assumed Investment Return and the “2000 Table”, using an assumed annuity commencement date of 2005 (static projection to this point) with dynamic projection using scale G from that point (100% of G for male, 50% of G for females). The dollar amount of additional variable annuity payments will vary based on the investment performance of the subaccount(s) of the separate account selected by the annuitant or beneficiary.

Determination of the First Variable Payment. The amount of the first variable payment depends upon the sex (if consideration of sex is allowed under state law) and adjusted age of the annuitant. For regular annuity payments, the adjusted age is the annuitant’s actual age nearest birthday, on the annuity commencement date, adjusted as described in your policy. This adjustment assumes an increase in life expectancy, and therefore it results in lower payments than without such an adjustment.

Determination of Additional Variable Payments. All variable annuity payments other than the first are calculated using annuity units which are credited to the policy. The number of annuity units to be credited in respect of a particular subaccount is determined by dividing that portion of the first variable annuity payment attributable to that subaccount by the annuity unit value of that subaccount on the annuity commencement date. The number of annuity units of each particular subaccount credited to the policy then remains fixed, assuming no transfers to or from that subaccount occur. The dollar value of variable annuity units in the chosen subaccount will increase or decrease reflecting the investment experience of the chosen subaccount. The dollar amount of each variable annuity payment after the first may increase, decrease or remain constant. This amount is equal to the sum of the amounts determined by multiplying the number of annuity units of each particular subaccount credited to the policy by the annuity unit value for the particular subaccount on the date the payment is made.

Death Benefit

Due proof of death of the annuitant is proof that the annuitant died prior to the commencement of annuity payments. A certified copy of a death certificate, a certified copy of a decree of a court of competent jurisdiction as to the finding of death, a written statement by the attending physician, or any other proof satisfactory to the Company will constitute due proof of death.

Upon receipt in good order (at our Administrative and Service Office) of this proof and an election of a method of settlement and return of the policy, the death benefit generally will be paid within seven days, or as soon thereafter as the Company has sufficient information about the beneficiary(ies) to make the payment. The beneficiary may receive the amount payable in a lump sum cash benefit, or, subject to any limitation under any state or federal law, rule, or regulation, under one of the annuity payment options described above, unless a settlement agreement is effective at the death of the owner preventing such election.

If an owner is not an annuitant, and dies prior to the annuity commencement date, the new owner may surrender the policy at any time for the amount of the adjusted policy value. If the new owner is not the deceased owner’s spouse, however, (1) the adjusted policy value must be distributed within five years after the date of the deceased owner’s death, or (2) payments under an annuity payment option must begin no later than one year after the deceased owner’s death and must be made for the new owner’s lifetime or for a period certain (so long as any period certain does not exceed the new owner’s life expectancy). If the sole new owner is the deceased owner’s surviving spouse, such spouse may elect to continue the policy as the new owner instead of receiving the death benefit.

8

Beneficiary. The beneficiary designation in the enrollment form will remain in effect until changed. The owner may change the designated beneficiary by sending written notice to the Company. The beneficiary’s consent to such change is not required unless the beneficiary was irrevocably designated or law requires consent. (If an irrevocable beneficiary dies, the owner may then designate a new beneficiary.) The change will take effect as of the date the owner signs the written notice, whether or not the owner is living when the notice is received by the Company. The Company will not be liable for any payment made before the written notice is received. If more than one beneficiary is designated, and the owner fails to specify their interests, they will share equally. If upon the death of the annuitant there is a surviving owner(s), the surviving owner(s) automatically takes the place of any beneficiary designation.

Death of Owner

Federal tax law requires that if any owner (including any joint owner who has become a current owner) dies before the annuity commencement date, then the entire value of the policy must generally be distributed within five years of the date of death of such owner. Certain rules apply where (1) the spouse of the deceased owner is the sole beneficiary, (2) the owner is not a natural person and the primary annuitant dies or is changed, or (3) any owner dies after the annuity commencement date. See “Certain Federal Income Tax Consequences” for more information about these rules. Other rules may apply to qualified policies.

Assignment

During the lifetime of the annuitant you may assign any rights or benefits provided by the policy if your policy is a nonqualified policy. An assignment will not be binding on the Company until a copy has been filed at its administrative and service office. Your rights and benefits and those of the beneficiary are subject to the rights of the assignee. The Company assumes no responsibility for the validity or effect of any assignment. Any claim made under an assignment shall be subject to proof of interest and the extent of the assignment. An assignment may have tax consequences.

Unless you so direct by filing written notice with the Company, no beneficiary may assign any payments under the policy before they are due. To the extent permitted by law, no payments will be subject to the claims of any beneficiary’s creditors.

Ownership under qualified policies is restricted to comply with the Code.

Evidence of Survival

The Company reserves the right to require satisfactory evidence that a person is alive if a payment is based on that person being alive. No payment will be made until the Company receives such evidence.

Non-Participating

The policy will not share in the Company’s surplus earnings; no dividends will be paid.

Amendments

No change in the policy is valid unless made in writing by the Company and approved by one of the Company’s officers. No registered representative has authority to change or waive any provision of the policy.

9

The Company reserves the right to amend the policies to meet the requirements of the Code, regulations or published rulings. You can refuse such a change by giving written notice, but a refusal may result in adverse tax consequences.

Employee and Agent Purchases

The policy may be acquired by an employee or registered representative of any broker/dealer authorized to sell the policy or their immediate family, or by an officer, director, trustee or bona-fide full-time employee of the Company or its affiliated companies or their immediate family. In such a case, the Company in its discretion, may credit an amount equal to a percentage of each premium payment to the policy due to lower acquisition costs the Company experiences on those purchases. The Company may offer certain employer sponsored savings plans, reduced fees and charges including, but not limited to, the annual service charge, the surrender charges, the mortality and expense risk fee and the administrative charge for certain sales under circumstances which may result in savings of certain costs and expenses. In addition, there may be other circumstances of which the Company is not presently aware which could result in reduced sales or distribution expenses. Credits to the policy or reductions in these fees and charges will not be unfairly discriminatory against any owner.

Present Value of Future Variable Payments

The present value of future period certain variable payments is calculated by taking (a) the supportable payment on the business day we receive the surrender request (in good order at our Administrative and Service Office), multiplied by (b) the number of payments remaining, multiplied by a discount rate (such as the assumed investment rate or “AIR”).

Stabilized Payments

If you have selected a payout feature that provides for stabilized payments (e.g., the Initial Payment Guarantee), please note that the stabilized payments remain level throughout each year and are adjusted on your annuitization anniversary. Without stabilized payments, each payment throughout the year would fluctuate based on the performance of your selected subaccounts. To reflect the difference in these payments we adjust (both increase and decrease as appropriate) the number of annuity units. The annuity units are adjusted when we calculate the supportable payment. Supportable payments are used in the calculation of surrender values, death benefits and transfers. On the anniversary of your annuity commencement date we set the new stabilized payment equal to the current supportable payment. In the case of an increase in the number of variable annuity units, your participation in the future investment performance of the subaccounts will be increased because more variable annuity units are credited to you. Conversely, in the case of a reduction of the number of variable annuity units, your participation in the future investment performance of the subaccounts will be decreased because fewer variable annuity units are credited to you. If the Initial Payment Guarantee is chosen, then the stabilized variable annuity payment will equal the greater of the guaranteed payment or the supportable payment at that time.

10

The following table demonstrates, on a purely hypothetical basis, the changes in the number of variable annuity units. The changes in the variable annuity unit values reflect the investment performance of the applicable subaccounts as well as the separate account charge.

Hypothetical Changes in Annuity Units with Stabilized Payments*

Assumed Investment Rate	5.0%
Life & 10 Year Certain
Male aged 65
First Variable Payment	$500

		Beginning Annuity Units		Annuity Unit Values		Monthly Payment Without Stabilization		Monthly Stabilized Payment		Adjustments In Annuity Units			Cumulative Adjusted Annuity Units
At Issue:	January 1		400.0000		1.250000	$	500.00	$	500.00		0.0000			400.0000
	February 1		400.0000		1.252005	$	500.80	$	500.00		0.0041			400.0041
	March 1		400.0000		1.252915	$	501.17	$	500.00		0.0059			400.0100
	April 1		400.0000		1.245595	$	498.24	$	500.00		(0.0089	)		400.0011
	May 1		400.0000		1.244616	$	497.85	$	500.00		(0.0108	)		399.9903
	June 1		400.0000		1.239469	$	495.79	$	500.00		(0.0212	)		399.9691
	July 1		400.0000		1.244217	$	497.69	$	500.00		(0.0115	)		399.9576
	August 1		400.0000		1.237483	$	494.99	$	500.00		(0.0249	)		399.9327
	September 1		400.0000		1.242382	$	496.95	$	500.00		(0.0150	)		399.9177
	October 1		400.0000		1.242382	$	496.95	$	500.00		(0.0149	)		399.9027
	November 1		400.0000		1.249210	$	499.68	$	500.00		(0.0016	)		399.9012
	December 1		400.0000		1.252106	$	500.84	$	500.00		0.0040			399.9052
	January 1		399.9052		1.255106	$	501.92	$	501.92		0.0000			399.9052

* The total separate account expenses and portfolio expenses included in the calculations are 2.25% (2.25% is a hypothetical figure). If higher (or lower) expenses were charged, the numbers would be lower (or higher).

CERTAIN FEDERAL INCOME TAX CONSEQUENCES

The following summary does not constitute tax advice. It is a general discussion of certain of the expected federal income tax consequences of investment in and distributions with respect to a policy, based on the Code, Regulations thereunder, judicial authority, and current administrative rulings and practice. This summary discusses only certain federal income tax consequences to “United States Persons,” and does not discuss federal gift, estate or any other state, local, or foreign tax consequences. United States Persons means citizens or residents of the United States, domestic corporations, domestic partnerships and trusts, or estates that are subject to United States federal income tax regardless of the source of their income.

Tax Status of the Policy

Diversification Requirements. Section 817(h) of the Code provides that in order for a non-qualified variable policy which is based on a segregated asset account to qualify as an annuity policy under the Code, the investments made by

11

such account must be “adequately diversified” in accordance with Treasury Regulations. The Regulations issued under Section 817(h) (Treas. Reg. Section 1.817-5) apply a diversification requirement to each of the subaccounts. The separate account, through its underlying fund portfolios and their portfolios, intends to comply with the diversification requirements of the Regulations. We have entered into agreements with each underlying fund portfolio company that require the portfolios to be operated in compliance with the Regulations.

Owner Control. In some circumstances, owners of variable policies who retain excessive control over the investment of the underlying separate account assets may be treated as the owners of those assets and may be subject to tax on income produced by those assets. Although there is little guidance in this area and published guidance does not address certain aspects of the policies, we believe that the owner of a policy should not be treated as the owner of the underlying assets. We reserve the right to modify the policies to bring them into conformity with applicable standards should such modification be necessary to prevent owners of the policies from being treated as the owners of the underlying separate account assets.

Distribution Requirements. The Code requires that nonqualified policies contain specific provisions for distribution of policy proceeds upon the death of any owner. In order to be treated as an annuity policy for federal income tax purposes, the Code requires that such policies provide that if any owner dies on or after the annuity commencement date and before the entire interest in the policy has been distributed, the remaining portion must be distributed at least as rapidly as under the method in effect on such owner’s death. If any owner dies before the annuity commencement date, the entire interest in the policy must generally be distributed within 5 years after such owner’s date of death or be used to provide payments to a designated beneficiary beginning within one year of such owner’s death and will be made for the life of the beneficiary or for a period not extending beyond the life expectancy of the beneficiary. However, if upon such owner’s death prior to the annuity commencement date, such owner’s surviving spouse becomes the sole new owner under the policy, then the policy may be continued with the surviving spouse as the new owner. Under the policy, the beneficiary is the person(s) designated by an owner/annuitant and the surviving joint owner is the beneficiary of an owner who is not the annuitant. If any owner is not a natural person, then for purposes of these distribution requirements, the primary annuitant shall be treated as an owner and any death or change of such primary annuitant shall be treated as the death of an owner. The nonqualified policies contain provisions intended to comply with these requirements of the Code. No regulations interpreting these requirements of the Code have yet been issued and thus no assurance can be given that the provisions contained in the policies satisfy all such Code requirements. The provisions contained in the policies will be reviewed and modified if necessary to assure that they comply with the Code requirements when clarified by regulation or otherwise.

The Federal Defense of Marriage Act currently does not recognize same-sex marriages or civil unions, even those that are permitted under individual state laws. Therefore, exercise of the spousal continuation provisions of this policy by persons who do not meet the definition of “spouse” under federal law—e.g., civil union partners and same-sex marriage spouses—may have adverse tax consequences. Consult a tax advisor for more information on this subject.

The following discussion is based on the assumption that the policy qualifies as an annuity policy for federal income tax purposes.

Taxation of Annuities

In General. Code Section 72 governs taxation of annuities in general. We believe that an owner who is an individual will not be taxed on increases in the value of a policy until such amounts are surrendered or distributed. For this purpose, the assignment, pledge, or agreement to assign or pledge any portion of the policy value, and in the case of a qualified policy,

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any portion of an interest in the plan, generally will be treated as a distribution. The taxable portion of a distribution is taxable as ordinary income.

Non-Natural Persons. Pursuant to Section 72(u) of the Code, a nonqualified policy held by a taxpayer other than a natural person generally will not be treated as an annuity policy under the Code; accordingly, an owner who is not a natural person will recognize as ordinary income for a taxable year the excess, if any, of the policy value over the “investment in the contract”. There are some exceptions to this rule and a prospective purchaser of the policy that is not a natural person should discuss these with a competent tax adviser.

Withholding. The portion of any distribution under a policy that is includable in gross income will be subject to federal income tax withholding unless the recipient of such distribution elects not to have federal income tax withheld. Election forms will be provided at the time distributions are requested or made. For certain qualified policies, the withholding rate varies according to the type of distribution and the owner’s tax status. For qualified policies taxable, “eligible rollover distributions” from Section 401(a) plans, Section 403(a) annuities, Section 403(b) tax-sheltered annuities, and governmental 457 plans are subject to a mandatory federal income tax withholding of 20%. An eligible rollover distribution is any distribution from such a plan, other than specified distributions such as distributions required by the Code, distributions in a specified annuity form or hardship distributions. The 20% withholding does not apply, however, to nontaxable distributions or if (i) the employee (or employee’s spouse or former spouse as beneficiary or alternate payee) chooses a “direct rollover” from the plan to a tax-qualified plan, IRA, Roth IRA or tax sheltered annuity or to a governmental 457 plan that agrees to separately account for rollover contributions; or (ii) a non-spouse beneficiary chooses a “direct rollover” from the plan to an IRA established by the direct rollover.

Incidental Death Benefits. The policy may include optional death benefit features, the value of which may exceed the value of the policy or premium payments made under the policy. Federal tax laws limit the value of such incidental death benefit in tax-qualified pension, profit-sharing and 403(b) plans. Further, the Internal Revenue Service has not reviewed this policy for qualification as an IRA, and has not addressed in a ruling of general applicability whether any death benefits available under the policy comport with qualification requirements. The actuarial present value of death benefit options and riders elected may need to be considered in calculating minimum required distributions. Consult a qualified tax adviser before purchasing an optional death benefit.

Qualified Policies. The qualified policy is designed for use with several types of tax-qualified retirement plans. The tax rules applicable to participants and beneficiaries in tax-qualified retirement plans vary according to the type of plan and the terms and conditions of the plan. Special favorable tax treatment may be available for certain types of contributions and distributions. Adverse tax consequences may result from contributions in excess of specified limits, distributions prior to age 59 ¹/2 (subject to certain exceptions), distributions that do not conform to specified commencement and minimum distribution rules, and in other specified circumstances. Some retirement plans are subject to distribution and other requirements that are not incorporated into the policies or our policy administration procedures. Owners, participants, and beneficiaries are responsible for determining that contributions, distributions, and other transactions with respect to the policies comply with applicable law.

For qualified plans under Section 401(a), 403(a), 403(b), and 457, the Code requires that distributions generally must commence no later than the later of April 1 of the calendar year following the calendar year in which the owner (or plan participant) (i) reaches age 70 ¹/2 or (ii) retires, and must be made in a specified form or manner. If a participant in a Section 401(a) plan is a “5 percent owner” (as defined in the Code), or in the case of an IRA (other than a Roth IRA), distributions generally must begin no later than April 1 of the calendar year in which the owner (or plan participant) reaches age 70 ¹/2. Each owner is responsible for requesting distributions under the policy that satisfy applicable tax rules.

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We do not attempt to provide more than general information about use of the policy with the various types of retirement plans. Purchasers of policies for use with any retirement plan should consult their legal counsel and tax adviser regarding the suitability of the policy.

Traditional Individual Retirement Annuities. In order to qualify as a traditional individual retirement annuity under Section 408(b) of the Code, a policy must satisfy certain conditions: (i) the owner must be the annuitant; (ii) the policy generally is not transferable by the owner, e.g., the owner may not designate a new owner, designate a contingent owner or assign the policy as collateral security; (iii) subject to special rules, the total premium payments for any calendar year may not exceed the amount specified in the Code ($5,000 for 2011, $6,000 if age 50 or older), except in the case of a rollover amount or contribution under Section 402(c), 402(e)(6), 403(a)(4), 403(b)(8), 403(b)(10), 408(d)(3) or 457(e)(16) of the Code; (iv) annuity payments or partial surrenders must begin no later than April 1 of the calendar year following the calendar year in which the annuitant attains age 70 ¹/2; (v) an annuity payment option with a period certain that will guarantee annuity payments beyond the life expectancy of the annuitant and the beneficiary may not be selected; (vi) certain payments of death benefits must be made in the event the annuitant dies prior to the distribution of the policy value; (vii) the entire interest of the owner is non-forfeitable; and (viii) the premiums must not be fixed. Policies intended to qualify as traditional individual retirement annuities under Section 408(b) of the Code contain such provisions. Amounts in the IRA (other than nondeductible contributions) are taxed when distributed from the IRA. Distributions prior to age 59 ¹/2 (unless certain exceptions apply) are subject to a 10% penalty tax.

Roth Individual Retirement Annuities (Roth IRA). The Roth IRA, under Section 408A of the Code, contains many of the same provisions as a traditional IRA. However, there are some differences. First, the contributions are not deductible and must be made in cash or as a rollover or transfer from another Roth IRA or other IRA. A rollover from or conversion of an IRA to a Roth IRA may be subject to tax. The Roth IRA is available to individuals with earned income and whose modified adjusted gross income is under $120,000 for single filers, $176,000 for married filing jointly, and $10,000 for married filing separately. Subject to special rules, the amount per individual that may be contributed to all IRAs (Roth and traditional) is the deductible amount specified in the Code ($5,000 for 2011, $6,000 if age 50 or older). Secondly, the distributions are taxed differently. The Roth IRA offers tax-free distributions when made 5 tax years after the first contribution to any Roth IRA of the individual and made after attaining age 59 ¹/2, to pay for qualified first time homebuyer expenses (lifetime maximum of $10,000), or due to death or disability. All other distributions are subject to income tax when made from earnings and may be subject to a penalty tax unless an exception applies. Unlike the traditional IRA, there are no minimum required distributions during the owner’s lifetime; however, required distributions at death are generally the same as for traditional IRAs.

Section 403(b) Plans. Under Section 403(b) of the Code, payments made by public school systems and certain tax exempt organizations to purchase policies for their employees are generally excludable from the gross income of the employee, subject to certain limitations. However, such payments may be subject to FICA (Social Security) taxes. The policy includes a death benefit that in some cases may exceed the greater of the premium payments or the policy value. The death benefit could be characterized as an incidental benefit, the amount of which is limited in any tax-sheltered annuity under Section 403(b). Therefore, employers using the policy in connection with such plans should consult their tax adviser. Additionally, in accordance with the requirements of the Code, Section 403(b) annuities generally may not permit distribution of (i) elective contributions made in years beginning after December 31, 1988, and (ii) earnings on those contributions, and (iii) earnings on amounts attributed to elective contributions held as of the end of the last year beginning before January 1, 1989. Distributions of such amounts will be allowed only upon the death of the employee, on or after attainment of age 59 ¹/2, severance from employment, disability, or financial hardship, except that income attributable to elective contributions may not be distributed in the case of hardship. These rules may prevent the payment of guaranteed withdrawals under a guaranteed lifetime withdrawal benefit prior to age 59 ¹/2.

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For policies issued after 2008, amounts attributable to nonelective contributions may be subject to distribution restrictions specified in the employer’s section 403(b) plan.

Pursuant to new tax regulations, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders you request from a 403(b) policy comply with applicable tax requirements before we process your request. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) policies or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Corporate Pension and Profit-Sharing Plans and H.R. 10 Plans. Sections 401(a) and 403(a) of the Code permit corporate employers to establish various types of retirement plans for employees and self-employed individuals to establish qualified plans for themselves and their employees. Such retirement plans may permit the purchase of the policies to accumulate retirement savings. Adverse tax consequences to the plan, the participant or both may result if the policy is assigned or transferred to any individual as a means to provide benefit payments.

Deferred Compensation Plans. Section 457 of the Code, while not actually providing for a qualified plan as that term is normally used, provides for certain deferred compensation plans with respect to service for state governments, local governments, political subdivisions, agencies, instrumentalities, and certain affiliates of such entities, and tax exempt organizations. The policies can be used with such plans. Under such plans a participant may specify the form of investment in which his or her participation will be made. For non-governmental Section 457 plans, all such investments, however, are owned by, and are subject to, the claims of the general creditors of the sponsoring employer. Depending on the terms of the particular plan, a non-government employer may be entitled to draw on deferred amounts for purposes unrelated to its Section 457 plan obligations. In general, all amounts received under a nongovernmental Section 457 plan are taxable and are subject to federal income tax withholding as wages.

Taxation of the Company

The Company at present is taxed as a life insurance company under part I of Subchapter L of the Code. The separate account is treated as part of the Company and, accordingly, will not be taxed separately as a “regulated investment company” under Subchapter M of the Code. We do not expect to incur any federal income tax liability with respect to investment income and net capital gains arising from the activities of the separate account retained as part of the reserves under the policy. Based on this expectation, it is anticipated that no charges will be made against the separate account for federal income taxes. If, in future years, any federal income taxes are incurred by us with respect to the separate account, we may make a charge to that account.

INVESTMENT EXPERIENCE

A “net investment factor” is used to determine the value of accumulation units and annuity units, and to determine annuity payment rates.

Accumulation Units

Allocations of a premium payment directed to a subaccount are credited in the form of accumulation units. Each subaccount has a distinct accumulation unit value. The number of units credited is determined by dividing the premium

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payment or amount transferred to the subaccount by the accumulation unit value of the subaccount as of the end of the valuation period during which the allocation is made. For each subaccount, the accumulation unit value for a given business day is based on the net asset value of a share of the corresponding portfolio of the underlying fund portfolios less any applicable charges or fees. The investment performance of the portfolio, expenses, and deductions of certain charges affect the value of an accumulation unit.

Upon allocation to the selected subaccount, premium payments are converted into accumulation units of the subaccount. The number of accumulation units to be credited is determined by dividing the dollar amount allocated to each subaccount by the value of an accumulation unit for that subaccount as next determined after the premium payment is received at the administrative and service office or, in the case of the initial premium payment, when the enrollment form is completed, whichever is later. The value of an accumulation unit for each subaccount was arbitrarily established at $1 at the inception of each subaccount. Thereafter, the value of an accumulation unit is determined as of the close of trading on each day the New York Stock Exchange is open for regular trading.

An index (the “net investment factor”) which measures the investment performance of a subaccount during a valuation period, is used to determine the value of an accumulation unit for the next subsequent valuation period. The net investment factor may be greater or less than or equal to one; therefore, the value of an accumulation unit may increase, decrease, or remain the same from one valuation period to the next. You bear this investment risk. The net investment performance of a subaccount and deduction of certain charges affect the accumulation unit value.

The net investment factor for any subaccount for any valuation period is determined by dividing (a) by (b) and subtracting (c) from the result, where:

(a) is the net result of:

(1) the net asset value per share of the shares held in the subaccount determined at the end of the current valuation period, plus

(2) the per share amount of any dividend or capital gain distribution made with respect to the shares held in the subaccount if the ex-dividend date occurs during the current valuation period, plus or minus

(3) a per share credit or charge for any taxes determined by the Company to have resulted during the valuation period from the investment operations of the subaccount;

(b) is the net asset value per share of the shares held in the subaccount determined as of the end of the immediately preceding valuation period; and

(c) is an amount representing the separate account charge and any optional benefit fees, if applicable.

Illustration of Separate Account Accumulation Unit Value Calculations

Formula and Illustration for Determining the Net Investment Factor

Net Investment Factor =	(A + B - C)	- E
	D

Where:
A =	The net asset value of an underlying fund portfolio share as of the end of the current valuation period.
	Assume	A = $11.57

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B =	The per share amount of any dividend or capital gains distribution since the end of the immediately preceding valuation period.
	Assume	B = 0
C =	The per share charge or credit for any taxes reserved for at the end of the current valuation period.
	Assume	C = 0
D =	The net asset value of an underlying fund portfolio share at the end of the immediately preceding valuation period.
	Assume	D = $11.40
E =	The daily deduction for the mortality and expense risk fee and the administrative charge, and any optional benefit fees, if applicable. Assume E totals 2.30% on an annual basis; On a daily basis, this equals 0.000062302.

Then, the net investment factor =	(11.57 + 0 – 0)	- 0.000062302 = Z = 1.014849979
	(11.40)

Formula and Illustration for Determining Accumulation Unit Value

Accumulation Unit Value = A * B

Where:

A =	The accumulation unit value for the immediately preceding valuation period.
	Assume = $X
B =	The net investment factor for the current valuation period.
	Assume = Y

Then, the accumulation unit value = $X * Y = $Z

Annuity Unit Value and Annuity Payment Rates

The amount of variable annuity payments will vary with annuity unit values. Annuity unit values rise if the net investment performance of the subaccount exceeds the assumed investment return of 5% annually. Conversely, annuity unit values fall if the net investment performance of the subaccount is less than the annual assumed investment return. The value of a variable annuity unit in each subaccount was established at $1 on the date operations began for that subaccount. The value of a variable annuity unit on any subsequent business day is equal to (a) multiplied by (b) multiplied by (c), where:

(a) is the variable annuity unit value for the subaccount on the immediately preceding business day;

(b) is the net investment factor for that subaccount for the valuation period; and

(c) is the assumed investment return adjustment factor for the valuation period.

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The assumed investment return adjustment factor for the valuation period is the product of discount factors of .99986634 per day to recognize the 5% effective annual assumed investment return. The valuation period is the period from the close of the immediately preceding business day to the close of the current business day.

The net investment factor for the policy used to calculate the value of a variable annuity unit in each subaccount for the valuation period is determined by dividing (i) by (ii) and subtracting (iii) from the result, where:

(i) is the result of:

(1) the net asset value of a fund share held in that subaccount determined at the end of the current valuation period; plus

(2) the per share amount of any dividend or capital gain distributions made by the fund for shares held in that subaccount if the ex-dividend date occurs during the valuation period; plus or minus

(3) a per share charge or credit for any taxes reserved for, which the Company determines to have resulted from the investment operations of the subaccount.

(ii) is the net asset value of a fund share held in that subaccount determined as of the end of the immediately preceding valuation period.

(iii) is a factor representing the mortality and expense risk fee and administrative charge. This factor is equal, on an annual basis, to 1.25% of the daily net asset value of shares held in that subaccount (For calculating Initial Payment Guarantee annuity payments, the factor is higher at a rate of 2.50%).

The dollar amount of subsequent variable annuity payments will depend upon changes in applicable annuity unit values.

The annuity payment rates generally vary according to the annuity option elected and the gender and adjusted age of the annuitant at the annuity commencement date. The policy contains a table for determining the adjusted age of the annuitant.

Illustration of Calculations for Annuity Unit

Value and Variable Annuity Payments

Formula and Illustration for Determining Annuity Unit Value

Annuity Unit Value = A * B * C

Where:
A =	annuity unit value for the immediately preceding valuation period.
	Assume = $X
B =	Net investment factor for the valuation period for which the annuity unit value is being calculated.
	Assume = Y
C =	A factor to neutralize the annual assumed investment return of 5% built into the Annuity Tables used.
	Assume = Z

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Then, the annuity unit value is:

$X * Y * Z = $Q

Formula and Illustration for Determining Amount of

First Monthly Variable Annuity Payment

First monthly variable annuity payment =	A * B
	$1,000

Where:
A =	The adjusted policy value as of the annuity commencement date.
	Assume = $X
B =	The annuity purchase rate per $1,000 of adjusted policy value based upon the option selected, the sex and adjusted age of the annuitant according to the tables contained in the policy.
	Assume = $Y

Then, the first monthly variable annuity payment =	$X * $Y	= $Z
	1,000

Formula and Illustration for Determining the Number of Annuity Units

Represented by Each Monthly Variable Annuity Payment

Number of annuity units =	A
	B

Where:
A =	The dollar amount of the first monthly variable annuity payment.
	Assume = $X
B =	The annuity unit value for the valuation date on which the first monthly payment is due.
	Assume = $Y

Then, the number of annuity units =	$X	= Z
	$Y

HISTORICAL PERFORMANCE DATA

Money Market Yields

The Company may from time to time disclose the current annualized yield of the money market subaccount, which invests in the corresponding money market portfolio, for a 7-day period in a manner which does not take into

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consideration any realized or unrealized gains or losses on shares of the corresponding money market portfolio or on its portfolio securities. This current annualized yield is computed by determining the net change (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) at the end of the 7-day period in the value of a hypothetical account having a balance of 1 unit of the money market subaccount at the beginning of the 7-day period, dividing such net change in account value by the value of the account at the beginning of the period to determine the base period return, and annualizing this quotient on a 365-day basis. The net change in account value reflects (i) net income from the portfolio attributable to the hypothetical account; and (ii) charges and deductions imposed under a policy that are attributable to the hypothetical account. The charges and deductions include the per unit charges for the hypothetical account for (i) the administrative charges and (ii) the mortality and expense risk fee. Current yield will be calculated according to the following formula:

Current Yield = ((NCS * ES)/UV) * (365/7)

Where:
NCS	=	The net change in the value of the portfolio (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) for the 7-day period attributable to a hypothetical account having a balance of 1 subaccount unit.
ES	=	Per unit expenses of the subaccount for the 7-day period.
UV	=	The unit value on the first day of the 7-day period.

Because of the charges and deductions imposed under a policy, the yield for the money market subaccount will be lower than the yield for the corresponding money market portfolio. The yield calculations do not reflect the effect of any premium taxes. The yield calculations also do not reflect surrender charges that may be applicable to a particular policy. Surrender charges range from 9% to 0% of the amount of premium payments surrendered based on the number of years since the premium payment was made. Surrender charges are based on the number of years since the date the premium payment was made, not the policy issue date.

The Company may also disclose the effective yield of the money market subaccount for the same 7-day period, determined on a compounded basis. The effective yield is calculated by compounding the base period return according to the following formula:

Effective Yield = (1 + ((NCS - ES)/UV))^365/7 - 1

Where:
NCS	=	The net change in the value of the portfolio (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) for the 7-day period attributable to a hypothetical account having a balance of 1 subaccount unit.
ES	=	Per unit expenses of the subaccount for the 7-day period.
UV	=	The unit value on the first day of the 7-day period.

The yield on amounts held in the money market subaccount normally will fluctuate on a daily basis. Therefore, the disclosed yield for any given past period is not an indication or representation of future yields or rates of return. The money market subaccount’s actual yield is affected by changes in interest rates on money market securities, average portfolio maturity of the corresponding money market portfolio, the types and quality of portfolio securities held by the corresponding money market portfolio and its operating expenses.

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Total Returns

The Company may from time to time also advertise or disclose total returns for one or more of the subaccounts for various periods of time. One of the periods of time will include the period measured from the date the subaccount commenced operations. When a subaccount has been in operation for 1, 5 and 10 years, respectively, the total return for these periods will be provided. Total returns for other periods of time may from time to time also be disclosed. Total returns represent the average annual compounded rates of return that would equate an initial investment of $1,000 to the redemption value of that investment as of the last day of each of the periods. The ending date for each period for which total return quotations are provided will be for the most recent month end practicable, considering the type and media of the communication and will be stated in the communication.

Total returns will be calculated using subaccount unit values which the Company calculates on each business day based on the performance of the separate account’s underlying fund portfolio and the deductions for the mortality and expense risk fee and the administrative charges. Total return calculations will reflect the effect of surrender charges that may be applicable to a particular period. The total return will then be calculated according to the following formula:

P (1 + T)^N = ERV

Where:
T	=	The average annual total return net of subaccount recurring charges.
ERV	=	The ending redeemable value of the hypothetical account at the end of the period.
P	=	A hypothetical initial payment of $1,000.
N	=	The number of years in the period.

Other Performance Data

The Company may from time to time also disclose average annual total returns in a non-standard format in conjunction with the standard format described above. The non-standard format will be identical to the standard format except that the surrender charge percentage will be assumed to be 0%.

The Company may from time to time also disclose cumulative total returns in conjunction with the standard format described above. The cumulative returns will be calculated using the following formula except that the surrender charge percentage will be assumed to be 0%:

CTR = (ERV / P)-1

Where:
CTR	=	The cumulative total return net of subaccount recurring charges for the period.
ERV	=	The ending redeemable value of the hypothetical investment at the end of the period.
P	=	A hypothetical initial payment of $1,000.

All non-standard performance data will only be advertised if the standard performance data is also disclosed.

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Adjusted Historical Performance Data

From time to time, sales literature or advertisements may quote average annual total returns for periods prior to the date a particular subaccount commenced operations. Such performance information for the subaccounts will be calculated based on the performance of the various portfolios and the assumption that the subaccounts were in existence for the same periods as those indicated for the portfolios, with the level of policy charges that are currently in effect.

PUBLISHED RATINGS

The Company may from time to time publish in advertisements, sales literature and reports to owners, the ratings and other information assigned to it by one or more independent rating organizations such as A.M. Best Company, Standard & Poor’s Insurance Ratings Services, Moody’s Investors Service and Fitch Financial Ratings. The purpose of the ratings is to reflect the financial strength of the Company. The ratings should not be considered as bearing on the investment performance of assets held in the separate account or of the safety or riskiness of an investment in the separate account. Each year the A.M. Best Company reviews the financial status of thousands of insurers, culminating in the assignment of Best’s Ratings. These ratings reflect their current opinion of the relative financial strength and operating performance of an insurance company in comparison to the norms of the life/health insurance industry. In addition, these ratings may be referred to in advertisements or sales literature or in reports to owners. These ratings are opinions of an operating insurance company’s financial capacity to meet the obligations of its insurance policies in accordance with their terms.

STATE REGULATION OF TRANSAMERICA LIFE INSURANCE COMPANY

The Company is subject to the laws of Iowa governing insurance companies and to regulation by the Iowa Department of Insurance. An annual statement in a prescribed form is filed with the Department of Insurance each year covering the operation of the Company for the preceding year and its financial condition as of the end of such year. Regulation by the Department of Insurance includes periodic examination to determine the Company’s contract liabilities and reserves so that the Department may determine the items are correct. The Company’s books and accounts are subject to review by the Department of Insurance at all times, and a full examination of its operations is conducted periodically by the National Association of Insurance Commissioners. In addition, the Company is subject to regulation under the insurance laws of other jurisdictions in which it may operate.

ADMINISTRATION

The Company performs administrative services for the policies. These services include issuance of the policies, maintenance of records concerning the policies, and certain valuation services.

RECORDS AND REPORTS

All records and accounts relating to the separate account will be maintained by the Company. As presently required by the 1940 Act, as amended, and regulations promulgated thereunder, the Company will mail to all owners at their last known address of record, at least annually, reports containing such information as may be required under that Act or by any other applicable law or regulation. Owners will also receive confirmation of each financial transaction and any other

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reports required by law or regulation. However, for certain routine transactions (for example, regular monthly premiums deducted from your checking account, or regular annuity payments the Company sends to you) you may only receive quarterly confirmations.

DISTRIBUTION OF THE POLICIES

We have entered into a principal underwriting agreement with our affiliate, Transamerica Capital, Inc. (“TCI”), for the distribution and sale of the policies. We may reimburse TCI for certain expenses it incurs in order to pay for the distribution of the policies (e.g., commissions payable to selling firms selling the Policies, as described below.)

TCI’s home office is located at 4600 S Syracuse St. Suite 1100 Denver, Colorado 80237-2719. TCI is an indirect, wholly owned subsidiary of AEGON USA. TCI is registered as a broker-dealer with the Securities and Exchange Commission under the Securities Exchange Act of 1934, and is a member of Financial Industry Regulatory Authority (“FINRA”). TCI is not a member of the Securities Investor Protection Corporation.

We currently offer the policies on a continuous basis. We anticipate continuing to offer the policies, but reserve the right to discontinue the offering. The policies are offered to the public through sales representatives of broker-dealers (“selling firms”) that have entered into selling agreements with us and with TCI. TCI compensates these selling firms for their services. Sales representatives with these selling firms are appointed as our insurance agents.

We and our affiliates provide paid-in capital to TCI and pay for TCI’s operating and other expenses, including overhead, legal and accounting fees. We also pay TCI an “override” payment based on the pricing of the product which becomes part of TCI’s assets. In addition, we pay commission to TCI for policy sales; these commissions are passed through to the selling firms with TCI not retaining any portion of the commissions. During fiscal year 2010, 2009 and 2008 the amounts paid to TCI in connection with all policies sold through the separate account were $15,370,032, $10,346,777, and $11,193,398, respectively.

We and/or TCI or another affiliate may pay certain selling firms additional cash amounts for: (1) “preferred product” treatment of the policies in their marketing programs, which may include marketing services and increased access to their sales representatives; (2) sales promotions relating to the policies; (3) costs associated with sales conferences and educational seminars for their sales representatives; and (4) other sales expenses of the selling firms. We and/or TCI may make bonus payments to certain selling firms based on aggregate sales or persistency standards. These additional payments are not offered to all selling firms, and the terms of any particular agreement governing the payments may vary among selling firms.

VOTING RIGHTS

To the extent required by law, the Company will vote the underlying fund portfolios’ shares held by the separate account at regular and special shareholder meetings of the underlying fund portfolios in accordance with instructions received from persons having voting interests in the portfolios, although none of the underlying fund portfolios hold regular annual shareholder meetings. If, however, the 1940 Act or any regulation thereunder should be amended or if the present interpretation thereof should change, and as a result the Company determines that it is permitted to vote the underlying fund portfolios shares in its own right, it may elect to do so.

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Before the annuity commencement date, you hold the voting interest in the selected portfolios. The number of votes that you have the right to instruct will be calculated separately for each subaccount. The number of votes that you have the right to instruct for a particular subaccount will be determined by dividing your policy value in the subaccount by the net asset value per share of the corresponding portfolio in which the subaccount invests. Fractional shares will be counted.

After the annuity commencement date, the person receiving annuity payments has the voting interest, and the number of votes decreases as annuity payments are made and as the reserves for the policy decrease. The person’s number of votes will be determined by dividing the reserve for the policy allocated to the applicable subaccount by the net asset value per share of the corresponding portfolio. Fractional shares will be counted.

The number of votes that you or the person receiving income payments has the right to instruct will be determined as of the date established by the underlying fund portfolio for determining shareholders eligible to vote at the meeting of the underlying fund portfolio. The Company will solicit voting instructions by sending you, or other persons entitled to vote, requests for instructions prior to that meeting in accordance with procedures established by the underlying fund portfolio. Portfolio shares as to which no timely instructions are received, and shares held by the Company in which you, or other persons entitled to vote have no beneficial interest, will be voted in proportion to the voting instructions that are received with respect to all policies participating in the same subaccount.

Each person having a voting interest in a subaccount will receive proxy material, reports, and other materials relating to the appropriate portfolio.

OTHER PRODUCTS

The Company makes other variable annuity policies available that may also be funded through the separate account. These variable annuity policies may have different features, such as different investment choices or charges.

CUSTODY OF ASSETS

The Company holds assets of each of the subaccounts. The assets of each of the subaccounts are segregated and held separate and apart from the assets of the other subaccounts and from the Company’s general account assets. The Company maintains records of all purchases and redemptions of shares of the underlying fund portfolios held by each of the subaccounts. Additional protection for the assets of the separate account is afforded by the Company’s fidelity bond, presently in the amount of $5,000,000, covering the acts of officers and employees of the Company.

LEGAL MATTERS

Sutherland Asbill & Brennan LLP, of Washington D.C. has provided legal advice to the Company regarding to certain matters under the federal securities laws that relate to the policies.

24

INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

The financial statements of the Separate Account VA C, at December 31, 2010 and for the periods disclosed in the financial statements, and the statutory-basis financial statements and schedules of Transamerica Life Insurance Company at December 31, 2010 and 2009 and for each of the three years in the period ended December 31, 2010, appearing herein, have been audited by Ernst & Young LLP, Suite 3000, 801 Grand Avenue, Des Moines, Iowa 50309, Independent Registered Public Accounting Firm, as set forth in their respective reports thereon appearing elsewhere herein, and are included in reliance upon their reports given on their authority as experts in accounting and auditing.

OTHER INFORMATION

A registration statement has been filed with the SEC, under the Securities Act of 1933 as amended, with respect to the policies discussed in this SAI. Not all of the information set forth in the registration statement and the amendments and exhibits thereto has been included in the prospectus or this SAI. Statements contained in the prospectus and this SAI concerning the content of the policies and other legal instruments are intended to be summaries. For a complete statement of the terms of these documents, reference should be made to the instruments filed with the SEC.

FINANCIAL STATEMENTS

The values of your interest in the separate account will be affected solely by the investment results of the selected subaccount(s). Financial statements of certain subaccounts of Separate Account VA C, which are available for investment by Transamerica Extra^SM Variable Annuity policy owners, are contained herein. The statutory-basis financial statements and schedules of Transamerica Life Insurance Company, which are included in this SAI, should be considered only as bearing on the ability of the Company to meet its obligations under the policies. They should not be considered as bearing on the investment performance of the assets held in the separate account.

25

APPENDIX

CONDENSED FINANCIAL INFORMATION

The accumulation unit values and the number of accumulation units outstanding for each subaccount from the date of inception are shown in the following tables.

			2.30%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation - Conservative VP – Service Class		2010	$	0.966309	$	1.026829		1,894,026.276
Subaccount Inception Date May 1, 2002		2009	$	0.791431	$	0.966309		1,265,314.746
		2008	$	1.000000	$	0.791431		563,870.227
Transamerica Asset Allocation - Moderate VP – Service Class		2010	$	0.940237	$	1.012278		2,164,608.656
Subaccount Inception Date May 1, 2002		2009	$	0.762186	$	0.940237		2,160,857.065
		2008	$	1.000000	$	0.762186		947,916.482
Transamerica Asset Allocation - Moderate Growth VP – Service Class		2010	$	0.892151	$	0.980279		2,049,109.618
Subaccount Inception Date May 1, 2002		2009	$	0.713754	$	0.892151		2,362,317.497
		2008	$	1.000000	$	0.713754		1,546,176.982
Transamerica Foxhall Global Conservative VP – Service Class		2010	$	0.982701	$	0.902049		0.000
Subaccount Inception Date November 19, 2009		2009	$	0.995050	$	0.982701		0.000
Transamerica International Moderate Growth VP – Service Class		2010	$	0.862757	$	0.929740		1,023,139.890
Subaccount Inception Date May 1, 2006		2009	$	0.682446	$	0.862757		800,529.083
		2008	$	1.000000	$	0.682446		421,387.192
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.035311	$	1.082220		1,808,308.185
Subaccount Inception Date May 1, 2002		2009	$	0.914994	$	1.035311		471,475.370
		2008	$	1.000000	$	0.914994		72,995.997
Transamerica Efficient Markets VP – Service Class		2010	$	1.193244	$	1.310801		19,458.844
Subaccount Inception Date November 10, 2008		2009	$	1.035705	$	1.193244		12,080.282
		2008	$	1.000000	$	1.035705		0.000
Transamerica Multi-Managed Balanced VP – Service Class(1)		2010	$	0.899500	$	1.089299		78,690.849
Subaccount Inception Date May 1, 2002		2009	$	0.730662	$	0.899500		21,305.971
		2008	$	1.000000	$	0.730662		16,101.843
Transamerica AEGON Money Market VP – Service Class(2)		2010	$	0.975272	$	0.953394		11,889.609
Subaccount Inception Date December 13, 1999		2009	$	0.997589	$	0.975272		996,690.791
		2008	$	1.000000	$	0.997589		1,357,986.981
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.046062	$	1.065731		112,033.779
Subaccount Inception Date December 13, 1999		2009	$	1.027019	$	1.046062		207,171.653
		2008	$	1.000000	$	1.027019		395,944.485
Transamerica Index 35 VP – Service Class		2010	$	0.997328	$	1.066785		5,707.464
Subaccount Inception Date November 19, 2009		2009	$	0.999938	$	0.997328		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.926675	$	1.002699		677,849.205
Subaccount Inception Date May 1, 2008		2009	$	0.813516	$	0.926675		682,438.411
		2008	$	1.000000	$	0.813516		0.000
Transamerica Index 75 VP – Service Class		2010	$	0.864525	$	0.954989		522,204.389
Subaccount Inception Date May 1, 2008		2009	$	0.717974	$	0.864525		475,568.355
		2008	$	1.000000	$	0.717974		0.000
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.228584	$	1.322043		275,391.472
Subaccount Inception Date November 10, 2008		2009	$	1.011883	$	1.228584		27,825.950
		2008	$	1.000000	$	1.011883		0.000
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class(4)
Subaccount Inception Date August 16, 2010		2010	$	1.000000	$	1.046195		0.000

26

CONDENSED FINANCIAL INFORMATION — (Continued)

			2.30%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
American Funds - Asset Allocation Fund – Class 2		2010	$	1.007237	$	1.104500		5,496.902
Subaccount Inception Date November 19, 2009		2009	$	0.989760	$	1.007237		0.000
American Funds - Bond Fund– Class 2		2010	$	0.992961	$	1.030171		0.000
Subaccount Inception Date November 19, 2009		2009	$	1.000881	$	0.992961		0.000
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.895254	$	1.030532		148,852.626
Subaccount Inception Date May 1, 2008		2009	$	0.662108	$	0.895254		478,687.414
		2008	$	1.000000	$	0.662108		0.000
Franklin Templeton VIP Founding Funds Allocation Fund– Class 4		2010	$	1.255873	$	1.351386		232,607.216
Subaccount Inception Date November 10, 2008		2009	$	0.989224	$	1.255873		198,272.238
		2008	$	1.000000	$	0.989224		0.000
GE Investments Total Return Fund – Class 3		2010	$	1.002880	$	1.070072		936.608
Subaccount Inception Date November 19, 2009		2009	$	0.988792	$	1.002880		0.000
			2.00%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation - Conservative VP – Initial Class		2010	$	1.267753	$	1.353913		42,802,258.305
Subaccount Inception Date May 1, 2002		2009	$	1.032618	$	1.267753		42,122,243.723
		2008	$	1.336403	$	1.032618		41,246,895.844
		2007	$	1.281467	$	1.336403		39,965,933.587
		2006	$	1.194232	$	1.281467		42,875,986.019
		2005	$	1.158033	$	1.194232		44,259,081.970
		2004	$	1.076670	$	1.158033		49,373,161.000
		2003	$	0.893465	$	1.076670		51,005,062.684
		2002	$	1.000000	$	0.893465		15,001,049.822
Transamerica Asset Allocation - Growth VP – Initial Class		2010	$	1.142864	$	1.287988		36,880,996.696
Subaccount Inception Date May 1, 2002		2009	$	0.897961	$	1.142864		42,326,492.947
		2008	$	1.517437	$	0.897961		43,118,645.631
		2007	$	1.436552	$	1.517437		52,563,524.166
		2006	$	1.267279	$	1.436552		55,069,051.672
		2005	$	1.151594	$	1.267279		55,127,551.475
		2004	$	1.028744	$	1.151594		54,862,442
		2003	$	0.802225	$	1.028744		52,829,401.384
		2002	$	1.000000	$	0.802225		25,821,891.723
Transamerica Asset Allocation - Moderate VP – Initial Class		2010	$	1.267493	$	1.371591		76,853,028.219
Subaccount Inception Date May 1, 2002		2009	$	1.022795	$	1.267493		83,476,070.163
		2008	$	1.409229	$	1.022795		87,222,425.488
		2007	$	1.331621	$	1.409229		103,282,514.576
		2006	$	1.218329	$	1.331621		125,234,199.666
		2005	$	1.156532	$	1.218329		136,508,780.685
		2004	$	1.059046	$	1.156532		140,924,320.000
		2003	$	0.865078	$	1.059046		137,258,725.513
		2002	$	1.000000	$	0.865078		55,257,149.201
Transamerica Asset Allocation - Moderate Growth VP – Initial Class		2010	$	1.222219	$	1.350781		80,845,080.473
Subaccount Inception Date May 1, 2002		2009	$	0.972754	$	1.222219		87,969,978.456
		2008	$	1.475825	$	0.972754		95,864,207.689
		2007	$	1.396424	$	1.475825		111,858,272.445
		2006	$	1.251178	$	1.396424		130,250,454.833
		2005	$	1.161058	$	1.251178		135,686,078.891
		2004	$	1.043050	$	1.161058		126,821,477.000
		2003	$	0.836600	$	1.043050		114,000,099.431
		2002	$	1.000000	$	0.836600		48,141,122.322

27

CONDENSED FINANCIAL INFORMATION — (Continued)

			2.00%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica International Moderate Growth VP – Service Class		2010	$	0.864938	$	0.934834		1,206,271.363
Subaccount Inception Date May 1, 2006		2009	$	0.682168	$	0.864938		1,780,069.932
		2008	$	1.092699	$	0.682168		746,982.136
		2007	$	1.027415	$	1.092699		968,842.082
		2006	$	1.000000	$	1.027415		92,434.581
Transamerica BlackRock Large Cap Value VP – Initial Class		2010	$	1.151826	$	1.247199		25,235,067.380
Subaccount Inception Date December 13, 1999		2009	$	1.030669	$	1.151826		14,945,427.326
		2008	$	1.590307	$	1.030669		7,698,354.135
		2007	$	1.550381	$	1.590307		8,441,132.751
		2006	$	1.352450	$	1.550381		11,138,766.674
		2005	$	1.189762	$	1.352450		10,599,204.048
		2004	$	1.025528	$	1.189762		5,395,338.000
		2003	$	0.805984	$	1.025528		4,901,467.669
		2002	$	1.000000	$	0.805984		3,094,674.034
Transamerica BlackRock Tactical Allocation VP - Service Class		2010	$	1.002607	$	1.093467		2,187,750.069
Subaccount Inception Date May 1, 2009		2009	$	0.993351	$	1.002607		117,838.906
Transamerica Index 35 VP – Service Class		2010	$	0.997673	$	1.070290		16,109.634
Subaccount Inception Date November 19, 2009		2009	$	0.999946	$	0.997673		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.995597	$	1.080446		112,918.016
Subaccount Inception Date May 1, 2008		2009	$	0.991630	$	0.995597		0.000
Transamerica Index 75 VP – Service Class		2010	$	0.998789	$	1.106552		22,960.121
Subaccount Inception Date May 1, 2008		2009	$	0.988760	$	0.998789		0.000
Transamerica Index 100 VP – Service Class		2010	$	1.023612	$	1.148129		374,763.991
Subaccount Inception Date November 19, 2009		2009	$	0.999946	$	1.023612		30,070.066
Transamerica Clarion Global Real Estate Securities VP – Initial Class		2010	$	1.683972	$	1.909650		3,026,477.088
Subaccount Inception Date May 1, 2002		2009	$	1.287443	$	1.683972		3,567,407.519
		2008	$	2.279268	$	1.287443		4,036,803.954
		2007	$	2.492229	$	2.279268		6,022,209.437
		2006	$	1.786636	$	2.492229		9,534,617.264
		2005	$	1.605890	$	1.786636		8,853,687.302
		2004	$	1.232930	$	1.605890		9,919,133.000
		2003	$	0.926467	$	1.232930		9,506,629.355
		2002	$	1.000000	$	0.926467		4,309,584.948
Transamerica JPMorgan Enhanced Index VP – Initial Class		2010	$	1.008170	$	1.138419		3,685,957.419
Subaccount Inception Date December 13, 1999		2009	$	0.793528	$	1.008170		4,409,093.836
		2008	$	1.292065	$	0.793528		4,264,010.830
		2007	$	1.260831	$	1.292065		6,599,306.065
		2006	$	1.115230	$	1.260831		7,005,368.142
		2005	$	1.099439	$	1.115230		8,309,308.157
		2004	$	1.010172	$	1.099439		12,381,356.000
		2003	$	0.799075	$	1.010172		13,492,013.110
		2002	$	1.000000	$	0.799075		8,842,715.398
Transamerica JPMorgan Mid Cap Value VP – Service Class		2010	$	1.029054	$	1.239127		536,991.304
Subaccount Inception Date November 19, 2009		2009	$	0.985145	$	1.029054		0.000

28

CONDENSED FINANCIAL INFORMATION — (Continued)

			2.00%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Jennison Growth VP – Initial Class		2010	$	1.054255	$	1.160332		9,351,683.719
Subaccount Inception Date December 13, 1999		2009	$	0.762631	$	1.054255		1,618,064.985
		2008	$	1.234997	$	0.762631		1,239,369.511
		2007	$	1.129751	$	1.234997		1,431,599.323
		2006	$	1.130104	$	1.129751		2,281,834.114
		2005	$	1.012972	$	1.130104		2,111,495.380
		2004	$	0.946858	$	1.012972		2,054,469.000
		2003	$	0.749982	$	0.946858		2,086,119.486
		2002	$	1.000000	$	0.749982		1,442,335.054
Transamerica Morgan Stanley Capital Growth VP - Initial Class(5)		2010	$	0.996991	$	1.245646		6,505,097.719
Subaccount Inception Date December 13, 1999		2009	$	0.795043	$	0.996991		6,152,971.213
		2008	$	1.274487	$	0.795043		6,944,241.408
		2007	$	1.286783	$	1.274487		9,035,192.362
		2006	$	1.107017	$	1.286783		11,190,439.472
		2005	$	1.084859	$	1.107017		12,494,852.259
		2004	$	1.013938	$	1.084859		15,336,048.000
		2003	$	0.765208	$	1.013938		15,362,345.634
		2002	$	1.000000	$	0.765208		8,736,030.070
Transamerica AEGON High Yield Bond VP – Initial Class		2010	$	1.404372	$	1.548092		8,269,958.140
Subaccount Inception Date December 13, 1999		2009	$	0.972883	$	1.404372		9,070,768.587
		2008	$	1.326743	$	0.972883		6,298,927.717
		2007	$	1.328792	$	1.326743		7,158,597.787
		2006	$	1.221573	$	1.328792		9,089,206.683
		2005	$	1.223742	$	1.221573		11,521,075.289
		2004	$	1.137199	$	1.223742		15,032,808.000
		2003	$	0.985166	$	1.137199		19,732,201.775
		2002	$	1.000000	$	0.985166		5,318,864.948
Transamerica MFS International Equity VP – Initial Class		2010	$	1.279288	$	1.385867		5,109,446.859
Subaccount Inception Date May 1, 2001		2009	$	0.983450	$	1.279288		6,305,960.284
		2008	$	1.550329	$	0.983450		7,122,405.163
		2007	$	1.448883	$	1.550329		9,045,458.217
		2006	$	1.200780	$	1.448883		11,197,438.452
		2005	$	1.085122	$	1.200780		9,385,525.958
		2004	$	0.968035	$	1.085122		8,975,420.000
		2003	$	0.788069	$	0.968035		10,118,465.659
		2002	$	1.000000	$	0.788069		3,443,863.649
Transamerica PIMCO Total Return VP – Initial Class		2010	$	1.310542	$	1.377279		29,873,299.102
Subaccount Inception Date May 1, 2002		2009	$	1.152014	$	1.310542		31,691,408.766
		2008	$	1.208880	$	1.152014		28,240,862.207
		2007	$	1.131892	$	1.208880		28,404,833.976
		2006	$	1.107823	$	1.131892		30,471,499.939
		2005	$	1.104194	$	1.107823		35,862,277.083
		2004	$	1.077880	$	1.104194		36,459,144.000
		2003	$	1.048045	$	1.077880		41,722,526.816
		2002	$	1.000000	$	1.048045		27,954,732.8555
Transamerica T. Rowe Price Small Cap VP – Initial Class		2010	$	1.109246	$	1.461897		6,418,796.250
Subaccount Inception Date December 13, 1999		2009	$	0.815720	$	1.109246		6,501,868.994
		2008	$	1.305309	$	0.815720		7,277,110.048
		2007	$	1.214819	$	1.305309		9,530,940.972
		2006	$	1.196154	$	1.214819		12,959,866.269
		2005	$	1.102984	$	1.196154		16,257,718.879
		2004	$	1.019424	$	1.102984		19,302,937.000
		2003	$	0.740575	$	1.019424		19,295,647.860
		2002	$	1.000000	$	0.740575		8,803,128.697

29

CONDENSED FINANCIAL INFORMATION — (Continued)

			2.00%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica WMC Diversified Equity VP - Initial Class(6)		2010	$	1.055503	$	1.209151		8,595,330.383
Subaccount Inception Date December 13, 1999		2009	$	0.838998	$	1.055503		7,257,946.287
		2008	$	1.519460	$	0.838998		1,188,485.734
		2007	$	1.344953	$	1.519460		1,632,782.997
		2006	$	1.154789	$	1.344953		1,590,170.560
		2005	$	1.095964	$	1.154789		2,247,960.330
		2004	$	1.021323	$	1.095964		1,784,880.000
		2003	$	0.822022	$	1.021323		1,237,356.358
		2002	$	1.000000	$	0.822022		589,500.165
Transamerica Multi-Managed Balanced VP – Initial Class(1)		2010	$	1.179324	$	1.435086		2,714,402.002
2006		2009	$	0.952440	$	1.179324		2,628,368.029
Subaccount Inception Date May 1, 2002		2008	$	1.437253	$	0.952440		2,962,706.417
		2007	$	1.290568	$	1.437253		4,096,465.552
		2006	$	1.206239	$	1.290568		4,481,779.733
		2005	$	1.139559	$	1.206239		4,941,515.690
		2004	$	1.045751	$	1.139559		6,040,258.000
		2003	$	0.936513	$	1.045751		6,661,944.121
		2002	$	1.000000	$	0.936513		2,611,109.654
Transamerica AllianceBernstein Dynamic Allocation VP – Initial Class(4)		2010	$	1.269318	$	1.360047		3,216,648.000
Subaccount Inception Date May 1, 2002		2009	$	0.986078	$	1.269318		3,894,668.592
		2008	$	1.593422	$	0.986078		4,253,577.563
		2007	$	1.370131	$	1.593422		4,666,308.254
		2006	$	1.260127	$	1.370131		5,357,761.160
		2005	$	1.237223	$	1.260127		4,663,873.088
		2004	$	1.115076	$	1.237223		5,228,366.000
		2003	$	0.919740	$	1.115076		4,814,292.506
		2002	$	1.000000	$	0.919740		1,822,284.220
Transamerica WMC Diversified Growth VP – Initial Class		2010	$	1.140619	$	1.317444		8,089,355.596
Subaccount Inception Date December 13, 1999		2009	$	0.900527	$	1.140619		9,482,300.480
		2008	$	1.701346	$	0.900527		11,770,743.227
		2007	$	1.492497	$	1.701346		14,085,846.944
		2006	$	1.400247	$	1.492497		18,474,637.009
		2005	$	1.225508	$	1.400247		18,087,856.128
		2004	$	1.079452	$	1.225508		18,497,317.000
		2003	$	0.839042	$	1.079452		12,997,209.887
		2002	$	1.000000	$	0.839042		6,398,657.964
Transamerica Morgan Stanley Growth Opportunities VP – Initial Class(7)		2010	$	1.278267	$	1.700156		4,044,605.938
Subaccount Inception Date May 1, 2001		2009	$	0.952676	$	1.278267		3,993,515.327
		2008	$	1.644548	$	0.952676		4,059,719.774
		2007	$	1.362963	$	1.644548		6,306,716.557
		2006	$	1.322671	$	1.362963		5,504,241.047
		2005	$	1.160673	$	1.322671		6,870,549.849
		2004	$	1.015141	$	1.160673		8,615,069.000
		2003	$	0.789126	$	1.015141		5,942,258.246
		2002	$	1.000000	$	0.789126		3,285,366.569
Transamerica AEGON Money Market VP - Initial Class(2)		2010	$	1.022349	$	1.002357		26,902,047.314
Subaccount Inception Date December 13, 1999		2009	$	1.041456	$	1.022349		23,291,176.105
		2008	$	1.037522	$	1.041456		46,545,524.010
		2007	$	1.007713	$	1.037522		22,779,551.235
		2006	$	0.981383	$	1.007713		22,037,069.535
		2005	$	0.972910	$	0.981383		20,287,826.482
		2004	$	0.982532	$	0.972910		16,492,326.000
		2003	$	0.994811	$	0.982532		19,459,962.625

30

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		2.00%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Systematic Small/Mid Cap Value VP - Initial Class(8)		2010	$	1.702193	$	2.176398		660,023.011
Subaccount Inception Date December 13, 1999		2009	$	1.212343	$	1.702193		820,499.502
		2008	$	2.091400	$	1.212343		912,814.371
		2007	$	1.710315	$	2.091400		1,146,787.355
		2006	$	1.477664	$	1.710315		1,439,497.055
		2005	$	1.327152	$	1.477664		1,839,006.689
		2004	$	1.163563	$	1.327152		2,093,897.000
		2003	$	0.621914	$	1.163563		2,216,461.144
		2002	$	1.000000	$	0.621914		2,540,297.734
Transamerica AEGON U.S. Government Securities VP – Initial Class(3)		2010	$	1.210056	$	1.238568		12,275,382.377
Subaccount Inception Date December 13, 1999		2009	$	1.181480	$	1.210056		14,122,801.162
		2008	$	1.119403	$	1.181480		15,104,583.960
		2007	$	1.076770	$	1.119403		9,844,283.266
		2006	$	1.063464	$	1.076770		11,931,761.808
		2005	$	1.061013	$	1.063464		12,294,070.242
		2004	$	1.047759	$	1.061013		14,008,432.000
		2003	$	1.038125	$	1.047759		21,094,464.426
		2002	$	1.000000	$	1.038125		15,429,788.674
Transamerica Morgan Stanley Active International Allocation VP – Initial		2010	$	1.376602	$	1.464064		4,675,101.335
Class		2009	$	1.115427	$	1.376602		6,068,280.495
Subaccount Inception Date December 13, 1999		2008	$	1.860173	$	1.115427		8,572,443.594
		2007	$	1.641440	$	1.860173		10,895,084.290
		2006	$	1.355531	$	1.641440		10,170,839.928
		2005	$	1.214998	$	1.355531		8,009,325.544
		2004	$	1.068030	$	1.214998		3,833,120.000
		2003	$	0.820248	$	1.068030		2,256,144.262
		2002	$	1.000000	$	0.820248		1,182,195.573
Transamerica Multi Managed Large Cap Core VP - Initial Class		2010	$	1.148362	$	1.341712		7,148,236.923
Subaccount Inception Date December 13, 1999		2009	$	0.805527	$	1.148362		7,895,854.322
		2008	$	1.418770	$	0.805527		1,406,547.147
		2007	$	1.324770	$	1.418770		1,852,245.391
		2006	$	1.224643	$	1.324770		2,419,430.720
		2005	$	1.141588	$	1.224643		2,705,551.708
		2004	$	1.032774	$	1.141588		2,277,182.000
		2003	$	0.869986	$	1.032774		2,435,262.763
		2002	$	1.000000	$	0.869986		1,276,455.501
Transamerica Morgan Stanley Mid-Cap Growth VP – Initial Class		2010	$	1.075785	$	1.412280		4,396,950.576
Subaccount Inception Date May 1, 2001		2009	$	0.683417	$	1.075785		3,405,009.970
		2008	$	1.297986	$	0.683417		3,382,061.999
		2007	$	1.080593	$	1.297986		4,606,398.404
		2006	$	1.002815	$	1.080593		4,307,450.042
		2005	$	0.951021	$	1.002815		5,507,472.840
		2004	$	0.905415	$	0.951021		6,607,218.000
		2003	$	0.720625	$	0.905415		7,207,416.116
		2002	$	1.000000	$	0.720625		4,624,818.501
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.833008	$	0.873396		4,373,966.236
Subaccount Inception Date May 1, 2002		2009	$	0.575118	$	0.833008		5,093,070.259
		2008	$	1.219814	$	0.575118		5,180,540.556
		2007	$	1.227607	$	1.219814		5,984,770.067
		2006	$	1.108624	$	1.227607		7,067,705.923
		2005	$	1.072517	$	1.108624		10,219,520.271
		2004	$	0.987041	$	1.072517		12,960,296.000
		2003	$	0.755307	$	0.987041		13,260,222.203
		2002	$	1.000000	$	0.755307		7,843,507.846

31

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		2.00%
Subaccount			Beginning AUV		Ending AUV		# Units
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.842217	$	0.951258		1,155,095.213
Subaccount Inception Date May 1, 2002		2009	$	0.711619	$	0.842217		1,260,594.888
		2008	$	1.265249	$	0.711619		1,541,852.235
		2007	$	1.155165	$	1.265249		1,617,195.928
		2006	$	1.110913	$	1.155165		2,591,984.017
		2005	$	1.043548	$	1.110913		2,173,294.606
		2004	$	1.001083	$	1.043548		2,808,707.000
		2003	$	0.790416	$	1.001083		2,793,960.328
		2002	$	1.000000	$	0.790416		1,393,608.068
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.919887	$	1.017288		4,753,075.291
Subaccount Inception Date May 1, 2001		2009	$	0.779642	$	0.919887		5,626,370.579
		2008	$	1.341034	$	0.779642		6,667,493.116
		2007	$	1.304592	$	1.341034		8,050,841.864
		2006	$	1.137425	$	1.304592		9,431,472.444
		2005	$	1.109128	$	1.137425		10,581,145.293
		2004	$	1.017215	$	1.109128		11,344,844.000
		2003	$	0.784917	$	1.017215		12,183,702.745
		2002	$	1.000000	$	0.784917		5,700,376.524
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.970457	$	1.044976		2,043,479.188
Subaccount Inception Date May 1, 2001		2009	$	0.721969	$	0.970457		2,455,405.389
		2008	$	1.223830	$	0.721969		2,100,321.185
		2007	$	1.098846	$	1.223830		2,840,806.145
		2006	$	1.127992	$	1.098846		3,214,426.002
		2005	$	1.001784	$	1.127992		3,511,731.130
		2004	$	0.943168	$	1.001784		3,674,710.000
		2003	$	0.779803	$	0.943168		4,258,365.336
		2002	$	1.000000	$	0.779803		1,731,588.265
Fidelity VIP Contrafund ® Portfolio – Service Class 2		2010	$	1.307994	$	1.499431		11,771,666.258
Subaccount Inception Date May 1, 2000		2009	$	0.984851	$	1.307994		12,409,407.079
		2008	$	1.753036	$	0.984851		14,933,756.751
		2007	$	1.524503	$	1.753036		18,438,587.217
		2006	$	1.395392	$	1.524503		22,012,127.904
		2005	$	1.220104	$	1.395392		24,067,141.830
		2004	$	1.080742	$	1.220104		20,711,661.000
		2003	$	0.859881	$	1.080742		18,243,549.207
		2002	$	1.000000	$	0.859881		7,579,480.885
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	0.977884	$	1.101740		3,487,244.908
Subaccount Inception Date May 1, 2000		2009	$	0.767949	$	0.977884		3,954,758.746
		2008	$	1.369859	$	0.767949		4,714,108.670
		2007	$	1.379845	$	1.369859		6,576,500.807
		2006	$	1.173503	$	1.379845		9,294,000.493
		2005	$	1.133751	$	1.173503		9,897,792.624
		2004	$	1.039687	$	1.133751		11,060,557.000
		2003	$	0.815553	$	1.039687		12,179,288.066
		2002	$	1.000000	$	0.815553		4,970,543.745
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.847072	$	1.028639		2,978,738.070
Subaccount Inception Date May 1, 2001		2009	$	0.675197	$	0.847072		2,716,486.137
		2008	$	1.307173	$	0.675197		2,997,179.393
		2007	$	1.052790	$	1.307173		5,003,611.264
		2006	$	1.007566	$	1.052790		3,523,042.731
		2005	$	0.974060	$	1.007566		4,268,288.112
		2004	$	0.963507	$	0.974060		5,825,042.000
		2003	$	0.741475	$	0.963507		6,545,815.995
		2002	$	1.000000	$	0.741475		3,210,924.474

32

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		2.00%
Subaccount			Beginning AUV		Ending AUV		# Units
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	1.654754	$	2.085871		10,125,181.331
Subaccount Inception Date May 1, 2000		2009	$	1.207741	$	1.654754		11,477,581.722
		2008	$	2.039987	$	1.207741		13,306,281.251
		2007	$	1.804281	$	2.039987		17,478,295.159
		2006	$	1.637200	$	1.804281		21,197,215.802
		2005	$	1.414926	$	1.637200		27,528,386.355
		2004	$	1.157817	$	1.414926		28,141,708.000
		2003	$	0.854204	$	1.157817		25,030,004.044
		2002	$	1.000000	$	0.854204		13,052,857.640
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	1.115330	$	1.381480		5,764,468.951
Subaccount Inception Date May 1, 2002		2009	$	0.723912	$	1.115330		6,691,855.770
		2008	$	1.515930	$	0.723912		6,777,674.052
		2007	$	1.466620	$	1.515930		9,211,192.614
		2006	$	1.289449	$	1.466620		11,484,658.469
		2005	$	1.284003	$	1.289449		13,060,778.549
		2004	$	1.150524	$	1.284003		15,324,659.000
		2003	$	0.745735	$	1.150524		15,021,244.301
		2002	$	1.000000	$	0.745735		7,189,603.659
Franklin Income Securities Fund - Class 2		2010	$	0.886076	$	0.978794		3,858,353.625
Subaccount Inception Date May 1, 2007		2009	$	0.666535	$	0.886076		3,343,136.043
		2008	$	0.966569	$	0.666535		1,557,560.510
		2007	$	1.000000	$	0.966569		1,046,608.381
Mutual Shares Securities Fund - Class 2		2010	$	0.731897	$	0.797876		2,008,268.201
Subaccount Inception Date May 1, 2007		2009	$	0.592261	$	0.731897		2,486,642.260
		2008	$	0.960642	$	0.592261		1,158,950.330
		2007	$	1.000000	$	0.960642		886,013.822
Templeton Foreign Securities Fund - Class 2		2010	$	0.836210	$	0.888745		4,647,408.895
Subaccount Inception Date May 1, 2007		2009	$	0.622392	$	0.836210		5,238,366.521
		2008	$	1.064874	$	0.622392		2,523,492.246
		2007	$	1.000000	$	1.064874		1,384,449.431
Janus Aspen – Enterprise Portfolio – Service Shares		2010	$	1.405692	$	1.729838		1,333,173.888
Subaccount Inception Date October 9, 2000		2009	$	0.992641	$	1.405692		1,098,172.665
		2008	$	1.803618	$	0.992641		1,332,109.949
		2007	$	1.511296	$	1.803618		1,208,480.106
		2006	$	1.360435	$	1.511296		1,307,708.969
		2005	$	1.238581	$	1.360435		1,586,371.282
		2004	$	1.048701	$	1.238581		2,051,998.000
		2003	$	0.793726	$	1.048701		1,221,713.916
		2002	$	1.000000	$	0.793726		631,070.597
Janus Aspen – Worldwide Portfolio – Service Shares		2010	$	0.903469	$	1.023231		5,978,118.593
Subaccount Inception Date October 9, 2000		2009	$	0.670682	$	0.903469		5,920,725.199
		2008	$	1.239604	$	0.670682		4,764,974.544
		2007	$	1.156260	$	1.239604		3,825,906.931
		2006	$	0.999963	$	1.156260		3,365,813.623
		2005	$	0.966124	$	0.999963		3,832,923.578
		2004	$	0.942814	$	0.966124		4,260,957.000
		2003	$	0.777523	$	0.942814		4,583,843.347
		2002	$	1.000000	$	0.777523		3,045,808.888

33

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		2.00%
Subaccount			Beginning AUV		Ending AUV		# Units
MFS ® New Discovery Series – Service Class		2010	$	1.097407	$	1.462592		3,129,767.050
Subaccount Inception Date May 1, 2002		2009	$	0.687052	$	1.097407		2,986,735.058
		2008	$	1.158818	$	0.687052		2,234,539.618
		2007	$	1.156112	$	1.158818		2,681,771.311
		2006	$	1.044169	$	1.156112		3,217,358.865
		2005	$	1.013968	$	1.044169		4,455,842.426
		2004	$	0.973842	$	1.013968		5,177,936.000
		2003	$	0.744424	$	0.973842		6,728,427.583
		2002	$	1.000000	$	0.744424		3,441,709.585
MFS ® Total Return Series – Service Class		2010	$	1.115919	$	1.199434		5,977,777.260
Subaccount Inception Date May 1, 2002		2009	$	0.966864	$	1.115919		6,544,900.203
		2008	$	1.269680	$	0.966864		6,789,846.649
		2007	$	1.246172	$	1.269680		9,576,083.042
		2006	$	1.040000	$	1.246172		10,782,468.044
		2005	$	0.914431	$	1.040000		13,003,324.43
		2004	$	1.000000	$	0.914431		6,644,330.265
		2003	$	0.914431	$	1.040000		13,003,324.437
		2002	$	1.000000	$	0.914431		6,644,330.265
	Year		1.85%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation - Conservative VP – Service Class		2010	$	0.974625	$	1.040246		6,660,088.626
Subaccount Inception Date May 1, 2002		2009	$	0.794732	$	0.974625		3,702,834.646
		2008	$	1.000000	$	0.794732		1,131,428.358
Transamerica Asset Allocation - Growth VP – Service Class		2010	$	0.847313	$	0.953791		1,079,112.408
Subaccount Inception Date May 1, 2002		2009	$	0.666176	$	0.847313		430,149.047
		2008	$	1.000000	$	0.666176		44,002.366
Transamerica Asset Allocation - Moderate VP – Service Class		2010	$	0.948324	$	1.025500		9,938,901.248
Subaccount Inception Date May 1, 2002		2009	$	0.765361	$	0.948324		8,015,838.240
		2008	$	1.000000	$	0.765361		3,123,047.231
Transamerica Asset Allocation - Moderate Growth VP – Service Class		2010	$	0.899850	$	0.993104		29,868,289.077
Subaccount Inception Date May 1, 2002		2009	$	0.716732	$	0.899850		21,946,217.012
		2008	$	1.000000	$	0.716732		12,595,190.977
Transamerica International Moderate Growth VP – Service Class		2010	$	0.870183	$	0.941890		6,703,388.939
Subaccount Inception Date May 1, 2006		2009	$	0.685290	$	0.870183		5,625,662.854
		2008	$	1.000000	$	0.685290		3,574,671.002
Transamerica BlackRock Global Allocation VP – Service Class		2010	$	1.200425	$	1.292577		8,291,227.438
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.200425		2,814,354.466
Transamerica BlackRock Large Cap Value VP – Service Class		2010	$	0.814239	$	0.880613		1,608,893.122
Subaccount Inception Date December 13, 1999		2009	$	0.729294	$	0.814239		312,776.737
		2008	$	1.000000	$	0.729294		14,257.504
Transamerica BlackRock Tactical Allocation VP – Service Class		2010	$	1.204175	$	1.315228		2,331,268.057
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.204175		605,373.387
Transamerica Clarion Global Real Estate Securities VP – Service Class		2010	$	0.824058	$	0.932888		518,543.724
Subaccount Inception Date May 1, 2002		2009	$	0.631030	$	0.824058		55,404.231
		2008	$	1.000000	$	0.631030		5,393.402
Transamerica Foxhall Emerging Markets/Pacific Rim VP – Service Class		2010	$	1.008913	$	1.024031		855,734.960
Subaccount Inception Date November 19, 2009		2009	$	0.990708	$	1.008913		370,894.895
Transamerica Foxhall Global Conservative VP – Service Class		2010	$	0.983214	$	0.906518		884,336.123
Subaccount Inception Date November 19, 2009		2009	$	0.995062	$	0.983214		25,578.759

34

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.85%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Foxhall Global Growth VP – Service Class		2010	$	1.006069	$	1.041027		415,463.187
Subaccount Inception Date November 19, 2009		2009	$	0.988961	$	1.006069		159,644.773
Transamerica Foxhall Global Commodities & Hard Asset VP – Service Class(9)		2010	$	0.985441	$	0.997558		738,582.494
Subaccount Inception Date November 19, 2009		2009	$	0.986565	$	0.985441		271,173.391
Transamerica Hanlon Balanced VP – Service Class		2010	$	1.020258	$	0.967038		379,689.257
Subaccount Inception Date November 19, 2009		2009	$	0.998153	$	1.020258		0.000
Transamerica Hanlon Growth VP – Service Class		2010	$	1.020927	$	0.995312		453,537.945
Subaccount Inception Date November 19, 2009		2009	$	0.996391	$	1.020927		99,434.210
Transamerica Hanlon Growth and Income VP – Service Class		2010	$	1.022007	$	0.982197		394,520.211
Subaccount Inception Date November 19, 2009		2009	$	0.997259	$	1.022007		12,862.484
Transamerica Hanlon Managed Income VP – Service Class		2010	$	1.003280	$	0.986221		3,249,499.482
Subaccount Inception Date November 19, 2009		2009	$	0.999950	$	1.003280		457,639.614
Transamerica JPMorgan Enhanced Index VP – Service Class		2010	$	0.874872	$	0.986582		185,692.657
Subaccount Inception Date December 13, 1999		2009	$	0.689051	$	0.874872		130,836.752
		2008	$	1.000000	$	0.689051		0.000
Transamerica JPMorgan Mid Cap Value VP – Service Class		2010	$	1.029234	$	1.241163		136,281.705
Subaccount Inception Date November 19, 2009		2009	$	0.985149	$	1.029234		0.000
Transamerica Jennison Growth VP– Service Class		2010	$	0.965008	$	1.060942		692,331.930
Subaccount Inception Date December 13, 1999		2009	$	0.698605	$	0.965008		21,833.915
		2008	$	1.000000	$	0.698605		0.000
Transamerica Morgan Stanley Capital Growth VP – Service Class(5)		2010	$	0.861561	$	1.075052		244,460.335
Subaccount Inception Date December 13, 1999		2009	$	0.687880	$	0.861561		61,236.062
		2008	$	1.000000	$	0.687880		0.000
Transamerica AEGON High Yield Bond VP – Service Class		2010	$	1.085851	$	1.195869		543,099.689
Subaccount Inception Date December 13, 1999		2009	$	0.753059	$	1.085851		83,802.739
		2008	$	1.000000	$	0.753059		0.000
Transamerica MFS International Equity VP – Service Class		2010	$	0.924448	$	1.001197		414,813.737
Subaccount Inception Date May 1, 2001		2009	$	0.712018	$	0.924448		191,893.299
		2008	$	1.000000	$	0.712018		13,110.671
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.044209	$	1.096349		5,945,297.918
Subaccount Inception Date May 1, 2002		2009	$	0.918798	$	1.044209		1,808,495.253
		2008	$	1.000000	$	0.918798		307,031.381
Transamerica T. Rowe Price Small Cap VP – Service Class		2010	$	0.969402	$	1.275993		497,670.994
Subaccount Inception Date December 13, 1999		2009	$	0.713745	$	0.969402		78,595.690
		2008	$	1.000000	$	0.713745		321.981
Transamerica WMC Diversified Equity VP – Service Class(6)		2010	$	0.785475	$	0.898819		663,061.253
Subaccount Inception Date December 13, 1999		2009	$	0.625758	$	0.785475		184,053.839
		2008	$	1.000000	$	0.625758		0.000
Transamerica Efficient Markets VP – Service Class		2010	$	1.199258	$	1.323210		869,133.380
Subaccount Inception Date November 10, 2008		2009	$	1.036345	$	1.199258		257,836.244
		2008	$	1.000000	$	1.036345		0.000
Transamerica Multi-Managed Balanced VP – Service Class(1)		2010	$	0.907237	$	1.103510		1,673,394.041
Subaccount Inception Date May 1, 2002		2009	$	0.733703	$	0.907237		689,912.635
		2008	$	1.000000	$	0.733703		108,938.228
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class(4)		2010	$	0.881152	$	0.944319		520,497.561
Subaccount Inception Date May 1, 2002		2009	$	0.684218	$	0.881152		80,507.490
		2008	$	1.000000	$	0.684218		0.000

35

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.85%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica WMC Diversified Growth VP – Service Class		2010	$	0.769016	$	.887043		185,433.449
Subaccount Inception Date December 13, 1999		2009	$	0.607655	$	0.769016		0.000
		2008	$	1.000000	$	0.607655		0.000
Transamerica Morgan Stanley Growth Opportunities VP – Service Class(7)		2010	$	0.888439	$	1.180107		153,503.161
Subaccount Inception Date May 1, 2001		2009	$	0.662824	$	0.888439		2,124.124
		2008	$	1.000000	$	0.662824		0.000
Transamerica AEGON Money Market VP – Service Class(2)		2010	$	0.983647	$	0.965818		4,509,259.953
Subaccount Inception Date December 13, 1999		2009	$	1.001736	$	0.983647		4,845,675.557
		2008	$	1.000000	$	1.001736		2,762,745.906
Transamerica Systematic Small/Mid Cap Value VP – Service Class(8)		2010	$	0.925057	$	1.181205		649,379.270
Subaccount Inception Date December 13, 1999		2009	$	0.659317	$	0.925057		90,602.014
		2008	$	1.000000	$	0.659317		3,246.309
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.055054	$	1.079643		1,891,712.434
Subaccount Inception Date December 13, 1999		2009	$	1.031288	$	1.055054		1,551,702.556
		2008	$	1.000000	$	1.031288		28,835.351
Transamerica Index 35 VP – Service Class		2010	$	0.997845	$	1.072050		509,730.221
Subaccount Inception Date November 19, 2009		2009	$	0.999950	$	0.997845		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.933525	$	1.014580		1,712,295.326
Subaccount Inception Date May 1, 2008		2009	$	0.815922	$	0.933525		1,018,493.141
		2008	$	1.000000	$	0.815922		16,386.023
Transamerica Index 75 VP – Service Class		2010	$	0.870910	$	0.966294		6,081,790.941
Subaccount Inception Date May 1, 2008		2009	$	0.720097	$	0.870910		3,793,893.524
		2008	$	1.000000	$	0.720097		765,265.451
Transamerica Index 100 VP – Service Class		2010	$	1.023790	$	1.150020		139,129.324
Subaccount Inception Date November 19, 2009		2009	$	0.999950	$	1.023790		0.000
Transamerica Morgan Stanley Active International Allocation VP – Service		2010	$	0.835905	$	0.888053		180,533.420
Class		2009	$	0.677428	$	0.835905		92,309.727
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	0.677428		10,289.109
Transamerica Multi Managed Large Cap Core VP – Service Class		2010	$	0.909732	$	1.061798		272,951.433
Subaccount Inception Date December 13, 1999		2009	$	0.638635	$	0.909732		102,220.287
		2008	$	1.000000	$	0.638635		10,131.897
Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class		2010	$	0.959324	$	1.258194		225,045.306
Subaccount Inception Date May 1, 2001		2009	$	0.610219	$	0.959324		38,897.481
		2008	$	1.000000	$	0.610219		3,477.655
PAM Transamerica AEGON U.S. Government Securities VP – Service		2010	$	1.055054	$	1.079643		3,032.191
Class(3)		2009	$	1.031288	$	1.055054		2,492.689
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	1.031288		22,921.360
Transamerica ProFunds UltraBear Fund – Service Class OAM		2010	$	0.561040	$	0.403424		115,590.490
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	0.561040		0.000
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.767822	$	0.806245		83,614.687
Subaccount Inception Date May 1, 2002		2009	$	0.529332	$	0.767822		44,715.301
		2008	$	1.000000	$	0.529332		14,332.280
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.773656	$	0.875122		146,271.962
Subaccount Inception Date May 1, 2002		2009	$	0.652734	$	0.773656		28,467.971
		2008	$	1.000000	$	0.652734		13,917.185
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.234764	$	1.334562		1,312,313.116
Subaccount Inception Date November 10, 2008		2009	$	1.012506	$	1.234764		1,110,489.184
		2008	$	1.000000	$	1.012506		0.000

36

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.85%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.766719	$	0.849153		140,585.977
Subaccount Inception Date May 1, 2001		2009	$	0.648864	$	0.766719		25,448.772
		2008	$	1.000000	$	0.648864		14,450.134
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.914663	$	0.986356		115,178.187
Subaccount Inception Date May 1, 2001		2009	$	0.679461	$	0.914663		49,915.559
		2008	$	1.000000	$	0.679461		13,772.455
American Funds - Asset Allocation Fund - Class 2		2010	$	1.007757	$	1.109924		1,163,012.575
Subaccount Inception Date November 19, 2009		2009	$	0.989772	$	1.007757		23,118.460
American Funds - Bond Fund - Class 2		2010	$	0.993473	$	1.035242		385,357.711
Subaccount Inception Date November 19, 2009		2009	$	1.000893	$	0.993473		35,084.385
American Funds - Growth Fund - Class 2		2010	$	1.002616	$	1.164887		536,171.086
Subaccount Inception Date November 19, 2009		2009	$	0.986475	$	1.002616		43,021.345
American Funds - Growth-Income Fund - Class 2		2010	$	1.008005	$	1.099564		341,823.719
Subaccount Inception Date November 19, 2009		2009	$	0.986796	$	1.008005		26,448.864
American Funds - International Fund - Class 2		2010	$	0.980131	$	1.028927		420,687.144
Subaccount Inception Date November 19, 2009		2009	$	0.982906	$	0.980131		58,115.822
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.901874	$	1.042736		847,914.926
Subaccount Inception Date May 1, 2008		2009	$	0.664068	$	0.901874		407,275.450
		2008	$	1.000000	$	0.664068		78,741.863
Fidelity VIP Contrafund ® Portfolio – Service Class 2		2010	$	0.851856	$	0.977967		1,414,274.871
Subaccount Inception Date May 1, 2000		2009	$	0.640460	$	0.851856		529,412.761
		2008	$	1.000000	$	0.640460		13,057.875
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	0.810662	$	0.914681		300,166.197
Subaccount Inception Date May 1, 2000		2009	$	0.635692	$	0.810662		139,566.146
		2008	$	1.000000	$	0.635692		0.000
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.745285	$	0.906359		169,942.413
Subaccount Inception Date May 1, 2001		2009	$	0.593199	$	0.745285		22,135.670
		2008	$	1.000000	$	0.593199		0.000
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	0.920074	$	1.161485		766,161.898
Subaccount Inception Date May 1, 2000		2009	$	0.670542	$	0.920074		204,406.252
		2008	$	1.000000	$	0.670542		1,627.141
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	0.861623	$	1.068798		184,022.159
Subaccount Inception Date May 1, 2002		2009	$	0.558417	$	0.861623		45,588.395
		2008	$	1.000000	$	0.558417		0.000
Franklin Income Securities Fund - Class 2		2010	$	0.969753	$	1.072808		739,031.153
Subaccount Inception Date May 1, 2007		2009	$	0.728407	$	0.969753		161,021.114
		2008	$	1.000000	$	0.728407		0.000
Mutual Shares Securities Fund - Class 2		2010	$	0.843067	$	0.920438		148,462.079
Subaccount Inception Date May 1, 2007		2009	$	0.681225	$	0.843067		82,733.733
		2008	$	1.000000	$	0.681225		4,486.104
Templeton Foreign Securities Fund - Class 2		2010	$	0.886044	$	0.943095		909,801.065
Subaccount Inception Date May 1, 2007		2009	$	0.658517	$	0.886044		202,066.450
		2008	$	1.000000	$	0.658517		0.000
Franklin Templeton VIP Founding Funds Allocation Fund - Class 4		2010	$	1.262175	$	1.364151		1,640,817.145
Subaccount Inception Date November 10, 2008		2009	$	0.989834	$	1.262175		1,157,411.884
		2008	$	1.000000	$	0.989834		0.000
GE Investments Total Return Fund – Class 3		2010	$	1.003397	$	1.075335		194,418.013
Subaccount Inception Date November 19, 2009		2009	$	0.988804	$	1.003397		0.000

37

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.85%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Janus Aspen – Enterprise Portfolio – Service Shares		2010	$	0.900194	$	1.109404		261,143.006
Subaccount Inception Date October 9, 2000		2009	$	0.634742	$	0.900194		124,428.426
		2008	$	1.000000	$	0.634742		13,114.911
Janus Aspen – Worldwide Portfolio – Service Shares		2010	$	0.828283	$	0.939457		430,614.413
Subaccount Inception Date October 9, 2000		2009	$	0.613959	$	0.828283		127,827.616
		2008	$	1.000000	$	0.613959		0.000
MFS ® New Discovery Series – Service Class		2010	$	1.093694	$	1.459792		436,571.553
Subaccount Inception Date May 1, 2002		2009	$	0.683716	$	1.093694		116,156.437
		2008	$	1.000000	$	0.683716		0.000
MFS ® Total Return Series – Service Class		2010	$	0.932473	$	1.003730		284,563.726
Subaccount Inception Date May 1, 2002		2009	$	0.806742	$	0.932473		49,409.510
		2008	$	1.000000	$	0.806742		13,645.262
			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation – Conservative VP – Service Class		2010	$	1.360674	$	1.453716		7,825,504.095
Subaccount Inception Date May 1, 2002		2009	$	1.108444	$	1.360674		7,982,001.489
		2008	$	1.435053	$	1.108444		5,930,159.280
		2007	$	1.375734	$	1.435053		5,527,530.703
		2006	$	1.282491	$	1.375734		3,845,822.251
		2005	$	1.242634	$	1.282491		2,804,704.507
		2004	$	1.155302	$	1.242634		1,855,335.000
		2003	$	1.000000	$	1.155302		307,212.936
Transamerica Asset Allocation – Growth VP – Service Class		2010	$	1.383795	$	1.559221		2,647,361.600
Subaccount Inception Date May 1, 2002		2009	$	1.086901	$	1.383795		3,128,815.316
		2008	$	1.835886	$	1.086901		3,672,464.659
		2007	$	1.737294	$	1.835886		4,848,400.234
		2006	$	1.533351	$	1.737294		5,114,118.516
		2005	$	1.393908	$	1.533351		4,565,256.388
		2004	$	1.245239	$	1.393908		2,876,079.000
		2003	$	1.000000	$	1.245239		290,506.090
Transamerica Asset Allocation – Moderate VP – Service Class		2010	$	1.409153	$	1.525314		17,802,002.572
Subaccount Inception Date May 1, 2002		2009	$	1.136173	$	1.409153		19,839,909.022
		2008	$	1.566461	$	1.136173		19,670,384.542
		2007	$	1.479583	$	1.566461		21,367,218.324
		2006	$	1.353622	$	1.479583		16,006,431.728
		2005	$	1.285592	$	1.353622		11,219,139.331
		2004	$	1.177178	$	1.285592		6,510,935.000
		2003	$	1.000000	$	1.177178		1,147,530.824
Transamerica Asset Allocation – Moderate Growth VP – Service Class		2010	$	1.410934	$	1.558693		34,348,066.549
Subaccount Inception Date May 1, 2002		2009	$	1.122716	$	1.410934		37,515,770.590
		2008	$	1.703179	$	1.122716		42,088,024.754
		2007	$	1.611349	$	1.703179		42,863,347.685
		2006	$	1.443975	$	1.611349		28,454,380.136
		2005	$	1.339175	$	1.443975		14,460,178.294
		2004	$	1.204194	$	1.339175		5,588,810.000
		2003	$	1.000000	$	1.204194		1,830,007.237
Transamerica International Moderate Growth VP – Service Class		2010	$	0.872753	$	0.945602		8,852,791.993
Subaccount Inception Date May 1, 2006		2009	$	0.686639	$	0.872753		9,701,250.417
		2008	$	1.097167	$	0.686639		10,460,325.885
		2007	$	1.029080	$	1.097167		9,562,636.466
		2006	$	1.000000	$	1.029080		1,433,431.069

38

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica BlackRock Global Allocation VP - Service Class		2010	$	1.201202	$	1.294690		681,223.139
Subaccount Incepetion Date May 1, 2009		2009	$	1.000000	$	1.201202		167,313.530
Transamerica BlackRock Large Cap Value VP – Service Class		2010	$	1.411217	$	1.527736		735,737.346
Subaccount Inception Date December 13, 1999		2009	$	1.262749	$	1.411217		549,368.025
		2008	$	1.948785	$	1.262749		356,633.333
		2007	$	1.900433	$	1.948785		702,828.504
		2006	$	1.658034	$	1.900433		476,841.074
		2005	$	1.457652	$	1.658034		402,565.262
		2004	$	1.256983	$	1.457652		157,920.000
		2003	$	1.000000	$	1.256983		0.000
Transamerica BlackRock Tactical Allocation VP - Service Class		2010	$	1.204966	$	1.317394		1,712,528.150
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.204966		69,942.078
Transamerica Clarion Global Real Estate Securities VP – Service Class		2010	$	1.728165	$	1.958315		181,129.220
Subaccount Inception Date May 1, 2002		2009	$	1.322060	$	1.728165		209,677.726
		2008	$	2.339523	$	1.322060		204,950.205
		2007	$	2.557346	$	2.339523		350,964.482
		2006	$	1.833468	$	2.557346		413,814.645
		2005	$	1.648190	$	1.833468		221,506.903
		2004	$	1.265770	$	1.648190		191,823.000
		2003	$	1.000000	$	1.265770		21,080.988
Transamerica Foxhall Emerging Markets/Pacific Rim VP – Service Class		2010	$	1.009028	$	1.025165		56,546.239
Subaccount Inception Date November 19, 2009		2009	$	0.990710	$	1.009028		0.000
Transamerica Foxhall Global Conservative VP – Service Class		2010	$	0.983325	$	0.907511		31,446.572
Subaccount Inception Date November 19, 2009		2009	$	0.995065	$	0.983325		0.000
Transamerica Foxhall Global Growth VP – Service Class		2010	$	1.006186	$	1.042154		0.000
Subaccount Inception Date November 19, 2009		2009	$	0.988963	$	1.006186		0.000
Transamerica Foxhall Global Commodities & Hard Asset VP – Service Class(9)		2010	$	0.985557	$	0.998657		176,789.615
Subaccount Inception Date November 19, 2009		2009	$	0.986568	$	0.985557		0.000
Transamerica Hanlon Balanced VP – Service Class		2010	$	1.020377	$	0.968114		35,859.857
Subaccount Inception Date November 19, 2009		2009	$	0.998156	$	1.020377		0.000
Transamerica Hanlon Growth VP – Service Class		2010	$	1.021045	$	0.996415		55,581.324
Subaccount Inception Date November 19, 2009		2009	$	0.996394	$	1.021045		0.000
Transamerica Hanlon Growth and Income VP – Service Class		2010	$	1.022125	$	0.983287		0.000
Subaccount Inception Date November 19, 2009		2009	$	0.997262	$	1.022125		0.000
Transamerica Hanlon Managed Income VP – Service Class		2010	$	1.003388	$	0.987297		62,003.981
Subaccount Inception Date November 19, 2009		2009	$	0.999952	$	1.003388		0.000
Transamerica JPMorgan Enhanced Index VP – Service Class		2010	$	1.210845	$	1.366794		146,044.256
Subaccount Inception Date December 13, 1999		2009	$	0.952735	$	1.210845		198,210.176
		2008	$	1.551699	$	0.952735		136,602.147
		2007	$	1.513862	$	1.551699		212,284.269
		2006	$	1.339793	$	1.513862		209,183.204
		2005	$	1.320935	$	1.339793		210,485.131
		2004	$	1.214100	$	1.320935		108,244.000
		2003	$	1.000000	$	1.214100		8,021.913
Transamerica JPMorgan Mid Cap Value VP – Service Class		2010	$	1.029351	$	1.242520		406,981.249
Subaccount Inception Date November 19, 2009		2009	$	0.985151	$	1.029351		27,682.174

39

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Jennison Growth VP – Service Class		2010	$	1.338557	$	1.473083		454,210.558
Subaccount Inception Date December 13, 1999		2009	$	0.968070	$	1.338557		70,972.715
		2008	$	1.566318	$	0.968070		74,203.944
		2007	$	1.432338	$	1.566318		84,439.178
		2006	$	1.434388	$	1.432338		80,209.744
		2005	$	1.285592	$	1.434388		86,686.977
		2004	$	1.201599	$	1.285592		81,977.000
		2003	$	1.000000	$	1.201599		21,860.345
Transamerica Morgan Stanley Capital Growth VP – Service Class(5)		2010	$	1.251941	$	1.563699		64,843.719
Subaccount Inception Date December 13, 1999		2009	$	0.998584	$	1.251941		120,078.616
		2008	$	1.601232	$	0.998584		133,436.617
		2007	$	1.617051	$	1.601232		226,472.796
		2006	$	1.390848	$	1.617051		287,510.460
		2005	$	1.363239	$	1.390848		221,435.614
		2004	$	1.273838	$	1.363239		149,092.000
		2003	$	1.000000	$	1.273838		9,134.125
Transamerica AEGON High Yield Bond VP – Service Class		2010	$	1.336763	$	1.473647		309,781.934
Subaccount Inception Date December 13, 1999		2009	$	0.926167	$	1.336763		612,327.180
		2008	$	1.264393	$	0.926167		218,662.078
		2007	$	1.264794	$	1.264393		795,496.012
		2006	$	1.163353	$	1.264794		379,937.913
		2005	$	1.166138	$	1.163353		416,362.883
		2004	$	1.083621	$	1.166138		614,622.000
		2003	$	1.000000	$	1.083621		284,139.839
Transamerica MFS International Equity VP – Service Class		2010	$	1.654440	$	1.793558		115,478.325
Subaccount Inception Date May 1, 2001		2009	$	1.273010	$	1.654440		177,952.266
		2008	$	2.009631	$	1.273010		157,766.097
		2007	$	1.878409	$	2.009631		314,826.154
		2006	$	1.554838	$	1.878409		243,834.908
		2005	$	1.407206	$	1.554838		66,180.836
		2004	$	1.253529	$	1.407206		67,886.000
		2003	$	1.000000	$	1.253529		19,846.953
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.225822	$	1.288298		1,620,262.184
Subaccount Inception Date May 1, 2002		2009	$	1.077549	$	1.225822		1,594,357.334
		2008	$	1.131233	$	1.077549		1,418,112.767
		2007	$	1.057979	$	1.131233		1,543,968.779
		2006	$	1.036061	$	1.057979		1,188,010.111
		2005	$	1.033136	$	1.036061		823,037.297
		2004	$	1.008725	$	1.033136		832,492.000
		2003	$	1.000000	$	1.008725		112,375.689
Transamerica T. Rowe Price Small Cap VP – Service Class		2010	$	1.447537	$	1.907215		298,993.352
Subaccount Inception Date December 13, 1999		2009	$	1.064746	$	1.447537		360,207.491
		2008	$	1.703672	$	1.064746		280,177.839
		2007	$	1.586516	$	1.703672		453,018.375
		2006	$	1.562046	$	1.586516		506,330.352
		2005	$	1.439612	$	1.562046		607,442.291
		2004	$	1.330301	$	1.439612		339,690.000
		2003	$	1.000000	$	1.330301		44,115.959

40

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica WMC Diversified Equity VP – Service Class(6)		2010	$	1.040887	$	1.192268		442,916.132
Subaccount Inception Date December 13, 1999		2009	$	0.828411	$	1.040887		352,571.328
		2008	$	1.500336	$	0.828411		142,630.360
		2007	$	1.327814	$	1.500336		243,974.802
		2006	$	1.140576	$	1.327814		83,038.410
		2005	$	1.082236	$	1.140576		78,284.068
		2004	$	1.204345	$	1.082236		72,007.000
		2003	$	1.000000	$	1.204345		2,168.392
Transamerica Efficient Markets VP – Service Class		2010	$	1.200602	$	1.326002		90,696.822
Subaccount Inception Date November 10, 2008		2009	$	1.036485	$	1.200602		90,544.354
		2008	$	1.000000	$	1.036485		0.000
Transamerica Multi-Managed Balanced VP – Service Class(1)		2010	$	1.236185	$	1.505101		379,182.527
Subaccount Inception Date May 1, 2002		2009	$	0.998763	$	1.236185		464,592.062
		2008	$	1.507293	$	0.998763		462,952.454
		2007	$	1.352856	$	1.507293		532,488.909
		2006	$	1.265831	$	1.352856		177,780.024
		2005	$	1.194852	$	1.265831		101,220.960
		2004	$	1.096549	$	1.194852		134,463.000
		2003	$	1.000000	$	1.096549		1,918.821
Transamerica AllianceBernstein Dynamic Allocation VP - Service Class(4)		2010	$	1.313788	$	1.409354		347,953.237
Subaccount Inception Date May 1, 2002		2009	$	1.019159	$	1.313788		343,601.131
		2008	$	1.646106	$	1.019159		346,274.373
		2007	$	1.416092	$	1.646106		733,366.439
		2006	$	1.302121	$	1.416092		788,817.200
		2005	$	1.279529	$	1.302121		581,684.314
		2004	$	1.152255	$	1.279529		547,609.000
		2003	$	1.000000	$	1.152255		126,073.200
Transamerica WMC Diversified Growth VP – Service Class		2010	$	1.277827	$	1.475398		364,925.396
Subaccount Inception Date December 13, 1999		2009	$	1.008706	$	1.277827		396,952.932
		2008	$	1.907006	$	1.008706		378,701.138
		2007	$	1.672260	$	1.907006		561,288.626
		2006	$	1.569849	$	1.672260		957,035.425
		2005	$	1.373635	$	1.569849		678,347.258
		2004	$	1.208906	$	1.373635		331,709.000
		2003	$	1.000000	$	1.208906		41,095.322
Transamerica Morgan Stanley Growth Opportunities VP – Service Class(7)		2010	$	1.575271	$	2.094467		123,195.466
Subaccount Inception Date May 1, 2001		2009	$	1.174087	$	1.575271		161,158.161
		2008	$	2.027205	$	1.174087		132,978.466
		2007	$	1.680725	$	2.027205		259,656.959
		2006	$	1.630219	$	1.680725		214,192.542
		2005	$	1.430744	$	1.630219		297,129.761
		2004	$	1.249566	$	1.430744		299,196.000
		2003	$	1.000000	$	1.249566		0.000
Transamerica AEGON Money Market VP – Service Class(2)		2010	$	1.033297	$	1.015571		5,885,153.343
Subaccount Inception Date December 13, 1999		2009	$	1.051231	$	1.033297		7,280,503.875
		2008	$	1.047028	$	1.051231		10,001,098.042
		2007	$	1.016973	$	1.047028		5,501,489.863
		2006	$	0.990442	$	1.016973		2,664,758.760
		2005	$	0.981927	$	0.990442		1,547,186.807
		2004	$	0.991686	$	0.981927		929,674.000
		2003	$	1.000000	$	0.991686		611,595.739
Transamerica ProFunds UltraBear Fund – Service Class OAM		2010	$	0.561414	$	0.404078		0.000
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	0.561414		0.000

41

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Systematic Small/Mid Cap Value VP – Service Class(8)		2010	$	0.926813	$	1.184614		53,983.548
Subaccount Inception Date December 13, 1999		2009	$	0.659927	$	0.926813		12,861.445
		2008	$	1.000000	$	0.659927		6,270.818
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.147360	$	1.175250		748,187.886
Subaccount Inception Date December 13, 1999		2009	$	1.120408	$	1.147360		507,624.243
		2008	$	1.061365	$	1.120408		1,113,858.707
		2007	$	1.021007	$	1.061365		482,437.684
		2006	$	1.007992	$	1.021007		17,439.551
		2005	$	1.005657	$	1.007992		34,879.101
		2004	$	0.994431	$	1.005657		41,131.074
		2003	$	1.000000	$	0.994431		82,663.000
Transamerica Index 35 VP – Service Class		2010	$	0.997954	$	1.073221		1,143.109
Subaccount Inception Date November 19, 2009		2009	$	0.999952	$	0.997954		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.935049	$	1.017230		58,199.348
Subaccount Inception Date May 1, 2008		2009	$	0.816459	$	0.935049		40,096.167
		2008	$	1.000000	$	0.816459		28,682.298
Transamerica Index 75 VP – Service Class		2010	$	0.872328	$	0.968815		41,423.707
Subaccount Inception Date May 1, 2008		2009	$	0.720567	$	0.872328		41,631.122
		2008	$	1.00000	$	0.720567		0.000
Transamerica Index 100 VP – Service Class		2010	$	1.023908	$	1.151278		84,338.486
Subaccount Inception Date November 19, 2009		2009	$	0.999952	$	1.023908		0.000
Transamerica Morgan Stanley Active International Allocation VP – Service Class		2010	$	1.689683	$	1.796851		295,009.750
		2009	$	1.367995	$	1.689683		436,980.515
Subaccount Inception Date December 13, 1999		2008	$	2.283791	$	1.367995		378,242.175
		2007	$	2.016043	$	2.283791		618,113.187
		2006	$	1.665142	$	2.016043		420,770.385
		2005	$	1.491214	$	1.665142		328,239.473
		2004	$	1.311295	$	1.491214		8,535.000
		2003	$	1.000000	$	1.311295		224.817
Transamerica Multi Managed Large Cap Core VP – Service Class		2010	$	1.278025	$	1.493130		293,541.326
Subaccount Inception Date December 13, 1999		2009	$	0.896283	$	1.278025		245,452.067
		2008	$	1.578048	$	0.896283		78,276.870
		2007	$	1.473996	$	1.578048		88,345.122
		2006	$	1.362620	$	1.473996		112,109.778
		2005	$	1.270500	$	1.362620		72,400.758
		2004	$	1.148860	$	1.270500		69,797.000
		2003	$	1.000000	$	1.148860		3,561.452
Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class		2010	$	1.410733	$	1.852067		128,809.410
Subaccount Inception Date May 1, 2001		2009	$	0.896457	$	1.410733		121,922.714
		2008	$	1.703148	$	0.896457		122,015.897
		2007	$	1.417812	$	1.703148		126,046.653
		2006	$	1.316316	$	1.417812		59,887.004
		2005	$	1.248019	$	1.316316		59,802.612
		2004	$	1.187770	$	1.248019		54,877.000
		2003	$	1.000000	$	1.187770		13,611.048
PAM Transamerica AEGON U.S. Government Securities VP – Service		2010	$	1.147360	$	1.175250		4,029,529.556
Class(3)		2009	$	1.120408	$	1.147360		6,196,538.125
Subaccount Inception Date December 13, 1999		2008	$	1.061365	$	1.120408		11,749,465.204
		2007	$	1.021007	$	1.061365		396,411.129
		2006	$	1.007992	$	1.021007		0.000
		2005	$	1.005657	$	1.007992		0.000
		2004	$	0.994431	$	1.005657		0.000
		2003	$	1.000000	$	0.994431		0.000

42

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.848858	$	0.892202		2,951,974.019
Subaccount Inception Date May 1, 2002		2009	$	0.584622	$	0.848858		3,597,654.359
		2008	$	1.236922	$	0.584622		4,001,591.249
		2007	$	1.241756	$	1.236922		4,948,441.923
		2006	$	1.118660	$	1.241756		6,086,696.959
		2005	$	1.079577	$	1.118660		7,063,154.195
		2004	$	0.991093	$	1.079577		8,529,674.000
		2003	$	0.756547	$	0.991093		8,449,207.284
		2002	$	1.000000	$	0.756547		5,866,259.794
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.858250	$	0.971761		576,334.913
Subaccount Inception Date May 1, 2002		2009	$	0.723394	$	0.858250		656,467.015
		2008	$	1.283006	$	0.723394		843,187.428
		2007	$	1.168487	$	1.283006		1,273,247.884
		2006	$	1.120967	$	1.168487		1,281,633.501
		2005	$	1.050411	$	1.120967		1,129,209.453
		2004	$	1.005183	$	1.050411		1,279,115.000
		2003	$	0.791715	$	1.005183		1,093,316.298
		2002	$	1.000000	$	0.791715		621,815.721
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.236150	$	1.337375		17,628.433
Subaccount Inception Date November 10, 2008		2009	$	1.012647	$	1.236150		0.000
		2008	$	1.000000	$	1.012647		0.000
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.841466	$	0.932852		5,431,904.683
Subaccount Inception Date May 1, 2001		2009	$	0.711425	$	0.841466		7,898,729.599
		2008	$	1.220699	$	0.711425		8,728,683.614
		2007	$	1.184597	$	1.220699		11,490,946.747
		2006	$	1.030286	$	1.184597		14,722,056.396
		2005	$	1.002212	$	1.030286		17,354,777.023
		2004	$	0.916899	$	1.002212		21,526,012.000
		2003	$	0.705776	$	0.916899		25,741,406.569
		2002	$	0.923843	$	0.705776		24,544,490.492
		2001	$	1.000000	$	0.923843		9,379,882.589
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.734336	$	0.792670		3,042,051.494
Subaccount Inception Date May 1, 2001		2009	$	0.544975	$	0.734336		4,355,761.205
		2008	$	0.921511	$	0.544975		4,700,114.605
		2007	$	0.825357	$	0.921511		6,252,703.104
		2006	$	0.845174	$	0.825357		7,747,363.711
		2005	$	0.748770	$	0.845174		8,815,008.919
		2004	$	0.703224	$	0.748770		9,159,759.000
		2003	$	0.579992	$	0.703224		10,613,051.855
		2002	$	0.853340	$	0.579992		10,310,971.412
		2001	$	1.000000	$	0.853340		4,869,043.939
American Funds – Asset Allocation Fund – Class 2		2010	$	1.007877	$	1.111159		40,368.146
Subaccount Inception Date November 19, 2009		2009	$	0.989775	$	1.007877		0.000
American Funds – Bond Fund – Class 2		2010	$	$0.993587	$	1.036375		522,954.170
Subaccount Inception Date November 19, 2009		2009		1.000896	$	0.993587		0.000
American Funds – Growth Fund – Class 2		2010	$	1.002731	$	1.166156		92,313.929
Subaccount Inception Date November 19, 2009		2009	$	0.986478	$	1.002731		0.000
American Funds – Growth-Income Fund – Class 2		2010	$	1.008123	$	1.100765		0.000
Subaccount Inception Date November 19, 2009		2009	$	0.986799	$	1.008123		0.000
American Funds – International Fund – Class 2		2010	$	0.980247	$	1.030054		181,323.070
Subaccount Inception Date November 19, 2009		2009	$	0.982909	$	0.980247		111,259.592

43

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.903362	$	1.045475		0.000
Subaccount Inception Date May 1, 2008		2009	$	0.664509	$	0.903362		0.000
		2008	$	1.000000	$	0.664509		6,260.607
Fidelity VIP Contrafund ® Portfolio – Service Class 2		2010	$	1.088497	$	1.250872		13,002,185.116
Subaccount Inception Date May 1, 2000		2009	$	0.817570	$	1.088497		16,208,180.974
		2008	$	1.451677	$	0.817570		18,090,305.232
		2007	$	1.259313	$	1.451677		21,776,573.556
		2006	$	1.149842	$	1.259313		25,631,023.153
		2005	$	1.002939	$	1.149842		28,396,875.206
		2004	$	0.886197	$	1.002939		26,517,376.000
		2003	$	0.703369	$	0.886197		24,045,118.452
		2002	$	0.791719	$	0.703369		20,713,389.339
		2001	$	0.920429	$	0.791719		8,751,224.818
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	1.000682	$	1.130196		6,164,274.328
Subaccount Inception Date May 1, 2000		2009	$	0.783929	$	1.000682		8,372,463.849
		2008	$	1.394918	$	0.783929		10,316,128.352
		2007	$	1.401626	$	1.394918		13,253,464.887
		2006	$	1.189107	$	1.401626		13,422,468.304
		2005	$	1.146026	$	1.189107		14,520,800.502
		2004	$	1.048363	$	1.146026		17,140,734.000
		2003	$	0.820348	$	1.048363		17,958,098.374
		2002	$	1.007541	$	0.820348		16,661,283.751
		2001	$	1.081814	$	1.007541		7,093,277.357
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.689383	$	0.839200		4,368,909.827
Subaccount Inception Date May 1, 2001		2009	$	0.548155	$	0.689383		5,402,504.431
		2008	$	1.058601	$	0.548155		5,871,562.339
		2007	$	0.850486	$	1.058601		7,141,878.311
		2006	$	0.811959	$	0.850486		7,587,710.281
		2005	$	0.783046	$	0.811959		9,310,042.981
		2004	$	0.772663	$	0.783046		10,180,607.000
		2003	$	0.593146	$	0.772663		12,168,564.241
		2002	$	0.865865	$	0.593146		9,029,212.659
		2001	$	1.000000	$	0.865865		2,699,493.342
Fidelity VIP Growth Opportunities Portfolio – Service Class 2		2010	$	0.610743	$	0.741133		496,599.807
Subaccount Inception Date May 1, 2000		2009	$	0.427214	$	0.610743		675,784.464
		2008	$	0.969019	$	0.427214		854,771.348
		2007	$	0.802292	$	0.969019		942,826.510
		2006	$	0.776551	$	0.802292		1,146,055.999
		2005	$	0.727019	$	0.776551		1,393,415.346
		2004	$	0.692087	$	0.727019		1,786,743.000
		2003	$	0.544174	$	0.692087		2,070,324.341
		2002	$	0.709957	$	0.544174		2,244,518.530
		2001	$	0.846377	$	0.709957		1,259,394.653
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	1.837552	$	2.321966		10,547,149.711
Subaccount Inception Date May 1, 2000		2009	$	1.337877	$	1.837552		13,556,645.038
		2008	$	2.254217	$	1.337877		15,569,875.501
		2007	$	1.988829	$	2.254217		19,841,907.404
		2006	$	1.800260	$	1.988829		24,571,018.193
		2005	$	1.552048	$	1.800260		29,660,998.063
		2004	$	1.266905	$	1.552048		30,902,013.000
		2003	$	0.932399	$	1.266905		31,291,510.142
		2002	$	1.054427	$	0.932399		28,701,583.575
		2001	$	1.112079	$	1.054427		11,346,046.582

44

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	1.136569	$	1.411244		3,854,987.512
Subaccount Inception Date May 1, 2002		2009	$	0.735889	$	1.136569		4,504,688.020
		2008	$	1.537212	$	0.735889		4,825,439.323
		2007	$	1.483542	$	1.537212		6,057,904.279
		2006	$	1.301136	$	1.483542		6,876,264.562
		2005	$	1.292475	$	1.301136		7,488,217.024
		2004	$	1.155272	$	1.292475		8,785,647.000
		2003	$	0.746970	$	1.155272		8,687,915.216
		2002	$	1.000000	$	0.746970		4,598,590.397
Franklin Income Securities Fund – Class 2		2010	$	0.891915	$	0.987666		4,647,795.648
Subaccount Inception Date May 1, 2007		2009	$	0.669279	$	0.891915		3,835,151.918
		2008	$	0.968163	$	0.669279		2,900,284.769
		2007	$	1.000000	$	0.968163		1,171,282.151
Mutual Shares Securities Fund – Class 2		2010	$	0.736718	$	0.805114		1,171,585.398
Subaccount Inception Date May 1, 2007		2009	$	0.594697	$	0.736718		1,389,244.676
		2008	$	0.962219	$	0.594697		1,150,459.755
		2007	$	1.000000	$	0.962219		1,406,943.475
Templeton Foreign Securities Fund – Class 2		2010	$	0.841717	$	0.896796		2,880,350.480
Subaccount Inception Date May 1, 2007		2009	$	0.624957	$	0.841717		3,905,588.899
		2008	$	1.066624	$	0.624957		1,856,604.448
		2007	$	1.000000	$	1.066624		1,342,336.291
Franklin Templeton VIP Founding Funds Allocation Fund – Class 4		2010	$	1.263591	$	1.367020		129,350.616
Subaccount Inception Date November 10, 2008		2009	$	0.989970	$	1.263591		36,527.095
		2008	$	1.000000	$	0.989970		0.000
GE Investments Total Return Fund – Class 3		2010	$	1.003512	$	1.076511		23,306.242
Subaccount Inception Date November 19, 2009		2009	$	0.988807	$	1.003512		0.000
Janus Aspen – Enterprise Portfolio – Service Shares		2010	$	0.557538	$	0.687794		4,904,695.795
Subaccount Inception Date October 9, 2000		2009	$	0.392742	$	0.557538		6,624,733.831
		2008	$	0.711839	$	0.392742		7,995,672.132
		2007	$	0.594999	$	0.711839		9,943,004.580
		2006	$	0.534291	$	0.594999		9,936,795.222
		2005	$	0.485242	$	0.534291		11,204,073.252
		2004	$	0.409845	$	0.485242		13,276,809.000
		2003	$	0.309434	$	0.409845		13,699,983.571
		2002	$	0.438010	$	0.309434		12,880,112.897
		2001	$	0.737868	$	0.438010		6,477,053.211
Janus Aspen – Perkins Mid Cap Value Portfolio – Service Shares		2010	$	1.295327	$	1.468664		477,871.790
Subaccount Inception Date October 9, 2000		2009	$	0.991570	$	1.295327		829,752.867
		2008	$	1.399365	$	0.991570		956,729.485
		2007	$	1.328695	$	1.399365		1,378,983.991
		2006	$	1.174896	$	1.328695		1,794,366.447
		2005	$	1.086698	$	1.174896		2,272,154.590
		2004	$	0.938690	$	1.086698		3,110,338.000
		2003	$	0.676351	$	0.938690		3,641,262.255
		2002	$	0.898686	$	0.676351		3,947,482.522
		2001	$	0.998150	$	0.898686		2,792,206.981

45

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Janus Aspen – Worldwide Portfolio – Service Shares		2010	$	0.582260	$	0.661071		6,679,197.507
Subaccount Inception Date October 9, 2000		2009	$	0.431170	$	0.582260		8,234,563.434
		2008	$	0.794959	$	0.431170		8,386,491.992
		2007	$	0.739676	$	0.794959		12,472,875.925
		2006	$	0.638122	$	0.739676		13,303,733.989
		2005	$	0.615015	$	0.638122		13,545,548.336
		2004	$	0.598703	$	0.615015		15,805,659.000
		2003	$	0.492540	$	0.598703		18,532,086.151
		2002	$	0.674597	$	0.492540		18,555,207.362
		2001	$	0.887128	$	0.674597		8,916,336.181
MFS ® New Discovery Series – Service Class		2010	$	1.118233	$	1.494005		2,347,305.988
Subaccount Inception Date May 1, 2002		2009	$	0.698378	$	1.118233		2,138,313.327
		2008	$	1.175024	$	0.698378		1,824,606.977
		2007	$	1.169387	$	1.175024		2,136,715.364
		2006	$	1.053572	$	1.169387		2,254,762.453
		2005	$	1.020614	$	1.053572		2,437,777.752
		2004	$	0.977809	$	1.020614		2,693,115.000
		2003	$	0.745636	$	0.977809		3,610,822.460
		2002	$	1.000000	$	0.745636		2,019,746.202
MFS ® Total Return Series – Service Class		2010	$	1.137119	$	1.225231		4,765,880.026
Subaccount Inception Date May 1, 2002		2009	$	0.982825	$	1.137119		5,910,442.024
		2008	$	1.287474	$	0.982825		6,249,561.913
		2007	$	1.260526	$	1.287474		7,156,713.498
		2006	$	1.044258	$	1.260526		7,839,770.204
		2005	$	0.915929	$	1.044258		7,888,743.334
		2004	$	1.000000	$	0.915929		3,457,470.907
		2003	$	0.915929	$	1.044258		7,888,743.334
		2002	$	1.000000	$	0.915929		3,457,470.907
Transamerica Asset Allocation - Conservative VP – Initial Class		2010	$	1.291833	$	1.383020		24,822,178.799
Subaccount Inception Date May 1, 2002		2009	$	1.049665	$	1.291833		30,850,472.484
		2008	$	1.355133	$	1.049665		29,252,549.870
		2007	$	1.296226	$	1.355133		26,772,941.005
		2006	$	1.205026	$	1.296226		28,803,075.550
		2005	$	1.165649	$	1.205026		29,260,957.661
		2004	$	1.081088	$	1.165649		32,662,557.000
		2003	$	0.894928	$	1.081088		32,965,140.953
		2002	$	1.000000	$	0.894928		14,853,733.512
Transamerica Asset Allocation - Growth VP – Initial Class		2010	$	1.164590	$	1.315702		28,907,661.175
Subaccount Inception Date May 1, 2002		2009	$	0.912788	$	1.164590		35,537,169.615
		2008	$	1.538689	$	0.912788		36,966,649.404
		2007	$	1.453068	$	1.538689		42,713,622.006
		2006	$	1.278714	$	1.453068		48,041,894.533
		2005	$	1.159151	$	1.278714		38,664,622.908
		2004	$	1.032962	$	1.159151		27,286,980.000
		2003	$	0.803540	$	1.032962		17,155,866.975
		2002	$	1.000000	$	0.803540		8,833,701.207
Transamerica Asset Allocation - Moderate VP – Initial Class		2010	$	1.291543	$	1.401048		38,621,982.210
Subaccount Inception Date May 1, 2002		2009	$	1.039650	$	1.291543		44,874,505.450
		2008	$	1.428931	$	1.039650		45,575,288.904
		2007	$	1.346920	$	1.428931		50,880,599.546
		2006	$	1.229314	$	1.346920		63,730,003.622
		2005	$	1.164113	$	1.229314		67,363,897.010
		2004	$	1.063371	$	1.164113		70,732,629.000
		2003	$	0.866497	$	1.063371		64,981,989.104
		2002	$	1.000000	$	0.866497		25,372,940.967

46

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation – Moderate Growth VP – Initial Class		2010	$	1.245438	$	1.379816		37,451,008.999
Subaccount Inception Date May 1, 2002		2009	$	0.988804	$	1.245438		44,868,202.662
		2008	$	1.496470	$	0.988804		50,194,533.109
		2007	$	1.412475	$	1.496470		67,211,453.727
		2006	$	1.262473	$	1.412475		76,778,320.596
		2005	$	1.168682	$	1.262473		73,142,192.497
		2004	$	1.047320	$	1.168682		64,168,215.000
		2003	$	0.837975	$	1.047320		51,260,086.194
		2002	$	1.000000	$	0.837975		20,766,948.075
Transamerica BlackRock Large Cap Value VP – Initial Class		2010	$	1.398249	$	1.517740		23,000,971.852
Subaccount Inception Date December 13, 1999		2009	$	1.248110	$	1.398249		16,991,509.272
		2008	$	1.921086	$	1.248110		7,578,002.629
		2007	$	1.868242	$	1.921086		8,657,095.007
		2006	$	1.625748	$	1.868242		10,108,085.653
		2005	$	1.426694	$	1.625748		10,479,700.420
		2004	$	1.226732	$	1.426694		9,371,010.000
		2003	$	0.961763	$	1.226732		10,058,174.263
		2002	$	1.140711	$	0.961763		10,847,793.131
		2001	$	1.182162	$	1.140711		5,175,898.347
Transamerica Clarion Global Real Estate Securities VP – Initial Class		2010	$	1.716019	$	1.950760		2,595,272.929
Subaccount Inception Date May 1, 2002		2009	$	1.308707	$	1.716019		3,249,583.271
		2008	$	2.311196	$	1.308707		4,139,735.641
		2007	$	2.520905	$	2.311196		5,542,876.550
		2006	$	1.802775	$	2.520905		7,890,644.091
		2005	$	1.616436	$	1.802775		7,401,947.752
		2004	$	1.237976	$	1.616436		8,059,439.000
		2003	$	0.927991	$	1.237976		8,970,356.424
		2002	$	1.000000	$	0.927991		5,352,055.101
Transamerica JPMorgan Enhanced Index VP – Initial Class		2010	$	0.743464	$	0.841574		6,066,892.338
Subaccount Inception Date December 13, 1999		2009	$	0.583751	$	0.743464		7,285,528.089
		2008	$	0.948152	$	0.583751		7,131,225.733
		2007	$	0.922959	$	0.948152		8,550,723.193
		2006	$	0.814375	$	0.922959		9,651,493.666
		2005	$	0.800880	$	0.814375		11,949,984.555
		2004	$	0.734037	$	0.800880		17,189,341.000
		2003	$	0.579220	$	0.734037		21,659,391.072
		2002	$	0.781570	$	0.579220		20,984,940.873
		2001	$	0.903591	$	0.781570		9,975,207.899
Transamerica Jennison Growth VP – Initial Class		2010	$	0.679204	$	0.749376		14,376,509.440
Subaccount Inception Date December 13, 1999		2009	$	0.490123	$	0.679204		3,632,896.949
		2008	$	0.791744	$	0.490123		4,053,693.093
		2007	$	0.722484	$	0.791744		5,053,347.713
		2006	$	0.720941	$	0.722484		7,131,594.915
		2005	$	0.644640	$	0.720941		7,852,046.611
		2004	$	0.601086	$	0.644640		8,280,159.000
		2003	$	0.474947	$	0.601086		9,192,783.681
		2002	$	0.697794	$	0.474947		9,798,634.842
		2001	$	0.871768	$	0.697794		4,791,920.564

47

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Morgan Stanley Capital Growth VP – Initial Class(5)		2010	$	1.188908	$	1.489067		8,267,478.868
Subaccount Inception Date December 13, 1999		2009	$	0.945762	$	1.188908		11,345,148.115
		2008	$	1.512364	$	0.945762		12,953,953.811
		2007	$	1.523207	$	1.512364		16,605,082.292
		2006	$	1.307215	$	1.523207		22,491,194.207
		2005	$	1.277918	$	1.307215		27,895,326.630
		2004	$	1.191435	$	1.277918		32,615,294.000
		2003	$	0.896966	$	1.191435		35,939,950.447
		2002	$	1.212295	$	0.896966		35,172,905.550
		2001	$	1.208438	$	1.212295		20,164,471.818
Transamerica AEGON High Yield Bond VP – Initial Class		2010	$	1.376188	$	1.520750		7,168,633.024
Subaccount Inception Date December 13, 1999		2009	$	0.951028	$	1.376188		10,201,118.666
		2008	$	1.293742	$	0.951028		6,839,007.551
		2007	$	1.292548	$	1.293742		8,055,265.676
		2006	$	1.185348	$	1.292548		11,241,956.971
		2005	$	1.184549	$	1.185348		14,166,085.099
		2004	$	1.098078	$	1.184549		19,153,510.000
		2003	$	0.948940	$	1.098078		20,883,651.999
		2002	$	0.945935	$	0.948940		16,339,103.470
		2001	$	0.927487	$	0.945935		7,396,347.346
Transamerica MFS International Equity VP – Initial Class		2010	$	1.052133	$	1.142585		5,188,191.255
Subaccount Inception Date May 1, 2001		2009	$	0.806842	$	1.052133		7,524,065.426
		2008	$	1.268785	$	0.806842		9,325,225.932
		2007	$	1.182850	$	1.268785		11,596,711.314
		2006	$	0.977904	$	1.182850		13,963,877.718
		2005	$	0.881555	$	0.977904		13,748,170.277
		2004	$	0.784500	$	0.881555		14,443,837.000
		2003	$	0.637090	$	0.784500		14,832,851.149
		2002	$	0.831278	$	0.637090		4,005,557.405
		2001	$	1.000000	$	0.831278		565,398.002
Transamerica PIMCO Total Return VP – Initial Class		2010	$	1.335418	$	1.406874		17,615,337.326
Subaccount Inception Date May 1, 2002		2009	$	1.171002	$	1.335418		20,380,519.261
		2008	$	1.225779	$	1.171002		18,259,032.821
		2007	$	1.144889	$	1.225779		17,090,597.296
		2006	$	1.117804	$	1.144889		19,578,765.051
		2005	$	1.111425	$	1.117804		21,409,674.847
		2004	$	1.082286	$	1.111425		22,596,294.000
		2003	$	1.049753	$	1.082286		24,866,413.872
		2002	$	1.000000	$	1.049753		22,382,341.571
Transamerica T. Rowe Price Small Cap VP – Initial Class		2010	$	0.939590	$	1.241340		6,818,061.362
Subaccount Inception Date December 13, 1999		2009	$	0.689272	$	0.939590		8,213,833.581
		2008	$	1.100262	$	0.689272		9,233,445.111
		2007	$	1.021465	$	1.100262		11,562,374.402
		2006	$	1.003308	$	1.021465		14,893,054.114
		2005	$	0.922895	$	1.003308		19,428,189.321
		2004	$	0.850879	$	0.922895		21,282,748.000
		2003	$	0.616618	$	0.850879		24,243,423.670
		2002	$	0.863607	$	0.616618		17,338,733.363
		2001	$	0.973385	$	0.863607		5,846,435.230

