Transamerica Landmark

This post-effective amendment designates a new effective date for a previously filed post-effective amendment.

The information in this Prospectus is not complete and may be changed. This Prospectus is contained in a registration statement filed with the Securities and Exchange Commission and we may not sell these securities until that registration statement is effective. This Prospectus is not an offer to sell these securities and is not soliciting an offer to buy these securities in any state where the offer or sale is not permitted.

TRANSAMERICA LANDMARK^SM VARIABLE ANNUITY

Issued Through

SEPARATE ACCOUNT VA B
By

TRANSAMERICA LIFE INSURANCE COMPANY

Sales of this Policy were discontinued for new purchasers effective April 30, 2013.

This prospectus describes information You should know before You purchase a Transamerica Landmark^SM Variable Annuity variable annuity. The prospectus describes a contract between each Owner and joint Owner (“You”) and Transamerica Life Insurance Company or Transamerica Financial Life Insurance Company (“us,” “we,” “our” or “Company”). This is an individual, deferred, flexible premium variable annuity. This variable annuity allows You to allocate Your premium payments among the Fixed Account(if available) and the underlying fund portfolios.

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.

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.

This variable annuity may not be suitable for everyone. This variable annuity may not be appropriate for people who do not have a long investment time horizon and is not appropriate for people who intend to engage in market timing or other frequent (disruptive) trading. You will get no additional tax advantage from this variable annuity if You are investing in a variable annuity through a tax-advantaged retirement plan (such as a 401(k) plan or Individual Retirement Account (“IRA”)). This prospectus is not intended to provide tax, accounting or legal advice.

We are not an investment adviser nor are we registered as such with the SEC or any state securities regulatory authority. We are not acting in any fiduciary capacity with respect to YourPolicy nor are we acting in any capacity on behalf of any tax-advantaged retirement plan. This information does not constitute personalized investment advice or financial planning advice.

Additional information about certain investment products, including variable annuities, has been prepared by the Securities and Exchange Commission’s staff and is available at Investor.gov.

We want to let You know that beginning January 1, 2021, we no longer mail copies of shareholder reports for Portfolio Companies in Your portfolio. This change is permitted by regulations adopted by the Securities and Exchange Commission. Instead, the reports will be made available on a website. We’ll let You know by mail each time a report is posted. The notification will have a URL for accessing the report. If You’ve already elected to receive documents from us electronically, You’re not affected by this change. You’re already receiving an email with a link to the reports so there’s nothing You need to do. You do have the option of continuing to receive paper copies of all future shareholder reports free of charge. If You’d like this option, give us a call at (800)525-6205, Monday through Thursday 8 - 6:30, or Friday 8 - 5:30 ET.

Prospectus Date: May 1, 2022

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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. For more information on unit values, including how they are calculated after the Annuity Commencement Date, please see the Statement of Additional Information.

Adjusted Policy Value- The Policy Value increased or decreased by any Excess Interest Adjustment.

Administrative Office- Transamerica Life Insurance Company, Attention: Customer Care Group, 6400 C Street SW, Cedar Rapids, IA 52499, (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 Period 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.

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 that is used in the calculation of each variable annuity payment.

Cash Value- The Adjusted Policy Value less any applicable surrender charge.

Excess Interest Adjustment- A positive or negative adjustment to amounts paid out or transferred 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 withdrawals, surrenders or commencement of annuity payments, depending upon whether there has been an increase or decrease in interest rates, respectively. The Excess Interest Adjustment will not decrease the interest credited to Your Policy below the guaranteed minimum.

Fixed Account- One or more Investment Options 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 charges or Excess Interest Adjustments.

Fund Facilitation Fee- A fee we charge in order to make certain Portfolio Companies available as Investment Options under the Policy. This may also be referred to as a Platform Charge.

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 Max^® rider and the Retirement Income Choice^® 1.6 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.

Investment Option(s) - The Subaccounts and the Fixed Account.

Investment Restrictions - The requirement of the Owners to invest in certain underlying fund portfolios, as required by certain optional riders.

Owner (You, Your)- The person who may exercise all rights and privileges under the Policy.

Policy - The Transamerica Landmark^SM Variable Annuity, an individual deferred, flexible premium variable annuity. Also referred to as the contract.

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 withdrawals (withdrawals plus or minus Excess Interest Adjustment plus the surrender charge on the portion of the requested withdrawal that is subject to the surrender charge plus taxes (on the withdrawal)); 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.

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Policy Year- A Policy Year begins on the Policy Date and on each anniversary thereafter.

Portfolio Company(ies)- The investment company(ies) made available as Investment Options under the Policy. Also referred to as underlying fund portfolios.

Separate Account- Separate Account VA B, 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 generally at the close of business 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 Office. For some transactions, the Company may accept an electronic notice such as telephone instructions or any other means acceptable to the Company. Such electronic notice must meet the requirements for good order that the Company establishes for such notices.

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important INFORMATION you should consider about the policy

	FEES AND EXPENSES	Location in Prospectus
Charges for Early Withdrawal	If You withdraw money during a specified number of Policy Years following each premium payment being withdrawn, You may be assessed a surrender charge. The surrender charge is assessed for 7 years with a maximum of 8%. The surrender charge is assessed for the first 4 years with a maximum of 8% under the Landmark with the Liquidity Rider. For example, if You make an early withdrawal, You could pay a surrender charge on a $100,000 investment of up to $8,000. If You elected Life with Emergency Cash^SM option, You may surrender Your Policy after the Annuity Commencement Date, but will incur a surrender charge for 4 years with a maximum of 4%.	Annuity Policy Fee Tables and Expense Examples Transaction Expenses – Surrender Charges Access to Your Money -Surrenders Life with Emergency Cash^SM Surrender Charge
Transaction Charges	In addition to surrender charges, You also may be assessed a transfer fee and special services fee. Transfer Fee. We reserve the right to charge for transfers among Investment Options after the first 12 transfers per Policy Year. For each such additional transfer, we may impose a transfer fee of $10. Currently, we do not charge a transfer fee, but reserve the right to do so. Special Service Fee. We reserve the right to deduct a $50 charge for special services, including overnight delivery, duplicate policies, handling insufficient checks on new business, duplicate Form 1099 and Form 5498 tax forms, check copies, printing and mailing previously submitted forms, and asset verification requests from mortgage companies. For policies issued prior to May 1, 2015, the special services fee may be up to $25.	Annuity Policy Fee Tables and Expense Examples Expenses – Transaction Expenses

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	FEES AND EXPENSES			Location in Prospectus
Ongoing Fees and Expenses (annual charges)	The table below describes the fees and expenses that You may pay each year, depending on the options You choose. Please refer to Your Policy specifications page for information about the specific fees You will pay each year based on the options You have elected.			Annuity Policy Fee Tables and Expense Examples Base Contract Expenses Appendix – Portfolio Companies Available Under the Policy
	Annual Fee	Minimum	Maximum
	Base Policy¹	1.30%	3.30%
	Portfolio Company (fund fees and expenses)²	[XXX]%	[XXX]%
	Optional Benefit Expenses (if elected)	0.20% ¹	2.50% ³
	¹ As a percentage of average Separate Account Value.
	² As a percentage of Portfolio Company assets.
	³ As a percentage of the Withdrawal Base.
	Because Your Policy is customizable, the choices You make affect how much You will pay. To help You understand the cost of owning Your Policy, the following table shows the lowest and highest cost You could pay each year based on current charges. This estimate assumes that You do not take withdrawals from the Policy, which could add surrender charges that substantially increase costs.
	Lowest Annual Cost [XXXX]	Highest Annual Cost [XXXX]
	Assumes:	Assumes:
	• Investment of $100,000 • 5% annual appreciation • Least expensive Portfolio Company fees and expenses • No optional benefits • No sales charges • No additional purchase payments, transfers, or withdrawals	• Investment of $100,000 • 5% annual appreciation • Most expensive combination of optional benefits and Portfolio Company fees and expenses • No sales charges • No additional purchase payments, transfers, or withdrawals
	RISKS			Location in Prospectus
Risk of Loss	You can lose money by investing in this Policy.			Principal Risks of Investing in the Policy
Not a Short-Term Investment	This Policy is not a short-term investment and is not appropriate for an investor who needs ready access to cash. Surrender charges may apply for several years under the Policy. Surrender charges will reduce the value of Your Policy if You withdraw money during that time. The benefits of tax deferral and living benefit protection also means the Policy is more beneficial to investors with a long time horizon.			Principal Risks of Investing in the Policy Transaction Expenses - Surrender Charges Tax Information

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	RISKS	Location in Prospectus
Risks Associated with Investment Options	• An investment in this Policy is subject to the risk of poor investment performance and can vary depending on the performance of the Investment Options available under the Policy. • Each Investment Option, including the Fixed Account, has its own unique risks. • You should review the prospectuses for the available Portfolio Companies before making an investment decision.	Principal Risks of Investing in the Policy Investment Options Appendix: Portfolio Companies Available Under the Policy
Insurance Company Risks	Any obligations (including under the Fixed Account), guarantees, and benefits under the Policy are subject to our claims-paying ability. If we experience financial distress, we may not be able to meet our obligations to You. More information about Transamerica Life Insurance Company, including our financial strength ratings, is available by visiting transamerica.com or by calling toll-free (800)525-6205.	Principal Risks of Investing in the Policy Transamerica Life Insurance Company Financial Condition
	RESTRICTIONS	Location in Prospectus
Investments	• We reserve the right to impose a charge for transfers in excess of 12 transfers per Policy Year. • We reserve the right to limit transfers in circumstances of large or frequent transfers. • The Fixed Account option may not be available for investment depending on when You applied for Your Policy and when it was issued. • We reserve the right to remove or substitute the Portfolio Companies that are available as Investment Options under the Policy.	Transaction Expenses Investment Option – Transfers Market Timing and Disruptive Trading
Optional Benefits	• Certain optional benefits limit or restrict the Investment Options that You may select under the Policy. We may change these restrictions in the future. • Withdrawals that exceed limits specified by the terms of an optional benefit may reduce the value of an optional benefit by an amount greater than the value withdrawn, which could significantly reduce the value or even terminate the benefit. • We may stop offering an optional benefit at any time for new sales, which includes sales to the Owners who may want to purchase the benefit after they purchase the Policy.	Investment Restrictions Benefits Available Under the Policy Optional Benefit Riders
	TAXES	Location in Prospectus
Tax Implications	• Consult with a tax professional to determine the tax implications of an investment in and payments received under the Policy. • If You purchase the Policy as an individual retirement account or through a tax qualified plan, You do not get any additional tax benefit. • You will generally not be taxed on increases in the value of Your Policy until they are withdrawn. Earnings on Your Policy are taxed at ordinary income tax rates when withdrawn, and You may have to pay a penalty if You take a withdrawal before age 59 ½.	Tax Information

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Overview of the policy

Purpose

The Transamerica Landmark^SM Variable Annuity is a variable annuity Policy. You can use the Policy to accumulate assets for retirement or other long-term financial planning purposes. The amount of money You are able to accumulate in Your Policy depends upon the performance of Your Investment Options. The Policy also offers a death benefit to protect Your designated beneficiaries.

This Policy may not be appropriate for people who do not have a long investment time horizon and is not appropriate for people who intend to engage in market timing or other frequent (disruptive) trading.

Who the Policy is Appropriate For

The Policy is designed for investors who intend to accumulate assets for retirement or other long-term financial planning best suited for those with a long investment horizon. Although You have the ability to make partial withdrawals and/or surrender the Policy at any time during the accumulation phase, the Policy should not be viewed as a highly liquid investment. In that regard, withdrawals taken in the near term can result in Your being assessed a surrender charge, which can be a significant amount. In addition, if You participate in certain optional benefits, withdrawals can markedly reduce the benefit’s value. Finally, failure to hold the Policy for the long-term would mean that You lose the opportunity for the performance of Your chosen Investment Options to grow on a tax-deferred basis. Thus, the Policy’s features are appropriate for an investor who does not have significant liquidity needs with respect to money dedicated to the Policy, has a long investment horizon, and has purchased the Policy for retirement purposes or other long-term financial planning purposes.

Share Classes

Two different Share Classes are sold under the Policy - Landmark and Landmark with the Liquidity Rider. The Landmark features a seven-year surrender charge period and a base Separate Account annual expense of 1.30%. The Landmark with the Liquidity Rider has a base Separate Account annual expense of 1.80% which is charged for the first four Policy Years only.

Phases of the Policy

The Policy has two phases: (1) an accumulation (or savings) phase and (2) and annuity (or income) phase.”

Accumulation Phase: To help You accumulate assets during the accumulation phase, You can invest Your Premium payments and Policy Value in:

•	Underlying fund portfolios available under the Policy, each of which has its own investment strategies and risks; investment adviser(s); expense ratio; and performance history; and
•	The Fixed Account option, which offers a guaranteed interest rate during a selected period.

A list of Portfolio Companies in which You can invest is provided in an Appendix to this Prospectus. SeeAppendix - Portfolio Companies Available Under the Policy.

Annuity Phase. You can elect to Annuitize Your Policy and turn Your Policy Value into a stream of income payments called annuity payments. When You Annuitize Your Policy, the accumulation phase ends, and You will no longer be able to withdraw money from Your Policy. Any guaranteed benefits You elected will terminate without value.

You can choose from among several Annuity Payment Options, including those guaranteeing payments for life and/or for a fixed time period. 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 annuity payments dies prior to the end of the guaranteed period, then the remaining guaranteed annuity payments will be continued to a new payee, or their present value may be paid in a single sum.

Primary Features and Options of the Policy

Type of Policy. Transamerica Landmark^SM Variable Annuity Policy is a flexible premium deferred variable annuity Policy It is a “deferred” annuity because You defer taking annuity payments during the accumulation phase. It is a “flexible premium” annuity because You are generally not required to make any premium payments in addition to the initial minimum premium payment. The Policy is “variable” because its value can go up or down based on the performance of the Investment Options You choose.The Policy is available as a non-qualified or qualified Policy. The tax treatment of Your Policy may impact the benefits, as well as fees and charges under Your Policy.

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Accessing Your Money. Before You Annuitize, You can withdraw money from Your Policy at any time. If You take a withdrawal, You may be subject to a negative Excess Interest Adjustment and/or have to pay a surrender charge and/or income taxes, including a tax penalty if You are younger than age 59½.

Tax Treatment. You can transfer money between Investment Options without tax implications, and earnings (if any) on Your investments are generally tax-deferred. You are taxed only upon: (1) making a withdrawal; (2) receiving a payment from us; or (3) payment of a death benefit.

Death Benefits. The Policy includes, at no additional cost, a default death benefit that will pay Your designated beneficiaries at least the Policy Value. You can purchase a guaranteed minimum death benefit for an additional fee, which may increase the amount of money payable to Your designated beneficiaries upon Your death. Some of the guaranteed minimum death benefits available to You depend on which, if any,Guaranteed Lifetime Withdrawal Benefit You choose.

Optional Living Benefits. For an additional fee, You can purchase one of several Guaranteed Lifetime Withdrawal Benefits, which are designed to provide a guaranteed level of withdrawals from Your Policy, regardless of investment performance.

Optional Liquidity Rider: For an additional fee, You can reduce the number of years that each premium payment is subject to surrender charges from seven years to the first four years.

Additional Services. At no additional charge, You may select the following additional services:

•	Dollar-Cost Averaging. This service allows You to automatically transfer amounts between certain Investment Options on a monthly basis.
•	Asset Rebalancing. This service automatically reallocates Your Policy Value among Your Investment Options on a periodic basis to maintain Your standing allocation instructions.
•	Systematic Payout Options. This service allows You to receive regular automatic withdrawals from Your Policy either on a monthly, quarterly, semi-annual and annual basis..
•	Telephone and Electronic Transactions. This service allows You to make certain transactions by telephone or other electronic means with the appropriate authorization from You.

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ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES

The following table describes the fees and expenses that You will pay when buying, owning, and surrendering or making withdrawals from the Policy. Please refer to Your Policy specification page for information about the specific fees You will pay each year based on the options You have elected.

The first table describes the fees and expenses that You will pay at the time that You buy the Policy, surrender or make withdrawals from the Policy, or transfer Cash Value between Investment Options. or request special services. State premium taxes may also be deducted.

Transaction Expenses:

Sales Load Imposed On Purchase Payments	0%
Maximum Surrender Charge (as a % of premium payments surrendered)⁽¹⁾	8%
Transfer Fee⁽²⁾	$0-$10
Special Service Fee⁽³⁾	$0-$25

The next section describes the fees and expenses that you will pay each year during the time that you own the Policy, not including portfolio fees and expenses.

Annual Contract Expenses:

Annual Service Charge⁽⁴⁾	$0-$35 per policy
Base Contract Expenses (as a percentage, annually, of average Separate Account Value)⁽⁵⁾:	1.30%
Fund Facilitation Fee	0.30%
Optional Benefit Expenses:
Double Enhanced Death Benefit - No Longer Available	0.65%
Annual Step-Up Death Benefit	0.20%
Liquidity Rider	0.50%
Optional Death Benefit Riders – No Longer Available
Additional Death Distribution^SM (annual charge based on Policy Value)	0.25%
Additional Death Distribution+^SM (annual charge based on Policy Value)	0.55%

Maximum Fees

	Maximum
Optional Guaranteed Lifetime Withdrawal Benefit Riders No Longer Available ⁽⁶⁾
Retirement Income Max^® rider (annual charge - a % of withdrawal base):* (for riders issued on or after May 1, 2017)	2.50%
Retirement Income Choice^® 1.6 rider (annual charge - a % of withdrawal base): (for riders issued on or after May 1, 2017)
Base Benefit Designated Allocation Group A*	2.50%
Base Benefit Designated Allocation Group B*	2.50%
Base Benefit Designated Allocation Group C*	2.50%
Additional Benefits available with the Retirement Income Choice^® 1.6 rider: (for riders issued on or after May 1, 2017)
Death Benefit (Single Life Option)*	0.55%
Death Benefit (Joint Life Option)*	0.50%
Income Enhancement^SM Benefit (Single Life Option)*	0.45%
Income Enhancement^SM Benefit (Joint Life Option)*	0.65%

*The Current rider fee will be less than or equal to the stated Maximum. Your rider fee may increase (or decrease) at the time of any automatic step-up. See Automatic Step-Up discussion for each applicable optional benefit. Your rider fee percentage will not be more than 0.75% greater than the current rider fee percentage in effect when you purchased the rider. The current rider fee will be disclosed

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in a Rate Sheet Prospectus Supplement. All Rate Sheet Prospectus Supplements are also available on the EDGAR system at sec.gov (File Number 33-33085).

Maximum Fee and Current Fees:

	Maximum	Current
Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available⁽⁶⁾
Living Benefits Rider (annual charge - a % of Principal Back Total Withdrawal Base)	1.25%	1.25%
Retirement Income Max^® rider (annual charge - a % of withdrawal base): (for riders issued December 12, 2011 to April 30, 2017)	2.00%	1.25%
Retirement Income Choice^® 1.6 rider (annual charge - a % of withdrawal base): (for riders issued May 1, 2014 to April 30, 2017)
Base Benefit Designated Allocation Group A	2.20%	1.45%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with the Retirement Income Choice^® 1.6 rider: (for riders issued May 1, 2014 to April 30, 2017)
Death Benefit (Single Life Option)	0.40%	0.40%
Death Benefit (Joint Life Option)	0.35%	0.35%
Income Enhancement^SM Benefit (Single Life Option)	0.30%	0.30%
Income Enhancement^SM Benefit (Joint Life Option)	0.50%	0.50%

	Maximum	Current
Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available
Living Benefits Rider (annual charge - a % of Principal Back Total Withdrawal Base)	1.25%	1.25%
Retirement Income Max^® rider (annual charge - a % of withdrawal base): (for riders issued prior to December 12, 2011)	1.75%	1.00%
Retirement Income Choice^® 1.6 rider (annual charge - a % of withdrawal base): (for riders issued prior to May 1, 2014)
Base Benefit Designated Allocation Group A	2.30%	1.55%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with the Retirement Income Choice^® 1.6 rider: (for riders issued prior to May 1, 2014)
Death Benefit (Single Life Option)	0.40%	0.40%
Death Benefit (Joint Life Option)	0.35%	0.35%
Income Enhancement^SM Benefit (Single Life Option)	0.30%	0.30%
Income Enhancement^SM Benefit (Joint Life Option)	0.50%	0.50%

Optional Guaranteed Lifetime Withdrawal Benefit Riders - No Longer Available:
5 for Life^SM rider (annual charge - a % of total withdrawal base)	1.35%
5 for Life^SM with Growth (with additional death benefit)	1.60%
5 for Life^SM with Growth (without additional death benefit)	1.35%

	Single	Joint
Income Select^SM for Life - Single and Joint Life Option (annual charge - a % of Total Withdrawal Base):	1.15%	1.35%
Additional Benefits available with Income Select^SM for Life rider:
Growth Benefit	0.25%	0.50%
Death Benefit	0.25%	0.20%
Income Enhancement^SM Benefit	0.10%	0.20%

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	Maximum	Current
Retirement Income Choice^® rider - Single Life Option: (annual charge - a % of Withdrawal Base)	2.10%	1.35%
Additional Benefits available with the Retirement Income Choice^® rider:
Death Benefit	0.25%	0.25%
Income Enhancement^SM Benefit	0.15%	0.15%
Retirement Income Choice^® rider- Joint Life Option (annual charge - a % of Withdrawal Base):	2.40%	1.65% ⁽¹⁾
Additional Benefits available with the Retirement Income Choice^® rider:
Death Benefit	0.20%	0.20%
Income Enhancement^SM Benefit	0.30%	0.30%
Retirement Income Choice^® with Double Withdrawal Base Benefit rider - Single Life Option (annual charge - a % of Withdrawal Base):	2.40%	1.65% ⁽¹⁾
Additional Benefits available with the Retirement Income Choice^® with Double Withdrawal Base Benefit rider:
Death Benefit	0.25%	0.25%
Income Enhancement^SM Benefit	0.15%	0.15%
Retirement Income Choice^® with Double Withdrawal Base Benefit rider - Joint Life Option (annual charge - a % of Withdrawal Base):	2.40%	1.65% ⁽¹⁾
Additional Benefits available with the Retirement Income Choice^® with Double Withdrawal Base Benefit rider:
Death Benefit	0.20%	0.20%
Income Enhancement^SM Benefit	0.30%	0.30%
Retirement Income Choice^® 1.4 rider (annual charge - a % of withdrawal base):
Base Benefit Designated Allocation Group A	2.30%	1.55%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with the Retirement Income Choice^® 1.4 rider:
Death Benefit (Single Life Option)	0.40%	0.40%
Death Benefit (Joint Life Option)	0.35%	0.35%
Income Enhancement^SM Benefit (Single Life Option)	0.30%	0.30%
Income Enhancement^SM Benefit (Joint Life Option)	0.50%	0.50%
Retirement Income Choice^® 1.2 rider (annual charge - a % of withdrawal base):
Base Benefit Open Allocation Option	2.30%	1.55%
Base Benefit Designated Allocation Group A	2.30%	1.55%
Base Benefit Designated Allocation Group B	1.85%	1.10%
Base Benefit Designated Allocation Group C	1.45%	0.70%
Additional Benefits available with the Retirement Income Choice^® 1.2 rider:
Death Benefit (Single Life Option)	0.40%	0.40%
Death Benefit (Joint Life Option)	0.35%	0.35%
Income Enhancement^SM Benefit (Single Life Option)	0.30%	0.30%
Income Enhancement^SM Benefit (Joint Life Option)	0.50%	0.50%
Income Link^SM rider (annual charge a - % of withdrawal base):	2.00%	1.25%

Optional Guaranteed Minimum Income Benefit Riders - No Longer Available:
Family Income Protector	0.30%
Managed Annuity Program	0.45%
Managed Annuity Program II	0.45%

⁽¹⁾ The current fee is 1.55% for policyowners who purchase the base benefit only with no additional benefits elected.

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Notes to Fee Table

Transaction Expenses:

1) Maximum Surrender Charge:

The surrender charge, if any is imposed, applies to each premium payment, regardless of how Policy Value is allocated among the Investment Options. The surrender charge decreases based on the number of years since the premium payment was made.

If you select the Life with Emergency Cash^SM Annuity Payment Option, You will be subject to a surrender charge after the Annuity Commencement Date. See EXPENSES - Life with Emergency Cash^SM Surrender Charge.

2) Transfer Fee:

The transfer fee, if any is imposed, applies to each Policy, regardless of how Policy Value is allocated among the Investment Options. 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. Currently, we do not charge a transfer fee, but reserve the right to do so.

3) Special Services Fees:

We may deduct a charge for special services, including overnight delivery and duplicate policies. We reserve the right to deduct a charge for special services in the future, including non-sufficient checks on new business; duplicate Form 1099 and Form 5498 tax forms; check copies; printing and mailing previously submitted forms; and asset verification requests from mortgage companies. We may charge a fee for each service performed and fees may vary based on the type of service but will not exceed the maximum Special Service Fee shown above.

4) Annual Service Charge:

The annual service charge is assessed per Policy 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 $50,000.

Annual Contract Expenses:

5) Base Contract Expenses:

Base contract expenses consist of the Mortality & Expense Risk Fee and Administrative Fee.

Mortality and Expense Risk Fee: The mortality and expense risk fee shown is for the accumulation phase with the base death benefit. During the income phase, the mortality and expense risk fee is at an annual rate of 1.25%.

Fund Facilitation Fee: Any Fund Facilitation Fee is a Separate Account expense in addition to the mortality and expense risk and administrative fees. This daily fee is applied only to Policy Value in the Subaccounts invested in the following Portfolio Companies:

Portfolio Companies		Annualized Fee %
American Funds - Asset Allocation Fund^SM - Class 2 American Funds - Growth Fund^SM - Class 2 American Funds - Growth-Income Fund^SM - Class 2 American Funds - International Fund^SM - Class 2 American Funds - The Bond Fund of America^SM - Class 2		0.30%
AB Balanced Hedged Allocation Portfolio - Class B State Street Total Return V.I.S. Fund - Class 3		0.20%
Franklin Allocation VIP Fund - Class 4 TA MSCI EAFE Index - Service Class TA S&P 500 Index - Service Class		0.15%

We charge a Fund Facilitation Fee in order to make certain Portfolio Companies available as investment choices under the policies. We apply the fee to Portfolio Companies that invest in underlying fund portfolios 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 Portfolio Companies that we specify.

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

Liquidity Rider: If you elect this rider, the fee is only charged for the first four Policy Years.

OPTIONAL RIDERS

In some cases, riders to the Policy are available that provide optional benefits. There are additional fees (annualized fee charged on a yearly or quarterly basis, depending on the rider) for those riders.

Optional Death Benefit Riders: – No Longer Available

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.

6) Optional Guaranteed Lifetime Withdrawal Benefit Riders – No Longer Available

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. 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 Max^® Rider and Retirement Income Choice^® 1.6 Rider - Withdrawal Base: We use the withdrawal base to calculate the rider withdrawal amount and the rider fee. The withdrawal base on the rider date is the Policy Value. For riders issued prior to the date of this prospectus, the withdrawal percentage, growth percentage and fee information can be found in the Statement of Additional Information “Appendix - Prior Withdrawal/Growth Percentages and Rider Fees”.

5 for Life^SM Rider, 5 for Life^SM with Growth rider and Income Select^SM for Life rider - base benefit: The annual 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. The withdrawal base may be referred to as total withdrawal base in Your Policy statement and other documents.

Income Select^SM for Life Rider - Additional Benefits (Single Life and Joint Life Options): If you elected the Income Select^SM for Life rider with one or more of the following options - Growth Option, Additional Death Payment Option, Joint Life Option, Income Enhancement^SM Option. The charge for each of these options is a percentage of the withdrawal base and is in addition to the Income Select^SM for Life rider base benefit fee.

Retirement Income Choice^® rider, Retirement Income Choice^® with Double Withdrawal Base Benefit rider, Retirement Income Choice^® 1.4 rider, Retirement Income Choice^® 1.2 rider and Retirement Income Choice^® 1.6 rider - base benefit: The fee is a percentage of the withdrawal base. The withdrawal base on the rider date is the Policy Value. 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^® Rider, Retirement Income Choice^® with Double Withdrawal Benefit Rider, Retirement Income Choice^® 1.4 Rider, Retirement Income Choice^® 1.2 Rider and Retirement Income Choice^® 1.6 Rider - Additional Benefits (Single Life and Joint Life Options): If you elected the Retirement Income Choice^® rider, Retirement Income Choice^® with Double Withdrawal Benefit rider, Retirement Income Choice^® 1.4 rider, Retirement Income Choice^® 1.2 rider or Retirement Income Choice^® 1.6 rider with one or more of the following options - Death Benefit or Income Enhancement^SM 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 Income Link^SM Rider Fees: After the first rider anniversary, the base benefit rider fees can increase when there is an automatic step-up. The withdrawal base on the rider date is the Policy Value. This fee total reflects the maximum fee increase resulting from an automatic step-up of the withdrawal base while the rider is in effect.

Optional Guaranteed Minimum Income Benefit Riders - No Longer Available:

Family Income Protector: The annual rider fee is 0.30% of the minimum Annuitization value and is deducted only during the accumulation phase. If you Annuitize under the rider, a guaranteed payment fee is deducted.

Managed Annuity Program: The Managed Annuity Program fee is 0.45% of the minimum income base value and is deducted only during the accumulation phase. If you Annuitize under the rider, a guaranteed payment fee is deducted at an annual rate of 1.25%.

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Managed Annuity Program II: A rider fee, 0.45% of the minimum income base on the rider anniversary, is charged annually prior to Annuitization. We will also charge this fee if you take a complete surrender. The rider fee is deducted from each Investment Option in proportion to the amount of Policy Value in each Investment Option. This fee is deducted even if the Adjusted Policy Value exceeds the minimum income base.

Annual Portfolio Company Expenses:

The next section shows the minimum and maximum total operating expenses charged by the Portfolio Companies that You may pay periodically during the time You own the Policy. A complete list of the Portfolios available under the Policy, including their annual expenses may be found under Appendix - Portfolio Companies Available Under the Policy.

Annual Portfolio Company Expenses	Minimum	Maximum
Expenses that are deducted from Portfolio Company assets, including management fees, distribution and/or service 12b-1 fees, Fund Facilitation Fee if applicable and other expenses	[XXX]%	[XXX]%
Expenses that are deducted from Portfolio Company assets, including management fees, 12b-1 fees, and other expenses, after any waivers or expense reimbursement	[XXX]%	[XXX]%

Expense Examples⁽¹⁾:

The following Examples are 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 Owner transaction expenses, annual Policy expenses, and annual Portfolio Company operating expenses.

The Examples assume that you invest $100,000 in the Policy for the time periods indicated. The Examples also assume that Your Policy has a 5% return each year and assumes the most expensive combination of annual Portfolio Company expenses and optional benefits available for an additional charge. Although Your actual costs may be higher or lower, based on these assumptions, Your costs would be:

If the Policy is surrendered at the end of the applicable time period (without Liquidity Rider):

1 Year	$[XXXXX]
3 Years	$[XXXXX]
5 Years	$[XXXXX]
10 Years	$[XXXXX]

If the Policy is Annuitized at the end of the applicable time period or if you do not surrender your Policy (without Liquidity Rider):

1 Year	$[XXXXX]
3 Years	$[XXXXX]
5 Years	$[XXXXX]
10 Years	$[XXXXX]

If the Policy is surrendered at the end of the applicable time period (with Liquidity Rider):

1 Year	$[XXXXX]
3 Years	$[XXXXX]
5 Years	$[XXXXX]
10 Years	$[XXXXX]

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Principal Risks of Investing in the Policy

There are risks associated with investing in the Policy. You can lose money in a variable annuity, including potential loss of Your original investment. The value of Your investment and any returns will depend primarily on the performance of the underlying fund portfolios You select. Each underlying fund portfolio may have its own unique risks.

Variable annuities are not a short-term investment vehicle. The surrender charge applies for a number of years, so that the Policy should only be purchased for the long-term. Under some circumstances, You may receive less than the sum of Your premium payments. In addition, full or partial withdrawals will be subject to income tax and may be subject to a 10% Internal Revenue Service (“IRS”) penalty if taken before age 59½. Accordingly, You should carefully consider Your income and liquidity needs before purchasing a Policy. Additional information about these risks appears in the Tax Information section of this prospectus.

Risks Of An Increase In Current Fees And Expenses. Certain fees and expenses are currently assessed at less than their guaranteed maximum levels. In the future, these charges may be increased up to the guaranteed (maximum) levels.

Investment Risk. You bear the risk of any decline in the Policy Value caused by the performance of the underlying fund portfolios held by the Subaccounts . Those funds could decline in value very significantly, and there is a risk of loss of your entire amount invested. The risk of loss varies with each underlying fund. This risk could have a significant negative impact on the value of certain optional benefits offered under the Policy. The investment risks are described in the prospectuses for the underlying funds.

Investment Restrictions – Opportunity Risks. Generally, the living benefit riders offered under the Policy restrict Your choice of available underlying fund portfolios. These restrictions are intended to protect us financially, in that they reduce the likelihood that we will have to pay guaranteed benefits under the riders from our own assets. These restrictions could result in an opportunity cost – in the form of underlying fund portfolios that You did not invest in that ultimately generated superior investment performance. Thus, You should consider these underlying fund portfolio restrictions when deciding whether to elect an optional benefit that features such restrictions.

Risk Associated With Election of Optional Benefits. Several of the optional benefits include a host of requirements that must be adhered to in order to preserve and maximize the guarantees we offer under the benefit. If You fail to adhere to these requirements, that may diminish the value of the benefit and even possibly cause termination of the benefit. In addition, it is possible that You will pay fees for the optional benefit without fully realizing the guarantees available under the optional benefit. For example, such would be the case if You were to hold a Guaranteed Lifetime Withdrawal Benefit for many years yet die sooner than anticipated, without having taken a significant number of lifetime withdrawals.

Risks of Managing General Account Assets. The general account assets of The Company are used to support the payment of guaranteed benefits under the Policy. To the extent that the Company is required to pay amounts in addition to the Policy Value, such amounts will come from our general account assets. You should be aware that the general account assets are exposed to the risks normally associated with a portfolio of fixed-income securities, including interest rate, option, liquidity and credit risk, and are also subject to the claims of the Company’s general creditors. The Company’s financial statements contained in the Statement of Additional Information include a further discussion of risks inherent in the general account investments.

Insurance Company Insolvency. It is possible that we could experience financial difficulty in the future and even become insolvent, and therefore unable to provide all of the guarantees and benefits that exceed the assets in the Separate Account that we promise.

Tax Consequences. Withdrawals are generally taxable to the extent of any earnings in the Policy, and prior to age 59½ a tax penalty may apply. In addition, even if the Policy is held for years before any withdrawal is made, withdrawals are taxable as ordinary income rather than capital gains.

Cybersecurity and Certain Business Continuity Risks

Our operations support complex transactions and are highly dependent on the proper functioning of information technology and communication systems. Any failure of or gap in the systems and processes necessary to support complex transactions and avoid systems failure, fraud, information security failures, processing errors, cyber intrusion, loss of data and breaches of regulation may lead to a materially adverse effect on our results of operations and corporate reputation. In addition, we must commit significant resources to maintain and enhance its existing systems in order to keep pace with applicable regulatory requirements, industry standards and customer preferences. If we fail to maintain secure and well-functioning information systems, we may not be able to rely on information for product pricing, compliance obligations, risk management and underwriting decisions. In addition, we cannot assure investors or consumers that interruptions, failures or breaches in security of these processes and systems will not occur, or if they do occur, that they can be timely detected and remediated. The occurrence of any of these events may have a materially adverse effect on our businesses, results of operations and financial condition.

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For additional detail regarding cybersecurity and related risks, please reference the Cyber Security section in the Statement of Additional Information.

Business Continuity

Our business operations may be adversely affected by volatile natural and man-made disasters, including (but not limited to) hurricanes, earthquakes, terrorism, civil unrest, military action, fires and explosions, pandemic diseases, and other catastrophes (“Catastrophic Events”). Over the past several years, changing weather patterns and climatic conditions have added to the unpredictability and frequency of natural disasters in certain parts of the world. To date, the COVID-19 pandemic has caused significant uncertainty and disruption to governments, business operations, and consumer behavior on a global scale. Such uncertainty as to future trends and exposure may lead to financial losses to our businesses. Furthermore, Catastrophic Events may disrupt our operations and result in the loss of, or restricted access to, property and information about Transamerica and its clients. Such events may also impact the availability and capacity of our key personnel. If our business continuity plans do not include effective contingencies for Catastrophic Events, we may experience business disruption, damage to corporate reputation, and damage to financial condition for a prolonged period of time.

Transamerica life insurance company, The separate account, and portfolio companies

Transamerica Life Insurance Company

Transamerica Life Insurance Company, located at 6400 C Street SW, Cedar Rapids, Iowa 52499, is the insurance company issuing the Policy.

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 Policy 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 are not assured and 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.

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. In addition, we hedge our investments in our general

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account, and may require purchasers of certain of the variable insurance products that we offer to allocate premium payments and Policy Value in accordance with specified investment requirements. However, it is important to note that there is no guarantee that we will always be able to meet our claims-paying obligations, and 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, which include bonds, mortgages, general real estate investments, and stocks, as well as the loss in market value of these investments. We may also experience liquidity risk if our general account assets cannot be readily converted into cash to meet obligations to our Policy Owners or to provide the collateral necessary to finance our business operations.

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 Insurance 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 Office referenced in this prospectus. In addition, the SAI is available on the SEC's website at sec.gov. Our financial strength ratings which reflect the opinions of leading independent rating agencies of our ability to meet our obligations to our Policy Owners are available on our website (Financial Strength | Transamerica), and the websites of these nationally recognized statistical ratings organizations – A.M. Best Company (AM Best Company), Moody’s Investors Service (Moodys.com) and Standard & Poor’s Rating Services (Standard & Poor's).

The Separate Account

The Company established a Separate Account, called Separate Account VA B, under the laws of the State of Iowa on January 19, 1990. 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.

The Underlying Funds

At the time you purchase your Policy, you may allocate your premium to Subaccounts. These are subdivisions of our Separate Account, an account that keeps your policy assets separate from our company assets. The Subaccounts then purchase shares of mutual funds set up exclusively for variable annuity or variable life insurance products. These are not the same mutual funds that you buy through your investment professional even though they may have similar investment strategies and the same portfolio managers. Each underlying fund portfolio has varying degrees of investment risk. Underlying fund portfolios are also subject to separate fees and expenses such as management fees and operating expenses. “Master-feeder” or “fund of funds” invest substantially all of their assets in other funds and will therefore bear a pro-rata share of fees and expenses incurred by both funds. This will reduce your investment return. Read the underlying fund portfolio prospectuses carefully before investing. We do not guarantee the investment results of any underlying fund portfolio. Certain underlying fund portfolios may not be available in all states and in all share classes. Please seeAppendix - Portfolio Companies Available Under the Policy for additional information.

Other Transamerica Policies

We offer a variety of fixed and variable annuity policies. They may offer features, including Investment Options, and have fees and charges, that are different from those in the Policy offered by this prospectus. Not every Policy we issue is offered through every financial intermediary. Some financial intermediaries may not offer and/or limit the offering of certain features or options, as well as limit the availability of the policies, based on issue Age, or other criteria established by the financial intermediary. Upon request, Your financial professional can show You information regarding other Transamerica annuity policies that he or she distributes. You can also contact us to find out more about the availability of any of the Transamerica annuity policies.

You should work with Your financial professional to decide whether this Policy is appropriate for You based on a thorough analysis of Your particular insurance needs, financial objectives, investment goals, time horizons and risk tolerance.

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VOTING RIGHTS

To the extent required by law, we 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 we will determine that it is permitted to vote the underlying fund portfolios shares in its own right, it may elect to do so.

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, You have 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 have 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. We 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 us 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. Accordingly, it is possible for a small number of 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. Shares owned by the insurance company and its affiliates will also be proportionately voted.

Each person having a voting interest in a Subaccount will receive proxy material, reports, and other materials relating to the appropriate portfolio.

THE ANNUITY POLICY

This prospectus describes the Transamerica Landmark^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 assets 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 premium payments of $50 or more until the Annuity Commencement Date. You are not required to make any additional premium payments.

The Policy is a “variable” annuity because the value of Your Policy can go up or down based on the performance of Your Subaccounts. 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 Subaccounts. You could lose the amount You allocate to the Separate Account. The amount of annuity payments You receive from the Separate Account during the income phase also depends upon the investment performance of Your Subaccounts. 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.

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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 Policy is not intended or designed to be traded on any stock exchange or secondary market. By purchasing this Policy, You represent and warrant that You are not using the Policy, or any of its riders for resale, speculation, arbitrage, viatication, or any other type of collective investment scheme.

PURCHASE

Policy Issue Requirements

The Company will not issue a Policy unless:

•	the Company receives in good order (SeeSending Forms and Transaction Requests in Good Order) all information needed to issue the Policy;

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

•	the Annuitant ,Owner, and any joint Owner are age 85 or younger (the limit may be lower for qualified policies);
•	the Owner and Annuitant have an immediate familial relationship.

Please note, certain riders described herein may require a younger age. Please carefully read the applicable rider sections regarding any age limitations.