48

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica WMC Diversified Equity VP – Initial Class(6)		2010	$	0.617813	$	0.709488		14,845,521.258
Subaccount Inception Date December 13, 1999		2009	$	0.489877	$	0.617813		15,108,512.702
		2008	$	0.885000	$	0.489877		3,167,327.327
		2007	$	0.781445	$	0.885000		4,576,820.509
		2006	$	0.669319	$	0.781445		5,850,855.837
		2005	$	0.633666	$	0.669319		6,224,099.268
		2004	$	0.745472	$	0.633666		1,784,880.000
		2003	$	0.598527	$	0.745472		2,842,327.915
		2002	$	0.775925	$	0.598527		2,313,843.058
		2001	$	0.949462	$	0.775925		1,500,180.507
Transamerica Multi-Managed Balanced VP – Initial Class(1)		2010	$	1.201741	$	1.465974		2,395,890.050
Subaccount Inception Date May 1, 2002		2009	$	0.968166	$	1.201741		3,091,359.215
		2008	$	1.457383	$	0.968166		4,117,756.172
		2007	$	1.305417	$	1.457383		4,541,690.885
		2006	$	1.217144	$	1.305417		3,716,516.400
		2005	$	1.147047	$	1.217144		3,965,041.520
		2004	$	1.050040	$	1.147047		4,315,546.000
		2003	$	0.938053	$	1.050040		4,391,224.959
		2002	$	1.000000	$	0.938053		2,548,131.921
Transamerica AllianceBernstein Dynamic Allocation VP – Initial Class(4)		2010	$	1.293427	$	1.389283		1,892,653.157
Subaccount Inception Date May 1, 2002		2009	$	1.002342	$	1.293427		2,406,431.125
		2008	$	1.615723	$	1.002342		2,841,610.874
		2007	$	1.385886	$	1.615723		3,404,235.335
		2006	$	1.271504	$	1.385886		3,360,178.313
		2005	$	1.245338	$	1.271504		3,171,680.981
		2004	$	1.119642	$	1.245338		3,279,033.000
		2003	$	0.921246	$	1.119642		2,403,716.541
		2002	$	1.000000	$	0.921246		739,462.454
Transamerica WMC Diversified Growth VP – Initial Class		2010	$	0.869099	$	1.006288		18,593,720.001
Subaccount Inception Date December 13, 1999		2009	$	0.684479	$	0.869099		24,206,819.003
		2008	$	1.289990	$	0.684479		27,184,155.405
		2007	$	1.128847	$	1.289990		32,577,682.372
		2006	$	1.056485	$	1.128847		42,371,477.438
		2005	$	0.922387	$	1.056485		39,909,716.070
		2004	$	0.810465	$	0.922387		46,826,015.000
		2003	$	0.628416	$	0.810465		39,342,889.868
		2002	$	0.822338	$	0.628416		38,256,209.552
		2001	$	1.015903	$	0.822338		21,634,764.125
Transamerica Morgan Stanley Growth Opportunities VP – Initial Class(7)		2010	$	1.533618	$	2.044778		3,599,864.635
Subaccount Inception Date May 1, 2001		2009	$	1.140181	$	1.533618		4,348,437.072
		2008	$	1.963369	$	1.140181		4,859,331.401
		2007	$	1.623189	$	1.963369		6,960,391.891
		2006	$	1.571345	$	1.623189		8,108,529.918
		2005	$	1.375532	$	1.571345		10,164,528.619
		2004	$	1.200115	$	1.375532		12,108,881.000
		2003	$	0.930632	$	1.200115		5,943,084.538
		2002	$	1.105094	$	0.930632		5,465,071.476
		2001	$	1.000000	$	1.105094		1,379,589.734

49

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica AEGON Money Market VP – Initial Class(2)		2010	$	1.106389	$	1.087410		11,255,955.160
Subaccount Inception Date December 13, 1999		2009	$	1.124315	$	1.106389		14,873,278.129
		2008	$	1.117314	$	1.124315		28,475,015.958
		2007	$	1.082524	$	1.117314		19,430,866.337
		2006	$	1.051661	$	1.082524		17,799,600.207
		2005	$	1.040022	$	1.051661		17,490,659.780
		2004	$	1.047750	$	1.040022		19,891,078.000
		2003	$	1.058245	$	1.047750		29,588,769.425
Transamerica Systematic Small/Mid Cap Value VP – Initial Class(8)		2010	$	2.471404	$	3.167660		5,547,475.560
Subaccount Inception Date December 13, 1999		2009	$	1.755887	$	2.471404		7,834,932.207
		2008	$	3.021574	$	1.755887		9,060,430.899
		2007	$	2.464912	$	3.021574		11,477,502.270
		2006	$	2.124396	$	2.464912		14,972,574.463
		2005	$	1.903339	$	2.124396		18,886,604.856
		2004	$	1.664631	$	1.903339		22,149,074.000
		2003	$	0.887551	$	1.664631		25,525,830.375
		2002	$	1.491874	$	0.887551		28,239,277.961
		2001	$	1.178786	$	1.491874		15,648,828.340
Transamerica AEGON U.S. Government Securities VP – Initial Class(3)		2010	$	1.358931	$	1.394365		10,439,393.109
Subaccount Inception Date December 13, 1999		2009	$	1.323586	$	1.358931		14,372,031.268
		2008	$	1.250969	$	1.323586		16,984,896.137
		2007	$	1.200371	$	1.250969		12,394,724.854
		2006	$	1.182629	$	1.200371		14,201,371.418
		2005	$	1.177019	$	1.182629		18,889,640.170
		2004	$	1.159469	$	1.177019		23,548,741.000
		2003	$	1.145993	$	1.159469		31,447,306.458
		2002	$	1.101974	$	1.145993		33,853,368.099
		2001	$	1.066980	$	1.101974		17,111,632.532
Transamerica Morgan Stanley Active International Allocation VP – Initial		2010	$	0.914996	$	0.975533		5,617,015.673
Class		2009	$	0.739576	$	0.914996		7,207,256.903
Subaccount Inception Date December 13, 1999		2008	$	1.230349	$	0.739576		9,537,103.319
		2007	$	1.083006	$	1.230349		12,427,484.982
		2006	$	0.892178	$	1.083006		13,767,904.805
		2005	$	0.797730	$	0.892178		12,999,886.637
		2004	$	0.699515	$	0.797730		9,093,759.000
		2003	$	0.535920	$	0.699515		6,993,256.084
		2002	$	0.656772	$	0.535920		6,917,367.160
		2001	$	0.867514	$	0.656772		3,968,986.008
Transamerica Multi Managed Large Cap Core VP – Initial Class		2010	$	0.968299	$	1.134103		11,740,561.116
Subaccount Inception Date December 13, 1999		2009	$	0.677560	$	0.968299		15,949,069.158
		2008	$	1.190446	$	0.677560		8,752,720.003
		2007	$	1.108831	$	1.190446		10,616,230.580
		2006	$	1.022523	$	1.108831		13,385839.290
		2005	$	0.950838	$	1.022523		16,899,056.152
		2004	$	0.858084	$	0.950838		21,914,585.000
		2003	$	0.721061	$	0.858084		23,358,311.939
		2002	$	0.877419	$	0.721061		24,379,905.704
		2001	$	0.960707	$	0.877419		16,918,734.305

50

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.75%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Morgan Stanley Mid-Cap Growth VP – Initial Class		2010	$	0.803530	$	1.057448		4,753,046.522
Subaccount Inception Date May 1, 2001		2009	$	0.509211	$	0.803530		5,976,942.327
		2008	$	0.964743	$	0.509211		6,059,275.946
		2007	$	0.801180	$	0.964743		7,343,228.873
		2006	$	0.741699	$	0.801180		8,809,235.436
		2005	$	0.701676	$	0.741699		9,935,220.086
		2004	$	0.666395	$	0.701676		11,640,075.000
		2003	$	0.529075	$	0.666395		12,836,754.604
		2002	$	0.000	$	0.529075		11,355,552.501
		2001	$	1.000000	$	0.000		3,799,921.981
			1.65%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation – Conservative VP – Service Class		2010	$	0.978341	$	1.046260		20,268,977.243
Subaccount Inception Date May 1, 2002		2009	$	0.796207	$	0.978341		17,691,024.936
		2008	$	1.000000	$	0.796207		6,317,972.100
Transamerica Asset Allocation – Growth VP – Service Class		2010	$	0.850553	$	0.959330		2,261,206.486
Subaccount Inception Date May 1, 2002		2009	$	0.667413	$	0.850553		1,729,222.633
		2008	$	1.000000	$	0.667413		895,632.249
Transamerica Asset Allocation – Moderate VP – Service Class		2010	$	0.951968	$	1.031459		35,787,581.147
Subaccount Inception Date May 1, 2002		2009	$	0.766792	$	0.951968		25,374,840.520
		2008	$	1.000000	$	0.766792		14,525,044.665
Transamerica Asset Allocation – Moderate Growth VP – Service Class		2010	$	0.903290	$	0.998859		57,070,907.875
Subaccount Inception Date May 1, 2002		2009	$	0.718064	$	0.903290		50,262,960.232
		2008	$	1.000000	$	0.718064		33,447,209.633
Transamerica International Moderate Growth VP – Service Class		2010	$	0.873506	$	0.947340		12,033,169.330
Subaccount Inception Date May 1, 2006		2009	$	0.686559	$	0.873506		10,487,008.376
		2008	$	1.000000	$	0.686559		8,377,050.110
Transamerica BlackRock Global Allocation VP – Service Class		2010	$	1.201990	$	1.296818		16,341,040.280
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.201990		4,527,629.053
Transamerica BlackRock Large Cap Value VP – Service Class		2010	$	0.817361	$	0.885726		2,412,135.173
Subaccount Inception Date December 13, 1999		2009	$	0.730649	$	0.817361		777,882.140
		2008	$	1.000000	$	0.730649		23,530.102
Transamerica BlackRock Tactical Allocation VP – Service Class		2010	$	1.205764	$	1.319555		3,963,821.864
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.205764		1,527,902.709
Transamerica Clarion Global Real Estate Securities VP – Service Class		2010	$	0.827221	$	0.938309		971,649.818
Subaccount Inception Date May 1, 2002		2009	$	0.632208	$	0.827221		325,401.525
		2008	$	1.000000	$	0.632208		530.541
Transamerica Foxhall Emerging Markets/Pacific Rim VP – Service Class		2010	$	1.009144	$	1.026295		2,766,088.312
Subaccount Inception Date November 19, 2009		2009	$	0.990713	$	1.009144		182,413.682
Transamerica Foxhall Global Conservative VP – Service Class		2010	$	0.983439	$	0.908509		1,390,492.289
Subaccount Inception Date November 19, 2009		2009	$	0.995068	$	0.983439		50,992.905
Transamerica Foxhall Global Growth VP – Service Class		2010	$	1.006302	$	1.043306		2,018,227.889
Subaccount Inception Date November 19, 2009		2009	$	0.988966	$	1.006302		81,654.637
Transamerica Foxhall Global Commodities & Hard Asset VP – Service
Class(9)		2010	$	0.985671	$	0.999750		2,216,792.820
Subaccount Inception Date November 19, 2009		2009	$	0.986571	$	0.985671		14,201.885
Transamerica Hanlon Balanced VP – Service Class		2010	$	1.020496	$	0.969182		2,108,415.599
Subaccount Inception Date November 19, 2009		2009	$	0.998158	$	1.020496		59,412.021

51

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.65%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Hanlon Growth VP – Service Class		2010	$	1.021163	$	0.997506		2,272,210.456
Subaccount Inception Date November 19, 2009		2009	$	0.996396	$	1.021163		329,288.979
Transamerica Hanlon Growth and Income VP – Service Class		2010	$	1.022242	$	0.984370		1,834,827.735
Subaccount Inception Date November 19, 2009		2009	$	0.997265	$	1.022242		146,051.847
Transamerica Hanlon Managed Income VP – Service Class		2010	$	1.003508	$	0.988365		14,885,607.799
Subaccount Inception Date November 19, 2009		2009	$	0.999955	$	1.003508		1,174,430.267
Transamerica JPMorgan Enhanced Index VP – Service Class		2010	$	0.878213	$	0.992292		74,420.203
Subaccount Inception Date December 13, 1999		2009	$	0.690332	$	0.878213		39,182.013
		2008	$	1.000000	$	0.690332		0.000
Transamerica JPMorgan Mid Cap Value VP – Service Class		2010	$	1.029468	$	1.243896		247,805.380
Subaccount Inception Date November 19, 2009		2009	$	0.985154	$	1.029468		0.000
Transamerica Jennison Growth VP– Service Class		2010	$	0.968717	$	1.067109		1,112,735.747
Subaccount Inception Date December 13, 1999		2009	$	0.699909	$	0.968717		109,013.450
		2008	$	1.000000	$	0.699909		0.000
Transamerica Morgan Stanley Capital Growth VP – Service Class(5)		2010	$	0.864855	$	1.081284		91,068.254
Subaccount Inception Date December 13, 1999		2009	$	0.689156	$	0.864855		33,589.132
		2008	$	1.000000	$	0.689156		0.000
Transamerica AEGON High Yield Bond VP – Service Class		2010	$	1.089989	$	1.202779		1,095,580.651
Subaccount Inception Date December 13, 1999		2009	$	0.754457	$	1.089989		362,124.837
		2008	$	1.000000	$	0.754457		0.000
Transamerica MFS International Equity VP – Service Class		2010	$	0.927994	$	1.007030		633,007.676
Subaccount Inception Date May 1, 2001		2009	$	0.713341	$	0.927994		318,535.330
		2008	$	1.000000	$	0.713341		30,244.316
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.048199	$	1.102698		8,930,040.986
Subaccount Inception Date May 1, 2002		2009	$	0.920505	$	1.048199		4,737,769.663
		2008	$	1.000000	$	0.920505		2,016,890.588
Transamerica T. Rowe Price Small Cap VP – Service Class		2010	$	0.973095	$	1.283366		944,657.482
Subaccount Inception Date December 13, 1999		2009	$	0.715068	$	0.973095		374,580.217
		2008	$	1.000000	$	0.715068		18,914.294
Transamerica WMC Diversified Equity VP – Service Class(6)		2010	$	0.788478	$	0.904041		1,495,716.865
Subaccount Inception Date December 13, 1999		2009	$	0.626917	$	0.788478		276,265.012
		2008	$	1.000000	$	0.626917		3,112.476
Transamerica Efficient Markets VP – Service Class		2010	$	1.201944	$	1.328803		1,277,032.689
Subaccount Inception Date November 10, 2008		2009	$	1.036627	$	1.201944		869,153.816
		2008	$	1.000000	$	1.036627		0.000
Transamerica Multi-Managed Balanced VP – Service Class(1)		2010	$	0.910713	$	1.109926		3,460,805.232
Subaccount Inception Date May 1, 2002		2009	$	0.735067	$	0.910713		1,388,276.554
		2008	$	1.000000	$	0.735067		757,454.415
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class(4)		2010	$	0.884529	$	0.949802		857,226.226
Subaccount Inception Date May 1, 2002		2009	$	0.685489	$	0.884529		54,433.003
		2008	$	1.000000	$	0.685489		2,442.079
Transamerica WMC Diversified Growth VP – Service Class		2010	$	0.771968	$	0.892217		958,887.843
Subaccount Inception Date December 13, 1999		2009	$	0.608782	$	0.771968		257,463.120
		2008	$	1.000000	$	0.608782		0.000
Transamerica Morgan Stanley Growth Opportunities VP – Service Class(7)		2010	$	0.891852	$	1.186968		552,442.886
Subaccount Inception Date May 1, 2001		2009	$	0.664066	$	0.891852		245,062.151
		2008	$	1.000000	$	0.664066		0.000

52

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.65%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica AEGON Money Market VP – Service Class(2)		2010	$	0.987430	$	0.971427		4,583,578.385
Subaccount Inception Date December 13, 1999		2009	$	1.003592	$	0.987430		4,757,321.363
		2008	$	1.000000	$	1.003592		1,499,328.840
Transamerica Systematic Small/Mid Cap Value VP – Service Class(8)		2010	$	0.928586	$	1.188049		1,739,597.689
Subaccount Inception Date December 13, 1999		2009	$	0.660541	$	0.928586		603,184.517
		2008	$	1.000000	$	0.660541		23,183.638
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.059101	$	1.085909		7,655,931.765
Subaccount Inception Date December 13, 1999		2009	$	1.033204	$	1.059101		3,438,793.688
		2008	$	1.000000	$	1.033204		872,719.436
Transamerica Index 35 VP – Service Class		2010	$	0.998075	$	1.074408		1,600,059.091
Subaccount Inception Date November 19, 2009		2009	$	0.999955	$	0.998075		33,287.399
Transamerica Index 50 VP – Service Class		2010	$	0.936613	$	1.019934		2,795,250.055
Subaccount Inception Date May 1, 2008		2009	$	0.817007	$	0.936613		1,866,428.019
		2008	$	1.000000	$	0.817007		257,385.854
Transamerica Index 75 VP – Service Class		2010	$	0.873783	$	0.971384		9,362,116.258
Subaccount Inception Date May 1, 2008		2009	$	0.721052	$	0.873783		7,061,328.811
		2008	$	1.000000	$	0.721052		1,346,647.630
Transamerica Index 100 VP – Service Class		2010	$	1.024027	$	1.152543		415,423.577
Subaccount Inception Date November 19, 2009		2009	$	0.999955	$	1.024027		0.000
Transamerica ProFunds UltraBear Fund – Service Class OAM		2010	$	0.561781	$	0.404748		303,046.526
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	0.561781		0.000
Transamerica Morgan Stanley Active International Allocation VP – Service		2010	$	0.839096	$	0.893198		425,794.831
Class		2009	$	0.678678	$	0.839096		137,649.624
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	0.678678		518.125
Transamerica Multi Managed Large Cap Core VP – Service Class		2010	$	0.913226	$	1.067975		274,330.075
Subaccount Inception Date December 13, 1999		2009	$	0.639823	$	0.913226		146,501.644
		2008	$	1.000000	$	0.639823		3,016.574
Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class		2010	$	0.962999	$	1.265509		1,012,267.649
Subaccount Inception Date May 1, 2001		2009	$	0.611350	$	0.962999		357,942.739
		2008	$	1.000000	$	0.611350		0.000
PAM Transamerica AEGON U.S. Government Securities VP – Service		2010	$	1.059101	$	1.085909		126,322.027
Class(3)		2009	$	1.033204	$	1.059101		192,922.883
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	1.033204		241,308.630
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.770752	$	0.810903		482,100.256
Subaccount Inception Date May 1, 2002		2009	$	0.530309	$	0.770752		461,312.957
		2008	$	1.000000	$	0.530309		0.000
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.776617	$	0.880190		748,443.632
Subaccount Inception Date May 1, 2002		2009	$	0.653945	$	0.776617		239,991.182
		2008	$	1.000000	$	0.653945		0.000
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.237531	$	1.340179		982,285.304
Subaccount Inception Date November 10, 2008		2009	$	1.012783	$	1.237531		343,252.727
		2008	$	1.000000	$	1.012783		33,981.111
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.769663	$	0.854090		888,775.150
Subaccount Inception Date May 1, 2001		2009	$	0.650077	$	0.769663		314,977.334
		2008	$	1.000000	$	0.650077		23,648.102
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.918167	$	0.992081		821,098.493
Subaccount Inception Date May 1, 2001		2009	$	0.680726	$	0.918167		471,473.071
		2008	$	1.000000	$	0.680726		0.000

53

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.65%
Subaccount			Beginning AUV		Ending AUV		# Units
American Funds - Asset Allocation Fund – Class 2		2010	$	1.007990	$	1.112364		1,192,409.561
Subaccount Inception Date November 19, 2009		2009	$	0.989778	$	1.007990		15,818.325
American Funds - Bond Fund – Class 2		2010	$	0.993701	$	1.037506		1,505,132.018
Subaccount Inception Date November 19, 2009		2009	$	1.000899	$	0.993701		0.000
American Funds - Growth Fund – Class 2		2010	$	1.002849	$	1.167433		890,602.425
Subaccount Inception Date November 19, 2009		2009	$	0.986481	$	1.002849		281,783.138
American Funds - Growth-Income Fund – Class 2		2010	$	1.008240	$	1.101971		495,504.155
Subaccount Inception Date November 19, 2009		2009	$	0.986802	$	1.008240		0.000
American Funds - International Fund – Class 2		2010	$	0.980359	$	1.031180		970,606.398
Subaccount Inception Date November 19, 2009		2009	$	0.982911	$	0.980359		126,577.713
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.904846	$	1.048229		2,051,668.484
Subaccount Inception Date May 1, 2008		2009	$	0.664950	$	0.904846		1,251,635.854
		2008	$	1.000000	$	0.664950		806,851.377
Fidelity VIP Contrafund ® Portfolio – Service Class 2		2010	$	0.855116	$	0.983643		1,504,501.260
Subaccount Inception Date May 1, 2000		2009	$	0.641644	$	0.855116		540,405.483
		2008	$	1.000000	$	0.641644		75,231.171
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	0.813769	$	0.919991		225,590.351
Subaccount Inception Date May 1, 2000		2009	$	0.636875	$	0.813769		61,789.436
		2008	$	1.000000	$	0.636875		8,502.933
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.748153	$	0.911651		249,152.998
Subaccount Inception Date May 1, 2001		2009	$	0.594306	$	0.748153		159,331.420
		2008	$	1.000000	$	0.594306		20,760.341
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	0.923603	$	1.168241		1,365,640.190
Subaccount Inception Date May 1, 2000		2009	$	0.671795	$	0.923603		466,293.016
		2008	$	1.000000	$	0.671795		9,267.438
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	0.864938	$	1.075026		796,984.730
Subaccount Inception Date May 1, 2002		2009	$	0.559463	$	0.864938		406,673.969
		2008	$	1.000000	$	0.559463		8,638.591
Franklin Income Securities Fund – Class 2		2010	$	0.973455	$	1.079026		940,960.968
Subaccount Inception Date May 1, 2007		2009	$	0.729760	$	0.973455		343,481.466
		2008	$	1.000000	$	0.729760		160,393.849
Mutual Shares Securities Fund – Class 2		2010	$	0.846299	$	0.925781		614,043.597
Subaccount Inception Date May 1, 2007		2009	$	0.682487	$	0.846299		282,019.503
		2008	$	1.000000	$	0.682487		10,180.512
Templeton Foreign Securities Fund – Class 2		2010	$	0.889448	$	0.948576		1,159,390.709
Subaccount Inception Date May 1, 2007		2009	$	0.659735	$	0.889448		427,852.169
		2008	$	1.000000	$	0.659735		1,855.065
Franklin Templeton VIP Founding Funds Allocation Fund – Class 4		2010	$	1.265010	$	1.369903		2,989,385.476
Subaccount Inception Date November 10, 2008		2009	$	0.990107	$	1.265010		1,280,870.047
		2008	$	1.000000	$	0.990107		0.000
GE Investments Total Return Fund – Class 3		2010	$	1.003631	$	1.077697		279,431.129
Subaccount Inception Date November 19, 2009		2009	$	0.988810	$	1.003631		0.000
Janus Aspen – Enterprise Portfolio – Service Shares		2010	$	0.903633	$	1.115844		438,198.267
Subaccount Inception Date October 9, 2000		2009	$	0.635920	$	0.903633		92,831.226
		2008	$	1.000000	$	0.635920		1,178.810
Janus Aspen – Worldwide Portfolio – Service Shares		2010	$	0.831468	$	0.944924		813,292.713
Subaccount Inception Date October 9, 2000		2009	$	0.615104	$	0.831468		264,596.921
		2008	$	1.000000	$	0.615104		22,805.490

54

CONDENSED FINANCIAL INFORMATION — (Continued)

	Year		1.65%
Subaccount			Beginning AUV		Ending AUV		# Units
MFS ® New Discovery Series – Service Class		2010	$	1.097886	$	1.468263		757,274.730
Subaccount Inception Date May 1, 2002		2009	$	0.684986	$	1.097886		330,809.912
		2008	$	1.000000	$	0.684986		0.000
MFS ® Total Return Series – Service Class		2010	$	0.936049	$	1.009566		1,040,140.445
Subaccount Inception Date May 1, 2002		2009	$	0.808242	$	0.936049		255,237.229
		2008	$	1.000000	$	0.808242		2,698.359
	Year		1.55%
Subaccount			Beginning AUV		Ending AUV		# Units
Transamerica Asset Allocation - Conservative VP – Initial Class		2010	$	1.311504	$	1.406840		2,275,557.711
Subaccount Inception Date May 1, 2002		2009	$	1.063539	$	1.311504		45,002.562
		2008	$	1.370333	$	1.063539		26,869.950
		2007	$	1.308178	$	1.370333		29,587.249
		2006	$	1.213762	$	1.308178		204,064.232
		2005	$	1.171794	$	1.213762		0.000
		2004	$	1.084641	$	1.171794		228,564.376
		2003	$	0.896108	$	1.084641		315,412.392
		2002	$	1.000000	$	0.896108		119,764.901
Transamerica Asset Allocation - Growth VP – Initial Class		2010	$	1.182285	$	1.338317		4,261,574.327
Subaccount Inception Date May 1, 2002		2009	$	0.924844	$	1.182285		61,344.854
		2008	$	1.555945	$	0.924844		84,805.080
		2007	$	1.466466	$	1.555945		93,704.023
		2006	$	1.287977	$	1.466466		85,317.958
		2005	$	1.165251	$	1.287977		93,689.817
		2004	$	1.036347	$	1.165251		93,961.322
		2003	$	0.804600	$	1.036347		45,928.750
		2002	$	1.000000	$	0.804600		174.81
Transamerica Asset Allocation - Moderate VP – Initial Class		2010	$	1.311197	$	1.425170		3,850,644.854
Subaccount Inception Date May 1, 2002		2009	$	1.053395	$	1.311197		273,350.542
		2008	$	1.444964	$	1.053395		310,318.177
		2007	$	1.359333	$	1.444964		300,983.353
		2006	$	1.238214	$	1.359333		127,310.594
		2005	$	1.170234	$	1.238214		134,300.445
		2004	$	1.066862	$	1.170234		241,302.481
		2003	$	0.867636	$	1.066862		116,942.124
		2002	$	1.000000	$	0.867636		99.89
Transamerica Asset Allocation - Moderate Growth VP – Initial Class		2010	$	1.264418	$	1.403599		4,929,986.894
Subaccount Inception Date May 1, 2002		2009	$	1.001893	$	1.264418		122,122.339
		2008	$	1.513286	$	1.001893		138,904.100
		2007	$	1.425519	$	1.513286		137,170.026
		2006	$	1.271629	$	1.425519		254,339.275
		2005	$	1.174845	$	1.271629		211,079.827
		2004	$	1.050773	$	1.174845		247,111.638
		2003	$	0.839081	$	1.050773		264,074.877
		2002	$	1.000000	$	0.839081		187,026.692
Transamerica International Moderate Growth VP – Service Class		2010	$	0.879106	$	0.954359		188,522.923
Subaccount Inception Date May 1, 2006		2009	$	0.690284	$	0.879106		15,043.256
		2008	$	1.100802	$	0.690284		79,356.005
		2007	$	1.030435	$	1.100802		81,135.694
		2006	$	1.000000	$	1.030435		0.000

55

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica BlackRock Large Cap Value VP – Initial Class		2010	$	1.174261	$	1.277119		6,618,554.023
Subaccount Inception Date December 13, 1999		2009	$	1.046107	$	1.174261		22,601.082
		2008	$	1.606977	$	1.046107		30,887.685
		2007	$	1.559685	$	1.606977		57,467.103
		2006	$	1.354580	$	1.559685		40,039.099
		2005	$	1.186405	$	1.354580		48,947.675
		2004	$	1.018118	$	1.186405		52,492.353
		2003	$	0.796637	$	1.018118		63,136.781
		2002	$	0.943003	$	0.796637		176,528.167
		2001	$	1.000000	$	0.943003		108,846.802
Transamerica BlackRock Tactical Allocation VP - Service Class		2010	$	1.003130	$	1.098884		239,561.723
Subaccount Inception Date May 1, 2009		2009	$	0.993363	$	1.003130		0.000
Transamerica Clarion Global Real Estate Securities VP – Initial Class		2010	$	1.742145	$	1.984355		507,387.272
Subaccount Inception Date May 1, 2002		2009	$	1.326025	$	1.742145		28,810.718
		2008	$	2.337148	$	1.326025		21,356.723
		2007	$	2.544168	$	2.337148		19,126.450
		2006	$	1.815856	$	2.544168		23,753.763
		2005	$	1.624970	$	1.815856		25,340.630
		2004	$	1.242059	$	1.624970		1,583.126
		2003	$	0.929213	$	1.242059		0.000
		2002	$	1.000000	$	0.929213		27,593.023
Transamerica Index 35 VP – Service Class		2010	$	0.998190	$	1.075590		11,517.449
Subaccount Inception Date November 19, 2009		2009	$	0.999958	$	0.998190		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.996117	$	1.085798		0.000
Subaccount Inception Date May 1, 2008		2009	$	0.991642	$	0.996117		0.000
Transamerica Index 75 VP – Service Class		2010	$	0.999308	$	1.112020		0.000
Subaccount Inception Date May 1, 2008		2009	$	0.988772	$	0.999308		0.000
Transamerica Index 100 VP – Service Class		2010	$	1.024147	$	1.153818		13,579.893
Subaccount Inception Date November 19, 2009		2009	$	0.999958	$	1.024147		0.000
Transamerica JPMorgan Enhanced Index VP – Initial Class		2010	$	0.867071	$	0.983426		893,333.970
Subaccount Inception Date December 13, 1999		2009	$	0.679456	$	0.867071		32,839.314
		2008	$	1.101409	$	0.679456		36,038.078
		2007	$	1.070028	$	1.101409		99,646.892
		2006	$	0.942288	$	1.070028		103,756.955
		2005	$	0.924871	$	0.942288		106,292.400
		2004	$	0.846025	$	0.924871		111,064.953
		2003	$	0.666282	$	0.846025		261,994.931
		2002	$	0.897283	$	0.666282		125,360.672
		2001	$	1.000000	$	0.897283		55,879.243
Transamerica JPMorgan Mid Cap Value VP – Service Class		2010	$	1.029587	$	1.245265		125,465.611
Subaccount Inception Date November 19, 2009		2009	$	0.985157	$	1.029587		0.000
Transamerica Jennison Growth VP – Initial Class		2010	$	0.861605	$	0.952491		2,042,902.950
Subaccount Inception Date December 13, 1999		2009	$	0.620523	$	0.861605		0.000
		2008	$	1.000404	$	0.620523		0.000
		2007	$	0.911090	$	1.000404		64,713.714
		2006	$	0.907366	$	0.911090		104,636.353
		2005	$	0.809746	$	0.907366		109,866.924
		2004	$	0.753552	$	0.809746		112,217.423
		2003	$	0.594247	$	0.753552		132,398.534
		2002	$	0.871348	$	0.594247		151,808.208
		2001	$	1.000000	$	0.871348		47,415.782

56

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Morgan Stanley Capital Growth VP – Initial Class(5)		2010	$	0.940772	$	1.180595		2,740,881.423
Subaccount Inception Date December 13, 1999		2009	$	0.746900	$	0.940772		53,936.120
		2008	$	1.192002	$	0.746900		58,765.279
		2007	$	1.198165	$	1.192002		93,204.669
		2006	$	1.026242	$	1.198165		115,162.357
		2005	$	1.001272	$	1.026242		169,179.072
		2004	$	0.931671	$	1.001272		173,787.963
		2003	$	0.700028	$	0.931671		180,259.408
		2002	$	0.944258	$	0.700028		229,142.2322
		2001	$	1.000000	$	0.944258		73,305.802
Transamerica AEGON High Yield Bond VP – Initial Class		2010	$	1.446340	$	1.601420		1,910,700.926
Subaccount Inception Date December 13, 1999		2009	$	0.997541	$	1.446340		51,556.168
		2008	$	1.354337	$	0.997541		58,145.551
		2007	$	1.350404	$	1.354337		82,864.697
		2006	$	1.235967	$	1.350404		85,452.834
		2005	$	1.232722	$	1.235967		94,255.252
		2004	$	1.140477	$	1.232722		96,144.530
		2003	$	0.983646	$	1.140477		117,636.817
		2002	$	0.978607	$	0.983646		153,982.191
		2001	$	1.000000	$	0.978607		72,409.466
Transamerica MFS International Equity VP – Initial Class		2010	$	1.070292	$	1.164590		1,089,756.584
Subaccount Inception Date May 1, 2001		2009	$	0.819162	$	1.070292		542.187
		2008	$	1.285611	$	0.819162		24,420.537
		2007	$	1.196166	$	1.285611		29,936.315
		2006	$	0.986968	$	1.196166		4,312.190
		2005	$	0.887981	$	0.986968		4,540.364
		2004	$	0.788649	$	0.887981		21,162.965
		2003	$	0.639197	$	0.788649		68,802.504
		2002	$	0.832379	$	0.639197		29,251.177
		2001	$	1.000000	$	0.832379		26,567.211
Transamerica PIMCO Total Return VP – Initial Class		2010	$	1.355748	$	1.431103		2,606,768.225
Subaccount Inception Date May 1, 2002		2009	$	1.186501	$	1.355748		90,298.069
		2008	$	1.239554	$	1.186501		76,256.240
		2007	$	1.155465	$	1.239554		81,646.518
		2006	$	1.125921	$	1.155465		100,871.964
		2005	$	1.117299	$	1.125921		106,254.623
		2004	$	1.085852	$	1.117299		89,921.168
		2003	$	1.051137	$	1.085852		90,351.146
		2002	$	1.000000	$	1.051137		106,777.025
Transamerica T. Rowe Price Small Cap VP – Initial Class		2010	$	1.054538	$	1.395945		887,604.387
Subaccount Inception Date December 13, 1999		2009	$	0.772071	$	1.054538		248.350
		2008	$	1.229984	$	0.772071		197.148
		2007	$	1.139640	$	1.229984		22,090.270
		2006	$	1.117184	$	1.139640		21,916.378
		2005	$	1.025631	$	1.117184		21,916.378
		2004	$	0.943746	$	1.025631		21,916.378
		2003	$	0.682575	$	0.943746		39,498.278
		2002	$	0.954095	$	0.682575		998.912
		2001	$	1.000000	$	0.954095		1000.000

57

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica WMC Diversified Equity VP – Initial Class(6)		2010	$	0.941858	$	1.083730		1,785,802.773
Subaccount Inception Date December 13, 1999		2009	$	0.745369	$	0.941858		45,627.856
		2008	$	1.343904	$	0.745369		2,319.487
		2007	$	1.184292	$	1.343904		1,005.180
		2006	$	1.012369	$	1.184292		0.000
		2005	$	0.956578	$	1.012369		0.000
		2004	$	1.000000	$	0.956578		0.000
Transamerica Multi-Managed Balanced VP – Initial Class(1)		2010	$	1.220025	$	1.491197		255,603.946
Subaccount Inception Date May 1, 2002		2009	$	0.980965	$	1.220025		0.000
		2008	$	1.473732	$	0.980965		0.000
		2007	$	1.317444	$	1.473732		2,183.902
		2006	$	1.225959	$	1.317444		3,212.590
		2005	$	1.153085	$	1.225959		8,325.102
		2004	$	1.053487	$	1.153085		2,108.559
		2003	$	0.939281	$	1.053487		2,420.719
		2002	$	1.000000	$	0.939281		99.890
Transamerica AllianceBernstein Dynamic Allocation VP – Initial Class(4)		2010	$	1.313104	$	1.413194		195,338.952
Subaccount Inception Date May 1, 2002		2009	$	1.015596	$	1.313104		0.000
		2008	$	1.633852	$	1.015596		32,464.298
		2007	$	1.398675	$	1.633852		34,305.500
		2006	$	1.280730	$	1.398675		34,100.448
		2005	$	1.251920	$	1.280730		32,713.061
		2004	$	1.123331	$	1.251920		0.000
		2003	$	0.922464	$	1.123331		0.000
		2002	$	1.000000	$	0.922464		99.890
Transamerica WMC Diversified Growth VP – Initial Class		2010	$	0.935035	$	1.084767		3,715,646.119
Subaccount Inception Date December 13, 1999		2009	$	0.734955	$	0.935035		56,680.813
		2008	$	1.382371	$	0.734955		147,192.042
		2007	$	1.207305	$	1.382371		188,967.895
		2006	$	1.127697	$	1.207305		214,253.892
		2005	$	0.982633	$	1.127697		158,220.548
		2004	$	0.861695	$	0.982633		169,660.200
		2003	$	0.666828	$	0.861695		190,538.067
		2002	$	0.870883	$	0.666828		226,311.413
		2001	$	1.000000	$	0.870883		118,422.035
Transamerica Morgan Stanley Growth Opportunities VP – Initial Class(7)		2010	$	1.560035	$	2.084095		375,930.727
Subaccount Inception Date May 1, 2001		2009	$	1.157534	$	1.560035		1,980.541
		2008	$	1.989306	$	1.157534		1,778.436
		2007	$	1.641377	$	1.989306		1,783.167
		2006	$	1.585844	$	1.641377		2,149.874
		2005	$	1.385499	$	1.585844		9,104.621
		2004	$	1.206427	$	1.385499		10,194.638
		2003	$	0.933694	$	1.206427		14,035.568
		2002	$	1.106549	$	0.933694		41,634.474
		2001	$	1.000000	$	1.106549		42,498.296
Transamerica AEGON Money Market VP – Initial Class(2)		2010	$	1.067022	$	1.050789		1,798,430.510
Subaccount Inception Date December 13, 1999		2009	$	1.082161	$	1.067022		0.000
		2008	$	1.073301	$	1.082161		326.568
		2007	$	1.037829	$	1.073301		9,853.813
		2006	$	1.006269	$	1.037829		182,969.109
		2005	$	0.993185	$	1.006269		190,499.757
		2004	$	0.998585	$	0.993185		9,601.684
		2003	$	1.000000	$	0.998585		534.587

58

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Systematic Small/Mid Cap Value VP – Initial Class(8)		2010	$	1.644130	$	2.111477		2,211,773.925
Subaccount Inception Date December 13, 1999		2009	$	1.165827	$	1.644130		52,086.099
		2008	$	2.002212	$	1.165827		128,735.856
		2007	$	1.630121	$	2.002212		241,688.250
		2006	$	1.402172	$	1.630121		275,763.581
		2005	$	1.253809	$	1.402172		513,355.956
		2004	$	1.094395	$	1.253809		532,172.496
		2003	$	0.582372	$	1.094395		514,636.128
		2002	$	0.976962	$	0.582372		577,620.892
		2001	$	1.000000	$	0.976962		200,821.027
Transamerica AEGON U.S. Government Securities VP – Initial Class(3)		2010	$	1.271074	$	1.306783		2,023,065.744
Subaccount Inception Date December 13, 1999		2009	$	1.235573	$	1.271074		67,193.705
		2008	$	1.165487	$	1.235573		87,694.910
		2007	$	1.116132	$	1.165487		34,097.380
		2006	$	1.097485	$	1.116132		36,316.991
		2005	$	1.090132	$	1.097485		57,449.028
		2004	$	1.071750	$	1.090132		102,051.991
		2003	$	1.057207	$	1.071750		126,779.085
		2002	$	1.014592	$	1.057207		374,800.397
		2001	$	1.000000	$	1.014592		327,040.329
Transamerica AEGON U.S. Government Securities VP – Service Class(3)		2010	$	1.179574	$	1.210634		33,873.578
Subaccount Inception Date December 13, 1999		2009	$	1.149598	$	1.179574		0.000
		2008	$	1.086878	$	1.149598		0.000
		2007	$	1.043482	$	1.086878		0.000
		2006	$	1.028154	$	1.043482		0.000
		2005	$	1.023764	$	1.028154		0.000
		2004	$	1.010345	$	1.023764		0.000
		2003	$	1.000000	$	1.010345		0.000
Transamerica Morgan Stanley Active International Allocation VP – Initial		2010	$	1.172768	$	1.252794		714,746.362
Class		2009	$	0.946077	$	1.172768		25,092.857
Subaccount Inception Date December 13, 1999		2008	$	1.570765	$	0.946077		35,689.765
		2007	$	1.379911	$	1.570765		36,582.814
		2006	$	1.134538	$	1.379911		32,697.516
		2005	$	1.012440	$	1.134538		45,016.129
		2004	$	0.886038	$	1.012440		47,063.728
		2003	$	0.677481	$	0.886038		49,151.481
		2002	$	0.828616	$	0.677481		127,231.249
		2001	$	1.000000	$	0.828616		82,418.958
Transamerica Multi Managed Large Cap Core VP – Initial Class		2010	$	1.079484	$	1.266819		2,123,022.739
Subaccount Inception Date December 13, 1999		2009	$	0.753873	$	1.079484		86,162.636
		2008	$	1.321903	$	0.753873		101,301.030
		2007	$	1.228845	$	1.321903		131,555.271
		2006	$	1.130969	$	1.228845		154,077.224
		2005	$	1.049636	$	1.130969		244,819.390
		2004	$	0.945384	$	1.049636		309,842.128
		2003	$	0.792879	$	0.945384		337,550.121
		2002	$	0.962911	$	0.792879		390,514.516
		2001	$	1.000000	$	0.962911		41,968.536

59

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Morgan Stanley Mid-Cap Growth VP – Initial Class		2010	$	0.817385	$	1.077792		850,565.949
Subaccount Inception Date May 1, 2001		2009	$	0.516977	$	0.817385		21,201.333
		2008	$	0.977513	$	0.516977		21,346.952
		2007	$	0.810185	$	0.977513		23,311.957
		2006	$	0.748559	$	0.810185		39,170.879
		2005	$	0.706779	$	0.748559		40,327.195
		2004	$	0.669908	$	0.706779		52,300.306
		2003	$	0.530826	$	0.669908		50,579.297
		2002	$	0.805310	$	0.530826		52,969.144
		2001	$	1.000000	$	0.805310		15,552.750
Invesco V.I. Basic Value Fund – Series II Shares		2010	$	0.861770	$	0.907557		279,233.038
Subaccount Inception Date May 1, 2002		2009	$	0.592358	$	0.861770		0.000
		2008	$	1.250803	$	0.592358		72.933
		2007	$	1.253207	$	1.250803		52.236
		2006	$	1.126766	$	1.253207		0.000
		2005	$	1.085273	$	1.126766		0.000
		2004	$	0.994356	$	1.085273		0.000
		2003	$	0.757548	$	0.994356		0.000
		2002	$	1.000000	$	0.757548		0.000
Invesco V.I. Capital Appreciation Fund – Series II Shares		2010	$	0.871300	$	0.988477		5,385.612
Subaccount Inception Date May 1, 2002		2009	$	0.732952	$	0.871300		0.000
		2008	$	1.297388	$	0.732952		0.000
		2007	$	1.179248	$	1.297388		0.000
		2006	$	1.129078	$	1.179248		0.000
		2005	$	1.055944	$	1.129078		0.000
		2004	$	1.008489	$	1.055944		0.000
		2003	$	0.792764	$	1.008489		0.000
		2002	$	1.000000	$	0.792764		99.890
AllianceBernstein Growth and Income Portfolio – Class B		2010	$	0.855967	$	0.950792		1,685,482.846
Subaccount Inception Date May 1, 2001		2009	$	0.722264	$	0.855967		97,266.825
		2008	$	1.236841	$	0.722264		187,228.610
		2007	$	1.197896	$	1.236841		280,029.890
		2006	$	1.039808	$	1.197896		297,924.629
		2005	$	1.009478	$	1.039808		333,770.239
		2004	$	0.921732	$	1.009478		446,236.516
		2003	$	0.708109	$	0.921732		483,774.313
		2002	$	0.925071	$	0.708109		631,692.556
		2001	$	1.000000	$	0.925071		198,836.774
AllianceBernstein Large Cap Growth Portfolio – Class B		2010	$	0.746965	$	0.807891		954,314.753
Subaccount Inception Date May 1, 2001		2009	$	0.553250	$	0.746965		0.000
		2008	$	0.933656	$	0.553250		83,080.529
		2007	$	0.834587	$	0.933656		92,567.930
		2006	$	0.852963	$	0.834587		97,790.445
		2005	$	0.754200	$	0.852963		103,745.905
		2004	$	0.706925	$	0.754200		110,949.221
		2003	$	0.581903	$	0.706925		118,632.568
		2002	$	0.854462	$	0.581903		141,728.704
		2001	$	1.000000	$	0.854462		87,415.361

60

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Fidelity VIP Contrafund ® Portfolio – Service Class 2		2010	$	1.320272	$	1.520198		1,755,002.271
Subaccount Inception Date May 1, 2000		2009	$	0.989701	$	1.320272		50,707.914
		2008	$	1.753860	$	0.989701		76,861.361
		2007	$	1.518462	$	1.753860		63,440.236
		2006	$	1.383752	$	1.518462		31,843.153
		2005	$	1.204608	$	1.383752		30,360.745
		2004	$	1.062289	$	1.204608		0.000
		2003	$	0.841480	$	1.062289		0.000
		2002	$	0.945328	$	0.841480		43,976.847
		2001	$	1.000000	$	0.945328		11,260.971
Fidelity VIP Equity-Income Portfolio – Service Class 2		2010	$	0.944282	$	1.068581		1,428,547.330
Subaccount Inception Date May 1, 2000		2009	$	0.738290	$	0.944282		29,391.663
		2008	$	1.311118	$	0.738290		32,372.172
		2007	$	1.314819	$	1.311118		65,079.487
		2006	$	1.113273	$	1.314819		131,771.939
		2005	$	1.070829	$	1.113273		141,970.581
		2004	$	0.977653	$	1.070829		160,638.800
		2003	$	0.763516	$	0.977653		161,139.795
		2002	$	0.935892	$	0.763516		231,085.767
		2001	$	1.000000	$	0.935892		58,950.541
Fidelity VIP Growth Portfolio – Service Class 2		2010	$	0.701231	$	0.855314		743,577.375
Subaccount Inception Date May 1, 2001		2009	$	0.556480	$	0.701231		1,747.672
		2008	$	1.072563	$	0.556480		0.000
		2007	$	0.860003	$	1.072563		0.000
		2006	$	0.819443	$	0.860003		0.000
		2005	$	0.788705	$	0.819443		0.000
		2004	$	0.776712	$	0.788705		18,757.625
		2003	$	0.595094	$	0.776712		18,816.610
		2002	$	0.867001	$	0.595094		48,655.770
		2001	$	1.000000	$	0.867001		1,000.000
Fidelity VIP Growth Opportunities Portfolio – Service Class 2		2010	$	0.796624	$	0.968615		98,185.709
Subaccount Inception Date May 1, 2000		2009	$	0.556143	$	0.796624		0.000
		2008	$	1.258957	$	0.556143		0.000
		2007	$	1.040290	$	1.258957		0.000
		2006	$	1.004935	$	1.040290		0.000
		2005	$	0.938993	$	1.004935		0.000
		2004	$	0.892116	$	0.938993		0.000
		2003	$	0.700088	$	0.892116		0.000
		2002	$	0.911567	$	0.700088		998.915
		2001	$	1.000000	$	0.911567		8,487.477
Fidelity VIP Mid Cap Portfolio – Service Class 2		2010	$	1.818522	$	2.302437		1,737,071.764
Subaccount Inception Date May 1, 2000		2009	$	1.321413	$	1.818522		55,802.128
		2008	$	2.222083	$	1.321413		68,010.444
		2007	$	1.956606	$	2.222083		140,991.919
		2006	$	1.767617	$	1.956606		162,904.304
		2005	$	1.520914	$	1.767617		194,908.573
		2004	$	1.239038	$	1.520914		213,253.272
		2003	$	0.910103	$	1.239038		256,755.139
		2002	$	1.027192	$	0.910103		315,453.564
		2001	$	1.000000	$	1.027192		66,684.529

61

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Fidelity VIP Value Strategies Portfolio – Service Class 2		2010	$	1.153874	$	1.435540		499,067.792
Subaccount Inception Date May 1, 2002		2009	$	0.745622	$	1.153874		0.000
		2008	$	1.554448	$	0.745622		10,475.209
		2007	$	1.497211	$	1.554448		11,246.783
		2006	$	1.310560	$	1.497211		11,856.139
		2005	$	1.299278	$	1.310560		12,545.279
		2004	$	1.159068	$	1.299278		13,333.769
		2003	$	0.747954	$	1.159068		14,206.022
		2002	$	1.000000	$	0.747954		15,478.691
Franklin Income Securities Fund – Class 2		2010	$	0.896617	$	0.994830		882,331.732
Subaccount Inception Date May 1, 2007		2009	$	0.671488	$	0.896617		807.217
		2008	$	0.969437	$	0.671488		0.000
		2007	$	1.000000	$	0.969437		0.000
Mutual Shares Securities Fund – Class 2		2010	$	0.740603	$	0.810942		214,528.584
Subaccount Inception Date May 1, 2007		2009	$	0.596665	$	0.740603		0.000
		2008	$	0.963492	$	0.596665		0.000
		2007	$	1.000000	$	0.963492		0.000
Templeton Foreign Securities Fund – Class 2		2010	$	0.846164	$	0.903305		305,296.421
Subaccount Inception Date May 1, 2007		2009	$	0.627021	$	0.846164		0.000
		2008	$	1.068021	$	0.627021		0.000
		2007	$	1.000000	$	1.068021		0.000
Janus Aspen – Enterprise Portfolio – Service Shares		2010	$	0.993891	$	1.228503		469,106.876
Subaccount Inception Date October 9, 2000		2009	$	0.698738	$	0.993891		0.000
		2008	$	1.263968	$	0.698738		0.000
		2007	$	1.054417	$	1.263968		33,083.812
		2006	$	0.944988	$	1.054417		36,026.489
		2005	$	0.856564	$	0.944988		39,050.027
		2004	$	0.722029	$	0.856564		42,322.781
		2003	$	0.544079	$	0.722029		55,410.836
		2002	$	0.768654	$	0.544079		62,830.493
		2001	$	1.000000	$	0.768654		1000.000
Janus Aspen – Perkins Mid Cap Value Portfolio – Service Shares		2010	$	1.325201	$	1.505480		253,722.921
Subaccount Inception Date October 9, 2000		2009	$	1.012444	$	1.325201		21,876.985
		2008	$	1.425989	$	1.012444		21,997.649
		2007	$	1.351312	$	1.425989		22,060.190
		2006	$	1.192545	$	1.351312		22,118.720
		2005	$	1.100856	$	1.192545		31,645.868
		2004	$	0.949036	$	1.100856		45,013.571
		2003	$	0.682460	$	0.949036		45,158.079
		2002	$	0.905027	$	0.682460		46,363.612
		2001	$	1.000000	$	0.905027		1000.000
Janus Aspen – Worldwide Portfolio – Service Shares		2010	$	0.732523	$	0.833299		1,110,311.736
Subaccount Inception Date October 9, 2000		2009	$	0.541386	$	0.732523		0.000
		2008	$	0.996184	$	0.541386		0.000
		2007	$	0.925085	$	0.996184		0.000
		2006	$	0.796510	$	0.925085		2,991.444
		2005	$	0.766160	$	0.796510		4,083.602
		2004	$	0.744370	$	0.766160		5,757.542
		2003	$	0.611173	$	0.744370		7,536.922
		2002	$	0.835427	$	0.611173		10,273.679
		2001	$	1.000000	$	0.835427		1000.000

62

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.55%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
MFS ® New Discovery Series – Service Class		2010	$	1.135251	$	1.519723		186,530.330
Subaccount Inception Date May 1, 2002		2009	$	0.707617	$	1.135251		0.000
		2008	$	1.188222	$	0.707617		10,246.140
		2007	$	1.180187	$	1.188222		11,000.863
		2006	$	1.061215	$	1.180187		11,596.900
		2005	$	1.025998	$	1.061215		12,270.995
		2004	$	0.981034	$	1.025998		13,042.228
		2003	$	0.746621	$	0.981034		13,895.388
		2002	$	1.000000	$	0.746621		15,142.427
MFS ® Total Return Series – Service Class		2010	$	1.154449	$	1.246334		559,735.920
Subaccount Inception Date May 1, 2002		2009	$	0.995840	$	1.154449		0.000
		2008	$	1.301938	$	0.995840		0.000
		2007	$	1.272166	$	1.301938		0.000
		2006	$	1.157309	$	1.272166		0.000
		2005	$	1.145445	$	1.157309		0.000
		2004	$	1.047708	$	1.145445		0.000
		2003	$	0.917149	$	1.047708		0.000
		2002	$	1.000000	$	0.917149		99.890

⁽¹⁾  Formerly known as Transamerica Balanced VP.

⁽²⁾  Formerly known as Transamerica Money Market VP.

⁽³⁾  Formerly known as Transamerica U.S. Government Securities VP.

⁽⁴⁾  Formerly known as Transamerica Convertible Securities VP.

⁽⁵⁾  Formerly known as Transamerica Focus VP.

⁽⁶⁾  Formerly known as Transamerica Diversified Equity VP.

⁽⁷⁾  Formerly known as Transamerica Growth Opportunities VP.

⁽⁸⁾  Formerly known as Transamerica Small/Mid Cap Value VP.

⁽⁹⁾  Formerly known as Transamerica Foxhall Global Hard Assets VP.

Transamerica AEGON Active Asset Allocation - Conservative VP, Transamerica AEGON Active Asset Allocation - Moderate VP, Transamerica AEGON Active Asset Allocation - Moderate Growth VP, Transamerica JPMorgan Core Bond VP, Transamerica JPMorgan Tactical Allocation VP, and Transamerica PIMCO Real Return TIPS VP had not commenced operations as of December 31, 2010, therefore, comparable data is not available.

63

APPENDIX

OA METHOD TRANSFERS

To make the Retirement Income Choice 1.2 Benefit available, we monitor your policy value and guarantees under the rider daily and periodically transfer amounts between your selected investment options and the OA Subaccount. We determine the amount and timing of OA Method transfers between the investment options and the OA Subaccount according to a mathematical model.

The mathematical model is designed to calculate how much of your policy value should be allocated to the OA Subaccount. Based on this calculation, transfers into or out of the OA Subaccount will occur (subject to the previously disclosed thresholds). The formula is:

Percent of Policy Value required in OA Subaccount (or X) = e^{-Dividend*Time} *(1- NormDist(d1))

where:

e	=	Base of the Natural Logarithm
NormDist	=	Cumulative Standard Normal Distribution
d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

In order to calculate the percent of policy value required in the OA Subaccount, we must first calculate d1:

d1 = [ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

where:

ln	=	Natural Logarithm Function
G	=	Guarantee Ratio
R	=	Rate
F	=	Fees
V	=	Volatility
T	=	Time

After calculating d1, the percent of policy value required in the OA Subaccount can be calculated. Once calculated, appropriate transfers into or out of the OA Subaccount will occur (subject to the thresholds).

Following is a brief discussion of the values used in the formula.

The POLICY VALUE includes the value in both the investment options and in the OA Subaccount.

The GUARANTEE RATIO is the policy value divided by the greater of (1) premiums minus any adjusted partial withdrawals or (2) present value of rider withdrawal amount (the present value of the rider amount looks at the sum of the expected lifetime payments discounted using a factor of [5.5]).

64

OA METHOD TRANSFERS — (Continued)

The RATE is the interest rate used for the OA Method. It is based on a long-term expectation based on historical interest rates and may vary over time.

The FEES is an approximation of average policy fees and charges associated with policies that have elected the RIC 1.2 rider. This value may change over time.

The VOLATILITY represents the volatility of the returns of policy value for all in force policies and is based on the long-term expectation of the degree to which the policy values tend to fluctuate. This value may vary over time.

The TIME is an approximation based on actuarial calculations of historical average number of years (including any fraction) which we anticipate remain until any potential payments are made under the benefit. This value may vary over time.

The PERCENT OF POLICY VALUE TO BE ALLOCATED TO THE OA SUBACCOUNT is computed for each policy. Ultimately the allocation for a policy takes into account the guarantees under the rider and the limit on allocations to the OA Subaccount.

The CUMULATIVE STANDARD NORMAL DISTRIBUTION function assumes that random events are distributed according to the classic bell curve. For a given value it computes the percentage of such events which can be expected to be less than that value.

The NATURAL LOGARITHM function for a given value, computes the power to which e must be raised, in order to result in that value. Here, e is the base of the natural logarithms, or approximately 2.718282.

Example:

Day 1: Policy Value Declines by 10%

For purposes of this example we will assume that the policy value declines by 10% to $90,000, the day after the rider issue date from the initial premium amount of $100,000 producing a guarantee ratio of 90% ($90,000/$100,000) invoking an OA transfer. We will also assume:

Guarantee Ratio	=	90%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	15%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.90)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.658832

65

OA METHOD TRANSFERS — (Continued)

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1-NormDist(d1)))

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(.658832)))
DOA	=	min(20%, 13.9948%)
DOA	=	13.9948%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the lower threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	max (0, DOA - (OA% = FA% / 3)
X	=	max (0, 13.9948% - (0% = 15% / 3)
X	=	max (0, 13,9948% - 5%)
X	=	8.9948%

Therefore, 8.9948% of the policy value is transferred to the OA Subaccount, resulting in a total transfer of $8,095.32.

Day 2: Policy Value Recovers to 95% of Initial Value after the 10% Decline

For purposes of this example we will assume that after the policy value declined to $90,000, it recovered the next day to $95,000 producing a guarantee ratio of 95% ($95,000/$100,000) and invoking an OA transfer. We will also assume:

Guarantee Ratio	=	95%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	14%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%
Percentage of policy value in OA Subaccount	=	8%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.95)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.779732

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

66

OA METHOD TRANSFERS — (Continued)

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1 - NormDist(d1)))

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(.779732)))
DOA	=	min(20%, 11.9517%)
DOA	=	11.9517%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the upper threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	min (OA%, max(0, OA% = FA% / 3 - DOA%))
X	=	min(8%, max(0, 8% + 14% / 3 - 11.9517%))
X	=	min(8%, max(0, 0.714967%))
X	=	0.714967%

Therefore, due to the policy value recovery, 0.714967% of the policy value will be transferred out of the OA Subaccount pro rata back into their current investment options, resulting in a total transfer of $679.22.

Day 3: Policy Value further recovers to 105% of Initial Value

For purposes of this example we will assume that after the policy value recovered to $95,000, it further recovered the next day to $105,000 producing a guarantee ratio of 105% ($105,000/$100,000) and invoking an OA transfer. We will also assume:

Guarantee Ratio	=	105%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	13%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%
Percentage of policy value in OA Subaccount	=	6%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(1.05)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	1.003524

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1 - NormDist(d1)))

67

OA METHOD TRANSFERS — (Continued)

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(1.003524)))
DOA	=	min(20%, 8.6605%)
DOA	=	8.6605%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the upper threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	min (OA%, max(0, OA% = FA% / 3 - DOA%))
X	=	min(6%, max(0, 6% + 13% / 3 - 8.6605%))
X	=	min(6%, max(0, 1.67283%))
X	=	1.67283%>

While the mathematical model would suggest we transfer only a portion of the policy value in the OA Subaccount into your investment options (leaving 4.32717% (6% - 1.67283%) in the OA Subaccount), all of the policy value in the OA Subaccount will be transferred into your investment options. If the Guarantee Ratio equals or exceeds 100%, then your policy value is greater than or equal to the value of the guarantee and there is no current need for any policy value to be allocated to the OA Subaccount.

68

APPENDIX

PAM METHOD TRANSFERS

To make the Living Benefits Rider available, we monitor your policy value and guarantees under the rider daily and periodically transfer amounts between your selected investment options and the PAM Subaccount. We determine the amount and timing of PAM Method transfers between the investment options and the PAM Subaccount according to a mathematical model.

The mathematical model is designed to calculate how much of your policy value should be allocated to the PAM Subaccount. Based on this calculation, transfers into or out of the PAM Subaccount will occur. The formula is:

Percent of Policy Value required in PAM Subaccount (or X) =

e-^{Dividend*Time} *(1- NormDist(d1))

where:

e	=	Base of the Natural Logarithm
NormDist	=	Cumulative Standard Normal Distribution
d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

In order to calculate the percent of policy value required in the PAM Subaccount, we must first calculate d1:

d1 = [ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

where:

ln	=	Natural Logarithm Function
	=	Guarantee Ratio
R	=	Rate
F	=	Fees
V	=	Volatility
T	=	Time

After calculating d1, the percent of policy value required in the PAM Subaccount can be calculated. Once calculated, appropriate transfers into or out of the PAM Subaccount will occur.

Following is a brief discussion of the values used in the formula.

The POLICY VALUE includes the value in both the investment options and in the PAM Subaccount.

The GUARANTEE RATIO is the policy value divided by 7% “Principal Back” Minimum Remaining Withdrawal Amount.

69

PAM METHOD TRANSFERS — (Continued)

The RATE is the interest rate used for the PAM Method. It is based on a long-term expectation based on historical interest rates and may vary over time.

The FEES is an approximation of average policy fees and charges associated with policies that have elected the Living Benefits Rider. This value may change over time.

The VOLATILITY represents the volatility of the returns of policy value for all in force policies and is based on the long-term expectation of the degree to which the policy values tend to fluctuate. This value may vary over time.

The TIME is an approximation based on actuarial calculations of historical average number of years (including any fraction) which we anticipate remain until any potential payments are made under the benefit. This value may vary over time.

The PERCENT OF POLICY VALUE TO BE ALLOCATED TO THE PAM SUBACCOUNT is computed for each policy. Ultimately the allocation for a policy takes into account the guarantees under the rider and the limit on allocations to the PAM Subaccount.

The CUMULATIVE STANDARD NORMAL DISTRIBUTION function assumes that random events are distributed according to the classic bell curve. For a given value it computes the percentage of such events which can be expected to be less than that value.

The NATURAL LOGARITHM function for a given value, computes the power to which e must be raised, in order to result in that value. Here, e is the base of the natural logarithms, or approximately 2.718282.

Example:

Day 1: Policy Value Declines by 10%

For purposes of this example we will assume that the policy value declines by 10% to $90,000 the day after the rider issue date from the initial premium amount of $100,000 producing a guarantee ratio of 90% ($90,000/$100,000). We will also assume:

Guarantee Ratio	=	90%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.90)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.658832

70

PAM METHOD TRANSFERS — (Continued)

Using the value we just calculated for d1 we can now calculate the percent of policy value required in the PAM Subaccount.

Percent of Policy Value in PAM Subaccount (or X) = e-^{Dividend*Time} *(1-NormDist(d1))

X	=	(2.718282 ^ -.03 * 20) * (1 – NormDist(.658832))
X	=	13.9948%

Therefore, 13.9948% of the policy value is transferred to the PAM Subaccount, resulting in a total transfer of $12,595.32.

Day 2: Policy Value Recovers to 105% of Initial Value after the 10% Decline

For purposes of this example we will assume that after the policy value declined to $90,000 it recovered the next day to $105,000 producing a guarantee ratio of 105% ($105,000/$100,000). We will also assume:

Guarantee Ratio	=	105%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(1.05)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	1.003524

Using the value we just calculated for d1 we can now calculate the percent of policy value required in the PAM Subaccount.

Percent of Policy Value in PAM Subaccount (or X) = e^{-Dividend*Time *}(1 - NormDist(d1))

X= (2.718282 ^ -.03 * 20) * (1 – NormDist(1.003524))

X = 8.6605%

While the mathematical model would suggest we transfer only a portion of the policy value in the PAM Subaccount into your investment options (leaving 8.6605% in the PAM Subaccount), all of the policy value in the PAM Subaccount will be transferred into your investment options. If the Guarantee Ratio equals or exceeds 100%, then your policy value is greater than or equal to the value of the guarantee and there is no current need for any policy value to be allocated to the PAM Subaccount.

71

MEMBERS^® EXTRA^SM VARIABLE ANNUITY

Issued Through

SEPARATE ACCOUNT VA C

By

TRANSAMERICA LIFE INSURANCE COMPANY

Prospectus

May 1, 2011

This flexible premium deferred annuity policy has many investment choices. There is a separate account that currently provides a means of investing in various underlying fund portfolios. There is also a fixed account, which offers interest at rates that are guaranteed by Transamerica Life Insurance Company. You can choose any combination of these investment choices. You bear the entire investment risk for all amounts you put in the separate account.

The Company will add a credit to your policy value for each premium payment that you make. Generally, an annuity with a premium enhancement will have higher overall expenses than a similar annuity without a premium enhancement; the amount credited under the premium enhancement may be more than offset by the additional fees and charges associated with the premium enhancement. You should always consider the expenses along with the features and enhancements to be sure that any annuity meets your financial needs and goals.

This prospectus and the underlying fund prospectuses give you important information about the policies and the underlying fund portfolios. Please read them carefully before you invest and keep them for future reference.

If you would like more information about the MEMBERS^® Extra^SM Variable Annuity, you can obtain a free copy of the Statement of Additional Information (SAI) dated May 1, 2011. Please call us at (800) 525-6205 or write us at: Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001. A registration statement, including the SAI, has been filed with the Securities and Exchange Commission (SEC) and the SAI is incorporated herein by reference. More information about the variable annuity can be reviewed and copied at the SEC’s Public Reference Room in Washington, D.C. You may obtain information about the operation of the public reference room by calling the SEC at 1-800-732-0330. The SEC also maintains a web site (http://www.sec.gov) that contains the prospectus, the SAI, material incorporated by reference, and other information. The table of contents of the SAI is included at the end of this prospectus.

For each premium payment you make, Transamerica will add an additional amount to your policy value, referred to as a premium enhancement.

Please note that the policies and the separate account investment choices:

• are not bank deposits

• are not federally insured

• are not endorsed by any bank or government agency

• are not guaranteed to achieve their goal

• are subject to risks, including loss of premium

The Securities and Exchange Commission has not approved or disapproved these securities, or passed upon the adequacy of this prospectus. Any representation to the contrary is a criminal offense.

PORTFOLIOS ASSOCIATED WITH THE SUBACCOUNTS

ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.

Managed by AllianceBernstein L.P.

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

AMERICAN FUNDS INSURANCE SERIES^® TRUST

Managed by Capital Research and Management Company^SM

American Funds – Asset Allocation Fund – Class 2

American Funds – Bond Fund – Class 2

American Funds – Growth Fund – Class 2

American Funds – Growth-Income Fund – Class 2

FIDELITY^® VARIABLE INSURANCE PRODUCTS FUND

Managed by Fidelity Management & Research Company

Fidelity VIP Balanced Portfolio – Service Class 2

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Managed by Franklin Advisers, Inc.

Franklin Income Securities Fund – Class 2

GE INVESTMENTS FUNDS, INC.

Managed by GE Asset Management, Inc.

GE Investments Total Return Fund – Class 3

TRANSAMERICA SERIES TRUST

Subadvised by AEGON USA Investment Management, LLC

Transamerica AEGON High Yield Bond VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Index 75 VP – Service Class

Transamerica Index 100 VP – Service Class

Subadvised by Alliance Bernstein L.P.

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Subadvised by BlackRock Financial Management, Inc.

Transamerica BlackRock Tactical Allocation VP – Service Class

Subadvised by BlackRock Investment Management, LLC

Transamerica BlackRock Large Cap Value VP – Service Class

Subadvised by Foxhall Capital Management, Inc.

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class

Subadvised by ING Clarion Real Estate Securities, LLC

Transamerica Clarion Global Real Estate Securities VP – Service Class

Subadvised by MFS^® Investment Management

Transamerica MFS International Equity VP – Service Class

Subadvised by Madison Asset Management. LLC

Transamerica Madison Balanced Allocation VP – Service Class

Transamerica Madison Conservative Allocation VP – Service Class

Transamerica Madison Diversified Income VP – Service Class

Transamerica Madison Large Cap Growth VP – Service Class

Transamerica Madison Moderate Growth Allocation VP – Service Class

Subadvised by Morgan Stanley Investment Management Inc.

Transamerica Morgan Stanley Active International AllocationVP – Service Class

Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class

Subadvised by Pacific Investment Management Company LLC

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Subadvised by T. Rowe Price Associates, Inc.

Transamerica T. Rowe Price Small Cap VP – Service Class

Advised by Transamerica Asset Management, Inc.

Transamerica BlackRock Global Allocation VP – Service Class

2

TABLE OF CONTENTS

GLOSSARY OF TERMS		6
SUMMARY		8
ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES		15
1.	THE ANNUITY POLICY	21
2.	PURCHASE	21
	Policy Issue Requirements	21
	Premium Payments	22
	Initial Premium Requirements	22
	Additional Premium Payments	22
	Maximum Total Premium Payments	22
	Allocation of Premium Payments	23
	Policy Value	23
	Premium Enhancement	23
3.	INVESTMENT CHOICES	24
	The Separate Account	24
	Selection of Underlying Portfolios	26
	Addition, Deletion, or Substitution of Investments	27
	Static Allocation Models	28
	The Fixed Account	28
	Transfers	29
	Market Timing and Disruptive Trading	29
4.	PERFORMANCE	33
5.	EXPENSES	33
	Surrender Charges	33
	Excess Interest Adjustment	35
	Mortality and Expense Risk Fees	35
	Premium Taxes	35
	Federal, State and Local Taxes	35
	Special Service Fees	35
	Transfer Fee	35
	Administrative Charges	35
	Initial Payment Guarantee	36
	Fund Facilitation Fee	36
	Additional Death Distribution	36
	Additional Death Distribution+	36
	Living Benefits Rider	36
	Retirement Income Choice® 1.2 Rider and Additional Options Fees	37
	Retirement Income Choice® 1.4 Rider and Additional Options Fees - This Rider is No Longer Available for New Sales	37
	Income Link® Rider Fee	37
	Retirement Income MaxSM Rider Fees	38
	Portfolio Fees and Expenses	38
	Revenue We Receive	38
6.	ACCESS TO YOUR MONEY	40
	Surrenders	40
	Delay of Payment and Transfers	41
	Excess Interest Adjustment	41
	Signature Guarantee	42
7.	ANNUITY PAYMENTS (THE INCOME PHASE)	42
	Annuity Payment Options	43
8.	DEATH BENEFIT	45
	When We Pay A Death Benefit	46
	When We Do Not Pay A Death Benefit	46
	Deaths After the Annuity Commencement Date	46
	Succession of Ownership	46
	Amount of Death Benefit	46
	Guaranteed Minimum Death Benefit	47
	Adjusted Partial Surrender	47
9.	TAXES	48
	Annuity Policies in General	48
	Qualified and Nonqualified Policies	48
	Surrenders-Qualified Policies Generally	49
	Surrenders-403(b) Policies	50
	Surrenders-Nonqualified Policies	50
	Taxation of Death Benefit Proceeds	51
	Annuity Payments	51
	Partial Annuitization	52
	Medicare Tax	52
	Diversification and Distribution Requirements	52
	Federal Defense of Marriage Act	52
	Federal Estate Taxes	52
	Generation-Skipping Transfer Tax	53

3

TABLE OF CONTENTS continued

	Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010	53
	Annuity Purchases by Residents of Puerto Rico	53
	Annuity Policies Purchased by Nonresident Aliens and Foreign Corporations	53
	Transfers, Assignments or Exchanges of Policies	53
	Possible Tax Law Changes	54
	Separate Account Charges	54
	Foreign Tax Credits	54
	Guaranteed Lifetime Withdrawal Benefits	54
10.	ADDITIONAL FEATURES	54
	Systematic Payout Option	54
	Income Benefit Programs	55
	Initial Payment Guarantee	55
	Additional Death Distribution	56
	Additional Death Distribution+	57
	Nursing Care and Terminal Condition Withdrawal Option	58
	Unemployment Waiver	59
	Telephone Transactions	59
	Dollar Cost Averaging Program	59
	Asset Rebalancing	61
	Guaranteed Lifetime Withdrawal Benefits	61
	Living Benefits Rider	61
	Retirement Income Choice® 1.2 Rider	69
	Retirement Income Choice® 1.4 Rider - This Rider is No Longer Available for New Sales	81
	Income LinkSM Rider	90
	Retirement Income MaxSM Rider	98
11.	OTHER INFORMATION	104
	Ownership	104
	Beneficiary	104
	Right to Cancel Period	105
	Assignment	105
	Sending Forms and Transaction Requests in Good Order	105
	Mixed and Shared Funding	105
	Exchanges and Reinstatements	106
	Voting Rights	106
	Legal Proceedings	106
	Transamerica Life Insurance Company	107
	Financial Condition of the Company	107
	The Separate Account	108
	Distribution of the Policies	108
TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION		111
APPENDIX
	CONDENSED FINANCIAL INFORMATION	112
APPENDIX
	POLICY VARIATIONS	116
APPENDIX
	EXCESS INTEREST ADJUSTMENT EXAMPLES	122
APPENDIX
	DEATH BENEFIT	126
APPENDIX
	ADDITIONAL DEATH DISTRIBUTION RIDER - ADDITIONAL INFORMATION	129
APPENDIX
	ADDITIONAL DEATH DISTRIBUTION+ RIDER - ADDITIONAL INFORMATION	130
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT COMPARISON TABLE	131
APPENDIX
	LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS	135
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME CHOICE® 1.2 RIDER AND RETIREMENT INCOME CHOICE® 1.4 RIDER (RETIREMENT INCOME CHOICE® 1.4 - NO LONGER AVAILABLE FOR NEW SALES)	142

4

TABLE OF CONTENTS continued

APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS - INCOME LINK® RIDER	148
APPENDIX
	GUARANTEED LIFETIME WITHDRAWAL BENEFIT ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME MAXSM RIDER	150
APPENDIX
	HYPOTHETICAL EXAMPLE OF THE WITHDRAWAL BASE CALCULATION - RETIREMENT INCOME MAXSM RIDER	153

5

GLOSSARY OF TERMS

Accumulation Unit — An accounting unit of measure used in calculating the policy value in the separate account before the annuity commencement date.

Adjusted Policy Value — The policy value increased or decreased by any excess interest adjustment.

Administrative and Service Office — Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001, (800) 525-6205.

Annuitant — The person on whose life any annuity payments involving life contingencies will be based.

Annuitize (Annuitization) — When you switch from the accumulation phase to the income phase and we begin to make annuity payments to you (or your designee).

Annuity Commencement Date — The date upon which annuity payments are to commence. This date may be any date after the policy date and may not be later than the last day of the policy month following the month after the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy. The annuity commencement date may have to be earlier for qualified policies and may be earlier if required by state law.

Annuity Payment Option — A method of receiving a stream of annuity payments selected by the owner.

Assumed Investment Return or AIR — The annual effective rate shown in the contract specifications section of the contract that is used in the calculation of each variable annuity payment.

Cash Value — The adjusted policy value less any applicable surrender charge and rider fees (imposed upon surrender).

Excess Interest Adjustment — A positive or negative adjustment to amounts surrendered (both partial or full surrenders and transfers) or applied to annuity payment options from the fixed account guaranteed period options prior to the end of the guaranteed period. The adjustment reflects changes in the interest rates declared by the Company since the date any payment was received by, or an amount was transferred to, the guaranteed period option. The excess interest adjustment can either decrease or increase the amount to be received by the owner upon full surrender or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively.

Fixed Account — One or more investment choices under the policy that are part of the Company’s general assets and are not in the separate account.

Free Amount — The amount that can be withdrawn each year without incurring any surrender charge or excess interest adjustment.

Guaranteed Lifetime Withdrawal Benefit — Any optional benefit under the policy that provides a guaranteed minimum withdrawal benefit, including the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider.

Guaranteed Period Options — The various guaranteed interest rate periods of the fixed account which the Company may offer and into which premium payments may be paid or amounts transferred.

Owner (You, Your) — The person who may exercise all rights and privileges under the policy. The owner during the lifetime of the annuitant and before the annuity commencement date is the person designated as the owner in the information that we require to issue a policy.

Policy Date — The date shown on the policy data page attached to the policy and the date on which the policy becomes effective.

Policy Value — On or before the annuity commencement date, the policy value is equal to the owner’s:

• premium payments; minus

• gross partial surrenders (partial surrenders minus excess interest adjustments plus the surrender charge on the portion of the requested partial surrender that is subject to the surrender charge); plus

• interest credited in the fixed account; plus

• accumulated gains in the separate account; minus

• accumulated losses in the separate account; minus

6

• service charges, rider fees, premium taxes, transfer fees, and other charges, if any.

Policy Year — A policy year begins on the policy date and on each anniversary thereof.

Separate Account — Separate Account VA C, a separate account established and registered as a unit investment trust under the Investment Company Act of 1940, as amended (the “1940 Act”), to which premium payments under the policies may be allocated.

Separate Account Value — The portion of the policy value that is invested in the separate account.

Subaccount — A subdivision within the separate account, the assets of which are invested in a specified underlying fund portfolio.

Valuation Period — The period of time from one determination of accumulation unit values and annuity unit values to the next subsequent determination of those values. Such determination shall be made on each business day.

Written Notice — Written notice, signed by the owner, that gives the Company the information it requires and is received in good order at the Administrative and Service Office. For some transactions, the Company may accept an electronic notice such as telephone instructions. Such electronic notice must meet the requirements for good order that the Company establishes for such notices.

You (Your) — the owner of the policy.

7

SUMMARY

The sections in this summary correspond to sections in this prospectus, which discuss the topics in more detail.

1. THE ANNUITY POLICY

The flexible premium deferred variable annuity policy offered by Transamerica Life Insurance Company (the Company, we, us, or our) provides a way for you to invest on a tax-deferred basis in the following investment choices: various subaccounts of the separate account and the fixed account of the Company. The policy is intended to accumulate money for retirement or other long-term investment purposes.

This policy currently offers subaccounts that are listed under “Investment Choices” in this prospectus. Each subaccount invests exclusively in shares of one of the underlying fund portfolios. The policy value may depend on the investment experience of the selected subaccounts. Therefore, you bear the entire investment risk with respect to all policy value in any subaccount. You could lose the amount that you invest.

The fixed account offers an interest rate that the Company guarantees.

The policy, like all deferred annuity policies, has two phases: the “accumulation phase” and the “income phase.” During the accumulation phase, earnings accumulate on a tax-deferred basis and are taxed as ordinary income when you take them out of the policy. The income phase occurs when you annuitize and begin receiving regular annuity payments from your policy. The money you can accumulate during the accumulation phase will largely determine the payments you receive during the income phase.

2. PURCHASE

The initial premium payment for nonqualified policies must be at least $5,000 or more, and at least $1,000 for qualified policies, under most circumstances. You must obtain prior Company approval to purchase a policy with an amount less than the stated minimum. You can generally add as little as $50 at any time during the accumulation phase.

3. INVESTMENT CHOICES

You can allocate your premium payments to one of several underlying fund portfolios listed under Investment Choices in this prospectus and described in the underlying fund prospectuses. Depending upon their investment performance, you can make or lose money in any of the subaccounts.

You can also allocate your premium payments to the fixed account.

We currently allow you to transfer money between any of the investment choices during the accumulation phase. We reserve the right to impose a $10 fee for each transfer in excess of 12 transfers per policy year and to impose restrictions and limitations on transfers.

8

4. PERFORMANCE

The value of the policy will vary up or down depending upon the investment performance of the subaccounts you choose.

5. EXPENSES

Note: The following section on expenses and the Annuity Policy Fee Table and expense examples only apply to policies issued after the date of this prospectus. See “Appendix – Policy Variations” for information about older policies.

No deductions are made from premium payments at the time you buy the policy so that the full amount of each premium payment is invested in one or more of your investment choices.

We may deduct a surrender charge of up to 9% of premium payments surrendered within nine years after the premium is paid. We will calculate surrender charges by taking the earnings, if any, out before premium payments. If you select the Life with Emergency Cash^® annuity payment option, then you can surrender your policy after annuity payments have begun. A surrender charge of up to 4% of adjusted policy value will apply during the first four years after the annuity commencement date.

Full surrenders, partial surrenders, and transfers from a guaranteed period option of the fixed account may also be subject to an excess interest adjustment, which may increase or decrease the amount you receive. This adjustment may also apply to amounts applied to an annuity payment option from a guaranteed period option of the fixed account prior to the end of the guaranteed period option.

We deduct daily mortality and expense risk fees and administrative charges from the assets in each subaccount during the accumulation phase, at an annual rate (as a percentage of the subaccount’s value) that depend on the death benefit option that you select, as follows:

• 1.65% if you choose the Return of Premium Death Benefit

• 1.85% if you choose the Annual Step-Up Death Benefit

During the accumulation phase, we deduct an annual service charge of no more than $35 from the policy value The charge is waived if either the policy value or the sum of all premium payments, minus all partial surrenders, is at least $100,000.

Upon full surrender, payment of a death benefit, or when annuity payments begin, we will deduct state premium taxes, if applicable. State premium taxes currently range from 0% to 3.50%, depending on the state.

If you elect the Initial Payment Guarantee feature when you annuitize, then there is a daily fee (during the income phase) currently equal to an annual rate of 1.25% of the daily net asset value in the subaccounts.

We deduct a daily fund facilitation fee from the assets in certain investment choices at an annual rate (as a percentage of the subaccount’s value) as follows:

• 0.30% if you choose the American Funds – Asset Allocation Fund – Class 2

• 0.30% if you choose the American Funds – Bond Fund – Class 2

• 0.30% if you choose the American Funds – Growth Fund – Class 2

• 0.30% if you choose the American Funds – Growth-Income Fund – Class 2

• 0.20% if you choose the AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

• 0.20% if you choose the GE Investments Total Return Fund – Class 3

9

• 0.10 % if you choose the Transamerica BlackRock Global Allocation VP – Service Class

If you elect the Additional Death Distribution (“ADD”), then there is an annual rider fee during the accumulation phase of 0.25% of the policy value.

If you elect the Additional Death Distribution+ (“ADD+”), then there is an annual rider fee during the accumulation phase of 0.55% of the policy value.

If you elect the Living Benefits Rider, then there is an annual rider fee during the accumulation phase of 0.90% of the “principal back” total withdrawal base on each anniversary (“rider anniversary”) of the date the rider was elected.

If you elect the Retirement Income Choice^® 1.2 Rider, there is an annual rider fee during the accumulation phase of 1.20% (of the withdrawal base charged quarterly) if you elect the Open Allocation option, and 0.45% to 1.40% if you elect the Designated Allocation option depending on what designated investment options you choose. For each additional option you elect with the rider, you will be charged a quarterly fee during the accumulation phase that is also a percentage of the withdrawal base; this fee is in addition to the rider fee for the base benefit.

If you elect the Income Link^® Rider, there is a rider fee during the accumulation phase of 0.90% (on an annual basis) of the withdrawal base charged quarterly.

If you elect the Retirement Income Max^SM Rider, there is a quarterly rider fee during the accumulation phase of 1.00% annually.

The value of the net assets of the subaccounts will reflect the management fee and other expenses incurred by the underlying fund portfolios.

6. ACCESS TO YOUR MONEY

You can generally take out $500 or more anytime during the accumulation phase (except under certain qualified policies).

You may generally take out up to the free amount free of surrender charges. Amounts surrendered in excess of this free amount may be subject to a surrender charge and an excess interest adjustment. You may have to pay income tax and a tax penalty on any money you take out.

If you have policy value in the fixed account, you may take out any cumulative interest credited free of excess interest adjustments.

Access to amounts held in qualified policies may be restricted or prohibited by law or regulation or the terms of the policy.

Surrenders are not generally permitted during the income phase unless you elect the Life with Emergency Cash^® annuity payment option.

Partial surrenders will reduce your policy value. Depending on its amount and timing, a partial surrender may considerably reduce or eliminate some of the benefits and guarantees provided by your Contract. You should carefully consider whether a partial surrender under a particular circumstance will have a negative impact to your benefits or guarantees. The impact of partial and full surrenders (generally)

10

on your benefits and guarantees is discussed in the corresponding sections of the prospectus describing such benefits and guarantees.

7. ANNUITY PAYMENTS (THE INCOME PHASE)

The policy allows you to receive income under one of several annuity payment options. You may choose from fixed payment options, variable payment options, or a combination of both. If you select a variable payment option, then the dollar amount of your annuity payments may go up or down.

However, the Initial Payment Guarantee is available for an extra fee and it guarantees a minimum amount for each variable annuity payment.

8. DEATH BENEFIT

If the sole annuitant dies before the income phase begins, then the beneficiary will generally receive a death benefit. If the owner is not the annuitant, then no death benefit is paid if the owner dies; however required distribution rules require that the policy value be distributed upon the death of any owner.

Naming different persons as owner and annuitant can affect to whom and whether amounts will be paid. Use care when naming owners, annuitants and beneficiaries, and consult your agent if you have questions.

When you purchase a policy you may generally choose an optional guaranteed minimum death benefit:

• Annual Step-Up Death Benefit

Charges are lower if you do not choose an optional guaranteed minimum death benefit.

After the policy is issued, a guaranteed minimum death benefit cannot be added, and the death benefit cannot be changed.

9. TAXES

Earnings, if any, are generally not taxed until taken out. If you take money out of a nonqualified policy during the accumulation phase, earnings come out first for federal tax purposes, and are taxed as ordinary income. For nonqualified and certain qualified policies, payments during the income phase may be considered partly a return of your original investment so that part of each payment may not be taxable as income. For qualified policies, payments during the income phase are, in many cases, considered as all taxable income. If you are younger than 59 ¹/2 when you take money out, you may incur a 10% federal penalty tax on the taxable earnings.

10. ADDITIONAL FEATURES

This policy has additional features that might interest you. These features may not be available for all policies, may vary for certain policies, may not each be available in combination with other optional benefits under the policy, and may not be suitable for your particular situation.

These features include, but are not limited to, the following:

• You can arrange to have money automatically sent to you monthly, quarterly, semi-annually or annually while your policy is in the accumulation phase. This feature is referred to as the “Systematic Payout Option” (“SPO”). Amounts you receive may be included in your gross income, and in certain circumstances, may be subject to penalty taxes.

• You can elect an optional feature at the time of annuitization that guarantees your variable annuity payments will never be less than a percentage of the initial variable annuity payment. This feature is called the “Initial Payment Guarantee” (“IPG”). There is an extra charge for this feature.

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• You may elect one of two optional riders that might pay an additional amount on top of the policy death benefit, in certain circumstances. These features are called the “Additional Death Distribution” (“ADD”) and “Additional Death Distribution+” (“ADD+”). There is an extra charge for these riders.

• Under certain medically related circumstances, you may surrender all or part of the policy value without any surrender charge or excess interest adjustment. This feature is called the “Nursing Care and Terminal Condition Withdrawal Option.”

• Under certain unemployment circumstances, you may surrender all or a portion of the policy value free of any surrender charge or excess interest adjustment. This feature is called the “Unemployment Waiver.”

• You may generally make transfers and/or change the allocation of additional premium payments by telephone. We may restrict or eliminate this feature.

• You can arrange to automatically transfer money (at least $500 per transfer) monthly or quarterly from certain investment choices into one or more subaccounts. This feature is known as “Dollar Cost Averaging.”

• We will, upon your request, automatically transfer amounts among the subaccounts on a regular basis to maintain a desired allocation of the policy value among the various subaccounts. This feature is called “Asset Rebalancing.”

• You may elect to purchase an optional rider which provides you with a guaranteed minimum accumulation benefit and a guaranteed lifetime withdrawal benefit. This feature is called the “Living Benefits Rider.” If you elect this rider, we will monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts back and forth between investment choices that we designate and the variable investment choices that you have selected. You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit. This feature is called the “Retirement Income Choice^® 1.2 Rider.” If you elect the Retirement Income Choice^® 1.2 Rider, you must allocate 100% of your policy value according to either the Designated Allocation option or the Open Allocation option and meet other conditions. (See “Retirement Income Choice^® 1.2 - Allocation Options and Restrictions”.) You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit that uses a higher withdrawal percentage for a defined period of time and then resets to a lower percentage. This feature is called the “Income Link^® Rider.” If you elect the Income Link^® Rider, you must allocate 100% of your policy value to one or more “designated investment option(s).” (See “Income Link^® Rider - Designated Investment Options”.) You may lose the benefit of this rider if you take non-Income Link^® rider systematic withdrawals. There is an extra charge for this rider.

• You may elect to purchase an optional rider which provides you with a guaranteed lifetime withdrawal benefit. This feature is called the “Retirement Income Max^SM Rider.” If you elect the Retirement Income Max^SM Rider, you must allocate 100% of your policy value to one or more “designated investment option(s).” (See “Retirement Income Max^SM - Designated Investment Options”.) The designated investment options differ from the designated investment options for the other guaranteed

12

lifetime withdrawal benefits. You may lose the benefit of this rider if you take “excess” withdrawals. There is an extra charge for this rider.

11. OTHER INFORMATION

Right to Cancel Period. You may return your policy for a refund, but only if you return it within a prescribed period, which is generally 10 days (after you receive the policy), or whatever longer time may be required by state law. The amount of the refund will generally be the premiums paid plus or minus accumulated gains or losses in the separate account; if state law requires, we will refund your original premium payment(s). The policy will then be deemed void.

No Probate. Usually, the person receiving the death benefit under this policy will not have to go through probate. State laws vary on how the amount that may be paid is treated for estate tax purposes.

Who should purchase the Policy? This policy is designed for people seeking long-term tax-deferred accumulation of assets, generally for retirement or other long-term purposes; and for persons who have maximized their use of other retirement savings methods, such as 401(k) plans. The tax-deferred feature is most attractive to people in high federal and state tax brackets. The tax deferral features of variable annuities are unnecessary when purchased to fund a qualified plan. You should not buy this policy if you are looking for a short-term investment, market timing, or if you cannot take the risk of losing money that you put in.

There are various fees and charges associated with variable annuities. You should consider whether the features and benefits of this policy, unique to variable annuities, such as the opportunity for lifetime income payments, a guaranteed death benefit, the guaranteed level of certain charges, and additional features, make this policy appropriate for your needs.

State Variations. Policies issued in your state may provide different features and benefits from, and impose different costs than, those described in this prospectus because of state law variations. These differences include, among other things, free look rights, issue age limitations, and the general availability of riders. This prospectus describes the material rights and obligations of a policy owner, and the maximum fees and charges for all policy features and benefits are set forth in the fee table of this prospectus. See your policy for specific variations because any such state variations will be included in your policy or in riders or endorsements attached to your policy. See your agent or contact us for specific information that is applicable to your state.

Old Policies. This prospectus generally describes policies issued after the date of this prospectus. See “Appendix – Policy Variations” for information on how older policies have different features and requirements, and sometimes different fees and deductions.

Financial Statements. Financial Statements for the Company and the subaccounts are in the SAI. Condensed financial information for the subaccounts (those in operation by year end December 31, 2010, if any) are in “Appendix – Condensed Financial Information” to this prospectus.

12. INQUIRIES

If you need more information or want to make a transaction, please contact us at:

Transamerica Life Insurance Company

Administrative and Service Office

Attention: Customer Care Group

4333 Edgewood Road NE

Cedar Rapids, IA 52499-0001

(800) 525-6205

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You may check your policy at www.transamericaannuities.com. Follow the logon procedures. You will need your pre-assigned Personal Identification Number (“PIN”) to access information about your policy. We cannot guarantee that you will be able to access this site.

You should protect your PIN, because on-line (or telephone) options may be available and could be made by anyone who knows your PIN. We may not be able to verify that the person providing instructions using your PIN is you or someone authorized by you.

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ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES

The following describes the fees and expenses that you will pay when buying, owning, and surrendering the policy. Please be certain to review the notes following the fee table and expense examples for further information about the fees and charges presented. The order of the notes follows the order in which the fees and charges under the policy are presented in the fee tables and the expense examples.

The first section describes the fees and expenses that you will pay at the time that you buy the policy, surrender the policy, or transfer cash value between investment choices. State premium taxes may also be deducted. Excess interest adjustments may be made to amounts surrendered or applied to annuity payment options from cash value from the fixed account.(All fees are maximum for purchases made while this prospectus is effective unless otherwise noted.)

Policy Owner Transaction Expenses:

Sales Load On Purchase Payments		0	%
Maximum Surrender Charge (as a % of premium payments surrendered) Base Policy		9	%
Transfer Fee	$	0 - $10
Special Service Fee	$	0 - $25

The next section describes the fees and expenses that you will pay periodically during the time that you own the policy, not including portfolio fees and expenses. (All fees are maximum for purchases made while this prospectus is effective unless otherwise noted.)

Annual Service Charge	$	0 - $35 per policy
Separate Account Annual Expenses (as a percentage, annually, of average separate account value):
Base Separate Account Expenses:
Mortality and Expense Risk Fee		1.50	%
Administrative Charge		0.15	%
Total Base Separate Account Annual Expenses		1.65	%
Optional Separate Account Expenses:
Annual Step-Up Death Benefit		0.20	%
Fund Facilitation Fee		0.30	%
Total Separate Account Annual Expenses with Highest Optional Separate Account Expenses		2.15	%
Optional Rider Fees:
Additional Death Distribution (annual charge based on policy value)		0.25	%
Additional Death Distribution+ (annual charge based on policy value)		0.55	%
Living Benefits Rider (annual charge, a % of Total Withdrawal Base)		0.90	%
Retirement Income Choice® 1.2 Rider (annual charge, a % of withdrawal base):
Base Benefit Open Allocation Option (Maximum)		1.95	%
Base Benefit Open Allocation Option (Current)		1.20	%
Base Benefit Designated Allocation Group A (Maximum)		2.15	%
Base Benefit Designated Allocation Group A (Current)		1.40	%

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Base Benefit Designated Allocation Group B (Maximum)	1.75	%
Base Benefit Designated Allocation Group B (Current)	1.00	%
Base Benefit Designated Allocation Group C (Maximum)	1.20	%
Base Benefit Designated Allocation Group C (Current)	0.45	%
Additional Benefits available with the Retirement Income Choice® 1.2 Rider:
Death Benefit (Single Life Option)	0.25	%
Death Benefit (Joint Life Option)	0.20	%
Income Enhancement Benefit (Single Life Option)	0.15	%
Income Enhancement Benefit (Joint Life Option)	0.30	%
Maximum Total Retirement Income Choice® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits	2.65	%
Current Total Retirement Income Choice® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits	1.90	%
Retirement Income Choice® 1.4 Rider (annual charge, a % of withdrawal base):
This Rider is No Longer Available for New Sales
Base Benefit Designated Allocation Group A (Maximum)	2.15	%
Base Benefit Designated Allocation Group A (Current)	1.40	%
Base Benefit Designated Allocation Group B (Maximum)	1.75	%
Base Benefit Designated Allocation Group B (Current)	1.00	%
Base Benefit Designated Allocation Group C (Maximum)	1.20	%
Base Benefit Designated Allocation Group C (Current)	0.45	%
Additional Benefits available with the Retirement Income Choice® 1.4 Rider:
Death Benefit (Single Life Option)	0.25	%
Death Benefit (Joint Life Option)	0.20	%
Income Enhancement Benefit (Single Life Option)	0.15	%
Income Enhancement Benefit (Joint Life Option)	0.30	%
Maximum Total Retirement Income Choice® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits	2.65	%
Current Total Retirement Income Choice® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits	1.90	%
Income Link® Rider (annual charge a - % of withdrawal base):
Base Benefit (Maximum)	1.65	%
Base Benefit (Current)	0.90	%
Retirement Income MaxSM Rider (annual charge a % of withdrawal base):
Base Benefit (Maximum)	1.75	%
Base Benefit (Current)	1.00	%

The next section shows the lowest and highest total operating expenses charged by the underlying fund portfolios for the year ended December 31, 2010 (before any fee waiver or expense reimbursements). Expenses may be higher or lower in future years. More detail concerning each portfolio’s fees and expenses is contained in the prospectus for each portfolio.

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Total Portfolio Annual Operating Expenses (Expenses that are deducted from portfolio assets, including management fees, distribution and/or service 12b-1 fees, and other expenses):

Lowest Gross	0.54	%
Highest Gross	1.78	%

The following Example is intended to help you compare the cost of investing in the policy with the cost of investing in other variable annuity policies. These costs include policy owner transaction expenses, policy fees, separate account annual expenses, and portfolio fees and expenses.

The Example assumes that you invest $10,000 in the policy for the time periods indicated. The Example also assumes that your investment has a 5% return each year, the highest fees and expenses of any of the portfolios for the year ended December 31, 2010, and the base policy with the combination of available optional features or riders with the highest fees and expenses, including the Highest Fund Facilitation Fee, Annual Step-Up Death Benefit, Additional Death Distribution+ Rider, and Retirement Income Choice^® 1.2 Rider - Joint Life with additional Death Benefit and Income Enhancement options. Although your actual costs may be higher or lower, based on these assumptions, your costs would be:

Expense Examples:

If the policy is surrendered at the end of the applicable time period:

1 Year	$	1464
3 Years	$	2600
5 Years	$	3750
10 Years	$	6678

If the policy is annuitized at the end of the applicable time period or if you do not surrender your policy:

1 Year	$	654
3 Years	$	1970
5 Years	$	3300
10 Years	$	6678

Please remember that the Example is an illustration and does not represent past or future expenses. Your actual expenses may be lower or higher than those reflected in the Example. Similarly, your rate of return may be more or less than the 5% assumed in the Example.

For information concerning compensation paid for the sale of the policies, see “Distributor of the Policies.”

NOTES TO FEE TABLE AND EXPENSE EXAMPLES

Annuity Policy Fee Table and Expense Examples: The fee table applies only to the accumulation phase and reflects the maximum charges unless otherwise noted. During the income phase the fees may be different than those described in the Fee Table. See section “5. Expenses”.

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Policy Owner Transaction Expenses:

Maximum Surrender Charge: The surrender charge, if any is imposed, applies to each premium, regardless of how policy value is allocated among the investment choices. The surrender charge decreases based on the number of years since the premium payment was made.

If you select the Life with Emergency Cash^® annuity payment option, you will be subject to a surrender charge after the annuity commencement date. See section “5. Expenses”.

Transfer Fee: The transfer fee, if any is imposed, applies to each policy, regardless of how policy value is allocated among the investment choices. There is no fee for the first 12 transfers per policy year. For additional transfers, the Company may charge a fee of $10 per transfer.

Special Service Fees: We may deduct a charge for special services, such as overnight delivery.

Annual Service Charge:

Annual Service Charge: The annual service charge is assessed on each policy anniversary and at surrender. The charge is waived if your policy value, or the sum of your premiums less all partial surrenders, is at least $100,000.

Separate Account Annual Expenses:

Mortality and Expense Risk Fee: The mortality and expense risk fee shown is for the accumulation phase with the base death benefit.

Optional Separate Account Expenses: Any optional separate account expense is in addition to the mortality and expense risk and administrative fees.

Fund Facilitation Fee: This daily fee is applied only to policy value in the subaccounts invested in the American Funds - Asset Allocation Fund - Class 2 (0.30%), American Funds - Bond Fund - Class 2 (0.30%), American Funds - Growth Fund - Class 2 (0.30%), American Funds - Growth-Income Fund - Class 2 (0.30%), AllianceBernstein Balanced Wealth Strategy Portfolio - Class B (0.20%), GE Investments Total Return Fund - Class 3 (0.20%), and the Transamerica BlackRock Global Allocation VP - Service Class (0.10%). See section “5. Expenses”.

Total Separate Account Annual Expenses with Highest Optional Separate Account Expenses: This reflects the base separate account expenses, the Annual Step-Up Death Benefit fee, plus the Fund Facilitation fee, but does not include any annual optional rider fees. The death benefits are mutually exclusive.

Optional Rider Fees:

Optional Rider Fees: In some cases, riders to the policy are available that provide optional benefits. There are additional fees (each year) for those riders.

Additional Death Distribution Rider and Additional Death Distribution+ Rider: This annual fee is a percentage of the policy value and is only deducted during the accumulation phase.

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Living Benefits Rider: The annual fee is a percentage of the “principal back” Total Withdrawal Base. The “principal back” Total Withdrawal Base on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the “principal back” Total Withdrawal Base is equal to: the “principal back” Total Withdrawal Base on the rider date; plus subsequent premium payments; less subsequent “principal back” adjusted partial withdrawals.

Retirement Income Choice^® 1.2 Rider, Retirement Income Choice^® 1.4 Rider, Income Link^® and Retirement Income Max^SM Rider – base benefit: The fee is a percentage of the Withdrawal Base. The Withdrawal Base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the Withdrawal Base is equal to the Withdrawal Base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent Withdrawal Base adjustments.

Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider – Additional Benefits (Single Life and Joint Life Options): You may elect the Retirement Income Choice^® 1.2 Rider or the Retirement Income Choice^® 1.4 Rider with one or more of the following options - Death Benefit or Income Enhancement Benefit. The charge for each of these options is a percentage of the Withdrawal Base and is in addition to the base benefit fee.

Maximum Total Retirement Income Choice^® 1.2 Rider and Maximum Total Retirement Income Choice^® 1.4 Rider Fees with Highest Combination of Benefits: After the fifth rider anniversary, the base benefit rider fees can increase when there is an automatic step-up. These fee totals reflect the maximum fee increase resulting from an automatic step-up of the Withdrawal Base while the rider is in effect.

Maximum Total Retirement Income Choice^® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Maximum), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Current Total Retirement Income Choice^® 1.2 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Current), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Maximum Total Retirement Income Choice^® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Maximum), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Current Total Retirement Income Choice^® 1.4 Rider Fees (Joint Life) with Highest Combination of Benefits: This reflects the Base Benefit Designated Allocation Group A (Current), the Death Benefit (Joint Life Option), plus the Income Enhancement Benefit (Joint Life Option).

Maximum Total Income Link^® Rider and Retirement Income Max^SM Rider Fees: After the first rider anniversary, the base benefit rider fees can increase when there is an automatic step-up. This fee total reflects the maximum fee increase resulting from an automatic step-up of the Withdrawal Base while the rider is in effect.

Total Portfolio Annual Operating Expenses:

Total Portfolio Annual Operating Expenses: The fee table information relating to the underlying fund portfolios was provided to the Company by the underlying fund portfolios, their investment advisors or managers, and the Company has not and cannot independently verify the accuracy or completeness of such information. Actual future

19

expenses of the portfolios may be greater or less than those shown in the Table. “Gross” expense figures do not reflect any fee waivers or expense reimbursements. Actual expenses may have been lower than those shown in the Table.

Expense Examples:

Expense Examples: The Example does not reflect premium tax charges or transfer fees. Different fees and expenses not reflected in the Example may be assessed during the income phase of the policy.

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1. THE ANNUITY POLICY

This prospectus describes the MEMBERS^® Extra^SM Variable Annuity policy offered by the Company. This prospectus generally describes policies issued on or after the date of this prospectus. Policies issued before that date may have different features (such as different death benefits or annuity payment options) and different charges. See “Appendix – Policy Variations” for information about older policies.

An annuity is a contract between you, the owner, and an insurance company (in this case the Company), where the insurance company promises to pay you an income in the form of annuity payments. These payments begin on a designated date, referred to as the annuity commencement date. Until the annuity commencement date, your annuity is in the accumulation phase and the earnings (if any) are tax deferred. Tax deferral means you generally are not taxed until you take money out of your annuity. After you annuitize, your annuity switches to the income phase.

The policy is a flexible premium deferred variable annuity. You can use the policy to accumulate funds for retirement or other long-term financial planning purposes. Your individual investment and your rights are determined primarily by your own policy.

The policy is a “flexible premium” annuity because after you purchase it, you can generally make additional investments of $50 or more until the annuity commencement date. You are not required to make any additional investments.

The policy is a “variable” annuity because the value of your investments can go up or down based on the performance of your investment choices. If you invest in the separate account, the amount of money you are able to accumulate in your policy during the accumulation phase depends upon the performance of your investment choices. You could lose the amount you allocate to the separate account. The amount of annuity payments you receive during the income phase from the separate account also depends upon the investment performance of your investment choices for the income phase. However, if you annuitize under the Initial Payment Guarantee feature, then you will receive stabilized annuity payments that will never be less than a percentage of your initial variable annuity payment. There is an extra charge for this feature.

The policy also contains a fixed account. The fixed account offers interest at rates that we guarantee will not decrease during the selected guaranteed period. There may be different interest rates for each different guaranteed period that you select.

Do not purchase this policy if you plan to use it, or any of its riders, for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme. Your contract is not intended or designed to be traded on any stock exchange or secondary market. By purchasing this contract, you represent and warrant that you are not using the contract, or any of its riders for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme.

2. PURCHASE

Policy Issue Requirements

The Company will not issue a policy unless:

• the Company receives in good order (at our Administrative and Service Office) all information needed to issue the policy;

• the Company receives in good order (at our Administrative and Service Office) a minimum initial premium payment; and

• the annuitant, owner, and any joint owner are age 85 or younger (the limit may be lower for qualified policies).

We reserve the right to reject any application or premium payment.

21

Premium Payments

You should make checks for premium payments payable only to Transamerica Life Insurance Company and send them to the Administrative and Service Office. Your check must be honored in order for us to pay any associated payments and benefits due under the policy.

We do not accept cash. We reserve the right to not accept third party checks. A third party check is a check that is made payable to one person who endorses it and offers it as payment to a second person. Checks should normally be payable to Transamerica Life Insurance Company, however, in some circumstances, at our discretion we may accept third party checks that are from a rollover or transfer from other financial institutions. Any third party checks not accepted by our company will be returned.

We reserve the right to reject or accept any form of payment. Any unacceptable forms of payment will be returned.

Initial Premium Requirements

The initial premium payment for nonqualified policies must be at least $5,000, and at least $1,000 for qualified policies. You must obtain prior company approval to purchase a policy with an amount less than the stated minimum. There is generally no minimum initial premium payment for policies issued under section 403(b) of the Internal Revenue Code; however, your premium must be received within 90 days of the policy date or your policy will be canceled. We will credit your initial premium payment to your policy within two business days after the day we receive it and your complete policy information at our administrative and service office. If we are unable to credit your initial premium payment, we will contact you within five business days and explain why. We will also return your initial premium payment at that time unless you let us keep it and credit it as soon as possible.

The date on which we credit your initial premium payment to your policy is generally the policy date. The policy date is used to determine policy years, policy months and policy anniversaries.

There may be delays in our receipt of applications that are outside of our control (for example, because of the failure of the selling broker/dealer or sales agent to forward the application to us promptly, or because of delays in determining whether the policy is suitable for you). Any such delays will affect when your policy can be issued and your premium allocated among your investment choices.

Additional Premium Payments

You are not required to make any additional premium payments. However, you can generally make additional premium payments as often as you like during the accumulation phase. Additional premium payments must be at least $50. We will credit additional premium payments to your policy as of the business day we receive your premium and required information in good order at our Administrative and Service Office. Additional premium payments must be received before the close of a regular business session of the New York Stock Exchange (usually 4:00 p.m. Eastern time) to get same-day pricing of the additional premium payment.

Maximum Total Premium Payments

For issue ages 0-80, we reserve the right to reject cumulative premium payments over $1,000,000 (this includes subsequent premium payments) for policies with the same owner or same annuitant issued by us or an affiliate. For issue ages over 80, we reserve the right to reject cumulative premium payments over

22

$500,000 (this includes subsequent premium payments) for policies with the same owner or same annuitant issued by us or an affiliate.

Allocation of Premium Payments

When you purchase a policy, we will allocate your premium payment to the investment choices you select. Your allocation must be in whole percentages and must total 100%. We will allocate additional premium payments the same way, unless you request a different allocation.

If you allocate premium payments to the Dollar Cost Averaging program, you must give us instructions regarding the subaccount(s) to which transfers are to be made or we cannot accept your premium payment.

You may change allocations for future additional premium payments by sending written instructions to our Administrative and Service Office, or by telephone, subject to the limitations described under “Telephone Transactions”. The allocation change will apply to premium payments received on or after the date we receive the change request in good order.

You could lose the amount you allocate to the variable subaccounts.

The Company reserves the right to restrict or refuse any premium payment.

Policy Value

You should expect your policy value to change from valuation period to valuation period. A valuation period begins at the close of regular trading on the New York Stock Exchange on each business day and ends at the close of regular trading on the next succeeding business day. A business day is each day that the New York Stock Exchange is open. The New York Stock Exchange generally closes at 4:00 p.m. Eastern time. Holidays are generally not business days.

Premium Enhancement

An amount equal to the applicable percentage (as set forth below) of the initial premium payment will be added to the policy value. The amount of the premium enhancement is not considered a premium payment and therefore may not be included in the calculation of certain policy features (such as certain death benefits or living benefits) or in the calculation of fees and charges that are based on premium payments made. The premium enhancement percentage may vary from premium to premium on subsequent premium payments, but will never be less than 0.25% nor more than 7%. A confirmation will be sent advising the owner of the amount of premium enhancement applicable to each subsequent premium payment. No premium enhancement will apply if the policy is canceled pursuant to the right to cancel provision.

The premium enhancement percentage is determined by the annuitant’s age at the time of each premium payment. The percentage will decrease as the annuitant’s attained age increases. The following schedule shows the current premium enhancement percentages:

Annuitant’s Age	Premium Enhancement Percentage
0-59		5.5	%
60-69		5.0	%
70-79		4.0	%
80+		2.0	%

These percentages are not guaranteed: As noted above, these precentages may change to as little as 0.25%.

23

Generally, an annuity with a premium enhancement may have higher expenses than a similar annuity without a premium enhancement. Accordingly, you should always consider the expenses along with the features and enhancements to be sure any annuity meets your financial needs and goals.

There is no specific charge for the premium enhancement. Transamerica expects to use a portion of the mortality and expense risk fee, administrative charge and/or the surrender charge to pay the premium enhancement.

Transamerica may take back or “recapture” the full dollar amount of any premium enhancement upon the occurrence of any of the following events:

• exercise of the right to cancel option;

• exercise of the Nursing Care and Terminal Condition Withdrawal Option or the Unemployment Waiver within one year from the time we apply the premium enhancement;

• a death benefit is payable within one year from the time we apply the premium enhancement; or

• annuitization within one year from the time we apply the premium enhancement.

In certain unusual circumstances, you might be worse off because of the premium enhancement. This could happen if we recapture the dollar amount of the premium enhancement and the overall investment performance of your policy was negative (if the overall investment performance of your policy was positive you would be better off).

The Internal Revenue Code generally requires that interests in a qualified policy be nonforfeitable, and it is unclear whether the premium enhancement feature is consistent with those requirements. Consult a tax advisor before purchasing this policy as a qualified policy.

The premium enhancement may vary for certain policies and may not be available for all policies.

3. INVESTMENT CHOICES

The Separate Account

The following variable subaccounts are available under the policy for new investors, but may not be available for all policies. The subaccounts invest in shares of the various underlying fund portfolios. The companies that provide investment advice and administrative services for the underlying fund portfolios offered through this policy are listed below. The following variable investment choices are currently offered through this policy. Please be certain to review the notes following the list of variable investment choices.

Note: If you received a summary prospectus for any of the portfolios listed below, please follow the instructions on the first page of the summary prospectus to obtain a copy of the full fund prospectus.

ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.

Managed by AllianceBernstein L.P.

AllianceBernstein Balanced Wealth Strategy Portfolio - Class B

AMERICAN FUNDS INSURANCE SERIES^® TRUST

Managed by Capital Research and Management Company^SM

American Funds – Asset Allocation Fund – Class 2

American Funds – Bond Fund – Class 2

American Funds – Growth Fund – Class 2

American Funds – Growth-Income Fund – Class 2

FIDELITY^® VARIABLE INSURANCE PRODUCTS FUND

Managed by Fidelity Management & Research Company

Fidelity VIP Balanced Portfolio – Service Class 2

24

FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST

Managed by Franklin Advisers, Inc.

Franklin Income Securities Fund – Class 2

GE INVESTMENTS FUNDS, INC.

Managed by GE Asset Management, Inc.

GE Investments Total Return Fund – Class 3

TRANSAMERICA SERIES TRUST

Subadvised by AEGON USA Investment Management, LLC

Transamerica AEGON High Yield Bond VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Index 75 VP – Service Class

Transamerica Index 100 VP – Service Class

Subadvised by Alliance Bernstein L.P.

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Subadvised by BlackRock Financial Management, Inc.

Transamerica BlackRock Tactical Allocation VP – Service Class

Subadvised by BlackRock Investment Management, LLC

Transamerica BlackRock Large Cap Value VP – Service Class

Subadvised by Foxhall Capital Management, Inc.

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class

Subadvised by ING Clarion Real Estate Securities, LLC

Transamerica Clarion Global Real Estate Securities VP – Service Class

Subadvised by MFS^® Investment Management

Transamerica MFS International Equity VP – Service Class

Subadvised by Madison Asset Management. LLC

Transamerica Madison Balanced Allocation VP – Service Class

Transamerica Madison Conservative Allocation VP – Service Class

Transamerica Madison Diversified Income VP – Service Class

Transamerica Madison Large Cap Growth VP – Service Class

Transamerica Madison Moderate Growth Allocation VP – Service Class

Subadvised by Morgan Stanley Investment Management Inc.

Transamerica Morgan Stanley Active International Allocation VP – Service Class

Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class

Subadvised by Pacific Investment Management Company LLC

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Subadvised by T. Rowe Price Associates, Inc.

Transamerica T. Rowe Price Small Cap VP – Service Class

Advised by Transamerica Asset Management, Inc.

Transamerica BlackRock Global Allocation VP – Service Class

NOTES TO VARIABLE INVESTMENT CHOICES

Some subaccounts may be available for certain policies and may not be available for all policies. You should work with your registered representative to decide which subaccount(s) may be appropriate for you based on a thorough analysis of your particular insurance needs, financial objectives, investment goals, time horizons, and risk tolerance.

There can be no assurance that the Transamerica AEGON Money Market VP – Service Class portfolio will be able to maintain a stable net asset value per share. During extended periods of low interest rates, and partly as a result

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of policy charges, the yield on the Transamerica AEGON Money Market VP – Service Class subaccount may become extremely low and possibly negative.

The general public may not purchase shares of any of these underlying fund portfolios. The names and investment objectives and policies may be similar to other portfolios managed by the same investment advisor or manager that are sold directly to the public. You should not expect the investment results of the underlying fund portfolios to be the same as those of other portfolios.

More detailed information, including an explanation of the portfolios’ fees and investment objectives, may be found in the current prospectuses for the underlying fund portfolios, which accompany this prospectus. You should read the prospectuses for the underlying fund portfolios carefully before you invest.

Selection of Underlying Portfolios

The underlying fund portfolios offered through this product are selected by the Company, and the Company may consider various factors, including, but not limited to, asset class coverage, the strength of the adviser’s or sub-adviser’s reputation and tenure, brand recognition, performance, and the capability and qualification of each investment firm. Another factor that we may consider is whether the underlying fund portfolio or its service providers (e.g., the investment adviser or sub-advisers) or its affiliates will make payments to us or our affiliates. For additional information about these arrangements, see “Revenue We Receive.” We review the portfolios periodically and may remove a portfolio, or limit its availability to new premiums and/or transfers of cash value if we determine that a portfolio no longer satisfies one or more of the selection criteria, and/or if the portfolio has not attracted significant allocations from owners. We have included the Transamerica Series Trust (“TST”) underlying fund portfolios at least in part because they are managed by one of our affiliates, Transamerica Asset Management, Inc. (“TAM”).

We have developed this variable annuity product in cooperation with one or more distributors, and have included certain underlying fund portfolios based on their recommendations; their selection criteria may differ from our selection criteria.

You are responsible for choosing the subaccounts which invest in the underlying fund portfolios, and the amounts allocated to each, that are appropriate for your own individual circumstances and your investment goals, financial situation, and risk tolerance. Because investment risk is borne by you, decisions regarding investment allocations should be carefully considered.

In making your investment selections, we encourage you to thoroughly investigate all of the information regarding the underlying fund portfolios that are available to you, including each underlying fund portfolio’s prospectus, statement of additional information and annual and semi-annual reports. Other sources such as the Fund’s website or newspapers and financial and other magazines provide more current information, including information about any regulatory actions or investigations relating to a Fund or underlying fund portfolio. After you select underlying fund portfolios for your initial premium, you should monitor and periodically re-evaluate your allocations to determine if they are still appropriate.

You bear the risk of any decline in the cash value of your policy resulting from the performance of the underlying fund portfolios you have chosen.

We do not recommend or endorse any particular underlying fund portfolio and we do not provide investment advice.

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We do not guarantee that any of the subaccounts will always be available for premium payments, allocations, or transfers. We reserve the right, subject to compliance with applicable law, to make certain changes to the separate account and its investments. We reserve the right to add new portfolios [or portfolio classes], close existing portfolios [or portfolio classes], or substitute portfolio shares that are held by any subaccount for shares of a different portfolio. We will not add, delete or substitute any underlying fund portfolio shares attributable to your interest in a subaccount without notice to you and prior approval of the SEC, to the extent required by the 1940 Act or other applicable law.

We reserve the right to limit the number of subaccounts you are invested in at any one time.

Addition, Deletion, or Substitution of Investments

The Company cannot and does not guarantee that any of the subaccounts will always be available for premium payments, allocations, or transfers. The Company retains the right, subject to any applicable law, to make certain changes in the separate account and its investments. The Company reserves the right to eliminate the shares of any portfolio held by a subaccount and to substitute shares of another portfolio of the underlying fund portfolios, or of another registered open-end management investment company for the shares of any portfolio, if the shares of the portfolio are no longer available for investment or if, in the Company’s judgment, investment in any portfolio would be inappropriate in view of the purposes of the separate account. To the extent required by the 1940 Act, as amended, substitutions of shares attributable to your interest in a subaccount will not be made without prior notice to you and the prior approval of the Securities and Exchange Commission (“SEC”). Nothing contained herein shall prevent the separate account from purchasing other securities for other series or classes of variable annuity policies, or from affecting an exchange between series or classes of variable annuity policies on the basis of your requests.

New subaccounts may be established when, in the sole discretion of the Company, marketing, tax, investment or other conditions warrant. Any new subaccounts may be made available to existing owners on a basis to be determined by the Company. Each additional subaccount will purchase shares in a mutual fund portfolio, or other investment vehicle. The Company may also eliminate one or more subaccounts if, in its sole discretion, marketing, tax, investment or other conditions warrant such change. In the event any subaccount is eliminated, the Company will notify you and request a reallocation of the amounts invested in the eliminated subaccount.

Similarly, the Company may, at its discretion, close a subaccount to new investment (either transfers or premium payments). Any amounts that would otherwise be invested in a closed subaccount (for premium allocations, portfolio rebalancing, dollar cost averaging, automatic checking account or payroll deductions for period premiums, etc.) will, if you do not provide instructions for a new allocation be invested in the subaccount that invests in a portfolio of money market instruments. If a portfolio of money market instruments is unavailable, the Company will reinvest the amounts in another subaccount, or in the fixed account, if appropriate.

In the event of any such substitution or change, the Company may, by appropriate endorsement, make such changes in the policies as may be necessary or appropriate to reflect such substitution or change. Furthermore, if deemed to be in the best interests of persons having voting rights under the policies, the separate account may be (1) operated as a management company under the 1940 Act or any other form permitted by law, (2) deregistered under the 1940 Act in the event such registration is no longer required or (3) combined with one or more

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other separate accounts. To the extent permitted by applicable law, the Company also may (1) transfer the assets of the separate account associated with the policies to another account or accounts, (2) restrict or eliminate any voting rights of owners or other persons who have voting rights as to the separate account, (3) create new separate accounts, (4) add new subaccounts to or remove existing subaccounts from the separate account, or combine subaccounts, or (5)  add new underlying fund portfolios, or substitute a new fund for an existing fund.

Static Allocation Models

A Static Allocation Model is an allocation strategy comprised of two or more underlying fund portfolios that together provide a unique allocation mix not available as a single underlying fund portfolio. Policy owners that elect a Static Allocation Model directly own subaccount units of the underlying fund portfolios that comprise a particular model. In other words, a Static Allocation Model is not a group of underlying fund portfolios with one accumulation/annuity unit value, but rather, direct investment in a certain allocation of subaccounts. There is no additional charge associated with investing in a Static Allocation Model.

Each of the Static Allocation Models is just that: static. The allocations or “split” between one or more subaccounts is not monitored and adjusted to reflect changing market conditions. However, a policy owner’s investment in a Static Allocation Model will be rebalanced annually to ensure that the assets are allocated to the percentages in the same proportion that they were allocated at the time of election.

Only one Static Allocation Model may be elected at any one time. Additionally, the entire policy value must be allocated to the elected model.

You may request to transfer from one model to another, or transfer from a model to any other investment option. Each transfer into or out of a Static Allocation Model is considered one transfer.

The Fixed Account

Premium payments allocated and amounts transferred to the fixed account become part of the Company’s general account. Interests in the general account have not been registered under the Securities Act of 1933 (the “1933 Act”), nor is the general account registered as an investment company under the 1940 Act. Accordingly, neither the general account nor any interests therein are generally subject to the provisions of the 1933 or 1940 Acts. Disclosures relating to interests in the general account may, however, be subject to certain generally applicable provisions of the federal securities laws relating to the accuracy of statements made in a registration statement.

While we do not guarantee that the fixed account will always be available for investment, we do guarantee that the interest credited to the fixed account will not be less than the guaranteed minimum effective annual interest rate shown on your policy (the “guaranteed minimum”). We determine credited rates, which are guaranteed for at least one year, in our sole discretion. You bear the risk that we will not credit interest greater than the guaranteed minimum. At the end of the guaranteed period option you selected, the value in that guaranteed period option will automatically be transferred into a new guaranteed period option of the same length (or the next shorter period if the same period is no longer offered) at the current interest rate for that period. You can transfer to another investment choice by giving us notice within 30 days before the end of the expiring guaranteed period.

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Full and partial surrenders and transfers from a guaranteed period option of the fixed account are generally subject to an excess interest adjustment (except at the end of the guaranteed period). This adjustment will also be made to amounts that you apply to an annuity payment option. This adjustment may increase or decrease the amount of interest credited to your policy. The excess interest adjustment will not decrease the interest credited to your policy below the guaranteed minimum.

We also guarantee that upon full surrender your cash value attributable to the fixed account will not be less than the amount required by the applicable nonforfeiture law at the time the policy is issued.

If you select the fixed account, your money will be placed with the Company’s other general assets. The amount of money you are able to accumulate in the fixed account during the accumulation phase depends upon the total interest credited. The amount of each annuity payment you receive during the income phase from the fixed portion of your policy will remain level for the entire income phase.

We reserve the right to refuse any premium payment or transfer to the fixed account.

Transfers

During the accumulation phase, you may make transfers to or from any investment choice within certain limitations.

Transfers out of a guaranteed period option of the fixed account are limited to the following:

• Transfers at the end of a guaranteed period. No excess interest adjustment will apply.

• Transfers of amounts equal to interest credited. This may affect your overall interest-crediting rate, because transfers are deemed to come from the oldest premium payment first.

• Other than at the end of a guaranteed period, transfers of amounts from the guaranteed period option in excess of amounts equal to interest credited, are subject to an excess interest adjustment. If it is a negative adjustment, the maximum amount you can transfer in any one policy year is 25% of the amount in that guaranteed period option, less any previous transfers during the current policy year. If it is a positive adjustment, we do not limit the amount that you can transfer.

Each transfer must be at least $500, or the entire subaccount value. Transfers of interest from a guaranteed period option of the fixed account must be at least $50. If less than $500 remains as a result of the transfer, then we reserve the right to include that amount in the transfer. Transfer requests must be received in good order at our Administrative and Service Office while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction.

The number of transfers permitted may be limited and a $10 charge for each transfer in excess of 12 in any policy year may apply. We reserve the right to prohibit transfers to the fixed account.

During the income phase, you may transfer values out of any subaccount; however, you cannot transfer values out of the fixed account. The minimum amount that can be transferred during this phase is the lesser of $10 of monthly income, or the entire monthly income of the annuity units in the subaccount from which the transfer is being made.

Transfers made by telephone are subject to the limitations described below under “Telephone Transactions.”

Market Timing and Disruptive Trading

Statement of Policy. This variable insurance product was not designed for the use of market timers or frequent or disruptive traders. (Frequent transfers are

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considered to be disruptive.) Such transfers may be harmful to the underlying fund portfolios and increase transaction costs.

Market timing and disruptive trading among the subaccounts or between the subaccounts and the fixed account can cause risks with adverse effects for other policy owners (and beneficiaries and underlying fund portfolios). These risks and harmful effects include:

(1) dilution of the interests of long-term investors in a subaccount if purchases or transfers into or out of an underlying fund portfolio are made at prices that do not reflect an accurate value for the underlying fund portfolio’s investments (some market timers attempt to do this through methods known as “time-zone arbitrage” and “liquidity arbitrage”);

(2) an adverse effect on portfolio management, such as:

(a) impeding a portfolio manager’s ability to sustain an investment objective;

(b) causing the underlying fund portfolio to maintain a higher level of cash than would otherwise be the case; or

(c) causing an underlying fund portfolio to liquidate investments prematurely (or otherwise at an inopportune time) in order to pay withdrawals or transfers out of the underlying fund portfolio; and

(3) increased brokerage and administrative expenses.

These costs are borne by all policy owners invested in those subaccounts, not just those making the transfers.

We have developed policies and procedures with respect to market timing and disruptive trading (which vary for certain subaccounts at the request of the corresponding underlying fund portfolios) and we do not make special arrangements or grant exceptions to accommodate market timing or potentially disruptive trading. As discussed herein, we cannot detect or deter all market timing or potentially disruptive trading. Do not invest with us if you intend to conduct market timing or potentially disruptive trading.

Detection. We employ various means in an attempt to detect and deter market timing and disruptive trading. However, despite our monitoring we may not be able to detect nor halt all harmful trading. In addition, because other insurance companies (and retirement plans) with different policies and procedures may invest in the underlying fund portfolios, we cannot guarantee that all harmful trading will be detected or that an underlying fund portfolio will not suffer harm from market timing and disruptive trading among subaccounts of variable products issued by these other insurance companies or retirement plans.

Deterrence. If we determine you are engaged in market timing or disruptive trading, we may take one or more actions in an attempt to halt such trading. Your ability to make transfers is subject to modification or restriction if we determine, in our sole opinion, that your exercise of the transfer privilege may disadvantage or potentially harm the rights or interests of other policy owners (or others having an interest in the variable insurance products). As described below, restrictions may take various forms, but under our current policies and procedures will include loss of expedited transfer privileges. We consider transfers by telephone, fax, overnight mail, or the Internet to be “expedited” transfers. This means that we would accept only written transfer requests with an original signature transmitted to us only by U.S. mail. We may also restrict the transfer privileges of others acting on your behalf, including your registered representative or an asset allocation or investment advisory service.

We reserve the right to reject any premium payment or transfer request from any person without prior notice, if, in our judgment, (1) the payment or transfer, or series of transfers, would have a negative impact on an underlying fund portfolio’s operations,

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or (2) if an underlying fund portfolio would reject or has rejected our purchase order or has instructed us not to allow that purchase or transfer, or (3) because of a history of market timing or disruptive trading. We may impose other restrictions on transfers, or even prohibit transfers for any owner who, in our view, has abused, or appears likely to abuse, the transfer privilege on a case-by-case basis. We may, at any time and without prior notice, discontinue transfer privileges, modify our procedures, impose holding period requirements or limit the number, size, frequency, manner, or timing of transfers we permit. Because determining whether to impose any such special restrictions depends on our judgement and discretion, it is possible that some policy owners could engage in disruptive trading that is not permitted for others. We also reserve the right to reverse a potentially harmful transfer if an underlying fund portfolio refuses or reverses our order; in such instances some policy owners may be treated differently than others in that some transfers may be reversed and others allowed. For all of these purposes, we may aggregate two or more variable insurance products that we believe are connected.

Please note: If you engage a third party investment advisor for asset allocation services, then you may be subject to these transfer restrictions because of the actions of your investment advisor in providing these services.

In addition to our internal policies and procedures, we will administer your variable insurance product to comply with any applicable state, federal, and other regulatory requirements concerning transfers. We reserve the right to implement, administer, and charge you for any fee or restriction, including redemption fees, imposed by any underlying fund portfolio. To the extent permitted by law, we also reserve the right to defer the transfer privilege at any time that we are unable to purchase or redeem shares of any of the underlying fund portfolios.

Under our current policies and procedures, we do not:

• impose redemption fees on transfers; or

• expressly limit the number or size of transfers in a given period except for certain subaccounts where an underlying fund portfolio has advised us to prohibit certain transfers that exceed a certain size; or

• provide a certain number of allowable transfers in a given period.

Redemption fees, transfer limits, and other procedures or restrictions may be more or less successful than ours in deterring market timing or other disruptive trading and in preventing or limiting harm from such trading.

In the absence of a prophylactic transfer restriction (e.g., expressly limiting the number of trades within a given period or limiting trades by their size), it is likely that some level of market timing and disruptive trading will occur before it is detected and steps taken to deter it (although some level of market timing and disruptive trading can occur even with a prophylactic transfer restriction). As noted above, we do not impose a prophylactic transfer restriction and, therefore, it is likely that some level of market timing and disruptive trading will occur before we are able to detect it and take steps in an attempt to deter it.

Please note that the limits and restrictions described herein are subject to our ability to monitor transfer activity. Our ability to detect market timing or disruptive trading may be limited by operational and technological systems, as well as by our ability to predict strategies employed by policy owners (or those acting on their behalf) to avoid detection. As a result, despite our efforts to prevent harmful trading activity among the variable investment choices available under this variable insurance product, there is no assurance that we will be able to detect or deter market timing or disruptive trading by such policy owners or intermediaries acting on their behalf. Moreover, our ability to discourage and restrict

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market timing or disruptive trading may be limited by decisions of state regulatory bodies and court orders that we cannot predict.

Furthermore, we may revise our policies and procedures in our sole discretion at any time and without prior notice, as we deem necessary or appropriate (1) to better detect and deter harmful trading that may adversely affect other policy owners, other persons with material rights under the variable insurance products, or underlying fund shareholders generally, (2) to comply with state or federal regulatory requirements, or (3) to impose additional or alternative restrictions on owners engaging in market timing or disruptive trading among the investment choices under the variable insurance product. In addition, we may not honor transfer requests if any variable investment choice that would be affected by the transfer is unable to purchase or redeem shares of its corresponding underlying fund portfolio.

Underlying Fund Portfolio Frequent Trading Policies. The underlying fund portfolios may have adopted their own policies and procedures with respect to frequent purchases and redemptions of their respective shares. Underlying fund portfolios may, for example, assess a redemption fee (which we reserve the right to collect) on shares held for less than a certain period of time. The prospectuses for the underlying fund portfolios describe any such policies and procedures. The frequent trading policies and procedures of an underlying fund portfolio may be different, and more or less restrictive, than the frequent trading policies and procedures of other underlying fund portfolios and the policies and procedures we have adopted for our variable insurance products to discourage market timing and disruptive trading. Policy owners should be aware that we may not have the contractual ability or the operational capacity to monitor policy owners’ transfer requests and apply the frequent trading policies and procedures of the respective underlying funds that would be affected by the transfers.

Accordingly, policy owners and other persons who have material rights under our variable insurance products should assume that any protection they may have against potential harm from market timing and disruptive trading is the protection, if any, provided by the policies and procedures we have adopted for our variable insurance products to discourage market timing and disruptive trading in certain subaccounts.

Policy owners should be aware that we are required to provide to an underlying fund portfolio or its designee, promptly upon request, certain information about the trading activity of individual policy owners, and to restrict or prohibit further purchases or transfers by specific policy owners identified by an underlying fund portfolio as violating the frequent trading policies established for the portfolio.

Omnibus Orders. Policy owners and other persons with material rights under the variable insurance products also should be aware that the purchase and redemption orders received by the underlying fund portfolios generally are “omnibus” orders from intermediaries such as retirement plans and separate accounts funding variable insurance products. The omnibus orders reflect the aggregation and netting of multiple orders from individual retirement plan participants and individual owners of variable insurance products. The omnibus nature of these orders may limit the underlying fund portfolios’ ability to apply their respective frequent trading policies and procedures. We cannot guarantee that the underlying fund portfolios will not be harmed by transfer activity relating to the retirement plans or other insurance companies that may invest in the underlying fund portfolios. These other insurance companies are responsible for their own policies and procedures regarding frequent transfer activity. If their policies and procedures fail to successfully discourage harmful transfer activity, it will affect other owners of underlying fund portfolio shares, as well as the owners of all of the variable annuity or life insurance policies, including ours, whose variable investment choices correspond to the affected

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underlying fund portfolios. In addition, if an underlying fund portfolio believes that an omnibus order we submit may reflect one or more transfer requests from owners engaged in market timing and disruptive trading, the underlying fund portfolio may reject the entire omnibus order and thereby delay or prevent us from implementing your request.

4. PERFORMANCE

The Company periodically advertises performance of the various subaccounts. Performance figures might not reflect charges for options, riders, or endorsements. We may disclose at least three different kinds of non-standard performance. First, we may calculate performance by determining the percentage change in the value of an accumulation unit by dividing the increase (decrease) for that unit by the value of the accumulation unit at the beginning of the period. This performance number reflects the deduction of the mortality and expense risk fees and administrative charges. It does not reflect the deduction of any applicable premium taxes, surrender charges, or fees for any optional riders or endorsements. Any such deduction would reduce the percentage increase or make greater any percentage decrease.

Second, advertisements may also include total return figures, which reflect the deduction of the mortality and expense risk fees and administrative charges. These figures may also include or exclude surrender charges. These figures may also reflect the premium enhancement, if any.

Third, for certain investment portfolios, performance may be shown for the period commencing from the inception date of the investment portfolio (i.e., before commencement of subaccount operations). These figures should not be interpreted to reflect actual historical performance of the subaccounts.

Not all types of performance data presented reflect all of the fees and charges that may be deducted (such as fees for optional benefits); performance figures would be lower if these charges were included.

5. EXPENSES

Note: The following section on expenses and the Annuity Policy Fee Table and Expense Examples only apply to policies issued after the date of this prospectus. See “Appendix – Policy Variations” for information about older policies.

There are charges and expenses associated with your policy that reduce the return on your investment in the policy.

Surrender Charges

During the accumulation phase, you can surrender part or all of the cash value (restrictions may apply to qualified policies). We may apply a surrender charge to compensate us for expenses relating to sales, including commissions to registered representatives and other promotional expenses.

You can surrender up to the greater of (i) 10% of your premium payments or (ii) any gains in the policy once each year free of surrender charges. This amount is referred to as the free amount and is determined at the time of surrender. (The free amount is not cumulative, so not surrendering anything in one year does not increase the surrender charge free amount in subsequent years.) If the surrender is in excess of this free amount, you might have to pay a surrender charge, which is a contingent deferred sales charge, on the excess amount.

The following schedule shows the surrender charges that apply during the nine years following payment of each premium payment:

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Number of Years Since Premium Payment Date	Surrender Charge (as a percentage of premium surrendered)
0 – 1		9	%
1 – 2		8	%
2 – 3		7	%
3 – 4		6	%
4 – 5		5	%
5 – 6		4	%
6 – 7		3	%
7 – 8		2	%
8 – 9		1	%
more than 9		0	%

For example, assume your premium is $100,000 and your policy value is $106,000 at the beginning of the second policy year and you surrender $30,000. Since that amount is more than your free amount ($10,000), you would pay a surrender charge of $1,600 on the remaining $20,000 [8% of ($30,000 -$10,000)].

Likewise, assume your policy value is $80,000 (premium payments $100,000) at the beginning of the second policy year and you surrender your policy. You would pay a surrender charge of $7,200 [8% of ($100,000 - ($100,000 x 10%))].

You can generally choose to receive the full amount of a requested partial surrender by directing us to deduct any applicable surrender charge (and any applicable excess interest adjustment) from your remaining policy value. You receive your cash value upon full surrender.

For surrender charge purposes, earnings are considered to be surrendered first, then the oldest premium is considered to be surrendered next.

Surrender charges are waived if you surrender money under the Nursing Care and Terminal Condition Withdrawal Option or the Unemployment Waiver.

Keep in mind that surrenders may be taxable and, if made before age 59 ¹/2, may be subject to a 10% federal penalty tax. For tax purposes, surrenders from nonqualified policies are considered to come from taxable earnings first.

Life with Emergency Cash^® Surrender Charge

If you select the Life with Emergency Cash^® annuity payment option, then you can surrender your policy even after annuity payments have begun. However, there is a surrender charge during the first four years after the annuity commencement date (no matter which policy or variation thereof you previously purchased). The following schedule shows the current surrender charge:

Number of Years Since Annuity Commencement Date	Surrender Charge (as a percentage of adjusted policy value)
0 – 1		4	%
1 – 2		3	%
2 – 3		2	%
3 – 4		1	%
more than 4		0	%

We can change the surrender charge, and you will be subject to whatever surrender schedule is in effect at the time you annuitize under the Life with Emergency Cash^® annuity payment option.

Note carefully the following three things about this surrender charge:

• this surrender charge is measured from the annuity commencement date and not from the premium payment date;

• this surrender charge is a percentage of the adjusted policy value applied to the Life with Emergency Cash^® annuity payment option, and not a percentage of premium; and

• under this payment option, there is no surrender charge free amount.

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Excess Interest Adjustment

Surrenders and transfers from the fixed account may be subject to an excess interest adjustment. This adjustment could retroactively reduce the interest credited in the fixed account to the guaranteed minimum or increase the amount credited. This adjustment may also apply to amounts applied to an annuity payment option. Please see “Appendix -Excess Interest Adjustment Examples” for an example showing the effect of a hypothetical excess interest adjustment calculation.

Mortality and Expense Risk Fees

We charge a fee as compensation for bearing certain mortality and expense risks under the policy. This fee is assessed daily based on the net asset value of each subaccount. Examples of such risks include a guarantee of annuity rates, the death benefit, certain expenses of the policy, and assuming the risk that the current charges will be insufficient in the future to cover costs of administering the policy. We may also pay distribution expenses out of this charge.

During the accumulation phase:

• For the Return of Premium Death Benefit, the daily mortality and expense risk fee is at an annual rate of 1.50%.

• For the Annual Step-Up Death Benefit, the daily mortality and expense risk fee is at an annual rate of 1.70%.

During the income phase, the mortality and expense risk fee is at an annual rate of 1.10%.

If this charge does not cover our actual costs, we absorb the loss. Conversely, if the charge more than covers actual costs, the excess is added to our surplus. We expect to profit from this charge. We may use any profit for any proper purpose, including distribution expenses.

Premium Taxes

Some states assess premium taxes on the premium payments you make. We currently do not deduct for these taxes at the time you make a premium payment. However, we will deduct the total amount of premium taxes, if any, from the policy value when:

• you begin receiving annuity payments;

• you surrender the policy; or

• a death benefit is paid.

State premium taxes currently range from 0% to 3.50%, depending on the state.

Federal, State and Local Taxes

We may in the future deduct charges from the policy for any taxes we incur because of the policy. However, no deductions are being made at the present time.

Special Service Fees

We will deduct a charge for special services, such as overnight delivery, up to $25 per service provided.

Transfer Fee

You are generally allowed to make 12 free transfers per policy year before the annuity commencement date. If you make more than 12 transfers per year, we reserve the right to charge $10 for each additional transfer. Premium payments, Asset Rebalancing, and Dollar Cost Averaging transfers do not count as one of your free transfers. All transfer requests made at the same time are treated as a single transfer.

Administrative Charges

We deduct a daily administrative charge to cover the costs of administering the policy (including certain distribution-related expenses). This charge is equal to

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an annual rate of 0.15% of the daily net asset value of each subaccount during both the accumulation phase and the income phase.

In addition, during the accumulation phase, an annual service charge of $35 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.

Initial Payment Guarantee

If you elect the Initial Payment Guarantee feature at the time of annuitization, there is a fee (during the income phase) currently at an annual rate of 1.25% of the daily net asset value. This fee may be higher or lower at the time you annuitize and elect the feature.

Fund Facilitation Fee

We charge a fund facilitation fee in order to make certain funds available as investment choices under the policies. We apply the fee to funds that do not provide us with the amount of revenue we require in order for us to meet our expenses and revenue targets. This fee is assessed daily based on the net asset value of subaccounts that we specify. The fund facilitation fee, expressed as an annual rate is:

• 0.30% if you choose the American Funds – Asset Allocation Fund – Class 2

• 0.30% if you choose the American Funds – Bond Fund – Class 2

• 0.30% if you choose the American Funds – Growth Fund – Class 2

• 0.30% if you choose the American Funds – Growth-Income Fund – Class 2

• 0.20% if you choose the AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

• 0.20% if you choose the GE Investments Total Return Fund – Class 3

• 0.10 % if you choose the Transamerica BlackRock Global Allocation VP – Service Class

Additional Death Distribution

If you elect the Additional Death Distribution, there is an annual rider fee during the accumulation phase of 0.25% of the policy value. The rider fee will be deducted on each rider anniversary and upon termination of the rider during the accumulation phase. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Additional Death Distribution+

If you elect the Additional Death Distribution+, there is an annual rider fee during the accumulation phase of 0.55% of the policy value. The rider fee will be deducted on each rider anniversary and upon termination of the rider during the accumulation phase. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Living Benefits Rider

If you elect the Living Benefits Rider, there is an annual rider fee of 0.90% of the “principal back” total withdrawal base on each rider anniversary before annuitization. We will also deduct the rider fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice. Generally, the rider fee is deducted even if your policy value exceeds your total withdrawal base.

We will continue to calculate the rider fee using the “principal back” total withdrawal base even after the “principal back” minimum remaining withdrawal amount reaches zero. The “principal back” total withdrawal base is always greater than or equal to the “for life” total withdrawal base.

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Retirement Income Choice^® 1.2 Rider and Additional Options Fees

If you elect the Retirement Income Choice^® 1.2 rider, then the rider fee, which is charged quarterly before annuitization, depends on the allocation option that you choose. If you choose the Open Allocation option, then the fee for the base benefit (for either single or joint life) is 1.20% ( on an annual basis) of the withdrawal base. If you choose the Designated Investment option, then the fee for the base benefit (for single or joint life) is 1.40%, 1.00%, and 0.45% (on an annual basis) of the withdrawal base for allocating 100% of your policy value in Designated Allocation Allocation Group A, Designated Allocation Group B, or Designated Allocation Group C, respectively. If you elect a combination of designated investment options among various classes, then your fee will be based on a weighted average of your choices. If you elect options with the Retirement Income Choice^® 1.2 rider, then for each option you elect, you will be charged a fee that is a percentage of the withdrawal base on each rider quarter before annuitization, and is in addition to the rider fee for the base benefit. The additional fees, on an annual basis, are as follows:

Options	Single Life Option			Joint Life Option
Death Benefit		0.25	%		0.20	%
Income Enhancement Benefit		0.15	%		0.30	%

We will also deduct any rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Retirement Income Choice^® 1.4 Rider and Additional Options Fees – This Rider is No Longer Available for New Sales

If you elect the Retirement Income Choice^® 1.4 rider, then the rider fee, which is charged quarterly before annuitization, is 1.40%, 1.00%, and 0.45% (on an annual basis) of the withdrawal base for allocating 100% of your policy value in Designated Allocation Allocation Group A, Designated Allocation Group B, or Designated Allocation Group C, respectively. If you elect a combination of designated investment options among various classes, then your fee will be based on a weighted average of your choices. If you elect options with the Retirement Income Choice^® 1.4 rider, then for each option you elect, you will be charged a fee that is a percentage of the withdrawal base on each rider quarter before annuitization, and is in addition to the rider fee for the base benefit. The additional fees, on an annual basis, are as follows:

	Single Life			Joint Life
Options	Option			Option
Death Benefit		0.25	%		0.20	%
Income Enhancement Benefit		0.15	%		0.30	%

We will also deduct any rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Income Link^® Rider Fee

If you elect the Income Link^® rider, then the rider fee, which is charged quarterly before annuitization, is 0.90% (on an annual basis) of the withdrawal base.

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We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Retirement Income Max^SM Rider Fees

If you elect the Retirement Income Max^SM rider, then the rider fee, which is charged quarterly before annuitization, is 1.00% (on an annual basis) of the withdrawal base. We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider. The rider fee(s) is deducted from each investment choice in proportion to the amount of policy value in each investment choice.

Portfolio Fees and Expenses

The value of the assets in each subaccount will reflect the fees and expenses paid by the underlying fund portfolios. The lowest and highest fund expenses for the previous calendar year are found in the Annuity Policy Fee Table section of this prospectus. See the prospectuses for the underlying fund portfolios for more information.

Revenue We Receive

This prospectus describes generally the payments that we (and/or our affiliates) may directly or indirectly receive from the underlying fund portfolios, their advisers, subadvisers, distributors or affiliates thereof, in connection with certain administrative, marketing and other support services we (and/or our affiliates) provide and expenses we incur in offering and selling our variable insurance products. These arrangements are sometimes referred to as “revenue sharing” arrangements and are described further below. While only certain of the types of payments described below may be made in connection with your particular policy, all such payments may nonetheless influence or impact actions we (and/or our affiliates) take, and recommendations we (and our affiliates) make, regarding each of the variable insurance products that we (and our affiliates) offer, including your policy.

We (and/or our affiliates) may receive some or all of the following types of payments:

• Rule 12b-1 Fees. Our affiliate Transamerica Capital, Inc. (“TCI”) is the principal underwriter for the policies and directly or indirectly receives some or all of the 12b-1 fees from the funds available as investment choices under our variable insurance products. Any 12b-1 fees received by TCI that are attributable to our variable insurance products are then credited to us. These fees range from 0.00% to 0.25% of the average daily assets of the certain underlying fund portfolios attributable to the policies and to certain other variable insurance products that we and our affiliates issue.

• Administrative, Marketing and Support Service Fees (“Support Fees”). As noted above, an investment adviser, sub-adviser, administrator and/or distributor (or affiliates thereof) of the underlying fund portfolios may make payments to us and/or our affiliates, including TCI. These payments may be derived, in whole or in part, from the profits the investment advisor or sub-adviser realized on the advisory fee deducted from underlying fund portfolio assets. Policy owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees (see the prospectuses for the underlying funds for more information). The amount of the payments we (or our affiliates) receive is generally based on a percentage of the assets of the particular underlying fund portfolios attributable to the policy and to certain other variable insurance products that our affiliates and we issue. These percentages differ and the amounts may be significant. Some advisers or sub-advisers (or other affiliates) pay us more than others.

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The following chart provides the maximum combined percentages of 12b-1 fees and Support Fees that we anticipate will be paid to us on an annual basis. Please note: Some of the underlying funds listed in the chart below may not currently be available under your policy:

Incoming Payments to the Company and/or TCI

Fund	Maximum Fee % of assets
TRANSAMERICA SERIES TRUST		0.25	%
AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS)		0.50	%
ALLIANCEBERNSTEIN VARIABLE PRODUCTS SERIES FUND, INC.		0.45	%
AMERICAN FUNDS INSURANCE SERIES® TRUST		0.25	%
FIDELITY® VARIABLE INSURANCE PRODUCTS FUND		0.35	%
FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST		0.35	%
GE INVESTMENTS FUNDS, INC.		0.45	%

NOTES TO INCOMING PAYMENTS TABLE:

Maximum Fee % of Assets: Payments are based on a percentage of the average assets of each underlying fund portfolio owned by the subaccounts available under this policy and under certain other variable insurance products offered by our affiliates and us. We and/or TCI may continue to receive 12b-1 fees and administrative fees on subaccounts that are closed to new investments, depending on the terms of the agreements supporting those payments and on the services we and TCI provide.

Transamerica Series Trust (“TST”): Because TST is managed by Transamerica Asset Management, Inc. (“TAM”), an affiliate of ours, there are additional benefits to us and our affiliates for amounts you allocate to the TST underlying fund portfolios, in terms of our and our affiliates’ overall profitability. These additional benefits may be significant. Payments or other benefits may be received from TAM. Such payments or benefits may be entered into for a variety of purposes, such as to allocate resources to us to provide administrative services to the policyholders who invest in the TST underlying fund portfolios. These payments or benefits may take the form of internal credits, recognition, or cash payments. A variety of financial and accounting methods may be used to allocate resources and profits to us. Additionally, if a TST portfolio is sub-advised by an entity that is affiliated with us, we may retain more revenue than on those TST portfolios that are sub-advised by non-affiliated entities. During 2010 we received $72,069,379 in benefits from TAM pursuant to these arrangements. This includes the 0.25% amount in the above chart. We anticipate receiving comparable amounts in the future.

Fidelity^® Variable Insurance Products Fund: We receive this percentage once $100 million in fund shares are held by the subaccounts of the Company and its affiliates.

• Other Payments. TCI also serves as the wholesale distributor for the policies, and in that capacity directly or indirectly receives additional amounts or different percentages of assets under management from certain advisers and sub-advisers to the underlying fund portfolios (or their affiliates) with regard to variable insurance products and/or mutual funds that are issued by us and our affiliates. These amounts may be derived, in whole or in part, from the profits the investment adviser or sub-adviser receives from the advisory fee deducted from underlying fund portfolio assets. Policy owners, through their indirect investment in the underlying fund portfolios, bear the costs of these advisory fees. Certain advisers and sub-advisers of the underlying fund portfolios (or their affiliates):

• may each directly or indirectly pay TCI amounts up to $75,000 per year to participate in a “preferred sponsor” program that provides such advisers and sub-advisers with access to TCI’s wholesalers at TCI’s national and regional sales conferences as well as internal and external meetings and events that are attended by TCI’s wholesalers and/or other TCI employees.

• may provide our affiliates and/or selling firms with wholesaling services to assist us in the distribution of the policies.

• may provide us and/or certain affiliates and/or selling firms with occasional gifts, meals, tickets or other compensation as an incentive to market the underlying fund portfolios and to assist with their promotional efforts. The amounts may be significant and these arrangements provide the adviser or subadviser (or other affiliates) with increased access to us and to our

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affiliates involved in the distribution of the policies.

For the calendar year ended December 31, 2010, TCI or its affiliates received total revenue sharing payments in the amount of $1,769,559 from the following Fund managers and/or sub-advisers to participate in TCI’s events: Alliance Bernstein Investments, American Funds, BlackRock Investment Management, LLC., BNY Melon, , Federated Equity Management Co, of PA, Fidelity Investments, Foxhall Capital Management, Franklin Templeton Investments, GE Asset Management, Hanlon Investment Management Inc., ING Clarion Real Estate Securities, Invesco AIM, Janus Capital, Jennison Associates, JPMorgan Investment Management, Loomis, Sayles & Company, MFS Investment Management, Neuberger Berman Management, Oppenheimer Funds, Pacific Investment Management Company, Putnam, Schroder Investment Management North America, Transamerica Investment Management, Van Kampen Investments, Vanguard, Wellington Management Company. Please note some of the aforementioned managers and/or subadvisors may not be associated with underlying fund portfolios currently available in this product.

Proceeds from certain of these payments by the underlying fund portfolios, the advisers, the sub-advisers and/or their affiliates may be used for any corporate purpose, including payment of expenses (1) that we and our affiliates incur in promoting, marketing, and administering the policy, and (2) that we incur, in our role as intermediary, in promoting, marketing, and administering the underlying fund portfolios. We and our affiliates may profit from these payments.

For further details about the compensation payments we make in connection with the sale of the policies, see “Distribution of the Policies” in this prospectus.

6. ACCESS TO YOUR MONEY

During the accumulation phase, you can have access to the money in your policy in the following ways:

• by making a surrender (either a full or partial surrender); or

• by taking systematic payouts (See “Section 10, Systematic Payout Option” for more details).

Surrenders

If you take a full surrender, you will receive your cash value.

If you want to take a partial surrender, in most cases it must be for at least $500. Unless you tell us otherwise, we will take the surrender from each of the investment choices in proportion to the policy value.

You may elect to take up to the free amount once each policy year without incurring a surrender charge. Remember that any surrender you take will reduce the policy value, and the amount of the death benefit. See “Section 8, Death Benefit”, for more details. A partial surrender also may have a negative impact on certain other benefits and guarantees of your Contract.

Surrenders from qualified policies may be restricted or prohibited.

Surrenders may be subject to a surrender charge. Surrenders from the fixed account may be subject to an excess interest adjustment. Income taxes, federal tax penalties and certain restrictions may apply to any surrenders you make.

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During the income phase, you will receive annuity payments under the annuity payment option you select; however, you generally may not take any other surrenders, either full or partial, unless you elect a Life with Emergency Cash^® payment option.

If your policy was issued pursuant to a 403(b) plan, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders, loans or transfers you request comply with applicable tax requirements and to decline requests that are not in compliance. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender, loan or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) contracts or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Delay of Payment and Transfers

Payment of any amount due from the separate account for a surrender, a death benefit, or the death of the owner of a nonqualified policy, will generally occur within seven days from the date we receive in good order all required information at our Administrative and Service Office. We may defer such payment from the separate account if:

• the New York Stock Exchange is closed other than for usual weekends or holidays or trading on the Exchange is otherwise restricted;

• an emergency exists as defined by the SEC or the SEC requires that trading be restricted; or

• the SEC permits a delay for the protection of owners.

Transfers of amounts from the subaccounts also may be deferred under these circumstances. In addition, if, pursuant to SEC rules, the Transamerica AEGON Money Market VP portfolio suspends payment of redemption proceeds in connection with a liquidation of the portfolio, then we may delay payment of any transfer, partial withdrawal, surrender, loan, or death benefit from the Transamerica AEGON Money Market VP portfolio until the portfolio is liquidated.

Any payment or transfer request which is not in good order will cause a delay.

Federal laws designed to counter terrorism and prevent money laundering by criminals might in certain circumstances require us to reject a premium payment and/or “freeze” a policy owner’s account. If these laws apply in a particular situation, we would not be allowed to pay any request for withdrawals, surrenders, or death benefits, make transfers, or continue making annuity payments absent instructions from the appropriate federal regulator. We may also be required to provide information about you and your policy to government agencies or departments.

Pursuant to the requirements of certain state laws, we reserve the right to defer payment of the cash value from the fixed account for up to six months. We may defer payment of any amount until your premium payment check has cleared your bank.

Excess Interest Adjustment

Money that you transfer out of or surrender from a guaranteed period option of the fixed account before the end of its guaranteed period (the number of years you specified the money would remain in the guaranteed period option) may be subject to an excess interest adjustment. At the time you request a transfer or surrender (either full or partial), if interest rates set by the Company have risen since the date of the initial guarantee, the excess interest adjustment will result in a lower cash value on surrender or transfer. However, if interest rates have fallen since the date of the initial guarantee, the excess interest adjustment will result in a higher cash value on surrender or transfer. Please see “Appendix - Excess

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Interest Adjustment Examples” to see how the excess interest adjustment is calculated and illustrative examples using hypothetical values.

Any amount surrendered in excess of the cumulative interest credited is generally subject to an excess interest adjustment. An excess interest adjustment may also be made on amounts applied to an annuity payment option.

There will be no excess interest adjustment on any of the following:

• surrenders of cumulative interest credited;

• Nursing Care and Terminal Condition Withdrawal Option surrenders;

• Unemployment Waiver surrenders;

• surrenders to satisfy any minimum distribution requirements; and

• Systematic Payout Option payments, which do not exceed cumulative interest credited at the time of payment.

Please note that in these circumstances you will not receive a higher cash value if interest rates have fallen nor will you receive a lower cash value if interest rates have risen.

The excess interest adjustment may vary for certain policies and may not be applicable for all policies.

Signature Guarantee

As a protection against fraud, we require a signature guarantee (i.e., Medallion Signature Guarantee or Notary Public Stamp as required by us) for the following transaction requests:

• Any surrenders over $250,000;

• Certain surrenders on or within 15 days of an address change;

• Any disbursement request made on or within 15 days of an ownership change;

• Any surrender when the Company has been directed to send proceeds to a different personal address from the address of record for that contract owner’s account. PLEASE NOTE: This requirement will not apply to requests made in connection with exchanges of one annuity for another with the same owner in a “tax-free exchange”;

• Any surrender when the Company does not have an originating or guaranteed signature on file;

• Any other transaction where we require.

We may change the specific requirements listed above, or add signature guarantees in other circumstances, in our discretion if we deem it necessary or appropriate to help protect against fraud. For current requirements, please refer to the requirements listed on the appropriate form or call us at (800) 552-6205.

You can obtain a Medallion signature guarantee from more than 7,000 financial institutions across the United States and Canada that participate in a Medallion signature guarantee program. This includes many:

• National and state banks;

• Savings banks and savings and loan associations;

• Securities brokers and dealers; and

• Credit Unions.

The best source of a Medallion signature guarantee is a bank, savings and loan association, brokerage firm, or credit union with which you do business. Guarantor firms may, but frequently do not, charge a fee for their services.

A notary public cannot provide a Medallion signature guarantee. Notarization will not substitute for a Medallion signature guarantee.

7. ANNUITY PAYMENTS (THE INCOME PHASE)

You choose the annuity commencement date. You can change this date by giving us notice with the information we need. New annuity commencement

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dates less than 30 days after we receive notice of the change require prior approval. The latest maximum annuity commencement date generally cannot be after the policy month following the month in which the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy.

Before the annuity commencement date, if the annuitant is alive, you may choose an annuity payment option or change your election. If the annuitant dies before the annuity commencement date, the death benefit is payable in a lump sum or under one of the annuity payment options (unless the surviving spouse continues the policy).

Unless you specify otherwise, the annuitant will receive the annuity payments. After the annuitant’s death, the beneficiary you designate at annuitization will receive any remaining guaranteed payments.

Annuity Payment Options

The policy provides several annuity payment options that are described below. You may choose any combination of annuity payment options. We will use your adjusted policy value to provide these annuity payments. If the adjusted policy value on the annuity commencement date is less than $2,000, we reserve the right to pay it in one lump sum in lieu of applying it under an annuity payment option. You can receive annuity payments monthly, quarterly, semi-annually, or annually. (We reserve the right to change the frequency if payments would be less than $50.)

If you choose to receive fixed payments, then the amount of each payment will be set on the annuity commencement date and will not change. You may, however, choose to receive variable payments. The dollar amount of the first variable payment will be determined in accordance with the annuity payment rates set forth in the applicable table contained in the policy. The dollar amount of additional variable payments will vary based on the investment performance of the subaccount(s) you select. The dollar amount of each variable payment after the first may increase, decrease, or remain constant. If the actual investment performance (net of fees and expenses) exactly matched the assumed investment return of 5% at all times, the amount of each variable annuity payment would remain constant. If actual investment performance (net of fees and expenses) exceeds the assumed investment return, the amount of the variable annuity payments would increase. Conversely, if actual investment performance (net of fees and expenses) is lower than the assumed investment return, the amount of the variable annuity payments would decrease. Please note that these changes only occur annually under the Initial Payment Guarantee.

A charge for premium taxes and an excess interest adjustment may be made when annuity payments begin.

The annuity payment options are explained below. Some options are fixed only and some can be fixed or variable.

Income for a Specified Period (fixed only). We will make level payments only for a fixed period. No funds will remain at the end of the period.

If your policy is a qualified policy, this payment option may not satisfy minimum required distribution rules. Consult a tax advisor before electing this option.

Income of a Specified Amount (fixed only). Payments are made for any specified amount until the amount applied to this option, with interest, is exhausted. This will be a series of level payments followed by a smaller final payment.

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If your policy is a qualified policy, this payment option may not satisfy minimum required distribution rules. Consult a tax advisor before electing this option.

Life Income. You may choose between:

• No Period Certain (fixed or variable)-Payments will be made only during the annuitant’s lifetime.

• 10 Years Certain (fixed or variable)-Payments will be made for the longer of the annuitant’s lifetime or ten years.

• Guaranteed Return of Policy Proceeds (fixed only)-Payments will be made for the longer of the annuitant’s lifetime or until the total dollar amount of payments we made to you equals the annuitized amount.

• Life with Emergency Cash^® (fixed or variable)-Payments will be made during the annuitant’s lifetime. With the Life with Emergency Cash^® feature, you are able to surrender all or a portion of the Life with Emergency Cash^® benefit. The amount you surrender must be at least $2,500. We will provide you with a Life with Emergency Cash^® benefit schedule that will assist you in estimating the amount you have available to surrender. A partial surrender will reduce all future payments pro rata. A surrender charge may apply and there may be tax consequences (consult a tax advisor before requesting a full or partial surrender). The maximum surrender charge is 4% of the annuitized amount (see “Expenses” for the surrender charge schedule). You will be subject to whatever surrender schedule is in effect at the time you annuitize under this annuity payment option. The Life with Emergency Cash^® benefit will continue through age 100 of the annuitant.

The Life with Emergency Cash^® benefit is also a death benefit that is paid upon the death of the annuitant and is generally equal to the surrender value without any surrender charges. For qualified policies the death benefit ceases on the date the annuitant reaches the IRS age limitation.

Joint and Survivor Annuity. You may choose:

• No Period Certain (fixed or variable)-Payments are made during the joint lifetime of the annuitant and a joint annuitant of your selection. Payments will be made as long as either person is living.

• Life with Emergency Cash^® (fixed or variable)-Payments will be made during the joint lifetime of the annuitant and a joint annuitant of your selection. Payments will be made as long as either person is living. With the Life with Emergency Cash^® feature, you are able to surrender all or a portion of the Life with Emergency Cash^® benefit. The amount you surrender must be at least $2,500. We will provide you with a Life with Emergency Cash^® benefit schedule that will assist you in estimating the amount you have available to surrender. A partial surrender will reduce all future payments pro rata. A surrender charge may apply and there may be tax consequences (consult a tax advisor before requesting a full or partial surrender). The maximum surrender charge is 4% of the annuitized amount (see “Expenses” for the surrender charge schedule). You will be subject to whatever surrender schedule is in effect at the time you annuitize under this annuity payment option. The Life with Emergency Cash^® benefit will continue through age 100 of the surviving joint annuitant.

The Life with Emergency Cash^® benefit is also a death benefit that is paid upon the death of the surviving joint annuitant and is generally equal to the surrender value without any surrender charges. For qualified policies the death benefit ceases on the date the surviving joint annuitant reaches the IRS joint age limitation.

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Other annuity payment options may be arranged by agreement with the Company. Some annuity payment options may not be available for all policies.

NOTE CAREFULLY

IF:

• you choose Life Income with No Period Certain or a Joint and Survivor Annuity with No Period Certain; and

• the annuitant dies (or both joint annuitants die) before the due date of the second (third, fourth, etc.) annuity payment;

THEN:

• we may make only one (two, three, etc.) annuity payments.

IF:

• you choose Income for a Specified Period, Life Income with 10 Years Certain, Life Income with Guaranteed Return of Policy Proceeds, or Income of a Specified Amount; and

• the person receiving payments dies prior to the end of the guaranteed period;

THEN:

• the remaining guaranteed payments will be continued to a new payee, or their present value may be paid in a single sum.

However, IF:

• you choose Life with Emergency Cash^®; and

• the annuitant dies (if both joint annuitants die) before age 101;

THEN:

• a Life with Emergency Cash^® death benefit will be paid.

We will not pay interest on amounts represented by uncashed annuity payment checks if the postal or other delivery service is unable to deliver checks to the payee’s address of record. The person receiving payments is responsible for keeping the Company informed of his/her current address.

You must annuitize your policy no later than the maximum annuity commencement date specified in your policy (earlier for certain distribution channels). If you do not elect an annuity payment option, the default option will be Life with 10 Years Certain option. Please note, all optional benefits (including guaranteed minimum death benefits and living benefits) terminate upon annuitization.

8. DEATH BENEFIT

We will pay a death benefit to your beneficiary, under certain circumstances, if the annuitant dies during the accumulation phase. If there is a surviving owner(s) when the annuitant dies, the surviving owner(s) will receive the death benefit instead of the listed beneficiary. The person receiving the death benefit may choose an annuity payment option, or may choose to receive a lump sum.

We will determine the amount of and pay the death benefit proceeds, if any are payable on a policy, upon receipt at our Administrative and Service Office of satisfactory proof of the annuitant’s death, written directions from each eligible recipient of death benefit proceeds regarding how to pay the death benefit, and any other documents, forms and information that we need (collectively referred to as “due proof of death”).

Please Note: Such due proof of death must be submitted in good order to avoid a delay in processing the death benefit claim.

The death benefit proceeds remain invested in the separate account in accordance with the allocations made by the policy owner until the beneficiary has provided us with due proof of death. Once the Company receives due proof of death, then investments in the separate account may be reallocated in accordance with the beneficiary’s instructions. The Company may permit the beneficiary to give a “one-time” instruction to reallocate the investments in the separate account to

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the money market fund after the death of the annuitant but before receiving due proof of death. If there is more than one beneficiary, all beneficiaries must agree to the reallocation instructions.

When We Pay A Death Benefit

We will pay a death benefit IF:

• you are both the annuitant and sole owner of the policy; and

• you die before the annuity commencement date.

We will pay a death benefit to you (owner) IF:

• you are not the annuitant; and

• the annuitant dies before the annuity commencement date.

If the only person receiving the death benefit is the surviving spouse, then he or she may elect to continue the policy as the new annuitant and owner, instead of receiving the death benefit. All surrender charges will be waived.

When We Do Not Pay A Death Benefit

We will not pay a death benefit IF:

• you are not the annuitant; and

• you die prior to the annuity commencement date.

Please note the new owner (unless it is the deceased owner’s spouse) must generally surrender the policy within five years of your death.

Distribution requirements apply to the policy value upon the death of any owner. These distribution requirements are detailed in the SAI.

Deaths After the Annuity Commencement Date

The death benefit payable, if any, on or after the annuity commencement date depends on the annuity payment option selected.

IF:

• you are not the annuitant; and

• you die on or after the annuity commencement date; and

• the entire interest in the policy has not been paid;

THEN:

• the remaining portion of such interest in the policy will continue to be distributed at least as rapidly as under the method of distribution being used as of the date of your death.

IF:

• annuity payments are being made under the Life with Emergency Cash^®; and

• the annuitant dies before age 101 (or earlier, if a qualified policy);

THEN:

• a Life with Emergency Cash^® death benefit will be paid.

Succession of Ownership

If an owner dies during the accumulation phase, the person or entity first listed below who is alive or in existence on the date of that death will become the new owner:

• any surviving owner;

• primary beneficiary;

• contingent beneficiary; or

• owner’s estate.

Amount of Death Benefit

Death benefit provisions may differ from state to state. The death benefit may be paid as a lump sum or as annuity payments. The amount of the death benefit depends on the guaranteed minimum death benefit option, if any, you choose when you buy the policy. The “base policy” death benefit will generally be the greatest of:

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• the policy value on the date we receive the required information in good order at our Administrative and Service Office;

• the cash value on the date we receive the required information in good order at our Administrative and Service Office (this will be more than the policy value if there is a positive excess interest adjustment);

• and the guaranteed minimum death benefit (discussed below), plus premium payments (after the date of death), less adjusted partial surrenders, from the date of death to the date the death benefit is paid. Please see “Appendix – Death Benefit” for illustrative examples regarding Death Benefit calculations.

Please note, the death benefit terminates upon annuitization and there is a maximum annuity commencement date.

Guaranteed Minimum Death Benefit

NOTE: The following generally applies, depending on the state of issue, to policies issued after the date of this prospectus.

Annual Step-Up Death Benefit

Under this option, on each policy anniversary prior to your 81st birthday, a new “stepped-up” death benefit is determined and becomes the guaranteed minimum death benefit for that policy year. This “step-up” death benefit is equal to:

• the largest policy value on the policy date or on any policy anniversary prior to the earlier of the annuitant’s date of death or the annuitant’s 81st birthday; plus

• any premium payments since the date of any policy anniversary with the largest policy value; minus

• any adjusted partial surrenders since the date of the policy anniversary with the largest policy value.

The Annual Step-Up Death Benefit is not available if you or the annuitant is 76 or older on the policy date. There is an extra charge for this death benefit of 0.20% annually.

Return of Premium Death Benefit

The Return of Premium Death Benefit is equal to:

• total premium payments; less

• any adjusted partial surrenders as of the date of death.

This benefit is not available if you or the annuitant is 91 or older on the policy date. The Return of Premium Death Benefit will be in effect if you do not choose another death benefit option when you purchase your policy.

Please note: You will not receive an optional guaranteed minimum death benefit if you do not choose one when you purchase your policy.

The Guaranteed Minimum Death Benefit may vary for certain policies and may not be available for all policies. This disclosure explains the material features of the Guaranteed Minimum Death Benefit. The application and operation of the Guaranteed Minimum Death Benefit are governed by the terms and conditions of the policy form and riders.

Adjusted Partial Surrender

When you request a partial surrender, your guaranteed minimum death benefit will be reduced by an amount called the adjusted partial surrender. Under certain circumstances, the adjusted partial surrender may be more than the dollar amount of your surrender request. This will generally be the case if the guaranteed minimum death benefit exceeds the policy value at the time of surrender. It is also possible that if a death benefit is paid after you have made a partial surrender, then the total amount paid could be less than the total premium payments. We

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have included a detailed explanation of this adjustment in the “Appendix – Death Benefit.” This is referred to as “adjusted partial surrender” in your policy. If you have a qualified policy, minimum required distributions rules may require you to request a partial surrender.

9. TAXES

NOTE: We have prepared the following information on federal income taxes as a general discussion of the subject. It is not intended as tax advice to any individual. No attempt is made to consider any applicable state or other income tax laws, any state and local estate or inheritance tax, or other tax consequences of ownership or receipt of distributions under the policy. You should consult your own tax adviser about your own circumstances. We have included an additional discussion regarding taxes in the SAI.

Annuity Policies in General

Deferred annuity policies are a way of setting aside money for future needs like retirement. Congress recognized how important saving for retirement is and provided special rules in the Internal Revenue Code for annuities.

Simply stated, these rules generally provide that individuals will not be taxed on the earnings, if any, on the money held in an annuity policy until taken out. This is referred to as tax deferral. When a non-natural person (e.g., corporation or certain other entities other than tax-qualified trusts) owns a nonqualified policy, the policy will generally not be treated as an annuity for tax purposes.

There are different rules as to how you will be taxed depending on how you take the money out and the type of policy-qualified or nonqualified.

You will generally not be taxed on increases in the value of your policy until a distribution occurs (either as a surrender or as annuity payments).

Qualified and Nonqualified Policies

If you purchase the policy under an individual retirement annuity, a 403(b) plan, a pension plan, or specially sponsored program, your policy is referred to as a qualified policy.

Qualified policies are issued in connection with the following:

• Individual Retirement Annuity (IRA): A traditional IRA allows individuals to make contributions, which may be deductible, to the policy. A Roth IRA also allows individuals to make contributions to the policy, but it does not allow a deduction for contributions, and distributions may be tax-free if the owner meets certain rules.

• Tax-Sheltered Annuity (403(b) Plan): A 403(b) Plan may be made available to employees of certain public school systems and tax-exempt organizations and permits contributions to the policy on a pre-tax basis. Pursuant to new tax regulations, starting January 1, 2009 the policy is not available for purchase under a 403(b) plan and we do not accept additional premiums or transfers to existing 403(b) policies. We generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders, loans or transfers you request from an existing 403(b) policy comply with applicable tax requirements before we process your request.

• Corporate Pension and Profit-Sharing and H.R. 10 Plan: Employers and self-employed individuals can establish pension or profit-sharing plans for their employees or themselves and make contributions to the policy on a pre-tax basis.

• Deferred Compensation Plan (457 Plan): Certain governmental and tax-exempt

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organizations can establish a plan to defer compensation on behalf of their employees through contributions to the policy.

There is no additional tax deferral benefit derived from placing qualified funds into a variable annuity. Features other than tax deferral should be considered in the purchase of a qualified policy. There are limits on the amount of contributions you can make to a qualified policy. Other restrictions may apply including terms of the plan in which you participate.

Optional death benefit features in some cases may exceed the greater of the premium payments or the policy value. Such a death benefit could be characterized as an incidental benefit, the amount of which is limited in any pension or profit-sharing plan or 403(b) plan. Because an optional death benefit may exceed this limitation, anyone using the policy in connection with such plans should consult their tax adviser before purchasing an optional death benefit. The Internal Revenue Service has not reviewed the policy for qualification as an IRA, and has not addressed in a ruling of general applicability whether the death benefit options and riders available, with the policy, if any, comport with IRA qualification requirements. The value of death benefit options and riders elected may need to be considered in calculating minimum required distributions.

If you purchase the policy as an individual and not under an individual retirement annuity, 403(b) plan, 457 plan, or pension or profit sharing plan, your policy is referred to as a nonqualified policy.

Surrenders-Qualified Policies Generally

There are special rules that govern qualified policies. Generally, these rules restrict:

• the amount that can be contributed to the policy during any year;

• the time when amounts can be paid from the policy; and

• the amount of any death benefit that may be allowed.

In the case of a withdrawal under a qualified policy, a pro rata portion of the amount you receive is taxable, generally based on the ratio of your “investment in the contract” to your total account balance or accrued benefit under the retirement plan. Your “investment in the contract” generally equals the amount of any non-deductible purchase payments made by you or on your behalf. In some cases, your “investment in the contract” can be zero.

In addition, a penalty tax may be assessed on amounts surrendered from the policy prior to the date you reach age 59 ¹/2, unless you meet one of the exceptions to this rule. You may also be required to begin taking minimum distributions from the policy by a certain date. The terms of the plan may limit the rights otherwise available to you under the policy. We have provided more information in the SAI.

We may make available under the policy certain guaranteed lifetime withdrawal and other optional benefits. The tax rules for qualified policies may limit the value of these optional benefits. For example, if you elect a guaranteed lifetime withdrawal benefit and your minimum required distribution amount exceeds your guaranteed withdrawal amount, you will have to withdraw more than the guaranteed withdrawal amount to avoid imposition of a 50% excise tax. It is not clear whether guaranteed lifetime withdrawal benefit payments made during the settlement phase will be taxed as withdrawals or as annuity payments. In view of this uncertainty, we will apply the non-annuity rules for determining minimum required distributions, meaning that a percentage of the value of all benefits under the policy will need to be withdrawn each year. The value may have to include the value of enhanced death benefits and other optional policy provisions such as the guaranteed lifetime withdrawal benefit rider itself.

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If you are attempting to satisfy minimum required distribution rules through partial surrenders, the value of any enhanced death benefit or other optional rider may need to be included in calculating the amount required to be distributed.

The Internal Revenue Code generally requires that interests in a qualified policy be nonforfeitable. If your policy contains a bonus rider with a recapture, forfeiture, or “vesting” feature, it may not be consistent with those requirements. Consult a tax advisor before purchasing a bonus rider as part of a qualified policy.

You should consult your legal counsel or tax adviser if you are considering purchasing an enhanced death benefit or other optional rider, or if you are considering purchasing a policy for use with any qualified retirement plan or arrangement.

Surrenders-403(b) Policies

The rules described above for qualified policies generally apply to 403(b) policies. However, specific rules apply to surrenders from certain 403(b) policies. Partial withdrawals and surrenders can generally only be made when an owner:

• reaches age 59 ¹/2;

• leaves his/her job;

• dies;

• becomes disabled (as that term is defined in the Internal Revenue Code); or

• declares hardship. However, in the case of hardship, the owner can only surrender the premium payments and not any earnings.

Please Note: In some instances the signature of the employer may be required. For policies issued after 2008, amounts attributable to nonelective contributions may be subject to distribution restrictions specified in the employer’s section 403(b) plan.

Pursuant to new tax regulations, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders or transfers you request from a 403(b) policy comply with applicable tax requirements before we process your request. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) policies or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Defaulted loans from Code Section 403(b) arrangements, and pledges and assignments of qualified policies generally are taxed in the same manner as surrenders from such policies. Please refer to the SAI for further information applicable to distributions from 403(b) policies. Please note that a defaulted loan may stop the growth on a guaranteed lifetime withdrawal benefit.

Surrenders-Nonqualified Policies

The information above describing the taxation of qualified policies does not apply to nonqualified policies. If you take a partial withdrawal or surrender (including systematic payouts and payouts under an optional feature, if any) from a nonqualified policy before the annuity commencement date, the Internal Revenue Code treats that surrender as first coming from earnings and then from your premium payments. If your policy contains an excess interest adjustment feature (also known as a market value adjustment), then your account value immediately before the surrender may have to be increased by any positive excess interest adjustments that result from the surrender. There is, however, no definitive guidance on the proper tax treatment of excess interest adjustments, and you may want to discuss the potential tax consequences of an excess interest adjustment with your tax advisor.

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When you make a surrender you are taxed on the amount of the surrender that is earnings. If you make a surrender, you are generally taxed on the amount that your surrender proceeds exceeds the “investment in the contract,” which is generally your premiums paid (adjusted for any prior surrenders or portions thereof that were not taxable). In general, loans, pledges, and assignments are taxed in the same manner as partial withdrawals and surrenders. Different rules apply for annuity payments. See “Annuity Payments” below.

The Internal Revenue Code also provides that surrendered earnings may be subject to a penalty tax. The amount of the penalty tax is equal to 10% of the amount that is includable in income. Some surrenders will be exempt from the penalty tax. They include, among others, any amounts:

• paid on or after the taxpayer reaches age 59 ¹/2;

• paid after an owner dies;

• paid if the taxpayer becomes disabled (as that term is defined in the Internal Revenue Code);

• paid in a series of substantially equal payments made annually (or more frequently) under a lifetime annuity;

• paid under an immediate annuity; or

• which come from premium payments made prior to August 14, 1982.

If your nonqualified policy contains a guaranteed lifetime withdrawal benefit rider, certain rules may apply. It is not clear whether guaranteed lifetime withdrawal benefit payments made during the settlement or income (payout) phase may be taxed as either withdrawals or annuities. In view of this uncertainty, we intend to adopt a conservative approach and treat guaranteed lifetime withdrawal payments during the settlement phase under nonqualified policies as withdrawals. Consult a tax advisor before purchasing a guaranteed lifetime withdrawal benefit rider or option.

All nonqualified deferred annuity policies that are issued by us (or our affiliates) to the same owner during any calendar year are treated as one annuity for purposes of determining the amount includable in the owner’s income when a taxable distribution occurs.

Taxation of Death Benefit Proceeds

Amounts may be distributed from the policy because of the death of the annuitant. Generally, such amounts should be includable in the income of the recipient:

• if distributed in a lump sum, these amounts are taxed in the same manner as a surrender; or

• if distributed under an annuity payment option, these amounts are taxed in the same manner as annuity payments.

Annuity Payments

Although the tax consequences may vary depending on the annuity payment option you select, in general, for nonqualified and certain qualified policies, only a portion of the annuity payments you receive will be includable in your gross income.

In general, the excludable portion of each annuity payment you receive will be determined as follows:

• Fixed payments-by dividing the “investment in the contract” on the annuity commencement date by the total expected value of the annuity payments for the term of the payments. This is the percentage of each annuity payment that is excludable.

• Variable payments-by dividing the “investment in the contract” on the annuity commencement date by the total number of expected periodic payments. This is the amount of each annuity payment that is excludable.

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The remainder of each annuity payment is includable in gross income. Once the “investment in the contract” has been fully recovered, the full amount of any additional annuity payments is includable in gross income and taxed as ordinary income.

If you select more than one annuity payment option, special rules govern the allocation of the policy’s entire “investment in the contract” to each such option, for purposes of determining the excludable amount of each payment received under that option. We advise you to consult a competent tax adviser as to the potential tax effects of allocating amounts to any particular annuity payment option.

If, after the annuity commencement date, annuity payments stop because an annuitant died, the excess (if any) of the “investment in the contract” as of the annuity commencement date over the aggregate amount of annuity payments received that was excluded from gross income may possibly be allowable as a deduction in your tax return.

You should consult a tax advisor before electing the Initial Payment Guarantee or a feature with stabilized payments.

Partial Annuitization

Under a new tax provision enacted in 2010, if part of an annuity policy’s value is applied to an annuity option that provides payments for one or more lives and for a period of at least ten years, those payments may be taxed as annuity payments instead of withdrawals. None of the payment options under the policy is intended to qualify for this “partial annuitization” treatment and, if you apply only part of the value of the policy to a payment option, we will treat those payments as withdrawals for tax purposes.

Medicare Tax

Beginning in 2013, distributions from nonqualified annuity policies will be considered “investment income” for purposes of the newly enacted Medicare tax on investment income. Thus, in certain circumstances, a 3.8% tax may be applied to some or all of the taxable portion of distributions (e.g. earnings) to individuals whose income exceeds certain threshold amounts ($200,000 for filing single, $250,000 for married filing jointly and $125,000 for married filing separately). Please consult a tax advisor for more information.

Diversification and Distribution Requirements

The Internal Revenue Code provides that the underlying investments for a variable annuity must satisfy certain diversification requirements in order to be treated as an annuity. The policy must also meet certain distribution requirements at the death of an owner in order to be treated as an annuity. These diversification and distribution requirements are discussed in the SAI. We may modify the policy to attempt to maintain favorable tax treatment.

Federal Defense of Marriage Act

The Federal Defense of Marriage Act currently does not recognize same-sex marriages or civil unions, even those that are permitted under individual state laws. Therefore, exercise of the spousal continuation provisions of this policy by persons who do not meet the definition “spouse” under federal law—e.g., civil union partners or same-sex marriage spouses—may have adverse tax consequences. Consult a tax advisor for more information on this subject.

Federal Estate Taxes

While no attempt is being made to discuss the Federal estate tax implications of the Policy, a purchaser should keep in mind that the value of an annuity policy owned by a decedent and payable to a

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beneficiary by virtue of surviving the decedent is included in the decedent’s gross estate. Depending on the terms of the annuity policy, the value of the annuity included in the gross estate may be the value of the lump sum payment payable to the designated beneficiary or the actuarial value of the payments to be received by the beneficiary. Consult an estate planning advisor for more information.

Generation-Skipping Transfer Tax

Under certain circumstances, the Internal Revenue Code may impose a “generation skipping transfer tax” when all or part of an annuity policy is transferred to, or a death benefit is paid to, an individual two or more generations younger than the Owner. Regulations issued under the Internal Revenue Code may require us to deduct the tax from your policy, or from any applicable payment, and pay it directly to the IRS.

Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010

The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “2010 Act”) increases the federal estate tax exemption to $5,000,000 and reduces the federal estate tax rate to 35%; increases the Federal gift tax exemption to $5,000,000 and retains the federal gift tax rate at 35%; and increases the generation-skipping transfer tax exemption to $5,000,000 and reduces the generation-skipping transfer tax rate to 35%. Commencing in 2012, these exemption amounts will be indexed for inflation.

The estate, gift, and generation-skipping transfer provisions of the 2010 Act are only effective until December 31, 2012; thereafter, the provisions will sunset, and the federal estate, gift and generation-skipping transfer taxes will return to their pre-2001 levels, resulting in significantly lower exemptions and significantly higher tax rates. Between now and the end of 2012, Congress may make these provisions of the 2010 Act permanent, or they may do nothing and allow these 2010 Act provisions to sunset, or they may alter the exemptions and/or applicable tax rates.

The uncertainty as to how the current law might be modified in coming years underscores the importance of seeking guidance from a qualified adviser to help ensure that your estate plan adequately addresses your needs and that of your beneficiaries under all possible scenarios.

Annuity Purchases by Residents of Puerto Rico

The Internal Revenue Service recently announced that income received by residents of Puerto Rico under life insurance or annuity policies issued by a Puerto Rico branch of a United States life insurance company is U.S.-source income that is generally subject to United States federal income tax.

Annuity Policies Purchased by Nonresident Aliens and Foreign Corporations

The discussion above provided general information (but not tax advice) regarding U.S. federal income tax consequences to annuity owners that are U.S. persons. Taxable distributions made to owners who are not U.S. persons will generally be subject to U.S. federal income tax withholding at a 30% rate, unless a lower treaty rate applies. In addition, distributions may be subject to state and/or municipal taxes and taxes that may be imposed by the owner’s country of citizenship or residence. Prospective foreign owners are advised to consult with a qualified tax adviser regarding U.S., state, and foreign taxation for any annuity policy purchase.

Transfers, Assignments or Exchanges of Policies

A transfer of ownership or assignment of a policy, the designation of an annuitant or payee or other beneficiary who is not also the owner, the selection of certain annuity commencement dates, the exchange

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of a policy and certain other transactions, or a change of annuitant other than the owner, may result in certain income or gift tax consequences to the owner that are beyond the scope of this discussion. An owner contemplating any such transfer, assignment, selection, exchange or change should contact a competent tax adviser with respect to the potential tax effects of such a transaction.

Possible Tax Law Changes

Although the likelihood of legislative or regulatory changes is uncertain, there is always the possibility that the tax treatment of the policy could change by legislation, regulation, or otherwise. You should consult a tax adviser with respect to legal or regulatory developments and their effect on the policy.

We have the right to modify the policy to meet the requirements of any applicable laws or regulations, including legislative changes that could otherwise diminish the favorable tax treatment that annuity policy owners currently receive.

Separate Account Charges

It is possible that the Internal Revenue Service may take a position that fees for certain optional benefits (e.g., death benefits other than the Return of Premium death benefit) are deemed to be taxable distributions to you. In particular, the Internal Revenue Service may treat fees associated with certain optional benefits as a taxable surrender, which might also be subject to a tax penalty if the surrender occurs prior to age 59 ¹/2. Although we do not believe that the fees associated with any optional benefit provided under the policy should be treated as taxable surrenders, the tax rules associated with these benefits are unclear, and we advise that you consult your tax advisor prior to selecting any optional benefit under the policy.

Foreign Tax Credits

We may benefit from any foreign tax credits attributable to taxes paid by certain underlying funds to foreign jurisdictions to the extent permitted under federal tax law.

Guaranteed Lifetime Withdrawal Benefits

We may make available, as options under the policy, certain guaranteed lifetime withdrawal and other optional benefits. If your policy contains a guaranteed lifetime withdrawal benefit rider the application of certain tax rules, particularly those rules relating to distributions from your policy, are not entirely clear. The tax rules for qualified policies may limit the value of these optional benefits. In view of this uncertainty, you should consult a tax advisor before purchasing a guaranteed lifetime withdrawal benefit rider for a qualified policy.

10. ADDITIONAL FEATURES

Systematic Payout Option

You can select at any time (during the accumulation phase) to receive regular withdrawals (i.e., partial surrenders) from your policy by using the Systematic Payout Option. Under this option, you can receive the greater of (1) or (2), divided by the number of withdrawals made per year, where: (1) up to 10% of your premium payments (reduced by prior withdrawals in that policy year); and (2) is any gains in the policy. For amounts greater than 10% of your premium payments, you must receive prior Company approval.

This amount may be taken free of surrender charges. Any payment in excess of the cumulative interest credited at the time of the payment may be subject to an excess interest adjustment.

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Systematic withdrawals can be made monthly, quarterly, semi-annually, or annually. Each withdrawal must be at least $50. Monthly and quarterly withdrawals must generally be made by electronic funds transfer directly to your checking or savings account.

If you request an additional withdrawal while a Systematic Payout Option is in effect, then the Systematic Payout Option will terminate.

Keep in mind that partial withdrawals under the Systematic Payout Option may be taxable, and if made before age 59 ¹/2, may be subject to a 10% federal penalty tax.

Please note, if you elect certain features (e.g. living benefit riders) your Systematic Payout Option may be different for the first year.

There is no charge for this benefit.

Income Benefit Programs

The Family Income Protector and Managed Annuity Programs are no longer available for new sales, but if you have previously elected one of these benefits you can still upgrade. If you upgrade your minimum annuitization value or minimum income base, you will generally receive the Managed Annuity Program II.

Initial Payment Guarantee

You may only elect to purchase the Initial Payment Guarantee at the time you annuitize your policy. You cannot terminate this payment guarantee (or eliminate the charge for it) after you have elected it. The guarantee only applies to variable annuity payments. There is an additional charge for this guarantee.

The Initial Payment Guarantee does not establish or guarantee the performance of any subaccount.

Under the Initial Payment Guarantee, you receive annuity payments that are stabilized—that is, held level throughout each policy year—and are guaranteed to never be less than a percentage of the initial payment. The guaranteed percentage is subject to change from time to time; however once you annuitize, the guaranteed percentage will not change during the life of the Initial Payment Guarantee. Contact us for the current guaranteed percentage.

The payment amount is adjusted once each year (on the anniversary of your annuity commencement date) to reflect the investment performance of your selected investment choice(s) over the preceding year (but your payment will not be less than the guaranteed minimum).

Fee. There is a charge for the Initial Payment Guarantee, which is in addition to the base product mortality and expense risk fee and administrative charge. This fee is reflected in the amount of the annuity payments that you receive if you select the Initial Payment Guarantee. It is reflected in the calculation of the annuity unit values.

The Initial Payment Guarantee fee is currently equal to an annual rate of 1.25% of the daily net asset value in the subaccounts. We can change the fee, and you pay whatever the fee is when you annuitize.

Other Terms and Conditions. The Initial Payment Guarantee uses a 5% assumed investment return to calculate your annuity payments. This means that the dollar amount of the annuity payments will remain level if the investment return (net of fees and expenses) exactly equals 5%. The payments will increase if actual investment performance (net of fees and expenses) exceeds the assumed investment return, and decrease if actual performance is below the assumed investment return (but not below the guaranteed level).

Termination. The Initial Payment Guarantee is irrevocable.

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The Initial Payment Guarantee may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Initial Payment Guarantee. The application and operation of the Initial Payment Guarantee are governed by the terms and conditions of the policy itself.

Additional Death Distribution

The optional Additional Death Distribution rider pays an additional amount (based on earnings, if any, since the rider was issued) when a death benefit is payable during the accumulation phase under your policy, in certain circumstances. The Additional Death Distribution is only available for issue ages through age 80.

Additional Death Distribution Benefit Amount. The Additional Death Distribution is payable only if you elected the rider prior to the death triggering the payment of the policy death benefit and a death benefit is payable under the policy. The Additional Death Distribution is equal to:

• the Additional Death Distribution factor (see below); multiplied by

• the rider earnings, if any, on the date the death benefit is calculated.

Rider earnings equal:

• the policy value on the date the death benefit is determined; minus

• policy value on the rider date; minus

• premium payments after the rider date; plus

• surrenders after the rider date that exceed the rider earnings on the date of the surrender.

No benefit is payable under the Additional Death Distribution rider if there are no rider earnings on the date the death benefit is calculated.

If you purchase your policy as part of a 1035 exchange or add the Additional Death Distribution rider after you purchase the policy, rider earnings do not include any gains before the 1035 exchange or the date the Additional Death Distribution is added to your policy.

The Additional Death Distribution factor is currently 40% for issue ages under 71 and 25% for issue ages 71-80, based on the annuitant’s age.

No benefit is paid under the rider unless (a) the rider is in force, (b) a death benefit is payable on the policy, and (c) there are rider earnings when the death benefit is calculated.

For purposes of computing taxable gains, both the death benefit payable under the policy and the Additional Death Distribution will be considered.

Please see “Appendix – Additional Death Distribution—Additional Information” for an example which illustrates the Additional Death Distribution payable as well as the effect of a partial surrender on the Additional Death Distribution benefit amount.

Spousal Continuation. If a spouse, as the new owner of the policy, elects to continue the policy instead of receiving a death benefit and Additional Death Distribution, the spouse will receive a one-time policy value increase equal to the Additional Death Distribution. At this time the rider will terminate. The spouse will have the option of immediately re-electing the rider through age 80. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

Rider Fee. A rider fee, 0.25% of the policy value, is deducted annually on each rider anniversary prior to annuitization. We will also deduct this fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted pro rata from each

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investment choice. The fee is deducted even during periods when the Additional Death Distribution would not pay any benefit (because there are no rider earnings).

Termination. The rider will remain in effect until:

• you cancel it by notifying our Administrative and Service Office in writing,

• the policy is annuitized or surrendered, or

• the Additional Death Distribution is paid or added to the policy value under a spousal continuation.

Once terminated, the Additional Death Distribution may be re-elected; however, a new rider will be issued and the additional death benefit will be re-determined. Please note that if the rider is terminated and then re-elected, it will only cover gains, if any, since it was re-elected and the terms of the new rider may be different than the terminated rider.

The tax consequences associated with this rider are not clear. This rider may violate the requirements of certain qualified plans and IRAs. Consult a tax advisor before electing this rider for any qualified plan or IRA.

Please note: This feature terminates upon annuitization and there is a mandatory annuitization date.

The Additional Death Distribution may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Additional Death Distribution. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Additional Death Distribution+

The optional Additional Death Distribution+ rider pays an additional death benefit amount when a death benefit is payable during the accumultion phase under your policy, in certain circumstances. The Additional Death Distribution+ is only available for issue ages through age 75.

Additional Death Distribution+ Benefit Amount. An additional death benefit is only payable if a death benefit is paid on the base policy to which the rider is attached. The amount of the additional benefit is dependent on the amount of time that has passed since the rider date as follows:

• If a death benefit is payable within the first five years after the rider date, the additional benefit amount will be equal to the sum of all rider fees paid since the rider date.

• If a death benefit is payable after five years following the rider date, the additional benefit will be equal to the rider benefit base multiplied by the rider benefit percentage.

The rider benefit base at any time is equal to the policy value less any premiums added after the rider date.

The rider benefit percentage may vary but currently equals 30% for issue ages 0 - 70 and 20% for issue ages 71 - 75, based on the annuitant’s age.

No benefit is payable under the Additional Death Distribution+ if the policy value on the date the death benefit is paid is less than the premium payments after the rider date.

For purposes of computing taxable gains, both the death benefit payable under the policy and the additional benefit will be considered.

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Please see “Appendix – Additional Death Distribution+—Additional Information” for an example that illustrates the additional death benefit payable as well as the effect of a partial surrender on the Additional Death Distribution+ benefit amount.

Spousal Continuation. If a spouse, as the new owner of the policy, elects to continue the policy instead of receiving the death benefit and Additional Death Distribution+, then the spouse will receive a one-time policy value increase equal to the Additional Death Distribution+. At this time the rider will terminate. The spouse will have the option of immediately re-electing the rider through age 75. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

Rider Fee. A rider fee, currently 0.55% of the policy value, is deducted annually on each rider anniversary prior to annuitization. We will also deduct this fee upon full surrender of the policy or other termination of the rider.

Please note: the rider fee is deducted pro rata from each investment choice. The fee is deducted even during periods when the rider would not pay any benefits.

Termination. The rider will remain in effect until:

• you cancel it by notifying our Administrative and Service Office in writing in good order,

• the policy is annuitized or surrendered, or

• the additional death benefit is paid or added to the policy value under a spousal continuation.

Once terminated, the Additional Death Distribution+ may not be re-elected for one year.

The tax consequences associated with this rider are not clear. This rider may violate the requirements of certain qualified plans and IRAs. Consult a tax adviser before electing this rider for any qualified plan or IRA.

Please note: This feature terminates upon annuitization and there is a maximum annuiity commencement date.

The Additional Death Distribution+ may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Additional Death Distribution+. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Nursing Care and Terminal Condition Withdrawal Option

No surrender charges or excess interest adjustment will apply if you make a surrender ($1,000 minimum), under certain circumstances, because you or your spouse has been:

• confined in a hospital or nursing facility for 30 days in a row after the policy issue date; or

• diagnosed with a terminal condition after the policy issue date (usually a life expectancy of 12 months or less).

This benefit is also available to the annuitant or annuitant’s spouse if the owner is not a natural person.

You may exercise this benefit at any time (during the accumulation phase). There is no charge for this benefit.

There is no restriction on the maximum amount you may surrender under this benefit.

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This benefit may vary for certain policies, may not be available for all policies, and may not be available in all states.

Unemployment Waiver

No surrender charges or excess interest adjustment will apply to surrenders after you or your spouse become unemployed in certain circumstances, because you were terminated, laid off, or otherwise lost your job involuntarily. In order to qualify, you (or your spouse, whichever is applicable) must have been:

• employed full time for at least two years prior to becoming unemployed;

• employed full time on the policy date;

• unemployed for at least 60 days in a row at the time of surrender;

• must have a minimum cash value at the time of surrender of $5,000; and

• you (or your spouse) must be receiving unemployment benefits.

You must provide written proof from your State’s Department of Labor, which verifies that you qualify for and are receiving unemployment benefits at the time of surrender.

You may select this benefit at any time (during the accumulation phase) and there is no charge for this benefit.

This benefit is also available to the annuitant or annuitant’s spouse if the owner is not a natural person. There is no charge for this benefit.

There is no restricion on the maximum amount you may surrender under this benefit.

This benefit may vary for certain policies, may not be available for all policies, and may not be available in all states.

Telephone Transactions

You may generally make certain transactions by telephone upon our receipt of the appropriate authorization.

You will be required to provide certain information for identification purposes when requesting a transaction by telephone and we may record your telephone call. We may also require written confirmation of your request. We will not be liable for losses resulting from telephone requests that we believe are genuine. We reserve the right to revoke your telephone transaction privileges at any time without revoking all owners’ telephone transfer privileges.

Telephone requests must be received while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. We may discontinue this option at any time.

We may deny the telephone transaction privileges to market timers and frequent or disruptive traders.

We cannot guarantee that telephone transactions will always be available. For example, our offices may be closed during severe circumstances or other emergencies. There may be interruptions in service beyond our control, and if the volume of calls is unusually high, we might not have anyone available, or lines available, to take your call. Although we have taken precautions to help our systems handle heavy use, we cannot promise complete reliability in all circumstances.

Dollar Cost Averaging Program

During the accumulation phase, you may instruct us to automatically make transfers into one or more variable subaccounts in accordance with your allocation instructions. This is known as Dollar Cost Averaging. While Dollar Cost Averaging buys more accumulation units when prices are low and fewer

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accumulation units when prices are high, it does not guarantee profits or assure that you will not experience a loss.

There are two Dollar Cost Averaging programs available under your policy:

• Traditional—You may specify the dollar amount to be transferred or the number of transfers. Transfers will begin as soon as the program is started.

• Special—You may only elect either a six or twelve month program. Transfers will begin as soon as the program is started. You cannot transfer from another investment choice into a Special Dollar Cost Averaging program. This program is only available for new premium, requires transfers from a fixed source, and may credit a higher or lower interest rate than a traditional program.

A minimum of $500 per transfer is required. A minimum of $3,000 is required to start a 6-month program and $6,000 is required to start a 12-month program. The minimum number of transfers is 6 monthly or 4 quarterly, and the maximum is 24 monthly or 8 quarterly.

You can elect to transfer from one of the fixed or variable sources listed on the Dollar Cost Averaging election form (only fixed sources are available for special Dollar Cost Averaging programs).

A Dollar Cost Averaging program will begin once we have received in good order all necessary information and the minimum required amount. Please note: Dollar Cost Averaging programs will not begin on the 29th, 30th, or 31st. If a program would have started on one of those dates, it will start on the 1st business day of the following month. If we receive additional premium payments while a Dollar Cost Averaging program is running, absent new instructions to the contrary, the amount of the Dollar Cost Averaging transfers will increase, but the length of the Dollar Cost Averaging program will not.

NOTE CAREFULLY:

IF:

• we do not receive all necessary information to begin an initial Dollar Cost Averaging program within 30 days of allocating the minimum required amount to a Dollar Cost Averaging program; or

• we do not receive the minimum required amount to begin an initial Dollar Cost Averaging program within 30 days of allocating an insufficient amount;

THEN:

• any amount in a fixed source will be transferred to the money market investment choice; and

• any amount in a variable source will remain in that variable investment choice; and

• new instructions will be required to begin a Dollar Cost Averaging program.

IF:

• we receive additional premium payments after a Dollar Cost Averaging program is completed and the additional premium meets the minimum requirements to start a Dollar Cost Averaging program;

THEN:

• we will, absent new instructions to the contrary, start a new Dollar Cost Averaging program using the previous instructions.

IF:

• we receive additional premium payments after a Dollar Cost Averaging program is completed, and the additional premium does not meet the minimum requirements to start a Dollar Cost Averaging program;

THEN:

• we will, absent new instructions to the contrary, allocate the additional premium as identified in the previous Dollar Cost Averaging program.

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IF:

• you discontinue a Dollar Cost Averaging program before its completion;

THEN:

• we will, absent new instructions to the contrary, transfer any remaining balance directly into the subaccounts in the Dollar Cost Averaging instructions.

You should consider your ability to continue a Dollar Cost Averaging program during all economic conditions.

There is no charge for this benefit.

The Dollar Cost Averaging Program may vary for certain policies, may not be available for all policies, and may not be available in all states. See your policy for availability of the fixed account options.

Asset Rebalancing

During the accumulation phase you can instruct us to automatically rebalance the amounts in your subaccounts to maintain your desired asset allocation. This feature is called Asset Rebalancing and can be started and stopped at any time. However, we will not rebalance if you are in the Dollar Cost Averaging program or if any other transfer is requested. If a transfer is requested, we will honor the requested transfer and discontinue Asset Rebalancing. New instructions are required to start Asset Rebalancing. Asset Rebalancing ignores amounts in the fixed account. You can choose to rebalance monthly, quarterly, semi-annually, or annually.

There is no charge for this benefit.

Guaranteed Lifetime Withdrawal Benefits

You may elect one of the following optional riders under the policy that offers guaranteed lifetime withdrawal benefits - the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income MaxSM Rider. Important aspects of each of these riders are summarized in the “Appendix - Guaranteed Lifetime Withdrawal benefit Comparison Table” and are described in more detail below. You should consult with tax and financial professionals to determine which of these riders is appropriate for you.

The following benefits are no longer available for new sales, but if you have previously elected one of these riders you can still upgrade:

• 5 for Life Rider

• 5 for Life with Growth Rider

• Income Select for Life Rider

• Retirement Income Choice^® Rider

• Retirement Income Choice^® with Double Withdrawal Base Benefit Rider

• Retirement Income Choice^® 1.4 Rider

Living Benefits Rider

You may elect to purchase the optional Living Benefits Rider which provides you with a guaranteed minimum accumulation benefit and a guaranteed minimum withdrawal benefit. The Living Benefits Rider is only available during the accumulation phase. The Living Benefits Rider is only available for annuitant issue ages through age 80. The maximum issue age may be lower if required by state law.

You should view the Living Benefits Rider as a way to permit you to invest in variable investment choices while still having your policy value and liquidity protected to the extent provided by the Living Benefits Rider.

Please note:

• Certain protections under the rider are available only if you hold the rider for ten years.

• If you elect the rider, we will monitor your policy value and we may transfer amounts back and forth between specified investment choices under the policy (including guaranteed period options in the fixed account) and the variable

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investment choices you choose, according to a mathematical model that we will use to assist us in managing portfolio risk and supporting the guarantees under the rider. See “Portfolio Allocation Method” below.

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider for you to take withdrawals each rider year that are less than or equal to the maximum annual withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the maximum annual withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• Because the guaranteed minimum withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the maximum annual withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take the maximum advantage of the tax deferral aspect of the policy.

• The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Living Benefits Rider for a qualified policy.

• Any such transfers out of a guaranteed period option may be subject to an excess interest adjustment. We intend to include among the specified investment choices fixed account options to which excess interest adjustments do not apply. (See “Portfolio Allocation Method,” below.)

Guaranteed Minimum Accumulation Benefit

If you elect the Living Benefits Rider, we will provide a guaranteed future value. This benefit is intended to provide a level of protection regardless of the performance of the variable investment choices you select.

Guaranteed Future Value. We guarantee that, on the guaranteed future value date (ten years after you elect the rider), your policy value will at least equal your guaranteed future value. The guaranteed future value on the rider date (i.e., the date the rider is added to the policy) is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date and before the guaranteed future value date, the guaranteed future value is equal to:

• the guaranteed future value on the rider date; plus

• a percentage of subsequent premium payments (as described below); less

• subsequent adjusted partial withdrawals (as described below).

After the guaranteed future value date, the guaranteed future value equals zero.

Subsequent Premium Payments. The percentage of subsequent premium payments that will be added to the guaranteed future value is as follows:

Rider Year	Percent of subsequent premium payments added to guaranteed future value
1	100%
2	90%
3	80%
4	70%
5	60%
6	50%
7	50%
8	50%
9	50%
10	0%

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Guaranteed Future Value Adjusted Partial Withdrawals. If you take a partial withdrawal, it will reduce your guaranteed future value. The amount of the reduction is referred to as the adjusted partial withdrawal amount, which will be equal to the greater of:

• the guaranteed future value immediately prior to the withdrawal multiplied by the percentage reduction in the policy value resulting from the gross partial withdrawal; or

• the gross partial withdrawal amount.

(The gross partial withdrawal amount is the amount you request, plus any surrender charges or excess interest adjustment that may be applicable.)

In other words, if your policy value is greater than the guaranteed future value at the time you make a partial withdrawal, then your guaranteed future value is reduced by the same amount we reduce your policy value. However, if your policy value is less than the guaranteed future value at the time you make a partial withdrawal, then your guaranteed future value will be reduced by more than the amount we reduce your policy value.

See the “Appendix - Living Benefits Rider Adjusted Partial Withdrawals” to this prospectus for examples showing the effect of hypothetical withdrawals in more detail, including withdrawals that reduce the guaranteed future value by more than the amount of the gross partial withdrawal.

Guaranteed Minimum Accumulation Benefit. On the guaranteed future value date (ten years after you elect the rider), if the policy value is less than the guaranteed future value, we will add an amount equal to the difference to your policy value. After the guaranteed future value date, the guaranteed minimum accumulation benefit will terminate.

Example. Assume you make a single premium payment of $100,000 and you do not make any withdrawals or additional premium payments. If, on the guaranteed future value date, your policy value has declined to $90,000 because of negative investment performance, then we will add $10,000 ($100,000 – $90,000) to your policy value.

Please note: You do not have any protection under the guaranteed minimum accumulation benefit unless you hold the policy with the rider for ten years. If you think that you may terminate the policy or elect to start receiving annuity payments (or if you must begin taking required minimum distributions) before the guaranteed future value date, electing the rider may not be in your best interests.

Guaranteed Minimum Withdrawal Benefit

If you elect the Living Benefits Rider, (first as withdrawals from your policy value or, if necessary, as payments from us) we will provide a maximum annual withdrawal amount regardless of your policy value. This benefit is intended to provide a level of benefits regardless of the performance of the variable investment choices you select.

Withdrawal Guarantees. We account for the withdrawals you take under the rider by applying two different withdrawal guarantees:

• “principal back,” for withdrawals of up to 7% of your total withdrawal base.

• “for life,” for withdrawals of up to 5% of your total withdrawal base.

When you make a withdrawal, you do not need to specify it as being under either withdrawal guarantee. Any withdrawals that you take while the rider is in effect could have different impacts under each of the withdrawal guarantees—on your maximum annual withdrawal amount, on your total withdrawal base, and on your minimum remaining withdrawal amount. For example, withdrawals that are compliant with the “principal back” maximum withdrawal amount could result in excess withdrawals under the “for life” withdrawal guarantee and, consequently, would reduce the maximum annual withdrawal

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amount, the total withdrawal base, and the minimum remaining withdrawal amount under the “for life” withdrawal guarantee. (See “Adjusted Partial Withdrawals” below.)

Your ability to change the frequency or amount of your withdrawals ceases if your policy value reaches zero.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion. See “Appendix - Living Benefits Rider Adjusted Partial Withdrawals,” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the total withdrawal base by a pro rata amount.

Please note:

• Any amount withdrawn in a rider year (including any surrender charge or excess interest adjustment) in excess of the maximum withdrawal amount is an excess withdrawal.

• The amount of your excess withdrawal will impact the maximum annual withdrawal amount, total withdrawal base, and minimum remaining withdrawal amount under each guarantee on a greater than dollar-for-dollar basis. (See “Maximum Annual Withdrawal Benefit,” “Total Withdrawal Base,” and “Minimum Remaining Withdrawal Amount,” below.)

Withdrawals under the guaranteed minimum withdrawal benefit also:

• reduce your policy value;

• reduce your death benefit and other benefits;

• may be subject to any surrender charge or excess interest adjustment; and

• may be subject to income taxes and federal tax penalties (See “Section 9. Taxes”).

Maximum Annual Withdrawal Amount. Under this benefit:

• you can withdraw up to 7% of your “principal back” total withdrawal base each rider year until your “principal back” minimum remaining withdrawal amount reaches zero;

Example. Assume you make a single premium payment of $100,000 and that you do not make any withdrawals or additional premium payments. Assume that after five years, your policy value has declined to $70,000 solely because of negative investment performance. You could still receive up to $7,000 (7% of $100,000) each rider year for the next fourteen years and $2,000 in the year immediately thereafter so you would get back your full $100,000 (assuming that you do not withdraw more than $7,000 in any one rider year).

• or, you can withdraw up to 5% of your “for life” total withdrawal base each rider year starting with the rider anniversary immediately following the annuitant’s 59th birthday and lasting until the annuitant’s death, unless your “for life” minimum remaining withdrawal amount reaches zero because of “excess withdrawals” (see “Adjusted Partial Withdrawals,” below). A penalty tax may be assessed on amounts surrendered from the policy before the annuitant reaches age 59 ¹/2.

Example. Assume you are the owner and annuitant and you make a single premium payment of $100,000 when you are 55 years old. Assume you do not make any withdrawals or additional premium payments. Assume that after five years, your policy value has declined to $70,000 solely because of negative investment performance. You could still receive up to $5,000 (5% of $100,000) each rider year for the rest of your life (assuming that you do not withdraw more than $5,000 in any one rider year).

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You can receive up to the maximum annual withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us) under this rider regardless of your policy value; however, once your policy value reaches zero you cannot make premium payments, and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to continue withdrawals under this rider after your policy value reaches zero, you must select an amount and frequency of future withdrawals. Once selected, the amount and frequency of future withdrawals after your policy value reaches zero cannot be changed.

Please note:

• Withdrawals under the 5% “for life” guarantee cannot begin until after the rider anniversary following the annuitant’s 59th birthday.

• Any withdrawal before the rider anniversary following the annuitant’s 59th birthday will reduce the benefits under the 5% “for life” guarantee.

• The maximum annual withdrawal amounts described above (the 7% “principal back” and 5% “for life”) are based on rider years, not calendar or policy years (if different from rider years).

• You cannot carry over any portion of your maximum annual withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the maximum annual withdrawal amount during a rider year, you cannot take more than the maximum annual withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• If you have a qualified policy, minimum required distribution rules may force you to take excess withdrawals to avoid the imposition of a 50% excise tax. Further, some qualified policies have withdrawal restrictions that may (with limited exceptions) prevent you from taking withdrawals before age 59 ¹/2. You should consult a tax advisor before purchasing this rider with a qualified policy.

Total Withdrawal Base. We use the total withdrawal base to calculate the maximum annual withdrawal amount. The total withdrawal base on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the total withdrawal base is equal to:

• the total withdrawal base on the rider date; plus

• subsequent premium payments; less

• subsequent adjusted partial withdrawals (as described below).

We will calculate separate total withdrawal bases for the “principal back” and “for life” guarantees.

Please note: We determine the total withdrawal base solely to calculate the maximum annual withdrawal amount. Your total withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

Minimum Remaining Withdrawal Amount. The minimum remaining withdrawal amount represents the total amount of guaranteed withdrawals still available under the rider. The minimum remaining withdrawal amount on the rider date is the policy value (less any premium enhancements if the rider is added in the first policy year). After the rider date, the minimum remaining withdrawal amount is equal to:

• the minimum remaining withdrawal amount on the rider date; plus

• subsequent premium payments; less

• subsequent adjusted partial withdrawals (as described below).

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We will calculate separate minimum remaining withdrawal amounts for the “principal back” and “for life” guarantees.

Adjusted Partial Withdrawals. Each rider year, for each withdrawal guarantee (i.e., “principal back” and “for life”), gross partial withdrawals (the amount that you request be withdrawn, plus any surrender charge or excess interest adjustment that may be applicable) up to the maximum annual withdrawal amount for that withdrawal guarantee, will reduce the minimum remaining withdrawal amount for that withdrawal guarantee on a dollar-for-dollar basis, but will not reduce the total withdrawal base for that withdrawal guarantee. For each withdrawal guarantee, gross partial withdrawals in excess of the maximum annual withdrawal amount for that withdrawal guarantee will reduce the total withdrawal base and minimum remaining withdrawal amount for that withdrawal guarantee by a pro rata amount (possibly to zero). See “Appendix - Living Benefits Rider Adjusted Partial Withdrawals,” which provides examples showing the effect of a withdrawal. Excess withdrawals may cause you to lose the withdrawal guarantees under this rider.

Please note: Gross partial withdrawals that are compliant with the “principal back” withdrawal guarantee (i.e., withdrawals of the “principal back” maximum annual withdrawal amount) and any partial withdrawal before the rider anniversary following the annuitant’s 59th birthday, will result in an excess partial withdrawal under the “for life” guarantee, and will reduce the “for life” maximum annual withdrawal amount, the “for life” total withdrawal base, and the “for life” minimum remaining withdrawal amount. Such reduction may be on a greater than dollar-for-dollar basis.

Rider Fee. A rider fee, 0.90% of the “principal back” total withdrawal base on each rider anniversary, is charged annually before annuitization. We will also deduct the rider fee upon full surrender of the policy or other termination of the rider. The rider fee is deducted from each investment choice in proportion to the amount of policy value in each investment choice. Generally, the rider fee is deducted regardless of your values (i.e., even if your policy value exceeds your total withdrawal base).

We will continue to calculate the rider fee using the “principal back” total withdrawal base even after the “principal back” minimum remaining withdrawal amount reaches zero. The “principal back” total withdrawal base is always greater than or equal to the “for life” total withdrawal base.

Please note: Because the rider fee is a percentage of your “principal back” total withdrawal base on each rider anniversary, the fee can be substantially more than 0.90% of your policy value if that total withdrawal base is higher than your policy value.

Portfolio Allocation Method

If you elect the Living Benefits Rider, the Portfolio Allocation Method (“PAM”) will automatically be in effect. PAM is designed to help manage portfolio risk and support the guarantees under the Living Benefits Rider. Using PAM, we will monitor your policy value and may transfer amounts back and forth between the PAM Transamerica AEGON U.S. Government Securities VP—Service Class subaccount (which invests in the Transamerica AEGON U.S. Government Securities VP—Service Class portfolio of the Transamerica Series Trust) or certain guaranteed period options of the fixed account (each a “PAM investment choice” and collectively, the “PAM investment choices”) and the variable investment choices you choose. You should read the underlying fund prospectus for the variable PAM investment choice(s) carefully before you elect the Living Benefits Rider. We will transfer amounts from your variable investment choices to the PAM investment choices to the extent we deem, at our sole discretion, necessary to support the guarantees under the rider. We will transfer amounts to the PAM investment choices proportionally from all your

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variable investment choices. Currently, PAM transfers are being made to the PAM Transamerica AEGON U.S. Government Securities VP—Service Class subaccount.

PAM is designed to help reduce portfolio risk associated with negative performance. Using PAM, we will transfer amounts from your variable investment choices to the PAM investment choices to the extent we deem, in our sole discretion, necessary to help manage portfolio risk and support the guarantees under the Living Benefits Rider. You should not view the Living Benefits Rider nor PAM as a “market timing” or other type of investment program designed to enhance your policy value. If you choose this rider, it may result in a lower policy value in certain situations. If policy value is transferred from your chosen variable investment choices to the PAM investment choices, less of your policy value may be available to participate in any future positive investment performance of your variable investment choices. This may potentially provide a lower policy value than if you did not select the Living Benefits Rider.

Under PAM, the mathematical model compares a number of interrelated factors including your policy value and the guarantees under the rider to be provided in the future. The mathematical model also uses assumptions for interest rates, the duration of the policy and stock market volatility. The following table sets forth the most influential of these factors and indicates how each one (assuming all other factors remain constant) could trigger a transfer into or out of the PAM subaccounts.

Factor	Direction of Transfer
Policy Value Increases	Transfer to the investment options
Policy Value Decreases	Transfer to the PAM subaccounts
Interest Rates Increase	Transfer to the investment options
Volatility Increases	Transfer to the PAM subaccounts

The amount of the transfer will vary depending on the magnitude and direction of the change in these factors. We may transfer some or all of your policy value to or from the PAM investment choices.

Transactions you make also affect the number of PAM transfers including:

• additional premium payments; and

• excess withdrawals.

These transactions will change the policy value relative to the guarantees under the rider and may result in additional PAM transfers.

You may not allocate premium payments to, nor transfer policy value into or out of, the PAM investment choices. PAM transfers are not subject to any transfer fee and do not count against the number of any free transfers we allow. Transfers out of a fixed account PAM investment choice are at our discretion and may be subject to an excess interest adjustment if the transfer occurs before the end of a guarantee period. Any transfer to your variable investment choices will be allocated into your variable investment choices in proportion to the amount of policy value in each variable investment choice.

Generally, transfers to the PAM investment choices first occur when the policy value drops by a cumulative amount of 3% to 5% over any period of time, although we may make transfers to the PAM investment choices when the policy value drops by a cumulative amount of less than 3% in relation to the guarantees. If the policy value continues to fall, more transfers to the PAM investment choices will occur. When a transfer occurs, the transferred policy value is allocated to the PAM investment choice(s) we deem appropriate. The policy value allocated to the PAM investment choices will remain there unless the performance of your chosen investment choices recovers sufficiently to enable us to transfer amounts back to your investment choices while maintaining the guarantees under the Living Benefits Rider. This

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generally occurs when the policy value increases by 5% to 10% in relation to the guarantees, although we may require a larger increase before transferring amounts back to your investment options.

The Daily Rebalancing Formula Under the Mathematical Model: As noted above, to limit our exposure under the rider, we transfer policy value from your investment options to the PAM subaccounts, to the extent called for by a mathematical model that will not change once you purchase the policy. We do this in order to minimize the need to provide payments (for example, when your policy value goes to zero by other than an excess withdrawal), or to extend the time before any payment is required. When payments become more likely (because your policy value is approaching zero), the mathematical model will tend to allocate more policy value to the PAM subaccounts. If, on the other hand, the policy value is much higher than the guarantees under the rider, then payments may not be necessary, and therefore, the mathematical model will tend to allocate more policy value to the investment options.

Each business day the mathematical model computes a “target allocation,” which is the portion of the policy value that is to be allocated to the investment options.

The target allocation depends on several factors, including the policy value as compared to the guarantees under the rider, the time until payments are likely required, and interest rates. However, as time passes, these factors change. Therefore, the target allocation changes from one business day to the next.

See “Appendix – PAM Method Transfers” in the SAI for more detail regarding the workings of the mathematical model, including the formula used to compute the allocation on a daily basis.

Upgrades

Prior to the annuitant’s 86th birthday and after the third rider anniversary, you can upgrade the total withdrawal base and guaranteed future value to the policy value by sending us written notice. The minimum remaining withdrawal amounts will also be upgraded to the policy value and the maximum annual withdrawal amounts will be recalculated.

If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, guaranteed future value date, and its own rider fee percentage (which may be higher than your current rider fee percentage). The “principal back” and “for life” withdrawal percentages will not change. The new rider date will be the date the Company receives all necessary information.

Annuitization

If you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments equal to your 5% “for life” maximum annual withdrawal amount.

Termination

The Living Benefits Rider will terminate upon the earliest of the following:

• the date we receive written notice from you in good order requesting termination of the Living Benefits Rider (you may not terminate the rider before the third rider anniversary);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your 5% “for life” maximum annual withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

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• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This feature terminates upon annuitization and there is a maximum annuity commencement date.

The Living Benefits Rider may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Living Benefits Rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Retirement Income Choice^® 1.2 Rider

You may elect to purchase the optional Retirement Income Choice^® 1.2 Rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value according to either the designated allocation option or open allocation option both of which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Choice^® 1.2 rider for a qualified policy.

Retirement Income Choice^® 1.2 – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments and Rider Death Benefit Adjustments, below). A rider year begins on the rider date (the date the rider becomes effective) and thereafter on each anniversary of that date.

Example. Assume you are the owner and annuitant and you make a single premium payment of $100,000 when you are 66 years old. Further assume that you do not make any withdrawals or additional premium payments, no automatic step-ups occurred, but that after five years your policy value has declined to $90,000 solely because of negative investment performance. With an annual growth rate percentage of 5.0%, after 5 years the withdrawal base is equal to $127,628 ($100,000 x 1.05⁵). You could receive up to $6,381 which is the applicable withdrawal percentage of 5.0% for the single life option multiplied by the withdrawal base of $127,628, each rider year for the rest of your life (assuming that you take your first withdrawal when you are age 71, that you do not withdraw more than the rider withdrawal amount in any one year and there are no future automatic step-ups.)

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

Example continued. Assume the same facts as above, but you withdraw $10,000 when you are 71 years old. That excess withdrawal decreases your future rider withdrawal amount to $6,105.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Choice^® 1.2 Rider” for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid

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under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated according to the Designated Allocation option or the Open Allocation option. You should consult with your registered representative to assist you in determining whether the investment restrictions attributable to each option are suited for your financial needs and risk tolerance.

• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base, and rider death benefit (if applicable) on a greater than dollar-for-dollar basis.

• Any withdrawal will reduce your rider death benefit (if applicable).

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Choice^® 1.2 rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” and “Rider Death Benefit Adjustments” below.

The rider withdrawal amount is zero if the annuitant is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

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For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider.

If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated according to either the Designated Allocation option or the Open Allocation option. (See “Allocation Options and Restrictions.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage— Single Life Option			Withdrawal Percentage— Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.0	%		3.5	%
65-74		5.0	%		4.5	%
³ 75		6.0	%		5.5	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus

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subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• Current withdrawal base;

• The withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

• The policy value on any monthiversary, including the current rider anniversary (see “Automatic Step-Up” below).

Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the

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policy value when the policy value is less than the withdrawal base), possibly to zero. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders -Retirement Income Choice^® 1.2 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

Allocation Options and Restrictions. If you elect this rider, you must allocate 100% of your policy value according to either the Designated Allocation option or the Open Allocation option. Transfers will be permitted between the Designated Allocation option and the Open Allocation option at any time.

Designated Allocation Option. Under the Designated Allocation option, you must designate 100% of your policy value into one or more of the designated investment options in the following designated allocation groups:

Designated Allocation Group A

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

American Funds – Asset Allocation Fund – Class 2

Fidelity VIP Balanced Portfolio – Service Class 2

GE Investments Total Return Fund – Class 3

Transamerica Index 75 VP – Service Class

Transamerica Madison Moderate Growth Allocation VP – Service Class

Designated Allocation Group B

Transamerica BlackRock Global Allocation VP – Service Class

Transamerica BlackRock Tactical Allocation VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Madison Balanced Allocation VP – Service Class

Transamerica Madison Diversified Income VP – Service Class

Designated Allocation Group C

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

American Funds – Bond Fund – Class 2

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Madison Conservative Allocation VP -Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Fixed Account

Transfers between the designated investment options in the Designated Allocation option are allowed as permitted under the policy; however, transfers as provided for in the policy from a designated investment option to a non-designated investment option are not permitted unless you change your allocation option to the Open Allocation option.

Open Allocation Option. Under the Open Allocation option, you may allocate to any investment options available under the policy.

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If you elect the Open Allocation option, the OA Method will automatically be in effect. The OA Method uses a mathematical model which is designed to help the Company manage portfolio risk and support the guarantees under the rider. Under the OA Method, the mathematical model monitors your policy value and guarantees under the rider and transfers amounts back and forth between the OA Transamerica ProFund UltraBear VP subaccount or certain other subaccounts we choose (each an “OA subaccount” and collectively, the “OA subaccounts”) and the variable investment options you choose to the extent necessary to support the benefit guarantees. You will still have complete discretion over the selection of, and allocation to, the variable investment options for any portion of your policy value that the OA Method does not allocate to the OA subaccounts. You should read the underlying fund prospectus for the variable OA subaccounts carefully before you elect the Open Allocation option.

Transfers to the OA subaccounts according to the mathematical model will be proportionally from all your variable investment options. This mathematical model will not change once you purchase the rider, but we may use a different model for riders issued in the future.

The OA Method is designed to help manage the Company’s portfolio risk associated with negative performance and support the guarantees under the rider. You should not view the rider nor the OA Method as a “market timing” or other type of investment program designed to enhance your policy value. If you choose the Open Allocation option, it may result in a lower policy value in certain situations. If policy value is transferred from your chosen variable investment options to the OA subaccounts, less of your policy value may be available to participate in any future positive investment performance of your variable investment options. This may potentially provide a lower policy value than if you did not select the Open Allocation option.

Under the OA Method, the mathematical model compares a number of interrelated factors including your policy value and the guarantees under the rider to be provided in the future. The mathematical model also uses assumptions for interest rates, the duration of the policy and stock market volatility. The following table sets forth the most influential of these factors and indicates how each one (assuming all other factors remain constant) could trigger a transfer into or out of the OA subaccounts.

Factor	Direction of Transfer
Policy Value Increases	Transfer to the investment options
Policy Value Decreases	Transfer to the OA subaccounts
Interest Rates Increase	Transfer to the investment options
Volatility Increases	Transfer to the OA subaccounts

The amount of the transfer will vary depending on the magnitude and direction of the change in these factors.

Transactions you make also affect the number of OA transfers including:

• additional premium payments; and

• excess withdrawals.

These transactions will change the policy value relative to the guarantees under the rider and may result in additional OA transfers.

You may not allocate premium payments to, nor transfer policy value into or out of, the OA subaccounts. OA Method transfers are not subject to any transfer fee and do not count against the number of any free transfers we allow. Any transfer to your

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variable investment options will be allocated into your variable investment options in proportion to the amount of policy value in each variable investment option.

Generally, transfers to the OA subaccounts first occur when the policy value drops by a cumulative amount of 2% to 5% over any period of time in relation to the guarantees, although the mathematical model may make transfers to the OA subaccounts when the policy value drops by a cumulative amount of less than 3%. The mathematical model will not transfer more than 20% of the policy value to the OA subaccounts. If the policy value continues to fall, no more transfers to the OA subaccounts will occur. However, up to 30% of the policy value could be in the OA subaccounts due to negative performance of the investment options. If negative investment performance causes the percentage of the policy value in the OA subaccounts to exceed 30% then the mathematical model will transfer the excess policy value back into your investment options. The policy value allocated to the OA subaccounts will remain there unless your policy value recovers sufficiently to enable us to transfer amounts back to your investment options while maintaining the guarantees under the rider. This generally occurs when the policy value increases by 2.5% to 10% in relation to the guarantees under the rider, although the mathematical model may require a larger increase before transferring amounts back to your investment options.

The Daily Rebalancing Formula Under the Mathematical Model: As noted above, to limit our exposure under the rider, we transfer policy value from your investment options to the OA subaccounts, to the extent called for by a mathematical model that will not change once you purchase the policy. We do this in order to minimize the need to provide payments (for example, when your policy value goes to zero by other than an excess withdrawal), or to extend the time before any payment is required. When payments become more likely (because your policy value is approaching zero), the mathematical model will tend to allocate more policy value to the OA subaccounts. If, on the other hand, the policy value is much higher than the guarantees under the rider, then payments may not be necessary, and therefore, the mathematical model will tend to allocate more policy value to the investment options.

Each business day the mathematical model computes a “target allocation,” which is the portion of the policy value that is to be allocated to the investment options.

The target allocation depends on several factors, including the policy value as compared to the guarantees under the rider, the time until payments are likely required, and interest rates. However, as time passes, these factors change. Therefore, the target allocation changes from one business day to the next.

See “Appendix—OA Method Transfers” in the SAI for more detail regarding the workings of the mathematical model, including the formula used to compute the allocation on a daily basis.

Please Note: The OA Transamerica ProFunds UltraBear VP subaccount invests in the Transamerica ProFunds UltraBear VP portfolio which is designed to seek daily investment results, before fees and expenses that correspond to twice (200%) the inverse (opposite) of the daily performance of the S&P 500 Index. Please read the prospectus for the Transamerica ProFunds UltraBear VP portfolio to understand how its investment objective may affect your policy value if OA Method transfers occur to the OA Transamerica ProFunds UltraBear VP subaccount.

You cannot allocate premium payments or transfers to the OA subaccounts.

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Please note:

• If you no longer want to be subject to an allocation option, you will be required to terminate the rider. If you terminate the rider you will lose all of its benefits.

• We can change a designated allocation group or eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Manual Upgrades. You can upgrade the withdrawal base to the policy value during the 30-day period following each successive fifth rider anniversary by sending us written notice in a form acceptable to us, as long as the rider issue requirements for a new rider are met. At this time the rider withdrawal amount and, if applicable, the rider death benefit will be recalculated. If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, its own rider fee percentage (which may be higher or lower than your current rider fee percentage) and its own terms and benefits (which may not be as advantageous as the current rider); and any options you elect to change or add. The new rider date will be the date the Company receives all necessary information in good order. You cannot elect a manual upgrade if the annuitant (or the annuitant’s spouse if younger and the joint option is elected) is 86 or older.

Retirement Income Choice^® 1.2 – Additional Options

You may elect the following options with this rider (the options are not mutually exclusive):

• Death Benefit;

• Joint Life; and

• Income Enhancement.

There is an additional fee if you elect the Death Benefit and/or the Income Enhancement Benefit option(s) under the rider. If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower. Furthermore, if you elect the Joint Life option in combination with the Death Benefit and/or the Income Enhancement Benefit option(s), then the fee for each of those additional options will be different than under the Single Life option. See “Retirement Income Choice^® 1.2 Rider and Additional Option Fees”.

1. Death Benefit. If you elect this rider, you can also elect to add an additional amount to the death benefit payable under the base policy, upon the death of the annuitant (or if the joint life option is selected, the annuitant’s spouse). The additional amount will be equal to the excess, if any, of the rider death benefit over the greater of any optional guaranteed minimum death benefit or the base policy death benefit. The additional amount can be zero. See “Section 8. Death Benefit.”

Rider Death Benefit. The rider death benefit on the rider date is the policy value (less any premium enhancement if the rider is added in the first policy year). After the rider date, the rider death benefit is equal to:

• the rider death benefit on the rider date; plus

• subsequent premium payments; less

• adjustments for withdrawals (as described under “Rider Death Benefit Adjustments,” below).

Rider Death Benefit Adjustments. Gross partial withdrawals up to the rider withdrawal amount in a rider year will reduce the rider death benefit on a dollar-for-dollar basis. Gross partial withdrawals in excess of the rider withdrawal amount in a rider year will reduce the rider death benefit by the greater of the dollar amount of the excess withdrawal or a pro rata amount (in proportion to the reduction in policy value), and possibly to zero. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted

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Partial Surrenders – Retirement Income Choice^® 1.2 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that results in pro rata adjustments. Rider death benefit adjustments occur immediately following all withdrawals.

Please note:

• No additional death benefit is payable if the base policy death benefit (including the guaranteed minimum death benefit) exceeds the rider death benefit. The greater the death benefit payable under the guaranteed minimum death benefit selected, the more likely it is that an additional amount will not be payable under the rider death benefit option.

• Excess withdrawals may eliminate the additional death benefit available with this rider. You will continue to pay the fee for this option, even if the additional death benefit available under the rider is $0.

• Manual upgrades to the withdrawal base will result in a recalculation of the rider death benefit. However, automatic step-ups will not reset the rider death benefit.

• If an owner who is not the annuitant dies and the surviving spouse continues the policy, then no additional amount is payable. If the policy is not continued, then the surviving owner (who is also the sole beneficiary) may elect to receive lifetime annuity payments equal to the rider withdrawal amount divided by the number of payments each year instead of receiving the policy’s cash value. Please note that under federal tax law, upon the death of an owner, only a “spouse,” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

The additional death benefit payment option may be referred to as “minimum remaining withdrawal amount” on your policy statement and other documents.

2. Joint Life Benefit. If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

Please note:

• The withdrawal percentage for each “age at the time of first withdrawal” is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The rider death benefit is not payable until the death of the surviving spouse, if you elect this option.

• You cannot elect a manual upgrade if the annuitant or annuitant’s spouse is 86 or older (lower if required by state law).

3. Income Enhancement Option. If you elect this rider, you can also elect to have your withdrawal percentage double if either the annuitant (or the annuitant’s spouse if the joint life option is elected) is confined, due to a medical necessity in a hospital or nursing facility due to physical or cognitive ailments. Benefits from this option are not available unless the

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rider has been in effect for 12 months (the “waiting period”) and confinement must meet the elimination period of 180 days within the last 365 days. The elimination period and waiting period can, but do not need to, run concurrently.

Please note:

• You cannot elect the Income Enhancement Option if the qualifying person or persons is/are already admitted to a hospital or already reside in a nursing facility.

• Confinement must be prescribed by a physician based on the individual’s inability to sustain themselves outside of a hospital or nursing facility due to physical or cognitive ailments.

• The increase to the withdrawal percentage stops when the qualifying person or persons is/are no longer confined as described above.

• The hospital and/or nursing facility must meet the criteria listed below to qualify for the benefit.

• You cannot elect the Income Enhancement Option if you are confined in an assisted living facility or a residential care facility.

A Qualifying Hospital must meet the following criteria:

• It is operated pursuant to the laws of the jurisdiction in which it is located;

• It is operated primarily for the care and treatment of sick and injured persons on an inpatient basis;

• It provides 24-hour nursing service by or under the supervision of registered graduate professional nurses;

• It is supervised by a staff of one or more licensed physicians; and

• It has medical, surgical and diagnostic facilities or access to such facilities.

A Qualifying Nursing Facility must meet the following criteria:

• It is operated pursuant to the laws and regulations of the state in which it is located as a nursing facility or Alzheimer’s disease facility;

• It provides care performed or supervised by a registered graduate nurse;

• It provides room and board accommodations; and

• Will provide 24-hour nursing services, 7 days a week by an on-site Registered Nurse and related services on a continuing inpatient basis.

• It has a planned program of policies and procedures developed with the advice of, and periodically reviewed by, at least one physician; and

• It maintains a clinical record of each patient.

A Qualifying Nursing Facility does not include:

• Assisted living facilities or residential care facilities;

• A place primarily for treatment of mental or nervous disorders, drug addiction or alcoholism;

• A home for the aged, a rest home, community living center or a place that provides domestic, resident, retirement or educational care;

• Personal care homes, personal care boarding homes, residential or domiciliary care homes;

• A rehabilitation hospital or basic care facilities;

• Adult foster care facilities, congregate care facilities, family and group living assisted living facilities; or

• Other facilities similar to those described above.

We will require confirmation of confinement in a qualifying hospital or a qualifying nursing facility while benefit payouts are being received. Confirmation of that confinement will be attained and approved by completing our “Income Enhancement Election and Proof of Confinement Questionnaire” form. This form requires additional proof of confinement which may be a physician’s statement, a statement from a hospital or nursing facility administrator, or any other information satisfactory to us which may include information from third party or company interviews and/or visits of the facility. If it is determined that the qualifying individual was not confined in an eligible facility as defined above and has received payments under the

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Income Enhancement Option, those payments could be considered an excess withdrawal and have a negative effect on the rider values. If confinement ceases, you may re-qualify by satisfying another 180-day elimination period requirement.

Retirement Income Choice^® 1.2 Fees

Retirement Income Choice^® 1.2 Base Rider Fee. The base rider fee is calculated on the rider date and at the beginning of each rider quarter. The base rider fee will be adjusted for any premium additions, excess withdrawals, transfers between designated investment groups, or changes to other allocation options during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the base rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The Open Allocation option base quarterly fee is calculated by multiplying (A) by (B) by (C), where:

(A) is the withdrawal base;

(B) is the rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

The Designated Allocation option base quarterly fee is calculated by multiplying (A) by (B) divided by (C) multiplied by (D), where:

(A) is the withdrawal base;

(B) is the sum of each designated investment group’s rider fee percentage multiplied by the applicable designated investment group’s value;

(C) is the total policy value; and

(D) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the base rider fee:

• Because the base rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the base rider fee is a percentage of the withdrawal base, the amount of the base rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

• If you make a transfer from one designated allocation group to another designated allocation group that has a higher rider fee percentage, then the resulting rider fee will be higher.

Base Rider Fee Adjustment for Transfers. For transfers that you make between different designated investment options in different designated allocation groups or different allocation options on other than the first business day of a rider quarter, a “rider fee adjustment” will be applied. This adjustment is

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necessary because of differences in the rider fee percentages. The adjustment in the rider fee percentage will ensure that you are charged the correct overall rider fee. The base rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated.

Base Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will also be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. As with the rider fee adjustments calculated for transfers, the rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

Additional Option Fees. If you elect options with this rider, then you will be charged a fee for each option you elect that is in addition to the rider fee for the base benefit (see the Fee Table). Each additional fee is charged quarterly before annuitization and is a percentage of the withdrawal base on each rider anniversary.

We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

Retirement Income Choice^® 1.2 Rider Issue Requirements

The Company will not issue the Retirement Income Choice^® 1.2 rider unless:

• the annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Choice^® 1.2 rider and any additional options will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity

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payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Choice^® 1.2 rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Choice^® 1.2 rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Retirement Income Choice^® 1.4 Rider – This Rider is No Longer Available for New Sales

You may elect to purchase the optional Retirement Income Choice^® 1.4 rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Choice^® 1.4 rider for a qualified policy.

Retirement Income Choice^® 1.4 – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary, as payments from us), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments and Rider Death Benefit Adjustments, below). A rider year begins on the rider date (the date the rider becomes effective) and thereafter on each anniversary of that date.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider

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when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you in determining whether these certain investment options are suited for your financial needs and risk tolerance.

• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base, and rider death benefit (if applicable) on a greater than dollar-for-dollar basis.

• Any withdrawal will reduce your rider death benefit (if applicable).

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Choice^® 1.4 rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” and “Rider Death Benefit Adjustments” below.

The rider withdrawal amount is zero if the annuitant is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (including the present value of any additional benefits provided under the policy to the extent required to be taken into account under IRS guidance) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider.

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If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage—Single Life Option			Withdrawal Percentage—Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.0	%		3.5	%
65-74		5.0	%		4.5	%
³ 75		6.0	%		5.5	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• Current withdrawal base;

• The withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

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• The policy value on any monthiversary, including the current rider anniversary (see “Automatic Step-Up” below).

Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix - Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base. See the “Appendix - Guaranteed Lifetime Benefit Adjustment Partial Surrenders - Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect hypothetical excess withdrawals in more detail.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

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Designated Investment Options.

If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options in the following designated allocation groups:

Designated Allocation Group A

AllianceBernstein Balanced Wealth Strategy Portfolio – Class B

American Funds – Asset Allocation Fund – Class 2

Fidelity VIP Balanced Portfolio – Service Class 2

GE Investments Total Return Fund – Class 3

Transamerica Index 75 VP – Service Class

Transamerica Madison Moderate Growth Allocation VP – Service Class

Designated Allocation Group B

Transamerica BlackRock Global Allocation VP – Service Class

Transamerica BlackRock Tactical Allocation VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Madison Balanced Allocation VP – Service Class

Transamerica Madison Diversified Income VP – Service Class

Designated Allocation Group C

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

American Funds – Bond Fund – Class 2

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Madison Conservative Allocation VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Within 30 days following the fifth rider anniversary (and each successive fifth rider anniversary), you can terminate this rider. Starting the next business day, you may transfer (or allocate premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can change a designated allocation group or eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Manual Upgrades. You can upgrade the withdrawal base to the policy value during the 30-day period following each successive fifth rider anniversary by sending us written notice in a form acceptable to us, as long as the rider issue requirements for a new rider are met. At this time the rider withdrawal amount and, if applicable, the rider death benefit will be recalculated. If an upgrade is elected, your current rider will terminate and a new rider will be issued with a new rider date, its own rider fee percentage (which may be higher or lower than your current rider fee percentage) and its own terms and benefits

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(which may not be as advantageous as the current rider); and any options you elect to change or add. The new rider date will be the date the Company receives all necessary information in good order. You cannot elect a manual upgrade if the annuitant (or the annuitant’s spouse if younger and the joint option is elected) is 86 or older.

Retirement Income Choice^® 1.4 – Additional Options

You may elect the following options with this rider (the options are not mutually exclusive):

• Death Benefit;

• Joint Life; and

• Income Enhancement.

There is an additional fee if you elect the Death Benefit and/or the Income Enhancement Benefit option(s) under the rider. If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower. Furthermore, if you elect the Joint Life option in combination with the Death Benefit and/or the Income Enhancement Benefit option(s), then the fee for each of those additional options will be different than under the Single Life option. See “Retirement Income Choice^® 1.4 Rider and Additional Option Fees”.

1. Death Benefit. If you elect this rider, you can also elect to add an additional amount to the death benefit payable under the base policy, upon the death of the annuitant (or if the joint life option is selected, the annuitant’s spouse). The additional amount will be equal to the excess, if any, of the rider death benefit over the greater of any optional guaranteed minimum death benefit or the base policy death benefit. The additional amount can be zero. See “Section 8. Death Benefit.”

Rider Death Benefit. The rider death benefit on the rider date is the policy value (less any premium enhancement if the rider is added in the first policy year). After the rider date, the rider death benefit is equal to:

• the rider death benefit on the rider date; plus

• subsequent premium payments; less

• adjustments for withdrawals (as described under “Rider Death Benefit Adjustments,” below).

Rider Death Benefit Adjustments. Gross partial withdrawals up to the rider withdrawal amount in a rider year will reduce the rider death benefit on a dollar-for-dollar basis. Gross partial withdrawals in excess of the rider withdrawal amount in a rider year will reduce the rider death benefit by the greater of the dollar amount of the excess withdrawal or a pro rata amount (in proportion to the reduction in policy value), and possibly to zero. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.4 Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that results in pro rata adjustments. Rider death benefit adjustments occur immediately following all withdrawals.

Please note:

• No additional death benefit is payable if the base policy death benefit (including the guaranteed minimum death benefit) exceeds the rider death benefit. The greater the death benefit payable under the guaranteed minimum death benefit selected, the more likely it is that an additional amount will not be payable under the rider death benefit option.

• Excess withdrawals may eliminate the additional death benefit available with this rider. You will continue to pay the fee for this option, even if the additional death benefit available under the rider is $0.

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• Manual upgrades to the withdrawal base will result in a recalculation of the rider death benefit. However, automatic step-ups will not reset the rider death benefit.

• If an owner who is not the annuitant dies and the surviving spouse continues the policy, then no additional amount is payable. If the policy is not continued, then the surviving owner (who is also the sole beneficiary) may elect to receive lifetime annuity payments equal to the rider withdrawal amount divided by the number of payments each year instead of receiving the policy’s cash value. Please note that under federal tax law, upon the death of an owner, only a “spouse” as defined under the Federal Defense of Marriage Act is permitted to continue a policy without taking required distributions. (The payment of a death benefit under the policy is triggered by the death of the annuitant.)

The additional death benefit payment option may be referred to as “minimum remaining withdrawal amount” on your policy statement and other documents.

2. Joint Life Benefit. If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

Please note:

• The withdrawal percentage for each “age at the time of first withdrawal” is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The rider death benefit is not payable until the death of the surviving spouse, if you elect this option.

• You cannot elect a manual upgrade if the annuitant or annuitant’s spouse is 86 or older (lower if required by state law).

3. Income Enhancement Option. If you elect this rider, you can also elect to have your withdrawal percentage double if either the annuitant (or the annuitant’s spouse if the joint life option is elected) is confined, due to a medical necessity in a hospital or nursing facility due to physical or cognitive ailments. Benefits from this option are not available unless the rider has been in effect for 12 months (the “waiting period”) and confinement must meet the elimination period of 180 days within the last 365 days. The elimination period and waiting period can, but do not need to, run concurrently.

Please note:

• You cannot elect the Income Enhancement Option if the individual(s) is/are already confined in a hospital or nursing facility.

• Confinement must be prescribed by a physician based on the individual’s inability to sustain themselves outside of a hospital or nursing facility due to physical or cognitive ailments.

• The increase to the withdrawal percentage stops when the qualifying person or persons is/are no longer confined as described above.

• The hospital and/or nursing facility must meet the criteria listed below to qualify for the benefit.

• You cannot elect the Income Enhancement Option if you are confined in an assisted living facility or a residential care facility.

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A Qualifying Hospital must meet the following criteria:

• It is operated pursuant to the laws of the jurisdiction in which it is located;

• It is operated primarily for the care and treatment of sick and injured persons on an inpatient basis;

• It provides 24-hour nursing service by or under the supervision of registered graduate professional nurses;

• It is supervised by a staff of one or more licensed physicians; and

• It has medical, surgical and diagnostic facilities or access to such facilities.

A Qualifying Nursing Facility must meet the following criteria:

• It is operated pursuant to the laws and regulations of the state in which it is located as a nursing facility or Alzheimer’s disease facility;

• It provides care performed or supervised by a registered graduate nurse;

• It provides room and board accommodations; and

• Will provide 24-hour nursing services, 7 days a week by an on-site Registered Nurse and related services on a continuing inpatient basis.

• It has a planned program of policies and procedures developed with the advice of, and periodically reviewed by, at least one physician; and

• It maintains a clinical record of each patient.

A Qualifying Nursing Facility does not include:

• Assisted living facilities or residential care facilities;

• A place primarily for treatment of mental or nervous disorders, drug addiction or alcoholism;

• A home for the aged, a rest home, community living center or a place that provides domestic, resident, retirement or educational care;

• Personal care homes, personal care boarding homes, residential or domiciliary care homes;

• A rehabilitation hospital or basic care facilities;

• Adult foster care facilities, congregate care facilities, family and group living assisted living facilities; or

• Other facilities similar to those described above.

We will require confirmation of confinement in a qualifying hospital or a qualifying nursing facility while benefit payouts are being received. Confirmation of that confinement will be attained and approved by completing our “Income Enhancement Election and Proof of Confinement Questionnaire” form. This form requires additional proof of confinement which may be a physician’s statement, a statement from a hospital or nursing facility administrator, or any other information satisfactory to us which may include information from third party or company interviews and/or visits of the facility. If it is determined that the qualifying individual was not confined in an eligible facility as defined above and has received payments under the Income Enhancement Option, those payments could be considered an excess withdrawal and have a negative effect on the rider values. If confinement ceases, you may re-qualify by satisfying another 180-day elimination period requirement.

Retirement Income Choice^® 1.4 Fees

Retirement Income Choice^® 1.4 Base Rider Fee. The base rider fee is calculated on the rider date and at the beginning of each rider quarter. The base rider fee will be adjusted for any premium additions, excess withdrawals, or transfers between designated investment groups during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the base rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The base quarterly fee is calculated by multiplying (A) by (B) divided by (C) multiplied by (D), where:

(A) is the withdrawal base;

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(B) is the sum of each designated investment group’s rider fee percentage multiplied by the applicable designated investment group’s value;

(C) is the total policy value; and

(D) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the fifth rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the base rider fee:

• Because the base rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the base rider fee is a percentage of the withdrawal base, the amount of the base rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

• If you make a transfer from one designated allocation group to another designated allocation group that has a higher rider fee percentage, then the resulting rider fee will be higher.

Base Rider Fee Adjustment for Transfers. For transfers that you make between different designated investment options in different designated allocation groups on other than the first business day of a rider quarter, a “rider fee adjustment” will be applied. This adjustment is necessary because of differences in the rider fee percentages. The adjustment in the rider fee percentage will ensure that you are charged the correct overall rider fee. The base rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated.

Base Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will also be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the base rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. As with the rider fee adjustments calculated for transfers, the rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

Additional Option Fees. If you elect options with this rider, then you will be charged a fee for each option you elect that is in addition to the rider fee for the base benefit (see the Fee Table). Each additional fee is charged quarterly before annuitization and is a percentage of the withdrawal base on each rider anniversary.

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We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

Retirement Income Choice^® 1.4 Rider Issue Requirements

The Company will not issue the Retirement Income Choice^® 1.4 rider unless:

• the annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Choice^® 1.4 rider and any additional options will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Choice^® 1.4 rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Choice^® 1.4 rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

Income Link^SM Rider

You may elect to purchase the optional Income Link^SM rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit that uses a higher withdrawal percentage for a defined period of time and then resets to a lower percentage (see the “Withdrawal Options and Percentages” section); and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Income Link^SM rider for a qualified policy. The date this rider is added to your policy is the “rider date.” You choose the date of the first Income Link^SM rider systematic withdrawal, which is the Income Link^SM rider start date.

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Income Link^SM Rider – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each Income Link^SM rider withdrawal year (first as systematic withdrawals from your policy value and, if necessary, as systematic payments from us), beginning on the Income Link^SM rider start date and lasting until the annuitant’s death (unless your withdrawal base is reduced to zero because of a non-Income Link^SM rider systematic withdrawal; see Withdrawal Base Adjustments below). The first Income Link^SM rider withdrawal year begins on the Income Link^SM rider start date and each successive Income Link^SM rider withdrawal year begins thereafter on each anniversary of that date.

Income Link^SM Rider – Systematic Withdrawals. In order to begin receiving Income Link^SM rider systematic withdrawals, you must elect the withdrawal option and frequency (monthly, quarterly, semi-annually or annually) through which you will receive the Income Link^SM rider systematic withdrawals (for qualified policies you will also have to elect whether or not to receive your minimum required distribution amount as calculated herein). Any change to the frequency of your Income Link^SM rider systematic withdrawals will take effect at the beginning of the next Income Link^SM rider withdrawal year. Any other withdrawal, regardless of amount or timing, is a non-Income Link^SM rider systematic withdrawal. See “Withdrawal Base Adjustments”.

Of course, you can always withdraw any amount up to your cash value pursuant to your rights under the policy at your discretion however, withdrawals other than Income Link^SM rider systematic withdrawals (and certain minimum required distributions) will reduce the withdrawal base. See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Income LinkSM Rider” for an example showing the effect of a hypothetical withdrawal in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for Income Link^SM rider systematic withdrawals from your policy value each Income Link^SM rider withdrawal year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount or on a non-systematic basis, because such withdrawals may significantly reduce or eliminate the value of the guarantees provided by the rider.

• Depending on which withdrawal option you elect, your withdrawal percentage will decrease after second, third, fourth, fifth, sixth or seventh withdrawal year.

• The longer you wait to start taking Income Link^SM rider systematic withdrawals under the rider, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular Income Link^SM rider systematic withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you

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in determining whether these certain investment options are suited for your financial needs and risk tolerance.

• Any withdrawal that is not an Income Link^SM rider systematic withdrawal (or certain minimum required distributions) will decrease the withdrawal base; the impact may be on a greater than dollar-for-dollar basis.

• During any Income Link^SM rider withdrawal year, if there is a withdrawal base adjustment, the remaining rider withdrawal amount and the Income Link^SM rider systematic withdrawal amount will increase or decrease by the same percentage as the withdrawal base.

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Income Link^SM rider terminates and all benefits thereunder cease.

• The only way to receive withdrawals (either Income Link^SM rider systematic withdrawals or minimum required distributions) without causing an adjustment to the withdrawal base is to use the Income Link^SM rider systematic withdrawal programs.

Like all withdrawals, Income Link^SM rider systematic withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce the amount you can withdraw “adjustment free” as a minimum required distribution;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount systematically each Income Link^SM rider withdrawal year from your policy value without causing an adjustment. See “Withdrawal Base Adjustments” below. You must use a systematic withdrawal program to withdraw your rider withdrawal amount. Such withdrawals are Income Link^SM rider systematic withdrawals. Any withdrawal other than an Income Link^SM rider systematic withdrawal is considered a non-Income Link^SM rider systematic withdrawal and will result in a withdrawal base adjustment (except for certain minimum required distributions, see “Minimum Required Distribution”).

The annual rider withdrawal amount is zero until Income Link^SM rider start date. On the Income Link^SM rider start date and at the beginning of each Income Link^SM rider withdrawal year thereafter, the annual rider withdrawal amount is equal to the applicable withdrawal percentage (based on the withdrawal option you elect) multiplied by the withdrawal base. During any Income Link^SM rider withdrawal year, the rider withdrawal amount and Income Link^SM rider systematic withdrawal amount may be adjusted up or down as described in the Withdrawal Base Adjustment section.

Minimum Required Distribution: Prior to the Income Link^SM rider start date, the systematic withdrawal of the minimum required distribution amount (determined as set forth below) will not cause an adjustment. After the Income Link^SM rider start date, the withdrawal of the minimum required distribution amount (determined as set forth below) will not cause an adjustment to the withdrawal base; however, it must be withdrawn pursuant to an Income Link^SM rider systematic withdrawal program whereby you will receive your Income Link^SM rider systematic withdrawals and any remaining minimum required distribution amount as calculated herein distributed at the end of the applicable calendar year (not at the end of the applicable rider year).

If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, you can withdraw via a systematic withdrawal option, an amount equal to any minimum required distribution amount (for the

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tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years). Minimum required distribution amounts calculated as set forth above and taken via a systematic withdrawal option will not cause an adjustment under this provision of the rider. Any withdrawal during a calendar year will reduce the withdrawal base adjustment free minimum required distribution amount for that year.

Please note: If you want to change the mode of the systematic withdrawal through which you are receiving your “adjustment free” minimum required distribution, your change will not take effect until the next anniversary of your systematic withdrawal program. Likewise, if you stop a systematic withdrawal program you cannot restart a new systematic program until the date that would have been the anniversary of the systematic withdrawal program you stopped. (For example, if you started a monthly systematic withdrawal program to receive your “adjustment free” minimum required distribution amount on August 19, 2010, and stopped it on December 21, 2010, you could not restart a new systematic withdrawal program until August 19, 2011.)

If your policy value reaches zero, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

Please note:

• The rider withdrawal amount will be zero until the Income Link^SM rider start date, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during an Income Link^SM rider withdrawal year for withdrawal in a future Income Link^SM rider withdrawal year. This means that if you do not take the entire rider withdrawal amount during an Income Link^SM rider withdrawal year, you cannot take more than the rider withdrawal amount in the next Income Link^SM rider withdrawal year and maintain the rider’s guarantees.

• Non-Income Link^SM rider systematic withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Options and Percentages. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the withdrawal option you select. The withdrawal percentages, categorized by withdrawal option, are as follows:

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Withdrawal Option— number years at increased rate	Withdrawal Percentage— Single Life Option	Withdrawal Percentage— Joint Life Option
7 years	5% for 7 years and 4% thereafter	4.5% for 7 years and 3.5% thereafter
6 years	6% for 6 years and 4% thereafter	5.5% for 6 years and 3.5% thereafter
5 years	7% for 5 years and 4% thereafter	6.5% for 5 years and 3.5% thereafter
4 years	8% for 4 years and 4% thereafter	7.5% for 4 years and 3.5% thereafter
3 years	9% for 3 years and 4% thereafter	8.5% for 3 years and 3.5% thereafter
2 years	10% for 2 years and 4% thereafter	9.5% for 2 years and 3.5% thereafter

Please note, once established, the withdrawal percentage will not increase.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to non-Income Link^SM rider systematic withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greater of:

• current withdrawal base or;

• the Automatic Step-up amount (see “Automatic Step-Up” below).

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary during the preceding rider year, if no non-Income Link^SM rider systematic withdrawal occurred, or (2) the policy value on the rider anniversary.

The rider fee percentage may increase (or decrease) at the time of any automatic step-up. The rider fee percentage will not exceed the maximum rider fee percentage in the fee table.

Please note:

• The withdrawal base “steps-up” on rider anniversaries whereas a Income Link^SM rider withdrawal year begins on the Income Link^SM rider start date and each anniversary thereof.

• If an automatic step-up occurs, your remaining rider withdrawal amount and Income Link^SM rider systematic withdrawal amount is proportionally increased for the remainder of that Income Link^SM rider withdrawal year.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up

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occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Premium additions will increase the withdrawal base on a dollar-for-dollar basis. See “Automatic Step-Up” for a description of how automatic step-ups increase the withdrawal base.

Income Link^SM rider systematic withdrawals up to the rider withdrawal amount will not reduce the withdrawal base. Non-Income Link^SM rider systematic withdrawals will reduce the withdrawal base, however, by the greater of the dollar amount of the withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Income Link^SM Rider” for examples showing the effect of hypothetical withdrawals in more detail. The effect of a negative adjustment is amplified if the policy value is less than the withdrawal base. See the “Appendix – Guaranteed Lifetime Benefit Adjustment Partial Surrenders – Income Link^SM Rider” for examples showing the effect of hypothetical non-Income Link^SM rider systematic withdrawals in more detail, including a non-Income Link^SM rider systematic withdrawal that reduces the withdrawal base by a pro rata amount. Withdrawal base adjustments occur immediately following premium additions or non-Income Link^SM rider systematic withdrawals. If you take a non-Income Link^SM rider systematic withdrawal that reduces your policy value (and withdrawal base) to zero, then the Income Link^SM rider will terminate and you will lose all its benefits.

Please Note: We do not monitor for non-Income Link^SM rider systematic withdrawals or notify you of withdrawal base adjustments. If you take a non-Income Link^SM rider systematic withdrawal please note your Income Link^SM rider systematic withdrawal amount will be reduced.

Designated Investment Options. If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options:

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

American Funds – Bond Fund – Class 2

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Madison Conservative Allocation VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Following the fifth rider anniversary you can terminate this rider. Starting the next business day, you may transfer (or allocate premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated

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investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Income Link^SM Rider – Joint Life Option

If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy).

If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower.

Please note:

• The withdrawal percentage for each withdrawal option is lower if you elect this option.

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

Income Link^SM Rider Fees

Income Link^SM Rider Fee. The rider fee is calculated on the rider date and at the beginning of each rider quarter. The rider fee will be adjusted for any premium additions and non-Income Link^SM rider systematic withdrawals during the rider quarter. It will be deducted automatically from your policy value at the end of each rider quarter.

On an annual basis, in general terms, the rider fee is the applicable “rider fee percentage” (see the Fee Table) times the withdrawal base.

The quarterly fee is calculated by multiplying (A) by (B) by (C), where:

(A) is the withdrawal base;

(B) rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

Beginning on the first rider anniversary, the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up will result in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the rider fee:

• Because the rider fee is a percentage of the withdrawal base, it could be a much higher

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percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the rider fee is a percentage of the withdrawal base, the amount of the rider fee we deduct will increase if the withdrawal base increases (although the percentage will remain the same).

Rider Fee Adjustment for Withdrawal Base Adjustments. A rider fee adjustment will also be calculated for subsequent premium payments and non-Income Link^SM rider systematic withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

We will also deduct the rider fee pro rata upon full surrender of the policy or other termination of the rider.

Income Link^SM Rider Issue Requirements

The Company will not issue the Income Link^SM rider unless:

• the annuitant is at least 55 years old and not yet 81 years old (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is at least 55 years old and not yet 81 years old (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Income Link^SM rider will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us following the fifth rider anniversary;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or if the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Income Link^SM rider may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Income Link^SM rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

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Retirement Income Max^SM Rider

You may elect to purchase the optional Retirement Income Max^SM rider which, provides you with: (1) a guaranteed lifetime withdrawal benefit; and (2) an opportunity for increases in the rider withdrawal amount. This rider is available during the accumulation phase, and requires that you allocate 100% of your policy value in certain designated investment choices which are designed to help manage the Company’s risk and support the guarantees under the rider. The tax rules for qualified policies may limit the value of this rider. Please consult a qualified tax advisor before electing the Retirement Income Max^SM rider for a qualified policy. If you elect the Retirement Income Max^SM rider you cannot elect another GLWB.

Retirement Income Max^SM – Base Benefit

Under this benefit, you can receive up to the rider withdrawal amount each rider year (first as withdrawals from your policy value and, if necessary because your policy value goes to zero by other than an excess withdrawal, as payments from us for life), starting with the rider year immediately following the annuitant’s (or the annuitant’s spouse if younger and the joint life option is elected) 59th birthday and lasting until the annuitant’s (or surviving spouse’s if the joint life option is elected) death (unless your withdrawal base is reduced to zero because of an “excess withdrawal”; see Withdrawal Base Adjustments, below). A rider year begins on the rider date and thereafter on each anniversary of that date.

Of course, you can always withdraw an amount up to your cash value pursuant to your rights under the policy at your discretion.

See the “Appendix—Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Max^SM Rider” for examples showing the effect of hypothetical withdrawals in more detail.

Please note:

• You will begin paying the rider charge as of the date the rider takes effect, even if you do not begin taking withdrawals for many years, or ever. We will not refund the charges you have paid under the rider if you never choose to take withdrawals and/or if you never receive any payments under the rider.

• We have designed this rider to allow for withdrawals from your policy value each rider year that are less than or equal to the rider withdrawal amount. You should not purchase this rider if you plan to take withdrawals in excess of the rider withdrawal amount, because such excess withdrawals may significantly reduce or eliminate the value of the guarantee provided by the rider.

• The longer you wait to start making withdrawals under the benefit, the less time you have to benefit from the guarantee because of decreasing life expectancy as you age. On the other hand, the longer you wait to begin making withdrawals, the higher your withdrawal percentage may be, the higher the withdrawal base due to growth may be, and the more opportunities you will have to lock in a higher withdrawal base. You should carefully consider when to begin making withdrawals. There is a risk that you will not begin making withdrawals at the most financially beneficial time for you.

• Because the guaranteed lifetime withdrawal benefit under this rider is accessed through regular withdrawals that do not exceed the rider withdrawal amount, the rider may not be appropriate for you if you do not foresee a need for liquidity and your primary objective is to take maximum advantage of the tax deferral aspect of the policy.

• All policy value must be allocated to a limited number of specified funds. You should consult with your registered representative to assist you in determining whether these certain investment options are suited for your financial needs and risk tolerance.

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• Cumulative withdrawals in any rider year that are in excess of the rider withdrawal amount are excess withdrawals.

• An excess withdrawal may impact the withdrawal base on a greater than dollar-for-dollar basis.

• Upon the death of the annuitant (or the death of the surviving spouse if the joint option is elected), the Retirement Income Max^SM rider terminates and all benefits thereunder cease.

Like all withdrawals, withdrawals while this rider is in effect also:

• reduce your policy value;

• reduce your base policy death benefit and other benefits;

• may be subject to surrender charges and excess interest adjustment;

• may be subject to income taxes and federal tax penalties; and

• may be limited or restricted under certain qualified policies.

Rider Withdrawal Amount. You can withdraw up to the rider withdrawal amount in any rider year (after age 59) from your policy value without causing an excess withdrawal. See “Withdrawal Base Adjustments” below.

The rider withdrawal amount is zero if the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is not 59 years old on the rider date and remains zero until the first day of the rider year after the annuitant’s (or the annuitant’s spouse’s if younger and the joint life option is elected) 59th birthday. If the annuitant (or the annuitant’s spouse if younger and the joint life option is elected) is at least 59 years old on the rider date, then the rider withdrawal amount is equal to the withdrawal base multiplied by the withdrawal percentage (see below).