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

Premium Payments

You should make checks for premium payments payable only to Transamerica Life Insurance Company and send them to the Administrative Office. Your check must be honored in order for us to pay any associated annuity 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 us 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 payment 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 in good order. If we are unable to credit Your initial premium payment, we will contact You or Your financial intermediary, if applicable, within five business days and explain why. We will also return Your initial premium payment at that time unless You instruct us to hold it and credit it within two business days after Your information is both complete and in good order.

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 Office. Additional premium payments must be received in good order before the close of a regular business session of regular trading on the New York Stock Exchange (usually 4:00 p.m. Eastern time) to get same-day pricing of the additional premium

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payment. Additional premium payments received in good order on non-business days or after our close of business on business days will receive next-day pricing. SeeSending Forms and Transaction Requests in Good Order.

Maximum Total Premium Payments

For issue ages 0-80, we reserve the right to require prior approval of any 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. We may approve premium payments over $1,000,000 but restrict access to certain optional benefits. For issue ages over 80, we reserve the right to require prior approval of any cumulative premium payments over $500,000 (this includes subsequent premium payments) for policies with the same Owner or same Annuitant issued by us or an affiliate. If You do not obtain prior approval for premium payments in excess of the dollar amounts listed above, the business will be deemed not in good order.

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. You could lose the amount You allocate to the Subaccounts.

If You allocate premium payments to the Dollar Cost Averaging program, (if it is available), 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 Office, or by telephone, or other electronic means acceptable to us, subject to the limitations described in ADDITIONAL FEATURES - Telephone and Electronic Transactions, or any other means acceptable to us. The allocation change will apply to premium payments received on or after the date we receive the change request in good order.

We reserve 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. Regular trading on the New York Stock Exchange usually closes at 4:00 p.m., Eastern time. Holidays are generally not business days.

INVESTMENT OPTIONS

The Transamerica Landmark^SM Variable Annuity offers you a means of investing in various underlying fund portfolios offered by different investment companies (by investing in the corresponding Subaccounts). The companies that provide investment advice and administrative services for the underlying fund portfolios offered through this Policy are listed in the Appendix - Portfolio Companies Available Under the Policy.

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 adviser 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 can be found at http://dfinview.com/Transamerica/TAHD/89352F657?site=VAVUL. You should read the prospectuses for the underlying fund portfolios carefully before You invest.

Note: If You received a summary prospectus for any of the underlying fund portfolios listed in Appendix - Portfolio Companies Available Under the Policy, please follow the instructions on the first page of the summary prospectus to obtain a copy of the full underlying fund prospectus or its Statement of Additional Information.

Selection of Underlying Fund Portfolios

The underlying fund portfolios offered through this variable annuity are selected by us, and we 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, volatility, hedgeability, 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.

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We review the portfolios periodically and may remove a portfolio, or limit its availability to new premium payments 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 may include certain underlying fund portfolios based on their recommendations. Their selection criteria may differ from our selection criteria.

If You elect a Guaranteed Lifetime Withdrawal Benefit rider, as discussed later in this prospectus, we require You to allocate Your Policy Value to designated Investment Options. This requirement is intended to reduce the Company’s costs and risks associated with offering the rider, and we select which underlying fund portfolios to make available under the riders with these factors in mind. Certain designated Investment Options invest in fund portfolios with volatility control strategies, which could limit full participation in market gains and the growth of the riders. See the Investment Restrictions section for information regarding the potential impact of volatility control strategies on the value of the Guaranteed Lifetime Withdrawal Benefit riders.

Designated Investment Options, including those that invest in fund portfolios with volatility control strategies, are also available to contract Owners who do not elect a Guaranteed Lifetime Withdrawal Benefit rider. Although volatility control strategies are intended to help limit overall volatility and reduce the effects of significant market downturns during periods of high market volatility, providing Policy Owners with the opportunity for smoother performance and better risk adjusted returns, such strategies could limit Your full participation in market gains and ability to maximize potential growth of Your Policy Value.

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

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 underlying fund's website 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 payment, 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. 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.

If You elect certain optional riders, You will be subject to Investment Restrictions. In the future, we may change the Investment Restrictions.

Not all Subaccounts may be available for all policies, in all states, or through all financial intermediary firms.

Addition, Deletion, or Substitution of Investment Options

We cannot and do not guarantee that any of the Subaccounts will always be available for premium payments, allocations, or transfers. We retain the right, subject to any applicable law, to make certain changes in the Separate Account and its Investment Options. We reserve 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. To the extent required by applicable law, substitutions of shares attributable to Your interest in a Subaccount will not be made without prior notice to You and prior regulatory approval. 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.

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New Subaccounts may be established when, in our sole discretion, marketing, tax, investment or other conditions warrant. Any new Subaccounts may be made available to existing Owners on a basis to be determined by us. Each additional Subaccount will purchase shares in an underlying fund portfolio or other investment vehicle. We may also close one or more Subaccounts if, in our sole discretion, marketing, tax, investment or other conditions warrant such change. In the event any Subaccount is closed, we will notify You and request a reallocation of the amounts invested in the closed Subaccount. If we do not receive additional instructions, any subsequent premium payments or transfers (including dollar cost averaging transactions or asset rebalance programs transactions) into a closed or liquidated Subaccount will be re-allocated to the remaining available Investment Options according to the investment allocation instructions You previously provided. If Your previous investment allocation instructions do not include any available Investment Options, we will require new instructions. If we do not receive new instructions, the requested transaction will be canceled and any premium payment will be returned. Under asset rebalance programs the value remaining in the closed Subaccount will be excluded from any future rebalancing. The value of the closed Subaccount will continue to fluctuate due to portfolio performance, and may exceed the original rebalance percentages You requested. As You consider Your overall investment strategy within Your annuity, You should also consider whether or not to re-allocate the value remaining in the closed Subaccount to another Investment Option. If You decide to re-allocate the value of the closed Subaccount, You will need to provide us with instructions. Under certain situations involving Annuitizations(e.g., Policy reached maximum Annuity Commencement Date) if an Investment Option is closed to new investment, the amount that would have been allocated thereto will instead be used to purchase annuity units pro-rata in the other Investment Options You have purchased Accumulation Units in and which are open to new investment. Moreover, in certain situations involving death benefit adjustments for continued policies, if an Investment Option is closed to new investment, the amount that would have been allocated thereto will instead be allocated pro-rata to the other current Investment Options You have value allocated to and which are open to new investment.

In the event of any such substitution or change, we 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, we 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 underlying fund portfolio for an existing underlying fund portfolio.

In addition, a Subaccount could become no longer available due to the liquidation of its corresponding underlying fund portfolio. To the extent permitted by applicable law, upon advance notice to You and unless You otherwise instruct us, we will:

1)	Re-allocate any Policy Value in the liquidated underlying fund portfolio to the money market Subaccount or a Subaccount investing in another underlying fund portfolio designated by us; and
2)	If You are using an automated transfer feature such as the Rebalancing program or Dollar Cost averaging with the Subaccount for the portfolio, You should contact us immediately to make alternate arrangements. If you make alternate arrangements before the closure date, any subsequent allocations to the Subaccount for the portfolio will be directed to the Money Market Subaccount.

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.

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.

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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 our 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 are, however, 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 Option by giving us notice within 30 days before the end of the expiring guaranteed period.

Surrenders, withdrawals, transfers, and amount applied to an Annuity Payment Option 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). SeeACCESS TO YOUR MONEY - Excess Interest Adjustment for more information about when an Excess Interest Adjustment applies. This adjustment will also be made to amounts that you apply to an Annuity Payment Option. The Excess Interest Adjustment will not decrease the interest credited to your Policy below the guaranteed minimum. Please seeAppendix – Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation.

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 non-forfeiture law at the time the Policy is issued.

If you select the Fixed Account, your money will be placed with our 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. The interest credited as well as principal invested in the Fixed Account is based on our claims-paying ability.

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 Option 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, including transfers in connection with the Portfolio Allocation Method discussed later in this prospectus, 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. (Note: This restriction may prolong the period of time it takes to transfer the full amount in the Guaranteed Period Option of the Fixed Account. You should carefully consider whether investment in the Fixed Account meets your needs and investment criteria.) Please see Appendix - Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation.

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In general, each transfer from a Subaccount must be at least $500, or the entire Subaccount value if less than $500. 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 while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. Transfer requests received in good order on non-business days or after our close of business on business days will get next-day pricing. SeeSending Forms and Transaction Requests in Good Order .

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, or other electronic means acceptable to us, are subject to the limitations described in ADDITIONAL FEATURES - Telephone and Electronic Transactions.

Investment Restrictions

If You elect certain optional riders, You will be subject to Investment Restrictions requiring You to invest in certain underlying fund portfolios, known as designated Investment Options. In the future, we may change the Investment Restrictions.

One or more of the underlying fund portfolios that may be designated Investment Options under an optional rider, in part, may include a volatility control strategy. Volatility control strategies, in periods of high market volatility, could limit Your participation in market gains; this may conflict with Your investment objectives by limiting Your ability to maximize potential growth of Your Policy Value and, in turn, the value of any guaranteed benefit that is tied to investment performance. Volatility control strategies are intended to help limit overall volatility and reduce the effects of significant market downturns during periods of high market volatility, providing Policy Owners with the opportunity for smoother performance and better risk adjusted returns. Volatility control (and similar terms) can encompass a variety of investment strategies of different types and degrees; therefore, You should read the applicable annuity and underlying fund portfolio prospectuses carefully to understand how these investment strategies may affect Your Policy Value and rider benefits. Our requirement to invest in accordance with certain Investment Options, which may include volatility control, may reduce our costs and risks associated with the applicable riders. You pay an additional fee for the rider benefits which, in part, pays for protecting the rider benefit base from investment losses. Since the rider benefit base does not decrease as a result of investment losses, volatility control strategies might not provide meaningful additional benefit to You. You should carefully evaluate with Your financial professional whether to invest in underlying fund portfolios with volatility control strategies, taking into consideration the potential positive or negative impact that such strategy may have on Your investment objectives, Your Policy Value and the benefits under the riders. If You determine that underlying fund portfolios with volatility control strategies are not consistent with Your investment objectives, other Investment Options are available under the riders that do not invest in underlying fund portfolios that utilize volatility control strategies.

For more information about the underlying fund portfolios and the investment strategies they employ, please refer to the underlying fund portfolios' current prospectuses.

Market Timing and Disruptive Trading

Statement of Policy. This variable annuity Policy was not designed to accommodate market timing or frequent or large transfers among the Subaccounts or between the Subaccounts and the Fixed Account. (Both frequent and large transfers may be considered disruptive.)

Market timing and disruptive trading can adversely affect You, other Owners, beneficiaries and underlying fund portfolios. The adverse effects may 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 seek or 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 Owners invested in those Subaccounts, not just those making the transfers.

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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 or anyone acting on Your behalf is 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 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 premium payment or transfer, or series of premium payments or 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. 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 judgment and discretion, it is possible that some 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 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 trades or variable insurance products that we believe are connected by Owner or persons engaged in trading on behalf of Owners.

In addition, transfers for multiple policies invested in the Transamerica Series Trust underlying fund portfolios which are submitted together may be disruptive at certain levels. At the present time, such aggregated transactions likely will not cause disruption if less than one million dollars total is being transferred with respect to any one underlying fund portfolio (a smaller amount may apply to smaller portfolios). Please note that transfers of less than one million dollars may be disruptive in some circumstances and this general amount may change quickly.

For policies with Portfolio Allocation Method or Open Allocation Method, the effect of transfers pursuant thereto may be considered disruptive for certain underlying fund portfolios. As a result, Policy Owners using Portfolio Allocation Method or Open Allocation Method may have to change their selected underlying fund portfolios. We will contact You in the event this occurs.

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

In addition to our internal policies and procedures, we will administer Your variable annuity 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.

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Redemption fees, transfer limits, and other procedures or restrictions imposed by the underlying funds or our competitors 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 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 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 Options 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 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.

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 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 Options under the variable insurance product. In addition, we may not honor transfer requests if any variable Investment Option 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. Owners should be aware that we do not monitor transfer requests from Owners or persons acting on behalf of Owners against, nor do we apply, the frequent trading policies and procedures of the respective underlying fund portfolios that would be affected by the transfers.

Owners should be aware that we are required to provide to an underlying fund portfolio or its payee, promptly upon request, certain information about the trading activity of individual Owners, and to restrict or prohibit further purchases or transfers by specific Owners or persons acting on their behalf, identified by an underlying fund portfolio as violating the frequent trading policies established for the underlying fund portfolio.

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

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EXPENSES

Note: The following section on expenses and the ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES only apply to policies issued on or 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. In addition to the following charges, there are optional benefits that if selected, assess additional charges. Please see ADDITIONAL FEATURES for more information.

Transaction Expenses:

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 take a withdrawal of up to the greater of (i) 10% of your premium payments or (ii) any gains in the Policy 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 seven years following payment of each premium payment:

Number of Years Since Premium Payment Date		Surrender Charge (as a percentage of premium surrendered)
0 – 1		8%
1 – 2		8%
2 – 3		7%
3 – 4		6%
4 – 5		5%
5 – 6		4%
6 – 7		3%
more than 7		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 surrender charge 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 withdrawal 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 and Excess Interest Adjustments are waived if You surrender money under the Nursing Care and Terminal Condition Withdrawal Option or the Unemployment Waiver.

Keep in mind that withdrawals 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.

An optional rider is available which reduces the number of years a surrender charge applies to each premium payment. There is an extra charge for this rider. See Liquidity Rider.

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Liquidity Rider

The optional Liquidity Rider reduces the number of years each premium payment is subject to surrender charges from seven years to four years. The surrender charge schedule is the same during the first four years for each premium payment. There is an extra charge for this rider.

Life with Emergency Cash^SM Surrender Charge

If you select the Life with Emergency Cash^SM 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 % of premium surrendered)
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^SM 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 premium; and
•	under this payment option, there is no surrender charge free amount.

Excess Interest Adjustment

Surrenders, withdrawals, transfers, amounts applied when a death benefit is calculated, and amounts applied to an annuity option 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. However, please note that a death benefit will not be reduced if the Excess Interest Adjustment results in a decrease in the Cash Value available to You. Please seeAppendix - Excess Interest Adjustment Examples for an example showing the effect of a hypothetical Excess Interest Adjustment calculation. The Excess Interest Adjustment plays a role in calculating the total interest credited to the Fixed Account.

Premium Taxes

A deduction is also made for premium taxes, if any, imposed on us by a state, municipality or other government agency. The tax, currently ranging from 0% to 3.50%, is assessed at the time premium payments are made or when annuity payments begin. We pay the premium tax at the time it is imposed. We will, at our discretion, deduct the total amount of premium taxes, if any, from the Policy Value when such taxes are due to the applicable taxing authority, You begin receiving annuity payments, You surrender the Policy or a death benefit is paid.

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 may deduct a charge for special services, including overnight delivery; duplicate policies; non-sufficient checks on new business; duplicate Form 1099 and Form 5498 tax forms; check copies; printing and mailing previously submitted forms; and asset verification requests from mortgage companies. We may charge a fee for each service performed and fees may vary based on the type of service but will not exceed the maximum Special Service Fee shown in the Fee Table.

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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 Policy 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. Currently we are not charging for transfers.

Base Contract Expenses:

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 (including distribution related expenses), and assuming the risk that the current charges will be insufficient in the future to cover costs of selling, distributing and administering the Policy.

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.

Administrative Charges

We deduct a daily administrative charge to cover the costs of supporting and administering the Policy (including certain distribution-related expenses). This charge is equal to a percentage of the daily net asset value of each Subaccount during both the accumulation phase and the income phase.

Annual Service Charge

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. The service charge is waived if your Policy Value or the sum of your premiums, less all partial surrenders, is at least $50,000.

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 Portfolio Companies available as Investment Options under the policies. We apply the fee to Portfolio Companies that invest in underlying fund portfolios 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 Portfolio Companies that we specify.

Optional Benefits

If You elect to purchase optional benefits, we will deduct an additional fee. For some optional benefits the fee is assessed against the daily net asset value of each Subaccount and for others it is deducted from each Investment Option in proportion to the amount of Policy Value in each Investment Option. Please refer to the ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES for the list of fees for each optional benefit and Optional Benefit Riders section for more information.

Underlying Fund 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 underlying fund portfolio expenses for the previous calendar year are found in the ANNUITY POLICY FEE TABLE AND EXPENSE EXAMPLES section of this prospectus. See the prospectuses for the underlying fund portfolios for more information.

Reduced Fees and Charges

We may at our discretion, reduce or eliminate certain fees and charges for certain policies (including employer-sponsored savings plans) which may result in decreased costs and expenses.

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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, sub-advisers, 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 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. We and/or our affiliate, Transamerica Capital, Inc. (“TCI”) who is the principal underwriter for the policies, indirectly receive 12b-1 fees from certain underlying fund portfolios available as Investment Options 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 0.45% 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. These fees are paid from the underlying fund portfolios’ assets. Policy Owners, through their indirect investment in the underlying fund portfolios, bear the costs of 12b-1 fees (see the prospectuses for the underlying fund portfolios for more information).

• 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 adviser 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 fund portfolios for more information). However, amounts paid from an investment adviser’s or sub-adviser’s (or other service provider’s) revenues are not paid from the underlying portfolios’ assets. 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 Support Fees and underlying fund portfolio fees (i.e. sub-transfer agent, Rule 12b-1, and Shareholder Services) 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
Underlying Fund Portfolio		Maximum Fee % of assets
TRANSAMERICA SERIES TRUST (“TST”)		0.25%
AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS)		0.55%
AB VARIABLE PRODUCTS SERIES FUND, INC.		0.45%
AMERICAN FUNDS INSURANCE SERIES^® TRUST		0.25%
FIDELITY ^® VARIABLE INSURANCE PRODUCTS FUND		0.395%
FRANKLIN TEMPLETON VARIABLE INSURANCE PRODUCTS TRUST		0.50%
STATE STREET VARIABLE INSURANCE SERIES 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 assets invested in Subaccounts that are closed to new premium payments, depending on the terms of the agreements supporting those payments and on the services provided.

TST: Because TST is managed by 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 and to provide administrative services to the policyholders who invest in Subaccounts that 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

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than on those TST portfolios that are sub-advised by non-affiliated entities. During 2021 we received approximately $[XXXX] million 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 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. 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 conference sponsorship or marketing allowance payments 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 sub-adviser (or other affiliates) with increased access to us and to our affiliates involved in the distribution of the policies.

For the calendar year ended December 31, 2021, TCI and its affiliates received payments that totaled approximately $1.9 million. The firms that paid to participate in TCI sponsored events included but were not limited to the following: Aegon Asset Management • Alliance Bernstein • Allianz Global Investors • American Century Investments • Amundi Pioneer Asset Management • Barrow, Hanley, Mewhinney & Strauss, LLC • BlackRock Investment Management, LLC • BNY Mellon • Capital Group • Charles Schwab Investment Management • Columbia Threadneedle Investments • Dimensional Fund Advisers • Fidelity Investments • Franklin Templeton Investments• Goldman Sachs Asset Management • Hartford Funds • Ivy Investments• Janus Henderson Investors • John Hancock Investments • Legg Mason Global Asset Management • Milliman Financial Risk Management LLC • MFS Investment Management • Morgan Stanley Investment Management Inc. • Neuberger Berman • New York Life/Mainstay Investments • PGIM Investments • Pacific Investment Management Company • PineBridge Investments LLC • Principal Global Investors • Putnam Investments • QMA • Rockefeller Capital Management • Systematic Financial Management • T. Rowe Price • Thompson Siegel & Walmsley LLC • The Vanguard Group, Inc. • Virtus Investment Partners • Wellington Management Company LLP and Wells Fargo Asset Management.

Please note some of the aforementioned managers and/or sub-advisers 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 OTHER INFORMATION - Distribution of the Policies in this prospectus.

general description of the policy

Ownership

You, as Owner of the Policy, exercise all rights under the Policy. You can generally change the Owner at any time by notifying us in writing at our Administrative Office. If we do not have an originating signature or guaranteed signature on file or if the Company suspects fraud, we may require a notarized signature. There may be limitations on Your ability to change the ownership of a qualified Policy. 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 Company will not be liable for any payment made before the Written Notice is received in our Administrative Office. If more than

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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), then the surviving Owner(s) automatically takes the place of any beneficiary designation.

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 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.

Termination for Low Value

If a withdrawal or fee (including an optional rider fee, administrative fee, or Owner transaction fee) reduces Your Cash Value below the minimum specified in Your Policy, we reserve the right to terminate Your Policy and send You a full distribution of Your remaining Cash Value. All benefits associated with Your annuity Policy will be terminated. Federal law may impose restrictions on our right to terminate certain qualified policies. We do not currently anticipate exercising this right if You have certain optional benefits, however, we reserve the right to do so. For all other policies, including policies with certain other optional benefits, we intend to exercise this termination provision.

Certain Offers

From time to time, we have (and we may again) offered You some form of payment or incentive in return for terminating or modifying certain guaranteed benefits.

When we make an offer, we may vary the offer amount, up or down, among the same group of Policy Owners based on certain criteria such as account value, the difference between account value and any applicable benefit base, investment allocations and the amount and type of withdrawals taken. For example, for guaranteed benefits that have benefit bases that can be reduced on either a pro rata or dollar-for-dollar basis depending on the amount of withdrawals taken, we may consider whether You have taken any withdrawal that has caused a pro rata reduction in Your benefit base, as opposed to a dollar-for-dollar reduction. Also, we may increase or decrease offer amounts from offer to offer. In other words, we may make an offer to a group of Policy Owners based on an offer amount, and, in the future, make another offer based on a higher or lower offer amount to the remaining Policy Owners in the same group.

If You accept an offer that requires You to terminate a guaranteed benefit and You retain Your Policy, we will no longer charge You for the benefit, and You will not be eligible for any future offers related to that type of guaranteed benefit, even if such future offer would have included a greater offer amount or different payment or incentive.

We may also make an offer to You to exchange an existing rider for a different rider.

Exchanges and/or Reinstatements

You can generally exchange a nonqualified annuity Policy for another in a “tax-free exchange” under Section 1035 of the Internal Revenue Code or transfer qualified policies directly to another life insurance company as a “trustee-to-trustee transfer”. Before making an exchange or transfer, You should compare both annuities carefully. Remember that if You exchange or transfer another annuity for the one described in this prospectus, then You may pay a surrender charge on the other annuity, and there may 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 or transfer another annuity for this one unless You determine, after knowing all the facts, that the exchange or transfer 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, transfer or otherwise).

You may ask us to reinstate Your Policy after such an exchange, transfer, withdrawal or surrender and in certain limited circumstances we will allow You to do so by returning the same total dollar amount of funds distributed to the applicable Investment Options. The dollar amount will be used to purchase new Accumulation Units at the then current price. In the event any Subaccount previously invested in is closed and we don’t receive additional instructions, funds will be reallocated to the remaining available Investment Options according to the investment allocation instructions You previously provided. Because of changes in market value, Your new Accumulation Units may be worth more or less than the units You previously owned. Generally for non-qualified annuity reinstatements, unless You return the original company check, if a portion of the prior withdrawal was taxable, we are required to report the taxable amount from the distribution even though the funds have been reinstated. The cost basis will be adjusted accordingly. The taxable amount will be reported on Form 1099-R which You will receive in January of the year following the

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distribution. Qualified annuity reinstatements may be subject to the same tax reporting and rollover requirements. We recommend that You consult a tax professional to explain the possible tax consequences of reinstatements.

ACCESS TO YOUR MONEY

During the accumulation phase, You can have access to the money in Your Policy in the following ways:

•	by taking a withdrawal or surrender; or

•	by taking systematic payouts (SeeADDITIONAL FEATURES - Systematic Payout Option for more details).

Surrenders

During the accumulation phase, if You take a full surrender, You will receive your Cash Value.

If You want to take a withdrawal, 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 Options in proportion to the Policy Value. Surrenders may be referred to as withdrawals on your Policy statement and other documents.

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. SeeDEATH BENEFIT, for more details. A withdrawal also may have a negative impact on certain other benefits and guarantees of Your Policy.

Withdrawals may be subject to a surrender charge. Withdrawals 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.

Surrenders from qualified policies may be restricted or prohibited.

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^SM 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 record keeper, and other product providers.

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.

Delay of Payment and Transfer

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 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 BlackRock Government Money Market VP portfolio (or any money market portfolio offered under this Policy) suspends payment of redemption proceeds in connection with a liquidation of the portfolio, then we may delay payment of any transfer, surrender (either full or partial), loan, or death benefit from the TA BlackRock Government Money Market Subaccount until the portfolio is liquidated.

Any payment or transfer request which is not in good order will cause a delay. See OTHER INFORMATION - Sending Forms and Transaction Requests in Good Order.

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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” an Owner's account. If these laws apply in a particular situation, we would not be allowed to pay any request for surrenders (either full or partial), 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

Surrenders, withdrawals, transfers, and amounts applied to an annuity 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. If at the time of such transactions the guaranteed interest rate set by us for the applicable period has risen since the date of the initial guarantee, the Excess Interest Adjustment will result in a lower Cash Value (but not below the Excess Interest Adjustment floor described in Appendix - Excess Interest Adjustment Examples). However, if the guaranteed interest rate for the applicable period has fallen since the date of the initial guarantee, the Excess Interest Adjustment will result in a higher Cash Value upon surrender or transfer. Please seeAppendix - Excess 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 for that Guaranteed Period Option is generally subject to an Excess Interest Adjustment. An Excess Interest Adjustment may also be made on amounts applied to an Annuity Payment Option.

The formula that will be used to determine the Excess Interest Adjustment is:

S* (G-C)* (M/12)
S	=	Is the amount (before surrender charges, premium taxes and the application of any Guaranteed Minimum Death Benefits, if any) being surrendered, withdrawn, transferred, paid upon death, or applied to an income option that is subject to the Excess Interest Adjustment;
G	=	Is the guaranteed interest rate for the guaranteed period applicable to “S”;
C	=	Is the current guaranteed interest rate then being offered on new premium payments 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 for “S”, rounded up to the next higher whole number of months; and
*	=	multiplication

Please seeAppendix - Excess Interest Adjustment Examples for more detailed information concerning the Excess Interest Adjustment calculation.

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;
•	transfers from a Dollar Cost Averaging fixed source;
•	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.

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Signature Guarantee

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

•	Any surrender over $250,000 unless it is a custodial owned annuity;

•	Any non-electronic disbursement request made on or within 15 days of a change to the address of record for a Policy Owner’s account;

•	Any electronic fund transfer instruction changes on or within 15 days of an address change;

•

Any surrender when we have 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 we do not have an originating or guaranteed signature on file unless it is a custodial owned annuity;
•	Any other transaction we require.

We may change the specific requirements listed above, or add signature guarantees in other circumstances, at 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)525-6205.

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

ANNUITY PAYMENTS (THE INCOME PHASE)

Upon the Annuity Commencement Date, which is the date Your Policy is Annuitized and annuity payments begin, Your annuity switches from the accumulation phase to the income phase. You can generally change the Annuity Commencement Date by giving us 30 days notice with the new date or age. The earliest Annuity Commencement Date is at least 30 days after You purchase Your Policy. Unless required by state law, the latest Annuity Commencement Date cannot be after the date specified in Your Policy unless a later date is agreed to by us.

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 is eligible to and elects to continue the Policy). If the Annuitant dies after the Annuity Commencement Date, no death benefit is payable and the amount payable will depend on the annuity income option.

Your Policy may not be “partially” Annuitized, i.e., You may not apply a portion of Your Policy Value to an annuity option while keeping the remainder of Your Policy in force.

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 (also known as income 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.)

In deciding on which Annuity Payment Option to elect, You must decide if fixed or variable payments are better for You. 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

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only occur annually under the Initial Payment Guarantee.

You must also decide if You want Your annuity payments to be guaranteed for the Annuitant's lifetime, a period certain, or a combination thereof. Generally, payments will be lower if You combine a period certain, guaranteed amount, or liquidity with a lifetime guarantee (e.g., Life Income with 10 years Certain and Life with Guaranteed Return of Policy proceeds). Likewise, annuity payments will also generally be lower the longer the period certain (because You are guaranteed payments for a longer time).

A charge for premium taxes and an Excess Interest Adjustment may be made when annuity payments begin.

The Annuity Payment Options currently available are explained below. Some options are fixed only.

Income for a Specified Period (fixed only). We will make level annuity payments only for a fixed period. No assets will remain at the end of the period. If Your Policy is a qualified Policy, this Annuity Payment Option may not satisfy minimum required distribution rules. Consult a financial professional 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 annuity payments followed by a smaller final annuity payment.

If Your Policy is a qualified Policy, this Annuity Payment Option may not satisfy minimum required distribution rules. Consult a financial professional 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. The last annuity payment will be the payment immediately before the Annuitant's death. If You choose this option and the Annuitant dies before the due date of the first annuity payment no payments will be made.
•	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 annuity payments we made to You equals the Annuitized amount (i.e., the Adjusted Policy Value less premium tax, if applicable).
•	Life with Emergency Cash^SM (fixed or variable)-Payments will be made during the Annuitant's lifetime. With the Life with Emergency Cash^SM feature, You are able to surrender all or a portion of the Life with Emergency Cash^SM benefit (unlike all other life Annuitization options which are not surrenderable). The amount You surrender must be at least $2,500. We will provide You with a Life with Emergency Cash^SM 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 adviser before requesting a full or partial surrender). The maximum surrender charge is 4% of the premium surrendered (see Expenses - Life with Emergency Cash^SM Surrender Charge 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^SM benefit will continue through age 100 of the Annuitant.
	The Life with Emergency Cash^SM benefit is also a death benefit that is paid upon the death of the Annuitant and is generally equal to the surrender value (i.e., the amount that would be available for surrender according to the Life with Emergency Cash^SM benefit schedule) 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. Annuity payments will be made as long as either person is living. If You choose this option and both joint Annuitants die before the due date of the first annuity payment no payments will be made.
•	10 Year Certain (fixed only) - Payments will be made for the longer of the lifetime of the Annuitant and joint Annuitant or ten years.

•

Life with Emergency Cash^SM (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^SM feature, You are able to surrender all or a portion of the Life with Emergency Cash^SM benefit. The amount You surrender must be at least $2,500. We will provide you with a Life with Emergency Cash^SM 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 adviser before requesting a full or partial surrender). The maximum surrender charge is 4% of the premium surrendered (see Expenses - Life with Emergency Cash^SM Surrender Charge 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^SM benefit will continue through age 100 of the surviving joint

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	Annuitant.
	The Life with Emergency Cash^SM 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.

Other Annuity Payment Options may be arranged by agreement with the Company. Some Annuity Payment Options may not be available for all policies, all ages or we may limit certain Annuity Payment Options to ensure they comply with the applicable tax law provisions.

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 annuity payments dies prior to the end of the guaranteed period;

THEN:

•	the remaining guaranteed annuity 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^SM; and

•	the Annuitant dies (if both joint Annuitants die) before age 101;

THEN:

•	a Life with Emergency Cash^SM 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 annuity payments is responsible for keeping us 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) or a later date if agreed to by us. If You do not elect an Annuity Payment Option, the default option will be variable payments under Life with 10 Years Certain. If any portion of the default Annuitization is a variable payout option, then annuity units will be purchased proportionally based off Your available current investment allocations. Please note, all benefits (including guaranteed minimum death benefits and living benefits) terminate upon Annuitization. The only benefits that remain include the guarantees provided under the terms of the annuity option.

Please Note: If You Annuitize before the maximum Annuity Commencement Date, the payments You receive under the Annuity Payment Options may be less than the guaranteed minimum payments You are entitled to under a GLWB rider (if elected). Please consult Your financial professional about the advisability of Annuitization before the maximum commencement date and the Annuity Payment options available to You.

Benefits Available Under the Policy

The following table summarizes information about the benefits available under the Policy.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Liquidity Rider	Reduces the number of years each premium payment is subject to surrender charges from 7 years to only for the first 4 years.	Optional	Equal to 0.50% annually of the Separate Account Value	• Available only at purchase. • We may credit lower interest rate to amounts allocated to the Fixed Account while the rider is in effect. • You cannot drop this benefit.
“Base Policy” Death Benefit	Pays minimum death benefit generally equal to the greatest of Policy Value, Cash Value plus positive Excess Interest Adjustment, minimum required Cash Value and premium payments (less any adjusted withdrawals).	Standard	No Charge	• Will be in effect if no optional death benefit is elected when You purchase Your Policy. • Withdrawals can significantly reduce benefit value or terminate benefit. • Cannot change death benefit once elected. • Has a mandatory Annuity Commencement Date. • Terminates upon Annuitization.
Double Enhanced Death Benefit (no longer available)	Pays the greater of 6% Annually Compounding death benefit or Monthly Step-Up death benefit	Optional	0.65% annually of average Separate Account Value	• Not available if You or Annuitant is 76 or older on Policy Date. • Must allocate 100% of Policy Value to designated Investment Options. • Withdrawals can significantly reduce benefit value or terminate benefit. • Cannot change death benefit once elected. • Has a mandatory Annuity Commencement Date. • Terminates upon Annuitization.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Annual Step-Up Death Benefit	Pays death benefit equal to highest Policy Value on Policy Date or on any Policy Anniversary prior to Annuitant’s 81st birthday (adjusted for premium payments and withdrawals).	Optional	0.20% annually of average Separate Account Value	• Not available if You or Annuitant is 76 or older on Policy Date. • Withdrawals can significantly reduce benefit value or terminate benefit. • Cannot change death benefit once elected. • ”Step-Up” ends on Policy Anniversary prior to Your 81st birthday. • Has a mandatory Annuity Commencement Date. • Terminates upon Annuitization.
Additional Death Distribution^SM (no longer available)	Can pay an additional benefit at time of death to help alleviate the burden of taxes.	Optional	0.25% - as a percentage annually of Policy Value	• Available for issue ages through 80 (unless state law requires a lower maximum issue age). • Not available in all states.
Additional Death Distribution^SM2003 (no longer available)	Pays an additional death benefit amount based on any rider earnings, since the rider was issued.	Optional	0.25% annually of the Policy Value	• Available for issue ages through 75 and younger. • Not available to Inherited IRAs. • Available only with Return of Premium Death Benefit or Annual Step-Up Death Benefit and subject to same Investment Restrictions. • Additional benefit amount varies by issue age. • Terminates upon Annuitization.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Additional Death Distribution+^SM (no longer available)	Pays an additional death benefit amount that varies depending on time elapsed since rider date.	Optional	0.55% annually of the Policy Value	• Available only for issue ages 69 and younger. • Not available to Inherited IRAs. • Available only with the Return of Premium Death Benefit or Annual Step-Up Death Benefit, and subject to the same Investment Restrictions. • Additional benefit amount during first five years after rider date equal to sum of all rider fees paid since rider date, after five years, benefit equal to percentage of rider benefit base. • Terminates upon Annuitization.
Nursing Care and Terminal Condition Waiver.	Waives Surrender Charges and Excess Interest Adjustments if You or Your spouse are confined to a nursing home or have terminal illness.	Standard	No charge	• Withdrawals are subject to a $1,000 minimum. • Qualifying conditions related to nursing home stay and terminal illness.
Unemployment Waiver.	Waives Surrender Charges and Excess Interest Adjustments if You or Your spouse become unemployed due to involuntary job termination or lay-off.	Standard	No charge	• Qualifying conditions related to job termination and job history. • Must be unemployed for a certain period of time prior to taking withdrawal, be receiving unemployment benefits, and have $5,000 minimum in Cash Value.
Dollar Cost Averaging Program.	Allows You to automatically make transfers into one or more Subaccounts	Standard	No charge	• Traditional – A minimum of $500 per transfer is required. • Minimum and maximum number of transfers. • Special – Limited to six month or twelve month transfer program and only available for new premium payments.
Asset Rebalancing	Automatically rebalances the amounts in Your Subaccounts to maintain Your desired asset allocation percentages.	Standard	No charge	• Does not include any amounts allocated to the Fixed Account.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Systematic Payout Option	Provides monthly, quarterly, semi-annual or annual withdrawals.	Optional	No Charge	• Subject to $40 minimum withdrawals. • Systematic withdrawals in excess of cumulative interest credited from Guaranteed Period Options may be subject to Excess Interest Adjustment. • Systematic withdrawals in excess of remaining Surrender Charge Free Amount may be subject to Surrender Charge. • Systematic withdrawals can significantly reduce benefit value or terminate benefit.
Initial Payment Guarantee	At the time of Annuitization guarantees annually stabilized payments will never be less than a percentage of the initial variable annuity payment at the time You Annuitize.	Optional	1.25% of the daily net asset value	• Available at time of Annuitization. • Payments are stabilized throughout each Policy Year. • The option is irrevocable.
Family Income Protector (no longer available)	This is a Guaranteed Minimum Income Benefit rider that assures You of a minimum level of income in the future.	Optional	Prior to Annuitization (Accumulation Phase) Base fee is 0.30% of the minimum Annuitization value After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account	• Available for issue age 0-80 (unless state law requires a lower maximum issue age). • Guarantees a minimum Annuitization value that You will have to apply to a payment option. • Growth rate of the minimum Annuitization value currently at 6% but will never be less than 3%. • Once issued the growth rate will not change for the life of the rider. • Only available for contracts issued after December of 2000 and prior to February of 2002.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Managed Annuity Program (no longer available)	This is a Guaranteed Minimum Income Benefit rider that assures You of a minimum level of income in the future.	Optional	Prior to Annuitization (Accumulation Phase) Base fee is 0.45% of the minimum income base After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account	• Available for issue age 0-90 (unless state law requires a lower maximum issue age). • Guarantees a minimum Annuitization value that You will have to apply to a payment option. • Growth rate of the minimum Annuitization value currently at 6% but will never be less than 3%. • Once issued the growth rate will not change for the life of the rider. • Only available for contracts issued after March of 2001 and prior to January of 2003.
Managed Annuity Program II (no longer available)	This is a Guaranteed Minimum Income Benefit rider that assures You of a minimum level of income in the future.	Optional	Prior to Annuitization (Accumulation Phase) Base fee is 0.45% of the minimum income base After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account	• Available for issue age 0-84 (unless state law requires a lower maximum issue age). • Guarantees a minimum Annuitization value that You will have to apply to a payment option. • Growth rate of the minimum Annuitization value currently at 5% but could be as low as 0%. • Once issued the growth rate will not change for the life of the rider. • Only available for contracts issued after September of 2002 and prior to January of 2003.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
5 for Life^SM (no longer available)	Guaranteed Lifetime Withdrawal Benefit rider that guarantees withdrawals for the Annuitant’s lifetime, regardless of Policy Value.	Optional	1.35% - annually as a percentage of the total withdrawal base	• Available for issue age 0-90 (unless state law requires a lower maximum issue age). • Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse of beneficiary as new Owner.
5 for Life^SMwith Growth or 5 for Life^SM with Growth and Death (no longer available)	Guaranteed Lifetime Withdrawal Benefit rider that guarantees withdrawals for the Annuitant’s lifetime, regardless of Policy Value.	Optional	Growth Only - 1.35% annually as a percentage of the total withdrawal base Growth and Death - 1.60% annually as a percentage of the total withdrawal base	• Available for issue age at least 55 years old and not yet age 81 (unless state law requires a lower maximum issue age). • Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse of beneficiary as new Owner.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Income Select^SM for Life rider (no longer available)	Guarantees withdrawals for Annuitant’s (or Annuitant’s spouse if younger and joint life option is elected) lifetime regardless of Policy Value.	Optional	Single Life Base Fee - 1.15% annually as a percentage of the total withdrawal base Additional Options (fees added to base fee) 0.25% for Growth Benefit 0.25% for Death Benefit 0.15% for Income Enhancement Joint Life Base Fee - 1.35% annually as a percentage of the total withdrawal base Additional Options (fees added to base fee) 0.50% for Growth Benefit 0.20% for Death Benefit 0.30% for Income Enhancement	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Riders, or with Inherited IRA policies. • Available for Annuitant issue ages 55-80 (unless state law requires a lower maximum issue age). • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Policy Value must be allocated to designated Investment Options. • Excess withdrawals may significantly reduce or terminated the benefit. • Terminates upon Annuitization.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice^® (no longer available)	Guarantees withdrawals for Annuitant’s (or Annuitant’s spouse if younger and joint life option is elected) lifetime regardless of Policy Value.	Optional	Single Life Base Fee - 2.10% annually as a percentage of the withdrawal base Additional Options (fees added to base fee) 0.25% for Death Benefit 0.15% for Income Enhancement Joint Life Base Fee - 2.40% annually as a percentage of the withdrawal base Additional Options (fees added to base fee) 0.20% for Death Benefit 0.30% for Income Enhancement	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider, or with Inherited IRA policies. • Available for Owner/Annuitant issue ages of 0-85 (unless state law requires a lower maximum issue age). • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Rider fees subject to increase (or decrease) at time of any automatic step-up. • Policy Value must be allocated to designated Investment Options. • Excess withdrawals could significantly reduce or terminate the benefits. • The Income Enhancement Option subject to qualifying conditions.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice^® with Double Withdrawal Base Benefit (no longer available)	Guarantees withdrawals for Annuitant’s (or Annuitant’s spouse if younger and joint life option is elected) lifetime regardless of Policy Value.	Optional	Single and Joint Life Base Fees 2.40% annually as a percentage of the total withdrawal base Single Life Additional Options (fees added to base fee) 0.25% for Death Benefit 0.15% for Income Enhancement Joint Life Additional Options (fees added to base fee) 0.20% for Death Benefit 0.30% for Income Enhancement	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider, or with Inherited IRA policies. • Available for Owner/Annuitant issue ages of 0-85 (unless state law requires a lower maximum issue age). • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Rider fees subject to increase (or decrease) at time of any automatic step-up. • Policy Value must be allocated to designated Investment Options. • Excess withdrawals could significantly reduce or terminate the benefits. • The Income Enhancement Option subject to qualifying conditions.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice^® 1.4 (no longer available)	Guarantees withdrawals for Annuitant’s (or Annuitant’s spouse if younger and joint life option is elected) lifetime regardless of Policy Value.	Optional	Base Benefit Fees: 2.30% Designated Fund Group A 1.85% Designated Fund Group B 1.45% Designated Fund Group C Additional Option Fees 0.40% Death Benefit Single Life 0.35% Death Benefit Joint Life 0.30% Income Enhancement Single Life 0.50% Income Enhancement Joint Life	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider, or with Inherited IRA policies. • Available for Owner/Annuitant issue ages of 0-85 (unless state law requires a lower maximum issue age). • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Rider fees subject to increase (or decrease) at time of any automatic step-up. • Policy Value must be allocated to designated Investment Options. • Excess withdrawals could significantly reduce or terminate the benefits. • The Income Enhancement Option subject to qualifying conditions.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice^® 1.2 (no longer available)	Guarantees withdrawals for Annuitant’s (or Annuitant’s spouse if younger and joint life option is elected) lifetime regardless of Policy Value.	Optional	Base Benefit Fees: 2.30% Designated Fund Group A 1.85% Designated Fund Group B 1.45% Designated Fund Group C Additional Option Fees 0.40% Death Benefit Single Life 0.35% Death Benefit Joint Life 0.30% Income Enhancement Single Life 0.50% Income Enhancement Joint Life	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Riders, or with Inherited IRA policies. • Available for Annuitant issue ages 0-85 (unless state law requires a lower maximum issue age). • Benefit subject to Investment Restrictions including Open Allocation Method (“OAM”). • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Rider fees subject to increase (or decrease) at time of any automatic step-up. • Policy Value must be allocated to designated Investment Options. • Withdrawals could significantly reduce or terminate benefit. • Benefit terminates upon Annuitization.