For qualified policies: If the plan participant (generally the annuitant) is at least 70 ¹/2 years old, the rider withdrawal amount for that rider year (and each subsequent rider year) is equal to the greater of:

• the rider withdrawal amount described above; or

• an amount equal to any minimum required distribution amount (for the tax year on that rider anniversary) calculated using only: (1) the living annuitant’s age, (2) the IRS Uniform Lifetime table or, if applicable, the Joint Life and Survivor Expectancy table, (3) the policy value of the base policy, (prior to the first rider anniversary we use the policy value on the rider date and thereafter we use the policy value on the date prescribed by the IRS) and (4) amounts from the current calendar year (no carry-over from past years).

Only amounts calculated as set forth above can be used as the rider withdrawal amount. If the minimum required distribution amount (determined as set forth above) exceeds the rider withdrawal amount, the excess will not be treated as an excess withdrawal under the rider. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Max^SM Rider” for an example showing the effect of a minimum required distribution amount.

If your policy value reaches zero:

• due to a non-excess withdrawal, then you cannot make premium payments and all other policy features, benefits, and guarantees (except those provided by this rider) are terminated. In order to receive benefits guaranteed by this rider after your policy value reaches zero, (i.e., payments of the rider withdrawal amount for life) you must select the amount and frequency of future payments. Once selected, the amount and frequency cannot be changed.

• due to an excess withdrawal, then this rider terminates (as does the policy).

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Please note:

• If the rider is added prior to the annuitant’s 59th birthday, the rider withdrawal amount will be zero until the beginning of the rider year after the annuitant’s 59th birthday, however, you will still be charged a rider fee prior to this time.

• You cannot carry over any portion of your rider withdrawal amount that is not withdrawn during a rider year for withdrawal in a future rider year. This means that if you do not take the entire rider withdrawal amount during a rider year, you cannot take more than the rider withdrawal amount in the next rider year and maintain the rider’s guarantees.

• Excess withdrawals may cause you to lose the benefit of the rider.

• All policy value must be allocated to a limited number of specified funds. (See “Designated Investment Options.”)

Withdrawal Percentage. We use the withdrawal percentage to calculate the rider withdrawal amount. The withdrawal percentage is determined by the annuitant’s age (or the annuitant’s spouse’s age if younger and the joint life option is elected) at the time of the first withdrawal taken on or after the rider anniversary immediately following the annuitant’s (or the annuitant’s spouse’s if younger and the joint life option is elected) 59th birthday. The withdrawal percentage is as follows:

Age at time of first withdrawal	Withdrawal Percentage— Single Life Option			Withdrawal Percentage— Joint Life Option
0-58		0.0	%		0.0	%
59-64		4.5	%		4.10	%
65-74		5.5	%		5.10	%
³ 75		6.5	%		6.10	%

Please note, once established, the withdrawal percentage will not generally increase even though the annuitant’s age increases except in certain instances involving automatic step-ups.

Withdrawal Base. We use the withdrawal base to calculate the rider withdrawal amount. The withdrawal base on the rider date is the policy value (less any premium enhancement, if the rider is added in the first policy year). During any rider year, the withdrawal base is equal to the withdrawal base on the rider date or most recent rider anniversary, plus subsequent premium payments, less subsequent withdrawal base adjustments due to excess withdrawals.

Please note:

• We determine the withdrawal base solely to calculate the rider withdrawal amount. Your withdrawal base is not a cash value, a surrender value, or a death benefit. It is not available for withdrawal, it is not a minimum return for any subaccount, and it is not a guarantee of policy value.

• Because the withdrawal base is generally equal to the policy value on the rider date, the rider withdrawal amount may be lower if you delay electing the rider and the policy value decreases before you elect the rider.

On each rider anniversary, the withdrawal base will equal the greatest of:

• current withdrawal base;

• the withdrawal base immediately before the rider anniversary, increased by the growth credit, if any (see “Growth” below);

• the policy value on any monthiversary, (the same day of the month as the rider date, or the next business day if our Administrative Office or the New York Stock Exchange are closed) including the current rider anniversary (see “Automatic Step-Up” below).

See “Appendix – Hypothetical Example of the Withdrawal Base Calculation – Retirement Income Max^SM Rider” which illustrates the hypothetical example of the withdrawal base calculation.

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Growth. On each of the first ten rider anniversaries, we will add an annual growth credit to your withdrawal base if no withdrawal occurred during the preceding rider year. The annual growth credit is equal to 5.0% of the withdrawal base immediately before the rider anniversary (i.e., withdrawal base x 0.05).

Please note: Because a withdrawal will eliminate a potential growth credit for that rider year, you should consider your need or possible need to take withdrawals within the first 10 rider years in deciding whether to purchase the rider.

Automatic Step-Up. On each rider anniversary, we will automatically step-up the withdrawal base to an amount equal to the greater of (1) the highest policy value on any monthiversary during the preceding rider year, if no excess withdrawal occurred, or (2) the policy value on the rider anniversary. This comparison takes place after the application of any applicable annual growth credit. The withdrawal percentage (as indicated in the withdrawal percentage table) will also increase if you have crossed into another age band prior to the automatic step-up.

On each rider anniversary the rider fee percentage may increase (or decrease) up to 75 basis points (0.75%) at the time of any automatic step-up (but will not exceed the maximum rider fee percentage in the fee table), i.e., the rider fee percentage is reset to the rider fee percentage then associated with newly issued riders.

Automatic Step-Up Opt Out. Each time an automatic step-up results in a rider fee percentage increase, you have the option to reject the automatic step-up and reinstate the withdrawal base, withdrawal percentage, and rider fee percentage to their respective amounts immediately before the automatic step-up, provided that you do so within 30 days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection (each time you elect to opt out), in good order, at our Administrative and Service Office within the same 30 day period after the rider anniversary on which the automatic step-up occurred. Opting out of one step-up does not operate as an opt-out of any future step-ups.

Withdrawal Base Adjustments. Cumulative gross partial withdrawals up to the rider withdrawal amount in any rider year will not reduce the withdrawal base. Cumulative gross partial withdrawals in excess of the rider withdrawal amount in any rider year (“excess withdrawals”) will reduce the withdrawal base, however, by the greater of the dollar amount of the excess withdrawal (if the policy value is greater than the withdrawal base) or a pro rata amount (in proportion to the reduction in the policy value when the policy value is less than the withdrawal base), possibly to zero. If an excess withdrawal reduces the policy value to zero, this rider will terminate. Withdrawal base adjustments occur immediately following excess withdrawals. See “Appendix – Guaranteed Lifetime Withdrawal Benefit Adjusted Partial Surrenders – Retirement Income Max^SM Rider” for examples showing the effect of hypothetical withdrawals in more detail, including an excess withdrawal that reduces the withdrawal base by a pro rata amount. The effect of an excess withdrawal is amplified if the policy value is less than the withdrawal base.

Please Note: We do not monitor for, or notify you of, excess withdrawals. If you take regular or scheduled withdrawals please pay particular attention to any excess withdrawal because your otherwise regular or scheduled non-excess withdrawals may thereafter all be excess withdrawals that reduce or eliminate your benefit on an accelerated basis.

Designated Investment Options. If you elect this rider, you must designate 100% of your policy value into one or more of the designated investment options:

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American Funds – Bond Fund – Class 2

Transamerica AEGON Money Market VP – Service Class

Transamerica AEGON U.S. Government Securities VP – Service Class

Transamerica AllianceBernstein Dynamic Allocation VP – Service Class

Transamerica Foxhall Global Conservative VP – Service Class

Transamerica Index 35 VP – Service Class

Transamerica Index 50 VP – Service Class

Transamerica Madison Balanced Allocation VP – Service Class

Transamerica Madison Conservative Allocation VP – Service Class

Transamerica Madison Diversified Income VP – Service Class

Transamerica PIMCO Real Return TIPS VP – Service Class

Transamerica PIMCO Total Return VP – Service Class

Fixed Account

Transfers between the designated investment options are allowed as permitted under the policy; however, you cannot transfer any amount (or allocate premium payments) to any non-designated investment option. Within 30 days following the fifth rider anniversary (and each successive fifth rider anniversary), you can terminate this rider. Starting the next business day, you may transfer (or allocate premium payments) to a non-designated investment option. Terminating the rider will result in losing all your benefits under the rider.

Please note:

• The earliest you can transfer (or allocate premium payments) to a non-designated investment option is the first business day after the fifth rider anniversary. You will be required to terminate the rider first (and lose its benefits).

• We can eliminate a designated investment option at any time. If this occurs, then a policy owner will be required to reallocate values in the affected designated investment options to other designated investment options that meet the allocation requirements.

Retirement Income Max^SM – Joint Life Option

If you elect this rider, then you can also elect to postpone termination of the rider until the later of the annuitant or annuitant’s spouse’s death (only if the annuitant’s spouse continues the policy). If you elect the Joint Life option, then the withdrawal percentage (used to calculate the rider withdrawal amount) is lower.

Please note:

• The annuitant’s spouse must be either a joint owner along with the annuitant or the sole primary beneficiary (and there is no joint owner), if you elect this option.

• A former spouse of the annuitant cannot continue to keep the policy in force if no longer married to the annuitant at the time of the annuitant’s death. In that event, the rider will terminate and no additional withdrawals under the rider will be permitted.

• The annuitant’s spouse for purposes of this rider cannot be changed to a new spouse.

• The rider withdrawal percentage is based on the age of the younger of the annuitant and annuitant’s spouse, if you elect this option.

• The withdrawal percentage for each “age at the time of the first withdrawal” is lower if you elect this option.

Retirement Income Max^SM Rider Fees

Retirement Income Max^SM. The rider fee is calculated on the rider date and at the beginning of each rider quarter. The rider fee will be adjusted for any premium additions and excess withdrawals. It will be deducted automatically from your policy value at the end of each rider quarter.

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On an annual basis, in general terms, the rider fee is the “rider fee percentage” (see the Fee Table) times the withdrawal base. Specifically, the quarterly fee is calculated by multiplying (A) by (B) multiplied by (C), where:

(A) is the withdrawal base;

(B) is the rider fee percentage; and

(C) is the number of remaining days in the rider quarter divided by the total number of days in the applicable rider year.

Example 1: Calculation at rider issue for first quarter rider fee assuming an initial withdrawal base of $100,000.

=100,000*0.01(91/365)

=1,000*(91/365)

=$249.32

We will assess a prorated rider fee upon termination of the rider for the period beginning on the first day of the most recent rider quarter and ending on the date of termination.

On each rider anniversary the rider fee percentage may increase (or decrease) at the time of an automatic step-up. Each time an automatic step-up results in a rider fee percentage increase, you will have the option to reject the automatic step-up and reinstate the withdrawal base and rider fee percentage to their respective amounts immediately before the automatic step-up (adjusted for any subsequent premium payments or withdrawals), provided that you do so within 30 calendar days after the rider anniversary on which the automatic step-up occurred. We must receive your rejection, in good order, at our Administrative and Service Office within the 30 day period after the rider anniversary on which the automatic step-up occurred.

Please note regarding the rider fee:

• Because the rider fee is a percentage of the withdrawal base, it could be a much higher percentage of your policy value, particularly in the event that your policy value decreases significantly.

• Because the rider fee is a percentage of the withdrawal base, the amount of the rider fee we deduct will increase if the withdrawal base increases (although the percentage(s) may remain the same).

Rider Fee Adjustment for Premium Payments and Excess Withdrawals. A rider fee adjustment will be calculated for subsequent premium payments and excess withdrawals because these events will change the withdrawal base. The rider fee adjustment will be calculated using the same formula as the rider fee and compare the fee for the remainder of the rider quarter to the initially calculated fee for the same period. The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be collected.

Example 2: Calculation for first quarter fee assuming initial withdrawal base from Example 1 above, plus adjustment for additional premium payment of $10,000 made with 20 days remaining in the first rider quarter. The withdrawal base change equals $10,000.

Fee adjustment as follows:

=10,000*0.01(20/365)

=100*(20/365)

=$5.48

Total fee assessed at the end of the first rider quarter (assuming no further rider fee adjustments):

=5.48 + 249.32

=$254.80

We will also deduct all rider fees pro rata upon full surrender of the policy or other termination of the rider.

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Retirement Income Max^SM Rider Issue Requirements

The Company will not issue the Retirement Income Max^SM rider unless:

• The annuitant is not yet age 86 (lower if required by state law);

• the annuitant is also an owner (except in the case of non-natural owners);

• there are no more than two owners; and

• if the joint life option is elected, the annuitant’s spouse is also not yet 86 (lower if required by state law) and (1) is a joint owner along with the annuitant or (2) is the sole primary beneficiary (and there is no joint owner).

Termination

The Retirement Income Max^SM rider will terminate upon the earliest of the following:

• the date we receive written notice from you requesting termination of the rider if such notice is received by us during the 30 days following the fifth rider anniversary or every fifth rider anniversary thereafter;

• the death of the annuitant (or if the joint life option was elected, the death of the annuitant’s spouse if that spouse continued the policy as the surviving spouse);

• annuitization (however, if you have reached your maximum annuity commencement date you may choose an annuitization option which guarantees you lifetime payments in an amount equal to your rider withdrawal amount);

• the date the policy to which this rider is attached is assigned or if the owner is changed without our approval;

• the date an excess withdrawal reduces your policy value to zero; or

• termination of your policy.

Please note: This rider terminates upon annuitization and there is a maximum annuity commencement date at which time your policy will be annuitized according to its terms. However, if you have reached your maximum annuity commencement date, we will allow you to annuitize your policy and elect to receive lifetime annuity payments which are at least equal to your rider withdrawal amount. Please contact us for more information concerning your options.

The Retirement Income Max^SM rider and additional options may vary for certain policies, may not be available for all policies, and may not be available in all states. This disclosure explains the material features of the Retirement Income Max^SM rider. The application and operation of the rider are governed by the terms and conditions of the rider itself.

11. OTHER INFORMATION

Ownership

You, as owner of the policy, exercise all rights under the policy. You can change the owner at any time by notifying us in writing at our Administrative and Service Office. An ownership change may be a taxable event.

Beneficiary

The beneficiary designation will remain in effect until changed. The owner may change the designated beneficiary by sending written notice to the Company. The beneficiary’s consent to such change is not required unless the beneficiary was irrevocably designated or law requires consent. (If an irrevocable beneficiary dies, the owner may then designate a new beneficiary.) The change will take effect as of the date the owner signs the written notice, whether or not the owner is living when the notice is received by the Company. The Company will not be liable for any payment made before the written notice is received. If more than one beneficiary is designated, and the owner fails to specify their interests, they will share equally. If, upon the death of the annuitant, there is a

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surviving owner(s), then the surviving owner(s) automatically takes the place of any beneficiary designation.

Right to Cancel Period

You may return your policy for a refund, but only if you return it within a prescribed period, which is generally 10 days (after you receive the policy), or whatever longer time may be required by state law. The amount of the refund will generally be the premiums paid plus or minus accumulated gains or losses in the separate account. You bear the risk of any decline in policy value during the right to cancel period. However, if state law requires, we will refund your original premium payment(s). We will pay the refund within seven days after we receive in good order within the applicable period at our Administrative and Service Office, written notice of cancellation and the returned policy. The policy will then be deemed void.

Assignment

You can also generally assign the policy any time during your lifetime. We will not be bound by the assignment until we receive written notice of the assignment in good order at our Administrative and Service Office and approve it. We reserve the right, except to the extent prohibited by applicable laws, regulations, or actions of the State insurance commissioner, to require that an assignment will be effective only upon acceptance by us, and to refuse assignments or transfers at any time on a non-discriminatory basis. We will not be liable for any payment or other action we take in accordance with the policy before we approve the assignment. There may be limitations on your ability to assign a qualified policy. An assignment may have tax consequences.

Sending Forms and Transaction Requests in Good Order

We cannot process your requests for transactions relating to the policy until we have received them in good order at our Administrative and Service Office. “good order” means the actual receipt by us of the instructions relating to the requested transaction in writing (or, when appropriate, by telephone or electronically, along with all forms, information and supporting legal documentation necessary to effect the transaction. This information and documentation generally includes, to the extend applicable to the transaction: your completed application; the policy number; the transaction amount (in dollars or percentage terms); the names and allocations to and/or from the Subaccounts affected by the requested transaction; the signatures of all policy owners (exactly as registered on the Policy) if necessary; Social Security Number or Taxpayer I.D.; and any other information or supporting documentation that we may require, including any spousal or joint owner’s consents. With respect to purchase requests, “good order” also generally includes receipt (by us) of sufficient funds 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.

Mixed and Shared Funding

Before making a decision concerning the allocation of premium payments to a particular subaccount, please read the prospectuses for the underlying fund portfolios. The underlying fund portfolios are not limited to selling their shares to this separate account and can accept investments from any insurance company separate account or qualified retirement plan. Since the underlying fund portfolios are available to registered separate accounts offering variable annuity products of the Company, as well as variable annuity and variable life products of other insurance companies, and qualified retirement plans,

105

there is a possibility that a material conflict may arise between the interests of this separate account and one or more of the other separate accounts of another participating insurance company. In the event of a material conflict, the affected insurance companies, including the Company, agree to take any necessary steps to resolve the matter. This may include removing their separate accounts from the underlying fund portfolios. See the underlying fund portfolios prospectuses for more details.

Exchanges and Reinstatements

You can generally exchange one annuity policy for another in a “tax-free exchange” under Section 1035 of the Internal Revenue Code. Before making an exchange, you should compare both annuities carefully. Remember that if you exchange another annuity for the one described in this prospectus, then you may pay a surrender charge on the other annuity, and there will be a new surrender charge period under this annuity and other charges may be higher (or lower) and the benefits under this annuity may be different. You should not exchange another annuity for this one unless you determine, after knowing all the facts, that the exchange is in your best interest and not just better for the person trying to sell you this policy (that person will generally earn a commission if you buy this policy through an exchange or otherwise).

You may surrender your policy and transfer your money directly to another life insurance company (sometimes referred to as a 1035 Exchange or a trustee-to-trustee transfer). You may also ask us to reinstate your policy after such a transfer and in certain limited circumstances we will allow you to do so by returning the same total dollar amount of funds to the applicable investment choices. The dollar amount will be used to purchase new accumulation units at the then current price. Because of changes in market value, your new accumulation units may be worth more or less than the units you previously owned. We recommend that you consult a tax professional to explain the possible tax consequences of exchanges and/or reinstatements.

Voting Rights

To the extent required by law, the Company will vote all shares of the underlying fund portfolios held in the separate account in accordance with instructions we receive from you and other owners that have voting interests in the portfolios. We will send you and other owners requests for instructions on how to vote those shares. When we receive those instructions, we will vote all of the shares in proportion to those instructions. Accordingly, it is possible for a small number of policy owners (assuming there is a quorum) to determine the outcome of a vote, especially if they have large policy values. If, however, we determine that we are permitted to vote the shares in our own right, we may do so.

Each person having a voting interest will receive proxy material, reports, and other materials relating to the appropriate portfolio.

Legal Proceedings

There are no legal proceedings to which the separate account is a party or to which the assets of the separate account are subject. The Company, like other life insurance companies, is involved in lawsuits. In some class action and other lawsuits involving other insurers, substantial damages have been sought and/or material settlement payments have been made. Although the outcome of any litigation cannot be predicted with certainty, the Company believes that at the present time there are no pending or threatened lawsuits that are reasonably likely to have a material adverse impact on the separate account, on the ability of Transamerica Capital, Inc., to perform under its principal underwriting agreement, or on the ability of the Company to meet its obligations under the policy.

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Transamerica Life Insurance Company

Transamerica Life Insurance Company was incorporated under the laws of the State of Iowa on April 19, 1961 as NN Investors Life Insurance Company, Inc. It is engaged in the sale of life and health insurance and annuity policies. The Company is a wholly-owned indirect subsidiary of Transamerica Corporation which conducts most of its operations through subsidiary companies engaged in the insurance business or in providing non-insurance financial services. All of the stock of Transamerica Corporation is indirectly owned by AEGON N.V. of The Netherlands, the securities of which are publicly traded. AEGON N.V., a holding company, conducts its business through subsidiary companies engaged primarily in the insurance business. The Company is licensed in the District of Columbia, Guam, Puerto Rico, the U.S. Virgin Islands, and all states except New York.

All obligations arising under the policies, including the promise to make annuity payments, are general corporate obligations of the Company. Accordingly, no financial institution, brokerage firm or insurance agency is responsible for the financial obligations of the Company arising under the policies.

Financial Condition of the Company

We pay benefits under your Contract from our general account assets and/or from your policy value held in the separate account. It is important that you understand that payments of the benefits depend upon certain factors discussed below.

Assets in the Separate Account. You assume all of the investment risk for your policy value that is allocated to the subaccounts of the separate account. Your policy value in those subaccounts constitutes a portion of the assets of the separate account. These assets are segregated and insulated from our general account, and may not be charged with liabilities arising from any other business that we may conduct.

Assets in the General Account. You also may be permitted to make allocations to guaranteed period options of the fixed account, which are supported by the assets in our general account. Any guarantees under a policy that exceed policy value, such as those associated with any lifetime withdrawal benefit riders and any optional death benefits, are paid from our general account (and not the separate account). Therefore, any amounts that we may be obligated to pay under the policy in excess of policy value are subject to our financial strength and claims-paying ability and our long-term ability to make such payments. The assets of the separate account, however, are also available to cover the liabilities of our general account, but only to the extent that the separate account assets exceed the separate account liabilities arising under the policies supported by it.

We issue other types of insurance policies and financial products as well, and we also pay our obligations under these products from our assets in the general account.

Our Financial Condition. As an insurance company, we are required by state insurance regulation to hold a specified amount of reserves in order to meet all the contractual obligations of our general account. In order to meet our claims-paying obligation we monitor our reserves so that we hold sufficient amounts to cover actual or expected policy and claims payments. However, it is important to note that there are risks to purchasing any insurance product.

State insurance regulators also require insurance companies to maintain a minimum amount of capital, which acts as a cushion in the event that the insurer suffers a financial impairment, based on the inherent risks in the insurer’s operations. These risks include those associated with losses that we may incur as the result of defaults on the payment of interest or principal on our general account assets,

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which include bonds, mortgages, general real estate investments, and stocks, as well as the loss in market value of these investments.

How to Obtain More Information. We encourage both existing and prospective policy owners to read and understand our financial statements. We prepare our financial statements on a statutory basis. Our financial statements, which are presented in conformity with accounting practices prescribed or permitted by the Iowa Department of Commerce, Insurance Division as well as the financial statements of the separate account—are located in the statement of Additional Information (SAI). For a free copy of the SAI, simply call or write us at the phone number or address of our Administrative and Service Office referenced in this prospectus. In addition, the SAI’s available on the SEC;s website at http://www.sec.gov. Our financial strength can be found on our website.

The Separate Account

The Company established a separate account, called Separate Account VA C, under the laws of the State of Iowa on February 20, 1997. The separate account receives and invests the premium payments that are allocated to it for investment in shares of the underlying fund portfolios.

The separate account is registered with the SEC as a unit investment trust under the 1940 Act. However, the SEC does not supervise the management, the investment practices, or the policies of the separate account or the Company. Income, gains and losses (whether or not realized), from assets allocated to the separate account are, in accordance with the policies, credited to or charged against the separate account without regard to the Company’s other income, gains or losses.

The assets of the separate account are held in the Company’s name on behalf of the separate account and belong to the Company. However, those assets that underlie the policies are not chargeable with liabilities arising out of any other business the Company may conduct. The separate account may include other subaccounts that are not available under these policies.

Distribution of the Policies

Distribution and Principal Underwriting Agreement. We have entered into a principal underwriting agreement with our affiliate, Transamerica Capital, Inc. (TCI), for the distribution and sale of the policies. We pay commissions to TCI which are passed through to selling firms. (See below). We also pay TCI an “override” that is a percentage of total commissions paid on sales of our policies which is not passed through to the selling firms and we may reimburse TCI for certain expenses it incurs in order to pay for the distribution of the policies. TCI markets the policies through bank affiliated firms, national brokerage firms, regional and independent broker-dealers and independent financial planners.

Compensation to Broker-Dealers Selling the Policies. The policies are offered to the public through broker-dealers (“selling firms”) that are licensed under the federal securities laws; the selling firm and/or its affiliates are also licensed under state insurance laws. The selling firms have entered into written selling agreements with us and with TCI as principal underwriter for the policies. We pay commissions through TCI to the selling firms for their sales of the policies.

A limited number of affiliated and unaffiliated broker-dealers may also be paid commissions and overrides to “wholesale” the policies, that is, to provide sales support and training to sales representatives at the selling firms. We also provide compensation to a limited number of broker-dealers for providing ongoing service in relation to the policies that have already been purchased.

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The selling firms that have selling agreements with us and TCI are paid commissions for the promotion and sale of the policies according to one or more schedules. The amount and timing of commissions may vary depending on the selling agreement, but the maximum commission is 6% of premiums (additional amounts may be paid as overrides to wholesalers).

To the extent permitted by Financial Industry Regulatory Authority (FINRA) rules, TCI may pay (or allow other broker-dealers to provide) promotional incentives or payments in the form of cash or non-cash compensation or reimbursement to some, but not all, selling firms and their sales representatives. These arrangements are sometimes referred to as “revenue sharing” arrangements and are described further below.

The sales representative who sells you the policy typically receives a portion of the compensation we (and our affiliates) pay to the selling firms, depending on the agreement between the selling firm and its registered representative and the firm’s internal compensation program. These programs may include other types of cash and non-cash compensation and other benefits. Ask your sales representative for further information about the compensation your sales representative, and the selling firm that employs your sales representative, may receive in connection with your purchase of a policy. Also inquire about any revenue sharing arrangements that we and our affiliates may have with the selling firm, including the conflicts of interests that such arrangements may create.

You should be aware that a selling firm or its sales representatives may receive different compensation or incentives for selling one product over another. In some cases, these differences may create an incentive for the selling firm or its sales representatives to recommend or sell this policy to you. You may wish to take such incentives into account when considering and evaluating any recommendation relating to the policies.

Special Compensation Paid to Affiliated Firms.

We and/or our affiliates provide paid-in capital to TCI and pay the cost of TCI’s operating and other expenses, including costs for facilities, legal and accounting services, and other internal administrative functions. We and/or our affiliates also provide TCI with a percentage of total commissions paid on sales of our policies and provide TCI with capital payments that are not contingent on sales.

TCI’s registered representatives and supervisors may receive non-cash compensation, such as attendance at conferences, seminars and trips (such as travel, lodging and meals in connection therewith), entertainment, merchandise and other similar items, payments, loans, loan forgiveness or loan guaranties.

Additional Compensation That We, TCI and/or Our Affiliates Pay to Selected Selling Firms. TCI, in connection with the sales of the policies, may pay certain selling firms additional cash amounts for “preferred product” treatment of the policies in their marketing programs in order to receive enhanced marketing services and increased access to their sales representatives. In exchange for providing TCI with access to their distribution network, such selling firms may receive additional compensation or reimbursement for, among other things, the hiring and training of sales personnel, marketing, sponsoring of conferences, meetings, seminars, events, and/or other services they provide to us and our affiliates. To the extent permitted by applicable law, TCI and other parties may provide the selling firms with occasional gifts, meals, tickets or other non-cash compensation as an incentive to sell the policies. These special compensation arrangements are not offered to all selling firms and the terms of such arrangements may differ among selling firms.

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Special compensation arrangements are calculated in different ways by different selling firms and may be based on past or anticipated sales of the policies and other criteria. For instance, in 2010, TCI, in connection with the sales of our policies, made flat fee payments to several selling firms ranging from $6,350 to $500,000, and payments of between 0.10% and 1.32% on new sales. TCI also paid selling firms special fees based on new sales and/or assets under management.

During 2010, we and/or TCI had such “preferred product” arrangements with the following selling firms:

AXA

Carillon Financial

Centarus Financial

CFD Investments

Citizens Bank

Compass Bank

Equity Services

Financial Advisors of America

Financial Network

Fintegra

Genworth Financial

Girard Securities

Hantz Financial

Huntington Bank

Independent Financial Group

Invest Financial Corporation

James T. Borello

Kovack Securities

LPL Financial

M&T Bank

Merrill Lynch

Money Concepts

Morgan Stanley Smith Barney

Multi Family Securities Corp

Multi Financial

National Planning Corporation

Newbridge Securities

NEXT Financial Group

Park Avenue Securities

Primevest

ProEquities

Raymond James and Associates

Raymond James Financial Group

Sigma Financial

Signator Investments

SII Investments

Summit Equities

Suntrust Bank

TFS Securities, Inc.

The Planners Network

Transamerica Financial Advisors

UBS Financial

UnionBanc Investment Services LLC

US Bancorp

Valmark Securities

Wells Fargo/Wachovia

World Equity Group

Word Group Securities

During 2010, in conjunction with TCI, we paid the following amounts (in addition to sales commissions) to the top 10 selling firms (in terms of amounts paid):

Name of Firm	Amount Paid in 2010
Wells Fargo/Wachovia	$	1,327,561
LPL Financial	$	1,170,949
Morgan Stanley Smith Barney	$	1,122,219
Merrill Lynch	$	810,000
Transamerica Financial Advisors	$	750,789
UBS Financial	$	485,097
Raymond James Financial Services	$	426,264
World Group Securities	$	412,219
National Planning Corporation	$	315,904
Citizens Bank	$	270,113

No specific charge is assessed directly to policy owners or the separate account to cover commissions, non-cash compensation, and other incentives or

110

payments described above. We do intend to recoup commissions and other sales expenses and incentives we pay, however, through fees and charges deducted under the policy and other corporate revenue.

TABLE OF CONTENTS OF THE STATEMENT OF ADDITIONAL INFORMATION

Glossary of Terms

The Policy - General Provisions

Certain Federal Income Tax Consequences

Investment Experience

Historical Performance Data

Published Ratings

State Regulation of Transamerica Life Insurance Company

Administration

Records and Reports

Distribution of the Policies

Voting Rights

Other Products

Custody of Assets

Legal Matters

Independent Registered Public Accounting Firm

Other Information

Financial Statements

Appendix - OA Method Transfers

Appendix - PAM Method Transfers

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APPENDIX

CONDENSED FINANCIAL INFORMATION

The accumulation unit values and the number of accumulations units outstanding from each subaccount from the date of inception are shown in the following tables.

			1.85%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica BlackRock Global Allocation VP – Service Class		2010	$	1.200425	$	1.292577		8,291,227.438
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.200425		2,814,354.466
Transamerica BlackRock Large Cap Value VP – Service Class		2010	$	0.814239	$	0.880613		1,608,893.122
Subaccount Inception Date December 13, 1999		2009	$	0.729294	$	0.814239		312,776.737
		2008	$	1.000000	$	0.729294		14,257.504
Transamerica BlackRock Tactical Allocation VP – Service Class		2010	$	1.204175	$	1.315228		2,331,268.057
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.204175		605,373.387
Transamerica Clarion Global Real Estate Securities VP – Service Class		2010	$	0.824058	$	0.932888		518,543.724
Subaccount Inception Date May 1, 2002		2009	$	0.631030	$	0.824058		55,404.231
		2008	$	1.000000	$	0.631030		5,393.402
Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class		2010	$	0.985441	$	0.997558		738,582.494
Subaccount Inception Date November 19, 2009		2009	$	0.986565	$	0.985441		271,173.391
Transamerica AEGON High Yield Bond VP – Service Class		2010	$	1.085851	$	1.195869		543,099.689
Subaccount Inception Date December 13, 1999		2009	$	0.753059	$	1.085851		83,802.739
		2008	$	1.000000	$	0.753059		0.000
Transamerica MFS International Equity VP – Service Class		2010	$	0.924448	$	1.001197		414,813.737
Subaccount Inception Date May 1, 2001		2009	$	0.712018	$	0.924448		191,893.299
		2008	$	1.000000	$	0.712018		13,110.671
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.044209	$	1.096349		5,945,297.918
Subaccount Inception Date May 1, 2002		2009	$	0.918798	$	1.044209		1,808,495.253
		2008	$	1.000000	$	0.918798		307,031.381
Transamerica T. Rowe Price Small Cap VP – Service Class		2010	$	0.969402	$	1.275993		497,670.994
Subaccount Inception Date December 13, 1999		2009	$	0.713745	$	0.969402		78,595.690
		2008	$	1.000000	$	0.713745		321.981
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class		2010	$	0.881152	$	0.944319		520,497.561
Subaccount Inception Date May 1, 2002		2009	$	0.684218	$	0.881152		80,507.490
		2008	$	1.000000	$	0.684218		0.000
Transamerica AEGON Money Market VP – Service Class		2010	$	0.983647	$	0.965818		4,509,259.953
Subaccount Inception Date December 13, 1999		2009	$	1.001736	$	0.983647		4,845,675.557
		2008	$	1.000000	$	1.001736		2,762,745.906
Transamerica AEGON U.S. Government Securities VP – Service Class		2010	$	1.055054	$	1.079643		1,891,712.434
Subaccount Inception Date December 13, 1999		2009	$	1.031288	$	1.055054		1,551,702.556
		2008	$	1.000000	$	1.031288		28,835.351
Transamerica Index 35 VP – Service Class		2010	$	0.997845	$	1.072050		509,730.221
Subaccount Inception Date November 19, 2009		2009	$	0.999950	$	0.997845		0.000
Transamerica Index 50 VP – Service Class		2010	$	0.933525	$	1.014580		1,712,295.326
Subaccount Inception Date May 1, 2008		2009	$	0.815922	$	0.933525		1,018,493.141
		2008	$	1.000000	$	0.815922		16,386.023
Transamerica Index 75 VP – Service Class		2010	$	0.870910	$	0.966294		6,081,790.941
Subaccount Inception Date May 1, 2008		2009	$	0.720097	$	0.870910		3,793,893.524
		2008	$	1.000000	$	0.720097		765,265.451
Transamerica Index 100 VP – Service Class		2010	$	1.023790	$	1.150020		139,129.324
Subaccount Inception Date November 19, 2009		2009	$	0.999950	$	1.023790		0.000

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CONDENSED FINANCIAL INFORMATION — (Continued)

			1.85%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica Morgan Stanley Active International Allocation VP – Service		2010	$	0.835905	$	0.888053		180,533.420
Class		2009	$	0.677428	$	0.835905		92,309.727
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	0.677428		10,289.109
Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class		2010	$	0.959324	$	1.258194		225,045.306
Subaccount Inception Date May 1, 2001		2009	$	0.610219	$	0.959324		38,897.481
		2008	$	1.000000	$	0.610219		3,477.655
PAM Transamerica AEGON U.S. Government Securities VP – Service		2010	$	1.055054	$	1.079643		3,032.191
Class		2009	$	1.031288	$	1.055054		2,492.689
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	1.031288		22,921.360
Transamerica ProFunds UltraBear Fund – Service Class OAM		2010	$	0.561040	$	0.403424		115,590.490
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	0.561040		0.000
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.234764	$	1.334562		1,312,313.116
Subaccount Inception Date Novemeber 10, 2008		2009	$	1.012506	$	1.234764		1,110,489.184
		2008	$	1.000000	$	1.012506		0.000
American Funds – Asset Allocation Fund – Class 2		2010	$	1.007757	$	1.109924		1,163,012.575
Subaccount Inception Date November 19, 2009		2009	$	0.989772	$	1.007757		23,118.460
American Funds – Bond Fund – Class 2		2010	$	0.993473	$	1.035242		385,357.711
Subaccount Inception Date November 19, 2009		2009	$	1.000893	$	0.993473		35,084.385
American Funds – Growth Fund – Class 2		2010	$	1.002616	$	1.164887		536,171.086
Subaccount Inception Date November 19, 2009		2009	$	0.986475	$	1.002616		43,021.345
American Funds – Growth-Income Fund – Class 2		2010	$	1.008005	$	1.099564		341,823.719
Subaccount Inception Date November 19, 2009		2009	$	0.986796	$	1.008005		26,448.864
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.901874	$	1.042736		847,914.926
Subaccount Inception Date May 1, 2008		2009	$	0.664068	$	0.901874		407,275.450
		2008	$	1.000000	$	0.664068		78,741.863
Franklin Income Securities Fund – Class 2		2010	$	0.969753	$	1.072808		739,031.153
Subaccount Inception Date May 1, 2007		2009	$	0.728407	$	0.969753		161,021.114
		2008	$	1.000000	$	0.728407		0.000
GE Investments Total Return Fund – Class 3		2010	$	1.003397	$	1.075335		194,418.013
Subaccount Inception Date November 19, 2009		2009	$	0.988804	$	1.003397		0.000
			1.65%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica BlackRock Global Allocation VP – Service Class		2010	$	1.201990	$	1.296818		16,341,040.280
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.201990		4,527,629.053
Transamerica BlackRock Large Cap Value VP – Service Class		2010	$	0.817361	$	0.885726		2,412,135.173
Subaccount Inception Date December 13, 1999		2009	$	0.730649	$	0.817361		777,882.140
		2008	$	1.000000	$	0.730649		23,530.102
Transamerica BlackRock Tactical Allocation VP – Service Class		2010	$	1.205764	$	1.319555		3,963,821.864
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	1.205764		1,527,902.709
Transamerica Clarion Global Real Estate Securities VP – Service Class		2010	$	0.827221	$	0.938309		971,649.818
Subaccount Inception Date May 1, 2002		2009	$	0.632208	$	0.827221		325,401.525
		2008	$	1.000000	$	0.632208		530.541
Transamerica Foxhall Global Conservative VP – Service Class		2010	$	0.983439	$	0.908509		1,390,492.289
Subaccount Inception Date November 19, 2009		2009	$	0.995068	$	0.983439		50,992.905
Transamerica Foxhall Global Commodities & Hard Assets VP – Service Class		2010	$	0.985671	$	0.999750		2,216,792.820
Subaccount Inception Date November 19, 2009		2009	$	0.986571	$	0.985671		14,201.885

113

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.65%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
Transamerica AEGON High Yield Bond VP – Service Class		2010	$	1.089989	$	1.202779		1,095,580.651
Subaccount Inception Date December 13, 1999		2009	$	0.754457	$	1.089989		362,124.837
		2008	$	1.000000	$	0.754457		0.000
Transamerica MFS International Equity VP – Service Class		2010	$	0.927994	$	1.007030		633,007.676
Subaccount Inception Date May 1, 2001		2009	$	0.713341	$	0.927994		318,535.330
		2008	$	1.000000	$	0.713341		30,244.316
Transamerica PIMCO Total Return VP – Service Class		2010	$	1.048199	$	1.102698		8,930,040.986
Subaccount Inception Date May 1, 2002		2009	$	0.920505	$	1.048199		4,737,769.663
		2008	$	1.000000	$	0.920505		2,016,890.588
Transamerica T. Rowe Price Small Cap VP – Service Class		2010	$	0.973095	$	1.283366		944,657.482
Subaccount Inception Date December 13, 1999		2009	$	0.715068	$	0.973095		374,580.217
		2008	$	1.000000	$	0.715068		18,914.294
Transamerica AllianceBernstein Dynamic Allocation VP – Service Class		2010	$	0.884529	$	0.949802		857,226.226
Subaccount Inception Date May 1, 2002		2009	$	0.685489	$	0.884529		54,433.003
		2008	$	1.000000	$	0.685489		2,442.079
Transamerica AEGON Money Market VP – Service Class		2010	$	0.987430	$	0.971427		4,583,578.385
Subaccount Inception Date December 13, 1999		2009	$	1.003592	$	0.987430		4,757,321.363
		2008	$	1.000000	$	1.003592		1,499,328.840
Transamerica AEGON U.S. Government Securities VP – Service Class		2010	$	1.059101	$	1.085909		7,655,931.765
Subaccount Inception Date December 13, 1999		2009	$	1.033204	$	1.059101		3,438,793.688
		2008	$	1.000000	$	1.033204		872,719.436
Transamerica Index 35 VP – Service Class		2010	$	0.998075	$	1.074408		1,600,059.091
Subaccount Inception Date November 19, 2009		2009	$	0.999955	$	0.998075		33,287.399
Transamerica Index 50 VP – Service Class		2010	$	0.936613	$	1.019934		2,795,250.055
Subaccount Inception Date May 1, 2008		2009	$	0.817007	$	0.936613		1,866,428.019
		2008	$	1.000000	$	0.817007		257,385.854
Transamerica Index 75 VP – Service Class		2010	$	0.873783	$	0.971384		9,362,116.258
Subaccount Inception Date May 1, 2008		2009	$	0.721052	$	0.873783		7,061,328.811
		2008	$	1.000000	$	0.721052		1,346,647.630
Transamerica Index 100 VP – Service Class		2010	$	1.024027	$	1.152543		415,423.577
Subaccount Inception Date November 19, 2009		2009	$	0.999955	$	1.024027		0.000
Transamerica ProFunds UltraBear Fund – Service Class OAM		2010	$	0.561781	$	0.404748		303,046.526
Subaccount Inception Date May 1, 2009		2009	$	1.000000	$	0.561781		0.000
Transamerica Morgan Stanley Active International Allocation VP – Service		2010	$	0.839096	$	0.893198		425,794.831
Class		2009	$	0.678678	$	0.839096		137,649.624
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	0.678678		518.125
Transamerica Morgan Stanley Mid-Cap Growth VP – Service Class		2010	$	0.962999	$	1.265509		1,012,267.649
Subaccount Inception Date May 1, 2001		2009	$	0.611350	$	0.962999		357,942.739
		2008	$	1.000000	$	0.611350		0.000
PAM Transamerica AEGON U.S. Government Securities VP – Service		2010	$	1.059101	$	1.085909		126,322.027
Class		2009	$	1.033204	$	1.059101		192,922.883
Subaccount Inception Date December 13, 1999		2008	$	1.000000	$	1.033204		241,308.630
AllianceBernstein Balanced Wealth Strategy Portfolio – Class B		2010	$	1.237531	$	1.340179		982,285.304
Subaccount Inception Date November 10, 2008		2009	$	1.012783	$	1.237531		343,252.727
		2008	$	1.000000	$	1.012783		33,981.111
American Funds – Asset Allocation Fund – Class 2		2010	$	1.007990	$	1.112364		1,192,409.561
Subaccount Inception Date November 19, 2009		2009	$	0.989778	$	1.007990		15,818.325
American Funds – Bond Fund – Class 2		2010	$	0.993701	$	1.037506		1,505,132.018
Subaccount Inception Date November 19, 2009		2009	$	1.000899	$	0.993701		0.000

114

CONDENSED FINANCIAL INFORMATION — (Continued)

			1.65%
Subaccount	Year		Beginning AUV		Ending AUV		# Units
American Funds – Growth Fund – Class 2		2010	$	1.002849	$	1.167433		890,602.425
Subaccount Inception Date November 19, 2009		2009	$	0.986481	$	1.002849		281,783.138
American Funds – Growth-Income Fund – Class 2		2010	$	1.008240	$	1.101971		495,504.155
Subaccount Inception Date November 19, 2009		2009	$	0.986802	$	1.008240		0.000
Fidelity VIP Balanced Portfolio – Service Class 2		2010	$	0.904846	$	1.048229		2,051,668.484
Subaccount Inception Date May 1, 2008		2009	$	0.664950	$	0.904846		1,251,635.854
		2008	$	1.000000	$	0.664950		806,851.377
Franklin Income Securities Fund – Class 2		2010	$	0.973455	$	1.079026		940,960.968
Subaccount Inception Date May 1, 2007		2009	$	0.729760	$	0.973455		343,481.466
		2008	$	1.000000	$	0.729760		160,393.849
GE Investments Total Return Fund – Class 3		2010	$	1.003631	$	1.077697		279,431.129
Subaccount Inception Date November 19, 2009		2009	$	0.988810	$	1.003631		0.000

Transamerica Madison Moderate Growth Allocation VP, Transamerica Madison Balanced Allocation VP, Transamerica Madison Diversified Income VP, TA PIMCO Real Return TIPS VP, Transamerica Madison Conservative Allocation VP and Transamerica Madison Large Cap Growth VP had not commenced operations as of December 31, 2010, therefore, comparable data is not available.

115

APPENDIX

POLICY VARIATIONS

The dates shown below are the approximate first issue dates of the various versions of the policy. These dates will vary by state in many cases. This Appendix describes certain of the more significant differences in features of the various versions of the policy. There may be additional variations. Please see your actual policy and any attachments for determining your specific coverage.

Policy Form/Endorsement	Approximate First Issue Date
AV464 101 121 799	December 1999
RGMI 1 798 (Family Income Protector)	December 1999
AV630 101 138 101	May 2001
AV710 101 147 102	May 2002
AV950 101 175 603	November 2003

116

Product Feature	ExtraSM Form Number: – AV464 101 121 799 – RGMI 1 798	ExtraSM 2001 Form Number: – AV630 101 138 101 – RGMI 1 798	ExtraSM 2002 Form Number: – AV710 101 147 102 – RGMI 1 798
Guaranteed Minimum Death Benefit Option(s)	Annual Step-Up Death Benefit—the largest policy value on the policy date or on any policy anniversary before you reach age 76; plus any premium payments you have made since then; minus any adjusted partial surrenders (discussed below) we have paid to you since then. Option is available if owner or annuitant is 74 or younger.	Annual Step-Up Death Benefit—the largest policy value on the policy date or on any policy anniversary before you reach age 81; plus any premium payments you have made since then; minus any adjusted partial surrenders (discussed below) we have paid to you since then. Option is available if owner or annuitant is 79 or younger.	A.Double Enhanced Death Benefit—greater of 1)      6% Annually Compounding through age 80 2)      monthly step-up through age 80 B.Return of Premium Option A is available if both owner and annuitant are under age 81. Option B is available if both owner and annuitant are under age 84.
Double Enhanced Death Benefit Designated Funds	N/A	N/A	N/A
Death Proceeds	Greatest of: 1)      policy value 2)      cash value 3)      guaranteed minimum death benefit.	Greatest of: 1)      policy value 2)      cash value 3)      guaranteed minimum death benefit.	Greatest of: 1)      policy value 2)      cash value 3)      guaranteed minimum death benefit.
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	•        1.75% for Annual Step-Up.	•        1.75% for Annual Step-Up - first 10 Policy Years. •        1.55% for Annual Step-Up - after first 10 Policy Years.	•        1.75% for Return of Premium - for first 10 Policy Years. •        1.30% for Return of Premium - after 10 Policy Years. •        2.00% for Double Enhanced - for first 10 Policy Years. •        1.55% for Double Enhanced - after first 10 Policy Years.
Is Mortality & Expense Risk Fee and Administrative Charge different after the annuity commencement date?	Yes - 1.55%	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee Premium Enhancement Guaranteed Period Options (available in the fixed account) Annual Contract Charge (Service Charge)	No Yes Up to 5% for ages 0-69 Up to 4% for ages 70+ 1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value is at least $100,000 or if the sum of your premiums, less all partial surrenders, is at least $100,000.	No Yes Up to 5% for ages 0-69 Up to 4% for ages 70+ 1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value is at least $100,000 or if the sum of your premiums, less all partial surrenders, is at least $100,000.	No Yes Up to 5% for ages 0-69 Up to 4% for ages 70+. 1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $50,000.

117

Product Feature	ExtraSM Form Number: – AV464 101 121 799 – RGMI 1 798	ExtraSM 2001 Form Number: – AV630 101 138 101 – RGMI 1 798	ExtraSM 2002 Form Number: – AV710 101 147 102 – RGMI 1 798
Optional Riders	•        5 for Life 2005	•        5 for Life 2005	•        5 for Life 2005
	•        Family Income Protector	•        Family Income Protector	•        Family Income Protector
	•        Managed Annuity Program	•        Managed Annuity Program	•        Managed Annuity Program
	•        Managed Annuity Program II	•        Managed Annuity Program II	•        Managed Annuity Program II
	•        Living Benefit Rider 2003	•        Living Benefit Rider 2003	•        Living Benefit Rider 2003
	•        Living Benefit Rider 2005	•        Living Benefit Rider 2005	•        Living Benefit Rider 2005
	•        Taxpayer	•        Taxpayer	•        Taxpayer
	•        Taxpayer Plus 2	•        Taxpayer Plus 2	•        Taxpayer Plus 2
	•        Taxpayer 2003	•        Taxpayer 2003	•        Taxpayer 2003
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing Option	Yes	Yes	Yes
Dollar Cost Averaging Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes	Yes	Yes
Unemployment Waiver	Yes	Yes	Yes
Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Death Proceeds	Greatest of:	Greatest of:	Greatest of:
	1)      policy value	1)      policy value	1)      policy value
	2)      cash value	2)      cash value	2)      cash value
	3)      guaranteed minimum death benefit.	3)      guaranteed minimum death benefit.	3)      guaranteed minimum death benefit.
Guaranteed Minimum Death Benefit Option(s)	Return of Premium Death Benefit (available if owner and annuitant are age 84 or younger).	Return of Premium Death Benefit (RGMD 8 0603) available if owner and annuitant are age 84 or younger.	A.     Return of Premium Death Benefit (RGMD 8 0603) B.     Modal Step Up (RGMD 5 0103) C.     Double Enhanced (RGMD 15 0108)
			Option A is available if owner and annuitant are age 90 or younger. Option B and Option C are available if owner and annuitant are age 75 or younger.

118

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Double Enhanced Death Benefit Designated Funds	N/A	N/A	•        AllianceBernstein Balanced Wealth Strategy Portfolio - Class B
			•        American Funds - Asset Allocation Fund - Class 2
			•        American Funds - Bond Fund - Class 2
			•        Fidelity VIP Balanced Portfolio – Service Class 2
			•        Franklin Templeton VIP Founding Funds Allocation Fund - Class 4
			•        GE Investments Total Return Fund – Class 3
			•        Transamerica Asset Allocation - Conservative VP – Service Class
			•        Transamerica Asset Allocation - Moderate VP – Service Class
			•        Transamerica Asset Allocation - Moderate Growth VP – Service Class
			•        Transamerica International Moderate Growth VP – Service Class
			•        Transamerica Multi-Managed Balanced VP – Service Class
			•        Transamerica BlackRock Global Allocation VP - Service Class
			•        Transamerica BlackRock Tactical Allocation VP - Service Class
			•        Transamerica Efficient Markets VP - Service Class
			•        Transamerica Foxhall Global Conservative VP – Service Class
			•        Transamerica Index 35 VP – Service Class
			•        Transamerica Index 50 VP – Service Class
			•        Transamerica Index 75 VP – Service Class
			•        Transamerica AEGON Money Market VP – Service Class
			•        Transamerica PIMCO Total Return VP – Service Class
			•        Transamerica AEGON U.S. Government Securities VP – Service Class

119

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	•        1.75% for Return of Premium - for first 10 Policy Years. •        1.30% for Return of Premium - after 10 Policy Years.	•        1.75% for Return of Premium - for first 10 Policy Years. •        1.30% for Return of Premium - after 10 Policy Years.	•        1.65% for Return of Premium. •        1.85% for Annual Step-Up. •        2.30% for Double Enhanced.
Is Mortality & Expense Risk Fee and Administrative Charge different after the annuity commencement date?	Yes - 1.25%	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee	No	Yes -	Yes -
		•        0.30% if you choose American Funds - Asset Allocation Fund, American Funds - Bond Fund, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. •        0.20% if you choose AllianceBernstein Balanced Wealth Strategy Portfolio or GE Investments Total Return Fund. •        0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund. •        0.10% if you choose Transamerica BlackRock Global Allocation VP.	•        0.30% if you choose American Funds - Asset Allocation Fund, American Funds - Bond Fund, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. •        0.20% if you choose AllianceBernstein Balanced Wealth Strategy Portfolio or GE Investments Total Return Fund. •        0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund. •        0.10% if you choose Transamerica BlackRock Global Allocation VP.
Premium Enhancement	Yes – 4%	Yes – 4% - 5.5%	Yes – Based on Attained Age
			Age 0-59 = 5.5%
			Age 60-69 = 5%
			Age 70-79 = 4%
			Age 80+ = 2%
Guaranteed Period Options (available in the fixed account) Annual Contract Charge (Service Charge)	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $50,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge of $40 (but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.	1, 3, 5, and 7 year guaranteed periods available. Annual service charge currently of $35 (can charge up to $40, but not more than 2% of the policy value) is charged on each policy anniversary and at surrender. The service charge is waived if your policy value or the sum of your premiums, less all partial surrenders, is at least $100,000.

120

Product Feature	ExtraSM 2002 (Revised) Form Number: – AV710 101 147 102 – RGMI 1 798	ExtraSM 2003 Form Number: – AV950 101 175 603	ExtraSM 2008 Form Number: – AV950 101 175 603
Optional Riders	•        5 for Life 2005 •        5 for Life with Growth •        5 for Life Growth with Death Benefit •        Living Benefit Rider 2003 •        Living Benefit Rider 2005 •        Tax Payer 2003 •        Taxpayer Plus 2	•        Living Benefit Rider 2003 •        Living Benefit Rider 2005 •        5 for Life 2005 •        Income Select for Life •        Retirement Income Choice® •        Retirement Income Choice® 2008 (with Double Withdrawal Base Benefit) •        Retirement Income Choice® 1.2 •        Retirement Income Choice® 1.4 •        Retirement Income MaxSM •        Taxpayer 2003 •        Taxpayer Plus 2	•        Living Benefit Rider 2005 •        Retirement Income Choice® •        Retirement Income Choice® 2008 (with Double Withdrawal Base Benefit) •        Retirement Income Choice® 1.2 •        Retirement Income Choice® 1.4 •        Income Link® •        Retirement Income MaxSM •        Taxpayer 2003 •        Taxpayer Plus 2
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing Option	Yes	Yes	Yes
Dollar Cost Averaging Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes	Yes	Yes
Unemployment Waiver	Yes	Yes	Yes

121

APPENDIX

EXCESS INTEREST ADJUSTMENT EXAMPLES

Money that you surrender from, transfer out of, or apply to an annuity payment option, from a guaranteed period option of the fixed account before the end of its guaranteed period (the number of years you specified the money would remain in the guaranteed period option) may be subject to an excess interest adjustment (“EIA”). At the time you request a surrender, if interest rates set by the Company have risen since the date of the initial guarantee, the excess interest adjustment will result in a lower cash value. However, if interest rates have fallen since the date of the initial guarantee, the excess interest adjustment will result in a higher cash value.

Excess interest adjustments will not reduce the adjusted policy value for a guaranteed period option below the premium payments and transfers to that guaranteed period option, less any prior partial surrenders and transfers from the guaranteed period option, plus interest at the policy’s minimum guaranteed effective annual interest rate. This is referred to as the excess interest adjustment floor.

The formula that will be used to determine the excess interest adjustment is:

S* (G-C)* (M/12)

S	=	Gross amount being surrendered that is subject to the excess interest adjustment
G	=	Guaranteed interest rate in effect for the policy
C	=	Current guaranteed interest rate then being offered on new premiums for the next longer option period than “M”. If this policy form or such an option period is no longer offered, “C” will be the U.S.Treasury rate for the next longer maturity (in whole years) than “M” on the 25th day of the previous calendar month, plus up to 2%.
M	=	Number of months remaining in the current option period, rounded up to the next higher whole number of months.
*	=	multiplication
^	=	exponentiation

The following examples are for illustrative purposes only and ore calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

122

Excess Interest Adjustment Examples — (Continued)

Example 1 (Full Surrender, rates increase by 3%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Surrender:	Middle of policy year 2
Cumulative Earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Amount subject to excess interest adjustment	= 54,181.21 – 4,181.21 = 50,000.00
Excess interest adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess interest adjustment
G = .055
C = .085
M = 42
Excess interest adjustment	= S* (G-C)* (M/12)
	= 50,000.00 * (.055-.085) * (42/12)
	= -5,250.00, but excess interest adjustment cannot cause the adjusted policy value to fall below the excess interest adjustment floor, so the adjustment is limited to 51,129.21 - 54,181.21 = -3,052.00
Adjusted policy value	= policy value + excess interest adjustment
	= 54,181.21 + (-3,052.00) = 51,129.21

Upon full surrender of the policy, the net surrender value (adjusted policy value less any surrender charge) will never be less than that required by the non-forfeiture laws of your state.

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

123

Excess Interest Adjustment Examples — (Continued)

Example 2 (Full Surrender, rates decrease by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Surrender:	Middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Amount subject to excess interest adjustment	= 54,181.21 – 4,181.21 = 50,000.00
Excess interest adjustment floor	= 50,000.00 * (1.015) ^ 1.5 = 51,129.21
Excess interest adjustment
G = .055
C = .045
M = 42
Excess interest adjustment	= S* (G-C)* (M/12)
	= 50,000.00 * (.055-.045) * (42/12) = 1,750.00
Adjusted policy value	= 54,181.21 + 1,750.00 = 55,931.21
Upon full surrender of the policy, the net surrender value will never by less than that required by the non-forfeiture laws of your state. For the purpose of these illustrations no surrender charges are assumed.

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

On a partial surrender, the Company will pay the policyholder the full amount of surrender requested (as long as the policy value is sufficient). Amounts surrendered will reduce the policy value by an amount equal to:

R - E + SC

R	=	the requested partial surrender;
E	=	the excess interest adjustment; and
SC	=	the surrender charges on (EPW - E); where
EPW	=	the excess partial withdrawal amount.

124

Excess Interest Adjustment Examples — (Continued)

Example 3 (Partial Surrender, rates increase by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Partial surrender:	$20,000 ; middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Excess interest adjustment
S = 20,000 – 4,181.21 = 15,818.79
G = .055
C = .065
M = 42
E = 15,818.79 * (.055 - .065) * (42/12) = -553.66	= 54,181.21 - (R - E + surrender charge)
Remaining policy value at middle of policy year 2	= 54,181.21 - (20,000.00 - (-553.66) + 0.00) = 33,627.55

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

Example 4 (Partial Surrender, rates decrease by 1%):

Single premium:	$50,000.00
Guarantee period:	5 Years
Guarantee rate:	5.50% per annum
Partial surrender:	$20,000; middle of policy year 2
Policy value at middle of policy year 2	= 50,000.00 * (1.055) ^ 1.5 = 54,181.21
Cumulative Earnings	= 54,181.21 – 50,000.00 = 4,181.21
Amount free of excess interest adjustment	= 4,181.21
Excess interest adjustment
S = 20,000 – 4,181.21 = 15,818.79
G = .055
C = .045
M = 42
E = 15,818.79 * (.055 - .045)* (42/12) = 553.66	= 54,181.21 - (R - E + surrender charge)
Remaining policy value at middle of policy year 2	= 54,181.21 - (20,000.00 – 553.66 + 0.00) = 34,734.87

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

125

APPENDIX

DEATH BENEFIT

Adjusted Partial Surrender. If you make a partial surrender (withdrawal), then your guaranteed minimum death benefit is reduced by an amount called the adjusted partial surrender. The amount of the reduction depends on the relationship between your death benefit and policy value. The adjusted partial surrender is equal to (1) multiplied by (2) divided by (3), where:

(1) is the amount of the gross partial surrender;

(2) is the value of the current death proceeds immediately prior to the gross partial surrender;

(3) is the policy value immediately prior to the gross partial surrender.

The following examples describe the effect of a surrender on the guaranteed minimum death benefit and policy value.

Example 1 (Assumed Facts for Example)

Current guaranteed minimum death benefit before surrender	$	75,000
Current policy value before surrender	$	50,000
Current death proceeds	$	75,000
Total Gross Partial Surrender	$	15,494
Adjusted partial surrender = 15,494 * 75,000 / 50,000	$	23,241
New guaranteed minimum death benefit (after surrender) = 75,000 – 23,241	$	51,759
New policy value (after surrender) = 50,000 - 15,494	$	34,506

Summary:
Reduction in guaranteed minimum death benefit	= $	23,241
Reduction in policy value	= $	15,494

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

** The guaranteed minimum death benefit is reduced more than the policy value because the guaranteed minimum death benefit was greater than the policy value just prior to the surrender.

126

Death Benefit — (Continued)

Example 2 (Assumed Facts for Example)

Current guaranteed minimum death benefit before surrender	$	50,000
Current policy value before surrender	$	75,000
Current death proceeds	$	75,000
Total Gross Partial Surrender	$	15,556
Adjusted partial surrender = 15,556 * 75,000 / 75,000	$	15,556
New guaranteed minimum death benefit (after surrender) = 50,000 - 15,556	$	34,444
New policy value (after surrender) = 75,000 - 15,556	$	59,444

Summary:
Reduction in guaranteed minimum death benefit	= $	15,556
Reduction in policy value	= $	15,556

* This example is for illustrative purposes only. The purpose of this illustration is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

** The guaranteed minimum death benefit and policy value are reduced by the same amount because the policy value was higher than the guaranteed minimum death benefit just prior to the surrender.

127

Death Benefit — (Continued)

Hypothetical Example

In this example, certain death benefit values at various points in time are depicted based on hypothetical assumed rates of performance. This example is for illustrative purposes only and assumes a single $100,000 premium payment by a sole owner and annuitant who is age 50. It further assumes no subsequent premium payments or withdrawals.

End of Year	Net Rate of Return for Fund*			Return of Premium		Annual Step-Up
Issue		N/A		$	100,000	$	100,000
1		-4	%	$	100,000	$	100,000
2		18	%	$	100,000	$	110,093
3		15	%	$	100,000	$	124,955
4		-7	%	$	100,000	$	124,955
5		2	%	$	100,000	$	124,955
6		10	%	$	100,000	$	124,955
7		14	%	$	100,000	$	140,257
8		-3	%	$	100,000	$	140,257
9		17	%	$	100,000	$	154,706
10		6	%	$	100,000	$	161,668

* The assumed rate does reflect the deduction of a hypothetical fund fee but does not reflect the deduction of any other fees, charges or taxes. The death benefit values do reflect the deduction of hypothetical base policy fees and hypothetical death benefit fees. Different hypothetical returns and fees would produce different results.

128

APPENDIX

ADDITIONAL DEATH DISTRIBUTION RIDER — ADDITIONAL INFORMATION

The following example illustrates the Additional Death Distribution additional death benefit payable by this rider as well as the effect of a partial surrender on the Additional Death Distribution benefit amount. The annuitant is less than age 71 on the Rider Date.

Example 1

Policy Value on the Rider Date:	$	100,000
Premiums paid after the Rider Date before Surrender:	$	25,000
Gross Partial Surrenders after the Rider Date:	$	30,000
Policy Value on date of Surrender:	$	150,000
Rider Earnings on Date of Surrender (Policy Value on date of surrender – Policy Value on Rider Date – Premiums paid after Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $150,000 – $100,000 – $25,000 + 0):	$	25,000
Amount of Surrender that exceeds Rider Earnings ($30,000 – $25,000):	$	5,000
Base Policy Death Benefit on the date of Death Benefit Calculation:	$	200,000
Policy Value on the date of Death Benefit Calculations:	$	175,000
Rider Earnings (= Policy Value on date of Death Benefit Calculations – policy value on Rider Date – Premiums since Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $175,000 – $100,000 – $25,000 + $5,000):	$	55,000
Additional Death Benefit Amount (= Additional Death Benefit Factor * Rider Earnings = 40%* $55,000):	$	22,000
Total Death Benefit paid (=Base policy death benefit plus Additional Death Benefit Amount):	$	222,000
Example 2
Policy Value on the Rider Date:	$	100,000
Premiums paid after the Rider Date before Surrender:	$	0
Gross Partial Surrenders after the Rider Date:	$	0
Base Policy Death Benefit on the date of Death Benefit Calculation:	$	100,000
Policy Value on the date of Death Benefit Calculations:	$	75,000
Rider Earnings (= Policy Value on date of death benefit calculations – policy value on Rider Date – Premiums since Rider Date + Surrenders since Rider Date that exceeded Rider Earnings = $75,000 – $100,000 – $0 + $0):	$	0
Additional Death Benefit Amount (= Additional Death Benefit Factor * Rider Earnings = 40%* $0):	$	0
Total Death Benefit paid (=Base policy death benefit plus Additional Death Benefit Amount):	$	100,000

129

APPENDIX

ADDITIONAL DEATH DISTRIBUTION+ RIDER - ADDITIONAL INFORMATION

Assume the Additional Death Distribution+ is added to a new policy opened with $100,000 initial premium. The annuitant is less than age 71 on the Rider Date. On the first and second Rider Anniversaries, the Policy Value is $110,000 and $95,000 respectively when the Rider Fees are deducted. The annuitant adds $25,000 premium in the 3rd Rider Year when the Policy Value is equal to $115,000 and then takes a withdrawal of $35,000 during the 4th Rider Year when the Policy Value is equal to $145,000. After 5 years, the Policy Value is equal to $130,000 and the death proceeds are equal to $145,000.

Example 1

Account Value on Rider Date (equals initial policy value since new policy)	$	100,000
Additional Death Benefit during first Rider Year	$	0
Rider Fee on first Rider Anniversary (= Rider Fee * Policy Value = 0.55% * $110,000)	$	605
Additional Death Benefit during 2nd Rider Year (= sum of total Rider Fees paid)	$	605
Rider Fee on second Rider Anniversary (= Rider Fee * Policy Value = 0.55% * $95,000)	$	522.50
Additional Death Benefit during 3rd Rider Year (= sum of total Rider Fees paid = $605 + $522.50)	$	1,127.50
Rider Benefit Base in 3rd Rider Year prior to Premium addition (= Account Value less premiums added since Rider Date = $115,000 – $0)	$	115,000
Rider Benefit Base in 3rd Rider Year after Premium addition (= $140,000 – $25,000)	$	115,000
Rider Benefit Base in 4th Rider Year prior to withdrawal (= Account Value less premiums added since Rider Date = $145,000 – $25,000)	$	120,000
Rider Benefit Base in 4th Rider Year after withdrawal = (Account Value less premiums added since Rider Date =$110,000 – $25,000)	$	85,000
Rider Benefit Base in 5th Rider Year (= $130,000 – $25,000)	$	105,000
Additional Death Benefit = Rider Benefit Percentage * Rider Benefit Base = 30% * $105,000	$	31,500
Total Death Proceeds in 5th Rider Year (= base policy Death Proceeds + Additional Death Benefit Amount = $145,000 + $31,500)	$	176,500

130

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT COMPARISON TABLE

Important aspects of the Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider are summararized in the following chart.

Note: The Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider and any additional options available under these riders, may vary for certain policies and may not be available for all policies; the Guaranteed Lifetime Withdrawal Benefit Riders may not be available in all states. You should consult with tax and financial professionals to determine which of these riders is appropriate for you.

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
Benefit:	Benefit:	Benefit:	Benefit:
•      Provides:	•      Provides	•      Provides:	•      Provides:
(1) Guaranteed Minimum Accumulation Benefit (“GMAB”)—Ten years after you elect the rider (“guaranteed future value date”), your policy value will equal your guaranteed future value (calculated as described below). After that date, the guaranteed future value equals zero.	(1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a level of cash withdrawals (and payments from us, if necessary) regardless of the performance of the Designated Investment Option or the Open Allocation Option that you select.	(1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a series of cash withdrawals (and payments from us, if necessary), which are based on a withdrawal percentage that is higher for a defined period and lower thereafter, regardless of the Designated Investment Option that you select.	(1) Guaranteed Lifetime Withdrawal Benefit (“GLWB”)—i.e., a level of cash withdrawals (and payments from us, if necessary) regardless of the performance of the designated investment choices that you select – if you invest in certain designated investment choices.
(2) Guaranteed Minimum Withdrawal Benefit (“GMWB”)—a maximum annual withdrawal amount (calculated as described below) regardless of your policy value; we account for withdrawals you take under the rider by applying two different withdrawal guarantees, “principal back,” for withdrawals of up to 7% of your total withdrawal base, or “for life,” for withdrawals up to 5% of your total withdrawal base.	(2) Growth—On each of the first 10 rider anniversaries, we add an annual growth credit (5% of the withdrawal base immediately before the rider anniversary) to the withdrawal base if no withdrawals have occurred during the preceding rider year. (3) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.	(2) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.	(2) Growth—On each of the first 10 rider anniversaries, we add an annual growth credit (5% of the withdrawal base immediately before the rider anniversary) to the withdrawal base if no withdrawals have occurred during the preceding rider year. (3) Automatic Step-Up—We will automatically step-up the withdrawal base on each rider anniversary. You can opt out of the automatic step-up if the automatic step-up would result in an increase in the rider fee percentage.

131

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
•      Upgrades:	•      Upgrades:
(1) Before the annuitant’s 86th birthday, you can upgrade the total withdrawal base (for GMWB) and the guaranteed future value (for GMAB) by sending us written notice. (2) If you upgrade, the current rider terminates and a new rider is issued (which may have a higher rider fee).	You may request by sending us written notice. If you upgrade, the current rider terminates and a new rider is issued (which may have a higher rider fee). If you have elected the joint life option under the rider, you cannot elect a manual upgrade if the annuitant or an annuitant’s spouse is 86 or older (unless state law requires a lower maximum age).

132

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
	•      Additional Options:	•      Additional Options:	•    Additional Options:
	(1) Death Benefit Option— You may add an amount to the death benefit payable under the base policy. (2) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner). (3) Income Enhancement Option—If the rider has been in effect for at least 12 months, then you may elect to have your withdrawal percentage double if either the annuitant or the annuitant’s spouse, if the joint life option is elected, is confined in a hospital or nursing facility because of a medical necessity, and has been so confined for an “elimination period” (i.e., 180 days within the last 365 days). You cannot elect this option if the qualifying person(s) is/are already confined in a hospital or nursing facility when the rider is elected. In addition, the increase to the withdrawal percentage stops when the qualifying person(s) is/are no longer confined.	(1) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner).	(1) Joint Life Option—You may elect to postpone termination of the rider until the later of the death of the annuitant or the death of the annuitant’s spouse. The annuitant’s spouse must be either a joint owner (along with the annuitant) or the sole primary beneficiary (without a joint owner).
Availability:	Availability:	Availability:	Availability:
•      0 - 80 (unless state law requires a lower maximum issue age	•      Younger than age 86 (unless state law requires a lower maximum issue age)	•      At least 55 years old and not yet age 81 (unless state law requires a lower maximum issue age)	•      Younger than age 86 (unless state law requires a lower maximum issue age)

133

Guaranteed Lifetime Withdrawal Benefit Comparison Table — (Continued)

Living Benefits Rider	Retirement Income Choice® 1.2 Rider	Income Link® Rider	Retirement Income MaxSM Rider
Charge:	Charges:	Charges:	Charges:
(1) 0.90% of total withdrawal base on each rider anniversary under the “principal back” withdrawal guarantee under the rider.	(1) for Base Benefit only—0.45% to 1.40% annually (single and joint life) of withdrawal base deducted on each rider quarter;	(1) 0.90% annually (single life and joint life) of withdrawal base deducted on each rider quarter.	(1) 1.00% annually (single life and joint life) of withdrawal base deducted on each rider quarter.
	(2) Open Investment Option – 1.20% annually (singlelife and joint life) of withdrawal base deducted on each rider quarter;
	(3) with Death Benefit Option— 0.25% (single life) or 0.20% (joint life) annually of withdrawal base deducted on each rider quarter, in addition to the base benefit fee;
	(4) with Income Enhancement Option—0.15% (single life) or 0.30% (joint life) annually of withdrawal base deducted on each rider quarter, in addition to the base benefit fee.
Investment Restrictions:	Investment Restrictions:	Investment Restrictions:	Investment Restrictions:
•      Portfolio Allocation Method (“PAM”)—We monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts between investment options that we designate and the variable investment choices that you select.	•      Designated Investment option—You must allocate 100% of your policy value to one or more investment options that we designate. •      Open Investment option (“OA”) – We monitor your policy value and, as we deem necessary to support the guarantees under the rider, may transfer amounts between investment options that we designate and the variable investment choices that you select.	•      Designated Investment option—You must allocate 100% of your policy value to one or more investment options that we designate.	•      You must allocate 100% of your policy value to one or more investment options that we designate.

134

APPENDIX

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS

The following examples show the effect of withdrawals on the benefits under the Living Benefits Rider.

GUARANTEED MINIMUM ACCUMULATION BENEFIT

Gross partial withdrawals will reduce the guaranteed future value by an amount equal to the greater of:

1) the gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the amount of gross partial withdrawal;

B is the policy value immediately prior to the gross partial withdrawal; and

C is the guaranteed future value immediately prior to the gross partial withdrawal.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under the guaranteed minimum accumulation benefit.

EXAMPLE 1:

Assumptions:

Policy value prior to withdrawal (“PV”) = $90,000

Guaranteed future value prior to withdrawal (“GFV”) = $100,000

Gross withdrawal amount (“WD”) = $10,000

Step One. What is the pro rata value of the amount withdrawn?

1. Formula is (WD / PV) * GFV = pro rata amount

2. ($10,000 / $90,000) * $100,000 = $11,111.11

Step Two. Which is larger, the $10,000 withdrawal or the $11,111.11 pro rata amount?

$11,111.11 pro rata amount

Step Three. After the withdrawal is taken, what will be new guaranteed future value?

$100,000 - $11,111.11 = $88,888.89

Result. If no more withdrawals are taken, the guaranteed future value on the 10th rider anniversary is $88,888.89.

135

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

EXAMPLE 2:

Assumptions:

PV = $120,000

GFV= $100,000

WD= $10,000

Step One. What is the pro rata value of the amount withdrawn?

1. Formula is (WD / PV) * GFV = pro rata amount

2. ($10,000 / $120,000) * $100,000 = $8,333.33

Step Two. Which is larger, the $10,000 withdrawal or the $8,333.33 pro rata amount?

$10,000 withdrawal

Step Three. After the withdrawal is taken, what will be new guaranteed future value?

$100,000 - $10,000 = $90,000

Result. If no more withdrawals are taken, the guaranteed future value on the 10th Rider Anniversary is $90,000.

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

Total Withdrawal Base. Gross partial withdrawals up to the maximum annual withdrawal amount will not reduce the total withdrawal base. Gross partial withdrawals in excess of the maximum annual withdrawal amount will reduce the total withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the total withdrawal base prior to the withdrawal of the excess amount.

Minimum Remaining Withdrawal Amount. Gross partial withdrawals up to the maximum annual withdrawal amount will reduce the minimum remaining withdrawal amount by the same amount (dollar-for-dollar). Gross partial withdrawals in excess of the maximum annual withdrawal amount will reduce the minimum remaining withdrawal amount by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

136

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the minimum remaining withdrawal amount after the maximum annual withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under the guaranteed lifetime withdrawal benefit.

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Minimum remaining withdrawal amount (“MRWA”)

2. Total withdrawal base (“TWB”)

3. Maximum annual withdrawal amount (“MAWA”)

EXAMPLE 1 (7% “PRINCIPAL BACK”):

Assumptions:

TWB = $100,000

MRWA = $100,000

7% WD would be $7,000 (7% of the current $100,000 total withdrawal base)

WD = $7,000

Excess withdrawal (“EWD”) = None

PV = $100,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the withdrawal greater than the “principal back” maximum annual withdrawal amount?

No. There is no excess withdrawal under the “principal back” guarantee if no more than $7,000 is withdrawn.

Step Two. What is the minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $7,000 (there is no excess to deduct)

2. $100,000 – $7,000 = $93,000.

Result. In this example, because no portion of the withdrawal was in excess of $7,000, the “principal back” total withdrawal base does not change and the “principal back” minimum remaining withdrawal amount is $93,000.00.

EXAMPLE 2 (7% “PRINCIPAL BACK”):

Assumptions:

TWB = $100,000

137

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

MRWA = $100,000

7% WD would be $7,000 (7% of the current $100,000 total withdrawal base)

WD = $8,000

EWD = $1,000 ($8,000 - $7,000)

PV = $90,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the total withdrawal greater than the maximum annual withdrawal amount?

Yes. $8,000 - $7,000 = $1,000 (the excess withdrawal amount)

Step Two. Calculate how much of the “principal back” minimum remaining withdrawal amount is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 7% WD)) * (MRWA - 7% WD)

2. ($1,000 / ($90,000 - $7,000)) * ($100,000 - $7,000) = $1,120.48

Step Three. Which is larger, the actual $1,000 excess withdrawal amount or the $1,120.48 pro rata amount?

$1,120.48 pro rata amount

Step Four. What is the “principal back” minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $7,000 + $1,120.48 (pro rata excess) = $8,120.48

2. $100,000 - $8,120.48 = $91,879.52

Result. The “principal back” minimum remaining withdrawal amount is $91,879.52.

NOTE. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the total withdrawal base needs to be adjusted as well as a new lower maximum annual withdrawal amount. Had the withdrawal for this example not been more than $7,000, the “principal back” total withdrawal base would remain at $100,000 and the “principal back” maximum annual withdrawal amount would be $7,000. However, because an excess withdrawal has been taken, the total withdrawal base is also changed (this is the amount the 7% is based on).

New “principal back” total withdrawal base:

Step One. The total withdrawal base is only reduced by the excess withdrawal amount or the pro rata amount if greater.

Step Two. Calculate how much the total withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 7% WD)) * TWB before any adjustments

2. ($1,000 / ($90,000 - $7,000)) * $100,000 = $1,204.82

138

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

Step Three. Which is larger, the actual $1,000 excess withdrawal amount or the $1,204.82 pro rata amount?

$1,204.82 pro rata amount.

Step Four. What is the new total withdrawal base upon which the maximum annual withdrawal amount is based?

$100,000 - $1,204.82 = $98,795.18

Result. The new “principal back” total withdrawal base is $98,795.18

New “principal back” maximum annual withdrawal amount:

Because the “principal back” total withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new maximum annual withdrawal amount for the 7% “principal back” guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new “principal back” maximum annual withdrawal amount?

$98,795.18 (the adjusted total withdrawal base) * 7% = $6,915.66

Result. Going forward, the maximum you can take out in a rider year is $6,915.66 without causing an excess withdrawal for the “principal back” guarantee and further reduction of the “principal back” total withdrawal base.

EXAMPLE 3 (5% “FOR LIFE”):

Assumptions:

TWB = $100,000

MRWA = $100,000

5% WD would be $5,000 (5% of the current $100,000 total withdrawal base)

WD = $5,000

Excess withdrawal (“EWD”) = None

PV = $100,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the withdrawal greater than the “for life” maximum annual withdrawal amount?

No. There is no excess withdrawal under the “for life” guarantee if no more than $5,000 is withdrawn.

Step Two. What is the minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $5,000 (there is no excess to deduct).

2. $100,000 - $5,000 = $95,000.

Result. In this example, because no portion of the withdrawal was in excess of $5,000, the “for life” total withdrawal base does not change and the “for life” minimum remaining withdrawal amount is $95,000.00.

139

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

EXAMPLE 4 (5% “FOR LIFE”):

Assumptions:

TWB = $100,000

MRWA = $100,000

5% WD would be $5,000 (5% of the current $100,000 total withdrawal base)

WD = $7,000

EWD = $2,000 ($7,000 - $5,000)

PV = $90,000

You = Owner and Annuitant (Age 60)

Step One. Is any portion of the total withdrawal greater than the maximum annual withdrawal amount?

Yes. $7,000 - $5,000 = $2,000 (the excess withdrawal amount)

Step Two. Calculate how much of the “for life” minimum remaining withdrawal amount is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 5% WD)) * (MRWA - 5% WD)

2. ($2,000 / ($90,000 - $5,000)) * ($100,000 - $5,000) = $2,235.29

Step Three. Which is larger, the actual $2,000 excess withdrawal amount or the $2,235.29 pro rata amount?

$2,235.29 pro rata amount

Step Four. What is the “for life” minimum remaining withdrawal amount after the withdrawal has been taken?

1. Total to deduct from the minimum remaining withdrawal amount is $5,000 + $2,235.29 (pro rata excess) = $7,235.29

2. $100,000 - $7,235.29 = $92,764.71

Result. The “for life” minimum remaining withdrawal amount is $92,764.71.

NOTE. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the total withdrawal base needs to be adjusted as well as a new lower maximum annual withdrawal amount. Had the withdrawal for this example not been more than $5,000, the “for life” total withdrawal base would remain at $100,000 and the “for life” maximum annual withdrawal amount would be $5,000. However, because an excess withdrawal has been taken, the total withdrawal base is also changed (this is the amount the 5% is based on).

New “for life” total withdrawal base:

Step One. The total withdrawal base is only reduced by the excess withdrawal amount or the pro rata amount if greater.

140

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

Step Two. Calculate how much the total withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV – 5% WD)) * TWB before any adjustments

2. ($2,000 / ($90,000 – $5,000)) * $100,000 = $2,352.94

Step Three. Which is larger, the actual $2,000 excess withdrawal amount or the $2,352.94 pro rata amount?

$2,352.94 pro rata amount.

Step Four. What is the new total withdrawal base upon which the maximum annual withdrawal amount is based?

$100,000 - $2,352.94 = $97,647.06

Result. The new “for life” total withdrawal base is $97,647.06

New “for life” maximum annual withdrawal amount:

Because the “for life” total withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new maximum annual withdrawal amount for the 5% “for life” guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new “for life” maximum annual withdrawal amount?

$97,647.06 (the adjusted total withdrawal base) * 5% = $4,882.35

Result. Going forward, the maximum you can take out in a rider year is $4,882.35 without causing an excess withdrawal for the “for life” guarantee and further reduction of the “for life” total withdrawal base.

141

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME CHOICE^® 1.2 RIDER

AND RETIREMENT INCOME CHOICE^® 1.4 RIDER (RETIREMENT INCOME

CHOICE^® 1.4 - NO LONGER AVAILABLE FOR NEW SALES)

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

3. Rider Death Benefit (“RDB”)

Withdrawal Base. Gross partial withdrawals in a rider year up to the rider withdrawal amount will not reduce the withdrawal base. Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the withdrawal base prior to the withdrawal of the excess amount.

Rider Death Benefit. Gross partial withdrawals in a rider year up to the rider withdrawal amount will reduce the rider death benefit by the amount withdrawn (dollar-for-dollar). Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the rider death benefit by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the guaranteed annual withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the rider death benefit after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Example 1 (Base):

Assumptions:

Withdrawal Base (“WB”) = $100,000

142

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Rider Withdrawal Amount (“RWA”) = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

Gross partial withdrawal (“GPWD”) = $5,000

Excess withdrawal (“EWD”) = None

Policy Value (“PV”) = $100,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee since no more than $5,000 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $5,000, the withdrawal base does not change.

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

RWA = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

GPWD = $7,000

EWD = $2,000 ($7,000 - $5,000)

PV = $90,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5%.

Result. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $5,000, the withdrawal base would remain at $100,000 and the rider withdrawal amount would be $5,000 starting on the next rider anniversary. However, because an excess withdrawal has been taken, the withdrawal base is also reduced (this is the amount the 5% is based on).

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 5% withdrawal)) * WB before any adjustments

2. ($2,000 / ($90,000 - $5,000)) * $100,000 = $2,353

Step Three. Which is larger, the actual $2,000 excess withdrawal or the $2,353 pro rata amount? $2,353 pro rata amount.

143

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $2,353 = $97,647

Result. The new withdrawal base is $97,647

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5% guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Question: What is the new rider withdrawal amount?

$97,647 (the adjusted withdrawal base) * 5% = $4,882

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $4,882.

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 8 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 8 = $147,745

RWA = 5% withdrawal beginning 8 years from the rider date would be $7,387 (5% of the then-current $147,745 withdrawal base)

GPWD = $7,387

EWD = None

PV = $90,000 in 8 years

You (if you elected RIC 1.2 or RIC 1.4 ) = owner and annuitant, age 68 on rider issue; age 76 at time withdrawals begin, which means Withdrawal Percentage is 5%

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $7,387 is withdrawn in a rider year.

Result. In this example, because no portion of the withdrawal was in excess of $7,387, the withdrawal base does not change.

144

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Example 4 (Base demonstrating WB growth with Additional Death Payment Option):

Assumptions:

You (if you elected RIC 1.2 or RIC 1.4 ) = owner and annuitant, age 68 on rider issue; age 76 at time withdrawals begin, which means Withdrawal Percentage is 5%

WB at rider issue = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 8 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 8 = $147,745

Rider Death Benefit (“RDB”) (optional additional death benefit for additional cost) = $100,000

RWA = 5% withdrawal beginning 8 years from the rider date would be $7,387 (5% of the then-current $147,745 withdrawal base)

GPWD = $7,387

EWD = None

PV = $90,000 in 8 years

Step One. Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $7,387 is withdrawn.

Step Two. What is the rider death benefit after the withdrawal has been taken?

1. Total to deduct from the rider death benefit is $7,387 (there is no excess to deduct)

2. $100,000 - $7,387 = $92,613.

Result. In this example, because no portion of the withdrawal was in excess of $7,387, the total withdrawal base does not change and the rider death benefit reduces to $92,613.

Example 5 (Base with WB growth with Additional Death Payment Option illustrating excess withdrawal):

Assumptions:

You = owner and annuitant, age 61 on rider issue; age 74 at time withdrawals begin, which means withdrawal percentage is 5%.

WB at rider issue = $100,000

Automatic step-up never occurs and no withdrawals are taken in the first 10 rider years.

WB in 10 years (assuming an annual growth rate percentage of 5.0%) = the greater of $100,000 * (1 + .05) ^ 10 = $162,889.

RDB (optional additional death benefit for additional cost) = $100,000

RWA = 5% withdrawal beginning 10 years from the rider date would be $8,144 (5% of the then-current $162,889 withdrawal base)

GPWD = $15,000

EWD = $6,856 ($15,000 - $8,144)

PV = $90,000 in 10 years

145

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step One. Is any portion of the total withdrawal greater than the rider withdrawal amount?

Yes. $15,000 - $8,144 = $6,856 (the excess withdrawal amount)

Step Two. Calculate how much of the rider death benefit is affected by the excess withdrawal.

1. Formula for pro rata amount is: (EWD / (PV - 5% withdrawal)) * (RDB - 5% withdrawal)

2. ($6,856 / ($90,000 - $8,144)) * ($100,000 - $8,144) = $7,694

Step Three. Which is larger, the actual $6,856 excess withdrawal amount or the $7,694 pro rata amount?

$7,694 pro rata amount.

Step Four. What is the rider death benefit after the withdrawal has been taken?

1. Total to deduct from the rider death benefit is $8,144 (RWA) + $7,694 (pro rata excess) = $15,838

2. $100,000 - $15,838 = $84,162.

Result. The rider benefit is $84,162.

Note: Because there was an excess withdrawal amount in this example, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $8,144, the withdrawal base would remain at $162,889 and the rider withdrawal amount would be $8,144. However, because an excess withdrawal has been taken, the withdrawal base is also reduced.

New benefit base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD/(PV - 5% withdrawal)) * WB before any adjustments

2. ($6,856 / ($90,000 - $8,144)) * $162,889 = $13,643

Step Three. Which is larger, the actual $6,856 excess withdrawal amount or the $13,643 pro rata amount?

$13,643 pro rata amount.

Step Four. What is the new withdrawalt base upon which the rider withdrawal amount is based?

$162,889 - $13,643 = $149,246

Result. The new benefit base is $149,246

146

Guaranteed Lifetime Withdrawal Benefit — (Continued)

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5% benefit percentage guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Step One. What is the new rider withdrawal amount?

$149,246 (the adjusted withdrawal base) * 5% = $7,462

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the benefit base is $7,462.

147

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS – INCOME LINK^® RIDER

When a withdrawal is taken, three parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

3. Income Link^® Rider Systematic Withdrawals (“ILSW”)

Withdrawal Base. Income Link^® rider systematic withdrawals (and certain minimum required distributions) will not reduce the withdrawal base. Non-Income Link^® rider systematic withdrawals (and minimum required distributions calculated other than as provided for in the rider or not taken via a systematic withdrawal program) will reduce the withdrawal base by an amount equal to the greater of:

1) the amount of the non-Income Link^® rider systematic withdrawal (or non-qualifying minimum required distribution); and

2) a pro rata amount, the result of (A / B) * C, where:

A is the amount in 1 above;

B is the policy value prior to the withdrawal; and

C is the withdrawal base prior to the withdrawal.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Assumptions:

WB = $100,000

RWA = 6% withdrawal would be $6,000 (6% of the current $100,000 withdrawal base)

ILSW = $500 per month

Non-ILSW = $10,000 (taken after the eighteenth monthly Income Link^® rider systematic withdrawal)

PV = $90,000

Assumes single life withdrawal option of 6% for 6 years and 4% thereafter has been elected. Non-Income Link^® rider systematic withdrawal occurs during the second Income Link^® rider withdrawal year (which means the withdrawal percentage is 6%).

Result. For the guaranteed lifetime withdrawal benefit, because there was a non-Income Link^® rider systematic withdrawal, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount and Income Link^® rider systematic withdrawal amount calculated.

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the amount of the non-Income Link^® rider systematic withdrawal or the pro rata amount, if greater.

148

Guaranteed Lifetime Withdrawal Benefit — (Continued)

Step Two. Calculate how much the withdrawal base is affected by the non-Income Link^® rider systematic withdrawal.

1. The formula is (Non-ILSW / (PV before withdrawal)) * WB before any adjustments

2. ($10,000 / ($90,000)) * $100,000 = $11,111

Step Three. Which is larger, the actual $10,000 non-Income Link^® rider systematic withdrawal or the $11,111 pro rata amount?

$11,111 pro rata amount.

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $11,111 = $88,889

Result. The new withdrawal base is $88,889. Please note the percentage reduction in the withdrawal base is used in calculating the revised RWA and ILSW.

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the non-Income Link^® rider systematic withdrawal) we have to calculate a new (remaining) rider withdrawal amount. This calculation assumes no more non-Income Link^® rider systematic withdrawal activity prior to the next Income Link^® rider withdrawal year.

Question: What is the new (remaining) rider withdrawal amount for the remainder of the Income Link^® rider withdrawal year?

$3,000 (the remaining rider withdrawal amount) – ($3000*11.11%) = $2,667

Result. Going forward, the maximum you can take out in a benefit year without causing a negative withdrawal base adjustment and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $5,333.

New Income Link^® rider systematic withdrawal amount:

Because the withdrawal base was adjusted (due to the non-Income Link^® rider systematic withdrawal) we have to calculate a new Income Link^® rider systematic withdrawal amount. This calculation assumes no more non-Income Link^® rider systematic withdrawal activity prior to the next Income Link^® rider withdrawal year.

Question: What is the new Income Link^® rider systematic withdrawal amount?

$500 (the old Income Link^® rider systematic withdrawal amount) – ($500*11.11%) = $444

Result. Going forward (until the seventh Income Link^® rider withdrawal year), the Income Link^® rider systematic withdrawal amount (assuming there are no future automatic step-ups) is $444

149

APPENDIX

GUARANTEED LIFETIME WITHDRAWAL BENEFIT

ADJUSTED PARTIAL SURRENDERS - RETIREMENT INCOME MAX^SM RIDER

When a withdrawal is taken, the following parts of the guaranteed lifetime withdrawal benefit can be affected:

1. Withdrawal Base (“WB”)

2. Rider Withdrawal Amount (“RWA”)

Withdrawal Base. Gross partial withdrawals in a rider year up to the rider withdrawal amount will not reduce the withdrawal base. Gross partial withdrawals in a rider year in excess of the rider withdrawal amount will reduce the withdrawal base by an amount equal to the greater of:

1) the excess gross partial withdrawal amount; and

2) a pro rata amount, the result of (A / B) * C, where:

A is the excess gross partial withdrawal (the amount in excess of the rider withdrawal amount remaining prior to the withdrawal);

B is the policy value after the rider withdrawal amount has been withdrawn, but prior to the withdrawal of the excess amount; and

C is the withdrawal base prior to the withdrawal of the excess amount.

The following demonstrates, on a purely hypothetical basis, the effects of partial withdrawals under this guaranteed lifetime withdrawal benefit.

Example 1 (Base):

Assumptions:

Withdrawal Base (“WB”) = $100,000

Rider Withdrawal Amount (“RWA”) = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base)

Gross partial withdrawal (“GPWD”) = $5,500

Excess withdrawal (“EWD”) = None

Policy Value (“PV”) = $100,000 (PV after GPWD = $94,500)

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee since no more than $5,500 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $5,500, the withdrawal base does not change.

150

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

RWA = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base)

GPWD = $7,000

EWD = $1,500 ($7,000 - $5,500)

PV = $90,000

You = owner and annuitant, age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Result. For the guaranteed lifetime withdrawal benefit, because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount calculated. Had the withdrawal for this example not been more than $5,500, the withdrawal base would remain at $100,000 and the rider withdrawal amount would be $5,500 starting on the next rider anniversary. However, because an excess withdrawal has been taken, the withdrawal base is also reduced (this is the amount the 5.5% is based on).

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the excess withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the withdrawal base is affected by the excess withdrawal.

1. The formula is (EWD / (PV - 5.5% withdrawal)) * WB before any adjustments

2. ($1,500 / ($90,000 - $5,500)) * $100,000 = $1,775

Step Three. Which is larger, the actual $1,500 excess withdrawal or the $1,775 pro rata amount?

$1,775 pro rata amount.

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $1,775 = $98,225

Result. The new withdrawal base is $98,225

New rider withdrawal amount:

Because the withdrawal base was adjusted (due to the excess withdrawal) we have to calculate a new rider withdrawal amount for the 5.5% guarantee that will be available starting on the next rider anniversary. This calculation assumes no more activity prior to the next rider anniversary.

Question: What is the new rider withdrawal amount?

$98,225 (the adjusted withdrawal base) * 5.5% = $5,402.38

Result. Going forward, the maximum you can take out in a year without causing an excess withdrawal and further reduction of the withdrawal base (assuming there are no future automatic step-ups) is $5,402.38.

151

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Automatic step-up never occurs and no withdrawals are taken.

WB in 8 years (assuming an annual growth rate percentage of 5%) = $100,000 * (1 + .05) ^ 8 = $147,746

RWA = 5.5% withdrawal beginning 8 years from the rider date would be $8,126 (5.5% of the then-current $147,746 withdrawal base)

GPWD = $8,126

EWD = None

PV = $90,000 in 8 years

You = owner and annuitant, age 63 on rider issue; age 71 at time withdrawals begin, which means Withdrawal Percentage is 5.5%.

Question: Is any portion of the withdrawal greater than the rider withdrawal amount?

No. There is no excess withdrawal under the guarantee if no more than $8,126 is withdrawn in a rider year.

Result. In this example, because no portion of the withdrawal was in excess of $8,126, the withdrawal base does not change.

Example 4 (Minimum Required Distribution “MRD”):

WB= $100,000

Automatic Step-up and growth never occur.

RWA for rider year beginning July 1, 2010 = 5.5% withdrawal would be $5,500 (5.5% of the current $100,000 withdrawal base.

MRD for 2010 = $6,000 (calculated as set forth in the rider)

MRD for 2011 = $6,500 (calculated as set forth in the rider)

GPWD on February 1, 2011 = $6,500

EWD = $500

Question: Is any portion of the withdrawal greater than the rider withdrawal amount or the minimum required withdrawal calculated pursuant to the terms of the rider?

Yes. Because more than $6,000 (the greater of the RWA ($5,500) or MRD for the tax year on that rider anniversary ($6,000) was withdrawn, there is an excess withdrawal of $500 (6,500 – 6,000 = 500). Please note, even though the withdrawal occurred in 2011, the MRD for 2011 does not become part of the RWA calculation until July 1, 2011 (the rider anniversary during that tax year).

Result: Because there was an excess withdrawal amount, the withdrawal base needs to be adjusted and a new lower withdrawal amount calculated. See Example 2 (Excess Withdrawal) for an example ofhow the new withdrawal base and new rider withdrawal amount are calculated.

152

APPENDIX

HYPOTHETICAL EXAMPLE OF THE WITHDRAWAL BASE CALCULATION -

RETIREMENT INCOME MAX^SM RIDER

The following table demonstrates, on a purely hypothetical basis, the withdrawal base calculation for the Retirement Income Max^SM rider using an initial premium payment of $100,000 for a Single Life Option rider at an issue age of 80. All values shown are post transaction values.

Rider Year	Hypothetical Policy Value		Subsequent Premium Payment		Withdrawal		Excess WB Adjustment		Growth Amount		High Monthiversary Value		Withdrawal Base			Rider Withdrawal Amount
	$	100,000	$		$		$		$		$	100,000	$	100,000		$	6,500
1	$	102,000	$		$		$		$		$	102,000	$	100,000		$	6,500
1	$	105,060	$		$		$		$		$	105,060	$	100,000		$	6,500
1	$	107,161	$		$		$		$		$	107,161	$	100,000		$	6,500
1	$	110,376	$		$		$		$		$	110,376	$	100,000		$	6,500
1	$	112,584	$		$		$		$		$	112,584	$	100,000		$	6,500
1	$	115,961	$		$		$		$		$	115,961	$	100,000		$	6,500
1	$	118,280	$		$		$		$		$	118,280	$	100,000		$	6,500
1	$	121,829	$		$		$		$		$	121,829	$	100,000		$	6,500
1	$	124,265	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	120,537	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	115,716	$		$		$		$		$	124,265	$	100,000		$	6,500
1	$	109,930	$		$		$		$	105,000	$	124,265	$	124,265	1	$	8,077
2	$	112,129	$		$		$		$		$	112,129	$	124,265		$	8,077
2	$	115,492	$		$		$		$		$	115,492	$	124,265		$	8,077
2	$	117,802	$		$		$		$		$	117,802	$	124,265		$	8,077
2	$	121,336	$		$		$		$		$	121,336	$	124,265		$	8,077
2	$	124,976	$		$		$		$		$	124,976	$	124,265		$	8,077
2	$	177,476	$	50,000	$		$		$		$	177,476	$	174,265		$	11,327
2	$	175,701	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	172,187	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	167,022	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	163,681	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	166,955	$		$		$		$		$	177,476	$	174,265		$	11,327
2	$	170,294	$		$		$		$	182,979	$	177,476	$	182,979	2	$	11,894
3	$	166,888	$		$		$		$		$	166,888	$	182,979		$	11,894
3	$	171,895	$		$		$		$		$	171,895	$	182,979		$	11,894
3	$	173,614	$		$		$		$		$	173,614	$	182,979		$	11,894
3	$	178,822	$		$		$		$		$	178,822	$	182,979		$	11,894
3	$	175,246	$		$		$		$		$	178,822	$	182,979		$	11,894
3	$	151,741	$		$	20,000	$	9,279	$		$		$	173,699		$
3	$	154,775	$		$		$		$		$		$	173,699		$
3	$	159,419	$		$		$		$		$		$	173,699		$

153

Rider Year	Hypothetical Policy Value		Subsequent Premium Payment	Withdrawal	Excess WB Adjustment	Growth Amount	High Monthiversary Value	Withdrawal Base			Rider Withdrawal Amount
3	$	161,013	$	$	$	$	$	$	173,699		$
3	$	165,843	$	$	$	$	$	$	173,699		$
3	$	174,135	$	$	$	$	$	$	173,699		$
3	$	181,101	$	$	$	$	$	$	181,101	1	$	11,772

⁽¹⁾  Automatic Step Up Applied

⁽²⁾  Growth Applied

154

MEMBERS^® EXTRA^SM VARIABLE ANNUITY

Issued by

TRANSAMERICA LIFE INSURANCE COMPANY

Supplement Dated May 1, 2011

to the

Prospectus dated May 1, 2011

We will not accept any premium payment that is allocated to the fixed account or the dollar cost averaging fixed account in excess of $5,000. We also will not accept any premium payment or transfer which would result in the aggregate policy value in the fixed account and the dollar cost averaging fixed account exceeding $5,000.

This Prospectus Supplement must be accompanied or preceded

by the Prospectus for the

Members^® Extra^SM Variable Annuity dated May 1, 2011

STATEMENT OF ADDITIONAL INFORMATION

MEMBERS^® EXTRA^SM VARIABLE ANNUITY

Issued through

SEPARATE ACCOUNT VA C

Offered by

TRANSAMERICA LIFE INSURANCE COMPANY

This Statement of Additional Information expands upon subjects discussed in the current prospectus for the MEMBERS^® Extra^SM Variable Annuity offered by Transamerica Life Insurance Company. You may obtain a copy of the current prospectus, dated May 1, 2011, by calling (800) 525-6205, or write us at: Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001. The prospectus sets forth information that a prospective investor should know before investing in a policy. Terms used in the current prospectus for the policy are incorporated in this Statement of Additional Information.

This Statement of Additional Information (SAI) is not a prospectus and should be read only in conjunction with the prospectuses for the policy and the underlying fund portfolios.

Dated: May 1, 2011

TABLE OF CONTENTS

GLOSSARY OF TERMS	3
THE POLICY — GENERAL PROVISIONS	6
Owner	6
Entire Policy	6
Misstatement of Age or Sex	7
Reallocation of Annuity Units After the Annuity Commencement Date	7
Annuity Payment Options	7
Death Benefit	8
Death of Owner	9
Assignment	9
Evidence of Survival	9
Non-Participating	9
Amendments	9
Employee and Agent Purchases	10
Present Value of Future Variable Payments	10
Stabilized Payments	10
CERTAIN FEDERAL INCOME TAX CONSEQUENCES	11
Tax Status of the Policy	11
Taxation of Annuities	12
Taxation of the Company	15
INVESTMENT EXPERIENCE	15
Accumulation Units	15
Annuity Unit Value and Annuity Payment Rates	17
HISTORICAL PERFORMANCE DATA	19
Money Market Yields	19
Total Returns	21
Other Performance Data	21
Adjusted Historical Performance Data	22
PUBLISHED RATINGS	22
STATE REGULATION OF TRANSAMERICA LIFE INSURANCE COMPANY	22
ADMINISTRATION	22
RECORDS AND REPORTS	22
DISTRIBUTION OF THE POLICIES	23
VOTING RIGHTS	23
OTHER PRODUCTS	24
CUSTODY OF ASSETS	24
LEGAL MATTERS	24
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM	25
OTHER INFORMATION	25
FINANCIAL STATEMENTS	25
APPENDIX
OA METHOD TRANSFERS	26
APPENDIX
PAM METHOD TRANSFERS	31

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GLOSSARY OF TERMS

Accumulation Unit — An accounting unit of measure used in calculating the policy value in the separate account before the annuity commencement date.

Adjusted Policy Value — The policy value increased or decreased by any excess interest adjustment.

Administrative and Service Office — Transamerica Life Insurance Company, Attention: Customer Care Group, 4333 Edgewood Road NE, Cedar Rapids, IA 52499-0001, (800) 525-6205.

Annuitant — The person on whose life any annuity payments involving life contingencies will be based.

Annuity Commencement Date — The date upon which annuity payments are to commence. This date may be any date after the policy date and may not be later than the last day of the policy month following the month after the annuitant attains age 95. The earliest annuity commencement date is at least thirty days after you purchase your policy. The annuity commencement date may have to be earlier for qualified policies and may be earlier if required by state law.

Annuity Payment Option — A method of receiving a stream of annuity payments selected by the owner.

Annuity Unit — An accounting unit of measure used in the calculation of the amount of the second and each subsequent variable annuity payment.

Assumed Investment Return or AIR — The annual effective rate shown in the contract specifications section of the contract that is used in the calculation of each variable annuity payment.

Beneficiary — The person who has the right to the death benefit as set forth in the policy.

Business Day — A day when the New York Stock Exchange is open for regular trading.

Cash Value — The adjusted policy value less any applicable surrender charge and rider fees (imposed upon surrender).

Code — The Internal Revenue Code of 1986, as amended.

Enrollment form — A written application, order form, or any other information received electronically or otherwise upon which the policy is issued and/or is reflected on the data or specifications page.

Excess Interest Adjustment — A positive or negative adjustment to amounts surrendered (both partial or full surrenders and transfers) or applied to annuity payment options from the fixed account guaranteed period options prior to the end of the guaranteed period. The adjustment reflects changes in the interest rates declared by the Company since the date any payment was received by, or an amount was transferred to, the guaranteed period option. The excess interest adjustment can either decrease or increase the amount to be received by the owner upon full surrender or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively.

Excess Partial Surrender — The portion of a partial surrender (surrender) that exceeds the free amount.

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Fixed Account — One or more investment choices under the policy that are part of the Company’s general assets and are not in the separate account.

Free Amount — The amount that can be withdrawn each year without incurring any surrender charge or excess interest adjustment.

Guaranteed Lifetime Withdrawal Benefit — Any optional benefit under the policy that provides a guaranteed minimum withdrawal benefit, including Living Benefits Rider, the Retirement Income Choice^® 1.2 Rider, the Income Link^® Rider or the Retirement Income Max^SM Rider

Guaranteed Period Options — The various guaranteed interest rate periods of the fixed account which the Company may offer and into which premium payments may be paid or amounts transferred.

Nonqualified Policy — A policy other than a qualified policy.

Owner (You, Your) — The person who may exercise all rights and privileges under the policy. The owner during the lifetime of the annuitant and prior to the annuity commencement date is the person designated as the owner in the information provided to us to issue a policy.

Policy Date — The date shown on the policy data page attached to the policy and the date on which the policy becomes effective.

Policy Value — On or before the annuity commencement date, the policy value is equal to the owner’s:

• premium payments; minus

• gross partial surrenders (partial surrenders minus excess interest adjustments plus the surrender charge on the portion of the requested partial surrender that is subject to the surrender charge); plus

• interest credited in the fixed account; plus

• accumulated gains in the separate account; minus

• accumulated losses in the separate account; minus

• service charges, rider fees, premium taxes, transfer fees, and other charges, if any.

Policy Year — A policy year begins on the policy date and on each anniversary thereof.

Premium Payment — An amount paid to the Company by the owner or on the owner’s behalf as consideration for the benefits provided by the policy.

Qualified Policy — A policy issued in connection with retirement plans that qualify for special federal income tax treatment under the Code.

Separate Account — Separate Account VA C, a separate account established and registered as a unit investment trust under the Investment Company Act of 1940, as amended (the “1940 Act”), to which premium payments under the policies may be allocated.

Separate Account Value — The portion of the policy value that is invested in the separate account.

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Service Charge — An annual charge on each policy anniversary (and a charge at the time of surrender during any policy year) for policy maintenance and related administrative expenses. This annual charge is $35, but will not exceed 2% of the policy value.

Subaccount — A subdivision within the separate account, the assets of which are invested in a specified underlying fund portfolios.

Supportable Payment — The amount equal to the sum of the variable annuity unit values multiplied by the number of variable annuity units in each of the selected subaccounts.

Surrender Charge — A percentage of each premium payment that depends upon the length of time from the date of each premium payment. The surrender charge is assessed on full or partial surrenders from the policy. A surrender charge may also be referred to as a “contingent deferred sales charge.”

Valuation Period — The period of time from one determination of accumulation unit values and annuity unit values to the next subsequent determination of values. Such determination shall be made on each business day.

Variable Annuity Payments — Payments made pursuant to an annuity payment option which fluctuate as to dollar amount or payment term in relation to the investment performance of the specified subaccounts within the separate account.

Written Notice — Written notice, signed by the owner, that gives the Company the information it requires and is received at the administrative and service office. For some transactions, the Company may accept an electronic notice, such as telephone instructions, instead of written notice. Such written or electronic notice must meet the requirements the Company establishes for such notices.

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In order to supplement the description in the prospectus, the following provides additional information about Transamerica Life Insurance Company (the Company, we, us or our) and the policy, which may be of interest to a prospective purchaser.

THE POLICY — GENERAL PROVISIONS

Owner

The policy shall belong to the owner upon issuance of the policy after completion of an enrollment form and delivery of the initial premium payment. While the annuitant is living, the owner may: (1) assign the policy; (2) surrender the policy; (3) amend or modify the policy with the Company’s consent; (4) receive annuity payments or name a payee to receive the payments; and (5) exercise, receive and enjoy every other right and benefit contained in the policy. The exercise of these rights may be subject to the consent of any assignee or irrevocable beneficiary; and of your spouse in a community or marital property state.

Unless the Company has been notified of a community or marital property interest in the policy, it will rely on its good faith belief that no such interest exists and will assume no responsibility for inquiry.

Note carefully. If the owner predeceases the annuitant and no joint owner, primary beneficiary, or contingent beneficiary is alive or in existence on the date of death, the owner’s estate will become the new owner. If no probate estate is opened because the owner has precluded the opening of a probate estate by means of a trust or other instrument, that trust may not exercise ownership rights to the policy. It may be necessary to open a probate estate in order to exercise ownership rights to the policy.

The owner may change the ownership of the policy in a written notice. When this change takes effect, all rights of ownership in the policy will pass to the new owner. A change of ownership may have tax consequences.

When there is a change of owner, the change will not be effective until it is recorded in our records. Once recorded, it will take effect as of the date the owner signs the written notice, subject to any payment the Company has made or action the Company has taken before recording the change. Changing the owner does not change the designation of the beneficiary or the annuitant.

If ownership is transferred to a new owner (except to the owner’s spouse) because the owner dies before the annuitant, then (a) the cash value generally must be distributed to the new owner within five years of the owner’s death, or (b) annuity payments must be made for a period certain or for the new owner’s lifetime so long as any period certain does not exceed that new owner’s life expectancy, if the first payment begins within one year of your death.

Entire Policy

The policy, any endorsements or riders thereon, the enrollment form, or information provided in lieu thereof, constitute the entire contract between the Company and the owner. All statements in the enrollment form are representations and not warranties. No statement will cause the policy to be void or to be used in defense of a claim unless contained in the enrollment form or information provided in lieu thereof.

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Misstatement of Age or Sex

If the age or sex of the annuitant or owner has been misstated, the Company will change the annuity benefit payable to that which the premium payments would have purchased for the correct age or sex. The dollar amount of any underpayment made by the Company shall be paid in full with the next payment due such person or the beneficiary. The dollar amount of any overpayment made by the Company due to any misstatement shall be deducted from payments subsequently accruing to such person or beneficiary. Any underpayment or overpayment will include interest at 5% per year, from the date of the wrong payment to the date of the adjustment. The age of the annuitant or owner may be established at any time by the submission of proof satisfactory to the Company.

Reallocation of Annuity Units After the Annuity Commencement Date

After the annuity commencement date, you may reallocate the value of a designated number of annuity units of a subaccount then credited to a policy into an equal value of annuity units of one or more other subaccounts or the fixed account. The reallocation shall be based on the relative value of the annuity units of the account(s) or subaccount(s) at the end of the business day on the next payment date. The minimum amount which may be reallocated is the lesser of (1) $10 of monthly income or (2) the entire monthly income of the annuity units in the account or subaccount from which the transfer is being made. If the monthly income of the annuity units remaining in an account or subaccount after a reallocation is less than $10, the Company reserves the right to include the value of those annuity units as part of the transfer. The request must be in writing to the Company’s administrative and service office. There is no charge assessed in connection with such reallocation. A reallocation of annuity units may be made up to four times in any given policy year.

After the annuity commencement date, no transfers may be made from the fixed account to the separate account.

Annuity Payment Options

Note: Portions of the following discussion do not apply to annuity payments under the Initial Payment Guarantee. See the “Stabilized Payments” section of this SAI.

During the lifetime of the annuitant and before the annuity commencement date, the owner may choose an annuity payment option or change the election, but notice of any election or change of election must be received by the Company in good order at its Administrative and Service Office at least thirty (30) days before the annuity commencement date (elections less than 30 days require prior approval). If no election is made before the annuity commencement date, annuity payments will be made under (1) life income with level (fixed) payments for 10 years certain, using the existing policy value of the fixed account, or (2) life income with variable payments for 10 years certain using the existing policy value of the separate account, or (3) a combination of (1) and (2).

The person who elects an annuity payment option can also name one or more successor payees to receive any unpaid amount the Company has at the death of a payee. Naming these payees cancels any prior choice of a successor payee.

A payee who did not elect the annuity payment option does not have the right to advance or assign payments, take the payments in one sum, or make any other change. However, the payee may be given the right to do one or more of these things if the person who elects the option tells the Company in writing and the Company agrees.

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Variable Payment Options. The dollar amount of the first variable annuity payment will be determined in accordance with the annuity payment rates set forth in the applicable table contained in the policy. For annuity payments the tables are based on a 5% effective annual Assumed Investment Return and the “2000 Table”, using an assumed annuity commencement date of 2005 (static projection to this point) with dynamic projection using scale G from that point (100% of G for male, 50% of G for females). The dollar amount of additional variable annuity payments will vary based on the investment performance of the subaccount(s) of the separate account selected by the annuitant or beneficiary.

Determination of the First Variable Payment. The amount of the first variable payment depends upon the sex (if consideration of sex is allowed under state law) and adjusted age of the annuitant. For regular annuity payments, the adjusted age is the annuitant’s actual age nearest birthday, on the annuity commencement date, adjusted as described in your policy. This adjustment assumes an increase in life expectancy, and therefore it results in lower payments than without such an adjustment.

Determination of Additional Variable Payments. All variable annuity payments other than the first are calculated using annuity units which are credited to the policy. The number of annuity units to be credited in respect of a particular subaccount is determined by dividing that portion of the first variable annuity payment attributable to that subaccount by the annuity unit value of that subaccount on the annuity commencement date. The number of annuity units of each particular subaccount credited to the policy then remains fixed, assuming no transfers to or from that subaccount occur. The dollar value of variable annuity units in the chosen subaccount will increase or decrease reflecting the investment experience of the chosen subaccount. The dollar amount of each variable annuity payment after the first may increase, decrease or remain constant. This amount is equal to the sum of the amounts determined by multiplying the number of annuity units of each particular subaccount credited to the policy by the annuity unit value for the particular subaccount on the date the payment is made.

Death Benefit

Due proof of death of the annuitant is proof that the annuitant died prior to the commencement of annuity payments. A certified copy of a death certificate, a certified copy of a decree of a court of competent jurisdiction as to the finding of death, a written statement by the attending physician, or any other proof satisfactory to the Company will constitute due proof of death.

Upon receipt in good order (at our Administrative and Service Office) of this proof and an election of a method of settlement and return of the policy, the death benefit generally will be paid within seven days, or as soon thereafter as the Company has sufficient information about the beneficiary(ies) to make the payment. The beneficiary may receive the amount payable in a lump sum cash benefit, or, subject to any limitation under any state or federal law, rule, or regulation, under one of the annuity payment options described above, unless a settlement agreement is effective at the death of the owner preventing such election.

If an owner is not an annuitant, and dies prior to the annuity commencement date, the new owner may surrender the policy at any time for the amount of the adjusted policy value. If the new owner is not the deceased owner’s spouse, however, (1) the adjusted policy value must be distributed within five years after the date of the deceased owner’s death, or (2) payments under an annuity payment option must begin no later than one year after the deceased owner’s death and must be made for the new owner’s lifetime or for a period certain (so long as any period certain does not exceed the new owner’s life expectancy). If the sole new owner is the deceased owner’s surviving spouse, such spouse may elect to continue the policy as the new owner instead of receiving the death benefit.

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Beneficiary. The beneficiary designation in the enrollment form will remain in effect until changed. The owner may change the designated beneficiary by sending written notice to the Company. The beneficiary’s consent to such change is not required unless the beneficiary was irrevocably designated or law requires consent. (If an irrevocable beneficiary dies, the owner may then designate a new beneficiary.) The change will take effect as of the date the owner signs the written notice, whether or not the owner is living when the notice is received by the Company. The Company will not be liable for any payment made before the written notice is received. If more than one beneficiary is designated, and the owner fails to specify their interests, they will share equally. If upon the death of the annuitant there is a surviving owner(s), the surviving owner(s) automatically takes the place of any beneficiary designation.

Death of Owner

Federal tax law requires that if any owner (including any joint owner who has become a current owner) dies before the annuity commencement date, then the entire value of the policy must generally be distributed within five years of the date of death of such owner. Certain rules apply where (1) the spouse of the deceased owner is the sole beneficiary, (2) the owner is not a natural person and the primary annuitant dies or is changed, or (3) any owner dies after the annuity commencement date. See “Certain Federal Income Tax Consequences” for more information about these rules. Other rules may apply to qualified policies.

Assignment

During the lifetime of the annuitant you may assign any rights or benefits provided by the policy if your policy is a nonqualified policy. An assignment will not be binding on the Company until a copy has been filed at its administrative and service office. Your rights and benefits and those of the beneficiary are subject to the rights of the assignee. The Company assumes no responsibility for the validity or effect of any assignment. Any claim made under an assignment shall be subject to proof of interest and the extent of the assignment. An assignment may have tax consequences.

Unless you so direct by filing written notice with the Company, no beneficiary may assign any payments under the policy before they are due. To the extent permitted by law, no payments will be subject to the claims of any beneficiary’s creditors.

Ownership under qualified policies is restricted to comply with the Code.

Evidence of Survival

The Company reserves the right to require satisfactory evidence that a person is alive if a payment is based on that person being alive. No payment will be made until the Company receives such evidence.

Non-Participating

The policy will not share in the Company’s surplus earnings; no dividends will be paid.

Amendments

No change in the policy is valid unless made in writing by the Company and approved by one of the Company’s officers. No registered representative has authority to change or waive any provision of the policy.

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The Company reserves the right to amend the policies to meet the requirements of the Code, regulations or published rulings. You can refuse such a change by giving written notice, but a refusal may result in adverse tax consequences.

Employee and Agent Purchases

The policy may be acquired by an employee or registered representative of any broker/dealer authorized to sell the policy or their immediate family, or by an officer, director, trustee or bona-fide full-time employee of the Company or its affiliated companies or their immediate family. In such a case, the Company in its discretion, may credit an amount equal to a percentage of each premium payment to the policy due to lower acquisition costs the Company experiences on those purchases. The Company may offer certain employer sponsored savings plans, reduced fees and charges including, but not limited to, the annual service charge, the surrender charges, the mortality and expense risk fee and the administrative charge for certain sales under circumstances which may result in savings of certain costs and expenses. In addition, there may be other circumstances of which the Company is not presently aware which could result in reduced sales or distribution expenses. Credits to the policy or reductions in these fees and charges will not be unfairly discriminatory against any owner.

Present Value of Future Variable Payments

The present value of future period certain variable payments is calculated by taking (a) the supportable payment on the business day we receive the surrender request (in good order at our Administrative and Service Office), multiplied by (b) the number of payments remaining, multiplied by a discount rate (such as the assumed investment rate or “AIR”).

Stabilized Payments

If you have selected a payout feature that provides for stabilized payments (e.g., the Initial Payment Guarantee), please note that the stabilized payments remain level throughout each year and are adjusted on your annuitization anniversary. Without stabilized payments, each payment throughout the year would fluctuate based on the performance of your selected subaccounts. To reflect the difference in these payments we adjust (both increase and decrease as appropriate) the number of annuity units. The annuity units are adjusted when we calculate the supportable payment. Supportable payments are used in the calculation of surrender values, death benefits and transfers. On the anniversary of your annuity commencement date we set the new stabilized payment equal to the current supportable payment. In the case of an increase in the number of variable annuity units, your participation in the future investment performance of the subaccounts will be increased because more variable annuity units are credited to you. Conversely, in the case of a reduction of the number of variable annuity units, your participation in the future investment performance of the subaccounts will be decreased because fewer variable annuity units are credited to you. If the Initial Payment Guarantee is chosen, then the stabilized variable annuity payment will equal the greater of the guaranteed payment or the supportable payment at that time.

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The following table demonstrates, on a purely hypothetical basis, the changes in the number of variable annuity units. The changes in the variable annuity unit values reflect the investment performance of the applicable subaccounts as well as the separate account charge.

Hypothetical Changes in Annuity Units with Stabilized Payments*

Assumed Investment Rate	5.0%
Life & 10 Year Certain
Male aged 65
First Variable Payment	$500

		Beginning Annuity Units		Annuity Unit Values		Monthly Payment Without Stabilization		Monthly Stabilized Payment		Adjustments In Annuity Units			Cumulative Adjusted Annuity Units
At Issue:	January 1		400.0000		1.250000	$	500.00	$	500.00		0.0000			400.0000
	February 1		400.0000		1.252005	$	500.80	$	500.00		0.0041			400.0041
	March 1		400.0000		1.252915	$	501.17	$	500.00		0.0059			400.0100
	April 1		400.0000		1.245595	$	498.24	$	500.00		(0.0089	)		400.0011
	May 1		400.0000		1.244616	$	497.85	$	500.00		(0.0108	)		399.9903
	June 1		400.0000		1.239469	$	495.79	$	500.00		(0.0212	)		399.9691
	July 1		400.0000		1.244217	$	497.69	$	500.00		(0.0115	)		399.9576
	August 1		400.0000		1.237483	$	494.99	$	500.00		(0.0249	)		399.9327
	September 1		400.0000		1.242382	$	496.95	$	500.00		(0.0150	)		399.9177
	October 1		400.0000		1.242382	$	496.95	$	500.00		(0.0149	)		399.9027
	November 1		400.0000		1.249210	$	499.68	$	500.00		(0.0016	)		399.9012
	December 1		400.0000		1.252106	$	500.84	$	500.00		0.0040			399.9052
	January 1		399.9052		1.255106	$	501.92	$	501.92		0.0000			399.9052

* The total separate account expenses and portfolio expenses included in the calculations are 2.25% (2.25% is a hypothetical figure). If higher (or lower) expenses were charged, the numbers would be lower (or higher).

CERTAIN FEDERAL INCOME TAX CONSEQUENCES

The following summary does not constitute tax advice. It is a general discussion of certain of the expected federal income tax consequences of investment in and distributions with respect to a policy, based on the Code, Regulations thereunder, judicial authority, and current administrative rulings and practice. This summary discusses only certain federal income tax consequences to “United States Persons,” and does not discuss federal gift, estate or any other state, local, or foreign tax consequences. United States Persons means citizens or residents of the United States, domestic corporations, domestic partnerships and trusts, or estates that are subject to United States federal income tax regardless of the source of their income.

Tax Status of the Policy

Diversification Requirements. Section 817(h) of the Code provides that in order for a non-qualified variable policy which is based on a segregated asset account to qualify as an annuity policy under the Code, the investments made by

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such account must be “adequately diversified” in accordance with Treasury Regulations. The Regulations issued under Section 817(h) (Treas. Reg. Section 1.817 -5) apply a diversification requirement to each of the subaccounts. The separate account, through its underlying fund portfolios and their portfolios, intends to comply with the diversification requirements of the Regulations. We have entered into agreements with each underlying fund portfolio company that require the portfolios to be operated in compliance with the Regulations.

Owner Control. In some circumstances, owners of variable policies who retain excessive control over the investment of the underlying separate account assets may be treated as the owners of those assets and may be subject to tax on income produced by those assets. Although there is little guidance in this area and published guidance does not address certain aspects of the policies, we believe that the owner of a policy should not be treated as the owner of the underlying assets. We reserve the right to modify the policies to bring them into conformity with applicable standards should such modification be necessary to prevent owners of the policies from being treated as the owners of the underlying separate account assets.

Distribution Requirements. The Code requires that nonqualified policies contain specific provisions for distribution of policy proceeds upon the death of any owner. In order to be treated as an annuity policy for federal income tax purposes, the Code requires that such policies provide that if any owner dies on or after the annuity commencement date and before the entire interest in the policy has been distributed, the remaining portion must be distributed at least as rapidly as under the method in effect on such owner’s death. If any owner dies before the annuity commencement date, the entire interest in the policy must generally be distributed within 5 years after such owner’s date of death or be used to provide payments to a designated beneficiary beginning within one year of such owner’s death and will be made for the life of the beneficiary or for a period not extending beyond the life expectancy of the beneficiary. However, if upon such owner’s death prior to the annuity commencement date, such owner’s surviving spouse becomes the sole new owner under the policy, then the policy may be continued with the surviving spouse as the new owner. Under the policy, the beneficiary is the person(s) designated by an owner/annuitant and the surviving joint owner is the beneficiary of an owner who is not the annuitant. If any owner is not a natural person, then for purposes of these distribution requirements, the primary annuitant shall be treated as an owner and any death or change of such primary annuitant shall be treated as the death of an owner. The nonqualified policies contain provisions intended to comply with these requirements of the Code. No regulations interpreting these requirements of the Code have yet been issued and thus no assurance can be given that the provisions contained in the policies satisfy all such Code requirements. The provisions contained in the policies will be reviewed and modified if necessary to assure that they comply with the Code requirements when clarified by regulation or otherwise.

The Federal Defense of Marriage Act currently does not recognize same-sex marriages or civil unions, even those that are permitted under individual state laws. Therefore, exercise of the spousal continuation provisions of this policy by persons who do not meet the definition of “spouse” under federal law—e.g., civil union partners and same-sex marriage spouses—may have adverse tax consequences. Consult a tax advisor for more information on this subject.

The following discussion is based on the assumption that the policy qualifies as an annuity policy for federal income tax purposes.

Taxation of Annuities

In General. Code Section 72 governs taxation of annuities in general. We believe that an owner who is an individual will not be taxed on increases in the value of a policy until such amounts are surrendered or distributed. For this purpose, the assignment, pledge, or agreement to assign or pledge any portion of the policy value, and in the case of a qualified policy,

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any portion of an interest in the plan, generally will be treated as a distribution. The taxable portion of a distribution is taxable as ordinary income.

Non-Natural Persons. Pursuant to Section 72(u) of the Code, a nonqualified policy held by a taxpayer other than a natural person generally will not be treated as an annuity policy under the Code; accordingly, an owner who is not a natural person will recognize as ordinary income for a taxable year the excess, if any, of the policy value over the “investment in the contract”. There are some exceptions to this rule and a prospective purchaser of the policy that is not a natural person should discuss these with a competent tax adviser.

Withholding. The portion of any distribution under a policy that is includable in gross income will be subject to federal income tax withholding unless the recipient of such distribution elects not to have federal income tax withheld. Election forms will be provided at the time distributions are requested or made. For certain qualified policies, the withholding rate varies according to the type of distribution and the owner’s tax status. For qualified policies taxable, “eligible rollover distributions” from Section 401(a) plans, Section 403(a) annuities, Section 403(b) tax-sheltered annuities, and governmental 457 plans are subject to a mandatory federal income tax withholding of 20%. An eligible rollover distribution is any distribution from such a plan, other than specified distributions such as distributions required by the Code, distributions in a specified annuity form or hardship distributions. The 20% withholding does not apply, however, to nontaxable distributions or if (i) the employee (or employee’s spouse or former spouse as beneficiary or alternate payee) chooses a “direct rollover” from the plan to a tax-qualified plan, IRA, Roth IRA or tax sheltered annuity or to a governmental 457 plan that agrees to separately account for rollover contributions; or (ii) a non-spouse beneficiary chooses a “direct rollover” from the plan to an IRA established by the direct rollover.

Incidental Death Benefits. The policy may include optional death benefit features, the value of which may exceed the value of the policy or premium payments made under the policy. Federal tax laws limit the value of such incidental death benefit in tax-qualified pension, profit-sharing and 403(b) plans. Further, the Internal Revenue Service has not reviewed this policy for qualification as an IRA, and has not addressed in a ruling of general applicability whether any death benefits available under the policy comport with qualification requirements. The actuarial present value of death benefit options and riders elected may need to be considered in calculating minimum required distributions. Consult a qualified tax adviser before purchasing an optional death benefit.

Qualified Policies. The qualified policy is designed for use with several types of tax-qualified retirement plans. The tax rules applicable to participants and beneficiaries in tax-qualified retirement plans vary according to the type of plan and the terms and conditions of the plan. Special favorable tax treatment may be available for certain types of contributions and distributions. Adverse tax consequences may result from contributions in excess of specified limits, distributions prior to age 59 ¹/2 (subject to certain exceptions), distributions that do not conform to specified commencement and minimum distribution rules, and in other specified circumstances. Some retirement plans are subject to distribution and other requirements that are not incorporated into the policies or our policy administration procedures. Owners, participants, and beneficiaries are responsible for determining that contributions, distributions, and other transactions with respect to the policies comply with applicable law.

For qualified plans under Section 401(a), 403(a), 403(b), and 457, the Code requires that distributions generally must commence no later than the later of April 1 of the calendar year following the calendar year in which the owner (or plan participant) (i) reaches age 70 ¹/2 or (ii) retires, and must be made in a specified form or manner. If a participant in a Section 401(a) plan is a “5 percent owner” (as defined in the Code), or in the case of an IRA (other than a Roth IRA), distributions generally must begin no later than April 1 of the calendar year in which the owner (or plan participant) reaches age 70 ¹/2. Each owner is responsible for requesting distributions under the policy that satisfy applicable tax rules.

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We do not attempt to provide more than general information about use of the policy with the various types of retirement plans. Purchasers of policies for use with any retirement plan should consult their legal counsel and tax adviser regarding the suitability of the policy.

Traditional Individual Retirement Annuities. In order to qualify as a traditional individual retirement annuity under Section 408(b) of the Code, a policy must satisfy certain conditions: (i) the owner must be the annuitant; (ii) the policy generally is not transferable by the owner, e.g., the owner may not designate a new owner, designate a contingent owner or assign the policy as collateral security; (iii) subject to special rules, the total premium payments for any calendar year may not exceed the amount specified in the Code ($5,000 for 2011, $6,000 if age 50 or older), except in the case of a rollover amount or contribution under Section 402(c), 402(e)(6), 403(a)(4), 403(b)(8), 403(b)(10), 408(d)(3) or 457(e)(16) of the Code; (iv) annuity payments or partial surrenders must begin no later than April 1 of the calendar year following the calendar year in which the annuitant attains age 70 ¹/2; (v) an annuity payment option with a period certain that will guarantee annuity payments beyond the life expectancy of the annuitant and the beneficiary may not be selected; (vi) certain payments of death benefits must be made in the event the annuitant dies prior to the distribution of the policy value; (vii) the entire interest of the owner is non-forfeitable; and (viii) the premiums must not be fixed. Policies intended to qualify as traditional individual retirement annuities under Section 408(b) of the Code contain such provisions. Amounts in the IRA (other than nondeductible contributions) are taxed when distributed from the IRA. Distributions prior to age 59 ¹/2 (unless certain exceptions apply) are subject to a 10% penalty tax.

Roth Individual Retirement Annuities (Roth IRA). The Roth IRA, under Section 408A of the Code, contains many of the same provisions as a traditional IRA. However, there are some differences. First, the contributions are not deductible and must be made in cash or as a rollover or transfer from another Roth IRA or other IRA. A rollover from or conversion of an IRA to a Roth IRA may be subject to tax. The Roth IRA is available to individuals with earned income and whose modified adjusted gross income is under $120,000 for single filers, $176,000 for married filing jointly, and $10,000 for married filing separately. Subject to special rules, the amount per individual that may be contributed to all IRAs (Roth and traditional) is the deductible amount specified in the Code ($5,000 for 2011, $6,000 if age 50 or older). Secondly, the distributions are taxed differently. The Roth IRA offers tax-free distributions when made 5 tax years after the first contribution to any Roth IRA of the individual and made after attaining age 59 ¹/2, to pay for qualified first time homebuyer expenses (lifetime maximum of $10,000), or due to death or disability. All other distributions are subject to income tax when made from earnings and may be subject to a penalty tax unless an exception applies. Unlike the traditional IRA, there are no minimum required distributions during the owner’s lifetime; however, required distributions at death are generally the same as for traditional IRAs.