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Name of Benefit	Purpose	Standard or Optional	Maximum Annual Fee	Brief Description of Restrictions/Limitations
Retirement Income Choice 1.6 Rider (no longer available)	Provides Guaranteed Lifetime Withdrawal Benefit amount, which can be withdrawn in any rider year after age 59. Also provides death protection and/or long-term care benefit for an additional fee.	Optional	2.50% annually of the Withdrawal Base 0.55% Death Benefit (Single Life) 0.50% Death Benefit(Joint Life) 0.45% Income Enhancement (Single Life) 0.65% Income Enhancement (Joint Life) If qualifications are met, the Income Enhancement Option increases the income benefit by 50%.	• Cannot be added to a Policy with another active Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider, or with Inherited IRA policies. • Available for Owner/Annuitant issue ages of 0-85. • Joint Life options available subject to certain restrictions and differences, including right to charge higher fee and provide lower annual withdrawal amounts. • Rider fees subject to increase (or decrease) at time of any automatic step-up. • Policy Value must be allocated to designated Investment Options. • Excess withdrawals could significantly reduce or terminate the benefits. • The Income Enhancement Option subject to qualifying conditions, including conditions related to the hospital and/or nursing home stay.
Income Link^SM Rider (no longer available)	Guaranteed Lifetime Withdrawal Benefit using higher withdrawal percentage for a defined period of time and then resets to a lower percentage and (2) an opportunity for increases in the rider withdrawal amount.	Optional (No longer offered)	2.00% annually of withdrawal base	• Must allocate 100% of Policy Value to designated Investment Options. • Cannot be elected with another Guaranteed Minimum Living Benefit or Guaranteed Minimum Income Benefit Rider. • A non-Income Link^SM rider withdrawal (not an RMD) decreases the withdrawal base, impact of withdrawal may be greater than dollar for dollar.

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 (if You pick a variable Annuity Payment

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Option fees and expenses will apply), or may choose to receive the death benefit as a lump sum withdrawal. The guarantees of these death benefits are based on our claims-paying ability. No death benefit will be payable upon or after the Annuity Commencement Date. Please note that there is a mandatory Annuity Commencement Date.

We will determine the amount of and process the death benefit proceeds, if any are payable on a Policy, upon receipt at our Administrative Office of satisfactory proof of the Annuitant's death, directions regarding how to process the death benefit, and any other documents, forms and information that we need (collectively referred to as “due proof of death”). For policies with multiple beneficiaries, we will process the death benefit when the first beneficiary provides us with due proof of their share of the death proceeds. We will not pay any remaining beneficiary their share until we receive due proof of death from that beneficiary. Such beneficiaries continue to bear the investment risk until they submit due proof of death. Please note, we may be required to remit the death benefit proceeds to a state prior to receiving “due proof of death.” SeeAbandoned or Unclaimed Property.

Please Note: Such due proof of death must be received in good order to avoid a delay in processing the death benefit claim. SeeSending Forms and Transaction Requests in Good Order.

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 we receive due proof of death, investments in the Separate Account may be reallocated in accordance with the beneficiary's instructions.

We may permit the beneficiary to give a “one-time” written instruction to reallocate the Policy Value in the Separate Account to the money market fund after the death of the Annuitant. If there is more than one beneficiary, all beneficiaries must agree to the reallocation instructions. This one-time reallocation will be permitted if the beneficiary provides satisfactory evidence of the Annuitant's death.

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 designated beneficiary receiving the death benefit is the surviving spouse of the Owner, then he or she may elect, if eligible, to continue the Policy as the new Annuitant and Owner, instead of receiving the death benefit. SeeDEATH BENEFIT - Spousal Continuation. 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. Generally, upon the Owner's death (who is not the Annuitant) the entire interest must be distributed within five years. SeeTAX INFORMATION for a more detailed discussion of the distribution requirements under the Code.

Deaths After the Annuity Commencement Date

The amount payable, if any, on or after the Annuity Commencement Date depends on the annuity income option.

IF:

•	You are not the Annuitant; and
•	You die on or after the Annuity Commencement Date; and
•	the guaranteed amount in the Policy has not been paid;

THEN:

•	the remaining portion of the guaranteed amount 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.

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IF:

•	You are the Owner and Annuitant; and
•	You die after the Annuity Commencement Date; and
•	the Annuity Payment Option You selected did not have or no longer has a guaranteed period;

THEN:

•	no additional payments will be made.

NOTE: If you elect the Life with Emergency Cash^SM and the Annuitant dies before age 101, then a Life with Emergency Cash^SM death benefit equaling the amount available for surrender will be paid.

IF:

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

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

THEN:

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

Succession of Ownership

If an Owner (who is not the Annuitant) 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.

Spousal Continuation

If the sole primary beneficiary is the spouse, upon the Owner's or the Annuitant's death, the beneficiary may elect to continue the Policy in his or her own name. Upon the Annuitant's death if such election is made, the Policy Value will be adjusted upward (but not downward) to an amount equal to the death benefit amount determined upon such election and receipt of due proof of death of the Annuitant. Any excess of the death benefit amount over the Policy Value will be allocated to each applicable Investment Option in the ratio that the Policy Value in the Investment Option bears to the total Policy Value. The terms and conditions of the Policy that applied prior to the Annuitant's death will continue to apply, with certain exceptions described in the Policy. For purposes of the death benefit on the continued Policy, the death benefit is calculated in the same manner as it was prior to continuation on the date the spouse continues the Policy. SeeTAX INFORMATION - Same Sex Relationships for more information concerning spousal continuation involving same sex spouses.

For these purposes, if the sole primary beneficiary of the Policy is a revocable grantor trust and the spouse of the Owner/Annuitant is the sole grantor, trustee, and beneficiary of the trust and the trust is using the spouse of the Owner/Annuitant's social security number at the time of claim, she or he shall be treated as the Owner/Annuitant's spouse. In those circumstances, the Owner/Annuitant's spouse will be treated as the beneficiary of the Policy for purposes of applying the spousal continuation provisions of the Policy.

For these purposes, if the Owner is an individual retirement account within the meaning of IRC sections 408 or 408A and if the Annuitant's spouse is the sole primary beneficiary of the Annuitant's interest in such account, the Annuitant's spouse will be treated as the beneficiary of the Policy for purposes of applying the spousal continuation provisions of the Policy.

Amount of Death Benefit

Death benefit provisions may differ from state to state. The death benefit may be paid as a lump sum, as annuity payments or as otherwise permitted by the Company in accordance with applicable law. 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:

•	the Policy Value on the date we receive the required information in good order at our Administrative Office;
•	the Cash Value on the date we receive in good order the required information at our Administrative Office (this will be more than the Policy Value if there is a positive Excess Interest Adjustment that exceeds the surrender charge);
•	minimum required Cash Value on the date we receive the required information in good order at our Administrative Office; and

•	the guaranteed minimum death benefit (discussed below), plus premium payments, less gross withdrawals, from the date of death

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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.

Guaranteed Minimum Death Benefit

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

The guaranteed minimum death benefit terminates upon Annuitization and there is a mandatory Annuity Commencement Date. On the Policy application, you may generally choose a guaranteed minimum death benefit listed below (age limitations may apply) for an additional fee. After the Policy is issued, you cannot make an election and the death benefit cannot be changed.

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 withdrawals (please seeAppendix - Death Benefit) 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 withdrawals (please seeAppendix - Death Benefit) as of the date of death.

This benefit is not available if You or the Annuitant is 86 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 a guaranteed minimum death benefit if You do not choose one when You purchase Your Policy.

Double Enhanced Death Benefit - No Longer Available

The death benefit under this option is the greater of 1 or 2 below:

1.	The 6% Annually Compounding through age 80 Death Benefit, which is equal to:

•	the total premium payments; less
•	any adjusted partial withdrawals;

•	accumulated at an effective annual rate of 6% from each premium payment date and each surrender date to the earlier of the Annuitant's date of death or the Annuitant's 81st birthday.

2.	The Monthly Step-Up through age 80 Death Benefit, which is equal to:

•	the largest Policy Value on the Policy Date or on any monthly anniversary before the earlier of the Annuitant's date of death or the Annuitant's 81st birthday; plus
•	any premium payments since the date of any monthly anniversary with the largest Policy Value; minus
•	any adjusted partial withdrawals since the date of the monthly anniversary with the largest Policy Value.

This benefit is not available if the Owner or Annuitant is age 76 or older on the Policy Date and requires you to invest only in certain “designated Investment Options”. There is an extra charge for this death benefit of 0.65% annually.

Designated Investment Options. If You elected the Double Enhanced Death Benefit, You must allocate 100% of Your Policy Value to one or more of the designated Investment Options approved for the Double Enhanced Death Benefit. SeeAppendix - Designated Investment Options for a complete listing of available Investment Options. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit.

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Please note:

•	All Policy Value must be allocated to one or more designated Investment Options or Your death benefit will terminate.
•	You may transfer amounts among the designated Investment Options; however, You cannot transfer any amount to any other Subaccount if You elect this death benefit.

The Double Enhanced Death Benefit was not available if a Guaranteed Lifetime Withdrawal Benefit was chosen.

The Guaranteed Minimum Death Benefit may vary for certain policies and may not be available for all policies, in all states, at all times or through all financial intermediaries. Once You elect a death benefit and Your Policy is issued, Your death benefit cannot be changed and You will not be impacted by a decision to discontinue offering any particular guaranteed minimum death benefit to new sales.

Adjusted Partial Withdrawal

When You request a partial withdrawal, Your guaranteed minimum death benefit will be reduced by an amount called the adjusted partial withdrawal. Under certain circumstances, the adjusted partial withdrawal may be more than the dollar amount of Your withdrawal request. This will generally be the case if the guaranteed minimum death benefit exceeds the Policy Value at the time of withdrawal. It is also possible that if a death benefit is paid after You have made a partial withdrawal, then the total amount paid could be less than the total premium payments.

The formula used to calculate the adjusted partial withdrawal amount is: adjusted partial withdrawal = (amount of the withdrawal * the current death proceeds prior to the withdrawal) / Policy Value prior to the withdrawal.

We have included a detailed explanation of this adjustment with examples in the Appendix - Death Benefit. This is referred to as “adjusted partial withdrawal” in Your Policy. If You have a qualified Policy, minimum required distributions rules may require You to request a partial withdrawal.

Optional Benefit Riders

You may have elected one of the following optional riders previously available for purchase which are no longer available. The following rider grid describes the material features of each of those riders. Please refer to Your personal rider pages and any supplemental mailings for Your specific coverage and features regarding these riders.

Listed below are the abbreviations that will be used in the following grids for Your reference.

Abbreviation		Definition
ADB		Additional Death Benefit
ADD		Additional Death Distribution
ADD+		Additional Death Distribution Plus
DB		Death Benefit
DCA		Dollar Cost Averaging
FIP		Family Income Protector
GFV		Guaranteed Future Value
GMAB		Guaranteed Minimum Accumulation Benefit
GMDB		Guaranteed Minimum Death Benefit
GMIB		Guaranteed Minimum Income Benefit
GMLB		Guaranteed Minimum Living Benefit
GMWB		Guaranteed Minimum Withdrawal Benefit
GPO		Guaranteed Period Option
GPS		Guaranteed Principal Solution^SM
IE		Income Enhancement^SM
ILSD		Income Link Start Date
ILSW		Income Link Systematic Withdrawal

Abbreviation		Definition
ILWY		Income Link Withdrawal Year
ISFL		Income Select^SM For Life
MAP		Managed Annuity Program
MAV		Minimum Annuitization Value
MAWA		Maximum Annual Withdrawal Amount
MIB		Minimum Income Base
MRWA		Minimum Remaining Withdrawal Amount
N/A		Not Applicable
OAM		Open Allocation Method
PAM		Portfolio Allocation Method
RDB		Rider Death Benefit
RIC		Retirement Income Choice^®
RMD		Required Minimum Distribution
RWA		Rider Withdrawal Amount
TWB		Total Withdrawal Base
WB		Withdrawal Base
WD		Withdrawal

Income Link^SM Rider Specific Withdrawal Benefit Terms:

Withdrawal Option Election Date - This is the date the withdrawal option is selected by the Policy Owner. The RWA is zero prior to the establishment of this date. The date and the corresponding withdrawal option can change any time prior to the ILSD. Once ILSD is set, it cannot be changed.

ILSD - This is the date the Policy Owner elects to begin receiving payments using one of the 4 ILSW options. This date may be changed prior to the establishment of the withdrawal year.

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ILWY - Also known as the withdrawal year, is each 12 month period beginning on the ILSD. This is the time period for withdrawing your RWA which is reset at the beginning of each withdrawal year.

ILSW - This rider offers 4 new systematic payment options specific to this rider only. ANY withdrawal that is not an ILSW (including other systematic payment options) will be treated as a 100% excess.

The information below is a summary of riders previously available for purchase which are no longer available.

Rider Name	Family Income Protector	Managed Annuity Program	Managed Annuity Program II
Rider Form Number¹	RGMI 1 798	RGMI 15 0301	RGMI 21 0902
Purpose of Rider	• This is a GMIB rider. • Assures You of a minimum level of income in the future by guaranteeing a MAV that You will have to apply to a payment option. • Growth rate for MAV is currently at 6% but will never be less than 3%. • Once rider is issued, the annual growth rate will not change during the life of a rider. • The rider also guarantees a minimum amount for those payments once You begin to receive them.	• This is a GMIB rider. • Assures You of a minimum level of income in the future by guaranteeing a MIB that You will have to apply to a payment option. • Growth rate for MIB is 6% but will never be less than 3% • Once rider is issued, the annual growth rate will not change during the life of a rider. • The rider also guarantees a minimum amount for those payments once You begin to receive them.	• This is a GMIB rider. • Assures You of a minimum level of income in the future by guaranteeing a MIB that You will have to apply to a payment option. • Growth rate for MIB is 5% but there is no guaranteed minimum growth rate for the rider and it could be as low as 0% • Once rider is issued, the annual growth rate will not change during the life of a rider. • The rider also guarantees a minimum amount for those payments once You begin to receive them.
Availability	• Issue age 0-80, but not yet 81 years old (unless state law requires a lower maximum issue age) • If You terminate the FIP rider (except pursuant to an upgrade) You cannot re-elect the rider. • Available on contracts issued after December of 2000 and prior to February of 2002. NOTE: As of February 2002, no new issues of this rider are allowed. This does not change any of the other terms and conditions of the FIP riders issued before February of 2002.	• Issue age 0-90, but not yet 91 years old (unless state law requires a lower maximum issue age) • If You terminate the MAP (except pursuant to an upgrade) You cannot re-elect the rider. • Available on contracts issued after March of 2001 and prior to January of 2003. NOTE: As of January 24, 2003, no new issues of this rider are allowed. This does not change any of the other terms and conditions of any MAP riders added on or before January 24, 2003.	• Issue age 0-84, but not yet 85 years old (unless state law requires a lower maximum issue age) • If You terminate the MAP II (except pursuant to an upgrade) You cannot re-elect the rider. • Available on contracts issued after September of 2002 and prior to January of 2003. NOTE: As of January 24, 2003, no new issues of this rider are allowed. This does not change any of the other terms and conditions of any MAP II riders added on or before January 24, 2003.
Base Benefit and Optional Fees	Prior to Annuitization (Accumulation Phase) Base fee is 0.30% of the MAV After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account.	Prior to Annuitization (Accumulation Phase) Base fee is 0.45% of the MIB After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account.	Prior to Annuitization (Accumulation Phase) Currently 0.45% of the MIB After Annuitization (Income Phase) Guaranteed Minimum Payment Fee is 1.25% of the daily net asset value in the Separate Account.
Fee Frequency	• The rider fee is charged annually on the rider date prior to Annuitization. • Fee is also assessed at time of total surrender of the annuity, or Annuitization. • The rider fee is waived if the Policy Value is greater than 200% of the MAV.	• The rider fee is charged annually on the rider date prior to Annuitization. • Fee is also assessed at time of total surrender of the annuity, or Annuitization. • The rider fee is waived if the Policy Value is greater than 200% of the MIB.	• The rider fee is charged annually on the rider date prior to Annuitization. • Fee is also assessed at time of total surrender of the annuity, or Annuitization.
Death Benefit	N/A	N/A	N/A
Investment Restrictions and/or Designated Funds Available	N/A	N/A	N/A
Withdrawal Benefits	N/A	N/A	N/A
Automatic Step-Up Benefit	N/A	N/A	N/A

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Rider Name	Family Income Protector	Managed Annuity Program	Managed Annuity Program II
Rider Form Number¹	RGMI 1 798	RGMI 15 0301	RGMI 21 0902
Exercising Rider	• Must wait a minimum of 10 years to Annuitize with the benefits of this rider. • Once the 10-year waiting period has been satisfied, may only Annuitize within 30 days after any Policy anniversary prior to the 95^th birthday in order to utilize the benefit of the FIP. • Annuity payments under the FIP are guaranteed to never be less than the initial payment. • During the first year of Annuitization, each payment will be stabilized to equal the first or initial payment. • During subsequent years, the stabilized payment will be either increased or decreased (never below the initial payment), and held level for that year. • Settlement options available for Annuitization are: –Life Only –Life w/10 Years Certain –Joint Life & Full Survivor –Joint Life & Full Survivor w/10 Years Certain	• May Annuitize within 30 days after any rider anniversary prior to the 95^th birthday. • If You Annuitize any time other than 30 days after any rider anniversary prior to the 95^th birthday You cannot utilize the benefits of the MAP. • Annuity payments under the MAP are guaranteed to never be less than the initial payment. • During the first year of Annuitization, each payment will be stabilized to equal the first or initial payment. • During subsequent years, the stabilized payment will be either increased or decreased (never below the initial payment), and held level for that year. • Settlement options available for Annuitization are: –Life Only –Life w/10 Years Certain –Joint Life & Full Survivor –Joint Life & Full Survivor w/10 Years Certain	• May Annuitize within 30 days after any rider anniversary prior to the 95^th birthday. • If You Annuitize any time other than 30 days after any rider anniversary prior to the 95^th birthday You cannot utilize the benefits of the MAP II. • Annuity payments under the MAP II are guaranteed to never be less than the initial payment. • During the first year of Annuitization, each payment will be stabilized to equal the first or initial payment. • During subsequent years, the stabilized payment will be either increased or decreased (never below the initial payment), and held level for that year. • Settlement options available for Annuitization are: –Life Only –Life w/10 Years Certain –Life w/20 Years Certain –Joint Life & Full Survivor –Joint Life & Full Survivor w/10 Years Certain –Joint Life & Full Survivor w/20 Years Certain
Income Benefit or Other Benefit Payout Considerations	If You choose to Annuitize Your Policy prior to the end of the 10 year waiting period, you may not utilize the benefit of the FIP rider.	If You Annuitize using the MAP rider before the 10^th rider anniversary, the first payment will be calculated with an annuity factor age adjustment resulting in lower payments than if an annuity factor age adjustment was not used. The age adjustment shown in the table below should be subtracted from Your current age nearest birthday. The years shown in the table below should be considered complete years since the Rider Date and the age adjustment is as follows: Rider YearsAge Adjustment 1................................................9 2................................................8 3................................................7 4................................................6 5................................................5 6................................................4 7................................................3 8................................................2 9................................................1 10+............................................0	If You Annuitize using the MAP II rider before the 10^th rider anniversary, the MAP II annuity income will not be fully vested and the first payment will be calculated with an annuity income vesting percentage of less than 100%, which reduces the amount of Your first payment by up to 50%. The years shown in the table below should be considered complete years since the Rider Date and the income vesting schedule is as follows: Rider YearsVesting % 1...........................................50% 2...........................................55% 3...........................................60% 4...........................................65% 5...........................................70% 6...........................................75% 7...........................................80% 8...........................................85% 9...........................................90% 10.......................................100%
Rider Upgrade	• Can upgrade the rider within 30 days after any Policy anniversary, prior to the Annuitant's 85^th birthday. • The old rider is terminated, and the new rider is issued. • New rider is issued using the current Policy Value, and not the original premium.	• Can upgrade any time after the first Rider Anniversary and prior to the Annuitant's 91^st birthday. • The old rider is terminated, and the new rider is issued. • New rider is issued using the current Policy Value, and not the original premium.	• Can upgrade any time within 30 days after any Rider Anniversary prior to the Annuitant's 85^th birthday. • The old rider is terminated, and the new rider is issued. • New rider is issued using the current Policy Value, and not the original premium.

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Rider Name	Family Income Protector	Managed Annuity Program	Managed Annuity Program II
Rider Form Number¹	RGMI 1 798	RGMI 15 0301	RGMI 21 0902
	• The policyholder upgrades to whatever rider is available at the time of the upgrade, including any charges and features. • Effective between February of 2002 and May of 2003 the rider available for upgrade was the MAP. • Effective since May of 2003 the rider available for upgrade is the MAP II.	• The policyholder upgrades to whatever rider is available at the time of the upgrade, including any charges and features. • Effective May of 2003 the only rider available for upgrade is the MAP II.	• The policyholder upgrades to whatever rider is available at the time of upgrade, including all its charges and features.
Rider Termination	The rider is irrevocable and cannot be terminated upon request. The rider however can be terminated upon the earliest of the following: • Annuitization (You will still get guaranteed minimum stabilized payments if You Annuitize using the MAV under the FIP); • upgrade (although a new rider will be issued); • termination of Your Policy; or • 30 days after the Rider Anniversary after Your 94^th birthday (earlier if required by state law).	The rider will terminate upon the earliest of the following: • the date we receive Written Notice from You requesting termination of the MAP (You may not terminate the rider before the first rider anniversary); • Annuitization (You will still get guaranteed minimum stabilized payments if You Annuitize using the MIB under the MAP); • upgrade (although a new rider will be issued); • termination of Your Policy; or • 30 days after the Rider Anniversary after Your 94^th birthday (earlier if required by state law).	The rider will terminate upon the earliest of the following: • the date we receive Written Notice from You requesting termination of the MAP II (You may not terminate the rider before the first rider anniversary); • Annuitization (You will still get guaranteed minimum stabilized payments if You Annuitize using the MIB under the MAP II); • upgrade (although a new rider will be issued); • termination of Your Policy; or • 30 days after the Rider Anniversary after Your 94^th birthday (earlier if required by state law).

Rider Name	Additional Death Distribution	5 For Life^SM3	5 For Life^SM with Growth 5 For Life^SM with Growth and Death³
Rider Form Number¹	RTP 1 201	RGMB 12 0105	RGMB 14 0905 (Growth Only) RGMB 15 0905 (Growth and Death)
Purpose of Rider	This is an Additional Death Benefit Rider which can pay an additional benefit at time of death to help alleviate the burden of taxes.	This is a GLWB Rider that guarantees withdrawals for the Annuitant's lifetime, regardless of Policy Value. • The policyholder can withdraw the MAWA each calendar year until the death of the Annuitant. • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB Rider that guarantees withdrawals for the Annuitant's lifetime, regardless of Policy Value. • The policyholder can withdraw the MAWA each calendar year until the death of the Annuitant. • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.
Availability	• Issue age 0-80, but not yet 81 years old (unless state law requires a lower maximum issue age) • Not available in all states. • Can be added at any time including post-issue.	• Issue age 0-90, but not yet 91 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person, trust or custodial. • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits.	• Issue age at least 55 years old and not yet 81 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person, trust or custodial). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits.

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Rider Name	Additional Death Distribution	5 For Life^SM3	5 For Life^SM with Growth 5 For Life^SM with Growth and Death³
Rider Form Number¹	RTP 1 201	RGMB 12 0105	RGMB 14 0905 (Growth Only) RGMB 15 0905 (Growth and Death)
		• Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Percentage of Policy Value - 0.25%	Percentage of TWB - 0.60% (prior to 11/4/13)	Growth Only - Percentage of TWB - 0.60% (prior to 11/4/13) Growth and Death - Percentage of TWB - 0.85% (prior to 11/4/13)
Fee Frequency	Assessed each rider anniversary and at rider termination and equal to the Policy Value multiplied by rider fee percentage.	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	The rider itself provides an additional death benefit to help alleviate the burden of taxes upon death for the beneficiary of the tax-deferred annuity.	Upon the death of the Annuitant this rider will pay an additional death benefit amount equal to the excess, if any, of the MRWA over the base Policy death benefit and then this rider will terminate.	• Growth Only - N/A • Growth and Death - Upon the death of an Annuitant this rider will pay an additional death benefit amount equal to the excess, if any, of the MRWA over the base Policy death benefit and then this rider will terminate.
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated fund based on rider issue date. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Appendix - Portfolio Companies Available Under the Policy in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.	N/A	TA BlackRock Government Money Market TA JPMorgan Asset Allocation - Conservative TA JPMorgan Asset Allocation - Moderate TA JPMorgan Asset Allocation - Growth TA JPMorgan International Moderate Growth TA Multi-Managed Balanced Fixed Account GPOs or DCA Accounts	TA BlackRock Government Money Market TA JPMorgan Asset Allocation - Conservative TA JPMorgan Asset Allocation - Moderate TA JPMorgan Asset Allocation - Growth TA JPMorgan International Moderate Growth TA Multi-Managed Balanced Fixed Account GPOs or DCA Accounts
Withdrawal Benefits - See Appendix - Hypothetical Adjusted Partial Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders for examples showing the effect of withdrawals on the WB.	N/A	The MAWA that can be withdrawn per calendar year under this rider is equal to the TWB multiplied by the For Life Withdrawal Percentage. • Starting with January 1^st following the Annuitant's 59^th birthday, the withdrawal percentage increases	The MAWA that can be withdrawn per calendar year under this rider is equal to the TWB multiplied by the For Life Withdrawal Percentage. • Starting with January 1^st following the Annuitant's 59^th birthday, the withdrawal percentage increases

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Rider Name	Additional Death Distribution	5 For Life^SM3	5 For Life^SM with Growth 5 For Life^SM with Growth and Death³
Rider Form Number¹	RTP 1 201	RGMB 12 0105	RGMB 14 0905 (Growth Only) RGMB 15 0905 (Growth and Death)
		above 0% which creates a MAWA available under the rider for withdrawal. • On each January 1^st the MAWA will be reset equal to the greater of: 1) The For Life TWB multiplied by the Withdrawal Percentage, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.	above 0% which creates a MAWA available under the rider for withdrawal. • On each January 1^st the MAWA will be reset equal to the greater of: 1) The For Life TWB multiplied by the Withdrawal Percentage, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.
Automatic Step-Up Benefit	N/A	N/A	N/A
Exercising Rider	Amount is paid whenever a death benefit is paid and the rider is attached. • amount paid=ADB Factor x Rider Earnings* • ADB Factor - 40% for issue ages 0-70 and 25% for issue ages 71-80. *Rider earnings are defined as: –the death proceeds of the base Policy; 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. NOTE: No benefit is payable under the ADB rider if there are no rider earnings on the date the death benefit is calculated.	• The policyholder is guaranteed to be able to withdraw up to the MAWA each calendar year even if the Policy Value is zero at the time of the withdrawal. • If the Policy Value goes to zero, but the minimum withdrawal benefits are still guaranteed, the policyholder can no longer add premiums or take withdrawals in excess of the MAWA. • The rider benefits cease when the Annuitant has died (the withdrawals do not continue for the lifetime of any spouse who continues the Policy when the original Annuitant dies).	• The policyholder is guaranteed to be able to withdraw up to the MAWA each calendar year even if the Policy Value is zero at the time of the withdrawal. • If the Policy Value goes to zero, but the minimum withdrawal benefits are still guaranteed, the policyholder can no longer add premiums or take withdrawals in excess of the MAWA. • The rider benefits cease when the Annuitant has died (the withdrawals do not continue for the lifetime of any spouse who continues the Policy when the original Annuitant dies).
Income Benefit or Other Benefit Payout Considerations	Spousal Continuation: If a spouse is eligible to and elects to continue the Policy as the new Owner instead of receiving a death benefit and Additional Death Benefit, the spouse will generally receive a one-time Policy Value increase equal to the Additional Death Benefit. At this time the rider will terminate.	N/A	Growth: The TWB will accumulate using the growth rate of 5% until the earlier of the first withdrawal or the 10^th rider anniversary.
Rider Upgrade	N/A	• May upgrade their rider anytime after the 3^rd anniversary as long as the Annuitant meets age requirements in effect at that time. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 90 years old. • An upgrade will reset the TWB, MRWA and MAWA values. • Rider Fee will be the fee that applies to the new rider at the time of upgrade.	• May upgrade their rider anytime after the 3^rd anniversary as long as the Annuitant meets age requirements in effect at that time. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 81 years old. • An upgrade will reset the TWB, MRWA and MAWA values. • Rider Fee will be the fee that applies to the new rider at the time of upgrade.
Rider Termination	The rider can be added or dropped at

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Rider Name	Additional Death Distribution	5 For Life^SM3	5 For Life^SM with Growth 5 For Life^SM with Growth and Death³
Rider Form Number¹	RTP 1 201	RGMB 12 0105	RGMB 14 0905 (Growth Only) RGMB 15 0905 (Growth and Death)
	any time. If the rider is dropped and re-added, the rider will only cover earnings accumulated since the rider was re-added. The rider will remain in effect until: • You cancel it by notifying our Administrative Office in writing. • the Policy is Annuitized or surrendered. • or the additional death benefit is paid.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • The policyholder must wait 3 years from the Rider Add Date to terminate. • After the three-year waiting period, the policyholder may terminate the rider at any time. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • The policyholder must wait 3 years from the Rider Add Date to terminate. • After the three-year waiting period, the policyholder may terminate the rider at any time. • The rider will be terminated the date we receive Written Notice from You requesting termination.

Rider Name	Living Benefit Rider 2003	Living Benefit Rider 2004	Income Select^SM For Life³
Rider Form Number¹	RGMB 1 0603 (2003)	RGMB 4 0504 (2004)	RGMB 18 0106 (w/o IE) RGMB 20 0106 (with IE)
Purpose of Rider	This is a Living Benefit Rider and should be viewed as a way to permit You to invest in variable Investment Options while still having Your Policy Value and liquidity protected to the extent provided by this rider. This rider is a combination of two separate annuity guarantees: 1) A GMWB and 2) A GMAB (a.k.a. principal protection benefit or guarantee future value benefit). The rider will guarantee that the Policy Value of the Policy will be at least as high as the GFV after a waiting period has expired.	This is a Living Benefit Rider and should be viewed as a way to permit You to invest in variable Investment Options while still having Your Policy Value and liquidity protected to the extent provided by this rider. This rider is a combination of two separate annuity guarantees: 1) A GMWB and 2) A GMAB (a.k.a. principal protection benefit or guarantee future value benefit). The rider will guarantee that the Policy Value of the Policy will be at least as high as the GFV after a waiting period has expired.	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the MAWA each year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.
Availability	• Issue age 0-80, but not yet 81 years old (unless state law requires a lower maximum issue age). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner. **Effective 5/1/2005: This rider is only available for states that have not approved the 2005 version of the Living Benefit Rider.	• Issue age 0-80, but not yet 81 years old (unless state law requires a lower maximum issue age). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner. **Effective 5/1/2005: This rider is only available for states that have not approved the 2005 version of the Living Benefit Rider.	• Issue age at least 55 years old, but not yet 81 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant) • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Percentage of “Principal Back” TWB - 0.75%	Percentage of “Principal Back” TWB - 0.90% (5/1/2009 - 11/3/13) Percentage of “Principal Back” TWB - 0.60% (prior to 5/1/2009)	Percentage of the TWB. Additional option fees would be added to the base. Single Life (5/1/07 - 11/3/13)

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Rider Name	Living Benefit Rider 2003	Living Benefit Rider 2004	Income Select^SM For Life³
Rider Form Number¹	RGMB 1 0603 (2003)	RGMB 4 0504 (2004)	RGMB 18 0106 (w/o IE) RGMB 20 0106 (with IE)
			Base Fee .....................................0.40% Growth Benefit Fee...................0.25% DB Fee......................................0.25% IE Benefit Fee............................0.15% (prior to 5/1/07) Base Fee.....................................0.40% Growth Benefit Fee...................0.25% DB Fee......................................0.25% IE Benefit Fee............................0.10% Joint Life (5/1/07 - 11/3/13) Base Fee.....................................0.60% Growth Benefit Fee...................0.50% DB Fee......................................0.20% IE Benefit Fee............................0.30% (prior to 5/1/07) Base Fee.....................................0.60% Growth Benefit Fee...................0.50% DB Fee......................................0.20% IE Benefit Fee............................0.20%
Fee Frequency	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	N/A	N/A	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of the Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the MRWA over the base Policy death benefit and then this rider will terminate.
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated fund based on rider issue date. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Portfolios Companies Available Under The Policy Appendix in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.	Must adhere to the Portfolio Allocation Method. See below.	Must adhere to the Portfolio Allocation Method. See below.	TA BlackRock Government Money Market TA JPMorgan Asset Allocation - Conservative TA JPMorgan Asset Allocation - Moderate TA JPMorgan Asset Allocation - Moderate Growth TA JPMorgan International Moderate Growth TA Multi-Managed Balanced Fixed Account GPOs or DCA Accounts
Allocation Methods	Portfolio Allocation Method (PAM):	Portfolio Allocation Method (PAM):	N/A

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Rider Name	Living Benefit Rider 2003	Living Benefit Rider 2004	Income Select^SM For Life³
Rider Form Number¹	RGMB 1 0603 (2003)	RGMB 4 0504 (2004)	RGMB 18 0106 (w/o IE) RGMB 20 0106 (with IE)
	• This program will automatically allocate assets from the policyholder's Subaccount to a Subaccount of our choosing when the Policy Value has dropped relative to the guaranteed amount. • If the Policy Value increases enough in relation to the guaranteed amounts, the money may be moved back into the Subaccounts (pro-rata based on the policyholder's current Subaccount values). • The allocation of assets between the accounts is at our sole discretion but will initially use modern financial theory to determine the correct allocation. • The policyholder may not allocate premium payments to, nor transfer Policy Value into or out of, the PAM Investment Options. Current PAM Safe Fund: TA Aegon U.S. Government Securities	• This program will automatically allocate assets from the policyholder's Subaccount to a Subaccount of our choosing when the Policy Value has dropped relative to the guaranteed amount. • If the Policy Value increases enough in relation to the guaranteed amounts, the money may be moved back into the Subaccounts (pro-rata based on the policyholder's current Subaccount values). • The allocation of assets between the accounts is at our sole discretion but will initially use modern financial theory to determine the correct allocation. • The policyholder may not allocate premium payments to, nor transfer Policy Value into or out of, the PAM Investment Options. Current PAM Safe Fund: TA Aegon U.S. Government Securities
Withdrawal Benefits - SeeLiving Benefits Rider Adjusted Partial Withdrawals and Hypothetical Adjusted Partial Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders appendices for examples showing the effect of withdrawals on the WB.	The GMWB guarantees a withdrawal amount regardless of the Policy Value. The policyholder has 2 withdrawal guarantees available. Once the rider is issued, values for both withdrawal guarantees will be calculated indefinitely as follows: a) 7% Principal Back: The policyholder can withdraw up to 7% of the 7% Principal Back TWB per year until at least the time at which the 7% Principal Back MRWA has reached zero. b) 5% For Life: The policyholder can withdraw up to 5% of the 5% For Life TWB each year starting with the Rider Anniversary following the Annuitant's 59^th birthday until at least the later of the death of the Annuitant or the time when the 5% For Life MRWA* has reached zero. * The MRWA represents the total minimum dollar amount of guaranteed withdrawals the policyholder has remaining provided they take no more than the MAWA each year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.	The GMWB guarantees a withdrawal amount regardless of the Policy Value. The policyholder has 2 withdrawal guarantees available. Once the rider is issued, values for both withdrawal guarantees will be calculated indefinitely as follows: a) 7% Principal Back: The policyholder can withdraw up to 7% of the 7% Principal Back TWB per year until at least the time at which the 7% Principal Back MRWA has reached zero. b) 5% For Life: The policyholder can withdraw up to 5% of the 5% For Life TWB each year starting with the Rider Anniversary following the Annuitant's 59^th birthday until at least the later of the death of the Annuitant or the time when the 5% For Life MRWA* has reached zero. * The MRWA represents the total minimum dollar amount of guaranteed withdrawals the policyholder has remaining provided they take no more than the MAWA each year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.	The MAWA that can be withdrawn per calendar year under this rider is equal to the TWB multiplied by the For Life Withdrawal Percentage based on the Annuitant's² attained age at the time of the first withdrawal. • Starting with January 1^st following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a MAWA available under the rider for withdrawal. • On each January 1^st following the Rider Date, the MAWA will be reset equal to the greater of: 1) The For Life TWB multiplied by the For Life Withdrawal Percentage based on the Annuitant's² attained age, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.
Automatic Step-Up Benefit	N/A	N/A	N/A
Exercising Rider	For Life GMWB: The policyholder is guaranteed to be able to withdraw up to the For Life MAWA until the later of 1) the Annuitant's death or 2) the For Life MRWA is zero. Principal Back GMWB: The policyholder is guaranteed to be	For Life GMWB: The policyholder is guaranteed to be able to withdraw up to the For Life MAWA until the later of 1) the Annuitant's death or 2) the For Life MRWA is zero. Principal Back GMWB: The policyholder is guaranteed to be	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the MAWA each calendar year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This

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Rider Name	Living Benefit Rider 2003	Living Benefit Rider 2004	Income Select^SM For Life³
Rider Form Number¹	RGMB 1 0603 (2003)	RGMB 4 0504 (2004)	RGMB 18 0106 (w/o IE) RGMB 20 0106 (with IE)
	able to withdraw up to the Principal Back MAWA until the Principal Back MRWA is zero. GMAB: At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, the GMAB feature will add the difference to the Policy Value on a pro-rata basis based on their current account value. a) The addition to the Policy will not be considered premium and should not affect any other Policy calculations, including the GMDB calculations. b) At the end of the waiting period, the GMAB will not provide any more benefits, unless the policyholder chooses to upgrade the rider.	able to withdraw up to the Principal Back MAWA until the Principal Back MRWA is zero. GMAB: At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, the GMAB feature will add the difference to the Policy Value on a pro-rata basis based on their current account value. a) The addition to the Policy will not be considered premium and should not affect any other Policy calculations, including the GMDB calculations. b) At the end of the waiting period, the GMAB will not provide any more benefits, unless the policyholder chooses to upgrade the rider.	optional feature may be elected with this rider. Upon the death of an Annuitant² this rider will pay an additional death benefit amount equal to the excess, if any, of the MRWA over the base Policy death benefit. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical impairment; does not include dementia, Alzheimer's or other forms of mental illness. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.
Income Benefit or Other Benefit Payout Considerations	The GFV is the Policy Value we are guaranteeing on the GFV date. After the Rider Issue Date, the GFV is equal to the GFV on the Rider Issue Date, plus a percentage of premiums (not including premium enhancements) received after the Rider Date as shown in the table below, less an adjustment for withdrawals. Year Rec'd% Added to GFV 1.........................................100% 2...........................................90% 3...........................................80% 4...........................................70% 5...........................................60% 6-10.....................................50% 10+.........................................0% At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, we will add the difference to the Policy Value on a pro-rata basis based on their current Policy Value.	The GFV is the Policy Value we are guaranteeing on the GFV date. After the Rider Issue Date, the GFV is equal to the GFV on the Rider Issue Date, plus a percentage of premiums (not including premium enhancements) received after the Rider Date as shown in the table below, less an adjustment for withdrawals. Year Rec'd% Added to GFV 1.........................................100% 2...........................................90% 3...........................................80% 4...........................................70% 5...........................................60% 6-10.....................................50% 10+.........................................0% At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, we will add the difference to the Policy Value on a pro-rata basis based on their current Policy Value.	Growth: This optional feature rewards the policyholder for delaying their first withdrawal. The TWB will accumulate using the growth rate of 5% until the earlier of the first withdrawal or the 10^th rider anniversary. The income benefit percentage is determined by the Annuitant's² age at the time of the first withdrawal taken on or after January 1^st following the Annuitant's² 59^th birthday. The income benefit percentage is as follows: Age 1st WDFor Life WD% 55-58..................................0.0% 59-64..................................4.5% 65-69..................................5.0% 70-74..................................5.5% 75-79..................................6.0% 80-84..................................6.5% 85-89..................................7.0% 90-94..................................7.5% 95+......................................8.0% Please note that once established at the time of the first withdrawal, the income benefit percentage will not increase even though the Annuitant's² age increases.
Rider Upgrade	Rider upgrades are not available.	• May upgrade anytime after the 5^th Anniversary by terminating the rider and adding the new rider in place at that time, as long as the covered lives meet the age requirements in effect at that time. • Must be prior to the Annuitant's 86^th birthday	• Upgrades allowed within 30-day window following the 1^st rider anniversary and each rider anniversary thereafter. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 81 years old.