Section 403(b) Plans. Under Section 403(b) of the Code, payments made by public school systems and certain tax exempt organizations to purchase policies for their employees are generally excludable from the gross income of the employee, subject to certain limitations. However, such payments may be subject to FICA (Social Security) taxes. The policy includes a death benefit that in some cases may exceed the greater of the premium payments or the policy value. The death benefit could be characterized as an incidental benefit, the amount of which is limited in any tax-sheltered annuity under Section 403(b). Therefore, employers using the policy in connection with such plans should consult their tax adviser. Additionally, in accordance with the requirements of the Code, Section 403(b) annuities generally may not permit distribution of (i) elective contributions made in years beginning after December 31, 1988, and (ii) earnings on those contributions, and (iii) earnings on amounts attributed to elective contributions held as of the end of the last year beginning before January 1, 1989. Distributions of such amounts will be allowed only upon the death of the employee, on or after attainment of age 59 ¹/2, severance from employment, disability, or financial hardship, except that income attributable to elective contributions may not be distributed in the case of hardship. These rules may prevent the payment of guaranteed withdrawals under a guaranteed lifetime withdrawal benefit prior to age 59 ¹/2.

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For policies issued after 2008, amounts attributable to nonelective contributions may be subject to distribution restrictions specified in the employer’s section 403(b) plan.

Pursuant to new tax regulations, we generally are required to confirm, with your 403(b) plan sponsor or otherwise, that surrenders you request from a 403(b) policy comply with applicable tax requirements before we process your request. We will defer such payments you request until all information required under the tax law has been received. By requesting a surrender or transfer, you consent to the sharing of confidential information about you, the policy, and transactions under the policy and any other 403(b) policies or accounts you have under the 403(b) plan among us, your employer or plan sponsor, any plan administrator or recordkeeper, and other product providers.

Corporate Pension and Profit-Sharing Plans and H.R. 10 Plans. Sections 401(a) and 403(a) of the Code permit corporate employers to establish various types of retirement plans for employees and self-employed individuals to establish qualified plans for themselves and their employees. Such retirement plans may permit the purchase of the policies to accumulate retirement savings. Adverse tax consequences to the plan, the participant or both may result if the policy is assigned or transferred to any individual as a means to provide benefit payments.

Deferred Compensation Plans. Section 457 of the Code, while not actually providing for a qualified plan as that term is normally used, provides for certain deferred compensation plans with respect to service for state governments, local governments, political subdivisions, agencies, instrumentalities, and certain affiliates of such entities, and tax exempt organizations. The policies can be used with such plans. Under such plans a participant may specify the form of investment in which his or her participation will be made. For non-governmental Section 457 plans, all such investments, however, are owned by, and are subject to, the claims of the general creditors of the sponsoring employer. Depending on the terms of the particular plan, a non-government employer may be entitled to draw on deferred amounts for purposes unrelated to its Section 457 plan obligations. In general, all amounts received under a nongovernmental Section 457 plan are taxable and are subject to federal income tax withholding as wages.

Taxation of the Company

The Company at present is taxed as a life insurance company under part I of Subchapter L of the Code. The separate account is treated as part of the Company and, accordingly, will not be taxed separately as a “regulated investment company” under Subchapter M of the Code. We do not expect to incur any federal income tax liability with respect to investment income and net capital gains arising from the activities of the separate account retained as part of the reserves under the policy. Based on this expectation, it is anticipated that no charges will be made against the separate account for federal income taxes. If, in future years, any federal income taxes are incurred by us with respect to the separate account, we may make a charge to that account.

INVESTMENT EXPERIENCE

A “net investment factor” is used to determine the value of accumulation units and annuity units, and to determine annuity payment rates.

Accumulation Units

Allocations of a premium payment directed to a subaccount are credited in the form of accumulation units. Each subaccount has a distinct accumulation unit value. The number of units credited is determined by dividing the premium

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payment or amount transferred to the subaccount by the accumulation unit value of the subaccount as of the end of the valuation period during which the allocation is made. For each subaccount, the accumulation unit value for a given business day is based on the net asset value of a share of the corresponding portfolio of the underlying fund portfolios less any applicable charges or fees. The investment performance of the portfolio, expenses, and deductions of certain charges affect the value of an accumulation unit.

Upon allocation to the selected subaccount, premium payments are converted into accumulation units of the subaccount. The number of accumulation units to be credited is determined by dividing the dollar amount allocated to each subaccount by the value of an accumulation unit for that subaccount as next determined after the premium payment is received at the administrative and service office or, in the case of the initial premium payment, when the enrollment form is completed, whichever is later. The value of an accumulation unit for each subaccount was arbitrarily established at $1 at the inception of each subaccount. Thereafter, the value of an accumulation unit is determined as of the close of trading on each day the New York Stock Exchange is open for regular trading.

An index (the “net investment factor”) which measures the investment performance of a subaccount during a valuation period, is used to determine the value of an accumulation unit for the next subsequent valuation period. The net investment factor may be greater or less than or equal to one; therefore, the value of an accumulation unit may increase, decrease, or remain the same from one valuation period to the next. You bear this investment risk. The net investment performance of a subaccount and deduction of certain charges affect the accumulation unit value.

The net investment factor for any subaccount for any valuation period is determined by dividing (a) by (b) and subtracting (c) from the result, where:

(a) is the net result of:

(1) the net asset value per share of the shares held in the subaccount determined at the end of the current valuation period, plus

(2) the per share amount of any dividend or capital gain distribution made with respect to the shares held in the subaccount if the ex-dividend date occurs during the current valuation period, plus or minus

(3) a per share credit or charge for any taxes determined by the Company to have resulted during the valuation period from the investment operations of the subaccount;

(b) is the net asset value per share of the shares held in the subaccount determined as of the end of the immediately preceding valuation period; and

(c) is an amount representing the separate account charge and any optional benefit fees, if applicable.

Illustration of Separate Account Accumulation Unit Value Calculations

Formula and Illustration for Determining the Net Investment Factor

Net Investment Factor =	(A + B - C)	- E
	D

Where:
A =	The net asset value of an underlying fund portfolio share as of the end of the current valuation period.
	Assume	A = $11.57

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B =	The per share amount of any dividend or capital gains distribution since the end of the immediately preceding valuation period.
	Assume	B = 0

C =	The per share charge or credit for any taxes reserved for at the end of the current valuation period.
	Assume	C = 0

D =	The net asset value of an underlying fund portfolio share at the end of the immediately preceding valuation period.
	Assume	D = $11.40
E =	The daily deduction for the mortality and expense risk fee and the administrative charge, and any optional benefit fees, if applicable. Assume E totals 2.30% on an annual basis; On a daily basis, this equals 0.000062302.

Then, the net investment factor =	(11.57 + 0 – 0)	- 0.000062302 = Z = 1.014849979
	(11.40)

Formula and Illustration for Determining Accumulation Unit Value

Accumulation Unit Value = A * B

Where:
A =	The accumulation unit value for the immediately preceding valuation period.
	Assume = $X

B =	The net investment factor for the current valuation period.
	Assume = Y

Then, the accumulation unit value = $X * Y = $Z

Annuity Unit Value and Annuity Payment Rates

The amount of variable annuity payments will vary with annuity unit values. Annuity unit values rise if the net investment performance of the subaccount exceeds the assumed investment return of 5% annually. Conversely, annuity unit values fall if the net investment performance of the subaccount is less than the annual assumed investment return. The value of a variable annuity unit in each subaccount was established at $1 on the date operations began for that subaccount. The value of a variable annuity unit on any subsequent business day is equal to (a) multiplied by (b) multiplied by (c), where:

(a) is the variable annuity unit value for the subaccount on the immediately preceding business day;

(b) is the net investment factor for that subaccount for the valuation period; and

(c) is the assumed investment return adjustment factor for the valuation period.

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The assumed investment return adjustment factor for the valuation period is the product of discount factors of .99986634 per day to recognize the 5% effective annual assumed investment return. The valuation period is the period from the close of the immediately preceding business day to the close of the current business day.

The net investment factor for the policy used to calculate the value of a variable annuity unit in each subaccount for the valuation period is determined by dividing (i) by (ii) and subtracting (iii) from the result, where:

(i) is the result of:

(1) the net asset value of a fund share held in that subaccount determined at the end of the current valuation period; plus

(2) the per share amount of any dividend or capital gain distributions made by the fund for shares held in that subaccount if the ex-dividend date occurs during the valuation period; plus or minus

(3) a per share charge or credit for any taxes reserved for, which the Company determines to have resulted from the investment operations of the subaccount.

(ii) is the net asset value of a fund share held in that subaccount determined as of the end of the immediately preceding valuation period.

(iii) is a factor representing the mortality and expense risk fee and administrative charge. This factor is equal, on an annual basis, to 1.25% of the daily net asset value of shares held in that subaccount (For calculating Initial Payment Guarantee annuity payments, the factor is higher at a rate of 2.50%).

The dollar amount of subsequent variable annuity payments will depend upon changes in applicable annuity unit values.

The annuity payment rates generally vary according to the annuity option elected and the gender and adjusted age of the annuitant at the annuity commencement date. The policy contains a table for determining the adjusted age of the annuitant.

Illustration of Calculations for Annuity Unit

Value and Variable Annuity Payments

Formula and Illustration for Determining Annuity Unit Value

Annuity Unit Value = A * B * C

Where:
A =	annuity unit value for the immediately preceding valuation period.
	Assume = $X

B =	Net investment factor for the valuation period for which the annuity unit value is being calculated.
	Assume = Y

C =	A factor to neutralize the annual assumed investment return of 5% built into the Annuity Tables used.
	Assume = Z

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Then, the annuity unit value is:

$X * Y * Z = $Q

Formula and Illustration for Determining Amount of

First Monthly Variable Annuity Payment

First monthly variable annuity payment =	A * B
	$1,000

Where:
A =	The adjusted policy value as of the annuity commencement date.
	Assume = $X

B =	The annuity purchase rate per $1,000 of adjusted policy value based upon the option selected, the sex and adjusted age of the annuitant according to the tables contained in the policy.
	Assume = $Y

Then, the first monthly variable annuity payment =	$X * $Y	= $Z
	1,000

Formula and Illustration for Determining the Number of Annuity Units

Represented by Each Monthly Variable Annuity Payment

Number of annuity units =	A
	B

Where:
A =	The dollar amount of the first monthly variable annuity payment.
	Assume = $X

B =	The annuity unit value for the valuation date on which the first monthly payment is due.
	Assume = $Y

Then, the number of annuity units =	$X	= Z
	$Y

HISTORICAL PERFORMANCE DATA

Money Market Yields

The Company may from time to time disclose the current annualized yield of the money market subaccount, which invests in the corresponding money market portfolio, for a 7-day period in a manner which does not take into

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consideration any realized or unrealized gains or losses on shares of the corresponding money market portfolio or on its portfolio securities. This current annualized yield is computed by determining the net change (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) at the end of the 7-day period in the value of a hypothetical account having a balance of 1 unit of the money market subaccount at the beginning of the 7-day period, dividing such net change in account value by the value of the account at the beginning of the period to determine the base period return, and annualizing this quotient on a 365-day basis. The net change in account value reflects (i) net income from the portfolio attributable to the hypothetical account; and (ii) charges and deductions imposed under a policy that are attributable to the hypothetical account. The charges and deductions include the per unit charges for the hypothetical account for (i) the administrative charges and (ii) the mortality and expense risk fee. Current yield will be calculated according to the following formula:

Current Yield = ((NCS * ES)/UV) * (365/7)

Where:

NCS	=	The net change in the value of the portfolio (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) for the 7-day period attributable to a hypothetical account having a balance of 1 subaccount unit.
ES	=	Per unit expenses of the subaccount for the 7-day period.
UV	=	The unit value on the first day of the 7-day period.

Because of the charges and deductions imposed under a policy, the yield for the money market subaccount will be lower than the yield for the corresponding money market portfolio. The yield calculations do not reflect the effect of any premium taxes. The yield calculations also do not reflect surrender charges that may be applicable to a particular policy. Surrender charges range from 9% to 0% of the amount of premium payments surrendered based on the number of years since the premium payment was made. Surrender charges are based on the number of years since the date the premium payment was made, not the policy issue date.

The Company may also disclose the effective yield of the money market subaccount for the same 7-day period, determined on a compounded basis. The effective yield is calculated by compounding the base period return according to the following formula:

Effective Yield = (1 + ((NCS - ES)/UV))^365/7 - 1

Where:

NCS	=	The net change in the value of the portfolio (exclusive of realized gains and losses on the sale of securities and unrealized appreciation and depreciation and income other than investment income) for the 7-day period attributable to a hypothetical account having a balance of 1 subaccount unit.
ES	=	Per unit expenses of the subaccount for the 7-day period.
UV	=	The unit value on the first day of the 7-day period.

The yield on amounts held in the money market subaccount normally will fluctuate on a daily basis. Therefore, the disclosed yield for any given past period is not an indication or representation of future yields or rates of return. The money market subaccount’s actual yield is affected by changes in interest rates on money market securities, average portfolio maturity of the corresponding money market portfolio, the types and quality of portfolio securities held by the corresponding money market portfolio and its operating expenses.

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Total Returns

The Company may from time to time also advertise or disclose total returns for one or more of the subaccounts for various periods of time. One of the periods of time will include the period measured from the date the subaccount commenced operations. When a subaccount has been in operation for 1, 5 and 10 years, respectively, the total return for these periods will be provided. Total returns for other periods of time may from time to time also be disclosed. Total returns represent the average annual compounded rates of return that would equate an initial investment of $1,000 to the redemption value of that investment as of the last day of each of the periods. The ending date for each period for which total return quotations are provided will be for the most recent month end practicable, considering the type and media of the communication and will be stated in the communication.

Total returns will be calculated using subaccount unit values which the Company calculates on each business day based on the performance of the separate account’s underlying fund portfolio and the deductions for the mortality and expense risk fee and the administrative charges. Total return calculations will reflect the effect of surrender charges that may be applicable to a particular period. The total return will then be calculated according to the following formula:

P (1 + T)^N = ERV

Where:

T	=	The average annual total return net of subaccount recurring charges.
ERV	=	The ending redeemable value of the hypothetical account at the end of the period.
P	=	A hypothetical initial payment of $1,000.
N	=	The number of years in the period.

Other Performance Data

The Company may from time to time also disclose average annual total returns in a non-standard format in conjunction with the standard format described above. The non-standard format will be identical to the standard format except that the surrender charge percentage will be assumed to be 0%.

The Company may from time to time also disclose cumulative total returns in conjunction with the standard format described above. The cumulative returns will be calculated using the following formula except that the surrender charge percentage will be assumed to be 0%:

CTR = (ERV / P)-1

Where:

CTR	=	The cumulative total return net of subaccount recurring charges for the period.
ERV	=	The ending redeemable value of the hypothetical investment at the end of the period.
P	=	A hypothetical initial payment of $1,000.

All non-standard performance data will only be advertised if the standard performance data is also disclosed.

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Adjusted Historical Performance Data

From time to time, sales literature or advertisements may quote average annual total returns for periods prior to the date a particular subaccount commenced operations. Such performance information for the subaccounts will be calculated based on the performance of the various portfolios and the assumption that the subaccounts were in existence for the same periods as those indicated for the portfolios, with the level of policy charges that are currently in effect.

PUBLISHED RATINGS

The Company may from time to time publish in advertisements, sales literature and reports to owners, the ratings and other information assigned to it by one or more independent rating organizations such as A.M. Best Company, Standard & Poor’s Insurance Ratings Services, Moody’s Investors Service and Fitch Financial Ratings. The purpose of the ratings is to reflect the financial strength of the Company. The ratings should not be considered as bearing on the investment performance of assets held in the separate account or of the safety or riskiness of an investment in the separate account. Each year the A.M. Best Company reviews the financial status of thousands of insurers, culminating in the assignment of Best’s Ratings. These ratings reflect their current opinion of the relative financial strength and operating performance of an insurance company in comparison to the norms of the life/health insurance industry. In addition, these ratings may be referred to in advertisements or sales literature or in reports to owners. These ratings are opinions of an operating insurance company’s financial capacity to meet the obligations of its insurance policies in accordance with their terms.

STATE REGULATION OF TRANSAMERICA LIFE INSURANCE COMPANY

The Company is subject to the laws of Iowa governing insurance companies and to regulation by the Iowa Department of Insurance. An annual statement in a prescribed form is filed with the Department of Insurance each year covering the operation of the Company for the preceding year and its financial condition as of the end of such year. Regulation by the Department of Insurance includes periodic examination to determine the Company’s contract liabilities and reserves so that the Department may determine the items are correct. The Company’s books and accounts are subject to review by the Department of Insurance at all times, and a full examination of its operations is conducted periodically by the National Association of Insurance Commissioners. In addition, the Company is subject to regulation under the insurance laws of other jurisdictions in which it may operate.

ADMINISTRATION

The Company performs administrative services for the policies. These services include issuance of the policies, maintenance of records concerning the policies, and certain valuation services.

RECORDS AND REPORTS

All records and accounts relating to the separate account will be maintained by the Company. As presently required by the 1940 Act, as amended, and regulations promulgated thereunder, the Company will mail to all owners at their last known address of record, at least annually, reports containing such information as may be required under that Act or by any other applicable law or regulation. Owners will also receive confirmation of each financial transaction and any other

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reports required by law or regulation. However, for certain routine transactions (for example, regular monthly premiums deducted from your checking account, or regular annuity payments the Company sends to you) you may only receive quarterly confirmations.

DISTRIBUTION OF THE POLICIES

We have entered into a principal underwriting agreement with our affiliate, Transamerica Capital, Inc. (“TCI”), for the distribution and sale of the policies. We may reimburse TCI for certain expenses it incurs in order to pay for the distribution of the policies (e.g., commissions payable to selling firms selling the Policies, as described below.)

TCI’s home office is located at 4600 S Syracuse St. Suite 1100 Denver, Colorado 80237-2719. TCI is an indirect, wholly owned subsidiary of AEGON USA. TCI is registered as a broker-dealer with the Securities and Exchange Commission under the Securities Exchange Act of 1934, and is a member of Financial Industry Regulatory Authority (“FINRA”). TCI is not a member of the Securities Investor Protection Corporation.

We currently offer the policies on a continuous basis. We anticipate continuing to offer the policies, but reserve the right to discontinue the offering. The policies are offered to the public through sales representatives of broker-dealers (“selling firms”) that have entered into selling agreements with us and with TCI. TCI compensates these selling firms for their services. Sales representatives with these selling firms are appointed as our insurance agents.

We and our affiliates provide paid-in capital to TCI and pay for TCI’s operating and other expenses, including overhead, legal and accounting fees. We also pay TCI an “override” payment based on the pricing of the product which becomes part of TCI’s assets. In addition, we pay commission to TCI for policy sales; these commissions are passed through to the selling firms with TCI not retaining any portion of the commissions. During fiscal year 2010, 2009 and 2008 the amounts paid to TCI in connection with all policies sold through the separate account were $15,370,032, $10,346,777, and $11,193,398, respectively.

We and/or TCI or another affiliate may pay certain selling firms additional cash amounts for: (1) “preferred product” treatment of the policies in their marketing programs, which may include marketing services and increased access to their sales representatives; (2) sales promotions relating to the policies; (3) costs associated with sales conferences and educational seminars for their sales representatives; and (4) other sales expenses of the selling firms. We and/or TCI may make bonus payments to certain selling firms based on aggregate sales or persistency standards. These additional payments are not offered to all selling firms, and the terms of any particular agreement governing the payments may vary among selling firms.

VOTING RIGHTS

To the extent required by law, the Company will vote the underlying fund portfolios’ shares held by the separate account at regular and special shareholder meetings of the underlying fund portfolios in accordance with instructions received from persons having voting interests in the portfolios, although none of the underlying fund portfolios hold regular annual shareholder meetings. If, however, the 1940 Act or any regulation thereunder should be amended or if the present interpretation thereof should change, and as a result the Company determines that it is permitted to vote the underlying fund portfolios shares in its own right, it may elect to do so.

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Before the annuity commencement date, you hold the voting interest in the selected portfolios. The number of votes that you have the right to instruct will be calculated separately for each subaccount. The number of votes that you have the right to instruct for a particular subaccount will be determined by dividing your policy value in the subaccount by the net asset value per share of the corresponding portfolio in which the subaccount invests. Fractional shares will be counted.

After the annuity commencement date, the person receiving annuity payments has the voting interest, and the number of votes decreases as annuity payments are made and as the reserves for the policy decrease. The person’s number of votes will be determined by dividing the reserve for the policy allocated to the applicable subaccount by the net asset value per share of the corresponding portfolio. Fractional shares will be counted.

The number of votes that you or the person receiving income payments has the right to instruct will be determined as of the date established by the underlying fund portfolio for determining shareholders eligible to vote at the meeting of the underlying fund portfolio. The Company will solicit voting instructions by sending you, or other persons entitled to vote, requests for instructions prior to that meeting in accordance with procedures established by the underlying fund portfolio. Portfolio shares as to which no timely instructions are received, and shares held by the Company in which you, or other persons entitled to vote have no beneficial interest, will be voted in proportion to the voting instructions that are received with respect to all policies participating in the same subaccount.

Each person having a voting interest in a subaccount will receive proxy material, reports, and other materials relating to the appropriate portfolio.

OTHER PRODUCTS

The Company makes other variable annuity policies available that may also be funded through the separate account. These variable annuity policies may have different features, such as different investment choices or charges.

CUSTODY OF ASSETS

The Company holds assets of each of the subaccounts. The assets of each of the subaccounts are segregated and held separate and apart from the assets of the other subaccounts and from the Company’s general account assets. The Company maintains records of all purchases and redemptions of shares of the underlying fund portfolios held by each of the subaccounts. Additional protection for the assets of the separate account is afforded by the Company’s fidelity bond, presently in the amount of $5,000,000, covering the acts of officers and employees of the Company.

LEGAL MATTERS

Sutherland Asbill & Brennan LLP, of Washington D.C. has provided legal advice to the Company regarding to certain matters under the federal securities laws that relate to the policies.

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INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

The financial statements of the Separate Account VA C, at December 31, 2010 and for the periods disclosed in the financial statements, and the statutory-basis financial statements and schedules of Transamerica Life Insurance Company at December 31, 2010 and 2009 and for each of the three years in the period ended December 31, 2010, appearing herein, have been audited by Ernst & Young LLP, Suite 3000, 801 Grand Avenue, Des Moines, Iowa 50309, Independent Registered Public Accounting Firm, as set forth in their respective reports thereon appearing elsewhere herein, and are included in reliance upon their reports given on their authority as experts in accounting and auditing.

OTHER INFORMATION

A registration statement has been filed with the SEC, under the Securities Act of 1933 as amended, with respect to the policies discussed in this SAI. Not all of the information set forth in the registration statement and the amendments and exhibits thereto has been included in the prospectus or this SAI. Statements contained in the prospectus and this SAI concerning the content of the policies and other legal instruments are intended to be summaries. For a complete statement of the terms of these documents, reference should be made to the instruments filed with the SEC.

FINANCIAL STATEMENTS

The values of your interest in the separate account will be affected solely by the investment results of the selected subaccount(s). Financial statements of certain subaccounts of Separate Account VA C, which are available for investment by MEMBERS^® Extra^SM Variable Annuity policy owners, are contained herein. The statutory-basis financial statements and schedules of Transamerica Life Insurance Company, which are included in this SAI, should be considered only as bearing on the ability of the Company to meet its obligations under the policies. They should not be considered as bearing on the investment performance of the assets held in the separate account.

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APPENDIX

OA METHOD TRANSFERS

To make the Retirement Income Choice 1.2 Benefit available, we monitor your policy value and guarantees under the rider daily and periodically transfer amounts between your selected investment options and the OA Subaccount. We determine the amount and timing of OA Method transfers between the investment options and the OA Subaccount according to a mathematical model.

The mathematical model is designed to calculate how much of your policy value should be allocated to the OA Subaccount. Based on this calculation, transfers into or out of the OA Subaccount will occur (subject to the previously disclosed thresholds). The formula is:

Percent of Policy Value required in OA Subaccount (or X) = e^{-Dividend*Time} *(1- NormDist(d1))

where:

e	=	Base of the Natural Logarithm
NormDist	=	Cumulative Standard Normal Distribution
d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

In order to calculate the percent of policy value required in the OA Subaccount, we must first calculate d1:

d1 = [ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

where:

ln	=	Natural Logarithm Function
G	=	Guarantee Ratio
R	=	Rate
F	=	Fees
V	=	Volatility
T	=	Time

After calculating d1, the percent of policy value required in the OA Subaccount can be calculated. Once calculated, appropriate transfers into or out of the OA Subaccount will occur (subject to the thresholds).

Following is a brief discussion of the values used in the formula.

The POLICY VALUE includes the value in both the investment options and in the OA Subaccount.

The GUARANTEE RATIO is the policy value divided by the greater of (1) premiums minus any adjusted partial withdrawals or (2) present value of rider withdrawal amount (the present value of the rider amount looks at the sum of the expected lifetime payments discounted using a factor of [5.5]).

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OA METHOD TRANSFERS — (Continued)

The RATE is the interest rate used for the OA Method. It is based on a long-term expectation based on historical interest rates and may vary over time.

The FEES is an approximation of average policy fees and charges associated with policies that have elected the RIC 1.2 rider. This value may change over time.

The VOLATILITY represents the volatility of the returns of policy value for all in force policies and is based on the long-term expectation of the degree to which the policy values tend to fluctuate. This value may vary over time.

The TIME is an approximation based on actuarial calculations of historical average number of years (including any fraction) which we anticipate remain until any potential payments are made under the benefit. This value may vary over time.

The PERCENT OF POLICY VALUE TO BE ALLOCATED TO THE OA SUBACCOUNT is computed for each policy. Ultimately the allocation for a policy takes into account the guarantees under the rider and the limit on allocations to the OA Subaccount.

The CUMULATIVE STANDARD NORMAL DISTRIBUTION function assumes that random events are distributed according to the classic bell curve. For a given value it computes the percentage of such events which can be expected to be less than that value.

The NATURAL LOGARITHM function for a given value, computes the power to which e must be raised, in order to result in that value. Here, e is the base of the natural logarithms, or approximately 2.718282.

Example:

Day 1: Policy Value Declines by 10%

For purposes of this example we will assume that the policy value declines by 10% to $90,000, the day after the rider issue date from the initial premium amount of $100,000 producing a guarantee ratio of 90% ($90,000/$100,000) invoking an OA transfer. We will also assume:

Guarantee Ratio	=	90%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	15%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.90)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.658832

27

OA METHOD TRANSFERS — (Continued)

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1-NormDist(d1)))

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(.658832)))
DOA	=	min(20%, 13.9948%)
DOA	=	13.9948%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the lower threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	max (0, DOA - (OA% = FA% / 3)
X	=	max (0, 13.9948% - (0% = 15% / 3)
X	=	max (0, 13,9948% - 5%)
X	=	8.9948%

Therefore, 8.9948% of the policy value is transferred to the OA Subaccount, resulting in a total transfer of $8,095.32.

Day 2: Policy Value Recovers to 95% of Initial Value after the 10% Decline

For purposes of this example we will assume that after the policy value declined to $90,000, it recovered the next day to $95,000 producing a guarantee ratio of 95% ($95,000/$100,000) and invoking an OA transfer. We will also assume:

Guarantee Ratio	=	95%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	14%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%
Percentage of policy value in OA Subaccount	=	8%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.95)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.779732

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

28

OA METHOD TRANSFERS — (Continued)

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1 - NormDist(d1)))

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(.779732)))
DOA	=	min(20%, 11.9517%)
DOA	=	11.9517%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the upper threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	min (OA%, max(0, OA% = FA% / 3 - DOA%))
X	=	min(8%, max(0, 8% + 14% / 3 - 11.9517%))
X	=	min(8%, max(0, 0.714967%))
X	=	0.714967%

Therefore, due to the policy value recovery, 0.714967% of the policy value will be transferred out of the OA Subaccount pro rata back into their current investment options, resulting in a total transfer of $679.22.

Day 3: Policy Value further recovers to 105% of Initial Value

For purposes of this example we will assume that after the policy value recovered to $95,000, it further recovered the next day to $105,000 producing a guarantee ratio of 105% ($105,000/$100,000) and invoking an OA transfer. We will also assume:

Guarantee Ratio	=	105%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20
Percentage of policy value in fixed account	=	13%
Maximum percentage of policy value in OA Subaccount at time of transfer	=	20%
Percentage of policy value in OA Subaccount	=	6%

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(1.05)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	1.003524

Using the value we just calculated for d1, we can now calculate the percent of policy value required in the OA Subaccount.

Percent of Policy Value desired in OA Subaccount (or DOA) = min(MAX2OA%, e^{-Dividend*Time} *(1 - NormDist(d1)))

29

OA METHOD TRANSFERS — (Continued)

DOA	=	min(.20, (2.718282 ^ -.03 * 20) * (1 – NormDist(1.003524)))
DOA	=	min(20%, 8.6605%)
DOA	=	8.6605%

This percentage gets adjusted if either there is money already in the OA Subaccount or if there is money in the fixed account. When the GR% crosses the upper threshold as in this situation, the ultimate OA transfer percentage is calculated as follows:

X	=	min (OA%, max(0, OA% = FA% / 3 - DOA%))
X	=	min(6%, max(0, 6% + 13% / 3 - 8.6605%))
X	=	min(6%, max(0, 1.67283%))
X	=	1.67283%>

While the mathematical model would suggest we transfer only a portion of the policy value in the OA Subaccount into your investment options (leaving 4.32717% (6% - 1.67283%) in the OA Subaccount), all of the policy value in the OA Subaccount will be transferred into your investment options. If the Guarantee Ratio equals or exceeds 100%, then your policy value is greater than or equal to the value of the guarantee and there is no current need for any policy value to be allocated to the OA Subaccount.

30

APPENDIX

PAM METHOD TRANSFERS

To make the Living Benefits Rider available, we monitor your policy value and guarantees under the rider daily and periodically transfer amounts between your selected investment options and the PAM Subaccount. We determine the amount and timing of PAM Method transfers between the investment options and the PAM Subaccount according to a mathematical model.

The mathematical model is designed to calculate how much of your policy value should be allocated to the PAM Subaccount. Based on this calculation, transfers into or out of the PAM Subaccount will occur. The formula is:

Percent of Policy Value required in PAM Subaccount (or X) =

e^{-Dividend*Time} *(1- NormDist(d1))

where:

e	=	Base of the Natural Logarithm
NormDist	=	Cumulative Standard Normal Distribution
d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

In order to calculate the percent of policy value required in the PAM Subaccount, we must first calculate d1:

d1 = [ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

where:

ln	=	Natural Logarithm Function
	=	Guarantee Ratio
R	=	Rate
F	=	Fees
V	=	Volatility
T	=	Time

After calculating d1, the percent of policy value required in the PAM Subaccount can be calculated. Once calculated, appropriate transfers into or out of the PAM Subaccount will occur.

Following is a brief discussion of the values used in the formula.

The POLICY VALUE includes the value in both the investment options and in the PAM Subaccount.

The GUARANTEE RATIO is the policy value divided by 7% “Principal Back” Minimum Remaining Withdrawal Amount.

31

PAM METHOD TRANSFERS — (Continued)

The RATE is the interest rate used for the PAM Method. It is based on a long-term expectation based on historical interest rates and may vary over time.

The FEES is an approximation of average policy fees and charges associated with policies that have elected the Living Benefits Rider. This value may change over time.

The VOLATILITY represents the volatility of the returns of policy value for all in force policies and is based on the long-term expectation of the degree to which the policy values tend to fluctuate. This value may vary over time.

The TIME is an approximation based on actuarial calculations of historical average number of years (including any fraction) which we anticipate remain until any potential payments are made under the benefit. This value may vary over time.

The PERCENT OF POLICY VALUE TO BE ALLOCATED TO THE PAM SUBACCOUNT is computed for each policy. Ultimately the allocation for a policy takes into account the guarantees under the rider and the limit on allocations to the PAM Subaccount.

The CUMULATIVE STANDARD NORMAL DISTRIBUTION function assumes that random events are distributed according to the classic bell curve. For a given value it computes the percentage of such events which can be expected to be less than that value.

The NATURAL LOGARITHM function for a given value, computes the power to which e must be raised, in order to result in that value. Here, e is the base of the natural logarithms, or approximately 2.718282.

Example:

Day 1: Policy Value Declines by 10%

For purposes of this example we will assume that the policy value declines by 10% to $90,000 the day after the rider issue date from the initial premium amount of $100,000 producing a guarantee ratio of 90% ($90,000/$100,000). We will also assume:

Guarantee Ratio	=	90%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(.90)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	.658832

32

PAM METHOD TRANSFERS — (Continued)

Using the value we just calculated for d1 we can now calculate the percent of policy value required in the PAM Subaccount.

Percent of Policy Value in PAM Subaccount (or X) = e^{-Dividend*Time} *(1-NormDist(d1))

X	=	(2.718282 ^ -.03 * 20) * (1 – NormDist(.658832))
X	=	13.9948%

Therefore, 13.9948% of the policy value is transferred to the PAM Subaccount, resulting in a total transfer of $12,595.32.

Day 2: Policy Value Recovers to 105% of Initial Value after the 10% Decline

For purposes of this example we will assume that after the policy value declined to $90,000 it recovered the next day to $105,000 producing a guarantee ratio of 105% ($105,000/$100,000). We will also assume:

Guarantee Ratio	=	105%
Rate	=	4.5%
Volatility	=	10%
Fees	=	3%
Time	=	20

First we calculate d1.

d1	=	[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]
d1	=	[ln(1.05)+(.045 – .03 +.5*.10 ^ 2)* 20]/[.10 * 20^.5]
d1	=	1.003524

Using the value we just calculated for d1 we can now calculate the percent of policy value required in the PAM Subaccount.

Percent of Policy Value in PAM Subaccount (or X) = e^{-Dividend*Time} *(1 - NormDist(d1))

X = (2.718282 ^ -.03 * 20) * (1 – NormDist(1.003524))

X = 8.6605%

While the mathematical model would suggest we transfer only a portion of the policy value in the PAM Subaccount into your investment options (leaving 8.6605% in the PAM Subaccount), all of the policy value in the PAM Subaccount will be transferred into your investment options. If the Guarantee Ratio equals or exceeds 100%, then your policy value is greater than or equal to the value of the guarantee and there is no current need for any policy value to be allocated to the PAM Subaccount.

33

FINANCIAL STATEMENTS AND SCHEDULES – STATUTORY BASIS

Transamerica Life Insurance Company

Years Ended December 31, 2010, 2009 and 2008

Transamerica Life Insurance Company

Financial Statements and Schedules – Statutory Basis

Years Ended December 31, 2010, 2009 and 2008

Contents

Report of Independent Registered Public Accounting Firm	1
Audited Financial Statements
Balance Sheets – Statutory Basis	3
Statements of Operations – Statutory Basis	5
Statements of Changes in Capital and Surplus – Statutory Basis	7
Statements of Cash Flow – Statutory Basis	10
Notes to Financial Statements – Statutory Basis	12
Statutory-Basis Financial Statement Schedules
Summary of Investments – Other Than Investments in Related Parties	117
Supplementary Insurance Information	118
Reinsurance	119

Report of Independent Registered Public Accounting Firm

The Board of Directors

Transamerica Life Insurance Company

We have audited the accompanying statutory-basis balance sheets of Transamerica Life Insurance Company (the Company) as of December 31, 2010 and 2009, and the related statutory-basis statements of operations, changes in capital and surplus, and cash flow for each of the three years in the period ended December 31, 2010. Our audits also included the statutory-basis financial statement schedules required by Regulation S-X, Article 7. These financial statements and schedules are the responsibility of the Company’s management. Our responsibility is to express an opinion on these financial statements and schedules based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. We were not engaged to perform an audit of the Company’s internal control over financial reporting. Our audits included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

As described in Note 1 to the financial statements, the Company presents its financial statements in conformity with accounting practices prescribed or permitted by the Insurance Division, Department of Commerce, of the State of Iowa, which practices differ from U.S. generally accepted accounting principles. The variances between such practices and U.S. generally accepted accounting principles also are described in Note 1. The effects on the financial statements of these variances are not reasonably determinable but are presumed to be material.

In our opinion, because of the effects of the matter described in the preceding paragraph, the financial statements referred to above do not present fairly, in conformity with U.S. generally accepted accounting principles, the financial position of Transamerica Life Insurance Company at December 31, 2010 and 2009, or the results of its operations or its cash flow for each of the three years in the period ended December 31, 2010.

1

However, in our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of Transamerica Life Insurance Company at December 31, 2010 and 2009, and the results of its operations and its cash flow for each of the three years in the period ended December 31, 2010, in conformity with accounting practices prescribed or permitted by the Insurance Division, Department of Commerce, of the State of Iowa. Also, in our opinion, the related financial statement schedules, when considered in relation to the basic statutory-basis financial statements taken as a whole, present fairly in all material respects the information set forth therein.

As discussed in Note 1 to the financial statements, in 2010, 2009, and 2008 in response to new accounting standards, the Company changed its method of accounting for collateral received related to certain financial transactions, deferred income taxes, and investments in loan-backed and structured securities. Also, as discussed in Notes 2 and 3 to the financial statements, at December 31, 2008 the Company, with the permission of the Insurance Division, Department of Commerce, of the State of Iowa, changed its policy for deferred income taxes and its calculation of reserves related to synthetic guaranteed investment contracts.

/s/ Ernst & Young LLP

Des Moines, Iowa

April 8, 2011

2

Transamerica Life Insurance Company

Balance Sheets – Statutory Basis

(Dollars in Thousands, Except per Share Amounts)

	December 31
	2010		2009
Admitted assets
Cash and invested assets:
Cash, cash equivalents and short-term investments	$	1,573,081	$	3,912,309
Bonds:
Affiliated entities		70,527		126,306
Unaffiliated		46,921,343		47,035,463
Preferred stocks:
Affiliated entities		7,162		7,632
Unaffiliated		123,925		152,661
Common stocks:
Affiliated entities (cost: 2010 - $666,018; 2009 - $681,297)		714,092		657,018
Unaffiliated (cost: 2010 - $307,132; 2009 - $360,043)		358,631		389,485
Mortgage loans on real estate		8,107,498		9,357,158
Real estate, at cost less accumulated depreciation (2010 - $55,396; 2009 - $52,214)
Home office properties		79,699		83,938
Investment properties		34,776		35,618
Properties held for sale		6,490		6,250
Policy loans		746,677		759,957
Receivables for securities		20,071		11,395
Securities lending reinvested collateral assets		3,956,880		—
Derivatives		107,125		105,704
Collateral balance		4,142		22,733
Other invested assets		2,460,490		2,590,207
Total cash and invested assets		65,292,609		65,253,834
Accrued investment income		542,992		567,326
Cash surrender value of life insurance policies		300,248		289,559
Premiums deferred and uncollected		223,886		280,202
Current federal income tax recoverable		222,917		288,946
Net deferred income tax asset		792,408		649,556
Reinsurance receivable		255,184		300,991
Receivable from parent, subsidiaries and affiliates		248,839		187,751
Accounts receivable		264,844		171,140
General agents pension fund		43,422		43,136
Reinsurance deposit receivable		146,715		137,437
Amounts incurred under modified coinsurance agreement		61,400		60,443
Goodwill		94,551		52,124
Other assets		25,709		27,654
Separate account assets		38,370,952		33,205,532
Total admitted assets	$	106,886,676	$	101,515,631

3

	December 31
	2010			2009
Liabilities and capital and surplus
Liabilities:
Aggregate reserves for policies and contracts:
Life	$	15,035,676		$	14,924,136
Annuity		17,990,509			19,080,480
Accident and health		3,418,734			3,317,854
Policy and contract claim reserves:
Life		306,384			325,407
Accident and health		210,969			194,930
Liability for deposit-type contracts		6,496,776			8,259,686
Other policyholders’ funds		20,473			21,006
Municipal reverse repurchase agreements		200,977			632,109
Remittances and items not allocated		417,545			507,629
Case level liability		7,415			13,236
Payable for derivative cash collateral		240,374			—
Asset valuation reserve		896,004			868,688
Interest maintenance reserve		1,045,860			203,669
Funds held under reinsurance treaties		13,184,805			14,073,538
Reinsurance in unauthorized reinsurers		7,055			11,969
Commissions and expense allowances payable on reinsurance assumed		62,485			61,500
Payable to affiliates		476,976			270,421
Payable for securities		4,366			68,822
Payable for securities lending		3,956,880			—
Transfers from separate accounts due or accrued (including $(547,780) and $(365,239) accrued for expense allowances recognized in reserves, net of reinsurance allowances at December 31, 2010 and 2009, respectively)		(512,837	)		(474,775	)
Amounts withheld or retained		169,393			169,294
Derivatives		221,171			357,733
Other liabilities		430,488			455,899
Separate account liabilities		38,300,074			33,145,575
Total liabilities		102,588,552			96,488,806
Capital and surplus:
Common stock, $10 per share par value, 1,000,000 shares authorized, 676,190 issued and outstanding at December 31, 2010 and 2009		6,762			6,762
Preferred stock, Series A, $10 per share par value, 42,500 shares authorized and issued (total liquidation value - $58,000) at December 31, 2010 and 2009; Series B, $10 per share par value, 250,000 shares authorized, 117,154 shares issued and 117,154 shares outstanding (total liquidation value -$1,171,540) at December 31, 2010 and 2009.		1,597			1,597
Treasury stock, Series A Preferred, $10 per share par value, 42,500 shares as of December 31, 2010 and 2009		(58,000	)		(58,000	)
Aggregate write-ins for other than special surplus funds		554,923			295,260
Surplus notes		150,000			150,000
Paid-in surplus		3,117,153			3,113,948
Unassigned surplus		525,689			1,517,258
Total capital and surplus		4,298,124			5,026,825
Total liabilities and capital and surplus	$	106,886,676		$	101,515,631

See accompanying notes.

4

Transamerica Life Insurance Company

Statements of Operations – Statutory Basis

(Dollars in Thousands)

	Year Ended December 31
	2010			2009			2008
							Restated
Revenues:
Premiums and other considerations, net of reinsurance:
Life	$	1,523,920		$	1,409,443		$	2,111,417
Annuity		6,931,132			5,997,868			4,700,329
Accident and health		710,067			692,821			706,198
Net investment income		2,919,171			3,073,157			3,886,926
Amortization of interest maintenance reserve		3,906			(11,138	)		29,315
Commissions and expense allowances on reinsurance ceded		892,482			844,831			(325,830	)
Income from fees associated with investment management, administration and contract guarantees for separate accounts		380,170			376,545			399,445
Reserve adjustment on reinsurance ceded		(351,287	)		(479,868	)		10,430,740
Consideration on reinsurance transaction		—			107			16,542
Income from administrative service agreement with affilate		51,177			40,040			44,122
Other income		85,480			92,279			16,005
		13,146,218			12,036,085			22,015,209
Benefits and expenses:
Benefits paid or provided for:
Life benefits		1,133,801			1,077,203			1,028,573
Accident and health benefits		496,368			436,567			492,379
Annuity benefits		1,084,962			1,304,213			1,597,820
Surrender benefits		6,208,241			4,979,209			7,773,476
Other benefits		215,848			142,045			742,343
Increase (decrease) in aggregate reserves for policies and contracts:
Life		51,172			(236,536	)		19,920
Annuity		(1,017,181	)		(4,337,005	)		(3,440,891	)
Accident and health		100,880			129,917			124,958
		8,274,091			3,495,613			8,338,578
Insurance expenses:
Commissions		1,440,391			1,315,400			1,445,898
General insurance expenses		764,037			636,705			683,967
Taxes, licenses and fees		72,666			102,602			147,885
Net transfers to separate accounts		1,664,131			2,009,163			800,973
Change in case level liability		(5,821	)		(525	)		(6,800	)
Consideration paid on reinsurance transactions		—			3,476,850			11,319,684
Other expenses		722,360			400,113			292,871
		4,657,764			7,940,308			14,684,478
Total benefits and expenses		12,931,855			11,435,921			23,023,056
Gain (loss) from operations before dividends to policyholders, federal income tax benefit and net realized capital gains (losses) on investments	$	214,363		$	600,164		$	(1,007,847	)

5

Transamerica Life Insurance Company

Statements of Operations – Statutory Basis (continued)

(Dollars in Thousands)

	Year Ended December 31
	2010			2009			2008
							Restated
Dividends to policyholders	$	10,074		$	11,010		$	12,165
Gain (loss) from operations before federal income tax benefit and net realized capital gains (losses) on investments		204,289			589,154			(1,020,012	)
Federal income tax benefit		(270,228	)		(104,942	)		(32,376	)
Gain (loss) from operations before net realized capital gains (losses) on investments		474,517			694,096			(987,636	)
Net realized capital gains (losses) on investments (net of related federal income taxes and amounts transferred to/from interest maintenance reserve)		(56,838	)		(700,521	)		366,218
Net income (loss)	$	417,679		$	(6,425	)	$	(621,418	)

See accompanying notes.

6

Transamerica Life Insurance Company

Statements of Changes in Capital and Surplus – Statutory Basis

(Dollars in Thousands)

	Common Stock			Preferred Stock		Treasury Stock			Aggregate Write-ins for Other than Special Surplus Funds		Participating Shareholders’ Surplus			Surplus Notes		Paid-in Surplus			Unassigned Surplus			Total Capital and Surplus
Balance at January 1, 2008, as restated	$	6,765		$	2,170	$	(631,400	)	$	—	$	2,002		$	150,000	$	2,694,296		$	2,121,268		$	4,345,101
Net loss		—			—		—			—		—			—		—			(621,418	)		(621,418	)
Change in net unrealized capital gains/losses, net of tax		—			—		—			—		—			—		—			(337,437	)		(337,437	)
Change in net unrealized foreign exchange capital gains/losses, net of tax		—			—		—			—		—			—		—			(20,767	)		(20,767	)
Change in net deferred income tax asset		—			—		—			—		—			—		—			(208,565	)		(208,565	)
Change in other nonadmitted assets		—			—		—			—		—			—		—			(85,798	)		(85,798	)
Change in provision for reinsurance in unauthorized companies		—			—		—			—		—			—		—			19,970			19,970
Change in reserve on account of change in valuation basis		—			—		—			—		—			—		—			35,039			35,039
Change in asset valuation reserve		—			—		—			—		—			—		—			255,123			255,123
Change in surplus in separate accounts		—			—		—			—		—			—		—			(40,108	)		(40,108	)
Reinsurance transactions		—			—		—			—		—			—		—			962,518			962,518
Increase in admitted deferred tax due to permitted practice		—			—		—			380,358		—			—		—			—			380,358
Correction of interest on taxes																				(969	)		(969	)
Dividends to stockholders		—			—		—			—		—			—		—			(316,438	)		(316,438	)
Change in deferred premiums associated with reserve valuation change		—			—		—			—		—			—		—			(17,488	)		(17,488	)
Return of capital related to stock rights plan of indirect parent		—			—		—			—		—			—		(14,543	)		—			(14,543	)
Capital contribution		—			—		—			—		—			—		507,239			—			507,239
Redemption of participating common stock		(1	)		—		—			—		(1,681	)		—		(1	)		—			(1,683	)
Participating shareholder activity		—			—		—			—		57			—		—			(57	)		—
Balance at December 31, 2008, as restated	$	6,764		$	2,170	$	(631,400	)	$	380,358	$	378		$	150,000	$	3,186,991		$	1,744,873		$	4,840,134

7

Transamerica Life Insurance Company

Statements of Changes in Capital and Surplus – Statutory Basis (continued)

(Dollars in Thousands)

	Common Stock			Preferred Stock			Treasury Stock			Aggregate Write-ins for Other than Special Surplus Funds			Participating Shareholders’ Surplus			Surplus Notes		Paid-in Surplus			Unassigned Surplus			Total Capital and Surplus
Balance at December 31, 2008, as restated	$	6,764		$	2,170		$	(631,400	)	$	380,358		$	378		$	150,000	$	3,186,991		$	1,744,873		$	4,840,134
Cumulative effect of change in accounting principle		—			—			—			—			—			—		—			(9,707	)		(9,707	)
Net loss		—			—			—			—			—			—		—			(6,425	)		(6,425	)
Change in net unrealized capital gains/losses, net of tax		—			—			—			—			—			—		—			(381,912	)		(381,912	)
Change in net unrealized foreign exchange gains/losses, net of tax		—			—			—			—			—			—		—			11,139			11,139
Change in net deferred income tax asset		—			—			—			—			—			—		—			(169,940	)		(169,940	)
Change in other nonadmitted assets		—			—			—			—			—			—		—			(170,812	)		(170,812	)
Change in provision for reinsurance in unauthorized companies		—			—			—			—			—			—		—			34,966			34,966
Change in reserve on account of change in valuation basis		—			—			—			—			—			—		—			(31,058	)		(31,058	)
Change in asset valuation reserve		—			—			—			—			—			—		—			398,394			398,394
Change in surplus in separate accounts		—			—			—			—			—			—		—			13,315			13,315
Reinsurance transactions		—			—			—			—			—			—		—			71,455			71,455
Decrease in admitted deferred tax attributable to expiration of permitted practice		—			—			—			(380,358	)		—			—		—			—			(380,358	)
Increase in admitted deferred tax asset to SSAP No. 10R		—			—			—			295,260			—			—		—			—			295,260
Corrections of errors		—			(573	)		573,400			—			—			—		(572,827	)		(898	)		(898	)
Dividends to stockholders		—			—			—			—			—			—		—			(10,031	)		(10,031	)
Return of capital related to stock rights plan of indirect parent		—			—			—			—			—			—		(214	)		—			(214	)
Dissolution of affiliate into the Company		—			—			—			—			—			—		—			23,938			23,938
Capital contribution		—			—			—			—			—			—		500,000			—			500,000
Redemption of participating common stock		(2	)		—			—			—			(417	)		—		(2	)		—			(421	)
Participating shareholder activity		—			—			—			—			39			—		—			(39	)		—
Balance at December 31, 2009	$	6,762		$	1,597		$	(58,000	)	$	295,260		$	—		$	150,000	$	3,113,948		$	1,517,258		$	5,026,825

8

Transamerica Life Insurance Company

Statements of Changes in Capital and Surplus – Statutory Basis (continued)

(Dollars in Thousands)

	Common Stock		Preferred Stock		Treasury Stock			Aggregate Write-ins for Other than Special Surplus Funds		Surplus Notes		Paid-in Surplus		Unassigned Surplus			Total Capital  and Surplus
Balance at December 31, 2009	$	6,762	$	1,597	$	(58,000	)	$	295,260	$	150,000	$	3,113,948	$	1,517,258			5,026,825
Cumulative effect of change in accounting principle		—		—		—			—		—		—		6,403			6,403
Net income		—		—		—			—		—		—		417,679			417,679
Change in net unrealized capital gains/losses, net of tax		—		—		—			—		—		—		153,857			153,857
Change in net unrealized foreign exchange capital gains/losses, net of tax		—		—		—			—		—		—		7,912			7,912
Change in net deferred income tax asset		—		—		—			—		—		—		(207,877	)		(207,877	)
Change in other nonadmitted assets		—		—		—			—		—		—		109,110			109,110
Change in provision for reinsurance in unauthorized companies		—		—		—			—		—		—		4,914			4,914
Change in reserve on account of change in valuation basis		—		—		—			—		—		—		119			119
Change in asset valuation reserve		—		—		—			—		—		—		(27,316	)		(27,316	)
Change in surplus in separate accounts		—		—		—			—		—		—		10,366			10,366
Long-term incentive compensation		—		—		—			—		—		3,205		—			3,205
Reinsurance transactions		—		—		—			—		—		—		(64,348	)		(64,348	)
Increase in admitted deferred tax asset pursuant to SSAP No. 10R		—		—		—			259,663		—		—		—			259,663
Dividends to stockholders		—		—		—			—		—		—		(1,400,000	)		(1,400,000	)
Change in deferred premium due to valuation adjustment		—		—		—			—		—		—		(2,388	)		(2,388	)
Balance at December 31, 2010	$	6,762	$	1,597	$	(58,000	)	$	554,923	$	150,000	$	3,117,153	$	525,689		$	4,298,124

See accompanying notes.

9

Transamerica Life Insurance Company

Statements of Cash Flow – Statutory Basis

(Dollars in Thousands)

	Year Ended December 31
	2010			2009			2008
							Restated
Operating activities
Premiums collected, net of reinsurance	$	9,222,197		$	7,981,888		$	7,620,124
Net investment income received		2,985,106			3,266,446			4,386,609
Miscellaneous income (expense)		569,910			(127,792	)		914,930
Benefit and loss related payments		(9,022,576	)		(8,847,466	)		(11,345,127	)
Net transfers to separate accounts		(1,709,930	)		(1,776,576	)		(238,756	)
Commissions, expenses paid and aggregate write-ins for deductions		(2,756,812	)		(5,957,821	)		(3,225,421	)
Dividends paid to policyholders		(10,559	)		(11,386	)		(13,295	)
Federal and foreign income taxes recovered (paid)		(113,355	)		391,699			(398,359	)
Net cash used in operating activities		(836,019	)		(5,081,008	)		(2,299,295	)
Investing activities
Proceeds from investments sold, matured or repaid:
Bonds		24,609,623			16,975,896			19,888,559
Common stocks		167,903			141,360			131,682
Preferred stocks		143,250			100,705			439,153
Mortgage loans		1,270,379			1,682,140			1,146,455
Real estate and properties held for sale		1,316			24,100			49,453
Other invested assets		693,425			560,339			2,592,998
Receivable for securities		(66,950	)		78,827			18,350
Miscellaneous proceeds		112,803			266,646			61,311
Total investment proceeds		26,931,749			19,830,013			24,327,961
Costs of investments acquired:
Bonds		(23,107,917	)		(11,629,415	)		(20,039,680	)
Common stocks		(96,764	)		(92,767	)		(440,692	)
Preferred stocks		(112,885	)		(115,980	)		(355,870	)
Mortgage loans		(38,062	)		(231,832	)		(398,019	)
Real estate and properties held for sale		(350	)		(1,100	)		(11,405	)
Other invested assets		(4,437,589	)		(296,564	)		(1,819,475	)
Payable for securities		—			—			(131,194	)
Miscellaneous applications		(227,105	)		(451,760	)		(278,394	)
Total cost of investments acquired		(28,020,672	)		(12,819,418	)		(23,474,729	)
Net decrease (increase) in policy loans		13,279			(27,369	)		(41,733	)
Net cost of investments acquired		(28,007,393	)		(12,846,787	)		(23,516,462	)
Net cash (used in) provided by investing activities		(1,075,644	)		6,983,226			811,499

10

Transamerica Life Insurance Company

Statements of Cash Flow – Statutory Basis (continued)

(Dollars in Thousands)

	Year Ended December 31
	2010			2009			2008
							Restated
Financing and miscellaneous activities
Net withdrawals on deposit-type contract funds and other liabilities without life or disability contingencies	$	(1,839,672	)	$	(5,137,903	)	$	(735,535	)
Funds held under reinsurance treaties with unauthorized reinsurers		(892,010	)		1,942,945			4,819,583
Dividends paid to stockholders		(1,400,000	)		(10,031	)		(316,438	)
Redemption of participating shareholders		—			(421	)		(1,683	)
Capital contribution received		—			500,000			507,239
Receivable from parent, subsidiaries and affiliates		(61,088	)		29,728			64,157
Payable to parent, subsidiaries and affiliates		206,555			25,557			(96,126	)
Payable for securities lending		3,956,880			—			—
Other cash provided (used)		(398,230	)		1,301,648			(1,250,156	)
Net cash provided by (used in) financing and miscellaneous activities		(427,565	)		(1,348,477	)		2,991,041
Net increase (decrease) in cash, cash equivalents and short-term investments		(2,339,228	)		553,741			1,503,245
Cash, cash equivalents and short-term
investments:
Beginning of year		3,912,309			3,358,568			1,855,323
End of year	$	1,573,081		$	3,912,309		$	3,358,568

See accompanying notes.

11

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

December 31, 2010

1. Organization and Summary of Significant Accounting Policies

Transamerica Life Insurance Company (the Company) is a stock life insurance company owned by Transamerica Corporation (74.01% of preferred shares), AEGON USA, LLC (25.99% of preferred shares), and Transamerica International Holdings, Inc. (100% of common shares). Prior to the mergers discussed below, the Company was owned by AEGON USA, LLC (100% of preferred shares) and Transamerica Occidental Life Insurance Company (100% of common shares). Transamerica Corporation (Transamerica), AEGON USA, LLC (AEGON), Transamerica International Holdings, Inc. (TIHI) and Transamerica Occidental Life Insurance Company (TOLIC) are indirect wholly-owned subsidiaries of AEGON N.V., a holding company organized under the laws of The Netherlands.

On October 1, 2009, the Company completed a merger with Iowa Fidelity Life Insurance Company (IFLIC), which was wholly owned by AEGON. Prior to the merger, IFLIC was partially owned by external shareholders holding 1,500 shares of participating common stock. All shares of participating common stock were redeemed prior to the merger in exchange for cash in the amount of $421. The merger was accounted for in accordance with Statement of Statutory Accounting Principles (SSAP) No. 68, Business Combinations and Goodwill, as a statutory merger. As such, financial statements for periods prior to the merger were combined and the recorded assets, liabilities and surplus of IFLIC were carried forward to the merged company. As a result of the merger, IFLIC’s common stock was deemed cancelled by operation of law and the outstanding common shares of IFLIC, on the date of the merger, were retired and considered authorized but unissued stock of the merged entity.

In exchange for its agreement to merge IFLIC into the Company, AEGON received 149 shares of the Company’s Series B preferred shares which are equal in value to the common stock of IFLIC deemed cancelled by the merger.

On October 1, 2008, the Company completed a merger with TOLIC, which was directly owned by TIHI (100% of common shares) and Transamerica (100% of preferred shares). On October 2, 2008, the Company completed a merger with Life Investors Insurance Company of America (LIICA), which was wholly owned by AEGON. The mergers were accounted for in accordance with SSAP No. 68, as statutory mergers. As such, financial statements for periods prior to the merger were combined and the recorded assets, liabilities and surplus of TOLIC and LIICA were carried forward to the merged company. As a result of the merger, TOLIC and LIICA’s common and preferred stock were deemed cancelled by operation of law and the outstanding common shares of the Company, on the date of the merger, were retired and considered authorized but unissued stock of the merged entity.

12

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

In exchange for its agreement to merge TOLIC into the Company, TIHI received common stock of the Company equal in value to the common stock of TOLIC deemed cancelled by the merger and Transamerica received Series B preferred stock of the Company equal in value to the Series B preferred stock of TOLIC deemed cancelled by the merger.

Specifically, TIHI received 676,190 shares of the Company’s common shares, and Transamerica received 86,590 shares of the Company’s Series B preferred shares. In exchange for its agreement to merge LIICA into the Company, AEGON received common stock of TIHI equal in value to the common stock of LIICA deemed cancelled by the merger. Specifically, AEGON received 18 shares of TIHI’s common shares.

Nature of Business

The Company sells individual non-participating whole life, endowment and term contracts, structured settlements, pension products and reinsurance, as well as a broad line of single fixed and flexible premium annuity products, guaranteed interest contracts and funding agreements. In addition, the Company offers group life, universal life, credit life, and individual and specialty health coverages. The Company is licensed in 49 states and the District of Columbia, Guam, Puerto Rico and US Virgin Islands. Sales of the Company’s products are primarily through a network of agents, brokers and financial institutions.

Basis of Presentation

The preparation of financial statements of insurance companies requires management to make estimates and assumptions that affect amounts reported in the financial statements and accompanying notes. Such estimates and assumptions could change in the future as more information becomes known, which could impact the amounts reported and disclosed herein.

The accompanying financial statements have been prepared in conformity with accounting practices prescribed or permitted by the Insurance Division, Department of Commerce, of the State of Iowa, which practices differ from accounting principles generally accepted in the United States (GAAP). The more significant variances from GAAP are:

13

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Investments: Investments in bonds and mandatory redeemable preferred stocks are reported at amortized cost or fair value based on their National Association of Insurance Commissioners (NAIC) rating; for GAAP, such fixed maturity investments would be designated at purchase as held-to-maturity, trading or available-for-sale. Held-to-maturity fixed investments would be reported at amortized cost, and the remaining fixed maturity investments would be reported at fair value with unrealized holding gains and losses reported in operations for those designated as trading and as a separate component of other comprehensive income (OCI) for those designated as available-for-sale. Fair value for GAAP is based on indexes, third party pricing services, brokers, external fund managers and internal models. For statutory reporting, the NAIC allows insurance companies to report the fair value determined by the Securities Valuation Office of the NAIC (SVO) or determine the fair value by using a permitted valuation method.

All single class and multi-class mortgage-backed/asset-backed securities (e.g., CMOs) are adjusted for the effects of changes in prepayment assumptions on the related accretion of discount or amortization of premium of such securities using either the retrospective or prospective methods. If the fair value of the mortgage-backed/asset-backed security is less than amortized cost, an entity shall assess whether the impairment is other-than-temporary. An other-than-temporary impairment is considered to have occurred if the discounted estimated future cash flows are less than the amortized cost basis of the security. An other-than-temporary impairment is also considered to have occurred if the fair value of the mortgage-backed/asset-backed security is less than its amortized cost basis and the entity intends to sell the security or the entity does not have the intent and ability to hold the security for a period of time sufficient to recover the amortized cost basis.

If it is determined an other-than-temporary impairment has occurred as a result of the cash flow analysis, the security is written down to the discounted estimated future cash flows. If an other-than-temporary impairment has occurred due to intent to sell or lack of intent and ability to hold, the security is written down to fair value. Prior to 2009, if it was determined that a decline in fair value was other-than-temporary, the cost basis of the security was written down to the undiscounted estimated future cash flows.

14

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

For GAAP, all securities, purchased or retained, that represent beneficial interests in securitized assets (e.g., CMO, CBO, CDO, CLO, MBS and ABS securities), other than high credit quality securities, are adjusted using the prospective method when there is a change in estimated future cash flows. If it is determined that a decline in fair value is other-than-temporary and the entity intends to sell the security or more likely than not will be required to sell the security before recovery of its amortized cost basis less any current period credit loss, the other-than-temporary impairment should be recognized in earnings equal to the entire difference between the amortized cost basis and its fair value at the impairment date. If the entity does not intend to sell the security and it is not more likely than not that the entity will be required to sell the security before recovery, the other-than-temporary impairment should be separated into a) the amount representing the credit loss, which is recognized in earnings, and b) the amount related to all other factors, which is recognized in OCI, net of applicable taxes. Prior to 2009, if it was determined that a decline in fair value was other-than-temporary, the cost basis of the security was written down to fair value. If high credit quality securities are adjusted, the retrospective method is used.

Derivative instruments used in hedging transactions that meet the criteria of an effective hedge are valued and reported in a manner that is consistent with the hedged asset or liability. Embedded derivatives are not accounted for separately from the host contract. Derivative instruments used in hedging transactions that do not meet or no longer meet the criteria of an effective hedge are accounted for at fair value, and the changes in the fair value are recorded in unassigned surplus as unrealized gains and losses. Under GAAP, the effective and ineffective portions of a single hedge are accounted for separately, an embedded derivative within a contract that is not clearly and closely related to the economic characteristics and risk of the host contract is accounted for separately from the host contract and valued and reported at fair value, and the change in fair value for cash flow hedges is credited or charged directly to a separate component of capital and surplus rather than to income as required for fair value hedges.

Derivative instruments are also used in replication transactions. In these transactions, the derivative is valued in a manner consistent with the cash investment and replicated asset. For GAAP, the derivative is reported at fair value with the changes in fair value reported in income.

15

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Investments in real estate are reported net of related obligations rather than on a gross basis as for GAAP. Real estate owned and occupied by the Company is included in investments rather than reported as an operating asset as under GAAP, and investment income and operating expenses for statutory reporting include rent for the Company’s occupancy of those properties. Changes between depreciated cost and admitted amounts are credited or charged directly to unassigned surplus rather than to income as would be required under GAAP.

Valuation allowances are established for mortgage loans, if necessary, based on the difference between the net value of the collateral, determined as the fair value of the collateral less estimated costs to obtain and sell, and the recorded investment in the mortgage loan. Under GAAP, such allowances are based on the present value of expected future cash flows discounted at the loan’s effective interest rate or, if foreclosure is probable, on the estimated fair value of the collateral.

The initial valuation allowance and subsequent changes in the allowance for mortgage loans are charged or credited directly to unassigned surplus as part of the change in asset valuation reserve (AVR), rather than being included as a component of earnings as would be required under GAAP.

Valuation Reserves: Under a formula prescribed by the NAIC, the Company defers the portion of realized capital gains and losses on sales of fixed income investments, principally bonds and mortgage loans, attributable to changes in the general level of interest rates and amortizes those deferrals over the remaining period to maturity of the bond or mortgage loan based on groupings of individual securities sold in five year bands. That net deferral is reported as the interest maintenance reserve (IMR) in the accompanying balance sheets. Realized capital gains and losses are reported in income net of federal income tax and transfers to the IMR. Under GAAP, realized capital gains and losses are reported in the statement of operations on a pre-tax basis in the period that the assets giving rise to the gains or losses are sold.

The AVR provides a valuation allowance for invested assets. The AVR is determined by an NAIC prescribed formula with changes reflected directly in unassigned surplus; AVR is not recognized for GAAP.

Subsidiaries: The accounts and operations of the Company’s subsidiaries are not consolidated with the accounts and operations of the Company as would be required under GAAP.

16

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Policy Acquisition Costs: The costs of acquiring and renewing business are expensed when incurred. Under GAAP, acquisition costs related to traditional life insurance and certain long duration accident and health insurance, to the extent recoverable from future policy revenues, would be deferred and amortized over the premium-paying period of the related policies using assumptions consistent with those used in computing policy benefit reserves; for universal life insurance and investment products, to the extent recoverable from future gross profits, deferred policy acquisition costs are amortized generally in proportion to the present value of expected gross profits from surrender charges and investment, mortality and expense margins.

Separate Accounts with Guarantees: Some of the Company’s separate accounts provide policyholders with a guaranteed return. In accordance with the guarantees provided, if the investment proceeds are insufficient to cover the rate of return guaranteed for the product, the policyholder proceeds will be remitted by the general account. These separate accounts are included in the general account for GAAP due to the nature of the guaranteed return.

Nonadmitted Assets: Certain assets designated as “nonadmitted”, primarily net deferred tax assets and other assets not specifically identified as an admitted asset within the NAIC Accounting Practices and Procedures Manual (NAIC SAP), are excluded from the accompanying balance sheets and are charged directly to unassigned surplus. Under GAAP, such assets are included in the balance sheet to the extent that they are not impaired.

Universal Life and Annuity Policies: Revenues for universal life and annuity policies with mortality or morbidity risk (including annuities with purchase rate guarantees) consist of the entire premium received. Benefits incurred represent surrenders and death benefits paid and the change in policy reserves. Premiums received and benefits incurred for annuity policies without mortality or morbidity risk and guaranteed interest in group annuity contracts are recorded directly to a policy reserve account using deposit accounting, without recognizing premium income or benefits expense. Interest on these policies is reflected in other benefits. Under GAAP, for universal life policies, premiums received in excess of policy charges would not be recognized as premium revenue and benefits would represent interest credited to the account values and the excess of benefits paid over the policy account value. Under GAAP, for all annuity policies without significant mortality risk, premiums received and benefits paid would be recorded directly to the reserve liability.

Benefit Reserves: Certain policy reserves are calculated based on statutorily required interest and mortality assumptions rather than on estimated expected experience or actual account balances as would be required under GAAP.

17

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Reinsurance: Any reinsurance amounts deemed to be uncollectible have been written off through a charge to operations. In addition, a liability for reinsurance balances would be established for unsecured policy reserves ceded to reinsurers not authorized to assume such business. Changes to the liability are credited or charged directly to unassigned surplus. Under GAAP, an allowance for amounts deemed uncollectible would be established through a charge to earnings.

Losses associated with an indemnity reinsurance transaction are reported within income when incurred rather than being deferred and amortized over the remaining life of the underlying reinsured contracts as would be required under GAAP.

Policy and contract liabilities ceded to reinsurers have been reported as reductions of the related reserves rather than as assets as would be required under GAAP.

Commissions allowed by reinsurers on business ceded are reported as income when incurred rather than being deferred and amortized with deferred policy acquisition costs as required under GAAP.

Deferred Income Taxes: Effective December 31, 2009, the Company began computing deferred income taxes in accordance with SSAP No. 10R, Income Taxes – Revised, A Temporary Replacement of SSAP No. 10, discussed in further detail in the Recent Accounting Pronouncement section of this note. Under SSAP 10R, deferred income tax assets are limited to 1) the amount of federal income taxes paid in prior years that can be recovered through loss carrybacks for existing temporary differences that reverse during a timeframe corresponding with the Internal Revenue Service tax loss carryback provisions, not to exceed three years, plus 2) the lesser of the remaining gross deferred income tax assets expected to be realized within three years of the balance sheet date or 15% of capital and surplus excluding any net deferred income tax assets, electronic data processing equipment and operating software and any net positive goodwill, plus 3) the amount of remaining gross deferred income tax assets that can be offset against existing gross deferred income tax liabilities after considering the character (i.e., ordinary versus capital) of the deferred tax assets and liabilities. The remaining deferred income tax assets are nonadmitted.

Deferred income taxes do not include amounts for state taxes. Under GAAP, state taxes are included in the computation of deferred income taxes, a deferred income tax asset is recorded for the amount of gross deferred income tax assets expected to be realized in all future years, and a valuation allowance is established for deferred income tax assets not realizable.

18

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Goodwill: Goodwill is admitted subject to an aggregate limitation of ten percent of the capital and surplus in the most recently filed annual statement excluding electronic data processing equipment, operating system software, net deferred income tax assets and net positive goodwill. Excess goodwill is nonadmitted. Goodwill is amortized over ten years. Under GAAP, goodwill is measured as the excess of the consideration transferred plus the fair value of any noncontrolling interest in the acquiree at the acquisition date as compared to the fair values of the identifiable net assets acquired. Goodwill is not amortized but is assessed for impairment on an annual basis, or more frequently if circumstances indicate that a possible impairment has occurred.

Policyholder Dividends: Policyholder dividends are recognized when declared rather than over the term of the related policies as would be required under GAAP.

Surplus Notes: Surplus notes are reported as surplus rather than as liabilities as would be required under GAAP.

Statements of Cash Flow: Cash, cash equivalents and short-term investments in the statements of cash flow represent cash balances and investments with initial maturities of one year or less. Under GAAP, the corresponding caption of cash and cash equivalents includes cash balances and investments with initial maturities of three months or less.

Securities Lending Assets and Liabilities: Beginning December 31, 2010, for securities lending programs, cash collateral received which may be sold or repledged by the Company is reflected as a one-line entry on the balance sheet (securities lending reinvested collateral assets) and a corresponding liability is established to record the obligation to return the cash collateral. Collateral received which may not be sold or repledged is not recorded on the Company’s balance sheet. Prior to 2010, cash collateral received from securities lending was not recorded on the Company’s balance sheet because the cash collateral was restricted. Under GAAP the reinvested collateral is included within invested assets (i.e. it is not one-line reported).

The effects of the foregoing variances from GAAP on the accompanying statutory-basis financial statements have not been determined by the Company, but are presumed to be material.

19

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Other significant accounting policies are as follows:

Investments

Investments in bonds, except those to which the SVO has ascribed an NAIC designation of 6, are reported at amortized cost using the interest method.

Single class and multi-class mortgage-backed/asset-backed securities are valued at amortized cost using the interest method, including anticipated prepayments, except for those with an initial NAIC designation of 6, which are valued at the lower of amortized cost or fair value. Prepayment assumptions are obtained from dealer surveys or internal estimates and are based on the current interest rate and economic environment. The retrospective adjustment method is used to value all such securities, except principal-only and interest-only securities, which are valued using the prospective method.

Investments in both affiliated and unaffiliated preferred stocks in good standing are reported at cost or amortized cost. Investments in preferred stocks not in good standing are reported at the lower of cost or fair value, and the related net unrealized capital gains (losses) are reported in unassigned surplus along with any adjustment for federal income taxes.

Hybrid securities, as defined by the NAIC, are securities designed with characteristics of both debt and equity and provide protection to the issuer’s senior note holders. These securities meet the definition of a bond, in accordance with SSAP No. 26, Bonds, excluding Loan-backed and Structured Securities and therefore, are reported at amortized cost or fair value based upon their NAIC rating.

Common stocks of unaffiliated companies, which includes shares of mutual funds, are reported at fair value and the related net unrealized capital gains or losses are reported in unassigned surplus along with any adjustment for federal income taxes.

Common stocks of affiliated insurance subsidiaries are reported based on underlying statutory equity plus the admitted portion of goodwill. Common stocks of affiliated noninsurance subsidiaries are reported based on underlying audited GAAP equity. The net change in the subsidiaries’ equity is included in the change in net unrealized capital gains or losses, reported in unassigned surplus along with any adjustment for federal income taxes.

20

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

The Company is restricted to trading Primus Guaranty, Ltd (Primus) a common stock holding, due to its ownership interest, which would require special securities filings prior to executing any purchase or sale transactions in regard to these securities. The Company’s interest in Primus does not meet the definition of an affiliate, and is therefore accounted for as an unaffiliated common stock investment. The carrying amount in Primus, which is carried at fair value, as of December 31, 2010 and 2009 was $28,657 and $17,027, respectively.

Short-term investments include investments with remaining maturities of one year or less at the time of acquisition and are principally stated at amortized cost.

Cash equivalents are short-term highly liquid investments with original maturities of three months or less and are principally stated at amortized cost.

Mortgage loans are reported at unpaid principal balances, less an allowance for impairment. A mortgage loan is considered to be impaired when it is probable that the Company will be unable to collect all principal and interest amounts due according to the contractual terms of the mortgage agreement. When management determines that the impairment is other-than-temporary, the mortgage loan is written down to realizable value and a realized loss is recognized.

Land is reported at cost. Real estate occupied by the Company is reported at depreciated cost net of encumbrances. Real estate held for the production of income is reported at depreciated cost net of related obligations. Real estate that the Company has the intent to sell is reported at the lower of depreciated cost or fair value, net of related obligations. Depreciation is calculated on a straight-line basis over the estimated useful lives of the properties.

Policy loans are reported at unpaid principal balances.

The Company has minority ownership interests in joint ventures and limited partnerships. The Company carries these investments based on its interest in the underlying audited GAAP equity of the investee.

Investments in Low Income Housing Tax Credit (LIHTC) properties are valued at amortized cost. Tax credits are recognized in operations in the tax reporting year in which the tax credit is utilized by the Company.

Other “admitted assets” are valued principally at cost, as required or permitted by Iowa Insurance Laws.

21

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Realized capital gains and losses are determined using the specific identification method and are recorded net of related federal income taxes. Changes in admitted asset carrying amounts of bonds, mortgage loans, common and preferred stocks are credited or charged directly to unassigned surplus.

Interest income is recognized on an accrual basis. The Company does not accrue income on bonds in default, mortgage loans on real estate in default and/or foreclosure or which are delinquent more than twelve months, or real estate where rent is in arrears for more than three months. Income is also not accrued when collection is uncertain. In addition, accrued interest is excluded from interest income when payment exceeds 90 days past due. At December 31, 2010 and 2009, the Company excluded investment income due and accrued of $314 and $2,924, respectively, with respect to such practices.

The carrying values of all investments are reviewed on an ongoing basis for credit deterioration or changes in estimated cash flows. If this review indicates a decline in fair value that is other-than-temporary, the carrying value of the investment is reduced to its fair value, and a specific writedown is taken for all investments other than loan-backed or structured securities, which are reduced to the present value of expected cash flows where the Company has the ability and intent to hold the security until recovery. Such reductions in carrying value are recognized as realized losses on investments.

For dollar repurchase agreements, the Company receives cash collateral in an amount at least equal to the fair value of the securities transferred by the Company in the transaction as of the transaction date. Cash received as collateral will be invested as needed or used for general corporate purposes of the Company.

Derivative Instruments

Interest rate swaps are the primary derivative financial instruments used in the overall asset/liability management process to modify the interest rate characteristics of the underlying asset or liability. These interest rate swaps generally provide for the exchange of the difference between fixed and floating rate amounts based on an underlying notional amount. Typically, no cash is exchanged at the outset of the swap contract and a single net payment is exchanged each due date. Swaps that meet hedge accounting rules are carried in a manner consistent with the hedged item, generally amortized cost, in the financial statements. If the swap is terminated prior to maturity, proceeds are exchanged equal to the fair value of the contract. These gains and losses may be included in IMR or AVR if the hedged instrument receives that treatment. Swaps not meeting hedge accounting rules are carried at fair value with fair value adjustments recorded in unassigned surplus.

22

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

The Company may hold foreign denominated assets or liabilities and cross currency swaps are utilized to convert the asset or liability to a US denominated security. Cross currency swap agreements are contracts to exchange two principal amounts of two currencies at the prevailing exchange rate at inception of the contract. During the life of the swap, the counterparties exchange fixed or floating rate interest payments in the swapped currencies. At maturity, the principal amounts are again swapped at a pre-determined rate of exchange. Each asset or liability is hedged individually and the terms of the swap must meet the terms of the hedged instrument. For cross currency swaps qualifying for hedge accounting, the premium or discount is amortized into income over the life of the contract and the foreign currency translation adjustment is recorded as unrealized gain/loss in unassigned surplus. Swaps not meeting hedge accounting rules are carried at fair value with fair value adjustments recorded in unassigned surplus. If a swap is terminated prior to maturity, proceeds are exchanged equal to the fair value of the contract. These gains and losses may be included in IMR or AVR if the hedged instrument receives that treatment.

The Company may issue foreign denominated assets or liabilities and use forward rate agreements to hedge foreign currency risk associated with these products. These forward agreements are marked to fair value based on the current forward rate on the financial statements thru unassigned surplus, and cash payments and/or receipts are recognized as realized gain or losses.

The Company issues products providing the customer a return based on various global equity market indices. The Company uses global futures contracts and/or options to hedge the liability option risk associated with these products. Futures are marked to fair value on a daily basis and a cash payment is made or received by the Company. These payments are recognized as realized gains or losses in the financial statements. Options are marked to fair value in the balance sheet and fair value adjustments are recorded in unassigned surplus.

An interest rate floor provides for the receipt of payments in the event interest rates fall below the strike rates in the contract. The interest rate floor is designed to generate cash flows to offset the lower cash flows received on assets during low interest rate environments. The Company pays a single premium at the beginning of the contract. These interest rate floors are marked to fair value in the balance sheet and the fair value adjustment is recorded in capital and surplus.

Capped floating rate commercial mortgage loans and interest rate caps that are designated as hedges and meet hedge accounting rules are carried at amortized cost in the financial statements. A gain or loss upon early termination would be reflected in the IMR similar to the underlying instrument. Caps not meeting hedge accounting rules are carried at fair value with fair value adjustments recorded in unassigned surplus.

23

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

For forecasted hedge transactions, the deferred gain (loss) is recognized in income as the hedged asset affects income. If the derivative is no longer effective at achieving the desired risk management objective or if the forecasted transaction is no longer probable, hedge accounting will cease and the forward-starting swap will be marked to fair value through unassigned surplus.

The Company may sell products with expected benefit payments extending beyond investment assets currently available in the market. Because assets will have to be purchased in the future to fund future liability cash flows, the Company is exposed to the risk of future investments made at lower yields than what is assumed at the time of pricing. Forward-starting interest rate swaps are utilized to lock-in the current forward rate. The accrual of income for forward-starting interest rate swaps begins at the forward date, rather than at the inception date. These forward-starting swaps meet hedge accounting rules and are carried at cost in the financial statements. Gains and losses realized upon termination of the forward-starting swap are deferred and used to adjust the basis of the asset purchased in the hedged forecasted period. The basis adjustment is then amortized into income as a yield adjustment to the asset over its life.

In addition to utilizing forward starting swaps to mitigate the risk of future re-investment risk at lower yields, the Company also uses put options. These put options are used when rates are below the Company’s target rate. In these market environments, the Company will sell put options on the forward starting swaps of which they would like to enter into. The option period will be considered an income generation transaction. Since the underlying is a derivative, the option will be marked to market with the offset through surplus and the premium received for the written option is deferred during the option period. If the option is exercised, the premium will adjust the forward starting swap’s acquisition cost. Once acquired, the forward starting swap will then be accounted for as outlined above.

24

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

A replication transaction is a derivative transaction entered into conjunction with a cash instrument to reproduce the investment characteristics of an otherwise permissible investment. The Company replicates investment grade corporate bonds by combining a AAA rated security as a cash component with a credit default swap which, in effect, converts the high quality asset in a lower rated investment grade asset. The benefits of using the swap market to replicate credit include possible enhanced relative values as well as ease of executing larger transactions in a shortened time frame. Generally, a premium is received by the Company on a periodic basis and recognized in investment income. In the event the representative issuer defaults on its debt obligation referenced in the contract, a payment equal to the notional amount of the contract will be made by the Company and recognized as a capital loss. The Company replicates hybrid fixed to floating treasuries by combining a US Treasury cash component with a forward starting swap which, in effect converts a fixed US Treasury into hybrid fixed to floating treasury. The purpose of these replications is to aid duration matching between the treasuries and the supported liabilities. Generally these swaps are carried at amortized cost with periodic interest payments beginning at a future date. Any early terminations are recognized as capital gains or losses. The Company complies with the specific rules established in AVR for replication transactions.

The Company holds some credit default swaps linked to a collateralized debt obligation structure. The Company was put into these swaps as a result of market events on a liquidity facility it had entered into. The Company does not intend to enter similar transactions in this current form. Under this transaction the Company receives a fee in exchange for providing credit protection if the underlying collateralized debt obligation structure incurs losses greater than its supporting collateral. The fee will be recorded in investment income. These swaps are marked to fair value in the balance sheet and the fair value adjustment is recorded in capital and surplus.

Separate Accounts

The majority of the separate accounts held by the Company, primarily for individual policyholders as well as for group pension plans, do not have any minimum guarantees, and the investment risks associated with fair value changes are borne by the policyholder. The assets in the accounts, carried at estimated fair value, consist of underlying mutual fund shares, common stocks, long-term bonds and short-term investments.

Certain other separate accounts held by the Company provide a minimum guaranteed return of 3% of the average investment balance to policyholders. The assets consist of long-term bonds and short-term investments which are carried at amortized cost.

25

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Assets held in trust for purchases of variable universal life and annuity contracts and the Company’s corresponding obligation to the contract owners are shown separately in the balance sheets. The assets in the separate accounts are valued at fair value. Income and gains and losses with respect to the assets in the separate accounts accrue to the benefit of the contract owners and, accordingly, the operations of the separate accounts are not included in the accompanying financial statements. The investment risks associated with fair value changes of the separate accounts are borne entirely by the policyholders except in cases where minimum guarantees exist. The Company received variable contract premiums of $6,368,599, $4,279,394 and $4,182,626 in 2010, 2009 and 2008, respectively. In addition, the Company received $380,170, $376,545 and $399,445 in 2010, 2009 and 2008, respectively, related to fees associated with investment management, administration and contractual guarantees for separate accounts.

Aggregate Reserves for Policies and Contracts

Life, annuity and accident and health benefit reserves are developed by actuarial methods and are determined based on published tables using statutorily specified interest rates and valuation methods that will provide, in the aggregate, reserves that are greater than or equal to the minimum or guaranteed cash value, or the amount required by law.

The Company waives deduction of deferred fractional premiums upon death of the insured and returns any portion of the final premium for periods beyond the month of death.

The aggregate policy reserves for life insurance policies are based principally upon the 1941, 1958, 1980 and 2001 Commissioners’ Standard Ordinary Mortality and American Experience Mortality Tables. The reserves are calculated using interest rates ranging from 2.00 to 6.00 percent and are computed principally on the Net Level Premium Valuation and the Commissioners’ Reserve Valuation Methods. Reserves for universal life policies are based on account balances adjusted for the Commissioners’ Reserve Valuation Method.

Additional premiums are charged or additional mortality charges are assessed for policies issued on substandard lives according to underwriting classification. Generally, mean reserves are determined by computing the regular mean reserve for the plan at the true age and holding, in addition, one-half (1/2) of the extra premium charge for the year. For certain flexible premium and fixed premium universal life insurance products, reserves are calculated utilizing the Commissioner’s Reserve Valuation Method for universal life policies and recognizing any substandard ratings.

26

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Deferred annuity reserves are calculated according to the Commissioners’ Annuity Reserve Valuation Method including excess interest reserves to cover situations where the future interest guarantees plus the decrease in surrender charges are in excess of the maximum valuation rates of interest. Reserves for immediate annuities and supplementary contracts with and without life contingencies are equal to the present value of future payments assuming interest rates ranging from 2.00 to 11.25 percent and mortality rates, where appropriate, from a variety of tables.

Annuity reserves also include guaranteed investment contracts (GICs) and funding agreements classified as life-type contracts as defined in SSAP No. 50, Classifications and Definitions of Insurance or Managed Care Contracts In Force. These liabilities have annuitization options at guaranteed rates and consist of floating interest rate and fixed interest rate contracts. The contract reserves are carried at the greater of the account balance or the value as determined for an annuity with cash settlement options, on a change in fund basis, according to the Commissioners’ Annuity Reserve Valuation Method.

Accident and health policy reserves are equal to the greater of the gross unearned premiums or any required mid-terminal reserves plus net unearned premiums and the present value of amounts not yet due on both reported and unreported claims.

Tabular interest, tabular less actual reserves released and tabular cost have been determined by formula. Tabular interest on funds not involving life contingencies has also been determined primarily by formula.

During 2009, the Company implemented an improved valuation method for single premium group annuity (SPGA) products. The prior method approximated the reserve using a spreadsheet-based balance roll forward. The current method is a seriatim valuation using a software package capable of making these calculations. The change in valuation process resulted in an increase in reserves in the amount of $3,053. The change in reserves has been credited directly to unassigned surplus.

During 2010, the Company reported a decrease in reserves on account of changes in valuation bases of $3,642 due to continued conversion from the spreadsheet-based balance roll forward method of valuation of SPGA products to a seriatim valuation. In addition, the Company continued to make enhancements to existing valuation platforms and converted from client based reserves to in-house seriatim calculations during 2010. These changes resulted in an increase in reserves of $3,523. The net change in reserves of $119 due to the conversions has been credited directly to unassigned surplus. Related to this change was a corresponding decrease in the deferred premium asset of $2,388. This amount was also charged directly to unassigned surplus.

27

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

During 2009, the Company reversed a change in reserve methodology implemented in 2008 pertaining to the change in valuation interest rates from those required under California insurance law to those allowed under Iowa insurance law due to the merger of TOLIC into TLIC. The Company changed back to valuation interest rates required under California insurance law during 2009 to meet the minimum aggregate reserve requirement for California and to preserve consistency in valuation rates and methods used for TOLIC’s California issued policies. This change in valuation process resulted in an increase in reserves in the amount of $28,005 which has been charged directly to unassigned surplus.

During 2008, the Company’s reserves decreased by $35,039 due to various changes in valuation basis. A decrease in reserves of $36,442 resulted from various valuation system upgrades or enhancements, the largest of which was the Prophet conversion. During 2008, the Company updated the valuation process which included conversion to the Prophet valuation system, subject to existing contractual mirror reserving requirements. Previously, reserves were determined by applying client reported data, with a one quarter of a year lag, against current in force volumes. The new method calculates the reserves directly (using Prophet) based on the current in force. The change in valuation process resulted in a decrease in reserves in the amount of $30,022, with a corresponding decrease in deferred premiums of $17,488. The change in reserves has been credited directly to unassigned surplus. A decrease in reserves of $23,967 represents a change in assumptions regarding the policyholder’s election to exercise the Supplementary Retirement Income Option rider attached to certain Universal Life policies. A decrease in reserves of $28,921 represents a change in valuation interest rates from those required under California insurance law to those allowed under Iowa insurance law due to the merger of TOLIC into TLIC. Also during 2008, the Company updated assumptions and made enhancements to valuation methodology related to its accident and health reserves. These changes resulted in a partially offsetting increase in accident and health reserves of $54,291.

Policy and Contract Claim Reserves

Claim reserves represent the estimated accrued liability for claims reported to the Company and claims incurred but not yet reported through the balance sheet date. These reserves are estimated using either individual case-basis valuations or statistical analysis techniques. These estimates are subject to the effects of trends in claim severity and frequency. The estimates are continually reviewed and adjusted as necessary as experience develops or new information becomes available.

28

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Liability for Deposit-Type Contracts

Deposit-type contracts do not incorporate risk from the death or disability of policyholders. These types of contracts may include GICs, funding agreements and other annuity contracts. Deposits and withdrawals on these contracts are recorded as a direct increase or decrease, respectively, to the liability balance and are not reported as premiums, benefits or changes in reserves in the statement of operations.

The Company issues certain funding agreements with well-defined class-based annuity purchase rates defining either specific or maximum purchase rate guarantees. However, these funding agreements are not issued to or for the benefit of an identifiable individual or group of individuals. These contracts are classified as deposit-type contracts in accordance with SSAP No. 50.

Municipal Reverse Repurchase Agreements

Municipal repurchase agreements are investment contracts issued to municipalities that pay either a fixed or floating rate of interest on the guaranteed deposit balance. The floating interest rate is based on a market index. The related liabilities are equal to the policyholder deposit and accumulated interest on the contract.

The Company enters into municipal repurchase agreements for which it requires a minimum of 95% of the fair value of the securities transferred to be maintained as collateral.

Premiums and Annuity Considerations

Revenues for policies with mortality or morbidity risk (including annuities with purchase rate guarantees) consist of the entire premium received and are recognized over the premium paying periods of the related policies. Consideration received and benefits paid for annuity policies without mortality or morbidity risk are recorded using deposit accounting and recorded directly to an appropriate policy reserve account, without recognizing premium revenue.

29

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Claims and Claim Adjustment Expense

Liabilities for losses and loss/claim adjustment expenses for accident and health contracts are estimated using statistical claim development models to develop best estimates of liabilities for medical expense business and using tabular reserves employing mortality/morbidity tables and discount rates meeting minimum regulatory requirements for other business. The balance in the liability for unpaid accident and health claim adjustment expenses as of December 31, 2010 and 2009 was $25,247 and $23,029, respectively.

The Company incurred $12,350 and paid $10,131 of claim adjustment expenses during 2010, of which $6,838 of the paid amount was attributable to insured or covered events of prior years. The Company incurred $11,227 and paid $10,397 of claim adjustment expenses during 2009, of which $6,727 of the paid amount was attributable to insured or covered events of prior years. The Company did not increase or decrease the provision for insured events of prior years during 2010 or 2009.

Reinsurance

Coinsurance premiums, commissions, expense reimbursements and reserves related to reinsured business are accounted for on bases consistent with those used in accounting for the original policies and the terms of the reinsurance contracts. Gains associated with reinsurance of inforce blocks of business are included in unassigned surplus and amortized into income over the estimated life of the policies. Premiums ceded and recoverable losses have been reported as a reduction of premium income and benefits, respectively. Policy liabilities and accruals are reported in the accompanying financial statements net of reinsurance ceded.

Stock Option Plan, Long-Term Incentive Compensation and Stock Appreciation Rights Plans

Prior to 2002 and in 2005 through 2008, AEGON N.V. sponsored a stock option plan for eligible employees of the Company. Pursuant to the plan, the option price at the date of grant is equal to the fair value of the stock. Under statutory accounting principles, the Company does not record any expense related to this plan. No stock options were issued during 2010 or 2009.

30

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

The Company’s employees participate in various stock appreciation rights (SAR) plans issued by the Company’s indirect parent. In accordance with SSAP No. 13, Stock Options and Stock Purchase Plans, the expense related to these plans for the Company’s employees has been charged to the Company, with an offsetting amount credited to paid-in surplus. No benefit or expense relating to these plans was recorded by the Company for the year ended December 31, 2010. The Company recorded a benefit of $214 and $14,618 for the years ended December 31, 2009 and 2008, respectively. In addition, the Company recorded an adjustment to paid-in surplus for the income tax effect related to these plans over and above the amount reflected in the statement of operations in the amount of $75 for the year ended December 31, 2008. The Company did not record an adjustment to paid-in surplus for the income tax effect related to these plans for the years ended December 31, 2010 or 2009.

Certain management employees of the Company participate in a stock-based long-term incentive compensation plan issued by the Company’s indirect parent. In accordance with SSAP No. 13, the expense or benefit related to this plan for the Company’s management employees has been charged to the Company, with an offsetting amount credited to paid-in surplus. The Company recorded an accrued expense in the amount of $3,205 for the year ended December 31, 2010. The Company did not record an accrued expense related to stock-based long-term incentive compensation for the years ended December 31, 2009 or 2008.

Recent Accounting Pronouncements

Effective December 31, 2010, the Company adopted modifications made to SSAP No. 91R, Accounting for Transfers and Servicing of Financial Assets and Extinguishment of Liabilities. As a result of these modifications, for securities lending programs, collateral received by the Company’s agent that can be sold or re-pledged is reported on the balance sheet. Collateral received and reinvestment of that collateral by the Company are reflected as a one-line entry on the balance sheet (securities lending reinvested collateral assets). A separate liability is also established to record the obligation to return the cash collateral (payable for securities lending). This change in accounting principle increased assets and liabilities by $3,956,880 with no impact to surplus. See Note 10 for further details.

31

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

In addition, the amendments to SSAP No. 91R resulted in cash collateral received from counterparties to derivatives contracts also being reported on the Company’s balance sheet in the respective asset class in which the cash was reinvested (short-term investments and bonds). A separate liability was established to record the obligation to return the cash collateral (Payable for derivative cash collateral). These balances were recorded on the Company’s balance sheet effective January 1, 2010 and resulted in an increase to assets of $220,439, an increase to liabilities of $215,069 and a net increase to surplus of $5,370. The net increase to surplus is comprised of $6,403 of accumulated earnings offset by unrealized losses associated with securities that were reported at lower of cost or market at the time of adoption of $1,033.

Effective December 31, 2010, the Company adopted SSAP No. 100, Fair Value Measurements, including recent modifications and clarifications made to the standard. This statement defines fair value, establishes a framework for measuring fair value and establishes disclosure requirements about fair value, and it applies under other statutory accounting pronouncements that require or permit fair value measurements. The adoption of this new accounting principle had no impact to the Company’s results of operations or financial position. See Note 4 for further details.

During 2010, revisions were adopted to certain paragraphs of SSAP No. 43R, Loan-backed and Structured Securities to clarify the accounting for gains and losses between AVR and IMR. The revisions clarify that an AVR / IMR bifurcation analysis should be performed when SSAP No. 43R securities are sold (not just as a result of impairment). These changes have an effective date of January 1, 2011 and are to be applied on a prospective basis.

During 2010, revisions were made to SSAP No. 43R to clarify the definitions of loan-backed and structured securities. The revised definitions will most likely result in more securities being accounted for under SSAP No. 43R. Companies are to prospectively apply the clarified guidance effective January 1, 2011. The Company is in the process of determining the impact of these changes.

32

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Effective September 30, 2009, the Company adopted SSAP No. 43R. This statement establishes statutory accounting principles for investments in loan-backed and structured securities. The SSAP supersedes SSAP No. 98, Treatment of Cash Flows When Quantifying Changes in Valuation and Impairments and paragraph 13 of SSAP No. 99, Accounting for Certain Securities Subsequent to an Other-Than-Temporary Impairment. SSAP No. 43R changes the accounting for other-than-temporary impairments (OTTI). If the Company intends to sell a security or lacks the intent or ability to hold the security until it recovers to its amortized cost basis, the security shall be written down to its fair value. If the Company does not expect to recover the entire amortized cost basis of a security, an OTTI shall be recognized as a realized loss equal to the difference between the security’s amortized cost basis and the present value of cash flows expected to be collected, discounted at the effective interest rate as outlined in the SSAP. Prior to the adoption of SSAP No. 43R, loan-backed and structured securities were accounted for in accordance with SSAP No. 43, which called for those securities to be impaired and written down using undiscounted cash flows. The cumulative effect of the adoption of this standard is the difference between the present value of expected cash flows for securities identified as having an OTTI compared with their amortized cost basis as of July 1, 2009. This change in accounting principle reduced surplus by a net amount of $14,934 ($9,707 net of tax), which includes impairments of $40,973 offset by NAIC 6 rated securities that were already reported at lower of cost or market at the time of the implementation of SSAP No. 43R of $26,039, which have been removed from the component of change in net unrealized gains/losses.

33

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

Effective December 31, 2009, the Company began computing deferred income taxes in accordance with SSAP No. 10R. This statement establishes statutory accounting principles for current and deferred federal and foreign income taxes and current state income taxes. This statement temporarily replaces SSAP No. 10, Income Taxes. Under SSAP No. 10R, gross deferred tax assets (DTAs) shall be admitted in an amount equal to the amount of federal income taxes paid in prior years that can be recovered through loss carrybacks for existing temporary differences that reverse by the end of the subsequent calendar year and the lesser of the amount of adjusted gross DTAs, expected to be realized within one year of the balance sheet date or 10% of capital and surplus excluding any net deferred income tax assets, electronic data processing equipment and operating system software and any net positive goodwill that can be offset against existing gross deferred income tax liabilities (DTLs) after considering the character. If the Company’s risk-based capital level (RBC) is above 250% where an action level could occur as a result of a trend test, the Company may elect to admit a higher amount of adjusted gross DTAs. When elected, additional DTAs are admitted for taxes paid in prior years that can be recovered through loss carryback provisions for existing temporary differences that reverse within three years of the balance sheet date and the lesser of the remaining gross DTAs expected to be realized within three years of the balance sheet date or 15% of capital and surplus excluding any net deferred income tax assets, electronic data processing equipment and operating software and any positive net goodwill plus the amount of remaining gross DTAs that can be offset against gross DTLs after considering the character (i.e., ordinary versus capital) of the DTAs and DTLs. Prior to the adoption of SSAP No. 10R, the Company obtained permission from the state of Iowa to compute deferred income taxes using a permitted practice. At December 31, 2009, the Company elected to admit additional deferred tax assets pursuant to SSAP No. 10R. The cumulative effect of the election of this statement is the difference between the calculation of the admitted DTA per SSAP No. 10R and the SSAP No. 10 methodology at December 31, 2009 as the use of the permitted practice expired as of December 15, 2009. As a result of this election, surplus increased by a cumulative effect of $554,923 and $295,260 at December 31, 2010 and 2009, respectively, which has been reflected as an aggregate write-in for other than special surplus funds on the 2010 and 2009 financial statements.

Effective December 31, 2009 the Company adopted amendments to SSAP No. 9, Subsequent Events, which establishes general standards of accounting for and disclosure of events that occur after the balance sheet date but before financial statements are issued or are available to be issued. The guidance requires the disclosure of the date through which an entity has evaluated subsequent events and whether that date represents the date the financial statements were issued or were available to be issued. The adoption did not impact the Company’s results of operations or financial position. See Note 16 for further discussion of the Company’s consideration of subsequent events.

34

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

1. Organization and Summary of Significant Accounting Policies (continued)

In September 2008, the NAIC issued SSAP No. 99, Accounting for Certain Securities Subsequent to an Other-Than-Temporary Impairment. This statement establishes the statutory accounting principles for the treatment of premium or discount applicable to certain securities subsequent to the recognition of an OTTI. Prior to SSAP No. 99, the Company’s previously impaired investments were reported in accordance with SSAP No. 26, Bonds, excluding Loan-backed and Structured Securities, SSAP No. 32, Investments in Preferred Stock and SSAP No. 43, Loan-backed and Structured Securities. The Company adopted SSAP No. 99 on January 1, 2009. The adoption of this statement was accounted for prospectively and therefore there was no impact to the Company’s financial statements at adoption.

Reclassifications

Certain reclassifications have been made to the 2009 and 2008 financial statements to conform to the 2010 presentation.

2. Prescribed and Permitted Statutory Accounting Practices

The Insurance Division, Department of Commerce, of the State of Iowa recognizes only statutory accounting practices prescribed or permitted by the State of Iowa for determining and reporting the financial condition and results of operations of an insurance company, and for determining its solvency under the Iowa Insurance Law.

The NAIC SAP has been adopted as a component of prescribed or permitted practices by the State of Iowa. The State of Iowa has adopted a prescribed accounting practice that differs from that found in the NAIC SAP related to reserve credits and secondary guarantee reinsurance treaties. As prescribed by Iowa Administrative Code 191-17.3(2), the Commissioner found that the Company is entitled to take reserve credit for such a reinsurance contract in the amount equal to the portion of total reserves attributable to the secondary guarantee, whereas this type of reinsurance does not meet the specific requirements of SSAP No. 61, Life, Deposit-Type and Accident and Health Reinsurance and Appendix A-791 of the NAIC SAP.

The Company, with the permission of the Commissioner of Insurance of the State of Iowa, records the value of its wholly owned foreign life insurance subsidiary, Transamerica Life (Bermuda), Ltd. (TLB), based upon audited statutory equity rather than audited U.S. GAAP equity adjusted to a statutory basis of accounting, utilizing adjustments as outlined in SSAP No. 97 – Investments in Subsidiary, Controlled and Affiliated Entities, a replacement of SSAP No. 88, paragraph 9.

35

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

2. Prescribed and Permitted Statutory Accounting Practices (continued)

At December 31, 2008, the Company received written approval from the Iowa Insurance Division to determine the admitted amount of deferred income tax assets pursuant to Iowa Bulletin 09-01. Bulletin 09-01 increased the realization period for purposes of determining the admissibility of deferred tax assets in accordance with the requirements of SSAP No. 10, Paragraph 10(b)(i) from one year to three years from the balance sheet date and expanded the limit on net deferred tax assets for Paragraph 10(b)(ii) from 10% of adjusted capital and surplus to 15%. The Company did not utilize this permitted practice during 2010 or 2009 and instead opted to calculate deferred income taxes using the provisions of SSAP No. 10R.

The State of Iowa has adopted a prescribed accounting practice that differs from that found in the NAIC SAP related to the reported value of the assets supporting the Company’s guaranteed separate accounts. As prescribed by Iowa Administrative Code 508A.1.4, the Commissioner found that the Company is entitled to value the assets of the guaranteed separate account at amortized cost, whereas the assets would be required to be reported at fair value under SSAP No. 56, Separate Accounts, of the NAIC SAP. There is no impact to the Company’s income or surplus as a result of utilizing this prescribed practice.

A reconciliation of the Company’s net income and capital and surplus between NAIC SAP and practices prescribed and permitted by the State of Iowa is shown below:

	2010			2009			2008
							Restated
Net income (loss), State of Iowa basis	$	417,679		$	(6,425	)	$	(621,418	)
State prescribed practice for secondary guarantee reinsurance		—			—			—
State permitted practice for valuation of foreign life subsidiary		—			—			—
Net income (loss), NAIC SAP	$	417,679		$	(6,425	)	$	(621,418	)
Statutory surplus, State of Iowa basis	$	4,298,124		$	5,026,825		$	4,840,134
State prescribed practice for secondary guarantee reinsurance		(2,926,627	)		(2,593,154	)		(2,349,638	)
State permitted practice for valuation of wholly-owned foreign life subsidiary		19,656			(20,745	)		(124,668	)
State permitted practice for deferred tax asset		—			—			(380,358	)
Statutory surplus, NAIC SAP	$	1,391,153		$	2,412,926		$	1,985,470

36

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

3. Accounting Changes and Correction of Errors

During 2009, the Company corrected the financial statement presentation of the preferred treasury stock. On December 19, 2007, the Company repurchased 57,340 shares of its Series B preferred shares for $573,400. The par value of the Series B preferred shares is $10 per share and the liquidation value is also $10 per share. At December 31, 2007, the financial statement of the Company appropriately presented the $573,400 as preferred treasury stock. Due to the merger of LIICA and TOLIC into the Company on October 2, and October 1, 2008, respectively, Transamerica Corporation was issued 86,590 shares of Series B preferred stock. Rather than reflecting the Series B preferred stock issued as first a reduction of treasury stock, with the remaining shares issued to TA Corp presented as additional shares issued and outstanding, the Company incorrectly presented the entire amount of the 86,590 shares issued to TA Corp as newly issued and outstanding shares. During 2009, the Company corrected the presentation of the Series B preferred shares, which resulted in a reduction of $573,400 to treasury stock and a reduction in the preferred capital stock line of $573, with an offset to gross paid-in capital. There was no net surplus impact to the Company due to this correction.

The Company entered into an agreement with an affiliated entity in which certain mortgage loans and real estate were sold with an effective date of December 31, 2008. The sales of these mortgage loans and real estate were not reflected in the December 31, 2008 financial statements. As a result, the Company has reflected such sales in the December 31, 2009 financial statements and has identified the surplus impact of such corrections as a separate change in capital and surplus within the statement of operations for 2009. Had these sales been appropriately recognized within the December 31, 2008 financials, the AVR balance would have been $6,275 lower and the sales would have increased the Company’s net loss by $7,173, for a net negative surplus impact of $898.

During 2008, the Company obtained approval from the Insurance Division, Department of Commerce, of the State of Iowa to calculate the reserves related to synthetic guaranteed investment contracts (synthetic GICs) utilizing a discount rate corresponding to the corporate bond AA credit curve, versus 105% of the Treasury spot-rate curve, which was utilized in previous years. The difference in the reserves held under the reserve methodology utilized at December 31, 2008 versus previous years’ methodology is a decrease in reserves of approximately $89,002. This approval is still effective, however, as of December 31, 2009, the Company resumed the higher reserve standard of utilizing the discount rate of 105% of the Treasury spot-rate curve to calculate its reserves related to its outstanding synthetic GIC contracts. The same method is utilized as of December 31, 2010. Only one contract had a non-zero reserve. Contractually the liability is limited to $3,000, and this is the reserve held by the Company at December 31, 2010 and 2009.

37

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments

The following methods and assumptions were used by the Company in estimating its fair value disclosures for financial instruments:

Cash, Cash Equivalents and Short-Term Investments: The carrying amounts reported in the accompanying balance sheets for these financial instruments approximate their fair values.

Bonds and Stocks: The NAIC allows insurance companies to report the fair value determined by the SVO or to determine the fair value by using a permitted valuation method. The fair values of bonds and stocks are reported or determined using the following pricing sources: indexes, third party pricing services, brokers, external fund managers and internal models.

For fixed maturity securities (including redeemable preferred stock) not actively traded, fair values are estimated using values obtained from independent pricing services, or, in the case of private placements, estimated by discounting the expected future cash flows using current market rates applicable to the coupon rate, credit and maturity of the investments.

Short-Term Notes Receivable from Affiliates: The carrying amounts reported in the accompanying balance sheets for these financial instruments approximate their fair value.

Mortgage Loans on Real Estate: The fair values for mortgage loans on real estate are estimated utilizing discounted cash flow analyses, using interest rates reflective of current market conditions and the risk characteristics of the loans.

Policy Loans: The fair value of policy loans is assumed to equal their carrying amount.

Securities Lending Reinvested Collateral: The cash collateral from securities lending is reinvested in various short-term and long-term debt instruments. The fair values of these investments are determined using the methods described above under Cash, Cash Equivalents and Short-Term Investments and Bonds and Stocks.

Other Invested Assets: The fair values for other invested assets, which include investments in surplus notes issued by other insurance companies and fixed or variable rate investments with underlying characteristics of bonds were determined primarily by using indexes, third party pricing services, and internal models.

38

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

Derivative Financial Instruments: The estimated fair values of interest rate caps and options are based upon the latest quoted market price at the balance sheet date. The estimated fair values of swaps, including interest rate and currency swaps, are based on pricing models or formulas using current assumptions.

Credit Default Swaps: The estimated fair value of credit default swaps are based upon the pricing differential as of the balance sheet date for similar swap agreements.

Investment Contract Liabilities: Fair values for the Company’s liabilities under investment contracts, which include GICs and funding agreements, are estimated using discounted cash flow calculations, based on interest rates currently being offered for similar contracts with maturities consistent with those remaining for the contracts being valued. For investment contracts with no defined maturity, fair value is estimated to be the present surrender value.

Deposit-Type Contracts: The carrying amounts of deposit-type contracts reported in the accompanying balance sheets approximate their fair values.

Separate Account Assets and Annuity Liabilities: The fair value of separate account assets are based on quoted market prices. The fair value of separate account annuity liabilities approximate the fair value of the separate account assets less a provision for the present value of future profits related to the underlying contracts.

Surplus Notes: Fair values for surplus notes are estimated using a discounted cash flow analysis based on the Company’s current incremental borrowing rate for similar types of borrowing arrangements.

Receivable From/Payable to Parents, Subsidiaries and Affiliates: The carrying value of receivable from/payable to affiliates approximates their fair value.

Fair values for the Company’s insurance contracts other than investment-type contracts (including separate account universal life liabilities) are not required to be disclosed. However, the fair values of liabilities under all insurance contracts are taken into consideration in the Company’s overall management of interest rate risk, such that the Company’s exposure to changing interest rates is minimized through the matching of investment maturities with amounts due under insurance contracts.

39

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

The following sets forth a comparison of the fair values and carrying amounts of the Company’s financial instruments:

			December 31
	2010				2009
	Carrying Amount		Estimated Fair Value		Carrying Amount		Estimated Fair Value
Admitted assets
Cash, cash equivalents and short-term investments, other than affiliates	$	1,303,081	$	1,303,081	$	3,032,109	$	3,032,109
Short-term notes receivable from affiliates		270,000		270,000		880,200		880,200
Bonds, other than affiliates		46,921,343		46,976,603		47,035,463		45,386,770
Preferred stocks, other than affiliates		123,925		121,878		152,661		144,696
Common stocks, other than affiliates		358,631		358,631		389,485		389,485
Mortgage loans on real estate, other than affiliates		8,027,115		8,325,341		9,275,690		8,935,978
Other invested assets		181,095		177,761		175,168		164,109
Floors, options and swaptions		1,462		1,462		3,661		3,111
FDAs		61		61		299		126
Interest rate caps		2		2		37		—
Interest rate swaps		93,365		738,331		92,254		541,568
Currency swaps		7,425		75,889		8,130		109,956
Credit default swaps		4,687		6,402		369		2,141
Foreign currency forward		123		123		954		954
Policy loans		746,677		746,677		759,957		759,957
Securities lending reinvested collateral		3,956,880		3,954,149		—		—
Receivable from parent, subsidiaries and affiliates		248,839		248,839		187,751		187,751
Separate account assets		38,370,952		38,370,952		33,205,532		33,205,532
Liabilities
Investment contract liabilities		19,741,412		20,176,069		23,563,017		23,599,026
Floors, options and swaptions		462		462		550		—
FDAs		7,990		7,990		5,237		5,064
Interest rate caps		1		—		37		—
Interest rate swaps		82,389		398,272		158,871		528,815
Currency swaps		118,187		138,305		187,912		219,697
Credit default swaps		11,988		10,000		5,047		5,179
Foreign currency forward		154		154		79		79
Payable to parent, subsidiaries and affiliates		476,976		476,976		270,421		270,421
Separate account annuity liabilities		30,301,261		30,299,758		24,918,494		24,912,008
Surplus notes		150,000		151,932		150,000		144,191

40

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

The fair value of a financial instrument is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.

Fair values are based on quoted market prices when available. When market prices are not available, fair value is generally estimated using discounted cash flow analyses, incorporating current market inputs for similar financial instruments with comparable terms and credit quality (matrix pricing). In instances where there is little or no market activity for the same or similar instruments, the Company estimates fair value using methods, models and assumptions that management believes market participants would use to determine a current transaction price. These valuation techniques involve some level of management estimation and judgment which becomes significant with increasingly complex instruments or pricing models. Where appropriate, adjustments are included to reflect the risk inherent in a particular methodology, model or input employed.

The Company’s financial assets and liabilities carried at fair value are classified, for disclosure purposes, based on a hierarchy defined by SSAP No. 100. The hierarchy gives the highest ranking to fair values determined using unadjusted quoted prices in active markets for identical assets and liabilities (Level 1), and the lowest ranking to fair values determined using methodologies and models with unobservable inputs (Level 3). An asset’s or a liability’s classification is based on the lowest level input that is significant to its measurement. For example, a Level 3 fair value measurement may include inputs that are both observable (Levels 1 and 2) and unobservable (Level 3). The levels of the fair value hierarchy are as follows:

Level 1 -	Unadjusted quoted prices for identical assets or liabilities in active markets accessible at the measurement date.
Level 2 -	Quoted prices in markets that are not active or inputs that are observable either directly or indirectly for substantially the full term of the asset or liability. Level 2 inputs include the following:

a) Quoted prices for similar assets or liabilities in active markets

b) Quoted prices for identical or similar assets or liabilities in non-active markets

c) Inputs other than quoted market prices that are observable

d) Inputs that are derived principally from or corroborated by observable market data through correlation or other means

41

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

Level 3 - Prices or valuation techniques that require inputs that are both unobservable and significant to the overall fair value measurement. They reflect the Company’s own assumptions about the assumptions a market participant would use in pricing the asset or liability.

The Company accounts for its investments in affiliated common stock using the equity method of accounting; as such, they are not included in the following disclosures as they are not carried at fair value on the balance sheet.

Fair Value Measurements

During 2010, amendments were made to SSAP No. 100 to eliminate the requirement to differentiate and report fair value measurements on separate recurring and non-recurring schedules. Instead, for December 31, 2010, all fair value measurements will be reported on a single schedule by class. The 2009 schedules were not required to be restated.

42

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

The following table provides information about the Company’s financial assets and liabilities measured at fair value as of December 31, 2010:

	2010
	Level 1		Level 2		Level 3		Total
Assets:
Bonds
Industrial and miscellaneous	$	—	$	143,201	$	59,357	$	202,558
Hybrid securities		—		7,069		—		7,069
Total bonds		—		150,270		59,357		209,627
Preferred stock
Industrial and miscellaneous		—		—		1,236		1,236
Total preferred stock		—		—		1,236		1,236
Common stock
Mutual funds		40,951		68		—		41,019
Industrial and miscellaneous		90,568		160		226,884		317,612
Total common stock		131,518		228		226,884		358,631
Short-term investments
Government		—		65,069		—		65,069
Industrial and miscellaneous		—		768,270		—		768,270
Mutual funds		—		465,525		—		465,525
Sweep accounts		—		64,484		—		64,484
Total Short-term investments		—		1,363,348		—		1,363,348
Derivative assets		—		3,469		—		3,469
Separate account assets		31,597,665		5,398,091		793,212		37,788,968
Total assets	$	31,729,183	$	6,915,406	$	1,080,689	$	39,725,279
Liabilities:
Derivative liabilities	$	—	$	24,705	$	4,600	$	29,305
Separate account liabilities		7,302		5,405		—		12,707
Total liabilities	$	7,302	$	30,110	$	4,600	$	42,012

Bonds classified in Level 2 are valued using inputs from third party pricing services or corroborated broker quotes. Level 3 measurements for bonds are primarily those valued using non-corroborated broker quotes or internal modeling.

43

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

Common Stock in Level 3 is comprised primarily of shares in the Federal Home Loan Bank (FHLB) of Des Moines, which are valued at par as a proxy for fair value as they can only be redeemed by the bank. In addition, the Company owns some warrants that are valued using non-corroborated broker quotes.

Short-term investments are classified as Level 2 as they are carried at amortized cost, which approximates fair value.

For derivatives, those classified as Level 2 represent over-the-counter (OTC) contracts valued using pricing models based on the net present value of estimated future cash flows, directly observed prices from exchange-traded derivatives, other OTC trades, or external pricing services. The Level 3 derivative liability is a credit swap calculated by simulation using a series of market-consistent inputs to model the dynamics of the swap. The inputs are taken from market instruments to the extent that they exist.

The following table summarizes the changes in assets and liabilities classified in Level 3 for 2010:

	Balance at January 1, 2010		Transfers into Level 3		Transfers out of Level 3		Total Gains and (Losses) Included in Net income			Total Gains and (Losses) Included in Surplus			Purchases ,Issuances, Sales and Settlements			Balance at December  31, 2010
Bonds
RMBS	$	19,291	$	30,955	$	5,802	$	(21,711	)	$	14,201		$	14,785		$	51,719
Other		144,501		10,365		60,223		(7,297	)		(1,407	)		(78,301	)		7,638
Preferred Stock		6,162		1,236		6,162		—			(36	)		36			1,236
Common Stock		278,111		4,251		—		5,664			1,663			(62,805	)		226,884
Other Long Term		32,660		—		—		130			27			(32,817	)		—
Derivative Liabilities		—		—		—		—			—			(4,600	)		(4,600	)
Separate account assets		936,012		—		4,382		(102,331	)		273			(36,360	)		793,212
Total	$	1,416,737	$	46,807	$	76,569	$	(125,545	)	$	14,721		$	(200,062	)	$	1,076,089

The Company’s policy is to recognize transfers in and out of Level 3 as of the beginning of the reporting period.

Transfers in for bonds were the result of securities not carried at fair value as of December 31, 2009 subsequently changing to being carried at fair value as of December 31, 2010. Such changes were the result of a change in NAIC rating and impairment. In addition, several securities were valued using third party vendor inputs at December 31, 2009 and changed at December 31, 2010 to being valued using non-corroborated broker quotes, thus causing the transfer into Level 3.

44

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

Transfers out for bonds were attributable to securities being carried at fair value as of December 31, 2009, subsequently changing to being carried at amortized cost as of December 31, 2010. Such changes were the result of a change in NAIC rating and impairment. In addition, there were some securities that were valued using internal modeling at December 31, 2009. Those securities were valued using third party vendor inputs at December 31, 2010.

Transfers in for preferred stock were the result of securities not carried at fair value as of December 31, 2009 subsequently changing to being carried at fair value as of December 31, 2010. Such changes were the result of a change in the price source, change in NAIC rating and impairment.

Transfers out for preferred stock were attributable to securities being carried at fair value as of December 31, 2009, subsequently changing to being carried at amortized cost as of December 31, 2010. Such changes were the result of a change in the price source, change in NAIC rating and impairment.

Transfers in for common stock were the result of warrants being valued using third party vendor inputs at December 31, 2009. The valuation of those warrants changed at December 31, 2010 to using non-corroborated broker quotes.

Transfers out for separate account assets were attributable to bonds being valued using non-corroborated broker quotes at December 31, 2009, subsequently changing to being valued using third party vendor inputs at December 31, 2010.

45

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

The following table provides information about the Company’s financial assets and liabilities measured at fair value on a recurring basis as of December 31, 2009:

	2009
	Level 1		Level 2		Level 3		Total
Assets:
Equity securities	$	103,871	$	7,503	$	278,111	$	389,485
Other invested assets		—		—		32,660		32,660
Short-term investments		—		3,064,145		—		3,064,145
Derivative assets		—		13,462		—		13,462
Separate account assets		22,215,160		9,313,341		936,012		32,464,513
Total assets	$	22,319,031	$	12,398,451	$	1,246,783	$	35,964,265
Liabilities:
Derivative liabilities	$	—	$	64,812	$	—	$	64,812
Total liabilities	$	—	$	64,812	$	—	$	64,812

Fair Value Measurements in Level 3 of the Fair Value Hierarchy

The following table summarizes the changes in assets and liabilities classified in Level 3 for 2009:

	Equity Securities			Short-term Investments			Other Invested Assets			Separate Account Assets			Total
Balance at January 1, 2009	$	295,552		$	42,444		$	—		$	—		$	337,996
Change in realized gains/losses included in net income		(6,155	)		—			—			(80,693	)		(86,848	)
Change in unrealized gains/losses included in surplus		5,177			284			(27	)		—			5,434
Net purchases (sales)		(28,878	)		(42,728	)		32,687			(229,258	)		(268,177	)
Net transfers in to Level 3		12,415			—			—			1,245,963			1,258,378
Balance at December 31, 2009	$	278,111		$	—		$	32,660		$	936,012		$	1,246,783
Total gains/losses included in income attributable to instruments held at the reporting date	$	(2,156	)	$	—		$	—		$	—		$	(2,156	)

46

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

4. Fair Values of Financial Instruments (continued)

Assets measured at fair value on a non-recurring basis

For the year ended December 31, 2009, the Company reported certain assets and liabilities at fair value on a non-recurring basis; that is, the instruments are not measured at fair value on an ongoing basis but are subject to fair value adjustments in certain circumstances (for example, when there is evidence of impairment). The Company reported the following financial instruments at fair value on a non-recurring basis:

Description	December 31, 2009		Level 1		Level 2		Level 3		Total Gains (Losses)
Fixed maturities	$	290,192	$	–	$	120,238	$	169,954	$	(104,050	)
Derivative liabilities		26,899		–		26,899		–		–

5. Investments

The carrying amounts and estimated fair value of investments in bonds and preferred stock are as follows:

	Carrying Amount		Gross Unrealized Gains		Gross Unrealized Losses 12 Months or More		Gross Unrealized Losses less Than 12 Months		Estimated Fair Value
December 31, 2010
Unaffiliated bonds:
United States Government and agencies	$	3,160,171	$	77,718	$	4,518	$	75,826	$	3,157,545
State, municipal and other government		836,397		49,894		19,517		6,180		860,594
Hybrid securities		1,557,055		17,968		226,807		1,009		1,347,207
Industrial and miscellaneous		27,657,173		1,553,520		106,995		230,233		28,873,465
Mortgage and other asset-backed securities		13,710,547		296,594		1,227,663		41,686		12,737,792
		46,921,343		1,995,694		1,585,500		354,934		46,976,603
Unaffiliated preferred stocks		123,925		9,783		10,723		1,107		121,878
	$	47,045,268	$	2,005,477	$	1,596,223	$	356,041	$	47,098,481

47

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

	Carrying Amount		Gross Unrealized Gains		Gross Unrealized Losses 12 Months or More		Gross Unrealized Losses less Than 12 Months		Estimated Fair Value
December 31, 2009
Unaffiliated bonds:
United States Government and agencies	$	2,213,602	$	46,272	$	10,359	$	57,837	$	2,191,678
State, municipal and other government		864,106		58,075		36,447		6,506		879,228
Hybrid securities		1,777,764		15,566		322,069		421		1,470,840
Industrial and miscellaneous		27,005,598		1,585,453		377,181		61,228		28,152,642
Mortgage and other asset-backed securities		15,174,393		165,590		2,537,314		110,287		12,692,382
		47,035,463		1,870,956		3,283,370		236,279		45,386,770
Unaffiliated preferred stocks		152,661		13,428		13,976		7,417		144,696
	$	47,188,124	$	1,884,384	$	3,297,346	$	243,696	$	45,531,466

At December 31, 2010 and 2009, respectively, for bonds and preferred stocks that have been in a continuous loss position for greater than or equal to twelve months, the Company held 784 and 1,417 securities with a carrying amount of $9,237,482 and $15,724,863 and an unrealized loss of $1,596,223 and $3,297,346 with an average price of 82.7 and 79.0 (fair value/amortized cost). Of this portfolio, 67.8% and 73.4% were investment grade with associated unrealized losses of $750,760 and $1,964,692, respectively.

At December 31, 2010 and 2009, respectively, for bonds and preferred stocks that have been in a continuous loss position for less than twelve months, the Company held 1,224 and 527 securities with a carrying amount of $10,099,730 and $5,312,143 and an unrealized loss of $356,041 and $243,696 with an average price of 96.5 and 95.4 (fair value/amortized cost). Of this portfolio, 97.3% and 96.3% were investment grade with associated unrealized losses of $345,226 and $209,917, respectively.

At December 31, 2010 and 2009, respectively, for common stocks that have been in a continuous loss position for greater than or equal to twelve months, the Company held 2 and 5 securities with a cost of $15 and $35 and an unrealized loss of $9 and $17 with an average price of 38.2 and 52.5 (fair value/cost).

At December 31, 2010 and 2009, respectively, for common stocks that have been in a continuous loss position for less than twelve months, the Company held 25 and 35 securities with a cost of $23,086 and $41,570 and an unrealized loss of $1,002 and $1,112 with an average price of 95.7 and 97.3 (fair value/cost).

48

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The estimated fair value of bonds, preferred stocks and common stocks with gross unrealized losses at December 31, 2010 and 2009 is as follows:

	Losses 12 Months or More		Losses Less Than 12 Months		Total
December 31, 2010
Unaffiliated bonds:
United States Government and agencies	$	237,897	$	1,386,362	$	1,624,259
State, municipal and other government		97,950		169,282		267,232
Hybrid securities		1,043,259		37,791		1,081,050
Industrial and miscellaneous		1,036,864		6,796,934		7,833,798
Mortgage and other asset-backed securities		5,180,283		1,342,227		6,522,510
		7,596,253		9,732,596		17,328,849
Unaffiliated preferred stocks		45,006		11,093		56,099
Unaffiliated common stocks		6		22,084		22,090
	$	7,641,265	$	9,765,773	$	17,407,038

	Losses 12 Months or More		Losses Less Than 12 Months		Total
December 31, 2009
Unaffiliated bonds:
United States Government and agencies	$	361,036	$	952,444	$	1,313,480
State, municipal and other government		170,904		121,643		292,547
Hybrid securities		1,297,347		15,671		1,313,018
Industrial and miscellaneous		3,594,291		2,417,578		6,011,869
Mortgage and other asset-backed securities		6,956,857		1,539,597		8,496,454
		12,380,435		5,046,933		17,427,368
Unaffiliated preferred stocks		47,082		21,515		68,597
Unaffiliated common stocks		18		40,458		40,476
	$	12,427,535	$	5,108,906	$	17,536,441

49

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The carrying amount and estimated fair value of bonds at December 31, 2010, by contractual maturity, are shown below. Expected maturities may differ from contractual maturities because certain borrowers have the right to call or prepay obligations with or without call or prepayment penalties.

	Carrying Amount		Estimated Fair Value
Due in one year or less	$	957,586	$	976,255
Due after one year through five years		9,687,493		10,172,757
Due after five years through ten years		9,031,523		9,436,666
Due after ten years		13,534,194		13,653,133
		33,210,796		34,238,811
Mortgage and other asset-backed securities		13,710,547		12,737,792
	$	46,921,343	$	46,976,603

The Company closely monitors below investment grade holdings and those investment grade issuers where the Company has concerns. The Company also regularly monitors industry sectors. Non-structured securities in unrealized loss positions that are considered other-than-temporary are written down to fair value. Structured securities considered other-than-temporarily impaired are written down to discounted estimated cash flows if the impairment is the result of cash flow analysis. If the Company has an intent to sell or lack of ability to hold a structured security, it is written down to fair value. The Company considers relevant facts and circumstances in evaluating whether the impairment is other-than-temporary including: (1) the probability of the Company collecting all amounts due according to the contractual terms of the security in affect at the date of acquisition; (2) the Company’s decision to sell a security prior to its maturity at an amount below its carrying amount; and (3) the Company’s ability to hold a structured security for a period of time to allow for recovery of the value to its carrying amount. Additionally, financial condition, near term prospects of the issuer and nationally recognized credit rating changes are monitored. For structured securities, cash flow trends and underlying levels of collateral are monitored. The Company will record a charge to the statement of operations to the extent that these securities are subsequently determined to be other-than-temporarily impaired.

Banking

At December 31, 2010, the Company’s banking sector portfolio had investments in an unrealized loss position which had a fair value of $1,622,486 and a carrying value of $1,880,648, resulting in a gross unrealized loss of $258,162. The banking sub-sector in the Company’s portfolio is large, diverse and of high quality. The unrealized losses in the banking sub-sector primarily reflect the size of the Company’s holdings, low floating rate coupons on some securities and credit spread widening on deeply subordinated securities.

50

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

As a whole, the sub-sector has been volatile in 2010 as Sovereign debt crises in Greece and Ireland have reintroduced liquidity fears into the market and concern has grown that other peripheral European countries may need financial bail-out packages. Subordinated securities, specifically, have become even more volatile following successful attempts by the European Commission to impose “burden sharing” on the subordinated securities of those banks receiving significant state-aid as a result of the financial crisis. Furthermore, new legislation introduced in Germany and Ireland gives those respective governments wide discretion to impose “burden sharing” on subordinated bondholders in order to quickly stabilize or wind-up troubled banks, and other countries will likely follow suit. While these measures have made existing subordinated securities more volatile in the near-term, new, more stringent, global legislation on capital and liquidity requirements is intended to reduce overall risk in the sector going forward. Furthermore, Central Banks appear committed to providing liquidity to the market and as a result asset write-downs and credit losses have diminished substantially in all but the most troubled countries. The value of the Company’s investments in deeply subordinated securities in the financial services sector may be significantly impacted if issuers of certain securities with optional deferral features exercise the option to defer coupon payments or are required to defer as a condition of receiving government aid. The Company evaluated the near-term prospects of the issuers in relation to the severity and duration of the unrealized loss and does not consider those investments to be impaired as of December 31, 2010.

Subprime Mortgages

At December 31, 2010, the Company’s asset-backed securities (ABS) subprime mortgage portfolio had investments in an unrealized loss position which had a fair value of $806,127 and a carrying value of $1,014,495, resulting in a gross unrealized loss of $208,368. The Company does not currently invest in or originate whole loan residential mortgages. The Company categorizes asset backed securities issued by a securitization trust as having subprime mortgage exposure when the average credit score of the underlying mortgage borrowers in a securitization trust is below 660 at issuance. The Company also categorizes asset backed securities issued by a securitization trust with second lien mortgages as subprime mortgage exposure, even though a significant percentage of second lien mortgage borrowers may not necessarily have credit scores below 660 at issuance. The Company does not have any “direct” residential mortgages to subprime borrowers outside of the ABS structures.

51

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

All ABS subprime mortgage securities are monitored and reviewed on a monthly basis. Detailed cash flow models using the current collateral pool and capital structure on the portfolio are performed quarterly. Model output is generated under base and several stress-case scenarios. The Company’s internal ABS-housing asset specialists utilize widely recognized industry modeling software to perform a loan-by-loan, bottom-up approach to modeling. Key assumptions used in the models are projected defaults, loss severities and prepayments. Each of these key assumptions varies greatly based on the significantly diverse characteristics of the current collateral pool for each security. Loan-to-value, loan size and borrower credit history are some of the key characteristics used to determine the level of assumption that is utilized. Defaults were estimated by identifying the loans that are in various delinquency buckets and defaulting a certain percentage of them over the near-term and long-term. Assumed defaults on delinquent loans are dependent on the specific security’s collateral attributes and historical performance.

Loss severity assumptions were determined by observing historical rates from broader market data while being adjusted for specific pool performance, collateral type, mortgage insurance and estimated loan modifications. Prepayments were estimated by examining historical averages of prepayment activity on the underlying collateral. Once the entire pool is modeled, the results are closely analyzed by the Company’s internal asset specialist to determine whether or not a particular tranche or holding is at risk for not collecting all contractual cash flows taking into account the seniority, and other terms of the tranches held. If cash flow models indicate a credit event will impact future cash flows and the Company does not have the intent to sell the security and does have the intent and ability to hold the security, the security is impaired to discounted cash flows.

The unrealized loss is primarily due to decreased liquidity, increased credit spreads in the market, slower prepayments and increased expected losses on loans within the underlying pools. Expected losses within the underlying pools are generally higher than original expectations, primarily in certain later-vintage adjustable rate mortgage loan pools, which has led to some rating downgrades in these securities. As the remaining unrealized losses in the ABS subprime mortgage portfolio relate to holdings where the Company expects to receive full principal and interest, the Company does not consider the underlying investments to be impaired as of December 31, 2010.

52

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

Commercial Mortgage-Backed Securities (CMBS)

At December 31, 2010, the Company’s CMBS portfolio had investments in an unrealized loss position which had a fair value of $1,671,381 and a carrying value of $1,893,326, resulting in a gross unrealized loss of $221,945. CMBS are securitizations of underlying pools of mortgages on commercial real estate. The underlying mortgages have varying risk characteristics and are pooled together and sold in different rated tranches. The Company’s CMBS includes conduit, large loan, single borrower, franchise loan, agencies, small loan and commercial real estate collateralized debt obligations (CDOs).

CMBS are monitored and reviewed on a monthly basis. Detailed cash flow models using the current collateral pool and capital structure on the portfolio are performed quarterly. Model output is generated under base and several stress-case scenarios by the Company’s internal CMBS asset specialists. For conduit securities, a widely recognized industry modeling software is used to perform a loan-by-loan, bottom-up approach. For non-conduit securities, a CMBS asset specialist works closely with the Company’s real estate valuation group to determine underlying asset valuation and risk. Both methodologies incorporate external estimates on the property market, capital markets, property cash flows and loan structure. Results are then closely analyzed by the asset specialist to determine whether or not a principal or interest loss is expected to occur. If cash flow models indicate a credit event will impact future cash flows and the Company does not have the intent to sell the security and does have the intent and ability to hold the security, the security is impaired to discounted cash flows.

Over the past 24 months, the commercial real estate market experienced a deterioration in property level fundamentals, which has led to an increase in CMBS loan-level delinquencies. The introduction of the 20% and 30% credit enhanced classes within the 2005-2008 vintage deals provide some offset to these negative fundamentals. Despite advancements in the availability of financing for commercial real estate, as evidenced by the gradual reopening of the CMBS markets, the lending market remains limited as lenders continue to be more conservative with underwriting standards. Moreover, property transactions have increased but still remain low relative to historical standards. While liquidity has improved within the CMBS market, a broad re-pricing of risk has kept credit spreads across the subordinate CMBS tranches at wide levels. As the remaining unrealized losses in the CMBS portfolio relate to holdings where the company expects to receive full principal and interest, the Company does not consider the underlying investments to be impaired as of December 31, 2010.

53

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

Residential Mortgage-Backed Securities (RMBS) Sector

At December 31, 2010, the Company’s RMBS sector portfolio had investments in an unrealized loss position which had a fair value of $2,671,967, and a carrying value of $3,354,983, resulting in a gross unrealized loss of $683,016. RMBS are securitizations of underlying pools of non-commercial mortgages on real estate. The underlying residential mortgages have varying credit ratings and are pooled together and sold in tranches. The Company’s RMBS portfolio includes collateralized mortgage obligations (CMOs), government sponsored enterprise (GSE) guaranteed passthroughs, prime jumbo passthroughs, Alt-A RMBS, negative amortization RMBS and reverse mortgage RMBS.

All RMBS of the Company are monitored and reviewed on a monthly basis. Detailed cash flow models using the current collateral pool and capital structure on the portfolio are performed quarterly. Model output is generated under base and several stress-case scenarios. The Company’s internal RMBS asset specialists utilize widely recognized industry modeling software to perform a loan-by-loan, bottom-up approach to modeling. Key assumptions used in the models are projected defaults, loss severities and prepayments.

Each of these key assumptions varies greatly based on the significantly diverse characteristics of the current collateral pool for each security. Loan-to-value, loan size and borrower credit history are some of the key characteristics used to determine the level of assumption that is utilized. Defaults were estimated by identifying the loans that are in various delinquency buckets and defaulting a certain percentage of them over the near-term and long-term. Assumed defaults on delinquent loans are dependent on the specific security’s collateral attributes and historical performance.

Loss severity assumptions were determined by obtaining historical rates from broader market data and by adjusting those rates for vintage, specific pool performance, collateral type, mortgage insurance and estimated loan modifications. Prepayments were estimated by examining historical averages of prepayment activity on the underlying collateral. Once the entire pool is modeled, the results are closely analyzed by the Company’s internal asset specialists to determine whether or not a particular tranche or holding is at risk for not collecting all contractual cash flows, taking into account the seniority and other terms of the tranches held. If cash flow models indicate a credit event will impact future cash flows and the Company does not have the intent to sell the security and does have the intent and ability to hold the security, the security is impaired to discounted cash flows.

54

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The pace of deterioration in the housing market began to stabilize in late 2009 and continued in 2010. Even with the stabilization, fundamentals in RMBS continue to be weak, which impacts the magnitude of the unrealized loss. Delinquencies and severities in property liquidations remain at an elevated level, while prepayments remain at historically low levels. Due to the weak fundamental situation, reduced liquidity and the requirement for higher yields due to market uncertainty, credit spreads remain elevated across the asset class. In addition, a high percentage of the Company’s RMBS portfolio is comprised of floating rate securities, which has resulted in higher unrealized losses relative to fixed rate securities but not necessarily higher default losses. As the remaining unrealized losses in the RMBS portfolio relate to holdings where the Company expects to receive full principal and interest, the Company does not consider the underlying investments to be impaired as of December 31, 2010.

The following tables provide the aggregate totals for loan-backed securities with a recognized OTTI due to intent to sell or lack of intent and ability to hold, in which the security is written down to fair value.

	Amortized  Cost Basis Before OTTI		OTTI Recognized in Loss
			Interest		Non-interest		Fair Value
Year Ended December 31, 2010
OTTI recognized 1st quarter:
Intent to sell	$	4,379	$	973	$	—	$	3,406
Total 1st quarter OTTI on loan-backed securities		4,379		973		—		3,406
OTTI recognized 2nd quarter:
Intent to sell		17,316		301		—		17,015
Inability or lack of intent to retain the investment in the security for a period of time sufficient to recover the amortized cost basis		6		—		6		0
Total 2nd quarter OTTI on loan-backed securities		17,322		301		6		17,015
Aggregate total	$	21,701	$	1,274	$	6	$	20,421

55

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

	Amortized  Cost Basis Before OTTI		OTTI Recognized in Loss
			Interest		Non-interest		Fair Value
Year Ended December 31, 2009
OTTI recognized 3rd quarter:
Intent to sell	$	21,033	$	—	$	5,508	$	15,525
Total 3rd quarter OTTI on loan-backed securities		21,033		—		5,508		15,525
OTTI recognized 4th quarter:
Intent to sell		179,064		—		66,154		112,910
Total 4th quarter OTTI on loan-backed securities		179,064		—		66,154		112,910
Aggregate total	$	200,097	$	—	$	71,662	$	128,435

The following tables provide the aggregate totals for loan-backed securities with a recognized OTTI due to the Company’s cash flow analysis, in which the security is written down to estimated future cash flows discounted at the security’s effective yield.

	Amortized Cost before Current Period OTTI		Recognized OTTI		Amortized Cost After OTTI		Fair Value
Year ended December 31, 2010
1st quarter present value of cash flows expected to be less than the amortized cost basis	$	578,055	$	55,253	$	522,802	$	330,810
2nd quarter present value of cash flows expected to be less than the amortized cost basis		343,146		24,294		318,852		217,741
3rd quarter present value of cash flows expected to be less than the amortized cost basis		648,299		44,545		603,754		489,879
4th quarter present value of cash flows expected to be less than the amortized cost basis		744,823		29,278		715,545		563,667
Aggregate total	$	2,314,323	$	153,370	$	2,160,953	$	1,602,097

56

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

	Amortized Cost before Current Period OTTI		Recognized OTTI		Amortized Cost After OTTI		Fair Value
Year ended December 31, 2009
3rd quarter present value of cash flows expected to be less than the amortized cost basis	$	320,333	$	27,156	$	293,177	$	153,730
4th quarter present value of cash flows expected to be less than the amortized cost basis		622,868		89,717		533,151		253,458
Aggregate total	$	943,201	$	116,873	$	826,328	$	407,188

57

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The following loan-backed and structured securities were held at December 31, 2010, for which an OTTI had been previously recognized:

CUSIP	Amortized Cost Before Current Period OTTI		Present Value of Projected Cash Flows		Recognized OTTI		Amortized Cost After OTTI		Fair Value at Time  of OTTI		Quarter in which Impairment Occurred
000759BP4	$	788	$	785	$	3	$	785	$	625	1Q 2010
02148AAA4		51,172		50,652		520		50,652		33,152	1Q 2010
02148YAJ3		8,309		8,128		181		8,128		6,809	1Q 2010
045427AE1		3,371		1,805		1,566		1,805		610	1Q 2010
12640PAA3		9,684		9,480		204		9,480		8,902	1Q 2010
126670ZN1		26,523		21,352		5,171		21,352		3,899	1Q 2010
12667G5G4		23,783		23,533		250		23,533		21,180	1Q 2010
126685DZ6		6,759		6,287		472		6,287		5,438	1Q 2010
225470FJ7		9,677		9,494		183		9,494		7,925	1Q 2010
225470YD9		60,770		59,922		848		59,922		37,312	1Q 2010
22942KCA6		22,560		22,305		255		22,305		16,542	1Q 2010
23245CAF7		256		246		10		246		586	1Q 2010
32027LAG0		110		94		16		94		57	1Q 2010
32028TAF4		171		85		86		85		100	1Q 2010
35729PPZ7		17,076		14,880		2,196		14,880		248	1Q 2010
361856EC7		25,782		25,461		321		25,461		16,478	1Q 2010
3622MAAF8		205		134		71		134		52	1Q 2010
38011AAC8		2,581		2,563		18		2,563		2,023	1Q 2010
43710LAF1		82		8		74		8		34	1Q 2010
45661EAE4		27,998		20,271		7,727		20,271		9,966	1Q 2010
46628SAJ2		10,507		10,154		353		10,154		6,420	1Q 2010
50177AAM1		9,810		2,378		7,432		2,378		1,242	1Q 2010
525170CG9		1,722		1,657		65		1,657		1,404	1Q 2010
525221GR2		6,622		3,934		2,688		3,934		1,875	1Q 2010
525221HE0		15,734		11,847		3,887		11,847		4,671	1Q 2010
52524MAW9		10,557		9,991		566		9,991		3,594	1Q 2010
52524YAA1		42,308		42,286		22		42,286		33,282	1Q 2010
655374AA4		2,702		2,353		349		2,353		1,117	1Q 2010
68400DAG9		2,794		1,924		870		1,924		106	1Q 2010
70557RAB6		37,812		32,192		5,620		32,192		18,685	1Q 2010
74925FAA1		17,548		16,761		787		16,761		15,542	1Q 2010
76110WPD2		3,676		3,387		289		3,387		2,855	1Q 2010
76110WQB5		15,198		14,267		931		14,267		12,048	1Q 2010
761118RM2		3,297		3,186		111		3,186		1,587	1Q 2010
761118VY1		28,164		25,601		2,563		25,601		11,604	1Q 2010
81379EAD4		5,191		3,589		1,602		3,589		99	1Q 2010
86357UAA9		23,809		21,484		2,325		21,484		16,973	1Q 2010
86357UBM2		4,156		3,750		406		3,750		3,020	1Q 2010
86358EZU3		8,992		7,205		1,787		7,205		2,672	1Q 2010
86365EAA5		12,137		10,952		1,185		10,952		8,530	1Q 2010
86365EAC1		5,116		4,616		500		4,616		3,718	1Q 2010
86365KAA1		4,184		3,775		409		3,775		2,989	1Q 2010
93935FAA9		5,241		5,003		238		5,003		2,472	1Q 2010
000759BP4		757		700		57		700		589	2Q 2010
02148AAA4		48,811		46,735		2,076		46,735		33,688	2Q 2010
02148YAJ3		7,973		7,794		179		7,794		6,567	2Q 2010
05948KL31		18,007		17,283		724		17,283		11,108	2Q 2010
059494AA2		41,693		41,000		693		41,000		31,082	2Q 2010
05953LAH2		1,317		888		429		888		319	2Q 2010
12668VAF6		8,391		8,231		160		8,231		4,535	2Q 2010
20173TAM7		7,151		5,554		1,597		5,554		1,032	2Q 2010
225470FJ7		9,025		8,578		447		8,578		8,170	2Q 2010

58

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

CUSIP	Amortized Cost Before Current Period OTTI		Present Value of Projected Cash Flows		Recognized OTTI		Amortized Cost After OTTI		Fair Value at Time  of OTTI		Quarter in which Impairment Occurred
225470U27		6,061		5,459		602		5,459		4,457	2Q 2010
22942KCA6		21,269		21,106		163		21,106		15,188	2Q 2010
32054YAD5		353		160		193		160		104	2Q 2010
35729PPZ7		14,854		13,465		1,389		13,465		920	2Q 2010
36244SAE8		901		881		20		881		508	2Q 2010
46629YAK5		4,361		1,232		3,129		1,232		795	2Q 2010
50177AAM1		2,227		1,477		750		1,477		1,291	2Q 2010
525170CG9		1,584		1,292		292		1,292		1,635	2Q 2010
525221HE0		11,184		6,764		4,420		6,764		5,228	2Q 2010
52522QAM4		121,936		116,652		5,284		116,652		83,155	2Q 2010
65536PAA8		3,451		3,224		227		3,224		2,937	2Q 2010
761118RM2		3,103		3,049		54		3,049		1,563	2Q 2010
86358EZU3		7,161		6,018		1,143		6,018		1,603	2Q 2010
000759BP4		674		657		17		657		572	3Q 2010
02148AAA4		44,694		41,915		2,779		41,915		35,127	3Q 2010
02148YAJ3		7,636		7,630		6		7,630		5,659	3Q 2010
05948KV63		13,694		13,656		38		13,656		12,859	3Q 2010
059494AA2		39,536		39,315		221		39,315		30,326	3Q 2010
059512AP8		1,912		1,732		180		1,732		744	3Q 2010
05953LAH2		832		708		124		708		304	3Q 2010
12638DAA4		72,351		64,487		7,864		64,487		58,004	3Q 2010
12640PAA3		7,475		7,142		333		7,142		7,293	3Q 2010
12667G5G4		24,540		24,439		101		24,439		24,121	3Q 2010
126685DZ6		5,919		5,603		316		5,603		4,887	3Q 2010
12669GTS0		50,815		47,578		3,237		47,578		25,003	3Q 2010
20173TAM7		5,443		1,960		3,483		1,960		1,077	3Q 2010
225470FJ7		8,417		8,408		9		8,408		8,621	3Q 2010
225470T94		6,996		6,650		346		6,650		5,183	3Q 2010
225470YD9		56,415		53,591		2,824		53,591		39,237	3Q 2010
225492AE7		21,757		21,547		210		21,547		18,885	3Q 2010
22942KCA6		20,247		20,203		44		20,203		15,799	3Q 2010
3622EEAA0		29,835		28,729		1,106		28,729		27,151	3Q 2010
36244SAE8		847		820		27		820		542	3Q 2010
38011AAC8		2,513		2,451		62		2,451		1,914	3Q 2010
46631QAR3		7,471		2,341		5,130		2,341		2,436	3Q 2010
52108MDU4		2,938		295		2,643		295		432	3Q 2010
525170CG9		1,202		1,082		120		1,082		1,185	3Q 2010
52519LAA6		110,126		101,397		8,729		101,397		87,934	3Q 2010
525221HE0		6,238		5,615		623		5,615		4,141	3Q 2010
65536PAA8		1,894		1,747		147		1,747		1,641	3Q 2010
75970JAJ5		5,448		4,933		515		4,933		2,733	3Q 2010
75970QAH3		7,000		6,369		631		6,369		3,783	3Q 2010
761118AH1		31,985		31,648		337		31,648		26,663	3Q 2010
761118VY1		23,714		22,571		1,143		22,571		11,123	3Q 2010
92911GAA7		1,688		1,015		673		1,015		1,121	3Q 2010
92922FZ27		23,995		23,693		302		23,693		21,808	3Q 2010
939336Q55		604		596		8		596		279	3Q 2010
05535DAM6		476		415		61		415		318	3Q 2010
05953YAG6		1,788		1,787		1		1,787		1,619	4Q 2010**
059515AC0		8,952		8,942		10		8,942		5,480	4Q 2010
36245CAC6		2,589		1,121		1,468		1,121		257	4Q 2010
52524YAA1		3,033		3,012		21		3,012		2,837	4Q 2010

59

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

CUSIP	Amortized Cost Before Current Period OTTI		Present Value of Projected Cash Flows		Recognized OTTI		Amortized Cost After OTTI		Fair Value at Time  of OTTI		Quarter in which Impairment Occurred
61754HAB8		2,987		2,790		197		2,790		1,467	4Q 2010**
02148YAJ3		7,480		7,334		146		7,334		5,783	4Q 2010
05530PAA0		2,460		2,395		65		2,395		2,046	4Q 2010
059494AA2		37,667		37,657		10		37,657		30,418	4Q 2010
059515AC0		8,938		7,602		1,336		7,602		5,504	4Q 2010
05953LAH2		626		432		194		432		273	4Q 2010
05953YAG6		1,732		1,553		179		1,553		1,575	4Q 2010
12638DAA4		61,724		61,571		153		61,571		56,681	4Q 2010
12667G5G4		12,382		12,239		143		12,239		11,936	4Q 2010
12668RAA6		27,353		25,747		1,606		25,747		16,167	4Q 2010
12669GTS0		46,681		44,524		2,157		44,524		24,463	4Q 2010
14984WAA8		7,942		7,730		212		7,730		6,113	4Q 2010
225470U27		5,279		5,139		140		5,139		4,314	4Q 2010
225470YD9		51,189		50,912		277		50,912		37,621	4Q 2010
22942KCA6		19,399		18,120		1,279		18,120		14,757	4Q 2010
36245CAC6		1,112		833		279		833		258	4Q 2010
36245RAA7		3,755		3,495		260		3,495		2,677	4Q 2010
39539KAF0		10,205		9,957		248		9,957		8,804	4Q 2010
41161MAC4		54,375		52,192		2,183		52,192		33,461	4Q 2010
45661EAE4		8,907		2,644		6,263		2,644		2,517	4Q 2010
52519LAA6		97,842		97,267		575		97,267		84,903	4Q 2010
525221GR2		3,510		1,336		2,174		1,336		1,054	4Q 2010
525221HE0		5,322		3,506		1,816		3,506		3,634	4Q 2010
52522QAM4		106,741		105,722		1,019		105,722		81,409	4Q 2010
52524YAA1		32,721		31,200		1,521		31,200		30,754	4Q 2010
61754HAB8		2,771		2,281		490		2,281		1,448	4Q 2010
74925FAA1		14,656		14,038		618		14,038		13,792	4Q 2010
759676AJ8		6,794		6,391		403		6,391		4,825	4Q 2010
75971EAF3		6,200		6,088		112		6,088		3,542	4Q 2010
761118VY1		21,814		20,938		876		20,938		11,309	4Q 2010
81379EAD4		3,583		3,258		325		3,258		348	4Q 2010
863592AP6		21,291		21,076		215		21,076		19,735	4Q 2010
863592AQ4		9,443		9,303		140		9,303		8,654	4Q 2010
92911CAA6		241		94		147		94		9	4Q 2010
92922FZ27		22,761		22,760		1		22,760		20,920	4Q 2010
939336Q55		576		558		18		558		302	4Q 2010
02148AAA4		56,623		55,412		1,211		55,412		27,639	3Q 2009
02148YAJ3		10,038		9,635		403		9,635		5,095	3Q 2009
045427AE1		5,981		4,341		1,640		4,341		388	3Q 2009
126670ZN1		32,849		28,835		4,014		28,835		2,148	3Q 2009
12668VAF6		14,078		9,775		4,303		9,775		3,695	3Q 2009
225470FJ7		11,026		10,842		184		10,842		6,252	3Q 2009
225470T94		9,057		8,721		336		8,721		4,335	3Q 2009
22942KCA6		27,233		25,136		2,097		25,136		14,065	3Q 2009
32027LAG0		156		153		3		153		55	3Q 2009
32028TAF4		214		210		4		210		167	3Q 2009
35729PPC8		3,943		727		3,216		727		169	3Q 2009
3622MAAF8		300		294		6		294		73	3Q 2009
40430FAF9		2,814		591		2,223		591		93	3Q 2009
43710LAF1		152		150		2		150		94	3Q 2009
46628SAJ2		11,798		11,254		544		11,254		4,475	3Q 2009
576435AT8		494		484		10		484		303	3Q 2009

60

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

CUSIP	Amortized Cost Before Current Period OTTI		Present Value of Projected Cash Flows		Recognized OTTI		Amortized Cost After OTTI		Fair Value at Time  of OTTI		Quarter in which Impairment Occurred
655374AA4		3,374		3,252		122		3,252		1,663	3Q 2009
86358EZU3		20,660		10,929		9,731		10,929		3,505	3Q 2009
939336Q55		725		687		38		687		255	3Q 2009
02148AAA4		55,412		54,674		738		54,674		30,484	3Q 2009
059512AP8		6,545		2,207		4,338		2,207		745	3Q 2009
12668VAF6		9,775		9,187		588		9,187		4,470	3Q 2009
225470FJ7		10,842		10,455		387		10,455		6,985	3Q 2009
22942KCA6		25,136		24,544		592		24,544		14,572	3Q 2009
23245CAF7		440		317		123		317		90	3Q 2009
3622MAAF8		294		248		46		248		48	3Q 2009
36244SAE8		1,000		949		51		949		481	3Q 2009
43710LAF1		150		107		43		107		113	3Q 2009
52524MAW9		11,476		11,109		367		11,109		3,902	3Q 2009
68400DAG9		4,806		3,554		1,252		3,554		193	3Q 2009
70557RAB6		41,797		37,940		3,857		37,940		20,360	3Q 2009
86358EZU3		10,929		9,287		1,642		9,287		1,747	3Q 2009
939336Q55		687		680		7		680		260	3Q 2009
059494AA2		45,468		44,726		742		44,726		30,478	4Q 2009
05951VAV1		60,026		59,859		167		59,859		34,196	4Q 2009
05948KV63		15,678		15,283		395		15,283		11,397	4Q 2009
126670ZN1		28,832		26,567		2,265		26,567		3,802	4Q 2009
126685DZ6		8,557		6,962		1,595		6,962		5,593	4Q 2009
23245CAF7		304		267		37		267		214	4Q 2009
12667G5G4		28,792		27,581		1,211		27,581		24,737	4Q 2009
02148AAA4		53,080		52,679		401		52,679		32,386	4Q 2009
02148YAJ3		9,305		8,787		518		8,787		6,122	4Q 2009
045427AE1		4,341		3,378		963		3,378		517	4Q 2009
12640PAA3		11,545		10,987		558		10,987		9,882	4Q 2009
225470FJ7		10,116		10,075		41		10,075		7,421	4Q 2009
32027LAG0		147		116		31		116		46	4Q 2009
32028TAF4		198		182		16		182		125	4Q 2009
38011AAC8		2,961		2,627		334		2,627		1,992	4Q 2009
361856EC7		31,354		26,889		4,465		26,889		14,755	4Q 2009
3622MAAF8		233		218		15		218		55	4Q 2009
43710LAF1		96		91		5		91		80	4Q 2009
52524YAA1		46,921		46,677		244		46,677		35,812	4Q 2009
52524MAW9		10,923		10,743		180		10,743		4,023	4Q 2009
576435AT8		467		397		70		397		284	4Q 2009
655374AA4		3,144		2,723		421		2,723		1,573	4Q 2009
68400DAG9		3,535		2,809		726		2,809		180	4Q 2009
761118VY1		30,381		29,354		1,027		29,354		12,445	4Q 2009
86358EZU3		9,243		9,032		211		9,032		222	4Q 2009
225470T94		8,516		7,425		1,091		7,425		5,324	4Q 2009
225470U27		7,991		6,431		1,560		6,431		4,577	4Q 2009
933637AJ9		3,782		3,505		277		3,505		2,574	4Q 2009

** Impairment amount was recorded as a part of the cumulative effect of adoption of amendments to SSAP No. 91R, which resulted in the cash collateral received from derivative counterparties and the related reinvestment of that cash collateral being reported on the Company’s balance sheet. These impairments were not reflected in the income statement in the current period.

61

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The unrealized losses of loan-backed and structured securities where fair value is less than cost or amortized cost for which an OTTI has not been recognized in earnings as of December 31, 2010 and 2009 is as follows:

	Losses 12 Months or More		Losses Less Than 12 Months
Year ended December 31, 2010
The aggregate amount of unrealized losses	$	1,458,666	$	46,087
The aggregate related fair value of securities with unrealized losses		5,640,930		1,393,078

	Losses 12 Months or More		Losses Less Than 12 Months
Year ended December 31, 2009
The aggregate amount of unrealized losses	$	2,777,510	$	116,079
The aggregate related fair value of securities with unrealized losses		7,198,974		1,553,619

Detail of net investment income (loss) is presented below:

	Year Ended December 31
	2010			2009			2008
Income (loss):
Bonds	$	2,476,783		$	2,581,437		$	2,993,763
Preferred stocks		10,296			10,395			118,882
Common stocks		36,266			8,444			46,168
Mortgage loans on real estate		534,467			609,836			690,904
Real estate		20,816			20,748			21,328
Policy loans		50,210			50,065			46,017
Cash, cash equivalents and short-term investments		11,008			38,804			85,494
Derivatives		(147,236	)		(134,716	)		(9,236	)
Other invested assets		50,078			17,276			28,504
Other		14,525			9,242			32,637
Gross investment income		3,057,213			3,211,531			4,054,461
Less investment expenses		138,042			138,374			167,535
Net investment income	$	2,919,171		$	3,073,157		$	3,886,926

62

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

Proceeds from sales and other disposals of bonds and preferred stock and related gross realized capital gains and losses were as follows:

	Year Ended December 31
	2010			2009			2008
Proceeds	$	24,752,873		$	17,076,601		$	20,354,654
Gross realized gains		1,626,104			365,886			362,690
Gross realized losses		(142,953	)		(394,368	)		(440,705	)
Net realized capital gains (losses)	$	1,483,151		$	(28,482	)	$	(78,015	)

The Company had gross realized losses for the years ended December 31, 2010, 2009 and 2008 of $192,541, $618,554 and $367,432, respectively, which relate to losses recognized on other-than-temporary declines in the fair values of bonds and preferred stocks.

Net realized capital gains (losses) on investments are summarized below:

	Realized
	Year Ended December 31
	2010			2009			2008
Bonds	$	1,290,685		$	(612,760	)	$	(324,506	)
Preferred stocks		(75	)		6,697			(120,940	)
Common stocks		2,949			(4,947	)		(65,021	)
Mortgage loans on real estate		(18,451	)		(55,349	)		(7,074	)
Real estate		(235	)		(1,051	)		17,781
Cash, cash equivalents and short-term investments		12			80			(13,767	)
Derivatives		(160,155	)		(437,350	)		54,650
Other invested assets		124,712			(8,392	)		654,443
		1,239,442			(1,113,072	)		195,566
Federal income tax effect		(450,184	)		235,951			119,219
Transfer to interest maintenance reserve		(846,096	)		176,600			51,433
Net realized capital gains (losses) on investments	$	(56,838	)	$	(700,521	)	$	366,218

63

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

At December 31, 2010 and 2009, the Company had recorded investments in restructured securities of $46,209 and $90,186, respectively. The capital gains (losses) taken as a direct result of restructures in 2010, 2009 and 2008 were $16,745, $(84,752) and $1,905, respectively. The Company often has impaired a security prior to the restructure date. These impairments are not included in the calculation of restructure related losses and are accounted for as a realized loss, reducing the cost basis of the security involved.

The changes in net unrealized capital gains and losses on investments were as follows:

	Change in Unrealized
	Year Ended December 31
	2010			2009			2008
Bonds	$	(53,819	)	$	16,818		$	(226,573	)
Preferred stocks		(35	)		(46,613	)		(22,844	)
Common stocks		22,057			36,097			(28,697	)
Affiliated entities		70,914			37,287			(7,222	)
Mortgage loans on real estate		1,826			(8,024	)		—
Cash, cash equivalents and short-term investments		—			284			—
Derivatives		113,051			(410,982	)		382,983
Other invested assets		25,289			(211,719	)		(900,944	)
Change in unrealized capital gains (losses)	$	179,283		$	(586,852	)	$	(803,297	)

The Company did not issue any new mortgage loans during 2010. During 2010, the Company reduced interest rates on mortgages by 3% for one loan in the amount of $1,986, by 2% for one loan in the amount of $1,269 and by 1% for two loans in the amount of $61,000. Mortgage loans with a carrying amount of $6 were non-income producing for the previous 180 days. Accrued interest of $1, $3 and $346 related to these mortgage loans was excluded from investment income at December 31, 2010, 2009 and 2008, respectively. The Company has a mortgage or deed of trust on the property thereby creating a lien which gives it the right to take possession of the property (among other things) if the borrower fails to perform according to the terms of the loan documents. The Company requires all mortgaged properties to carry fire insurance equal to the value of the underlying property. At December 31, 2010 there were no taxes, assessments and other amounts advanced not included in the mortgage loan total.

64

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

During 2009, the Company issued mortgage loans with interest rates of 6.65% for commercial loans and 7.00% for agricultural loans. During 2009, the Company did not reduce interest rates on any outstanding mortgages. The maximum percentage of any one mortgage loan to the value of the underlying real estate originated during the year ended December 31, 2009 at the time of origination was 60%. At December 31, 2009, mortgage loans with a carrying value of $11 were non-income producing for the previous 180 days. Taxes, assessments and other amounts advanced not included in the mortgage loan total were $16 for the year ended December 31, 2009.

At December 31, 2010 and 2009, respectively, the Company held $89,765 and $121,760 in impaired loans with related allowance for credit losses of $6,198 and $8,024. There were no impaired mortgage loans held without an allowance for credit losses as of December 31, 2010 and 2009, respectively. The average recorded investment in impaired loans during 2010 and 2009 was $137,077 and $32,445, respectively.

The following table provides a reconciliation of the beginning and ending balances for the allowance for credit losses on mortgage loans:

	Year Ended December 31
	2010			2009			2008
Balance at beginning of period	$	8,024		$	11,924		$	—
Additions, net charged to operations		16,645			20,940			11,924
Recoveries in amounts previously charged off		(18,471	)		(24,840	)		—
Balance at end of period	$	6,198		$	8,024		$	11,924

The Company accrues interest income on impaired loans to the extent deemed collectible (delinquent less than 91 days) and the loan continues to perform under its original or restructured contractual terms. Interest income on nonperforming loans generally is recognized on a cash basis. For the years ended December 31, 2010, 2009 and 2008, respectively, the Company recognized $8,500, $1,993 and $1,374 of interest income on impaired loans. Interest income of $8,568, $509 and $1,570, respectively, was recognized on a cash basis for the years ended December 31, 2010, 2009 and 2008.

At December 31, 2010 and 2009, the Company held a mortgage loan loss reserve in the AVR of $77,736 and $123,257, respectively.

65

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The Company’s mortgage loan portfolio is diversified by geographic region and specific collateral property type as follows:

Geographic Distribution							Property Type Distribution
	December 31							December 31
	2010			2009				2010			2009
South Atlantic		24	%		23	%	Office		31	%		31	%
Pacific		22			22		Apartment		21			21
Middle Atlantic		17			15		Retail		21			20
Mountain		13			15		Industrial		17			19
E. North Central		10			10		Other		5			5
W. North Central		6			5		Agricultural		3			3
W. South Central		4			5		Medical		2			1
E. South Central		2			3
New England		2			2

At December 31, 2010 and 2009, the Company had mortgage loans with a total net admitted asset value of $13,125 and $13,454, respectively, which had been restructured in accordance with SSAP No. 36, Troubled Debt Restructuring. The Company did not have any mortgage loans which had been restructured in accordance with SSAP No. 36 at December 31, 2008. There were no realized losses during the years ended December 31, 2010, 2009 and 2008 related to such restructurings. There were no commitments to lend additional funds to debtors owing receivables at December 31, 2010, 2009 or 2008.

During 2010, the Company recorded an impairment of $3,276 for its investment in Stonington Capital Appreciation 1994 Fund, L.P., and an impairment of $272 for its investment in Yield Strategies Fund I, L.P. The impairments were taken because the decline in fair value of the funds was deemed to be other than temporary and a recovery in value from the remaining underlying investments in the funds was not anticipated. These write-downs are included in net realized capital gains (losses) within the statements of operations.

A write down of carrying value is required when an investor’s intent to retain the investment in the issuer has changed at the reporting date and there is not a sufficient period of time to allow for any anticipated recovery in value to occur. At December 31, 2009 and 2008, respectively, the Company recorded an impairment of $15,287 and $42,829 for its investment in Zero Beta Fund, LLC. The impairment was taken because there is an intent to sell some of the underlying investments of the fund before any anticipated recovery in value would occur.

66

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

During 2009, the Company recorded impairments of $40,688 and $10,030 for its investment in Real Estate Alternatives Portfolio 2, LLC and Real Estate Alternatives Portfolio 3, LLC, respectively. The impairment was taken because the declines in fair value of underlying investments of the fund were deemed to be other-than-temporary.

During 2009, the Company recorded an impairment of $2,120 for its investment in Yucaipa Equity Partners, L.P., an impairment of $2,884 for its investment in BCI Growth IV, L.P., an impairment of $296 for its investment in Allsop Venture Partners III, L.P., an impairment of $1,548 for its investment in B III Capital Partners, L.P., an impairment of $551 for its investment in Cahill, Warnock Strategic Partners Fund, L.P., an impairment of $49 for its investment in CM Equity Partners, L.P., an impairment of $133 for its investment in Conning Insurance Capital Limited Partnership III, an impairment of $706 for its investment in FS Equity Partners III, L.P. and an impairment of $5,133 for its investment in Harbour Group Investments III, L.P. It was determined that the decline was other than temporary because the expected future proceeds is the current reflected fair value on each of the deals.

At December 31, 2010, the Company had ownership interests in sixty-two LIHTC Investments. The remaining years of unexpired tax credits ranged from one to eleven. One property was the subject of a review by the South Dakota Housing Development Authority in which the Company is responding with corrective actions. The length of time remaining for holding periods ranged from one to sixteen years. The amount of contingent equity commitments expected to be paid during the years 2011 to 2019 is $29,934. There were no impairment losses, write-downs or reclassifications during the year related to any of these credits.

At December 31, 2009, the Company had ownership interests in sixty-one LIHTC Investments. The remaining years of unexpired tax credits ranged from one to twelve and none of the properties were subject to regulatory review. The length of time remaining for holding periods ranged from one to sixteen years. The amount of contingent equity commitments expected to be paid during the years 2010 to 2019 is $45,413. There were no impairment losses, write-downs or reclassifications during the year related to any of these credits.

67

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The following table provides the carrying value of state transferable tax credits gross of any related tax liabilities and total unused transferable tax credits by state and in total as of December 31, 2010 and 2009:

			December 31, 2010
Description of State Transferable Tax Credits	State		Carrying Value		Unused Amount*
Low-Income Housing Tax Credits		MA	$	5,135	$	8,370
Low-Income Housing Tax Credits		MO		1,461		1,642
Total			$	6,596	$	10,012
			December 31, 2009
Description of State Transferable Tax Credits	State		Carrying Value		Unused Amount
Low-Income Housing Tax Credits		MA	$	4,479	$	8,370
Total			$	4,479	$	8,370

* The unused amount reflects credits that the Company deems will be realizable in the period from 2011 to 2014.

The Company estimated the utilization of the remaining state transferable tax credits by projecting a future tax liability based on projected premium, tax rates and tax credits and comparing the projected future tax liability to the availability of remaining state transferable tax credits. The Company had no impairment losses related to state transferable tax credits.

On December 31, 2010, the Company sold two real estate related limited liability company interests (Transamerica Pyramid Properties, LLC and Transamerica Realty Properties, LLC) to Monumental Life Insurance Company (MLIC), an affiliate, for a combined sale price of $252,975. The sale price was based predominantly on the valuations of the properties within each of the entities. This transaction resulted in a realized gain of $24,296.

68

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The Company uses interest rate swaps to reduce market risk in interest rates and to alter interest rate exposures arising from mismatches between assets and liabilities. An interest rate swap is an arrangement whereby two parties (counterparties) enter into an agreement to exchange periodic interest payments. The dollar amount the counterparties pay each other is an agreed-upon period interest rate multiplied by an underlying notional amount. Generally, no cash is exchanged at the outset of the contract and no principal payments are made by either party. The Company also uses cross currency swaps to reduce market risk in foreign currencies and to alter exchange exposure arising from mismatches between assets and liabilities. A cash payment is often exchanged at the outset of the swap contract, representing the present value of cash flows of the instrument. A notional currency exchange occurs at the beginning and end of the contract. During the life of the swap, the counterparties exchange fixed or floating interest payments in its swapped currency. All swap transactions are entered into pursuant to master agreements providing for a single net payment to be made by one counterparty at each due date.

The Company invests in capped floating rate commercial mortgage loans and uses interest rate caps to convert the commercial mortgage loan into a pure floating rate asset in order to meet its overall asset/liability strategy. Interest rate caps provide for the receipt of payments when interest rates rise above the strike rates in the contract. A single premium is paid by the Company at the beginning of the interest rate cap contracts.

The Company replicates investment grade corporate bonds by combining a AAA rated security as a cash component with a credit default swap which, in effect, converts the high quality asset into a lower rated investment grade asset. Using the swap market to replicate credit quality enables the Company to enhance the relative values while having the ability to execute larger transactions in a shortened time frame. A premium is received by the Company on a periodic basis and recognized in investment income. The Company replicates hybrid fixed to floating treasuries by combining a US Treasury cash component with a forward starting swap which, in effect converts a fixed US Treasury into hybrid fixed to floating treasury. The purpose of these replications is to aid duration matching between the treasuries and the supported liabilities. Generally these swaps are carried at amortized cost with periodic interest payments beginning at a future date. At December 31, 2010 and 2009, the Company had replicated assets with a fair value of $1,422,102 and $475,424 and credit default swaps with a fair value of $29,383 and $1,377, respectively. For the year ended December 31, 2010, the Company did not recognize any capital losses related to replication transactions. For the years ended December 31, 2009 and 2008, respectively, the Company recognized $3,088 and $306 in capital losses related to replication transactions.

69

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The Company replicates investment grade corporate bonds by writing credit default swaps. As a writer of credit swaps, the Company actively monitors the underlying asset, being careful to note any events (default or similar credit event) that would require the Company to perform on the credit swap. If such events would take place the Company has recourse provisions from the proceeds of the bankruptcy settlement of the underlying entity or by the sale of the underlying bond. As of December 31, 2010, credit default swaps, used in replicating corporate bonds are as follows:

Deal, Receive (Pay), Underlying	Maturity Date	Maximum Future Payout (Estimate)		Current Fair Value
3823, SWAP USD0.43/USD0, 023551L@1	12/20/2012	$	2,000	$	2
3936, SWAP USD0.49/USD0, 031162F@4	6/20/2013		15,000		86
3817, SWAP USD0.6/USD0, 872384A@1	12/20/2012		1,000		4
3815, SWAP USD0.6/USD0, 872384A@1	12/20/2012		3,000		12
3820, SWAP USD0.6/USD0, 872384A@1	12/20/2012		1,000		4
3937, SWAP USD0.85/USD0, 370334F@8	6/20/2013		15,000		219
3938, SWAP USD1.52/USD0, 88732JA@7	6/20/2013		12,000		303
3066, SWAP USD0.41/USD0, 459200F#3	4/15/2041		40,000		285
3818, SWAP USD0.6/USD0, 872384A*3	1/15/2021		1,000		4
3247, SWAP USD0.37/USD0, 12189TA*5	10/15/2014		13,000		33
3249, SWAP USD0.39/USD0, 539830C#4	10/15/2014		17,000		57
3251, SWAP USD0.38/USD0, 666807B#8	10/15/2014		13,000		28
3725, SWAP USD1.261/USD0, 969457E#3	6/15/2019		5,000		(13	)
3725, SWAP USD1.261/USD0, 969457E#3	6/15/2019		20,000		(51	)
4199, SWAP USD1/USD0, BAE3BZ$01	2/15/2040		20,000		140
4201, SWAP USD1/USD0, 36962G$01	11/15/2018		10,000		(152	)
4200, SWAP USD1/USD0, 59156R$01	8/15/2040		10,000		(279	)
4203, SWAP USD1/USD0, 38141G$01	5/15/2038		10,000		(93	)
4208, SWAP USD1/USD0, 36962G$02	8/15/2040		10,000		(152	)
4208, SWAP USD1/USD0, 36962G$02	8/15/2040		10,000		(152	)
4233, SWAP USD1/USD0, BAE3BZ$03	5/15/2040		20,000		140
4234, SWAP USD1/USD0, 025816$01	5/15/2040		20,000		215
4235, SWAP USD1/USD0, 36962G$03	5/15/2040		20,000		(304	)
4236, SWAP USD1/USD0, 14040E$01	5/15/2040		20,000		186
4237, SWAP USD1/USD0, BAE3BZ$04	5/15/2040		7,500		52
4237, SWAP USD1/USD0, BAE3BZ$04	5/15/2040		12,500		87
4238, SWAP USD1/USD0, 00817Y$01	5/15/2040		7,500		155

70

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

Deal, Receive (Pay), Underlying	Maturity Date	Maximum Future Payout (Estimate)		Current Fair Value
4238, SWAP USD1/USD0, 00817Y$01	5/15/2040	$	12,500	$	259
4239, SWAP USD1/USD0, 91324P$01	2/15/2040		20,000		49
4240, SWAP USD1/USD0, BAE3BZ$05	2/15/2040		20,000		140
4241, SWAP USD1/USD0, 14040E$02	2/15/2040		12,500		116
4241, SWAP USD1/USD0, 14040E$02	2/15/2040		7,500		70
4244, SWAP USD1/USD0, BAE3BZ$06	8/15/2040		20,000		140
4248, SWAP USD1/USD0, BAE3BZ$07	5/15/2030		20,000		140
4250, SWAP USD1/USD0, 02209S$01	11/15/2028		20,000		77
4251, SWAP USD1/USD0, 02209S$02	11/15/2039		9,722		37
4251, SWAP USD1/USD0, 02209S$02	11/15/2039		10,278		40
4252, SWAP USD1/USD0, 29273R$01	11/15/2039		10,000		(150	)
4253, SWAP USD1/USD0, 460146$01	11/15/2027		20,000		(163	)
4254, SWAP USD1/USD0, 59156R$02	2/15/2040		20,000		(558	)
4255, SWAP USD1/USD0, 025816$02	11/15/2039		20,000		215
4256, SWAP USD1/USD0, 02209S$03	5/15/2040		20,000		77
4257, SWAP USD1/USD0, 878742$01	2/15/2040		20,000		(96	)
4258, SWAP USD1/USD0, 828807$01	11/15/2039		6,667		16
4258, SWAP USD1/USD0, 828807$01	11/15/2039		13,333		32
4267, SWAP USD1/USD0, 29273R$02	11/15/2039		6,667		(100	)
4267, SWAP USD1/USD0, 29273R$02	11/15/2039		13,333		(200	)
4268, SWAP USD1/USD0, 14040E$03	8/15/2025		20,000		186
4261, SWAP USD1/USD0, 35671D$01	5/15/2030		20,000		(85	)
4262, SWAP USD1/USD0, 59156R$03	11/15/2026		20,000		(558	)
4263, SWAP USD1/USD0, 149123$01	8/15/2025		20,000		287
4264, SWAP USD1/USD0, 585055$01	11/15/2026		20,000		418
4265, SWAP USD1/USD0, 00817Y$02	8/15/2040		20,000		414
4266, SWAP USD1/USD0, 91324P$02	2/15/2040		3,529		13
4266, SWAP USD1/USD0, 91324P$02	2/15/2040		16,471		62
4269, SWAP USD1/USD0, 549271$01	5/15/2030		20,000		(162	)
4270, SWAP USD1/USD0, 097023$01	8/15/2040		20,000		337
4271, SWAP USD1/USD0, 585055$02	2/15/2040		8,889		186
4271, SWAP USD1/USD0, 585055$02	2/15/2040		11,111		232
4272, SWAP USD1/USD0, 670346$01	2/15/2040		20,000		207
4273, SWAP USD1/USD0, 61166W$01	11/15/2039		20,000		443
4278, SWAP USD1/USD0, 38141G$03	5/15/2040		8,095		(89	)
4278, SWAP USD1/USD0, 38141G$03	5/15/2040		11,905		(131	)
		$	898,000	$	2,722

71

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The Company issues products providing the customer a return based on various global equity market indices. The Company uses global futures contracts and/or options to hedge the liability option risk associated with these products. Options are marked to fair value in the balance sheet and the fair value adjustment is recorded to unassigned surplus in the financial statements. The Company did not recognize any income from options contracts for the year ended December 31, 2010. The Company recognized income from options contracts in the amount of $1,534 for the year ended December 31, 2009. The Company did not recognize any income from options contracts for the year ended December 31, 2008.

The Company may sell products with expected benefit payments extending beyond investment assets currently available in the market. Because assets will have to be purchased in the future to fund future liability cash flows, the Company is exposed to the risk of future investments made at lower yields than what is assumed at the time of pricing. Forward-starting interest rate swaps are utilized to lock-in the current forward rate. When rates are below the Company’s target rate, the Company will sell put options on the forward starting swaps of which they would like to enter into. The option will be considered an income generation transaction. Since the underlying is a derivative, the option will be marked to market with the offset through surplus and the premium received for the written option will be deferred during the option period. If the option is exercised, the premium will adjust the forward starting swap’s acquisition cost. The forward starting swap will be then accounted for as follows. The accrual of income begins at the forward date, rather than at the inception date. These forward-starting swaps meet hedge accounting rules and are carried at cost in the financial statements. Gains and losses realized upon termination of the forward-starting swap are deferred and used to adjust the basis of the asset purchased in the hedged forecasted period. The basis adjustment is then amortized into income as a yield adjustment to the asset over its life. At December 31, 2010, the Company had written options with a fair value of $(462) and average fair value for the year of $(425). The Company had no realized gains or losses for the year ended December 31, 2010 related to these options.

The Company holds some credit default swaps linked to a collateralized debt obligation structure. The Company was put into these swaps as a result of market events on a liquidity facility it had entered and does not intend to enter similar transactions in this current form. Under this transaction the Company receives a fee in exchange for providing credit protection if the underlying CDO structure incurs losses greater than its supporting collateral. The fee will be recorded in investment income. These swaps are marked to fair value in the balance sheet and the fair value adjustment is recorded in capital and surplus. At December 31, 2010, the Company had credit default swaps linked to collateralized debt obligations with a fair value of $(4,600) and average fair value for the year of $(4,600).

72

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

The Company is exposed to credit related losses in the event of nonperformance by counterparties to financial instruments, but it does not expect any counterparty to fail to meet their obligations given their high credit ratings of ‘A’ or better. At December 31, 2010 and 2009, the fair value of all contracts, aggregated at a counterparty level, with a positive fair value amounted to $822,271 and $656,501, respectively.

The Company has entered into collateral agreements with certain counterparties wherein the counterparty is required to post assets on the Company’s behalf. The posted amount is equal to the difference between the net positive fair value of the contracts and an agreed upon threshold based on the credit rating of the counterparty. If the net fair value of all contracts with this counterparty is negative, the Company is required to post assets. At December 31, 2010 and 2009, the fair value of all contracts, aggregated at a counterparty level, with a negative fair value amounted to $555,186 and $757,479, respectively.

The maximum term over which the Company is hedging its exposure to the variability of future cash flows for forecasted transactions is 22 years. The Company hedges the variability in future cash flows from expected future investment purchases due to changes in interest rates through the use of forward starting interest rate swaps. If the forecasted asset purchase does not occur or is no longer highly probable of occurring, valuation at cost ceases and the forward-starting swap would be valued at its current fair value with fair value adjustments recorded in unassigned surplus. At December 31, 2010 and 2009, none of the Company’s cash flow hedges have been discontinued as it was probable that the original forecasted transactions would occur by the end of the originally specified time period documented at inception of the hedging relationship. As of December 31, 2010, the Company has accumulated deferred gains in the amount of $89,357 related to the termination of forecasted transactions. It is expected that these gains will be used as basis adjustments on future asset purchases expected to transpire throughout 2026.

Derivative instruments are subject to market risk, which is the possibility that future changes in market prices may make the instruments less valuable. The Company uses derivatives as hedges; consequently, when the value of the derivative changes, the value of a corresponding hedged asset or liability will move in the opposite direction. Market risk is a consideration when changes in the value of the derivative and the hedged item do not completely offset (correlation or basis risk) which is mitigated by active measuring and monitoring.

73

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

At December 31, 2010 and 2009, the Company’s outstanding financial instruments with on and off balance sheet risks, shown in notional amounts, are summarized as follows:

	Notional Amount
	2010		2009
Interest rate and currency swaps:
Receive floating - pay floating	$	2,038,837	$	2,129,869
Receive fixed - pay floating		12,288,402		10,548,640
Receive floating - pay fixed		4,848,678		5,856,796
Receive fixed - pay fixed		129,098		236,005
Interest rate cap agreements		10,250		1,605,000
Interest rate floor agreements		—		64,000

The Company utilizes futures contracts to hedge against changes in market conditions. Initial margin deposits are made by cash deposits or segregation of specific securities as may be required by the exchange on which the transaction was conducted. Pursuant to the contracts, the Company agrees to receive from or pay to the broker, an amount of cash equal to the daily fluctuation in the value of the contract. Such receipts or payments are known as “variation margin” and are recorded by the Company as a variation margin receivable or payable on futures contracts. During the period the futures contracts are open, daily changes in the values of the contracts are recognized as realized gains (losses) since they are effectively settled daily through the variation account. The Company recognizes a realized gain or loss equal to the difference between the proceeds from, or cost of, the closing transaction and the Company’s cost basis in the contract. The Company recognized net realized gains (losses) from futures contracts in the amount of $(120,396), $(180,328) and $119,833 for the years ended December 31, 2010, 2009 and 2008, respectively.

74

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

5. Investments (continued)

Open futures contracts at December 31, 2010 and 2009, were as follows:

Long/Short	Number of Contracts			Contract Type	Opening Market Value			Year-End Market Value
December 31, 2010
				S&P 500
Short		(1,190	)	March 2011 Futures	$	(366,683	)	$	(372,767	)
				US Ultra Bond
Long		4,950		March 2011 Futures		646,816			629,095

Number of Contracts	Contract Type		Opening Market Value		Year-End Market Value
December 31, 2009
		S&P 500
1,074		March 2010 Futures	$	297,468	$	298,223

For the years ended December 31, 2010 and 2009, the Company has recorded $(22,972) and $(73,133), respectively, for the component of derivative instruments utilized for hedging purposes that did not qualify for hedge accounting. This has been recorded directly to unassigned surplus as an unrealized loss. The Company did not recognize any unrealized gains and losses during 2010 and 2009 that represented the component of derivative instruments gain or loss that was excluded from the assessment of hedge effectiveness.

At December 31, 2010 and 2009, investments with an aggregate carrying value of $44,885,204 and $44,519,346, respectively, were on deposit with regulatory authorities or were restrictively held in bank custodial accounts for the benefit of such regulatory authorities, as required by statute.

75

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance

Certain premiums and benefits are assumed from and ceded to other insurance companies under various reinsurance agreements. The Company reinsures portions of the risk on certain insurance policies which exceed its established limits, thereby providing a greater diversification of risk and minimizing exposure on larger risks. The Company remains contingently liable with respect to any insurance ceded, and this would become an actual liability in the event that the assuming insurance company became unable to meet its obligation under the reinsurance treaty.

Premiums earned reflect the following reinsurance amounts:

	Year Ended December 31
	2010			2009			2008
Direct premiums	$	10,763,441		$	12,709,931		$	13,309,443
Reinsurance assumed - non affiliates		1,652,588			1,612,150			1,515,095
Reinsurance assumed - affiliates		427,231			196,638			296,438
Reinsurance ceded - non affiliates		(1,042,739	)		(1,130,902	)		(1,101,435	)
Reinsurance ceded - affiliates		(2,635,402	)		(5,287,685	)		(6,501,597	)
Net premiums earned	$	9,165,119		$	8,100,132		$	7,517,944

The Company received reinsurance recoveries in the amount of $2,580,994, $2,360,201 and $2,166,604 during 2010, 2009 and 2008, respectively. At December 31, 2010 and 2009, estimated amounts recoverable from reinsurers that have been deducted from policy and contract claim reserves totaled $429,355 and $464,122, respectively. The aggregate reserves for policies and contracts were reduced for reserve credits for reinsurance ceded at December 31, 2010 and 2009 of $38,345,117 and $37,294,459, respectively.

The net amount of the reduction in surplus at December 31, 2010 and 2009, if all reinsurance agreements were cancelled, is $18,827 and $28,937, respectively.

At December 31, 2010, the Company did not enter into any new reinsurance agreements in which a reserve credit was taken. At December 31, 2009, the amount of reinsurance credits, whether an asset or a reduction of liability, taken for new agreements or amendments was $3,383,308.

76

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

Effective December 31, 2010, the Company entered into a reinsurance agreement with Western Reserve Life Assurance Co. of Ohio (WRL), an affiliate, to assume on a 100% quota share basis a block of variable universal life business on a modified coinsurance basis. Reserves on the block were $1,013,110, with assets backing the block comprised of $853,669 of separate account assets and $159,441 of general account assets. The Company paid consideration of $193,000, resulting in a pre-tax loss of $193,000 which was included in the statement of operations.

Effective June 1, 2010, the Company entered into an assumption reinsurance agreement in which the Company ceded group annuity policies to Transamerica Financial Life Insurance Company (TFLIC), an affiliate. Reserves of $68,683 were ceded and assets in the amount of $92,931 were transferred. This transaction resulted in a net pre-tax loss to the Company of $24,248, which has been reflected in the statement of operations, as this transaction was deemed economic.

Effective April 1, 2010, the Company entered into an assumption reinsurance agreement in which the Company assumed term life policies from TFLIC. Life and claim reserves of $38,023 and $7,558, respectively, and other assets of $5,538 were assumed by the Company. The Company received consideration of $5,106. This transaction resulted in a net pre-tax loss to the Company of $34,936, which has been reclassified to the balance sheet and presented as goodwill, as this transaction was deemed economic. The goodwill will be amortized into operations over the period in which the Company benefits economically, not to exceed 10 years. Amortization of goodwill for the year was $899.

Effective December 31, 2008, the Company ceded certain term life business to Transamerica Pacific Life Insurance Company (TPIC, formally known as CGC Life Insurance Company (CGC)), an affiliate, on a funds withheld basis. Life and claim reserves of $505,004 and $6,874, respectively were released and the Company established other reserves of $28,680. The net pre-tax gain of $483,198 ($314,079 net of tax) resulting from this transaction was credited directly to unassigned surplus. During the first quarter of 2010 and during 2009, the Company amortized $10,721 and $17,577, respectively, on a pre-tax basis ($6,969 and $11,425, respectively, after-tax) of this gain back into earnings. Effective April 1, 2010, the Company recaptured these term life insurance policies from TPIC. Life and claim reserves of $484,646 and $3,108, respectively, were assumed along with other net assets of $24,933, resulting in a pre-tax loss of $462,821 which was recognized in the statement of operations. With the recapture of this business, the previously deferred gain associated with the original July 1, 2009 cession to TPIC was released into the statement of operations in the amount of $454,900 ($295,685 after-tax).

77

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

Subsequent to the recapture and also effective April 1, 2010, the Company entered into an indemnity reinsurance agreement to cede the same block of term life insurance policies to MLIC, an affiliate, on a coinsurance basis. The Company released life and claim reserves of $484,646 and $3,108, respectively, and other net assets of $24,933, resulting in a net pre-tax gain of $462,821 ($300,833 net of tax), which was deferred directly into unassigned surplus. During 2010, the Company has amortized $11,200 of this gain into earnings on a net of tax basis with a corresponding charge to unassigned surplus.

Effective January 1, 2010, the Company entered into an assumption reinsurance agreement in which the Company assumed term life policies from TFLIC. Life and claim reserves of $18,822 and $446, respectively, were assumed, and the Company received consideration of $791. This transaction resulted in a net pre-tax loss to the Company of $18,477, which has been reclassified to the balance sheet and presented as goodwill, as this transaction was deemed economic. The goodwill will be amortized into operations over the period in which the Company benefits economically, not to exceed 10 years. Amortization of the goodwill for the year was $1,752.

Effective January 1, 2010, the Company entered into an assumption reinsurance agreement in which the Company ceded accident and health policies to TFLIC. Claim reserves of $2,357 and other liabilities of $9,761 were ceded by the Company, with $12,118 consideration paid, having no impact on the Company’s net income.

Effective July 1, 2009, and concurrent with the merger of CGC into TPIC, the Company recaptured universal life business secondary guarantee reserves previously ceded to CGC, an affiliate. As a result, a pre-tax loss of $129,005 was included in the statement of operations. The remaining unamortized gain on a pre-tax basis that resulted from the initial ceding transaction to CGC that had been credited directly to unassigned surplus was released into earnings in the amount of $82,288.

Subsequently, effective July 1, 2009, the Company ceded the same block of universal life business plus additional universal life policies (2009 new issues) to TPIC under a coinsurance agreement. The pre-tax gain of $184,918 resulting from this transaction was credited directly to unassigned surplus.

Also effective July 1, 2009, the Company ceded certain term life business to TPIC on a coinsurance basis. The net pre-tax gain of approximately $36,489 resulting from this transaction was credited directly to unassigned surplus.

78

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

Also effective July 1, 2009, the Company amended a reinsurance agreement with TPIC to change a term agreement from a coinsurance funds withheld treaty to a straight coinsurance treaty. Assets of $58,394 were transferred to TPIC, and the Company released the funds withheld liability of a like amount. There was no earnings impact of this treaty amendment.

The Company entered into an indemnity reinsurance agreement with MLIC, an affiliate, effective July 1, 2009 in which the Company agreed to cede on a coinsurance basis fixed deferred annuities issued under selected plans. The initial consideration paid was $3,474,331, the initial ceding allowance received was $13,677 and reserves ceded were $3,474,331. In addition, an interest maintenance reserve of $15,469 was transferred to MLIC, resulting in a pre-tax gain of $29,146 on the transaction, which was credited directly to unassigned surplus. During 2010 and 2009, the Company amortized $3,765 and $1,895, respectively, into earnings on a net of tax basis with a corresponding charge to unassigned surplus.

Effective June 30, 2009, the Company entered into an indemnity reinsurance agreement with Global Preferred Re Limited, an affiliate, to cede on a 90% quota share basis the net liabilities associated with certain of the Company’s deferred fixed annuity products issued on or after April 1, 2009 on a coinsurance funds withheld basis.

Effective January 1, 2009, the Company terminated and recaptured a block of US credit life and credit disability business that had been reinsured from LIICA, which merged into the Company effective October 2, 2008, to an affiliate, Canadian Premier Life insurance Company (CPLIC). The Company paid CPLIC a recapture fee of $2,564. In addition, the unamortized pre-tax gain held by the Company in unassigned surplus resulting from the original insurance transaction was released into income in the amount of $2,910 ($1,892 on a net of tax basis).

Effective December 31, 2008, the Company recaptured term life business previously ceded to Transamerica International Re (Ireland) Ltd. (TIRI), and Transamerica International Re (Bermuda) Ltd (TIRe) both affiliates. The Company received recapture consideration of $120,476, recorded net assets of $33,804, and recaptured reserves of $856,239 and $53,085 for life and claim reserves, with respect to the recapture from TIRI. The Company received recapture consideration of $25,563, recorded net assets of $5,088, and recaptured reserves of $167,004 and $4,821 for life and claim reserves, with respect to the recapture from TIRe. The Company incurred a statutory loss on the recapture from TIRI in the amount of $755,044 and a statutory loss on the recapture from TIRe in the amount of $141,174. As a result, a pre-tax loss of $896,218 was included in the statement of operations.

79

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

Subsequently, effective December 31, 2008, the Company ceded term life business to CGC. The Company paid initial consideration of $146,039, released life and claim reserves of $1,023,243 and $57,906 respectively, and established other net liabilities of $38,892. The net pre-tax gain of $896,218 resulting from this transaction was credited directly to unassigned surplus. During 2010, the Company amortized $34,739 ($22,580 after-tax) into earnings with a corresponding charge to unassigned surplus.

The Company has entered into an indemnity reinsurance agreement effective December 31, 2008, with TIRe to cede on a 100% quota share basis the net liabilities associated with certain of the Company’s variable annuity products on a coinsurance and modified coinsurance basis. The Company ceded reserves on a coinsurance basis of $872,822 and ceded premium of a like amount, paid consideration of $223,608 and established a funds withheld liability of $1,096,431. The pre-tax loss of $223,608 ($145,345 on a net of tax basis) is included in the statement of operations. The Company ceded general account and separate account reserves on a modified coinsurance basis of $284,780 and $7,248,603, respectively. An initial reinsurance premium equal to the reserves ceded was recorded, resulting in no gain or loss on the modified coinsurance portion on this transaction.

Effective October 1, 2008 the Company recaptured various guaranteed minimum death benefit (GMDB) riders included in certain of its variable annuity contracts that were previously ceded to TIRe under a 2001 reinsurance agreement. The Company released a funds withheld liability of $40,133 associated with this business and received recapture consideration of $45,038. Reserves recaptured included $100,672 of GMDB reserves and $15,099 of claim reserves. The resulting pre-tax loss of $30,600 was included in the statement of operations. In addition, the unamortized pre-tax ceded gain held by the Company in unassigned surplus resulting from the original reinsurance transaction was released into income in the amount of $16,521 ($10,739 net of tax). Prior to this transaction, the Company had amortized $3,812 on a pre-tax basis ($2,478 on a net of tax basis) into earnings for 2008, with a corresponding charge to unassigned surplus.

Effective December 31, 2008, the Company recaptured term life business previously ceded to TIRI on a funds withheld basis under a 2001 reinsurance agreement. The Company released the funds withheld liability of $38,603, recorded net assets of $5,036 and recaptured reserves of $288,498 and $7,065 for life and claim reserves, respectively. As a result, a pre-tax loss of $251,924 was included in the statement of operations. The gain that resulted from the initial ceding transaction to TIRI that had been credited directly to unassigned surplus was released into earnings in the amount of $221.

80

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

Subsequently, effective December 31, 2008, the Company ceded term life business on a funds withheld basis to CGC. Life and claim reserves of $288,498 and $7,065, respectively, were released and the Company established a funds withheld liability of $38,603 and established other net liabilities of $5,036. The net pre-tax gain of $251,924 resulting from this transaction was credited directly to unassigned surplus. During 2009, the Company amortized $11,425 into earnings on a net of tax basis with a corresponding charge to unassigned surplus.

Also effective December 31, 2008, the Company ceded certain term life business to CGC on a funds withheld basis. Life and claim reserves of $587,293 and $6,874, respectively, were released and the Company established other reserves of $28,680. The net pre-tax gain of $565,487 resulting from this transaction was credited directly to unassigned surplus.

The Company entered into an assumption reinsurance agreement with MLIC effective September 30, 2008. The Company was the issuer of a series of corporate-owned life insurance policies issued to LIICA. The assumption reinsurance transaction resulted in the Company novating all liabilities arising under these policies to MLIC. The Company ceded reserves of $138,025 and paid consideration of $125,828. The Company recorded a liability of $12,197 within the remittances line related to this transaction. The Company amortized $1,019 and $1,201 of the liability in 2010 and 2009, respectively.

The Company entered into a stop loss reinsurance agreement with Transamerica Life International (Bermuda) Ltd. (TLIB), an affiliate, to cede an in force block of universal life business effective July 1, 2008. Reinsurance premiums paid of $70,728 were offset by a comparable amount of ceded reserves. Several other accounts were impacted by lesser amounts resulting in a pre-tax loss of $15. The net of tax loss of $10 was included in the statement of operations.

81

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

The Company entered into an assumption reinsurance agreement with CPLIC, effective July 1, 2008. This transaction resulted in CPLIC assuming all in force policies and certificates from the Canadian branch of the Company, along with all of the assets and liabilities related to these policies and all capital supporting this business. Subsequent to this assumption reinsurance transaction, the Company withdrew its license in Canada and therefore considered this transaction an economic transaction. The Company received a ceding commission of $11,460, which resulted in a pre-tax gain. Below is a summary of the net policyholder liabilities and assets transferred effective July 1, 2008:

Invested assets/cash transferred	$	(52,859	)
Ceded reserves		64,882
Due premiums		(2,920	)
Due comp liability		1,007
Retro accruals		1,350
Pre-tax net income impact	$	11,460

The Company entered into an indemnity reinsurance agreement with a nonaffiliated company effective May 1, 2008 in which the Company agreed to cede certain single premium deferred annuities on a coinsurance basis. The initial consideration paid was $446,522, the initial ceding allowance received was $18,263, and reserves ceded were $446,522, resulting in a pre-tax gain of $18,263. The net of tax gain of $11,871 was credited directly to unassigned surplus. The Company amortized $1,406, $2,466 and $1,410 on a net of tax basis into earnings during 2010, 2009 and 2008, respectively, with a corresponding charge to unassigned surplus.

The Company entered into a stop loss reinsurance agreement with TLIB to cede an in force block of universal life business effective January 1, 2008. Reinsurance premiums paid of $3,267,950 were offset by a comparable amount of ceded reserves. Several other accounts were impacted by lesser amounts resulting in a pre-tax loss of $603. The net of tax loss of $392 was included in the statement of operations.

During 2010, 2009 and 2008, the Company amortized deferred gains from reinsurance transactions occurring prior to 2008 of $23,577, $20,240 and $109,704, respectively, into earnings on a net of tax basis with a corresponding charge to unassigned surplus.

82

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

6. Reinsurance (continued)

TLB acquired the direct liability to the policyholder through a court order from the Hong Kong Special Administrative Region Court, effective December 31, 2006, for most of the business issued from TOLIC’s branch in Hong Kong. TLB also acquired the direct liability to the policyholder through a court order from the High Court of the Republic of Singapore, effective December 31, 2006 for all business issued from TOLIC’s branch in Singapore. The novation of the contracts was approved by the Iowa Insurance Department and all policyholder liabilities were transferred to TLB. All balances assumed by TLB were reflected as direct adjustments to the balance sheet. As the transfer occurred between affiliated companies no gain or loss was recognized, and the difference between the assets transferred and the statutory liabilities assumed in the amount of $78,993 was recorded as goodwill and will be amortized into operations over the life of the business, not to exceed ten years. Goodwill in the amount of $8,335, $8,642 and $8,954 was amortized during 2010, 2009 and 2008, respectively, related to this transaction. TLB is valued on a U.S. statutory basis and includes a deferred gain liability of a similar amount to the goodwill reflected in the financials of the Company.

During 2001, TOLIC novated certain traditional life insurance contracts to TFLIC, an affiliate of the Company, via an assumption reinsurance transaction. Under the terms of this agreement, a significant portion of the future statutory-basis profits from the contracts assumed by TFLIC will be passed through to the Company as an experience rated refund. TOLIC recorded a deferred liability of $14,334 as a result of this transaction, which has been fully amortized at December 31, 2010. The accretion of the deferred liability was $1,433 for 2010, 2009 and 2008.

The Company reports a reinsurance deposit receivable of $146,715 and $137,437 as of December 31, 2010 and 2009, respectively. In 1996, TOLIC entered into a reinsurance agreement with an unaffiliated company where, for a net consideration of $59,716, TOLIC ceded certain portions of future obligations under single premium annuity contracts originally written by the Company in 1993. Consistent with the requirements of SSAP No. 75, Reinsurance Deposit Accounting, the Company reports the net consideration paid as a deposit. The amount reported is the present value of the future payment streams discounted at the effective yield rate determined at inception.

During 2010, 2009 and 2008, the Company obtained letters of credit of $804,032, $727,996 and $716,918, respectively, for the benefit of affiliated and nonaffiliated companies that have reinsured business to the Company where the ceding company’s state of domicile does not recognize the Company as an authorized reinsurer.

83

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes

The net deferred income tax asset at December 31, 2010 and 2009 and the change from the prior year are comprised of the following components:

	December 31, 2010
	Ordinary			Capital			Total
Gross Deferred Tax Assets	$	1,092,703		$	450,875		$	1,543,578
Statutory Valuation Allowance Adjustment		—			—			—
Adjusted Gross Deferred Tax Assets		1,092,703			450,875			1,543,578
Deferred Tax Liabilities		340,498			153,083			493,581
Subtotal (Net Deferred Tax Assets)		752,205			297,792			1,049,997
Deferred Tax Assets Nonadmitted		257,589			—			257,589
Net Admitted Deferred Tax Assets	$	494,616		$	297,792		$	792,408
				December 31, 2009
	Ordinary			Capital			Total
Gross Deferred Tax Assets	$	1,162,628		$	636,817		$	1,799,445
Statutory Valuation Allowance Adjustment		—			(81,188	)		(81,188	)
Adjusted Gross Deferred Tax Assets		1,162,628			555,629			1,718,257
Deferred Tax Liabilities		184,653			339,404			524,057
Subtotal (Net Deferred Tax Assets)		977,975			216,225			1,194,200
Deferred Tax Assets Nonadmitted		535,652			8,992			544,644
Net Admitted Deferred Tax Assets	$	442,323		$	207,233		$	649,556
	Ordinary			Change Capital			Total
Gross Deferred Tax Assets	$	(69,925	)	$	(185,942	)	$	(255,867	)
Statutory Valuation Allowance Adjustment		—			81,188			81,188
Adjusted Gross Deferred Tax Assets		(69,925	)		(104,754	)		(174,679	)
Deferred Tax Liabilities		155,845			(186,321	)		(30,476	)
Subtotal (Net Deferred Tax Assets)		(225,770	)		81,567			(144,203	)
Deferred Tax Assets Nonadmitted		(278,063	)		(8,992	)		(287,055	)
Net Admitted Deferred Tax Assets	$	52,293		$	90,559		$	142,852

84

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

The main components of deferred income tax amounts are as follows:

	Year Ended December 31
	2010		2009		Change
Ordinary
Discounting of unpaid losses	$	2,515	$	—	$	2,515
Policyholder reserves		300,047		286,552		13,495
Investments		71,214		30,231		40,983
Deferred acquisition costs		578,542		590,614		(12,072	)
Compensation and benefits accrual		28,548		31,513		(2,965	)
Receivables - nonadmitted		26,307		30,149		(3,842	)
Tax credit carry-forward		—		112,480		(112,480	)
Corporate Provision		44,634		25,163		19,471
Other (including items <5% of ordinary tax assets)		40,896		55,926		(15,030	)
Subtotal		1,092,703		1,162,628		(69,925	)
Statutory valuation allowance adjustment		—		—		—
Nonadmitted		257,589		535,651		(278,062	)
Admitted ordinary deferred tax assets		835,114		626,977		208,137
Capital:
Investments		450,875		636,816		(185,941	)
Other (including items <5% of total capital tax assets)		—		—		—
Subtotal		450,875		636,816		(185,941	)
Statutory valuation allowance adjustment		—		81,188		(81,188	)
Nonadmitted		—		8,992		(8,992	)
Admitted capital deferred tax assets		450,875		546,636		(95,761	)
Admitted deferred tax assets	$	1,285,989	$	1,173,613	$	112,376

85

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

	Year Ended December 31
	2010		2009		Change
Deferred Tax Liabilities:
Ordinary
Investments	$	118,738	$	126,913	$	(8,175	)
§807(f) adjustment		71,810		46,221		25,589
Separate account adjustments		—		—		—
Other (including items <5% of total ordinary tax liabilities)		10,171		11,519		(1,348	)
Subtotal		200,719		184,653		16,066
Capital
Investments		278,967		339,404		(60,437	)
Separate account adjustments		—		—		—
Other (including items <5% of total capital tax liabilities)		13,895		—		13,895
Subtotal		292,862		339,404		(46,542	)
Deferred tax liabilities		493,581		524,057		(30,476	)
Net deferred tax assets/liabilities	$	792,408	$	649,556	$	142,852

The Company did not report a valuation allowance for deferred income taxes as of December 31, 2010. The valuation allowance for deferred tax assets as of December 31, 2009 was $81,188. The valuation allowance is primarily related to deferred tax assets of a capital character that in the judgment of management, are not more likely than not to be realized.

86

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

As discussed in Note 1, the Company has elected to admit deferred tax assets pursuant to SSAP No. 10R, paragraph 10.e. for the 2010 and 2009 reporting periods. The amount of admitted adjusted gross deferred income tax assets under each component of SSAP No. 10R is as follows:

	December 31, 2010
	Ordinary		Capital		Total
Admission Calculation Components SSAP No. 10R, Paragraphs 10.a., 10.b.,and 10.c.:
SSAP No. 10R, Paragraph 10.a.	$	140,068	$	95,031	$	235,099
SSAP No. 10R, Paragraph 10.b. (the lesser of paragraph 10.b.i. and 10.b.ii. below)		—		2,386		2,386
SSAP No. 10R, Paragraph 10.b.i.		—		2,386		2,386
SSAP No. 10R, Paragraph 10.b.ii.		—		457,414		457,414
SSAP No. 10R, Paragraph 10.c.		200,719		292,862		493,581
Total	$	340,787	$	390,279	$	731,066
Admission Calculation Components SSAP No. 10R, Paragraph 10.e.:
SSAP No. 10R, Paragraph 10.e.i.	$	52,010	$	196,472	$	248,482
SSAP No. 10R, Paragraph 10.e.ii. (the lesser of paragraph 10.e.ii.a and 10.e.ii.b. below)		442,606		101,320		543,926
SSAP No. 10R, Paragraph 10.e.ii.a.		442,606		101,320		543,926
SSAP No. 10R, Paragraph 10.e.ii.b.		558,314		127,807		686,121
SSAP No. 10R, Paragraph 10.e.iii.		340,498		153,083		493,581
Total	$	835,114	$	450,875	$	1,285,989

87

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

	December 31, 2009
	Ordinary		Capital		Total
Admission Calculation Components SSAP No. 10R, Paragraphs 10.a., 10.b.,and 10.c.:
SSAP No. 10R, Paragraph 10.a.	$	70,812	$	6,281	$	77,093
SSAP No. 10R, Paragraph 10.b. (the lesser of paragraph 10.b.i. and 10.b.ii. below)		166,410		110,793		277,203
SSAP No. 10R, Paragraph 10.b.i.		166,410		110,793		277,203
SSAP No. 10R, Paragraph 10.b.ii.		229,106		152,536		381,642
SSAP No. 10R, Paragraph 10.c.		184,653		339,404		524,057
Total	$	421,875	$	456,478	$	878,353
Admission Calculation Components SSAP No. 10R, Paragraph 10.e.:
SSAP No. 10R, Paragraph 10.e.i.	$	70,812	$	6,281	$	77,093
SSAP No. 10R, Paragraph 10.e.ii. (the lesser of paragraph 10.e.ii.a and 10.e.ii.b. below)		371,512		200,951		572,463
SSAP No. 10R, Paragraph 10.e.ii.a.		371,512		200,951		572,463
SSAP No. 10R, Paragraph 10.e.ii.b.		371,512		200,951		572,463
SSAP No. 10R, Paragraph 10.e.iii.		184,653		339,404		524,057
Total	$	626,977	$	546,636	$	1,173,613

88

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

	Ordinary			Change Capital			Total
Admission Calculation Components SSAP No. 10R, Paragraphs 10.a., 10.b.,and 10.c.:
SSAP No. 10R, Paragraph 10.a.	$	69,256		$	88,750		$	158,006
SSAP No. 10R, Paragraph 10.b. (the lesser of paragraph 10.b.i. and 10.b.ii. below)		(166,410	)		(108,407	)		(274,817	)
SSAP No. 10R, Paragraph 10.b.i.		(166,410	)		(108,407	)		(274,817	)
SSAP No. 10R, Paragraph 10.b.ii.		(229,106	)		304,878			75,772
SSAP No. 10R, Paragraph 10.c.		16,066			(46,542	)		(30,476	)
Total	$	(81,088	)	$	(66,199	)	$	(147,287	)
Admission Calculation Components SSAP No. 10R, Paragraph 10.e.:
SSAP No. 10R, Paragraph 10.e.i.	$	(18,802	)	$	190,191		$	171,389
SSAP No. 10R, Paragraph 10.e.ii. (the lesser of paragraph 10.e.ii.a and 10.e.ii.b. below)		71,094			(99,631	)		(28,537	)
SSAP No. 10R, Paragraph 10.e.ii.a.		71,094			(99,631	)		(28,537	)
SSAP No. 10R, Paragraph 10.e.ii.b.		186,802			(73,144	)		113,658
SSAP No. 10R, Paragraph 10.e.iii.		155,845			(186,321	)		(30,476	)
Total	$	208,137		$	(95,761	)	$	112,376

• 10.a. – Federal income taxes paid in prior year that can be recovered through loss carrybacks for existing temporary differences that reverse by the end of the subsequent calendar year

• 10.b.i. – Adjusted gross DTAs, after the application of 10.a., expected to be realized within one year

• 10.b.ii. – 10% of adjusted statutory capital and surplus as shown on most recently filed statement

• 10.c. – Adjusted gross DTAs, after the application of 10.a. and 10.b., that can be offset against gross DTLs after considering the character of the DTAs and DTLs

• 10.d. – If the reporting entity’s financial statements and risk-based capital (RBC) calculated using an admitted adjusted gross DTA as the sum of 10.a., 10.b., and 10.c. results in the Company’s RBC level being above the maximum RBC level where an action level could occur as a result of the trend test (i.e., 250%); then the Company may elect to admit a higher amount of adjusted gross DTAs as calculated in paragraph 10.e.

• 10.e.i. – Federal income taxes paid in prior years that can be recovered through loss carrybacks for existing temporary differences that reverse during a timeframe corresponding with IRS tax loss carryback provisions, not to exceed three years

• 10.e.ii.(a) – Adjusted gross DTAs, after the application of 10.e.i, expected to be realized within three years

• 10.e.ii.(b) – 15% of adjusted statutory capital and surplus as shown on most recently filed statement

• 10.e.iii. – Adjusted gross DTAs, after the application of 10.e.i. and 10.e.ii., that can be offset against DTLs after considering the character of the DTAs and DTLs

89

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

Total increased admitted adjusted gross DTA’s as the result of the application of paragraph 10.e. SSAP No. 10R:

	December 31, 2010
	Ordinary		Capital			Total
Total increased admitted deferred tax asset	$	494,327	$	60,596		$	554,923
	December 31, 2009
	Ordinary		Capital			Total
Total increased admitted deferred tax asset	$	205,102	$	90,158		$	295,260
	Ordinary		Change Capital			Total
Total increased admitted deferred tax asset	$	289,225	$	(29,562	)	$	259,663
Used in SSAP No. 10R, paragraph 10.d.:

	December 31, 2010
	Ordinary		Capital		Total
Total Adjusted Capital		XXX		XXX		4,667,170
Authorized Control Level		XXX		XXX		636,411
	December 31, 2009
	Ordinary		Capital		Total
Total Adjusted Capital		XXX		XXX		5,600,252
Authorized Control Level		XXX		XXX		678,529
	Ordinary		Change Capital		Total
Total Adjusted Capital		XXX		XXX		(933,082	)
Authorized Control Level		XXX		XXX		(42,118	)

90

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

	December 31, 2010
	Ordinary			Capital			Total
SSAP No. 10R, Paragraphs 10.a., 10.b., and 10.c.:
Admitted Deferred Tax Assets	$	340,787		$	390,279		$	731,066
Admitted Assets		XXX			XXX			106,331,752
Adjusted Statutory Surplus*		XXX			XXX			3,743,200
Total Adjusted Capital from DTAs		XXX			XXX			4,667,170
Increases due to SSAP No. 10R, Paragraph 10.e.:
Admitted Deferred Tax Assets	$	494,327		$	60,596		$	554,923
Admitted Assets		494,327			60,596			554,923
Statutory Surplus		494,327			60,596			554,923
	December 31, 2009
	Ordinary			Capital			Total
SSAP No. 10R, Paragraphs 10.a., 10.b., and 10.c.:
Admitted Deferred Tax Assets	$	421,875		$	456,478		$	878,353
Admitted Assets		XXX			XXX			101,159,928
Adjusted Statutory Surplus*		XXX			XXX			4,731,565
Total Adjusted Capital from DTAs		XXX			XXX			5,600,252
Increases due to SSAP No. 10R, Paragraph 10.e.:
Admitted Deferred Tax Assets	$	205,102		$	90,158		$	295,260
Admitted Assets		205,102			90,158			295,260
Statutory Surplus		205,102			90,158			295,260
	Ordinary			Change Capital			Total
SSAP No. 10R, Paragraphs 10.a., 10.b., and 10.c.:
Admitted Deferred Tax Assets	$	(81,088	)	$	(66,199	)	$	(147,287	)
Admitted Assets		XXX			XXX			5,171,824
Adjusted Statutory Surplus*		XXX			XXX			(988,365	)
Total Adjusted Capital from DTAs		XXX			XXX			(933,082	)
Increases due to SSAP No. 10R, Paragraph 10.e.:
Admitted Deferred Tax Assets	$	289,225		$	(29,562	)	$	259,663
Admitted Assets		289,225			(29,562	)		259,663
Statutory Surplus		289,225			(29,562	)		259,663

* As reported on the statutory balance sheet for the most recently filed statement with the domiciliary state commissioner adjusted in accordance with SSAP No. 10R, paragraph 10.b.ii.

• XXX denotes breakout between ordinary and capital is not applicable to this information.

91

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

The impact of tax planning strategies at December 31, 2010 was as follows:

	December 31, 2010
	Ordinary Percent			Capital Percent			Total Percent
Impact of Tax Planning Strategies:
Adjusted Gross DTAs
(% of Total Adjusted Gross DTAs)		7	%		7	%		14	%
Net Admitted Adjusted Gross DTAs
(% of Total Net Admitted Adjusted Gross DTAs)		14	%		13	%		27	%

Current year income taxes incurred consist of the following major components:

	Year Ended December 31
	2010			2009			Change
Current Income Tax
Federal	$	(268,109	)	$	(104,925	)	$	(163,184	)
Foreign		(2,119	)		(17	)		(2,102	)
Subtotal		(270,228	)		(104,942	)		(165,286	)
Federal income tax on net capital gains		450,184			(235,951	)		686,135
Utilization of capital loss carry-forwards		—			—			—
Other		—			—			—
Federal and foreign income taxes incurred	$	179,956		$	(340,893	)	$	520,849

92

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

The Company’s current income tax incurred and change in deferred income tax differs from the amount obtained by applying the federal statutory rate of 35% to income before tax as follows:

	Year Ended December 31
	2010			2009			2008
Current income taxes incurred	$	179,956		$	(340,893	)	$	(151,595	)
Change in deferred income taxes (without tax on unrealized gains and losses)		126,689			251,128			208,565
Total income tax reported	$	306,645		$	(89,765	)	$	56,970
Income before taxes	$	1,443,732		$	(523,918	)	$	(824,446	)
		35.00	%		35.00	%		35.00	%
Expected income tax expense (benefit) at 35% statutory rate	$	505,306		$	(183,371	)	$	(288,556	)
Increase (decrease) in actual tax reported resulting from:
Dividends received deduction		(27,413	)		(23,617	)		(19,749	)
Tax credits		(57,815	)		(61,814	)		(82,095	)
Tax-exempt income		(90	)		(605	)		(681	)
Tax adjustment for IMR		(1,513	)		(1,213	)		(10,260	)
Surplus adjustment for in-force ceded		(22,522	)		25,009			336,881
Nondeductible expenses		3,213			3,626			2,717
Deferred tax benefit on other items in surplus		35,989			14,424			134,480
Provision to return		(5,730	)		(25,350	)		(2,188	)
Life-owned life insurance		(3,741	)		(4,051	)		(3,955	)
Dividends from certain foreign corporations		374			448			805
Statutory valuation allowance		(81,188	)		81,188			—
Prior period adjustment		(57,775	)		68,049			5,799
Intercompany dividends		(11,620	)		(256	)		—
Pretax income of Single Member Limited Liability Companies (SMLLC’s)		32,281			16,027			—
Partnership permanent adjustment		2,402			2,526			—
Other		(3,513	)		(785	)		(16,228	)
Total income tax reported	$	306,645		$	(89,765	)	$	56,970

93

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

7. Income Taxes (continued)

For federal income tax purposes, the Company joins in a consolidated income tax return filing with its parent and other affiliated companies. The method of allocation between the companies is subject to a written tax allocation agreement. Under the terms of the tax allocation agreement, allocations are based on separate income tax return calculations. The Company is entitled to recoup federal income taxes paid in the event the future losses and credits reduce the greater of the Company’s separately computed income tax liability or the consolidated group’s income tax liability in the year generated. The Company is also entitled to recoup federal income taxes paid in the event the losses and credits reduce the greater of the Company’s separately computed income tax liability or the consolidated group’s income tax liability in any carryback or carryforward year when so applied. Intercompany income tax balances are settled within thirty days of payment to or filing with the Internal Revenue Service. A tax return has not yet been filed for 2010.

As of December 31, 2010, the Company has no tax credit carryforwards. The Company had tax credit carryforwards at December 31, 2009 of $112,480. As of December 31, 2010 and 2009, the Company had no operating loss or capital loss carryforwards available for tax purposes.

The Company incurred income taxes of $248,482 and $146 during 2010 and 2008, respectively, which will be available for recoupment in the event of future net losses. The Company did not incur income taxes during 2009 which will be available for recoupment in the event of future net losses.

The amount of tax contingencies calculated for the Company as of December 31, 2010 and 2009 is $44,265 and $73,038, respectively. The total amount of tax contingencies that, if recognized, would affect the effective income tax rate is $44,265. The Company classifies interest and penalties related to income taxes as interest expense and penalty expense, respectively. The Company’s interest expense related to income taxes for the years ending December 31, 2010, 2009 and 2008 is $12,048, $5,088 and $4,111, respectively. The total interest payable balance as of December 31, 2010 and 2009 is $9,830 and $21,878, respectively. The Company recorded no liability for penalties. It is not anticipated that the total amounts of unrecognized tax benefits will significantly increase within twelve months of the reporting date.

The Company’s federal income tax returns have been examined by the Internal Revenue Service and closing agreements have been executed through 2004. The examination for the years 2005 through 2006 have been completed and resulted in tax return adjustments that are currently being appealed. The Company believes that there are adequate defenses against or sufficient provisions established related to any open or contested tax positions. An examination is currently underway for the years 2007 and 2008.

94

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes

Participating life insurance policies were issued by the Company which entitle policyholders to a share in the earnings of the participating policies, provided that a dividend distribution, which is determined annually based on mortality and persistency experience of the participating policies, is authorized by the Company. Participating insurance constituted approximately 0.06% and 0.07% of ordinary life insurance in force at December 31, 2010 and 2009, respectively.

For the years ended December 31, 2010, 2009 and 2008, premiums for life participating policies were $18,274, $21,721 and $18,433, respectively. The Company accounts for its policyholder dividends based on dividend scales and experience of the policies. The Company paid dividends in the amount of $10,074, $11,010 and $12,165 to policyholders during 2010, 2009 and 2008, respectively, and did not allocate any additional income to such policyholders.

A portion of the Company’s policy reserves and other policyholders’ funds (including separate account liabilities) relates to liabilities established on a variety of the Company’s annuity and deposit fund products. There may be certain restrictions placed upon the amount of funds that can be withdrawn without penalty. The amount of reserves on these products, by withdrawal characteristics, is summarized as follows:

	December 31 2010					December 31 2009
	Amount		Percent			Amount		Percent
Subject to discretionary withdrawal
With fair value adjustment	$	2,074,251		3	%	$	2,362,527		3	%
At book value less surrender charge of 5% or more		11,051,155		15			12,077,452		17
At fair value		30,171,132		41			24,823,739		35
Total with adjustment or at fair value		43,296,538		59			39,263,718		55
At book value without adjustment (with minimal or no charges or adjustments)		13,913,541		19			13,767,281		19
Not subject to discretionary withdrawal		16,081,041		22			18,345,290		26
Total annuity reserves and deposit fund liabilities - before reinsurance		73,291,120		100	%		71,376,289		100	%
Less reinsurance ceded		18,062,445					18,657,485
Net annuity reserves and deposit fund liabilities	$	55,228,675				$	52,718,804

95

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

Included in the liability for deposit-type contracts at December 31, 2010 and 2009 are $413,274 and $468,917, respectively, of funding agreements issued by an affiliate to special purpose entities in conjunction with non-recourse medium-term note programs. Under these programs, the proceeds from each note series issuance are used to purchase a funding agreement from an affiliated Company which secures that particular series of notes. The funding agreement is reinsured to the Company. In general, the payment terms of the note series match the payment terms of the funding agreement that secures that series. Claims for principal and interest for these funding agreements are afforded equal priority as other policyholders.

At December 31, 2010, the contractual maturities were as follows:

Year	Amount
2011	$	125,606
2012		54,233
2013		—
2014		233,434
2015		—
Thereafter		—

The Company’s liability for deposit-type contracts includes GIC’s and funding agreements assumed from MLIC. The liabilities assumed are $1,896,737 and $2,702,888 at December 31, 2010 and 2009, respectively.

Certain separate and variable accounts held by the Company relate to individual variable life insurance policies. The benefits provided on the policies are determined by the performance and/or fair value of the investments held in the separate account. The net investment experience of the separate account is credited directly to the policyholder and can be positive or negative. The assets of these separate accounts are carried at fair value. The life insurance policies typically provide a guaranteed minimum death benefit.

Certain separate accounts held by the Company represent funds which are administered for pension plans. The assets consist primarily of fixed maturities and equity securities and are carried at fair value. The Company provides a minimum guaranteed return to policyholders of certain separate accounts. Certain other separate accounts do not have any minimum guarantees and the investment risks associated with fair value changes are borne entirely by the policyholder.

96

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

Information regarding the separate accounts of the Company as of and for the years ended December 31, 2010, 2009 and 2008 is as follows:

	Guaranteed Indexed		Nonindexed Guarantee Less Than or Equal to 4%		Nonindexed Guarantee Greater Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, deposits and other considerations for the year ended December 31, 2010	$	—	$	14,373	$	12,735	$	6,368,599	$	6,395,707
Reserves for separate accounts as of December 31, 2010 with assets at:
Fair value	$	—	$	18,416	$	45,818	$	35,632,948	$	35,697,182
Amortized cost		—		589,789		—		—		589,789
Total as of December 31, 2010	$	—	$	608,205	$	45,818	$	35,632,948	$	36,286,971
Reserves for separate accounts by withdrawal characteristics as of December 31, 2010:
Subject to discretionary withdrawal:
With fair value adjustment	$	—	$	80,801	$	—	$	—	$	80,801
At fair value		—		—		—		35,595,332		35,595,332
At book value without fair value adjustment and with current surrender charge of less than 5%		—		508,989		—		—		508,989
Subtotal		—		589,790		—		35,595,332		36,185,122
Not subject to discretionary withdrawal		—		18,415		45,818		37,616		101,849
Total separate account liabilities at December 31, 2010	$	—	$	608,205	$	45,818	$	35,632,948	$	36,286,971

97

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

	Guaranteed Indexed		Nonindexed Guarantee Less  Than or Equal to 4%		Nonindexed Guarantee Greater Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, deposits and other considerations for the year ended December 31, 2009	$	—	$	25,111	$	11,535	$	4,277,875	$	4,314,521
Reserves for separate accounts as of December 31, 2009 with assets at:
Fair value	$	—	$	23,701	$	43,846	$	30,630,714	$	30,698,261
Amortized cost		—		564,835		—		—		564,835
Total as of December 31, 2009	$	—	$	588,536	$	43,846	$	30,630,714	$	31,263,096
Reserves for separate accounts by withdrawal characteristics as of December 31, 2009:
Subject to discretionary withdrawal:
With fair value adjustment	$	—	$	76,570	$	—	$	—	$	76,570
At fair value		—		—		—		30,630,714		30,630,714
At book value without fair value adjustment and with current surrender charge of less than 5%		—		488,265		—		—		488,265
Subtotal		—		564,835		—		30,630,714		31,195,549
Not subject to discretionary withdrawal		—		23,701		43,846		—		67,547
Total separate account liabilities at December 31, 2009	$	—	$	588,536	$	43,846	$	30,630,714	$	31,263,096

98

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

	Guaranteed Indexed		Nonindexed Guarantee Less Than or Equal to 4%		Nonindexed Guarantee Greater Than 4%		Nonguaranteed Separate Accounts		Total
Premiums, deposits and other considerations for the year ended December 31, 2008	$	—	$	63,549	$	36,534	$	4,145,459	$	4,245,542
Reserves for separate accounts as of December 31, 2008 with assets at:
Fair value	$	—	$	32,841	$	351,543	$	23,812,058	$	24,196,442
Amortized cost		—		548,144		—		—		548,144
Total as of December 31, 2008	$	—	$	580,985	$	351,543	$	23,812,058	$	24,744,586
Reserves for separate accounts by withdrawal characteristics as of December 31, 2008:
Subject to discretionary withdrawal:
With fair value adjustment	$	—	$	61,733	$	—	$	—	$	61,733
At fair value		—		—		—		23,812,058		23,812,058
At book value without fair value adjustment and with current surrender charge of less than 5%		—		486,411		—		—		486,411
Subtotal		—		548,144		—		23,812,058		24,360,202
Not subject to discretionary withdrawal		—		32,841		351,543		—		384,384
Total separate account liabilities at December 31, 2008	$	—	$	580,985	$	351,543	$	23,812,058	$	24,744,586

99

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

A reconciliation of the amounts transferred to and from the Company’s separate accounts is presented below:

	Year Ended December 31
	2010			2009			2008
Transfer as reported in the summary of operations of the separate accounts statement:
Transfers to separate accounts	$	6,369,429		$	4,414,472		$	4,199,455
Transfers from separate accounts		(4,622,672	)		(2,297,193	)		(3,658,761	)
Net transfers to separate accounts		1,746,757			2,117,279			540,694
Miscellaneous reconciling adjustments		(82,626	)		(270	)		(11,259	)
Net transfers as reported in the statement of operations of the life, accident and health annual statement	$	1,664,131		$	2,117,009		$	529,435

The legal insulation of separate account assets prevents such assets from being generally available to satisfy claims resulting from the general account. At December 31, 2010 and 2009, the Company’s separate account statement included legally insulated assets of $38,370,952 and $33,205,532, respectively. The assets legally insulated from general account claims at December 31, 2010 are attributed to the following products:

Product	Legally Insulated Assets
Group annuities	$	12,233,633
Variable annuities		18,848,339
Fixed universal life		555,267
Variable universal life		6,472,224
Variable life		173,383
Modified separate accounts		88,106
Total separate account assets	$	38,370,952

100

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

Some separate account liabilities are guaranteed by the general account. In accordance with the guarantees provided, if the investment proceeds are insufficient to cover the rate of return guaranteed for the product, the policyholder proceeds will be remitted by the general account. As of December 31, 2010, the general account of the Company had a maximum guarantee for separate account liabilities of $1,954,169. To compensate the general account for the risk taken, the separate account paid risk charges of $107,662 to the general account in 2010. As of December 31, 2010, the general account of the Company had paid $76,405 toward separate account guarantees.

The Company reported guaranteed separate account assets at amortized cost in the amount of $68,840 based upon the prescribed practice granted by the State of Iowa as described in Note 2. These assets had a fair value of $71,653 at December 31, 2010, which would have resulted in an unrealized gain of $2,813 had these assets been reported at fair value.

The Company reported additional separate account assets at amortized cost in the amount of $505,926 due to a practice prescribed by the State of Iowa, as discussed in Note 2. These assets had a fair value of $528,910 at December 31, 2010, which would have resulted in an unrealized gain of $22,984 had these assets been reported at fair value.

The Company does not participate in securities lending transactions within the separate account.

Effective December 31, 2009, the Company adopted Actuarial Guideline XLIII (AG 43), which replaces Actuarial Guidelines 34 and 39. AG 43 specifies statutory reserve requirements for variable annuity contracts with benefit guarantees (VACARVM) and without benefit guarantees and related products. The AG 43 reserve calculation includes variable annuity products issued after January 1, 1981. Examples of covered guaranteed benefits include guaranteed minimum accumulation benefits, return of premium death benefits, guaranteed minimum income benefits, guaranteed minimum withdrawal benefits and guaranteed payout annuity floors. The Aggregate Reserve for contracts falling within the scope of AG 43 is equal to the Conditional Tail Expectation (CTE) Amount, but not less than the Standard Scenario Amount (SSA). The Company reported an increase in reserves and a decrease in net income of $17,571 at December 31, 2009, related to the adoption of AG 43 and changes in the underlying assumptions.

To determine the CTE Amount, the Company used 1,000 of the pre-packaged scenarios developed by the American Academy of Actuaries (AAA) produced in October 2005 and prudent estimate assumptions based on Company experience. The SSA was determined using the assumptions and methodology prescribed in AG 43 for determining the SSA.

101

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

At December 31, 2010 and 2009, the Company had variable and separate account annuities with minimum guaranteed benefits as follows:

Benefit and Type of Risk	Subjected Account Value		Amount of Reserve Held		Reinsurance Reserve Credit
December 31, 2010
Minimum guaranteed death benefit	$	9,490,182	$	1,177,396	$	864,478
Minimum guaranteed income benefit		5,577,295		849,211		800,705
Guaranteed premium accumulation fund		136,292		10,717		—
Minimum guaranteed withdrawal benefit		9,433,267		960		960
December 31, 2009
Minimum guaranteed death benefit	$	9,406,064	$	1,253,807	$	918,570
Minimum guaranteed income benefit		5,504,688		892,435		830,185
Guaranteed premium accumulation fund		63,644		8,388		—
Minimum guaranteed withdrawal benefit		6,431,653		56,028		40,560

Reserves on the Company’s traditional life insurance products are computed using mean reserving methodologies. These methodologies result in the establishment of assets for the amount of the net valuation premiums that are anticipated to be received between the policy’s paid-through date to the policy’s next anniversary date. At December 31, 2010 and 2009, the gross premium and loading amounts related to these assets (which are reported as premiums deferred and uncollected), are as follows:

	Gross			Loading		Net
December 31, 2010
Life and annuity:
Ordinary first-year business	$	14,252		$	479	$	13,773
Ordinary renewal business		482,857			7,405		475,452
Group life direct business		9,163			2,132		7,031
Credit life business		(8,524	)		—		(8,524	)
Reinsurance ceded		(288,150	)		—		(288,150	)
		209,598			10,016		199,582
Accident and health		24,304			—		24,304
	$	233,902		$	10,016	$	223,886

102

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

8. Policy and Contract Attributes (continued)

	Gross			Loading		Net
December 31, 2009
Life and annuity:
Ordinary first-year business	$	12,260		$	325	$	11,935
Ordinary renewal business		528,884			12,610		516,274
Group life direct business		15,896			2,309		13,587
Credit life business		(12,865	)		—		(12,865	)
Reinsurance ceded		(264,249	)		—		(264,249	)
		279,926			15,244		264,682
Accident and health		15,520			—		15,520
	$	295,446		$	15,244	$	280,202

The Company anticipates investment income as a factor in the premium deficiency calculation, in accordance with SSAP No. 54, Individual and Group Accident and Health Contracts. At December 31, 2010 and 2009, the Company had insurance in force aggregating $465,525,557 and $361,829,973, respectively, in which the gross premiums are less than the net premiums required by the valuation standards established by the Insurance Division, Department of Commerce, of the State of Iowa. The Company established policy reserves of $907,228 and $675,762 to cover these deficiencies at December 31, 2010 and 2009, respectively.

For indeterminate premium products, a full schedule of current and anticipated premium rates is developed at the point of issue. Premium rate adjustments are considered when anticipated future experience foretells deviations from the original profit standards. The source of deviation (mortality, persistency, expense, etc.) is an important consideration in the re-rating decision as well as the potential effect of a rate change on the future experience of the existing block of business.

9. Capital and Surplus

The Company is subject to limitations, imposed by the State of Iowa, on the payment of dividends to its shareholders. Generally, dividends during any twelve-month period may not be paid, without prior regulatory approval, in excess of the greater of (a) 10 percent of the Company’s statutory surplus as of the preceding December 31, or (b) the Company’s statutory gain from operations before net realized capital gains (losses) on investments for the preceding year. Subject to the availability of unassigned surplus at the time of such dividend, the maximum payment which may be made in 2011, without the prior approval of insurance regulatory authorities, is $474,517.

103

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

9. Capital and Surplus (continued)

Prior to merging into the Company during 2009, IFLIC was partially owned by unaffiliated participating common shareholders. At December 31, 2008, IFLIC had 3,000 participating common shares authorized and 1,500 shares issued and outstanding. Participating shareholders’ surplus is segregated from unassigned surplus on the balance sheet to disclose the surplus required by mandatory participating voting common stock redemption provisions of the Company bylaws. At December 31, 2008, IFLIC had Participating shareholders’ surplus of $378. Participating common shareholders were redeemed for cash consideration of $421 during 2009 prior to the merger of IFLIC into the Company, resulting in a reduction of common stock and additional paid-in capital of $2 each and a reduction of unassigned surplus of $417.

On December 30, 2009, the Company received a capital contribution of $500,000 from its parent company.

The Company paid a common stock dividend of $1,260,830 to its common stock shareholder, TIHI on December 23, 2010. The Company paid preferred stock dividends of $36,260 and $102,910 to its preferred stock shareholders, AEGON and Transamerica, respectively, on December 23, 2010.

The Company paid a dividend to its parent company of $10,031 in the form of 1,000 shares of stock of TPIC on June 25, 2009.

On December 31, 2008, the Company received a contribution of $9,300 from its parent company in the form of 1,000 shares of TPIC. Prior to the merger of LIICA into the Company, LIICA received a capital contribution from its parent, AEGON of $408,438 on June 2, 2008. On June 3, 2008, LIICA repurchased 504,033 of its Series A preferred shares for $392,000 from AEGON. Net impact to gross paid-in and contributed surplus for the Company was $16,438. The Company received a capital contribution of $481,500 from its parent company, TIHI, on December 30, 2008.

The Company paid a common stock dividend of $268,580 to its common stock shareholder, TIHI, on December 29, 2008.

The Company paid preferred stock dividends of $18,750 and $12,670 to its preferred stock shareholders, AEGON and Transamerica, respectively, on December 29, 2008. Prior to its merger with the Company, in conjunction with the redemption of its 504,033 shares of its Series A preferred stock, LIICA paid a dividend of $16,438 to its preferred stock shareholder, AEGON, on June 3, 2008.

104

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

9. Capital and Surplus (continued)

Life and health insurance companies are subject to certain risk-based capital (RBC) requirements as specified by the NAIC. Under those requirements, the amount of capital and surplus maintained by a life or health insurance company is to be determined based on the various risk factors related to it. At December 31, 2010, the Company meets the minimum RBC requirements.

On September 30, 2002, LIICA received $150,000 from AEGON in exchange for surplus notes. These notes are due 20 years from the date of issuance at an interest rate of 6%, and are subordinate and junior in right of payment to all obligations and liabilities of the Company. In the event of liquidation of the Company, the holders of the issued and outstanding preferred stock shall be entitled to priority only with respect to accumulated but unpaid dividends before the holder of the surplus notes and full payment of the surplus notes shall be made before the holders of common stock become entitled to any distribution of the remaining assets of the Company. The Company received approval from the Insurance Division, Department of Commerce, of the State of Iowa prior to paying quarterly interest payments.

Additional information related to the outstanding surplus notes at December 31, 2010 and 2009 is as follows:

For Year Ending	Balance Outstanding		Interest Paid Current Year		Cumulative Interest Paid		Accrued Interest
2010	$	150,000	$	9,000	$	72,000	$	2,250
2009		150,000		6,750		63,000		2,250

10. Securities Lending

The Company participates in an agent-managed securities lending program. The Company receives collateral equal to 102% of the fair value of the loaned domestic securities as of the transaction date. If the fair value of the collateral is at any time less than 102% of the fair value of the loaned securities, the counterparty is mandated to deliver additional collateral, the fair value of which, together with the collateral already held in connection with the lending transaction, is at least equal to 102% of the fair value of the loaned government or other domestic securities. In the event the Company loans a foreign security and the denomination of the currency of the collateral is other than the denomination of the currency of the loaned foreign security, the Company receives and maintains collateral equal to 105% of the fair value of the loaned security.

105

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

10. Securities Lending (continued)

At December 31, 2010 and 2009, respectively, securities in the amount of $3,841,442 and $827,408 were on loan under securities lending agreements as a part of this program. At December 31, 2010, the collateral the Company received from securities lending activities was in the form of cash and on open terms. This cash collateral is reinvested and is not available for general corporate purposes. The reinvested cash collateral has a fair value of $3,954,149 and $836,069 at December 31, 2010 and 2009, respectively.

The contractual maturities of the securities lending collateral positions are as follows:

	Fair Value
Open	$	3,956,579
30 days or less		—
31 to 60 days		—
61 to 90 days		—
Greater than 90 days		—
Total		3,956,579
Securities received		—
Total collateral received	$	3,956,579

The maturity dates of the reinvested securities lending collateral are as follows:

	Amortized Cost		Fair Value
Open	$	281,436	$	281,436
30 days or less		2,534,617		2,534,617
31 to 60 days		728,905		728,905
61 to 90 days		267,667		267,667
91 to 120 days		22,448		22,217
121 to 180 days		40,525		40,450
181 to 365 days		21,038		21,064
1 to 2 years		15,915		15,552
Greater than 3 years		44,329		42,241
Total		3,956,880		3,954,149
Securities received		—		—
Total collateral reinvested	$	3,956,880	$	3,954,149

106

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

10. Securities Lending (continued)

For securities lending, the Company’s sources of cash that it uses to return the cash collateral is dependent upon the liquidity of the current market conditions. Under current conditions, the Company has securities with a par value of $3,957,791 (fair value of $3,954,149) that are currently tradable securities that could be sold and used to pay for the $3,956,579 in collateral calls that could come due under a worst-case scenario.

11. Retirement and Compensation Plans

The Company’s employees participate in a qualified defined benefit pension plan sponsored by AEGON. The Company has no legal obligation for the plan. The Company recognizes pension expense equal to its allocation from AEGON. The pension expense is allocated among the participating companies based on International Accounting Standards 19 (IAS 19), Accounting for Employee Benefits as a percent of salaries. The benefits are based on years of service and the employee’s compensation during the highest five consecutive years of employment. Pension expense aggregated $18,324, $17,949 and $16,434 for the years ended December 31, 2010, 2009 and 2008, respectively. The plan is subject to the reporting and disclosure requirements of the Employee Retirement Income Security Act of 1974.

The Company’s employees also participate in a defined contribution plan sponsored by AEGON which is qualified under Section 401(k) of the Internal Revenue Service Code. Employees of the Company who customarily work at least 1,000 hours during each calendar year and meet the other eligibility requirements are participants of the plan. Participants may elect to contribute up to twenty-five percent of their salary to the plan. The Company will match an amount up to three percent of the participant’s salary. Participants may direct all of their contributions and plan balances to be invested in a variety of investment options. The plan is subject to the reporting and disclosure requirements of the Employee Retirement and Income Security Act of 1974. Expense related to this plan was $10,390, $9,654 and $9,795, for the years ended December 31, 2010, 2009 and 2008, respectively.

107

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

11. Retirement and Compensation Plans (continued)

AEGON sponsors supplemental retirement plans to provide the Company’s senior management with benefits in excess of normal pension benefits. The plans are noncontributory, and benefits are based on years of service and the employee’s compensation level. The plans are unfunded and nonqualified under the Internal Revenue Service Code. In addition, AEGON has established incentive deferred compensation plans for certain key employees of the Company. The Company’s allocation of expense for these plans for each of the years ended December 31, 2010, 2009 and 2008 was negligible. AEGON also sponsors an employee stock option plan/stock appreciation rights for employees of the Company and a stock purchase plan for its producers, with the participating affiliated companies establishing their own eligibility criteria, producer contribution limits and company matching formula. These plans have been accrued or funded as deemed appropriate by management of AEGON and the Company.

In addition to pension benefits, the Company participates in plans sponsored by AEGON that provide postretirement medical, dental and life insurance benefits to employees meeting certain eligibility requirements. Portions of the medical and dental plans are contributory. The postretirement plan expenses are charged to affiliates in accordance with an intercompany cost sharing arrangement. The Company expensed $4,609, $4,254 and $1,382 related to these plans for the years ended December 31, 2010, 2009 and 2008, respectively.

12. Related Party Transactions

The Company shares certain officers, employees and general expenses with affiliated companies.

108

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

12. Related Party Transactions (continued)

The Company is party to a common cost allocation service agreement between AEGON companies, in which various affiliated companies may perform specified administrative functions in connection with the operation of the Company, in consideration of reimbursement of actual costs of services rendered. The Company is also party to two additional service agreements with Transamerica Advisors Life Insurance Company of New York (TALICNY) and TFLIC, in which the Company provides services, including accounting, data processing and other professional services, in consideration of reimbursement of the actual costs of services rendered. The Company is also a party to a Management and Administrative and Advisory agreement with AEGON USA Realty Advisors, Inc. whereby the advisor serves as the administrator and advisor for the Company’s mortgage loan operations. AEGON USA Investment Management, LLC acts as a discretionary investment manager under an Investment Management Agreement with the Company. The net amount received by the Company as a result of being a party to these agreements was $46,373, $32,580 and $19,737 during 2010, 2009 and 2008, respectively. Fees charged between affiliates approximate their cost. The Company has an administration service agreement with Transamerica Asset Management, Inc. to provide administrative services to the AEGON/Transamerica Series Trust. The Company received $51,177, $40,040 and $44,122 for these services during 2010, 2009 and 2008, respectively.

Transamerica Capital, Inc. provides wholesaling distribution services for the Company under a distribution agreement. The Company incurred expenses under this agreement of $67,790, $73,721 and $74,156 for the years ended December 31, 2010, 2009 and 2008, respectively.

At December 31, 2010 and 2009, respectively, the Company reported a net amount of payables to affiliates of $228,137 and $82,670. Terms of settlement require that these amounts be settled within 90 days. Receivables from and payables to affiliates bear interest at the thirty-day commercial paper rate.

109

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

12. Related Party Transactions (continued)

At December 31, 2010, the Company had short-term intercompany notes receivable of $270,000 as follows. In accordance with SSAP No. 25, Accounting for and Disclosures about Transactions with Affiliates and Other Related Parties, these notes are reported as short-term investments.

Receivable from	Amount		Due By	Interest Rate
Transamerica Corporation	$	75,500	July 19, 2011		0.35	%
AEGON		69,500	December 22, 2011		0.25
AEGON		18,000	December 24, 2011		0.25
AEGON		76,000	December 27, 2011		0.25
AEGON		31,000	December 29, 2011		0.25

At December 31, 2009, the Company had short-term intercompany notes receivable of $880,200 as follows. All of these notes were repaid prior to their due date.

Receivable from	Amount		Due By	Interest Rate
AEGON	$	6,600	June 1, 2010		0.30	%
AEGON		14,000	June 2, 2010		0.30
AEGON		17,700	June 15, 2010		0.30
AEGON		6,700	June 19, 2010		0.30
AEGON		39,200	June 24, 2010		0.30
AEGON		20,900	June 25, 2010		0.30
AEGON		67,600	June 26, 2010		0.30
AEGON		7,900	July 2, 2010		0.32
Transamerica Corporation		123,800	July 24, 2010		0.32
AEGON		11,700	July 27, 2010		0.32
AEGON		17,500	July 28, 2010		0.32
AEGON		89,700	July 29, 2010		0.32
AEGON		30,800	July 30, 2010		0.32
AEGON		26,100	October 29, 2010		0.22
AEGON		330,000	December 11, 2010		0.20
AEGON		70,000	December 15, 2010		0.20

During 2010, 2009 and 2008, the Company paid (received) net interest of $142, $(1,193) and $3,223, respectively, to affiliates.

110

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

12. Related Party Transactions (continued)

During 1998, the Company issued life insurance policies to two affiliated companies, covering the lives of certain employees of those affiliates. Aggregate reserves for policies and contracts related to these policies are $143,563 and $138,726 at December 31, 2010 and 2009, respectively.

In prior years, the Company purchased life insurance policies covering the lives of certain employees of the Company from an affiliate. At December 31, 2010 and 2009, the cash surrender value of these policies was $148,756 and $143,644, respectively.

13. Commitments and Contingencies

At December 31, 2010 and 2009, the Company has mortgage loan commitments of $37,624 and $211,491, respectively. The Company has contingent commitments for $457,326 and $686,426 as of December 31, 2010 and 2009, respectively, to provide additional funding for various joint ventures, partnerships, and limited liability companies, which includes LIHTC commitments of $29,934 and $45,413, respectively.

There were no private placement commitments outstanding as of December 31, 2010. Private placement commitments outstanding as of December 31, 2009 were $18,000.

There were no securities being acquired on a “to be announced” (TBA) basis as of December 31, 2010. TBA securities outstanding as of December 31, 2009 were $5,049.

The Company may pledge assets as collateral for derivative transactions. At December 31, 2010 and 2009, the Company has pledged invested assets with a carrying value of $210,686 and $366,806, respectively, and fair value of $208,328 and $400,679, respectively, in conjunction with these transactions. Also in conjunction with the derivative transactions, cash in the amount of $215,045 and securities in the amount of $259 were posted to the Company as of December 31, 2009, which were not included in the financials of the Company. A portion of the cash posted to the Company was reposted as collateral by the Company in the amount of $13,309 as of December 31, 2009.

As mentioned in Note 1, amendments to SSAP No. 91R during 2010 resulted in the cash collateral received from derivative counterparties being recorded on the Company’s balance sheet. The amount of cash collateral posted as of December 31, 2010 was $240,335. In addition, securities in the amount of $104,186 were also posted to the Company as of December 31, 2010, which were not included in the financials of the Company. In accordance with amended SSAP No. 91R, noncash collateral is not to be recognized by the recipient unless that collateral is sold or repledged or the counterparty defaults.

111

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

13. Commitments and Contingencies (continued)

The Company may pledge assets as collateral for transactions involving funding agreements. At December 31, 2010 and 2009, the Company has pledged invested assets with a carrying amount of $182,365 and $243,127, respectively, and fair value of $190,511 and $244,838, respectively, in conjunction with these transactions.

The Company had outstanding funding agreements totaling $4,500,724 and $5,450,716 at December 31, 2010 and 2009, respectively, to the FHLB, and the funds received are reported as deposit-type liabilities per SSAP No. 52, Deposit-Type Contracts. Total reserves are equal to the funding agreements balance. These funding agreements are used for investment spread management purposes and are subject to the same asset/liability management practices as other deposit-type business. All of the funding agreements issued to the FHLB are classified in the general account as it is a general obligation of the Company.

Collateral is required by the FHLB to support repayment of the funding agreements. The amount of pledged collateral at December 31, 2010 and 2009 was $6,607,053 and $6,922,409, respectively. In addition, the FHLB requires their common stock to be purchased. The Company owns $210,250 and $252,525 of FHLB common stock at December 31, 2010 and 2009, respectively. The FHLB has set funding capacity limits on the Company which are significantly higher than the current funding agreement level; however, the FHLB is under no obligation to extend additional capacity.

The Company has issued synthetic GIC contracts to benefit plan sponsors on assets totaling $2,034,558 and $4,201,338 as of December 31, 2010 and 2009, respectively. A synthetic GIC is an off-balance sheet fee-based product sold primarily to tax qualified plans. The plan sponsor retains ownership and control of the related plan assets. The Company provides book value benefit responsiveness in the event that qualified plan benefit requests exceed plan cash flows. In certain contracts, the Company agrees to make advances to meet benefit payment needs and earns a market interest rate on these advances. The periodically adjusted contract-crediting rate is the means by which investment and benefit responsive experience is passed through to participants. In return for the book value benefit responsive guarantee, the Company receives a premium that varies based on such elements as benefit responsive exposure and contract size. The Company underwrites the plans for the possibility of having to make benefit payments and also must agree to the investment guidelines to ensure appropriate credit quality and cash flow. A contract reserve of $3,000 has been established for the possibility of unexpected benefit payments at below market interest rates at December 31, 2010 and 2009.

The Company has guaranteed that TFLIC, an affiliate, will maintain capital and surplus amounts in excess of the statutory minimum requirements of $3,000. At December 31, 2010, TFLIC had capital and surplus of $794,667. The Company has recorded no liability for this guarantee.

112

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

13. Commitments and Contingencies (continued)

The Company has provided a guarantee for the performance of an affiliated noninsurance entity that was involved in guaranteed sales of investments in LIHTC partnerships. These partnerships are partially or majority owned by a noninsurance subsidiary of the Company for which a third party is the primary investor. The balance of the investor’s capital account covered by this transaction is $349,609 as of December 31, 2010. The nature of the obligation is to provide the investor with a minimum guaranteed annual and cumulative return on their contributed capital. The Company is not at risk for changes in tax law or the investor’s inability to fully utilize tax benefits. Accordingly, the Company believes the likelihood of having to make material payments under the guarantee is remote.

As of December 31, 2010 and 2009, the Company had entered into a credit enhancement and a standby liquidity asset purchase agreement on a municipal variable rate demand note facility with commitment amounts of $535 and $1,105, respectively, for which it was paid a fee. Prior to a change in the remarketing agent, this agreement was drawn upon and repaid during 2009. The Company does not believe there will be an additional draw under this agreement. However, if there were, any such draws would be purchases of municipal bonds, which would be repaid with interest.

At December 31, 2009, the Company had entered into multiple agreements with commitment amounts of $142,425 for which it was paid a fee to provide credit enhancement and standby liquidity asset purchase agreements on municipal variable rate demand note facilities. A draw was made under one of these liquidity facilities in January 2008 for approximately $1,900, which was repaid in full with interest. This agreement was unwound during 2010, so the Company no longer holds a contingent reserve related to this agreement as of December 31, 2010.

The Company serves as guarantor for an affiliate’s guarantees of the principal value of loans made to entities which invest in certain investment funds. There was no notional amount associated with these guarantees as of December 31, 2010 or 2009. The investment funds’ assets are restricted based on established investment guidelines and are required, upon a decline in value below a formula based threshold, to either replace the assets with fixed income instruments or sell assets and pay down the loan in order to minimize the guarantor’s principal protection liability. There are no expected payments associated with these guarantees.

The Company has also provided a guarantee for the obligations of noninsurance affiliates who have accepted assignments of structured settlement payment obligations from other insurers and purchase structured settlement insurance policies from subsidiaries of the Company that match those obligations. There are no expected payments associated with this guarantee.

113

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

13. Commitments and Contingencies (continued)

The Company is a party to legal proceedings involving a variety of issues incidental to its business, including class actions. Lawsuits may be brought in nearly any federal or state court in the United States or in an arbitral forum. In addition, there continues to be significant federal and state regulatory activity relating to financial services companies. The Company’s legal proceedings are subject to many variables, and given its complexity and scope, outcomes cannot be predicted with certainty. Although legal proceedings sometimes include substantial demands for compensatory and punitive damages, and injunctive relief, it is management’s opinion that damages arising from such demands will not be material to the Company’s financial position.

The Company recorded a one-time provision to general insurance expenses of $140,000 for settlement of a dispute related to a Bank Owned Life Insurance (BOLI) policy in the United States. Subsequent to the disruption in the credit market, which affected the investment value of the policy’s underlying assets, a suit was filed alleging that the policy terms were not sufficiently fulfilled by AEGON.

The Company is subject to insurance guaranty laws in the states in which it writes business. These laws provide for assessments against insurance companies for the benefit of policyholders and claimants in the event of insolvency of other insurance companies. Assessments are charged to operations when received by the Company, except where right of offset against other taxes paid is allowed by law. Amounts available for future offsets are recorded as an asset on the Company’s balance sheet. The future obligation for known insolvencies has been accrued based on the most recent information available from the National Organization of Life and Health Insurance Guaranty Associations. Potential future obligations for unknown insolvencies are not determinable by the Company and are not required to be accrued for financial reporting purposes. The Company has established a reserve of $37,041 and $34,814 and an offsetting premium tax benefit of $3,550 and $4,309 at December 31, 2010 and 2009, respectively, for its estimated share of future guaranty fund assessments related to several major insurer insolvencies. The guaranty fund expense was $2,465, $460 and $1,720, for the years ended December 31, 2010, 2009 and 2008, respectively.

14. Sales, Transfer, and Servicing of Financial Assets and Extinguishments of Liabilities

The Company has recorded liabilities of $200,977 and $632,109 for municipal repurchase agreements as of December 31, 2010 and 2009, respectively. The repurchase agreements are collateralized by securities with book values of $235,220 and $637,109 as of December 31, 2010 and 2009, respectively. These securities have maturity dates that range from 2011 to 2029 and have a weighted average interest rate of 5.37%.

The Company did not participate in dollar repurchase agreements at December 31, 2010 or 2009.

114

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

14. Sales, Transfer, and Servicing of Financial Assets and Extinguishments of Liabilities (continued)

In the course of the Company’s asset management, securities are sold and reacquired within 30 days of the sale date to enhance the Company’s yield on its investment portfolio. The details by NAIC designation 3 or below of securities sold during 2010 and reacquired within 30 days of the sale date are:

	Number of Transactions		Book Value  of Securities Sold		Cost of Securities Repurchased		Gain/(Loss)
Bonds:
NAIC 3		1	$	1,840	$	1,879	$	(25	)
NAIC 4		1		4,177		4,728		646
NAIC 5		4		2,453		2,590		190
NAIC 6		6		4,232		4,460		176

15. Reconciliation to Statutory Statement

The 2008 Annual Statement did not include the appropriate tax effect on the mark to market income on a derivative as of December 31, 2008. This item was adjusted for in the 2008 financial statements, as discussed further below, and was corrected through federal income tax expense in the 2009 Annual Statement. There were no reconciling items at December 31, 2010 or for the year then ended. The following is a reconciliation of amounts previously reported to the Insurance Division, Department of Commerce, of the State of Iowa in the 2009 Annual Statement, to those reported in the accompanying statutory-basis financial statements:

	December 31, 2009
Statement of Operations:
Statutory net loss as reported in the Company’s Annual Statement of Operations:	$	(99,471	)
Increase federal income tax benefit		93,046
Total statutory net loss per financial statements	$	(6,425	)

115

Transamerica Life Insurance Company

Notes to Financial Statements – Statutory Basis

(Dollars in Thousands, Except per Share amounts)

15. Reconciliation to Statutory Statement (continued)

The following is a reconciliation of amounts previously reported to the Insurance Division, Department of Commerce, of the State of Iowa in the 2008 Annual Statement, to those reported in the accompanying statutory-basis financial statements:

	December 31, 2008
Statement of Operations:
Statutory net loss as reported in the Company’s Annual Statement of Operations:	$	(528,468	)
Reduce federal income tax benefit		(93,046	)
Restatement to reflect IFLIC merger		96
Total statutory net income (loss) per financial statements	$	(621,418	)

16. Subsequent Events

The financial statements are adjusted to reflect events that occurred between the balance sheet date and the date when the financial statements are available to be issued, April 8, 2011, provided they give evidence of conditions that existed at the balance sheet date (Type I). Events that are indicative of conditions that arose after the balance sheet date are disclosed, but do not result in an adjustment of the financial statements themselves (Type II). As of April 8, 2011, the Company has not identified any Type I or Type II subsequent events for the year ended December 31, 2010.

17. Unaudited Subsequent Events

Subject to regulatory approval, the Company will be a party to a series of reinsurance agreements to support the divestment of its life reinsurance business to SCOR that will transpire either in the second or third quarter of 2011. In conjunction with this transaction, certain blocks of business will be recaptured from affiliates. The net surplus impact to the Company will not be known until the transaction is closed with SCOR; however the negative surplus impact is expected to be approximately $400,000.

116

Transamerica Life Insurance Company

Summary of Investments – Other Than

Investments in Related Parties

(Dollars in Thousands)

December 31, 2010

SCHEDULE I

Type of Investment	Cost (1)		Market Value		Amount at Which Shown in the Balance Sheet
Fixed maturities
Bonds:
United States government and government agencies and authorities	$	3,920,855	$	3,927,101	$	3,920,855
States, municipalities and political subdivisions		1,069,997		1,081,867		1,069,997
Foreign governments		717,413		737,784		717,413
Hybrid securities		1,559,172		1,349,230		1,559,172
All other corporate bonds		39,653,906		39,880,621		39,653,906
Preferred stocks		123,925		121,878		123,925
Total fixed maturities		47,045,268		47,098,481		47,045,268
Equity securities
Common stocks:
Industrial, miscellaneous and all other		307,132		358,631		358,631
Total equity securities		307,132		358,631		358,631
Mortgage loans on real estate		8,027,115				8,027,115
Real estate		120,965				120,965
Policy loans		746,677				746,677
Other long-term investments		1,399,892				1,399,892
Cash, cash equivalents and short-term investments		1,303,081				1,303,081
Total investments	$	58,950,130			$	59,001,629

(1) Original cost of equity securities and, as to fixed maturities, original cost reduced by repayments and adjusted for amortization of premiums or accrual of discounts.

117

Transamerica Life Insurance Company

Supplementary Insurance Information

(Dollars in Thousands)

SCHEDULE III

	Future Policy Benefits and Expenses		Unearned Premiums		Policy and Contract Liabilities		Premium Revenue		Net Investment Income*		Benefits, Claims Losses and Settlement Expenses		Other Operating Expenses*
Year ended December 31, 2010
Individual life	$	14,015,969	$	—	$	256,354	$	1,411,484	$	993,846	$	1,938,525	$	1,109,156
Individual health		2,906,758		102,601		137,513		492,364		199,500		437,569		150,292
Group life and health		1,413,616		15,466		96,571		330,139		75,398		281,807		114,825
Annuity		17,990,509		—		26,915		6,931,132		1,650,427		5,616,190		3,283,491
	$	36,326,852	$	118,067	$	517,353	$	9,165,119	$	2,919,171	$	8,274,091	$	4,657,764
Year ended December 31, 2009
Individual life	$	13,898,182	$	—	$	273,389	$	1,286,997	$	900,907	$	1,408,720	$	986,135
Individual health		2,801,188		116,341		121,468		470,438		179,158		411,103		158,964
Group life and health		1,409,957		16,322		103,431		344,829		92,181		270,852		135,934
Annuity		19,080,480		—		22,049		5,997,868		1,900,911		1,404,938		6,767,121
	$	37,189,807	$	132,663	$	520,337	$	8,100,132	$	3,073,157	$	3,495,613	$	8,048,154
Year ended December 31, 2008
Individual life	$	14,091,494	$	—	$	235,075	$	1,945,171	$	1,004,973	$	1,663,836	$	4,643,176
Individual health		2,663,242		133,885		125,768		501,797		189,285		425,938		183,199
Group life and health		1,416,556		17,766		108,339		370,647		102,526		300,950		178,562
Annuity		23,412,004		—		15,183		4,700,329		2,590,142		5,947,854		9,408,003
	$	41,583,296	$	151,651	$	484,365	$	7,517,944	$	3,886,926	$	8,338,578	$	14,412,940

* Allocations of net investment income and other operating expenses are based on a number of assumptions and estimates, and the results would change if different methods were applied.