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Rider Name	Living Benefit Rider 2003	Living Benefit Rider 2004	Income Select^SM For Life³
Rider Form Number¹	RGMB 1 0603 (2003)	RGMB 4 0504 (2004)	RGMB 18 0106 (w/o IE) RGMB 20 0106 (with IE)
		• An upgrade will reset the MRWA, TWB, MAWA and the GFV values. • Rider Fee will be the fee that applies to the new rider at the time of upgrade.	• An upgrade will reset the MRWA, TWB, MAWA and the Income Benefit Percentage determination. • Rider Fee will be the fee that applies to the new rider at the time of upgrade. • Growth percentage will be the percentage available at the time of upgrade.
Rider Termination	• The rider will be terminated upon Policy surrender, Annuitization or upgrade. • The policyholder must wait 5 years from the Rider Start Date to terminate. • After the five-year waiting period, the policyholder may terminate the rider at any time. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization or upgrade. • The policyholder must wait 5 years from the Rider Start Date to terminate. • After the five-year waiting period, the policyholder may terminate the rider at any time. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each rider anniversary. • The rider will be terminated the date we receive Written Notice from You requesting termination.

Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
Purpose of Rider	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.
Availability	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at	Percentage of WB. Additional option	Percentage of WB. Additional option	Fee based on designated allocation

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Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
issue	fees would be added to the base. Single Life (prior to 11/4/13) Base Fee.....................................0.60% DB Fee......................................0.25% IE Benefit Fee............................0.15% Joint Life (prior to 11/4/13) Base Fee.....................................0.90% DB Fee......................................0.20% IE Benefit Fee............................0.30%	fees would be added to the base. Single Life (1/19/09 - 11/3/13) Base Fee.....................................0.90% DB Fee......................................0.25% IE Benefit Fee............................0.15% (11/10/08 - 1/18/09) Base Fee.....................................0.75% DB Fee......................................0.25% IE Benefit Fee............................0.15% Joint Life (1/19/09 - 11/3/13) Base Fee.....................................0.90% DB Fee......................................0.20% IE Benefit Fee............................0.30% (11/10/08 - 1/18/09) Base Fee.....................................0.75% DB Fee......................................0.20% IE Benefit Fee............................0.30%	groups and the optional benefits selected. If You elect a combination of designated allocations from among the various groups below, then Your fee will be based on a weighted average of Your choices. Base Benefit Fees (2/21/11 - 11/3/13) Group A....................................1.40% Group B....................................1.00% Group C....................................0.45% Additional option fees would be added to the base and are as follows: DB Single Life...........................0.25% DB Joint Life.............................0.20% IE Single Life.............................0.15% IE Joint Life..............................0.30% Base Benefit Fees (9/21/09 - 2/2011) Group A....................................1.25% Group B....................................0.90% Group C....................................0.40% Additional option fees would be added to the base and are as follows: DB Single Life...........................0.25% DB Joint Life.............................0.20% IE Single Life.............................0.15% IE Joint Life..............................0.30%
Fee Frequency	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. • Deducted at each rider quarterversary in arrears during the accumulation phase. • The fee is calculated on a quarterly basis and varies depending on the fund allocation option You have chosen. • A “rider fee adjustment” will be applied for transfers between allocation groups and for subsequent premium payments and withdrawals that change the withdrawal base. • 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. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal

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Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
	to the excess, if any, of the RDB over the base Policy death benefit and then this rider will terminate. The RDB does not reset due to the automatic step-up feature.	to the excess, if any, of the RDB over the base Policy death benefit and then this rider will terminate. The RDB does not reset due to the automatic step-up feature.	to the excess, if any, of the RDB over the base Policy death benefit and then this rider will terminate. The RDB does not reset due to the automatic step-up feature.
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated fund based on rider issue date. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Portfolio Companies Available Under the Policy Appendix in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.	AB Balanced Hedged Allocation Portfolio American Funds - Asset Allocation Fund American Funds - The Bond Fund of America^SM Fidelity VIP Balanced Portfolio Franklin Templeton VIP Founding Funds Allocation Fund State Street Total Return V.I.S. Fund TA 60/40 Allocation TA Aegon U.S. Government Securities TA American Funds Managed Risk – Balanced TA BlackRock Government Money Market TA BlackRock Global Allocation TA BlackRock iShares Active Asset Allocation - Conservative TA BlackRock iShares Active Asset Allocation – Moderate Growth TA BlackRock iShares Active Asset Allocation - Moderate TA BlackRock iShares Dynamic Allocation – Balanced TA BlackRock iShares Dynamic Allocation – Growth TA BlackRock iShares Edge 40 TA BlackRock iShares Edge 50 TA BlackRock iShares Edge 75 TA BlackRock Tactical Allocation TA Janus Balanced TA JPMorgan Asset Allocation - Conservative TA JPMorgan Asset Allocation - Moderate Growth TA JPMorgan Asset Allocation - Moderate TA JPMorgan Core Bond TA JPMorgan International Moderate Growth TA JPMorgan Tactical Allocation TA Madison Diversified Income TA Managed Risk – Balanced ETF TA Managed Risk – Conservative ETF TA Managed Risk – Growth ETF TA Market Participation Strategy TA Morgan Stanley Global Allocation Managed Risk – Balanced TA Multi-Managed Balanced TA PIMCO Tactical – Balanced TA PIMCO Tactical – Conservative TA PIMCO Tactical – Growth TA PIMCO Total Return TA PineBridge Inflation Opportunities Fixed Account GPOs or DCA Accounts	AB Balanced Hedged Allocation Portfolio American Funds - Asset Allocation Fund American Funds - The Bond Fund of America^SM Fidelity VIP Balanced Portfolio Franklin Templeton VIP Founding Funds Allocation Fund State Street Total Return V.I.S. Fund TA 60/40 Allocation TA Aegon U.S. Government Securities TA American Funds Managed Risk – Balanced TA BlackRock Global Allocation TA BlackRock Government Money Market TA BlackRock iShares Active Asset Allocation - Conservative TA BlackRock iShares Active Asset Allocation – Moderate Growth TA BlackRock iShares Active Asset Allocation - Moderate TA BlackRock iShares Dynamic Allocation – Balanced TA BlackRock iShares Dynamic Allocation – Growth TA BlackRock iShares Edge 40 TA BlackRock iShares Edge 50 TA BlackRock iShares Edge 75 TA BlackRock Tactical Allocation TA Janus Balanced TA JPMorgan Asset Allocation - Conservative TA JPMorgan Asset Allocation - Moderate Growth TA JPMorgan Asset Allocation - Moderate TA JPMorgan Core Bond TA JPMorgan International Moderate Growth TA JPMorgan Tactical Allocation TA Madison Diversified Income TA Managed Risk – Balanced ETF TA Managed Risk – Conservative ETF TA Managed Risk – Growth ETF TA Market Participation Strategy TA Morgan Stanley Global Allocation Managed Risk – Balanced TA Multi-Managed Balanced TA PIMCO Tactical – Balanced TA PIMCO Tactical – Conservative TA PIMCO Tactical – Growth TA PIMCO Total Return TA PineBridge Inflation Opportunities Fixed Account GPOs or DCA Accounts	Designated Allocation Group A AB Balanced Hedged Allocation Portfolio American Funds - Asset Allocation Fund Fidelity VIP Balanced Portfolio Franklin Templeton VIP Founding Funds Allocation Fund State Street Total Return V.I.S. Fund TA 60/40 Allocation TA BlackRock Global Allocation TA BlackRock iShares Active Asset Allocation – Moderate Growth TA BlackRock iShares Dynamic Allocation – Growth TA BlackRock iShares Edge 75 TA Janus Balanced TA JPMorgan Asset Allocation - Moderate Growth TA JPMorgan International Moderate Growth TA Managed Risk – Growth ETF TA Multi-Managed Balanced TA PIMCO Tactical – Growth Designated Allocation Group B TA American Funds Managed Risk - Balanced TA BlackRock iShares Active Asset Allocation - Moderate TA BlackRock iShares Dynamic Allocation – Balanced TA BlackRock iShares Edge 50 TA BlackRock Tactical Allocation TA JPMorgan Asset Allocation – Moderate TA Madison Diversified Income TA Managed Risk – Balanced ETF TA Market Participation Strategy TA Morgan Stanley Global Allocation Managed Risk - Balanced TA PIMCO Tactical – Balanced Designated Allocation Group C American Funds - The Bond Fund of America^SM TA Aegon U.S. Government Securities TA BlackRock Government Money Market TA BlackRock iShares Active Asset Allocation - Conservative TA BlackRock iShares Edge 40 TA JPMorgan Asset Allocation - Conservative TA JPMorgan Core Bond TA JPMorgan Tactical Allocation TA Managed Risk – Conservative ETF TA PIMCO Tactical – Conservative TA PIMCO Total Return TA PineBridge Inflation Opportunities Fixed Account
Allocation Methods	N/A	N/A	N/A
Withdrawal Benefits - See	The percentage is determined by the	The percentage is determined by the	The percentage (after 2/1/2010) is

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Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
Hypothetical Adjusted Partial Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders Appendix for examples showing the effect of withdrawals on the WB.	attained age of the Annuitant² at the time of the first withdrawal. Age 1st WDFor Life WD% 0-58....................................0.0% 59-69..................................5.0% 70-79..................................6.0% 80+......................................7.0% • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) the RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	attained age of the Annuitant² at the time of the first withdrawal. Age 1st WDSingle Life WD% 0-58....................................0.0% 59-69..................................5.0% 70-79..................................6.0% 80+......................................7.0% Age 1st WDJoint Life WD% 0-58....................................0.0% 59-69..................................4.5% 70-79..................................5.5% 80+ .....................................6.5% • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	determined by the attained age of the Annuitant² at the time of the first withdrawal. Age 1st WDSingle Life WD% 0 - 58..................................0.0% 59-64..................................4.0% 65-74..................................5.0% 75 + ....................................6.0% Age 1st WDJoint Life WD% 0 - 58..................................0.0% 59-64..................................3.5% 65-74..................................4.5% 75 + ....................................5.5% NOTE: Prior to 2/1/2010 the age bands regarding the withdrawal percentages above were as follows: 0-58 59-69 70-79 80+ • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.
Automatic Step-Up Benefit	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 rider years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5^th rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing.	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 rider years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5^th rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing.	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5^th rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee. Must be in writing.

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Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
	• If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups.	• If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups.	• If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The benefit percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.
Exercising Rider	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each calendar year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This optional feature may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the greater of the base Policy death benefit or any GMDB. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each calendar year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This optional feature may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the greater of the base Policy death benefit or any GMDB. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This optional feature may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the greater of the base Policy death benefit or any GMDB. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.
Income Benefit or Other Benefit Payout Considerations	Growth: Benefit is not elected separately but is built into the rider. The WB will grow at 5% growth annually. This will only be credited on the rider anniversary for up to 10 rider years. If a withdrawal has occurred in the current rider year the 5% growth will not be applied. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	Growth: Benefit is not elected separately but is built into the rider. The WB will grow at 5% growth annually. This will only be credited on the rider anniversary for up to 10 rider years. If a withdrawal has occurred in the current rider year the 5% growth will not be applied. Double Withdrawal Base Feature: If no withdrawals have been made within the first 10 rider years or the anniversary following attained age 67, the WB on that rider anniversary will be the greater of; 1) the current WB; or 2) premiums applied within 90 days of the rider date multiplied by 2. NOTE: There is not an adjustment or credit for partial years of interest.	Growth: Benefit is not elected separately but is built into the rider. The WB will grow at 5% growth annually. This will only be credited on the rider anniversary for up to 10 rider years. If a withdrawal has occurred in the current rider year the 5% growth will not be applied. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.

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Rider Name	Retirement Income Choice^®	Retirement Income Choice^® with Double Withdrawal Base Benefit³	Retirement Income Choice^® 1.4³
Rider Form Number¹	RGMB 27 0108 (w/o IE) RGMB 29 0108 (with IE)	RGMB 31 0708 (w/o IE) RGMB 33 0708 (with IE)	RGMB 37 0809 (w/o IE) RGMB 38 0809 (with IE)
		Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.
Rider Upgrade	• Upgrades allowed within a 30 day window following each successive 5^th rider anniversary. • Rider availability and fees may vary at time of upgrade. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 85 years old. • An upgrade will reset the WB, RDB, RWA and Income Benefit determination. • Rider Fee Percentage will be the fee percentage that applies to the new rider at the time of upgrade. • Growth percentage will be the percentage available at the time of upgrade.	• Upgrades allowed within a 30 day window following each successive 5^th rider anniversary. • Rider availability and fees may vary at time of upgrade. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 85 years old. • An upgrade will reset the WB, RDB, RWA and Income Benefit determination. • Rider Fee Percentage will be the fee percentage that applies to the new rider at the time of upgrade. • Growth percentage will be the percentage available at the time of upgrade.	• Upgrades allowed within a 30 day window following each successive 5^th rider anniversary. • Rider availability and fees may vary at time of upgrade. • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 85 years old. • An upgrade will reset the WB and RDB. • Rider Fee Percentage will be the fee percentage that applies to the new rider at the time of upgrade. • Growth percentage will be the percentage available at the time of upgrade.
Rider Termination	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • After termination, there is no wait period to re-add the rider, assuming the rider is still being offered. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • After termination, there is no wait period to re-add the rider, assuming the rider is still being offered. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • After termination, there is no wait period to re-add the rider, assuming the rider is still being offered. • The rider will be terminated the date we receive Written Notice from You requesting termination.

Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
Purpose of Rider	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees tiered withdrawals for the Annuitant's² lifetime. • The policyholder can withdraw (required to use systematic withdrawals) the RWA each rider year until the death of the Annuitant². • This benefit is intended to provide a level of tiered payments regardless of the performance of the designated variable Investment Option You select.
Availability	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant).	• Issue age 55-80, but not yet 81 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant).

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Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
	• Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Fee based on designated allocation groups and the optional benefits selected. If You elect a combination of designated allocations from among the various groups below, then Your fee will be based on a weighted average of Your choices. Base Benefit Fees (12/12/11 - 11/3/13) OAM Option.................................................1.25% Group A.........................................................1.55% Group B.........................................................1.10% Group C.........................................................0.70% Additional option fees would be added to the base and are as follows: DB Single Life................................................0.25% DB Joint Life..................................................0.20% IE Single Life..................................................0.30% IE Joint Life....................................................0.50% Base Benefit Fees (2/21/11 - 12/12/11): OAM Option.................................................1.20% Group A.........................................................1.40% Group B.........................................................1.00% Group C.........................................................0.45% Additional option fees would be added to the base and are as follows: DB Single Life................................................0.25% DB Joint Life..................................................0.20% IE Single Life..................................................0.15% IE Joint Life....................................................0.30% Base Benefit Fees (5/1/09 - 2/20/11): OAM Option.................................................1.10% Group A.........................................................1.25% Group B.........................................................0.90% Group C.........................................................0.40% Additional option fees would be added to the base and are as follows: DB Single Life................................................0.25% DB Joint Life..................................................0.20% IE Single Life..................................................0.15% IE Joint Life....................................................0.30%	Percentage of WB - 0.90% for Single and Joint Life Riders (prior to 11/3/2013)
Fee Frequency	• The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. • Deducted at each rider quarterversary in arrears during the accumulation phase. • The fee is calculated on a quarterly basis and varies depending on the fund allocation option You have chosen. • A “rider fee adjustment” will be applied for transfers between allocation groups and for subsequent premium payments and withdrawals that change the withdrawal base. • The base rider fee adjustment will be calculated using the same formula as the base rider fee.	• The fee is calculated at issue and each subsequent calendar rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. • Deducted at each rider quarterversary in arrears during the accumulation phase. • The fee is adjusted for new deposits that increase the WB and decreased for withdrawals that are not ILSW or RMD systematic withdrawals. • The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. • A pro-rated fee is assessed at the time of rider termination or full surrender.

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Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
	• The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the base Policy death benefit and then this rider will terminate. The RDB does not reset due to the automatic step-up feature.	N/A
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as designated fund based on rider issue date. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Portfolio Companies Available Under the Policy Appendix in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.	Designated Allocation Group A AB Balanced Hedged Allocation Portfolio American Funds - Asset Allocation Fund Fidelity VIP Balanced Portfolio Franklin Templeton VIP Founding Funds Allocation Fund State Street Total Return V.I.S. Fund TA 60/40 Allocation TA BlackRock Global Allocation TA BlackRock iShares Active Asset Allocation – Moderate Growth TA BlackRock iShares Dynamic Allocation - Growth TA BlackRock iShares Edge 75 TA Janus Balanced TA JPMorgan Asset Allocation - Moderate Growth TA JPMorgan International Moderate Growth TA Managed Risk – Growth ETF TA Multi-Managed Balanced TA PIMCO Tactical - Growth Designated Allocation Group B TA American Funds Managed Risk - Balanced TA BlackRock iShares Active Asset Allocation – Moderate TA BlackRock iShares Dynamic Allocation - Balanced TA BlackRock iShares Edge 50 TA BlackRock Tactical Allocation TA JPMorgan Asset Allocation - Moderate TA Madison Diversified Income TA Managed Risk – Balanced ETF TA Market Participation Strategy TA Morgan Stanley Global Allocation Managed Risk - Balanced TA PIMCO Tactical - Balanced Designated Allocation Group C American Funds - The Bond Fund of America^SM TA Aegon US Government Securities TA BlackRock Government Money Market TA BlackRock iShares Active Asset Allocation - Conservative TA BlackRock iShares Edge 40 TA JPMorgan Asset Allocation - Conservative TA JPMorgan Core Bond TA JPMorgan Tactical Allocation TA Managed Risk – Conservative ETF TA PIMCO Tactical - Conservative TA PIMCO Total Return TA PineBridge Inflation Opportunities Fixed Account	American Funds - The Bond Fund of America^SM TA Aegon U.S. Government Securities TA BlackRock Government Money Market TA BlackRock iShares Active Asset Allocation - Conservative TA BlackRock iShares Edge 40 TA JPMorgan Asset Allocation - Conservative TA JP Morgan Core Bond TA JP Morgan Tactical Allocation TA Managed Risk – Conservative ETF TA PineBridge Inflation Opportunities TA PIMCO Tactical Conservative TA PIMCO Total Return Fixed Account
Allocation Methods	Open Allocation Method (OAM):	N/A

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Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
	• This program will automatically allocate assets from the policyholder's Separate Accounts to a Subaccount of our choosing when the Policy Value has dropped relative to the guaranteed amount. • If the Policy Value increases enough in relation to the guaranteed amounts, the money will be moved back into the Separate Accounts (pro-rata based on the policy holder's current Separate Account values). • The allocation of assets between the accounts is at our sole discretion but will initially use modern financial theory to determine the correct allocation. • The policyholder may not allocate premium payments to, nor transfer Policy Value into or out of the OAM Investment Options. Current OA Subaccount: TA ProFund UltraBear
Withdrawal Benefits - See Hypothetical Adjusted Partial Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders and Guaranteed Lifetime Withdrawal Benefit Adjusted Withdrawals - Income Link appendices for examples showing the effect of withdrawals on the WB.	The percentage (after 12/12/2011) is determined by the attained age of the Annuitant² at the time of the first withdrawal. Age 1st WDSingle Life WD% 0 - 58........................................................0.0% 59-64........................................................4.0% 65-79........................................................5.0% 80 + .........................................................6.0% Age 1st WDJoint Life WD% 0 - 58........................................................0.0% 59-64........................................................3.5% 65-79........................................................4.5% 80 + .........................................................5.5% NOTE: Prior to 2/1/2010 the age bands regarding the withdrawal percentages above were as follows: 0-58 59-69 70-79 80+ –After 2/1/2010 and prior to 12/12/2011 the age bands regarding the withdrawal percentages above were as follows: 0-58 59-64 65-74 75+ • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	Withdrawal Option Election Date - This is the date the withdrawal option is selected by the Policy Owner. ILSD - This is the date the Policy Owner elects to begin receiving payments. ILWY - This is each 12-month period beginning on the ILSD and establishes the time period for withdrawing Your RWA and is reset at the beginning of each withdrawal year. ILSW - There are 4 systematic payment options specific to this rider. Any withdrawal that is not an ILSW will be considered an excess withdrawal. The withdrawal percentage is used to calculate the RWA and is determined by electing a withdrawal option, which is not required to elect at the time of issue. Once selected, the ILSWs are not required to begin immediately. Your withdrawal option is not locked in until the ILSD and the percentage is not recalculated at the time of an automatic step-up. Withdrawal options are as listed below: Single Life 5% for 7 years and 4% thereafter 6% for 6 years and 4% thereafter 7% for 5 years and 4% thereafter 8% for 4 years and 4% thereafter 9% for 3 years and 4% thereafter 10% for 2 years and 4% thereafter Joint Life 4.5% for 7 years and 3.5% thereafter 5.5% for 6 years and 3.5% thereafter 6.5% for 5 years and 3.5% thereafter 7.5% for 4 years and 3.5% thereafter 8.5% for 3 years and 3.5% thereafter 9.5% for 2 years and 3.5% thereafter On each ILSD and the beginning of each ILWY thereafter, the RWA is equal to the withdrawal option percentage multiplied by the withdrawal base.
Automatic Step-Up Benefit	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage*	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; or 3) The highest Policy Value on a rider monthiversary^SMfor the current rider year* * Item 3) is set to zero if there have been any withdrawals that are not ILSW or RMD systematic withdrawals in the current rider year. The highest

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Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
	* Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10 years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5^th rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee. - Must be in writing. • If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The benefit percentage will also increase if You have crossed into another age band prior to an automatic step-ups after the election date.	monthly value is the largest Policy Value on each rider monthiversary during the rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee. -Must be in writing. • If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups.
Exercising Rider	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This optional feature may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the greater of the base Policy death benefit or any GMDB. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each withdrawal year even if the Policy Value is zero at the time of withdrawal. The rider benefits cease when the Annuitant² has died.
Income Benefit or Other Benefit Payout Considerations	Growth: Benefit is not elected separately but is built into the rider. The WB will grow at 5% growth annually. This will only be credited on the rider anniversary for up to 10 rider years. If a withdrawal has occurred in the current rider year the 5% growth will not be applied. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	Systematic Withdrawal Options: 1. 72t/72q SPO - This allows fixed level payments that will not change for at least 5 years and payments will not exceed RWA. Only 5, 6 and 7 year options available. 2. RMD Only SPO - This allows a modal amount equal to the annual RMD requirement for the current calendar year less all withdrawals taken in current calendar year divided by the number of payments remaining in the calendar year. Will not reduce RWA and is only available prior to ILSD. 3. RWA SPO no RMD kick out - Allows modal payments of the remaining RWA divided by the number of payments remaining in the current withdrawal year. Payments will be adjusted for any step-ups, premium additions or excess withdrawals and will reduce the RWA with each

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Rider Name	Retirement Income Choice^® 1.2³	Income Link^SM3
Rider Form Number¹	RGMB 35 0109 (w/o IE) RGMB 36 0109 (with IE)	RGMB 39 0110
		payment. 4. RWA SPO with RMD kick out - This allows for payments equal to #3 above with an additional payment to satisfy the RMD paid on December 27^th each calendar year. Modal payments are not affected by this RMD payment.
Rider Upgrade	• Upgrades allowed within a 30-day window following each successive 5^th rider anniversary. • Rider availability and fees may vary at time of upgrade • Upgrades are subject to issue age restrictions of the rider at the time of upgrade. Currently the maximum upgrade age is 85 years old. • An upgrade will reset the WB and RDB. • Rider Fee Percentage will be the fee percentage that applies to the new rider at the time of upgrade. • Growth percentage will be the percentage available at the time of upgrade.	• No upgrades allowed, however the Owner may terminate the existing rider any time after the 5^th rider anniversary and add the new rider in place at that time, as long as the covered lives meet the age requirements in effect at that time. • New rider addition will be subject to issue age restrictions of the rider at the time of termination and re-addition. Currently the maximum age is 80 years old. • Rider availability and fees are subject to what applies to the new rider being added.
Rider Termination	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • The rider will be terminated the date we receive Written Notice from You requesting termination. • After termination, there is no wait period to re-add the rider, assuming the rider is still being offered.	• The rider will be terminated upon Policy surrender, Annuitization or Annuitant² death. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed at any time after the 5^th rider anniversary. • The rider will be terminated the date we receive Written Notice from You requesting termination. • After termination, there is no wait period to re-add the rider, assuming the rider is still available.

Rider Name	Additional Death Distribution 2003	Additional Death Distribution +
Rider Form Number¹	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513
Purpose of Rider	This is an Additional Death Benefit Rider which can pay an additional benefit at time of death to help alleviate the burden of taxes.	This is an Additional Death Benefit Rider which can pay an additional benefit at time of death to help alleviate the burden of taxes.
Availability	• Issue age 0-75 but not yet 76 years old (Policy application signed on or after May 1, 2020). • Issue age 0-80 but not yet 81 years old (policy application signed prior to May 1, 2020). • Not available in all states. • Can be added at any time including post issue.	• Issue age 0-69 but not yet 70 years old (Policy application signed on or after May 1, 2020). • Issue age 0-75 but not yet 76 years old (Policy application signed prior to May 1, 2020). • Not available in all states. • Can be added at any time including post issue.
Base Benefit and Optional Fees at issue	Percentage of Policy Value – 0.25%	Percentage of Policy Value – 0.55%
Fee Frequency	Assessed each rider anniversary and at rider termination and equal to the Policy Value multiplied by rider fee percentage.	Assessed each rider anniversary and at rider termination and equal to the Policy Value multiplied by rider fee percentage.
Death Benefit	Amount is paid whenever a death benefit is paid and the rider is attached. • Amount paid=ADB Factor x Rider Earnings*	Amount is paid whenever a death benefit is paid and the rider is attached. • Prior to 5^th rider anniversary = Sum of all fees paid for this rider since the rider date.

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Rider Name	Additional Death Distribution 2003	Additional Death Distribution +
Rider Form Number¹	RTP 18 0103 ICC12 RTP 170513	RTP 17 0103 ICC12 RTP 180513
	• ADB Factor - 40% for issue ages 0-70 and 25% for issue ages 71-80 (when application signed date is prior to May 1, 2020). • ADB Factor - 40% for issue ages 0-70 and 25% for issue ages 71-75 (when application signed date is after May 1, 2020). *Rider earnings are defined as: - 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. NOTE: No benefit is payable under the ADD rider if there are no rider earnings on the date the death benefit is calculated.	• On or after 5^th rider anniversary = Rider Benefit Base* x Rider Benefit Percentage. The rider benefit percentage = 30% for issue ages 0-70 and 20% for issue ages 71-75 (when application signed date is prior to May 1, 2020). *The rider benefit percentage = 30% for issue ages 0-69 (when application signed date is after May 1, 2020). The Rider Benefit Base at any time is equal to the Policy Value less any premiums added after the Rider Date NOTE: No benefit is payable under the ADD+ rider if the Policy Value on the date the death benefit is paid is less than the premium payments after the rider date.
Investment Restrictions and/or Designated Funds Available	N/A	N/A
Withdrawal Benefits	N/A	N/A
Automatic Step-Up Benefit	N/A	N/A
Exercising Rider	No further action required to exercise the rider.	No further action required to exercise the rider.
Income Benefit or Other Benefit Payout Considerations	N/A	N/A
Rider Upgrade	N/A	N/A
Rider Termination	The rider can be added or dropped at any time. If the rider is dropped and re-added, the rider will only cover earnings accumulated since the rider was re-added. The rider will remain in effect until: • You cancel it by notifying our Administrative Office in writing, • the Policy is Annuitized or surrendered, • or the additional death benefit is paid.	The rider can be added or dropped at any time. If the rider is terminated they must wait one year to re-add rider. The rider will remain in effect until: • You cancel it by notifying our Administrative Office in writing, • the Policy is Annuitized or surrendered, • or the additional death benefit is paid.

Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
Purpose of Rider	Also known as Guaranteed Principal Solutions (GPS) rider, this is a Living Benefit Rider and should be viewed as a way to permit you to invest in variable Investment Options while still having your Policy Value and liquidity protected to the extent provided by this rider. This rider is a combination of two separate annuity guarantees: 1) A GMWB and 2) A GMAB (a.k.a. principal protection benefit or guarantee future value benefit). The rider will guarantee that the Policy Value of the Policy will be at least as high as the GFV after a waiting period has expired.	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.	This is a GLWB rider that guarantees withdrawals for the Annuitant's² lifetime, regardless of Policy Value. • The policyholder can withdraw the RWA each rider year until the death of the Annuitant.² • This benefit is intended to provide a level of payments regardless of the performance of the designated variable Investment Options You select.

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Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
Availability	• Issue age 0-80, but not yet 81 years old (unless state law requires a lower maximum issue age). • • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.	• Issue age 0-85, but not yet 86 years old (unless state law requires a lower maximum issue age). • Single Annuitant ONLY. Annuitant must be an Owner (unless Owner is a non-natural person). • Maximum of 2 living Joint Owners (with one being the Annuitant). • Cannot be added to a Policy with other active GMLB or GMIB riders. • Cannot be added on policies with Growth or Double Enhanced Death Benefits. • Not available on qualified annuity which has been continued by surviving spouse or beneficiary as a new Owner.
Base Benefit and Optional Fees at issue	Percentage of “Principal Back” TWB - 1.25%	You may contact us at www.transamerica.com for the current Rate Sheet Supplement applicable for this rider. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.	Fee based on designated allocation groups and the optional benefits selected. If You elect a combination of designated allocations from among the various groups below, then your fee will be based on a weighted average of Your choices. You may contact us at www.transamerica.com for the current Rate Sheet Supplement applicable for this rider. For riders issued prior to the date of this prospectus, please reference the “Appendix – Prior Withdrawal/Growth Percentages and Rider Fees” in the Statement of Additional Information.
Fee Frequency	• Fee is deducted annually during the accumulation phase on each rider anniversary. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. • Deducted at each rider quarterversary in arrears during the accumulation phase. • The fee is calculated on a quarterly basis. • A rider fee adjustment will be applied for subsequent premium payments and withdrawals that change the withdrawal base. • The base rider fee adjustment will be calculated using the same formula as the base rider fee. • The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated. • A pro-rated fee is deducted at the time the rider is terminated or upgraded.	• The fee is calculated at issue and each subsequent rider quarter for the upcoming quarter based on the fund values and WB at that point in time and stored. • Deducted at each rider quarterversary in arrears during the accumulation phase. • The fee is calculated on a quarterly basis and varies depending on the fund allocation option You have chosen. • A rider fee adjustment will be applied for transfers between allocation groups and for subsequent premium payments and withdrawals that change the withdrawal base. • The base rider fee adjustment will be calculated using the same formula as the base rider fee. • The rider fee adjustment may be positive or negative and will be added to or subtracted from the rider fee to be allocated.

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Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
			• A pro-rated fee is deducted at the time the rider is terminated or upgraded.
Death Benefit	N/A	N/A	For an additional fee, the optional death benefit may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the base Policy death benefit and then this rider will terminate. The RDB does not reset due to the automatic step-up feature.
Designated Investment Options Available - Policyholders who add these riders may only invest in the Investment Options listed. Investment Options may not be available as a designated fund based on rider issue date. Requiring that You designate 100% of Your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit. PLEASE NOTE: These Investment Options may not be available on all products, may vary for certain policies and may not be available for all policies. Please reference Appendix - Portfolio Companies Available Under the Policy in Your prospectus for available Portfolio Companies. You cannot transfer any amount to any other non-designated Subaccount without losing all Your benefits under this rider.	All funds within the product are considered designated funds for this purpose. You must, however, adhere to the Portfolio Allocation Method. See below.	For a list of designated funds for this rider, please reference the Appendix - Designated Investment Options.	For a list of designated funds for this rider, please reference the Appendix - Designated Investment Options.
Allocation Methods	Portfolio Allocation Method (PAM): • This program will automatically allocate assets from the policyholder's Separate Accounts to a Subaccount of our choosing when the Policy Value has dropped relative to the guaranteed amount. • If the Policy Value increases enough in relation to the guaranteed amounts, the money may be moved back into the Subaccounts (pro-rata based on the policyholder's current Subaccount values). • The allocation of assets between the accounts is at our sole discretion but will initially use modern financial theory to determine the correct allocation. • The policyholder may not allocate premium payments to, nor transfer Policy Value into or out of, the PAM	N/A	N/A

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Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
	Investment Options. Current PAM Subaccount: TA Aegon U.S. Government Securities
Withdrawal Benefits - See Hypothetical Adjusted Partial Withdrawals - Guaranteed Lifetime Withdrawal Benefit Riders and Living Benefit Rider Adjusted Partial Withdrawals appendices for examples showing the effect of withdrawals on the WB.	The GMWB guarantees a withdrawal amount regardless of the Policy Value. The policyholder has 2 withdrawal guarantees available. Once the rider is issued, values for both withdrawal guarantees will be calculated indefinitely as follows: a) 7% Principal Back: The policyholder can withdraw up to 7% of the 7% Principal Back TWB per year until at least the time at which the 7% Principal Back MRWA has reached zero. b) 5% For Life: The policyholder can withdraw up to 5% of the 5% For Life TWB each year starting with the Rider Anniversary following the Annuitant's 59^th birthday until at least the later of the death of the Annuitant or the time when the 5% For Life MRWA* has reached zero. * The MRWA represents the total minimum dollar amount of guaranteed withdrawals the policyholder has remaining provided they take no more than the MAWA each year. • The policyholder does not have to take the entire MAWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next calendar year.	The percentage is determined by the attained age of the Annuitant² at the time of the first withdrawal. Please see the Prior Withdrawal and Growth Percentages Appendix in the Statement of Additional Information for Your applicable Withdrawal Percentage. • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.	The percentage is determined by the attained age of the Annuitant² at the time of the first withdrawal. Please see the Prior Withdrawal and Growth Percentages Appendix in the Statement of Additional Information for Your applicable Withdrawal Percentage for riders issued after May 1, 2016. Single Life Riders Issued prior to and after 5/1/14 Age 1st WDSingle Life WD% 0 - 58..................................0.0% 59-64..................................4.0% 65-79..................................5.0% 80 + ....................................6.0% Joint Life Riders Issued on or after 5/1/14 Age 1st WDJoint Life WD% 0 - 58..................................0.0% 59-64................................3.75% 65-79................................4.75% 80 + ..................................5.75% Issued prior to 5/1/14 0 - 58..................................0.0% 59-64..................................3.5% 65-79..................................4.5% 80 + ....................................5.5% • Starting the rider anniversary following the Annuitant's² 59^th birthday, the withdrawal percentage increases above 0% which creates a RWA available under the rider for withdrawal. • On each rider anniversary, the RWA will be reset equal to the greater of: 1) The WB multiplied by the Withdrawal Percentage based on the attained age of the Annuitant² at the time of their first withdrawal if applicable, and 2) The RMD amount for this Policy for the current calendar year. • The policyholder does not have to take the entire RWA in any year. • If they do not take the full amount available, the remaining portion does not carry over to the next rider year.
Automatic Step-Up Benefit	N/A	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10	On each rider anniversary, the WB will be set to the greatest of: 1) The current WB: 2) The Policy Value on the rider anniversary; 3) The highest Policy Value on a rider monthiversary^SM; or 4) The current WB immediately prior to anniversary processing increased by the growth rate percentage* * Item 3) is set to zero if there have been any excess withdrawals in the current rider year. ** Item 4) is set to zero after the first 10

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Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
		years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 1^st rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. • If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The withdrawal percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.	years or if there have been any withdrawals in the current rider year. A step-up will occur if the largest value is either 2) or 3) above. A step-up will allow us to change the rider fee percentage after the 5^th rider anniversary. • If the largest value is 1) or 4) above, this is not considered a step-up. • Owner will have a 30 day window after the rider anniversary to reject an automatic step-up if we increase the rider fee.—Must be in writing. • If an Owner rejects an automatic step-up, they retain the right to all future automatic step-ups. NOTE: The withdrawal percentage will also increase if You have crossed into another age band prior to an automatic step-up after the election date.
Exercising Rider	For Life GMWB: The policyholder is guaranteed to be able to withdraw up to the For Life MAWA until the later of 1) the Annuitant's death or 2) the For Life MRWA is zero. Principal Back GMWB: The policyholder is guaranteed to be able to withdraw up to the Principal Back MAWA until the Principal Back MRWA is zero. GMAB: At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, the GMAB feature will add the difference to the Policy Value on a pro-rata basis based on their current account value. a) The addition to the Policy will not be considered premium and should not affect any other Policy calculations, including the GMDB calculations. b) At the end of the waiting period, the GMAB will not provide any more benefits, unless the policyholder chooses to upgrade the rider.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant² has died.	Exercising Base Benefit: The policyholder is guaranteed to be able to withdraw up to the RWA each rider year if the Policy Value does not reach zero as a result of an excess withdrawal. The rider benefits cease when the Annuitant² has died. Exercising Death Option: This optional feature may be elected with this rider. Upon the death of an Annuitant², this rider will pay an additional death benefit amount equal to the excess, if any, of the RDB over the greater of the base Policy death benefit or any GMDB. Exercising the Income Enhancement Option: If qualifications are met, this optional feature doubles the income benefit percentage until the Annuitant² is no longer confined (either has left the facility or deceased). Qualifications: –Confinement must be due to a medical necessity due to physical or cognitive ailment. –Must be the Annuitant² who is confined. –Waiting period of 1 year from the rider date before the increase in the income benefit percentage is applicable. –Elimination period is 180 days within the last 12 months which can be satisfied during the waiting period. –Proof of confinement is required. This may be a statement from a Physician or a hospital or nursing facility administrator. –Qualification standards can be met again on the Annuitant's² life.
Income Benefit or Other Benefit Payout Considerations	The GFV is the Policy Value we are guaranteeing on the GFV date. After the Rider Issue Date, the GFV is equal to the GFV on the Rider Issue Date, plus a percentage of premiums (not including premium enhancements)	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if	Growth: Benefit is not elected separately but is built into the rider. The WB will grow annually. This will only be credited on the rider anniversary for up to 10 rider years. This is not added on top of a step-up if

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Rider Name	Living Benefit Rider (2005)³	Retirement Income Max^®³	Retirement Income Choice^® 1.6³
Rider Form Number¹	RGMB 4 0504	RGMB 41 0513	RGMB 37 0809 - (w/o IE) RGMB 38 0809 - (with IE)
	received after the Rider Date as shown in the table below, less an adjustment for withdrawals. Year Rec'd% Added to GFV 1.........................................100% 2...........................................90% 3...........................................80% 4...........................................70% 5...........................................60% 6-10.....................................50% 10+.........................................0% At the end of the GMAB waiting period (currently 10 years), should the Policy Value be less than the GFV, we will add the difference to the Policy Value on a pro-rata basis based on their current Policy Value.	applicable. If a withdrawal has occurred in the current rider year growth will not be applied. Please see the Prior Withdrawal and Growth Percentages Appendix in the Statement of Additional Information for Your applicable Growth Percentage. NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.	applicable. If a withdrawal has occurred in the current rider year growth will not be applied. For riders issued on or after May 1, 2014................................5.5% For riders issued prior to May 1, 2014................................5.0% NOTE: There is not an adjustment or credit for partial years of interest. Growth is not accumulated daily. Only calculated at the end of the year if no withdrawals were taken.
Rider Upgrade	Since this rider is no longer sold, upgrades are no longer available.	N/A	Since this rider is no longer sold, upgrades are no longer available.
Rider Termination	• The rider will be terminated upon Policy surrender, Annuitization or upgrade. • The policyholder must wait 3 years from the Rider Start Date to terminate. • After the three-year waiting period, the policyholder may terminate the rider at any time. • The rider will be terminated the date we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • The rider will be terminated the date an excess withdrawal reduces Your Policy Value to zero; or we receive Written Notice from You requesting termination.	• The rider will be terminated upon Policy surrender, Annuitization, Annuitant² death or upgrade. • The date the Policy to which this rider is attached is assigned or if the Owner is changed without our approval. • Termination allowed within 30 day window following each successive 5^th rider anniversary. • The rider will be terminated the date an excess withdrawal reduces Your Policy Value to zero; or we receive Written Notice from You requesting termination.