118

Transamerica Life Insurance Company

Reinsurance

(Dollars in Thousands)

SCHEDULE IV

	Gross Amount		Ceded to Other Companies		Assumed From Other Companies		Net Amount		Percentage of Amount Assumed to Net
Year ended December 31, 2010
Life insurance in force	$	459,820,666	$	969,368,385	$	731,229,732	$	221,682,013		330	%
Premiums:
Individual life		2,631,499		3,101,663		1,881,648		1,411,484		133	%
Individual health		536,163		154,031		110,232		492,364		22	%
Group life and health		398,638		87,932		19,433		330,139		6	%
Annuity		7,197,141		334,516		68,507		6,931,132		1	%
	$	10,763,441	$	3,678,142	$	2,079,820	$	9,165,119		23	%
Year ended December 31, 2009
Life insurance in force	$	450,746,436	$	908,732,362	$	677,546,211	$	219,560,285		309	%
Premiums:
Individual life	$	2,466,652	$	2,799,049	$	1,619,394	$	1,286,997		126	%
Individual health		540,470		189,419		119,387		470,438		25	%
Group life and health		389,911		74,823		29,741		344,829		9	%
Annuity		9,312,898		3,355,296		40,266		5,997,868		1	%
	$	12,709,931	$	6,418,587	$	1,808,788	$	8,100,132		22	%
Year ended December 31, 2008
Life insurance in force	$	443,518,542	$	837,623,161	$	634,973,061	$	240,868,442		264	%
Premiums:
Individual life	$	2,471,167	$	2,071,576	$	1,545,580	$	1,945,171		79	%
Individual health		573,587		205,331		133,541		501,797		27	%
Group life and health		422,904		83,809		31,552		370,647		9	%
Annuity		9,841,785		5,242,316		100,860		4,700,329		2	%
	$	13,309,443	$	7,603,032	$	1,811,533	$	7,517,944		24	%

119

FINANCIAL STATEMENTS

Transamerica Life Insurance Company

Separate Account VA C

Year Ended December 31, 2010

Transamerica Life Insurance Company

Separate Account VA C

Financial Statements

Year Ended December 31, 2010

Contents

Report of Independent Registered Public Accounting Firm	1
Financial Statements
Statements of Assets and Liabilities	2
Statements of Operations	38
Statements of Changes in Net Assets	56
Notes to Financial Statements	91

Report of Independent Registered Public Accounting Firm

The Board of Directors and Contract Owners

of Separate Account VA C

Transamerica Life Insurance Company

We have audited the accompanying statements of assets and liabilities of the subaccounts of Transamerica Life Insurance Company Separate Account VA C (the Separate Account) (comprised of the Transamerica Asset Allocation – Growth VP, Transamerica Asset Allocation – Conservative VP, Transamerica Asset Allocation – Moderate VP, Transamerica Asset Allocation – Moderate Growth VP, Transamerica MFS International Equity VP, Transamerica Clarion Global Real Estate Securities VP, Transamerica Small/Mid Cap Value VP, Transamerica Balanced VP, Transamerica Diversified Equity VP, Transamerica Jennison Growth VP, Transamerica JPMorgan Enhanced Index VP, Transamerica AEGON High Yield Bond VP, Transamerica BlackRock Large Cap Value VP, Transamercia PIMCO Total Return VP, Transamerica Focus VP, Transamerica AllianceBernstein Dynamic Allocation VP, Transamerica WMC Diversified Growth VP, Transamerica Growth Opportunities VP, Transamerica U.S. Government Securities VP, Transamerica U.S. Government Securities VP PAM SC, Transamerica Money Market VP, Transamerica T. Rowe Price Small Cap VP, Transamerica Morgan Stanley Active International Allocation VP, Transamerica Multi Managed Large Cap Core VP, Transamerica Morgan Stanley Mid-Cap Growth VP, Transamerica International Moderate Growth VP SC, Transamerica Efficient Markets VP SC, Transamerica Index 50 VP SC, Transamerica Index 75 VP SC, Transamerica BlackRock Global Allocation VP SC, Transamerica BlackRock Tactical Allocation VP SC, Transamerica ProFunds UltraBear Fund VP OAM SC, Transamerica Foxhall Global Growth VP SC, Transamerica Foxhall Global Conservative VP SC, Transamerica Foxhall Global Hard Asset VP SC, Transamerica Foxhall Emerging Markets/Pacific Rim VP SC, Transamerica Hanlon Growth VP SC, Transamerica Hanlon Growth and Income VP SC, Transamerica Hanlon Balanced VP SC, Transamerica Hanlon Managed Income VP SC, Transamerica Index 35 VP SC, Transamerica Index 100 VP SC, Transamerica JP Morgan Midcap Value VP SC, Invesco V.I. Basic Value, Invesco V.I. Capital Appreciation, AllianceBernstein Growth and Income, AllianceBernstein Large Cap Growth, AllianceBernstein Balanced Wealth Strategy, Janus Aspen – Enterprise, Janus Aspen – Perkins Mid Cap Value, Janus Aspen – Worldwide, MFS^® New Discovery, MFS^® Total Return, Fidelity VIP Contrafund, Fidelity VIP Equity – Income, Fidelity VIP Growth, Fidelity VIP Growth Opportunities, Fidelity VIP Mid Cap, Fidelity VIP Value Strategies, Fidelity VIP Balanced, Franklin Income Securities, Mutual Shares Securities, Templeton Foreign Securities, Franklin Templeton VIP Founding Funds Allocation, American Funds – Asset Allocation Fund, American Funds – Bond Fund, American Funds – Growth Fund, American Funds – Growth – Income Fund, American Funds – International Fund, and GE Investments Total Return Fund subaccounts) at December 31, 2010, and the related statements of operations and changes in net assets for the periods indicated thereon. These financial statements are the responsibility of the Separate Account’s management. Our responsibility is to express an opinion on these financial statements based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. We were not engaged to perform an audit of the Separate Account’s internal control over financial reporting. Our audits included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Separate Account’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. Our procedures included confirmation of securities owned as of December 31, 2010 by correspondence with the mutual funds’ transfer agents. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of each of the respective subaccounts comprising Transamerica Life Insurance Company Separate Account VA C, at December 31, 2010, and the results of their operations for the year then ended and changes in their net assets for the periods indicated thereon, in conformity with U.S. generally accepted accounting principles

/s/ Ernst & Young LLP

Des Moines, Iowa

April 28, 2011

1

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Asset Allocation-Growth VP Subaccount		Transamerica Asset Allocation- Conservative VP Subaccount		Transamerica Asset Allocation-Moderate VP Subaccount		Transamerica Asset Allocation-Moderate Growth VP Subaccount
Assets
Investment in securities:
Number of shares - Initial		10,487,294.781		9,279,051.616		15,790,418.899		15,860,051.252
Cost	$	105,581,243	$	90,836,971	$	171,893,296	$	182,529,549
Number of shares - Service		847,952.950		4,054,188.902		7,372,281.023		13,583,083.399
Cost	$	6,454,727	$	37,337,018	$	73,932,097	$	146,044,351
Investments in mutual funds, Level 1 quoted prices at net asset value	$	98,565,778	$	136,874,710	$	241,460,431	$	310,014,225
Receivable for units sold		21		—		162		—
Total assets		98,565,799		136,874,710		241,460,593		310,014,225
Liabilities
Payable for units redeemed		—		22		—		103
	$	98,565,799	$	136,874,688	$	241,460,593	$	310,014,122
Net Assets:
Deferred annuity contracts terminable by owners	$	98,565,799	$	136,874,688	$	241,460,593	$	310,014,122
Total net assets	$	98,565,799	$	136,874,688	$	241,460,593	$	310,014,122

2

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Asset Allocation-Growth VP Subaccount		Transamerica Asset Allocation- Conservative VP Subaccount		Transamerica Asset Allocation-Moderate VP Subaccount		Transamerica Asset Allocation-Moderate Growth VP Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		4,261,574		2,275,558		3,850,645		4,929,987
M&E - 1.65%		—		—		—		—
M&E - 1.75%		28,907,661		24,822,179		38,621,982		37,451,009
M&E - 1.85%		—		—		—		—
M&E - 2.00%		36,880,997		42,802,258		76,853,028		80,845,080
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.338317	$	1.406840	$	1.425170	$	1.403599
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.315702	$	1.383020	$	1.401048	$	1.379816
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.287988	$	1.353913	$	1.371591	$	1.350781
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		2,261,206		20,268,977		35,787,581		57,070,908
M&E - 1.75%		2,647,362		7,825,504		17,802,003		34,348,067
M&E - 1.85%		1,079,112		6,600,089		9,938,901		29,868,289
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		1,894,026		2,164,609		2,049,110
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	0.959330	$	1.046260	$	1.031459	$	0.998859
M&E - 1.75%	$	1.559221	$	1.453716	$	1.525314	$	1.558693
M&E - 1.85%	$	0.953791	$	1.040246	$	1.025500	$	0.993104
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	1.026829	$	1.012278	$	0.980279

See accompanying notes.

3

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica MFS International Equity VP Subaccount		Transamerica Clarion Global Real Estate Securities VP Subaccount		Transamerica Small/Mid Cap Value VP Subaccount		Transamerica Balanced VP Subaccount
Assets
Investment in securities:
Number of shares - Initial		2,036,817.562		1,048,623.224		1,134,625.122		614,263.975
Cost	$	13,932,718	$	12,904,037	$	18,563,594	$	6,820,043
Number of shares - Service		182,065.214		149,330.982		140,189.872		504,715.164
Cost	$	1,113,310	$	1,596,784	$	2,394,132	$	5,191,647
Investments in mutual funds, Level 1 quoted prices at net asset value	$	15,537,982	$	13,599,601	$	26,577,351	$	14,133,137
Receivable for units sold		—		—		—		3
Total assets		15,537,982		13,599,601		26,577,351		14,133,140
Liabilities
Payable for units redeemed		13		339		525		—
	$	15,537,969	$	13,599,262	$	26,576,826	$	14,133,140
Net Assets:
Deferred annuity contracts terminable by owners	$	15,537,969	$	13,599,262	$	26,576,826	$	14,133,140
Total net assets	$	15,537,969	$	13,599,262	$	26,576,826	$	14,133,140

4

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica MFS International Equity VP Subaccount		Transamerica Clarion Global Real Estate Securities VP Subaccount		Transamerica Small/Mid Cap Value VP Subaccount		Transamerica Balanced VP Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		1,089,757		507,387		2,211,774		255,604
M&E - 1.65%		—		—		—		—
M&E - 1.75%		5,188,191		2,595,273		5,547,476		2,395,890
M&E - 1.85%		—		—		—		—
M&E - 2.00%		5,109,447		3,026,477		660,023		2,714,402
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.164590	$	1.984355	$	2.111477	$	1.491197
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.142585	$	1.950760	$	3.167660	$	1.465974
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.385867	$	1.909650	$	2.176398	$	1.435086
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		633,008		971,650		1,739,598		3,460,805
M&E - 1.75%		115,478		181,129		53,984		379,183
M&E - 1.85%		414,814		518,544		649,379		1,673,394
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		78,691
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	1.007030	$	0.938309	$	1.188049	$	1.109926
M&E - 1.75%	$	1.793558	$	1.958315	$	1.184614	$	1.505101
M&E - 1.85%	$	1.001197	$	0.932888	$	1.181205	$	1.103510
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	1.089299

See accompanying notes.

5

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Diversified Equity VP Subaccount		Transamerica Jennison Growth VP Subaccount		Transamerica JPMorgan Enhanced Index VP Subaccount		Transamerica AEGON High Yield Bond VP Subaccount
Assets
Investment in securities:
Number of shares - Initial		1,131,194.319		2,983,666.201		865,682.810		3,489,506.027
Cost	$	17,377,326	$	21,710,799	$	9,757,448	$	25,709,214
Number of shares - Service		123,626.098		333,037.225		38,732.015		312,335.776
Cost	$	2,170,708	$	2,384,258	$	394,037	$	2,396,274
Investments in mutual funds, Level 1 quoted prices at net asset value	$	25,337,668	$	26,161,993	$	10,637,080	$	29,188,237
Receivable for units sold		—		—		11		—
Total assets		25,337,668		26,161,993		10,637,091		29,188,237
Liabilities
Payable for units redeemed		333		653		—		321
	$	25,337,335	$	26,161,340	$	10,637,091	$	29,187,916
Net Assets:
Deferred annuity contracts terminable by owners	$	25,337,335	$	26,161,340	$	10,637,091	$	29,187,916
Total net assets	$	25,337,335	$	26,161,340	$	10,637,091	$	29,187,916

6

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Diversified Equity VP Subaccount		Transamerica Jennison Growth VP Subaccount		Transamerica JPMorgan Enhanced Index VP Subaccount		Transamerica AEGON High Yield Bond VP Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		1,785,803		2,042,903		893,334		1,910,701
M&E - 1.65%		—		—		—		—
M&E - 1.75%		14,845,521		14,376,509		6,066,892		7,168,633
M&E - 1.85%		—		—		—		—
M&E - 2.00%		8,595,330		9,351,684		3,685,957		8,269,958
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.083730	$	0.952491	$	0.983426	$	1.601420
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	0.709488	$	0.749376	$	0.841574	$	1.520750
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.209151	$	1.160332	$	1.138419	$	1.548092
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		1,495,717		1,112,736		74,420		1,095,581
M&E - 1.75%		442,916		454,211		146,044		309,782
M&E - 1.85%		663,061		692,332		185,693		543,100
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	0.904041	$	1.067109	$	0.992292	$	1.202779
M&E - 1.75%	$	1.192268	$	1.473083	$	1.366794	$	1.473647
M&E - 1.85%	$	0.898819	$	1.060942	$	0.986582	$	1.195869
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—

See accompanying notes.

7

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica BlackRock Large Cap Value VP Subaccount		Transamerica PIMCO Total Return VP Subaccount		Transamerica  Focus VP Subaccount		Transamerica AllianceBernstein Dynamic Allocation VP Subaccount
Assets
Investment in securities:
Number of shares - Initial		5,482,440.485		6,015,279.765		2,019,667.565		897,691.000
Cost	$	70,215,944	$	68,265,965	$	24,950,918	$	6,558,739
Number of shares - Service		341,660.046		1,768,599.486		39,578.730		222,015.351
Cost	$	4,376,620	$	20,445,397	$	409,084	$	1,751,726
Investments in mutual funds, Level 1 quoted prices at net asset value	$	79,512,639	$	90,066,578	$	24,112,982	$	9,076,378
Receivable for units sold		3		31		—		—
Total assets		79,512,642		90,066,609		24,112,982		9,076,378
Liabilities
Payable for units redeemed		—		—		557		3
	$	79,512,642	$	90,066,609	$	24,112,425	$	9,076,375
Net Assets:
Deferred annuity contracts terminable by owners	$	79,512,642	$	90,066,609	$	24,112,425	$	9,076,375
Total net assets	$	79,512,642	$	90,066,609	$	24,112,425	$	9,076,375

8

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica BlackRock Large Cap Value VP Subaccount		Transamerica PIMCO Total Return VP Subaccount		Transamerica  Focus VP Subaccount		Transamerica AllianceBernstein Dynamic Allocation VP Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		6,618,554		2,606,768		2,740,881		195,339
M&E - 1.65%		—		—		—		—
M&E - 1.75%		23,000,972		17,615,337		8,267,479		1,892,653
M&E - 1.85%		—		—		—		—
M&E - 2.00%		25,235,067		29,873,299		6,505,098		3,216,648
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.277119	$	1.431103	$	1.180595	$	1.413194
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.517740	$	1.406874	$	1.489067	$	1.389283
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.247199	$	1.377279	$	1.245646	$	1.360047
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		2,412,135		8,930,041		91,068		857,226
M&E - 1.75%		735,737		1,620,262		64,844		347,953
M&E - 1.85%		1,608,893		5,945,298		244,460		520,498
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		1,808,308		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	0.885726	$	1.102698	$	1.081284	$	0.949802
M&E - 1.75%	$	1.527736	$	1.288298	$	1.563699	$	1.409354
M&E - 1.85%	$	0.880613	$	1.096349	$	1.075052	$	0.944319
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	1.082220	$	—	$	—

See accompanying notes.

9

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica WMC Diversified Growth VP Subaccount		Transamerica Growth Opportunities VP Subaccount		Transamerica U.S. Government Securities VP Subaccount		Transamerica U.S. Government Securities VP PAM SC Subaccount
Assets
Investment in securities:
Number of shares - Initial		1,487,021.433		1,048,979.496		2,541,482.614		—
Cost	$	35,399,641	$	13,979,040	$	31,782,274	$	—
Number of shares - Service		70,104.971		77,598.719		874,786.100		378,826.506
Cost	$	1,344,240	$	871,553	$	11,691,134	$	4,982,355
Investments in mutual funds, Level 1 quoted prices at net asset value	$	34,956,935	$	16,116,304	$	43,758,627	$	4,917,168
Receivable for units sold		18		—		26		—
Total assets		34,956,953		16,116,304		43,758,653		4,917,168
Liabilities
Payable for units redeemed		—		533		—		6
	$	34,956,953	$	16,115,771	$	43,758,653	$	4,917,162
Net Assets:
Deferred annuity contracts terminable by owners	$	34,956,953	$	16,115,771	$	43,758,653	$	4,917,162
Total net assets	$	34,956,953	$	16,115,771	$	43,758,653	$	4,917,162

10

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica WMC Diversified Growth VP Subaccount		Transamerica Growth Opportunities VP Subaccount		Transamerica U.S. Government Securities VP Subaccount		Transamerica U.S. Government Securities VP PAM SC Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		3,715,646		375,931		2,023,066		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		18,593,720		3,599,865		10,439,393		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		8,089,356		4,044,606		12,275,382		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.084767	$	2.084095	$	1.306783	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.006288	$	2.044778	$	1.394365	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.317444	$	1.700156	$	1.238568	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		33,874
M&E - 1.65%		958,888		552,443		7,655,932		126,322
M&E - 1.75%		364,925		123,195		748,188		4,029,530
M&E - 1.85%		185,433		153,503		1,891,712		3,032
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		112,034		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	1.210634
M&E - 1.65%	$	0.892217	$	1.186968	$	1.085909	$	1.085909
M&E - 1.75%	$	1.475398	$	2.094467	$	1.175250	$	1.175250
M&E - 1.85%	$	0.887043	$	1.180107	$	1.079643	$	1.079643
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	1.065731	$	—

See accompanying notes.

11

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Money Market VP Subaccount		Transamerica T. Rowe Price Small Cap VP Subaccount		Transamerica Morgan Stanley Active International Allocation VP Subaccount		Transamerica Multi Managed Large Cap Core VP Subaccount
Assets
Investment in securities:
Number of shares - Initial		41,062,419.140		2,019,738.325		1,152,541.723		1,649,208.963
Cost	$	41,062,419	$	16,815,266	$	13,508,533	$	17,737,147
Number of shares - Service		14,795,804.780		261,363.316		93,759.456		64,666.915
Cost	$	14,795,805	$	1,924,513	$	974,085	$	801,921
Investments in mutual funds, Level 1 quoted prices at net asset value	$	55,858,224	$	21,504,138	$	14,290,387	$	26,616,814
Receivable for units sold		80		—		6		—
Total assets		55,858,304		21,504,138		14,290,393		26,616,814
Liabilities
Payable for units redeemed		—		329		—		355
	$	55,858,304	$	21,503,809	$	14,290,393	$	26,616,459
Net Assets:
Deferred annuity contracts terminable by owners	$	55,858,304	$	21,503,809	$	14,290,393	$	26,616,459
Total net assets	$	55,858,304	$	21,503,809	$	14,290,393	$	26,616,459

12

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Money Market VP Subaccount		Transamerica T. Rowe Price Small Cap VP Subaccount		Transamerica Morgan Stanley Active International Allocation VP Subaccount		Transamerica Multi Managed Large Cap Core VP Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		1,798,431		887,604		714,746		2,123,023
M&E - 1.65%		—		—		—		—
M&E - 1.75%		11,225,955		6,818,061		5,617,016		11,740,561
M&E - 1.85%		—		—		—		—
M&E - 2.00%		26,902,047		6,418,796		4,675,101		7,148,237
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.050789	$	1.395945	$	1.252794	$	1.266819
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.087410	$	1.241340	$	0.975533	$	1.134103
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.002357	$	1.461897	$	1.464064	$	1.341712
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		4,583,578		944,657		425,795		274,330
M&E - 1.75%		5,885,153		298,993		295,010		293,541
M&E - 1.85%		4,509,260		497,671		180,533		272,951
M&E - 2.00%		—		—		—		—
M&E - 2.30%		11,890		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	0.971427	$	1.283366	$	0.893198	$	1.067975
M&E - 1.75%	$	1.015571	$	1.907215	$	1.796851	$	1.493130
M&E - 1.85%	$	0.965818	$	1.275993	$	0.888053	$	1.061798
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	0.953394	$	—	$	—	$	—

See accompanying notes.

13

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Morgan Stanley Mid-Cap Growth VP Subaccount		Transamerica International Moderate Growth VP SC Subaccount		Transamerica Efficient Markets VP SC Subaccount		Transamerica Index 50 VP SC Subaccount
Assets
Investment in securities:
Number of shares - Initial		416,468.237		—		—		—
Cost	$	9,413,843	$	—	$	—	$	—
Number of shares - Service		62,726.082		3,128,413.237		222,839.996		523,954.094
Cost	$	1,441,038	$	27,478,769	$	2,612,375	$	5,046,472
Investments in mutual funds, Level 1 quoted prices at net asset value	$	13,955,291	$	28,343,424	$	2,992,741	$	5,449,123
Receivable for units sold		16		—		1		—
Total assets		13,955,307		28,343,424		2,992,742		5,449,123
Liabilities
Payable for units redeemed		—		12		—		8
	$	13,955,307	$	28,343,412	$	2,992,742	$	5,449,115
Net Assets:
Deferred annuity contracts terminable by owners	$	13,955,307	$	28,343,412	$	2,992,742	$	5,449,115
Total net assets	$	13,955,307	$	28,343,412	$	2,992,742	$	5,449,115

14

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Morgan Stanley Mid-Cap Growth VP Subaccount		Transamerica International Moderate Growth VP SC Subaccount		Transamerica Efficient Markets VP SC Subaccount		Transamerica Index 50 VP SC Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		850,566		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		4,753,047		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		4,396,951		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	1.077792	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	1.057448	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	1.412280	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		188,523		—		—
M&E - 1.65%		1,012,268		12,033,169		1,277,033		2,795,250
M&E - 1.75%		128,809		8,852,792		90,697		58,199
M&E - 1.85%		225,045		6,703,389		869,133		1,712,295
M&E - 2.00%		—		1,206,271		—		112,918
M&E - 2.30%		—		1,023,140		19,459		677,849
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	0.954359	$	—	$	1.085798
M&E - 1.65%	$	1.265509	$	0.947340	$	1.328803	$	1.019934
M&E - 1.75%	$	1.852067	$	0.945602	$	1.326002	$	1.017230
M&E - 1.85%	$	1.258194	$	0.941890	$	1.323210	$	1.014580
M&E - 2.00%	$	—	$	0.934834	$	—	$	1.080446
M&E - 2.30%	$	—	$	0.929740	$	1.310801	$	1.002699

See accompanying notes.

15

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Index 75 VP SC Subaccount		Transamerica BlackRock Global Allocation VP SC Subaccount		Transamerica BlackRock Tactical Allocation VP SC Subaccount		Transamerica ProFunds UltraBear Fund VP OAM SC Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		1,570,802.543		2,467,296.601		980,563.807		40,694.349
Cost	$	13,285,876	$	30,226,110	$	12,365,542	$	201,864
Investments in mutual funds, Level 1 quoted prices at net asset value	$	15,535,237	$	32,790,372	$	13,208,194	$	169,288
Receivable for units sold		9		6		—		1
Total assets		15,535,246		32,790,378		13,208,194		169,289
Liabilities
Payable for units redeemed		—		—		6		—
	$	15,535,246	$	32,790,378	$	13,208,188	$	169,289
Net Assets:
Deferred annuity contracts terminable by owners	$	15,535,246	$	32,790,378	$	13,208,188	$	169,289
Total net assets	$	15,535,246	$	32,790,378	$	13,208,188	$	169,289

16

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Index 75 VP SC Subaccount		Transamerica BlackRock Global Allocation VP SC Subaccount		Transamerica BlackRock Tactical Allocation VP SC Subaccount		Transamerica ProFunds UltraBear Fund VP OAM SC Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		239,562		—
M&E - 1.65%		9,362,116		16,341,040		3,963,822		303,047
M&E - 1.75%		41,424		681,223		1,712,528		—
M&E - 1.85%		6,081,791		8,291,227		2,331,268		115,590
M&E - 2.00%		22,960		—		2,187,750		—
M&E - 2.30%		522,204		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	1.112020	$	—	$	1.098884	$	—
M&E - 1.65%	$	0.971384	$	1.296818	$	1.319555	$	0.404748
M&E - 1.75%	$	0.968815	$	1.294690	$	1.317394	$	0.404078
M&E - 1.85%	$	0.966294	$	1.292577	$	1.315228	$	0.403424
M&E - 2.00%	$	1.106552	$	—	$	1.093467	$	—
M&E - 2.30%	$	0.954989	$	—	$	—	$	—

See accompanying notes.

17

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Foxhall Global Growth VP SC Subaccount		Transamerica Foxhall Global Conservative VP SC Subaccount		Transamerica Foxhall Global Hard Asset VP SC Subaccount		Transamerica  Foxhall Emerging Markets/Pacific Rim VP SC Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		220,707.632		221,531.798		295,242.368		337,183.845
Cost	$	2,366,784	$	2,145,607	$	2,940,322	$	3,563,996
Investments in mutual funds, Level 1 quoted prices at net asset value	$	2,538,138	$	2,093,475	$	3,129,569	$	3,773,087
Receivable for units sold		—		5		1		4
Total assets		2,538,138		2,093,480		3,129,570		3,773,091
Liabilities
Payable for units redeemed		1		—		—		—
	$	2,538,137	$	2,093,480	$	3,129,570	$	3,773,091
Net Assets:
Deferred annuity contracts terminable by owners	$	2,538,137	$	2,093,480	$	3,129,570	$	3,773,091
Total net assets	$	2,538,137	$	2,093,480	$	3,129,570	$	3,773,091

18

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica  Foxhall Global Growth VP SC Subaccount		Transamerica Foxhall Global Conservative VP SC Subaccount		Transamerica Foxhall Global Hard Asset VP SC Subaccount		Transamerica  Foxhall Emerging Markets/Pacific Rim VP SC Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		2,018,228		1,390,492		2,216,793		2,766,088
M&E - 1.75%		—		31,447		176,790		56,546
M&E - 1.85%		415,463		884,336		738,582		855,735
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	1.043306	$	0.908509	$	0.999750	$	1.026295
M&E - 1.75%	$	1.042154	$	0.907511	$	0.998657	$	1.025165
M&E - 1.85%	$	1.041027	$	0.906518	$	0.997558	$	1.024031
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	0.902049	$	—	$	—

See accompanying notes.

19

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Hanlon Growth VP SC Subaccount		Transamerica Hanlon Growth and Income VP SC Subaccount		Transamerica Hanlon Balanced VP SC Subaccount		Transamerica Hanlon Managed Income VP SC Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		246,738.832		198,161.472		223,727.116		1,628,472.705
Cost	$	2,693,466	$	2,135,937	$	2,403,236	$	18,067,752
Investments in mutual funds, Level 1 quoted prices at net asset value	$	2,773,344	$	2,193,647	$	2,445,337	$	17,978,339
Receivable for units sold		—		—		—		16
Total assets		2,773,344		2,193,647		2,445,337		17,978,355
Liabilities
Payable for units redeemed		6		1		9		—
	$	2,773,338	$	2,193,646	$	2,445,328	$	17,978,355
Net Assets:
Deferred annuity contracts terminable by owners	$	2,773,338	$	2,193,646	$	2,445,328	$	17,978,355
Total net assets	$	2,773,338	$	2,193,646	$	2,445,328	$	17,978,355

20

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Hanlon Growth VP SC Subaccount		Transamerica Hanlon Growth and Income VP SC Subaccount		Transamerica Hanlon Balanced VP SC Subaccount		Transamerica Hanlon Managed Income VP SC Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		2,272,210		1,834,828		2,108,416		14,885,608
M&E - 1.75%		55,581		—		35,860		62,004
M&E - 1.85%		453,538		394,520		379,689		3,249,499
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	0.997506	$	0.984370	$	0.969182	$	0.988365
M&E - 1.75%	$	0.996415	$	0.983287	$	0.968114	$	0.987297
M&E - 1.85%	$	0.995312	$	0.982197	$	0.967038	$	0.986221
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—

See accompanying notes.

21

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Index 35 VP SC Subaccount		Transamerica Index 100 VP SC Subaccount		Transamerica JP Morgan Midcap Value VP SC Subaccount		Invesco V.I. Basic Value Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		210,468.388		100,753.498		134,479.762		1,130,319.407
Cost	$	2,201,082	$	1,093,582	$	1,603,010	$	7,287,167
Investments in mutual funds, Level 1 quoted prices at net asset value	$	2,302,524	$	1,181,839	$	1,804,718	$	7,166,225
Receivable for units sold		—		—		—		—
Total assets		2,302,524		1,181,839		1,804,718		7,166,225
Liabilities
Payable for units redeemed		6		—		6		492
	$	2,302,518	$	1,181,839	$	1,804,712	$	7,165,733
Net Assets:
Deferred annuity contracts terminable by owners	$	2,302,518	$	1,181,839	$	1,804,712	$	7,165,733
Total net assets	$	2,302,518	$	1,181,839	$	1,804,712	$	7,165,733

22

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Transamerica Index 35 VP SC Subaccount		Transamerica Index 100 VP SC Subaccount		Transamerica JP Morgan Midcap Value VP SC Subaccount		Invesco V.I. Basic Value Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		11,517		13,580		125,466		279,233
M&E - 1.65%		1,600,059		415,424		247,805		482,100
M&E - 1.75%		1,143		84,338		406,981		2,951,974
M&E - 1.85%		509,730		139,129		136,282		83,615
M&E - 2.00%		16,110		374,764		536,991		4,373,966
M&E - 2.30%		5,707		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	1.075590	$	1.153818	$	1.245265	$	0.907557
M&E - 1.65%	$	1.074408	$	1.152543	$	1.243896	$	0.810903
M&E - 1.75%	$	1.073221	$	1.151278	$	1.242520	$	0.892202
M&E - 1.85%	$	1.072050	$	1.150020	$	1.241163	$	0.806245
M&E - 2.00%	$	1.070290	$	1.148129	$	1.239127	$	0.873396
M&E - 2.30%	$	1.066785	$	—	$	—	$	—

See accompanying notes.

23

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Invesco V.I. Capital Appreciation Subaccount		AllianceBernstein Growth and Income Subaccount		AllianceBernstein Large Cap Growth Subaccount		AllianceBernstein Balanced Wealth Strategy Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		106,935.207		728,011.383		230,659.433		303,642.623
Cost	$	2,454,225	$	15,460,062	$	5,754,677	$	3,015,729
Investments in mutual funds, Level 1 quoted prices at net asset value	$	2,450,955	$	12,383,474	$	6,246,257	$	3,455,453
Receivable for units sold		2		—		—		3
Total assets		2,450,957		12,383,474		6,246,257		3,455,456
Liabilities
Payable for units redeemed		—		48		342		—
	$	2,450,957	$	12,383,426	$	6,245,915	$	3,455,456
Net Assets:
Deferred annuity contracts terminable by owners	$	2,450,957	$	12,383,426	$	6,245,915	$	3,455,456
Total net assets	$	2,450,957	$	12,383,426	$	6,245,915	$	3,455,456

24

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Invesco V.I. Capital Appreciation Subaccount		AllianceBernstein Growth and Income Subaccount		AllianceBernstein Large Cap Growth Subaccount		AllianceBernstein Balanced Wealth Strategy Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		5,386		1,685,483		954,315		—
M&E - 1.65%		748,444		888,775		821,098		982,285
M&E - 1.75%		576,335		5,431,905		3,042,051		17,628
M&E - 1.85%		146,272		140,586		115,178		1,312,313
M&E - 2.00%		1,155,095		4,753,075		2,043,479		—
M&E - 2.30%		—		—		—		275,391
Accumulation unit value - Service:
M&E - 1.55%	$	0.988477	$	0.950792	$	0.807891	$	—
M&E - 1.65%	$	0.880190	$	0.854090	$	0.992081	$	1.340179
M&E - 1.75%	$	0.971761	$	0.932852	$	0.792670	$	1.337375
M&E - 1.85%	$	0.875122	$	0.849153	$	0.986356	$	1.334562
M&E - 2.00%	$	0.951258	$	1.017288	$	1.044976	$	—
M&E - 2.30%	$	—	$	—	$	—	$	1.322043

See accompanying notes.

25

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Janus Aspen - Enterprise Subaccount		Janus Aspen - Perkins Mid Cap Value Subaccount		Janus Aspen - Worldwide Subaccount		MFS® New  Discovery Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		187,438.551		68,856.696		423,865.726		570,348.925
Cost	$	5,816,750	$	1,011,774	$	12,207,583	$	7,415,419
Investments in mutual funds, Level 1 quoted prices at net asset value	$	7,034,569	$	1,083,804	$	12,631,199	$	10,117,990
Receivable for units sold		—		4		—		—
Total assets		7,034,569		1,083,808		12,631,199		10,117,990
Liabilities
Payable for units redeemed		1		—		513		875
	$	7,034,568	$	1,083,808	$	12,630,686	$	10,117,115
Net Assets:
Deferred annuity contracts terminable by owners	$	7,034,568	$	1,083,808	$	12,630,686	$	10,117,115
Total net assets	$	7,034,568	$	1,083,808	$	12,630,686	$	10,117,115

26

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Janus Aspen - Enterprise Subaccount		Janus Aspen - Perkins Mid Cap Value Subaccount		Janus Aspen - Worldwide Subaccount		MFS® New  Discovery Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		469,107		253,723		1,110,312		186,530
M&E - 1.65%		438,198		—		813,293		757,275
M&E - 1.75%		4,904,696		477,872		6,679,198		2,347,306
M&E - 1.85%		261,143		—		430,614		436,572
M&E - 2.00%		1,333,174		—		5,978,119		3,129,767
M&E - 2.30%		—		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	1.228503	$	1.505480	$	0.833299	$	1.519723
M&E - 1.65%	$	1.115844	$	—	$	0.944924	$	1.468263
M&E - 1.75%	$	0.687794	$	1.468664	$	0.661071	$	1.494005
M&E - 1.85%	$	1.109404	$	—	$	0.939457	$	1.459792
M&E - 2.00%	$	1.729838	$	—	$	1.023231	$	1.462592
M&E - 2.30%	$	—	$	—	$	—	$	—

See accompanying notes.

27

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	MFS® Total  Return Subaccount		Fidelity VIP Contrafund Subaccount		Fidelity VIP Equity- Income Subaccount		Fidelity VIP Growth Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		814,010.901		1,679,271.550		683,599.771		210,991.306
Cost	$	15,214,632	$	43,903,958	$	14,943,272	$	7,746,832
Investments in mutual funds, Level 1 quoted prices at net asset value	$	15,042,921	$	39,446,089	$	12,817,496	$	7,747,601
Receivable for units sold		—		—		—		—
Total assets		15,042,921		39,446,089		12,817,496		7,747,601
Liabilities
Payable for units redeemed		335		262		5		4
	$	15,042,586	$	39,445,827	$	12,817,491	$	7,747,597
Net Assets:
Deferred annuity contracts terminable by owners	$	15,042,586	$	39,445,827	$	12,817,491	$	7,747,597
Total net assets	$	15,042,586	$	39,445,827	$	12,817,491	$	7,747,597

28

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	MFS® Total  Return Subaccount		Fidelity VIP Contrafund Subaccount		Fidelity VIP Equity- Income Subaccount		Fidelity VIP Growth Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		559,736		1,755,002		1,428,547		743,577
M&E - 1.65%		1,040,140		1,504,501		225,590		249,153
M&E - 1.75%		4,765,880		13,002,185		6,164,274		4,368,910
M&E - 1.85%		284,564		1,414,275		300,166		169,942
M&E - 2.00%		5,977,777		11,771,666		3,487,245		2,978,738
M&E - 2.30%		—		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	1.246334	$	1.520198	$	1.068581	$	0.855314
M&E - 1.65%	$	1.009566	$	0.983643	$	0.919991	$	0.911651
M&E - 1.75%	$	1.225231	$	1.250872	$	1.130196	$	0.839200
M&E - 1.85%	$	1.003730	$	0.977967	$	0.914681	$	0.906359
M&E - 2.00%	$	1.199434	$	1.499431	$	1.101740	$	1.028639
M&E - 2.30%	$	—	$	—	$	—	$	—

See accompanying notes.

29

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Fidelity VIP Growth Opportunities Subaccount		Fidelity VIP Mid Cap Subaccount		Fidelity VIP Value Strategies Subaccount		Fidelity VIP Balanced Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		26,049.443		1,621,394.058		1,549,955.071		208,513.348
Cost	$	351,131	$	47,880,388	$	14,043,503	$	2,773,570
Investments in mutual funds, Level 1 quoted prices at net asset value	$	463,159	$	52,095,391	$	15,174,060	$	3,188,169
Receivable for units sold		—		—		—		—
Total assets		463,159		52,095,391		15,174,060		3,188,169
Liabilities
Payable for units redeemed		8		665		339		3
	$	463,151	$	52,094,726	$	15,173,721	$	3,188,166
Net Assets:
Deferred annuity contracts terminable by owners	$	463,151	$	52,094,726	$	15,173,721	$	3,188,166
Total net assets	$	463,151	$	52,094,726	$	15,173,721	$	3,188,166

30

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Fidelity VIP Growth Opportunities Subaccount		Fidelity VIP Mid Cap Subaccount		Fidelity VIP Value Strategies Subaccount		Fidelity VIP Balanced Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		98,186		1,737,072		499,068		—
M&E - 1.65%		—		1,365,640		796,985		2,051,668
M&E - 1.75%		496,600		10,547,150		3,854,988		—
M&E - 1.85%		—		766,162		184,022		847,915
M&E - 2.00%		—		10,125,181		5,764,469		—
M&E - 2.30%		—		—		—		148,853
Accumulation unit value - Service:
M&E - 1.55%	$	0.968615	$	2.302437	$	1.435540	$	—
M&E - 1.65%	$	—	$	1.168241	$	1.075026	$	1.048229
M&E - 1.75%	$	0.741133	$	2.321966	$	1.411244	$	1.045475
M&E - 1.85%	$	—	$	1.161485	$	1.068798	$	1.042736
M&E - 2.00%	$	—	$	2.085871	$	1.381480	$	—
M&E - 2.30%	$	—	$	—	$	—	$	1.030532

See accompanying notes.

31

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Franklin Income Securities Subaccount		Mutual Shares Securities Subaccount		Templeton Foreign Securities Subaccount		Franklin Templeton VIP Founding Funds Allocation Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		745,811.521		214,714.891		626,103.536		885,168.984
Cost	$	9,835,495	$	2,915,497	$	8,258,787	$	6,088,900
Investments in mutual funds, Level 1 quoted prices at net asset value	$	11,052,927	$	3,424,703	$	8,947,020	$	6,824,653
Receivable for units sold		6		—		3		4
Total assets		11,052,933		3,424,703		8,947,023		6,824,657
Liabilities
Payable for units redeemed		—		4		—		—
	$	11,052,933	$	3,424,699	$	8,947,023	$	6,824,657
Net Assets:
Deferred annuity contracts terminable by owners	$	11,052,933	$	3,424,699	$	8,947,023	$	6,824,657
Total net assets	$	11,052,933	$	3,424,699	$	8,947,023	$	6,824,657

32

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	Franklin Income Securities Subaccount		Mutual Shares Securities Subaccount		Templeton Foreign Securities Subaccount		Franklin Templeton VIP Founding Funds Allocation Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		882,332		214,529		305,296		—
M&E - 1.65%		940,961		614,044		1,159,391		2,989,385
M&E - 1.75%		4,647,796		1,171,585		2,880,350		129,351
M&E - 1.85%		739,031		148,462		909,801		1,640,817
M&E - 2.00%		3,858,354		2,008,268		4,647,409		—
M&E - 2.30%		—		—		—		232,607
Accumulation unit value - Service:
M&E - 1.55%	$	0.994830	$	0.810942	$	0.903305	$	—
M&E - 1.65%	$	1.079026	$	0.925781	$	0.948576	$	1.369903
M&E - 1.75%	$	0.987666	$	0.805114	$	0.896796	$	1.367020
M&E - 1.85%	$	1.072808	$	0.920438	$	0.943095	$	1.364151
M&E - 2.00%	$	0.978794	$	0.797876	$	0.888745	$	—
M&E - 2.30%	$	—	$	—	$	—	$	1.351386

See accompanying notes.

33

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	American Funds – Asset Allocation Fund Subaccount		American Funds – Bond Fund Subaccount		American Funds – Growth Fund Subaccount		American Funds – Growth – Income Fund Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—		—		—
Cost	$	—	$	—	$	—	$	—
Number of shares - Service		165,008.130		236,979.399		32,608.648		26,916.423
Cost	$	2,537,998	$	2,555,145	$	1,569,258	$	846,523
Investments in mutual funds, Level 1 quoted prices at net asset value	$	2,668,181	$	2,502,502	$	1,771,954	$	921,887
Receivable for units sold		—		—		—		1
Total assets		2,668,181		2,502,502		1,771,954		921,888
Liabilities
Payable for units redeemed		6		4		4		—
	$	2,668,175	$	2,502,498	$	1,771,950	$	921,888
Net Assets:
Deferred annuity contracts terminable by owners	$	2,668,175	$	2,502,498	$	1,771,950	$	921,888
Total net assets	$	2,668,175	$	2,502,498	$	1,771,950	$	921,888

34

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	American Funds – Asset Allocation Fund Subaccount		American Funds – Bond Fund Subaccount		American Funds – Growth Fund Subaccount		American Funds – Growth – Income Fund Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		—		—		—		—
M&E - 1.75%		—		—		—		—
M&E - 1.85%		—		—		—		—
M&E - 2.00%		—		—		—		—
M&E - 2.30%		—		—		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	—	$	—	$	—	$	—
M&E - 1.75%	$	—	$	—	$	—	$	—
M&E - 1.85%	$	—	$	—	$	—	$	—
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	—	$	—	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—		—		—
M&E - 1.65%		1,192,410		1,505,132		890,602		495,504
M&E - 1.75%		40,368		522,954		92,314		—
M&E - 1.85%		1,163,013		385,358		536,171		341,824
M&E - 2.00%		—		—		—		—
M&E - 2.30%		5,497		—		—		—
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—	$	—	$	—
M&E - 1.65%	$	1.112364	$	1.037506	$	1.167433	$	1.101971
M&E - 1.75%	$	1.111159	$	1.036375	$	1.166156	$	1.100765
M&E - 1.85%	$	1.109924	$	1.035242	$	1.164887	$	1.099564
M&E - 2.00%	$	—	$	—	$	—	$	—
M&E - 2.30%	$	1.104500	$	1.030171	$	—	$	—

See accompanying notes.

35

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	American Funds – International Fund Subaccount		GE Investments Total Return Fund Subaccount
Assets
Investment in securities:
Number of shares - Initial		—		—
Cost	$	—	$	—
Number of shares - Service		90,127.882		32,741.063
Cost	$	1,505,324	$	507,931
Investments in mutual funds, Level 1 quoted prices at net asset value	$	1,620,499	$	536,299
Receivable for units sold		—		—
Total assets		1,620,499		536,299
Liabilities
Payable for units redeemed		—		2
	$	1,620,499	$	536,297
Net Assets:
Deferred annuity contracts terminable by owners	$	1,620,499	$	536,297
Total net assets	$	1,620,499	$	536,297

36

Transamerica Life Insurance Company

Separate Account VA C

Statements of Assets and Liabilities

December 31, 2010

	American Funds – International Fund Subaccount		GE Investments Total Return Fund Subaccount
Accumulation units outstanding - Initial:
M&E - 1.55%		—		—
M&E - 1.65%		—		—
M&E - 1.75%		—		—
M&E - 1.85%		—		—
M&E - 2.00%		—		—
M&E - 2.30%		—		—
Accumulation unit value - Initial:
M&E - 1.55%	$	—	$	—
M&E - 1.65%	$	—	$	—
M&E - 1.75%	$	—	$	—
M&E - 1.85%	$	—	$	—
M&E - 2.00%	$	—	$	—
M&E - 2.30%	$	—	$	—
Accumulation units outstanding - Service:
M&E - 1.55%		—		—
M&E - 1.65%		970,606		279,431
M&E - 1.75%		181,323		23,306
M&E - 1.85%		420,687		194,418
M&E - 2.00%		—		—
M&E - 2.30%		—		937
Accumulation unit value - Service:
M&E - 1.55%	$	—	$	—
M&E - 1.65%	$	1.031180	$	1.077697
M&E - 1.75%	$	1.030054	$	1.076511
M&E - 1.85%	$	1.028927	$	1.075335
M&E - 2.00%	$	—	$	—
M&E - 2.30%	$	—	$	1.070072

See accompanying notes.

37

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Asset Allocation- Growth VP Subaccount			Transamerica Asset Allocation- Conservative VP Subaccount			Transamerica Asset Allocation- Moderate VP Subaccount			Transamerica Asset Allocation- Moderate Growth VP Subaccount
Net investment income (loss)
Income:
Dividends	$	951,494		$	4,318,045		$	6,734,643		$	6,032,532
Expenses:
Administrative, mortality and expense risk charge		1,713,856			2,441,828			4,243,806			5,189,524
Net investment income (loss)		(762,362	)		1,876,217			2,490,837			843,008
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			376,286			—			—
Proceeds from sales		18,801,920			24,200,291			37,162,296			37,227,493
Cost of investments sold		32,004,872			27,706,361			44,036,539			47,110,384
Net realized capital gains (losses) on investments		(13,202,952	)		(3,129,784	)		(6,874,243	)		(9,882,891	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(38,139,118	)		(1,560,208	)		(27,103,220	)		(56,542,219	)
End of period		(13,470,192	)		8,700,721			(4,364,962	)		(18,559,675	)
Net change in unrealized appreciation/depreciation of investments		24,668,926			10,260,929			22,738,258			37,982,544
Net realized and unrealized capital gains (losses) on investments		11,465,974			7,131,145			15,864,015			28,099,653
Increase (decrease) in net assets from operations	$	10,703,612		$	9,007,362		$	18,354,852		$	28,942,661

See accompanying notes.

38

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica MFS International Equity VP Subaccount			Transamerica Clarion Global Real Estate Securities VP Subaccount			Transamerica Small/Mid Cap Value VP Subaccount			Transamerica Balanced VP Subaccount
Net investment income (loss)
Income:
Dividends	$	207,214		$	799,774		$	163,000		$	56,198
Expenses:
Administrative, mortality and expense risk charge		283,219			228,183			393,269			203,976
Net investment income (loss)		(76,005	)		571,591			(230,269	)		(147,778	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		5,452,779			3,530,064			3,703,099			3,141,743
Cost of investments sold		8,177,231			7,611,237			1,705,609			3,131,204
Net realized capital gains (losses) on investments		(2,724,452	)		(4,081,173	)		1,997,490			10,539
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(3,347,360	)		(6,048,620	)		1,535,073			(409,135	)
End of period		491,954			(901,220	)		5,619,625			2,121,447
Net change in unrealized appreciation/depreciation of investments		3,839,314			5,147,400			4,084,552			2,530,582
Net realized and unrealized capital gains (losses) on investments		1,114,862			1,066,227			6,082,042			2,541,121
Increase (decrease) in net assets from operations	$	1,038,857		$	1,637,818		$	5,851,773		$	2,393,343

See accompanying notes.

39

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Diversified Equity VP Subaccount			Transamerica Jennison Growth VP Subaccount			Transamerica JPMorgan Enhanced Index VP Subaccount			Transamerica AEGON High Yield Bond VP Subaccount
Net investment income (loss)
Income:
Dividends	$	226,371		$	9,074		$	138,871		$	3,893,316
Expenses:
Administrative, mortality and expense risk charge		387,494			337,556			189,229			508,279
Net investment income (loss)		(161,123	)		(328,482	)		(50,358	)		3,385,037
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		5,001,813			6,031,553			2,722,447			16,750,592
Cost of investments sold		4,256,597			6,003,489			3,429,124			16,240,171
Net realized capital gains (losses) on investments		745,216			28,064			(706,677	)		510,421
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		3,361,249			59,871			(1,510,618	)		2,359,635
End of period		5,789,634			2,066,936			485,595			1,082,749
Net change in unrealized appreciation/depreciation of investments		2,428,385			2,007,065			1,996,213			(1,276,886	)
Net realized and unrealized capital gains (losses) on investments		3,173,601			2,035,129			1,289,536			(766,465	)
Increase (decrease) in net assets from operations	$	3,012,478		$	1,706,647		$	1,239,178		$	2,618,572

See accompanying notes.

40

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica BlackRock Large Cap Value VP Subaccount			Transamerica PIMCO Total Return VP Subaccount		Transamerica Focus VP Subaccount			Transamerica AllianceBernstein Dynamic Allocation VP Subaccount
Net investment income (loss)
Income:
Dividends	$	547,813		$	3,635,948	$	171,936		$	470,699
Expenses:
Administrative, mortality and expense risk charge		1,181,186			1,645,710		358,651			166,848
Net investment income (loss)		(633,373	)		1,990,238		(186,715	)		303,851
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			124,887		—			—
Proceeds from sales		11,479,972			24,838,702		3,039,353			3,880,909
Cost of investments sold		16,763,485			23,441,724		3,776,418			4,929,254
Net realized capital gains (losses) on investments		(5,283,513	)		1,521,865		(737,065	)		(1,048,345	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(4,588,540	)		587,897		(6,875,477	)		(632,106	)
End of period		4,920,075			1,355,216		(1,247,020	)		765,913
Net change in unrealized appreciation/depreciation of investments		9,508,615			767,319		5,628,457			1,398,019
Net realized and unrealized capital gains (losses) on investments		4,225,102			2,289,184		4,891,392			349,674
Increase (decrease) in net assets from operations	$	3,591,729		$	4,279,422	$	4,704,677		$	653,525

See accompanying notes.

41

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica WMC Diversified Growth VP Subaccount			Transamerica Growth Opportunities VP Subaccount			Transamerica U.S. Government Securities VP Subaccount			Transamerica U.S. Government Securities VP PAM SC Subaccount
Net investment income (loss)
Income:
Dividends	$	173,719		$	4,243		$	1,392,327		$	209,487
Expenses:
Administrative, mortality and expense risk charge		588,786			230,540			804,396			116,461
Net investment income (loss)		(415,067	)		(226,297	)		587,931			93,026
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			1,020,225			163,875
Proceeds from sales		6,552,961			2,494,877			22,589,487			5,472,214
Cost of investments sold		6,553,673			3,310,474			21,496,629			5,085,483
Net realized capital gains (losses) on investments		(712	)		(815,597	)		2,113,083			550,606
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(7,001,962	)		(3,526,393	)		1,937,440			376,109
End of period		(1,786,946	)		1,265,711			285,219			(65,187	)
Net change in unrealized appreciation/depreciation of investments		5,215,016			4,792,104			(1,652,221	)		(441,296	)
Net realized and unrealized capital gains (losses) on investments		5,214,304			3,976,507			460,862			109,310
Increase (decrease) in net assets from operations	$	4,799,237		$	3,750,210		$	1,048,793		$	202,336

See accompanying notes.

42

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Money Market VP Subaccount			Transamerica T. Rowe Price Small Cap VP Subaccount			Transamerica Morgan Stanley Active International Allocation VP Subaccount			Transamerica Multi Managed Large Cap Core VP Subaccount
Net investment income (loss)
Income:
Dividends	$	2,976		$	—		$	279,214		$	165,956
Expenses:
Administrative, mortality and expense risk charge		1,076,968			310,336			261,872			451,034
Net investment income (loss)		(1,073,992	)		(310,336	)		17,342			(285,078	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		55,076,998			4,351,948			4,669,673			4,412,036
Cost of investments sold		55,076,998			6,031,688			7,210,622			5,408,837
Net realized capital gains (losses) on investments		—			(1,679,740	)		(2,540,949	)		(996,801	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		—			(4,013,200	)		(3,484,524	)		2,843,472
End of period		—			2,764,359			(192,231	)		8,077,746
Net change in unrealized appreciation/depreciation of investments		—			6,777,559			3,292,293			5,234,274
Net realized and unrealized capital gains (losses) on investments		—			5,097,819			751,344			4,237,473
Increase (decrease) in net assets from operations	$	(1,073,992	)	$	4,787,483		$	768,686		$	3,952,395

See accompanying notes.

43

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Morgan Stanley Mid-Cap Growth VP Subaccount			Transamerica International Moderate Growth VP SC Subaccount			Transamerica Efficient Markets VP SC Subaccount			Transamerica Index 50 VP SC Subaccount
Net investment income (loss)
Income:
Dividends	$	12,201		$	653,312		$	13,346		$	50,456
Expenses:
Administrative, mortality and expense risk charge		198,415			452,850			34,663			79,312
Net investment income (loss)		(186,214	)		200,462			(21,317	)		(28,856	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			36,023			46,198
Proceeds from sales		2,475,088			3,755,041			98,182			1,929,885
Cost of investments sold		1,793,586			4,856,856			70,984			1,606,551
Net realized capital gains (losses) on investments		681,502			(1,101,815	)		63,221			369,532
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		500,115			(2,214,632	)		181,693			346,371
End of period		3,100,410			864,655			380,366			402,651
Net change in unrealized appreciation/depreciation of investments		2,600,295			3,079,287			198,673			56,280
Net realized and unrealized capital gains (losses) on investments		3,281,797			1,977,472			261,894			425,812
Increase (decrease) in net assets from operations	$	3,095,583		$	2,177,934		$	240,577		$	396,956

See accompanying notes.

44

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Index 75 VP SC Subaccount			Transamerica BlackRock Global Allocation VP SC Subaccount			Transamerica BlackRock Tactical Allocation VP SC Subaccount			Transamerica ProFunds UltraBear Fund VP OAM SC Subaccount
Net investment income (loss)
Income:
Dividends	$	138,061		$	93,844		$	27,357		$	—
Expenses:
Administrative, mortality and expense risk charge		203,779			351,877			117,742			6,245
Net investment income (loss)		(65,718	)		(258,033	)		(90,385	)		(6,245	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		117,332			—			21,315			—
Proceeds from sales		1,422,383			1,142,832			1,117,938			2,505,025
Cost of investments sold		1,053,382			984,939			1,008,057			2,810,882
Net realized capital gains (losses) on investments		486,333			157,893			131,196			(305,857	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		1,228,695			380,453			120,006			—
End of period		2,249,361			2,564,262			842,652			(32,576	)
Net change in unrealized appreciation/depreciation of investments		1,020,666			2,183,809			722,646			(32,576	)
Net realized and unrealized capital gains (losses) on investments		1,506,999			2,341,702			853,842			(338,433	)
Increase (decrease) in net assets from operations	$	1,441,281		$	2,083,669		$	763,457		$	(344,678	)

See accompanying notes.

45

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Foxhall Global Growth VP SC Subaccount			Transamerica Foxhall Global Conservative VP SC Subaccount			Transamerica Foxhall Global Hard Asset VP SC Subaccount			Transamerica Foxhall Emerging Markets/Pacific Rim VP SC Subaccount
Net investment income (loss)
Income:
Dividends	$	5,134		$	1,619		$	2,407		$	6,738
Expenses:
Administrative, mortality and expense risk charge		23,841			20,183			24,505			31,441
Net investment income (loss)		(18,707	)		(18,564	)		(22,098	)		(24,703	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		13,337			945			5,752			16,351
Proceeds from sales		384,297			228,947			288,216			247,255
Cost of investments sold		392,463			239,340			296,795			244,692
Net realized capital gains (losses) on investments		5,171			(9,448	)		(2,827	)		18,914
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		2,419			(320	)		2,432			11,842
End of period		171,354			(52,132	)		189,247			209,091
Net change in unrealized appreciation/depreciation of investments		168,935			(51,812	)		186,815			197,249
Net realized and unrealized capital gains (losses) on investments		174,106			(61,260	)		183,988			216,163
Increase (decrease) in net assets from operations	$	155,399		$	(79,824	)	$	161,890		$	191,460

See accompanying notes.

46

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Hanlon Growth VP SC Subaccount			Transamerica Hanlon Growth and Income VP SC Subaccount			Transamerica Hanlon Balanced VP SC Subaccount			Transamerica Hanlon Managed Income VP SC Subaccount
Net investment income (loss)
Income:
Dividends	$	22,183		$	9,409		$	5,618		$	21,701
Expenses:
Administrative, mortality and expense risk charge		30,381			18,963			18,234			152,990
Net investment income (loss)		(8,198	)		(9,554	)		(12,616	)		(131,289	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		14,745			5,442			2,746			36,549
Proceeds from sales		491,738			313,426			141,223			820,903
Cost of investments sold		531,960			324,756			148,070			821,802
Net realized capital gains (losses) on investments		(25,477	)		(5,888	)		(4,101	)		35,650
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		1,144			707			1,094			251
End of period		79,878			57,710			42,101			(89,413	)
Net change in unrealized appreciation/depreciation of investments		78,734			57,003			41,007			(89,664	)
Net realized and unrealized capital gains (losses) on investments		53,257			51,115			36,906			(54,014	)
Increase (decrease) in net assets from operations	$	45,059		$	41,561		$	24,290		$	(185,303	)

See accompanying notes.

47

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Transamerica Index 35 VP SC Subaccount			Transamerica Index 100 VP SC Subaccount			Transamerica JP Morgan Midcap Value VP SC Subaccount			Invesco V.I. Basic Value Subaccount
Net investment income (loss)
Income:
Dividends	$	329		$	204		$	21,904		$	24,569
Expenses:
Administrative, mortality and expense risk charge		16,598			4,899			14,913			134,613
Net investment income (loss)		(16,269	)		(4,695	)		6,991			(110,044	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			33			—			—
Proceeds from sales		54,809			133,199			256,068			1,780,053
Cost of investments sold		52,973			132,015			256,331			3,463,757
Net realized capital gains (losses) on investments		1,836			1,217			(263	)		(1,683,704	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(83	)		—			(179	)		(2,203,315	)
End of period		101,442			88,257			201,708			(120,942	)
Net change in unrealized appreciation/depreciation of investments		101,525			88,257			201,887			2,082,373
Net realized and unrealized capital gains (losses) on investments		103,361			89,474			201,624			398,669
Increase (decrease) in net assets from operations	$	87,092		$	84,779		$	208,615		$	288,625

See accompanying notes.

48

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Invesco V.I. Capital Appreciation Subaccount			AllianceBernstein Growth and Income Subaccount			AllianceBernstein Large Cap Growth Subaccount			AllianceBernstein Balanced Wealth Strategy Subaccount
Net investment income (loss)
Income:
Dividends	$	11,021		$	—		$	15,159		$	47,393
Expenses:
Administrative, mortality and expense risk charge		38,794			215,341			101,832			43,809
Net investment income (loss)		(27,773	)		(215,341	)		(86,673	)		3,584
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		273,565			1,970,054			1,345,129			241,326
Cost of investments sold		342,049			2,734,481			1,291,763			179,525
Net realized capital gains (losses) on investments		(68,484	)		(764,427	)		53,366			61,801
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(385,096	)		(5,251,257	)		30,176			289,592
End of period		(3,270	)		(3,076,588	)		491,580			439,724
Net change in unrealized appreciation/depreciation of investments		381,826			2,174,669			461,404			150,132
Net realized and unrealized capital gains (losses) on investments		313,342			1,410,242			514,770			211,933
Increase (decrease) in net assets from operations	$	285,569		$	1,194,901		$	428,097		$	215,517

See accompanying notes.

49

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Janus Aspen - Enterprise Subaccount			Janus Aspen - Perkins Mid Cap Value Subaccount			Janus Aspen - Worldwide Subaccount			MFS® New Discovery Subaccount
Net investment income (loss)
Income:
Dividends	$	—		$	5,125		$	54,470		$	—
Expenses:
Administrative, mortality and expense risk charge		98,762			18,063			206,870			135,528
Net investment income (loss)		(98,762	)		(12,938	)		(152,400	)		(135,528	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		1,283,622			247,865			1,832,064			3,271,674
Cost of investments sold		1,532,419			246,439			2,375,449			2,738,200
Net realized capital gains (losses) on investments		(248,797	)		1,426			(543,385	)		533,474
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(361,632	)		(73,370	)		(1,743,360	)		828,457
End of period		1,217,819			72,030			423,616			2,702,571
Net change in unrealized appreciation/depreciation of investments		1,579,451			145,400			2,166,976			1,874,114
Net realized and unrealized capital gains (losses) on investments		1,330,654			146,826			1,623,591			2,407,588
Increase (decrease) in net assets from operations	$	1,231,892		$	133,888		$	1,471,191		$	2,272,060

See accompanying notes.

50

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	MFS® Total Return Subaccount			Fidelity VIP Contrafund Subaccount			Fidelity VIP Equity-Income Subaccount			Fidelity VIP Growth Subaccount
Net investment income (loss)
Income:
Dividends	$	364,298		$	370,468		$	191,915		$	1,865
Expenses:
Administrative, mortality and expense risk charge		263,931			648,148			216,228			111,397
Net investment income (loss)		100,367			(277,680	)		(24,313	)		(109,532	)
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			16,931			—			20,999
Proceeds from sales		2,699,973			5,511,015			2,241,290			1,297,550
Cost of investments sold		3,230,196			8,063,417			3,411,882			1,754,584
Net realized capital gains (losses) on investments		(530,223	)		(2,535,471	)		(1,170,592	)		(436,035	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(1,642,646	)		(12,396,598	)		(4,745,283	)		(1,781,300	)
End of period		(171,711	)		(4,457,869	)		(2,125,776	)		769
Net change in unrealized appreciation/depreciation of investments		1,470,935			7,938,729			2,619,507			1,782,069
Net realized and unrealized capital gains (losses) on investments		940,712			5,403,258			1,448,915			1,346,034
Increase (decrease) in net assets from operations	$	1,041,079		$	5,125,578		$	1,424,602		$	1,236,502

See accompanying notes.

51

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Fidelity VIP Growth Opportunities Subaccount			Fidelity VIP  Mid Cap Subaccount			Fidelity VIP Value  Strategies Subaccount			Fidelity VIP Balanced Subaccount
Net investment income (loss)
Income:
Dividends	$	—		$	56,556		$	40,325		$	42,261
Expenses:
Administrative, mortality and expense risk charge		7,188			853,666			254,401			40,535
Net investment income (loss)		(7,188	)		(797,110	)		(214,076	)		1,726
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			153,073			—			15,431
Proceeds from sales		42,179			7,534,911			3,009,153			931,673
Cost of investments sold		33,336			9,025,771			4,673,529			683,575
Net realized capital gains (losses) on investments		8,843			(1,337,787	)		(1,664,376	)		263,529
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		30,417			(8,903,930	)		(3,679,994	)		283,859
End of period		112,028			4,215,003			1,130,557			414,599
Net change in unrealized appreciation/depreciation of investments		81,611			13,118,933			4,810,551			130,740
Net realized and unrealized capital gains (losses) on investments		90,454			11,781,146			3,146,175			394,269
Increase (decrease) in net assets from operations	$	83,266		$	10,984,036		$	2,932,099		$	395,995

See accompanying notes.

52

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	Franklin Income Securities Subaccount			Mutual Shares Securities Subaccount			Templeton Foreign Securities Subaccount			Franklin Templeton VIP Founding Funds Allocation Subaccount
Net investment income (loss)
Income:
Dividends	$	527,158		$	47,233		$	156,572		$	134,753
Expenses:
Administrative, mortality and expense risk charge		151,416			56,976			159,010			102,454
Net investment income (loss)		375,742			(9,743	)		(2,438	)		32,299
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			509
Proceeds from sales		2,424,861			1,036,977			5,075,683			403,278
Cost of investments sold		2,627,796			1,068,241			4,552,863			269,630
Net realized capital gains (losses) on investments		(202,935	)		(31,264	)		522,820			134,157
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		456,357			179,243			794,510			391,788
End of period		1,217,432			509,206			688,233			735,753
Net change in unrealized appreciation/depreciation of investments		761,075			329,963			(106,277	)		343,965
Net realized and unrealized capital gains (losses) on investments		558,140			298,699			416,543			478,122
Increase (decrease) in net assets from operations	$	933,882		$	288,956		$	414,105		$	510,421

See accompanying notes.

53

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	American Funds – Asset Allocation Fund Subaccount			American Funds – Bond Fund Subaccount			American Funds – Growth Fund Subaccount			American Funds – Growth – Income Fund Subaccount
Net investment income (loss)
Income:
Dividends	$	41,502		$	65,716		$	9,867		$	11,064
Expenses:
Administrative, mortality and expense risk charge		21,471			24,557			18,570			9,224
Net investment income (loss)		20,031			41,159			(8,703	)		1,840
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—			—			—
Proceeds from sales		493,191			581,454			176,443			55,805
Cost of investments sold		477,704			556,384			178,480			58,874
Net realized capital gains (losses) on investments		15,487			25,070			(2,037	)		(3,069	)
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(28	)		(116	)		(2,621	)		(41	)
End of period		130,183			(52,643	)		202,696			75,364
Net change in unrealized appreciation/depreciation of investments		130,211			(52,527	)		205,317			75,405
Net realized and unrealized capital gains (losses) on investments		145,698			(27,457	)		203,280			72,336
Increase (decrease) in net assets from operations	$	165,729		$	13,702		$	194,577		$	74,176

See accompanying notes.

54

Transamerica Life Insurance Company

Separate Account VA C

Statements of Operations

Year Ended December 31, 2010

	American Funds – International Fund Subaccount			GE Investments Total Return Fund Subaccount
Net investment income (loss)
Income:
Dividends	$	26,708		$	6,147
Expenses:
Administrative, mortality and expense risk charge		19,038			3,657
Net investment income (loss)		7,670			2,490
Net realized and unrealized capital gains (losses) on investments
Net realized capital gains (losses) on investments:
Realized gain distributions		—			—
Proceeds from sales		164,377			84,902
Cost of investments sold		171,999			82,011
Net realized capital gains (losses) on investments		(7,622	)		2,891
Net change in unrealized appreciation/depreciation of investments:
Beginning of period		(1,337	)		—
End of period		115,175			28,368
Net change in unrealized appreciation/depreciation of investments		116,512			28,368
Net realized and unrealized capital gains (losses) on investments		108,890			31,259
Increase (decrease) in net assets from operations	$	116,560		$	33,749

See accompanying notes.

55

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Asset Allocation-Growth VP Subaccount						Transamerica Asset Allocation-Conservative VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(762,362	)	$	735,141		$	1,876,217		$	2,595,575
Net realized capital gains (losses) on investments		(13,202,952	)		(3,574,607	)		(3,129,784	)		(5,754,390	)
Net change in unrealized appreciation/depreciation of investments		24,668,926			23,129,168			10,260,929			25,848,622
Increase (decrease) in net assets from operations		10,703,612			20,289,702			9,007,362			22,689,807
Contract transactions
Net contract purchase payments		2,173,651			2,021,422			5,354,680			6,769,478
Transfer payments from (to) other subaccounts or general account		(4,130,277	)		1,342,314			7,879,734			20,278,279
Contract terminations, withdrawals, and other deductions		(5,664,445	)		(4,318,186	)		(10,930,449	)		(9,102,768	)
Contract maintenance charges		(513,831	)		(496,846	)		(750,236	)		(596,551	)
Increase (decrease) in net assets from contract transactions		(8,134,902	)		(1,451,296	)		1,553,729			17,348,438
Net increase (decrease) in net assets		2,568,710			18,838,406			10,561,091			40,038,245
Net assets:
Beginning of the period		95,997,089			77,158,683			126,313,597			86,275,352
End of the period	$	98,565,799		$	95,997,089		$	136,874,688		$	126,313,597

See accompanying notes.

56

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Asset Allocation-Moderate VP Subaccount						Transamerica Asset Allocation-Moderate Growth VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	2,490,837		$	4,810,556		$	843,008		$	3,560,569
Net realized capital gains (losses) on investments		(6,874,243	)		(393,828	)		(9,882,891	)		(284,270	)
Net change in unrealized appreciation/depreciation of investments		22,738,258			37,226,817			37,982,544			53,331,446
Increase (decrease) in net assets from operations		18,354,852			41,643,545			28,942,661			56,607,745
Contract transactions
Net contract purchase payments		12,301,907			13,589,959			15,805,396			19,119,903
Transfer payments from (to) other subaccounts or general account		3,109,707			11,100,872			3,495,338			(2,224,305	)
Contract terminations, withdrawals, and other deductions		(16,788,351	)		(12,845,022	)		(20,027,265	)		(12,535,829	)
Contract maintenance charges		(1,385,459	)		(1,140,709	)		(1,945,718	)		(1,648,920	)
Increase (decrease) in net assets from contract transactions		(2,762,196	)		10,705,100			(2,672,249	)		2,710,849
Net increase (decrease) in net assets		15,592,656			52,348,645			26,270,412			59,318,594
Net assets:
Beginning of the period		225,867,937			173,519,292			283,743,710			224,425,116
End of the period	$	241,460,593		$	225,867,937		$	310,014,122		$	283,743,710

See accompanying notes.

57

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica MFS International Equity VP Subaccount						Transamerica Clarion Global Real Estate Securities VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(76,005	)	$	140,565		$	571,591		$	(189,935	)
Net realized capital gains (losses) on investments		(2,724,452	)		(3,397,905	)		(4,081,173	)		(5,377,596	)
Net change in unrealized appreciation/depreciation of investments		3,839,314			7,045,943			5,147,400			8,231,592
Increase (decrease) in net assets from operations		1,038,857			3,788,603			1,637,818			2,664,061
Contract transactions
Net contract purchase payments		482,176			434,021			800,122			309,848
Transfer payments from (to) other subaccounts or general account		(1,280,272	)		(624,614	)		(315,333	)		(625,590	)
Contract terminations, withdrawals, and other deductions		(1,370,431	)		(1,539,987	)		(761,375	)		(884,118	)
Contract maintenance charges		(83,804	)		(86,845	)		(73,116	)		(70,926	)
Increase (decrease) in net assets from contract transactions		(2,252,331	)		(1,817,425	)		(349,702	)		(1,270,786	)
Net increase (decrease) in net assets		(1,213,474	)		1,971,178			1,288,116			1,393,275
Net assets:
Beginning of the period		16,751,443			14,780,265			12,311,146			10,917,871
End of the period	$	15,537,969		$	16,751,443		$	13,599,262		$	12,311,146

See accompanying notes.

58

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Small/Mid Cap Value VP Subaccount						Transamerica Balanced VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(230,269	)	$	269,187		$	(147,778	)	$	(6,997	)
Net realized capital gains (losses) on investments		1,997,490			1,393,921			10,539			(891,132	)
Net change in unrealized appreciation/depreciation of investments		4,084,552			4,695,901			2,530,582			2,542,983
Increase (decrease) in net assets from operations		5,851,773			6,359,009			2,393,343			1,644,854
Contract transactions
Net contract purchase payments		1,535,602			564,692			1,186,187			796,334
Transfer payments from (to) other subaccounts or general account		(383,485	)		(426,480	)		2,020,233			(260,274	)
Contract terminations, withdrawals, and other deductions		(1,815,571	)		(2,083,586	)		(692,503	)		(746,653	)
Contract maintenance charges		(112,902	)		(99,639	)		(72,553	)		(55,153	)
Increase (decrease) in net assets from contract transactions		(776,356	)		(2,045,013	)		2,441,364			(265,746	)
Net increase (decrease) in net assets		5,075,417			4,313,996			4,834,707			1,379,108
Net assets:
Beginning of the period		21,501,409			17,187,413			9,298,433			7,919,325
End of the period	$	26,576,826		$	21,501,409		$	14,133,140		$	9,298,433

See accompanying notes.

59

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Diversified Equity VP Subaccount						Transamerica Jennison Growth VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(161,123	)	$	15,908		$	(328,482	)	$	(60,147	)
Net realized capital gains (losses) on investments		745,216			(907,519	)		28,064			(389,829	)
Net change in unrealized appreciation/depreciation of investments		2,428,385			4,966,412			2,007,065			1,677,760
Increase (decrease) in net assets from operations		3,012,478			4,074,801			1,706,647			1,227,784
Contract transactions
Net contract purchase payments		677,601			320,571			555,339			126,837
Transfer payments from (to) other subaccounts or general account		5,425,119			11,491,468			21,252,885			372,808
Contract terminations, withdrawals, and other deductions		(1,424,118	)		(721,255	)		(1,654,290	)		(315,358	)
Contract maintenance charges		(121,125	)		(68,780	)		(94,246	)		(20,891	)
Increase (decrease) in net assets from contract transactions		4,557,477			11,022,004			20,059,688			163,396
Net increase (decrease) in net assets		7,569,955			15,096,805			21,766,335			1,391,180
Net assets:
Beginning of the period		17,767,380			2,670,575			4,395,005			3,003,825
End of the period	$	25,337,335		$	17,767,380		$	26,161,340		$	4,395,005

See accompanying notes.

60

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica JPMorgan Enhanced Index VP Subaccount						Transamerica AEGON High Yield Bond VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(50,358	)	$	29,318		$	3,385,037		$	1,591,778
Net realized capital gains (losses) on investments		(706,677	)		(882,604	)		510,421			(2,239,006	)
Net change in unrealized appreciation/depreciation of investments		1,996,213			3,074,429			(1,276,886	)		8,148,382
Increase (decrease) in net assets from operations		1,239,178			2,221,143			2,618,572			7,501,154
Contract transactions
Net contract purchase payments		96,337			144,517			1,294,604			418,782
Transfer payments from (to) other subaccounts or general account		(421,251	)		916,251			(587,981	)		9,180,903
Contract terminations, withdrawals, and other deductions		(496,215	)		(650,492	)		(2,144,292	)		(1,722,328	)
Contract maintenance charges		(59,953	)		(53,528	)		(149,191	)		(115,035	)
Increase (decrease) in net assets from contract transactions		(881,082	)		356,748			(1,586,860	)		7,762,322
Net increase (decrease) in net assets		358,096			2,577,891			1,031,712			15,263,476
Net assets:
Beginning of the period		10,278,995			7,701,104			28,156,204			12,892,728
End of the period	$	10,637,091		$	10,278,995		$	29,187,916		$	28,156,204

See accompanying notes.

61

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica BlackRock Large Cap Value VP Subaccount						Transamerica PIMCO Total Return VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(633,373	)	$	(104,770	)	$	1,990,238		$	2,923,466
Net realized capital gains (losses) on investments		(5,283,513	)		(4,228,181	)		1,521,865			2,163,834
Net change in unrealized appreciation/depreciation of investments		9,508,615			6,572,210			767,319			3,402,810
Increase (decrease) in net assets from operations		3,591,729			2,239,259			4,279,422			8,490,110
Contract transactions
Net contract purchase payments		1,723,894			743,316			9,017,663			3,169,042
Transfer payments from (to) other subaccounts or general account		36,792,133			23,287,166			5,409,376			15,534,119
Contract terminations, withdrawals, and other deductions		(4,915,473	)		(1,390,104	)		(6,340,259	)		(6,391,825	)
Contract maintenance charges		(344,836	)		(117,319	)		(468,543	)		(371,742	)
Increase (decrease) in net assets from contract transactions		33,255,718			22,523,059			7,618,237			11,939,594
Net increase (decrease) in net assets		36,847,447			24,762,318			11,897,659			20,429,704
Net assets:
Beginning of the period		42,665,195			17,902,877			78,168,950			57,739,246
End of the period	$	79,512,642		$	42,665,195		$	90,066,609		$	78,168,950

See accompanying notes.

62

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Focus VP Subaccount						Transamerica AllianceBernstein Dynamic Allocation VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(186,715	)	$	135,380		$	303,851		$	138,638
Net realized capital gains (losses) on investments		(737,065	)		(962,782	)		(1,048,345	)		(2,897,656	)
Net change in unrealized appreciation/depreciation of investments		5,628,457			4,867,754			1,398,019			4,570,724
Increase (decrease) in net assets from operations		4,704,677			4,040,352			653,525			1,811,706
Contract transactions
Net contract purchase payments		184,717			191,197			1,106,887			140,295
Transfer payments from (to) other subaccounts or general account		931,528			(835,326	)		(318,907	)		(5,149	)
Contract terminations, withdrawals, and other deductions		(1,506,180	)		(1,328,792	)		(946,274	)		(704,581	)
Contract maintenance charges		(107,993	)		(111,223	)		(45,478	)		(45,828	)
Increase (decrease) in net assets from contract transactions		(497,928	)		(2,084,144	)		(203,772	)		(615,263	)
Net increase (decrease) in net assets		4,206,749			1,956,208			449,753			1,196,443
Net assets:
Beginning of the period		19,905,676			17,949,468			8,626,622			7,430,179
End of the period	$	24,112,425		$	19,905,676		$	9,076,375		$	8,626,622

See accompanying notes.

63

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica WMC Diversified Growth VP Subaccount						Transamerica Growth Opportunities VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(415,067	)	$	(255,782	)	$	(226,297	)	$	(154,898	)
Net realized capital gains (losses) on investments		(712	)		(1,127,984	)		(815,597	)		(1,686,073	)
Net change in unrealized appreciation/depreciation of investments		5,215,016			8,321,242			4,792,104			4,923,935
Increase (decrease) in net assets from operations		4,799,237			6,937,476			3,750,210			3,082,964
Contract transactions
Net contract purchase payments		853,062			391,570			323,344			178,672
Transfer payments from (to) other subaccounts or general account		26,989			(1,877,586	)		822,968			287,745
Contract terminations, withdrawals, and other deductions		(3,157,462	)		(2,352,892	)		(966,892	)		(804,259	)
Contract maintenance charges		(177,676	)		(182,798	)		(64,883	)		(60,400	)
Increase (decrease) in net assets from contract transactions		(2,455,087	)		(4,021,706	)		114,537			(398,242	)
Net increase (decrease) in net assets		2,344,150			2,915,770			3,864,747			2,684,722
Net assets:
Beginning of the period		32,612,803			29,697,033			12,251,024			9,566,302
End of the period	$	34,956,953		$	32,612,803		$	16,115,771		$	12,251,024

See accompanying notes.

64

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica U.S. Government Securities VP Subaccount						Transamerica U.S. Government Securities VP PAM SC Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	587,931		$	178,390		$	93,026		$	28,255
Net realized capital gains (losses) on investments		2,113,083			820,264			550,606			406,942
Net change in unrealized appreciation/depreciation of investments		(1,652,221	)		6,342			(441,296	)		(196,235	)
Increase (decrease) in net assets from operations		1,048,793			1,004,996			202,336			238,962
Contract transactions
Net contract purchase payments		14,734,681			3,397,088			—			1
Transfer payments from (to) other subaccounts or general account		(10,087,305	)		994,700			(1,941,646	)		(5,562,211	)
Contract terminations, withdrawals, and other deductions		(4,485,363	)		(5,394,355	)		(596,532	)		(696,308	)
Contract maintenance charges		(235,842	)		(239,881	)		(63,611	)		(100,983	)
Increase (decrease) in net assets from contract transactions		(73,829	)		(1,242,448	)		(2,601,789	)		(6,359,501	)
Net increase (decrease) in net assets		974,964			(237,452	)		(2,399,453	)		(6,120,539	)
Net assets:
Beginning of the period		42,783,689			43,021,141			7,316,615			13,437,154
End of the period	$	43,758,653		$	42,783,689		$	4,917,162		$	7,316,615

See accompanying notes.

65

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Money Market VP Subaccount						Transamerica T. Rowe Price Small Cap VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(1,073,992	)	$	(1,351,080	)	$	(310,336	)	$	(243,483	)
Net realized capital gains (losses) on investments		—			—			(1,679,740	)		(2,209,713	)
Net change in unrealized appreciation/depreciation of investments		—			—			6,777,559			6,544,029
Increase (decrease) in net assets from operations		(1,073,992	)		(1,351,080	)		4,787,483			4,090,833
Contract transactions
Net contract purchase payments		8,930,565			9,034,173			789,776			299,353
Transfer payments from (to) other subaccounts or general account		1,174,991			(30,479,361	)		1,292,428			31,941
Contract terminations, withdrawals, and other deductions		(11,006,309	)		(15,159,747	)		(1,164,466	)		(1,062,122	)
Contract maintenance charges		(393,216	)		(448,510	)		(93,589	)		(80,493	)
Increase (decrease) in net assets from contract transactions		(1,293,969	)		(37,053,445	)		824,149			(811,321	)
Net increase (decrease) in net assets		(2,367,961	)		(38,404,525	)		5,611,632			3,279,512
Net assets:
Beginning of the period		58,226,265			96,630,790			15,892,177			12,612,665
End of the period	$	55,858,304		$	58,226,265		$	21,503,809		$	15,892,177

See accompanying notes.

66

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Morgan Stanley Active International Allocation VP Subaccount						Transamerica Multi Managed Large Cap Core VP Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	17,342		$	(262,866	)	$	(285,078	)	$	(146,998	)
Net realized capital gains (losses) on investments		(2,540,949	)		(4,554,684	)		(996,801	)		(831,107	)
Net change in unrealized appreciation/depreciation of investments		3,292,293			7,831,949			5,234,274			7,735,892
Increase (decrease) in net assets from operations		768,686			3,014,399			3,952,395			6,757,787
Contract transactions
Net contract purchase payments		300,139			228,309			383,593			257,334
Transfer payments from (to) other subaccounts or general account		(1,306,373	)		(3,306,052	)		(326,826	)		12,556,951
Contract terminations, withdrawals, and other deductions		(1,308,675	)		(1,117,335	)		(2,394,087	)		(1,546,066	)
Contract maintenance charges		(72,052	)		(84,521	)		(142,870	)		(100,184	)
Increase (decrease) in net assets from contract transactions		(2,386,961	)		(4,279,599	)		(2,480,190	)		11,168,035
Net increase (decrease) in net assets		(1,618,275	)		(1,265,200	)		1,472,205			17,925,822
Net assets:
Beginning of the period		15,908,668			17,173,868			25,144,254			7,218,432
End of the period	$	14,290,393		$	15,908,668		$	26,616,459		$	25,144,254

See accompanying notes.

67

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Morgan Stanley Mid-Cap Growth VP Subaccount						Transamerica International Moderate Growth VP SC Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(186,214	)	$	(125,112	)	$	200,462		$	172,595
Net realized capital gains (losses) on investments		681,502			434			(1,101,815	)		(1,366,533	)
Net change in unrealized appreciation/depreciation of investments		2,600,295			3,125,897			3,079,287			5,970,943
Increase (decrease) in net assets from operations		3,095,583			3,001,219			2,177,934			4,777,005
Contract transactions
Net contract purchase payments		823,114			388,320			3,661,985			3,538,518
Transfer payments from (to) other subaccounts or general account		1,737,468			556,011			(524,806	)		1,099,994
Contract terminations, withdrawals, and other deductions		(676,323	)		(384,396	)		(1,495,718	)		(701,462	)
Contract maintenance charges		(61,590	)		(43,448	)		(242,136	)		(183,315	)
Increase (decrease) in net assets from contract transactions		1,822,669			516,487			1,399,325			3,753,735
Net increase (decrease) in net assets		4,918,252			3,517,706			3,577,259			8,530,740
Net assets:
Beginning of the period		9,037,055			5,519,349			24,766,153			16,235,413
End of the period	$	13,955,307		$	9,037,055		$	28,343,412		$	24,766,153

See accompanying notes.

68

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Efficient Markets VP SC Subaccount						Transamerica Index 50 VP SC Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(21,317	)	$	(11,686	)	$	(28,856	)	$	(24,869	)
Net realized capital gains (losses) on investments		63,221			12,376			369,532			15,172
Net change in unrealized appreciation/depreciation of investments		198,673			181,693			56,280			344,162
Increase (decrease) in net assets from operations		240,577			182,383			396,956			334,465
Contract transactions
Net contract purchase payments		752,610			780,049			2,066,044			2,115,338
Transfer payments from (to) other subaccounts or general account		542,789			543,509			(256,260	)		711,324
Contract terminations, withdrawals, and other deductions		(6,019	)		(28,829	)		(94,306	)		(35,190	)
Contract maintenance charges		(14,224	)		(103	)		(32,119	)		(4,211	)
Increase (decrease) in net assets from contract transactions		1,275,156			1,294,626			1,683,359			2,787,261
Net increase (decrease) in net assets		1,515,733			1,477,009			2,080,315			3,121,726
Net assets:
Beginning of the period		1,477,009			—			3,368,800			247,074
End of the period	$	2,992,742		$	1,477,009		$	5,449,115		$	3,368,800

See accompanying notes.

69

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Index 75 VP SC Subaccount						Transamerica BlackRock Global Allocation VP SC Subaccount
	2010			2009			2010			2009(1)
Operations
Net investment income (loss)	$	(65,718	)	$	(64,034	)	$	(258,033	)	$	(39,121	)
Net realized capital gains (losses) on investments		486,333			(210,618	)		157,893			8,953
Net change in unrealized appreciation/depreciation of investments		1,020,666			1,426,703			2,183,809			380,453
Increase (decrease) in net assets from operations		1,441,281			1,152,051			2,083,669			350,285
Contract transactions
Net contract purchase payments		3,244,586			6,162,812			14,924,024			5,887,596
Transfer payments from (to) other subaccounts or general account		1,263,426			1,149,580			7,462,437			2,800,484
Contract terminations, withdrawals, and other deductions		(235,068	)		(51,920	)		(540,543	)		(7,764	)
Contract maintenance charges		(100,645	)		(12,925	)		(160,773	)		(9,037	)
Increase (decrease) in net assets from contract transactions		4,172,299			7,247,547			21,685,145			8,671,279
Net increase (decrease) in net assets		5,613,580			8,399,598			23,768,814			9,021,564
Net assets:
Beginning of the period		9,921,666			1,522,068			9,021,564			—
End of the period	$	15,535,246		$	9,921,666		$	32,790,378		$	9,021,564

See accompanying notes.

70

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica BlackRock Tactical Allocation VP SC Subaccount						Transamerica ProFunds UltraBear Fund VP OAM SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(90,385	)	$	(13,487	)	$	(6,245	)	$	—
Net realized capital gains (losses) on investments		131,196			35,812			(305,857	)		(5	)
Net change in unrealized appreciation/depreciation of investments		722,646			120,006			(32,576	)		—
Increase (decrease) in net assets from operations		763,457			142,331			(344,678	)		(5	)
Contract transactions
Net contract purchase payments		3,450,598			1,390,232			—			—
Transfer payments from (to) other subaccounts or general account		6,608,013			1,256,569			522,353			97
Contract terminations, withdrawals, and other deductions		(335,571	)		(12,479	)		(4,867	)		(92	)
Contract maintenance charges		(51,999	)		(2,963	)		(3,519	)		—
Increase (decrease) in net assets from contract transactions		9,671,041			2,631,359			513,967			5
Net increase (decrease) in net assets		10,434,498			2,773,690			169,289			—
Net assets:
Beginning of the period		2,773,690			—			—			—
End of the period	$	13,208,188		$	2,773,690		$	169,289		$	—

See accompanying notes.

71

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Foxhall Global Growth VP SC Subaccount						Transamerica Foxhall Global Conservative VP SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(18,707	)	$	(186	)	$	(18,564	)	$	(43	)
Net realized capital gains (losses) on investments		5,171			1			(9,448	)		—
Net change in unrealized appreciation/depreciation of investments		168,935			2,419			(51,812	)		(320	)
Increase (decrease) in net assets from operations		155,399			2,234			(79,824	)		(363	)
Contract transactions
Net contract purchase payments		1,944,827			87,525			1,418,430			31,142
Transfer payments from (to) other subaccounts or general account		271,415			153,232			709,106			44,660
Contract terminations, withdrawals, and other deductions		(66,475	)		(195	)		(22,299	)		(100	)
Contract maintenance charges		(9,812	)		(13	)		(7,231	)		(41	)
Increase (decrease) in net assets from contract transactions		2,139,955			240,549			2,098,006			75,661
Net increase (decrease) in net assets		2,295,354			242,783			2,018,182			75,298
Net assets:
Beginning of the period		242,783			—			75,298			—
End of the period	$	2,538,137		$	242,783		$	2,093,480		$	75,298

See accompanying notes.

72

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Foxhall Global Hard Asset VP SC Subaccount						Transamerica Foxhall Emerging Markets/Pacific Rim VP  SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(22,098	)	$	(435	)	$	(24,703	)	$	(572	)
Net realized capital gains (losses) on investments		(2,827	)		(2	)		18,914			6
Net change in unrealized appreciation/depreciation of investments		186,815			2,432			197,249			11,842
Increase (decrease) in net assets from operations		161,890			1,995			191,460			11,276
Contract transactions
Net contract purchase payments		1,902,858			42,843			2,314,860			167,913
Transfer payments from (to) other subaccounts or general account		937,694			236,485			878,957			379,193
Contract terminations, withdrawals, and other deductions		(142,265	)		(99	)		(155,321	)		(100	)
Contract maintenance charges		(11,831	)		—			(15,147	)		—
Increase (decrease) in net assets from contract transactions		2,686,456			279,229			3,023,349			547,006
Net increase (decrease) in net assets		2,848,346			281,224			3,214,809			558,282
Net assets:
Beginning of the period		281,224			—			558,282			—
End of the period	$	3,129,570		$	281,224		$	3,773,091		$	558,282

See accompanying notes.

73

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Hanlon Growth VP SC Subaccount						Transamerica Hanlon Growth and Income VP SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(8,198	)	$	(100	)	$	(9,554	)	$	(57	)
Net realized capital gains (losses) on investments		(25,477	)		—			(5,888	)		1
Net change in unrealized appreciation/depreciation of investments		78,734			1,144			57,003			707
Increase (decrease) in net assets from operations		45,059			1,044			41,561			651
Contract transactions
Net contract purchase payments		2,181,600			319,784			1,879,678			141,353
Transfer payments from (to) other subaccounts or general account		239,317			117,045			172,683			20,542
Contract terminations, withdrawals, and other deductions		(117,772	)		(100	)		(53,610	)		(100	)
Contract maintenance charges		(12,639	)		—			(9,112	)		—
Increase (decrease) in net assets from contract transactions		2,290,506			436,729			1,989,639			161,795
Net increase (decrease) in net assets		2,335,565			437,773			2,031,200			162,446
Net assets:
Beginning of the period		437,773			—			162,446			—
End of the period	$	2,773,338		$	437,773		$	2,193,646		$	162,446

See accompanying notes.

74

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Hanlon Balanced VP SC Subaccount						Transamerica Hanlon Managed Income VP SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(12,616	)	$	(75	)	$	(131,289	)	$	(1,549	)
Net realized capital gains (losses) on investments		(4,101	)		184			35,650			3,714
Net change in unrealized appreciation/depreciation of investments		41,007			1,094			(89,664	)		251
Increase (decrease) in net assets from operations		24,290			1,203			(185,303	)		2,416
Contract transactions
Net contract purchase payments		1,980,710			105,100			14,552,753			910,535
Transfer payments from (to) other subaccounts or general account		406,306			(45,573	)		2,197,551			724,840
Contract terminations, withdrawals, and other deductions		(19,098	)		(100	)		(157,950	)		(100	)
Contract maintenance charges		(7,510	)		—			(66,387	)		—
Increase (decrease) in net assets from contract transactions		2,360,408			59,427			16,525,967			1,635,275
Net increase (decrease) in net assets		2,384,698			60,630			16,340,664			1,637,691
Net assets:
Beginning of the period		60,630			—			1,637,691			—
End of the period	$	2,445,328		$	60,630		$	17,978,355		$	1,637,691

See accompanying notes.

75

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica Index 35 VP SC Subaccount						Transamerica Index 100 VP SC Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(16,269	)	$	(28	)	$	(4,695	)	$	—
Net realized capital gains (losses) on investments		1,836			1			1,217			1
Net change in unrealized appreciation/depreciation of investments		101,525			(83	)		88,257			—
Increase (decrease) in net assets from operations		87,092			(110	)		84,779			1
Contract transactions
Net contract purchase payments		1,782,475			100			353,242			100
Transfer payments from (to) other subaccounts or general account		411,183			33,334			713,797			30,780
Contract terminations, withdrawals, and other deductions		(7,814	)		(101	)		(151	)		(101	)
Contract maintenance charges		(3,641	)		—			(608	)		—
Increase (decrease) in net assets from contract transactions		2,182,203			33,333			1,066,280			30,779
Net increase (decrease) in net assets		2,269,295			33,223			1,151,059			30,780
Net assets:
Beginning of the period		33,223			—			30,780			—
End of the period	$	2,302,518		$	33,223		$	1,181,839		$	30,780

See accompanying notes.

76

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Transamerica JP Morgan Midcap Value VP SC Subaccount						Invesco V.I. Basic Value Subaccount
	2010			2009(1)			2010			2009
Operations
Net investment income (loss)	$	6,991		$	(11	)	$	(110,044	)	$	(35,593	)
Net realized capital gains (losses) on investments		(263	)		1			(1,683,704	)		(1,578,465	)
Net change in unrealized appreciation/depreciation of investments		201,887			(179	)		2,082,373			3,875,299
Increase (decrease) in net assets from operations		208,615			(189	)		288,625			2,261,241
Contract transactions
Net contract purchase payments		399,804			100			168,667			369,503
Transfer payments from (to) other subaccounts or general account		1,194,773			28,685			(385,578	)		734,530
Contract terminations, withdrawals, and other deductions		(23,639	)		(101	)		(548,256	)		(964,186	)
Contract maintenance charges		(3,336	)		—			(44,082	)		(41,201	)
Increase (decrease) in net assets from contract transactions		1,567,602			28,684			(809,249	)		98,646
Net increase (decrease) in net assets		1,776,217			28,495			(520,624	)		2,359,887
Net assets:
Beginning of the period		28,495			—			7,686,357			5,326,470
End of the period	$	1,804,712		$	28,495		$	7,165,733		$	7,686,357

See accompanying notes.

77

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Invesco V.I. Capital Appreciation Subaccount						AllianceBernstein Growth and Income Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(27,773	)	$	(26,134	)	$	(215,341	)	$	192,980
Net realized capital gains (losses) on investments		(68,484	)		(185,046	)		(764,427	)		(1,141,026	)
Net change in unrealized appreciation/depreciation of investments		381,826			476,058			2,174,669			2,799,915
Increase (decrease) in net assets from operations		285,569			264,878			1,194,901			1,851,869
Contract transactions
Net contract purchase payments		485,534			176,753			638,270			266,068
Transfer payments from (to) other subaccounts or general account		(67,140	)		(176,035	)		(590,715	)		(284,694	)
Contract terminations, withdrawals, and other deductions		(75,340	)		(138,217	)		(963,392	)		(1,170,129	)
Contract maintenance charges		(11,179	)		(10,118	)		(62,971	)		(63,820	)
Increase (decrease) in net assets from contract transactions		331,875			(147,617	)		(978,808	)		(1,252,575	)
Net increase (decrease) in net assets		617,444			117,261			216,093			599,294
Net assets:
Beginning of the period		1,833,513			1,716,252			12,167,333			11,568,039
End of the period	$	2,450,957		$	1,833,513		$	12,383,426		$	12,167,333

See accompanying notes.

78

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	AllianceBernstein Large Cap Growth Subaccount						AllianceBernstein Balanced Wealth Strategy Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(86,673	)	$	(83,636	)	$	3,584		$	(13,629	)
Net realized capital gains (losses) on investments		53,366			(40,116	)		61,801			13,359
Net change in unrealized appreciation/depreciation of investments		461,404			1,494,500			150,132			286,062
Increase (decrease) in net assets from operations		428,097			1,370,748			215,517			285,792
Contract transactions
Net contract purchase payments		453,564			400,937			1,152,114			1,218,824
Transfer payments from (to) other subaccounts or general account		(249,733	)		580,842			318,287			332,398
Contract terminations, withdrawals, and other deductions		(414,843	)		(398,666	)		(42,479	)		(40,383	)
Contract maintenance charges		(31,175	)		(26,990	)		(18,147	)		(882	)
Increase (decrease) in net assets from contract transactions		(242,187	)		556,123			1,409,775			1,509,957
Net increase (decrease) in net assets		185,910			1,926,871			1,625,292			1,795,749
Net assets:
Beginning of the period		6,060,005			4,133,134			1,830,164			34,415
End of the period	$	6,245,915		$	6,060,005		$	3,455,456		$	1,830,164

See accompanying notes.

79

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Janus Aspen - Enterprise Subaccount						Janus Aspen - Perkins Mid Cap Value Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(98,762	)	$	(87,871	)	$	(12,938	)	$	(13,462	)
Net realized capital gains (losses) on investments		(248,797	)		(855,880	)		1,426			3,105
Net change in unrealized appreciation/depreciation of investments		1,579,451			2,665,786			145,400			263,438
Increase (decrease) in net assets from operations		1,231,892			1,722,035			133,888			253,081
Contract transactions
Net contract purchase payments		414,065			187,363			240			300
Transfer payments from (to) other subaccounts or general account		471,519			(395,195	)		(47,841	)		(26,925	)
Contract terminations, withdrawals, and other deductions		(484,791	)		(522,593	)		(100,745	)		(88,045	)
Contract maintenance charges		(31,245	)		(30,099	)		(5,527	)		(5,554	)
Increase (decrease) in net assets from contract transactions		369,548			(760,524	)		(153,873	)		(120,224	)
Net increase (decrease) in net assets		1,601,440			961,511			(19,985	)		132,857
Net assets:
Beginning of the period		5,433,128			4,471,617			1,103,793			970,936
End of the period	$	7,034,568		$	5,433,128		$	1,083,808		$	1,103,793

See accompanying notes.

80

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Janus Aspen - Worldwide Subaccount						MFS® New  Discovery Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(152,400	)	$	(47,918	)	$	(135,528	)	$	(76,517	)
Net realized capital gains (losses) on investments		(543,385	)		(581,488	)		533,474			(988,295	)
Net change in unrealized appreciation/depreciation of investments		2,166,976			3,095,281			1,874,114			2,994,143
Increase (decrease) in net assets from operations		1,471,191			2,465,875			2,272,060			1,929,331
Contract transactions
Net contract purchase payments		516,149			299,742			740,283			355,541
Transfer payments from (to) other subaccounts or general account		1,122,986			1,513,470			1,801,310			1,338,057
Contract terminations, withdrawals, and other deductions		(887,178	)		(583,116	)		(814,875	)		(257,293	)
Contract maintenance charges		(62,192	)		(52,055	)		(40,691	)		(23,369	)
Increase (decrease) in net assets from contract transactions		689,765			1,178,041			1,686,027			1,412,936
Net increase (decrease) in net assets		2,160,956			3,643,916			3,958,087			3,342,267
Net assets:
Beginning of the period		10,469,730			6,825,814			6,159,028			2,816,761
End of the period	$	12,630,686		$	10,469,730		$	10,117,115		$	6,159,028

See accompanying notes.

81

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	MFS® Total Return Subaccount						Fidelity VIP Contrafund Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	100,367		$	197,137		$	(277,680	)	$	(211,280	)
Net realized capital gains (losses) on investments		(530,223	)		(629,633	)		(2,535,471	)		(3,804,672	)
Net change in unrealized appreciation/depreciation of investments		1,470,935			2,376,530			7,938,729			12,749,774
Increase (decrease) in net assets from operations		1,041,079			1,944,034			5,125,578			8,733,822
Contract transactions
Net contract purchase payments		976,424			321,125			1,578,574			886,811
Transfer payments from (to) other subaccounts or general account		(424,335	)		403,652			473,649			(1,912,697	)
Contract terminations, withdrawals, and other deductions		(787,849	)		(1,008,467	)		(2,402,299	)		(2,308,219	)
Contract maintenance charges		(72,175	)		(71,175	)		(183,702	)		(176,011	)
Increase (decrease) in net assets from contract transactions		(307,935	)		(354,865	)		(533,778	)		(3,510,116	)
Net increase (decrease) in net assets		733,144			1,589,169			4,591,800			5,223,706
Net assets:
Beginning of the period		14,309,442			12,720,273			34,854,027			29,630,321
End of the period	$	15,042,586		$	14,309,442		$	39,445,827		$	34,854,027

See accompanying notes.

82

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Fidelity VIP Equity-Income Subaccount						Fidelity VIP Growth Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(24,313	)	$	21,892		$	(109,532	)	$	(88,229	)
Net realized capital gains (losses) on investments		(1,170,592	)		(2,643,512	)		(436,035	)		(640,726	)
Net change in unrealized appreciation/depreciation of investments		2,619,507			5,288,769			1,782,069			1,977,375
Increase (decrease) in net assets from operations		1,424,602			2,667,149			1,236,502			1,248,420
Contract transactions
Net contract purchase payments		387,770			305,434			212,353			164,526
Transfer payments from (to) other subaccounts or general account		(62,173	)		(905,764	)		668,838			918
Contract terminations, withdrawals, and other deductions		(1,301,773	)		(1,294,994	)		(497,244	)		(471,647	)
Contract maintenance charges		(67,581	)		(71,802	)		(35,233	)		(34,387	)
Increase (decrease) in net assets from contract transactions		(1,043,757	)		(1,967,126	)		348,714			(340,590	)
Net increase (decrease) in net assets		380,845			700,023			1,585,216			907,830
Net assets:
Beginning of the period		12,436,646			11,736,623			6,162,381			5,254,551
End of the period	$	12,817,491		$	12,436,646		$	7,747,597		$	6,162,381

See accompanying notes.

83

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Fidelity VIP Growth Opportunities Subaccount						Fidelity VIP Mid Cap Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(7,188	)	$	(5,745	)	$	(797,110	)	$	(541,187	)
Net realized capital gains (losses) on investments		8,843			(541	)		(1,337,787	)		(3,467,386	)
Net change in unrealized appreciation/depreciation of investments		81,611			141,844			13,118,933			16,225,354
Increase (decrease) in net assets from operations		83,266			135,558			10,984,036			12,216,781
Contract transactions
Net contract purchase payments		397			251			1,449,637			679,488
Transfer payments from (to) other subaccounts or general account		111			(11,135	)		(971,423	)		(2,107,622	)
Contract terminations, withdrawals, and other deductions		(31,305	)		(74,784	)		(3,748,045	)		(2,927,519	)
Contract maintenance charges		(2,049	)		(2,329	)		(243,309	)		(235,605	)
Increase (decrease) in net assets from contract transactions		(32,846	)		(87,997	)		(3,513,140	)		(4,591,258	)
Net increase (decrease) in net assets		50,420			47,561			7,470,896			7,625,523
Net assets:
Beginning of the period		412,731			365,170			44,623,830			36,998,307
End of the period	$	463,151		$	412,731		$	52,094,726		$	44,623,830

See accompanying notes.

84

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Fidelity VIP Value Strategies Subaccount						Fidelity VIP Balanced Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(214,076	)	$	(151,271	)	$	1,726		$	9,276
Net realized capital gains (losses) on investments		(1,664,376	)		(2,516,466	)		263,529			(123,724	)
Net change in unrealized appreciation/depreciation of investments		4,810,551			7,112,564			130,740			415,360
Increase (decrease) in net assets from operations		2,932,099			4,444,827			395,995			300,912
Contract transactions
Net contract purchase payments		437,130			362,737			959,787			738,638
Transfer payments from (to) other subaccounts or general account		110,576			648,338			174,437			346,403
Contract terminations, withdrawals, and other deductions		(1,204,713	)		(889,419	)		(250,646	)		(46,787	)
Contract maintenance charges		(75,915	)		(62,010	)		(19,803	)		(3,736	)
Increase (decrease) in net assets from contract transactions		(732,922	)		59,646			863,775			1,034,518
Net increase (decrease) in net assets		2,199,177			4,504,473			1,259,770			1,335,430
Net assets:
Beginning of the period		12,974,544			8,470,071			1,928,396			592,966
End of the period	$	15,173,721		$	12,974,544		$	3,188,166		$	1,928,396

See accompanying notes.

85

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Franklin Income Securities Subaccount						Mutual Shares Securities Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	375,742		$	263,498		$	(9,743	)	$	3,099
Net realized capital gains (losses) on investments		(202,935	)		(367,441	)		(31,264	)		(245,053	)
Net change in unrealized appreciation/depreciation of investments		761,075			1,511,159			329,963			670,037
Increase (decrease) in net assets from operations		933,882			1,407,216			288,956			428,083
Contract transactions
Net contract purchase payments		1,027,163			280,346			363,638			248,634
Transfer payments from (to) other subaccounts or general account		2,605,813			2,346,080			(158,856	)		1,186,274
Contract terminations, withdrawals, and other deductions		(348,517	)		(232,048	)		(204,087	)		(80,891	)
Contract maintenance charges		(39,548	)		(23,771	)		(16,822	)		(10,810	)
Increase (decrease) in net assets from contract transactions		3,244,911			2,370,607			(16,127	)		1,343,207
Net increase (decrease) in net assets		4,178,793			3,777,823			272,829			1,771,290
Net assets:
Beginning of the period		6,874,140			3,096,317			3,151,870			1,380,580
End of the period	$	11,052,933		$	6,874,140		$	3,424,699		$	3,151,870

See accompanying notes.

86

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	Templeton Foreign Securities Subaccount						Franklin Templeton VIP Founding Funds Allocation Subaccount
	2010			2009			2010			2009
Operations
Net investment income (loss)	$	(2,438	)	$	28,132		$	32,299		$	43,856
Net realized capital gains (losses) on investments		522,820			(1,037,843	)		134,157			15,352
Net change in unrealized appreciation/depreciation of investments		(106,277	)		1,996,024			343,965			391,788.00
Increase (decrease) in net assets from operations		414,105			986,313			510,421			450,996
Contract transactions
Net contract purchase payments		1,322,458			508,566			1,952,076			2,408,468
Transfer payments from (to) other subaccounts or general account		(129,298	)		4,170,529			1,261,094			558,517
Contract terminations, withdrawals, and other deductions		(838,560	)		(149,205	)		(223,788	)		(40,812	)
Contract maintenance charges		(49,049	)		(20,959	)		(51,476	)		(839.00	)
Increase (decrease) in net assets from contract transactions		305,551			4,508,931			2,937,906			2,925,334
Net increase (decrease) in net assets		719,656			5,495,244			3,448,327			3,376,330.00
Net assets:
Beginning of the period		8,227,367			2,732,123			3,376,330			—
End of the period	$	8,947,023		$	8,227,367		$	6,824,657		$	3,376,330

See accompanying notes.

87

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	American Funds – Asset Allocation Fund Subaccount						American Funds – Bond Fund Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	20,031		$	(14	)	$	41,159		$	51
Net realized capital gains (losses) on investments		15,487			1			25,070			—
Net change in unrealized appreciation/depreciation of investments		130,211			(28	)		(52,527	)		(116	)
Increase (decrease) in net assets from operations		165,729			(41	)		13,702			(65	)
Contract transactions
Net contract purchase payments		1,908,267			37,442			991,515			33,439
Transfer payments from (to) other subaccounts or general account		568,919			1,943			1,487,310			1,581
Contract terminations, withdrawals, and other deductions		(4,935	)		(101	)		(15,535	)		(100	)
Contract maintenance charges		(9,048	)		—			(9,349	)		—
Increase (decrease) in net assets from contract transactions		2,463,203			39,284			2,453,941			34,920
Net increase (decrease) in net assets		2,628,932			39,243			2,467,643			34,855
Net assets:
Beginning of the period		39,243			—			34,855			—
End of the period	$	2,668,175		$	39,243		$	2,502,498		$	34,855

See accompanying notes.

88

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	American Funds – Growth Fund Subaccount						American Funds – Growth – Income  Fund Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	(8,703	)	$	42		$	1,840		$	220
Net realized capital gains (losses) on investments		(2,037	)		—			(3,069	)		1
Net change in unrealized appreciation/depreciation of investments		205,317			(2,621	)		75,405			(41	)
Increase (decrease) in net assets from operations		194,577			(2,579	)		74,176			180
Contract transactions
Net contract purchase payments		926,357			308,455			682,670			21,800
Transfer payments from (to) other subaccounts or general account		348,958			19,944			146,758			4,782
Contract terminations, withdrawals, and other deductions		(15,001	)		(100	)		(4,628	)		(101	)
Contract maintenance charges		(8,661	)		—			(3,749	)		—
Increase (decrease) in net assets from contract transactions		1,251,653			328,299			821,051			26,481
Net increase (decrease) in net assets		1,446,230			325,720			895,227			26,661
Net assets:
Beginning of the period		325,720			—			26,661			—
End of the period	$	1,771,950		$	325,720		$	921,888		$	26,661

See accompanying notes.

89

Transamerica Life Insurance Company

Separate Account VA C

Statements of Changes in Net Assets

Years Ended December 31, 2010 and 2009, Except as Noted

	American Funds – International Fund Subaccount						GE Investments Total Return Fund Subaccount
	2010			2009(1)			2010			2009(1)
Operations
Net investment income (loss)	$	7,670		$	185		$	2,490		$	—
Net realized capital gains (losses) on investments		(7,622	)		(1	)		2,891			1
Net change in unrealized appreciation/depreciation of investments		116,512			(1,337	)		28,368			—
Increase (decrease) in net assets from operations		116,560			(1,153	)		33,749			1
Contract transactions
Net contract purchase payments		887,673			169,283			317,571			100
Transfer payments from (to) other subaccounts or general account		352,845			122,086			186,326			—
Contract terminations, withdrawals, and other deductions		(19,477	)		(101	)		—			(101	)
Contract maintenance charges		(7,217	)		—			(1,349	)		—
Increase (decrease) in net assets from contract transactions		1,213,824			291,268			502,548			(1	)
Net increase (decrease) in net assets		1,330,384			290,115			536,297			—
Net assets:
Beginning of the period		290,115			—			—			—
End of the period	$	1,620,499		$	290,115		$	536,297		$	—

See accompanying notes.

90

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

1. Organization and Summary of Significant Accounting Policies

Organization

Seperate Account VA C (the Separate Account) is a segregated investment account of Transamerica Life Insurance Company (TLIC), an indirect wholly owned subsidiary of AEGON N.V., a holding company organized under the laws of The Netherlands.

The Separate Account is registered with the Securities and Exchange Commission as a Unit Investment Trust pursuant to provisions of the Investment Company Act of 1940. The Separate Account consists of multiple investment subaccounts. Each subaccount invests exclusively in the corresponding portfolio of a Mutual Fund. Each Mutual Fund is registered as an open-end management investment company under the Investment Company Act of 1940, as amended. Activity in these specified investment subaccounts is available to contract owners of Transamerica Extra Variable Annuity.

The Transamerica U.S. Government Securities-Portfolio Asset Manager-Service Class (PAM Fund) and the Transamerica Profunds UltraBear-Open Allocation Method-Service Class (OAM Fund) are included in the Mutual Fund portfolio only to facilitate a contract owner purchase option.

Subaccount Investment by Mutual Fund:

Transamerica Series Trust - Initial Class

Transamerica Asset Allocation-Growth VP IC

Transamerica Asset Allocation-Conservative VP IC

Transamerica Asset Allocation-Moderate VP IC

Transamerica Asset Allocation-Moderate Growth VP IC

Transamerica MFS International Equity VP IC

Transamerica Clarion Global Real Estate Securities VP IC

Transamerica Diversified Equity VP IC

Transamerica Balanced VP IC

Transamerica Jennison Growth VP IC

Transamerica JPMorgan Enhanced Index VP IC

Transamerica AEGON High Yield Bond VP IC

Transamerica BlackRock Large Cap Value VP IC

Transamerica PIMCO Total Return VP IC

Transamerica Focus VP IC

Transamerica AllianceBernstein Dynamic Allocation VP IC

Transamerica WMC Diversified Growth VP IC

Transamerica Growth Opportunities VP IC

Transamerica U.S. Government Securities VP IC

Transamerica T. Rowe Price Small Cap VP IC

Transamerica Morgan Stanley Active International Allocation VP IC

Transamerica Multi Managed Large Cap Core VP IC

Transamerica Money Market VP IC

Transamerica Morgan Stanley Mid-Cap Growth VP IC

Transamerica Small/Mid Cap Value VP IC

Transamerica Series Trust - Service Class

Transamerica Asset Allocation-Growth VP SC

Transamerica Asset Allocation-Conservative VP SC

Transamerica Asset Allocation-Moderate VP SC

Transamerica Asset Allocation-Moderate Growth VP SC

Transamerica MFS International Equity VP SC

Transamerica Clarion Global Real Estate Securities VP SC

91

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

1. Organization and Summary of Significant Accounting Policies (continued)

Subaccount Investment by Mutual Fund: (continued)

Transamerica Series Trust - Service Class

Transamerica Diversified Equity VP SC

Transamerica Balanced VP SC

Transamerica Jennison Growth VP SC

Transamerica JPMorgan Enhanced Index VP SC

Transamerica AEGON High Yield Bond VP SC

Transamerica BlackRock Large Cap Value VP SC

Transamerica PIMCO Total Return VP SC

Transamerica Focus VP SC

Transamerica AllianceBernstein Dynamic Allocation VP SC

Transamerica WMC Diversified Growth VP SC

Transamerica Growth Opportunities VP SC

Transamerica U.S. Government Securities VP SC

Transamerica U.S. Government Securities VP PAM SC

Transamerica T. Rowe Price Small Cap VP SC

Transamerica Morgan Stanley Active International Allocation VP SC

Transamerica Multi Managed Large Cap Core VP SC

Transamerica Money Market VP SC

Transamerica Morgan Stanley Mid-Cap Growth VP SC

Transamerica Small/Mid Cap Value VP SC

Transamerica International Moderate Growth VP SC

Transamerica Efficient Markets VP SC

Transamerica Index 50 VP SC

Transamerica Index 75 VP SC

Transamerica BlackRock Global Allocation VP SC

Transamerica BlackRock Tactical Allocation VP SC

Transamerica ProFunds UltraBear Fund VP OAM SC

Transamerica Foxhall Global Growth VP SC

Transamerica Foxhall Global Conservative VP SC

Transamerica Foxhall Global Hard Asset VP SC

Transamerica Foxhall Emerging Markets/Pacific Rim VP SC

Transamerica Hanlon Growth VP SC

Transamerica Hanlon Growth and Income VP SC

Transamerica Hanlon Balanced VP SC

Transamerica Hanlon Managed Income VP SC

Transamerica Index 35 VP SC

Transamerica Index 100 VP SC

Transamerica JP Morgan Midcap Value VP SC

AIM Variable Insurance Funds (Invesco Variable Insurance Funds) -Series II Shares:

Invesco V.I. Basic Value Fund

Invesco V.I. Capital Appreciation Fund

92

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

1. Organization and Summary of Significant Accounting Policies (continued)

Subaccount Investment by Mutual Fund: (continued)

AllianceBernstein Variable Products Series Fund, Inc.-Class B:

AllianceBernstein Growth and Income Portfolio

AllianceBernstein Large Cap Growth Portfolio

AllianceBernstein Balanced Wealth Strategy Portfolio

Janus Aspen Series-Service Shares:

Janus Aspen - Enterprise Portfolio

Janus Aspen - Perkins Mid Cap Value Portfolio

Janus Aspen - Worldwide Portfolio

MFS^® Variable Insurance Trust - Service Class

MFS^® New Discovery Series

MFS^® Total Return Series

Fidelity^® Variable Insurance Products Fund - Service Class 2

Fidelity VIP Contrafund Portfolio

Fidelity VIP Equity-Income Portfolio

Fidelity VIP Growth Portfolio

Fidelity VIP Growth Opportunities Portfolio

Fidelity VIP Mid Cap Portfolio

Fidelity VIP Value Strategies Portfolio

Fidelity VIP Balanced Portfolio

Franklin Templeton Variable Insurance Products Trust - Class 2

Franklin Income Securities Fund

Mutual Shares Securities Fund

Templeton Foreign Securities Fund

Franklin Templeton Variable Insurance Products Trust - Class 4

Franklin Templeton VIP Founding Funds Allocation Fund

American Funds Insurance Series Trust - Class 2:

American Funds Asset Allocation Fund (Class 2)

American Funds Bond Fund (Class 2)

American Funds Growth Fund (Class 2)

American Funds Growth - Income Fund (Class 2)

American Funds International Fund (Class 2)

GE Investments Funds, Inc. - Class 3

GE Investments Total Return Fund - Class 3

Each period reported on reflects a full twelve month period except as follows:

Subaccount	Inception Date
Transamerica International Moderate Growth VP	May 1, 2006
Franklin Income Securities Fund	May 1, 2007
Mutual Shares Securities Fund	May 1, 2007
Templeton Foreign Securities Fund	May 1, 2007
Transamerica Index 50 VP	May 1, 2008
Transamerica Index 75 VP	May 1, 2008
Fidelity VIP Balanced	May 1, 2008
Transamerica Efficient Markets VP	November 10, 2008

93

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

1. Organization and Summary of Significant Accounting Policies (continued)

    Each period reported on reflects a full twelve month period except as follows: (continued)

Subaccount	Inception Date
AllianceBernstein Balanced Wealth Strategy Portfolio	November 10, 2008
Franklin Templeton VIP Founding Funds Allocation	November 10, 2008
Transamerica BlackRock Global Allocation VP SC	May 1, 2009
Transamerica BlackRock Tactical Allocation VP SC	May 1, 2009
Transamerica ProFunds UltraBear Fund VP OAM SC	May 1, 2009
Transamerica Foxhall Global Growth VP SC	November 19, 2009
Transamerica Foxhall Global Conservative VP SC	November 19, 2009
Transamerica Foxhall Global Hard Asset VP SC	November 19, 2009
Transamerica Foxhall Emerging Markets/Pacific Rim VP SC	November 19, 2009
Transamerica Hanlon Growth VP SC	November 19, 2009
Transamerica Hanlon Growth and Income VP SC	November 19, 2009
Transamerica Hanlon Balanced VP SC	November 19, 2009
Transamerica Hanlon Managed Income VP SC	November 19, 2009
Transamerica Index 35 VP SC	November 19, 2009
Transamerica Index 100 VP SC	November 19, 2009
Transamerica JP Morgan Midcap Value VP SC	November 19, 2009
American Funds – Asset Allocation Fund	November 19, 2009
American Funds – Bond Fund	November 19, 2009
American Funds – Growth Fund	November 19, 2009
American Funds – Growth – Income Fund	November 19, 2009
American Funds – International Fund	November 19, 2009
GE Investments Total Return Fund	November 19, 2009

The following Portfolio name changes were made effective during the fiscal year ended December 31, 2010

Portfolio	Formerly
Transamerica WMC Diversified Growth VP	Transamerica Equity VP
Transamerica Morgan Stanley Active International Allocation VP	Transamerica Van Kampen Active International Allocation VI
Transamerica Multi Managed Large Cap Core VP	Transamerica Van Kampen Large Cap Core VP
Transamerica Morgan Stanley Mid-Cap Growth VP	Transamerica Van Kampen Mid Cap Growth VP
Transamerica Diversified Equity VP	Transamerica Templeton Global VP
Invesco V.I. Basic Value Fund	AIM V.I. Basic Value Fund
Invesco V.I. Capital Appreciation Fund	AIM V.I. Capital Appreciation Fund
Transamerica AllianceBernstein Dynamic Allocation VP	Transamerica Convertible Securities VP

The following Portfolio mergers were made effective during the fiscal year ended December 31, 2010

Portfolio	Formerly
Transamerica Diversified Equity VP	Transamerica Science & Technology VP
Transamerica BlackRock Large Cap Value VP	Transamerica American Century Large Company Value VP
Transamerica BlackRock Large Cap Value VP	Transamerica T. Rowe Price Equity Income VP
Transamerica Jennison Growth VP	Transamerica Marsico Growth VP
Transamerica Jennison Growth VP	Transamerica T. Rowe Price Growth Stock VP
Transamerica Balanced VP	Transamerica Value Balanced VP

94

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

1. Organization and Summary of Significant Accounting Policies (continued)

Investments

Net purchase payments received by the Separate Account are invested in the portfolios of the Mutual Funds as selected by the contract owner. Investments are stated at the closing net asset values per share on December 31, 2010.

Realized capital gains and losses from sales of shares in the Separate Account are determined on the first-in, first-out basis. Investment transactions are accounted for on the trade date (date the order to buy or sell is executed) and dividend income is recorded on the ex-dividend date. Unrealized gains or losses from investments in the Mutual Funds are included in the Statements of Operations.

Dividend Income

Dividends received from the Mutual Fund investments are reinvested to purchase additional mutual fund shares.

Accounting Policy

On July 1, 2009, the FASB Accounting Standards Codification^TM (ASC or the Codification) was launched as the single source of authoritative nongovernmental accounting principles generally accepted in the United States (GAAP). Guidance in the Codification is organized by Topic, each representing a collection of related guidance (e.g., Financial Services—Insurance). Topics are further subdivided into Subtopics (e.g., Insurance Activities), and Sections (e.g., Recognition, Measurement, or Disclosure). All guidance contained in the Codification carries an equal level of authority. The Separate Account adopted guidance that establishes the Codification as the source of authoritative GAAP for the period ended September 30, 2009. The adoption required updates to the Separate Account’s financial statement disclosures, but did not impact the results of operations or financial position.

As of December 31, 2009 the Separate Account adopted ASC 855, Subsequent Events, which establishes general standards of accounting for and disclosure of events that occur after the balance sheet date but before financial statements are issued or are available to be issued. See Note 9 to the financial statements for additional disclosure.

The financial statements included herein have been prepared in accordance with GAAP for variable annuity separate accounts registered as unit investment trusts. The preparation of the financial statements in conformity with GAAP requires management to make estimates and assumptions regarding matters that affect the reported amount of assets and liabilities. Actual results could differ from those estimates.

95

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

2. Investments

The aggregate cost of purchases and proceeds from sales of investments for the period ended December 31, 2010 were as follows:

	Purchases		Sales
Transamerica Series Trust - Initial Class
Transamerica Asset Allocation-Growth VP IC	$	7,586,309	$	16,814,702
Transamerica Asset Allocation-Conservative VP IC		15,407,075		18,059,517
Transamerica Asset Allocation-Moderate VP IC		18,367,445		28,544,790
Transamerica Asset Allocation-Moderate Growth VP IC		15,481,376		26,619,129
Transamerica MFS International Equity VP IC		2,397,794		5,109,603
Transamerica Clarion Global Real Estate Securities VP IC		2,487,153		3,227,310
Transamerica Diversified Equity VP IC		7,447,435		4,497,647
Transamerica Balanced VP IC		1,641,263		2,174,694
Transamerica Jennison Growth VP IC		22,979,269		5,430,868
Transamerica JPMorgan Enhanced Index VP IC		1,583,599		2,529,770
Transamerica AEGON High Yield Bond VP IC		12,944,733		12,457,496
Transamerica BlackRock Large Cap Value VP IC		40,633,956		10,758,928
Transamerica PIMCO Total Return VP IC		17,216,080		18,336,731
Transamerica Focus VP IC		2,040,909		2,908,358
Transamerica AllianceBernstein Dynamic Allocation VP IC		2,478,855		3,566,257
Transamerica WMC Diversified Growth VP IC		2,758,907		6,279,475
Transamerica Growth Opportunities VP IC		1,748,460		2,269,075
Transamerica U.S. Government Securities VP IC		8,299,062		12,300,024
Transamerica T. Rowe Price Small Cap VP IC		3,468,221		3,961,033
Transamerica Morgan Stanley Active International Allocation VP IC		1,800,091		4,254,807
Transamerica Multi Managed Large Cap Core VP IC		1,189,362		4,276,117
Transamerica Money Market VP IC		35,666,372		34,871,191
Transamerica Morgan Stanley Mid-Cap Growth VP IC		2,945,249		2,195,024
Transamerica Small/Mid Cap Value VP IC		666,920		3,399,713
Transamerica Series Trust - Service Class
Transamerica Asset Allocation-Growth VP SC		2,318,309		1,987,218
Transamerica Asset Allocation-Conservative VP SC		12,599,419		6,140,774
Transamerica Asset Allocation-Moderate VP SC		18,523,310		8,617,506
Transamerica Asset Allocation-Moderate Growth VP SC		19,917,023		10,608,364
Transamerica MFS International Equity VP SC		726,656		343,176
Transamerica Clarion Global Real Estate Securities VP SC		1,265,136		302,754
Transamerica Diversified Equity VP SC		1,951,093		504,166
Transamerica Balanced VP SC		3,794,059		967,049
Transamerica Jennison Growth VP SC		2,784,146		600,685
Transamerica JPMorgan Enhanced Index VP SC		207,408		192,677

96

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

2. Investments (continued)

	Purchases		Sales
Transamerica Series Trust - Service Class
Transamerica AEGON High Yield Bond VP SC	$	5,604,364	$	4,293,096
Transamerica BlackRock Large Cap Value VP SC		3,468,388		721,044
Transamerica PIMCO Total Return VP SC		17,355,912		6,501,971
Transamerica Focus VP SC		314,355		130,995
Transamerica AllianceBernstein Dynamic Allocation VP SC		1,502,135		314,652
Transamerica WMC Diversified Growth VP SC		923,865		273,486
Transamerica Growth Opportunities VP SC		635,184		225,802
Transamerica U.S. Government Securities VP SC		15,824,697		10,289,463
Transamerica U.S. Government Securities VP PAM SC		3,127,333		5,472,214
Transamerica T. Rowe Price Small Cap VP SC		1,397,874		390,915
Transamerica Morgan Stanley Active International Allocation VP SC		499,953		414,866
Transamerica Multi Managed Large Cap Core VP SC		457,781		135,919
Transamerica Money Market VP SC		17,042,698		20,205,807
Transamerica Morgan Stanley Mid-Cap Growth VP SC		1,166,282		280,064
Transamerica Small/Mid Cap Value VP SC		2,030,072		303,386
Transamerica International Moderate Growth VP SC		5,354,848		3,755,041
Transamerica Efficient Markets VP SC		1,388,042		98,182
Transamerica Index 50 VP SC		3,630,603		1,929,885
Transamerica Index 75 VP SC		5,646,300		1,422,383
Transamerica BlackRock Global Allocation VP SC		22,569,939		1,142,832
Transamerica BlackRock Tactical Allocation VP SC		10,719,921		1,117,938
Transamerica ProFunds UltraBear Fund VP OAM SC		3,012,746		2,505,025
Transamerica Foxhall Global Growth VP SC		2,518,883		384,297
Transamerica Foxhall Global Conservative VP SC		2,309,329		228,947
Transamerica Foxhall Global Hard Asset VP SC		2,958,325		288,216
Transamerica Foxhall Emerging Markets/Pacific Rim VP SC		3,262,248		247,255
Transamerica Hanlon Growth VP SC		2,788,797		491,738
Transamerica Hanlon Growth and Income VP SC		2,298,954		313,426
Transamerica Hanlon Balanced VP SC		2,491,770		141,223
Transamerica Hanlon Managed Income VP SC		17,252,117		820,903
Transamerica Index 35 VP SC		2,220,749		54,809
Transamerica Index 100 VP SC		1,194,817		133,199
Transamerica JP Morgan Midcap Value VP SC		1,830,667		256,068
AIM Variable Insurance Funds (Invesco Variable Insurance Funds) -Series II Shares:
Invesco V.I. Basic Value Fund		861,245		1,780,053
Invesco V.I. Capital Appreciation Fund		577,664		273,565
AllianceBernstein Variable Products Series Fund, Inc.-Class B:
AllianceBernstein Growth and Income Portfolio		775,951		1,970,054
AllianceBernstein Large Cap Growth Portfolio		1,016,614		1,345,129
AllianceBernstein Balanced Wealth Strategy Portfolio		1,654,680		241,326

97

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

2. Investments (continued)

	Purchases		Sales
Janus Aspen Series-Service Shares:
Janus Aspen - Enterprise Portfolio	$	1,554,404	$	1,283,622
Janus Aspen - Perkins Mid Cap Value Portfolio		81,049		247,865
Janus Aspen - Worldwide Portfolio		2,369,933		1,832,064
MFS® Variable Insurance Trust - Service Class
MFS® New Discovery Series		4,823,048		3,271,674
MFS® Total Return Series		2,492,758		2,699,973
Fidelity® Variable Insurance Products Fund - Service Class 2
Fidelity VIP Contrafund Portfolio		4,716,774		5,511,015
Fidelity VIP Equity-Income Portfolio		1,173,227		2,241,290
Fidelity VIP Growth Portfolio		1,557,739		1,297,550
Fidelity VIP Growth Opportunities Portfolio		2,153		42,179
Fidelity VIP Mid Cap Portfolio		3,378,427		7,534,911
Fidelity VIP Value Strategies Portfolio		2,062,496		3,009,153
Fidelity VIP Balanced Portfolio		1,812,606		931,673
Franklin Templeton Variable Insurance Products Trust - Class 2
Franklin Income Securities Fund		6,045,507		2,424,861
Mutual Shares Securities Fund		1,011,111		1,036,977
Templeton Foreign Securities Fund		5,378,790		5,075,683
Franklin Templeton Variable Insurance Products Trust - Class 4
Franklin Templeton VIP Founding Funds Allocation Fund		3,373,982		403,278
American Funds Insurance Series Trust - Class 2:
American Funds Asset Allocation Fund (Class 2)		2,976,431		493,191
American Funds Bond Fund (Class 2)		3,076,558		581,454
American Funds Growth Fund (Class 2)		1,419,397		176,443
American Funds Growth - Income Fund (Class 2)		878,696		55,805
American Funds International Fund (Class 2)		1,385,871		164,377
GE Investments Funds, Inc. - Class 3
GE Investments Total Return Fund - Class 3		589,942		84,902

98

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica Asset Allocation-Growth VP			Transamerica Asset Allocation-Conservative VP			Transamerica Asset Allocation-Moderate VP			Transamerica Asset Allocation-Moderate Growth VP			Transamerica MFS International Equity VP
	Subaccount			Subaccount			Subaccount			Subaccount			Subaccount
Units outstanding at January 1, 2009		84,782,199			84,469,745			171,374,425			235,874,248			16,673,173
Units purchased		2,481,886			8,134,251			16,359,490			26,484,743			617,412
Units redeemed and transferred to/from		(4,050,891	)		11,054,899			(3,718,544	)		(17,311,422	)		(2,771,636	)
Units outstanding at December 31, 2009		83,213,194			103,658,895			184,015,371			245,047,569			14,518,949
Units purchased		2,759,087			6,687,110			16,413,268			19,908,953			594,026
Units redeemed and transferred to/from		(9,934,368	)		(3,857,414	)		(15,409,890	)		(18,394,073	)		(2,562,281	)
Units outstanding at December 31, 2010		76,037,913			106,488,591			185,018,749			246,562,449			12,550,694

99

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica Clarion Global Real Estate Securities VP			Transamerica Small/Mid Cap Value VP			Transamerica Balanced VP			Transamerica Diversified Equity VP		Transamerica Jennison Growth VP
	Subaccount			Subaccount			Subaccount			Subaccount		Subaccount
Units outstanding at January 1, 2009		8,408,771			10,134,682			8,425,908			4,503,874		5,367,267
Units purchased		419,497			835,659			1,061,681			523,896		148,311
Units redeemed and transferred to/from		(1,391,983	)		(1,556,175	)		(1,203,775	)		18,197,207		(62,796	)
Units outstanding at December 31, 2009		7,436,285			9,414,166			8,283,814			23,224,977		5,452,782
Units purchased		1,026,087			1,582,960			1,308,842			1,713,661		957,517
Units redeemed and transferred to/from		(661,912	)		(134,893	)		1,365,313			2,889,711		21,620,075
Units outstanding at December 31, 2010		7,800,460			10,862,233			10,957,969			27,828,349		28,030,374

100

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica JPMorgan Enhanced Index VP Subaccount			Transamerica AEGON High Yield Bond VP Subaccount			Transamerica BlackRock Large Cap Value VP Subaccount		Transamerica PIMCO Total Return VP Subaccount			Transamerica Focus VP Subaccount
Units outstanding at January 1, 2009		11,567,877			13,414,744			15,701,666		50,391,182			20,090,397
Units purchased		258,717			463,858			1,013,671		3,329,698			275,032
Units redeemed and transferred to/from		269,096			6,503,096			16,884,228		7,053,444			(2,598,470	)
Units outstanding at December 31, 2009		12,095,690			20,381,698			33,599,565		60,774,324			17,766,959
Units purchased		245,788			1,176,786			2,678,231		9,043,951			410,538
Units redeemed and transferred to/from		(1,289,137	)		(2,260,730	)		23,333,563		(1,418,961	)		(263,667	)
Units outstanding at December 31, 2010		11,052,341			19,297,754			59,611,359		68,399,314			17,913,830

101

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica AllianceBernstein Dynamic Allocation VP Subaccount			Transamerica WMC Diversified Growth VP Subaccount			Transamerica Growth Opportunities VP Subaccount			Transamerica U.S. Government Securities VP Subaccount			Transamerica U.S. Government Securities VP PAM SC Subaccount
Units outstanding at January 1, 2009		7,476,369			39,480,791			9,053,807			34,588,532			12,013,695
Units purchased		172,330			649,048			203,114			3,752,625			—
Units redeemed and transferred to/from		(869,058	)		(5,729,623	)		(504,644	)		(4,073,839	)		(5,621,741	)
Units outstanding at December 31, 2009		6,779,641			34,400,216			8,752,277			34,267,318			6,391,954
Units purchased		1,315,201			3,135,230			456,649			14,653,959			—
Units redeemed and transferred to/from		(1,064,525	)		(5,627,478	)		(359,383	)		(13,775,570	)		(2,199,197	)
Units outstanding at December 31, 2010		7,030,317			31,907,968			8,849,543			35,145,707			4,192,757

102

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica Money Market VP Subaccount			Transamerica T. Rowe Price Small Cap VP Subaccount			Transamerica Morgan Stanley Active International Allocation VP Subaccount			Transamerica Multi Managed Large Cap Core VP Subaccount			Transamerica Morgan Stanley Mid-Cap Growth VP Subaccount
Units outstanding at January 1, 2009		90,642,027			16,810,166			18,534,286			10,351,994			9,588,179
Units purchased		10,078,603			420,049			332,253			853,752			456,968
Units redeemed and transferred to/from		(44,675,984	)		(1,700,881	)		(4,898,969	)		13,219,514			(123,230	)
Units outstanding at December 31, 2009		56,044,646			15,529,334			13,967,570			24,425,260			9,921,917
Units purchased		10,106,749			813,222			796,113			576,436			883,392
Units redeemed and transferred to/from		(11,235,081	)		(476,772	)		(2,855,482	)		(3,149,052	)		561,376
Units outstanding at December 31, 2010		54,916,314			15,865,784			11,908,201			21,852,644			11,366,685

103

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica International Moderate Growth VP SC Subaccount			Transamerica Efficient Markets VP SC Subaccount		Transamerica Index 50 VP SC Subaccount			Transamerica Index 75 VP SC Subaccount		Transamerica BlackRock Global Allocation VP SC Subaccount(1)
Units outstanding at January 1, 2009		23,659,772			—		302,454			2,111,913		—
Units purchased		4,916,344			770,978		2,575,977			8,256,288		5,373,456
Units redeemed and transferred to/from		(166,552	)		458,637		729,025			1,004,221		2,135,841
Units outstanding at December 31, 2009		28,409,564			1,229,615		3,607,456			11,372,422		7,509,297
Units purchased		4,465,998			640,267		2,291,936			3,765,656		13,212,640
Units redeemed and transferred to/from		(2,868,278	)		386,440		(542,880	)		892,417		4,591,554
Units outstanding at December 31, 2010		30,007,284			2,256,322		5,356,512			16,030,495		25,313,491

104

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica BlackRock Tactical Allocation VP SC Subaccount(1)		Transamerica ProFunds UltraBear Fund VP OAM SC Subaccount(1)			Transamerica Foxhall Global Growth VP SC Subaccount(1)			Transamerica Foxhall Global Conservative VP SC Subaccount(1)		Transamerica Foxhall Global Hard Asset VP SC Subaccount(1)
Units outstanding at January 1, 2009		—		—			—			—		—
Units purchased		1,289,336		3			92,429			33,153		45,992
Units redeemed and transferred to/from		1,031,721		(3	)		148,870			43,419		239,383
Units outstanding at December 31, 2009		2,321,057		—			241,299			76,572		285,375
Units purchased		2,960,933		—			2,246,792			1,774,104		2,237,378
Units redeemed and transferred to/from		5,152,940		418,637			(54,400	)		455,599		609,412
Units outstanding at December 31, 2010		10,434,930		418,637			2,433,691			2,306,275		3,132,165

105

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica Foxhall Emerging Markets/Pacific Rim VP SC		Transamerica Hanlon Growth VP SC			Transamerica Hanlon Growth and Income VP SC			Transamerica Hanlon Balanced VP SC			Transamerica Hanlon Managed Income VP SC
	Subaccount(1)		Subaccount(1)			Subaccount(1)			Subaccount(1)			Subaccount(1)
Units outstanding at January 1, 2009		—		—			—			—			—
Units purchased		177,843		329,392			146,155			110,579			953,110
Units redeemed and transferred to/from		375,466		99,331			12,759			(51,167	)		678,960
Units outstanding at December 31, 2009		553,309		428,723			158,914			59,412			1,632,070
Units purchased		2,673,629		2,390,458			2,091,562			2,241,902			15,449,114
Units redeemed and transferred to/from		451,432		(37,851	)		(21,128	)		222,651			1,115,927
Units outstanding at December 31, 2010		3,678,370		2,781,330			2,229,348			2,523,965			18,197,111

106

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Transamerica Index 35 VP SC		Transamerica Index 100 VP SC		Transamerica JP Morgan Midcap Value VP SC		Invesco V.I. Basic Value			Invesco V.I. Capital Appreciation
	Subaccount(1)		Subaccount(1)		Subaccount(1)		Subaccount			Subaccount
Units outstanding at January 1, 2009		—		—		—		9,196,537			2,398,956
Units purchased		106		105		107		1,179,543			249,708
Units redeemed and transferred to/from		33,181		29,965		27,575		(1,179,327	)		(463,143	)
Units outstanding at December 31, 2009		33,287		30,070		27,682		9,196,753			2,185,521
Units purchased		1,841,541		334,036		385,584		278,611			680,657
Units redeemed and transferred to/from		269,439		663,129		1,040,259		(1,304,476	)		(234,647	)
Units outstanding at December 31, 2010		2,144,267		1,027,235		1,453,525		8,170,888			2,631,531

107

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	AllianceBernstein Growth and Income			AllianceBernstein Large Cap Growth			AllianceBernstein Balanced Wealth Strategy		Janus Aspen - Enterprise			Janus Aspen - Perkins Mid Cap Value
	Subaccount			Subaccount			Subaccount		Subaccount			Subaccount
Units outstanding at January 1, 2009		15,621,504			6,897,289			33,981		9,342,076			978,727
Units purchased		379,149			534,112			1,233,558		343,513			292
Units redeemed and transferred to/from		(2,037,860	)		(98,846	)		214,029		(1,745,423	)		(127,389	)
Units outstanding at December 31, 2009		13,962,793			7,332,555			1,481,568		7,940,166			851,630
Units purchased		1,021,067			598,229			960,181		495,711			190
Units redeemed and transferred to/from		(2,084,036	)		(954,662	)		145,869		(1,029,559	)		(120,225	)
Units outstanding at December 31, 2010		12,899,824			6,976,122			2,587,618		7,406,318			731,595

108

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Janus Aspen - Worldwide			MFS® New Discovery		MFS® Total Return			Fidelity VIP Contrafund			Fidelity VIP Equity- Income
	Subaccount			Subaccount		Subaccount			Subaccount			Subaccount
Units outstanding at January 1, 2009		13,174,272			4,069,393		13,055,752			33,189,212			15,071,112
Units purchased		461,579			378,329		406,886			1,173,774			428,090
Units redeemed and transferred to/from		911,862			1,124,293		(702,649	)		(4,624,872	)		(2,941,232	)
Units outstanding at December 31, 2009		14,547,713			5,572,015		12,759,989			29,738,114			12,557,970
Units purchased		745,441			699,349		1,123,484			2,201,282			476,407
Units redeemed and transferred to/from		(281,619	)		586,086		(1,255,376	)		(2,491,766	)		(1,428,554	)
Units outstanding at December 31, 2010		15,011,535			6,857,450		12,628,097			29,447,630			11,605,823

109

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Fidelity VIP Growth			Fidelity VIP Growth Opportunities			Fidelity VIP Mid Cap			Fidelity VIP Value Strategies			Fidelity VIP Balanced
	Subaccount			Subaccount			Subaccount			Subaccount			Subaccount
Units outstanding at January 1, 2009		8,889,501			854,771			28,955,061			11,622,227			891,854
Units purchased		341,682			2,080			778,621			456,219			930,224
Units redeemed and transferred to/from		(928,978	)		(181,067	)		(3,972,954	)		(429,640	)		315,521
Units outstanding at December 31, 2009		8,302,205			675,784			25,760,728			11,648,806			2,137,599
Units purchased		290,696			3,008			1,527,643			568,651			1,080,817
Units redeemed and transferred to/from		(82,580	)		(84,006	)		(2,747,166	)		(1,117,926	)		(169,980	)
Units outstanding at December 31, 2010		8,510,321			594,786			24,541,205			11,099,531			3,048,436

110

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	Franklin Income Securities		Mutual Shares Securities			Templeton Foreign Securities			Franklin Templeton VIP Founding Funds Allocation		American Funds – Asset Allocation Fund
	Subaccount		Subaccount			Subaccount			Subaccount		Subaccount(1)
Units outstanding at January 1, 2009		4,618,240		2,324,077			4,381,951			—		—
Units purchased		350,653		348,882			638,885			2,312,644		39,042
Units redeemed and transferred to/from		2,714,705		1,567,681			4,753,038			360,437		(105	)
Units outstanding at December 31, 2009		7,683,598		4,240,640			9,773,874			2,673,081		38,937
Units purchased		1,138,762		445,732			1,626,296			1,636,242		1,958,760
Units redeemed and transferred to/from		2,246,113		(529,484	)		(1,497,922	)		682,837		403,590
Units outstanding at December 31, 2010		11,068,473		4,156,888			9,902,248			4,992,160		2,401,287

111

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

Years Ended December 31, 2010 and 2009, Except as Noted, continued

3. Accumulation Units Outstanding

A summary of changes in equivalent accumulation units outstanding follows:

	American Funds – Bond Fund			American Funds – Growth Fund		American Funds – Growth – Income Fund		American Funds – International Fund		GE Investments Total Return Fund
	Subaccount(1)			Subaccount(1)		Subaccount(1)		Subaccount(1)		Subaccount(1)
Units outstanding at January 1, 2009		—			—		—		—		—
Units purchased		35,188			321,297		22,969		181,139		105
Units redeemed and transferred to/from		(104	)		3,507		3,480		114,814		(105	)
Units outstanding at December 31, 2009		35,084			324,804		26,449		295,953		—
Units purchased		998,307			965,545		712,589		1,024,800		336,266
Units redeemed and transferred to/from		1,380,053			228,738		98,290		251,864		161,826
Units outstanding at December 31, 2010		2,413,444			1,519,087		837,328		1,572,617		498,092

112

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights

The Separate Account offers various death benefit options, which have differing fees that are charged against the contract owner’s account balance. These charges are discussed in more detail in the individual’s policy. Differences in the fee structures for these units result in different unit values, expense ratios, and total returns.