⁽¹⁾	Rider form number may be found on the bottom left corner of your rider pages.
⁽²⁾	If the rider's Joint Life option has been elected for an additional fee, the benefits and features available could differ from the Single Life Option based on the age of the Annuitant's spouse if younger.
⁽³⁾	This rider and additional options may vary for certain policies and may not be available for all policies. This disclosure explains the material features of the riders. The application and operation of the riders are governed by the terms and conditions of the rider itself.

ADDITIONAL FEATURES

Systematic Payout Option

You can select at any time (during the accumulation phase) to receive regular surrenders (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 surrenders made per year, where: (1) up to 10% of your premium payments (reduced by prior surrenders 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. The amount of Your payment is established when You select the option. The amount available is recalculated on each Policy anniversary thereafter while the Systematic Payout Option is in effect.

This amount may be taken free of surrender charges.

Any systematic withdrawal in excess of the remaining rider withdrawal amount could affect your rider values (if elected). Systematic surrenders can be made monthly, quarterly, semi-annually, or annually. Each surrender must be at least $40. Monthly and quarterly surrenders must generally be made by electronic funds transfer directly to Your checking or savings account.

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Any systematic withdrawal in excess of your remaining surrender charge free amount may be subject to a surrender charge. If the request does not exceed the surrender charge free amount, future systematic payments will be recalculated based on the remaining free amounts.

Keep in mind that surrenders under the systematic payout option may be taxable, and if made before age 59½, may be subject to a 10% federal penalty tax. There is no charge for this benefit.

Income Benefit Programs

The Family Income Protector and Managed Annuity Programs are no longer available, 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. See Optional Benefit Riders for Additional Information on each of these riders.

Initial Payment Guarantee

You may only elect to purchase the Initial Payment Guarantee which provides annually stabilized payments that are guaranteed to never be less than a percentage of the initial variable annuity payment 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 (i.e., Your payment is “net” the initial payment guarantee fee, mortality and expense risk fee, and administrative charges).

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.

The Initial Payment Guarantee may vary for certain policies and may not be available for all policies, in all states or at all times.

Liquidity Rider

The optional Liquidity Rider reduces the number of years each premium payment is subject to surrender charges. You can only elect this rider at the time You purchase the Policy.

The Liquidity Rider may vary for certain policies and may not be available for all policies, in all states, at all times or through all financial intermediaries. We may discontinue offering this benefit at any time for new sales, which includes new sales to existing policyowners. In some cases, a benefit not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a benefit, please contact Your financial intermediary or our Administrative Office.

Rider Fee. A rider fee equal to an effective annual rate of 0.50% of the daily net asset value in the Separate Account is deducted in calculating the Accumulation Unit values. The rider fee is only charged for the first four Policy Years.

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Accumulation Unit Values. We intend to administer the removal of the Liquidity Rider fee by changing to a different class of Accumulation Units. This will result in adjusting the number of Accumulation Units and adjusting the unit value of the Subaccounts in which You were invested once the Liquidity Rider fee is no longer charged. The elimination of the fee and the adjustment in the number of Accumulation Units and unit values will not affect Policy Values.

Termination. The rider is irrevocable.

Please note:

•	This feature terminates upon Annuitization and there is a mandatory Annuity Commencement Date.
•	We may credit interest in the Fixed Account at a lower rate if You select this rider.
•	The Liquidity Rider is not suitable for an investor purchasing the Policy for a long term investment.

Nursing Care and Terminal Condition Withdrawal Option

No surrender charges or Excess Interest Adjustments will apply if You take a withdrawal ($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).

You may exercise this benefit at any time during the accumulation phase. This benefit is also available to the Annuitant or Annuitant's spouse if the Owner is not a natural person. There is no restriction on the maximum amount You may withdraw under this benefit. There is no charge for this benefit.

The Nursing Care and Terminal Condition Withdrawal Option may vary for certain policies and may not be available for all policies, in all states or at all times.

Unemployment Waiver

No surrender charges or Excess Interest Adjustments will apply to surrenders after You or Your spouse become unemployed due to:

•	involuntary termination of employment
•	involuntary lay off;

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. This benefit is also available to the Annuitant or Annuitant's spouse if the Owner is not a natural person. There is no restriction on the maximum amount You may surrender under this benefit. There is no charge for this benefit.

The Unemployment Waiver may vary for certain policies and may not be available for all policies, in all states or at all times.

Telephone and Electronic Transactions

Currently, certain transactions may be made by telephone or other electronic means acceptable to us upon our receipt of the appropriate authorization. We may discontinue this option at any time. To access information and perform transactions electronically, we require You to create an account with a username and password, and to maintain a valid e-mail address.

We will not be liable for following instructions communicated by telephone or electronically we reasonably believe to be genuine. We will employ reasonable procedures to confirm that instructions we receive are genuine. Our procedures require You to provide information to verify Your identity when You call us and we will record conversations with You. We may also require written confirmation of the request. When someone contacts our Administrative Office and follows our procedures, we will assume You are authorizing us to act upon those instructions. For electronic transactions through the internet, You will need to provide Your username and password. You are responsible for keeping Your password confidential and must notify us of any loss, theft or unauthorized use of Your password.

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Telephone and other electronic transactions must be received in good order while the New York Stock Exchange is open for regular trading to get same-day pricing of the transaction. Transactions received in good order on non-Business Days or after our close of business on Business Days will get next-day pricing. SeeOTHER INFORMATION – Sending Forms and Transaction Requests in Good Order. Please note that the telephone and/or electronic device transactions may not always be available. Any telephone, fax machine or other electronic device, whether it is Yours, Your service provider's, or Your financial representative(s) can experience outages or slowdowns for a variety of reasons. These outages or slowdowns may delay or prevent our processing of Your request if the volume of transactions is unusually high, we might not have anyone available, or lines available, to take Your transaction. Although we have taken precautions to limit these problems, we cannot promise complete reliability under all circumstances. If You are experiencing problems, You should make Your request by writing to our Administrative Office.

We reserve the right to revoke Your telephone and other electronic transaction privileges at any time without revoking all Owners' privileges. We may deny telephone and electronic transaction privileges to market timers or disruptive traders.

Dollar Cost Averaging Program

During the accumulation phase, You may instruct us to automatically make transfers into one or more 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 Accumulation Units when prices are high, it does not guarantee profits or assure that You will not experience a loss.

Dollar Cost Averaging programs that may be 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. A minimum of $500 per transfer is required. 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 the Fixed Account, money market or other specified Subaccount.

•

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 Option into a Special Dollar Cost Averaging program. This program is only available for new premium payments, 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 ($3,000 or $6,000 to start a 6-month or 12-month program, respectively).

A Dollar Cost Averaging program will begin the next business day after we have received in good order all necessary information and the minimum required amount. SeeSending Forms and Transaction Requests in Good Order. 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:

New Dollar Cost Averaging instructions are required to start a new Dollar Cost Averaging program once the previous Dollar Cost Averaging program has completed. Additional premium payments, absent new allocation instructions, received after a Dollar Cost Averaging program has completed, will be allocated according to the current premium payment allocations at that time but will not reactivate a completed Dollar Cost Averaging program.

IF:

•	we do not receive all necessary information to begin or restart a Dollar Cost Averaging program;

THEN:

•	any amount allocated to a fixed source will be invested in that fixed source but will be transferred to the money market Investment Option within 30 days of allocation to fixed source if new Dollar Cost Averaging instructions are not received;
•	any amount in a variable source will be invested in that variable source and will remain in that variable Investment Option; and
•	new Dollar Cost Averaging instructions will be required to begin a Dollar Cost Averaging program.

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You should consider Your ability to continue a Dollar Cost Averaging program during all economic conditions. Transfers from a Dollar Cost Averaging fixed source are not subject to an Excess Interest Adjustment. A Dollar Cost Averaging program can be used in conjunction with Asset Rebalancing and a Guaranteed Lifetime Withdrawal Benefit (subject to any Investment Restrictions involving the source). There is no charge for this benefit.

The Dollar Cost Averaging Program may vary for certain policies and may not be available for all policies, in all states or at all times. See Your Policy for availability of the Fixed Account options. We reserve the right to terminate the availability of any Dollar Cost Averaging program at any time.

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. Asset rebalancing can be used in conjunction with a Guaranteed Lifetime Withdrawal Benefit. Please note, any amounts rebalanced may be immediately transferred to the Portfolio Allocation Method (PAM) Investment Options or Open Allocation Subaccounts as applicable under the Portfolio Allocation Method or Open Allocation Method (OAM). There is no charge for this benefit. We reserve the right to terminate the availability of any asset rebalancing program at any time.

Loans

No Loans are available on this Policy.

TAX INFORMATION

NOTE: We have prepared the following information on federal taxes as a general discussion of the subject. It is not intended as tax advice to any taxpayer. The federal tax consequences discussed herein reflects our understanding of current law, and the law may change. No representation is made regarding the likelihood of continuation of the present federal tax law or of the current interpretations by the Internal Revenue Service. The discussion briefly references federal estate, gift and generation-skipping transfer taxes, but principally discusses federal income taxes. 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 financial professional about Your own circumstances.

Introduction

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 (the “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 withdrawn. This is referred to as tax deferral. When a non-natural person (e.g., corporation or certain trusts) owns a nonqualified Policy, the Policy will generally not be treated as an annuity for tax purposes. Thus, the Owner must generally include in income any increase in the Policy Value over the investment in the Policy during each taxable year.

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.

If You purchase the Policy as an individual retirement annuity or as a part of a 403(b) plan, 457 plan, a pension plan, a profit sharing plan (including a 401(k) plan), or certain other employer sponsored retirement programs, Your Policy is referred to as a qualified 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. To the extent there is a conflict between a plan's provisions and a Policy's provisions, the plan's provisions will control.

If You purchase the Policy other than as part of any arrangement described in the preceding paragraph, the Policy is referred to as a nonqualified Policy.

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You will generally not be taxed on increases in the value of Your Policy, whether qualified or nonqualified, until a distribution occurs (e.g., as a surrender, withdrawal, or as annuity payments). However, You may be subject to current taxation if You assign or pledge or enter into an agreement to assign or pledge any portion of the Policy. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. All amounts received from the Policy that are includible in income are taxed at ordinary income rates; no amounts received from the Policy are taxable at the lower rates applicable to capital gains.

The Internal Revenue Service (“IRS”) has not reviewed the Policy for qualification as an IRA annuity, 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 living and death benefit options and riders elected may need to be taken into account in calculating minimum required distributions from a qualified plan/or Policy.

We may occasionally enter into settlements with Owners and beneficiaries to resolve issues relating to the Policy. Such settlements will be reported on the applicable tax form (e.g., Form 1099) provided to the taxpayer and the taxing authorities.

Taxation of Us

We are at present taxed as a life insurance company under part I of Subchapter L of the Code. The Separate Account is treated as a part of us 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. We may benefit from any dividends received or foreign tax credits attributable to taxes paid by certain underlying fund portfolios to foreign jurisdictions to the extent permitted under federal tax law.

Tax Status of a Nonqualified Policy

Diversification Requirements. In order for a nonqualified variable Policy which is based on a segregated asset account to qualify as an annuity Policy under Section 817(h) of the Code, the investments made by such account must be “adequately diversified” in accordance with Treasury Regulations. The Regulations apply a diversification requirement to each of the Subaccounts. Each 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 but we do not have control over the underlying fund Portfolio Companies. The Owners bear the risk that the entire contract could be disqualified as an annuity Policy under the Code due to the failure of a Subaccount to be deemed to be “adequately diversified.”

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. In Revenue Ruling 2003-91, the IRS stated that whether the Owner of a variable Policy is to be treated as the Owner of the assets held by the insurance company under the Policy will depend on all of the facts and circumstances.

Revenue Ruling 2003-91 also gave an example of circumstances under which the Owner of a variable Policy would not possess sufficient control over the assets underlying the Policy to be treated as the Owner of those assets for federal income tax purposes. To the extent the circumstances relating to the issuance and ownership of a Policy vary from those described in Revenue Ruling 2003-91, Owners bear the risk that they will be treated as the Owner of Separate Account assets and taxed accordingly.

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. Concerned Owners should consult their own financial professionals regarding the tax matter discussed above.

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 starting 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 starting date, the entire interest in the Policy must generally be distributed (1) within 5 years after such Owner's date of death or (2) to (or for the benefit of) a designated beneficiary, over the life of such designated beneficiary (or over a period not extending beyond the life expectancy of such beneficiary) and such distribution begin not later than 1 year after the date of the Owner’s death (also known as a “stretch” payout). The designated beneficiary must be an individual. The only method

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we use for making distribution payments from a nonqualified “stretch” payment option is the required minimum distribution method as set forth in Revenue Ruling 2002-62. The applicable payments are calculated using the Single Life Expectancy Table set forth in Treasury Regulations § 1.401(a)(9)-9, A-1. However, if upon such Owner's death the Owner's surviving spouse is the designated beneficiary of the Policy, then the Policy may be continued with the surviving spouse as the new Owner. If any Owner is a non-natural person (except in the case of certain grantor trusts), 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.

Taxation of a Nonqualified Policy

The following discussion assumes the Policy qualifies as an annuity Policy for federal income tax purposes.

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 as collateral for a loan generally will be treated as a distribution of such portion. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. 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 rules with a competent financial professional. A Policy owned by a trust using the grantor's social security number as its taxpayer identification number will be treated as owned by the grantor (natural person) for the purposes of our application of Section 72 of the Code. Consult a financial professional for more information on how this may impact Your Policy.

Different Individual Owner and Annuitant

If the Owner and Annuitant on the Policy are different individuals, there may be negative tax consequences to the Owner and/or beneficiaries under the Policy if the Annuitant predeceases the Owner including, but not limited, to the assessment of penalty tax and the loss of certain death benefit distribution options. You may wish to consult Your legal counsel or financial professional if You are considering designating a different individual as the Annuitant on Your Policy to determine the potential tax ramifications of such a designation.

Annuity Starting Date

This section makes reference to the annuity starting date as defined in Section 72 of the Code and the applicable regulations. Generally, the definition of annuity starting date will correspond with the definition of Annuity Commencement Date used in Your Policy and the dates will be the same. However, in certain circumstances, Your annuity starting date and Annuity Commencement Date will not be the same date. If there is a conflict between the definitions, we will interpret and apply the definitions in order to ensure Your Policy maintains its status as an annuity Policy for federal income tax purposes. You may wish to consult a financial professional for more information on when this issue may arise.

It is possible that at certain advanced ages a Policy might no longer be treated as an annuity contract if the Policy has not been Annuitized before that age or have other tax consequences. You should consult with a financial professional about the tax consequences in such circumstances.

Taxation of 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.

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

•	Fixed payments-by dividing the “investment in the Policy” on the annuity starting date by the total expected return under the Policy (determined under Treasury regulations) 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 Policy” on the annuity starting date by the total number of expected periodic payments. This is the amount of each annuity payment that is excludable.

The remainder of each annuity payment is includable in gross income. Once the “investment in the Policy” has been fully recovered, the full amount of any additional annuity payments is includable in gross income and taxed as ordinary income. The “investment in the Policy” is generally equal to the premiums You pay for the Policy, reduced by any amounts You have previously received from the Policy that are excludible from gross income.

If You select more than one Annuity Payment Option, special rules govern the allocation of the Policy's entire “investment in the Policy” 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 financial professional as to the potential tax effects of allocating amounts to any particular Annuity Payment Option.

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

Taxation of Surrenders and Withdrawals - Nonqualified Policies

When You surrender Your Policy, You are generally taxed on the amount that Your surrender proceeds exceeds the “investment in the Policy”. The “investment in the Policy” is generally equal to the premiums You pay for the Policy, reduced by any amounts You have previously received from the Policy that are excludible from gross income. Withdrawals are generally treated first as taxable income to the extent of the excess in the Policy Value over the “investment in the policy.” Distributions taken under the systematic payout option are treated for tax purposes as withdrawals, not annuity payments. In general, loans, pledges, and collateral assignments as security for a loan are taxed in the same manner as withdrawals and surrenders. You may also be subject to current taxation if You make a gift of a nonqualified Policy without valuable consideration. All taxable amounts received under a Policy are subject to tax at ordinary rather than capital gain tax rates.

If Your Policy contains an Excess Interest Adjustment feature (also known as a market value adjustment), then Your Policy Value immediately before a Policy withdrawal (or transaction taxed like a withdrawal) may have to be increased by any positive Excess Interest Adjustments that result from the transaction. 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 financial professional.

The Code also provides that amounts received from the Policy that are includible in gross income (including the taxable portion of some annuity payments) 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 withdrawals and other amounts will be exempt from the penalty tax. Amounts received that are not subject to the penalty tax include, among others, any amounts: (1) paid on or after the taxpayer reaches age 59½; (2) paid after an Owner (or where the Owner is a non-natural person, an Annuitant) dies; (3) paid if the taxpayer becomes disabled (as that term is defined in the Code); (4) paid in a series of substantially equal payments made annually (or more frequently) over the life of the taxpayer or the joint life of the taxpayer and the taxpayer's designated beneficiary; (5) paid under an immediate annuity; or (6) which come from premium payments made prior to August 14, 1982. Regarding the disability exception, because we cannot verify that the Owner is disabled, we will report such withdrawals to the IRS as early withdrawals with no known exception from the penalty tax.

Other exceptions may be applicable under certain circumstances and special rules may be applicable in connection with the exceptions enumerated above. You may wish to consult a financial professional for more information regarding the imposition of penalty tax.

Guaranteed Lifetime Withdrawal Benefits

For policies with a Guaranteed Lifetime Withdrawal Benefit or a Guaranteed Minimum Accumulation Benefit the application of certain tax rules, particularly those rules relating to distributions from Your Policy, are not entirely clear. It is possible that the withdrawal base (with respect to the Guaranteed Lifetime Withdrawal Benefits) and the guaranteed future value (with respect to the Guaranteed Minimum Accumulation Benefit) could be taken into account to determine the Policy Value that is used to calculate required distributions and the amount of the distribution that would be included in income. The proper treatment of the Income Enhancement Option under a Guaranteed Lifetime Withdrawal Benefit is unclear. It is possible that the IRS could determine that the

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benefit provides some form of long term care insurance. In that event, the Internal Revenue Service may determine the Income Enhancement Option is an incidental benefit with adverse consequences for qualification as an Individual Retirement Annuity, You could be treated as in receipt of some amount of income attributable to the value of the benefit even though You have not received a payment from Your Policy, and the amount of income attributable to guaranteed lifetime withdrawal payments could be affected. In addition, if the Income Enhancement Benefit causes an increase in payments calculated to meet the Required Minimum Distribution requirements it may violate the rules governing such distributions with adverse tax consequences. In view of this uncertainty, You should consult a financial professional with any questions.

Aggregation

All nonqualified deferred annuity policies that are issued by us (or our affiliates) to the same Owner (policyholder) during the same calendar year are treated as one annuity for purposes of determining the amount includable in the Owner's income when a taxable distribution (other than annuity payments) occurs. If You are considering purchasing multiple policies from us (or our affiliates) during the same calendar year, You may wish to consult with Your financial professional regarding how aggregation will apply to Your policies.

Tax-Free Exchanges of Nonqualified Policies

We may issue the nonqualified Policy in exchange for all or part of another annuity contract that You own. Such an exchange will be tax free if certain requirements are satisfied. If the exchange is tax free, Your investment in the Policy immediately after the exchange will generally be the same as that of the annuity contract exchanged, increased by any additional premium payment made as part of the exchange. Your Policy Value immediately after the exchange may exceed Your investment in the Policy. That excess may be includable in income should amounts subsequently be withdrawn or distributed from the Policy (e.g., as a withdrawal, surrender, annuity income payment or death benefit).

If You exchange part of an existing contract for the Policy, and within 180 days of the exchange You received a payment other than certain annuity payments (e.g., You take a withdrawal) from either contract, the exchange may not be treated as a tax free exchange. Rather, some or all of the amount exchanged into the Policy could be includible in Your income and subject to a 10% penalty tax.

You should consult Your financial professional in connection with an exchange of all or part of an annuity contract for the Policy, especially if You may take a withdrawal from either contract within 180 days after the exchange.

Medicare Tax

Distributions from nonqualified annuity policies are considered “investment income” for purposes of the 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, trusts, and estates whose income exceeds certain threshold amounts. We are required to report distributions taken from nonqualified annuity policies as being potentially subject to this tax. While distributions from qualified policies are not subject to the tax, such distributions may be includable in income for purposes of determining whether certain Medicare Tax thresholds have been met. As such, distributions from Your qualified Policy could cause Your other investment income to be subject to the tax. Please consult a financial professional for more information.

Same Sex Relationships

Same sex couples have the right to marry in all states. The parties to each marriage that is valid under the law of any state will each be treated as a spouse as defined in this Policy. Individuals in other arrangements, such as civil unions, registered domestic partnerships, or other similar arrangements, that are treated as a valid marriage under the applicable state law, will each be treated as a spouse as defined in this Policy for state law purposes. However, individuals in other arrangements that are not recognized as marriage under the relevant state law, will not be treated as married or as spouses as defined in this Policy for federal tax purposes. Therefore, exercise of the spousal continuation provisions of this Policy or any riders by individuals who do not meet the definition of “spouse” may have adverse tax consequences and/or may not be permissible. Please consult a financial professional for more information on this subject.

Taxation of Death Benefit Proceeds

Amounts may be distributed from the Policy because of Your death or the death of the Annuitant. Generally, such amounts should be includable in the income of the recipient: (1) if distributed in a lump sum, these amounts are taxed in the same manner as a surrender; (2) if distributed via withdrawals, these amounts are taxed in the same manner as surrenders; or (3) if distributed under an Annuity Payment Option, these amounts are taxed in the same manner as annuity payments.

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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 exchange 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 transaction or designation should contact a competent financial professional with respect to the potential tax effects.

Charges

It is possible that the IRS 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 IRS may treat fees associated with certain optional benefits as a taxable withdrawal, which might also be subject to a tax penalty if the withdrawal occurs prior to age 59½. Although we do not believe that the fees associated with any optional benefit provided under the Policy should be treated as taxable withdrawals, the tax rules associated with these benefits are unclear, and we advise that You consult Your financial professional prior to selecting any optional benefit under the Policy.

Federal Estate, Gift and Generation-Skipping Transfer Taxes

The estate and gift tax unified credit basic exclusion amount is $10,000,000, subject to inflation adjustments (using the C-CPI-U), for taxable years beginning after December 31, 2017, and before January 1, 2026. The maximum rate is 40%.

The uncertainty as to how the current law might be modified in the future underscores the importance of seeking guidance from a competent professional to help ensure that Your estate plan adequately addresses Your needs and that of Your beneficiaries under all possible scenarios.

Federal Estate Taxes. While no attempt is being made to discuss the Federal estate tax implications of the Policy in detail, a purchaser should keep in mind that the value of an annuity Policy owned by a decedent and payable to a 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 professional for more information.

Generation-Skipping Transfer Tax. Under certain circumstances, the 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 Code may require us to deduct the tax from Your Policy, or from any applicable payment, and pay it directly to the IRS.

Qualified Policies

The qualified Policy is designed for use with several types of tax-qualified retirement plans which are briefly described below. 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 59½ (subject to certain exceptions), distributions that do not conform to specified commencement and minimum distribution rules, and in other specified circumstances. The distribution rules under Section 72(s) of the Code do not apply to annuities provided under a plan described in Sections 401(a), 403(a), 403(b), 408 or 408A of the Code, but other similar rules may. Some retirement plans are subject to distribution and other requirements that are not incorporated into the policies or our Policy administration procedures. Owners, employers, participants, and beneficiaries are responsible for determining that contributions, distributions, and other transactions with respect to the policies comply with applicable law.

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 for the year, 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 withdrawals according to the requirements in the IRS regulations (minimum required distributions) must begin no later than April 1 of the calendar year following the calendar year in which the Annuitant attains age 72 (or age 70½ if the Annuitant attained 70½ before 1/1/2020); (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

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individual retirement annuities under Section 408(b) of the Code contain such provisions. Amounts in the individual retirement annuity (other than nondeductible contributions) generally are taxed only when distributed from the annuity. Distributions prior to age 59½ (unless certain exceptions apply) are subject to a 10% penalty tax.

SIMPLE and SEP IRAs are types of IRAs that allow employers to contribute to IRAs on behalf of their employees. SIMPLE IRAs permit certain small employers to establish SIMPLE plans as provided by section 408(p) of the Code, under which employees may elect to defer to a SIMPLE IRA a specified percentage of compensation. The sponsoring employer is required to make matching or non-elective contributions on behalf of employees. Distributions from SIMPLE IRAs are subject to the same restrictions that apply to IRA distributions. Subject to certain exceptions, distributions prior to age 59½ are subject to a 10 percent penalty tax, which is increased to 25 percent if the distribution occurs within the first two years after the commencement of the employee's participation in the plan. SEP IRAs permit employers to make contributions to IRAs on behalf of their employees, up to a specified dollar amount for the year and subject to certain eligibility requirements as provided by Section 408(k) of the Code. Distributions from SEP IRAs are subject to the same rules that apply to IRA distributions and are taxed as ordinary income.

The IRS has not reviewed this Policy for qualification as a traditional IRA, SIMPLE IRA or SEP IRA, and has not addressed in a ruling of general applicability whether any death benefits available under the Policy comport with qualification requirements.

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, a traditional IRA or other allowed qualified plan. A rollover from or conversion of an IRA to a Roth IRA may be subject to tax. The ability to make cash contributions to Roth IRAs is available to individuals with earned income and whose modified adjusted gross income is under a specified dollar amount for the year. Subject to special rules, the amount per individual that may be contributed to all IRAs (Roth and traditional) is an amount specified in the Code for the year. Secondly, the distributions are taxed differently. The Roth IRA offers tax-free distributions when taken 5 tax years after the first contribution to any Roth IRA of the individual and taken after one of the following: attaining age 59½, to pay for qualified first time home buyer expenses (lifetime maximum of $10,000), or due to death or disability. All other distributions are subject to income tax when taken from earnings and may be subject to a penalty tax unless an exception applies. Please note that specific tax ordering rules apply to Roth IRA distributions. Unlike the traditional IRA, there are no minimum required distributions during the Owner's lifetime; however, minimum required distributions at death are generally the same as for traditional IRAs.

The IRS has not reviewed this Policy for qualification as a Roth IRA, and has not addressed in a ruling of general applicability whether any death benefits available under the Policy comport with qualification requirements.

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 Federal Insurance Contributions Act (FICA or 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. 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, unless certain events have occurred. Specifically distributions of such amounts will be allowed only upon the death of the employee, on or after attainment of age 59½, 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 59½. For policies issued after 2008, amounts attributable to non-elective contributions may be subject to distribution restrictions specified in the employer's section 403(b) plan. Employers using the Policy in connection with Section 403(b) plans may wish to consult with their financial professional.

Pursuant to tax regulations, we generally are required to confirm, with Your 403(b) plan sponsor or otherwise, that surrenders, loans 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 record keeper, and other product providers.

Pension and Profit-Sharing Plans. Sections 401(a) and 403(a) of the Code permit 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. Contributions to and distributions from such plans are limited by the Code and may be subject to penalties.

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Deferred Compensation Plans. Section 457(b) of the Code, while not actually providing for a qualified plan as that term is normally used, provides for certain deferred compensation plans established and maintained by state and local governments (and their agencies and instrumentalities) and tax exempt organizations. Under such plans a participant may be able to specify the form of investment in which his or her participation will be made. For non-governmental Section 457(b) plans, all such investments, however, are typically 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(b) plan obligations. In general, all amounts received under a non-governmental Section 457 plan are taxable in the year paid (or in the year paid or made available in the case of a non-governmental 457(b) plan). Distributions from non-governmental 457(b) plans are subject to federal income tax withholding as wages, distributions from governmental 457(b) plans are subject to withholding as “eligible rollover distributions” as described in the section entitled “Withholding.” below. Contributions to and distributions from such plans are limited by the Code and may be subject to penalties. Deferred compensation plans of governments and tax-exempt entities that do not meet the requirements of Section 457(b) are taxed under Section 457(f), which means compensation deferred under the plan is included in gross income in the first year in which the compensation is not subject to substantial risk of forfeiture.

Ineligible Owners-Qualified

We currently will not issue new policies to/or for the following plans: 403(a), 403(b), 412(i)/412(e)(3), 419, 457 (we will in certain limited circumstances accept 457(f) plans), employee stock ownership plans, Keogh/H.R.-10 plans and any other types of plans at our sole discretion.

Taxation of Surrenders and Withdrawals - Qualified Policies

In the case of a withdrawal under a qualified Policy (other than from a deferred compensation plan under Section 457 of the Code), a pro rata portion of the amount You receive is taxable, generally based on the ratio of Your “investment in the Policy” to Your total account balance or accrued benefit under the retirement plan. Your “investment in the Policy” generally equals the amount of any non-deductible premium payments made by You or on Your behalf. If You do not have any non-deductible premium payments, Your investment in the contract will be treated as zero.

In addition, a penalty tax may be assessed on amounts surrendered from the Policy prior to the date You reach age 59½, unless You meet one of the exceptions to this rule which are similar to the penalty exceptions for distributions from nonqualified policies discussed above. However, the exceptions applicable for qualified policies differ from those provided to nonqualified policies. You may wish to consult a financial professional for more information regarding the application of these exceptions to Your circumstances. 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.

Qualified Plan Required Distributions

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 72 (or 70½ if he/she attained 70½ prior to 1/1/2020) or (ii) retires, and must be made in a specified form or manner. If a participant is a “5 percent Owner” (as defined in the Code), or in the case of an IRA (other than a Roth IRA which is not subject to the lifetime required minimum distribution rules), distributions generally must begin no later than April 1 of the year following the calendar year in which the Owner (or plan participant) reaches age 72 (or 70½ if he/she attained 70½ prior to 1/1/2020). The actuarial present value of death and/or living benefit options and riders elected may need to be taken into account in calculating required minimum distributions. Please consult with your financial professional to learn more about an optional living or death benefit prior to purchase.

Each Owner is responsible for requesting distributions under the Policy that satisfy applicable tax rules. We do not attempt to provide more than general information about the 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 financial professional regarding the suitability of the Policy.

The Code generally requires that interest in a qualified Policy be non-forfeitable.

You should consult Your legal counsel or financial professional 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.

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Optional Living Benefits

For policies with a Guaranteed Lifetime Withdrawal Benefit or a Guaranteed Minimum Accumulation Benefit 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 impact the value of these optional benefits. Additionally, the actions of the qualified plan as contract holder may cause the qualified plan participant to lose the benefit of the Guaranteed Lifetime Withdrawal Benefit. In view of this uncertainty, You should consult a financial professional before purchasing this Policy as a qualified Policy.

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 taken. The amount of withholding varies according to the type of distribution. The withholding rates applicable to the taxable portion of periodic payments (other than eligible rollover distributions) are the same as the withholding rates generally applicable to payments of wages. A 10% withholding rate applies to the taxable portion of non-periodic payments. Regardless of whether You elect not to have federal income tax withheld, You are still liable for payment of federal income tax on the taxable portion of the payment. 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 403(b) 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.

Annuity Purchases by Residents of Puerto Rico

The IRS has 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 Non-resident 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 financial professional regarding U.S., state, and foreign taxation for any annuity Policy purchase.

Foreign Account Tax Compliance Act (“FATCA”)

If the payee of a distribution from the Policy is a foreign financial institution (“FFI”) or a non-financial foreign entity (“NFFE”) within the meaning of the Code as amended by the Foreign Account Tax Compliance Act (“FATCA”), the distribution could be subject to U.S. federal withholding tax on the taxable amount of the distribution at a 30% rate irrespective of the status of any beneficial Owner of the Policy or the distribution. The rules relating to FATCA are complex, and a financial professional should be consulted if an FFI or NFFE is or may be designated as a payee with respect to the Policy.

Possible Tax Law Changes

Although the likelihood and nature 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 financial professional 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 Owners currently receive.

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OTHER INFORMATION

State Variations

Oregon. The Retirement Income Choice^® 1.6 rider will not terminate upon assignment or ownership changes.

Washington. The Retirement Income Choice^® 1.6 designated funds excludes Fixed Account and does not allow funds to be allocated to the Dollar Cost Averaging Fixed Account. The Living Benefits Rider fee cannot be deducted from the Fixed Account.

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 (for replacements the right cancel period is generally 30 days), 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 or federal tax regulations require we will refund your original premium payment(s), or surrender value, if greater. We will pay the refund within seven days after we receive in good order within the applicable period at our Administrative Office, Written Notice of cancellation and the returned Policy. The Policy will then be deemed void.

Sending Forms and Transaction Requests in Good Order

We cannot process Your requests for transactions relating to the Policy until they are received in good order. “Good order” means the actual receipt 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 extent 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 dated signatures of all 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 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.

“Received” or receipt in good order generally means that everything necessary must be received by us, at our Administrative Office specified in the Glossary of Terms. We reserve the right to reject electronic transactions that do not meet our requirements.

Regulatory Modifications to Policy

We reserve the right to amend the Policy or any riders attached thereto as necessary to comply with specific direction provided by state or federal regulators, through change of law, rule, regulation, bulletin, regulatory directives or agreements.

Mixed and Shared Funding

The underlying fund portfolios may serve as investment vehicles for variable life insurance policies, variable annuity policies and retirement plans (“mixed funding”) and shares of the underlying fund portfolios also may be sold to Separate Accounts of other insurance companies (“shared funding”). While we currently do not foresee any disadvantages to Owners and participants arising from either mixed or shared funding, it is possible that the interests of Owners of various policies and/or participants in various plans for which the underlying fund portfolios serve as investments might at some time be in conflict. We and each underlying fund portfolio’s Board of Directors intend to monitor events in order to identify any material conflicts and to determine what action, if any, to take. Such action could include the sale of underlying fund portfolio shares by one or more of the Separate Accounts, which could have adverse consequences. Such action could also include a decision that separate funds should be established for variable life and variable annuity Separate Accounts. In such an event, we would bear the attendant expenses, but Owners and plan participants would no longer have the economies of scale resulting from a larger combined fund. Please read the prospectuses for the underlying fund portfolios, which discuss the underlying fund portfolios’ risks regarding mixed and shared funding, as applicable. Please seeVoting Rights section for how shares held by the Company would be voted.

Abandoned or Unclaimed Property

Every state has unclaimed property laws that generally provide for escheatment to the state of unclaimed property (including proceeds of annuity, life and other insurance policies) under various circumstances. In addition to the state unclaimed property laws, we may be required to escheat property pursuant to regulatory demand, finding, agreement or settlement. To help prevent such escheatment,

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it is important that You keep Your contact and other information on file with us up to date, including the names, contact information and identifying information for Owners, insureds, Annuitants, beneficiaries and other payees. Such updates should be communicated in a form and manner satisfactory to us.

Legal Proceedings

We, like other life insurance companies, are subject to regulatory and legal proceedings, in the ordinary course of our business. Such legal and regulatory matters include proceedings specific to us and other proceedings generally applicable to business practices in the industry in which we operate. In some lawsuits and regulatory proceedings involving insurers, substantial damages have been sought and/or material settlement payments have been made. Although the outcome of any litigation or regulatory proceeding cannot be predicted with certainty, at the present time, we believe that there are no pending or threatened proceedings or lawsuits that are likely to have a material adverse impact on the Separate Account, on TCI's ability to perform under its principal underwriting agreement, or on our ability to meet our obligations under the Policy.

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 may market the policies through bank affiliated firms, national brokerage firms, regional and independent broker-dealers and independent financial planners.

We have discontinued new sales of the policies. You may, however, continue to make Premium Payments to fund Your Policy pursuant to its terms, and exercise all other rights and options under Your Policy - such as reallocating Your Policy Value among investment choices, making surrenders and full surrenders, and making changes of ownership of Your Policy.

Compensation to Broker-Dealers Who Sold the Policies. The policies have been 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 ongoing commissions through TCI to the selling firms for their past sales of the policies.

The selling firms were paid commissions for the promotion and sale of the policies according to one or more schedules. The amount and timing of commissions varies depending on the selling agreement, but the maximum commission is 7.2% of Premium Payment (additional amounts may be paid as overrides to wholesalers).

To the extent permitted by Financial Industry Regulatory Authority (FINRA) rules, the Company and 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 described further below.

The sales representative who sold You the Policy may receive 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 continue to receive in connection with Your Policy. Also inquire about any ongoing compensation 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 have received different compensation or incentives for selling one product over another. In some cases, these differences may have created an incentive for the selling firm or its sales representatives to have recommended or sold this Policy to You.

Special Compensation Paid to Affiliated Firms. We and/or our affiliates may provide paid-in capital to TCI. 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 guarantees.

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Additional Compensation That We, TCI and/or Our Affiliates Pay to Selected Selling Firms. TCI, may continue to pay certain selling firms additional cash amounts in order to receive enhanced marketing services and increased access to their sales representatives. These special compensation arrangements are not offered to all selling firms and the terms of such arrangements may differ among selling firms.

During 2020, in general, payments calculated as a percentage of sales ranged from 7 basis points (0.07%) to 75 basis points (0.75%), payments calculated as a percentage of assets under management ranged from 2.5 basis points (0.025%) to 16 basis points (0.16%), and flat annual fees ranged from $5,000 to $500,000, which included at times payments for a series of meetings and/or events of other broker-dealers and banks.

As of 2021, TCI had revenue sharing agreements with more than 69 brokers and other financial intermediaries including, without limitation:

Advisor Group, Inc.• Ameriprise Financial Services, Inc. • AXA Advisors LLC • BBVA Securities, Inc. • Bruderman Brothers• Cadaret, Grant & Co. • Cambridge Investment Research, Inc. • Centarus Financial, Inc. • Cetera Financial Group, Inc. • CFD Investments, Inc. • Charles Schwab • Citigroup Global Markets, Inc. • Citizens Securities Inc. • CUSO Financial • D.A. Davidson & Co., Inc. • Edward D. Jones & Co., L.P. • Equitable Network, LLC • • Equity Services, Inc. • FSC Securities Corporation • Financial Data Services, Inc. • Geneos Wealth Management, Inc. • GWFS Equities Inc. • GW Sherwold Associates, Inc.• Hantz Financial Services, Inc. • HD Investment Services • Huntington Investment Company • Investacorp, Inc. • Infiniex Investments, Inc. • J.P. Morgan Securities LLC • James T. Borello & Co, • Janney Montgomery Scott, LLC • Kestra Investment Services • KMS Financial Services Inc. • LPL Financial Corp. • Logan Group Securities • M&T Securities, Inc. • Merrill Lynch • MML Investors Services • Morgan Stanley Smith Barney • Mutual of Omaha Investor Services, Inc. • National Financial Services, Inc. • Next Financial • Oppenhaiemer & Co. • Park Avenue Securities• Parkland Securities, LLC • Pershing LLC • Pursche Kaplan Sterling Financial • Raymond James and Associates, Inc. • Raymond James Financial Services, Inc. • RBC Wealth Management • Royal Alliance Associates, Inc. • SagePoint Financial, Inc. • Securian Financial Services, Inc. • Securities America, Inc. • Securities Service Network, Inc. • Sigma Financial Corporation • Stifel Nicolaus & Company Inc. • SunTrust Investment Services Inc.• TD Ameritrade • Triad Advisors, Inc. • Trinity Wealth. • UBS Financial Services Inc.• United Planners Financial Services of America • US Bancorp Investments, Inc. • VOYA Financial Advisors, Inc. • Waddell Reed • Wells Fargo Advisors, LLC • Wentworth Financial Partners • Woodbury Financial Services

For the calendar year ended December 31, 2021 TCI paid approximately $34.4 million to these brokers and other financial intermediaries in connection with revenue sharing arrangements. TCI expects to have revenue sharing arrangements with a number of brokers and other financial intermediaries in 2021, including some or all of the foregoing brokers and financial intermediaries, among others, on terms similar to those discussed above.

No specific charge is assessed directly to Owners or the Separate Account to cover commissions, non-cash compensation, and other incentives or 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.

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APPENDIX

PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY

The following is a list of current Portfolio Companies available under the Policy, which are subject to change as discussed in this prospectus. Depending on the optional benefits you choose, you may not be able to invest in certain Portfolio Companies.

More information about the Portfolio Companies is available in the prospectuses for the Portfolio Companies, which may be amended from time to time and can be found online at http://dfinview.com/Transamerica/TAHD/89352F657?site=VAVUL. You can also request this information at no cost by calling our Administrative Office at (800)525-6205.

The current expenses and performance below reflects fee and expenses of the Portfolio Companies, but do not reflect the other fees and expenses that your Policy may charge. Expenses would be higher and performance would be lower if these other charges were included. Each Portfolio Company’s past performance is not necessarily an indication of future performance.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: To maximize total return consistent with the Adviser's determination of reasonable risk.	AB Balanced Hedged Allocation Portfolio - Class B⁽³⁾ Advised by: AllianceBernstein L.P.	[XXX]%	0.20%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term growth of capital.	AB Growth and Income Portfolio - Class B Advised by: AllianceBernstein L.P.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: To provide high total return (including income and capital gains) consistent with preservation of capital over the long term.	American Funds - Asset Allocation Fund^SM - Class 2 Advised by: Capital Research and Management Company^SM	[XXX]%	0.30%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: To provide growth of capital.	American Funds - Growth Fund^SM - Class 2 Advised by: Capital Research and Management Company^SM	[XXX]%	0.30%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: To achieve long-term growth of capital and income.	American Funds - Growth-Income Fund^SM - Class 2 Advised by: Capital Research and Management Company^SM	[XXX]%	0.30%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: To achieve long-term growth of capital.	American Funds - International Fund^SM - Class 2 Advised by: Capital Research and Management Company^SM	[XXX]%	0.30%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: To provide as high a level of current income as is consistent with the preservation of capital.	American Funds - The Bond Fund of America^SM - Class 2 Advised by: Capital Research and Management Company^SM	[XXX]%	0.30%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks income and capital growth consistent with reasonable risk.	Fidelity ^® VIP Balanced Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Fidelity ^® VIP Contrafund^® Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term growth of capital.	Fidelity ^® VIP Mid Cap Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Seeks capital appreciation.	Fidelity ^® VIP Value Strategies Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: The highest total return, composed of current income and capital appreciation, as is consistent with prudent investment risk.	State Street Total Return V.I.S. Fund - Class 3 Advised by: SSGA Funds Management, Inc.	[XXX]%	0.20%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation and current income.	Transamerica 60/40 Allocation VP - Service Class Advised by: Transamerica Asset Management, Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks a high level of current income by investing in high-yield debt securities.	Transamerica Aegon High Yield Bond VP - Service Class Sub-Advised by: Aegon USA Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks total return gained from the combination of dividend yield, growth of dividends and capital appreciation.	Transamerica Aegon Sustainable Equity Income VP - Service Class Sub-Advised by: Aegon Asset Management UK plc (“AAM”)	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide as high a level of total return as is consistent with prudent investment strategies.	Transamerica Aegon U.S. Government Securities VP - Service Class Sub-Advised by: Aegon USA Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide total return (including income and capital gains) consistent with preservation of capital over the long term while seeking to manage volatility and provide downside protection.	Transamerica American Funds Managed Risk VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize total return.	Transamerica BlackRock Global Real Estate Securities VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks as high a level of current income as is consistent with preservation of capital and liquidity.	Transamerica BlackRock Government Money Market VP - Service Class⁽²⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks current income and preservation of capital.	Transamerica BlackRock iShares Active Asset Allocation - Conservative VP - Service Class⁽⁴⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation and current income.	Transamerica BlackRock iShares Active Asset Allocation - Moderate VP - Service Class⁽⁵⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Seeks capital appreciation with current income as secondary objective.	Transamerica BlackRock iShares Active Asset Allocation - Moderate Growth VP - Service Class⁽⁶⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation and income.	Transamerica BlackRock iShares Dynamic Allocation - Balanced VP - Service Class⁽⁷⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation and income.	Transamerica BlackRock iShares Dynamic Allocation - Growth VP - Service Class⁽⁸⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long term capital appreciation and capital preservation.	Transamerica BlackRock iShares Edge 40 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation and capital preservation.	Transamerica BlackRock iShares Edge 50 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation and capital preservation as a secondary objective.	Transamerica BlackRock iShares Edge 75 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica BlackRock iShares Edge 100 VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation with current income as a secondary objective.	Transamerica BlackRock Tactical Allocation VP - Service Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica International Focus VP - Service Class⁽⁹⁾ Sub-Advised by: Epoch Investment Partners, Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital growth, consistent with preservation of capital and balanced by current income.	Transamerica Janus Balanced VP - Service Class Sub-Advised by: Janus Capital Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica Janus Mid-Cap Growth VP - Service Class Sub-Advised by: Janus Capital Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Conservative VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation and current income.	Transamerica JPMorgan Asset Allocation - Moderate VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation with current income as a secondary objective.	Transamerica JPMorgan Asset Allocation - Moderate Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks total return, consisting of current income and capital appreciation.	Transamerica JPMorgan Core Bond VP - Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to earn a total return modestly in excess of the total return performance of the S&P 500^® (including the reinvestment of dividends) while maintaining a volatility of return similar to the S&P 500^®.	Transamerica JPMorgan Enhanced Index VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation with current income as a secondary objective.	Transamerica JPMorgan International Moderate Growth VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks growth from capital appreciation.	Transamerica JPMorgan Mid Cap Value VP–Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks current income and preservation of capital.	Transamerica JPMorgan Tactical Allocation VP - Service Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks high total return through the combination of income and capital appreciation.	Transamerica Madison Diversified Income VP - Service Class Sub-Advised by: Madison Asset Management. LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to balance capital appreciation and income.	Transamerica Managed Risk - Balanced ETF VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Seeks current income and preservation of capital.	Transamerica Managed Risk - Conservative ETF VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation as a primary objective and income as a secondary objective.	Transamerica Managed Risk - Growth ETF VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation.	Transamerica Market Participation Strategy VP - Service Class Sub-Advised by: PGIM Quantitative Solutions LLC⁽¹⁰⁾	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize long-term growth.	Transamerica Morgan Stanley Capital Growth VP – Service Class Sub-Advised by: Morgan Stanley Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks high total return..	Transamerica Morgan Stanley Global Allocation VP - Service Class Sub-Advised by: Morgan Stanley Investment Management Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide capital appreciation and income while seeking to manage volatility.	Transamerica Morgan Stanley Global Allocation Managed Risk - Balanced VP - Service Class Sub-Advised by: Milliman Financial Risk Management LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to track the investment results of an index composed of large- and mid-capitalization developed market equities, excluding the U.S. and Canada.	Transamerica MSCI EAFE Index VP - Service Class Sub-Advised by: SSGA Funds Management, Inc.	[XXX]%	0.15%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide a high total investment return through investments in a broadly diversified portfolio of stock, bonds and money market instruments.	Transamerica Multi-Managed Balanced VP – Service Class Sub-Advised by: J.P. Morgan Investment Management Inc. and Aegon USA Investment Management, LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks a combination of capital appreciation and income.	Transamerica PIMCO Tactical - Balanced VP - Service Class Sub-Advised by: Pacific Investment Management Company LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks a combination of capital appreciation and income.	Transamerica PIMCO Tactical - Conservative VP - Service Class Sub-Advised by: Pacific Investment Management Company LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks a combination of capital appreciation and income.	Transamerica PIMCO Tactical - Growth VP - Service Class Sub-Advised by: Pacific Investment Management Company LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks maximum total return consistent with preservation of capital and prudent investment management.	Transamerica PIMCO Total Return VP – Service Class Sub-Advised by: Pacific Investment Management Company LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Seeks maximum real return, consistent with appreciation of capital.	Transamerica PineBridge Inflation Opportunities VP - Service Class Sub-Advised by: PineBridge Investments LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica Rothschild & Co Large Cap Value VP - Service Class Sub-Advised by: Rothschild & Co Asset Management US Inc. (“Rothschild”)	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide investment results that, before expenses, correspond generally to the price and yield performance of the S&P 500^® Index.	Transamerica S&P 500 Index VP - Service Class Sub-Advised by: SSGA Funds Management, Inc.	[XXX]%	0.15%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize total return.	Transamerica Small/Mid Cap Value VP – Service Class Sub-Advised by: Systematic Financial Management L.P. & Thompson, Siegel & Walmsley LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term growth of capital by investing primarily in common stocks of small growth companies.	Transamerica T. Rowe Price Small Cap VP – Service Class Sub-Advised by: T. Rowe Price Associates, Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks maximum long-term total return, consistent with reasonable risk to principal, by investing in a diversified portfolio of common stocks of primarily non-U.S. issuers.	Transamerica TS&W International Equity VP – Service Class Sub-Advised by: Thompson, Siegel & Walmsley LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize long-term growth.	Transamerica WMC US Growth VP – Service Class Sub-Advised by: Wellington Management Company, LLP	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

⁽¹⁾

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 objective, investment goals, time horizons, and risk tolerance.

⁽²⁾	There can be no assurance that any money market portfolio offered under this Policy will be able to maintain a stable net asset value per share

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PORTFOLIO COMPANIES AVAILABLE UNDER THE POLICY — (Continued)

during extended periods of low interest rates, and partly as a result of policy charges, the yield on the money market Subaccount may become extremely low and possibly negative.

⁽³⁾	Effective on or about May 1, 2022 AB Balanced Wealth Strategy Portfolio will be renamed AB Balanced Hedged Allocation Portfolio.
⁽⁴⁾	Effective on or about November 1, 2021 Transamerica QS Investors Active Asset Allocation - Conservative VP will be renamed Transamerica BlackRock iShares Active Asset Allocation - Conservative VP.
⁽⁵⁾	Effective on or about November 1, 2021 Transamerica QS Investors Active Asset Allocation - Moderate VP will be renamed Transamerica BlackRock iShares Active Asset Allocation - Moderate VP.
⁽⁶⁾	Effective on or about November 1, 2021 Transamerica QS Investors Active Asset Allocation - Moderate Growth VP will be renamed Transamerica BlackRock iShares Active Asset Allocation - Moderate Growth VP.
⁽⁷⁾	Effective on or about November 1, 2021 Transamerica Legg Mason Dynamic Allocation - Balanced VP will be renamed Transamerica BlackRock iShares Dynamic Allocation - Balanced VP.
⁽⁸⁾	Effective on or about November 1, 2021 Transamerica Legg Mason Dynamic Allocation - Growth VP will be renamed Transamerica BlackRock iShares Dynamic Allocation - Growth VP.
⁽⁹⁾	Effective on or about November 1, 2021 Transamerica International Growth VP sub-advised by TDAM USA Inc. will be renamed Transamerica International Focus VP and will be sub-advised by Epoch Investment Partners, Inc.
⁽¹⁰⁾	Effective on or about September 28, 2021 Transamerica Market Participation Strategy VP will have a sub-adviser change from Quantitative Management Associates LLC (QMA LLC) to PGIM Quantitative Solutions LLC.

NOTE: All underlying fund portfolios in the Transamerica Series Trust are advised by Transamerica Asset Management. The entities listed are the sub-advisers unless otherwise indicated.

Certain Subaccounts may not be available in all states, at all times or through all financial intermediaries. We may discontinue offering any Subaccount at any time. In some cases, a Subaccount not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a Subaccount, please contact Your financial intermediary or our Administrative Office.

PORTfolio companies available under the policy prior to 2003

For policyholders that purchased their policies before May 1, 2003, the following Initial Class Transamerica Series Trust funds are available in place of the Service Class funds listed in the prior fund listing.

The current expenses and performance below reflects fee and expenses of the Portfolio Companies. Fund Facilitation Fees are not applicable to these funds.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	1 year	5 years	10 years
Investment Objective: Seeks a high level of current income by investing in high-yield debt securities.	Transamerica Aegon High Yield Bond VP – Initial Class Sub-Advised by: Aegon USA Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks total return gained from the combination of dividend yield, growth of dividends and capital appreciation.	Transamerica Aegon Sustainable Equity Income VP - Initial Class Sub-Advised by: Aegon Asset Management UK plc (“AAM”)	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide as high a level of total return as is consistent with prudent investment strategies.	Transamerica Aegon U.S. Government Securities VP – Initial Class Sub-Advised by: Aegon USA Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize total return.	Transamerica BlackRock Global Real Estate Securities VP – Initial Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks as high a level of current income as is consistent with preservation of capital and liquidity.	Transamerica BlackRock Government Money Market VP - Initial Class⁽¹⁾ Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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PORTfolio companies available under the policy prior to 2003 — (Continued)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	1 year	5 years	10 years
Investment Objective: Seeks long term capital appreciation and capital preservation.	Transamerica BlackRock iShares Edge 40 VP – Initial Class Sub-Advised by: BlackRock Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica International Focus VP – Initial Class⁽²⁾ Sub-Advised by: Epoch Investment Partners, Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica Janus Mid-Cap Growth VP – Initial Class Sub-Advised by: Janus Capital Management LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Conservative VP - Initial Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks current income and preservation of capital.	Transamerica JPMorgan Asset Allocation - Growth VP - Initial Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation with current income as a secondary objective.	Transamerica JPMorgan Asset Allocation - Moderate Growth VP - Initial Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to earn a total return modestly in excess of the total return performance of the S&P 500^® (including the reinvestment of dividends) while maintaining a volatility of return similar to the S&P 500^®.	Transamerica JPMorgan Enhanced Index VP – Initial Class Sub-Advised by: J.P. Morgan Investment Management Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize long-term growth.	Transamerica Morgan Stanley Capital Growth VP - Initial Class Sub-Advised by: Morgan Stanley Investment Management Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to provide a high total investment return through investments in a broadly diversified portfolio of stock, bonds and money market instruments.	Transamerica Multi-Managed Balanced VP – Initial Class Sub-Advised by: J.P. Morgan Investment Management Inc. and Aegon USA Investment Management, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks maximum total return consistent with preservation of capital and prudent investment management.	Transamerica PIMCO Total Return VP – Initial Class Sub-Advised by: Pacific Investment Management Company LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term growth of capital by investing primarily in common stocks of small growth companies.	Transamerica T. Rowe Price Small Cap VP – Initial Class Sub-Advised by: T. Rowe Price Associates, Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks maximum long-term total return, consistent with reasonable risk to principal, by investing in a diversified portfolio of common stocks of primarily non-U.S. issuers.	Transamerica TS&W International Equity VP – Initial Class Sub-Advised by: Thompson, Siegel & Walmsley LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to maximize long-term growth.	Transamerica WMC US Growth VP – Initial Class Sub-Advised by: Wellington Management Company, LLP	[XXX]%	[XXX]%	[XXX]%	[XXX]%

⁽¹⁾	There can be no assurance that any money market portfolio offered under this Policy will be able to 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 money market Subaccount may become extremely low and possibly negative.
⁽²⁾	Effective on or about November 1, 2021 Transamerica International Growth VP sub-advised by TDAM USA Inc. will be renamed Transamerica International Focus VP and will be sub-advised by Epoch Investment Partners, Inc.

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CLOSED INVESTMENT OPTIONS:

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.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	1 year	5 years	10 years
Investment Objective: Seeks to provide capital growth.	Fidelity VIP Growth Opportunities Portfolio - Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation.	Janus Henderson Mid Cap Value Portfolio - Service Shares Advised by: Janus Capital Management LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seeks to maximize total return.	Transamerica Small/Mid Cap Value VP - Initial Class Sub-Advised by: Systematic Financial Management L.P. & Thompson, Siegel & Walmsley LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%

The following Subaccounts are only available to Owners that held an investment in these Subaccounts on December 12, 2011. However, if any such Owner surrenders all of his or her money from these Subaccounts after December 12, 2011, that Owner may not reinvest in those Subaccounts.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	1 year	5 years	10 years
Investment Objective: Long-term growth of capital.	Invesco V.I. Value Opportunities Fund – Series II Shares Advised by: Invesco Advisers, Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seek capital growth.	Invesco V.I. American Franchise Fund – Series II Shares Advised by: Invesco Advisers, Inc.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term growth of capital.	AB Large Cap Growth Portfolio – Class B Advised by: AllianceBernstein L.P.	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks reasonable income and will also consider the potential for capital appreciation. The goal is to achieve a yield which exceeds the composite yield on the securities comprising the S& P 500^® Index.	Fidelity VIP Equity-Income Portfolio – Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks to achieve capital appreciation.	Fidelity VIP Growth Portfolio – Service Class 2 Advised by: Fidelity Management & Research Company	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Capital appreciation. Secondary goal is income.	Franklin Mutual Shares VIP Fund - Class 2 Advised by: Franklin Mutual Advisers, LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term growth of capital.	Janus Henderson Enterprise Portfolio – Service Shares Advised by: Janus Capital Management LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term growth of capital.	Janus Henderson Global Research Portfolio – Service Shares Advised by: Janus Capital Management LLC	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seek total Return.	MFS ^® Total Return Series – Service Class Advised by: MFS^® Investment Management	[XXX]%	[XXX]%	[XXX]%	[XXX]%

Effective open of business on September 17, 2012, the following Subaccounts are closed to new investments.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: To maximize income while maintaining prospects for capital appreciation.	Franklin Income VIP Fund - Class 2 Advised by: Franklin Advisers, Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term capital growth.	Templeton Foreign VIP Fund - Class 2 Advised by: Templeton Investment Counsel LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks capital appreciation. Secondary goal is income.	Franklin Allocation VIP Fund - Class 4 Advised by: Franklin Templeton Services, LLC	[XXX]%	0.15%	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seek capital appreciation.	MFS ^® New Discovery Series – Service Class Advised by: MFS^® Investment Management	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

Effective December 12, 2011, the Invesco V.I. Value Opportunities Fund (Series II) was closed to new investments. Effective on or about August 18, 2017, the Invesco V.I. Value Opportunities Fund (Series II) fund was replaced with Transamerica Barrow Hanley Dividend Focused VP (Initial Class)

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seeks total return gained from the combination of dividend yield, growth of dividends and capital appreciation.	Transamerica Aegon Sustainable Equity Income VP - Initial Class Sub-Advised by: Aegon Asset Management UK plc (“AAM”)	[XXX]%	[XXX]%	[XXX]%	[XXX]%

Effective on December 1, 2020 Transamerica Barrow Hanley Dividend Focused VP was renamed Transamerica Aegon Sustainable Equity Income.

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Landmark^SM ML INVESTMENT OPTIONS:

Below is listed of Investment Options specific to the Landmark^SM ML contracts.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seeks capital appreciation and, secondarily, income.	BlackRock Basic Value V.I. Fund Advised by: BlackRock Advisors, LLC.	[XXX]%	[XXX]%	[XXX]%	[XXX]%

Effective on or about September 17, 2018 the BlackRock High Yield V.I. Fund, the BlackRock Total Return V.I. Fund, and the BlackRock U.S. Government Bond V.I. Fund (fund “Funds” will reorganize into a newly created series called the BlackRock Variable Series Funds, II Inc.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seeks to maximize total return, consistent with income generation and prudent investment management.	BlackRock High Yield V.I. Fund - Class I Shares Advised by: BlackRock Advisors, LLC.	[XXX]%	[XXX]%	[XXX]%	[XXX]%

The following Subaccount will only be available to Owners that held an investment in these Subaccounts on May 1, 2009. However, if any such Owner surrenders all of his or her money from these Subaccounts after May 1, 2009, that Owner may not reinvest in the Subaccount.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Average Annual Total Returns (as of 12/31/21)
			1 year	5 years	10 years
Investment Objective: Seeks high total investment returnl.	BlackRock Global Allocation V.I. Fund Advised by: BlackRock Advisors, LLC.	[XXX]%	[XXX]%	[XXX]%	[XXX]%

The following Subaccounts will be available on or about on March 21, 2016.

Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	Average Annual Total Returns (as of 12/31/21)
Investment Objective	Underlying Fund Portfolio and Adviser/Sub-adviser⁽¹⁾	Current Expenses	Platform Charges	Current Expenses Plus Platform Charges	1 year	5 years	10 years
Investment Objective: Long-term capital appreciation with capital preservation.	Transamerica BlackRock iShares Edge 50 VP - Service Class Sub-Advised by: Transamerica Asset Management Inc. & BlackRock Investment Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Long-term capital appreciation with capital preservation as a secondary objective.	Transamerica BlackRock iShares Edge 75 VP - Service Class Sub-Advised by: Transamerica Asset Management Inc. & BlackRock Investment Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica BlackRock iShares Edge 100 VP - Service Class Sub-Advised by: Transamerica Asset Management Inc. & BlackRock Investment Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks long-term capital appreciation.	Transamerica International Focus VP - Service Class Sub-Advised by: SSGA Funds Management, Inc.	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%
Investment Objective: Seeks high total return through the combination of income and capital appreciation.	Transamerica Madison Diversified Income VP - Service Class Sub-Advised by: Madison Asset Management. LLC	[XXX]%	-	[XXX]%	[XXX]%	[XXX]%	[XXX]%

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APPENDIX

Designated Investment Options

The table below identifies the Designated Investment Options available for use with the Guaranteed Minimum Death Benefits and our Guaranteed Lifetime Withdrawal Benefits.

	Double Enhanced Death Benefit⁽¹⁾	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider
Subaccounts		Before 12/12/11	12/12/11 to 11/9/14	11/10/14 to 1/31/18	2/1/18 to 4/30/20	Post 5/1/20	Before 2/28/19	3/1/19 to 8/31/2020	9/1/2020 and After Group A, B or C
AB Balanced Hedged Allocation Portfolio - Class B	√						A	A	B
AB Growth and Income Portfolio - Class B								A	A
American Funds - Asset Allocation Fund^SM - Class 2	√							A	B
American Funds - The Bond Fund of America^SM - Class 2	√	√	√	√	√	√	C	A	C
American Funds - Growth Fund^SM - Class 2								A	A
American Funds - Growth-Income Fund^SM - Class 2								A	A
American Funds - International Fund^SM - Class 2								A	A
Fidelity ^® VIP Balanced Portfolio - Service Class 2	√							A	B
Fidelity ^® VIP Contrafund^® Portfolio - Service Class 2								A	A
Fidelity ^® VIP Mid Cap Portfolio - Service Class 2								A	A
Fidelity ^® VIP Value Strategies Portfolio - Service Class 2								A	A
State Street Total Return V.I.S. Fund - Class 3	√						A	A	B
TA 60/40 Allocation - Service Class							A	A	B
TA Aegon High Yield Bond - Service Class								A	B
TA Aegon Sustainable Equity Income - Service Class								A	A
TA Aegon U.S. Government Securities - Service Class	√	√	√	√	√	√	C	A	C
TA American Funds Managed Risk - Balanced - Service Class⁽²⁾	√	√	√		√		B	A	B
TA BlackRock Global Real Estate Securities - Service Class								A	A
TA BlackRock Government Money Market - Service Class	√	√	√	√	√	√	C	A	C
TA BlackRock iShares Active Asset Allocation - Conservative - Service Class⁽²⁾	√	√	√	√	√	√	C	A	B

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Designated Investment Options — (Continued)

	Double Enhanced Death Benefit⁽¹⁾	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider
Subaccounts		Before 12/12/11	12/12/11 to 11/9/14	11/10/14 to 1/31/18	2/1/18 to 4/30/20	Post 5/1/20	Before 2/28/19	3/1/19 to 8/31/2020	9/1/2020 and After Group A, B or C
TA BlackRock iShares Active Asset Allocation - Moderate - Service Class⁽²⁾		√	√	√	√	√	B	A	B
TA BlackRock iShares Active Asset Allocation - Moderate Growth - Service Class⁽²⁾							A	A	B
TA BlackRock iShares Dynamic Allocation - Balanced - Service Class⁽²⁾		√	√	√	√	√	B	A	B
TA BlackRock iShares Dynamic Allocation - Growth - Service Class⁽²⁾							A	A	B
TA BlackRock iShares Edge 40- Service Class	√	√	√		√	√	C	A	B
TA BlackRock iShares Edge 50 - Service Class	√						B	A	B
TA BlackRock iShares Edge 75 - Service Class	√						A	A	B
TA BlackRock iShares Edge 100 - Service Class	√							A	A
TA BlackRock Tactical Allocation - Service Class⁽²⁾							B	A	B
TA International Focus - Service Class								A	A
TA Janus Balanced - Service Class							A	A	B
TA Janus Mid-Cap Growth - Service Class								A	A
TA JPMorgan Asset Allocation - Conservative - Service Class⁽²⁾	√	√	√	√	√	√	C	A	B
TA JPMorgan Asset Allocation - Growth - Service Class								A	A
TA JPMorgan Asset Allocation - Moderate - Service Class⁽²⁾	√	√	√		√	√	B	A	B
TA JPMorgan Asset Allocation - Moderate Growth - Service Class⁽²⁾	√						A	A	B
TA JPMorgan Core Bond - Service Class		√	√	√	√	√	C	A	C
TA JPMorgan Enhanced Index - Service Class								A	A
TA JPMorgan International Moderate Growth - Service Class⁽²⁾	√						A	A	B
TA JPMorgan Mid Cap Value - Service Class								A	A
TA JPMorgan Tactical Allocation - Service Class		√	√	√	√	√	C	A	B
TA Madison Diversified Income - Service Class		√	√	√	√	√	B	A	B
TA Managed Risk - Balanced ETF - Service Class⁽²⁾	√	√	√	√	√	√	B	A	B

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Designated Investment Options — (Continued)

	Double Enhanced Death Benefit⁽¹⁾	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Max^® Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider	Retirement Income Choice^® 1.6 Rider
Subaccounts		Before 12/12/11	12/12/11 to 11/9/14	11/10/14 to 1/31/18	2/1/18 to 4/30/20	Post 5/1/20	Before 2/28/19	3/1/19 to 8/31/2020	9/1/2020 and After Group A, B or C
TA Managed Risk - Conservative ETF - Service Class⁽²⁾	√	√	√	√	√	√	C	A	B
TA Market Participation Strategy - Service Class		√	√					A	B
TA Morgan Stanley Capital Growth - Service Class								A	A
TA Morgan Stanley Global Allocation - Service Class							A	A	B
TA Morgan Stanley Global Allocation Managed Risk - Balanced - Service Class⁽²⁾	√	√	√		√		B	A	B
TA MSCI EAFE Index - Service Class	√							A	A
TA Multi-Managed Balanced - Service Class	√						A	A	B
TA PIMCO Tactical - Balanced - Service Class⁽²⁾		√	√				B	A	B
TA PIMCO Tactical - Conservative - Service Class⁽²⁾		√	√	√	√		C	A	B
TA PIMCO Tactical - Growth - Service Class⁽²⁾							A	A	B
TA PIMCO Total Return - Service Class	√	√	√	√	√	√	C	A	C
TA PineBridge Inflation Opportunities - Service Class		√	√	√	√	√	C	A	C
TA Rothschild & Co Large Cap Value - Service Class								A	A
TA S&P 500 Index - Service Class	√							A	A
TA Small Mid Cap Value - Service Class								A	A
TA T. Rowe Price Small Cap - Service Class								A	A
TA TS&W International Equity - Service Class								A	A
TA WMC US Growth - Service Class								A	A
Fixed Account	√	√	√	√	√	√	C	A	C

⁽¹⁾	The Double Enhanced Death Benefit is no longer available on new policies.

⁽²⁾

This Subaccount invests in an underlying fund portfolio that utilized a volatility management strategy as part of its investment objective and/or principal investment strategy. See Investment Restrictions earlier in the prospectus for information on how volatility management strategies may impact Your Policy Value in certain optional riders.

Certain designated Investment Options may not be available in all states, at all times or through all financial intermediaries. We may discontinue offering any designated Investment Option at any time. In some cases, a designated Investment Option not available through a financial intermediary may be obtained by contacting us directly. For more information on the options available for electing a designated Investment Option, please contact your financial intermediary or our Administrative Office.

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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	AV201 101 65 189	January 1991
	AV254 101 87 196	June 1996
	AV320 101 99 197	May 1997
	AV376 101 106 1197	May 1998
	AV432 101 114 199	May 2000
	AV494 101 124 100	May 2000
	AV620 101 137 101	May 2001
	AV720 101 148 102	May 2002
	AV920 101 168 603	November 2003
Policy Endorsement Form Number	AE830 292	May 1992
	AE847 394	June 1994
	AE871 295	May 1995
	AE909 496	June 1996
	AE890 196	June 1996
	AE945 197	May 1997

Product Feature	Landmark 96 & Prior Form Number: AV201 101 65 189	Landmark 96 & Prior Form Numbers: AV201 101 65 189 AE830 292 AE847 394	Landmark 96 & Prior Form Numbers: AV201 101 65 189 AE847 394 AE871 295
Guaranteed Minimum Death Benefit Option(s)	Total premiums paid, less any partial surrenders and any surrender charges made before death, accumulated at 4% to the date we receive due proof of death or the Policy Value on the date we receive due proof of death, which ever is greater.	5% Annually Compounding	A. 5% Annually Compounding B. Annual Step-Up Option A is only available if Owner and Annuitant are both under age 75.
Double Enhanced Death Benefit Designated Funds	N/A	N/A	N/A
Death Proceeds	Greater of: 1) the Policy Value on the date we receive due proof of death, or 2) the total premiums paid for this policy, less any partial surrenders and any surrender charges made before death, accumulated at 4% interest per annum to the date we receive due proof of death	Greater of: 1) Policy Value or 2) 5% Annually Compounding Death Benefit	Greater of: 1) Policy Value or 2) guaranteed minimum death benefit
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	1.40%	1.40%	1.40%
Is Mortality & Expense Risk Fee and Administrative Charge different after the Annuity Commencement Date?	No	No	No
Fund Facilitation Fee	No	No	No
Guaranteed Period Options (available in the Fixed Account)	1 and 3 year guaranteed periods available.	1 and 3 year guaranteed periods available.	1 and 3 year guaranteed periods available.

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Product Feature	Landmark 96 & Prior Form Number: AV201 101 65 189	Landmark 96 & Prior Form Numbers: AV201 101 65 189 AE830 292 AE847 394	Landmark 96 & Prior Form Numbers: AV201 101 65 189 AE847 394 AE871 295
Annual Contract Charge (Service Charge)	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0
Distribution Financing Charge	N/A	N/A	N/A
Liquidity (L-Share) Optional Rider	Not Available	Not Available	Not Available
Optional Riders	N/A	N/A	N/A
Premium Enhancement^SM	No	No	No
Excess Interest Adjustment	N/A	Yes	Yes
Asset Rebalancing	N/A	Yes	Yes
Dollar Cost Averaging Fixed Account Option	N/A	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	N/A	Yes - Endorsement AE 847 394	Yes - Endorsement AE 847 394
Unemployment Waiver	N/A	N/A	N/A
Surrender Charge Free Amount Limited to a Certain Number of Withdrawals	Yes - One per year.	Yes - One per year.	Yes - One per year.

Product Feature	Landmark 96 & Prior Form Numbers: AV254 101 87 196 AE909 496 AE 890 196	Landmark 97 Form Numbers: AV320 101 99 197 AE945 197	Landmark 98 Form Numbers: AV376 101 106 1197 AE 945 197
Guaranteed Minimum Death Benefit Option(s)	A. 5% Annually Compounding B. Annual Step-Up C. Return or Premium Option A is only available if Owner and Annuitant are both under age 75.	A. 5% Annually Compounding B. Annual Step-Up C. Return of Premium Option A is only available if Owner and Annuitant are both under age 75. Option B is only available if Owner and Annuitant are under age 81.	A. 5% Annually Compounding B. Double Enhanced C. Return of Premium Option A is only available if Owner and Annuitant are both under Age 75. Option B is only available if Owner and Annuitant are both under age 81.
Double Enhanced Death Benefit Designated Funds	N/A	N/A	N/A
Death Proceeds	Greatest of (a) annuity purchase value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	• 1.40% for Return of Premium • 1.40% for Step-up • 1.40% for Compounding	• 1.40% for Return of Premium (Years 1-7) • 1.25% for Return of Premium (Years 8+) • 1.55% for Compounding (Years 1-7) • 1.40% for Compounding (Years 8+) • 1.55%for Annual Step-up (Years 1-7) • 1.40% for Annual Step Up (Years 8+)	• 1.40% for Return of Premium (Years 1-7) • 1.25% for Return of Premium (Years 8+) • 1.55% for Compounding (Years 1-7) • 1.40% for Compounding (Years 8+) • 1.55% for Annual Step-up (Years 1-7) • 1.40% for Annual Step Up (Years 8+)
Is Mortality & Expense Risk Fee and Administrative Charge different after the Annuity Commencement Date?	No	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee	No	No	No
Guaranteed Period Options (available	1, 3, 5, and 7 year guaranteed periods	1, 3, 5 and 7 year guaranteed periods	1, 3, 5, and 7 year guaranteed periods

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Product Feature	Landmark 96 & Prior Form Numbers: AV254 101 87 196 AE909 496 AE 890 196	Landmark 97 Form Numbers: AV320 101 99 197 AE945 197	Landmark 98 Form Numbers: AV376 101 106 1197 AE 945 197
in the Fixed Account)	available.	available.	available.
Annual Contract Charge (Service Charge)	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.
Distribution Financing Charge	N/A	Applicable	Applicable
Liquidity (L-Share) Optional Rider	Not Available	Not Available	Not Available
Optional Riders	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003
Premium Enhancement^SM	No	No	No
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing	Yes	Yes	Yes
Dollar Cost Averaging Fixed Account Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes - Endorsement AE 890 196	Yes - Endorsement AE 945 197	Yes - Endorsement AE 945 197
Unemployment Waiver	N/A	N/A	N/A
Surrender Charge Free Amount Limited to a Certain Number of Withdrawals	Yes - One per year.	Yes - One per year.	Yes - One per year.

Product Feature	Landmark 2000 Form Numbers: AV432 101 114 199 CRT AV494 101 124 100 and RGMI 1 798	Landmark 2001 Form Numbers: AV620 101 137 101 and RGMI 1 798	Landmark 2002 Form Numbers: AV720 101 148 102 RGMI 1 798
Guaranteed Minimum Death Benefit Option(s)	A. 5% Annually Compounding B. Greater of 5% Annually Compounding through age 80 or Annual Step-Up through age 80 C. Return of Premium D. Monthly Step-Up through age 80 Option A is only available if Owner and Annuitant are both under age 75. Option B and D are only available if Owner and Annuitant are both under age 81.	A. Double Enhanced Death Benefit - Greater of (1) 6% Annually Compounding through age 80 or (2) Monthly Step-Up through age 80 B. Return of Premium Death Benefit Option A is available if Owner and Annuitant are age 80 or younger. Option B is available if Owner and Annuitant are age 90 or younger.	A. Double Enhanced Death Benefit - greater of (1) 6% Annually Compounding through age 80 or (2) monthly step-up through age 80 B. Return of Premium Death Benefit Option A is available if Owner and Annuitant are age 80 or younger. Option B is available if Owner and Annuitant are age 90 or younger.

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POLICY VARIATIONS — (Continued)

Product Feature	Landmark 2000 Form Numbers: AV432 101 114 199 CRT AV494 101 124 100 and RGMI 1 798	Landmark 2001 Form Numbers: AV620 101 137 101 and RGMI 1 798	Landmark 2002 Form Numbers: AV720 101 148 102 RGMI 1 798
Double Enhanced Death Benefit Designated Funds	N/A	N/A	N/A
Death Proceeds	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	• 1.40% for Return of Premium • 1.55% for Compounding • 1.55% for Annual Step-up • 1.55% for Double Enhanced	• 1.25% for Return of Premium • 1.50% for Double Enhanced	• B-Share: 1.30% for Return of Premium • 1.55% for Double Enhanced • L-Share (Optional Liquidity Rider): 1.80% for Return of Premium (Years 1-4) • 1.30% for Return or Premium (Years 5+) • 2.05% for Double Enhanced (Years 1-4) • 1.55% for Double Enhanced (Years 5+)
Is Mortality & Expense Risk Fee and Administrative Charge different after the Annuity Commencement Date?	Yes - 1.25% for Individual Annuity and 1.55% for Group Policy	Yes - 1.25%	Yes - 1.25%
Fund Facilitation Fee	No	No	No
Guaranteed Period Options (available in the fixed account)	1, 3, 5, and 7 year guaranteed periods available.	1, 3, 5, and 7 year guaranteed periods available.	1, 3, 5, and 7 year guaranteed periods available.
Annual Contract Charge (Service Charge)	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options. (Group Policy AV432 101 114 199 $0-$2000 = 2% or if Policy Value is over $2001 = $40)	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.
Distribution Financing Charge	N/A	N/A	N/A
Liquidity (L-Share) Optional Rider	Not Available	Not Available	Available
Optional Riders	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life 2005^SM • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003 • Group Policy AV432 101 114 199 options - Income Select^SM for Life,	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003	• Family Income Protector • Managed Annuity Program • Managed Annuity Program II • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003

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POLICY VARIATIONS — (Continued)

Product Feature	Landmark 2000 Form Numbers: AV432 101 114 199 CRT AV494 101 124 100 and RGMI 1 798	Landmark 2001 Form Numbers: AV620 101 137 101 and RGMI 1 798	Landmark 2002 Form Numbers: AV720 101 148 102 RGMI 1 798
	Living Benefits Rider 2005, Guaranteed Minimum Income Benefit RGMI 4 499.
Premium Enhancement^SM	Yes - Endorsements for Group Policy AV432 101 114 199 - AE 1073 199, AE 1075 199, or AE 1076 199	No	No
Excess Interest Adjustment	Yes	Yes	Yes
Asset Rebalancing	Yes	Yes	Yes
Dollar Cost Averaging Fixed Account Option	Yes	Yes	Yes
Nursing Care and Terminal Condition Withdrawal Option	Yes	Yes	Yes
Unemployment Waiver	Yes	Yes	Yes
Surrender Charge Free Amount Limited to a Certain Number of Withdrawals	Yes - One per year.	Yes - One per year.	Yes - One per year.

Product Feature	Landmark 2002 - Revised Form Number: AV720 101 148 102	Landmark 2003 Form Number: AV920 101 168 603	Landmark 2008 Form Number: AV920 101 168 603
Guaranteed Minimum Death Benefit Option(s)	A. Double Enhanced Death Benefit (RGMD 6 0203) - greater of (1) 6% Annually Compounding through age 80 or (2) Monthly Step-Up through age 80 B. Annual Step Up Death Benefit (RGMD 5 0103) C. Return of Premium Death Benefit Option A and B are available if Owner and Annuitant are age 80 or younger. Option C is available if Owner and Annuitant are age 90 or younger.	A. Double Enhanced Death Benefit (RGMD 6 0203) - greater of (1) 6% Annually Compounding through age 80 or (2) Monthly Step-Up through age 80 B. Annual Step Up Death Benefit (RGMD 5 0103) C. Return of Premium Death Benefit (RGMD 8 0603) Option A and B are available if Owner and Annuitant are age 80 or younger. Option C is available if Owner and Annuitant are age 90 or younger.	A. Double Enhanced Death Benefit (RGMD 15 0108) - greater of (1) 6% Annually Compounding through age 80 or (2) Monthly Step-Up through age 80 B. Annual Step Up Death Benefit (RGMD 5 0103) C. Return of Premium Death Benefit (RGMD 8 0603) Option A and B are available if Owner and Annuitant are age 75 or younger. For riders issued on or after December 12, 2011. Option C is available is Owner and Annuitant are age 86 or younger. For riders issued prior to December 12, 2011. Option C is available if Owner and Annuitant are age 90 or younger.
Double Enhanced Death Benefit Designated Funds Requiring that you designate 100% of your Policy Value to the designated Investment Options, some of which employ strategies that are intended to reduce the risk of loss and/or manage volatility, may reduce investment returns and may reduce the likelihood that we will be required to use our own assets to pay amounts due under this benefit.	N/A	N/A	• AB Balanced Hedged Allocation Portfolio - Class B • American Funds - Asset Allocation Fund^SM - Class 2 • American Funds - The Bond Fund of America^SM - Class 2 • Fidelity^® VIP Balanced Portfolio - Service Class 2 • Franklin Allocation VIP Fund - Class 4 • State Street Total Return V.I.S. Fund - Class 3 • TA Aegon U.S. Government Securities - Service Class • TA American Funds Managed Risk - Balanced - Service Class

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POLICY VARIATIONS — (Continued)

Product Feature	Landmark 2002 - Revised Form Number: AV720 101 148 102	Landmark 2003 Form Number: AV920 101 168 603	Landmark 2008 Form Number: AV920 101 168 603
			• TA BlackRock Government Money Market - Service Class • TA BlackRock iShares Active Asset Allocation - Conservative - Service Class • TA BlackRock iShares Edge 40- Service Class • TA BlackRock iShares Edge 50 - Service Class • TA BlackRock iShares Edge 75 - Service Class • TA BlackRock iShares Edge 100 - Service Class • TA JPMorgan Asset Allocation - Conservative - Service Class • TA JPMorgan Asset Allocation - Moderate Growth - Service Class • TA JPMorgan Asset Allocation - Moderate - Service Class • TA JPMorgan International Moderate Growth - Service Class • TA Managed Risk - Balanced ETF - Service Class • TA Managed Risk - Conservative ETF - Service Class • TA Managed Risk - Growth ETF - Service Class • TA MSCI EAFE Index - Service Class • TA Multi-Managed Balanced - Service Class • TA PIMCO Total Return - Service Class • TA S&P 500 Index - Service Class
Death Proceeds	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.	Greatest of (a) Policy Value, (b) Cash Value, and (c) guaranteed minimum death benefit.
Mortality & Expense Risk Fee and Administrative Charge prior to Annuity Commencement Date	• B-Share: 1.30% for Return of Premium • 1.50% for Annual Step Up • 1.80% for Double Enhanced • L-Share (Optional Liquidity Rider): 1.80% for Return of Premium (Years 1-4) • 1.30% for Return or Premium (Years 5+) • 2.00% for Annual Step Up (Years 1-4) • 1.50% for Annual Step-Up (Years 5+)	• B-Share: 1.30% for Return of Premium • 1.50% for Annual Step Up • 1.80% for Double Enhanced • L-Share (Optional Liquidity Rider): 1.80% for Return of Premium (Years 1-4) • 1.30% for Return or Premium (Years 5+) • 2.00% for Annual Step Up (Years 1-4) • 1.50% for Annual Step-Up (Years 5+)	• B-Share: 1.30% for Return of Premium • 1.50% for Annual Step Up • 1.95% for Double Enhanced • L-Share (Optional Liquidity Rider): 1.80% for Return of Premium (Years 1-4) • 1.30% for Return or Premium (Years 5+) • 2.00% for Annual Step Up (Years 1-4) • 1.50% for Annual Step-Up (Years 5+)

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POLICY VARIATIONS — (Continued)

Product Feature	Landmark 2002 - Revised Form Number: AV720 101 148 102	Landmark 2003 Form Number: AV920 101 168 603	Landmark 2008 Form Number: AV920 101 168 603
	• 2.30% for Double Enhanced (Years 1-4) • 1.80% for Double Enhanced (Years 5+)	• 2.30% for Double Enhanced (Years 1-4) • 1.80% for Double Enhanced (Years 5+)	• 2.45% for Double Enhanced (Years 1-4) • 1.95% for Double Enhanced (Years 5+)
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 - • 0.30% if you choose American Funds - Asset Allocation Fund, American Funds - The Bond Fund of America, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. • 0.20% if you choose AB Balanced Wealth Strategy Portfolio or State Street Total Return V.I.S. Fund. • 0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund.	Yes - • 0.30% if you choose American Funds - Asset Allocation Fund, American Funds - The Bond Fund of America, American Funds - Growth Fund, American Funds - Growth-Income Fund, or American Funds - International Fund. • 0.20% if you choose AB Balanced Wealth Strategy Portfolio or State Street Total Return V.I.S. Fund. • 0.15% if you choose Franklin Templeton VIP Founding Funds Allocation Fund, TA International Equity Index or TA U.S. Equity Index.
Guaranteed Period Options (available in the Fixed Account)	1, 3, 5, and 7 year guaranteed periods available.	1, 3, 5, and 7 year guaranteed periods available.	1, 3, 5, and 7 year guaranteed periods available.
Annual Contract Charge (Service Charge)	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.	If Policy Value is: $0-$1,750 = 2% $1,751-$49,999.99 = $35 + $49,999.99 = $0 Assessed either on a policy anniversary or on surrender. The service charge is deducted pro-rata from the Investment Options.
Distribution Financing Charge	N/A	N/A	N/A
Liquidity (L-Share) Optional Rider	Available	Available	Available
Optional Riders	• Managed Annuity Program • 5 for Life^SM 2005 • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Income Select^SM for Life • Retirement Income Choice^® • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution • Additional Death Distribution+ • Additional Death Distribution 2003	• 5 for Life 2005^SM • 5 for Life^SM with Growth • 5 for Life^SM Growth with Death Benefit • Income Select^SM 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 Max^® • Living Benefits Rider 2003 • Living Benefits Rider 2005 • Additional Death Distribution+ • Additional Death Distribution 2003	• Retirement Income Choice^® • Retirement Income Choice^® 2008 (with Double Withdrawal Base Benefit) • Retirement Income Choice^® 1.2 • Retirement Income Choice^® 1.4 • Retirement Income Choice^® 1.6 • Income Link^SM • Retirement Income Max^SM • Living Benefits Rider 2005 • Additional Death Distribution+ • Additional Death Distribution 2003

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APPENDIX

Excess Interest Adjustment Examples

Surrenders (full and partial), transfers, death benefits and amounts applied to an annuity 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 the guaranteed interest rate set by the Company has risen since the date of the initial guarantee, the Excess Interest Adjustment will result in a lower Cash Value. However, if the guaranteed interest rate set by us has 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
M	=	Number of months remaining in the current option period, rounded up to the next higher whole number of months.
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% (the amount of the “adjustment” will be based on an actuarial risk based analysis considering a number of financial criteria including the prevailing interest rate environment).
*	=	multiplication

The following examples are for illustrative purposes only and are calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal. In the following examples ^ denotes exponentiation. Please note the exponentiation represents the compounding of the interest rate.