Subaccount	Year Ended		Units		Unit Fair  Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica Asset Allocation-Growth VP
		12/31/2010		76,037,913	$	1.34	to	$	1.29	$	98,565,799		1.03	%		1.55	%	to	2.00	%		13.20	%	to	12.70	%
		12/31/2009		83,213,194		1.18	to		1.14		95,997,089		2.76			1.55		to	2.00			27.84		to	27.27
		12/31/2008		84,782,199		0.92	to		0.90		77,158,683		2.74			1.55		to	2.00			(40.56	)	to	(40.82	)
		12/31/2007		100,219,250		1.56	to		1.52		154,531,725		2.22			1.55		to	2.00			6.10		to	5.63
		12/31/2006		108,310,384		1.47	to		1.44		157,927,539		0.92			1.55		to	2.00			13.86		to	13.36
Transamerica Asset Allocation-Conservative VP
		12/31/2010		106,488,591		1.41	to		1.03		136,874,688		3.26			1.55		to	2.30			7.27		to	6.26
		12/31/2009		103,658,895		1.31	to		0.97		126,313,597		4.30			1.55		to	2.30			23.32		to	22.10
		12/31/2008		84,469,745		1.06	to		0.79		86,275,352		3.12			1.55		to	2.00			(22.39	)	to	(22.73	)
		12/31/2007		72,295,993		1.37	to		1.34		97,664,334		3.00			1.55		to	2.00			4.75		to	4.29
		12/31/2006		75,728,948		1.31	to		1.28		97,837,237		3.37			1.55		to	2.00			7.78		to	7.30
Transamerica Asset Allocation-Moderate VP
		12/31/2010		185,018,749		1.43	to		1.01		241,460,593		2.94			1.55		to	2.30			8.69		to	7.66
		12/31/2009		184,015,371		1.31	to		0.94		225,867,937		4.36			1.55		to	2.30			24.47		to	23.36
		12/31/2008		171,374,425		1.05	to		0.76		173,519,292		3.35			1.55		to	2.30			(27.10	)	to	(27.42	)
		12/31/2007		175,831,316		1.44	to		1.41		252,159,405		2.84			1.55		to	2.00			6.30		to	5.83
		12/31/2006		205,097,947		1.36	to		1.33		276,459,608		2.57			1.55		to	2.00			9.78		to	9.30
Transamerica Asset Allocation-Moderate Growth VP
		12/31/2010		246,562,449		1.40	to		0.98		310,014,122		2.12			1.55		to	2.30			11.01		to	9.88
		12/31/2009		245,047,569		1.26	to		0.89		283,743,710		3.30			1.55		to	2.30			26.20		to	24.99
		12/31/2008		235,874,248		1.00	to		0.71		224,425,116		3.00			1.55		to	2.30			(33.79	)	to	(34.09	)
		12/31/2007		222,070,244		1.51	to		1.48		338,874,691		2.27			1.55		to	2.00			6.16		to	5.69
		12/31/2006		235,737,495		1.43	to		1.40		336,544,822		1.57			1.55		to	2.00			12.10		to	11.61
Transamerica MFS International Equity VP
		12/31/2010		12,550,694		1.16	to		1.39		15,537,969		1.36			1.55		to	2.00			8.81		to	8.33
		12/31/2009		14,518,949		1.07	to		1.28		16,751,443		2.83			1.55		to	2.00			30.66		to	30.08
		12/31/2008		16,673,173		0.82	to		0.98		14,780,265		5.10			1.55		to	2.00			(36.28	)	to	(36.57	)
		12/31/2007		20,986,931		1.29	to		1.55		29,408,340		0.89			1.55		to	2.00			7.48		to	7.00
		12/31/2006		25,409,463		1.20	to		1.45		33,204,131		1.36			1.55		to	2.00			21.20		to	20.66
Transamerica Clarion Global Real Estate Securities VP
		12/31/2010		7,800,460		1.98	to		1.91		13,599,262		6.49			1.55		to	2.00			13.90		to	13.40
		12/31/2009		7,436,285		1.74	to		1.68		12,311,146		—			1.55		to	2.00			31.38		to	30.80
		12/31/2008		8,408,771		1.33	to		1.29		10,917,871		6.30			1.55		to	2.00			(43.26	)	to	(43.52	)
		12/31/2007		11,935,176		2.34	to		2.28		27,402,694		6.24			1.55		to	2.00			(8.14	)	to	(8.55	)
		12/31/2006		17,862,830		2.54	to		2.49		44,772,714		1.40			1.55		to	2.00			40.11		to	39.49

113

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended		Units		Unit Fair  Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica Small/Mid Cap Value VP
		12/31/2010		10,862,233	$	2.11	to	$	2.18	$	26,576,826		0.73	%		1.55	%	to	2.00	%		28.43	%	to	27.86	%
		12/31/2009		9,414,166		1.64	to		1.70		21,501,409		3.22			1.55		to	2.00			41.03		to	40.41
		12/31/2008		10,134,682		1.17	to		1.21		17,187,413		1.71			1.55		to	2.00			(41.77	)	to	(42.03	)
		12/31/2007		12,865,977		2.00	to		2.09		37,562,425		0.89			1.55		to	2.00			22.83		to	22.28
		12/31/2006		16,687,835		1.63	to		1.71		39,817,600		0.86			1.55		to	2.00			16.26		to	15.74
Transamerica Balanced VP
		12/31/2010		10,957,969		1.49	to		1.09		14,133,140		0.50			1.55		to	2.30			22.23		to	21.10
		12/31/2009		8,283,814		1.22	to		0.90		9,298,433		1.72			1.55		to	2.30			24.37		to	23.11
		12/31/2008		8,425,908		0.98	to		0.73		7,919,325		1.83			1.55		to	2.30			(33.44	)	to	(33.73	)
		12/31/2007		9,172,830		1.47	to		1.44		13,312,476		1.12			1.55		to	2.00			11.86		to	11.37
		12/31/2006		8,379,289		1.32	to		1.29		10,880,389		0.97			1.55		to	2.00			7.46		to	6.99
Transamerica Diversified Equity VP
		12/31/2010		27,828,349		1.08	to		1.21		25,337,335		1.07			1.55		to	2.00			15.06		to	14.56
		12/31/2009		23,224,977		0.94	to		1.06		17,767,380		1.95			1.55		to	2.00			26.36		to	25.81
		12/31/2008		4,503,874		0.75	to		0.84		2,670,575		1.81			1.55		to	2.00			(44.54	)	to	(44.78	)
		12/31/2007		6,454,584		1.34	to		1.52		6,898,829		1.53			1.55		to	2.00			13.48		to	12.97
		12/31/2006		7,524,065		1.18	to		1.34		6,821,087		1.34			1.55		to	2.00			16.98		to	16.47
Transamerica Jennison Growth VP
		12/31/2010		28,030,374		0.95	to		1.16		26,161,340		0.05			1.55		to	2.00			10.55		to	10.06
		12/31/2009		5,452,782		0.86	to		1.05		4,395,005		0.16			1.55		to	2.00			38.85		to	38.24
		12/31/2008		5,367,267		0.62	to		0.76		3,003,825		0.10			1.55		to	2.00			(37.97	)	to	(38.25	)
		12/31/2007		6,634,100		1.00	to		1.23		5,965,977		0.06			1.55		to	2.00			9.80		to	9.32
		12/31/2006		9,598,275		0.91	to		1.13		7,940,588		—			1.55		to	2.00			0.41		to	(0.03	)
Transamerica JPMorgan Enhanced Index VP
		12/31/2010		11,052,341		0.98	to		1.14		10,637,091		1.36			1.55		to	2.00			13.42		to	12.92
		12/31/2009		12,095,690		0.87	to		1.01		10,278,995		2.19			1.55		to	2.00			27.61		to	27.05
		12/31/2008		11,567,877		0.68	to		0.79		7,701,104		5.33			1.55		to	2.00			(38.31	)	to	(38.58	)
		12/31/2007		15,461,960		1.10	to		1.29		17,073,271		1.17			1.55		to	2.00			2.93		to	2.48
		12/31/2006		16,969,802		1.07	to		1.26		18,168,216		1.07			1.55		to	2.00			13.56		to	13.06
Transamerica AEGON High Yield Bond VP
		12/31/2010		19,297,754		1.60	to		1.55		29,187,916		14.06			1.55		to	2.00			10.72		to	10.23
		12/31/2009		20,381,698		1.45	to		1.40		28,156,204		9.57			1.55		to	2.00			44.99		to	44.35
		12/31/2008		13,414,744		1.00	to		0.97		12,892,728		9.08			1.55		to	2.00			(26.34	)	to	(26.67	)
		12/31/2007		16,092,225		1.35	to		1.33		21,037,102		8.91			1.55		to	2.00			0.29		to	(0.15	)
		12/31/2006		20,796,555		1.35	to		1.33		27,204,373		9.48			1.55		to	2.00			9.26		to	8.78
Transamerica BlackRock Large Cap Value VP
		12/31/2010		59,611,359		1.28	to		1.25		79,512,642		0.84			1.55		to	2.00			8.76		to	8.28
		12/31/2009		33,599,565		1.17	to		1.15		42,665,195		1.22			1.55		to	2.00			12.25		to	11.76
		12/31/2008		15,701,666		1.05	to		1.03		17,902,877		0.92			1.55		to	2.00			(34.90	)	to	(35.19	)
		12/31/2007		17,858,524		1.61	to		1.59		31,517,027		0.89			1.55		to	2.00			3.03		to	2.58
		12/31/2006		21,763,733		1.56	to		1.55		37,122,336		0.51			1.55		to	2.00			15.14		to	14.63

114

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended		Units		Unit Fair  Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica PIMCO Total Return VP
		12/31/2010		68,399,314	$	1.43	to	$	1.08	$	90,066,609		4.10	%		1.55	%	to	2.30	%		5.56	%	to	4.53	%
		12/31/2009		60,774,324		1.36	to		1.04		78,168,950		6.24			1.55		to	2.30			14.26		to	13.15
		12/31/2008		50,391,182		1.19	to		0.91		57,739,246		5.84			1.55		to	2.30			(4.28	)	to	(4.70	)
		12/31/2007		47,121,047		1.24	to		1.21		57,135,124		2.53			1.55		to	2.00			7.28		to	6.80
		12/31/2006		51,339,147		1.16	to		1.13		58,279,404		3.36			1.55		to	2.00			2.62		to	2.17
Transamerica Focus VP
		12/31/2010		17,913,830		1.18	to		1.25		24,112,425		0.87			1.55		to	2.00			25.49		to	24.94
		12/31/2009		17,766,959		0.94	to		1.00		19,905,676		2.58			1.55		to	2.00			25.96		to	25.40
		12/31/2008		20,090,397		0.75	to		0.80		17,949,468		2.01			1.55		to	2.00			(37.34	)	to	(37.62	)
		12/31/2007		25,959,952		1.19	to		1.27		37,101,899		1.28			1.55		to	2.00			(0.51	)	to	(0.96	)
		12/31/2006		34,084,305		1.20	to		1.29		49,261,314		0.98			1.55		to	2.00			16.75		to	16.24
Transamerica AllianceBernstein Dynamic Allocation VP
		12/31/2010		7,030,317		1.41	to		1.05		9,076,375		5.29			1.55		to	2.30			7.62		to	4.62
		12/31/2009		6,779,641		1.31	to		1.27		8,626,622		3.75			1.55		to	2.00			29.29		to	28.72
		12/31/2008		7,476,369		1.02	to		0.99		7,430,179		5.99			1.55		to	2.00			(37.84	)	to	(38.12	)
		12/31/2007		8,838,214		1.63	to		1.59		14,198,949		1.91			1.55		to	2.00			16.81		to	16.30
		12/31/2006		9,540,856		1.40	to		1.37		13,162,392		1.74			1.55		to	2.00			9.21		to	8.73
Transamerica WMC Diversified Growth VP
		12/31/2010		31,907,968		1.08	to		1.32		34,956,953		0.54			1.55		to	2.00			16.01		to	15.50
		12/31/2009		34,400,216		0.94	to		1.14		32,612,803		0.94			1.55		to	2.00			27.22		to	26.66
		12/31/2008		39,480,791		0.73	to		0.90		29,697,033		0.22			1.55		to	2.00			(46.83	)	to	(47.07	)
		12/31/2007		47,413,786		1.38	to		1.70		67,321,389		0.02			1.55		to	2.00			14.50		to	13.99
		12/31/2006		62,017,403		1.21	to		1.49		77,263,337		—			1.55		to	2.00			7.06		to	6.59
Transamerica Growth Opportunities VP
		12/31/2010		8,849,543		2.08	to		1.70		16,115,771		0.03			1.55		to	2.00			33.59		to	33.00
		12/31/2009		8,752,277		1.56	to		1.28		12,251,024		0.34			1.55		to	2.00			34.77		to	34.18
		12/31/2008		9,053,807		1.16	to		0.95		9,566,302		3.42			1.55		to	2.00			(41.81	)	to	(42.07	)
		12/31/2007		13,528,549		1.99	to		1.64		24,567,441		0.04			1.55		to	2.00			21.20		to	20.66
		12/31/2006		13,829,114		1.64	to		1.36		21,027,281		0.22			1.55		to	2.00			3.50		to	3.05
Transamerica U.S. Government Securities VP
		12/31/2010		35,145,707		1.31	to		1.07		43,758,653		3.14			1.55		to	2.30			2.81		to	1.88
		12/31/2009		34,267,318		1.27	to		1.05		42,783,689		2.25			1.55		to	2.30			2.87		to	1.85
		12/31/2008		34,588,532		1.24	to		1.03		43,021,141		2.00			1.55		to	2.30			6.01		to	5.55
		12/31/2007		22,755,543		1.17	to		1.12		27,076,919		4.36			1.55		to	2.00			4.42		to	3.96
		12/31/2006		26,204,329		1.12	to		1.08		29,970,824		3.52			1.55		to	2.00			1.70		to	1.25
Transamerica U.S. Government Securities VP PAM SC
		12/31/2010		4,192,757		1.21	to		1.08		4,917,162		3.14			1.55		to	1.85			2.63		to	2.33
		12/31/2009		6,391,954		1.18	to		1.06		7,316,615		2.00			1.55		to	1.85			2.61		to	2.30
		12/31/2008		12,013,695		1.15	to		1.03		13,437,154		1.33			1.55		to	1.85			5.77		to	5.56
		12/31/2007		396,411		1.09	to		1.06		420,737		9.58			1.55		to	1.75			4.16		to	3.95
		12/31/2006		—		1.04	to		1.02		—		8.15			1.55		to	1.75			1.49		to	1.29

115

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended			Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica Money Market VP
		12/31/2010			54,916,314	$	1.05	to	$	0.95	$	55,858,304		0.01	%		1.55	%	to	2.30	%		(1.52	)%	to	(2.24	)%
		12/31/2009			56,044,646		1.07	to		0.98		58,226,265		0.13			1.55		to	2.30			(1.40	)	to	(2.24	)
		12/31/2008			90,642,027		1.08	to		1.00		96,630,790		2.26			1.55		to	2.30			0.83		to	0.38
		12/31/2007			47,721,761		1.07	to		1.04		51,115,455		4.93			1.55		to	2.00			3.42		to	2.96
		12/31/2006			42,684,398		1.04	to		1.01		44,375,415		4.65			1.55		to	2.00			3.14		to	2.68
Transamerica T. Rowe Price Small Cap VP
		12/31/2010			15,865,784		1.40	to		1.46		21,503,809		—			1.55		to	2.00			32.38		to	31.79
		12/31/2009			15,529,334		1.05	to		1.11		15,892,177		—			1.55		to	2.00			36.59		to	35.98
		12/31/2008			16,810,166		0.77	to		0.82		12,612,665		1.57			1.55		to	2.00			(37.23	)	to	(37.51	)
		12/31/2007			21,568,423		1.23	to		1.31		25,961,430		—			1.55		to	2.00			7.93		to	7.45
		12/31/2006			28,381,166		1.14	to		1.21		31,784,903		—			1.55		to	2.00			2.01		to	1.56
Transamerica Morgan Stanley Active International Allocation VP
		12/31/2010			11,908,201		1.25	to		1.46		14,290,393		1.99			1.55		to	2.00			6.82		to	6.35
		12/31/2009			13,967,570		1.17	to		1.38		15,908,668		0.15			1.55		to	2.00			23.96		to	23.41
		12/31/2008			18,534,286		0.95	to		1.12		17,173,868		5.06			1.55		to	2.00			(39.77	)	to	(40.04	)
		12/31/2007			23,977,265		1.57	to		1.86		37,025,989		2.76			1.55		to	2.00			13.83		to	13.33
		12/31/2006			24,392,213		1.38	to		1.64		32,498,958		0.31			1.55		to	2.00			21.63		to	21.09
Transamerica Multi Managed Large Cap Core VP
		12/31/2010			21,852,644		1.27	to		1.34		26,616,459		0.67			1.55		to	2.00			17.35		to	16.84
		12/31/2009			24,425,260		1.08	to		1.15		25,144,254		0.97			1.55		to	2.00			43.19		to	42.56
		12/31/2008			10,351,994		0.75	to		0.81		7,218,432		3.72			1.55		to	2.00			(42.97	)	to	(43.22	)
		12/31/2007			12,688,376		1.32	to		1.42		15,579,276		0.91			1.55		to	2.00			7.57		to	7.10
		12/31/2006			16,071,457		1.23	to		1.32		18,402,409		0.93			1.55		to	2.00			8.65		to	8.18
Transamerica Morgan Stanley Mid-Cap Growth VP
		12/31/2010			11,366,685		1.08	to		1.41		13,955,307		0.11			1.55		to	2.00			31.86		to	31.28
		12/31/2009			9,921,917		0.82	to		1.08		9,037,055		—			1.55		to	2.00			58.11		to	57.41
		12/31/2008			9,588,179		0.52	to		0.68		5,519,349		2.02			1.55		to	2.00			(47.11	)	to	(47.35	)
		12/31/2007			12,098,986		0.98	to		1.30		13,300,833		—			1.55		to	2.00			20.65		to	20.12
		12/31/2006			13,215,743		0.81	to		1.08		11,829,028		—			1.55		to	2.00			8.23		to	7.76
Transamerica International Moderate Growth VP SC
		12/31/2010			30,007,284		0.95	to		0.93		28,343,412		2.53			1.55		to	2.30			8.56		to	7.76
		12/31/2009			28,409,564		0.88	to		0.86		24,766,153		2.62			1.55		to	2.30			27.35		to	26.42
		12/31/2008			23,659,772		0.69	to		0.68		16,235,413		2.62			1.55		to	2.30			(37.29	)	to	(37.57	)
		12/31/2007			10,612,614		1.10	to		1.09		11,639,776		1.20			1.55		to	2.00			6.83		to	6.35
		12/31/2006	(1)		1,525,866		1.03	to		1.03		1,570,084		—			1.55		to	2.00			3.04		to	2.74
Transamerica Efficient Markets VP SC
		12/31/2010			2,256,322		1.33	to		1.31		2,992,742		0.66			1.65		to	2.30			10.55		to	9.85
		12/31/2009			1,229,615		1.20	to		1.19		1,477,009		0.06			1.65		to	2.30			15.95		to	15.21
		12/31/2008	(1)		—		1.04	to		1.04		—		—			1.55		to	2.30			3.66		to	3.57
Transamerica Index 50 VP SC
		12/31/2010			5,356,512		1.09	to		1.00		5,449,115		1.15			1.55		to	2.30			9.00		to	8.20
		12/31/2009			3,607,456		1.00	to		0.93		3,368,800		0.31			1.55		to	2.30			0.45		to	13.91
		12/31/2008	(1)		302,454		0.81	to		0.82		247,074		—			1.65		to	2.30			(18.30	)	to	(18.65	)

116

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended			Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica Index 75 VP SC
		12/31/2010			16,030,495	$	1.11	to	$	0.95	$	15,535,246		1.18	%		1.55	%	to	2.30	%		11.28	%	to	10.46	%
		12/31/2009			11,372,422		1.00	to		0.86		9,921,666		0.39			1.55		to	2.30			1.07		to	20.41
		12/31/2008	(1)		2,111,913		0.72	to		0.72		1,522,068		—			1.65		to	2.30			(27.89	)	to	(28.20	)
Transamerica BlackRock Global Allocation VP SC
		12/31/2010			25,313,491		1.30	to		1.29		32,790,378		0.48			1.75		to	1.95			7.89		to	7.68
		12/31/2009	(1)		7,509,297		1.20	to		1.20		9,021,564		—			1.75		to	1.95			20.20		to	20.04
Transamerica BlackRock Tactical Allocation VP SC
		12/31/2010			10,434,930		1.10	to		1.09		13,208,188		0.40			1.55		to	2.00			9.55		to	9.06
		12/31/2009	(1)		2,321,057		1.00	to		1.00		2,773,690		—			1.55		to	2.00			0.98		to	0.93
Transamerica ProFunds UltraBear Fund VP OAM SC
		12/31/2010			418,637		0.40	to		0.40		169,289		—			1.65		to	1.85			(27.95	)	to	(28.09	)
		12/31/2009	(1)		—		0.56	to		0.56		—		—			1.65		to	1.85			(43.82	)	to	(43.90	)
Transamerica Foxhall Global Growth VP SC
		12/31/2010			2,433,691		1.04	to		1.04		2,538,137		0.37			1.65		to	1.85			3.68		to	3.47
		12/31/2009	(1)		241,299		1.01	to		1.01		242,783		—			1.65		to	1.85			1.75		to	1.73
Transamerica Foxhall Global Conservative VP SC
		12/31/2010			2,306,275		0.91	to		0.90		2,093,480		0.14			1.65		to	2.30			(7.62	)	to	(8.21	)
		12/31/2009	(1)		76,572		0.98	to		0.98		75,298		—			1.65		to	2.30			(1.17	)	to	(1.24	)
Transamerica Foxhall Global Hard Asset VP SC
		12/31/2010			3,132,165		1.00	to		1.00		3,129,570		0.17			1.65		to	1.85			1.43		to	1.23
		12/31/2009	(1)		285,375		0.99	to		0.99		281,224		—			1.65		to	1.85			(0.09	)	to	(0.11	)
Transamerica Foxhall Emerging Markets/Pacific Rim VP SC
		12/31/2010			3,678,370		1.03	to		1.02		3,773,091		0.36			1.65		to	1.85			1.70		to	1.50
		12/31/2009	(1)		553,309		1.01	to		1.01		558,282		—			1.65		to	1.85			1.86		to	1.84
Transamerica Hanlon Growth VP SC
		12/31/2010			2,781,330		1.00	to		1.00		2,773,338		1.25			1.65		to	1.85			(2.32	)	to	(2.51	)
		12/31/2009	(1)		428,723		1.02	to		1.02		437,773		—			1.65		to	1.85			2.49		to	2.46
Transamerica Hanlon Growth and Income VP SC
		12/31/2010			2,229,348		0.98	to		0.98		2,193,646		0.83			1.65		to	1.85			(3.70	)	to	(3.90	)
		12/31/2009	(1)		158,914		1.02	to		1.02		162,446		—			1.65		to	1.85			2.50		to	2.48
Transamerica Hanlon Balanced VP SC
		12/31/2010			2,523,965		0.97	to		0.97		2,445,328		0.51			1.65		to	1.85			(5.03	)	to	(5.22	)
		12/31/2009	(1)		59,412		1.02	to		1.02		60,630		—			1.65		to	1.85			2.24		to	2.21
Transamerica Hanlon Managed Income VP SC
		12/31/2010			18,197,111		0.99	to		0.99		17,978,355		0.24			1.65		to	1.85			(1.51	)	to	(1.70	)
		12/31/2009	(1)		1,632,070		1.00	to		1.00		1,637,691		—			1.65		to	1.85			0.36		to	0.33
Transamerica Index 35 VP SC
		12/31/2010			2,144,267		1.08	to		1.07		2,302,518		0.03			1.55		to	2.30			7.75		to	6.96
		12/31/2009	(1)		33,287		1.00	to		1.00		33,223		—			1.55		to	2.30			(0.18	)	to	(0.26	)

117

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended			Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Transamerica Index 100 VP SC
		12/31/2010			1,027,235	$	1.15	to	$	1.15	$	1,181,839		0.07	%		1.55	%	to	2.00	%		12.66	%	to	12.16	%
		12/31/2009	(1)		30,070		1.02	to		1.02		30,780		—			1.55		to	2.00			2.42		to	2.37
Transamerica JP Morgan Midcap Value VP SC
		12/31/2010			1,453,525		1.25	to		1.24		1,804,712		2.68			1.55		to	2.00			20.95		to	20.41
		12/31/2009	(1)		27,682		1.03	to		1.03		28,495		—			1.55		to	2.00			4.51		to	4.46
Invesco V.I. Basic Value
		12/31/2010			8,170,888		0.91	to		0.87		7,165,733		0.34			1.55		to	2.00			5.31		to	4.85
		12/31/2009			9,196,753		0.86	to		0.83		7,686,357		1.29			1.55		to	2.00			45.48		to	44.84
		12/31/2008			9,196,537		0.59	to		0.58		5,326,470		0.46			1.55		to	2.00			(52.64	)	to	(52.85	)
		12/31/2007			10,933,264		1.25	to		1.22		13,421,208		0.31			1.55		to	2.00			(0.19	)	to	(0.63	)
		12/31/2006			13,154,403		1.25	to		1.23		16,234,558		0.11			1.55		to	2.00			11.22		to	10.73
Invesco V.I. Capital Appreciation
		12/31/2010			2,631,531		0.99	to		0.95		2,450,957		0.53			1.55		to	2.00			13.45		to	12.95
		12/31/2009			2,185,521		0.87	to		0.84		1,833,513		0.28			1.55		to	2.00			18.88		to	18.35
		12/31/2008			2,398,956		0.73	to		0.71		1,716,252		—			1.55		to	2.00			(43.51	)	to	(43.76	)
		12/31/2007			2,890,444		1.30	to		1.27		3,679,740		—			1.55		to	2.00			10.02		to	9.53
		12/31/2006			3,873,618		1.18	to		1.16		4,491,741		—			1.55		to	2.00			4.44		to	3.98
AllianceBernstein Growth and Income
		12/31/2010			12,899,824		0.95	to		1.02		12,383,426		—			1.55		to	2.00			11.08		to	10.59
		12/31/2009			13,962,793		0.86	to		0.92		12,167,333		3.56			1.55		to	2.00			18.51		to	17.99
		12/31/2008			15,621,504		0.72	to		0.78		11,568,039		1.77			1.55		to	2.00			(41.60	)	to	(41.86	)
		12/31/2007			19,821,819		1.24	to		1.34		25,169,792		1.23			1.55		to	2.00			3.25		to	2.79
		12/31/2006			24,451,453		1.20	to		1.30		30,100,810		1.16			1.55		to	2.00			15.20		to	14.70
AllianceBernstein Large Cap Growth
		12/31/2010			6,976,122		0.81	to		1.04		6,245,915		0.27			1.55		to	2.00			8.16		to	7.68
		12/31/2009			7,332,555		0.75	to		0.97		6,060,005		—			1.55		to	2.00			35.01		to	34.42
		12/31/2008			6,897,289		0.55	to		0.72		4,133,134		—			1.55		to	2.00			(40.74	)	to	(41.01	)
		12/31/2007			9,186,077		0.93	to		1.22		9,325,025		—			1.55		to	2.00			11.87		to	11.37
		12/31/2006			11,059,580		0.83	to		1.10		10,008,115		—			1.55		to	2.00			(2.15	)	to	(2.58	)
AllianceBernstein Balanced Wealth Strategy
		12/31/2010			2,587,618		1.34	to		1.32		3,455,456		2.13			1.85		to	2.50			8.29		to	7.61
		12/31/2009			1,481,568		1.24	to		1.23		1,830,164		0.55			1.85		to	2.50			22.19		to	21.42
		12/31/2008	(1)		33,981		1.01	to		1.01		34,415		—			1.85		to	2.50			1.28		to	1.19
Janus Aspen - Enterprise
		12/31/2010			7,406,318		1.23	to		1.73		7,034,568		—			1.55		to	2.00			23.61		to	23.06
		12/31/2009			7,940,166		0.99	to		1.41		5,433,128		—			1.55		to	2.00			42.24		to	41.61
		12/31/2008			9,342,076		0.70	to		0.99		4,471,617		0.06			1.55		to	2.00			(44.72	)	to	(44.96	)
		12/31/2007			11,184,569		1.26	to		1.80		9,299,272		0.68			1.55		to	2.00			19.87		to	19.34
		12/31/2006			11,280,530		1.05	to		1.51		7,926,705		—			1.55		to	2.00			11.58		to	11.09

118

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended		Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Janus Aspen - Perkins Mid Cap Value
		12/31/2010		731,595	$	1.51	to	$	1.47	$	1,083,808		0.49	%		1.55	%	to	1.75	%		13.60	%	to	13.38	%
		12/31/2009		851,630		1.33	to		1.30		1,103,793		0.34			1.55		to	1.75			30.89		to	30.63
		12/31/2008		978,727		1.01	to		0.99		970,936		0.36			1.55		to	1.75			(29.00	)	to	(29.14	)
		12/31/2007		1,401,044		1.43	to		1.40		1,961,160		4.51			1.55		to	1.75			5.53		to	5.32
		12/31/2006		1,816,485		1.35	to		1.33		2,414,055		0.98			1.55		to	1.75			13.31		to	13.09
Janus Aspen - Worldwide
		12/31/2010		15,011,535		0.83	to		1.02		12,630,686		0.49			1.55		to	2.00			13.76		to	13.26
		12/31/2009		14,547,713		0.73	to		0.90		10,469,730		1.27			1.55		to	2.00			35.31		to	34.71
		12/31/2008		13,174,272		0.54	to		0.67		6,825,814		0.96			1.55		to	2.00			(45.65	)	to	(45.90	)
		12/31/2007		16,298,783		1.00	to		1.24		14,658,035		0.57			1.55		to	2.00			7.69		to	7.21
		12/31/2006		16,672,539		0.93	to		1.16		13,734,976		1.64			1.55		to	2.00			16.14		to	15.63
MFS® New Discovery
		12/31/2010		6,857,450		1.52	to		1.46		10,117,115		—			1.55		to	2.00			33.87		to	33.28
		12/31/2009		5,572,015		1.14	to		1.10		6,159,028		—			1.55		to	2.00			60.43		to	59.73
		12/31/2008		4,069,393		0.71	to		0.69		2,816,761		—			1.55		to	2.00			(40.45	)	to	(40.71	)
		12/31/2007		4,829,487		1.19	to		1.16		5,631,448		—			1.55		to	2.00			0.68		to	0.23
		12/31/2006		5,483,718		1.18	to		1.16		6,370,004		—			1.55		to	2.00			11.21		to	10.72
MFS® Total Return
		12/31/2010		12,628,097		1.25	to		1.20		15,042,586		2.56			1.55		to	2.00			7.96		to	7.48
		12/31/2009		12,759,989		1.15	to		1.12		14,309,442		3.36			1.55		to	2.00			15.93		to	15.42
		12/31/2008		13,055,752		1.00	to		0.97		12,720,273		2.96			1.55		to	2.00			(23.51	)	to	(23.85	)
		12/31/2007		16,732,796		1.30	to		1.27		21,372,644		2.42			1.55		to	2.00			2.34		to	1.89
		12/31/2006		18,622,238		1.27	to		1.25		23,319,044		2.16			1.55		to	2.00			9.92		to	9.44
Fidelity VIP Contrafund
		12/31/2010		29,447,630		1.52	to		1.50		39,445,827		1.06			1.55		to	2.00			15.14		to	14.64
		12/31/2009		29,738,114		1.32	to		1.31		34,854,027		1.16			1.55		to	2.00			33.40		to	32.81
		12/31/2008		33,189,212		0.99	to		0.98		29,630,321		0.72			1.55		to	2.00			(43.57	)	to	(43.82	)
		12/31/2007		40,278,601		1.75	to		1.75		64,047,323		0.70			1.55		to	2.00			15.50		to	14.99
		12/31/2006		47,674,994		1.52	to		1.52		65,883,388		0.99			1.55		to	2.00			9.74		to	9.25
Fidelity VIP Equity-Income
		12/31/2010		11,605,823		1.07	to		1.10		12,817,491		1.61			1.55		to	2.00			13.16		to	12.67
		12/31/2009		12,557,970		0.94	to		0.98		12,436,646		2.02			1.55		to	2.00			27.90		to	27.34
		12/31/2008		15,071,112		0.74	to		0.77		11,736,623		2.05			1.55		to	2.00			(43.69	)	to	(43.94	)
		12/31/2007		19,895,045		1.31	to		1.37		27,581,702		1.47			1.55		to	2.00			(0.28	)	to	(0.72	)
		12/31/2006		22,848,240		1.31	to		1.38		31,810,817		3.06			1.55		to	2.00			18.10		to	17.58
Fidelity VIP Growth
		12/31/2010		8,510,321		0.86	to		1.03		7,747,597		0.03			1.55		to	2.00			21.97		to	21.43
		12/31/2009		8,302,205		0.70	to		0.85		6,162,381		0.20			1.55		to	2.00			26.01		to	25.46
		12/31/2008		8,889,501		0.56	to		0.68		5,254,551		0.49			1.55		to	2.00			(48.12	)	to	(48.35	)
		12/31/2007		12,145,489		1.07	to		1.31		14,100,985		0.39			1.55		to	2.00			24.72		to	24.16
		12/31/2006		11,110,753		0.86	to		1.05		10,162,266		0.18			1.55		to	2.00			4.95		to	4.49

119

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended			Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
Fidelity VIP Growth Opportunities
		12/31/2010			594,786	$	0.97	to	$	0.74	$	463,151		—	%		1.55	%	to	1.75	%		21.59	%	to	21.35	%
		12/31/2009			675,784		0.80	to		0.61		412,731		0.22			1.55		to	1.75			43.24		to	42.96
		12/31/2008			854,771		0.56	to		0.43		365,170		0.13			1.55		to	1.75			(55.83	)	to	(55.91	)
		12/31/2007			942,827		1.26	to		0.97		913,617		—			1.55		to	1.75			21.02		to	20.78
		12/31/2006			1,146,056		1.04	to		0.80		919,472		0.50			1.55		to	1.75			3.52		to	3.31
Fidelity VIP Mid Cap
		12/31/2010			24,541,205		2.30	to		2.09		52,094,726		0.12			1.55		to	2.00			26.61		to	26.05
		12/31/2009			25,760,728		1.82	to		1.65		44,623,830		0.45			1.55		to	2.00			37.62		to	37.01
		12/31/2008			28,955,061		1.32	to		1.21		36,998,307		0.24			1.55		to	2.00			(40.53	)	to	(40.80	)
		12/31/2007			37,461,194		2.22	to		2.04		80,696,756		0.49			1.55		to	2.00			13.57		to	13.06
		12/31/2006			45,931,138		1.96	to		1.80		87,432,027		0.19			1.55		to	2.00			10.69		to	10.21
Fidelity VIP Value Strategies
		12/31/2010			11,099,531		1.44	to		1.38		15,173,721		0.30			1.55		to	2.00			24.41		to	23.86
		12/31/2009			11,648,806		1.15	to		1.12		12,974,544		0.38			1.55		to	2.00			54.75		to	54.07
		12/31/2008			11,622,227		0.75	to		0.72		8,470,071		0.49			1.55		to	2.00			(52.03	)	to	(52.25	)
		12/31/2007			15,280,344		1.55	to		1.52		23,293,289		0.58			1.55		to	2.00			3.82		to	3.36
		12/31/2006			18,372,779		1.50	to		1.47		27,062,608		0.36			1.55		to	2.00			14.24		to	13.74
Fidelity VIP Balanced
		12/31/2010			3,048,436		1.05	to		1.03		3,188,166		1.82			1.65		to	2.30			15.85		to	15.11
		12/31/2009			2,137,599		0.90	to		0.90		1,928,396		2.72			1.65		to	2.30			36.08		to	35.21
		12/31/2008	(1)		891,854		0.66	to		0.66		592,966		4.29			1.65		to	2.30			(33.51	)	to	(33.79	)
Franklin Income Securities
		12/31/2010			11,068,473		0.99	to		0.98		11,052,933		6.32			1.55		to	2.00			10.95		to	10.46
		12/31/2009			7,683,598		0.90	to		0.89		6,874,140		7.47			1.55		to	2.00			33.53		to	32.94
		12/31/2008			4,618,240		0.67	to		0.67		3,096,317		5.48			1.55		to	2.00			(30.73	)	to	(31.04	)
		12/31/2007	(1)		2,217,890		0.97	to		0.97		2,145,611		0.18			1.55		to	2.00			(3.06	)	to	(3.34	)
Mutual Shares Securities
		12/31/2010			4,156,888		0.81	to		0.80		3,424,699		1.54			1.55		to	2.00			9.50		to	9.01
		12/31/2009			4,240,640		0.74	to		0.73		3,151,870		2.01			1.55		to	2.00			24.12		to	23.58
		12/31/2008			2,324,077		0.60	to		0.59		1,380,580		2.94			1.55		to	2.00			(38.07	)	to	(38.35	)
		12/31/2007	(1)		2,292,957		0.96	to		0.96		2,204,930		—			1.55		to	2.00			(3.65	)	to	(3.94	)
Templeton Foreign Securities
		12/31/2010			9,902,248		0.90	to		0.89		8,947,023		1.85			1.55		to	2.00			6.75		to	6.28
		12/31/2009			9,773,874		0.85	to		0.84		8,227,367		2.50			1.55		to	2.00			34.95		to	34.35
		12/31/2008			4,381,951		0.63	to		0.62		2,732,123		2.51			1.55		to	2.00			(41.29	)	to	(41.55	)
		12/31/2007	(1)		2,726,785		1.07	to		1.06		2,906,032		0.02			1.55		to	2.00			6.80		to	6.49
Franklin Templeton VIP Founding Funds Allocation
		12/31/2010			4,992,160		1.37	to		1.35		6,824,657		2.51			1.80		to	2.45			8.29		to	7.61
		12/31/2009			2,673,081		1.27	to		1.26		3,376,330		5.07			1.80		to	2.45			27.76		to	26.96
		12/31/2008	(1)		—		0.99	to		0.99		—		—			1.80		to	2.45			(0.99	)	to	(1.08	)
American Funds – Asset Allocation Fund
		12/31/2010			2,401,287		1.11	to		1.10		2,668,175		3.90			1.95		to	2.60			10.35		to	9.66
		12/31/2009	(1)		38,937		1.01	to		1.01		39,243		—			1.95		to	2.60			1.84		to	1.77

120

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	Year Ended			Units		Unit Fair Value Corresponding to Lowest to Highest Expense Ratio					Net Assets		Investment Income Ratio*			Expense Ratio** Lowest to Highest						Total Return*** Corresponding to Lowest to Highest Expense Ratio
American Funds – Bond Fund
		12/31/2010			2,413,444	$	1.04	to	$	1.03	$	2,502,498		5.24	%		1.95	%	to	2.60	%		4.41	%	to	3.75	%
		12/31/2009	(1)		35,084		0.99	to		0.99		34,855		0.51			1.95		to	2.60			(0.72	)	to	(0.79	)
American Funds – Growth Fund
		12/31/2010			1,519,087		1.17	to		1.16		1,771,950		1.05			1.95		to	2.15			16.41		to	16.18
		12/31/2009	(1)		324,804		1.00	to		1.00		325,720		0.09			1.95		to	2.15			1.66		to	1.64
American Funds – Growth – Income Fund
		12/31/2010			837,328		1.10	to		1.10		921,888		2.42			1.95		to	2.15			9.30		to	9.08
		12/31/2009	(1)		26,449		1.01	to		1.01		26,661		2.78			1.95		to	2.15			2.17		to	2.15
American Funds – International Fund
		12/31/2010			1,572,617		1.03	to		1.03		1,620,499		2.83			1.95		to	2.15			5.18		to	4.98
		12/31/2009	(1)		295,953		0.98	to		0.98		290,115		0.33			1.95		to	2.15			(0.26	)	to	(0.28	)
GE Investments Total Return Fund
		12/31/2010			498,092		1.08	to		1.07		536,297		3.10			1.85		to	2.50			7.38		to	6.70
		12/31/2009	(1)		—		1.00	to		1.00		—		—			1.85		to	2.50			1.50		to	1.42

* These amounts represent the dividends, excluding distributions of capital gains, received by the subaccount from the Mutual Fund, net of management fees assessed by the fund manager, divided by the average net assets. These ratios exclude those expenses, such as mortality and expense charges, that are assessed against contract owner accounts either through reductions in the unit values or the redemption of units. The recognition of investment income by the subaccount is affected by the timing of the declaration of dividends by the Mutual Fund in which the subaccounts invest.

** These amounts represent the annualized contract expenses of the Separate Account, consisting primarily of mortality and expense charges, for each period indicated. These ratios include only those expenses that result in a direct reduction to unit values. Charges made directly to contract owner accounts through the redemption of units and expenses of the Mutual Fund have been excluded.

*** These amounts represent the total return for the periods indicated, including changes in the value of the Mutual Fund, and expenses assessed through the reduction of unit values. These ratios do not include any expenses assessed through the redemption of units. Investment options with a date notation indicate the effective date of that investment option in the variable account. The total return is calculated for each period indicated or from the effective date through the end of the reporting period.

There are subaccounts that have total return ranges outside of the range indicated above. Following is the list of the subaccounts and their corresponding lowest total return and highest total return.

Subaccount	2010 Total Return Range
Transamerica Asset Allocation-Growth VP	12.57% to 13.20%
Transamerica MFS International Equity VP	8.30% to 8.81%
Transamerica Clarion Global Real Estate Securities VP	13.21% to 13.90%
Transamerica Small/Mid Cap Value VP	27.69% to 28.43%
Transamerica Diversified Equity VP	14.43% to 15.06%
Transamerica Jennison Growth VP	9.94% to 10.55%
Transamerica JPMorgan Enhanced Index VP	12.77% to 13.42%
Transamerica AEGON High Yield Bond VP	10.13% to 10.72%
Transamerica BlackRock Large Cap Value VP	8.15% to 8.76%
Transamerica Focus VP	24.78% to 25.49%

121

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	2010 Total Return Range (continued)
Transamerica WMC Diversified Growth VP	15.35% to 16.01%
Transamerica Growth Opportunities VP	32.83% to 33.59%
Transamerica T. Rowe Price Small Cap VP	31.63% to 32.38%
Transamerica Morgan Stanley Active International Allocation VP	6.24% to 6.82%
Transamerica Multi Managed Large Cap Core VP	16.72% to 17.35%
Transamerica Morgan Stanley Mid-Cap Growth VP	31.15% to 31.86%
Subaccount	2009 Total Return Range
Transamerica Asset Allocation-Growth VP	27.19% to 27.84%
Transamerica MFS International Equity VP	29.83% to 30.66%
Transamerica Clarion Global Real Estate Securities VP	30.59% to 31.38%
Transamerica Small/Mid Cap Value VP	40.31% to 41.03%
Transamerica Diversified Equity VP	25.52% to 26.36%
Transamerica Jennison Growth VP	38.13% to 38.85%
Transamerica JPMorgan Enhanced Index VP	26.97% to 27.61%
Transamerica AEGON High Yield Bond VP	44.19% to 44.99%
Transamerica BlackRock Large Cap Value VP	11.65% to 12.25%
Transamerica Focus VP	25.25% to 25.96%
Transamerica WMC Diversified Growth VP VP	26.55% to 27.22%
Transamerica Growth Opportunities VP	34.04% to 34.77%
Transamerica T. Rowe Price Small Cap VP	35.82% to 36.59%
Transamerica Morgan Stanley Active International Allocation VP	23.39% to 23.96%
Transamerica Multi Managed Large Cap Core VP	42.45% to 43.19%
Transamerica Morgan Stanley Mid-Cap Growth VP	57.21% to 58.11%
Transamerica Index 50 VP SC	0.40% to 14.64%
Transamerica Index 75 VP SC	1.01% to 21.18%
Transamerica BlackRock Tactical Allocation VP SC	0.93% to 20.58%
Subaccount	2008 Total Return Range
Transamerica Asset Allocation-Conservative VP	-22.76% to -22.39%
Transamerica Asset Allocation-Moderate VP	-27.47% to -27.10%
Transamerica MFS International Equity VP	-36.65% to -36.28%
Transamerica Balanced VP	-33.74% to -33.44%
Transamerica Diversified Equity VP	-44.78% to -44.54%
Transamerica JPMorgan Enhanced Index VP	-38.60% to -38.31%
Transamerica AEGON High Yield Bond VP	-26.75% to -26.34%
Transamerica BlackRock Large Cap Value VP	-35.20% to -34.90%
Transamerica PIMCO Total Return VP	-4.75% to -4.28%
Transamerica Focus VP	-37.64% to -37.34%
Transamerica WMC Diversified Growth VP VP	-47.11% to -46.83%
Transamerica Growth Opportunities VP	-42.08% to -41.81%
Transamerica Morgan Stanley Active International Allocation VP	-40.10% to -39.77%
Transamerica Morgan Stanley Mid Cap Growth VP	-47.36% to -47.11%
Transamerica Efficient Markets VP	-18.35% to 3.65%
Fidelity VIP Growth Opportunities	-55.91% to -55.83%
Franklin Templeton VIP Founding Funds Allocation	-1.08% to -0.99%

122

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

4. Financial Highlights (continued)

Subaccount	2007 Total Return Range
Transamerica MFS International Equity VP	6.99% to 7.48%
Transamerica BlackRock Large Cap Value VP	2.54% to 3.03%
Transamerica Focus VP	.98% to -.51%
Transamerica AllianceBernstein Dynamic Allocation VP	16.24% to 16.81%
Transamerica Growth Opportunities VP	20.61% to 21.20%
Transamerica U.S. Government Securities VP	3.95% to 4.42%
Transamerica Money Market VP	2.96% to 3.42%
Transamerica T. Rowe Price Small Cap VP	7.38% to 7.93%
Transamerica Morgan Stanley Active International Allocation VP	13.28% to 13.83%
Subaccount	2006 Total Return Range
Transamerica Asset Allocation-Conservative VP	7.27% to 7.78%
Transamerica Asset Allocation-Growth VP	13.30% to 13.86%
Transamerica Asset Allocation-Moderate Growth VP	11.59% to 12.10%
Transamerica Clarion Global Real Estate Securities VP	39.48% to 40.11%
Transamerica Jennison Growth VP	-0.14% to 0.41%
Transamerica JPMorgan Enhanced Index VP	12.99% to 13.56%
Transamerica BlackRock Large Cap Value VP	14.62% to 15.14%
Transamerica AEGON High Yield Bond VP	8.72% to 9.26%
Transamerica PIMCO Total Return VP	2.12% to 2.62%
Transamerica Diversified Equity VP	16.42% to 16.98%
Transamerica Balanced VP	6.87% to 7.46%
Transamerica WMC Diversified Growth VP	6.52% to 7.06%
Transamerica Money Market VP	2.68% to 3.14%
Transamerica Morgan Stanley Active International Allocation VP	21.07% to 21.63%
Transamerica Multi Managed Large Cap Core VP	8.17% to 8.65%
Transamerica Morgan Stanley Mid-Cap Growth VP	7.71% to 8.23%

123

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

5. Administrative and Mortality and Expense Risk Charges

TLIC deducts a daily administrative charge equal to an annual rate of .15% of the contract owner’s account for administrative expenses. TLIC also deducts an annual charge, not to exceed $35, proportionately from the subaccounts’ unit values. An annual charge ranging from 1.40% to 2.15% is deducted (based on the death benefit selected) from the unit values of the subaccounts of the Separate Account for TLIC’s assumption of certain mortality and expense risks incurred in connection with the contract. The charge is assessed daily based on the net asset value of the Mutual Fund. Charges for administrative and mortality and expense risk are an expense of the Separate Account. Charges reflected above are those currently assessed and may be subject to change. Contract owners should see their actual policy and any related attachments to determine their specific charges.

In addition to M&E, the following subaccounts are assessed a daily charge for fund facilitation fees:

Subaccount	Additional Fund Facilitation Fee Assessed
AllianceBernstein Balanced Wealth Strategy Portfolio		0.20	%
Franklin Templeton VIP Founding Funds Allocation		0.15	%
American Funds – Asset Allocation Fund		0.30	%
American Funds – Bond Fund		0.30	%
American Funds – Growth Fund		0.30	%
American Funds – Growth – Income Fund		0.30	%
American Funds – International Fund		0.30	%
GE Investments Total Return Fund		0.20	%

6. Income Taxes

Operations of the Separate Account form a part of TLIC, which is taxed as a life insurance company under Subchapter L of the Internal Revenue Code of 1986, as amended (the Code). The operations of the Separate Account are accounted for separately from other operations of TLIC for purposes of federal income taxation. The Separate Account is not separately taxable as a regulated investment company under Subchapter M of the Code and is not otherwise taxable as an entity separate from TLIC. Under existing federal income tax laws, the income of the Separate Account is not taxable to TLIC, as long as earnings are credited under the variable annuity contracts.

7. Dividend Distributions

Dividends are not declared by the Separate Account, since the increase in the value of the underlying investment in the Mutual Funds is reflected daily in the accumulation unit price used to calculate the equity value within the Separate Account. Consequently, a dividend distribution by the Mutual Funds does not change either the accumulation unit price or equity values within the Separate Account.

124

Transamerica Life Insurance Company

Separate Account VA C

Notes to Financial Statements

December 31, 2010

8. Fair Value Measurements and Fair Value Hierarchy

ASC 820 defines fair value, establishes a framework for measuring fair value, establishes a fair value hierarchy based on the nature of inputs used to measure fair value and enhances disclosure requirements for fair value measurements.

The Separate Account has categorized its financial instruments into a three level hierarchy which is based on the priority of the inputs to the valuation technique. The fair value hierarchy gives the highest priority to quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). If the inputs used to measure fair value fall within different levels of the hierarchy, the category level is based on the lowest priority level input that is significant to the fair value measurement of the instrument.

Financial assets and liabilities recorded at fair value on the Statements of Assets and Liabilities are categorized as follows:

Level 1. Unadjusted quoted prices for identical assets or liabilities in an active market.

Level 2. Quoted prices in markets that are not active or inputs that are observable either directly or indirectly for substantially the full term of the asset or liability. Level 2 inputs include the following:

a) Quoted prices for similar assets or liabilities in active markets

b) Quoted prices for identical or similar assets or liabilities in non-active markets

c) Inputs other than quoted market prices that are observable

d) Inputs that are derived principally from or corroborated by observable market data through correlation or other means.

Level 3. Prices or valuation techniques that require inputs that are both unobservable and significant to the overall fair value measurement. They reflect management’s own assumptions about the assumptions a market participant would use in pricing the asset or liability.

All investments in the Mutual Funds included in the Statements of Assets and Liabilities are stated at fair value and are based upon daily unadjusted quoted prices, therefore are considered Level 1.

9. Subsequent Events

The Separate Account has evaluated the financial statements for subsequent events through the date which the financial statements were issued. During this period, there were no subsequent events requiring recognition or disclosure in the financial statements.

125

PART C

OTHER INFORMATION

Item 24.    Financial Statements and Exhibits

(a)  Financial Statements

All required financial statements are included in Part B of this Registration Statement.

(b)  Exhibits:

(1)	(a)		Resolution of the Board of Directors of PFL Life Insurance Company authorizing establishment of the Separate Account. Note 4
(2)			Not Applicable
(3)	(a)		Principal Underwriting Agreement by and between PFL Life Insurance Company, on its own behalf and on the behalf of the Separate Account, and AFSG Securities Corporation. Note 5
	(a)	(1)	Form of Amended and Reinstated Principal Underwriting Agreement by and between AFSG Securities Corporation and Transamerica Life Insurance Company on its behalf and on behalf of the separate investment accounts. Note 18.
	(a)	(2)	Amendment No. 8 and Novation to Amended and Restated Principal Underwriting Agreement Note 30.
	(a)	(3)	Amendment No. 10 to Amended and Restated Principal Underwriting Agreement. Note 36.
	(a)	(4)	Amended and Reinstated Principal Underwriting Agreement. Note 44
	(b)		Form of Broker/Dealer Supervision and Sales Agreement by and between AFSG Securities Corporation and the Broker/Dealer. Note 5
	(b)	(1)	Form of Broker/Dealer Supervision and Sales Agreement (TCI). Note 33.
(4)	(a)		Form of Group Master Policy and Optional Riders for the Endeavor Generations Plus Variable Annuity. Note 4
	(b)		Form of Group Certificate for the Endeavor Generations Plus Variable Annuity. Note 4
	(c)		Form of Individual Policy for the Endeavor Generations Plus Variable Annuity. Note 4
	(c)	(1)	Form of Policy for the Separate Account VA C. Note 12
	(c)	(2)	Form of Policy Rider (Additional Death Distribution). Note 12
	(c)	(3)	Form of Policy Endorsement (Initial Payment Guarantee). Note 12
	(c)	(4)	Form of Policy Rider (Managed Annuity Program), Note 14
	(c)	(5)	Form of Policy for Separate Account VA C. Note 20
	(c)	(6)	Form of Policy Rider (MAP II). Note 19
	(d)		Form of Policy Rider (GPS) Note 25.
	(e)		Form of Policy Rider (5 for Life) Note 25.
	(f)		Form of Policy Rider (ADD+) Note 25.
	(g)		Form of Rider (5 for Life with Growth - without Death Benefit) Note 28.
	(h)		Form of Rider (5 for Life with Growth - with Death Benefit). Note 28.
	(i)		Form of Rider (Income Select for Life). Note 29.
	(j)		Form of Rider (Double Enhanced). Note 32.
	(k)		Form of Rider (Annual Step-Up). Note 31.
	(l)		Form of Rider (Retirement Income Choice). Note 32.
	(m)		Form of Endorsement (Fund Facilitation Fee). Note 35.
	(n)		Form of Policy Rider (Retirement Income Choice - Double Withdrawal Base Benefit). Note 35.
	(o)		Form of Policy Rider (Retirement Income Choice 1.2). Note 38
	(p)		Form of Policy Rider (Retirement Income Choice 1.4). Note 39.
	(q)		Form of Policy Rider (Income Link). Note 42.
	(r)		Form of Rider (RIM). Note 45.
(5)	(a)		Form of Group Master Application for the Endeavor Generations Plus Variable Annuity. Note 4
	(b)		Form of Group Certificate Enrollment Application for the Endeavor Generations Plus Variable Annuity. Note 4
	(c)		Form of Individual Application for the Endeavor Generations Plus Variable Annuity. Note 4
	(c)	(1)	Form of Individual Application for the Separate Account VA C. Note 12
	(c)	(2)	Form of Individual Application for the Separate Account VA C. Note 20
	(d)		Form of Application. Note 21
	(e)		Form of Application. Note 39.
(6)	(a)		Articles of Incorporation of PFL Life Insurance Company. Note 1
	(b)		ByLaws of PFL Life Insurance Company. Note 1
(7)			Reinsurance Agreement. Note 24.
	(a)		Reinsurance agreement between Transamerica Life Insurance & Annuity Company and Swiss RE Life & Health America Inc. dated January 2, 1998. Note 38.
	(b)		Reinsurance agreement between Transamerica Occidental Life Insurance Company and North America Reassurance Company dated July 1, 1994. Note 38.
	(c)		Reinsurance agreement No. FUV-1 between Transamerica Life Insurance Company and Union Hamilton Reinsurance Limited dated April 1, 2001. Note 38.
	(c)	1	Reinsurance agreement Amendment No. 1 to agreement FUV-1 between Transamerica Life Insurance Company and Union Hamilton Reinsurance Limited dated April 1, 2001. Note 38.
	(d)		Reinsurance Agreement No. FUV-011 between Transamerica Life Insurance Company and Scottish Annuity & Life International Insurance Company (Bermuda) Limited initial dated April 1, 2001, Amended and Restated – May 1, 2007. Note 38.
	(e)		Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 31, 2008. Note 38.
(7)	(e)	(1)	Amendment No. 1 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 30, 2008. Note 44.
	(e)	(2)	Amendment No. 2 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 29, 2009. Note 44.
	(e)	(3)	Amendment No. 3 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated May 27, 2010. Note 44.
	(f)		Reinsurance Agreement between American United Life Insurance Company and Transamerica Life Insurance Company dated July 1, 2007. Note 38.
	(g)		Reinsurance Agreement between Union Hamilton Reinsurance Ltd. And Scottish Annuity & Life International Insurance Company (Bermuda) Ltd. And Transamerica Life Insurance Company dated June 30, 2008. Note 41.
(8)	(a)		Participation Agreement by and between PFL Life Insurance Company, Endeavor Management Co. and Endeavor Series Trust. Note 2
	(a)	(1)	Amendment No.6 to Participation Agreement by and between PFL Life Insurance Company, Endeavor Management Co. and Endeavor Series Trust. Note 5
	(a)	(2)	Amendment to Schedule A of the Participation Agreement by and between PFL Life Insurance Company and Endeavor Series Trust. Note 10
	(a)	(3)	Form of Termination of Participation Agreement among Transamerica Life Insurance Company, AUSA Life Insurance Company, Inc., Peoples Benefit Life Insurance Company, on their own behalf and on behalf of their separate accounts, Endeavor Series Trust and Endeavor Management Co. Note 18.
	(b)		Participation Agreement among WRL Series Fund, Inc., Western Reserve Life Assurance Co. of Ohio, and PFL Life Insurance Company, and Addendums thereof. Note 3.
	(b)	(1)	Amendment No. 12 to Participation Agreement among WRL Series Fund, Inc., PFL Life Insurance Company. AUSA Life Insurance Company, Inc., and Peoples Benefit Life Insurance Company. Note 5.
	(b)	(2)	Amendment No. 15 to Participation Agreement among WRL Series Fund, Inc., PFL Life Insurance Company, AUSA Life Insurance Company, Inc., and Peoples Benefit Life Insurance Company. Note 10
	(b)	(3)	Amendment No. 17 to Participation Agreement among WRL Series Fund, Inc. Transamerica Life Insurance Company (formerly PFL Life Insurance Company), AUSA Life Insurance Company, Inc., Peoples Benefit Life Insurance Company and Transamerica Occidental Life Insurance Company. Note 12
	(b)	(4)	Amendment No. 20 to Participation Agreement among AEGON/Transamerica Series Fund, Inc., Transamerica Life Insurance Company, AUSA Life Insurance Company, Inc., Peoples Benefit Life Insurance Company, Transamerica Occidental Life Insurance Company and Transamerica Life Insurance and Annuity Company. Note 22.
	(b)	(5)	Amendment No. 31 to Participation Agreement (AEGON/Transamerica) Note 24.
	(b)	(6)	Amendment No. 32 to Participation Agreement (AEGON/Transamerica) Note 25.
	(b)	(7)	Amendment No. 36 to Participation Agreement (Transamerica Series Trust). Note 34.
	(b)	(8)	Amendment No. 38 to Participation Agreement (TST). Note 36.
	(b)	(9)	Amendment No. 40 to Participation Agreement (TST). Note 38.
	(b)	(10)	Amendment No. 41 to Participation Agreement (TST). Note 40.
	(b)	(11)	Amendment No. 42 to Participation Agreement (TST). Note 41.
	(b)	(12)	Amendment No. 43 to Participation Agreement (TST). Note 43.
	(b)	(13)	Amendment No. 44 to Participation Agreement (TST). Note 45.
	(c)		Participation Agreement by and between PFL Life Insurance Company and Transamerica Variable Insurance Fund, Inc. Note 8.
(8)	(c)	(1)	Termination of Participation Agreement (Transamerica). Note 14.
(8)	(c)	(2)	Participation Agreement (Transamerica). Note 14.
(8)	(c)	(3)	Addendum to Participation Agreement (Transamerica). Note 14.
	(d)		Participation Agreement by and between Variable Insurance Product Funds and Variable Insurance Products Fund II, Fidelity Distributors Corporation, and PFL Life Insurance Company, and Addendums thereto. Note 6.
	(d)	(1)	Amended Schedule A to Participation Agreement by and between Variable Insurance Product Funds and Variable Insurance Products Fund II, Fidelity Distributors Corporation, and PFL Life Insurance Company. Note 8.
	(d)	(2)	Form of Amended Schedule A to Participation Agreement by and between Variable Insurance Product Funds and Variable Insurance Products Funds II, Fidelity Distributors Corporation, and Transamerica Life Insurance Company (formerly PFL Life Insurance Company). Note 12
	(d)	(3)	Amendment No. 4 to Participation Agreement by and between Variable Insurance Products Funds, Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 13
	(d)	(4)	Amendment No. 4 to Participation Agreement by and between Variable Insurance Products Fund II, Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 13
	(d)	(5)	Amended Schedule A to Participation Agreement by and between Variable Insurance Product Funds and Variable Insurance Products Fund II, Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 13
	(e)		Participation Agreement between Variable Insurance Products Fund III, Fidelity Distributors Corporation, and PFL Life Insurance Company. Note 7.
	(e)	(1)	Amended Schedule A to Participation Agreement between Variable Insurance Products Fund III, Fidelity Distributors Corporation, and PFL Life Insurance Company. Note 8.
	(e)	(2)	Amendment No. 2 to Participation Agreement by and between Variable Insurance Products Fund III, Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 13
	(e)	(3)	Amended Schedule A to Participation Agreement by and between Variable Insurance Products Fund III, Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 13
	(f)		Participation Agreement by and between Janus Aspen Series and PFL Life Insurance Company. Note 9
	(f)	(1)	Amendment No. 2 to Participation Agreement by and between Janus Aspen Series and PFL Life Insurance Company. Note 10
	(f)	(2)	Amendment No. 12 to Fund Participation Agreement (Janus Aspen Series). Note 44.
(8)	(g)		Participation Agreement by and among Alliance Variable Products Series Fund, PFL Life Insurance Company, AFSG Securities Corporation. Note 11
	(g)	(1)	Amendment No. 2 to Participation Agreement by and among Alliance Variable Products Series Fund, Transamerica Life Insurance Company (formerly PFL Life Insurance Company), AFSG Securities Corporation. Note 14
	(g)	(2)	Amendment to Participation Agreement (Alliance Bernstein). Note 36.
(8)	(h)		Participation Agreement by and among AIM Variable Insurance funds, Inc., AIM Distributors, Inc., PFL Life Insurance Company and AFSG Securities Corporation. Note 15.
	(h)	(1)	Form of Amendment No. 7 to Participation Agreement among AIM Variable Insurance Funds, AIM Distributors, Inc., Transamerica Life Insurance Company and AFSG Securities Corporation. Note 18.
(8)	(h)	(2)	Amendment to Participation Agreement (AIM/INVESCO). Note 42.
(8)	(h)	(3)	Amendment to Participation Agreement (AIM). Note 44.
(8)	(i)		Participation Agreement among MFS Variable Insurance Trust, PFL Life Insurance Company and Massachusetts Financial Services Company. Note 16.
	(i)	(1)	Partial Termination of Participation Agreement among MFS Variable Insurance Trust, PFL Life Insurance Company and Massachusetts Financial Services Company. Note 17.
	(i)	(2)	Form of Amendment to Participation Agreement by and among MFS Variable Insurance Trust, Massachusetts Financial Services Company, and Transamerica Life Insurance Company. Note 18.
(8)	(j)		Amended and Restated Participation Agreement among Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 27.
(8)	(k)		Amended and Restated Participation Agreement among Franklin/Templeton Distributors, Inc. and Transamerica Life Insurance Company. Note 38.
	(k)	(1)	Amendment No. 3 to Participation Agreement (Franklin Templeton). Note 36.
	(k)	(2)	Amendment No. 4 to Participation Agreement (Franklin Templeton). Note 44.
(8)	(l)		Participation Agreement among Transamerica Life Insurance Company; American Funds Insurance Series, and Capital Research and Management Company (“CRMC”). Note 40.
(8)	(l)	(1)	Amendment No. 2 to Participation Agreement (American Funds). Note 40.
(8)	(l)	(2)	Amendment No. 4 to Participation Agreement (American Funds). Note 40.

Page 1

(8)	(m)	Participation Agreement by and among Transamerica Life Insurance Company and GE Investments Funds, Inc. and GE Investment Distributors, Inc. and GE Asset Management Incorporated. Note 40.
(9)	(a)	Opinion and Consent of Counsel. Note 45.
	(a) (b)	Consent of Counsel. Note 45.
(10)	(a)	Consent of Independent Registered Public Accounting Firm. Note 45.
(10)	(b)	Opinion and Consent of Actuary. Note 27.
(11)		Not applicable.
(12)		Not applicable.
(13)		Performance Data Calculations. Note 27.
(14)		Powers of Attorney. Craig D. Vermie, Arthur C. Schneider, Eric J. Martin, Brenda K. Clancy, Mark Mullin, Darryl D. Button, Note 45.
Note 1.		Incorporated herein by reference to the Atlas Portfolio Builder Variable Annuity Initial Filing to Form N-4 Registration Statement (File No. 333-26209) on April 30, 1997.
Note 2.		Incorporated herein by reference to the Endeavor Series Trust Post—Effective Amendment No. 14, Exhibit No. 6 (File No. 33-27352), filed on April 29, 1996.
Note 3.		Incorporated herein by reference to the Atlas Portfolio Builder Variable Annuity filing of Post-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-26209) on April 29, 1998.
Note 4.		Filed with the Initial Filing of Form N-4 Registration Statement (333-83957) on July 29, 1999.
Note 5.		Filed with Pre-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 83957) on December 8, 1999.
Note 6.		Incorporated by reference to Pre-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-7509) on December 6, 1996.
Note 7.		Incorporated by reference to Post-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-7509) on April 29, 1997.
Note 8.		Filed with Post-Effective Amendment No. 3 to this Form N-4 Registration Statement (File No. 333-83957) on April 28, 2000
Note 9.		Incorporated by reference to Post-effective Amendment No. 3 to Form N-4 Registration Statement (333-26209) on April 28, 2000.
Note 10.		Filed with Post-Effective Amendment No. 4 to this Form N-4 Registration Statement (File No. 333-83957) on October 3, 2000.
Note 11.		Incorporated by reference to Post-Effective Amendment No. 3 to Form N-4 Registration Statement (File No. 333-26209) on April 28, 2000.
Note 12.		Filed with Post-Effective Amendment No. 7 to Form N-4 Registration Statement (File No. 333-83957) on April 27, 2001.
Note 13.		Incorporated by reference to Pre-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-63086) on September 13, 2001.
Note 14.		Incorporated by reference to Post-Effective Amendment No. 26 to Form N-4 Registration Statement (File No. 33-33085 on October 2, 2001.
Note 15.		Incorporated herein by reference to Post-Effective Amendment No. 5 to Form N-4 Registration Statement (File No. 333-7509) on July 16, 1998.
Note 16.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-7509) on December 23, 1997.
Note 17.		Incorporated herein by reference to Post-Effective Amendment No. 8 to Form N-4 Registration Statement (File No. 333-7509) on April 29, 1999.
Note 18.		Filed with Post-Effective Amendment No. 12 to Form N-4 Registration Statement (File No. 333-83957) on April 29, 2002
Note 19.		Incorporated herein by reference to Post-Effective Amendment No. 31 to Form N-4 Registration Statement (File No. 33-33085) on October 15, 2002.
Note 20.		Filed with Pre-Effective Amendment No. 13 to this Form N-4 Registration Statement (File No. 333-83957) on December 30, 2002.
Note 21.		Filed with Post-Effective Amendment No. 16 to Form N-4 Registration Statement (File No. 333-83957) on April 29, 2003
Note 22.		Filed with Post-Effective No. 18 to Form N-4 Registration Statement (File No. 333-83957) on April 29, 2004.
Note 23.		Incorporated herein by reference to Initial Filing to N-4 Registration Statement (File No. 333-116562) on June 17, 2004.
Note 24.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-109580) on January 7, 2005.
Note 25.		Filed with Post-Effective Amendment No. 21 to this Form N-4 Registration Statement (File No. 333-83957) on April 27, 2005.
Note 26.		Incorporated by reference to Post-Effective Amendment No. 38 to Form N-4 Registration Statement (File No. 33-33085) on September 12, 2005.
Note 27.		Filed with Post-Effective Amendment No. 21 to this Form N-4 Registration Statement (File No. 333-83957) on April 27, 2006.
Note 28.		Incorporated herein by reference to Post-Effective Amendment No. 39 to this Form N-4 Registration Statement (File No. 33-33085) on December 12, 2005.
Note 29.		Incorporated herein by reference to Pre-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-131987) filed on July 19, 2006.
Note 30.		Filed with Post-Effective Amendment No. 22 to this Form N-4 Registration Statement (File No. 333-83957) on April 30, 2007.
Note 31.		Incorporated herein by reference to Initial Filing on Form N-4 Registration Statement (File No. 333-131987) filed on February 22, 2006.
Note 32.		Filed with Post-Effective Amendment No. 22 to this Form N-4 Registration Statement (File No. 333-83957) on September 21, 2007.
Note 33.		Incorporated herein by reference to Post-Effective Amendment No. 6 to Form N-4 Registration Statement (File No. 333-12581 filed on February 15, 2008.
Note 34.		Filed with Post-Effective Amendment No. 24 to this Form N-4 Registration Statement (File No. 333-83957) on April 30, 2008.
Note 35.		Incorporated herein by reference to Post-Effective Amendment No. 5 to Form N-4 Registration Statement (File No. 333-131987) filed on August 14, 2008.
Note 36.		Filed with Post-Effective Amendment 25 to this Form N-4 Registration Statement (File No. 333-83957) on November 6, 2008.
Note 37.		Incorporated herein by Reference to Initial Filing on Form N4 Registration Statement (File No. 333-156259) filed on December 18, 2008.
Note 38.		Filed with Post-Effective Amendment No. 26 to this Form N-4 Registration Statement (File No. 333-83957) on April 30, 2009.
Note 39.		Incorporated herein by reference to Post-Effective Amendment No. 9 to N-4 Registration Statement (333-142762) filed on August 31, 2009.
Note 40.		Filed with Post-Effective Amendment No. 28 to this Form N-4 Registration Statement (File No. 333-83957) filed on November 19, 2009.
Note 41.		Filed with Post-Effective Amendment No. 29 to this Form N-4 Registration Statement (File No. 333-83957) filed on April 23, 2010.
Note 42.		Filed with Post-Effective Amendment No. 30 to this Form N-4 Registration Statement (File 333-83957) filed on August 6, 2010.
Note 43.		Incorporated herein by reference to Initial Filing to Form N-4 Registration Statement (File No. 333-169445) filed on September 17, 2010.
Note 44		Filed with Post-Effective Amendment 31 to this Form N-4 Registration Statement (File No. 333-83957) filed on February 15, 2011.
Note 45.		Filed herewith.

Page 2

Item 25.    Directors and Officers of the Depositor (Transamerica Life Insurance Company)

Name and Business Address	Principal Positions and Offices with Depositor
Craig D. Vermie   4333 Edgewood Road, N.E.   Cedar Rapids, Iowa 52499-0001	Director, Senior Vice President, Secretary and General Counsel
Arthur C. Schneider   4333 Edgewood Road, N.E.   Cedar Rapids, Iowa 52499-0001	Director, Chief Tax Officer, and Senior Vice President
Eric J. Martin   4333 Edgewood Road, N.E.   Cedar Rapids, Iowa 52499-0001	Senior Vice President and Corporate Controller
Brenda K. Clancy   4333 Edgewood Road, N.E.   Cedar Rapids, Iowa 52499-0001	Director, President and Chairman of the Board
Darryl Button   4333 Edgewood Road, N.E   Cedar Rapids, Iowa 52499-0001	Director, Executive Vice President and Chief Financial Officer
Mark W. Mullin   4333 Edgewood Road, N.E.   Cedar Rapids, Iowa 52499-0001	Director and Chief Executive Officer

Page 3

Item 26. Persons Controlled by or under Common Control With the Depositor or Registrant.

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Academy Alliance Holdings Inc.	Canada	100% Creditor Resources, Inc.	Holding company
Academy Alliance Insurance Inc.	Canada	100% Creditor Resources, Inc.	Insurance
AEGON Alliances, Inc.	Virginia	100% Commonwealth General Corporation	Insurance company marketing support
AEGON Asset Management Services, Inc.	Delaware	100% AUSA Holding Co.	Registered investment advisor
AEGON Assignment Corporation	Illinois	100% AEGON Financial Services Group, Inc.	Administrator of structured settlements
AEGON Assignment Corporation of Kentucky	Kentucky	100% AEGON Financial Services Group, Inc.	Administrator of structured settlements
AEGON Canada ULC	Canada	AEGON Canada Holding B.V. owns 168,250,001 shares of Common Stock; 1,500 shares of Series III Preferred stock; 2 shares of Series II Preferred stock. TIHI Canada Holding, LLC owns 1,441,941.26 shares of Class B—Series I Preferred stock.	Holding company
AEGON Capital Management Inc.	Canada	100% AEGON Asset Management (Canada) B.V.	Portfolio management company/investment advisor
AEGON-CMF GP, LLC	Delaware	Transamerica Realty Services, Inc. is sole Member	Investment in commercial mortgage loans
AEGON Core Mortgage Fund, LP	Delaware	General Partner—AEGON-CMF GP, LLC	Investment in mortgages
AEGON Direct Marketing Services, Inc.	Maryland	Monumental Life Insurance Company owns 103,324 shares; Commonwealth General Corporation owns 37,161 shares	Marketing company
AEGON Direct Marketing Services Australia Pty Ltd.	Australia	100% Transamerica Direct Marketing Asia Pacific Pty Ltd.	Marketing/operations company
AEGON Direct Marketing Services e Corretora de Seguros Ltda.	Brazil	749,000 quota shares owned by AEGON DMS Holding B.V.; 1 quota share owned by AEGON International B.V.	Brokerage company
AEGON Direct Marketing Services Europe Ltd.	United Kingdom	100% Cornerstone International Holdings, Ltd.	Marketing
AEGON Direct Marketing Services Hong Kong Limited	China	100% AEGON DMS Holding B.V.	Provide consulting services ancillary to the marketing of insurance products overseas.
AEGON Direct Marketing Services Insurance Broker (HK) Limited	Hong Kong	100% AEGON Direct Marketing Services Hong Kong Limited	Brokerage company
AEGON Direct Marketing Services International, Inc.	Maryland	100% AUSA Holding Company	Marketing arm for sale of mass marketed insurance coverage
AEGON Direct Marketing Services Japan K.K.	Japan	100% AEGON DMS Holding B.V.	Marketing company
AEGON Direct Marketing Services Korea Co., Ltd.	Korea	100% AEGON DMS Holding B.V.	Provide consulting services ancillary to the marketing of insurance products overseas.
AEGON Direct Marketing Services Mexico, S.A. de C.V.	Mexico	100% AEGON DMS Holding B.V.	Provide management advisory and technical consultancy services.
AEGON Direct Marketing Services Mexico Servicios, S.A. de C.V.	Mexico	100% AEGON DMS Holding B.V.	Provide marketing, trading, telemarketing and advertising services in favor of any third party, particularly in favor of insurance and reinsurance companies.

As of 1/1/2011 Page 1

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
AEGON Direct Marketing Services, Inc.	Taiwan	100% AEGON DMS Holding B.V.	Authorized business: Enterprise management consultancy, credit investigation services, to engage in business not prohibited or restricted under any law of R.O.C., except business requiring special permission of government
AEGON Direct Marketing Services (Thailand) Ltd.	Thailand	93% Transamerica International Direct Marketing Consultants, LLC; remaining 7% held by various AEGON employees	Marketing of insurance products in Thailand
AEGON Financial Services Group, Inc.	Minnesota	100% Transamerica Life Insurance Company	Marketing
AEGON Fund Management Inc.	Canada	100% AEGON Asset Management (Canada) B.V.	Mutual fund manager
AEGON Funding Company, LLC.	Delaware	100% AEGON USA, LLC	Issue debt securities-net proceeds used to make loans to affiliates
AEGON Institutional Markets, Inc.	Delaware	100% Commonwealth General Corporation	Provider of investment, marketing and administrative services to insurance companies
AEGON Life Insurance Agency Inc.	Taiwan	100% AEGON Direct Marketing Services, Inc. (Taiwan Domiciled)	Life insurance
AEGON Managed Enhanced Cash, LLC	Delaware	Members: Transamerica Life Insurance Company (90.2543%) ; Monumental Life Insurance Company (9.7457%)	Investment vehicle for securities lending cash collateral
AEGON Management Company	Indiana	100% AEGON U.S. Holding Corporation	Holding company
AEGON N.V.	Netherlands	22.446% of Vereniging AEGON Netherlands Membership Association	Holding company
AEGON Stable Value Solutions Inc.	Delaware	100% Commonwealth General Corporation	Principle Business: Provides management services to the stable value division of AEGON insurers who issue synthetic GIC contracts.
AEGON Structured Settlements, Inc.	Kentucky	100% Commonwealth General Corporation	Administers structured settlements of plaintiff’s physical injury claims against property and casualty insurance companies
AEGON U.S. Holding Corporation	Delaware	100% Transamerica Corporation	Holding company
AEGON USA Asset Management Holding, LLC	Iowa	100% AUSA Holding Company	Holding company
AEGON USA Investment Management, LLC	Iowa	100% AEGON USA Asset Management Holding, LLC	Investment advisor
AEGON USA Real Estate Services, Inc.	Delaware	100% AEGON USA Realty Advisors, Inc.	Real estate and mortgage holding company
AEGON USA Realty Advisors, LLC	Iowa	Sole Member—AEGON USA Asset Management Holding, LLC	Administrative and investment services
AEGON USA Realty Advisors of California, Inc.	Iowa	100% AEGON USA Realty Advisors, Inc.	Investments
AEGON USA Travel and Conference Services LLC	Iowa	100% Money Services, Inc.	Travel and conference services
AEGON USA, LLC	Iowa	100% AEGON U.S. Holding Corporation	Holding company
AFSG Securities Corporation	Pennsylvania	100% Commonwealth General Corporation	Inactive
ALH Properties Eight LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Eleven LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Four LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Nine LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Seven LLC	Delaware	100% FGH USA LLC	Real estate

As of 1/1/2011 Page 2

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
ALH Properties Seventeen LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Sixteen LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Ten LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Twelve LLC	Delaware	100% FGH USA LLC	Real estate
ALH Properties Two LLC	Delaware	100% FGH USA LLC	Real estate
American Bond Services LLC	Iowa	100% Transamerica Life Insurance Company (sole member)	Limited liability company
ARC Reinsurance Corporation	Hawaii	100% Transamerica Corporation	Property & Casualty Insurance
ARV Pacific Villas, A California Limited Partnership	California	General Partners—Transamerica Affordable Housing, Inc. (0.5%); Non-Affiliate of AEGON, Jamboree Housing Corp. (0.5%). Limited Partner: Transamerica Life Insurance Company (99%)	Property
Asia Business Consulting Company	China	100% Asia Investments Holdings, Limited	Provide various services upon request from Beijing Dafu Insurance Agency.
Asia Investments Holdings, Limited	Hong Kong	99% Transamerica Life Insurance Company	Holding company
AUSA Holding Company	Maryland	100% AEGON USA, LLC	Holding company
AUSA Properties, Inc.	Iowa	100% AUSA Holding Company	Own, operate and manage real estate
AUSACAN LP	Canada	General Partner—AUSA Holding Co. (1%); Limited Partner—AEGON USA, LLC (99%)	Inter-company lending and general business
Bay Area Community Investments I, LLC	California	70%Transamerica Life Insurance Company; 30% Monumental Life Insurance Company	Investments in low income housing tax credit properties
Bay State Community Investments I, LLC	Delaware	100% Monumental Life Insurance Company	Investments in low income housing tax credit properties
Bay State Community Investments II, LLC	Delaware	100% Monumental Life Insurance Company	Investments in low income housing tax credit properties
Beijing Dafu Insurance Agency Co. Ltd.	Peoples Republic of China	10% owned by WFG China Holdings, Inc.; 90% owned by private individual (non-AEGON associated)	Insurance Agency
Canadian Premier Holdings Ltd.	Canada	100% AEGON DMS Holding B.V.	Holding company
Canadian Premier Life Insurance Company	Canada	100% Canadian Premier Holdings Ltd.	Insurance company
Capital General Development Corporation	Delaware	2.64 shares of common stock owned by AEGON USA, LLC 18.79 shares of common stock owned by Commonwealth General Corporation	Holding company
CBC Insurance Revenue Securitization, LLC	Delaware	100% Clark Consulting, LLC	Special purpose
CC Matteson, LLC	Illinois	Members: Monumental Life Insurance Company (83.03%); Pan-American Life Insurance Company, a non-affiliate of AEGON (9.75%); Nationwide Life Insurance Company, a non-affiliate of AEGON (7.22%)	Ownership of commercial real estate acquired via remedies enforcement.
Chicago Community Housing Fund I, LLC	Delaware	100% Transamerica Life Insurance Company	Investments
Clark/Bardes (Bermuda) Ltd.	Bermuda	100% Clark, LLC	Insurance agency
Clark, LLC	Delaware	Sole Member—Diverisified Investment Advisors, Inc.	Holding company
Clark Consulting, LLC	Delaware	100% Clark, LLC	Financial consulting firm
Clark Investment Strategies, inc.	Delaware	100% Clark Consulting, LLC	Registered investment advisor
Clark Securities, Inc.	California	100% Clark Consulting, LLC	Broker-Dealer
Commonwealth General Corporation	Delaware	100% AEGON U.S. Holding Corporation	Holding company
Consumer Membership Services Canada Inc.	Canada	100% Canadian Premier Holdings Ltd.	Marketing of credit card protection membership services in Canada

As of 1/1/2011 Page 3

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Cornerstone International Holdings Ltd.	UK	100% AEGON DMS Holding B.V.	Holding company
CRG Insurance Agency, Inc.	California	100% Clark Consulting, Inc.	Insurance agency
Creditor Resources, Inc.	Michigan	100% AUSA Holding Co.	Credit insurance
CRI Canada Inc.	Canada	100% Creditor Resources, Inc.	Holding company
CRI Credit Group Services Inc.	Canada	100% Creditor Resources, Inc.	Holding company
CRI Solutions Inc.	Maryland	100% Creditor Resources, Inc.	Sales of reinsurance and credit insurance
Cupples State LIHTC Investors, LLC	Delaware	100% Garnet LIHTC Fund VIII, LLC	Investments
Diversified Actuarial Services, Inc.	Massachusetts	100% Diversified Investment Advisors, Inc.	Employee benefit and actuarial consulting
Diversified Investment Advisors, Inc.	Delaware	100% AUSA Holding Company	Registered investment advisor
Diversified Investors Securities Corp.	Delaware	100% Diversified Investment Advisors, Inc.	Broker-Dealer
Erfahrungsschatz GmbH	Germany	100% Cornerstone International Holdings, Ltd.	Marketing/membership
FD TLIC, LIMITED LIABILITY COMPANY	New York	100% Transamerica Life Insurance Company	Broadway production
FD TLIC Ltd.	United Kingdom	100% FD TLIC, LLC	Theatre production
FGH Realty Credit LLC	Delaware	100% FGH USA, LLC	Real estate
FGH USA LLC	Delaware	100% RCC North America LLC	Real estate
FGP 90 West Street LLC	Delaware	100% FGH USA LLC	Real estate
FGP West Mezzanine LLC	Delaware	100% FGH USA LLC	Real estate
FGP West Street LLC	Delaware	100% FGP West Mezzanine LLC	Real estate
FGP West Street Two LLC	Delaware	100% FGH USA LLC	Real estate
Fifth FGP LLC	Delaware	100% FGH USA LLC	Real estate
Financial Planning Services, Inc.	District of Columbia	100% Commonwealth General Corporation	Special-purpose subsidiary
First FGP LLC	Delaware	100% FGH USA LLC	Real estate
Fourth & Market Funding, LLC	Delaware	Commonwealth General Corporation owns 0% participating percentage, but is Managing Member. Ownership: 99% Monumental Life Insurance Company and 1% Garnet Assurance Corporation II	Inactive
Fourth FGP LLC	Delaware	100% FGH USA LLC	Real estate
Garnet Assurance Corporation	Kentucky	100%Transamerica Life Insurance Company	Investments
Garnet Assurance Corporation II	Iowa	100% Commonwealth General Corporation	Business investments
Garnet Assurance Corporation III	Iowa	100% Transamerica Life Insurance Company	Business investments
Garnet Community Investments, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments II, LLC	Delaware	100% Monumental Life Insurance Company	Securities
Garnet Community Investments III, LLC	Delaware	100%Transamerica Life Insurance Company	Business investments
Garnet Community Investments IV, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments V, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments VI, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments VII, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments VIII, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments IX, LLC	Delaware	100% Monumental Life Insurance Company	Investments

As of 1/1/2011 Page 4

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Garnet Community Investments X, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments XI, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments XII, LLC	Delaware	100% Monumental Life Insurance Company	Investments
Garnet Community Investments XVIII, LLC	Delaware	100% Transamerica Life Insurance Company	Investments
Garnet Community Investments XX, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet Community Investments XXIV, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Real estate investments
Garnet Community Investments XXV, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet Community Investment XXVI, LLC	Delaware	100% Transamerica Life Insurance Company	Investments
Garnet Community Investments XXVII, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet Community Investment XXVIII, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet Community Investments XXIX, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet Community Investments XXX, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet LIHTC Fund II, LLC	Delaware	Members: Garnet Community Investments II, LLC (0.01%); Metropolitan Life Insurance Company, a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund III, LLC	Delaware	Members: Garnet Community Investments III, LLC (0.01%); Jefferson-Pilot Life Insurance Company, a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund IV, LLC	Delaware	Members: Garnet Community Investments IV, LLC (0.01%); Goldenrod Asset Management, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund V, LLC	Delaware	Members: Garnet Community Investments V, LLC (0.01%); Lease Plan North America, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund VI, LLC	Delaware	Members: Garnet Community Investments VI, LLC (0.01%); Pydna Corporation, a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund VII, LLC	Delaware	Members: Garnet Community Investments VII, LLC (0.01%); J.P. Morgan Chase Bank, N.A., a non-AEGON affiliate(99.99%)	Investments
Garnet LIHTC Fund VIII, LLC	Delaware	Members: Garnet Community Investments VIII, LLC (0.01%); J.P. Morgan Chase Bank, N.A., a non-AEGON affiliate(99.99%)	Investments
Garnet LIHTC Fund IX, LLC	Delaware	Members: Garnet Community Investments IX, LLC (0.01%); Bank of America, N.A., a non-AEGON affiliate (99.99%)	Investments

As of 1/1/2011 Page 5

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Garnet LIHTC Fund X, LLC	Delaware	Members: Garnet Community Investments X, LLC (0.01%); Goldenrod Asset Management, a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XI, LLC	Delaware	Members: Garnet Community Investments XI, LLC (0.01%); NorLease, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XII, LLC	Delaware	Garnet Community Investments XII, LLC (.01%); and the following non-AEGON affiliates: Bank of America, N.A.( 73.39%); J.P. Morgan Chase Bank, N.A. (13.30%); NorLease, Inc. (13.30%)	Investments
Garnet LIHTC Fund XII-A, LLC	Delaware	Garnet Community Investments XII, LLC (0.01%); Bank of America, N.A., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XII-B, LLC	Delaware	Garnet Community Investments XII, LLC (0.01%); J.P. Morgan Chase Bank, N.A., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XII-C, LLC	Delaware	Garnet Community Investments XII, LLC (.01%); NorLease, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XIII, LLC	Delaware	Garnet Community Investments XII, LLC (.01%); and the following non-AEGON affiliates: Bank of America, N.A.( 73.39%); J.P. Morgan Chase Bank, N.A. (13.30%); NorLease, Inc. (13.30%)	Investments
Garnet LIHTC Fund XIII-A, LLC	Delaware	Garnet Community Investments XII, LLC (.01%); J.P. Morgan Chase Bank, N.A., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XIII-B, LLC	Delaware	Garnet Community Investments XII, LLC (.01%); Norlease, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XIV, LLC	Delaware	0.01% Garnet Community Investments, LLC; 49.995% Wells Fargo Bank, N.A.; and 49.995% Goldenrod Asset Management, Inc.	Investments
Garnet LIHTC Fund XV, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); Bank of America, N.A., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XVI, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); FNBC Leasing Corporation, a non-AEGON entity (99.99%)	Investments
Garnet LIHTC Fund XVII, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); ING USA Annuity and Life Insurance company, a non-affiliate of AEGON (12.999%), and ReliaStar Life Insurance Company, a non-affiliate of AEGON (86.991%).	Investments

As of 1/1/2011 Page 6

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Garnet LIHTC Fund XVIII, LLC	Delaware	Members: Garnet Community Investments XVIII, LLC (0.01%); Verizon Capital Corp., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XIX, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); Bank of America, N.A., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XX, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet LIHTC Fund XXI, LLC	Delaware	100% Garnet Community Investments, LLC	Investments
Garnet LIHTC Fund XXII, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); Norlease, Inc., a non-AEGON affiliate (99.99%)	Investments
Garnet LIHTC Fund XXIII, LLC	Delaware	Members: Garnet Community Investments, LLC (0.01%); Idacorp Financial Services, Inc. (99.99%)	Investments
Garnet LIHTC Fund XXIV, LLC	Delaware	100% Garnet Community Investments, LLC	Investments
Garnet LIHTC Fund XXV, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet LIHTC Fund XXVI, LLC	Delaware	Members: Garnet Community Investments XXVI, LLC (0.01%); American Income Life Insurance Company, a non-affiliate of AEGON (99.99%)	Investments
Garnet LIHTC Fund XXVII, LLC	Delaware	Sole Member—Transamerica Life Insurance Company	Investments
Garnet LIHTC Fund XXVIII, LLC	Delaware	Sole Member—Garnet Community Investments XXVIII, LLC	Real estate investments
Garnet LIHTC Fund XXIX, LLC	Delaware	Managing Member—Garnet Community Investments XXIX, LLC	Investments
Garnet LIHTC Fund XXX, LLC	Delaware	Managing Member—Garnet Community Investments XXX, LLC	Investments
Global Preferred Re Limited	Bermuda	100% AEGON USA, LLC	Reinsurance
Horizons Acquisition 5, LLC	Florida	Sole Member—PSL Acquisitions Operating, LLC	Development company
Horizons St. Lucie Development, LLC	Florida	Sole Member—PSL Acquisitions Operating, LLC	Development company
Innergy Lending, LLC	Delaware	50% World Financial Group, Inc.; 50% ComUnity Lending, Inc.(non-AEGON entity)	In the process of being dissolved
Intersecurities Insurance Agency, Inc.	California	100% Western Reserve Life Assurance Co. of Ohio	Insurance agency
Investment Advisors International, Inc.	Delaware	100% AUSA Holding Company	Investments
Investors Warranty of America, Inc.	Iowa	100% AUSA Holding Co.	Leases business equipment
Legacy General Insurance Company	Canada	100% Canadian Premier Holdings Ltd.	Insurance company
Life Investors Alliance, LLC	Delaware	100% Transamerica Life Insurance Company	Purchase, own, and hold the equity interest of other entities
Life Investors Financial Group, Inc.	Iowa	100% AUSA Holding Company	Special-purpose subsidiary
LIICA Holdings, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	To form and capitalize LIICA Re I, Inc.
LIICA Re I, Inc.	Vermont	100% LIICA Holdings, LLC	Captive insurance company
LIICA Re II, Inc.	Vermont	100%Transamerica Life Insurance Company	Captive insurance company
Massachusetts Fidelity Trust Company	Iowa	100% AUSA Holding Co.	Trust company
MLIC Re I, Inc.	Vermont	100% Stonebridge Life Insurance Company	Captive insurance company

As of 1/1/2011 Page 7

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Money Services, Inc.	Delaware	100% AUSA Holding Co.	Provides financial counseling for employees and agents of affiliated companies
Monumental General Administrators, Inc.	Maryland	100% AUSA Holding Company	Provides management services to unaffiliated third party administrator
Monumental Life Insurance Company	Iowa	99.72% Capital General Development Corporation; .28% Commonwealth General Corporation	Insurance Company
nVISION Financial, Inc.	Iowa	100% AUSA Holding Company	Special-purpose subsidiary
National Association Management and Consultant Services, Inc.	Maryland	100% Monumental General Administrators, Inc.	Provides actuarial consulting services
NEF Investment Company	California	100% Transamerica Life Insurance Company	Real estate development
New Markets Community Investment Fund, LLC	Iowa	50% AEGON Institutional Markets, Inc.; 50% AEGON USA Realty Advisors, Inc.	Community development entity
Oncor Insurance Services, LLC	Iowa	Sole Member—Life Investors Financial Group, Inc.	Direct sales of term life insurance
Peoples Benefit Services, Inc.	Pennsylvania	100% Stonebridge Life Insurance Company	Special-purpose subsidiary
Pine Falls Re, Inc.	Vermont	100% Stonebridge Life Insurance Company	Captive insurance company
Primus Guaranty, Ltd.	Bermuda	Partners are: Transamerica Life Insurance Company (13.1%) and non-affiliates of AEGON: XL Capital, Ltd. (34.7%); CalPERS/PCO Corporate Partners Fund, LLC (13.0%); Radian Group (11.1%). The remaining 28.1% of stock is publicly owned.	Provides protection from default risk of investment grade corporate and sovereign issues of financial obligations.
Prisma Holdings, Inc. I	Delaware	100% AEGON USA Asset Management Holding, LLC	Holding company
Prisma Holdings, Inc. II	Delaware	100% AEGON USA Asset Management Holding, LLC	Holding company
PSL Acquisitions, LLC	Iowa	Sole Member: Investors Warranty of America, Inc.	Aquirer of Core Florida mortgage loans from Investors Warranty and holder of foreclosed read estate.
PSL Acquisitions Operating, LLC	Iowa	Sole Member: Investors Warranty of America, Inc.	Owner of Core subsidiary entities
Pyramid Insurance Company, Ltd.	Hawaii	100% Transamerica Corporation	Property & Casualty Insurance
Quantitative Data Solutions, LLC	Delaware	100% Transamerica Life Insurance Company	Special purpose corporation
RCC North America LLC	Delaware	100% AEGON USA, LLC	Real estate
Real Estate Alternatives Portfolio 1 LLC	Delaware	Members: Transamerica Life Insurance Company (90.959%); Monumental Life Insurance Company (6.301%); Transamerica Financial Life Insurance Company (2.74%). Manager: AEGON USA Realty Advisors, Inc.	Real estate alternatives investment
Real Estate Alternatives Portfolio 2 LLC	Delaware	Members are: Transamerica Life Insurance Company (90.25%); Transamerica Financial Life Insurance Company (7.5%); Stonebridge Life Insurance Company (2.25%). Manager: AEGON USA Realty Advisors, Inc.	Real estate alternatives investment
Real Estate Alternatives Portfolio 3 LLC	Delaware	Members are: Transamerica Life Insurance Company (73.4%); Monumental Life Insurance Company (25.6%); Stonebridge Life Insurance Company (1%). Manager: AEGON USA Realty Advisors, Inc.	Real estate alternatives investment

As of 1/1/2011 Page 8

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Real Estate Alternatives Portfolio 3A, Inc.	Delaware	Members: Monumental Life Insurance Company (37%); Transamerica Financial Life Insurance Company (9.4%); Transamerica Life Insurance Company (52.6%); Stonebridge Life Insurance Company (1%)	Real estate alternatives investment
Real Estate Alternatives Portfolio 4 HR, LLC	Delaware	Members are: Transamerica Life Insurance Company (64%); Monumental Life Insurance Company (32%); Transamerica Financial Life Insurance Company (4%). Manager: AEGON USA Realty Advisors, Inc.	Investment vehicle for alternative real estate investments that are established annually for our affiliated companies common investment
Real Estate Alternatives Portfolio 4 MR, LLC	Delaware	Members are: Transamerica Life Insurance Company (64%); Monumental Life Insurance Company (32%); Transamerica Financial Life Insurance Company (4%). Manager: AEGON USA Realty Advisors, Inc.	Investment vehicle for alternative real estate investments that are established annually for our affiliated companies common investment
Real Estate Alternatives Portfolio 5 RE, LLC	Delaware	AEGON USA Realty Advisors, LLC is non-owner Manager; no ownership interests at this time.	Real estate investments
Realty Information Systems, Inc.	Iowa	100% Transamerica Realty Services, LLC	Information Systems for real estate investment management
Retirement Project Oakmont	California	General Partner: Transamerica Oakmont Retirement Associates, a CA limited partnership; Transamerica Life Insurance Company (limited partner); and Oakmont Gardens, a CA limited partnership (non-AEGON entity limited partner). General Partner of Transamerica Oakmont Retirement Associates is Transamerica Oakmont Corporation. 100 units of limited partnership interests widely held by individual investors.	Senior living apartment complex
River Ridge Insurance Company	Vermont	100% AEGON Management Company	Captive insurance company
Second FGP LLC	Delaware	100% FGH USA LLC	Real estate
Selient Inc.	Canada	100% Canadian Premier Holdings Ltd.	Application service provider providing loan origination platforms to Canadian credit unions.
Seventh FGP LLC	Delaware	100% FGH USA LLC	Real estate
Short Hills Management Company	New Jersey	100% AEGON U.S. Holding Corporation	Holding company
Southwest Equity Life Insurance Company	Arizona	Voting common stock is allocated 75% of total cumulative vote—AEGON USA, LLC. Participating Common stock (100% owned by non-AEGON shareholders) is allocated 25% of total cumulative vote.	Insurance
St. Lucie West Development Company, LLC	Florida	Sole Member—PSL Acquisitions Operating, LLC	Development company

As of 1/1/2011 Page 9

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Stonebridge Benefit Services, Inc.	Delaware	100% Commonwealth General Corporation	Health discount plan
Stonebridge Casualty Insurance Company	Ohio	100% AEGON USA, LLC	Insurance company
Stonebridge Group, Inc.	Delaware	100% Commonwealth General Corporation	General purpose corporation
Stonebridge International Insurance Ltd.	UK	100% Cornerstone International Holdings Ltd.	General insurance company
Stonebridge Life Insurance Company	Vermont	100% Commonwealth General Corporation	Insurance company
Stonebridge Reinsurance Company	Vermont	100% Stonebridge Life Insurance Company	Captive insurance company
TAH-MCD IV, LLC	Iowa	Sole Member—Transamerica Affordable Housing, Inc.	Serve as the general partner for McDonald Corporate Tax Credit Fund IV Limited Partnership
TAH Pentagon Funds, LLC	Iowa	Sole Member—Transamerica Affordable Housing, Inc.	Serve as a general partner in a lower-tier tax credit entity
TAHP Fund 1, LLC	Delaware	Investor Member: Monumental Life Insurance Company	Real estate investments
TAHP Fund 2, LLC	Delaware	Sole Member—Garnet LIHTC Fund VIII, LLC	Low incoming housing tax credit
TAHP Fund VII, LLC	Delaware	Investor Member: Garnet LIHTC Fund XIX, LLC	Real estatement investments
TCF Asset Management Corporation	Colorado	100% TCFC Asset Holdings, Inc.	A depository for foreclosed real and personal property
TCFC Air Holdings, Inc.	Delaware	100% Transamerica Commercial Finance Corporation, I	Holding company
TCFC Asset Holdings, Inc.	Delaware	100% Transamerica Commercial Finance Corporation, I	Holding company
TCFC Employment, Inc.	Delaware	100% Transamerica Commercial Finance Corporation, I	Used for payroll for employees at Transamerica Finance Corporation
The AEGON Trust Advisory Board: Mark W. Mullin, Alexander R. Wynaendts, and Craig D. Vermie	Delaware	AEGON International B.V.	Voting Trust
The RCC Group, Inc.	Delaware	100% FGH USA LLC	Real estate
THH Acquisitions, LLC	Iowa	Sole Member—Investors Waranty of America, Inc.	Acquirer of Core South Carolina mortgage loans from Investors Warranty of America, Inc. and holder of foreclosed real estate.
TIHI Canada Holding, LLC	Iowa	Sole Member—Transamerica International Holdings, Inc.	Holding company
TIHI Mexico, S. de R.L. de C.V.	Mexico	95% Transamerica International Holdings, Inc.; 5% Transamerica Life Insurance Company	To render and receive all kind of administrative, accountant, mercantile and financial counsel and assistance to and from any other Mexican or foreign corporation, whether or not this company is a shareholder of them
Tradition Development Company, LLC	Florida	Sole Member—PSL Acquisitions Operating, LLC	Development company
Tradition Irrigation Company, LLC	Florida	Sole Member—PSL Acquisitions Operating, LLC	Irrigation company
Transamerica Accounts Holding Corporation	Delaware	100% TCFC Asset Holdings, Inc.	Holding company
Transamerica Advisors Life Insurance Company	Arkansas	100% AEGON USA, LLC	Insurance company
Transamerica Advisors Life Insurance Company of New York	New York	100% AEGON USA, LLC	Insurance company
Transamerica Affinity Services, Inc.	Maryland	100% AEGON Direct Marketing Services, Inc.	Marketing company
Transamerica Affordable Housing, Inc.	California	100% Transamerica Realty Services, LLC	General partner LHTC Partnership

As of 1/1/2011 Page 10

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Transamerica Annuity Service Corporation	New Mexico	100% Transamerica International Holdings, Inc.	Performs services required for structured settlements
Transamerica Asset Management, Inc.	Florida	Western Reserve Life Assurance Co. of Ohio owns 77%; AUSA Holding Co. owns 23%.	Fund advisor
Transamerica Aviation LLC	Delaware	100% TCFC Air Holdings, Inc.	Special purpose corporation
Transamerica Capital, Inc.	California	100% AUSA Holding Co.	Broker/Dealer
Transamerica Commercial Finance Corporation, I	Delaware	100% Transamerica Finance Corporation	Holding company
Transamerica Consultora Y Servicios Limitada	Chile	95% Transamerica Life Insurance Company; 5% Transamerica International Holdings, Inc.	Special purpose limited liability corporation
Transamerica Consumer Finance Holding Company	Delaware	100% TCFC Asset Holdings, Inc.	Consumer finance holding company
Transamerica Corporation	Delaware	100% The AEGON Trust	Major interest in insurance and finance
Transamerica Corporation	Oregon	100% Transamerica Corporation	Holding company
Transamerica Direct Marketing Asia Pacific Pty Ltd.	Australia	100% AEGON DMS Holding B.V.	Holding company
Transamerica Direct Marketing Consultants, LLC	Maryland	51% Hugh J. McAdorey; 49% AEGON Direct Marketing Services, Inc.	Provide consulting services ancillary to the marketing of insurance products overseas.
Transamerica Direct Marketing Consultants Private Limited	India	100% AEGON DMS Holding B.V.	Marketing consultant
Transamerica Distribution Finance—Overseas, Inc.	Delaware	100% TCFC Asset Holdings, Inc.	Commercial Finance
Transamerica Finance Corporation	Delaware	100% Transamerica Corporation	Commercial & Consumer Lending & equipment leasing
Transamerica Financial Advisors, Inc. (f/k/a InterSecurities, Inc.)	Delaware	1,00 shares owned by AUSA Holding Company; 209 shares owned by Transamerica International Holdings, Inc.	Broker/Dealer
Transamerica Financial Life Insurance Company	New York	87.40% AEGON USA, LLC; 12.60% Transamerica Life Insurance Company	Insurance
Transamerica Fund Services, Inc.	Florida	Western Reserve Life Assurance Co. of Ohio owns 44%; AUSA Holding Company owns 56%	Mutual fund
Transamerica Funding LP	U.K.	99% Transamerica Leasing Holdings, Inc.; 1% Transamerica Commercial Finance Corporation, I	Intermodal leasing
Transamerica Home Loan	California	100% Transamerica Consumer Finance Holding Company	Consumer mortgages
Transamerica Insurance Marketing Asia Pacific Pty Ltd.	Australia	100% Transamerica Direct Marketing Asia Pacific Pty Ltd.	Insurance intermediary
Transamerica International Direct Marketing Consultants, LLC	Maryland	51% Hugh J. McAdorey; 49% AEGON Direct Marketing Services, Inc.	Provide consulting services ancillary to the marketing of insurance products overseas.
Transamerica International Holdings, Inc.	Delaware	100% AEGON USA, LLC	Holding company
Transamerica International RE (Bermuda) Ltd.	Bermuda	100% AEGON USA, LLC	Reinsurance
Transamerica International Re Escritório de Representação no Brasil Ltd	Brazil	95% Transamerica International Re(Bermuda) Ltd.; 5% Transamerica International Holdings, Inc.	Insurance and reinsurance consulting
Transamerica Investment Holdings, LLC	Delaware	100 shares of Class A stock owned by Transamerica Investment Services, Inc.; 1,902.82 shares of Class B stock owned by Professional Members (employees of Transamerica Investment Services, Inc.)	Holding company

As of 1/1/2011 Page 11

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Transamerica Investment Management, LLC	Delaware	81.75% Transamerica Investment Services, Inc. as Original Member; 18.25% owned by Professional Members (employees of Transamerica Investment Services, Inc.)	Investment advisor
Transamerica Investment Services, LLC	Delaware	100% AEGON USA Asset Management Holding, LLC	Holding company
Transamerica Investors, Inc.	Maryland	100% Transamerica Asset Management, Inc.	Open-end mutual fund
Transamerica Leasing Holdings, Inc.	Delaware	100% Transamerica Finance Corporation	Holding company
Transamerica Life (Bermuda) Ltd.	Bermuda	100% Transamerica Life Insurance Company	Long-term life insurer in Bermuda——  will primarily write fixed universal life and term insurance
Transamerica Life Canada	Canada	100% AEGON Canada ULC	Life insurance company
Transamerica Life Insurance Company	Iowa	676,190 shares Common Stock owned by Transamerica International Holdings, Inc.; 86,590 shares of Preferred Stock owned by Transamerica Corporation; 30,564 shares of Preferred Stock owned by AEGON USA, LLC	Insurance
Transamerica Life Solutions, LLC	Delaware	Investors Warranty of America, Inc.—sole member	Provision of marketing, training, educational, and support services to life insurance professionals relating to the secondary market for life insurance, primarily through its affiliation with LexNet, LP, a life settlements marketplace.
Transamerica Minerals Company	California	100% Transamerica Realty Services, LLC	Owner and lessor of oil and gas properties
Transamerica Oakmont Corporation	California	100% Transamerica International Holdings, Inc.	General partner retirement properties
Transamerica Oakmont Retirement Associates	California	General Partner is Transamerica Oakmont Corporation. 100 units of limited partnership interests widely held by individual investors.	Senior living apartments
Transamerica Pacific Insurance Company, Ltd.	Hawaii	26,000 shares common stock owned by Commonwealth General Corporation; 1,000 shares of common stock owned by Transamerica International Holdings, Inc.	Life insurance
Transamerica Pyramid Properties LLC	Iowa	100% Transamerica Life Insurance Company	Realty limited liability company
Transamerica Realty Investment Properties LLC	Delaware	100% Transamerica Life Insurance Company	Realty limited liability company
Transamerica Realty Services, LLC	Delaware	AUSA Holding Company—sole Member	Real estate investments
Transamerica Retirement Management, Inc.	Minnesota	100% AEGON Financial Services Group, Inc.	Life Insurance and underwriting services
Transamerica Retirement Services Corp.	Ohio	100% AUSA Holding Company	Record keeping
Transamerica Small Business Capital, Inc.	Delaware	100% TCFC Asset Holdings, Inc.	Holding company
Transamerica Trailer Leasing Sp. Z.O.O.	Poland	100% Transamerica Leasing Holdings, Inc.	Leasing
Transamerica Vendor Financial Services Corporation	Delaware	100% TCFC Asset Holdings, Inc.	Provides commercial leasing
United Financial Services, Inc.	Maryland	100% AEGON USA, LLC	General agency
Universal Benefits, LLC	Iowa	100% AUSA Holding Co.	Third party administrator

As of 1/1/2011 Page 12

Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Western Reserve Life Assurance Co. of Ohio	Ohio	100% AEGON USA, LLC	Insurance
WFG China Holdings, Inc.	Delaware	100% World Financial Group, Inc.	Hold interest in Insurance Agency located in Peoples Republic of China
WFG Insurance Agency of Puerto Rico, Inc.	Puerto Rico	100% World Financial Group Insurance Agency, Inc.	Insurance agency
WFG Properties Holdings, LLC	Georgia	100% World Financial Group, Inc.	Marketing
WFG Property & Casualty Insurance Agency of California, Inc.	California	100% WFG Property & Casualty Insurance Agency, Inc.	Insurance agency
WFG Property & Casualty Insurance Agency of Nevada, Inc.	Nevada	100% WFG Property & Casualty Insurance Agency, Inc.	Insurance agency
WFG Property & Casualty Insurance Agency, Inc.	Georgia	100% World Financial Group Insurance Agency, Inc.	Insurance agency
WFG Reinsurance Limited	Bermuda	51% owned by World Financial Group, Inc; remaining 49% is annually offered to independent contractors associated with WFG Reinsurance Ltd.	Reinsurance
WFG Securities of Canada, Inc.	Canada	100% World Financial Group Holding Company of Canada, Inc.	Mutual fund dealer
World Financial Group Holding Company of Canada Inc.	Canada	100% Transamerica International Holdings, Inc.	Holding company
World Financial Group, Inc.	Delaware	100% AEGON Asset Management Services, Inc.	Marketing
World Financial Group Insurance Agency of Canada Inc.	Ontario	50% World Financial Group Holding Co. of Canada Inc.; 50% World Financial Group Subholding Co. of Canada Inc.	Insurance agency
World Financial Group Insurance Agency of Hawaii, Inc.	Hawaii	100% World Financial Group Insurance Agency, Inc.	Insurance agency
World Financial Group Insurance Agency of Massachusetts, Inc.	Massachusetts	100% World Financial Group Insurance Agency, Inc.	Insurance agency
World Financial Group Insurance Agency of Wyoming, Inc.	Wyoming	100% World Financial Group Insurance Agency, Inc.	Insurance agency
World Financial Group Insurance Agency, Inc.	California	100% Western Reserve Life Assurance Co. of Ohio	Insurance agency
World Financial Group Subholding Company of Canada Inc.	Canada	100% World Financial Group Holding Company of Canada, Inc.	Holding company
World Group Securities, Inc.	Delaware	100% AEGON Asset Management Services, Inc.	Broker-dealer
Zahorik Company, Inc.	California	100% AUSA Holding Co.	Inactive
Zero Beta Fund, LLC	Delaware	Members are: Transamerica Life Insurance Company (74.0181%); Monumental Life Insurance Company (23.6720%); Transamerica Financial Life Insurance Company (2.3097%). Manager: AEGON USA Investment Management LLC	Aggregating vehicle formed to hold various fund investments.

As of 1/1/2011 Page 13

Item 27.    Number of Contract Owners

As of February 10, 2011, there were 17,852 Contract owners.

Item 28.    Indemnification

The Iowa Code (Sections 490.850 et. seq.) provides for permissive indemnification in certain situations, mandatory indemnification in other situations, and prohibits indemnification in certain situations. The Code also specifies producers for determining when indemnification payments can be made.

Insofar as indemnification for liabilities arising under the Securities Act of 933 may be permitted to directors, officers and controlling persons of the Depositor pursuant to the foregoing provisions, or otherwise, the Depositor 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 Depositor of expenses incurred or paid by a director, officer or controlling person in connection with the securities being registered), the Depositor 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.

Page 4

Item 29. Principal Underwriters

(a) Transamerica Capital, Inc. serves as the principal underwriter for:

Transamerica Capital, Inc. serves as the principal underwriter for the Retirement Builder Variable Annuity Account, Separate Account VA A, Separate Account VA B, Separate Account VA C, Separate Account VA D, Separate Account VA E, Separate Account VA F, Separate Account VA I, Separate Account VA J, Separate Account VA K, Separate Account VA L, Separate Account VA P, Separate Account VA Q, Separate Account VA R, Separate Account VA S, Separate Account VA W, Separate Account VA X, Separate Account VA Y; Separate Account VA EE, Separate Account VA FF, Separate Account VA-1, Separate Account VA-2L, Separate Account VA-5, Separate Account VA-6, Separate Account VA-7, Separate Account VA-8, Separate Account Fund B, Separate Account Fund C, Transamerica Corporate Separate Account Sixteen, Transamerica Separate Account R3, Separate Account VL, Separate Account VUL-1; Separate Account VUL-2, Separate Account VUL-3, Separate Account VUL-4, Separate Account VUL-5, Separate Account VUL-6, Separate Account VUL A, and Variable Life Account A. These accounts are separate accounts of Transamerica Life Insurance Company.

Transamerica Capital, Inc. serves as principal underwriter for Separate Account VA BNY, Separate Account VA HNY, Separate Account VA QNY, Separate Account VA WNY, Separate Account VA YNY, TFLIC Separate Account VNY, Separate Account VA-2LNY, TFLIC Separate Account C, Separate Account VA-5NLNY, Separate Account VA-6NY, TFLIC Series Annuity Account and TFLIC Series Life Account. These accounts are separate accounts of Transamerica Financial Life Insurance Company.

Transamerica Capital, Inc. serves as principal underwriter for Separate Account VA U, Separate Account VA V, Separate Account VA AA, WRL Series Life Account, WRL Series Life Account G, WRL Series Life Corporate Account, WRL Series Annuity Account and WRL Series Annuity Account B. These accounts are separate accounts of Western Reserve Life Assurance Co. of Ohio.

Transamerica Capital, Inc. also serves as principal underwriter for Separate Account VA BB, Separate Account VA CC, and Separate Account VL E. This account is a separate account of Monumental Life Insurance Company.

Transamerica Capital, Inc. also serves as principal underwriter for Merrill Lynch Life Variable Annuity Separate Account, Merrill Lynch Life Variable Annuity Separate Account A, Merrill Lynch Life Variable Annuity Separate Account B, Merrill Lynch Life Variable Annuity Separate Account C, Merrill Lynch Life Variable Annuity Separate Account D, Merrill Lynch Variable Life Separate Account, and Merrill Lynch Life Variable Life Separate Account II. These accounts are separate accounts of Transamerica Advisors Life Insurance Company.

Transamerica Capital, Inc. also serves as principal underwriter for ML of New York Variable Annuity Separate Account, ML of New York Variable Annuity Separate Account A, ML of New York Variable Annuity Separate Account B, ML of New York Variable Annuity Separate Account C, ML of New York Variable Annuity Separate Account D, ML of New York Variable Life Separate Account, and ML of New York Variable Life Separate Account II. These accounts are separate accounts of Transamerica Advisors Life Insurance Company of New York.

Transamerica Capital, Inc. also serves as principal underwriter for Transamerica Series Trust, Transamerica Funds and Transamerica Investors, Inc.

(b) Directors and Officers of Transamerica Capital, Inc.:

Name	Principal Business Address	Position and Offices with Underwriter
Swank, Thomas A.	(1)	Director
Michael Brandsma	(2)	Director, President and Chief Financial Officer
Hopewell, David W.	(1)	Director
Barkdoll, Tamara D.	(2)	Assistant Secretary
Burke, Erin K.	(1)	Assistant Secretary
Angle, Amy	(3)	Assistant Vice President
Belanger, Elizabeth	(5)	Assistant Vice President
Cullem-Fiore, Margaret A.	(4)	Assistant Vice President
Fischer, John	(4)	Assistant Vice President
Gallagher, Dennis P	(4)	Assistant Vice President
Mossman, Shelley A.	(1)	Assistant Vice President
Post-Rissin, Christy	(4)	Assistant Vice President
Smith, Brenda L.	(4)	Assistant Vice President
Smith, Darin D.	(1)	Assistant Vice President
Wachendorf, Lisa	(1)	Assistant Vice President
Woods, Arthur D.	(4)	Assistant Vice President
John, Courtney	(2)	Chief Compliance Officer and Vice President
Bostwick, Blake S.	(2)	Chief Marketing Officer and Chief Operations Officer
Paulsen, David R.	(1)	Chief Sales Officer
Camp, Frank A.	(1)	Secretary
Wright, Karen R.	(3)	Treasurer
Heburn, Karen D.	(4)	Vice President
Hodgson, Wesley J.	(2)	Vice President

(1) 4333 Edgewood Road N.E., Cedar Rapids, IA 52499-0001

(2) 4600 S. Syracuse St., Suite 1100, Denver, CO 80237-2719

(3) 400 West Market Street, Louisville KY 40202

(4) 570 Carillon Parkway, St. Petersburg, FL 33716

(5) 440 Mammaroneck Avenue, Harrison, NY 10528

(c) Compensation to Principal Underwriter:

Name of Principal Underwriter	Net Underwriting Discounts and Commissions(1)		Compensation on Redemption	Brokerage Commissions	Compensation
Transamerica Capital, Inc.	$	15,370,032	0	0	0

⁽¹⁾ Fiscal Year 2010

Item 30.    Location of Accounts and Records

The records required to be maintained by Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 to 31a-3 promulgated thereunder, are maintained by Manager Regulatory Filing Unit Transamerica Life Insurance Company at 4333 Edgewood Road, N.E., Cedar Rapids, Iowa 52499.

Item 31.    Management Services.

All management Policies are discussed in Part A or Part B.

Item 32.    Undertakings

(a) Registrant undertakes that it will file a post-effective amendment to this registration statement as frequently as necessary to ensure that the audited financial statements in the registration statement are never more than 16 months old for so long as Premiums under the Policy may be accepted.

(b) Registrant undertakes that it will include either (i) a postcard or similar written communication affixed to or included in the Prospectus that the applicant can remove to send for a Statement of Additional Information or (ii) a space in the Policy application that an applicant can check to request 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 to Transamerica at the address or phone number listed in the Prospectus.

(d) Transamerica Life Insurance Company hereby represents that the fees and charges deducted under the policies, in the aggregate, are reasonable in relation to the services rendered, the expenses expected to be incurred, and the risks assumed by Transamerica Life Insurance Company.

SECTION 403(B) REPRESENTATIONS

Transamerica represents that it is relying on a no-action letter dated November 28, 1988, to the American Council of Life Insurance (Ref. No. IP-6-88), regarding Sections 22(e), 27(c)(1), and 27(d) of the Investment Company Act of 1940, in connection with redeemability restrictions on Section 403(b) Policies, and that paragraphs numbered (1) through (4) of that letter will be complied with.

STATEMENT PURSUANT TO 6C-7: TEXAS OPTIONAL RETIREMENT PROGRAM

Transamerica and the Mutual Fund Account rely on 17 C.F.R. Sec. 270.6c-7, and represent that the provisions of that Rule have been or will be complied with.

Page 5

SIGNATURES

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant hereby certifies that this Amendment to the Registration Statement meets the requirements for effectiveness pursuant to paragraph (b) of Securities Act Rule 485 and has caused this Registration Statement to be signed on its behalf, in the City of Cedar Rapids and State of Iowa, on this 28^th day of April, 2011.

SEPARATE ACCOUNT VA C
TRANSAMERICA LIFE INSURANCE COMPANY
Depositor
	*
Brenda K. Clancy
President

As required by the Securities Act of 1933, this Registration Statement has been signed by the following persons in the capacities and on the dates indicated.

Signatures	Title	Date
* Mark W. Mullin	Director and Chief Executive Officer	, 2011
* Craig D. Vermie	Director, Senior Vice President, Secretary and General Counsel	, 2011
* Arthur C. Schneider	Director, Senior Vice President and Chief Tax Officer	, 2011
* Eric J. Martin	Senior Vice President and Corporate Controller	, 2011
* Brenda K. Clancy	Director, President and Chairman of the Board	, 2011
* Darryl Button	Director, Executive Vice President and Chief Financial Officer	, 2011
/s/ Shane E. Daly Shane E. Daly	Assistant Vice President and Assistant Secretary	April 28, 2011

* By: Shane E. Daly – Attorney-in-Fact pursuant to Powers of Attorney filed previously and herewith.

Registration No.333-83957

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

EXHIBITS

TO

FORM N-4

REGISTRATION STATEMENT

UNDER

THE SECURITIES ACT OF 1933

FOR

SEPARATE ACCOUNT VA C

EXHIBIT INDEX

Exhibit No.	Description of Exhibit	Page No.*
(4)(r)	Form of Rider (RIM)
(8)(b)(13)	Amendment No. 44 to Participation Agreement (TST)
(9)(a)	Opinion and Consent of Counsel
(9)(b)	Consent of Counsel
(10)(a)	Consent of Independent Registered Public Accounting Firm
(14)	Powers of Attorney

^* Page numbers included only in manually executed original.