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Excess Interest Adjustment Examples — (Continued)

Example 1 (Full Surrender, rates increase by 3%):

Assumptions:

Single premium payment = $50,000

Guaranteed period = 5 Years

Guarantee rate = 5.5% per annum

Current Rate = 8.5% per annum

Guaranteed minimum interest rate = 1.50%

Surrender in the middle of Policy Year 2

Summary:
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 S(G-C)(M/12) where:	G = .055 C = .085 M = 42 = 50,000.00 * (0.055 * 0.085) * (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.

Example 2 (Full Surrender, rates decrease by 1%):

Assumptions:

Single premium payment = $50,000

Guaranteed period = 5 Years

Guarantee rate = 5.5% per annum

Current Rate = 4.5% per annum

Guaranteed minimum interest rate = 1.50%

Surrender in the middle of Policy Year 2

Summary:
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 S* (G-C)* (M/12) where:	G = .055 C = .045 M = 42 = 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.

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Excess Interest Adjustment Examples — (Continued)

On a withdrawal, the Company will pay the policyholder the full amount of withdrawal requested (as long as the Policy Value is sufficient). Amounts withdrawn will reduce the Policy Value by an amount equal to:

R - E + SC
R	=	the requested withdrawal;
E	=	the Excess Interest Adjustment; and
SC	=	the Surrender Charges on (EPW - E): where
EPW	=	the excess partial withdrawal amount.

Example 3 (Withdrawal, rates increase by 1%):

Assumptions:

Single premium payment = $50,000

Guaranteed period = 5 Years

Guarantee rate = 5.5% per annum

Current rate = 6.5% per annum

Withdrawal of $20,000 in the middle of Policy Year 2

Summary:
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(G-C)(M/12) where:	S = 20,000 – 4,181.21 = 15,818.79 G = .055 C = .065 M = 42 = 15,818.79 * (.055 - .065) * (42/12) = -553.66
Remaining Policy Value at middle of Policy Year 2	= 54,181.21 - (R - E + Surrender Charge) = 54,181.21 - (20,000.00 - (-553.66) + 0.00) = 33,627.55

Example 4 (Partial Withdrawal, rates decrease by 1%):

Assumptions:

Single premium payment = $50,000

Guaranteed period = 5 Years

Guarantee rate = 5.5% per annum

Current rate = 4.5% per annum

Partial Withdrawal of $20,000 in the middle of Policy Year 2

Summary:
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(G-C)(M/12) where:	S = 20,000 – 4,181.21 = 15,818.79 G = .055 C = .045 M = 42 = 15,818.79 * (.055 - .045)* (42/12) = 553.66
Remaining Policy Value at middle of Policy Year 2	= 54,181.21 - (R - E + Surrender Charge) = 54,181.21 - (20,000.00 – 553.66 + 0.00) = 34,734.87

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APPENDIX

Death Benefit

Adjusted Withdrawals. If You take a withdrawal, then Your guaranteed minimum death benefit is reduced by an amount called the adjusted withdrawal. The amount of the reduction depends on the relationship between Your Death Proceeds and Policy Value. The adjusted withdrawal is equal to the gross withdrawal multiplied by the Death Proceeds immediately prior to the withdrawal divided by the Policy Value immediately prior to the withdrawal. The formula is AW = GW x (DP/PV) where:

AW = adjusted withdrawal

GW= gross withdrawal

DP = Death Proceeds prior to the withdrawal = greatest of (PV, CV, or GMDB)

PV = Policy Value prior to the withdrawal

GMDB = guaranteed minimum death benefit prior to the withdrawal

CV = Cash Value prior to the withdrawal

The following examples describe the effect of a surrender on the guaranteed minimum death benefit and Policy Value.

Example 1: Death Proceeds Greater than Policy Value

Assumptions:

GMDB = $75,000

PV = $50,000

DP = $75,000

GW = $15,494

AW = $15,494 x ($75,000/$50,000) = $23,241

Summary:
Reduction in guaranteed minimum death benefit	=$23,241
Reduction in Policy Value	=$15,494
New guaranteed minimum death benefit amount	=$51,759
New Policy Value (after withdrawal)	=$34,506

The guaranteed minimum death benefit is reduced more than the Policy Value because the guaranteed minimum death benefit was greater than the Policy Value immediately prior to the withdrawal.

Example 2: Death Proceeds Equal to Policy Value

Assumptions:

GMDB = $50,000

PV = $75,000

DP = $75,000

GW = $15,494

AW = $15,494 x ($75,000/$75,000) = $15,494

Summary:
Reduction in guaranteed minimum death benefit	=$15,494
Reduction in Policy Value	=$15,494
New guaranteed minimum death benefit amount	=$34,506
New Policy Value (after withdrawal)	=$59,506

The guaranteed minimum death benefit and Policy Value are reduced by the same amount because the Policy Value was greater than the guaranteed minimum death benefit immediately prior to the withdrawal.

These examples are for illustrative purposes only. The purpose of these illustrations is to demonstrate how this feature is calculated using hypothetical values. Your experience will vary based on circumstances at the time of withdrawal.

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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. The difference between the two “Policy Value” columns is the fee for the guaranteed minimum death benefit.

End of Year	Net Rate of Return*	Policy Value (No GMDB Elected)	Policy Value (Return of Premium GMDB Elected)	Return of Premium GMDB	Policy Value (Annual Step-up GMDB Elected)	Annual Step-Up GMDB
Issue	N/A	$100,000	$100,000	$100,000	$100,000	$100,000
1	-4%	$ 94,850	$ 94,700	$100,000	$ 94,500	$100,000
2	18%	$110,832	$110,515	$100,000	$110,093	$110,093
3	15%	$126,182	$125,655	$100,000	$124,955	$124,955
4	-7%	$115,899	$115,226	$100,000	$114,334	$124,955
5	2%	$116,884	$116,033	$100,000	$114,905	$124,955
6	10%	$127,228	$126,127	$100,000	$124,672	$124,955
7	14%	$143,577	$142,146	$100,000	$140,257	$140,257
8	-3%	$137,618	$136,033	$100,000	$133,945	$140,257
9	17%	$159,431	$157,391	$100,000	$154,706	$154,706
10	6%	$167,163	$164,788	$100,000	$161,668	$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. For purposes of this example we assumed a Mortality and Expense Risk Fee and Administrative Charge of 1.15% for Policy Value, 1.30% for Return of Premium and 1.50% for Annual Step-Up. Different hypothetical returns and fees would produce different results.

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APPENDIX

ADDITIONAL DEATH DISTRIBUTION^SM RIDER – No longer available

The following example illustrates the Additional Death Distribution^SM additional death benefit payable by this rider as well as the effect of a withdrawal on the Additional Death Distribution^SM benefit amount. The Annuitant is less than age 71 on the Rider Date.

Example 1

Assumptions:

Policy Value on the rider date = $100,000

Premiums paid after the rider date before surrender = $25,000

Gross withdrawals after the rider date = $30,000

Policy Value on date of surrender = $150,000

Summary:
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 (assumed) 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

Assumptions:

Policy Value on the rider date = $100,000

Premiums paid after the rider date before surrender = $0

Gross withdrawals after the rider date = $0

Base Policy death benefit (assumed) on the date of death benefit calculation = $100,000

Policy Value on the date of death benefit calculations = $75,000

Summary:
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

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APPENDIX

ADDITIONAL DEATH DISTRIBUTION+^SM RIDER – no longer available

Assume the Additional Death Distribution+^SM rider is added to a new Policy opened with $100,000 initial premium payment. The Annuitant is less than age 70 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 a $25,000 premium payment 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

Assumptions:

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

Summary:
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)	$115,000.00
Rider benefit base in 3rd rider year after premium addition (= $140,000 - $25,000)	$115,000.00
Rider benefit base in 4th rider year prior to withdrawal (= account value less premiums added since rider date = $145,000 - $25,000)	$120,000.00
Rider benefit base in 4th rider year after withdrawal = (account value less premiums added since rider date =$110,000 - $25,000)	$ 85,000.00
Rider benefit base in 5th rider year (= $130,000 - $25,000)	$105,000.00
Additional death benefit = rider benefit percentage * rider benefit base = 30% * $105,000	$ 31,500.00
Total Death Proceeds in 5th rider year (= base Policy Death Proceeds + additional death benefit amount = $145,000 + $31,500)	$176,500.00

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APPENDIX

LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS

The following examples show the effect of withdrawals on the benefits under the Living Benefits Rider which is no longer available to elect.

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.

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

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LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

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:

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

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)

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LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

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

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.

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LIVING BENEFITS RIDER ADJUSTED PARTIAL WITHDRAWALS — (Continued)

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.

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.

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

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APPENDIX

PAM METHOD TRANSFERS

NOTE: The Living Benefits rider is no longer available to elect. For previously elected riders, 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 and threshold amounts, transfers into or out of the PAM Subaccount may 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

G = 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 may occur based on the transfer threshold amounts.

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.

♦	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.

♦	The FIXED ACCOUNT TRANSFER THRESHOLD (FATT) is the percentage that the Guarantee Ratio must be below before any of the Policy Value can be transferred to the PAM Subaccount. This threshold is set to a fixed percentage at rider issue and is then recalculated after each PAM Subaccount transfer.

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PAM METHOD TRANSFERS — (Continued)

♦	The SEPARATE ACCOUNT TRANSFER THRESHOLD (SATT) is the percentage that the Guarantee Ratio must exceed before any of the Policy Value can be transferred from the PAM Subaccount. This threshold is set to a fixed percentage at rider issue and is then recalculated after each PAM Subaccount transfer.

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

FATT = 95

SATT = 105%

First we calculate d1.

d1=[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

d1=[ln(.90)+(.06 – .0305 +.5*.15 ^ 2)* 10]/[.15 * 10^.5]

d1=.658832

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 ^ -.0305 * 10) * (1 – NormDist(.004509))

X = 36.7235%

Therefore, 36.7235% of the Policy Value is transferred to the PAM Subaccount since the guarantee ratio (90%) is less than the FATT (95%), resulting in a total transfer of $33,051.15.

Day 2: Policy Value Recovers to 99% 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 $99,000 producing a guarantee ratio of 99% ($99,000/$100,000). We will also assume:

Rate = 2%

Volatility = 15%

Fees = 3.05%

Time = 10

FATT = 85.5% (G last transfer *.95) = (.9*.95)

SATT = 94.5% (G last transfer *1.05) = (.9*1.05)

PAM Subaccount Value = $33,051.15

Value in other Investment Options = $65,948.85 ($99,000 - $33,051.15)

PAM Subaccount Value as percent of Policy Value = $33,051.15 / $99,000 = 33.3850%

First we calculate d1.

d1=[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

d1=[ln(.99)+(.02 – .0305 +.5*.15 ^ 2)* 10]/[.15 * 10^.5]

d1= -.005376

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 ^ -.0305 * 10) * (1 – NormDist(-0.005376))

X = 37.0143%

Although the GR is greater than the SATT, since the percentage required in the PAM Subaccount (37.0143%) is greater than the amount allocated to the PAM Subaccount (33.3850%), none of the Policy Value will be transferred to the PAM Subaccount. Consequently, the amount in the PAM Subaccount will remain $33,051.15 and the FATT And SATT will not recalculate.

Day 3: Policy Value Recovers to 105% of Initial Value after the increase to 99% of Initial Value

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PAM METHOD TRANSFERS — (Continued)

For purposes of this example we will assume that after the Policy Value recovered further the next to $105,000 producing a guarantee ratio of 105% ($105,000/$100,000). We will also assume:

Rate = 3%

Volatility = 15%

Fees = 3.05%

Time = 10

FATT = 85.5%

SATT = 94.5%

PAM Subaccount Value = $33,051.15

Value in other Investment Options = $71,948.85 ($105,000 - $33,051.15)

PAM Subaccount Value as percent of Policy Value = $33,051.15 / $105,000 = 31.4773%

First we calculate d1.

d1=[ln(G)+(R – F +.5*V ^ 2)* T]/[V * T^.5]

d1=[ln(1.05)+(.03 – .0305 +.5*.15 ^ 2)* 10]/[.15 * 10^.5]

d1= .329488

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 ^ -.0305 * 10) * (1 – NormDist(.329488))

X = 27.3394%

While the mathematical model would suggest we transfer only a portion of the Policy Value in the PAM Subaccount into your Investment Options (leaving 27.3394% 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%. Because the 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.

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APPENDIX

Hypothetical Adjusted withdrawals -Guaranteed Lifetime Withdrawal Benefit Riders

This appendix explains the material features of the 5 For Life^SM, 5 For Life^SM with Growth, 5 For Life^SM with Growth and Death, Income Select^SM for Life, Retirement Income Choice^®, Retirement Income Choice^® with Double Withdrawal Base Benefit, Retirement Income Choice^® 1.4, Retirement Income Choice^® 1.2, Retirement Income Max^® and Retirement Income Choice^® 1.6 riders. These riders are no longer available to elect.

When a withdrawal is taken, three parts of the Guaranteed Lifetime Withdrawal Benefit can be affected:

1.	Withdrawal Base (“WB”) (also referred to as Total Withdrawal Base (“TWB”) for some riders);
2.	Rider Withdrawal Amount (“RWA”) (also referred to as Maximum Annual Withdrawal Amount (“MAWA”) for some riders); and
3.	Rider Death Benefit (“RDB”) (also referred to as Minimum Remaining Withdrawal Amount (“MRWA”) for some riders (if applicable)).

Withdrawal Base. Gross withdrawals in a rider year up to the rider withdrawal amount will not reduce the withdrawal base. Gross 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 withdrawal amount; and
2)	a pro rata amount, the result of (A / B) * C, where:

A	is the excess 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.

Rider Death Benefit. Gross 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 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 withdrawal amount; and
2)	a pro rata amount, the result of (A / B) * C, where:

A	is the excess gross 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 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 withdrawals under a Guaranteed Lifetime Withdrawal Benefit. The withdrawal percentages shown may not be available on all riders. Certain features (growth and rider death benefits) may not be available on all riders. For information regarding a specific rider, please refer to that rider section in this prospectus.

Example 1 (Base):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

RWA = 5% withdrawal would be $5,000 (5% of the current $100,000 withdrawal base)

Gross withdrawal (“GPWD”) = $5,000

Excess withdrawal (“EWD”) = None

Policy Value (“PV”) = $100,000

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.

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Hypothetical Adjusted withdrawals -Guaranteed Lifetime Withdrawal Benefit

Riders — (Continued)

Example 2 (Excess Withdrawal):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

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

NOTE. 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. 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 = $2,352.94

Step Three. Which is larger, the actual $2,000 excess withdrawal or the $2,352.94 pro rata amount?

$2,352.94 pro rata amount.

Step Four. What is the new withdrawal base upon which the rider withdrawal amount is based?

$100,000 - $2,352.94 = $97,647.06

Result. The new withdrawal base is $97,647.06

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 calendar anniversary. This calculation assumes no more activity prior to the next calendar anniversary.

Question: What is the new rider withdrawal amount?

$97,647.06 (the adjusted withdrawal base) * 5% = $4,882.35

Result. Going forward, the maximum You can take out in a year is $4,882.35 without causing an excess withdrawal for the guarantee and further reduction of the withdrawal base (assuming there are no future automatic step-ups).

Example 3 (Base demonstrating growth):

Assumptions:

WB = $100,000

Withdrawal Percentage = 5%

WB in 10 years (assuming an annual growth rate percentage of 5.0%) = $100,000 * (1 + .05) ^ 10 = $162,889

RWA = 5% withdrawal beginning 10 years from the rider date would be $8,144 (5% of the then-current $162,889 withdrawal base)

Please Note: Withdrawals under these riders can begin prior to the 10th rider anniversary, but the WB growth will not occur during the rider years when a withdrawal is taken, and the growth stops on the 10th rider anniversary.

GPWD = $8,144

EWD = None

PV = $90,000 in 10 years

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 $8,144 is withdrawn.

Result. In this example, because no portion of the withdrawal was in excess of $8,144, the withdrawal base does not change.

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Hypothetical Adjusted withdrawals -Guaranteed Lifetime Withdrawal Benefit

Riders — (Continued)

Example 4 (Base demonstrating WB growth with Additional Death Payment Option):

Assumptions:

Withdrawal Percentage = 5%

WB at rider issue = $100,000

WB in 10 years (assuming an annual growth rate percentage of 5%) = $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 = $8,144

EWD = None

PV = $90,000 in 10 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 $8,144 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 $8,144 (there is no excess to deduct)
2.	$100,000 - $8,144 = $91,856.

Result. In this example, because no portion of the withdrawal was in excess of $8,144, the total withdrawal base does not change and the rider death benefit reduces to $91,856.

Example 5 (Base with WB growth with Additional Death Payment Option illustrating excess withdrawal):

Assumptions:

Withdrawal Percentage = 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%) = $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)

Please Note: Withdrawals under these riders can begin prior to the 10th rider anniversary, but the WB growth will not occur during the rider years when a withdrawal is taken and the growth stops on the 10th rider anniversary.

GPWD = $10,000

EWD = $1,856 ($10,000 - $8,144)

PV = $90,000 in 10 years

Step One. Is any portion of the total withdrawal greater than the rider withdrawal amount?

Yes. $10,000 - $8,144 = $1,856 (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.	($1,856 / ($90,000 - $8,144)) * ($100,000 - $8,144) = $2,082.74

Step Three. Which is larger, the actual $1,856 excess withdrawal amount or the $2,082.74 pro rata amount?

$2,082.74 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) + $2,082.74 (pro rata excess) = $10,226.74
2.	$100,000 - $10,226.74 = $89,773.26.

Result. The rider benefit is $89,773.26.

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APPENDIX

Hypothetical Example of the Withdrawal Base Calculation -Retirement Income Max^® rider

The Retirement Income Max^® rider can no longer be elected. The following table demonstrates, on a purely hypothetical basis, the withdrawal base calculation for the Retirement Income Max^® 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. The assumed withdrawal percentage in the example below is 6.30%

Rider Year	Hypothetical Policy Value	Subsequent Premium Payment	Withdrawal	Excess WB Adjustment	Growth Amount*	High Monthiversary^SM Value	Withdrawal Base	Rider Withdrawal Amount
	$100,000	$	$	$	$	$100,000	$100,000	$ 6,300
1	$102,000	$	$	$	$	$102,000	$100,000	$ 6,300
1	$105,060	$	$	$	$	$105,060	$100,000	$ 6,300
1	$107,161	$	$	$	$	$107,161	$100,000	$ 6,300
1	$110,376	$	$	$	$	$110,376	$100,000	$ 6,300
1	$112,584	$	$	$	$	$112,584	$100,000	$ 6,300
1	$115,961	$	$	$	$	$115,961	$100,000	$ 6,300
1	$118,280	$	$	$	$	$118,280	$100,000	$ 6,300
1	$121,829	$	$	$	$	$121,829	$100,000	$ 6,300
1	$124,265	$	$	$	$	$124,265	$100,000	$ 6,300
1	$120,537	$	$	$	$	$124,265	$100,000	$ 6,300
1	$115,716	$	$	$	$	$124,265	$100,000	$ 6,300
1	$109,930	$	$	$	$105,000	$124,265	$124,265 ¹	$ 7,829
2	$112,129	$	$	$	$	$112,129	$124,265	$ 7,829
2	$115,492	$	$	$	$	$115,492	$124,265	$ 7,829
2	$117,802	$	$	$	$	$117,802	$124,265	$ 7,829
2	$121,336	$	$	$	$	$121,336	$124,265	$ 7,829
2	$124,976	$	$	$	$	$124,976	$124,265	$ 7,829
2	$177,476	$50,000	$	$	$	$177,476	$174,265	$10,979
2	$175,701	$	$	$	$	$177,476	$174,265	$10,979
2	$172,187	$	$	$	$	$177,476	$174,265	$10,979
2	$167,022	$	$	$	$	$177,476	$174,265	$10,979
2	$163,681	$	$	$	$	$177,476	$174,265	$10,979
2	$166,955	$	$	$	$	$177,476	$174,265	$10,979
2	$170,294	$	$	$	$182,979	$177,476	$182,979 ²	$11,528
3	$166,888	$	$	$	$	$166,888	$182,979	$11,528
3	$171,895	$	$	$	$	$171,895	$182,979	$11,528
3	$173,614	$	$	$	$	$173,614	$182,979	$11,528
3	$178,822	$	$	$	$	$178,822	$182,979	$11,528
3	$175,246	$	$	$	$	$178,822	$182,979	$11,528
3	$151,741	$	$20,000	$9,676	$	$	$173,303	$
3	$154,775	$	$	$	$	$	$173,303	$
3	$159,419	$	$	$	$	$	$173,303	$
3	$161,013	$	$	$	$	$	$173,303	$
3	$165,843	$	$	$	$	$	$173,303	$
3	$174,135	$	$	$	$	$	$173,303	$

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APPENDIX

Guaranteed Lifetime Withdrawal BenefitAdjusted withdrawals - Income Link^SM Rider - No Longer Available

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^SM rider Systematic Withdrawals (“ILSW”)

Withdrawal Base. Income Link^SM rider Systematic Withdrawals (and certain minimum required distributions) will not reduce the withdrawal base. Non-Income Link^SM 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^SM 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^SM 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^SM rider systematic withdrawal occurs during the second Income Link^SM rider withdrawal year (which means the withdrawal percentage is 6%).

Result. For the Guaranteed Lifetime Withdrawal Benefit, because there was a non-Income Link^SM rider systematic withdrawal, the withdrawal base needs to be adjusted and a new lower rider withdrawal amount and Income Link^SM rider systematic withdrawal amount calculated.

New withdrawal base:

Step One. The withdrawal base is reduced only by the amount of the non-Income Link^SM rider systematic withdrawal or the pro rata amount, if greater.

Step Two. Calculate how much the withdrawal base is affected by the non-Income Link^SM 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^SM 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^SM rider systematic withdrawal) we have to calculate a new (remaining) rider withdrawal amount. This calculation assumes no more non-Income Link^SM rider systematic withdrawal activity prior to the next Income Link^SM rider withdrawal year.

Question: What is the new (remaining) rider withdrawal amount for the remainder of the Income Link^SM rider withdrawal year?

$3,000 (the remaining rider withdrawal amount) - ($3,000*11.11%) = $2,667

144

The information in this Statement of Additional Information is not complete and may be changed. This Statement of Additional Information is contained in a registration statement filed with the Securities and Exchange Commission and we may not sell these securities until that registration statement is effective. This Statement of Additional Information is not an offer to sell these securities and is not soliciting an offer to buy these securities in any state where the offer or sale is not permitted.

STATEMENT OF ADDITIONAL INFORMATION

TRANSAMERICA LANDMARK^SM VARIABLE ANNUITY

Issued through

SEPARATE ACCOUNT VA B

Offered by

TRANSAMERICA LIFE INSURANCE COMPANY

This Statement of Additional Information expands upon subjects discussed in the current prospectus for the Transamerica Landmark^SM Variable Annuity offered by Transamerica Life Insurance Company. You may obtain a copy of the current prospectus, dated May 1, 2022, by calling (800)525-6205, or write us at: Transamerica Life Insurance Company, Attention: Customer Care Group, 6400 C Street SW, Cedar Rapids, IA 52499. 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 have the same meaning.

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, 2022

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Information About Us

We are engaged in the sale of life and health insurance and annuity policies. 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. and is licensed in all states and the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands. We are 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.

All obligations arising under the policies, including the promise to make annuity payments, are general corporate obligations of ours. Accordingly, no financial institution, brokerage firm or insurance agency is responsible for our financial obligations arising under the policies.

The Separate Accounts

Separate Account VA B (the “Separate Account”), 6400 C Street S.W., Cedar Rapids, Iowa, was established by the Company on January 19, 1990, and is a unit investment trust registered with the SEC and operating under Iowa law. The Separate Account has various Subaccounts each of which invests solely in a corresponding Portfolio of the Fund.

The Separate Accounts are registered with the SEC as unit investment trusts under the 1940 Act (the “1940 Act”). However, the SEC does not supervise the management, the investment practices, or the policies of the separate accounts.

Cyber Security (continued from “Principal Risks” section of the Prospectus)

Our operations support complex transactions and are highly dependent on the proper functioning of information technology and communication systems. Any failure of our information technology or communications systems may result in a material adverse effect on our results of operations and corporate reputation.

Any failure of or gap in the systems and processes necessary to support complex transactions and avoid systems failure, fraud, information security failures, processing errors, cyber intrusion, loss of data and breaches of regulation may lead to a materially adverse effect on our results of operations and corporate reputation. In addition, we must commit significant resources to maintain and enhance our existing systems in order to keep pace with applicable regulatory requirements, industry standards and customer preferences. If we fail to maintain secure and well-functioning information systems, we may not be able to rely on information for product pricing, compliance obligations, risk management and underwriting decisions. In addition, we cannot assure investors or consumers that interruptions, failures or breaches in security of these processes and systems will not occur, or if they do occur, that they can be timely detected and remediated. The occurrence of any of these events may have a materially adverse effect on our businesses, results of operations and financial condition.

A computer system failure or security breach may disrupt our business, damage our reputation and adversely affect our operational results, financial condition and cash flows.

We rely heavily on computer and information systems and internet and network connectivity to conduct a large portion of our business operations. This includes the need to securely store, process, transmit and dispose of confidential information, including personal information, through a number of complex systems. In many cases this also includes transmission and processing to or through commercial customers, business partners (semi-) governmental agencies and third-party service providers. The introduction of new technologies, computer system failures, cyber-crime attacks or security or data privacy breaches may materially disrupt our business operations, damage our reputation, result in regulatory and litigation exposure, investigation and remediation costs, and materially and adversely affect our results of operations, financial condition and cash flows.

The information security risk that we face includes the risk of malicious outside forces using public networks and other methods, including social engineering and the exploitation of targeted offline processes, to attack our systems and information. It also includes inside threats, both malicious and accidental. For example, human error, unauthorized user activity and lack of sufficiently automated processing can result in improper information exposure or use. We also face risk in this area due to our reliance in many cases on third-party systems, all of which may face cyber and information security risks of their own. Third-party administrators or distribution partners used by us or our affiliates may not adequately secure their own information systems and networks, or may not adequately keep pace with the dynamic changes in this area. Potential bad actors that target us and our applicable third parties may include, but are not limited to, criminal organizations, foreign government bodies, political factions, and others.

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In recent years information security risk has increased sharply due to a number of developments in how information systems are used by companies such as us, but also by society in general. Threats have increased as criminals and other bad actors become more organized and employ more sophisticated techniques. At the same time companies increasingly make information systems and data available through the internet, mobile devices or other network connections to customers, employees and business partners, thereby expanding the attack surface that bad actors can exploit.

Large, global financial institutions such as us have been, and will continue to be subject to information security attacks for the foreseeable future. The nature of these attacks will also continue to be unpredictable, and in many cases may arise from circumstances that are beyond our control. Especially if and to the extent we fail to adequately invest in defensive infrastructure, timely response capabilities, technology and processes or to effectively execute against our information security strategy, we may suffer material adverse consequences.

To date the highest impact information security incidents that we have experienced are believed to have been the result of e-mail phishing attacks targeted at our business partners and commercial customers. This in turn led to unauthorized use of valid website credentials to engage in fraudulent transactions and improper data exfiltration. Additionally, we have also faced other types of attacks, including but not limited to other types of phishing attacks and distributed denial of service (DDoS) attacks, as well as certain limited cases of unauthorized internal user activity, including activity between other units of Aegon. Although to our knowledge these events have thus far not been material in nature, our management recognizes the need to establish and maintain adequate information security systems that are capable of addressing the possibility of these types of attacks, as well as for the possibility of more significant and sophisticated information security attacks, in the future. There is no guarantee that the measures that we take will be sufficient to stop all types of attacks or mitigate all types of information security or data privacy risks.

We maintain cyber liability insurance to help decrease the impact of cyber-attacks and information security events, subject to the terms and conditions of the policy, however such insurance may not be sufficient to cover all applicable losses that we may suffer.

A breach of data privacy or security obligations may disrupt our business, damage our reputation and adversely affect financial conditions and results of operations.

Pursuant to applicable laws, various government agencies and independent administrative bodies have established numerous rules protecting the privacy and security of personal information and other confidential information held by us. For example, our businesses are subject to laws and regulations enacted by U.S. federal and state governments, including various regulatory organizations relating to the privacy and/or security of the information of customers, employees or others. These laws, among other things, increased compliance obligations, impacted our businesses’ collection, processing and retention of personal data, reporting of data breaches, and provide for penalties for non-compliance. For example, the New York Department of Finance Services (NYDFS), pursuant to its cybersecurity regulation, requires financial institutions regulated by the NYDFS, including certain of our entities, to, among other things, satisfy an extensive set of minimum cyber security requirements, including but not limited to governance, management, reporting, policy, technology and control requirements. Numerous other U.S. laws also impose various information security and privacy related obligations with respect to various Company affiliates operating in the U.S., including but not limited to the Gramm-Leach-Bliley Act and related state laws (GLBA), the California Consumer Privacy Act (CCPA) and the Health Insurance Portability and Accountability Act (HIPAA), among many others. Other legislators and regulators with jurisdiction over our businesses are considering, or have already enacted, enhanced information security risk management and privacy rules and regulations. A number of our entities and affiliates are also subject to contractual restrictions with respect to the information of our clients and business partners. The Company, and numerous of its, employees and business partners have access to, and routinely process, the personal information of consumers and employees. We rely on a large number of processes and controls to protect the confidentiality, integrity and availability of personal information and other confidential information that is accessible to, or in the possession of, us, our systems, employees and business partners. It is possible that an employee, business partner or system could, intentionally or unintentionally, inappropriately disclose or misuse personal or confidential information. Our data or data in our possession could also be the subject of an unauthorized information security attack. If we fail to maintain adequate processes and controls or if we or our business partners fail to comply with relevant laws and regulations, policies and procedures, misappropriation or intentional or unintentional inappropriate disclosure or misuse of personal information or other confidential information could occur. Such control inadequacies or non-compliance could cause disrupted operations and misstated or unreliable financial data, materially damage our reputation or lead to increased regulatory scrutiny or civil or criminal penalties or (class action) litigation, which, in turn, could have a material adverse effect on our business, financial condition and results of operations. In addition, we analyze personal information and customer data to better manage our business, subject to applicable laws and regulations and other restrictions. It is possible that additional regulatory or other restrictions regarding the use of such techniques may be imposed. Additional privacy and information security obligations have been imposed by various governments with jurisdiction over the Company or its affiliates in recent years, and more such obligations are likely to be imposed in the near future across our operations. Such restrictions and obligations could have material impacts on our business, financial conditions and/or results of operations.

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In addition, we analyze personal information and customer data to better manage our business subject to applicable laws and regulations and other restrictions. It is possible that additional regulatory or other restrictions regarding the use of such techniques may be imposed. Additional privacy and information security obligations have been imposed by various governments with jurisdiction over Transamerica or its subsidiaries in recent years, and more such obligations are likely to be imposed in the near future across our operations. Such restriction and obligations could have material impacts on our business, financial conditions and/or results of operations.

For a complete description regarding Transamerica’s policies for its websites, including the Privacy Policy and Terms of Use for such websites, please visit: www.transamerica.com/individual/privacy-policy and www.transamerica.com/individual/terms-of-use.

In order to supplement the description in the prospectus, the following provides additional information about the 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 our 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 we have 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 we have made or action we have taken before recording the change. Changing the Owner does not change the designation of the Beneficiary or the Annuitant.

Entire Contract

The entire contract consists of the policy and any application, endorsements and riders. If any portion of the policy or rider attached thereto shall be found to be invalid, unenforceable or illegal, the remainder shall not in any way be affected or impaired thereby, but shall have the same force and effect as if the invalid, unenforceable or illegal portion had not been inserted.

Misstatement of Age or Sex

During the Accumulation Phase. If the age of any person whose life or age a benefit provided under a guaranteed benefit has been misstated, any such benefit will be that which would have been purchased on the basis of the correct age. If that person would not have been eligible for that guaranteed benefit at the correct age, (i) the benefit will be rescinded; and (ii) any charges that were deducted for the benefit will be refunded and applied to the total account value of the policy.

We reserve the right to terminate the contract at any time if we discover a misstatement or fraudulent representation of any information provided in connection with the issuance or ongoing administration of the policy.

After the Annuity Commencement Date. We may require proof of the Annuitant’s or Owner’s age and/or sex before any payments associated with any benefits are made. If the age or sex of the Annuitant and/or Owner has been misstated, we will change the payment associated with any benefits payable to that which the Premium Payments would have purchased for the correct age or sex. The dollar amount of any underpayment made by us shall be paid in full with the next payment due such person, Beneficiary, or payee. The dollar amount of any overpayment made by us due to any misstatement shall be deducted from payments subsequently accruing to such person or Beneficiary. Any underpayment or overpayment will include interest specified in Your policy, 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 us.

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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, we reserve the right to include the value of those Annuity Units as part of the transfer. The request must be in writing to our Administrative 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 us in good order 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 life income with variable payments for 10 years certain using the existing policy value of the separate account. These default options may be restricted with respect to qualified policies.

The person who elects an annuity payment option can also name one or more successor payees to receive any unpaid amount we have 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 us in writing and we agree.

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 “Annuity 2000” (male, female and unisex if required by law) mortality table projected for improvement using projection scale G. The rates were projected dynamically using an assumed annuity commencement date of 2005. The “Annuity 2000” mortality rates are adjusted based on improvements in mortality to more appropriately reflect increased longevity. 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. For certain qualified policies the use of unisex mortality tables may be required.

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 and Federal 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 or any other proof satisfactory to us will constitute due proof of death. If the annuitant dies after the annuity commencement date, no death benefit is payable and the amount payable will depend on the annuity income option.

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Upon receipt in good order of this proof and an election of a method of settlement, the death benefit generally will be paid within seven days, or as soon thereafter as we have sufficient information about the beneficiary(ies) to make the payment. The death benefit may be paid as a lump sum, as annuity payments or as otherwise permitted by the Company in accordance with applicable law 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.

Beneficiary. The beneficiary designation in the enrollment form will remain in effect until changed. The owner may change the designated beneficiary by sending us written notice. 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 us. We 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 the TAX INFORMATION section in the prospectus 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 us until a copy has been filed at its Administrative Office. Your rights and benefits and those of the beneficiary are subject to the rights of the assignee. We assume 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 us, 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

We reserve 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 we receive such evidence.

Non-Participating

The policy will not share in our surplus earnings; no dividends will be paid.

Amendments

No change in the policy is valid unless made in writing by us and approved by one of our officers. No registered representative has authority to change or waive any provision of the policy.

We reserve 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.

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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 ours or our affiliated companies or their immediate family. In such a case, we in our discretion, may credit an amount equal to a percentage of each premium payment to the policy due to lower acquisition costs we experience on those purchases. We 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 we are 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), 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).

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 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 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.

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The net investment factor for any subaccount for any valuation period is determined by dividing (A + B - C) by (D) and subtracting (D) from the result, where the net result of:

A	the net asset value per share of the shares held in the subaccount determined at the end of the current valuation period, plus
B	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
C	a per share credit or charge for any taxes determined by us to have resulted during the valuation period from the investment operations of the subaccount;
D	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
E	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
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 1.95% on an annual basis; On a daily basis, this equals 0.000052912.

Then, the net investment factor =	(11.57 + 0 – 0)	- 0.000052912 = Z = 1.014859369
	(11.40)

Formula for Determining Accumulation Unit Value

Accumulation Unit Value = A * B
Where:
A =	The accumulation unit value for the immediately preceding valuation period.
	Assume A = $X
B =	The net investment factor for the current valuation period.
	Assume B = 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 we determine 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.

Calculations for Annuity Unit

Value and Variable Annuity Payments

Formula for Determining Annuity Unit Value

Annuity Unit Value = A * B * C
Where:
A =	Annuity unit value for the immediately preceding valuation period.
	Assume A = $X
B =	Net investment factor for the valuation period for which the annuity unit value is being calculated.
	Assume B = Y
C =	A factor to neutralize the annual assumed investment return of 5% built into the Annuity Tables used.
	Assume C = Z
Then, the annuity unit value is: $X * Y * Z = $Q

Formula 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 A = $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 B = $Y

Then, the first monthly variable annuity payment =	$X * $Y	= $Z
	1,000

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Formula 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 A = $X
B =	The annuity unit value for the valuation date on which the first monthly payment is due.
	Assume B = $Y

Then, the number of annuity units =	$X	= Z
	$Y

HISTORICAL PERFORMANCE DATA

Money Market Yields

We 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 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 8% 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.

We 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.

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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.

Total Returns

We 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 we calculate 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

We 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%.

We 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.

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.

services

We perform administrative services for the policies. These services include issuance of the policies, maintenance of records concerning the policies, and certain valuation services.

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RECORDS AND REPORTS

All records and accounts relating to the separate account will be maintained by us. As presently required by the 1940 Act, as amended, and regulations promulgated thereunder, we 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 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 we send 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 1800 California St. Suite 5200 Denver, Colorado 80202. 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.

The policies were 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 2020, 2019 and 2018 the amounts paid to TCI in connection with all policies sold through the separate account were $55,370,914, $57,243,595 and $62,731,496, respectively.

We and/or TCI or another affiliate may pay certain selling firms additional cash amounts for: (1) marketing allowances, 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. Differences in compensation paid to a selling firm or its sales representatives for selling one product over another may create conflicts of interests for such firms or its sales representatives.

CUSTODY OF ASSETS

We hold 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 our general account assets. We maintain 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 our fidelity bond, presently in the amount of $5,000,000, covering the acts of our officers and employees.

INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To be filed by amendment.

FINANCIAL STATEMENTS

To be filed by amendment

The values of Your interest in the Separate Account will be affected solely by the investment results of the selected Subaccount(s). The statutory-basis financial statements and schedules of Transamerica Life Insurance Company should be considered only as bearing on our ability to meet our 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

Prior Withdrawal/ Growth Percentages and Rider Fees

The table below identifies the prior percentages for the Retirement Income Max^® rider.

Rider fee Percentages

Date		Percentage
Prior to February 1, 2018		1.25%
February 1, 2018 to June 30, 2018		1.35%

Date	Single Life	Joint Life
July 1, 2018 to November 30, 2019	1.35%	1.45%
December 1, 2019 to April 30, 2020	1.45%	1.55%
May 1, 2020 to April 30, 2021	1.50%	1.60%

Growth Percentages

Date		Percentage
Prior to May 1, 2014		5.00%
May 1, 2014 to January 31, 2018		5.50%
February 1, 2018 to April 30, 2020		7.20%
May 1, 2020 to August 31, 2020		6.50%
September 1, 2020 to April 30, 2021		5.00%

Withdrawal Percentages

Date	Age at time of first withdrawal	Singe Life Percentage	Joint Life Percentage
Prior to December 12, 2011	0-58 59-64 65-74 ≥75	0.00% 4.50% 5.50% 6.50%	0.00% 4.10% 5.10% 6.10%
December 12, 2011 to May 1, 2014	0-58 59-64 65-79 ≥80	0.00% 4.30% 5.30% 6.30%	0.00% 3.80% 4.80% 5.80%
May 1, 2014 to February 16, 2015	0-58 59-64 65-79 ≥80	0.00% 4.30% 5.30% 6.30%	0.00% 4.00% 5.00% 6.00%
February 17, 2015 to December 31, 2016	0-58 59-64 65-79 ≥80	0.00% 4.20% 5.20% 6.20%	0.00% 3.80% 4.80% 5.80%
January 1, 2017 to January 31, 2018	0-58 59-64 65-79 ≥80	0.00% 4.20% 5.20% 6.20%	0.00% 3.70% 4.70% 5.70%
February 1, 2018 to June 30, 2018	0-58 59-64 65-79 ≥80	0.00% 4.00% 5.00% 6.00%	0.00% 3.50% 4.50% 5.50%

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APPENDIX

Prior Withdrawal/Growth Percentages and rider fees

The table below identifies the prior percentages for the Retirement Income Choice^® 1.6 rider.

Rider fee Percentages

Date	Rider Benefit	Single Life Option	Joint Life Option
June 1, 2017 to June 30, 2018	Base Benefit Designated Allocation Group A	1.45%	1.45%
	Base Benefit Designated Allocation Group B	1.10%	1.10%
	Base Benefit Designated Allocation Group C	0.70%	0.70%
	Death Benefit	0.40%	0.35%
	Income Enhancement	0.30%	0.50%

Date	Rider Benefit	Single Life Option	Joint Life Option
July 1, 2018 to February 28, 2019	Base Benefit Designated Allocation Group A	1.40%	1.50%
	Base Benefit Designated Allocation Group B	1.15%	1.25%
	Base Benefit Designated Allocation Group C	0.80%	0.90%
	Death Benefit	0.40%	0.35%
	Income Enhancement	0.30%	0.50%

Date	Rider Benefit	Single Life Option	Joint Life Option
March 1, 2019 to August 31, 2020	Base Benefit Designated Allocation Group A	1.50%	1.60%
	Base Benefit Designated Allocation Group B	1.50%	1.60%
	Base Benefit Designated Allocation Group C	1.50%	1.60%
	Death Benefit	0.40%	0.35%
	Income Enhancement	0.30%	0.50%

Date	Rider Benefit	Single Life Option	Joint Life Option
September 1, 2020 to April 30, 2021	Base Benefit Designated Allocation Group A	1.85%	1.95%
	Base Benefit Designated Allocation Group B	1.40%	1.50%
	Base Benefit Designated Allocation Group C	0.95%	1.05%
	Death Benefit	0.40%	0.35%
	Income Enhancement	0.30%	0.50%

Growth Percentages

Date		Percentage
May 1, 2016 to February 28, 2019		5.50%
March 1, 2019 to November 30, 2019		6.00%
December 1, 2019 to April 30, 2020		5.25%
May 1, 2020 to April 30, 2021		5.00%

Withdrawal Percentages

Date		Age at time of first withdrawal		Singe Life Percentage		Joint Life Percentage
May 1, 2016 to December 31, 2016		0-58 59-64 65-79 ≥80		0.00% 4.00% 5.00% 6.00%		0.00% 3.75% 4.75% 5.75%

Item 28. Directors and Officers of the Depositor (Transamerica Life Insurance Company)


Name and Business Address		Principal Positions and Offices with Depositor

Blake S. Bostwick 1801 California St. Suite 5200 Denver, CO 80202		Director, Chief Executive Officer and President

Fred Gingerich 6400 C Street SW Cedar Rapids, Iowa 52499		Director, Chairman of the Board, Controller, Assistant Treasurer and Vice President

Karyn Polak 100 Light Street Baltimore, MD 21202		Director, General Counsel, Secretary and Senior Vice President

Matthew McCorry 6400 C Street SW Cedar Rapids, Iowa 52499		Director, Chief Operating Officer, Individual Solutions Division

Christopher Ashe 100 Light Street Baltimore, MD 21202		Chief Financial Officer, Executive Vice President and Treasurer

Zachary Harris 6400 C Street SW Cedar Rapids, Iowa 52499		Director

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 1933 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.

Transamerica Capital, Inc. serves as the principal underwriter for the Retirement Builder Variable Annuity Account, Separate Account VA B, Separate Account VA Q, Separate Account VA FF, Separate Account VA HH, 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, 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, Separate Account VA BB, Separate Account VA CC, Separate Account VA U, Separate Account VA V, Separate Account VA AA, WRL Series Annuity Account, WRL Series Annuity Account B, WRL Series Life Account, WRL Series Life Account G, WRL Series Life Corporate Account and Separate Account VL E. 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 QNY, TFLIC Separate Account VNY, Separate Account VA-2LNY, TFLIC Separate Account C, Separate Account VA-5NLNY, Separate Account VA-6NY, TFLIC Series Annuity Account, TFLIC Series Life Account, TFLIC Pooled Account No. 44, Transamerica Variable Funds, 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 and ML of New York Variable Life Separate Account II. These accounts are separate accounts of Transamerica Financial Life Insurance Company.

Transamerica Capital, Inc. also serves as principal underwriter for Transamerica Series Trust, Transamerica Funds and Transamerica Asset Allocation Variable Funds.

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 6400 C Street SW, Cedar Rapids, Iowa 52499.

The Depositor hereby represents that the fees and charges deducted under the contracts, in the aggregate, are reasonable in relation to

the services rendered, the expenses expected to be incurred, and the risks assumed by the Depositor.

Transamerica Life Insurance Company 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.

Transamerica relies on 17 C.F.R. Sec. 270.6c-7 and represents that the provisions of that Rule have been or will be complied with.

As required by the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant has duly caused this Registration Statement to be signed on its behalf by the undersigned, duly authorized, in the City of Denver and State of Colorado, on January 14, 2022.

As required by the Securities Act of 1933, this Registration Statement has been signed by the following persons in the capacities indicated on January 14, 2022.


Signatures		Title

* Blake S. Bostwick		Director, Chief Executive Officer and President (principal executive officer)

* Fred Gingerich		Director, Chairman of the Board, Controller, Vice President and Assistant Treasurer (principal accounting officer)

* Matthew McCorry		Director, Chief Operating Officer, Individual Solutions Division

* Karyn Polak		Director, General Counsel, Secretary and Senior Vice President

* Christopher Ashe		Chief Financial Officer, Executive Vice President and Treasurer (principal financial officer)

* Zachary Harris		Director

/s/Brian Stallworth Brian Stallworth		Assistant Secretary

*By: Brian Stallworth – Attorney-in-Fact pursuant to Powers of Attorney filed previously and/or herewith.

	CONFLICT OF INTEREST	Location in Prospectus
Investment Professional Compensation	Your investment professional may receive compensation for selling this Policy to You, in the form of commissions, additional cash benefits (e.g., bonuses), and non-cash compensation. Our affiliate, Transamerica Capital, Inc. (“TCI”) is the principal underwriter and may share the revenue we earn on this Policy with Your investment professional’s firm. In addition, we may pay all or a portion of the cost of affiliates’ operating and other expenses. This conflict of interest may influence Your investment professional to recommend this Policy over another investment for which the investment professional is not compensated or compensated less.	Distribution of the Policies
Exchanges	If You already own an insurance Policy, some investment professionals may have a financial incentive to offer You a new Policy in place of the one You own. You should only exchange a Policy you already own if You determine, after comparing the features, fees, and risks of both policies, that it is better for You to purchase the new Policy rather than continue to own Your existing Policy.	Exchanges and/or Reinstatements

⁽¹⁾	Automatic Step Up Applied
⁽²⁾	Growth Applied
*	Growth Percentage = 5%


Exhibit No:		Description

(a)		Board of Directors Resolution

(a)(1)		Resolution of the Board of Directors of PFL Life Insurance Company authorizing establishment of the Separate Account. Note 1 P

(a)(2)		Authorization Changing Name of the Separate Account. Note 2

(b)		Custodian Agreements. Not applicable.

(c)		Underwriting Contracts

(c)(1)		Principal Underwriting Agreement by and between PFL Life Insurance Company, on its own behalf and on the behalf of the Separate Account, and MidAmerica Management Corporation. Note 3 P

(c)(2)		Principal Underwriting Agreement by and between PFL Life Insurance Company, on its own behalf and on behalf of the Separate Account, and AFSG Securities Corporation. Note 4

(c)(3)		Termination of Principal Underwriting Agreement by and between AEGON USA Securities, Inc., formerly known as MidAmerica Management Corporation, and PFL Life Insurance Company on its own behalf and on the behalf of PFL Endeavor Variable Annuity Account. Note 5

(c)(4)		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 6

(c)(5)		Amendment No. 8 and Novation to Amended and Restated Principal Underwriting Agreement. Note 7

(c)(6)		Amendment No. 10 to Amended and Restated Principal Underwriting Agreement. Note 8

(c)(7)		Amended and Reinstated Principal Underwriting Agreement. Note 9

(d)		Contracts

(d)(1)		Policy for the Endeavor Variable Annuity. Note 3 P

(d)(2)		Policy Endorsement (Required Distributions). Note 3 P

(d)(3)		Policy Endorsement (Death Benefits). Note 10 P

(d)(4)		Policy Endorsement (Nursing Care). Note 11 P

(d)(5)		Policy Endorsement (Death Benefit). Note 12

(d)(6)		Policy for the Endeavor Variable Annuity. Note 13

(d)(7)		Policy Endorsement (Nursing Care). Note 13

(d)(8)		Policy for the Endeavor FI Variable Annuity. Note 14


(d)(9)		Policy Endorsement for the Endeavor FI (Nursing Care). Note 14

(d)(10)		Policy Endorsement for the Endeavor Variable Annuity. (Nursing Care) Note 14

(d)(11)		Policy for the Endeavor Variable Annuity. Note 4

(d)(12)		Policy Endorsement (New Separate Accounts and Annuity Commencement Date). Note 4

(d)(13)		Policy Rider for the PFL Endeavor Variable Annuity and the PFL Endeavor ML Variable Annuity (GMIB) Note 5

(d)(14)		Policy Endorsement for the PFL Endeavor Variable Annuity and the PFL Endeavor ML Variable Annuity (403(b) Loan). Note 15

(d)(15)		Group Master Policy and Optional Riders for the Endeavor Variable Annuity. Note 16

(d)(16)		Group Certificate for the Endeavor Variable Annuity. Note 16

(d)(17)		Individual Policy for the Endeavor Variable Annuity. Note 16

(d)(18)		Policy for the Separate Account VA B. Note 17

(d)(19)		Policy Rider (Additional Death Distribution). Note 17

(d)(20)		Policy Endorsement (Initial Payment Guarantee). Note 17

(d)(21)		Policy Rider (Managed Annuity Program) Note 18

(d)(22)		Individual Policy for the Separate Account VA B. Note 19

(d)(23)		Policy Rider (Liquidity Rider). Note 19

(d)(24)		Policy Rider (MAP II) Note 19

(d)(25)		Policy Rider (GPS) Note 20

(d)(26)		Policy Rider (5 for Life) Note 20

(d)(27)		Rider (ADD+) Note 21

(d)(28)		Rider (5 for Life-Growth - without Death Benefit) Note 22

(d)(29)		Rider (5 for Life with Growth - with Death Benefit) Note 22

(d)(30)		Rider (Income Select for Life). Note 20

(d)(31)		Rider (Double Enhanced). Note 23

(d)(32)		Rider (Retirement Income Choice). Note 20

(d)(33)		Endorsement (Fund Facilitation Fee). Note 24

(d)(34)		Policy Rider (Retirement Income Choice- Double withdrawal Base Benefit). Note 20

(d)(35)		Policy Rider (Retirement Income Choice 1.2). Note 20

(d)(36)		Policy Rider (Retirement Income Choice 1.4). Note 20


(d)(37)		Policy Rider (Income Link). Note 20

(d)(38)		Policy Rider (RIM). Note 20

(d)(39)		Policy Rider (Retirement Income Choice 1.6). Note 9

(e)		Applications

(e)(1)		Application for the Endeavor Variable Annuity. Note 14

(e)(2)		Application for the Endeavor FI Variable Annuity. Note 14

(e)(3)		Application for the Endeavor ML Variable Annuity. Note 14

(e)(4)		Application for the PFL Endeavor Variable Annuity. Note 4

(e)(5)		Application for the PFL Endeavor Variable Annuity. Note 5

(e)(6)		Application for the PFL Endeavor ML Variable Annuity. Note 5

(e)(7)		Group Master Application for the Endeavor Variable Annuity. Note 16

(e)(8)		Application for Transamerica Landmark Note 17

(e)(9)		Application for Transamerica Landmark ML. Note 17

(e)(10)		Application for Transamerica Landmark. Note 19

(e)(11)		Application for Transamerica Landmark with Merrill Lynch Funds. Note 19

(e)(12)		Application. Note 25

(e)(13)		Application Note 26

(f)		Depositor’s Certificate of Incorporation and By-laws

(f)(1)		Articles of Incorporation of PFL Life Insurance Company. Note 3 P

(f)(2)		Articles of Incorporation of Transamerica Life Insurance Company. Note 27

(f)(3)		Articles of Incorporation of Transamerica Life Insurance Company. Note 28

(f)(4)		Bylaws of PFL Life Insurance Company. Note 3 P

(f)(5)		Bylaws of Transamerica Life Insurance Company. Note 27

(g)		Reinsurance Contracts

(g)(1)		Reinsurance Agreement. Note 29

(g)(2)		Reinsurance agreement between Transamerica Life Insurance & Annuity Company and Swiss RE Life & Health America Inc. dated January 2, 1998. Note 30

(g)(3)		Reinsurance agreement between Transamerica Occidental Life Insurance Company and North American Reassurance Company dated July 1, 1994. Note 30


(g)(4)		Reinsurance Agreement No. FUV-1 between Transamerica Life Insurance Company and Union Hamilton Reinsurance Limited dated April 1, 2001. Note 30

(g)(5)		Reinsurance agreement Amendment No. 1 to agreement FUV-1 between Transamerica Life Insurance Company and Union Hamilton Reinsurance Limited dated April 1, 2001. Note 30

(g)(6)		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 30

(g)(7)		Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 31, 2008. Note 30

(g)(8)		Amendment No. 1 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 30, 2008. Note 31

(g)(9)		Amendment No. 2 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated December 29, 2009. Note 31

(g)(10)		Amendment No. 3 to Reinsurance Agreement between Transamerica Life Insurance Company and Transamerica International RE (Bermuda) LTD dated May 27, 2010. Note 31

(g)(11)		Assignment, Transfer and Novation Agreement by and among Transamerica International RE (Bermuda) Ltd., Firebird Re Corp. and Transamerica Life Insurance Company. Note 32

(g)(12)		Reinsurance Agreement between American United Life Insurance Company and Transamerica Life Insurance Company dated July 1, 2007. Note 30

(g.13)		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 33

(g)(14)		Reinsurance Agreement between Firebird Re Corp. and Transamerica Life Insurance Company. Note 32

(h)		Participation Agreements

(h)(1)		Participation Agreement by and between PFL Life Insurance Company and Endeavor Series Trust. Note 3 P

(h)(2)		Participation Agreement by and between PFL Life Insurance Company and Merrill Lynch Asset Management L.P. for the Endeavor ML Variable Annuity Note 14

(h)(2)(i)		Amendment to Participation Agreement (BlackRock). Note 34

(h)(2)(ii)		Amendment No 1. to Participation Agreement (BlackRock). Note 34

(h)(2)(iii)		Amendment of Agreements (BlackRock). Note 34

(h)(2)(iv)		Amendment No 3 to Participation Agreement (BlackRock). Note 35

(h)(3)		Amendment to Participation Agreement by and between PFL Life Insurance Company and Endeavor Series Trust. Note 14

(h)(3)(i)		Amendment No. 6 to Participation Agreement by and between PFL Life Insurance Company, Endeavor Management Co. and Endeavor Series Trust. Note 36


(h)(3)(ii)		Amendment to Schedule A of the Participation Agreement by and between PFL Life Insurance Company and Endeavor Series Trust. Note 37

(h)(3)(iii)		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 19

(h)(4)		Participation Agreement by and between Janus Aspen Series and PFL Life Insurance Company. Note 38

(h)(4)(i)		Amendment No. 2 to Participation Agreement by and between Janus Aspen Series and PFL Life Insurance Company. Note 37

(h)(4)(ii)		Amendment No. 12 to Fund Participation Agreement (Janus Aspen Series). Note 31

(h)(4)(iii)		Amendment No. 13 to Fund Participation Agreement (Janus Aspen Series). Note 39

(h)(4)(iv)		Amendment No. 3 to Participation Agreement (Janus). Note 40

(h)(4)(v)		Amendment No. 14 to Participation Agreement (Janus). Note 41

(h)(5)		Participation Agreement by and among Alliance Variable Products Series Fund, PFL Life Insurance Company, AFSG Securities Corporation. Note 42

(h)(5)(i)		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 43

(h)(5)(ii)		Amendment to Participation Agreement (Alliance Bernstein). Note 8

(h)(5)(iii)		Amendment to Participation Agreement (Alliance Bernstein). Note 44

(h)(5)(iv)		Amendment No. 13 to Participation Agreement (AllianceBernstein). Note 35

(h)(5)(v)		Amended Schedule A to Participation Agreement dated May 1, 2015 (AllianceBernstein). Note 20

(h)(5)(vi)		Amended Schedule A to Participation Agreement dated May 1, 2017 (AllianceBernstein). Note 45

(h)(5)(vii)		Amended Schedule A to Participation Agreement dated May 1, 2020 (AllianceBernstein). Note 46

(h)(6)		Participation Agreement by and among AIM Variable Insurance funds, Inc., AIM Distributors, Inc., PFL Life Insurance Company and AFSG Securities Corporation Note 47

(h)(6)(i)		Amendment No. 7 to Participation Agreement among AIM Variable Insurance Funds, AIM Distributors, Inc., Transamerica Life Insurance Company and AFSG Securities Corporation. Note 48

(h)(6)(ii)		Amendment to Participation Agreement (AIM/INVESCO). Note 49

(h)(6)(iii)		Amendment Participation Agreement (AIM/INVESCO). Note 31

(h)(6)(iv)		Amendment No. 21 to Participation Agreement (AIM/INVESCO). Note 50

(h)(6)(v)		Amendment No. 12 to Participation Agreement (AIM/INVESCO). Note 40

(h)(6)(vi)		Amendment No. 18 to Participation Agreement (AIM/INVESCO). Note 40

(h)(6)(vii)		Amendment No. 22 to Participation Agreement (AIM/INVESCO). Note 51


(h)(7)		Participation Agreement among MFS Variable Insurance Trust, PFL Life Insurance Company and Massachusetts Financial Services Company. Note 52

(h)(7)(i)		Partial Termination of Participation Agreement among MFS Variable Insurance Trust, PFL Life Insurance Company and Massachusetts Financial Services Company. Note 18

(h)(7)(ii)		Amended and Restated Participation Agreement by and among MFS Variable Insurance Trust, Massachusetts Financial Services Company, and Transamerica Life Insurance Company. Note 19

(h)(7)(iii)		Amendment No. 3 to the Amended and Restated Participation Agreement dated July 1, 2001 by and among the MFS Variable Insurance Trust, Massachusetts Financial Service Company and Transamerica Life Insurance Company. Note 19

(h)(7)(iv)		Addendum to Participation Agreement (MFS). Note 32

(h)(8)		Participation Agreement among STI Classic Variable Trust, SEI Investment Distribution Company, Trustco Capital Management, Inc. and PFL Life Insurance Company. Note 53

(h)(8)(i)		Amendment No. 1 to Participation Agreement by and among STI Classic Variable Trust. SEI Investments Distribution Company, Trustco Capital Management, Inc. and PFL Life Insurance Company. Note 53

(h)(9)		Participation Agreement between MTB Group of Funds, Edgewood Services, Inc., MTB Investment Advisors, Inc., Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company. Note 53

(h)(9)(i)		Amendment No. 1 to the Participation Agreement (MTB Group of Funds). Note 21

(h)(10)		Amended and Restated Participation Agreement among Fidelity Distributors Corporation and Transamerica Life Insurance Company. Note 54

(h)(10)(i)		Amendment No. 7 to Participation Agreement (Fidelity Distributors Corporation) Note 34

(h)(10)(ii)		Amendment No. 8 to Participation Agreement (Fidelity). Note 55

(h)(10)(iii)		Amended Schedule A to Participation Agreement dated May 1, 2017 (Fidelity). Note 45

(h)(10)(iv)		Amended Schedule A to Participation Agreement dated May 1, 2020 (Fidelity). Note 46

(h)(11)		Amended and Restated Participation Agreement (Franklin Templeton). Note 30

(h)(11)(i)		Amendment No. 3 to Participation Agreement (Franklin Templeton). Note 8

(h)(11)(ii)		Amendment No. 4 to Participation Agreement (Franklin Templeton). Note 31

(h)(11)(iii)		Amendment No. 5 to Participation Agreement (Franklin Templeton). Note 39

(h)(11)(iv)		Amendment No. 2 to Participation Agreement (Franklin). Note 40

(h)(11)(v)		Amendment to Participation Agreement (Franklin). Note 40

(h)(11)(vi)		Amendment to Participation Agreement January 15, 2013 (Franklin). Note 40

(h)(11)(vii)		Amendment No. 8 to Amended and Restated Participation Agreement (Franklin). Note 55

(h)(11)(viii)		Amendment No. 9 to Amended and Restated Participation Agreement (Franklin). Note 51

(h)(11)(ix)		Amendment No. 10 to Amended and Restated Participation Agreement (Franklin). Note 35


(h)(11)(x)		Amendment No.11 to Participation Agreement (Franklin). Note 56

(h)(12)		Amendment No. 1 to Participation Agreement among Huntington VA Funds and Transamerica Life Insurance Company. Note 57

(h)(12)(i)		Amendment No. 2 to Participation Agreement (Huntington). Note 30

(h)(12)(ii)		Amended and Restated Supplement Late Day Transmission Agreement 2007. Note 34

(h)(12)(iii)		Amended and Restated Supplemental Late Day Transmission Agreement 2008. Note 34

(h)(12)(iv)		Huntington Novation Agreement 2009. Note 34

(h)(12)(v)		Huntington Amendment of Agreements 2011. Note 34

(h)(12)(vi)		Amended and Restated Supplement Late Day Transmission Agreement 2012. Note 34

(h)(12)(vii)		Amendment to Participation Agreement (Huntington). Note 34

(h)(12)(viii)		Amendment No. 4 to Participation Agreement (Huntington). Note 55

(h)(12)(ix)		Amended Schedule A to Participation Agreement (Huntington). Note 35

(h)(12)(x)		Amended Schedule A to Participation Agreement dated May 16, 2014 (Huntington). Note 35

(h)(12)(xi)		Amended Schedule A to Participation Agreement dated March 6, 2015 (Huntington). Note 20

(h)(12)(xii)		Amended Schedule A to Participation Agreement dated November 1, 2018 (Huntington). Note 58

(h)(13)		Participation Agreement among Transamerica Life Insurance Company; American Funds Insurance Series, and Capital Research and Management Company (“CRMC”). Note 59

(h)(13)(i)		Amendment No. 2 to Participation Agreement (American Funds). Note 59

(h)(13)(ii)		Amendment No. 4 to Participation Agreement (American Funds). Note 59

(h)(13)(iii)		Amendment No. 8 to Participation Agreement (American Funds). Note 60

(h)(13)(iv)		Amendment No. 9 to Participation Agreement (American Funds). Note 56

(h)(13)(v)		Amendment No. 10 to Participation Agreement (American Funds). Note 61

(h)(13)(vi)		Amendment No. 11 to Participation Agreement (American Funds). Note 45

(h)(13)(vii)		Amendment No. 12 to Participation Agreement (American Funds). Note 46

(h)(14)		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 59

(h)(14)(i)		Amendment No. 1 to Participation Agreement (GE). Note 44

(h)(14)(ii)		Amendment No. 2 to Participation Agreement (GE). Note 55

(h)(14)(iii)		Amendment No. 3 to Participation Agreement (GE/SSGA). Note 62

(h)(15)		Amended and Restated Participation Agreement (TST). Note 40


(h)(15)(i)		Amendment No. 1 to Participation Agreement (TST). Note 55

(h)(15)(ii)		Amended Schedule A to Participation Agreement dated September 18, 2013 (TST). Note 63

(h)(15)(iii)		Amended Schedule A to Participation Agreement dated May 1, 2014 (TST). Note 35

(h)(15)(iv)		Amendment No. 2 to Participation Agreement (TST). Note 56

(h)(15)(v)		Amended Schedule A to Participation Agreement dated May 1, 2015 (TST). Note 20

(h)(15)(vi)		Amended Schedule A to Participation Agreement dated July 1, 2015 (TST). Note 64

(h)(15)(vii)		Amended Schedule A to Participation Agreement dated December 18, 2015 (TST). Note 32

(h)(15)(viii)		Amended Schedule A to Participation Agreement dated March 21, 2016 (TST). Note 32

(h)(15)(ix)		Amended Schedule A to Participation Agreement dated May 1, 2016 (TST). Note 32

(h)(15)(x)		Amended Schedule A to Participation Agreement dated December 16, 2016 (TST). Note 65

(h)(15)(xi)		Amended Schedule A to Participation Agreement dated May 1, 2017 (TST). Note 45

(h)(15)(xii)		Amended Schedule A to Participation Agreement dated September 29, 2017 (TST). Note 66

(h)(15)(xiii)		Amended Schedule A to Participation Agreement dated May 1, 2018 (TST). Note 67

(h)(15)(xiv)		Amended Schedule A to Participation Agreement dated November 1, 2018 (TST). Note 67

(h)(15)(xv)		Amended Schedule A to Participation Agreement dated May 1, 2020 (TST). Note 46

(i)		Administrative Contracts. Not applicable.

(j)		Other Material Contracts. Not applicable.

(k)		Legal Opinion. Opinion and Consent of Counsel. To be filed by amendment.

(l)		Other Opinions. Consent of Independent Registered Public Accounting Firm. To be filed by amendment.

(m)		Omitted Financial Statements. Not applicable

(n)		Initial Capital Agreements. Not applicable

(o)		Form of Initial Summary Prospectuses. Not applicable.

(p)		Powers of Attorney. Filed herewith.


Note 1.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration Statement (File No. 33-33085) filed on January 23, 1990.

Note 2.		Incorporated herein by reference to Post-Effective Amendment No. 11 to Form N-4 Registration Statement (File No. 33-33085) filed on April 24, 1996

Note 3.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 33-33085) filed on April 1, 1991.


Note 4.		Incorporated herein by reference to Post-Effective Amendment No. 14 to Form N-4 Registration Statement (File No. 33-33085) filed on February 27, 1998.

Note 5.		Incorporated herein by reference to Post-Effective Amendment No. 16 to Form N-4 Registration Statement (File No. 33-33085) filed on September 28, 1998.

Note 6.		Incorporated herein by reference to Post-Effective Amendment 30 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 2002.

Note 7.		Incorporated herein by reference to Post-Effective Amendment No. 41 to Form N-4 Registration Statement (File No. 33-33085) filed on April 26, 2007.

Note 8.		Incorporated herein by reference to Post-Effective Amendment No. 44 to Form N-4 Registration Statement (File No. 33-33085) filed on November 6, 2008.

Note 9.		Incorporated herein by reference to Pre-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-185573) filed on April 10, 2013.

Note 10.		Incorporated herein by reference to Post-Effective Amendment No. 3 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 1992.

Note 11.		Incorporated herein by reference to Post-Effective Amendment No. 10 to Form N-4 Registration Statement (File No. 33-33085) filed on April 27, 1995.

Note 12.		Incorporated herein by reference to Post-Effective Amendment No. 7 to Form N-4 Registration Statement (File No. 33-33085) filed on March 29, 1994.

Note 13.		Incorporated herein by reference to Post-Effective Amendment No. 12 to Form N-4 Registration Statement (File No. 33-33085) filed on February 28, 1997.

Note 14.		Incorporated herein by reference to Post-Effective Amendment No. 13 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 1997.

Note 15.		Incorporated herein by reference to Post-Effective Amendment No. 17 to Form N-4 Registration Statement (File No. 33-33085) filed on January 25, 1999.

Note 16.		Incorporated herein by reference to Post-Effective Amendment No. 21 to Form N-4 Registration Statement (File No. 33-33085) filed on April 27, 2000.

Note 17.		Incorporated herein by reference to Post-Effective Amendment No. 25 to Form N-4 Registration Statement (File No. 33-33085) filed on April 27, 2001.

Note 18.		Incorporated herein by reference to Post-Effective Amendment No. 8 to Form N-4 Registration Statement (File No. 333-7509) filed on April 29, 1999.

Note 19.		Incorporated herein by reference to Post-Effective Amendment No. 31 to Form N-4 Registration Statement (File No. 33-33085) filed on October 15, 2002.

Note 20.		Incorporated herein by reference to Post-Effective Amendment No. 64 to Form N-4 Registration Statement (File No. 33-33085) filed on April 24, 2015.

Note 21.		Incorporated herein by reference to Post-Effective Amendment No. 37 to Form N-4 Registration Statement (File No. 33-33085) filed on April 27, 2005.

Note 22.		Incorporated herein by reference to Post-Effective Amendment No. 39 to Form N-4 Registration Statement (File No. 33-33085) filed on December 12, 2005.


Note 23.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-131987) filed on September 21, 2007.

Note 24.		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 25.		Incorporated herein by reference to Post-Effective Amendment No. 34 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 2003.

Note 26.		Incorporated herein by reference to Post-Effective Amendment No. 9 to Form N-4 Registration Statement (File No. 333-142762) filed on August 31, 2009.

Note 27.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration (File No. 333-62738) filed on June 11, 2001.

Note 28.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration Statement (File No. 333-169445) filed on September 17, 2010.

Note 29.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-109580) filed on January 7, 2005.

Note 30.		Incorporated herein by reference to Post-Effective Amendment No. 45 to this Form N-4 Registration Statement (File No. 33-33085) filed on April 30, 2009.

Note 31.		Incorporated herein by reference to Post-Effective Amendment No. 50 to Form N-4 Registration Statement (File No. 33-33085) filed on February 15, 2011.

Note 32.		Incorporated herein by reference to Post-Effective Amendment No. 65 to Form N-4 Registration Statement (File No. 33-33085) filed on April 25, 2016.

Note 33.		Incorporated herein by reference to Post-Effective Amendment No. 48 to Form N-4 Registration Statement (File No. 33-33085) filed on April 23, 2010.

Note 34.		Incorporated herein by reference to Post-Effective Amendment No. 57 to Form N-4 Registration Statement (File No. 33-33085) filed on September 10, 2012.

Note 35.		Incorporated herein by reference to Post-Effective Amendment No. 63 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 2014.

Note 36.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration Statement for the Access Variable Annuity (File No. 333-94489) filed on January 12, 2000.

Note 37.		Incorporated herein by reference to Post-Effective Amendment 22 to Form N-4 Registration Statement (File No. 33-33085) filed on October 3, 2000.

Note 38.		Incorporated herein by reference to Post-Effective Amendment No. 3 to Form N-4 Registration Statement (File No. 333-26209) filed on April 28, 2000.

Note 39.		Incorporated herein by reference to Post-Effective Amendment No. 54 to Form N-4 Registration Statement (File No. 33-33085) filed on April 17, 2012.

Note 40.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration Statement (File No. 333-187910) filed on April 15, 2013.

Note 41.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-187911) filed on April 29, 2014.


Note 42.		Incorporated herein by reference to Post-Effective Amendment No. 3 to Form N-4 Registration Statement (File No. 333-26209) filed on April 28, 2000.

Note 43.		Incorporated herein by reference to Post-Effective Amendment No. 26 to Form N-4 Registration Statement (File No. 33-33085) filed on October 2, 2001.

Note 44.		Incorporated herein by reference to Post-Effective Amendment No. 21 to Form N-4 Registration Statement (File No. 333-125817) filed on October 7, 2011.

Note 45.		Incorporated herein by reference to Post-Effective Amendment No. 9 to Form N-4 Registration Statement (File No. 333-185573) filed on April 24, 2017.

Note 46.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-233836) filed on July 30, 2020.

Note 47.		Incorporated herein by reference to Post-Effective Amendment No. 5 to Form N-4 Registration Statement (File No. 333-7509) filed on July 16, 1998.

Note 48.		Incorporated herein by reference to Pre-Effective Amendment No. 1 to Form N-4 Registration Statement (File No. 333-76230) filed on April 29, 2002.

Note 49.		Incorporated herein by reference to Post-Effective Amendment No. 49 to Form N-4 Registration Statement (File No. 33-33085) filed on August 6, 2010.

Note 50.		Incorporated herein by reference to Post-Effective Amendment No. 52 to Form N-4 Registration Statement (File No. 33-33085) filed on October 7, 2011.

Note 51.		Incorporated herein by reference to Post-Effective Amendment No. 61 to Form N-4 Registration Statement (File No. 33-33085) filed on October 17, 2013.

Note 52.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-7509) filed on December 23, 1997.

Note 53.		Incorporated herein by reference to Post-Effective Amendment No. 36 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 2004.

Note 54.		Incorporated herein by reference to Post-Effective Amendment No. 40 to Form N-4 Registration Statement (File No. 33-33085) filed on April 27, 2006.

Note 55.		Incorporated herein by reference to Post-Effective Amendment No. 59 to Form N-4 Registration Statement (File No. 33-33085) filed on August 16, 2013.

Note 56.		Incorporated herein by reference to Post-Effective Amendment No. 67 to Form N-4 Registration Statement (File No. 33-56908) filed on December 30, 2014.

Note 57.		Incorporated herein by reference to Post-Effective Amendment No. 42 to Form N-4 Registration Statement (File No. 33-33085) filed on December 21, 2007.

Note 58.		Incorporated herein by reference to Post-Effective Amendment No. 70 to Form N-4 Registration Statement (File No. 33-33085) filed on April 29, 2021,

Note 59.		Incorporated herein by reference to Post-Effective Amendment No. 47 to Form N-4 Registration Statement (File No. 33-33085) filed on November 19, 2009.

Note 60.		Incorporated herein by reference to Post-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-186031) filed on February 21, 2014.


Note 61.		Incorporated herein by reference to Post-Effective Amendment No. 12 to Form N-4 Registration Statement (File No. 333-189435) filed on August 8, 2016.

Note 62.		Incorporated herein by reference to Post-Effective Amendment No. 10 to Form N-4 Registration Statement (File No. 333-185573) filed on April 30, 2018.

Note 63.		Incorporated herein by reference to Pre-Effective Amendment No. 2 to Form N-4 Registration Statement (File No. 333-189435) filed on October 2, 2013.

Note 64.		Incorporated herein by reference to Post-Effective Amendment No. 4 to Form N-4 Registration Statement (File No. 333-186029) filed on October 13, 2015.

Note 65.		Incorporated herein by reference to the Initial Filing of Form N-4 Registration Statement (File No. 333-215598) filed on January 18, 2017.

Note 66.		Incorporated herein by reference to Post-Effective Amendment No. 67 to Form N-4 Registration Statement (File No. 33-33085) filed on April 30, 2018.

Note 67.		Incorporated herein by reference to Post-Effective Amendment No. 11 to Form N-4 Registration Statement (File No. 333-185573) filed on April 25, 2019.


Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
25 East 38th Street, LLC	Delaware	Sole Member: Yarra Rapids, LLC	Real estate investments
239 West 20th Street, LLC	Delaware	Sole Member: Yarra Rapids, LLC	Real estate investments
313 East 95th Street, LLC	Delaware	Sole Member: Yarra Rapids, LLC	Real estate investments
319 East 95th Street, LLC	Delaware	Sole Member: Yarra Rapids, LLC	Real estate investments
AEGON Affordable Housing Debt Fund I, LLC	Delaware	Members: AHDF Manager I, LLC (0.01%), Mangaging Member; Transamerica Life Insurance Company (5%); non-AEGON affiliates: Dominium Taxable Fund I, LLC (94.99%)	Affordable housing loans
AEGON AM Funds, LLC	Delaware	AEGON USA Investment Management, LLC is the Manager; equity will be owned by clients/Investors of AEGON USA Investment Management, LLC	To serve as a fund for a client and offer flexilbility to accommodate other similarly situated clients.
AEGON Asset Management Services, Inc.	Delaware	100% AUSA Holding, LLC	Registered investment advisor
Aegon Community Investments 50, LLC	Delaware	Members: Aegon Community Investments 50, LLC (0.10%); Transamerica Financial Life Insurance Company (25.49750%); Transamerica Life Insurance Company (25.49750%); non-AEGON affiliate, Citibank, N.A. (48.9950%)	Investments
Aegon Community Investments 51, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments
Aegon Community Investments 52, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments
Aegon Community Investments 53, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments
Aegon Community Investments 54, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments
Aegon Community Investments 55, LLC	Delaware	Sole Member - Transamerica Life Insurance Company	Investments
Aegon Community Investments 56, LLC	Delaware	Sole Member - Transamerica Life Insurance Company	Investments
Aegon Community Investments 57, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments
Aegon Community Investments 58, LLC	Delaware	Sole Member: Transamerica Life Insurance Company	Investments


Name	Jurisdiction of Incorporation	Percent of Voting Securities Owned	Business
Aegon Workforce Housing JV 4C, LLC	Delaware	Members: Aegon Workforce Housing Fund 2 Holding Company, LLC (10%); non-affiliates of AEGON: Strategic Partners Real Estate VII Investments, L.P. (45%), Landmark Real Estate Partners VIII, L.P. (43.295445%), NCL Investments II, L.P. (1.704555%)	Investments
Aegon Workforce Housing Park at Via Rosa REIT, LLC	Delaware	Sole Member: Aegon Worforce Housing Separate Account 1, LLC	Multifamily private equity structure with third- party Investor
Aegon Workforce Housing Separate Account 1, LLC	Delaware	Members: Transamerica Life Insurance Company (20.08%); Transamerica Financial Life Insurance Company (4.170%); non-affiliates of AEGON: Lake Tahoe IV, L.P. (23.860%); Townsend RE Global Special Solutions, L.P. (10.230%); Townsend Real Estate Alpha Fund III, L.P. (40.910%). Member Manager: AWHSA Manager 1, LLC.	Multifamily private equity structure with third- party Investor
AHDF Manager I, LLC	Delaware	Sole Member: AEGON USA Realty Advisors, LLC	Investments
ALH Properties Eight LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Eleven LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Four LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Nine LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Seven LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Seventeen LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Sixteen LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Ten LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Twelve LLC	Delaware	Sole Member: FGH USA LLC	Real estate
ALH Properties Two LLC	Delaware	Sole Member: FGH USA LLC	Real estate
AMFETF Manager, LLC	Delaware	Sole Member: AEGON USA Realty Advisors, LLC	Investments
AMTAX HOLDINGS 308, LLC	Ohio	TAHP Fund II, LLC - 100% Member; TAH Pentagon Funds LLC - non-owner Manager	Affordable housing
AMTAX HOLDINGS 347, LLC	Ohio	TAHP Fund II, LLC - 100% Member; TAH Pentagon Funds LLC - non-owner Manager	Affordable housing


Name	Principal Business Address	Position and Offices with Underwriter
Brian Beitzel	(2)	Director, Treasurer and Chief Financial Officer
Mark Halloran	(3)	Director, Chairman of the Board, Chief Executive Officer and President
Doug Hellerman	(3)	Director, Chief Compliance Officer and Vice President
Timothy Ackerman	(3)	Director and Vice President
Jennifer Pearce	(3)	Director and Vice President
Gregory E. Miller-Breetz	(1)	Secretary